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Record

Draft: efta02782659

EXHIBIT D

VS.

MAXWELL

Deposition

05/03/2016

Agren B/undo Court Reporting & Video, Inc.

216 16th Street, Suite 600

Denver Colorado, 80202

303-296-0017

IN THE UNITED STATES DISTRICT COURT 1 Pursuant to Notice and the Federal Rules SOUTHERN DISTRICT OF NEW YORK 2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF Civil Action No. 15-cv-07433-RWS 3 called by Defendant, was taken on 4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150 May 5 East 10th Avenue, Denver, Colorado, before Kelly A. 6 Mackereth, Certified Shorthand Reporter, Registered 7 Professional Reporter, Certified Realtime Reporter 8 and Notary Public within Colorado. 9

ill.MIEOTAPED

Plaintiff,

v. GHISLAINE MAXWELL, Defendant.

10 INDEX

11 EXAMINATION PAGE MS. MENNINGER 8

APPEARANCES: 12

FAMER, JAFFE, WEISSING, EDwARDS, FISTOS & 13 LEHRMAN, P.L. By Brad Edwards, Esq. 14 PRODUCTION REQUEST(S): 425 N. Andrews Avenue Suite 2 15 (None.) Fort Lauderdale, FL 33301 Phone: 954.524.2820 bradepathtolustice.corn rAzine:irring on behalf of the ff

16 17 18

BOLES, SCHILLER & FLEXNER LLP 19 By Sigrid S. McCawley, ESQ. (For Portion) 401 East Las OLas Boulevard 20 Suite 1200 Fort Lauderdale, FL 33301-2211 21 Phone: 954.356.0011 smccawleyebsfIlp.com 22 Appearing on behalf of the Plaintiff 23

24 25

Page 2 Page 4

1 APPEARANCES: (Continued) 1 INDEX OF EXHIBITS 2 HADDON, NI RQtNI AND RgMAN, P.C. 2 YJdgy ri itic2, r q. 3 S.. Pa sg. 3 DESCRIPTION REFERENCE East 10 P4Fue 47410 5 mericiinarRrp4rai waw.com 5 TriaIre Jane Doe No. 102 v. f gyea&to on befit C)? r the e endarlt

INITIAL

4

4H. 64 Exhibit 1 Complaint and Demand for Jury 17 Jeffrey Epstein

6 7 6 7

Exhibit 2 lane Doe #3 andiane_Doe #4's 21 Motion Pursuant to Rule 21 for Joinder in Action

Also Present: . -r iggS R P.dRaftt; Pa rA eRcleographer 9 9

8

8

Exhibit of Virginia L. arration re Jane Doe #1 and Jane 10 to - America vs. United States of

11 11 Exhibit 4 Declaration of Jane Doe 3 re 31 12 12 ?Jill1 te 5 1 Set ates er aadAli icDaoe #2 vs.

13 13 Exhibit 5 Mt n of 33 re J. Ed 14 14 vs. m isell

15 15

Exhibit 6 documentation, date of entry 36 16 16 7/ 5/ FBI 13

17 17 Exhibit 7 Document tit ed Telecon, 39 Participa Brad is is EtZ214Z' . , JFH, (23 pages of tr nscrIption)

19 19

20 20 Exhibit 8 tlayboy Club, 41 21 21 By

Exhibit 9 Plaintiff's Response and 44 _. Objections to Defendants First 23 23 Rlaintifrre VINeasxlefi

22 22

1INITIAL
2 DESCRIPTIONREFERENCE
Exhibit 10 Plaintiffs Supplemental46
4 Response and Obiections to
Defendant's First Set of 5 Discovery Requests to Plaintiff
6 Exhibitated Declaration of re Plaintiffs
7ental Response and
Objections tO Defendant's First 8 Set of Discovery Requests servedon March 22, 2016
Exhibit 12 Plaintiffs Second AmendedSupplemental Response and ObjeCtions to Defendant's First Set of Discovery Requests to Plaintiff47
Exhibit 13 Mrs.resume67
Exhibit 14 ComaPosition -re Open 68
Exhibit 15 IIIIIMM appassport180
Exhibit 16 Composite of e-mail strings251
Exhibit foliationof e-mails between and Silva and others259
Exhibit Sofof e-mails between and Sandra265
Exhibit 19 Compilation of elligween fe Strong and269
23 Exhibit foffe-mails between and Jason
CE 46 7 7 68 80 51 259 265 2691 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21in the matter of versus Ghislaine Maxwell. for the record. Ghislaine Maxwell.
27623being first duly sworn in the above cause, was
24examined and testified as follows:
25MR. EDWARDS: Just before we get started,
1INITIAL
2 DESCRIPTIONREFERENCE
Exhibit 21 Compilation of e-een 284
4 IChurcher and Exhibit 22 Compilation of e-mails r, Michael and other Exhibit 23 Compilation of May 20100ffils 288
isSharon Churcher, Paulo Silva and o
Exhibit 24 Comp'011 e-mails 289
between Sharonand
Exhibit 26 PR Hub Statement on Behalf of 300 Ghislaine Maxwell article
Exhibit 27 112/15 e-mail from to 309 To Whom It May Con
1I just wanted to make sure that we're clear, and I
2think that we are, that this deposition in total will
3be treated as confidential until such time as we are
4able to review and de-designate.
QAnd where do you live right now,
Good morning, Laura.
QAll right. And who lives with you there?
AMy son, my other son, my daughter, my
QAnd when did you return to the U.S. for
AI believe It was around Thursday, the
QOkay. And who traveled with you?
AMyself.

Q Yourself? 2 A Yes. 3 Q Are you able to travel freely between the 4 U.S. and Australia? 5 A Yes. 6 9 Are you married? 7 A Yes. 8 Q To whom? 9 A 10 Q All right. And did Mr. travel 11 with you back to the U.S.? 12 A No. 13 Q All right. Have you taken any medications 14 in the last 24 hours? 15 A I have taken -- I have a cold, but I have 16 taken non-drowsy cold tablets and some DayQuil. 17 Q All right. Anything else? 18 A No. 19 9 All right. And what is your current 20 profession,-? 21 A I'm a housewife. 22 Q All right. And how long have you been a 23 housewife? 24 A For the last ten years, since I've had 25 kids.

1 under oath? 2 A Yes. 3 Q What does it mean to you? 4 A To tell the truth, the whole truth and 5 nothing but the truth. 6 Q All right. And what does the word truth 7 mean to you? 8 A To be honest. 9 Q Is there more than one truth? 10 A Is there more than -- no, there's no more 11 than one truth. 12 Q If you are confused by a question, you 13 need to let me know that so I can clarify the 14 question, okay? 15 A Okay. 16 Q For example, if I asked you the question 17 were you sexually trafficked to foreign presidents, 18 do you understand what that question means? 19 A Yes. 20 9 What does it mean? 21 A Was I lent out for the purposes of sex to 22 a foreign person -- president. 23 Q All right. And what is the answer to that 24 question? 25 A Yes.

1 Q All right. And what was your profession 2 in 2014? 3 A A housewife. 4 Q All right. Any other profession? 5 A No. 6 Q All right. You understand that you're 7 under oath today? 8 A Yes. 9 Q And you understand that if you don't 10 understand a question, you need to let me know that. 11 A Okay. 12 Q And ask for clarification. 13 A Urn-hum. 14 Q Do you understand? 15 A Yes. 16 Q You also understand, I'm assuming, that 17 you have to say yes or no in answer to a question, or 18 you have to make a verbal response and not just shake 19 your head or something -- 20 A Yes. 21 Q -- so the court reporter can get it. 22 You have -- you have been deposed before, 23 correct? 24 A Yes. 25 Q Do you understand what it means to be

1 Q And If I ask you have you met any foreign 2 presidents, do you understand what that question 3 means? 4 A Yes. 5 Q And what is the answer to that question? 6 A Yes. 7 Q All right. And if I asked you which 8 foreign presidents have you met, do you understand 9 what that question means? 10 A Yes. 11 Q What is the answer to that question? 12 A What is the name of the person? 13 Q Yes. Who are the foreign presidents that 14 you have met? 15 A I honestly can't remember his name at this 16 time. I'm a very visual person so -- 17 Q All right. Can you describe him, then? 18 A Yes. He's Spanish. 19 Q Okay. 20 A Tall, dark hair. 21 Q All right. Anything else? 22 A And he's got a foreign tongue, accent. 23 Q And what age, approximately? 24 A Was I or was he? 25 Q Was he.

1 A I'd say in his 40s. 2 Q Okay. And where did you meet him? 3 A I believe it was New Mexico. 4 Q New Mexico? 5 A Possibly New Mexico. I'm sorry. It's 6 really hard to go back and remember lots of different 7 events with lots of different people. 8 Q Okay. And is that the only foreign 9 president that you have met? 10 A I've met a lot of very high, powerful 11 people and I wasn't just introduced to them as who 12 they were. It's only going back through photos in 13 time to be able to realize who they are and what they 14 are now. So it's hard for me to distinguish who I've 15 actually met and when and where I've met them. 16 Q So to your knowledge, you have only met 17 one foreign president? 18 A To my knowledge at this time, yes. 19 Q And is there anything that might change 20 your knowledge at a different time? 21 A If I were to see more photos of other 22 people. I mean, I've been able to distinguish the 23 majority of the people I've been lent out to, but 24 who's to say there's not more. 25 Q All right. If I were to ask you the

A Yes. 2 Q And which ones did you review? 3 A I'd have to see which ones you're 4 specifically talking about. There's quite a lot of 5 statements I've made. 6 Q Right. And which ones do you recall 7 having reviewed before you attended this deposition 8 today? 9 A I've reviewed my affidavit. I'm not a 10 lawyer so I really don't know legal terms to half of 11 the, you know, legal jargon of statements, which they 12 are. If you showed me, I'd be able to tell you if 13 I've seen it or not. 14 Q Okay. So to your knowledge, can you 15 identify any sworn statement you reviewed before 16 attending the deposition today? 17 A Could I name what the statement is? 18 Q Right. 19 A The actual piece of paper that has the 20 title at the top? 21 Q Right. 22 A No, I don't. 23 Q Can you describe it in any other fashion? 24 A I don't understand. I'm sorry. 25 Q That's all right. You have to tell me if

2 3 A 4 5 question? question how many times have you had sex with= do you know what that question means? I believe so. All right. And what is the answer to that 6 A I believe I was with once. 7 Q Okay. I would like to ask you about your 8 prior sworn statement. 9 You understand you're under oath today, 10 correct? 11 A Yes. 12 Q All right. You've previously made 13 statements under oath, correct? 14 A Yes. 15 Q And you've previously authorized pleadings 16 to be filed on your behalf, correct? 17 A Yes. 18 Q By various attorneys, right? 19 A Yes. 20 Q All right. You have included in your 21 sworn statement allegations about my client, 22 Ghisiaine Maxwell, correct? 23 A Yes. 24 Q And did you review any of those prior 25 sworn statements before appearing here today?

I you don't. 2 Do you have any reason to believe that any 3 of your previous sworn statements that you have made 4 are not true? 5 A No. 6 MR. EDWARDS: I just object and ask that 7 if we're going to ask the witness questions about any 8 of her statements in whole or in part that the 9 witness be allowed to see the statement, review the 10 statement and then answer your questions. 11 Q (BY MS. MENNINGER) You may answer the 12 question. 13 A Can you reask the question? I'm sorry. 14 Q Do you have any reason to believe that any 15 of your prior sworn statements are untrue? 16 A I have no reason to believe that my prior 17 statements are untrue. 18 Q Has anyone told you to say something that 19 was not true in connection with this case? 20 A No, ma'am. 21 Q All right. I'd like to start with a 22 lawsuit that you filed under the caption Jane Doe 23 versus Jeffrey Epstein. 24 Do you recall that lawsuit? 25 A I believe so.

1 (Exhibit 1 marked.)

2 Q (BY MS. MENNINGER) I'm going to show you 3 an exhibit that we are marking as Defendant's

4 Exhibit 1.

5 MR. EDWARDS: Can 1 see that for a second?

6 I'd Just like to make an objection on the 7 record for the misidentification of this document.

8 While there was a lawsuit filed under the

9 style of Jane Doe versus Jeffrey Epstein, Jane Doe

10 was not And the lawsuit that's now

11 being handed to this witness Is Jane Doe 102 versus

12 Jeffrey Epstein.

13 Is that the document we're talking about?

14 MS. MENNINGER: Counsel, if you have an

15 objection, you should state the basis for your

16 objection In a non-leading, non-suggestive manner.

17 If you have any other record to make, you

18 can do so in a pleading filed with the Court.

19 MR. EDWARDS: Sure. My objection Is

20 you've misrepresented what you've handed the witness.

21 1 want to make sure that the witness is holding what

22 you actually want her to be holding as opposed to the

23 lawsuit you said that you were going to hand her.

24 That's R.

25 MS. MENNINGER: Counsel, I will ask the

2 A I can see paragraph 23.

3 Q Okay. And do you see that there are

4 allegations about a Ms. Maxwell contained in that 5 complaint?

6 A Yes, I do.

7 Q All right. And do you understand that to

8 be Ghislaine Maxwell, my client?

9 A Yes.

10 Q All right. And Ms. Maxwell was not sued

11 as a part of this case, correct?

12 MR. EDWARDS: Object to the form.

13 THE DEPONENT: Does that mean I can

14 answer?

15 MR. EDWARDS: Sure, you can answer.

16 MS. MENNINGER: Right.

17 MR. EDWARDS: If you understand the

18 question, answer it.

19 A Yes, Ms. Maxwell -- sorry, repeat the

20 question.

21 Q (BY MS. MENNINGER) Was Ms. Maxwell sued 22 in this --

23 A No, she wasn't.

24 Q in the case that's represented by

25 Defendant's Exhibit 1?

1 2 witness questions about the document. I did not ask you any questions about the document.

3 Q (BY, could you

4 please take a look at what we have marked as

5 Defendant's Exhibit 1.

6 Do you recognize that document,

7

8 A I believe so. Yes. Yes, I do.

9 Q And do you see that the counsel on the

10 last page -- I'm sorry, not the last page, but the

11 third from the last page are Mr. Josefsberg and

12 Ms. Ezell from Podhurst Orseck?

13 A Yes.

14 Q Were those your lawyers?

15 A Yes, they were.

16 Q And did you authorize them to file Jane

17 Doe 102 versus Epstein on your behalf?

18 A Yes, I did.

19 Q And is that this complaint that's been

20 marked as Defendant's Exhibit 1?

21 A I believe so.

1 A No, she wasn't. I'm sorry for

2 interrupting you. But no, she was not sued at this

3 time, no.

4 Q And why not?

5 MR. EDWARDS: I'd object and ask the

6 witness not answer that question because that would

7 be privileged, attorney-client privileged,

8 information that was between and the

9 Podhurst Orseck firm at that time.

10 So I'm instructing you not to answer.

11 Q (BY MS. MENNINGER) All right.

12 did you make a decision yourself whether

13 or not to sue Ms. Maxwell as a part of this lawsuit

14 against -- Jane Doe 102 versus Jeffrey Epstein?

15 A I think I've been advised not to answer

16 that question.

17 Q This is a different question.

18 A e okay.

19 Q So your counsel can assert a privilege,

20 21 but that question did not call for privileged information.

Page 21 1 versus Epstein was filed? 2 MR. EDWARDS: And I disagree. And I 3 object to this invading the attorney-client 4 privilege. 5 And I'm instructing you not to answer. 6 Q (BY MS. MENNINGER) Can you answer that 7 question without revealing any attorney-client 8 communications, whether you made a decision to file a 9 lawsuit or not? 10 A Fm going to have to listen to my attorney 11 and not answer the question. 12 Q All right. I would like to show you some 13 documents that were filed in what we'll call the CVRA 14 case, the Crime Victims' Rights Act case. 15 Do you know what I mean by that reference? 16 A 1 am familiar with that. 17 Q Okay. I'm going to start with one on or 18 about December 30th, 2014. We will mark it as 19 Defendant's Exhibit 2. 20 (Exhibit 2 marked.) 21 MR. EDWARDS: Thank you. 22 Q (BY MS. MENNINGER) All right. 23 MM. do you recognize Defendant's Exhibit 2? 24 A Yes. 25 Q And what do you understand it to be?

Page 23 1 CVRA action in or about December 30th, 2014, correct? 2 A I -- I'm not aware of the exact dates. 3 There's no dates on this. But I did try to Join the 4 motion, yes. 5 Q All right. If you can look at the top 6 line of the document. 7 A Yes. 8 Q Does it say, Entered on FLSD -- 9 A Oh, it does, too, I'm sorry, yes. 10 Q That's all right. So does that refresh 11 your memory as to about when you first sought to Join 12 the CVRA action? 13 A Yes. 14 Q December 30th, 2014, correct? 15 A Yes. 16 Q And the corrected motion was filed a few 17 days later, correct? 18 A Yes, correct. 19 Q If I could turn to Defendant's Exhibit 3, 20 which was January 21st. 21 (Exhibit 3 marked.) 22 MR. EDWARDS: Thank you. 23 Q (BY MS. MENNINGER) Do you recognize this 24 document? 25 A Yes, I do.

Page 22

1 A I believe this is when I was hoping to 2 join the CVRA case. 3 Q All right. And do you know when this 4 document was filed? 5 And actually, just to be clear, about 6 halfway there's actually a second document that was 7 filed. So this is a composite exhibit. Let me be 8 very clear. 9 So after page 14 -- I'm sorry, 13, there's 10 a second document that is styled Jane Doe #3 and Jane 11 Doe #4's Corrected Motion Pursuant to Rule 21 for 12 Joinder In Action. 13 Do you see that? 14 A Did you say page 14? 15 Q It is on the 14th page of this document. 16 Do you see that? 17 A I do. 18 Q And so this composite Exhibit 2 has both a 19 motion and a corrected motion. 20 Do you see that? 21 A Yes. 22 Q And were both of those pleadings 23 authorized by you to be filed? 24 A Yes. 25 Q In other words, you wanted to join the

Page 24

1 Q What do you understand this document to 2 be? 3 A It's a rough background of the years that 4 I was abused by Ghislaine and Jeffrey. 5 Q All right. And this is something I 6 believe that you on page 15 signed; is that true? 7 A Just let me have a look. Q Sure. 9 A I think I'm actually missing page 15. Oh, 10 here we go. 11 Q Sorry. I'm looking at the numbers on the 12 top right. I apologize. I believe there was some 13 cover page or something that was excluded. 14 MR. EDWARDS: And just for the record, I'm 15 going to object to the relevance of this document. 16 I'm going to allow the witness to answer the 17 question, but I want my objection on the record. 18 MS. MENNINGER: Okay. Simple objection, 19 relevance. 20 A Are we talking about this page? 21 Q (BY MS. MENNINGER) Yes, the one with the 22 black box, yes. Do you believe that to have 23 contained your signature? 24 A Yes. 25 Q All right. And you executed that on

2 A At the very top of the page it says 3 January 21st, 2015.

4 Q The date it was filed. Is there a date 5 just above the signature block?

6 A Oh, yes, sorry. Yes, there is.

7 Q And what date -- what date was that?

8 A The 19th day of January, 2015.

9 Q Okay. And this document is something that 10 you believe contains the truth, correct?

11 A To the best of my knowledge at the time, 12 yes.

13 Q All right. Did something change between 14 the time then and today that makes you believe that 15 It's not all accurate?

16 A Well, as you can see, in line 4 on page 1, 17 I wasn't aware of my dates. I was just doing the 18 best to guesstimate when I actually met them.

19 Since then I've been able to find out that 20 through my Mar-a-lago records that it was actually 21 the summer of 2000, not the summer of 1999.

22 Q Oh, I'm sorry. Are you back on page 1?

23 A On the first page.

24 Q Okay.

25 A Yes.

2 MR. EDWARDS: Object to the form.

3 A I wouldn't say that it wasn't true. I was 4 Just unaware of the times and the dates.

5 Q (BY MS. MENNINGER) Again, is there more 6 than one truth, M ?

7 A No, there's no more than one truth.

8 Q All right. So a document in which you 9 swore that you were 15 years old when you met

10 Ms. Ghislaine Maxwell is an untrue statement, 11 correct?

12 MR. EDWARDS: Object to the form.

13 A It's not that It's an untrue statement.

14 It was a mistake. So It wasn't intentionally trying 15 to say something that wasn't true. It was to my best 16 knowledge that I thought it was 1999. And when I got 17 my records from Mar-a-Lago I was able to find out 18 that It was 2000. And this was entered before I 19 found out the actual dates that I did work at 20 Mar-a-Lago.

21 Q (BY MS. MENNINGER) Okay. So a document 22 that you filed under oath --

23 A Um-hum.

24 Q is now, you believe to be untrue,

25 correct?

1 Q And you're talking about line 4?

2 A Line 4.

3 Q Paragraph 4 or line 4?

4 A Oh, sorry. Number 4, the paragraph 5 number 4.

6 Q Okay. And what part of paragraph 4 do you 7 now believe to be untrue?

8 A In approximately --

9 MR. EDWARDS: Object to the form.

10 You can answer.

11 A In approximately 1999 when I was 15 years 12 old I met Ghislaine Maxwell.

13 Q (BY MS. MENNINGER) Okay.

14 A I now know that it was 2000, that I was 16 15 years old when I met Ghislaine Maxwell.

16 Q So when you signed this document under 17 penalty of perjury stating that it was true, you no 18 longer believe that to be true, correct?

19 A It was an honest mistake. We had no idea 20 how to pinpoint without any kind of records or dates 21 or anything like that. I was just going back 22 chronologically through time. And that's the best 23 time that I thought it was. And now I know the 24 facts, so it's good to know.

1 MR. EDWARDS: Objection. Asked and 2 answered.

3 Q (BY MS. MENNINGER) You may answer.

4 MR. EDWARDS: Answer again.

5 A Again, I wouldn't say its untrue. Untrue 6 would mean that I would have lied. And I didn't lie.

7 This was my best knowledge at the time. And I did my 8 very best to try to pinpoint time periods going back 9 such a long time ago.

10 It wasn't until I found the facts that I

11 worked at Mar-a-Lago in 2000 that I was able to 12 figure that out.

13 Q (BY MS. MENNINGER) And approximately when 14 did you learn those facts about the dates you worked 15 at Mar-a-Lago?

16 A I would say it was mid-2015

17 Q Mid-2015 is the first time you became 18 aware of the dates --

19 A I don't know the exact --

20 Q If you could just let me finish.

21 A I'm sorry.

22 Q That's all right. Approximately mid-2015

23 when you learned the true dates that you had worked 24 at Mar-a-Lago?

1 Q And based on the fact that you learned the 2 fact you had worked at Mar-a-Lago in 2000 -- you 3 became aware in mid-2015 -- 4 A Urn-hum. 5 Q -- that you had met Ms. Maxwell in 2000, 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 correct? A That's -- MR. EDWARDS: Object to the form. A That's correct. Q (BY MS. MENNINGER) All right. And you became aware in mid-2015 that you were not 15 years old when you met Ghislaine Maxwell, correct? MR. EDWARDS: Object to the form. A That's correct. Q (BY MS. MENNINGER) Okay. And who provided you those Mar-a-Lago records in approximately mid-2015? MR. EDWARDS: I'm going to object. And to the extent that this invades the attorney-client privilege, if it was your attorneys that you spoke to and learned this information or received this information from, then you're instructed not to answer. A I cannot answer that question. Q (BY MS. MENNINGER) Did you yourself look

Page 31

1 Q (BY MS. MENNINGER) I'm going to show you 2 an exhibit filed on, I believe on or about 3 February 6th of 2015. Defendant's Exhibit 4. (Exhibit 4 marked.) 5 MR. EDWARDS: Thank you. 6 Q (BY MS. MENNINGER) And drawing your 7 attention to the heading line that says, Entered on 8 the docket February 6th, 2015. 9 Do you see that? 10 A Yes. 11 Q All right. And Declaration of lane Doe 3, 12 do you see that on the first page? 13 A Yes. 14 Q And it's in the CVRA case, correct, Jane 15 Doe 1 and lane Doe 2 versus United States of America? 16 A Yes. 17 Q All right. And do you recognize this 18 document? 19 A Yes. 20 Q And what do you understand this document 21 to be? 22 A I believe it's more reason to why I should 23 have been added to the CVRA case. 24 MR. EDWARDS: Objection to the relevance, 25 Counsel.

Page 30

1 at records in the middle of 2015 regardless of who 2 showed them to you? 3 MR. EDWARDS: Objection. And to the 4 extent that they were showed to yOu Or shared by any 5 of your lawyers, you're instructed not to answer the 6 question. It invades the attorney-client privilege. 7 Q (BY MS. MENNINGER) Did you look at 8 Mar-a-Lago records in the middle of 2015 yourself? 9 MR. EDWARDS: She's not answering the 10 question. 11 MS. MENNINGER: On what grounds is she not 12 answering the question? 13 MR. EDWARDS: I just told you it invades 14 the attorney-client privilege. If she learned -- 15 I will instruct her if she learned by some 16 other way than her attorneys sharing the information 17 with her, then she can answer the question. 18 Q (BY MS. MENNINGER) I'm asking you not to 19 tell me whether your attorneys showed you the record. 20 I'm asking you not to tell me the source of the 21 record. 22 I'm asking you if you personally in the 23 middle of 2015 looked at Mar-a-Lago records? 24 MR. EDWARDS: Same objection. 25 Same instruction.

1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q (BY MS. MENNINGER) Okay. And again, if you look to the last page of the document, paragraph 67 -- A The last page? Q Yes, the very last. A 67, yes. Q All right. It says in paragraph 67: I declare under penalty of perjury that the foregoing is true and correct, right? A Yes. Q And it was executed on or about the 5th day of February, 2015, correct? A It's a bit smudged, but it kind of looks like a 5. Q All right. And then there's a signature block that's redacted that says lane Doe 3, correct? A Correct. Q Do you believe that you signed this document and it was later covered up by that block? A Yes. Q All right. And again, is there anything in this document that you believe today to not be true? MR. EDWARDS: I just ask that you read through the entire document and answer the question.

Page 32

1 Q (BY MS. MENNINGER) Have you seen this 2 document before, 3 A I'm sure I have, but its always good to 4 refresh your memory just looking over something. 5 Q All right. 6 (Pause.) 7 A Thank you for giving me time to read that 8 over. 9 Q Certainly. So have you had a chance to 10 read it now? 11 A Yes. 12 Q All right. And what parts of this 13 document sworn by you under penalty of perjury are 14 not true? 15 A Again, the only thing that I see is the 16 mistake that I made, I first met Epstein when I was 17 15 years old. 18 Q Okay. And that's in paragraph 5? 19 A That's in paragraph 5 on the first page. 20 Q All right. And everything else you 21 believe to be true? 22 A Yes. 23 Q Okay. If I could now turn to what I'll 24 mark as Defendant's Exhibit S. 25 (Exhibit S marked.)

Page 35

against-; is that your understanding? 2 It's your understanding. You don't have 3 to look at your lawyer if you don't understand. You don't have to -- 5 A No, I just don't know if I'm allowed -- 6 Q That's all right. 7 A -- to say certain things about that. But, 8 yes, I believe they were in a lawsuit. 9 Q Okay. And that's against 10 right? 11 A Correct. 12 MR. EDWARDS: Object to the form. I 13 object to the relevance of the document. 14 Q (BY MS. MENNINGER) All right. 15 IMMI, again, if you could turn to the last 16 page of this document. And do you see a signature on 17 that page? 18 A Ido. 19 Q Whose signature Is that? 20 A That is mine. 21 Q And approximately when did you sign that 22 document? 23 A Executed this 20th day of November, 2015. 24 Q All right. So you signed that on 25 November 20th, 2015, correct?

Page 34

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 me. 22 Q All right. 23 A And Mr. Cassell is another one of my 24 lawyers. 25 Q All right. And they are in a lawsuit THE DEPONENT: Thank you. MR. EDWARDS: Thank you. MS. MENNINGER: I think I have one more. MS. McCAWLEY: It's okay if you don't. MS. MENNINGER: I don't think I have all of them. Q (BY MS. MENNINGER) All right. Do you recognize Defendant's Exhibit 5? A Yes. Q What is the title of that document? A Declaration of Q And that's you, correct? A Yes. Q And do you recognize which case this declaration was filed in? A Yes. Bradley Edwards and Paul Cassell, Plaintiff versus Q All right. And who do you understand Mr. Edwards and Mr. Cassell to be? A Mr. Edwards is my lawyer sitting next to

Page 36

1 A Correct. 2 Q All right. And that was under penalty of 3 perjury, correct? A Correct. 5 Q All right. If I could now turn to what 6 we'll mark as Defendant's Exhibit 6. 7 (Exhibit 6 marked.) 8 MR. EDWARDS: Thank you. 9 MS. McCAWLEY: Thanks. 10 Q (BY MS. MENNINGER) Do you recognize this 11 document,-'? 12 A Ido. 13 Q All right. What do you believe this 14 document to be? 15 A I believe this is when I spoke to the FBI. 16 Q Okay. And do you remember about when you 17 spoke to the FBI? 18 A It says, Date of entry July 5th, 2013. 19 Q Do you believe that you spoke to the FBI 20 in 2013? 21 A I thought it was 2011 when I talked to 22 them. 23 Q Okay. I'm going to direct your attention 24 to the bottom of that page. 25 A Yes.

Q The first page. Do you see that?

2 A Yes.

3 Q The last few lines there have another

4 date.

5 A • yes, Investigation of, yes.

6 Q All right

7 A So that makes sense, okay.

8 Q Okay. What do you understand that to be?

9 And if it refreshes your recollection about when you 10 spoke to the FBI, just let us know.

11 A Yeah, March 17th, 2011 sounds more right 12 than 2013.

13 Q Okay. And where did you speak to them?

14 A I believe this was in the office of the 15 consulate, American Consulate, in Sydney.

16 Q Sydney, Australia?

17 A Sydney, Australia.

18 Q Okay. And you were there in person with 19 these FBI agents?

20 A Correct.

21 Q And were they taking notes when they spoke 22 to you?

23 A Yes.

24 Q Were they recording the interview, to your 25 knowledge?

1 Q Okay. And have you reviewed any -- have 2 you at any time reviewed this document without those 3 portions whited out?

4 A I don't believe I've seen this document 5 without the portions.

6 Q Okay. So you don't know, for example, 7 what's behind those, other than what you recall --

8 A No.

9 Q having told the FBI at the time, 10 correct?

11 A That's correct.

12 Q Okay. I'm going to show you a new 13 document.

14 A Okay.

15 Q You can just put that to the side.

16 Defendant's Exhibit 7.

17 (Exhibit 7 marked.)

18 Q (BY MS. MENNINGER) All right.

19 MR. EDWARDS: Thanks.

20 Q (BY MS. MENNINGER) And do you recognize 21 this document?

22 A Yes.

23 Q And what do you understand it to be?

20 A This was a phone conversation that I had 25 between Jack Scarola and Brad Edwards.

1 A I believe they were.

2 Q Okay. Have you had a chance to review 3 this report?

4 And I will make note for the record that 5 there are obviously many places that are blacked 6 out --

7 A Yeah.

8 Q -- or whited out. Is that fair?

9 A Yes.

10 Q All right. Have you had a chance to 11 12 review this one with whited-out portions of it before today?

13 A Yes.

14 15 16 Q All right. And you understood when you were speaking to the FBI that they were federal agents, correct?

17 A Yes.

18 19 Q And that you were supposed to tell them the truth, correct?

20 A Absolutely.

21 22 Q And do you believe that you did, in fact, tell them the truth?

1 Q Okay. And do you see a date reflected on 2 the front page?

3 A April 7, 2011.

4 Q Is that when you had that phone 5 conversation with them?

6 A If it's dated like that, it must be, yes.

7 Q Well, I just need you to say from your 8 memory, does that sound about right in terms of what 9 you recall having been the phone conversation?

10 A I'm sure it's correct.

11 Q Okay.

12 A I don't have a good calendar in my brain.

13 So, yes, I'm sure that that's the correct date.

14 Q Did you understand it was being recorded, 15 correct?

16 A Yes.

17 Q Okay. Have you listened to the recording 18 of that phone call?

19 A I don't believe I listened to the

20 recording, but I have seen the document.

21 Q All right. And again, you were speaking 22 the truth at the time you were speaking to them as

1 Q Okay. And then the last -- the last 2 document, I hope, is -- 3 MS. MENNINGER: The big one. 4 (Exhibit 8 marked.) 5 Q (BY MS. MENNINGER) All right. Do you 6 recognize -- I'm going to -- I'm sorry, if I didn't 7 say it already. This is Defendant's Exhibit 8. 8 Do you recognize this document?

9 A Yes, I do. 10 Q And what is this document? 11 A This is a manuscript that I was writing, I 12 believe, back in 2011 regarding some of my life 13 story. And just to make it known, this is a based on 14 true events. But I wouldn't say fictional, but just 15 based on true events. 16 Not everything in it is -- not everything 17 is in there and not everything is, you know, correct. 18 So there's a few mistakes in there. 19 Q Okay. Off the top of your head, do you 20 recall any mistakes that are in there now without 21 reading the 140-page document? 22 MR. EDWARDS: We're going to be here a 23 long time. 24 A Yeah, we could be here a very long time. 25 I mean, I'd like to say a majority of it is correct.

1 as you sit here right now, is there anything in that 2 manuscript about Ghislaine Maxwell that is untrue? 3 A I don't believe so. Like I said, there is 4 a lot of stuff that I actually have left out of here. 5 Q Um-hum. 6 A So there is a lot more information I could 7 put in there. But as far as Ghislaine Maxwell goes, 8 I would like to say that there Is 99.9 percent of it 9 would be to the correct knowledge. 10 Q All right. Is there anything that you -- 11 and I understand you're doing this from memory. Is 12 there anything that you recall, as you're sitting 13 here today, about Ghislaine Maxwell that is contained 14 in that manuscript, that is not true? 15 A You know, I haven't read this in a very 16 long time. I don't believe that there's anything In 17 here about Ghislaine Maxwell that is not true. 18 MR. EDWARDS: I'd Just ask, Counsel, if 19 you have anything specific to show her about 20 Ghislaine Maxwell -- 21 MS. MENNINGER: I'll ask questions. 22 MR. EDWARDS: -- I'll have her look at it. 23 MS. MENNINGER: I'll ask questions. 24 MR. EDWARDS: I know, but I want the 25 record clear that if she hasn't read it in a long

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Some names have been changed in order to protect other people. Q (BY MS. MENNINGER) Protect their privacy? A Protect their privacy, yeah, I would say, just not getting them involved in, if this were to ever go public. Q Well, again, without rereading the whole manuscript -- A Reading it, yeah. I'm trying to see if I can -- see something in here. Q Let me narrow my question and maybe that will help. A Yes. Q Is there anything -- well, first of all, did you author that entire manuscript? A Yes, I did. Q Did anyone else author part of that manuscript? A Do you mean did anyone else write this with me? Q Right. A No. Q That's all your writing? A This is my writing. Q Okay. To the best of your recollection,

1 time, she -- 2 MS. MENNINGER: She made the record very 3 clear. Thank you. She doesn't need you to make a 4 record. 5 MR. EDWARDS: I'm not making records, but 6 you're making this last longer. There's no need for 7 this. This doesn't have to be an unpleasant process. 8 I want her to help you. 9 MS. MENNINGER: I don't find it 10 unpleasant. I'm sorry if you do. 11 MR. EDWARDS: Okay. Well, then, I object 12 to that last series of questions to the extent that 13 she was unable to look at what you wanted her to look 14 at. 15 Q (BY MS. MENNINGER) I would like to next 16 turn to a document filed on March 16th of this year. 17 Or actually, let me rephrase that. A document dated 18 March 16th of this year, which we will mark as 19 Defendant's Exhibit 9. 20 (Exhibit 9 marked.) 21 Q (BY MS. MENNINGER) Do you recognize this 22 document, 23 A Yes, I do. 24 Q All right. And what is your understanding 25 of what this document represents?

A Based upon the title, it is Plaintiffs 2 Response and Objections to Defendant's First Set of 3 Discovery Requests to Plaintiff. 4 Q And are you the plaintiff? 5 A I am the plaintiff, yes. 6 Q All right. So It's your response to 7 Ms. Maxwell's discovery request, correct? 8 A Correct. 9 Q All right. And if you look at the last 10 page -- or, I'm sorry, it would be the second to last 11 page -- you might see signatures of your attorney, 12 correct? 13 A I see printed names. 14 Q Printed. Electronic signature -- 15 A Okay. 16 Q -- will have a little Sin front of it. 17 A All right. 18 Q Do you see that? 19 A I can see the, yeah the printed names. So 20 if its electronic signature, then yes. 21 Q All right. And the date on that is 22 March 16th of 2016? 23 A Correct. 24 Q All right. And so without revealing the 25 content of your conversations, you assisted in

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Do you see your attorney's signature and the date, March 22nd, 2016, correct? A I do. Q All right. And then looking at Defendant's Exhibit 11, that's your declaration, correct? A Yes, it is. Q And declaring under penalty of perjury as of March 22nd, 2016 that the supplemental response and objections are true and correct, right? A Correct. Q And you -- that's your signature? A That is mine. Q And you are swearing under penalty of perjury that Defendant's Exhibit 10 is true and correct? A Yes. Q As of March 22nd, 2016, right? A Yes. Q All right. And then one more on that. Defendant's Exhibit 12. (Exhibit 12 marked.) Q (BY MS. MENNINGER) And do you recognize this document? A Yes.

