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Page 502 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB Plaintiff, -vs- VOLUME IV OF IV JEFFREY EPSTEIN AND Defendants. VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF Tuesday, February 09, 2010 10:09 - 5:05 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1296 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542lef-d299-4e4t-gba6-85and271A405 EFTA01076158 EFTA01076159 Page 503 Page 505 Is 16 17 18 19 20 21 22 23 34 25 10 1 APPEARANCES: 2 On behalf of the Plaintiff.," and 3 BRAD J. EDWARDS. FARMER, JAFFE, WELSSREG, EDWARDS FESTOS & 1EHRMAN, P.L 425 North Andrews Avenue 5 Suite 2 6 Fort da ' 33301 Phone: 7 On behalf o the Jeffrey Epstein: 3 ROBERT D. CRITTON, JR., F5QU1RE MARK T. Lunn, ESQUIRE 9 atramAN. CRJTTON, LUTTIER & COLEMAN. ELP 303 Banyan Boulevard Suite 400 West 33401 Phone 2 On he f ot the De ate, Jeffrey Epstein: 3 JACK ALAN GOLDTJERGER. ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South Suite 1403 West Pa a 33401-5012 Phone: ALSO PRESENT. kffrey Epsldn, via video conference Daniel C1/47.7ney, Viikographier Visual Evidence, Incorporated 1 2 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROCEEDINGS THE VIDEOGRAPHER: We're back on the record at 1:48 p.m. BY MR. LUTHER: Q. Okay, Ma'am. I want to add that during the morning session, I was asking you some questions. I just want to go over a couple of things. One of the first things I asked you this morning is whether you understood you were under oath today. And you indicated you did understand that? A. Comet. Q. Are you, did you, are you aware of the fact that it is a crime known as perjury to make a false statement under oath? A. Correct. Q. Are you also aware that it is a separate crime, a federal crime to make a false statement to an FBI agent? A. Correct. Q. And you've already admitted that you committed that federal crime; you lied to the FBI, according to you. A. I was in fear of my son's life, correct. 1 2 3 4 5 5 7 8 9 10 11 12 13 14 15 16 19 20 21 22 23 24 25 Page 504 INDEX VOLUME I DIRECT CROSS REDIRECT RECROSS BY MR. LUTHER 4 EXHIBITS EXHIBIT DESCRIPTION PAGE DEMI Photo of 512 ad 518 634 618 1 2 3 4 5 6 7 8 9 10 11 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 506 Q. Now, l want to ask you one more time: Is there anything you want to correct about any of your testimony this morning, especially as it relates to worki in laces of employment thati wiltave termed to be at or about or near m o m s A. Correct. I'm fine on that. Q. Okay. Isn't it a fact that on Saturda January 30th, you went to A. Yes. Q. And you got them, what time, around 8:00? A. Yes. some point in time you left did you not? A. Yes. Q. And you went to a place called of Palm Beach, did you riot? A. Not that I recall. I don't know a name Q. Well, Each' located right next door to A. I thought that was affiliated with . You're familiar with that, aren't, ''. MI. Q. Well, so that ue know — would be the 2 (Pages 503 to 506 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542Icf-d299-4e4f.9ba6-85aad27f4405 EFTA01076160 Page 509 Page 507 1 (Cellphone interruption.) 2 THE WITNESS: Oh, Pin sorry, my phone. 3 MR. LUTTIER: Sure. Oo ahead. 4 THE WITNESS: Okay. Sorry. 5 BY MR. LUTTIER: 6 Q. There is whether or not it's 7 affiliated with 1 don't know. When 8 you referred to your testimontl ming that you 9 didn't go anyplace other than MM Rhinos and 10 places affiliated did, with it, did you mean to 11 include in those places that you went of 12 Palm Beach? 14 Beach, but I know that, there, that has A. I persona lly never heard ofaiir 13 15 a couple places affiliated with them. 16 Q. What places do they have that are 17 affiliated with them? 18 A. The back and then there's an entrance to 19 another place. That's all ! know. 20 Q. Well, tell me about this entrance to 21 another place. What am yo 22 A Well, in the back of there is 23 a little section that the dancers -- I don't know 24 exactly what they do there, but that's where I do sell 25 shoes and my lingerie. Page 508 1 And then there is another entrance that 2 you can go through and then there is another it's 3 like there's, I know that there's, there's a lot of 4 doors. I don't know what they consist of. 1 don't know what they do there, but I know that they are 6 t that they were affiliated with 7 and that's where I also go to sell 8 my shoes and purses. 9 Q. Oka about a place in 10 the back of the ou • access 11. to by going through the 12 establishment? 13 A. Yes. 14 Q. All right. Now, what is this second place 15 that you are talkin a out that u say is 16 affiliated with 17 A. ter go through out the back 18 door of and take a right, and then there 19 is a place there that's affiliated with them. 20 Q. Is there a name? Is there a separate 21 entrance to the place? 22 A. I — they're connected. 23 Q. Is there a separate name on this place? 24 A. Not that I know of 25 Q. Okay. I'm tallthsabout a place that's 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 v it's to the left side of as you look at it. It's got a separate entrance. It's got neon signs on it? A. Okay. Q. And it's known as You're aware of that place, aren't you MR. EDWARDS: Fora THE WITNESS: I'm not aware of any name. BY MR. LUTHER: you w in the establishment known as on the evening of Saturday, January 30th, 2010, were you not? MR. EDWARDS: Font THE WITNESS: If that's what it's called, MM. long, as far as I know, that's the name I know it as of, you know. BY MR. LUTTIER: Q. Well, this is a place that has a separate Y don't go through the entrance of for a place called . rate entrance A. Well — Q. I want to make sure we're real clear here we're not playing semantics. Page 510 1 A We're not playing what? 2 Q. Semantics. 3 A. Okay. 4 MR. CRITTON: Word games. 5 THE WITNESS: Oh. 6 MR. LUTTIER: All right? 7 THE WITNESS: Yeah. 8 BY MR. LUTTIER: 9 Q. Sil dai rwere in fact, in this place 10 called on Saturday, January 11 30th, 2010, were you not? 12 MR. EDWARDS: Object to the fonn. 13 THE WITNESS: I definitely walked through 14 an elmitithought was affiliated 15 with 16 BY MR. LUTTIER: 17 Q. And there's a black female in there that 18 works at the front desk, is there not? There was on 19 Saturday night. 20 A. Oh, I don't know. I don't know who works 21 there. I don't blow. 22 Q. And the -- 23 A. I just know that I go into 24 I sell my — 25 Q. And — and 3 (Pages 507 to 510) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fef-d299-4o4f-9ba6.85aad2714405 EFTA01076161 Page 511. — items. 2 it . the name that you're known as is 3 isn't that right? 4 A. I'm not known as r= 5 Q. That's the name you remember we were 6 asking you about the cards you used to use? A. Yeah, I was known as =in '07 and '08. 8 Q. that's the name you've used in the past 9 is 10 A. Yes. 11 Q. And in fact on Saturda January 30th, you 12 were working in which was. 13 to use your terms, a were you not? 14 A. NA I was not working there. 15 Q. And you were charging $120 fora half hour 16 to perform services; isn't that right? 17 A. No. 18 Q. Andacame out and told somebody your 19 name was Mend that that was your charge, 20 didn't you not? 21. A. No, I did not. All I do is sell shoes and 22 purses there. 23 MR. LUTRER: Let me show you a picture 24 here which we'll mark as, !guess we want to do 25 it in order. It will be Exhibit 3. Page 513 1 A. No. I say to the girls, my name is 2 they know that I sell all of my, all of my cil anand 3 lingerie and shoes and everything else I sell. 4 Q. But there is no doubt that now that you 5 have seen this picture, you were in that 6 establishment that is depicted on Exhibit No. 3 on 7 January 30th, right? 8 A. Correct. 9 Q. And you drive a white Mitsubishi Gallant; 10 is that right? 11 A. Yes. i 2 Q. License plate number is is that 13 correct. 14 A. I don't know my license plate number, but 1 15 definitely drive a white Mitsubishi Gallant 16 Q. And is, was that vehicle parked outside 17 of the Palm Beach on Saturday night, 18 atu rn y e 30th? 19 A. Yes, but like I said before, from my 20 knowledge, I thought this was affiliated with 21 22 Q. And that car 23 A. And they don't like me to park, they don't 24 like me to park in front of because 25 there are so many clientele Agoe fl n., out. So Page 512 1 (Defendant's Exhibit No. 3 was marked for 2 identification.) 3 THE WITNESS: This place, yeah, ifs next 4 to - 5 MR. LUTTIER: Hold on. Hold on. 6 THE WITNESS: Sorry. 7 BY MR. LUTTIER: 8 Q. I have to ask you a couple of questions. 9 Do you recognize Exhibit 3? 10 A. Yes but what I would do, 'would go out of 11 from the beck and go into the back 12 entrance of or whatever this place is called. 13 Q. SA so, now upon seeing the picture, you 14 want to correct our testimon and say, in fact, you 15 were in on Saturday? 16 A. I, from my understanding, from my knowledge, I 17 thought that this place was owned by 18 Q. All right. The place of business that's 19 depicted in Exhibit No.3, were you in that place of 20 business on Saturday, January 30th? 21 A. Yes, selling my items. 22 Q. And did you, in fact, on that night, on 22 23 Saturday, hus30th, toll individuals that your 23 24 name was and that you charged $120 per half 24 25 howl Page 514 1 they need as much parking space as they can. 3 until what hour on the 2 Q. And you stayed at 4 be January 31st? 5 A. I stayed until what time? 6 Q. Yeah, the morning until — what time on 7 the morning of Sunday, January 31st, did you leave? A. Well, I would go wail 9 closing like 5, .. •t" .1 1 m le back of here, of 10 that's like, sometimes they have after 11 parties t This is what I hear from the, 13 sometimes lam/MM.; a couple of drinks. 12 the manager at And like I said, 14 And I'm not sure what time I left 15 Q. I don't want to know — 16 A. As long estkeep on selling shoes and 17 lingerie, I'm the there. 18 Q. I am not asking about sometimes. T am 19 talking about Sunday morning, January 31st, 2010, 20 what time did you leave on that day? 21 A. I couldn't tell you that. I don't know. Q. Well, what's your best estimate? A. I don't know, sir. Q. Well, first of all you closed at, what, 5 in the morning? a......4:01.3.4SOW.,••••••••.•...mveatilmcnista 4 (Pages 511 to 514) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542for-d299-4c4f-9ba6-85aad2714405 EFTA01076162 Page 517 Page 515 1 A. I closed it? 2 Q. Yeah, you were them until it closed? 3 A. Yes. 4 Q. And then you went over to 5 right? 6 A. That I thought was 7 back 8 Q. Whatever. 9 A. Okay. 10 Q. And then, how much longer did you stay 11 there? 12 A. I stayed there a little while because there is 13 more girls there that like to buy my items. 14 Q. Now, let's talk about your trip to New 15 York 16 A. Okay. 17 Q. Tuesday, February 2nd, 2010. Remember I 18 asked you earlier about whether you ever used any 19 business cards? 20 A. Yes. 21. Q. When you went on this trip to New York, 22 did you have any cards? 23 A. No, not that I no. 24 Q. Did M . have any cards? 25 A. Not that I know of. from the 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. And we started talking to people. Q. Who did you talk to in particular? A. I don't know anyone else. Q. Did you talk to a male there? A. Yeah. Q. Have him over at your table? A. He came closer to — we were at the bar. Q. The three of you were talking, were you not? A. Yeah. Q. Do you remember the guy having a laptop? A. Yes. Q. What did you-all do on the laptop or what did he do on the laptop while you were there and you both were sitting there? Well, I told him that I modeled for And I told him if he would like to see my pictures, to go onto Q. So, did you tell him about any other websites? A. Excuse me? Q. Did you tell him about any other websites? A. No, not that I recall. MR. LIMIER: Let's mark this as exhibit — what's this, 4? Page 516 1 Q. Did you, when you went to the Palm Beach 2 International Airport, did you give the taxicab 3 driver a card? 4 A. Did I give hi card? 5 Q. Yeah, you or M., little business card? 6 A. I didagive him a card, no. 7 Q. Did M. give him a business card? 8 A. Not that I know of. • 9 Q. When you went into the Palm Beach 10 International Airport, your card — do you recall 11 going to a bar? 12 A. Palm Beach International Airport, yeah, I went 13 to a bar there — 14 Q. What bar do you go to? 15 A. — because I totally missed the flight. 1.6 Q. What bar did you go to? 17 A. I think it was Fridays, if I am not mistaken 18 or not. I don't know what it was called. 19 Q. Who went VS bar with you? 20 A. 1 went with M. to the bar and it was just 21 her and 1. 22 Q. And for how long was it just the two of 23 you? 24 A. For like ten minutes. 25 Q. And then what happened? 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT Page 518 THE COURT REPORTER: Four. MR. LUTHER: Mark this as 4. MR. EDWARDS: Is Exhibit 1 and 2 marked — MR. LUITIER: Yeah. MR. EDWARDS: in the previous depo? MR. LUTHER: Yeah, the previous depo. Although I don't know where the exhibits are or they were. MR. EDWARDS: Okay. MR. LUTTIER: It was like answers to interrogatories. Something like that. MR. EDWARDS: Okay. (Defendants Exhibit No. 4 was marked for identification.) BY MR. Q. Let me show you what's been marked as Exhibit 4 and ask you if you can identify that. A. This is — MR. EDWARDS: Wait until he asks you a question. BY MR. LUTHER: Q. Can you identify it? A. Yes. Q. What is it? A. This si— 1 modeled forallitand it _ 5 (Pages 515 to 518 REPORTING AGENCY, INC. Electronically signed by cynthie hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542lef-d299-4041-9ba6.85aad27f4405 EFTA01076163 Page 519 1 is their advertisement now. 2 Q. And is this one of the pictures on your 3 website? 4 A. On my website? 5 Q. Yeah or your Facebook, !guess, account 6 or MySpace, whatever it was. 7 A. Yeah, I have posted it on there, yeah. 8 Q. Is, was this one of the pictures you were 9 telling us at your last deposition that you really 10 wouldn't want your four-year-old son to see? 11 A. No, that's fine if he sees this. This is, 12 this is very legit. His mother modeled and I am 13 actually very proud of this photo. 14 Q. All right. Now, did you do anything else 15 with this indigaial before you left the bar that 16 you, you and M. were talking to at the Palm Beach 17 International Airport? 18 A. Did we do anything with him? 19 Did you give him anything, either you or 20 21 A. I don't recall givinglupt anything but — 22 Q. Well, did you see M. give him anything? 23 A. No. 24 Q. Did either one of you give him a business 25 card? 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 521 Q. Did you do anything else that evening? A. Yes, we went out to dinner. Q. After you — did you leave the apartment and go look around at Grand Central Station and then keep on walking around or did you come back to the apartment? A. We went back to the apartment. Q. Okay. And then there came a time after you came back from sightseeing that you left the apartment a second time? A. Yes. Q. And that was for what purpose? A. We went to Angelo's. Q. Okay. And how did you get to Angelo's? A. We got to Angelo's in a taxi. Q. A taxi? A. Uh-huh. Q. And that was about what time? A. Oh, jeez, maybe, maybe 9:00. Q. Between the time — what time did you go looking at Grand Central Station? A. That was before 9:00. Q. Okay. And do you remember, do you recall that evening an individual by name of Martin Krouner? 1 2 3 4 5 7 8 10 11 12 13 14 15 16 17. 