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Page I UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME I OF II Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JANE DOE NO. 3 Friday, February 19, 2010 10:07 - 5:09 p.m. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Nofary Public, State of Florida Prose Court Reporting Services Job No.: IIII EXHIBIT PROSE COURT REPORTING AGENCY, INC. EFTA01104171 Page 82 1 any additional sworn testimony regarding Mr. Epstein 2 to anyone? 3 A. No. 4 Q. Did you ever give a handwritten report to 5 anyone as to what occurred at Mr. Epstein's house, 6 and I'm not interested again in what happened, once 7 you hired Mr. Herman? 8 A. I don't remember. 9 Q. At any time — well, let me ask it this 10 way: After you filed your — or after the Palm 11 Beach Police Department met with you, Officer 12 Recarey met with you, did you ever discuss that 13 ' that is the conversation you had with them 14 with , that is this is what they asked me; 15 what did they ask you? 16 A. What? 17 Q. You said.. was around you at the 18 dine - 19 A. Yes. 20 Q. — when the Palm Beach Police Department 21 came' correct? 22 A. Yes. 23 Q. Okay. After — did they interview her as 24 well the same day? 25 A. No. Page 84 1 Q. Okay. Did you, did you, did she tell you 2 that before you ever went to Epstein's home? 3 A. Yes. 4 Q. Okay. And what was the occasion of her 5 telling -- her, telling you what had occurred 6 at Epstein — or that she had been to Epstein's 7 hone? Do you want me to ask that again — 8 A. Yes. 9 Q. — because I confused myself. 10 You said that.. told you, before 11 you first went to Mr. Epstein's house which you 12 described as being approximately in June of '04, 13 that she had been to Epstein's home; is that 14 correct? 15 A. Yes. 16 Q. Okay. And, and what was the occasion of 17 her telling you, that is how did it come about that 18 she told you she had been to Epstein's home? 19 A. How did she ten me? 20 Q. No. What was the occasion? Where were 23. you and how did you — how did the subject come up? 22 A. asked me if I wanted to do it. 23 Q. SAM meaning 24 A. 25 Q. And where were you-all at the time? Page 83 1 Q. Okay. Do you know whether she ever went 2 to Epstein's? 3 A. Yes. 4 Q. Okay. And how, how did you know that? 5 A. She told me. 6 Q. Okay. Did she tell you before the police 7 department ever contacted you? 8 A. Yes. 9 Q. Okay. And did you know.. -- was she 10 one of your good friends at the time? 11 A. Yes. 12 Q. Okay. She's still a good friend? 13 A. Yes. 14 Q. Okay. Do you know whether she's a 15 plaintiff or has ever filed any type of claim? 16 A. I don't know. 17 Q. Okay. Did you ever tell her that you had 18 filed a claim? 19 A. No. 20 Q. She just knows that you went to Epstein's 21 home? 22 A. Yes. 23 Q. Okay. Did she ever tell you what happened 24 at Epstein's home? 25 A. Yes. 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 A. At a girlfriend's house. Q. Whose house were you at? A. Jane Doe No. 4's. Q. Jane Doe No. 4 who? A. Doe No. 4. Q. And how did you know Jane Doe No. 4? A. I gew up with her in MI I went to school with her. Q. Same grade? A. No. Q. Older; younger? at Older. Q. How much older? A. A year. MR. MERMELSTEIN; Just to be dear, your question as to who was older, her or Jane Doe Na 4? BY MR. CRITTON: Q. I'm assuming you meant Jane Doe No. 4 was a year older than you. A. Yes, sir. MR. CRITTON: I think it was just you. MR. MERMELSTEN: I'm the only one that was confused, right? MR. CRITFON: Yeah 22 (Pages 82 to 85) PROSE COURT REPORTING AGENCY, INC. EFTA01104172 Page 86 1 BY MR. CRITTON: 2 Q. And Jane Doe No. 4, is she from pretty 3 much a middle class family as well? 4 A. Yes. 5 Q. All right. AM Jane Doe No.4 is the one, 6 she's a soccer player, wasn't she? 7 A. Yes. 8 Q. And did you and Jane Doe No. 4 — well, 9 let me stile that. 10 Let's see, if you went in 1.1 approximately June of'04, approximately when did 12 this conversation take place, how many months before 13 you ultimately went? 14 A. What conversation? 15 Q. Well, you said theta asked you, if I 16 understood you, asked you if you wanted to go? 17 A. Yes. 18 Q. Okay. Is that the first time.' had 19 ever brought it up to you? 20 A. No. 21 Q. So, at least at the time that 22 brought up going to Mr. Epstein's house or going 23 to did you know his name was Epstein at that 24 time? 25 A. Jeffrey. Page 1 A. Don't know exactly where I was. I deal 2 remember. She told me that she gave a massage to 3 Jeffrey for $200. 4 Q. Did she tell you how many times she'd done 5 it? 6 A. No. 7 Q. Did you ask her about Jeffrey? 8 A. No. 9 Q. Did you say, what are you doing giving 10 did she tell you how old Jeffrey was? 11 A. No. 12 Q. Okay. Had you ever heard — or let me 13 strike that. 14 At the time that., mentioned that, 15 first mentioned to you that she had given a guy 16 named Jeffrey a massage for $200, had you, had.. 17 ever talked to you at all? 18 A. Yes. 19 Q. And had talked to you a number of 20 months before you eventually went to Mr. Epstein's 23. home; is that correct? 22 A. Yes. 23 Or to Jeffreys home. Where were you when 24 first said something to you about 25 Jeffrey? 88 Page 87 1 Q. Just Jeffrey. All right. When she said, 2 she asked you, apparently again, if you were 3 interested in going to Mr. — to, to Jeffrey's house 4 to give him a massage, at least on this occasion 5 Jane Doe No. 4 — you were at Jane Doe No. 4's 6 house, and.. was there 7 A. No. B Q. — as well as..? Is that wrong? 9 A. That is wrong. 10 Q. Okay. Then let me ask a question. 11 thought you — had you learned that II., had, 12 had been at Jeffrey's house sometime before this 13 conversation? 14 A. Yes. 15 Q. By "this conversation," I mean when 16 asked you, you were at Jane Doe No. 4's house. 17 A. Yes. 18 Q. How much earlier was the conversation 19 where told you she had been to Jeffrey's house? 20 A. A lot earlier. 21 Q. A number of months? 22 A. Probably, yeah. 23 Q. And when • told you that, what did she 2 4 tell you; that is what were the circumstances of her Who innanis 2 „...... was there? Where were ou? Page 89 A. Jane Doe No. 4's house. 2 Q. Okay. AM who was there at the time, you, 3 Jane Doe No.4, ; anyone else? 4 A. Nope. 5 Q. And how many months was this prior to your 6 ultimately going to Jeffreys home? 7 A. I don't remember. Q. Four months, six months? 9 A. I don't remember. 10 Q. A number of months? 11 A. I really don t remember. 12 Q. You don't know whether it was a day or a 13 number of months? 14 MR. MERMELSTE1N: Objection. She's 15 answered the question. 16 THE WITNESS: I don't remember. 1, I 17 don't remember. 18 BY MR. CRITTON: 19 Q. I just want you to make sure, because I 20 want to make sure that the ladies and gentlemen 21 understand. 22 So, the first conversation where 23 ever referenced going to JeffieStouse, you 2 4 were at Jane Doe No. 4 home, you, MI and Jane Doe 2 5 No. 4 were the onlyczle there, correct? 