UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092, DEPOSITION OF JANE DOE #7 - VOLUME I (videotaped) Monday, March 15, 2010 10:02 - 6:49 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RMR, CRR Notary Public, State of Florida EXHIBIT B Original PROSE COURT REPORTING AGENCY, INC. EFTA01104222 Page 66 1 was like a long time ago. I don't -- 2 Q. 3 A. 4 Q. 5 A. 6 Q. 7 A. 8 Q. 9 to Mr. Epstein's house or during the time that you were 10 going to Mr. Epstein's house that you saw him jogging on 11 the beach? 12 A. I don't exactly remember when it was. I think 13 it was when I was still going. 14 Q. Okay. So the only time that you've ever 15 spoken with Mr. Epstein outside of his home would have 16 been the one time you saw him out jogging on the beach 17 and you were at the beach over in Palm Beach, correct? 18 MR. HOROWITZ: Form. 19 THE WITNESS: Yeah, I thought I saw him in Key 20 West once, but I wasn't sure that was him. But 21 yeah, other than that, yes. 22 BY MR. CRITTON: 23 Q. Okay. You have never traveled with And you talked to him? Yes. He said "Hi, how are you?" Uh huh. Yes? Yes. And did you, was that after you stopped going 24 Mr. Epstein? 25 A. No. PROSE COURT REPORTING AGENCY, INC. EFTA01104223 Page 67 1 Q. And Mr. Epstein has never flown you or asked 2 you to travel anyplace, has he, where you traveled? 3 A. No. 4 Q. That's correct? 5 A. Yes. 6 Q. All right. First time, at least what you told 7 the police officers, your best recollection is that you 8 went over there with ., you went upstairs, and you 9 gave Mr. Epstein a massage, correct? 10 A. Yes. 11 Okay. And during the course of the massage, 12 you kept your clothes on, true? 13 A. I believe that's what I told them. 14 Q. All right. And you also told the police that 15 at no time did he try to touch you or did he touch you, 16 correct? 17 A. I told them that he did try to touch my butt. 18 Q. Okay. He did try? 19 A. Or he did, I think I said. 20 Q. What's the difference between trying and 21 touching? 22 A. I don't exactly remember the words I said. I 23 think I did tell them that he did. 24 Q. So it's now your testimony that you recall 25 telling the Palm Beach Police Department that he did PROSE COURT REPORTING AGENCY, INC. EFTA01104224 Page 106 1 asked . if you could go to Mr. Epstein's? 2 A. . asked me twice, and then asked me 3 from then on. So I never asked III. to go. 4 Q. Okay. Did you ever make a call to 5 A. No, would always call -- 6 MR. HOROWITZ: Let him finish. You know what 7 each other is going to say, but let him finish. 8 BY MR. CRITTON: 9 Q. Did you ever make a call to 10 A. No, not that I could remember. 11 Q. And if called you, she basically said, 12 in essence the conversation was "Would you like to come 13 over today?" 14 A. Yeah, she asked me what my schedule was and 15 when I had school and classes and like what days I could 16 come. 17 Q. And that was the extent of the conversation, 18 it was strictly a scheduling? 19 A. No, and she asked me if I knew anybody too 20 that I would want to bring for a massage. 21 Q. Okay. And that was the extent of the 22 conversation, at least as to you? Whatever 23 conversations you had with , she may have called 24 you on the phone and she said basically is what's your 25 schedule? Can you come at a certain time, or what times (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. EFTA01104225 Page 346 1 Q. Okay. So if she was doing cocaine or ecstasy 2 or xanax, again, you never saw it? 3 MR. HOROWITZ: Form. 4 THE WITNESS: No. My friends knew I didn't do 5 it, so some of them would try to hide it or not do 6 it around me. So I never really saw them, whoever 7 did what. 8 BY MR. CRITTON: 9 Q. I think you told me you've never been in a 10 hospital? 11 MR. HOROWITZ: Form. 12 BY MR. CRITTON: 13 Q. Right? 