Text extracted via OCR from the original document. May contain errors from the scanning process.
CASE NO. 08-CIV-80119-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
vs-
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 $17 - VOLUME III
(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
(561) 832-75CC
(561) 832-7506
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Electronically signed by Rachel Bridge 1201.272-617.4627)
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Page
APPEARANCES:
On behalf of the Plaintiffs in related cases
Nos. 08-80069, 08-80119, 08-80232, 08-80380,
0840381, os-so993, 08-86994:
18205 Biscayne Boulevard
Suite 2218
6
Min4,040.
7
8
On behalf of the Defendant Jeffrey Epstein:
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10
303 Banyan Boulevard
Suite 400
11
West P
33401
Teleph
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Also Present: Socha Quimby, videographer
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PROCEEDINGS
THE VIDEOGRAPHER: We are back on the record
at 4:08 pm.
BY MR. CRITTON:
Q. Jane Doe 7, in your supplemental answers to
interrogatories, you listed the names and addresses and
phone numbers, number 18, and I don't know whether I
used that as an exhibit — this will be Exhibit 9.
(The document was matted Defendant's
Exhibit 9 for identification.)
BY MR. CRITTON:
Q. There area couple of supplements you filed
which as things come to you, I think, or your attorneys.
Anyhow, this one deals with males that you had sexual
activity. You listed Mr. Evans, Bryant —
MR. HOROWITZ: You handed us two different
things. This is a request to produce.
MR. CRTITON: Oh, Tin sorry.
MR. HOROWITZ: No problem.
MR. CRT TON: Give this back. This will be
number nine.
(Discussion held off the record.)
BY MR. CRITTON:
Q. Is that the right one that has Mr. Evans?
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10
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14
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18
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20
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Page 300
- - -
INDEX
WITNESS:
Jane Doe #7
By Mr. Critton
5
EXHIBITS
EXHIBIT
PAGE
Defendant's 1
233
Defendant's2
233
Defendant's 3
233
Defendant's 4
263
Defendant's 5
268
Defendant's 6
274
Defendant's 7
280
DePeadant'S 8
294
Defendant's 9
301
Page 302
1
There is a person listed as Bryant. Who is he?
2
A. He a friend from Orlando. 1 kind of dated
3
him.
4
Q. And so of the five individuals you have here,
5
Mr. Evans, Bryant, Mackenzie Russell, PJ Tao and Blake
6
Russell, are the only individuals with whom you have had
7
any type of sexual activity since the time you were ten
8
years old?
9
A. Yeah, other than like kissing. I don't
10
remember everybody I kissed and stuff like that.
11
Q. All right. 1 want to go back to a couple of
12
areas to make sure I got all the information on it.
13
At the time that you met with the officers
14
from Palm Beach, you said, do you remember one of them
15
being a person named Recarey, R-e-c-a-r-e-y,
16
Officer Recarey7
17
A. Yes.
18
Q. I think you said there were two males. Do you
19
remember who the other male was?
20
A. I think his name was Joe something.
21
Q. Joe something, all right. And, Mr. Recarey's
22
first name, Detective Recarey's first name is Joe
23
Recarey.
24
A. Oh, sorry.
25
Q. Do you remember what the other person looked
'(561) 832-7500
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INC.
(561) 832-7506
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Page 305
1
like? Not Mr. Recarey, but the other one.
2
A. He was like just an older man. He was kind of
3
bigger, gray hair, I think.
4
Q. All right. And in terms of that individual,
5
did he say anything or was it Officer Recarey who
6
conducted the interview with you?
7
A. I think it was Officer Recarey mostly.
8
Q. Did you eves have any subsequent contact with
9
him? Did you ever talk to him after the interview on
10
October 4th of 2005?
11
A. I don't think so. I don't remember.
12
Q. When he talked to you, that is, when he
13
introduced himself to you, did he explain to you how he
14
found you, that is, how he knew that you may have had
15
some involvement with Mr. Epstein?
16
A. I think it was somebody told him.
17
Q. Did he tell you who the somebody was?
18
A. No.
19
Q. Did he tell you when you met with him, and
20
again before he started the tape of the statement, did
21
he tell you that, that he had interviewed a number of
22
other females?
23
A. I don't remember if he told me that or not.
24
Q. Did he tell you, you know, tell us everything
25
because we've heard stories from other people, so we
1
car?
2
A. Yeah, I think so.
3
Q. So they actually showed you, was it a color
4
picture or black and white picture?
5
A. .Black and white.
6
Q. So they actually had a picture of what, the
7
rear of your car that had the license plate number?
8
A. I'm almost positive.
9
Q. So when they showed you the picture of your
10
car, and you had said that earlier in your testimony,
11
you recognized right away as they knew that you had been
12
there?
13
A. Yes.
14
Q. All right Did you ask him how old the
15
picture was?
16
A. No, I didn't.
17
Q. And they just said that they had had him under
18
some surveillance fora period of time?
19
A. Yes.
20
Q. Did they show you more than one picture of
21
your car so that, that suggested that they had taken a
22
picture of your car on a number of occasions?
23
A. No.
24
Q. Did they tell you whether they knew any other
25
people who had been to his house? That is, did they use
Page 304
1
have an idea of what may have occurred at Mr. Epstein's
2
house?
3
A. Like front the very beginning of me going?
4
Q. No, no, no. When you first met with him after
5
you sent Mom back into the house, did Officer Recarey
6
say to you "Hey, lane Doe 7, you can tell us what went
7
on because we've heard stories from other people, so
8
tell us everything that happened"?
That is, did he try to make you comfortable so
10
you would talk to him?
11
MIt HOROWITZ: Form
12
THE WITNESS: I don't exactly remember what he
13
said, but basically he showed me the picture of my
14
car or my license plate or something. He said that
15
they have been like watching Jeffrey and they know
16
I've been there because they saw my car there.
17
BY MR. CRITTON:
18
Q. Okay. Did they tell you how long they had
19
been watching Jeffrey?
20
A. No, I don't think so.
21
Q. Did you get the impression that over the last
22
few months they had been watching him?
23
A. Yes.
24
Q. Okay. And so the picture they had, did they
25
have an actual picture of your license plate on your
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Page 306
any names?
A. I think they j ust said other girls in my high
school.
Q. And the only name you gave them was Jane
Doe 4?
A. AndM
Q. IMI:tid you give t hem
too?
A. And S.V., yes.
Q. Did they show you any other photographs of
either his house, any other cars, any other vehicles, or
was it just yours?
A. I think tlisiright have -- yeah, they showed
me a picture of =
and they asked ra
tify the
girl in the picture, and I identified her
Q. Did you ever Imw what
last name was?
A. It began with al, something.
Q. Did she ever introduce herself to you?
A. Yes.
Asil=, or did she just say my name is
A. I don't remember.
Q. Was she nice to you?
A. Yes.
Q. Friendly?
A. Yes.
ata....Gittet•a•45,40
,
(561) 832-7500
3 (Pages 303 to 306
(561) 832-7506
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Q. How old did you thinavms?
2
A. She looked about in her nu twenties.
3
Q. All right. And did you tell them that? Did
4
they ask you about her at all?
5
A. Yes. I think they just asked if I recognized
6
her and just asked what I saw her doing there and stuff
7
like that.
8
Q. And I think you said earlier that.
called
9
you during the time, either just before or urmg the
10
time you were being interviewed by the police?
11
A. Yes.
12
Q. And did you take her call?
13
A. No.
14
Q. Did you call her back?
15
A. No. I just listened to her voicemail.
16
Q. What did — did you play the voicemail for the
17
police?
18
A. Yes.
19
Q. Okay. And did they record it?
20
A. I think so, yes.
21
Q. What did the voicemail say, to the best of
22
your knowledge or recollection?
23
A. Just that "Hi, Jane Doe 7, this is M." I
24
think she just asked if there was cops at my house and
25
if I was talking to them. And she said for me to call
Page 309
1
he suggest things, like we know this, we know that?
2
Like your car, we know you were there because here's a
3
picture of your car and your license plate. Isn't that
4
your car and license plate?
5
MR. HOROWITZ: Form.
6
THE WITNESS: The only thing he suggested is
7
he just kind of knew I was there, so —
8
BY MR. CRITTON:
9
Q. Did he ever tell you what some of the other
10
females had said had occurred at Mr. Epstein's house?
11
A. I don't remember exactly what he said to me.
12
Q. Did they ever tell you that some of the other
13
females were saying that Mr. Epstein did X or Y with
14
them? X or Y could be anything, but did he say well, we
15
know Female ABC did such and such, or at least she says
16
she did such and such with Mr. Epstein or he did such
17
and such with her?
18
Did he suggest that?
19
A. I don't remember.
20
Q. Did they ever say
and I think they asked
21
you, because I asked you earlier and you had told them
22
that at least in the visit that you had under oath with
23
them is that you had, he had not masturbated when you
24
were there, correct?
25
MR. HOROWITZ: Form.
Page 308
1
her back.
2
Q. But you never did?
3
A. No. They told me not to.
4
Q. They being the police?
5
A. Yes.
6
Q. Did they tell you anything else to do or not
7
to do?
8
A. Just not really to talk about it with anybody.
9
Q. Did they tell you not to tell your parents?
10
A. No, they never said that.
11
Q. Did they tell you that if somebody called you
12
on behalf of Mr. Epstein not to talk to them?
13
A. Yes.
14
Q. Did they mention at that time anything about
15
the US attorney or the FBI?
16
A. No.
17
Q. Did anyone else, did either Officer Recarey or
18
anyone else from Palm Beach ever try to recontact you
19
for a followup interview or to clarify something?
20
A. No.
21
Q. And I think you told me earlier they never
22
sent you anything?
23
A. No.
24
Q. When Officer Recarey was talking to you, did
25
he — and i don't mean this in a negative way, but did
Page 310
1
BY MR. CRITTON:
2
Q. mars what you told them that day?
3
MR. HOROWITZ: Form.
4
THE WITNESS: I believe so.
5
BY MR. CRITION:
6
Q. And did they say "Well, other females had said
7
that Mr. Epstein masturbated, did he do that when you
8
were there?"
9
Did they suggest things like that in askinr
10
questions?
11
A. !thinks*, yes.
12
Q. Okay. And did he reassert to you, did he tell
:3
you at any time "You can tell us anything, you are not
going to get in any trouble"?
15
MR. HOROWITZ: Form.
16
THE WITNESS: I don't remember if he said that
17
or not.
18
BY MR. CRITTON:
19
Q. Well, did he ever say to you if in fact you
20
received money for having taken people to Mr. Epstein's,
21
you could be charged with a crime under Florida law?
22
Did he tell you that?
23
A. No.
24
Q. Okay. Did he ever read you your Miranda
25
rights?
(561) 832-7500
4 (Pages 307 to 310
INC.
(561) 832-7506
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1
A. No.
2
Q. Were you concerned that you might be charged
3
with a crime?
4
A. Yes.
Q. Because you thought you had committed a crime?
MR. HOROWITZ: Form.
THE WITNESS: I just thought I was going to
8
get in trouble for going there.
9
BY MR. CRITTON:
10
Q. Dkly
also said that
11
called you eras
you described.
12
Did you know who she was before she called
13
you?
14
A. No.
15
Q. She just called you out of the blue one day?
16
A. I think she called me and — actually, I think
17
Agent Nezbit from the FBI might have told me something
18
that she, she was the attorney general maybe, I think
19
I don't
20
Q. Nezbit is the female FBI agent, correct?
21
A. Yes.
22
Q. And then when she came to (bland° to meet with
23
you and you met at Starbuck's, she had a male agent with
24
her as well?
25
A. Yes.
1
THE WITNESS: I think so.
2
BY MR. CRITTON:
3
Q. Did she have the statement that you had given
4
to the Palm Beach police?
5
A. I think so, yes.
6
Q Did she ask you about the statement? That is,
7
did she quiz you from the statement?
8
Did it sound like she had a transcript of your
9
statement so she was asking you questions, did this
10
happen, did that happen?
11
A. Yeah, she basically asked me if what I told
12
the Palm Beach police was true. She said that she knew,
13
you know, a lot of girls did a lot more things with
14
them, what I have said, and she basically knew, you
15
know, I felt that she knew a lot more.
16
So 1 just told her the truth, that 1 lied to
17
them and that I finally, you know, broke down and told
18
her everything that happened.
19
Q. And did she encourage you to do that? I mean
20
did she tell you "A lot of other girls have come forward
21
and said XY, that XYZ happened at Mr. Epstein's, so
22
please tell us everything"?
23
MB. HOROWITZ: Form.
24
THE WITNESS: Well, she kind of acted like she
25
already knew and she knew a lot more went on than
Page 312
1
Q. And I think you said you spent an hour and a
2
half, two hours with them?
3
A. Yes.
4
Q. And you recall that they took a taped
5
statement from you?
6
A. Yes.
7
Q. Much like FBI did — Pm sorry, much like the
8
Palm Beach police did?
9
A. Yes.
10
Q. Did they talk to you fora period of time
11
before they turned on their tape recorder?
12
A. I don't remember.
13
Q. You just remember them taking a taped
14
statement?
15
A. Yes.
16
Q. Okay. Did they also take notes?
17
A. Yes.
18
Q. And who was taking the notes, the male or the
19
FBI Agent Nezbit?
20
A. The male was.
21.
Q. And was the Agent Nezbit, was she, did she
22.
!mow that you had
let me strike that.
23
Did she have the benefit of any information
24
from Palm Beach?
25
MR. HOROWITZ: Form.
Page 314
1
what I told the officers in Palm Beach.
2
BY MR. CR1TTON:
3
Q. And whether she did or not, you don't blow,
4
that's how she played it, so to speak?
5
A. Yes.
6
Q. All right. Did, after the hour or two that
7
you spent with Agent Nezbit, was she someone who — did
8
you get emotional with Agent Nezbit?
9
A. Yeah, I mean I felt like i could like open up
10
to her more than I could guys, you know.
11
Q. Did she give you a hug when you left?
12
A. No.
13
Q. Shake hands?
14
A. Yes.
15
Q. Was she warm, comforting?
16
A. Yeah, she was nice.
17
Q. And did she give you her card and say "Jane
18
Doe 7, If you ever have any issues associated with this,
19
you can call me any time at this number"?
20
A. Yes.
21
Q. All right. And did you ever call her?
22
A. Yes, I called her a couple of times.
23
Q. For what?
24
A. Just called her to ask what was going on with
25
the case and if she heard any news and things like that.
(561) 832-7500
5 (Pages 311 to 314)
(561) 832-7506
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1
Q. Did you ever call her back to get the name of
2
an attorney?
3
A. No.
4
Q. And I think you told me she said if you ever
5
need the name of an attorney, she could give you one,
6
but you would have to call her?
7
MR. HOROWITZ: Form.
THE WITNESS: I think Marie was the one that
9
said about the attorney stuff.
10
BY MR. CRITTON:
Q. Okay, when she called you, when she, meaning
12
Marie,calkdyaa
13
A. (Witness nods head up and down.)
14
Q. Did Officer Nezbit ever call you independently
15
of you calling her?
16
A. About what?
17
Q. Whatever.
18
A. No.
19
Q. You said you called her on two occasions to
20
find out status.
21
A. Yeah.
22
Q. Okay. And I think you told me you don't know
23
when you first talked to her.
24
A. She called me again to ask me if there were
25
any details that I left out or anything like that Just
Page 317
1
A. Maybe a month maybe.
2
Q. Did they arrange that before they came back up
3
or did they call you out of the blue?
4
A. Well, no, they arranged it to come back up.
5
Q. Why did they tell you they needed to see you
6
again?
7
A. They just wanted to make sure everything was
8
correct and go over everything with me again.
9
Q. Did they have like a statement that they were
10
now reading ftom?
11
Did they have an outline that they were
12
reading from when they came to meet with you on the
13
second occasion?
14
A. I don't remember.
15
Q. How long did that meeting last?
16
A. I think about an hour.
17
Q. And It was just the two of them?
18
A. Yes.
19
Q. Did they record you at that occasion again?
20
A. I think so, yes.
21
Q. So on both occasions that the FBI met with
22
you, you recall them taking a recorded statement from
23
you?
24
A. Yes.
25
Q. Or recording the session, correct?
t
Page 316
1
basically asked me if I remembered anything. She called
2
me about that.
3
Q. All right. And you told her what?
4
Did you add any details?
5
A. I don't remember.
6
Q. That's when she called you?
7
A. Yes.
8
Q. Okay. And then, and that's the only time she
9
ever called you after the first interview?
10
A. Well, no, they came back up to Orlando.
11
Q. A second time?
12
A. Yes.
13
Q. Oh, I didn't know that. All right, they came
14
back a second time. Meet at Starbucks again?
