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Page 158 Page 160 APPEARANCES: 2 On behalf of the Plaintiff.: 3 SPENCER KUM, ESQUIRE LEOPOLD KUVIN, P.A 2925 POA Boulevard, Suite 200 Palm Florida 33410 Phone t On behalf 71ILMIrMane Does 24: 7 ADAM HORMEL, ESQUIRE MRMELSTEIN & HOROWITZ, PA 18205 Biscayne Boulevard Suite 2218 9 Miami Phone: 10 1.1 On behalf of Plaintiff Carolyn Andnono 12 TACK Hal, ESQUIRE SEARCY, DENNEY. SCAROIA, BARNHART & SHIPLEY, PA 13 2139 Palm Beach Lakes Boulevard West till ride 33409 14 Phone; 15 RICHARD/MATS, ESQUIRE (via telephone) RICHARD H. WILLITS, P.A. 16 229010th Avenue North, Suite 404 Lake WS3461 17 Phone 18 On behalf o the Defendant 19 ROBERT CRITTON, ESQUIRE BURMAN, CRITTON, LIMIER & COLEMAN 20 515 Nonh Wet Drive Suite 400 21 West Ptrida 33401 Phone: 22 23 24 25 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROCEEDINGS - - (Continued from Volume I.) VIDEOGRAPHER: We're back on the video record. This is the beginning of tape number three. The time is 3:02 p.m BY MR. KUVTN: Q. Okay. Let me do it this way, so we can just back up a little bit. Ms. you're aware that girls, including my client, have sued Jeffrey Epstein in civil lawsuits, correct? A. Yes. Q. All right. Arc you also aware that one of the defenses has been that these girls volunteered to go to the house so, therefore, what are they complaining about? Are you aware of that? A. Yes, I am. Q. Okay. You feel that way yourself? A. Absolutely. Q. Because you volunteered to go, right? A. Absolutely. Q. And you haven't sued Mr. Epstein, have you? A. I have no intentions of that. Q. Did you contemplate it at one point? Page 159 1 On behalf of the Witness: 2 DOUGLAS MCINTOSH, ESQUIRE CAMILLE E. BLANTON, ESQUIRE 3 MCINTOSH, SAWRAN, PELTZ & CARTAYA, PA. 1601 Forum Place 4 Suite 1110 West Pal Fonda 33401 5 Phone: 6 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: MICHAEL DOWNEY, VIDEOORAPHER 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 161 A. Did I contemplate it? Yeah, it crossed my mind a few times. WilYi A. Nee. use 1 just thought it was the easy way out. And then 1 decided this is my life andl have to take responsibility for my own actions because 1 did volunteer. So I'm handling my grief and my situation a different way, and that's by putting this shit behind me. Q. Got you. Fair enough. What I'm wondering then — and the reason 1 asked the question initially was not to embarrass or harass you. But since even yourself, you think to a certain extent that these girls bear their own responsibility for going? A. They don't bear any responsibility. They need to take responsibility. Q. Got you. Did your dad tell you that? A. No. I've learned that. Q. What was his response to you about what happened then? That's why I asked the question initially. MS. BLANTON: We are not going to discuss her father and mother and relatives or any other friends' reactions to these lawsuits or what she's j 2 (Pages 158 to 161) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddcH-69oe-4e 57-9cd8 -8392056001GO EFTA01075988 Page 162 1 been through. Again, she's not a Plaintiff. She's 2 not a Defendant. We're not going to do it. 3 The only purpose that serves is to upset her 4 and you've seen that. 5 MR. KUVIN: I certainly don't mean to upset 6 her, but obviously I'm rep cbenting certain 7 individuals who are being — prosecuting their 8 action. And I think that the questions are 9 relevant But if you're not going to let her 10 answer, then we'll move on. 11 BY MR. KUVIN: 12 Q. As you sit here today, did anyone blame you, 13 other than yourself for what happened? 14 MR. CRITTON: Form. 15 THE WITNESS: Yes. 16 BY MR. KUVIN: 17 Q. Who? 18 A. A lot of people. 19 Q. Who? Who can we talk to that blamed you, 20 other than your own personal feelings? 21 A. My sister. 22 Q. Okay. Who else? 23 A. Ifs the only person that I care about that 24 blamed me. 25 Q. Well, anyone that didn't — that you don't 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 164 A. Yes. Q. As you sit here today, do you think that the money that he's paid you and the fact that be's paying for your lawyers when your parents couldn't afford it anymore affects your testimony in any way? A. Absolutely not. That's ridiculous. Q. Okay. Fair enough. Fair enough. Do you think it was right for Mr. Epstein, personally, to have underage girls, girls under the age of 16 come to his house and give him naked massages? You think that was okay? MR. CRITTON: Form. THE WITNESS: I don't know. MS. BLANTON: Object to form. Define okay. BY MR. KUVIN: Q. Well, personally. I mean, do you think there was anything wrong with that, personally? MR. CRITTON: Form. THE WITNESS: I don't know. BY MR. KUVIN: Q. You have no opinion about that? MS. BLANTON: She's answered that twice. MR. CRITTON: Form. Argumentative, if that was a question. BY MR. KUVIN: I 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 way? Page 163 care about? A. I think a lot of the other Plaintiffs blame me. Q. Okay. Do you feel any personal msponsibility for any — bringing any of those girls to the house? MR. CRITTON: Form. Asked and answered. THE WITNESS: Can you repeat the question? BY MR. KUVIN: Q. Yeah. You said just now that you think some of the other girls that you brought blame you? A. Ub-hub. Q. Correct? A. Yes. Q. Do you — A. Do I blame myself? Q. Yeah, for bringing them. A. Absolutely not. Q. Not at all? A. No. Q. If Mr. Epstein were not paying for your lawyers, think you'd feel the same way? A. I would feel this way, no matter what. Q. If Mr. Epstein hadn't paid you in excess of 53,000 over the years, do you think you'd feel the same Page 165 1 Q. You got no opinion about that? 2 A. I have no opinion about that. 3 Q. Okay. Do you remember the address of 4 Mr. Epstein's home? 5 A. No, I do not. 6 Q. Does the name Brillo Way sound familiar to 7 you? 8 A. Brillo Way sounds familiar. 9 Q. Did you ever take a shower in Mr. Epstein's 10 shower? 11 A. No. 12 Q. When you were at Mr. Epstein's house, did the 13 chef ever prepare you guys lunch as you were them? 14 MR. CRITTON: Form. 15 THE WITNESS: I don't remember. 16 BY MR. KUVIN: 17 Q. Any one of the girls that you brought to the 18 home, did any of those girls ultimately go to. 19 University, as far as you know? 20 A. Yes. 21 Q. Who? 22 A. Jane Doe 4. 23 Q. And I apologize, but is she the one that you 24 had heard had sex with Mr. Epstein? 25 MR. CRITTON: Form. PROSE COURT REPORTING AGENCY, Electronically signed by Sandra Townsend (401= Electronically signed by Sandra Townsend (401 • 3 (Pages 162 to 165) INC. 7a82dddt-59ee.4e57-9cd8.8392056001c0 EFTA01075989 Page 166 1 MS. BLANTON: rm sorry. Did you -- 2 BY MR. KUVIN: 3 Q. There was one of the girls that you had heard 4 had sex with them? 5 A. That was and I heard that from Jane Doe 6 101. 7 Q. Okay. Sony. 8 What did Jane Doe 4 do with him, if you know? 9 A. I don't. 10 Q. Did you ever tell anyone that you worked for 11 Jeffrey? 12 A. Did I tell anyone I worked for k 13 Q. Yes. 14 A. Yes. 15 Q. Who? 16 A. The girls. 17 Q. What did you mean by that when you said you 18 worked for Jeffrey? 19 A. Worked for Jeffrey, like, got girls to give 20 him massages. When I was introduced to a girl, I would 21 be, like, yeah, I work forJeffrey. I find girls to 22 give him massages. 23 Q. Okay. You weren't on any kind of a payroll or 24 anything, right? 25 A. No. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 168 Q. So all of the girls that you brought actually recruited other girls as well? A. Yes. MR. CRITTON: Pont BY MR. KUVIN: Q. Okay. How do you know that? A. I know that because they told me. Q. Okay. Which one of them? A. Jane Doe 7 brought,. Jane Doe 4 brought Jane Doe 3 brought a couple girls, can't recall their names.', I think, may have broughten somebody, but I can't be accurate on that. And I don't know for tut W I think Jane Doe 7. may have also brought i Q but and., the sisters. Q. So now we're talking about around 12 girls that you brought. And then as far as you know, a lot of those, if not all of them, brought other girls, at least one or two other girls? MR. CRITTON: Form. BY MR. KUVIN: Q. Is that — did I understand you correctly? A. Yes, you do. Q. So as you sit here today, how many girls are 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 167 Q. Did you ever bring a girl over with the initials •? - A. Pm sorry. What were the initials? Q. M. A. No, not that I can remember. Not that I can recall, no. Q. Do you know a girl by the name of A. No. Q. Doesn't sound familiar to you? A. M.? Q. Yes. A. Does not sound familiar at all. Q. How about'"? Q. Does the name sound familiar to you at all? I. as a girl that went over to Mr. Epstein's home at some point? A. rye heard that name come up a few times. Q. Do you remember bringing a'. over to the house? A. I never brought a over to the house. Q. Of any of the girls that you brought, do you know if any of those girls then did similar to you in getting other girls? 25 A. All of them. Page 169 1 you aware of that were brought to Mr. Epstein's home? 2 A. That I'm aware of? 3 Q. Well, yeah, either that you brought or that 4 you know other people brought. I mean, you've already 5 talked to us about 12. Then where there's -- if they 6 each brought them, then we're talking 12 more, plus some 7 of them may have brought additional ones. You know, 8 simple math, were in the twenties now. How many are 9 you aware of let me strike the statement. 10 How many people are you aware of, either 11 directly or indirectly, girls that were brought to 12 Mr. Epstein's home? 13 MR. CRITTON: Form. 14 THE WITNESS: At least 20. 15 BY MR. KUVIN: 16 Q. At least? 17 A. At least 20. 18 Q. Could it be at least 30? 19 A. I don't know. 20 MR. CR1TTON: Form. 21 THE WITNESS: I don't want to speculate. 22 BY MR. KUVIN: 23 Q. But through either firsthand knowledge, in 24 addition to secondhand knowledge from the girls 25 themselves, you're aware of at least 20? 4 (Pages 166 to 169) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddl-59ee-4e57-9cd8-1339205600fc0 EFTA01075990 Page 170 Page 172 1 A. At least. 2 Q. Okay. And of those girls, other than the one 3 girl that we've talked about before that was 24 years 4 old, as you sit here today, all those girls were under 5 age 18; is that correct? 6 MR. CRITTON: Form. 7 THE WITNESS: That I know ot yes. 8 BY MR. KUVIN: 9 Q. And the on one 're aware of that was over 10 that age of 18 was ou 11 A. At 23, yes. 12 Q. Did Jane Doe 101 ever tell you how she first 13 heard about Mr. Epstein? 14 A. No, she did not. 15 Q. What I'm hying to understand is, at some 16 point it seemed like, according toyour testimon that 17 there were a number of girls from High 18 School that were going over to Mr. Epstein's home during 19 this period of time in 2005, early 2006. 20 What I'm trying to figure out is, if you know, 21 how did Mr. Epstein or his people get entree into your 22 high school initial) in other words, who was the first 23 person at High School, if you know, 24 that started this whole thing? 25 MR. CRITTON: Form. 1 whatever, at word got around campus. And 2 then girls that 1 were bringing were like, yeah, I know 3 so and so and she did that, like, ninth grade. But it's 4 hearsay. 5 Q. I understand. M., how much older than you 6 was she? 7 A. My age. 8 Q. She was your age? 9 A. She's my age now. 10 Q. Well then, she would have been your age then? 11 A. Yeah. 12 Q. Right? 13 A. Yeah. 14 Q. Okay. Unless she's got a time machine that we 15 don't know about. 16 A. She might. 17 Q. You had heard that she went in ninth grade? 18 A. That is what I heard. 19 Q. Who did you hear that from? 20 A. Multiple people. 21 Q. Are you aware, other than her, of anyone else 22 that went over to Jeffrey's house before you that was 23 going to 24 A. Yes. 25 Q. Who else? 1 2 3 4 5 6 7 8 El? 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 171 THE WITNESS: I have no idea. I do not !mow. It wasn't me. BY MR. KUVIN: Q. Right. Because Jane Doe 101 got you? A. Jane Doe 101 got me, that's correct. Q. And I'm sorry. I know I asked this before. But Jane Doe 101, she was a classmate of yours at A. No. I went to with her. Q. Okay. A. Her, We weren't friends, didn't hang out. Just saw each other through the hallways. Q. Well, that's interesting then. from Ar wathe first girl, that you're aware of, High School that went to Mr. Epstein's home? MR. CRTTTON: Font THE WITNESS: No. BY MR. KUVIN: Q. Who was the first girl that you were aware of from = that went there? A. Q. And how did you become aware of her going? A. When I started going and I started bringing girls that I was friends with, acquaintances with, 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 173 A. Q. When did she go? A. I don't know if she ever worked for him or gave him a massage, but she was — she's been to his house. AA. O i or (phonetics), I think. Q. Okay. Who else? A. On top of my head, that's all 1 can think of. Q. Do you know how to spell A. Q. A. Q. And A. I. Q. And A. Q. Other than Brom there? .A. Q. Flow do you II= anyone else that you're aware of that went over PROSE COURT REPORTING AGENCY, Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 5 (Pages 170 to 173) INC. 7a82dddl•59e*Ao57-9cd8439205600fc0 EFTA01075991 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 174 A. Q. Who else? A. That's it, that I can think of on the top of my head that went before I even heard about him. Q. Were you all at school talking about going over to this old guys house on the beach? MR. CRITTON: Form. BY MR. KUVIN: Q. I mean, were there any conversations that were had around the hallways at school about this issue? MR. CRITTON: Font THE WITNESS: I had no idea that they had even gone until after I met Epstein and was already done with my situation. BY MR. KUVIN: Q. Right. A. So this is information that I've learned in the last three years — Q. Okay. A. -- that I hadn't known before. The girls and the friends that I hung around with, they would all talk about it in the hallways because they knew that I was taking them or that they met him through me. Page 176 1 M. was just - I don't even know what 2 category I can put her under. 3 Jane Doe 3 was definitely promiscuous. 4 I don't really have a category to put M. 5 under. She was just kind of the younger one, the not so 6 bright one. Q. Got you. When you would ask girls to go, would you look for the ones you thought were more promiscuous? 10 MR. CRITTON: Form. 11 THE WITNESS: No. No. 12 BY MR. KHVIN: 13 Q. How would you decide which ones to ask? 14 A. They were my friends, the girls that I vent to 15 school with, the ones that I kicked it with after 16 school. They were in my circle. It was convenient. 17 Q. Okay. Call me naive, but how do you convince 18 a girl that age to go to an old man's house, even just 19 to give a massage? 20 MS. BLANTON: Object to the form. Go ahead. 21 I think you were handling the answer just fine. 22 MR.. CRTITON: Form. 23 BY MR. KUVIN: 24 Q. Go ahead. 25 A. That's the thing. I didn't have to convince 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 175 Q. Right. A. But if you mean communication through different cliques in the hallway, as, like, an issue, no, nobody ever spoke about it. Q. Okay. All the girls that you took, what was their, I guess for lack a better term, social status within the school? I mean, were they popular girls? Were they not popular girls? Were there, you know,1 mean, in sane schools there are, like, the cheerleaders and the different groups? A. Should I be brutally honest? MR. HOROWITZ: I'm going to object to the form then. BY MR. KUVIN: Q. Yes. Brutally honest. A. Do you want to include myself in this? Q. Let's k ou out of it for the moment. 1 46 A. a was the party animal. and and, I believe,.. were the cheerleaders. Q. Okay. A. Jane Doe 7 and Jane Doe 4 were the promiscuous ones. was - not promiscuous, but more flirtatious. 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 17 than. Q. What do you mean? A. I didn't convince anything. I proposed to them. They took it. They volunteered. Q. Okay. A. Sometimes the girls would come up to me and ask me if they can work for him this weekend. There was no convincing needed. Q. Right. So you would just mention it and — A. They jumped on it, just like I did. Q. Then why did it bother you when you did it the first time? A. It bothered me more so because I just — I can't explain it to you. It didn't bother me then as it bothered me now. It bothers me now for different reasons. Q. Well, do you think you were any less sensitive than these girls? A. I am definitely less sensitive than those girls. Q. You see yourself as being more sensitive than them? A. At times, yes. At other times, no. Pm a very hard person. Everybody's sensitive when they want to be. You strike somewhere where it hurts, you're 4.4.5.-M14:41A.Vtaattor.? 6 (Pages 174 to 177) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7082dddf-59ce-4e57-9cd8-8392056001c0 EFTA01075992 Page 178 Page 180 1 going to be sensitive. You're going to &IL 2 Q. And this whole issue with Epstein obviously is 3 a sensitive point with you? 4 A. It is. 5 Q. Did like the fact that went over 6 them, if you know? 7 A. I don't know. 8 Q. Did you ever hear that he was upset about you 9 bringing..? 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. We did have a falling out. Q. After you brought'.? A. After I brought When he found out that I Ness going to bring her, yeah, he distanced himself from her and me. Q. Do you know why? A. No. Q. Did you hear that he actually punched a wall he was so upset? MR. CRITTON: Form. BY MR. KUVIN: Q. Did someone tell you that? A. No. Q. Have you talked to him since? A. We're not as close. Q. Have you talked to him at all since? 1 BY MR. HOROWITZ: 2 Q. Hi. Good afternoon. My name is Adam 3 Horowitz, as I mentioned when we started today. 4 A. Okay. 5 Q. I represent seven of the Plaintiffs. Pm 6 going to be asking you some questions, sort of filling 7 in some blanks in my mind based on the previous 8 questions and also some particular questions about my 9 clients. Okay? 10 Sort of at the beginning of the deposition you 11 told us that Jute Doe 101 first mentioned Jeffrey 12 Bpstein's tune to you at the Beach Resort; is 13 that right? 14 A. That is correct. 15 Q. Before that time, you had never heard of him; 16 is that right? 17 A. That's right. I had never heard of him 18 before. 19 Q. But you know now that certain 20 classmates of yours wore already going to his house? 21 A. That's correct. 22 Q. Did Jane Doe 101 ever tell you that she, 23 herself, had gotten paid for giving Mr. Epstein a 24 massage or was she simply a recruiter for him? 25 A. We news discussed that Page 179 1 A. Yes. 2 Q. Did you talk to him about this incident? 3 A. No. Ifs not a conversation that me and him 4 have had. Ifs not a conversation that I would like to 5 have with him. 6 Q. Is that the only reason you can think of that 7 you two had a falling out? 8 A. Yes. 9 Q. When you were in the room with Mr. Epstein, 10 did you actually see his genitals? 11 A. I don't remember. I tried not to look. 12 Q. Okay. So as you sit here today, you couldn't 13 describe them? 14 A. No. I could not describe them for you. 15 Q. I don't mean obviously his face. I'm talking 16 about his genitals. You could not describe those? 17 A. I could not describe his genitals for you. 18 Q. Okay. Did you ever talk tot's parents? 19 A. No. 20 MR. KUVIN: All right. I appreciate it. 21 That's all the questions I have at this point 22 Other attorneys, I'm sure, are going to have some 23 for you. 24 (Discussion held off the record.) 25 CROSS EXAMINATION Page 181 1 MR. CRITTON: Form. 2 BY MR. HOROWITZ: 3 Q. Do you — as we sit here today, do you know of 4 anything that took place when Jane Doe 101 went to 5 Jeffrey's house? 6 A. No. 7 Q. Do you know if she ever gave him a massage? 8 A. No, l don't 9 Q. Do you know if they ever had sexual contact? 10 A. No, I do not. 11 Q. And you told us that Jane Doe 101 did not 12 forewarn you that Jeffrey Epstein would touch you in a 13 sexual manner, is that correct? 14 MR. CRITTON: Form. 15 THE WITNESS: That's correct. 16 BY MR. HOROWITZ: 17 Q. Did she ever say that he would touch your 18 private parts? 19 A. No. He never did she never did. 20 Q. She never told you that? 21 A. Sony. 22 Q. Did you ever tell her that, in fact, he had 23 touched you, as you said, below the belt in the front? 