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Page 50: IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO:502008CA028051XXXXMB AB Plaintiff, -vs- VOLUME IV OF IV JEFFREY EPSTEIN AND Defendants. VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF Tuesday, February 09, 2010 10:09 - 5:05 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1296 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (0014151-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) b55421ef-d299-4e4f-9ba6-85and27f4405 EFTA01108851 EFTA01108852 Page 503 Page 505 1 APPEARANCES: 2 On behalf of the Plaintiff. and Jane DDe . 3 BRAD J. EDWARDS. FARMER, JAFFE, WE/SSING, EDWARDS I,PJ02MAt4. PL 7 On behalf o the Jeffrey Epstein: 3 ROBERT D. CRITTON,11t, P8QUIRE MARK T. tura ESQUIRE 9 R • wt ft* LLITTIER & COLEMAN, ELP 12 On o the a r: ant, ;army Epstein: 13 JACK ALAN GOLDBERGER. ESQUIRE • R & WEISS, PA. 14 16 17 18 ALSO PRESENT. kffrey Epstein, via video conference Daniel C1/4”.ney, Videogmpber 19 Visual Evidence, Incorporated 20 21 22 23 24 25 1 2 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROCEEDINGS THE VIDEOGRAPHER: We're back on the record at 1:48 p.m. BY MR. LUTHER: Q. Okay, Ma'am. I want to add that during the morning session, I was asking you some questions. I just want to go over a couple of things. One of the first things I asked you this morning is whether you understood you were under oath today. And you indicated you did understand that? A. Correct. Q. Are you, did you, are you aware of the fact that it is a crime known as perjury to make a false statement under oath? A. Correct. Q. Are you also aware that it is a separate crime, a federal crime to make a false statement to an FBI agent? A. Correct. Q. And you've already admitted that you committed that federal crime; you lied to the FBI, according to you. A. I was in fear of my sorts life, correct. 1 2 3 4 5 5 7 Page 504 INDEX VOLUME I "NESS: DIRECT CROSS REDIRECT RECROSS BY MR. LUTHER 4 8 9 10 11 EXHIBITS 12 13 14 EXHIBIT DESCRIPTION PAGE 15 DEFENDANT'S NO.3 Photo of Fantasies of Palm Beach 512 16 DEFENDANTS NO. 4 518 17 Photo of Demon's Motorcycle ad 18 DEFENDANTS NO. 5 634 • ' unction for 19 20 DEFENDANTS NO. 6 618 tinctice for 21 22 23 24 25 Page 506 1 Q. Now, l want to ask you one more time: Is 2 there anything you want to correct about any of your 3 testimony this morning, especially as it relates to 4 working in places of employment that you have termed 5 to be jack shacks at or about or near Speannim 6 Rhino? 7 A. Correct. I'm fine on that 8 Q. Okay. Isn't it a fact that on Saturday, 9 January 30th, you went to Spearmint Rhino's? 10 A. Yes. 11 Q. And you got there, what time, around 8:00? 2 A. Yes. 13 Q. And then at some point in time you la 14 Spearmint Rhino's, did you not? 15 A. Yes. 16 Q. And you went to a place called Fantasies 17 of Palm Beach, did you not? 18 A. Not that I recall. I don't know a name 1 9 Fantasies. 20 Q. Well, Fantasies of Palm Beach would be the 21 facility that's located right next door to Spearmint 22 Rhino's. You're familiar with that, aren't you? 23 A. I thought that was affiliated with Spearmint 24 Rhino. 25 Q. Well, so that we 'mow - (561) 832-7500 PROSE COURT REPORTING 2 (Pages 503 to 506) AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (901451.976-2934) Electronically signed by cynthia hopkins (601451.9762934) Electronically signed by cynthia hopkins (601451.9762934) b5542lef-d299-4e4f-9ba6-85aad27f4405 EFTA01108853 Page 509 Page 507 1 (Cellphone interngtion.) 2 THE WITNESS: Oh, Pm sorry, my phone. 3 MR. Lill-TIER: Sure. Oo ahead. 4 THE WITNESS: Okay. Sorry. 5 BY MR. LUTHER: 6 Q. There is a — whether or not ifs 7 affiliated with Spearmint Rhino, I don't know. When 8 you referred to your testimony this morning that you 9 didn't go anyplace other than Spearmint Rhinos and 10 places affiliated did, with it, did you mean to 11 include in those places that you went Fantasies of 12 Palm Beach? 13 A. I personally never heard of Fantasies of Palm 14 Beach, but I know that, there, that Spearmint Rhino has 15 a couple places affiliated with them. 16 Q. What places do they have that are 17 affiliated with them? 18 A. The back and then there's an entrance to 19 another place. That's all ! know. 20 Q. Well, tell me about this entrance to 21 another place. What are you talking about? 22 A. Well, in the back of Spearmint Rhino there is 23 a little section that the dancers I don't know 24 exactly what they do there, but that's where I do sell 25 shoes and my lingerie. Page 508 1 And then there is another entrance that 2 you can go through and then there is another it's 3 like there's, I know that there's, there's a lot of 4 doors. I don't know what they consist of. 1 don't know what they do there, but I know that they are 6 affiliated, I thought that they were affiliated with 7 Spearmint Rhino, and that's where I also go to sell 8 my shoes and ptuses. 9 Q. Okay. Well, you talked about a place in 10 the back of Spearmint Rhino's that you gain access 11 to by going through the Spearmint Rhino 12 establishment? 13 A. Yes. 14 Q. All right. Now, what is this second place 15 that you are talking about that you say is 16 affiliated with Spearmint Rhino's? 17 A. Well, you can either go through out the back 18 door of Spearmint Rhino and take a right, and then there 19 is a place there that's affiliated with them. 20 Q. Is there a name? Is there a separate 21 entrance to the place? 22 A. 1— they're connected. 23 Q. Is there a separate name on this place? 24 A. Not that I know of 25 Q. Okay. I'm tallthsabout a place that's (561) 832-7500 1 located, I believe it's to the left side of 2 Spearmint Rhino's as you look at it. It's got a 3 separate entrance. It's got neon signs on it? 4 A. Okay. 5 Q. And it's known as Fantasies of Palm Beach. 6 You're aware of that place, aren't you? 7 MR. EDWARDS: Fan 8 THE WITNESS: I'm not aware of any name. 9 BY MR. LUTTIER: 10 Q. Well, you were in the establishment known 11 as Fantasies of Palm Beach on the evening of 12 Saturday, January 30th, 2010, were you not? 13 MR. EDWARDS: Font. 14 THE WITNESS: If that's what it's called, 15 then, yes. But, as long, as far as I know, 16 Spearmint Rhino, that's the name I know it as 17 you know. 18 BY MR. LUTTIER: 19 Q. Well, this is a place that has a separate 20 entrance. You don't go through the entrance of 21 Spearmint Rhino. You go into a separate entrance 22 for a place called Fantasies of Palm Beach. 23 A. Well - 24 Q. I want to make sure we're real clear here 25 we're not playing semantics. Page 510 1 A. We're not playing what? 2 Q. Semantics. 3 A. Okay. 4 MR. CRITTON: Word games. 5 THE WITNESS: Oh. 6 MR. LUTTIER: All right? 7 THE WITNESS: Yeah. 8 BY MR. LUTTIER: 9 Q. And, and you were, in fact, in this place 1 0 called Fantasies of Palm Beach on Saturday, January 11 30th, 2010, were you not? 12 MR. EDWARDS: Object to the form. 13 THE WITNESS: I definitely walked through 14 an entrance and that I thought was affiliated 15 with Spearmint Rhino. 16 BY MR. LUTTIER: 17 Q. And there's a black female in there that 18 works at the front desk, is there not? There was on 19 Saturday night. 20 A. Oh, I don't know. I don't know who works 21 there. I don't blow. 22 Q. And the-- 2 3 A. I just know that I go into Speannint Rhino and 24 I sell my — 25 Q. And — 4,1 J 3 (Pages 507 to 510) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (801.051.976-2934) Electronically signed by cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (601.061-9762934) b5542fef-d299-404f-9ba6.85aad2714405 EFTA01108854 Page 511. — items. 2 the name that you're known as is 3 isn't that right? 4 A- I'm not known as 5 Q. That's the name you -- remember we were 6 asking you about the cards you used to use? A. Yeah, I was known as =in '07 and '08. 8 O. that's the name you've used in the past 9 is 10 A. Yes. 11 Q. And in fact on Saturday, January 30th, you 12 were working in Fantasies of Palm Beach which was. 13 to use your terms, a jack shack, were you not? 14 A. No, I was not working there. 15 Q. And you were charging $120 fora half hour 16 to perform services; isn't that right? 17 A. No. 18 Q. Andacame out and told somebody your 19 name was Mend that that was your charge, 20 didn't you not? 21 A. No, I did not. All I do is sell shoes and 22 purses there. 23 MR. LUTRER: Let me show you a picture 24 here which we'll mark as, !guess we want to do 25 it in order. It will be Exhibit 3. Page 513 1 A. No. I say to the girls, my name is Lynn and 2 they know that I sell all of my, all of my clothes and 3 lingerie and shoes and everything else I sell. 4 Q. But there is no doubt that now that you 5 have seen this picture, you were in that 6 establishment that is depicted on Exhibit No. 3 on 7 January 30th, right? 8 A. Correct. 9 Q. And you drive a white Mitsubishi Gallant; 10 is that right? 11 A. Yes. i 2 Q. License plate number is 193HV; is that 13 correct. 14 A. I don't know my license plate number, but 1 15 definitely drive a white Mitsubishi Gallant 16 Q. And is, was that vehicle parked outside 17 Fantasies of the Palm Beach on Saturday night, 18 January the 30th? 19 A. Yes, but like I said before, from my 20 knowledge, I thought this was affiliated with Spearmint 21 Rhino. 22 Q. And that car -- 23 A. And they don't like me to park, they don't 24 like me to park in front of Spearmint Rhino because 25 there are so many clientele that goes in and out. So Page 512 1 (Defendant's Exhibit No. 3 was marked for 2 identification.) 3 THE WITNESS: This place, yeah, ifs next 4 to Spearmint Rhino's. 5 MR. LUTTTER: Hold on. Hold on. 6 TI WITNESS: Sorry. 7 BY MR. LUITLER: 8 Q. I have to ask you a couple of questions. 9 Do you recognize Exhibit 3? 10 A. Yes, but what I would do, I would go out of 11 Spearmint Rhino from the back and go into the back 12 entrance of Fantasies or whatever this place is called. 13 Q. So so, now upon seeing the picture, you 14 want to correct your testimony and say, in fact, you 15 were in Fantasies of Palm Beach on Saturday? 16 A. I, from my understanding, from my knowledge, I 17 thought that this place was owned by Spearmint Rhino. 18 Q. All right. The place of business that's 19 depicted in Exhibit No.3, were you in that place of 20 business on Saturday, January 30th? 21 A. Yes, selling my items. 22 Q. And did you, in fact, on that night, on 23 Saturday, It 30th, tell individuals that your 24 name was and that you charged $120 per half 25 hour? Page 514 1 they need as much parking space as they can. 2 Q. And you stayed at Fantasies of Palm Beach 3 until what hour on the morning of Sunday which would 4 be January 31st? 5 A. I stayed until what time? 6 Q. Yeah, the morning until — what time on 7 the morning of Sunday, January 31st, did you leave? 8 A. Well, Spearmint Rhino, I would go until 9 closing like 5, 6. And then in the back of here, of 10 Spearmint Rhino, that's like, sometimes they have after 11 pa-ties there, something. This is what I hear from the, 12 the manager at Spearmint Rhino. And like I said, 13 sometimes I stay there and I have a couple of drinks. 14 And I'm not sure what time I left. 15 Q. I don't want to know — 16 A. As long as I keep on selling shoes and 17 lingerie, I'm the there. 18 Q. I am not asking about sometimes. h am 19 talking about Sunday morning, January 31st, 2010, 20 what time did you leave on that day? 21 A. I couldn't tell you that. 1 don't know. 22 Q. Well, what's your best estimate? 23 A. I don't know, sir. 24 Q. Well, first of all you closed Spearmint 25 Rhino at, what 5 in the morning? (561) 832-7500 PROSE COURT REPORTING. 4 (Pages 511 to 514) AGENCY, INC.. (561) 832-7506 Electronically signed by synth's hopkIns (601-061-976.2934) Electronically signed by cynthia hooking (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) b5542for-d299-4c4f-9ba6-85aad2714406 EFTA01108855 Page 515 1 A. I closed it? 2 Q. Yeah, you were them until it closed? 3 A. Yes. 4 Q. And then you went over to Fantasies, 5 right? 6 A. That I thought was Spearmint Rhino from the 7 back 8 Q. Whatever. 9 A. Okay. 10 Q. And then, how much longer did you stay 11 there? 