Page 47

Page 46

1 preparing responses to discovery requests, correct? 2 A Yes. 3 Q All right. I'm going to show you a 4 subsequent one marked Defendant's Exhibit 10 and 5 dated March 22nd. 6 (Exhibit 10 marked.) 7 Q (BY MS. MENNINGER) If you can take a look 8 at that. 9 A Thank you. 10 Q And while we're at it, I'm going to give 11 you Defendant's Exhibit 11 so you can look at them 12 together. 13 (Exhibit 11 marked.) 14 Q (BY MS. MENNINGER) All right. 15 A Thank you. 16 Q All right. So looking at Defendant's 17 Exhibit 10, do you recognize that document? 18 A Plaintiffs Supplemental Response and 19 Objections to Defendant's First Set of Discovery 20 Requests to Plaintiff. 21 I've seen a lot of documents, and they all 22 look the same. But I'm sure I've seen it. 23 Q All right. And looking, again, at the 24 last page -- or I'm sorry, this time it will be the 25 third to last page.

Page 48 1 Q Okay. And what is this document? 2 A Plaintiffs Second Amended Supplemental 3 Response and Objections to Defendant's First Set of 4 Discovery Requests to Plaintiff. 5 Q All right. And again, turning to the very 6 rear section, I think you'll see your attorney's 7 signatures again and the date of April 29th, 2016? 8 A I do see that. 9 Q All right. And again, you authorized this 10 document to be filed, correct? 11 A Correct. 12 Q And the statements contained therein are 13 true, to the best of your knowledge, correct? 14 A Correct. 15 Q And that's -- April 29th is just a few 16 days ago, correct? 17 A Yes. 18 Q All right. Did you review this April 29th 19 document before it was filed or served? 20 A Like I said, I've seen a lot of documents 21 and they all look alike, but I'm sure I've seen this 22 one. 23 Q Okay. And if it's something that was 24 served last Friday, does that refresh your 25 recollection that you reviewed it before it was

3 Q And you were here in the U.S. last Friday?

4 A Yes.

5 Q So you saw it in person, correct?

6 A Yes, I was looking at a lot of documents 7 on Friday.

8 Q Okay.

9 A I believe this could definitely be one I

looked at.

Q All right. If I could direct your attention to -- let me see, in that document --

MR. EDWARDS: Exhibit 12?

MS. MENNINGER: Um-hum, Defendant's Exhibit 12.

Q (BY MS. MENNINGER) -- to page -- sorry. You're not the only one who's seen a lot of documents.

Well, without asking you to look at a page, can you tell me what your -- between 1996 and -- well, in 1996 to 2002, what was the first job that you held?

A I believe the first job that I held was in the year 2000, and that was at Mar-a-Lago.

Q Okay. And is that the first job you held

3 I remember he asked me to come in and help him out, 4 and that's -- I didn't really consider myself an 5 employee there, but --

6 Q Just wearing the shirt and getting a 7 paycheck didn't cause you to think you were an 8 employee?

9 A Well --

10 MR. EDWARDS: Object to the form.

11 Mischaracterizes her testimony.

12 A Yeah, I know. I mean, it was my

13 boyfriend. I was helping him out. So that's the way 14 I looked at it.

15 Q (BY MS. MENNINGER) Is there any other 16 place that you wore a uniform and got a check from in 17 the years from '96 to 2000?

18 A I did work at Publix as a bag girl, but 19 that was only for a couple weeks, I think.

20 Q Which Publix was that?

21 A I believe it was in Loxahatchee.

22 Q Okay. Do you remember the street?

23 A No.

24 Q All right. Anywhere else you wore a 25 uniform and got a paycheck?

1 as a teenager or at any point in time, that you 2 recall?

3 A Yes, that I recall.

4 Q All right. Did you ever work at Taco 5 Bell?

6 A My ex-boyfriend used to work there and I

7 would help him out. I was never really -- I don't

8 think I was employed there. He was my boyfriend so I 9 stayed there with him all the time.

10 Q What was his name?

11 A I called him but I think his real 12 name was

13 Q Okay. And so he was employed there, but 14 you were not employed there?

15 A I used to go there and help him out.

16 Q Did you have a uniform?

17 A I would have to wear a shirt when I was 18 there, yes. He was the manager, so --

19 Q S a TacoBellshirt?

20 A Yes.

21 Q Okay. And did you get a paycheck from 22 them?

1 A I volunteered at a bird aviary.

2 Q What was the name of that?

3 A I don't know the name of it. But it 4 was -- I'm an animal lover. So --

5 Q Okay.

6 A -- it's something I enjoyed doing.

7 Q Okay. Did you get a check from them?

8 A I volunteered. I think they eventually

9 put me on some kind of payroll. I don't think it was 10 much, though.

11 Q Okay. So what year were you in helping 12 out in a Taco Bell wearing the uniform and getting a 13 check?

14 A I have no idea when it comes to years.

15 Q Was it before or after Mar-a-Lago?

16 A Before Mar-a-Lago.

17 Q Okay. And how --

18 A Mar-a-Lago was my first real job so --

19 Q What's that?

20 A Mar-a-Lago was like my first real job.

21 Q What do you mean by real job?

22 A Like, you know, fully employed, sit down 23 for an interview and, you know.

1 MR. EDWARDS: Object to the form. 1 2 A Uhm, I don't know, to be honest. 2 you had Immediately prior to Mar-a-Lago? 3 Q (BY MS. MENNINGER) And In what order did 3 A If I were correct, it would be the aviary 4 Taco Bell, Publix and Mar-a-Lago go, and the aviary, 4 that I volunteered at. 5 sorry? 5 Q Okay. And you believe you were living 6 A Oh, I would have to guess. Do you want me 6 with your parents at the time you worked at the 7 to guess? 7 aviary? 8 Q Sure. 8 A Yes. 9 A Urn, I would say Publix. And then, I think 9 Q Okay. And not living with 10 that's when I helped my boyfriend out at Taco Bell 10 A might have been living with me and 11 and then I think the aviary. 11 my parents. 12 Q And where was the Taco Bell? 12 Q Okay. So you recall was living 14 was Fort Lauderdale. Don't quote me on that, but 14 the aviary? 15 somewhere in Florida, Broward County, something like 15 A Yes. 16 that. 16 MS. McCAWLEY: Objection. 17 Q And who were you living with at that time? 17 Mischaracterizes testimony. 20 worked at the Taco Bell, right? 20 Mar-a-Lago? 21 A Yes, I was living with him. 21 A Yes. 22 Q And you worked with Michael when you 22 Q And what address was living with 23 worked at the Publix, correct? 23 you and your parents at the time you started at 24 A No. 24 Mar-a-Lago? 25 Q Okay. So Publix came after Taco Bell or 25 A My parents' address?

Q Months. And what was the job you believe 13 A I was living in Fort Lauder -- I think it 13 with you and your parents at the time you worked at 18 A Michael. His name is James, but Michael. 18 Q (BY MS. MENNINGER) And was living 19 Q So you were living with Michael when you 19 with you and your parents at the time you started at

1 before? 1 Q Whatever address you were living at, at 2 A I think it came -- like I said, don't 2 the time you started at Mar-a-Lago. 3 quote me on it, but I think Publix came before it. 3 A Loxahatchee, Florida 4 Q And who were you living with when you 4 33470. 5 worked at Publix? 5 Q How is it that you came to work at 6 A My mom and my dad. 6 Mar-a-Lago? 7 Q And who were you living with when you 7 A My dad is a maintenance manager or 8 worked at the aviary? 8 supervisor, I don't know what you call it. But he 9 A My mom and my dad. 9 worked in the maintenance department, mostly on 10 Q Anywhere else that you got a paycheck from 10 tennis courts, working on the air conditioning, 11 before 2000? 11 helping set up for functions. And he got me a summer 12 A No, not that I can think of. 12 job there. 13 Q Okay. Anywhere else you wore a uniform? 13 Q Okay. And you said you were on a break? 14 A Besides Mar-a-Lago and -- yeah, that's it. 14 A Yes. 15 Q Okay. And so how long was it between 15 Q What were you on a break from? 16 working at any of those three places and the time 16 A I think like -- this is going back so long 17 that you worked at Mar-a-Lago? 17 now, but I was attempting to get my GED. And it, 18 A I have no idea. I'm sorry. Um -- 18 summer came, so school stops during the summertime 19 Q Years? Months? 19 here in America, and I got a summer job. 20 A Oh, we're going to go back 20 Q All right. And where were you in school? 21 chronologically. I was trying to get my GED and I -- 21 A I don't actually know the name of the 22 there was a summer break. And that's when I started 22 place. It's -- yeah, I know. 23 working for Mar-a-Lago. So that Mar-a-Lago we know 23 Q A GED place? 24 now is in the year 2000. So I would have to say a 24 A Yeah, it was, like, I was previously in 25 month. 25 Royal Palm Beach High School, but, I mean, because of

1 a lot of the circumstances that I had been subjected 2 to, I decided I wanted to get my GEO. 3 Q Okay. So you were going to an actual 4 school to get your GED, that's what you're saying? 5 A Yes. 6 Q And that school, whatever it was, where 7 you were getting your GED was not Palm Beach High 8 School, right? 9 A No. 10 Q And it -- whatever the school was where 11 you were getting your GED took a summer break? 12 A I believe so, yes. 13 Q And that was In 2000? 14 A Now that we know the right dates, yes. 15 Q And that's when your dad helped you get a 16 quote-unquote summer job? 17 A Yes. 18 Q All right. And that summer job was 19 Mar-a-Lago? 20 A Yes. 21 Q Okay. Now tell me how you sort of came 22 into Mar-a-Lago for the first time? He asked you to 23 come? They called you? What happened? 24 A My dad was very liked there. So I think 25 he talked to the people who were in HR. And then

1 Q Locker room attendant was the name? 2 A Of the position? 3 Q Yes. 4 A Yes. 5 Q And did they give you any training? 6 A No. 7 Q Did they show you how to work the lockers? 8 A Well, I mean, there was a girl who already 9 worked there at the front desk. I think she helped 10 make appointments and greeted people, and then she 11 Just told me my duties in the locker room were to, 12 you know, make tea. I had never made tea before, so 13 that was -- that was fun. Learn how to make tea. 14 Clean up after the ladies who had been in the locker 15 room. Make sure the bathrooms were kept nice and 16 tidy. You fold the toilet paper into a little 17 triangle every time anyone went to the toilet. Clean 18 up the sink area. It was a very crazy Job. 19 Q Do you remember the names of any of your 20 coworkers who you worked with at Mar-a-Lago? 21 A I believe the head of the spa area was 22 Adriana or Adrienne. I cant remember exactly. 23 Q Okay. 24 A And the girl who trained me, I have a very 25 clear picture of her face, but I can't remember her

Page 58

1 they said for me to come in for an interview. 2 Q Um-hum. 3 A To be interviewed for a locker room 4 assistant. 5 Q Um-hum. 6 A They liked me. I had to go through a 7 series of drug tests, polygraph tests. I mean, it 8 was a very extensive regime to get a job there. 9 Q Yeah. 10 A And when all those came back good, I 11 started the job. 12 Q So how long do you think it took for you 13 to go through that extensive series of drug tests and 14 polygraph tests and -- 15 A I did them both in the same day. 16 Q Okay. When was the interview? Was it on 17 the same day or a different day? 18 A I believe it was like a few days 19 beforehand. 20 Q Okay. And do you remember who you 21 Interviewed with? 22 A No. 23 Q Do you remember the title of the job for 24 which you were interviewing? 25 A Locker room attendant.

Page 60

1 name. 2 Q All right. What did she look like? 3 A She had blonde hair, probably to her 4 shoulders, and it was curly. 5 Q And how old was she? 6 A I'd say in her 20s. 7 Q All right. Did they check your 8 identification when you went in for your job 9 interview or your -- 10 A It was very extensive. I'm sure they 11 would have had to check and make sure I was who I 12 was. 13 Q And so you had a driver's license, right? 14 A I believe so. 15 Q All right. And, let's see. Did you move 16 to a different position while you were there or did 17 you always stay as a locker room -- 18 A I wasn't there very long. So I just -- 19 Q 3ust one second. Did you always stay as a 20 locker room attendant? 21 A Yes. 22 Q Okay. I just need to finish my question 23 for the court reporter. 24 A I know, I'm sorry. I have a tendency of 25 jumping in.

1 2 3 4 Q Okay. If I can direct your attention back to Defendant's Exhibit 12 at page 15. And under the heading Response to Interrogatory Number 9, do you see that where it says --

5 A Yes.

6 Q

7 excuse me, responds as follows?

8 A Yes.

9 10 Q Okay. It says you worked as a locker room attendant for the spa area, correct?

11 A Yes.

12 13 Q And it says records produced in this case identify the date of employment as 2000, correct?

14 A Yes

15 16 17 Q What records that were produced in this case cause you to believe that the employment began in 2000?

18 19 A Uhm, is this going back to another question that I'm not allowed to answer?

20 Q No.

21 22 A I have seen the documents, and I know that my employment now was in 2000.

23 24 Q What documents did you see that caused you to make that answer?

25 A The Mar-a-Lago employment documents.

Page 61

Page 63

documents that you met Ghlslalne Maxwell in '98 or '99, correct?

A Yes.

Q And you do admit that you told members of the media that you met Gillslain. Maxwell in '98 or '99, correct?

MR. EDWARDS: Form.

A That was my closest approximation to what I could actually remember, so --

Q (BY MS. MENNINGER) You told the media that you met her in '98 or '99?

MR. EDWARDS: Form.

A Again, yes, as close as I can remember.

Q (BY MS. MENNINGER) And the media

published in the newspapers that you met Ghlslalne Maxwell in V8 or '99, correct?

MR. EDWARDS: Form.

A Yes, they did.

Q (BY MS. MENNINGER) And the news media published in the newspapers what you told them, which Is that you were 15 when you met Ghislaine Maxwell, correct?

MR. EDWARDS: Form.

A Which is what I truly thought at the time, yes.

Page 62

1 Q Are they your Mar-a-Lago employment 2 documents?

3 A Um --

4 MR. EDWARDS: Object to the form.

5 A My name is on there. 6 Q (BY MS. MENNINGER) Okay. Do you believe 7 them to be your Mar-a-Lago employment documents?

8 A As far as l can tell.

9 Q Okay. So you were able to review your 10 Mar-a-Lago employment documents --

11 MR. EDWARDS: Object to the form.

12 Q (BY MS. MENNINGER) -- and respond to the 13 question, as it says right there that you respond, 14 correct?

15 A Yes.

16 Q When did you review the documents that you 17 reviewed to cause you to respond to that answer that 18 way?

19 A I don't think I found out till sometime 20 mid -- mid last year, I believe.

21 Q Okay.

22 A I'm really not too sure. You know, I'm 23 sorry, dates and documents, there's too many to 24 remember. But --

Page 64

1 Q (BY MS. MENNINGER) Okay. And it is not 2 true that you were 15 when you met Ghlslalne Maxwell, 3 correct?

4 A It was a mistake that I made, yes.

5 Q So that the printing in the newspaper that 6 you met Ghislaine Maxwell when she was -- when you 7 were 15 is not a true statement of fact, correct?

8 A It is an incorrect statement as I have now 9 found out, that my employment started in 2000.

10 Q All right. And to the best of your II recollection, you found that out in the middle of 12 2015, correct?

13 MS. McCAWLEY: Objection.

14 A To the best of my recollection. I mean, I 15 can't pinpoint an exact date I found out. But, yes.

16 Q (BY MS. MENNINGER) About a year ago? 17 MR. PAGLIUCA: Are we all participating in 18 this deposition or just --

19 MS. McCAWLEY: Same way you guys did. 20 MR. PAGLIUCA: We did not.

21 MS. MENNINGER: I did not.

22 MS. McCAWLEY: You both objected.

1 record. 2 MR. PAGLIUCA: We sure can. 3 So if we're all participating, maybe I'll 4 have a few questions at the end of this. I think we 5 should limit this to one lawyer. And your statement 6 about two lawyers participating in the last 7 deposition is wrong. 8 MS. McCAWLEY: Well, I recall that she got 9 a microphone because she said she was going to be 10 objecting. So -- 11 MR. PAGLIUCA: I know. She put on a 12 microphone and didn't speak through the whole thing. 13 MS. McCAWLEY: Well, we can take a look 14 back at the record. You know, it's not a problem. 15 Brad can make the objections. 16 MR. PAGLIUCA: Okay. Let's take care of 17 it that way, then. 18 MR. EDWARDS: Can you tell me when you're 19 at a good stopping point? 20 MS. MENNINGER: I was about to say it's 21 been an hour. 22 MR. MENNINGER: So this would be a good 24 time to take a break. 25 MR. EDWARDS: Okay. Thanks.

1 Mar-a-Lago? 2 A Correct. 3 Q Okay. I'm going to show you an exhibit 4 marked as Defendant's Exhibit 13. 5 (Exhibit 13 marked.) 6 Q (BY MS. MENNINGER) Okay. All right, 7 S do you recognize this document? 8 A Yes, I do. 9 Q What is this document? 10 A This is a resume that I created myself. 11 Q All right. And what address did you put 12 at the top of your resume? 13 A 14 15 Q And when did you live at that address? 16 A I believe from 2013 to 2014. 17 Q Okay. And you said you created this 18 document, correct? 19 A Yes. 20 Q And did you send it out to any employers? 21 A Do you have any attachments that this goes 22 with to say that I have? Because I'm not too sure. 23 I've created a lot of resumes. 24 Q Okay. And hold on, I'll see if we do. 25 MS. MENNINGER: All right. I'll mark this

1 THE VIDEOGRAPHER: We're off the record at 2 10:12. 3 (Recess taken from 10:12 a.m. to 4 10:27 a.m.) 5 THE VIDEOGRAPHER: We're back on the 6 record at 10:27. 7 Q (BY MS. MENNINGER) All right. 8 S you testified that you first became 9 aware that you -- your employment at Mar-a-Lago began 10 in 2000, in mid-2015, correct? 11 MR. EDWARDS: Object to the form. 12 Mischaracterizes her testimony. 13 A I don't know exactly when. It could be 14 towards the end of 2015. It could be towards the 15 beginning of 2016. I Just know that I've teamed 16 about it recently. I'm not too sure exactly what 17 date I did learn about it. 18 Q (BY MS. MENNINGER) Okay. But to your 19 mind, it's been within the last 6 to 12 months; Is 20 that fair? 21 A I wouldn't say 12 months, no. I would 22 just say up until -- I don't know when I was shown 23 that, when I actually first saw it, but it wasn't a 24 year ago. 25 Q Saw your employment records from

1 next as Defendant's Exhibit 14. 2 (Exhibit 14 marked.) 3 A Thank you. 4 Q (BY MS. MENNINGER) All right. Do you 5 recognize this document? 6 A Yes. 7 Q What is this document? A This is me replying to ads for jobs. 9 Q Okay. And you were communicating with -- 10 by your e-mail, correct? 11 A Yes. 12 Q All right. And I apologize. This one 13 actually has the resume attached to an e-mail. 14 A Urn-hum. 15 Q Do you see that, towards the back of the 16 document? 17 A Yes, I do. 18 Q Okay. So -- 19 A Sorry. 20 Q To whom -- to whom -- with whom were you 21 communicating about a job at this time? 22 A Well, on the very top, Phil or Gary, and 23 that was for a bartending position. 24 Q Okay. 25 A Um --

1 Q Was that something your brother had 2 recommended or your father? I don't know who. 3 A You know, I Just looked at that, that's 4 kind of why I giggled. I don't know why my 5 brother -- that's my brother. That's the way we talk 6 to each other: Hi, stupid head. Good luck, smelly, 7 XOXOXO, sissie. 8 He's my little brother so you have to 9 understand we kind of play around. But subject to my 10 resume for hospitality, I'm not too sure why he would 11 have gotten it, but apparently he did. 12 Q Okay. And you see that your resume was 13 attached to an e-mall communication you had with your 14 brother? 15 A Yes, I do. 16 Q Right. And that's also your brother was 17 part of the e-mall chain with respect to an ad placed 18 on cralgsllst for a position, correct? 19 A He was on -- let me Just check the dates, 20 then. 21 Q Sure. 22 A 1/20/2014, 1/21, so Just within a day of 23 each other, yes. 24 Q All right. And then the resume that's 25 attached is the address you were living at in

1 you believe the one attached to Defendant's 2 Exhibit 14 is the one that you sent? 3 A There are differences, isn't there? Yes, 4 there is. 5 Q Okay. What are the differences that you 6 know? 7 A It starts -- I mean, let me see. The very 8 top introduction is the same. 9 Q Um-hum. 10 A After the experience. 11 Q Urn-hum. 12 A That changes. The dates change. And then 13 underneath Employment Training Recruitment is Indigo 14 Bar & Grill on Exhibit 14. On Exhibit 13 it's 15 Mannway logistics underneath Employment Training 16 Recruitment. 17 And then underneath Mannway Logistics on 18 Exhibit 13 is Mar-a-Lago Resort and Spa. And on 19 Exhibit 14 Is Gemma Catering/Wedding Receptions. So 20 there is quite a few differences. 21 Q Okay. Great. Do you have any idea when 22 you sent out Defendant's Exhibit 13, or if you did, 23 to an employer? 20 A Unless you have something that's attached 25 to it, I can't be sure that I did.

1 January -- 2 A Yes. 3 Q -- of 2014, correct? 4 A Correct. 5 Q All right. So you believe you created the 6 resume that's attached to Defendant's Exhibit 14, 7 correct? 8 A Correct. 9 Q And you sent it out with respect to this 10 employment you saw on craigslist, correct? 11 A Correct. 12 Q And you are the one who put into this 13 document the contents of the resume, right? 14 A Yes. 15 Q All right. 16 MR. EDWARDS: We're talking about the 17 resume that's attached to Exhibit 14, right? 18 MS. MENNINGER: We are. 19 MR. EDWARDS: Okay. Got it. 20 MS. MENNINGER: Thank you for clarifying. 21 MR. EDWARDS: Got it. 22 MS. MENNINGER: Although, I don't know 23 there are any differences with Defendant's 24 Exhibit 13. 25 Q (BY MS. MENNINGER) But just to be safe,

1 Q Okay. Is the content in Defendant's 2 Exhibit 14, that you believe you sent out to an 3 employer, correct? 4 A Unfortunately, I have to tell you that S they are not correct. Through my experience I was in 6 the mind-set that I was unemployable. I had been 7 abused for many years and I was told by a job agency 8 that I need to show that I've consistently worked at 9 various places and given experience. So it's not 10 something that I'm proud of, but I have had to plump 11 up my resumes to make it look as though I could be 12 employed. 13 Q What do you mean by plump up your resume? 14 A Well, I couldn't -- I didn't feel that I 15 could go to an employer and tell them that I had 16 held, you know, one job in the last 10 to 12 years 17 and before that I was trafficked for the purpose of 18 sex. And that's definitely something you don't want 19 to put down on your resume, which makes you quite 20 highly unemployable. 21 So I did add places in, such as Indigo Bar 22 & Grill, Calmao Flamenco Bar & Restaurant. 23 Q Wait, wait. Which one? 24 A On Exhibit 14. 25 Q Um-hum.

5 6 7 1 A Underneath Experience, the dates are all 2 Incorrect, as well. It's Just to show that I was 3 consistently working, which I was not. And I needed 4 a job to help my family. I've got a family of five. So like I said, it's not something proud that I had to do, but I felt it was the only way that I could actually get employed.

8 9 10 11 Q You Iled on your resume? A I made it look as though I had continuously worked throughout the years so that way an employer would see me as a potential candidate.

12 13 Q Okay. Well, let's start with Employment Training and Recruitment, ET Australia.

14 15 Did you work at that place of employment? A 1 did work there.

16 17 18 19 Q What dates did you actually work there? A I know I finished working for -- we call It ET Australia, so if you don't mind me abbreviating it.

20 21 22 23 24 25 Q However you want. A I know I finished there in January of 2006 right before my son was born, my first son was born. And I believe I worked there for a year, I believe so. It might have been a little bit over a year, but just around a year.

1 A I never worked there. 2 Q The description that you typed out about 3 the things that you did at that Indigo Bar & Grill is 4 made up, correct? 5 A Well, it's -- it's generally what you 6 would do if you were a server or a waitress. But, 7 like I said, I did not work at Indigo Bar & Grill. 8 Q So when you represented to an employer 9 that you were applying for a job that you had done 10 these things, you had not actually done these things 11 at Indigo Bar & Grill, correct?

12 A Not at Indigo Bar & Grill, no. 13 Q All right. Can you read the first 14 sentence of your job description? 15 A For Indigo Bar & Grill? 16 Q Right. 17 A At this restaurant located inside of an 18 RSL, we were never slow. 19 Q Okay. So when you said, "We were never 20 slow," you just made that up, correct? 21 MR. EDWARDS: Form. 22 A I tried to give as much information to my 23 potential employer to show that I could handle a 24 large amount of pressure and guests. So, yes, I put 25 that in there.

1 2 3 Q All right. So you worked at a place for about a year. And on your resume you typed that you worked there for nine years, correct?

4 5 6 7 8 9 10 11 12 13 14 15 16 A Correct. Q And you did that, correct? A I did. Q Nobody else typed that for you? A No, I did it myself. Q All right. And the next employment you list here -- well, is your job description accurate? A Yes, that is actually accurate. Q Okay. And everything in there is what you actually did? A Yes, for ET Australia. Q Okay. Indigo Bar & Grill, did you type that in?

17 18 19 20 21 22 23 A I did type that in. Q And did you actually work at Indigo Bar & Grill? A No, I did not. Q All right. So the dates that you put on your resume are not true, correct? A That's correct. 24 Q The title of your job at that place was 25 not correct; you didn't work there, right?

Page 76 1 Q (BY MS. MENNINGER) But you represented 2 you were there working as a server or waitress and 3 that we were never slow. That is not true, correct? 4 A Well, I never worked there, so it's -- 5 again, I was very highly unemployable, given my past. 6 So I did whatever I could to make it look as though 7 my potential employer could hire me. 8 Q Okay. You described your duties that were 9 not -- those were fictional duties, correct? 10 A They were duties that a waitress and a 11 server would do. 12 Q But you did not do at Indigo Bar -- 13 A But I did not do them at Indigo Bar & 14 Grill. 15 Okay. You described your energetic 16 service and your service with a smile to the guests. 17 That was not true, correct? 18 A Everything in Indigo Bar & Grill is not 19 correct. 20 Q And you created that entire description, 21 correct? 22 A For the sole purpose of being able to 23 obtain employment, yes. 24 Q To get money? 25 MR. EDWARDS: Form.

1 A To make a wage for my family. 2 Q (BY MS. MENNINGER) All right. The next 3 job, Gemma Catering and Wedding Receptions, did it -- 4 is that a job that you actually held? 5 A I did actually work there. I don't know 6 the dates, but I was a server, waitress and 7 bartender. 8 Q March of 2003 to April 2004, is that about 9 when you worked there? 10 A It could be very close to It. I'm not too 11 sure. 12 Q You're not sure? 13 A No, I'm not sure. 14 Q Did you have children -- had you already 15 had children at the time you worked there? 16 A No, I do not believe I did. I became a 17 stay-at-home mom when I had my first child. 18 Q And what year was that? 19 A 2006. 20 Q Okay. So you believe you worked at Gemma 21 Catering and Wedding Receptions before 2006? 22 A I believe so. 23 Q And other than that, you can't recall what 24 dates you worked there? 25 A I'm sorry, I couldn't help, no.

Page 79

Q And after you moved to A Ila, which 2 was what year? 3 A I moved to Australia at the end of 2002, I 4 believe. 5 Q All right. Do you recall going to work 6 shortly after you got to Australia? 7 A YeS. 8 Q How -- 9 A I had to obtain my -- my ability to work 10 there. So I think that took a couple months. You 11 can get a temporary visa that allows you to work 12 while you're waiting for your permanent resident 13 status, and that's what we did. 14 Q All right. Were you able to apply for 15 that temporary job permission before you actually got 16 married in Australia? 17 A I got married in Aus -- we were married in 18 Thailand, really, but we made it official in January 19 of 2003. And within a couple of weeks, I was granted 20 the permission to work in Australia legally. 21 Q Okay. So to the best of your 22 recollection, you got permission to work in Australia 23 sometime in the spring of 2003? 24 MR. EDWARDS: Form. 25 A That's actually summer over there.

Page 78

1 Q All right. And then what were your 2 actual -- is that your actual job that you had there? 3 A The description of it? 4 Q The title, server, waitress, bartender? 5 A Yes. 6 Q All right. Is the description accurate? 7 A To a T. 8 Q What's that? 9 A To a T. 10 Q Okay. The next job you list is Mannway 11 Logistics, Logistics Receptionist. 12 Is that a job you actually held? 13 A It is a job I held. 14 Q And when did you hold It? 15 A Again, I'm very bad at dates. I'm not too 16 sure. 17 Q All right. Approximately when did you 18 have it? 19 A I don't want to speculate and give you the 20 wrong answer, so I'm not too sure. 21 Q Did you have children at the time you 22 worked there? 23 A No. 24 Q So before 2006? 25 A Yes.

2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 80 Q (BY MS. MENNINGER) Fair enough. The first quarter of the year, calendar year -- A Yes. Q -- 2003? A If we're going to be politically correct, yes. Q That's what you recall? A (Indicating.) I'm sorry, yes. Q And is your description of Mannway Logistics correct? A Yes. Q All right. And how long did you work there? A I think that was less than a year that I worked there. I would approximate about six, seven months. Q Can you name one coworker you had or boss or anybody else that worked there? A I know her name started with an M, but I can't remember. I remember what she looks like. I just don't remember her name. Q Okay. And how much did you make there? A I don't remember the exact amount. Approximately about 520 an hour, I think.

1 Q And how many hours per week were you 2 working for that six months to a year? 3 A I believe that was full time. 4 Q And is full time the same in Australia? 5 A Yeah it's a 40-hour week. 6 Q Okay. 7 A Well, 38 because you get two hours of 8 lunch, so, yes. 9 Q All right. Have you been In touch with 10 anyone from that employment in a while? 11 A No. 12 Q All right. The next job listed there is 13 what? 14 A Calmao Flamenco Bar & Restaurant. 15 Q Is that someplace you actually worked? 16 A No, It's not. 17 Q Is that a place that actually exists? 18 A I don't really know. 19 Q All right. 20 A I mean, I think I looked on the Internet 21 and found something similar to what the description I 22 was needing to fill, and that was it. 23 Q Okay. So when you were creating this 24 document In 2013/2014, right, that's when you had the 25 Titusville address?

1 A Before I worked at ET Australia, I was 2 actually a Job seeker there. And a Job seeker, I 3 don't know if you're familiar with the term. 4 Somebody who is looking for work and you 5 go to a Job agency, and you go look on the computer. 6 And you actually have somebody who helps you find 7 employment. And they are the ones who recommend that 8 you show that you've continuously worked throughout 9 your years. They ended up really liking me, so 10 that's how I got the Job there. 11 Q Okay. Was It a particular person there 12 that gave you the advice to plump up your resume? 13 A It would have been one of the counselors. 14 Q Which one? 15 A I don't know. 16 Q Okay. Do you remember the names of any of 17 the counselors? 18 A I only remember the name of one of the 19 girls I worked with, but I don't remember -- I don't 20 remember anyone else's name. 21 Q When did you first become a job seeker at 22 ET Australia? 23 A Well, If I finished there In 2006 and I 24 worked there for approximately a year, It would have 25 been 2005 -- late 2004, 2005. I'm not too sure.

1 A Yes. 2 Q All right. You went on the Internet and 3 you searched for a place that would be like the job 4 you were looking for? 5 A Correct. 6 Q And you found the name of an actual place, 7 Calmao Flamenco Bar & Restaurant. Did I get that right? 9 A I'm not 100 percent on that, but I think 10 So. 11 Q Okay. And you did that in order to 12 impress the employer you were applying for here in 13 the e-mail, correct? 14 A Correct. 15 Q All right. And you did that in order to 16 get money from a job that you hoped to get from this 17 employer in the e-mail, correct? 18 A I was hoping to gain employment. And not 19 having much experience, I put in there that I had 20 experience. 21 Q Okay. And you said that you had been 22 advised to plump up your resume by a job agency; is 23 that right? 24 A Yes. 25 Q What was the name of that job agency?

1 Q Okay. So you were a job seeker there 2 first and then got employment there, right? 3 A Yes. 4 Q Okay. So the advice to plump up your 5 resume was while you were seeking a job or while you 6 were employed there? A While I was seeking a job. Q All right. And you were assigned a 9 counselor? 10 A Yes. 11 Q One or more than one? 12 A It changes on a daily basis. There's 13 somebody who comes into the office and they sit with 14 you and they help you with your resume. And then 15 they help you go on the computer and look for open 16 vacancies. 17 Q So someone in approximately 2005 gave you 18 the advice to plump up your resume. That's what 19 you're saying? 20 A To make it look like I've continuously 21 worked, yes. 22 Q Okay. So back to Calmao Flamenco Bar & 23 Restaurant, which is a place you found on the 24 Internet but did not actually work. Is that, the 25 dates for your employment there, December 2001 to

3 during 2001 I was with Jeffrey and Ghislaine being

4 trafficked.

5 Q Urn-hum. So you were not working at Calmao

6 Flamenco Bar --

7 A Obviously not, yes.

8 Q And you said you got to Australia in

9 late '02 and did not work there between late '02 and

10 February of ' 03, correct?

11 A I've never worked at Calmao Flamenco Bar &

12 Grill, period.

13 Q All right. And the job description that

14 you crafted there is also fictional, correct?

15 A Yes.

16 Q All right. And Mar-a-Lago Resort and Spa

17 you put down as a place you had worked, correct?

18 A Correct.

19 Q And you typed in August 2000 to September

20 2001, correct?

21 A Correct.

22 Q And you created your job description

23 there, correct?

24 A Correct.

25 Q All right. And then turning to the last

3 A Correct, I mean given that my past had not

4 enabled me to be able to look for work or I wasn't

5 able to put down what I actually had -- had to do in

6 my past. So I made it look as though I was able to

7 be employed.

8 Q You did not have the past that you thought

9 the employer was looking for, right?

10 A I couldn't put down on there that I was

11 sex trafficked for a couple years and did not have

12 the experience to be able to apply for Jobs and

13 provide for my family.

14 So this is something that I said. Again,

15 I am not proud of, but I felt was necessary to do to

16 be able to gain employment.

17 Q All right. So you were applying for a Job

18 at a restaurant, right?

19 A At this -- according to the front e-mail,

20 yes.

21 Q All right. And you did not put down Taco

22 Bell on this resume, correct?

23 A No. The only Jobs on here are the ones

24 that we have mentioned.

25 Q Right. And so why did you choose August

Page 86

1 page you have your education, correct?

2 A Can I just make a statement to say that,

3 again, with the Mar-a-Lago Resort and Spa, I did have

4 to add dates to make it look as though I had

5 continuously worked. So those, again, are incorrect

6 dates.

7 Q But it is a date that you typed into a

8 resume in 2013 or 2014 --

9 A That is the date that --

10 Q If you could just let me finish my

11 question.

12 A Sure.

13 Q That is a date that you typed into your

14 resume in 2013 or 2014, correct?

15 A That is the date that I did type in, but

16 those are incorrect dates.

17 Q All right.

18 A And, as well as the -- the position,

19 organizing, making and canceling appointments for

20 massage therapists.

21 Q All right.

Page 88

1 of 2000 as your start date for Mar-a-Lago?

2 A It just looks as though I've given them a

3 longstanding history of employment.

4 Q You chose a month. Why did you choose

5 that month?

6 A I chose months and dates for every single

7 position on that resume. There is no specific reason

8 why I chose that month. It was just purely to show

9 that I was continuously employed.

10 Q On the last page it has some education.

11 Which part of that is untrue?

12 MR. EDWARDS: Object to the form.

13 A I have received my business admin cert 3

14 from ET Australia. I've never held responsible

15 service of alcohol and gambling.

