# EXHIBIT 1 (FILE UNDER SEAL) Page 1 HIGHLY CONFIDENTIAL AEO UNITED STATES DISTRICT COUR"' SOUTHERN DISTRICT OF NEW YORK x v. GHISLAINE MAXWELL, Plaintiff, Case No: 15-cv-07433-RWS Defendant. x HIGHLY CONFIDENTIAL DEPOSITION OF NEW YORK, NEW YORK Friday, February 17, 2017 Reported by: JEREMY RICHMAN JOB NO: 300491 > MAGNA LEGAL SERVICES 320 West 37th Street, 12th Floor New York, New York 10018 (866) 624-6221 ![](_page_1_Picture_19.jpeg) Page 2 at the offices of Boies, Schiller & Flexner, 575 Lexington Avenue, New York, New York, before JEREMY RICHMAN, a Shorthand Reporter and Notary Public of the State of New York. HIGHLY CONFIDENTIAL AEO February 17, 2017 9:00 a.m. DEPOSITION of, held Page 3 1 HIGHLY CONFIDENTIAL AEO 2 APPEARANCES: 3 4 BOIES, SCHILLER & FLEXNER, LLP 5 Attorneys for plaintiff 6 401 East Las Olas Boulevard, Suite 1200 7 Fort Lauderdale, FL 33301-2211 8 BY: SIGRID MCCAWLEY, ESQ. 9 (smccawley@bsfllp.com) 10 11 12 HADDON, AND, P.0 13 Attorneys for Defendant 14 150 East 10th Avenue 15 Denver, CO 80230 16 BY: LAURA A. MENNINGER, ESQ. 17 JEFFREY S. PAGLIUCA, ESQ. 18 (lmenninger@hmflaw.com) 19 (jpagliuca@hmflaw.com) 20 21 22 23 24 25 Page 4 HIGHLY CONFIDENTIAL AEO 2 APPEARANCES (Continued): 3 4 J. STANLEY POTTINGER, PLLC 5 Attorneys for the witness 6 49 Twin Lakes Road, Suite 100 7 South Salem, NY 10590 8 BY: J. STANLEY POTTINGER, ESQ. 9 (stanpottinger@aol.com) 10 11 12 MINTZ & GOLD, LLP 13 Attorneys for the witness 14 600 Third Avenue 15 New York, NY 10016 16 BY: PETER GUIRGUIS, ESQ. 17 (guirguis@mintzandgold.com) 18 19 20 ALSO PRESENT: 21 GHISLAINE MAXWELL, via teleconference 22 23 24 25 Page 5 1 HIGHLY CONFIDENTIAL AEO 2 IT IS HEREBY STIPULATED AND AGREED 3 by and between the attorneys for the respective 4 parties herein, that filing and sealing be and 5 the same are hereby waived. 6 IT IS FURTHER STIPULATED AND AGREED 7 that all objections, except as to form of the 8 question, shall be reserved to the time of the 9 trial. 10 IT IS FURTHER STIPULATED AND AGREED 11 that the within deposition may be sworn to and 12 signed before any officer authorized to 13 administer an oath, with the same force and 14 effect as if signed and sworn to before the 15 Court. 16 17 18 19 20 - oOo - 21 22 23 24 25 Page 6 HIGHLY CONFIDENTIAL AEO 2 MS. MENNINGER: If we could 3 have counsel enter their 4 appearances for the record, 5 please. 6 MR. GUIRGUIS: Sure. My 7 name is Peter Guirguis. I'm 8 appearing on behalf of the 9 witness today. 10 MS. MCCAWLEY: Sigrid 11 McCawley on behalf of the plaintiff in the 13 action. 14 MR. POTTINGER: Stan 15 Pottinger on behalf of the 16 witness. 17 MS. MENNINGER: Laura 18 Menninger and Jeffrey Pagliuca or 19 behalf of Ms. Maxwell, who is 20 appearing by telephone. 21 having been 22 called as a witness, having first 23 been duly sworn by a Notary 24 Public (Jeremy Richman) of the 25 State of New York, was examined Page 7 HIGHLY CONFIDENTIAL AEO 2 and testified as follows: 3 EXAMINATION BY 4 MS. MENNINGER: 5 Q. Good morning, 6 A. Good morning. 7 Q. Can you please give us your 8 full name. 9 A. 10 Q. And what is your birth date? 11 A. 12 Q. And what is your current 13 address? 14 MR. GUIRGUIS: I'm going to 15 object to current address. 16 Q. You can answer. 17 MR. GUIRGUIS: You can give 18 your last permanent address. 19 A. 20 (An off-the-record 21 discussion was held.) 22 A. 24 Q. And what does that mean, 25 that's your last permanent address? Page 8 HIGHLY CONFIDENTIAL AEO 2 A. I reside there. 3 Q. Do you rent an apartment? 4 A. My partner does 5 Q. Who is your partner? 6 MR. GUIRGUIS: Objection. 7 Q Who is your partner? 8 THE WITNESS: Do I have to 9 answer that? 10 MR. GUIRGUIS: Yes. 11 A. 12 Q. I'm sorry? 13 A. 14 Q. How do you spell that last 15 name? 16 A. 17 Q. And how long has been 18 your partner? 19 MR. GUIRGUIS: I'm going to 20 object. I'm not sure what the 21 relevance of this is or where 22 you're going with this. 23 Q. How long has been your 24 partner? 25 THE WITNESS: Sorry, can I Page 9 HIGHLY CONFIDENTIAL AEO 2 just ask a question? I would 3 like to just clarify. When you 4 say objection, does that mean I 5 actually have to answer the 6 question? Because that's 7 irrelevant. 8 MR. GUIRGUIS: Right. 9 Unless I'm telling you not to 10 answer, you need to answer. 11 THE WITNESS: So I don't 12 need to answer? 13 MR. GUIRGUIS: No, you do 14 need to answer this. 15 A. Okay. We've been together 16 almost a year. 17 Q. And what is your current 18 occupation? 19 A. I'm a writer. 20 Q. And what do you write? 21 A. Just stuff, you know? Just 22 about factual stuff. You know, just a 23 bit of this, bit of that. 24 Q. Have you been paid for any 25 of your writing? Page 10 HIGHLY CONFIDENTIAL AEO 2 A. No. It's more of a hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 object to that. Income is out. 11 You don't have to answer 12 that. 13 Q. Do you have any source of 14 income? 15 MR. GUIRGUIS: I just 16 objected to that. You don't have 17 to answer. 18 MS. MENNINGER: Is there a 19 privilege you're asserting? 20 MR. GUIRGUIS: I'm not sure 21 what the relevance is, and I'm 22 not going to allow -- 23 MS. MENNINGER: Do you 24 believe that relevance is a 25 proper objection during a Page 11 HIGHLY CONFIDENTIAL AEO deposition? MR. GUIRGUIS: I believe 4 that if you go far afield with 5 this witness, that the judge is 6 not going to appreciate it, and 7 that I'm not going to just sit 8 here and be a potted plant and 9 allow her to answer any questions 10 on any subject that you see fit. 11 MS. MENNINGER: On 12 relevance? You're instructing 13 her not to answer on a relevance 14 objection? Is that what you're 15 saying? 16 MR. GUIRGUIS: I just 17 objected. 18 MS. MCCAWLEY: I'm going to 19 object on behalf of the 20 plaintiff, , to 21 the extent that you're requesting 22 from a nonparty financial 23 information, which is not allowed 24 under New York law. 25 MS. MENNINGER: I have asked Page 12 HIGHLY CONFIDENTIAL AEO 2 her whether she has any source of 3 income, and you're going to 4 object -- 5 MS. MCCAWLEY: Yes. 6 MS. MENNINGER: -- and 7 instruct her not to answer as 8 well? 9 MS. MCCAWLEY: I'm not 10 instructing her not to answer. 11 I'm just making a record. 12 MR. GUIRGUIS: It's 13 financial information -- 14 MS. MENNINGER: And whether 15 she has a financial motive is 16 relevant. 17 Q. So I'm going to ask you a 18 last time: Do you have any source of 19 income? 20 MR. GUIRGUIS: I'm going to 21 instruct you again not to answer. 22 Q. Has any of your writing been 23 published by anyone? 24 A. No. 25 Q. Have you sought to have your Page 13 1 HIGHLY CONFIDENTIAL AEO 2 writing published by anyone? 3 A. No. 4 Q. What is your partner's 5 occupation? 6 MR. GUIRGUIS: Objection. 7 MS. MCCAWLEY: Objection. 8 MR. GUIRGUIS: I'm going to 9 object, yeah. Same objection. 10 MS. MENNINGER: If you are 11 going to instruct the witness not 12 to answer, please say that 13 contemporaneous with your 14 objection, because there are two 15 different things: There are 16 objections and instructions not 17 to answer. 18 So are you instructing her 19 not to answer what her partner's 20 occupation is? 21 MR. GUIRGUIS: Right. Same 22 objection. I'm instructing the 23 witness not to answer on the 24 basis of both relevance and 25 because she is a third-party nor. Page 14 HIGHLY CONFIDENTIAL AEO 2 -- I'm sorry -- nonparty witness who you are asking for financial 4 information about -- 5 MS. MENNINGER: No, I asked 6 for an occupation. 7 MS. MCCAWLEY: I'm going to 8 object. That relates directly to 9 financial information, so it's 10 covered by New York law with 11 respect to nonparty witnesses. 12 Q. What are the names of your 13 parents? 14 A. U 16 Q. How do you spell 17 A. 18 Q. And where do your parents 19 live? 20 A. I'm not comfortable giving 21 my mother's and my father's address to 22 you. 23 MS. MENNINGER: Are you 24 instructing her not to answer? 25 MS. MCCAWLEY: Do you want Page 15 1 HIGHLY CONFIDENTIAL AEO 2 to confer? 3 MR. GUIRGUIS: Give me a 4 moment on this. 5 THE WITNESS: We're really 6 well organized. 7 (Time noted: 9:21 a.m.) 8 (Recess.) 9 (Time noted: 9:23 a.m.) 10 Q. , there was a 11 question pending when you took a break 12 with your lawyers. Can you please 13 answer the question. 14 MR. GUIRGUIS: I'm 15 instructing the witness not to 16 answer questions regarding 17 current information about her own 18 location, her family's location, 19 things of that nature. 20 The witness has expressed to 21 me fears of harassment and the 22 belief that she's being followed, 23 and my understanding is that 24 there are other witnesses that 25 have had similar fears and Page 16 HIGHLY CONFIDENTIAL AEO 2 concerns. 3 And unless you make some 4 sort of proffer of the actual 5 relevance of her parents' 6 addresses, wherever those are, 7 I'm not going to have her answer. 8 MS. MENNINGER: Okay. Where 9 does that understanding come 10 from, please, Mr. Guirguis? 11 Mr. Guirguis, where does 12 your understanding come from? 13 You just made a factual 14 representation. I would like to 15 know where your understanding 16 comes from. 17 MR. GUIRGUIS: Yeah, I'm not 18 being deposed. I'm not going to 19 answer your questions. 20 MS. MENNINGER: All right. 21 Q. , did you agree 22 to be a witness in the case of 23 versus Maxwell? 24 A. Yes. 25 Q. Did you voluntarily agree to 1 HIGHLY CONFIDENTIAL AEO 2 do that? 3 A. Yes. 4 Q. Were you promised anything 5 in exchange for your testimony in the 6 versus Maxwell case? Page 17 7 A. No. 8 Q. Were you provided legal 9 counsel? 10 A. Sorry, does that mean -- 11 MS. MCCAWLEY: You have a 12 lawyer, yes? 13 MR. GUIRGUIS: Yes. 14 A. Yes. 15 Q. Okay. How many lawyers do 16 you have now? 17 A. Three. 18 MS. MENNINGER: I would like 19 the record to reflect that 20 witness is checking with the 21 lawyers to get answers to these 22 questions. 23 MR. POTTINGER: Wait, wait, 24 wait. Objection. 25 MR. GUIRGUIS: There is Page 18 HIGHLY CONFIDENTIAL AEO 2 absolutely no exchange. No words 3 were spoken by -- 4 MS. MENNINGER: 5 Mr. Pottinger, did you put up a 6 number of fingers? 7 Did you put up a number of 8 fingers, Mr. Pottinger? 9 MR. POTTINGER: You said, 10 I'm going to object because the 11 witness is answering these 12 questions, in the plural. 13 MS. MENNINGER: Mm-hmm. 14 MR. POTTINGER: That is 15 inaccurate. When she looked at 16 me to ask how many lawyers she 17 had, I said three with three 18 fingers. That is a single 19 request on her part and a single 20 answer, not multiple. 21 MS. MENNINGER: No. She has 22 looked to her lawyers for 23 previous answers. 24 We'll just make a record as 25 we go along. Thank you. Page 19 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: You could 3 have had a videotape here so that 4 we would have a record of that, 5 because I think your verbal 6 record is inaccurate, so... 7 MR. POTTINGER: And, in 8 fact, she -- this is Mr. 9 Pottinger speaking. 10 And, in fact, she has not 11 looked at me during this 12 deposition except one time, which 13 was for what I took to be a 14 request to know how many lawyers 15 she has. 16 MS. MENNINGER: So are you 17 being deposed, Mr. Pottinger? 18 MR. POTTINGER: I am not. 19 Q. , how many 20 lawyers do you think you have? 21 A. Three. 22 Q. Can you please name them? 23 A. Peter, Sigrid and Stan. 24 Q. Is Mr. 25 representing you? Page 20 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. Is Mr. Paul Cassell 4 representing you? 5 A. No. 6 Q. Is Mr. David Boies 7 representing you? 8 A. Yes. 9 MS. MCCAWLEY: I just want 10 to be clear for the record if 11 you're talking about representing 12 generally or you're talking about 13 a particular matter. Because we 14 have a couple matters. 15 MS. MENNINGER: I'm asking 16 questions here. 17 MS. MCCAWLEY: No, I 18 understand that you have to make 19 the record clear -- 20 MS. MENNINGER: Ms. 21 McCawley, if you want to ask her 22 questions later, you are more 23 than welcome to do so. I am 24 going to ask questions of the 25 witness I am deposing. Page 21 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: Well, we want 3 the record to be clear that there 4 are more than one action -- 5 MS. MENNINGER: You can ask 6 questions when you're doing your 7 questioning. I'm doing my 8 questioning now, and so I will 9 ask the questions. 10 MS. MCCAWLEY: I'm going to 11 object. The record should be 12 clear there is more than one 13 action pending here. She is 14 represented here as a nonparty 15 witness, and she also has her own 16 action pending. 17 MR. PAGLIUCA: Thank you for 18 that speaking objection, Ms. 19 McCawley, and communicating that 20 information to the witness, which 21 you know is totally improper. 22 MS. MCCAWLEY: Now, that's 23 two people objecting right now. 24 Is it going to be Laura taking 25 this deposition or you, Jeff? Page 22 HIGHLY CONFIDENTIAL AEO 2 You guys have done this to me 3 before, and it's not a position 4 where you're allowed to object 5 and she's allowed to object. You 6 guys pulled that at the last 7 deposition, so please do not do 8 this here. 9 MR. PAGLIUCA: I was just 10 thanking you. 11 Q. All right. So the number of 12 lawyers we're up to so far is 13 Mr. Guirguis, Ms. McCawley, 14 Mr. Pottinger, Mr. , Mr. Boies. 15 That's five, correct? 16 A. Can I just ask you a 17 question? 18 Q. No, you cannot. 19 A. Okay. 20 Q. Are those five lawyers that 21 are representing you? 22 MR. GUIRGUIS: Objection. 23 Q. Yes or no? 24 A. Yes. 25 Q. All right. Anyone else Page 23 2 representing you? 3 A. No. 6 A. No. 7 Q. How much are you paying for 8 any of those lawyers? 9 A. It's on a pro-bono basis. 10 Q. Do you know what each of 11 those lawyers' normal hourly rates 12 are? 13 A. No. 14 Q. Do you know how many hours 15 you have spent with your attorneys? 16 A. No. 17 MR. GUIRGUIS: Objection. 18 Q. How many hours have you 19 spent with Mr. Guirguis? 20 MR. GUIRGUIS: Objection. 21 Q. Without communicating to me 22 any information you and he have 23 shared. 24 A. A few, maybe. 25 Q. How many? HIGHLY CONFIDENTIAL AEO 4. representing you? Page 24 HIGHLY CONFIDENTIAL AEO 2 A. About 11 hours in total. 3 Q. When is the first time that 4 you met Mr. Guirguis? 5 MR. GUIRGUIS: Objection. 6 MS. MCCAWLEY: You can 7 answer. 8 MR. GUIRGUIS: You can 9 answer. 10 A. Yesterday. 11 Q. You met Mr. Guirguis 12 yesterday? Was that your answer? 13 A. Yes. 14 Q. And who is paying for 15 Mr. Guirguis's fees, if you know? 16 A. I have a pro-bono 17 arrangement. 18 Q. Do you know if he's 19 receiving money from anyone else in 20 exchange for representing you? 21 A. No. 22 Q. No, you don't know, or no, 23 he is not? 24 A. I don't know. 25 Q. How many hours have you Page 25 1 HIGHLY CONFIDENTIAL AEO 2 spent with Ms. McCawley? 3 A. Can I just clarify that 4 question? Does that mean on the 5 phone? Like what are you referring 6 to, in person or -- 7 Q. Either one. How many hours, 8 how much time have you spent with 9 Ms. McCawley in person? 10 A. I met with Ms. McCawley for 11 the first time in person yesterday, 12 but I've spent -- yeah, we've been -- 13 Ms. McCawley was the first person I 14 actually spoke to. 15 Q. And how many hours have you 16 spent with her on the phone? 17 A. Many, many hours. 18 Q. Approximately how many? 19 A. I don't know. 20 Q. Five? 21 MR. GUIRGUIS: Objection. 22 A. More than five. 23 Q. Ten? 24 MR. GUIRGUIS: Objection. 25 Q. Ten? Page 26 HIGHLY CONFIDENTIAL AEO 2 A. Well, 10, 15. She's been 3 with me the whole way since when I 4 came forward, so she's been a very 5 prominent person. 6 Q. And when did you first speak 7 with her on the phone? 8 A. I think it was -- 9 Q. Without telling me what you 10 said. 11 A. I think it was November. 12 Q. November what? 13 A. I can't remember the date. 14 Q. Early November? Late 15 November? 16 MR. GUIRGUIS: Objection. 17 A. I can't remember. 18 Q. Was she speaking to you on 19 your cell phone or a landline? 20 A. Cell phone. 21 Q. A mobile number or a 22 landline? 23 A. A cell phone. 24 Q. Okay. And what's that cell 25 phone number? Page 27 HIGHLY CONFIDENTIAL AEO A. I don't have it anymore. Q. That's okay. What's the 4 cell phone number? 5 A. I actually don't know. I 6 can't remember my cell phone number. 7 I don't have anything with me, so I 8 can't remember that number offhand. 9 Q. How long did you have that 10 cell phone? 11 A. About eight months. 12 Q. What happened to it? 13 A. I got rid of it. 14 Q. Why? 15 A. Because I fear for my life 16 because of Jeffrey Epstein and 17 Ghislaine Maxwell. 18 Q. What did you do with it? 19 A. I sold it. 20 Q. When? 21 A. November. 22 Q. Before or after you first 23 spoke with Ms. McCawley? 24 A. Before. 25 Q. So then how did you speak Page 28 1 HIGHLY CONFIDENTIAL AEO 2 with Ms. McCawley over the phone? 3 A. On my partner's cell phone. 4 Q. What's his cell phone 5 number? 6 MS. MCCAWLEY: Objection. 7 What's the relevance of her 8 partner's cell phone? 9 Again, this is irrelevant. 10 It's harassing. It's -- you're 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q. What is your partner's cell 19 phone number? 20 MR. GUIRGUIS: I'm directing 21 the witness not to answer. 22 Q. How many hours have you 23 spent speaking with Mr. Pottinger? 24 A. I've been speaking to 25 Mr. Pottinger from November. Page 29 HIGHLY CONFIDENTIAL AEO 2 Q. When in November? 3 A. I can't remember. 4 Q. On your same cell phone that 5 you got rid of? 6 A. No, on my partner's cell 7 phone. 8 Q. And when did you first meet 9 Mr. Pottinger in person? 10 A. It was in the beginning of 11 January. 12 Q. And where was that meeting? 13 A. Barcelona. 14 Q. Where in Barcelona? 15 A. Barcelona. It's Barcelona. 16 We meet -- I can't remember the area. 17 Q. In a restaurant? In a 18 hotel? In an office? 19 A. In a hotel. 20 Q. And how long did you spend 21 with Mr. Pottinger on that occasion? 22 A. Two days. 23 Q. How many hours over the two 24 days? 25 A. Gosh, about 16. Page 30 HIGHLY CONFIDENTIAL AEO 2 Q. How many hours did you spend 3 with Mr. II. MCCAWLEY: Objection. 5 A. The same amount. 6 Q. He was with Mr. Pottinger? 7 A. Yeah, yes. 8 Q. And Mr. Boies, how much time 9 have you spent with Mr. Boies? 10 A. I haven't spent any time 11 with him yet. 12 Q. Have you met him? 13 A. No. 14 Q. Have you spoken to him on 15 the phone? 16 A. No. 17 Q. And you have not paid any 18 money for any of those lawyers' time, 19 correct? 20 A. Yes. 21 Q. In addition to your free 22 legal counsel, were you given anything 23 else in exchange for your agreement to 24 be a witness in this case? 25 MR. GUIRGUIS: Objection. Page 31 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Did you fly over here? 4 A. Yes. 5 Q. From Barcelona? 6 A. Yes. 7 Q. Did you pay for the plane 8 ticket? 9 A. Yes. 10 Q. How much was the plane 11 ticket? 12 A. It was -- I think it was 13 1,000 -- it was 1,000 -- I can't 14 remember the exact total. 15 Q. Has anyone agreed to 16 reimburse you for that? 17 A. No. 18 Q. And you're staying where 19 while you're here? 20 MR. GUIRGUIS: Objection. 21 And direct you not to answer 22 that. 23 Q. Are you staying in a hotel 24 while you're here? 25 MR. GUIRGUIS: You can Page 32 HIGHLY CONFIDENTIAL AEO 2 answer that. 3 A. Yeah. 4 Q. Are you paying for that? 5 MR. GUIRGUIS: Objection. 6 I'm directing you not to 7 answer. 8 MS. MCCAWLEY: You can 9 answer. 10 MR. GUIRGUIS: I think you 11 can answer. 12 MS. MCCAWLEY: Yeah, I think 13 you can answer. 14 MR. GUIRGUIS: That's fine. 15 I agree. 16 MS. MCCAWLEY: You're a 17 nonparty witness. You can answer 18 that question. 19 MS. MENNINGER: Who is -- 20 MS. MCCAWLEY: I am 21 representing Virginia. He is 22 representing the witness. 23 MS. MENNINGER: Well, you're 24 representing the witness as well, 25 right? Page 33 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: I'm not. 3 MS. MENNINGER: Well, did 4 you just tell her she can answer 5 a question? 6 MS. MCCAWLEY: I did. 7 Q. Are you paying for the 8 hotel? 9 A. No. 10 Q. Who's paying for the hotel? 11 A. It's on expenses, I think, 12 of a witness. It's expenses from -- 13 yeah, I don't know, actually. 14 Q. You don't know who is paying 15 for your hotel? 16 A. No. 17 Q. It's not you? 18 A. No. 19 Q. And how much per night is 20 your hotel? 21 A. I have no idea. 22 Q. How long are you staying 23 here on this trip? 24 A. Just for the deposition. 25 Q. Okay. When did you arrive? Page 34 HIGHLY CONFIDENTIAL AEO 2 A. It was Tuesday, late Tuesday 3 night. 4 Q. And when are you leaving? 5 A. Tomorrow evening. 6 Q. In addition to your legal 7 counsel and your hotel, is there 8 anything else you've been given in 9 exchange for your -- 10 A. No. 11 Q. -- to be a witness in this 12 case? 13 You have to wait for me to 14 finish my question before you answer. 15 A. Sorry. 16 Q. Have you been given anything 17 else? 18 A. No. 19 Q. Have you been promised 20 anything else? 21 A. No. 22 Q. Have you been promised that 23 you would have counsel to help you 24 bring a lawsuit against a number of 25 people? Page 35 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: Objection. 3 To the extent this gets into 4 attorney/client privileged 5 information, you're not allowed 6 to answer. 7 Q. Have your lawyers agreed to 8 bring a lawsuit on your behalf against 9 a number of people? 10 A. Yes. 11 Q. And are you paying for that 12 counsel? 13 A. No. 14 Q. Have you reached any 15 agreement about a contingency fee for 16 that case? 17 A. Can you explain what 18 contingency means? Sorry. 19 Q. Do you expect to receive 20 money as a result of that lawsuit? 21 A. II, no. No. 22 Q. You're not asking to receive 23 any money as a result of that lawsuit? 24 A. No. No. 25 Q. All right. So have you had Page 36 HIGHLY CONFIDENTIAL AEO 2 any agreements regarding writing a 3 book -- 4 A. No. 5 Q. -- about your experience? 6 You have to wait for me to 7 finish my question. 8 Have you had any agreements 9 with your lawyers about media rights 10 in any form? 11 MR. GUIRGUIS: Objection to 12 the extent that you're asking 13 about communications with the 14 attorneys. 15 MS. MENNINGER: I'm asking 16 about her arrangement with her 17 attorneys, which is not 18 privileged. 19 A. Can you please repeat the 20 question. 21 Q. Have you reached any 22 agreement with your attorneys 23 regarding media rights for your story? 24 A. No. 25 Q. Have you talked to anyone Page 37 1 HIGHLY CONFIDENTIAL AEO 2 about publishing anything relating to 3 your story? 4 A. Can you repeat the question, 5 please. 6 MS. MENNINGER: Can you read 7 it back. 8 (Requested portion of the 9 record was read back.) 10 A. Yes, I have. 11 Q. Who have spoken to? 12 A. The New York Post. 13 Q. Who at the New York Post? 14 A. Maureen Callahan. 15 Q. And when did you speak with 16 her? 17 A. I think it was later 18 October. 19 Q. Have you spoken with her 20 since? 21 A. No. 22 Q. And how long did you speak 23 to her? 24 A. I spoke to her for, gosh, 25 about 30 minutes on the phone once. Page 38 1 HIGHLY CONFIDENTIAL AEO 2 Q. And what was -- what did you 3 tell her in your phone call? 4 A. I told her what Jeffrey 5 Epstein and Ghislaine Maxwell did to 6 me and the other girls. 7 Q. Did she give you any money 8 in exchange for that interview? 9 A. No. 10 Q. Did she publish anything 11 related to that interview? 12 A. No. 13 Q. How did you get in touch 14 with Ms. Callahan? 15 A. I emailed after I read an 16 article that she had written about 17 Jeffrey Epstein, and the last sentence 18 was -- it was on the 16th of October, 19 and one of the last sentences I 20 remember was, will we ever know the 21 true extent of Jeffrey Epstein's 22 victims. And I wrote her after that 23 because, well, it still continues, 24 doesn't it. 25 Q. Where is the email that you Page 39 HIGHLY CONFIDENTIAL AEO 2 wrote her? 3 A. It's on a it's on my 4 computer. 5 Q. Okay. In your Yahoo 6 account? 7 A. Yes. 8 Q. Did you have any agreement 9 with her to have any additional 10 conversation? 11 A. Yes. 12 Q. And what was that agreement? 13 A. It wasn't an agreement per 14 such. What actually happened was I 15 came forward. As soon as I came 16 forward, there was -- where I live in 17 Barcelona, there's quite a lot -- it's 18 quite busy traffic with people. 19 I came forward to Maureen 20 Callahan. I wanted to tell my story, 21 and I want to run a campaign in which 22 all the girls that have been abused by 23 Ghislaine and Jeffrey can come 24 forward. And I wanted to run a 25 campaign with the New York Post to get Page 40 HIGHLY CONFIDENTIAL AEO 2 these girls to have the courage to 3 come forward, because I know a lot of 4 them are frightened like myself. 5 The email correspondence I 6 had with Maureen Callahan, she was 7 going away or something and she was 8 going to write a piece in the New York 9 Post about my story. During that time 10 it was the elections, so there was a 11 lot more other things going on. 12 There were two people 13 following me after I came forward to 14 Maureen Callahan. I went to -- I 15 walked downstairs. I walked around -- 16 I have a usual routine that I do. In 17 the morning I went out, I saw the same 18 two people. Later on that afternoon, 19 I saw the same two people again. I 20 was frightened. I'm frightened for my 21 life, absolutely frightened. So there 22 you go. 23 So that's what I was -- 24 communication stopped between Maureen 25 Callahan and I. I got really angry Page 41 HIGHLY CONFIDENTIAL AEO 2 with Maureen because she had obviously 3 told someone. Being the New York 4 Post, so, you know. 5 Q. So you had an email to 6 Ms. Callahan and an email back from 7 her? 8 A. Yes. 9 Q. More than one? 10 A. Yes. 11 Q. How many? 12 A. I can't remember. 13 Q. More than ten or less than 14 ten? 15 A. Less than ten. 16 Q. And you had one phone call 17 with her or more than one? 18 A. Just one. 19 Q. And it lasted about 30 20 minutes? 21 A. About that. 22 Q. And was that also on the 23 cell phone that you got rid of? 24 A. That was on my partner's 25 cell phone. Page 42 HIGHLY CONFIDENTIAL AEO 2 Q. And what had you read in the 3 press that caused you to get in touch 4 with Ms. Callahan? 5 MS. MCCAWLEY: Objection to 6 form. Go ahead. 7 A. You can read the article 8 yourself. It's on the 16th of 9 October, there's an article in the New 10 York Post written by Maureen Callahan. 11 You can read it. And that's what 12 inspired me to come forward. 13 Q. What do you recall about 14 that article? 15 A. I can't remember. The 16 one thing I do remember is the last 17 sentence of the article, which has 18 stuck with me and quite prominent, and 19 that is, will we ever know the true 20 extent of Jeffrey Epstein's victims. 21 Q. Do you recall anything else 22 about the article? 23 A. It's just the same. When I 24 read the article, the stuff that I had 25 experienced myself with Jeffrey, it's Page 43 HIGHLY CONFIDENTIAL AEO 2 just same old stuff, just continuing. 3 I thought he had stopped abusing 4 girls. 5 Q. What do you recall reading a 6 article that Jeffrey Epstein was 7 doing? 8 A. I can't remember 9 Q. Anything at all? 10 A. You can read the article. I 11 can't remember. 12 Q. The question is what you 13 remember. 14 A. I can't remember. 15 Q. You remember nothing else 16 about the article 17 MS. MCCAWLEY: Asked and 18 answered objection. 19 Q. -- except it was related to 20 Jeffrey Epstein and it ended with the 21 sentence that you've described? 22 MS. MCCAWLEY: Objection, 23 asked and answered. 24 A. Yes. 25 Q. What do you know about other Page 44 HIGHLY CONFIDENTIAL AEO 2 girls being frightened? 3 A. I know that the girls on the 4 island and in New York during my time 5 with Jeffrey and Ghislaine, that they 6 were frightened. 7 Q. Okay. What are the names of 8 those girls? 9 A. 10 -- I don't know her surname. I can't 11 remember her surname. 12 Q. How do you spell the first 13 name? 14 A. II I'm just taking a 15 guess, , I'm guessing, I 16 think. 17 MR. GUIRGUIS: I'm going to 18 remind the witness I told her not 19 to speculate, but that's okay. 20 Q. In addition to 21 and what are the 22 names of the other girls who you 23 believe are frightened? 24 A. There were a 25 couple other girls I met during my Page 45 1 HIGHLY CONFIDENTIAL AEO 2 time with Ghislaine and Jeffrey that 3 were frightened. 4 Q. What were the names of the 5 girls that you met that were 6 frightened? 7 A. There was 8 And there were two 9 other girls, I can't remember their 10 names. 11 Q. Okay. Please describe them. 12 A. The -- describe all the 13 girls or 14 Q. No. We're talking about the 15 girls that you met on the island that 16 you described as frightened. 17 A. Okay. On the island -- 18 MR. GUIRGUIS: Objection. 19 You seem to be suggesting that 20 all those girls are from the 21 island. I'm not sure that's the 22 testimony. 23 Q. All right. You said girls 24 on the island and in New York who are 25 frightened. I asked you for their Page 46 HIGHLY CONFIDENTIAL AEO 2 names. 3 You gave me three, correct? 4 A. Yes. 5 Q. You said there were two 6 others, correct? 7 A. Mm-hmm. 8 Q. What did those two other 9 girls look like? 10 A. I can't really remember. 11 One had blonde hair; long, blonde 12 hair. 13 Q. Anything else about that? 14 A. I can't remember. 15 Q. The other girl, can you 16 remember her hair color? 17 A. No, I can't remember. 18 Q. Do you know the height of 19 either one of them? 20 A. No, I can't remember. 21 Q. Do you have a photograph of 22 either one of them? 23 A. No. 24 Q. And where did you meet these 25 two other girls? 2 A. In New York. 3 Q. Where in New York? 4 A. I can't remember. 5 Q. You don't know the location 6 at all? Page 47 HIGHLY CONFIDENTIAL AEO 7 A. No. It was ten years ago. 8 Q. Was it in a home or in a 9 commercial setting? 10 A. I met girls commercially and 11 in home settings. 12 Q. Where did you meet these two 13 other girls you described as being 14 frightened? 15 A. I can't remember. 16 Q. What is 's last 17 name? 18 A. I don't know. 19 Q. What does look 20 like? 21 A. She's got long, blonde hair. 22 Q. How long? 23 A. Long, long hair. 24 Q. Longer than your hair now? 25 A. I think so. I think it was Page 48 HIGHLY CONFIDENTIAL AEO 2 longer. 3 Q. So middle of her back? 4 A. I can't -- i can't remember 5 on how long her hair is. 6 Q. Where did you meet 7 A. I met first in New 8 York. 9 Q. Where in New York? 10 A. I can't remember. 11 Q. Anywhere in New York? You 12 can't remember at all? 13 A. I can't remember the 14 location. 15 Q. Was it at Mr. Epstein's 16 home? 17 MR. GUIRGUIS: Objection. 18 You have asked her now almost 20 19 questions about where she met 20 these girls, and she has 21 consistently said that she does 22 not remember. 23 Q. Was it in Mr. Epstein's 24 home? 25 A. No. Page 49 HIGHLY CONFIDENTIAL AEO Q Was it at a club? MR. GUIRGUIS: Are we going 4 5 6 met these two girls? to spend seven hours with her saying I can't remember where she 7 Q. Was it at a club? 8 A. One was at a club. 9 Q. Which one? 10 A. 11 Q. Where did you meet 12 A. I first met 13 island. on the 14 Q. 15 time? Did you meet her a second 16 A. Yes. 17 Q. 18 second time? Where did you meet her the 19 A. I can't remember. 20 Q. State? 21 A. Can't remember. 22 Q. Country? 23 A. Well, U.S. 24 25 THE WITNESS: Sorry, can I have a break? I actually need to Page 50 HIGHLY CONFIDENTIAL AEO 2 go to the bathroom. Sorry. 3 MS. MENNINGER: Yes, I don't 4 think I have a question pending. 5 We'll go off the record now. 6 (Time noted: 9:52 a.m.) 7 (Recess.) 8 (Time noted: 10:07 a.m.) 9 Q. So I want to return to your 10 conversations with Ms. Callahan, 11 conversation with Ms. Callahan. 12 Did you have any further 13 communications with her after the 14 phone call you described? 15 A. There were, I think, a few 16 emails exchanged, but nothing ever 17 came about it. 18 Q. And, again, those are emails 19 from your Yahoo account? 20 A. Yes. 21 Q. Did you ask Ms. Callahan for 22 compensation in exchange for your 23 story? 24 MS. MCCAWLEY: Objection, 25 asked and answered. Page 51 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Had you seen any other 4 stories in the press about Jeffrey 5 Epstein? 6 A. Through the last ten years, 7 I've seen a few articles written about 8 Jeffrey Epstein. 9 Q. What do you recall about 10 those articles? 11 A. The way he used to abuse 12 girls. Basically articles written 13 very similar to my own story -- well, 14 identical, so... 15 Q. And have you written down 16 your story? 17 A. No. 18 Q. Nowhere? 19 A. No. 20 Q. Did you see any articles 21 about 7 22 A. Yes. 23 Q. Which articles did you see 24 about 25 A. I can't remember. It was Page 52 1 HIGHLY CONFIDENTIAL AEO 2 quite some time ago. 3 Q. What do you recall about it? 4 A. She came forward and I 5 was it was a few years ago that she 6 came forward, and her story was 7 exactly the same as mine. 8 I can't remember 9 specifically what article I read, but 10 every single article I did read during 11 the duration of that time, she 12 experienced the same thing I did. 13 So it was more or less the 14 same context and it's the same story 15 in all articles, really. 16 Q. So you were reading these 17 articles over the course of a period 18 of ten years, you think? 19 A. Yeah. I didn't pay much 20 attention to it because I've spent the 21 last ten years trying to get over that 22 experience, and I've been frightened 23 to come forward. 24 Q. And when you read the 25 articles, you noticed that there were Page 53 1 HIGHLY CONFIDENTIAL AEO 2 details that you thought were similar 3 to your experience? 4 MS. MCCAWLEY: Objection. 5 A. They were details that were 6 exactly the same as what I had 7 experienced. 8 Q. Do you know whether anyone 9 else had brought lawsuits against 10 Mr. Epstein? 11 A. No. 12 Q. Did you save any of these 13 articles that you read? 14 A. Sorry, can you repeat that. 15 Q. Did you save any of the 16 articles that you read? 17 A. No. 18 Q. Where did you grow up? 19 A. I grew up in South Africa. 20 I then finished school in Scotland. 21 Q. When did you move to 22 Scotland? How old were you? 23 A. I was 14. 24 Q. Did your family move to 25 Scotland or just you? Page 54 HIGHLY CONFIDENTIAL AEO 2 A. Just myself. 3 Q. Are you a South African 4 citizen? 5 A. Yes. 6 Q. Do you have a South African 7 passport? 8 A. Well, yeah. It was stolen. 9 I'm reapplying for a new one. I have 10 to renew my South African passport. 11 It was stolen. South Africa for you. 12 Q. So when did you get that 13 South African passport? 14 A. I can't remember. I've had 15 a South African passport my whole 16 life, so... 17 Q. And when was it stolen? 18 A. I think it was 2014, 2015. 19 Q. So you were born in South 20 Africa, you're a South African 21 citizen, and you had a South African 22 passport your whole life. 23 Have I got that right? 24 A. Mm-hmm. 25 Q. Yes or no? Page 55 HIGHLY CONFIDENTIAL AEO MR. GUIRGUIS: Objection to form. 4 You can answer. 5 A. Yes. 6 Q. Did you also have a British 7 passport? 8 A. Yes. 9 Q. How did that come about? 10 A. My mom's side of the family 11 is British. 12 Q. And when did you get a 13 British passport? 14 A. I think when I was about 15 five. 16 Q. Do you have a dual 17 citizenship? 18 A. Yes. 19 Q. And do you travel using both 20 passports? 21 A. It's really complicated. I 22 only use my South African passport 23 when I enter into South Africa. So 24 that's the only time I use my South 25 African passport, then. Page 56 HIGHLY CONFIDENTIAL AEO 2 Other than that, I use my 3 British passport for all other 4 transportation. Because South Africa 5 you need, like, a visa; it's really 6 complicated. So I'm lucky I've got a 7 British passport. 8 Q. It's easier to travel on a 9 British passport than a South African 10 passport? 11 A. Yeah, a lot easier. A lot 12 easier. 13 Q. All right. Did you have any 14 siblings growing up? 15 A. Yes. 16 Q. How many? 17 A. I've got one real older 18 brother and then I've got a half 19 younger brother and a half younger 20 sister. 21 Q. Did you all grow up in the 22 same home? 23 A. No. 24 Q. Who did you grow up in the 25 same home with? I don't need their Page 57 HIGHLY CONFIDENTIAL AEO 2 names, but just the people you just 3 described. 4 MR. GUIRGUIS: Objection. 5 You can answer. 6 A. I grew up with my mom and my 7 stepdad, and my brother was just 8 entering boarding school. 9 And then I lived with my 10 auntie and uncle in Scotland. 11 Q. And cousins? 12 A. Yeah, and cousins. One 13 cousin. 14 Q. And how long did you attend 15 school in Scotland? 16 A. About three years. 17 Q. Did you graduate? 18 A. Yep, yes. 19 Q. Is that the equivalent of 20 our high school? 21 A. Yeah, it is. 22 Q. Did you go to college? 23 A. I went to university to 24 study psychology and sociology. 25 Q. Where did you go? Page 58 HIGHLY CONFIDENTIAL AEO 2 A. Queen Margaret University in 3 Edinburgh. 4 Q. Did you graduate? 5 A. No, I didn't. 6 Q. Did you go to that college 7 immediately after graduating from high 8 school? 9 A. No. 10 Q. When did you go to that 11 college? 12 A. 2004. 13 Q. And how long did you stay at 14 Queen Margaret college? 15 A. A year and a half. 16 Q. Why did you leave college? 17 A. I chose the wrong course. I 18 didn't -- I didn't really agree with 19 what I was being taught in sociology, 20 so I quit. 21 Q. During the time you were in 22 college, did you work? 23 A. Yes. 24 Q. Where did you work? 25 A. I was a waitress at a bar. 2 Q. Anything else? 3 A. No. 4 Q. Have you ever been married? 5 A. No. 6 Q. Have you ever been engaged? 7 A. Yes. Page 59 HIGHLY CONFIDENTIAL AEO 8 Q. To whom? 9 A. 10 Q. Your current partner? 