15
A. No, we met at the Radisson.
16
Q. All right. Were they staying there?
17
A. I think, yeah. Well, I don't know if they
18
were staying there or not actually.
19
Q. Where did you meet, in the restaurant?
20
A. No, we met like in a conference center.
21
Q. Who was t ere other than you?
22
A. The same two people, just me and her and the
23
same guy.
24
Q. How much time transpired between the first
25
visit and the second visit?
Page 318
1
A. Yes.
2
Q. And on the second occasion did you provide
3
them any additional information?
4
A. I don't remember.
5
Q. Did they provide you any additional
6
information, such u we've talked to a number of other
7
females and they have told us X, Y and Z, did this
8
happen? Did that happen?
9
MR. HOROWITZ: Form.
10
THE WITNESS: I think they, yeah, they just, I
11
think they, yeah, said something like that, yeah.
12
BY MR. CRITTON:
13
Q. So they gave you some more at least
14
information. Again, you don't know whether it's true or
15
not, but they said "Well, we found out this or we found
16
out that. Did that happen to your
17
Did they ask questions like that?
18
A. I believe so.
19
Q. All right. Did they, after that second
20
occasion, did they ever recontact you?
21
A. Agent Nezbit did, just, she would call me and
22
fill me in on what was going on.
23
Q. How many more times did Agent Nezbit call?
24
A. I think once or twice after that. She didn't
25
call me a lot.
6 (Pages 315 to 318)
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!age 319
1
Q. Did she ever ask you what your feelings were
2
about any criminal prosecutions directed to Mr. Epstein?
3
A. No.
4
Q. Pardon?
5
A. No.
6
Q. Did you know who -- andIn
asked you
7
et me just clarify it. Before
8
called you, did know who she was?
9
A. I want to say I don't remember. I think Agent
10
Nezbit might have said something about her to me. And
11
then she just called and --
12
Qi.th:iiitifishat
she said, she, Nezbil
13
said
14
A. No. It was towards the end of everything, and
15
I think she just updated me on everything that was going
16
at. Might have told me like who she was.
17
Q. And at the time, so if — and !know that, I
18
think you said that at the time that you spoke with Jane
19
Doe 4 in the summer of '08, you did not have an
20
attorney, a your recollection was you didn't think you
21
had an attorney at that time. You may have spoken with
22
Mr. Herman tut you may not have had an attorney.
23
Son= would have had to have spoken with
24
you sometime before Jane Doe 4 came to stay with you in
25
the suntmer of '08; is that your best recollection?
1
2
3
4
5
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7
8
9
10
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12
13
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15 •
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18
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Page 321
questions.
Q. And you said a lawyer to protect yourself.
Protect yourself from what?
MR. HOROWITZ: Form.
BY MR. CRHITON:
Q. What did she tell you?
A. I don't, I don't know what she was referring
to.
Q. Okay. Did she tell you you might have a civil
claim or you would have a civil claim against
Mr. Epstein?
A. No.
Q. Did she tell you the deal that the government
had worked out or was attempting to work out would
provide a civil remedy for individuals who had gone to
Mr. Epstein, females who had gone to Mr. Epstein's
house?
A. No.
Q. Do you ever remember receiving a letter from
her that said you may have a civil remedy that you can
pursue under a specific federal statute?
A. I think I received a letter, but I don't
remember what it said. It might have said something
like that.
Q. Do you ever remember receiving a letter from
Page 320
A. Yes.
Q. Do you remember how many months before Jane
Doe 4 came there that you would have spoken wit
A. Probably I think a while. Probably like, I
don't know, six months.
7
Q. All right. And you only spoke with her on
8
that one occasion?
9
A. Yes.
10
Q. Did she ever tell you elf you ever have any
11
questions, you can call me?
12
A. Yeah, she gave me a number to call.
13
Q. Did you ever follow up and try to call her for
14
any reason?
15
A. No.
16
Q. When she filled you in on what was going on,
17
what exactly did she say to you?
18
A. She just told me about the criminal case. I
19
forget exactly what she said.
20
And then she just explained all the like legal
21
terms and what was going on. She said, you know, "Other
22
people am getting lawyers, if you want to protect
23
yourself, you know, you could get a lawyer too"
24
But she didn't give me any names or numbers,
25
but she did give me a number to call if I had any more
Page 322
1
Robert Josefsberg from Podhurst Orseck saying he was the
2
attorney representative who had been appointed to
3
represent individuals who the government had deemed to
4
have been, quote, unquote, victims?
5
A. No, I never got a letter from Mm.
6
Q. Did you ever hear from any other government
7
agent, government agent for the United States government
8
who purported to work for thegovernment other than the
9
two FBI agents an
10
A. No, I don't think so.
11
Q. Did you ever hear from anyone else associated
12
with any other police department other than
13
Officer Recarey and whoever the other Palm Beach police
14
officer was?
15
A. No.
16
Q. Did your dad know any of the officers. having
17
been associated with the Town of Palm Beach or employed
18
by the Town of Palm Beach?
19
A. No.
20
Q. Did he ever see anyone in the Town of Palm
21
Beach about this situation, to your knowledge? That is,
22
did he ever go talk to the mayor or the chief-of-police
23
about you and Mr. Epstein?
24
A. No.
25
Q. Other than the time that you told your mom and
14.....•••••44
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INC.
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your dad, you disclosed to them, that is the day that
Officer Recarey was there, October 4 of 2005, has your
mom ever discussed it with you? Not necessarily the
details, but how she feels about it.
A. I mean she's read the newspapers and obviously
she doesn't like him, but I mine she actually didn't
want me to go ahead with the lawsuit.
Q. She didn't?
A. No.
Q. Why not?
MR. HOROWITZ Form.
BY MR. CRITTON:
Q. What did she tell you?
A. She thought it would bring more stress and
anxiety on me.
Q. Has it?
A. I mean, of course, hearing everything, hearing
his name brings anxiety and I get depressed and sad over
it, yeah.
Q. Over the lawsuit?
MR. HOROWITZ: Form.
THE WITNESS: Not just over the lawsuit, but
hearing his name, it brings back memories.
BY MR. CRITTON:
Q. How about your dad, how did he feel about the
Page 325
1
County to work?
2
A. No. They just said wherever I get a job at.
3
Q. Okay. In terms of your parents, are you
4
closer, like if you had a personal problem or an issue,
5
would you more likely call your mom or your dad?
6
A. I mean either one really. I'm not more close
7
to either of them.
Q. Both would be supportive of you, both
9
emotionally and as well financially if they thought that
10
it was necessaty?
11
MR. HOROWITZ Form.
12
THE WITNESS: Yes.
13
BY MR. CRITTON:
14
Q. And that's always been true with you and your
15
family and your mom and your dad?
16
A. Yes.
17
Q. Okay. If you had a friend or friends that you
18
were going to tum to now that you needed help or
19
assistance in some fashion, you didn't want to tell your
20
mom or your dad, would Jane Doe 4 be one of the people
21
you would go to?
22
A. Yes,
23
Q. Who else? Who else would you consider would
24
be a good friend that you would go to?
25 .
A. Jane Doe 4 or Jane Doe 3 really.
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Page 324
lawsuit? Did he ever express any opinion?
A. My dad just basically said it was up to me to
do what I wanted to do.
Q. Has your room ever said to you that she's angry
with you for ever having gone there?
A. I mean no. She was upset about it, and at
first she like asked me how I could have been so stupid
and why I would have went there. But I mean she
understands that I was young and confiised at the time,
so--
Q. Did your dad ever ask you?
A. No. My dad didn't really talk about it.
Q. Are you closer to your mom or your dad? You
love them both, right?
A. Yeah.
Q. And they both love you?
A. (Witness nods head up and down.)
Q. Supportive of you?
A. Yes.
Q. And they are supportive of you getting a
career, certainly a job?
A. Yes.
Q. Every parent wants their child to get a job,
that's good.
Do they want you to come back to Palm Beach
Page 326
1
Q. I'm sorry?
2
A. Jane Doe 4 or Jane Doe 3.
3
Q. Jane Doe 3?
4
A. Yes.
5
Q. Looking briefly at your work history, looks
6
lila, you worked irt,IFIrm i.
t
ottra to Orlando you
7
worked at
8
A. Yes.
9
Q. And you were a cart girl?
10
A. Yes.
11
Q. All right. So you drove around on the golf
12
course?
13
A. Yes.
14
Q. For refreshments and food for guys? Guys and
15
gals, whoever was playing golf?
16
A. Yes.
17
Q. All right. And then you worked — and that
18
was in '07, and is the only job that you have had since
19
then, although I think you said you are working
20
someplace now. I'll get
21
Then you worked ball.
in 2008, the whole
22
year?
23
A. Yeah, about a year. I don't know actually
24
have that.
25
Q. So you went £roil
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MR. HOROWITZ: Do you want to show her that?
2
MR. CRITTON: That was in Exhibit 2. She
3
should have it right in front of her.
4
MR. HOROWITZ: That was like eight exhibits
5
aga
6
MR. CRITTON: I can help you. Maybe you need
7
an assistant to help you sort through the exhibits.
8
BY MR. CRITTON:
9
say you worked
10
at
11
A. Yes.
12
Q. In 2007. That was the only job you had in
13
2007, correct?
14
A. Yes.
15
Q. Okay. And then 2008 was
part of
16
your — I think you told us earlier it w pan
toyour
17
work experience through school?
18
A. Yes.
19
Q. Okay. And you worked them for all of 2008?
20
A. Yes
21
Q. Did you work anyplace else in 2008?
22
A. 2008, no,1 don't believe so.
23
Q.
way, were you with hum Doe 4 when she
24
w
v
up in Orlando and she went P
25
and tried OM as a stripper?
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Page 329
Q.
does what?
A. They are liquor too.
Q. But they are two different entities?
A. Yes. One is just like a modeling agency.
Well, its just like an agency where they have girls
that they hire to like the liquor company, and that's
out of Tampa, but they have jobs in jobs in Orlando that
I do. I have driven to Tampa before.
Q So you will go to Tampa to do this work too?
A. Yes, sometimes.
Q. How much do you get paid for doing that?
A. $25 an hour.
Q. 25 bucks an hour?
A. Uh huh.
Q. All you have to do is go to a bar, look
pretty, have a cute outfit on, and hand out liquor?
MR. HOROWITZ: Form.
THE WITNESS: Yes.
BY MR. CRITTON:
Q. 'filets basically it, isn't it?
MR. HOROWITZ: You are jealous.
BY MR. CRITTON:
Q. This is not professional work. I couldn't do
it. I wouldn't look good in a skirt.
But in essence, they give you 25 bucks an
I
Page 328
1
A. No.
2
Q. Are you aware of the circumstances of her
3
doing it?
4
A. I learned about it.
5
Q Who did you hear about it from?
6
A. Jane Doe 4 told me.
7
Q. What did she say about it?
8
Nothing really. She just said she went to
9
work and it was her birthday and they were just
10
n of joking around.
11
Q. Did she tell you she got up on the stage and
12
danced for a while and made some money?
13
A. She didn't tell me she made money. She just
14
said she did it as a joke.
15
Q. And now where are you currently working again?
16
Tell me a in.
17
A.
18
19
that,
Q. That's
what? Is
is that all the same company?
20
21
m
i l They are two differen
is separate. And then
22
same co
n .
23
Q.
are the liquor people,
24
right?
25
A. Yes.
are the
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Page 330
hour, and bow long is the gig usually?
. A. It depends. Sometimes ifs like four bars we
go to, sometimes ifs two. Sometimes it's five bars.
Q. So it might be six to ten hours?
A. Its neva ten hours, but ifs usually from
lace three to five hours.
Q. All right. Do they pay in cash?
A. No, I get a paycheck.
Q. So you get a 1099?
A. Yes.
you work
or
f
during
About
during the course o a mon
A. About
e twice a week maybe, so —
Q. Is it almost exclusively in Orlando? You said
you have been to Tampa.
A. Yes.
Q. Have you been to any other cities other than
Tampa?
A. No.
Q. If you have to go to Tampa, do they put you up
overnight?
A. No.
Q. How long have you been doing this twice a
week?
A. I meanIdon't always do it twice a week. I
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Page 331
started picking up more shifts now that I only have
three classes. Last semester I was taking six classes,
sol didn't really have time to do that much.
Q. Now you do it approximately two times a week?
A. Yeah, I try to pick up as many shifts as I
can.
Q. And they just go to different ban in Orlando?
A. Not just bars. Restaurants too.
Do you have my Advil at all?
MR. CRITPON: Let's go off the record.
THE VIDEOGRAPHER: Going off the record,
4:21 p.m.
(A recess was taken.)
THE VIDEOGRAPHER: We're back on the record at
4:48 p.m
BY MR. CRITTON:
Q. Ma'am, have you ever been treated in a drug or
an alcohol program?
A. No.
Q. Have you ever had an HIV test?
A. No.
Q. To the best of your knowledge, you are not HIV
positive?
A. No.
Q. All right. Have you ever had any surgery of
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B
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Page 333
A. No.
Q. Jane Doe?
A. No.
Q. Jane Doe 6?
A. No.
Q. Jane Doe 2?
A. No.
Q. L.L.?
A. No.
Q. K.H.?
A. Yes.
Q. How do you know K.H.?
A. She goes to my school, or went to my school,
high school.
Q. How about Jane Doe 101?
A. Sounds kind of familiar.
Q. But you can't place her?
A. I./ uh.
MR. HOROWITZ: No?
THE WITNESS: No.
BY MR. carrroN:
Q. How about L.P, does that mean anything to
you?
A. No.
Q. Is K.H. your age or older?
Page 332
1
any kind?
2
A. Just wisdom teeth.
3
Q. I'm sorry, have you ever bad any cosmetic
4
5
A. No.
6
Q. Have you ever been pregnant?
7
A. No.
8
Q. Jane Doe 3, how long have you known her?
9
A. Since i was a sophomore in high school.
10
Q. So that would have been the '03 time period?
11
A. Yes.
12
Q. And was Jane Doe 3 your age?
13
A. She was a year younger than me.
14
Q. How did you all become friends?
15
A. I believe Jane Doe 4 knew her and her sister.
16
Q. Jane Doe 4?
17
A. Jane Doe 4.
18
Q. Does she go by Jane Doe 4?
19
A. I mean no. T call her Jane Doe 4.
20
Q. Okay. It might have been my heating. So she
21
was a friend of Jane Doe 4's?
22
A. (Witness nods head up and down.)
23
Q. Have you ever met anybody by the name WM?
24
25
10.1calb:GSPAI
t.
A.
of sounds familiar.
surgery?
Page 334
1
A. She's a year older than me.
2
Q. Who was she friends with? Let me rephrase the
3
question.
4
Was she friends with any of your friends, your
5
group?
6
A. Yes.
7
Q. Who?
8
A. Jane Doe 4 and Jane Doe 3.
9
Q. Do you know whethe= ever went to
10
Mr. Epstein's home?
S
t°
11
A. Well
Id me I think she went there.
12
Q. This
13
A. Yes, she is also friends witi= too.
14
Q. I'm sorry?
15
A. She is also friends with., good friends.
1 6
Q. Were you aware, 'think you told me earlier,
17
and I may have forgotten, you told me you were aware
18
back at the time when you
ing to Mr. Epstein's or
19
around that time period thaarhad been there to
20
Epstein's as well?
21
A. Yes.
22
And she told you on or about that time that
23
had been there?
24
A. No, I didn't ford out abotiM. until --
25
Q. When did you find that out?
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Page 335
A. When I wiling =when
I told you
2
recently I talked a
about it.
3
Q. Did she say anything aboulM., whether she
4
had brought any kind of action against Mr. Epstein or
intended to bring any action against him?
o
A. Yeah, I think she said she had a lawyer, but
she didn't really go into detail.
Q. Did she know what had happened, whether the
9
lawyer had filed a lawsuit or not?
10
A. No.
11
Q. So at least back at the time you lava,
12
but you didn't, you had no knowledge that she had been
13
to Mr. Epstein's house?
14
A. No, we weren't good friends. I just know of
15
her because she was friends with my friends.
16
Q. Of the people that you knew who went to
17
Mr. Epstein's house back in the time peril.
18
were there, it would have been Jane Doe 3
19
A. Yes.
20
Q. You are pretty sure..?
21
A. Yes.
22
Q. Jane Doe 4?
23
24
Q.
25
A. Yes.
Page 337
1
A. We didn't really talk about it. The only
2
girls I talked about it with would be Jane Doe 4 and
3
Jane Doe 3.
4
Q. Okay. That's what my uestion is. Did any of
5
those individua
Jane Doe 3
Doe
, Jane
6
, ever say to you that anything that
7
had occurred, at the time that anything that had
8
occurred was inappropriate?