12 A. I stayed there a little while because there is 13 more girls there that like to buy my items. 14 Q. Now, let's talk about your trip to New 15 York 16 A. Okay. 17 Q. Tuesday, February 2nd, 2010. Remember 1 18 asked you earlier about whether you ever used any 19 business cards? 20 A. Yes. 21 Q. When you went on this trip to New York, 22 did you have any cards? 23 A. No, not that I no. 24 Q. Did M . have any cards? 25 A. Not that I know of. Page 517 1 A. And we started talking to people. 2 Q. Who did you talk to in particular? 3 A. I don't know anyone else. 4 Q. Did you talk to a male there? 5 A. Yeah. 6 Q. Have him over at your table? 7 A. He came closer to — we were at the bar. 8 Q. The three of you were talking, were you 9 not? 10 A. Yeah. 11. Q. Do you remember the guy having a laptop? 12 A. Yes. 13 Q. What did you-all do on the laptop or what 14 did he do on the laptop while you were there and you 15 both were sitting there? 16 A. Well, I told him that I modeled for Demons 17 Cycles. And I told him if he would like to see my 18 pictures, to go onto Demons Cycles. 19 Q. So, did you tell him about any other 20 websites? 21 A. Excuse me? 22 Q. Did you tell him about any other websites? 23 A. No, not that I recall. 24 MR. LIMIER: Let's mark this as 25 exhibit — what's this, 4? Page 516 1 Q. Did you, when you went to the Palm Beach 2 International Airport, did you give the taxicab 3 driver a card? 4 A. Did I give hi card? 5 Q. Yeah, you or ., little business card? 6 A. I didiagive him a card, no. 7 Q. Did M. give him a business sand? 8 A. Not that I know of. • 9 Q. When you went into the Palm Beach 10 International Airport, your card — do you recall 11 going to a bar? 12 A. Palm Beach International Airport, yeah, I went 13 to a bar there — 14 Q. What bar do you go to? 15 A. — because I totally missed the flight. 1.6 Q. What bar did you go to? 17 A. I think it was Fridays, if I am not mistaken 18 or not. I don't know what it was called. 19 Q. Who went tuk bar with you? 20 A. 1 went with M. to the bar and it was just 21 her and 1. 22 Q. And for how long was it just the two of 23 you? 24 A. For like ten minutes. 25 Q. And then what happened? Page 518 1 THE COURT REPORTER: Four. 2 MR. urrIIER: Mark this as 4. 3 MR. EDWARDS: Is Exhibit 1 and 2 marked - 4 MR. LUTTIER: Yeah. 5 MR. EDWARDS: in the previous depo? 6 MR. LUFTIER: Yeah, the previous depo. 7 Although I don't know where the exhibits are or 8 they went. 9 MR. EDWARDS: Okay. 10 MR. LUTT1ER: It was like answers to 11 interrogatories. Something like that. 12 MR. EDWARDS: Okay. 13 (Defendants Exhibit No. 4 was marked for 14 identification.) 15 BY MR. 16 Q. Let me show you what's been marked as 17 Exhibit 4 and ask you if you can identify that. 18 A. This is — 19 MR. EDWARDS: Wait until he asks you a 20 question. 21 BY MR. LUTHER: 22 Q. Can you identify it? 23 A. Yes. 24 Q. What is it? 25 A. This is --1 modeled for Demon Cycles and it (561) 832-7500 5 (Pages 515 to 518) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051-976.2934) b5542lef-d299-4041-9ba6.85aac127f4406 EFTA01108856 Page 519 1 is their advertisement now. 2 Q. And is this one of the pictures on your 3 website? 4 A. On my website? 5 Q. Yeah, or your Facebook, I guess, account 6 or MySpace, whatever it was. 7 A. Yeah, I have posted it on there, yeah. 8 Q. Is, was this one of the pictures you were 9 telling us at your last deposition that you really 10 wouldn't want your four-year-old son to see? 11 A. No, that's fine if he sees this. This is, 12 this is very legit. His mother modeled and I am 13 actually very proud of this photo. 14 Q. All right. Now, did you do anything else 15 with this inditinial before you left the bar that 16 you, you and M. were tenting to at the Palm Beach 17 International Airport? 18 A. Did we do anything with him? 19 Did you give him anything, either you or 20 21 A. I don't recall givingain anything but — 22 Q. Well, did you see M. give him anything? 23 A. No. 24 Q. Did either one of you give him a business 25 card? Page 521 1 Q. Did you do anything else that evening? 2 A. Yes, we went out to dinner. 3 Q. After you — did you leave the apartment 4 and go look around at Grand Central Station and then 5 keep on walking around or did you come back to the 6 apartment? 7 A. We went back to the apartment. 8 Q. Okay. And then there came a time after 9 you came back from sightseeing that you left the 10 apartment a second time? 11 A. Yes 12 Q. And that was for what purpose? 13 A. We went to Angelo's. 14 Q. Okay. And how did you get to Angelo's? 15 A. We got to Angelo's in a trod. 16 Q. Alexi? 17 A. Uh-huh. 18 Q. And that was about what time? 19 A. Oh, jeez, maybe, maybe 9:00. 20 Q. Between the time — what time did you go 21 looking at Grand Central Station? 22 A. That was before 9:00. 23 Q. Okay. And do you remember, do you recall 24 that evening an individual by name of Martin 25 Krouner? Page 520 1 A. I don't have any business cards. I don't — 2 Q. Well, I don't — you may want to be 3 careful here. I don't want to trick you. lam not 4 playing semantics. Did either you or give him 5 a business card? 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: Not that I recall, no, sir. 8 We had a few drinks and, and we were off to our 9 flight. 10 BY MR. LUTTIER: 11 Q. And then you flew to New York and you took 12 a c and u went to this apartment that's located 13 at 'n New York: is that ri t? That 14 would be the corner o anc Street? 15 A. rings a bell. 16 That's where we stayed? 17. Q. Yeah. 18 A. Yeah. 19 Q. Now, on that evening, the first night that 20 you got there on Tuesday, I think earlier you said 21 you-all walked down a street and went to dinner, is 22 that right? 23 A. We walked down the street and we walked into 24 a, I think it's Grand Central Station. I'm not sure 25 because I'm not from there and we looked around. Yeah. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 522 A. Do I know a man named Martin? Q. Uh.huh, Martin Krouner. A. No. Q. Do you remember getting in a black Series 5 BMW when you came out of the condominium? A. We, we did take a ride with a man. Q. Well, 'thought you just told me you walked to the restaurant. A. No, 'told you I took a cab to the restaurant. Q. Oh, took a cab to the restaurant? A. Yes. Q. Did you forget about getting in a car with this man? A. He took us a little sightseeing. No, I did not forget about that. Q. Was that before dinner? A. That was before dinner, yes. Q. Did you just fail to mention that or — this is different than the man who took you sightseeing later, isn't it? A. Yes. Q. Okay. So, tell me who Martin Krouner is. A. I don't know his name, if that is his name. Q. Well, the guy that picked up in the black BMW, who's he? (561) 832-7500 6 (Pages 519 to 522) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601.051476-2834) Electronically signed by cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (601-051.9764934) b55421et-d299.4c41-9ba6.85aad27f4405 EFTA01108857 Page 523 Page 525 1 A. I guess a friend of Anna's. 2 Q. Well, tell us how old this individual was. 3 Describe him for us. 4 A. He has not a lot of hair. He's about five-six 5 maybe and a little chubby. 6 Q. For what purpose were you — and you never 7 met him before? 8 A. No. 9 Q. In never met him before? 10 A. No. 11 Q. You didn't have any idea who he was? 12 A. No. 13 Q. You-all climbed in his car? 14 A. Yeah, I think it was Anna's friend. 15 Q. Okay. What did Anna tell you about the 16 guy? 17 A. She's Chinese. She's like go, go; go, go have 18 fun, go search the town. 19 Q. So, where did you go with Martin? 20 A. We ended up meeting him at Angelo's. 21 Q. Wait a minute. You got — first of all 22 you got in Martin's car, right? 23 A. I got into Martin's car, yes. 24 Q. And then where did you go once you got in 25 Martin's car? 1 fellow here, Mr. Martin Krouner? 2 A. If that's his name. I don't know if we took a 3 picture of him, but we definitely took pictures of.. 4 and I. 5 Q. And, and where did you take those 6 pictures? 7 A. Wherever we were. 8 • Q. Okay. And when this man brought you back, 9 did he go to dinner with you? • 10 A. He ended up meeting us there, yes. 11 Q. Did he drop you at the restaurant? 12 A. He dropped us near so we can get there with a 13 taxi. He dropped us somewhere off of the street and we 14 went with a taxi. 15 Q. So, he dropped you off and then you got a 16 taxi to get there? 17 A. To go to Angelo's, yeah. 18 Q. And then he met you there later? 19 A. Lateran. 20 Q. Okay. About what time? 21 A. Oh, God, I don't know the times. Maybe this 22 was around, maybe around — I'm — this is total 23 ballpark, Mee 10 maybe. 24 Q. Okay. An d, and then after dinner 25 what did you and M. and he do? Page 524 1 A. We searched around the town. 2 Q. What do you mean you searched around? 3 A. We went sightseeing. 4 Q. Okay. Do you remember where you went? 5 A. And we went sightseeing. 6 Q. Do you remember where you want 7 sightseeing? 8 A. Then we took a taxi. No, because I don't know 9 the area. 10 Q. You went sightseeing in Mr. Kroner's car, 11 correct? 12 A. Yes. 13 Q. All right. And, and did there come a time 14 that you got of Mr. Kroner'S car? 15 A. Yeah, and we looked around. It was finning 16 outside, so it was nice to feel the snow. 17 Q. And where did you get out of the car? 18 A. Sir, I don't know New York. I don't — 19 Q. Well, was it at a restaurant? Was it at 20 the pool? Was it back at the condo? Where was it? 21 A. it was near a whole bunch of buildings. 22 Q. By the way, did you take any pictures 23 while you were up there? 24 A. I did take pictures. 25 a Take a picture of you and ■ and this (561) 832-7500 Page 526 1 A. Well, we took a taxi back to his car. And we 2 went up to the, we went up to Anna's room and he just -- 3 we just said bye. 4 Q. And did you receive anything at all of 5 value from this man? 6 A. No. 7 Q. Did you charge him anything? 8 A. No. 9 Q. Were you paid anything for the time you 10 spent with him? 11 A. No. 12 Q. Now, who's Robert Fredrick Burke? 13 A. Robert Fredrick Burke, I have no idea. 14 Q. Well, on the next day on Wednesday, 15 February 3rd, did you go sightseeing again? 16 A. Yes, we did. 17 Q. And you said that this fellow Bobby came 18 to see you at the apartment sometime the morning of. 19 Wednesday, February 3rd? 20 A. He came to see us, uh4tuh. Pm not sure what 21 time it was. I think it was around in the afternoon. 22 . Okay. And then after he kit, you and 23 did some more sightseeing? 24 A. Yeah, we walked around town. 25 Q. Do you remember getting in a vehicle with 7 (Pages 523 to 526) PROSE COURT REPORTING AGENCY; INC. (561) 832-7506' Electronically signed by Cynthia hopkins (601451476-2934) Electronically signed by cynthla hopkins (601.051-976-2934) Electronically signed by synth's hopkins (601.061.976.2934) b55421of-d299-4e41-9b416.85ead2714405 EFTA01108858 Page 527 Page 529 1 somebody that night? 2 A. Yes. 3 Q. Who did you get in a vehicle with? 4 A. I told you, I don't know his name. 5 Q. Well, where did you, where did you meet 6 this person? 7 A. Everybody was Alma's friend. Anna has a lot 3 of friends. 9 Q. Well, what did you know about the person? 10 A. Nothing. 11 Q. How old is the person? 12 A. I told you, I don't know anything about him. 13 Q. And what kind of vehicle did you get in? 14 A. I don't even know the vehicle. 15 Q. Toyota Highlander? 16 A. (sit — I don't know. 17 Q. And what nationality is this individual? 18 A. I have no idea. 19 Q. And where did this individual take you? 20 A. He took us to sightseeing and he took us to 21 the Statue of Liberty, everywhere. 22 Q. Did you receive anything of value from 23 him? 24 A. No. 25 Q. Did you charge him anything? 1 A. I have no idea. 2 Q. Were they a male's clothes or female's 3 clothes? 4 A. I didn't search through the garbage. I just 5 know that I threw out the trash. 6 Q. So you're telling me you don't know whose 7 they were? 8 A. No. 9 Q. Okay. Do you know 10 A. Yes, Id°. 11 Q. And how do you know 12 A. We grew up together. Firer ably 'mew her since 13 1 was 12. 