24 MR. CRITTON: Form. 25 THE WITNESS: I don't remember. I 7 (Pages 178 to 181) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dridt-Sgee-4e57-9cd8-8392056001c0 EFTA01075993 Page 182 Page 184 1 BY MR. HOROWITZ: 2 Q. You don't know if you ever told her that? 3 A. I don't know if l ever told her that. 4 Q. Was it upsetting to you that she didn't tell S you that that might occur? 6 A. I don't remember. 7 Q. Are you, as we sit here today, upset — if she 8 knew — strike that. 9 If she knew that Jeffrey Epstein had a sexual 10 interest in girls, would you have liked to have known 11 that before you went to his house? 12 MR. CRITFON: Form. 13 THE WITNESS: I don't know. 14 BY MR. HOROWITZ: 15 Q. That might be something you didn't care about 16 before you went to his house? 17 A. I don't know how to answer that. I don't 18 know. I'm not being put in that position. 19 Q. Well, was it upsetting to you when he touched 20 you in a sexual manner and you had no idea he was going 21 to do that? 22 A. I don't know. I can't recall my feelings at 23 that point in time. 24 Q. And you don't recall whether you ever told her 25 what had taken place? 1 going to touch you in a sexual manner? 2 MR. CRITTON: Form. 3 THE WITNESS: Yes. 4 BY MR. HOROWITZ: 5 Q. Now, you -- do you know if she recruited other 6 girls to go to Jeffrey's house? 7 A. I don't know. 8 Q. Has she ever told you that she recruited other 9 girls to go to Jeffrey's house? 10 A. I can't remember. 11 Q. Have you heard from anyone that Jane Doe 101 12 recruited other girls to go to Jeffrey's house? 13 A. Nobody said anything, no. 14 Q. As we sit here today, are you aware— is it 15 your understanding that you are the only person that she 16 recruited or do you have some other fountain of 17 information? 18 A. To my knowledge, I'm the only girl that she 19 recruited. 20 Q. And when she recruited you, did she talk about 21 the range of girls that Jeffrey preferred? 22 A. No. 23 Q. Did she indicate to you at any point how long 24 it is that she was -- had been recruiting for Jeffrey 25 Epstein? Page 183 1 A. I don't know if I ever told her. Q. Now, when you got done with this 3 massage/touching encounter, you went downstairs and you I saw her on the first floor of the house? 5 MR. CRITTON: Form. 6 BY MR. HOROWITZ: 7 Q. is that right? A. I went downstairs. I don't know if she came 9 up and got me or inflict her down there, but she was 10 waiting for me with yes. 11 Q. And then you proceeded to ride home -- 12 A. Together. 13 Q. Together? Did you tell her any of the events 14 that had taken place upstairs in the massage room? 15 A. I can't recall. 16 Q. Do you think she should have told you that 17 Jeffrey Epstein was going to touch you in a sexual 18 manna? 19 A. Should she have? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't know. Yes. 22 BY MR. HOROWITZ: 23 Q. Well, which is it] don't know or yes? I'll 24 ask the question again so it's clear. 25 Should she have told you that Jeff Epstein was 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 185 A. No, she did not. Q. And you told us that when you recruited for Jeffrey Epstein, you told the girls that you worked for Jeffrey; is that eorree.t? A. Yes. Q. Did she make a similar pitch to you, I work for Jeffrey and I'd like you to come for a massage? A. I can't remember. Q. Okay. Turning your attention to the encounter when you were in the massage room with Jeffrey. When Jeffrey Epstein reached below your belt in the front, as you described it, did you push him away? A. I pushed his hand away. Q. You pushed his hand away. Did you, like, move away as well? A. I don't remember. Q. Was that your -- was that your indication to him that you were uncomfortable with what it is he was doing? A. Yes. Q. What I'm trying to get at is, that's why you pushed him away, to indicate to him you didn't want him to touch you that way? A. That's correct. Q. In a sexual way? Y.• 8 (Pages PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 182 to 185) 7a82ddd1.59o0.4057.9cd8.839205600fc0 EFTA01075994 Page 186 Page 188 A. That's correct. 2 Q. Did he continue masturbating after you told 3 him — after you pushed his hand away? 4 MR. CRITTON: Form. 5 THE WITNESS: Yes. 6 BY MR. HOROWITZ: 7 Q. And you — did you hear him, like, breathing 8 heavy? 9 MR. CRITTON: Form. 10 THE WITNESS: I can't remember. 11 BY MR. HOROWITZ: 12 Q. Was he masturbating, like, with his hand on 13 his penis? 14 A. Yes, 15 MR. CRITTON: Form. 16 BY MR. HOROWITZ: 17 Q. And had you looked that way, would his 18 genitals have been exposed? 19 A. Yes. 20 Q. And did he suddenly stop masturbating, as in, 21. when someone has a climax or orgasm? 22 A. Yes. 23 Q. You distinctly recall that? 24 A. Yes. 25 Q. At the conclusion of this encounter in the 1 Q. He said what? 2 A. He had just made a comment about her age when 3 he was paying me. He just made a comment, like, you 4 know, she was old. 5 Q. Meaning, the previous girl -- 6 A. Yes. 7 Q. — was old? 8 Did Jeffrey — now, you told us that the range 9 of the other girls you brought was between ages 14 and 10 17; is that alma 11 A. Besid that's right. 12 Q. Did Jeffrey Epstein ever express displeasure 13 with the 14 to 17 year old girls that you brought? 14 A. !don't know. 15 Q. I'm just asking, did he ever express it to 16 you? 17 A. He never expressed it to me. 18 Q. Now, when you were bringing these girls over 19 to Jeffrey Epstein's house, did you believe that these 20 girls were going ova to Epstein's house so that Epstein 21 could have sexual contact with them? 22 A. I don't know. 23 Q. Now — go ahead. 24 A. 1 don't know. I never directly stated 25 anything about sexual contact Page 187 1 massage room, you told us, I think, that Jeffrey Epstein 2 asked you to bring other girls. Did I get that right? 3 A. Yes. 4 Q. What was your response? 5 A. I told him, okay. 6 Q. You were comfortable with that? 7 A. Yes. 8 Q. And did you tell him, I'll be in touch, or 9 anything along those lines? 10 A. I don't tensanber. 11 Q. But by then you already had lumber, 12 telephone number? 13 A. At some point 1 had number. I don't 14 recall if it was before or after the massage. 15 Q. Okay. All right. Now, you told us that 16 on one occasion brought an older girl named is 17 that right? 18 A. That is right. 19 Q. Was it Jeffrey Epstein who told you she was 20 too old? 21 A. Yes. 22 Q. And did he tell you that when you arrived in 23 the first floor of the house or after the massage or 24 when did that conversation take place? 25 A. The next girl I brought. Page 189 1 Q. I got that I'm not asking what you said. 2 But in your own mind, when you're bringing these girls 3 over, did you think in your own mind, these girls are 4 going over to Ertein's house and Epstein is going to 5 have some type of sexual contact with them, the same way 6 he did with me? 7 MR. CRITTON: Form. THE WITNESS: I don't know. 9 BY MR. HOROWITZ: 10 Q. It didn't cross your mind that — 11 A. I don't know what crossed my mind seven years 12 ago. 13 Q. Okay. Did you believe that you were being 14 paid cash to bring over girls to Epstein's house for 15 sexual pleasure? 16 A. No. 17 MR. CRITTON: Form. 18 BY MR. HOROWITZ: 19 Q. What did you think the purpose of the money 20 that you were getting was? 21 A. To introduce him to girls for massages. 22 Q. For massages? 23 A. Yes. 2 4 Q. You thought that a reason that you were 25 getting paid $200 was for an untrained high school girl 9 (Pages 186 to 1 8 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Tandddf-69eo4o57-9cd8-839205600fc0 EFTA01075995 Page 190 1 to give a grown man just a massage? 2 A. Yes. 3 Q. I'm trying to — was there a part of your 4 mindset that thought, I'm also going to get paid for 5 giving — for bringing girls to give Epstein sexual 6 pleasure? A. I didn't receive any sexual pleasure, so 1 8 can't make that analysis. 9 Q. I'm not asking about your sexual pleasure. 10 Pm asking about Epstein's sexual pleasure. 11 Was there a part — was there a part of your 12 mind that said, I'm getting paid hundreds of dollars to 13 bring young, attractive girls to Jeffrey's house so that 14 he can have sexual pleasure? Did that cross your mind? 15 A. No, it did not. 16 Q. As we sit here today, looking back on the 17 large sum of money that Jeffrey paid you, thousands of 18 dollars, would you agree that he paid you that money so 19 you could bring girls for his sexual pleasure? 20 MR. CRITTON: Form. 21 THE WITNESS: I don't know. No. No. 22 BY MR, HOROWITZ: 23 Q. Well, in your estimation, what do you think 24 was the reason he paid you thousands of dollars? 25 A. Fora massage, for me to introduce him to Page 192 1 bit wiser, in your opinion were you paid thousands of 2 dollars for Jeffrey Epstein to get sexual pleasure from 3 14 to 17 year old girls? 4 MIL CRITTON: Form. 5 THE WITNESS: No. 6 BY Mr. HOROWITZ: 7 Q. Did Jeffrey Epstein tell you in particular, 8 specifically, I want these girls ova because they're 9 good masseuses, that they really improve my back? 10 A. No, he never said that. 11 Q. And to your knowledge, is there a single girl 12 that you brought over that Jeffrey Epstein did not have 13 an orgasm with? 14 A. Yes. 15 MR. CRITTON: Form. 16 BY MR. HOROWITZ: 17 Q. There's some girls that he did not achieve 18 climax? 19 A. Yes. 20 MR. CRITTON: Form. 21 BY MR. HOROWITZ: 22 Q. Are there any girls that you're aware of that 23 he didn't touch or try to touch in a sexual manner? 24 A. No. 25 MR CRITTON: Excuse me. Form to the last Page 191 1 girls to give him a massage. 2 Q. Through your different conversations with 3 Jeffrey Epstein, you've come to know that he's a very 4 affluent man. I mean, you've described him as a 5 billionaire. 6 MR. CRITTON: Fenn. 7 THE WITNESS: Yes. 8 BY MR. HOROWITZ: 9 Q. Would you agree that if he wanted to, he could 10 have the best masseuses in the world? 11 MR. CRITTON: Roan. 12 THE WITNESS: Yes. 13 BY MR. HOROWITZ: 14 Q. And yet he wanted these masseuses, in 15 particular, from 14 to 17 year old girls; is that 16 correct? 17 MR. CRITTON: Form. 18 MS. BLANTON: Objection. You're asking her to 19 speculate on what Jeffrey Epstein wanted or had in 20 his mind. If you want to ask her a question about 21 what he told her or what she communicated with him, 22 that's fine. 23 BY MR. HOROWITZ: 24 Q. My question is: As you look back on it now, 25 having, you know, being a few years older and a little Page 193 1 question. 2 MR. HOROWITZ: Too late. 3 BY MR. HOROWITZ: 4 Q. How did -- S MR. CRITTON: Then you need to slow down. 6 MIL HOROWITZ: You need to speed up, old man. 7 BY MR. HOROWITZ: 8 Q. How did you go about recruiting? 9 MR. CARTON: Ill smile. 10 BY MR. HOROWITZ: 11 Q. How did you go about — how did you go about 12 recruiting thegirls that were in your social circle at 13 High School? Was it always 14 face-to-face or was it ever telephone? E-mail? Text? 15 A. Sometimes over the phone. Sometimes when I'd 16 run into them in the hallways at school or hang out with 17 them, so face-to-face, over the phone. 18 Q. Would you always have these take a girl 19 that you went to high school — give me a name of 20 somebody who you went to high school with. 21 A. Jane Doe 4. 22 Q. Okay. Jane Doe 4. When you spoke to Jane Doe 23 4 and told her for the first time about Jeffrey Epstein 24 and this opportunity, did you tell her - was anybody 25 else there when you told her? 10 (Pages 190 to 193) PROSE COURT REPORTING AGENCY, INC. ElectroMcally signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82deldf.59ee-4e57-9cd8-839205600fc0 EFTA01075996 Page 194 Page 196 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't recall. Q Did you tell her in person, by phone or howl A. I don't recall. Q. What about Jane Doe 7? Did you tell her — was it a one-on-one type of conversation? A. I really don't recall. Q. What about Jane Doe 2? Was that in person Or •••• A. Jane Doe 2. Q. Do you recognize that name? A. I never brought her. Q. Jane Doe 3? A. Jane Doe 3, I don't recall. Q. You don't recall whether — I didn't even ask a question. You don't recall whether it was in person or by telephone, anything of that sort? A. I don't recall how I told her. Q. But each of these girls, it was always, like, a private kind of one-on-one conversation or would you sort of announce it in the cafeteria or the classroom MR. CRITTON: Form. THE WITNESS: I don't think I ever announced it in the cafeteria, but I don't know. BY MR. HOROWITZ: 1 THE WITNESS: Yes. 2 BY MR. HOROWITZ: 3 Q. What would you say? 4 A. I would just talk to them, hey, listen, you 5 !mow, I know this guy, his name is left hes on the 6 Island, he has a lot of money, he's a billionaire, you 7 know, he's looking for girls to give massages. Are you 8 interested? 9 And then obviously if they were interested, I 10 would go into a little bit more detail, you know, 11 exchange dates and times that they were available. 12 Q. And ou would always clear those dates and 13 times with or somebody else? 14 A. 15 Q. Am I correct in is all that you told the girls 16 in regard to the services they had to render was that 17 they were getting money for massages? 18 A. I told them they would get $200 for a massage. 19 The more you do, the more you make. 20 Q. Well, you told us earlier that they were 21 getting paid for massages. 22 A. They were getting paid for massages. 23 Q. And that's what you told them? 24 A. That is what I told them. 25 Q. Thank you. Page 195 1 Q. Would you make an effort to have a private 2 conversation about this subject? 3 A. Depending. Depending on the girl. 4 Q. Well, give me the, if you can, the variables. 5 What would weigh in favor of making son of a public or 6 semi-public announcement about this and what would weigh 7 in favor of having a private conversation? 8 A. Wellwith Jane Doe 4 it had to be private 9 because if her old boyfriend, found out, he 10 would beat the aap out of her. So she was somebody 11 that I went to privately. 12 MR. HOROWITZ: Move to strike. 13 THE WITNESS: Also, depending on what the 14 girls were like, I mean, some are very jealous when 15 it comes to money. It depends. The other girls 16 didn't like it when they weren't working and the 17 other girl was. So usually I probably bad to just 18 do it privately. A lot of them were very not 19 wanting other girls to work for him. 20 BY MR. HOROWITZ: 21 Q. Did you— did you have a standard sales 22 pitch, so to speak, in recruiting these girls, like, 23 what you would tell each of them in order to get them to 24 go to Jeffrey Epstein's house? 25 MR. CR1TTON: Form. Page 197 1 You told us that you an understand — a moment 2 ago you told us that you had an understanding that the 3 more girls did, the more they got; is that right? 4 A. Yes. 5 Q. Where did you come up with this understanding? 6 A. Jane Doe 101 told me that, so I just passed it 7 along. 8 S Was that a theme that — or a message that 9 also told you? 10 A. No. 11 Q. Did Jeffrey ever tell you that? 12 A. No. 13 Q. Did anybody who worked or was connected with 14 Jeffrey tell you that? 15 A. No. 16 Q. So you took Jane Doe 101 at her word that the 17 more — the more the girls did, the more they got paid? 18 A. That's comet. 19 Q. And do you know if, in fact, that is a true 20 statement? 21 A. I don't know. 22 Q. In terms of the more you get the more you 23 do, the more you get paid, what were the — on the low 24 end of the scale, the less you did, the less you got 25 paid, what would be the lesser activities? 11 (Pages 194 to 197) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7.82dthif-50co.4o57-9cd8-839205600fc0 EFTA01075997 Page 198 1 A. The lesser activities? I don't know. 2 Q. Well, -- and how much would you get paid on 3 the lesser end? 4 A. I don't know. 5 Q. And then on the higher end, when you say the 6 more you did, the more you got paid, what sort of things 7 are we talking about? $ A. Whatever the girl allowed him to do or 9 whatever their situation was. I don't know. I was 10 never in the room with them. I just took what Jane Doe 11 101 said and passed it down. 12 Q. Well, did anyone ever say, well, what does 13 that mean, the more you do, the more you get paid? 14 A. Yes. 15 Q. And how would you explain that? 16 TIE WITNESS: Didn't we already discuss this? 17 The more you do, the more you make. If you 18 were topless, if you were working in your thong, 19 your bra, you're going to make more than a hundred, 20 as to somebody who is always complaining about 21. money and never takes off her shirt 22 BY MR. HOROWITZ: 23 Q. So a hundred is the low end? 24 A. You could say that 25 Q. What's the high end? If you really did a lot Page 200 1 A. Either would call me or I'd call 2 and we'd work it out to where when Jeffrey was coming 3 home I would have a girl that would be available for 4 those dates and times. 5 Q. So you would — you would get a heads up 6 before he came into Florida? 7 A. Ulthuh. 8 Q. Yes? 9 A. Yes. 10 Q. Okay. And would MI give you that 11 information by telephone? 12 A. Yes. 13 Q. Would she call your home phone or cell phone? 14 A. Cell phone. 15 Q. And where would she be calling you from? 16 A. I don't know. 17 Q. Did you get the sense that she lived with 18 Jeffrey? 19 MR. CRITTON: Form. 20 THE WITNESS: Yes. 21 BY MR. HOROWITZ: 22 Q. Would she ca/ I you horn his home? 23 A. I don't remember. 24 Q. You told us or you told Mr. Kuvin that you 25 told the girls to say that they were 18 years old? Page 199 1 of stuff with Jeffrey, what would you — how much money 2 could you make? 3 MR. CRITTON: Form. 4 THE WITNESS: I heard about 300. 3 BY MR. HOROWITZ: G Q. Three hundred. And what sod of sexual 7 contact or nudity would you have to do to get that kind 3 of money? MR. CRITTON: Form. 10 THE WITNESS: I don't know. I wasn't in the 11 room. 12 BY MR. HOROWITZ: 13 Q. And you just don't know from hearing it from 14 other people? 15 A. 1 don't know. 16 !t How would you know the — you told us that 17 I= was always the person who gave you the dates and 18 times for appointments. How would she communicate that 19 to you? 20 A. Can you repeat the question? 21 Q. Yeah. If you were to recruit a girl and she 22 was interested and you said you would tell her potential 23 dates and time and things like that. How would you have 24 that knowledge? How would you know available dates and 25 times? Page 201 1 A. Yes. 2 Q. Can you specifically recall telling that to 3 every we of the girls that you recruited? 4 A. Yes. 5 Q. And why would you tell them that? 6 A. Jane Doe 101 told me to tell him that. 7 Q. So you just — 8 A. Jane Doe 10I told me. I passed it down. 9 Q. Now, were you physically present when all of 10 the girls went for their encounters with Jeffrey 11 Epstein; meaning, were you upstairs in the massage room 12 for any of them? 13 A. No. 14 Q. So would it be — do you know if any of the 15 girls, in fact, told Jeffrey Epstein, I'm 18? 16 A. No. 17 Q. Do you have — I'm trying to work through this 18 because we're getting late in the day. 19 Did you get the same payout for each of the 20 girls that you brought? 21 A. What do you mean? 22 Q. For a -- name a particular girl. 23 A. Jane Doe 4. 24 Q. Would you get paid $200 for every girl that 25 you brought? 12 (Pages 198 to 201) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-59ce-4eS7.9cd8-839205600(c0 EFTA01075998 Page 202 Page 204 1 A. Yes. 2 Q. Were that any girls that you got paid less 3 for? 4 A. No. 5 Q. Would you ever get paid more than 200 for 6 bringing a girl? 7 A. No. 8 Q. Was your payout based on what Epstein did with 9 the girls or what the girls did with Epstein? 10 A. No. 11 Q. It was just for sort of brokering the deal, 12 getting them in the same place at the same time? 13 MR. CIUTTON: Form. 14 TILE WITNESS: Yes. 15 BY MR. HOROWITZ: 16 Q. Ii; for instance, a girl you recruited, just 17 an example, say, Jane Doe 7. If she came ten times, 18 would you get paid ten times or how did that work? 19 A. If I — sometimes I would get paid 5200 for 20 every girl. Other times, for instance, if I was to 21 bring Jane Doe 7 more than once, I might be able to 22 sneak in and get paid more than once. But usually it 23 was Just 200 for every girl. 24 Q. But there were sometimes in some — in the 25 case of some girls that you got paid more than once for 1 need a restroom break. 2 MR. HOROWITZ: That's fine. I'm not holding 3 anyone captive. 4 VIDEOGRAPHER: Going off the record, 3:45. 5 (Brief recess.) 