18 19 20 21 22 23 24 25 Page 520 A. I don't have any business cards. I don't — Q. Well, I don't — you may want to be careful here. I don't want to trick you. lam not playing semantics. Did either you or give him a business card? MR. EDWARDS: Object to the form. THE WITNESS: Not that I recall, no, sir. We had a few drinks and, and we were off to our flight. BY MR. LUTTIER: Q. And then you flew to New York and you took a c and u went to this apartment that's located at in New Yor • is that right? That would be the corner of A. rings a bell. That's where we stayed? Q. Yeah. A. Yeah. Q. Now, on that evening, the first night that you got there on Tuesday, I think earlier you said you-all walked down a street and went to dinner, is that right? A. We walked down the street and we walked into a, I think it's Grand Central Station. I'm not sure because I'm not from there and we looked around. Yeah. 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 522 A. Do I know a man named Martin? Q. Uh.huh, Martin Krouner. A. No. Q. Do you remember getting in a black Series 5 BMW when you came out of the condominium? A. We, we did take a ride with a man. Q. Well, 'thought you just told me you walked to the restaurant. A. No, 'told you I took a cab to the restaurant. Q. Oh, took a cab to the restaurant? A. Yes. Q. Did you forget about getting in a car with this man? A. He took us a little sightseeing. No, I did not forget about that. Q. Was that before dinner? A. That was before dinner, yes. Q. Did you just fail to mention that or — this is different than the man who took you sightseeing later, isn't it? A. Yes. Q. Okay. So, tell me who Martin Krouner is. A. I don't know his name, if that is his name. Q. Well, the guy that picked up in the black BMW, who's he? 6 (Pages 519 to 522) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542let-d299.4c41-9ba6.85aad27f4405 EFTA01076164 Page 523 Page 525 1 A. I guess a friend of_. 2 Q. Well, tell us how old this individual was. 3 Describe him for us. 4 A. He has not a lot of hair. He's about five-six 5 maybe and a little chubby. 6 Q. For what purpose were you — and you never 7 met him before? 8 A. No. 9 Q. never met him before? 10 A. No. 11 Q. You didn't have any idea who he was? 12 A. No. 13 Q You-all climbed in car? 14 A. Yeah, I thinkit was friend. 15 Q. Okay. What did tell you about the 16 guy? 17 A. She's Chinese. She's like go, go; go, go have 18 fun, go search the town. 19 Q. So, where did you go with Martin? 20 A. We ended up meeting him at Angelo's. 21 Q. Wait a minute. You got — first of all 22 you got in Martin's car, right? 23 A. I got into Martin's car, yes. 24 Q. And then where did you go once you got in 25 Martin's car? 1 fellow here, Mr. Martin Krouner? 2 A. If that's his name. I don't know if we took a 3 picture of him, but we definitely took pictures of M. 4 and I. 5 Q. And, and where did you take those 6 pictures? 7 A. Wherever we were. 8 • Q. Okay. And when this man brought you back, 9 did he go to darner with you? • 10 A. He ended up meeting us there, yes. 11 Q. Did he drop you at the restaurant? 12 A. He dropped us near so we can get there with a 13 taxi. He dropped us somewhere off of the street and we 14 went with a taxi. 15 Q. So, he dropped you off and then you got a 16 taxi to get there? 17 A. To go to Angelo's, yeah. 18 Q. And then he met you there later? 19 A. Lateran. 20 Q. Okay. About what time? 21 A. Oh, God, I don't know the times. Maybe this 22 was around, maybe around — I'm — this is total 23 ballpark, lace 10 maybe. 24 Q. Okay. Anal& and then after dinner 25 what did you and M. and he do? Page 524 1 A. We searched around the town. 2 Q. What do you mean you searched around? 3 A. We went sightseeing. 4 Q. Okay. Do you remember where you went? 5 A. And we went sightseeing. 6 Q. Do you remember where you want 7 sightseeing? 8 A. Then we took a taxi. No, because I don't know 9 the area. 10 Q. You went sightseeing in Mr. Kroner's car, 11 correct? 12 A. Yes. 13 Q. All right. And, and did there come a time 14 that you got of Mr. Kroner's car? 15 A. Yeah, and we looked around. It was filming 16 outside, so it was nice to feel the snow. 17 Q. And where did you get out of the car? 18 A. Sir, I don't know New York. I don't — 19 Q. Well, was it at a restaurant? Was it at 20 the pool? Was it back at the condo? Where was it? 21 A. R was near a whole bunch of buildings. 22 Q. By the way, did you take any pictures 23 while you were up there? 24 A. I did take pictures. 25 2. Take a icture of you at and this Page 526 1 A. Well, we took a taxi back to his car. And we 2 went up to the, we went up to room and he just -- 3 we just said bye. 4 Q. And did you receive anything at all of 5 value from this man? 6 A. No. 7 Q. Did you charge him anything? 8 A. No. 9 Q. Were you paid anything for the time you 10 spent with him? 11 A. No. 12 Q. Now, who's Robert Fredrick Burke? 13 A. Robert Fredrick Burke, I have no idea. 14 Q. Well, on the next day on Wednesday, 15 February 3rd, did you go sightseeing again? 16 A. Yes, we did. 17 Q. And you said that this fellow Bobby came 18 to see you at the apartment sometime the morning of 19 Wednesday, February 3rd? 20 A. He came to see us, ubhuh. I'm not sure what 21 time it was. I think it was around in the afternoon. 22 . Okay. And then after he eft, you and 23 did some more sightseeing? 24 A. Yeah, we walked around town. 25 Q. Do you remember getting in a vehicle with PROSE COURT REPORTING 7 (Pages 523 to 5261 AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421of-d299-4e41-9ba6.85aad2714405 EFTA01076165 Page 527 Page 529 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 somebody that night? A. Yes. Q. Who did you get in a vehicle with? A. I told you, I don't know his name. Q. Well, where did you, where did you meet this person? A. Everybody was =friend. =has a lot of friends. Q. A. Q. A. Q. A. Q. A. Q. A. I have no idea. Q. And where did this individual take you? A. He took us to sightseeing and he took us to the Statue of Liberty, everywhere. Q. Did you receive anything of value from him? A. No. Q. Did you charge him anything? Well, what did you know about the person? Nothing. How old is the person? I told you, I don't know anything about him. And what kind of vehicle did you get in? I don't even know the vehicle. Toyota Highlander? Ls it — I don't know. And what nationality is this individual? 1 A. I have no idea. 2 Q. Were they a male's clothes or female's 3 clothes? 4 A. I didn't search through the garbage. I just 5 know that I threw out the trash. 6 Q. So you're telling me you don't know whose 7 they were? 8 A. No. 9 Q. Oistry. Do you know 10 A. Yes, Id°. 11 Q. And how do you know 12 A. We grew up together. ro bly 'mew her since 13 1 was 12. 14 Q. Have you ever been engaged in any kind of 15 a business venture, regardless of whether it was a 16 formally formed business venture like a corporation, 17 but any kind of business venture with .M? 18 A. I went, we went to Jeffrey's togWer. 19 Q. My other kind of business venture, you 20 and her? 21 A. No. 22 Q. Were you ever, did you ever represent or 23 attempt to start a business venture with her? 24 A. This is years ago. 25 Q. How many years ago? Page 528 1 A. No. 2 Q. You or El? 3 A. I did not charahim anything. 4 Q. How about ? 5 A. I don't know what she does but, no, I don't 6 think so. 7 Well, was there ever a time that you and 8 were not together in this person's presence? 9 A. Other than me going to the restroom, no. We, 10 I, we were pretty much together the whole time. 11 Q. On the evening of February 3rd, 2010, do 12 you recall throwing a bag of trash in the garbage? 13 MR. EDWARDS: Mat date is that? 14 MR. LUITIER: The evening of February 3rd, 15 2010, at approximately 9:00 p.m. 16 THE WITNESS: In the evening. 17 MR. LUTHER: Just before you got in the 18 Toyota Highlander. 19 THE WITNESS: Yes, we did. 20 BY MR. LIMIER: 21 Q. Okay. And do you recall what it was that 22 was in that bag? 23 A. There was whole bunch of clothes and 24 everything that did not want, so we threw it out. 25 Q. And whose c other were those? Page 530 1 A. Well, 13, 14, 15, like eight years ago. 2 Q. Okay. So, this is 2010. We're talking 3 about 2002? 4 A. Yeah. 5 Q. Okay. So tell us about the venture that 6 you were forming with her? 7 A. I don't know what you're talking about. 8 Q. Well, you were thinking about something 9 because you said years ago. You were the one that 10 picked the date. So, what was it you were thinking 11 about? 12 A. No, I said years ago we, we knew each other. 13 We used to hang out. Like we used to do little girl 14 stuff, go in the pool and — 15 Q. No, my question was, was there a business 16 venture and you said it was years ago. 17 A. It was years ago that I've known her. Any 18 type of business venture, not that I recall. 19 Q. Have you ever told anyone at all that you 20 and were forming a business venture or had a 21. business venture? 22 A. At 12, no, I don't — 23 Q. At any, I don't care, right up until 24 today. 25 A. No. ? Noliedades tliZteAlit•40 , 11.1111.7a....429>Veal <aatia606 .44-L7fl4.i 8 (Pages 527 to 530) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia honking Electronically signed by cynthia bodkins Electronically signed by Cynthia hopkins b55421ef.d299-4e4f-9bat3-85aad2714405 EFTA01076166 Page 531 1 Q. Did you ever have any sort of a business 2 venture that involved in any way, shape, or form you 3 and/or her taking showers? 4 A. No. 5 Q. Did you ever tell anybody you did? 6 A. No. 7 Q. Did you ever have any literature or 8 written material describing such a venture? 9 A. Not that I recall, sir. 10 Q. Ever have anything that described such a 11 venture or any costs associated with procuring those 12 services if someone wanted to do that? 13 A. Taking showers? 14 Q. Well, taking showers or watching the two 15 of you take showers or any combination or 16 permutation that you can think of. 17 A. Not that I can think of unless we were like 18 stupid little girls who — I don't recall anything about 19 any shower or anything like that, no. 20 Q. Did you ever tell anybody that you had 21 such a business going? 22 A. No. 23 Q. Did you ever tell anybody you had such a 24 business going with someone other than e? 25 A. A business going, no. 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 532 Q. I don't mean a formal thing, Did you ever tell anybody that you were involved in any kind of activity involving taking showers for which you got paid money? A. Definitely not. I don't — I have never. And when was the last time you talked to A. Oh, boy. It's been years. Ballpark three years maybe. Q. And where did you talk to her three years ago? A. At the trailer that I had an at. Q. Now, your other friend, A. Uh-huh. Q. — when is the first time that you can recall having done any type of a drug with..? A. When we first started seeing Jeffrey we tried to numb each other with like downers, you know, Percocets or something just to ignore really what was going on between Jeffrey and us. Well, at the lad deposition you told who we know to bed first at u to Jeffrey's. Do you recall that testimony? A. Yes. Page 533 Q. And you testified that she provided you 2 with drugs? 3 A. Yes. 4 Q. All right. Now, who provided the drugs to 5 e? 6 A. I have no clue. 7 Q. Well, who provided the drugs to you that 8 you just claim you took when you were with 9 A. I couldn't even say. Maybe, maybe 10 11 Q. That's your boyfriend? 12 A. At the time he was my boyfriend. 13 Q. Well, he was your boyfriend. He became 14 the father of your child, right? 15 A. Yes. 16 Q. Okay. I mean, that would qualify as a 17 boyfriend, right? 18 A. If that's what you call it 19 Q. He was a drug dealer, wasn't he? 20 A. No. 21 MR. EDWARDS: Form. 22 BY MR. LUTHER: 23 Q. Did he provide drugs to you on more than 24 one occasion? 25 A. No, he, no, he, if anything, him and his Page 534 1 friends got together and they were stupid and young and 2 they did a couple of drugs, but I didn't want anything 3 to do with them until I met Jeffrey. And then I wanted 4 to numb myself to be around Jeffrey. And I know that I 5 would take drugs hrom him occasionally. 6 But he didn't like give them to me or sell 7 them to me or anything like that. 8 Q. Well, what did you do, go steal than from 9 him or what? 10 A. I would probably take him from his stash or 11 something but — 12 Q. So, he had a lot of drugs? 13 A. No, not that I remember. I don't know where I 14 got these drugs from. To telLyau the truth, I really 15 don't recall. I don't know if.. brought them. I 16 don't blow if I brought them. 17 Q. Well, did you give these drugs toe.? 18 A. No, not that I recall. 19 Q. One thing you knew was that these were 20 illegal drugs, right? 21 A. Yes. 22 Q. You knew it was against the law what you 23 were doing? 24 A. Yes, especially — Jeffrey Epstein knew it was 25 whist t ......22!222±....t.2ndISTar-old girls 9 (Pages 531 to 534) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fel-d299-4e41-9ba6.85aad27,4405 EFTA01076167 Page 535 1 too. 2 MR. LUTHER: Well, Jeffrey Epstein -- 3 move to strike as not responsive. 4 BY MR. LUTHER: 5 Q. What Jeffrey Epstein told you was that you 6 shouldn't drink and shouldn't do drugs, didn't he? 7 A. He told me that he never drank or did drugs. 8 He was so interested in saint kind of drugs we were on. 9 Q. So, not withstanding what you knew to be 10 clearly -- 11 A. He would ask, he would be asking us so how 12 does Xanax make you feel, how does coke make you feel, 13 how does Percocets make you feel, how does this make you 14 feel. 15 Q. He never asked you to take any of those 16 drugs, did he? 17 A. No, but he would — 18 Q. He never gave you any of those drugs, did 19 he? 20 A. No. 21 Q. And you claim he had all this money. He 22, could have provided you with any drug he wanted if 23 he wanted to give you a drug, couldn't he? 24 A. I guess. 25 Q. And he never provided you with one single Page 537 1 A. Probably. 2 ow, you remember going 3 don't you? 4 A. Yes, l do. 5 Q. Two occasions you went and she went in the 6 room with you, didn't she? 7 A. She went in the room with me at the beginning, 8 at the first time, yes. 9 Q. Went in the room the second time too, 10 didn't she? 11 A. I, I think so. I'm not sure about that. 12 Q. Are you aware that — 13 14 A. I bet you have pict huh. Q. Are you aware tha en deposed? 15 A. Have been what? 16 Q. Has been deposed, gone through the same 17 process you are? 18 A. Oh, yes, of course. She should be. 19 Q. How are you aware of that fact? 20 A. Excuse me? 21 Q. How are you aware of that fact? 22 A. Everybody's been deposed. Most all, most of 23 all these girls have been deposed. 24 Q. Who told you that? 25 A. You know, the girls talk. there with Page 536 1 illegal drug and told you he never touched drugs? 2 A. No, but that's not his crime. He fondled me 3 when I was 13 years old. He didn't sell me drugs. 4 Sony, he just molested me. MR. LUTTIER: Move to strike. 6 BY MR. LUTHER: 7 Q. He never provided you with one illegal 8 drug, did he? 9 A. No. 10 Q. You went and got those all on your own? 11 A. Yes. 12 Q. You and your friends would go and take all 13 kinds of illegal drugs? 14 A. Yes, because I was scared to be around an old 15 man when he is touching my vagina and masturbating with 16 his cock in front me ejaculating all over himself, so 17 yes, I would, I think you would take drugs too. 18 Q. So, were you so scared that you said I'm 19' not going anymore? 