14 A. Not that I can recall, no. 15 Q. I asked you what you told the Palm Beach 16 police the first time you went to Mr. Epstein's house, 17 what you told them as to how you ended up going to 18 Epstein's. I asked you what you had told them. 19 Now my question to you is I never asked you 20 what you told the FBI. At this point I'm beyond that, 21 so let me ask this question. 22 How did you first hear that other people in 23 your grade or at school were going to Mr. Epstein's 24 home? Who did you hear that from? 25 A. I mean I just remember the first time I heard PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201.272-617-4627) Electronically signed by Rachel Bridge (201-272417-4627) fe3b2074-481394a4d-ac93454119Bfd7921 EFTA01104226 Page 347 1 about it was asking me to go. And then after that, 2 I just remember Jane Doe 4 talking about it and then 3 4 Q. And you said . asked you to go. And at 5 that time I think you said it was, you remembered it 6 being in gym class or something like that. 7 A. Yes. 8 Q. And . was in your grade? 9 A. , but anybody could 10 have gym together. 11 Q. So what specifically did . say to you, your 12 best recollection? 13 A. She asked me if, if I needed a job and if I 14 needed money, and then she asked me if I knew how to 15 give a massage. And I said yes, but not professionally. 16 And she told me that was fine. 17 And then she told me how she knows a guy that 18 lives in Palm Beach and will pay me if I give a massage. 19 Q. You had been to Palm Beach before? 20 A. Yes. 21 Q. And I assume based on what you told me earlier 22 you had been to the beach in Palm Beach? 23 A. Yes. 24 Q. And had your dad driven you over there in Palm 25 Beach because this is where I work, this is the kind of PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge (201-272-6174627) fe3b2074-4669-4a4d-ac93-e546961d7921 EFTA01104227 Page 349 1 A. No. 2 Q. All right. She just said "If you want a job, 3 you want to make some money, you have to give a 4 massage." 5 You said, "I'm not a professional, but I've 6 given massages before"? 7 A. Yes. 8 Q. Who had you ever given a massage to? 9 A. I don't remember, just girlfriends mainly, 10 like back massages. 11 Q. So did you ask . when she said, you know, 12 you can make some money, did she tell you how much you 13 could make? 14 A. Yeah, I think she said $200. 15 Q. And did she say whether she was going to make 16 any money? 17 A. No. 18 Q. And did you say okay, did you say "Yeah, I'm 19 interested"; or "No, I'm not interested, let me think 20 about it"? 21 A. I told her I was interested. 22 Q. Why were you interested in any way well, 23 let me ask you this. Did you say "Well, where exactly 24 is the massage going take place?" 25 A. I didn't ask her any of the details. I just PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272417-4627) Electronically signed by Rachel Bridge (201.272-617-4627) ts3b2074.4669.4s4dac9Sr64696fd7921 EFTA01104228 Page 351 1 remember us going there. 2 Q. And drove? 3 A. Yes. 4 Q. What did she have at the time? Did she have a 5 car, a truck, SUV? 6 A. 7 Q. What did it look like, do you remember? B A. 9 Q. , all right. Now before you went, did 10 you talk with her again and say "Okay, what am I 11 supposed to wear?" 12 A. No. That first conversation, she just told me 13 to dress cute. 14 Q. Dress cute? 15 A. Yeah. 16 Q. What's that mean to you or what did that mean 17 to you? 18 A. I don't know. I just wore like my bathing 19 suit, because she said -- like we were planning on going 20 to the beach after. And then I wore a skirt and a tank 21 top? 22 Q. So you wore a bathing suit, tank top, skirt 23 and like flip-flops? 24 A. Uh huh. 25 Q. Yes? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272-617.4627) Electronically signed by Rachel Bridge (201-2724174827) fe3b2074-48139-4a4d-ec93-•64696fdllil21 EFTA01104229 Page 350 1 was interested in making money, I guess. 2 Q. So when is the next time you and . had some 3 conversation about it? 4 A. The next time is she just, I'm pretty sure 5 like when I actually went there. 6 Q. Did she say at school, "Hey, we're going to go 7 on Tuesday" or whatever? 8 A. I don't remember. 9 Q. On any of the times that you ever went to 10 Mr. Epstein's, did you ever miss school to go? 11 A. I went on -- no, I usually went after school. 12 Q. What time? What time did you get out of 13 school, like two, three o'clock? 14 A. Yes. 15 Q. So you would go after you got out of school? 16 A. Yes. 17 Q. And on the first occasion, how did you know 18 that you were going to go a particular day? 19 A. III. told me. I guess she made plans with 20 or Jeffrey. 21 Q. Tell me what you know, not what you guess. So 22 let me ask you again. What did say to you? 23 A. I don't remember exactly. I just remember her 24 asking me, and then I forget how we actually, when we 25 made plans to go there, like what day, but -- and then I PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272-617.4627) Electronically signed by Rachel Bridge (201-272-617-4627) fe3b2074-4669-4a4d-ac93-046961d7921 EFTA01104230 Page 384 1 MR. HOROWITZ: Form. 2 BY MR. CRITTON: 3 Q. Or something like that? A. I'm sure I did. I don't remember exactly what 5 I told her. 6 Q. All right. So at that point, that is, after 7 that, describe that as a pretty miserable experience for you yourself? A. Yes. _O Q. So this miserable experience having occurred, 11 I assume you made a decision right then and there that 12 you would never go back to Mr. Epstein's house, because L3 why would you put yourself in such a situation which was 14 awkward, where you would be weird, you would be scared, 15 nervous, anxious, and what he did from your view was 16 inappropriate and uncomfortable for you? 17 MR. HOROWITZ: Form. 18 THE WITNESS: Well, you know I went eight to 19 ten times, so obviously you know I went back after 20 that. 21 BY MR. CRITTON: 22 Q. That's my question to you, was if you found 23 the situation awkward, weird, you were scared, nervous, 24 you felt what he did was inappropriate and you were 25 uncomfortable and confused and you felt that . had PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201.272617.4627) Electronically signed by Rachel Bridge (201-272417-4627) fe3b2074.4669-4a4d-ac93-064696fd7921 EFTA01104231 Page 387 1 anybody, and then other girls started going, and that's 2 when I believe III. asked me about it or III., one of 3 them. And that's when I took one of those girls. 4 Q. All right. So on the second occasion is when 5 you took somebody else? 6 A. Yes. 7 Q. All right. So on the second occasion you took 8 either . or III., right? 9 A. Yes. 10 Q. Do you remember which one now, having thought 11 about it? 12 13 14 was A. No. I mean I know -- now I'm pretty sure it • not ., but I can't remember which one I took first. 15 Q. All right. And, all right, on the second 16 occasion you said called you and asked you whether 17 18 19 20 you wanted to come back or whether you had someone else that would like to come? A. Yeah, she said either. Q. All right. And did she say to you when she 21 called you "Do you have someone else that would like to 22 give Mr. Epstein a massage?" 23 A. Yes. 24 Q. Or did she say to come and work? What did she 25 1 say? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge (201-272-617-4627) felb2074-4669-434d-ac93.e54696fd7921 EFTA01104232 Page 388 1 A. She asked me both if I wanted to come work or 2 if I knew somebody what wanted to come work. 3 Q. Those were her exact words? 