23 (Pages 86 to 89) PROSE COURT REPORTING AGENCY, INC. EFTA01104173 Page 90 Page 92 1 A. Correct. 2 Q. And then we know you went to Mr. Epstein's 3 borne, or at least by your testimony, sometime in June of '04; is that correct? 5 A. Yes. 6 Q. So, and is it your testimony as to when 7 this conversation first took place, where 8 asked you if you wanted to go to Jeffrey's home, you 9 don't recall whether that was a week before you 10 ultimately went or months; is that correct? 11 A. Correct. 12 Q. What did say to you the first 13 occasion at Jane Doe No. 4's home? 14 A. Excuse me. You can make quick money, 200 15 bucks just to give a guy a massage. 16 Q. And did she tell you about who the guy 17 was? 18 A. Yeah, his name is Jeffrey Epstein. 19 Q. And she said Epstein? 20 A. Yes. 21 Q. Okay. And did she tell you where he 22 lived? 23 A. On Palm Beach. 24 Q. I assume you'd been to Palm Beach before. 25 A. Yes. 1 Q. Ever done it with a, with a guy? 2 A. No. 3 Q. A boyfriend? 4 A. No. 5 Q. Did Jane Doe No. 4 say anything at that 6 time when asked you? 7 A. Excuse me. I don't remember. 8 Q. Did you know that Jane Doe No. 4 had 9 gone — 10 A. No. 11 Q. — to Epstein's home at that time? 12 A. No. 13 Q. Okay. At some point she told you, didn't 14 she? 15 A. She didn't tell me, no. 16 Q. At some point did you come to team that 17 Jane Doe No. 4 had been to Mr. Epstein's home? 18 A. Yes. 19 Q. Okay. From whom did you learn that fact? 20 A. Word of mouth. 21. Q. When you say, "word of mouth," meaning 22 what, it was just common knowledge? 23 A. We all hung out together. 24 Q. So, at some point somebody mentioned that 25 Jane Doe No. 4 had been to Epstein's house? Page 91 1 Q. And did she tell you anything about it, 2 that is, his age, what he did? 3 A. No. 4 Q. Did she tell you anything about how old he 5 was, that is, whether he was your age, whether he 6 was an older person? 7 A. No. 8 Q. Did you ask? 9 A. I don't remember. 10 Q. Did, did you say, wait a minute, why 11 would — well, let me strike that. 12 Did she, M. say that she had been 13 there? 14 A. Yes. 15 Q. Did she say that she'd given him a massage 16 before? 17 A. No. 18 Q. Okay. Did you say, why are you asking me 19 if I would be interested in going? 20 A. I don't remember. 21 Q. Okay. Had you ever given a person a 22 massage before, before that period of time? 23 A. Yes. 24 Q. Okay. To whom had you given a massage? 25 A. My mom, my cousin. Page 93 1 A. Yes. 2 Q. Did you ever ask Jane Doe No. 4, say, hey, 3 how many times have you been to Epstein's house? 4 A. No. 5 Q. Okay. Did — when the word of mouth that 6 Jane Doe No.4 had been to Mr. Epstein's house, was 7 that kind of discussed when you guys would get 8 together, that is, who had been to Epstein's house? 9 A. Can you repeat that, please? 10 Q. Sure. You said you learned that Jane Doe 11 No. 4 had gone to Mr. Epstein's house by word of 12 mouth be you were all friends. 13 A. Yes. 14 Q. Okay. And somebody brought it up, but you 15 can't identify who the person is that brought it up. 16 A. Yes. 17 Q. Okay. And did you team from at least 18 these conversations, before you ever went to 19 Mr. Epstein's house, that Jane Doe No. 4 had been 20 there on many occasions? 21 A. No, I did not know that. 22 Q. Okay. Did you — you knew for sure she'd 23 been there once, but you didn't know how many times 24 she'd been there? 25 A. Correct. a 24 (Pages 90 to 93) PROSE COURT REPORTING AGENCY, INC. EFTA01104174 Page 102 1 Q. All right. And how much longer did you, 2 the two of you continue to date? 3 A. Maybe about two years, a year and a half. 4 Q. Two years after that? 5 A. Yes. 6 Q. So you dated.. about a year, a year to 7 ayes' and a half before you had this conversation 8 about giving a massage to Mr. Epstein, and then you 9 dated another two years after that? 10 A. About a year after that. 11 Q. Okay. 12 A. Yeah. 13 Q. All tight. So how much time transpired or 14 passed before you then had a conversation with — 15 another conversation about the possibility of giving 16 a massage to Jeffrey? 17 A. 'have no idea. 18 Q. Was ft a month, a week, a year, two years? 19 A. Awhile. 20 Q. Was it after then? 21 A. I was already broken up with.. 22 Q. All right. So it had to have been about a 23 year later. A year — 24 A. Me and him were on and off. We didn't have a 25 steady relationship. Page 104 1 friends? 2 A. Excuse me. Yes, me and Jane Doe No. 4 were 3 good friends, yes. 4 Q. Are you and Jane Doe No. 4 still good 5 friends? 6 A. No. 7 Q. Okay. When did you, you and Jane Doe 8 No.4 stop being good friends? 9 A. When she went lit 10 Q. When she went t 11 A. Yes. 12 Q. Do you know whether Jane Doe No. 4 is a 13 plaintiff in a lawsuit against Mr. Epstein? 14 A. I don't know. 15 Q. Okay. Do you know if I -- do you know 16 whether your current lawyer is representing Ms. Doe 17 No.4? 18 A. Yes. 19 Q. Okay. How do you know that? 20 A. Because I've spoken with her. 21 Q. With Jane Doe No. 4? 22 A. (Witness nods head.) 23 Q. Okay. And so — 24 11133 COURT REPORTER: Is that a yes? 25 IHE WITNESS: Yes. Yes, sony. Page 103 1 're i Q. So now yout ves dating or 2 you on and off with at this point in time? 3 A. Yes. 4 Q. And what happens? How does the topic come 5 up again? 6 A. I was approached again bylM. 7 Q. Where were you at the time? 8 A. I don't remember. 9 Q. Do you remember who was then? 10 A. I don't remember. 11 Q. How often — were you and good 12 friends? 13 A. 14 Q. 15 A. 16 Q. 17 A. 18 Q 19 No.4. 20 A. 21 22 23 24 25 No. Were you friends? Yes. Okay. More acquaintance-type friends? Yes. Okay. Was she good friends with Jane Doe Were she and Jane Doe No. 4 good friends? I don't 'mow their relationship. Q. Okay. Well, at least the fast time when -- that you're at Jane Doe No. 4's house when mentioned to you, do you, were you interested in making — giving a massage to Jeffrey, there was only the three of you. So were any of you good Page 105 1 BY MR. CRITTON: 2 Q. Okay. And she told you — when did you 3 last speak with Jane Doe No. 4? 4 A. A couple of days ago. 5 Q. All right. 6 A. I need to take a break, please. 7 Q. Can I have two more minutes? 8 A. No, I'm tired. I leed to take a break, 9 please. 10 MR. CRITTCK All right 11 THE VIDEOGRAPHER: We're going off the 12 record at 11:43 a.m. 13 (A brief recess was held.) 14 THE VIDEOGRAPHER: We're back on the 15 record at 11:57 a.m. 16 BY MR. CRITTON: 17 Q. We were talking about Jane Doe No. 4, and 18 you said that you spoke with her a couple of days 19 ago. 20 A. Yes. 21 Q. How long have you known that Jane Doe 22 No. 4 is a plaintiff against Mr. Epstein? 23 A. A little while. 24 Q. What's a little while mean to you, a 25 month, a week, a yea/7_ PROSE COURT REPORTING 27 (Pages 102 to 105) AGENCY, INC. EFTA01104175 Page 90 Page 92 1 A. Correct. 