| | | Page 1 | | ------------------------------------------------------ | ----------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------- | | | UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE No.08-CIV-80119-MARRA/JOHNSON | | | | • | | | | Plaintiff,
-vs | | | | JEFFREY EPSTEIN, | | | | Defendant. | | | | Related cases:
08-80232, 08-08380, 08-80381, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092, | | | | VIDEOTAPED DEPOSITION OF | | | | Friday, November 6, 2009
9:16 a.m. - 12:43 p.m. | | | | | | | | | | | | Reported By:
Sandra W. Townsend, FPR
Notary Public, State of Florida
PROSE COURT REPORTING AGENCY
West Palm Beach Office | | | | | | | | PROSE COURT REPORTING AGENCY, INC. | | | | | | | Electronically signed 1,1
Electronically signed 1,1 | | 98e1e8e8-1011)-4717-b728-ef54d2/14.16d | EFTA_00006124 ![](_page_1_Figure_0.jpeg) EFTA_00006125 Page 2 NO EXHIBITS MARKED PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 3 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006126 | | Page | | --- | ------------------------------------------------------ | | 1 | PROCEEDINGS | | 2 | | | 3 | Deposition taken before Sandra W. Townsend, Court | | 4 | Reporter and Notary Public in and for the State of | | 5 | Florida at Large, in the above cause. | | 6 | - - - | | 7 | VIDEOGRAPHER:
This is the 6th day of | | 8 | November, 2009. The time is 9:16 a.m. | | 9 | This is the videotaped deposition of | | 10 | in the matter of | | 11 | versus Epstein. | | 12 | This deposition is being held at | | 13 | , West Palm Beach, Florida. | | 14 | My name is Sasha Quinby. I'm the videographer | | 15 | representing Visual Evidence, Inc. | | 16 | Will the attorneys please announce their | | 17 | appearances for the record. | | 18 | Mark Luttier, on behalf of
MR. LUTTIER: | | 19 | Jeffrey Epstein. | | 20 | MR.
on behalf of | | 21 | | | 22 | THEREUPON, | | 23 | | | 24 | having been first duly sworn or affirmed, was examined | | | and testified as follows: | EFTA_00006127 ![](_page_4_Figure_0.jpeg) EFTA_00006128 ![](_page_5_Figure_0.jpeg) EFIA_00006129 ![](_page_6_Figure_0.jpeg) EFTA_00006130 ![](_page_7_Figure_0.jpeg) EFIA_00006131 ![](_page_8_Figure_0.jpeg) EFIA_00006132 ![](_page_9_Figure_0.jpeg) EFIA_00006133 ![](_page_10_Figure_0.jpeg) EFIA_00006134 ![](_page_11_Figure_0.jpeg) EFIA_00006135 ![](_page_12_Figure_0.jpeg) EFIA_00006136 ![](_page_13_Figure_0.jpeg) EFIA_00006137 ![](_page_14_Figure_0.jpeg) EFIA_00006138 ![](_page_15_Figure_0.jpeg) EFIA_00006139 ![](_page_16_Figure_0.jpeg) EFIA_00006140 ![](_page_17_Figure_0.jpeg) EFIA_00006141 ![](_page_18_Figure_0.jpeg) EFIA_00006142 ![](_page_19_Figure_0.jpeg) EFIA_00006143 ![](_page_20_Figure_0.jpeg) EFIA_00006144 ![](_page_21_Figure_0.jpeg) EFIA_00006145 ![](_page_22_Figure_0.jpeg) EFIA_00006146 ![](_page_23_Figure_0.jpeg) EFIA_00006147 ![](_page_24_Figure_0.jpeg) EFIA_00006148 ![](_page_25_Figure_0.jpeg) EFIA_00006149 ![](_page_26_Figure_0.jpeg) EFIA_00006150 ![](_page_27_Figure_0.jpeg) EFIA_00006151 ![](_page_28_Figure_0.jpeg) EFIA_00006152 ![](_page_29_Figure_0.jpeg) EFIA_00006153 ![](_page_30_Figure_0.jpeg) EFIA_00006154 ![](_page_31_Figure_0.jpeg) EFIA_00006155 ![](_page_32_Figure_0.jpeg) EFIA_00006156 ![](_page_33_Figure_0.jpeg) EFIA_00006157 ![](_page_34_Figure_0.jpeg) EFIA_00006158 ![](_page_35_Figure_0.jpeg) EFIA_00006159 ![](_page_36_Figure_0.jpeg) EFIA_00006160 ![](_page_37_Picture_0.jpeg) EFTA_00006161 | | | | | | | | Page 39 | | | --- | --- | ------------- | ---------------- | --- | --------------------------------------------- | --- | ------- | --- | | 1 | | Q. | | | This is when you earlier said you moved to | | | | | 2 | | | West Palm Beach? | | | | | | | 3 | | A. | Yeah. | | | | | | | 4 | | | | | | | | | | 5 | | | | | | | | | | 6 | | | | | | | | | | 7 | | | | | | | | | | 8 | | | | | | | | | | 9 | | | | | | | | | | 10 | | | | | | | | | | 11 | | | | | | | | | | 12 | | | | | | | | | | 13 | | | | | | | | | | 14 | | | | | | | | | | 15 | | | | | | | | | | 16 | | | | | | | | | | 17 | | | | | | | | | | 18 | | Q. | | | So -- and you think that's when she was about | | | | | 19 | 14? | | | | | | | | | 20 | | A. | Yes, sir. | | | | | | | 21 | | Q. | | | And what kind of problems arose then? | | | | | 22 | | A. | | | Well, she met some other people in the | | | | | 23 | | neighborhood. | | | | | | | | 24 | | Q. | | | She met some other people what? | | | | | 25 | | A. | | | In that neighborhood. | | | | | | | | | | PROSE COURT REPORTING AGENCY, INC. | | | | | | | | | | | | | | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 39 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006162 | | Page 40 | | --- | ------------------------------------------------------ | | 1 | Q.
And who did she meet?
Do you know who it was? | | 2 | A.
and some of his friends.
Yeah. | | 3 | Q.
Do you know what year this was? | | 4 | A.
No. I couldn't tell you the year. | | 5 | Q.
Okay.
And do you know this | | 6 | A.
Yes, I do. | | 7 | Q.
When did you first make his acquaintance? | | 8 | A.
When we first moved to that place. | | 9 | Q.
And how did you make his acquaintance? | | 10 | A.
told me she was dating him.
I guess | | 11 | Q.
Well, you moved there.
Obviously there was | | 12 | day one when you moved there? | | 13 | A.
Oh, right. | | 14 | Q.
Was she already dating him? | | 15 | A.
Oh, no.
No.
No.
No. She didn't know | | 16 | anybody. | | 17 | Okay.
Q. | | 18 | A.
No, she didn't know anybody.
But then she had | | 19 | friends. So then
met
and she met some of | | 20 | she was palling out with
and some of his friends. | | 21 | | | 22 | | | 23 | | | 24 | | | 25 | | EFTA_00006163 ![](_page_40_Figure_0.jpeg) EFIA_00006164 ![](_page_41_Figure_0.jpeg) EFIA_00006165 ![](_page_42_Figure_0.jpeg) EFIA_00006166 ![](_page_43_Figure_0.jpeg) EFIA_00006167 ![](_page_44_Figure_0.jpeg) EFIA_00006168 ![](_page_45_Figure_0.jpeg) EFIA_00006169 | 1 | | | --- | ------------------------------------------------------ | | 2 | | | 3 | | | 4 | | | 5 | | | 6 | | | 7 | | | 8 | | | 9 | | | 10 | | | 11 | | | 12 | | | 13 | | | 14 | | | 15 | Q.
Did there come a time when she quit going to | | 16 | school entirely? | | 17 | A.
Yeah. | | 18 | Q.
When was that? | | 19 | A.
I remember trying to get her into | | 20 | and the school at-would
not accept her | | 21 | because they told me she was too -- too mature for her | | 22 | age. | | 23 | Q.
What do you mean by that? | | 24 | A.
Oh, that it would distract the boys. I | | 25 | clearly remember that. | | | | 3506-001 Page 47 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006170 | What did they -- did you ask them what they
1
Q.
2
meant by that?
3
A.
Yeah.
They said that she was -- I can't
4
pronounce the word, but she was very well built for her
5
age.
6
Q.
Was she older than the students that -- in
7
whose class she would be put?
8
You know what? I don't believe so.
A.
I think
9
they just said that she was too -- what's that word, you
know? -- like, too -- she was -- her body was too
10
11
mature.
Q.
Do you have any record where somebody at
12
13
public school system said that your child couldn't be
enrolled because her body was too mature?
14
A.
And that's when I tried to enroll
15
Yeah.
her -- that's when I just took her out.
16
Q.
What do you mean, you took her out?
17
A.
They told us to go -- because she had
18
Yeah.
19
to be.
Maybe that's when she went to
then, because
20
I remember going to try to help her get her GED from
21
another school on Military. I just don't recall the
22
order of protection, you know, the order of
23
So --
Q.
I want to go back.
She was at
But --
A.
24
25
-- did there come a time that she quit going
Q.
PROSE COURT REPORTING AGENCY, INC. | Page 48 | | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------- | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-4454d28436d 3506-001 Page 48 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_ONX6171 Page 1 to 2 A. Yes. 3 Q. And why was that? 4 A. She got annoyed. 5 Q. What do you mean, "she got annoyed?" 6 A. She got annoyed and she told me that she had 7 found a job. 8 Q. Well, I don't know -- I'm not understanding 9 what you mean when you said, "she got annoyed." 10 A. She got annoyed with the people that were 11 there. And at that time that's when came into 12 play. And then she told me -- she was working with me 13 for a little while in And then she 14 said she found a job in Palm Beach. 15 Q. Well, at this point she's -- what? -- 14 16 years old? 15? 17 A. Maybe 14, going on 15. 18 Q. So your daughter says she's annoyed with 19 school. What's your reaction to that? What was your 20 reaction? 21 A. I -- what was my reaction? I wasn't very 22 happy. But for some reason, I know she initially didn't 23 come out of school until she was 16, however it worked 24 out. But I know she was still, I believe, involved in 25 . And in the beginning she went to work with me a PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-ef54d28436cf 3506-001 Page 49 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006172 ![](_page_49_Figure_0.jpeg) EFIA_00006173 ![](_page_50_Figure_0.jpeg) EFIA_00006174 ![](_page_51_Figure_0.jpeg) EFIA_00006175 ![](_page_52_Figure_0.jpeg) EFIA_00006176 ![](_page_53_Figure_0.jpeg) EFIA_00006177 ![](_page_54_Figure_0.jpeg) EFIA_00006178 ![](_page_55_Figure_0.jpeg) EFIA_00006179 ![](_page_56_Figure_0.jpeg) EFIA_00006180 ![](_page_57_Figure_0.jpeg) EFIA_00006181 ![](_page_58_Figure_0.jpeg) EFIA_00006182 ![](_page_59_Figure_0.jpeg) EFIA_00006183 ![](_page_60_Figure_0.jpeg) EFIA_00006184 ![](_page_61_Figure_0.jpeg) EFIA_00006185 ![](_page_62_Figure_0.jpeg) EFIA_00006186 ![](_page_63_Figure_0.jpeg) EFIA_00006187 ![](_page_64_Figure_0.jpeg) EFIA_00006188 ![](_page_65_Figure_0.jpeg) EFIA_00006189 ![](_page_66_Figure_0.jpeg) EFIA_00006190 ![](_page_67_Figure_0.jpeg) EFIA_00006191 ![](_page_68_Figure_0.jpeg) EFIA_00006192 ![](_page_69_Figure_0.jpeg) EFIA_00006193 ![](_page_70_Figure_0.jpeg) EFIA_00006194 ![](_page_71_Figure_0.jpeg) EFIA_00006195 ![](_page_72_Figure_0.jpeg) EFIA_00006196 ![](_page_73_Figure_0.jpeg) EFIA_00006197 | | Page | | --- | ------------------------------------------------------ | | 1 | | | 2 | | | 3 | | | 4 | | | 5 | | | 6 | | | 7 | | | 8 | | | 9 | | | 10 | . You moved into
Q.
