EFTA01735431

NOTES OF QUOTES AND STATEMENTS FROM DEPOSITION TRANSCRIPTS I. Deposition of. Althougi has sought in her civil case against Epstein to portray herself as an innocent, who was damaged by her interactions with Epstein, both her behavior and her own sworn statements during the course of her deposition in her civil case belie her claims. Repeatedly throughout the course of her deposition= engaged in the frequent use of profani and personal attacks on Epstein's counsel. For example, during her deposition made the following comments: A: You're an asshole. Q: You were a - A: You're a fucking asshole. (see Depo Transcript 130:10-19) A: You are just fucking sitting here making money. (see Depo Transcript 132:9-10) Q: Ok, you were partying, right? A: Yeah, like normal people do like you're going to probably do after this with all your fucking money. (see Depo Transcript 133:3-5) Q: ... Let's be honest. A: Okay. Let's be honest. Q: Did you ever send? A: Yeah jackass. You're a fucking asshole. (see Depo Transcript 225:19-23) In fact, use of profanity was so egregious and disruptive during her deposition that the court agreed to extend her deposition for six hours and ordered her attorney to caution against engaging in such further inappropriate behavior: But the witness should be warned that the Court will not tolerate any further vulgarities, any further accusations without merit relative to counsel, any further attacks on counsel, any references to counsel's children or anything of that nature. I will allow the deposition ... without interruptions of the same type that we witnessed by virtue of my reading of this transcript on several occasions now, to last another six hours, total. Period. EFTA_R1_00018824 EFTA01735431 I want to put on record that the vulgarities, the attacks on counsel, the attacks of a personal nature that were communicated b} vere such that, if they are repeated, that sanctions will be assessed, and those sanctions could include the striking of the pleadings. (see November 3. 2009 Hearing Transcript 9:20-10:23) In addition to her "vul ar" behavior durin her de • osition admitted durin the de • osition that admitted under oath tha Transcri t 109.17-18 She also admitted that she di Transcript 86:12-15) She testified that she started (see Depo Transcript 86:22-24) She admitted, however, that Epstein never provide' with any drugs or alcohol: -22). She see De • o see De o Q: Jeffrey Epstein never gave you any drugs did he? A: No. Q: He was an antidrug person, wasn't he? A: That's what he said. Q: And he made that pretty clear to you? A: Yes. Q: Never gave you alcohol, right? A: Never. Q: Told you he didn't believe in alcohol. Didn't drink it himself, right? A: True. Q: Always treated you well when you were at his house, didn't he? A: Of course. (see Depo Transcript 305:5-306:1) Q: A: ••• A: ••• Q: A: also testified under oath that she and her friend Okay, when you though at what We both went to When we were, when we were.we went there like once or twice. So, you went in there at agenvith her? Were you t the time? E Yes. She might have been I was maybe just turned EFTA_R1_00018825 EFTA01735432 Q: What did you do A: I was an • • • Q: And then when you say you were what did you do? A: Q: A: Yes. Q: A: Yes. Q: Did you do A: Q: A: Yes. (see Depo Transcript 299:2-300:21) also testified that she "probably" told Epstein that she worked at that (see Depo Transcript 300:3-4) also admitted that she was testified at her de osition 156:7), and "I was a (see Depo Transcript 280:16-19). In fact more from Q: Was it more than ten? A: Maybe. Q: Was it more than 20? A: Maybe. (see Depo Transcript 157:11-159:6). also admitted under oath t see De She (see Depo Transcript o Transcri t 156:12-13 , (see Depo Transcript 59:13-64:12), including a book of hat she obtained from a -tore (see Depo Transcript 152:1-14). EFTA_R1_00018826 EFTA01735433 p y_ other ngs II ttem ted to la blame on Epstein during her deposition for, among (see Depo Transcript 129:5-23). Yet= admitted that she never had sexual intercourse with Epstein and never touched Epstein's penis: Q: You never had sexual intercourse with Mr. Epstein, did