9
A. I mean I didn't talk about it with diem.
10
Q. So nobody brought it up and said "You won't
11
believe what happened"? Nobody said something like to
12
you?
13
A. No, they all kind of kept it to themselves I
14
think because they were embarrassed.
15.
Q. So no one said
did anyone ever tell you
16
that Mr. Epstein had been in any way aggressive with
17
them, had used any kind of physical or verbal force or
18
had coerced them to do anything, or that issue never was
19
discussed back then?
20
A. We just didn't discuss it.
21
Q. But no one raised it? If something had
22
happened and somebody had discussed it, that's something
23
that you would have remembered?
24
A. Yes, l don't know.
25
Q. With regard to Jane Doe 3, you said you knew
Page 336
1
Q.
2
A. Yes.
3
Q. Anyone else have I missed?
4
A. I don't think so.
S
Q. okay. As to arm.
A. I heard of a girall. but I didn't know her.
7
Q. Do you leumnbe
last name?
8
A. No.
9
Q. If I said
would that mean anything
10
to you?
11
A. I don't know if that was her last name or not.
12
Q. Just somebody name=
Do you remember
13
what she looked like?
14
A. Blonde hair.
15
Q. Older?
16
A. I think she was in our grade.
17
Q. Just not in your friend group?
18
A. No.
19
Q. Of the females Jane Doe 3,
20
Jane Doe 4,
did any of those people ever
21
tell you that Mr. Epstein — and tell you now, not vault
22
you assume — that anything had happened back at the
23
time, that anything had ever occurred at Mr. Epstein's
24
house that had been, they considered to be
25
inappropriate?
An
Page 338
1
her when she was -- so you. ould have been a junior, she
2
would have been a sophomore?
3
A. I think I knew her my sophomore year when she
4
was a freshman.
5
Q. So she would have been a freshman?
6
A. Yeah.
7
Q. Were you aware that — let me strike that. Do
8
you know whether you had gone to Mr. Epstein's before
9
Jane Doe 3 went or whether she went afterward, after you
10
had already gone? Does that make sense?
11
MR. HOROWITZ: No, try that again.
12
BY MR. CRITTON:
13
Q. Okay. Do you know whether you went to
14
Mr. Epstein's first or Jane Doe 3 went to Epstein's
15
first?
16
A. No.
17
Q. You don't remember?
18
A. No.
19
Q. Okay. if I asked you to assume that Jane Doe
20
3 says that she went to Mr. Epstein's after you had
21
already been there, would you dispute that?
22
A. I mean yes, because I don't really know, I
23
don't remember.
24
Q. But so if Jane Doe 3 said no, I asked Jane Doe
25
7 and Jane Doe 7 said she had been to Mr. Epstein's
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Page 341
1
before --
2
MR. HOROWITZ: Fonn.
3
THE WITNESS: If that's what she said --
4
BY MR. CRITTON:
5
Q. Then you would go with her recollection on
6
that?
7
MR. HOROWITZ: Form.
8
THE WITNESS: Yes.
9
BY MR. CRITTON:
10
Q. Do you know how many times -- well, let me
11
strike that, because you don't remember of your own
12
independent recollection who went first, Jane Doe 3 or
13
you.
14
Did Jaw Doe 3 ever express to you that
15
anything inappropriate — let me strike that.
16
Have you ever discussed what Jane Doe 3's
17
visits were with Mr. Epstein? Did you ever discuss that
18
with her?
19
A. No. I mean she shared her feelings about him
20
with me, but she never discussed what happened.
21
Q. And when you said her feelings, is that
22
recently?
23
A. I mean I don't remember if she did back then,
24
but she has recently.
25
Q. Pardon?
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21.
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Q.
A.
A.
A.
Q.
A.
Okay. Did you go out with her?
Yes.
Where did you all go?
Went to Noche.
Up in Palm Beach Gardens?
Yes.
That's at the Soverel Marina?
Yes.
Who else
Just her at
and two other girls I didn't
know.
Q. MM.
nix)?
A.
Q. Do you know whether J.S., was she one of your
friends too back at that time?
A. Yes.
Q. Did she ever go to Epstein's?
A. Yes.
Q. How do you know that?
A. Because she told me.
Q. Why did she tell you? What made her tell you
that?
MR. HOROWITZ: Form.
THE WITNESS: I don't remember.
Page 340
1
A. I don't remember what she said about him back
2
then, but I mean recently she has.
3
Q. And what has she said recently?
4
A. Just that she thinks he's lice a horrible
5
person and she thinks that the justice system didn't
6
work for him at all, and she told me about how he's nov,
7
on probation and out of jail, and just stuff like that.
8
Q. With Jane Doe 3, have you ever met her
9
husband?
10
A. No.
11
Q. Did you know she was married?
12
A. Yeah, she told me.
13
Q. When is the last time you talked to Jane Doe
14
3?
15
A. I talked to her recently.
16
Q. Last couple of weeks?
17
A. Yes.
18
Q. When is the last time you saw her?
19
A. The last time I was down in Palm Beach.
20
Q. Which was when, February?
21
A. No, I don't really remember.
22
Q. Where did you see her?
23
A. Actually I saw her, I was recently, I was here
24
before I went down to Key West and I saw her. It was
25
her birthday.
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Page 342
BY MR. CRITTON:
Q. Did she know that you had been to Epstein's?
A. Yes.
Q. Did she know that you area plaintiff in a
lawsuit?
MR. HOROWITZ: Form.
THE WITNESS: Yes.
BY MR. CRITTON:
Q. How did she know you were a plaintiff in a
lawsuit?
MR. HOROWITZ: Form.
THE WITNESS: I don't know who told her. She
asked me about it.
BY MR. CRITTON:
Q. Did you confinn to her that you had in fact
brought a suit against Mr. Epstein?
A. Yes.
Q. If somebody asks you whether you are a
plaintiff in a lawsuit against Mr. Epstein, do you tell
them yes?
A. If they are one of my close friends. If I
don't know them, no.
Q. Okay. Wein, is she a friend as you
described earlier?
A. Yes.
(561) 832-7500
12 (Pages 339 to 342)
INC.
(561) 832-7506
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Page 343
Page J.]
1
Q. Or a good friend?
2
A. She's a friend, yes.
3
Q. Someone you might trust or you might not?
4
A. She knew about it before when we were in high
5
school.
6
Q. She knew what, that you had gone there?
7
A. Yes.
8
Q. How did she know?
9
MR. HOROWITZ• Form.
10
THE WITNESS: Everybody knew. She was in our
11
friend group.
12
BY MR. CRITTON:
13
Q. So ever/body who was in your Mend group knew
14
who had gone to Epstein's?
15
A. I mean basically it was me, Jane Doe 4,E,
16
lane Doe 3, we were all friends, so we all knew.
17
Q. And did J.S. ever describe her visits, visit
18
or visits to Epstein's?
19
A. I think she only watt once.
20
Q. Did she tell you why?
21
A. Yeah, she said that he like seared her or
22
something and tried to like make her do something and
23
she never went back.
24
Q. Okay. Were you still going to Epstein's at
25
the time you heard that?
1
A. Yeah.
2
Q. And she said she had given a deposition?
3
A. Yes.
4
Q. Do you know if she's married?
5
A. She said she was divorced.
6
Q. She told you she was divorced?
7
A. Or they are separated, not divorced, I think
Q. Which did she tell you?
9
A. !think separated.
10
. Q. Did she tell you why?
11
A. I think she was kind of embarrassed about it,
12
so she didn't really go into detail with me.
13
Q. Did you go to her wedding %Olen she got
14
trawled?
15
A. No.
16
Q. Have you ever — she has a child, doesn't she?
17
A. No.
18
Q. She doesn't have a child?
19
A. No.
20
Q. Jane Doe 3, was she someone, Jane Doe 3, did
21
you see her do, when she drank with you all in high
22
school, alcohol?
23
A. Yes.
24
Q. And did you see her do drugs in high school?
25
A. No.
Page 344
1
A. I don't remember when it was.
2
Q. Did you say to her that never happened to me?
3
A. I don't remember exactly what I told her.
4
just remember her telling me that.
5
Q. Did she say that she has any interest in
6
bringing a lawsuit against him?
7
A. No.
8
Q. Did she ask you how your lawsuit was going?
9
A. Na
10
Q. When you saw Jane Doe 3, you went to Noce,
11
what time did you all meet?
12
A. I think around eleven. I was driving home
13
from Orlando to visit my parents and then go to Key
14
West.
15
Q. And how long did you stay?
16
A. Not long just like two hours.
17
Q. Had a couple of drinks and then headed home?
18
A. Yes.
19
Q. Did Jane Doe 3 tell you that she had given her
20
deposition at that point?
21
A. [don't think she has given it yet, at that
22
point, no.
23
Q. But you subsequently talked to her?
.24
A. Yes, recently.
25
Q. Over the phone?
(561) 832-7500
Page 346
1
Q. Okay. So if she was doing cocaine or erctacy
2
or xanax, again, you never saw it?
3
MIt HOROWITZ: Form.
4
THE WITNESS: No. My friends knew I didn't do
5
it, so some of than would tsy 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 too 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 tirne I beard
13 (Pages 343 to 346)
(561) 832-7506
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Page 347
about it w'
asking me to go. And then after that,
II
remember Jane Doe 4 talking about it and then
Q. And you said
asked you to go. And at
that time I think you said it was, you remembered it
being in gym class or something like that.
A. Yes..
Q. AndM. was in your grade?
A. She was a grade ahead of me, but anybody could
have gym together.
Q. So what specifically clid
say to you, your
best recollection?
A. She asked me it if I needed a job and if I
needed money, and then she asked me if I knew how to
give a massage. And I said yes, but not professionally.
And she told me that was fine.
And then she told me how she knows a guy that.
lives in Palm Beach and will pay me if I give a massage.
Q. You had been to Palm Beach before?
A Yes.
Q. And I assume based on what you told me earlier
you had been to the beach in Palm Beach?
A. Yes.
Q. And had your dad driven you over there in Palm
Beach because this is where I work, this is the kind of
Page 349
1
A. No.
2
Q. All right. She just said "If you want ajob,
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 este when she said, you know.
12
you can make some money, did she tell you how much you
13
could make?
14
A. Yeah, l think she said 5200.
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
*bout it"?
21
A. I told ha 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. 'just
Page 348
1
houses i inspect?
2
A. He works like downtown. He doesn't work like
3
on Palm Beach island.
4
Q. Where does he work when you say downtown, West
5
Palm? That's where his office is?
6
A. Yeah, West Palm.
7
Q. Okay. Had he ever driven you over there?
8
A. I mean yeah, he's driven over there to go to
9
the beach and stuff.
10
Q. Had you walked up and down at times, you and
11
your mom at times walked up and down Worth Avenue and
12
then gone over to the beach just to look?
13
A. !mean yeah, i guess.
14
Q. It's a tourist spot?
15
A. Yes, I've been to Worth Avenue before.
16
Q. All
you were familiar with Palm
17
Beach befo
said — so when she said there is a
18
guy over in Palm Beach, you knew where Palm Beach was
19
and you had been on the island before, correct?
20
A. Yes.
21
Q. And did she tell you how old the person was,
22
how old this guy yeas?
23
A. No.
24
Q. She didn't tell you whether he was 20 years
25
old or 50 years old or 100 years old?
Page 350
1
was interested in making money, I
2
Q. So when is the next time yottle
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
going to go a particular day?
19
A.
told me. i guess she made plans with
20
Sarah or Jeffrey.
21
Q. Tell me what you know
at you guess. St
22
let me ask you again. What di
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
(561) 832-7500
14 (Pages 347 to 350)
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Page 351
Page 353
1
rememberus
mg there.
2
Q. As=
drove?
3
A. Yes.
4
Q. What did she have at the time? Did she have a
5
car, a truck, SUV?
6
A. She had a truck.
7
Q. What did it look like, do you remember?
A. Maroon.
9
Q. Maroon, all right. Now before you went, did
10
you talk with her again and say "Okay, what am 1
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 meat to you or what did that mean
17
to you?
18
A. I don't know. f 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?
1
A. Yes.
2
Q. What did you anticipate, and their arms and
3
their hands and their feet, necks, their head sometimes?
4
A. What did 1 anticipate I was going to do?
Q. All right. If you — had you seen that on TV?
6
A. I mean yeah, !guess.
7
Q. Okay. So if you had seen that on TV, did you
8
assume that when you went over to earn money to do a
9
massage and you weren't, as you said, you weren't a
10
professional, that you were going to give some guy a
11
massage, so you would be massaging basically a large
12
part of his body?
13
A. Yes.
14
Q. And you understood, or I assume from having
15
seen it on TV, you understood that people who have
16
massages, males or females, oftentimes they are on
17
either their back or their stomach and then their
18
private parts are covered only with a towel, but they
19
are naked underneath?
20
A. Yes.
21
Q. All right. Now, so you are going over there,
22
at leas= tells you you are going to get 200 bucks
23
for giving a massage fora guy, so you knew it was a
24
male.
25
Did you ask her at the time how old is this
Page 352
1
A. Yes.
2
Q. Did you say "Wait a minute, why do 1 have
3
to — even if we're going to the beach afterwards, why
4
do I have to dress cute for this massage?"
5
A. I don't, I don't really remember. 1 was
6
confused.
Q. What's confusing about that?
8
A. 1, she could have meant like dress, you know,
9
professionally, like massage people dress cute, I don't
10
know. I was like 16. I don't remember.
11.
Q. Okay. Where had you ever seen -- had you ever
12
had a massage yourself?
13
A. No.
14
Q. Had you ever been to a spa?
15
A. No. I have seen spas before. I have never
16
actually been.
17
Q. Had you ever seen anyone have a professional
18
massage?
19
A. Yeah, like on W I have seen people. Not like
20
in person, but I have known the —
21
Q. And do you know when you give someone a
22
massage, that is a professional massage, you are
23
massaging their legs and their thighs and their back and
24
their neck, and then they flip over and you do the front
25
of their legs, things like that?
Page 354
1
person?
2
A. No.
3
Q. Why not?
4
A. !just, I didn't think about it. I remember
5
asking her like why he doesn't just hire somebody to
6
give him a massage, and she told me he doesn't like
7
professional people, lace professional massages.
8
Q. Okay. As you described yourself earlier, you
9
said you arc of above average intelligence, so did you
10
say to her at that time wait a minute, why doesn't —
11
you had certainly the common sense to say why doesn't he
12
hire a professional masseuse, and she said well, he
13
doesn't like those.
14
Did that send off a little bell in your head
15
to go gee, why am I going and getting paid $200 versus a
16
professional massager, masseuse?
17
MR. HOROWITZ: Form.
18
THE WITNESS: I mean I didn't know. I didn't
19
really think about it.
20
BY MR. CRITTON:
21
Q. You thought about it enough to ask why doesn't
22
he get a professional, right?
23
A. Yeah.
24
Q. Did you say okay —1 assume when you have
25
seen people on TV give massages, you have seen they have
(561) 832-7500
15 (Pages 351 to 354)
INC.
(561) 832-7506
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Page 355
been in basically in uniform, sometimes they are in a
2
white uniform or may have a polo shirt on and pants or
3
shorts, right?
4
MR. HOROWITZ: Form.
THE WITNESS: Yes.
6
BY MK CRTITON:
Q. Have you ever seen people again separate and
8
about from — well, let me strike that.
9
Have you ever seen people give massages in the
10
movies, other than when a guy is giving a girl a massage
11
that they have a relationship, where someone shows up in
12
a swimsuit or a cute little tank top and a skirt?
13
MR. HOROWITZ: Form.
14
774E WITNESS: No.
15
BY MR. CRITTON•
16
Q. All right. St
tells you to dress cute.
17
You are going to give a guy who doesn't want
18
professional massage a massage, and you arc not
19
masseuse, right?
20
A. Yes.
21
Q. And you didn't ask how old he is, correct?
22
A. Correct
23
Q. Okay. Did you ask who was going to be there?
24
A. No.
25
Q. Did you ask where it's going to be done?
Page 357
1
A. I think she might have said that.
2
Q. Did she, did you express any concern, like is
3
this guy going to be pushy? Is he nice? Is he an angry
4
kind of person? You know, is he going to be physical
5
with me or verbally abusive in any way?
6
Did you ask any of those questions?
7
A. No.
Q. Did she say anything when you said — I said
9
did she say anything about that she he was nice and you
10
wouldn't have to worry, and you said you remember her
11
saying something about him being nice, right?
12
A. Yes.
3
Q. Okay. Did she say that he wouldn't use any
14
physical force or violence or any kind of coercion, that
15
you could feel safe?
16
MR. HOROV/ITZ: Form.
1 7
THE WITNESS: I mean she never said it that
18
way.