Back to
Okay. | | 11 | How long was it after you moved to this | | 12 | trailer on
before you met this fellow? | | 13 | A.
Before I met him personally? | | 14 | Q.
Yeah. | | 15 | Probably -- because I worked
I used to
A. | | 16 | clean houses a lot in
for the elders. | | 17 | don't know.
Maybe two, three months. | | 18 | And you came to know him because your -- did
Q. | | 19 | your daughter introduce you to him or -- | | 20 | A.
Yeah, he came over with some of his friends | | 21 | and, yeah, my daughter introduced me to him.
Seemed | | 22 | like a nice, respectable boy at the time. | | 23 | Q.
And how old was he in relation to your | | 24 | daughter? | | 25 | A.
Honestly, I don't know. I don't -- at that | Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47(7-0720-ef54d20436cf 3506-001 Page 75 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006198 | | Page | | --- | ---------------------------------------------------------- | | 1 | time I don't know. | | 2 | Q.
And, so, you thought he was a fine guy? | | 3 | A.
Yeah.
He dressed very nice.
His family lived | | 4 | diagonally across.
Nice aunt.
Nice
he came from a | | 5 | nice house. | | 6 | Q.
So you had no problem with your daughter | | 7 | hanging out with him? | | 8 | No, I didn't, you know.
A. | | 9 | Did there ever come a time that you learned
Q. | | 10 | ?
anything else about Mr. | | 11 | A.
Yeah. | | 12 | Q.
When was that? | | 13 | A.
Probably a little bit after that. | | 14 | Q.
Meaning, a little bit after the couple months | | 15 | after -- | | 16 | A.
Yeah.
After I met him. | | 17 | Q.
So give me an approximation.
When you say, "a | | 18 | little bit after," are we talking about a month later? | | 19 | A.
Maybe a month, two months. | | 20 | So this would be about three months --
Q. | | 21 | A.
Three months maybe. | | 22 | -- after you moved over to
Q. | | 23 | A.
Uh-huh. | | 24 | Q.
Okay.
Well, what did you learn? | | 25 | A.
Well,
was hanging out with these | 3506-001 Page 76 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_OYX6199 | | Page | | --------------------------------------------------------------- | ---- | | people and --
1 | | | 2
And who do you mean by, "these people?"
Q. | | | 3
A.
and his friends.
There was another girl | | | 4
and a boy. | | | 5
What are their names?
Q. | | | 6
I don't remember. I remember the girl working
A. | | | 7 | | | 8
I want to say I know it, but I know she | | | 9
School with
because
attended | wa | | School. I don't remember her name.
10
attending | | | Q.
What do you mean by '
School?"
11 | | | 12 | | | 13 | | | 14 | | | Well, what is it you learned about him at that
15
Q• | | | 16
time? | | | A.
, like, kind of beware, you
17
I just told | | | 18
know.
It seemed to me like he was a player-type guy. | | | 19
Q.
What do you mean by "player?" | | | 20
A.
You know, he dressed nice, appeared nice, | | | but -- how would I describe a player?
Like, he kind of
21 | | | 22
knows, like, he knew everything and he was, like, you | | | 23
know, he was the thing. | | | 24
Well, what gave you concern about that?
Q• | | | 25
A.
What gave me the concern about that? Because | | 3506-GUI Page 77 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006200 Page 78 1 a couple of times didn't get home on time and I, 2 you know, I questioned where she was, what she was 3 doing. 4 And then it wasn't long after that 5 told me that and this other girl that they were 6 hanging out with helped her get a job. And that was 7 down in -- down in Palm Beach over a bridge. 8 MR. LUTTIER: Okay. I'll take a break now. 9 Go to the restroom. 10 VIDEOGRAPHER: Going off the record at 10:33 11 a.m. 12 (Brief recess.) 13 VIDEOGRAPHER: We're back on the record at 14 10:40 a.m. 15 BY MR. LUTTIER: 16 Q. Okay. We were talking before the break about 17 this fellow . And you said there were a 18 couple times when your daughter didn't come home on time 19 and apparently was out with him? 20 A. Yes, sir. 21 Q. Did there ever come a time that you learned 22 his age? 23 A. No. I don't think I -- I didn't know it at 24 that time. 25 Q. Did you ever ask her if it was -- PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b4717-6728-ef54d28436d 3506.001 Page 78 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006201 | | Page | | --- | ---------------------------------------------------- | | 1 | A.
Yeah. | | 2 | Q.
-- somebody her age? | | 3 | But I think I was told he was, like, 7
A. | | 4 | maybe 16 or 17. | | 5 | Q.
And your daughter would have been 14? | | 6 | A.
Fifteen. She was, like, I believe she was, | | 7 | like, 14, going on 15. | | 8 | And did you come -- come a time that you
Q. | | 9 | learned that wasn't true? | | 10 | A.
Oh, many years later. | | 11 | Q.
But she told you he was approximately the same | | 12 | age she was? | | 13 | A.
Yeah. | | 14 | | | 15 | | | 16 | | | 17 | | | 18 | | | 19 | | | 20 | | | 21 | | | 22 | | | 23 | | | 24 | | | 25 | | 3506-001 Page 79 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006202 ![](_page_79_Figure_0.jpeg) EFTA_00006203 ![](_page_80_Figure_0.jpeg) EFTA_00006204 ![](_page_81_Figure_0.jpeg) EFTA_00006205 ![](_page_82_Figure_0.jpeg) EFTA_00006206 | Page | | ------------------------------------------------------------- | | 1 | | 2 | | 3 | | 4 | | 5 | | 6 | | 7
Q.
All right.
For example, she told you this | | 8
fellow,
, was an age that he wasn't? | | 9
A.
Correct. | | 10
Q.
And she obviously knew how old he was, right? | | MR.
Object to the form.
11
: | | 12
THE WITNESS:
I don't know that to be true. | | 13
BY MR. LUTTIER: | | Q.
And she knew that you would disapprove with
14 | | 15
her hanging around with him if he was much older than | | 16
her? | | A.
17
Oh, absolutely she'd know that. | | 18
Q.
Because you told her that, right? | | 19
A.
She knows that. | | 20
Q.
And when you said that he was a player, what | | 21
exactly did you tell her about somebody that was a | | 22
What did you caution her about, if anything?
player? | | 23
A.
A smooth talker. | | 24
Q.
I mean, right down graphically what did you | | 25
tell her about that, if anything else? | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-ef54d20436cf 3506-001 Page 84 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006207 | | | Page 85 | | --- | --------------------------------------------------------- | ------------------------------------ | | 1 | A.
I just told her to watch her step. | | | 2 | Q.
Meaning, what? | | | 3 | He's a nice dresser.
A.
He's a smooth talker. | | | 4 | He likes to talk to this woman, talk to that girl, talk | | | 5 | to this girl, that girl, whatever.
And I just consider | | | 6 | a person like that just to be a smooth talker. | | | 7 | Q.
Did you tell your daughter anything other than | | | 8 | he was a smooth talker? | | | 9 | A.
No. | | | 10 | | | | 11 | | | | 12 | | | | 13 | | | | 14 | | | | 15 | | | | 16 | | | | 17 | | | | 18 | | | | 19 | | | | 20 | | | | 21 | | | | 22 | | | | 23 | | | | 24 | | | | 25 | | | | | PROSE COURT REPORTING AGENCY, INC. | | | | Electronically signed by Sandra Townsend (401 | | | | Electronically signed by Sandra Townsend (401 | 08e1e8e8-101b-471743728-ef54d28436cf | | | | Page 85 of 187 | EFTA_00006208 ![](_page_85_Figure_0.jpeg) EFTA_00006209 | 1 | | | -------- | ------------------------------------------------------------------------------------- | | 2 | | | 3 | | | 4 | | | 5 | | | 6 | | | 7 | | | 8 | | | 9 | | | 10 | | | 11 | | | 12
13 | Q. | | 14 | Well, did there come a time that you were
suspicious that she was sexually active? | | 15 | A.
Was there a time? | | 16 | Yeah, there was. | | 17 | Q.
And when was that? | | 18 | A.
That was after my concrete evidence of | | 19 | , we moved to
being sexually active was after | | 20 | . And some people were calling me on my cell | | 21 | and she got gifts in the mail,
phone to talk to | | 22 | negligees and a massage book.
I clearly remember that. | | 23 | Q.
Did you ask her about those? | | 24 | A.
Yes, I did. | | 25 | Q.
What did she say? | | | | 3506-001 Page 87 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006210 | | Page 88 | | --- | --------------------------------------------------------- | | 1 | A.
She told me that the man she was -- the | | 2 | household, the man in the household that she was working | | 3 | for in Palm Beach, she was doing ironing and cleaning, | | 4 | is what I understood.
But this man offered to send her | | 5 | to school. | | 6 | Q.
And, so, is that all?
You accepted that as a | | 7 | response to your question? | | 8 | A.
Yeah.
I can say I did at that point. | | 9 | Q.
So getting gifts of lingerie fit into that | | 10 | description to you, that she was cleaning his house and | | 11 | he was going to send her to massage school and that's | | 12 | why she got gifts -- | | 13 | A.
It wasn't -- how can I explain? It wasn't | | 14 | lingerie that came -- it came from, like, I understood | | 15 | it was a wife that, you know, she goes to New York to | | 16 | these -- she was a model or something and she went to | | 17 | And it wasn't like a -- like a
these nice places. | | 18 | frilly negligee that I would consider something to be | | 19 | sexual. It was just, like, you know.
But, I mean, then | | 20 | I thought it was nice that the wife thought of her like | | 21 | that. | | 22 | Q.