14 Q. Have you ever been engaged in any kind of 15 a business venture, regardless of whether it was a 16 formally formed business venture like a corporation, 17 but any kind of business venture with .M? 18 A. I went, we went to Jeffrey's togWer. 19 Q. My other kind of business venture, you 20 and heft 21 A. No. 22 Q. Were you ever, did you ever represent or 23 attempt to start a business venture with her? 24 A. This is years ago. 25 Q. How many years ago? Page 528 1 A. No. 2 Q. You or El? 3 A. I did not charahim anything. 4 Q. How about ? 5 A. I don't know what she does but, no, I don't 6 think so. 7 Well, was there ever a time that you and 8 were not together in this person's presence? 9 A. Other than me going to the restroom, no. We, 10 I, we were pretty much together the whole time. 11 Q. On the evening of February 3rd, 2010, do 12 you recall throwing a bag of trash in the garbage? 13 MR. EDWARDS: Mat date is that? 14 MR. LUITIER: The evening of February 3rd, 15 2010, at approximately 9:00 p.m. 16 THE WITNESS: In the evening. 17 MR. LUTHER: Just before you got in the 18 Toyota Highlander. 19 THE WITNESS: Yes, we did. 20 BY MR. WITTER: 21 Q. Okay. And do you recall what it was that 22 was in that bag? 23 A. There was whole bunch of clothes and 24 everything that Anna did not want, so we threw it out. 25 Q. And whose clothes were those? Page 530 1 A. Well, 13, 14, 15, like eight years ago. 2 Q. Okay. So, this is 2010. We're talking 3 about 2002? 4 A. Yeah. 5 Q. Okay. So tell us about the venture that 6 you were forming with her? 7 A. I don't know what you're talking about. 8 Q. Well, you were thinking about something 9 because you said years ago. You were the one that 10 picked the date. So, what was it you were thinking 11 about? 12 A. No, I said years ago we, we knew each other. 13 We used to hang out. Like we used to do little girl 14 stuff, go in the pool and — 15 Q. No, my question was, was there a business 16 venture and you said it was years ago. 17 A. It was years ago that I've known her. Any 18 type of business venture, not that I recall. 19 Q. Have you ever told anyone at all that you 20 and were forming a business venture or had a 21. business venture? 22 A. At 12, no, I don't — 23 Q. At any, I don't care, right up until 24 today. 25 A. No. 9 (561) 832-7500 PROSE COURT REPORTING AGENCY, 8 (Pages 527 to 530) INC.' .(561) 832-7506 Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (001-061.976.2934) b55421ef.d299-4e4f-9bat3-85aad2714405 EFTA01108859 Page 531 1 Q. Did you ever have any sort of a business 2 venture that involved in any way, shape, or form you 3 and/or her taking showers? 4 A. No. 5 Q. Did you ever tell anybody you did? 6 A. No. 7 Q. Did you ever have any literature or 8 written material describing such a venture? 9 A. Not that I recall, sir. 10 Q. Ever have anything that described such a 11 venture or any costs associated with procuring those 12 services if someone wanted to do that? 13 A. Taking showers? 14 Q. Well, taking showers or watching the two 15 of you take showers or any combination or 16 permutation that you can think of. 17 A. Not that I can think of unless we were like 18 stupid little girls who — I don't recall anything about 19 any shower or anything like that, no. 20 Q. Did you ever tell anybody that you had 21 such a business going? 22 A. No. 23 Q. Did you ever tell anybody you had such a 24 business going with someone other than e? 25 A. A business going, no. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 532 Q. I don't mean a formal thing, Did you ever tell anybody that you were involved in any kind of activity involving taking showers for which you got paid money? A. Definitely not. I don't — I have never. And when was the last time you talked to A. Oh, boy. It's been years. Ballpark three years maybe. Q. And where did you talk to her three years ago? A. At the trailer that I had an at. Q. Now, your other friend, A. Uh-huh. Q. — when is the first time that you can recall having done any type of a drug with..? A. When we first started seeing Jeffrey we tried to numb each other with like downers, you know, Percocets or something just to ignore really what was going on between Jeffrey and us. deposition you toll = wn first took you at testimony? sir, a tha who we know to be to Jeffrey's. Do you recall A. Yes. (561) 832-7500 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 533 Q. And you testified that she provided you with drugs? A. Yes. e Q. All right. Now, who provided the drugs to A. I have no clue. Q. Well, who provided the drugs to you that you just claim you took when you were with A. I couldn't even say. Maybe, maybe Q. That's your boyfriend? A. At the time he was my boyfriend. Q. Well, he was your boyfriend. He became the father of your child, right? A. Yes. Q. Okay. I mean, that would qualify as a boyfriend, right? A. If that's what you call it Q. He was a drug dealer, wasn't he? A. No. MR. EDWARDS: Form. BY MR. LUTHER: Q. Did he provide drugs to you on more than one occasion? A. No, he, no, he, if anything, him and his Page 534 1 friends got together and they were stupid and young and 2 they did a couple of drugs, but I didn't want anything 3 to do with them until I met Jeffrey. And then I wanted 4 to numb myself to be around Jeffrey. And I know that I 5 would take drugs from him occasionally. 6 But he didn't like give them tome or sell 7 them to me or anything like that. 8 Q. Well, what did you do, go steal than from 9 him or what? 10 A. I would probably take him from his stash or 11 something but — 12 Q. So, he had a lot of drugs? 13 A. No, not that I remember. I don't know where I 14 got these drugs from. To telLyau the truth, I really 15 don't recall. I don't blow if.. brought them. I 16 don't blow if I brought them. 17 Q. Well, did you give these drugs toe.? 18 A. No, not that I recall. 19 Q. One thing you knew was that these were 20 illegal drugs, right? 21 A. Yes. 22 Q. You knew it was against the law what you 23 were doing? 24 A. Yes, especially — Jeffrey Epstein knew it was 25 against2.11:jaw to be fondlin 14-yearold girls g 9 (Pages 531 to 534) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601.061.976.2934) Electronically signed by cynthia hopkins (601.061.976.2934) Electronically signed by cynthia hopkins (601.061.976.2934) b5542fel-d299-4e4f-9ba6.85aad27,4405 EFTA01108860 Page 535 1 too. 2 MR. LUTHER: Well, Jeffrey Epstein -- 3 move to strike as not responsive. 4 BY MR. LUTHER: 5 Q. What Jeffrey Epstein told you was that you 6 shouldn't drink and shouldn't do drugs, didn't he? 7 A. He told me that he never drank or did drugs. 8 He was so interested in what kind of drugs we were on. 9 Q. So, not withstanding what you knew to be 10 clear/y-- 11 A. He would ask, he would be asking us so how 12 does =make you feel, how does coke make you feel, 13 how does Percocets make you feel, how does this make you 14 feel. 15 Q. He never asked you to take any of those 16 drugs, did he? 17 A. No, but he would — 18 Q. He never gave you any of those drugs. did 19 he? 20 A. No. 21 Q. And you claim he had all this money. He 22, could have provided you with any drug he wanted if 23 he wanted to give you a drug, couldn't he? 24 A. I guess. 25 Q. And he never provided you with one single 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 537 1 A. Probably. all ow, you remember going there with don't you? A. Yes, l do. Q. Two occasions you went and she went in the room with you, didn't she? A. She went in the room with me at the beginning, at the first time, yes. Q. Went in the room the second time too, didn't she? A. I, I think so. I'm not sure about that. Q. Are you aware that — A. I bet you have pict huh. Q. Are you aware tha en deposed? A. Have been what? Q. Has been deposed, gone through the same process you are? A. Oh, yes, of course. She should be. Q. How are you aware of that fact? A. Excuse me? Q. How are you aware of that fact? A. Everybodys been deposed. Most all, most of all these girls have been deposed. Q. Who told you that? A. You know, the girls talk. Page 536 1 illegal drug and told you he never touched drugs? 2 A. No, but that's not his crime. He fondled me 3 when I was 13 years old. He didn't sell me drugs. 4 Sony, he just molested me. MR. LUTTIER: Move to strike. 6 BY MR. LUT17812: 7 Q. He never provided you with one illegal 8 drug, did he? 9 A. No. 10 Q. You went and got those all on your own? 11 A. Yes. 12 Q. You and your friends would go and take all 13 kinds of illegal drugs? 14 A. Yes, because I was scared to be around an old 15 man when he is touching my vagina and masturbating with 16 his cock in front me ejaculating all over himself, so 17 yes, I would, I think you would take drugs too. 18 Q. So, were you so scared that you said I'm 19 not going anymore? 20 A. He was like our master. He's like= 21. master. He does, anything he says, we do 22 because we are intimidated by him. We were scared of 23 him. 24 Q. So, if he said run out in front of 24 25 traffic, you would? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (561) 832-7500 Page 538 1. Q. Okay. 2 A. It get's around town and it's in the newspaper 3 every weekend, so how not know? 4 Q. Did you talk to 5 A. No, I did not. 6 Q. Okay. So, how did you know al had 7 been deposed if she was deposed? 8 MR. EDWARDS: Object to the form to the extent — THE WITNESS: Of course she's been deposed. MR. EDWARDS: Hold on. Hold on — to the extent that you're asking for attorney-client privilege information which you did — MR. LUMER: No. MR. EDWARDS: - in the first deposition and it sounds like you're going there again — MR: LUTHER: I don't want to know anything your lawyer said. MR. EDWARDS: — about talking to my client BY MR. LUITIER: Q. I don't want to know anythi wyer said. Have you seen a transcript of 10 (Pages 535 to 538) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051.976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) b5542fehc1299-041-9ba6-85aad27f4405 EFTA01108861 Page 539 1 MR. EDWARDS: Object to the form. If she 2 has seen a transcript, that would obviously 3 being something that her attorney has shown 4 her. That is not something she would have seen 5 independent of that. So that would be 6 protected information. 7 MR. LUTITER: I, I mean, I don't think — 8 I think if you show her a copy of a deposition, 9 that is not protected by attorney-client 10 privilege. If you had a discussion with her, I 11 agree with you, whatever your discussions were. 12 But the fact that you showed her the transcript 13 I don't think is protected by the privilege. 14 BY MR LUTTIER: 15 Q. Havesher seen a co y of the 16 transcript of deposition? 17 A. Not that I Icnow o 18 Q. Well, did u know that -- or strike that 19 as and 20 were wit .Epstein on t e secon 21 occasion when she took you there, isn't it true that 22 you began a conversation with Jeffrey discussing 23 what you and your mother did and how much you 24 charged for various things? 25 A. False. Page 1 A. Am I religious? 2 Q. No, do you have a religious affiliation? 3 'Are you associated with a particular faith? 4 A. Yes. 5 Q. Protestant, Catholic, Jewish? 6 A. Yes, I am. 7 Q. What faith would that be? 8 A. I believer in Jesus Christ. 9 Q. Any particular organized -- do you know 10 what I mean by organized religion? There's, theres 11 a bunch — 12 A. !would Ince to call myself a Christian but 13 believe that the Lord, Catholics, Jews, Buddhism, it 14 doesn't matter because it shouldn't be judged. It 15 shouldn't be organized. The Lord doesn't — the Lord 16 doesn't organize anything. I just know that I am, I am 17 very spiritual and I do love the Lord very much. 18 Q. Okay. So you would characterize yourself 19 just as a, for lack of a better term Christian? 20 A. lam very spiritual. 21 Q. Okay. 22 A. And I pray every day. 23 Q. Do, do you participate it an organized 24 religion? 25 A. Do I go to church? Page 540 1 Q. Sexual nature. 