19
BY MR. CRTITON:
20
Q. Did you assume that?
21
A. When she said he was
22
done it, I assumed it
23
Q. Okay. Did she tell you if he, if you are
24
asked your age, to say you are over 18?
25
A. No.
nice and she's already
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 356
A. Yes.
Q. And she said?
A. At his house.
Q. Okay. Did you say "Why are we doing it at his
house?"
A. I don't remember.
Q. Did you say "Where are you going to do it in
the house?"
A. I don't remember.
Q. Did you ask her "Am I going to M., are
you going to be there too?"
A. She was the one that was bringing me, so yeah,
I obviously assumed she was going to be there.
Q. So you assumed she was going to be there. So
what, did you say "What parts of his body do I have to
massage?"
A. Uh uh,
ask She told me like —
Q. Go ahead.
A. She told me his legs and his feet is what she
usually does, but I then never
really.
Q. Okay. Do you remem
telling you that,
in fact, it was an older man, late miles, fifties?
A. No.
Q. Do you remember her telling you he was a nice
guy?
Page 358
1
Q. So in.
says that's what she told you, that
2
would not be hue or you just don't remember?
3
A. No, that would be a lie.
4
Q. Kind of like what you told the Palm Beach
5
police?
6
MR. HOROWITZ: Form, argumentative.
7
BY MR. CR1TTON:
8
Q. Right?
9
A. I guess you would say that.
10
Q. Did she ever say anything that you might be
11
asked to remove your clothes or take off an article of
12
clothing?
13
A. No, not the first time I went.
14
Q. Did she ever give you any indication that you
15
should be — well, let me strike that.
16
Okay, so she makes an arrangement for a time.
17
You don't know how, but she tells you we're going over
18
there at such and such a time, dress cute, right?
19
A. Uh huh.
20
Q. Yes?
21
A. Yes.
22
Q. She pit you up?
23
A. I don't — we 'night have left after school.
24
Q. So you might have left right from school?
15
A. Yes.
16 (Pages 355 to 358)
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Page 359
Q. Did you just take clothes with you from
2
school?
3
A. Well, we were going to the beach after, so I
4
probably, l remember wearing my bathing suit.
Q. Did you in fact go to the beach afterwards?
6
A. Yes.
Q. In Palm Beach?
A. Yes.
9
Q. All right. So do you remember what time of
10
year it was now? In thinking of that, it had to have
11
been warm if you were going to the beach or at least
12
decent.
13
A. Yes.
14
Q. And it was just the two of you?
15
A. Yes.
16
Q. On the way over there, did you discuss what
17
you were going to be doing? Were you nervous at all?
18
A. I mean f was a little bit nervous, but I — we
19
didn't really talk about what we were going to be doing.
20
Q. So you got to the house. Did she park on the
21
driveway or on the street?
22
A. The driveway.
23 S.
When you got out of the ear, did you say to
24
at any time before you got out of the car, "You
25
know, this doesn't seem like a great idea, I think I
Page 361
1
A. 1 think so. I don't remember what I ate. I
2
remember
like offering food. He was cooking.
3
Q. Art
went upstairs. Did Mr. Epstein come
4
down?
5
A. No, I think she just came back down and told
6
me to go upstairs.
7
Q. Told you to go upstairs?
8
A. Yes.
9
Q. Tice first time that you went to the
tein
10
home, did you actually go up or did
'
onl
go up?
11
A. I remember I went once wit
hen she just
12
went up.
13
Q. Was that the first time?
14
A. Yes, I think that was the first time.
15
Q. So the first time you were there --
16
A. Or actually — I don't remember correctly.
17
Q. Okay.
18
A. I don't, I l WIAlliber just going once with her
19
when she did her s
And then —
m
20
Q. She eani
21
A. Yes. So yeah, I remember the first time 1
22
went there to do it.
23
Q. Da
tell you she had been there before?
24
A. Yes.
25
Q. Okay. So at least onetime you went wit=
Page 360
1
don't want to do it"?
2
A I mean no. When I got there, I was kind of
3
conflated by everything, but I didn't really say that to
4
her.
5
Q. Why not?
6
A. I mean I didn't know what was going to go on.
7
Q. Well, you could have
t time turned
8
around and said, "You know
I don't really feel
9
like doing this," right?
10
A. Yes.
11
Q. So you had to -- again, it was your decision.
12
You could either say yes or no, and you said yes, I'm
13
going to go into the house, right?
14
A. Yes. I mean the first time she didn't tell me
15
what was going on at all, so —
16
Q. You go in the house. Was
there?
17
A. There was a cook there
18
Q. And you were in the kitchen?
19
A. Yes.
20
Q. And what happened then?
21
They just like offered me food and water and
22
Milinlintroduced herself to rne. And she went up and got
23
Jeffrey.
24
Q. Okay. Did you eat anything when you were
25
there?
Page 362
1
where she went up and gave the massage and you just sat
2
in the kitchen?
3
A. Yes.
4
Q. Do you remember that being the first time or
5
another time?
6
A. I think it was
no, it was the second time,
7
because I didn't know the first time what —
8
Q. Okay. So the first timMeme back down
9
and she said you can go upstairs?
10
A. Yes.
11
Q. Did she take you upstairs?
12
A. Yeah, she walked up there with me.
13
Q. So you followed her?
14
A. Yes.
15
Q. Did you go up a stairway, I assume?
16
A. Stairway, yeah.
17
Q. Anything unusual about the stairway?
18
A. There were just like weird pictures like on
19
the skle of the wall.
20
Q. Of what?
21
A. They were pictures of like girls, pictures of
22
boobs, pictures of like weird drawings.
23
Q. Arts kind of pictures?
24
A. Arts, but then there was some kind of weird
25
pictures of girls with boobs and naked pictures.
(561) 832-7500
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1
Q. Describe — you said there were some art
2
pictures on the wall that had what, naked people or
3
portions of torsos or something?
4
A. Yeah.
5
Q. And then you saw a picture of
another
6
picture where women were, didn't have tops on?
7
A. And I saw a picture of a little girl.
8
Q. Okay. And how was she dressed?
9
A. She had like a dress on.
10
Q. All right.
11
A. I think that was his daughter that I saw there
12
before.
13
And then I walked into the room and there were
14
more pictures there of girls and weird art pictures.
15
Q. Again, just, you say weird art pictures,
16
just -
17
A. Just I don't know, weird torso and boob
18
pictures, I guess.
19
Q. Of different parts of bodies, pictures?
20
A. Yes.
21.
Q. And there were other pictures of girls?
22
A. Yes.
23
Q. Anyone that you recognized?
24
A. No.
25
Q. Anyone that you had ever seen at the house?
Page 365
1
A. Yes.
2
Q. Did she tell you what you were supposed to do
3
or what you were supposed to use or anything like that?
4
A. She said there was like massage oil, and she
5
like pointed to the massage oil. And that's all I think
6
I can remember her saying.
7
Q. Were you nervous at all?
8
A. Yes.
9
Q. Did you say UM "You knew what, I dont
10
think I want to do this, l think I'm out of here"?
1
A. I fek like I was kind of pressured and put in
12
a weird position where I just felt hie I kind of had to
13
do it because I
there.
4
Q. Becaus
had put you in that position?
15
A. I mean -
16
MR. HOROWITZ: Form.
17
THE W'ffNESS: Well, Jeffrey walked in.
18
BY MR. CRITION:
19
Q. No, before Jeffrey got there.
20
A. Well, not just because'
no. Just in
2.1
general, I already said I would do it.
22
Q. Because you committed kind of?
23
A. Yes.
24
Q. So you felt that you — well, all right So
25
you got up there, she shows you the lotions. Does=
Page 364
1
A. I don't think so.
2
Q. Were they clothed or unclothed?
3
A. I think they were undressed.
4
Q. Completely or just tops?
A. I remember their breasts were showing.
Q. That's what you remember seeing?
7
A. Yes.
Q. And you don't know who they were?
9
A. No.
10
Q. Or how old they were?
11
A. No.
12
Q. Did they appear to be adults to you?
13
A. They could have..
14
Q. So then you go i
walks you into a
15
room?
16
A. Yet
17
Q. And whafs there?
18
A. There was a shower, like a vanity, the massage
19
table. She like already had it set up.
20
Q. Had you ever seen a massage table before?
21.
A. Just not
l mean in movies.
22
Q. Movies again. Did she say anything to you?
23
A. She just said that Jeffrey would be in
24
shortly.
25
Q. And did she leave then?
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Page 366
leave before Jeffrey comes into the room?
A. I think so, yes.
Q. Okay. So you are what, just standing by the
table?
A. Yeah.
Q. And what happens?
A. And then Jeffrey comes in.
Q. And what's he do? How is he dressed?
A. I think he just had a towel around him.
Q. Okay. What color was the towel?
A. White.
Q. And describe it.
A. He just had it like around his waist.
Q. Describe Mr. Epstein.
A. Like his body?
Q. Yes. Tall, short?
A. He's a taller guy, has gray hair, kind of
hairy, kind of bigger, not fat, but like bigger build,
blue eyes, like a longer face.
Q. All right Did he introduce himself?
A. Yes.
Q. What did he say?
A. Just said "Hi, I'm Jeffrey."
Q. And you said?
A. I said, "Hi, I'm Jane Doe 7, Es friend."
18 ( Pages 363 to 366)
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Q. Did you shake hands?
2
A. I thirdcso.
3
Q. And what did he do?
4
A. And then that's when he got on the massage
S
table and he, that's when basically like the first time
lgave a massage and he said that he would like his feet
7
and his calves massaged, and he was turned over.
Q. So he was on his back. How long did the
9
session last?
10
A. It lasted for about, about half an hour, I
11
think.
12
Q. About 30 minutes?
13
A. Yes.
14
Q. All right. And did you massage his feet?
15
A. Yes.
16
Q. Did you pick the oil that you were going to
17
use?
18
A. Yes.
19
Q. Had you ever used massage oil before?
20
A. No.
21
vita
did you know which one to pick, just from
22
told you?
23
A. Yes.
24
Q. So you used the massage oil. You did his
25
calves and his feet?
1
Q. Next to his right ann?
2
A. Well, I mean if you are looking at him this
3
way, I was over here.
4
Q. Well, you say he was lying down, so as he was
5
lying down, were you near his right shoulder or his left
6
shoulder?
7
A. When he was lying down, l was near his left
8
shoulder.
9
Q. As you were massaging his chest —
10
MR. HOROWITZ: You mean lying down en his back
11
or his stomach?
12
BY MR. CRITTON:
13
Q. You said he was lying on his back?
14
A. Yes.
15
Q. So you were near his right shoulder?
16
A. His left shoulder.
17
Q. His left shoulder, all right. And were you
18
standing at his side er were you standing at the top of
19
his head, massaging his chest?
20
A. On the side.
21
Q. All right And you say you Is.ard a humming
22
and then what happened?
23
A. And then he just started reaching under his
24
towel and then he kind of like grabbed, he grabbed me
25
towards him and pulled me towards him.
Page 368
1
A. Yes
2
Q. Did he turn over then?
3
A. Towards the end, yes.
4
Q. So after what, you are 90 percent done, then
5
he turned over?
A. Yeah.
7
Q. Okay. And he had a towel over him the entire
8
time?
9
A. Yes.
10
Q. Okay. And when he turned over, what did
11
you — did you continue the massage?
12
A. He turned over and then he asked me if I could
13
like massage his chest.
14
Q. And did you?
15
A. Yes.
16
Q. All right. And then what?
17
A. And then I was massaging his chest, and I
18
don't know, he started making noises.
19
Q. Like what?
20
A. Just like humming noises.
21
Q. Hununing?
22.
A. Yeah. Just, I don't know, weird noises. And
23
then — .
24
Q. Were you standing to his left or his right?
25
A. I was standing on his right.
Page 370
1
Q. Where did he grab you?
2
A. He grabbed my buttocks and pulled me to him.
3
Q. When you say grabbed you, he put his hand
4
behind your buttocks and pulled you toward him?
5
A. Yes.
6
Q. Which hand?
7
A. His left hand.
8
Q. When he did that, what did you do?
9
A. Felt really awkward arid got really scared. I
10
think he could tell I was scared. And I got nervous and
11
he, he kind of asked me if I was okay.
12
And I just told him I felt, I felt nervous.
13
And that's, that's when he like started to masturbate,
14
and that's when —
15
Q. How do you know he was masturbating?
16
A. Because I could, I could tell.
17
Q. Had you ever seen a guy masturbate before?
18
.
A. .Yes.
19
Q. Where?
20
A. Die on TV.
21
Q. On what, like a porno movie or something like
22
that?
23
A. I don't know, I knew what it was.
24
Q. Everybody learns about it at some point in sex
25
education, right, male and female masturbation, right?
(5 6 1) 8 32 — 7 50 0
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Page 373
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A. Yes.
2
Q. All right. It's part of life. You had seen
3
it on TV before? Yes?
4
A. Yes.
5
Q. lied you seen it in the movies before?
6
A. Yes.
7
Q. All right. Had you ever seen it in person
8
before?
9
A. No.
10
Q. All right. So you figured that's what he was
11
doing under the towel, right?
12
A. Yes.
13
Q. All right. You didn't see it, you just
14
assumed that's what was going on?
15
MR. HOROWITZ: Form.
16
THE WITNESS: Yes.
17
BY MR. CRITTON:
18
Q. All right. So had he let go of you Men? He
19
put his hand on your butt and pulled you toward him,
20
when you said you felt awkward, scared and nervous and
21
he sensed that and you said "Im nervous," did he let go
22
of you?
23
A. No.
24
Q. Okay. Did he continue to hold on to your
25
butt?
1
Q. Okay. Did he get up then?
2
A. Yes.
3
Q. Keep the towel around him?
4
A. I know he like put on, grabbed a new towel,
5
and then I walked around the side and he got his money
6
and gave me the $200.
7
And then he asked me for my number. And he
8
told me ifl had a friend, asked me if I had a friend
9
that wanted to make money.
10
Q. And you said? So he asked you for your number
11
and said if you had a friend who would like come --
12
A. Yes,
13
Q. What?
14
A. l le said if I brought a friend, then I would
15
make money.
16
Q. Okay. And he gave you $200. You felt
17
awkward, scared and nervous.
18
Did you give him your phone number or did you
19
give him just a fake phone number?
20
A. I gave him mine.
21
Q. But you could have said "No, thanks, I'm done,
22
Pm not going to give you my phone number," right?
23
A. Yes. I just felt scared and intimidated, so I
24
gave him my number.
25
Q. But you could have given him any phone number,
Page 372
1
A. Yes.
2
Q. Did you ever — had you removed any clothing?
3
A. No.
4
Q. Had he ever asked you to remove any clothing?
5
A. I think the first time, I fen so like nervous
6
and awkward, I don't think he asked me, no.
7
Q. Well, all right. So your best recollection is
8
he didn't ask you to take any of your clothes oft?
9
A. The first time.
10
Q. So he pulled you towards him. You felt
11
awkward, scared and nervous, right?
12
A. Uh huh.
13
Q. You told him — yes?
14
A. Yes.
15
Q. And you told him that?
16
A. Yes.
17
Q. Okay. And then he was, from your perspective,
18
was masturbating under the towel?
19
A. Yes.
20
Q. And then what happened?
21
A. And then he was just making noises. And I
22
didn't see him ejaculate, but I'm assuming he
23
ejaculated, because he stopped. And then that was --
24
Q. That was it?
25
A. Yes.
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Page 374
true?
A.
Q.
A.
Q.
A.
Q. Did you feel in any way embarrassed or
humiliated?
A. I was kind of confused. Like he was like an
older, powerful man and, you know, I just felt confused
about the whole situation at that point.
MR. CRITTON: Okay. Let's take a break.
THE VIDEOGRAPHER: Going off the record at
5:28 pm. This marks the end of tape three.
(Disclicsion held off the record.)
THE VIDEOGRAPHER: We are back on the record
at 531 p.m. This marks the beginning of tape
four.
BY MR. CRITTON:
Q. You said that you thought Mr. Epstein — did
you know what his last name was at that time or you just
knew his name was Jeffrey?
A. I thinkl knew, just thought it was Jeffrey.
Q. You said when he walked in the room, obviously
you knew that he was, you know what his approximate age
Umm, I suppose.
Okay. Did you feel intimidated?
Yes.
Did you feel uncomfortable?
Yes.
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Page 375
Page 377
1
was?
2
A. He looked older, yes.
3
Q. All right. When you say older, how old does
4
that mean?
5
A. He looked like he was like 45, 50.
6
Q. You said he was powerful. What made you think
7
he was powerful?