6 VIDEOGRAPHER: We're back on the video record. 7 The time is 3:57. 8 BY MR. HOROWITZ: 9 Q. Have you ever been to Jeffrey Epstein's house 10 when you were not there to give a massage or to bring a 11 girl who was there to give a massage? 12 A. No. 13 Q. So every time that were you ever somewhere 14 other than Jeffrey Epstein's house With Jeffrey Epstein? 15 A. No. 16 Q. So all of your contact, personal contact with 17 him was at his house; is that right? 18 A. Yes. 19 Q. And it was always in the course of bringing — 20 either going with Jane Doe 101 or bringing one or more 21 girls? 22 A. Yes. 23 Q. Have you ever travelled with Jeffrey Epstein? 24 A. No. 25 Q. Have you ever travelled with someone who Page 203 1 that same girl? 2 A. Yes. Q. Now, if one of the girls who you recruited in turn recruited another girl, would you get paid as well? ▪ A. I'm cut out of that deal. • Q. You're cut out of the deal? A. Uh-huh. a Q. Did you ever talk to Jeffrey or about 9 whether you should be included in that deal? 10 A. No. 11 Q. Were you always paid in cash? 12 A. Yes. 13 Q. And who gave you the money, like, physically 14 handed you the money? 15 A. Epstein. 16 Q. While you were upstairs or while you were 17 downstairs? 18 A. I don't remember. 19 Q. And would it would you get paid in front of 20 the girls you had brought? 21 A. No. 22 Q. You would — and would they get paid in front 23 of you? 24 A. Not that I can remember, no. 25 MS. BLANTON: If you're at a good point, I 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 205 worked for him? A. No. Q. Have you ever been in a favorer's office with Jeffrey Epstein? A. No. Q. Have you ever been in a vehicle owned or controlled by Jeffrey Epstein? A. No. Q. Have you ever been invited to travel with Jeffrey Epstein? A. No. Q. Did Jeffrey Epstein talk to you about properties that he owned? A. No. Q. Did he ever talk to you about businesses that he owned? A. No. Q. Did he ever talk to you about how he accumulated his wealth? A. Yes. Q. What sort of things would he tell you? A. He told me he was a scientist. Q. You're laughing. A. He did. Q. You know he's not a scientist? 13 (Pages 202 to 205) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-59ite-4e57-9cd8-8392056001c0 EFTA01075999 Page 206 Page 208 1 MR. CRITTON: Form. 2 THE WITNESS: Obviously I know that now. 3 BY MR. HOROWITZ: 4 Q. You lmow he's a child molester? 5 MR. CRITTON: Form. Argumentative. 6 BY MR. HOROWITZ: 7 Q. Right? A. No, I do not know that. 9 BY MR. HOROWITZ: 10 Q. You know he touches underage girls for sexual 11 pleasure? 12 A. I don't blow that. 13 Q. You know he touched at least one girl for 14 sexual pleasure, right? 15 MR. CRITTON: Form. 16 BY MR. HOROWITZ: 17 Q. Yes? 18 A. I don't ;mow that. 19 Q. Do you know if he — well, you've told us he 20 touched you for sexual pleasure, correct? 21 A. Tried. 22 MB. CRITTON: Form. 23 BY MR. HOROWITZ: 24 Q. !mean — but he did touch you. You told the 25 police 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 A. I don't even remember. Q. I'm going to ask the question again because there was — I'm not sure there was an objection, just kind of an interruption, exactly. Other than a statement that you made in the police car regarding MM, what else did you discuss with the police when you were in the police air? MR. CRITTON: Let me just object to the form because she just said she couldn't talk about MI MR. HOROWITZ: Are you instructing her? I'm saying, other than. MR. CRITTON: Yeah, but you're trying Sa rick her into suggesting that maybe she did say M. So you've got to be careful with your questioning. I think that was inappropriate. THE WITNESS: I don't even remember the ride. MR. HOROWITZ: If it was inappropriate -- MR. CRITTON: I don't think it was intentional. I don't think it was intentional. Maybe you're too young to understand. BY MR. HOROWITZ: Q. Eliminate — MR. HOROWITZ: That's true. BY MR. HOROWITZ: Page 207 1 A. Yes. 2 Q. And you know he masturbated while looldng at 3 you while you were l6 or I7 years old? 4 A. Yes. 5 Q. You were asked some questions by Mr. Kuvin 6 about your travel in the police car. Do you recall 7 those questions? 8 A. Yes, Id°. 9 Q. Where were you going to? Where were you 10 coming from and where were you going to? 11 A. They picked me up at my house, took me down to 12 the station and then they brought me home to my house. 13 Q. So you're going — this conversation that 14 you've been talking about was in the — 15 A. In the police car. 16 Q. Going from the police station downtown to your 17 home; is that right? 18 A. That is right. 19 Q. Okay. Other than an statement made in the 20 police car regarding which your attorney 21 has already told you not to answer, what else did you 22 discuss with the police? 23 MR. BLANTON: I'm sorry. When? 24 BY MR. HOROWITZ: 25 Q. When you were in the vehicle. Page 209 1. Q. Exclude any conversation or non-conversation 2 that you had regarding-. Put that out of 3 your mind, if it at all ever occurred. 4 Tell me about what else you discussed with the 5 police In the police car. 6 A. I don't remember. 7 Q. Did you tell the police that Jeffity Epstein 8 admitted to you that he was a serial pedophile? 9 MR. BLANTON: She just testified that she does 10 not — 11 MR. HOROWITZ: I'm hying to — there's an art 12 of questioning where you try and refresh people's 13 recollection. You go with the general and then you 14 narrow it to the specific. 15 BY MR. HOROWITZ: 16 ' Q. And, so, my question for you is: Did you tell 17 the police that Jeffrey Epstein admitted to you that he 18 was a serial pedophile? 19 A. No, he never admitted.that. That is absurd. 20 Q. Did you tell — did you tell the police that 21 Jeffrey Epstein was a pedophile who paid you to bring 22 girls for his sexual gratification? 23 MR. CRITTON: Form. 24 THE WITNESS: No, I did not tell the police 25 that [told him he was a serial pedophile that paid e.V.I•movaVa.mi-wnwv 14 (Pages 206 to 209) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddt-59ee-4e57-9cd8-839205600fc0 EFTA01076000 Page 210 me for sexual acts or brought anybody or for sexual 2 acts. 3 BY MR. HOROWITZ: 4 Q. Did you tell the police that Jeffrey Epstein 5 had paid you thousands of dollars to bring 14 to 17 year 6 old girls to his home so he could masturbate? MR. CRM'ON: Form. DIE WITNESS: I don't recall that. 9 BY MR. HOROWITZ: 10 Q. Did you tell the police that Jeffrey Epstein 11 admitted sexually abusing Jane Doe 7? 12 A. No, he didn't admit to sexually abusing Jane 13 Doe 7. 14 Q. Did you ever have a conversation with him 15 about what took place with Jane Doe 7? 16 A. No. 17 Q. Did you ever have a conversation with Jeffrey 18 Epstein about what took place between him and Jane Doe 19 4? 20 A. Yes. 21 Q. Did you ever have a conversation with Jeffrey 22 Epstein as to what took place between him and Jane Doe 23 3? 24 A. No. 25 Q. Tell me everything that Jeffrey Epstein told Page 212 1 4 that Jeffrey Epstein said that she was one of his 2 favorites? 3 A. I don't terember. 4 Q. Was she — do you know — strike that. 5 How many times did you go to Jeffrey Epstein's 6 house with Jane Doe 4? A. I don't recall. 8 Q. Was it more than once? 9 A. Possibly. I don't recall. 10 Q. Was it at least once? 11 A. At least once. 12 Q. And you're not sure if it was more than once 13 then? 14 A. I'm not sure if it was more than once. 15 Q. Do you have a specific recollection about what 16 took place on the one occasion that you do recall? 17 A. No. 18 Q. Do you know whether you drove in a vehicle 19 with her to Jeffrey Epstein's house on that occasion? 20 A. I do remember an occasion me and Jane Doe 4 21 being in a car driving and pulling up to Epstein's house 22 in her mom's Buick. 23 Q. In her mom's Buick. And who was driving? 24 A. I don't remember. 25 Q. And were you an older, younger or in the same 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 211 you about what he and Jane Doe 4 talked about or did together. A. All he said was that she was like day and night She had this wild side to her and he had, like, a nickname of, like, or some ridiculous thing like that. It's the only thing we discussed when it came to Jane Doe 4. Q. You also told us that she was one of his favorites, correct? A. Yes. Q. And another one of his favorites wasl.; is that right? A. Yes. Q. And thinking about the two of them when they 14 were 16, 17 years old, did they share any common 15 physical characteristics? 16 A. No. 17 Q. Do they resemble each other physically? 18 A. No. 19 Q. Nothing at all? 20 A. No. 21 Q. Did you ever ask Jeffrey Epstein what he meant 22 when he said that Jane Doe 4 was one of his favorites? 23 A. No. 24 Q. Did you ever ask — did you ever tell Jane Doe 25 1 2 3 4 5 6 7 8 9 10 11 12 13 Page 213 grade as Jane Doe 4? A. I was in a grade above her. Q. Was she younger than you? A. That's right. Q. What grade was she in when you pulled up to Jeffrey Epstein's house with her? A. I don't recall. Q. Do you know if it was when she was in the ninth grade? A. No, I do not Q. Do you know if it was when she was in the tenth grade? A. N0,11 do not Q. Do you know if it was when she was in the 11th grade? A. No, I do not Q. And what took place after you and Jane Doe 4 arrived at Jeffrey Epstein's house? A. I don't remember. Q. Do you have a recollection of seeing her of her getting paid? A. No. Q. Do you have a recollection of you getting paid? A. No. PROSE COURT REPORTING AGENCY, Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 15 (Pages 210 to 213) INC. Ta82ddd1-59ee4e57-9cd8.8392056001c0 EFTA01076001 Page 214 Page 216 1 Q. Were you paid? 2 A. I don't remember. 3 Q. Do you know how long the two of you stayed at 4 his house? 5 A. No. 6 Q. Do you know if anybody else was home or in 7 Jeffrey Epstein's house when the two of you went? 8 A. I don't recall. 9 Q. Anything stand out or, you know, that you can 10 recall, other than what you've told us about the day 11 that you and Jane Doe 4 went to Jeffrey Epstein's house? 12 A. It was cold out. We went out afterwards. 13 Q. Anything else? 14 A. (Nods head.) 15 Q. Did no? 16 A. No. 17 Q. Did she tell you at any point what took place 18 on that particular day? 19 A. No. 20 Q. Did you ask her? 21 A. Yes. 22 Q. And what did she say? 23 A. I don't recall. 24 Q. Was it a weekday or weekend? 25 A. I don't know. 1 a vehicle together? 2 A. Yes. 3 Q. And had you scheduled this with M? 4 A. Yes. 5 Q. By telephone? 6 A. Yes. 7 Q. And who drove? 8 A. I don't remember. 9 Q. AM when you arrived, what took place? 10 A. I don't recall. 11 Q. Do you recall how long you were there? 12 A. No. 13 Q. Do you recall getting paid for bringing Jane 14 Doe 7? 15 A. Yes. 16 Q. Do you recall her getting paid? 17 A. I don't remember. 18 Q. Do you recall anything you told her about what 19 you thought might take place? 20 A. No, I don't remember. 21 Q. Do you recall if she told you what it is that, 22 in fad, did take place between her and Jeffrey Epstein? 23 A. I don't remember. 24 Q. Do you recall her going upstairs to the 25 massage room? Page 215 1 Q. Given that you were in high school when you 2 were recruiting these girls, was it fair to say you 3 would always go after school or on the weekends when you 4 went to Jeffrey Epstein's house? 5 A. It would be fair to say that it was either 6 after school or on the weekends. 7 Q. Would you ever miss school or go during school 8 to Jeffrey Epstein's house? 9 A. No. 10 Q. Did -- was Jeffrey Epstein familiar with your 11 school schedule, such that he could schedule 12 appointments after your school day ended? 13 A. No. 14 Q. Well, how is it — how did it come to be that 15 you would never get scheduled to come in during the 16 school day? 17 MR. CRITION: Form. 18 THE WITNESS: I don't know. It was usually 19 the weekends. 20 BY MR. HOROWITZ: 21 Q. How many times did you take Jane Doe 7 to 22 Jeffrey Epstein's house? 23 A. I know for sure once, but I can't be positive 24 anything else after. 25 Q. Tell me how — did the two of you ride over in Page 217 1 A. I don't remember. 2 Q. Did you set up the massage table that day? 3 A. Don't remember. 4 Q. Did you wait downstairs while she was giving a 5 massage? 6 A. I don't remember. 7 Q. Anything you do remember about the time you 8 spent at Jeffrey Epstein's house with Jane Doe 7? 9 A. No,1 don't remember. 10 Q. And you can't recall if it was more than once? 11 A. I can't recall. 12 Q. Are you aware whether or not she went more 13 than once to his house? 14 A. She did go more than once. 15 Q. You know that because she told you or some 16 other way? 17 A. Because she told me. 18 MR. CRITTON: We're on Jane Doe 7 now? 19 MR. HOROWITZ: Yes. 20 BY MR. HOROWITZ: 21 Q. And briefly just going back to Jane Doe 4, are 22 you aware whether or not she went more than once? 23 A. She definitely went more than once. 24 Q. And how do you know that? From her, Jeffrey 25 or some other place? 16 (Pages 214 to 217) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 7a82dddt-69ee-4e57-9cd8-8392056001c0 EFTA01076002 Page 218 1 A. Her, Jeffrey. Jane Doe 7 told me. 2 also told me a couple times. 3 Q. And in the case of Jane Doe 4, would you have 4 been paid your $200 introductory fee once or more than 5 once? 6 A. I don't remember. 7 Q. And what about with Jane Doe 7? 8 A. I don't remember. 9 Q. And next we're on to Jane Doe 3. Do you know 10 how many times you were there at Jeffrey Epstein's house 11 when she was also there? 12 A. I took her once. Anything after that I don't 13 remember. 14 Q. Go ahead. 15 A. I went once to take her for a massage and then 16 me and her brought another girl named'. So that's 17 twice I know that she worked with him, once that me and 18 her went together to take a girl. Other than that, I 19 don't know if she went back, how many times or who she 20 brought. 21 Q. The day when you brought this other girl named 22 I. — is that her name? 23 A. Yes. 24 Q. Was that a mutual friend of you and Jane Doe 25 3? Page 220 THE WITNESS: I mean, there was — the house 2 was -- there was always people in the house, 3 regardless if it was models, a chef, a chauffeur, 4 butler, whatever. There was always somebody in the 5 house. 6 BY MR. HOROWITZ: 7 Q. And do you recall ever talking to them? 8 A. I'm sure I did. 9 Q. Did anything — do you remember any of the 10 conversations you had or the subjects you talked about? 11 A. No. 12 Q. Did they ever feed you at that house? 13 A. I've eaten there, yes. 14 Q. Was it a meal you made yourself or someone 15 made it for you? 16 A. No. 17 Q. Who made it for you? 18 A. The chef. 19 Q. Did you ever lay out at the pool? 20 A. Not in a bathing suit. A girl upstairs was 21 giving a massage and I was laying out by the pool in my 22 clothes, just waiting for her to come downstairs. I 23 wasn't doing it to get sun. 24 Q. Getting paid while you were lying out at the 25 pool? Page 219 1 A. It was more so Jane Doe 3's friend, but I had 2 it to where me and her would split the profit. 3 Q. That was my next question, who got the 4 commission? 5 A. We split it. 6 Q. IIt n ui s lit it. Okay. 7 . went -- ME go upstairs to the 8 massage room? 9 A. Yes. 10 Q. Did you and Jane Doe 3 wait downstairs? 11 A. I don't recall. 12 Q. Do you recall anything about what you and Jane 13 Doe 3 did while you were in Jeffrey Epstein's house 14 while' was giving a massage? 15 A. I don't remember. 16 Q. Do you recall whether anyone was in the house, 17 Jeffrey Epstein's house? 18 A. I don't recall. 19 Q. Thinking back on it, when you would bring 20 girls over to Jeffrey Epstein's house and you would wait 21 downstairs while the girl and Jeffrey Epstein went 22 upstairs, was someone at his house watching you or 23 looking after you to make suit you didn't get into 24 trouble or take anything or -- 25 MR. CRITTON: Form. Page 221 1 A. Waiting for the girl to come downstairs, yes. 2 Q. Did you ever go kind of snooping around the 3 house, looking around to see the different rooms in the 4 house? 5 A. No. 6 Q. Did ever show you a datebook or 7 appointment book? a A. I don't remember. 9 Q. Did she ever show you a calendar where you 10 could sort of fit in your appointments? 11 A. No. 12 Q. Did she ever talk to you about having — 13 keeping a datebook -- 14 A. No. 15 Q. -- or a calendar with appointments? 16 A. A calendar, no. 17 Q. When — did Jeffrey Epstein ever take pictures 18 of you? 19 A. Not that I !mow of. 20 Q. When you went to his house, did you ever 21 notice there was surveillance cameras? 22 MR. CRITTON: Form. 23 THE WITNESS: No, I did not !mow that. 24 BY MR. HOROWITZ: 25 Q. Did -- did Jeffrey Epstein have anyone that VCAOL.4.ee'ves••••••1•4N 17 (Pages 218 to 221) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7082ddd1.59ee-4057-9cd8-839205600tc0 EFTA01076003 Page 222 1 you might characterize as a girlfriend or a partner? 2 A. Somebody that I can characterize as? 3 Q. Somebody that you — that you sort of looked 4 at and said, okay, that's his girlfriend? 5 A. Q. And what about their relationship led you to 1 think that they were boyfriend/girlfriend? 9 A. Just the way they were towards each other, how 9 she always helped him out. She always set his 10 appointments. There was one time — I don't know if I 11 was taking a girl upstairs or if it was my massage that 12 I gave him — but she was in the shower, coming out of 13 the shower with him. 14 Q. You were where? 15 A. I don't know. I can't remember if I was 16 bringing — if I had brought a woman up there to give a 17 massage or if I had -- was there to give him my massage. 18 But either/or I do recollect her and Epstein coming out 19 of the shower together. 20 Q. Okay. Appearing as if they had showered 21 together? 22 A. That's correct. 23 Q. And were they affectionate to each other? 24 MR. CRITTON: Form. 25 BY MR. HOROWITZ: Page 224 1 upstairs with one of the kids? 2 MR. CRITTON: Form. 3 THE WITNESS: I never heard anything. 4 BY MR. HOROWITZ: 5 Q. Is Jane Doe 7 someone that you considered a 6 friend at the time that you recruited her to go to' 7 Jeffrey Epstein's house? 8 A. Not necessarily a friend. A party buddy. 9 Q. Social — social acquaintance? 10 A. Yes. 11 Q. Someone that you had a good time with? 12 A. Yes. 13 Q. Is she someone that you would now go out and 14 have a good time with? 15 A. Never. 16 Q. What took place between then and now — well. 17 let me backup. 18 Do you not -- do you not like her at this 19 point in time? 20 A. I don't wish ill upon her. 21 Q. My question is: Do you not like her? 22 A. I don't like her. 23 Q. What took place between then and now that you 24 do not like Jane Doe 7? 25 A. When and I came home Page 223 1 Q. From your perspective did she appear to be 2 affectionate? 3 A. I don t recall. 4 Q. Would they say the types of things or call 5 each other, honey, sweetheart or anything like that? 6 A. Not that I can remember. 7 Q. Were they physically affectionate, meaning, 8 sort of touch each other in a way that a boyfriend/girlfriend might touch their partner? 10 A. Not that I saw. 11 Q. Did they ever kiss? 12 A. Not around me. 13 Q. When Jeffrey Epstein, when you came to his 14 house, would he ever kiss or embrace you when you saw 15 him each time? 16 A. No. 17 Q. I mean, he would just say, hello? 18 A. Yes. 19 Q. I hate to do this, but try and think back to 20 the day you were in his massage room and he's 21 masturbating, his hand is on his penis. Is he groaning, 22 making noises? 23 A. I can't recall. 24 Q. Did you ever hear Jeffrey Epstein groaning, 25 making noises while you were downstairs and he was Page 225 1 in tears sobbing, I was very emotional. It was a very jjjj 2 trying day forme. I had gone into my bedroom and I w•as 3 throwing things. I was very upset. 4 She came in and told me to put some clothes on 5 and to come out drinking with her and =. And I 6 just felt at that point in my life, I hit a low point 7 and you are supposed to be my roommate, you're supposed 8 to be my somewhat friend, acquaintance, we live 9 together, you have no heart, you show no love to me 10 after all these years and all you want me to do is go 11 and get completely annihilated with you? 12 Q. Is that the reason you don't like her anymore? 13 A. That's one of the reasons. 14 Q. I'm trying to get a full list or if there's -- 15 or however many masons there are. 16 What are the other reasons you don't like Jane 17 Doe 7? 