16 Q (BY MS. MENNINGER) Do you understand that

17 to be a licensing of some sort or a class? Or what

18 do you understand that --

19 A In Australia you have to have something

20 called an RSA and RCG to be able to work as a

21 waitress or bartender or anything. And I didn't know

And I did go to- Palm Beach High 2 School and I didn't put down a degree there or 3 anything. 4 Q So Is it fair to say you never worked as a 5 waitress in Australia. Is that what you just said? 6 A I did work as a waitress at Gemma 7 Catering. 8 Q S okay. 9 A I don't believe I needed my RSA to work 10 there. I'm not too sure. 11 Q All right. And if I could just ask you 12 one other question about Gemma Catering. In the last 13 line of the job description it says: This job was a 14 second Job. I would work in the evenings and 15 weekends for saving extra cash. 16 What was it a second job to? 17 A If my time period Is right, It would be my 18 second Job to Mannway Logistics because they were 19 both -- Gemma Catering and Mannway Logistics were 20 both in Sydney, whereas ET Australia was on the 21 central coast. 22 Q All right. ET Australia is on the central 23 coast? 24 A Correct. 25 Q And Gemma and Mannway are in Sydney?

Page 91

1 A I remember spending a birthday with them 2 on Jeffrey Epstein's island called Little Saint 3 Jeff's. I wouldn't say it was a party. It was Just 4 Ghislaine, me, Jeffrey. I believe was 5 there. I got some presents from them. 6 Q What presents did you get? 7 A Ghislaine gave me a whole bunch of makeup, 8 like boxes of different kinds of eye shadows and 9 lipsticks and just makeup altogether. 10 Jeffrey gave me a bracelet and, I think 11 earrings. 12 Q What kind of earrings? 13 A They were what I believed to be diamonds. 14 I don't know what they exactly were. I think Jeffrey 15 was talking about, they could have been passed off as 16 good knock-offs. But they appeared to be diamonds. 17 Q Any other presents? 18 A I remember the makeup and the jewelry. I 19 don't remember much else. 20 Q And that was your 17th birthday, you said? 21 MR. EDWARDS: Form. 22 A It's hard for me to really pinpoint 23 exactly which birthday it was. 24 Q (BY MS. MENNINGER) So It could have been 25 your 18th or your 19th?

Page 90

1 A In Sydney, yeah. 1 2 Q All right. Got it. 2 3 Do you know if those two organizations 3 4 still exist? 4 5 A Mannway, I would definitely say, it's a -- 5 6 it's a large logistic company. I would say it still 6 7 does exist. 7 8 Gemma Catering, I'm not too sure if that 8 9 exists anymore or not. 9 10 Q Okay. All right. So did you spend your 10 11 16th birthday with Ghislaine Maxwell and Jeffrey 11 12 Epstein? 12 13 A No. I was 16 when I met them, now that I 13 14 know the correct dates. So I would have spent my 14 15 17th birthday with them. 15 16 Q So when you represented that you spent 16 17 your 16th birthday with Ghislaine Maxwell and Jeffrey 17 18 Epstein, that was not true, correct? 18 19 A At my ability at the time, that's what I 19 20 believed to be true. It wasn't until I found the 20 21 Mar-a-Lago records stating the year 2000. Me being 21 22 born in 1983 would make me turning 17 that year. 22 23 Q So please describe for me your 17th 23 24 birthday that you claim you spent with Ghislaine 24 25 Maxwell and Jeffrey Epstein. 25

Page 92

A I don't want to lock down on which exact birthday it could have been without knowing. Q You don't know which birthday it was; is that what you're saying? A The one that I'm specifically telling you about? Q Right. You don't know which one? A No. Q All right. Do you remember spending more than one birthday with Jeffrey Epstein and Ghislaine Maxwell? A Yes. Q Okay. Tell me about the other ones that you remember. A Well, I know my 19th birthday. I can't remember, really, my 18th birthday. But my 19th birthday we celebrated it early, earlier than my actual date of birth. And that's when he surprised me with tickets to Thailand. Q What do you mean he surprised you with tickets to Thailand? A He told me that the tickets for Thailand were for my birthday. Q Did he hand you something that looked like a ticket to Thailand? What do you mean?

1 A He didn't hand me the tickets at that
2 time, but he told me that he had booked me in for
3 massage training at an institute in Chiang Mai.

4 Q And he told you he had booked you tickets
5 to a massage training in Chiang Mai, Thailand
6 sometime before your actual 19th birthday?

7 MR. EDWARDS: Form.

8 Q (BY MS. MENNINGER) Did I get that right?

9 A Yes.

10 Q Okay. Did he hand you --

11 A Excuse me.

12 Q -- hand you anything at that time?

13 A No, I don't think so.

14 Q And where were you located when he told
15 you this about the Thailand massage training?

16 A Jeffrey, Ghislaine and I had just gone
17 scuba -- not scuba diving, not with the big tanks,
18 but snorkeling with just the mask and the two-piece,
19 and on Jeffrey's island, by the way.

20 And we had gone out for a while. And we
21 had come back. And he's got a pier where it's got a
22 ladder and you climb up. And we were wearing wet
23 suits. So we were taking off our flippers and our
24 wet suits and all of our gear.

25 And they said they wanted to sit down and

1 shortly before my birthday, but not my birthday.

2 Q (BY MS. MENNINGER) Okay. And he told you
3 he had booked you tickets to go to Thailand, right?

4 A Correct.

5 Q All right. So you remember one birthday
6 at which you received makeup, bracelet and earrings
7 and one birthday at which you received tickets to
8 Thailand.

9 Do you remember any other birthdays that
10 you spent with Jeffrey Epstein and/or Ghislaine
11 Maxwell?

12 A I'm sure there is, but I honestly can't
13 remember what I did for my 18th birthday.

14 Q Okay. Well, I'm sorry, did you know for
15 sure that the bracelet, earrings and makeup were from
16 your 17th birthday, or do you know?

17 A I don't know.

18 Q But you know they were not for your
19 16th birthday, right?

20 A Correct.

21 Q All right. If I could have you go back to
22 Defendant's Exhibit 1, I think.

23 A Defendant's, sorry, Exhibit 1?

24 Q Um-hum. Page 9, either at the bottom or
25 in the upper right-hand corner.

1 talk to me, just the three of us. And he -- first,
2 he told me about the --

3 Q If I could just stop you. I think I asked
4 where were you --

5 A [REDACTED] I'm sorry.

6 Q -- when you had this conversation about
7 the --

8 A Just the island. I'm just trying to
9 describe the instance that he gave it to me.

10 Q [REDACTED] okay.

11 A It was on the island, on the pier in the
12 Caribbean.

13 Q Okay. And it was sometime before your
14 19th birthday?

15 A Correct.

16 Q How much time before?

17 A I don't know. A couple -- six weeks, a
18 couple of months. I don't know. Close to my
19 birthday. It was my birthday present, that's what he
20 told me.

21 Q Okay. So you don't know when you had this
22 conversation?

23 MR. EDWARDS: Form.

24 A I mean, I -- no, I didn't record the time
25 and the date, so I can only speculate. It was

1 Do you see that page?

2 A Page 9 of 27, yes.

3 Q All right. And paragraph 23, do you see
4 that paragraph?

5 A I see the paragraph.

6 Q All right.

7 A I was just going to read it over quickly.

8 Q By all means.

9 A I've read it.

10 Q And the sentence, Defendant and
11 Ms. Maxwell acknowledged and celebrated plaintiff's
12 16th birthday, is not a true statement, correct?

13 A Only upon learning about the fact that I
14 just found out my records. I assumed at the time it
15 was my 16th birthday. But now we know different.

16 Q You admit, as you sit here today, that
17 defendant and Ms. Maxwell did not celebrate your 16th
18 birthday with you, correct?

19 A Correct, based upon the records.

20 Q Which you don't know when you saw?

21 A I know it was, you know, it wasn't -- it
22 wasn't a year ago, but it wasn't that long ago
23 either. So I'm not too sure. I can't tell you the
24 date that I actually saw them.

3 Q And then you moved to Australia, correct?

4 A Yes.

5 Q You did not live in Florida at any point 6 in time during 2015, correct?

7 A I believe I left Titusville at the end of 8 2014.

9 Q Okay. So you did not live in Florida 10 during 2015, correct?

11 A I believe so. 12 Q All right. So when you reviewed these 13 records sometime in 2015 that caused you to know the 14 real date of when you worked at Mar-a-Lago, where 15 were you physically located?

16 MR. EDWARDS: Object to the form and 17 mischaracterized her testimony.

18 A I don't remember where I saw these 19 records, when I saw these records. I know it wasn't 20 a year ago. I know It was more recent. I can't 21 pinpoint the date that I actually saw them, but I 22 recently, I believe -- I don't know. I don't want to 23 sit here and speculate and then give you the wrong 24 answer. It's just new knowledge for me.

25 Q (BY MS. MENNINGER) All right. Did you

3 MS. MENNINGER: No, you're not testifying.

4 I've asked her --

5 MR. EDWARDS: I'm clearing the record up 6 right now, though.

7 MS. MENNINGER: You can object based on 8 form. That's a valid objection. You've made your 9 record.

10 Q (BY MS. MENNINGER) Did you review records 11 that clarified dates for you?

12 A I've either reviewed them or I've been 13 told about -- I can't remember. I'm sorry. I 14 know -- I know now that the dates are what they are, 15 but I don't remember.

16 Q You don't know when you learned that the 17 dates are what they are?

18 A No, I don't.

19 Q And your best guess is what?

20 MR. EDWARDS: Objection. 21 If any of your answer is based on 22 attorney-client privilege, I'm instructing you not to 23 answer.

20 A I can't answer, then.

25 Q (BY MS. MENNINGER) Okay. So have your

1 receive the records by e-mail?

2 A I believe so.

3 Q Okay. Did you use any e-mail address

4 other than

5 A No.

6 Q That's the only e-mail address that you've 7 used?

8 A That's correct.

9 Q And the Mar-a-Lago records that you 10 reviewed you received by e-mail at that e-mail 11 address?

12 A Possibly. I mean, I can't say 13 100 percent. I could have been told about them. I 14 could have seen them on a piece of paper. I really 15 don't know. This is a very hazy subject. All I know 16 is that I found out and that was able to clarify a 17 lot of dates for us.

18 Q Okay. What other dates were clarified?

19 MR. EDWARDS: I object and instruct the 20 witness not to answer if any of your knowledge is 21 based on any privileged communication that you had 22 between yourself and any of your lawyers.

1 attorneys told you to change your dates?

2 MR. EDWARDS: Objection.

3 Do not answer that question. This is a 4 question intentionally devised to invade the 5 attorney-client privilege.

6 silts not going to answer those questions.

7 Q (BY MS. MENNINGER) You can answer a 8 question about whether your attorneys had told you to 9 lie. Because that would be a crime, and I'm sure --

10 A I will --

11 Q I'm sure you want to tell me that your 12 attorneys did not tell you to lie, correct?

13 A I can tell you for a fact my attorneys 14 have never told me to lie.

15 Q All right. And did your attorneys tell 16 you to change a date?

17 MR. EDWARDS: Objection. She's not 18 answering any questions about communications between 19 her lawyers and herself, period.

20 Q (BY MS. MENNINGER) So if I could also 21 direct your attention to Defendant's Exhibit 8. It's 22 the manuscript. If you could turn to page 40.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 mic higher up on your jacket, please? THE DEPONENT: Sure. THE VIDEOGRAPHER: Thank you. THE DEPONENT: Tell me if that's okay. Better? A Okay. Page 40? Q (BY MS. MENNINGER) Right. Do you see the first full paragraph on that page? A I do. Q The first line begins: I spent my sweet 16th birthday on his island in the Caribbean next to Little (sic) St. James Isle. He liked to call it Little St. Jeff's. His ego was enormous as his appetite for fornicating. Do you see that sentence? A I do. Q That is not true, correct? You were not spending your sweet 16th birthday on Little St. James Isle, correct? A Based on my knowledge at the time that I wrote this manuscript, I thought I did spend my 16th birthday there. And so I put it down in there as that. Now I know that it wasn't my 16th birthday. Q A Well, we -- Or your sweet 16th birthday?

1 If you remember the answer, please tell 2 her the answer. 3 A I don't know the answer, where I spent my 4 sweet 16th birthday. 5 Q (BY MS. MENNINGER) Do you know who you 6 were with on your sweet 16th birthday? 7 A No, I don't. 8 Q Do you know where you lived on your sweet 9 16th birthday? 10 A No, I don't. 11 Q Were you living with your parents on your 12 sweet 16th birthday? 13 A I don't know. 14 Q Were you living with on your sweet 15 16th birthday? 16 A I don't know. I was a runaway a lot. I 17 don't know where I lived at the time. 18 Q Okay. Were you working at Taco Bell on 19 your sweet 16th birthday? 20 A I don't think so. I don't know. 21 Q Were you working at Publix on your sweet 22 16th birthday? 23 A I don't know. 24 Q Were you working at an aviary on your 25 sweet 16th birthday?

1 MR. EDWARDS: Object to the form. 2 Harassing. 3 Q (BY MS. MENNINGER) Was it your sweet 16th 4 birthday? 5 A Is it not custom to call your 16th 6 birthday sweet? Have you never heard that saying 7 before? 8 Q Was it your sweet 16th birthday, 9 10 A As we -- 11 MR. EDWARDS: She's answered the question. 12 It's been asked and answered. 13 MS. MENNINGER: She asked me a question, 14 actually. You're not testifying here. 15 Q (BY MS. MENNINGER) Was it your sweet 16th 16 birthday? 17 A As I thought, in the manuscript when I 18 wrote it, I thought it was my sweet 16th birthday. 19 Q Okay. Now that you know it wasn't, where 20 did you spend your sweet 16th birthday? 21 A Well, I don't know. 22 Q Well, just give us your best guess. 23 MR. EDWARDS: Objection. And she's not 24 going to guess today. She's going to tell you the 25 answers as she remembers them.

1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Again, I don't know. Q Do you recall any present you actually got on your sweet 16th birthday? A No, I don't. I don't know where I spent it, who I spent it with or what I got. I'm sorry. Q How long did you work at Mar-a-Lago? A Best of my recollection, it was a summer Job. I believe I started in June. And I think I only worked there approximately two weeks, two, three weeks. Q How many hours a week did you work? A I want to say it was a -- I want to say it's a full-time job. Q Do you recall it being a full-time job? A It was a summer Job, but just thinking back, my dad used to bring me in and bring me home. So he worked full time, all day. So -- and I didn't lounge around Mar-a-Lago so, yes, I think it would have been a full-time job. Q And how much did you make per hour? A Approximately, I think I remember making $9 an hour. Q The bracelet and earrings you got for your birthday, some birthday, on Little -- or where was that birthday party, at Little St. James?

1 MR. EDWARDS: Object to the form. 2 Q (BY MS. MENNINGER) Where was it? 3 A At Little Saint Jeffs. 4 Q Okay. Where are those bracelet and 5 earrings now?

6 A I left everything behind me when I went to 7 Thailand.

8 Q Where did you leave them, exactly? 9 A I had a storage facility and my apartment 10 that I lived in.

11 Q So where were they, in the storage 12 facility or in the apartment?

13 A Most likely in the apartment.

14 Q Okay. What apartment was that?

15 A Royal Palm Beach. I don't know the 16 address, I'm sorry.

17 Q You don't know the address at all?

18 A Not at all.

19 Q Okay. Where was it roughly located in 20 Royal Palm Beach?

21 A I don't know. It's been a long time since

22 I've been back to Royal Palm. I don't remember 23 street names or anything.

24 Q Did it have one or two bedrooms?

25 A It was two bedrooms.

1 2 3 4 5 6 Q Well, all right. We'll come back to that in a minute. But the apartment that you left In 2002 was the one in Royal Palm Beach that you lived at originally with and then after breaking up with lived there? That's the one we're talking about?

7 A Correct.

8 Q That's the apartment we're talking about?

9 A That's not the one that --

10 Q Okay.

11 12 A Sorry. I'm confused. Could you please reask the question?

13 Q All right. I asked you where you left

14 your bracelet or earrings. You think you --

15 A Okay, yes.

16 Q -- left them In an apartment, correct?

17 A Okay. Yes. Yeah, not the one -- not the

18 first one. The one where= eventually moved Into.

19 20 Q That's the apartment you left the bracelet and earrings at?

21 A I believe so, yes.

22 23 Q So when you were working at Mar-a-Lago, you rode with your father every day?

24 A Yes.

25 Q What car did he drive at the time?

1 Q Was it on the first or second floor?

2 A The second floor.

3 Q Who lived there with you?

4 A first lived there with me.

5 and I broke up shortly after living there.

6 And- lived there with me.

7 Q Okay. And that's the apartment that you 8 left when you went to Thailand?

9 A Yes.

10 Q Did you live at more than one apartment 11 with

12 A When I was a runaway, he let me stay at 13 his apartment.

14 Q Was that a different apartment?

15 A Yes.

16 Q All right. So you lived at 17 apartment when you were a runaway?

18 A Correct.

19 Q And did you live anywhere else other than 20 those two apartments with

21 A We stayed at parents' house, I 22 think for a few weeks before the apartment.

1 A I don't know.

2 Q Okay. Did you have a vehicle of your own 3 at the time?

4 A No.

5 Q Did you have a driver's license at the 6 time?

7 A Yes. I got my permit when I was 15 and my 8 driver's license when I was 16.

9 Q Okay. And how were you paid, by cash or 10 check or some other method?

11 A I don't remember.

12 Q Did you have a bank account at that time?

13 A I don't think I've ever had a bank

14 account -- well, up until recently, living here. I 15 don't remember having a bank account.

16 Q So you believe you got paid by unknown 17 means and you did not deposit it into a bank?

18 A Correct.

19 Q What was your uniform when you worked 20 there?

21 A At Mar-a-Lago?

22 Q Right.

Page 109 Page 111

A I don't know, maybe. 2 Q Did you wear it to and from work every 3 day? 4 A Yes. 5 Q Did you get new ones when you arrived that 6 were clean or did you launder them at home? 7 A I would have had to wash them when I got 8 home, I suppose. 9 Q And you think you had more than one or you 10 don't recall? 11 A I don't recall. 12 Q All right. Was that something you 13 purchased or did they give it to you? 14 A They gave it to me. 15 Q And who else was wearing that uniform? 16 A The other locker -- the lady that did the 17 front desk next to the locker rooms. 18 Q She had the same one? 19 A Yes. 20 Q Was that Adriana? 21 A I don't think Adriana wore a uniform. I 22 think she just dressed professional. 23 Q Okay. And what other employees did you 24 see there at the spa at the time when you worked 25 there?

1 masseuses had their own uniforms. 2 Q What did the masseuses' uniform look like? 3 A I don't remember. 4 Q No recollection at all? 5 A None whatsoever. 6 Q Color? 7 A No, sorry. I remember mine. 8 Q Okay. How did it come to pass that you 9 were no longer working at Mar-a-Lago in two to three 10 weeks? 11 A I was approached by Ghislaine Maxwell. 12 Q Okay. And how long had you been working 13 at Mar-a-Lago when you were approached by Ghislaine 14 Maxwell? 15 A Roughly two to three weeks. 16 Q Okay. Where in the spa were you when you 17 were approached by Ghislaine Maxwell? 18 A Just outside the locker room, sitting 19 where the other girl that works there usually sits. 20 She was away from the desk. I was reading a book on 21 massage therapy. 22 Q Was that Indoors or outdoors? 23 A Outdoors. 24 Q Okay. And what -- were you in the sun or 25 in the shade?

Page 110

A There were -- well, this is in the massage 2 area and there's also like a fitness area. So 3 there's spa and fitness. So there would be the 4 masseuses and then there would be the trainers. And 5 that was just located in that one area away from the 6 main house and stuff. 7 Q And is that the area in which you worked? 8 A Yes. 9 Q In the spa area or the fitness area? 10 A The spa and the fitness area were in the 11 same complex. 12 Q Okay. What did the other people who 13 worked in the spa area wear? 14 A I don't remember what they wore. 15 Q All right. And what did the people in the 16 fitness area wear? 17 A I don't remember. I know it was -- we had 18 our own uniforms. Everyone else had their own. 19 Q Who is we? 20 A Well, the girls that worked in the meet 21 and greet area. Me and the other girl with the curly 22 hair I told you about -- 23 Q Um-hum. 24 A -- had our own uniforms. And then the 25 fitness people had their own uniforms. And the

Page 112

1 A In the shade underneath a -- I don't know 2 what you'd like to call it, but, you know, underneath 3 the complex, the building. 4 Q All right. And what was Ghislaine Maxwell 5 wearing when she approached you? 6 A I don't remember what she was wearing. 7 Q Any recollection, color of clothing or 8 anything? 9 A No. 10 Q Okay. Any details about her? Was she 11 carrying a purse or anything? 12 A No. She looked like, from my memory, she 13 looked like she was either there for a massage or 14 fitness. I remember she had a British accent. She 15 was very interested in the book that I was reading. 16 I mean, we can get into some more details 17 later if you'd like, but I don't remember any more 18 about what she was wearing that day. 19 Q Did you have a cell phone at that time? 20 A No. 21 Q Where were you living at that time? 22 A At my parents'. 23 Q And who else was living there with you at 24 the time? 25 A My mother and my dad and my brother.

Which brother? 2 A 3 Q What about your other brother? 4 A 1 think he had moved out by then. 5 Q What forms of communication did you have? 6 lust a home phone number, or what? 7 A Yeah, there was a home phone. 8 Q When do you recall ever getting a cell 9 phone? 10 A The first cell phone I ever got was the 11 one that Ghislaine gave to me. 12 Q So you never had -- your parents, did they 13 have ones when you were working at Mar-a-Lago? 14 A No, my dad used to -- like, we had phones 15 in the spa and maintenance area and so on, so forth. 16 And you could, so to speak, page people from around 17 the courts. 18 Q Okay. So tell me what you recall of the 19 first conversation that you had with Ghislaine 20 Maxwell. 21 A I'm sitting there reading my book about 22 massage therapy, as I'm working in the spa. And I'm 23 getting my GE -- well, I was in the process of 24 getting my GED before I went to my summer job. I 25 decided that I would like to become a massage

1 there's one in Royal Palm and Wellington, and I used 2 to go to both. 3 Q Did you have a card for both? 4 A Did I have a card? 5 Q A library card? 6 A Yeah. 7 Q For both places? 8 A To be able to rent out a book, yeah. 9 Q Okay. So the best of your recollection is 10 you used one of your library cards at one of those 11 two libraries to check out a book on massage and 12 anatomy? 13 A Correct. 14 Q And when did you do that relative to 15 starting at Mar-a-Lago? 16 A Probably within the first week. I mean, I 17 saw what the massage therapists got to do. I mean, 18 their Jobs were so relaxing. The music, like the 19 atmosphere, they always had happy clients. It just 20 seems like an ideal Job. 21 Q And so you were spurred to go to the 22 library and check out a book? 23 A Well, I had been talking with the other 24 massage therapists and they're the ones who first 25 intrigued me about what they do. And, you know, I

l therapist one day. And the body really intrigued me, 2 you know, reading this massage was a lot about 3 anatomy, blood flow. Everything to do with, you 4 know, touching somebody somewhere and then triggering 5 a result somewhere else. I just was very intrigued 6 by the whole anatomy thing. 7 She came up, Ghislaine, sorry. Ghislaine 8 came up and approached me at the desk that I was 9 sitting at. And my book was like this (Indicating) 10 and she said, Oh, you're reading a book about 11 massage. You want to do massage? And I told her, 12 Yes, you know, I'm very interested in it. One day I 13 would like to become a masseuse. 14 Q All right. Where did you get the book on 15 massage? 16 A Maybe the library. 17 Q Maybe or do you recall? 18 A I don't think I purchased it. So I'd have 19 to say the library. 20 Q Okay. What library was that? 21 A Whichever library was close to my house. 22 Q Do you remember a library being close to 23 your house? 24 A There's one in Wellington that I used to 25 go to. Oh, no, there's one in Royal Palm. Yeah,

1 wanted to aim for something higher than being a 2 locker room attendant one day. And. Yeah. 3 Q What was the name of the massage therapist 4 that you were speaking with? 5 A Oh, I have no idea. 6 Q Can you give me any physical description 7 of any of them? 8 A Urn, there was one who had blonde short 9 hair. There was -- I would say there's probably 10 about four massage therapists that work in there. n So, I mean, I don't remember all of them. 12 Q Okay. What time of day was it? 13 MR. EDWARDS: Object to the form. 14 A Afternoon. 15 Q (BY MS. MENNINGER) How late? 16 A Anywhere between 2 to 4. 17 Q And what time did you get off of work? 18 A I believe I got off at 5. 19 Q And what was the rest of your conversation 20 with Ms. Maxwell? 21 I'm sorry, I don't think you finished. 22 A Thank you. Well, she noticed I was 23 reading the massage book. And I started to have 24 chitchat with her just about, you know, the body and 25 the anatomy and how I was interested in it. And she

1 told me that she knew somebody who was looking for a 2 traveling masseuse.

3 And I said, Well, I don't have any 4 accreditations. This is the first book I've ever 5 read. She goes, That's okay. I know somebody. We 6 can train you. We can get you educated. You know, 7 we can help you along the way if you pass the 8 Interview.

9 If the guy likes you, then, you know, It 10 will work out for you. You'll travel. You'll make It good money. You'll be educated, and you'll finally 12 get accredited one day.

13 Q Okay. 14 A She finished off by, you know, giving me 15 her number. And I told her I'd have to ask my dad. 16 And I called my dad. I ran over, actually, to see my 17 dad, talked to him. He said it would be okay. I 18 used the phone from Mar-a-Lago to call her and tell 19 her that I was allowed to come over. 20 And she said, Great. Meet me here at -- I 21 don't remember the exact address, but it was 22 El Brillo Way in Palm Beach -- after you get off. 23 And my dad drove me. 24 Q Did you write down her add -- the address 25 that she gave?

Page 119

I A cell phone or a home phone, or do you have any 2 Idea? 3 A I have no idea. Ghlslaine answered. So 4 if it was a home phone, the butlers probably would 5 have answered. So most likely it was her cell phone. 6 Q All right. And what happened when you got 7 off of work? 8 A My dad drove me to El Brillo Way. 9 Q Um-hum. 10 A We arrived at a very large pink mansion. 11 And we knocked on the door. My dad got out of the 12 car and we knocked on the door. 13 Q Do you recall which car this was? 14 A I don't know what he was driving at the 15 time. My dad always drives trucks. So it would have 16 been some kind of truck. 17 Q But you don't know which kind? 18 A I don't know if it was a Ford or a Dodge 19 20 Q What kind of car does your mom drive? 21 A Right now? 22 Q No, in 2000. 23 A Oh, I have no idea. I don't remember. 24 They change cars quite often. They like getting 25 different cars.

Page 118

1 A Yes. 2 Q Did you write down her phone number? 3 A Yes. 4 Q So did you go run and talk to your dad 5 while she was still there? 6 A No, I believe she left. And she told me 7 to ask my dad and then to give her a phone call. 8 Q Okay. Did she ask you your age when she 9 had that conversation with you? lo A No, she did not. 11 Q Did you tell her your age? 12 A No, I did not. 13 Q And so somewhere you wrote down a phone 14 number to call her back at? 15 A Um-hum. 16 Q All right. And where did you write that 17 down? 18 A Probably just a piece of paper lying 19 around the desk. 20 Q Okay. But you don't remember? 21 A I mean, no, I don't have that piece of 22 paper anymore, so no. 23 Q Okay. And did you write down an address? 24 A Yes. 25 Q And what number do you think you called?

1 2 A 3 Andrew. When did you get your first car? After my trip to London to meet Prince 4 Q Okay. What kind of car did you get? 5 A A Dodge Dakota. 6 Q And did you purchase that yourself? 7 A Yes, I did. 8 Q And how much did it cost? 9 A I don't remember off the top of my head 10 how much it cost. 11 Q Who did you buy it from? 12 A My dad helped me bargain with it. I don't 13 remember where we bought it from. 14 Q And was the title put in your name or your 15 dad's name? 16 A I think the title was put in my name. I 17 think. I mean, my dad was with me. I've never 18 registered a car or anything like that before. So -- 19 Q So that was your first time? 20 A Yes. 21 Q Memorable, right? 22 A Yes. 23 Q When you got there, a butler or someone 24 answered the door, is that what you said? 25 A No, Ghislaine answered the door.

Page 120

1 2 3 4 5 6 7 8 9 10 Q Okay. And then what happened? 1 A She shook hands with my dad. Uke, she 2 briefly opened the door. She stepped out, shook hands with my dad. Told her (sic) she'd look after me and shed make sure I get a ride home. And just very briefly, that was it. And my dad left, and I went Inside with Ghislaine. Q Did Ghislaine and your dad have any discussion about what it was you were doing there, in your presence?

11 12 13 A You know, I can't recall exactly what was said. But I had already told my dad what was -- what the interview was for. So --

14 15 16 17 18 19 20 Q What did you tell your dad? A That a very nice lady approached me and told me that she would offer me an education to become a massage therapist. And it was a great -- it would be great experience for me to be able to get educated and trained and eventually be accredited. So he was very happy for me as well.

21 22 23 24 Q You told him that outside of the presence of Ghislaine? A Yes, when I first ran to the tennis courts where he was at.

25 Q And then, in your presence at the home,

Q All right. Where did you see Mary? A The same place, kitchen. 3 Q Were they talking to one another? 4 A No. Mary was doing something with the 5 dishes. They were always either cleaning up or doing 6 stuff, so -- 7 Q And you saw them in the kitchen? 8 A In the kitchen area. I mean, you have to 9 understand there's like three parts to that kitchen. 10 So its very large.

11 Q All right. What part did you see John in? 12 A In the corner, left hand. And Mary was in 13 the same vicinity but not right next to him. They 14 weren't chatting.

15 Q What is also contained in the corner, left 16 hand of the room?

17 A There's like a -- like shelves with -- I 18 don't know. Just shelves that I remember, you know, 19 open door pantry stuff.

20 Q What was Ms. Maxwell wearing when you 21 arrived at the home?

22 A I don't remember what she was wearing.

23 Q The book that you were reading at the spa 24 that day, do you recall the name of it?

25 A No. I Just know it was -- it said the

Page 122

1 did your dad and Ms. Maxwell have any conversation 2 further conversation about what you were doing there?

3 A I don't recall. I think they probably 4 would have chatted for approximately -- maybe 30 5 seconds. It really wasn't a long chat. 6 The things that stick out in my mind were, 7 We will take good care of her and we'll be 8 bringing -- we will make sure she gets a ride home. 9 Q And how far away did you live? 10 A Approximately 30 minutes. 11 Q And that's with your parents' house, 12 right?

13 A That was my parents' house. 14 Q Did you see any other employees or any 15 other people inside the house on that day?

16 A Yes. 17 Q Who else did you see? 18 A Juan Alessi. 19 Q Urn-hum. 20 A And Maria. But Jeffrey and Ghislaine like 21 to call them John and Mary.

22 Q Okay. Where did you see John? 23 A Downstairs after the whole ordeal. 24 Q Um-hum. Which room? 25 A The kitchen.

Page 124

1 word massage on the front of it. I don't know the 2 title or the author.

3 Q Do you know the color of the book? 4 A It was -- it was dark. It was a, like 5 plastic covering.

6 Q All right. And how big was it, if you can 7 just demonstrate for the video?

8 A Smaller than that. Maybe -- I don't -- 9 maybe a little bit less than that.

10 Q Can you hold it sideways for the video?

11 A (Complied.) 12 Q So you're saying the book size was a 13 little bit less than half of --

14 A Right. I mean, the book was a little bit 15 bigger. The pages were -- you know, this is very 16 small print. This is printed A4 longways, whereas, I 17 think. It wasn't A4 that way. I don't know. It was 18 just a book. And I don't know how many pages it had 19 either. I mean, approximately, maybe 100 pages.

20 Q Okay. So maybe my question wasn't a very 21 good question.

22 How big was the outside of the book, not 23 the thickness, but the length and the width?

24 A Maybe like here (indicating). 25 Q So a little bit bigger?

1 A Longer than this, yeah. We're going to
2 fold it in half again, and then like that
3 (indicating).

4 Q So larger than an 8 and a half and
5 11 piece of paper?

6 MR. EDWARDS: Form.

7 A I don't know what 8 and a half and
8 11 inches is. If this is 8 and a half and 11 inches,
9 then yes. It's (indicating).

10 Q (BY MS. MENNINGER) So when you fold it in
11 half, is that a little bit smaller, folded in half,
12 than the book --

13 A Yeah, if I were going to hold the book
14 like this, if I were going to sit there and read the
15 book like this, in my mind it would be a little bit
16 bigger than what I'm holding right here.

17 Q All right. So you're demonstrating the
18 book as it's opened that way?

19 A Yeah, let's just say I'm reading it like
20 this.

21 Q Okay. Got it.

22 MS. MENNINGER: I'm going to suggest we
23 take a short break. We can --

24 MR. [REDACTED]
25 [REDACTED] MENNINGER: -- order lunch for you

1 guys and then do a little bit more before the lunch
2 gets here --

3 MR. [REDACTED]
4 [REDACTED] MENNINGER: -- if that works for
5 everybody.

6 MR. EDWARDS: Yeah, that's great.

7 MS. MENNINGER: All right. Let's do that.

8 THE VIDEOGRAPHER: We're off the record at
9 11:38.

10 (Recess taken from 11:38 a.m. to
11 11:57 a.m.)

12 THE VIDEOGRAPHER: We're back on the
13 record at 11:57.

14 Q (BY MS. MENNINGER) How long were you at
15 the El Brillo home on that first day you went?

16 A Over two hours.

17 Q Okay. And who took you home?

18 A Juan Alessi.

19 Q And what car was he driving?

20 A I believe it was a black Suburban.

21 Q Did anyone else ride in the car with you?

1 A Yes.

2 Q Who else was at home when you got home?

3 A My mom, my dad and my brother.

4 Q Which brother?

5 A Sky.

6 Q And anyone else who was there at the time?

7 A I believe Michael might have been living
8 with me at that time. So he might have been there.

9 Q Do you recall if he was there when you got
10 home?

11 A I don't really remember. I remember what
12 I did when I got home, that I basically made a
13 beeline for the bathroom.

14 Q Let me ask you a question. Michael was
15 living with you at that home, at your parents' home
16 at the time, is your best recollection today; is that
17 right?

18 A That's my best recollection, yes.

19 Q When you say living with you, were you
20 guys staying in the same room?

21 A Yes.

22 Q Were you engaged at that time to him?

23 A That was a really weird relationship. He
24 was a friend who looked after me, and he did propose
25 to me and I did say yes. But my heart was never in

1 it.

2 He was somebody that helped me off the
3 streets so I felt compelled to say yes to him.

4 Q Okay. So when he proposed to you and you
5 said yes, did that take place before you started
6 working at Mar-a-Lago or after you started working at
7 Mar-a-Lago?

8 A Before.

9 Q And so if he were living with your parents
10 at that time, you were living in the same room; is
11 that correct?

12 A I believe so.

13 Q And your parents understood him to be your
14 fiance?

15 A I don't think they agreed with it, but I
16 think they understood it as that. I mean --

17 Q I mean, you communicated to them that he
18 had proposed and you had accepted?

19 A Yeah, in not such a pretty way. I mean,
20 they obviously weren't very happy about it. And it
21 wasn't my true intentions to ever marry him.

2 A Oh, they never thought it was going to go
3 forward either.

4 Q When you got home, you said you made a
5 beeline for the bathroom?

6 A Correct.

7 Q And what did you do in the bathroom?

8 A I showered.

9 Q Okay. Did you have a conversation with
10 anyone prior to going to the bathroom?

11 A My mom came into the bathroom and -- and
12 she, you know, she asked me how it went. And I told
13 her I'd rather not talk about it. And she didn't
14 push me any further for any more conversation.

15 Q Okay. And then she left the bathroom?

16 A She left the bathroom.

17 Q Did anyone overhear that conversation?

18 A No, the door was closed.

19 Q Was your dad at home?

20 A Yes.

21 Q Did you have a conversation with your dad
22 that night?

23 A Not that I remember, no.

24 Q And did you have any other conversation
25 with your mother that night?

1 A No.

2 Q Did you have any conversation with your
3 brother that night?

4 A No. He's -- he's five years younger than
5 me. It's not something I'd talk to him about.

6 Q And did you have any conversation with
7 [REDACTED] that night?

8 A I could have. I don't remember having
9 one, but I could have.

10 Q Did you call any of your friends that
11 night?

12 A No.

13 Q Who were your good friends at that time?

14 A [REDACTED] (phonetic). That was
15 really it. I didn't really have many friends. I
16 kept to myself a lot.

17 Q Did you call [REDACTED] that night?

18 A I don't think [REDACTED] and I were -- we were
19 on and off friends from middle school. And no reason
20 on and off like we had an argument or something. We
21 just got out of touch.

2 A I can tell you that she had very large
3 natural breasts. I can tell you that her public hair
4 was dark brown, nearly black. I don't remember any
5 specific birthmarks or moles that I could point out
6 that would be relevant.