20 A. He was like our master. He's like IM 21 master. He does, anything he says, we do 22 because we are intimidated by him. We were scared of 23 him. 24 Q. So, if he said run out in front of 25 traffic, you would? 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 538 Q. Okay. A. It get's around town and it's in the newspaper every weekend, so how not know? Q. Did you talk tc A. No, I did not. 4 Okay. So, how did you know had been deposed if she was deposed? MR. EDWARDS: Object to the form to the extent — THE WITNESS: Of course she's been deposed. MR. EDWARDS: Hold on. Hold on — to the extent that you're asking for attorney-client privilege information which you did — MR. LUMEII: No. MR. EDWARDS: — in the first deposition and it sounds like you're going there again -- MR: LUTHER I don't want to know anything your lawyer said. MR. EDWARDS: — about talking to my client BY MR. LUTTEER: Q. I don't want to know any • wyer said. Have you seen a transcript of de ition? 10 (Pages 535 to 538) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronkally signed by Cynthia hopkins b5542febc1299-4e41-9ba6-85aad27f4405 EFTA01076168 Page 539 1 MR. EDWARDS: Object to the form. If she 2 has seen a transcript, that would obviously 3 being something that her attorney has shown 4 her. That is not something she would have seen 5 independent of that. So that would be 6 protected information. 7 MR. LUTTIER I, I mean, I don't think - 8 1 think if you show her a copy of a deposition, 9 that is not protected by attorney-client 10 privilege. If you had a discussion with her, I 11 agree with you, whatever your discussions were. 12 But the fact that you showed her the transcript 13 I don't think is protected by the privilege. 14 BY MR LUTTIER: 15 Q. Have ou ever seen a co y of the 16 transcript o deposition? 17 A. Not that I lcnow o 18 Q. Well, did ou know that -- or strike that 19 20 laNwere wit . Tstem on t e secon 21 occasion when she took you there, isn't it true that 22 you began a conversation with Jeffrey discussing 23 what you and your mother did and how much you 24 charged for various things? 25 A. False. Page 1 A. Am I religious? 2 Q. No, do you have a religious affiliation? 3 'Are you associated with a particular in 4 A. Yes. 5 Q. Protestant, Catholic, Jewish? 6 A. Yes, I am. 7 Q. What Illwould that be? 8 A. I believer m Jesus Christ. 9 Q. Any particular organized -- do you know 10 what I mean by organized religion? There's, theres 11 a bunch - 12 A. !would like to call myself a Christian but I 13 believe that the Lord, Catholics, Jews, Buddhism, it 14 doesn't matter because it shouldn't be judged. It 15 shouldn't be organized. The Lord doesn't — the Lord 16 doesn't organize anything. I just know that I am, I am 17 very spiritual and I do love the Lord very much. 18 Q. Okay. So you would characterize yourself 19 just as a, for lack of a better term Christian? 20 A. lam very spiritual. 21 Q. Okay. 22 A. And I pray every day. 23 Q. Do, do you participate it an organized 24 religion? 25 A. Do I go to chinch? Page 540 1 Q. Sexual nature. 2 A. No. 3 Q. Is there any reason 4 would want to make that story tqr 5 MR. EDWARDS: Object to the form. 6 THE WITNESS: I have no idea. 7 BY MR. LUTTIER: 8 Q. And isn't it true that when you began — 9 A. She knew Jeffrey more than I did. 10 Q. Well, didn't -- 11 A. This is the first time or second time I had 12 ever been with Jeffrey. I didn't tell him anything; 13. only the questions he asked nte. 14 Q. And, and isn't it true that when you began 15 to talk to Mr. Epstein and discuss with him what you 16 and your mom did and the prices u would charge for 17 things that Mr. Epstein to leave 18 the room? 19 A. I don't even know why my mother is brought up 20 in this because, no, I would never talk about my mother 21 as being a prostitute. She did not raise me like that. 22 My mother is a very beautiful person inside and out and 23 she would never raise me like that. 24 Q. By the way, what is your — do you have a 25 religious affiliation? 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 PROSE COURT REPORTING Q. A. Q. A. Page 542 Yeah. Yes. And where did ou o? I've been to Tye been to was the last time you were at mber '08. Q. And where did you go, for Christmas? A. Before Christmas. Okay. And when was the last time you were September '08. Q. Okay. Are you members of either of those churches or you just went to them? A. If you want to call me a member, I — Q. Are you a registered in them? A. — I attend, I attend yes. Q. Do you attend it wr some o regularity? A. Yes. Q. And how often? A. As often as I can. Q. Okay. Well, I mean, I don't want to pin you down to a scpecific number of!latu!.22ow many 11 (Pages 539 to 542) AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542lef-d299-4c41-9ba6-85aad2714405 EFTA01076169 Page 543 1 days a month would you say on average you go? 2 A. As of tight now, one, unfortunately. 3 Q. And when you say unfortunately, are you 4 unable to go more days? 5 A. No, I would love to go more days. 6 Q Okay. Was there something that prevents 7 you from going more days? 9 A. I have a busy life. 9 Q. Okay. What is it that you're doing that 10 prevents you from going more days. 11 A. Well, lam trying to get my son enrolled into 12 Christian school, and there's a lot of bills that need 13 to be paid and things that need to be done, errands that 14 need to be ran, clothes that need to be washed, food 15 that needs to be bought, time I need to spend with my 16 son. 17 Q. So, it's errands and clothes, laundry, 16 purchasing groceries and stuff, and time with your 19 son that prevents you from being able to attend more 20 frequently; is that right? 21 IVIR. EDWARDS: Object to the form. 22 THE WITNESS: Stn. 23 BY W. LUTHER: 24 Q. You set your own work hours, right? 25 A. Yes. Page 545 1 A. You guys have been there before. You should 2 know. 3 Q. It's the same house she's always lived in? 4 A. No. She hasn't lived there her whole life. 5 Q. Okay. But I mean while you were a kid, 6 when, when you were living with her; is it the same 7 place that she lived in? 8 A. No. 9 Q. Bow long has she been living where she is 10 now? 11 A. I don't know. There's been a couple of years 12 that my mother and I haven't talked. 13 Q. Well, when was the last time you talked to 14 your mother? 15 A. Today. 16 Q. And, and when did you talk to her? 17 A. This morning. 18 Q. And why did you talk to her this morning? 19 A. So she could pray with me over the phone. 20 Q. And when was the last time you talked to 21. her prior to this morning? 22 A. Last night 23 Q. Did I misunderstand? I thought you said 24 there was a - 25 A. There was a period in my life that we didn't Page 544 1 Q. Your mother is and I may get 2 this name sort of, is it? 3 A. Yeah. 4 Q. Did I !announce it right? 5 A. No. 6 Q. w ou do pronounce that? 7 A. 8 Q. . And is she currently married? 9 A. No. Can I have a tissue? 10 Q. And where does she currently live? 11 A. In 12 Q. In what development? 13 At I don't know what the developments called. 14 MR EDWARDS: Can we take a split second 15 break to take grab a tissue? 16 MR. LUTTIER: Sure. 17 MR. EDWARDS: 1 don't see one right now. 18 THE VIDEOGRAPHER: Going off the record at 19 228 pm. 20 (A brief recess was held.) 21 THE VIDEOGRAPHER: We're back on the 22 record at 2:32 p.m. 23 BY MR. LUTHER: 24 Q. Okay. You're saying you don't know the 25 development that she lives in PROSE COURT Page 546 1 talk. 2 Q. Okay. So that's some past period of time? 3 A. Yes. 4 Q. When did that change? 5 A. Around May '09. 6 Q. And what is it that caused the change in 7 May of '09? 8 A. I was living my life and she was living hers. 9 Q. What does that mean? 10 A. I was living my life and she was living hers. 11 Q. Okay. Why did that, why did that 12 facilitate — 13 m ire was taking cafe of my sister that has 14 and they were going through a lot, so I left it 15 alone. 16 Q. My question was what caused in May of '09 17 this period of estrangement between you and your 18 mother to end? 19 A. I just told you. 20 Q. You said that your mother - 21 A. My mother and I, she had — my. was 22 taking care ofkiter who has severe 23 Q. That's 7 24 A. Yes. 25 9. Oka You mean duri • your riod of 12 (Pages 543 to 546) REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b6542104299-4•41409646aad2714405 EFTA01076170 Page 549 Page 547 1 estrangement? 2 A. Yes. 3 Q. Okay. So, you didn't communicate with her 4 because she was taking care of your sister? 5 A. Yes. 6 Q. Did something happen in May of '09 that 7 changed all that? 8 A. My sister moved away. 9 Q. 'iwere did she go to? 10 A. 11 Q. And, and when she moved, did she go with a 12 boyfriend? 13 A. Yes. 14 Q. And who is that? 15 A. Wu name is 16 Q. Do you know his last name? 17 A. No. 18 Q. And she's still living in IMM? 19 A. Yes. 20 Q. Now, what's the relationship between you 21 and your sister? 22 A She's, she has like she's a little slow, so 23 we can't really relate but other than that I love her. 24 Q. Well, haven't you in the past been violent 25 toward your sister? Page 548 1 A. Yeah. 2 Q. And tell us exactly what you did to your 3 sister. 4 A. Well, when I was 14, 15,14, I was like 5 mentally abusive to her because I guns I was just taking out everything, all of my pain from what was 7 going on with Jeffrey, and I would just take it out all 8 on her. 9 Q. What do you mean by you would take it out 10 on her? 11 A. I was mentally abusive to her. 12 Q Well, describe what it is you actually 13 did. 14 stuttered; l would make fun of her. She 15 has I wouldn't respect it. 16 Q. And did your sister actually have to get a 17 restraining order against you? 18 A. No. 19 Q. Did your sister ever get a restraining 20 order against you? 21 A. Not that I know of. She's slow. She's not 22 all there. She has like part =. 23 Q. Now, did your mother discuss with you 24 about whether she ever had any discussions about you 25 with an else? A. Excuse me? 2 Q. Did your mother ever discuss with you 3 whether she had any conversations about you with 4 anybody else with respect to this lawsuit? 5 MR. EDWARDS: Is this in addition or 6 different than the previous discussion that wm 7 discussed at the first deposition? 8 MR. LurnER: I won't know until she 9 ansmms 10 MR. EDWARDS: But is this a separate 11 occurrence from what she was asked at the last 12 deposition? 13 THE WITNESS: No, she's never discussed 14 anything else with anyone else, no. 15 BY MR pima 16 Q. Okay. 17 A Not to my knowledge. historically as a child you used would she be Q. And if yourmothertnld ry that 18 20 telling the truth? 21 A. Yes. 22 Q. Do you mho• 23 A Yes, I dm 24 Q. And who is that? 25 A Ekriumrent boyfriend. is? Page 550 1 Q. And do you believe him to be a truthful 2 individual? 3 A. Yes. 4 Q. And how long has he known your mother? 5 A. For 15 years. 6 Q Do you know of anything he has told 7 anybody else about what it is your mother used to do 8 fora living? 9 A. No. 10 Q Is the first time that you've heard any 11 reference to your mother being a prostitute in this 12 case? 13 A. No. 14 Q. When else have you heard that? 15 A. I have never heard that my mother was a 16 prostitute. 17 Q So, what I am saying is, is the first time 18 that you have heard that issue even come up in this 19 case? 20 A. This is the first time I am hearing this, yes. 21 Q. Did you discuss with your mother the 22 activities you were engaging in with Mr. Epstein at 23 the time that you were engaging in them? 24 A. I kept everything a secret until years later 25 when after I had my son and then 1 told her what went 13 (Pages 547 to 550) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542lef-d299-4e4f-9ba6-85aad27P1405 EFTA01076171 Page 551 1 on. 2 . Earlier ou said at 15 you worked for 3 4 A. Yes, 5 Q. And my notes are unclear. I believe I 6 asked you, did you tell them how old you were. Do 7 you remember me asking you that question? 8 A. (Witness nods head). 9 Q. And what did you respond? 10 A. I told them 1was 19. 11 Q. Okay. Did you provide them with any kind 12 of proof/ 13 A. No. 14 Q. And why did you lie to them and tell them 15 you were 19 if you were really 15? 16 A. Becausei wouldn't be able to work there. 17 Q. Did you tell other people that you were 18 older than you really were? 19 A. Yes. 20 Q. Who else did you tell you were older than 21 you really were? 22 A. Probably everybody I came across. 23 Q. So, that would be many people? 24 A. Yes. 25 Q. All of the various adult entertainment 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 553 at WITNESS: I worked at Once I turned 18, I told everybody my age- BY MR. LUTHER: Q. Well, you worked at a place called when you? A. I told them I was 19 as well. Q. When you were how old, 14? A. Yes. Q. Okay. And then what, what was the next place yobiliavent to do topless dancing? We'll do separate from to less dancing. A. I don't know. I worked at when 1 was 14. I worked at when I was 15, and I worked for Jeffrey throughout all those years. Q. X2v Mfr . s_ t a lot of other besides and MN= didn't you? A. Not when 115. Q. Well, I want to start there and keep on going. A. We already know the places I've worked at. We've been through this. We've went through this for the last deposition. Q. That's why — Page 552 1 places you worked at. The places, the topless bars 2 you worked at, did you tell all of them you were 3 older than you really were? 4 *iad of time when I worked at 5 I told everyone I was 19. Jeffrey knew 6 how old I was. And Jeffrey new how old every girl I 7 brought there was, and he wanted young girls all the 8 time. 9 Q. Does that have anything to do with the 10 question that I asked? 11 MR. LUTT1EFt: 1 move to strike. 12 THE WITNESS: The question you asked has 13 nothing do with Jeffrey. 14 MR. LIJTTIER: Let's, let's go back. If 15 you will read the question that I asked. If 16 you will listen to this question, that's the 17 one I would like you to answer. 18 THE WITNESS: I know you guys love to get 19 paid but — 20 (Ile requested portion of the record was 21 read by the reporter.) 22 THE WITNESS: At what period of time? 23 MR. LUTTIER: At any time. From the time 24 you first worked at one to the last time you 25 worked. Page 554 1 A. And we've already been through this for this 2 deposition. 3 Q. — I am giving you the chance to 4 sturunarize, so let's just go down and — 5 A. You already know the places I worked. 6 Q. I am asking you as to each one, how old 7 you told them you were. 8 A. When I was underage, I told theml was 19 9 years old. 10 Q. Every place that you worked? 11 A. Yes. Except Jeffrey's, Jeffrey knew that 12 was 13. I'm sick of this. 13 Q. So, at you told than 19. Is that 14 just the number you picked? 15 A. On advice of counsel I am invoking my Fifth 16 Amendment rights under the United States constitution. 17 MR. EDWARDS: Do you want to take a break 18 or are you all right? 19 MR LIMIER: Yeah, do you want to take a 20 break? 21 THE WITNESS: No. I want to get this done 22 and over with. I am sick of it. Jeffrey is — 23 it's disgusting. 24 BY MR. LUTHER: 25 Q. Flirts xou told them tou were 19? 14 (Pages 551 to 554) PROSE COURT REPORTING AGENCY, INC. 1 Electronically signed by Cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by Cynthia hopkins b5542lef-d299-4e41-9ba6aSaad27f4405 EFTA01076172 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 555 A I was — on advice of counsel, l am invoking 2 my Fifth Amendment rights under the United States 3 Constittigis. 