11 A. Yes. 12 Q. Anyone else? 13 A. Yes, I have. 14 Q. Who else have you been 15 engaged to? 16 MS. MCCAWLEY: Objection. 17 MR. GUIRGUIS: Objection. 18 A. I don't really see the 19 relevance in that. 20 Q. Who else have you been 21 engaged to? 22 A. 23 Q. Was he listed in your 24 passport? 25 A. Yes. Page 60 1 HIGHLY CONFIDENTIAL AEO 2 Q. Anyone else? 3 A. Listed on my passport? 4 Sorry. 5 Q. Have you been engaged to 6 anyone else? 7 A. II, sorry. I've got a 8 really bad train... No. 9 Q. During what period of time 10 were you engaged to 11 A. I can't remember. 12 Q. Was it before 2006 or after? 13 A. After. 14 Q. How long after? 15 A. Three years. 16 Q. Did you know Mr. 17 during 2006? 18 A. It's, sorry. 19 20 Vaguely, vaguely. We lost 21 contact. 22 Q. When did you lose contact? 23 A. In 2006. 24 Q. And when did you reestablish 25 contact? Page 61 HIGHLY CONFIDENTIAL AEO 2 A. 2008. 3 Q. Do you go by any other 4 names? 5 A. No. 6 Q. Do you go by 7 online? 8 A. I don't think so. I don't 9 know. 10 Q. On Twitter? 11 A. I don't have any social 12 media platforms, so I can't remember. 13 Q. Have you ever gone by 14 , all one word, on 15 Twitter? 16 A. I can't remember. 17 Q. Do you have any tattoos? 18 A. Yes. 19 Q. Where? 20 A. One here. 21 Q. Indicating on your arm? 22 A. Indicating on my arm, sorry. 23 No camera. 24 Yes, I have one, two, three 25 four. Page 62 HIGHLY CONFIDENTIAL AEO 2 Q. Where is the second one? 3 A. I've got four. 4 Q. All right. Just tell me 5 where they are. 6 A. One is on my arm, one is on 7 my right hip, one's on my upper bikini 8 line on my right inner thigh, and I've 9 got one on my left side on my rib 10 cage. 11 Q. Okay. Have you had them for 12 a long time? 13 A. I've had -- hang on. Two I 14 have had for a long time. 15 Q. Which ones are they? 16 A. The scorpion on my right hip 17 and my Leo symbol on my bikini line. 18 Q. Have you ever obtained a 19 college degree? 20 A. No. 21 Q. Have you ever gone back to 22 college? 23 A. I have tried to. I wanted 24 to. 25 Q. When did you do that? Page 63 HIGHLY CONFIDENTIAL AEO 2 A. When I moved to New York. 3 Q. In 2006? 4 A. Correct. 5 Q. Any other time? 6 A. Well, recent. I mean, I'm 7 going back to university next year, so 8 I'm currently relooking at colleges. 9 I'm going back to do my psychology 10 degree. 11 Q. Where? 12 A. I haven't decided yet 13 because I'm looking for an open degree 14 -- well, sorry, home learning, so I 15 haven't found somewhere yet. But I'm 16 currently going -- well, my aim is to 17 go back to university and get 18 qualified. 19 Q. Between 2006 and today, have 20 you applied to any other colleges? 21 A. No. 22 II, yes. Sorry, can you 23 repeat the question? Sorry. 24 MS. MENNINGER: He can read 25 it back. Page 64 HIGHLY CONFIDENTIAL AEO 2 A. Yes. Yes. 3 Q. Okay. When did you apply to 4 colleges between 2006 and today? A. It was 2006. 6 Q. Is that FIT? A. That's correct. Q. Anywhere else? 9 A. No. 10 Q. Other than working as a 11 waitress at a bar during college in 12 2004-2005, what other employment have 13 you had? 14 A. I have worked in 15 hospitality. I've worked in 16 superyachting, those wealthy people 17 that have superyachts. I used to work 18 for them. I have done modeling. And 19 I can't remember any... 20 Q. Did you have a modeling 21 agent? 22 A. I did in Scotland. 23 Q. In college? 24 A. Mm-hmm, that's correct. 25 Q. Any other time? Page 65 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. And what type of modeling 4 was that? 5 A. Just commercial. 6 Q. Print? 7 A. Yep. 8 Q. Runway? 9 A. Yep. 10 Q. TV or ads? 11 A. No. 12 Q. And all in Scotland? 13 A. No. 14 Q. Where else did you model? 15 A. New York. 16 Q. Anywhere else? 17 A. No. 18 Q. London? 19 A. II, yeah, I did, sorry. I 20 did do modeling, a bit of modeling in 21 London. 22 Q. All right. When did you do 23 modeling in New York? 24 A. During -- when I first 25 arrived in New York in 2006. Page 66 HIGHLY CONFIDENTIAL AEO 2 Q. How much money did you make 3 as a model? 4 MR. GUIRGUIS: Objection. 5 A. I can't remember. 6 Q. When did you work in 7 superyachting? 8 A. I can't remember. About 9 2011. About 2011. 10 Q. And when did you work in 11 hospitality? 12 A. I've worked in hospitality 13 my whole life. I've worked in -- I 14 mean, hospitality, I've either done 15 bar work, waitressing, superyachting, 16 yeah. 17 Q. So on and off? 18 A. Yeah, on and off. 19 Q. And since you were an adult? 20 A. And since I was an adult, I 21 worked in corporate jobs as well. 22 Q. Where did you work in 23 corporate jobs? 24 A. In South Africa. 25 Q. And just so I understand, Page 67 HIGHLY CONFIDENTIAL AEO 2 you lived in Scotland from the ages of 3 14 to 22? 4 A. That's correct. 5 Q. And then where did you move? 6 A. To New York. 7 Q. And how long did you live in 8 New York? 9 A. About seven, eight months. 10 Q. And where did you move? 11 A. Back in London. 12 Q. And how long did you live in 13 London? 14 A. Well, I lived in the UK. 15 Because I moved around a few times, so 16 I didn't just specifically live in 17 London. But I was in the UK about 18 2012. 19 Q. And then where did you move? 20 A. I then went into the 21 superyachting industry, so I didn't -- 22 I lived on a boat in Italy and south 23 of France. 24 Q. Did you work for a company? 25 A. I worked for a private Page 68 HIGHLY CONFIDENTIAL AEO 2 owner. 3 Q. On one yacht? 4 A. On multiple yachts. 5 Q. And what was your job? 6 A. Stewardess -- stewardess, 7 and then I was a deckhand. 8 Q. With wine? 9 A. Sorry? 10 Q. What's a decant? 11 A. A deckhand. 12 MS. MCCAWLEY: D-E-C-K. 13 THE WITNESS: Sorry. 14 15 deckhand. I thought you were 16 decanting wine. It's a pretty 17 good job. 18 Q. Who is the owner of the 19 ship? 20 A. I'm not allowed to specify. 21 Q. Do you have a 22 confidentiality agreement? 23 A. I did sign a confidentiality 24 agreement when I started employment. 25 Q. And how long were you Page 69 HIGHLY CONFIDENTIAL AEO 2 employed in superyachting? 3 A. Two and a half years. 4 Q. Okay. And what did you do 5 after that? 6 A. I moved back to Cape Town. 7 Q. So that was in 2014? 8 A. I can't remember the 9 specific dates or year. 10 Q. Between 2014 and 2016? 11 A. I've moved 47 times, so I 12 can't remember. 13 Q. You can't remember what year 14 you moved back to Cape Town? 15 A. No. 16 Q. Okay. And who did you live 17 with when you moved back to Cape Town? 18 A. Myself. 19 Q. And how long did you live 20 there? 21 A. Four years. 22 Q. And you, when did you move 23 after that? 24 A. December. Yeah, it was 25 December 2015. Sorry. It was Page 70 1 HIGHLY CONFIDENTIAL AEO 2 December 2015. 3 Q. Where did you move? 4 A. I moved from Cape Town to 5 London. 6 Q. And how long did you live 7 there? A. Three months. 9 Q. And then where did you move? 10 A. Barcelona. 11 Q. So in March 2016? 12 A. Sorry, no, just hang on. 13 Sorry. I moved to Barcelona around 14 June, June last year. 15 Q. 2016 June? 16 A. Yeah. 17 Q. You moved to Barcelona? 18 A. Yeah. 19 Q. When you came to the U.S., 20 you said that was in 2006? 21 A. Correct. 22 Q. And who did you come with? 23 A. Myself. 24 Q. And who paid for your plane 25 ticket? Page 71 HIGHLY CONFIDENTIAL AEO 2 A. Myself. 3 Q. Why did you come? 4 A. I wanted to advance my 5 career. 6 Q. What year? 7 A. I wanted to go to FIT 8 university. 9 Q. Did you have a student visa 10 when you came in 2006? 11 A. No. 12 Q. Had you applied to FIT when 13 you came to New York in 2006? 14 A. No. 15 Q. Did you have a job when you 16 came here in 2006? 17 A. No. 18 Q. Where did you stay when you 19 got here in 2006? 20 A. The Upper East Side. 21 Q. With whom? 22 A. It was just a housemate, 23 house. 24 Q. What was that person's name? 25 A. Page 72 HIGHLY CONFIDENTIAL AEO 2 Q. How do you spell 3 A. 4 Q. And what's the last name of 5 6 A. I can't remember. 7 Q. Male or female? 8 A. Male. 9 Q. How old? 10 A. I think he was in his 40s. 11 Q. And how did you meet 12 A. I met just via -- I 13 met him when -- why can't I remember? 14 I think, yeah, I was looking for an 15 apartment when I got here so it was 16 just a -- like, we just kind of met on 17 the Upper East Side and, yeah, I said 18 I was looking for somewhere to stay. 19 Q. Did you pay rent? 20 A. Yes. 21 Q. How much did you pay? 22 A. I can't remember. 23 Q. A thousand dollars? 24 MR. GUIRGUIS: Objection. 25 A. I think it was less than Page 73 HIGHLY CONFIDENTIAL AEO 2 that. 3 Q. Did you have your own 4 bedroom? 5 A. No. 6 Q. Was the only other 7 occupant? 8 A. There was another guy. 9 Q. Did you share a bed with 10 anyone at that house? 11 A. With 12 Q. Were you in a relationship 13 with 14 A. No. 15 Q. You slept in a bed with 16 in the apartment on the Upper 17 East Side? 18 A. That's correct. 19 Q. What was the address of that 20 apartment? 21 A. I can't remember. 22 Q. Do you have any way of 23 reaching now? 24 A. No, no, I don't. 25 Q. Do you know approximately Page 74 HIGHLY CONFIDENTIAL AEO 2 where in New York it was besides the 3 Upper East Side? 4 A. I just remember it being in 5 the Upper East Side. I can't remember 6 the exact location. 7 Q. Any of the cross-streets? 8 A. I went there the other day, 9 and it looks -- it looks familiar. I 10 can't -- I can't remember 11 specifically. 12 Q. You went to the apartment 13 the other day? 14 A. No, I didn't go to the 15 apartment the other day. I went to 16 the Upper East Side yesterday -- the 17 other day, sorry. But I can't 18 remember where the apartment was, no. 19 Q. Was it a walkup or a doorman 20 or elevator kind of building? 21 A. It was an elevator building. 22 Q. Was there a doorman? 23 A. No. 24 Q. What floor were you on? 25 A. I can't remember. Page 75 HIGHLY CONFIDENTIAL AEO 2 Q. And you don't remember how 3 you met 4 MR. GUIRGUIS: Objection. 5 A. I met loads of people during 6 that time. I can't specifically 7 remember how I met every individual. 8 Q. And in the same house, there 9 was and another guy? 10 A. That's correct. 11 MS. MCCAWLEY: Objection, 12 misstates 13 Q. Do you remember the other 14 guy's name? 15 A. I can't remember. 16 Q. How long did you live with 17 and the other guy? 18 A. For a -- I think it was a 19 couple months until I moved. 20 Q. And where did you move? 21 A. To Jeffrey Epstein's 22 apartment 23 Q. What was the address to 24 that? 25 A. I think it was 2000 - Page 76 HIGHLY CONFIDENTIAL AEO 2 sorry -- 205 East. It was Midtown 3 somewhere. 4 Q. I'm sorry, what? 5 A. It was sort of Midtown. I'm 6 not familiar with New York because I 7 haven't been here and I don't live 8 here. It was kind of Midtown, his 9 apartment. 10 Q. Okay. 11 A. If I recall, yeah. 12 Q. So it's 205 East something? 13 A. It's East -- it's East 14 something. It was the same -- it was 15 the same apartment building that 16 lived in, because we lived in the same 17 building. 18 Q. Did you live in the same 19 apartment? 20 A. No. 21 Q. Did you have your own 22 apartment? 23 A. Yes. 24 Q. How big was the apartment? 25 A. It was massive. Page 77 HIGHLY CONFIDENTIAL AEO 2 Q. How many bedrooms did it 3 have? 4 A. I can't remember. I can't 5 remember. I can't -- 6 Q. Two or seven? 7 A. I just -- I remember just 8 the -- like, the living room, and it 9 was very spacious. 10 Q. Can you draw a picture of 11 the layout of it? 12 A. I wouldn't remember the 13 layout. There was -- I remember like 14 a pale blue decor. 15 Q. And no one else lived there 16 with you? 17 A. No. 18 Q. And you don't know how many 19 bedrooms? 20 A. I can't remember how many 21 bedrooms there were. 22 Q. Was there a doorman? 23 A. I can't remember. 24 Q. Was it a walkup or elevator? 25 A. Elevator. Page 78 HIGHLY CONFIDENTIAL AEO 2 Q. What floor were you on? 3 A. I can't remember. 4 Q. Approximately when did you 5 move into this apartment? 6 A. It was not long after I 7 moved in with About two 8 months, I think. About two months, I 9 think, roughly. 10 Q. So you lived with for 11 about two months and then you moved 12 into this other apartment? 13 A. That's correct. 14 Q. And how much were you paying 15 for this new apartment? 16 A. II, it was Jeffrey's. I 17 didn't pay a single thing. 18 Q. And who else lived in the 19 apartment building? 20 A. Quite a -- gosh. A few, 21 actually. I recall 22 Q. Do you know last 23 name? 24 A. I can't remember her last 25 name, last name. Page 79 HIGHLY CONFIDENTIAL AEO 2 Q. Okay. Who else? 3 A. There were a few other 4 girls. I can't remember their names. 5 Q. None of them? 6 A. No. It was a long time ago. 7 Q. What did they look like, 8 these other names you can't remember? 9 A. I can't remember. There 10 were so many. There were so many 11 girls, a constant influx of girls. 12 Q. How many? 13 MS. MCCAWLEY: Objection. 14 A. I can't remember. 15 Q. 50? 16 MR. GUIRGUIS: Objection. 17 A. I can't remember. 18 Q. A hundred? 19 MR. GUIRGUIS: Objection. 20 A. I can't remember. 21 Q. Can you say if it was more 22 than a thousand or less? 23 MR. GUIRGUIS: Objection. 24 A. I can't remember. 25 Q. You can't remember if it was Page 80 HIGHLY CONFIDENTIAL AEO 2 more than a thousand? 3 A. I can't remember. 4 MR. GUIRGUIS: Objection. 5 MS. MCCAWLEY: Objection. 6 This is harassing. 7 MR. GUIRGUIS: Objection. 8 We're crossing a line here. 9 MS. MENNINGER: Okay. I'm 10 asking if she can remember if it 11 was more than a thousand or less. 12 MS. MCCAWLEY: But you 13 haven't defined it. You're not 14 saying where. In the apartment? 15 In general when she met with 16 Jeffrey? I mean -- 17 MS. MENNINGER: I'm asking 18 her -- she said there were so 19 many women that were influx in 20 the apartment, and I'm asking how 21 many. 22 MS. MCCAWLEY: She didn't 23 say in the apartment. Go back 24 and look at the testimony. 25 THE WITNESS: In the Page 81 HIGHLY CONFIDENTIAL AEO 2 building. 3 Q. Right. In the building. 4 How many females did you meet in the 5 building? 6 MR. GUIRGUIS: Objection. 7 A. I can't remember. 8 Q. And can you say it was more 9 or less than one thousand? 10 MR. GUIRGUIS: Objection. 11 A. It was less than a thousand 12 girls. 13 Q. Was it less than a hundred? 14 A. Yes, it was less than a 15 hundred. 16 Q. Was it less than 50? 17 A. I can't remember. 18 Q. Apart from can you 19 name any other one of the females that 20 you met in the apartment building? 21 MR. GUIRGUIS: Objection. 22 A. I can't remember. 23 Q. Can you describe any of 24 them? 25 MR. GUIRGUIS: Objection. 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember. 3 Q. Did you do any employment Page 82 4 while you were here in the U.S. in the 5 fall of 2006? 6 MR. GUIRGUIS: Objection. 7 A. I did freelance modeling. 8 Q. Who did you do that for? 9 A. Various photographers. 10 Q. Do you have those 11 photographs still? 12 A. No. 13 Q. Do you have a portfolio? 14 A. I used to have one. 15 Q. Do you currently have a 16 modeling portfolio? 17 A. No. 18 Q. Do you have any of your 19 modeling photos? 20 MS. MCCAWLEY: Objection, 21 asked and answered. 22 A. Yeah, I got a couple. 23 Q. Where are they? 24 A. At home. 25 Q. In Barcelona? Page 83 HIGHLY CONFIDENTIAL AEO 2 A. That's correct. 3 Q. Are they on a computer? 4 A. No. 5 Q. When you came to the U.S. in 6 the fall of 2006, was there a limit on 7 how long you could stay here? 8 MR. GUIRGUIS: Objection. 9 A. Yes, there was. 10 Q. What was that? 11 A. It was a three-month tourist 12 visa. 13 Q. Were you permitted to be 14 employed while you were here on a 15 tourist visa? 16 MR. GUIRGUIS: Objection. 17 Hold on a second. 18 MS. MENNINGER: I don't know 19 what kind of visa she was on. 20 I'm just asking the question. 21 MR. GUIRGUIS: I don't -- I 22 don't know why her visa status is 23 relevant or why we're going to 24 get into things that 25 might be interested in, so I'm Page 84 HIGHLY CONFIDENTIAL AEO 2 not going to have her sit here 3 and testify about whether she was 4 complying with immigration law or 5 not. 6 MS. MENNINGER: Is she 7 taking the Fifth Amendment? 8 MR. GUIRGUIS: I'm just not 9 sure that you need to ask the 10 question. 11 MS. MENNINGER: Well, I did 12 ask the question. I want to know 13 if she was permitted, on the type 14 of visa she came in on the fall 15 of 2006, to engage in paid 16 employment. 17 MR. GUIRGUIS: Okay. Now 18 that I hear the question, you can 19 answer it if you know the answer. 20 A. No. 21 Q. No, you were not permitted 22 to do paid employment, correct? 23 A. That's correct. 24 Q. You did paid employment 25 while you were here on the tourist Page 85 HIGHLY CONFIDENTIAL AEO 2 visa, correct? 3 A. I wouldn't quite say 4 kind of -- I wasn't that great at it, 5 so I didn't make a lot of money doing 6 modeling. I was too fat, apparently. 7 So I wouldn't say I milked the bank 8 there. 9 (An off-the-record 10 discussion was held.) 11 A. Milked the bank with my 12 modeling -- amazing modeling career. 13 Q. So you came over in order to 14 further your education, I think you 15 testified to earlier, correct? 16 A. That's correct. 17 Q. So while you were here 18 during those three months -- was it 19 three months you said, at first, on 20 the tourist visa? Correct? 21 A. Yes, yeah. 22 Q. When you were here those 23 first three months, what did you do to 24 further your education? 25 A. I started looking at Page 86 HIGHLY CONFIDENTIAL AEO 2 universities or colleges, researching 3 what was the right one for me to go 4 to. 5 By that stage, I -- I've 6 always been interested in the fashion 7 industry, designing, clothes 8 designing. And New York was -- well, 9 this is the place to be for it. 10 So, yeah, I did quite a lot 11 of research on which university, what 12 kind of people were there and 13 etcetera, so... 14 Q. How were you supporting 15 yourself while you were living in New 16 York during the three-month period 17 after you initially arrived? 18 A. I had some savings. 19 Q. Was your family providing 20 you any money? 21 A. No. 22 Q. Apart from your savings, was 23 there any other source of income 24 during October or so of 2006? 25 A. I did the occasional, I Page 87 HIGHLY CONFIDENTIAL AEO 2 guess, job where I was called to 3 entertain or spend time with people, 4 but that was about it. 5 Q. What does that mean? 6 A. Well, I don't really like to 7 use the word per se, because you guys 8 kind of, in your legal minds, have it 9 in a box of what you think it is. 10 But, like, once or twice, I 11 was paid to spend dinner with a 12 gentleman during that time. 13 Q. And how did you meet the 14 gentleman? 15 A. It was through an agency. 16 Q. What was the name of the 17 agency? 18 A. I can't remember. 19 Q. Do you know where it was 20 located? 21 A. No. 22 Q. Do you know how much you 23 were paid to spend dinner time with a 24 gentleman? 25 A. It depended how long the Page 88 1 HIGHLY CONFIDENTIAL AEO 2 dinner was for. 3 Q. And what was the most that 4 you recall making for spending dinner 5 with a gentleman? 6 A. \$1,500. 7 Q. Did you engage in any sexual 8 relations with the gentleman? 9 A. One, yeah, once or twice, 10 but it was on my own accord. It was 11 after that time period had finished. 12 Q. What time period? 13 A. My appointment, my dinner 14 with them. 15 Q. Okay. 16 A. He just happened to be 17 really good looking. 18 MR. GUIRGUIS: It's been 19 about an hour. Maybe we can take 20 five minutes, stretch. 21 MS. MENNINGER: Sure. 22 (Time noted: 10:47 a.m.) 23 (Recess.) 24 (Time noted: 11:05 a.m.) 25 Q. Approximately how many times Page 89 HIGHLY CONFIDENTIAL AEO 2 do you recall being paid to spend 3 dinner with a gentleman in New York 4 when you were living here in late 5 2006? 6 A. I can't remember. 7 Q. Ten times? 8 MR. GUIRGUIS: Objection. 9 A. It could be, it wasn't -- 10 yeah, it could be that. It wasn't 11 really... 12 Q. Apart from that income, did 13 you have any other sources of income? 14 MR. GUIRGUIS: I'm sorry. 15 Off the record for a second. 16 (An off-the-record 17 discussion was held.) 18 MS. MENNINGER: I think 19 there's a question pending. 20 (Requested portion of the 21 record was read back.) 22 A. Yes, I did, yes. 23 Q. What were the other sources? 24 A. Jeffrey Epstein. 25 Q. Any other source? Page 90 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Who introduced you to 4 Jeffrey Epstein? 5 A. 6 Q. And how did you meet 7 8 A. I met her in a nightclub. 9 Q. Do you know which nightclub? 10 A. I can't remember the exact 11 name. It was a rock club. The owner 12 of the club, his name is Yeah, 13 his name -- it's quite a well-known 14 club. If you Google the name 15 you'll find the name. the 16 nightclub owner; he's quite famous in 17 New York. 18 Q. Do you know where in New 19 York the club is located? 20 A. I can't remember. I don't 21 know the exact location. 22 Q. Were you there socially or 23 were you working? 24 A. Socially. 25 Q. And were you with anyone? Page 91 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection. 3 A. I can't remember. I would 4 have been with an acquaintance or 5 something, but I can't remember who I 6 was with. 7 Q. Were you able to make some 8 friends with people here in New York 9 when you moved here? 10 A. Yes. 11 a girl named 12 There were a few other -- I can't 13 remember their they weren't close 14 friends, they were just acquaintances. 15 You don't really make friends in New 16 York. 17 Q. Tell me about your meeting 18 of 19 A. She was a very attractive 20 girl, I think Very 21 friendly, very beautiful girl, very -- 22 we clicked immediately. 23 Yeah. She approached me. I 24 wasn't -- yeah, I didn't go out of my 25 way to meet any friends in a Page 92 HIGHLY CONFIDENTIAL AEO 2 nightclub, so -- especially girls. 3 Q. What do you mean, she 4 approached you? 5 A. So when I go to a club, I 6 don't really speak to girls. I speak 7 to guys. So approached me and 8 came on to me. 9 Q. Where were you? 10 A. In the nightclub. 11 Q. Where in the nightclub? 12 A. I can't -- I can't remember 13 the exact location. 14 Q. Were you at the bar area? 15 On the dance floor? In the bathroom? 16 A. I would say she pretty much 17 hit on me everywhere in the club. 18 Q. Was there a dance floor? 19 A. Yes, there was. 20 Q. Was it a one floor club or 21 two floors? 22 A. I can't remember how many 23 floors. 24 Q. And what did she do to hit 25 on you? Page 93 HIGHLY CONFIDENTIAL AEO 2 A. She befriended me, she -- 3 yeah, she kissed me. 4 Q. Where did she kiss you? 5 A. On the mouth. 6 Q. Anywhere else? 7 A. Can -- is that in general or 8 at that -- 9 Q. I'm just talking about the 10 first time you met. 11 A. The first time we met? 12 Q. Right. 13 A. I can't remember if we had 14 sex the first night we met, but we 15 definitely were intimate the first 16 time we met. But I can't remember if 17 we had had sex on that first night. 18 Q. Okay. Was that consensual 19 sex? 20 A. Yes, it was with 21 22 Q. And where did you have 23 consensual sex with 24 A. In the club the first time. 25 Q. Where in the club? 2 A. In the owner's office. 3 Q. Was the owner present? 4 A. Yes, the owner was present. 5 Q. HIGHLY CONFIDENTIAL AEO Page 94 6 A. Is that I don't know his 7 surname, so -- is it -- -- I can 8 give you a description of if you 9 want. 10 Q. Sure. 11 A. 12 13 14 15 16 Q. Okay. So you and 17 and had consensual sex in 18 office? 19 MR. GUIRGUIS: Objection. 20 MS. MCCAWLEY: Objection. 21 Q. Is that right? 22 A. That's correct. 23 Q. Did I get that wrong in any 24 way? 25 MR. GUIRGUIS: Here's the Page 95 HIGHLY CONFIDENTIAL AEO 2 question. 3 A. Yeah, that's correct. 4 Q. Was anyone else present? 5 A. No. 6 Q. Did you have any alcohol 7 that night? 8 A. I did. 9 Q. How much? 10 A. Not enough to forget or 11 black out, so not much. I was able to 12 make decisions. 13 Q. Do you recall what you were 14 wearing? 15 A. No, I don't. 16 Q. Did you have any cocaine 17 that night? 18 A. I don't remember. 19 Q. Did you use cocaine during 20 the fall of 2006? 21 A. Yes, I did. 22 Q. And where did you get that 23 cocaine? 24 A. From and 25 Q. Anywhere else? Page 96 HIGHLY CONFIDENTIAL AEO 2 A. From 's best friend, a 3 guy named I don't 4 know how to spell that. 5 Q. Anywhere else? 6 A. No. 7 Q. Did you pay for any of the 8 cocaine? 9 A. No. 10 Q. Did you use any other 11 controlled substances in the fall of 12 2006? 13 A. No. 14 Q. Did you take any 15 prescriptions in the fall of 2006? 16 A. I did. 17 Q. What did you take? 18 A. Jeffrey's psychiatrist 19 prescribed me lithium, Ritalin, and 20 there was a bipolar description drug 21 that was also prescribed to me by 22 Jeffrey Epstein's psychiatrist. I 23 can't remember the exact name of that 24 bipolar drug. But I was started off 25 with lithium and Ritalin. Page 97 1 HIGHLY CONFIDENTIAL AEO 2 Q. Okay. What was the name of 3 the psychiatrist? 4 A. I can't remember her name. 5 Q. It was a woman? 6 A. It was a woman. 7 Q. And where was she located? 8 A. I can't -- I can't remember 9 the exact location of her office. 10 Q. Can you describe the office 11 in any way? 12 A. I can't remember. 13 Q. Did anyone go with you? 14 A. No, I went on my own. 15 Q. Where did you go to get your 16 prescriptions filled? 17 A. A pharmacy near Jeffrey 18 Epstein's apartment that I was living 19 in at the time. I think it was a 20 Duane Reade. 21 Q. Were they in your name? 22 A. Yes, they were. 23 Q. Were you taking these in the 24 fall of 2006 or in 2007 or both? 25 A. Jeffrey first put me in Page 98 HIGHLY CONFIDENTIAL AEO 2 touch with his psychiatrist, it was 3 before -- it was -- yeah, it was well 4 before December, so it was the fall 5 of -- fall/winter, going into winter 6 2006. 7 Q. Do you recall what month you 8 came to the U.S.? 9 A. It was September 2006. 10 Q. Did you leave and come back 11 in October? 12 A. I think I may have. I may 13 have made a trip to London or like a 14 quick, brief trip. 15 Q. Who paid for that? 16 A. I can't remember. 17 Q. Why did you go back? 18 A. I actually can't even 19 remember why I went back. 20 Q. So you think you came in 21 September? 22 A. I know I came in September. 23 Q. And you said you could stay 24 for three months? 25 A. And then I left the country Page 99 1 HIGHLY CONFIDENTIAL AEO 2 briefly for a day and then I came back 3 in again. 4 Q. When did you do that? 5 A. So if you look at my 6 passport when I entered -- you've got 7 my passport. So I arrived on the 1st, 8 I think, of September, and then it was 9 just before the three months were up, 10 and then I left. 11 I think that was the trip 12 that I made to London in -- October, 13 November -- October, November -- yeah, 14 so I was -- I left before the due time 15 that my tourist visa was up, and I 16 spent a summer and came back. 17 Q. Where did you go? 18 A. I think it was London. I 19 went to -- I went to London. And then 20 Jeffrey paid for a flight for me to 21 visit my family in South Africa in 22 February. 23 Q. Okay. So there's two trips 24 to London we're talking about? 25 There's one you went and you came Page 100 1 HIGHLY CONFIDENTIAL AEO 2 right back? 3 A. I only recall one trip to 4 London. I didn't really kind of 5 catalog every trip I made. I did a 6 lot of traveling during my time in the 7 U.S., so... 8 Q. Had you traveled a lot 9 before you came to the U.S.? 10 A. Yeah. I spent my whole life 11 traveling. 12 Q. How were you able do that? 13 A. Through savings, through 14 waitressing jobs, that kind of thing. 15 Q. Did your family ever pay for 16 you to go on trips? 17 A. No. 18 Q. Never? 19 A. No. 20 Q. Does your family travel? 21 A. Yeah, they travel. They go 22 on holidays overseas. They go on 23 holidays. 24 Q. So you said you got a 25 passport your whole life, I think you Page 101 1 HIGHLY CONFIDENTIAL AEO 2 said, right? 3 A. Well, I can't remember the 4 specific date when -- I was like from 5 3 to 5 when I got my passport. I 6 didn't arrange my passport at 3 years 7 old; my mom kind of did that. 8 So I've always grown up with 9 a British and South African passport. 10 I had dual nationality right from the 11 get-go. 12 Q. Right. So when you were a 13 child, did you travel internationally? 14 A. Yeah, I did, to visit my 15 family in Scotland. 16 Q. And apart from the UK and 17 South Africa, did you go anywhere as a 18 child? 19 A. We went on holidays and 20 Africa. Maybe I went to Scotland to 21 visit my family, yeah, possibly. I 22 don't remember. 23 Q. Okay. 24 A. They weren't photo-happy in 25 my family. Page 102 1 HIGHLY CONFIDENTIAL AEO 2 Q. They were what? 3 A. They weren't photo-happy, 4 so.. . 5 Q. So back in the fall 2006, 6 you were here for three months and 7 then you left -- 8 A. Yeah. I didn't want to go 9 over my visa and get in trouble, and I 10 wasn't making much money anyway. And 11 Jeffrey was with FIT, so he was going 12 to organize me a visa so I could stay. 13 So I didn't do anything 14 wrong or illegal with my visa, just to 15 clarify. 16 Q. I understand. I'm just 17 trying to get the timing of when you 18 were here and then you left and then 19 you came back; is that right? 20 A. So the duration that I was 21 here, I arrived in September and I 22 left -- I think it was the 1st of May. 23 So during that time, there 24 was a trip that I made to South Africa 25 to visit my family and there was a Page 103 1 HIGHLY CONFIDENTIAL AEO 2 trip to London. I don't recall -- I 3 don't remember any other trips that I 4 made during that duration of time, 5 away from Jeffrey and Ghislaine, if 6 you understand, on my independent own. 7 Q. Right. So if you came in 8 September and you could stay for three 9 months -- 10 A. Mm-hmm. 11 Q. So you left in December? 12 MS. MCCAWLEY: Objection, 13 asked and answered. 14 A. September, October, 15 November. Yeah, I did -- I did make a 16 trip to -- I don't recall the specific 17 dates, but I did make a trip to London 18 and I did make a trip to South Africa 19 in February. So I don't... 20 Q. Did you go from London to 21 South Africa? 22 A. I don't remember the exact 23 trip itinerary. But, yeah, I flew to 24 South Africa on a plane. 25 Q. From London? Page 104 HIGHLY CONFIDENTIAL AEO 2 A. From New York. 3 Q. Okay. So you recall having 4 been on two trips independently 5 between September 2006 and May 2007, 6 right? One to London and one to South 7 Africa? 8 A. Yeah, that's correct. 9 Q. And the one to London, you 10 recall being a brief trip to then 11 allow you to stay in the country 12 longer? 13 A. I don't remember why I went. 14 I don't even remember the trip, okay? 15 I really don't recall. I probably 16 visited my mom or -- or whatever. I 17 just know that I made two trips during 18 that duration and I know that I did 19 not over go the three-month thing. So 20 I made those for those specific 21 reasons. 22 Q. Okay. 23 A. But those -- I just wanted 24 to make clear that those were the only 25 two trips I made independently without Page 105 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey aiding, and I would like to 3 make that clear. I made multiple 4 trips with Jeffrey, so independently I 5 did those two. 6 Q. Were any of your trips with 7 Jeffrey international? 8 A. No. 9 Q. Can you tell me when in your 10 stay in the U.S. you initially met 11 12 A. It was pretty soon after I 13 arrived. I can't remember the exact 14 time frame. I think it was about 15 maybe two, three weeks after I 16 arrived. 17 Q. Were you living at 's? 18 A. Yes. 19 Q. Did you consider yourself in 20 a relationship with 21 A. No, we were just having fun. 22 And she was -- she was really 23 friendly, and I didn't know anyone in 24 New York, so -- and, you know, I 25 wanted to make friends. She was a Page 106 1 HIGHLY CONFIDENTIAL AEO 2 girl and was just very friendly, 3 pretty. 4 Q. Was she also involved in the 5 fashion industry at all? 6 A. I don't recall. I just 7 recall her working for Jeffrey. 8 Q. What did you observe her 9 doing for Jeffrey? 10 A. The exact same thing she did 11 with me. She recruited me and was 12 paid for it. 13 Q. Okay. Did you see her get 14 paid? 15 A. No. 16 Q. How do you know she got 17 paid? 18 A. The girls told me. 19 Q. Who were the girls? 20 A. I can't remember their 21 names. 22 Q. Okay. So the girls told 23 you're that got paid by 24 Jeffrey? 25 A. That's correct. Page 107 1 HIGHLY CONFIDENTIAL AEO 2 Q. So what did you see 3 do for Jeffrey? 4 A. Well, she recruited me. I 5 think she recruited other girls for 6 Jeffrey. 7 Q. Did you see her do that? 8 A. No, but I met some of the 9 other girls that had been introduced 10 to Jeffrey and Ghislaine via 11 Q. Got it. 12 So you were recruited by 13 correct? Yes or no. 14 A. Yes. 15 Q. And you met other girls who 16 knew and Jeffrey, correct? 17 A. Well, all the girls knew 18 each other, really. All the girls 19 kind of... 20 Q. Are these the same girls 21 that are in the apartment building or 22 a different set of girls? 23 A. Different set of girls. 24 Q. Okay. 25 A. You know, there was a Page 108 1 HIGHLY CONFIDENTIAL AEO 2 constant flow of women, girls. 3 Q. So where did you see these 4 other girls? 5 A. In Manhattan, with Jeffrey, 6 a few social occasions that we went 7 on, the island. On the plane, Jeffrey 8 Epstein's plane. I met girls 9 everywhere -- every time I went with 10 Jeffrey. Well, not every time, but he 11 was always surrounded by new girls. I 12 couldn't keep up with the names, to be 13 honest. That's why I can't remember 14 any of them. 15 Q. Getting back to you 16 met her at the nightclub? 17 A. Mm-hmm. 18 Q. Did she work as a model at 19 all? 20 A. I wasn't quite clear what 21 she actually did, to be honest. I 22 have absolutely no idea. 23 Q. Do you know where she lived? 24 A. No, I didn't. I don't know 25 where she lives. Page 109 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you ever go to her 3 apartment? 4 A. No. 5 Q. When is the last time you 6 talked to her? 7 A. I haven't -- I think before 8 I left New York. 9 Q. Did you have a cell phone 10 when you were in New York? 11 A. Yes, I did. 12 Q. Do you recall who your cell 13 phone provider was? 14 A. I don't remember. 15 Q. Do you know your cell phone 16 number? 17 A. No, I have no idea. 18 Q. When you were living in New 19 York, were your parents living in 20 South Africa? 21 A. My dad was living in South 22 Africa, my mom was in the UK. 23 Q. Can you tell me about your 24 first conversation with 25 A. I can't remember my first Page 110 1 HIGHLY CONFIDENTIAL AEO 2 conversation with her. 3 Q. Can you remember any 4 conversation with her? 5 A. Yeah, I can. I can remember 6 chatting. She was my friend. I mean, 7 we spoke about everything. We spoke 8 about life with Jeffrey, we spoke 9 about Ghislaine, we spoke about the 10 other girls, we spoke about 11 was a really nice girl as well. Like, 12 we often got coffee with each other, 13 lunches, dinners. 14 Q. Okay. Do you remember any 15 specifics of your conversations? 16 MS. MCCAWLEY: Objection, 17 asked and answered. 18 A. We spoke very frequently 19 about the faces Jeffrey used to pull 20 when he used to masturbate over the 21 girls, which was quite funny. 22 We spoke about Ghislaine 23 quite a lot and what a monster she 24 was. She's really not a nice person, 25 so -- yeah, I mean, we spoke about Page 111 1 HIGHLY CONFIDENTIAL AEO 2 them a lot, actually. 3 Q. Okay. So you spoke about 4 the faces Jeffrey made when he 5 masturbates over the girls? 6 A. And the way he spits on his 7 hand when he masturbates. It's really 8 gross. It's quite funny. 9 Q. Any other conversations with 10 that you remember? 11 A. I remember I didn't really 12 get on with Ghislaine. As I said, 13 she's -- in my opinion, she's not a 14 nice person. I didn't really get her. 15 And Jeffrey Epstein promised 16 me a -- going to FIT. So we 17 frequently spoke about just everyday 18 things, you know. 19 and I -- 20 really Jeffrey Epstein and I once 21 had a fight and patched things 22 up between us, because I didn't want 23 to speak to Jeffrey anymore. 24 I often spoke to 25 about why Ghislaine didn't like me and Page 112 1 HIGHLY CONFIDENTIAL AEO 2 why the other girls didn't like me: 3 didn't like me, Ghislaine didn't 4 like me, definitely 5 didn't like me. Yeah, that kind of 6 stuff. 7 Q. How is it that you came to 8 meet Jeffrey Epstein? 9 A. Through 10 Q. Tell me about that. 11 A. I first met Jeffrey -- 12 introduced me to Jeffrey. She 13 kind of described him to me. She knew 14 I wanted to go back to school to get a 15 degree, and I was really battling 16 financially because at that time I 17 wasn't really modeling material. 18 So, yeah, she told me about 19 this guy who was really wealthy, a 20 21 22 23 24 philanthropist, you know, really enjoyed -- you know, he really cares about people and he really wants to help them, and he was a really good, decent guy. 25 Then we -- he was helping Page 113 1 HIGHLY CONFIDENTIAL AEO 2 her at that time, as well as and 3 other girls. 4 Q. That's what she told you? 5 A. Yes. 6 Q. Where were you when 7 was describing Jeffrey? 8 A. I can't remember the 9 location, but -- I mean, she first 10 described Jeffrey -- I think it was 11 the second time we met, because I had 12 discussed with her that I was 13 struggling financially because my 14 modeling career hadn't really taken 15 off as I had hoped, so I was -- yeah, 16 she wanted to help. 17 Q. And you don't remember where 18 you had this conversation? 19 A. No, not specifically the 20 exact location. 21 Q. Was it in person or over the 22 phone? 23 A. It was in person. 24 Q. Was anybody else there? 25 A. I think could have been Page 114 1 HIGHLY CONFIDENTIAL AEO 2 there, could have been 3 there, a few other people could have 4 been there. Various people. She was 5 quite open about it. 6 Q. And do you know when this 7 was in the fall of 2006? 