7 Q Any scar?

8 A I don't remember any scars.

9 Q Any tattoos?

10 A No tattoos.

11 Q When did you next go to the El Brillo
12 house?

13 A I believe it would have been the next day.

14 Q You believe it would have been or was it?

15 MR. EDWARDS: Form.

16 A I know that it was consecutive, that I
17 continued to go there after my first -- the first
18 time that the abuse took place there. It was
19 consecutive that I was there, I believe, over the
20 next course of weeks.

21 Q (BY MS. MENNINGER) What day of the week
22 was the first time you went?

23 A I don't know.

24 Q Do you know whether you went the very next
25 day or not?

1 A I believe I did.

2 Q All right. How did you get there the very
3 next day?

4 MR. EDWARDS: Form.

5 A I believe my dad dropped me off again.

6 Q (BY MS. MENNINGER) When you say you
7 believe, do you recall him doing that or are you
8 guessing?

9 A I don't -- well, this is how I figure
10 this. I don't remember Ghislaine picking me up from
11 Mar-a-Lago. I didn't have my own car. So the only
12 way I could have really gotten there would have been
13 my dad picking me up -- I mean, sorry, dropping me
14 off.

15 Q Do you have a distinct recollection of
16 your father dropping you off there more than one day
17 in a row?

18 A Yes.

19 Q You do not recall the car he was driving?

20 A Like I said, he always drove trucks.
21 That's as good as I can get.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 another weekday or was it on a weekend? MR. EDWARDS: Form. A I don't know. Q (BY MS. MENNINGER) Do you know if you went after work at Mar-a-Lago? A Yes. Q So you went to work the very next day at Mar-a-Lago? A Yes. Q Did you have a conversation with anyone at Mar-a-Lago about the day before at El Brilio? A No. Q You didn't talk to any of your coworkers about it? A No. Q Who was your boss at the time? A No. Q Did you have a boss at the time? A I think Adriana or Adrienne. I don't remember the exact pronunciation of her name, but It's along those lines. I believe she was my boss. Q And you did not talk to her about It? A No. Q You surmise that your father dropped you off because you can't think of another way you would

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 time. Q So did you introduce yourself as or asM A Most likely =. Q Do you recall this or is this something that you're guessing about? A Well, considering that everybody knew me as I think I would have introduced myself as Q You don't recall it? MR. EDWARDS: Form. A I don't recall the exact answer to that, no, but Just knowing I had everybody pretty much call me I= Q (BY MS. MENNINGER) I'm just trying to make a clear record about what you do remember and what you're guessing about. So when you say I think I would have, it leads me to believe you don't recall it. If you mean something different by that -- A I -- Q -- please feel free to clarify. I'm just trying to explain to you what I'm asking. A Yes. And I'm doing the very best that I can tell you exactly what it Is. But it's Just hard

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have gotten there, correct? A Correct. Q And when you came the second day, did your father come to the door? A I don't think he came to the door that time. I think I was just dropped off. Q All right. And what did you do when you got there? A Q Q Alessi? A Jeffrey, Ghislaine and Q Okay. And where did you see A She was downstairs. Q Did you speak to her? A Just introductions. Q Tell me what you mean by Introductions. A My name is M. Nice to meet you. Her name, she introduced herself as And she told me she was Ghislaine's personal assistant. Q Did you call yourself at the time? A No, I think I've gone by for a long Knocked on the door and -- Who answered the door? Juan Alessi. Okay. Was anyone else there besides Juan

1 for me to remember so long ago. And knowing that I 2 introduced myself as to everybody leads me to 3 assume that I would have introduced myself to them as 4 -as well. 5 Q All right. But if we were to speak to 6 , she might have a different recollection, 7 fair to say? 8 MR. EDWARDS: Form. 9 A She could. 10 Q (BY MS. MENNINGER) How is it that you 11 knew to come there on this second day? 12 A I was asked to come back. 13 Q When were you asked to come back? 14 A The day before, after the encounter they 15 told me to come back at the same time after work. 16 Q Who is they? 17 A Jeffrey and Ghislaine. 18 Q Okay. Did they both simultaneously say 19 that or did one of them say it? 20 A It was like a conversation that they both 21 had with me separately. Jeffrey told me upstairs 22 after the whole entire abuse had happened that he 23 really liked me and he'd like me to come back. 24 When I went downstairs •- 25 Q Let me just stop you there. Did he say, I

2 A Yes. 2 Q It was continuous. Name one girl that 3 Q Okay. Did he tell you what time tomorrow 3 Ghislaine Maxwell had sex with in your presence.

4 he wanted you to come back? 4 A I mean, that's a name that I

5 A No, he just said he wants me to come back 5 know well because was always around.

6 tomorrow. 6 I'm trying to think of her name, sorry.

7 Q Okay. And then you went downstairs and 7 Her name used to be I think 8 what happened? 8 she's changed it now that she's married.

9 A Ghistaine told me I did a really good Job 9 (phonetic) -- I can't

10 and she wants me to come back tomorrow after work. 10 pronounce her last name properly, but it's around

11 Q That's what she said, I want you to come 11 those lines. 12 back tomorrow after work? 12 There were a lot of other girls that I

13 A Yes. 13 honestly can't remember their names. I'm sorry. I

14 Q You recall those words being used by her? 14 wish I could help out more because I really would

15 A Yes. 15 like to provide more witnesses for this, but I can't

16 Q Did you ask them for a ride to get there 16 remember a lot of girls' names.

17 the next day? 17 Q So those are the three names of females 18 A No. 18 that you observed Ghlslaine Maxwell have sex with --

19 Q You Just said, I'll come back tomorrow. 19 MR. EDWARDS: Object to the form.

20 A Yeah. I agreed to come back the next day. 20 Mischaracterizes testimony.

21 Q How did you agree? 21 Q (BY MS. MENNINGER) -- Is that what I 22 A Verbally. 22 understand your answer to be?

23 Q Okay. Was anyone else present when 23 MR. EDWARDS: Objection. Mischaracterizes

24 Ghislaine said that to you and you responded, I'll 24 her testimony.

25 come back tomorrow? 25 A Those are -- those are some three of the

1 A I believe Juan Alessi was pretty much 1 names that I know very well. Like I said, there was

2 within ear distance. 2 a lot more.

3 Q Could you see him? 3 Q (BY MS. MENNINGER) Okay. Do you know the 4 A Yes. 4 names of any other girl that you personally observed

5 Q Okay. 5 Ghislaine Maxwell have sex with?

6 A Like I said, in ear distance, when I mean 6 A Do you mind me taking a minute to just try

7 ear distance like hearing, in the hearing vicinity. 7 to reflect?

8 And it was in the same time that she was asking him 8 Q No.

9 to drop me off at home. 9 A Um, her name is on the tip of my tongue.

10 Q Okay. When you were driving home the 10 Her last name is I don't remember her 11 first night with Juan Alessi, did you have any 11 first name off the top of my head. I normally could 12 conversation with him? 12 remember it.

13 A No. I had told him my address. It was a 13 Q Okay.

14 very quiet ride. 14 A There's just a blur of so many girls.

15 Q Did you ride in the front or the back? 15 It's really hard for me to remember. And you have to 16 A The front. 16 understand we weren't introduced to each other on a

17 Q It is your contention that, Ghislaine 17 first name basis half the time. A lot of these girls

18 Maxwell had sex with underage girls virtually every 18 would come and go and you'd never see them again. 19 day when I was around her, correct? 19 So, no, it's very difficult for me to

20 A Yes. 20 pinpoint exactly who they were. But those four that

21 Q All right. With whom did Ghislaine 21 I've given you are 100 percent.

22 Maxwell have sex in your presence? 22 Q Okay. Did you observe Ghislaine Maxwell

24 involved. We weren't on a first name basis with each 24 contact with her? 25 other. I wouldn't be able to give you lists of names 25 MR. EDWARDS: Form.

1 A I don't believe that any of the girls 2 involved were truly willing participants doing it out 3 of their own wanting. I believe we were all there 4 for one purpose, and that was to keep Jeffrey and 5 Ghislaine happy and to do our Jobs, which was giving 6 them erotic massages and keeping them pleased 7 sexually.

8 Q (BY MS. MENNINGER) Okay. Do you know 9 what the word force means, physical force?

10 A If you mean like held down or a gun put to 11 the head, then no.

12 Q Okay.

13 A But force in a word -- like a way of 14 coercion. There was definitely indirect threats that 15 you knew these people were powerful. They had a lot 26 of contacts. They were very wealthy. They were 17 people you did not want to cross lines with on a bad 18 way.

79 Q Okay. What threats did you hear Ghlsialne 20 Maxwell state to you?

21 A lust the reminders of the prominent people 22 that she knows personally.

23 Q When did Ghislaine Maxwell remind you 24 about the prominent people that she knows personally?

25 A It was on a constant basis. I mean, there

1 Mischaracterins her testimony.

2 You can answer.

3 A You wouldn't want to piss us off. You 4 wouldn't want to piss me and Jeffrey off. I mean 5 that's one way of saying it. Other than --

6 Q (BY MS. MENNINGER) Did she say, I don't 7 want -- you would not want to piss me off?

8 A Piss me off is probably my word, using 9 piss, but it was along those lines. I don't remember 10 the exact word that she used.

11 Q And do you remember a specific occasion on 12 which she said that to you?

13 A I remember very early on.

10 Q Where were you? 15 A I believe it was during my, what I call

16 the training period with Jeffrey and Ghislaine. 17 Q Okay. And where were you?

18 A For a specific -- and like I said, it 19 happened a lot. But for one specific, I remember

20 being out on the balcony in the house at El Brillo, 21 sitting outside with her. This is when I thought 22 that -- I didn't know that I worked for Jeffrey

23 Immediately. I thought I worked for Ghislaine 24 because she was the one who brought me in. And she 25 was the one offering the majority of the training to

1 was no just one time that she said it. It was like a 2 reminder, you know. And Jeffrey did a lot more of 3 that than she did. But she definitely made it aware 4 that we shouldn't cross boundaries with them.

5 Q Or what would happen? 6 A Like I said, it was more of an indirect 7 threat. And it doesn't take an intellect to figure 8 out what they mean when they say that they're 9 powerful people and they're very wealthy and they 10 know a lot of people.

11 Q I need you to be very clear. You just 12 used the word "they." I've asked you about Ghislaine 13 Maxwell.

14 A Okay.

15 Q So I just want to make sure you understand 16 the question.

17 A Correct.

18 Q Because I don't want to have you, you 19 know, misunderstand the question.

20 A Correct.

21 Q So I'm asking you, what did Ghislaine 22 Maxwell say would happen in regards to crossing a 23 line with respect to her knowledge of famous people?

1 me.

2 3 So, yeah, it was on the balcony, Outside, I believe the yellow room.

4 S 6 Q She said, You would not want to piss me off because I know powerful people, or words to that effect?

7 A Words to that effect, yes.

8 Q And did she say what would happen if you 9 pissed her off because she knows powerful people?

10 A That statement alone was enough to let me 11 know. I was scared and I didn't want to -- I didn't 12 want to push any further into that question. I

13 seemed like I would obey.

14 Q Up until that point in your life, had you 15 met any powerful people?

16 MR. EDWARDS: Form.

17 A I do believe that I've been put in very 18 dangerous situations, being a runaway and having a 19 lot of bad things happen to me. Understanding the 20 word powerful people and things that could happen,

21 I've put two and two together and knew what she 22 meant.

23 Q (BY MS. MENNINGER) Okay. So you had met 24 powerful people before the day that Ghislaine Maxwell 25 said this to you; is that your testimony?

1 A Nowhere near as powerful as Jeffrey and 2 Ghislaine, nowhere near. But people that did scare 3 me, yes. 4 Q Okay. And you had met those people at 5 what age? 6 A I don't know what age I was. I'm sorry. 7 I was young. I was -- before I met Jeffrey and 8 Ghislaine.

9 Q Is there any girl who you personally 10 observed to have sexual contact with Ghislaine 11 Maxwell when she was under the age of 18?

12 A It's very hard to tell how many girls were 13 under the age of 18. My instruction from them was 14 the younger the better.

15 Q And, again, them, who told you that? 16 A Them, both of them. They both --

17 Ghislaine did the majority of my training in the 18 beginning. Jeffrey also insinuated and told me lots 19 of things as well.

20 Q Okay. So you don't know the age of any 21 other female that you saw have sexual contact with 22 Ghislaine Maxwell --

23 MR. EDWARDS: Object --

24 Q (BY MS. MENNINGER) -- is that true?

25 MR. EDWARDS: Object to the form of the

1 2 3 4 5 6 7 of all the girls that were sent to Jeffrey and Ghislaine. That is my answer. Q (BY MS. MENNINGER) I did not ask you about the girls who were sent to Jeffrey and Ghlslaine. I asked you about any girl that you personally saw have sexual contact with Ghislaine Maxwell.

8 Do you understand that question?

9 A Do I know the ages of them?

10 11 Q Do you know the age of any girl that you saw have sexual contact with Gills'eine Maxwell?

12 13 14 15 16 17 A Well, for Instance, I mean, was, I think, a year older than me. That's one way of putting It. older than me. I think was like a few years again, a few years older than me. I mean, those are the girls that I can actually name.

18 19 20 Without, not knowing the other girls' names, there's no way for me to identify what age they actually were.

21 22 23 24 Q Okay. Describe for me any other girl other than the ones that you've named who you say you saw have sexual contact with Ghislaine Maxwell with your own two eyes.

25 A There's so many I don't know where you

Page 146

1 question. Mischaracterized her testimony. She 2 wasn't finished with her answer.

3 MS. MENNINGER: I wasn't finished with my 4 question when you objected. And at the end of my 5 question I said, "Is that true?" She can now restate 6 it without you suggesting to her the answer.

7 MR. EDWARDS: I have no idea what the

8 question is to even object to at this point.

9 Do you know the question?

10 A Do I know any underage girls that 11 Ghislaine slept with.

12 MS. MENNINGER: Can you please read back 13 the question?

14 (Record read as requested.)

15 MR. EDWARDS: Hold on. She wasn't 16 finished with her question, she told me. So that's 17 not the finished question.

18 MS. MENNINGER: You interrupted it. I 19 finished my question. She just read it to her.

20 Q (BY MS. MENNINGER) Can you please answer 21 the question?

1 2 3 4 5 want me to start. I find it impossible to answer that question with the amount of girls that I have witnessed. And without being able to give you specific names, I don't think Cm able to answer that question.

6 7 8 Q Okay. I asked you to describe them, so you could give me a height, a hair color, anything else that comes to mind?

9 10 11 A There were blondes, there were brunettes, there were redheads. They were all beautiful girls. I would say the ages ranged between 15 and 21.

12 13 Q And why do you believe the ages ranged from 15 to 21?

14 15 16 17 18 19 A Some of them looked really young. Some of them, I wouldn't say 21 looks old or anything like that, but it's hard to gauge another person's age without really asking them. But some of them looked younger than me and some of them looked older than me.

20 21 Q And in what physical locations did you see Ghislaine Maxwell have sexual contact with any girl?

Page 148

1 A In cabanas. Do you know what I mean by 2 cabana?

3 Q I do, thank you.

4 A In cabanas, in Jeffrey's room.

5 Q Describe Jeffrey's room on U.S. V.I. for 6 me.

7 A So can I use this as an idea? Like if 8 this is the island -- can I do that?

9 Q I'm asking you to describe the inside of a 10 room.

11 A Oh, the inside of a room. I thought you 12 meant located.

13 Q Um-hum.

14 A Okay. Large, stony. He had a king size 15 bed with posts on it. There was a large door, I

16 think its called a door, where you put your clothes. 17 There was an adjacent bathroom with a more stony 18 look, giant tub.

19 Q What color was the paint on the wall? 20 A It was stone.

21 Q What color was the bedspread?

22 A White.

23 Q What color were the sheets? 24 A White.

25 Q And you saw Ghislaine Maxwell have sexual

2 But, yes, outside by the pool, down by the beach

3 there's these -- they're little -- I wouldn't call It

4 a hut. Little tiny wooden room that only could fit a

5 bed in it.

6 Q I'm talking about outside.

7 A That's outside.

8 Q So let's start with by the pool.

9 A Yes.

10 Q Is that a different occasion than the hut?

11 A I'm talking about many occasions.

12 Q Okay.

13 A Overtime.

14 Q Let's Just talk about the ones that you

15 saw happen outside, out of doors.

16 A Okay.

17 Q Okay?

18 A Yeah.

19 Q Do you recall any such specific occasion

20 or is it just a big blur in your mind?

21 A No, I mean, one occasion stands out.

22 Models were -- I think they were models -- were flown

23 In. There were orgies held outside by the pool.

24 That's one occasion.

25 Q All right. Let's stick with that

1 contact with an unknown, unnamed female in that room, 2 correct?

3 A Absolutely.

4 Q All right. When were you there that you 5 saw this happen?

6 A This happened on so many occasions. The

7 island was a place where orgies were a constant thing

8 that took place. And again, it's impossible to know 9 how many. And, like I said, it wasn't just Jeffrey's

10 room. It was outside and, you know. It was --

11 Q When you were outside did you see 12 Ghislaine Maxwell have sexual contact with a female?

13 A When you say sexual contact does that mean

14 fornicating or down to taking explicit photos or 15 what -- can you define what you mean by sexual

16 contact?

17 Q Sure. It generally, in my mind, means 18 placing either mouth or intimate parts or hands on

19 the breasts, buttocks, or pubic area of another

20 person for sexual gratification.

21 A Sure. 22 Q Did you see Ghislaine Maxwell have sexual

23 contact with a woman outside on the U.S. Virgin 24 Islands?

I occasion.

2 A Okay.

3 Q What sexual contact did you observe

4 Ghislaine Maxwell have with a female by the pool at 5 an orgy on the U.S. Virgin Islands?

6 A Well, there was quite a few girls and it

7 was -- excuse me, if I'm saying this in an inexplicit

8 way, but I don't know how else to say it. So if you

9 don't understand, please let me know -- girl-on-girl

10 action. So there was a lot of -- what's the word for

11 it? Licking, licking vaginas, breasts.

12 Q Okay. Which --

13 A Fingers being used. She was involved with

14 that. I remember specifically I had to go down -- do 15 you know what I mean by go down?

16 Q It's your testimony. Go ahead.

17 A I had to go down on Ghislaine. Jeffrey 18 was there as well.

19 Q And this is -- we're still by the pool?

20 A We're still by the pool with lots of 21 girls.

22 Q Can you name any of those girls that were 23 there?

Q Can you describe them physically? 2 A Beautiful, tall, some were blonde, some 3 were sandy They had a foreign tongue. 4 Q What -- what language were they speaking? 5 A I'm not too sure. It could have been 6 Russian. It could have been Czechoslovakian. It 7 could have been -- I think It's between those two, to 8 be honest. It could have been something else but, I 9 mean, I don't speak any other language other than 10 English, so I don't really know. 11 Q All right. Any other time you saw 12 Ghislaine Maxwell have sexual contact with another 13 female outdoors in the U.S. Virgin Islands other than 14 this, models with the unknown language? 15 A Are we talking about besides with me as 16 well? 17 Q I don't know if you participated. I'm 18 asking if you observed her have sexual contact with 19 another female? 20 A Another female other than myself? 21 Q You can answer it however you want. 22 A Well, and the list keeps going on. 23 Ghislaine and I and Jeffrey and 24 participated in, I guess what you would call a 25 foursome in the living room in the main house.

1 Q More than 20? 2 A I would say more than 20. 3 Q More than SO? 4 A I don't think more than SO, but -- 5 Q Did -- 6 A I don't have an exact number. I mean, 7 if -- I think if yOu look at the flight logs, you 8 know, that helps, but then they're not fully 9 complete. We only have flight logs to one plane and 10 then there's a time I was flown commercially into the 11 island. 12 Q Um-hum. 13 A So it's really hard for me to gauge a 14 number. 15 Q Okay. Do you have any photographs of 16 yourself on the Island? 17 A I know I used to, but they would be left 18 in that apartment. 19 Q What other locations did you participate 20 in sexual contact with Ghislaine Maxwell, other than 21 the island? 22 A Everywhere. New York, Palm Beach. 23 Q Where in New York? 24 A The mansion, Jeffrey's mansion. 25 Q Okay. Anywhere else In New York?

Page 154 1 Q Okay. I was asking about outdoors. 2 Sorry. 3 A Oh. Well, I don't know if you'd consider 4 this outdoors, but on the beach where those -- it's 5 basically an outdoor setting. It's like a little 6 wooden house. It's not a house, only a bed can fit 7 in there. It's right on the beach. It's open. 8 Q Um-hum. 9 A Would you consider that outdoors? 10 Q I have never been there. So I don't know 11 whether it's outdoors or not. 12 A I would consider it outdoors. And -- 13 Q How old were you at that time? 14 A I don't know. 15 Q Okay. 16 A I have no idea. Again, Ghislaine, myself, 17 Jeffrey, another girl in this blue, outdoor -- I 18 don't know what you want to call it. Cabana, that a 19 house -- just a bed could fit in. 20 Q How many times did you visit the island? 21 A I wouldn't be able to say. Lots of times. 22 Q More than five? 23 A Definitely more than five. 24 Q More than ten? 25 A More than ten.

Page 156 1 A Not at her townhouse. 2 Q Anywhere else in New York? 3 A No. 4 Q In Palm Beach? 5 A At the house in Palm Beach. 6 Q Anywhere else in Palm Beach? 7 A No. 8 Q In New Mexico? 9 A The house in New Mexico. 10 Q Anywhere else in New Mexico? 11 A No. 12 Q What other countries? 13 A France, uhm, England. Um -- we also -- I 14 mean, if we're going to talk about other countries 15 we've got to talk about international travel space or 16 plane space or whatever you want to call it because 17 it happened all the time on the planes. 18 Q Okay. 19 A Going from different country to country. 20 Q Where in France did you have sexual 21 contact with Ghislaine Maxwell? 22 A There's a couple places in France that we 23 used to go to. 24 Q When you say you used to go to, how many 25 times did you go to France?

A I think I've been to France three times. 2 Q All right. How old were you when you went 3 to France? 4 A I don't know. 5 Q Did you have a passport when you went to 6 France? 7 A I would have had to, yes. 8 Q You did have a passport when you went to 9 France? 10 A Yes. 11 Q And you went to France three times, you 12 believe? 13 A Yes. 14 Q And when you were in France those three 15 times, how many of those three times did you have 16 sexual contact with Ghislaine Maxwell? 17 A Every time. 18 Q And in what locations in France did you 19 have sexual contact with Ghislaine Maxwell? 20 A The first time that I remember, we stayed 21 at a really fancy hotel. 22 Q In what city? 23 A Paris. 24 Q Okay. 25 A And it was within the view of the Champs-

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 with Gillslalne Maxwell at this hotel room overlooking 2 the Champs-Elysees? 3 A Before she picked up the redhead. Q And was that Just you and Ghislaine or was anyone else a participant In that? A Jeffrey and Q And where else in France did you have sexual contact with Ghislaine Maxwell? A The south of France. Q Where? A I wouldn't call it so much a hotel. I don't know what you'd call It. It had like big townhouse kind of things that you could rent out. Q Was this on the same trip or a different trip? A Different trip. Q Okay. Who else was present for that? A Well, we were going to birthday party. It wasn't at the birthday party. Q Right. A It was before the birthday party. Q Oh, you had sexual contact with Ghlslalne Maxwell before you went to birthday party? MR. EDWARDS: Form.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Elysees. Q room? A Page 158 Did you have your own room or a sep We all stayed in the same room, but that room had adjoining rooms to it. So, you know, one hotel room but with different rooms in it. Q Okay. And anywhere else on that one trip that you went? A She brought in a redheaded French girl. She walked up to her in Paris and, you know -- Q In your presence? A In my presence. Q Urn-hum. A And she walked up to this French girt to show me how easy it was for her to procure girls. I wasn't very good at it. And, you know, it was part of my training was to bring in other girls. So she walked up to her. Within five minutes she had her number and that girl came over later that night to the hotel and serviced Jeffrey. I didn't see Ghislaine with her. I just know she told me what happened and Jeffrey told me what happened. 23 Q So you were not there? 24 A I did not see it. 25 Q Okay. When did you have sexual contact

Page 160 1 A That's correct. 2 Q (BY MS. MENNINGER) And who else was 3 present during your supposed sexual contact with 4 Ghislaine Maxwell on this occasion? 5 MR. EDWARDS: Object to the form of the 6 question. 7 A It wasn't supposed. It actually happened. 8 And Ghislaine was present, Jeffrey was present. I 9 believe was present as well. 10 Q (BY MS. MENNINGER) Anyone else? 11 A There was someone else on that trip with 12 us, but they weren't involved with the sexual 13 activity at that time. 14 Q Okay. And what was the other location in 15 France? 16 A I believe the same exact place. I mean, 17 we stayed there for a few days. 18 Q Okay. So the three locations are hotel in 19 Paris, same place, same place? 20 A Correct. 21 Q And the second and third same places were 22 on the same trip? 23 A Same trip. 24 Q Okay. And then you had a third trip to 25 France where you did not have sexual contact with

3 A I believe -- it's hard for me to remember.

4 I remember going to quite a few different countries

5 on that trip. I don't know if it was -- I don't know

6 If we did it in Paris or not, to be honest. We did

7 it in other places. But I've been to Paris three

8 times -- or not Paris, sorry, France.

9 Q (BY MS. MENNINGER) Okay. All right.

10 When did you first tell your parents that you would

11 be traveling with Jeffrey Epstein?

12 A I'm not too sure when I actually told

13 them.

14 Q How long after you were working with

15 Jeffrey Epstein did you travel with him?

16 A Well, I know my first trip was to New

17 York. I would say anywhere between six weeks -- I

18 would say after six weeks.

19 Q You were -- you had known Jeffrey Epstein

20 for six weeks before you started traveling with

21 him --

22 A I believe.

23 Q -- am I understanding that correct?

24 A I believe so. I mean, that's an

25 approximate answer.

3 THE VIDEOGRAPHER: We're off the record at

4 12:42.

5 (Recess taken from 12:42 p.m. to

6 1:21 p.m.)

7 THE VIDEOGRAPHER: We're back on the

8 record at 1:21.

9 Q (BY MS. MENNINGER) All right.

10 I want to talk to you about where you

11 were living In the late '90s. Do you recall -- you

12 testified earlier, I believe, that you were living at

13 your parents' house and you gave us an address at the

14 time you started at Mar-a-Lago.

15 A Yes.

16 Q Do you remember where you lived previous

17 to living at your parents' house at that time?

18 A Like I said, I was a runaway, so there was

19 a lot of different places I lived. One of the places

20 I lived was, like I told you earlier, with

21 parents. That was somewhere around Fort Lauderdale,

22 I believe, maybe a little bit outside of It.

23 Q Okay.

24 A got an apartment and I lived In

25 apartment for a short period.

1 Q And your first trip was to New York?

2 A Yes.

3 Q And did you just go to New York and come

4 back or did you go somewhere else?

5 A I think I just went to New York, but 1

6 can't remember if we went somewhere else.

7 Q Okay. And did you tell your parents you

8 were going to New York?

9 A Yes.

10 Q And do you recall any part of your

11 conversation with your parents about going to New

12 York?

13 A I didn't get into details about what I was

14 having to do with Ghislaine and Jeffrey. I didn't

15 tell them that, but I told them I was going to New

16 York.

17 Q And you don't recall telling them anything

18 else about it?

19 A I don't know. I mean, I might have called

20 them from New York and told them it was cold and, you

21 know, just simple stuff. But I can't really recall

1 Q And where do you recall that being?

2 A Somewhere in Fort Lauderdale, again.

3 Q Okay. And then you were living with your

4 parents or was there another place in between?

5 A Then I lived with my parents.

6 Q Okay. And then where is the next place

7 that you moved?

8 A An apartment that Jeffrey got for me in

9 Royal Palm Beach.

10 Q Okay. And you don't know the address of

11 that?

12 A No, I wish I could give it to you. I

13 don't know it.

14 Q And you stayed in that apartment until you

15 left for Thailand in the fall, later in the year in

16 2002, correct?

17 A Yes.

18 9 Right?

19 A Yes.

209 All right. And when did you first stop

21 living with your parents? How old were you when you

Page 165 Page 167

1 A I believe I was 11. 1 Loxahatchee, Florida were made aware that you had run

2 Q Okay. What caused you to stop living with 2 away from home at the age of 11? 3 your parents when you were 11? 3 A Yes. 4 A I just had some trouble and my parents 4 Q And what abuse had you suffered prior to 5 thought It would be better if they sent me to 5 the age of 11? 6 California. 6 A There was a very close family friend who 7 Q Okay. What trouble did you have? 7 was a very sick man. And he took advantage. 8 A It's very hard for me to talk about. 8 Q What's his name? 9 There was stuff that went on in my life that, you 9 A 10 know, made me so I -- I couldn't live with my parents 10 Q what? 11 anymore. 11 A 12 Q What went on in your life that caused you 12 Q And where is today? 13 to not be able to live with your parents at the age 13 A I don't know where he is. 14 of 11? 14 Q Does anyone in your family keep in contact 15 A Do I have to answer this? 15 with him? 16 Q Well, did you talk to Sharon Churcher 16 A No. 17 about being molested as a child? 17 Q What did he do to you? 18 A I did. 18 A Um, he touched me places I shouldn't be 19 Q And you authorized Sharon Churcher to 19 touched. He sexually abused me. 20 publish that in a newspaper, correct? 20 Q For how long? 21 A I don't think I authorized her to do it. 21 A I don't know how long. 22 I think she -- I wouldn't say she did it on her own 22 Q Did you tell that to your parents? 23 accord. But I talked to her about it and I wasn't 23 A They know. 24 aware of exactly what she was going to publish and 20 Q How do they know? 25 what she wasn't. 25 A I told them.

Page 166 Page 168

1 Q So you were able to talk to a reporter for 1 Q Did you tell them when you were under the 13 somewhere else. 13 Q Did the event of you being molested cause

2 the Mail On Sunday about this, correct? 2 age of 11 or at the age of 11? 3 A I did tell her a little bit about my past 3 A I told them later. 4 and where I came from. 4 Q When did you tell them? 5 Q All right. So what caused you to be sent S A It took me a long time to forgive my 6 away from your parents' home at the age of 11 to 6 parents for sending me away. I didn't feel like 7 California? 7 anybody understood me. So not until later in my life 8 A Some of the prior abuse which led me to be 8 did I feel like I was able to talk to anyone about 9 a very troubled young teenager. I mean, I guess you 9 it. 10 wouldn't call 11 a teenager yet, but led me to 10 Q Okay. Was it reported to the authorities? 11 running away a lot and -- and my family just thought 11 A No. I went too late to talk to anybody 12 it was best that I get out of the area and move 12 about it. 14 Q Okay. You had run away prior to being the 14 your parents to split up? 15 age of 11? 15 A I think Sharon reported that, but I don't 16 A Yes. 16 think that's the case, no. My parents split up 17 Q All right. Was that reported to the 17 because they were really messed up. 18 authorities? 18 Q Your parents split up because they were 19 A That I ran away? 19 really messed up? 20 Q Yes. 20 A . they just didn't get along. There 21 A Yes. 21 were a lot of marital problems. 22 Q And where were your parents living at the 22 Q When did they split up? 23 age of 11? 23 A I don't really remember what year it was. 24 A The same address I gave you earlier. 24 Q How old were you? 25 Q Okay. So the authorities associated with 25 A I believe I was living with Jeffrey at the

3 A My -

4 Q And who else?

5 A

6 Q And with who else?

7 A That's it.

8 Q And for how long did you live with them?

9 A I don't really know how long, maybe over a

10 year, maybe two years.

11 Q And then what caused you to not live with 12 them anymore?

13 A I kept running away from them, too.

14 Q And where did you live in California?

15 A I'm sorry?

16 Q Where in California did you live?

17 A Where did they live?

18 Q Where did you live with them?

19 A Salinas.

20 Q And do you know the address?

21 A No.

22 Q Do they still live there?

23 A No.

24 Q When did they stop living there?

25 A I don't know. I haven't kept in contact

3 A Oh. Yes.

Q And then when did you go back to Florida?

5 A I don't know.

6 Q Was your younger brother living with your 7 parents in Florida while you were in California?

8 A Um-hum, yes.

9 Q And was your older brother living with

10 your parents in Florida while you were in California?

11 A I don't think so.

12 Q How much older than you is he?

13 A Five years.

14 Q And when you went back to Florida, where 15 did you go to school, when you got back?

16 A I believe I went to Crestwood Middle

17 School.

18 Q And did you complete your studies at

19 Crestwood Middle School?

20 A Did I get out of middle school there, yes.

21 Q Okay. What grades were middle school?

22 A Six, seven and eight.

23 Q Okay. And when you went back to live with 24 your parents again, that was at the same address in

25 Loxahatchee?

Page 170

1 with them.

2 Q And you believe you lived with them for a 3 little more than a year?

4 A Maybe a year, maybe two years. I'm not 5 too sure.

6 Q Did you go to school there?

7 A Yes.

8 Q Where did you go to school?

9 A Somewhere near Salinas, I'm assuming.

10 Q What grade were you in?

11 A Middle school.

12 Q Sixth grade, seventh grade?

13 A I think sixth grade.

14 Q And did you go there for more than one 15 year or just one year?

16 A Maybe -- I don't know. I'm sorry, I don't 17 know.

18 Q Were the authorities in Salinas alerted to 19 the fact that you ran away from home there?

20 A Yes.

21 Q How long was the longest you were away 22 from home in Salinas, California?

Page 172

1 A Yes.

2 Q And you don't believe your older brother 3 was in the home at the time?

4 A No, he was sent to boarding school.

5 Q Where did he go to boarding school?

6 A Washington.

7 Q State or city?

8 A Washington above California.

9 Q When was the next time you stopped living 10 with your parents?

11 A They sent me to a group home called

12 Growing Together.

13 Q Why?

14 A Because I kept running away.

15 Q Were the authorities alerted when you ran 16 away?

17 A Yes.

18 Q And how old were you when you went to live 19 at Growing Together?

20 A I don't know. It's hard for me to piece

21 back dates. Off the top of my head -- I don't want

22 to guess. I don't think I should guess. I don't 23 know.

A I wouldn't say directly. 2 Q How — 3 A I'd say I stayed with my parents for -- 4 like, I think I finished school at Crestwood. So I 5 would have been in, I don't know, I guess eighth 6 grade, finished eighth grade. And then -- I don't 7 know. I really don't know. Around eighth grade. 8 Q You went to Growing Together? 9 A I think -- I think it was then. 10 Q And how many years did you live at Growing 11 Together? 12 A Over a year. 13 Q Were you ever in foster care? 14 A What Growing Together was, was like a 15 group home that sent you away to foster parents every 16 night. 17 Q So you lived in other people's homes 18 during the period of time you were assigned to 19 Growing Together? 20 A Well, you stayed at Growing Together 21 during the day and then at night you get sent home 22 with parents. 23 Q Did you go to school while you were at 24 Growing Together? 25 A Yeah, they offer education there.

I between the ages of eighth grade and when you started 2 working at Mar-a-Lago? 3 A Besides the ones I've told you about, you 4 know, I did run away from Growing Together quite 5 often. And I did end up being -- being abused by 6 another older guy who I stayed with for I don't know 7 how long. 8 Q How old were you then? 9 A I don't know. I'm sorry. I really wish I 10 could pinpoint dates. I don't know dates. 11 Q Okay. What was that man's name? 12 A 13 Q And how long were you living -- were you 14 living with 15 A Yes. 16 Q And for how long were you living with him? 17 A I don't know. 18 Q Days? Weeks? Months? 19 A I don't know. I mean, it wasn't days. I 20 don't think It was weeks. It would have been close 21 to maybe a few months. 22 Q Okay. And was prosecuted 23 by federal authorities In South Florida? 24 A Yes. 25 Q And you were located by the FBI, I

1 Q So the education was at Growing Together? 2 A Yeah. 3 Q You did not attend a Palm Beach County -- 4 A I did, but you had to earn your levels up 5 to be able to go outside. So I don't remember what 6 level you have to get up to, to go out to another 7 school. I think there was like seven levels or 8 something. And you had to make it to, like, level 4 9 to be able to go to outside school. 10 Q So for some period of time you were 11 assigned to Growing Together and you were going to 12 school at Growing Together. And for some period of 13 time you were going to other schools and coming back 14 to Growing Together? 15 A Correct. 16 Q And then when you came back to Growing 17 Together, you were sent to spend the night at a 18 family's home? 19 A Yes. 20 Q So you never slept at Growing Together? 21 A No. 22 Q Did you live -- other than living at or 23 staying at Growing Together during the day and 24 sleeping at these other homes at night, is there 25 anywhere else that you recall living in the period

1 believe? 2 A Yes. 3 Q And you gave an interview to the FBI 4 concerning your time with-, correct? S A Yes. 6 Q Did you ever get a victim's notification 7 letter regarding your status as a victim in 8 federal criminal prosecution? 9 A I don't know. My parents handled 10 everything. 11 Q Do you know if your parents received such 12 a letter? 13 A I don't know. 14 Q Have you ever asked them? 15 A No, I've never really brought it up with 16 them. It really pissed them off a lot, so I never 17 brought it up with them. 18 Q It pissed them off that you were living 19 with 20 A Yes. 21 Q Why did it piss them off, if you know? 22 A Well, I think they were just disgusted, 23 you know, that this happened to me again. And they 24 didn't want to talk about it. They didn't want to 25 talk about it.