Did your daughter tell you that she got these | | 23 | gifts from some person's wife? | | 24 | A.
Yeah, she did. | | 25 | Q.
And you saw these gifts, correct? | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-ef54d28436d 3506-001 Page 88 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006211 Page 89 1 A. Absolutely. 2 Q. Did you open the packages when they came? 3 A. No. 4 Q. How is it you saw them? 5 A. It just so happened that one day I had been 6 there. The package came. And then I saw the book and 7 she said that this was -- came from the family she was 8 working for in Palm Beach, because they were going to 9 send her to school because she had discussed that she 10 wanted to be a massage therapist, because supposedly 11 that's what the wife did or something. 12 And said, Mom, there's good money in 13 this and they're willing to help me with school. And, 14 Lord knows, I couldn't afford it because I was 15 supporting three kids on my own. 16 And I said, , well, that's nice. And 17 honestly I didn't think anything of it because I house 18 clean and I've had my clients pull together to buy me a 19 car, you know, for compensation of helping them out and 20 things like that. So -- or they had allowed me to take 21 a small loan from them and pay them back a little bit 22 every week. 23 So I just -- I didn't really think anything 24 further into the picture because I knew that had 25 this job in Palm Beach. She was making money. She was PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98elette8-101b-47t7-b728.efS4d28436cf 3506-001 Page 89 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006212 Page 90 1 coming home. She was coming home. She was fine. Her 2 attitude was fine. She was happy. And I didn't really 3 think much of it. 4 Q. Now, you began this area of discussion when I 5 asked you when was the first time you became suspicious 6 that your daughter had been sexually active. And this 7 is the event that you have described to us. 8 So what is it about this event that caused you 9 to wonder whether or not your daughter was sexually 10 active? 11 A. The way she started carrying herself. 12 Q. Was this before or after this event? You're 13 talking about an event where you -- she got gifts? 14 A. It was after this event. 15 Q. What do you mean by "carrying herself?" 16 A. I could kind of see her demeanor change where 17 she was now wearing low-cut blouses and tight pants. 18 And she was very -- very prevalent about she always had 19 to have make up on when she went to work and, you know, 20 that was, again, it just -- I don't know. Something 21 didn't seem right. 22 And then I questioned her. 23 And she said, no, Mom. I'm just cleaning 24 house, that where she cleans, I understood there was 25 several people that worked there, that there was, like, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b4717-6728-ef54d28436d 3506.001 Page 90 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA \_00006213 Page 91 1 a crew, they had a cleaning crew, a cooking crew, and... 2 Q. Okay. Well, did there ever come another point 3 in time that you -- strike that. 4 Is there anything else about this conversation 5 that you had with her when she got these gifts that made 6 you think that she was perhaps sexually active, other 7 than the fact the way she carried herself? 8 A. No. 9 Q. Did there was there ever another time that 10 you questioned whether or not she was sexually active? 11 A. Yes. 12 Q. When was that? 13 A. I -- I guess the people, something happened 14 with the transportation because they would come and get 15 or would take her to her job because they 16 were kind of dating at that point, so I didn't think 17 anything of it. would take her to her job or the 18 people would send a car for 19 And, like I said, I didn't think anything of 20 it because I've had clients come and pick me, you know, 21 people that I worked for come and pick me up. 22 And then one day -- I don't know -- something 23 happened, but it was -- had to get to her job 24 and had to get to her job and I drove her there. 25 Q. And when was this? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47174,7284d54d28436cf 3506001 Page 91 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006214 Page 1 A. The exact date, I don't remember. I -- T 2 don't remember the exact date. 3 Q. Do you know what year it was? 4 A. No. No. -- it all evolves in the 5 time between maybe 15. Maybe 15. 6 Q. Do you have any record of when this event 7 would have occurred -- 8 A. Do I have any record? 9 Q. -- when you drove her to this place? 10 A. No. I can't say I wrote it down. 11 Q. Well, did you create any record at any time 12 about it to pinpoint when it happened? 13 A. No. I remember it was a nice day. Time of 14 year, I can't remember. 15 Q. Did she ask you to take her there? 16 A. Yeah. She said if I take her there, her 17 employer would pay me for my travel, you know, to bring 18 her there, because I was very frugal about the way I 19 spent my money because I was supporting three children 20 by myself. 21 And I said, , I don't have, you know, _ 22 have to get through the week. And I remember not having 23 enough gas money to get there. 24 And I said, , I have gas, but what's in 25 my tank has to stay there. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47174,7284d54d28436d 3506-001 Page 92 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006215 Page 1 So I dropped -- I went down there with 2 . I didn't pull in a driveway. I remember it 3 being on the street. 4 And then went in a driveway. 5 And then she said, Mom, I'll be right out. 6 They're going to give you money for gas so you don't 7 have to worry. 8 And I said, okay. 9 So -- and then she was taking, like, a minute, 10 so I started to proceed to walk in the driveway. 11 And then walked out and introduced me 12 to her employer. And I shook her employer's hand and 13 that was Jeffrey. And I shook his hand. He seemed like 14 a very nice person. He said that my daughter, you know, 15 was doing a wonderful job. And, you know, he asked 16 several -- you know, it was a huge house. I never was 17 inside, but there was, like, quarters in the back of it. 18 And I'm telling you there had be 20 beautiful cars that 19 were parked. 20 And I just said, well, , this is a good 21 deal, you know, you make good money in Palm Beach. I 22 would have liked to have had a cleaning job in Palm 23 Beach. 24 And I had asked, you know, -- and I said, 25 , you know, if they need help, let me know. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47t7-b728.efS4d28436cf 3506001 Page 93 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006216 | | Page 94 | | --- | ------------------------------------------------------- | | 1 | And she said, no. | | 2 | And I left
there. | | 3 | And the man -- Jeffrey said, you know, | | 4 | Mr. Epstein said, don't worry, we'll get your daughter | | 5 | -- I think her name was
home.
You know, | | 6 | she talks with a, I guess, a British accent -- came out | | 7 | and assured me that she would get my daughter home. | | 8 | And I went about
So I said, okay. Thank you. | | 9 | my business. | | 10 | Did anybody give you money on that occasion?
Q. | | 11 | A.
Yeah.
Yeah. | | 12 | Q.
How much money did you get? | | 13 | A.
I think \$50, because I was totally amazed. | | 14 | But then I thought about it, well, these people are in | | 15 | Palm Beach, they have money. | | 16 | | | 17 | | | 18 | | | 19 | | | 20 | | | 21 | | | 22 | | | 23 | | | 24 | | | 25 | | 3506-001 Page 94 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006217 | | Page | | --- | ---------------------------------------------------------- | | 1 | | | 2 | | | 3 | | | 4 | | | 5 | | | 6 | | | 7 | | | 8 | Who gave you the \$50?
Q. | | 9 | A.
Mr. Epstein. | | 10 | Q.
Did you ever ask Mr. Epstein what your | | 11 | daughter was doing? | | 12 | A.
Yeah.
He told me she was ironing.
She was | | 13 | doing ironing work and the laundry.
She was in part of | | 14 | the laundry. | | 15 | Did you ever wonder about your -- how old did
Q. | | 16 | you say your daughter was at this time? | | 17 | She, I think, was about 16.
A. | | 18 | Q.
Did you ever wonder about your daughter | | 19 | working at age 16 doing this? | | 20 | A.
No.
No.
Because back in New York I worked | | 21 | I lied and worked at Burger King at 15, so I didn't | | 22 | think anything of it.
My daughter is 16 working.
And | | 23 | before that when I was in high school, I used to work | | 24 | and clean houses for the elderly people because I had | | 25 | such good grades. | | | | PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98elette8-101b4M-b728.efS4d28436cf 3506001 Page 95 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006218 | | Page 96 | | --- | -------------------------------------------------------- | | 1 | Did your -- did your daughter -- did you take
Q. | | 2 | your daughter to this location on any other occasion? | | 3 | And it was only she
A.
Maybe two other times. | | 4 | was running in to get her pay. | | 5 | Q.
And how much was her pay? | | 6 | A.
\$300. | | 7 | Q.
And that was supposed to be for how long? | | 8 | Honestly, I don't know. I don't know.
A. | | 9 | Q.
Did you know how much she was getting? | | 10 | A.
No. | | 11 | Q.
Did you ask her? | | 12 | A.
Yeah. | | 13 | Q.
And what did she tell you? | | 14 | A.
Well, a couple of times she told me she was | | 15 | getting a hundred dollars. And then she told me on | | 16 | several -- well, I guess, at one point Mr. Epstein, I | | 17 | guess, some of his help was going somewhere and asked | | 18 | if she could bring anybody to work.
And as a | | 19 | matter of fact, I was very big in church back then and : | | 20 | had asked one of the church sisters if she needed to | | 21 | make money to go, you know, that this Mr. Epstein was | | 22 | looking for other help.
Because I was too busy, you | | 23 | know, so I gave it to somebody else. | | 24 | Q.
So did the nun go? | | 25 | A.
She wasn't a nun. | | | | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-ef54d28436d 3506-001 Page 96 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006219 Page 1 Q. Or a sister, you referred to it? 2 A. I call her my sister. Yes, she did. 3 Q. And what was her name? 4 A. 5 Q. what? 6 A. Do you want the truth? I don't remember her 7 last name. 8 Q. So went over there -- 9 MR. : Yes, he wants the truth. 10 THE WITNESS: I don't remember her last name. 11 BY MR. LUTTIER: 12 Q. So went over there and did some -- what\_ 13 was it? -- ironing? 14 A. went over there with her -- with her 15 her niece. 16 Q. And did they ever contact you after that and 17 tell you what they did? 18 A. Well, said she left, but she left her 19 niece there, because I think drove her niece there 20 was the whole thing. But I wasn't close with her niece 21 to have, like, a -- I didn't have her phone number, she 22 didn't have mine and everything was through You 23 know, and I said to, you can go ahead and go 24 there. 25 And -- I got the directions because PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47(7-0720-ef54d20436cf 3506-001 Page 97 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006220 | | Page 98 | | --- | -------------------------------------------------------- | | 1 | I know he was looking for
that British lady called. | | 2 | couldn't go one day and that's why I
help and | | 3 | think I called Sister
in a hurry and said, do you | | 4 | want to make some money, that this guy had people coming | | 5 | in and they needed extra help. | | 6 | And then
called me and told me that she | | 7 | left there but she left her niece there. | | 8 | Q.
Now, when you say, Sister
that's not | | 9 | really your sister? | | 10 | A.
No.
No.
No.
No.
No. It's church term. | | 11 | What church is it that you --
Q. | | 12 | A. | | 13 | Q.
Okay.
And did
ever contact you after | | 14 | that and tell you anything about the work that her niece | | 15 | did? | | 16 | A.
She just said --
Did she? No.
just, | | 17 | said that her niece said it wasn't -- you know, it | | 18 | wasn't for her.