4 MR. HOROWITZ: Form. 5 THE WITNESS: Pretty much. 6 BY MR. CRITTON: 7 Q. When she said that -- again, you have never 8 texted with , have you? 9 A. I don't remember. I don't think so. 10 Q. You never communicated by Facebook or social 11 networking with 12 A. No. 13 Q. Or anyone on behalf of Mr. Epstein? 14 MR. HOROWITZ: Form. 15 THE WITNESS: No. 16 BY MR. CRITTON: 17 Q. All right. And when you talked with and 18 she said would you like to come and work or do you have 19 a friend that would like to come and work, you said 20 what? 21 A. I told her that I didn't know and that I would 22 call her back. 23 Q. And did you at that time -- how much time had 24 passed since the time you were there the first time? 25 A. I'm not sure. I think like two weeks or so. 104 Oarworaelliet•••,... I PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201.272417-4627) Electronically signed by Rachel Bridge (201-272-617-4627) fe3b2074-46694a404c93.646961d1921 EFTA01104233 Page 393 1 A. I don't remember. 2 Q. What was her reputation around school? 3 A. It was good. 4 Q. All right. So what did you do? Did you call 5 aback and say "Yep, I'm bringing a friend"? 6 A. No. Mill actually called me again, and then 7 I told her that I, yes, I had a friend that wanted to 8 come, M. 9 Q. And she said, said "Okay, just set up a 10 time"? 11 A. Yes. 12 Q. And did you set up a time and did you take 13 . there? 14 A. I don't remember. 15 Q. ., was she driving at the time? 16 A. Yes. 17 Q. Did you say you were in the same class? 18 A. Yes. 19 Q. So one of the two of you drove, and I think 20 you told us earlier maybe III. went, you just don't 21 remember, or you think just the two of you went? 22 A. I don't remember. 23 Q. So you drive over there. Did . ask you any 24 questions as you were going over there? 25 A. I don't remember. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272-617.4627) Electronically signed by Rachel Bridge (201-2724174127) fe3b20744669-4a4d-ac934646961d7921 EFTA01104234 Page 397 1 her like it had been to you? 2 MR. HOROWITZ: Form. 3 THE WITNESS: She didn't go into any detail. 4 I'm sure she was embarrassed. 5 BY MR. CRITTON: Q. As you had been, right? 7 A. Yes. 8 Q. Okay. And did she say anything else? 9 A. Not that I can remember. 10 Q. To your knowledge, did . ever go back to 11 Mr. Epstein's? 12 A. I don't know. 13 Q. You never took her? 14 A. No. I never took her again. 15 Q. All right. On the third occasion that you 16 went to Mr. Epstein's, is this when you would have taken 17 18 A. Yes, I believe so. 19 Q. So the third time, how did that happen? 20 A. I don't remember exactly. I just remember me 21 taking her there. I think I might have drove, and 22 basically the same thing with 23 Q. Did you tell III. what your experience had 24 been? 25 A. Yes, but she also heard about it from other PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272417-4627) Electronically signed by Rachel Bridge (201.2724174627) fe3b207444569-4e4d-ac93464696M7921 EFTA01104235 Page 401 1 this occasion? 2 A. I believe and maybe the girl, 3 girl. 4 Q. I'm sorry, and, and 5 A. Yeah, 6 Q. You pull into the kitchen. Was the cook 7 there? 8 A. I think so, yeah. There was usually a cook 9 there. 10 Q. Did you have anything to eat? 11 A. I don't remember. 12 Q. So you sat in the kitchen and did take 13 upstairs? 14 A. Yes. 15 Q. How long was she up there, about 30 minutes? 16 A. Yes. 17 Q. She comes back down. Did Mr. Epstein come 18 back down again? 19 A. Umm, umm, actually I think that was the time 20 that brought me up there and Jeffrey was, was in 21 like a smaller room kind of by the bathroom. 