Page 1

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. RELATED CASES: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 DEPOSITION OF Tuesday, May 11, 2010 9:16 A.M. - 10:59 A.M. PROSE COURT REPORTING AGENCY, INC. 3111 West Dr. Martin Luther King, Jr. Boulevard Suite 100 Tampa, Florida 33607 REPORTED BY: MICHELLE OLSEN BADEN, RPR, FPR Notary Public, State of Florida at Large Prose Job No.: 1998 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden.M ) and0i404:4536-414d-8110443419Ciec569 EFTA00724274 EFTA00724275 Electronically signed by Michelle Baden Ma APPEARANCES: 2 BRAD EDWARDS, ESQUIRE 3 FARMER JAFFE WEISSINO EDWARDS FISTOS & LEHRMAN, P1. 4 425 North Andrews Avenue, Suite 2 also, Florida 33301 5 Attorney or Plaintiff in Related Case No0840893 (Appeared via telephone conference call) 31 12 13 14 15 16 17 18 19 20 21 22 23 24 25 STUART S. MERMEISTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, PA. 18205 Biscayne Boulevard, Saute 2218 a ila 33160 Attorney for Plaintiffs in related cases 08-80069, 08-80119, 08-80232, 08-80380, 0840381, 0840993, 0840994 (Appeared via telephone conference call) MICHAEL I. PIKE, ESQUIRE BURMAN CRITTON LUTHER & COLEMAN n Boulevard, Suite 400 Florida 33401 Attorney for Defendant, JEFFREY EPSTEIN (Appeared via telephone conference call) Page Page 4 1 The deposition of vas taken 2 pursuant to Subpoena by counsel for the Defendant on 3 Tuesday, May 11,2010, commencing at 9:16 A.M. at PROSE 4 COURT REPORTING AGENCY, INC., 3111 West Dr. Martin Luther King, Jr. Boulevard, Suite 100, Tampa, Florida 6 33607. Said deposition was reported by Michelle Olsen 7 Baden, RPR. Notary Public, State of Florida at Large. a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 WHEREUPON: THE REPORTER: Please raise your right hand Do you solemnly swear or affirm that the testimony you give today in this matter will be the truth, the whole truth and nothing but the truth? THE WITNESS: Yes. a witness, having been duly sworn to tell the truth, the whole truth and nothing but the truth, was examined and testified as follows: EXAMINATION BY MR. PIKE: Q Morning, Ms. My name is Michael Plke Can you hear me clearly? A Yes. Q fm taking your deposition today via telephone. Usually, when we have a telephone 1 2 3 Examination By Mr. Pike 4 Examination By Mr. Edwards. ..... .—....--.72 5 6 Certificate of Reporter.._......_ 77 7 Catificate of Oath. ...... ..... —...78 9 10 11 12 13 14 Page 3 INDEX . PAGE 15 16 17 18 19 20 21 22 23 24 25 EXHIBITS (No exhibits were market) 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 Page 5 deposition, its very easy for me to talk ova you and vice versa. So, during this telephone deposition, please allow me to finish my questions and I will allow you to finish your answers, that way you and I can hear each other clearly. If at any time you do not understand my question, please stop and ask me to repeat the question and I will do so, especially given the fact that we are on the telephone. Okay? A No problem. Q Okay. Would you please state your name for the record. A Q woo you please spell your last name. A Q Ms. A I live Q A Q Q Q where is your current residence? And how long have you lived in I moved right befo And what Is your date of . Wow old are you today? lam. What is your current telephone number, both 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY INC. IIIIIIIIIIIII 053d0950-b535-41401118-6434195ae559 EFTA00724276 Page 6 2 3 4 Q How long have you had that cellular telephone? 5 A As long as I have lived ha. 6 Q Cm sorry, what was the date that you 7 moved a, just the year? 8 A Roughly, September or — wait. October, rrn 9 sorry. 10 Q Of 2009 or 2008? 11 A 12 Q Where do you currently work? 13 A lam not working. 14 Q Where was ur last lace of em lo t? 15 A I worked s. 16 17 Q What of business is that? 18 A It tvas 19 Q Where that located? 20 A INIMMINIMMIIIMI 21 22 Q Is that also a 23 A Yes, sir. 24 QAnd before that where did you work, 25 Ms. ? home and cell phone? A IS have a cell, there is no home, and it Page 8 1 A Nowhere. That was m first lob — or no I'm 2 sorry. I worked 3 • • Q was your first place of 4 employment? S A Yes, sir. 6 Q I'm going to ask you whether or not you know 7 certain individuals, and I would just like you to answer 8 me yes, you know them or no, you do not know them. And 9 the ones that you do know we'll come back to later on, 10 after I finish figuring out who it is that you know and 11 who it is you don't know. Okay? 12 A Okay. 13 Q Do you blow a female by the name of 14 Jane Doe 2? 15 A No. 16 Q Do you 'mow a female by the name of 17 Jane Doe 3? 18 A No. 19 Q Do you know a female by the name of 20 Jane Doe 4? 21 A No. 22 Q Sometimes pronounced Jane Doe 4? 23 A No. 24 Q Do you know a female by the name of 25 Jane Doe 5? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 A I worked Q Where was tha A street, maybe Q And befo A I worked a Page 7 located? Not exactly sure of the , somewhere along there. where were ou employed? Q And before A I worked at Q And where is tha 'located, areet-wise? A It's right there on. and Q What was our osition at A I was Q Okay. How long did you work for A I would say a couple months. Q And before= in you work? A I worked at — I'm not sure of the name — I want to say Q How long did you work for the A I would say ma be a month month or two. Q And bef where did you work? where did Page 9 1 A No. 2 Q Do you know a female by the name of 3 Jane Doe 6? 4 A Yes. 5 Q Do you 'mow a female by the name of 6 Jane Doe 7? 7 A No. 8 Q Do you know a female by the name of 9 Jane Doe 8? 10 A No. 11 Q Do you know a female by the name of 12 A No. 13 Q Have you ever met El? 14 A No. Never heard the name. 15 ...Do youlmow a female by the name oil.. 16 17 A No. 18 Q Do you know a female by the name of= 19 A No. 20 Q Do you latow a female by the name of 21 Jane Doe II? 22 A No. 23 Q Do you blow a female by the name of Jane Doe? 24 A Yes. Q Do you know a female by the name ofMIT 1r 4. 3 (Pages 6 to 9) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden IIIMEIM) and09804538-04d-M18-643419bac559 EFTA00724277 Page 10 1 A Yes. 2 Q Do you know a female by the name oliM 3 A Yes. 4 Q Do you know a female by the name of Si 5 A Yes. 6 Q Do you know a female by the name SIM 7 A No. 8 Q Give me one second. Ms. how is it 9 that you know Jane Doe 6? 10 A She lives in the neighborhood I use to hang 11 out in. 12 Q And what nei borhood is that? 13 A 14 Q Would I that for the record. 15 A I believe. 16 Q How long have you known Jane Doe 6? 17 A I woWd say since I was 15. 18 Q Did you guys go to school together? 19 A No. 20 Q How did you meet her? 21 A She was just hanging out with friends, I 22 believe. Just everybody hanging out and we met. 23 Q Have you remained friends since the time you 24 first met her? 25 A Yes. 1 A No. 2 Q And when I ask that question I mean, from the 3 time that you have known her up until today's date, has 4 she ever mentioned to you the name Jeffrey Epstein? 5 A No. 6 MR. EDWARDS: I'm sorry is the "her" that 7 we're talking about Jane Doe 6 still? 8 MR. PIKE: Yes. 9 THE WITNESS: Yeah, no, I nova heard anything 10 about it. She's never mentioned that name. 11 BY MR. PIKE: 12 Q Did you ever come to team that Jane Doe 6 had 13 gone to Mr. Epstein's home for any reason? 14 A No. 15 Q Did Jane Doe 6 ever tell you that she went to 16 Mr. Epstein's home in Palm Beach to give Mr. Epstein a 17 massage? 18 A No. She said she went there, when I last 19 talked to her, but no details. 20 Q Did Jane Doe 6 ever tell you that Mr. Epstein 21 faced her to do anything against her will? 22 A No, sir. 23 MR. MERMELSTEIN: Object to form the question. 