4 Q. whatever, = whatever it 5 was, you told them you were 19? A. Q. whatever. A. I was of age. Okay. How about when you were at ■ were you of age then? A. Q. Showgirls? A. Yes, I was of a . Q. And how about were you of age then? A. On advice of counsel I invoke my Fifth Amendment rights under the United States Constitution. Q. Did you wort( ata A. On advice of council I'm invoking my Fifth Amendment rights under the United States Constitution. And what work did you do at A. I'm over this shit. MR. EDWARDS: Let's take a break. THE WTTNESS: No. On advice of counsel I 1 a — 2 A. 3 Q. 4 A. 5 Q. 6 A. Yes. — store? Yes. And that was upsetting to you? Yes. Page 557 7 Q. Why was it upsetting to you? 8 A. I was trying to say hello tomitle sister 9 who was three at the time. And was mad at my 10 father and she didn't want me talking to my little 11 sister. So, she doesn't know the American rights 12 because she's from Mexico and she totally mazed me when 13 I was trying to hug my little sister. 14 (Mr. Goldberger entered the deposition 15 room.) 16 THE WITNESS: I just hope Jeffrey gets 17 what he deserves. 18 BY MR. LUTT1ER: 19 Q. And what's that, Ma'am? 20 A. Punishment for putting us girls through all 21 this. 22 Q. That is those things that you are talking 23 about the times that you elected to go back to his 24 house and get paid to give him massages? 25 A. He demanded us to over the phone, sir. Page 556 1 am invoking my Fifth Amendment rights under the 2 United States Constitution. 3 BY MR. LUTTIER: 4 Q. Are you fearful that you're in to be 5 prosecuted for something about ? 6 A. No. 7 Q. So, well then, what are you asserting the 8 Fifth Amendment for? 9 A. Because I want to. 10 Q. Because what? 11 A. Because I want to. 12 MR. EDWARDS: Listen, don't engage with 13 him. Just read. 14 BY MR. LUTTIER: 15 Q. Do you know 16 (phonetic). 17 A. I know a 18 Q. Okay. And who is that? 19 A. My step-mother. 20 Q. Married to your father, 21 A. Yes, sir. 22 Q. And have you had a confrontation with her? 23 A. What kind of confrontation is this now? 24 Q. Did you ever have a confrontation with 25 her, a physical confrontation in the parking lot of 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 558 Q. But nobody made you do it, right? A. No. But Jeffrey demanded us for us to do it. And as young girls we were scared of Jeffrey. And you know what, he will get what he deserves IS t's see. You lived out by A. Yes, I did. Q. He lived in Palm Beach? A. Yes. Q. How many miles was it, would you say between those two houses? A. I don't know, five, six. Q. And you didn't, you didn't have a car because you weren't driving, right? A. No. He sent taxies to my house to come get me. Q. So, then you could have said I am not getting in any of the taxies you wanted me to. You could have said I'm not going, just like a bunch of your friends did, right? They said after, boom, I don't want to go anymore, tight? A. I could have said no. Q. As a matter of fact you had friends that you took, you found them, Jeffrey Epstein didn't find them, ru found them. J 15 (Pages 555 to 558) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5S421of-d299-4e4t..9ba6-85aad27f4405 EFTA01076173 Page 559 A. Yeah. Because he wanted me to find them. He 2 said you better find me a girl the next day, or I am not 3 going to call you anymore. 4 Q. And you took them to Jeffrey Epstein's and 5 you told them don't worry, this is what's going to 6 happen, ifs easy money, right? 7 A. Yeah, because I was tried of Jeffrey. 8 Q. And some of those girls went one time and 9 said they didn't want to go back, right? 10 A. C,omxt. Because they were afraid of Jeffrey. 11 Q. And you could have done the same thing, 12 couldn't you? 13 A. Correct. 14 Q. But you wanted the money? 15 A. I was a poor little girl who couldn't even 16 afford a pair of shoes, yes. 17 Q. You wanted the money? 18 A. Yes. 19 Q. And not only did you want the money but 20 you wanted to make money taking other girls there? 21 A. Yes. 22 23 24 25 Page 561 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 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 560 Page 562 1 2 3 4 MR. EDWARDS: Objection, asked and 5 answered. 6 BY MR. LUTHER: 7 Q. If there isn't any, fine. If there is I 8 want to get them that's all. Do you know of any 9 others? 10 A. No. 11 12 13 14 15 16 17 18 19 20. 21 22 23 24 25 16 (Pages 559 to 562) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b65421.14299-4•41a.6416=127f4405 EFTA01076174 Page 563 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 564 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 (Pages 563 to 566) PROSE COURT REPORTING AGENCY, INC. MR. LUTTIER: Move to strike. Not Page 565 1 responsive. Please, listen to the question. 2 The court reporter is going to read it back and 3 just answer my question. 4 (The requested portion of the record was 5 read by the reporter.) 6 THE WITNESS: No. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 566 Electronically signed by cynthla booklets Electronically signed by cynthia hopkins Electronically signed by cynthia booklets b5542let-d299-4e41-9ba6-85aad27f4406 EFTA01076175 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Pase 567 Page 568 Page 569 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 5'10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Q. And you last saw Mr. Epstein in 2005? 17 A. I went to his house pregnant when I was -- 18 2006, or no, I was pregnant. 1 had my son 2005, and 19 then 1 went to his house after 1 was pregnant 20 Q. I believe you told us in the last 21 deposition the latest you could have seen him was 22 September of '05. Are you changing that or is that 23 comet? 24 A. Sir, you know what, when people go through a 25 lot of drama in their life, choose not to really 18 (Pages 567 to 570 PROSE COURT REPORTING AGENCY, INC. Electronically signed by synth's hopkins Electronically signed by synth's hopkins Electronically signed by synth's hopkins b5542tef-d299-4e41-9ba6.85aad2714406 EFTA01076176 Page 571 1 recall a lot of stuff but I blow I saw him after I had 2 my son. 3 Q. Well, you had your so. 4 right? 5 A. Yes. So, it could have been July, August, 6 September, October, November, December. Then maybe it 7 could have went on to '0,'06. 8 Q. Well, do you know? 9 A. I'm not positive but I know that I went there 10 after I was pregnant. 11 Q. That's all you -- 12 A. That's all l can tell you. 13 Q. All right. 14 A. And he didn't want me because he doesn't like 15 women that had a kid regardless of what their age is. 16 So, I had to bring another girl. 17 Q. And that was upsetting to you? 18 A. No. 19 Q. You thought you were his favorite girl at 20 one point? 21. A. No. 22 Q. That's what you told us in the last depo, 23 didn't you? 24 A. I told I was his favorite girl? 25 Q. That you thought you were special and you 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 573 Page 572 1 were his favorite girl? 2 A. He made me feel special. He made me feel like 3 I was his favorite girl. 4 Q. And it upset you when you found out there 5 were other people going? 6 A. Did it upset me? 7 Q. Yeah. 8 A. No. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 574 1 2 3 4 you e two 5 right? 6 A. Okay. Great. Well, that goes to my son. 7 MR. EDWARDS: Object to form, 8 argumentative. 9 BY MR. LUTTIER: 10 Q. You would go and sell your wares, your 11 shoes. 12 A. So, what all the money I owe, or all the money 13 that l eam, goes to 'iv son. 14 Q. And you didn't even pay -- 15 A. Not to suits. 16 Q. You didn't even -- 17 A. Not to 'ceipts. 18 Q. You didn't even — 19 A. Not to paper. 20 Q. And you didn't even pay taxes on money you 21 earned, did you? 22 MR. EDWARDS: Object to the form. 23 THE WITNESS: I did pay taxes. 24 BY MR. LUTTIER: 25 Q. Did you ?ay taxes in '08? 19 (Pages 571 to 574) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542604299-4e4f4ba6-85aad2714405 EFTA01076177 7. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 Page 575 A. Yes, I did. Q. And did you pay on the amount of income you actually earned? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: It's none of your damn 6 business. BY MR. LUTTIER: Q. Do you know that filing a false tax return is a crime? A. Yeah, and it wasn't false. Kiss my ass. Q. So your, your tax return is in '08 is correct; is that right? Is that what you are telling us? A. No. Q. Is it false? MR. EDWARDS: Just read. Q. Well, ma'am — A. Can you tell I am suffering? I hate Jeffrey Epstein, and I hope he burns in hell. On advice of counsel, I am invoking my Page 576 1 Fifth Amendment rights under the United States 2 Constitution. 3 Q. To anything in particular or just making 4 that statement? S A. To the question you asked me about my taxes. 6 Q. That question has already been answered. 7 A. Oh, 0 . Next. a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 577 Pa.e 578 20 (Pages 575 to 578) PROSE COURT REPORTING AGENCY, INC.' Electronically signed by cynthia hopkIns Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins bS542fetd299-4e41-9ba6455aad2714405 EFTA01076178 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 581 2 3 4 5 6 7 8 Q. Who did 9 A. aezd o 10 Q. 11 A. I don't know his last name. 12 Q. Where did you meet him? 13 A. I don't know. 14 15 16 17 18 19 s some y you to . 20 A. No. 21 Q. Is he someone with whom you had some kind 22 of relationship? 23 A. Yeah. 24 Q. What kind of relationship did you have 25 with him? Pa •e 580 Page 582 1 A. Our sons would play together. 2 Q. Do they still play together? 3 A. No. 4 Q. Was he a client of yours? 5 A. No. 6 7 B 9 10 el, o 'ow, a invasion — w 11 do you mean when you say you've suffered invasion of 12 your privacy? 13 A. Are you serious? Well, here is one. Here is 14 two. 15 Q. So, you're talking about things that you 16 did -- 17 A. Investigators. 18 Q. — in the public? 19 A. All my damn, all these years that I've, after 20 Jeffrey they wanted -- invasion of my privacy, are you 21 kidding me? I can't go anywhere without anyone knowing 22 where I'm going. The FBI, the investigators following 23 me everywhere. I can't take my son out with anybody 24 knowing me. 25 Invasion of my privacy?. Everybody knows 21 (Pages 579 to 582). PROSE COURT REPORTING AGENCY, INC. ' Electronically signed by cynthia hopkins Electronically signed by cynthia hooking ) Electronically signed by cynthia hopkins b664,210-d299-4•04ba6416arad27M405 EFTA01076179 Page 583 1 that Jeffrey Epstein molested me. So, if my son 2 wants to go out and play with somebody, oh, no, 3 she's the little girl that was in prostitution for 4 Jeffrey Epstein, so we don't want her playing with 5 our son. 6 Q. So, or do they say she's the lady that 7 ems her own escort service, we don't want her 8 playing with our son? 9 A. No one knows about that shit except you guys. 10 Q. How about when you were working for 11 another escort service? 12 A. How about what? 13 Q. You don't think anybody knew about that? 14 A. No. 15 Q. How about when you were — 16 A. lam very discrete what I do. l don't put my . 17 name in the newspaper like Jeffrey Epstein saying that I 18 am a prostitute or a slave for Jeffrey Epstein. 19 Q. How about when you were top, dancing 20 topless at bars? Do you think maybe people said — 21 A. I did that out of, like not locally. 22 Q. So, maybe, well, 1 mean — 23 A. Well - 24 Q. You wouldn't exa tl call 25 A. . I Page 585 1 all out. Everybody knows. Okay. You can sit there and 2 act like you, you can act like an attorney and -- 3 Q. Has the words — 4 A. — say where has your name been? My name is 5 out there everywhere. Okay. l am the prostitute of 6 Jeffrey Epstein. I have brought young underaged girls 7 there. I am so horrible. 8 My son can't play with certain kids 9 because ofJeffrey Epstein now. He has ruined my 10 fucking life. He has brought me into this industry 11 that this is all I know. And now I can't even, I 12 can't even explain to you the hard things that I've 13 been through my life because of Jeffrey Epstein, 14 because he has taught me and many other girls how to 15 pull money from older men. 16 Q. Let's just be honest for the ladies and 17 gentleman of the jury: Ho didn't force you to do 18 anything? 19 A. But he taught me from a young age — 20 Q. Wait a minute. Let me finish. 21 A. — when I was 13 years old. 22 Q. You -- 23 A. He taught me how to get money real quick. 24 Q. Do you — 25 A. — from an old man. Don't sit here and tell Page 584 live in West Palm. 2 Q. So, you meant within the immediate 3 geographic area. And maybe they said, well, this is the lady that goes and sells her wares at all these 5 topless bars; we don't want our children playing 6 with her. 7 A. No, not all. They see Jeffrey Epstein and my 8 name all over the place and they say, you know what, I 9 don't even want anything to with this girl because she 10 was a prostitute for Jeffrey Epstein. 11 Can I talk to him without you in his ear? 12 Amidone talking? 13 Q. Could you just tell me one place where 14 your name has appeared anywhere as being someone who 15 saw Jeffrey Epstein? 16 A. It's everywhere. 17 Q. Well, where? Just tell me one place. 18 A. Where have you been? 19 Q. Just tell me one place. Can you cite 20 me — 21 A. Ifs in the newspaper. 22 Q. What newspaper ever ran your name? 23 A. The Initials of my name? 24 Q. No, your name. 25 A. It doesn't matter. The It's Page 586 1 me that I was not forced or anything like that. 2 Q. That's exactly what I'm suggesting. ma'am. 3 Do you believe that you owe, that you have a certain 4 le''el of responsibility for your own conduct? 5 A. Now I k 6 Q. You're.. years old. 7 A. When I was 13 years old, 1 didn't, I wasn't, 8 no, I did not have that demeanor. 9 Q. So, a what you thought, because you 10 want to clean up your imagine for your son, right? 11 You want him to look up — 12 A. Yes, I do. 13 Q. So, as part of tha ess what you 14 thought you would do aM is you would agree to 15 hire out to strange men whom you don't know for 16 between 3300 and $500 for what you say is to go sit 17 in rooms naked with them, and that's how you thought 18 you would prove? 19 A. Because that's all I know. I'm Sony. 20 Q. And Jeffrey Epstein didn't make you do 21 that, did he? You decided to do that, didn't you? 22 A. You know what 23 Q. A whole new business that you decided to 24 do on your own; is that right? 25 MR. EDWARDS: Object to form. 22 (Pages 583 to 586) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421of-d299-4041-91m6.85aad2714405 EFTA01076180 Page 587 1 THE WITNESS: — before! -- 2 MR. EDWARDS: Argumentative, asked and 3 answered. 4 BY MR. LUTTIER: 5 Q. Did Jeffrey Epstein ever give you the 6 business advice on a business plan to go out — 7 A. Yes, he did. He gave me business advice. 8 Q. Wait. You started this in January? 9 A. You know what he told me this: He said, you 10 inc girls, this is business. Let's talk business, 11 I . You get me girls, twill pay you. Is that not 12 called business? 13 Q. So, and you quit doing that when? 14 A. You get me girls, and I brought him.two girls 15 a day, one girl a day, $200 each. That's not business? 16 Q. And when you — 17 A. He taught me business and now I run business. 18 Q. And so — 19 A. Just like you run business. 20 Q. And when did that, when did you start — 21 A. Just like you learned how to do this, I 22 learned how to do this. 23 Q. What — so, you kamed to be a 24 prostitute? 