And
said she left her there and, | | 19 | you know, that was it, that it just wasn't for her. Sc | | 20 | that's what I understood. | | 21 | Q.
So did you ever ask your daughter how she | | 22 | why she was getting paid \$300? | | 23 | A.
Did I ever ask her?
No. | | 24 | Q.
How much were you making cleaning places at | | 25 | | 3506-001 Page 98 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006221 | | | Page 99 | | --- | --------- | -------------------------------------------------------- | | 1 | A. | How much was I making back then? | | 2 | Q. | Yeah. | | 3 | A. | Oh, I got 40 to \$50 a condo.
I could do | | 4 | | three, four condos in a day, five condos. I'd make \$300 | | 5 | in a day. | | | 6 | Q. | It's work all day though? | | 7 | A. | 250 -- yeah. | | 8 | Q. | And your daughter wasn't working all day at | | 9 | | this place, was she? | | 10 | A. | I have no idea because I was busy working. | | 11 | Q. | Well, you took her and dropped her off and -- | | 12 | A. | That's all I did. | | 13 | Q. | -- you don't know when she got home? | | 14 | A. | No, I don't. | | 15 | Q. | Did you ask her anything more about it? | | 16 | A. | No.
Honestly, I didn't. | | 17 | Q. | Did you have any other contact with | | 18 | | Mr. Epstein, other than the time that you were there and | | 19 | | you claim he said she was ironing? | | 20 | A. | Only on the phone. | | 21 | Q. | And what contact did you have with him on the | | 22 | phone? | | | 23 | A. | They would call and make an appointment. | | 24 | Q. | Who is the "they?" | | 25 | A. | Some -- it begins with an M -- Maxine or | | | | | | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98elette8-101b-47174,728-4454d28436d 3506-001 Page 99 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006222 | | Page 100 | | --- | -------------------------------------------------------- | | 1 | somebody. | | 2 | Q.
Is this with Mr. Epstein? | | 3 | Yes, Max -- Maxine. Could that be her
A. | | 4 | Q.
Well, Mr. Epstein is Jeffrey Epstein? | | 5 | A.
I know, but he had secretaries. | | 6 | Q.
My question is: Did you ever have any
No. | | 7 | other direct contact with Jeffrey Epstein? | | 8 | A.
Oh, Jeffrey Epstein called my phone and said | | 9 | he -- | | 10 | Q.
Did you talk to him? | | 11 | A.
Yes, I did. | | 12 | Q.
Okay.
When was that? | | 13 | A.
I don't know exactly when it was, but he just | | 14 | called to leave a message for
and tell her that | | 15 | he would appreciate it if she could come in at like 3:00 | | 16 | at one day.
And then another day that he was having | | 17 | company coming over and if she could make it, you know, | | 18 | at a different time. And it just like an appointment | | 19 | thing. | | 20 | Q.
Was this a direct phone conversation you had | | 21 | with him where you exchanged words or is this just some | | 22 | message left on a machine? | | 23 | A.
Oh, no.
No.
We exchanged words. | | 24 | Q.
And you said, sure, no problem? | | 25 | A.
Yeah.
Because
at that time didn't | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8eS-101b-47ff-b728-ef54d28436d 3506-001 Page 100 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006223 Page 101 1 have a cell phone or anything. 2 Q. And when did these conversations occur? 3 A. Exactly, I don't know when. It was just after 4 I knew that she had the job with him and stuff. 5 Q. Okay. So you were -- something about all this 6 made you suspicious that she was sexually active, is 7 8 where I think we started the question. A. It wasn't so much about that. But then I 9 started question her because she would leave, you know, 10 and occasionally I'd see her come home and I'd say, 11 , you have, like, a such a low-cut blouse on. 12 And you got such short, short shorts. Why -- I don't 13 understand. 14 Oh, Mom, I changed when I got in the house. 15 Q. Anything else that made you suspicious? 16 A. She did come home sometimes and I smelled 17 alcohol on her breath. 18 And I said, your employer lets you drink? 19 was concerned about that. 20 Q. And what did she say? 21 A. She said, yeah. She says, the people in the 22 kitchen are real nice and she was allowed to go -- I 23 guess there was a certain refrigerator or something that 24 sometimes she'd go sit in the kitchen. And the cooks 25 would cook for her, too. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Sile1eSe8-101b-47f7-b728-efS4d28436cf 3506001 Page 101 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006224 | | Page 102 | | --- | --------------------------------------------------------- | | 1 | Q.
So what did you do?
Did you pick up the phone | | 2 | and call this person and say, I don't want my -- what | | 3 | you said was a 15 year old daughter over there drinking? | | 4 | A.
I tried to get in touch with him.
I remember | | 5 | that. But I couldn't get through. | | 6 | Q.
Well, did you keep trying? | | 7 | A.
Did I keep trying?
Yeah. | | 8 | Q.
Did you ever get in touch with him? | | 9 | No. It was like the man vanished.
A. | | 10 | Q.
Did you get in the car and drive over there? | | 11 | A.
Nobody answered the door. | | 12 | Q.
Did you get in your car and drive over there? | | 13 | A.
Yes, I did and nobody answered the door. | | 14 | Q.
What did you do? Tell me about this occasion | | 15 | when you got in the car and drove over there.
Who went | | 16 | with you? | | 17 | A.
I went by myself.
Nobody. | | 18 | Q.
And when was this? | | 19 | A.
It had to be after
told me that her and | | 20 | her niece weren't interested in working for him. | | 21 | That's -- time of year, I don't really remember. But I | | 22 | I don't remember the time.
know it was daylight out. | | 23 | Q.
So what did you do?
You went to the house? | | 24 | A.
Yeah, I tried to knock on the door but there | | 25 | was so many doors I just didn't know where I was | | | | PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e0-101b-47ff-b728-ef54d28436d 3506-001 Page 102 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 71819110/ 15, and 17 EFTA_00006225 | | Page 103 | | --- | ---------------------------------------------------- | | 1 | knocking. | | 2 | Q.
What, did you knock on more than one door? | | 3 | A.
Yeah. | | 4 | Q.
Which door did you knock on? | | 5 | A.
There's a garage that had a big, long thing | | 6 | here. And then there's a front door.
And there's | | 7 | said something about this
another house because | | 8 | house in the back. | | 9 | Q.
So how many doors did you knock on? | | 10 | A.
Three. | | 11 | And -- and you're telling me --
Q. | | 12 | A.
Nobody answered. | | 13 | -- there was nobody there and nobody answered?
Q. | | 14 | A.
No. | | 15 | MR.
Object to the form.
: | | 16 | BY MR. LUTTIER: | | 17 | Q.
So did you come across anybody on the grounds? | | 18 | A.
No. | | 19 | Q.
So what did you do next? | | 20 | A.
I got in my car and left. | | 21 | Q.
And for what purpose had you gone there on | | 22 | that occasion? | | 23 | Just because I think I wanted to know why he
A. | | 24 | allowed her to drink. | | 25 | Q.
Well, in fact, you were suspicious about what | | | PROSE COURT REPORTING AGENCY, INC. | | | | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Seelelle8-101b-47ff-b728-efS4d28436cf 3506001 Page 103 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006226 Page 104 1 was going on by then, weren't you? 2 A. Yeah, after told me she didn't want to 3 work for her and didn't have the heart to tell me, 4 I guess maybe she knew more of the story than I did at 5 that point. 6 Q. Did you ask anything else, why isn't it. 7 for your niece? 8 A. Yeah, I did ask 9 Q. And what did she say? 10 A. And just said her niece just said it 11 wasn't for her. 12 Q. Did you inquire further? 13 A. No. 14 Q. Did you -- by now if you're suspicious, did 15 you ask your daughter more about what was going on? 16 A. Yeah. 17 Q. And you said your daughter was always truthful 18 with you, right? 19 A. Yeah. So she said -- 20 MR. : Object to the form. 21 THE WITNESS: Yeah. 22 So she just said, no, Mom, we're working. 23 And I said, well, why -- your hours are 24 changing now. Like, I don't understand. You know, 25 you don't do a full day or whatever. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1ette8-101b-47(7-0720-ef54d28436cf 3506-001 Page 104 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006227 | | Page 105 | | --- | ------------------------------------------------------ | | 1 | And she said, no.
She said, Mom, his company | | 2 | flies in all the time. | | 3 | And sometimes I know that he's in New York, | | 4 | so -- and she still -- she still goes over there, | | 5 | Because a couple times I knew he was in
you know. | | 6 | New York because he called from New York. | | 7 | called from New York and said she still had to go | | 8 | to the house. | | 9 | BY MR. LUTTIER: | | 10 | Q.
Who called from New York? | | 11 | A.
I'm sorry? | | 12 | ?
Who called from New York?
Q. | | 13 | A.
Yeah. | | 14 | Q.
And did she talk to you? | | 15 | A.
Yeah. | | 16 | ?
Q.
So you talked to | | 17 | A.
I talked to | | 18 | Q.
And when did this conversation happen? | | 19 | A.
It was late in the afternoon. She said that | | 20 | Jeffrey was coming in with some -- with some friends, | | 21 | needed to be over there, I guess, like, twc
but | | 22 | hours or three hours before Jeffrey came in with the | | 23 | people to make sure everything was, I guess, in place. | | 24 | ? Do you know whether or
Q.
And where was | | 25 | not
was, in fact, in Palm Beach calling you saying | 3506-001 Page 105 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006228 | | Page 106 | | --- | -------------------------------------------------------- | | 1 | that Mr. Epstein was coming in and wanted your daughter | | 2 | to come over? | | 3 | A.
Honestly, I don't know. | | 4 | Q.
Okay.
And by the way, when you're having | | 5 | these conversations with either the time that | | 6 | Mr. Epstein called or when you say you talked to | | 7 | did you ever ask them about -- more about what was going | | 8 | on? | | 9 | A.
No. They informed me that she was cleaning | | 10 | They were happy to have
and she was doing a good job. | | 11 | her. | | 12 | Q.
Well, you told me that Mr. Epstein said she | | 13 | was ironing; is that right? | | 14 | A.
She was ironing and she was in charge of, | | 15 | like, the ironing and the laundry. | | 16 | Q.
Did you ever have any other conversation with | | 17 | Mr. Epstein where you asked him what was going on? | | 18 | A.
No. | | 19 | Q.
Did you have a conversation with
whe' | | 20 | she called and asked her what was going on? | | 21 | A.
No. | | 22 | Q.
Did you ever directly confront your daughter | | 23 | about what was going on? | | 24 | A.
No. | | 25 | | Electronically signed by Sandra Townsend (401 98e1e8e0-101b-47ff-b728-e154d28436d Page 106 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006229 3506.001 ![](_page_106_Figure_0.jpeg) EFTA_00006230 | 2 | | | --- | ------------------------------------------------------ | | 3 | | | 4 | | | 5 | | | 6 | | | 7 | | | 8 | | | 9 | | | 10 | | | 11 | | | 12 | | | 13 | | | 14 | | | 15 | | | 16 | Q.
