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Page 336 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB Plaintiff, - vs- JEFFREY EPSTEIN AND Defendants. VOLUME III OF IV VIDEO-CONFERENCED VIDEOTAPED DEPOSITION OFIIII. Tuesday, February 09, 2010 10:09 - 5:05 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1296 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108807 } EFTA01108808 Page 337 Page 339 1 APPEARANCES: 2 On beJulf ofthe Plaintiff lig! and Jane Dot 3 BRAD J. EDWARDS, FARMER, JAFFE, WEISSItla EDWARDS 4 I 9 On of tbe Jeffrey Epstein: ROBERT D. CROTON, JR., ESQUIRE MARK T. LUTHER. ESQUIRE LUITIER ea COLEMAN, LLP • 2 On bed o • • licfrroYEPslele: .3 JACK ALAN GOLDBERGER, ESQUIRE ER Fe WEISS. PA 14 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: kffrey Epstein, via video conference Daniel Downey, Videograplicr Visual Evidence, Incorporated 1 PROCEEDINGS 2 3 THE VIDEOGRAPHER: This is the 9th day of 4 February, 2010. The dine is approximately 5 10 imIty.m. This is the videotaped deposition 6 OM. in the matter of M. versus Epstein. 7 This deposition is being held at 250 South 8 Australian Avenue, West Palm Beach, Florida. 9 My name is Daniel Downey, I am the 10 videographer representing Visual Evidence, 11 Incorporated. Will the attorneys please 12 announce their appearances for the record. 13 MR. EDWARDS: Brad Edwards on behalf of 14 15 MR. LUTTLER: Mark Luttier with the firm 16 of Burman, Critton, Luther & Coleman on behalf 17 of Mr. Epstein. 18 MR. CRITMN: Bob Critton on behalf of 19 Mr. Epstein. 20 Thereupon, 21 22 Having been first duly sworn or affirmed, was 23 examined and testified as follows: 24 THE WITNESS: I do. 25 1 2 3 4 INDEX VOLUME I Page 338 5 6 WITNESS: DIRECT CROSS REDIRECT RECROSS 7 8 BY MR. LUTHER 4 9 10 11. 12 NO EXHIBITS MARKED 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 Page 340 1 DIRECT EXAMINATION 2 BY MR. LLTIT1ER: 3 Q. Good morning, Ms... We're here for the 4 continuation of your deposition that was started on 5 September 24th, 2009. Do you understand that you're 6 still under oath today? 7 A. Yes, sir. 8 Q. Have you had an opportunity to reviewa 9 transcript of that portion of your deposition which 10 has been completed thus far? 11 A. Yes, sir. 12 Q. Have you reviewed the full transcript? 13 A. Yes, sir. 14 Q. And were there any corrections in your 15 testimony? 16 A. Were there any corrections in my testimony? 17 Q. In other words, when you read it did you 18 see anything that was incorrect? 19 A. No, sir. 20 Q. Do you recall whether or not you silted 21 the transcript indicating that all of it was 22 accurate? 23 A. I signed, yes. 24 Q Do you know if the original got sent 25 anywhere or do you stil I have it or dicliou just 2 (Pages 337 to 340) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108809 Page 341 1 give it to your lawyer? 2 A. I gave it to my attorney. 3 Q. And you signed it without any corrections? 4 A. Yes, sir. 5 Q. Have you ever been to Mr. Edwards' former 6 law firm's office in Fort Lauderdale? That would be 7 the firm of Rothstein, Rosenfeldt & Adler. 8 A. What is this address? Is this address on 9 Andrews? 10 Q. 1/ A. No. 12 Q. Have you ever been to a law firm where 13 Mr. Edwards was practicing while he's been 14 representing you where there are other lawyers 15 besides himself present? 16 A. No. 17 Q. Does the name Rothstein ring a bell to 18 you? Do you know who that is? 19 A. No. 20 Q. Do -- have you ever met with anyone else 21 other than your lawyer with respect to the merits of 22 this lawsuit and whether or not you believed you 23 were likely to recover money in this case? 24 A. No. 25 Q. Has anyone ever approached you arid -- 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 343 shown to third parties and they had been asked whether or not they wanted to purchase an interest in your lawsuit? A. No. Q. No one had called you and advised you that your files were being shown to anybody? A. No. Q. Have you had any discussions with anyone about that issue? A. No. Q. And when I say anyone I mean representative of the Florida Bar Association; have you had any discussions with anybody from the Florida Bar? A. No, sir. Q. Any discussions with anybody from the FBI about that specific issue? A. About what issue, about getting — . Q. About someone attempting to purchase an interest in your lawsuit. A. No. Q. Anyone from the State Attorney's office? A. No. Q. Okay. Prior to coming here today, have you had an opportunity to review a transcript of a Page 342 1 other than your lawyer -- and discussed with you the 2 merits of this case or whether or not you believed 3 you were likely to recover money? 4 A. No. Q. Have you been advised that — or let me 6 strike that. Have you been provided any information 7 that your case and the information contained in it 8 was made available to third parties to review to 9 determine whether or not they wanted to purchase an 10 interest in the outcome of your case? 11 A. No. 12 Q. Have you, prior to me just asking you that 13 • question, did you know that that had occurred? 14 MR. EDWARDS: Object to the fonn. 15 THE WITNESS: Excuse me? 16 MR. EDWARDS: I objected to the form of 17 the question. It assumes that it did occur. 18 BY MR. LUITIER: 19 Q. Before I asked you that question, did you 20 know that that had occurred. 21 A. Sr, I'm not really understanding what you're 22 saying. 23 Q. All right. Let me repeat it. 24 . A. Okay. 25 Q. Did you know that your case tiles had been Page 344 1 hearing that was held before the court on 2 November 3rd, 2009, upon your motion to terminate 3 the continuation of this deposition? 4 A. Excuse me? 5 Q. Prior to coming here today have you been 6 provided an opportunity to review a transcript of a 7 hearing that was held before the court on 8 November 3rd, 2009, on your motion to limit this 9 deposition? 10 A. I'm not understanding this. 11 Q. You know what a transcript is, don't you? 12 A. A transcript, yes. 13 Q. This would have been a transcript or 14 written record of a court hearing that we had in 15 case on November 3rd, 2009, that concerned the 16 conducting of this deposition. Have you seen any 17 such transcript? 18 A. A transcript of what? 19 Q. Of that court hearing. 20 A. Of what court hearing? 21 Q. The one that was held on November 3rd, 22 2009. 23 A. That we recently just did, my last deposition? 24 Q. No. The, the hearing was held on 25 November 3rd, 2009. The subject matter of the (561) 832-7500 3 (Pages 341 to 344) PROSE COURT. REPORTING AGENCY, INC. (561) 832-7506 EFTA01108810 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 345 hearing was a motion that was filed by your lawyer to limit the continuation of this deposition. A. Yes. I knew that we were going to have another deposition. • Have you seen the transcript of that hearing wherein the judge gave some specific direction to you and your conduct in the continuation of this — A. Yes. Q. deposition? A. Yes. Q. Okay. So you're aware of that? A. Yes. Q. Okay. Are you still living at the same address that you gave me at the last deposition? A. Yes, sir. Q. Who else is living with you there now? A. My son. Q. Anyone else? A. No, sir. Q. Has anyone else lived with you at that address since your deposition on September 24th, 2009, other than your son? A. No, sir. Since November, actually, Thomas Souder, he had moved, he lived with me until 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 347 was 13 years old. And on that note, he took it from there to just comfort me through the, through the pain that I was going through and that I have been going through. Q. Did any of these discussions concern anything else? A. No, sir. Q Have you, since your deposition on September 24th, 2009, had any type of contact with anyone else who has filed asuit against Mr. Epstein? A. Yes. Q. M. Who have you had contact with? A Q. Anyone else? A. No, sir. Q. And when I, I use the word contact, by that I mean could be face-to-face contact, could be a conversation, could be some sort of computer, computer message, a text, Twitter, e-mail, any kind of commuter — anything like that, could it be, it could be something in writing. Do you understand that's What I mean by communication? A. Yes, sir. Q. And so the only person since September 2 3 4 5 6 7 ,8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 346 January 1st, 2010. Q. And am I correct told us at your last deposition that was then your current boyfriend? A. Yes. Q. Has that relationship changed now? A. Yes. Q. He is no longer your current boyfriend? A. Correct Q. Is the apartment that you currently live in, is that a rental apartment? A. Yes. Q. Is that rental apartment in your name? A. Yes. Q. Bite was the situation that caused you and to part company? A. It was mutual. Q. Was there any domestic violence involved? A. No, sir. O• Did you have any discussions with at any time about this lawsuit? A. Yes. 1 2 3 11 18 4 5 • 6 7 8 9 10 12 13 14 15 16 17 19 20 21 22 Q. What discussions did you have? 2 A. Well, he's saw the news and I pretty much told 24 him that Jeffrey F nCt in has been mol ting MP since I 25 r.! , Q. And when did you have communication with Page 348 24th, 2009,. that. yo_u had any contact with that has a Ms. Lan cry? suit pending against Mr. Epstein is E.? A. Yes, sir. put her microphone on? actually getting all of this. THE WITNESS: No. THE WITNESS: MR. CRITION: No, Mr MR. LUU1ER: MR. CRITTON: Oh, MR. LUTIIER: Yeah. MR. CRITTON: Okay. MR. LUITIER: And when did you VIDEOGRAPHER: I can pick her up. MR. EDWARD: You can pick — Okay. THE VIDEOGRAPHER: That's fine. MR. LUTT1ER: That would be a good idea. MR. EDWARDS: Let's make sure we're MR. LUTTIEFt: Start over. MR. EDWARD: We don't need that. 3 BY MR. LUTTEER: MR. CRITTON: What.did she say? MR. EDWARD: Fm sorry. Does she need to 4 (Pages 345 to 348) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (.561). 832-7506 . ' EFTA01108811 Page 349 1 A. We are awriates. We're friends. When did I 2 have a conversation with ha? 3 Q. Yes. Well, I don't want to limit it to a 4 conversation. When did you have communication with her? A. I have communication with her frequently but 7 we don't talk about the Jeffrey Epstein case. My 8 attorney is not her attorney. We don't choose to talk 9 about it. 10 Q. When you said you are associates, what do 11 you mean? 12 A. Well, I have my life and she has her life. 13 Q. Well, you said that you were associates 14 and then you said friends. But you used the term 15 associates. 16 A. We are friends. 17 Q. Do you have any kind of business 18 relationship with her? 19 A. Not at all. 20 Q. Did you mean the word associates to mean 21 something other than just merely being social 22 friends? 23 A. We are friends. 24 Q. Do you have any kind of relationship with 25 her other than simply friends? Page 351 1 and we can confine (sic) in each other if anything. But 2 as in confining, I mean all I have to do is look in her 3 eyes and'we just know the pain that we've went through. 4 Q. Am I going to assume correctly that the 5 word you mean is confide, you confide in each other? 6 You tell each other - 7 A. No, I told you, as when I confine in her, it's 8 as simple as we will go to a bar. We'll look at each 9 other in our eyes and we just realize the pain that 10 Jeffrey has caused us. 11 Q. Do you have any other discussions with her 12 or have you had any other discussions with her in 13 more detail than that? 14 A. I have know that she has an attorney and I 15 have mine. But other than that, we definitely don't 16 talk about the case because ifs negative. We already 17 know what we went through. 18 Q. Has she indicated to you whether she's 19 been in contact with other people that have pending 20 claims again Mr. Epstein? 21 A. No, sir. 22 Q. Has she indicated to you whether or not 23 she has sought any professional help? By that I 24 mean a mental health professional, psychologist, 25 psychiatrist, that thing, that type of thing? Page 350 1 A. We're just fiends. 1 2 Q. You have no common joint venture that 2 3 you're pursuing? 3 4 A. No. 4 5 Q. No business that you're pursuing? 5 A. No. 6 7 Q. Are you-all in clubs together? 7 8 A. We go out sometimes. 9 Q. By clubs I meant — I don't know what 9 10 clubs women are in no, Junior League or 4-H, that 10 11 type of thing. I don't mean nightclubs. Are 11 12 you-all in any organizations together? 12 13 A. No. 13 14 Q. Okay. Does — 14 15 A. We go out to a bar once in a blue moon. 15 16 Q. With what degree of frequency do you have 16 17 contact with her? 17 18 A. I call her and tell her I love her once a 18 19 week. 19 - 20 Q. Is that something unique to your 20 21 relationship with her? 21 22 A. Yes. 22 23 Q. And what is it about your relationship 23 24 with her that's unique? 24 25 A. We've been fighting the Jeffrey Epstein case 25 (561) 832-7500 PROSE COURT Page 352 A. No, sir. Q. There were some other — Ms..., is that, is that an individual that you took to Mr. Epstein? A. Yes, sir. Q. And on how many occasions did you take her to Mr. Epstein? A. Around four times, Q. And did she go alone after that? A. Yes, sir. Q. And did she tell you how many times she went? A. No, sir. Q. Has she indicated to you any intent to sue you for taking her to Mr. Epstein? A. No, sir. Q. Did the discussion ever come up? A. No, sir. Q. Do you feel responsible in some part for taking her to Mr. Epstein if she claims that she was somehow damaged as a result of going to sec him? A. No, sir. Q. And did you tell her when you first took her to Mr. Epstein that nothing bad was going to hapeen, that she wasn'tring to be asked to do 5 (Pages 349 to 352) REPORTING AGENCY, INC . (561) 832-7506 EFTA01108812 Page 353 1 anything she didn't want to do? 2 A. Correct. 3 Q. Did you tell her exactly what to expect 4 when she went? 5 A. No. 6 Q. And did she -- after she went the first 7 time, did she indicate to you anything about the visit? 9 A. Yes. 10 Q. What did she say? 11 A. She told me she did not like it. 12 Q. That would be on the first visit? 13 A. Yet 14 Q. Did she say Mr. Epstein did anything or 15 forced her to do anything that she didn't want to 16 do? 17 A. Mr. Epstein always told us don't tell anybody. 18 He just wanted us to find girls. So, whatever 19 transpired between her and Mr. Jeffrey Epstein, i 20 don't -- I'm not sure. 21 MR. LUTHER: Move to strike as not being 22 responsive to the question. My question was, 23 if you will read back what my question was to 24 the witness. 25 (Tbe requested portion of the record was Page 355 1 anything at all that she didn't want to do that he 2 insisted that she do? 3 A. No. All she told me is that she was afraid of 4 him and she did not want to go back. S Q. And so what did you tell her after this first visit where you took her there and told her 7 that she could be as comfortable as she wanted and 8 she reported to you that she felt that she had to do 9 whatever Mr. Epstein wanted her to do? 10 A. Weil, I said why don't we go again and make 11 some money. 12 Q. So, it was you that encouraged her 13 notwithstanding whatever reservations she told you 14 to go back to Mr. Epstein? 15 A. Yes. 16 Q. And you told her let's do that because you 17 wanted to make money; is that correct? 18 A. Yes. 19 Q. And after the second visit, did Ms. • 20 tell you that, anything about her visit with 21. Mr. Epstein? 22 A. She told me the same thing. She was very 23 quiet about it. She said I do not want to go back. 24 Q. And notwithstanding that comment did you 25 take her back a third time? Faye 3 1 read by the reporter.) 2 THE WITNESS: Yes. 3 BY MR. LUTTIER: 4 Q. What did she tell you? 5 A. She said that she felt very obligated to do 6 what Mr. Jeffrey Epstein had asked her to do. 7 Q. And what did she say Mr. Epstein asked her 8 to do? 9 A. Take off her clothes. 10 Q. And you had told her before she went that 11 that was going to be requested of her, right? 12 A. Brom what I remember, I told her that, that 13 she would be in a room and we were going to massage his 14 thighs. And then oncel left the room you can be as 15 comfortable as you want to be with him. 16 Q. And did she say anything other than that 17 occurred? 18 A. Excuse me? 19 Q. Did she say anything other than that 20 occurred? 21 A. She said she wasn't comfortable. 22 Q. And did she say that she told Mr. Epstein 23 that? 24 A. No, she was scared of him. 25 Q. She indicate that she told Mr. Epstein %el (561) 832-7500 PROSE COURT 1 2 3 4 5 6 7 8 9 1.0 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 356 A. Yes. Q. And what did you tell her after she told you she didn't want to go back? A. I was stubborn and I said let's go back, and please make some more money. Q. So, would it be a fair statement to say that you coerced her into going back? A. Yes. Q. Now, why would you coerce a friend of yours to go back? A. Well, when you're -- at that time I was 14. And when you're 14 and you're poor, a young lady is going to do anything for money especially when you're intimidated by a man who lives in an island that was highly, highly known of. And i was very intimidated by Jeffrey, and he always wanted me to bring girls. And he told me, make sure you have a girl for me. So, at that time, I would only, at that specific time i would only have Q. Had you been brought up with any kind of moral upbringing from your parents? A. Yes. Q. And had you been taught as a, as a child from as far back as you can remember not to do things that were wrong? 