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I.
Deposition of a
During her sworn deposition in her civil case against, Jeffrey Epstein, M.
admitted that she never traveled any place with Jeffrey Epstein and never
communicated with Jeffrey Epstein by computer.
Q:
Did you ever travel anyplace with Jeffrey Epstein?
A:
Nope
* **
Q:
Did you ever communicate with Jeffrey Epstein on the computer?
A:
No not that I recall.
(MM
By the admissions in her sworn testimony it is clear that M. was not
persuaded by Jeffrey Epstein by Internet or telephone to engage in unlawful sexual
activity with Jeffrey Epstein.
M. was first brought to Jeffrey Epstein by
who M. met
in person. M. had no contact with Jeffrey Epstein prior to being brought to Jeffrey
Epstein's house by
.
A:
She brought me to Jeffrey's the first time.
Q:
How did you know this person?
A:
I was at a house and I am not exaeSvas at one of my friend's house. And
I spent the night over there. And I guess
was one of my friend's friend. And
she asked me if l wanted to make $200. And at first I was very, very skeptical about
it because of the wa she ex lained it to me. But then she convinced me into it.
Q:
So it was this person named
that you say convinced you to go to
Jeffrey Epstein the first time, is that - do I have your testimony correct on that?
A:
Yes, you do.
Q:
Jeffrey Epstein had no contact with you until M,
whatever her last name
is, brought you to his house; is that correct?
A:
That's correct.
continued to take M. to Jeffrey Epstein's house for about a month's
time. After that M. obtained Mr. Epstein's telephone number and called herself to
make appointments.
A:
After a couple of months, we hung out and that's when I got Jeffrey's number.
And I didn't, I did not no longer need her to take me to Jeffrey's. So we hung out a
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couple of times. We would talk about Jeffrey and how much money we were making
from Jeffrey and that's that.
Q:
What do you mean you no longer needed her to get to Jeffrey's?
A:
I had Jeffrey's phone number, so I could call him, so he could send a taxi over,
or he could send somebody from house to come pick me up to go to Jeffrey's. I
didn't need her or one of her friends to drive me to eff, to Jeffrey's anymore. * * *
Q:
And this occurred when, that is, that
never - stopped taking you
there and you began to go over there on your own?
A:
Within a month.
Q:
During this period of time that you were going to see Mr. Epstein. Sometimes
you called and asked his people at his house whether, you know, you could come
work, did you not?
A:
Yeah because he told me to call if I had a girl. So, I would call and ask if he
was available.
As is confirmed by •'s deposition testimony (excerpted below) in none of
the telephone calls was sexual conduct specifically discussed. Nor, given
history could it be reasonably argued that the telephone was used to persuade
to engage in any sexual conduct
also testified under oath that she and her friend, M., worked as topless
dancers at a strip club when
was fourteen or fifteen years old:
Q:
Okay, when you tart
.] was 14, at what club was she dancing?
A:
We both went to
A:
When we were, when we were 14, we went there like once or twice.
Q:
So, you went in there at age 14 with her? Were you 14 at the time?
A:
Yes. She might have been 15. I was maybe just turned 15.
Q:
What did you do [at
A:
I was an entertainer. We went there two times and -
Q:
Did you work there both times?
A:
Yes.
Q:
And then when you say you were entertainment, what did you do?
A:
I was a dancer.
Q:
Meaning you got up on stage, right?
A:
Yes.
Q:
Took your top off, right?
A:
Yes.
Q:
Did you do lap dances?
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A:
Q:
A:
(see
Not at this particular club.
You have done them at other clubs?
Yes.
M. also testified that she " robably" told Epstein that she was going to that
strip club. (see
), providing corroboration for claims that
Jeffrey believed she was of age.
M. also admitted that she was a call girl/escort since at least the age of 15
(though remarks she made to Epstein, as witnessed by
- See below
- confirm that M. was engaged in prostitution before she met Epstein
testified at her deposition: "Well, I lived life as a prostitute" see
),
"1 am a prostitute when I make money" (see
),
and "I was a call irl and I worked for myself.... From the age of 15 to the age of 21"
(see
a.
In fact,
admitted to making $1,000 a day or
more from prostitution on "maybe" more than 20 occasions in one year alone:
Q:
You earlier said that in the year 2008, some days you made a
thousand dollars a day, some days you made $2,000 a day. How many days
out of the year would you say you made a thousand dollars a day or more a
day in the year 2008?
A:
I don't know.
.
•
Q:
Was it more than ten?
A:
Maybe.
Q:
Was it more than 20?
A: itrbe.
i
(see
also admitted under oath to keeping a list of amounts she collected from her
johns in "two or three" lined books that she kept for the years "06, 07, 08 and 09"
(see
includingi al
.
of "Psalms" that she obtained
from a religious store (see
M. attempted to lay blame on
other things, her life as a prostitute.
sworn deposition testimony from
M. to Epstein's home, indicates that
Epstein. In her dsaosition,
Epstein's home, M. quoted to Epstein
sexual favors that they perform.
rm
about some stuff that her mom and her
that" (see
of
information" to Epstein:
E stein during her
I•c
tion for, among
. However,
, the person who first brought
was a prostitute before she ever met
testified that on C's second visit to
rites of M. and
's mother for various
testified that
was "telling [Epstein]
did sexually for mone. some stuff like
and that
was "offering
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A:
That her and her mom have had, her mom does things and has prices
for things. Something of that matter...