Now, by the time that she met
and you | | 17 | claim that she was going over to Mr. Epstein's house, | | 18 | had you discovered that your daughter was using drugs? | | 19 | A.
I suspected it because I'll tell you what. | | 20 | and this girl,
this girl, | | 21 | , because
and
used to
and | | 22 | drive over there a lot. | | 23 | Q.
Over where? | | 24 | A.
To Jeffrey Epstein's, because I know | | 25 | MI
worked for him and he was sending
Lc | | | PROSE COURT REPORTING AGENCY, INC. | EFTA_00006231 | | Page 109 | | --- | ---------------------------------------------------------- | | 1 | school, too. | | 2 | And then -- I don't know.
Then I found out -- | | 3 | I guess then I found out she went to
or something, | | 4 | And we -- I never talked to her -- you
somewhere weird. | | 5 | III
s
know, we never talked to her again.
But | | 6 | working for Jeffrey, too, cleaning.
That's how | | 7 | Ililland
actually got the job, was through | | 8 | So what -- the question was about being
Q. | | 9 | suspicious that she was using drugs. | | 10 | Because -- I'll tell you why.
A.
Because I | | 11 | -- when I'd see
noticed a couple times that | | 12 | III II and
in
, they had white powder on their | | 13 | nose. | | 14 | Q.
And you knew what that was, right? | | 15 | A.
I'm sure it wasn't baby powder. | | 16 | | | 17 | | | 18 | | | 19 | | | 20 | | | 21 | | | 22 | | | 23 | | | 24 | | | | | 3506-001 Page 109 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006232 ![](_page_109_Figure_0.jpeg) EFTA_00006233 ![](_page_110_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006234 | 1 | | | --- | ---------------------------------------------------------- | | 2 | | | 3 | | | 4 | | | 5 | Q.
When did you first suspect she was using | | 6 | Xanax? | | 7 | A.
I didn't know about Xanax. | | 8 | Q.
When did you first suspect she was using | | 9 | Xanax? | | 10 | I guess when her friends -- I guess when her
A. | | 11 | friends and Jeffrey Epstein turned her on and had her | | 12 | doctor shopping. | | 13 | Q.
Well, what do you mean by that? You said two | | 14 | things. | | 15 | A.
Oh, she came from Jeffrey Epstein's a few | | 16 | times a little looped. | | 17 | Q.
What was she looped on? | | 18 | A.
I couldn't tell you because I wasn't there. | | 19 | Q.
Well then, how do you know she came from | | 20 | Jeffrey Epstein's looped? | | 21 | A.
Because the last I knew she was working. | | 22 | Q.
No.
I want to know, you said she came
No. | | 23 | from Jeffrey Epstein's looped.
Did you see her when she | | 24 | came from Jeffrey Epstein's looped? | | 25 | A.
Well, when I got to the house and she was | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 90e1e8e0-101b-47ff-b728-ef54d28436d 3506-001 Page 112 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 71819110/ 15, and 17 EFTA_00006235 | | Page 113 | | --- | ------------------------------------------------------- | | 1 | looped and she told me she just got off of work, that's | | 2 | where I assumed she'd been. | | 3 | Q.
Oh, you assumed, -- | | 4 | A.
Yes. | | 5 | -- but you didn't know?
Q. | | 6 | So you didn't go pick her up from Jeffrey | | 7 | Epstein's? | | 8 | A.
No, sir. | | 9 | Q.
Well, let's assume that -- that she told you | | 10 | that she'd just gotten off work and you saw her and she | | 11 | was looped.
That would have then caused you even | | 12 | greater concern about what was going on at | | 13 | Mr. Epstein's, right? | | 14 | A.
Yeah. | | 15 | Q.
So did you pick up the phone or go over to | | 16 | Mr. Epstein's at that point to find out why your | | 17 | daughter was -- to use your words -- looped? | | 18 | A.
Honestly, no, I didn't. | | 19 | Q.
Okay.
Because you weren't that concerned | | 20 | about it? | | 21 | A.
No, sir.
That's not why. | | 22 | Q.
Okay.
Was she still hanging out with this | | 23 | , at the time?
fellow, | | 24 | A.
Yes, she was, and | | 25 | Q.
And what did you do, if anything, about | 3506-001 Page 113 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006236 | | Page 114 | | --- | ---------------------------------------------------------- | | 1 | interceding with her at her age, which was -- what? | | 2 | III I and
15, hanging out with this
and | | 3 | , who you now have said as to
III land | | 4 | , you observed them with white powder on their | | 5 | nose? | | 6 | A.
It's a very hard thing to
Sir, you know what? | | 7 | say because, you know what? I went to business.
So | | 8 | it's just like you if you have children.
When you leave | | 9 | your house, do you know what your kids do 24/7? No, I | | 10 | don't. | | 11 | When I leave to go to work, I don't know.
My | | 12 | daughter could say she's home and, sir, I don't know if | | 13 | she's there or if she stepped out. | | 14 | So you say the first time you were
Q.
Okay. | | 15 | aware or concerned about your daughter using Xanax was | | 16 | on some occasion when she was with her friends? | | 17 | I didn't say my daughter -- I didn't -- I
A. | | 18 | didn't say I was concerned about my daughter using Xanax | | 19 | at all.
You said it, not me. | | 20 | Q.
Well, the truth of the matter is, you did | | 21 | believe your daughter was using Xanax, didn't you? | | 22 | A.
No, I can't honestly say I did. I had | | 23 | suspicion. | | 24 | | | 25 | | | | | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47ff-0728-ef54d28436d 3506-001 Page 114 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006237 ![](_page_114_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8191101151 and 17 EFIA_00006238 ![](_page_115_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006239 | | Page 117 | | --- | --------------------------------------------------------- | | 1 | We have to change tapes. | | 2 | VIDEOGRAPHER:
Going off the record at 11:28 | | 3 | a.m.
This marks the end of tape one. | | 4 | (Brief recess.) | | 5 | VIDEOGRAPHER:
We're back on the record at | | 6 | This marks the beginning of tape two.
11:30 a.m. | | 7 | BY MR. LUTTIER: | | 8 | Q.
Now, you say that there were several | | 9 | occasions, I think you described two, where you say you, | | 10 | personally, talked to Jeffrey Epstein on the phone.
Do | | 11 | you recall that? | | 12 | A.
Yes, I talked to him personally on the phone. | | 13 | Q.
Do you know how many times? | | 14 | A.
No. | | 15 | Q.
And were these occasions when he was at his | | 16 | house in Palm Beach? | | 17 | A.
You know, I know a couple of occasions he was | | 18 | in New York getting ready to come back.
And just that | | 19 | when he was coming back to -- that he needs
told | | 20 | her to work at the house. | | 21 | Q.
When you say, he told
, I thought you | | 22 | were having this conversation with him? | | 23 | A.
No.
would be there and I'd
Sometimes | | 24 | give her the phone. | | 25 | Q.
I want to know | | | PROSE COURT REPORTING AGENCY, INC. | | | | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 SeeletieS-101b-47f7-b728-ef54d28436cf 3506-001 Page 117 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_OYX6240 Page 118 1 A. But I know he called. 2 Q. I want to know about now specifically the 3 conversations that you, personally, had with Mr. Epstein 4 on the other end of the phone. That's my question. How 5 many times did it occur that you, personally, had phone 6 conversations with Mr. Epstein? 7 A. I would say, maybe three, four, because he 8 called a couple times to tell me there was some kind of 9 music tickets coming -- he was Fed-Exing her music 10 tickets. 11 Q. On those occasions that you had direct phone 12 contact with Mr. Epstein, was he in his house in Palm 13 Beach? 14 A. I don't know, sir. 15 Q. Do you know where he was? 16 A. No, sir. 17 Q. Now, you said, and there were other phone 18 conversations where he called and all you did was give 19 the phone to 20 A. Yes. 21 Q. You didn't participate in those phone 22 conversations? 23 A. No. If was there, I handed her the 24 phone directly. But on occasion that they would tell me 25 just if I, you know, when I contacted her, let her know PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1eSe8-101b-47ff-b728-ef54d28436d 3506.001 Page 118 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000624I Page 119 1 if she could work this day or time or whatever. 2 Q. Do you -- did your daughter ever tell you what 3 the basis of her compensation was? 4 MR. : Object to the form. Asked and 5 answered. 6 BY MR. LUTTIER: 7 Q. Did she get paid hourly or by the day? 8 A. No. I never discussed that with her. 9 Q. All right. And did she ever tell you what the 10 total compensation she received was? 11 MR. : Object to the form. Asked and 12 answered. 13 THE WITNESS: No. 14 BY MR. LUTTIER: 15 Q. And by "total," I mean, you know, collectively 16 for a month or two months. 17 A. No. 18 Q. Now, this happened -- this was all occurring 19 during a period of time that you claim you thought she 20 was in school; is that right? 21 A. Yes. 22 Q. Didn't you know that she had already dropped 23 out of school by then? 24 A. No. 25 Q. And you -- were you home on all occasions when PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47f7-b728-ef54d28436cf 3506-001 Page 119 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006242 | | Page 120 | | --- | -------------------------------------------------------- | | 1 | your daughter went to Mr. Epstein's? | | 2 | A.
Absolutely not. | | 3 | So you didn't really know where she was?
Q. | | 4 | A.
Absolutely not. | | 5 | So in the day, all you knew is, you left and
Q. | | 6 | you had no idea if she was in school or at Mr. Epstein's | | 7 | or at the beach or anyplace else? | | 8 | A.
Correct. | | 9 | Q.
And when you came home, all you knew is she | | 10 | was either home or she wasn't home, right? | | 11 | A.
That's correct. | | 12 | Q.
Did you ever tell her that you didn't want her | | 13 | hanging out with this guy, | | 14 | A.
Yeah. | | 15 | Q.
And what did you tell her specifically? | | 16 | A.
I told her I just didn't want her to hang out | | 17 | with him, that his aunt didn't want them to hang out | | 18 | and | | 19 | Q.
Whose aunt? | | 20 | A.
aunt. | | 21 | Q.
aunt? | | 22 | A.
Yeah. | | 23 | Q.
And how did you know
aunt didn't want | | 24 | them to hang out? | | 25 | A.
Because we've had conversations. | 3506-001 Page 120 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006243 ![](_page_120_Figure_0.jpeg) EFTA_00006244 | | Page 122 | | -------- | --------------------------------------------------- | | 1 | | | 2 | | | 3 | | | 4 | | | 5 | | | 6 | | | 7 | | | 8 | | | 9 | | | 10 | | | 11
12 | Q.
But on the other hand, you told me that | | 13 | was taking her to Mr. Epstein's? | | 14 | A.