8 A. It was very close to after I 9 had first arrived, so it was quite 10 soon after I arrived. I don't know 11 specifically if it was three weeks or 12 two weeks, but it was quite soon after 13 I first got to... 14 Q. Okay. So did you meet 15 Jeffrey? Did you agree to meet 16 Jeffrey? What happened next? 17 MR. GUIRGUIS: Objection to 18 form. 19 Q. What happened next? 20 MR. GUIRGUIS: Objection to 21 that one too. 22 A. I agreed to -- yeah, I met 23 Jeffrey. 24 Q. How? 25 A. We went to -- the first Page 115 1 HIGHLY CONFIDENTIAL AEO 2 meeting I had with Jeffrey was at the 3 cinema. There were about ten other 4 girls with him. 5 Q. How did that meeting get 6 arranged? 7 A. arranged it, and 8 said she had spoken to Jeffrey and 9 Jeffrey wanted to meet me. 10 Q. And what movie did you see? 11 A. I can't remember what movie 12 it was. 13 Q. Did you sit with him? 14 A. Yes, I did. 15 Q. Next to him? 16 A. I can't remember if it was 17 next to him, but I was close by him. 18 Q. You, ten other 19 girls and Jeffrey? 20 A. I don't know if it was 21 exactly ten, but there were -- there 22 were many other girls there. There 23 was like a big group of us. 24 Q. And where was the theater? 25 A. I can't remember the exact Page 116 1 HIGHLY CONFIDENTIAL AEO 2 location, but it was quite a 3 prominent -- it was a big cinema. It 4 was like a huge -- like one of your 5 main cinemas. Somewhere -- is there a 6 cinema on Lexington, maybe? 7 I don't know. Sorry. 8 Navigation isn't in my strong points. 9 I'm going to stop speculating. I'm 10 sorry, okay? I said it for you. I 11 don't know. 12 Q. It was somewhere in New 13 York? 14 A. It was in New York. 15 Q. And you went with 16 A. Yes. 17 Q. How did you go? 18 A. By cab. 19 Q. From your apartment with 20 21 A. Yes. 22 Q. And tell me about your 23 experience at the cinema? 24 A. I bought popcorn and sweets 25 and juice, and I had an awesome time Page 117 1 HIGHLY CONFIDENTIAL AEO 2 watching the movie with a bunch of new 3 people. 4 Q. And you do not remember the 5 name of the movie? 6 MR. GUIRGUIS: Objection. 7 A. No. 8 Q. And what happened after the 9 movie was over? 10 MR. GUIRGUIS: Objection. 11 A. I got in a taxi. 12 Q. And? 13 MR. GUIRGUIS: Objection. 14 15 MS. MENNINGER: What's the objection? 16 17 18 MR. GUIRGUIS: The question and, objection to form. That's a good objection. 19 A. I went home. 20 When was the next time you 21 met Jeffrey? 22 A. I can't remember specific -- 23 I can't remember -- I think I met 24 him -- again, I'm not trying to 25 speculate. I think I met him in New Page 118 1 HIGHLY CONFIDENTIAL AEO 2 York again. I can't remember that 3 meeting. I then met him again on his 4 private plane. 5 Q. So you believe the third 6 time you met him was on the private 7 plane? 8 A. That's correct. 9 Q. And do you remember anything 10 about the second time you met him? 11 A. No, I can't remember. 12 Q. And do you know how long 13 after the first time you met him the 14 second time was? 15 A. Pretty soon after. 16 Q. What does that mean to you? 17 A. Couple days. 18 Q. Where did you meet him that 19 second time? 20 A. In New York. 21 Q. Where? 22 A. I can't remember. 23 Q. At his house? 24 A. No, it wasn't at his house. 25 Q. Was anyone else there the Page 119 1 HIGHLY CONFIDENTIAL AEO 2 second time you met him? 3 A. 4 Q. Anyone else? 5 A. No, not that I recall. 6 Q. Anything memorable about 7 that event? 8 A. Nothing, nothing memorable. 9 Q. Anything sexual happen at 10 the second meeting? 11 A. No. 12 Q. At the first meeting? 13 A. No. 14 Q. How did the flight meeting 15 become arranged, if you know? 16 A. So it was pretty a 17 last-minute thing. phoned me 18 up and said that Jeffrey Epstein would 19 very much like to have me go to his 20 island. It was going to be so much 21 fun, it was going to be a girls' week, 22 there were lots of other girls going, 23 we were going to have so much fun, 24 etcetera, etcetera, etcetera. 25 Q. And what did you do? Page 120 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection. 3 A. I went on the I went with 4 them to the island. 5 Q. Where was the plane located? 6 A. I can't remember the exact 7 airport. I think it was either Newark 8 or JFK. 9 Q. Did you fly commercially or 10 private? 11 A. Private. 12 Q. Was it Jeffrey's plane? 13 A. Yes. 14 Q. Who else was on the plane? 15 A. -- I would 16 like to say but I can't remember 17 her specifically being there on the 18 first trip, so... and 19 were definitely there. 20 Q. Had you met before? 21 A. No. 22 Q. And you don't remember 23 anyone else? 24 A. No, it was -- I mean, there 25 were always new people around Jeffrey Page 121 1 HIGHLY CONFIDENTIAL AEO 2 and Ghislaine, so I don't really -- 3 Q. Well, you just said and 4 Ghislaine. Was Ghislaine there? 5 A. No, not the first time. 6 Q. And do you recall what month 7 this was? 8 A. I can't remember what month 9 it was. 10 Q. It was sometime during your 11 first three-month period? 12 A. Yeah, it was within that 13 first three months. 14 Q. So sometime between 15 September and December? 16 A. That's correct. 17 Q. And did you have a camera 18 with you when you went? 19 A. I did. 20 Q. Did you take pictures? 21 A. I took a couple. 22 Q. Describe for me what 23 happened on the plane ride? 24 A. walked in, sat down in 25 front of me, We all buckled Page 122 1 HIGHLY CONFIDENTIAL AEO 2 up, we took off. 3 The rest of the passengers 4 in the -- I think it's towards the 5 front of the plane where all the seats 6 are -- we all -- all the guests 7 were -- fell asleep. I pretended to 8 be asleep. 9 Jeffrey then went -- Jeffrey 10 went to his -- was in his bed on the 11 plane, having open sex with for 12 everyone to see, on display. 13 Q. Did you participate in that 14 sex at all? 15 A. No, I didn't. 16 Q. Did anyone ask you to? 17 A. No. 18 Q. Did you and have any 19 sexual relationship on that plane, the 20 first plane ride? 21 A. No. 22 Q. Were you still having an 23 occasional sexual relationship with 24 at that time? 25 MS. MCCAWLEY: Objection. Page 123 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember. 3 Q. What types of sexual 4 relationship did Jeffrey and 5 have on the plane in your presence? 6 A. Well, was straddling 7 Jeffrey for quite some time. I 8 watched them both ejaculate with each 9 other. They were having quite a good 10 time together. 11 Q. How long was the plane ride? 12 A. Gosh, a few hours. Few 13 hours. 14 Q. Did you say anything? 15 A. No. I was a guest. I 16 thought it would be quite 17 inappropriate. 18 Q. All right. Can if I ask you 19 if you could just draw a layout of the 20 plane? 21 I'm going to reach over? 22 Just kind of describe where 23 everyone was sitting and the bed area. 24 A. I don't remember if it was 25 the back or front. The front of the Page 124 1 HIGHLY CONFIDENTIAL AEO 2 plane, I think there was a round -- 3 there was, like, a round bed at the 4 back of the plane. 5 There was seating. Pilots 6 are there. walked in with her 7 Louis Vuitton handbag. She sat there 8 in front of me at the side of the 9 plane. So there was seating here. 10 Q. Can you just write 11 next to that -- 12 A. Okay. 13 Q. so I will remember later. 14 A. sat there when she 15 first walked in. And I remember her 16 specifically with a Louis Vuitton 17 handbag that she had, a black one. 18 Q. Okay. And where were you 19 sitting? 20 A. I was sitting opposite her. 21 And then I think we changed positions 22 or there was -- I just remember at the 23 front, there was seating here, okay. 24 Q. Well, where was 25 sitting? Page 125 1 HIGHLY CONFIDENTIAL AEO 2 A. I don't remember where she 3 was sitting. 4 Q. Can you just put where the 5 other seats were, if you don't 6 remember who was in them? 7 A. I remember there was seating 8 here. I think there was -- I'm 9 speculating here, but I can't remember 10 if they were sitting on the -- on the 11 other side of the plane. I can't -- I 12 just remember that I sat on a seat in 13 the front of the plane and there were 14 people opposite me. 15 Q. When you say opposite, do 16 you mean in front and back of you or 17 are you saying to your sides? 18 A. In front of me. 19 Q. Okay. 20 A. So it's like a seating 21 Q. Is it one seat in a row? 22 A. I can't remember the 23 specific layout of the seating on the 24 aircraft, but I know that there's a 25 big, fat, round open -- there's a bed Page 126 1 HIGHLY CONFIDENTIAL AEO 2 on the back of the plane -- 3 Q. Okay. 4 A. -- which there's no door, so 5 you can quite easily have sex and show 6 the whole plane. Which is how it's 7 designed, I'm guessing. 8 Q. Okay. 9 A. Because there's no privacy 10 around the bed. 11 Q. I understand. 12 Can you just draw where the 13 other seats are, though? 14 MS. MCCAWLEY: Objection, 15 asked and answered. 16 A. I don't remember where the 17 other seats are. I remember me 18 sitting in a specific airplane seat at 19 the beginning, you know, at the front 20 of the plane. I don't remember the 21 decor of the plane. I remember there 22 was a bed. It was open, it was open 23 plan. 24 Q. Were there bathrooms on the 25 plane? Page 127 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. Where were they? 4 A. I can't remember where the 5 bathrooms were located on the 6 aircraft. 7 Q. Do you know what kind of 8 plane it was? 9 A. It was a nice, big plane. 10 Yeah, it was a plane. A plane. 11 Q. Had you been on a private 12 plane before? 13 A. No. 14 Q. Do you know how many people 15 it carried? 16 A. I just know it's a plane. 17 MS. MENNINGER: Can we mark 18 that. Can you mark that as 19 Defendant's Exhibit 1. 20 MR. GUIRGUIS: Have you seen 21 it before you want to mark it? 22 THE WITNESS: It's really 23 bad. Do you want me to redraw 24 that? It's really embarrassing. 25 I'm not an artist or anything. Page 128 1 HIGHLY CONFIDENTIAL AEO 2 It's really bad. 3 MR. GUIRGUIS: Just hand it 4 over. 5 (Defendant's Exhibit 1, 6 hand-drawn picture marked for 7 identification.) 8 Q. Was there a kitchen on the 9 plane that you recall? 10 A. I can't remember any, no. 11 Q. Was there an office area? 12 A. I can't remember the layout 13 of the plane. I remember the bed. 14 The only thing I remember is the 15 open-plan bed where I watched 16 and Jeffrey have sex. 17 Q. Apart from the Louis Vuitton 18 bag, do you remember what was 19 wearing? 20 A. I just remember she had a 21 black Louis Vuitton handbag. And I 22 don't remember what she was wearing, 23 no. But I remember the black handbag 24 because I liked it so much, I bought 25 the red-colored version a few years Page 129 1 HIGHLY CONFIDENTIAL AEO 2 later. It was really nice. 3 Q. How long did you stay on the 4 island during this first trip? 5 A. A few days. 6 Q. Was it a week or two days? 7 A. I can't remember. 8 Q. Apart from 9 Jeffrey and yourself, is there anyone 10 else you recall being on that first 11 trip? 12 MR. GUIRGUIS: Objection. 13 A. On that particular first 14 trip, I can't remember. I just 15 remember Jeffrey, 16 myself on the first trip. 17 Q. When you got to the island, 18 was there anyone there? 19 A. Yes. There was a lovely 20 couple from Zimbabwe, somewhere in 21 Africa. I think they were either 22 South African or from Zimbabwe, but 23 they was a lovely middle-age couple. 24 Chef, like staff, really nice staff on 25 the island. Page 130 1 HIGHLY CONFIDENTIAL AEO 2 Q. Any other guests? 3 A. No, not that first trip. 4 Q. Did you engage in any sexual 5 acts with Jeffrey Epstein on your 6 first trip? 7 A. Yes. 8 Q. What happened? 9 MR. GUIRGUIS: Objection. 10 A. It was -- I had to give him 11 a massage in his bedroom. 12 Q. And how did that come about? 13 A. So the entire basics were 14 explained to me, there's this wealthy 15 dude, this philanthropist, loves 16 women, loves getting massages. And 17 this was a nice way to make extra 18 cash, which is great. 19 I got to the island -- II, I 20 was made to massage Jeffrey on the 21 plane. Sorry. That's where I gave my 22 first massage to Jeffrey. 23 So my first massage started 24 with him on the plane, with his feet 25 and his hands. And on that trip I Page 131 1 HIGHLY CONFIDENTIAL AEO 2 was -- I had to give him other 3 massages, like legs, arms, feet, 4 hands, head, shoulders. And it wasn't 5 straight away, but they got more 6 sexual. Then I was called to his 7 bedroom. 8 Q. Okay. I just want to make 9 sure we're talking about the same time 10 frame. 11 There was a massage you gave 12 on the plane on the way down there? 13 A. Yes. 14 Q. That was not sexual? 15 A. That was not sexual, no. 16 Q. Was that before or after he 17 was having sex with in the open 18 bed in the plane area? 19 A. It was before. It was 20 before they had sex, because we all 21 fell asleep. 22 Q. Okay. And then how did the 23 massage come about? 24 A. On the island or -- 25 Q. No, on the plane. Just on Page 132 1 HIGHLY CONFIDENTIAL AEO 2 the plane. 3 A. Jeffrey asked me to massage 4 him. 5 Q. So you were asleep and 6 Jeffrey woke you up? 7 MS. MCCAWLEY: Objection. 8 A. When we first got on the 9 plane, we sat down. You know, like 10 when you first get on an airplane, you 11 settle in and chat, chat, chat. And I 12 massaged him, and then it was after 13 that we find of all fell asleep. And 14 then I woke up and I saw Jeffrey and 15 16 Q. Okay. 17 A. So in that effect, I was 18 probably sitting -- I was facing the 19 bed. 20 Q. You were rear-facing? 21 A. Yeah. 22 Q. Can I just hand you back 23 Defendant's Exhibit 1. Is it still, 24 in your recollection, the same place? 25 A. Yeah. We switched seats a Page 133 1 HIGHLY CONFIDENTIAL AEO 2 few times. 3 Q. So where was Jeffrey when 4 you gave him the massage on the 5 airplane? 6 A. He was -- he was seated at 7 the front. 8 Q. In front of where you were? 9 A. We weren't really all seated 10 throughout the entire duration of the 11 flight. So as soon as the flight took 12 up, we took our seat belts off and 13 kind of moved around freely, because 14 it's not a commercial flight. You can 15 do that on private planes. So we 16 weren't in our seats the whole time. 17 There was a lot of moving around. 18 Q. Okay. Can you just draw on 19 Defendant's Exhibit 1 where he was 20 when you gave him the massage? 21 A. I can't remember where 22 specifically on what seat or where I 23 was facing that I gave Jeffrey his 24 massage, so I'm not comfortable 25 putting something because that's Page 134 1 HIGHLY CONFIDENTIAL AEO 2 speculating. 3 Q. Do you have a general area 4 at all? Was it in the front area? 5 A. The general area -- the 6 general area here is at the front of 7 the plane, and then the bed at the 8 back of the plane. 9 Q. So which of those two 10 general areas was the massage? 11 A. So the massage was at the 12 front, because I didn't give him it on 13 the bed; it was in the front of the 14 plane. I don't remember what specific 15 seat plan I gave him a massage. 16 Q. Was he wearing clothes? 17 A. Yes. 18 Q. During the whole massage? 19 A. During the whole massage, 20 yes. 21 Q. What was he wearing? 22 A. I don't remember. 23 Q. Did he have on shoes? 24 A. Yes, he had on shoes when he 25 walked onto the plane. But then he Page 135 1 HIGHLY CONFIDENTIAL AEO 2 took his shoes off to have the 3 massage. 4 Q. And do you recall what he 5 said when he asked you to give him a 6 massage? 7 A. Yes. He asked me to massage 8 his feet and massage him. 9 Q. Were you surprised by that 10 request? 11 A. No. 12 Q. Why not? 13 A. Because told me that 14 he liked getting massages from girls 15 and that he paid for them. 16 Q. Did he pay you for that 17 massage on the plane? 18 A. No. 19 Q. Did you expect him to? 20 A. Well it was a -- it was the 21 beginning of the trip, so I'm hardly 22 going to go, I don't really know you. 23 Can you please pay me. It's not 24 something you really discuss, I don't 25 think. It's not really appropriate. Page 136 1 HIGHLY CONFIDENTIAL AEO 2 It's not very businesslike. 3 Q. And you were clothed during 4 the massage on the plane? 5 A. Yes. 6 Q. Where was the second 7 massage? 8 A. On his island. 9 Q. Where on the island? 10 A. So the second time I 11 massaged him was probably on -- it 12 was -- I was then asked to massage him 13 again later that day, to massage him 14 again in the open-planned seating area 15 on the island. 16 Q. Who asked you to do that? 17 A. 18 Q. So was on the 19 island? 20 A. Yes. 21 Q. Did she travel with you? 22 A. Not all -- I can't remember 23 specifically who traveling -- I can't 24 say that I a hundred percent remember 25 her there on that first flight. I Page 137 1 HIGHLY CONFIDENTIAL AEO 2 don't -- I can't visually see her 3 there. But I know that she traveled 4 with us pretty much every time with 5 Jeffrey. She traveled everywhere with 6 Jeffrey. 7 Q. How many times did you go to 8 the island? 9 A. Several. 10 Q. How many? 11 A. Several. Several times. 12 There were multiple occasions that I 13 went to the island. 14 Q. Three times? 15 A. Several. Several. I can't 16 remember how many times specifically. 17 Q. I understand you don't have 18 a specific answer. 19 A. Yeah. 20 Q. Do you believe it was more 21 than ten times? 22 A. I don't think it was as much 23 as ten times, no. Maybe a little bit 24 less, but not that many. 25 Q. Do you know how many times Page 138 1 HIGHLY CONFIDENTIAL AEO 2 you went on the private plane versus a 3 commercial plane? 4 A. I flew both, so I can't 5 remember how many times I did 6 commercial, how many times I did 7 private. I mean, it was -- I know 8 that I did fly commercially at some 9 times when the plane wasn't available. 10 Q. And the total number of 11 trips to the island you think was less 12 than ten times? 13 MR. GUIRGUIS: Objection. 14 A. There was several times. 15 I'm not sure if it was more than ten. 16 I don't know the accurate number. It 17 was several times. 18 Q. Did you go through any type 19 of passport control when you went to 20 the island at all? 21 A. No, they didn't check 22 passports 23 Q. How did you get from where 24 the plane landed to the island? 25 A. Jeffrey's speedboat. Page 139 1 HIGHLY CONFIDENTIAL AEO 2 Q. Was that the only method? 3 A. Also a helicopter. 4 Q. Who flew the helicopter? 5 A. I don't -- a guy. 6 Q. Was he cute? 7 MR. GUIRGUIS: Objection. 8 A. I don't remember. 9 MR. GUIRGUIS: Objection, 10 and I direct the witness not to 11 answer. 12 MS. MENNINGER: I'm learning 13 about superyachting. I thought I 14 would find out about the 15 helicopter. 16 MR. GUIRGUIS: I thought you 17 were going to ask if he was 18 taller than 6 feet or less than 6 19 feet. I thought that was the 20 next series of questions. 21 Q. So you said the second 22 massage you gave Jeffrey was on the 23 island the same day you flew down 24 there the first time? 25 A. Yes. Page 140 1 HIGHLY CONFIDENTIAL AEO 2 Q. And it was in the open-plan 3 area? 4 A. Yes. 5 Q. And you recall 6 being the one to ask you to give the 7 message? 8 A. We were all sitting there 9 socially. Jeffrey asked me. And that 10 wasn't a sexual massage in the seating 11 area on the island, the second 12 massage. He was still training me to 13 massage, so my standards weren't quite 14 high enough. 15 Q. How did he train you to 16 massage him? 17 A. He let the girls massage me 18 in front of him. He showed me how 19 to -- because his body's full of 20 knots, so -- and he likes his massage 21 really hard. So when you really push 22 on those knots that he has, you have 23 to be quite firm with him. 24 Q. So he told you what he 25 liked? Page 141 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes, yeah. And some of the 3 other girls -- sorry. showed 4 me how he like his massages. 5 Q. Was he clothed during the 6 second massage? 7 A. Yes. 8 Q. Were you clothed? 9 A. Yes. 10 Q. Did any sexual contact occur 11 on the second massage? 12 A. No. 13 Q. When do you recall there 14 being a third massage? 15 A. The next day. 16 Q. And what happened that gave 17 rise to the third massage? 18 A. I was called to Jeffrey's 19 bedroom to massage him. 20 Q. Who called you? 21 A. I'm -- I don't want to 22 speculate, so I can't remember 23 specifically who called me. 24 Q. Okay. So some third person 25 you don't recall -- Page 142 1 HIGHLY CONFIDENTIAL AEO 2 A. It was a female. It was 3 either or so I 4 can't remember which of the two that 5 called me, because they called me many 6 times during the duration of my trip. 7 Q. So when you say called me, 8 what does that mean? 9 A. They come up to me and say, 10 please go to Jeffrey's bedroom and 11 massage Jeffrey. He is waiting for 12 you. 13 Q. What time of day was it? 14 A. I think it was -- I can't 15 remember what specific time of day it 16 was. 17 Q. Can you kind of describe the 18 island for me. Were there more than 19 one building on it? 20 A. Yeah, there were multiple 21 buildings. You had the main house. 22 You had certain accommodation areas 23 where the girls sit. 24 There were various buildings 25 around the island where he used to Page 143 1 HIGHLY CONFIDENTIAL AEO 2 have all -- him and his other guests, 3 like beds and beds, like little 4 shelter things where him and his 5 guests used to have sex with the 6 girls, like beds set up for instant 7 sexual entertainment. So -- 8 Q. On a beach area? 9 A. All over the island. All 10 over the island. So if you go on one 11 of his quad bikes and do a tour of his 12 island, which I'm sure you guys have 13 done, you will see multiple buildings 14 around the island. 15 Q. And where were you staying 16 during this first trip? 17 A. I was staying in one of the 18 guest houses that -- the main 19 guest house that all the girls shared. 20 Q. Were you staying in your own 21 room? 22 A. No. 23 Q. Who were you sharing a room 24 with? 25 A. I think Page 144 1 HIGHLY CONFIDENTIAL AEO 2 slept in the bungalow; she didn't stay 3 there per se. She was explained to be 4 Jeffrey Epstein's girlfriend at the 5 time. 6 Q. When you were asked to give 7 Jeffrey a massage on the third 8 occasion by a female, do you recall 9 what words were used? 10 A. I can't remember the exact 11 words, no. But I was -- it was 12 generally -- it was, can you please go 13 and give Jeffrey -- it's kind of like 14 your turn type of thing. 15 Q. Did you know where his 16 bedroom was? 17 A. I was shown to his bedroom. 18 Q. Who showed you to his 19 bedroom? 20 A. I can't remember who showed 21 me to his bedroom. 22 Q. All right. Tell me what 23 happened during the third massage? 24 A. So I went into Jeffrey 25 Epstein's bedroom. His bedroom is Page 145 1 HIGHLY CONFIDENTIAL AEO 2 ice-cold; it's always ice-cold. He 3 likes his bedrooms very well air 4 conditioned. 5 There was a massage table 6 laid out in his bedroom. He asked me 7 to undress and that he wanted to give 8 me a massage, and he asked me to lay 9 on the table. He then started 10 touching my body. 11 I was -- I was -- it didn't 12 start off as a sexual massage; it was 13 just -- you know, it was just doing a 14 normal massage, and then he started to 15 touch me. He touched my vaginal 16 region and he touched me all over. 17 Q. Were you draped with a 18 towel? 19 A. No. 20 Q. For no part of the massage? 21 A. For the -- I can't remember. 22 Q. Was anyone else present in 23 the room? 24 A. No. 25 Q. And after he started Page 146 1 HIGHLY CONFIDENTIAL AEO 2 touching you while you were on the 3 table, did you give him a massage? 4 A. I can't remember the 5 specific sequence of events, but I 6 remember the third massage, it wasn't 7 for Jeffrey; it was for me. He 8 performed the massage on me. 9 Q. Did you tell him to stop? 10 A. No, I didn't. 11 Q. Did you have any sexual 12 contact with him? 13 A. No, he just touched me. And 14 he was touching himself too, so... 15 Q. Did you have an orgasm? 16 A. I did have an orgasm. He 17 used a specific vibrator on me, which 18 it was quite hard not to. 19 Q. Can you describe it? 20 A. Yeah. It's quite big. It's 21 not an actual vibrator. It's really 22 good; you should get one if you don't. 23 THE WITNESS: Sorry. I'm 24 allowed to talk. Okay. Sorry. 25 A. It's -- I'll -- can I draw Page 147 1 HIGHLY CONFIDENTIAL AEO 2 it? Can I draw it? I'll draw you the 3 exact -- I can actually get you -- I 4 actually own one, so I can get you a 5 photo of it, you know. It's also in 6 the pictures in the dentist chair, 7 one of the photos, so... 8 It's like this. 9 THE WITNESS: I'm sorry. 10 MR. GUIRGUIS: You're fine. 11 MS. MCCAWLEY: You're fine. 12 A. So it's actually a massager 13 for shoulders. It's got a long base. 14 It's got quite a -- it's got like a 15 rubber head. 16 And, yeah, it was really -- 17 it's not -- it's not used for sexual 18 purposes. 19 Q. It's not? 20 A. No, that's what I'm saying. 21 It's not a vibrator. 22 Q. Okay. 23 A. It was actually quite 24 painful for me -- 25 Q. Okay. Page 148 1 HIGHLY CONFIDENTIAL AEO 2 A. -- actually. 3 Q. Okay. Did you tell him to 4 stop? 5 A. I told him to stop when 6 he -- because he pressed the vibrator 7 head on my clitoris and it was 8 incredibly painful. It hurt me. 9 That's a very sensitive area, and the 10 strength of this specific device he 11 used is -- it's not really meant for 12 that. 13 Q. Right. Did he stop when you 14 said stop? 15 A. No. 16 Q. And how long did this 17 massage 18 A. Until -- until I orgasmed. 19 Q. And then what happened? 20 A. He just stopped. And I got 21 dressed and I left. 22 Q. Was there any discussion? 23 A. No. 24 Q. Did he give you any money? 25 A. No. Page 149 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Can we stop 3 for a moment? The witness is 4 crying. I think maybe we should 5 take a moment, have a moment. 6 MS. MENNINGER: Okay. Mark 7 that as Defendant's Exhibit 2, 8 and then we'll take a break for 9 ten minutes. 10 (Defendant's Exhibit 2, 11 hand-drawn picture, was marked 12 for identification.) 13 (Time noted: 12:07 p.m.) 14 (Recess.) 15 (Time noted: 12:19 p.m.) 16 Q. So you just described for 17 us, I think, what you recall being the 18 third massage with Jeffrey? 19 A. Yeah. 20 Q. Do you recall the next one 21 after that? 22 A. It was -- it was basically 23 the same. I was called to give 24 Jeffrey massages. 25 Q. During that first trip to Page 150 1 HIGHLY CONFIDENTIAL AEO 2 the island? 3 A. During the first trip, yeah. 4 Q. Can you approximate how many 5 massages you gave to him during that 6 first trip? 7 A. I would give him up to maybe 8 two a day. The other girls, they had 9 to also give him massages during that 10 trip. 11 Q. And you don't remember how 12 many days that trip was? 13 A. No, not specifically how 14 many. It was a few days. It was a 15 few days. 16 Q. At some point did the 17 massages become different than the one 18 you just described as the third 19 massage? 20 A. It was either Jeffrey lying 21 on the massage -- me massaging him and 22 it turning sexual or vice versa. 23 Pretty much from the third sexual 24 massage I had with Jeffrey, all other 25 massages were sexual. Page 151 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you recall who was on the 3 flight home from the first trip? 4 A. I don't recall who was on 5 the flight home. I think it was all 6 the people that were on the first 7 flight there. 8 Q. Did you receive any 9 compensation from Jeffrey during that 10 first trip? 11 A. I received like \$300 or 12 something. Not a lot. 13 Q. When did you get that? 14 A. At the end of the trip. 15 Q. How was it given to you? 16 A. In cash. 17 Q. By whom? 18 A. That specific time it was 19 Jeffrey. 20 Q. Where were you when he gave 21 that you money? 22 A. I can't recall where I was 23 when he gave me the cash. 24 Q. Did -- were you still with 25 the other females that had been on the Page 152 1 HIGHLY CONFIDENTIAL AEO 2 plane? 3 A. When he gave me the cash? 4 Q. Yes. 5 A. I can't recall. I don't 6 remember if someone was with me. But 7 we all knew that we were going to get 8 cash. 9 Q. Did you see him give cash to 10 anyone else? 11 A. I saw him give cash to 12 13 Q. How much did he give her, if 14 you know? 15 A. I don't know. 16 Q. Did you see having 17 any type of sexual relations with 18 Jeffrey during the trip? 19 A. Yes, I did. 20 Q. When did you see that? 21 A. I didn't see it in the 22 bedroom, but we were called on, like, 23 a rotation visit for Jeffrey 24 throughout the day and evening. 25 Q. When did you see Page 153 1 HIGHLY CONFIDENTIAL AEO 2 having some type of sexual 3 relationship with Jeffrey on the 4 island during the first trip? 5 A. I didn't see her perform 6 sexual acts on Jeffrey. 7 Q. Did anyone see you 8 performing sexual acts on Jeffrey 9 during the first trip to the island? 10 A. No. 11 Q. Did you tell any of these 12 other women about what was going on 13 during your massages with Jeffrey? 14 A. Yes. 15 Q. Who did you tell? 16 A. All the girls that were 17 there. 18 Q. And, again, that is 19 and 20 MR. GUIRGUIS: Objection. 21 Q. Do you remember? 22 A. I can't say specifically if 23 was there. I can't remember 24 being there, so I don't like to bring 25 into the first trip. Page 154 1 HIGHLY CONFIDENTIAL AEO 2 I saw her multiple times on 3 the island, but I can't specifically 4 place her there on the first trip. I 5 just remember the key people that were 6 there because they were the most vivid 7 in my memory. 8 Q. Do you know if you took any 9 pictures during that first trip? 10 A. I don't think during that 11 first trip, no. We weren't actually 12 allowed to bring any electronic 13 devices with us. 14 Q. How did you learn that rule? 15 A. told me and the 16 other girls told me. 17 Q. Who are the other girls? 18 A. 19 Q. Did you take a camera to the 20 island? 21 A. Not the first time, no. 22 Q. Did you have a digital 23 camera at the time? 24 A. Yes, I did. 25 Q. What kind? Page 155 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember. 3 Q. Did you have a phone with a 4 camera on it? 5 A. I had a BlackBerry, yes, 6 which you could take photos on. 7 Q. All right. Do you recall 8 there being any sexual acts performed 9 on the plane on the ride home during 10 the first trip? 11 A. No. 12 Q. Okay. Do you recall going 13 down a second time? 14 A. To the island? 15 Q. Yes. 16 A. Yes. 17 Q. When did that happen? 18 A. Shortly. I can't remember 19 specifically when it was, but it 20 wasn't on -- I don't know the time 21 length. I saw Jeffrey and Ghislaine 22 and the crowd quite a lot in New York 23 as well, so it's not clear to me when 24 the second trip was. 25 Q. When was the first time you Page 156 1 HIGHLY CONFIDENTIAL AEO 2 met Ghislaine? 3 A. I'd been to the island a 4 couple times before, and then I met 5 Ghislaine on the island. 6 Q. Tell me about your meeting 7 with her? 8 A. I remember being told by 9 everyone before she arrived who she 10 was. And I was pretty much told the 11 type of person she was and that I had 12 to do everything she told me to do. 13 Q. Who told that you? 14 A. , 15 Every single girl that 16 I came in communication with told me 17 that. 18 Q. And what type of person did 19 they tell you that she was? 20 A. She's incredibly 21 intimidating. She's not someone you 22 want to be stuck in an alley at night, 23 put it that way. She's a very 24 dangerous character and has 25 connections. Page 157 1 HIGHLY CONFIDENTIAL AEO 2 Q. And that was communicated to 3 you by this group of females: 4 and 5 A. Yes. 6 Q. Anyone else? 7 A. I mean, it was a general 8 conversation amongst the girls about 9 Ghislaine, so there were other girls 10 all the time. So during the duration 11 of my stay -- so pretty much from 12 my -- when I first arrived in New 13 York, my entire time was spent with 14 Jeffrey and Ghislaine and that crowd. 15 So, yeah, it was -- that's 16 about everything. 17 Q. Okay. So you met -- 18 A. I met a lot of girls who we 19 all had the same opinion of Ghislaine; 20 we were all frightened of her. She 21 had a very odd relationship with 22 Jeffrey and -- yeah, she's not a 23 nice -- I'm sorry, I know she's your 24 client, but she's not -- she's not a 25 friendly, warm person. Page 158 1 HIGHLY CONFIDENTIAL AEO 2 I liked her dog, though, her 3 Yorkshire Terrier. Her dog was nice. 4 Q. You recall meeting her for 5 the first time on the island? 6 A. Yeah. She flew in by 7 helicopter. 8 Q. And that was after you were 9 on the island a couple of times? 10 A. Yeah. 11 Q. Did she fly the helicopter? 12 A. I can't remember if she flew 13 it or not. I just remember her 14 getting out -- like getting out of 15 a -- and going Ghislaine, and I was 16 like -- I was quite frightened when 17 she arrived, so... 18 Q. Was she alone or with 19 someone? 20 A. I can't remember if she was 21 with someone. I just remember the 22 first time I saw her, I was like, is 23 that it? She didn't look that scary 24 when I first met her. Looks are 25 deceiving. Page 159 1 HIGHLY CONFIDENTIAL AEO 2 Q. So the first time you saw 3 her, she was getting off of a 4 helicopter? 5 A. Yeah. 6 Q. And you don't recall if she 7 flew the helicopter? 8 A. I don't recall if she flew 9 it herself or if there was a pilot 10 there. I just remember she arrived on 11 a helicopter. 12 Q. What's the next thing you 13 remember about your interactions with 14 her personally? 15 A. She stayed on the island a 16 few days, and I didn't have a lot of 17 interaction with her. I avoided her, 18 to be honest. 19 Q. Did you take pictures of 20 her? 21 A. No. We weren't allowed any 22 digital cameras on the island. 23 Q. Have you ever taken a 24 picture of her? 25 A. No. I didn't really feel Page 160 1 HIGHLY CONFIDENTIAL AEO 2 the need to take pictures of Ghislaine 3 for my photo album. 4 Q. Apart from staying away from 5 her and not having a lot of 6 interactions, do you recall anything 7 else about your first interaction with 8 her on the island? 9 A. Yeah. She was incredibly 10 unpleasant to me. She wasn't friendly 11 or warm. 12 Q. What did she say or do? 13 A. She was very dismissive. 14 Just another girl, really. 15 Q. Did you ever give her a 16 massage? 17 A. No. 18 Q. Did she ever give you a 19 massage? 20 A. She massaged me once or 21 twice, but it was to -- it was to 22 refine my technique for Jeffrey. 23 Q. This was on the first time 24 you met her? 25 A. Yeah, during that trip Page 161 1 HIGHLY CONFIDENTIAL AEO 2 she -- because Jeffrey, again, he's 3 quite specific on how he likes his 4 massages and, yeah, I'm not -- that's 5 not my forte, massages. 6 Q. How did it come about that 7 she was helping you to refine your 8 massage techniques? 9 A. We were just sitting in the 10 main area by the big house. That's 11 where we chilled out. There's a table 12 there as well. 13 And, yeah, we were just 14 sitting on the sofas, and I think -- I 15 can't remember if I was giving Jeffrey 16 a massage, but we were all sitting 17 together, and I think he was getting 18 massaged by one girl and we were kind 19 of taking it in turns. 20 Q. Was it sexual? 21 A. No, it wasn't sexual. But 22 Ghislaine was there, and I wasn't 23 doing it properly and she showed me 24 how to massage him and how he liked 25 it. Page 162 1 HIGHLY CONFIDENTIAL AEO 2 Q. What part of his body did 3 she show you how to massage? 4 A. His feet, his hands. 5 Q. Did she say anything to you? 6 A. I can't remember 7 specifically what she said to me. She 8 said a lot of things to me. 9 Q. Okay. Well, tell me what 10 you remember she said to you. 11 MR. GUIRGUIS: Objection. 12 When? Where? What? What are we 13 talking about? 14 A. I can't remember 15 specifically what she said to me. All 16 I know is that she wasn't -- she 17 wasn't a particularly nice person, to 18 me or anybody. So very dictorial 19 [sic]. 20 Q. Unlimited by time or 21 anything, do you recall anything 22 Ghislaine said to you? 23 MR. GUIRGUIS: Objection. 24 You're asking her -- 25 A. It was how to massage Page 163 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey. 3 I remember speaking to her 4 quite a lot about my FIT application. 5 I remember speaking to 6 Ghislaine about my psychiatrist, about 7 my weight. My weight was a big issue. 8 And, in fact, everything was an issue 9 with Ghislaine. 10 Q. During this first time you 11 met her, other than discussing 12 massages, did those other topics come 13 up? 14 A. I can't remember the first 15 encounter with Ghislaine, but it was 16 pretty soon after. Everything 17 snowballed quite quickly. 18 Q. Well, you saw her getting 19 off the helicopter, correct? 20 A. Yeah. 21 Q. And you saw her on the 22 island for a couple days that time, 23 you said, correct? 24 A. Yeah. 25 Q. So during that time you saw Page 164 1 HIGHLY CONFIDENTIAL AEO\ 2 her over a couple days, do you\ 3 remember any other discussions you had\ 4 with her apart from this massage? 5 A. We spoke about why I was\ 6 there, New York. I mean, we -- you\ 7 know, she got to know me. She asked\ 8 me a lot of questions about my family\ 9 life, my -- I mean, she questioned me\ 10 a lot on my personal life. 11 Q. Was anyone else present when\ 12 you were having these discussions with\ 13 Ghislaine? 14 A. Yes, everyone. Everyone\ 15 that was -- [REDACTED] [REDACTED], Jeffrey,\ 16 [REDACTED] 17 Q. Was there anyone different\ 18 on this trip? 19 A. [REDACTED] as well. [REDACTED] was\ 20 there. 21 Q. Anyone else on this trip? 22 A. I can't remember. 23 Q. Was [REDACTED] [REDACTED] [REDACTED] there? 24 A. Not the first time I met\ 25 Ghislaine. ![](_page_164_Picture_125.jpeg) Page 165 1 HIGHLY CONFIDENTIAL AEO 2 Q. Was anyone else there? 3 A. I can't remember. 4 Q. Anything that would refresh 5 your memory? 