6 (Pages 353 to 356) REPORTING AGENCY, INC. (561) 832-7506 EFTA01108813 Page 357 1 A. Yes. 2 Q. And you discarded your upbringing and 3 decided in order to make money you would tell your, 4 one of your good friends that notwithstanding her 5 reservations about going back to Mr. Epstein that b you wanted her to do that; is that correct? 7 A. Yes. 8 Q. Other than Ms. E telling you that she 9 felt that she was obligated to do what Mr. Epstein 10 wanted her to do, did she tell you anything about, 11 anything else about her conversations or 12 interactions with Mr. Epstein at any time? 13 A. She told me that if Jeffrey told her if she 14 was to tell anybody, she would be in trouble. 15 Q. Did she tell you anything else? 16 A. No. 17 Q. Now, at some point in time before you 18 filed this lawsuit, the FBI came to visit with you? 19 A. Yes. 20 Q. Is that correct? 21 A. Yes. 22 Q. And they took a sworn statement from you, 23 correct? 24 A. At what time? 25 Q. They took a sworn statement sometime 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 359 Eisenberg at the statement representing you, correct? A. Yes. Q. Okay. And did you tell the FBI what you just told me about the conversations you had with el ? A. No. Q. In fact what you told the FBI was exactly the opposite, was it not? A. Correct. Q. Now, there are a number of other people who in the first deposition you said you had contact with in the past. So, I want to make sure we haven't missed anybody with respect to my question about communications with them since September 24th of '09. There was a lady you referred to in your previous deposition by the name of At the time of your prior deposition you sae you know her last name. Do you now know her last name? A. No, sir. Q. Say what? A. No, sir. Q. Does the name Msound familiar to you? A. No, sir. Page 358 1 before you filed this lawsuit? 2 A. Yes. 3 Q And you were represented by a lawyer at 4 that sworn statement; is that right? 5. MR. EDWARDS: Object, I object to the 6 form. And I know that it's not your intention 7 to rehash the entire first deposition, but I 8 think this area was covered. So, to the extent 9 that it wasn't, then obviously the inquiry can 10 proceed, but we're not going to rehash the 11 entire event as it happened in the first 12 deposition. 13 MR. LUTHER: I have no intention to. 14 BY MR. LUTHER: 15 Q. You were represented by a lawyer at that 16 time, correct? 17 A. On Jeffreys behalf? 18 Q. No, on your behalf. There was a lawyer 19 there who represented to the FBI that he was your 20 lawyer, is that right? 21. MR. EDWARDS: Object to the form. 22 THE WITNESS: I am not understanding this, 23 sir. • 24 BY MR. LIMITER: 25 Q. There was a fellow by the name of James Page 360 1 Q Have you had any communications with this 2 lady since your September 24th, '09, 3 deposition 4 A. No, sir. 5 Q Have you had any communications with a 6 lady by the name of Jane Doe II since your September 7 24th, '09, deposition? 8 A. No, sir. 9 Q. Have you had any communications with a 10 lady by the name of Jane Doe since your September 11 24th, 2009, deposition? 12 A. No, sir. 13 Q. On your last deposition, you indicated to 14 us that at some point in tune Ms. Jane Doe,' 15 believe, had watched your son for you on some 16 occasion? 17 A. Yes. About two occasions. 18 Q. Okay. Other than those two occasions that 19 you've described in the previous deposition, has 20 Ms. Jane Doe ever watched your son since then or on 21 any other occasion? 22 A. No, sir. 23 Q Since your September 24th, '09, deposition 24 have you ever had anybody else watch your son or has 25 he always been with you since then? (561) 832-7500 7 (Pages 357 to 360) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108814 1 A. I have a,1 have a babysitter. 2 Q. And who is your babysitter? 3 A. 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 zs Page 361 A. I'm not really sure how to spell -- Q. Where — A. — her Q. WherenaZ4IMI reside? A. She resides in the, in the acreage. I'm not positive what the address is. Q. With what degree of frequency since September 24th, '09, have you utilized her services to watch your son? A. Very frequently. Ever since December, I mean January 1st, 2010, she watches my son regularly. Q. Is there like certain days of the week she automatically watches him? A. No. Q. And, and why -- is the frequency with which she watches your son since January of 2010 greater than the frequency with which you had people 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 363 A. Yes, or at night as well. Q. Whose shows do you sell? What line of shoes? . . A. I sell BCBG, Jessica Simpson. Coach. I can pretty much get any shoe. Q. And where do you get the shoes? A. Igo to Macy's. Igo to the clearance rack. I buy them for really cheap, and 1 sell them for what they are originally. Q. So, you would go into a Macy's, if there was a clearance and buy a half a dozen pairs of shoes? A. Yes. • Q. Without knowing what anybody's size was? A. Correct. Q. In other words you don't get somebody's order first and go fill the order? A. I could do that but I really don't — I would rather go there and buy a bulk of shoes with whatever size. And if someone is interested in a nail salon, you know, and if ifs their size, then they'll buy it Q. When did you first start selling these shoes? A. January I st, 2010. Q. And did somebody introduce you to this Page 362 1 watch your son prior to that date? 2 A. Excuse me? Can you — 3 Q. Why is she watching your son frequently 4 since January 10? 5 A. So I can work. 6 Q. Okay. Where are you working? 7 A. I sell Mary Kay, shoes, lingerie, and clothes. 8 Q. Mary Kay shoes? 9 A. Lingerie and clothes. 10 Q. Lingerie and what else? 11 A. And clothes. 12 Q. Is that, is that all of that Mary ICay 13 items; that is Mary Kay has a line of shoes, or are 14 you saying — 15 A. No. 16 Q. — that you sell Mary Kay cosmetics, plus 17 you sell shoes, plus you sell lingerie, plus you • 18 sell clothes? 19 A. Yes. 20 Q. All right And do you — what hours do 23. you work? 22 A. Well, 1 just, it's on my own hours. I will go 23' to tanning salons to see if anybody wants to buy. I 24 will go to nail salons. 25 Q. Is this all during the day? Page 364 1 business? 2 A. No. 3 Q. This is something you came up with on your 4 own? 5 A. Yes. 6 • Q. Okay. Who do you sell lingerie for? 7 A. I go to different areas. I go to, I will go 8 to strip clubs and sell lingerie if they want it. My 9' girlfriends. I sell lingerie to. Valentine's is coming 10 up. I will be selling a lot of lingerie soon. 11. Q. Who do you get the lingerie from? 12 A. Igo to local adult stores and I go to the 13 clearance and I buy them in bulk, and then I sell them 14 for the original or more price. 15 Q So and when do you go to these strip 16 clubs, during the day or at night? 17 A. Both. 18 Q. And what do you do at these strip clubs? 19 MR. EDWARDS: Object to the form You tan 20 EMSWer. 21 THE WITNESS: Yeah, I walk In with my 22 duffel bag MI oldie items I like to sell, 23 and the women get to choose what they wait to .24. buy 25. 8 (Pages 361 to 364) :(561) 832-7500 PROSE ,COURT REPORTING' AGENCY, INC. . (561) 832-7506 EFTA01108815 Page 365 1 BY MR.. LUITIER: 2 Q. Do you dance at any of these strip clubs? 3 A. No, sir. 4 ' Q. Have you danced anywhere since September 5 24th, 2009? 6 A. No, sir. 7 Q. Have you worked in any adult establishment 8 of any kind or nature since September 24th, 2009? 9 A. Not in a strip joint, no. 10 Q. Okay. Well, have you worked in any other 11 kind of adult establishment other than a strip joint 12 since September 24th, '09? 13 A. Yes. 14 Q. Where have you worked? 15 A. I have worked for my private clientele. 1.6 Q. What do you mean by "private clientele"? 17 A. I have worked, I have been company to a few 18 men that I have met ever since the last deposition, and 19 I provide company for than. 20 Q. The last time you told us you had worked 21 for an escort service. Do you recall that? 22 A. Correct 23 Q. Is this in essence the same thing you're 24 still doing? 25 A. No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 367 Q. So, what you are telling the ladies and gentlemen of the jury is somebody pays you three to $500 an hour just to be in your company and not to have any sex with you? MR.. EDWARDS: Object to the fonn. BY MR. LUTTIER: Q. Is that right? MR. EDWARDS: And just so that the record Is clear, the wage claim, the loss wages and loss of earning capacity has been withdrawn in the case. You can answer the question, if you understand the question. BY MR. LUTTIER: Q. Is that right. A. What was the question? Q. So you're telling the ladies and gentlemen of the jury that men pay you three to $500 an hour just for your company but you have no sex with them; is that correct? MR. EDWARDS: Object to the form. 111E WITNESS: Correct. BY MR. LUTHER: Q. Or is sex an additional charge? A. No, I don't have sex with them. Page 366 1 Q. Are you working for an escort service now? 2 A. No. 3 Q. Have you been working for an escort 4 service since September 24th, 2009? 5 A. No, sir. 6 Q. Do you advertise your services somehow? 7 A. No, sir. 8 Q. So, how do you — how do these people know 9 to retain your services? 10 A. Word of mouth. 1 Q Okay. And how do they get word of mouth? 12 A. I have one client, Bobby, and he has referred 13 me to three other clients. 14 Q. And what's the difference between what you 15 are doling with these clients and what you did with 16 the escort service? 17 A. Well, the difference is is that I don't 18 perform any sexual acts. It's pretty much just I am 19 company if — they pay me for my company. 20 Q. Well, how much do they pay you for your 21 company? 22 A. It ranges anyway, any any price is from 300 23 to 500. 24 g 300 to 500 what? 25 A. An hour. Page 368 1 Q. Have you ever — or when did you start 2 this little escort service that you're describing 3 now? 4 A. Well, I don't know what your definition of 5 escort is. It's pretty much I offer my company to got 6 paid. January 5th, 2010. 7 1 Q. And how did you fix on the date 8 January 5th? 9 A. I had met a gentleman named Bobby in CityPlace 10 and we sat down for a drink and we just started talking. 11 Q. Had you gone there to meet him? 12 A. No, I just went there by myself. And I 13 just — 14 Q. Did you meet him in an establishment at 15 CityPlaoe? 16 A. I met him at Carousel. 17 Q. Okay. That's a restaurant and a bar 18 there? 19 A. It's a restaurant, correct. 20 Q. Okay. Is that Can Can -- 21 A. Can Can Carousel (sic). 22 Q. Motive or motif? 23 A. Can Can Carousel. 24 Q. Right The waitresses are in cancan 25 outfits and dance on the tables or something like 9 (Pages 365 to 368) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108816 Page 369 1 that? 2 A. Yes. 3 Q. And were, were you there -- why were you 4 there? 5 A. I was just — Igo out by myself sometimes 6 just to recuperate and have a nice drink and a nice 7 dinner by myself. I am single. 8 Q. So, were you there for dinner or were you 9 there for something else? 10 A. I was there fora drink. 11 Q. So you went to the bar? 12 A. Yes. 13 Q. And this fellow happened to be at the bar? 14 A. Yes. 15 Q. And it wasn't, it wasn't prearranged. He 16 just happened to be at the bar? 17 A. Correct 18 Q. Okay. And then how did it evolve from you 19 sitting next to this person who you had no contact 20 with prior to that, right? 21 A. Correct. 22 Q. To suddenly he was lining up escorts for 23 you, or lining up people for you to escort? 24 A. He did not line up escorts for me at that -- 25 or, I don't know what your definition of escort is. But Page 371 1 males approximately your age would ask you out to a 2 movie or something like that on a date. Has that 3 happened to you? 4 A. Yes. With these men, yes. 5 Q. So, what these people -- you consider 6 these people dates; is that what you're telling me? 7 A. Yes, we go out to the movies. We go out to 8 eat dinner. 9 Q. How many dates did you have as a youth 10 where people paid you three to 5500 an hour — 11 A. Sir-- 12 Q just to have the opporttmity to date 13 you? 14 A. Ever since Jeffrey Epstein -- 15 MIL EDWARDS: Object to the form. 16 THE WITNESS: -- I have never hung out 17 with anyone my age. He has taught me that 18 older men have money, and that's all I know. 19 BY MR. LUTTIER: 20 Q. Is that, is that something that you had to 21 be taught that is this was some particularly unique 22 thing that you learned from Mr. Epstein, older men 23 have money? 24 A. Yes. 25 Q. And do you believe that statement Is true, Page 370 1 he didn't line anybody up at that specific time. We, I 2 just — I was just at the bar and he just so happened to 3 be at the bar as well, and we started talking. I was 4 alone. He was alone. He is an older man He told me 5 he was married, and he said that he would love to enjoy 6 my company. 7 Q. And what did you say? 8 A. I said sure. 9 Q. Is it, is it now your practice to go out 10 with older married men without their wives so they 11 can enjoy your company? 12 A. Sure. 13 Q. And what do you think those older married 14 men have in mind? 15 A. I don't know what they have in mind but with 16 the four customers I do have, I know what they have in 17 mind. 18 Q. These clearly aren't dates, right? These 19 are not — 20 A. They — 21 MR. EDWARDS: Object to the form. 22 • BY MR. LUTFIER: 23 Q. When I say a date, I assume that there 24 have been times in your life, and maybe I am wrong 25 and cornett me ifl an wrong, where a male, young Page 372 1 older men have money? 2 A. As of right now, yes. 3 Q. No such thing as older men without money, 4 right? 5 MR EDWARDS: Form. 6 THE WITNESS: White collar men have money. 7 BY MR. LUITIER: 8 Q. White collar. You mean the color of the 9 shirt they wear? What you did mean by white collar? 10 A. Successful men. 11 Q. You mean you've figured out how to look at 12 an older man and determine whether or not he is 13 likely to have money? 14 A. Yes, Jeffrey has definitely showed me the 15 ambiance and the, the way a man should look to where 16 they have money. 17 Q. Well, how did he teach you that? 18 A. Well, I was with hlm since I was 13, 14, 15, 19 16, going onto 17, and I pretty much have an eye for 20 that 21 Q. What do you mean when you say you were 22 with him for that period of time? 23 A. I was with Jeffrey — 24 Q. But I mean - 25 A. -- seeing Jeffrey. I (561) 832-7500 10 (Pages 369 to 372) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108817 Page 373 Page 375 1 Q. — did you and he go out to dinner? 1 A. Well, I sat down and I talked to him and we 2 A. No. 2 had a nice conversation. And he pretty much told me 3 Q. Didn't — maybe I misunderstood something 3 that he has a wife, but he would lilts to take me out to 4 from your last deposition, but didn't you simply go 4 dinner as much as, you know, as much as possible. 5 to Mr. Epstein's house -- 5 Q. Well, did you ask him — did that seem 6 A. Correct. 6 unusual or strange to you? 7 Q. to perform massages? 7 A. At this time in my life, no. 8 A. Correct That's in the past B Q. Because you had worked as an escort in an 9 Q. So, he wasn't taking you out in public to 9 escort service for a substantial period of time in 10 movies or dinners or shows or things like that 10 the past, right? 11 correct? 11 A. Correct 12 A. No, but he has sent me out with a couple of 12 MR. EDWARDS: Object to form. 13 girls to buy a movie, he's rode me around in his car. 13 BY MR. LUTHER: 14 Q. So, how did he show you how to identify an 14 Q. And you knew what married men that wanted 15 older man that you believe has money? 15 to go out with young women really meant, correct? 16 A. Well, as a younger girl when I am 13, and 14, 16 MR. EDWARDS: Form. 17 and 15 years old, and I am going to a mansion once or 17 THE WITNESS: Correct. 18 twice a day, and I see that environment, subconsciously 18 BY MR. LUTHER: 19 you, you, you learn that 19 Q. And you knew that's exactly what Bobby had 20 Q. So, what you have done is you believe you 20 in mind, right? 21 have acquired a skill and that skill is how to look 21 A. No, be told me he did not want to have sexual 22 and figure out whether or not older men have money, 22 intercourse. He just wanted company. He's an old man 23 correct? 23 that has an old wife and he just simply wants a young 24 A. Jeffrey taught me that — 24 woman to have company with. 25 Q. That wasn't my question. 25 Q. And you think it's perfectly acceptable to Page 374 Page 376 1 A. — lifestyle. 1 charge him — what do you charge him, by the way, 2 MR. LUTTIER: Move to strike, not 2 300 or 500 an hour? 3 responsive. Would you read my question back to 3 MR. EDWARDS: Object to the form. 4 her? 4 THE WITNESS: Whatever he wants to give 5 MR. EDWARDS: Object to the form. And the 5 me. 6 answer was responsive to the question. 6 BY MR. LUTHER: 7 THE WITNESS: I believe it was. 7 Q. Well, what's your — what do you tell him . 8 MR. LUTHER: Go ahead and read back my 8 the charge Is? 9 question. 9 A. I don't tell him anything. Whatever he wants 10 (The requested portion of the record was 10 to give me. 300 most of the time. 11 read by the reporter.) 11 Q. How many times have you gone out with him? 12 MIL LUITIER: Now, would you answer — 12 A. Around five times now. 13 THE WITNESS: Correct 13 Q. Okay. Tell us where you have gone. 14 MR. LUTHER: Okay. 14 A. We've went to several, actually we went to 15 BY Mft. LUTTIER: 15 several hotels. 16 Q. Now, how did you know when you were 16 Q. What do you mean several hotels? 17 sitting there — strike that. Was this individual 17 A. We've been to La Quinta. 18 who I believe you said his name was Bobby that you 18 Q. What is there at La Quints? 19 met at the Carousel bar, was he one of those 19 A. A hotel room. 20 individuals that you identified as an older man with 20 Q. Is there a bar them or something? 