Page 177 Page 179

1 Q But they were aware of it? 1 Mar-a-Lago, correct? 2 A Yes. 2 A Yes. 3 Q Your dad came and picked you up from the 3 Q Do I have that sequence right? 4 police station? 4 A So far, yes. 5 A Yes. 5 Q And when did you stop living at your 6 Q And your dad would not let you come home? 6 parents' at the time you started working at 8 want me to come home. 8 do you stop living with your parents? 9 Q Did she say why? 9 A I don't know exact dates. I was traveling 10 A She just probably thought I was just going 10 with Jeffrey a lot, and I was making -- he was giving 11 to keep running away again. And -- 11 me lots of money for the sex that I had with him and 12 Q Did she say that to you? 12 Ghislaine. 13 A Well, I asked my dad at the police station 13 And after, I would say, a short time -- 14 if I could come home Instead of going back to Growing 14 I'm not too sure, darling, I don't know. 15 Together. And he said my mom didn't want me to come 15 Q All right. Can you -- 16 home. And I told him if he didn't get me out within 16 MS. MENNINGER: I have no recollection of 17 a week, I'd run away again and he'd never hear from 17 which number were on in terms of exhibit. 18 me again. 18 MS. RODRIGUEZ: 15. 19 Q And how Is it that you came back to be 19 Q (MS. MENNINGER) Okay. I'd like to mark 20 living at their house, then? 20 as Defendant's Exhibit IS a document and see if you 21 A I ran away again and I called him up and I 21 can identify it. 22 said, This is your final chance. And they came and 22 Actually, before I do that, when do you 23 picked me up and they let me live there. 23 recall ever getting a passport? 24 Q And when did you go live with 20 A I got my passport in New York. I don't 25 A Not long after that. 25 know what age I was.

7 A Well, I think it was more my mom didn't 7 Mar-a-Lago? How long after you started at Mar-a-Lago

Page 178 Page 180

1 Q And when did you live with Q Okay. And did you -- how did you get it? 2 parents? 2 Did you go somewhere or what happened? 3 A Well, I lived with parents 3 A Jeffrey had me fill out paperwork and go 4 before I lived with in his apartment. 4 to a Kodak shop or something similar of a Kodak shop 5 Q And that was an apartment that S and get my picture taken. I gave him my picture and 6 rented? 6 my paperwork. He sent it away. And I think a week 7 A and his friend. I can't remember 7 later he said he got it expedited. 8 his friend's name. Mario, I think his friend's name 8 Q Did you physically go to an office in New 9 was. 9 York? 10 Q When did you live with 10 A Jeffrey's office. 11 as parents? 11 Q An office associated with Immigration or 12 A That was just a brief stint. I didn't 12 Homeland Security or whatever it was called back 13 really stay there very long, but it was -- I was a 13 then? 14 runaway. That's in between times of -- I don't know. 14 A Not that I recall. 15 Q How old were you? 15 Q And do you know how old you were? 16 A I don't know. 16 A No. I don't know how old you have to be 17 Q I just want to be clear. rented 17 to get a passport, so I'm not too sure. 18 an apartment that you moved into that he had rented, 18 (Exhibit 15 marked.) 19 correct? 19 Q (BY MS. MENNINGER) Okay. I'm going to 20 A Correct. 20 show you Defendant's Exhibit 15. 21 Q And that was after you had lived with 21 Do you recognize this document? 22 and his parents, correct? 22 A Yes. 23 A Yes. 23 Q Is this document the passport application 24 Q And that was prior to you and 24 that you filled out? 25 living with your parents when you started working at 25 A Yes.

1 Q Is it in your handwriting? 2 A Yes. 3 Q All right. What did you put down as your 4 address at this time to mail the passport to? It's 5 about the second line -- third line. 6 A Number 13? 7 Q Well, the third line says, Mail passport 8 to. What address did you put down? 9 A Are we talking about number 13, Permanent 10 address, do not list P.O. box, street? 11 Q No, I'm talking about the third line In 12 the entire thing that says, Mail passport to. 13 A Oh, I'm sorry, up here, the U U 16 Q All right. So you asked to have the 17 passport mailed to you at your parents' address, 18 right? 19 A I don't know if it was mailed to my 20 parents' house, but that's the address I sent -- put 21 down, yes. 22 Q Okay. And if you look a little bit 23 further to the right, roughly equal with that line, 24 do you see a date that's stamped on there? 25 A Yeah, January 12th, 2001.

1 a 3. I think it's I really can't make out 3 the telephone number. 4 Q Okay. Do you see Relationship? Can you 5 read that? 6 A Friend. 7 Q Okay. Do you see just below that there's 8 a line that says number 21? 9 A Do not stop -- sorry, Do not sign 10 application until requested to do so by 11 administrating an oath. 12 Q Okay. 13 A Applicant's signature age 13 or older. 14 Q Oh, it's by the signature line? 15 A Yeah. 16 Q And that's your signature? 17 A Yes. 18 Q All right. And this is the document that 19 you recall filling out for your first passport? 20 A I don't recall doing it, but yes, it's in 21 my handwriting and it's got all of my information on 22 it. 23 Q Okay. And on line -- box 23 it's got your 24 driver's license checked off, right? 25 A July 23. Yeah, I really can't make out

1 Q Okay. And then if you go down a little 2 bit further, as you pointed out, line number 13, you 3 gave your permanent address as your parents' address, 4 again, correct? 5 A Correct. 6 Q If you look at box number 12 where it asks 7 for occupation, what did you write down? 8 A Masseuse. 9 Q Okay. If you look at line number 18, Have 10 you ever been issued a U.S. passport before, what did 11 you put down? 12 A No. 13 Q All right. And if you go down a little 14 bit further than that, emergency contact, who did you 15 put down? 16 A 17 Q Okay. So is that the fiancé you were 18 talking about earlier? 19 A Yes. 20 Q In January of 2001 were you still his 21 affianced? 22 A Looks like it, yes. 23 Q And what address did you put down for 24 25 A It's kind of hard to read. I think that's

1 numbers and stuff, though. 2 Q But the box, Driver's License is checked 3 off? 4 A Yes. 5 Q Okay. And then if you look in the lower 6 right-hand corner of the page, do you see what we 7 call a Bates stamp number? I don't know if you know 8 what that means. 9 A No. 10 Q Just the lower right-hand corner of the 11 document. 12 A 0047217 13 Q Okay. Thank you. 14 So at January 2001 was 15 living 16 A Well, he would have had to have been if I 17 put it down there. 18 Q Okay. Was that the apartment that he had 19 rented? 20 A No, it's in Royal Palm Beach. The 21 apartment he rented was in Fort Lauderdale. So this 22 could be my apartment that he lived at with me. 23 Q Okay. So his apartment where he lived 24 with you was in Royal Palm Beach? 25 A Yes.

Page 185 Page 187

1 Q And he rented that apartment? 1 Q Let me have you put the paper down. 2 MR. EDWARDS: Object to the form. 2 A Yes. 3 Mischaracterization. 3 Q Do you recall applying for another 4 A He lived there with me for a short period. 4 passport? 5 I don't -- I don't know how long he lived there with 5 A No. 6 me for. 6 Q Okay. Do you recall ever applying for 7 Q (BY MS. MENNINGER) And who rented the 7 another passport, ever? 8 apartment? 8 A Well, yeah, when I got to Australia I had 9 A Well, Jeffrey paid for the apartment. I 9 to -- I don't have it on me right now, but I could 10 was the occupant, and he was an occupant. 10 tell you it's -- I had to apply for another one 11 Q Did you ever see the lease? 11 because the other one ran out as expiree. 13 saying that I was living there. 13 another one from the U.S.? 14 Q So you were living at -- is it-14 A (Indicating.) 15 15 Q Have you ever gotten -- 16 A I can't honestly read it. It looks like a 16 Is that right? 17 C-a-C (sic), but that doesn't make sense. 17 A Yeah. 18 Q So January of 2001 you signed a document 18 Q Have you ever gotten a passport from 19 under oath putting 19 Australia? 21 A Yes. 21 Q Right. 22 Q And you put your permanent address and 22 A No. 24 address -- 24 get one replaced? 25 A Yes. 25 A I don't think so.

12 A Yes, I believe I had to sign the paperwork 12 Q So whenever one expired, you applied for 20 A An Australian passport? 23 your mail your passport to at your parents' 23 Q Have you ever lost a passport and had to

Page 186 Page 188

1 Q -- is that right? 1 Q When was the first time that you came back 2 And it's your position that that is the 2 to the U.S. from Australia? 3 apartment that Jeffrey paid for and you signed a 3 A October 16th, 2013. 4 lease? 4 Q And did you come back before that? 5 A Yes, Jeffrey paid for it and I think I had S A No. 6 to sign something that said I was going to occupy it. 6 Q Did you ever tell Sharon Churcher or 8 Q Okay. And you stayed at that apartment 8 on a trip to New York in 2011? 9 from at least January 2001 until you left in the fall 9 A No. 10 of 2002, right? 10 Q Is it your contention that Ghislaine 11 A I would say before then, yes. Like I 11 Maxwell sexually trafficked you to famous people? 12 said, I can't really tell you the exact date that I 12 A If you have a document in front of you 13 moved there, but -- 13 that you could show me so I could see what you're 14 Q Why did you have your passport sent to 14 talking about, yes. 15 your parent's house if you weren't living at your 15 Q I'm asking you, is it your contention that 16 parents' house? 16 Ghislaine Maxwell sexually trafficked you to famous 17 A Urn, I don't know. I guess a fail-safe. 17 people? 18 I'm not too sure. 18 A Could you be more specific, like are we 19 Q When was the next passport that you got? 19 talking about rock stars or royalty or -- 20 A I think I had to reapply for one in -- 20 Q Politically connected and financially 21 well, this one expired in 2002. So I would have had 21 powerful people. 22 to apply for another one. 22 A Yes. 23 Q I'm asking do you remember when you got 23 Q Okay. To whom did Ghislaine Maxwell 24 another passport? 24 sexually traffic you? 25 A This expired January 10th, 2002. 25 A You have to understand that Jeffrey and

7 I don't know if James ever did. 7 Sharon White or Marianne Strong that you were going

1 2 3 4 5 6 7 8 Ghislaine are joined hip by hip, okay? So they both trafficked me. Ghislaine brought me in for the purpose of being trafficked. Jeffrey was just as a part of it as she was. She was just as a part of it as he was. They trafficked me to many people. And to be honest, there is people I could name and then there's people that are just a blur. There was so much happening.

9 10 Q Okay. Please name a person that Ghislaine Maxwell directed you to go have sex with?

11 12 13 14 15 16 A Q Okay. Who else? A As a whole, they both trafficked me to people. It was under both of their direction. So it's not easy just to say Ghislaine. When I say they, I mean both of them.

17 18 19 20 21 Q Okay. Well, I need you to say a time when Ghislaine Maxwell directed you to go have sex with another person. So can you please tell me to whom Ghislaine Maxwell asked you to go have sex with another person?

22 MR. EDWARDS: Object to the form.

23 24 25 A Q (BY MS. MENNINGER) Who else? A I'm going to continue to tell you that

1 exactly what you would do for Jeffrey to him. Keep 2 him happy. I can't remember her exact words, and I'm 3 not going to put words in my mouth to make it sound a like what she said. But it was all along those 5 lines.

6 Q Those are words that Ghislaine Maxwell 7 used to you in directing you to go have sex with 8

9 MR. EDWARDS: Object to the form.

10 Mischaracterized her testimony.

11 A Along those lines, yes. 12 Q (BY MS. MENNINGER) Okay. Where were you 13 located when she used those words with you?

14 A It could have been Palm Beach. It could 15 have been New York.

16 Q You don't recall? 17 A I don't recall.

18 Q Okay. How old were you when she used 19 those words to you?

20 MR. EDWARDS: Object to the form. 21 Mischaracterizes her testimony.

22 A I don't know. I would think I was 17.

23 Q (BY MS. MENNINGER) But you're not sure? 24 A Well, it was in the beginning, like after 25 my training. were

1 they both directed me to do it. It was part of my 2 training. They both told me, you've got tickets to 3 go here. This is who you're meeting, and this is 4 what you're doing.

5 So-is another one. 6 Q Ghislaine Maxwell directed you to go have 7 sex with - 7

8 MR. EDWARDS: Object to the form to the 9 extent it mischaracterized her testimony.

10 A I'm trying to tell you that they both did, 11 Ghislaine and Jeffrey both directed me. They both 12 paid me and they both directed me.

13 Q (BY MS. MENNINGER) All right. When did 14 Ghislaine Maxwell direct you to go have sex with 15

16 MR. EDWARDS: Object to the form. Same 17 objection.

18 A I don't know the time. I don't -- you 19 know, I could tell you the place. I don't know the 20 time.

21 Q (BY MS. MENNINGER) What words did 22 Ghislaine Maxwell use in talking to you and asking 23 you to go have sex with

1 the two first people I was sent out to.

2 Q Okay. Well, I was asking about 3 okay?

4 A Right. That's what I'm saying. If you 5 want me to categorically tell you when it happened 6 and why I think I was 17, because those were the two 7 first people I was sent to.

8 Q So you don't actually recall the 9 conversation regarding 10 recall where you were, right? 7 You don't

11 A I can't picture if it was New -- I know it 12 was either New York or Palm Beach. I don't remember 13 exactly which one.

14 Q You don't recall exactly what words were 15 used by Ghislaine Maxwell in speaking to you, 16 correct?

17 A I remember the tone that she used, the 18 type of words that she used. I can't word for word 19 replay what she said.

20 Q All right. And so when in time was 21

22 23 A was months, six months, I'm not too sure.

7

1 think I met Prince Andrew in 2001. And Glenn Dubin 2 and Stephen Kaufmann were, like I said, the first 3 people I was sent out to after my training. So I 4 don't know. I'm not going to give you an exact time 5 if I don't know it.

6 Q I asked you the relative order. 7 A And I'm trying to give you it. 8 Q And where does Alan Dershowitz fit Into 9 that group of people?

10 A Same. I can't tell you piece by piece by 11 piece who -- I know Glenn Dubin was first.

12 Q Okay. 13 A And I know Stephen Kaufmann was one of the 14 first I was sent to. Alan Dershowitz could have been 15 between there. Between, sorry, between Glenn and 16 Stephen. The first time I was with Alan Dershowitz 17 was in New York, so I wasn't actually sent to him. 18 It actually happened at one of Jeffrey's residences.

19 (Ms. McCawley left the deposition.) 20 A So it's very hard for me to 21 chronologically give you each person Individually.

22 Q (BY MS. MENNINGER) Okay. Name the other 23 politically connected and financially powerful people 24 that Ghislaine Maxwell told you to go have sex with?

25 A Again, I'm going to tell you "they"

1 2 Q If you're going to tell me more names, please continue your answer.

3 A I'm trying to think.

4 5 Q If you're just going to talk -- A I'm sorry. I'm trying to think.

6 7 Q Okay. Let's take a break and then you can think over the break.

8 9 THE VIDEOGRAPHER: Were off the record at 2:01.

10 11 12 (Recess taken from 2:01 p.m. to 2:09 p.m.) THE VIDEOGRAPHER: We're back on the record at 2:09.

13 14 Q (BY MS. MENNINGER) Ms. IM you have filed a lawsuit against Ghislaine Maxwell, correct?

15 16 17 A Yes. Q You understand her to be my client, correct?

18 A Yes.

19 20 Q I'm here today to talk to you about your allegations against Ghislaine Maxwell.

21 Do you understand that?

22 A Yes.

23 24 25 Q you recall Ghislaine Maxwell using words to you and directing you to go have sex with another person -- I want you to tell me a single time that

1 2 because that's how it went. They instructed me to go to George Mitchell, Jean Luc Brunel, Bill Richardson, another prince that I don't know his name. A guy

3 4 5 that owns a hotel, a really large hotel chain, I can't remember which hotel it was. Marvin Minsky.

6 7 8 9 10 11 12 13 14 There was, you know, another foreign president, I can't remember his name. He was Spanish. There's a whole bunch of them that I just -- its hard for me to remember all of them. You know, I was told to do something by these people constantly, told to -- my whole life revolved around just pleasing these men and keeping Ghislaine and Jeffrey happy. Their whole entire lives revolved around sex.

15 16 They call massages sex. They call modeling sex. They call --

17 18 19 Q I asked you the names for people. Are you going to tell me any other names or is that all of them?

20 21 22 A I'm trying to think. That's the answer I'm trying to give to you. It's that it's so hard to just keep naming and naming and naming.

23 Q All right. 24 A A lot of times I would be introduced to 25 them. I didn't know --

1 MR. EDWARDS: Object.

2 3 Q (BY MS. MENNINGER) -- not anybody else, Ghislaine Maxwell?

4 5 MR. EDWARDS: Objection. Asked and answered.

6 7 To the extent that she can answer the question, I'd ask that she answer the question.

8 9 A I have answered the question. The question that you're asking me is Ghislaine. And

10 11 Ghislaine and Jeffrey worked together. They were one and the same of persons. They both directed me to do

12 13 this. They both directed me to report back to them. They were both the same.

14 15 Q (BY MS. MENNINGER) You cannot recall a single instance in which Ghislaine --

16 A I have to --

17 Q Excuse me.

18 -- in which Ghislaine Maxwell alone

19 directed you to have sex with another person --

20 A I have to --

21 Q -- correct?

22 A -- believe --

Page 197 Page 199

1 Q (BY MS. MENNINGER) Correct? 1 was going to be trained as a masseuse and that she 2 MR. EDWARDS: Are you finished with your 2 instructed me to take off my clothes and to give oral 3 question? 3 sex to Jeffrey Epstein. 4 MS. MENNINGER: Now you may make your 4 Q (BY MS. MENNINGER) Excuse me. I've asked 5 objection. And then she may answer. 5 you for the names. 6 MR. EDWARDS: Okay. Objection. 6 A I've just given you a name. Jeffrey 7 Argumentative. Harassing for absolutely no reason. 7 Epstein is a big name. 8 Mischaracterizing the witness's testimony. 8 Q All right. 9 Answer, if you can. 9 A She Instructed me on that one. 10 A I have given you the names of the people 10 Q So you're saying -- 11 that Ghislaine herself has told me to go be sex 11 MR. EDWARDS: The witness is finishing her 12 trafficked to, along with Jeffrey Epstein, okay? 12 answer right now. She's in the process of explaining 13 She's the one who brought me to Jeffrey 13 one of the people Ghislaine told her to have sex 14 Epstein to be trafficked In the fucking first place. 14 with. is So I have given you as much information as 15 Q (BY MS. MENNINGER) So you're saying 16 I possibly can to let you know what she was about, 16 Ghislaine Maxwell directed you to have sex with 17 who she told me to go with, what she wanted me to do. 17 Jeffrey Epstein? 18 That is what I am stating and that's what I 18 A Correct. 19 previously stated to you. 19 Q Ghislaine Maxwell directed you to have sex 20 Q (BY MS. MENNINGER) And these names that 20 with Glenn Dubin? 21 you have just given are people to whom Ghislaine 21 A Correct. 22 Maxwell alone told you to go have sex? 22 Q What words did Ghislaine Maxwell tell you 23 MR. EDWARDS: Objection. 23 to go have sex with Glenn Dubin? 24 Mischaracterization. 24 A It was the same all the time, all right? 25 A Ghislaine and Jeffrey, I don't know how 25 They want me to go provide these men with a massage.

Page 198 Page 200

1 many times you want me to keep answering this 1 And when they say massage, that means erotic, okay? 2 question. Both told me to do this, okay? They both 2 That's their term for it. I think there are plenty 3 sent me to these people. 3 of other witnesses that can attest to what massage 4 How many times do you want me to answer 4 actually means. 5 this? 5 And I'm telling you that Ghislaine told me 6 Q (BY MS. MENNINGER) I think you're 6 to go to and give him a massage, which 7 answering a different question so that's why I'm 7 means sex. 8 going to ask you again. I am not asking you anything 8 Q Okay. So -- Ghislaine Maxwell told 9 about a time when Jeffrey and Ghislaine together told 9 you to go give a massage to 10 you to go do something. I'm asking you to name a 10 A Correct. 11 single time during which Ghislaine Maxwell acting 11 Q That's your testimony? 12 alone directed you to go have sex with another 12 A That is my testimony. 13 person? 13 Q All right. Ghislaine Maxwell told you to 14 MR. EDWARDS: Objection. Asked and 14 go give a massage to correct? 15 answered. Harassing. Argumentative. 15 A Correct. 16 A I've given you the names of the people 16 Q Ghislaine Maxwell told you to give a 17 that Ghislaine instructed me to go have sexual 17 massage to correct? 18 relations with. I am not discluding (sic) the fact 18 A Correct. 19 that Jeffrey also told me. 19 Q Ghislaine Maxwell told you to give a 20 Ghislaine told me from her mouth to do 20 massage to, correct? 21 these things. Jeffrey told me from his mouth to do 21 A Correct. 22 these things with these people. Ghislaine instructed 22 Q When did Ghislaine Maxwell tell you to 23 me to do the things that I did with Jeffrey Epstein 23 give a massage to-? 24 on the very first meeting that I had with him. She 24 A I don't know dates. 25 brought me there under the preclusion (sic) that 1 25 Q Where were you?

1 A When it happened? 2 Q When Ghislaine Maxwell used the words, Go 3 give a massage to Bill Richardson, where were you? 4 MR. EDWARDS: Object to the form. 5 Mischaracterizes her testimony. 6 A I can't tell you where we were. I know 7 where I was sent to. I don't know where we were when 8 she told me to do that. 9 Q (BY MS. MENNINGER) Where were you sent 10 to -- 11 A New Mexico. 12 Q by Ghislaine Maxwell? 13 MR. EDWARDS: Object to the form. 14 Mischaracterizes her testimony again. 15 A Are you smiling at me because -- 16 Q (BY MS. MENNINGER) No, I'm asking you to 17 answer the question. 18 A I have answered the question. I was sent 19 to New Mexico. 20 Q Okay. Where were you sent from? 21 A I already answered that. I don't know 22 where I was sent from. 23 Q Okay. 24 A I was flying everywhere with these people. 25 Q Where were you sent by Ghislaine Maxwell

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1 know where it was when she said to go do this. 2 Q (BY MS. MENNINGER) Okay. Where were you 3 sent to have sex with the owner of a large hotel 4 chain by Ghislaine Maxwell? 5 MR. EDWARDS: Object to the form. 6 A I believe that was one time in France. 7 Q (BY MS. MENNINGER) Which time in France? 8 A I believe it was around the same time that 9 Naomi Campbell had a birthday party. 10 Q Where did you have sex with the owner of a 11 large hotel chain in France around the time of Naomi 12 Campbell's birthday party? 13 A In his own cabana townhouse thing. It was 14 part of a hotel, but I wouldn't call it a hotel. 15 Jeffrey was staying there. Ghislaine was 16 staying there. was staying there. I was 17 staying there. This other guy was staying there. I 18 don't know his name. 19 I was instructed by Ghislaine to go and 20 give him an erotic massage. 21 Q She used the words erotic massage? 22 A No, that's my word. The word massage is 23 what they would use. That's their code word. 24 Q Was she in the room when you gave this 25 erotic massage to the owner of a large hotel chain?

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1 to have sex with 2 MR. EDWARDS: Object to the form. 3 Mischaracterized her testimony. 4 A Many places. 5 Q (BY MS. MENNINGER) Ghislaine Maxwell sent 8 9 10 11 12 13 14 15 6 you to many places to have sex with 7 MR. EDWARDS: Object to the form. A It happened at many places, yes. Q (BY MS. MENNINGER) You had sex with= at many places is what you're saying, 18 19 20 Ghislaine Maxwell send you to have sex with the owner 21 of a large hotel chain? 22 MR. EDWARDS: Object to the form. 23 Mischaracterization. 24 A I'm going to keep answering the questions 25 the same way that I keep answering them. I don't correct? A I was sent to-at many places to have sex with him. Q When did Ghislaine Maxwell send you to a place to have sex with 7 16 A You are asking -- 17 MR. EDWARDS: Form. A -- me to answer the impossible. Q (BY MS. MENNINGER) All right. When did

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1 A No, she was not in the room. She was in 2 another cabana. 3 Q And other than telling you to go give the 4 owner of this large hotel chain a massage, do you 5 remember any other words she used to you to direct 6 you in what you should do? 7 A Not at the time, no. 8 Q Where did -- where were you and where was 9 Ms. Maxwell when she directed you to go have sex with 10 Marvin Minsky? 11 MR. EDWARDS: Object to the form. 12 A I don't know. 13 Q (BY MS. MENNINGER) Where did you go to 14 have sex with Marvin Minsky? 15 A I believe it was the U.S. Virgin Islands, 16 Jeff's -- sorry, Jeffrey Epstein's island in the U.S. 17 Virgin Islands. 18 Q And when was that? 19 A I don't know. 20 Q Do you have any time of year? 21 A No. 22 Q Do you know how old you were? 23 A No. 24 Q Other than Glenn Dubin, Stephen Kaufmann, 25 Prince Andrew, Jean Luc Brunel, Bill

1 another prince, the large hotel chain owner and 2 Marvin Minsky, is there anyone else that Ghislalne 3 Maxwell directed you to go have sex with? 4 A I am definitely sure there is. But can I 5 remember everybody's name? No. 6 Q Okay. Can you remember anything else 7 about them? 8 A Look, I've given you what I know right 9 now. I'm sorry. This is very hard for me and very 10 frustrating to have to go over this. I don't -- I 11 don't recall all of the people. There was a large 12 amount of people that I was sent to. 13 Q Do you have any notes of all these people 14 that you were sent to? 15 A No, I don't. 16 Q Where are your notes? 17 A I burned them. 18 Q When did you burn them? 19 A In a bonfire when I lived at Titusville 20 because I was sick of going through this shit. 21 Q Did you have lawyers who were representing 22 you at the time you built a bonfire and burned these 23 notes? 24 A I've been represented for a long time, but 25 it was not under the instruction of my lawyers to do

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Q Including Mr. Edwards, who is sitting 2 right here, correct? 3 A Correct. 4 Q What did that journal look like? 5 A It was green. 6 Q And what else? 7 A It was just a spiral notebook. 8 Q Okay. And what did you put into that 9 green spiral notebook? 10 A Bad memories. Things that I've gone 11 through, lots of things, you know. I can't tell you. 12 There was a lot of pages. It was over 300 pages in 13 that book. 14 Q Did you ever show that book to your 15 lawyers? 16 A No. 17 Q Did you show that book to anyone? 18 A My husband. 19 Q Did you show it to anyone else besides 20 your husband? 21 A No. 22 Q Did you tear out pages and give them to 23 Sharon Churches*? 24 A No, I wrote -- those pages that you're 25 talking about, I wrote for her specifically. She

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1 this. My husband and I were pretty spiritual people 2 and we believed that these memories were worth 3 burning. 4 Q So you burned notes of the men with whom 5 you had sex while you were represented by counsel in 6 litigation, correct? 7 MR. EDWARDS: Object to the form. 8 A This wasn't anything that was a public 9 document. This was my own private journal, and I 10 didn't want it anymore. So we burned it. 11 Q (BY MS. MENNINGER) When did you write 12 that journal? 13 A Just over time. I started writing it 14 probably in, I don't know, I can't speculate, 2012, 15 2011. 16 Q So you did not write this journal at the 17 time it happened? 18 A No. 19 Q You started writing this journal 20 approximately a decade after you claim you finished 21 being sexually trafficked, correct? 22 A Yes. 23 Q And you started writing a journal after 24 you had a lawyer, correct? 25 A Correct.

Page 208 1 wanted to know about the Prince Andrew incident. 2 Q So that's a different piece of paper? 3 A Yeah, that's just random paper. 4 Q So you had a green spiral notebook that 5 you began sometime in 2011 or 2012 in which you wrote 6 down your recollections about what had happened to 7 you, and you burned that in a bonfire in 2013. 8 Did I get that right? 9 A You got that right. 10 Q And do you have no other names of people 11 to whom you claim Ghislalne Maxwell directed you to 12 have sex, correct? 13 A At this time, no. 14 Q Is there any document that would refresh 15 your recollection that you could look at? 16 A If you have a document you'd like to show 17 me, I would be glad to look at It and tell you the 18 names I recognize off of that. 19 Q I'm just asking you if there's a document 20 you know of that has this list of names in it? 21 A Not in front of me, no. 22 Q Where is the original of the photograph 23 that has been widely circulated in the press of you 24 with Prince Andrew? 25 A I probably still have it. It's not in my

3 A Probably in some storage boxes. 3 A Jeffrey Epstein.

4 Q Where? 4 Q And where did you have it developed?

5 A In Sydney. 5 A I believe when I got back to America.

6 Q Where in Sydney? 6 Q So where?

7 A At some family's house. We got the boxes 7 A I don't know. 8 shipped to Australia, and they were picked up off the 8 Q Palm Beach? 9 porch by my nephews and brought to their house. 9 A I don't know.

10 Q Which is where? 10 Q What is the date the photograph was

11 A In Sydney. 11 printed?

12 Q Where in Sydney? 12 A I believe it's In March 2001.

13 A 13 Q Okay.

14 Q And who lives in that house? 14 A But that's just off of my photographic

15 A Well, it's owned by my mother-in-law and 15 memory. I don't -- It could be different, but I 16 father-in-law, but my nephews live in the house. 16 think it's March 2001.

17 Q What are their names? 17 Q You have a photographic memory?

18 A I'm not giving you the names of my 18 A I'm not saying I have a photographic 19 nephews. 19 memory. But if I'd look at the back of the photo and

20 Q What's the address of the house? 20 I remember what it says, I believe it was March 2001.

21 A Why would you want that? 21 Q Did the photograph ever leave your

22 Q I want to know where the photograph is. 22 possession for a while?

23 I'm asking you where the photograph is. And you've 23 A I gave it to the FBI.

24 just told me it's somewhere in 20 Q Okay. And when did you get it back?

25 A Yes. 25 A When they took copies of it.

1 Q So where I. is the photograph 1 Q When was that? 2 located? 2 A 2011.

3 A If I can't 100 percent say that the 3 Q When they came to interview you? 4 photograph is there, it could be at my house that I 4 A Yes. 5 presently live in. I'm not going to give you the 5 Q So from 2011 until you left Colorado it 6 address of my nephews' residence. 6 was in your personal possession?

7 Q When is the last time you saw the 7 A Yes.

8 photograph in person? 8 Q What other documents related to this case

9 A When I packed and left America. 9 are in that, storage boxes in Australia?

10 Q Colorado? 10 MR. EDWARDS: Object to the form.

11 A Yes. 11 A Documents related to this case -- there --

12 Q All right. So you had that photograph 12 I don't know. I really can't tell you. I mean,

13 here with you in Colorado? 13 there's seven boxes full of Ned guns, my kids' toys, 14 A Yes. 14 photos. I don't know what other documents would be

15 Q What's on the back of the photograph? 15 in there.

16 A I'm sorry? 16 Q (BY MS. MENNINGER) Did anyone search 17 Q Is there anything on the back of the 17 those documents after you received discovery requests

18 photograph? 18 from us in this case?

19 A There's like the date it was printed, but 19 A I haven't been able to obtain those boxes.

20 no writing or anything. 20 I can't get them sent back up to me. It's going to 21 Q Okay. Does it say where it was printed? 21 cost me a large amount of money. And right now I'm

22 A I don't believe so. I think it just -- I 22 trying to look after my family, so I'm not able to 23 don't remember. I just remember there's a date on 23 afford to get them up. 24 it. 24 Q You live in Australia, correct?

1 Q Okay. How far away are the boxes from 2 where you live In Australia? 3 A Sydney is down here at the bottom. Cairns 4 is up here at the top. 5 Q Okay. 6 A It's probably a six-day drive. 7 Q Did you fly here through Sydney? 8 A No. 9 Q Have you been to Sydney since you've moved 10 back to Australia? 11 A I flew into Sydney with my three kids, but 12 it was a connecting flight to Brisbane. 13 Q Did you ask your nephews or anyone else to 14 search those boxes in response to discovery requests 15 that we issued in this case? 16 A They are my nephews. I would never let 17 them look at those. 18 Q Other than your green spiral notebook, 19 what else did you burn in this bonfire in 2013? 20 A That was it. 21 Q That's the only thing? 22 A Yes. 23 Q Did you use wood? 24 A Yes. 25 Q Charcoal?

2 3 4 5 6 7 9 10 11 12 13 U 15 16 17 18 19 20 21 A My husband built the bonfire out of wood and I don't know what else he put in it. He's the one who always makes the fires, not me. Q Who else was present? A )ust him and I. Q Were your kids there? A No. They were inside sleeping. Q And what beach was this? A It wasn't a beach. It was in my backyard. Q What's your address? A At that time? Q Urn-hum. A A Yes. Q Who were your neighbors? A Sweet people. Ray and -- I could look on my phone if you want. Q No, thank you. Do they still live there? A Yes. Q Do you keep in touch with them? 22 A Last time I talked to them was a few 23 months ago. 24 Q Did they see the fire? 25 A They've seen many fires that we've had.

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Page 215

1 We've had lots of bonfires there. 2 Q Did you ever ride in a helicopter with 3 Ghislaine Maxwell acting as pilot of the helicopter? 4 A Yes. 5 Q Who else was on the flight? 6 A I've been on the helicopter with her 7 plenty of times. I can't mention how many people 8 were on the -- on the helicopter at the same time. 9 Q How many times? 10 A I don't know. Do you have helicopter 11 records that you could show me? 12 Q I'm asking you how many times you were on 13 the helicopter with Ghislaine Maxwell acting as the 14 pilot -- 15 A It's impossible for me to answer the 16 question without having the actual physical records 17 in front of me. 18 Q I'm asking you to look into your memory 19 and tell me how many times you recall being on a 20 helicopter with Ghislaine Maxwell at the pilot seat? 21 A There is no number I can give you. 22 There's plenty of times I've been on her helicopter. 23 Q Where did you go from and to on a 24 helicopter? 25 A I believe it was -- don't quote me on this

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1 because I get confused on the islands there. I want 2 to say it was St. John's. It could have been 3 St. Baits. St. John or St. Baits, and then we would 4 fly straight to Jeffrey's island. 5 Q Okay. Did you ever go anywhere else on 6 the helicopter? 7 A No. 8 Q Were you ever on the helicopter with. 9 and Ghislaine Maxwell as the pilot of the 10 helicopter? 11 A No. 12 Q Were you ever on the helicopter with. 13 and Ghislaine Maxwell as the 14 pilot? 15 A No. 16 Q Do you recall telling Sharon Churcher that 17 you were? 18 A No. 19 Q Did you see the press article in which 20 Sharon Churcher reported that you were? 21 MR. EDWARDS: Objection. I'd just ask 22 that if you're going to ask this witness about a 23 specific article I'd like for her to see the article. 24 Otherwise she's not going to testify about it. 25 If you have something to show her, then,

1 please. 2 Q (BY MS. MENNINGER) Do you recall seeing a 3 press article in which Sharon Churcher reported that 4 you were on a helicopter with and 5 Ghislaine Maxwell as the pilot?

6 MR. EDWARDS: Again, I'll let you answer 7 the question once she's looking at the document that 8 you're being asked about.

9 MS. MENNINGER: You're not letting her 10 answer a question about whether she recalls a 11 particular press statement?

12 MR. EDWARDS: I will let her answer every 13 question about the press statement as long as she 14 sees the press statement. I'm okay with that. She 15 can answer all of them.

16 MS. MENNINGER: No, there Is a rule of 17 civil procedure that allows you to direct a witness 18 not to answer a question when there's a claim of 19 privilege.

20 What privilege are you claiming to direct 21 her not to answer this question?

22 MR. EDWARDS: I thought that you wanted 23 accurate answers from this witness. If the -- 24 MS. MENNINGER: I asked her if she 25 recalled something --

1 flying on a helicopter with Ghislaine Maxwell?

2 A I believe that It was taken out of 3 context. Ghislaine told me that she flew. 4 in. And Ghislaine likes to talk a lot of 5 stuff that sounds fantastical. And whether It's true 6 or not, that is what I do recall telling Sharon 7 Churcher.

8 Q So you told Sharon Churcher that Ghislaine 9 Maxwell is the one who told you that she New. 10 in the helicopter?

11 A I told Sharon Churcher that Ghislaine flew 12 onto the island, based upon what 13 Ghislaine had told me.

14 Q Not based upon what had told 15 you, correct?

16 A Correct. 17 Q Did you ever ask Sharon Churcher to 18 correct anything that was printed under her name, 19 concerning your stories to Sharon Churcher?