18 A. She -- when me and her, we would go out and 19 party sometimes, every guy I would talk to she would end 20 up with at the end of the night A lot of back 21 stabbing. Her and Jane Doe 4 would go behind my back 22 and talk very bad about me and say things and judge me, 23 which friends don't do. That's why I classify her as a 2 4 party buddy. 25 Q. Okay. 18 (Pages 222 to 225 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddd1.59ee•4o57.9cd8-839205600fc0 EFTA01076004 Page 226 1 A. Other than that, I don't have a personal 2 vendetta against her. 3 Q. Does anything — I asked you if you don't like 4 her and you said, yes. Does any of the reasons you 5 don't like her have anything to do with Jeffrey Epstein? 6 A. Yes. 7 Q. I'm trying to get all these reasons out of 8 you. Tell me all the reasons. 9 A. She volunteered for this. 10 Q. You don't like her for that reason? 11 A. She volunteered for this. I didn't. I've 12 paid a higher price than I feel she has. AM everybody 13 knew what they were getting themselves into prior to 14 this. 15 Why am I sitting here having to explain myself 16 while you party it up? 17 Q. You don't like her because she volunteered- 18 A. Togo. 19 Q. to go to Jeffrey Epstein's house? 20 A. That's correct. 21 Q. Unlike you, who — did you volunteer? 22 A. I volunteered, too. 23 Q. And would it be a fair statement you don't 24 want her to get any money in this lawsuit; is that 25 right? Because you don't like her? Page 228 1 this lawsuit berimce she's a bad -- you don't like her? 2 A. I don't care. I don't care either way. 3 MR. CRTITON: Form. 4 BY MR. HOROWITZ: 5 Q. You don't care either way. 6 It would be okay with you if she gets millions 7 of dollars for her pain and suffering? 8 A. Sure. 9 Q. What are all the reasons you don't like her? 10 A. Oh, one of the guys I was dating she was 11 sleeping with behind my back. Didn't find out until 12 later. As well as her lies build up. When we were 13. party buddies, like I said, her and Jane Doe 7 did a lot 14 of scheming and scamming behind my back, a lot of lies. 15 What else? We got into a fistfight my 16 sophomore year of high school. 17 She also told me that she was not suing 18 Jeffrey Epstein and that she thinks Jane Doe 7 is a 19 complete idiot and a moron and then goes behind my back 20 thinking that I'm dumb and Is a complete hypocrite. 21 Q. Anything else? 22 A. She lets men beat on her. That's why I don't 23 like her. 24 Q. You don't like her because men beat on her and 25 she doesn't put up a fight? Page 227 1 A. I can't care either way. 2 Q. You don't care whether she gets money? 3 A. She's out of my life. That's all I know. 4 Q. Would it be okay with you if she gets millions 5 of dollars for the pain and suffering she endured? 6 MR. CRTITON: Form. 7 THE WITNESS: That's fine. 8 BY MR. HOROWITZ: 9 Q. Jane Doe 4. Is she someone that you 10 considered a friend when you recruited her to go to 11 Jeffrey Epstein's house? 12 A. Party buddy. 13 Q. Not a friend? 14 A. Not a friend. 15 Q. Never was a friend? 16 A. Never was a friend. 17 Q. Do you like her now? 18 A. No. 19 Q. You — that's someone you really don't like? 20 A. Don't like her. 21 Q. You don't like her? 22 A. I don't like her. 23 Q. You see her, you go the other way? 24 A. Oh, yes. High tail it. 25 Q. And you don't want her to get any money in Page 229 1 A. She doesn't do anything. It's weak. 2 Q. Any other reasons you don't like her? You've 3 given us a few. Tm trying to find all of them. 4 A. I can't think of any other reason why I 5 wouldn't like her. 6 Q. Who is the boyfriend that you said she was 7 with? 8 A. The guy I was dating at one point in my life, 9 1 was dating him, went to bed, woke up in the middle of 10 the night and his pants were around the ankles in the 11 kitchen with Jane Doe 4. 12 Q. And who is that? 13 A. 14 Q. And you said you had a fistfight with her. 15 When was that? What grade was that? 16 A. I don't recall. 17 Q. Was it before or after you introduced her to 18 Jeffrey Epstein? 19 A. I can't remember. 20 Q. It could have been before? 21 A. Could have been before. 22 Q. Did you patch up that issue, such that you 23 were able to have a conversation and tell her how to 24 make money and make yourself money? 25 MR. cRrrron nw=====i PROSE COURT REPORTING Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 19 (Pages 226 to 229) AGENCY, INC. 7a82ddctf-59ee-4857-9cd8-8392056001c0 EFTA01076005 Page 230 1 THE WITNESS: We eventually patched things up. 2 BY MR. HOROWITZ: 3 Q. And do any of the reasons that you don't like 4 Jane Doe 4 have anything to do with Jeffrey Epstein, 5 other than, I think you told us she denied being a 6 Plaintiff in the lawsuit? 7 A. Yes. 8 Q. What reasons are there pertaining to Jeffrey 9 Epstein? 10 A. Same thing as Jane Doe 7. You volunteered, 11 you knew yourself what you were getting into. You were 12 a hypocrite to my face, told me that it's stupid for 13 Jane Doe 7 to sue. You disagree with her decision. You 14 go behind my back, you do it. And then what? This is 15 it? I don't — I don't care for either one of them. 16 Q. And, so, because of that, you don't think 17 she's been harmed. You don't want to see her get any 18 money because she volunteered for it; is that correct? 19 MR. CRITTON: Form. 20 MR. BLANTON: Object to form. She's asked and 21 answered that before. 22 THE WITNESS: I don't care either way. 23 BY MR. HOROWITZ: 24 Q. Is it your opinion that Jane Doe 4 should tell 25 everyone that she's a Plaintiff in the lawsuit? Page 232 1 A. I found out, like, two days later. 2 Q. That she what? 3 A. Was a Plaintiff. 4 Q. Do you know if at that point she had filed a 5 lawsuit? 6 A. Yes. 7 Q. You know that because who told you? 8 A. 9 Q. And, in fact, you knew when Jane Doe 4 lied — 10 you knew when Jane Doe 4 told you that she wasn't a 11 Plaintiff that she was a Plaintiff? 12 MR. BLANTON: She's already answered that 13 question. 14 THE WITNESS: I already answered. 15 BY MR. HOROWITZ: 16 Q. Isn't it true you sent her a text message 17 saying, I always knew you were a Plaintiff? 18 A. Yes. 19 Q. In fact, even when she told you she wasn't, 20 you knew she was, correct? 21 A. No. 22 MR. BLANTON: She's answered that three times. 23 BY MR. HOROWITZ: 24 Q. But why would you send her an e-mail saying 25 that, in fact, you knew she was? Page 231 1 A. No. But she shouldn't deny it. 2 Q. She should answer truth -- she should answer 3 to everyone that, in fact, she's a Plaintiff, if anybody 4 asks her? 5 A. Yes. 6 Q. Did you know the answer before you asked her? 7 A. No. 8 Q. So you believed her when she said she wasn't a 9 Plaintiff? 10 A. Yes. 11 Q. And it upsets you that she didn't want to tell 12 you that she was a Plaintiff? 13 A. No. It upsets me that she lied to my face and 14 was fake to my face and told me one thing and then went 15 behind my back and did another thing. That's scandalous 16 and ifs not right. 17 Q. What's the other thing she did? 18 A. She told me to my face that she wasn't a 19 Plaintiff and that she disagreed. It's not the fact 20 that she didn't want to tell me. She could have just 21 said, it's not your business. But for her to lie to my 22 face and then put down somebody else for the same thing 23 you're doing is a little hypocritical. 24 Q. Do you know if, in fact, she was a Plaintiff 25 at the time she denied being a Plaintiff? 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 233 A. Because I wasn't going to let her have the satisfaction of thinking she threw me for a loop, thinking that she had ono over me. Q. So she —you lied to her? A. Yes. Q. You lied to her so that she wouldn't think that she got one ova on you? A. Yes. Q. Okay. lane Doe 3. Is she someone you can -- at the time you recruited her, is she someone you considered a friend? A. No. Q. Was she ever a — I think you called a Icyparty— A. Party buddy. Q. Party buddy? A. No. Q. Do you have any feelings for her one way or the other today different than when you did then? A. I have nothing bad or good to say about her. Q. Okay. Are you friends with anybody who you are aware of has filed a lawsuit against Jeffrey Epstein? A. No. MR. CRITTON: Object to the form. She may not 20 (Pages 230 to 233) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 lati2dddl.Sece-4057-9cd8.819205600fc0 EFTA01076006 Page 234 1 know. 2 MR. HOROWITZ: That's the way I framed the 3 question the way I did. I said, that you are — 4 MR. CR1TTON: Oh, okay. 5 BY MR. HOROWITZ: 6 Q. You told us that you have not caranunicated -- 7 have you communicated with Jeffrey Epstein since his 8 arrest? 9 A. No. 10 Q. And how is it that you ended up with an 11 attorney who he is paying for, if you have not 12 communicated? 13 MR. BLANTON: Object to the form. Do not 14 answer that question. 15 We've had this conversation. She will not be 16 dittencsing that any further. 17 BY MR. HOROWITZ: 18 Q. You recall signing an affidavit in this 19 lawsuit? 20 A. Yeah. To be more specific, I've signed a lot 21 of paperwork. 22 Q. Do you recall signing, like, a sworn statement 23 that said — that detailed an encounter with a couple of 24 the Plaintiffs? You met one at and 25 another one at another nightclub? Page 236 1 MR. HOROWITZ: We may have to deal with that 2 one again. 3 BY MR. HOROWITZ: 4 Q. There was a girl named Ewho earned a 5 thousand dollars from Jeffrey Epstein? 6 MR. CRITION: Form. 7 THE WITNESS: What I heard. 8 BY MR. HOROWITZ: 9 Q. What you heard. Who recruited her? 10 A. 1 have no idea. 11 Q. Was she a High School student? 12 A. I have no idea. I know that she went to 13 I don't know where she went to high 14 school. She may have been a. 15 Q. And from — sorry. From who did you hear that 16 she earned a thousand dollars? 17 A. Jane Doe 101. 18 Q. Did Jane Doe 101 claim to have recruited..? 19 A. I'm sorry? 20 Q. Did Jane Doe 101 claim to have recruited.? 21 A. No. She never said either way. 22 Q. And what is — can you — 'don't think you've 23 spelled her last name for us. 24 A. I? 25 Q. Yeah. Page 235 1 A. I remember signing an affidavit about a 2 Plaintiff and me at an incident that we had at 3 yes. 4 Q. Did Mr. Epstein's attorneys ask you to sign an 5 affidavit pertaining to those facts? 6 MR. BLANTON: Do not answer that unless you 7 know it somehow other than speaking to me. And I 8 am your attorney. So if that aff -- if you had 9 dealings with that affidavit outside of my 10 presence, you may answer. Otherwise, you are not 11 to answer that question. 12 THE WITNESS: Okay. 13 BY MR. HOROWITZ: 14 Q. Did Mr. Epstein —1'm not interested in what 15 your attorneys said to you or asked you to do. Did 16 Mr. Epstein's attorneys ask you to sign an affidavit? 17 A. I don't know. 18 Q. You just did it because it felt right? How 19 did it come to be that you signed this affidavit? 20 MR. BLANTON: If you can answer that without 21 disclosing the conversations that you had with your 22 attorney. 23 THE WITNESS: I can't answer that. 24 MR. BLANTON: That information is privileged. 25 She will not be disclosing that. Page 237 1 A. I. 2 Q. And is he she older, younger, or the same? 3 A. Same age. 4 Q. Same grade, as far as you 'mow? 5 A. Yes. 6 Q. Yes. Okay. How many times would you estimate 7 that you have been to Jeffrey Epstein's home? 8 A. Estimate? 9 Q. Or if you know specifically, you can tell me. 10 But I was trying to help you out. 11 A. I don't know specifically. But if I'm telling 12 you that I brought about a dozen girls and sometimes 13 went more than twice, I think it would be fair to say 14 maybe two dozen times, a dozen and a half to two dozen 15 times maybe. 16 Q. Eighteen to 24 roughly? 17 A. Possibly. 18 Q. That's your best estimate? 19 A. Best estimation. 20 MR. HOROWITZ: Let's take a break and I'll try 21 to wrap it up and maybe Mr. Willits will have 22 questions. 23 VIDEOGRAPHER: Going off the record. The time 24 is 4:25 p.m. This is the end of tape number three. 25 (Brief recess.) 21 (Pages 234 to 237) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401= Electronically signed by Sandra Townsend (401 7a82dddf-59eo-4e57.9cd8.839205600fc0 EFTA01076007 Page 238 1 VIDEOGRAPHER: We're back on the record. The 2 time is approximately 4:30 p.m. This is the 3 beginning of tape number four. 4 BY MR. HOROWITZ: 5 Q. A few more questions. 6 On the occasions when you travelled with other 7 girls to see Mr. Epstein, before going to his home, did 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 either you or any of the other girls use alcohol or drugs? A. I didn't. Q. Did any of the girls that you travelled with or recruitexl to see him use alcohol or drugs before going to his house? A. i don't know. Q. You were asked earlier whether Mr. Epstein gave you money or gifts before, other than the cash he gave you for the massages and bringing girls. And you said, none; is that correct? A. That is. Q. Did he pay for anyone to render any services for you? A. No. Q. Did he open any doors, whether it be employment opportunities or other opportunities for you? A. No. Page 240 1 Q. What was it in a general sense that you were 2 journaling, if not your emotions and feelings? 3 MS. BLANTON: Are you asking with regard to 4 Jeffrey Epstein or her in general? 5 MR. HOROWITZ: No. 6 BY MR. HOROWITZ: 7 Q. My question was: In a general sense, what is 8 it that you were journaling or putting in a diary at 9 that period of time? 10 A. About things that were going on in my life, 11 just things that i was going through that — some didn't 12 even have anything to do with Epstein and M. And 13 sometimes I would just write about how I used to work 14 for him and whatever. But it was never anything like 15 emotional about him. it was more different things in my 16 life. 17 Q. If we were to open the pages of the journal, 18 we would see somewhere a reference to the fact that you 19 worked or used to work for him; it would say something 20 like that? 21 A. Possibly, yes. 22 Q. Would it say something about how you felt 23 about working for him or having worked for him? 24 A. I don't know. Possibly. 25 Q. What sort of things did you write about, Page 239 1 Q. Did he make offers to assist you in any way? 2 Professionally? Educationally? 3 A. No. 4 Q. Anything Ince that? 5 Did you ever ask Jeffrey Epstein for anything 6 other than the cash you were given for the massage and 7 the bringing of other girls? 8 A. Sorry. No. 9 Q. Did you ever keep a diary of the events, in 10 terms of your dealings with Jeffrey Epstein? 11 A. No. 12 Q. Did you ever keep a journal or a log of the 13 contacts_nLi had with the police or the State Attorney 14 or with = anything like that? 15 A. I kept a journal for my own self about what 16 was going on in my life, but nothing about and 17 Epstein specifically. 18 Q. Would there be a reference to either what 19 happened with Jeffrey Epstein or how you felt about it? 20 A. No. 21 Q. Would there be a reference to your emotional 22 state or how you were feeling at or about the time that 23 you went there or you were bringing other girls to his 24 home? 25 A. No. Page 241 1 having worked for Mr. Epstein? 2 A. I don't know. 3 Q. Would there be any reference to having worked 4 for him in a sense of bringing other girls to his home? 5 A. Possibly. 6 (Brief interruption.) 7 BY MR. HOROWITZ: 8 Q. Where is this journal? Do you have it at your 9 house? 10 A. I do not have it at my house. 11 Q. Who has your journal? 12 A. The last place m journal was, was with my old 13 roommates down in . And I left a bunch 14 of my belongings down there, so either it's thrown away 15 or she still has it. 16 Q. And who is "she? 17 A. 18 Q. 19 A. 20 Q. 21 A. 22 Q. 23 A. 24 street. 25 Q. Did Mg° to What is last name? I do not know. Where did u i with ' Down in by the beach. What street? I said by the beach. I don't know what High School? 22 (Pages 238 to 241) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddt-59ee-4o57-9cd8-8392056001c0 EFTA01076008 Page 242 Page 244 1 A. No. 2 Q. Where did go to high school? 3 A. I don't ;mow. 4 Q. How did you know M? 5 A. We worked together. 6 Q. Where did you work together? 7 A. We danced together. 8 Q. Okay. And what dance club was that? 9 A. A strip club. 10 Q. And do you know last name? 11 A. No, I do not. 12 Q. How long a period of tittle was it that you were 13 a stripper? 14 MS. BLANTON: rm going to object, .- 15 MR. HOROWITZ: What? 16 MS. BLANTON: — based on earlier concerns. 17 This is very private, personal information. With 18 regard to how it relates to Jeffrey Epstein, if you 19 have some sort of predicate or can explain the 20 relevance me know. I think you have a right 21 to ask = last name. She doesn't know it. 22 You have a right to ask where the name of the place 23 is if you want to try to find her. 24 MR. HOROWITZ: Thank you. That wasn't a form 25 objection. 1. 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. You she tried out. Q. And then what happened? It didn't work out? A. She got the job, but she was only up there visiting so she didn't keep it. She just wanted quick money. Q. What was the name of that club? A. Q. What were the other clubs that ou worked at? Q. A. Q. A. Q. A. Q. That's not a strip club? A. No, it's not a strip club. You've never heard of It's not a strip club. Q. What do you do at A. have. I wait tables. MR. CRITTON: You're not local. I take that back. You can only ask the question. BY MR. HOROWITZ: Are you currently working? Yes. Where are you currently working? Page 243 1 BY MR. HOROWITZ: 2 Q. Where did you dance? 3 A. A lot of places. 4 Q. Give me the names of the clubs that you worked 5 as a stripper. 6 MS. BLANTON: I'm going to object based on 7 privacy. I do not think she needs to answer that. 8 I don't think it has any relevance to this lawsuit. 9 BY MR. HOROWITZ: 10 Q. Did you work as a stri per with any of the 11 girls who went to High School? 12 A. Not thatl know of, no. 13 Q. Did any of the girls who you brought to 14 A. Actually, I take that back Jane Doe 4 came 15 to visit me in and I took her to the strip club 16 1 worked with up there and she stripped. 17 Q. She went one time? 18 A. Yes. 19 Q. How long did she strip for? 20 A. Maybe three hours and then we left the club. 21 Q. It's your testimony she stripped for three 22 hours? 23 A. Yep. Yes. 24 Q. And was she on, like, the payroll? She was 25 hired by the — by the strip club the day she went? 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 245 Q. How old were you when Jane Doe 4 came to see you at the strip dub you were wetting at? A. In Q. Yes. A. I want to say that I was just turned 20. Q. And I'm ptering that since Jane Doe 4 came to visit you in whatever arguments you had in high school, the fistfight, problems with the boyfriend or ex-boyfriend, you had kind of worked those things out by the time she came to visit you in M? MR. CRITTON: Form. THE WITNESS: Because of my living circumstances with Jane Doe 7, I put our differences aside as respect for my roommate. BY MR. HOROWITZ: Q. So Jane Doe 7 was your roommate in while — and she was going to school there? A. That's correct. Q. How did it come to be that you were no longer roommates with Jane Doe 7? A. After that everybody just split up. My parents wanted me to come home. This whole stein case had 'ust blown up the same week They felt it would be more beneficial for my health that I come home and ••• ••••••••... 23 (Pages PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 242 to 245) 7a82cIddf.59et-4e57-9cd8-8392056001c0 EFTA01076009 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 246 deal with it as a family, instead of being in Q. How did it come to be when you came to live with Jane Doe? in A. I wanted out of I was tmhappy living at my home. I had just been interrogated by the police about the whole Epstein situation. So I thought it would be good to get out or and start off kind of fresh somewhere else. which was lane Doe Ts roommate, said she wanted to move back home. Her boyfriend wanted to as well. So I took her lease over in the loft. Q. What was the name of the strip club you worked at with A Q. MR. HOROWITZ: Thanks. I don't have any further questions at this point in time. MR. CRITTON: Dick, you're on. MR. WILLITS: Thank you very much. CROSS EXAMINATION BY MR. WILLITS: Q. Mr. Kuvin has a picture that I would like for him to show you now of a young lady. MR. KUVIN: One of us does. Yeah. IR hold Page 248 MR. KUVIN: I've given it to the witness, 2 Dick. 3 BY MR. WILLITS: 4 Q. Do you recognize that young lady? 5 A. No. But she kind of looks like that girl that 6 killed her kid on tv. What's her name? No. Cayley, 7 the whole Cayley Anthony. It resembles her, but I've 8 never seen this girl in my life. 9 Q. Okay. Thank you very much. 10 I want to change the subject and ask ou: 11 When is the last time you talked to 12 A. Oh, it's been a very long time. Eighteen? 