21 money? 21 A. No, it's just a room. 22 A. Correct. 22 Q. You went to a hotel room with him? 23 Q. And how were you able to determine sitting 23 A. Correct, because he has wife and I can't go to 24 at a bar meeting this stranger for the first time 24 his house to have company with hint 25 that he was an older man with money? 25 Q. So, what exactly did you and Bobby do at (561) 832-7500 11 (Pages 373 to 376) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108818 Page 377 1 the La Quinta? 2 A. 'just gave him company. 3 Q. Okay. Well, how do you, to use your 4 phrase, give him company? 5 A. Like I am giving you company right now, l talk 6 to him. He confines in me and we have conversations. 7 Q. And where do you do this, in his hotel 8 . room? 9 A. Yes. 10 Q. And why wouldn't you just do that out in 11 public if that's all you were doing? 12 A. We have done that out in public. 13 Q. Well, why would I don% understand why 14 Bobby took you to the La Quinta and took you into a 15 hotel room if all you were — 16 A. How can you not understand that? 17 Q. — if all you were going to do is share 18 company? Had you suggested to him that you should 19 get a motel room? 20 A. No. 21 Q. Was that his idea? 22 A. Yes. 23 Q. Did he tell you why he thought you should 24 get a motel room? 25 A. So, we can have silence instead of always Page 379 1 happened. 2 MR. EDWARDS: Form 3 BY MR. LUITIER: 4 'Q. What is Bobby — 5 A. That is what happened. 6 Q. What is Bobby's last name? 7 A. Oh, l have no idea. 8 Q. When you, weren't you at all concerned 9 about going out with a stranger? Didn't you want to 10 know at least what his name was? 11 A. I bow his name is Bobby. 12 Q. Is that all thought you needed to know? 13 A. That's all I felt I needed to know. 14 Q. Where does he live? 15 A. I don't know. I don't care where he lives and 16 I don't want him to know where I live. He has a wife. 17 Q. How, how did, how did you and he meet at 18 the La Quinta? Did he come pick you up someplace? 19 Did you pick him up? 20 A. No, we just drove there. 21 Q. Is, was this a prearranged place to meet? 22 A. Yes. 23 Q. All right. And how did that 24 prearrangement occur? 25 A. Well, I gave him my number and he calls me. 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 378 being at a restaurant. Q. How were you dressed on that occasion? A. Just like this. Q. Did you at any time in the hotel room undress? A. No. Q. Partially or completely? A. No. Q. Did you ever place your hands on Bobby — A. No. Q. ' — while you were in the motel room? A. No. Q. Did he ever place his hands on you? A. No. Q. Any kissing? A. No. Q. So, Bobby here pays you $500 or $300 to go 17 to a La Quints and literally sit across the room 18 from him; is that right? 19 A. Yes. 20 MR. EDWARDS: Form. 21 THE WITNESS: Some people have money like 22 that. 23 BY MR. LUITIER: 24 Q. At least that's what you're saying 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Page 383 Q. And he says — A. I do not have his number. Q. And what did he say? A. Hi, would you like to meet at the La Quinta. Q. And you say sure? A. Yes. Q. And do you do that during the day, do you do that during the day or at night? A. At night — or during the day, sorry. Q. Well, which was it? A. Day. Q. And what La Quinta was this? A. On Okeechobee. Q. Out by the Turnpike? A. Correct. Q. And who selected the hotel? • A. Bobby. Q. And what's Bobby do? A. I have no idea. Q. Did you ever ask him? A. No. Q. Did you ever ask him anything about him. A. He talks about his wife. No, we just have nice conversations. . As far as you're concerned this is 'ust (561) 832-7500 12 (Pages 377 to 380) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506' EFTA01108819 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 381 strictly a business deal, right? A. Yeah, and a friendship as well. Q. Where else have you gone with Bobby? A. Out to eat. Q And you said you went about five times. So if once to the La Quinta, and the other four times were out to eat? • A. No, we went to the La Quinta again. Q. Same La Quinta? A Yes. Q. Same room? A. No. Q. Okay. So La Quinta times two? A. Okay. Q. And where did you go to eat? A. To the Carousel again. Q. Anyplace else? A. We went to — and then the fifth one is New York. Q.' And when did you go to New York? A. February 2nd through the 4th. Q. Of 2007? A. Correct. Q. Tell me how that occurred. Bobby just calls you up and says — well, go ahead and tell me Page 383 1 A. Oh, I don't know the address. I know it's 2 near Grand Central Station. 3 Q. So, so, all Bobby said was I'm going to 4 New York, and, and do you want to go book a flight? 5 A. Yes. 6 Q. Did he say that you were going to do 7 anything when you got to New York or did he just say 8 go take a trip to New York? 9 A. He said take a trip to New York. And he said 10 I will meet you at Anna's. You know, I will meet you at 11 Anna's one time and Mars it. 12 Q. Did you know this Anna before you went? 13 A. No. 14 Q. Had you — 15 A. I just thought it was a nice opportunity to go 16 to New York. 17 Q. So, what are you 22 now? 18 A. Twenty-one. 19 Q. Twenty-one. So, and how long had you 20 known Bobby at that point in time? 23. A. Oh, since January, January 5th, 2010. 22 Q. So, you had known him for less than a 23 month? 24 A. Yes. 25 Q You met him kt a bar? Page 382 1 what occurred. 2 A. Bobby calls me. He says, well, you can, I'm 3 going to New York with my wife and I said okay. He says 4 you should come sanetime. I said all right. He said if 5 you would like to, you can, you can book yourself a 6 flight. So, I had booked myself a flight to New York. 7 Q. Well, this is like — this was last 8 Tuesday? 9 A. Yes. 10 Q. I mean, does he tell you — well, you were 11 just flying into New York. New York City is a big 12 city, a big state. Does he tell you where you're 13 going or anything? 14 A. Yes. 15 Q. Where were you going? 16 A. He has a friend Anna that owns a condo, and I 17 stayed with her for two days. 18 Q. I'm going to guess that Anna is not his 19 wife. 20 A. No. 21 Q. Who's Anna? What age is she, your age? 22 A. No, she's an older woman. 23 Q. What do you mean by older? 24 A. She's probably in her 40s. 25 Q. Does anybody else — where was this condo? (561) 832-7500 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 384 A. Uh-huh. Q. You knew — didn't know his last name? A. No. Q. You know nothing about what he does? A. No. Q. Don't know if he's got a criminal background? A. No. Q. Literally you know nothing about him? A. Correct. Q. Other than you believe he has a lot of money? A. Correct Q. He says go to New York and stay with a friend of mine named Anna? A. Correct. Q. You don't know who Anna is? A. No. Q. Never met her? A. No. Q. Don't know how old she is? A. No. Q. Don't know what she does for a living? A. No. • Q Don't know if she has a criminal 13 (Pages 381 to 384) PROSE COURT REPORTING AGENCY, INC. . (561) 832-7506 EFTA01108820 Page 385 1 background? 2 A. Correct. 3 Q. You buy yourself a ticket, pay for a 4 ticket? 5 A. Yes. 6 Q. You get on a plane and you fly to New 7 York? 8 A. Correct. 9 Q. You go to La Guardia? La Guardia Airport, 10 is that where you want in? 11 A. J.F.K. 12 Q. You go into J.F.K. You get in a cab? 13 A. Correct. 14 Q. You give them the address of wherever Anna 15 is or did somebody come pick you up from the 16 airport? 17 A. No, Thad, I had an address on a piece of 18 paper, and I gave him, the taxi -- 19 Q. The cab driver? 20 A. — driver, yeah. 21 Q. So, you go to this Anna place, this Anna 22 lady's, woman's residence? 23 A. Yes, her condo. 24 Q. And you have never seen her? 25 A. No. Page 387 1 A. I told Bobby I would rather have a girl go 2 with me because I don't want to go by myself. I would 3 Lilco to enjoy New York with a friend of mine. 4 Q. Well, why were you afraid to go alone? 5 A. I wasn't afraid to go alone. I just would 6 rather go with a friend instead of myself. 7 Q. I just want to make sure I understand 8 this. You had no fear or trepidation about going on 9 this trip? 10 A. Of muse I did a little bit, but it was an 11 opportunity for me to go to New York and I took it. 12 Q. Okay. What happens when you get to New 13 York, and you ring the doorbell at this lady's, 14 Anna's condominium or apartment or whatever she 15 lived. 16 A. I introduce myself. introduces herself 17 to Anna and it was nice. 18 Q. What does Anna say toyou? Does she 19 say — 20 A. HIi, welcome, come in. 21 Q. And does she say, ever tell you what her 22 relationship to Bobby is? 23 A. No. She said Bobby's a friend. 24 Q. And so do you stay at this condominium? 25 A. Yes. Page 386 1 Q. All right. And what do you do? Do you 2 get to her condominium and just go ring the 3 doorbell? 4 A. Yes. 5 Q. Did anybody else go with you on this trip? 6 A. Yes. 7 Q. Who else went th you? 8 A. My girlfriend,M. 9 Q. I thought I asked you earlier whether you 10 had any communications with anyone since September 11 24th who's flied a claims against Mr. Epstein. You 12 said, no, other than • 13 A. Oh, well, •, that's, this is her attorney 14 as well. 15 Q. But she's got a claim going against 16 Mr. Epstein with — 17 A. Fm sony. I didn't think about that 18 Q. — the same lawyer you have. 19 A. I thought you mgelsomeone. 20 Q. Okay. Now, so . is going on this trip? 21 A. Yes. 22 Q. Does... know old Bobby? 23 A. No. 24 . Q. Did Bobby tell you to bring . along 25 too? Page 388 1 Q. And, and who-all is staying in this 2 condominit 3 A. JustM., I, and Anna. 4 Q. Does there — what time do you get to New 5 York? 6 A. Well, we missed our flight, so we — I am 7 pretty sure we got there around 4. I'm guessing. 8 Q. Ballpark. Does there come a time that 9 Bobby hooks up with you someplace? 10 MR. EDWARDS: Object to the form. 11 THE WITNESS: He went to Anna's house on 12 Wednesday. 13 BY MR. LUTFIER: 14 Q. Is Anna's house the same as the 15 condominium yodre staying in? 16 A. Yes. 17 Q. Okay. So he comes to where you're 18 staying? 19 A. Yes. 20 Q. But he doesn't come on Tuesday, the day 21 you come up. He comes on. Wednesday? 22 A. Correct. 23 Q. So, what do you all do on Tuesday after 24 you get there? 25 A. We just han out havi a good time — (561) 832-7500 14 (Pages 385 to 388) PROSE COURT REPORTING AGENCY, INC. • (561) 832-7506 EFTA01108821 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 389 Q. Sit around in a condominium? A. — drinking champagne. Yeah. Q. Did you go out -- A. I'm in New York Q. — and see — do you go out and see the city Of just — A. YetALI went out to the see the city. I walked. and I walked around by ourselves. We ate hot dogs, dressed in New York clothes, and we just went sightseeing. Q. You said you were drinking champagne? A. We had a couple of glasses of champagne on Wednesday with Bobby. Q. That's Wednesday. Okay. Well, I am going to get to Wednesday. Let's stay on Tuesday. Tuesday is the day you fly up there. Champagne on Tuesday? A. Yeah, we were tired. No, not — Q. Any drinking going on any time on Tuesday? A. Na that I recall. I was very tired. So — Q. Okay. And — A. Tuesday, Tuesday night S and I did go out to a restaurant, Angelo's. So, yes, I did have a Merlot. Q. Did Bobby go? Page 391 1 Q. Did you, did you go out shopping with this 2 fellow? Did he go buy you stuff while you were in 3 New York? 4 A. With Bobby? 5 Q. Bobby, yeah- 6 A. No. 7 Q. He pay — did he gigisup your dinner tab? 8 A. No. !writ to - IM and I had took a taxi 9 to Angelo's. 10 Q. Right. 11 A. We heard that was a good restaurant. And 12 actually we, we met up with a guy there that I have no 13 idea who he is but he was by himself and he offered to 14 buy us dinner. 15 Q. And what was his name? 16 A. I don't even ber. 17 Q. So, you and ago to New York You go 18 to a restaurant. You meet a person who would be, 19 who was an absolute stranger to you and — 20 A. Yes, we're in New York having a good time. 21 Q. And he says, why don't you girls have 22 dinner with me and you say fine? 23 A. Yes. He was alone and obviously saw two hot 24 girls and offered for, to pay a tab for dinner, yeah. 25 Q. Okay. What do you mean by hot girls? Page 390 1 A. No. 2 Q. Okay. So where is Angeles in 3 relationship to where you're staying? 4 A. I don't know NOW York, sir, sir. 5 Q. Did you walk there or did you have to get 6 a cab? 7 A. We, we got a cab. 8 Q. All right. So, you go to, you go out to 9 dinner. By the way, who is paying for all of this? 10 A. What do you mean? 11 Q. Who paid for the trio Who paid for the 12 flight ticket to begigavith? 13 A. I paid for III% flier and Bobby had paid 14 for my 15 Q. Did you go first class? 16 AL NO. 17 Q. So, how much did you pay for 18 flight? 19 A. 478. 20 Q. And you just took her along just because 21 she was a friend of yours? 22 A. Yes, she's a very good friend of mine. 23 Q. And then when you got up there, I assume 24 you didn't pay anything to stay at kolta's place? 25 A. No. (561) 832-7500 Page 392 1 A. Two good looking girls — 2 MR. EDWARDS: Form. 3 THE WITNESS: — walking in Angelo's, 4 definitely not from New York. We weren't 5 wearing all black. 6 BY MR. LUTHER: 7 Q. What did you do after dinner? A. We went right back to the hotel. 9 Q. Did this fellow take you? 10 A. No, we took a taro. 11. Q. And when you say hotel you mean the condo? 12 A. Yes. 13 Q. Okay. And then the next day do you hook 14 up with Bobby? 15 A. Wednesday, yes. 16 Q. And what do you do when you — when does 17 he hook up with you? 18 A. He came over in the mid day, maybe around 19 1:00, and we had a couple of glasses of champagne and — 20 Q. With Anna? 21 A. No, not with Anna. 22 Q. Was she gone from the condo? 23 A. No, she was there. 24 Q. Okay. But you guys didn't have champagne 25 in the condo? 15 (Pages 389 to 392) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108822 Page 393 1 A. Yes, we drank champagne in the condo. 2 Q. Bobby nd you — • 3 A. 4 Q. — an . But Anna, She was there but 5 didn't have champagne, or she wasn't there? 6 A. I, I don't believe she had champagne. She was 7 there, yes. 8 Q. Okay. All right. All right. So you guys 9 have some champagne and what happens next? 10 A. We had a conversation. We just hung out, had 11 a good time, watched TV. 12 Q. Did you ever go anywhere? 13 A. No. 14 Q. So, Bobby comes to this condo, stays 15 there. You guys are there and then at some point he 16. leaves? 17 A. Yes. 18 Q. When does he leave? 19 A. Couple of hours later. 20 Q. What do you-all do the rest of the day? 21 A. We just hung out. 22 Q. What does that mean? 23 A. We hung out in the condo. 24 Q. Did you ever go out that day? 25 A. That day, yes. We walked down the same street Page 395 1 take you out to dinner? 2 A. Yeah. 3 Q. And so you go with him? 4 A. Yes. 5 Q. Again you don't know anything about the 6 PO 7 A. No. 8 Q. And how old is this fellow? 9 A. I don't know. 10 Q. Older than you? 11 A. Yes. 12 Q Okay. Did he look lie he had money? 13 A. I didn't care if he had money or not. i just 14 wanted to see the town. 15 Q. Okay. Just an opportunity? 16 A. Exactly. 17 Q. So, you and . go with this fellow to, 18 out to dinner? 19 A. Yes. 20 Q. And he picks up the tab? 21 A. Yes. 22 Q. And where do you guys go then? 23 A. He actually took us to see the Statue of 24 Liberty. We did not go on the boat. We just actually 25 saw it from — 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 394 that we walked down -- I think it's Grand Central Station. I'm not sure because I'm not from there, but we went sightseeing. Q. Okay. A. A little sightseeing, nothing special. Q. Did you have a meal out again? A. No. On Wednesday, on Wednesday, yes, at night. Yes, on Wednesday night. Q. Where did you go and with whom? A. We went with -- oh, my goodness. i can't remember his name but someone from New York and he took us to Saigon Grill. Q. Well, who was this individual? A. We didn't know him either. Q. Where did you meet him? A. II. and I were just looking for opportunities to go and look around town. Q. Did you meet him in a bar earlier in the day or was it somebody that Bobby knew -- A. No, on the street. Q. -- or setup? You met this guy on the street? A. Yeah, we were walking. Q. Two hot girls walking down the street in New York You ran into this guy and he offers to (561) 832-7500 PROSE COURT 1 Q. Did you ever during this time that he was 2 buying you dinner and taking you to the Statue of 3 Liberty manage to get his name? 4 A. I did know his name but I don't remember it. 5 Q. Get a phone number from him and call him? 6 A. No, I gave him my phone number. 7 Q. Okay. When you pass out your phone 8 number, do you have like a card that you give 9 people? 10 A. No. 11 Q. You just scribble it on an envelope or 12 napkin or something? 13 A. Or they put it in their phone. 14 Q. Have you ever had business cards? 15 A. I have in '07, '08, but it wasn't for any 16 escort or any personal company like that. It was 17 actually for, to sell shoes and purses. 18 Q. To sell shoes and purses for who? 19 A. For myself. 20 Q I thought you said you just started the 21 shoe business in January of 2010. 22 A. I didn't say I just started it. i've 23 always — I do it once in a while just to make extra 24 money. 