6 A. If you could give me the 7 plane logs or something, or names or 8 photos. Ten years, as I said, is an 9 incredibly long time. I don't 10 remember who -- I mean, it was such a 11 long time for me. 12 I came to New York, my 13 intention was to meet many people, 14 make new friends, make a new life for 15 myself. So I didn't really -- I don't 16 remember names specifically. 17 Q. Do you remember any 18 descriptions of other people who were 19 on the island the first time you met 20 Ghislaine? 21 A. They were all beautiful 22 people. I just remember being 23 surrounded by beautiful young people. 24 They were always girls. There were 25 always girls. You know, girls didn't Page 166 1 HIGHLY CONFIDENTIAL AEO 2 even have time to kind of remember 3 girls' names because there was always 4 people leaving the island, popping in, 5 flying in. So there was a constant 6 flux of people coming in, popping in 7 visiting Jeffrey and Ghislaine. 8 Q. So the first time you met 9 Ghislaine, you saw her get off a 10 helicopter. She was on the island for 11 a couple days. 12 Any other females you 13 remember being there on that occasion? 14 MS. MCCAWLEY: Objection, 15 asked and answered. 16 A. 17 and I can't remember any 18 others. 19 Q. Can you remember any 20 descriptions of other people who were 21 there on that occasion? 22 MR. GUIRGUIS: Objection, 23 asked and answered. 24 A. They were just pretty. They 25 were just beautiful. Page 167 1 HIGHLY CONFIDENTIAL AEO 2 Q Hair color? 3 MR. GUIRGUIS: Objection. 4 A. Normal. 5 Q. Height? 6 A. I don't recall height. 7 Q. Any other physical 8 characteristics at all? 9 MR. GUIRGUIS: Objection. 10 A. Just that they were 11 extremely beautiful. I've never seen 12 girls like this. 13 Q. Well, you had been a model 14 in London, right? 15 A. Yeah, I have, but, you know, 16 Jeffrey Epstein, he acquired the 17 elite, didn't he, you know, him and 18 Ghislaine. So they were pretty much 19 the crème de la crème of the crop, I 20 would say, the girls that were around 21 him. 22 Q. On this first occasion when 23 you met Ghislaine and there were 24 beautiful girls, who you don't recall 25 what they look like; you recall they Page 168 1 HIGHLY CONFIDENTIAL AEO 2 were beautiful? 3 A. Yeah, there were beautiful 4 people constantly surrounded by 5 Jeffrey Epstein and Ghislaine. They 6 were only surrounded by beautiful 7 people, beautiful girls. 8 Q. But apart from that, you 9 don't have any other specifics? 10 A. I don't recall the 11 appearance of the other girls. I 12 don't -- as I will say again, there 13 was a constant stream of people coming 14 in, going off the island, popping in, 15 popping out, girls flying in, girls 16 flying out. There were girls on the 17 island that were there shorter time 18 frames than me and flew out. 19 I didn't really -- I hung 20 out with my crew: They 21 were -- they were my friends. I 22 thought they were my friends. So I 23 didn't really cozy up to any of the 24 other girls. 25 It's like high school, you Page 169 1 HIGHLY CONFIDENTIAL AEO 2 know, you're not friends with 3 everybody. You ask me who -- everyone 4 I went to school with, I don't 5 remember. I don't have a clue. I 6 don't know who they are. 7 Q. Do you have a best friend 8 from school? 9 MR. GUIRGUIS: Objection. 10 A. Several. Several. I mean, 11 who has any best friend at school? 12 School's school. We don't make best 13 friends at school. 14 Q. Who is 15 A. She was an acquaintance that 16 I met in New York. 17 Q. Where did you meet her? 18 A. I think I met her at a bar 19 or something. 20 Q. Was she a friend of yours 21 during this time period? 22 A. She was an acquaintance. I 23 would say friend is -- yeah, I 24 wouldn't say friend. I'd say 25 acquaintance. Page 170 1 HIGHLY CONFIDENTIAL AEO 2 Q. So on this occasion where 3 you met Ghislaine on the island and 4 you spoke to her about massage, did 5 you ever have any other sexual-type 6 interactions with her? 7 MS. MCCAWLEY: I didn't hear 8 the end of that. Did you say 9 "him"? 10 Q. Sexual-type interactions 11 with her? 12 A. With her? 13 Q. Ghislaine? 14 A. No. 15 Q. And do you recall if she 16 flew with you back on the plane? 17 A. I can't remember. 18 Q. What's the next time you 19 went to the island? 20 A. Again, I don't remember 21 specifically. I went various several 22 times during the duration. So I 23 remember there was a -- it was several 24 times. I can't remember the next time 25 I went to the island. I mean, it's.. . Page 171 1 HIGHLY CONFIDENTIAL AEO 2 Q. Was it before you went back 3 to South Africa to visit? 4 A. Yes. 5 Q. All the visits to the island 6 were before that? 7 MS. MCCAWLEY: Objection. 8 A. Yeah. 9 Q. What's the next time you 10 remember meeting Ghislaine? 11 A. I met her at the office in 12 New York. 13 Q. What's the office? 14 A. Jeffrey's office, main 15 office. 16 Q. Where is that? 17 A. I don't remember the 18 location. It's central. It's got a 19 courtyard. Like when you walk in, 20 there's like a courtyard. 21 Q. What were you doing at 22 Jeffrey's office in New York? 23 A. We were preparing for my 24 college application. Jeffrey often 25 wanted to see just how I was doing, so Page 172 1 HIGHLY CONFIDENTIAL AEO 2 I had to regularly pop in to see him 3 and Ghislaine. And Ghislaine would 4 often check how I was doing and blah, 5 blah, blah, etcetera. 6 Q. What were you doing to 7 prepare for your college application? 8 A. I had to write an essay. 9 Q. When did you 10 A. Also, I had to do -- like, 11 you know how you apply for college 12 applications; you've got your 13 application forms and such. So it was 14 more admin. 15 Q. And you were going to 16 Jeffrey's office to work on your 17 forms? 18 A. Yes. And to just say hi. I 19 was -- well, I never went on my own 20 accord. I was either invited or told 21 to be there by either Ghislaine or 22 Jeffrey. I also went to the offices 23 on a number of occasions for private 24 legal matter. 25 Q. What's the private legal Page 173 1 HIGHLY CONFIDENTIAL AEO 2 matter? 3 MR. GUIRGUIS: Objection. 4 I'm going to direct you not to 5 answer if it's unrelated to this 6 case. 7 Q. Was there an attorney 8 present? 9 A. Yes. 10 Q. What was the name of the 11 attorney who was present? 12 A. Alan Dershowitz. 13 Q. So I was asking about the 14 second time you met Ghislaine. It was 15 at Jeffrey's office in New York? 16 A. Yes. 17 Q. How did you come to be in 18 Jeffrey's office in New York where you 19 met Ghislaine the second time? 20 A. I was told to be there. 21 Q. Who told you to be there? 22 A. I think it was Ghislaine. 23 Q. How did Ghislaine tell you 24 to be there? 25 A. I can't remember if it was Page 174 1 HIGHLY CONFIDENTIAL AEO 2 via telephone call. I can't remember 3 the exact communication that she used. 4 But I was told to regularly be there 5 when they wanted me there, and just 6 grabbed a taxi and arrived at the 7 office. 8 Q. Well, I'm asking you about 9 the second time. 10 So you met her on the 11 island, and the next thing you know, 12 you have a communication from her in 13 New York? 14 A. Well, she was always with 15 Jeffrey in his office, so it's like -- 16 okay, so let me explain it. 17 So you go to an office and 18 you see Jeffrey's office there and 19 Ghislaine Ghislaine was always at 20 Jeffrey's office, so I think she had 21 her own office there. 22 So when you walk in and 23 you've met people before, you kind of 24 say hi to everyone. You know, you 25 have a little chitchat. Page 175 1 HIGHLY CONFIDENTIAL AEO 2 Do you understand? You 3 don't -- you don't -- you know, I 4 chatted with Ghislaine, I chatted with 5 Jeffrey. It was a busy office. I 6 can't remember specifically what was 7 said. It was just a check-in, kind 8 of. 9 Q. So you were going there to 10 work on your college application, and 11 you happened to see Ghislaine in the 12 offices? 13 MS. MCCAWLEY: Objection. 14 A. She -- you know, she 15 participated in the -- you know, a 16 lot. She was interested in me. I 17 was -- you know, she interacted with 18 me. 19 Q. I know. I'm trying to 20 understand when you did this. When 21 was it? 22 A. It was the second time, the 23 first time I went to the office. 24 Q. The first time you went to 25 the office, the second time you met Page 176 1 HIGHLY CONFIDENTIAL AEO 2 Ghislaine? 3 A. Yes. 4 Q. And when was it relative to 5 the first time you met Ghislaine? 6 A. I can't remember if it was a 7 couple of weeks later. I don't 8 remember the exact time frame of how 9 many days or weeks there was between 10 the first trip and the -- when I went 11 in to the office. 12 Q. But you do recall going into 13 the office to work on your college 14 application? 15 MS. MCCAWLEY: Objection. 16 A. Yes. Well, I went in a 17 number of times to the office. So, 18 like, we regularly had to report to 19 Jeffrey in the office. It was a -- we 20 were called all the time there. 21 Q. What do you mean, you had to 22 report there? 23 A. Well, Jeffrey liked to check 24 in with all of us. 25 Q. How was it communicated to Page 177 1 HIGHLY CONFIDENTIAL AEO 2 you that you needed to report to the 3 office? 4 A. Jeffrey. I was just told to 5 be there; I had to be there. 6 Q. Who told that you? 7 A. Jeffrey and Ghislaine. 8 Q. Anyone else? 9 A. and 10 11 Q. How did they communicate it 12 to you? 13 A. By telephonic call. 14 Q. To your cell phone? 15 A. And BlackBerry, which they 16 provided me. 17 Q. So you did not have a 18 BlackBerry before you met Jeffrey? 19 A. No. 20 Q. Then you got a BlackBerry 21 when you were -- 22 A. That's correct. 23 Q. -- acquainted with him. 24 And what happened with the 25 phone you had before? Page 178 1 HIGHLY CONFIDENTIAL AEO 2 A. It's got lost through 3 translation. I have moved several 4 times through the years, so... 5 Q. So you got messages or phone 6 calls? 7 A. BBMs, phone calls, text 8 messages. 9 All the emails that they 10 sent me, I think you guys have. There 11 wasn't a lot of email correspondence. 12 The majority of it was done by phone 13 call. 14 Q. Did you have any emails with 15 Ghislaine? 16 A. No, no email correspondence 17 with Ghislaine. 18 Q. Did you have her phone 19 number? 20 A. I did at the time, yeah. 21 Q. Do you remember what it was? 22 A. No. 23 Q. Do you remember what your 24 number was? 25 A. No. Page 179 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection, 3 asked and answered. 4 Q. Tell me about any 5 conversations you had with Ghislaine 6 that involved FIT. 7 MR. GUIRGUIS: Objection, 8 form. 9 A. I can't remember the 10 specific conversation. There were 11 many conversations. I was just 12 applying -- doing an application form. 13 And they were trying to get me in. 14 They -- yeah, I can't remember the 15 exact -- I think Ghislaine also knew 16 people there, so they were basically 17 trying to get me into FIT. 18 Q. Well, tell me what you 19 recall Ghislaine saying versus they? 20 A. I can't remember 21 specifically the conversation, so I 22 would not like to speculate. But I 23 will give you the overall conversation 24 was regarding my FIT application, but 25 I cannot remember the specific content Page 180 1 HIGHLY CONFIDENTIAL AEO 2 or the specific words used. 3 But it was surrounding my 4 FIT application and an essay I had to 5 write, and they both proofread my FIT 6 application as well. 7 Q. And did they both read your 8 essay? 9 A. Yes, they did. 10 Q. When did you write that 11 essay? 12 A. I can't remember. 13 Q. Before you went to South 14 Africa? 15 A. Yes. 16 Q. Do you know what the 17 application deadline was? 18 A. I don't know. I don't know. 19 I can't remember. 20 Q. When did you meet Alan 21 Dershowitz? 22 A. I don't remember the 23 specific date. It was a few months 24 after I had been here in New York. 25 Q. Was it after you had gone to Page 181 1 HIGHLY CONFIDENTIAL AEO 2 the island? 3 A. Yes. 4 Q. Do you know what time of 5 year? 6 A. I mean, I think it was 7 before winter. 8 Q. Well, you were here in the 9 fall. 10 A. Yeah. 11 Q. And you left in the winter? 12 A. Yeah. I left in May. 13 Q. So did you meet him before 14 you went to South Africa? 15 A. Yes. 16 Q. Well, let's be clear. You 17 were here until you went to South 18 Africa, and you left for a while and 19 then you came back, right? 20 A. Mm-hmm. 21 Q. How long were you gone? 22 A. I think about three -- about 23 three weeks. 24 Q. So you met him before you 25 went to South Africa? Page 182 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. And tell me about when you 4 met Alan. 5 A. I first met Alan at the 6 offices. 7 Q. And tell me what happened. 8 A. I can't really tell you what 9 happened, because it's about a legal 10 matter. 11 Q. Was he your lawyer? 12 A. He was going to be assigned 13 to be my lawyer. 14 Q. Assigned to be your lawyer? 15 A. Through Jeffrey's 16 instruction. 17 Q. Okay. Was he your lawyer? 18 MS. MCCAWLEY: Objection, 19 asked and answered. 20 MS. MENNINGER: I don't know 21 if there's a privilege. 22 MR. GUIRGUIS: There's a 23 privilege whether he was retained 24 or not, right? I mean, if you're 25 at a cocktail party and you speak Page 183 1 HIGHLY CONFIDENTIAL AEO 2 to a lawyer, you know that 3 conversation is privileged. 4 So... 5 MS. MENNINGER: Well, I 6 don't, actually. 7 MR. GUIRGUIS: You're free 8 to research it. 9 MS. MENNINGER: I will ask 10 questions, then, to try to 11 establish whether or not there's 12 a good-faith basis. 13 Q. Did you approach Alan 14 Dershowitz for the purpose of seeking 15 legal advice? 16 A. I was introduced to Alan. 17 Q. By whom? 18 A. Jeffrey Epstein. 19 Q. On what day? 20 A. I don't recall what day. 21 Q. Was it related to some event 22 that had occurred just before that? 23 A. Yes, that's correct. 24 Q. Were you in touch with any 25 law enforcement authorities? Page 184 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Hmm? 4 A. No. 5 Q. Was Jeffrey Epstein in the 6 room when you were speaking with Alan 7 Dershowitz? 8 A. Yes. 9 Q. Did Jeffrey Epstein overhear 10 your conversation with Alan 11 Dershowitz? 12 A. Yes. 13 Q. What did you talk about with 14 Alan Dershowitz? 15 MR. GUIRGUIS: Objection. 16 A. It -- 17 MR. GUIRGUIS: Objection. I 18 direct the witness not to answer. 19 MS. MENNINGER: A third 20 party was in the room; you've 21 heard that, Counsel. And you 22 know that means that's a waiver. 23 MS. MCCAWLEY: No. I mean, 24 they would have been involved -- 25 we don't know what the situation Page 185 1 HIGHLY CONFIDENTIAL AEO 2 is. They could have been 3 involved together. There could 4 be a number of reasons why 5 Jeffrey had some sort of common 6 interest with her with that. 7 Q. Did you sign a common 8 interest agreement with Jeffrey? 9 MR. GUIRGUIS: Objection. 10 Do not answer. 11 MS. MENNINGER: Whether she 12 had a common interest agreement 13 with Jeffrey, you're instructing 14 her not to answer; is that right, 15 Counsel? 16 MR. GUIRGUIS: Do you have 17 realtime in front of you, 18 Counsel? 19 MS. MENNINGER: I don 't . 20 MR. GUIRGUIS: You don ' t? 21 You can borrow mine. 22 MS. MENNINGER: I don't want 23 it. Thank you. 24 MR. GUIRGUIS: Okay. 25 Q Anyone else in the room when Page 186 1 HIGHLY CONFIDENTIAL AEO 2 you spoke with Mr. Dershowitz? 3 A. No. 4 Q. Describe Mr. Dershowitz for 5 me. 6 A. He -- old age; , pasty 7 skin; not very attractive. Wears 8 glasses. Bit of an ugly man, really. 9 Q. Did he have any facial hair? 10 A. I can't recall at that time, 11 no. 12 Q. Mustache? 13 A. I can't remember. 14 Q. Beard? 15 A. I can't remember. 16 Q. You can't remember if he had 17 a mustache or a beard? 18 MR. GUIRGUIS: Objection, 19 asked and answered. 20 MS. MCCAWLEY: Objection. 21 A. I don't recall seeing a 22 massage -- sorry, a mustache on Alan 23 Dershowitz. I don't recall a massive 24 amount of facial hair. I recall Alan 25 Dershowitz. Whether he had stubble or Page 187 1 HIGHLY CONFIDENTIAL AEO 2 not, I'm -- yeah, it's -- he didn't 3 have a beard, I don't think. 4 Q. All right. Did you sign an 5 affidavit that you submitted in this 6 case? 7 A. Yes. 8 Q. Did you make the allegation 9 in your declaration that you had a 10 sexual relationship with Alan 11 Dershowitz? 12 A. Yes, I absolutely did. 13 Q. When did you have sex with 14 Alan Dershowitz? 15 A. I can't remember the exact 16 time, but it was in Jeffrey's New York 17 apartment. 18 Q. Where in the apartment? 19 A. It was in a bathroom. I 20 can't remember. 21 Q. Was it before or after you 22 had this conversation that you won't 23 describe? 24 A. It was after. 25 Q. So do you recall what month Page 188 1 HIGHLY CONFIDENTIAL AEO 2 that was? Before you went to South 3 Africa or after you went to South 4 Africa? 5 A. I can't remember. 6 Q. How long did you speak to 7 Alan Dershowitz during your first 8 meeting with him? 9 A. Until I was finished 10 explaining what my legal matter was. 11 Q. Did he believe you to be -- 12 did he believe that he was your lawyer 13 during that conversation? 14 MR. GUIRGUIS: Objection. 15 MS. MCCAWLEY: Objection. 16 MR. POTTINGER: Please. 17 MR. PAGLIUCA: All right, 18 guys. You know, let's just do 19 the deposition here without the 20 chorus over there. 21 MR. GUIRGUIS: And without 22 the speeches as well. 23 We agree, let's carry on 24 without asking ridiculous 25 questions about what other Page 189 1 HIGHLY CONFIDENTIAL AEO 2 people's mental state was. I 3 think that's a good idea. Let's 4 carry on. 5 Counsel? 6 Q. Did you ever sign a fee 7 agreement with Alan Dershowitz? 8 A. No. 9 Q. Did you ever appear in court 10 with Alan Dershowitz? 11 A. No. 12 Q. Did you ever appear in court 13 yourself? 14 A. No. 15 Q. Did you ever have any 16 contact with any law enforcement 17 officers while you were in New York? 18 A. No. 19 Q. Any police? 20 A. No. 21 Q. After you left that meeting 22 with Alan Dershowitz, when did you see 23 him next? 24 A. I can't remember. I think 25 it was at dinner. There was a dinner, Page 190 1 HIGHLY CONFIDENTIAL AEO 2 yeah. 3 Q. And do you know whether the 4 dinner was before or after you went to 5 South Africa? 6 A. I can't remember the 7 specific time period, so I don't 8 remember if it was before or after. 9 But it was -- 10 Q. Where was the dinner? 11 A. It was in a restaurant in 12 New York. 13 Q. What restaurant? 14 A. I can't remember. 15 Q. Who else was there? 16 A. I remember Alan, Jeffrey, 17 myself. And I can't remember if 18 others -- if there were other people 19 there. 20 Q. What type of restaurant was 21 it? 22 A. It was a nice restaurant. 23 Q. Do you remember the type of 24 cuisine? 25 A. No. Page 191 1 HIGHLY CONFIDENTIAL AEO 2 Q. When was the next time -- 3 what do you remember discussing that 4 dinner? 5 A. The legal matter I had. 6 Q. Did you consider him to be 7 your lawyer at that dinner? 8 A. Yes, I did. 9 Q. What's the next time that 10 you saw Alan Dershowitz? 11 A. At Jeffrey's New York 12 mansion. 13 Q. When was that? 14 A. It was after the second time 15 I had met Alan. 16 Q. Had you been to South 17 Africa? 18 A. I can't remember. 19 Q. Tell me what happened during 20 that encounter. 21 A. I walked in the room -- I 22 walked in the house. Jeffrey and 23 and Alan were there. 24 Q. What happened after you 25 walked in the house? ![](_page_191_Picture_26.jpeg) Page 192 1 HIGHLY CONFIDENTIAL AEO 2 A. I -- it was really strange, 3 because didn't like me. And so 4 when I arrived, we had -- I think -- I 5 can't remember if I had, like, water 6 or whatever. 7 took me upstairs. I 8 remember there was a room. I didn't 9 quite understand what was going on at 10 the time. I knew obviously something 11 was going on, because I never met 12 socially. 13 So started undressing 14 me in the room. She started 15 undressing me by the bed. We got on 16 the bed. I kind of knew what was 17 going on from that. The girls were 18 often forced to have sex with each 19 other for Jeffrey's pleasure, so it 20 was just another occasion, I guess. 21 Jeffrey then walked in the 22 room. He started masturbating under 23 his clothes. He put his hand in his 24 trousers. A few minutes later Alan 25 walked in the room. He started Page 193 1 HIGHLY CONFIDENTIAL AEO 2 undressing, he got on the bed with 3 and myself, and we basically had 4 a three-way sexual interaction. 5 Q. Was Alan fully unclothed? 6 A. During -- when? At what 7 specific -- he walked in with clothes. 8 Q. And he got fully undressed? 9 A. Yes. 10 Q. So you saw his entire naked 11 body? 12 A. Yes. 13 Q. Did you notice anything 14 specific about his body? 15 A. Not that I recall. I mean 16 -- yeah, not that I -- I can't really 17 remember. It was quite a -- it was 18 a -- it wasn't a pleasant experience. 19 Q. What did you do with Alan? 20 A. I gave him oral sex, 21 masturbated him. 22 Q. Anything else? 23 A. He did the same with 24 He performed the same on me. 25 Q. Did he ejaculate? Page 194 1 HIGHLY CONFIDENTIAL AEO 2 A. He did, yeah. 3 Q. In your mouth? 4 A. No. 5 Q. Did you have intercourse 6 with him? 7 A. No, not penetration, no. 8 Q. Did you see him ejaculate 9 more than once? 10 A. No, I didn't see him 11 ejaculate more than once. 12 Q. You didn't notice any scars? 13 MS. MCCAWLEY: Objection. 14 A. I don't recall specific 15 markings on every man I've been with 16 body. So it's not something -- I 17 wasn't ravishing Alan's body. I was 18 trying to close my eyes and just get 19 it done so I could go home and watch 20 TV, really. So I wasn't really aware. 21 I didn't really like kind of 22 go, woo, his body. I don't -- I don't 23 recall his body at all. Like, I don't 24 make a mental note of every man's body 25 I've slept with. Page 195 1 HIGHLY CONFIDENTIAL AEO 2 Q. Other than Jeffrey, is that 3 the first time you had sex with 4 another man in his home or on his 5 property? 6 A. Sorry, can you just repeat 7 the question. 8 MR. GUIRGUIS: Or rephrase 9 it. 10 THE WITNESS: I'll just read 11 it. 12 MR. GUIRGUIS: If you 13 understand it. 14 A. Yeah, he was the only 15 person, Alan Dershowitz. 16 Q. Did you have sex with him 17 more than once? 18 A. No. 19 Q. At the occasion you just 20 described, did he have an erection? 21 A. It was -- it was it 22 wasn't particularly hard. It was 23 pretty disappointing. 24 Q. And where did he ejaculate? 25 A. I had given him oral sex Page 196 1 HIGHLY CONFIDENTIAL AEO 2 and, well, he ejaculated -- he 3 ejaculated. I mean, there's only so 4 many places a man can ejaculate. He 5 didn't ejaculate on me. 6 He didn't ejaculate in my 7 mouth. I gave him oral and I 8 masturbated him and finished him off. 9 He ejaculated over himself, me. 10 Just -- there wasn't a lot of 11 ejaculation. I don't remember a lot 12 of sperm. I didn't see massive 13 amounts of semen. But I just remember 14 him ejaculating, but it wasn't in my 15 mouth. 16 Q. And in terms of time frame, 17 the best you can say is this is after 18 you had been to the island a few 19 times? 20 A. That's correct. 21 Q. And you don't remember if it 22 was before or after you went to South 23 Africa? 24 A. I can't remember 25 specifically, no. Page 197 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you see Alan Dershowitz 3 again after that one occasion? 4 A. No. 5 Q. So you saw him at the 6 office, you say saw him at dinner, and 7 you saw him that one time in the 8 bedroom at Jeffrey's house? 9 A. That's correct. 10 MS. MENNINGER: It's 1:00. 11 I think we should take a small 12 lunch break. 13 (Time noted: 1:01 p.m.) 14 (Luncheon recess.) 15 16 17 18 19 20 21 22 23 24 25 Page 198 1 HIGHLY CONFIDENTIAL AEO 2 AFTERNOON SES S I ON 3 (Time noted: 1:54 p.m.) 4 MR. GUIRGUIS: Counsel, 5 before you commence with your 6 questioning, I think there's one 7 issue from this morning that the 8 witness wants to correct herself 9 on, so just let her do that now. 10 THE WITNESS: I said earlier 11 that I would just like to correct 12 that my lawyers are paying for -- 13 they are covering my hotel 14 expense. 15 MS. MENNINGER: Thank you 16 for that clarification. 17 THE WITNESS: And -- 18 MR. GUIRGUIS: Go ahead. 19 THE WITNESS: And my flight. 20 MS. MENNINGER: Thank you. 21 , RESUMED, 22 having been previously and duly 23 sworn, was examined and testified 24 further, as follows: 25 CONTINUED EXAMINATION Page 199 1 HIGHLY CONFIDENTIAL AEO 2 BY MS. MENNINGER: 3 Q. Going back to your first 4 conversation with Alan Dershowitz, at 5 any point in that conversation, had 6 Mr. Dershowitz agreed to act as your 7 lawyer? 8 A. Yes. 9 Q. Did he do anything in terms 10 of contacting anyone on your behalf? 11 MR. GUIRGUIS: Objection. 12 Do not answer. 13 Q. What was the specific legal 14 15 matter that you were seeking representation for? 16 MS. MCCAWLEY: Objection. 17 MR. GUIRGUIS: Objection. 18 Do not answer. 19 Q. 20 purpose 21 the room for during that conversation? What did you understand the of Jeffrey Epstein being in 22 A. Jeffrey was there to support 23 me and Jeffrey was looking after me. 24 Q. When you engaged in sexual 25 conduct with Alan Dershowitz, did you Page 200 1 HIGHLY CONFIDENTIAL AEO 2 see any evidence on his body of his 3 surgical procedure? 4 A. I don't recall seeing 5 anything. I can't remember. 6 Q. Did you see any bandages? 7 A. I can't remember. 8 Q. Did you see him bleed 9 through his penis? 10 A. Not that I recall. 11 Q. Do you recall seeing 12 Mr. Dershowitz bleed through his 13 penis? 14 MS. MCCAWLEY: Objection, 15 asked and answered. 16 A. Not that I recall. 17 Q. When you were on the island, 18 sometime less than ten times, you 19 think, did you ever use any drugs? 20 A. No. 21 Q. Did you use cocaine? 22 A. No. 23 Q. Did you ever get thrown off 24 the island for using cocaine? 25 A. No. Page 201 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you drink alcohol? 3 A. No. 4 Q. None? 5 A. During on the island, 6 whenever I was around Jeffrey, 7 absolutely not. 8 Q. Other than going to the 9 island, did you travel with Jeffrey 10 anywhere else? 11 A. No. 12 Q. Did you ever travel anywhere 13 with Ghislaine Maxwell? 14 A. No. 15 Q. Did you ever fly on an 16 airplane with Ghislaine Maxwell? 17 A. I don't -- I don't remember. 18 Q. You don't remember any time 19 you flew on a plane with Ghislaine 20 Maxwell? 21 A. No, I don't remember. There 22 were always many people on the plane. 23 Q. When you refer to the plane, 24 you're referring to a private plane? 25 A. Jeffrey's plane, yes. Page 202 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you travel on more than 3 one plane of Jeffrey's? 4 A. Not that I -- no, I don't 5 remember. I don't remember. 6 Q. Can you visualize in your 7 head any other layout of a different 8 type of plane than the one you drew in 9 Defendant's Exhibit 1? 10 A. No. 11 Q. Why did you go to South 12 Africa in early 2007? 13 A. To visit my family. 14 Q. And which family members did 15 you visit? 16 A. My father and my stepmother. 17 Q. Anyone else? 18 A. No. 19 Q. Any siblings? 20 A. My younger brother and 21 sister lived with my parents; my dad 22 and my stepmom and their two younger 23 children. 24 Q. Did you see any school 25 friends there? Page 203 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Who paid for your plane 4 ticket to go to South Africa? 5 A. Jeffrey did. 6 Q. How did that come about? 7 A. I wanted to see my family, 8 and he funded the plane ticket because 9 he was funding everything else at that 10 time. 11 Q. What else was he funding at 12 that time? 13 A. Accommodation, travel, 14 taxis, food, my prescription that I 15 had to pay for, for the prescription 16 that -- prescription drugs. 17 Q. Had you taken any 18 prescriptions for mental health 19 disorders before October 2006? 20 A. No. 21 Q. Have you taken any since May 22 of 2007? 23 A. Yes, I have. 24 Q. Which ones? 25 A. Paroxetine. Page 204 1 HIGHLY CONFIDENTIAL AEO 2 Q. Anything else? 3 MS. MCCAWLEY: I'm going to\ 4 object. There's no time frame on\ 5 this. You're talking about one\ 6 year? All the years from 2007 to\ 7 2015? Which I would say is\ 8 inappropriate for a nonparty\ 9 witness to talk about her -- if\ 10 you're talking generally about\ 11 prescriptions. 12 [REDACTED]\ [REDACTED]\ [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED]\ [REDACTED] [REDACTED] 1 2 15 • • E • • • • • • • HIGHLY CONFIDENTIAL AEO \= - - M = . M - 1 \_ - 1 - - 1 M = - EMU --1 - IN U MI - - - - - \= M - - M • = UMME I - = M 1 - - - - - I= M \_ _ M - MI M 1 2 I I I I I I I • • • • • • • • • 19 • • • • • • HIGHLY CONFIDENTIAL AEO U 1 M M M - U - M 1 U U - - - - U I= I - U - - U NEI I - . - - • MI MI - M I= - - - - M M I ■ **M** ■ **MI I \_** **I M IMM** **U** **-** **U** **U - -** **U I = I** **EMI - - - MI - -** Page 207 1 HIGHLY CONFIDENTIAL AEO 2 I had been prescribed were incorrect. 3 Q. Those are the ones you 4 mentioned earlier in your testimony? 5 A. Yeah. I had to stop and 6 change medication, because I was first 7 started on lithium. The lithium made 8 me put on weight at quite a rapid 9 rate, so I was put on so many 10 different types of medication because 11 I didn't -- not every one agrees with 12 you. Weight was a massive issue for 13 Ghislaine and Jeffrey, so the lithium 14 just didn't work for me. I mean, I 15 put on weight quite quickly. 16 Q. What did Ghislaine Maxwell 17 say to you about weight? 18 A. Well, what did she not say? 19 She bullied me massively about my 20 weight. 21 Q. What did see say? 22 A. I was told that I would lose 23 Jeffrey's financing if I didn't lose 24 weight, and I would not -- they would 25 not help me get into FIT. Page 208 1 HIGHLY CONFIDENTIAL AEO 2 Q. Who were you told that by? 3 A. Ghislaine and Jeffrey. 4 Q. In the same conversation? 5 A. Various conversations. 6 Q. Tell me your conversations 7 with Ghislaine. When did she say that 8 to you? 9 A. On the island. 10 Q. Before you went to South 11 Africa? 12 A. Yes. 13 Q. And was that in person? 14 A. Yes. 15 Q. Who else was present? 16 A. , a girl 17 named and a girl named 18 Sorry, I just remembered a name. A 19 girl named and a girl named 20 21 Q. So they were all present 22 when you had a discussion with 23 Ghislaine about your weight on the 24 island? 25 A. Yes. Page 209 1 HIGHLY CONFIDENTIAL AEO 2 Q. And what did Ghislaine say 3 to you about your weight when you were 4 on the island in front of all these 5 people? 6 A. I can't remember the 7 specific conversation, how it went. 8 We got into an argument about my 9 weight, quite a heated argument. 10 Q. What do you recall about the 11 argument? 12 A. I recall it got so heated 13 that I ran off and tried to swim off 14 the island. I wanted to get as far 15 away from Jeffrey and Ghislaine as 16 possible. 17 Q. Okay. And then what 18 happened? 19 A. I left the main house I 20 took -- there's like a buggy thing. 21 It was evening. I drove to a 22 particular spot on the island. It was 23 -- so Jeffrey's island is quite rocky 24 around the edges, so -- and it's not 25 really -- you can't just go into the Page 210 1 HIGHLY CONFIDENTIAL AEO 2 water. It was quite steep. And, 3 well, I didn't really know how to swim 4 away. i didn't know how to escape. 5 But I wanted to, at that precise 6 moment, get as far as away from him as 7 possible. 8 Q. So you had a heated argument 9 about your weight with Ghislaine? 10 A. Ghislaine and Jeffrey. 11 Q. They were both there? 12 A. Yes. 13 Q. And do you remember anything 14 that was said during that argument? 15 A. It was basically an 16 ultimatum that I either lose weight 17 or -- or that's it. 18 THE WITNESS: Sorry, can I 19 -- sorry. I need to get a 20 headache tablet, if you don't 21 mind. 22 MS. MENNINGER: Go off the 23 record for a second. 24 (An off-the-record 25 discussion was held.) Page 211 1 HIGHLY CONFIDENTIAL AEO 2 MS. MENNINGER: Go back on. 3 Q. You were given an ultimatum 4 to lose weight or what? 5 A. They wouldn't help me to get 6 into FIT, and that my time with 7 Jeffrey would be -- would end. 8 Q. Who said what? 9 A. Well, they both -- they both 10 said it in so many words. I can't 11 remember the exact conversation. I 12 remember it being heated. I remember 13 them giving me the ultimatum. I think 14 a few curse words were shared. I 15 can't -- it was a very heated 16 conversation. I can't remember the 17 exact words. 18 Q. Was there? 19 A. No, I don't recall her being 20 there. 21 Q. Were you taking the 22 medications that you talked about 23 earlier during this time period? 24 A. Yes. 25 Q. Had you put on weight since Page 212 1 HIGHLY CONFIDENTIAL AEO 2 taking those medications? 3 A. Yes, I had. And I had also 4 put on weight because I wasn't allowed 5 to smoke any cigarettes at all, with 6 Jeffrey on the island or anywhere near 7 Jeffrey. Jeffrey wasn't allowed to 8 know that we smoked. 9 So I put on also a lot of 10 weight as well, in conjunction with 11 the lithium. So yeah. 12 Q. How did the topic of your 13 weight come up? 14 A. Well, I wasn't as skinny as 15 the other girls, and Jeffrey liked his 16 girls very thin. 17 Q. Were you interested in 18 modeling at that point in time? 19 A. I was doing freelance 20 modeling at the time, but I mean, I 21 wasn't exactly going to be a Kate 22 And the modeling agency thought 23 I wasn't petite enough for them 24 either. 25 I would like to clarify I Page 213 1 HIGHLY CONFIDENTIAL AEO 2 wasn't actually fat; I was normal 3 weight, by the way, just to make that 4 clear. I am 64, 65 kilograms at that 5 time. 6 Q. Why did you understand that 7 Jeffrey and Ghislaine wanted you to 8 lose weight? 9 A. I was one of the girls that 10 Jeffrey had sexual encounters with 11 regularly. He liked his girls thin. 12 Q. Did you ask Jeffrey to help 13 you become a model? 14 A. No. I wanted 15 degree and an education. to get a 16 Q. So you were not attempting 17 to become a model at that point in 18 time? 19 A. No. I wanted to get an 20 education as opposed to being a model. 21 Q. Did you talk to 22 about becoming a model? 23 A. 24 during that 25 freelancing -- as I was freelancing time, or trying to get work, Jeffrey kept us on a Page 214 1 HIGHLY CONFIDENTIAL AEO 2 little string with his massage 3 payments, so I wanted to earn a 4 separate income while I was doing my 5 education to fund my living expenses. 6 So, you know, I wanted to potentially 7 increase my jobs. 8 But no, my job was not to be 9 a high-fashion model. I wanted to get 10 my degree, get my education and work 11 in the fashion industry. 12 Q. You had worked as a model 13 during college earlier, correct? 14 A. Yes. 15 Q. And you saved up money from 16 that job, correct? 17 A. Yes. 18 Q. And you had used that money 19 to fly to New York at some point, 20 correct? 21 A. Yes. 22 Q. And what you're saying now 23 is you would also potentially do 24 modeling while you were studying in 25 the future? Page 215 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection. 3 That's not at all what she's 4 saying. 5 A. As in future, as in would I 6 do modeling now? 7 Q. No. I'll rephrase the 8 question. 9 A. Please. 10 MS. MENNINGER: Let's take a 11 break, go off the record. And 12 when you finish the salad, we'll 13 proceed. 14 (Time noted: 2:14 p.m.) 15 (Recess.) 16 (Time noted: 2:15 p.m.) 17 MS. MENNINGER: Go back or 18 the record. 19 Q. At the time you were having 20 a discussion with Jeffrey and 21 Ghislaine about your weight when you 22 were on the island, did you have any 23 intention of being a model at that 24 time? 25 A. I was a freelance model. I Page 216 1 HIGHLY CONFIDENTIAL AEO 2 wanted to increase my workload to help 3 fund my living expenses. So it was 4 not my intention to be a full-time 5 model, because I quite clearly applied 6 to a college to get an education that 7 I was promised by Jeffrey Epstein. 8 Q. Between January of 2007 and 9 today, have you worked as a model? 10 A. No. 11 Q. When you left for South 12 Africa, did you have a ticket to 13 return to the U.S.? 14 A. At that time, a return 15 ticket hadn't been booked by Jeffrey 16 yet. 17 Q. You traveled to South Africa 18 to visit your family without a return 19 ticket? 20 A. Yes. 21 Q. Did anyone travel with you 22 to South Africa? 23 A. No. 24 Q. Your mother was not in South 25 Africa when you went to South Africa Page 217 1 HIGHLY CONFIDENTIAL AEO 2 on that occasion in 2007, correct? 3 A. Correct. 4 Q. What did you do while you 5 were in South Africa in February of 6 2007? 7 A. Spend time with my family. 8 Q. Anything else? 9 A. I spent time with my family, 10 that's -- that's it. 11 Q. Did you visit any modeling 12 agencies? 13 A. Yes, I did visit some 14 modeling agencies. 15 Q. Which modeling agencies did 16 you visit? 17 A. I can't remember the exact 18 names. The modeling agencies were on 19 Long Street in Cape Town. I visited 20 several modeling agencies on Long 21 Street, and Bree Street as well. Bree 22 Street and Long Street and a few 23 others in central Cape Town. So I 24 visited a few, actually. 25 Q. Had you worked with any of Page 218 1 HIGHLY CONFIDENTIAL AEO 2 those modeling agencies in the past? 3 A. No. 4 Q. Did you have any connections 5 with any of those modeling agencies? 6 A. No. 7 Q. Did you have an agent at 8 that time? 9 A. No. 10 Q. What did you do when you 11 visited the modeling agencies in Cape 12 Town in February of 2007? 13 A. I was requested to look for 14 a PA for Mr. Epstein. 15 Q. What does that mean? 16 A. It means that he told me he 17 would pay me a certain amount of money 18 to find him a PA in South Africa. 19 Q. What do you understand the 20 initials PA to stand for? 21 A. Personal assistant. 22 Q. What are the job 23 responsibilities of a personal 24 assistant? 25 A. To book flights, type, do Page 219 1 HIGHLY CONFIDENTIAL AEO 2 faxes. Basically a PA is your -- a 3 CEO's right-hand man of, you know, 4 company's -- anything business-wise. 5 They do everything, really, for that 6 person. 