2 Q. And then we know you went to Mr. Epstein's 3 home, or at least by your testimony, sometime in 4 June of '04; is that correct? 5 A. Yes. Q. So, and is it your testimony as a 7 this conversation first took place, when 8 asked you if you wanted to go to Jeffrey's home, you 9 don't recall whether that was a week before you 10 ultimately went or months; is that correct? 11 A. Correct. 12 Q. What di.. say to you the first 13 occasion at Jane Doe No. 4's home? 14 A. Excuse me. You can make quick money, 200 15 lucks just to give a guy a massage. 16 Q. And did she tell you about who the guy 17 was? 18 A. Yeah, his name is Jeffrey Epstein. 19 Q. And she said Epstein? 20 A. Yes. 21 Q. Okay. And did she tell you where he 22 lived? 23 A On Palm Beach. 24 Q. I assume you'd been to Palm Beach before. 25 A. Yes. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Ever done it with a, with a guy? A. No. Q. A boyfriend? A. No. Q. Did t Doe No. 4 say anything at that time where asked you? A. Excuse me. I don't remember. Q. Did you know that Jane Doe No. 4 had A. No. Q. — to Epstein's home at that time? A. No. Q. Okay. At some point she told you, didn't she? A. She didn't tell me, no. Q. At some point did you come to learn that Jane Doe No. 4 had been to Mr. Epstein's home? A. Yes. Q. Okay. From whom did you learn that fact? A. Word of mouth. Q. When you say, "word of mouth," meaning what, it was just common knowledge? A. We all hung out together. Q. So, at some point somebody mentioned that Jane Doe No. 4 had been to Epstein's house? Page 1 Q. And did she tell you anything about it, 2 that is, his age, what he did? 3 A. No. 4 Q. Did she tell you anything about how old he 5 was, that is, whether he was your age, whether he 6 was an older person? 7 A. No. 8 Q. Did you ask? 9 A. I don't remember. 10 Q. Did, did you say, wait a minute, why 11 would — well, let mE rike that. 12 Did she,MR, say that she had been 13 there? 14 A. Yes. 15 Q. Did she say that she'd given him a massage 16 before? 17 A. No. 18 Q. Okay. Did you say, why are you asking me 19 if I would be interested in going? 20 A. I don't remember. 21 Q. Okay. Had you ever given a person a 22 massage before, before that period of time? 23 A. Yes. 24 Q. Okay. To whom had you given a massage? 25 A. My y mom, m cousin. aoaata- ekrikgeWAX•Stsfause... face.140-•— Page 93 1 A. Yes. 2 Q. Did you ever ask Jane Doe No. 4, say, hey, 3 how many times have you been to Epstein's house? 4 A. No. 5 Q. Okay. Did -- when the word of mouth that 6 Jane Doe No. 4 had been to Mr. Epstein's house, was 7 that kind of diqmosed when you guys would get 8 together, that is, who had been to Epstein's house? 9 A. Can you repeat that, please? 10 Q. Sure. You said you learned that Jane Doe 11 No.4 had gone to Mr. Epstein's house by word of 12 mouth because you were all friends. 13 A. Yes. 14 Q. Okay. And somebody brought it up, but you 15 can't identify who the person is that brought it up. 16 A. Yes. 17 Q. Okay. And did you learn from at least 18 these conversations, before you ever went to 19 Mr. Epstein's house, that Jane Doe No. 4 had been 20 there on many occasions? 21 A. No, I did not know that. 22 Q. Okay. Did you — you knew for sure she'd 23 been there once, but you didn't know how many times 24 she'd been there? 25 A. Correct. 24 (Pages 90 to 93) PROSE COURT REPORTING AGENCY, INC. EFTA01104176 Page 94 Q. Okay. Did, did you at some point get the 2 drift — not the drift — did you, did you come to 3 at least understand, based on the conversations that 4 were going on before you ever went to Mr. Epstein's, 5 that she had been there a number of times? 6 A. No. 7 Q. Just that she had been there? 8 A. Correct. 9 Q. All right. But you understood that she 10 had also gone to Epstein's to give him a massage? 11 A. Correct 12 Q. Who else did you lean other than MI 13 and Jane Doe No. 4, at least on the first occasion, 14 did you learn or know that had given Mr. Epstein a 15 massage, or purport had given him a massage? 16 A. I didn't know given, has given Epstein a 17 massage. 18 Q. You just }mew that she asked you if you 19 would be interested? 20 A. Yes. 21 Q. Okay. And did you ask her at that time, 22 say, did you give — have you ever given him a 23 massage? 24 A. No. 25 Q. Okay. At the time she asked — first 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 96 A Not that I remember, no. MI Okay. Well, did you say, did you say to as well, what do I have to do for $200? A. Yes. Q. Okay. And what did she say? A. A massage. Q. Okay. Did you say, what's the massage consist of? A. I did not say that. Q. Okay. Did you say, how long does it have to last? A. Yes. Q. And what did she say? A. Half an hour. Q. All right. And did she tell you where you'd have to go? A. Yes. Q. Did you say, well, who's going to go there with me? A. Yes. Q. All right. And she said? A. She would. Q. All right And did she say — did you discuss how you were to get there? A. She already said she would drive. Page 95 1 asked you, when you were at Jane Doe No. 4's house, 2 what was your response? 3 A. I don't know; I'll have to think about it. 4 Q. Okay. What questions did you ask before 5 you even said, I don't know; TR have to think 6 about it? 7 A. What happens? 8 Q. Did you — and what did she say? 9 A. You give him a massage. 10 Q. Okay. And what did you say, well, I have 11 never really given --1 have never given a man a 12 massage, did you tell her that? 13 A. No. 14 Q. And have you ever given a boyfriend a 15 massage, did I ask you that? 16 A. You did ask me that. 17 Q. Okay. You were, you were — had, already 18 at that point in your time, 2004, had had 19 relationships with other males, true? 20 A. Yes. 21 Q. Okay. And you were sexually active at 22 that point in time, true? 23 A. Yes. 24 Q. All right And you had never given a male 25 a massage? Page 97 1 Q. Okay. And what, what in, at least in your 2 thinking process at that time would cause you even 3 to Nth that you might have some interest in doing 4 that, that is, going to give some unknown person, 5 unknown to you, at their home a half-hour massage 6 for 200 bucks? 7 M.R. MERMELSTEN: Objection to form. 8 THE WITNESS: Can you repeat that? 9 MR. CRITTON: No, but Cindy can. Cindy 10 will. She can and will. 11 THE WITNESS: Okay. 12 (The requested portion of the record was 13 read by the reporter.) 14 THE WITNESS: So you want to know my 15 interest? 16 BY MR. CRITTON: 17 Q. Yeah, why, why — why you, who is 18 apparently about 16 at the time would have any 19 interest in giving a massage to some unknown male 20 that you had never met, a half-hour massage which 21 you didn't know what it consisted of, for 200 bucks? 22 A. I was young and it was $7.00. 23 Q. And if I understood your earlier 24 testimony, you didn't say, well, Et have you 25 dame it? 25 (Pages 94 to 97) PROSE COURT REPORTING AGENCY, INC. EFTA01104177 Page 214 anything improper or otherwise. 