13 When I was 18 years old. After I brought I cut off 14 ties. 15 Q. And where did that conversation take place? 16 A. At Epstein's house. 17 Q. And what was it about? 18 A. I don't know. I don't remember. 19 We didn't end on bad tams. It was just after 20 I brought the last girl, I just never spoke to them 21 again. 22 MR. WILLITS: I don't have any other 23 questions. 24 MR. HOROWITZ: Neither does Bob. 25 CROSS EXAMINATION Page 247 1 it up. 2 MR. CRITTON: Can we mark it as the next 3 Exhibit? 4 MR. HOROWITZ: Let's show it to the camera. 5 MR. KUVIN: Do you want to mark it? 6 MR. WILLITS: Well, don't we have some sort of 7 a— do we have a deal or not? 8 MR. CRITTON: Yeah. We're not — the pictures 9 remain with the lawyers, you know, within the 10 confines of the files anyway. They're not going to 11 be filed. 12 MR. WILLITS: Okay. Sure. Mark it. 13 MR. KUVIN: This will be Plaintiffs 5. And, 14 Dick, give me one second to just show it to the 15 camera. 16 (Exhibit number 5 was marked for 17 identification purposes.) 18 MR. CRITTON: You know, it's probably not a 19 bad idea for the court reporter — are you 20 attaching Exhibits to the depositions? 21 VVIrat you should do is probably put the 22 Exhibits in a separate envelope and put a sticker 23 on it as warning if it tells us the original, 24 whoever gets the original, they don't erroneously 25 file something. Page 249 1 BY MR. CRITTON: 2 Q. My name is Bob Critton. I represent 3 Mr. Epstein. 4 Is it okay if I call you M? 5 A. Yes. 6 Q. M, you've been asked — let's see. We 7 started today at 11:00. It's about quarter to 5:00 and 8 I think we took about 45 minutes to an hour for lunch 9 and we've had a couple other breaks. So I know you've 10 been here a long time, but you've also covered a lot of 11 territory that I need to kind of work my way back 12 through. 13 If I understand it from your testimony 14 well, let me ask you this first: Mr. Kuvin, who spent 15 the better of the day with you represents a person rt 16 named I think during one of his last few questions 17 he asked you whether you knew her. And I think your 18 response was you've never heard of her, correct? 19 A. That's correct. 20 Q. In the other approximately four hours' worth 21 of uestioning, did he ever ask you one question about 22 M.? 23 A. No. 24 Q. All right. With regard to Mr. Epstein, if I 25 understood your earlier testimony, is, you learned about 24 (Pages 246 to 249) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddd1-59ee.4e57.9cd8.839205600fc0 EFTA01076010 Page 250 1 Mr. Epstein who was referred to as Jeff or Jeffrey from 2 Jane Doe 101, correct? 3 A. Yes. 4 Q. All right. And that occurred at a bar railed 5 or a restaurant/bar called, =, which is on the 6 beach in Florida? 7 A. Yes. 8 Q. And Jane Doe 101 basically said something to 9 the effect, is, after you had a discussion with her and 10 casual friend is, is, would you like to make a couple 11 hundred bucks? 12 A. Yes. 13 Q. And when she — and if I also understood your 14 testimony, is, she basically said, depending on how 15 you're dressed, you may cam a little bit more, a little 16 less money; is that aftin statement? 17 MR. HOROWITZ: Object to the form. 18 MR. KUVIN: Join. 19 MR. WILLITS: Object to the form. 20 THE WITNESS: I'm sorry. Can you repeat the 21 question? 22 BY MR. CRITTON: 23 Q. Sure. If I tmderstood what Jane Doe 101 said 24 to you, is, she said a number of thing, is, Jeff- 25 Jeffrey lived in Palm Beach, had a big house, that you Page 252 1 MR. HOROWITZ: Form. 2 MR. KUVIN: Join. 3 THE WITNESS: Yes. 4 BY MR. CRITTON: 5 Q. Did Mr. Epstein at any time try to use any 6 force or coercion or any type of physical force towards 7 you? A. Never. 9 Q. Did he ever threaten you in any way, either 10 physically or verbally? 11. A. No. 12 Q. Did you find him to be, at least in your 13 discussions with him, to be soft spoken; that is, he was 14 nice to you? 15 A. Yes. 16 MR- KUVIN: Objection to form. 17 BY MR. CRITTON: 18 Q. Was he ever not nice to you or ever rode to 19 you in any fashion? 20 A. Never. 21 MR. HOROWITZ: Form. 22 MR. KUVIN: Join. 23 BY MR. CRITTON: 24 Q. Were you at any time 25 MR. WILLITS: Form. Page 251 1 would give him — that you would be required to give him 2 a massage, and that's pretty that's at least some of 3 the information that she provided, correct? 4 A. Yes. 5 Q. Did she tell you what you should wear or 6 suggest what you should wear in any way? 7 A. No. 8 Q. Did she at that time tell you that if you wear 9 something or if you take something off, you might get 10 paid a little bit more money? 11 MR. HOROWITZ: Object to the form. 12 MR. KUVIN: Join. 13 THE WITNESS: No. 14 BY MR. CRITTON: 15 Q. And, so — and that's pretty much what you 16 knew about Mr. Epstein or Jeff until you got to the 17 house? 18 A. Yes. 19 Q. And if I understood your testimony in response 20 to questioning by Mr. Kuvin and Mr. Horowitz, is, you 21 went upstairs, you gave the massage. He during the 22 course of the massage he reached towards you, you said, 23 in essence, stop. and that was the end of him in any vary 24 towards you or attempting to touch you; is that a 25 correct statement? Page 253 1 BY MR. CRITTON: 2 Q. — concerned about your safety being in 3 Mr. Epstein's home? 4 A. That's absurd. 5 Q. Okay. So the answer is no? 6 A. No. 7 Q. Were you — did you at any time even 8 contemplate yelling or screaming or crying for help at 9 any time that you were around Mr. Epstein? 10 A. No. 11 Q. Were you ever with anyone in his home, at any 12 time were you afraid or fearful or concerned at all 13 about your safety? 14 A. No. 15 Q. After the one occasion that you were at 16 Mr. Epstein's home and you gave him a massage, ill 17 understood your testimony, you never gave him another 18 massage? 19 A. I never gave him another massage. 20 Q. But, in fact, you did bring a number of girls, 21 which 1 think you described to be approximately 12,12 22 different people, some people more than once, but 12 23 different people that you can recall approximately? 24 A. Yes. 25 Q. And they were females? 25 (Pages 250 to 253) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-5See-4e57-9cd8-8392056001c0 EFTA01076011 Page 254 1 A. Yes. 2 Q. We know that. All right 3 A. That I know of, yes. 4 Q. And of the females that you brought, if I 5 understood your testimony, as to all of those girls you 6 basically had or provided pretty much a standard talk or 7 a standard — you had kind of a standard explanation as 8 to what would occur, is that a fair statement? 9 A. That is a fair statement. 10 Q. And if I also understood your testimony, is, 11 after you brought one or two girls, that the word kind 12 of got around in your circle of your friends and/or 13 acquaintances and a lot of people wanted -- a number of 14 other females wanted to come and to give Mr. Epstein 15 massages at his home? 16 MR. KUVIN: Fenn. 17 THE WITNESS: Yes. 18 BY MR. CRITTON: 19 Q. And if I understood as well what you said, is, 20 the little speech or the information that you provided 21 the girls was, is that, there was a man in late forties, 22 early fifties, you could make some money, you could give 23 him a massage, you would go to his house, he's got a 24 nice house in Palm Beach, he's a billionaire, he's nice, 25 you don't have to be scared, you know, you don't have to Page 256 1 reservations about going; that is, did you have to try 2 to cajole these people or encourage them to go or did 3 all of the 12 basically once you told them what was 4 going on and that they could make a couple hundred 5 bucks, did all of them willingly go? 6 A. Yes. 7 Q. As to the girls that went, what I also 8 understood your testimony, I think it was in response to 9 Mr. Horowitz's questions, is that — is, I think, as you 10 said — I think your testimony was, is, you told them, 11 in essence, what Jane Doe 101 had told you; that is, if 12 they go -- if they — if they do a massage dressed, 13 they'll make approximately X amount of dollars. If they 14 leave just their bra on or if they take their skirt or 15 their pants off or if they go topless, then they might 16 make some additional money? 17 MR. HOROWITZ: Form. 18 MR. KUVIN: Join. 19 THE WITNESS: Yes. 20 BY MR. CRITTON: 21 Q. And the girls that you talked to, that is, the 22 12 approximately girls that you brought, did any of them 23 ever express to you any reservations or any concern 24 about after you told them that they might be asked to 25 go topless or to take off their shirt or to do the Page 255 worry about anything when you're there? 2 A. Mats correct. 3 Q. Did you tell them — did you tell these girls 4 that he would be respectful towards them? 5 A. Yes. 6 Q. Did you tell them that at no time would they 7 ever experience any type of physical force or violence 8 or any type of coercion? 9 A. Yes. 10 Q. And did you tell them that — that you had 11 never been afraid? 12 A. Yes. 13 Q. All right. And did some of the people who -- 14 well, let me ask it this way: Of those girls, did you 15 tell all of them to tell Mr. Epstein that they were DI 16 years old or older? 17 A. I told all of them to lie about their age. 18 Q. And you told them to lie about their age? 19 A. That's correct. 20 Q. And did any of them, that is, did any of the 21 12 girls that you took, did any of them express any 22 cancent about lying about their age? 23 A. No. 24 Q. Did any of them express, that is, any of the 25 12 girls that you took, did any of them ever express any Page 257 1 massage in their bra and a thong or maybe even with only 2 partially clothed, did any of those girls after you told 3 them that, express any reservation or concern? 4 A. No. 5 Q. Now, of the 12 girls that you took to 6 Mr. Epstein's home in some fashion, did you transport 7 them all or did some of them get there by themselves or 8 pick you up and take you there? 9 A. Sometimes I drove. Sometimes they drove. 10 Q. And of the of the females that went to 11 Mr. Epstein's home, the 12 -- and I'm talking about just 12 their initial visits, and that would include Jane Doe 4, 13 Jane Doe 7 and Jane Doe 3, all who are three Plaintiffs 14 in three separate cases here, and — did any of those 15 girls, including those three, ever express when they 16 came down from being upstairs with Mr. Epstein that they 17 were scared or fearful of anything that had occurred at 18 the house? 19 MR. HOROWITZ: Form. 20 THE WITNESS: No. 21 BY MR. CRITTON: 22. Q. Did any of those girls during the time — did 23 any of those females during the time that they were 24 upstairs at any time yell, scream or cry for help? 25 A. No. Foundation. 26 (Pages 254 to 257) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7aB2dddf-59ce4e57-9cd8-8392056001c0 EFTA01076012 Page 259 1 Q. Did myone, other than the one person that you 2 mentioned, M., I think was her name -- 3 A. Uh-huh. 4 Q. -- who was complaining about the amount of 5 money or that she and Mr. Epstein had gotten into a 6 dispute about the amount of money -- did any of them 7 ever explain to you or tell you that they had had any 8 problem with what occurred with Mr. Epstein upstairs? 9 A. No. 10 Q. Did any of them — let me strike that. 11 Let me focus on the one person who complained 12 about the money, Ms.I.,.. Did she ever — other 13 than saying she thought instead of getting 200 or 14 whatever the number was she should have gotten 300, was 15 that the extent of her complaint? 16 A. Yes. 17 Q. Did she ever complain or suggest to you that 18 she had -- that there had been any type of verbal or 19 physical abuse or any inappropriate conduct that had 20 caused her any problem or that she complained about? 21 A. No. 22 Q. Did Ms. — M. go back again, to your 23 knowledge? 24 A. No. She wanted to, but I didn't feel 25 comfortable bringing her back after the dispute, the Page 26G 1 MR. HOROWITZ: Objection. Fenn. Cumulative. 2 MR. KUVIN: Join. 3 THE WITNESS: No. 4 BY MR. CRITTON: 5 Q. Did — with the individuals that went back, 6 did that include Jane Doe 7 and Jane Doe 4; that is, 7 they went multiple times that you're aware of? 8 A. Yes. 9 Q. And did that include Jane Doe 3? 10 A. I don't know. 11 Q. You know for sure she went one time and you 12 know she went another time when you and Jane Doe 3 took 13 another.? 14 A. Yes. 15 Q. At the time that -- let me strike that. 16 Th.. that %vas — you and Jane Doe 3 took, 17 did Jane Doe 3 ever express any concern to you or 18 complaint that maybe it would be inappropriate to take 19 I. because something bad or inappropriate or humiliating 20 or emotionally disturbing had occurred with her? 21 A. No. 22 MR. KUVIN: Objection to form. 23 BY MR. CRITION: 24 Q. Did Jane Doe 3 ever tell you that as a result 25 of the, at least one visit she had with Mr. Epstein, Page 259 1 first dispute between them. 2 Q. So., even though she had a dispute 3 apparently with Mr. Epstein over money, she then came I back to you and asked if she could go back again? 5 A. She wanted to work for him again. And he pretty much made it clear that, you know, the whole argument was unnecessary and then I felt uncomfortable 8 bringing her back, so I wouldn't bring her back. I told 9 her no. 10 Q. And, so, despite -- despite the financial 11 dispute, did it appear there had been any other problem 12 or any other issue or any other inappropriate actions by 13 Mr. Epstein that would have suggested to you — well, 14 let me stole that. 15 MR. HOROWITZ: Objection. Cumulative at this 16 point, whatever your next question is. 17 MR. CRITTON: Ill withdraw that question. I 18 think live finished with M. 19 BY MR. CRITTON: 20 Q. Let me -- with the other I I females, separate 21 and apart from.., did any of than ever complain to 22 you at any time, whether it was the first or second 23 visit or third, that they that anything that had 24 occurred with Mr. Epstein was inappropriate or that — 25 or that they complained about? Page 261 1 that she suffered any type of emotional or mental 2 trauma? 3 A. No. 4 MR. HOROWITZ: Form. 5 BY MR. CRITTON: 6 Q. Did she ever tell you, Jane Doe 3, at any time 7 after she went to see Mr. Epstein and when she took. 8 that she was concerned about.. suffering some sort of 9 emotional or mental anguish or trauma or psychological 10 or psychiatric damage? 11 A. No one ever complained of that. 12 Q. Well, I want to stick just with Jane Doe 3. 13 Did she ever complain about that? 14 A. No. 15 Q. Did. Jane Dee 4 at any time after the first 16 visit or the second or any other visits that you knew 17 she had with Mr. Epstein, did she ever express to you 18 that she was humiliated by the experience? 19 MR. HOROWITZ: Cumulative. 20 THE WITNESS: No. 21 BY MR. CROFTON: 22 Q. Did she, Jane Doe 4, ever tell that you she 23 was embarrassed by having been with Mr. Epstein on the 24 multiple occasions? 25 MR. HOROWITZ: Form. 27 (Pages 258 to 261) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7482dcldf-69ev-4o57-9cd8-8392056001c0 EFTA01076013 Page 262 Page 264 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE WITNESS: No. MR. CRITTON: Form. How can I correct it? MR. HOROWITZ: You cant. Cumulative. You have asked the same question six different ways and you already have the answer. And now you're using words. You're using synonyms. MR. CR1TTON: Pm sorry I asked. MR. KUVIN: You asked. MR. HOROWITZ: Like a Thesaurus. How many different ways can you say anguish, trauma. BY MR. CRITTON: Q. M, did Jane Doe 4 ever tell you she had sustained any type of emotional or psychological trauma? A. No. MR. HOROWITL Cumulative. THE WITNESS: It's Jane Doe 4 though. Sony. BY MR. CRITTON: Q. i MR. KUVIN: Now he's going to reask all the questions. BY MR. CRITTON: Q. Did Jane Doe 3 or Jane Doe 4 — A. Yes. Q. — ever tell you that they had lost income as 1 A. Yes. 2 Q. Did she ever express to you as a result of 3 having been with Mr. -- the time she spent with 4 Mr. Epstein that she was required to see a psychologist 5 or psychiatrist or any other health care professional? 6 A. She did tell me something about that 7 Q. And when did she tell you that? A. When I moved back down here when her, 9 and I started hanging out. 10 Q. And what did she tell you? 11 A. Well, she didn't tell me directly. She told 12 that she had to go see a thai , her and Jane 13 Doe 7 had to see some therapist in and they flew 14 her out there and they had to fake cry and they had to 15 pretend like they were damaged. They had to pretend 16 that they were being molested. And Jane Doe 7 was 17 laughing about it. This is according to what 19 told me. 19 Q. Okay. Separate and apart from that incident, 20 did Jane Doe 4 ever tell you that she had seen a 21 psychiatrist or psychologist as a result of any contact 22 that she had had with Jeffrey Epstein? 23 A. No. 24 . B the way when Jane Doe 4 was dancing at 25 in EM, and you said thes a strip I Page 263 1 a result of being — of having gone to Mr. Epstein's 2 home? 3 A. No. 4 Q. Did any of them, did either Jane Doe 3 or Jane 5 Doe 4 ever tell you that their economic -- their ability 6 to earn money in the future had in some way been 7 impacted? 8 A. No. 9 Q. Did Jane Doe 3 ever tell you as a result of 10 seeing Mr. Epstein that she was required to see a 11 psychologist or psychologist? 12 A. No. 13 Q. Did Jane Doe 4 ever tell you — and apparently 14 you saw her for a number of years following the time 15 that she — she was at Mr. Epstein's home, correct? And 16 you saw Jane Doe 4 even when she was at college or 17 during the time she was at college at University? 18 A. Yes. 19 Q. And ifl understood your response to 20 Mr. Horowitz's question, you even got to see her strip 21 up at —what was it? 22 A. 23 Q. 24 A- Yes. 25 Q. -- up in for three hours, right? Page 265 1 club? 2 A. Yes. 3 Q. And you said she tried out? 4 A. Yes. 5 Q. For, I assume, the manager? 6 A. The whole club. 7 Oh. So Jane Doe 4, the player from 8 =University, was she in college at the time? 9 A. Yes. 10 Q. All right. And was she kind of a shy person? 11 A. No. 12 Q. And I think you also described -- described 13 one of the instances why you don't respect her or don't 14 think highly of her was, is that, you found her or 15 your — who you thought was your boyfriend having sex 16 with Jane Doe 4? 17 A. It was a guy that I was dating and she was 18 having oral sex with him. 19 Q. Okay. 20 MR. HOROWITZ: Move to strike. 21 BY MR.. CRITTON: 22 Q. Well, you saw it yourself? 23 A. I walked in on them, yes. 24 Q. All right. And she was giving him oral sex at 25 the time? PROSE COURT REPORTING AGENCY, Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 28 (Pages 262 to 265) INC. 7a82dddf-69eo4e57-9cd8-839205400k0 EFTA01076014 Page 266 Page 268 1 A. That's correct. 2 Q. And did you say anything? 3 A. We almost got into a second fight. 4 Q. And when she came up, so to speak, when she — 5 you said something to her, did she stop what she was 6 doing and then stand up? 7 A. Well, she had been drinking and she kind of 8 got up off the floor and she got in my face. We had a 9 little bit of an altercation. And he pretty much got in 10 between us and I walked away. 11 MR. HOROWITZ: Move to strike. 12 Non-responsive. 13 BY MR. CRITTON: 14 Q. And the male's name was? 15 A. 16 Q. Was she, Jane Doe 4, dating anyone at the 17 time, to your knowledge? 18 A. I don't remember. 19 Q. Approximately what time — what time period 20 are we dealing with? 21 A. We were definitely in high school. I can't be 22 accurate about the years. 23 ■Q. Oh, okay. All right. Let me go back to. 24 25 A. 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 MR. KUVIN: Fonn. THE WITNESS: Yes. BY MR. CRITTON: Q. Did she tell you they asked her to stay or to come back? A. The manager came to me specifically and asked me if she wanted the job. Q. And of course she had to go back to college? A. Yes. Q. Let me be specific now with regard to Jane Doe 7. Jane Doe 7. I think you testified you were aware that she went to Mr. Epstein's house on a number of occasions? A. Yes. Q. You took her once and you may have gone back one or more occasions with her? A. Possibly. Q. But you were aware from — what? -- from speaking with her that she had gone beck on multiple occasions? A. Yes. Q. And I think you told us earlier neither Jane Doe 4 nor Jane Doe 7 nor Jane Doe 3 described what actually occurred? Page 267 1 Q. . When she you say she tried 2 out for the whole club. What time of day was it that 3 she was trying out? 4 A. I can't be sure. 5 Q. Evening? 