7 Q. When did Jeffrey ask you to 8 find him a PA while in South Africa? 9 A. Before I went. 10 Q. Did you agree to do that? 11 A. Yes. 12 Q. And you did go to the 13 modeling agencies? 14 A. I told Jeffrey I did, but I 15 actually -- I went to a couple and 16 then I just -- it wasn't right. My 17 gut instinct was -- yeah. 18 Q. What happened when you went 19 inside the modeling agencies in Cape 20 Town? 21 A. I was humiliated I was 22 completely embarrassed. I couldn't 23 even ask them what Jeffrey was 24 wanting. I mean, it was so absolutely 25 ridiculous, his request of me finding Page 220 1 HIGHLY CONFIDENTIAL AEO 2 him a PA. 3 Q. So what happened? 4 A. So I I asked if they had 5 any girls that would want to travel; 6 they would be put up in accommodation 7 and they would be a PA. 8 And when I actually spoke to 9 the modeling agencies, they actually 10 laughed at me, because it was quite 11 ridiculous that a young 22-year-old 12 was asking a modeling agencies for a 13 18-year-old PA for a multi-billionaire 14 who had several already. 15 Q. So you recall a conversation 16 where the person you were speaking to 17 started laughing? 18 A. Yes. 19 Q. What type of person were you 20 describing that you were looking for? 21 A. The same specifications that 22 Jeffrey told me: She had to be 18, 23 thin, very young looking, pretty. 24 Q. Anything else? 25 A. Well, bright and able to Page 221 1 HIGHLY CONFIDENTIAL AEO 2 type. 3 Q. Did you go on a diet while 4 you were in South Africa? 5 A. I was forced to go on a 6 diet. 7 Q. Tell me what you mean by 8 forced to go on a diet. 9 A. After that incident on the 10 island in -- it was December, when 11 Ghislaine brought me back to the main 12 house after she -- she sent a search 13 party. She led a search party to find 14 me on the island and bring me back. 15 Q. Ghislaine led a search 16 party? 17 A. Yeah, yeah, yeah. She got 18 everyone together and they all went 19 looking for me when I disappeared. 20 Q. Who went looking for you? 21 A. , Jeffrey, the 22 girls, Ghislaine. 23 Q. Which girls? 24 A. and the girl 25 named Page 222 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did Jeffrey go searching for 3 you? 4 A. Yes. 5 Q. How do you know that? 6 A. I was told. 7 Q. About whom? 8 A. By and the other 9 girl. 10 Q. Where were you located? 11 A. On the island. 12 Q. Where on the island? 13 A. A corner of the island. 14 Q. On the water? 15 A. No. It was quite a long 16 drop off the -- it was like a 17 cliff-type -- I wasn't able to jump or 18 get in the water. 19 Q. Your intent was to swim off 20 21 the island, but you didn't make it into the water? 22 23 A. No, because I would have killed myself, so it wasn't safe. 24 25 Q. So who located you on this corner of the island? Page 223 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember who got to 3 me first. I remember the -- I can't 4 remember who found me first. 5 Q. Do you remember anyone who 6 found you? 7 A. Yes, I was definitely found 8 because I didn't have enough time to 9 find a different location on the 10 island so I could get off and swim 11 away from Jeffrey and Ghislaine. 12 Q. Once they found you, what 13 happened? 14 A. I was brought back to the 15 main house. 16 Q. How were you brought back? 17 A. The same way that I got 18 there, on the, like, beach buggy, 19 black 4-by-4, not -- what are they. 20 Quad things. 21 MS. MCCAWLEY: Quad bikes? 22 A. Quad bikes, yeah. 23 Q. Did you bike back? 24 A. Yes. 25 Q. Accompanied by some people? Page 224 1 HIGHLY CONFIDENTIAL AEO 2 A. I was accompanied back, yes. 3 Q. By whom? 4 A. I can't remember 5 specifically who it was. 6 Q. Okay. And once you got 7 back, what happened? 8 A. They tried to calm me down. 9 Q. And then what happened? 10 A. From that evening onwards, I 11 was -- Jeffrey put me on the Atkins 12 Diet. 13 Q. Did you calm down? 14 A. Yes, I did. 15 Q. Did you take some more 16 medications? 17 A. No. When you're on 18 prescription drugs, you only take them 19 at a specific required time. 20 Generally you don't take more than 21 your prescription when you're on 22 prescription drugs, so you don't kind 23 of just throw tablets in your mouth. 24 You kind of just take them in the 25 morning or -- Page 225 1 HIGHLY CONFIDENTIAL AEO 2 Q. I asked a bad question. 3 A. Yeah. 4 Q. You said earlier that the 5 prescriptions were causing you to gain 6 weight, I thought you said. 7 A. Yes. 8 Q. And then you just said you 9 were put on a diet after this event, 10 correct? 11 A. Yes. 12 Q. And what do you mean by you 13 were put on a diet? 14 A. Jeffrey said, you either go 15 on the Atkins Diet, or I can go. 16 Q. Go meaning off the island? 17 A. As in, don't call me back, 18 Sarah. 19 Q. Here's the question: Did 20 you discontinue the medications at the 21 same time you went on the Atkins Diet? 22 A. No. 23 Q. And how long were you on the 24 Atkins Diet? 25 A. Long enough for my kidneys Page 226 1 HIGHLY CONFIDENTIAL AEO 2 to be incredibly painful and for me to 3 no longer continue on the diet because 4 it was unsafe to do so. 5 Q. Did you seek medical help 6 for that pain? 7 A. I just took painkillers. 8 Q. What painkillers did you 9 take? 10 A. I can't remember what 11 painkillers. 12 Q. Prescription or 13 over-the-counter? 14 A. Over-the-counter. 15 Q. Were you on the diet for 16 more than a week? 17 A. Yes, I was. 18 Q. More than a month? 19 A. Yes. 20 Q. More than two months? 21 A. I can't remember. 22 Q. Were you on the diet the 23 whole time you were in South Africa? 24 A. Yes. 25 Q. Did you continue on the diet Page 227 1 HIGHLY CONFIDENTIAL AEO 2 after you returned? 3 A. Yes. 4 Q. What was the lowest weight 5 that you reached during that period of 6 time on the diet? 7 A. 56 kilograms. 8 Q. Had you ever weighed 9 56 kilograms in your adult life 10 A. No. 11 Q. -- previously? 12 A. No. 13 Q. Have you since? 14 A. No. 15 Q. Did you speak to Jeffrey 16 again about that diet? 17 A. Multiple times. 18 Q. What did you say? 19 A. I complained frequently 20 about the diet that he had put me on, 21 because it was seriously affecting my 22 physical health as well as my mental 23 health. Yeah, it's a pretty hectic 24 diet. 25 Q. The time you were on this Page 228 1 HIGHLY CONFIDENTIAL AEO 2 diet, did you have a boyfriend? 3 A. II, yeah. Yes. 4 Q. Who was your boyfriend at 5 the time? 6 A. 7 Q. 8 A. That's This. 9 10 Q. What's last name? 11 A. I think it's 12 Q. Where did he live? 13 A. In the Upper East Side. 14 Q. Did you talk to about 15 your diet? 16 A. Yes. 17 Q. Were you living with 18 A. Not at -- not when I was in 19 South Africa. 20 Q. When you returned from South 21 Africa, did you move in with 22 A. Yes, I did, to get away from 23 Jeffrey. 24 Q. And where on the Upper East 25 Side did live? Page 229 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember. 3 Q. Walkup or elevator building? 4 A. Elevator. 5 Q. How big was that apartment? 6 A. It's relatively small. 7 Q. More than one bedroom? 8 A. No, it was just one bedroom. 9 It was a small, tiny apartment. 10 Q. And what did do for a 11 living? 12 A. He was a 13 Q. Where did he work? 14 A. He worked at -- I can't 15 remember where he worked. 16 Q. How did you meet 17 A. At a delicatessen, when I 18 was buying food. 19 Q. Had you started dating him 20 before you went to South Africa? 21 A. I think we had gone on a 22 couple dates or something. 23 Q. Where had you gone on your 24 dates? 25 A. I can't remember. Page 230 1 HIGHLY CONFIDENTIAL AEO 2 Q. When you were in South 3 Africa, did you have contact with 4 5 A. Once or twice, like three 6 times. Well, we were sort of seeing 7 each other, so I don't know how many 8 phone times I spoke to him in a month. 9 Yeah, a few times I spoke to 10 Q. When you spoke to him, did 11 he ask you to move in with him when 12 you returned? 13 A. I wouldn't really say that. 14 I wouldn't really say he asked me to 15 move in. 16 Q. Okay. What would you say? 17 A. I asked him for me to move 18 in with him. 19 Q. Okay. While you were in 20 South Africa, did you receive any 21 phone calls from Jeffrey? 22 A. Yes. 23 Q. Did you want Jeffrey to call 24 you there? 25 A. Yes. He was helping me get Page 231 1 HIGHLY CONFIDENTIAL AEO 2 into FIT. 3 Q. Any other reason for you to 4 have communications while you were in 5 South Africa? 6 A. I was living in his 7 apartment. 8 Q. In South Africa? 9 A. In New York. 10 Q. So you wanted to have 11 communications with Jeffrey while you 12 were in South Africa because you were 13 living in his apartment in New York? 14 MS. MCCAWLEY: Objection. 15 A. And he was going to -- he 16 promised that he would pay for my 17 education. And I was staying in his 18 apartment and he was funding my life, 19 so of course I would want him to 20 contact me. 21 And, also, he was still - 22 he told me he would pay for my return 23 ticket. So, yeah, of course I wanted 24 him to contact me. 25 (An off-the-record Page 232 1 HIGHLY CONFIDENTIAL AEO 2 discussion was held.) 3 Q. Did you have an intention 4 while you were in South Africa to go 5 to Miami upon your return? 6 A. I think there was a vague 7 conversation about it, but I had no 8 real intention of going to Miami. I 9 had a conversation with about 10 it. 11 Q. What, if anything, were you 12 going to do in Miami? 13 A. I can't remember. 14 Q. Did you have a job lined up 15 in Miami? 16 A. I can't remember. 17 Q. An internship? 18 A. It was something to do with 19 Jeffrey, that Jeffrey, and -- 20 it would have -- it would have -- it 21 was through Jeffrey, something with 22 Miami. I can't remember what it was 23 for or -- I don't remember. It 24 didn't -- it was just a conversation 25 about Miami. Page 233 1 HIGHLY CONFIDENTIAL AEO 2 Q. So not a real firm plan to 3 go to Miami? 4 A. No, no. 5 Q. Were you disappointed when 6 you didn't go to Miami? 7 A. No, no, not at all. 8 Q. And you weren't planning to 9 be a model in Miami, for example? 10 A. No. 11 Q. You said that Jeffrey had 12 agreed to pay for your education? 13 A. Yes. 14 Q. Did you apply to any other 15 school besides FIT? 16 A. No. 17 Q. Do you know whether you met 18 the qualifications to get into FIT? 19 MR. GUIRGUIS: Objection, 20 form. 21 A. Yes. 22 MR. GUIRGUIS: 23 Comprehensibility. 24 MS. MENNINGER: She seemed 25 to understand it just fine. Page 234 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: I don't know 3 if she did, but fine. 4 Q. Do you know how much FIT was 5 supposed to cost per year? 6 A. No. 7 Q. Did you believe it to be 8 expensive? 9 A. All schools are expensive. 10 Q. You had previously attended 11 Queen Margaret College; is that right? 12 A. Queen Margaret University. 13 Q. My apologies. 14 How much did Queen Margaret 15 University cost? 16 A. I can't remember. 17 Q. Did you apply for any 18 financial aid for FIT? 19 A. No. Jeffrey was covering 20 FIT. 21 Q. That's what Jeffrey told 22 you? 23 A. Multiple, multiple times. 24 Q. Did Ghislaine Maxwell say 25 anything to you with regards to FIT? Page 235 1 HIGHLY CONFIDENTIAL AEO 2 A. It was various 3 conversations. It was known among 4 everyone that I was going to FIT, and 5 Jeffrey -- everyone knew he was 6 helping me to get into FIT. It was 7 common knowledge. 8 Q. You described earlier that 9 Ghislaine was helping review your 10 application and your essay. 11 Was there something else 12 that she was doing to help you? 13 A. Well, she said she would, 14 but whether she did, I have no idea. 15 She said she would. Whether she made 16 calls, I doubt, because I didn't end 17 up at FIT. So... 18 Q. Did you get accepted there? 19 A. I never heard from anyone at 20 FIT. 21 Q. You never got a response? 22 A. No. 23 Q. Did you have an email 24 address at that time? 25 A. Yes, I did. Page 236 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you have a copy of your 3 FIT application? 4 A. I think it's somewhere. I 5 think it's in the email. 6 Q. There's an essay and then 7 there's an application, correct? 8 A. Yes, that's correct. I can 9 find the essay if you want. 10 MR. GUIRGUIS: I think we've 11 already produced that essay. 12 Q. While you were in South 13 Africa, did you have any phone 14 conversation with Ghislaine? 15 A. Yes. 16 Q. When was that? 17 A. Through various times 18 throughout my stay in South Africa. 19 Q. What phone were you using 20 while you were in South Africa? 21 A. I had the BlackBerry that 22 they had given me, and they also 23 phoned my parents' landline as well. 24 Q. Who is they? 25 A. Jeffrey, Ghislaine and Page 237 1 HIGHLY CONFIDENTIAL AEO 2 3 Q. Did Ghislaine speak to your 4 parents? 5 A. Yes. 6 Q. Who did she speak to? 7 A. I can't remember if she 8 spoke -- I can't remember, actually. 9 I can't remember who she spoke to. 10 Q. How do you know that she 11 spoke to your parents? 12 A. Because I remember it being 13 a huge thing, and my family -- because 14 they couldn't quite understand what 15 Jeffrey and Ghislaine were doing 16 paying for their daughter's education, 17 and they obviously thought -- 18 suspected something was going on. 19 Q. So how do you know that 20 someone spoke to your parents? 21 A. Because my parents and I 22 fought about it. 23 Q. Did your parents tell you 24 that they spoke to Ghislaine? 25 A. I -- I can't remember. I Page 238 1 HIGHLY CONFIDENTIAL AEO 2 remember having a huge row with my 3 family because they had spoken to -- 4 so there were multiple phone calls 5 during the duration of that month, 6 okay. There's not a specific call. 7 There were multiple calls. 8 There were multiple emails. 9 I produced emails during that time 10 frame, back-and-forth emails between 11 and myself. So they 12 were -- they contacted me regularly. 13 Ghislaine, and Jeffrey 14 Epstein phoned me a few times. 15 Q. Did your parents tell you 16 that they spoke to Ghislaine? 17 A. I knew with my own -- that 18 they had spoken to Ghislaine. 19 Q. How did you know that? 20 A. Because I know that they had 21 spoken. They told me that they had 22 spoken. I know she made communication 23 with my family. 24 Q. Your family told you that 25 they had spoken to Ghislaine? Page 239 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection, 3 asked and answered. 4 A. Yes. 5 Q. Who in your family told that 6 you they had spoken to Ghislaine? 7 A. I can't remember whether it 8 was my stepmother or my father. I 9 cannot remember which one it was. 10 Q. What did your stepmother or 11 father tell you they had discussed 12 with Ghislaine? 13 14 15 16 17 18 19 20 A. That she had reassured them that my education would be paid for and -- basically that. You know, they spent a lot of time and effort reassuring my family they weren't abusing me, which they were, and that they weren't going to traffic me, which they were. 21 22 So there you go. I had to lie to my family. 23 24 name? Q. What is your stepmother's 25 A. ![](_page_239_Picture_13.jpeg) Page 240 1 HIGHLY CONFIDENTIAL AEO 2 Q. And do you have an email 3 address or phone number for her? 4 A. No, I don't. 5 MR. GUIRGUIS: Objection. 6 No current information. Same 7 objection as at the outset of 8 deposition. 9 MS. MENNINGER: Are you 10 instructing her not to answer? 11 MR. GUIRGUIS: I am 12 instructing her not to answer. 13 Q. Where does 14 MR. GUIRGUIS: And I'm again 15 offering you to the opportunity 16 to proffer a reason for these 17 questions. And I -- 18 MS. MENNINGER: I'll tell 19 you. Your client has signed an 20 affidavit and a complaint 21 discussing this conversation, and 22 I'm asking for contact 23 information for a witness to the 24 conversation, the person who 25 actually supposedly had a phone Page 241 1 HIGHLY CONFIDENTIAL AEO 2 conversation with my client. And 3 you're telling me I can't follow 4 up with those witnesses. 5 Q. So please tell me how to 6 reach your stepmother, 7 A. I'm not going to offer you 8 my family's address details. 9 MR. GUIRGUIS: You don't 10 have to answer. 11 Go on. 12 come 13 back and answer it another day, 14 but... 15 Q. Where does 16 live? 17 A. She lives in Cape Town. 18 Q. Where in Cape Town? 19 A. I don't know. 20 Q. Have you been in touch with 21 her? 22 A. Not recently, no. 23 Q. When is the last time you 24 communicated with her? 25 A. A while back. Page 242 1 HIGHLY CONFIDENTIAL AEO 2 Q. More than a year? 3 A. Less than a year. 4 Q. Is she still married to your 5 father? 6 A. I presume so. 7 Q. Have you talked to him in 8 the same period of time? 9 A. No. 10 Q. Why haven't you talked to 11 your family in more than a year? 12 MS. MCCAWLEY: Objection. 13 This is getting into her current 14 relationships, which is not 15 relevant to the case and also can 16 be used for harassment. 17 Q. Why haven't you talked to 18 your family in a year? 19 A. Because I came forward. 20 Q. When did you come forward? 21 A. October, around October. 22 Q. Have you spoken to your 23 family since October? 24 A. No. 25 Q. When was the last time you Page 243 1 HIGHLY CONFIDENTIAL AEO 2 spoke to your father or stepmother 3 before October? 4 A. September. 5 Q. And did you tell them not to 6 contact you or did they tell you not 7 to contact them? 8 A. Well, I didn't -- I 9 basically said to them, either accept 10 me for who I am or we need to stop 11 this relationship. 12 Q. What did you mean by accept 13 you as you are? 14 A. I've made a lot of poor 15 choices, particularly Jeffrey, being 16 involved with Jeffrey Epstein. And 17 they feel I've come a long way from 18 that time, and they thought that they 19 didn't want me going back to a time 20 that was very traumatic for me. 21 Q. Did they tell you they would 22 not be in touch with you going 23 forward? 24 A. I didn't give them that 25 option for them to tell me that. Page 244 1 HIGHLY CONFIDENTIAL AEO 2 Q. So your not having a 3 conversation with your father and 4 stepmother in a year is because of 5 your choice to come forward? 6 A. That's correct. 7 Q. What about your mother? 8 MR. GUIRGUIS: Objection to 9 form. 10 A. What about my mother? 11 Q. Have you had contact with 12 her in a year? 13 A. Yes. 14 Q. When was the last time you 15 had contact with your mother? 16 A. Last week. 17 Q. When you returned to New 18 York and moved in with did you 19 talk to about Jeffrey Epstein? 20 A. Yes. 21 Q. What did you tell 22 A. I told him that I was 23 frightened. 24 He was incredibly concerned 25 about my weight loss and about the Page 245 1 HIGHLY CONFIDENTIAL AEO 2 weight goal that Jeffrey and Ghislaine 3 set for me, which was 52 kilograms. 4 He was scared for me, actually. 5 Q. To your knowledge, did he 6 contact anyone about it? 7 A. Not to my knowledge. 8 Q. What did he do about his 9 concern, to your knowledge? 10 A. I begged him if I could live 11 with him, and he agreed. 12 Q. How long did you live with 13 him? 14 A. It wasn't really long, 15 because I moved in with him after 16 South Africa. So about a month or 17 something. 18 Q. From the time you returned 19 from South Africa to when you returned 20 to South Africa? 21 A. is. Yeah, no, we only kind 22 of went -- we only dated for briefly. 23 It wasn't a serious relationship. 24 Yeah. So when I moved to New York 25 sorry, back to London, kind of our Page 246 1 HIGHLY CONFIDENTIAL AEO 2 relationship couldn't really go 3 anywhere, I guess. 4 Q. The long distance? 5 A. Yeah, long distance doesn't 6 really work, so... 7 Q. So about the time you moved 8 back to London is when you and he 9 broke up? 10 A. That's correct. 11 Q. Have you had contact with 12 him since then? 13 A. I had contact with him again 14 in 2008. 15 Q. Did you come back to the 16 U.S. then? 17 A. No. 18 Q. You did not come back to the 19 U.S. in 2008? 20 A. II, I did, sorry, for a 21 business trip. I went -- I did a 22 tour, yeah, from -- I think it was 23 Atlantic to Atlanta to San Francisco. 24 Q. With which business? 25 A. Belfairs International. Page 247 1 HIGHLY CONFIDENTIAL AEO 2 It's a private company at that time 3 that did private planes, the interiors 4 of private planes. 5 (An off-the-record 6 discussion was held.) 7 Q. One more time. Can you 8 spell that? 9 A. Sorry. B-A-R- -- sorry, B 10 sorry. It's getting so bad. I'm, 11 like, really bad at spelling. It's 12 B-E-L-F-A-I-R-S, Belfairs 13 International. 14 Q. You were working with them 15 in 2008? 16 A. Briefly. 17 Q. And you came for a business 18 trip? 19 A. Yes. 20 Q. And how long were you in the 21 U.S. on that occasion? 22 A. Gosh, I can't remember. It 23 was like a week. 24 Q. And who did you come with? 25 A. My manager of business. Page 248 1 HIGHLY CONFIDENTIAL AEO 2 Q. What was that person's name? 3 A. 4 Q. What's the last name? 5 A. I can't remember the last 6 name. 7 Q. So you came back to the U.S. 8 in 2008, but you did not have contact 9 with on that trip? 10 A. No. 11 Q. When did you have contact 12 with in 2008? 13 A. He moved to London in 2008. 14 Q. Did you see him in London? 15 A. Yes, I did. 16 Q. Where did you see him? 17 A. He came to stay with me in 18 London. 19 Q. Did you resume your 20 relationship? 21 A. Briefly. 22 Q. Is that the last time you've 23 had contact with him? 24 A. Yes. 25 Q. Was that about the time you Page 249 1 HIGHLY CONFIDENTIAL AEO 2 became engaged to -- 3 A. 4 Q. 5 A. and I got together at 6 the end of 2008. We didn't meet and 7 then get engaged immediately. It was 8 like we dated and then got engaged. 9 Q. Understood. 10 In addition to discussing 11 Jeffrey with is there someone 12 else you discussed Jeffrey with in 13 your life in 2006 or 2007? 14 A. Well, I discussed it with 15 everyone I knew. It's quite an amaz-16 -- he's an amazing man. Yeah, 17 everyone I knew knew that I was 18 involved with Jeffrey Epstein. 19 Everyone that I met in New York knew 20 that I was affiliated with Jeffrey 21 Epstein and Ghislaine Maxwell. 22 Q. More specifically, who did 23 you tell that you had concerns about 24 your relationship with Jeffrey? 25 A. My friend And there Page 250 1 HIGHLY CONFIDENTIAL AEO 2 were a few other friends I had at the 3 time, but I don't remember their 4 names. 5 Q. Did you discuss it with 6 7 A. Yes. 8 Q. What did you tell 9 A. Everything that Jeffrey did 10 to me. I told her every single detail 11 on how he abused me. 12 Q. How did Jeffrey abuse you? 13 A. There were times that I was 14 I mean, look, I was intimidated. I 15 was frightened of Jeffrey, okay. I 16 wanted to go to FIT, get an education. 17 But if I didn't comply with Jeffrey's 18 requests, I was scared. Okay? 19 So how did he abuse me? 20 When he had me on, like, the massage 21 table, I had no option. So how did he 22 abuse me? By putting a vibrator and 23 pushing it down on my clitoris for ten 24 minutes, that's abuse. That was not 25 pleasurable; that was exceptionally Page 251 1 HIGHLY CONFIDENTIAL AEO 2 painful. He hurt me physically and he 3 abused me mentally, both. 4 Q. How did he abuse you 5 mentally? 6 A. Jeez. Well, I think the 7 fact that -- A, physical abuse always 8 leads to mental abuse. It's a fact. 9 So you can't physically abuse someone 10 and they can't be mentally, because 11 they will -- without a doubt, I'm sure 12 myself and all the other girls will 13 have suffered some form of 14 posttraumatic stress. 15 So in terms of how did he 16 mentally abuse me? He bullied me. He 17 went on about my weight. He 18 intimidated me. He promised me things 19 he didn't deliver. I mean, I could go 20 on. So... 21 Q. What things did he promise 22 you that he didn't deliver? 23 A. An education. 24 Q. And what do you know about 25 what he did or didn't do to get you an Page 252 1 HIGHLY CONFIDENTIAL AEO 2 education? 3 A. Well, I didn't go to FIT, so 4 I presume not very much. 5 Q. Do you know why you didn't 6 get into FIT? 7 A. No, no. It just didn't ever 8 materialize. 9 Q. Did you ever contact FIT to 10 find out? 11 A. During that time, Jeffrey 12 had it in hand. I didn't think I 13 needed to contact anybody at FIT. I 14 mean, Jeffrey -- it was Jeffrey's 15 contact in the first place that he was 16 contacting. So I didn't contact 17 anyone at FIT. 18 Q. You didn't contact them at 19 all? 20 A. Well, no, because Jeffrey 21 said that he was going to do that for 22 me to get me into FIT. 23 Q. And how did you ever confirm 24 or deny that you weren't admitted to 25 FIT? Page 253 1 HIGHLY CONFIDENTIAL AEO 2 A. I was never told. I was 3 never given a letter. I didn't have 4 anyone phone me. I didn't have the 5 contact that Jeffrey had been speaking 6 to about getting me in. She didn't 7 contact me. So I'm presuming as an 8 educated woman it was all hearsay, 9 because nothing ever materialized from 10 that. 11 Q. Did FIT have your address at 12 's? 13 A. Not that I recall. 14 Q. Did you give Jeffrey your 15 address at 's? 16 A. Yes, Jeffrey knew where I 17 lived. 18 Q. I understood you were going 19 to live with in order to get away 20 from Jeffrey. 21 A. So when -- so basically when 22 you live in someone's apartment, it's 23 a form of control. So when you don't 24 comply with their instructions all the 25 time, hundred percent, it's like Page 254 1 HIGHLY CONFIDENTIAL AEO 2 leverage for them to control you. 3 I don't like being 4 controlled by people, especially by 5 someone like Jeffrey Epstein and 6 Ghislaine Maxwell. 7 So Jeffrey Epstein, he knew 8 where I was all the time, so.. . 9 Q. Did Jeffrey come to 's 10 apartment? 11 A. He came around the Upper 12 East Side near the apartment, yes, he 13 did. There was an occasion that 14 Jeffrey Epstein picked me up when I 15 didn't go to the mansion. 16 Q. Picked you up where? 17 A. I can't remember the 18 location. 19 Q. Jeffrey lived on the Upper 20 East Side? 21 A. I can't remember where 22 Jeffrey -- his exact location is I 23 mean, it's a nice -- I think it's near 24 5th. It's near 5th Avenue. 25 Q. Was it on the Upper East Page 255 1 HIGHLY CONFIDENTIAL AEO 2 Side? 3 A. I think. I don't think it 4 was on the West Side. So hang on. So 5 5th Avenue is there. Is the West Side 6 that side? 7 I don't know -- sorry. I'm 8 really -- I'm a tourister, so I don't 9 know. I don't know where Jeffrey -- I 10 know that he's got -- it was near 5th 11 Avenue. That's where I know his 12 apartment was. 13 I'm not a New Yorker, so... 14 Q. Do you recall an occasion 15 while you were living with that 16 Jeffrey came and picked you up? 17 A. Yes. 18 Q. Somewhere on the Upper East 19 Side? 20 A. Yes. 21 Q. You don't know where? 22 A. No, I don't know the 23 specific street, name or pavement that 24 I was standing on, no, I don't. 25 Q. Where did you go with Page 256 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey when he picked you up on the 3 Upper East Side? 4 A. I got in his car and went 5 back to his mansion. 6 Q. What kind of car was it? 7 A. It was a -- I can't remember 8 what car it was. 9 Q. Who was driving the car? 10 A. He wasn't driving. I can't 11 remember who was driving. 12 Q. Was anyone else in the car? 13 A. Someone was driving the car. 14 Q. Anyone else? 15 A. I can't remember anyone 16 else. 17 Q. What was the purpose of your 18 going back to the mansion on that 19 occasion? 20 A. I don't know. You're going 21 to have to ask Jeffrey. 22 Q. Why did you get in the car? 23 A. Because I was frightened. 24 Q. What were you frightened of? 25 A. The fact that he had found Page 257 1 HIGHLY CONFIDENTIAL AEO 2 me and wasn't supposed to know where I 3 was. So I was incredibly intimidated 4 that he drove up beside me and knew 5 where I was. 6 Q. You were somewhere out on 7 the street visible and he found you? 8 A. No. I was supposed to meet 9 Jeffrey. I was instructed to meet 10 Jeffrey. I failed to turn up to meet 11 Jeffrey and Jeffrey found me. 12 Q. Who instructed you to meet 13 Jeffrey? 14 A. It was one of the girls. It 15 was either or 16 17 Q. How did they instruct you to 18 meet Jeffrey? 19 A. Via the BlackBerry they gave 20 me. 21 Q. You kept the BlackBerry 22 after you returned from South Africa? 23 A. Yes, I did. 24 Q. While you were living with 25 Page 258 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. Why did you keep the 4 BlackBerry after you were living with 5 6 A. Because Jeffrey and I were 7 still in contact. 8 Q. What were you in contact 9 about? The FIT application? 10 A. He was trying to get me a 11 visa, and he -- he devised a way of me 12 getting -- I don't know what you call 13 it, sorry -- an apprenticeship, an 14 internship with a cosmetic company. 15 Yeah, a cosmetic agency, doctor's 16 medical facility. 17 Q. When you came back from 18 South Africa in February of 2007, did 19 you have a tourist visa? 20 A. Yeah, yes. 21 Q. So Jeffrey was trying to 22 help you get a job so you could get a 23 different kind of visa? 24 A. Yeah. Well, you can't live 25 in New York on a tourist visa. It's Page 259 1 HIGHLY CONFIDENTIAL AEO 2 three months, so -- so I don't know 3 what it's like anymore, the laws. But 4 back then, if you wanted to tour 5 America, you would go and fill -- I 6 think it was 90 days, but then you 7 would have to leave. You couldn't 8 stay. 9 And Jeffrey was trying to 10 get me a -- it's difficult, not 11 being -- it's difficult actually going 12 to university here if you don't have a 13 British -- I don't know the system. I 14 just didn't have a visa I could go to 15 FIT. 16 And this friend of his that 17 owned a cosmetic surgery, he had 18 organized that I would go in and do an 19 internship, and that way would be a 20 legitimate way to -- for me to get a 21 visa, for me to stay and continue in 22 FIT. If that makes sense. 23 Q. What was the name of that 24 friend? 25 MR. GUIRGUIS: Do you need a Page 260 1 HIGHLY CONFIDENTIAL AEO 2 break? 3 THE WITNESS: I do, sorry. 4 Do you mind? 5 MS. MENNINGER: There was a 6 question pending. 7 MR. GUIRGUIS: She has a 8 question pending. You can answer 9 that, then. Go ahead. 10 What was the name of that 11 friend? 12 THE WITNESS: I don't know. 13 It was a man. 14 Q. Did you end up working in 15 that internship? 16 A. No. 17 Q. Did you ever meet with that 18 man? 19 A. Yes. 20 Q. Why didn't you end up 21 working in that internship with that 22 man? 23 A. I wanted to return home. 24 MR. GUIRGUIS: Can we take 25 that break? Page 261 1 HIGHLY CONFIDENTIAL AEO 2 MS. MENNINGER: Yes. 3 (Time noted: 3:04 p.m.) 4 (Recess.) 5 (Time noted: 3:20 p.m ) 6 MS. MENNINGER: Going back 7 on the record. 8 MR. GUIRGUIS: Before you 9 proceed with your questions, 10 Counsel, I raised an objection to 11 providing 's email 12 address before. Then you 13 proffered a reason for it. 14 I accept your proffer and I 15 will provide you that email 16 address now, or have the witness 17 do it. 18 MS. MENNINGER: Okay. 19 THE WITNESS: It's 20 21 (An off-the-record 22 discussion was held.) 23 MR. GUIRGUIS: And let the 24 record reflect she's taking it 25 down from a Google search on the Page 262 1 HIGHLY CONFIDENTIAL AEO 2 web. She believes that's right. 3 Q. What is your father's email 4 address? 5 A. I don't remember it offhand. 6 MS. MENNINGER: Can you mark 7 this. 8 (Defendant's Exhibit 3, 9 affidavit, was marked for 10 identification.) 11 Q. Do you recognize the 12 document we marked as Defendant's 13 Exhibit 3? 14 A. Yes. 15 Q. What is it? 16 A. My affidavit. 17 Q. Who wrote this affidavit? 18 A. Well, I -- I -- I didn't 19 type it up, but I gave the affidavit. 20 Q. So you spoke words to 21 someone else and they typed it? 22 A. Yes. 23 Q. Who was that person? 24 A. I don't know. 25 Q. Who was the person you gave Page 263 1 HIGHLY CONFIDENTIAL AEO 2 words to? 3 MR. GUIRGUIS: Was it an 4 attorney? 5 THE WITNESS: Yes. 6 MR. GUIRGUIS: Okay. 7 Q Which attorney? 8 MR. GUIRGUIS: I think I'm 9 going to object to that. I don't 10 know that it matters which 11 attorney or which attorney 12 provided the work or did specific 13 tasks. I think that's 14 privileged. 15 Q. Did you communicate these 16 words to a attorney with the intent 17 that they would put it into an 18 affidavit that you would share 19 publicly? 20 A. I don't know that the 21 affidavit is public, but to share 22 with -- with you guys. 23 Q. With a third party? 24 A. Yeah, with a third party. 25 Q. And you knew that at the Page 264 1 HIGHLY CONFIDENTIAL AEO 2 time you were giving the words to the 3 person to type up? 4 A. Yeah, to give to you guys. 5 Q. So who was the person that 6 you were speaking to that took down 7 the words for your affidavit? 8 A. Sorry. It was Stan and 9 Brad. 10 Q. And when did you have that 11 conversation with them? 12 A. I think it was either -- I 13 think it was in January. 14 Q. Last month? 15 A. II, God. Last month. Yea' , 16 last month. 17 Q. In person? 18 A. In person. 19 Q. Did they give you multiple 20 drafts of this document? 21 A. I wouldn't say multiple, but 22 I made sure that it was accurate. 23 Q. Did you make any changes to 24 the document you were originally 25 presented with? Page 265 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. The first document that you 4 were presented with, is that the one 5 that you signed? 6 A. Yes. 7 Q. And nothing was changed 8 after you reviewed it? 9 A. No. 10 Q. Is that your signature on 11 the second page? 12 A. Yes, that is my signature. 13 Q. And the last page, is that 14 the official in Spain who witnessed 15 your signature? 16 A. Yes. 17 Q. Did you sign page 2 in front 18 of the person indicated on page 3? 19 A. Yes. 20 Q. Did you present that person 21 with some form of identification? 22 A. Yes. 23 Q. What form of identification 24 did you present? 25 A. My passport. Page 266 1 HIGHLY CONFIDENTIAL AEO 2 Q. Which passport? 3 A. My British passport. 4 Q. Is that a current British 5 passport? 6 A. Yes. 7 Q. Did you have a British 8 passport that expired in 2014? 9 A. Yeah, I can't remember when 10 it expired, but I think you guys have 11 a copy as well of my passport. I 12 don't remember the exact date that it 13 expired. 14 Q. Not the South African 15 passport that was stolen? 16 A. The South African passport 17 is completely irrelevant. You can't 18 19 20 21 22 23 travel on a South African passport. It's -- you can't go into any other country bar South Africa, other than South Africa, on a passport. So I've hardly used my South African passport at all. 24 Q. I'm just asking which 25 passport you showed to the person on 1 HIGHLY CONFIDENTIAL AEO 2 page 3. 3 A. Sorry. My British passport 4 Q. And it's a British passport 5 that's current? 6 A. Yes. 7 MR. GUIRGUIS: Asked and 8 answered. 9 MS. MENNINGER: Just a bit 10 of a detour. 11 Q. Can I have you take a look 12 at paragraph 1? 13 A. Yep. 14 Q. Is paragraph 1 true? 15 A. "I am currently over the age 16 of 18," paragraph 1, yes. 17 Q. And you presently reside in 18 Spain? 19 A. Yes. 20 Q. Paragraph 2, you state, "In 21 the summer of 2006, when I was 22 22 years old and living in New York, I 23 was introduced to Jeffrey Epstein by a 24 girl I had met named 25 " Page 268 1 HIGHLY CONFIDENTIAL AEO 2 Is that true? 3 A. Yes. 4 Q. Was it the summer of 2006 5 when you met 6 A. Okay, well, it was summer. 7 End of summer going into fall. 8 Q. So when was it, do you 9 think? 10 A. It was fall of 2006. It was 11 just after the summer. 12 Q. So it was the fall of 2006 13 when you met 14 A. Well, it was the end of the 15 summer, so I don't know -- fall or in 16 the summer or -- it was end of summer, 17 fall. 18 Q. Sometime after you came into 19 the U.S.? 20 A. Yes, yeah. 21 Q. And do you know when in the 22 fall of 2006 you met 23 A. What, you mean the end of 24 summer/fall slash -- if you really 25 want to go -- can you define, like, Page 269 1 HIGHLY CONFIDENTIAL AEO 2 geography lessons? Should we do 3 geography lessons? 4 MS. MCCAWLEY: All right. 5 Hang on a second. 6 A. Maybe summer? Fall? 7 Winter? What are your dates here in 8 New York? 9 MR. POTTINGER: Can we get 10 this clear? 11 MR. PAGLIUCA: Would you 12 just stop it? 13 MR. POTTINGER: Do you mind? 14 Do you mind? 15 MR. PAGLIUCA: I mind you 16 talking. 17 MR. POTTINGER: Do you mind? 18 MS. MENNINGER: If you want 19 to enter an objection, please do 20 so. 21 MR. POTTINGER: I object. 22 MS. MENNINGER: What is the 23 basis of your objection, Mr. 24 Pottinger? 25 MR. POTTINGER: Define Page 270 1 HIGHLY CONFIDENTIAL AEO 2 summer or fall. 3 MS. MENNINGER: I will do 4 whatever I want during my 5 deposition. 6 MR. POTTINGER: Define -- 7 define summer or fall. 8 MS. MENNINGER: I don't have 9 to define anything. 10 MR. POTTINGER: Define 11 summer or fall for the client 12 MS. MENNINGER: All right. 13 MR. POTTINGER: -- and then 14 we will answer the -- she will be 15 able to answer the question. 16 MS. MENNINGER: I'm going 17 off the record until you calm 18 down. 19 Let's go off the record. 20 (Time noted: 3:28 p.m. ) 21 (Recess.) 22 (Time noted: 3:30 p.m.) 23 MS. MENNINGER: Go back on 24 the record. 25 Q. Approximately what month and Page 271 1 HIGHLY CONFIDENTIAL AEO 2 day did you meet 3 A. As I said earlier, I can't 4 remember what day, but it was end of 5 summer/fall in the United States. I 6 can't remember what specific date or 7 time that was. 8 Q. What month? Any idea? 9 A. It was September. 10 Q. When did you meet Jeffrey 11 Epstein? 12 A. Shortly after I met 13 Q. Was that also in September? 14 A. I guess so. I don't know 15 the exact date I arrived, so if 16 someone can provide me with my 17 passport so I can see my entry date, 18 maybe that would help. 19 So I met -- if you 20 look at the date that I arrived in New 21 York on my passport, I think it's very 22 clear when I arrived. You've got the 23 evidence, I'm sure. 24 So two weeks after the date 25 that is on my passport that I arrived Page 272 1 2 3 met 4 5 6 7 HIGHLY CONFIDENTIAL AEO in, I met Very soon after I I was introduced to Jeffrey Epstein. It was in and around September. I can't specifically remember the date, time, season, whatever. 