Text extracted via OCR from the original document. May contain errors from the scanning process.
J. MICHAEL BURMAN. PA"
ROBERT D. CRITTON. JR.. PA'
MICHAEL J. PIKE
DAVID YAREMA
'FLORIDA BOARD CERTIFIED CIVIL TRIAL LAWYER
2ADMITTED TO PRACTICE IN EIORIDA AND COLORADO
Sent by E-Mail Only
Robert Josefsber , Es
Re:
Epstein Matter
Dear Bob:
BURMAN, CRITTON
YOUR
TRUSTED
ADVOCATES
August 28, 2009
PAIALLGAL/INvESTIGATOR
JESSICA CADWELL
BETTY STOKES
RAPALEGALS
RITA H. BUDNYK
OF COUNSEL
ED RICCI
COUNSEL
SPECIAL
JUSTICE
I am enclosing a copy of the taped interview of
which I believed
was taken in 2005 by Det. Recarey. As you will note, the tape was transcribed by a
court re
der who listened to the tape. Additionally, I am providing you the statement of
which was taken by Jack Goldberger with Lily Sanchez present on March
21, 2008.
is demanding $250,000. I believe after you read her statement,
you will be able to conclude she never should have been placed on the list in the first
place and has no valid claim; her words, her sworn testimony and given in 2005.
In reviewin
statement, it is significant as to her willingness to lie
about her age (wit
insistence), she said that she was 17.9 years old; and
everything she did, was 100% consensual. She said there was never force, coercion
and she was always comfortable around Mr. Epstein. This leads one to belie
•
claim also should not exist. She also casts substantial doubt on any claim of
These statements are being provided to you in furtherance of our settlement
discussions, prior agreement and are completely confidential and privileged under both
state and federal law and applicable statutes.
PHONE:
• FAX:
• MAI 10BC1CLAW.COM
WiArW.BUCLAW.COM
EFTA01075901
August 28. 2009
Page 2
Please let me know if you will be able to get the information that we have
requested re: the prior USAO lists so as to continue our good faith dialogue and
exchange of information.
Cord
Robe D. Critton, Jr.
RDC/clz
Enclosure
EFTA01075902
Page
Sandy Rossi
Notary Public, State of Florida
Consor and Associates
3. Censor &
•
•
Transcription
EFTA01075903
Page 2
1
r- --(Thereupon, the following interview was had:)
2
_
_
3
4
5
6
7
as when you met Mr. Epstein.
8
A
As soon as (inaudible) house. And
and
9
10
11
12
13
14
15
16
a week later I had gone with
and it was me and her in
17
the room with him and it was kind of weird because he's
18
naked but she's like oh, he's always like that, don't worry
19
about it. And then we just gave him a massage and he gave
20
her $200 and he gave me $300 and he asked me to come back.
21
So I'm like okay. I came back about probably about five or
22
six times.
23
Q
Okay. He gave you 300 to do a massage, right?
24
A
Uh-huh.
25
Q
Okay. And that was about a year ago?
Q
-- say nothing but the truth so help you God?
A
Yeah.
Q
All right. So tell me from the beginning as far
were (inaudible). I'm like what are you guys talking
about? And I hadn't really hung out with them. I was kind
of with the redneck crowd. They're the preppy girl crowd.
And they were telling me about this guy and they would go
and give him massages and he'd pay them $200 for giving a
massage for an hour. And they said do you want to do it and
I'm like yeah, $200 for an hour, let's go. So I think about
J. Consor & As
ranscription
EFTA01075904
Page 3
1
A
Yeah.
2
0
Okay. You were approached about this by Faith and
3
4
A
Uh-huh.
5
Q
Okay.
what's her last name?
6
7
V.
8
9
10
11
12
13
14
15
16
17
18
Q
Okay.
19
A
And I gave him a massage in my bra and underwear.
20
21
22
23
24
did the massage take place?
25
A
A
Valdez or Vas -- I don't know. It begins with a
Okay. All right. Let's start back from the
beginning on the massage. He was naked on the massage?
A
Yes, with a towel over him.
Q
Okay. How were you dressed when you were
providing the massage?
A
I think jeans and a tank top.
Q
Jeans and a tank top. At any time did he ask you
to remove your clothing?
A
He did probably about the third time that I went
there.
Q
Just your underwear. Okay.
A
That's why I stopped going because he said if you
start to feel uncomfortable just (inaudible) anymore.