6 A. It was evening. 7 Q. And were there patrons in the place? 8 A. Yes. 9 Q. And wear a costume? 10 A. No. 11 Q. What did she do? What did you see her do? 12 A. Dance in her thong and pasties. 13 Q. All right. Did she tell you afterwards she 14 enjoyed it? 15 A. Yeah. She said she made good money. 16 . So that she tried out, she -- at a strip club, 17 in M. She danced for about three 18 hours and made good money? 19 A. Uh-huh. 20 Q. Yes? 21 A. Yes. 22 Q. And could she have come back there to her work 23 there if she didn't have to go back to school? 24 A. Yes. 25 Q. From at least what you observed? Page 2C 1 A. That's correct. 2 Q. And because you weren't upstairs, you don't 3 know what occurred with them? 4 A. That's correct. 5 Q. And with regard to Jane Doe 7, did she ever 6 tell you that Mr. -- well, let me smite that. 7 Did she ever complain to you that Mr. Epstein 8 had acted inappropriately with her at any time? 9 A. No. 10 Q. Did she, Jane Doe 7, ever complain that 11 Mr. Epstein had used any type of physical or verbal 12 force or violence directed to her? 13 MR. HOROWITZ: Form. Cumulative. 14 THE WITNESS: No. 15 BY MR. CRITTON: 16 Q. Did she, Jane Doe 7, ever tell you that she 17 had suffered any type of emotional or mental trauma as a 18 result of her involvement with Mr. Epstein? 19 MR. HOROWITZ: Cumulative. Asked and 20 answered. 21 THE WITNESS: No. 22 BY MR. EPSTEIN: 23 Q. Did she ever tell you that she ever suffered a 24 loss of income, either past income or the futurability 25 to earn income as a result of her relationship with lb ammo...4,1.6,s 29 (Pages 266 to 269) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82(Iddf-59ee-4e57-9cd0-83920560Dre0 EFTA01076015 Pacie 2;J Page 272 1 Mr. Epstein? 2 A. No. 3 Q. Did she, Jane Doe 7, ever tell you that she 4 was, as a resuh of her contact with Mr. Epstein, that 5 she had been required to see a psychiatrist or a 6 psychologist or some sort of mental health counselor? A. Not directly, no. 3 Q. And the only thing you know is what you heard? 9 A. Was told to me from 10 Q. All right. Did Jane Doe 7, Jane Doe 3. — 11 well, let me grace that. 12 Did Jane Doe 7 ever tell you that she was 13 embarrassed or humiliated as a result of her actions 14 with Mr. Epstein? 15 MR. HOROWITZ: Form. Cumulative. 16 THE WITNESS: No. 17 BY MR. CRITTON: 18 Q. You said at ono time or on a number of 19 occasions various individuals approached you so that 20 they could go to Mr. Epstein's home? 21 A. Uh-huh. 22 Q. Is that correct? 23 A. Yes. 24 Q. Did that include Jane Doe 7 and Jane Doe 4? 25 A. Yes. 1 Q. What was — let me strike that. 2 Did you know anything about'., other than 3 that — at the time that you spoke with her, other than 4 she was dating at the time? 5 MR. KUVIN: Form. 6 MR. HOROWITZ: Form. THE WITNESS: That she was dating-? No. 8 I mean, that's all I knew. 9 BY MR. CRITTON: 10 Q. Well, did you know anything about her 11 reputation around school? 12 A. Yes. 13 Q. What was her reputation? 14 MR. KUVIN: Object to the form. 15 THE WITNESS: She was promiscuous. 16 BY MR. CRITTON: 17 Q. And you had heard that from a number of 18 people? 19 MR. KUVIN: Object to the form. 20 THE WITNESS: ! heard that from two people 21 BY MR. CRITTON: 22 Q. To your knowledge, was she sexually active? 23 A. Yes. 24 Q. Did she tell you that or did NI tell you 25 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 271 Q. Did that include Jane Doe 3? A. I can't remember. Q. Now, Mr. Kuvin did ask a number of questions about is a person who you told — you told to tell Epstein if asked that she was 18? A. Yes. Q. Did she have any problem with that? A. No. MR. HOROWITZ: Object to the form. MB. KUVIN: Join. BY MR. CRITTON: Q. What was Is did you know who'. was? A. Yeah. Q. I mean, you knew. from — from high school? A. No. Q. You knew her throughlM? A. Yes. Q. All right. And when you told, about or told her about — let me strike that. Did you tell me she had heard about it — heard about Epstein from someone else and she approached you or did you say you approached I.? A. 1 had said something to her and she had asked me if I could take her. Page 273 1 A. Both. 2 Q. And serially active, both intercourse and oral 3 sex? 4 A. Yes. 5 Q. And did I. — well, let me strike that. 6 Do you know whether. also was a user of 7 illegal drugs or non-prescription drugs? 8 MR. KUVIN: Objection to form. 9 THE WITNESS'. Yes. 10 BY MR. CRITTON: 11 Q. And what kind of drugs were you aware that she 12 used? 13 A. Marijuana. 14 MR. HOROWITZ: Fenn. 15 BY MR. CRITTON: 16 Q. Anything else? 17 A. Not that I know of 18 Q. When'. — so you talked tol. about 19 Mr. Epstein. The matter dropped. And did she 20 re-contact you, like, right away or within a few days? 21 A. We had -- we had talked about it. I had said 22 something to her. She had asked me if I could take her. 23 And within a day or a couple days we had set it up. 24 Q. But she approached you? 25 A. Well, 1 had said something about it and then 30 (Pages 270 to 273) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-59ec.4e57.9cd8-8392056001c0 EFTA01076016 Page 274 1 she had asked me to take her. 2 Q. But, again, she could have said, I'm not 3 interested, don't — 4 A- But she didn't. 5 MR. KUVIN: Objection to form. Move to 6 strike. 7 BY MR. CRITTON: 8 Q. Did she ever say, I'm not — let me start 9 again. 10 You told her about it? 11 A. Uh-huh, yes. 12 Q. Did you then follow up with ha on multiple 13 additional conversations or was it'. then who contacted 14 you and said, I'd like to go? 15 A. It was more we had talked about it, she 16 contacted me or I contacted her and then we went. It 17 wasn't like a phone tag game, no. 3.8 Q. Did you have to push her in any way to go? 19 A. No. 20 Q. Did she -- was she encouraging you to take 21 her? 22 A. Yes. 23 Q. And did you tell her the same thing that you 24 had told the other girls, Le., tell him — lie about 25 your age, the more you do, i.e., in terms of how you're 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 276 is, you never had -- you never spoke with Mr. Epstein by phone, never tested back and forth, nor never -- nor did you ever email; is that correct? A. That's correct. Q. Did -- you knew Jane Doe 7 both before and after she had seen Mr. Epstein; is that correct? A. Yes Q. And as of the last -- and did you see -- after Jane Doe 7 stopped going to Mr. Epstein's home, did you see her on — well, I think you said you were roommates, if I understood correctly? A. That's true. Q. How long were you all roommates? A. Between -- about seven months. Q. Give me a time frame, if you could, A. Q. And did you stay — so at least you saw her pretty much everyday dining that time period? A. That's true, yes. So during the you saw Jane Doe 7 on almost a daily basis. On those during that daily basis, did she ever appear to be so depressed to you or depressed or Page 275 1 dressed or how you're undressed, you'll make more money? 2 A. That's correct. 3 Q. Did she express any concern or reticence about 4 going? 5 A. No. 6 Q. All right. Did she express any -- instead of 7 using reticence, probably not a great word — did she 8 express any hesitation or concern about going? 9 A. No. 10 MR. KUVIN: Objection. Cumulative. 11 BY MR. CRITTON: 12 Q. When she came — well, let me strike that. 13 When she came down after you went to Epstein's 14 home, did she ever express any type of concern or 15 complaints about anything that had occurred with 16 Mr. Epstein? 17 A. No. 18 Q. Did she express to you at any time that there 19 had been any inappropriate conduct -- 20 A. Na 21 Q. — or contact? 22 A. No. 23 MR KUVIN: Objection to form. 24 BY. MR. CRITTON: 25 Q. If I understood your — your earlier testimony 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 277 upset to any degree that she did not appear to be carrying out ha daily activities of living? MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. Did you ever see Jane Doe 7 hesitate to go to a party or go to a bar? Well, let me stile that. Did you ever go with Jane Doe 7 to bars, to social gatherings, to parties during that time frame? A. Yes. Q. And did she ever appear to be emotionally disturbed or have any type of depression or concern that prevented her from attending parties, going out to bars, engaging in social activities, at least from what you observed? MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. Did she ever express to you during that approximately six or seven months -- well, let me strike that. During that six or seven months, did she ever talk about Epstein? A. No, not that I can remember. Q. Did either one of you bring up Epstein? PROSE COURT REPORTING AGENCY, 31 (Pages 274 to 277) INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddelf-59e04057-9cd8-8392056001c0 EFTA01076017 Page 278 1 A. It was a joke from time to time. 1 mean, we 2 joked around about how nice it would be to find an 3 Epstein that lived in . We joked about it. But 4 it wasn't anything derog — well, I mean, you can 5 consider that derogatory. But there was nothing about 6 her psychiatric health or her ability to move on with 7 life. 8 Q. Oka rou say you joked about if you had an 9 Epstein in meaning what during that time frame? 10 A. Meaning, it would just be nice if we had a guy 11 for income, I guess. 12 Q. And this time you were -- let's see, in 13 you were 20 years old? 14 A. (Jh-huh. 15 Q. And or almost, you were just about 19, 16 about to nun 20. Is Jane Doe 7 the same age as you or 17 you're- 18 A. Jane Doe 7 is a year younger. 19 Q. So she would have been 18, closing in on 20 I9, — 21 A. Yes. 22 Q. -- depending on when her birthday was? 23 So if I understand your testimony, the 24 discussion that you and Jane Doe 7 had regarding 25 Epstein, at least, in — during that six or seven month 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 280 BY MR CR117ON: Q. During the same -- after and 1 understand that you returned because o — A. Yes. Q. And you returned back to the area? A. Yes. Q. And you had little contact with Jane Doe 7 after that point in time for some of the reasons you told us? A. That's correct. Q. And Jane Doe 4 u u did you stay in somewhat ntil the point that you returned contact with her during the time period that you and Jane Doe 7 were roommates? A. I wouldn't say friends. When I lived with Jane Doe 7. like I said, I respected her as a roommate, so I treated Jane Doe 4 differently. But we weren't friends. Q. All right. All you know is — but she did come out with you to go dancing with you at the A. Yes. MR. CRITFON: I'm sorry. Dancing. Jane Doe 4 Page 279 1 time period was, it would be nice to have an Epstein up 2 there, as distinct from, I'd say, either one of you 3 complaining or suggesting that you were depressed. 4 humiliated, concerned or had any type of emotional 5 problems? 6 MR. HOROWITZ: Form. Compound. 7 MR. KUVIN: Join 8 MR. CRITTON: Well, let me rephrase it 9 BY MR. CRiTFON: 10 Q. If I understood your testimony, is, you and 11 Jane Doe 7 joked about, it would be nice to have an 12 Epstein up there? 13 MR. HOROWITZ: Asked and answered. 14 MR KUVIN: Join. 15 THE WITNESS: Yes. 16 BY MR. CRITTON: 17 Q. And did you and Jane Doe 7 ever talk about or 18 either one of you ever express any type of that either 19 one of you had suffered any type of emotional injury or 20 traumatic event as a result of your involvement with 21 Mr. Epstein? 22 MR. HOROWITZ: Cumulative. Asked and answered 23 as to Jane Doe 7. 24 MR. KUVIN: Join. 25 THE WITNESS: No. Page 281 stripped. 2 BY MR. CRITTON: 3 Q. Anyhow with regard to when Jane Doe 4 would 4 cane up to , did she come up on more than one 5 occasion — 6 A. I can't remember. 7 Q. — during the time you were roommates with 8 Jane Doer 9 A. I can't remember. 10 Q. You just remember the one time? 11 A. That's correct. 12 Q. And during the time that she came up there, 13 did she stern to have any type of lingering depression or 14 psychological condition, at least that she either 15 expressed to you or that you observed? 1 6 MR. HOROWITZ: Form. Foundation. 17 THE WITNESS: No. 18 BY MR. CRITTON: 19 Q. Did you and Jane Doe 7 - did you and Jane Doe 20 4 ever e-mail back and forth, either on My Space or on a 21 social networking thing? 22 A. I believe My Space. 23 Q. And did she ever express to you -- and let me 24 strike that 25 In the times that she would communicate with MoleasaMeeS1 32 (Pages 278 to 281) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-Sgeo-4e57-9cd8-13392056001c0 EFTA01076018 Page 282 1 you on My Space, did she ever suggest that she was 2 Wing any type of emotional problems? 3 MR. HOROWITZ: Cumulative. Asked and 4 answered. 5 BY MR. CRITTON: 6 Q. On the My Space? 7 A. No. Q. Did she ever, in communicating, indicate that 9 she was having pretty good life, that things seemed to 10 be okay with ha? 11 A. Yes. 12 Q. And did she — "she," meaning, Jane Doe 4 13 did she appear to be enjoying college and the college 14 experience? 15 A. Yes. 16 MS. BLANTON: I need a quick restroom break, 17 if you're at a deceit stopping point. 18 MR. CRITTON: I'm at a decent stopping point 19 and ni try to imish in about 10 or 15 minutes. 20 VIDEOGRAPHER: Going off the record. The time 21 is 5:18 p.m. 22 (Brief recess.) 23 VIDEOGRAPFIER: Were beck on the video record. 24 The time is 5:22 p.m. 25 BY MR. CRITTON: Page 284 1 she used? . 2 A. Cocaine. 3 Q. To your knowledge, was Ms. Jane Doe 3. ever 4 pregnant? Did she ever have an abortion? 5 A. I have no idea. 6 Q. To your knowledge, did Ms. Jane Doe 3 have any 7 STDs? 8 A. I have no idea. 9 MR. HOROWITZ: Object to the form. 10 BY MR. CRITTON: 11 Q. To your knowledge, did Ms. Jane Doe 3 have any 12 criminal history? 13 A. I have no idea. 14 Q. Did she ever express to you that she, Ms. Jane 15 Doe 3, ever express to you that she had been molested by 16 an individual? 17 MR. HOROWITZ: Form. 18 THE WITNESS: No. 19 BY MR. CRITTON: 20 Q. By a person namer=? 21 A. By who? 22 Q. By a person named MI? 23 MR. HOROWITZ: Form. 24 THE WITNESS: No. 25 BY MR. CRITTON: Page 283 1 Q. I vault to ask you some specific questions 2 about a number of the girls. I want to start with Jane 3 Doe 3 if I could. 4 You described her earlier in response to 5 either Mr. Kuvin or Mr. Horowitz's questions that her 6 reputation was that she was promiscuous? 7 MR. HOROWITZ: Object to the form. 8 THE WITNESS: That's correct. 9 BY MR. CRITTON: 10 Q. And when you say prorniscuim4 what do you 11 mean,-? 12 A. Sleeping around. Having boys come over and 13 stay the night with her. 14 Q. And did you from time to time witness that? 15 A. I was there one night -- twice actually, two 16 different nights. 17 Q. And did she — and was this before she ever 18 went over to Mr. Epstein's home? 19 A. I believe so, yes. 20 Q. And with regard to Jane Doe 3, separate and 21 apart from being promiscuous, based upon what you heard 22 and saw, did she -- were you aware whether she used 23 illegal drugs? 24 A. Yes, she did. 25 Q. And what kind of drugs were you aware of that Page 285 1 Q. Did she ever indicate to you, again, that Jane 2 Doe 3 — let me strike that. 3 Did you understand anything about her family 4 life? 5 A. 6 Q. 7 A. 8 Q. 9 3? 10 A. That's all I know. 11 Q. The you were asked a question earlier about 12 generically whether — let me strike that. 13 The girls that you asked to go or came to you 14 10 ask to go to Mr. Epstein's and, in fact, of the 15 approximately 12 that went to Mr. Epstein, how would you 16 have described them? Would you describe them, like, 17 middle class? Upper class? Middle class? Lower middle 18 class? 19 MR. HOROWITZ: Foundation. Predicate. 20 MR.1CUVIN: Form. 21 THE WITNESS: Same as me, middle class. 22 BY MR. CRITTON: 23 Q. And all of the girls that went, the females 24 that went to Mr. Epstein's home, did you have -- that 25 is, with almost all of them, did you have some idea or I knew her sister. And her sister, was she in your grade or -- She went to school with my sister. Did you know anything else about her, Jane Doe 33 (Pages 282 to 285) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddt-59ee-4e57-9cd8-839205400fcg EFTA01076019 Page 286 Page 288 1 did you know where they lived? 2 A. Yes. 3 Q. And, so, you were familiar with — of the 12 4 females that went to Mr. Epstein's home, you were 5 familiar with where they lived, their neighborhood, 6 their house, you know, what kind of car they either 7 drove or were transported in? 8 A. Yes. 9 Q. And, so, when you say they were from the 10 middle class, that was based upon your observations? 11 A. Yes. 12 Q. With regard to Jane Doe 4, you knew before 13 she ever went to Mr. Epstein's home, were you familiar 14 with any of her boyfriends? 15 A. llh-huh, yes. 16 Q. And what was her main — well, let me strike 17 that. 18 You also described Jane Doe 4 as being 19 promiscuous? 20 A. Yes. 21 Q. And you knew that how? 22 A. We were friends. She was dating 23 MIE. She was cheating on him every second that we 24 were together. She had guys sneaking in and out of her 25 window. Whenever her and would break up she 1 or during the break up? You're kind of — 2 BY MR. CRITTON: 3 Q. During the entire time she dated him, 4 including break ups, did you see her having or engaging 5 in some type of sexual activity? 6 A. At least two. 7 Q. And as to Jane Doe 4, were you aware of 8 whether or not she used illegal drugs? 9 A. Yes. 10 Q. And what illegal drugs were you aware that she 11 took? 12 MR. HOROWITZ: Form. Foundation. 13 THE WITNESS: Xanax, marijuana and cocaine. 14 BY MR. CRITTON: 15 Q. And did you actually see her take those? 16 A. Yes. 17 Q. Now, =, were you -- did -- were 18 you ever -- well, let me strike that. 19 I assume you knew him? 20 A. Yes. 21. Q. Were you ever present when Mr. 22 bit or physically abused Ms. Jane Doe 4? 23 A. Yes. 24 Q. On more than one occasion did you see him — 25 k Yes. struck, 1 I Page 287 1 would date another guy for maybe three days and then get 1 2 back with . 2 3 Q. And was she hooking up with these guys? Did 3 4 she tell you that? 4 0 MR. HOROWITZ: Objection. Foundation. 5 6 THE WITNESS: I saw it a few times. 6 7 BY MR. CRITTON: 7 8 Q. And you say you saw it on a few occasions? 8 3 THE WITNESS: Yes. 9 10 BY MIt. CRITTON: 10 11 Q. So you — you physically — you have personal 11 12 knowledge during the time that she was dating 12 13 during the times they were broken up, on more than one 13 14 occasion you would see her having or engaging in sexual 14 15 activity with others, other males? 15 16 A. Not necessarily having sex. Engaging, yes. 16 17 Q. Well, in addition — let's see. One of the i 7 18 individuals was a guy that you were dating, correct? 18 19 A. Yes. 19 20 Q. And did you see her with others as well? 20 21 A. Yes. 21 22 Q. Approximately how many other individuals, 22 23 separate gart from =, during the time she was 23 24 dating . 24 25 MR. HOROWITZ: During the time she was dating 25 Page 289 Q. — physically abuse he A. (Nods head.) Q. What was her reaction to the physical abuse that her boyfriend was doing to her? A. Sometimes she would hit back. She would fight back. Other times she would spit on him. Sometimes slit would run from him. Q. You'd see her actually hit and spit — hit him back and spit on him? A. That's correct. Q. Did you ever see him spit on her? A. Yes. Q. Did she ever -- did you ever discuss with her, that is, with Jane Doe 4, that maybe this wasn't a healthy relationship? A. Several times. Q. What was her response? Was this prior to her seeing Mr. Epstein or ever meeting Mr. Epstein? A. That's correct. Q. And what was her response to your conversations with her about the phikal and verbal abusethat MI -- I'm sorry -‘ • that was causing her? A. We staged an intervention once with her family and they called the police. And she told the police PROSE COURT REPORTING 34 (Pages 286 to 289) AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7andddf-59eu-4057-9cd8-839205600fc0 EFTA01076020 Page 290 I. officer she didn't want to have a restraining order or 2 to press charges against him after she got beat by him. 3 We had several conversations about her being 4 in an unhealthy relationship and maybe going to a clinic 5 where abused women or women with relationship issues 6 should go to maybe get therapy as couples or to leave 7 him. 8 And she looked at me like I was nuts. I'm in 9 love with him. I don't want to leave him. He loves me. 10 Crazy talk. 11 Q. So despite your involvement in speaking with 12 her and her family and intervention with her, nobody 13 could talk her out of staying in her abusive 14 relationship? 