24 BY MR. PIKE: 25 Q And, Mr. there are two other lawyers Page Page 11 1 Q When was the last time you spoke to her? 2 A I spoke to her what is today, Tuesday. I 3 talked to her on Sunday. 4 Q When you spoke to her on Sunday did you speak 5 about this case? 6 A No. 7 Q Have you ever spoken to Jane Doe 6 about this 8 case? 9 A I never knew she had anything to do with this 10 until she told me the other day. 11 Q Would that be Sunday? 12 A No. We -- !just got back from 13 Q So when you were in you saw her face 14 to face? 15 A Yes. 16 Q And where did you guys meet in NEM 17 A I saw her at her house. I came to say hi. 18 Q What did you guys talk about relative to this 19 case? 20 A All I said was that I can't — not talking 21 to because I have to do a deposition and she just 22 said that she had something to do with it but that's — 23 she didn't go into detail. 24 Q Did she ever talk to you about a gentleman by .!5 the name ofJeffrey Epstein? Page 13 1 on the phone and they are going to be making legal 2 objections. Basically what that is is an attempt to 3 preserve the record. Those objections aren't directed 4 at you. Those objections are directed at my questions. 5 So when you do hear a lawyer make an objection. Please 6 hold off until we finish our dialogue and then I'll come 7 back to you and ask you to finish your answer. Okay? 8 A Okay. 9 Q Did Jane Doe 6 ever tell you that she 10 experienced any traumatic events at Jeffrey Epstein's 11 home? 12 MR. MERMELSTEIN: Objection to form. 13 THE WITNESS: No. 14 BY MR. PIKE: 15 Q Did Jane Doe 6 ever tell you that she provided 16 Mr. Epstein a massage while her bra was off? 17 A No, sir. 18 Q Is Jane Doe 6 one of your best friends? 19 A I wouldn't say best friend but she is a 20 friend. 21 Q Is she a close friend? 22 A I mean, when I go to i go and say hi 23 but that's about it. 24 Q Since you moved to how often do you 25 speak to Jane Doe 6? I 4 (Pages 10 to 1 3) PROSE COURT 'REPORTING AGENCY, INC. Electronically signed by Michelle Baden MMIM aa3d0950-6535.414d-81186434195ac559 EFTA00724278 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 14 A Only when I go down there, so I would call her before I go down there and say "Hi," but other than that we don't talk. Q Do you know of any traumatic events that Jane Doe 6 has experienced in her lifetime? MR. MERMELSTEIN: Objection to form. BY MR. PIKE: Q And your answer was, A No. Q Do you know whether or not any one of her boyfriends everMEMS? A Yes. Q Would you consider that a traumatic event? A Yeah. Q And your answer was, A Yes. What • was that, to your knowledge, A I have no idea. Q Did Jane Doe 6 ever discuss that traumatic event with you? A No. I heard from somebody else. Q Who did you hear from? A I have no idea. Just gossip around the neighborhood. I have no idea. Ms ? 1 .2 3 4 5 6 7 8 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25, Page 16 A Q Do you know of any other close friends that have died in Jane Doe 6 lifetime? A No —or yes. Q And who was that? A Q And who is that to Jane Doe 6? A Good friend. Q Would you consider that a traumatic experience for her? MR. MERMELSTEIN: Objection to form. BY MR. PIKE: Q You can answer. A Slightly, yes, a little Q And how did Mr. die? A a And did they eve1 A Yes. Q And is that person= A Yes. Q Do you know whether or not Jane Doe 6 has ever done drugs in front of you? And by "drugs" I mean marijuana, amphetamine or any kind of painkillers? A Yes. Page 15 1 Q Did you ever have any sexual experiences with 2 Jane Doe 6? 3 A No. 4 Dkl ever learn that Jane Doe 6 was an 5 at the age of, A No. 7 MR, MERMELSTEIN: Objection to fonn. 8 BY MR. PIKE: 9 aor you know whether or not Jane Doe 6 is a 10 11 12 13' 14 1S 16 17 18. 19 20 21 22. 23 24 A I knew shel.Mbut 1 don't see it any farther than that. Q Do you know whether or not she has a relationship with her mother? A She does, as far as 1 know. Q Based upon your experience, do you know whether or not it is a good relationship or a bad relationship? A 1 would say good. Q Where does her mother live, to your knowledge? A Q What about her relationship with her father, do you know anything about that? A I guess they have a good relationship. Q Do you know where her father lives? Page 17 1 Q And what drugs has she done, to your 2 knowledge? 3 A Marijuana in front of me. 4 Q What other drugs? 5 A She's never done anything else in from of me. 6 Q To your knowledge, do you know whether she has 7 done any other drugs, separate and apart from marijuana? 8 A . I'm not sure. 9 Q Do you know whether or not Jane Doe 6 drinks 10 alcohol? 11 A No. 12 Q When she did marijuana in front of you, how 13 old was she and how old were you? 14 A 15 and 1 don't know how old she was. 15 Q Have you ever met Jane Doe 6's child? 16 A 17 18 A 19 20 A 21 22' A 23 24 A 25 Yes. And what is name? Have you ever met the father? Yes. And what is his name? And his last name? 1 have no idea. Do you know who Jane Doe 6 currently dates? 5 (Pages 14 to 17) PROSE COURT REPORTING Electronically signed by Michelle Baden NM= AGENCY., INC. a53d0950-136364f4d-8118-6434195se659 EFTA00724279 Page 18 1 A la. 2 Q And doeaMive 3 A Yes. 4 Q And what does he do? 5 A I'm not sure. alMni or something. 6 Q With regard to the women that you said you 7 knew, were you aware as to whether or not any of those 8 women ever went to Jeffrey Epstein's home in Palm Beach? 9 A 1 only knew about Jane Doe anclia 10 Q Did you ever go to Jeffrey Epstein's home? 11 A No, sir. 12 Q Ind you ever drop anyone off at Jefftey 13 Epstein's home by vehicle? 14 A No. I can't drive. 15 Q And why can't you drive? 16 A 1 don't have a license and lam afraid of the 17 road. 18 Q Have you ever had a license? 19 A No, slr. 20 Q Why is it that you are afraid of the road? 21 A I got in a car accident whealwaa 22 Q Who was in the car with you? 23 A My friend= 24 Q And what is her last name? 25 A 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 20 A No. We went to the store. Q During the times that you hung out with her, was she ever crying? A No. Q During the times you hung out with her recently, did she ever make any mention or complaint about Jeffrey Epstein? A No. Q Did she seem depressed to you? A No. Q Did she dist-mg any emotional issues that she was having with you? A No, sir. Q Did she discuss at all any happy times in her life, of the times that you visited with her most recently? A No. Q What did you guys talk about? n't know. Ii our friend' A Q A And that would be Ma Yes, sir. Ho ' 9 He Page 19 1 Q Anyone else? 2 A /N. stn. 3 Q I still living today, that is did she 4 die as a result of the car accident? 5 A No. She's still living. 6 Q When you saw Jane Doe 6 on Stmday, did she 7 seem happy to you? 8 A I don't know. We just stopped by and said 9 "Bye" so — she was just watching a movie. 10 Q You said you stopped by and said "Bye..."? 11 A Yeah, because we were driving back toME 12 Q Who was with you? 13 A My boyfriend. 14 Q What is his name? 15 A 16 Q Does lie live in 17 A Yes. 18 Q How long did you visit with Jane Doe 6 for? 19 A I saw her a couple of times since I was there, 20 just hung out for a little and then I was mainly at my 21 mom's. 22 Q When you hung out with Jane Doe 6, where did 23 you go? 14 A We were at her house. 25 Q Any other places? 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 Page 21 Q A Yes, sir. Pm sorry, you testified that Mal was Ma is that correct? A Yes. vots.What were the circumstances surrounding how he A They sa r a lot of stories like it the but he got basically and then the people ran. . _10 Where was be living at the time that he was NEA if ou lifis mw? Q Do you know if Mr was in a gang? A No, I don't. Q Do you know iflane Doe 6 was ever in 2. A I don't believe so but I don't know everyb . she knows. I live here now. Q Did Jane Doe 6 ever talk to you about her being a prostitute? A No. Q Do you know whether Jane Doe 6 ever was a prostitute? A No. 6 (Pages 18 to 21) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by Michelle Baden .53•10960-b535-0444t184434198ae569 EFTA00724280 Page 22 1 Q That is no you don't lmow one way or the 2 other? 