0
Okay. When you were giving him the massage, where
Like if you go upstairs into his bedroom like his
1
Consor 8,e As
Transcription
EFTA01075905
Page 4
1
bathroom I guess like there's this big room with like a
2
sauna and a shower and in there.
3
Q
Okay. Were there a table already set up?
4
A
Sometimes it was already set up and then sometimes
5
when we went up there there's like a little closet and the
6
table is in the closet and we'd bring it out and set it up.
7
Q
Did you set it up or --
8
A
Yes.
9
Q
-- did somebody else set it up for you?
10
A
Sometimes it was already set up when we got there.
11
Q
Okay.
12
A
Sometimes I had to set it up.
13
Q
Okay. How were you taken to the bedroom area?
14
A
Usually
would lead you up but after you were
15
there a couple times she'd say go on up.
16
0
Okay. And you went what, five to six times?
17
A
Yeah.
18
Q
Okay. All right. Let's get back to your first
19
massage you gave. He was wrapped in a towel.
20
A
Uh-huh.
21
Q
Okay. At any time did he take off the towel?
22
A
Only when he got up and put a robe around him.
23
Q
Okay. During the time you were providing him a
24
massage, did he ever touch himself?
25
A
No. He was laying on his stomach.
I
i
•
J. Consor & As
"
Transcription
EFTA01075906
1
Q
Page 5
Laying on his stomach the entire time?
2
A
Yeah.
3
Q
Okay. Did he ever ask you to rub his chest?
4
A
Yes.
5
Q
Okay.
6
A
But not the first time.
7
Q
Not the first time. You just massaged his
8
A
His legs and his feet the first time.
9
Q
Okay. Feet and --
10
A
Shasdy massaged his back and I massaged his feet.
11
Q
Okay. So the first time Shasdy and you did the
12
massage?
13
A
Uh-huh.
14
Q
Okay. All right. And you were completely
15
clothed?
16
A
Yes.
17
Q
Okay. Did he touch you --
18
A
No.
19
Q
-- during the massage?
20
A
No.
21
Q
No. Was there any massagers slash vibrators
22 introduced into the massage?
23
A
No. Just like he had like this massage cream from
24
Bath and Body Works I think it was from. That's it. And
25
I'd use that.
J. Consor & As
•
Transcription
EFTA01075907
Page 6
1
2
how were you contacted?
3
4
5
6
7
8
9
10
Q.
Okay. When the second time you went, how did you,
A
Asked -- when he asked -- when he gave me $300 and
asked me to come back, I had left him my cell phone number.
Q
Okay.
A
Andillillicalled me and told me that Jeff had
wanted me to come back and then I went down there.
Q
Okay. Do you recall when this was?
A
No. I know it started like this time last year
because I think about January is the last time I went when I
11
met my boyfriend and he didn't want me going down there.
12
13
went?
14
A
Yeah.
15
16
to come --
17
A
(Inaudible.)
18
Q
-- tells you to come to the house to provide, to
19
work?
20
A
Uh-huh.
21
Q
Did anything happen during that massage?
22
A
No. The only thing he ever did was he tried to
23
grab my butt and I told him I didn't feel comfortable with
24
that and he always said that if you didn't feel comfortable
25
just to let him know. He didn't want you to feel
Q
So January of this year was the last time you
Q
Okay. All right. So she calls you and tells you
J. Consor &
Transcription
EFTA01075908
Page 7
1
uncomfortable.
2
Q
Was that on the second massage?
3
A
No. Probably about towards the end because I was
4
fully clothed until the third massage.
5
0
Okay.
6
A
That was the massage. That's when just I did it
7
in my bra and underwear. And then after that is when I
8
started feeling uncomfortable with it because he was like
why don't you take that off and I was like no. And then
10
just -- he never pressured me. He never forced me to do
11
anything. But he would like try to talk you into it and I
12
didn't feel comfortable with it.
13
0
Okay. So you recall both -- the first two times?
14
A
Uh-huh.
15
Q
Did he touch himself during the second massage?
16
A
I guess kinda he would sometimes.
17
Q
What do you mean?
18
A
Well not -- like towards the end when I was in my
18
bra and underwear like sometimes when I would be rubbing his
20
chest then he would.
21
Q
Okay. Did he do it on the second time you went?
22
A
No.
23
Q
Okay. The third time you went, how were you
24
contacted to go?
25
A
called me again.
1 Consor &
Transcription
EFTA01075909
Page 8
called you again?
2
3
your clothing?
4
5
6
7
8
9
10
11
12
his chest?
13
A
Yes.
14
15
masturbate?
16
17
18
19
20
21
22
23
also. Would you like something to drink?