20 A I wasn't given those stories to read 21 before they were printed.

22 Q After they were printed did you read them? 23 A I tried to stay away from them. They were 24 very hard. You have to understand it was a very hard 25 time for me and my husband to have to have this

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1 MR. EDWARDS: If the sole purpose is to 2 just to harass her --

3 MS. MENNINGER: I asked her if she 4 recalled something --

5 MR. EDWARDS: Then that's just not going 6 to be what's happening today.

7 Q (BY MS. MENNINGER) All right. So you're 8 refusing to answer a question about whether you 9 recall a particular press statement --

10 MR. EDWARDS: She's --

11 Q (BY MS. MENNINGER) is that true? 12 MR. EDWARDS: She is not refusing to 13 answer any questions. She --

14 A I'm not refusing to answer. I just want 15 to see the article you're talking about so I can be 16 clear in my statement.

17 Q (BY MS. MENNINGER) Do you recall seeing a 18 press article written by Sharon Churcher reporting 19 that you flew on a helicopter with and 20 Ghislaine Maxwell as the pilot?

21 A No, I do not recall reading a press 22 article saying that I was on a helicopter with. 23 as Ghislaine is the pilot.

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i public -- we didn't think it was going to be this 2 publicly announced and that big. So we turned off 3 the news and we stopped reading so many things.

4 Q You didn't read the articles about your 5 stories to Sharon Churcher --

6 A I've read some articles --

7 Q Let me just finish. You did not read the 8 articles published by Sharon Churcher about your 9 stories to Sharon Churcher?

10 A I have read some articles about what

11 Sharon Churcher wrote. And a lot of the stuff that 12 she writes she takes things from my own mouth and 13 changes them into her own words as journalists do.

14 And I never came back to her and told her 15 to correct anything. What was done was done. There 16 was nothing else I can do.

17 Q So even if she printed something that were 18 untrue you didn't ask her to correct it, correct?

19 A There was things that she printed that 20 really pissed me off, but there was nothing I could 21 do about it. It's already out there.

22 Q She printed things that were untrue, 23 correct?

1 A I wouldn't say that they were untrue. I 2 would Just say that she printed them as journalists 3 take your words and turn them into something else.

4 Q (BY MS. MENNINGER) She got it wrong? 5 MR. EDWARDS: Object to the form. 6 Mischaracterization.

7 A In some ways, yes.

8 Q (BY MS. MENNINGER) Did she print things 9 in her articles that you did not say to her?

10 MR. EDWARDS: I object and ask that the 11 witness be given the opportunity to see the document 12 so that she can review it and answer that question 13 accurately. Otherwise she's unable to answer the 14 question. I'm not going to allow her to answer.

15 MS. MENNINGER: You know the civil rules 16 tell you not to suggest answers to your client.

17 Q (BY MS. MENNINGER) And you understand 18 your lawyer is now directing you to not all of a 19 sudden remember what your answer is. That's what 20 he's suggesting that you say. So you're not supposed 21 to listen to him suggest that to you. You're 22 supposed to tell me from your memory.

23 MR. EDWARDS: That is not what I'm --

24 Q (BY MS. MENNINGER) Did you -- 25 MR. EDWARDS: That's not what I'm doing. 1 to why I want my client to answer all of these 2 questions, but I want her to have the fair 3 opportunity to see this document.

4 Q (BY MS. MENNINGER) Did Sharon Churcher 5 print things that you felt were inaccurate?

6 MR. EDWARDS: Same objection. Same 7 instruction. If she sees the document, she's going 8 to answer every one of these questions.

9 Q (BY MS. MENNINGER) Did any other reporter 10 print statements that you believe are inaccurate?

11 MR. EDWARDS: Same objection. Same 12 instruction.

13 Q (BY MS. MENNINGER) Did any reporter print 14 statements about Ghislaine Maxwell that were 15 Inaccurate?

16 MR. EDWARDS: Same objection. Same 17 instruction.

18 This is harassing. This is harassing a 19 sexual abuse victim. And all I'm asking is for 20 fairness, that we just let her see the document so 21 she can answer this.

22 MS. MENNINGER: Mr. Edwards, please stop 23 saying anything other than an objection, what the 24 basis is, or instructing your client not to answer.

25 MR. EDWARDS: I will do that.

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1 You don't get to just talk over me and 2 tell my client when not to listen to me. All you 3 have to do to get answers is show her the document 4 you're talking about, and I'll let her answer every 5 question. I don't know why we're so scared of the 6 actual documents.

7 MS. MENNINGER: I don't know why you're 8 scared of your client's recollection, Mr. Edwards. 9 But anyway --

10 MR. EDWARDS: Why would you do this to 11 her?

12 Q (BY MS. MENNINGER) Did Sharon Churcher 13 print things that you did not say?

14 MR. EDWARDS: I'm going to instruct my 15 client not to answer unless you give her what it is 16 that you're talking about that was printed. And she 17 will tell you the answer, the accurate answer to your 18 question. Just without the document to refresh her 19 recollection and see it, she's not going to answer 20 the question.

21 Q (BY MS. MENNINGER) Did Sharon Churcher 22 print things that you did not say?

23 MR. EDWARDS: Same objection. Same 24 instruction not to answer.

1 2 MS. MENNINGER: That's what the Federal Rules of Civil Procedure provide.

3 4 5 MR. EDWARDS: I hear you. They also provide for fairness and civility. And all I'm asking, very calmly, is for her to see this.

6 8 9 10 11 MS. MENNINGER: Mr. Edwards, this is not your deposition. I'm asking your client what she remembers. If she doesn't want to talk about what she remembers, then let her not answer. But you cannot instruct her not to answer unless there's a privilege.

12 What privilege --

13 14 MR. EDWARDS: I am instructing her not to answer.

15 16 17 18 Q (BY MS. MENNINGER) All right. You are refusing to answer questions about whether statements to the press about Ghislaine Maxwell attributed to you were inaccurate?

19 20 MR. EDWARDS: She's not refusing not to answer.

21 22 23 A You are refusing to show me these documents so I could answer properly. I would give you an answer if you were to show me some documents.

24 25 Q (BY MS. MENNINGER) You can't say without looking at a document whether the press attributed to

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A Please show me the document.

Q You can't say from the top of your head

whether any Inaccurate statement has been attributed to you In the press?

A Please show me a document and I will tell you.

Q Are you refusing to answer my questions

about your knowledge of whether Inaccurate statements have been attributed to you In the press?

A Are you refusing to give me the documents to look at?

Q Are you refusing to answer the question?

A I am refusing to answer the question based upon the fact that you are not being fair enough to

let me see the document in order to give you an honest answer.

A Yes.

Q — we are talking about press that has been published on the Internet, correct?

A Yes.

Q Do you have access to the Internet?

A Yes.

Q Have you looked on the Internet and read

2 Q And did you write a long document or a 3 short document? What was it?

4 A I can't recall how long the document was, 5 but I would say it would be a few pages.

6 Q And other than asking you to write

7 whatever you remember about did she 8 give you any other directions about what you should 9 write?

10 A She was interested in two things, really.

11 How Epstein got away with so many counts of child 12 trafficking for sex and how was 13 involved in it. Those were her two main inquiries.

14 Q What did she ask you to write?

15 A She asked me to write about

16 Q Did she tell you to put it in your own 17 handwriting?

18 A No, she Just asked me to write down what I 19 can remember.

20 Q Did you give her everything that you 21 wrote?

22 A Did I give her the whole entire pages that

23 I wrote?

24 Q Yes.

25 A Yeah, I wrote pages for her specifically.

Page 226

1 articles that attribute statements to you about

2 Ghislaine Maxwell?

3 A Yes.

4 Q Do you know any statement that has been

5 attributed to you in a press article on the Internet 6 about Ghislaine Maxwell that is untrue?

7 MR. EDWARDS: Same objection. Same 8 instruction.

9 A Please show me a specific document.

10 Q (BY MS. MENNINGER) Do you know of any 11 such statement about Ghislaine Maxwell attributed to 12 you by the press that is inaccurate?

13 A If you could please show me a specific 14 document.

15 Q Tell me what Sharon Churcher asked you to 16 write for her.

17 A Any knowledge that I had about my time 18 with

19 Q And did you write it?

20 A Um-hum.

21 Q What did you write it in or on?

22 A Paper.

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1 Q In your own handwriting?

2 A In my own handwriting.

3 Q And what you wrote, was that true?

4 A Yes.

5 Q And did you get paid for those pieces of 6 paper?

7 A Not for the papers, I don't believe.

8 Q Okay. Have you gotten paid when they've 9 been reprinted?

10 A No.

11 Q Have you negotiated any deal with Radar 12 Online?

13 A No.

14 Q Have you negotiated any deal with Sharon 15 Churcher for the purpose of publishing those pieces 16 of paper?

17 A Not those pieces of paper.

18 Q When did you write those pieces of paper? 19 MR. EDWARDS: Object to the form.

20 A A week before she came out.

21 Q (BY MS. MENNINGER) And when did you give 22 them to her?

1 2 Q What did you get paid for, if not for those pieces of paper?

3 MR. EDWARDS: Object to the form.

4 5 6 7 A I was paid for the picture with with his arm around me, Ghlslaine In the background. And I was paid for the, I guess, the print of the stories.

8 Q (BY MS. MENNINGER) Anything else?

9 A No.

10 11 Q You were not paid for those pieces of paper?

12 A No.

13 14 Q All right. And how many pieces of paper did you write?

15 A Like I said, I'm rounding it around three.

16 Q Three pieces of paper?

17 18 A That's what I -- I don't remember to be exact on a number. I'm sorry. But over three pages.

19 Q And you wrote those sometime in 2011?

20 21 A The week that she was coming out to see me.

22 Q And you gave them to her, right?

23 A I gave them to her.

24 Q Did you keep a copy of that?

25 A No.

2 A No. I think -- I think they had played 3 the guessing game and I was 17.

4 Q And so Ghislaine Maxwell did not tell

5 that you were only 16?

6 MR. EDWARDS: Object to the form. 7 Speculation.

8 Q (BY MS. MENNINGER) In your presence?

9 A I don't remember the exact conversation.

10 I just remember they liked to play the guessing game 11 a lot.

12 Q And so you don't recall Ghislaine Maxwell

13 telling in your presence that you were 14 quote, only, really only 16, right?

15 A Correct, I don't remember that.

16 Q And if that were in the paper, that would 17 be untrue, correct?

18 A Correct.

19 MS. MENNINGER: I think now might be a 20 good time for a break.

21 THE DEPONENT: Thank you.

22 MR. EDWARDS: Okay. Sounds good.

23 THE VIDEOGRAPHER: We're off the record at

24 2:45.

25 (Recess taken from 2:45 p.m. to 2:55 p.m.)

1 Q Did you rip them out to make them look 2 like they came out of a journal?

3 A No.

4 Q Were you directed to make them look like 5 they came out of a journal?

6 A No.

7 Q Do you know why your lawyer would have 8 told the federal judge in New York that that's what 9 you did?

10 MR. EDWARDS: Object to the form.

11 A My lawyer in New York?

12 Q (BY MS. MENNINGER) Um-hum.

13 A Ripped them out of a journal?

14 Q Said that you had. Do you know why she 15 would have said that?

16 A Maybe she thought that I did.

17 Q But you didn't?

18 A They were just pieces of paper written for 19 Sharon Churcher's purpose.

20 Q And not directed to look like they came 21 from a journal?

22 A Nobody told me to make them look like they 23 came from a journal. They were just pieces of paper 24 that I wrote down for Sharon Churcher.

THE VIDEOGRAPHER: We're back on the 2 record at 2:55.

3 Q (BY MS. MENNINGER) Do you have any 4 photographs of yourself either nude or in a sexually 5 compromising position that you claim were taken by 6 Ghislaine Maxwell?

7 A I do not have any of those in my evidence.

8 But if you ask Ghislaine Maxwell, she would have 9 plenty.

10 Q Do you have any In your storage boxes in 11 Sydney?

12 A No.

13 Q Do you know whether your attorneys have 14 any such photographs that you claim were taken by

15 Ghislaine Maxwell?

16 A No.

17 Q You don't know or they don't have them?

18 A I don't know. And I don't think they have 19 them. If they had them, they would have told me.

20 You should ask your client. She's got plenty of 21 them.

3 A Again, I don't know types of cameras. I 3 Q Did you tell him what you were doing to

4 mean, I use my phone for using a camera. So it's a 4 other people? 5 black camera and it had a lens that you could put out 5 A I don't think I told him about many other 6 further or bring back. 6 people, no.

7 Q Did you ask her to take any photographs of 7 Q What people did you tell him about? 8 you? 8 A Mainly Ghislaine and Jeffrey.

9 A No. She asked to take photographs of me. 9 Q When did you tell him that?

10 Q Was it a film or a digital camera? 10 A From the start.

11 A I never saw how she printed them out. 11 Q When was the start that you told him?

12 Q What's the first time you told anybody 12 A From, I wouldn't say the first meeting, 13 that you had been sexually trafficked? 13 but I told him around that time.

14 MR. EDWARDS: Form. 14 Q And what did tell you to

15 A Tony Figueroa, my ex-boyfriend, knew some 15 do? 16 of the stuff that was happening, though I did not go 16 A He didn't mind what I had to do. Again, 17 in great detail to him, being that he's my boyfriend. 17 he was another guy that used me because I made lots 18 And then the first person I really opened up to about 18 of money, and he didn't tell me to do anything. 19 everything was my husband. 19 Q Did he tell you not to tell the police?

20 Q (BY MS. MENNINGER) Did you tell Tony 20 A No, he didn't tell me not to do anything. 21 Figueroa that you were forced to have sex with 21 Q Did he tell you to tell the police? 22 Jeffrey Epstein? 22 A Again, he told me not -- he didn't tell me

23 A Yes. 23 to do anything.

24 Q Did you tell Tony Figueroa you were forced 24 Q When did you tell your parents that you 25 to have sex with Ghislaine Maxwell? 25 were sexually trafficked by Jeffrey Epstein?

1 A Yes. 1 A After I had my kids.

2 Q Did you tell that Ghislaine 2 Q When did you tell your parents that you 3 Maxwell sent you to have sex with famous people? 3 were sexually trafficked by Ghislaine Maxwell?

4 A Yes. 4 A I told them the same time about Jeffrey 5 Q When did you tell that? 5 and Ghislaine. So sometime after I had my children.

6 A During conversations. Like, I'd call him 6 Q After you had had all three children or

7 from places that I was at and just talk to him. And 7 after you had your first child? 8 like I said, I wouldn't get into great detail about 8 A I think after I had all three of my 9 things. But, you know, I had to be with this person 9 children.

10 or that person today and -- 10 Q What was the last year in which you had a

11 Q Did you tell not to call the 11 child? 12 police? 12 A 2010.

13 A No. enjoyed his lifestyle with me. 13 Q So you believe you told your parents 14 So he wouldn't have gone to the police. 14 sometime after 2010 that you had been sexually

15 Q Did you tell that 15 trafficked? 16 you were sexually trafficked? 16 A Yes.

17 A You know, I don't know what I told 17 Q You didn't tell your parents that you had 18 at the time. I know he asked me and I think I told 18 a lawsuit entitled lane Doe 102 versus Jeffrey

19 him, but I didn't get into detail with him. 19 Epstein in 2009?

20 Q What do you think you told him? 20 A I wasn't very close with my parents.

21 A That I wasn't just massaging these people. 21 Q Why not?

Q Do you get along with your parents now? 2 A I get along with my parents now, yes. 3 Q Okay. Have you ever told anyone that you 4 were a sex slave for four years? 5 A Under the assumption that I got my dates 6 wrong, yes, I probably have. 7 Q And that's not true, correct? 8 A Not because I didn't mean it to be true. 9 Just because I didn't know my dates. 10 Q So four years Is not two years, correct? 11 MR. EDWARDS: Object to the form. 12 A Four years is not two years. 13 Q (BY MS. MENNINGER) What did your parents 14 say when you told them that you had been sexually 15 trafficked by Jeffrey Epstein and Ghislaine Maxwell? 16 A I believe they were disgusted. 17 Q What did they tell you to do or to not do? 18 A I don't remember the exact conversations 19 that we had, but they weren't happy. 20 Q Were they both on the phone at the same 21 time? 22 A No. 23 Q Who was on the phone first? 24 MR. EDWARDS: Object to the form. 25 A I don't know.

1 been through. I think for ten, however long many 2 years, I mean, over ten years, I had tried to start a 3 new life, become a new person. And I wanted to put 4 all that stuff behind me and not think about It. But 5 after you have children, something changes In you and 6 you Just want to stand up and do the right thing and 7 protect any other children from having to go through 8 this. 9 Q Did you tell your parents how much money 10 you received from your settlement with Jeffrey II Epstein? 12 A No. That Is a -- I think there's like a 13 non-disclosure statement. I don't know exactly what 14 the legal term is, but -- 15 Q Did you send any money to your parents? 16 A No, I don't -- no. No, I've never sent 17 money to my parents. 18 Q Who is 19 A One of shady friends. 20 Q Did you talk to about 21 your involvement with Jeffrey Epstein? 22 A No. 23 Q Did you ever live with 24 A No, he used to come over to my house. 25 Q Between 2000 and 2002 did you ever have

Page 238 1 Q (BY MS. MENNINGER) You were in Australia 2 at the time, correct? 3 A Yes. 4 Q They were not? 5 A Yes. 6 Q Have they ever been to see you in 7 Australia? 8 A My dad has. 9 Q Has your mom ever been to see you in 10 Australia? 11 A No, my mom is afraid of flying. 12 Q When did your dad come to see you in 13 Australia? 14 A The birth of my son, my first one in 2006. 15 And then, I believe in 2010 when my daughter was 16 born. 17 Q And did you have this conversation with 18 your dad about this in person or on the phone? 19 A I've had conversations with him about it 20 since. 21 Q I'm talking about the first time you had a 22 conversation with your dad. 23 A On the phone. 24 Q What caused you to tell him in 2010? 25 A I was just starting to accept what I had

1 any interactions with law enforcement? 2 A Yes. 3 Q When? 4 A When I tried to break away from Jeffrey 5 and Ghislaine, I started making myself unavailable. 6 And I got a job at Road House Grill. And Tony used 7 to come pick me up in the afternoons, at nighttime, 8 and he'd sit at the bar. And there's this big cup 9 that's got tips in it. 10 I was in the back room. And I had to -- 11 first you have to sign out and you have to take off 12 your aprons, put your aprons away. And there's a 13 whole bunch of cleaning up stuff you have to do. 14 In that time period, Tony grabbed money 15 from a cup that had money in it. That was for the 16 bartenders for their tips. My boss called me the 17 next day. He told me that I had stolen the money, 18 which I hadn't. And I came back and I returned the 19 money after I confronted Tony about it. Gave the 20 money back to him and he said, I'm sorry, but it's 21 just law that I have to call the police. So he 22 called the police. 23 And knowing that Jeffrey has got the Palm 24 Beach Police Department in his pocket, I went to 25 Jeffrey Epstein and I told him what had happened.

1 And Jeffrey said, Don't worry about It. Let me take 1 2 care of it for you. 2 3 Q Okay. I'm sorry. When did you have 3 4 interaction with law enforcement, then? 4 5 A What year? 6 Q Did you speak with a law enforcement 7 officer? 8 A I don't believe I spoke to them. Jeffrey 9 handled everything. 10 Q Okay. And you said that you had finished 11 your shift at -- this is at the Road House Grill, 12 correct? 13 A Correct. 14 Q You had finished your shift? 15 A Yeah, it was the end of the shift. 16 Q Okay. And you had cleaned up and were 17 checking out, correct? 18 A Yeah, it's a completely separate part of 19 the -- it's like back of the house. Do you know what 20 that means, like in waitering terms? 21 Q (Indicating.) 22 A Yeah, back of the house. 23 Q And what was -- who was this boss that you 24 spoke to? 25 A I can't remember his name.

never heard anything about it ever again. Q Did you ever check to see if you had a warrant out? A No. Jeffrey told me that he took care of 5 It. 6 Q Do you think it's a problem to leave the 7 country when you have an outstanding warrant? 8 MR. EDWARDS: Object to the form. 9 Foundation. Lack of predicate. 10 A I don't think I have an outstanding 11 warrant. Why would I -- do you have a document that 12 says I have an outstanding warrant? 13 Q (BY MS. MENNINGER) I'm just asking you if 14 you believe it's a bad thing to leave the country 15 when you have an outstanding warrant? 16 A Absolutely. 17 Q And you would never assist someone in 18 doing that, correct? 19 A Correct. 20 Q During the year 2015, have you spoken to 21 law enforcement about any topic other than Ghislaine 22 Maxwell? 23 A In 2015? 24 Q Um-hum. 25 A Did I talk to any law enforcement about

1 Q Okay. 2 A But, I mean, he was very nice. He didn't 3 want to but he just had to because it's just the law. 4 You know, the money was returned to him, but he still 5 had to do what he had to do. 6 Q You paid him back the money the next day? 7 A Very next day. 8 Q And did you ever speak with the Palm Beach 9 County Sheriff's Office about it? 10 A You know, I don't know if they called me 11 or not, but I know that since my boss told me he had 12 to call the police, I went to Jeffrey. And Jeffrey 13 said he'd handle it. 14 Q How old were you at the time? 15 A I don't know, 18, maybe 19. 16 Q You weren't a juvenile, were you? 17 A Well, juvenile being under 18, no. 18 Q Is that the only interaction with law 19 enforcement that you had between 2000 and 2002? 20 A Correct. 21 Q Were you, in fact, charged with theft 22 based on that case? 23 A No charges were ever brought to me. 24 Q Do you know if they were filed? 25 A No. Jeffrey told me he'd handle it, and I

1 Ghislaine Maxwell? 2 Q About anything other than Ghislaine 3 Maxwell? 4 MR. EDWARDS: And I would just object at S this point in time and instruct the witness not to 6 convey any answers as to who she has or who she has 7 not disclosed until such time as the Court rules on 8 the current outstanding motion. 9 I know that we have some obligations to 10 fulfill by the 4th. We intend to do that. And I 11 also recognize we may be back to answer some of these 12 questions. But for today, she's not going to answer 13 those questions. 14 MS. MENNINGER: Well, I'm Just going to 15 ask them and -- 16 MR. EDWARDS: I understand. 17 Q (BY MS. MENNINGER) Have you spoken to any 18 law enforcement in Colorado since the beginning of 19 January 20157 20 A I can't answer that question right now. 21 MR. EDWARDS: Hold on one second. I may 22 be able to get you an answer to that question. Can I 23 take -- can I Just take a quick break, and I think I 24 can answer that particular question for you? 25 MS. MENNINGER: I'm not asking you to

1 answer any questions -- 2 MR. EDWARDS: Fine. 3 MS. MENNINGER: -- Mr. Edwards. 4 MR. EDWARDS: Fine. 5 MS. MENNINGER: I appreciate It, but I'm 6 asking the witness to answer these questions. 7 MR. EDWARDS: I know, I'm Just trying to 8 help you today. 9 For today, don't answer the questions. 10 THE DEPONENT: I don't mind explaining. 11 MR. EDWARDS: I know, but you -- 12 THE DEPONENT: Okay. 13 MR. EDWARDS: I wanted to help. 14 THE DEPONENT: Okay. 15 Q (BY MS. MENNINGER) So have you spoken to 16 any law enforcement officers In Colorado since 17 January of 2015 until today? 18 A I am not answering that question. 19 Q Have your attorneys spoken to any law 20 enforcement officers in Colorado since the beginning 21 of 2015 until today? 22 A I'm not answering that question. 23 Q Have you been living with your husband in 24 Australia since October of 2015? 25 A Yes.

1 other terms of his probationary period? 2 A No. He went to everything that he was 3 supposed to go to. 4 Q Has he paid his fines? 5 A Yes, as far as I know. 6 Q Describe for me the contract that you had 7 with the Mail On Sunday? 8 A Could you be a little bit more specific? 9 Like -- 10 Q Have you had more than one contract with 11 the Mail On Sunday? 12 A Well, there was one contract for the 13 picture. And that was to pay me 140,000 for the 14 picture. And then two stories were printed after 15 that for the amount of 10,000 each. 16 Q Is that the only money that you received 17 from the Mail On Sunday? 18 A Correct. 19 Q Did you receive any money for syndication 20 of the photograph? 21 A Isn't that what the 140 was for? 22 Q I'm asking you. 23 A Well, I don't really know what syndication 24 means. 25 Q Did you have a written contract with the

I • 11 • • • 15 • • • • • • • • • 25 I 9 I I 9 I I

Mail on Sunday? 2 A Yes. 3 Q Where is that contract right now? 4 A I don't know. I've moved that many times. 5 I -- I lose paperwork wherever I go. 6 Q Is it possible it's in the boxes in 7 Sydney? 8 A I don't think I kept it, to be honest. 9 Q Did you ever refer back to it after you 10 signed it? 11 A I know I kept it for a short while, but I 12 mean, like I said, I've moved countries twice in the 13 last two years and three different houses. So the 14 paper trail is lost. I don't know where it would be. 15 Q Did you receive it via e-mail? 16 A No. I received it -- Sharon Churcher 17 handed it to me by paper. 18 Q And you signed it? 19 A I signed it. 20 Q And then did you make a copy of it? 21 A No. 22 Q You never had a copy of it? 23 A Well, I had my own copy. I'm sure she has 24 hers. 25 Q Do you recall there being a period of

2 A Yes. 2 if I want to do it yet. I mean, I think there's a 3 Q What was that period? 3 lot more that can go into it, you know.

4 A I believe it was like a three-month period 4 Q You were actively sending the manuscript 5 or something. 5 to people for purposes of having them reach a deal

6 Q Okay. And what other terms of the 6 with you and publish it, correct?

7 contract, do you recall? 7 A No deal was ever talked about. What we

8 A I couldn't talk to any other news 8 talked about was the possibility of publishing it, is

9 publication about the story. 9 it publishing-worthy, would I need to get a

10 Q Anything else? 10 ghostwriter. You know, this is the first time I've 11 A Not that I know of. 11 ever written a manuscript so I didn't know what I was

12 Q Were you happy when the period was up? 12 doing.

13 A Well, I mean, at that time I wanted to 13 Q Okay. You contacted Jarred Weisfeld,

14 write about my story. So I guess, yes, I was happy 14 correct? 15 when that period was up. 15 A Correct.

16 Q And you were actively writing a book at 16 Q I'm going to mark a document as

17 that time, correct? 17 Defendant's Exhibit 16. It is a composite exhibit.

18 A My manuscript. I've never published it. 18 (Exhibit 16 marked.)

19 Q You were writing the manuscript at the 19 MR. EDWARDS: Thank you.

20 time of your period of exclusivity with Sharon 20 Q (BY MS. MENNINGER) I'm not going to ask 21 Churcher, correct? 21 you to read every single page of this, but if you

22 A Those three months were just craziness. I 22 look at the first page. 23 think I started after that. 23 A Urn-hum.

24 Q You think you started writing the book 24 Q Can you tell what this is in terms of what

25 after the 90 days were up? 25 type of document?

1 A Yeah. 1 A It's an e-mail from me to Jarred.

2 Q And then you attempted to sell that 2 Q Okay. And there's also e-mails from 3 manuscript, correct? 3 Jarred to you on the same page, correct?

4 A I didn't attempt to sell it. I went to 4 A Yes. 7 word. People who publish books, not like a newspaper 7 case; is that true? 8 or anything. And I inquired about what they thought 8 A Yes.

5 other publications, like, what do you call them? 5 Q And can you tell -- I just presume that 6 People -- I'm trying to think of the name of the 6 you know that you have turned over documents in this

9 of my manuscript and if they thought it was, you 9 Q All right. And do you see at the bottom 10 know, a good story. And, yeah. 10 it's got your name and some page numbers in the

11 Q So you sent the manuscript to these people 11 bottom right-hand corner? 12 for the purposes of trying to publish the book, 12 A 003529? 13 correct? 13 9 Right.

14 A Some people, yes. 14 A Yes. 16 book publication, correct? 16 from you e-mails, for example?

15 Q And you were trying to get money from the 15 Q So you understood that your lawyers sought

17 A Well, I wasn't going to sell it to them 17 A Yes.

18 for free. 18 Q And searched your computer, correct?

19 Q But you were unsuccessful in finding 19 A Correct.

20 someone to publish it, correct? 20 Q And printed out e-mails, correct?

21 A Well, I was always on the fence with it. 21 A Yes. 23 I was more seeking judgment based upon these people 23 A Yes.

22 I wasn't too sure if I wanted to or didn't want to. 22 Q And these look like some of the e-mails?

24 who have done this plenty and plenty of times. 24 Q Okay. Do you have any reason to believe 25 Still to this day, I mean, I've had people 25 that e-mails produced by your lawyers with your name

1 on the e-mail address line are anything other than 2 your e-mail?

3 A No, they're my e-mails.

4 Q Okay. Did anyone else use your e-mail 5 account?

6 A No.

7 Q Okay.

8 A I mean, well, my husband uses It 9 sometimes. My kids use it for games.

10 Q Okay.

11 A But that's about it.

12 Q So if an e-mail is signed XOXO

13 A Yes.

14 Q is that you?

15 A Correct.

16 Q All right. And do you believe anyone else 17 in your family was communicating with

18

19 A No, no one else.

20 Q All right. What was the purpose of you 21 communicating with Jarred?

22 A We were trying to figure out if my book 23 was -- my manuscript was ever published or 24 publishable. And this was at a time where there was 25 a lot of controversy about what's going on around M.

2 3 MR. EDWARDS: I object just to the apparent mischaracterization.

4 MS. MENNINGER: Of 2012?

5 MR. EDWARDS: Being the first e-malls.

6 7 MS. MENNINGER: I only meant the first pages of this composite exhibit.

8 MR. EDWARDS: Okay.

9 10 MS. MENNINGER: But I appreciate your clarification.

11 MR. EDWARDS: Okay.

12 13 14 Q (BY MS. MENNINGER) The first e-mails of this composite exhibit are dated July of 2012, correct?

15 A Correct.

16 MR. EDWARDS: The first page. As opposed 17 to the first in the chronological timeline.

18 MS. MENNINGER: Yes.

19 MR. EDWARDS: Okay.

20 Q (BY MS. MENNINGER) If you flip sort of 21 anywhere towards the back, can you also see that 22 you -- there are e-mails between yourself and Jarred 23 in 2011?

24 A Excuse me. And which page?

25 Q Really, you can take your pick anywhere

1 And when I say JE, I mean Jeffrey Epstein.

2 It was a very scary thing for a lot of publishers to 3 even consider taking it on because Jeffrey is a very 4 powerful person.

5 Q Did you send your manuscript to Jarred?

6 A I believe I did.

7 Q All right. Did you ask Jarred to send it

8 on to other people like

9 MR. EDWARDS: Object to the form.

10 A I can't -• I can't recall. I believe I 11 met= through Jarred.

12 Q (BY MS. MENNINGER) Okay. I'm going to 13 ask you to turn -- well, on the first page, the 14 second e-mail says, is Epstein too big for

15 Does that refresh your recollection that 16 Jarred and= had something to do with one another?

17 A Yes.

18 Q Okay. And on the second page in the 19 middle of the page, just to be clear, is that an 20 indication that, definitely does not want the

21 book, X0X0= 22 Is that what you wrote?

1 from the back of that exhibit?

2 A Yeah, yeah, I see what you're talking 3 about.

4 Q Here. Why don't I direct you to the 5 bottom right Is 3563. Now, it's going to be 6 a little tricky to find, but it's about eight 7 pages -- I'm sorry, six pages from the back of the 8 composite exhibit.

9 A Yes.

10 Q Do you see on that page an e-mail from 11 yourself to Jarred from June 7th of 2011?

12 A Yes.

13 Q And in that e-mail you write: Dear Jarred 14 Weisfeld, We spoke on the phone going back a couple 15 months regarding the story I am writing called, The 16 Billionaires Playboy Club.

17 Right?

18 A Correct.

19 Q I am no longer under any contract and 20 would like to ask you to review my synopsis and if 21 you are interested I would love for you to represent 22 me as my literary agent.

1 covered the ongoing case of Jeffrey Epstein, the 2 world's richest pedophile. And my good friend and 3 journalist Sharon Churcher has a few from her 4 articles that she has written to send to you as well.

5 Correct?

6 A Correct.

7 Q I am very serious about getting my book 8 published and believe this story will cover many 9 genres of interest, not only by those following the 10 lengthy case, but it is also a woman's story of

11 glitz, glamour, sorrow, compassion, and true love. I 12 hope you enjoy.

13 Correct?

14 A Correct.

15 Q Signed, yourself?

16 A Yes.

17 Q So in about June you sent to Jarred 18 Welsfeld a synopsis and were asking him to represent 19 you as your literary agent to sell the book, correct?

20 A Yes.

21 Q And you characterized Sharon Churcher as 22 your good friend, correct?

23 A Well, at that time -- you have to 24 understand, Jarred and Sharon are very close. Sharon 25 Is the one who Introduced me to Jarred. And that's

1 one? All right.

2 MR. EDWARDS: What are we on now, 17?

3 MS. MENNINGER: 17.

4 (Exhibit 17 marked.)

5 6 7 8 9 Q (BY MS. MENNINGER) Very similarly, can you take a look at this exhibit? It is a composite of documents produced by your attorneys with various Bates ranges, Bates numbers in between Giuffre 2750 and 3928.

10 A 2750 and --

11 Q I think -- I think the last page is 3927,

12 13 but it does not contain all of -- I'm sorry, 3928. But it does not contain all of the pages in between,

14 just to let you know.

15 16 A Okay. Is there one specific that you want me to look at?

17 18 Q No, if you can Just take a look at the first page.

19 A Okay.

20 Q And tell me if you know who this person

21 is?

22 A Paulo Silva is somebody who works for the

23 24 Mall On Sunday. And he was the one in charge of paying me.

25 Q Paying you for what?

Page 259

Page 258

1 just being nice.

2 Q Do you disagree that Sharon Churcher was 3 your good friend at that time?

4 A Well, at that time I did trust her a lot 5 more than what I do now.

6 Q Why did you change your opinion of Sharon 7 Churcher?

8 A You know, I -- I just -- I think -- I

9 think talking to some journalists can be very 10 dangerous, especially sometimes how words can get 11 taken out of context. And I'm not saying that she's 12 a bad person. I'm just saying that just, I wouldn't 13 call her up and ask her what she's cooking for dinner 14 tonight or how the family is doing.

15 Q Did you ever introduce her to your hair 16 stylist?

17 A No.

18 Q All right.

19 A Oh, actually, yes, I did. She did get a 20 haircut where I was at.

21 Q All right.

22 MS. MENNINGER: So if I could have the 23 e-mails with Paulo Silva, please. I'm going to mark 24 these Defendant's Exhibit -- 18 -- 17.

Page 260

1 A The 140 plus the 10 and the 10.

2 Q Okay. And did he also pay you on an 3 ongoing basis for further sales of the photograph of 4 yourself and

5 A No, it was a set fee of 140 plus the 10 6 and 10. But they broke it up for some reason. So as

7 you can see here, Thanks for transferring the money. 8 I will let you know when it reaches my bank account

9 but just a little bit confused as I have a previous 10 e-mail with the amount owed at 4100. Is there still 11 an outstanding amount yet to be paid.

12 So they broke it up into quite a lot of

13 different fractions but it still equaled the 140 plus 14 the 10 and the 10.

15 Q Okay. If I could ask you to flip back to

16 2758. They're in sequential order, so it 17 should be about eight pages back.

18 A Yes.

19 Q All right. Do you see -- do you see that 20 that's an e-mail from Paulo Silva to your e-mall 21 account?

1 Introductory e-mail to you. Is that a fair 2 characterization of it? 3 A It would be hard to say. Like, I'd have 4 to look at the first one. That's June 24th. This Is 5 March 28th. I suppose so, if he's Introducing 6 himself as Paulo Silva. 7 Q All right. And In this e-mail he 8 Introduces himself by name and tells you that he 9 works for Solo Syndication and represents they are 10 the official syndication agency for Daily Mail and n Mail On Sunday and that he's been overseeing the 72 syndication of your Image, correct? 13 A Correct. 14 Q All right. And then he tells you that 15 with regard to your Image with he can 16 confirm that they've been able to sell it frequently 17 over the last couple of weeks. And he listed the 18 names of various news agencies to whom they had sold 19 the image, correct? 20 A Correct. 21 Q And then he tells you what the sales were 22 as of last Friday and then what your share of It is, 23 correct? 24 A Correct. 25 Q And your share of it was approximately

1 what the terms of your agreement were with this 2 syndication, Solo Syndication? 3 A Well, like you said, it looks like half 4 of -- 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A 2754? 23 Q Correct. 24 A Okay. 25 Q And it's a document with the heading Solo In regards to your image with= I can confirm we've been able to sell it quite frequently over the last few weeks. So far we've been able to sell it to the following clients. It lists names. So far the total sales, as of last Friday, Is the number listed there. Therefore, your share is 4,487. Q So let me be clear. I guess I'm asking, do -- do you recall what your deal was with Syndication? A No, I do not recall it. I Just remember Sharon writing up the contract saying 140 plus the 10 and the 10. I completely forgot about the syndication for $4,000 and 487 cents (sic). Q Okay. I'm going to ask you to turn back to 2754.