8 9 10 11 12 Q. Did you show your passport to Mr. Pottinger and Mr. when you were standing there at the consulate having the affidavit notarized? 13 14 A. I showed my current passport when I had this signed. 15 16 Q. Not the passport that contained dates from 2006? 17 18 A. My current valid passport. You can only show a valid passport. 19 Q. Fair enough. 20 21 22 So you believe that your lawyers have produced your current valid passport to me? 23 A. No -- 24 MS. MCCAWLEY: Objection. 25 A. -- they have not produced my Page 273 1 HIGHLY CONFIDENTIAL AEO 2 current passport. They produced have 3 my passport during that time frame, 4 which clearly shows that -- when I 5 entered the United States. 6 Q. So when your lawyers wrote, 7 "A copy of nonparty 8 current passport is attached hereto as 9 157 to 168, which should be 10 treated as confidential pursuant to 11 the party's protective order," do you 12 believe that to be an accurate 13 statement? 14 MS. MCCAWLEY: Objection. 15 You're asking her legal 16 information that she's not privy 17 to. 18 MS. MENNINGER: There was 19 nothing legal about that comment. 20 A. Sorry. That makes no sense 21 to me, please. Can you repeat the 22 question. 23 Q. I'll do it this way. 24 MS. MENNINGER: Defendant's 25 Exhibit 4. Page 274 1 HIGHLY CONFIDENTIAL AEO 2 (Defendant's Exhibit 4, 3 , was marked for 4 identification.) 5 Q. Take a look at Defendant's 6 Exhibit 4. 7 A. Okay. 8 Q. Just take a look at it. Do 9 you recognize it? 10 A. Yeah, this is my passport. 11 Q. Do you know which passport 12 this is? 13 A. This is my old passport. 14 Q. So it's not your current 15 passport, correct? 16 A. No, it's not my current 17 passport, because it expired on -- 18 let's have a look here -- 19 Q. Can you turn to the 20 second-to-last page. Sorry. 21 A. Yes, here we go. 22 Q. Does that have a 23 number? In other words, your name, 24 , with an underscore and then 25 page numbers after that, that were Page 275 1 HIGHLY CONFIDENTIAL AEO 2 placed there by your attorneys. 3 4 understand. A. Hmm, sorry. I don't 5 Q. Do you see at the bottom of 6 that page, your name, 7 A. Yes. 8 Q. 9 All right. And that's on a document that is an expired passport? 10 A. Yes. 11 Q. 12 passport? This is not your current 13 14 MR. GUIRGUIS: Objection, asked and answered. 15 A. No. 16 17 18 currently in effect? Q. You have another passport that's not this passport that's 19 20 MR. GUIRGUIS: Objection, asked and answered. 21 Q. Correct? 22 A. Yes. 23 24 25 Q. If I could also have you take a look at -- and I'll have to show, if you can see, there are the Page 276 1 HIGHLY CONFIDENTIAL AEO 2 passport page numbers 3 A. Mm-hmm. 4 Q. -- that show up on a 5 passport. 6 A. Yeah. 7 Q. And these have been put in 8 some order. 9 A. Mm-hmm, the order of my 10 passport, yes. 11 Q. Right. That's not how they 12 were produced, but that's the order 13 they're in now. 14 A. Okay. 15 Q. If we could have you turn to 16 162, which is page 16 of your 17 passport. 18 MR. GUIRGUIS: Is that the 19 front -- sorry, 162. 20 MS. MENNINGER: They're not 21 in order. They're put in 22 the order of the passport. 23 THE WITNESS: in, yeah. 24 Mm-hmm. 25 MS. MENNINGER: It's page Page 277 1 HIGHLY CONFIDENTIAL AEO 2 16. 3 Q. Do you see on that page a 4 stamp from the Department of Homeland 5 Security of the U.S., dated 6 October 19, 2 0 0 6? 7 A. Mm-hmm. 8 Q. Does that indicate to you 9 that you were admitted to visit the 10 U.S. on October 19th of 2 0 0 6? 11 A. Yes, it does. 12 Q. Do you believe October 19th 13 is during the summer in the U.S.? 14 A. No. I don't see the 15 relevance. 16 Q. What season do you think 17 October 19th is in the U.S.? 18 A. Okay. Well, considering I 19 arrived in September, October's in 20 winter. But I arrived in September. 21 Q. Okay. Well, do you believe 22 that you did not enter the U.S. on 23 October 19th, 2 0 0 6? 24 A. Well, it's stamped. 25 Q. Does it say "admitted"? Page 278 1 HIGHLY CONFIDENTIAL AEO 2 A. "Admitted," yes. 3 Q. Does it say "October 19, 4 2006"? 5 A. Yes. 6 Q. Does it say "Department of 7 Homeland Security, U.S. Customs and 8 Border Patrol"? 9 A. Yes. 10 Q. So you do or do not believe 11 you were admitted to the United States 12 on October 19, 2006? 13 A. I flew in and had my 14 passport stamped after I went on my 15 trip to London in the UK. 16 Every time you go into a -- 17 as you all know, using your passport, 18 every time you go into a new country, 19 if you don't have their passport, you 20 get a stamp. So if you go in several 21 times, every time you go into that new 22 country, it gets stamped. 23 Q. So you think you went on a 24 trip in October and came back to the 25 U.S. on October 19th? Page 279 1 HIGHLY CONFIDENTIAL AEO 2 A. I obviously went -- I 3 arrived in New York a day on the 19th 4 of October. 5 Q. Where were you coming from 6 on October 19th? 7 A. I can't remember. 8 Q. You have no idea? 9 A. I think it was London. I 10 made a trip to London. 11 Q. And how long were you in 12 London in October? 13 A. I can't remember. 14 Q. A week? 15 A. I can't remember. 16 Q. Who paid for that ticket? 17 A. Myself. 18 Q. Did you go with anyone? 19 A. No. 20 Q. Did you have a new 90 days 21 that began on October 19th? 22 A. Yes. It automatically 23 starts every time you enter. 24 Q. So in order to be compliant 25 with that visa, you needed to leave Page 280 1 HIGHLY CONFIDENTIAL AEO 2 within 90 days of October 19th? 3 A. That's correct. 4 Q. Do you know which airline 5 you flew to London in 2006? 6 A. I can't remember. 7 Q • Do you know which class of 8 service you flew? 9 A. I can't remember. 10 Q. Where is your current 11 passport right now? 12 A. It is in my hotel room. 13 Here, in -- it's in my hotel room. 14 Q. Got it. 15 Did 16 fly with you to London? 17 A. No. 18 Q. Did Jeffrey pay for you to 19 go to London? 20 A. I can't remember. 21 Q. Do you know whether you had 22 met Jeffrey before you went to London 23 in October of 2006? 24 A. I had met Jeffrey by then. 25 Q. Do you have any emails or Page 281 1 HIGHLY CONFIDENTIAL AEO 2 anything reflecting your travel plans 3 on that trip? 4 A. I think there was a 5 plane, i think there was a plane 6 booking or something. 7 Q. For that trip to London in 8 October of 2006? 9 A. I think so. I would have to 10 double check. 11 Q. Where would you check? 12 A. Well, I'm trying to go and 13 find it in my email, my old email 14 account, where all of my other emails 15 exchanged between and 16 are. 17 Q. Do you have any frequent 18 flyer accounts? 19 A. No. 20 Q. Did your first trip to the 21 private island in the U.S. Virgin 22 Islands before or after you went to 23 London and returned? 24 A. What was the date in October 25 again? 19th. I can't remember. I Page 282 1 HIGHLY CONFIDENTIAL AEO 2 mean, I said earlier I can't remember 3 the first time. 4 Q. In the next sentence you 5 say, "After that first trip, I 6 traveled to the island several more 7 times, usually on one of Jeffrey's 8 private airplanes, and always at his 9 direction." 10 What do you mean by "always 11 at his direction"? 12 A. Well, I wasn't going to go 13 there on my own, so I would have to be 14 invited first. I didn't want to just 15 go chill on my own. It was Jeffrey's 16 house, so he had to phone me and 17 invite me before I decided I wanted to 18 go to his island. 19 Q. So he phoned you, he invited 20 you, and you decided you wanted to go 21 to his island. 22 A. No, I had to go to his 23 island. 24 Q. Why did you have to go to 25 his island? Page 283 1 HIGHLY CONFIDENTIAL AEO 2 A. Because I was frightened of 3 him. 4 Q. Did Jeffrey ever hit you? 5 A. No, he didn't. 6 Q. Did you ever see Jeffrey 7 with a weapon? 8 A. No. 9 Q. Have you reviewed any flight 10 logs? 11 A. No, not that I recall. 12 Q. You've never seen a flight 13 log? 14 A. I've seen one which showed 15 my name. 16 Q. When did you first become 17 frightened of Jeffrey Epstein? 18 A. During my time with him in 19 New York. 20 Q. What period of time? 21 A. Pretty much soon after I met 22 him, actually, and he forced the 23 vibrator on my vagina for an extended 24 period of time, which considerably 25 hurt my lady region, actually. Page 284 1 HIGHLY CONFIDENTIAL AEO 2 Q. That's when you became 3 frightened of him? 4 A. Yes, absolutely. 5 Q. You've seen a flight log 6 with your name on one flight? 7 A. Yes, I have. 8 Q. When did you see that? 9 A. I saw it in January, and it 10 was to confirm that -- 11 MR. GUIRGUIS: I'm going to 12 object. Hold on. 13 Is this -- if this is a 14 communication with counsel, you 15 should understand, any time she 16 asks you a question, if the 17 answer is it was with counsel, 18 then you don't answer. 19 Was this with counsel? 20 THE WITNESS: Yes. 21 MR. GUIRGUIS: Don't answer. 22 MS. MENNINGER: Seeing a 23 document when you're with counsel 24 is privileged? 25 MR. GUIRGUIS: I don't know Page 285 1 HIGHLY CONFIDENTIAL AEO 2 what your next question is going 3 to be, so... 4 MS. MENNINGER: I asked her 5 when she saw the flight logs. 6 And she said in January, correct? 7 MR. GUIRGUIS: Right. And 8 then she was about to continue 9 the answer. I'm fine with the I 10 saw it in January. That's why I 11 didn't object when you asked the 12 question. 13 I'm objecting to her 14 continuing and caution the 15 witness not to waive her 16 attorney/client privilege. 17 Q. Don't tell me anything that 18 your lawyer said to you. 19 You reviewed the flight log 20 in January? 21 A. I reviewed one flight log, 22 which confirmed that I was there. 23 Q. What other documents did you 24 review? 25 A. No other documents. Page 286 1 HIGHLY CONFIDENTIAL AEO 2 Q In addition to Jeffrey and 3 what other girls did you have 4 sexual relations with on the island? 5 A. I can't remember their 6 names. 7 Q. Can you remember any of 8 their names? 9 A. There were a few. 10 Q. Can you remember any of 11 their names? 12 A. -- sorry, I 13 misunderstood your question. I didn't 14 have sexual relations with 15 Sorry, I misunderstood you. 16 It was and 17 And there were a couple 18 others, I don't remember their names. 19 Q. What are other guests did 20 you have sexual relations with on the 21 island? 22 A. It was only those ones. 23 Q. Do you know the ages of any 24 of the individuals you had sexual 25 relations with on the island? Page 287 1 HIGHLY CONFIDENTIAL AEO 2 A. They were 18, I assumed. 3 was around my age, was my age. 4 Q. In the next paragraph, you 5 refer to meeting Ghislaine Maxwell on 6 one of your visits to the island, 7 correct? 8 A. Correct. 9 Q. You said, "Watching her 10 interact with the other girls on the 11 island, it became clear to me that she 12 recruited all or many of them to the 13 island." 14 what do you mean that? 15 A. That she recruited a lot of 16 the girls. 17 Q. What did you see? 18 A. I saw how she interacted 19 with all the girls. You know, if you 20 walk into any -- I mean, common 21 sensewise, if you walk into a firm, 22 you kind of know who the boss is. 23 You know, all the girls kind 24 of reported to Ghislaine. Ghislaine 25 was like the mama bear, if you know Page 288 1 HIGHLY CONFIDENTIAL AEO 2 what I mean. She called the shots; we 3 had to listen to Ghislaine. 4 And Ghislaine was Jeffrey's 5 right-hand woman, so, you know, 6 whatever Jeffrey wanted went through 7 Ghislaine and then filtered through. 8 Q. What did any girl report to 9 Ghislaine in your presence? 10 MR. GUIRGUIS: Objection. 11 I'm not sure that's -- just 12 objection to form. 13 Q. You said that the girls 14 reported to Ghislaine. What did you 15 see or hear that caused you to say 16 that? 17 A. Well, it's pretty obvious. 18 I mean, Ghislaine called the shots. 19 So, for example, when -- I 20 can't remember specifics, but 21 I think, had an issue. And she had to 22 speak to Ghislaine if there was ever 23 an issue. 24 Q. What issue? 25 A. I can't remember Page 289 1 HIGHLY CONFIDENTIAL AEO 2 specifically. We always have issues. 3 Girls have issues. We have period 4 pains, we've got headaches. 5 You know, we had to look a 6 certain way for Jeffrey. So if we put 7 on a little bit of weight or, for 8 example, if my hairstyle was wrong 9 Jeffrey liked girls to look a certain 10 way. 11 So, for example, there was 12 one occasion where Jeffrey didn't like 13 my hair and Ghislaine told me to 14 change it. 15 So there was -- everyone was 16 afraid of Ghislaine. All the girls 17 were afraid of her, so everyone 18 reported to her. 19 reported to her. I don't know 20 how to tell you. 21 So when I say reporting, I 22 witnessed with my own two eyes 23 reporting to Ghislaine in front 24 of me, but I can't remember specifics. 25 They were talking about girls. I Page 290 1 HIGHLY CONFIDENTIAL AEO 2 can't remember the specific 3 conversation. But every single person 4 100 percent, 200 percent reported to 5 Ghislaine. 100 percent. 6 Q. Okay. Great. I appreciate 7 your certainty. 8 A. Absolutely. 9 Q. So we have 10 having a discussion with Ghislaine 11 about girls. What other discussions 12 did you overhear? 13 A. There were various 14 discussions. We were always talking 15 about girls. There was a constant 16 influx of girls. There were so many 17 girls. There were girls in Miami. 18 There were guests coming. There 19 were -- 20 It's like, I'm sure if you 21 go into a brothel and see how 22 they run their business, I mean, it's 23 just general conversation about who's 24 going to have sex with who and, you 25 know -- what do you talk about when Page 291 1 HIGHLY CONFIDENTIAL AEO 2 all do you is have sex every day on 3 rotation? I mean, what is there to 4 talk about? 5 Q. You were in Miami? When did 6 you go to Miami? 7 MR. GUIRGUIS: Objection. 8 MS. MCCAWLEY: Objection. 9 A. No, I didn't go to Miami. I 10 didn't say that. 11 Q. Apart from general 12 conversation, do you recall any 13 specifics of any female reporting to 14 Ghislaine? 15 A. Yes, I saw. And with my own 16 eyes, I saw how Ghislaine and 17 and the other girls reported to 18 them. 19 If you would like me to 20 report specific conversations, I 21 can't. But in my being an adult and 22 having common sense and a sensible 23 head on my shoulders, you can quite 24 quickly work out who is the management 25 there. Page 292 1 HIGHLY CONFIDENTIAL AEO 2 And we were told by Jeffrey 3 Epstein to listen to Ghislaine. So 4 Ghislaine was the main right-hand 5 woman of Jeffrey Epstein. We were 6 told by Jeffrey Epstein to listen to 7 Ghislaine. 8 Q. When did Jeffrey Epstein 9 tell you that? 10 A. I can't remember the exact 11 time, date or where I was standing, on 12 which pavement or crack. But it was 13 around the time that I met Ghislaine. 14 Q. Which was on the island? 15 A. I can't remember what date, 16 time, pavement, where I was standing. 17 But I was told during around the time 18 I met Ghislaine that I had to listen 19 to Ghislaine. 20 Q. By Jeffrey? 21 A. By Jeffrey. And every 22 single other girl that I've ever met 23 with Jeffrey. 24 Q. And we know three names, but 25 that's it? Page 293 1 HIGHLY CONFIDENTIAL AEO 2 A. Those are three names that I 3 remember, but I met -- I met lots of 4 girls. Lots. 5 Q. Okay. 6 A. Yeah. 7 Q. What activities was 8 Ghislaine Maxwell in charge of? 9 A. In terms of -- can you 10 explain activities, please? 11 Q. I'm actually just looking at 12 your affidavit on paragraph 3, so why 13 don't you take a look at that. 14 A. Activities. Activities. So 15 when we had to go to the island, when 16 we had to go see Jeffrey in New York, 17 when we had to go to his mansion. 18 You know, we saw Jeffrey 19 pretty regularly. I was on rotation 20 pretty much every day, so -- amongst 21 other girls. 22 So Ghislaine also called 23 me -- she also called the other 24 girls -- when Jeffrey wanted his 25 massage. So there was an occasion Page 294 1 HIGHLY CONFIDENTIAL AEO 2 that I didn't want to go, and she got 3 angry with me because I didn't want to 4 give Jeffrey a massage. 5 Q. When was that? 6 A. It was on one of my -- one 7 of my stays on the island. I can't 8 remember what specific date or what 9 specific time. 10 Q. How many times were you on 11 the island with Ghislaine? 12 A. I can't remember 13 specifically. 14 Q. More than once? 15 A. Yeah. 16 Q. More than twice? 17 A. I can't remember. I also 18 saw her in New York quite a lot, so 19 I mean, this isn't just based on the 20 island. I spent just as much time 21 with Jeffrey and Ghislaine in New 22 York, so we can't just concentrate on 23 the island, please. 24 Q. Did you believe Ghislaine 25 was living in New York in January of Page 295 1 HIGHLY CONFIDENTIAL AEO 2 2007? 3 A. I don't know where the hell 4 Ghislaine lived, to be honest. 5 Q. But you saw her regularly in 6 January of 2007? 7 MR. GUIRGUIS: Objection. 8 MS. MCCAWLEY: Objection. 9 A. Regularly, what's regularly? 10 I saw her a few times. I don't know 11 where she was living. I tried to 12 actually not spend -- well, I tried to 13 spend as little time with her as 14 possible because every time I saw her 15 on the island, she would call me to 16 give Jeffrey a massage, so... 17 Q. You saw her more than once 18 on the island and you saw her a few 19 times in New York. Did you see her 20 anywhere else? 21 MR. GUIRGUIS: Objection. 22 MS. MCCAWLEY: Objection, 23 mischaracterizes testimony. 24 A. No. 25 Q. In New York, you saw her at Page 296 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey's office. Did you see her 3 anywhere else in New York? 4 A. I can't remember. I saw 5 them, I spent a lot of time with them, 6 so... 7 Q. How much time did you spend 8 with Ghislaine? 9 A. Enough. 10 MR. GUIRGUIS: Objection. 11 That's vague. 12 A. Enough time. I mean, how 13 long is a piece of string? I was here 14 for a certain amount of time, and in 15 that time, the majority of the time I 16 spent with Jeffrey Epstein being 17 involved with his pedophiling -- I 18 mean, how much time have you spent 19 with him? I don't know. It wasn't a 20 lot of time, because I couldn't stand 21 the woman and she was a bully and no 22 one liked her, so no one really went 23 out of their way to spend time with 24 her. 25 So I didn't spend a lot of Page 297 1 HIGHLY CONFIDENTIAL AEO 2 time with her because she's a 3 particularly unpleasant person. And 4 when I did spend time with her, it was 5 either directing me to massage Jeffrey 6 or her showing me how to massage 7 Jeffrey, or I spent a lot of time with 8 her on the island. 9 Yeah, so how much time did I 10 spend with Ghislaine in total of 11 hours? I can't recall because it was 12 ten years ago. I mean, how many hours 13 did I spend with Jeffrey? I mean, 14 what a silly question. 15 Q. How many days did you see 16 Ghislaine? 17 A. Don't know. 18 Q. Less than ten or more than 19 ten? 20 A. I can't remember. 21 Q. Less than five or more than 22 five? 23 A. Can't remember. 24 Q. You indicate that many girls 25 you saw appeared to be young Page 298 1 HIGHLY CONFIDENTIAL AEO 2 teenagers. Where did you see young 3 teenagers? 4 A. It says they appeared to be 5 teenagers. All the girls I saw looked 6 young. 7 Q. Okay. Where did you see 8 girls who appeared to be young 9 teenagers? 10 A. On the island and in New 11 York. 12 Q. Describe for me a young 13 teenager that you saw. 14 MR. GUIRGUIS: Objection, 15 mischaracterizes testimony. 16 A. So I never said I saw a 17 teenager. They appeared to look like 18 teenagers, okay? was -- I try 19 to look at I don't know how 20 old is, but she looked young. 21 And I'm sure you can agree, as a mom, 22 in the photos, that she looks pretty 23 young for an old man to be bonking. 24 So she looks really young. She looks 25 younger than me. Page 299 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you see her bonk 3 someone? 4 A. No, but she told me. She 5 told me and that they abused her 6 on the island. 7 Q. said they abused who 8 on the island? 9 MR. GUIRGUIS: Objection, 10 mischaracterizes testimony. 11 That's not what she said. 12 A. said that Jeffrey 13 and had abused her. 14 Q. Okay. And do you have any 15 way to reach 16 A. I haven't spoken to her. I 17 don't -- I just know her first name. 18 Q. You said you recall seeing 19 "a particularly young, thin girl who 20 looked well under 18," and you recall 21 asking her her age. 22 When did you see this 23 particularly young, thin girl who 24 looked well under 18 and you recall 25 asking her age? Page 300 1 HIGHLY CONFIDENTIAL AEO 2 A. It was on the trips. I 3 think you've got the photos. 4 is in the photos. So it was that trip 5 in December. 6 Q. Did you take a photo of the 7 young, thin girl who looked well under 8 18? 9 A. I think I did take a photo 10 of her. I don't have any more photos 11 of her of my own. 12 Well, I have photos of her. 13 You've got the photos. 14 Q. So the person -- 15 A. I've given you all the 16 photos that I have. 17 Q. The person that you wrote 18 here was "a particularly young, thin 19 girl who looked well under 18" is 20 reflected in photographs you've 21 produced in this case? 22 A. That's correct. 23 Q. And do you know her name? 24 A. Sorry, can you just repeat 25 that? Didn't I just answer this Page 301 1 HIGHLY CONFIDENTIAL AEO 2 question? 3 Yeah, that's who I 4 was particularly concerned about, 5 about her age, in the photos that I 6 have supplied with -- you with, with 7 me in them with 8 Q. So in your affidavit in 9 paragraph 3 where you talk about "a 10 particularly young, thin girl who 11 looked well under 18," you are 12 referring to 13 A. Yes. 14 Q. And you said you later 15 learned she was a 16 A. That's correct. 17 Q. How did you learn she was a 18 19 A. Because she told me. And 20 she told me Jeffrey Epstein was 21 funding her 22 Q. And where was her 23 24 A. I don't know. 25 Q. When did she tell you this? Page 302 1 HIGHLY CONFIDENTIAL AEO 2 A. During that December trip. 3 Q. Was that the only trip you 4 took with her? 5 A. I can't -- I can't remember. 6 I think there was another trip, but I 7 can't remember. 8 Q. Did you ever see her name on 9 a flight log? 10 A. No. 11 Q. Was she on the plane with 12 you? 13 A. I can't -- I can't remember. 14 I can't remember. Yeah, I just 15 remember on the island. 16 Q. Other than her telling you 17 she was a did she tell you 18 anything else about herself? 19 A. Yeah, you know, I think she 20 came from quite a tough background. 21 Q. What did she say? 22 A. Well, I can't remember the 23 specifics, but I remember that -- I 24 don't know if she had issues with her 25 parents -- I don't know. She was a Page 303 1 HIGHLY CONFIDENTIAL AEO 2 bit of a -- you know, she was a -- I 3 was worried about her. 4 Q. What did she say to cause 5 you to be worried about her? 6 A. Well, I first met her -- she 7 was new to Jeffrey Epstein's list of 8 girls in December. And when I first 9 met her, she was a really bubbly girl 10 and -- I mean, she was young. She was 11 inexperienced. She -- she was frail. 12 And she changed quite quickly after 13 that first trip. 14 Q. How many trips did you take 15 with her? 16 A. I think it was more than 17 one. I can't remember. I saw her a 18 lot. 19 Q. Where did you see her? 20 A. II, it was either New York 21 or the island. I mean, I can't 22 remember. 23 Q. In New York, where did you 24 see her? 25 A. I think we met -- like we Page 304 1 HIGHLY CONFIDENTIAL AEO 2 all met a couple times in New York. 3 We all kind of knew each other. 4 Q. Did you ever see her 5 A. No. 6 Q. Did she live in an apartment 7 that you went to? 8 A. I can't remember about her 9 living arrangements. 10 Q. Do you know where her 11 was? 12 A. No. 13 Q. When did you ask to see her 14 passport? 15 A. When we shortly arrived to 16 the Virgin Islands, she looked 17 particularly young. And you know what 18 girls are like with passport -- with 19 passport pictures. They don't -- they 20 get embarrassed about their passport 21 pictures. 22 And she was quite cagey 23 about her passport, so she didn't show 24 me. I don't know whether that -- I 25 don't know. She just didn't show me. Page 305 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did she say why she wasn't 3 showing it to you? 4 A. She said it was because she 5 was embarrassed about the picture. 6 Q. Were you living in the same 7 room with her on the island? 8 A. Yeah, we stayed in the same 9 room. 10 Q. Did you ever attempt to look 11 at her passport when she wasn't there? 12 A. No. 13 Q. Did you ever call any 14 authorities about having seen this 15 young, thin girl who looked well under 16 18? 17 A. No. 18 Q. In the fourth paragraph, you 19 described being lent out to Jeffrey's 20 friends in New York. 21 Which friends of Jeffrey's 22 were you lent out to to have sex? 23 A. Alan Dershowitz. 24 Q. Who else? 25 A. All the girls that Page 306 1 HIGHLY CONFIDENTIAL AEO 2 were involved, really. I had to have 3 sex with them, so... 4 Q. Well, what do you mean by 5 lent out? 6 A. Lent out as in -- so I was 7 one of the girls that regularly -- 8 that Jeffrey regularly asked to see 9 sexually. 10 And what my description was 11 of being lent out is when -- it's 12 almost like Jeffrey's quite possessive 13 of his girls. He's -- you know, he 14 lends them out. 15 He samples the girls, he has 16 friends come over to New York or the 17 island and they -- they get to see who 18 all the girls are around Jeffrey, and 19 they get to pick one which they want 20 to be with. 21 Q. So you were with Jeffrey and 22 a number of other females in New York 23 when a person, a friend would come in, 24 Alan Dershowitz would come in and look 25 at all of the girls and choose one? Page 307 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: Objection. 3 MR. GUIRGUIS: Objection, 4 mischaracterizes testimony. 5 MS. MENNINGER: I'm asking a 6 question. 7 MR. GUIRGUIS: I'm objecting 8 to your question. 9 A. So let me give you a 10 specific example of that. So, for 11 example, there was an occasion where I 12 and some of the other girls were on 13 the island. So a specific occasion 14 was when -- I don't know his 15 surname, but he owns or 16 whatever, and he came with his 17 fiancée. 18 So, you know, you got a 19 table with Jeffrey Epstein of lots of 20 women -- girls, women, whatever -- 21 beautiful girls, and you've got 22 friends joining him. And friends 23 popped over all the time. 24 So I had other -- there were 25 other males that visited Jeffrey on Page 308 1 HIGHLY CONFIDENTIAL AEO 2 the island. I don't know who they 3 are. I can't remember their names. 4 But, yeah. I mean, he 5 didn't -- he didn't line them up and 6 go, hey, boys, pick which vagina you 7 want. He didn't do it that blatantly. 8 But they had spent time with 9 the girls during a lunch on the 10 island -- yeah, I mean, they -- his 11 friends would spend time with us. 12 Q. Okay. In paragraph 4, where 13 you say, "At his townhouse, I was also 14 lent out by him to his friends and 15 associates to have sex." 16 What do you mean by that 17 sentence? 18 A. Well, I mean, it's quite 19 obvious with the incidents -- well, 20 the incident that happened with Alan. 21 So I would classify that as being lent 22 out. I didn't willingly go, hey, 23 Alan, let's have some fun, because no 24 one on the planet would say that to 25 Alan. Page 309 1 HIGHLY CONFIDENTIAL AEO 2 Q. So you say "lent out by him 3 to his friends and associates." 4 Who are the friends and 5 associates that you were lent out to? 6 MR. GUIRGUIS: Objection, 7 asked and answered. 8 A. Alan Dershowitz and 9 The girls that I mentioned. There 10 were other girls that I had sexual 11 intercourse with, but I can't remember 12 their names. 13 Q. Were there any other men? 14 A. No, there weren't any other 15 men. 16 Q. 17 A. No. 18 Q. 19 A. No, no, I don't know that. 20 Q. Yes? No? 21 A. No. That I would be lent 22 out to have sex with? 23 Q. Yes. 24 A. No, no. 25 Q. Tom Pritzker? Page 310 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. 4 A. No. 5 Q. Were you paid money after 6 you had sex with Alan Dershowitz? 7 A. No. 8 Q. Were you paid money after 9 you had sex with 10 A. No. 11 Q. Were you paid money after 12 you had sex with 13 A. No. 14 Q. Were you paid money after 15 you had sex with any of the other 16 girls -- 17 A. No. 18 Q. -- of names you can't 19 remember? 20 A. I was only ever paid to 21 when I had sex with Jeffrey himself. 22 Q. In the course of massage? 23 A. Yes. 24 Q. Did you ever have sex with 25 Jeffrey not in a massage context? Page 311 1 HIGHLY CONFIDENTIAL AEO 2 A. Yeah, we -- yeah. He was 3 really intimate all the time. We 4 had -- multiple times. I can't tell 5 you how many times I've slept with 6 Jeffrey. I mean, we were on rotation. 7 Every single day, it was -- sometimes 8 twice a day I was called. 9 You know, Ghislaine, 10 you know, it was -- yeah. I 11 mean, how -- we were on rotation 12 pretty much the whole time I was here. 13 Q. And when you say you were on 14 rotation, you mean you were having sex 15 with Jeffrey multiple times per day? 16 A. No. As in when I was 17 finished, another girl was called by 18 Ghislaine. And when they had 19 finished, another girl was called. 20 Q. How do you know that another 21 girl was called by Ghislaine? 22 A. Because I was there, and I 23 saw it and heard it with all my 24 senses. I saw Ghislaine call another 25 girl, and she called me herself, to go Page 312 1 HIGHLY CONFIDENTIAL AEO 2 give Jeffrey Epstein a sexual massage. 3 Q. What do you mean by call? I 4 guess I'm thinking like telephone. 5 That may be my 6 A. No. As in going up to the 7 person and going, Jeffrey wants to see 8 you in his bedroom, which meant it's 9 your turn to be abused. That kind of 10 thing. 11 Q. And this is on the island? 12 A. This is on the island. 13 Q. You heard -- as soon as you 14 were done with Jeffrey, you heard 15 Ghislaine go up to another girl and 16 say, it's your turn with Jeffrey? 17 A. So every single day, I 18 mean -- so I don't know how quickly 19 Jeffrey's sperm bank fills up. I 20 mean, I know guys can normally cum 21 once or twice a day, but Jeffrey's not 22 a normal person. 23 So, I mean, our rotation 24 changed every day that specific trip 25 we had in December. Page 313 1 HIGHLY CONFIDENTIAL AEO 2 So, for example, I would be 3 called. Maybe a couple hours when 4 Jeffrey had a little, you know, break, 5 another girl was called, 6 Then another girl was called. Every 7 single day. 8 We tried to hide on 9 different -- like, so we wouldn't have 10 to get called. We'd generally have to 11 sit in the main area. There was like 12 a big pool, the main seating area. 13 There was a big table. We'd sit there 14 and do kind of art on the table, and 15 we always had to be around. We 16 weren't allowed to go very far on the 17 island. 18 We always had to report to 19 Ghislaine and Jeffrey and tell them if 20 we were going down to the beach to 21 swim because they had an inflatable 22 trampoline. So they -- I mean, we 23 always had to tell Ghislaine and 24 Jeffrey where we were at all times. 25 Q. On the island? Page 314 1 HIGHLY CONFIDENTIAL AEO 2 A. On the island, yeah. 3 Q. In New York -- strike that. 4 How many times a day, to 5 your knowledge, did Jeffrey Epstein 6 have sex? 7 A. To my knowledge, from what I 8 saw and what I've witnessed -- I don't 9 know what he did when I wasn't 10 there -- up to about three, four times 11 a day. 12 Q. So you had sex with him 13 three or four times a day? 14 MS. MCCAWLEY: Objection. 15 A. No. 16 Q. I'm sorry. You said to your 17 knowledge, what you witnessed. I'm 18 trying to understand what you mean. 19 A. So as soon as I slept with 20 Jeffrey, a certain time would go by. 21 He maybe had a coffee. And then there 22 was a specific occasion where then 23 was called to go and do that 24 for Jeffrey. 25 Q. And you were not in the room Page 315 1 HIGHLY CONFIDENTIAL AEO 2 when was with Jeffrey? 3 A. No, but I was certainly 4 there afterwards, because she was 5 forced to have sex with and 6 Jeffrey Epstein. 7 Q. That happened? 8 A. Yes. And she had never had 9 a female experience before and she was 10 very upset, very upset. 11 Q. So you didn't personally see 12 it, but you talked to and saw 13 her afterwards? 14 A. Well, I don't think the 15 girls, when they were called, were 16 making cups of tea with Jeffrey in his 17 room. So -- and when a girl comes out 18 crying and I know that I've been 19 sexually abused, it's quite safe to 20 assume. 21 And when that girl tells you 22 she's being forced to have sex with 23 Jeffrey Epstein and you know, 24 it's there, isn't it. 25 Q. So she told you? Page 316 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes, she told me. And with 3 my own intelligence, in my -- you 4 know, I can see with my own senses. I 5 can hear things, see things. It's 6 quite obvious what was going on. 7 MS. MENNINGER: I need a 8 small break. 9 (Time noted: 4:17 p.m.) 10 (Recess.) 11 (Time noted: 4:28 p.m.) 12 Q. On Defendant's Exhibit 3 in 13 the last paragraph, you describe 14 having had sex with Alan Dershowitz, 15 correct? 16 A. Correct. 17 Q. You say in the last sentence 18 that you recall "specific key details 19 of his person." 20 what specific key details of 21 his person do you recall? 22 A. You know, I recall his 23 appearance. You know, I'd met him, 24 you know, twice beforehand. So in 25 terms of specific key details, I can Page 317 1 HIGHLY CONFIDENTIAL AEO 2 describe how he looked. 3 Q. How did he look? 4 A. He was, as I've explained -- 5 described earlier, quite -- quite an 6 elderly man, wore glasses, quite 7 pasty, pasty-skinned. Not well, I 8 assumed, not at all well. He wasn't 9 well, W-E-L-L. Like, he wasn't a -- 10 he wasn't -- he wasn't a healthy 11 person. 12 Q. And do you recall whether he 13 had a mustache? 14 A. I can't -- I can't recall if 15 he had a mustache, no. 16 Q. Which of those that you just 17 described are the key details you are 18 referring to in paragraph 4? 19 MS. MCCAWLEY: Objection, 20 asked and answered. 21 A. As I've described. I 22 mean... 23 Q. Pasty skin? 24 A. Pasty skin, wrinkly. I 25 didn't I tried to pay as little Page 318 1 HIGHLY CONFIDENTIAL AEO 2 attention to him as possible. During 3 that session, I was completely 4 overwhelmed. I -- it completely took 5 me by surprise, that incident, and I 6 was exceptionally upset by what was 7 going on because I felt that I had 8 been coerced beforehand, that it had 9 been prior arranged to me arriving 10 there. 11 Q. Can you describe any other 12 specific key detail of his person that 13 you haven't already mentioned? 14 A. I can't remember specific 15 ones. It was -- I just tried to just 16 get it done as soon as possible to get 17 out of there. I couldn't wait to get 18 out of there quick enough, to be 19 honest. 20 Q. Did you tell your attorneys, 21 I recall specific key details of this 22 person? 23 A. I think I've just described 24 that key details of this person. 25 Q. Did you say those words to Page 319 1 HIGHLY CONFIDENTIAL AEO 2 your attorneys when you drafted this? 3 MR. GUIRGUIS: Objection, 4 asked and answered. 5 MS. MCCAWLEY: Objection. 6 A. I do recall specific 7 details, which I've given. 8 Q. And they're the ones you've 9 already given? 10 A. I don't -- as I specified, 11 this was a coerced event that took 12 place. I was extremely upset. I did 13 not want to have sexual intercourse 14 with Alan. 15 I did not -- I don't -- I 16 don't remember specific -- I don't 17 remember specific things. I remember 18 me paying particular 19 attention to because I didn't 20 want Alan touching me, so it was -- as 21 I said, it was a traumatic experience. 22 I don't remember the finer 23 details of Alan Dershowitz's private 24 parts or any other thing. I tried to 25 spend as little time as possible Page 320 1 HIGHLY CONFIDENTIAL AEO 2 touching Alan, as I'm sure you can 3 imagine. 4 Q. How was it coerced? 5 A. It was coerced in the sense 6 that when I arrived there, Alan 7 Dershowitz was there and was 8 there. It was quite clear to me what 9 their intention was after me arriving 10 there. 11 Q. There being where? 12 A. Jeffrey's New York 13 apartment. 14 Q. When you arrived at 15 Jeffrey's New York apartment, Alan was 16 already there? 17 A. Yes. 18 Q. And was already there? 19 A. Yes. 20 Q. What were the specific key 21 details of the sex acts that you can 22 remember that you have not already 23 described? 24 A. There was cunnilingus 25 involved, masturbation. Page 321 1 HIGHLY CONFIDENTIAL AEO 2 Q. Who performed cunnilingus on 3 who? 4 A. We all performed cunnilingus 5 on each other. 6 Q. So did anyone perform 7 cunnilingus on Mr. Dershowitz? 8 A. Is that the same as girls 9 and boys? Yeah, same definition. 10 Q. Did you perform cunnilingus 11 on 12 A. Yes. 13 Q. Did she perform it on you? 14 A. Yes. 15 Q. Did Mr. Dershowitz perform 16 it on you? 17 A. Yes. 18 Q. Did he perform it on 19 A. Yes. 20 Q. And any other specific key 21 details of the sex acts you can 22 describe? 23 A. There was a lot of touching, 24 fondling, yeah. 25 Q. When you say Professor Page 322 1 HIGHLY CONFIDENTIAL AEO 2 Dershowitz's name, you say Dershovitz 3 with a V, phonetically, correct? 4 A. I'm slightly dyslexic and 5 I'm terrible with names. So it's 6 known that I've always struggled with 7 pronunciations, especially because of 8 my accent as well. 9 Q. Do you believe you were 10 introduced to him as Dershovitz with a 11 V? 12 A. I was introduced to him as 13 Alan. 14 Q. Did you ever hear anyone say 15 his last name? 16 A. Yes. 17 Q. Did you hear those people 18 say it with a V? 19 A. I can't recall the exact 20 pronunciation of the tongue, but the 21 way my ears hear words -- perhaps you 22 can contact my university. I don't -- 23 I have difficulty with names and I'm 24 slightly dyslexic, so... 25 MS. MENNINGER: Okay. Can Page 323 1 HIGHLY CONFIDENTIAL AEO 2 you mark this as Defendant's 3 Exhibit 5. 