2 Is there — what, if anything, has caused 3 you now that we have finished about an hour or 4 45-minute lunch break that maybe June of'04 was not 5 the right date, approximately, that you went to 6 Mr. Epstein's home for the first time? 7 A. Okay. 8 THE VIDEOGRAPHER: You're fine. 9 THE WITNESS: Okay. Just thinking about 10 it, like, I don't want, I don't want to matte 11 exact dates and may be wrong. 12 BY MR. CRITTON: 13 Q. Could it have been *05? 14 A. It could have been, yes. 15 Q. Would it have been before your birthday in 16 '05 for the first time, or could it have been 17 afterwards? 18 A. After, I think. 19 Q. Okay. 20 A. I don't know. 21 Q. So all you know is that you went to 22 Mr. Epstein's home four times. It could have 23 started in '05. It could have started in '04. You 24 just can't tell us as you sit here today? 25 A. Right, I can't tell you exact dates. Page 215 1 Q. Okay. And you can't tell us — I mean, 2 there's nothing about — well, there, there was. 3 You said that one of the visits you had you 4 remembered seeing a — some sort of Christmas 5 decoration. 6 A. Correct. 7 Q. Okay. And instead of being in 8 December-ish of'04, assuming that's when Christmas 9 decorations come out, it could have been as well 10 December of '05. Is that possible? 11 A. I don't know. 12 Q. Well, Pm asking you, is that possible, it 13 could have been December of '05 as distinct from 14 December of'04, or you just don't know one way or 15 the other? 16 A. I just know that it was around Christmas one 17 of the times. 18 Q. But you can't tell me whether it was '04 19 or '05? 20 A. Correct. 21 Q. Because you don't remember when the first 22 time was? 23 A. Correct. 24 Q. And that could have been sometime in — 25 after your 16th birthday. Could have even been Page 216 1 after your 17th birthday. You just don't remember? 2 A. I first visited Jeffrey, like I stated before, • 3 soon after I turned 16. 4 Q. Okay. But we established just by simple 5 math — 6 A. I'm not a math genius. 7 Q. None ails arc, that's why we Gan I. M. 8 if l add 16 to MI because you were born in M. 9 that takes me to 2004, Mardi of 2004. Ail rig t:. 10 I'm not hying to be tricky here. I'm hying to • 11 would you agree with me, 16 and IN is 12 A. Sixteen, yes. 13 Q. All right. So if it MS Sal/clime after 14 that, then it had to have been in '04, or do you 15 want to say it still could have been '05? 16 A. 'still say it was alter I was 16. 17 Q. Okay. And it still could, could have been 18 in '04; it could have been in 'OS. You're just not 19 sure? 20 A. Correct 21 Q. All right. Okay. So let's just stick with 22 the first Umiak& So they — I know you, you 23 told us that =asked if you wanted to go. You 24 were with Jane Doe No. 4 only. You were at Jane Doe 25 No. 4's house, just the three of you. You said Page 217 1 you'd think alugatiaiwient back. You talked 2 about it with IMeho was your boyfriend 3 at that time. He basically said, he discouraged 4 you, as you described earlier, comet? 5 A. Yes. 6 . Then sometime later there, now you i 7 and were either between, either weren't dating 8 anymore or you were — I think you said yigialaren't 9 dating anymore, so somebody — was that Mlagain 10 asked you then again? 11 A. Yes 12 Okay. And where were you at the time 13 =asked you? 14 A. I don't remember. 15 Q. All right. And when she asked you, do you 16 remember whether anyone else was there at the time? 17 A. I don't remember. 18 Q. And did — what did she say to you? 19 A. Do you want to make 5200 and give a guy a 20 massage, or Jeffrey a massage. 21 Q. And you said — did you say something 22 like, we talked about this before, I said, no? 23 A. No. 24 Q. Okay. What did you say this time? 25 A. I'll call you back. nit get back to you, 10 (Pages 214 to 217) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins dalled07-Otte4c7a-95e1-dadtiebkf35 EFTA01104178 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 218 something along that line. Q. And what happened then? A. I agreed to do so and she set it up. Q. Did you, did you call her or did she call you or did you just see her again? A. She initiated it Q. Okay. What, she called you or did she see you? A. She called sm. Q. Okay. And is, and as far as you, you were concerned is that at least you were going to go there, give this Jeffrey chap a massage, and that was the extent of the conversation? A. At first, yes. Q. When you say "at first," you mean at least, at least from the first time she told you — A. Yes. Q. — the second time? A. Yes. Q. Okay. And even when she spoke to you on the phone, she basically said — or let me say it, the first time she asked you if you want, you were, when you were at Jane Doe No. 4's house, if you wanted to go give this — give Jeffrey a massage for 200 bucks, that was the extent of the conversation, Page 220 1 that you had had. She had set it up and she said, 2 okay, we're going to go at such-and-such a time. 3 And that's all she had said to you at least up until 4 the time that she picked you up? 5 A. Cared. 6 Q. Okay. That is the phone conversations, 7 that is the in-person conversations, time one, when 8 you decided no; the second time you said, I'll think 9 about it the third time is you called her back and 10 said, it's okay,FIldo it; and the fourth time is, 11 she said — she calkd you back and said, okay, l 12 set it up for such-and-such a time and I'll pick you 13 up at such-and-such a time. Is that substantially 14 correct, or correct? 15 A. She asked me the first time. I had spoken 16 with my boyfriend, so no. And then she asked me the 17 second time, I told her rd to think about it. I agreed 18 to it, she set it up. 19 Q. Okay. So second time you did — I thought 20 you said you, you told her you'd think about it. 21. A. I said I would think about it, and that I 22 agreed to it. 23 Q. The same — 24 A. The second time. 25 Q. Right there at the second occasion that Page 219 1 correct? 2 A. Yes. 3 Q. Okay. The second time that she mentioned 4 it, again, it was pretty similar as it was give this 5 Jeffrey chap a massage, 200 bucks? 6 A. Yes. 7 Q. If you want to do it. And you said, I'll 8 think about it? 9 A. Yes. 10 Q. You called her back and said, rit do it? 11 A. Yes. 12 Q. Okay. And then she said, okay, P11 let 13 you know? 14 A. Shell set it up. 15 Q. All right And so at least at that time, 16 when you talked to her on the phone and she then 17 called you back and set it up, as far as you were 18 concerned at that time you were going to give a 19 half-hour massage for 200 bucks? 20 A. Yes. 21 Q. And that was the extent of the 22 conversation or, at least, the two conversations and 23 the two phone calls that you two had had? 24 A. At that — what do you mean? 25 0. That was the extent of the conversations Page 221 1 she mentioned it to you? 2 A. Right 3 Q. You didn't call her back? You said -- 4 A. No, I — 5 Q. You thought about it right then and there? 