24
Q
No, I'm good. I'm good.
25
Okay. When you got there he asked you to remove
A
Yeah.
Q.
Okay. When you say panties, were they normal
panties or were they
A
A thong.
Q
A thong.
Okay. You provided the massage?.
A
Uh-huh.
Q
And this was the first time that he had you rub
Q
Okay. While you were rubbing his chest, did he
A
Yes.
Q
Okay.
A
But this is towards the end.
Q
Okay. Towards the end of the massage?
A
No, like towards like the last time I went there.
Q
Okay.
A
But yeah, it was towards the end of the massage
A
Okay. I've lost all my manners. (Inaudible.)
I
3. Consor &
'
& Transcription
EFTA01075910
Page 9
That's okay. Do you know if he climaxed?
A
I don't know. He still had the towel over him.
Q
He never removed the towel?
4
A
No. Judging by the his breathing I would think
that he did but I never asked if he did.
6
Q
And do you know what I mean when I say
7
masturbate --
8
A
Yes.
9
Q
-- and climax?
10
A
Yes.
11
Q
Okay. All right. So each time you went to the
12
house, at what point did he try to escalate to more than
13
just a massage?
14
A
Like it would start out as a normal massage and
15
he'd like sit down and talk to you and stuff and then he'd
16
be like oh, well come here and do this or do that and he's
17
like if you told him no he wouldn't, you know, he wouldn't
18
make a big deal out of it. If you told him you felt
19
uncomfortable about anything then --
20
Q
Okay. when did he grab your buttocks?
21
A
I don't know. One of the times I was giving a
22
massage. X really can't --
23
Q
Okay. Did he ever grab more than just your
24
buttocks?
25
A
No, because I made it clear when he did that that
3. Consor & Asso '
s
e
rtin
Transcription
EFTA01075911
Page 10
1 - I was very uncomfortable and I left.
2
Q
Okay. Did he ever touch your breasts?
3
A
No.
4
Q
Okay. Did he ever touch your vagina area?
5
A
No.
6
Q
Okay. Did he ever bring out any kind of sexual
7
toys?
8
A
No.
9
Q
When was the last time you were contacted by
10
anybody at the Epstein (inaudible)?
11
A
The last time I went there because I told him that
12
I wasn't coming back.
13
Q
Okay. So January 2005 approximately?
14
A
Yes.
15
Q
The very last time you went, did he, did he
16
continue like when you were giving him a massage,
17
masturbate?
18
A
No, because I was giving him the massage and I
19
kept looking at the clock on the sink and I was looking at
20
the clock and he was like why do you keep looking at the
21
clock? And I was like I don't know and I was like because
22
my boyfriend is waiting to come pick me up and he's like
23
well, he's like he said you're supposed to make me enjoy my
24
massage right now. He said you're not supposed to be
25
looking at the clock. And I was like well, and he's like if
Transcription
EFTA01075912
Page 11
1
you don't want to do this then you don't have to do it and
2
that's when I told him I don't want to come back anymore
3
because I really don't feel comfortable and, you know, my
boyfriend doesn't like that I'm coming here. And then that
was it and I haven't spoken to him since.
Q
On top of the $300 did he ever offer you more
money?
A
No. He gave me money for Christmas. He Western
4
5
6
7
8
9
Unioned I think it was like $200 as a Christmas present but
10
other than that, that's it.
11
Q
For last Christmas?
12
A
Yes.
13
Q
What -- which Western Union did you pick that up
14
at?
15
A
The one in Royal Palm and Okeechobee. I think
16
it's in The Check Cashing Store. There's a Western Union
17
there.
18
0
Okay. Did you ever take anybody to the house?
19
A
No. Nobody that I hung out with knew about that.
20
Q
Okay. Was there anybody else in the room when you
21
were providing massage --
22
A
No.
23
0
-- aside from
24
A
Aside from_no.
25
Q
Okay. No other assistants?
J. Consor & Associates Re ortin & Transcription
EFTA01075913
Page 12
1
2
3
4
5
A
No.
Q
Okay. Did he ever offer you monies to go
further --
A
No.
Q
-- than just a massage?
6
Okay. How old were you when you first went there?
7
A
Seventeen.
8
Q
Seventeen.
9
A
And I was 17 the last time I went there too.
10
just turned 18 this past June.
11
12
13
14
15
16
A
No. They just told me that we were going to do a
17
massage.
18
Q
Okay. All right. You were attending Royal Palm
19
Beach High School --
20
21
22
23
24
25
When did you turn 18?