3 A No, I don't know. 4 Q Do you know whether or not Jane Doe 6 ever 5 vented at any strip clubs and/or gentlemen's clubs? 6 A No. 7 Q That is no, you do not know? 8 A No, I do not know. 9 Q Do you know if she ever hung out at any strip 10 clubs or gentlemen's clubs? 11 MR. MERMELSTEIN: Objection to form. 12 BY MR. PIKE: 13 Q You can answer. 14 A I don't 'mow. 15 Q Do you know if Jane Doe 6 was ever involved in 16 a car accident? 17 A I believe so, when she was younger. 18 Q What do you know about that car accident? 19 A I believe it was aMill That is all I 20 remember. 21 Q Do you know if anybody passed away in her 22 vehicle? 23 A I don't know. 24 Q Do you know if anybody came close to dying 25 that was in her vehicle? Page 24 1 A No, sir. 2 Q Were you ever out anywhere a 3 where you saw.lat a club? 4 A No. 5 Q Dld you talk to= on the phone? 6 A No. 7 Q When was the last time you talked toile 8 A !saw her at Wal-Mart when I was, probably, 9 It 10 Q You said you saw her at Wal-Mart? 11 A Yeah. 12 Q I didn't hear you if you testified to this, 13 Pm sorry. How long ago was that? 14 A I'd say when I was 18. I went down to visit 15 and she was at Wal-Mart eating at the food 16 court and I _ i said "Hi." 17 Q Hass. ever discussed Jeffrey Epstein with 18 you? 19 A No, sir. 20 t f I remember correctly, you said you knew 21 that M. was going to Jeffrey Epstein's home? 22 A I heard Jane Doe mention it but don't know 23 details. 24 Q When you say "Jane Doe" you mean Jane Doe? 25 A Yes, sir. Page 23 1 MR. MERMELSTEIN: Objection to form. 2 THE WITNESS: I don't know. 3 BY MR. PIKE: 4 Q Let's talk abou= You said you knewill.; 5 is that correct? 6 A I met.. 7 Q How did you meet.. 8 A Once again, just everybody knows everybody and 9 she was hanging out one night and I met her. 10 Q Where did u meet her? 11 A at the bead, I believe. 12 Q How long have you known ha? 13 A I not her on my 15th birthday, !believe. 14 Q Okay. So you have 'mown her for, what,. 15 years, approximately? 16 A Well, I have only — in that whole time, I 17 have only hung out with her for maybe lute three times. 18 So that is why I don't say like she's a friend. She's 19 just an acquaintance. I met her. 20 Q When you hung out with her for those three 21 times, where did you guys hang out? 22 A We were at the beach. The other times we were 23 just, I don't know. I know she was at Jane Doe's once. 24 And then I don't !mow. 25 Q Did you guys ever go out to clubs together? 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 25 Q What did Jane Doe mention that you are talking about now? A She said that she was at the house that. Q That. was at Mr. Epstein's house? A Yeah. • Q Have you ever discussed.. going to Mr. Epstein's house with.? A No. Q What, if anything, do you know about... going to Mr. Epstein's home?. MR. EDWARDS: Form. THE WITNESS: I don't know anything besides that she went there. BY MR. PIKE: Q Do you know whether or not she did anything of sexual in nature at Mr. Epstein's home? A I have no idea. I know that you said you didn't bang out with M. that much, but I have to ask you these questions and I'll try to make them short. Did.. discuss with you any traumatic events that happened to her at Mr. Epstein's home? A No, sir. Q Has.. called you to discuss at all any emotional issues that she allegedly has by virtue of 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden IMMIMID at3d0950-b536-4f4d4018-643419Sec669 EFTA00724281 Page 26 1 having visited Mr. Epstein's home? 2 A No. 3 Q Do you know whether or nail worked at 4 strip clubs? 5 A I don't 'mow. 6 Q As you sit here coda our testimony is you 7 don't know whether or node. ever worked as a stripper 8 at a snip club? 9 A I have no idea. 10 Q Did Jane Doe ever tell you than. ever 11 worked at any strip club? 12 A No. 13 Q Do you know whether or no is an admitted 14 prostitute? 15 A I don't know. 16 MR. MERMELSTEIN: Form. 17 BY MR. PIKE: 18 Q Do you know whether or not- ever sold her 19 body for sex? 20 MR. EDWARDS: Objection to form. 21 THE WITNESS: I have no idea. 22 BY MR. PIKE: 23 Do you know whether or no= ever 24 when shewaiters old? 25 A I have no idea. 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 28 BY MR. PIKE: Have you ever been AMMAN A No, sir. Q Do you know whale) is? A A gentlemen's club. Q Do you know t nextd Mien- - club is a place call A I don't even latow is located. Q Have you ever heard the term "jack shack"? A Yeah. Movies. Q What -- bow do you understand that term? A I guess, basically, a place where you go and sell yourself. Q Do you know whether or no.. has ever worked at any jack shacks? A No. MR. EDWARDS: Object to the form. BY MR. PIKE: Q That is no, you don't know? A No, I don't know. Q All right let's move on toM. You did testify earlier that you knew her, correct? A Yes. Q How do you known.? Page 27 1 MR. EDWARDS: Objection to the form of that 2 question as well. 3 BY MR. PIKE: 4 Q Do you know whether or no s a 5 prostitute? 6 A I don't know. 7 142. EDWARDS: Same objection. 8 BY MR. PUCE: 9 Q Had you ever heard than...as a 10 prostitute? 11 A No. 12 Q Do you know who.. is currently dating? 13 A No. 14 Q What else can you tell me about., if 15 anything, that we haven't discussed during your 16 deposition today? 17 A !can say nothing because I don't talk to her. 18 I've only hung out with her a couple times and didn't 19 really, you know, talk-talk. Just hung out. I don't 20 know her. I don't know anything. 21 Q Do you know whether 22 works at a lace call 23 in 24 A I don't ;mow. 15 MR. EDWARDS: Object to form. ently right by 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 Page 29 and was Q was that? A Q And did you go to HAM for. years? . A No. Q 11..ur long did you go - A El years. Q And how long did.. go to that school for? A I'm nql.tia. .Q What= were you in when you first met A I was Q Did You Pr A No. Q How did you meet her? A I met her brother and then I went to her house and met ha. Q How did you meet her bro ? • A Just around the neighborhood, like everybody knows everybody. Q Did you ever date her brother? A No. Q Did you ever have any sexual experiences with 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden . and095043536-414d-8116-6434195ac669 EFTA00724282 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 Page 30 her brother? A No. !ti Did you ever have any sexual experiences with ..? A No. Q Are you aware that.. and.. are friends? A Yes. Q How are ou aware of that? A . htzg_out with me and then she started hanging out with., and then we basically an talk an more. We went separate ways. Did . ever tell you that.. ever worked A No. I haven't talked to.. maybe since I was 15. Q And why did you stop talking to..? A Well, she always came to hang out with me and then, I don't know, we went our separate ways and, I don't knowzie•ust lost contact Q Did . ever discuss whether she went to Mr. Epstein's home in Palm Beach? A No, sir. Q She never discussed that with you? A No. Q Did.. ever tell you that she worked at Page 32 1 MR. EDWARDS: Form. 2 BY MR. PIKE: 3 Q When was the last time I 'mow you said you 4 haven't spoke a. in a while. When was the last 5 time you spoke to her? 6 A I talked to her, I would say, maybe two years 7 ago on the phone. She was with Jane Doe, I believe, and 8 I just said "Hi" you know, caught up and asked how we 9 were doing and that was it. 10 Q Did she tell you what she was up to worlovise 11 in that telephone call? 12 A No. 13 Q How long did that telephone call last? 14 A I would say maybe five, 10 minutes. I was at 15 a store, Thad to go. 16 2 How did you learn or di ever learn that 17 M. went over to her home in 18 A Basically you told me. !had I10 idea. 19 Q So you had no idea — you had no idea up until 20 today's date? 21 A Yes, no idea. 22 Q Did Jane Doe or anyone ever tell you that I. 23 had some sort of experience with Mr. Epstein? 