6 A. No, I called her back. 7 Q. Okay. That's what rm getting at. 8 A. Yes. 9 Q. And you called her back and said this was 10 what, a two, a ten-second conversation, and said, 11 okay, ru do it? 12 A. Then she said she'll -- 13 Q. Yes? First of all, is that yes? 14 A. Yet 15 Q. It was like a second ten-second 16 conversation? 17 A. Yes. 18 Q. And then she called you back for another 19 ten-second conversation that said, okay, I have set 20 it up for such-and-such a time, and I'll pick you 21 up? 22 A. Yes. 23 Q. Okay. And that was the extent of the 24 conversation, just basically a scheduling issue? 25 A. Correct 11 (Pages 218 to 221) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hooking Electronically signed by cynthia hopkins Electronically signed by Cynthia hopkins da88od07-Occo-4c7a-95ol.d4dVlob3cf36 EFTA01104179 Page I 4 2 1 THE WrINESS: Could you restate that? 2 BY MR. CRITTON: 3 Q. Sure. You said before you went to 4 r or.n.tein's the first time, you learned or heard 5 that she and Mr. Epstein had gotten into a 6 disagreement, correct? 7 A. Yes. 8 Q. Okay. Did you ask her what the nature of 9 the disagreement was? Because you wouldn't want to 10 go to someplace where you might have a disagreement, 11 right? 12 A. Coned. 13 Q. All right. And what did she say to you 14 when you asked her? 15 A. She said that it was in regards to her, her 16 not getting paid. 17 Q. She didn't get money or — 18 A. Correct. 19 Q. — it was either she didn't get paid or 20 didn't get the right amount? 21 A. She didn't get — that she wasn't going to get 22 paid. 23 Q. Okay. Did she tell you why she wasn't 24 going to get paid? 25 A. Something to do with a question that he had 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 144 BY MR. CM-TON: Q. Because if any of those four people, li ad Jane Doe No. 4, Jane Doe No. 7 or said anything that would have caused you any concern, would it be a correct statement you, more likely than not, would not have gone? MR. MERMELSIE1N: Objection to form. THE WITNESS: Yeah. BY MR. CRITTON: Q. All right. Because they were friends of yours? A. Yes. Q. All right. And if something bad had happened or something inappropriate had happened, at least from their perspective you would have expected them to tell you that, wouldn't you? A. Yes, I did. Q. All right. And none of those four friends of yours told you anything or disclosed anything to you that caused you any concern; is that correct? A. Correct Q. And if you felt that they had misled you in any way, you would have been angry with them, wouldn't you? A. Yes. Page 143 1 asked her, and she just — !guess she didn't like it 2 and they got into a little disagreement 3 Q. Okay. And did you, did you then think to 4 yourself as, gee, you know, I could go over them, 5 give a massage and not ..paid because I could get 6 into a disagreement like did, or did she make 7 it out like it was really no big deal? B A. She made it seem like it was not a big major 9 concern. 10 Q. Okay. And Jane Doe No. 4, what did Jane 11 Doe No. 4 did she ever indicate that you should 12 have any hesitation going over to Mr. Epstein's 13 home? 14 A. No. 15 Q. All right. And ME, did she ever 16 indicate to you that you should hesitate to go over 17 to Mr. Epstein's home? 18 A. Not really, no. 19 Q. Okay. So had Jane Doe Na 4, Jane Doe 20 No. 7, M. and ME who all, at least from your 21 perspective, led you to believe that your going to 22 Mr. Epstein's home was not a problem, no big deal, 23 safe, true? 24 A. True. 25 MR. fvfERMELSTEIN: Objection to form. 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 145 Q. After you came back from Mr. Epstein's the first time, did you ever talk with Jane Doe No. 4, that is shortly after you were there the first time, about what had occurred? A. No. Q. All right. Did you ever suggest to her that she had in any way misled you or lied to you or deceived you — A. No. Q. — about her experiences with Mr. Epstein? A. No. Q. Did you ever say anything within a short period — and a short period could be a day, it could be a week, it could be a month, it could be six months. Did you ever talk with M. and tell her what had occurred at Mr. EpsteiWi? A. I don't remember. Q. Okay. Did you ever express anger with her or, or did you ever tell her that she had in some way deceived you or misled you? A. No. Q. Or lied to you? A. No. Q. Okay. Within a short period of time again, you know, a day to six months, did ou ever 37 (Pages 142 to 145) PROSE COURT REPORTING AGENCY, INC. EFTA01104180 Page 222 Page 224 1 Q. All right. You've never spoken with 2 Mr. Epstein or anyone who works on his behalf by 3 phone, have you? 4 A. No. S Q. Okay. Mr. Epstein or anyone on his behalf 6 has never twitted you, have they? 7 A. No. 8 Q. Okay. Has anyone, has either Mr. Epstein 9 or anyone on his behalf corresponded with you or 10 communicated with you by way of e-mail or over the 11 computer? 12 A. No. 13 Q. Okay. Has Mr. Epstein or anyone on his 14 behalf ever communicated with you by text messages 15 or any other type of, you know, electronic 16 communication? 17 A. No. 18 Q. sikAght. So, all right. First time you 19 turned down. Second time you said you'd think 20 about it. I think you told me in the interim you 21 had, you'd known — you had known that Jane Doe No. 22 4 had been there. Isu knew Jane Doe No. 7 had been 23 there S know. had been there. And you knew 24 that had been there, but you didn't know if 25 she had done anything, ever given a massage; is that 1 Q. AliridtDdyOUever 2 before did come to pick you up that day, 3 whatever the first day is you went to Mr. Epstein's 4 house? 5 A. She picked me up, yes. 6 Q. Okay. And when she picked you up, was it 7 in her cat? 8 A. Yes. 9 Q. Do you remember what kind of car she had? 10 A. It was a truck. 11 Q. Okay. 12 A. A maroon truck. 13 Q. All right. And when she before you got 14 in the truck, did you look in and say well, let 15 me ask you this: What did you have on? Mot were 16 you wearing? 17 A. A skirt and a shirt. 18 Q. And under that you had your bra and your 19 boy shorts? 20 A. Yet 21 Q. All right. And what did the sldrt look 22 like? 23 A. Like a jean sldrt. 24 Q. Short, long? 25 A. Yeah, fingertip length. Page 223 1 correct? 2 A. Yes. 3 Q. All right. But you how that s, Jane 4 Doe No. 7 had been there, and Jane Doe No. 4 had 5 been there, and none of them expressed to you, 6 either by outward signs that you saw or anything 7 verbally that would have caused you any concern; is 8 that a fair statement? 9 A. Yes. 10 Q. Okay. Before you got in the car — okay, 11 so at some point you knew that Jeffrey was in — 12 lived in Palm Beach. 13 A. Yes. 14 Q. Did you know that before you went? 15 A. That he lived in Palm Beach? 