A
June that just passed.
Q
June that just passed?
Did Shasdy ever tell you that you would have to
provide the massage naked or --
A
Yes.
Q
-- okay, at the time?
A
Kinds. I kind of dropped out right in the middle.
Q
Okay. Did you ever finish school?
A
No. Actually tomorrow is my GED test.
Q
Well good luck with that.
I
I
4
1
I
3. Consor & Associates Re orting & Transcription
EFTA01075914
Page 13
A
-Thank you. I fell in love, moved to Jupiter, it
2
didn't last forever, blah, blab, blah.
3
Q
This is the guy that didn't want you going back
4
anymore?
5
A
Yeah. Yeah.
6
Q
You guys aren't together anymore?
7
A
It's off and on. We got engaged. We were
together off and on for nine years so (inaudible).
9
Q
I guess the best thing he did was have you stop
10
going.
11
A
Yeah.
12
Q
Is there anything else you would like to add?
13
A
No. I actually have some questions as to what's
14
going on with this.
15
Q
well, this is an ongoing investigation. We
16
received a complaint and we're following it up. Obviously
17
based on the questions that I've asked you, you can pretty
18
much figure out what this is --
19
A
Yeah. Is Jeffrey in custody?
20
Q
Not at this time. But this is an ongoing
21
investigation so I would appreciate that if anybody contacts
22
you, I know that friends have been calling each other and
23
telling them oh my God, there's a cop here, whatever, asking
24
me questions.
25
A
Yeah, this is Royal Palm. That's big news in this
J. Consor & Asso •
• 9 & Transcription
EFTA01075915
Page 14
1
2
3
4
5
6
little town.
Q
Well, I would appreciate it if you didn't, you
know, say anything what we discussed. Especially if
calls you or anybody else calls you, you could say that I
Was here and if they have any questions they can give me a
call. Obviously if anybody from the -- Jeffrey's house
7
calls you, I'd also appreciate it if you call back and let
8
me know.
9
A
Okay.
10
Q
All right?
11
A
All right.
12
DETECTIVE RECAREY: At this time I'm going to
13
go ahead and conclude this tape. The time on my
14
watch is 12:45.
15
(Thereupon, the interview ended.)
16
- - -
17
18
19
20
21
22
23
24
25
I
I
1
J. Consor &
Transcription
EFTA01075916
Page 15
1
C
E
R
.T
I
F
I
C
A
T
E
2
3 STATE OF FLORIDA
4
5
I, Sandra Rossi, Court Reporter, State of
Florida at Large, certify that I was authorized to
6
and did stenographically report the forgoing
proceedings, and that the transcript is a true and
7
complete record of the tape as listened to by me.
8
9
Dated this 30th day of January, 2007.
10
11
Sandra Rossi, Court Reporter
12
13
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17
18
19
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3. Consor & Ass
•
Transcription
EFTA01075917
CD
nsor & Associates
Ropacting And Trznsc iptia.. Inc.
1 (Pages 1 to 4)
Page 1
)
)
IN RE:
SWAN 51
76-
IN
TEPI NT
Friday, March 21, 2008
4:00 p.m. - 4:20 p.m.
Reported BY:
Judith F. Caw, FPR
Notary Public, State of Honda
.Connor & Associates Reporting and Teanstription
West P
Phone tie
APPEARANCES:
2
On behalf of the Defendant
3
JACK A. GOLDBEItGER, ESQ.
. ton:
• Y. D:
. '41N
6
ALSO PRESENT
7
8
9
10
17
12
13
14
15
16
17
18
19
20
21
22
23
24
2s
.. • .% •
en
11.•aeou • 4s. • • ..
3
What %tiro going to do today is we're going
4
to MIT Winn !MOW as a swan statement from you. And
s
my Court reporter just put you Under oath. So all l want
6
yon to dos tell the absolute truth today.
7
A. Right
Q. I dont want you to color what you're
saying in any way. Really, the only thing that will be
It)
of any use to anyone is if you just tell the absolute
II
truth.
A. Right.
13
Q. So those are the irstruedous, okay?
14
A. Okay.
s
Q. All right. And sometimes — I've been
16
doing this for a lot of yean and sometimes I talk hire a
lawyer too much, and if you don't understand what I'm —
A. That's yourjob.
19
Q. I guess. But if you don't understand what
20
I'm saying at some point, just say, lack, say it in
21
English," and I'll make It better for you. OW
22
A. Okay.
23
Q. So tell me hcrw you first metJeffrey
24
25
. A.
introduced me to him.