Q:
Sexual nature?
A:
Yeah.
(see
of
Moreover, although M. claimed in her deposition that Jeffrey knew how old
she was, M. also admitted about lying about her age to everyone she came across,
including the strip clubs and prostitution businesses at which she worked beginning
at age 14 and 15.
Q:
Earlier you said you worked for
A:
Yes.
** *
A:
I told them I was 19.
Q:
Okay. Did you provide them with any kind of proof?
A:
No.
Q:
And why did you lie to them and tell them you were 19 if you were really 15?
A:
Because I wouldn't be able to work there.
Q:
Did you tell other people that you were older than you really were?
A:
Yes.
Q:
Who else did you tell that you were older than you really were?
A:
Probably everybody I came across.
Q:
So, that would be many people.
A:
Yes.
Q:
All of the various adult entertainment places you worked at. The places, the
topless bars you worked at, did you tell all of them you were older than you really
were?
A:
The period of time when I worked at
I told everyone I
was 19.
(See
[Note, however, that immediately after
gave that answer in her testimony
she added (I presume to protect against these admissions) that "Jeffrey knew
how old I was. And Jeffrey knew hold old every girl I brought there was, and
he wanted young girls all the time."]
Q:
Well
worked at a place called
when you were 14, didn't you?
A:
. I told them I was 19 as well.
Q:
When you were how old, 14?
A:
Yes.
(See
)
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11.
Deposition of
admited in her sworn deposition testimony that she never traveled with
Jeffrey Epstein and never exchanged emails or text messages with Mr. Epstein.
Q:
Did you ever travel at any time with Mr. Epstein?
A:
No.
Q:
Did you ever email him at any time?
A:
No.
***
Q:
... Would it be - it would be - did you ever have - exchange emails with Mr.
Epstein at any time?
A:
No.
Q:
A:
Q:
A:
No.
(See
Did you ever exchange text messages with Mr. Epstein at any time?
No.
Did you ever travel with Mr. Epstein in any fashion at any time?
M. confirmed in her deposition that she was not persuaded by Mr. Epstein
by telephone to en age in sexual activi •.
confirmed in her deposition that fl
first introduced M. to Mr.iutein. M. contacted Mr. Epstein by telephone to tell
him that she was bringing M. Mr. Epstein told M. that he would send a driver
and told M. where to meet the driver nothing else.
Q:
A:
Q:
A:
(See
Now, when you - when did you first go to Mr. Epstein's house?
I believe it was sometime in August 2002.
And iff took you?
Yes.
Q:
What - what occurred during the conversation? What specifically was said?
A:
That we were going to meet him - we were going to meet whoever his
drivers were at the shell gas station to pick us up.
Q:
Who initiated the call?
A:
She
she called him and told him that she had a girl to bring to him.
(See
As is true for n, N. also admitted in her deposition to having contacted
Jeffrey Epstein's home herself to ask to come to work for him.
Q:
Did you ever request or contact Mr. Epstein's home and ask to come over to
work?
A:
Yes
(See
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M. testified to speaking with
or Jeffrey Epstein on the
phone, but as to all of those conversations,
specifically testified that no specific
discussion regarding sexual activity ever took place over the telephone.
A:
So he would -
would ask me to call - see if I could come, and then I
would call him back directly, ask to talk to Jeffrey. Jeffrey wouldjat on the hone,
and I would confirm if I was coming or not. Yes, hi, Jeff, it's M.
7 No, M. Yeah, I'll be there at 3:00, I'll be there at 9:00p.m., I'll be there at
8:00, whenever the time was.
Q:
Is the extent of the conversations that you had with Mr. Epstein, at least
when you would call back to confirm, it was hi, this is M., I'll be there at X time
period?
A:
Pre
much.
(See
I
B
Whatever was said during M.'s telephone calls,
testified very clearly
that at no time was the subject of sexual activity with
or anyone else ever
discussed with M. by telephone.
1.
Would it be a correct statement that at no time did either Mr. Epstein or
or
ever say to you over the telephone, whether you called or
they called you, that the massage would involve any sexual touching or any other
form of sexual conduct?
* * *
A:
No the never' col
Sc;
that over the phone. It was always face to face.
(See
M. admitted that every occasion that she went to Mr. Epstein's home was a
"knowing and voluntary decision" See
118:5-19). M. admitted
that Mr. E stein never threatened
"No. He never said he was goin to hurt me"
alcohol or encouraged
use them. (See
. Mr. E stein never ave
. drugs or
).
- See
Evidence from •'s
testimony indicates that Mr. Epstein had every reason
to believe the M. was 18 years old.
admited that she talked to Mr. Epstein
about working at the Strip =
called
when she first started seein
Mr. Epstein impliedly confirming to him that she was 18
(See
223:17-224:1).
, which
had a tattoo on her ankle with one of her professional names
admits normally requires that a person be 18 to receive. (See
. Moreover, M. admitted to going to night clubs
from the time she was 14 years old and never ever being carded at the doors of the
night clubs, indicating that she did not look underage from the time that she was 14
years old. (See
I. In addition, M. was permitted to
work at strip clubs without showing ID when she was 14 ears old also indicating
that she appeared to be of age. (See
. Evidence that
M. lied about her age is found in
's sworn deposition testimony where she
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admits that she lied to the owner of
that she was 18, and lied on her
applications to work at
and
that she was 18.
(See
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