But I wasn't aware of that. I was
Correct. | | 15 | at work. | | 16 | So I thought you -- so the only way you know
Q. | | 17 | was taking her to Epstein's is something
that | | 18 | somebody told you at some point later in time? | | 19 | A.
No, because in the very beginning when | | 20 | met Mr. Epstein through
and this girl, | | 21 | because Mr. Epstein needed additional help at his | | 22 | estate. | | 23 | Q.
Well, somebody told you that, right? Somebody | | 24 | told you that Mr. Epstein needed additional help? | | 25 | A.
Yeah, my daughter did. She says -- she was | Page 122 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d20436cf EFTA_00006245 3506-001 | | Page 123 | | --- | -------------------------------------------------------- | | 1 | very excited that
I and
brought her to
M | | 2 | this estate and she was going to have a job. | | 3 | Q.
So this is the story that your daughter told | | 4 | you? | | 5 | A.
Absolutely. | | 6 | Q.
So you had -- you and
aunt wanted | | 7 | and your daughter not to see each other? | | 8 | A.
Right. But I didn't know. | | 9 | Q.
So you told her not to hang around with | | 10 | A.
Right.
Because he was much older than she | | 11 | was. | | 12 | Q.
So you never physically were present to see | | 13 | pick her up and take her anywhere? | | 14 | A.
I really can't say that because I know | | 15 | sometimes he borrowed my car to take her. | | 16 | Q.
Let's see now.
You just told me that you | | 17 | and your daughter to hang out. You
didn't want | | 18 | told your daughter not to hang out with him? | | 19 | A.
But that was prior -- that was prior
Yeah. | | 20 | to -- that was prior to us declaring that we didn't want | | 21 | them to hang out. | | 22 | Q.
What was prior to you declaring that you | | 23 | didn't -- | | 24 | A.
to Jeff Epstein's
That
had taken | | 25 | a couple of times in my car. | | | | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 90e1e8e0-101b-47ff-b728-ef54d28436d 3506-001 Page 123 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 71819110, 15, and 17 EFTA_00006246 ![](_page_123_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006247 ![](_page_124_Figure_0.jpeg) EFTA_00006248 ![](_page_125_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006249 | 1 | | | --- | ------------------------------------------------------ | | 2 | | | 3 | | | 4 | | | 5 | | | 6 | | | 7 | | | 8 | | | 9 | | | 10 | | | 11 | | | 12 | | | 13 | | | 14 | | | 15 | | | 16 | | | 17 | Q.
Did there come a time that your daughter told | | 18 | you a different story about what was going on when she | | 19 | went to Mr. Epstein's? | | 20 | A.
No. | | 21 | Q.
Right up until today? | | 22 | A.
I'll be honest with you.
The way I found out | | 23 | is when an FBI agent knocked on my door. | | 24 | Q.
Okay.
And when did that happen? | | 25 | A.
We were living at the trailer then, so it was | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d20436cf Page 127 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006250 3506-001 Page 128 1 2 somewhere trailer in the time that we were living at this, a man and a woman 3 came to the house. And they told me I couldn't even 4 listen to the conversation, it had nothing to do with 5 me, it pertained to my daughter. 6 Q. So who was present at this meeting? 7 A. A woman, a man and my daughter. And they said 8 they were from the FBI. 9 Q. And did you participate in this conversation? 10 A. No, I didn't, sir. They wouldn't let me. 11 Q. Well, they said you couldn't participate, but 12 were you -- 13 A. No, I wasn't. I was in the house. 14 Q. How old was your daughter at the time? 15 A. Oh, this just -- it happened while we were at 16 the trailer, so it was probably about -- maybe a year 17 and a half ago. 18 Q. She was over 18 by then? 19 A. Yeah, uh-huh, I think so. 20 Q. And that's the first time that you suspected 21 22 that something different was going on than cleaning the house? 23 A. That's the first time I found out something 24 different was going on. 25 Q. And how did you find it out, if you weren't PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47ff-b728-ef54d28436d 3506-001 Page 128 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA J)0006251 Page 129 | 1 | present in that meeting? | | --- | ---------------------------------------------------------- | | 2 | A.
Because when they were done with my daughter, | | 3 | I specifically asked these people. And they said they | | 4 | had to talk to her about Jeffrey Epstein. So that's the | | 5 | person she worked for, so I just assumed being the | | 6 | brilliant person I am that, you know, something more is | | 7 | going on. | | 8 | But did these -- did these two people
Q.
Okay. | | 9 | that you've identified as FBI agents tell you anything | | 10 | else was going on? | | 11 | No, I don't recall them.
A. | | 12 | Q.
Did your daughter ever tell you anything else | | 13 | was going on? | | 14 | A.
That's when my daughter spilled the beans. | | 15 | And she told me she was going to Mr. Epstein's and she | | 16 | was bringing girls there from
school and she'd get | | 17 | paid a hundred dollars for every girl she brought there, | | 18 | plus she would get \$300. And that's when she told me | | 19 | that what was going on, because she felt like it didn't | | 20 | matter now because she hadn't been over there for, you | | 21 | know, for a -- you know, a year or two years, whatever | | 22 | it was, a year.
So, I mean, it was like water under the | | 23 | told me.
bridge. And that's when | | 24 | And she goes, Mom, the negligees, and he took | | 25 | pictures of me. | | | | PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Seelegeg-101b-47ff-b728-efS4d28436cf 3506-001 Page 129 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006252 | | Page 130 | | --- | -------------------------------------------------------- | | 1 | And I said, well, what do you mean? | | 2 | And
took pictures of her and this Maxine | | 3 | or Max -- Max -- I don't know, but all's I know it was | | 4 | Max something. | | 5 | Q.
Maxine what?
What was she saying about this | | 6 | Maxine person? | | 7 | A.
That -- that this Maxine person would take | | 8 | would -- she modeled for them.
pictures and | | 9 | And she said, Mom, that's why, you know, that | | 10 | different lingerie -- it was just, like, you know, stuff | | 11 | like that. | | 12 | And I said, well, what's this massage book | | 13 | about? | | 14 | And that's when she told me. | | 15 | Q.
Told you what? | | 16 | A.
That's when
actually admitted to me | | 17 | that
would put on these little outfits and | | 18 | Jeffrey Epstein would ejaculate in front of her. | | 19 | Q.
Is that what she told you? | | 20 | A.
Uh-huh. | | 21 | Now, is this all in this immediately following
Q. | | 22 | the occasion that the -- | | 23 | A.
FBI came. | | 24 | -- two people from the FBI? So it happened
Q. | | 25 | right after that meeting on the same day? | | | | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 130 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006253 | | Page 131 | | --- | ------------------------------------------------------- | | 1 | That's -- well, pretty much so, yeah.
A.
That's | | 2 | . And I said, could you please
when I questioned | | 3 | tell me what's really going on? What kind of trouble | | 4 | are you in? | | 5 | And she said, Mom, I'm not in no trouble. | | 6 | I said, well, what is this all about? | | 7 | And that's when
told me.
She says, | | 8 | you know that place you took me to with Jeffrey Epstein | | 9 | and you met him and his nice car? Well, that's Jeffrey | | 10 | Epstein and he took pictures of me. | | 11 | Q.
Did she tell you anything more about other | | 12 | than just that he, quote, took pictures of me? | | 13 | A.
No.
He would do sex acts with some other | | 14 | I guess it was his wife.
girl. | | 15 | Sex acts -- when she said pictures, did she
Q. | | 16 | describe anything more about the pictures, what her | | 17 | state of dress was, whether she was in lingerie? | | 18 | A.
Just that she was in lingerie and
No. | | 19 | And he would go into a bath --
sometimes she wasn't. | | 20 | guess this room was a bathroom or something and Jeffrey | | 21 | would just come out with a towel wrapped around him. | | 22 | And then one time he asked her to sit on him | | 23 | or -- I don't know -- sit on him or something. And | | 24 | -- I don't know whether she did or didn't | | 25 | because I was really getting disgusted and sick to my | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Sile1eSe8-101b-47f7-b728-ef54d28436d 3506-001 Page 131 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9 10, 15, and 17 EFTA_00006254 | | Page 132 | | --- | -------------------------------------------------------- | | 1 | stomach. | | 2 | Q.
Well, back to the pictures.
You said | | 3 | sometimes she said she was in lingerie and sometimes she | | 4 | wasn't? | | 5 | A.
Yeah. | | 6 | Q.
Meaning, what was she in, if she wasn't in the | | 7 | lingerie? | | 8 | A.
I guess she was nude. | | 9 | Q.
Did she tell you she was nude or she just said | | 10 | she was in some other outfit? | | 11 | A.
No.
She just said that just sometimes she was | | 12 | in lingerie and she wasn't. | | 13 | Q.
Did she tell you she was nude? | | 14 | A.
Honestly, I don't recall. | | 15 | Q.
How about these other pictures that you claim | | 16 | or this Maxine -- did she claim that
that either | | 17 | or Maxine took pictures of her? | | 18 | A.
Yeah. | | 19 | Q.
And what did she say her state of dress was | | 20 | for that? | | 21 | She was wearing a -- she said she was wearing,
A. | | 22 | like, lingerie-type clothing. | | 23 | Q.
Is that for both the pictures that
took | | 24 | and the pictures that allegedly -- | | 25 | A.
Honestly, I'm not sure. | | | | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47f7-b728-ef54d28436d 3506.001 Page 132 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA \_00006255 Page 133 1 Q. -- Maxine took? 2 Did she ever tell you that she was ever -- 3 anybody took any picture of her when she was naked or is 4 that just the assumption you made? 5 A. I don't recall her telling me that. 6 Q. And then -- so have you now told me everything 7 she told you about anyone taking pictures of her? 8 A. As -- yeah. 9 Q. And then you said did she say that she gave 10 massages to Mr. Epstein? 11 A. Yeah. That's why he was sending her massage 12 books because -- 13 Q. Did she describe those massages at all to you? 14 A. She told me she didn't want to discuss it with 15 me because it would hurt me. 16 Q. So she didn't tell you about it? 17 A. No. She just said that she was -- that she 18 would give Jeffrey massages. 19 Q. Then you say she said that -- what did she 20 tell you about what Mr. Epstein -- 21 A. I asked her what she massaged. 22 Q. Okay. And what did she say? 23 A. She says, Mom, I don't want to get into it. 24 You know enough. 25 Q. Did you ever push at any time after that to PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 gile1eSe8-101b-47ff-b728-ef54d28436cf 3506.001 Page 133 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006256 Page 134 1 find out more? 2 A. No. 3 Q. Then you say Mr. Epstein would ejaculate? 4 A. Yes. 5 Q. What did she specifically say about that? 6 A. He would jerk himself off -- 7 Q. Okay. Did she tell you -- 8 A. -- while took pictures. 9 Q. Of who? 10 A. Honestly, I'm not sure. 11 Q. Did she tell you anything else about the 12 massages? 13 A. No. But she did tell me that occasionally 14 there was other men that were present. And whether it 15 was a one-on-one with that man and her or however it 16 worked, I don't know, but my daughter didn't tell me 17 specifics. 18 Q. Did she say she was involved with other men? 19 A. Jeffrey Epstein brought people there, I guess, 20 yeah. 21 Q. But was she telling you -- what was she 22 telling you about the other men as it related to her? 23 A. Oh, that the phone call, I guess, the phone 24 calls that I was getting for to meet at the 25 house was because there was men, I guess, other men PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47f7-b728-ef54d28436d 3506.001 Page 134 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006257 | | Page 135 | | --- | -------------------------------------------------------- | | 1 | flying in from somewhere and they wanted -- I guess | | 2 | Jeffrey Epstein set a date up for
and the other | | 3 | man. | | 4 | Q.