4 (Defendant's Exhibit 5, jury 5 trial demand, was marked for 6 identification.) 7 MS. MCCAWLEY: Because I 8 forget earlier, just for the 9 record, the plaintiff in the case 10 is going to mark the deposition 11 as confidential. 12 MS. MENNINGER: Yes. I 13 discussed it with the court 14 reporter, and I think he already 15 has, but if not, he will do it. 16 MS. MCCAWLEY: Okay. 17 Q. Can you take a look at 18 Defendant's Exhibit 5. 19 A. Yes. 20 Q. Have you seen this document 21 before? 22 A. Yes. 23 Q. Did you review it before it 24 was filed? 25 A. Yes. Page 324 1 HIGHLY CONFIDENTIAL AEO 2 Q. What do you understand this 3 document to be? 4 A. This is a complaint against 5 Jeffrey Epstein. 6 Q. Anyone else? 7 A. Ghislaine Maxwell, 8 9 10 Q. And this is a complaint that 11 you authorized be filed on your 12 behalf? 13 A. That's correct. 14 Q. And at the end of this 15 complaint, you ask for money to be 16 awarded to you, correct? 17 A. Can you refer me to the 18 specific page, please? 19 Q. Well, do you understand that 20 you are asking for money to be awarded 21 to you? 22 A. Can you tell me which page 23 that's on, please. 24 Q. I'm just asking your 25 understanding. Page 325 1 HIGHLY CONFIDENTIAL AEO 2 A. Nothing's been promised to 3 me about money. 4 Q. Were you seeking money when 5 you authorized this complaint to be 6 filed on your behalf? 7 A. No. I just wanted a 8 pedophile behind bars, really, and for 9 him to stop abusing young girls. 10 Seeing as I'm going to be a 11 parent myself, I can't really live 12 with myself, knowing that there's a 13 pedophile with my kids on the planet. 14 So as a responsible human being, I 15 thought that I would come forward. 16 Q. So your hope in filing this 17 lawsuit was not to recover any money? 18 A. No. I want Jeffery and 19 Ghislaine and all of these people 20 behind bars so I can then visit them 21 in jail. 22 Q. In paragraph 36 of this, 23 which is on page 11, can I have you 24 review that paragraph. 25 A. Yep. Page 326 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you know what that 3 paragraph refers to? 4 A. Yes, I do. 5 Q. What is the basis for your 6 statement that "Defendant 7 reported to Defendants 8 and Maxwell, and was paid for her 9 recruitment of young females, 10 including the recruitment of 11 plaintiff"? 12 A. She told me face to face, in 13 person, that she was paid by Jeffrey. 14 15 16 17 18 And Jeffrey also offered to pay me \$5,000 to find him a new 18-year-old model PA to help him with his multi-billionaire corporation, because she's that qualified. 19 20 21 people who are 18? Q. So when you say recruitment of young females, you're referring to 22 A. Yes. 23 Q. And at the time you were in 24 touch with Ms. you were 22, 25 correct? Page 327 1 HIGHLY CONFIDENTIAL AEO 2 A. That's correct. 3 Q. Apart from what Ms. 4 told you, do you have any other basis 5 for knowing that reported to 6 and Maxwell and was paid 7 for her recruitment of young females, 8 including you? 9 A. What she told me. 10 Q. Apart from what she told 11 you, do you have any other basis for 12 that? 13 A. Well, I saw it with my own 14 eyes. I was a witness. 15 Q. What did you witness? 16 A. I witnessed the same thing 17 all the other girls did, the same 18 thing I had to do, was go and report 19 to and 20 Ghislaine. 21 Ghislaine was the main lady. 22 and did all 23 the admin, like booking flights, like 24 what a normal PA does. 25 Do you understand? Page 328 1 HIGHLY CONFIDENTIAL AEO 2 Q. Well, did you get paid for 3 recruitment of young females? 4 A. Jeffrey Epstein told me that 5 he would give me money to find him a 6 PA for him in South Africa. 7 Q. You did not find a PA, 8 correct? 9 A. Absolutely not. 10 Q. And you did not get paid for 11 recruitment of young females, correct? 12 A. Absolutely not. 13 Q. You say in paragraph 37 that 14 you were introduced to Epstein by 15 correct? 16 A. Correct. 17 Q. And Epstein confirmed to you 18 that he would use his wealth and 19 influence to have you admitted into 20 FIT, correct? 21 A. That's correct. 22 Q. What did Epstein say to you 23 to confirm that? He said, I will use 24 my wealth and influence to have you 25 admitted, or some other words? Page 329 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember the exact 3 conversation, but from the very 4 beginning Jeffrey and Ghislaine knew 5 what my intentions were and why I 6 wanted to stay in New York, which was 7 to get a degree. 8 Q. Did Epstein say something to 9 you about a similar institute of 10 higher learning offering a curriculum 11 of fashion industry training? 12 A. No. I was pretty adamant 13 that I wanted to go to FIT. It's one 14 of the best fashion schools, so... 15 Q. In paragraph 38, you say 16 Maxwell told you that you would "need 17 to provide Epstein with body massages 18 in order to reap the benefits of his 19 and her connections." 20 What did Ms. Maxwell say to 21 you in regards to giving body massages 22 in order to reap benefits of her 23 connections? 24 A. Well, the fact that she told 25 me I had to weigh 52 kilograms in Page 330 1 HIGHLY CONFIDENTIAL AEO 2 order for them to pay for my 3 education, that was pretty -- that was 4 one of the conversations that she had 5 with me. 6 Q. Does that have something to 7 do with body massages? 8 A. Can you repeat -- let me 9 read the question again. 10 So I would just like to 11 clarify, body massages meant sex, 12 okay? That's like a key word for sex. 13 So as soon as you stop having sex with 14 Jeffrey and his friends and his girls, 15 you're out, because otherwise there's 16 no reason for you to be associated 17 with Jeffrey, because you're just 18 there to have sex with him, so... 19 Q. Can I direct your attention 20 to the first sentence in paragraph 38, 21 and can you just explain to me when 22 that conversation took place. 23 MR. GUIRGUIS: Objection, 24 form. 25 A. First time I met Ghislaine, Page 331 1 HIGHLY CONFIDENTIAL AEO 2 from the very first beginning. 3 Q. What did Ghislaine say to 4 you? 5 A. I can't remember the 6 specific conversation. But the fact 7 that she helped me refine my massage 8 skills to satisfy Jeffrey, I think 9 it's pretty self-explanatory. 10 Q. The one you described 11 earlier? 12 A. The one I described earlier. 13 Q. Okay. In the second 14 sentence, where it says, "Maxwell and 15 Epstein also threatened plaintiff that 16 while they had the ability to advance 17 her education and career, they also 18 had the ability to make sure that she 19 would obtain no formal education or 20 modeling agency contracts if she 21 failed to provide the sexual favors 22 desired by defendant Epstein or abide 23 by the instructions given her by 24 defendants Epstein and Maxwell." 25 A. Mm-hmm. Page 332 1 HIGHLY CONFIDENTIAL AEO 2 Q. What did Ms. Maxwell say to 3 you that gave rise to this particular 4 statement? 5 A. Well, the fact that she used 6 to personally call me herself to give 7 Jeffrey sexual massages. Not body 8 massages; sexual massages. It should 9 be rephrased. 10 I mean, it was pretty 11 obvious. I mean, the whole weight 12 thing. I tried to swim off the 13 island. I tried to escape from an 14 island during the evening to try and 15 escape from her because if I didn't 16 lose weight, they would cut me out of 17 their -- financially off. I would 18 lose the place that I was staying at. 19 I would lose my education. You name 20 it. 21 They bullied me with 22 everything, just like they did with 23 the other girls. 24 Q. In paragraph 38, you say, 25 "Maxwell and Epstein also threatened Page 333 1 HIGHLY CONFIDENTIAL AEO 2 plaintiff." 3 What was the threat that was 4 made to you by Maxwell? 5 MS. MCCAWLEY: Objection, 6 asked and answered. 7 A. The fact that I would lose 8 everything that they promised me. 9 They -- they were really naughty. You 10 know, they took girls from very 11 underprivileged families. They gave 12 them accommodation, they gave them 13 food, gave them money for 14 transportation, you know, private 15 planes, etcetera, etcetera. 16 So if I didn't have sex with 17 Jeffrey, I would be homeless and 18 starving in New York, so -- and my 19 dream of getting a full-time education 20 at one of the top fashion institutes 21 in the world would be diminished. 22 And that's what he held over 23 my head, exactly like he did with 24 and the other girls. He was 25 paying for all of their educations. Page 334 1 HIGHLY CONFIDENTIAL AEO 2 Q. How do you know that? 3 A. Because they were telling 4 me. It was common knowledge amongst 5 all the girls. No other girl would be 6 there willingly just to have sex with 7 Jeffrey. 8 Q. In paragraph 40, you say, 9 "Maxwell instructed plaintiff how to 10 massage Epstein using the techniques 11 that he preferred." 12 A. Correct. 13 Q. Is that the accident you 14 described earlier on the island? 15 A. There were many times that 16 she gave me massage techniques to help 17 refine my techniques. Jeffrey Epstein 18 was all about massages and the 19 techniques. He liked as many girls 20 touching him as possible all the time. 21 So there was more than one 22 occasion that Ghislaine showed me how 23 to massage him. It could have been on 24 that specific trip or the other one. 25 I'm not quite sure day, Page 335 1 2 3 4 5 6 7 8 9 HIGHLY CONFIDENTIAL AEO time, what seat I was sitting in, what color the seat it is, but she on more than one occasion showed me how to massage Jeffrey and how to get out the extreme knots in his body. Because everyone knows about his knots and how he likes them to pop and, yeah, the specific techniques that he likes. 10 11 12 13 Q. The next sentence reads, "During plaintiff's first massage, defendant Epstein converted it into a sexual act..." and it goes on. 14 15 16 17 Ms . Your first massage that defendant Epstein converted into a sexual act was prior to you meeting Maxwell, correct? 18 A. Yes. 19 20 21 MS. MENNINGER: I'm going to show you Defendant's Exhibit 6, which are some photographs. 22 23 24 (Defendant's Exhibit 6, stamped marked for identification.), wa 25 Q. Do you recognize the Page 336 1 HIGHLY CONFIDENTIAL AEO 2 photographs contained in Defendant's 3 Exhibit 6? 4 A. Yes, I do. 5 Q. What are they? 6 A. They are photos of Jeffrey's 7 island and the trip in December. 8 Q. Who took those photos? 9 A. took these specific 10 photos. 11 Q. And when you were asked to 12 provide these to us, where did you 13 locate them? 14 A. I had a disk that 15 had given me as a present and memento 16 of that holiday. 17 Q. Where is that disk now? 18 A. In Spain. 19 Q. Do you see in the corner 20 there are some little numbers with 21 your last name and then some 22 A. II, yeah, okay. 23 Q. I'm only showing you that so 24 we can together go through to some. 25 A. Okay. Page 337 1 HIGHLY CONFIDENTIAL AEO 2 Q. So if I could ask you to 3 turn to -- well, the first ones 4 show -- 5 A. 6 is kitesurfing. 7 Q. Got it. 8 A. Yeah, that's 9 Q. How do you know that that's 10 11 A. Because he came for lunch 12 that day and hi, I'm 13 14 Hi, 15 Q. Did you have any sexual 16 relations with 17 A. No. 18 Q. If you could turn to the one 19 that says 22 in the corner. 20 It's about five or six pages back. 21 A. Yes. 22 Q. Who is that in the 23 photograph? 24 A. 25 Q. And who is the other person? Page 338 1 HIGHLY CONFIDENTIAL AEO 2 A. That's me. 3 Q. 4 taken? And when was this photograph 5 A. This was taken during the 6 December trip. 7 Q. Was there only one trip in 8 December? 9 16 17 Jeffrey Epstein for the first time. 18 So I had been there various times 19 before these were taken. 20 Q. Do you know how many? 21 A. Like I said earlier, 22 several. I mean, I.. . you had taken? A. No. had taken? which was not so long after I met 10 11 Q. Was that the first trip that 12 13 14 Q. When was the first trip you 15 A. I answered that previously, 23 Q. And can you turn to 24 24? 25 A. Mm-hmm. A. From what I recall, yeah. Page 339 1 HIGHLY CONFIDENTIAL AEO 2 Q. Who is that? 3 A. That's the wonderful 4 5 Q. Did you take these 6 photographs? 7 A. took these ones. 8 Q. All of them? 9 A. There were -- I had other 10 photos as well. 11 Q. That came later, a separate 12 batch? 13 A. Yeah, those are the hard 14 copies. 15 MS. MENNINGER: I will mark 16 it now, the second batch, 17 Defendant's Exhibit 7. 18 (Defendant's Exhibit 7, 19 stamped \_000204, was 20 marked for identification.) 21 MS. MENNINGER: I apologize, 22 Counsel. We just got these last 23 night, so I only have one copy 24 for the witness. 25 MR. GUIRGUIS: That's fine. Page 340 1 HIGHLY CONFIDENTIAL AEO 2 Q. So is Defendant's Exhibit 7 3 the second batch that you were 4 referring to? 5 A. Yes. 6 Q. Okay. So I'm just trying to 7 help be clear. 8 Defendant's Exhibit 6, you 9 believe were all given to you by 10 on a disk? 11 A. Well, there's a lot of 12 photos here. So I took some, I had 13 some hard copies, and they're all 14 actually all together, so.. . 15 Q. Okay, that's fine. 16 A. Yeah. I don't want to be 17 unclear on which exhibit is which. 18 There's hundreds here. 19 Q. So the photographs of 20 you're saying were taken by 21 that we were looking at in 22 24? 23 A. Well, I can recheck the disk 24 and then I can actually tell you 25 exactly which ones he took, but I Page 341 1 HIGHLY CONFIDENTIAL AEO 2 can't recall every single photo on 3 's disk. But there were 4 multiple photos that were produced 5 from myself as well. 6 Q. Okay. I will just ask you 7 about a few. 8 A. Okay. 9 Q. 24 is one that you 10 said was -- of was one 11 you said you thought had 12 taken? 13 A. Yes. 14 Q. If you could turn to 15 40. And these are in order, so 16 hopefully that will be easy. 17 A. Okay. Mm-hmm. 18 Q. Who is represented in this 19 photograph? 20 A. That's 21 Q. And where is in this 22 photograph, if you know? 23 A. This is by the beach. 24 There's like -- there's like a small 25 beach, like there's a beach house on Page 342 1 HIGHLY CONFIDENTIAL AEO 2 the beachfront. 3 Q. Do you know who took this 4 photograph? 5 A. I can't remember. 6 Q. Okay. Turning a couple more 7 pages to 42, who is that? 8 A. That's me. 9 Q. Are you smoking? 10 A. I am. And that was after 11 the argument that I had with Jeffrey 12 about me being on lithium and me not 13 being able to smoke. And that was the 14 reason I was really upset, that I 15 couldn't smoke and that I was being 16 put on a stupid diet. 17 So Jeffrey -- yeah, Jeffrey 18 said it was okay for me to smoke. I 19 wasn't allowed to smoke in front of 20 him. That was the rule. 21 Q. Do you know who took this 22 photograph? 23 A. I don't remember who took 24 that photograph. 25 Q. Is it on the same trip in Page 343 1 HIGHLY CONFIDENTIAL AEO 2 December? 3 A. Yes. 4 Q. Turning the next page, is 5 that also you and 6 A. That's correct. 7 Q. Do you know who took this 8 photograph? 9 A. I can't remember. 10 Q. Was it also in the same time 11 frame when you were upset? 12 A. It was that same December 13 trip, yes. 14 MS. MENNINGER: We can go 15 off the record for just a minute. 16 I think we're swapping out 17 counsel. 18 (Ms. McCawley left the 19 hearing and Ms. Syed entered.) 20 (Time noted: 4:56 p.m.) 21 (Recess.) 22 (Time noted: 4:56 p.m.) 23 Q. Looking at 44, 24 you're saying it's in the same time 25 period? Page 344 1 HIGHLY CONFIDENTIAL AEO 2 A. Yeah. 3 Q. And also true of 45? 4 A. Yes. 5 Q. And 47? 6 A. Yes. It was the same 7 holiday, the same trip. 8 Q. And do you know who took 9 these photographs? 10 A. I don't remember. 11 Q. Is that also true for 48, 12 49, 50, 51, 52? 13 A. I don't remember who took 14 those photos. 15 Q. Okay. Can you tell from 52 16 where you were situated on the island? 17 A. It was on the beach. 18 Q. 53, can you tell me who that 19 is? 20 A. That's 21 Q. 54 and 55, also 22 A. That's correct. 23 Q. 69, who is that? 24 A. That's Jeffrey Epstein. 25 Q. Do you know who took this Page 345 1 HIGHLY CONFIDENTIAL AEO 2 photograph? 3 A. I can't remember who took 4 this photograph. 5 Q. 71, is that you? 6 A. That's correct. 7 Q. Were you posing for the 8 photograph? 9 A. Most people pose for 10 photographs, every photograph. So 1 11 presume I was posing. 12 Q. Do you know what 13 line of work is? 14 A. I think he's with modeling 15 or something, like a modeling agent. 16 Q. Do you know where he's 17 based? 18 A. I have no idea where he's 19 based. 20 Q. Did you meet him more than 21 once? 22 A. I can't remember if I met 23 him more than once. 24 Q. Did you have sexual contact 25 with him? Page 346 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Did you give him a massage? 4 A. No. 5 Q. Sorry. Going back a little 6 bit further to 121. 7 A. Mm-hmm. 8 Q. Who is in that photograph? 9 A. That's and 10 Q. Okay. So 's on the 11 left? 12 A. That's correct. 13 Q. And 's on the right? 14 A. That's correct. 15 Q. Do you know what they're 16 doing? 17 A. I would love to know what 18 they're doing myself, personally. 19 Q. Did you take this 20 photograph? 21 A. I can't remember. 22 Q. Turning to 123, do you know 23 what is happening in that photograph? 24 A. I think we were just playing 25 around. I don't think it was serious, Page 347 1 HIGHLY CONFIDENTIAL AEO 2 you know. 3 Q. Okay. 4 A. Just to make that clear. 5 Q. Can I have you look at 126. 6 A. Yeah. 7 Q. Who is in that photograph? 8 A. That's and 9 Q. And is in the 10 background? 11 A. That's correct. 12 Q. On 127 13 A. Mm-hmm. 14 Q. -- who is in that 15 photograph? 16 A. To the right -- sorry, to 17 the left it's myself, 18 and then 19 Q. Is this on the same December 20 trip? 21 A. That's correct. 22 Q. When did give you 23 the disk? 24 A. I can't remember when he 25 gave me the disk. Page 348 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you know if these 3 photographs are ones that he took? 4 A. They were photos that were 5 taken during our holiday together, and 6 they were given to me as a memento, as 7 a present from 8 Q. In person? 9 A. I can't remember. 10 Q. Do you recall the tortoise? 11 A. I can't remember the 12 tortoise. 13 Q. Apart from 14 and yourself and, do 15 you remember anyone else being on this 16 particular trip? 17 A. There were -- there were 18 quite a few people that visited the 19 island. I don't remember their names. 20 Q. Can I have you look at 138. 21 A. Mm-hmm, yeah. 22 Q. Do you know who took that 23 photograph? 24 A. I don't know who took that 25 photograph. Page 349 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you know when it was 3 taken? 4 A. It was taken that December 5 trip that I took with Ghislaine and 6 Jeffrey. 7 Q. How do you know that? 8 A. Because I remember what she 9 was wearing. And I was there. I was 10 there in person. Like, I was there. 11 Q. So you saw her on the island 12 wearing those clothes? 13 A. I saw her on the island 14 wearing those clothes. 15 Q. Did you see her sitting in 16 this position while on the island? 17 A. I saw her with my own eyes 18 sitting in this position. I was 19 probably sitting next to her. 20 Q. But you don't know if you 21 took the photograph or someone else? 22 A. You know what? Photos are 23 photos. I don't remember if I took 24 the photo or if someone else took the 25 photo. Page 350 1 HIGHLY CONFIDENTIAL AEO 2 All I remember is I was with 3 Ghislaine on this trip. I was 4 probably sitting next to her in this 5 photo. I don't know who -- which 6 specific girl took the photo. 7 Q. Do you know if it was a girl 8 who took the photo? 9 A. I have no idea who took the 10 photo. I just remember sitting there 11 and remember being next to Ghislaine 12 while she was wearing that outfit. I 13 was there during that time frame. 14 Q. 139, who is that, if 15 you know? 16 A. That is after 17 she had a shower, and she's in 18 Victoria's Secret pajamas that were 19 supplied to us. 20 Q. They were supplied to you? 21 A. Yes. All of the outfits -- 22 there were clothes that were provided 23 on the island by Jeffrey Epstein, 24 which were all Victoria's Secret 25 clothing: bikinis, nightwear. Page 351 1 HIGHLY CONFIDENTIAL AEO 2 Q. You're talking about the 3 flannel pajamas? 4 A. Yes. 5 Q. Page 140, do you know who 6 took this photograph? 7 A. I don't remember taking this 8 photo, but I remember that very well 9 because we are doing mosaic on that 10 table. We were busy doing a fish. So 11 that's what all these are apparatus 12 are. We were doing mosaics. 13 So I don't remember if I 14 took that photo, but I remember I was 15 there, because we were all doing 16 mosaics. 17 Q. 142? 18 A. Mm-hmm. 19 Q. Do you remember who took 20 that photograph? 21 A. I can't remember -- is, the 22 BlackBerry. I can't remember who took 23 all the photos when I was there. You 24 can see the mosaics that we were doing 25 together. Page 352 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you still have that 3 mosaic? 4 A. No. It was on the big table 5 that she's sitting at, the large 6 table. So we actually stuck the 7 mosaic on the table. 8 Q. 143, do you know who took 9 that? 10 A. No. We were all there 11 together. 12 Q. Going through the rest, do 13 you see any that you know who took the 14 photo? 15 A. No. 16 MR. GUIRGUIS: Take your 17 time and look at each onem. 18 Don't just -- take your time. 19 Can we take a break for just 20 a minute. 21 (Time noted: 5:06 p.m.) 22 (Recess.) 23 (Time noted: 5:15 p.m.) 24 Q. Did you have a chance to 25 look through the rest of the Page 353 1 HIGHLY CONFIDENTIAL AEO 2 photographs in Defendant's Exhibit 6? 3 A. No, because I took a break, 4 so I will continue now. 5 Q. Sure. 6 A. I can't remember who took 7 these photos. It was during all the 8 same trip. 9 Q. It was what? 10 A. It was during that same 11 trip. 12 Q. Can I have you take a look 13 at 154. It's one of the last 14 few of that exhibit. 15 A. Yes. 16 Q. Do you know where that 17 photograph was taken? 18 A. I can't remember. 19 Q. Do you know if you were 20 there? 21 A. I can't remember. 22 Q. Does it appear to be inside 23 of a shop? 24 A. It appears that way. 25 Q. Do you recall going to any Page 354 1 HIGHLY CONFIDENTIAL AEO 2 shops on that trip? 3 A. I went everywhere with 4 Jeffrey, so... 5 Q. Did that include shops? 6 A. Yes. 7 Q. Do you recall this shop? 8 A. There were many shops that I 9 visited. I can't recall this specific 10 shop. 11 Q. Do you know who the 12 gentleman is? 13 A. I can't remember his name. 14 Q. And by gentleman, I mean the 15 person on the left. 16 A. Thank you for clarifying 17 that. 18 No, I don't recall. I don't 19 know who this Jeffrey -- Jeffrey's on 20 the right. I don't know the name, I 21 can't remember the name of this guy. 22 Q. Wearing a belt? 23 A. Trying on a belt, yeah. 24 Q. Okay. Turning to 25 Defendant's Exhibit 7. Page 355 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. Do you recognize these 4 photographs? 5 A. I remember this photograph, 6 the first one, very well. 7 Q. What is it? 8 A. It's a box -- it's a box of 9 condoms that were placed around the 10 island for the guests to use at their 11 leisure. 12 Q. Where on the island was this 13 one? 14 A. I can't remember. 15 Q. Did you take the photograph? 16 A. I can't remember. 17 Q. Do you have this photograph 18 at your house now? 19 A. I'll have to recheck. I 20 can't remember where this photo came 21 from, if it was either on the disk or 22 by myself. But it was -- I recognize 23 the box. There were boxes like this 24 put everywhere. 25 Q. Did you have any photographs Page 356 1 HIGHLY CONFIDENTIAL AEO 2 contained on your computer? 3 A. No. 4 Q. Where were photographs that 5 you gathered together to produce? 6 A. You've got them all there. 7 I just need to -- all the photos that 8 I have, you guys have. So I don't 9 know. 10 Q. Where were they? Where did 11 you find them? 12 A. My photos? 13 Q. Yes. 14 A. In my storage. 15 Q. Where is that? 16 A. It was in England. It was 17 in my private box where I keep all my 18 photos from, you know, when I was a 19 baby to now, so... 20 Q. Is that with your mother? 21 A. No, that wasn't with my 22 mother. 23 Q. Where is the storage in 24 London? 25 A. The storage was in Ramsgate. Page 357 1 HIGHLY CONFIDENTIAL AEO 2 Q. And where did it go? 3 A. It's now in my current 4 residency in Spain. 5 Q. When you gathered the photos 6 together and gave them to your lawyer 7 to give to us, did you gather them in 8 Spain or in London? 9 A. My stuff was in London and I 10 moved to Barcelona. I was currently 11 staying in Barcelona with and 12 we were just going to commute between 13 St. Albans and Barcelona. 14 When I came forward, I knew 15 that I had photos that I had taken and 16 I knew that I had materials. 17 At that same time is 18 during that same time, I contacted 19 Maureen Callahan. When I contacted 20 Maureen Callahan, there were people 21 that were following me in Barcelona, 22 and I got scared. 23 I then contacted my estate 24 agent. I got my entire flat packed up 25 in St. Albans and moved to Spain. I Page 358 1 HIGHLY CONFIDENTIAL AEO 2 was too frightened to actually fly 3 back myself and pack, so I stayed in 4 Barcelona and a company packed my 5 things for me and brought them to me. 6 Q. Okay. So they were in St. 7 Albans. You had them all packed up 8 and sent to you in Barcelona, where 9 you relocated? 10 A. That's correct. 11 Q. When you were interacting 12 with Ms. Callahan, did you send her 13 any photographs? 14 A. Sorry, sorry. Who is 15 Ms. Callahan? Sorry. I'm just really 16 tired. I'm really bad with names. 17 Callahan first name, please. 18 Q. Do you know who Ms. Callahan 19 is? 20 A. It's really late, I've had a 21 really long day, and I've said 22 numerous times throughout the day that 23 I am slightly dyslexic and I have 24 difficulty with names. 25 Can you just tell me Page 359 1 HIGHLY CONFIDENTIAL AEO 2 Ms. Callahan's first name so I can 3 answer the question, please. 4 Q. Is Ms. Callahan the name of 5 the individual that you said worked 6 for the New York Post? 7 A. II, sorry. Maureen 8 Callahan, yes. 9 Q. Did you send Ms. Callahan 10 any photographs? 11 A. Not of this, no. Not of 12 this. 13 Q. Did you send her photographs 14 of something else? 15 A. I did. I sent her a photo 16 of ME mm 17 ll 18 A. 19 II II 20 A. El . • 21 • 22 • • • • 23 24 • • II Page 360 HIGHLY CONFIDENTIAL AEO • - I 4 Q. Why did you send 5 Ms. Callahan a photograph of V A. Because I wanted to show her 8 I was telling the truth about 9 everything. I didn't want to send a 10 journalist anything regarding Jeffrey 11 Epstein because I -- I -- well, I sent 12 her a picture of 13 to show that I was telling my story, 14 that my story was straight from the 15 beginning, MIMM , etcetera. So... Q. • - I II IN I - • • • Page 361 1 HIGHLY CONFIDENTIAL AEO 2 I I 4 Q. Apart from the photograph 5 , did you send 6 Ms. Callahan any other documents or 7 photographs? 8 A. I can't remember. 9 Q. Did you have contact with 10 any other media person? 11 A. I can't remember. 12 Q. Did you meet with anyone 13 from the Daily Mail? 14 A. No. 15 Q. From the Mirror? 16 A. No. 17 Q. Did you speak to anyone from 18 the Daily Mail? 19 A. No. 20 Q. Anyone from the Mirror? 21 A. No. 22 Q. The Independent? 23 A. No. 24 Q. The Guardian? 25 A. No. Page 362 1 HIGHLY CONFIDENTIAL AEO 2 Q. When you got these boxes of 3 items from St. Albans and you looked 4 at them while you were in Barcelona; 5 is that right? 6 A. I -- 7 MR. GUIRGUIS: Objection. 8 A. I looked at them -- I 9 vaguely went through the photos in St. 10 Albans. I knew what was there. Yeah, 11 I -- they were there, so I saw them. 12 I went through my photos, like all my 13 memorabilia that had been in storage. 14 But that's about it. 15 Q. And you selected photographs 16 to send to your lawyers to give to us, 17 correct? 18 A. I was asked to -- well I 19 just provided every -- all the 20 evidence that I had. 21 Q. When did do you that? 22 MR. GUIRGUIS: I'm going to 23 object. If you're talking about 24 a communication between client 25 and counsel -- is that what Page 363 1 HIGHLY CONFIDENTIAL AEO 2 you're asking for? 3 MS. MENNINGER: No. I'm 4 asking when did you provide all 5 of your evidence, which is what 6 she said that she had. 7 MR. GUIRGUIS: The photos 8 you mean when she provided them 9 to her counsel? 10 MS. MENNINGER: Yes. 11 Q. When did you provide them to 12 your counsel? 13 MR. GUIRGUIS: Objection. 14 Do not answer. 15 Q. Did you receive a subpoena 16 in this case? 17 A. I don't know what a subpoena 18 is. 19 MS. MENNINGER: Let's mark 20 Defendant's Exhibit 8. 21 (Defendant's Exhibit 8, 22 Notice of Service of Rule 45 23 Subpoena and Notice of Deposition 24 of 25 identification.) was marked for Page 364 1 HIGHLY CONFIDENTIAL AEO 2 Q. Have you seen this document 3 before? 4 A. Let me just have a look, 5 okay. I don't remember. 6 Q. Have you ever seen this 7 document before? 8 MR. GUIRGUIS: Objection, 9 asked and answered. 10 MS. MENNINGER: I'm sorry. 11 I didn't hear an answer. 12 A. I've seen various papers. I 13 remember specifically seeing the 14 depositions. There's been millions of 15 documents. I can't remember which 16 specific documents I've seen. 17 Q. Okay. If I could have you 18 turn to the last three pages, where it 19 says "Documents to be Produced." 20 A. Mm-hmm. 21 Q. Have you seen that list 22 before? 23 A. Yes, I have. 24 Q. Did you conduct a search of 25 your records to produce documents? Page 365 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes, I believe that I 3 produced every single document I can. 4 Q. After looking at this list, 5 did you go back and look through your 6 photographs in Barcelona? 7 A. As I said, I looked at 8 everything I had during that time 9 frame and I produced everything I can 10 during that time frame that I was with 11 Jeffrey. 12 Q. Just tell me what you did in 13 order to make sure you had produced 14 everything that was called for in this 15 list. 16 A. Okay. So I went through a 17 box of about over 5,000 photos that I 18 had, and I went through every single 19 photo, every single disk, everything 20 that I had. 21 I went through all my 22 emails. 23 I tried to look for the 24 BlackBerry sim card, which I had hoped 25 that I had kept, which had all Page 366 1 HIGHLY CONFIDENTIAL AEO 2 Ghislaine's messages on and Jeffrey's 3 and 's, and stupidly I misplaced 4 that, which is really annoying. 5 But I myself, you know, 6 considering my objective is to get 7 these people and get justice for the 8 abuse that Ghislaine caused me -- and 9 Jeffrey -- I have given as sufficient 10 evidence that I have. 11 Q. Did you look for all 12 photographs taken by you or containing 13 any image of you at or near any home, 14 business, private vehicle or any other 15 property owned or controlled by 16 Jeffrey Epstein, as indicated in 17 paragraph 7? 18 A. Yes. 19 Q. Likewise in paragraph 8, did 20 you look for any photographs that 21 depict any home, business, private 22 vehicle or any other property owned or 23 controlled by Jeffrey Epstein? 24 A. Yes. 25 Q. And you did that after Page 367 1 HIGHLY CONFIDENTIAL AEO 2 reviewing this list of documents? 3 A. Yeah, I mean, I received the 4 list and I've complied with 5 everything. I have given absolutely 6 everything that I can to you guys. 7 Q. Have you given all of your 8 passports, travel visas or permissions 9 to live, work or study in other 10 country? 11 A. I haven't given my current 12 passports, but I've given everything 13 that I have; documents, passports that 14 I had during, commercial plane 15 tickets. 16 Q. Do you have any visas? 17 A. I have a visa coming here, 18 but that's the only visa that I have. 19 Q. Do you have any visa 20 applications? 21 A. No. 22 Q. Do you have any other plane 23 tickets or boarding passes for the 24 period 2006 to 2007? 25 A. No. Page 368 1 HIGHLY CONFIDENTIAL AEO 2 Q. Turning back to Defendant's 3 Exhibit 7, these photographs, do you 4 know what the second photograph 5 represents? 6 A. Yes, that's me playing with 7 Ghislaine's dog, a Yorkshire Terrier. 8 Q. Where are you in this 9 picture? 10 A. I was in the girls' bedroom 11 where we all slept, and I was on my 12 bed playing with Ghislaine's dog. 13 Q. When was this photograph 14 taken? 15 A. I can't remember. 16 Q. Was it the same trip as 17 Defendant's Exhibit 6? 18 A. I can't remember. 19 Q. Okay. Do you know who took 20 the photograph in 205? 21 A. I can't remember. 22 Q. 206? 23 MR. GUIRGUIS: Objection to 24 form. 25 A. I can't remember. Page 369 1 HIGHLY CONFIDENTIAL AEO 2 Q 207? 3 MR. GUIRGUIS: Objection to 4 form. 5 A. Can't remember. 6 Q. Who is depicted in 208? 7 A. 8 Q. And? 9 A. II, and me. That's me. 10 Q. And 209? 11 A. Sorry. That's me, 12 , and one of Jeffrey's staff 13 members in the background. 14 Q. Turning to 213, is that you? 15 A. Yes, that's me. 16 Q. And where are you located? 17 A. I'm trying to remember 18 specifically where that is on the 19 island. I think it's near the main 20 house, there was a -- yeah, there was 21 a fountain near the main house. 22 Q. Do you know whether you took 23 this? 24 A. I don't remember. 25 Q. Do you know whether you had Page 370 1 HIGHLY CONFIDENTIAL AEO 2 this photograph on the disk? 3 A. I think these were one of my 4 photos. 5 Q. Was it in hard copy, like an 6 actual print? 7 A. I can't remember. I have to 8 double check if there are more copies 9 But I think -- yeah, I'm pretty sure 10 this is a hard copy. 11 Q. Does it have a back, like 12 when it was developed or printed? 13 A. I can check. 14 Q. Is it back in Barcelona? 15 A. No. 16 Q. Where are these photographs? 17 A. I have given all the 18 photographs to my lawyers. 19 Q. Okay. How did you do that? 20 By handing them over in person? 21 Sending them by mail? 22 A. Handing them over in person. 23 Q. Was this some type of photo 24 shoot represented in 214, 215, 25 216? Page 371 1 HIGHLY CONFIDENTIAL AEO 2 A. Sorry. 214, this is not a 3 photo shoot. We were just messing 4 around on the island. 5 Q. Do you know who you were 6 messing around with? 7 A. We were all having fun 8 together. 9 Q. Were there photographs of 10 other people taken around the same 11 time that you have? 12 A. I have given all the photos 13 that I have. 14 Q. In other words, if you were 15 messing around with at this 16 time and there's a photo of 17 that you have, did you provide that? 18 A. I provided every single 19 photograph that I have. 20 Q. And 218, was that a photo 21 shoot? 22 A. That was me when I was 23 naked, actually, and I had a towel 24 around me. So I think I just had a 25 massage by Jeffrey, because I was Page 372 1 HIGHLY CONFIDENTIAL AEO 2 naked underneath the towel. 3 Q. Also 219 and 220? 4 A. Yep. 5 Q. Those were just after a 6 massage? 7 A. Yeah. You can tell I look 8 really, really happy to be out of 9 there, so... 10 Q. Do you know which trip that 11 was on? 12 A. I can't remember which trip. 13 Q. And page 221, who is 14 in that photograph? 15 A. Myself, and 16 and a staff member in the background. 17 Q. Do you know what's happening 18 in 223? 19 A. II, no. Yes. So Jeffrey 20 provided cosmetics for all the girls. 21 We had to look our best. So that was 22 a Creme de la Mer facial mask that he 23 regularly gave to the girls so their 24 skin was nice. We had top-line 25 cosmetics in our bathroom to use at Page 373 1 HIGHLY CONFIDENTIAL AEO 2 our disposal. 3 Q. So in 223 and 224 you're 4 doing a facial mask? 5 A. I'm attempting to do a 6 facial. It's not going that well. 7 Q. And going to 229, do you 8 know where that was taken? 9 A. That was on Jeffrey's 10 speedboat to -- going to the island. 11 Q. Do you know when? 12 A. I don't recall which date 13 that was. 14 Q. Did you have any contact 15 with the mail on Sunday? 16 MR. GUIRGUIS: Objection. 17 Huh? 18 Q. Did you ever have any 19 contact with the mail on Sunday? 20 A. No. 21 MR. GUIRGUIS: You mean the 22 mail as in postage? I'm sorry. 23 MR. PAGLIUCA: The 24 newspaper. 25 A. No, no, I haven't had Page 374 1 HIGHLY CONFIDENTIAL AEO 2 correspondence with them, no. 3 Q. Apart from Ms. Callahan, 4 have you had contact with any member 5 of the press? 6 A. II, I contacted 7 because 8 9 Q. Okay. Did you have any 10 contact with any other member of the 11 press? 12 A. No. 13 Q. When was the last time that 14 you saw Ghislaine Maxwell? 15 A. In New York, before I left 16 in 2007. 17 Q. How long before you left? 18 A. I can't remember. 19 Q. What time of year was it? 20 A. When I left? 21 Q. Yes. 22 A. It was the end of April. 23 Q. How do you know that? 24 A. Because I am on some of 25 the emails, I wanted to go home. Page 375 1 HIGHLY CONFIDENTIAL AEO 2 Actually, back to my mom. 3 Q. When's the last time you 4 spoke to Ghislaine Maxwell? 5 A. Before I left New York. 6 Q. Okay. Do you know how long 7 before you left? 8 A. I can't remember. 9 Q. Tell me what you recall 10 about the last time you saw Ghislaine 11 Maxwell. 12 A. I can't remember. 13 Q. Where it was? 14 A. I can't remember my last 15 interaction with Ghislaine. 16 Q. Or the last time you spoke 17 with her? 18 MR. GUIRGUIS: Objection, 19 asked and answered. 20 A. I can't remember the last 21 time I spoke to her. Yeah, I don't 22 remember the specifics. 23 Q. Were you living with at 24 the time you last spoke to Ghislaine? 