24 A No. 25 Q Did anyone ever tell you that.. ever gave Page 31 1 2 A No. 3 Q How long were you friends with..? 4 A Well, I have known her — I met her when 1 was 5 likes and we hung out for a couple of years, and then 6 we just didn't hang out any more, so two years. 7 Q Pro sorry? 8 A Like two years. 9 Q So you knew her for two yews? 10 A Yeah. 12 tell you that she worked a Q And durittg that two- ear eriod, did she ever 11 13 A No. 14 Q Did you ever come to learn at any even 15 up through today's date, that she worked at 16 A Yeah. 17 Q How did you learn that? 18 A Jane Doe. 19 Q What did Jane Doe tell you about that? 20 A She just told me she w 21 Q Did she tell you which 22 A No. 23 Q Did she tell you that ever worked at any ?4 jack shacks? A No. Page 33 1 Nix. Epstein massages in exchange for money? 2 A No. 3 Q Do you know whetbirar not, during the time 4 that you were friends withM. that she ever used 5 drugs? 6 A Marijuana. 7 Q And how old was she when she was using 8 marijuana? 9 A 15,14. 10 Q Do you know whether or not she used marijuana 11 on a weekly basis or on a daily basis during that time? 12 A I think it was just like a weekend thing. 13 Q Do you know whether or not she ever did 14 Ecstasy? 15 A I have no idea. 16 Q What about do you know whether or not 17 she did Ecstasy? 18 A I have no idea. 19 Q And Jane Doe 6, do you know whether or not she 20 ever did Ecstasy? 21 A I don't think so. 22 Q Other than marijuana, are you aware at joy. 23 time, even up until today's date, whether or not EMI. 24 used any other drugs? 25 A No. 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden lIMM. a53d0950-b535-4(4d-Sf18-6434195ac559 EFTA00724283 Page 34 1 Q No, you are not aware? 2 A No, I don't know. I'm not aware. 3 Q The last time you spoke with., which was 4 approximately two years ago, did she discuss whether or 5 not she was experiencing any emotional or traumatic 6 experiences in her life? 7 A No, sir. 8 Q Give me one second. 9 A Olcay 10 Q DWI... ever ask you to go to Mr. Epstein's 11 home? 12 A No. 13 Q Were you ever asked by anyone to go to 1.4 Mr. Epstein's home? 15 A Yes, by Jane Doe. 16 Q And wall. around at the time that Jane Doe 17 asked you that? 18 A No. 19 Q DidM. ever attempt to persuade you in any 20 way to go to Mr. Epstein's home? 21 A No. 22 Q Let's talk about Jane Doe. When was the first 23 time you came to know Jane Doe? 24 A 25 Q Did you guys live close to each other? 1 2 3 4. 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 36 BY MR. PIKE: Q You can answer. A Oh. Q And are u aware as to why A or something along those lines. Now are ou aware as to whether or not he was A I think so. ai d do you know the circumstances surrounding A No. Q Do you know whether or not Jane Doe witnessed an in related to that A I believe she was there when it happened. Q What, to you ed? A I heard that and she woke up and he was Q And who was that, relative to Jane Doe? A Do u know whether or not her A I don't know. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22. 23 24 !p Page 35 A Q Would you consider yourselves to be best friends? A We were. Q So how lonuere you best friends? A Since i was. and then I moved here and we just don't talk too much any more. We don't talk any more, Q So is it a fair statement that you were best friends for approximately= years? A Yes. Q And that would be approximately from the time that you both were, up until the time that you were about. A Yeah. I would say Q And why aren't you best friends today? A Well, I would consider her my best friend but then we went separate ways. I moved here and !just haven't talked to her. Since I've moved here I have only talked to her a couple of times. Q I want to talk a little bit about Jane Doe and her childhood. What traumatic experiences are you aware of that she experienced in her childhood? MR. EDWARDS: I object to the form of the question. 1 2 3 4 6 7 8 . 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 37 Q Do oulmow what — did Jane Doe ever tell ou that her A No. Q Do you know whether or not lane Doe gave any itions related to A I think so. Se Do you know whether or not she lied for her in deposition? A I don't know. ME Did she ever tell you that she lied for her in those depositions? A No, sir. • Do you know how old the 1, was that A I don't know. I'm not sure. Q You testified that as a result of this incident, as we speak today, correct? A Yes. • Q Do you know whether or not Jane Doe has a relationship with her today? A I don't know. Q D o i" know whether or not she has gone to visit in the last two years? 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY,. INC. Beetronicany signed by Michelle Baden =EMS a53(10950-b535-4f4d-8f18-6434195ac559 EFTA00724284 1 Q Who is that? 2 A Her ex-boyfriend. 3 Q Do you know how long they dated for? 4 A I would say over a year. 5 Q And how old was Jane Doe when she started 6 dating Mr. a/ 7 A I would say 16 — no, 16, 17, maybe, yeah. 8 16, 17. 9 Q Ma in know whether or not she had intercourse 10 with Mr. during the time that she was dating 11 him? . 12. A Yes. 13 Q The answer is, yes, she did have intercourse? 14 A Yes. 15 Q Dosi row whether or not she ever gave oral 16 sex to Mr. 17 A I don't know. 18 Q Did she ever discuss that with you? 19 A No. 20 Q Do you IcnoW whether or not Mr. 21 performed oral sex on her? • 22 A I don't know. 23 Q Did she ever discuss that with you? 24 A No. 25 Q Who else are you aware — actually, let's back 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No. Q No, she has not or no you don't know? A No, I don't know. o lio you know whether or not her - A I don't 'mow. I think so but I don't know for sure. il Do you lmow, as u sit here today, what her may have A No. Q Do you know whether or not Jane Doe has a relationship with her father? A No. Do u know whether or not her father ever A !don't know. Q Did Jane Doe ever discuss with you her fathers MOM? A No. Q Did Jane Doe ever discuss with you her Page 38 was ever father A No. Ali o you know a gentleman by the name of IM A Yes. Page 40 1 up. Did you ever witness an or physical 2 altercations between Mr. and Jane Doe? 3 A No. 4 Q Do you Imo" whether or not Mr. ever 5 EJane Doe? 6 A No, I don't ;mow. 7 Q What other gentleman are you aware of that 8 Ms. Jane Doe dated, from age 13 up until today's date? 9 A Umm. 10 Q Let's start from the age 13 and move forward. 11 A Wow. Well, she dated — I don't know. The 12 people she dated was only for a little and I didn't 13 even — I don't know. Let's see. She dated. Oh, she 14 dated 15 Q How long did she date him for? 16 A Not too long, couple months. 17 told was she when she was dating 18 Mr. 1919 A 14,13. 20 Q Did she have intercourse with Mr. IMF 21. A Yes. 22 Q Dost how many times she had intercourse 23 with Mr. 24 A No. 25 Q Do you know how many times she had intercourse Page 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 ever 20 21 22 23 24 Page 41 with Mr.M? A No. Q Do know whether or not she performed oral sex on Mr. A I don't know. Q Do you know whether or not he performed oral sex on her? A I don't know. • Q How did you become aware that Jane Doe had intercourse with Mr. and Mr.M? A She told me but that's about it. No details. Q As you sit here today, do it inow whether or not she had intercourse with Mr. more than five times? A Probably. Q And, as you sit here today, do you know whether or not she had sexual. ntercourse with Mr. more than five times? A Probably. Q Dayou know whether or not she did any drugs with Mr. and Mr. a MR. EDWARDS: Object to form. THE WITNESS: Marijuana. BY MR. PIKE: . 