8
A. 1 could just tell by his house.
9
Q. Just because he had a big house?
10
A. Yes.
11
Q. Did you know anything about him?
12
A. No.
13
Q. During the eight to ten times you claim that
14
you went, did you ever learn anything about him, what he
15
did fora living?
16
A. Yes, I think he told somebody —
17
Q. No, what he told you, not somebody.
18
MR. HOROWITZ: No, no, that's how she learned.
19
She is explaining to you.
20
BY MR. CRITTON:
21
Q. Let me stick with my question. Did you ever
22
learn from him what he did?
23
A. No, he would talk about his friends in finance
24
and he would be on phone calls sometimes when I was like
25
giving him massages.
1
money foe.?
2
A. No.
3
Q. Did you well, let me strike that. He gave
4
you $200 he asked for your phone number and you
5
voluntarily gave it to him, correct?
6
A. Yes.
7
Q. He asked you if you ever wanted to bring
8
someone else that wanted to come, he'd pay you to do
9
that?
10
A. Yes.
11
Q. Did he tell you how much he'd pay you to do
12
that?
13
A. 200.
14
Q. And I think you described yourself at that
15
point as awkward, you felt the situation was awkward.
16
scared, I think you used the word weird, you thought it
17
was inappropriate and you felt uncomfortable. Fair?
MR. HOROWITZ: Form.
19
THE WITNESS: Yeah.
20
MR. HOROWITZ: Confused too.
21
BY MR. CRITTON:
22
Q. Let's put confused there too. I'll add that.
23
So as you left, you gave him your phone
24
number, you listened to what he said about bringing
25
somebody else, and what happened then? Did he go off?
1
2
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Q. Yawn he gave you the $200, did he give you any
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Page 376
And then he talked to me about how his friends
like own yachts and, you know sail, because I told him I
wanted to get into hospitality and travel. So he told
me about his friends, and he said he would introduce me
to one of his friends if I wanted to, because his friend
has like a yacht, and 1 could work on his yacht and just
stuff like that. So 1 just kind of assumed things.
Q. The friends, did he ever tell you who his
friends were?
A. I saw pictures of like Bill Clinton, I think,
10
and 1 saw a picture with Donald Trump. He never told me 11
who they were.
12
Q. He just said he had friends?
13
A. Yes.
14
Q. And you saw some pictures?
15
A. Yes.
16
Q. And you dont know whether those people were
17
his friends or not, you just know that you saw pictures
18
with those people?
19
A. I mean he had his arm around them and they
20
looked like they were friends.
21
Q. So Mr. Epstein was in the picture, one picture
22
with Trump, another picture with Clinton?
23
A. Yes.
24
1
2
3
4
5
6
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8
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Page 379
A. Yeah, I just left witty
Q. No, no, did he go off before you went back
downstairs?
A. Like walked off?
Q. Did he leave the room?
A. I think he just walked me to the stairs.
Q. And he still had a towel around him?
A. I think so, yeah, or a robe maybe.
Q. You never saw him completely naked that day,
did you?
A. No.
Q. Then he wallatyau to the stairs, you went
back down the staff rl=
was still there?
A. Yes.
Q. And did you have anything to eat or drink
before you left?
A. No.
Q. Did you see
again?
A. Yeah, l saw
w
I was leaving.
Q. Did she say anything to you?
A. Just goodbye, I think. Something like that.
Q. And what did you say?
A. Just said bye. Just wanted to get out of
there.
Q. You wanted to get out of there because you
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Page 379
1
thought it was a really weird situation; fair statement?
2
A. Yes.
3
Q. And you were very uncomfortable and scared and
4
nervous, true?
S
MR. HOROWITZ: Form.
6
THE WITNESS: I mean yeah, I was confused by
everything. I saw like a rich, powerful guy, and
then he was, you know, and very nice to me, but at
the same time like I, you know, Mt uneasy and
just confused by everything that was going on.
BY MR. CRITTON:
Q. Had you ever been with a guy before, a male
before where he had masturbated, even if you didn't see
A. No.
Q. Had you ever been with one of your, a guy
friend and the guy had masturbated?
A. No.
Q. Or you thought he was masturbating?
A. No.
Q. You both leave the kitchen, you leave the
house, you get back in the truck.
A. (Witness nods head up and down.)
Q. Do you start screaming a=
going "What in
God's name did you get me into here"
Page 381
1
A. Yeah.
2
Q. All right. You just went to that beach,
3
parked at the meters, and just went down to the beach
4
fee a while?
5
A. Yes.
6
Q. And then to get home from there, what is it,
7
about a 30-minute ride?
8
A. Yes.
9
Q. So you ancM. go to the beach fora period
10
of time and you ride home. Were you aware wheth.
11
had received any money at that point?
12
A. I don't remember.
13
Q. Did you learn later that H.R. had received
14
money?
15
A. Yes.
16
Q. Did she tell you?
17
A. I don't remember if she told me. I think she
18
did.
19
Q. Did she tell you how much money she received?
20
A. I think just 200, like he pays everybody.
2 1
Q. And were you offended that she had received
22
S200 for bringing you?
23
A. I don't remember what I thought back then.
24
Q. Dld, when you were on the beach or on the way
25
home, so there bad to have been at least 30 minutes plus
Page 380
1
A. Actually, I was just like really embarrassed
2
about everything, and I forget my conversation with her
3
that day, though.
4
Q. Well, did you say to her — did she say
5
anything to you like "Well, everything go okay?"
6
A. No.
7
Q. So how far — did she take you home or did you
8
guys go to the beach?
9
A. I believe we went to the beach after that.
10
Q. How long did you stay at the beach?
11
A. I don't remember.
12
Q. An hour, ten minutes, five minutes?
13
A. I have no idea.
14
Q. Did you go in the ocean?
15
A. I don't remember. I just remember we went to
16
the beach after that.
17
Q. And then you went home. Did she drive you
18
home?
19
A. Yes.
20
Q. What's it from Palm Beach to the beach — did
21
you go to the beach off of Worth Avenue, that area?
22
A. Just when you keep driving straight down
23
Okeechobee to -- yeah, the one straight, all the way
24
down.
25
Q. The end on Royal Palm Way?
Page 382
1
the time you rode from Mr. Epstein's house to the beach,
2
sat there a while
nutes, an hour, maybe longer,
3
did you ever, di
ever ask you what had happened or
4
if you were okay, what had happened?
5
A. I don't remember. It was seven years ago. I
6
don't remember what we talked about.
7
Q. Well, depending on the time period, maybe five
8
years ago.
9
A. Five,
10
Q. Maybe six years ago, maybe seven years, fm
11
not sure, based on your
r testimony.
12
So you woe wi
Did you express any
13
anger-
14
A. I'm mean I'm sure I was angry —
15
Q. Let me finish the question. Did you express
16
any anger or anxiety to her with regard to what had
17
occurred between you and Mr. Epstein?
18
A. I mean Fm sure she could tell I was
19
uncomfortable and upset because of what happened, but I
20
don't rernanber what I said to her, what she said to me
21
exactly.
22
Q. Why would she notice that you were upset?
23
A. Because she didn't tell me everything that was
24
going to go on, so of course I would have been upset.
25
Q. Why? How would she know that you were upset
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1
if you didn't express it?
2
A. I don't remember if I said something about
3
her -- I mean I'm sure I did say something like why
4
didn't you tell me the whole story or something like
5
that, but I don't --
6
Q. Did you feel that you had been misled?
A. Yes.
3
Q. Did you feel that.
had deceived you?
9
A. Yes.
10
Q. Did you feel that she had misrepresented the
11
circumstances of you giving the massage?
12
A. Yes.
13
Q. Did you feel she had lied to you?
14
A. I just felt like she didn't tell me everything
15
that was going to go on.
16
Q. All right. So did you express something like
17
that to her?
18
A. I'm sure I did. !just don't remember exactly
19
what I said.
20
Q. Okay. And did you tell her, do you remember
21
telling her you felt the situation was awkward, you were
22
scared, you were nervous, you were confused, you were
23
uneasy, you thought that his actions were inappropriate,
24
you felt uncomfortable?
25
Did you tell her all that?
Page 385
1
deceived you and misrepresented what was going to occur,
2
why didn't you then at that point say no way under God's
3
green earth am I going back to Mr. Epstein's house again
4
under any circumstances?
5
A. Just because I was young and I wasn't thinking
6
and I was just confused, and I heard my friends started
7
going there and then, you know, waited a little bit.
8
And I mean, I don't know, I just wasn't in the right
9
mindset. I was —
10
Q. Well, you knew that he couldn't force you to
11
go back, right?
12
A. Yes.
13
Q. And you knew he had no power over you? Once
14
you left that house, from your perspective, you were no
15
longer committed to anything, you never had to go back.
16
you never had to go back to Mr. Epstein's house for any
17
reason under any circumstances, did you?
18
A. No.
19
Q. Okay. And you could have said I found what I
20
did inappropriate, Pm embarrassed, I'm humiliated about
21
going, I'm not going back?
22
MR. HOROWITZ: Form.
23
BY MR. CRITTON:
24
Q. You could have marksaigt decision right then
25
and there on the beach with= that day, right?
3
Page 384
1
MR. HOROWITZ: Form.
2
BY MR. CRITTON:
3
Q. Or something like that?
4
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
8
you yourself?
9
A. Yes.
10
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
13
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 l 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 Ilia
ad
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Page 386
A. Yes.
Q. All right. And you felt embarrassed and
humiliated, didn't you?
MR. HOROWITZ.: Form.
THE WITNESS: Yes.
BY MR. CRITTON:
Q. All right. Did you think it was kind of
traumatic what he had done? You had never seen a guy or
you had never been in the presence where another male
had masturbated. Even though you didn't see him, that's
what you thought he was doing, right?
A. Yes.
Q. All right. And that you found completely
inappropriate, right?
A. I mean yes. I was just confused at the time.
Q. What's there to be confused about? You came
away from that experience having been embarrassed and
humiliated. You felt the situation was inappropriate.
You were uncomfortable, scared and nervous.
What would you ever be thinking why you would
have any interest in going back to Mr. Epstein's after
that occasion?
A. Well, I wasn't planning on going back for a
Italia
And then I just heard girls stared going
and
alled me and asked me if I wanted to bring
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Page 387
1
anybody, and tibriLotber girls started going, and that's
2
when I believe= asked me about it (MI one of
3
them. And that's when I took one of those girls.
4
Q. All right Soon the second occasion is when
5
you took somebody else?
6
A. Yes.
7
Q. All ri t. So on the second occasion you took
8
either
, right?
9
A. Yes.
10
Q. Do you remember which one now, having thought
11
about it?
12
A. No. I mean I {mow now I'm pretty sure it
13
wa.,
but I can't remember which one I
14
took first.
15
Q. All right. And, all right, on the second
16
occasion you said= called you and asked you whether
17
you wanted to come back or whether you had someone else
18
that would like to come?
19
A. Yeah, she said either.
20
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
say?
1
2
3
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Page 389
Q. And did you say sit back and think — did you
say to yourself I'm sorry I ever gave him my phone
number?
A I just tried not like to think about it I
just, I don't remember.
Q. Did you say geez, that was a traumatic
experience for me, l don't want to go back there or have
anything to do with those people?
MR. HOROWITZ: Form.
THE WITNESS: I don't remember exactly.
BY MR. CRITTON:
Q. Okay. But again, when you heard iron=
did all those feelings of being uncomfortable and
anxious and scared, did all those feelings come back to
you when she called you?
A. Yeah, a little bit.
....
And did you say to yourself, you know, when
strike that.
Wher=called you and asked you if you
wanted to bring someone else, did you say no?
MR. HOROWITZ: Form.
THE WITNESS: I believe I just said I didn't
know and I'd call her back.
BY MR. CRITTON:
Q. All right Did you then decide right, I'm not
Page 388
1
A. She asked me both if I wanted to come work or
2
if 1 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. CRTTTON:
7
Q.Whssibitsaid that — again, you have never
8
texted widt= have you?
9
A. I don't remember. I don't think so.
10
g You never communicated by Facebook or social
11
networking "=
12
A. No.
13
Q. Or Imam on behalf of Mr. Epstein?
14
MR. HOROWITZ: Fenn
15
THE WITNESS: No.
16
BY MR. CRITTON:
17
Q. All right And when you talked witMand
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. '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.
Page 390
1
calling this lady back, I want nothing to do with them?
2
A. I don't know what I decided o
than I 'Int
3
ranembe= found out about it
4
asked me if I went and if I could bring her.
5
Q. And did you say you had been there?
6
A. Yes.
7
Q. Okay. And why didn't you, when you said you
8
had been there and she said "Could you take me," why
9
didn't you just say "Go talk t'
I have got no
10
interest in going back"?
11
A. Because she asked me to take her and I 'mew I
12
could make money. And I told her, you know, what
13
happened. And she said that she wanted to make money or
14
needed money, so —
15
Q. So you were going to make money of.
16
making money by taking her to Mr. Epstein's. Did you
17
consider yourself acting as a pimp?
18
MR. HOROWITZ: Form.
19
THE WITNESS: No.
20
BY MR. CRITTON:
21
Q. Pardon?
22
A. No.
23
Q. What did you consider yourself doing? What
24
was your role?
25
A. If she, if I brought her there and told her
24 (Pages 387 to 390)
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Page 391
nothing lit,
did mc, there is like a difference.
Q. Okay. So did you to
what had happened
with you?
A. Yes.
Q. Okay. a
you told her exactly what you
just told us had happened?
MR. HOROWITZ: Fam.
THE WITNESS: Yes, at the time I told her what
happened.
BY MR. CRITTON:
Q. And did you tell her that you had massaged
him, including his chest, he had turned over and then he
had masturbated under a towel?
A. Yes.
Q. And she said what, no problem?
A. She said she still wanted to go.
Q. All right. And did you tell her that you
found the whole situation with Mr. Epstein weird and
awkward?
A. Yes, Fm sure I said that.
Q. And did you tell her you were scared and
nervous when you were up there?
A. I told her it was, you know, awkward. I felt
weird and I told her what happened, but I don't remember
exactly what words I used.
1
2
3
4
5
6
7
9
1 0
11
12
13
14
15
16
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Page 393
A. I don't remember.
Q. What was her reputation around school?
A. It was good.
Mill
All right. So what did you do? Did you call
. baNclair
"Yep, iyrcal
m bonginga .friend"?then
I toll illir
I, yes, I had a friend that wanted to
con
Q. And she said,Maid "Okay, just set up a
time"?
A. Yes.
mid
And did you set up a time and did you take
ere?
•I'remember.
Q.
, was she driving at the time?
A. Yes.
Q. Did you say you were in the same class?
A. Yes.
Q. So one of the two of you drove, and I think
you told us earlier maybe M. went, you just don't
remember, or you think just
two of you went?
A. I don't remember.
Q. So you drive over there. Din
ask you any
questions as you were going over there?
A. I don't remember.
Page 392
1
Q. Did you tell her the
hadn't told you the
2
truth, that she had deceived you and misrepresented what
3
was going to happen?
4
A. I don't remember if I told her that.
5
Q. Okay. Did you tell her — did she say "Well,
6
would you go back up there with him?"
7
A. She never asked me that.
8
Q. Okay. So you told her you were, it had been
9
awkward and weird, that you were scared and nervous?
10
Did you tell her that?
11
A. I don't remember.
12
Q. Did you tell her that he had grabbed your
13
butt?
14
A. Yes.
15
Q. Okay. And she gill said "I'll go"?
16
A. Yes,
17
Q. Okay. What was S.V.'s reputation at school?
18
Was she someone who dated a bunch of guys?
19
MR. HOROWITZ: Form.
20
BY MR. CRITTON:
21
Q. I mean was she someone who had intimate
22
relationship with guys, from what you knew?
23
A. I mean she had boyfriends.
24
Q. Do you know whether she was in a sexual
25
relationship with those boyfriends?
Page 394
1
Q. Did you feel like you had give= full
2
disclosure as to at least what your experience was?
3
MR. HOROWITZ: Form.
4
THE WITNESS: Yes.
5
BY MR. CRITTON:
6
Q. So even though yours waslit
ble
7
experience, you found it frame •
11 wanted to
8
go?
9
MR. HOROWITZ: Form.
10
THE WITNESS: Yes.
11
BY MR. CRMON:
12
Q. So you get over there. You go into the
13
kitcza
was
do ythere
ou seta: alit
14
15
Q. Anyone else?
16
A. And
wn-haired girl. I forget her name.
17
I thinIcit's the
'rt.
Q. Who is th
18
girl?
19
A. The brown-haired girl that was always over
20
there.
21
Q. Did you meet her at some point?
22
A. Yes.
23
Q. What did she look like?
24
A. She's like really tall and skinny and brown
25
hair, pretty.
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25 (Pages 391 to 394)
INC.