16 Q. Yes, ma'am. 17 A. Yes. 18 Q. All right. And you knew, did you know 19 anything about his age at that time? 20 A. No. 21 Q. Okay. Did you know, did you think he was 22 your age, or did you think he was older, or... 23 A. I don't know. 24 Q You just — okay. 25 A. I had no idea. Page 225 1 Q. Okay. And your shirt? 2 A. I don't remember what shirt I was wearing. 3 Q. Lace a tank top or a crop top, or was it 4 a - 5 A. No, it was a, it was a regular shirt. 6 Q. Lake a blouse — 7 A. Yes. 8 — shirt? Before you got in the car, 9 pulls up in her truck. Before you get in the 10 truck did you say, do I look okay? 11 A. No. 12 Q. Okay. Did — did you say is, you 13 how, I've thought about this, tell me a little bit 14 more about what Pm doing for 200 bucks? 15 A. No. 16 Q. Had you ever mark 200 bucks for a 17 half-an-hour's work before? 18 A. No. 19 Q. Okay. Had anybody ever paid you 5200 for 20 doing an hour, a half hour or an hour or two-hours 21 worth of work? 22 A. Yes. 23 Q. Doing what? 24 A. Regrouting tables. 25 O. Regroutin2 tables. E lain that for me. 12 (Pages 222 to 225) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cyntNa hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins datad07-Oca-4e7s45•1414.121•1:40135 EFTA01104181 Page 18 1 Q. All trying to do is, is ifs your best recollection that you remember when you went to 3 Mr. Epstein's house, approximately June of 2004, 4 henanse you got a used 2006 Toyota Corolla, correct? A. I got a 2006 Toyota Corolla for my 16th 0 birthday. 1 Q. Okay. And you got that at what, 8 approximately three months after your 16th birthday? 9 A. I got it on my 16th birthday. 10 Q. At -- okay. And did you go and get your 11 driver's license on your 16th birthday or did you 12 have a learner's permit? 13 A. I had a learner's permit. 14 Q. So you could drive that car with someone 15 else? 16 A. Yes. 17 Q. And who gave you the ear? 18 A. My mother. 19 Q. Okay. And any strings attached to it; 20 that is, did you have to pay the insurance? Did you 21 have to pay for the car? Did you have to make any 22 payments? 23 A. I paid $1,000 down payment, and I paid for the 24 car. 25 Q. Okay. And what did your mom pay for it? 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 20 you recall what approximate date that was? Or if you want to use approximately X-time after June of '04, that's okay too. A. I don't remember. Q. How about the third time? A. About close to Christmas. Q. And what makes you recall that, that it — A. Decorations. Q. — that it was close to Christmas? A. Decorations. Q. Okay. You mean, just decorations around town or decorations — that is, where did you see decorations that makes you remember the third time you were at his home? A. On a gate. Q. On his gate? A. On a gate. Q. On just a gate when you were going, headed that way? A. Yes. Q. All right. And then the fourth time was approximately when? Was it after Christmas? A. Yes. Q. Approximately how long after? A. It was hot outside, maybe spring, summer. Page 19 1 She obviously -- the got you the car? 2 A. I put the $1,000 down payment. She took care 3 of the rest. 4 Q. Oh, okay. So you put 1,000 and your mom 5 paid off for the, the remaining balance of the 6 vehicle, of the car? 7 A. Well, she bought it from the bank, so... 8 Q. All right, but she paid it? 9 A. Uh-huh. 10 Q. Yes? 11 A. Yes. 12 Q. An right. So, from your 16th birthday on 13 you were able to drive a call 14 A. Yes. 15 Q. Okay. Let me go back then to the police 16 statement. The police statement that you gave in 17 the Epstein — well, let me strike that. 18 You were at Mr. Epstein's home on, 19 you say approximately June of 2004. And I think you 20 went on how many additional occasions to his home? 21. A. I were a total of four times. 22 Q. And were they within a short period of 23 time, or were they over a length of time? 24 A. A length of time. 25 Q. And what - for going the second time, do Page 21 1 Q. And that would have been of '05? 2 A. Correct. 3 Q. So If — of the four times that you went, 4 last being approximately sprinWsummer of '05 based 5 on your testimony, how much after that period or how 6 long a time period transpired before you spoke with 7 the police, or do you just not have any 8 recollection? 9 A. I don't remember. 10 Q. And you don't remember whether you spoke 11 to the police in '05 or '06 or '07; is that a 12 correct statement? 13 A. Correct. 14 Q. And I think part of my question was 15 you indicated I think you've seen the police 16 statement approximately two or three times? 17 A. Correct. 18 Q. Okay. Did you read the entire statement? 19 A. Yes. 20 Q. Okay. Did you see was anything, do you 21 know, if I use the word "redacted," do you know what 22 that means? 23 A. No, sir. 24 Q. Something's crossed out. 25 A. Yes, I saw that. 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. EFTA01104182 Page 174 1 BY Nill. CRITTON: 2 Q. All right. Let me go back I., okay. 3 At the time that Mr. Epstein, at least based on what 4 you testified earlier today, is because Mr. Epstein 5 did touch your breasts -- well, in fact, I should 6 probably clear up one thing. He only touched you in 7 the vaginal area, from what you've testified to 8 today, is over your boy shorts, correct? 9 A. Yes. 10 Q. And you have said that there was never any 11 penetration? 12 A. Correct. 13 Q. Okay. You never touched any of his 14 private parts, true? 15 A. Correct. 16 Q. Okay. You never had any kind of 17 intercourse? 18 A. No. 19 Q. All right Never had oral sex? 20 A. No. 21 Q. He to you, you to him, correct? 22 A. No. 23 Q. Any type of other — no type of sexual 24 contact whatsoever? 25 MR. MERMELSTEIN: Objection, form. 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 176 THE WITNESS: Yes. BY MR. CRITTON: Q. Okay. And what kind of a friend, at least with Jane Doe No. 2, what kind of a friend exposes another good Mend to a shocking, disturbing, emotionally disturbing event? MR. MITRMEISTEN: Form, argumentative, rhetorical. BY MR. CRITION: Q. Why did you do that? A. I don't know. Q. Okay. You abo did that ta, coned? A. Yes. Q. Okay. Why did you do that with..? A. I don't know. MR. CRITTON: Let's go about ten more minutes, and we'll take a break. Okay? MR. WEIN: All right. Is that okay? ME WITNESS: (Witness nods head.) MR. MERMELSTEIN: Okay. BY MR. CRITTONL. Q. Did you tell., what Did you tell her what you had tot Page 175 1 BY MR. CRITTON: 2 Q. That is, your, your sexual organ with one 3 of his sexual organs; that never occurred, correct? 4 A. You're asking me if I've had sex with him? 5 Q. No. None of your sexual organs ever came 6 in contact with his sexual organs, true? 7 A. Correct. 8 Q. All rig o, again, what — based on 9 what you told that he did touch your breasts, 10 and that you did take your shirt and your skirt off 11 but left on your bra and your boy shorts, that you 12 were in shock and emotionally disturbed at what 13 within — at the time, and then you told 14 Within an hour how upset you were, you also 15 took Jane Doe Na 2 there, correct? 