2 A. No. 3 Q. Is there any reason why 4 would want to make that story II. 5 MR. EDWARDS: Object to the form. 6 THE WITNESS: I have no idea. 7 BY MR. LUTTIER: 8 Q. And isn't it true that when you began — 9 A. She knew Jeffrey more than I did. 10 Q. Well, didn't -- 11 A. This is the first time or second time I had 12 ever been with Jeffrey. I didn't tell him anything; 13. only the questions he asked nte. 14 Q. And, and isn't it true that when you began 15 to talk to Mr. Epstein and discuss with him what you 16 and your mom did and the prices you would charge for 17 things that Mr. Epstein asked Ms. to leave 18 the room? 19 A. I don't even know why my mother is brought up 20 in this because, no, I would never talk about my mother 21 as being a prostitute. She did not raise me like that. 22 My mother is a very beautiful person inside and out and 23 she would never raise me like that. 24 Q. By the way, what is your — do you have a 25 religious affiliation? (561) 832-7500 PROSE Page 542 1 Q. Yeah. 2 A. Yes. 3 Q. And where did you go? 4 A. I've been to Christ Fellowship. I've been to 5 First Baptist. 6 Q. When was the last time you were at Christ 7 Fellowship? 8 A. In December '08. 9 Q. And where did you go, for Christmas? 10 A. Before Christmas. 11 Q. Okay. And when was the last time you were 12 at First Baptist? 13 A. Maybe September '08. 14 Q. Okay. Are you members of either of those 15 churches or you just went to them? 16 A. If you want to call me a member, I — 17 Q. Are you a registered in them? 18 A. — I attend, I attend Christ Fellowship, yes. 19 Q. Do you attend it with some degree of 20 regularity? 21 A. Yes. 22 Q. And how often? 23 A. As often as I can. 24 . Q. Okay. Well, I mean, I don't want to pin 25 ~rou ecific er of days, many 11 (Pages 539 to 542) COURT REPORTING AGENCY, INC. (561)'832-7506 Electronically signed by cynthia hopkins (601451.976-2934) Electronically signed by cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (601-051476-2934) b5542lef-d299-4c41-9ba6-85aad2714405 EFTA01108862 Page 543 1 days a month would you say on average you go? 2 A. As of tight now, one, unfortunately. 3 Q. And when you say unfortunately, are you 4 unable to go more days? 5 A. No, I would love to go more days. 6 Q Okay. Was there something that prevents 7 you from going more days? a A. I have a busy life. 9 Q. Okay. What is it that you're doing that 10 prevents you from going more days. 11 A. Well, lam trying to get my son enrolled into 12 Christian school, and there's a lot of bills that need 13 to be paid and things that need to be done, errands that 14 need to be ran, clothes that need to be washed, food 15 that needs to be bought, time I need to spend with my 16 son. 17 Q. So, it's errands and clothes, laundry, 16 purchasing groceries and stuff, and time with your 19 son that prevents you from being able to attend more 20 frequently; is that right? 21 IVIR. EDWARDS: Object to the form. 22 THE WITNESS: Stn. 23 BY MR LUTHER: 24 Q. You set your own work hours, right? 25 A. Yes. Page 545 1 A. You guys have been there before. You should 2 know. 3 Q. It's the same house she's always lived in? 4 A. No. She hasn't lived there her whole life. 5 Q. Okay. But I mean while you were a kid, 6 when, when you were living with her; is it the same 7 place that she lived in? 8 A. No. 9 Q. How long has she been living where she is 10 now? 11 A. I don't know. There's been a couple of years 12 that my mother and I haven't talked. 13 Q. Well, when was the last time you talked to 14 your mother? 15 A. Today. 16 Q. And, and when did you talk to her? 17 A. This morning. 18 Q. And why did you talk to her this morning? 19 A. So she could pray with me over the phone. 20 Q. And when was the last time you talked to 21. her prior to this morning? 22 A. Last night 23 Q. Did I misunderstand? I thought you said 24 there was a - 25 A. There was a period in my life that we didn't 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 544 Q. Your mother i and I may get this name sort of is it? A. Yeah. Q. Did I pronounce it right? A. No. Q. Ilow you do pronounce that? A. . And is she currently married? A. No. Can I have a tissue? Q. And where does she currently live? A. In Palm Beach Gardens. Q. In what development? A. I don't know what the development's called. MR. EDWARDS: Can we take a split second break to take grab a tissue? MR. LUTTIER: Sure. MR. EDWARDS: I don't see one right now. THE VIDEOGRAPHER: Going off the record at 228 pm. (A brief recess was held.) THE VIDEOGRAPHER: We're back on the record at 2:32 p.m. BY MR. LINTER: Q. Okay. You're saying you don't know the development that she lives in Palm Beach Gardens? Page 546 1 talk. 2 Q. Okay. So that's some past period of time? 3 A. Yes. 4 Q. When did that change? 5 A. Around May '09. 6 Q. And what is it that caused the change in 7 May of '09? 8 A. I was living my life and she was living hers. 9 Q. What does that mean? 10 A. I was living my life and she was living hers. 11 Q. Okay. Why did that, why did that 12 facilitate — 13 A. She was taking care of my sister that has 14 diabetes and they were going through a lot, so I left it 15 alone. 16 Q. My question was what caused in May of '09 17 this period of estrangement between you and your 18 mother to end? 19 A. I just told you. 20 Q. You said that your mother — 21 A. My mother and I, she had — my mother was 22 taking care ofkiter who has severe diabetes. 23 Q. That's 7 24 A. Yes. 25 S. Oka You mean duri our riod of (561) 832-7500 12 (Pages 543 to 546) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) b66421442094•41-91x446a.0741405 EFTA01108863 Page 549 Page 547 1 estrangement? 2 A. Yes. 3 Q. Okay. So, you didn't communicate with her 4 because she was taking care of your sister? 5 A. Yes. 6 Q. Did something happen in May of '09 that 7 changed all that? 8 A. My sister moved away. 9 Q. And where did she go to? 10 A. Orlando. 11 Q. And, and when she moved, did she go with a 12 boyfriend? 13 A. Yes. 14 Q. And who is that? 15 A. Rs name is David. 16 Q. Do you know his last name? 17 A. No. 18 Q. And she's still living in Orlando? 19 A. Yes. 20 Q. Now, what's the relationship between you 21 and your sister? 22 A She's, she has like she's a little slow, so 23 we can't really relate but other than that I love her. 24 Q. Well, haven't you in the past been violent 25 toward your sister? Page 548 A. Yeah. 2 Q. And tell us exactly what you did to your 3 sister. 4 A. Well, when I was 14, 15, 14,1 was like 5 mentally abusive to her because I guns I was just taking out everything, all of my pain from what was 7 going on with Jeffrey, and I would just take it out all 8 on her. 9 Q. What do you mean by you would take it out 10 on her? 11 A. I was mentally abusive to her. 12 Q. Well, describe what it is you actually 13 did. 14 A. She stuttered; l would make fun of her. She 15 has diabetes; I wouldn't respect it. 16 Q. And did your sister actually have to get a 17 restraining order against you? 18 A. No. 19 Q. Did your sister ever get a restraining 20 order against you? 21 A. Not that I know of. She's slow. She's not 22 all there. She has like part autism. 23 Q. Now, did your mother discuss with you 24 about whether she ever had any discussions about you 25 withanybodyelse? (561) 832-7500 1 A. Excuse me? 2 Q. Did your mother ever discuss with you 3 whether she had any conversations about you with 4 anybody else with respect to this lawsuit? 5 MR. EDWARDS: Is this in addition or 6 different than the previous discussion that was 7 discussed at the first deposition? 8 MR. LUTHER: I won't know until she 9 answers it. 10 MR. EDWARDS: But is this a separate 11 occurrence from what she was asked at the last 12 deposition? 13 THE WITNESS: No, she's never discussed 14 anything else with anyone else, no. 15 BY MR. LUTHER: 16 Q. Okay. 17 A Not to my knowledge. 18 Q. And if your mother told anybody that 19 historically as a child you used Xanax, would she be 20 telling the truth? 21 A. Yes. 22 Q. Do you who• 23 A. Yes, Id°. 24 Q. And who is that? 25 A. Her current boyfriend. is? Page 550 1 Q. And do you believe him to be a truthful 2 individual? 3 A. Yes. 4 Q. And how long has he known your mother? 5 A. For 15 years. 6 Q. Do you know of anything he has told 7 anybody else about what it is your mother used to do 8 fora living? 9 A. No. 10 Q. Is the first time that you've heard any 11 reference to your mother being a prostitute in this 12 case? 13 A. No. 14 Q. When else have you heard that? 15 A. I have never heard that my mother was a 16 prostitute. 17 Q. So, what I am saying is, is the first time 18 that you have heard that issue even come up in this 19 case? 20 A. This is the first time 1 am hearing this, yes. 21 Q. Did you discuss with your mother the 22 activities you were engaging in with Mr. Epstein at 23 the time that you were engaging in them? 24 A. I kept everything a secret until years later 25 when after I had my son and then 1 told her what went j 13 (Pages 547 to 550) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthla hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) b55421cf-d299-4e4(-9ba6-85aad2714405 EFTA01108864 Page 551 1. on. 2 Q. Earlier you said at 15 you worked for 3 Jamie's photo studio? 4 A. Yes. 5 Q. And my notes are unclear. I believe I 6 asked you, did you tell them how old you were. Do 7 you remember me asking you that question? 8 A. (Witness nods head). 9 Q. And what did you respond? 10 A. I told the.m1was 19. 11 Q. Okay. Did you provide them with any kind 12 of proof? 13 A. No. 14 Q. And why did you lie to them and tell them 15 you were 19 if you were really 15? 16 A. Because! wouldn't be able to work there. 17 Q. Did you tell other people that you were 18 older than you really were? 19 A. Yes. 20 Q. Who else did you tell you were older than 21 you really were? 22 A. Probably everybody I came across. 23 Q. So, that would be many people? 24 A. Yes. 25 Q. All of the various adult entertainment 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 553 THE WITNESS: I worked at Jamie's photo studio. Once I turned 18, I told everybody my BY MR. MR. LUTHER: Q. Well, you worked at a place called Cabaret when you were 14, didn't you? A. Curves Cabaret. I told them I was 19 as well. Q. When you were how old, 14? A. Yes. Q. Okay. And then what, what was the next place you did, you went to do topless dancing? We'll do jack shacks separate front topless dancing. A. I don't know. I worked at Curves Cabaret when I was 14. I worked at Jamie's photo studio when I was 15, and I worked for Jeffrey throughout all those years. Q. You worked fora lot of other places besides Jamie's photo studio and Curves Cabaret, didn't you? A. Not when 115. Q. Well, I want to start there and keep on Pin& A. We already know the places I've worked at. We've been through this. We've went through this for the last deposition. Q. That's why — Page 552 1 places you worked at. The places, the topless bars 2 you worked at, did you tell all of them you were 3 older than you really were? 4 A. The period of time when I worked at Jamie's 5 photo studio, I told everyone 1 was 19. Jeffrey knew 6 how old I was. And Jeffrey new how old every girl I 7 brought there was, and he wanted young girls all the 8 time. 9 Q. Does that have anything to do with the 10 question that I asked? 11 MR. LUTT1EFt: I move to strike. 12 THE WITNESS: The question you asked has 13 nothing do with Jeffrey. 14 MR. L1JTTIER: Let's, let's go back. If 15 you will read the question that I asked. If 16 you will listen to this question, that's the 17 one I would like you to answer. 18 TILE WITNESS: I know you guys love to get 19 paid but — 20 (The requested portion of the record was 21 read by the reporter.) 22 THE WITNESS: At what period of time? 23 MR. LUTTIER: At any time. From the time 24 you first worked at one to the last time you 25 worked. (56]) 832-7500 Page 554 1 A. And we've already been through this for this 2 deposition. 3 Q. — I am giving you the chance to 4 sturunarize, so let's just go down and — 5 A. You already know the places I worked. 6 Q. I am asking you as to each one, how old 7 you told them you were. 8 A. When 1 was underage, I told them I was 19 9 years old. 10 Q. Every place that you worked? 