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Page 393
1
Q. S'
have been there an
2
A. Sarah was there.
3
Q. And what happened? The two of you come in.
4
everybody says hi, and what happens next?
5
A. I just introduce
., andMi
6
talked t=.
fora little bit, and they went upstairs
7
and I waited in the kitchen.
8
Q. Okay. And how long w-
gone?
9
A. For about half an hour.
10
Q. She comes back down the stairs?
11
A. Yes.
12
Q. Okay. Did you ever see Jeffrey that day?
13
A. Yes.
14
Q. Did he come down the stairs wit.?
15
A. Yes.
16
Q. What did he say to you?
17
A. We went over in like his living room and then
18
he just gave meauzey. I forget what he said to me.
19
Q. And diet
see you getting money for
20
bringing her?
21
A. I don't remember.
22
Q. Did she understand that you were going to get
23
money for bringing ha?
24
MR. HOROWITZ: Form.
25
THE WITNESS: I don't remember.
1
2
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4
5
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7
8
9
1.0
11
12
13
14
15
16
17
18
19
20
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22
23
24
25
Pc..1
her like it had been to you?
MR. HOROWITZ: Form.
THE WITNESS: She didn't go into any detail.
I'm sure she was embarrassed.
BY MR. CIUTTON:
Q. As you had been, right?
A. Yes.
Q. Okay. And did she say anything else?
A. Not that I can remem
Q. To your knowledge, :lie.
ever go back to
Mr. Epstein's?
A. I don't know.
Q. You never took her?
A. No. I never took her again.
Q. All right. On the third occasion that you
went to Mr. Epstein's, is this when you would have taken
A. Yes, I believe so.
Q. So the third time, how did that happen?
A. I don't remember exactly. 'just remember me
taking her there. I think I mi t have drove, and
basically the same
wt
Q. Did you tel
what your experience had
been?
A. Yes, but she also heard about it from other
Page 396
1
BY MR. CRITFON:
2
Q. Did you ever tell her?
3
A. I don't remember.
4
Q. When you got back in the car, did you go back
5
home, both of you?
6
A. Yes.
7
Q. Did you askencnv was it," or what was
8
your — you know, "Everything go okay?"
9
A. I don't remember exactly what we talked about.
10
I just, I knew she said something about lute he was
11
weird and, you know, she was kind of creeped out. And
12
that's, she didn't really go into detail with me.
13
Q. So she thought Mr. Epstein was weird and she
14
was creeped out by the whole experience.
15
MR. HOROWITZ: Form.
16
TIM WITNESS: Yes.
17
BY MR. ORITION:
18
Q. Okay. And she told you that?
19
A. Yes. That's what I, the summary of what I
20
remember.
21
Q. Okay. And that was consistent with how you
22
felt after the fast time, because you thought it was
23
weird and you were creeped out too, weren't you?
24
A. Yes.
25
Q. Did she seem to be a traumatic experience to
Page 398
1
girls at school, so she also kind of knew what was going
2
on.
3
Q. Had she, did she say, after told her your
4
experience — I mean you told her again that he had
5
grabbed your butt.
6
A. (Witness nods head up and down.)
7
Q. Yes?
8
A. Yes.
9
Q. Okay. You told her that you had massaged his
10
legs, he had turned over and he had masturbated, at
11
least from your perception, under the towel?
12
A. Yes.
13
Q. Okay. And did she seem to be bothered by that
14
stall?
15
MR. HOROWITZ: Form.
16
THE WITNESS: I don't remember.
17
BY MR. CRITTON:
18
Q. Had she heard that, though, from other girls?
19
A. I think so, yes.
20
Q. And she left you with that impression, "Yeah,
21
I've heard he does that"?
22
A. Yes.
23
Q. Did you tell her that you had taken
24
A. I don't remember.
25
Q. Okay. Well, did you tell her as you ton
(561) 832-7500
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Page 399
1
that you found the situation weird and awkward and you
2
were uncomfortable, confused, and nervous and scared?
3
MR. HOROWITZ: Form.
4
THE WITNESS: I don't remember, because she
5
already kind of knew about it, so I don't remember
6
what I said to her.
7
BY MR. CRITTON:
8
Q. But you told her that you didn't feel
9
comfortable being there, didn't you?
10
MR. HOROWITZ: Fr.
11
THE WITNESS: I don't remember.
12
BY MR. CRITTON:
13
Q. Well, did you mislead her and misrepresent
14
what was going to happen, or did you tell her that it
15
was a very uncomfortable experience for you?
16
MR.. HOROWITZ: Form.
17
THE WITNESS: I don't know if she asked me
18
about it, but she already knew what was going on.
19
BY MR. CRITTON:
20
Q. Well, do you remember telling her your
21
experience? That's what Pm interested in. I mean
22
whether she knew it from somebody else, did you tell her
23
your experience?
24
MR HOROWITZ.: Forth.
25
THE WITNESS: I don't remember.
Page 401
1
this occasion?
2
A. I believeMand maybe, the girl,
3
brown-haired girl.
4
Q. I'm sort
and, an
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
. So you sat in the kitchen and did.
take
13
oPstaks?
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 Sarah brought me up there and Jeffrey was, was in
21
Ike a smaller room kind of by the bathroom.
22
And he gave me the money and he said something
23
Ike "good job," and then just tried to grab my butt
24
again. And then I was kind
e pulled away, and he
25
gave me the money and
came out and then we
Page 400
1
BY MR. CRITTON:
2
Q. Okay. Well, whether she asked you whether she
3
could go a not, you were in a situation that you found
4
traumatic, you thought he acted inappropriately, you
5
felt uncomfortable, nervous, scared, and confused.
6
Did you disclose — didn't you feel you had an
7
obligation to disclose that to her before you allowed
8
her or took her to the house?
9
MR. HOROWITZ: Form.
10
THE WITNESS: She already knew like what was
11
the deal, like what was going on. So ifs not like
12
I hid anything from her. And any time they would
13
ask me, I would tell them straight up, you know.
14
BY MR. CRITTU
15
Q. So you an
o. You think she !mew
16
everything at least that you knew, plus she had heard
17
stuff from other girls?
18
A. Yes.
19
Q. So you felt that she had full knowledge, full
20
disclosure, so to speak?
21
MR HOROWITZ: Form.
22
BY MR. CRITTON:
23
Q. Is that fair?
24
A. Yes.
25
Q. You go in the house. Who was in the house on
Page 402
1
left
2
Q. So when he reached out for your butt, you
3
moved away?
4
A. Yes.
5
Q. So the third occasion, so you an.
then
6
walked downstairs?
7
A. Yes.
8
Q. Did you go to the beach? Did you go shopping,
9
or did you take her home?
10
A. I don't rer»ember what we did. A lot of times
11
I would go to the beach after, but I don't remember
12
specifically.
an.
13
Q. Were you
friends?
14
A. Yes.
15
Q. Did
anything about the episode? Did
16
she say
said, like "This is really weird,
17
this really creeped me out"?
18
A. Yeah, I think she was kind of — I think ever)
19
girl that watt kind of had that feeling — like not
20
every girl, but I mean a lot of the girls, the first
21
time theysvere kind of confused by everything.
22
Q. S
ave you at least the impression she
23
thought it was weird and she was kind of creeped out
24
too?
25
A. I mean she didn't tell me, but I would assume.
27 (Pages 399 to 402)
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Page 403
1
Q. You don't have to assume. I want to know what
2
she said. Did she say anything to you?
3
MR. HOROWITZ: Form.
4
THE WITNESS: I don't remember what she said
5
to me.
6
BY MR. CRITTON:
7
Q. Well, did she say anything or did she suggest
8
to you — strike that
9
Did she tell you that anything inappropriate
10
had happened?
1/.
MR. HOROWITZ: Form.
12
THE WITNESS: I don't remember.
13
BY MR. CRUTON:
14
Q. Okay. Did she say he had touched her in any
15
way or assaulted her?
16
A. No. She didn't say assaulted.
17
Q. Well, did she say that anything had happened
18
that was in any way inappropriate?
19
MR. HOROWITZ: Form.
20
THE WITNESS: I don't remember.
21
BY MR. CRITTON:
22
Q. Again, neither
ever came down
23
looking distraught or crying or upset, did they?
24
A. I mean yeah, they kind of looked like upset
25
and weirded out. None of them ever cried, but —
Page 405
1
money. You had a job at the time or you didn't have a
2
job?
3
A. I don't think I had a job, no.
4
Q. So did you ask your parents for money?
5
A. My parents like rarely gave me money. Like
6
just when I needed things like bad, like for school.
7
Q. Who paid for your gas?
8
A. I would have to like wash my dad's car or
9
clean the yard. I would have to do chores to get —
10
Q. Soto speak, an honest days work for an
11
honest days pay?
12
A. Pretty much.
13
Q. All right. So and how about for insurance,
14
who paid the car payment and the insurance payment for
15
the car, your parents?
16
A. My dad.
17
Q. All right. Did your parents ever ask you
18
where you went when you were going over to Palm Beach,
19
or did they not know you were going to Palm Beach?
20
A. They didn't Icnigr agoing.
21
Q. All right So i
Iled, you said you
22
needed some money, so you said you'd go again?
23
A. Yes.
24
Q. Now the fourth time, this is the fourth of the
25
eight to ten times you went?
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. Diver
say, "You know what?
8
This guy did something unappropriate, we should call the
9
pollee?
10
A. No.
11
Q. How about and you? DiMisay 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. !just remember like major
24
things that happened when I was there.
25
Q. Okay. The fourth time, you say you needed
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 406
A. Yes.
Q. So you go on the fourth time, you go. Who was
in the kitchen at the time?
MR. HOROWITZ: Form.
BY MR. CRITTON:
Q. Let me strike that.
Was there anyone in the kitchen at the time?
MR. HOROWITZ: No, that's not my objection.
BY MR. CRITTON:
Q. Fourth visit
MR. HOROWITZ: That is a better question.
BY MR. CRITTON:
Q. You went to his house the fourth time.
correct?
A. Yes.
Q. You went to the
did you always go to the
kitchen entrance?
A. Yes.
Q. Did you ring the bell?
A. No.
Q. You just walked in?
A. I think so, yeah.
Q. Was anyone in the kitchen?
A. I don't remember exact like lime to time. I
just, I remember usually there was a cook in the
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Page 409
1
kitchenaape I saw Shairl there. One time
2
1 saw dein
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. Dialtake you up or you
9
just !mew 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. HOROATfZ: Form.
22
THE WITNESS: I don't know, I just, I wanted
23
money. And I mean a lot of my high school
24
girlfriends were going and I thought it was kind of
25
like, you know, getting to be normal almost. And
1
right?
2
MR. HOROWITZ: Form.
3
THE WITNESS: Like I said earlier, I just, I
4
was confused. I wasn't thinking. I was young.
And a lot of my friends were going and I just
6
started getting more comfortable because my friends
7
were going. It wasn't like he was a mean man. He
was like really nice to me, and I mean other than
9
what he did. But I mean I don't know why.
10
BY MR. CRITTON:
11
Q. Okay. Each of the subsequent times, each of
12
the times from the fourth time through the eighth or the
13
tenth time, whatever it was, with the second and third
14
time taking someone else and not you participating, you
15
voluntarily consented to go to Mr. Epstein's home, true?
16
A. Yes.
17
Q. And in each instance, when you were asked
18
whether you wanted to come and work, you had to make a
19
decision to say, number one, yes; and then number two,
20
to get in the car and to transport yourself over there?
21
A. lb huh.
22
Q. Yes?
23
A. Yes.
25
toldOX AN
right. And in any instance you could have
24
that you had no interest incoming
Page 408
1
don't know, I was just young and confused, and so I
2
went there again.
3
BY MR. CRITTON:
4
Q. But had you ever had had you ever put your
5
hand on or near a kitchen — do you have a gas or an
6
electric range?
7
A. Gas.
a
Q. Okay. Did you ever put your hand too close to
9
the flame and it bums?
10
A. Yes.
11
Q. Not a pleasant experience, right?
12
A. Yes.
13
Q. What's it teach you? Even as a small child,
14
you learn you don't do that again, right?
15
MR. HOROWITZ: Form.
16
THE WITNESS: Yes.
17
BY MR. CRITTON:
18
Q. All right. So in this instance you had a very
19
unpleasant experience with Mr. Epstein —
20
A. Yes.
21
Q. — from the first occasion. Traumatic, as
22
you've described it.
23
So why would you put yourself back in that
24
position again? I mean you had a lot of time to think
25
it before you ever went back a second time for yourself.
Page 410
1
back to Mr. Epstein's house, correct?
2
A. Yes. She would call me a lot, though.
3
Q. I'm sorry?
4
A. She called me a lot.
5
Q. All you had to do was say don't, do not call
6
me again, correct?
7
A. Yes.
8
Q. That's all you had to say?
9
MR. HOROWITZ: Form.
10
BY MR. CRITTON:
11
Q. Did you ever al=
"Don't call me
12
anymore, I have no interest in coining to your house"?
13
A. No.
14
Q. Okay. Have you ever told someone — my guess
15
is you've told males before who wanted to date you, you
16
have said "Look, I have no interest in dating you, don't
17
call me anymore."
You have said that to men, haven't you?
19
A. Yes.
20
Q. And my guess is you probably said that to some
21
females over the years, some people that you don't want
22
to associate with if they call you and say "Look, I'm
23
sorry I did this to you. Look, don't call me"
24
You have said that to people, haven't you?
25
A. Yes.
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Page 411
1
Q. And you could have said that t•MI could
2
you not?
3
A. Yes.
4
Q. All right. But you chose not to for whatever
5
reason, true?
6
A. Uh huh.
7
Q. Yes?
8
A. Yes.
9
Q. All right. So the fourth time you go over,
10
you say you saw him, he was in the shower.
11
A. Yes.
12
Q. All right. So what did you do?
13
A. He was just talking to me while he was in the
14
shower. And I think he asked me how school was or
15
something.
16
And he said he needed to take a shower because
17
he just went for a jog, and we were just briefly
18
talking. Then he got out and he grabbed a towel. He
19
was like all naked and just kind of dried off and then
20
asked me if I was ready to do the massage.
21
Q. Were you looking at him when he got out of the
22
shower or did you turn away?
23
A. !saw him naked and then I tamed away.
24
Q. Okay. Did you say anything to him when you
25
say him naked, say "Look, you know, I don't need that"?
Page 413
1
Q. Again, you are there. Were all these sessions
2
about a half hour?
3
A. Yes.
4
Q. So you massage his feet and his legs again.
5
Is he talking to you?
6
A. Yes.
7
Q. Does he ever ask you your age?
8
A. No.
9
Q. Do you ever tell him your age?
10
A. I don't think so. I remember telling him I
11
was in high school.
12
Q. You did ever show him your fake IDs?
13
A. No.
14
Q. Did you tell him you had a fake ID?
15
A. No.
16
Q. If he had asked for the ID, you would have
17
given him the fake ID?
18
MR. HOROWITZ: Form.
19
20
BY MR. CRITTON:
21
Q. Why not?
22
A. I mean why would I have?
23
Q. Were you concerned at all about your age?
24
MR. HOROWITZ: Form.
25
T E WTTNESS: No.
Page 412
1
A. I mean no, I was kind of nervous. I was just
2
put in an awkward situation, pretty much.
3
Q. So again, you felt in a very awkward and
4
unoomfortable position?
5
A. Uh huh.
6
Q. Yes?
7
A. Yes.
8
Q. All right. Did you say, you know, "I really
9
don't feel like doing this, I don't feel well, I think
10
III go downstairs"?
11
A. No.
12
Q. Okay. I mean you've gotten out of other
13
events in your life, whether it's a party or going out
14
with someone by saying "Look, I don't feel well, I have
15
got a headache, l feel sick," and then you didn't have
16
to go to dinner with the person or didn't have to go
17
out?
18
You have done that before?
19
A. Yes.
20
Q. All right. So he puts a towel around himself
21
Does he come over and get on the table then?
22
A. Yes.
23
Q. Did you start massaging his feet and his legs
24
again?
2 5
A. Yes.
Page 414
1
BY MR. CRITTON:
2
Q. So again the fourth time, but the second time
3
you alone, you massage his feet and his legs.
4
What happens? Is it the exact same as the
5
fast occasion?
6
A. No.
7
Q. How is it different?
8
A. It was worse. Like every time it gradually
9
got worse. That was the time when he like grabbed my
10
buttocks and pulled me closer and after the massage, and
11
then he tried grabbing my breasts and asked me to take
12
my shirt off.
13
And I think I always wore like a bathing suit
14
there, and he told me that I had like a nice body and I
15
was pretty. And then he would ask me things, like if l
16
was still a virgin.