25 Q So your testimony is that you have seen her do 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY; INC.' . Electronically signed by Michelle Baden Mal a5M0960-b535-41,4d4f184434195salS9 EFTA00724285 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 Page 42 marijuana with Mr. and Mr. IIIIP A Yeah. MR.. EDWARDS: Object to the form. BY MR. PIKE: Q Let me rephrase the question. Have you seen Jane Doe do marijuana with Mr. and Mr. A Yes. Q And how old was she, approximately, when you witnessed these events? A 14 and 16, roughly, yeah. 14, 16 Q.o weve tented about Mr. and A Uh-huh. Q I want yoti to think a bit and tell me who else you can recall that Jane Doe dated? A Some kid namedMI. That was a long time ego and that only lasted for a little while. Q Do you know whether or not she had sexual intercourse with-? A No, I don't know. Q How long ago was it that she dated Mr. IM? A 15. She was 15. Q Do you know how long she dated for? A Not long at all. Q Do you blow last name? Page 43 1 A No idea. Don't even !mow his real first name. 2 Q I figured that. Do you know who Jane Doe is 3 currently dating? 4 A Somebody named 5 Q Is that his real name? 6' A I have no idea. 7 Q Do you 'mow whether or not they live together? 8 A I think so, yes. 9 Q Where does Jane Doe currently live, to your 10 Icnowleci 11 A 12 13 wiQ Do know whether or not she still lives 14 A Yes. 15 Q And does Mr.. live there with them in that 16 residence? 17 A I'm not positive but as far as I know. 18 Q How did she meet Mr. In? 19 A No idea. 20 Q Do you know whether or not Mr. has 21 been — has ever been 22 23 A I have no idea. 14 O Does Jane Doe ever tell you that Mr.Ill was 25 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 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 Page 44 A No. MR. EDWARDS: Object to form. MR. PIKE: For the record, if the form is I don't mear~ THE WITNESS: Yeah. No. Since she's been withM, I haven't talked to her. BY MR. PIKE: Q And how long has it been since you've last spoken to Jane Doe? A I saw her whe Do ot ica mi whethex or not Jane Doe ever al A Yes. Q And how old was she when A The time I know about, I think, slue was St Okay. And what were the reasons why she • to your knowledge? A IfigrAtheYmellIIIIIIIIIIII Q What do you mean that? A I don't knowl Q And when u set " who do ou mean? A Q And do you know wiry they were trying to Page 45 MK in your words? A No. Q Have you ever heard of the tent A Yes. Q Were they trying to A I not sure. Might have, but I don't know. I was young too so I just — I don't know. Q And do you know, when sheMINIME A It was jus situation. Q Did Jane Doe eye period of time? A I mean, you could say We were Just always together. Q Let me try — was there a time that she ever due A She came to.. • ' Q And at that time were both of your parents or was it just one parent? and she didn't know the Or a to her A I would say a couple of dayilIMI with me. Q At the time that you testified that her parents were do you know whether 12 (Pages 42 to PROSE COURT REPORTING'AGENCY, INC. Electronically signed by Michelle Baden IIMM) 853d0950-8535-O48-8118-6434195ac559 EFTA00724286 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 Page 46 or not she was doing drugs or alcohol? A I don't think it was her trying to IIIIIIIthMkftwas But I don't think so. Maybe, if it was, marijuana. Q Do you know whether or not Jane Doe was ever arrested at any time? A I think Q What was she arrested for? A I think Mahe said. Q Do you know what she A No. Q Do you know whether or not Jane Doe was ever arrested for A No. Do ou know whether or not Jane Doe ever. A Oh, yes. Yes. Q How many times? A Q And was she arrested for that? A I believe so, now that you mention it. Q So there is another arrest that you weren't aware of, correct? A Well, now that you bring it up I'd say yes, I was aware of it, but I didn't even remember that. 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 Page 48 hand jobs for mono a A No, sir. Have ever heard of the term of the A I have heard the term, yes. Do you know whether or not Jane Doe worked in A I don't know. Q Have you ever heard the term A No. Q Have you ever heard the tenni...? A Yes. Q Do you know whether or not Jane Doe ever gave to men in exchange for money? A I don't know. Q She never told you? A No. Q Okay. What did Jane Doe discuss with you about working at these two sIES, that you are aware of? A All she said is she works there. I don't talk to her much at all. I say, "Hey, what are you doing? She says, "Hey, I work hero," and I leave it like that because I don't want to know the details. Q Would she tell you how much money she made? Page 47 1 Q You understand you are under oath today, 2 correct? 3 A Yes, sir. 4 Q And that oath is for you to tell the truth? 5 A Yes. 6 Q So I'm going to ask you a question. I want 7 you to take some time and think about this question. 8 As you sit here today, having known Jane Doe 9 from the time that you were 13 up until todays date, 10 other than the two arrests that we have just discussed, 11 are you aware and do you recall any other arrests? 12 A No, sir. 13 Q Ares= whether or not Jane Doe ever 14 worked at 15 A Yes. 16 Q Whs' arc you aware of that she 17 wonted at? 18 A 19 Q What others? 20 A I don't Icnow. 21 S . But you are aware that there were other". 22 but you don't know the names; is that correct? 23 A I think one other one but J don't know the • 24 name. 25 Q Okay. Did Jane Doe tell you that she gave men 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20. 21 22 23 24 Page 49 A No. Q Did she ever tell you that she sold her body for sex? A No. Q Back when you were 14 to 17, who did Jane Doe live with? A Q And where was her to your knowledge, at this time period? A At her house. Q When you say "her house" do you mean the house or a separate home? A No. A separate home. Q Why did lime Doe and her live apart? A They have never got along. I'm not sure the reason why they — she left but they have never got along, basically. Do you know whether or not Jane Doe has a. A No. Q Do you know whether or not married? A Oh, wait. Yes. I don't know if she's married but it's a guy named if I'm correct with the name. 9 Okay. Do pan, kno tv whether tu fr2i not la 7:e is 13 (Pages 46 to 49' PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden IMES a53d0950-b535-414d-8118-6434195ac559 EFTA00724287 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. Page 50 Doe had a relationship, good relationship? A 1 dolt think they got along either. Q Do you know why? A No. I think he was just a mean guy. Q Did he ever do anything mean to Jane Doe? MR- EDWARDS: Object to the form. BY MR. PIKE: Q You said he was a mean guy, so I just want to know did he ever do anything mean to Jane Doe, to your knowledge? A No. Maybe just be an ass. Sorry for my language. Q Have you ever witnessed any altercations beriveen Jane Doe and her mother -- A No. Q -- between the ages of 13 and 17? A No. Q Do you know whether or not Jane Doe ever kick A No. Have u ever seen Jane Doe physically hurt A No. Have ou ever seen Jane Doe physically touch in an aperessive manner? Page 52 1 we were like 14, 15 and — yeah. 2 Q Hold on one second, please. 