25 A. Yes, I did. Page 588 1 Q. And you enjoy it? 2 A. No, !don't enjoy it, and I can't wait to get 3 the hell out of it. 4 Q. And that's why in January of '010 you 5 decided what you would do is start getting men to pay you S300 to $500 an hour to sit around naked 7 with them, is that right? 8 MR. EDWARDS: Form. 9 THE WITNESS: Yes, that's right. 10 BY MR. LUTTIER: 11 Q. And the last time you took a girl to 12 Jeffrey Epstein was when? 13 THE WITNESS: Did we already ask this 14 question? 15 MR. LUTTIER: When? No, the last time — 16 MR. EDWARDS: Object to the form. 17 MR. LUTTIER: — you said you went was — 18 MR. CRTITON: You're out of time. 19 MR. LUTT1ER: Okay. 20 THE V1DEOGRAPHER: Going off the record at 21 3:14 p.m. This is the end of Tape 2. 22 (A brief recess was held and 23 Mr. Goldberger did not re-enter the room.) 24 THE VIDEOGRAPHER: We're back on the 25 record at 3:24 p.m. This is the start of 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 589 Tape 3. MR. EDWARDS: Before we get started I just want to put something on the record that there was a hearing, I believe it was November 3rd, 2009, and the judge suggested that the defense only have one attorney there. And his recommendation was such because of the breakdown — MR. LUTTIER: Well, let's — MR. EDWARDS: — in the first deposition. You can, you can make a record after. That is fine. Was because of the breakdown in the first deposition, and he thought that that type of intimidation by more than one attorney would lead to an additional meltdown. We have been fine thus far today despite there at a minimum always being two attorneys and in the last 15 to 20 minutes not only was Mark Luttier here and Bob Critton as it has been all day, but Jack Goldberger was also in the room. And once it was lined up three attorneys over there, either passing notes, talking in each other's ear, and otherwise assisting in the deposition or at least that was the feeling Page 590 1 from the witness, we began to have another 2 meltdown. 3 So, hopefully we can proceed with less 4 attorneys and we can get through this process. s But I just wanted to put on the record exactly 6 who was in the room when everything started to 7 break down just now. 8 MIL LUTIIER: Well — 9 MR. EDWARDS: If you have something to 10 say, that's fine. 11 MR. LUTHER: That just is not factually 12 correct. Mr., first of all the judge ordered 13 that Mr. Critton and I could be present 14 throughout this deposition. Mr. Critton and I 15 have been present throughout this deposition, 16 and he and I have communicated throughout the 17 deposition. 18 Mr. Goldberger walked in here. I didn't 19 put a stopwatch on how long he was there. He 20 is not even here now. He was here for maybe 21 ten minutes. I had no communication at all 22 with him. He carne. He sat here. He got up 23 and he walked out. 24 This breakdown that you're talking about 25 occurred Ions before Mr. Goldberger ever of 23 (Pages 587 to 590) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fet-d299-4041-9ba6-55aad2714405 EFTA01076181 Page 591 here. So, I dispute — 2 THE WITNESS: No. 3 MR. LUTHER: — the facts, but it's sort 4 of a moot issue now anyway, so — 5 MR. EDWARDS: But if we're going to get 6 into that, then every time he comes into the 7 . room do we need to now put it on the record 8 that he is in the room? 9 MR. LUTHER: I have absolutely no 10 problem — 11 MR. EDWARDS: And each time — 12 MR. LUTTIER: Anytime he comes in, we'll 13 stop him and well let him know he can't come 14 in here. Quite frankly, if you would have said 15 something to me about it, I was examining the 16 witness, I would have stopped right then and 17 said, Jack, get out of the room. 18 MR. EDWARDS: And I know in all fairness 19 to what you just said I am not saying that to 20 you was not factually accurst; what you just 21 said, but you weren't able to see what was 22 behind you, the passing of the cellphone and 23 other things that the witnesses notices. 24 I am just telling you that this impacts 25 the deposition. So, I just want to make it Page 592 1 clear so that you would know exactly what's 2 happening and maybe we can get through this. 3 You know, it's all of our goals to get through 4 this day. So, I, I think the witnesses is 5 ready if you're ready, Mr. Luttier. 6 MR. LUTTIER: I'm ready. 7 MR. EDWARDS: Okay. 8 MR. CRITTON: What time did we start 9 because we haven't we've been on the record, 10 but we haven't asked a single question. 11 THE VIDEOGRAPHER: les 3:28 right now. 12 Three and a half minutes. 13 MR. CRITTON: Thank you. 14 BY MR. LUTTffiR: 15 Q. I am now referring to your, your 16 interrogatory answers. These are answers that you 17 gave to written questions that were sent to you in 18 this case. And they are entitled Defendant's 19 unverified better answers to first interrogatories. 20 I believe they may have been marked as Exhibit 1 to 21 the first deposition, but there is only one set of 22 them. 23 • MR. LUTHER: And Brad, they are, the date 24 of service on, I don't know, wait. Date of 25 service is August 4th, 2009. Page 593 1 MR EDWARDS: mats the — 2 MR. LUTHER: Defendants unverified 3 better answers to first interrogatories to 4 Plaintiff. Later I'm going to come to the S Plaintiffs supplemental better answers to 6 Defendant's Interrogatory No. 19. 7 MR. EDWARDS: Okay. But you said the date 8 of service meaning you saved on us? 9 MR LUTHER: No, no. Your answers, 10 better answers. 11 MR. EDWARDS: Got it. I am looking as the 12 same document you are. 13 BY MR. LUTHER: 14 Q. All right. Ma'am, in response to some 15 interrogatories you stated that from the end of 2007 16 to November of 2008 you worked at 17 earning S1100 a week. So that would have been a 18 period of approximately one year; is that right? 19 MR. EDWARDS: Read. 20 THE WITNESS: On advice of counsel I am 21 invoking my Fifth Amendment rights again under 22 the United States Constitution. 23 BY MR. LUTHER: 25 you worked at what did you do for Q. From, f of time that 24 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 594 your money? A. On advice of counsel I'm invoking my Fifth Amendment rights under the United States Constitution. Q. In continuing in answering that particular imar.saici that in 2008 worked at . Where is located? A. On advice of counsel I'm invoking my Fifth Amendment rights under the United States Constitution. Q. What did you do at A. On advice of counsel I'm invoking my Fifth Amendment rights under the United States Constitution. Q. Did you have any communication with Jeffrey Epstein after the phone call you made to him following the FBI's interview of you? A. I talked to ing Oh, my God. I don't know what I am going through. I'm like shaking. Q. I am talking about now a conversation with Mr. Epstein. MR. EDWARDS: The question was, did you talk to him after you called him — MR. LUTHER: Right MR. EDWARDS: — after the FBI statement? MR. LUTHER: Right. 24 (Pages 591 to 594) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns Electronically signed by cynthia hopkIns Electronically signed by cynthia hopkIns b55421ef-d299-4e4f-9ba6-85aad27t4405 EFTA01076182 9 10 13. 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 595 BY MR. LUTTIER: 2 Q. And the date of your FBI statement for 3 your information was April 241h, 2007. Did you have 4 any conversation with Jeffrey Epstein after that . 5 date? 6 A. After I, after I had called my attorney? 7 Q. After April 24th, '07, which is the date 8 that you gave a st FBI. A. I talked toatlisic) or whatever her name is. Q. Did you have any conversation with Jeffrey Epstein? A. No. I don't think so, no. Q. Other than the witnesses you have listed in answer to Interrogatory No. 5, do you know of any other witnesses or do you intend to call any witnesses in the trial of this matter? A. What? MR. EDWARDS: Objection. Attorney-client privilege. I don't want her answering questions as to whether, as to information that she and I have spoken about in terms of what witnesses will be called at trial or our trial strategy. Page 597 1 with Mr. =bout being a witness? That is what 2 would he be offering as testimony in the case? 3 A. What would he be offering? 4 Q. Yeah. Why did you ask him about being a 5 witness? 6 A. I didn't ask him about being a witness. I 7 .told him about what happened to me when 1 was 13 years 8 old. 9 Q. Okay. 10 A. I'm not asking anybody to be a witness as of 11 right now. 12 Q. What is -- • 13 A. I'm my own witness. 14 MR. EDWARDS: Listen to his question. 15 THE WITNESS: I am trying. I can't think 16 right now. 17 MR. EDWARDS: He wasn't asking you about 18 being a witness. 19 BY MIL WrrIER: 20 Q. Where does Mr. =live now? 21 A. West Palm Beach. • 22 Q. est Palm? 23 A. 24 Q. When did you last have communication with 25 him? Page 596 1 BY MR. LUTHER: 2 Q. Have you spoken to anyone with respect to 3 their willingness or your intention to call them as 4 a witness to the trial of this matter? 5 MR.. EDWARDS: Not who I have spoken to. 6 MR. LUTHER: Yeah, you. 7 THE WITNESS: What? 8 BY MR. LUTHER: 9 Q. Have you spoken to anybody about being a 10 witness • • is matter? 11 A. 12 Q. Anyone else? 13 A. Not that I know of. 14 Q. And when did you speak with Mr. 15 about being a witness? 16 A. May `09. 17 Q. And what is it you told him or asked him 18 about being a witness? 19 A. I told him that Jeffrey Epstein molested me 20 since I was 13 years old. 21 Q. Okay. And he wasn't around at the time 22 that you alleged Mr. Epstein molested you, correct? 23 A. He wasn't around at the time when Jeffrey 24 Epstein was molesting me. 25 . Okay. S aS= st r w hat did you confer Page 598 1 A. January 3rd, 2010. 2 Q. And for what purpose did you have 3 communication with him on that date? 4 A. I had to give him some of his clothes. 5 Q. When was the last were in 6 tion with Mr. that would be 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING A. lie's my son's father. So, I talked to him two weeks ago. Q. And where was he when you talked to him? A. Fort Myers. Q. And do you know how he's employed now? A. .No. He says he's not employed. Q. Have you discussed with him in the last year anything about this lawsuit? A. Yes. . Q. What have you discussed with him? A. I told him I'm going through a lawsuit. Q. And what did he say? A. He said okay. Q. Have you asked him to be a witness? A. No. Q. Have you ' nication with any . other members of Mr, family in the last two years? 25 (Pages 595 to 598) AGENCY, INC'. Electronically signed by cynthia hopkIns Electronically signed by Cynthia hopkIns Electronically signed by Cynthia hapkins b55421ef-d2994e4t-9ba6-85aac12714405 EFTA01076183 Page 599 1 A. Yes. 2 Q. 3 AA. illi nit c). 4 Q. Who is 5 A. His sister. 6 Q. And where does she live? 7 A. Wellington. 8 Q And for what purpose have you been in 9 touch with her? 10 A. She's my son's aunt 11 Q. And with what degree of frequency are you 12 in communication with her? 13 A. She asked me to attend her wedding via e-mail 14 this March of '010. 15 Q. Have you discussed with her anything about 16 Mr. Epstein? 17 A. No. 18 Q. Does she to the best of your knowledge H know anything about it? 20 A. Yes. 21 Q. Did you say no? 22 A. Yes. 23 Q. Does she know anything about? 24 A. Yes. 25 Q. What does she know about it? Page 601 1 Q. Is that the last time she's seen your son? 2 A. Approximately, yeah. 3 t Q. ' ur son when you were 4 down a m 8:00 at night until 5 in the 6 A. 7 Q. I 8 identified earlier? 9 A. Yeah. 10 Q. And where was she watching him? 11 A. At my house. 12 Q. So, does she come spend the night at your 13 house? 14 A. Yes. 15 d there, was there ever a time that you 16 and 1M lived together? 17 A. Yes. 18 Q. When was that? 19 A. When we were 13, 14. 20 Q. Thirteen and 14. Was any adult living 21 with you? 22 A. My father. 23 Q. Since you were 13 or 14 has a ever 24 lived with you? 25 ANo. 1 2 3 7 8 9 9 10 10 11 11. 12 12 13 13. 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23. 25 2: 25 SC, 24 24 Page 600 1 A. That Jeffrey Epstein's a child molester. 2 Q. And how did she get that information? 3 A. From the news, from friends, from the 4 neighbor/mod -- 5 Q. Did — 6 A. From her brother. 7 Q. — has she asked you any questions about 8 your relationship or interaction with Mr. Epstein? A. She said I am sorry that you're going through the trauma that you're going through. other member of Mr. family? Q. Have you tmitation with any A His mother. Q. illy t's her name? A. Q. And where is she located? A. Fort Myers. Q. And when did you last have communication with her? A. I don't know. A year ago. Q. And for what purpose did you have communication with her at that time? A. Dropping my son off with her. ho you rather? 4 Page 602 Q. Did you tell why you needed to have haisall night when you were down at A. Hold her I need to work. Q. Do you tell her what you do for work? A. Yes. Q. What did you tell her? A. I sell lingerie and shoes and purses and Mary Kay. Q. Do you have any personal knowledge of the matters about which the witnesses listed in your answers to interrogatories that these witnesses have, have information about? MR. EDWARDS: Objection, attorney-client privilege. And we do this all the time. BY MR. LUITIER: Q. This is just a list as prepared by your lawyer. You don't know what any one of these witnesses would say? MR. EDWARDS: And if she does, it's going to be information that I have talked to her about which you know is protected by attorney-client privilege and so do L If you're asking her independent of her information I have told her, fine. 4. , ...••••••••••••4 26 (Pages 599 to 602 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421ef-d299-4e4f-9ba6-85aad2714405 EFTA01076184 Page 603 1 MR. LUTTIER: That's exactly what I am 2 asking her. 3 MR. EDWARDS: Okay. Let's ask it that way 4 because it doesn't sound like that. 5 BY MR. LUTTIER: 6 Q. Do you know of any information that these 7 witnesses have based on your communications with 8 them? 9 A. Excuse me? 10 Q. Do you know any information that any of 11 these witnesses have about this case based on your 12 personal contact with them? 13 A. What witnesses? 14 Q. That are listed in the Answers to 15 Interrogatory 5. 16 MR. EDWARDS: Just answer his question, 17 yes or no. 18 THE WITNESS: No. I don't know these 19 people. 20 BY MR. LUTTIER: 21 Q. On any visit that you went to see Jeffrey 22 Epstein, did he ever ask you to do anything that you 23 said you did not want to do? 24 A. Yes. 25 Q. What did he ask you to do that you said Page 604 1 you didn't want to do? 2 k At one occasion he wanted to stick his lingers 3 like all the way inside of me and 1 said no? 4 Q. And what did he then do when you said no. 5 A. He said okay. So then he just penetrated my 6 vagina with his tinge's. 7 Q. What did he, did he —when you said you 8 didn't want him to do that, did he respect your 9 wishes and not do it? 10 A. No. Actually he, he pushed it. He tried to 11 do it and he said, okay, no, it's going to be okay. 12 It's going to be okay. And I backed off and I said no. 13 Q. And then he stopped? 14 A. Then he decided to respect my wishes. 15 Q. Okay. Any other — and this is on one 16 occasion? 17 A. Many occasions. 16 Q. Well, on — so on many occasions he would 19 say he wanted to penetrate your vagna. You would 20 say you didn't want — well, actually what you said 21 was he wanted to penetrate your vagina deeply I 22 think And, and you said no and he respected your 23 wishes and didn't do it? 24 A. Correct. 