.
Page 3
Statement taken before Judith F. Cotner,
2
Court Reporter and Nowt' Public in and for the State of
Florida at large, in the above came.
4
llmmupon
6
7
a
9
10
12
13
14
IS
16
17
18
19
20
21
22
23
24
25
Page 2
having been first duly sworn or affirmed, was examined
and staled as follows:
THE WITNESS: I do.
Q. Would you state your arra for the record,
pkam.
A.
Q.
where do you live now?
A. Address?
Q. Sure.
Q. Do you live there alone or do you live with
somebody there?
A. My father.
Q. Very good. And arc you working now or not
working? Sometimes you murk and sometinrs you dont?
A. When I want to.
Q. Okay. And bow old are you today?
1
A. Twenty-Dot
2
Q. Very good.
Page 4
12
17
18
•
EFTA01075918
O
O
*
nsor & Associates
-Roperriagand Tesestription,
9•••••• •
_.r. el...., .
2 (Pages 5 to 8$
2
3
6
7
a
9
to
12
13
14
IS
16
17
Is
19
20
21
22
23
24
25
Page 5
Q. Ana
was a friend of yours at the
time?
A. Yes.
Q. Okay. And tell me a link bit about the
introduction, has= introduced you to Jeffrey.
A. Well, she told me that I amid go over
there and give him a massage --
Q. Okay.
A. — and be'd pay me for it and that he was a
164µ4.11111 guy.
Q. Okay. So let's break that down a little
bit.
She told you you could go ova them to
Jeffrey Epstein's house and give a massage?
A. Rif*
Q. When she said go give & massage did she
tell you what she meant by that?
A. Jost am— no. Just a message She didn't
really give me my details.
Q. Okay. Let me ask it to you another way.
A. Okay.
Q. Was there any suggestion that what you were
being offered the oppatuniy to do would be sexual in
any way?
A. No.
2
3
4
6
7
a
9
IC
11
12
13
14
IS
16
17
IS
19
20
21
22
23
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Page 7
A. No.
Q. And she didn't e-mil you oboe that?
A. No.
Q. She didn't send you a text message like you
guys do?
A. No.
Q. Okay. Shejam simply saw you in person
one day and said, "Do you wane go over to
Mr. Epstein's home and do a massager
A. Yes.
Q. And I take it you said okay and you went
over there?
A. Yes.
Q. Ail right. Now at the time that you went
over there, you were not yet 18, but you were ahnost 18?
A. Yes.
Q. You were within *couple of months of being
18 years old?
A. Yes, I do believe so.
Q. Okay. And what didMedi you about if
asked, how old you should tell anyone you were when you
were ova to his house?
Was that a bad question?
A. Repeat that.
Q. Sure. Okay.
Page 6
Q. Okay. So as far as you tmderstood it and
2
a far as whatM told you, you would be going ovate
3
Mr. Epstein's house and just giving him a normal
4
theraponie massage?
A. Right.
6
Q. Okay. And I asume=told you you would
7
be paid fair?
a
A. Yes.
9
Q. Did she tell you how much you would be
to
paid?
it
A. Yes. Two hundred.
12
Q. Okay. When was the first time that you
13
went tolefty Epeteln's house? Was it after you spoke
14
to Alex?
1 s
A. Yes.
16
Q. Okay. And the fine time that you was to
17
Mr. Epstein's house, that was in response a
18
talking to you person. In aher wends, she said --
19
you saw her somewhat, be it at the store that you worked
20
at or around the TAighbahool, she said to you in person,
'Do you want to go over to Jeffrey Epstein's house?'
22
Right?
23
A. Q11-bah.
24
Q.
She didn't call you oldie witch= cod
offer you the opportunity? , . .
„
!
1
2
3
4
6
7
10
II
12
14
IS
16
17
IS
19
A. Right.
20
Q. By the way, were you ma asked?
21
A. Eventually.
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Q May.
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A. Not the first day, I don't believe.
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Q. Okay. Was it leaky or someone else that
..2$
Page 8
Before you twat over to Jeffreys house
aft you out Ala In ;ascot did she tell you if anyone
asked you how old you were, how old you were supposed to
say you wad
A. Yes.
Q. What did she tell you?
A. Yes. She told me to say that l was 181f
it was asked.
Q. She didn't &he you a saipt and say as
moo as you walk to the house you're supposed to say,
'ho 18,• right?
A. No.
Q. She just said that if anyone ever asked,
you should say that you were 18 years of age.