15 MR. HOROWITZ: Form. 16 THE WITNESS: No. 17 BY MR. CRITTON: 18 Q. In terms of Ms. lane Doe 4, were you ever 19 aware whether she was pregnant? 20 A. Yes. 21 Q. On how many occasions were you aware that she 22 was pregnant? 23 A. Two or three. 24 Q. And did she ever have a child? 25 A. No. 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 292 BY MR. CFUTTON: Q. And what did the video depict? A. I never saw it myself, but there wereict7res of her on the Internet going around with lesbian pictures in their underwear, their thong, posing on top of each other, making out. Q. Did you ever see any of those pictures or that's just what you were told? A. That's what I was told. Q. And who told you that? A. My boyfriend at the time. Q. Who was? A. =. Q. And in terms of lane Doe 4, did you ever talk to her about it, say, hey, I hea.idou did a video with — what was her name? — A. Yes. Q. Did you ever ask her about it? A. My boyfriend did while I was present and she said that she didn't care, it didn't bother her, and that if somebody had a problem with it, they could F off. That was pretty much her attitude. Q. And you heard her say that? A. Yes. Q. And did she ever indicate that the pictures Page 291 1 Q. Did she have abortions? 2 A. Yes. 3 MR. HOROWITZ: Form. 4 BY MR. CRITTON: 5 Q. And did she tell you that? A. Yes. 7 Q. And did she tell other people, as far as you 3 know? 9 A. Yes. 10 Q. Who else did she tell? 11 A. Jane Doe 7. She told 12 obviously. And that's &Ilk: M. ,. as 13 well. 14 Q. So at least among that group it was pretty 15 common knowledge that she had had three abortions? 16 MR. HOROWITZ: Form 17 THE WITNESS: Two or three. 18 BY MR. CRSITON: 19 Q. Two or three abortions. Do you know if she 20 ever told her family? 21 A. No, I do not. 22 Q. Were you ever aware of a video that she made 23 with another female? 24 lit. HOROWITZ: Form. 25 THE WITNESS: Yes, in big' school. Page 293 1 that were displayed of her having — in her thong, in 2 some sort of, at least whatms rceived to be a 3 lesbian relationship with that that caused her 4 any embarrassment or humiliation? 5 MR. HOROWITZ: Form. 6 THE WITNESS: No. 7 BY MR. CRITfON: 8 Q. Well, did you hear — so I'm clear, is, I 9 thought -- thought you said that asked her about 10 the pictures? 11 A. Yes, he did. 12 Q. And did he describe the pictures as to what, 13 say, hey, I hear did he say something like, hey, 1 14 hear you and are on the Internet and shows 15 pictures of you guys on top of each other? 16 A. No. He had just briefly mentioned that there 17 were pictures on the Internet floating around and he 18 caught one of them. 19 Q. And that's when she said, if you have a 20 problem with it, Fa, 21 A. Pretty much was her attitude. 22 Q. All right. Were you ever aware that she did 23 her own photography, made a video of she and 24 engaging in various sexual acts? 25 MR. HOROWITZ: Form. 35 (Pages 290 to 293) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddill-69eo-4e57-9cd8-8392056001c0 EFTA01076021 Page 294 1 THE WITNESS: I can't disclose that 2 information. 3 BY MR. CRIT'fON: 4 Q. Let me ask it this way: Did she ever tell 5 you? 6 A. She never told me. 7 Q. Did she or ever show you a 8 video of the two of them having sex? 9 A. No. 10 Q. Did =, from your observations let me 11 strike that. 12 Wile., were present, did you ever observe 13 using illegal drugs? 14 A. Yes. 15 Q. Was he — did you ever view him or observe him 16 taking or drinking excessively? 17 A. Yes. 18 Q. Did — was Ell from at least your 19 perception, a drug addict? 20 MR. HOROWITZ: Form. 21 THE WITNESS: Yes. 22 BY MR. CRAYON: 23 Q. Well let the ask ou this: How would you 24 describe and his use of illegal drop? 25 A. He had an addiction. Page 296 1 Q. And at the times — on some of the occasions 2 that you saw present and taking illegal 3 drugs, was Jane Doe 4 partaking in the same illegal 4 drugs? 5 MR. HOROWITZ: Form. 6 THE WITNESS: Yes. 7 BY MR. CRITTON: 8 Q. Was known for being a seller 9 of drugs? 10 MR. HOROWITZ: Form. 11 THE WITNESS: I don't know. 12 BY MR. CIUTTON: 13 Q. All you blow, he was a user? 14 A. Yes. 15 Q. Was Jane Doe 4 dating 16 she was seeing Jeffrey Epstein? 17 A. Yes. 18 Q. Did she ever tell IM? 19 A. She wouldn't. 20 MR. HOROWITZ: Form. 21 BY MR. CRITTON: 22 Q. To your knowledge? 23 A. No. 24 Q. Did you ever see 25 kill or to injure Jane Doe 4? during the time threaten to Page 295 1 Q. And what kind of drugs, illegal drugs did he 2 take? 3 A. Cocaine, pills, alcohol. 4 Q. Did you ever see him using those, that is, 5 cocaine, pills — cocaine and pills in the presence of 6 he and Jane Doe 4? 7 A. Yes. 8 Q. So if I had to ask you to assume that Jane Doe 9 4 has testified in this case that she was unaware that 10 abused illegal drugs, would you be surprised to 11 hear that testimony? 12 MR. HOROWITZ: Form. 13 THE WITNESS: Not really. 14 BY MR. CRITTON: 15 Q. Because you think she doesn't tell the truth? 16 MR. HOROWITZ: Form. 17 THE WITNESS: She doesn't tell the truth. 18 BY MR. CRITTON: 19 Q. And, so, let me just ask it this way: Were 20 ifisically present when when you saw 21 taking illegal drugs and Jane Doe 4 was there 22 and saw it as well? 23 A. Yes. 24 MR. HOROWITZ: Form. 25 BY MR. CRITTON: Page 297 1 A. On a regular basis. 2 Q. Literally? 3 A. Literally. 4 Q. What was her response to that? 5 A. She -- upset, start a physical fight. 6 Q. At what point were you aware when she stopped 7 dating =? 8 A. I wasn't aware that they had stopped dating 9 until I moved back home and she was with another guy. 10 Q. Who was the guy that she was with? 11 A. M. 12 Q. And who is M? 13 A. Her boyfriend. 14 Q. Is that — when is the last time you saw Jane 15 Doe 4? 16 A. I don't remember. I want to say, 17 Q. Was that -- was — and who was she there with 18 at the time? 19 A. It was her and two girls. 20 Q. And did you talk about Epstein at all on that 21 occasion? 22 A. No. 23 Q. Did she try to bring it up with you? 24 A. No. 25 Q. Did you speak to her? 36 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 (Pages 294 to 297) 7a82dddf-59ea-4e57-9cd8-839205600fc0 EFTA01076022 Page 298 Page 300 7 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 A. No. Q. You saw her, but neither one of you spoke? A. Yes. Q. With 'regard to MI, her boyfriend, do you know what his last name is? A. No, I do not. Did you ever know a boy that she dated named A. Yes. Q. And how did you know M? A. I didn't know him personally. She talks about him. They had dated for a short period of time. I'm guessing this is either in between M. I can't be sure. His name came up a lot, but that's it. Q. Did she ever indicate to you whether while she was dating • she was cheating on him? A. No, she never indicated that. Q. With regard to M . do you knoW anything about him? A. Hes a drug dealer. Q. And how do you know is a drug dealer? A. I was around them both. Q. Were you around when he was using illegal drugs? A. Yes. 1 A. Yes. 2 Q. Did she tell you that? 3 A. Yes. 4 Q. What was her -- was she concerned about that? 5 A. She said he was going to eventually stop. 6 MR. KUVIN: I'm sorry•. Is a Plaintiff 7 in one of these cases? 8 I was just curious. 9 BY MR. CRITTON: 10 Q. When is the last — when is the last time you 11 had any conversation with Jane Doe 4? 12 A. When I sent her a text message — text message 13 letting her know that I knew what was going on about the 14 whole lawsuit. 15 Q. Do you know anything about Jane Doe 4's home 16 life? 17 A. Yes. 18 MR-HOROWITZ: Form. Vague. 19 MR. CRITTON: I'm sorry? 20 MR. HOROWITZ: Vague. Her home life. What 21 does that mean? 22 BY MR. CRITTON: 23 Q. You know where she lived? 24 A. Yes. 25 Q. Okay. Do you know anything about her parents? Page 299 1 Q. And what kind of illegal drugs was he using? 2 A. Cocaine. 3 Q. And at the time — and this was well after 4 Epstein; that is, you had — either one of you had seen Mr. Epstein? A. I'm sorry? Q. Was the time that she when she — "she," meaning, Jane Doe 4 -- started dating MI, was that after the time that she had seen Mr. Epstein? A. Yes. Q. And when she started dating M, were you ever present when you saw her taking illegal drugs with MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. You just saw using cocaine? A. Yes. Q. And in terms of being a drug dealer, is that — did Jane Doe 4 — did you ever ask Jane Doe 4 one way about it? A. Me and her had a conversation, me coming from similar situation, I tried to give her advice. And she didn't want to listen. Q. Was she aware that was a drug dealer? Page 301 1 A. Yes. 2 Q. What do you know about her father? 3 MR. HOROWITZ: Vague. 4 THE WITNESS: Crazy. 5 BY MR. CRITTON: 6 Q. And what do you mean, "crazy?" 7 A. He — when be talks, he always sniffed. And 8 it used to be a joke with me and Jane Doe 4's friends 9 until we understood that he was a drug user when he was 10 younger. 11 Q. Do you know anything about -- as far as you 12 know though, during the time that you know him, was he a 13 drug user? 14 A. I have no idea. 15 MR. HOROWITZ: Form. 16 BY MI. CRITTON: 17 Q. How about her mother? 18 A. Nice lady. 19 Q. Jane Doe 4's. What do you know about her? 20 A. Nice lady. 21 Q. Si Ina nice home? 22 A. 23 Q. Pit o? 24 A. 25 Q. They live in a nice home? I I 1 37 (Pages 298 to 301) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7/032dddt-69ee-4e57-9cd8-8392056001c0 EFTA01076023 Page 302 Page 304 1 A. Yes. 2 Q. Did Jane Doe 4 have access to nice clothes and 3 to, you know, living in a -- being able to drive around 4 in a vehicle? 5 A. Yes. 6 Q. At least have access to a vehicle? 7 A. Yes. 8 Q. Would you have considered either Jane Doe 3, 9 Jane Doe 7, or Jane Doe 4 to be underprivileged or dirt 10 poor in any way? 11 MR. HOROWITZ: Form. 12 THE WITNESS: No, not at all. 13 BY MIL CRITTON: 14 Q. Did Jane Doe 4 ever tell you how many times 15 she had been to Mr. Epstein's home? 16 A. No. 17 Q. Let me tum to Jane Doe 7. 18 You knew Jane Doe 7 from high school? 19 A. Yes. 20 Q. And you met her through whom? That is, did 21 you know Jane Doe 4 first or Jane Doe 77 22 A. I knew — I knew Jane Doe 7 first, but me and 23 Jane Doe 4 shared a class together. 24 Q. Jane Doe 7. Had you ever been to her home? 25 A. Yes. 1 A. Both. 2 Q. And in tams of Jane Doe 7 having a lot of 3 boyfriends, did she have anybody that was steady or did 4 she go with a lot of men? 5 A. She went with a lot of men. 6 Q. From your observations and at least watching 7 her -- well, let me strike that. 8 Prior to — well, let me strike that. 9 At any time did you ever see Jane Doe 7 using 10 any type of illegal drugs? 11 MR. HOROWITZ: Fonn. 12 THE WITNESS: Yes. 13 BY MR. CRITTON: 10 Q. What type of drugs did you see her use? 15 A. Marijuana and Xanax. 16 Q. And did you see her use those before -- let me 17 strike that. 18 When you all were in high school together, did 19 you see her using marijuana and Xanax? 20 A. Yes. 21 Q. And post-high school and when were living 22 up north — not north — living up in did she 23 continue to use these illegal drugs, at least from what 24 you observed? 25 A. What I observed? No. Page 303 1 Q. Nice home? 2 A. Yes. 3 Q. Ha mother and father, what did you know about 4 her home life, in terms of her parents, from what you 5 observed? 6 A. They spoiled her. 7 Q. In what way? 8 A. Paid for everything. She never had to work a 9 day in her life. They bought her cars all the time. 10 Paid her phone bill. Let her pretty much do anything 11 she wanted. 12 Q. From your observations, at least with Jane Doc 13 7, did she seem to be spoiled? 14 A. Yes. 15 Q. And what was Jane Doe 7 -- from your 16 observations, did Jane Doe 7 have a lot of boyfriends -- 17 A. Yes. 18 Q. -- when you knew her, again, before 19 Mr. Epstein? 20 A. Yes. 21 Q. And, again, I think you described her as being 22 as well promiscuous? 23 A. Yes. 24 Q. And is that something you observed or was that 25 her reputation at school? Page 305 1 Q. Did she continue — let me strike that. 2 After you were her roommate, did she continue 3 to be sexually active? 4 A. I don't know. 5 Q. Did she continue to date on a regular basis? 6 A. I don't know. 7 Q. Did she go out -- did she go out often? 8 A. I don't know. 9 Q. Not right now. When you were roommates? 10 A. When we were roommates, yes. 11 Q. And did you ever observe — did you ever go 12 out with her or out with a group of friends -- 13 A. Yes. 14 Q. — to bars? Did she appear to be, at least 15 during the time that you were living in she 16 appeared to date on a regular basis? 17 A. Yes. 18 Q. Do you know whether Jane Doe 7 -- and I don't 19 think I asked you about Jane Doe 4. Do you know whether 20 she ever had any type of sexually transmitted dise2se? 21 MR. HOROWITZ: Form. Come on, Bob. That's 22 just not right 23 THE WITNESS: Jane Doe 7.1 heard, but I don't 24 know. 25 BY MR. CRITTON: AL. 38 (Pages PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 302 to 305 7a82dddr-69se-0e57.9cd8.839205600fc0 EFTA01076024 Page 306 1 Q. Did she ever discuss it with you? 2 A. No. 3 MR. HOROWITZ: Bob. 4 BY MR. CRITTON: 5 Q. How about Jane Doe 7, do you know whether she 6 ever had any type of — 7 A We just talked about Jane Doe 7. MR. HOROWITZ: Form. 9 BY MR. CRITTON: 10 Q. I'm sorry. I meant Jane Doe 4. 11 A. Yes. 12 MR. HOROWITZ: Form. 13 BY MR. CRITTON: 14 Q. Let me go back to Jane Doe 4. 15 Did Jane Doe 4 ever tell you that she had any 16 type of STD? 17 A. Yes. 18 Q. What did she tell you? 19 MR. HOROWITZ: Form. 20 THE WITNESS: She told me that gave 21. her HPV, which led to warts. 22 BY MR. CRITTON: 23 Q. And did she tell you that she was embarrassed 24 or humiliated about that? 25 MR. HOROWITZ: Form. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 308 MR. HOROWITZ Form. Cumulative. BY MR. CRITTON: Q. Is'. the only person you're aware of that Jane Doe 7 brought to Mr. Epstein's, that is, by name? A. By name, yes. Q. Did she indicate to you that she had taken other people there? A. She didn't and I don't want to speculate. Q. And I think you said that Jane Doe 4 said that she had brought at least one person there, correct? A. Yes. Q. Did either Jane Doe 7 or Jane Doe 4 tell you what they had — well, let me strike that. Did Jane Doe 7 ever tell you what she had told before taking her to Mr. Epstein's? A. No. ai Did Jane Doe 4 ever tell you what she had told before she took her to Epstein's? MS. BLANTON: You okay? You need a break? THE WITNESS: No. I'm good. MS. BLANTON: We're getting long. THE WITNESS: It's okay. MS. BLANTON: Tell me. THE WITNESS: My butt is numb. MS. BLANTON: You want to stand up, walk Page 307 1 THE WITNESS: She told me — well, she asked 2 me politely not to mention anything, and that she 3 had gone to the gyro and had it taken care of. But 4 she didn't realize that had given it to 5 het 6 BY MR. CRITTON: Q. And I think you said — I asked you about Jane 8 Doe 7. 9 To your knowledge, did Jane Doe 7 ever discuss 10 with you whether she had an STD? 11 MR. HOROWITZ: Form. Asked and answered. 12 THE WITNESS: Jane Doe 7 never discussed that 13 with me. 14 BY MR. CRITTON: 15 Q. I think you said Jane Doe 7 brought someone 16 named, to Mr. Epstein's home? 17 A. Yes. 18 Q. Did -- and how did you know that? Did Jane 19 Doe 7 tell you? 20 A. Uh-huh, yes. 21 Q. Yes? Did Jane Doe 7 ever say, you know, my 22 experience was so — with Mr. Epstein was so 23 inappropriate, I don't want — 1 shouldn't expose any 24 other person to Mr. Epstein? 25 A. No. Page 309 1 around? You okay? 2 THE WITNESS: I'm good. 3 BY MR. CRITTON: 4 . Did u ever discuss Mr. Epstein with Jane Doe 5 Tat 6 A. Yes. 7 Q. And did she approach you? 8 A. Yes. 9 Q. Or did you approach her? 10 A. She approached me and the group I was standing 11. with. 12 Q. And who was she with? 13 A. A random guy. 14 Q And — 15 MR. CRITTON: I'm sorry? 16 MR. HOROWITZ: Go ahead. 17 BY MR. CRITTON: 18 Q. And when she approached you with this random 19 person, were you aware that she was a Plaintiff in these 20 lawsuits? 21 A. Yes. 22 Q. And did she say anything to you about the 23 lawsuit or her being a Plaintiff and suing Mr. Epstein? 24 MR. HOROWITZ: Asked and answered. 25 THE WITNESS: We had discussed it, yes. 39 (Pages 306 to 309) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf•69ee.4e57.9cd8-839205600fc0 EFTA01076025 Page 310 1 BY MR. CRITTON: 2 Q. AM did she ever tell you why she was bringing 3 a lawsuit against Mr. Epstein? 4 A. She told me her parents were pushing her to. 5 Q. Did she indicate that she really didn't want 6 to bring the lawsuit but that her parents vivre pushing 7 her? 8 MR. HOROWITZ: Form. 9 THE WITNESS: She said it wasn't her fault and 10 that her parents had really been pushing the issue. 11 BY MR. CRITTON: 12 Q. Did you ever know a person named M.? 13 A. Yes. 14 Q. Do you know whether she went to Epstein's? 15 A. She did. 16 Q. And do you know who took her? 17 A. !can't be quite sure. I don't remember. 18 MR. CRITTON: I think I'm almost done. Give 19 me about one minute. Just look at my notes. 20 BY MR. CRITTON: 21 Q. M, with regard to — I'm going to ask the 22 same question with each of the three — but with regard 23 to Jane Doe 3 — Jane Doe 3, did she ever tell you that 24 she was sexually assaulted or battered; that is, 25 physically touched by Mr. Epstein? Page 312 1 VIDEOORAPHER: We're back on the video record. 2 The time is approximately 5:58 p.m. This is the 3 beginning of tape number five. 4 REDIRECT EXAMINATION 5 BY MR. KUVIN: 6 Q. Are you aware that Jeffrey entered into a 7 non-prosecution agreement with the Federal Government 8 with respect to the claims of all the girls that came to 9 his house? Did anyone ever talk to you about that, 10 other than your lawyers? 11 MS. BLANTON: Other than your lawyers. 12 THE WITNESS: No. 13 BY MR. KUVIN: 14 Q. Are you aware as a part of that agreement he 15 essentially hung you out to dry, didn't put you in the 16 agreement? 17 MS. BLANTON: Anything you know about that 18 agreement that you did not learn from your 19 attorneys, you can discuss; otherwise, you are not 20 to discuss it. 21 MR. CRITTON: Form. 22 THE WITNESS: Can you repeat the question? 23 BY MR. KUVIN: 24 Q. Yeah. Are you aware, other than conversations 25 with your attorneys, that Jeffrey Epstein did not get Page 311 3. A. No. 2 Q. Did she ever tell you that she had suffered 3 some sort of intentional infliction of some huge or 4 severe emotional distress? 5 A. No. 6 Q. Did Jane Doe 4 ever tell you that she had been 7 sexually assaulted or physically battered by 8 Mr. Epstein? 9 MR. HOROWITZ: Cumulative. 10 THE WITNESS: No. 11 BY MR. CRITTON: 12 Q. Did Jane Doe 7 ever tell that you that they 13 had been — that she had been sexually assaulted or 14 battered or physically — 15 ME. HOROWITZ: Cumulative. 16 BY MR. CRITTON: 17 Q. — touched by Mr. Epstein? 18 A. No. That's ridiculous. 19 MR. CRITTON: That's all I have. Thank you, 20 ma'am. 21 THE WITNESS: Can get a two-minute 22 break? 23 VIDEOGRAPHER: Going off the mord. This is 24 the end of tape number four. The time is 5:52. 25 (Brief recess.) 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 313 immunity for you with the Federal Government when he was negotiating on behalf of Lesley Graaf (phonetics), (phonetics)? MR. CRITTON: Form. THE WITNESS: No. BY MR. KUVIN: Q. Obviously when you were going to Jeffrey's house and bringing girls to him it was before December 7 of 2080 — I'm sorry before October 29 of 2007, wasn't it? A. I don't remember. Q. It was before 2007, wasn't it? A. Oh, before 2007, yes. Q. Okay. Other than what your attorneys may have told ou, arc ou aware that he negotiated for immunity for Lesley Graaf and trot. CRITTON: Form. THE WITNESS: No. BY MR. KUVIN: Q. Other than your attorneys, did anyone discuss whether or not he should negotiate for immunity for you? A. No. Q. You seem to have no problems talking about other girls being promiscuous, boys being promiscuous. 