1 half of whatever the sales were, correct? 2 A Yes, it looks that way. 3 Q All right. And so then he gave you their 4 general payment terms, correct? 5 A (Deponent perused document.) 6 Yes. Yep. 7 Q And is that syndication deal separate and 8 apart from your deal with the Mail On Sunday to get 9 paid for the stories and a chunk -- 10 A Yes. 11 Q for the image? 12 A So I will have to correct my previous 13 statement. 14 Q Okay. 15 A So I forgot completely about the fact that 16 I received 4,487.50 for -- for the pictures that got 17 sold. 18 Q And is it possible it was sold some more 19 after this date, for which you received some money, 20 correct? 21 A I don't believe so. I -- I didn't even 22 remember this one, to be honest. So if there's any 23 others that you can show me, I'd be happy to look at 24 them. 25 Q Well, I'm just asking you if you remember

Syndication Limited. Is that the right page you're 2 on? 3 A Yes. 4 Q Dated May 23rd, 2011, correct? 5 A Yes. 6 Q All right. And there's some handwriting 7 in the middle of the page towards the bottom. 8 A Not my handwriting. 9 Q It's not your handwriting? 10 A No. 11 Q Do you know whose it is? 12 A No. 13 Q All right. 14 A I don't even know what it says. Does it 15 say Chai canceled and something mode? I have no idea 16 what it even says. 17 Q Okay. And it's not your handwriting? 18 A No. 19 Q It was produced by your attorneys, 20 correct? 21 A I'm sorry? 22 Q It was produced to us by your attorneys, 23 correct? 24 A Yes. They went through and gave you guys 25 everything you asked for.

1 Q All right. Since these e-mails come from 2 your e-mall address to and from Paulo Silva, do you 3 have any reason to doubt that they are your e-mails? 4 A 1 have no reason to doubt. 5 Q All right. Do you recall a Sandra White? 6 A Yes. She was a possible ghostwriter that 7 I was going to use. Sharon recommended that I got a 8 ghostwriter to be involved. And we nearly settled on 9 some kind of agreement, but I wasn't really happy 10 with the agreement In the end, so I decided not to 11 use her.

12 Q You weren't happy with the terms of her 13 price, if you will? 14 A Yes. 15 Q And so you didn't come to an agreement 16 with her, correct? 17 A We nearly did, but we in the end did not. 18 Q All right. If I can show you Defendant's 19 Exhibit -- whew -- 18. 20 MR. EDWARDS: You did kill a tree there. 21 Q (BY MS. MENNINGER) Take a look at that. 22 (Exhibit 18 marked.) 23 THE DEPONENT: So put this one away? 24 MR. EDWARDS: Put these in some sort of 25 order. They don't have to be perfect, but Just so

1 backwards. 2 Q Right. So if an e-mall is responding to 3 May 25th, is it more or less likely that it was 4 written on June 5th or May 6th? 5 MR. EDWARDS: Object to the form. 6 A I would say May 6th. 7 Q (BY MS. MENNINGER) So when responded to a 8 May 25th -- 9 A Oh, no, you're right. No, I'm sorry, I'm 10 going backwards because It's going up, isn't it? 11 Okay. Yes. 12 Q All right. 13 A I'm confused, too. 14 Q Anyway. In the last e-mall it says: I'm 15 very sad we won't be able to work together as I've 16 been very excited about the project. As you know, I 17 do not sell synopsis or individual chapters, and 18 especially not for those amounts. I'm merely 19 intrigued about where you were getting advice from. 20 Rest assured what we have worked on is confidential. 21 If you change your mind, let me know. 22 So that was around June 5th? 23 A 2011. 24 Q 2011, right? 25 A Yes.

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1 you know what you're looking at. 2 This is 187 3 Q (BY MS. MENNINGER) All right. Again, do 4 you recognize that the e-mail address -- 5 A Is mine. 6 Q -- is yours and it's from and to Sandra 7 White, correct? 8 A Correct. 9 Q And the date is in or around May 25th, 10 June 5th, something like that? 11 A It's Australian so it's backwards. So 12 it's the 6th of May, 2011. 13 Q Well, I would have thought that except the 14 bottom e-mail is May 24th, the middle one is May 25th 15 and then the most recent one says 6/5. So I don't -- 16 I don't know. I didn't write the document. 17 A Yeah. 18 Q But I'm asking if you believe it was in or 19 around the end of May? 20 A The only reason I can tell you that is 21 because if you look here, 24/5/11 is the way that we 22 actually do our dates in Australia, whereas in 23 America you would do 5/24/11. 24 So right here where it's written makes it 25 nice and dear but just to be clear, the dates are

Page 268

1 Q All right. So you had been trying to 2 reach an agreement with Sandra White prior to 3 June 5th? 4 A Correct. 5 Q And were unable to do so? 6 A Yes. 7 Q And not that you need to read every page, 8 but is it fair to say that you exchanged some 9 portions of your synopsis with Sandra during the 10 course of your interactions with her? 11 A Yes. And she rewrote some portion of it 12 as well, which I don't even know, it might be in 13 here. It might not be in here. I don't know what 14 I've kept or not kept. 15 Q Okay. And did you get advice from Sharon 16 Churcher with respect to the terms upon which you 17 should be looking for the ghostwriting agreement? 18 A Sharon is the one who introduced me to 19 Sandra. I can't remember who was giving me the 20 advice. It's going back so long ago, you know, I 21 don't want to pinpoint somebody and say it was 22 definitely them if it wasn't. 23 So, yeah, I'm just not going to comment on 24 that one without knowing. 25 Q Okay. You probably have e-mails, though,

18 Is?

19 A Oh, it's an email from me to Marianne

20 Strong.

21 Q All right. And at roughly what time

22 frame?

23 A February 20th, 2014.

24 Q All right. And what were you speaking

25 with Marianne or writing with Marianne Strong about?

So --

Q Okay. I'm going to show you Defendant's

Exhibit 19.

(Exhibit 19 marked.)

Q (BY MS. MENNINGER) Who is Marianne

Strong?

A She's my literary agent.

Q All right. And can you identify

Defendant's Exhibit 19?

A I'm sorry?

Q Can you identify what Defendant's

Exhibit 19 is?

A Defendant's Exhibit 19, like the number at

the bottom?

Q No, do you know what kind of document this

3 Q Urn-hum.

4 A Oh, sorry. (Pause.)

5 Yep, I've read it.

6 Q All right. Do you remember that e-mail 7 now?

8 A It's going back a long time ago, but it's

9 definitely my kind of writing.

10 Q Okay. So in the -- on the bottom of the

11 first page, 3417 --

12 A Urn-hum.

13 Q -- you represented to Marianne Strong that

14 you had served four years as Jeffrey Epstein's

15 personal and abused sex slave, correct?

16 A Correct.

17 Q That is not true, correct?

18 A Since we have now found out the actual

19 dates, it is not correct.

20 Q Okay. I want to turn the page, the second

21 page. On the first line, the first full sentence

22 that begins on the first line:

23 Even though there is over 40 women that

24 were once vulnerable girls that looked like the sweet

25 girl next door but now that they have been taken

1 A Can I just read it real quick and I'll

2 tell you?

3 Q Sure.

4 (Pause.)

5 A Sure.

6 Q Do you remember now the topic upon which 7 you and Marianne Strong were exchanging 8 communication?

9 A 1 don't recall talking about

10

11 I don't know who-s. But I

12 do understand what she's saying. If I win, then my 13 story would be a much better story to write.

14 Q And what case was she referring to, if you I know?

16 A I think this was regarding probably the 17 time when I was in -- trying to get involved with the 18 CVRA case.

19 Q In February of 2014?

20 A Correct.

21 Q Okay. And at the bottom of the page 22 there's an e-mail from you to her, correct?

I advantage of by this disgusting Wall Street tyrant,

2 most of them have led a very unhealthy lifestyle

3 since having served Jeffrey, such as drug addictions

4 and prostitution and do not hold accreditation to

S talk.

6 You wrote that, correct?

7 A Correct.

8 Q Who are the 40 women that you are talking

9 about here?

10 A When I spoke to the FBI, they told me that

11 there were -- and this is maybe just a guesstimate,

12 maybe there was more, maybe there was less that they

13 said. But they had told me that there was a lot of

14 other victims involved in this case. And this is

15 when I believed that after the FBI came to see me

16 that they were willing to reopen the case and do 17 something about it.

18 Q Okay. So the FBI is the one that told you

19 that there were 40 women?

20 A It could be less than 40. It could be

21 more than 40. I think I just summed it up to 40.

22 Q You came up with 40?

Q All right. But you based it on -- 2 A On my speaking -- 3 Q what? 4 A -- with the FBI. 5 Q Okay. And -- 6 MR. EDWARDS: Just let her finish her 7 question before you answer. 8 THE DEPONENT: Okay. 9 MR. EDWARDS: I just want the record 10 clear. 11 Q (BY MS. MENNINGER) Who at the FBI did you 12 speak with? 13 A I can't think of his name. I spoke to -- 14 oh, God, I can't even think of his name right now. I 15 spoke to a male and a female. And I also spoke to 16 about everything that was happening. 17 Q Is it 18 A yes. 19 Q Did tell you that the FBI 20 was reopening their case? 21 A He wanted to reopen the case. And the 22 last conversation that I had with him, I can't 23 remember when it was, he said that he was having 24 trouble doing it from the people above him. 25 Q Okay. When was that?

1 the assumption that the case was being reopened, that 2 they still were investigating. 3 Q Okay. Did you believe that the FBI had 4 reopened their case in 2011? 5 A I believe that's when they first started 6 to reinvestigate and reopen it. 7 Q And then sometime when you were in Florida 8 told you that they were not actually going to continue investigating the case? 10 A I believe I was in Florida, yes. And he 11 didn't say that -- he Just said his hands were tied 12 and up above, I don't know, chain of command, it 13 just -- it didn't look like It was going anywhere. 14 There was no definite no and a definite yes. It was 15 Just, right now there's really nothing that we can 16 do. 17 Q All right. In the third paragraph from 18 the top, you said there's another major paper that 19 has followed the story for a while that has worked 20 with me before and they were asking you for the 21 exclusive story but updated and obviously the end 22 outcome from the judicial decision. 23 Who was the other major paper that had 24 followed the story for a while and was asking you for 25 an exclusive story?

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1 A Like I said, I don't know. 2 Q Was it like a year ago or two years ago or 3 three years ago? 4 A I don't remember the last time I talked to 5 him. I think I was in Florida the last time I spoke 6 to him. 7 Q And was that on the phone or in person? 8 A On the phone. 9 Q Hmm? 10 A On the phone. 11 Q On the phone. Where was he located, if 12 you know, when you spoke to him? 13 A I don't know. 14 Q Do you have his phone number? 15 A I have his card somewhere. Probably not 16 on me anymore. Like I told you, my paper trail is 17 (indicating). 18 Q Okay. So in the fourth line you say: 19 Miraculously since I came to light with the truth in 20 speaking out against him in 2011, the FBI have 21 reopened the case. Which as you know, has current 22 proceedings in which I am involved in. 23 So what current proceeding were you 24 involved in on February 19th, 2014? 25 A Well, just speaking with the FBI, I was in

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1 A That would -- that, just coining to mind 2 must be the Daily Mail. If I said I've worked with 3 them before, the only other -- the only other, what 4 do you Call them, press, that I had worked with was S the Daily Mail, so -- 6 Q Okay. But you said you had held out on 7 them because Marianne had told you about her contact 8 will the New York City Post, right? 9 A I have held out because you told me about 10 your contact witIMith the New York Post, and I 11 appreciate you trying to make big headlines for the 12 story and hopefully one day the book. Yes. 13 Q Okay. And then the last line of that 14 paragraph you say: I would also like to know that 15 I'm going to profit from this as well, correct? 16 A Correct. I'm not going to give it for 17 free. 18 Q Right. All right. 19 (Exhibit 20 marked.) 20 MS. MENNINGER: Defendant's Exhibit 20. 21 Q (BY MS. MENNINGER) Do you recognize these 22 documents -- this document, which is another 23 composite exhibit? 24 A Yes. 25 Q Do you recognize it?

A Oh, like I said, I don't recognize it, but 2 it obviously comes from -- 3 Q Your e-mail address? 4 A Yes. 5 Q Now, what e-mail address is that, exactly, 6 on the first page of this exhibit? 7 A @icloud.com, that must be from a phone. 8 Q So that's different from the other e-mail 9 address? 10 A Yeah, I don't actually know about that 11 e-mail address. I obviously used it. U 13 Q And is the e-mail signed by your husband? 14 A No, it's signed by me. Q Okay. And in the subject line you wrote (Jane Doe 102), correct? A Subject line? Q The very top line of that page. A In yeah, I see. Q Okay. And it was to 15 16 17 18 19 20 21 jason.richards2@ic.fbi.gov, correct? 22 A Correct. 23 Q And is that 24 referring to? 25 A Yes. we were just

Q Right. 2 A But anything they had of me. 3 Q And Brad Edwards, who Is sitting right 4 here, was your attorney at the time and you 5 identified him as such in the e-mail, correct? 6 A Correct. 7 Q You did not identify Mr. -- Judge Cassell 8 as your attorney in this e-mail, correct? 9 A I knew him as a former judge, and I just 10 wrote down, Judge Paul Cassal (sic) as it looks. But 11 he was my attorney -- I don't know if he was my 12 attorney at that time. But yes -- he's always -- 13 he's been with me since the beginning, so -- 14 Q So he's representing you in this case now, 15 correct? 16 A Yes. 17 Q But at that time you don't know if he was 18 your attorney? 19 A I think he was. I mean, I've been talking 20 with him since the beginning. And this is dated 21 2014. So I believe at this time he was my attorney 22 at the time as well. 23 Q Okay. When do you recall first speaking 24 with him? 25 A Speaking with Paul, I'm not too sure. I

2 3 4 5 6 7 Q All right. And you had some e-mails with over time; is that fair? A Sure. Q These ones that came from your computer, right? A Sure, yes. Q Okay. You talk about having spoken with 8 Judge Paul Cassell in this first page, correct? 9 A I am here to get this BS non-prosecution 10 agreement thrown out and speaking with Judge Paul 11 Cassal (sic). He suggested trying to get ahold of 12 any photos or video recordings released by the FBI to 13 assist our case further in providing (sic) how much 14 pedophilia occurred by Jeffrey and the many other 15 monsters he obliged with underage girls. 16 Q Okay. 17 A If this is a possibility, please let me 18 know so I can give you Brad Edwards (my attorney) his 19 contact details. Many thanks for your time and I 20 hope we should meet again. 21 Q Okay. And so you were going back to Jason 22 and trying to get any evidence that the FBI had about 23 your case, right? 24 A Correct. Any photographs pertaining to 25 what -- myself, not of anyone else.

Page 278

Page 280

1 can't remember if I spoke to Paul in the phone in 2 Australia or if I met him in person in Florida. 3 Q Do you remember when you signed any kind 4 of fee agreement with him? 5 MR. EDWARDS: Object to the form. 6 A Um, the -- well, the first time I would 7 have signed an agreement would have been in Florida. 8 Q (BY MS. MENNINGER) When you were living 9 in Titusville? 10 A As far as my knowledge reminds me. I 11 mean, Fm looking at e-mails that I can't even 12 remember sending. It's a possibility I could have 13 signed earlier, but as far as I remember. 14 Q Okay. Do you recall ever having e-mail 15 communications with Sharon Churcher about her 16 publishing the first serial of your book? 17 A Serial, what does that mean? I'm sorry. 18 Q Like a sequel. 19 A A sequel to my book? 20 Q Urn-hum. 21 A My book has never been published. 22 Q Right. Do you remember ever e-mailing 23 with Sharon about her being the one who would publish 24 any subsequent follow-up book? 25 A If you have something in front of you to

1 2 3 4 5 6 see and show me I would look at It. Like I said, there's a million e-mails here. I mean, there's a whole dead tree with e-malls I don't remember sending. So -- Q So you don't remember that e-mail chain, as you sit here? 7 A Yes. 7 breadwinner and I'm a stay-at-home mom. 8 Q Okay. You have signed contingency fee 8 Q And what is his Job? 9 agreements with Boles, Schiller, correct? 9 A 10 A Yes. 11 Q You've signed contingency fees with 12 Mr. Cassell, correct? 12 Q And how long has he had that Job? 13 A Correct. 13 A He got that Job, I believe, in December or 14 Q Mr. Edwards and his firm? 14 January. December 2015 or January 2016. I know he 15 A Correct. 15 got the Job and then we had to go through all these 16 Q Stan Pottinger; is that correct? 16 preliminary tests and everything to make sure you 17 A Correct. 17 qualify. So -- 18 Q And pursuant to those fee agreements you 18 Q And what is the last paid employment that 19 understand that you would get a recovery of any money 19 you had? 20 that you won in this case, correct? 20 A The last paid employment that I had was -- 21 A Correct. 21 there was that -- do you remember going back through 22 Q And what percent is that? 22 the e-mails where I had that resume and I sent it and 23 A I don't know off the top of my head. I 23 they said, What time do you want to come for an 24 think It's 40 percent. I'm not too sure, to be 24 interview? 25 honest. 25 I ended up getting the job there for two

1 2 3 4 5 6 family? A We've been doing well. Q You've been doing well? A Yes. Q What Is your source of income right now? A My husband is the main income -- he's the

Page 283

Page 282 Page 284

1 Q Do you remember having any conversations 1 days because the place was disgusting and the boss 2 with about money that you hoped to 2 was just horrible. 3 obtain from this case or from any other source 3 I didn't get paid from them, but I got 4 related to this? 4 employed by them. And other than that, the last time 5 A I remember talking to as a 5 I worked was in -- ended in 2006 for ET Australia. 6 girlfriend telling her what cases I was involved 6 Q Did you quit that job after two days 7 with. I don't believe we ever spoke about any 7 because the place was disgusting? 8 monetary settlements. There was no number that was 8 A It was vile. Okay. They had the -- the 9 ever mentioned. I told her that I was involved in 9 whole place was closed down. The restaurant was 10 these cases. And, you know, it was just girlfriend 10 closed down for a period of, like, six months. And 11 talk between girlfriends. I never expected her to 11 he wanted me to go into this freezer area that had a 12 turn around and consort with the enemy. 12 dead rat in it and like this thick (indicating) layer 13 Q Well, it's fair to say you do hope to make 13 of mold at the bottom. And he wanted me to dean it. 14 money from bringing this lawsuit, correct? 14 Q All right. 15 MR. EDWARDS: Form. 15 A And I was just like, No. 16 A I hope to win, but that's not the only 16 Q Just checking, did you quit or did he fire 17 reason I want to win. I want to see justice come 17 you? 18 through. 18 A No, I definitely walked out of that one, 19 Q (BY MS. MENNINGER) Is money one of the 19 hands up. 20 reasons you want to win? 20 Q Okay. I'm going to do one more document I 21 MR. EDWARDS: Same objection. 21 have, quickly. 22 A More than the money, I want to see 22 (Exhibit 21 marked.) 23 Ghislaine and Jeffrey own up to what they have done 23 Q (BY MS. MENNINGER) I'll show you 24 and pay for the price, yes. 24 Defendant's Exhibit 21, another composite exhibit. 25 Q (BY MS. MENNINGER) Is money tight in your 25 Do you recognize the to and froms on this e-mail?

1 A To Sharon Churcher from myself, yes. 2 Q And this is the Sharon Churcher from Mail 3 On Sunday we were discussing earlier? 4 A That's correct. 5 Q And these are from February of 2011, 6 correct? 7 A Yes. 8 Q Okay. 9 A I mean, its Just assuming that were not 10 looking at Australian backwards dates. it Q Okay. Well, a few pages back, where It 12 says 2/19/2011. 13 A Oh, yeah, yeah. 14 Q All right. If I could direct your 15 attention to one of the pages, Its 3676 in the lower 16 right-hand corner. 17 A 3676. 18 Q Now, these are in sequential order. 19 They're not in Bates stamp order so you might have to 20 look at the dates on the top to find one that's 21 February 19th of 2011. 22 THE DEPONENT: Do you know which page it 23 Is? 24 MR. EDWARDS: Well -- 25 MS. MENNINGER: It's almost In the middle.

1 Supposedly JE purchased her at age 14 from her 2 family. 3 Q Okay. And then you asked her to call to 4 discuss that, correct? 5 A I tried to call. The line was busy. 6 Could you call concerning the question you asked? 7 Q Right. 8 A Yes. 9 Q All right. Defendant's Exhibit 22. 10 (Exhibit 22 marked.) 11 THE DEPONENT: Thank you. 12 Q (BY MS. MENNINGER) Okay. Do you 13 recognize these series of e-mails? 14 A So far. I mean, it's definitely from me 15 to her. Or actually, Michael Thomas Is the 16 photographer that worked with her, just to be clear. 17 Q And is she one of the two -- the 18 recipients of the first-page e-mail? You and she 19 received an e-mail from Michael Thomas; is that 20 right? 21 A Yes. 22 Q Okay. 23 MR. EDWARDS: I think she wants you to 24 look and make sure you recognize them. 25 Q (BY MS. MENNINGER) Yeah, do you recognize

Page 286

1 MR. EDWARDS: It's like what she's saying 2 is that -- 3 MS. MENNINGER: If you look at the date at 4 the top -- 5 MR. EDWARDS: If you look at the top it 6 says 2/19/2011. That's not it. It's like half a 7 page. Keep going. 8 A 2/13, 2/17, 2/18, 2/19 -- 2/19/2011. 9 Q (BY MS. MENNINGER) If it says 3676 in the 10 lower right-hand corner? 11 A Yes. 12 Q Okay. Is that an e-mail that you sent to 13 Sharon Churcher in response to an e-mail that Sharon 14 Churcher sent to you? 15 A To Sharon Churcher from Subject 16 R-E, received, yes. 17 I tried to call the line was busy. Could 18 you call concerning the question you asked? 19 Q All right. And that was in response to an 20 e-mail Just below it you received from Sharon 21 Churcher, correct? 22 A Yes. 23 Q And what did Sharon Churcher write to you 24 on February 19th of 2011? 25 A Do you know a-?

Page 288

1 the document, the e-mails? 2 A Like I said, these are back in 2011, but 3 it's from my e-mail address. I recognize that. I 4 recognize Sharon's name and I recognize Michael 5 Thomas. 6 Q Do you have any reason to doubt that the 7 e-mails from March of 2011 -- 8 A I don't have any -- 9 Q -- from yourself and Ms. Churcher are 10 accurately reflected from the documents taken from 11 your computer here? 12 A I have no reason to doubt that. 13 Q Okay. 14 (Exhibit 23 marked.) 15 Q (BY MS. MENNINGER) Defendant's 16 Exhibit 23. Again, e-mails between your e-mail 17 address and Sharon Churcher from May of 2011. 18 Do you recognize your e-mail address? 19 A Yes. 20 Q And Sharon Churcher's e-mail address? 21 A Yes. 22 Q And you're signing your e-mails to her, 23 Much love, X0X0= And she's signing her e-mails 24 to you, Love Shaza, correct? 25 A Correct.

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And Shaza is a name that you call her? A In Australia we kind of shorten the names of people and put z-a on the end, so yes. Q So she became Shaza? A She became Shaza, correct. Q And do you recall having e-mail communications with her in which you referred to her as Shaza and -- A Yes. Q -- she referred to herself as Shaza? A She's the same person were talking about, yes. Q All right. So it's coming from her e-mail address as Sharon Churcher, right? A Yes. Q All right. And I think the last -- MR. EDWARDS: Are you at a stopping point? MS. MENNINGER: Almost. MR. EDWARDS: Okay. Okay. I just have to a make a quick call, but I can wait a while so -- MS. MENNINGER: I understand. Almost done. MR. EDWARDS: Okay. (Exhibit 24 marked.) Q (BY MS. MENNINGER) This is Exhibit 24,

1 phrase sex trafficked as that is a heads up about the 2 book revealing more than be printed. 3 Q All right. So is Sharon Churcher writing 4 to you about -- actually, it's cc'd to Brad, correct? 5 A Yes. 6 Q And I only use Brad, not his last name 7 because it's bradOpathtojustice.com, correct? 8 A Yes. 9 Q All right. And that's Brad Edwards, who 10 is sitting here, right? 11 A Yes. 12 Q All right. And so in the e-mail from 13 Sharon Churcher to you regarding whether or not you 14 should let Vanity Fair buy your picture, she's also 15 recommending in the last line that you should have 16 Brad use the phrase sex trafficked, correct? 17 A If a statement is made, yes. I don't 18 think Vanity Fair ever did, anyway. 19 Q And the picture that they're talking about 20 there is the one with, correct? 21 A That's yeah, the big one. 22 Q The one that was previously sold? 23 A Yes. 24 Q And Paulo Silva was syndicating that one, 25 correct?

2 3 4 5 6 7 8 9 10 13 16 18 20 21 22 14 15 17 19 11 A May I have time to read it, please? 12 Q Please. A Are we talking about the very bottom one or the one in the kind of middle bottom? Q The very bottom one. A I would let VF buy your picture via Brad. The big gamble would be to let him also give them a statement. Q Right. A (Deponent perused document, sotto voce.) The reason this is a gamble is Jeffrey knows some of the most powerful people in publishing 23 and, once altered, will inevitably try to scare off 24 potential buyers. But the upside is it should help 25 you get a good agent. I would have Brad use the e-mails between yourself and Sharon Churcher from lune of 2011? A Um-hum. Yes, sorry. Q And, again, Shaza and l=,==, Shaza, right? A Yes. Q And at the bottom of this first page, is Sharon Churcher giving you advice regarding the purchase by Vanity Fair

1 A Yes. Yeah. 2 Q And on that second page there's a 3 redaction. Who is -- who is in that redaction? 4 A I have no idea. 5 Q You don't know? 6 A No, I don't know. 7 Q So who are the two world's most respected 8 politicians? and who? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 A I don't know. Q Do you recall ever telling Sharon Churcher that you were trafficked to two of the world's most respected politicians, and somebody else? MR. EDWARDS: Object to form. A Is that her wording? This is from her. So this is her wording. Q (BY MS. MENNINGER) Right. A If she considered them to be the world's most respected politicians, that would be her opinion, not mine. Q Okay. But you received this e-mail and responded to it, correct? A Is the top one above that what I responded 24 to? Sorry. It just confuses me because it goes 25 upwards, doesn't it, not downwards. We're not

1 2 3 4 5 6 reading chronologically down, are we? Q You can probably look at the dates and figure it out. I need you to do that, not me? A Okay the 30th of the fifth, 31st of the fifth, 6th of the first. Right. So I still don't know who she's talking about there. 7 Q You don't know If you received this 7 I Just had a great weekend in LA on a 8 e-mall? 8 celebrity story. Got to go to Rodeo Drive!!! 9 A No, I received this e-mall, obviously, but 9 Much love, Shaza. 10 I don't know who's redacted there. 10 Yes. I1 Q Okay. And in the e-mall that you 11 Q So she's encouraging you to have David 13 correct? 13 right? 14 A It does concern me what they could want to 14 MR. EDWARDS: Object to the form. 15 write about me considering tha walked 15 Mischaracterizes the exhibit. 16 into VF and threatened them not to write sex 16 A Is the question pending? 17 trafficking articles about his good friend JE. 17 Q (BY MS. MENNINGER) Yes. 18 Q Right. Does that refresh your memory that 18 A She -- yeah, she encouraged me to -- I 19 when you got this e-mall unredacted was 19 mean, once she saw that, you know, there was more 20 included as well as ? 20 litigation going on, she thought -- like she says, 21 MR. EDWARDS: Object to the form. 21 How fantastic. And up until recently she's still 22 Q (BY MS. MENNINGER) In the line referred 22 been trying to get me to get the book out. 25 making an assumption because I don't know who that 25 A In May of 2015, no. Jarred wanted to do

1 2 3 4 5 6 case. How fantastic, Have you asked him how he'd feel about reviving your book? It would be an incredible shame if the other project lilts your story, which it could at least somewhat. Jarred Is still very keen to represent you. I'm afraid I screwed you by steering you to Mimi. 12 responded to, you're talking about -- you used 12 Boles also help you In the book writing department, 23 to as two of the world's most respected politicians? 23 Q And in May of 2015, do you have -- did you 24 A It could be. But, again, I would be 24 have any active agreement to publish your book?

1 name is. 1 something again, but his only thing was, he wanted 2 Q I don't either. 2 Sharon to be in on it as like a ghostwriter. And I 3 A Okay. 3 said, Look, Sharon is all well and good, but I don't 4 Q Maybe our lawyers can tell us. 4 want a journalist, you know, as they can twist things 5 MS. MENNINGER: All right. Last one, and 5 around writing my story. 6 then you can get your break. 6 So he was like, Well, I'm sorry, I don't 7 (Exhibit 25 marked.) 7 want to work with you then. And I said, Well, that's 8 Q (BY MS. MENNINGER) Defendant's 8 fine. No problem. 9 Exhibit 25. Again, e-mails to and from yourself and 9 Q Do you, as you sit here today, have any 10 Sharon Churcher, correct? 10 agreement to publish your story in written form? 11 A Yes. 11 A No, we have no agreement. 12 Q And in this e-mail, it's dated 4/12/2015 12 Q Do you have an agreement for anyone else 13 on the first page of this composite e-mail? 13 to write your story? 14 A Yes. 14 A No. 15 Q She is encouraging you to do a book, 15 Q Have you got any ghostwriter in the book? 16 correct? 16 A Besides Sandra, who I didn't like, no. 17 A As she has from the beginning, yes. 17 MS. MENNINGER: All right. I think now is 18 Q Right. And she suggested a roman a clef. 18 a good time for a break. And then -- 19 Do you know what that means? 19 MR. EDWARDS: Okay. 20 A No. 20 THE VIDEOGRAPHER: We are off the record 21 Q On the third page back, she wrote you to 21 at 4:12. 22 compliment you about David Boles taking your case, 22 (Recess taken from 4:12 p.m. to 4:22 p.m.) 23 correct? 23 THE VIDEOGRAPHER: We are back on the 24 A (Deponent perused document sotto voce.) 24 record at 4:22. 25 Just reading about David Boles taking your 25 Q (BY MS. MENNINGER) When you were

3 photograph --

4 A Urn-hum.

5 Q -- do you recall whether you shared with

6 Sharon Churcher anything that you had discussed with 7 your attorney, Mr. Edwards?

8 A In relationship to what? Like, have I

9 identified people to her?

10 Q Right

11 A Yes.

12 Q Okay. So you -- you Identified people to

13 her and you then looped back to her about your

14 conversations with Mr. Edwards, correct?

15 MR. EDWARDS: Object to the form.

16 A I'm sorry, can you rephrase? I don't

17 understand.

18 Q (BY MS. MENNINGER) All right. So you

19 were e-mailing with her --

20 A Urn-hum.

21 Q -- getting her advice about whether or not

22 to sell your-to Vanity Fair?

23 A Right.

24 Q She asked you to run some information by

25 Brad --

3 Q Um-hum.

4 A I believe there was a time when she was --

5 oh, God, I can't remember. I really can't remember

6 and don't want to say anything without looking at

7 that exact e-mail. Do you have it to show me?

8 Q Well, I'm sure its probably in there but

9 I don't want to take the time to look for it now.

10 A Okay.

11 Q So I understand you're just repeating what

12 you recall from your memory.

13 A Yes.

14 Q And it may not be accurate because you're

15 not looking at the document. I've got that caveat.

16 What do you recall, just as you're sitting

17 there?

18 A I know there was e-mails that Sharon sent

19 to me suggesting to say to Brad Edwards, I know that.

20 I don't remember or recall exactly what was in those

21 statements.

22 Q Okay. And did you send those e-malls to

23 Mr. Edwards, as you recall today?

24 A I don't know. I'm sorry.

25 Q And do you know if you went back to Sharon

1 A Yes.

2 Q -- Edwards. And you said that you were

3 going to do that?

4 A Um-hum.

5 Q And then you spoke to Mr. Edwards,

6 correct?

7 A I don't know if I spoke to him or if I

8 e-mailed him.

9 Q Okay. And then did you report back to

10 Sharon Churcher what you had discussed with

11 Mr. Edwards?

12 A I'm not too sure. Like I said, going back

13 to the 2011 e-mails, look at this pile here. Its

14 Impossible for me to know.

15 Q So you were having a lot of communications 16 with Sharon Churcher in 2011?

17 A In 2011, yes.

18 Q All right. And Mr. Edwards was your

19 attorney in 2011, correct?

20 A Yes.

21 Q And did you ever have Sharon Churcher

Churcher and told her about the conversations or

2 e-mails you had with Mr. Edwards?

3 A Some of them, I'm sure, yes.

4 Q Because you were in fairly regular contact

5 with Sharon Churcher at that time, correct?

6 A Right, at that time.

7 Q All right. I want to introduce to you

8 Defendant's Exhibit 26.

9 (Exhibit 26 marked.)

10 Q (BY MS. MENNINGER) Have you seen this

11 document before?

12 A I don't know if I've seen this specific

13 document before, but I've seen something close to it,

14 I think.

15 Q All right. Do you see the date on the

16 document?

17 A March 10th, 2011.

18 Q March 9th?

19 A I see March 10th, sorry.

20 Q Hmm.

21 A London, March 10th, 2011.

Page 301 Page 303

MS. MENNINGER: That's okay. 2 THE DEPONENT: Yeah. Sorry about that. 3 MS. MENNINGER: Okay. 4 MR. EDWARDS: One is right on top of the 5 other.

6 Q (BY MS. MENNINGER) I don't doubt you. I 7 was just looking for it.

8 A Okay. 9 Q All right. So after the word London, 10 March 10th, 2011, correct?

11 A Correct. 12 Q And above that is a title, Statement on 13 behalf of Ghislaine Maxwell, right?

14 A Yes. 15 Q By Devonshires Solicitors, PRNE, correct? 16 A Correct. 17 Q And then Wednesday, March 9th, 2011, 18 correct?

19 A Correct. 20 Q And you understand that March 9th or 21 March 10th, 2011 is roughly the time your original 22 stories were published in the press --

23 A Correct. 24 Q internationally, correct? 25 A Correct.

A It doesn't surprise me, but I don't 2 remember reading this. I know that, you know, there 3 was a lot of stories in press going on and a lot of 4 them I decided I Just didn't want to read. There was 5 a lot of stuff in there that Just, I didn't want to 6 go through.

7 Q Okay. Were you harmed on March 10th or 8 March 11th, 2011 by the issuance of a statement on 9 behalf of Ghislalne Maxwell?

10 A I am harmed by Ghislaine Maxwell denying 11 anything that has ever happened between us, whether 12 It's in 2002 or 2011 or 2015. I think that she knows 13 what she did, and she should be held accountable for 14 them. And not only has she hurt me once, but she's 15 hurt me apparently twice and now three times.

16 Q So on March 11th, 2011, say, how were you 17 harmed by the issuance of this press statement?

18 A She's denied that she had any involvement 19 in the procuring of me and other young girls.

20 Q Um-hum. 21 A And she tries to make herself look like 22 she had no partake in it.

23 Q Did you suffer any physical symptoms on 24 March 11th, 2011 after this statement was issued, as 25 a consequence of this statement being Issued?

Page 302

1 Q And this statement issued by Ghislaine 2 Maxwell or issued by Devonshires Solicitors on her 3 behalf denied allegations about her that have 4 appeared recently in the media, correct? 5 A Correct. 6 Q It says, These allegations are all 7 entirely false, correct? Did I read that properly? 9 A Ghislaine Maxwell denies the various 10 allegations about her -- oh, yeah, right -- yeah, 11 right below that. These allegations are entirely 12 false.

13 Q All right. In 2011, were you aware that 14 Ghislaine Maxwell issued a statement denying the 15 allegations about her that had appeared in the media? 16 A I'm not too sure what I recall from 2011 17 about Ghislaine Maxwell denying it. I know that she 18 denied it recently in 2015. I know that for a fact. 19 Q So you don't know whether she denied it in 20 2011?

21 A I can't recall back to 2011, if I do 22 remember that. 23 Q And you don't know whether she put out a 24 press statement that said these allegations are all 25 entirely false, correct?