A. Right.
Q And I assume if you were asked, you wanted
to be convincing that you \v at over the age of 18,
because you wanted to do the work, right?
_asked ra wbetha youwereover the age of 18? ..
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A. It was probably Jeffrey. I don't remember
2
very dearly.
3
Q. Whoever asked you, though, you dearly said
4
when asked, 'Pin lg."
A. Oh-huh.
Q. And you were very believable in saying that
you Imre over 18?
A. Yes.
Q. Okay. Now the first time that you went to
Jeffrey's house did you give him a massage that dry?
A. Lit-inah.
Answer yes or no so the
record is clear.
THE WITNESS: Yes. Okay.
(Discussion held off the record.)
Q. Okay. So you go to Jeffrey's house and you
moat him and you're going to do a massage that day,
right?
A. Yes.
Q. Now were you -• you were not forced to give
a massage, correct? '
A. No.
Q. You were not forced to do anything that you
didn't want to do?
Page 11
Q. The reason you went there Isbecause=
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■told
you in person
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A. Yes,
4
Q. — that if you wanted to—ituasall
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voluntary on your part — you could go to Jeffrey's house
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and give him a massage.
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A. Right
8
Q. Okay. So did Alex tell you what to expect
9
when you went there, es far as keeping your clothes on cc
ID
taking your clothes of!?
tt
A. ffne did say that he may ask me to take my
12
clothes off and that he was very respectful about that
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and that if l didnI feel comfortable about it that I
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didn't have W.
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Q. All right.
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A. it was no problem. He wouldn't be upset.
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Q. Alt right So Alex told you there would be
is
no pressure on you whatsoever?
9
A. Right.
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Q. Wu simply did what yea warded to do?
21
A. Yes.
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Q. And if you didn't wtalt to do saneding, you
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were free to say, "No. I daft want to do
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A. Yes.
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Q. All right And lures experiences with
Page 10
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A. Right.
2
Q. No one coerced you or threatened you in any
3
way?
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A. Noway.
Q. No one offered you any drugs io do a
6
massage?
7
A
No-
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Q No one offered you any alcohol to do a
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message?
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A. No.
Q And prior to going over to Jeffrey's house
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the fro time there was no e-mail message from him?
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A. No.
Q. In any way?
A. No way.
Q. There was no text mail message from him?
A. No.
Q. There was no fax from him?
A. No.
Q. Okay. And the same gondol= There W2S
no e-mail from anyone that worked for Jeffrey before you
went over there?
A. No,
Q. No text menages from anybody?
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Page 12
Mr. Epstein, by the way, solo there ever a time when that
didn't play out, when he tried to force you to do
something that you didn't want to do?
A He never tried to force me to do anything.
Q. If you said no to something. whatever that
might be, he would respect that?
A Yes.
Q. Affright
Now the first time that yea went there do
you remember whether you gave Jeffrey a massage with your
clothes on or your clothes off?
A. At the begirsing, it was with a3 my
clothes on.
Q. til-huh.
A But the most Out
I mean' was satin
my bra and panties.
Q. Okay. The whole time?
A. Yes.
Q. Right.
A. I'm pretty sure, yes.
Q. Did you see during that manage -. did he
try and touch you in wry way during that massage?
A. No.
Q. Did he use any kind of device on you in any
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Page 13
A. No.
2
Q. Do you know -- he vms wearing a towel
3
though that massage?
4
A. Yes.
5
Q. Do you know whether he touched himself in
6
any way, his penis or anything like that, during the
massage?
A. Yeah, like towards the end.
Q. Okay. Do you know whether he masturbated?
A Oh, Milo&
Q. If you don't know, you don't know.
A I mean probably, but I don't know. I can't
remember cannily. It was so long ago.
Q. Okay. There was nothing that you were
muomfortabk with in this massage?
A. No. Yeah. And Iftte I said, he also, you
know, reassured ill wasn't comfortable with anything,
then just tell him and —
Q. He would stop?
A.
that would Ix the end of it.
Q. Okay. Now after that !lost tint you met at
Wirers horse, you left. And did there come other
times that you went to Jeffreys house?
A. Yes.
Q. And how would fiat come How would that
Page 15
massage or not?
2
A. Yee, It was ahveys that.
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Q. Obw• And there was never any discussice,
4
'Well, we really wet you to caw over because we want .
you to have sex with Jeffrey," or anything like that?
6
A. Right. Noway.
Q. Never, ever suggested, right?
A. No.
9
Q. Okay. The only thing that ever occurred on
10
any of these phone calls was, "Are you willing to come
it
over," or, "Would you hie to come ova and give a
12
massage?"