11 A. Yes. Except Jeffrey's, Jeffrey knew that I 12 was 13. I'm sick of this. 13 Q. So, at Abby's you told them 19. Is that 14 just the number you picked? 15 A. On advice of counsel I am invoking my Fifth 16 Amendment rights under the United States constitution. 17 MR. EDWARDS: Do you want to take a break 18 or are you all right? 19 MR. LIMIER: Yeah, do you want to take a 20 break.? 21 THE WITNESS: No. I want to get this done 22 and over with. lam sick of it. Jeffrey is — 23 it's disgusting. 24 BY MR. LUTTIER: 25 Q. Flirts you told them you were 19? 14 (Pages 551 to 554) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by Cynthia hopkins (601-051-976.2934) b5542101-d299-4e41-9ba6.65aad27(4405 EFTA01108865 Page 555 A I was — on advice of counsel, l am invoking 2 my Fifth Amendment rights under the United States 3 Constitution. 4 Q. Lennie's, whatever, Laurie's, whatever it 5 was, you told them you were I9? A. Lauren's. Q. Lauren's, whatever. A. I was of age. 9 Q. Okay. How about when you were at Pure 10 Platinum, were you of age then? 11 A. Pure Platinum. 12 Q. Platinum Showgirls? 13 A. Yes, I was of age. 14 Q. And how about Elegance Day Spa, were you 15 of age then? 16 A. On advice of counsel I invoke my Fifth 17 Amendment rights under the United States Constitution. 18 Q. Did you work at Elegance Day Spa? 19 A. On advice of council I'm invoking my Fifth 20 Amendment rights under the United States Constitution. 21 Q. And what work did you do at Elegance Day 22 Spa? 23 A. I'm over this shit. 24 MR. EDWARDS: Let's take a break. 25 THE WITNESS: No. On advice of counsel I 1 a — 2 A. 3 Q. 4 A. 5 Q. 6 A. Yes. — store? Yes. And that was upsetting to you? Yes. Page 557 7 Q. Why was it upsetting to you? 8 A. i was trying to say hello sa little sister 9 who was three at the time. And was mad at my 10 father and she didn't want me talking to my little 11 sister. So, she doesn't know the American rights 12 because she's from Mexico and she totally mazed me when 13 I was trying to hug my little sister. 14 (Mr. Goldberger entered the deposition 15 room.) 16 THE WITNESS: Utast hope Jeffrey gets 17 what he deserves. 18 BY MR. LUTTIER: 19 Q. And what's that, Ma'am? 20 A. Punishment for putting us girls through all 21 this. 22 Q. That is those things that you are talking 23 about the times that you elected to go back to his 24 house and get paid to give him massages? 25 A. He demanded us to over the phone, sir. Page 556 1 am invoking my Fifth Amendment rights under the 2 United States Constitution. 3 BY MR. LUTHER: 4 Q. Are you fearful that you're going to be 5 prosecuted for something about Elegance Day Spa? 6 A. No. 7 Q. So, well then, what are you asserting the 8 Fifth Amendment for? 9 A. Because I want to. 10 Q. Because what? 11 A. Because I want to. 12 MR. EDWARDS: Listen, don't engage with 13 him. Just read. 14 BY MR. LUITIER: 15 Q. Do you know 16 (phonetic). 17 A. I know a 18 Q. Okay. And who is that? 19 A. My step-mother. 20 Q. Married to your father,_? 21 A. Yes, sir. 22 Q. And have you had a confrontation with her? 23 A. What kind of confrontation is this now? 24 Q. Did you ever have a confrontation with 25 here physical confrontation in the parking lot of (561) 832-7500 Page 558 1 Q. But nobody made you do it, right? 2 A. No. But Jeffrey demanded us for us to do it. 3 And as young girls we were scared ofJeffrey. And you 4 'mow what, be will get what be deserves. 5 Q. Let's see. You lived out Okeechobee by 6 Drexel Road? 7 A. Yes, I did. 8 Q. He lived in Palm Beach? 9 A. Yes. 10 Q. How many miles was it, would you say 11 between those two houses? 12 A. I don't know, five, six. 13 Q. And you didn't, you didn't have a car 14 because you weren't driving, right? 15 A. No. He sent taxies to my house to come get 16 me. 17 Q. So, then you could have said I am not 18 getting in any of the taxies you wanted me to. You 19 could have said I'm not going, just like a bunch of 20 your friends did, right? They said after, boom, I 21 don't want to go anymore, right? 22 A. I could have said no. 23 Q. As a matter of fact you had friends that 24 you took, you found them, Jeffrey Epstein didn't 25 find them, you found them. J 15 (Pages 555 to 558) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkIns (601-051-976-2934) Electronically signed by cynthia hopkIns (601-051.976.2934) Electronically signed by cynthia hopkIns (601.051-976-2934) b5S42lot-d299-4e4f..9ba6-85aad27f4406 EFTA01108866 Page 559 1 A. Yeah. Because he wanted me to find them. He 2 said you better find me a girl the next day, or I am not 3 going to call you anymore. 4 Q. And you took them to Jeffrey Epstein's and 5 you told them don't worry, this is what's going to 6 happen, ifs easy money, right? 7 A. Yeah, because I was tried of Jeffry. 8 Q. And some of those girls went one time and 9 said they didn't want to go back, right? 10 A. Correct. Because they ;we afraid of Jeffrey. 11 Q. And you could have done the same thing, 12 couldn't you? 13 A. Correct. 14 Q. But you wanted the money? 15 A. I was a poor little girl who couldn't even 16 afford a pair of shoes, yes. 17 Q. You wanted the money? 18 A. Yes. 19 Q. And net only did you want the money but 20 you wanted to make money taking other girls there? 21 A. Yes. 22 Q. Now, you allege in your complaint that's 23 the, the pleadings that you have filed in this case, 24 that you have suffered physical injury and a bunch 25 of other things. What physical injury have 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 561 mental damage, and red marks on you as a result of anything that Jeffrey Epstein did, if any? A. Physical? Q. Yes, physical. A. Not mentally -- Q. I am going to come to that. A. — or psychologically? Q. Physical injury. A. Physically, well, now I can't — lam not even anormal person anymore. My mentality is totally different. Q. So, how does that -- A. I was molested for years. Q. How does that physically evidence itself? A. I don't know. You tell me. You get molested for years and tell me how you feel. Q. Well, I'm asking you, you're the one that filed the complaint and alleged that you have suffered physical injuries in the past. You've told us that -- A. If you're asking me if the guy has ever hit me, no. Q. No. I am asking you — A. Smacked me on my butt a couple times. Q. I need to find out what you are alleging Page 560 1 suffered in the past as a result of anything that 2 Jeffrey Epstein did? 3 A. Stress, my heart, mental damage. 4 Q. My other physical injury? 5 A. Besides the red marks he would leave on my 6 pussy. 7 Q. And how would he do that? 8 A. He left red mutts on my vagina with his 9 fingers, with his vibrator. 10 Q. And how did that injure you? 11 A. Well, it kind of hurt. 12 Q. Did you tell him that? 13 A. No. I was scared to tell him anything that he 14 didn't want to hear. 15 Q. Did you seek medical treatment for that? 16 A. No. 17 Q. What other physical injury do you allege 18 you suffered as a result of anything that Jeffrey 19 Epstein did? 20 A. Stress, stress, and more stress. 21 Q. Anything else? 22 A. No. 23 Q. Do you allege that -- and I should break 24 that down. What physical injuries due you allege 25 you suffered in the past other than stress heart, 561 ) 832-7500 Page 562 1 so I can defend it. So, what physical injuries, if 2 any, other than stress, heart, mental damage and red 3 marks? 4 MR. EDWARDS: Objection, asked and 5 answered. 6 BY MR. LUTHER: 7 Q. inhere isn't any, fine. If there is 1 8 want to get them that's all. Do you know of any 9 others? 10 A. No. 11 Q. All right. You allege that you're going 12 to suffer in the future physical injury that's 13 physical injures that you haven't suffered yet. 14 Well, what physical injury do you allege you will 15 suffix in the future as a result of anything that 16 Jeffrey Epstein did? 17 A. Fucking heart attack. 18 Q. Heart attack. Anything else? 19 A. Mental stress. 20. Q. Mental stress. Anything else? 21 A. All day, every day. My son is going to suffer 22 from it beranse I'm suffering from it. 23 Q. Okay. And you're son is going to suffer 24 from what? 25 A. He can feel his mother's stress. 16 (Pages 559 to 562) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506. Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) b55421of-d299.4c41-9ba6-85aad2714108 EFTA01108867 Page 563 1 Q. Any, anything else? 2 A. Physically, no. 3 Q. All right. Have you obtained any medical 4 care or treatment in the past for any physical 5 injury that you allege you suffered as a result of 6 anything Jeffrey Epstein did? 7 A. No. He told me if I tell anyone what is going 8 on it's going to be, I'm going to be in trouble. So, I 9 would not dare tell anybody what Jeffrey did to me. 10 • Q. Did you ever go to any doctor or healer of 11 any kind, person, whether it was a chiropractor or 12 anything else, with respect to treatment of any 13 injury that you allege you suffered in the past as a 14 result of anything that Jeffrey Epstein did? 15 A. In the past? 16 Q. Yep. 17 A. No. 18 Q. Have you incurred any medical expense at 19 all as a result of any physical injury you allege 20 you suffered in the past as a result of anything 21 Jeffrey Epstein did? 22 A. No, but he still molested me for years. 23 Q. He what? 24 A. He still molested me for years. Sony he is 25 not a physical abuser, you know, or a whatever, a 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 565 responsive. Please, listen to the question. The court reporter is going to read it back and just answer my question. (The requested portion of the record was read by the reporter.) THE WITNESS: No. BY MR. LUTTIER: Q. Has any person with professional knowledge or expertise told you that you're going to suffer mental stress in the future as a result of anything Jeffrey Epstein did? A. Yes. Q. Who? A. Q. ? A. n P ow E her last name, but she's a counselor. AA. frier name? Q. Victim's Services lady? A. Yep. Q. And when did you see her last? A. I don't know the dates, sir. Q. Well, in last year? A. Yep. Page 564 1 violent, you know — 2 Q. Have you gone -- 3 A. - VA)111231beater. 4 Q. Have you gone to any doctor at all with 5 respect to any physical injury that you allege you 6 suffered in the past as a result of anything that 7 Jeffrey Epstein did? 8 A. No. Because I was afraid of the man. I 9 didn't know what he would do to me. He was powerful to 10 me. He was like a master to me. Anything he said I 11 would do. 12 Q. Now, you allege that the physical injury 13 you're going to receive or you're going to suffer in 14 the future is a heart attack. Has any person with 15 professionalized, with professional knowledge or 16 experience told you that you're going to suffer a 17 heart in the future because of anything that Jeffrey 18 Epstein did? 19 A. Anybody that knows that so much stress and so 20 much heartache each and every day worried about what you 21 are doing and worried about, you know. who, how this guy 22 managed me in the past, that's stress. And yeah, you 23 can definitely suffer from a heart attack or a stroke or 24 panic attacks, anything. 25 MR. LUTTlER: Move to strike. Not 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 566 Q. Did you say, yes? A. Yes. Q. How many times -- A. Not 2010 but '09. Q. '09? How man times did you see her? A. And i has told me the same thing. Q. How es r av ie you see her in '09? A. Three. Q. Do you go with any degree of regularity? A. No, but I'm going to. Q. Have you gone to her -- how many times have ou gone in total to her, that is .tir.ft times. Q. And the last time was sometime in '09? A. Yes. Q. When was the first time? A. '09, I guess, or '08, '08. Q. And then you sec' last time you saw A. In '09. Q. How many times have you seen her? A. Three. Q. When was the first time? A. In '09. When was the (562) 832-7500 17 (Pages 563 to 566) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthla hopkins (601-061.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) b5542let-6299-4e41-9ba6-85aad27(4406 EFTA01108868 Page 567 1 Q. Okay. And I believe at the last 2 deposition you said you had seen her twice. Do you 3 recall that? 4 A. Yeah. I saw her three times though. 