22 And he gave me the money and he said something 23 like "good job," and then just tried to grab my butt 24 again. And then I was kind of like pulled away, and he 25 gave me the money and then . came out and then we PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201.272417627) Electronically signed by Rachel Bridge (201.272.617.4627) te3b2074-4669-4e4d-ac93-054696td7921 EFTA01104236 Page 404 1 Q. Did they ever call for help when they were 2 there? 3 A. No. 4 Q. Did you after the first visit ever call the 5 Palm Beach Police Department? 6 A. No. 7 Q. Okay. Did . ever say, "You know what? 8 This guy did something unappropriate, we should call the 9 police"? 10 A. No. 11 Q. How about . and you? Did . say anything 12 to you about calling the police that maybe what was 13 going on was inappropriate? 14 A. No. 15 Q. All right. So you made another 200 bucks for 16 taking somebody else, right? 17 A. Yes. 18 Q. Okay. The fourth time now you went, how did 19 it happen that you went a fourth time? 20 A. I just heard about, you know, girls going, and 21 then I just needed money and like kept calling me, 22 so then I just decided to go back, but it's hard to 23 distinct from time to time. I just remember like major 24 things that happened when I was there. 25 Q. Okay. The fourth time, you say you needed PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201.272-617.4627) Electronically signed by Rachel Bridge (201-272-6174627) fe3b20744669.4a4dac93e54696fd7921 EFTA01104237 Page 407 1 kitchen. One time I saw a little girl there. One time 2 I saw the girl there. was usually always 3 there. 4 Q. Can you tell me, can you identify the fourth 5 time and what happened at the fourth time? 6 A. I think the fourth time was when he was in the 7 shower and I went up there. 8 Q. So you went up. Did IIIII take you up or you 9 just knew how to get up there? 10 A. I think she took me up. 11 Q. Okay. Now this is the fourth time you went. 12 You went one time, you were, you felt the situation 13 completely inappropriate, you were traumatized, you were 14 scared and confused. 15 The next two times you take friends. You 16 explain to them what was going to go on, and they knew, 17 they heard it from other people. 18 Why did you put yourself in a position to go 19 back now a second time yourself after the first 20 experience was traumatic and awful for you? 21 MR. HOROWITZ: Form. 22 THE WITNESS: I don't know, I just, I wanted 23 money. And I mean a lot of my high school 24 25 girlfriends were going and I thought it was kind of like, you know, getting to be normal almost. And I PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272-6174627) Electronically signed by Rachel Bridge (201-272417-4627) fe3b2074-46694a4d-ac934646961d7621 EFTA01104238 Page 420 1 that. 2 Q. Did he ever pay you more than $200? 3 A. No. 4 Q. So he always paid you $200? 5 A. Yes. 6 Q. Okay. Now on that occasion, on the sixth now, 7 you say again -- well, were you on the fifth or the 8 sixth? 9 A. They kind of blend together for me, so -- 10 Q. On the fifth or the sixth, what happened 11 again -- now let's go to the sixth. What happened 12 differently on the sixth than the fifth? 13 MR. HOROWITZ: Form. 14 THE WITNESS: I honestly can't remember every 15 visit. I just remember like really the things that 16 stood out. Like it's so painful for me to 17 remember, like I don't know, it's hard to bring 18 back up, and I just remember the main things that 19 happened. 20 BY MR. CRITTON: 21 Q. Well, at some visit, whether it was the fifth 22 or the sixth, you say he tried to touch your breasts. 23 You moved away from him and said you didn't feel 24 comfortable with that. 25 A. Yes. fflirt•CULM1=====0111011=CIU PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201.2724174827) Electronically signed by Rachel Bridge (201-2724174627) fe3b2074-4669-4a4d-ac93.e54696M7921 EFTA01104239 Page 442 1 you, and I think -- well, let me strike that. 2 When I asked you earlier, I think you said 3 that ME never texted you through the phone, nor did 4 she ever communicate with you over the computer, 5 correct? 