25 Q. Is it — did you do it with a business Page 396 i 16 (Pages 393 to 396) REPORTING AGENCY, INC. (561) 832-7506 EFTA01108823 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 397 name or — A. No, I just wrote III on the card and then my number and then I said if you're ever interested in any shoes or purses, give me a call. Q. Has there ever been any type of — I'm going to call it a business cant You know what a business card is? A. Yes. Q. Has there ever been any type of business card that contained a number which is a number at which you could be reached with either your name on it, your real name, or any other name that you used for any purpose whatsoever? Does any such card exist in the world? A. Yes. There was a card that said al and then my old number. Q. Okay. And is that the only thing that was on that card? A. The only thing with two kissy marks. Q. Now I want to make sure you understand my question. Other than that card is there any other business card that's ever existed from the beginning of the world until now that had your phone number on it — A. Uh-huh. Page 399 1 Q. And you say three years ago. Are you -- 2 does that mean it was in the year 2007? 3 A. Yeah, beginning of '07. 4 Q. .For what period of time did you dispense 5 those cards, give them out? 6 A. I didn't really dispense a lot of them at all. 7 1, maybe like for a five month period. I didn't really 8 dispense them at all. 9 Q. And who did you give them to? 10 A. Back three years ago I would give them to 11 potential clients. 12 Q. What do you mean potential clients? 13 A. Potential clients. 14 Q. What kind of clients? 15 A. To run escort. 16 Q. This is when you were working for an 17 escort service? 18 A. No, I was working for myself. 19 Q. You were a self-employed escort? 20 A. Yes, self, yeah. 21 Q. And what, and what were you doing business 22 as? What was your name? Did you have a name for 23 your business? 24 A. No. 25 Q. And why were you using a fake name? 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 398 Q. — and a name? A. Yes. Q. — whether it was your real name or some stage name or some other name that you've used? A. Yes, there has been. Q. Okay. There mere a bunch of those, weren't there? MR. EDWARDS: Form. THE WITNESS: What do you mean a bunch of those? BY MR.. LUTTIER: Q. Go ahead. Tell me about the other cards that existed. A. One card, it was a black card. This was probably three years ago. Yes, three years ago. It had, rm pretty sure, a fake name on there and a number to contact me and that's it. Q. And what else was on the card? A. I think it was roses. I'm not sure. Q. What else, what other words were on the card? A. No words. Just my name and my number. Q. And do you remember the name that you used? . A. If anything it mould be Page 400 1 A. Why use my real name? 2 Q. Any other reason why you were using a fake 3 name? 4 A. Yeah, because I don't want stalkers. 5 Q. Now at the time you were using this card, 6 you would give that to prospective escorts; that is 7 males that would pay you money to go out with you, 8 right? 9 A. Correct. 10 Q. And again were you did you figure out 11 how to target what you thought were older men with 12 money? 13 A. Col I ei.t. 14 Q. Now, when you were using the card that 15 said Taneal, not only were you going out with these 16 individuals but you would pertain' sexual acts with 17 these individuals, did you not? 18 A. Correct. 19 Q. What — and you say this went on for a 20 five-month period roughly? 21 .A. Dispensing of the cards. 22 Q. For what period of time, though, were you 23 conducting your own escort' ervice? 24 MR. EDWARDS: Form. 25 THE WITNESS: I can't tell you that. •(561) 832-7500 17 (Pages 397 to 400) PROSE COURT REPORTING AGENCY, INC. . (561) 832-7506 EFTA01108824 Page 401 1 BY MR. LUTDER 2 Q. Well, was It throughout the whole year — 3 A. I've always before January 2010, I've always 4 been independent in some way or another except when I 5 was with or 11 months. 6 Q. What do you mean by you were independent? 7 You mean you were, you were running your own escort 8 service? 9 A. No, I was running me. 10 Q. Okay. But I mean what you were running 11 was an escort service with one person, that being 12 you? 13 A. Correct 14 Q. All tight. Now, was there a particular 15 clientele that you targeted while you were operating 16 as your one-man or one-woman escort service? 17 A. Old men. 18 Q What, old men? 19 A. Yep. 20 Q. You liked older men better than younger 21 men? 22 A. Yes. 23 Q. And why did you like older men better? 24 A. Beeanse Jeffrey had money, so I assumed that 25 older men had money. 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 403 Q. Okay. Did you ever get paid $2000 a day when you were working for yourself? A. No. Q. What's the most you recall getting paid when you worked for yourself? MR. EDWARDS: Form. THE WITNESS: On advise of counsel I am invoking my Fifth Amendment rights under the United States Constitution. BY MR. LUMER: Q. And what why would you be invoking your right under the Fifth Amendment? Do you think you committed some kind of crime? A. On advice of counsel I am invoking my Fifth Amendment tights wider the United States Constitution. Q. Tell the ladies and gentlemen of the jury what acts and activities you engaged in with these older men that you had targeted and thought were rich for which you got paid between $50 and $2,000? A. Between what dates? Q. While you were operating your own escort savice. A. Between what dates? Q. Well, let's take, you said it was 2007. So, let's take 2007. 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 402 Q. So, you, your reason for picking old men was you thought they were rich? it Correct. Q. And that's what you wanted was rich people? A. Correct. Q. And how much would you get paid by these clients? A. Anywhere froni $50 to — sir, I don't recall what I made. I can't I can't answer that question truthfially. Q. Well, you said in your last deposition, but I don't know if this is while you were working on your own escort service or when you were working for somebody else, that you made as much as $2,000 a day; do you recall that? MR. EDWARDS: Object to the form. THE WITNESS: Correct BY MR. LUTHER: Q. Okay. All nee. So, is that while you were working for somebody else's escort service or is that while you were self-employed in your own escort service? A. I did that together. I worked for escort services and I've also worked for nwself. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 L7 18 19 20 21 22 23 24 25 Page 404 A. Sexual intercourse, oral, and just strictly company, naked company. Q. Naked company? A. Correct Q. Meaning? A. Sitting there naked and talking, having a conversation. Q. So, a customer would pay you — by the way when you were running your own escort service, how would you actually meet the client? Would they come pick you up, would you pick them up, that kind of thing? MR. EDWARDS: Object to the form. THE WITNESS: I would meet them at their house. BY MR. LUTITER: Q. Okay. Was that typically what you did, you would go to a client's house? A. Correct. Q. And so some of these clients that you went to, all of whom were, fit within the category of rich older men? A. Correct. Q. .You— some of them you would just go, go in and disrobe and sit in their house and talk to (561) 832-7500 18 (Pages 401 to 404) PROSE COURT REPORTING AGENCY, INC. 1561) 832-7506 EFTA01108825 Page 405 them? 2 A. Correct. Or take a bath, either/or. Q. Take a bath with them or alone? A. With them or without them. 5 Q. Would you get calls from individuals whom 6 you had never met before? 7 A. Correct. 8 Q. And then would you have some clients that 9 would be repeat business that would call you again? 10 A. Correct. 11 Q. How would you know if someone called you 12 on the phone whether or not that's, anything about 13 the person? 14 A. How would I know? 15 Q. If the person called you on the phone, 16 would they typically just give you an address and 17 say come meet me there? 18 A. Correct. 19 Q. So how — what did you know about this 20 person before you went to their home? 21 MR. EDWARDS: Form. 22 THE WITNESS: That he has a penis and that 23 he has money. 24 BY MR. WITTER: 25 Q. And how would you be able to ascertain he Page 407 1 discussion about dollars, how much? • 2 A. If you want to pay my phone bill, I can give 3 you naked company. If you want to pay my son's tuition, 4 I can give you naked company. Bargaining, you know. 5 Q. Would the, would the person actually do 6 that, sort of barter and actually pay your phone 7 bill as opposed to giving you the money? Is that 8 just the amount of money that he would give you is 9 what your phone bill was? 10 A. It would go either way. 11 Q. So, let's — 12 A. rd say, hey, I need my phone bill paid; you 13 can pay my phone bill. 14 Q. Let's use the example of your son's 15 tuition. 16 A. Ifit-huh. 17 Q. Is that, is that an actual event where you 18 told somebody I need my son's tuition paid? 19 A. Yet 20 Q. Okay. And how much was the tuition 21 roughly? 22 A. It's $400 a month. 23 Q. Okay. So you go to this client and you 24 say I need to have my son's tuition paid. That's 25 400 bucks a month. Now, are you — did you 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 406 bad money? A. I'm not working for free. Q. Well, would you have a discussion up front in the first phone call about money? A. Sometimes. Q. Because these are people -- A. I don't hie to talk over the phone. I would rather talk in person. Q. Okay. But these would be people that you had, they had gotten your number someplace but you had never met the first time, right? A. Correct Q. Okay. So then, so a guy calls. You talk to hint You say you don't want to talk money the first phone call, so then you go to his house? A. Coned. Q. Do you have a discussion with him at that point in time about money? A. Correct. Q. Okay. And, and what would that discussion be? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 A. 1 can accommodate you with whatever your needs 22 are, and you can accommodate me with whatever my needs 23 are. . 24 Q. And would you, would you have a specific 25 Page 408 communicate him that you needed just one month's paid or more than one month? A. If they want to pay one month, great, if they want to pay two, greater. Q. I mean, what did the client say to you when you say I need my son's tuition paid? A. He would either say, yes, I agree, or, no, I don't agree. Q. Okay. So. he says, yes, I will agree. How does that determine, how do you determine what specific acts you're going to engage in? A. Whatever he wants. Does he want sexual intercourse in 'O7. Does he want oral sex in 2007, or does he just want simple company? Q So, it didn't, it didn't matter. It wasn't like certain things cost more so to speak? A. No, I, no, I just went with the flow. Q. Okay. What -- and, and you had no concerns about that? A. Of course. I am always in fear for what I do. Q. I mean, did you use like a condom? A. Yes. Q. MI right: What was the, what event can you recall that was the most expensive event you performed, or the one for which you got paid the (561) 832-7500 19 (Pages 405 to 408) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108826 Page 409 1 most money? What did you do for the maximum amount 2 of money that you ever got paid for doing this? 3 A. Is that relevant? 4 Q. Yeah. 5 A. Okay. 6 MR. EDWARDS: Object to the fonn. 7 THE WITNESS: Okay. On advice of counsel 8 I am invoking my Fifth Amendment rights under 9 the United States Constitution. 10 BY MR. LUTTIER: 11 Q. Well, let me ask you this way: You said 12 that you could be anything from naked company to 13 sexual intercourse or oral sex, right? 14 MR. EDWARDS: I'm sorry. What was the 15 question? 16 MR. LUTTIER: it could be anything 17 from naked — 18 MR. EDWARDS: No. What was the question 19 on the table. 20 MR. LUTTIER: The effect of it was the one 21 that you got paid the most for, what did you do 22 is what I asked. 23 THE WITNESS: Yeah. 24 BY MR. LIUTTEER: 25 Q. So what did you do — Page 411 1 A. Yes. 2 Q. Okay. How, how was that arranged. 3 A. I, I really didn't do a lot of those. If 4 anything two. How was that arranged? 5 Q. Yeah. 6 A. A guy would get a girl. I would go to his 7 house and there would be a girl there. 8 Q. And what would you typical, typically get 9 paid for this? 10 A. I don't — Whatever he wants to give me. I'm 11 not sure. 12 Q. And what acts would you-all, the throe of 13 you engage in? 14 A. We could either sit there and sit in our 15 panties and talk with each other or I would fondle the 16 girl or we would just give oral. It depends. I've 17 already told you. 18 Q. What do you mean we would just give oral? 19 A. The girl that be had called. 20 Q. Well, you, you and the other girl would 21 give oral to each other? 22 A. No. Oral sex for him. 23 Q. Did you ever perform oral sex on another 24 woman ever? 25 A. Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 410 MR. EDWARDS: You can answer. THE WETNESS: Is that convenient, I mean MR. EDWARDS: Answer it. THE WITNESS: From, the first thing that comes to my mind in 30 minutes I got paid close to two grand. BY MR. LUTTIER: Q. For doing what? A. Sexual intercourse. Q. Just straight sexual intercourse? A. Correct. Q. Did you have anal intercourse with anybody? A. No way. Q. Sex with other females? A. Have I ever? Q. Yeah. A. Yeah. Q. Okay. Did you ever do it when you were employed as an escort service? A. Have I ever done it in what year? Q. As part of this escort — well, let's talk about we're talking about the time when you were self-employed. Page .41 ._ 1 Q. Okay. Do you recall when the first time 2 you did that was? 3 A. No. 4 Q. Do you remember how old you were? 5 A. No. 6 Q. Was it prior to your 15th birthday? 7 A. Was it before my 151h birthday? 8 Q. Yell 9 A. I don't recall. 10 Q. Do you remember who it was with? 11 A. No. 12 Q. Have you performed oral sox on women on 13 mom than one occasion? 14 A. Yes. 15 Q. Do you remember the names of any of the 16 women that you performed oral sex gat. 17 A. Is this like business or like — 18 Q. And do yo l when the first time you 19 had oral sex with was? 20 A. No. 21 Q. Do you have any fear at all about fl ? 22 A. As in -- 23 Q. Anything. Does she scare you? Are you 24 afraid of her at all? 25 A. No. (561) 832-7500 20 (Pages 409 to 412) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108827 Page 413 1 Q. And you have knownM. pretty much all 2 your life? 3 A. Since 1 was 13. 4 Q. And did you have oral sex with her before 5 you ever met Jeff Epstein? 6 A. No. 7 Q. And how did it come about that you and she 8 decided to have oral sex? 9 MR. EDWARDS: Form. You can answer if you 10 know. 11 THE WITNESS: When do I recall the last? 12 BY MR. LIJ1T1ER: . 13 Q. How did it come about that you and she 14 decided at some point to have oral sex? 15 A. I don't know. We were probably — I really 16 can't recall that. I don't know. I don't remember. 17 Q. Now, you said that this is the first time 18 that you had oral sex with a female, correct, is the 19 time you had it with.. or was that did I — 20 A. I did not say that was my first time. 21 Q. Was this the first time that you had sex, 22 oral sex with a female? 23 A. No. 24 Q. Okay. Let's go back to the first time you 25 had sex. 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 415 Q. Well, I am taking on the first occasion. Was it just two — A. I don't remember the first occasion. I don't remember the first girl. Q. Do you remember about how many -- did it happen with any degree of frequency? MR. EDWARDS: Font). THE WITNESS: No. BY MR. LUMbR.: Q. This was consensual, correct? A. Yes. Q. All your oral sex with other people was oonsanual? A. Yes. Q. By the way, have you ever been raped? A. By Jeffrey Epstein. Q. And how were you raped by Jeffrey Epstein? A. Well, he took advantage of me since 1 was 13, 14, 15, and then 17 years old, he took advantage of me. Q. Do you know what the definition of rape is? A. What's the definition of rape? Q. I am just asking, do you know what the definition of rape is? A. Well, to me the definition of rape is taking Page 414 1 A. I told you I don't remember. 2 Q. Well, let me ask you a question here. 3 A. Okay. 4 Q. I asked you if it was before you were 15. 5 You said you didn't recall. Does that mean it may 6 have been before you were 15 -- 7 MR. EDWARDS: Form. 8 BY MR. LUITIER: 9 Q. — or you just don't know? 10 A. !just don't know. 11 Q. And you — was that a significant event in 12 your life — 13 A. No. 14 Q. — the first time you had oral sex with a 15 female? 16 A. No. 17 Q. It was no big deal? 18 MR. EDWARDS: Form. 19 ME WITNESS: No. 20 BY MR. LLTITMR: 21 Q. Do you remember anything about the event? 22 A. Pussy in my face. 23 Q. Was it just the two of you or more people 24 involved? 25 A. Sometimes, sometimes not. I don't know. Page 416 1 advantage of a person who doesn't want to be taken 2 advantage of. 3 Q. So, when you say you were raped by Jeffrey 4 Epstein, that's the definition you're using? 5 A. Correct. 6 Q. Jeffrey Epstein never had sexual 7 intercourse with you, right? 8 A. Nope. 9 Q. Never penetrated an orifice of your body? 10 A. Yes, he did. 11 Q. What orifice did he penetrate? 12 A. He, he penetrated my vagina. 13 Q. With what? 14 A. With his forgers, with a vibrator. 15 Q. With, with a vibrator. Tell — describe 16 thls vibrator that you say he penetrated your 17 orifice? 18 A. It was about a foot long and the head of it 19 was about the size of a small plate, pretty big, pretty 20 powerful right onto my vagina. 21 Q. Did you say onto or did you say he 22 penetrated your vagina? 23 A. He penetrated my vagina with his fingers. He 24 also penetrated my vagina with the vibrator. 25 Q. So, the vibrator you just described you (.561) 832-7500 . 21 (Pages 413 to 416) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108828 Page 417 1 said had this big head, that was inserted into your 2 vagina? 3 A. It was not inserted. It was -- 4 Q. Placed on the outside of your vagina? 