25 A. Yes. Page 376 1 HIGHLY CONFIDENTIAL AEO 2 Q. What did she say to you when 3 you last spoke to her -- 4 MR. GUIRGUIS: Objection, 5 asked and answered. 6 Q. -- when you were living with 7 8 MR. GUIRGUIS: Objection, 9 asked and answered. 10 A. I can't remember. 11 Q. Did you speak to her about 12 FIT? 13 MR. GUIRGUIS: Objection, 14 asked and answered. 15 A. I had spoken to her numerous 16 times about FIT. 17 MS. MENNINGER: Counsel, 18 when did I already ask her, did 19 you speak to her about FIT. 20 MR. GUIRGUIS: You've asked 21 her -- 22 THE WITNESS: Several times. 23 MS. MENNINGER: I'm not 24 talking to you. 25 MR. GUIRGUIS: Okay. Page 377 1 HIGHLY CONFIDENTIAL AEO 2 THE WITNESS: That was rude. 3 MR. GUIRGUIS: It was, and 4 I'm not going to answer her 5 question now. 6 You can proceed, Counsel. 7 MS. MENNINGER: When did I 8 last ask her about -- 9 MR. GUIRGUIS: I'm not going 10 to answer your question. I'm not 11 being deposed. I'm not arguing 12 objections with you. You have 13 asked her about it before; that's 14 why I made my objection. 15 You can proceed with your 16 questioning whenever you like, 17 Counsel. 18 MS. MENNINGER: Thank you. 19 MR. GUIRGUIS: Feel free to 20 search the transcript later. 21 MS. MENNINGER: I would like 22 to mark as Defendant's Exhibit 8. 23 (Defendant's Exhibit 8, 24 stamped, was 25 marked for identification.) Page 378 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you recognize Defendant's 3 Exhibit 8? 4 A. Yes, I do. 5 Q. What is it? 6 A. They're emails. 7 Q. Did you find these emails 8 and produce them? 9 A. That's correct. 10 Q. Where did you find them? 11 A. On my old email account that 12 I had during that time. 13 Q. What was your old email 14 account? 15 A. 16 Q. When did you stop using that 17 email account? 18 A. A guess a year or a few 19 months after. I can't recall when I 20 stopped using it. 21 Q. Do you see on the first page 22 where it says 004, there are 23 two emails in the chain which are 24 visible? 25 A. That's correct. Page 379 1 HIGHLY CONFIDENTIAL AEO 2 Q. And did you produce the 3 other emails between those two that 4 are not visible? 5 A. Yes. 6 Q. When did you do that? 7 A. The same time I provided all 8 the emails originally. 9 Q. Okay. So you believed that 10 you produced six emails of 11 conversation between yourself and 12 13 MR. GUIRGUIS: I'm going to 14 object and just ask for 15 clarification. 16 I'm not trying to give you a 17 hard time on this one. When you 18 say produced, you're asking the 19 witness if she provided it to her 20 attorneys, right? Because 21 obviously the attorneys produced 22 the documents in this case. 23 MS. MENNINGER: Correct. 24 MR. GUIRGUIS: So just 25 she didn't produce anything, Page 380 1 HIGHLY CONFIDENTIAL AEO 2 obviously. 3 So she's asking you did you 4 collect this email and give it to 5 the lawyers, I guess is the 6 question. 7 A. Yeah, I collected all 8 all -- everything I had, I gave to my 9 lawyers. 10 Q. Okay. So you believe you 11 gave six emails between yourself and 12 to your attorneys? 13 A. Yes, I gave all my evidence. 14 Q. Okay. And -- 15 MR. GUIRGUIS: I'm going to 16 object to that last question also 17 as misrepresenting the testimony. 18 MS. MENNINGER: What was 19 misrepresenting what testimony? 20 MR. GUIRGUIS: You're saying 21 that she gave six emails. 22 MS. MENNINGER: Well, let's 23 go back, then, and get the 24 testimony right. 25 Q. On 004, how many Page 381 1 HIGHLY CONFIDENTIAL AEO 2 emails between yourself and 3 do you see total? 4 There's one at 1:04 a.m., 5 correct? 6 MR. GUIRGUIS: Counsel, 7 you're doing the exact thing that 8 I just tried to avoid confusion 9 on, right? 10 There's a difference between 11 what was produced to you -- and 12 apparently and you're saying that 13 six emails were produced to 14 you -- 15 MS. MENNINGER: No, I was 16 not saying that. 17 MR. GUIRGUIS: -- which 18 she's providing to her counsel. 19 MS. MENNINGER: No, I'm not 20 saying that. So I'm trying to 21 get it straight now. 22 Q. There's an email indicated 23 on the first page from to you 24 at 1:04 a.m. on February 3rd, 2007, 25 correct? Page 382 1 HIGHLY CONFIDENTIAL AEO 2 A. Mm-hmm. Yes. 3 Q. And you can read the text of 4 that email, correct? 5 A. Yes, I can. 6 Q. And the next email down says 7 " at 4:07 -- at 4:01 8 p.m. 9 A. Mm-hmm. 10 Q. Can you read that email? 11 A. No, because it's on Yahoo. 12 It's a technological thing. You can't 13 read all emails. 14 Q. So did you produce the 15 February '04, '07, 4:01 p.m. email 16 from yourself to to 17 your attorneys? 18 MR. GUIRGUIS: Objection to 19 the use of the word produce. 20 A. I've given all my email 21 correspondence to my lawyers. 22 Q. Did you give that email to 23 your lawyer? 24 A. I've given all my emails to 25 my lawyers. Page 383 1 HIGHLY CONFIDENTIAL AEO 2 Q. Okay. The next email down 3 says " , February 5, 2007, 4 at 10:09 p.m." 5 Can you read the text of 6 that email on this document? 7 A. Mm-hmm. 8 Q. What does the 10:09 p.m. 9 email say? 10 A. As I've specified before, 11 this is a screenshot, okay, of the 12 actual Yahoo email. This is a 13 screenshot. So technically I can't 14 read that anyways, seeing as it's a 15 screen shot. 16 Q. Okay. 17 A. This isn't a computer. I 18 can't tap into that email on a page 19 because it's a screen shot. 20 Q. Did you give a February 6th, 21 '07, 2:00 a.m. email between yourself 22 and to your attorneys? 23 A. I have handed all over my 24 evidence to my attorneys. 25 Q. Did you give a February 8, Page 384 1 HIGHLY CONFIDENTIAL AEO 2 2007, 9:12 p.m. email from yourself to 3 to your attorneys? 4 A. I have given all my evidence 5 to my attorneys. 6 MS. MENNINGER: I'm going to 7 show you Defendant's Exhibit 10. 8 (Defendant's Exhibit 10, 9 stamped, was 10 marked for identification.) 11 Q. Do you recognize Defendant's 12 Exhibit 10? 13 A. Yes. 14 Q. What is it? 15 A. It's an email correspondence 16 between and myself. 17 Q. On the second page, 18 0008, do you see other emails with 19 headings but no text visible in the 20 screenshot? 21 A. Mm-hmm. 22 Q. Did you give each one of 23 those emails to your attorneys? 24 A. I have given all my 25 correspondence to my attorneys. Page 385 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you see in the "Smart 3 View" column on the left side a folder 4 named 5 A. Yes, I do. 6 Q. Does that folder contain 7 your correspondence with 8 9 A. I didn't even know that 10 folder was there, but I presume so, 11 which is why I would have created it 12 in the first place. 13 Q. And it also shows a 14 substantial number of documents in 15 your Inbox. 16 A. Yes. 17 Q. Did you search your Inbox 18 for documents responsive to the 19 subpoena that I showed you a little 20 while ago? 21 A. I did. I wanted to be 22 thorough with my research, so I, 23 during that time frame, went through 24 every single email. 25 Q. You went through each one? Page 386 1 HIGHLY CONFIDENTIAL AEO 2 A. I went through all of my 3 emails to make sure I gave all my 4 evidence to my lawyers. 5 Q. Did you search for keywords 6 or did you just read each email? 7 A. I read each email. 8 Q. And did you print out each 9 email? 10 A. I didn't print out. I saved 11 them to a USB stick. 12 Q. All of them or just the ones 13 that you thought were needed? 14 A. Just the ones that were 15 for -- just anything related to 16 Jeffrey, I sent over. 17 Q. And I think you testified 18 earlier you believe you still have 19 your FIT application in an email? 20 A. I haven't read it. I'm 21 assuming I have it. 22 MS. MENNINGER: I want to 23 show you Defendant's Exhibit 11. 24 (Defendant's Exhibit 11, 25 Maureen Callahan article, was Page 387 1 HIGHLY CONFIDENTIAL AEO 2 marked for identification.) 3 A. II, it's 9th of October, 4 sorry. 5 Q. Do you recognize this 6 document? 7 A. Let me go to the last 8 sentence. That catchphrase that I 9 mentioned earlier, as I said earlier, 10 I couldn't remember the contents of 11 the article earlier. I do apologize, 12 I got the date wrong from the 16th. 13 It was actually the 9th of October. I 14 couldn't remember the specific date. 15 I remember the specific 16 statement that really struck a chord 17 with me, which was, "The true number 18 of Epstein's victims will never be 19 known." 20 Q. So you believe this is the 21 document by Maureen Callahan that you 22 read last October that caused you to 23 come forward? 24 A. I'm presuming so, because 25 I've gone straight to the bank, and Page 388 1 HIGHLY CONFIDENTIAL AEO 2 the sentence that I told you that I 3 remembered is this. So I'm assuming, 4 yes, that it's the same. 5 Q. And this article had a big 6 impact on you because it caused you to 7 come forward, I think you testified 8 earlier; is that correct? 9 A. That's correct. 10 Q. All right. Do you also see 11 on that last page, just right where 12 you were, there's a little box on the 13 left hand side. Can you read that out 14 loud, beginning "Today Jeffrey 15 Epstein..." 16 Do you see that in bold 17 letters on that last page? 18 A. 19 Q. Can you just read that 20 sentence to us? 21 A. "Today Jeffrey Epstein is a 22 free man, albeit one who routinely has 23 civil lawsuits brought against him by 24 young women out of court." 25 MS. MENNINGER: Okay. Page 389 1 HIGHLY CONFIDENTIAL AEO 2 Defendant's Exhibit 12. 3 (Defendant's Exhibit 12, 4 website printout titled How to 5 Apply, was marked for 6 identification.) 7 Q. Do you recognize this 8 document? 9 A. I've seen it before, yes. 10 Q. And what do you recognize it 11 be? 12 A. It's the application how you 13 apply to FIT. 14 Q. It talks about students 15 applying to different parts of the 16 school, including arts and design or 17 business and technology. 18 Do you recall if you were 19 applying to a particular area at FIT 20 or a general admission? 21 A. I wanted to specialize in 22 fashion designing. 23 Q. Do you know if that was a 24 special area? 25 A. Yes, it was. FIT's the Page 390 1 HIGHLY CONFIDENTIAL AEO 2 financial -- fashion school, so yeah. 3 Q. Did you visit the building 4 where FIT is located? 5 A. Yes, I did. 6 Q. Did you attend classes 7 there? 8 A. No. 9 Q. I mean did you visit a 10 class. I know you didn't enroll, but 11 did you visit a class? 12 A. No, I didn't. But I went to 13 the university, had a look around. 14 Q. Did you take a tour? 15 A. Not per se. I mean, I went 16 around, I looked at the university. I 17 didn't go on a big personalized tour 18 with a specific person, no. 19 Q. Did you talk to any of the 20 teachers there? 21 A. No, I didn't. 22 Q. Do you recall there being 23 multiple steps for applications to 24 FIT? 25 A. There's multiple steps on Page 391 1 HIGHLY CONFIDENTIAL AEO 2 any college application form. 3 Q. Do you remember what those 4 steps were when you were applying? 5 A. No. 6 Q. Do you remember an original 7 application which had details? 8 A. I can't remember the 9 original application form, no. 10 Q. Do you remember there being 11 a separate essay portion? 12 A. Yes, I do remember that. 13 Q. Do you remember a separate 14 portion that relates to students who 15 are applying who are not U.S. 16 citizens? 17 A. I can't remember that. I 18 can't remember the specific form. 19 Q. Do you remember filling out 20 any special paperwork for someone who 21 was applying who was not a U.S. 22 citizen? 23 A. No, there was no paperwork 24 as such for that. Jeffrey Epstein was 25 sorting that out for me with his Page 392 1 HIGHLY CONFIDENTIAL AEO 2 connections at FIT. 3 Q. So you don't believe you 4 filled that part out? 5 MR. GUIRGUIS: Objection. 6 A. I said I can't remember 7 filling that part out. 8 Q. Do you remember getting a 9 copy of your transcript from Queen 10 Margaret University? 11 A. I haven't got my transcripts 12 yet, but I can get them. 13 Q. Do you remember submitting 14 them to FIT? 15 A. I can't remember. 16 Q. Did you get a degree from a 17 school in Edinburgh, high school? 18 A. So I finished all my high 19 school qualification, which, you know, 20 my grades were good enough to get into 21 psychology and sociology in Edinburgh. 22 Q. What was the name of your 23 high school? 24 A. Grantown Grammar School. 25 Q. Did you get a transcript Page 393 1 HIGHLY CONFIDENTIAL AEO 2 from that school to provide to FIT? 3 A. I think I was in the process 4 of getting my transcripts from Queen 5 Margaret. I did have a copy of my 6 high school grades as well. When you 7 fill out an application, you submit 8 all your grades, high school. 9 Q. And that's the one in 10 Scotland? 11 A. Yes, that's correct. 12 MS. MENNINGER: I think I've 13 only got a couple more questions, 14 but I got my piles messed up. 15 Can we take a two-minute break 16 and I can get organized and 17 finished. 18 (Time noted: 5:54 p.m.) 19 (Recess.) 20 (Time noted: 6:07 p.m.) 21 MS. MENNINGER: I'm going to 22 mark a new exhibit Defendant's 23 Exhibit 13. 24 (Defendant's Exhibit 13, 25 stamped was Page 394 1 HIGHLY CONFIDENTIAL AEO 2 marked for identification.) 3 Q. Do you recognize this 4 document? 5 A. Yes, I do. 6 Q. What is it? 7 A. It was an email sent to my 8 friend 9 Q. Is that different than 10 that you were with on the island? 11 A. I was never with on the 12 island. It was 13 Q. Do you remember testifying 14 about someone named 15 A. was my friend in New 16 York. 17 Q. Is that the same person you 18 were writing here, or is that a 19 different person? 20 A. It's the same person; it's 21 just I called her It's a 22 name. She's 23 Q. How did you know 24 A. I met her in New York. 25 Q. Do you know whether you paid Page 395 1 HIGHLY CONFIDENTIAL AEO 2 for your plane ticket to come back to 3 New York from South Africa in February 4 of '07? 5 A. I didn't pay for my ticket. 6 Q. You did not? 7 A. No. 8 Q. Do you see in your email 9 exchange in Defendant's Exhibit 13 10 that you wrote to on February 8th 11 of '07, "Not going to Miami anymore, 12 clearly, and have to pay for me flight 13 back." 14 It's in the second paragraph 15 towards the bottom. 16 A. Mm-hmm. 17 Q. Did you write that? 18 A. Yes. 19 Q. But you did not, in fact, 20 pay for your flight back? 21 A. No. 22 Q. Do you know what you meant 23 by "Not going to Miami anymore, 24 clearly..."? 25 A. I can't remember what that Page 396 1 HIGHLY CONFIDENTIAL AEO 2 whole Miami thing was about. It never 3 came about, so I can't remember the 4 specific details on Miami. But it was 5 via Jeffrey Epstein. 6 Q. Okay. How did it happen 7 that you were writing, "I'm going to 8 have to pay for me flight back," but 9 you did not, in fact, pay for your 10 flight back? 11 A. Because Jeffrey Epstein and 12 I had a fight about my weight. So 13 that was probably during the argument, 14 the time frame that I had the argument 15 with Jeffrey. He said that he refused 16 to pay for my flight back if I didn't 17 get down to 52 kilograms. 18 Q. And how did it come about 19 that you did not pay for your flight 20 back? 21 A. I carried on losing weight 22 to try and get to the goal that 23 Jeffrey and Ghislaine had set for me, 24 which is 52 kilograms. 25 Q. How does that relate to Page 397 1 HIGHLY CONFIDENTIAL AEO 2 payment for a flight? 3 MR. GUIRGUIS: Objection. 4 A. Well, I didn't pay for that 5 flight because Jeffrey was financing 6 me, so I wouldn't have had the money 7 to pay for my own flight back. 8 Q. But you said you were "going 9 to have to pay for my flight back," 10 right? 11 A. That's correct. 12 Q. And then what changed? 13 MR. GUIRGUIS: Objection, 14 asked and answered. 15 A. I made up with Jeffrey. I 16 tried to meet my target weight of 17 52 kilograms. 18 Q. And how did you make up with 19 him? 20 A. I can't remember if it was 21 telephone call or email or message, 22 but there were various phone calls 23 that were made to my family home from 24 Ghislaine and Jeffrey during that time 25 frame. Page 398 1 HIGHLY CONFIDENTIAL AEO 2 It was a very delicate time 3 because my family were up in arms the 4 fact I was told to be 52 kilograms, 5 which is not -- it can't be achievable 6 with my body frame, and they saw me 7 getting very ill. 8 And I didn't have the funds 9 to buy a flight back, so I had to do 10 what Ghislaine and Jeffrey told me do. 11 Q. What did you do? 12 A. Continue to lose weight. 13 Q. Did you see any medical 14 professionals while you were in South 15 Africa? 16 A. No. 17 Q. How did you communicate to 18 Jeffrey that you had decided to 19 continue losing weight? 20 A. So Jeffrey, Ghislaine, 21 again, we all corresponded by 22 telephonic call, BBM, message, my 23 house phone. I decided to lose 24 weight. I was given an ultimatum that 25 either I do it or I'm finished. At Page 399 1 HIGHLY CONFIDENTIAL AEO 2 that point I had no option. 3 Q. If you wanted the flight 4 back. 5 A. If I wanted the flight back. 6 I had all my stuff in New York, I had 7 my life in New York, I was going to 8 FIT. 9 I didn't have any finances; 10 Jeffrey was funding me. So I was 11 stuck. I either had to do what 12 Ghislaine and Jeffrey told me do or I 13 was stuck, really. 14 Q. You were stuck at your 15 father and stepmother's house in South 16 Africa, where you grew up? 17 A. I didn't grow up with my 18 father and my stepmother. 19 Q. You grew up in South Africa? 20 A. I grew up in Johannesburg. 21 Q. When you say you were stuck, 22 you're describing a time you were in 23 South Africa? 24 A. I'm describing a time I was 25 on holiday visiting my family, that Page 400 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey paid for. 3 Q. Okay. Did you finish your 4 answer? 5 A. Sorry, I just read here. 6 I'm describing a time that I was on 7 holiday visiting my family, that was 8 paid for by Jeffrey and Ghislaine. 9 They financed my ticket. They 10 financed every ticket. They financed 11 my whole lifestyle. 12 Q. Ghislaine financed your 13 ticket? 14 A. Well, they were one entity. 15 Ghislaine is Jeffrey's right-hand 16 woman. They -- 17 Q. When did Ghislaine finance 18 this ticket? 19 A. It was through Jeffrey's 20 company that she worked with. 21 Q. Did you correspond by email 22 with Ghislaine about financing this 23 ticket? 24 A. No. 25 Q. You searched for emails with Page 401 1 HIGHLY CONFIDENTIAL AEO 2 yourself and Ghislaine, correct? 3 A. That's correct. 4 Q. And you found none, correct? 5 A. That's correct. 6 Q. You found emails between 7 yourself and about the 8 plane ticket back, correct? 9 A. That's correct. 10 Q. But none with Ghislaine? 11 A. I never said once today that 12 I had email communication with 13 Ghislaine. 14 Q. But you just said that 15 Ghislaine financed your holiday in 16 South Africa. And what is your basis 17 for saying that? 18 MR. GUIRGUIS: Objection. 19 She did not say that Ghislaine 20 financed it. 21 Q. What is your basis for 22 referring to Ghislaine financing your 23 holiday in South Africa? 24 MR. GUIRGUIS: Objection. 25 A. So Ghislaine is Jeffrey's Page 402 1 HIGHLY CONFIDENTIAL AEO 2 right-hand man, so she -- so we report 3 to her. I told them I wanted to go 4 and see my family. They paid for my 5 flight. 6 Q. You told them when they were 7 together in the same place? 8 A. I can't remember the 9 specific location. I just wanted to 10 go on holiday to see my family, which 11 Ghislaine and Jeffrey paid for. 12 Q. How did Ghislaine pay for 13 it? 14 A. I don't know. You should 15 ask Ghislaine. 16 Q. Did she write a check? 17 A. You should ask Ghislaine. 18 Q. Did she put it on a credit 19 card? 20 MR. GUIRGUIS: Objection. 21 A. You should ask Ghislaine. 22 Q. Do you have any idea how 23 Ghislaine Maxwell paid for your trip 24 to South Africa? 25 MR. GUIRGUIS: Objection. Page 403 1 HIGHLY CONFIDENTIAL AEO 2 A. You should ask Ghislaine. 3 Q. Is that an answer? 4 MR. GUIRGUIS: Objection. 5 Q. Do you have an answer? 6 MR. GUIRGUIS: Objection. 7 A. You should ask Ghislaine how 8 she funded my ticket. 9 Q. I appreciate the tip. 10 Do you have any information 11 inside of your head about how 12 Ghislaine financed your trip to South 13 Africa? 14 MR. GUIRGUIS: Counsel, she 15 has repeatedly stated that she 16 does not know. You keep asking 17 her the same question. 18 MS. MENNINGER: No, she has 19 repeated to he me that she 20 needed -- I needed to ask my 21 client. 22 MR. GUIRGUIS: Hold on. 23 "QUESTION: Ghislaine funded 24 your ticket? 25 "ANSWER: Well, she was his Page 404 1 HIGHLY CONFIDENTIAL AEO 2 right-hand... 3 "QUESTION: When did 4 Ghislaine finance this ticket? 5 "ANSWER: Well, it was 6 through Jeffrey's company that 7 she worked with." 8 Are you asking a different 9 question, Counsel? Am I 10 misunderstanding? 11 MS. MENNINGER: Yeah, you 12 are. 13 MR. GUIRGUIS: Please 14 MS. MENNINGER: Can you read 15 the question that I asked. 16 (Requested portion of the 17 record was read back.) 18 A. In my head, I can't remember 19 how she financed, how she and Jeffrey 20 financed. 21 Q. Did you see any invoice paid 22 by Ghislaine for your ticket? 23 A. No. But a ticket was 24 produced which enabled me to fly back 25 to my family, so a ticket was produced Page 405 1 HIGHLY CONFIDENTIAL AEO 2 by Ghislaine and Jeffrey in order for 3 me to fly home to see my family. 4 Q. How did Ghislaine produce a 5 ticket to you? 6 A. I can't remember. 7 Q. Did it come by email? 8 MR. GUIRGUIS: Objection. 9 A. I've provided all the emails 10 that I have. 11 Q. That's not the question. 12 Did the ticket get produced 13 to you by Ghislaine by email? 14 MR. GUIRGUIS: Objection. 15 A. No. 16 Q. Did it get sent by a courier 17 to you from Ghislaine? 18 MR. GUIRGUIS: Objection. 19 A. I can't remember how I 20 received the ticket specifically. 21 Q. Your final line to is, 22 "You must save some partying energy 23 for me when I come back. Lots of 24 love, Sarah." 25 Correct? Page 406 1 HIGHLY CONFIDENTIAL AEO 2 A. Mm-hmm. 3 Q. Is that right? 4 A. Mm-hmm. 5 Q. In the first paragraph, do 6 you advise Sarah, "Still very loved 7 up, so much so that he asked me to 8 move in with him and I accepted. All 9 good," exclamation point, exclamation 10 point, exclamation point -- well, 11 about eight of them, or ten. 12 A. Mm-hmm. 13 Q. Is that what you wrote? 14 A. Yes, that's what you wrote. 15 Q. Is that true? 16 A. Yes. 17 Q. Looking back at Defendant's 18 Exhibit 8, which you testified earlier 19 were your communications with 20 or some of them -- 21 A. That's Exhibit 9. 22 MR. GUIRGUIS: We seem to be 23 missing Exhibit 8 from the stack. 24 MS. MENNINGER: I checked it 25 during the break. Page 407 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: It's just out 3 of order. 4 THE WITNESS: Is this 5 Defendant's Exhibit 8? 6 MS. MENNINGER: Eight. 7 THE WITNESS: Is this 8 Exhibit 8? 9 MR. GUIRGUIS: Yes, it is. 10 Q. So the emails with 11 Maybe I wrote it down wrong. I 12 apologize. 13 MR. GUIRGUIS: With who? 14 I'm sorry? 15 MS. MENNINGER: 16 THE WITNESS: That was 17 Exhibit -- II, gosh. This is 18 Exhibit 9 between and 19 myself. 20 Q. Okay. And it's got 21 0004 and 0005; is that right? Just 22 making sure we're looking at the same 23 thing. On the lower right-hand 24 corner. 25 A. Yes, 000004. Page 408 1 HIGHLY CONFIDENTIAL AEO 2 Q. All right. Those are emails 3 that you and exchanged in 4 February of 2007, correct? 5 A. That's correct. 6 Q. And can you read to us the 7 email at the bottom from you to 8 on February 8, 2007. 9 A. "Hey sweetie, how are you? 10 I'm busy writing my essay for FIT. 11 What fun. I had a bit of a fight with 12 Jeffrey. II, well, what can you do. 13 I meant to ask in my last email can 14 you please email me your address. It 15 looks like I'm not going to Miami 16 either. Well, at least I will be back 17 in NY. Hope you are well and look 18 forward to seeing you soon. Please 19 tell I say hi. Lots of hugs 20 and kisses, Sarah." 21 Q. Were you writing your FIT 22 essay in February 2007 while you were 23 in South Africa? 24 A. Yeah. It took me quite some 25 time writing my essay, so it was over Page 409 1 HIGHLY CONFIDENTIAL AEO 2 a duration of... 3 Q. Did you email your essay 4 from South Africa to Ghislaine 5 Maxwell? 6 A. I don't recall emailing her. 7 Q. Defendant's Exhibit 10, I 8 think it is, with 9 A. Yes. 10 MR. GUIRGUIS: Hold on a 11 second. Let me just find my 12 copy. 13 Q. And I show 006 is 14 the first one in the lower right-hand 15 corner. 16 A. Yes. 17 Q. So did you correspond with 18 about faxing your FIT 19 application in to her on or about 20 February 8, 2007? 21 A. Yes. 22 Q. Did you also ask her to look 23 into booking a flight for you back to 24 New York? 25 A. That's correct. Page 410 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you give her the date 3 you wanted to fly back? 4 A. That's correct. 5 Q. And the next email down, did 6 you say, "Hi, can you please phone 7 back?" 8 A. Mm-hmm. 9 Q. Was that to or to 10 Jeffrey? 11 A. I can't remember who it was 12 to. Jeffrey never corresponded 13 directly; he either did it through 14 or -- so I can't remember 15 who phoned me back. 16 Q. Can you turn two pages back 17 to where it says 18 Do you see those emails? 19 A. Mm-hmm. 20 MR. GUIRGUIS: Read the 21 emails, don't just... 22 Q. Did ask what type of 23 visa you were coming on, student or 24 tourist? 25 MR. GUIRGUIS: Hold on, Page 411 1 HIGHLY CONFIDENTIAL AEO 2 Counsel. 3 Are you through with it? 4 THE WITNESS: Sorry, I 5 haven't finished reading yet. 6 Q. Did ask what type of 7 visa you were coming on, student or 8 tourist? 9 A. That's correct. 10 Q. And what was your response? 11 A. I can't remember what my 12 response was. 13 Q. Is it visible in this 14 exhibit? 15 A. No. 16 Q. All right. You said you 17 left New York in late April -- 18 A. That's correct. 19 Q. -- 2007? 20 Did you find any records 21 reflecting that departure when you 22 were going through all of your emails 23 and your other documents? 24 A. No. 25 Q. When was the last time you Page 412 1 HIGHLY CONFIDENTIAL AEO 2 saw Jeffrey Epstein? 3 A. April 2007. 4 Q. Where did you see him last? 5 A. In New York. 6 Q. Where in New York? 7 A. I can't remember where I 8 last saw him. 9 Q. Do you remember what 10 happened the last time you saw him? 11 A. No, I can't remember what 12 happened. 13 Q. Do you know whether he gave 14 you any money the last time you saw 15 him? 16 A. No, he didn't give me money. 17 Q. Do you know if you talked 18 about FIT the last time you saw him? 19 A. I didn't really want 20 anything do with Jeffrey and Ghislaine 21 at that stage. So at that point I did 22 not talk about FIT anymore with them. 23 I just wanted to go back home to my 24 mom. 25 Q. And this is when you were Page 413 1 HIGHLY CONFIDENTIAL AEO 2 living with 3 A. Yes. 4 Q. When did you decide you 5 didn't want to have anything to do 6 with Jeffrey Epstein? 7 A. After my trip to South 8 Africa, my relationship deteriorated 9 with Jeffrey and Ghislaine. So I 10 didn't really want to be here anymore. 11 Q. When did you make that 12 decision? 13 A. I was kind of toying with 14 the idea of going back. I was in a 15 bit of a mess after what I had been 16 through with Ghislaine and Jeffrey, 17 so -- yeah. 18 Q. And who purchased your plane 19 ticket to London? 20 A. I think it was my mom. I 21 can't remember. 22 Q. Were you still taking the 23 medications at the time you went back? 24 A. Yes. 25 Q. And you returned from South Page 414 1 HIGHLY CONFIDENTIAL AEO 2 Africa in February 2007, correct? 3 A. That's correct. 4 Q. And that's when you made the 5 decision to break with Jeffrey by 6 moving in with correct? 7 A. I wanted to distance myself 8 from Jeffrey. Things weren't great. 9 What he was doing was wrong and what 10 he was doing to me was wrong, and I 11 got pretty depressed about it. I was 12 in -- I was stuck in a dark hallway. 13 I was basically being abused by a man, 14 and I -- I didn't -- I didn't know 15 what to do, where to go. 16 Q. Did you have a bank account 17 in New York? 18 A. Yes, I did. 19 Q. With which bank? 20 MR. GUIRGUIS: Objection. 21 Same objection I gave at the 22 beginning, financial information 23 for a nonparty witness. 24 MS. MENNINGER: The name of 25 the bank. The name of the bank. Page 415 1 HIGHLY CONFIDENTIAL AEO 2 Q. Let me ask you this: What 3 did you do with the cash you received 4 from Jeffrey Epstein? Did you put it 5 in the bank? 6 A. No. I spent it on food, 7 cabs. General expenses. 8 Q. Where did you get the money 9 that you put into the bank? 10 A. From the occasional modeling 11 job that I got, freelance modeling. 12 Q. Were you still modeling in 13 the spring of 2007? 14 A. No. 15 MR. GUIRGUIS: Off the 16 record. 17 (An off-the-record 18 discussion was held.) 19 MR. GUIRGUIS: Back on the 20 record. 21 MS. MENNINGER: I think if 22 you can just give my co-counsel 23 and I a minute off the record. 24 (Time noted: 6:28 p.m.) 25 (Recess.) Page 416 1 HIGHLY CONFIDENTIAL AEO 2 (Time noted: 6:29 p.m.) 3 Q. In February of 2007, you 4 decided to make a break with Jeffrey 5 Epstein, correct? 6 A. No, I didn't decide to make 7 a break with Jeffrey Epstein. He let 8 me down with my FIT application and he 9 wasn't taking me seriously, and he 10 wasn't following through his end of 11 the deal, basically. 12 Q. How did he let you down with 13 your FIT application? 14 A. Because I didn't go to FIT. 15 Q. And why didn't you go to 16 FIT? 17 A. Because I wanted to go home 18 back to my mom. 19 Q. When did you decide that he 20 let you down with the FIT application? 21 A. Well, I think it was pretty 22 much after that incident with Alan and 23 the fact that I had been sexually 24 abused for months on end by Jeffrey, I 25 kind of wanted to call it time with Page 417 1 HIGHLY CONFIDENTIAL AEO 2 him. 3 I saw how he was acting with 4 the other girls. I saw how they got 5 pretty mentally messed up as well; for 6 example, So... 7 Q. And you saw that before you 8 went to South Africa? 9 A. Yes. 10 Q. And while you were in South 11 Africa, you got in a fight with 12 Jeffrey. 13 A. That's correct. 14 Q. And you didn't want to lose 15 this weight, correct? 16 A. I didn't want to lose this 17 weight because I would be dead if I 18 weighed 52 kilograms. 19 Q. You didn't want to lose the 20 weight in South Africa, correct? 21 A. I wanted to -- I was 22 desperate to go to FIT. I tried to 23 lose as much weight as I could for 24 Jeffrey and Ghislaine. 25 Q. While you were in South Page 418 1 HIGHLY CONFIDENTIAL AEO 2 Africa, you did some reevaluating of 3 your life? 4 MR. GUIRGUIS: Objection. 5 A. Reevaluating of my life? I 6 wouldn't say I spent the holiday 7 reevaluating my life, no. 8 Q. Were you happy when you were 9 in South Africa? 10 A. I was concerned because I 11 was being asked and being hounded to 12 find a 18-year-old PA for Jeffrey, and 13 I knew that was wrong because he would 14 do exactly the same thing to that girl 15 that he did to me, and I would not let 16 him do that to another girl. 17 Q. So when you were in South 18 Africa, you decided to make a break 19 from Jeffrey. 20 MR. GUIRGUIS: Objection. 21 A. I didn't decide to make a 22 break; I decided to distance myself 23 from Jeffrey. Not make a break, but 24 to distance myself. 25 Q. When you came back, you Page 419 1 HIGHLY CONFIDENTIAL AEO 2 moved in with 3 A. That's correct. 4 Q. You can't remember the last 5 time that you saw Jeffrey? 6 MR. GUIRGUIS: Objection. 7 That's not the testimony. 8 A. No. 9 MS. MENNINGER: No further 10 questions. Thank you. 11 THE WITNESS: Thank you. 12 MS. MENNINGER: Do you have 13 any? 14 MR. GUIRGUIS: Give me one 15 second to confer. 16 We have no questions. 17 MS. MENNINGER: Counsel, 18 we're going to, unfortunately, 19 before we go off the record, need 20 to leave the deposition open, 21 just because there are some email 22 documents that were referenced 23 but not produced. And we can 24 follow up and have a discussion 25 with counsel about that. Page 420 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Okay. So on 3 the record -- we can carry on the 4 conversation, certainly, off the 5 record. 6 But while we're on the 7 record, I will say that my 8 understanding is that those 9 documents were all produced to 10 you, including all the emails 11 that you asked her about, and 12 where are the missing emails, and 13 she kept saying they'd been 14 produced to her attorneys. My 15 understanding is that the 16 attorneys did provide them to 17 defense counsel. 18 MS. MENNINGER: Well, 19 there's a current passport that 20 we know was not produced, there 21 is an FIT application that we 22 know was not produced, and I 23 believe there are emails that 24 were not produced. 25 And I'm happy to have the Page 421 1 HIGHLY CONFIDENTIAL AEO 2 conversation continue off the 3 record, but I'm telling you those 4 are some of my recollections. 5 MR. GUIRGUIS: Okay. And to 6 be clear so that I'm not 7 misrepresenting, I see that I 8 said there were documents and the 9 emails. I meant to clarify, as 10 in the emails I know were 11 produced. 12 I can't speak to any other 13 documents that you might want to 14 raise a dispute about. But with 15 respect to the emails that you 16 said, my understanding, at least 17 as I sit here, is that they were 18 produced. 19 That said, I think we can go 20 off the record and resolve any 21 other issues between counsel and 22 23 (Time noted: 6:34 p.m.) 24 25 Page 422 HIGHLY CONFIDENTIAL AEO Signed and subscribed to before me, this day of 2017. Notary Public Page 423 2 CERT I F I CATE 3 STATE OF NEW YORK ) 4 COUNTY OF NEW YORK) 5 6 I, Jeremy Richman, a Notary Public 7 within and for the State of New York, do hereby 8 certify: 9 THAT, the witness 10 whose deposition is hereinbefore set forth, was 11 duly sworn by me and that such deposition is a 12 true record of the testimony given by such 13 witness. 14 I further certify that I am not 15 related to any of the parties to this action by 16 blood or marriage; and that I am in no way 17 interested in the outcome of this matter. 18 IN WITNESS WHEREOF, I have hereunto 19 set my hand 19th day of February 2017. ![](_page_423_Picture_19.jpeg) 21 22 r -------- Jeremy Richman 23 24 25 Page 424 1 #### 2 INDEX #### 3 EXAMINATION BY 4 MS. MENNINGER 7 5 P.M. Session 199 6 #### 7 EXHIBITS MARKED 8 (Defendant's Exhibit 1, hand-drawn 128 9 picture marked for identification.) 10 (Defendant's Exhibit 2, hand-drawn 149 11 picture, was marked for 12 identification.) 13 (Defendant's Exhibit 3, affidavit, 262 14 was marked for identification.) 15 (Defendant's Exhibit 4, 274 16 , was marked for 17 identification.) 18 (Defendant's Exhibit 5, jury trial 323 19 demand, was marked for 20 identification.) 21 (Defendant's Exhibit 6, 33 22 stamped was marked 23 for identification.) 24 (Defendant's Exhibit 7, 339 25 stamped was marked Page 425 1 for identification.) 2 (Defendant's Exhibit 8, Notice of 36 - 3 Service of Rule 45 Subpoena and 4 Notice of Deposition of, was marked for 6 identification.) 7 (Defendant's Exhibit 8, 8 stamped, was marked 9 for identification.) 10 (Defendant's Exhibit 10, 384 11 stamped, was marked 12 for identification.) 13 (Defendant's Exhibit 11, Maureen 386 14 Callahan article, was marked for 15 identification.) 16 (Defendant's Exhibit 12, website 389 17 printout titled How to Apply, was 18 marked for identification.) 19 (Defendant's Exhibit 13, 393 20 stamped was marked 21 for identification.) 22 #### 23 QUESTIONS INSTRUCTED NOT TO ANSWER 24 do you have any source of income? 10 25 so I'm going to ask you a last 12 Page 426 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 time: Do you have any source of income? what is your partner's occupation? 13 and where do your parents live? 14 , there was a question 15 pending when you took a break with your lawyers. Can you please answer the question. what is your partner's cell phone 28 number? and you're staying where while you're here? have you been promised that you 34 would have counsel to help you bring a lawsuit against a number of people? what's the private legal matter? 172 what did you talk about with Alan 184 Dershowitz? did you sign a common interest 185 agreement with Jeffrey? did he do anything in terms of 199 contacting anyone on your behalf? what was the specific legal matter 199 that you were seeking 1 representation for? Page 427 2 who prescribed it to you? 204 3 so please tell me how to reach your 241 4 stepmother, 5 when did you see that? 284 6 when did you provide them to your 363 7 counsel? 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ![](_page_429_Picture_5.jpeg) ![](_page_430_Picture_3.jpeg) ![](_page_431_Picture_3.jpeg) ![](_page_432_Picture_5.jpeg) ![](_page_433_Picture_3.jpeg) ![](_page_434_Picture_3.jpeg) ![](_page_435_Picture_5.jpeg) ![](_page_436_Picture_5.jpeg) ![](_page_437_Picture_6.jpeg) ![](_page_438_Picture_3.jpeg) ![](_page_439_Picture_6.jpeg) |
 

Alliance of Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of States of the United States

Confederation of States of the United States
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Confederation of Stat

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北京市

| | | | | | | --------------------------------- | ------ | ------ | ------ | ------ | ------ | | | | | | | | | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | | | | | | | | | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | | | | | | | | | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | | | | | | | | | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | | | | | | | | | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | | | | | | | | | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | 北京市 | | | | | | | | ![](_page_446_Picture_5.jpeg) |

Ward County

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