you? A: Penis inserted into the vagina, no. Q: Did he ever insert his penis into your mouth? A: No. Q: Did he ever insert his penis into your anus? A: No. Q: Did he ever insert his penis into your vagina? A: No. Q: Did you ever hold his penis in your hand? A: No. (see Depo Transcript 71:15-72:9) Moreover, sworn deposition testimony from the person who first broughtetto Epstein's home, indicates tha before ■ ever me Epstein. In her de osition testified that on second visit to Epstein's home, that an was "telling [Epstein] about some stuff tha i or some stuff like that" (see Depo Transcript of C.M.A. 280:9-11) and that as "offering information" to Epstein: A: • f that matter... Q: A: Yeah. (see Depo Transcript of C.M.A. 276:16-277:11) II. Deposition of Another woman claiming in her civil case to have lost her innocence to Epstein is Yeta sworn deposition testimony in her civil case against Epstein paints quite a different picture. who during her deposition a eared at time testified under oath to For examp e: EFTA_R1_00018827 EFTA01735434 Q: A: Q: A: Q: A: es, ave Q: A: Yeah... (see Depo Transcript 87:11-88:8). admitted that she begs before she ever met Epstein (see Depo Transcript 274:11-13). In addition, she testified: Q: A: Q: A: (see Depo Transcript 274:14-19) She further admitted that she a so tests e that "I tol see Depo Transcript 271 Like- offered her drugs or alcohol: confirmed under oath that Epstein never gave or even Q; Mr. Epstein never gave you any drugs, did he? A: No. (see Depo Transcript 103:8-10) Q: He never told you to use drugs in his house, did he? A: No, he never told me to. Q: He never gave you alcohol in his house, did he? A: No. (see Depo Transcript 106:7-12) Q: He never attempted to drug you in any manner, did he? A: No. EFTA_R1_00018828 EFTA01735435 Q: Never even offered you drugs, correct? A: Correct (see Depo Transcript 131:13-17) In addition to he in her deposition that she had well before she ever met Epstein: Q: So, by, by your acknowledgement in these answers to interrogatories r- v rw n • Mr. E stein's house the first tim an A: And that's it Q: And A: No. Q: No A: Yes. (see Depo Transcript 258:6-16) Q: Okay. And when was the A: Q: A: (see Depo Transcript 161:18-22) Q: A: • • • Q: A: Q: A: Q: Was this before or after the point in time that you had your A: It was after. Well, it was before. I don't - It was like durin e of thin . EFTA_R1_00018829 EFTA01735436 : res. Q: A: Q: A: (see Depo Transcript 200:25-202:5) testified tha (see Depo Transcri t 204:10-11 . Q: When did you first meet A: When I was Q: Did you A: Yes. Q: A: Yes. Q: A: Yes. efore you first went to Mr. Epstein's? A: Q: And did you consider A: Q: during the entire period of time that you went to Mr. Epstein's A: Yeah. Q: And ever physically bring you to Mr. Epstein's house? A: Yes. Q: ... Ever any occasion whet brought any females that he dropped off at Mr. Epstein's other t tan - A: Yes, me an' and me and (see Depo Transcript 207:20-209:17) about having a For example: A: EFTA_R1_00018830 EFTA01735437 A: (see Depo Transcript 258:22-259:4) : For a roximately how long did the event take place that A: Q: A: (see Depo Transcript 260:24-261:4) Was there another occasion that tanta Q: A: Q: A: (see Depo Transcript 261:15-19) Yes. Q: And when did you tell Mr. Epstein about it? A: On one of the occasions I went to his house. Q: And what did he say? A: I don't know. He talked to me about it. Q: Was he sympathetic toward you? A: Q: A: Q: A: (see Depo Transcript 262:5-17) 4 " Despit meeting pstein an hat predated her interactions with Epstein laims injury by Epstein in her civil case. She makes these claims even though she made the following admissions in her deposition: Q: Did you ever have sexual intercourse with Mr. Epstein? EFTA_R1_00018831 EFTA01735438 A: No. (see Depo Transcript 106:13-15) Q: Did you ever touch Mr. Epstein's penis - A: No. Q: -- in any way? A: No, no. (see Depo Transcript 109:1-4) Q: All right. Would you, would you say that during the period from r. Epstein was good to you? A: Yes. (see Depo Transcript 127:23-128:1) Q: Did he ever, did he ever strike you ever, hit you? A: No. Q: Did he ever commit an act of