5 Q. Okay. So, you have seen her one more 6 time? You have seen her once since your deposition 7 on September 24th '09? 8 A. Yes. She came to my house. 9 Q. Since September 24th '09? 10 A. Since September 24th. 11 Q. And for what reason — I can't hear what 12 you're saying. Did you say she did come to your 13 house since September 24th, '09? 14 A. I don't know the dare, sir, but I did a whole 15 psychological paper. 16 Q. Well, last time in your deposition you 17 testified you had seen her twice. That one time you 18 saw her on Clematis — 19 A. Yeah. 20 Q. — in somebody else's office and you 21 thought you had done some sort of evaluation. Do 22 you recall that testimony? 23 A. Yes. 24 Q. All right. That, that would have been one 25 time. That was the second time. Where, where did Page 569 1 Clematis Street? 2 A. That's the last time I saw her. She came to 3 my house. 4 Q. Okay. So, she's been to your house twice? 5 A. From what I recall, yeah, but I can't 6 remember. 7 Q. Did she go to the apartment that you live 8 in now? 9 A. Yes. 10 Q. Previously, did she come out to a trailer 11 where you live, or did she come to the same 12 apartment that you live — 13 A. I don't live in a trailer. 14 Q. So, both times that she came to your house 15 she's come to the apartment that you live in now? 16 A. Yes, if she came two times. I might have saw 17 her two times or I might have saw her two, three, who 18 cares? 19 Q. For the last, on the last — 20 A. You drive me crazy. 21 Q. — time she came for what purpose did she 22 come? 23 A. For an evaluation to counsel me. 24 Q. Well, are those things in your mind the 25 same? Page 568 1 you see her the very first time? 2 A. In the office. 3 Q. Whose office? 4 A. Her's. 5 Q. Where is that? 6 A. The place you just named. 7 Q. Well, an office on Clematis? 8 A. Yes. 9 Q. All right. So, you saw her there once and 10 then you went back and saw her at that same office 11 the second time on Clematis Street? 12 A. I think I had to go back there. It might have 13 been two times. I'm not sure, sir. She saw me at my 14 house either once or twice at my house and then either 15 once or twice at that office. 16 Q. Well, when you say she saw you at your 17 house, was that, I believe, and your memory may be 18 different than mine or better. I believe you 19 testified at your last deposition that one time she 20 came out to your house and one time you saw her at 21 an office on Clematis Street that was somebody 22 else's office that she was borrowing? 23 A. Yes. 24 Q. Okay. Now, have you seen her since that 25 visit thatru had with her in the office on (561) 832-7500 PROSE COURT REPORTING Page 570 1 A. No. 2 Q. Okay. So, did she come to do an 3 evaluation or did she come to give you counseling? 4 A. Both. 5 Q. How long was she there? 6 A. Fora few hours. 7 Q. Have you had any communication with her 8 other than those three occasions that you say she 9 visited with you? 10 A. She sent me a Christmas card. 11 Q. Have you received treatment from any 12 mental health specialisalathan assuming there 13 was any treatment by Any other 14 psychologist, psychiatrist? 15 A. No. But you're damn right I will after this. 16 Q. And you last saw Mr. Epstein in 2005? 17 A. I went to his house pregnant when I was -- 18 2006, or no,I was pregnant. I had my son 2005, and 19 then I went to his house after I was pregnant 20 Q. I believe you told us in the last 21 deposition the latest you could have seen him was 22 September of '05. Are you changing that or is that 23 correct? 24 A. Sir, you know what, when people go through a 25 lot of drama in their life, they h ot to really 18 (Pages 567 to 570 AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by Cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (601-0514164934) b55421ef-d299-4c41-9ba6.85aad2714405 EFTA01108869 Page 571 1 recall a lot of stuff but I know I saw him after I had 2 my son. 3 Q. Well, you had your son June 29th '05, 4 right? 5 A. Yes. So, it could have been July, August, 6 September, October, November, December. Then maybe it 7 could have went on to '0,'06. 8 Q. Well, do you know? 9 A. I'm not positive but I know that I went there 10 after I was pregnant. 11 Q. That's all you -- 12 A. That's al can tell you. 13 Q. All right. 14 A. And he didn't want me because he doesn't like 15 women that had a kid regardless of what their age is. 16 So, I had to bring another girl. 17 Q. And that was upsetting to you? 18 A. No. 19 Q. You thought you were his favorite girl at 20 one point? 21. A. No. 22 Q. That's what you told us in the last depo, 23 didn't you? 24 A. I told I was his favorite girl? 25 Q. That you thought you were special and you Page 573 1 Q. Is that November, December? 2 A. Maybe. 3 Q. Who did you go to? 4 A. I went to a cardiac specialist center. I 5 don't know what it's called. 6 Q. What's the doctor's name? 7 A. I have no idea. 8 Q. Did you go to a hospital? 9 A. No, but they put patches all over my heart and 10 a monitor to monitor my heart. 11. Q. And, and, and why did you go? What were 12 your symptom? 13 A. I have panic attacks all the time. I'm always 14 stressed out. I'm depressed. 15 Q. And what, what if anything, what if any 16 treatment did the doctor render to you? 17 A. I ended up not going back because I didn't 18 have enough money to pay for that. 19 Q. Well, what do you mean you didn't have 20 enough money? 21 A. What don't you understand about that? 22 Q. Well, how much did it cost? 23 A. A lot of money. 24 Q. How much? 25 A. A lot of money. More than grands. Page 572 1 were his favorite girl? 2 A. He made me feel special. He made me feel like 3 I was his favorite girl. 4 Q. And it upset you when you found out there 5 were other people going? 6 A. Did it upset me? 7 Q. Yeah. 8 A. No. 9 Q. So, for the last four years, a little bit 10 more than four years, the only person you've seen 11 with respect to any alleged mental illness or harm 12 has been and who was 13 provided by the Victim Services Bureau of the State 14 Attorneys office? 15 A. Yes. 16 Q. Have you gone to any cardiologists or any 17 physician specializing in -- 18 A. Yes, I have. 19 Q. Who did you go to? 20 A. A place in Wellington to see if my heart was 21 okay. 22 Q. When was that? 23 A. The end of '08. 24 Q. What do you mean by end of '08? 25 A. One of the months that is at the end of '08. Page 574 1 Q. Well, how much? You said you — 2 A. Like two grand. I don't know. Why don't you 3 check my records? 4 Q. You said you made two grand on a night, 5 right? 6 A. Okay. Great. Well, that goes to my son. 7 MR. EDWARDS: Object to form, 8 argumentative. 9 BY MR. LUTTIER: 10 Q. You would go and sell your wares, your 11 shoes. 12 A. So, what all the money I owe, or all the money 13 that l eam, goes to my son. 14 Q. And you didn't even pay -- 15 A. Not to suits. 16 Q. You didn't even -- 17 A. Not to 'ceipts. 18 Q. You didn't even — 19 A. Not to paper. 20 Q. And you didn't even pay taxes on money you 21 earned, did you? 22 MR. EDWARDS: Object to the form. 23 THE WITNESS: I did pay taxes. 24 BY MR. LUTTIER: 25 4. Did ou taxes in '08? (561) 832-7500 19 (Pages 571 to 574) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (801-051-976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) b5842104299-4441469846aad2714406 EFTA01108870 1 2 3 4 6 7. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 22 23 24 25 Page 575 A. Yes, I did. Q. And did you pay on the amount of income you actually earned? MR. EDWARDS: Object to the form. THE WITNESS: It's none of your damn business. BY MR. LUTHER: Q. Do you know that filing a false tax return is a crime? A. Yeah, and it wasn't false. Kiss my ass. Q. So your, your tax return is in '08 is correct; is that right? Is that what you are telling us? A. No. Q. Is it false? MR. EDWARDS: Just read. BY MR. LUTHER: Q. Now, you allege in your complaint that you have suffered, and I am going to list a series of things. A. Yeah. Can you tell I am suffering? Q. Well, ma'am — A. Can you tell I am suffering? I hate Jeffrey Epstein, and I hope he bums in hell. On advice of counsel, I am invoking my Page 576 Fifth Amendment rights under the United States Constitution. Q. To anything in particular or just malting that statement? A. To the question you asked me about my taxes. Q. That question has already been answered. A. Oh, okay. Next. Q. In your complaint you allege that you have suffered emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of esteem, loss of dignity, invasion of your privacy. A. Amen. Yes, I have. Q Have you — A. All of the above. Q. Have you described for me thus far in this deposition all of those elements that you allege of damage that you allege you suffered or is there A. Yes, I have. And you already know the doctors in the last deposition. Q. And you said some guy who is no longer in business out on Okeechobee. Anybody else? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 5 Q. Then you went to him tse you said you had your son in Publix, I think, and you had a panic attack? A. alWhen was the last time I yo mes is • A. I don't know. I couldn't tell you. Why don't you look at the documents since you're so smart. Q. Well, because we've tried to subpoena this doctor and he can't be found. That's why. A. Well, too bad for you then. I don't know. Page 578 1 Q. So maybe you haven't seen him quite as 2 often as you thought? 3 A. Bullshit. 4 Q. When was the last time you went then? 5 MR. EDWARDS: Watch your language, please. 6 THE WITNESS: Last year. 7 BY MR. LUTHER: 8 Q. That would be in '09. When in '09? 9 A. Beginning of '09. 10 't Q. You were asked to proclaim.", a an records from 11 didn 17 18 19 20 21 22 23 A. When have I been asked to produce any records? Q. You've gotten several requests to produce in this case. They go to your lawyer. A. Okay. Well, I've beta there. So, what do you want me to say? Q. 20 (Pages 575 to 578) (562) 832:-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506' Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) b5542(ef-d299-4041-9ba6-65aad2714405 EFTA01108871 10 13. 3.2 13 3.4 15 16 17 18 19 20 21. 22 23 24 25 Page 579 Q. Stop. We're staying will 2 THE COURT REPORTER: One at a time. 3 BY MR. LUITIER: 4 Q. We're going to stay with 5 We're going to follow this down to, right to the 6 end. 7 A. Okay. Keep on going. 8 Q. So, you say you went to him in '09. Where 9 did you physically go to him? A. I physically went to his doctor's office. Q. On Okeechobee? I think you said it was at Simsbury and Okeechobee? A. Yes. Q. So, your testimony is in '09 you went physically into that office and saw him? A. It might have been end of '08 or '09. I can't tell you the date. I don't know the date. Q. And you haven't seen him since then, have you? A. No, I have not. Q. So, it's been at least a year — A. Because I have enough — Q. — • 7 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 581 Q. Did somebody recommend this physician in Wellington to you? A. Yes. Q. Who did that? A. My friend Mark. Q. Mark who? A. I don't know his last name. Q. Where did you meet him? A. I don't know. Q. And did you pay for your first visit to that doctor? A. No. Q. Who paid for it? A. Mark. Q. Is he somebody you dated? A. Na Q. Is he someone with whom you had some kind of relationship? A. Yeah. Q. What kind of relationship did you have with him? Page 580 1 Q. How many pills do you have? 2 A. I don't know. I haven't counted them. I'm 3 sorry. 4 Q. And, and what kind of pills do you have? 5 A. What kind of pills? 6 7 A Q. . the drug? 8 Q. Okay. And was the drug you used to 9 abuse when you were teenager, didn't you? 10 A. Yes. I used to abuse them, yes. I don't 11 abuse them anymore. I lake them when I have panic 12 attacks. 13 Q. Were you ever addicted to MI , 14 A. No. 15 Q. And you haven't had to refill your 16 prescription, have you? 17 A. No. 18 18 19 19 20 is that right? 20 21 A. Nope. 21 22 Q. Now, what made — I want to clarify what 22 23 made you go to see this doctor in Wellington? 