13
A. Right.
la
Q. Okay. And emplane calls from Jeffrey —
is
well, you never spoke to Jeffrey on the phone, right?
16
A. No.
17
Q. Okay. The phone call frosn Sara or any
Is
other assistant would always it would be sporadic,
19
right? They always said, "Jeffreys going to be in town.
20
Do you want to r
over this afternoon at four o'clock7
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A. Yeah, yeah. It wasn't
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Q. There was nothing regular about it?
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k
No.
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Q. Okay. Other than Sara, who else would have
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called you to ask whether you wanted to acme ova and
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happen?
A San, one of his assinanu, would call me
and ask me if I wad Ida to cocoa over and give a
massage, because he would be in tan.
Q. So would it be primarily Sara that would
call or would there be others?
A. Most of the time.
Q. And would it be a message that would be
left for you or would it be you would talk to Sara or me
of the other as assistants directly?
A. I mean generally it would be directly.
Q. ObaY
A. Unless] didn't answer my phone.
Q. And if think I tradastaod what you're
saying, you would talk to San or another assistant and
they would say, "Listen, Jeffrey's going to be in am.
Would you like to come over and give a massage? Right?
A. Yes.
Q. Was there es= any suggestion in any of
those phone calls where you made arrangements to go to
Jeffreys home that there would be anything sexual that
would occur at the house?
A. No.
Q. Was it always if there was a plime call,
that this was whether you warned to come and give
Page 16
1
give a massage?
A. If it wasn't Sin, then Malaya Adriana,
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maybe one other person I don't know the name of. Just -
4
ITC= it was mostly Sn. And Adriaoa I spoke to a time
s
or two.
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Q. Okay. Now when you would go over to
7
Jeffrey's house after getting a phone call, you would go
s
and you'd go to give him a nuusage, right?
9
A. Yes.
1 o
Q. And oma4tratly would there be more than a
I 1
massage that occurred?
12
A It happened a few times.
13
Q. Okay. And the few times that it happened,
4
though, it was very sporadic and it was nothing that was
IS
planned?
is
A. Noway.
17
Q. It just occurred?
Is
A. Right.
I9
Q. So it wasn't like there was a phone call,
z o
you km, 'Today we want you to come ova and do mere
21
112811 just a =saw with Jeffrey"?
22
A. Right.
23
Q.
When anything more occurred you'd be over
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there and it would be totally voluntary en your pert?
.. A Yes; definftebi consensuaL
,
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Q. Okay. Now when we're talking about more
2
then Just a massage, what sort of conduct are we talking
3
about that might have occurred?
4
A. It was probably mostly — maybe nee, not
$
particularly cud, but, I mean there's just random
6
things, but not sex.
7
Q. Okay. So let's put it into perspective.
a
You certainly neva had intercourse with him, right?
9
A. No.
t 0
Q. And did you actually ever really have oral
sex with him?
12
A. Maybe once or twice. I barely even
13
remember eat.
14
Q. Okay.
s
A. I mean it was all just mostly —
16
Q. I'm sorry. Mostly what?
I 7
A. Mostly like hand oriented
18
Q. Okay. So on occasion you would touch his
19
penis with your hand?
20
A. Ifs hapctned a few times.
21
Q. Okay. And anytime that termed it would
22
be totally vohnitery on your part?
23
A. Yes.
24
Q. Consensual cc your pat?
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A. Yes. He would never make me do anything.
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to make was that there were never phone calls that would
come to you and they would ay, 'Do you want to cane ova
and give a massage,' and per just assumed it would be to
go have sex? That was not the ease?
A. No.
Q. Never, never, neva, right?
A. Yes.
Q. All tight There were times when you would
be away and not be In Palm Beach and —I moan you very
much thought that Jeffrey was your Mend? You tread
him as a friend?
A. Yes, definitely. 1 kb that le was my
friend
Q. And them were times when maybe you were
out of town and for whatever reason, you found yourself
in a situation where yea needed some money, cermet?
A. Yes.
Q. Okay. And you felt that the relationship
was such that you could call Jeffrey and it nova had
anything to do with a massage or anything. You would
say, "Listen, l could use a mule of dollies. I have a
problem."
A. Yes.
Q. And would be ever hesitate to help you out?
A. No.
Page 18
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Q. And it would jest be totally random and it
2
would occur during the moment?
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A. Ub-buli.
4
Q. Okay. There was nothing that was planned
in advance concerning that?