5 A. Yes. 6 Q. Did you achieve an organism when this 7 happened? 8 A. Nope. 9 Q. And then you say he insetted his forgers 10 into your vagina? 11 A. Yes. 12 Q. And on how many occasions did that happen? 13 A. I've been to Jeffrey Epstein's house so many 14 times, I caret recall how many times he's inserted his 15 fingers into my vagina. 16 Q. Was — had you had intercourse, or excuse 17 me, had you had any type of sexual contact with a 18 male before your first sexual encounter with a 19 female? 20 A. Excuse me? 21 Q. Had you had any sexual encounter with a 22 male before your first sexual encounter with a 23 female? 24 A. !have had an encounter sexually with a man or 25 with a boy before I had any type of sexual acts with a Page 419 1 A. No. 2 Q. Are you sure? 3 A. Was that before Jeffrey Epstein, no. 4 Q. Are you sure of that? 5 A. Positive. o Okay. And at the time who wale 7 a (phonetic) to you? 8 A. Boyfriend. 9 Q. Had you been dating him for some period of 10 time or just somebody you happened upon? 11 A. Yeah, we were dating. 12 Q. And what specific acts did you and he 13 engage in, just sexual intercourse? 14 A. 'Yes. 15 Q. Did you ever perform oral sex on him? 16 A. Yeah. 17 Q. And did he perform oral sex on you? 18 A. I — probably. 19 Q. And do you have any idea how long' 20 the time you had your first sex wit 21 alli et:nd when you had your first encounter with a 22 female? 23 A. No. 24 Q. But by the time you were 15 you had had 25 sex with males and sex with females? 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 Q. And was that before Jeffrey in? Page 418 woman. Q. Okay. And do you remember the first time you had sex with a male? A. Excuse me. Yes. Q. When was that? A. I was probably just turning, just -- I, I was 14. Q. Just turning 14? A. I was 14. Q. Do you know — you started by saying "just turning.° If I remember correctly — I can look up your birthday here. Lees see. Your birthday is July 26, 1988? A. Correct. Q.. So, with whom did you have this first sexual encounter with j male? A. His name wasIM. Q. And what sexual encounter did you have? A. Sexual intercourse. Q. Just straight sexual intercourse? A. I lost my virginity. Q. Ci_yca. This is, and is this guys last name =? A. Yes. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 420 1 A. Yeah. Yes. 2 Q. Did your sex with females consist of 3 anything other than oral sex on each other? 4 A. Just oral. 5 Q. Did you guys use any kind of dildos, 6 vibrators, toys, or anything like that? 7 A. No. 8 Q. You never did that? A. No. Q. When was last time you had sex with a female? A. I don't remember. Q. So, did you have sex with. when yet were in New York? A. No. When was the last time you had sex with A. Q. Year? A. Q. A. Q. A. I don't remember. That was years ago. Have you had sex with a female in the last This year, no. Well, what I mean, '10. How about '09? Sure. • Do you know how many times? No. 22 (Pages 417 to 420) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (.561) 832-7506 EFTA01108829 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 1 2 3 4 5 6 7 8 9 that? 10 A. Yep. 11 Q. Let me guess: You accused him of getting 12 it from someplace else and giving it to you? 13 A. Uh-huh, yes. 14 Q. And what did he say, didn't happen? 15 A. He said lees get it fixed. 16 Q. So you got treated? 17 A. 18 Q. when you first were 19 pregnant with your son, have you ever had any other 20 sexual! 21 22 23 24 25 Q. Have you had herpes? Page 421 Q. And were they all females that you knew? A. I've only done this a couple of times. Yes, it was females I knew. Q. Were these -- did you ever have any female escort service clients? A. Yeah, that's what I am talking about. Q. In other words instead of a man calling you, a female would call you? A. No. Q. That's what I meant. A. No. Q. So, the females were only in conjunction with a male calling you? A. Correct. Q. All right. How many, roughly, I !mow you don't know exactly, in 2007, how many clients did you have in your escort business? A. I have no idea. Q. Hundreds? A. Maybe. 1 A. No. 2 3 5 4 6 A. 7 Q. Did you get treatment for it? 8 A. Yes. 9 Q. What was the treatment? 10 A. What was the treatment? 11 Q. Yeah. 12 A. A Lap. 13 Q. And who performed it? 14 A. 15 Q. 16 A. 17 Q. And where is he? 18 A. Benoist Farms and Okeechobee, Palm Beach, Palm 19 Beach Doctors. 20 Q. Olaty. Hes a gyno? 21 A. Yes. 22 Q. Has he been your gyno for a long time? 23 A. Yeah. 24 Q. Is he still your gyno? 25 A. Yeah. Page 422 And do you remember the first time you got Q it? A. A. Q. A. Q. Yes. When was that? When I got p with my son. And did Mr. give it to you? Yes. Did you have an argument with him about • (561) 832-7500 PROSE COURT 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 423 Q. A. Wita m iti mmumet A. A. A. A. A. Page 424 When did you get, first get.? Oh, '07. Do you know who you got it from? Yes. Another boyfriend? Yeah. Just had one bout Ma? Excuse me -- Just had one occasion ofM? Yes. Any other sexually transmitted diseases? No. Q. Never have -- have you ever been tested for herpes? A. Yes. Q. Tested for Aids? A. Yes. Q. Anybody ever accuse you of transmitting a sexually transmitted disease to them? A. No. Q. What was your reaction first of all, how long did you date Mr. INN, the father of your child? 23 (Pages 421 to 424) REPORTING AGENCY, INC. (561) 832-7506 EFTA01108830 Page 425 1 A. A year. 2 Q. Was your pregnancy planned with him? 3 A. No. 4 Q. Can we assume that you-all were having 5 sexual intercourse without the benefit of any kind 6 of contraception? 7 A. We had sexual intercourse without condoms. 8 Q. Ended up getting pregnant the first time 9 or was it — 10 MR. EDWARDS: Object to the form. 11 THE WITNESS: I don't know when I had —1 12 know that when I went to the doctor that I was 13 already two months pregnant 14 BY MR. LUTTIER: 15 Q. Is this when you were like 15? 16 MR. EDWARDS: Form. 17 THE WITNESS: I was 16. 18 BY MR. LUTHER: 19 Q. Sixteen. Okay. And when you first went 20 to the doctor and you were two months re artt, is 21 that when you found out you ? 22 A. Yeah. 23 Q. Is that wit °t avern to the doctor was 24 because you had and then while you were 25 there — 1 2 3 4 5 18 19 20 21 22 23 24 25 Page 427 THE WITNESS: But it was a miracle. BY MR. LUTTIER: Q. Well, I mean, you're happy to have your child, right? A. So A. It was a one-night stand with a cop and the condom had broke. I was contemplating whether to keep the baby or not, but I didn't want that child to not have a father. Q. By then you'd had your son? A. Yeah. Q. And you recognized at that point at least the, the joys of having a boy, correct? J. 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 426 A. No, I, I figured out that I was late on my period for two months. So, I figured that 1 was pregnant, took a pregnancy test and went to the doctor to get checked out, and they told me I had.... Q. And what was reaction when the dos said you had A. Hurry up. Get me cured. I need to have this baby healthy. Q. Was it upsetting to you? A. Yeah, of course. Q. I, I mean, did you think among other things that your, that, that your then boyfriend, the father of your child must have been out having sex with somebody other than you? A. Before he was, yeah. But when we were dating, no. Q. And did you all — what kind of argument did you and he have about that? A. I just told him we need to get I wasn't worried about hint. I was worried about my child. We needed to get it cured and we did. Q. Now, being pregnant at 16, I — is it safe to say that's not what you planned in life? A. It's not what I planned. MR. EDWARDS: Object to form. (561) 832-7500 1 2 3 4 5 6 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 428 A. Yes. I would have loved to have that baby. Q. So, what sort of thought process, what sort of emotional turmoil, if any, did you go through in making the decision that you were going to abort the child in February of '09? A. It was very hardthfam il S would want m child And I didn't feel at that time since I'm working in the business how could I have worked and made money to support my son plus another baby without a father. Q. What do you mean working in the business? You mean as an escort? A. Yes. Q. Did you discuss it with the father? A. It was a one-night, it was a one-night stand with a cop. Q. I mean did you tell him that you were pregnant by him? A. No. Q. So this fellow doesn't even know that you were carrying his child? A. No. 24 (Pages 425 to 428) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108831 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 429 A. Q. So you must have had an idea that you were pregnant for a couple of months? A. Of course. Q. Any thought process that you had about not telling the father of the child? A. It was a one-night stand with a cop. I don't even know him. Q. Well, you must have known him long enough to have sex with him, right? MR. EDWARDS: Object to the form. THE WITNESS: I was out that night drunk and so was he. He picked me up, and we had sex, condom broke. I found out I was pregnant three weeks later and that's that. BY MR. LUTTIER: When were you-all? Where did you hook up with each other? A. Dr. Feelgoods. Q. Down on Clematis? A. Yes. Q. Had you ever met the guy before? A. No. Q. Did you know, do you know his name? A. No. 1 3 I 7 8 9 10 11 12 13 14 15 16 17 18 24 Page 431 have it over at A. Yes. Q. Who took you them? A. My friend T.J. And who is T.J.? A. A friend of mine. Q. Male or female? A. Male. Q. Okay. Would you describe that as a traumatic event for you. making that decision and in light of having had , your son? A. Of course. Of course. Q. That's all right Any time during the 25 deposition you realize that yottve told me something Page 430 1 Q. How is it that you ran into a guy that you : 2 never met before and ended up having sex with him? 3 A. He was a cop. I was drunk. 4 4 Where did you have sex? 5 A. In the car. 6 Q. In the parking, in the parking lot on 7 Clematis? 8 A. Yes. 9 Q. Back seat? 10 A. Yeah. Front seat, back seat, trunk. Just 11. kidding 12 Q.. And did you have any, did you have airy 13 second thoughts or any, any regrets about not 14 telling the fellow? 15 A. [can't find him. If I would have found him, 16 I would have told him. 17 Q. Do you know what police department he was 18 with? 19 A. No. 20 ini 7 Did you cry about it, 21 22 A. Yes. 23 . Did ou to any kind of counseling about 24 25 A. No. (561) 832-7500 Page 432 1 wrong, just let me know. 2 A. Okay. Sony. 3 Q. There's no tricks? 4 A. I 7 8 9 10 I 13 MR. EDWARDS: Fenn. 14 THE WITNESS: No. 15 BY MR. LUTTIER: 16 Q. Was that a, was it an upsetting event for 17 you? 18 A. No. 19 Q. You were happy to have that happen? 20 A. Yeah. 21 MR. LUTTIER: Okay. I want to take a 22 break and go to the bathroom. 23 THE VIDEOGRAPIJER: Going off the record at 24 11:42 a.m. 25 (A brief recess was held.) Q. Was that a planned pregnancy? A. Nope, I just, I just recently started dating him. 25 (Pages 429 to 4 32) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108832 1 2 3 4 15 18 19 20 21 22 23 24 25 Page 433 THE VIDEOGRAPHER: We are back on the record at Linmit t 11:54 By Q. The same gynecologist take care of you for that? A. No, Itthawntwala A. No. Q. Do you know among the people that you know that also went to Jeffrey Epstein, do you know of other girls that have had abortions? A. No. Q. Do you know if.. has had an abortion? A. No. Q How about Page 435 1 restricted every time because he has a wife. 2 Q. Okay. And you've had any kind of sexual 3 encounter at all with Bobby, not even the least 4 little bit? 5 A. No. • 6 MR. EDWARDS: Form. 7 BY MR. LUTHER: 8 Q. So, you wart on this New York trip. Did 9 you get reimbursed for your expenses? 10 A. No. 11 Q. Who bought your plane ticket? 12 A. I told you. 13 Q. But did, did you put the money but first 14 and get reimbursed, or did he buy it for you at the 15 front end? 16 A. Lipoid for it first, and then I got 17 reimbursed when I got to New York. 18 Q. Okay. And how, he* did he reimburse you? 19 A. When he got to the hotel, he gave me the 20 money. 21 Q. Cash? 22 A. Yes. 23 Q. Okay. So, how much did you get for that, 24 400 bucks? 25 A. It was like 450. Page 434 1 MR. EDWARDS: I'm sorry, who did you, 2 what - 3 MR. LUTHER: I means l m sorry. 4 MR. EDWARDS: 5 1HE WITNESS: You mess up a lot of names. 6 MR. LUTHER: There'd a bunch of them. 7 THE WITNESS: No. 8 BY MR. LUTHER.: 9 Q. You don't know? 10 A. I have no clue if they did, no. 11 Q. Now, back with Bobby on this trip to New 12 York, do, do you, now do you recall the name of 13 either of the gentlemen that bought you dinner? 14 A. No. 15 . Q. Do you remember Bobby's last name? 16 A. I don't ever think Bobby ever told me his last 17 name. 18 Q. And does Bobby live in New York or does he 19 live down here? 20 A. I think he lives in both places. 21 Q. And, and you have a cellphone, don't you? 22 A. Yes. 23 Q. Don't you have Bobby's number in 24 cellphone? . 5 A. No. I give him my number and he calls me Page 436 1 Q. Okay. Did you get reimbursed for any of 2 your other expenses, any money that you spent in New 3 York, any dinners or anything at all? 4 A. No. 5 Q. So, so, he gave you $400 to go to fly to 6 New York, period? 7 A. Yes. . 8 Q. Did you get paid a fee for the time you 9 spent with him? Didn't you say you spent an 10 afternoon sitting there? 11 A. Yeah, yeah. He, when he came over and we hung 12 out, be gave me like $200. 13 Q. Well, that's, that was a bargain. I mean, 14 that was below your regular hourly rate? 15 A. He just gave it to me. He's litre, here, go 16 shopping, do whatever. 17 Q. Did he give — okay. So, so, all you got 18 was 400 reimbursement and 200 when he came over and 19 hung out? 20. A. Yeah. 21 Q. That's all the money you got from him for 22 this New York trip? 23. A. Yet 24 Q. Did he buy you any gills? 25 A. No. 26 (Pages 433 to 436) (561) 832-7500 PROSE COURT REPORTING AGENCY,'INC. (561) 832-7506 EFTA01108833 Page 437 Q. Did he allow you to go out and buy 2 anything on his charge accounts, charge cards, 3 anything like that? 1 A. I wish. 5 Q. Did you go, did you do any shopping while 6 you were -- I mean, most women go to New York, they 7 shop. 8 A. I did. I went to DSW and I just bought two 9 shirts. 10 Q. How about these other fellows that bought 11 you dinner, did you charge them anything for your 12 company? 13 A. No. 14 Q. Dia. get paid any money? 15 A. With —yeah, Bobby gave her, I am pretty 16 sure — I don't blow how much he gave her but I know he 17 gave her somethin 18 Q. And is. iMr. a customer or Bobby a 19 customer °fir as well? 20 A. No. 21 Q. noose. do the same thing you do? 22 A. No. 23 Q. How about .., is she in the escort 24 similar business to you? 25 A. No, no, no. Page 439 1 was like our master. 2 Q. All you know is what she told you she did, 3 right? 4 A. Yes. And then Jeffrey also told me that she 5 came back many times after that 6 Q. Now, have you ever prior to today told 7 anybody this rendition of the story that, that you 8 were afraid of Jeffrey? 9 A. I have told ruyattomey I am afraid of 10 Jeffrey. ve told... I am afraid of Jeffrey. I 11 have toIM.4 I am afraid of Jeffrey. Pretty much 12 everyone knows I am afraid of Jeffrey and 13 Q. Would it be a true statement that you 14 didn't tell anybody you were afraid of Jeffrey until 15 after you filed the lawsuit? 16 A. I didn't say a word because I was afraid that 17 my son was going to be taken way from me. 18 Q. So my statement's correct, you never told 19 anybody you were afraid of Jeffrey Epstein until you 20 filed this lawsuit? 21 A. I didn't say anything. .I didn't say a word. 22 Q. And in fact when you were questioned by 23 the FBI - 24 A. I told my son's father I was afraid of Jeffrey 25 Epstein. Page 438 1 Q. How, how much time do you spend hanging 2 without.. in a physical -- 3 A. I told you. 4 Q. I mean physically with her as opposed to 5 maybe talking on the phone? 6 A. When we do get to see each other, the last 7 time I saw her it was like 30 minutes. 8 Q. If, if she told you she didn't want to go 9 to Epstein's, you took her I think you said four 10 times. But you said she kept going after that, 11 right? 12 A. I guess so. 13 Q. Did she ever tell you why she kept going? 14 A. I 'mow that she was scared. Jeffrey told her, 15 you know, don't, don't tell anybody. And he was like 16 our master. Whatever he told us to do, we did. We were 17 scared to tell anybody else, and he would be constantly 18 calling us on the phone, give me another girl, give me 19 another girl, give me another girL 20 So, my mentality at that age, I was 21 afraid and lc I thought this guy had so much power. 22 He has this big mansion. He has this big boat. He 23 hes this big house. You know, I,1 was scared so I 24 did anything and. and all those girls did 25 anything that whatever Jeffrey told us to do. He 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 440 Q. When you were questioned by the FBI, you specifically told them that Jeffrey Epstein was a nice guy and you didn't have any fear of him? A. Yeah, and then the next day I told my son's father I'm definitely afraid of Jeffrey Epstein and I'm scared my son's going to taken away from me. Q. Well, speaking of having your son taken away from you, you said in your last deposition you were familiar with the agency called DCF? A. Yes. MR. EDWARDS: Form. BY MR. LUTTIER: Q. That's Department of Children and Families? A. Yes. Q. And what was your involvement with them? MR. EDWARDS: Object to the form. THE WITNESS: I had a — there was a domestic violence. My ex-boyfriend had, went crazy and wherrmy child was sleeping, he battered me. BY MR. LUTITER: A. boyfriend was this? Q. And when did this happen? (561) 832-7500 27 (Pages 437 to 440) PROSE COURT REPORTING AGENCY INC. (561) 832-7506 EFTA01108834 Page 441 1 A. I want to say '06. 