23 24 A. Because my, I, I thought I was, something was 24 25 wromvith my heart. 25 Page 582 1 A. Our sons would play together. 2 Q. Do they still play together? 3 A. No. 4 Q. Was he a client of yours? 5 A. No. 6 Q. Do you know physically where this office 7 was that you went in Wellington? 8 A. I told you, no. You have just as a bad memory 9 as I do. 10 Q. Well, I'm old. Now, what invasion — what 11 do you mean when you say you've suffered invasion of 12 your privacy? 13 A. Are you serious? Well, here is one. Here is 14 two. 15 Q. 16 did — 17 A. Investigators. Q. — in the public? A. All my damn, all these years that I've, after Jeffrey they wanted -- invasion of my privacy, are you kidding me? I can't go anywhere without anyone knowing where I'm going. The FBI, the investigators following me everywhere. I can't take my son out with anybody knowing me. Invasion of my privacy?. Everybody knows So, you're talking about things that you 21 (Pages 579 to 582). (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601-051.976-2934) b5542fef-d299-4e41-9ba6-85aad2714405 EFTA01108872 Page 583 1 that Jeffrey Epstein molested me. So, if my son 2 wants to go out and play with somebody, oh, no, 3 she's the little girl that was in prostitution for 4 Jeffrey Epstein, so we don't want her playing with 5 our son. 6 Q. So, or do they say she's the lady that 7 runs her own escort service, we don't want her 8 playing with our son? 9 A. No one knows about that shit except you guys. 10 Q. How about when you were working for 11 another escort service? 12 A. How about what? 13 Q. You don't think anybody knew about that? 14 A. No. 15 Q. How about when you were — 16 A. lam very discrete what I do. l don't put my . 17 name in the newspaper like Jeffrey Epstein saying that I 18 am a prostitute or a slave for Jeffrey Epstein. 19 Q. How about when you were top, dancing 20 topless at bars? Do you think maybe people said — 21 A. 1 did that out of, like not locally. 22 Q. So, maybe, well, I mean — 23 A. Well- 24 Q. You wouldn't exactly call Platinum 25 A. Show Girls is in Boynton Beach Boulevard. I Page 585 1 all out. Everybody knows. Okay. You can sit there and 2 act like you, you can act like an attorney and -- 3 Q. Has the words — 4 A. — say where has your name been? My name is 5 out there everywhere. Okay. I am the prostitute of 6 Jeffrey Epstein. I have brought young underaged girls 7 there. I am so horrible. 8 my son can't play with certain kids 9 because of Jeffrey Epstein now. He has ruined my 10 fucking life. He has brought me into this industry 11 that this is all I know. And now I can't even, I 12 can't even explain to you the hard things that I've 13 been through my life because of Jeffrey Epstein, 14 because he has taught me and many other girls how to 15 pull money from older men. 16 Q. Let's just be honest for the ladies and 17 gentleman of the jury: Ho didn't force you to do 18 anything? 19 A. But he taught me from a young age — 20 Q. Wait a minute. Let me finish. 21 A. — when I was 13 years old. 22 Q. You -- 23 A. He taught me how to get money real quick. 24 Q. Do you — 25 A. — from an old man. Don't sit here and tell Page 584 1 live in West Palm. 2 Q. So, you meant within the immediate 3 geographic area. And maybe they said, well, this is the lady that goes and sells her wares at all these 5 topless bass; we don't want our children playing 6 with her. 7 A. No, not all. They see Jeffrey Epstein and my 8 name all over the place and they say, you know what, I 9 don't even want anything to with this girl because she 10 was a prostitute for Jeffrey Epstein. 11 Can 1 talk to him without you in his ear? 12 Ant I done talking? 13 Q. Could you just tell me one place where 14 your name has appeared anywhere as being someone who 15 saw Jeffrey Epstein? 16 A. It's everywhere. 17 Q. Well, where? Just tell me one place. 18 A. Where have you been? 19 Q. Just tell me one place. Can you cite 20 me — 21 A. Ifs in the newspaper. 22 Q. What newspaper ever ran your name? 23 A. The initials of my name? 24 Q. No, your name. 25 A. It doesn't matter. The means It's (561) 8 3 2-7 50 0 Page 586 1 me that I was not forced or anything like that. 2 Q. That's exactly what I'm suggesting, ma'am. 3 Do you believe that you owe, that you have a certain 4 leVel of responsibility for your own conduct? 5 A. Now I do. 6 Q. You're 21 years old. 7 A. When I was 13 years old, 'didn't, I wasn't, 8 no, I did not have that demeanor. 9 Q. So, at 21 what you thought, because you 10 want to clean up your imagine for your son, right? 11 You want him to look up — 12 A. Yes, I do. 13 Q. So, as part of that process what you 14 thought you would do at 21 is you would agree to 15 hire out to strange men whom you don't know for 16 between $300 and $500 for what you say is to go sit 17 in rooms naked with them, and that's how you thought 18 you would prove? 19 A. Because that's all I know. I'm sorry. 20 Q. And Jeffrey Epstein didn't make you do 21 that, did he? You decided to do that, didn't you? 22 A. You know what 23 Q. A whole new business that you decided to 24 do on your own; is that right? 25 MR. EDWARDS: Object to form. 22 (Pages 583 to 586) PROSE COURT REPORTING AGENCY,. INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051476-2934) Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601.051.976.2934) b5542101-d299-4041-91m6.85aad2714405 EFTA01108873 Page 587 1 THE WITNESS: — before 1 — 2 MR. EDWARDS: Argumentative, asked and 3 answered. 4 BY MR. LUTTIER: 5 Q. Did Jeffrey Epstein ever give you the 6 business advice on a business plan to go out — 7 A. Yes, he did. He gave me business advice. 8 Q. Wait. You started this in January? 9 A. You know what he told me this: He said, you 10 inc girls, this is business. Let's talk business, 11 I . You get me girls, twill pay you. Is that not 12 called business? 13 Q. So, and you quit doing that when? 14 A. You get me girls, and I brought him.two girls 15 a day, one girl a day, $200 each. That's not business? 16 Q. And when you — 17 A. He taught me business and now I run business. 18 Q. And so — 19 A. Just like you run business. 20 Q. And when did that, when did you start — 21 A. Just like you learned how to do this, I 22 learned how to do this. 23 Q. What — so, you kamed to be a 24 prostitute? 25 A. Yes, I did. Page 588 1 Q. And you enjoy it? 2 A. No, 'don't enjoy it, and I can't wait to get 3 the hell out of it. 4 Q. And that's why in January of '010 you 5 decided what you would do is start getting men to pay you S300 to $500 an hour to sit around naked 7 with them, is that right? 8 MR. EDWARDS: Form. 9 THE WITNESS: Yes, that's right. 10 BY MR. LUTTIER: 11 Q. And the last time you took a girl to 12 Jeffrey Epstein was when? 13 THE WITNESS: Did we already ask this 14 question? 15 MR. LUTTIER: When? No, the last time — 16 MR. EDWARDS: Object to the form. 17 MR. LUTTIER: — you said you went was — 18 MR. CRITTON: You're out of time. 19 MR. LUTTIER: Okay. 20 THE VIDEOGRAPHER: Going off the record at 21 3:14 p.m. This is the end of Tape 2. 22 (A brief recess was held and 23 Mr. Goldberger did not re-enter the room.) 24 THE VIDEOGRAPHER: We're back on the 25 record at 3:24 p.m. This is the start of 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 589 Tape 3. MR. EDWARDS: Before we get started I just want to put something on the record that there was a hearing, I believe it was November 3rd, 2009, and the judge suggested that the defense only have one attorney there. And his recommendation was such because of the breakdown — MR. LUTT1ER: Well, let's — MR. EDWARDS: — in the first deposition. You can, you can make a record after. That is fine. Was because of the breakdown in the first deposition, and he thought that that type of intimidation by more than one attorney would lead to an additional meltdown. We have been fine thus far today despite there at a minimum always being two attorneys and in the last 15 to 20 minutes not only was Mark Luttier here and Bob Critton as it has been all day, but Jack Goldberger was also in the room. And once it was lined up three attorneys over there, either passing notes, talking in each other's ear, and otherwise assisting in the deposition or at least that was the feeling Page 590 1 from the witness, we began to have another 2 meltdown. 3 So, hopefully we can proceed with less 4 attorneys and we can get through this process. s But I just wanted to put on the record exactly 6 who was in the room when everything started to 7 break down just now. 8 MIL LUTIIER: Well — 9 MR. EDWARDS: If you have something to 10 say, that's fine. 11 MR. LUTHER: That just is not factually 12 correct. Mr., first of all the judge ordered 13 that Mr. Critton and I could be present 14 throughout this deposition. Mr. Critton and I 15 have been present throughout this deposition, 16 and he and I have communicated throughout the 17 deposition. 18 Mr. Goldberger walked in here. I didn't 19 put a stopwatch on how long he was there. He 20 is not even here now. He was here for maybe 21 ten minutes. I had no communication at all 22 with him. He carne. He sat here. He got up 23 and he walked out. 24 This breakdown that you're talking about 25 occurred Ions before Mr. Goldberger ever of (561) 832-7500 23 (Pages 587 to 590) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601.051476.2934) Electronically signed by cynthia hopkins (601.051476-2934) b5542fet-d299-4041-9ba6-55aad2714405 EFTA01108874 Page 591 here. So, I dispute — 2 THE WITNESS: No. 3 MR. LUTMER: — the facts, but it's sort 4 of a moot issue now anyway, so — 5 MR. EDWARDS: But if we're going to get 6 into that, then every time he comes into the 7 . room do we need to now put it on the record 8 that he is in the room? 9 MR. LUTTIER: I have absolutely no 10 problem — 11 MR. EDWARDS: And each time — 12 MR. LUTTIER: Anytime he comes in, we'll 13 stop him and well let him know he can't come 14 in here. Quite frankly, if you would have said 15 something to me about it, I was examining the 16. witness, I would have stopped right then and 17 said, Jack, get out of the room. 18 MR. EDWARDS: And I know in all fairness 19 to what you just said I am not saying that to 20 you was not factually accurst; what you just 21 said, but you weren't able to see what was 22 behind you, the passing of the cellphone and 23 other things that the witnesses notices. 24 I am just telling you that this impacts 25 the deposition. So, i just want to make it Page 592 1 clear so that you would know exactly what's 2 happening and maybe we can get through this. 3 You know, it's all of our goals to get through 4 this day. So, I, I think the witnesses is 5 ready if you're ready, Mr. Luther. 6 MR. LUTTIER: I'm ready. 7 MR. EDWARDS: Okay. 8 MR. CRITTON: What time did we start 9 because we haven't we've been on the record, 10 but we haven't asked a single question. 11 THE VIDEOGRAPHER: It's 3:28 right now. 12 Three and a half minutes. 13 MR. CRTITON: Thank you. 14 BY MR. LUTTIER: 15 Q. I am now referring to your, your 16 interrogatory answers. These are answers that you 17 gave to written questions that were sent to you in 18 this case. And they are entitled Defendant's 19 unverified better answers to first interrogatories. 20 I believe they may have been marked as Exhibit 1 to 21 the first deposition, but there is only one set of 22 them. 23 • MR. LUTHER: And Brad, they are, the date 24 of service on, I don't know, wait. Date of 25 service is August 4th, 2009. Page 593 1. MR EDWARDS: That's the — 2 MR. LUTHER: Defendants unverified 3 better answers to first interrogatories to 4 Plaintiff. Later I'm going to come to the S Plaintiffs supplemental better answers to 6 Defendant's Interrogatory No. 19. 7 MR. EDWARDS: Okay. But you said the date 8 of service meaning you saved on us? 9 MR LUTTIER: No, no. Your answers, 10 better answers. 11 MR. EDWARDS: Got it. I am looking at the 12 same document you are. 13 BY MR. LUTTIER: 14 Q. All right. Ma'am, in response to some 15 interrogatories you stated that from the end of 2007 16 to November of 2008 you worked at Palm Beach Angels 17 earning S800 a week. So that would have been a 18 period of approximately one year; is that right? 