17
Q. I'm just talking about the fourth visit now.
18
A. Okay.
19
Q. This all happened on the fourth visit, the
20
second time you were there alone?
21
A. I can't distinct visit to visit. I just
22
remember the fourth until certain big events that
23
happened.
24
Q. You say they got worse and worse. So as of
25
the second time, you say he grabbed your butt again.
30 (Pages 411 to 414)
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Page 415
1
A. Yes.
2
Q. And then you said he tried grabbing your or
3
touching your breasts?
4
A. Yes.
5
Q. Did he?
6
A. I don't lmow if he did it on the tomtit or the
7
fifth time, but eventually, yes, he did.
8
Q. Okay. But on the fourth at least he tried is
9
what you are saying?
10
A. Yes.
11
Q. And you described, you felt that this was a
12
worse situation than the first time that you had been
13
there alone?
14
A. Yes.
15
Q. All right. Did you feel more scared?
16
A. Yes.
17
Q. More anxious?
18
A. Yes.
19
Q. And did you feel that his conduct was more
20
inappropriate?
21
A. Yes,
22
Q. And vane you more traumatized because he was
23
more what you perceived to be a little more aggressive?
24
MR. HOROWITZ: Form.
25
THE WITNESS: Yes.
Page 417
1
Q. And you had your swimsuit on underneath?
2
A. Yes.
3
Q. Which would have been the top and the bottom?
4
At IA huh, yeah.
5
Q. Your swimsuit, was it a thong or full
6
swimsuit?
7
A. It was like a full swimsuit.
8
Q. Um a two-piece?
9
A. Yes.
10
Q. But not like a thong bikini?
11.
A. No.
12
Q. So on the fourth time did he masturbate again,
13
or what you perceived to be masturbating?
14
A. Yes.
15
Q. And again, under the towel?
16
A. Yes.
17
Q. And at the end of the session, at the end of
18
the massage session, were you again anxious, scared,
19
very uncomfortable?
20
A. Yes.
21
Q. All right. Felt again traumatized by the
22
events?
23
A. Yes, I felt upset about everything and
24
embarrassed, yeah.
25
Q. And he again paid you 200 bucks?
Page 916
1
BY MR. CRITTON:
2
Q. Okay. Did he ask you — did you remove any of
3
your clothing on that visit? This is the second — the
4
fourth time recognizing — I don't want to keep
5
repeating this, but the same
you brought and
6
the third time you brou
7
So the fourth time, did you remove any of your
8
clothing?
9
A. 1 remember, I just remember him grabbing my
10
butt and trying to grab my boobs and just like being
11
more rough with me than the first time I went there.
12
I don't know if It was the fourth or the fifth
13
time when I took off my shirt.
14
Q. All right. So whether it was the fourth or
15
the fifth, we'll kind of combine those two, but between
16
the fourth and the fifth, did it get worse from your
17
perspective than two?
18
A. Yes.
19
Q. Did he ask you to take off your shirt on
20
either let's say on the fifth time?
21
A. Yes.
22
Q. And did you have a tank top cm?
23
A. I don't remember exactly what I was wearing.
24
I usually just wear like a skirt and cute shirt, tank
25
top.
Page 418
1
A. Yes.
2
Q. And when you left that time, you had come
3
alone, so you went home alone, right?
4
A. Yes.
5
Q. And did you make a vow to yourself, I'm not
6
going back there again, this was worse than the last
7
time, than the first time when I was there alone, I have
8
no interest in ever going back to this place?
9
A. No. I would wait a little bit again and then
10
just kind of, you know, just wait. And ther
would
11
keep calling me again, and then I finally gave in again
12
and went. And I mean yeah.
13
Q. The fifth time, so between the fourth time and
14
the fifth time, how much time transpired? How much time
15
usually transpired between visits?
16
MR. HOROWITZ: Form.
17
THE WITNESS: I don't remember, sometimes a
18
week, sometimes a month.
19
BY MR. CRITFON:
20
Q. Were you telling other people, were your
21
Mends aware that you had gone back?
22
A. Just Jane Doe 4, and I dont know if I told
23
Jane Doe 3.
24
Q. Okay. Did you tell them what was going on?
25
A. I don't remember what I told them.
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Page 419
1
Q. Well, did the three of you talk about what
2
went on when you were there?
3
A. I mean I don't remember generally. I'm sure
4
we talked about it, but I don't remember what was said.
5
Q. Okay. Did you know or did Jane Doe 4, did she
6
ever mention that he masturbated?
7
A. I don't remember.
8
Q. Did Jane Doe 3 ever tell you that Mr. Epstein
9
masturbated when she was there?
10
A. I don't remember.
11
Q. The fifth time you say you removed your shirt,
12
but you still had your top on.
13
A. Yes.
•
14
Q. Did he touch you in any way?
15
A. Yes. He touched my breast.
16
Q. Over your swimsuit?
17
A. Yeah, and tried to reach under it
18
Q. He tried, but he didn't?
19
A. The fifth time he didn't. He just kept trying
20
to grab my breast.
21
Q. Did you tell him not to?
22
A. Youth, I kind of liked pulled away and I was
23
like 1 don't feel comfortable."
24
And he's like "Well, you know, yottve been
25
here before, you should know." He said something like
Page 421
1
Q. And he said something to the effect of well.
2
you've been here before.
3
A. (Witness nods head up and down.)
4
Q. And you still moved away from him?
5
A. Yes.
6
Q. Is that correct?
7
A. Yes.
8
Q. All right. So as of the sixth visit, you had
9
tatter' your top off, he had put his hand on your butt and
10
pulled you closer each time; is that true?
11
A. Yes.
12
Q. All right. And he tried to touch your breast,
13
but was not successful, correct? That is, under your
14
swimsuit?
15
A. Yes.
16
Q. And on each of the visits did he masturbate,
17
at least from your perception, under the towel?
18
A. Yes.
19
Q. All right. What happened on the — what event
20
occurred next, whether it was the seventh or the last
21
visit, if the last visit was the eighth, what happened
22
next?
23
A. Well, I remember being just like, I took off
24
my bottoms and I was just in a bathing suit.
25
Q. Is this now the last time you went?
Page 420
1
that.
2
Q. Did he ever pay you more than S200?
3
A. No.
4
Q. So he ahvays 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 forme, 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, ifs hard to bring
18
backup, 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.
Page 422
1
A. No, this is around the sixth or the seventh
2
time probably, and I was just in my bathing suit And
3
then he pretty much did the same thing.
4
And then he just kept asking me more like
5
vulgar questions every time and —
6
Q. Vulgar questions?
7
A. Yes.
8
Q. Me what?
9
A. Like asked me what I have done with guys and
10
why I was still a virgin.
11
Q. Because you told him that you had done nothing
12
with guys?
13
A. Yes.
14
Q. Other than kissing, making out?
15
A. Yes.
16
Q. I think you testified earlier that you had not
17
had sexual intercourse with a man by then?
18
A. No.
19
Q. And you had not engaged in oral sex, either
20
giving or receiving; is that correct?
21
A- Yes.
22
Q. So you said, whatever question he asked, you
23
said, "I haven't engaged in sex, it was my own choice,"
24
right?
25
MR. HOROWITZ: Form.
cab
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Page 423
1
BY MR. CRITTON:
2
Q. Strike that. Did you tell him when he said
3
"Why arc you still a virgin," what did you say?
4
A. I said I hadn't fallen in love yet and 1 was
5
waiting until I found somebody I fell in love with.
6
Q. So you certainly had the presence of mind with
7
other males, males your age or a few years older or
8
younger, my guess is guys had encouraged you to by to
9
have sex with them?
10
MR.11OROWITZ: Form.
11
THE WITNESS: I mean not really. I just, I
12
just, I mean I'm sure guys like hit on tne and this
13
and that, but I've never really been in that
14
position where 1 was with Jeffrey wherel felt so
15
obligated to do things and just like in that
16
situation.
17
BY MR. CRITTON:
18
Q. Ur me ask you this. Before you ever went to
19
Mr. Epstein's house, had you ever been in a position
20
with a boy who tried to get more aggressive than just
21
kissing you, with a male?
22
A. I mean I don't think so. I don't remember.
23
Q. So you're either 15, 16 or 17 when you are
24
going to Mr. Epstein's house, depending on what your
25
interrogatories and what you have told us today and what
Page 425
1
BY MR. CRITION:
2
Q. Go ahead.
3
A. I don't remember. Maybe like I, I don't — it
4
was so long ago, I don't remember exactly what happened
5
in high school and what guys, you )(now, tried to touch
6
me or if a guy tried to touch me. Irernernber, of
7
course, I made out with people and, you know.
8
Q. Had you ever tried to touch a guy?
9
A. No.
10
Q. All right. So you are at Mr. Epstein's house.
11
It's now the sixth or the seventh time. You are in a
12
bathing suit.
13
On each occasion you felt that he acted
14
inappropriately, both from a physical standpoint and
15
from a verbal standpoint at this point, right? The
16
questions he was asking you?
17
A. Yes.
18
Q. All right. You felt that the questions were
19
becoming more inappropriate?
20
A. Yes.
21
Q. And making you more uncomfortable.
22
A. Yes.
23
Q. And you were uncomfortable not only with the
24
questions that he was asking you, but with his actions,
25
that is, in pulling you close to him by putting his hand
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 424
you told the Palm Beach police, whatever that date or
whatever that time period was, is it your testimony that
no male had, or that you had done nothing with a male
other than kissing them?
MR. HOROWITZ: Form.
THE WITNESS: While I was going to Jeffrey's?
BY MR. CRITTON:
Q. Yes, during the torte that you were going to
Jeffrey's.
MR. HOROWITZ: Fenn.
THE WITNESS: Yeah, I was a virgin. I didn't
do anything.
BY MR. CRITTON:
Q. And no guy, no male had ever put his hand on
your breast, either on the exterior of your clothes,
under your bra; is that what you arc testifying to?
MR. HOROWITZ: Form.
THE WITNESS: I don't really remember. It was
high school. Fm sure some guy tried to touch me
or —
BY MR. CRITTON:
Q. Had a guy touched you?
MR HOROWITZ: Hold on. You are cutting her
off. Go ahead.
Page 426
1
on your buttocks, right?
2
A. Yes.
3
Q. And trying to reach and touch your breast over
4
your swimsuit?
5
A. ' Yes.
6
Q. And again, you felt awkward, scared, nervous,
7
and you felt the situation was weird?
8
A. Yes, but at the same time he was also like
9
very nice to me and would ask me questions and say that
10
he would like get me jobs and he was a good person to
11
know, so I was confused by the whole situation. It was
12
kind of conflicting in my head.
13
Q. You may have had some conflict, but on each
14
occasion when you came away from Mr. Epstein's,
15
certainly as of the sixth or seventh time, you felt that
16
the situation from your perspective was escalating, was
17
getting worse, right?
18
A. Yes.
19
Q. And you felt more uncomfortable than you had
20
the first time and with each time thereafter felt
21
equally -- in fact, more uncomfortable?
22
A. Yes.
23
Q. And you felt his behavior was more
24
uncomfortable each time?
25
A. Uh huh.
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Page 427
Q. Yes?
A. Yes.
Q. And so on any of those occasions, whether
before you went back on the fifth, the sixth, the
seventh or the eighth, all you had to do was tell
a
I'm not coming, I don't feel comfottable,"
net
8
A. Yes.
9
MR. HOROWITZ: Form.
10
BY MR. CRITTON:
11
Q. You didn't even have to give a reason, all you
12
had to do was say Tm not coming"?
13
MR. HOROWITZ: Form.
14
THE WITNESS: Yes.
15
BY MR. CRITION:
16
Q. "Ifs over, I have no interest in corning
17
anymore," true?
18
A. Yes.
19
Q. And you could have told Mr. Epstein when you
20
were there and he is asking you these questions that you
21
felt were inappropriate, WI you had to do was say
22
"Jeffrey, I'm never coming back here if you keep asking
23
me questions like that."
24
Did you ever say that?
25
A. I remember telling him something like "I don't
Page 429
1
MR. HOROWITZ: Form
2
BY MR. CRITTON:
3
Q. On the eighth time, the next time, what event
4
happened? Is the next time the last tint you were
5
there?
6
MR. HOROWITZ: Form.
7
THE WITNESS: Yeah, the last time was the
8
worst.
9
BY MR. CRITTON:
10
Q. Okay. So on the eighth time when you were
11
there, what happened?
12
MR. HOROWITZ: Form.
13
THE WITNESS: The last time he I had my
14
shkt off. I had a bra and underwear on, and I
15
gave him a massage. And then that time he was just
16
the most aggressive with me. And that's when be
17
like pulled me close to him and he asked me to take
18
my underwear off, and I said no.
19
And then he tried to grab it and pull it down,
20
and I was like "No, I just don't feel comfortable."
21
And he was Illce "You've been here plenty of
22
times before." And then he — I took my shirt off.
23
And then he was grabbing my breast, and I kept
24
pulling away and he kept grabbing it.
25
And then he just like pulled me closer to him.
Page 428
1
feel comfortable telling you about, you know, guys and
2
talking about this," and then he just kept pressuring me
3
and asking me why not.
4
Ink just he's good at talking and he's good
5
at making you feel like you could tell him stuff; and
b
he's good at like making you feel like it's okay to do
7
stuff.
3
Q. But you knew, you felt it was inappropriate,
9
right?
10
So whether he is trying to make you feel
11
comfortable or not, you in your own mind knew that the
12
questions were very uncomfortable and inappropriate,
13
true?
14
A. Yes, and I told him about it.
15
Q. All right. So seventh time, now you are in
16
your swimsuit, he's asking you more direct questions.
17
You felt even more uncomfortable.
18
Again, be masturbated under the towel?
19
MR. HOROWITZ: Form.
20
THE WITNESS: Yes.
21
BY MR. CRITTON:
22
Q. All right. And then you would, he would get
23
up and go take a shower or he would leave the room and
24
you would take your 200 bucks and leave the house?
25
A. Yes.
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Page 430
And that's when he like tried to like reach under
my — well, he did reach under my underwear and
touch my vagina and he was, like tried fingering
me.
BY MR. CRITTON:
Q. This last time, were you still giving him a
massage?
A. Well, I was like massaging his chest while he
was like doing this.
Q. But you were doing the same kind of massage
you had done before, you were doing his feet, his legs
and then he would turn over?
A. Uh huh
Q. Ms. jane Doe 7, you say he got a little more
aggressive. So did you take off your bra?
A. I don't remember. I think he tried to unhook
it and pull it down —
Q. But you didn't let him do that?
A. — and grab my breast. I think he pulled it
down. I didn't take it all the way off, but he pulled
it down.
Q. Did he touch your breast?
A. Yes.
Q. Both or just one?
A. I know he touched one. I think he touched
34 (Pages 427 to 430
G AGENCY, INC.
(561) 832-7506
(561) 832-7500
Electronically signed by Rachel Bridge (201-272-6174627)
Electronically signed by Rachel Bridge (201-272-617-4627)
fe3b2074-4669-434d-ac93-e54696fd7921
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Page 433
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both.
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Q. If he was lying on the table, how is he able
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to do that?
4
A. Touching, Ince going from — this is so
5
embarrassing.
6
Q. With his left hand or with his right hand?
MR. HOROWITZ: Take your time. Just try to
answer the question as best you can.
THE WITNESS: It was with his left hand.
BY MR. CRITfON:
Q. Okay. So you are saying he pulled down your
In and then was able to touch your breast with the same
hand that he was pulling your bra down?
A. Well, he pulled it down and then grabbed it.
Q. When he pulled it down, did you move away from
him?
A. Yeah, and then he pulled it down again and he
was being very aggressive.
Q. When he gabbed your bra and pulled it down,
why didn't you just move away from him?
A. I did move away.
Q. Well, why did you ever move back near him
then?
A. Because he pulled me back near him with his
arm.
1
want to tell anybody.
2
Q. That's the last time you went Mr. Epstein's?
3
A. Yes.
4
Q. And on that last occasion that you went to his
5
house, when you left, where did you go?
6
A. I don't remember. I think I went home.
7
Q. All right. Did you ever tell anyone about it?
8
A. No.
9
Q. Did you ever tell Jane Doe 47
10
A. I mean Jane Doe 4 is maybe the only person ]
11
ever told.
12
Q. Did you tell her at the time?
13
A. I don't remember.
14
Q. At some point did you tell her?
15
A. I don't remember.
16
Q. So you don't even lmow what you told Jane
17
Doe 4?
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MR. HOROWITZ: Form.
19
THE WITNESS: I don't exactly icn nber what I
20
told Jane Doe 4 why I stopped going, like if I told
21
her everything. I mean I was embarrassed. I
22
didn't want to like share all my details.