16 A. Yes. 17 Q. All right. And was Jane Doe No. 2 a good 18 friend of yours, then? 19 A. Yes. 20 Q. All right So despite this, I'd say, 21 shocking incident to you, you were willing to expose 22 your friend Jane Doe No. 2 as well to, at least 23 based on your testimony, to this shocking, 24 disturbing experience that you had had, true? 25 MR. MERMELSTEIN: Form. 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 177 A. Not exactly. Q. But did you tell her she might be asked to take off her clothes? A. And that you don't have to, yes. Q. All right And you said you, you may be asked to take off your clothes, but you don't have to? A. Yes. Q. Okay. And did you say he might try to touch you, but if he does, just tell him you're not comfortable? MR. MERMELSTEIN: Form. ME WITNESS: Can you — BY MR. CRITTON: Q. Yeah. Did you, did you tell her as well, is if he tries to touch you, just tell him you don't feel comfortable? MR. MERMELSTEIN: Form. ME WITNESS: I told her if he tries to do anything, you can say no. BY Mt. CRITTON: Q. Okay. And, and then he will stop? A. Yes. Q. Okay. And did you tell Jane Doe No. 2 the same thin -- 45 (Pages 174 to 177 PROSE COURT REPORTING AGENCY, INC. EFTA01104183 Page 258 1 Q. En house? 2 A. Yes. 3 Q. Okay. And, and what did you do there? 4 A. Get ready to go out or do something. I don't 5 remember. 6 Q. Did you go out that night? 7 A. We did. I don't ;mow. 8 Q. Did something? 9 A. I don't remember. We did something. I don't 10 remember. 11 Q. The three of you did something? 12 A. We did something. 13 Q. Okay. Do you remember what you did with 14 the money? 15 A. No. 16 Q. Okay. Did you buy anything, or you just 17 don't remember one way or the other? 18 A. I bought a beer. 19 Q. All right. Usually beers aren't 200 20 bucks. 21 A. Right. 22 Q. Especially in — all right. And you don't 23 remember what you did with the rest of the money? 24 A. No. 25 Q. The, the next time you went, I think you Page 260 1 there the first time, but you don't recall seeing 2 her either the second or the third time but only the 3 fourth time when you took her? 4 A. Correct. 5 Q. And when you took Jane Doe No. 2 the 6 second time, you already described for me, so I 7 won't belabor it as to say what your c,onvefrigMn 8 was with both Jane Doe No. 2 and as wellW 9 Remember we talked about that a little earlier? 10 A. Yes. 11 THE VIDEOGRAPHER: Sir, you're covering 12 your microphone. 13 BY MR. CRITFON: 14 Q. We talked about that earlier, correct? 15 A. Yes. 16 Q. Okay. So when you, when you took Jane Doe 17 No. 2 the second time, did you pick her up? 18 A. Yes. 19 Q. And did you pick her up in your 2006 20 Toyota Corolla? 21 MR. MERMELSTEIN: Objection to form. 22 THE WITNESS: I picked her up in my car, 23 yes. 24 BY MR. CRITTON: 25 Q. Which was the 2006 Toyota Corolla? Page 259 1 said, was the next time you went around the 2 Christmastime date, or did you go the second time 3 before Christmas? 4 A. Maybe around -- I don't know. I don't 5 remember. 6 Q. And do you remember who, how it was that 7 you went the second time? 8 A. I don't remember. 9 Q. Okay. Do you remember who you went with 10 the second time? 11 A. I believe it was with Jane Doe No. 2. 12 Q. Okay. Jane Doe No. 2? 13 A. Yes. 14 Q. So your recollection is you went with Jane 15 Doe No. 2 the second time, just the two of you? 16 A. Yes. 17 Q. Okay. Did Jane Doe No. 4 go with you the 18 second time? 19 A. I don't remember. 20 Q. Did, did Jane Doe No. 4 ever go with you 21 again? 22 A. Yes. 23 Q. Okay. When did she go with you again? 24 A. When I took her. 25 9. So our recollection is that she, she was Page 261 1 MR. MERMELSTEIN: Form. 2 THE WITNESS: Or I don't know what year it 3 was. I don't remember. 4 BY MR. CRITTON: 5 Q. Pm just — Pm telling you what -- I'm 6 repeating back what you told me earlier today. 7 A. Well, I think I'm going to correct you. I 8 think it was an older model, model than that. 9 Q. Okay. So, anyhow, you picked her up in 10 your car? 11 A. Yep. 12 Q. And when you got in the car did you say, 13 did you say anything else to her other than what you 14 told early, told me earliathat you said to both 15 Jane Doe No. 2 and toa. about him maybe asking 16 you to take your clothes off, him asking you that he 17 may try to touch you, and do what you feel 18 comfortable with? 19 A. That you're not allowed to talk to hint 20 Q. Okay. Anything else? 21 A. Not that I remember, no. 22 Q. Okay. And when you got over there, how, 23 how were the arrangements made for you to bring Jane 24 Doe N there? 25 A. 21 (Pages 258 to 261) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins dattEted07-0ece-4e7s-95•1-d4d2lobitt35 EFTA01104184 Page 262 1 Q. Well set it up? 2 A. Yes. 3 Q. Okay. But you're sure she didn't go with 4 you? A. I believe so. 6 Q You don't believe? 7 A. I do believe so. 8 Q. You, you believe she did not go? 9 A. Correct. 10 Q. Okay. So, so you get over there. You 11 drive over to the same location. Did you remember 12 how to get there, or did you have to get directions? 13 A. I don't remember. 14 Q. And when you got over there -- but somehow 15 you got over there. And did you go in the same 16 entrance again? 17 A. Yes. 18 Q. Okay. And when you were there, what did 19 you do? That is, you parked your car. Did you pull 20 into the driveway? 21 A. Yes. 22 Q. Did you go in the side door again? 23 A. The ldtchen. 24 Q. The kitchen. And when you get into the 25 kitchen, who was there on this occasion? 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 264 Q. Did she at any time say to you, you know, I don't think I really want to do this? A. No. Q. Okay. Did you ever discourage her from doing it? A. Not that I remember. Q. Okay. I think you already told me earlier is despite the fact that you were shocked, were emotionally disturbed, that you thought it was a terrible experience, you still took Jane Doe No. 2? A. Yes. MR. MERMELSTEIN: Objection, asked and answered numerous times. BY MR CRTITON: Q. So, you go up — so she goes upstairs. How long was she upstairs? A. I don't know. Q. What did you do when you were downstairs? A. Hang out in the kitchen. Q. Did you have anything to eat, drink? A. No. Q. Just hung in the kitchen? A. (Witness nods head.) Q. All right. THE COURT REPORTER: That's ayes? 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. • Q. A. Q. A. A. house. Q. A. Q. Q. Q. house? A. Yes. Q. Okay. But not that occasion? A. Correct. Q. So somehow Jane Doe No. 2 got upstairs? A. (Witness nods head.) Q. Yes? A. Yes, I don't -- Page 263 The chef. Anyone else? The housekeeper. Okay. Do you remember what her name was? I was never -- He or she, was it a he or she? It was a her. All right. And what happened, then? I got let in the house. We went into the Who went upstairs with Jane Doe No. 2? I don't remember. Did you go? No. Okay. Because you never went up again? Right Did you ever see Mr. Epstein again at his ..