2 Q. And specifically what did he do? 3 A. [guess he was like high on coke and he came 4 in and he threw me on the ground a couple of times and 5 defended myself by hitting him in the nose which made 6 him bleed. And there was blood all over the house. 7 So, when DCF came ova, they 8 practically told me that if this happens again then, 9 you know, I am going to have to go to parenting 10 classes and I am going have to be vet), careful of 11 the kind of people I bring around my son. 12 Q. Where did this event occur? 13 A. In Holiday Plaza. 14 Q. Holiday Plaza is what? 15 A. The trailer that I had my son in. 16 Q. Okay. So this was a trailer that you 17 owned or actually your dad owned it, right? 18 A. Yeah. 19 Q. So, in your trailer, let's, let's be a 20 little more specific. Mr. Riedel, when you say he 21 threw you on the ground, describe what he actually 22 did. 23 A. He threw me on the ground. 24 Q. Did he hurt you? 25 A. It didn't really hurt to fall on the ground 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 443 Q. What is it that you want to do. A. I would love to be a normal person who hangs out with people my age and do what I went to college for. Q. What do you mean do what you went to college for? A. I would like to be an esthetician, a massage therapist. Q. Have you finished your massage therapy school? A. Yes. Q. When did you get, when did you finish that? A. in late '09. Q. Did you pass the test? A. Not the nationals. Q. Did you get, did you have to take a local test or a state test? A. Yes. Q. Did you pass that? A. I didn't take it yet. Q. Okay. So you finished your course work but you haven't taken the test, right? A. Yes. Q. So why didn't you take test? Page 442 1 but he pushed me around. 2 Q. Were you afraid? 3 A. A little bit. 4 Q. Scared? 5 A. I was scared that my son was going to wake up. 6 Q. Did he threaten you? 7 A. No, he just threw on the ground a couple of 8 times, and I didn't like it so I ptur.hed him in the 9 nose, and then he decided to spit blood all over the 10 trailer and that was it. And then DCF, I called the 11 cops and that's when DCF got involved because if there 12 is a domestic violence, then if there is a child 13 involved, then DCF comes. 14 Q. Okay. You said back when you were talking 15 about this fellow Bob — by the way, this business 16 that you have, that you're doing, these various 17 things, whether ifs selling Mary Kay, selling 18 shoes, selling lingerie, selling clothes or going 19 out with these men that pay you money, are all of 20 those things that you're currently doing for money 21 things that you have selected to do? 22 A. Yes. 23 Q. And out of everything that you could do in 24 the world, are these the things that you want to do? 25 A. No. Page 444 1 A. Why didn't I? 2 Q. Yeah. 3 A. Because I am so involved in this money right 4 now. I am involved in making money so my son can go to 5 Christian school and try to better myself with this kind 6 of money. This is all I know. Since I was I3, Jeffrey 7 trained me to make money like this and this is all I 8 know. So, it's kinds of scary going into something that 9 I don't know. 10 Q. Well, Jeff never told you how to make 11 money, did he? 12 A. Yes, he did tell me how to make money. 13 Q. What did he tell you to do? 14 A. To get naked so he can masturbate and 15 ejaculate all over himself and he will pay me money. 16 Q. But he didn't tell you to go out and do 17 that fora living, did he? 18 A. Oh, when I started working at a jack shack 19 when I was 15 years old, he encouraged me to do that. 20 Q. What jack shack was that? 21 A. That was Jamie's photo studio. 22 Q. What's a jack shack so the jury will 23 appreciate that? 24 MR. EDWARDS: Form. 25 TIE WITNESS: That is a place where (561) 832-7500 28 (Pages 441 to 444) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108835 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 495 1 gentlemen go to get happy endings. 2 BY MR. LUITIER: 3 Q. What do you mean by happy endings, 4 masturbating? 5 A. Yes. Q. Do you massage them first or just give just — A. No. Q. So, these are men that come in and you, you masturbate them until they ejaculate, is that the idea? MR. EDWARDS: Object to form. THE WITNESS: Yes. BY MR. LUT1TER: Q. And yoU were doing that at 15, were you? A. Yep. Q. And that was at -- what was the name of it Jamie's Studio? A. Yes. Q. And where was that located? A. Congress and Okeechobee. Q. And did you apply for that job? A. Yes. Q. Who did you apply with? A. Mariah. Page 447 1 Q. And how did he know this person? 2 A. 'Through a friend. 3 Q. And did you, did suggest that you 4 go see her and do this? 5 A. No. 6 Q. Well, why did introduce you to her? 7 A. We were all playing cards one day and she told 8 me that her, her stage name is Vivian. I just 9 remembered. Vivian told me that I can make a lot of 10 money and I was, I was afraid. 11 So when I went back to Jeffrey, I 12 talked to him about it. And I said, well, there is 13 this place that be working at and it's pretty 14 much the same thing that were doing here. And he's 15 tile go for it; you should have a great time, you 16 know. And he encouraged me to do it. 17 Q. And when you were interviewed by the FBI. 18 did you tell them that? 19 A. No. 20 Q. Have you ever told anybody that story 21 until today? 22 MR. EDWARDS: Object to the fonn, 23 attorney-client privilege. 24 MIL LUTHER: Other than your lawyer. 25 Mt EDWARDS: Other than me if you have I Page 446 1 Q. And how did you know Mariah? 2 A. Through a friend. 3 Q. What friend? 4 A. It was a stage name. It wasn't even her real 5 name. I don't even remember. 6 Q. What was the stage name, Mariah or the 7 friend? 8 A The friend 9 Q. Okay. When you say a stage name, stage 10 where? What stage? 11 A. It was a fake name. 12 Q. Okay. But stage name means she was 13 working someplace. Was she working at — 14 A. She was working at Jamie's photo studio. 15 Q. Okay. But this is somebody you knew that 16 was already working there? 17 A. Yes. 18 Q. And, and was it somebody you went to 19 school with? 20 A. No. 21 Q. How did you know her? How did you meet 22 her? 23 A. Throughm 's ather. 24 Q. That's= 25 A. Page 448 1 told anybody else that you can answer. 2 THE WITNESS: No, I have not told anybody 3 else that. 4 BY MR. • 5 Q. Youtrrold, that you were going to do 6 it, didn't you? 7 A. Yeah, well, heard the conversation. 8 Q. Right 9 A. And knew I was doing it. 10 Q. And heard the conversation where 11 Vivian said you could come do this fora lot of 12 money? 13 A. Y. 14 Q. And then you went and applied for the job? 15 A. Yes. 16 Q. You didn't tell that Jeff Epstein 17 made you do it, did you? 18 A. No, because I was afraid of Jeffrey Epstein. 19 Jeffrey Epstein told me not to say anything to anyone, 20 just bring him girls. 21 Q. So, but, but you will admit nobody forced 22 you to go interview and get that job, did they? 23 A. Correct. 24 Q. You decided to do it because you wanted to 25 make more money? (561) 832-7500 29 (Pages 445 to 448) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108836 Page 449 1 A. Correct 2 • Q. You knew — 3 A. Because I couldn't find anymore girls for 4 Jeffrey. 5 Q. Well, you knew it was wrong. You were 15 6 years old, right? 7 A. Correct, but Jeffrey taught me that lifestyle 8 is the lifestyle to go. 9 Q. That was .- 10 A. III want a mansion, if I want a pool, ill 11 want food on my table, if I want nice clothes, if I want 12 to live a luxury life, why not make money. I could 13 hen* find anymore girls for Jeffrey at that time. So 14 Jeffrey said, go ahead, go. And he even said bring me 15 girls from that place. 16 Q. Well, what you figured out was to have 17 fancy things in life, it took money to get them, 18 right? 19 A. Yes. 20 Q. Jeffrey didn't teach you that? You 21 figured that out? 22 A. Yes, he did. 23 Q. How did he teach you that? 24 A. Because he would tell me when I am sitting 25 there and massaging him: 'would say what do you do for Page 451 1 on how to make any kind of money. 2 Q. Well, why didn't you go off and be a brain 3 surgeon because if Mr. Epstein told you that he was 4 a brain surgeon, that's how he got these things? 5 A. Because I am sitting there 13 years old naked 6 in front of an old man while he ejaculates and gives me 7 $200 and then gives me $200 an hour later for bringing 8 another girl and then he gives me 200 the next day for 9 . bringing another girl and then I accumulate a thousand 10 dollars in a week. And then I accumulate another 11 thousand dollars the next week, why would I want to be a 12 brain surgeon right then and there? 13 Q. That was your choice, right? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: When I am 13 years old, can 16 I beat:fah) surgeon? 17 BY MR. LUIT1ER: 18 Q. Was it your choice at that point that you 19 wanted to continue to do what you were doing? 20 MR. EDWARDS: Object, form. 21 THE WITNESS: He was my master. Whatever 22 he told me to do, he — I did. 23 BY MR. LUITIER: 24 Q. How, how did he — once you walked ota of 25 his house, you could have done anything you wanted, 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 450 a living. He would say I was a brain surgeon. I would say really. Okay, so that's how, that's how you got all this stuff when I was massaging him. And he says, yeah, you know, successful men, that's why you have successful things. Q. Okay. So, what he told you was to be wealthy and happy you need to be a brain surgeon. That's what he told you, right? A. He didn't say you had to be a brain surgeon. He just said you need to make money. Q. Well, no, I thought what you just said was when you sat and talked to him he said I ern a brain surgeon and that's how you got these things. A. I asked him, what do you do for a living. He said I am a brain surgeon. Q. So, you concluded that if you were a brain surgeon, you can acquire these things, right? A. No, I concluded that if you make lots of money, then you an have nice things. Q. Okay. But I mean you would know that, I mmm— A. No. Q. It's just common sense. A. No, it's not comment sense because I was a little girl living in a trailer park, and I had no idea 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 452 couldn't you. A. He scared me. lie said don't tell anybody what we're doing. Q. Other than you claiming that he said that to you, how did he restrict you from doing anything you wanted to do? A. He said I will be caning you; please, make sure you have a girl for me. Q. Did you — A. If you don't have a girl for rile, then I am going to be mad. Q. Well, did you ever just say, no, I don't want to do it anymore? A. I had told him, Jeffrey, I don't a have girl and he, he would be mad. He said don't ever do that again. Q. My question — A. I would be in his house, and if I brought him, if I didn't bring him a girl, and if I just came alone, he would say don't ever do that to me again. Q. My question is did you ever tell him, no, I don't want to do this anymore? A. No, I didn't say that. I was scared to say that to him. Q. Well, you were so afraid that while you 30 (Pages 449 to 452) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. .'(561) 832-7506 EFTA01108837 Page 453 1 were goiroMra n, you were living with this 2 boyfriend MIE weren't you? 3 A. I was living with my father. 4 Q. Well, you were living with 5 fora good bit of the time when you first went to 6 Mr. Epstein's? 7 A. Correct. 8 Q. And he knew exactly what you were doing, 9 didn't he? 10 A.. Correct. 11 Q. Because you told him? 12 A. Correct. 13 Q. And told you as long as 14 you're bringing home money, go ahead and do it, 15 didn't he? 16 A. No. 17 Q. Did he say anything like that? 18 A. No. 19 Q. What did he say about the fact that being 20 your girl — you being his girlfriend, that you were 21. going -- 22 A. He didn't say anything. He said -- he didn't 23 care. 24 Q. He didn't care but you ran it by him? 25 A. He was an alcoholic. He didn't care. He Page 455 1 A. Great. She said you can start tomorrow. 2 Q. And did you mention you were 15? 3 A. No. 4 Q. Did you show her a fake ID? 5 A. No. 6 Q. You did have a fake ID at that point? 7 A. Nope. 8 Q. Asa matter of fact you told the FBI you 9 had a fake ID, didn't you? 10 A. Yeah, when I lied in my first deposition. 11 Q. And of course you would have known lying 12 to the FBI was a bad thing to do? 13 A. I had no fake ID. I have never had a fake ID 14 and when f was 15, I told her I was 19. She said you 15 can - 16 Q. So, tell me about your first *soda. 17 Maly, Made (sic) says to you, yeah, you can go to 18 work here? 19 A. Yes. 20 Q. Does she give you any instruction about 21 what you're to wear, what you're to do, fill out 22 paperwork, or anything like that? 23 A. No, l told her I was instructed by a guy which 24 was Jeffrey Epstein and I know what I am doing. 25 Q. Okay. So what did you do? Did you report 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 454 lived. He paid the bills. We lived in a trailer. Q. And you ran it by him. You said this is what I am doing and this is what I am getting paid and he said he didn't care? A. Yes. Q. And then along came this opportunity after this card game for you to go to work in what you call a jack shack, right? A. Because I could hardly find any more girls for Jeffrey, so, yeah, and he encouraged me to bring girls from the jack shack to him. Q. And encouraged you to go take that job, too -- A. Not at all. had nothing to do. He was not my master. I was not intimidated by Q. You wanted to get that extra money, didn't you? A. Yes, I dld. Q. Okay. So, now you're 15 and you go to see Vivian. Or, no, you go see this Marie at this — MR. CRITTON: Mariah. BY MR. LUTHER: Q. Mariah at Jamie's studio. How did that ,25 interview go? (561) 832-7500 Page 456 1. for work one day? 2 A. Excuse me? 3 Q. Did you report for work one day? 4 A. Yes, I went to work. 5 Q. Morning, night, when? 6 A. In the morning. 7 Q. Okay. And what did you do? 8 A. When a client came in, I would put a condom on 9 him and I would jerk him oft 10 Q. This is in some room that they had there? 11 A. Yes. 12 Q. And is that all you did? 13 A. Yes. 14 Q. Were you fully clothed? 15 A. No. 16 Q. What were you wearing? 17 A. I kept my panties on. 18 Q. Okay. So you were topless? 19 A. Yes. 20 Q. And so a guy would come in, somebody you 21 didn't know at all, right? 22 A. Correct. 23 Q. And you would, you would jerk him off? 24 A. Yes. 25 Q. All right. And bow many of those would 31 (Pages 453 to 456) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108838 Page 457 1 you do a day? 2 A. One, two, three, or four. 3 Q. And how much did you get paid for that? 4 A. $40. 5 MR. EDWARDS: Object to form. 6 BY MR. LUTTIER: 7 Q. And did you ever do anything other than 8 that? 9 A. I gave oral sex there. 10 Q. How much did you get for that? 3.1 A. Ninety. 12 Q. So you got more money for that than you 13 did for just Jerking the guy off? 14 A. Yes. 15 Q. And how much money would you make in a 16 day? 17 A. I don't know because ifs not — I am not 18 working on a salary. I am not working on a set price 19 here. Whatever client came in, if a client came in and 20 he wanted me to jack him off, then I would make $40 for 21 that day. 22 Q. Okay. 23 A. If a client, two clients came in, and they 24 both wanted oral sex, I would make 180. 25 Q. Okay. And they would pay you cash? Page 459 1 Q. Would people schedule appointments with 2 you? 3 A. No. 4 MR. CRITTON: We have to change the tape. 5 MR. LUTT1ER: Okay. 6 THE VIDEOGRAPHER: Going off the record at 7 12:16 p.m. This is the end of Tape 1. 8 (A discussion was held off the record.) 9 THE VIDEOGRAPHER: We're back on the 10 record at 12:18 p.m. This is the start of 11 Tape 2. 12 BY MR. LUTHER: 13 Q. Was Jamie's studio the first business of 14 that nature that you worked at? 15 A. Yes. 16 Q. Now, you had, you had masturbated males 17 before you worked at Jamie's studio, right? 18 A. Jeffrey, I have not masturbated but I've 19 worked for Jeffrey. 20 Q. But no, you — my question was you had 21 masturbated males prior to working at Jamie's 22 studio, hadn't you? 23 A. Not for money. 24 Q. That wasn't my question. You had 25 masturbated — Page 458 A. Cash. 2 Q. Put the money in your pocket? 3 A. Put the money in my pocket but I had to pay 4 Mariah. 5 Q. How much did you have to pay her? 6 A. From what I recall $30. 7 Q. Per client? 8 A. It depends on — day. So, it was, Iwotdd 9 charge them $100 for the room, and I would have to pay 10 her 60 and I would get 40 for just to jack someone off. 11 Q. Now, did you have regular clients that 12 would come? 13 A. Yeah. 14 Q. How many days a week did you work there? 15 A. Maybe four. 16 Q. And how long would a day be? 17 A. Seven hours. 18 Q. You'd literally sit there for seven hours? 19 A. Literally sit there for seven hours. 20 Q. And how long, how many clients would you 21 see in seven hours? 22 A_ I told you this once before, one, maybe two, 23 maybe three, maybe four. 24 Q. Ina seven-hour period? 25 A. Yes. Page 460 1 A. Yes. 2 Q. All right. Do you remember when you first 3 masturbated your first male? 4 A- No. 5 Q. Do you remember who it was? 6 A. I told you, 7 Q. Well, hadn't you, in fact, masturbated a 8 male before you ever went to Jeffrey Epstein? 9 A. Have I masturbated a male before Jeffrey 10 Epstein? I was 13. Yeah. 11 Q. And do you remember how far before? Was 12 it like a year or so before that? 13 A. No, it was like right before Jeffrey. 