Page 304

1 A Not being able to remember reading this in 2 2011, it's hard to say. But it's the same thing that 3 I'm going through right now. I mean, she's denied it 4 again. And it is painful. It's physically painful. 5 I am taking medication to help me deal with this. 6 And --

7 Q Okay. I'm just limiting you right now to 8 March of 2011.

9 MR. EDWARDS: I would just ask that she's 10 able to finish her answer, though, please.

11 MS. MENNINGER: Well, the answer is 12 nonresponsive, so -- 13 MR. EDWARDS: In your opinion it's not 14 responsive.

15 Q (BY MS. MENNINGER) I want you to 16 understand that the question is related to any 17 physical symptoms you suffered in March of 2011 as a 18 consequence of Defendant's Exhibit 26 being issued.

19 A If I would have seen this in March 10th, 20 2011, this would have been harmful to me.

21 Q Okay. Do you recall, as you sit here 22 today, experiencing any physical symptoms as a 23 consequence of Defendant's Exhibit 26 being issued to 24 the press?

25 MR. EDWARDS: Objection. Asked and

Page 305 Page 307

1 answered. Lacks predicate. 2 A I have been suffering from Ghislaine 3 Maxwell and Jeffrey Epstein since the summer of 2000. 4 So hearing again in 2011 that she's denied it, of 5 course, It's going to hurt me. 6 Did I hear about this in 2011? I can't 7 tell you I honestly have. 8 In 2015 is when I know that she denied it. 9 And again, I haven't stopped suffering from the 10 repercussions that they put me through. 11 Q (BY MS. MENNINGER) And I'm asking you to 12 separate, if you can, any symptoms that you 13 experienced anew in March of 2015 -- I mean, excuse 14 me, March of 2011, as a consequence of this statement 15 being Issued, which I believe you said you don't 16 recall seeing at the time; is that fair? 17 A But you're asking me now about 2015? 18 Q Nope. March of 2011. Sorry, I misspoke 19 there. 20 A You're still on 2011? 21 Q Yes. Did you start taking any new 22 medications in March of 2011? 23 Let me ask you that. 24 A I've been taking medication to control my 25 since 2002.

1 can't believe you've been through this. I never 2 knew. I'm so sorry. You know, that kind of stuff. 3 So they never -- I never spoke to anybody about this 4 except for my husband. 5 Q All right. So the first time you recall 6 any sort of people in your community referencing 7 things to you is when the press picked up on it in 8 2014 or 2015? 9 A Yeah, I think it may be end of 2014, early 10 2015. 11 Q All right. And so in March of 2011 you 12 don't recall any neighbors or anybody saying anything 13 to you about this? 14 A No, I don't recall. 15 Q Did anyone tell you in March of 2011 about 16 Defendant's Exhibit 26, the statement on behalf of 17 Ghislalne Maxwell? 18 A No, otherwise I would have been able to 19 recall it. 20 Q Okay. Do you remember anyone in 2011 21 ridiculing you because of Defendant's Exhibit 26? 22 A Well, because nobody knew me as 23 everybody knows me as no one probably put two 24 and two together. And like I told you, I didn't tell 25 anybody. So there was nobody there to ridicule me in

Page 306

1 Q Okay. So did you take any new medications 2 or any additional amounts of medications in March of 3 2011? 4 A I have been taking the same medication 5 since 2002. 6 Q Okay. 7 A And that's due to - 8 caused from the pain that I suffered at the hands of 9 Ghislaine Maxwell and Jeffrey Epstein. 10 Q Did you -- do you recall any neighbors or 11 other moms at the school or anybody in 2011 12 referencing to you in any way the fact that Ghislaine 13 Maxwell had issued a denial of the allegations about 14 her that had been published in the media in March of 15 2011? 16 A No. I didn't speak to any -- I didn't 17 speak to any moms about what I had gone through. I 18 mean, when it came out in the press, I don't think 19 any -- like, Australians don't pay attention to news, 20 number one. 21 Number two, the first time that my friends 22 contacted me they were shocked. And this was, I 23 believe in -- when the press picked it up again, I 24 think, was 2014/2015. And I got a whole bunch of 25 like Facebook texts from them saying, Oh, my God, I

Page 308

1 2011 over this. 2 Q Where were you living in 2011 when 3 came to see you -- 4 A IS 5 Q Do you recall applying for any job in or 6 around 2011 and someone referencing Defendant's 7 Exhibit 26 and denying you a job? 8 A I don't -- I don't think I applied for a 9 job in 2011. 10 Q Okay. Did you go see a doctor and talk to 11 any doctor about Defendant's Exhibit 26? 12 A Not about this. Not about this paper 13 right here. But I have talked to doctors about my 14 abuse at the hands of Ghislaine and Jeffrey. 15 Q Have you talked to a doctor about any 16 statements in the press made by Ghislaine Maxwell? 17 A Recent statements, yes. 18 Q Which doctor did you speak to about that? 19 A Her name is Judith Lightfoot. 20 Q And where is she? 21 A She's in Australia. 22 Q Where in Australia? 23 A She's in Sydney, but we do phone 24 conversations. 25 Q Have you ever met her in person?

1 2 3 4 5 A Yes. Q When? A In 2011. Q All right. And is she affiliated with an office or a hospital or what? 6 A She's a psychiatrist. 6 claims. 8 since 2011? 8 before? 9 A No, because I've lived so far away and 9 A I've seen it recently, yes. 10 she's kind of the only person that -- like, I've seen 10 Q All right. What -- have you discussed 12 it's really hard for them to break down the walls and 12 she's a doctor or what. 13 be comfortable enough to talk to them about this 13 A Psychiatrist, yeah. 14 stuff. Judith is different. She's somebody that I 14 Q Is she an MD? 15 feel I can trust. She's 76 and she's just a very 15 A I don't know what her levels of credential 16 lovely lady. 16 are. I'm sure she is. 18 my pain and suffering. And I continue to see her 18 the statement? 19 over the phone because I can't see her in person. 19 A This full statement I have only seen 21 Defendant's Exhibit 26? 21 in the press was, claims are obvious 22 A I can't recall ever seeing this exhibit. 22 lies and so on, so forth. I don't remember seeing 23 So -- 23 this in the press. 24 Q Okay. 24 Q Okay. So the part that you remember 25 (Exhibit 27 marked.) 25 seeing in the press is claims are

1 2 3 4 5 the same. Maxwell strongly denies -- excuse me. Excuse me -- strongly denies allegations of an unsavory nature, which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory 7 Q All right. Have you seen her in person 7 Q All right. Have you seen this statement 11 a lot of doctors. And I can honestly tell you -- 11 this statement with Ms. Lightfoot? I don't know if 17 And she offers me other ways to deal with 17 Q Okay. When is the first time that you saw 20 Q Do you recall ever discussing with her 20 through discovery. The original statement that I saw

Page 310 Page 312 11 Q Sorry. I'm sorry if you misunderstood my 15 Ms. Maxwell. 15 statement that you recall seeing in the press besides

1 Q (BY MS. MENNINGER) I'm going to give you 1 obvious lies? 2 Defendant's Exhibit 27. 2 A Yes. 3 A Yes. 3 Q Anything else about this? 4 Q All right. Have you seen this document 4 A I can't remember what else she printed in 5 before? 5 the press. It's a very horrible thing for her to do, 6 A Yes. 6 turn around and call me a liar after everything that 7 Q And what do you understand it to be? 7 she knows she's done. And I didn't expect her to 8 A sounds like a PR, if 8 come out and be truthful. 9 Fm not right -- if I'm not wrong. Sent -- or 9 Jeffrey Epstein hasn't even issued a 10 subject is Ghislaine Maxwell. I don't know 10 statement. • 12 question. 13 It says: To whom it may concern, Please 13 A Yes. 14 find attached credible statement on behalf of 14 Q Was there anything else within this 16 And then it goes on, to hear about that 16 the line, claims are obvious lies? 17 she is saying: Each time the story is retold it 17 A Without saying 100 percent, I think that 18 changes with new salacious details about public 18 the original allegations are not new and have been 19 figures and world leaders and now it is alleged by 19 fully responded to be shown to be untrue. I don't 20 that is involved in 20 know if that's in the press or not, but I've read 21 having sexual relations with her, which he denies. 21 this before. 22 claims are obvious lies and 22 So I don't know if I'm confusing this with 23 should be treated as such and not publicized as news, 23 what I've read out of this or what I've read in the 24 as they are defamatory. Ghislaine Maxwell's original 24 press. The main thing is, I know she called me a 25 response to the lies and defamatory claims remains 25 liar, and that's what she publicized.

1 2 3 4 Q And when you say she called you a liar, that's the claims are obvious lies part? A Yes. Q Okay. When is the first time that you saw 5 this whole document? 5 A I mentioned a lot of names to him. 6 A I guess when you guys handed it over for 6 Q Okay. What new symptoms did you 7 discovery. 7 experience following January 2nd, 2015? 8 Q Okay. And who showed it to you? 8 A I think it's one thing to be a victim of 9 A It was sent to me by e-mail. 9 sexual abuse and survive it and come out trying to 10 Q Okay. Just through the course of 10 tell the world my story, and then another thing for 11 communicating with your attorneys? 11 It to be shut down because these people, Ms. Maxwell 12 A Yes. 12 and others are calling me liars (sic). 13 Q You've never seen it published? 13 Q And I asked you what symptoms had you 14 A Not this whole e-mail, no. 14 experienced -- 15 Q All right. Did you -- I'm sorry, did you 15 MR. EDWARDS: She's going to finish her 16 discuss this publication of what you saw in the press 16 answer to this question. You cut her off so many 17 with Judith Lightfoot? 17 times. 18 A Yes. 18 MS. MENNINGER: It has nothing to do with 19 Q All right. And when did you discuss it 19 this. 20 with her? 20 MR. EDWARDS: It absolutely does. Because 21 A When I got back to Australia, Judith and I 21 this is a psychological damages claim, and she is 22 started seeing each other again. Before then, I 22 trying to explain to you what those damages are. 23 spoke with a doctor in Colorado about this. His name 23 Q (BY MS. MENNINGER) Okay. What are your 24 is Dr. Olsen. And it was causing me a lot of 24 symptoms that you experienced since January 2nd, 2015 25 distress to have to deal with being called a liar all 25 that are new?

1 2 3 4 a liar from the people that abused me. Q Okay. Do you recall specifically mentioning to him Ghlslaine Maxwell's statement to the press?

Page 314 Page 316

1 over again, when I know I'm standing up doing the 1 A Very strong anxiety attacks, bad panic 2 right thing. And the doctor prescribed me 2 attacks. My throat closes up, I can't breathe. I 3 And, yeah. 3 vomit when I have anxiety attacks. My -- this is 4 Q Okay. So my question was, when did you 4 personal, but my sex life has suffered. My marriage 5 discuss it with Judith Lightfoot? 5 has suffered. Psychologically, it's just hurt me all 6 I think I now understand you did that 6 over again. I mean, they've hurt me before, and now 7 after you returned to Australia in November or so of 7 they've hurt me again by doing this. 8 2015; is that right? 8 And I felt like I was in the process of 9 A I returned to Australia in October, and 9 healing before this came out because I had opened up 10 that's when I picked up talking to her again. 10 this wonderful charity called Victims Refuse Silence. 11 Q All right. And you're saying that at 11 And then my aim was to heal by helping other girls 12 another point in time you talked to another doctor, 12 get out of the situations that I was in before. 13 Dr. Olsen, in Colorado, correct? 13 And my lawyers were nice enough to help 14 A Correct. 14 me. I have this beautiful website where you can 15 Q And when did you meet with Dr. Olsen? 15 click on in any state and you can find a place. I 16 A I don't know the first date that I met 16 have personally called all of them and they will help 17 with him. 17 you get out of the situation that you're in. They 18 Q Did you meet with him more than once? 18 will get you medical help. They will get you legal 19 A I believe so. 19 advice. I think I was in the really good process of 20 Q And you believe you spoke with him about 20 healing. And when this came out, it just ruined me 21 Ghislaine Maxwell's published statement in the press 21 all over again. 22 that claims are obvious lies. 22 Q (BY MS. MENNINGER) All right. Tell me 23 That's what you believe you spoke with 23 all of the damages that you claim occurred to you 24 Dr. Olsen about? 24 because of Defendant's Exhibit 27. 25 A I spoke with Dr. Olsen about being called 25 A My reputation, my psychological abuse,

1 physical ailments. My marriage has suffered, my
2 family life has suffered. I'm constantly battling
3 depression. I feel like I've taken 10 steps forward
4 and 12 steps back since this all happened.
5 Q Okay. And by since this all happened, do
6 you mean since January 2nd, 2015?
7 A That's correct.
8 Q All right. Have you lost any income since
9 January 2nd, 2015 as a consequence of Defendant's
10 Exhibit 27?
11 A Well, I believe that my charity that was
12 going to go forward and help other victims was going
13 to not only bring in income but also be able to
14 provide women with shelters and food and assistance
15 that I wanted to help them with.
16 I haven't been able to get a job or work
17 or anything like that. You know, financially, my
18 husband brings home the money for me. But as myself
19 goes, I couldn't work right now with everything going
20 on.
21 Q How much income were you making prior to
22 December 30th, 2014?
23 A Well, I've been a stay-at-home mom since
24 2006.
25 Q So how much income have you lost as a

1 A Well, number one, my charity. I mean,
2 that's -- that was my voice for other people to get
3 help. And I don't think that people want to get help
4 from somebody who's being called a liar in the press,
5 somebody who is claiming to be a victim that isn't.
6 I mean, I wouldn't want to get help from somebody who
7 did that, you know.
8 And I know when I introduce myself to
9 people these days, I don't introduce myself as
10 [REDACTED] anymore. I introduce myself as another name
11 because I'm afraid that if people read papers or if
12 people Google or find out who I am that they'll think
13 differently of me.
14 Q What do you introduce yourself as?
15 A I tell everybody my name is [REDACTED].
16 Q In what country or location has your
17 reputation been damaged as a consequence of
18 Defendant's Exhibit 27?
19 A Considering this is worldwide publication,
20 I would saying England, America, Australia. You
21 know, friends in Australia were seeing my face on
22 national TV. Like I said, I can't remember if it was
23 2014 or 2015. And I have since not been in contact
24 with those friends. I thanked them for their
25 sympathies, but it's not something I want people to

1 result of Defendant's Exhibit 27?
2 A I could only imagine, you know, being the
3 head of a corporation, a charity, I would be earning
4 a decent wage. It's hard to say how much I would be
5 earning because it is a non for-profit.
6 But because of these statements telling
7 everybody in the world that I'm a liar, my charity
8 has not been able to take off. And as a consequence
9 of that, I have missed out on the results of not
10 being able to go forward with it.
11 Q Okay. Have you applied for any job that
12 you've been denied since January 2nd, 2015?
13 A I haven't been denied a job. I haven't --
14 I've just -- I thought about applying for jobs, but I
15 mean, the second that you Google my name, people are
16 going to know exactly who I am. And these days,
17 employers Google everything, and it makes me fearful
18 that if I do go apply for a job, which I would like
19 to. I mean, my kids are all at school now. I'd like
20 to get back into the work force.
21 But I'm afraid if I do, my past is going
22 to stop me from being able to do that. No one wants
23 to hire a sex slave.
24 Q How has your reputation been harmed by
25 Defendant's Exhibit 27?

1 know about. You know, especially people close to me.
2 I mean, I want to go out there and I want
3 to help other victims. But being called a liar and
4 people having to sit there and second guess if I'm
5 telling the truth or not doesn't really give me much
6 incentive to want to make friends.
7 Q Did anyone in Penrose, Colorado approach
8 you and mention Ghislaine Maxwell's name?
9 A We have reporters at our door.
10 Q Did anyone in Penrose, Colorado approach
11 you and mention Ghislaine Maxwell's name?
12 A What, reporters? Yes, plenty of them.
13 Q Did anyone who lives in Penrose, Colorado
14 approach you and mention Ghislaine Maxwell's name?
15 A Have you ever been to Penrose? It's --
16 it's in the middle of nowhere. So you really -- I
17 didn't have friends in Penrose. There was nobody
18 that I knew there.
19 Q All right. And which reporters mentioned
20 you and Maxwell's name to you in Penrose, Colorado?
21 A We have reporters chasing us down the
22 street, in car parks, taking my kids to the doctor's,
23 going to the grocery store. You know, asking me all
24 kinds of questions about it. And I didn't talk to
25 any journalists or reporters about it.

1 Q And what do you recall any reporter saying 2 to you that included the name Ghislaine Maxwell? 3 A Asking me -- I don't remember what they 4 asked me, to be honest. There was regarding 5 Ghislaine and-and Jeffrey Epstein. I 6 mean, it was an array -- you know how reporters can 7 be when they're hashing at you. 8 Q Okay. So no one In Penrose, Colorado who 9 lived there mentioned Ghislaine Maxwell by name to 10 you? 11 A Besides reporters? 12 Q Right. People who live in Penrose, 13 Colorado. 14 A Right. I didn't know anyone in Penrose, 15 except for my mom. 16 Q Okay. Now, in March or April of 2015 did 17 you fly to New York? 18 A I'm sorry, what date? 19 Q March or April of 2015, did you fly to New 20 York? 21 A It's a possibility. 22 Q Did you stay at the Ritz-Carlton? 23 A It's definitely a possibility. 24 Q Were you there with Mr. Edwards and 25 Mr. Cassell and Sigrid McCawley?

I Trafficking Coalition sometime after January 2nd, 2 2015? 3 A I did give -- I did go for a speaking 4 engagement. I don't remember when. 5 Q Was there any speaking engagement you had 6 booked that was canceled after January 2nd, 2015? 7 A I can't remember off the top of my head. 8 Q All right. You founded Victims Refuse 9 Silence In February of 2014, correct? 10 A It was -- It was a process because, 11 obviously, you have to go through all the bylaws and 12 everything. I think we started it In October of 13 2014, but It wasn't official until January, I think. 14 Q Okay. So in the period it was in 15 operations before January 2nd, 2015, had you gotten 16 any -- had you been paid any salary by Victims Refuse 17 Silence? 18 A No, I hadn't. 19 Q Had -- 20 A I mean, it was just up and running. So 21 there was no -- 22 Q Had any contributions been made to Victims 23 Refuse Silence before January 2nd, 2015? 24 A I can't recall. You know, we've only had 25 a few contributions. I don't know what dates they

A I've been to New York quite a few times. 2 So I'd have to refresh my memory. But I have been to 3 New York with Brad Edwards and Paul Cassell and 4 Sigrid McCawley. 5 Q Was that after January 2nd, 2015? 6 A Definitely could be. 7 Q Did you give an interview to ABC News on 8 camera? 9 A I did 10 Q And that was after January 2nd, 2015? 11 A I did. 12 Q Did you give an interview to Good Morning 13 America? 14 A No. 15 Q All right. Did you correspond at all with 16 Good Morning America about the publication of your 17 story? 18 A I can't remember if ABC and Good Morning 19 America wanted to do something together. I can't -- 20 all I know is I was interviewed by one person at ABC. 21 I never was interviewed by anyone from Good Morning 22 America. Maybe they were going to show the same 23 airing in the same show, but powers that be, of 24 course, wouldn't let it go forward. 25 Q Did you give a lecture to the Human

1 were put in. 2 Q Has anyone else called you a liar in the 3 press? 4 A Yes. 5 Q Who? 6 A 7 Q Anyone else? 8 A Ghislaine Maxwell, obviously. 9 Q Anyone else? 10 A Not that I know of. 11 Q Has anyone else publicly denied your 12 allegations? 13 A From what Ghislaine Maxwell said? 14 Q Have you seen any press in which another 15 person has denied your allegations? 16 MR. EDWARDS: Objection. Vague. 17 A I've seen allegations denied by 18 Ms. Maxwell. And I've seen the allegations denied by 19 20 Q (BY MS. MENNINGER) And 21 actually went on TV and called you a serial liar, 22 correct? 23 A Very correct. 24 Q You saw that, correct? 25 A Yes.

1 Q And that hurt your feelings? 1 context? 2 A Badly. 2 MR. EDWARDS: Object to the form of the 3 Q 3 question. I 4 A Can I point to a person -- I'm sorry. I I I 5 don't understand. Can you rephrase it for me -- I I 6 Q (BY MS. MENNINGER) All right. I 7 A -- so I can understand what you mean? 8 MR. EDWARDS: Form. 8 Q Where you live in Australia now, has 10 Q (BY MS. MENNINGER) How do you know which 10 A After all of the news hits, after the 11 harm you've suffered is attributable to Ghislaine 11 press hits in 2015 and, you know, everyone is calling 12 Maxwell's denial versu 12 me a liar, all of my friends in Australia called me 14 A Ghislaine Maxwell brought me into the sex 14 can't believe what you went through. 15 trafficking industry. She's the one who abused me on 15 That was very embarrassing for something 16 a regular basis. She's the one that procured me, 16 that I tried to keep separate from my other life 17 told me what to do, trained me as a sex slave, abused 17 where I would like to help victims. I didn't want 18 me physically, abused me mentally. 18 the friends of my kids parents knowing about that 19 She's the one who I believe, in my heart 19 stuff. You know, and of course they all felt sorry 20 of hearts, deserves to come forward and have justice 20 for me. And you know, like I said. I didn't know 21 happen to her more than anybody. Being a woman, it's 21 anybody in Penrose. So there's nobody that could 22 disgusting. 22 have come up to me and talked to me about it. My 23 Q So you cannot delineate what harm you have 23 mom. 24 suffered In terms of all of the psychological damage 24 Q This question was about Australia, sorry. 25 you just disclosed? 25 A Oh, sorry, I thought you were talking

9 A 9 anyone referenced the name Ghislaine Maxwell to you? 13 and talked to me and said, I can't believe this. I

1 A Oh, of course. 1 about pointing out people. 2 Q -- if that is attributable to Ghislaine 2 Q No. 3 Maxwell's statement on January 2nd versus 3 A Okay, well in Australia, yes, at least a 4 calling you a serial liar on Good Morning 4 dozen friends. 6 A Of course, it all hurts. Okay? = 6 Maxwell's denial to the press to you? . . 9 doesn't feel good to have people who have done 9 being denied, and they felt sorry for me. And, you 10 something to you deny something that's happened, when 10 know, it was the whole circumference of things. 11 I'm actually brave enough to come forward and talk 11 Q So the people in Australia that came up to 13 What hurts me the worst is that Ghislaine 13 A Yes. 14 Maxwell brought me into this. Not only has she hurt 14 Q All right. And when you spoke to 15 me once, but she's hurt me twice coming forward and 15 Dr. Olsen you recall specifically mentioning 16 saying, This is not true, this is categorically 16 Ghislaine Maxwell's press release? 17 untrue and obvious lies. 17 MR. EDWARDS: Object to the form. 18 That to me is a stick in the mud and that 18 A Yes, I remember mentioning her, as well as 19 to me is what caused the most harm to me. 19 the press release, as well as other press releases. 20 Q Okay. And so can you point to any person 20 And the abuse that I had occurred (sic) from the 21 who has referenced Ghislaine Maxwell's denial in the 21 hands of Jeffrey and Ghislaine. 24 Q Can you point to any time that someone has 24 A I don't know. I mean, I've been told that 25 referenced Ghislaine Maxwell's denial to you in any 25 I've . You know --

5 America? 5 Q They came up and they mentioned Ghislaine 7 A They couldn't believe what I had been Of course those hurt. It 8 through and, you know, that these were, you know, 12 about it. 12 you had sympathy for you and believed you, correct? 22 press or to your face or anywhere? 22 Q (BY MS. MENNINGER) Okay. When have you 23 A Can I point to a person? 23 been diagnosed with a mental health condition, first?

1 Q When were you first told that? 1 just got to Australia and Judith Lightfoot was 2 A Well, early in -- early in 2003, I believe 2 helping me. 3 Is the first time that I was suffering from 4 And then my doctor, Judith I And I told him the reason. 5 Lightfoot, has in 2011 5 Q And this is since you returned to 6 6 Australia? 7 And, you know, I've recently seen another 7 A Correct. 8 doctor who said that I've got the exact same symptoms 8 Q And this is the first time you had seen 9 that Judith Lightfoot mentioned, which Is 9 that doctor? 10 10 A I've seen that doctor twice now. 12 Q Which doctor is that? 12 know you already said it, but I just -- 13 A You know, I don't honestly know his name. 13 A Dr. Donahue. 14 Q When did you see this new doctor? 14 Q Donahue, all right. 15 A Um -- 15 This doctor that you haven't yet 17 to a doctor that's been sent to you by one of your 17 country? 18 lawyers — 18 A United States. 19 THE DEPONENT: Yes. 19 Q And in what state? 20 MR. EDWARDS: -- at this time, I'm 20 A San Francisco. 21 Instructing you not to answer. 21 Q And when did you see that doctor? 22 THE DEPONENT: Okay. 22 A Um, Friday. Last Friday. 24 seen a doctor and you're not going to answer what 24 doctor? 25 doctor you've seen? 25 A Once. Well, twice actually. I saw him

. 11 Q I'm sorry, what was the name again? I 16 MR. EDWARDS: Sorry. If you're referring 16 disclosed, where did you see that person? In what 23 MS. MENNINGER: Wait. What is it? You've 23 Q And how many times have you seen that

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1 MR. EDWARDS: Sure. If it's a consulting I the next day, too. 2 witness in this case that has seen her at the 2 Q All right. Did you suffer from anxiety 3 direction of an attorney, that has not yet been 3 before meeting Jeffrey Epstein? 4 disclosed per any expert witness disclosure, then I'm 4 A I was never prescribed anything for 5 instructing her not to answer that question. 5 anxiety before I met Jeffrey Epstein. 6 If that's what you're referring to. I 6 Q That wasn't my question. 7 don't know if that's what you're referring to. 7 A Did I -- 9 to. 9 met Jeffrey Epstein? 10 Q (BY MS. MENNINGER) All right. So you 10 A I think a person who has gone through as 11 recall seeing Dr. Lightfoot. You recall seeing 11 much trauma as I have in my life would suffer from 12 Dr. Olsen. And you recall seeing a new unnamed 12 quite a few problems. But like I said, I was never 13 doctor recently. 13 prescribed anything until I met Jeffrey Epstein. 14 Anyone else you've seen since January 2nd, 14 Q Did you suffer from panic attacks before 15 2015? 15 meeting Jeffrey Epstein? 16 A Dr. Olsen, Dr. Lightfoot. Oh, 16 A Nowhere near as bad, no. 17 Dr. Donahue. 17 Q So you did suffer from 18 Q Where is Dr. Donahue located? 18 They just weren't as severe; is that what your 19 A He's in my suburb or he's a suburb next to 19 testimony Is? 20 me in Australia. 20 A No, what I'm trying to say is I did have 21 Q And is that a psychiatric-type doctor, a 21 I did have I had lived a very 22 medical-type doctor? 22 hard life prior to meeting Jeffrey Epstein as well. 23 A He's medical. 23 After meeting Jeffrey Epstein and 24 Q And what did you see him for or her for? 24 Ghislaine Maxwell, everything escalated. That's when 25 A I didn't have anybody to basically -- I 25 I started to take Xanax and smoke marijuana to help

8 THE DEPONENT: That's what I'm referring 8 Q Were you suffering from anxiety before you

1 calm the anxiety and everything down. 2 Q Before you met Jeffrey Epstein, had you 3 used any drugs? 4 A Sure, yes. 5 Q Which drugs had you used prior to meeting 6 Jeffrey Epstein? 7 A I smoked pot. I've taken Ecstasy. 8 Q Cocaine? 9 A Yeah, I would have snorted cocaine, 10 urn-hum. 11 Q Did you ever abuse alcohol before meeting 12 Jeffrey Epstein? 13 A No, I was -- I wasn't even of age to be 14 able to buy it. I mean, if there was alcohol at 15 parties I would have drank it, but I wouldn't say I 16 abused it. 17 Q Okay. Were there ever occasions upon 18 which you were observed to be drunk by other people, 19 prior to meeting Jeffrey Epstein? 20 A If you're drinking, the possibility of 21 getting drunk is always there. I don't -- I can't 22 recall exact situation where that was the case, 23 but -- 24 Q Were you diagnosed as a drug addict prior 25 to meeting Jeffrey Epstein?

1 Q How much does it cost you every time you 2 talk to Dr. Lightfoot? 3 A Her normal fee is $200. 4 Q And how much do you pay? 5 A She doesn't charge me anything anymore. 6 Q When did she stop charging you? 7 A Since I got back to Australia. 8 Q So before you left for Titusville, 9 Florida, you saw her and you were paying $200 per 10 session? 11 A Yes. 12 Q And what has Dr. Lightfoot recommended 13 that you do in order to get better? 14 A She loves what I'm doing with speaking 15 out. She thinks the more that I speak out about it, 16 the stronger I'll become. She recommends that I 17 write my book, I tell my story. She thinks not only 18 will it help me, but by helping me it'll help others 19 find a way to get Out Of the situation and to know 20 that there's other girls who have gone through what 21 I've gone through and what they're going through. 22 She recommends meditation, breathing 23 techniques, focus techniques. 24 Q Does she prescribe medications for you? 25 A No, she doesn't. She's a spiritual

1 A No, I was not diagnosed as a drug addict. 2 Q Were you sent to live at a rehabilitation 3 facility because of your use of drugs? 4 A No, that was more of a group home. Yes, 5 it was also a rehab facility, but it wasn't because I 6 was a drug addict. I wasn't coming off of anything. 7 Q Had you abused drugs prior to meeting 8 Jeffrey Epstein? 9 A I took drugs. I didn't abuse them, but I 10 took them. 11 Q Okay. 12 A Recreationally. 13 Q How often do you see Dr. Lightfoot? 14 A Once a week every Monday. I've skipped 15 this week because I've been over here and it's 16 expensive to call back home right now, unless you 17 FaceTime, but -- 18 Q Has Dr. Lightfoot recommended that you see 19 a treating doctor in person? 20 A No, she's -- she knows my history pretty 21 well. And she's a very wonderful woman and I 22 honestly wouldn't -- Dr. Donahue wants me to go see 23 another psychiatrist in person, but I prefer to stay 24 with Judith because she's someone I can personally 25 relate to.

1 2 3 4 5 1 6 9 10 11 12 13 • • • • • • • • • • • • doctor. Q Is there anything that she's recommended that you do that you're not doing? A Is there anything that I do that she recommends I don't? Sorry, say that one more time. Q That's okay. Is there anything that Dr. Lightfoot has recommended that you do that you are not actually doing? Are you following her advice? A Yes, I am. Q Okay. And what has Dr. Donahue recommended that you do? • 1 •

I

I 15 16

I All right. MS. MENNINGER: I'm going to ask that we 17 take just a brief break and that I can hopefully then 18 come back and just ask a few final follow-up 19 questions, okay? 20 THE DEPONENT: Okay. 21 THE VIDEOGRAPHER: We are off the record 22 at 5:16. 23 (Recess taken from 5:16 p.m. to 5:25 p.m.) 24 THE VIDEOGRAPHER: We're back on the 25 record at 5:25.

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1 2 3 4 5 6 7 Q When was It? A I don't know the exact date. Q What's your best recollection? A I don't know. I would have to have dates in front of me. If you've got something that has a date on there, I'm happy to look at It and tell you it's right or wrong. 8 Q It was a few months ago or many months 8 (Proceedings concluded at 5:28 p.m.) 9 ago? 9 10 A Um, to my best recollection, it was about 10 •• * * * * * 11 a year ago. 11 12 MS. MENNINGER: I have no further 12 13 questions for you at this time. As you know, there 13 14 are some questions that you refused to answer and 14 15 other questions that your attorney directed you not 15 16 to answer. So we will take those up with the Court 16 17 and may see you again. 17 18 THE DEPONENT: Okay. 18 19 MR. EDWARDS: And Just as a matter of 19 20 clarification, I don't believe that there's anything 20 21 she's refused to answer. There may be things that 21 22 I've instructed her not to answer because I believe 22 23 that they were privileged or for whatever reason I 23 24 Instructed her not to answer but she hasn't refused 24 25 to answer them. 25

1 2 3 4 5 6 7 read It. MS. MENNINGER: We're going off the record. MR. EDWARDS: Yeah, that's fine. She'll read. THE VIDEOGRAPHER: That concludes today's proceedings. We're off the record at 5:28.

1 Either way, the record is what it is. 1 I, do hereby certify that 2 MS. MENNINGER: I was going to say, do you 2 I have read the foregoing transcript and that the 3 dispute that the court reporter has been taking down 3 same and accompanying amendment sheets, if any, 4 what was said this entire time? 4 constitute a true and complete record of my 5 MR. EDWARDS: I'll read it. She'll read. 5 testimony. 6 MS. MENNINGER: Actually, that's a good 6 7 question. 7 e Q (BY MS. MENNINGER) Do you have any 8 9 questions that I've asked you today that you don't 9 bi irr otuArAh)ridf ifylggirsent 10 feel like you understood? 10 ( 11 A No, I don't think that there's questions 11 Acknowledged before me this 12 that you've asked me that I don't think I've 12 day of, 2016. 13 understood. But, you know, I really just want to 13 14 state something for my own piece of mind, if that's 14 Notary Public: 15 okay, if I'm allowed to do that. 15 Address: 16 Q No, that's not really what this forum is 16 17 about. 17 My commission expires 18 A Okay. 18 Seal: 19 Q There are other forums. 19 20 MR. EDWARDS: That will only be good for 20 21 them. There is no reason to say that. 21 KAM 22 THE DEPONENT: Okay. 22 23 MR. EDWARDS: You get a chance to talk 23 24 later. 24 25 Do you have an order form? And she'll 25

Amendments Attached

1 STATE OF COLORADO) 1 AGREN BLANDO COURT REPORTING & VIDEO, INC. 2 ) ss. REPORTER'S CERTIFICATE 2 Denver, Colorado 80202 3 COUNTY OF DENVER ) 3 Boulder, Colorado 80363 4 I, Kelly A. Mackereth, do hereby certify 4 5 that I am a Registered Professional Reporter and 5 6 Notary Public within the State of Colorado; that 6 7 previous to the commencement of the examination, the 7 v. Maxwell 8 deponent was duly sworn to testify to the truth. 8 9 I further certify that this deposition was 9 10 taken in shorthand by me at the time and place herein 10 11 set forth, that It was thereafter reduced to 11 12 typewritten form, and that the foregoing constitutes 12 13 a true and correct transcript. 13 14 I further certify that I am not related to, 14 amendment sheets, if any, to be filed at 15 employed by, nor of counsel for any of the parties or 15 16 attorneys herein, nor otherwise interested in the 16 to C.R.C.P. Rule 38(e). 17 result of the within action. 17 _XXX Unsigned; amendment sheets and/or signature 18 In witness whereof, I have affixed my 18 19 signature this 11th day of May, 2016. 19 20 My commission expires April 21, 2019. 20 21 21 Thank you. 22 22 AGREN BLANDO COURT REPORTING & VIDEO, INC. kelly A. Mackereth, LRR, RPR, CSR 23 216 - 16th Street, Suite 600 23 cc: All Counsel Denver, Colorado 80202 24 24 25 25

216 - 16th Street, Suite 600 4450 Arapahoe Avenue, Suite 100 . 15-cv-07433-RWS The original videotaped deposition was filed with Laura A. Menninger, Esq., on approximately the 11th day of May, 2016. Signature waived. Unsigned; signed signature page and trial. Reading and signing not requested pursuant pages 71 tii el benvelope n hwt entheBlando to sealed original.

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1 AGREN BLANDO COURT REPORTING & VIDEO, INC. 216 - 16th Street, Suite 600 - AMENDMENT SHEET - 2 Denver, Colorado 80202 4450 Arapahoe Avenue, Suite 100 3 Boulder, Colorado 80363 Videotaped Deposition of 4 May 11, 2016 5 gigS,SSICII-clawEllri Esq 6 401 East Las Olas Boulevard the testimony as originally given: Suite 1200 Page Une Should Read Reason 7 Fort Lauderdale, FL 33301-2211 8 Re:goitaped Deposition of v. Maxwell 9 o. 15-cv-07433-RWS 10 The aforementioned deposition is ready for reading and signing. Please attend to this matter by 11 following BOTH of the Items indicated below: 12 Call 303-296-0017 and arrange with us to read and sign the deposition in our office. 13 Have the deponent read your copy and sign 14 _XXX the signature page and amendment sheets, if applicable; the signature page Is attached. 15 Read the enclosed copy of the deposition and 16 sign the signature page and amendment sheets, if applicable; the signature page is 17 attached. 18 _XXX_ WITHIN 30 DAYS OF THE DATE OF THIS LETTER 19 20 By due to a trial date of be giirsehetfar :ifigainhayl signature page and amendment areSIGNED BEFORE A NOTARY Signature of Deponent: 21 PUBLIC and returned to Agren Blando for filing with the original deposition. A copy of these changes 22 should also be forwarded to counsel of record. Acknowledged before me this day of Thank you. 2016. 23 Notary's signature AGREN BLANDO COURT REPORTING & VIDEO, INC. (seal) 24 25 cc: All Counsel

3, 2016 . v1.5-Mcavx-VIII33-RWS LIP The deponent wishes to make the following changes in My commission expires

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