3 I want to backtrack a little bit We talked 4 about Mr. and Mr. and we talked about 5 and we talked about 6 A Uh-huh. 7 Q Having discussed them today, are you aware of 8 anyone else that she's dated? 9 A Off the top of my head, 1can't think of 10 anybody right now. I'm thinking but she was with -- 11 yeah, I think after yeah, after she was still 12 dating him when I moved to 13 Q And do you know whether or not Mr. 14 verbally and physically abusive to her? • 15 A I don't know. 16 MR. EDWARDS: Objection; form. 17 BY MR. PIKE: 18 Q You don't know? 19 A I don't ;mow. 20 Q Do you know whether or not Jane Doe has ever 21 tried cocaine? 22 A I third( -- yeah. 23 Q Do you know whether or not she's ever tried 24 Ecstasy? 25 A Yes. was Page 51 1 A No. 2 Have ou ever known Jane Doe to do drugs in 3 home? 4 A No. 5 Q As you sit here today, your testimony is that 6 do not know that Jane Doe has ever done drugs in her 7 home? 8 A Well, marijuana And that was when we were 9 like 15 no, not even 15. 14, 13. 10 Q How many times? 11 A I don't know. More than once. Like four 12 times, couple times. 13 Q And who was with you guys at the time you were 14 doing marijuana? That is, who else was doing it with 15 you, if anyone? 16 A It was just us. 17 Q And back in those days, where would you 18 purchase the marijuana? 19 A I don't !mow. She gait. 20 Q Do you have any idea where she got it from? 21 A • No. We would just hang out after school. 22 Q Do you know whether or not 23 did not want her around because she worked at 24 and did drugs? .5 A No. When -- last time I even heard about (....•••443•Jdnesaryi4a.an Page 53 1 Q Do you know whether or not she's ever tried 2 pain pills? 3 A No. 4 Q Do you Imow whether or not she's ever tried 5 methamphetamines? 6 A No. 7 Q How do yoti know she tried cocaine? 8 . A She told me. 9 Q How many tines? 10 A I'm not sure. Maybe a couple. 1 don't loww. 11 We were young. I don't know. 12 Q Do you know how many times she tried Ecstacy? 13 -A I don't blow. 14 Q Were you with her when she tried Ecstacy? 15 A Yeah. 16 Q All right. Where were you guys? 17 A Well, we were hanging outside and then we went 18 to my house. 19 Q So you guys were doing Ecstacy outside and at 20 your house? 21 A Yeah. 22 Q How many times did you do Ecstacy with her? 23 A . A couple. 24 Q Did you guys ever go to any raves? 25 A No. iarl 14 (Pages 50 to 53) 'PROSE COURT REPORTING AGENCY, INC: Electronically signed by Michelle Baden a aS3d0950-b535-414d-M184434195acE59 EFTA00724288 Page 54 1 Q Where did you do Etstacy? 2. A We would take it and then we would go inside 3 and hide from my mother. 4 Q Did you purchase the Ecstacy? 5 A No. 6 Q Who got the Ecstacy for you? 7 A I'm not even sure. 8 Q Did Jane Doe get it? 9 A I don't know. Maybe. I don't know how we got 10 it. 11 Q Do you know whether or not Jane Doe has ever 12 done acid? 13 A I don't think so. 14 Q Do you ;mow whether or not Jane Does 15 was a serious user? 16 A I heard. did drugs. 17 MR. EDWARDS: Form. 18 BY MR. PIKE: 19 Q Let me rephrase thesestion. Do you know 20 whether or not Jane Doe's... ever did drugs? 21 A Yeah. 22 Q What do you know about that? 23 A I think Jane Doe said ■ 24 0 Do you know for how ion 25 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 56 Q Do you know where What I mean by that is state and county or just the county? A I just know Do you know how old Jane Doe was at the time she A Younger than Q Did she ever discuss that with ou? A She said she woke up and and that's all I know. Q Do you know whether or not that was psychologically impacting for her? MR. EDWARDS: Object to form. THE WITNESS: Probably. BY Mt. PIKE: Q And, once again, I'm just going to ask the question. Did she ever discuss the incident with you at all? A Yeah. Q And what did she discuss with youseparate and ai m telling you that she woke up an' there? A Oh, well that's it. She said she woke up and there was MEN and said "Oh, m osh, look" or something and she looked up and sass 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 to, quote, 19 she currently lived in? 20 A No, I have no idea. 21 22 A 23 Q And 24 25 A I believe so. I'm not sure. What is her name? Oh, my gosh, leaf* even think of it right Is itelliffM? Yes. Do ou know Jane Doe's name? Page 55 A Q now. Q A Q Do you know whether or not Jane Doe was ever forcibly taken from her home by her A I have no idea. Q Did you know whether or not her mother and her father had several physical fights in front of Jane Doe? A No. Do ou know whether or not there was any n Jane Doe's home? A No, I don't know. Q Do you know whether or not there was ever an incident back in where or Jane Doe threatened that as his 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 Page 57 Q Is that it? A Yes, sir. Q Let me ask you this question. Did she ever tell you that and that her was becoming angry as a result of that? A No. Sr Did Jane Doe ever tell ou that she saw that was not that evening and that she went to he tell him the same? A No. Q Did Jane Doe ever discuss with you the to statement that she gave to n or around ME A No, sir. Q Do you know whether or not Jane Doe ever testified that helIMIMIMIIMI A I know she testified but I have no idea what happened. Do ou know whether or not her laxly? ever A No. I don't know. Did Jane Doe ever tell you that her '7 A No. 15 (Pages 54 to 57) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden Mlle a53d0950-b535-414d-8f18-6434195ac559 EFTA00724289 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 Page 58 Q You testified earlier that you know of the name Jeffrey Epstein, correct? A Yes. Q And do you know whether or not Jane Doe had any dealings with Mr. Epstein? A Yeah. Q And what are you aware of? A I'm aware that she went to his house by taxi and went there and massaged him naked for money. Q And when you say she was naked, can you explain that for me? And what I mean is did she have her panties on and her bra off or everything off? A I heard everything. MR. EDWARDS: Object to the form of the question. BY MR. PIKE: Q Ybu can answer. What do you mean by "naked"? A No clothes. Q What else did she, Jane Doe, tell you about having gone to Mr. Epstein's house? A That there were other girls there and that's it. Q Did Jane Doe tell you how many times she went to Mr. Epstein's home? A I don't know. All I !mow of is like two Page 60 1 A No, sir. 2 Q Did she seem happy about receiving the money? 3 A I don't know. I don't even think i was there 4 when — she wasn't even around when she got the money. 5 I have never even physically seen money. 6 • Q Did she ever seem upset about going 7 Mr. Epstein's home? 8 A Well, she wasn't with me when she went. She 9 just told me, so I wasn't even around her. 10 Q When she told you, did she seem upset? 11 A Maybe a little, but I don't know. She just 1 2 told me she went and that's it. 13 Q Was she crying when she told you this? 14 A No. 15 Q Did she ever seem emotionally disturbed as a 16 result of going to Mr. Epstein's home, to your 17 knowledge? 18 A Not to my knowledge. 19 Q Did she seem to be under any emotional 20 distress as a result of going to Mr. Epstein's home? 21 MR. EDWARDS: Object to form. 22 THE WITNESS: Not to my knowledge. 23 BY MR. PIKE: 24 Q Do you know whether or not Jane Doe attempted 25 to reauit other girls to allegedly go to Mr. Epstein's Page 59 1 times, three times. 2 Q And other than giving him a massage, did Jane 3 Doe say she would do anything else for Mr. Epstein? 4 A No, sir. 5 MR. EDWARDS: Object to the form. 6 THE WITNESS: No, sir. 7 BY MR. PIKE: 8 Q Did Jane Doe ever tell you that Mr. Epstein 9 forced her to do anything inappropriate? 10 A No, sir. 11 MR. EDWARDS: Object to the form. 12 MR. PIKE: You didn't like that answer, did 13 you, Brad? 14 MR. EDWARDS: I didn't like your question. 