Do you not know?
You keep saying, you guess. | | 5 | A.
Well, sir, it's only what I heard.
I don't | | 6 | know for surely.
I wasn't there. | | 7 | Q.
It's not something you know.
All right. | | 8 | Did your daughter tell you on any occasion she | | 9 | went and there was some male person there | | 10 | A.
Yes, she did. | | 11 | Q.
What did she tell you about that? | | 12 | A.
She just told me that there was another -- | | 13 | another -- she had to meet one of Jeffrey Epstein's | | 14 | friends. | | 15 | Q.
When she said, meet, what was she telling you? | | 16 | What do you mean, meet one of Jeffrey Epstein's friends? | | 17 | A.
She just told me that she had to meet one of | | 18 | Jeffrey Epstein's friends at the house. | | 19 | What did she tell you happened when -- did she
Q. | | 20 | tell you that she actually met this person? | | 21 | A.
Yeah. | | 22 | Q.
What did she tell you happened when she met | | 23 | this person? | | 24 | A.
Honestly, I don't remember because I was just | | 25 | totally disgusted by the whole situation. | | | | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Sile1eSe8-101b-47ff-b728-ef54d28436cf 3506-001 Page 135 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9 10, 15, and 17 EFTA_00006258 | | Page 136 | | --- | -------------------------------------------------------- | | 1 | Q.
Did she claim that she had performed a massage | | 2 | on someone other than Mr. Epstein? | | 3 | A.
In Mr. Epstein's presence, yes.
Yes. | | 4 | Q.
So she told you specifically that there was an | | 5 | occasion that she went to Mr. Epstein's house and | | 6 | performed a massage on some other man and Mr. Epstein | | 7 | was present? | | 8 | A.
Yes. | | 9 | Q.
Did she tell you anything about that massage? | | 10 | A.
No. | | 11 | Q.
Did she tell you whether or not that happened | | 12 | on any occasion more than this one occasion? | | 13 | A.
Well, I know
also told me about | | 14 | something about two girls and Mr. Epstein observed it. | | 15 | Q.
What did she tell you about two girls? | | 16 | A.
Well, actually I think Mr. Epstein, I guess | | 17 | his wife -- I guess it was his wife is what she told me, | | 18 | that he -- Mr. Epstein wanted
and his wife to | | 19 | perform sexual acts on each other. | | 20 | Q.
Did she say what acts? | | 21 | Honestly, I said, please don't go any further
A. | | 22 | because it's turning my stomach. | | 23 | Q.
Did she tell you whether she, in fact, engaged | | 24 | in any sexual act with this per -- | | 25 | A.
No. | | | | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 SifeleSeS-101b-47f7-b728-efSild28436cf 3506-001 Page 136 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9 10, 15, and 17 EFTA_00006259 | Page 137 | | --------------------------------------------------------------- | | Q.
1
She didn't tell you or she said she didn't? | | 2
I don't know
A.
No, I didn't say she didn't. | | 3
because my daughter knew I was not feeling easy with the | | 4
situation.
And she already knew that I was diagnosed | | 5
being sick, and my daughter just didn't want to put any | | 6
more on my head. | | 7
Q.
Okay.
Did she tell you anything else about | | 8
going over to Mr. Epstein's, other than what you've told | | 9
me thus far? | | A.
10
No. | | Q.
Did she tell you how much she was getting paid
11 | | for each of these visits?
12 | | After -- when the FBI, I found out she was
13
A. | | getting \$300 per session.
And every time she brought a
14 | | 15
friend there he would pay a hundred to \$200 to her, just | | like a finder's fee.
16 | | Q.
17
And you say the FBI told you that? | | A.
No. I said
18
did. | | Q.
19
Okay. | | 20
And she told you she was bringing people from | | 21
the
school? | | 22
A.
Yes. | | 23
Q.
Did she ever tell you who she brought? | | A.
24
No. | | 25
Q.
Did she ever tell you anything more about | | | | PROSE COURT REPORTING AGENCY, INC. | Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 SeeletieS-101b-47ff-b728-ef54d28436cf 3506.001 Page 137 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006260 Page 138 1 this -- who was this person that you said that -- 2 A. 3 Q. Yeah, • Did she tell you anything 4 more about this MI person? 5 A. I met IIIII quite -- a very, very nice 6 girl, very attractive. And I don't -- I don't know what 7 happened to II because she was, like, there one 8 day and gone the next. 9 And then I guess talked to somebody or 10 talked to somebody and they told me that Jeffrey 11 Epstein sent her somewhere to go to school to increase 12 her knowledge in, I guess, physical therapist then. 13 And then I heard she got married to 14 somebody -- I don't remember where they told me she got 15 married. And that's where she is, but... 16 Q. Have you had any other contact with 17 Mr. Epstein, other than what you've described 18 A. No, uh-uh. 19 Q. -- in this deposition? 20 A. No. 21 Q. Now, your daughter told you these things, 22 whatever day it was the FBI came by, and you think that 23 was around a year ago? 24 MR. : No. Object to the form. 25 MR. LUTTIER: Did I get that wrong? PROSE COURT REPORTING AGENCY, INC. MectronkallysIgmdbySmckerownserW001 MectronkallysIgmdby&mdranownserW001 Seeletie8-101b-47f7-0728-054d28436d 3506-001 Page 138 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9 10, 15, and 17 EFTA_00006261 Page 139 1 BY MR. LUTTIER: 2 Q. Refresh my memory. About how long ago do you 3 think this meeting was with the FB -- 4 A. Oh, I don't know. All's I could tell you is 5 exactly it was the time we were living in this trailer. 6 Q. The one you're in now or -- 7 A. Uh-huh. 8 Q. All right. Was the statement recorded, do you 9 know? 10 A. I couldn't tell you, sir. 11 Q. Were they in a separate room from where you 12 were? 13 A. Sir, they were sitting outside on my patio. 14 was in the house. 15 Q. For the entire conference? 16 A. Yes, sir. 17 Q. And you say it was a man and a woman? 18 A. Yes, sir. 19 Q. Black? White? 20 A. Sir, I don't remember. 21 Q. To the best of your knowledge, were there any 22 other meetings with the FBI? 23 A. Sir, I don't know. 24 Q. Has your daughter discussed it? Other than 25 the discussion you had with her immediately following PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Seele8e8-101b-47ff-b728-efS4d28436cf 3506-001 Page 139 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006262 | | | | Page 140 | | --- | --- | --- | ------------------------------------------------ | | 1 | | | her meeting with the FBI, have you had any other | | 2 | | | discussions with her | | 3 | | A. | No, sir. | | 4 | | Q. | -- about Jeffrey Epstein? | | 5 | | A. | No, sir. | | 6 | | Q. | Right up until today? | | 7 | | A. | No. Because she knows the way I feel about | | 8 | it. | | | | 9 | | | | | 10 | | | | | 11 | | | | | 12 | | | | | 13 | | | | | 14 | | | | | 15 | | | | | 16 | | | | | 17 | | | | | 18 | | | | | 19 | | | | | 20 | | | | | 21 | | | | | 22 | | | | | | | | | | 23 | | | | | 24 | | | | EFTA_00006263 ![](_page_140_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006264 ![](_page_141_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 718191101151 and 17 EFTA_00006265 ![](_page_142_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006266 ![](_page_143_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006267 ![](_page_144_Figure_0.jpeg) EFTA_00006268 ![](_page_145_Figure_0.jpeg) EFTA_00006269 ![](_page_146_Figure_0.jpeg) EFTA_00006270 ![](_page_147_Figure_0.jpeg) EFIA_00006271 ![](_page_148_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006272 ![](_page_149_Figure_0.jpeg) EFTA_00006273 ![](_page_150_Figure_0.jpeg) EFTA_00006274 ![](_page_151_Figure_0.jpeg) EFTA_00006275 ![](_page_152_Figure_0.jpeg) EFTA_00006276 ![](_page_153_Figure_0.jpeg) EFTA_00006277 | | Page 155 | | --- | ----------------------------------------------------- | | 1 | MR.
Object to the form.
: | | 2 | THE WITNESS:
Let me put it to you this way: | | 3 | I wouldn't say anything out of the normal for a | | 4 | child growing up, but it got progressively worse | | 5 | after she met Mr. Epstein.
Okay?
Thank you very | | 6 | much. | | 7 | BY MR. LUTTIER: | | 8 | Q.
Well, it also got progressively worse after | | 9 | she fell in with this fellow,
and got pregnant by | | 10 | him, didn't it? | | 11 | A.
Well,
was the one that introduced her to | | 12 | Mr. Epstein, sir. | | 13 | Q.
And the drug use that she was using was when | | 14 | she was away from Mr. Epstein's house, wasn't it? | | 15 | Sir, I couldn't testify to that because I
A. | | 16 | don't know. | | 17 | Q.
You don't know whether or
So you don't know. | | 18 | was giving her the drugs or she was buying it
not | | 19 | off the street, do you? | | 20 | | | 21 | | | 22 | | | 23 | | | 24 | | | 25 | | | | | | | PROSE COURT REPORTING AGENCY, INC. | 3506-001 Page 155 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006278 ![](_page_155_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8191101151 and 17 EFTA_00006279 ![](_page_156_Figure_0.jpeg) EFTA_00006280 ![](_page_157_Figure_0.jpeg) EFIA_00006281 ![](_page_158_Figure_0.jpeg) EFTA_00006282 ![](_page_159_Figure_0.jpeg) EFTA_00006283 ![](_page_160_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006284 ![](_page_161_Figure_0.jpeg) EFTA_00006285 ![](_page_162_Figure_0.jpeg) EFTA_00006286 | | | Page 164 | | --- | --- | ------------------------------------------- | | 1 | | | | 2 | | | | 3 | | | | 4 | | | | S | | | | 6 | | | | 7 | | | | 8 | | | | 9 | | | | 10 | | | | 11 | Q. | By the way, did your daughter ever say that | | 12 | | Mr. Epstein ever hit her? | | 13 | A. | No. | | 14 | Q. | Ever say that he gave her drugs? | | 15 | A. | Not directly, no. | | 16 | Q. | Ever say that he physically hurt her? | | 17 | A. | No.