14 Q. And that you had seen, by that time in 15 your life you had seen people perform masturbation 16 on males, had you not? 17 A. No. 18 g Had you seen pornography before that? 19 A. I think I like took a look at it one time and 20 it was not forme. 21 g Did you ever tell anybody ever in your 22 life that your mother showed you pornography to 23 teach you how to please men? 24 A. No. 25 Q. Did you ever make that statement or (561) 832-7500 PROSE COURT 32 (Pages 457 to 460) REPORTING AGENCY, INC. (561) 832-7506 EFTA01108839 Page 461 1 anything similar to that statement to anyone at any 2 tune in your entire life? 3 A. No. Why the heck would my mother.-- 4 Q. Did, did you ever tell anyone at any time 5 in your life that your mother was a prostitute? 6 A. No. 7 Q. So, when you went to see Jeffrey Epstein 8 for the first time and you said he masturbated in 9 your presence, that wasn't the first time you'd seen 10 that done, right? 11 A. Excuse me? 12 Q. When you went to Jeffrey Epstein for the 13 first time and you say he masturbated in your 14 presence that, that wasn't something you had not 15 seen before? 16 MR. EDWARDS: Object to form. 17 MR. LUTTIER: It was not something that 18 you had — it was not something you had not 19 seen. Let me rephrase it. You'd seen — 20 MR. EDWARDS: I'm confused. 21 BY M. LUTHER: 22 Q. You had seen a male masturbate before you 23 went to Jeffrey Epstein for the first time, hadn't 24 you? 25 A. Yes. Page 463 1 sit here right now. 2 A. I was with my, my boyfriend all 2000, all 3 2009. 4 Q. 5 A. 6 Q. 7 2009? 8 A. 9 Q. You are absolutely sure of that? 10 A. Yeah. 11 Q. Have you ever allowed anyone to take your 12 car and go to what you've described as a jack shack? 13 A. I definitely let people use my car. 14 Q. Have you ever allowed anybody to take your 15 car to a jack shack? 16 A. I let people use my car. If they decide to go 17 to a jack shack, I don't know. 18 Q. In the year — 19 A. I am a nice person. I lend, !lend my car 20 out, yes, I do. 21 Q. In the year 2010, okay, which is now a 22 little over 30 days old — 23 A. Uh-huh. 24 Q. — have you been to ajack shack? 25 A. I've been to gentlemen's clubs to sell my Doesn't change my question. I didn't work at a jack shack 2009. Have you ever been in one since January of No. Page 462 Q. Now, after Jamie's studio, did you ever 2 work at any other establishment that was a similar 3 type of establishment to that? 4 A. Yes, and we went through this the last 5 deposition. 6 Q. Okay. Well, which ones did you work in? 7 You might remember you asserted a lot of objections 8 last time. 9 A. Okay. Weil, you name them off to me and I 10 will tell you. 11 Q. So, which ones. I can give you a list of 12 them. Just tell me the last one you worked at. 13 A. Name them off to me. I can't remember. 14 Q. When was the last one that you worked at? 15 A. I cannot remember. 16 Q. I want, I want to be fair to you. 17 A. Okay. 18 Q. Let's start with this, let's start in the 19 year, from January 1 of 2009 to the present tell me 20 which establishment you worked at that are similar 21 to Jamie's studio? 22 A. 2009? 23 Q. What you referred to as jack shacks. 24 A. 2009? 25 Sys, January I of 2009 to the minute you Page 464 1 shoes and my purses and my — 2 Q. What gentlemen's club? 3 A. I've been to Spearmint Rhino. I've been to 4 Flashdance. I've been to Pompano Cheetah. I've been to 5 any strip club 1 can drive by. 6 Q. Well, you — would you go to those in the daytime or would you go there at night? 8 A. Bold, am. and p.m. 9 Q. Well, let's start, lees start with the 10 bottom one, Pompano Cheetah. 11 A. Okay. 12 Q. You haven't been to it lately, have you? 13 A. No. 14 Q. Not open now, is it? 15 A. Oh, I don't know if it's open or not. 16 Q. Did you go to it since January of 2010? 17 A. No. 18 Q. Okay. Have you gone to Flashdance since 19 January, 2010? 20 A. To sell stuff. yes. 21 Q. Well, we're going to get to why you went 22 there. But you admit that you went to Flashdance 23 since January of 2010? 24 A. Yep. 25 Q. And how many times have you been there? (561) 832-7500 33 (Pages 461 to 464) PROSE COURT. REPORTING AGENCY, INC. (561) 832-7506 EFTA01108840 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 465 A. A few times. Q. And how many is a few? A. A few, like three, four. Q. Okay. And was it in the day or night? A. Flashdance, at night. Q. Okay. And what did you do on each of the occasions when you went there? A. i walk in there. One time I just went there to hang out. Q. I don't know what you mean by just to hang out? A. Just to hang out to have a couple drinks. Q. Okay. Now, Flashdance is a topless bar? A. Yes. Q. So, and this is in 2010? A. Yeah. Q. And why would you just be going to a topless bar to hang out and have drinks. Did you have friends you were meeting there? A. No. Q. So, you just picked out of all of the bars • in Palm Beach County, you elected, the one you wanted to go to was the Flashdance topless bar? A. Yes. Q. And why was that? Page 467 1 A. Who cares if I went to Flashdance. 2 Q. There are a lot of bars out there that are 3 dose to - • .4 A. What does it matter if I went to Flashdance or 5 not. What does it matter if I went to Flashdance that 6 night or not? Really, what does it matter? 7 Q. I can't answer your question. I am just 8 taking a deposition. 9 A. Okay. 10 Q. So, you can't articulate any reason why 11 you went to Flashdance? 12 MR. EDWARDS: Object to the form. 13 THE WITNESS: I went to have a couple of 14 drinks. 15 BY MR. LUTTIER: 16 Q. And who did you join for this? 17 A. I am allowed to do that. 18 Q. • And who did you have drinks with? 19 A. Me, myself, and I. 20 (Loud noise at the window.) 2/ THE WITNESS: Holy - 22 BY MR. LUTTIER: 23 Q. Did you tip anybody? 24 A. No. 25 Q. Did you talk to anybody you knew there? Page 466 1. A. It was the decision I made that night 2 Q. So, you were comfortable going into a 3 topless bar, right? i mean, you worked in than 4 before, right? 5 A. Yeah 6 Q. So, then you thought going in that and 7 watching women get naked and dance for men and do 8 lap dances and all that was all okay, right? 9 A. I sit at the bar. I don't have to watch the 10 women. i have a couple of drinks and I leave. 11 Q. Well, why would you pick a topless bar as 12 opposed to the Carousel at CityPlace, for example? 13 A. Because my house is closer to there. 14 Q. Okay. And you're going to tell me that's 15 the only bar near your house? 16 A. No, but I would rather be around, you know, at 17 that time maybe I wanted to be around people my age 18 rather than, you know, an older man that time. I don't 19 know. 20 Q. Well, Clematis Street right down here in 21 West Palm Beach is full of bars with people your 22 age. 23 A.. Yeah, but it's not close Flashdance is 24 closer to me. 25 Q. Well, there's a lot of bars out there Page 468 1 A. Yeah, I talked to a couple of people that I 2 knew. 3 Q. And who was that? 4 A. There was one girl Marium, but I don't even 5 know if that's her real name. And then a couple guys 6 that I've seen. They're associates, i mean, I saw in 7 the past. 8 Q. What do you mean by associates? 9 A. Like people that i don't, that are not my 10 friends, that i just saw in the past. 11 Q. Well, !mean, do you use the word 12 associate to define somebody that you just 13 physically saw? 14 A. Associates, people I have talked to before. 15 Q. So, you would characterize everybody in 16, this room as just an associate because you've talked 17 to us? 18 A. Yeah, like if I saw her, I would say I know 19 her. 20 Q. Were these individuals that you saw there. 21 these couple of guys, people that you had done 22 business with? 23 A. No. 24 Q. And Murium, how did you know her? 25 A. From a snip club. (561) 832-7500 34 (Pages 465 to 4 6 8) PROSE COURT REPORTING' AGENCY, INC. (561) 832-7506 EFTA01108841 Page 469 1 Q. What club? 2 A. Flashdance. 3 Q. Well, that's the club you were in? 4 A. Yeah. 5 Q. And how did you know her before that? 6 A. From Flashdance. 7 Q. Okay. And, and you had made her 8 acquaintance because of what? 9 A. She came up to me when I was at Flashdance one 10 day and said, hi, how are you, and we started a 11 conversation. 12 Q. Did you ever dance at Flashdance? 13 A. No. 14 Q. Okay. Spearmint Rhino, when is the last 15 time you were there? 16 A. Couple of days ago. 17 Q. Let's see now. Today is February 9th so 18 that would be what day? 19 A. I don't 'mow. Like three days ago. 20 Q. Okay. And what other places, adult type 21 places are located near Spearmint Rhino? 22 A. There is Cheetah's down the road. There's a 23 couple of, I know there's a couple shops that I stopped 24 by that I don't know the names. I know there is 25 another, there is like a new Lauren's that I've walked Page 471 1 in there and I spend five minutes. If they don't want 2 anything, they tell me to go. And then sometimes I will 3 go in there and, you know, f will sell stuff for two 4 hours, or I could stay there all night long and sell 5 stuff. 6 Q. For what period of time were you there 7 Saturday night? 8 A. Saturday night I probably arrived at like 8:00 9 and left at closing. 10 Q. Which is what time? 11 A. Five, I want to say 5 or 6. 12 Q. That's 5 a.m., isn't it? 13 A. Yeah. 14 Q. So you were there for nine hours? 15 A. Yeah. 16 Q. Wait, two, seven hours? 17 A. Yeah. 18 Q. According to you selling shoes and 19 lingerie and Mary Kay, right? 20 MR. EDWARDS: Form. 21 THE WITNESS: Correct. 22 BY MR. LUTTMR: 23 Q. All right. So tell us how much you sold. 24 A. I sold a couple shoes. 25 Q. Dollar volume. Page 470 1 into on Forest Hill and Military. I will even walk into 1 2 like island Jack's and try to sell my shoes and purses. 2 3 Igo anywhere. I go to nail salons. 3 4 Q. Well, how often do you go to Spearmint 4 5 Rhinos? 5 6 A. I go to Spearmint Rhino frequently. 6 7 Q. How frequently? 7 8 A. Like once a week. 8 9 Q. And for what reason did you go Spearmint 9 10 Rhino once a week? 10 11 A- To sell my shoes, my purses, my lingerie„ my 11 12 Mary Kay. 12 13 Q. Any other reason? 13 14 A. No. 14 15 Q. Sella lot of Mary Kay to the dancers? 15 16 A. Yeah. 16 17 Q. Now, you say two days ago. Today is the 17 18 9th. So, are you referring to Sunday night you were 18 19 at Spearmint Rhino's? 19 20 A. Sunday night What did I do on Sunday night? 20 • 21 What was I doing Sunday night? No, !think it was 21 22 Saturday, Saturday night. 22 23 Q. Okay. And how long were you at Spearmint 23 24 Rhino's Saturday night? 24 25 A. 1 stayed there fora while. I, sometimes I go 25 (561) 832-7500 Page 472 A Forty — Q. 5100 worth of stuff? A. $40 shoes, $50 shoes. Lingerie, I sold a lot of that. Q. How much dollar wise, $100 worth? A. Are you trying to, like, get to know, like, how much I make? Q. I just want to know how much — A. How much do you make? Q. — for this, you know, for this period of time that you were there until 5 a.m. in the morning? A. I don't know. I didn't write it down. I'm sorry. Q. Well, you must keep track of it, right? A. No, I don't. Q. Don't you report it for tax reasons? MR. EDWARDS: Object to the form. THE WITNESS: No, no, I don't. BY MR. LUTHER: Q. You don't report tax on this? A. I, listen, I don't have any documents of how much I bring in from my shoes and stuff. Q. Well; you know you've got to pay taxes on money Lou earn, don't you? 35 (Pages 469 to 472) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108842 Page 473 1 A. Yeah. 2 Q. Okay. So, how do you keep a record of It? 3 A. It's in my head. !know -- 4 Q. Fora year? 5 A. Why not? Yeah. I can estimate. 6 Q. What we you going to do at the end of the 7 year in tenns of reporting your sales and how 8 much -- 9 A. Idoit. 10 Q. -- how much income you've made so you can 11 report properly to the IRS what you owe in taxes? 12 A. Idoit. 13 Q. How? 14 A. I just told. 15 Q. In your head you remember a year's worth 16 of sales? 17 A. ram pretty good at that, yeah. 18 Q. You've got no documents? 19 A. No. 20 Q. Okay. But that would be kind of lilce your 21 tax returns in '07 and '08 when you said you were 22 making $20,000 a year cleaning houses while you were 23 making $2,000 a night as an escort, right? Imam, 24 they probably wouldn't be very accurate, would they? 25 MR. EDWARDS: Fenn. Page 4.: 1 A. Yeah. 2 Q. And, and, and who are the names of the 3 ones you had drinks with? 4 A. Star, Mercedes. 5 Q. And how do you know Star and Mercedes? 6 A. From Spearmint Rhino. 7 Q. Ever dance with them? 8 A. No. 9 Q. Okay. What else did you do while you were 10 there? 11 A. I just told you that's all! did was hang out 12 and sell my stuff. 13 Q. Okay. Now, the week immediately before 14 that, the previous week, starting February 1st, were 15 you at Spearmint Rhino's at any time? 16 A. Yeah. 17 Q. Okay. And when was that? 18 A. I can't tell you the specific dates. 19 Q. Okay. Well, how many times during that 20 week were you there the first week of February? 21 A. I know I stopped by there ]ice practically 22 every day because some, some people would give me 23 requests like 1 want a pink, you know, a pink top or a 24 blue top so — 25 g And Page 474 MR. LUITIER: You do recall — 2 THE WITNESS: Okay. So what's you're 3 question. 4 BY MR. LUTTIER: 5 Q. I want to know how much you sold in 6 lingerie that night. 7 MR. EDWARDS: Form. 8 THE WITNESS: $150. 9 BY MR. LUIT1ER: 10 Q. Okay. So we have got $150 and maybe 40 or 11 50 in shoes. Any purses? 12 A. No. 13 Q. • Okay. So you were there for, what, seven, 14 eight hours, and you made, you sold $200 worth of 15 stuff? 16 A. Yeah. 17 Q. Okay. And what else did you do while you 18 were there? 19 A. Hung out. 20 Q. What do you mean by "hang out*? 21 A. I had a couple of drinks with the bouncers and 22 with the girls. 23 Q. What girls would those be? 24 A. The girls that work there. 25 Q. Dancers, right? Page 476 1 A. — I would bring them whatever they wanted. 2 Q. And how long, on those orrasions you went 3 how long did you stay there? 4 A. Anywhere between an hour to five hours. 5 Q. Okay. And how much, in that whole week 6 how much stuff did you sell? 7 A I probably sold $500 worth of stuff. 8 Q. Now, are there other business 9 establishments in the same center where Spearmint 10 Rhino's is located? 11 A. Yeah, it's like a strip mall. 12 Q. What other places are there? What other 13 adult type entertainment places are in that same 14 strip mall as Spearmint Rhino's? 15 A. I have no idea because I don't go there. 16 Q. Have you ever been in any of those? 17 A. No. 18 g Do you have a name that you use these days 19 other than, than your given name? 20 A Sometimes. 21 Q. What name would that be? 22 A. Lynn. 23 Q. How about any other names? 24 A. That's it. 25 Q. All ri$trt. I want to make sure we're (561) 832-7500 36 (Pages 473 to 476) PROSE COURT REPORTING AGENCY,' INC. (5 6 1) 832 -75 0 6 EFTA01108843 Page 477 1 clear. I want to give you an opportunity. 2 A. Okay. 3 Q. Frail February 1st of 2010 — 4 A. February 1st 2010. 5 Q. Better yet I am going to back that up. 6 From January 28th, 2009, until today, that's the 7 period of time I am -- 8 A. January 28th, 2009. 9 Q. — asking you about. Have you ever been 10 in any other business establishment that's located 11 in the strip mall where Spearmint Rhino's is? 12 A. Nope. I've just been in Spearmint Rhino and 13 everything affiliated with that. 14 Q. Well, okay, well, what do you mean 15 everything affiliated with that; other businesses 16 affiliated with it? 17 A. No, just Spearmint Rhino. 18 Q. Like the business right next to it, do you 19 know what the name of that business is? 20 A. No. 21 Q. What other businesses are there that are 22 affiliated with Spearmint Rhino? 23 A. There's-- 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: — Spearmint Rhino and then Page 479 1 Q. But you would have no — I want to make 2 sure we're clear. You would have no earthly idea 3 why anyone would ever report that you were in 4 someplace other than Spearmint Rhino that's located 5 in that same location; is that right? 6 A. I have no earthly idea? 7 Q. Right, you have no idea because you were 8 never in anyplace there, is that right? 9 A. Correct. 10 Q. When was the last time you were in a 11 facility that you would call a jack shack? 12 A. I don't know. I've been in a couple of places 13 like the old Lauren's — it's a new Lauren's on Forest 14 Hill and Military selling shoes. 15 Q. No, I said when was the last time you were 16 in a place you would characterize as a jack, as a 17 jack shack? 18 A. That's that, the old Lauren's. 19 Q. So, you would call Lauren's a jack shack? 20 A. I think that's what they do. 21 Q. Now, eject( shack is not occupied by 22 dancers, right? 23 A. I'm not sure. Fm not positive. 24 Q. So- 25 A. I'm not going to speak for them. I don't Page 478 there is like in the back there is a little 2 thing back there in Spearmint Rhino and they 3 have a different, it's, it's just different, 4 ifs affiliated differently. BY MR. LUTHER: Q. Any other place that you were? A. I said no like five times. 8 Q. Okay. Do you know of a, what you have 9 called a jack shack that's located right next door 10 to Spearmint Rhino? 11 A. No. 12 Q. Have you ever heard of a place called I 13 think it's called Fantasies? 14 A. No. 15 Q. Never heard of that? 16 A. No. 17 Q. Have you ever been in that place? 18 A. No.. 19 Q. Could you think of any reason why anyone 20 would report that you were in that location during 21 the period of time that I just said? 22 A. Is it in, is it next to Spearmint Rhino? 23 Q. Yep. 24 A Oh, well, then maybe I should go there and 25 sell shoes. Page 480 1 know. 2 Q. Why would you be in Lauren's if ifs a 3 jack shack trying to sell shoes? 