A. Na
Q. And it didn't become every time you went
ova there that would happen, right?-
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A. Ye& No.
to
Q. No, no. I menial* you would go ova and
11
give a massage one day end the please call would be the
12
same, 'Do you want to come over and give a massage,' and
13
maybe
14
A. Yes.
Is
Q.
— maytc another time you would get a phone
la
call, 'Do you want to cane over sod give a massage,' and
17
jUSt tecause of the clay it was as whatever was going on,
is
it may have gone a link tether where they may have
19
been some touching. correct?
20
A. Right.
21
Q. And then the next time you could go over
72
there and it could have been a regular massage again,
23
right?
24
A. 1Jb-huh,
25
•
a Okay; so the ktint that l guess rat trying
Page 20
Q. And in fact, did he not tell you that,
2
Men —he would talk to you about life and about
3
A.
4
Q.
S
life?
6
A. Yes.
Yes.
- about vibe you warned to do with your
Q. And he said, "If yeti ever find yourself in
troubk, you have a friend in me and you can give me a
9
car?
10
A. Yes.
ii
Q. Okay. If you had to guess
and
2
recognizing that them can be no accuracy hat — if you
to
had to guess, how many time do you think you want ova
14
to Jeffrey's house?
is
A. !would say at least five, less than ter
16
Q. Okay. I think that's kind of a fair range.
17
And diring those five to ten times that you
is
went there, was there ever anything uncomforiable, ht
19
your mind, that occurred over at Jeffrey's borne?
20
A. No.
2 t
Q. Okay. I know we've touched on this, but
22
just UIly, the detail person, makes sum that we get
23
everything. After you met Jeffrey the first time did you
24
aver talk to Idol 00 the telephone about arranging
25
massage cr anything lice thaa . .
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A. No.
Q. Okay. And you never e-mailed him or
3
anything like that?
A. No, no.
5
Q. Never tow-messaged him?
6
A. Na
7
Q. Okay. Now st times when you would go over
a
to give a massage, Jeffrey, while he was getting the
massage, would be preoccupied doing a lot of things,
o
right?
A. Yes, very often.
12
Q. He was a busy guy?
I.3
A. Yes.
14
Q. He would be on the telephone talking to
s
folks addle you were giving a massage?
16
A. Yes. Sometimes it would be just a massage
17
and had be pretty much doing business the whole time.
is
Q. Right. Certainly it wasn't sex or anything
19
bla thee?
20
A. No.
21
Q. He would be doing busiress and you'd be
22
massaging him?
23
A. Yes.
24
Q. Okay. Give me one second.
25
(Discussion held off the record.)
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Q. Okay. I assume, based on what you're
telling me, Jeffrey didn't know at the time that it was
your 18th birthday. He must have —
A. No. It was kind of like -- it was my 19th
birthday.
Q. Okay. And you made it pretty clear to him
that it was your 19th birthday end not your 18th
birthday?
A. Yeah I tried not to like even touch upon
that.
Q. But I !mow you didn't try and touch upon
it —
A. Yes.
Q.
— but was it clear to him, based on what
you know, that he thought it was your 19th birthday?
A. Yes.
Q. Okay. Great.
Hae's the lawyer talking now.
1 didn't try to influence you in any way to
say anything, did II
A. No.
Q. ha fad, all I asked you to do is tell me
the absolute truth here today?
A. Yes.
Q. And that's what you've done?
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Q. Every time you went back to Jeftley's house
you went back there because you wanted to, right?
A. inshula yes.
Q. No one — certainly Mr. Epstein never tried
to persuade you or induce you or entice you or coerce you
to engage in any kind of sex?
A. No.
Q. And no one representing Jeffrey Epstein
ever tried to persuade or induce you to engage in sex?
A. No.
Q. Ali right. And I think you told me when we
rust started talking that you "etc wry, wry close to
your 18th birthday, and when asked, you in fact said you
were 16 and tried to be wry, wry convincing of that.
A. Yeah. I didn't mean that - all I said was
1 was 18.
Q. Okay.
A. Law there was no ifs, ands or buts about
that
Q. There was a time when there was 0 concert
or a show down in Fort Lauderdale and Jeffrey got you
tickets to go to that show because it was your birthday,
right?
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A. Yes.
Q. Okay. And you've understood all my
questions, have you?
A. Yes.
MR. OOLDBERGI3R: Okay. I thank you very
much for corning in today and it really made it
much easier for us to do it this way. So thanks a
iot.
(Thereupon, the sworn sonement was
concluded at 4:20 p.m.)
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