domestic violence against you? A: No. (see Depo Transcript 129:2.10) Q: ... Did Mr. Epstein ever threaten you in any manner? A: No. (see Depo Transcript 131:2-4) In fact testified that she enjoyed going to Epstein's home: Q: Did you enjoy the occasions when you went to Mr. Epstein's? A: Yes. Like enjoyed collecting the money, yes. Q: Well, you enjoyed what you were doing, didn't you? You enjoyed spending time with him? A: Not exactly spending time with him. I enjoyed going to be able to collect that much money. (see Depo Transcript 141:10-16) enjoyed collecting the money so much that she, herself, initiated contact in order to schedule visits to collect that money: Q: Well, there were also occasions when no one from Mr. Epstein called, but rather you called Mr. Epstein's and asked to go? A: Yes. Q: And that was because you wanted to go and earn some money, correct? EFTA_R1_00018832 EFTA01735439 A: Yes. (see Depo Transcript 137:7-13) Nevertheless claimed in her deposition that specifically because of her interactions with Epstein: A: I have a very hard time working around older men or in specific situations. Q: What situations would those be? A: I don't trust anybody and I don't feel safe in some places. Q: Well, you say you don't trust anybody? A: Well, I don't trust men. Q: What—any kind of particular kind of men or just - A: Older men. Q: And what's your definition of "older"? A: Above 40. (See Depo Transcript 66:10-21) Yet, despite her claimed "trust" issues with men over 40 years old, admitted under oath at her deposition that, after she stopped seeing Epstein: A: I was working for an Q: And what was the name of that A: Q: That wou d • e two separate A: Yes. (see Depo Transcript 68:12-18) Q: And thereafter A: Yes. (See Depo Transcript 75:21-24). Incredulously Q: EFTA_R1_00018833 EFTA01735440 A: Yes. Q: A: Yes, that's true. (see Depo Transcript 67:15-20) and A: Yeah. (see Depo Transcript 82:12-16) III. Deposition o Althoug.also claimed in her civil case injury from her interactions with Epstein, her sworn deposition testimony clearly establishes that any injuries that been interacting with Epstein: Q: Now, read to the ladies and gentlemen of the jury what you wrote occurred on 2004 wit A: hone EFTA_R1_00018834 EFTA01735441 Q: A: (see epo ranscrip : - : oug era missions l uring e eposition indicate that it was earlier than that): : Now, it's a fact, is it not, that b the be 'nnin of ou b A: Yeah. (see Depo Transcript 180:7-11) A: Q: A: Q: (see Depo Transcript 181:21-182:2) Q: Are you - did you A: Yeah. (see Depo Transcript 183:19-21). was then Q: A: Q: hen you first started dating him, right? A: Yes, somewhere in that time - I'm pretty sure it's somewhere in that time frame. (see Depo Transcript 198:3-11) A: (see Depo Transcript 199:17-21) EFTA_R1_00018835 EFTA01735442 Q: A: Yeah. iaa A: (see Depo Transcript 202:10-22) Nevertheless A: I have made Q: A: Q: A: Q: A: Q: A: (see l epo Q: A: Q: A: Q: ... what did thi When you made the EFTA_R1_00018836 EFTA01735443 A: Yeah. A: Yeah. Q• A: Q: A: Q: A: Q: Tell the ladies and : entlemen, look in the camera and tell the ladies and entlemen of the jury A: (see Depo Transcript 361:20-368:8) Q: A: Q: A: EFTA_R1_00018837 EFTA01735444 Q: A: Q: A: (see Depo Transcript 324:24-325:10) Q: A: Q: A: Q: A: Q: A: One of those two. (see Depo Transcript 326:23-327:9) Q: A: Three. (see Depo Transcript 299:16-21) Q: A: Q: ... A: Q: A: (see epo ranscript Q: A: Q: A: (see epo ranscript Q: EFTA_R1_00018838 EFTA01735445 Q: Is that right? A: Yeah. (see Depo Transcript 426:9-16) A: Yeah, probably. (see Depo Transcript 213:11-25) Q: Okay. And it was - it was when you were 17, between the ages of 17 and 18? A: Uh-huh. (see Depo Transcript 25:17-26:1) Q: You had before you met Mr. Epstein, had you not? A: Yeah. (see Depo Transcript 221:3-5) I want to ask you again, did you ever do EFTA_R1_00018839 EFTA01735446 (see Depo Transcript 214:24-215:4) ttlir A: (see epo ranscrip Q: A: (see Depo Transcript 217:19-23) a s attempted to blame E stein for an in'uries she claims to have sustained durin the eriod tell [Epstein] your age" (see Depo ranscript : - . oreover Q: Didn't have any sexual relations