6 A. I don't believe, I definitely never had any 7 e-mails or computer, but I don't think she ever texted 8 me. 9 Q. All right. And the only communication 10 separate and apart from the conversation that you had 11 with or the voice message that she left you when 12 you were with the Palm Beach police and they were 13 interviewing you, all other calls for were dealing 14 with could you come or could you bring someone else to 15 come to work? 16 MR. HOROWITZ: Form. 17 THE WITNESS: Yes. 18 BY MR. CRITTON: 19 Q. And you understood that to mean could you come 20 and give Mr. Epstein a massage? 21 MR. HOROWITZ: Form. 22 THE WITNESS: Yes. Well, she said well, 23 basically, yeah. 24 BY MR. CRITTON: 25 Q. And she never, that is, never said to PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge (201472-617-4627) fe3b2074-4669-4a4d-ac93-0546961d7921 EFTA01104240 Page 443 1 you "I want you to come to work to provide sexual 2 services for Mr. Epstein"? 3 She never said that, did she? 4 MR. HOROWITZ: Form. 5 THE WITNESS: No. 6 BY MR. CRITTON: 7 Q. All right. And based on what you told me, just told me, never attempted to persuade or to 9 induce or to entice you to engage in any sexual conduct 10 with Mr. Epstein during any phone conversation, did she? 11 MR. HOROWITZ: Form. 12 THE WITNESS: Just the massages and basically 13 that. 14 BY MR. CRITTON: 15 Q. Right. And she's the only one who ever called 16 you, true? 17 A. I think so. 18 Q. Has anyone, separate and apart from the 19 allegations you have made in this complaint, has anyone 20 ever attempted to sexually assault you or to rape you? 21 A. No. 22 Q. At any time? Have you ever been attacked by 23 anyone? 24 A. No. 25 Q. Other than your PROSE COURT REPORTING AGENCY, INC. Electronically signed by Rachel Bridge (201.272-817-4627) Electronically signed by Rachel Bridge (201-272417-4827) fe3b2074-4889-444d-ac93-084898fd7921 EFTA01104241 Page 28 1 Q. Let me get back to the police here. 2 So the police sit and they interview you for 3 an hour and a half to two hours, and during that, not 4 only the sworn part of the testimony out of your 5 statement, but as well you're saying that you lied to 6 them during part of, part of what you've said, both 7 sworn and unsworn, and as well you didn't provide them 8 all the information, right? 9 A. Yes. 10 Q. Now, you filed your lawsuit in this case 11 against Mr. Epstein and you are seeking, at least your 12 lawyers are asking in part of the complaint for 13 $50 million. Are you aware of that? 14 A. No, my lawyers take care of all that. 15 Q. All right. Let me show you I'll mark as 16 Exhibit 1. 17 (The document was marked Defendant's 18 Exhibit 1 for identification.) 19 BY MR. CRITTON: 20 Q. Exhibit 1 is the amended complaint that you 21 filed, that your lawyers -- it's the second complaint 22 that actually was filed in this action. The original 23 complaint was filed on September 10th of '08, all right? 24 A. Uh huh. 25 Q. Yes? PROSE COURT REPORTING AGENCY, INC. EFTA01104242 Page 29 1 A. Yes. 2 Q. All right. So between the time that the 3 lawsuit was filed on September -- let me strike that -- 4 that you gave a statement to the police officers under 5 which you, about which you've admitted you did not tell 6 the truth on , 2005, up until three years 7 later -- almost three years later, September 10th of 8 '08, did you recontact the police and tell the police 9 that you had not told them the truth? In fact, you had 10 lied to them and withheld information? 11 A. I told the FBI that when they came up to visit 12 me 13 Q. That wasn't my question. 