µ.1 .irmewa.s.n“.44)440100.8041411Silal arn• Page 265 1 TIE WITNESS: Yes, sorry. 2 BY MR. CRITTON: 3 Q. Okay. Anything else happen? Anything 4 else unusual, usual, or you just hung in the 5 kitchen; you waited for her to come back? 6 A. Correct. 7 Q. Okay. And she comes back downstairs? 8 A. Yes. 9 Q. And do you leave? 10 A. Yes. 11 Q. Okay. Did you see anyone else? 12 A. Not that I remember. 13 Q. Okay. So you get back in your car and 14 where did you two go? 15 Well, in fact, before that is, did you 16 receive any money for bringing, having brought Jane 17 Doe No. 2 there on the second occasion? 18 A. Yes. 19 Q. And who gave you the money? 20 A. I don't remember who gave it to me. 21 Q Do you know how you got the money? Was h 22 handed to you? Did you get it when you were there? 23 Did you — 24 A. I don't remember. 25 Q. So, but how much did you • 22 (Pages 262 to 265) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins da88ed07-Occe-4c7a-9501.d4d2leb3c135 EFTA01104185 Page 266 1 A. A hundred. 2 Q Did Jane Doe No. 2 know that you had 3 received money for taking her there? 4 A. Yes. 5 Q. Because you told her? 6 A. Yes. 7 Q. You got back in the car. Did Jane Doe No. 8 2 say anything to you? 9 A. Not that I remember. 10 Q. All right. And so you drove where? Where 11 did you go after that? 12 A. I don't remember. 13 Q. Did you go back to anybody's house? Did 14 you go out that night, or do you have any 15 recollection? 16 A. I do not remember what we did after. 17 Q. All right The, the third time you went, 18 you took who, M.? 19 A. Yes. 20 Q. All right. And did anyone go with you on 21 that oc asion? 22 A. No, I went by myself. 23 Q. Okay. You're sure neither nor, 24 excuse me, Jane Doe No. 4 went with you? 25 A. Yes, I'm sure. Page 267 1 Q. And how did you make gements to take 2 your -- one of your best friends,, there? 3 A. 4 Q. All right And when you, did you 5 basically follow the same procedure you had with 6 Jane Doe No. 2; that is, you drove to the house. 7 You went in the kitchen? 8 A. Yes. 9 Q. Okay. Was anybody there at that time in 10 the kitchen? 11 A. No. 12 Q. Okay. So you're in the house. How did 13 you get in the door or was it open? 14 A. No. Some -- the, the chef was always there. 15 Q. All right. So the chefs in the kitchen. 16 Did he open the door for you? 17 A. Yes. 18 Q. Okay. So the two of you come in? 19 A. Yes. 20 Q. All right. And do you remember what.. 21 had on? 22 A. No. 23 Q. Okay. Do you remember what you had on? 24 A. No. 25 9. so, you sit in, you — did you recognize Page 268 1 the cook? 2 A. I don't remember. 3 Q. Do you know whether it was the same cook? 4 A_ No. 5 Q. So you both go into the kitchen. Other 6 than the cook, was anybody else there? This is now 7 the third visit. 8 A. No. 9 Q. So, how did M. get upstairs to give the 10 massage? 11 A. I don't remember who took her up. 12 Q. You don't remember seeing anybody else 13 other than the cook, though, at least before she 14 went upstairs, correct? 15 A. Correct. 16 Q. All rig,ht. And I think, again, so as not 17 to repeat it, what you told me earlier about Ms.— 18 taking s and what you told Jane Doe No. 2, that 19 would apply to what. you had told her going, up until 20 the time she went upstairs, correct? 21 A. I'm confused on what you're saying. 22 Q. Well, we talked — I don't want to have to 23 repeat &valise Stuart will object as I'm being 24 repetitious, so when we talked about what you had 25 told — Page 269 1 A. Oh, yes. 2 Q. -- about everything, you know, what to — 3 what to, in essence, what to expect, you, you, I 4 don't need to repeat that -- S A. Yes. 6 Q. -- correct? 7 A. Yes. 8 Q. All right. And did you tell, did you tell 9 either of them if you're asked your age to tell them 10 you're 19? 11 A. No. 12 Q. Had you told either one of them then? 13 A. No. 14 Q. All right. Do you know how old Jane Doe 15 No. 2 was at the time you took her? 16 A. No. 17 Q. Do you know how old.. was when you took 18 her? 19 A. No. 20 Q. Were they approximate — were they in your 21 age, in your class at school? And I think you said 22 Jane Doe No. 2 was. 23 A. Jane ae No. 2 was, yes. 24 Q. Was M. older? 25 A. Yes. 4.4•0414...1 .0••••••••••••••••••Sa". 23 (Pages 266 to 269) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins daSeed07-Occe-4c7a-95el-d4d2leb3c136 EFTA01104186 Page 2 APPEARANCES: Oa behalf of the Plaintiff: STUART S. MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, PA 18205 Biscayne Boulevard Suite 2218 Miami, Phone: On behalf of the Defendant ROBERT D. CRITION, IR, ESQUIRE BURMAN, CR1TTON, LUTHER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 Phone: E-mail: West 'de 33401 ALSO PRESENT: Sesdm Quimby, Vidcographer Visual Evidence, Incorporated 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 4 PROCEEDINGS Deposition taken before Cynthia Hopkins, Registered Professional Reporter, Florida Professional Reporter, and Notary Public in and for the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is the 19th day ot February, 2010. The time is 10:07 a.m. This is the videotaped deposition of lane Doe No. 3 in the matter of Jane Doe No.2 versus Epstein. This deposition is being held at 250 Australian Avenue South, West Palm Beach, Florida My name is Sascha Quimby. I am the videogmpher representing Visual Evidence, Inc. Will the attorneys please announce their appearances for the record. MR. MERMELSTEIN: Stuart Mermelstein for Plaintiff Jane Doe 3. MR. CRITTON: Bob Critton on behalf of Jeffrey Epstein. Thereupon, (JANE DOE NO.3) having been first duly sworn or affirmed, was examined and testified as follows: Page 3 INDEX EXANENATION DIRECT CROSS REDIRECT JANE DOE NO.3 BY MR. CRITION 4 EXHIBITS EXHIBIT DESCRIPTION PAGE DEFENDANTS EX. I 115 PSYCHOLOGICAL/SOCIAL HISTORY FORM DEFENDANTS EX. 2 170 SECOND AMENDED COMPLAINT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Page 5 THE WITNESS: Yes. DIRECT EXAMINATION BY MR. CRITTON: Q. Would you please tell me your full name. A. Jane Doe No. 3. Q. Give me our date of birth, please. A. Q. And do you know your Social Security number? A. 111111111. Q. Ms. Jane Doe No. 3, have you ever had your deposition taken before? A. Yes. • Q. When? A. From the police department. Q. That was a sworn statement? A. Okay. So then, no. Q. Was there a court reporter there that took it or was it — 20 A. No. 21 . Q. In what fashion did you give a sworn 22 statement to the police department? 23 A. Explain further. 24 Q. What were the circumstances of your giving 25 a sworn statement? Jcomm4.1......Crai,A,ftiValliwieinseNwaiftWf,MWINI,Mw011ign, =======WOCOMAI. 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. EFTA01104187