with Mr. Epstein did you? A: No. (see Depo Transcript 180:12-14) Q: And by the way, did you - did you ever touch Mr. Epstein's penis? A: No. (see Depo Transcript 361:5-7) Q: A: Q: Did he ever physically hurt you in any manner whatsoever? No. Did he ever demean you in any manner whatsoever? A: No. (see Depo Transcript 169:16-25) Q: Mr. Epstein never gave you drugs, correct? A: No. (see Depo Transcript 221:12-14) l a An dmitted during her deposition: Q: Was Mr. Epstein good to you? A: Yeah. (see Depo Transcript 122:9-10) EFTA_R1_00018840 EFTA01735447 Q: And Mr. Epstein, as you said before lunch, was very nice towards you, was he not? A: Yeah. A: He was really nice, like friendly. (see Depo Transcript 168:9-20) In factindmitted that from the period of time after she was of legal age and legally deemed able to make her own decisions regarding her interactions with Epstein, she voluntarily saw Epstein as much as 50 times: : Can ou tell me how man times ou went to Mr. Epstein's between A: Well, approximately, approximately like 30 to 50 times. Q: Okay. You went voluntarily. Nobody forced you to go to Mr. Epstein's, correct? A: Yeah. (see Depo Transcript 77:17-79:4) MoreoveMdmitted under oath that when■ first learned of the claims against Epstein and before she filed her law suit against Epstein "was like defendin Mr. E stein" (see Depo Transcript 276:2), and thatMan er frien discussed and told others that such claims were outrageous: Q: Did you ever, at any point in your life right up until today tell anyone that you thought it was outrageous that anyone would file a lawsuit against Jeffrey Epstein because everybody knew what the deal was and knew what they were doing or words to that effect? A: Yeah, I said that tjra because I didn't even think I was doing anything wrong at the ti ... A: We, she said we both said to each other. We were just, like, I can't believe this is happening, like Jeffrey is such a great guy, like, you know, like, saying all this stuff about, about him... (see Depo Transcript 275:18-277:2) Q: All right. • ' • that you have made this statement to people other than between January of '06 and January of '09, that everybody tha wen o see e rey Epstein knew exactly what they were EFTA_R1_00018841 EFTA01735448 getting into, did it voluntarily, and it's outrageous that they would sue him? A: Yeah. Q: can assume and I'm sure your counsel will correct me if I'm wrong, but you didn't file this lawsuit until 2008. You had a lot of conversations with your friends that had gone to Jeffrey Epstein before you filed this lawsuit, didn't you? Now, I want to tell you that you filed your lawsuit in 2008. Okay. You A: Yeah. Q: And all those conversations were that everybody knew what they were getting into, and it was all done voluntarily, and at that time you-all thought it was crazy that anybody would sue Jeffrey Epstein, didn't you? A: Yeah. (see Depo Transcript 282:8-25) Finallyalso admitted that even after the police contacted her when she was in college and of legal age, but before she had retained legal counsel in her civil case, she "probably more than likely" would have continued to see Epstein. See Depo Transcript 393:10-16. claims against Epstein de& credibility. She was consistently evasive during her deposition. She admitted in her deposition to lying under oath and to 'on interviews with her own experts, includin about such things as see Depo Transcript 402:22-403:2) an see Depo Transcript 405:2-406:9). Most tellingl dmitted: Q: So, we don't really know, even when you're under oath, whether you're telling the truth or you're lying, do we? A: No. (see Deposition Transcript 401:7-10) In light of her admitted the entire period that she claims to ave een interacting with Epstein, her evasive responses to direct deposition questions, her admitted deceptions to her own experts, her revelation that her testimony cannot be relied upon, even under oath, her admissions regarding her positive personal feelings about Mr. Epstein and her • re-litigation characterization of the civil claims against Epstein as outrageous, civil claims of injury by Epstein do not withstand scrutiny. EFTA_R1_00018842 EFTA01735449