15 BY MR. PIKE: 16 Q Did Jane Doe ever all you that Mr. Epstein 17 forced her to do anything? 18 A No. 19 Q Did Jane Doe tell you that she gave 20 Mr. Epstein a massage in exchange for money? 21 A Yes. 22 Q What did she tell you, just that? 23 A Yes. 24 Q Do you know how much she claims Mr. Epstein 25 gave you? Page 1 home? 2 A She asked me and that is all I 'mow. 3 Q And at that time you were her best friend, 4 correct? 5 A Correct 6 Q And what did you say when she asked you to go 7 to Mr. Epstein's home. 8 A Absolutely not. 9 Q Okay. And why did you make that decision? 10 A Because I would never do that or put myself in 11 a position to do anything like that. 12 Q Did she tell you what she did for Mr. Epstein 13 when she made this offer for you to go to his home? 14 A .Yeah, I Ian the circumstances. 15 Q Explain to me how you understood the 16 circumstances at that time? 17 A Well, she told me she would massage him naked 18 and I said, "Pm never going. 1 would never do that" 19 Q Did she ever say that she touched his penis? 20 A No. 21 Q And where would she massage him, to your 22 knowledge? 23 A In atom. 24 Q Ina room? 25 A Yeah. ?1,1UNSOAEAredites.... .....00,4•4•4 16 (Pages 58 to 61) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden MIMI a53d0250-b535-414d-M18-6434195ac559 EFTA00724290 Page 62 1 Q What body parts did she touch, to your 2 knovdedge, if at all? 3 A I don't know if she touched anything. I don't 4 know anything like that 5 Q So, to your knowledge, the massage was just a 6 regular massage but naked? 7 A Yes. To my knowledge, yes. 8 Q Do you know whether or not Mr. Epstein ever 9 touched her in a sexual nature? 10 A I have no idea. 11 Q Did she ever tell you that Mr. Epstein 12 masturbated during any one of these alleged massages? 13. A Yes. 14 Q What did she tell you? 15 A She said he masturbated while she massaged him 16 or something. 17 Q And when she told you this, was she laughing? 18 A No. 19 Q Was she crying? 20 A No. 21 Q Did she seem depressed? 22 A No. 23 Q How much money did she tell you she received 24 as a result of this massage? 25 A She never told me money amount. 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 Page 64 Q You can answer the miestion, if you recall. A I don't know about every day. I don't !mow about every day. Q What about every other day, do you have any knowledge as to that? A No. Q Have you ever done cocaine with Jane Doe? A Yes. Q And where did you do cocaine with Jane Doe venue-wise? Where was the location? A My house hiding from my mother. Q And did ou ever do cocaine with Jane Doe at Jane Doe's house? A No, sir. Q How many times did you do cocaine with Jane Doe? A I don't know. More than once. Q More than five times? A No. She stopped. She didn't like it anymore. Q After she stopped using cocaine, what other drugs, if any, did she continue to use? A I don't think any. Just marijuana, I think, if that Q Did she ever tell you that Mr. Epstein threatened or intimidated her for any reason? Page 63 1 Q So when she told you that she would give 2 Mr. Epstein a massage naked and she invited you to come 3 with her, she didn't tell you how much money you could 4 make? 5 A No, because I basically wanted to end the 6 conversation because I don't want to hear about that. 7 Q Do you know whether or not Jane Doe recruited 8 any other girls? 9 A I don't know. 10 Q Do you know whether or not Jane Doe and 11 worked at the same 12 A I don't know. 13 Q Do you know whether or not Jane Doe's drug use 14 affected her memory? 15 A I don't blow. 16 Q I'll have ou assume that Jane Doe testified 17 that sh un an every-day basis. Does that 18 refresh our recollection as to whether or not Jane Doe 19 n an every-day basis? 20 MR. EDWARDS: Object to the form as it 21 completely mischaracterizes the witness' testimony. 22 If this witness Is going to be basing her answer on 23 a hypothetical then Pm going to object to all of 24 those questions. .5 BY MR. PIKE: 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 Page 65 A No, sir. Q Did she ever tell you that Mr. Epstein forced her to do anything? A No. Q When she discussed having you potentially come over to Mr. Epstein's home, did she tell you you would have to lie about your age? A No. Q Did she discuss anything about your quote, age? A No. Q Do you know whether or not Jane Doe was seeing a psychologist or a counselor between the ages Aland today's date? A Maybe a counselor, but I don't know. Q Have you ever heard the tenn A Yes. Q How did you come to learn about that term? A TV, just learning it. Qail mm i t ane Doe ever tell ou that she suffered froci A No. Q Did Jane Doe ever tell you that she had any emotional disorders? 17 (Pages 62 to 65) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden IMIEM aS3d0950-b535-414d-8118-6434195ac559 EFTA00724291 10 11 12 13 14 15. 16 17 18 19 Does that refresh your recollection? 20 A I have no idea. 21 Do you know whether or not Jane Doe was ever 22 23 A No. 24 Q Other than the individuals we've discussed 15 today, are you aware of anyone else that allegedly went 1 3 4 5 6 8 10 11 12 13 14 15 • 16 17 18 19 20 21 22 23 24 25 Page 66 A No. Q Did Jane Doe ever tell you that she had any emotional problems? A I mean, her life has been crazy. Her whole life, so Q And what do you mean by that, if you could be a little more specific? A I mean, *ust her growiad then the stuff with oing on and i has nothing to do with her. The only person that cares for her is her =I, so, I don't know. Q Have you 'mown Jane Doe since you were. A Yes. Q Did you see any emotional change or emotional distress after you learned that Jane Doe was going to Mr. Epatein's home? A No. Q Do you know whether or not Jane Doe worked at A I believe she might have mentioned that one, the MMIIM kind of rings a bell but I'm not sure. .1.3o you know whether or not she ever worked at A I have no idea. Q What about Page 68 1 to Mr. Epstein's home? 2 A No, sir. 3 Q Give me one second. When was the last time 4 you talked to Jane Doe? 5 A Last time I talked to her is when sant. 6 came to serve me these papers and I was i and 7 I called her and I asked why they were giving me papers. 8 Q And what did she tell you? 9 A She told me because I was her friend and they 10 wanted to ask me questions. 11 Q Have you ever been contacted by any 12 investigators to discuss this matter? 13 A No, sir. 14 - Q Have you been contacted by any lawyers at any 15 time to discuss this matter? 16 A No. 17 Q Has Mr. Edwards ever talked with you over the 18 phone or in person? 19 A No. 20 Q Has anyone by the name of Stuart Mermelstein, 21 Adam Horowitz or Jessica Arbor (phonetic) ever talked to 22 you over the phone or face to face? 23 A No. 24 Q Tell me exactly — understanding that you're 25 under oath, tell me exactly, ma'am, what Jane Doe talked Page 67 1 A I have no idea. 2 Q What abo 3 A No idea. The only one I ;mow is liken 4 5 Q Do you know whether or not Jane Doe's uncle 6 took her to Mr. Epstein's home? 7 A I have no idea. 8 Q You said that you learned that Jane Doe went 9 to Mr. Epstein's home by cab? A Yes. Q How did you learn that? A She told me. Q And did she tell you how many times she went to Mr. Epstein's home by cab? A No, sir. Q Do you know whether or not it was ever to the police that Jane Doe 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 Page 69 with you about relative to this case at any time? A Okay. She told me she would get in a cab and go to Palm Beach. There would be other girls at the house, and she would go in a room and massage him naked and he would give her money and she would leave. And that's all 1 know. Q Did she tell you that she filed a lawsuit against Mr. Epstein? A Yes. Q What did she tell you about that? A That's it. Just ended it right there at that. Q Did she tell you that she wanted to file a lawsuit or that she was convinced by lawyers to file a lawsuit? A She just said there was a lawsuit and that's all! know. Like I haven't talk to her. Q Have you talked to anyone, other than Jane Doe about this lawsuit? A I briefly scanned over to my family but not giving details, just because they asked why I was getting served papers. Q Let's talk about you for a minute. Have you ever been arrested? A No, sir. Q Have you ever been charged with a crime? 