14 MR. HOROWITZ: Form. 15 BY MR. CRITTON: 16 Q. My question was did you talk to the Palm Beach 17 police department -- 18 A. I never talked to them after that. 19 Q. I need to finish the question. 20 A. I'm sorry. 21 Q. -- from the time that you first spoke with 22 them on of 2005 up until the time that the 23 complaint was filed, that is, to bring this lawsuit 24 seeking damages in excess of $50 million against 25 Mr: Epstein, did you ever call or recontact the Palm PROSE COURT REPORTING AGENCY, INC. EFTA01104243 Page 34 1 you first went to Mr. Epstein's home? 2 A. I believe I went the end of my sophomore year 3 till about the end of my junior year. I'm not sure if 4 it was the beginning or the end of my sophomore year. 5 Somewhere around there. 6 Q. Well, you told the police that you were 7 approximately 17 when you first went to Mr. Epstein's 8 home, didn't you? 9 A. I don't exactly remember what, when I said 10 that, I first told them I went. 11 Q. If I asked you to assume that the police 12 report reflects that the statement that you gave to 13 them, that you were there when you were 17 years old, 14 all right? 15 A. Okay. 16 Q. If you were 17 years old and you were born in, 17 let's see, so it would have been 18 approximately June, the end of June of 2004, correct, 19 that you first went there? 20 MR. HOROWITZ: Form. 21 THE WITNESS: I, I don't exactly know, to be 22 honest with you. 23 BY MR. CRITTON: 24 Q. You mean when you first went to Mr. Epstein's? 25 A. I can't put a date on it. I just remember it PROSE COURT REPORTING AGENCY, INC. EFTA01104244 Page 35 1 was my sophomore year to my junior year. 2 Q. When you gave a statement to the police on 3 , 2005, whether you were 16 or 17, what 4 difference would it have made to the police officers? 5 Why would being scared or confused, why would you lie 6 about your age when you first went to Mr. Epstein's? 7 MR. HOROWITZ: Form. 8 THE WITNESS: I don't know. 9 BY MR. CRITTON: 10 Q. Maybe in fact -- 11 A. I mean I did go when I was 17 too, so I may 12 have just said 17, I don't really know. 13 Q. Well, you were 18 -- again, would you agree 14 with me that your recollection of the events involving 15 Mr. Epstein would have been better in October of '05 16 than it is at the current time? 17 MR. HOROWITZ: Form. 18 THE WITNESS: Yes. 19 BY MR. CRITTON: 20 Q. And if you told the police officers you were 21 17 when you first went to Mr. Epstein's home, would you 22 agree with me that that, there would have been no reason 23 for you to lie about your age at that time -- 24 MR. HOROWITZ: Form. 25 PROSE COURT REPORTING AGENCY, INC. EFTA01104245 Page 36 1 BY MR. CRITTON: 2 Q. -- to the police officers? 3 MR. HOROWITZ: Form. 4 BY MR. CRITTON: 5 Q. Whether you were scared or confused at that 6 time, you probably would have given them at least your 7 accurate age when you first went to Mr. Epstein's? 8 MR. HOROWITZ: Form. 9 THE WITNESS: I may have said it because I was 10 scared and I didn't want to them to think I 11 actually went that long, or I don't know why I said 12 it. I honestly don't know. 13 BY MR. CRITTON: 14 Q. And maybe it was the truth at the time? 15 MR. HOROWITZ: Form. 16 THE WITNESS: I mean I really don't know. 17 BY MR. CRITTON: 18 Q. So it may have been the truth, it may not have 19 been the truth; even today you don't know, correct, 20 whether you were 17 when you first went to 21 Mr. Epstein's? 22 A. I believe I was 16, because I believe it was 23 the end of my sophomore year. So I at least think I was 24 16. 25 Q. So you are meeting with two police officers PROSE COURT REPORTING AGENCY, INC. EFTA01104246 Page 37 1 from the Town of Palm Beach in basically a secure 2 environment, nothing can happen to you there. You told 3 them that you were 17 years old when you first went to 4 Mr. Epstein's. 5 Now that you are seeking $50 million in a 6 lawsuit that was filed on September 10 of '08, now all 7 of a sudden maybe you were 16? Is that your testimony? 