4 A. Because women love shoes. 5 Q. Any other jack shacks you have been in 6 within the last two years? 7 A. I stop at every place l know. I stop, like I 8 will drive down Military Trail or I will drive down 9 Okeechobee Trail and if there's a nail salon, if there's 10 a tanning salon, if even people are walking out of CVS, 11 if there is a shop which is a, what you're calling a 12 jack shack, if there is anything like that, women 13 affiliated, I will go there and try to sell Mary Kay. 14 Q. Since January of'09, have you performed 15 any services in a facility that you've termed a jack 16 shack? 17 A. Since January '09, no. 18 Q. January I of'09. You're absolutely sure 19 of that? There is no doubt in your mind. It's 20 not — 21 A. I was with 22 Q. Wait a minute. It's not something you, 23 you just can't remember. You're emphatically 24 denying that ever happened; is that right? 25 MR. EDWARDS: Form. .(561) 832-7500 37 (Pages 477 to 480) . PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108844 Page 481. 1 THE WITNESS: As of right now I do not 2 remember of any time through January of '09 that I was in an tick shack, no, because I was 4 With 5 BY MR. LUTHER: Q. Have you ever worked A. And he took care of me. a Q. -r at Abby's? 9 A. On advice of counsel I am invoking my Fifth 10 Amendment rights under the United States Constitution. 11 Q. Would Abby's qualify as a jack shack? 12 A. I don't 'mow. 13 Q. For what period of time did you work at 14 Abby's? 15 A. I never said t worked at Abby's. 16 Q. Well, did you work at Abby's? 17 A. On advice of counsel I may invoke my Fifth 18 Amendment rights under the United States Constitution. 19 Q. Okay. So did you work in Abby's in, since 20 January 1 of 2009? 21 A. Excuse me? 22 Q. Did you work in Abby's since January 1 of 23 2009? 24 A. No. 25 Q. Have you worked in Whispers? 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 483 to it. THE WITNESS: On advice of counsel I am invoking my Fifth Amendment rights under the United States Constitution. BY MR. LUTHER: Q. Did you masturbate males in Angels of Palm Beaches? A. On advice of counsel I am invoking my Fifth Amendment rights under the United States Constitution. Q. Nobody forced you to work at Angels, did they? A. On advice of counsel lam invoking my Fifth Amendment rights under the United States Constitution. Q. A. A. Q. A. Q. A. Q. A. Q. A. Did you work at Flirts? Yes. When did you work at Flirts? In early '08. And what did you do at Flirts? Did I private sessions. And what is Flirts? Flirts is one-on-one private sessions. Where is it located? Purdy and Military. What do you mean by private sessions? Pretty much naked company. Page 482 1. A. Nope. 2 Q. Have you worked in Angels of the Palm 3 Beaches? 4 A. On advice of counsel I am invoking my Fifth 5 Amendment rights under the United States Constitution. 6 Q. What did you do at Angels of Palm Beaches? 7 A. On advice, on advice of counsel I am invoking 8 my Fifth Amendment rights under the United State 9 Constitution. 10 Q. There were other girls that went to 11 Jeffrey Epstein's that worked at Angels with you, 12 weren't there? 13 A. No, not that I know of. 14 Q. How much was, what was your split in your 15 pay when you worked Angels of Palm Beaches? How 16 much did you have to pay to the house and how much 17 did you keep? 18 A. I never said I worked there. 19 Q. I know you didn't say that. I5a just 20 asking you the question. I notice that you're not 21 denying that you got any money. 22 A. Excuse me? 23 Q. You're not denying that you worked there, 24 right? 25 MR. EDWARDS: Stick to that. Just stick Page 484 1 Q. What do you mean by that? 2 A. Naked company. 3 Q. So, describe what would go on there. What 4 did you do there. 5 A. Company being naked. A gentleman would conic 6 in and you sit there nude or in panties and bra and you 7 get paid for company. 8 Q. Well, lust of all, let me -- let's break 9 this down. He would come in and you would take him 10 into a room? 11 A. Correct. 12' Q. And what was in this room? 13 A. Chairs, sofa, lights. 14 Q. Anything else? 15 A. An ashtray. 16 Q. And what would you — 17 A. Table. 18 Q. What did you do for your clients that came 19 into these rooms? 20 A. I just told you. Let's say it again. I would 21 bring a guy in and then I would either be in my bra and 22 panties or just my panties and a guy would pay to have 23 my naked company. 24 Q. And what else would occur? • Nothing. 38 (Pages 481 to 484) (561) 832-7500 PROSE COURT REPORTING. AGENCY,. INC. (561) 832-7506 EFTA01108845 Page 485 1 Q. Any, any physical touching ever? 2 A. Nope. 3 Q. What would the guy do? You would just be 4 sitting there naked. 5 A. The guy was not allowed to do anything. 6 Q. And how much would somebody pay you for 7 this? 8 A. It was SLOG to get in the door. 9 Q. Okay. And how much of that money did you 10 get to keep? 11 A. Forty. 12 . Q. And did you ever do anything with anybody 13 in Flirts other than simply sit there either in your 14 panties and bra or just your panties? 15 A. No. 16 Q. How many other similar establishments did 17 you work in? 18 A. A couple of them. 19 Q. What were their names? 20 A. I don't recall. 21 Q. Did you, have you advertised your services 22 before in any type of publication or online website 23 or things Ince that? 24 A. Personally, no. People have took my picture 25 without my consent and done it, but no. Page 487 / like this to certain people. And they used my ad, used 2 my picture for their ad. 3 Q. Well, was — 4 A. Not my fault 5 Q. -- it more than one picture that had been 6 taken when you went to your girlfriend's? 7 A. Yes. 8 Q. Now, you knew when your girlfriend was 9 taking the picture that you were going to use the 10 picture for something? . 11 MR. EDWARDS: Object to form. 12 THE WITNESS: No, not at all. I take fun 13 pictures all the time. 14 BY MR. LUTHER: 15 Q. So, fun pictures where you just stand 16 around topless with your hands -- 17 A. Yeah, I am 21 years old. I'm having film 18 Like you've never done it. 19 Q. Well, when were these pictures taken? 20 They weren't taken when you were 21, were they? 21 A. No. They were taken when I was like maybe 18 22 Q. Okay. And so, for what purpose were the 23 pictures taken? 24 A. Just for fun. 25 Q. Okay. Just you and a friend whose name Page 486 1 Q. Well, how do you know that? 2 A. Because I've saw it and I'm -- 3 Q. What - 4 A. -- having -- I am trying to actually get that 5 resolved right now because ifs wrong. 6 Q. What did you see? 7 A. I saw supposedly someone posting me as an 8 escort on, on websites. 9 Q. What websites? 10 A. I'm not — I don't recall. 11 Q. Well, was your picture there? 12 A. Yeah, and it was not supposed to be. 13 Q. And what were you wearing in the picture? 14 A. A thong and like my hands like this, topless. 15 Q. Topless? 16 A. Yeah. 17 Q. So, it was a picture you had posed for? 18 A. Yeah, but not like in a shop or anything. 19 Q. What do you mean not like in a shop? 20 A. Not in a jack shack. 21 Q. Well, where had you posed for the picture? 22 A. At a house, like at my girlfriend's house. 23 Q. Which girlfriend? 24 A. I don't recall. These pictures were so long 25 ago. But someone got a hold of diem and things happen Page 488 1 you can't remember? 2 A. No. 3 Q. You can't remember her name? 4 A. Nope. 5 Q. Was there anybody else there with you? 6 A. Actually one girl's name was Brittany. 7 Q. Brittany what? B A. I don't know. 9 Q. Another person that's got a claim against 10 Mr. Epstein? 11 A. No. 12 Q. Okay. When did you notice that your 13 picture was up on a website? 14 A. I had — lwas going on eraig's List to !bid 15 furniture. And I, I was just curious and I was looking 16 at — 'went to the adult section and it caught me by 17 surprise that it said like I saw my picture on there 18 for, for an establishment. 19 Q. What establishment was that? 20 A. I 'mow one was for Abby's. 21 Q. And you had worked at Abbys, right? 22 A. No. 23 .Q. And in fact you had run ads on Craig's 24 List under the exotk or erotic -- 25 A. No, I did not. (561) 832-7500 39 (Pages 485 to 488) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108846 1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 A. No. 24 5 Q. Now, you said, back with Bobby, you said 25 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 489 Q. — service? A. I have never run ads. You have asked me this three times. I have never run an ad. I've never advertised myself. People have took my picture and decided upon themselves to run their ad with my picture on it. Q. Why would — A. False advertising. Q. Why would they want to do that? A. Probably because a good looking girl and they wanted, you know, men to come into the shop. Q So, when did you first discover that your picture was on this website? A. About a year ago. Q. And what did you — you said you were doing something to straighten it out. What have you done? A. I called an attorney. Q. And who was that? A. It doesn't matter. Q. Yeah. Who did you call? MR. EDWARDS: You can tell him who. That's about it. THE WITNESS: Brad Edwards. Page 491 1 that you went to, I guess the Carousel a couple of 2 times and La Quinta a couple times and New York? 3 A. Yep. 4 Q. And you said that there were, you had 5 several other clients. I think you said three but I 6 could be wrong. He had referred you three other 7 clients. Do you recall that testimony? 8 A. Yes. 9 Q. And who are the other clients? 10 A. There is Jeff and then two Johns. 11 Q. And, and who is Jeff? 12 A. Jeff is a man. 13 Q. Okay. And how many times have you been 14 out with him? 15 A. Three times. 16 Q. And where did you go with him? 17 A. La Quint& 18 Q. Is it just coincidental -- at the same 19 hotel that you went with Bobby? 20 A. Yes. 21 Q. Just coincidentally you went to the same 22 hotel? 23 A. Yeah. 24 Q. And what did you do with Jeff at the 25 La Quints? Page 490 BY MR. WITTER: Q. And is there a lawsuit filed? MR. EDWARDS: Object to the form Any other questions are going to attorney-client privilege. I am not going to let her answer any of the substance of that conversation after the fact that she called me and she's disclosed that. MR. LUTHER: !just want to know if there is a lawsuit filed. That would be public record. MR. EDWARDS: Right. You can look it up in public record. I am not going to let her tat MR. WTTIER: Well, l think she gets to answer. BY MR. LUTTIER: Q. Is, is there a lawsuit filed? MR. EDWARDS: Don't answer, attorney-client BY MR. L Q. Is there -- have you written a demand letter to a defendant? IP' Page 4'• A. Just nude company. Q. You were nude for that one? A. Yep, nude, nude company. Q. Have you ever been nude with Bobby? A. No. Q. Has he ever asked you to be nude? A. No. Q. Any reason why you haven't been nude with him? A. Because he didn't ask for it. Q. Did this guy Jeff ask for it? A. Yeah. Q. And how much did y0u get paid for by him for that? A. 200. Q. An hour? • A. Yes. Q. And how many hours would you be there? A. One. Q. So, tell the ladies and gentlemen of the jury what you did on this occasion when you went to the La Quints to give Jeff nude company. MR. EDWARDS: Object to the form. THE WITNESS: Jeff and I went to La Quinta and we sat down on the bed. And I took (561) 832-7500 40 (Pages 489 to 492) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108847 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 493 clothes oft and he would sit there smoking cigarettes, and we would just talk about life. BY MR. LUTITER: Q. Well, what do you — was that the first time you met Jeff? A- Yes. Q. Had you had a face-to-face meeting with him before you went to the La Quinta for the first time? A. No. He was a referral from Bobby. Q. Okay. So, you knew nothing about him? A. No. Q. The first time he called you didn't even know his name until he identified himself? A. Yep. Q. !she married? A I think so. Q. How old is he? A. I have no idea, older. Q. Older man? A. Maybe around your age. Q. Okay. Well, that's pretty old. I am going to qualify for Social Security soon. Did he look like a rich guy? A. Yeah. 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 495 of what I do. Q. Well, why would you do it if you were scared? A. Because it's all I know. Q. All right. So, and you, at two other times you went to see this Jeff right? A. Yeah. Q. When was the second time, where did you 110? A. We went to a hotel in Royal Palm. Q. Well, there's not many out there. Which one did you go to? A. I forgot. Royal Palm Inn, I don't know. Q. What you do that time? A. Same thing. Q. Nude company? A. Yeah. Q. Did he ever touch you? A. No, I don't do that anymore. I have four clients. Q. And what do you do if he says he wants some sex? A. I will tell him go find another girl. Q. What if he just wants you to masturbate him? Page 494 1 Q. Did he look like Mr. Edwards? 2 A. No. 3 MR. EDWARDS: Just like you. 4 THE WITNESS: No not like you either. 5 BY MR. LLM'IER: 6 Q. So, had you decided - 7 A. You don't look rich. 8 Q. — this guy was, was a wealthy guy? 9 A. Sure. 10 Q. Was there anything else that made you 11 decide he was wealthy other than the fact that he 12 was an older guy? 13 A He had a nice car. He had nice clothes. 14 Q. And therefore you said I am happy to go 15 sit in a room naked with him and get paid 200 bucks 16 from him? 17 A. Yeah. 18 Q. You wanted the money. 19 A. Yeah. 20 Q. Good deal, right? 21 A. That's what I do fora living. 22 Q. Didn't scare you? 23 A. No. 24 Q. Didn't bother you? ‘35 A. Actually it did scare me. I am alwap scam!! (561) 832-7500 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 496 A. Masturbate him? Q. Yes. A. Isn't that sex? Q. I don't know. I don't know what's your definition. Depends on who you are. A. Sex, the definition of sex is, you know, touching somebody. Q. Okay. What if you're touching yourself: is that — A. Yeah. Q. — what you call sex? A. Yes. Q. So did you ever masturbate in front of these guys? A. No, I sat there naked. Q. Do they get to take pictures or anything? A No. Q. Okay. So you went to the hotel in Royal Palm Beach again for an hour? A. Yes. Q. How much did you get, $200? A. Yes. sm.... I Q. Okay. And then what was the third time'? A. Third time same hotel, Royal Palm. Same thing? 41 (Pages 493 to 496) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108848 Page 497 Page 499 1 A. Yes. 2 Q. Do anything else? 3 A. Same thing. 4 Q. When was the last time you were there with 5 Jeff? 6 A. Before New York. 7 Q. Like the first week of February of 2010? 8 A. Yeah, I don't know the dates. 9 Q. Either the last week of January 2010 or 10 the first week of February 2010. Within the last 11 ten days? 12 A. Maybe. 13 Q. Okay. And when was the time — all right. 14 So you were with Bobby last week. You were with 15 this guy within the last ten days. Now, how about 16 John One, how many times have you been with John 17 One? 18 A. Once. 19 Q. One time. and when was that? 20 A. Right after I saw Jeff. 21 Q. The last time? 22 A. Uh-huh. 23 Q. So — 24 A. Yes. 25 Q. So, that's been within the last ten days? 1 A. Probably. 2 Q. Think he's got a lot of money? 3 A. Yeah. 4 Q. And what did you do for him? 5 A. Same thing I did for Jeff. 6 Q. Sat around nude in a room? 7 A. Yes. 8 Q. And how much did you get paid? 9 A. 200. 10 Q. For an hour? 11 A. Yeah. 12 Q. And has he made an appointment for another 13 time or just one? 14 A. He calls me whenever he wants me. 15 Q. Has he called you since that — you said 16 you went in the last ten days. Has he called you 17 since then? 18 A. No. 19 Q. Do you got any appointments scheduled now 20 as you sit here? 21 A. No. 22 Q. With anybody? 23 A. No. 24 Q. Okay. Then there was another John. 25 A. Uh-huh. Page 498 1 A. From what I remember, yes. 2 Q. Okay. And where did you meet him? 3 A. At a hotel. 4 Q. What hotel? 5 A. It's on Okeechobee near the Turnpike or near 6 the, near the 95. I don't remember the name. 7 Q. The Marriott? 8 A. Ifs -- I'm not sure but ifs near 95. 9 Q. By the Tri-Rail station? 10 A. It's near 95. 11 Q. As in like right down the street from this 12 building? 13 A. It's, no, it's, it's east -- it's west of, 14 west of, west on Okeechobee. 15 Q. Yeah, but you said near 1-95? 16 A. Closer to 1-95 than the Turnpike, yeah. 17 Q. East of Military Trail? 18 A. East of Military Trail. It might have been. 19 I'm not, I'm not positively sure. 20 Q. Okay. So, did, did you know anything 21 about John before you met him in this hotel? 22 A. No. 23 Q. And is, is he an older man? 24 A. Of course. 25 R. Married? 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 500 Q. And how many times have you been with that John? A. One other time. Q. One other time or is this, is this with the first John? A. Second John. Q. Okay. Second John. A. One time at the same La Quinta. Or not the La Quinta the behind the La Quinta there is a, ifs like 180 to get a room. I don't know what it's called. Q. On what road, on Okeechobee? A. Yeah. Ifs behind the La Quinta on the west side of the La Quinta. Q. Okay. Older guy? A. Yeah. Q. You think he's wealthy? A. Yes. Q. Married? A. Probably. Q. How much -- what you did you do for him? A. Same thing. Q. Sat around in a room nude? A. Yeah. Q. Got paid 200? A. Yes. 42 (Pages 497 to 500) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01108849 Page 501 1 MR. WITTER: We might as well rake a 2 break now. 3 THE VIDEOGRAPHER: Going off the record at 4 12:54 prn. 5 (A luncheon recess was held from 12:54 to 6 1:48 p.m.) 7 4, • • B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 43 (Page 501) (561) 832-7506 EFTA01108850