40 (Pages 310 to 313) PROSE *COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddf-69eo-4e57-9cd8.839205600Ic0 EFTA01076026 1 2 3 4 S 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 314 blow jobs, sex, abortions, illegal drug use, Xanax, marijuana, alcohol, vaginal warts, people who are spoiled, drug dealers, sex videos and lesbianism of people that may be Plaintiffs in other lawsuits, as well as you seem to have no problem talking about people that may not be Plaintiffs in civil lawsuits. As you sit here today, when did you first start having sex? MR. CRITION: Form. MS. BLANTON: Objection. This was asked previously. The objection is the same and her instructions not to answer that question are the same. BY MR. KUVIN: Q. So you had no problem talking about other peoples promiscuity, drug use, vaginal warts and other sexual conduct, but you're not going to sit here and tell us anything about your sexual activity; is that true? MS. BLANTON: You do not need to answer that. You do not need to answer that. THE WITNESS: Nope. MS. BLANTON: Pm instructing you not to answer that very argumentative question, if there is even is question in it. 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 316 A. No. MR. CRITTON: Form. BY MR. KUVIN: Q. When did you stop? MS. BLANTON: Objection. THE WITNESS: I'm asserting my Fifth Amendment Right BY MR. KUVIN: Q. Okay. So you're not using them today? A. Asserting my Fifth Amendment Right. MS. BLANTON: Objection. I'm instructing her not to respond to any more of your questions. MR. KUVIN: Oh, we're done? MS. BLANTON: No. With what you are doing right now we are done. MR. KUVIN: Okay. BY MR. KUVIN: Q. You mentioned before abortions from other girls. Have you had an abortion? MS. BLANTON: Objection. THE WITNESS: I'm asserting my Fifth Amendment Right. MS. BLANTON: You do not -- Its not even a Fifth Amendment Right. It's a right to privacy. You are not a Plaintiff or a Defendant in this Page 315 1 BY MR. KUVIN: 2 Q. And you've got no problem talking about other 3 people's drug habits, but you're still going to stand by 4 a privilege objection or privacy objection as to your 5 drug use? 6 MS. BLANTON: With regard to drug use, I would 7 instruct my client to assert her Fifth. 8 BY MR. KUVIN: 9 Q. Okay. So you've used marijuana before, have 10 you not? 11 A. I'm asserting my Fifth Amendment Right 12 Q. You've used Xanax before, have you not? 13 A. I'm asserting my Fifth Amendment Right. 14 Q. You've used cocaine before? 15 A. I'm asserting my Fifth Amendment Right. 16 Q. You've used LSD before? 17 A. Pm asserting my Fifth Amendment Right 18 Q. You've used — you used cocaine on a regular 19 basis in the past, have you not? 20 A. I'm asserting my Fifth Amendment Right 21 Q. You've used Xanax on a regular basis in the 22 past, have you not? 23 A. I am asserting my Fifth Amendment Right. 24 Q. You continue to still use Xanax, cocaine, 25 marijuana, and other illegal drugs, don't you? Page 317 1 suit. 2 We've had these discussions earlier. It's the 3 same objections. 4 You do not need to answer that question 5 without a Court Order. 6 BY MR. KUVIN: 7 Q. You talked about boys that have gotten blow 8 jobs that aren't Plaintiffs in lawsuits. 9 Have you given blow jobs before when you were 10 14? 11 MS. BLANTON: Objection. You do not need to 12 answer that question. 13 MR. CRITTON: Form. 14 BY MR. KUVIN: 15 Q. You talked about other people who had made sex 16 videos. Did you ever make a sex video? 17 MS. BLANTON: You do not need to answer that 18 question. 19 Same objection. And it's going to be the same 20 objection. 21 BY Mr. KUVIN: 22 Q. Okay. You talked about whether'. -- I'm 23 sorry — whether the youngest girl that you brought 24 to Jeffrey, was -- seemed emotionally traumatized or 25 upset over the incident. I PROSE COURT REPORTING AGENCY, Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 41 (Pages 314 to 317) INC. 7a82dddf-69ee-4057-9cd0-839205600fc0 EFTA01076027 Page 318 1 When is the last thne you saw 2 A. On the back of some kid's crotch rocket at 3 Target when I was with my cousin a couple years ago, 4 maybe a year ago. 5 Q. Crotch rocket, you mean some kind of a — 6 A. Bike. 7 Q. fast motorcycle? 8 A. Yes. 9 Q. Did you talk to her? 10 A. No. 11 Q. Did you have when is the last time you ever 12 had any communication with her whatsoever? 13 A. When she tried getting me to bring her back to 14 Epstein. 15 Q. Back when she was I4? 16 A. Yes. 17 Q. So whether or not she regrets and feels bad 18 and has emotional trauma and is upset, much like you 19 testified that you are, you have no idea today? 20 MR. CRITTON: Form. 21 THE WITNESS: No idea about what? 22 BY MR. KUVIN: 23 Q. Whether she regrets what happened back then 24 when she was younger. 25 A. No, I don't care. Page 320 1 Q. And because of the small town, what? 2 A. I lmow a lot of people. 3 Q. And all — many of them seem to be drug users 4 and drug sellers? 5 A. Yes. 6 Q. As you sit idle and sort of watch them while 7 they use and sell drugs or do you participate -- 8 MS. BLANTON: Do not answer that question. 9 BY MR. HOROWITZ: 10 Q. — and partake in the drug use and sales? 11 MR. CRITTON: Form. 12 MS. BLANTON: That question has been asked. 13 I've stated my full objection. Fm instructing her 14 to assert her Fifth Amendment Right. And if you 15 would like for her to do it again, she will. 16 BY MR. HOROWITZ: 17 Q. Isn't it true that the people who you 18 identified as drug users and drug sellers, you have 19 sold, purchased or consumed drugs with? 20 MR. CRITTON: Form. 21 MS. BLANTON: Do not answer that question. 22 And do not ask her another question that has 23 already been asked and her Amendments have been 24 asserted to — her Fifth Amendments Rights have 25 been asserted. If you have a different question, Page 319 1 Q. You don't really care about any of these girls 2 and what they feel, do you? 3 MS. BLANTON: Objection. 4 THE WITNESS: No. 5 BY MR. KUVIN: 6 Q. You could care a less whether they're 7 emotionally traumatized or not? A. Yes. I could care less. 9 MR. KIJVIN: Okay. Perfect. Thank you. 10 That's all I got. 11 MR. CRITTON: Microphone. 12 RECROSS EXAMINATION 13 BY MR. HOROWffZ: 14 Q. Within your social circles when you were in 15 high school, you've identified several people who were 16 users and/or sellers of drugs, correct? 17 A. Yes. 18 Q. In your examination by Mr. Epstein's attorney, 19 do you remember telling us several people who you felt 20 were drug dealers or drug users? Yes? 21 A. Yes. 22 Q. How is it that you seem to know so many drug 23 users and sellers? How is it that you come into social 24 contact with all these people? 25 A. s a small town. 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 321 please move on. BY MR.. HOROWITZ: Q. Isn't it true that like some of the other girls you mentioned, you also slept around with boyfriends while you were in high school? MS. BLANTON: Do not answer that question. It has been asked. I've asserted my objection. Do you have another question — MR. HOROWITZ: I have many more questions. MS. BLANTON: — or else this deposition is over. MR. HOROWITZ: I have many more questions. MS. BLANTON: Do you have one that has not been asked? MR. HOROWITZ: I have many more questions. BY MR. HOROWITZ: Q. Isn't it true that you have had sexual intercourse with Jane Doe 4? You've had sexual contact with her? MS. BLANTON: Objection. THE WITNESS: Oh, what? MS. BLANTON: Do not answer that question. BY MR. HOROWITZ: Q. Isn't it true that you slept with Jane Doe 4's boyfriend? 42 (Pages 318 to 321) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 7a82dddf-59oo-4e57.9cdB-839205800fce EFTA01076028 Page 322 1 MS. BLANTON: Do not answer the question. 2 THE WITNESS: I'm done. 3 MS. BLANTON: Do you have a question that has not -- you don't have to say anything. Do you have another question that has not been 5 asked? BY MR. HOROWITZ: Q. You described Mr. Epstein to his lawyer as 9 being a nice person; is that right? You were asked, is 10 he nice? And you said, yes, he's nice? 11 A. Yes. 12 Q. In your mind, was it nice of Mr. Epstein to 13 masturbate in front of you when you were a child? 14 A. I don't know. I wasn't a child. 15 MR. CRITTON: Form. 16 BY MR. HOROWITZ: 17 Q. When you were a 16 year old girl and 18 Mr. Epstein was masturbating in front of you, exposing 19 his genitals, was that a nice thing of him to do? 20 MR. CRITT0N: Form. 21 THE WITNESS: I don't know. 22 BY MR. HOROWITZ: 23 Q. You have no opinion? 24 A. i have no opinion. 25 Q. When Mr. Epstein had his hand on his penis, on 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 324 A. I don't know. Q. You have no knowledge of her going into the champagne room and giving a lap dance to a grown man and taking off her clothes, correct? A. i don't know. Q. But that, if she were to do thaL that would be something tilt promiscuous? A. I don't know. MS. BLANTON: Object to the form. BY MR. HOROWITZ: Q. With regard to Jane Doe 4, other than a three-hour try out where she didn't continue to work at a strip club, you're not aware of her ever working at a strip club, correct? A. I don't know. Q. And with regard to Jane Doe 7, you have no knowledge of her working at a strip club, correct? A. I don't know. Q. Those would be the kinds of things that promiscuous girls would do, correct? A. I don't know. MR. CRITTON: Pam. MS. BLANTON: Object to the form. BY MR. HOROWITZ: Q. You described Jane Doe 4, in your opinion, as Page 323 1 his shaft and he's stroking it and he's coming — having 2 orgasm, was that a nice thing of him to do to you? 3 A. I don't know. • 4 MR. CRITTON: Let me object to the form. It's 5 intimidating, It's dying to harass her. 6 MS. BLANTON: Wine as well. 7 MR, CRITTON: I think it serves no purpose. 8 BY MR. HOROWITZ: 9 Q. And when you look back on it, is that a nice 10 memory that you have? 11 MR. CRITTON: Form. 12 THE WITNESS: I don't know. 13 MS. BLANTON: Let the record reflect that it's 14 after 6:00. You've been here for over seven hours 15 and these questions not only serve to intimidate, 16 harass and embarrass her, theyre very ill willed 17 and worded at this point. 18 BY MR. HOROWITZ: 19 Q. You described — you described Jane Doe 3 as 20 promiscuous? 21 A. Yes, 22 Q. Now, she wasn't the kind of girl who would 23 give lap dances at a strip club, was she? 24 A. I don't know. 25 Q. You have no knowledge that she did that? Page 325 1 being not an honest person, correct? 2 A. That's true. 3 Q. And if we were to ask Jane Doe 4 today whether 4 you were an honest person, would you agree that she 5 would likely say that you were dishonest? 6 MS. BLANTON: Object to the form. You're 7 asking her to -- 8 MR. CRITTON: Form. 9 THE WITNESS: i don't know. 10 MS. BLANTON: — speculate. 11 BY MR. HOROWITZ: 12 Q. You wouldn't be surprised if she said that you 13 were a liar? 14 A. i wouldn't be surprised if she told me she was 15 a raging alcoholic lesbian who loved monkeys. it would 16 not shock me. 17 Q. And although you described Jane Doe 4 as being 18 promiscuous for a period of years, you actually remained 19 friends with her; is that right? 20 A. Acquaintances. 21 Q. More than acquaintances. You actually staged 22 an intervention for her benefit is that correct? 23 MS. BLANTON: Is there a question? 24 THE WITNESS: I pitied her, yes. 25 BY MR. HOROWITZ: . 43 (Pages 322 to 325 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddr-59oo-4e57.9cd8.8392056001c0 EFTA01076029 Page 326 1 Q. Pardon me? 2 A. Yes. I pitied her. 3 Q. You cared for her enough you wanted to -- 4 A. I care for any woman that gets battered by 5 their boyfriend or husband, yes. 6 Q. And you wanted her to have a better life and, 7 so, that's what you thought was the appropriate thing to 8 do? 9 A. I thought that was the appropriate thing. 10 Q. So even though she had a tumultuous 11 relationship and in your mind was promiscuous and a drug 12 user, you still you still were within her social 13 circles, right? 14 A. I still wanted to help her. 15 Q. You still went to parties with her where you 16 claim that she used drugs? 17 A. Not went to parties with her. 18 Q. You went to parties — you went to parties 19 where you saw her and you were within close enough 20 proximity that you could see her purportedly using 21 drugs, right? 22 A. It's called, keeping order. 23 Q. Keeping whose order? 24 A. Keeping order. 25 Q. What does that mean? 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 328 Q. Do you have a specific recollection of her using drugs in the 11th grade? A. Yes. Q. And in the 12th grade? A. Yes. Q. And would you agree that her — any ding use she had increased over time? A. I don't know that. MR. CRITTON: Form. BY MR. HOROWITZ: Q. Did the types of drugs that she used increase over time, meaning, more substantial? A. No. It's the same drugs. Q. And you described, I think, one or two incidences of her breaking up and being with other — other guys when she was in break ups, right? A. Uh-huh. Q. What grade did that take place in? A. Well, she was with her junior and 12th grade years, so it happened then. Q. Okay. And you described — didn't you tell us that you felt that Jane Doe 3 used drugs? A. Jane Doe 3 did use drugs. Q. In what grades do you think she used drugs in? I lth? 12th? Tenth? Ninth? Page 327 1 A. I'm out in public. I'm going to be cordial 2 whether I like you or not. That's just me. 3 Q. But you stayed close enough to her that you 4 could supposedly watch her use drugs? 5 MS. BLANTON: Asked. Answered. 6 BY MR. HOROWITZ: 7 Q. Is that right? 8 A. Sure, yes. 9 Q. And not only that, you were sufficiently 10 familiar with the relationship she had with her 11 boyfriend, such that, you could see the type of 12 tumultuous relationship that you've described to us? 13 A. Yes. 14 Q. You didn't uy and stay out of her life; you 15 kept in close contact with her so that you could know 16 the ins an outs of her relationship with her boyfriend? 17 A. I didn't stay too close to her. 18 Q. What age or what grade do you think — strike 19 that. 20 Can you have a specific recollection of Jane 21 Doe 4 using drugs in the ninth grade? 22 A. Yes. 23 Q. What — do you have a specific recollection of 24 her using drugs in the tenth grade? 25 A. I can't recall. Page 329 1 MR. CRITTON: Form. 2 THE WITNESS: Tenth. 3 BY MR. HOROWITZ: 4 Q. Okay. Any — any other grade? 5 A. I can't recall. 6 Q. And what ages do you think what grades do 7 you think she was promiscuous, in your mind? 8 A. I can't recall what grade she was in. 9 Q. And when you describe someone as being 10 promiscuous, are you comparing it to sort of your own 11 values and morals or — 12 MS. BLANTON: Object to the form. 13 And do not answer that. 14 THE WITNESS: I'm not going to. 15 MR. HOROWITZ: No. I think I'm entitled to 16 understand her foundation, the predicate upon which 17 she's calling someone promiscuous. 18 BY MR. HOROWITZ: 19 Q. And who are you comparing that to? 20 A. I'm not comparing it to anybody. Obviously 21 when a girl is having a threesome in a bedroom, that's 22 promiscuous to me. 23 Q. And you were watching this? 24 A. I walked in on it. 25 Q. And you just kind of did what? tra 44 (Pages 326 to 329) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7ancIddt-Stlee4e57-9cd81139205600fc0 EFTA01076030 Page 330 Page 332 A. Shut the door. We were at a party. 2 Q. And when you are dancing at strip dubs, do 3 you ever give lap dances to two men at a time? 4 MS. BLANTON: Object. Do not answer. 5 MR. HOROWITZ: No other questions. 6 MR. CRITTON: I have one question. 7 RECROSS EXAMINATION 8 BY MR. CRITTON: 9 Q. And Mr. Horowitz didn't want to follow up on 10 it. But he said, he asked you what — your definition 11 of promiscuous. And you said, walking in or seeing 12 someone in a threesome falls within your definition of 13 promiscuous? 14 A. Yes. 15 Q. Who did you see in a threesome and where were 16 you? 17 A. Jane Doe 3. 18 Q. Was with what, another girl and a guy? Two 19 guys? 20 A. Two guys. 21 Q. Wbat was she doing? 22 A. I just saw her naked over the bed. That's it. 23 MR. CRITTON: All right That's all I have. 24 RECROSS EXAMINATION 25 BY MR. HOROWITZ: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF PALM BEACH 1 the undersi authority, certify that personally appeared before me and was duly sworn on the 10th day of November, 2009. Dated this 20th day of November, 2009. &Air :tut Sandra W. Townsend, Court R 16 Notary Public - State of Florida My Commission Expires: 6t26/12 17 My Commission No.: DO W3913 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 331 Q. And what grade was she in when this supposedly took place? A. I can't recall. MR. HOROWITZ: Thank you. MR. CRITTON: You going to read? MS. BLANTON: Yes, please. VIDEOGRAPHF.R: Going off the record. This is the end of tape number five. The time is 6:12 p.m. (Witness excused.) (Deposition was concluded.) 1 CERTIFICATE 2 STATE OF FLORIDA 3 COUNTY OE PALM BEACH 4 Sandra W. Towson& Court Reporter sad Notary Public in and for the State of Florida at Urge, 6 do Itchy et-iffy Om the aforementioned witruna was lyy me first clay swan to testify the whale Mork that I wall authorized to and did Itfort said doposmon stenotype; and this the foregoing pages rumbaed 157 to 329. inclusive, aro a Int and correct hartxripion of my sbonhand noies Maid deposition. I funk( certify that said deposition was 10 taken at the time and place hatirtabovc set forth and that the taking of said deposition wn connanced and 11 completed as hereinabose set at. 12 I further certify Oat I am tot attorney or Camel of any of the parties, nor am! a relative or 13 employee Many attorney or counsel of party emanated with the action, nor am I finan.ially interested in On 14 action. 15 The foregoing eaufleabon of this incorript does not apply to any reproduction ti the same by any 16 nails unless under die dimes cordrd and/or direction of the certifying reporter. 7 9 17 18 19 20 Dated this 20th day of November, 2009 21 Cia2hdrAELAC/L 22 23 24 25 Sandra W. Townsend Court Reporter Page 333 45 (Pages 330 to 333) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7082dd669eo-4o57-9cd8-839205600fe0 EFTA01076031 fags 334 Page 336 DATE, 2 TO Go i non, Esquire 3 MCINTOSH. SAWRAN, PELTZ & CARTAYA, P.A. 1601 Fawn Place. Suite 1110 W Bach, Florida 33401 CASE NO.: 08CA0373 I 97000M3 AB eC IN RE Epstein vs. Please take notice that on Tuesday, the 10th of November, 2009, you gave your depositica in the above-referred matter At that time, you did not wain signature It is now necessity that you sign your 9 deposition_ Please all as office at the below-listed 10 number to schedule an appointment between the hours of 9110 a.m. and 4:30 p m., Monday through Enday, it the 11 Esquire office located nearest you. If you do not read and sign the deposition 12 within a reasonable time, the original, which has already been forwarded to the ordering attorney, may be 13 • filed with the Chili of the Court Byars wish to waive your signature. sign your name in the blank at the 14 bottom ofthis letter and return it to us. 15 Very truly yours, 16 17 18 Sandra W. Townsend, FPR PROSE COURT REPORTING AGENCY 19 250S. Australian Avenue, Suite 1500 West Palm Beach, Florida 33401 20 21 22 23 24 2S 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the 6 foregoing deposition by me given, and that the 7 statements contained herein are true and correct to the 8 best of my knowledge and belief, with the exception of 9 any corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2009. 14 15 16 17 18 19 20 21 22 23 24 25 I do hereby waive my sigranire waive my signature. Cc Via transcript: All Counsel of Record; file copy CERTIFICATE Page 335 1 2 3 4 S 6 7 PAGE LINES CHANGE REASON RRATA SHEET IN RE: I. VS. t WISEND DEPOS ON O TAKEN. 11/10(19 DONDE WRITE ON TRANSCRIPT - ENTER CHANGES HERE 8 10 11 12 13 14 15 16 17 18 Please forward the original signed errata sheet to this office so that copies may be distributed to all parties. Under penally of perjury,1 declare that 1 have read my 20 deposition and that it is true and correct subject to any changes in &an or substance enteral here. DATE: SIGNATURE OP DEPONENT. 19 21 22 23 24 25 46 (Pages 334 L._ PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsond (401 7a82dddf-69oe-44757-9cd8-839205600fc0 EFTA01076032