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	UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CIV-80119-MARRA/JOHNSON
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	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.
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1	PROCEEDINGS
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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:

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1		Q.			This is when you earlier said you moved to
2			West Palm Beach?
3		A.	Yeah.
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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.
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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.
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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.

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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

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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.¶

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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

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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

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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.
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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
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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

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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.¶

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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.
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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?
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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.
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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?

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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?
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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.¶

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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.¶

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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.¶

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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.¶

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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.¶

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	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
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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.

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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.
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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¶

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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

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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
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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
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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.¶

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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

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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
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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.¶

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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

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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

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12
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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
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	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
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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
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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

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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
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	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
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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.¶

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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.¶

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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.

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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

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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.
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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
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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.¶

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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.

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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?
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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
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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.
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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.¶

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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.¶

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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.
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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.
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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
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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.¶

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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.¶

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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.
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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
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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
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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.
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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.
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1	178 paw:,
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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?
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	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 :
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	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
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16	Sandra W. Townsend, Court Repd1 Notary Public - State of Florida
17	My Commission Expires: 6/26/12 My Commission No.: DD 793913
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1	Page 184 CERTIFICATE
2	STATE OF FLORIDA
3	COUNTY OF PALM BEACH
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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
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19	Dated this 19th day of November, 2009.
20
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	Sandra W. Townsend, Court Reporter
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		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
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	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.
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	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
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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:

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