18 (Pages 66 to 69, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden a aS3d0950-b5354f4d-8118-6434195ac559 EFTA00724292 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 Page 70 A No. Q Have you ever been detained by a police officer? A No, sir. Q Have you ever worked at any strip clubs? A No. Q What about jack shacks? A No. Q Have you ever sold your body for sex? A No. Q Has anyone offered you any money in this case relative to your testimony today? A No. Well, I have a $45 witness fee. That's it. Q Thank you. A I just looked over to that. Q When you spoke to Jane Doe 6, did Jane Doe 6 tell you that she was assaulted or humiliated by Jeffrey Epstein? MR. MERMELSTEIN: Objection to form. THE WITNESS: No. BY MR. PIKE: Q Did she ever tell you that? A Na Q Give me one second. 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 Page 72 I was liken and I haven't talked to her probably since then. Did ou talk with her at all while she was in A No. Q Do you know whether or not does drugs or not? A I have no idea. • Q When is the last time you s eke to her? A Probabl when I w lik Maybe like see her be like "Hp, Q What reputation, if any, do you recall her having in middle school? A 'don't know. She was a good kid. Q Do you recall any of her boyfriends in middle school? A No. Q Do you know whether or not she had intercourse while she was in middle school? A I have no idea. Q Okay. I have no further questions. MR. EDWARDS: All right. I have a few. EXAMINATION BY MR. EDWARDS: Page 71 1 A Okay. 2 Q Let me ask you this: What was -- if you 3 recall, what was Jane Doe's reputation in high school? 4 A She never went to high school with me. 5 Q Do you know what her reputation was though? 6 A No. 7 Q Was she ever referred to as a girl that was 8 easy to get sex from? 9 A No. 10 Q What about Jane Doe 6? 11 A No. 12 Q What about...? 13 A I don't know. I don't even know her but no, I 14 haven't heard anythirs_. 15 Q What aboutM., to your knowledge, has her 16 reputation ever been to be an easy girl? 17 A No, not when I knew her. 18 Q Tell me about., what do you know about 19 her? 20 A Thad no idea she was even in this case, but I 21 22 23 24 A Absolute nothing. !just know her from 15 . She use to come to my birthdays when went t. with her. Q Tell me what you know about her, other than Page 73 1 Q Melissa, this is Brad Edwards and I represent 2 Jane Doe and I also reportlill. and.. 3 A Uh-huh. 4 Q My question is do you know how many girls 5 Jeffrey Epstein has molested? 6 A I have no idea. 7 MR. PIKE: Object to forth on that. 8 Hey, let's do the court reporter a favor. 9 Let's kind of slow down the question and answer so I 10 can get a "coml." in. 11 MR. EDWARDS: I'll just assume you are going 12 to object to the form of every one of my questions 13 consistent with form. 14 MR. PIKE: I agree, I probably will. If the 15 court reporter doesn't hear it, then madam court 16 reporter let's put a form objection in there for 17 each of his objections, but twill put one on the 18 record as well. Okay. 19 BY MR. EDWARDS: 20 Q Melissa, do you know how many underage females 21 that Jeffrey Epstein has performed oral sex on? 22 MR. PIKE: Form. 23 THE WITNESS: I have no idea. 24 BY MR. EDWARDS: 25 Q Do you know whether Jeffrey Epstein has 19 (Pages 70 to 73) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden =ME) a53d0950-b535-4f4d-8f18-6434195ac559 EFTA00724293 Page 74 1 engaged in sex with underage transvestites? 2 A Oh, no idea. 3 Q Do you know whether that he's made comments to 4 underage transvestite in the course of sexual 5 interaction such as, 'I love how young you are. You 6 have a tight butt like a baby"? 7 MR. PIKE: Fenn. 8 THE WITNESS: No idea. 9 BY MR. EDWARDS: 10 Q Do you know if Jeffrey Epstein has given or 11 received anal sex from men? 12 MR. PIKE: Form. 13 THE WITNESS: I don't know. 14 BY MR. EDWARDS: 15 Q Do you know if Jeffrey Epstein has engaged in 16 sexual intercourse with underaged females as young as 12 17 years old? 18 MR. PIKE: Form. 19 THE WITNESS: I don't know. 20 BY MR. EDWARDS: 21 Q All right. Other than the individuals that we 22 spoke about today, do you know of any of the names of 23 the other young females that have been molested by 24 Jeffrey Epstein in the last 20 years? 25 MR. PIKE: Form. 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 76 MR. EDWARDS: This is Brad Edwards. III take a copy. I dent need a mini, ASCII or anything else. I'll take a copy since Mr. Pike ordered it. MR. MERMELSTEIN: This is Stuart Mermelstein. I'm not going to order at the present time. Thank you. (At 10:59 am. no further questions were propounded to the witness.) Page 75 1 THE WITNESS: No, sir. 2 MR. EDWARDS: Okay. All right. 1 appreciate 3 your tirne. That's all Fve got. 4 THE WITNESS: Okay. 5 MR. MERMELSTEIN: This is Stuart Mermelstein. 6 1 have no questions. 7 MR. PIKE: Okay. Ma'am, you have the option 8 to read your deposition or waive that right. If you 9 choose to read your deposition, you will be provided 10 with a sheet called an errata sheet. You can read 11 your deposition and look for corrections that you 12 may find that were incorrect, or you can waive that 13 right today if you feel that the testimony you have 14 given today is truthful and you do not want to read 15 your deposition to make any corrections. 16 THE WITNESS: I believe it's truthful but I 17 could reread it if — I don't know. I mean, 18 everything I said is truthful but — 19 MR. PIKE: It's really your choice. You can 20 read it or you can waive that right 21 THE WITNESS: I don't know. I'll waive it. 22 MR. PIKE: Okay. Thank you very much. 23 THE REPORTER: This is the court reporter. 24 Does anybody need this transcript? MR. PIKE: Yes. I do, Michael Pike. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Page 77 CERTIFICATE OF REPORTER STATE OF FLORIDA ) COUNTY OF HIUSBOROUGH) LIvEchelkOlstmBacWI,RPR,O:11Whalwas authorized to and did stenographically report the deposition; that a review of the transcript was not requested; and that the foregoing pages are a true and complete record of my stenographic notes taken during said deposition. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am 1 a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 24th day of May, 2010. Michelle Olsen Baden 24 Registered Professional Reporter Florida Professional Reporter 25 PROSE COURT REPORTING AGENCY, Electronically signed by Michelle Baden 20 (Pages 74 to 77) INC. as3d09504$36-4(4441I18-6434issacs69 EFTA00724294 Page 78 CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF HILLSBOROUGH) 3 4 5 6 I, the undersigned authority, certify that 7 the witness in this matter personally appeared before me 8 and was duly sworn on the 1 1th day of May, 2010. 9 10 WITNESS my hand and official seal this 24th of 11 May, 2010. 12 13 14 15 16 17 18 19 Nebel's Olsen Baden, R Notary Public 20 State of Florida at Large My Commission Number. DD537984 21. Expires: 6/20/2010 22 23 24 25 21 (Page 78) PROSE COURT REPORTING AGENCY, INC. EJectronically signed by Michelle Baden IMIE=Ib a53d0950-b535-414d-8f18-6434195ac559 EFTA00724295