Physically hurt her? | | 18 | Q. | Yes. | | 19 | | | | 20 | | | | 21 | | | | 22 | | | | 23 | | | | 24 | | | | | | | EFTA_00006287 ![](_page_164_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006288 ![](_page_165_Figure_0.jpeg) EFTA_00006289 ![](_page_166_Figure_0.jpeg) EFTA_00006290 ![](_page_167_Figure_0.jpeg) EFIA_00006291 ![](_page_168_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006292 ![](_page_169_Figure_0.jpeg) EFTA_00006293 ![](_page_170_Figure_0.jpeg) EFTA_00006294 ![](_page_171_Figure_0.jpeg) EFTA_00006295 ![](_page_172_Figure_0.jpeg) EFTA_00006296 ![](_page_173_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006297 | | Page 175 | | --- | --------------------------------------------------------- | | 1 | What you're describing as normal with your | | 2 | kids is telling your kids, call me to let me know that | | 3 | you're not dead and in a dumpster yet; is that right? | | 4 | A.
No.
Actually, I've said that to my daughter | | 5 | because she disappears. | | 6 | And that's been a consistent problem, correct?
Q. | | 7 | A.
Not until recent. | | 8 | What do you mean by recently?
Q. | | 9 | A.
Not until after her escapades with Jeffrey | | 10 | That's when she really became out of control.
Epstein. | | 11 | That's when she ran off with this
Q. | | 12 | and went to
right? | | 13 | A.
Yep. | | 14 | | | 15 | | | 16 | | | 17 | But had a baby with him, right?
Q.
Okay. | | 18 | A.
Yes. | | 19 | | | 20 | | | 21 | | | 22 | | | 23 | | | 24 | | | 25 | | SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006298 | 1 | | | --- | --------------------------------------------------- | | 2 | Q.
Mr. Epstein doesn't have anything to do with | | 3 | any of that, does he? | | 4 | MR.
Object to the form.
: | | 5 | BY MR. LUTTIER: | | 6 | Q.
Wasn't around for any of that, was he, ma'am? | | 7 | A.
I don't know. | | 8 | | | 9 | | | 10 | | | 11 | | | 12 | | | 13 | | | 14 | | | 15 | | | 16 | | | 17 | | | 18 | | | 19 | | | 20 | | | 21 | | | 22 | | | 23 | | | 24 | | | 25 | | | | PROSE COURT REPORTING AGENCY, INC. | | | Electronically signed by Sandra Townsend (401 | EFTA_00006299 ![](_page_176_Figure_0.jpeg) SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8191101151 and 17 EFTA_00006300 | 1 | 178
paw:, | | ------ | ------------------------------------------------------ | | 2 | | | 3 | | | | | | 4
5 | | | 6 | | | 7 | | | 8 | | | 9 | | | 10 | | | 11 | | | 12 | | | 13 | | | 14 | MR. LUTTIER: Okay.
Let me take a break and | | 15 | might be done. | | 16 | Going off the record at 12:29
VIDEOGRAPHER: | | 17 | p.m. | | 18 | (Brief recess.) | | 19 | VIDEOGRAPHER:
We are back on the record at | | 20 | 12:39 p.m. | | 21 | BY MR. LUTTIER: | | 22 | Q.
Other than the occasions that you took your | | 23 | daughter to the -- to the location in Palm Beach where | | 24 | you said Mr. Epstein lived, have you ever taken your | | 25 | daughter anybody place else to meet Mr. Epstein? | | | | | | PROSE COURT REPORTING AGENCY, INC. | 3506-001 Page 178 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006301 | | Page 179 | | --- | -------------------------------------------------------- | | 1 | A.
No. | | 2 | Q.
Have you described for me in this deposition | | 3 | all personal contact, that is, one-on-one contact you've | | 4 | had with Mr. Epstein? | | 5 | A.
Just one time. | | 6 | And I meant, which would either be when you,
Q. | | 7 | personally, saw him or you, personally, spoke to the | | 8 | person who you believe is him -- | | 9 | A.
No. I'm talking about when I physically was | | 10 | on his property in his driveway. | | 11 | Q.
And have you described for me in this | | 12 | deposition all occasions when you've personally spoken | | 13 | with him on the phone? | | 14 | A.
Yeah. | | 15 | Q.
Has your daughter told you anything else about | | 16 | Mr. Epstein, other than what you've told me -- | | 17 | A.
No. | | 18 | -- during this deposition?
Q. | | 19 | MR. LUTTIER:
I don't have any other | | 20 | questions. | | 21 | MR.
I don't have lien
: | | 22 | | | 23 | | | 24 | | | 25 | | 3506-001 Page 179 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006302 ![](_page_179_Figure_0.jpeg) EFTA_00006303 ![](_page_180_Figure_0.jpeg) EFTA_00006304 ![](_page_181_Picture_0.jpeg) Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47(7-0720-ef54d20436cf 3506-001 Page 182 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006305 | | Page 183 | | --- | -------------------------------------------------------------------- | | 1 | CERTIFICATE OF OATH | | 2 | STATE OF FLORIDA | | 3 | COUNTY OF PALM BEACH | | 4 | | | 5 | | | 6 | I, the undersigned authority, certify that | | 7 | personally appeared before me and was | | 8 | duly sworn on the 6th day of November, 2009. | | 9 | | | 10 | Dated this 19th day of November, 2009. | | 11 | | | 12 | | | 13 | | | 14 | | | 15 | | | 16 | Sandra W. Townsend, Court Repd1
Notary Public - State of Florida | | 17 | My Commission Expires:
6/26/12
My Commission No.:
DD 793913 | | 18 | | | 19 | | | 20 | | | 21 | | | 22 | | | 23 | | | 24 | | | 25 | | | | | EFTA_00006306 | 1 | Page 184
CERTIFICATE | | | ------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --- | | 2 | STATE OF FLORIDA | | | | | | | 3 | COUNTY OF PALM BEACH | | | 4 | | | | 5
6 | I, Sandra W. Townsend, Court Reporter and
Notary Public in and for the State of Florida at Large,
do hereby certify that the aforementioned witness was by
me first duly sworn to testify the whole truth; that I | | | | | | | 7 | was authorized to and did report said deposition in
stenotype; and that the foregoing pages numbered 1 to | | | 8 | 182, inclusive, are a true and correct transcription of | | | 9 | my shorthand notes of said deposition. | | | 10 | I further certify that said deposition was
taken at the time and place hereinabove set forth and
that the taking of said deposition was commenced and | | | 11 | completed as hereinabove set out. | | | 12 | I further certify that I am not attorney or | | | 13 | counsel of any of the parties, nor am I a relative or
employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the | | | 14 | action. | | | 15 | The foregoing certification of this transcript
does not apply to any reproduction of the same by any | | | 16 | means unless under the direct control and/or
direction
of the certifying reporter. | | | 17 | | | | 18 | | | | 19 | Dated this 19th day of November, 2009. | | | 20 | | | | 21 | | | | | Sandra W. Townsend, Court Reporter | | | 22 | | | | 23 | | | | 24 | | | | 25 | | | 3506-001 Pagc 184 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006307 | | | Page 185 | | | | --- | ------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --- | --- | | 1 | DATE: | November 19, 2009 | | | | 2 | TO: | c o
, Esquire | | | | 3 | | | | | | 4 | | | | | | 5 | IN RE: | III II vs. Epstein | | | | 6 | | CASE NO.: 08-CIV-80119-MARRA/JOHNSON | | | | 7 | | Please take notice that on Friday, the 6th of
November, 2009, you gave your deposition in the | | | | | | above-referred matter.
At that time, you did not waive | | | | 8 | signature.
deposition. | It is now necessary that you sign your | | | | 9 | | Please call our office at the below-listed | | | | 10 | number to schedule an appointment between the hours of
9:00 a.m. and 4:30 p.m., Monday through Friday, at the
Esquire office located nearest you. | | | | | 11 | | If you do not read and sign the deposition | | | | 12 | | within a reasonable time, the original, which has
already been forwarded to the ordering attorney, may be
filed with the Clerk of the Court. If you wish to waive | | | | 13 | | your signature, sign your name in the blank at the
bottom of this letter and return it to us. | | | | 14 | | | | | | 15 | | Very truly yours, | | | | 16 | | | | | | 17 | | Sandra W. Townsend, FPR
PROSE COURT REPORTING AGENCY | | | | 18 | | | | | | 19 | | | | | | 20 | | I do hereby waive my signature. | | | | 21 | | | | | | 22 | | | | | | 23 | | I do hereby waive my signature: | | | | 24 | | cc: Via transcript: All Counsel of Record; file copy | | | | 25 | | | | | | | | PROSE COURT REPORTING AGENCY, INC. | | | | | | | | | | | Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401 | 08e1e8e8-101b-4717-0720-ef54d20436cf | | | | | | | | | EFTA_00006308 | | Page 186 | | --- | -------------------------------------------------------------------------------------------------------------------------------------- | | 1 | CERTIFICATE | | 2 | | | 3 | THE STATE OF FLORIDA | | 4 | COUNTY OF PALM BEACH | | 5 | I hereby certify that I have read the | | 6 | foregoing deposition by me given, and that the | | 7 | statements contained herein are true and correct to the | | 8 | best of my knowledge and belief, with the exception of | | 9 | any corrections or notations made on the errata sheet, | | 10 | if one was executed. | | 11 | | | 12 | day of
Dated this | | 13 | 2009. | | 14 | | | 15 | | | 16 | | | 17 | | | 18 | | | 19 | | | 20 | | | 21 | | | 22 | | | 23 | | | 24 | | | 25 | | | | PROSE COURT REPORTING AGENCY, INC. | | | Electronically signed by Sandra Townsend (401
Electronically signed by Sandra Townsend (401
08e1e8e8-101b-4717-0720-ef54d20436cf | | | Pagc 186 of 187 | EFTA_00006309 | | Page 187 | | -------- | ---------------------------------------------------------------------------------------------------------------- | | 1 | ERRATA
SHEET | | 2 | MI
CR: S. TOWNSEND
IN RE:
VS. EPSTEIN | | 3 | DEPOSITION OF: | | 4 | TAKEN: 11/6/09 | | 5 | | | 6 | DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE | | 7 | PAGE 4
LINE 4
CHANGE
REASON | | 8 | | | 9 | | | 10 | | | 11 | | | 12 | | | 13 | | | 14 | | | 15 | | | 16 | | | 17 | | | 18 | Please forward the original signed errata sheet to this | | 19 | office so that copies may be distributed to all parties. | | 20 | Under penalty of perjury, I declare that I have read my
deposition and that it is true and correct subject to | | | any changes in form or substance entered here. | | 21 | | | 22 | DATE: | | 23 | | | 24
25 | SIGNATURE OF DEPONENT: | | | | EFTA_00006310