2 5 Q. Okay. Was there ever anything that at Page 605 1 all that you said I don't want to do this and Jeff 2 said you had to do it anyway? 3 A. Yeah. I told him that at times I did not want 4 to bring girls, and he says, yes, I want you to do it 5 anyway; you need to do it anyway. 6 Q. And did you tell all the girls that you 7 brought that Jeffrey would respect their wishes, and 8 if they were uncomfortable doing anything, that they 9 should just tell him that, and he wouldn't ask them 10 to do anything that they weren't comfortable doing? 11 A. Yes, because I was scared. 12 Q. And that's, in fact, how he treated you, 13 fir? 14 A. Yes. 15 Q. You previously earned a degree as an 16 esthetician; is that right? 17 A Yes. 18 Q. And you now earned a degree since going to 19 Mr. Epstein in massage therapy, correct? 20 A. Yes. 21 Q. And you emillairnom the same 22 school located on 23 A. Yes. 24 Q. And you could pursue a profession as an 25 esthetician, a massage therapist if you so chose, 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 PROSE COURT REPORTING Page 606 could you not? A. No, not as a massage therapist. Q. Why not? A. Because I've told you once before I need to take the nationals. Q. But no one has prevented you from taking test, right? A. I have to wait to take the test. It only happens twice a year. Q. And has — did you pass the first opportunity you had? A. No. Q. Okay. So, when's, when's the test coming up? A. In a few months. Q. And are you going to take it? A. Yes. Q. And you could have been working as an esthetician ever since you went to Jeffrey Epstein's? A. And I did work as an esthetician. Q. No one has prevented you from doing that, correct? A. No. 9. You made the decision to drop out of 27 (Pages 603 to 606) AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by synth's hopkins Electronically signed by cynthia hopkins b5542fef-c1299-4e41-9ba6-85aad27f4405 EFTA01076185 Page 607 school before you ever met Jeffrey Epstein, did you 2 not? A. I'm pretty sure I was going to school when I Was seeing Jeffrey Epstein. 5 Q. But, but you made the decision to drop out 6 based on other facts and circumstances that had 7 nothing to do with seeing Jeff Epstein; isn't that a correct? 9 A. Excuse me? 10 Q. You decided to drop out of school for your 11 own reasons particularly 1 think you said because 12 you got pregnant, didn't you? 13 A. No. 14 Q. Well, why did you decide to drop out of 15 school? 16 A. I was trying to find girls to bring to 17 Jeffrey's house. 18 Q. Well, didn't you tell us the last 19 deposition that you dropped out when you got 20 pregnant? 21 A. I was going to school when I was pregnant. 22 Q. Yeah. And then you dropped out, right? 23 A. I dropped out when I was pregnant. 24 ass drop out of 25 and then go to 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 609 six. But then I did go back and I got my high school diploma, and like you said I have two degrees. Q. When did you get your, your GED? A. Yes. Q. When did you get that? A. What I turned 18. Al Q. So, you got a high school equivalency diploma at the same time you would have gotten a high school graduation certificate — A. Correct. Q. -- had you stayed in school? A. Correct. Q. And then you were free to pursue the same pursuits as anybody else that had graduated from high school whether that would be college or a trade school or whatever you want to? A. No, no. If I would have stayed in school, I could have got some type of scholarship. I could have had many opportunities in school to learn higher education than just the GED. Q. Well, when you got — A. And I could have — traveled and I could have went to a college, a bigger college, a state college. Page 608 1 A. Because ever since I met Jeffrey I— before 2 Jeffrey I made wonderful grades. And then ever since I 3 met Jeffrey my grades went down and I was failing, so I 4 had to go to a school to bring my grades a up. S 1i. But you opted to drop out of the 6 MIE before you graduated? 7 A. Yes. I was four months pregnant 8 Q. And that's why you dropped out? 9 A. Well, I needed to make money to buy a house, a 10 trailer so I could have my baby. 11 Q. Because you were pregnant? 12 A. Yes. 13 Q. Had you not been pregnant, you would have 14 continued in school, correct? 15 A. I can't answer that question. I don't know. 16 Q. Well, the point is the direct reason why 17 you dropped out was you were pregnant? 18 A. And I was making so much money off of Jeffrey 19 that I didn't think school was so necessary at that 20 time. 21 Q. Did you consult with your parents or any 22 counselors about that? 23 A. I didn't tell my parents about Jeffrey. 24 Q. How much were you making at that time? 2 5 A. 1 WaSJnakilik $200 pretty much a day or 400 or Page 610 1 Q. How do you know that? 2 A. les common sense. 3 Q. Well, you don't know what your grades 4 would have been, right? 5 A. No, I don't know what my grades would have 6 been. 7 Q. And at — A. Do you know what tomorrow is grimy, bring? 9 siAt the time that you went into the MI 10 you were qmillpally failing, weren't you? 11 A. Yeah, but they help girls, young girls 12 bring up their grades so you can go back into high 13 school and accomplish making more, bettering your grades 14 so you can get a scholarship. 15 Q. Well, in fact you got a scholarship for 16 your massage therapy, didn't you? 17 A. No. How could I? 18 Q. Did you tell us in the last deposition 19 that you got some kind of scholarship for going 20 there? 21 A. I didn't get a scholarship for going. No. 22 I've never got a scholarship. 23 Q. Did they lend you money to go to school 24 there? 25 A. For massage therapy but not for esthetics. 28 (Pages 607 to 610) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins ) Electronically signed by cyntNa hopkins ) b5542fef-d299-4e4f-9ba645aad2714405 EFTA01076186 Page 611 Page 613 1 Q. That's what I was talking about was 1 2 massage therapy. 2 3 A. That's not a scholarship. 3 4 Q. Okay. 4 5 A. That's a loan that I have to still payback. 5 6 Q. Did you ever travel anyplace with Jeffrey 6 7 Epstein? 7 8 A. Nope. 8 9 Q. Are you — you're a person that uses the 9 10 computer now, correct? 10 11 A. Yep. 11 12 Q. Did you ever communicate with Jeff Epstein 12 13 on the computer? 13 14 A. No not that I recall 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 124 24 25 25 29 (Pages 611 to 614) PROSE COURT REPORTING AGENCY, INC. ' Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b56421ef-d299-4e4f-9ba6.85aad2714405 EFTA01076187 2 3 4 5 6 7 a 9 10 11. 12 13 14 15 16 17 1.8 19 20 21 22 23 24 25 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 615 e 616 1 2 3 4 5 6 7 8 9 10 1 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 617 Page 618 30 (Pages 615 to 618) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fef-d299-4e4f-9ba6-85aad27f4406 EFTA01076188 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 620 1 A. Yes. 2 Q. Do you know of -(phonetic)? 2 A. Yeah. 4 Q. Who is that? 5 A. Ifs actually my sister's son or daughter's 6 father's cousin. 7 Q. Sister's daughter? Your sister has a 8 daughter? 9 A. Yes. 10 Q. So daughter's cousin's father? 11 A. y's father, his cousin. 12 ii?kay. When did you first meet 13 14 A. Probabl knew him since]. was 11. 15 16 17 18 19 20 21 22 23 24 25 Page 621 1 BY MR. LUTHER: 2 Q. Did you she ever approach you about that? 3 A. No. 4 Q. Did she ever tell the police she was concerned about that? A. No. MR. EDWARDS: Object to the form. 9 10 11 MR. EDWARDS: Form, predicate. 12 MR. CRITTON: What's the form? 13 THE WITNESS: She was probably concerned. 14 MR. EDWARDS: You're asking - 15 MR. LUTTIER: Was your mother - 16 MR. EDWARDS: You're asking to tell 17 you whether she knows how her mother was 18 feeling at some certain time. 19 Y MR. LUTHER: 20 21 22 23 MR. EDWARDS: Same objection. 24 THE WITNESS: She probably was concerned, 25 yet Page 622 1 LTIER: 2 3 4 5 6 7 8 Tr " . • i gcm, 9 predicate. 10 THE WITNESS: A mother's love. I don't 11 know. I can't speak for my mother. I am 12 sorry. 13 BY MR. LUTTIER: 14 Q. Were you doing something that gave her 15 that concern? 16 MR. EDWARDS: Object to the form, 17 speculation. 18 THE WITNESS: I don't know. 19 BY MR. LUTHER: 20 . Are a aware of the fact that your father 21 22 uly of 23 '04? 24 A. Ile filed for what? 25 What's called a 31 (Pages 619 to 622) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins Electronically signed by cynthia hopkins b55421ef-d299-4e41-9ba6-85aad2714405 EFTA01076189 2 3 6 5 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 623 A. I never went to any program or anything. Q Yeah, but do you know he filed a petition in the court claiming that you come home when you want to, you're in trouble with the police, and that Did you know he filed that in July of'04? A. No. Q. You didn't know that? A. (Witness shakes head.) Q. you, in fact, taking in July of'04? A. Yes. I apologized to my father. Q. So, he had a legitimate concern at that time? MR. EDWARDS: Form. THE WITNESS: Yes. BY MR. LUTTIER: And with what degree were you taking at that time? A. I was a confused little girl with Jeffrey Epstein and that always, leaving Jeffrey Epstein's house always lead me to do more drugs and more drugs. I was uncomfortable about my body. Page 624 Q. What were you — A. I didn't like the way Jeffrey made me feel. Q. What were you uncomfortable about your body about? A. I felt insulted. I felt used. Q. Did you tell him that? A. No. Q. Did you tell anybody that? A. Yeah. Q. Who did you tell? A. a Q. On the, on the way over to Jeffrey Epstein's when you were taking her there? A. Yeah. We would tell each other that we didn't like the way we felt. Q. Did tu file a complaint that your boyfriend was stalking you? A. Yes. Q. Was be, in fact, stalking you? A. He got -- he was on coke one day, and I was scared because he was trying to get in the house and I didn't want nothing to do with him. Q. Did that give you some concern? A. Excuse me? Q. Did that give you concern? 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 625 A. Concern? Q. Yeah. I mean were you afraid? A. Only for that one night that he was on coke. He was just trying to, like, get in my house and I didn't want him in there. Q. D# o ou know a lady by the name of * A. Ob, my. I know herii.r Q. How do you know Q. Who is A. A friaamine. Q. Where did ou meet ? A 'Through yfriend. Q. And wbos boyfriend? MR. EDW : you ve a question, Bob? MR. CRITTON: He was telling me to ask her what n's -- IvfirEDWARDS: Oh, sony -- MR. LUIT1ER: -- full name is. We'll get to that. MR. EDWARDS: Okay. THE WITNESS: I don't — oh, God, I don't remember his name but they were both no good. Page 626 1 They were like gang members. 2 BY MR. LLITTIER: 3 Q. That is 7 + 4 A. No, and her boyfriend. 5 Q. Okay. you don't remember the 6 boyfriends's name? How did you — what was your 7 relationship with B A. AssociatePPIII, in a while. 9 Q. When did you first meet her? 10 A. In — I don't know. Maybe when I was 14. 11 Q. Did she live in your neighborhood? 12 A. No. 13 Q. How did you meet her? 14 A. I'm not sure. 15 Q. Was she a friend? 16 A. She became an associate. 17 Q. Is there a difference between an associate 18 and a friend? 19 A. Yeah. A friend is someone who's always by 20 your side and who you can talk to daily, and an 23. associate is just someone you can, that you know. 22 Q. Did you socialize with her? 23 A. Yeah. 24 Q. What kinds of things did you do with her? 25 A. Not good things. 32 (Pages 623 to 626) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 10842444d299-Se4SabaSattaad2714406 EFTA01076190 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 627 Q. And this was during the time that you were seeing Mr. Epstein? A. Yeah. Q. What else did you and she do together? A. Nothing. Q. Did you-all live together at some point? A. I asked her to -- she asked me if she could room with me when I was living in my trailer and 1 gave her a chance. About a week later 1 found out that she was not the kind of friend for me at all and she was into no good things. And I have a son so I couldn't have her around. Q. What do you mean she was into no good things? A. She was into drugs and stealing and -- 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 629 A. Yeah. Q. And she threatened to kill you? A. Yeah, she threatened a lot of stuff. Q. And did you believe she had the capacity to do that? A. No. Q. What gang was she in? A. y(phonetic). Q. did you know her to be a violent person? A. Yeah. But she's like 80-pounds soaking wet so Tut not worried about her. She's just lost and God bless her soul. Q. Now, let's talk about Mr., is it =or a (phonetic)? Q. "And you have described earlier a confrontation that you had with him. And was his mother present for that confrontation? A. Yes. Q. And, and did it initially start out that Mr.thr was physically abusive towards his mo A. Yes. I had told him to leave and his mother came to pick up his daughter from my house. When she Page 628 1 Q. Did you and she have a physical 2 confrontation? 3 A. She brought --1 told her when she moved in 4 for that one week I told her do not bring anyone into 5 this house. She brought a man into my house. I opened 6 her bedroom door, found her giving him oral sex. I got 7 angry. I said, please leave. She was on drugs. 8 She got angrier and came into the bathroom 9 and hit me or tried to hit me on my head. So, I 10 pretty much held her down until the cops came 11 because 1 called the cops to get her out. 12 Q. Was it an upsetting event to you? 13 A. No. I just couldn't wait for her to get out. 14 Q. Was that a common thing for you to have 5 fistfights with other women? 16 A. No. I didn't throw a fist. No, it was not a 17 common thing. 18 Q. And did she threaten you on the way out? 19 A. Yes. 20 Q. And you said she was in a gang? 21 A. Yeah. 22 Q. And what did she tell you on the way out? 23 ' A. O6,1 don't remember. I'm going to regret it. 24 Q. Well, did she say, I am going to get you, 25 bitch? 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 630 arrived, he started pushing and shoving his mother into the car. I could tell that he was on drugs. So, I said this is uncalled, uncalled for. I called the cops and that was that. He ran. I guess you can say 1 have a good heart and I give the wrong people chances. Q. Well, that was one incident when, when the mother was present, right? A. Yes, and that night actually -- Q. There was a second incident, was there not? A. Yes. That night he — that's when he pushed me down a couple times and that's when I hit him and then he spit blood all over the house. And that's when immediately moved out of the house and moved to D, DCF got involved. So, 1, three days later, And the next thing I know the week that 1 move . wed at m house. 33 (Pages 627 to 630 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins IDS542lef-d299-4e4f-94a6-55aad27f4405 EFTA01076191 Page 631 213 4 5 6 7 8 9 .10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 34 (Pages 631 to 634) PROSE COURT REPORTING AGENCY, INC. 