23
BY MR. CRITP0N:
24
Q. Did anyone, did Sarah ever call you again to
25
work?
Page 432
1
Q. Did you say something to him like "Let me go"?
2
A. Yeah. I said, I just told him, I was like "I
3
just can't do this," like no. I don't remember the
4
exact words I used.
5
And he just made me feel like really stupid
6
and belittled. He was like "You have been here so many
7
times and, you know, you should know like what goes on
8
by now."
9
And then I just felt like in that position
10
where like I just felt like obligated or just like I was
11
just put in that weird position. And then that's when
12
he pulled me closer to him again, and that's when he
13
pulled down my underwear, and then that's when he
14
touched my vagina and tried to finger me.
15
And then after that, I was just, I was like
16
no, Fin done after that. And I was just so, I was fed
17
up with everything. I was like this has gone way too
18
far.
19
Q. Did you tell him that?
20
A. Yeah, I was like fm done. He knew I felt
21
really in shock And then he was like okay, okay. And
22
then he was just mad at me and just like gave me dirty
23
looks and just made me feel stupid.
24
Q. Did you ever call for help?
25
A. No. I mean I was so embarrassed. I didn't
Page 434
1
A. Yes.
2
Q. What did you tell her?
3
A. !just like ignored her phone calls.
4
Q. And you could have done that after the very
5
first time you had been at Mr. Epstein's home, true?
6
A. Yes.
7
Q. So at least after the eighth visit, you were
8
. able 03 ignore
phone calls without a problem at
9
all?
10
MR. HOROWITZ: Form.
11
THE WITNESS: Yeah, l was just in shock and
12
over it. And I just felt so embarrassed and like
13
ashamed of myself. And then so that was the last
14
time.
15
MR. HOROWITZ: Critton, it's now 6:30.
16
How far in this tape are we, sir?
17
THE VIDEOGRAPHER: Fifty-seven minutes into
18
this tape, sir.
19
MR. HOROWITZ: Tick, tick, tick.
20 '
MR. CRITTON: Let's go off the record for just
21
a minute.
22
711E VIDEOGRAPHER: Going off the record at
23
6:29 p.m.
24
(A recess was taken.)
25
THE VIDEOGRAPHER: We are back on the record
(561) 832-7500
35 (Pages 431 to 434)
INC.
(561) 832-7506
Electronically signed by Rachel Bridge (201-272-617-4627)
Electronically signed by Rachel Bridge (201-272.617-4627)
103b2074-4669-4a4d-ac93 e54696t(17921
EFTA01107911
Page 435
Page 437
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at 6:36 p.m.
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BY MR. CRITTON:
3
Q. Ma'am, the last time that you went, you were
4
at Mr. Epstein's house, did he masturbate or not?
A. Yeah, I believe he was masturbating. Well, he
6
was masturbating. I don't know if he finished,
7
because —
8
Q. He climaxed?
9
A. Yes.
10
Q. He had the towel over himself again?
11
A. Yes. I mean 1-
12
Q. You always, each time you were there, he had a
13
towel ova himself and you believe that he was
14
masturbating?
15
A. I knew he was masturbating.
16
Q. You )(new it because you could what?
17
A. I could tell by his hand. I could feet it. I
18
know.
19
Q. All right. But you never saw him masturbate,
20
you just saw him doing it under the towel, coned?
21
A. Yes, and I neva wanted to look. rd always
22
look the other way while he was doing it
23
Q. He always had a towel on?
24
A. Yes.
25
Q. The only time, if I understood, that you saw
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Q. Anything else in the drawer?
A. I don't remember what else was in the drawer.
Q. What were you doing in the drawer?
A. The drawer was open.
Q. And what did the vibrator look like or the
massager look like?
MR. HOROWITZ: Form.
THE WITNESS: I'm pretty sure it was just
white.
BY MR. CRITTON:
Q. Do you know the difference? Have you ever
used a vibrator?
MR. HOROWITZ: Form.
THE WITNESS: Yeah
no, I mean like a
massager?
BY MR. CRITTON:
Q. Well, your lawyer was laughing when I
interchanged the massager for the vibrator.
MR. HOROWITZ: That's because she called it a
vibrator and you are calling it a massager.
MR. CRITTON: Well, I'm not sure what it is,
so we're going to find out. So you don't have to
laugh and nobody else does too.
MR. HOROWITZ: I wasn't laughing.
Page 436
1
him naked was one timei he got out of the shower before
2
he put a towel around himself?
3
A. I believe so.
4
Q. And if I also understood your testimony, you
5
never took off your swimsuit, nor your bra, nor your
6
underwear at any time, correct?
7
MR. HOROWITZ: Form.
8
THE WITNESS: Well, my bra did come like down,
9
but not completely off.
10
BY MR. CRITTON:
11
Q. But you never took it off?
12
A. No.
13
Q. Did he ever ask you to take your bra off?
14
A. Yes.
15
Q. And you declined?
16
A. Yes.
17
Q. Did you ever tell -- strike that.
18
Did he ever use any type of -- he,
19
Mr. Epstein, did he ever have a massage or any kind of
20
what you would have perceived to be a sexual toy?
21
A. Yeah, he had a vibrator, but he never used it
22
with me.
23
Q. How do you know he had one?
24
A. Because Jane Doe 4 and them told me about it
25
and also it was laying right there in the drawer he had.
Page 438
1
BY MR. CRITTON:
2
Q. Do you know what the distinction between a
3
massager and a vibrator?
4
A. Yes.
5
Q. Okay. What do you understand a massager is?
6
A. Massager, I just, I know the difference. I'm
7
not -
8
Q. Okay. What you saw in the drawer, was it a
9
massager or it was a vibrator?
10
A. It looked to me like a vibrator.
11
Q. What did it look like? Describe it, please.
12
A. The one I saw was just white and it had like,
13
I don't know, a big thing on the end that was white.
14
Q. Did it look like something that you would get
15
at like an adult store or did it look like something you
16
would get from Brookstone, or do you know?
17
A. I mean I don't know. I mean I heard he uses
18
that as the, as the vibrator. So I'm assuming that was
19
the vibrator.
20
Q. You heard that from Jane Doe 4?
21
A. Yes.
22
Q. From anyone else?
23
A. I don't think so.
24
Q. And as to whether it was a vibrator or a
25
massager, if you purchased it, whether it would be
(561) 832-7500
36 (Pages 435 to 438)
(561) 832-7506
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Electronically signed by Rachol Bridge (201-272417-4627)
fe7b2074-4669-4a4d-ac93-0546961d7921
EFTA01107912
Page 439
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considered a vibrator or a massager, you don't know;
2
would that be a fair statement?
3
MR. HOROWITZ: Form.
4
THE WITNESS: Yes.
5
BY MR. CRITTON:
6
Q. Okay. But he never used that on you, nor did
7
he ever attempt to use that on you, whatever it was,
8
correct?
9
A. Yes.
10
Q. That's correct?
11
A. Yes.
12
Q. Did you ever discuss with your boyfriends,
13
even the long terms, a
from 107, '08 and '09,
14
did you ever tell them anything about Mr. Epstein?
15
A. Absolutely not.
16
Q. Okay. You said that you bad flashbacks.
17
Describe what you mean by a flashback.
18
A. Just when somebody would say his name or I
19
would just even hear Jeffrey, just like me being there,
20
the massage table, him in the shower, I would just get
21
flashbacks.
22
Q. You had bad memories of that?
23
A. Yes. Even, sometimes even nobody had to say
24
anything. Like I would just be lilt's in a bad mood or
25
upset and I would just get, you know, just memories or
Page .;
1
Q. Okay.
2
A. It was like a really bad dream.
3
Q. Is that the last dream you've had about that
4
separate and apart from the flashbacks?
5
A. I remember having other dreams, but they
6
weren't like as bad. They weren't like, nothing like
7
significant that I could remember. I just ri.nomtber that
8
one, like I woke up crying and felt like I was having a
9
panic attack.
10
A
vas, actually it was when I
11
worked I
aloon, because I had a dream that lie
12
came there to Visit me. And my parents were there and
13
it was just like a really bad nightmare that I had.
14
Q. Okay. Is that the last time you had a dream
15
about it separate and apart from the flashbacks?
16
A. I mean I've seen him, like I have had dreams,
17
but none that 1 could really remember like
18
significantly.
19
Q. Okay.
20
MR. CRITTON: How about another five minutes
21
and then I'm done.
22
MR. HOROWITZ: Five is fine. You are on the
23
clock.
24
BY MR. CRII7ON:
25
Q. I asked you earlier when's.-
culd call
Page 440
1
fit
2
Q. Does that happen very often or is that just
3
really if you, if someone brings up the episode, like if
4
you have something to do with this case or you would
5
read about Mr. Epstein, then you would think back of the
6
time that you were there?
7
A. I mean the flashbacks like have always
8
happened.
9
Q. I'm sorry?
10
A. They have always happened, but it gets worse
11
when, you know, I hear about the case or somebody says
12
something to me about it or I have to, you know, talk to
13
somebody about it.
14
Q. Did in terms of have you ever had a dream?
15
A. Yes.
16
Q. How often do you have a dream or how many
17
dreams have you ever had about having been at
18
Mr. Epstein?
19
MR. HOROWITZ: Form.
20
THE WITNESS: I don't
exactly, but I
21
remember one that like stood out really clearly.
22
BY MR. CARTON:
23
Q. How long ago?
24
A. It was about when l was talking to the FBI, so
25
probably about three years ago.
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Page 442
you, and I think — well, let me strike that.
When I asked you earlier, I think you said
that Sarah never texted you through the phone, nor did
she ever communicate with you over the computer,
correct?
A. I don't believe, I definitely never had any
e-mails or computer, but I don't think she ever texted
me.
Q. All right. And the only communication
sePtrapart
from the conversation that you had
wi
the voice message that she left you when
you were with the Palm Beach poilitiagg they wore
interviewing you, all other calls f
were dealing
with could you come or could you bring someone else to
come to work?
MR. HOROWITZ: Form.
THE WITNESS: Yes.
BY MIL CRITTON:
Q. And you understood that to mean could you come
and give Mr. Epstein a massage?
MR. HOROWITZ: Form.
THE WITNESS: Yes. Well, she said -- well,
basically, yeah.
BY MR. CRITTON:
Q. And she never, that i
never said to
37 (Pages 439 to 442)
(561) 832-7506
Electronically signed by Rachel Bridge {201-272-617-4627)
Electronically signed by Rachel Bridge (201-272-617.4627)
le3b2074.4669-444d-ac93-e54696M7921
EFTA01107913
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
based on what you told me,
8
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 trip to Italy this coming
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Page 445
Q. Does she work now?
A. Yes.
Q
IS her boyfriends name?
A
A.
a
-
don't know.
. Is that
that used to be friends
A. No.
Q. Different
A. Yes, differen
Q. Did you know nice
A. Yes.
Q. Since Jane Doe 4 an'
broke up —
A. Yes.
Q. -- have you seen=
at all since then?
A. I think I just saw him once when I was
downtown.
Q Okay. Did you consider him kind of a scary
character? Was he someone you were scared of?
A. I was never scared of him. !just thought he
was, thought he was an asshole. I never really liked
him because of what happened with Jane Doe 4.
. Did ou ever know Jane Doe 4's boyfriend,
Page 444
: 1
summer, any other plans for trips, vacations --
2
A. No.
3
Q. — when you finish college?
4
A. No. fm just saving up for Italy.
5
Q. Do you plan to stay, when you finish your
6
month in Italy, do you plan to try to save up enough
7
money so you can travel a little bit before you can come
8
to the states?
9
A. I don't think so. llure are certain dates,
10
it's only like a month, and everybody is pretty much
n
leaving together.
12
Q. Are any of your friends going with you?
13
A. Not — there are just people from school.
14
Q. Okay. I asked you earlier -- this is my last
15
short series. I asked you, you said Jane Doe 4 is your
16
best friend. Who is your next best friend?
17
A.
can probablM
18
QM?
19
A. Yes.
20
Q. Next down the scale from. would be whom?
21
A. J
3.
22
Q. I
still in town, in the West Palm Beach
23
area, Palm Beach County?
24
A. Sometimes she's in town became her parents
25
live here, but she lives with her boyfriend in Atlanta.
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Page 446
A. Yes.
Q. Nice guy?
A. Really nice guy.
MR. CRITTON: Okay, that's all I've got.
Thuile you. Read?
MR. HOROWITZ: We'll read, and we'll take a
copy if it's ordered.
THE VIDEOGRAPHER: Going off the deposition at
6:49. This is the end of the deposition.
(Witness excused.)
(Deposition was concluded.)
.:a•l•teesas•brualtatalr•N••
.
•
38 (Pages 443 to 4 4 6)
(561) 832-7500
(561) 832-7506
Electronically signed by Rachel Bridge (201-272-6174627)
Electronically signed by Rachel Bridge (201.272.617.4627)
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Page 447
Page 449
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I, the undersigned authority, certify that
7
Jane Doe #7 personally appeared before me and was duly
sworn on the 15th day of March, 2010.
Witness my hand and official seal this 25th
day of March, 2010.
Rachel W. Bridge, RMR,
17
Notary Public - State of Florida
My Commission Expires:
5/11
18
My Commission No.: DD 607230
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Ftachd W. Bridge. RAIL ad
19
250 Amnion Mama Scud; MI500
W
pbecatrinlit
33401
1
DATE: Morn 25, 2010
2
TO.
Jaw Dee te7
do Adam Diforowlis, Esq.
3
Parmelstein & Horowio, P.A.
18205 Bivouac Boulevard
Sale 2218
Mimi, Florida 33160
5
6
7
The transcript of your deposition taken on
3. 5.10 has been completed and amity reading and
8
sigiung. As recousty ameech the trans* well to
finished to you through you, counsel
9
Attend of the ttansonpt youwillfmdas
cram sheet As son read your deposition, my dames
10
or met mottos that you wish to make should he noted on
the arse sheet Ming page and tine number of said
II
thane, Onto yea hurt read the transcript and noted any
changes, be sure to sign and date the errata Meet and
12
Mtn there pager to me
If yet: do not lewd and ogs the deposition
13
within a numonahle time, the original. which has
already been formided to the ordering canny, tray be
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filed with the Ckric of the Court. If re wish to wave
your signature, lign you name in the blank at the
boom of this Icon and ;duns it to to
Sincerely,
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I dobertby waive my swam.
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bee Dan
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!BRE: /ane Doe No. 2 vt. Epstein
Page 448
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CERTIFICATE
Reehd W. Bridge, Certified Realtime
Reporter and Notary Public in and for the State of
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Florida at Large, do hereby catify this the
aforementioned witness was by me first duly swam to
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testify the a** truth; that I was authorized to and
did report said deposition in stenotype and that the
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foregoing pages numbered 1 to 446, inclusive, we a true
and correct transcription of my shorthand notes of said
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deposition.
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1 further certify that said deposition was
taken at the time and place beronaberee set forth and
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that the taking of said deposition was commented and
completed as hereirebOVe set Cu.
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I gather candy that I am not attorney or
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counsel of any of the parties, nor am 1 a relative or
employee of any attorney or counsel of potty connected
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with the *elite, nor am I financially imerested in the
action
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•
The foregoing certification of this transcript
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does not apply to any reproduction of the urns by any
means unless under the direct control and/or direction
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of the certifying reponer.
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is 25th day of March, 2010.
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Ilieb
acd. Bridge,
CRR
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14-).
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Page 450
CERTIFICATE
I hereby certify that I have read the
foregoing deposition by me given, and that the
statements contained herein are true and correct to the
best of my knowledge and belief; with the exception of
any corrections or notations made on the errata shed,
if one was executed.
Dated this
day of
2010.
JANE DOE #7
39 (Pages
447 Lo 450)
( 561 ) 832-7500
(561) 832-7506
Electronically signed by Rachel Bridge (201-272-617-4627)
Electronically signed by Rachel Bridge (201.272.617.4627)
fe3b2074-4669-4a4d-ac93-0546961d7921
EFTA01107915
Page 451
ERRATA SHEET
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IN RR Jane Doe No. 2 vs. Epstein CR: Rachel Bridge
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DEPOSITION On JANE DOE 47
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TAKEN: 3-15-10
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REASON
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Please forward the mignui signed c nW 010:1 to this
office so that copies may be distributed to ail ponies.
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Under penalty of perjury. I desist that I have real my
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deposition and that it is true and ccirect subject to
any changes in form or substance entered here.
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DATE:
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(561) 832-7500
Electronically signed by Rachel Bridge (201-272417-4827)
Electronically signed by Rachol Bridge (201.272417.4627)
40 (Page 451)
(561) 832-7506
fe3b2074-4889-4a4d-ac93-e54696fd7921
EFTA01107916