8 MR. HOROWITZ: Let me object to form. You are 9 mischaracterizing the testimony. 10 BY MR. CRITTON: 11 Q. You can go ahead and answer, ma'am. 12 A. Well, I told you that I didn't tell them the 13 complete truth. So what would it matter if I told them 14 I was 17 or 16, when I already told you I didn't tell 15 them the complete truth and I didn't tell them 16 everything that happened? 17 Q. Well, again, my point is merely is -- 18 A. I understand. 19 Q. I want you to confirm that you didn't even 20 tell them the correct age, or at least your position is 21 you may have lied to the police officers even about the 22 age when you first went to Mr. Epstein's house? 23 A. I believe the only reason I would have lied 24 about my age, because I was scared and I didn't want 25 them obviously when I was 16 to think that I went there PROSE COURT REPORTING AGENCY, INC. EFTA01104247 Page 38 1 as well as 17 and if I didn't really want to be involved 2 in it, so maybe that's why I said I was 17. I don't 3 remember that far back what I was thinking. 4 Q. Okay. I understand that. But in fact it 5 could have been true that the first time you went to 6 Mr. Epstein's house you were 17 years old, correct? 7 MR. HOROWITZ: Form. 8 THE WITNESS: No, I remember going around the 9 end of my sophomore year. 10 BY MR. CRITTON: 11 Q. Give me your best exact date when you first 12 went to Mr. Epstein's home. 13 A. I remember III. was and she 14 asked me to go, and I'm almost positive that was my 15 towards the end of my sophomore year. She was in 16 class. 17 Q. That takes you now to your sophomore year? 18 A. Yes. 19 Q. Okay. 20 A. Yes. 21 Q. Which would have been when? 22 A. When I was 16. 23 Q. You were a senior -- let's just get the dates 24 right. You were senior as of August of '05 -- I'm 25 sorry, of '04, correct? PROSE COURT REPORTING AGENCY, INC. EFTA01104248 Page 39 1 A. Yes. 2 Q. And as of August of '04, you would have been 3 17 years old as a senior; is that correct? 4 A. Yes. 5 Q. Okay. So as a junior, you would have been 16 6 years old and you would have started in August of '03 to 7 '04, right? 8 A. Yes. 9 Q. If '05, 04-05 is your senior year and you were 10 17 during your whole senior year; is that correct? 11 A. Yes. 12 Q. All right. So you would have been 16 during 13 your entire junior year? 14 A. Uh huh. 15 Q. Yes? 16 A. Yes. 17 Q. Okay. But you just said . asked you to go 18 to Mr. Epstein's house now when you were in your 19 sophomore year. 20 A. Yes. 21 Q. Okay. So you would have been 15 then? 22 A. I guess so. I wasn't really going by age. I 23 was just trying to remember when she was in 24 class, and I can't remember if it was my sophomore or my 25 junior year. PROSE COURT REPORTING AGENCY, INC. EFTA01104249 Page 42 1 Q. So now you are saying it really could be the 2 junior year? 3 A. I really, I really don't know. I can't 4 remember. I just remember her being 5 asking me to go. 6 Q. So maybe it's '03, maybe it's '04, maybe it's 7 '05, you are just not sure? 8 MR. HOROWITZ: Form. 9 THE WITNESS: It's not '05. It was either 10 2003, I'm pretty sure it was 2003 -- or 2002 or 11 2003 through 2004. It wasn't 2005 at all. 12 BY MR. CRITTON: 13 Q. All right. Let me show you what I'll mark as 14 Exhibit 2. 15 (The document was marked Defendant's Exhibit 16 2 for identification.) 17 MR. CRITTON: Here's extra copy for you. 18 MR. HOROWITZ: Okay. 19 BY MR. CRITTON: 20 Q. These are interrogatory answers that you 21 signed on January 23, 2008. Do you see that? 22 A. Yes. 23 Q. Would you go to the second, go to the 24 second-to-last page. 25 MR. HOROWITZ: What, is there a question? PROSE COURT REPORTING AGENCY, INC. EFTA01104250