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 633 Page 634 1 A. Yes. 2 MR. LUITTER: Let's mark this as our next, 3 whatever number we're on. 4 THE COURT REPORTER: Five. 5 MR. LUTTIER: Five. 6 (Defendants Exhibit No. 5 was marked for 7 identification) 8 BY MR. LUTTIER: 9 Q. Let me show you what is now marked as 10 Exhibit 5 and ask ou if that's a co of the 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fel-d299-4e4f-9ba6-85aad27f4405 EFTA01076192 Page 635 2 3 4 5 6 7 8 9 10 11 12 13 1.4 15 16 17 18 19 20 21 22 23 24 25 Page 636 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 35 (Pages 635 to 638) PROSE COURT REPORTING AGENCY, INC. Page 637 1 2 3 4 5 6 7 8 9 10 MR. LUTT1ER: Let me mark that as 6, our 11 next. And ask you if you can identify this 12 document. 13 (Defendants Exhibit No. 6 was marked for 14 identification.) 15 THE WITNESS: I've had some crazy 16 boyfriends, but for three years everything's 17 been fine. 18 BY MR. LUTHER: 19 Q. Let a show ou what has been marked as 20 Exhibit 6. 21 22 A. tat a outa. 23 MR. EDWARDS: lie was just showing it to 24 you. 25 THE WITNESS: Yes, I saw it before. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 638 Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b6642/04112994,4f4balaudilt4406 EFTA01076193 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 639 MR. LUTTIER: I need to take a quick break. THE VIDEOGRAPHER: Going off the record at 4:19 p.m. (A brief recess was held.) THE VIDEOGRAPHER: We're back on the record at 4.30 p.m. BY MR. LUTTIER: Q. Do you actually, yourself, call Mr. Epstein's home asking him if you could come work, did you not? MR. EDWARDS: Object to the form, predicate, time-frame. Page 641 3. A. No. 2 Q. Do you know if any of them have consulted 3 with any lawyers about that other than your lawyers? 4 A. No. What they want to sue me along with S Jeffrey? 6 Q. Have you ever discussed yourself with them 7 their feelings about you having taken them to see 8 Mr. Epstein? 9 A. Yeah. 10 Q. ./that did they tell you? 11 A. is very sensitive towards it. She 12 didn't like it at all. She just was a poor little girl 13 that I guess was influenced by me to go to Jeffrey's 14 house. 15 Q. But I mean has she ever asked you why did 16 you do that knowing what you knew or anything like 17 that or said she holds you responsible? 18 A. In 'don't 'mow the exact words but 19 she's definitely came to me and said why would you even 20 do that, why would we go there? You know, it, it hurts 21 our self-esteem. 22 And in M.'s aspect she was extremely 23 scared to go the first time. And me being one of 24 her best friends at the time, she just finally wont 25 after I begged her many times when I couldn't fmd Page 640 1 BY MR. WITIER: Q. During this period of time that you were 3 going to see Mr. Epstein. Sometimes you called and 4 asked his people at his house whether, you know, you 5 could come work, did you not? 6 A. Yeah. Because he told me to call if I had a 7 girl. SO, I would call and ask is he available. 8 Q. Now, I want to askot couple questions 9 about your ttke friends, and again M. 10 A. Excuse me. 11 Q. You took to Mr. Epstein, did you 12 not? 13 A. Yes, I did. 14 Q. How many times did you take her? 15 A. I dolifiv. 16 Q. Has or III. or anyone else that 17 you took to Mr. Epstein discussed with you or anyone 18 else that you know of the potential for them suing 19 you? 20 A. Who suing me? 21 Q. My girl that you took to Mr. Epstein. 22 A. No. • 23 Q. Do you know if any of them talked to their 24 lawyers about suing you as a result of you taking 25 them to see Mr. Epstein? 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 ti 4006......146.44.114 ••••>...•••••••• Page 642 any other girl. And no, they both didn't like it. Who would like it? Q. Did you have any friends better then M, You know, would you consider her, she was your best friend, or is your best friend? A. At that time, no. Q. Who is your best friend now? A. Q. .How about now? A. My son. Q. Okay. Other than your son, a friend not family. is she, is she your best friend still? A. Jesus, myself, my son. Why are you looking at me crazy? Q. Is she your best friend was the question. A. I don't have a best friend. Actually, yes, l do. Q. Who? A. Q. Who is she? A. Q. Is she another person that is suing Jeff Epstein? A. Nope. She was affiliated with who died. 36 (Pages 639 to 642) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fef-d299-4e41-9ba13.85aad27f4406 EFTA01076194 643 Page 645 I Q Wbala? 2 A. Yeah. 3 4 'allow was she affiliated with 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page A. She was good friends with ha and I met through her. And If took to Jeffiey Epstein's house. Q. Where does live? A. Rhode Island. Q. Do you have the phone number for this babysitter you say you use? A. Yes. Q. A. Yes. Q. What's her number? A. I don't know it off the top of my head. Q. Is she listed in the phone book? A. Probably. Q. Is she — you say she lives in the Acreage? A. Yes. Q. Is she married? A. No. Q. Have you ever been to her house? A. Yeah. 1 times you actually went? 2 MR. EDWARDS: Form. 3 THE WITNESS: What does that mean? 4 MR. EDWARDS: Answer if you know what that 5 means. Do you have physical proof, videotape. 6 Answer his question if you know what the answer 7 is.. THE WITNESS: No. No one videotaped me 9 and no, we didn't keep a log, no. 10 BY MR. LUTIIER: 11 Q. There is no record that you could consult 12 that would say I !mow I went 21 times or exactly how 13 many times because you kept a record of it? 14 MR. EDWARDS: Font 15 THE WITNESS: No. 16 MR. EDWARDS: This is outside of whatever 17 records are in your client's possession. 18 BY MR. LUTTIER: 19 Q. And since you and ed.. are 20 all represented by the same lawyer, do you recognize 21 that there is an inherent conflict amonathree 22 in terms of any accusations that M. and 23 would have against you for taking them to 24 Mr. Epstein? 25 MR. EDWARDS: Object to the form. Page 644 Q. Does she rent, does she own, do you know? A. No. Q. Live alone or with somebody else? A. Her brother. Q. Same last name -- A. I don't know. as her and her brother, last name is 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 • 22 23 1 2 2 3 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 BY MR- LUTTIER: 24 25 Q. And you have no physical proof of how many 25 A. I don't know. • THE VIDEOGRAPHER: Your Sc is on your chair. BY MR. WITTER: Q. Now, you've told us when you believe you first went to Jeffrey Epstein and when you went the last time. If I and I may have asked you at the last deposition: You have no physical proof of when you actually went, right, the actual dates that you went? MR. EDWARDS: Object to the form. MR. LUTTIER: That would be like a calendar or notes, something like that. MR. EDWARDS: Form. THE WITNESS: Nope. PROSE COURT REPORTING Page 646 THE WITNESS: I don't understand what the hell — BY MR. LUTTER: Q. There is a conflict of interest. Mr. Edwards can't represent one, one client suing another one of his clients; you recognize that, don't you? MR. EDWARDS: Form. THE WITNESS: Okay. BY MR. LU1TIER: Q. Have you seen deposition? A. No. Q. Have you been told anything about it? A. No. O. Have you been told anything about case . A. No. Q. Who is actually representing you now? Do you know the name of the law firm that now represents you? A. Whatever this law firm's called. Q. Is it — did you sign a new fee agreement with the new law firm? A. Yes. Q. So, it's whatever firm IMINIM is now 37 (Pages 643 to 646) AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421ef-d299-4e4f-9ba6.85and2714405 EFTA01076195 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 647 with? A. Yes. Q. meet any of the people from the A. No. ' any investigators from the A. No. Q. Have you ever been interviewed by any of the investigators from there? A. No. ar Do you know a man by the name of II A. No. Q. Ha v heard of his name? A. Q- A. No. Q. Do you have this babysitter's phone number in your cellphone? A. No. I don't keep it in my cellphone. Q. You, you don't keep your babysitters number in your cellphone? A. No. Q. And you don't have it memorized? Page 648 1 A. No. 2 Q. So, what do you have to do when you want 3 to call a babysitter? 4 A. Ifs at home. 5 Q. So, if you're out and about and you need 6 to call the babysitter and tell her you'll be 7 A. I usually keep it in my purse. 8 Q. — there late you don't have any way to do 9 that until you get home? 10 A. I usually keep it in my purse and I am not 11 late. 12 Q. Where do you keep it? Do you have a phone 13 book in your purse? 14 A. No. I have a piece of paper with her number. 15 Q. Okay. Do you have that with you here 16 today? 17 A. No. 18 Q. So, as you sit here todq=illo not have 19 on your person anywhere Ms. phone number, 20 is that right? 21 A. I do not have her number with me, no. 22 Q Do you know somebody by the name of ■ 23 (phonetic)? 24 A. No. What time is it? 25 Q. 4:41. Page 649 1 A. Okay. I have to pick my son up by 6 so — 2 MR. EDWARDS: Well be done. 3 BY MR. LUTHER: 4 Q. At the beginning of this deposition you 5 asked a question about whether or not somebody else 6 was going to be here I think on behalf of you. And 7 you made some reference to somebody you had met with 8 about this deposition. Do you recall making that 9 statement, asking whether or not this other person 10 was going to be here? 1 A. Uhhuh, yes. 12 Q. Who were you referring to? 13 A. His name is I don't know his name. 14 Q. Is it a lawyer? 15 A. Hp's an attorney. 16 Q. Not a paralegal. A guy named Fanner, 17 Mr. Farmer? 18 A. I daft know. 19. Q. Have you net this other person? 20 A. Yes. 21 Q. Where did you meet this other person? 22 A. At the law firm. 23 Q. Mr. Edward's law firm? 24 A. Yes. 25 Q. Down in Fort Lauderdale? 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 650 A. Yes. Q. So, you've been down to his new law firm? A. Yes. Q. Did you review anything in preparation for today's deposition? A. Yesterday I talked to my attorney. Q. Did you review any documents? A. I reviewed a document, yes. Q. What document? A. I don't know. I don't know what document, sir. Sorry. Q. You say you reviewed a document or documents? A. I reviewed a document. Q. One piece of paper? A. A few, a few pieces of paper. Q. Okay. What were they? What did they have on them? MR. EDWARDS: Objection as to this line of questioning calls for attorney-client privilege information. She's not going it answer it as to exactly what we went over in preparation for the deposition. BY MR. LUTTIER: . Other than notes created by our lawyer ewe 38 (Pages 647 to 650) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421ef-d299-4e4f-aba6-85aad2714405 EFTA01076196 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 651 which I don't want to know about, did you review any other documents in preparation for your deposition? A. No. I have to be out of here at 5:30. Q. Did you ever hear anything about how your case may have been involved in any of that? A. No. It's irrelevant to me right now. Q. Does that mean you have never heard Page 653 1 in the garbage. 2 Q. Well, at the time we took your deposition 3 in September, you told us under oath that it was at 4 your home. Did you do something with it since -- 5 A. No. 6 Q. — your deposition on 7 A. No. 8 Q. Well, it just didn't disappear, did it? 9 MR. EDWARDS: Form. 10 THE WITNESS: No. Are you being sarcastic 11 with me? 12 BY MR. LUTHER: 13 Q. No. I mean you had to do something with 14 it, right? 15 MR. EDWARDS: Form. 16 THE WITNESS: I didn't touch it. I can't 17 find it. I don't know where it is. It's not 18 in the house, so, song. 19 BY MR. LUTTIER: 20 Q. Well, where did you think it was when you 21 testified definitively that it was in your home? 22 A. I thought it was in a couple of my papers that 23 I have and it's not. I thought it was where my Social 24 Security card was. It's not them, sir. End of 25 dismission. Page 652 1 anything or you just disregarded what you heard? 2 A. I disregarded what I heard. 3 Q. So, what did you hear? 4 MR. EDWARDS: You're asking her though 5 what she heard outside of any conversation with 6 me obviously? 7 MR. LUTHER: Yeah, oh, yeah. I don't 8 want you to tell me, I don't want you to ever 9 tell me anything your lawyer told you. 10 THE WITNESS: Oh, no, I didn't hear 11 nothing. 12 BY MR. LUTTIER: 13 Q. Okay. Now, in your previous deposition 14 you indicated that you had a book. I think you said 15 it had a red — it was a red book. !don't remember 16 if the color was right and you said it had a Bible 17 verse on it. Do you remember that testimony? 18 A. Yes. 19 Q. And at that deposition you told us 20 definitively that you had that at your home? 21 A. Yes. 22 Q. Where is that book now? 23 A. I can't find it. It's nowhere to be found. 24 Q. Well, what did you do with it? 25 A. I don't know. I moved a lot so it's rehab! 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 654 Q. Do you know the names of any of your clients that you had when you were working — other than the ones you've aheady identified here, clients you had when you were working for any of the escort services? A. No. Why would they want me to know their names? I don't want to know their names either. Q. I have no idea. A. They have wives. Q. All your clients have wives? A. Probably. We don't — it's not about relationships, man. It's about — Q. When you were wmtirag for those — A — mo and out. MR. EDWARDS: Form. MR. LUTTIER: Right? MR. EDWARDS: Fonn. BY MR. LUTTIER: 39 (Pages 651 to 654 PROSE COURT REPORTING AGENCY,. INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421ef-d299.4e41-9ba6.85aad2714405 EFTA01076197 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 655 Q. Well, why did you do it? A. That's all I know. It's what Jeffrey taught me. Q. Well, Jeffrey wasn't married, was he? A. I don't1=w. Q. Well, did you ever ask him? A. He lied to me about everything. Q. Did you ever ask him? A. Yeab, I think I did. Q. And what did he tell you? A. He said no. Q. Do you have any information that Jeffrey Epstein is married? A. No. Q. Do you have any information that he was ever married when you were -- And— Page 657 1 And you know I don't want to do this in the 2 future. I absolutely despise what I do. I 3 hate what I do. I don't want to do what I do. 4 This is what I have learned from Jeffrey 5 Epstein and I hate it, and I can't wait to get 6 out of it. 7 BY MR. LUTHER: 8 Q. That's what you said in 9 wasn't it? 10 A. Yeah. 11 Q. Didn't stop you, did it? You still went 12 ahead and you keep on doing the same thing you've 13 always done? 14 MR. EDWARDS: Form. 15 BY MR.. LUTHER: 16 Q. — ben tledl you want the money, isn't that 17 right? 18 A. Yeah. 19 Q. That's the — the bottom line is -- 20 A. Well, actually I put myself through school 21 through it. 22 Q. The bottom line is — 23 A. I wanted to go back to school. Bottom line, I 24 wanted to go back to school so I did it to go to school. 25 Q. Well, have you saved up money to go to 1 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 656 A. It's wrong either way. A. How do you justify you sitting here representing a pedophile? You know? You're silly. But I'm sorry. MR. LUTTIER: Move to strike? THE WITNESS: I don't know. MR. LIMIER: And now answer my question. THE WITNESS: I have to go home every day and put a poker face in front of my son. I don't ever want him to know what I have done. Page 658 1 school? 2 A. Yes, I did. 3 Q. How natal have you saved? 4 MR. EDWARDS: Form. 5 THE WITNESS: It's none of your business. 6 BY MR. LUTHER: 7 Q. Where's the money? 8 A. None of your business. 9 MR. EDWARDS: Form. 10 BY MR. LUTTIER: 11 Q. Got it in a bank account? 12 MR. EDWARDS: Form. 13 THE WITNESS: It's none of your business. 14 BY Kt. LUTTIER: 15 Q. Well, how are we going to test the 16 credibility of what you say when you say you saved 17 money unless we know where it is? 18 A. Who cares? Who gives a shit if you, if I save 19 money or not and if I -- you Icnow, the money I saved, 20 who cares. You got money? 21 Q. Well, your justification as I understand 22 it for doing what you do is so that you can save 23 money to go to school, is that right? 24 A. Yeah, and so my son can go to Christian 25 school. 40 (Pages 655 to 658) PROSE COURT. REPORTING AGENCY, INC.. Electronically signed by cynthia hopkins Electronically signed by cynthia Hopkins Electronically signed by cynthia hopkins b5542fet•d299-4e41-9ba6-85aad27f4405 EFTA01076198 Page 659 1 Q. So, I am asking you, did you save money 2 and if so where is the money? 3 MR. EDWARDS: Form. 4 THE WITNESS: Yeah. 1 saved money and 3 it's under my bed. 6 MR. EDWARDS: Don't be sarcastic. Just give him an answer, the truth. 3 THE WITNESS: No, Fm not. It's under my 9 bed with rubber-bands. 10 BY MR. LUTTIER: 11 Q. All right. Well, how much have you saved 12 then since it's under your bed? 13 MR. EDWARDS: Object to the form. 14 BY MR. LUTHER: 15 Q. How much have you saved? 16 MR. EDWARDS: Form, asked and answered. 17 Harassing at this point. 18 BY MR. LUITIER: 19 Q. Do you have a record of it anywhere? 20 A. Nope. I have headache. 21 Q. Have you ever applied, applied for 22 financial assistance at any college or university? 23 A. Yes. 24 Q. Where did y >Iv or a. istance? 25 A. Through the Page 66 Q. And did you get any financial aide? 2 A. Yep. 3 Q. What? 4 A. Yeah. 5 Q. Was that the loan you described earlier? 6 A. Yes. 7 Q. So, you have been able to finance your 8 education by simply applying for financial aide? 9 A. Correct. 10 Q. So, you didn't have to do what you're 11 doing in order to go to college. 12 A. Thad to finance and then I had to make the 13 money back to pay for it. I don't have a mommy and 14 daddy that takes care of me and I am not going to be 15 working at Burger King. 16 Q. What's wrong with working at Burger King? 17 A. You make $7 an hour. 18 Q. And that's really why you do what you want 19 to do is you don't want to go get a job that pays 20 less than the amount of money you can make doing 21 what you do, isn't that right? 22 A. No, you're wrong. 23 MR. EDWARDS: Object to the form. 24 BY MR. LUTHER: 25 Q. You could gowork al BurgerKing, right? 1 2 3 4 5 6 7 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 661 A !could. Q. How many jobs hgvagaga•ktalor? A. 'used to work at being an esthetician. Q. How many — in the last two years, how many jobs have you applied for? _As I actually worked und le r the sending out things for I do side jobs. I do cleaning jobs. There is I do to make money. Q. First of all, my question was how many jobs have you applied for in the last two years? A. In the last two years probably five, and I have got them all. Q. Okay. Where did you, where did you put in your applications f. five Sobs? A. One for Q. A Q. Wait a minute. Is, is the ed something different A. No. Ifs just Q. So, the big company, you submitted an application? Page 662 A Yeah. Q. And did you get hired? A. Yep. Q. Okay. How much did they pay you? A Fifteen bucks an hour. Q. So, you were able to get jobs in the labor market just like everybody else, right? A. Yeah. Q. Where else did A. I have applied Q. A Q. Okay. In the last two years? A. Yeah. Q. And did you get hired? A. Yep. Q. And how much did they pay you? A. Twelve an how. Q. Okay. S that job. Are you still working for A. No. Q. Why did you quit? A. It was seasonal. Are you still forking'for 41 (Pages 659 to 662) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fef-d299.4e41-9ba6-85aad2714405 EFTA01076199 Page 663 Page 665 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. Nope. Q. Why did you quit? A. The economy just went down and she only could hire me three days out of the week so — Q. Where else did you apply in the last two years? A. I always—. Q. Well, that's not an application is it? A. Well, you got to sign up to Q. That's just you selling stuff that you have al A. Okay. Well, if that's how you want it. Q. Where else hrsyou applied for a job? A. I've been at IME and they paid me under the table. Q. When did you apply fora job at M? A. Last year. Q. What dk iu do for them? A. Q. Okay. How much did you get paid? A. That was like $9 an hour. Q. Ok is s Where else did you apply? A. Q What did you do there? A. I was one of the instructors for 1 2 Q. 3 that? Page 664 group. And, and how much did you get paid for 4 A. Nine dollars an hour. 5 Q. And are you still working there? 6 A. No. 7 Q. Why not? 8 A. Because it's not paying the bills. 9 Q. So, you quit? 10 A. Yeah. 11 Q. Did you quit M7 12 A No. 13 Q. Did they fire you? 14 A. No. 15 Q. Still there? 16 A. No. 17 Q. What happened? 18 A. They, they just needed help fora couple 19 months. 20 Q. Okay. Any other places you have applied 21 for jobs? 22 A. I clean houses -- 23 Q. For who? 24 A. —once in a while. For people. 25 Q. How much do you get paid to clean a house? 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 $ 10 11 12 13 14 15 16 17 18 • 19 20 21 22 23 24 25 1 A. Ten dollars an hour. 2 Q. And when was the last time you did that? 3 A. Like before I went to New York. 4 Q. And whose houses, did you clean the same 5 clients' houses? 6 A. It's just actually friends' houses. Q. Anyplace else you've applied for work? A. No, that I can recall. il ou said you worked for the- Did I hear that? A. Well that was for, that's incorporated with Q. The- employed you, did they? A. That is in — intertwined with to my question. The A. No. I didn't apply for never employed ou did the n so they couldn't deny me. Q. Well, you SU ested the were a in ou under the table. The never paid you under the table. I never, I never worked for the_ sir. So keep on bring it up so we can keep on going over it again. never Page 666 THE WITNESS: What time Is it? MR. EDWARDS: You got time. It's 5. • •elx Q. Is it current? A. I don't know. I don't use it. Q. Were you provided with a copy of a document that's called a proposal for settlement in this case? A. Idon't Know: Was 1? Q. I mean I can show it to you. !don't want to mark it on the — I don't want to have it in the record because I don't want it to be a — but I will show it to you so you can recognize the document. Let me just show you the document. . A. You can't help me. Q. Just go ahead and read it. A. Jeffrey Epstein is not admitting, he is in fact denying all liability or responsibility because he did it — THE COURT REPORTER: If you could read -- MR. EDWARDS: Just read it to yourself because if you say the words, she has to take 42 (Pages 663 to 666) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421of-d299-4e41-9ba6-85aad27f4406 EFTA01076200 Page 667 Page 669 1 them down. 2 THE WITNESS: Oh, okay. I don't want to 3 read anymore. I'm good. 4 BY MR. LUTHER: 5 Q. Did you see that — 6 A. Yeah. 7 Q. Have you seen that before today? 8 A. You know what, send Jeffrey to jail for 20 9 years and then I will take zero dollars. I need 10 justice. I want what's fair for all of us, for all of 11 us guts. 12 Q. What you want is money, right? 13 A. No. I want justice and I want what's fair. 14 And what's fair is that he should serve jail time. He 15 didn't sense jail time forme and my girlfriends. He 16 sat with his little rich butt -- 17 Q. And who told you that? 18 A. — in a little office doing community service 19 which was probably nothing for him because money talks. 20 And you know what, I want justice. So, I tell you what, 21 give me no money right now and send Jeffrey to jail for 22 20 years, and 1 will walk out of here with a smile from 23 ear to ear. 24 Q. Have you ever gone to jail, ma'am? 25 A. Nope. 1 2 3 4 5 6 7 8 9 :0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yeah, I do have problems sleeping. Q. Do you — well, other than the fact that you're out until 5:00 -- A. Actually Q. Other, other than the fact that you're out until 5:00 in the morning at strip clubs, do you have any problem sleeping? A. Oh, you're so cute. I have trouble sleeping over Jeffrey, yeah. going out to Q. Well I me it doesn't keep you from until 5:00 in the morning, does it? A. It keeps me up. Q. Okay. A. People got to do what you got to do. Just hire you got sit here and defend a child molester, you know. I got sit here and go to and make money, too. What's the difference, right? Now, you testified last time that you were A. Girls. I don't know. Q. What are their names? A. I don't know. They have stage names. I really could not tell you. Page 668 1 Q. You don't know how long Mr. Epstein was in 2 jail, do you? 3 A. I heard he was in jail for 18 months but -- 4 Q. You don't know what it was like in jail, 5 do you? 6 A. Oh, God. For Jeffrey, poor old Jeffrey, oh, 7 he went to jail because he molested over 100 little 8 girls. I hope he was molested or rapped, whatever the 9 definition is. He needs more torture than that, jail. 10' Yeah, he needs to stay in there for 20 years, not 18 11 months. 12 Q. What do you think you should do as a 13 result of you having taken a bunch of your best 14 friends and girlfriends and knowing exactly what was 15 going to happen in taking them to Jeffrey Epstein? 16 A. Call all of them and say, I am sorry,1 was 13 17 years old, I apologize for being naive and a stupid 18 little girl and I hope that everybody can get 19 counseling. And 1 hope that everybody can get served 20 justice. I hope we can see Jeffrey's face in the 21 newspaper saying that finally this jerk-off is in jail 22 for 20 years, and now all of us can go to sleep 23 peacefully. 24 Q. You don't have any problem sleeping, do 25 you? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 MR. EDWARDS: Object to the form. 21 THE WITNESS: No. 22 • 23 24 25 Page 670 Q. Well, did you guys work together? A. A few times. Q. And when you say you worked together, what does that mean? A. That we worked totether. 43 (Pages 667 to 670) PROSE COURT REPORTING 'AGENCY, INC. Electronically signed by synods hopkins Electronically signed by synthla hopkins Electronically signed by synth's hopkins b5542fef-d299do4f-9ba6.85aad2714405 EFTA01076201 Page 671. Page 673 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 3 4 5 A. Sometimes. So, will Jeffrey go to jail for 20 6 years if he gives nobody money or he can't stand it? 7 Q. Have you sold any interest in this lawsuit S to anybody? 9 A. No. 10 Q. In other words have you received money 11 from anybody and in return given them an interest in 12 this lawsuit? 13 A. No. 14 Q. Have you received any money or any other 15 kind of consideration from any company with respect 16 to this lawsuit? 17 A. No. 18 Q. Any attorney with respect to this lawsuit? 19 A. No. 20 Q. Any other person with respect to this 21 lawsuit? 22 A. No. 23 Q. Have you been provided any money advances, 24 that is money — 25 A. No. 18 19 20 21 22 23 24 25 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH M the undersigned authority, certify that . personally appeared before me and was duly sworn on the 9th day of February, 2010. Dated this 19th day of February, 2010. Cynthia Hopkins, RPR, FPR aWif 17 Notary Public - State of Florida My Commission Expires: February 25, 2011 My Commission No.: DD 643788 Page 672 Q. - as an advance against an outcome in 2 return for a sharing of the percentage of it? 3 A. No. Q. Have you assigned any interest in this lawsuit to anyone? A. No. MR. LUTTIER: Okay. Fro done. Any cross? MR. EDWARDS: We'll read. THE VIDEOGRAPHER Going off the record at 5:05 p.m. This is the end of Tape 3 of the deposition. THE COURT REPORTER: Do you want to order this? MR. LUTTIER: Yes. THE COURT REPORTER: Would you like a cOPY? MR. EDWARDS: Yes, please. (Witness excused.) (Deposition was concluded.) 16 17 18 19 20 21 22 23 24 25 1 2 3 5 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH ;Cynthia Hopkins, Registered Professional Reporter. Florida Psofessionsl /tenacity and Notary 6 PuNic in and for the State of Florida at large, do hereby certify that I ass authorized to and did 7 report said deposition in stenotype and that the foregoing pages arc a true and cornet transcription 8 of my shorthand notes of said deposition 9 I further amid& that said deposition vas till= at the tirne and place hereinabove set fonds 10 and that the taking of said deposition was commenced and completed as hereinabove set out. I tut certify that 1 am not anomey or 12 cowed of any of the Indies, nor am a relative or employee of any ancimey or counsel of party 13 connected with the action, nor am 1 financially interested in the acme 14 The foregoing cenitication of this transcript 15 does not apply to any reproduction of the same by any moon unless tinder the dinxt control andkr direction of the oertifyin reporter. Dated this 19th day of retailer% 2010 11 ia Hopkins, Page 674 44 (Pages 671 to 674) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia napkin* Electronically signed by cynthia hooking Electronically signed by cynthia napkins b5S42lel-d299.4041-9ba6-85aad27f 4405 EFTA01076202 Page 675 Page 677 DATE: Febnery 19t, 2030 e/MAD J. EDWARDS, ESQUIRE TO. FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEBRMAN. 42S North Ansley«. Avenue Suite 2 vs. ySleiri E Port ale, Florida 33201 IN RE: CASE 14D s CA02805 I =MAE Att Please take nonce that on Tuesday. the 9th of February, 20)0. you gam your deposition kite abcoc-refsued mattes. At that tulia. you not wave ligature. It is oar neorstuy that you sign you deposition As Menai* agreed to, the transcript sell be firmased se you trot* yea counsel. Max read the Folloun antimafia...1 carefully. At the end of the transcript you wilt find et twin then As you read yotx depos:non, any 2 changes or (mottoes that you wish to make should be noted on the errata tires, caing page and line 13 number of raid chrism DO NOT unto on the aaracrim itself. Once you law read the 14 rransciipt md noted any changes. be sure to tops and due the nails:es and return time pages to 15 me If you do not tad and sign the dcposibon 16 within a reasonable time, the original. which has abraly ban Ibilwaided io the Waal Malay, may 17 00 filed wins the Clak tithe Can lf you MA to waive your ri&tature, sign your name in the blank Sr a the bottom of this letter and scans is to us 19 Very t-Ar you,. 20 21 22 23 I de hereby waive my Sigialutt. 24 25 • 1 2 3 4 5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE I LINEN CHANGE REASON 6 ERRATA SHEET IN RE: VS. EPSTEIN DEPOSITION OF: HopkiltPR, PPR CR: TAKEN: February , 0 8 9 10 11 12 13 14 15 16 17 Please forward the original signed meta sheet to this office so that copies may be distnlnued to all 18 parties. 19 Under penalty of pajury, I declare that I have read my deposition and that it is true and correct 20 subject to any changes in form or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 I Page 676 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are tme and correct to the best of 8 my knowledge and belief, with the exception of any 9 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 45 (Pages 675 to 677, PROSE COURT REPORTING AGENCY, INC. 1 Electronically signed by Cynthia hopkins 601.0 1-97 Electronically signed by Cynthia hopkins Electronically signed by Cynthia hopkina b5542tcl-c1299-404liba6.B5aad27,4405 EFTA01076203