19 MR. EDWARDS: Read. 20 TIDE WITNESS: On advice of counsel I am 21 invoking my Fifth Amendment rights again under 22 the United States Constitution. 23 BY MR. LUTHER: 24 Q. From, for the entire period of time that 25 you worked at Palm Beach Angels, what did you do for 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 594 your money? A. On advice of counsel I'm invoking my Fifth Amendment rights under the United States Constitution. Q. In continuing in answering that particular interrogatory you said that in 2008 you worked at Palm Beach Massage. Where is Palm Beach Massage located? A. On advice of counsel I'm invoking my Fifth Amendment rights under the United States Constitution. Q. What did you do at Palm Beach Massage? A. On advice of counsel I'm invoking my Fifth Amendment rights under the United States Constitution. Q. Did you have any communication with Jeffrey Epstein after the phone call you made to him following the FBI's interview of you? A. I talked to M. Oh, my God. I don't know what I am going through. I'm like shaking. Q. I am talking about now a conversation with Mr. Epstein. MR. EDWARDS: The question was, did you talk to him after you called him — MR. LUTTIER: Right. MR. EDWARDS: — after the FBI statement? MR. LUTTIER: Right 24 (Pages 591 to 594) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkIns (601.051.976-2934) Electronically signed by cynthia hopkIns (601.061.976.2934) Electronically signed by cynthia hopkIns (601-061-976-2934) b55412lef-d299-4e4f-9ba6-85aad27t4406 EFTA01108875 9 10 13. 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 595 BY MR. LUTTIER: 2 Q. And the date of your FBI statement for 3 your information was April 241h, 2007. Did you have 4 any conversation with Jeffrey Epstein after that . 5 date? 6 A. After I, after I had called my attorney? 7 Q. After April 24th, '07, which is the date 8 that you gave a st FBI. A. I talked toaalasic) or whatever her name is. Q. Did you have any conversation with Jeffrey Epstein? A. No. I don't think so, no. Q. Other than the witnesses you have listed in answer to Interrogatory No. 5, do you know of any other witnesses or do you intend to call any witnesses in the trial of this matter? A. What? MR. EDWARDS: Objection. Attorney-client privilege. I don't want her answering questions as to whether, as to information that she and I have spoken about in terms of what witnesses will be called at trial or our trial strategy. 1 2 3 4 5 6 7 8 9 10 1]. 12 13 14 15 16 17 18 19 20 21 22 23 24 Q. When did you last have communication with 25 him? Page 597 with fl out being a witness? That is what would he be offering as testimony in the case? A. What would he be offering? Q. Yeah. Why did you ask him about being a witness? A. I didn't ask him about being a witness. I .told hhn about what happened to me when I was 13 years old. Q. Okay. A. I'm not asking anybody to be a witness as of right now. Q. What's • A. I'm my own witness. MR. EDWARDS: Listen to his question. THE WITNESS: I am trying. I can't think right now. MR. EDWARDS: He wasn't asking you about being a witness. BY MR. WrITER: Q. Where does ...live now? A. West Palm Beach. AQ. t Palm? Page 596 1 BY MR. LUTHER: 2 Q. Have you spoken to anyone with respect to 3 their willingness or your intention to call them as 4 a witness to the trial of this matter? 5 MR.. EDWARDS: Not who I have spoken to. 6 MR. LUTHER: Yeah, you. 7 THE WITNESS: What? 8 BY MR. LUTHER: 9 Q. Have you spoken to anybody about being a 10 witness' is matter? 11 A. 12 Q. Anyone else? 13 A. Not that I know of. 14 Q. And when did you speak with 15 about being a witness? 16 A. May `09. 17 Q. And what is it you told him or asked him 18 about being a witness? 19 A. I told him that Jeffrey Epstein molested me 20 since 1 was 13 years old. 21 Q. Okay. And he wasn't around at the time 22 that you alleged Mr. Epstein molested you, correct? 23 A. He wasn't around at the time when Jeffrey 24 Epstein was molesting me. 25 . Okay. S a = t r w did you confer (561) 832-7500 Page 598 1 A. January 3rd, 2010. • 2 Q. And for what purpose did you have 3 communication with him on that date? 4 A. I had to give him some of his clothes. 5 Q. When was ' were in 6 ' tion with that would be 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. lie's my son's father. So, I talked to him two weeks ago. Q. And where was he when you talked to him? A. Fort Myers. Q. And do you know how he's employed now? A. .No. He says he's not employed. Q. Have you discussed with him in the last year anything about this lawsuit? A. Yes. . Q. What have you discussed with him? A. I told him I'm going through a lawsuit. Q. And what did he say? A. He said okay. Q. Have you asked him to be a witness? A. No. other members of family in the last Q. Have you ' nication with any . two years? 25 (Pages 595 to 598) PROSE COURT REPORTING AGENCY INC. (561) 832-7506 Electronically signed by cynthia hopkins (601.061-976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by Cynthia hopkins (601.051.976-2934) to5542lef-d2994e4t-gba6-135aad2714405 EFTA01108876 Page 599 1 A. Yes. 2 Q 3 A. .c). 4 Q. Who is 5 A. His sister. 6 Q. And where does she live? 7 A. Wellington. 8 Q. And for what purpose have you been in 9 touch with her? 10 A. She's my son's aunt 11 Q. And with what degree of frequency are you 12 in communication with her? 13 A. She asked me to attend her wedding via e-mail 14 this March of '010. 15 Q. Have you discussed with her anything about 16 Mr. Epstein? 17 A. No. 18 Q. Does she to the best of your knowledge H know anything about it? 20 A. Yes. 21 Q. Did you say no? 22 A. Yes. 23 Q. Does she know anything about? 24 A. Yes. 25 Q. What does she know about it? 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 601 Q. Is that the last time she's seen your son? A. Approximately, yeah. Q. Who was watching your son when you were down at Spearmint Rhino's from 8:00 at night until 5 in the morning? A. Q. I sic) who you identified earlier? rather? A. Yeah. Q. And where was she watching him? A. At my house. Q. So, does she come spend the night at your house? A. Yes. Qa.gd there, was there ever a time that you and 1M lived together? A. Yes. Q. When was that? A. When we were 13, 14. Q. Thirteen and 14. Was any adult living with you? A. My father. Q. Since you were 13 or 14 has a ever lived with you? ANo. Page 600 A. That Jeffrey Epstein's a child molester. 2 Q. And how did she get that information? 3 A. From the news, from friends, from the 4 neighborhood -- 5 Q. Did — 6 A. From her brother. 7 Q. — has she asked you any questions about 8 your relationship or interaction with Mr. Epstein? 9 A. She said I am sorry that you're going through 10 the trauma that you're going through. 12 other member of family? Q. Have you communication with any 11 13 A Ms mother. 14 Q. is her name? 15 16 17 18 19 20 21 22 23 24 25 AI Q. And where is she located? A. Fort Myers. Q: And when did you last have communication with her? A. I don't know. A year ago. Q. And for what purpose did you have communication with her at that time? A. Dropping my son off with her. Q. In Fort Myers? A. Belle Glade. (561) 832-7500 1 2 3 7 8 9 10 11. 12 13. 14 15 16 17 18 19 20 21 22 23. 24 25 Page 602 Q. Did you tell why you needed to have her watch your son all night when you were down at Spearmint Rhino's? A. I told her I need to work. Q. Do you tell her what you do for work? A. Yes. Q. What did you tell her? A. I sell lingerie and shoes and purses and Mary Kay. Q. Do you have any personal knowledge of the matters about which the witnesses listed in your answers to interrogatories that these witnesses have, have information about? MR. EDWARDS: Objection, attorney-client privilege. And we do this all the time. BY MR. LUITIER: Q. This is just a list as prepared by your lawyer. You don't know what any one of these witnesses would say? MR. EDWARDS: And if she does, it's going to be information that I have talked to her about which you know is protected by attorney-client privilege and so do L If you're asking her independent of her information I have told her, fine. 26 (Pages 599 to 602) PROSE COURT REPORTING AGENCY, INC. (561) 832-750.6 Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601-061.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) b55421ef-d299-4e4f-9ba6-85aad2714405 EFTA01108877 Page 603 1 MR. LUTTIER: That's exactly what I am 2 asking her. 3 MR. EDWARDS: Okay. Let's ask it that way 4 because it doesn't sound like that. 5 BY MR. LUTTIER: 6 Q Do you know of any information that these 7 witnesses have based on your communications with 8 them? 9 A. Excise me? 10 Q. Do you know any information that any of 11 these witnesses have about this case based on your 12 personal contact with them? 13 A. What witnesses? 14 Q. That are listed in the Answers to 15 Interrogatory 5. 16 MR. EDWARDS: Just answer his question, 17 yes or no. 18 THE WITNESS: No. I don't know these 19 people. 20 BY MR. LUTTIER: 21 Q. On any visit that you went to see Jeffrey 22 Epstein, did he ever ask you to do anything that you 23 said you did not want to do? 24 A. Yes. 25 Q. What did he ask you to do that you said Page 604 1 you didn't want to do? 2 k At one occasion he wanted to stick his fingers 3 like all the way inside of me and I said no? 4 Q. And what did he then do when you said no. 5 A. He said okay. So then he just penetrated my 6 vagina with his fingers. 7 Q. What did he, did he —when you said you 8 didn't want him to do that, did he respect your 9 wishes and not do it? 10 A. No. Actually he, he pushed it. He tried to 11 do it and he said, okay, no, it's going to be okay. 12 It's going to be okay. And I backed off and I said no. 13 Q. And then he stopped? 14 A. Then he decided to respect my wishes. 15 Q. Okay. Any other — and this is on one 16 occasion? 17 A. Many occasions. 18 Q. Well, on — so on many occasions he would 19 say he wanted to penetrate your vagina. You would 20 say you didn't want — well, actually what you said 21 was he wanted to penetrate your vagina deeply I 22 think. And, and you said no and he respected your 23 wishes and didn't do it? 24 A. Correct. 25 Q. Okay. Was there ever anytWnthatt at Page 605 1 all that you said I don't want to do this and Jeff 2 said you had to do it anyway? 3 A. Yeah. I told him that at times I did not want 4 to bring girls, and he says, yes, I want you to do it 5 anyway; you need to do it anyway. 6 Q. And did you tell all the girls that you 7 brought that Jeffrey would respect their wishes, and 8 if they were uncomfortable doing anything, that they 9 should just tell him that, and he wouldn't ask them 10 to do anything that they weren't comfortable doing? 11 A. Yes, because I was scared. 12 Q. And that's, in fact, how he treated you, 13 fir? 14 A. Yes. 15 Q. You previously earned a degree as an 16 esthetician; is that right? 17 A. Yes. 18 Q. And you now earned a define since going to 19 Mr. Epstein in massage therapy, correct? 20 A. Yes. 21. Q. And you earned both of those from the same 22 school located on Northiake Boulevard? 23 A. Yes. 24 Q. And you could pursue a profession as an 25 esthetician, a massage therapist if you so chose, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING Page 606 could you not? A. No, not as a massage therapist. Q. Why not? A. Because I've told you once before I need to take the nationals. Q. But no one has prevented you from taking test, right? A. I have to wait to take the test. It only happens twice a year. Q. And has — did you pass the first opportunity you had? A. No. Q. Okay. So, when's, when's the test coming up? A. In a few months. Q. And are you going to take it? A. Yes. Q. And you could have been working as an esthetician ever since you went to Jeffrey Epstein's? A. And I did work as an esthetician. Q. No one has prevented you from doing that, corned? A. No. 9. You made the decision to drop out of 27 ( Pages 603 to 606) AGENCY, INC. (561) 832-7506 new:ironically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) bSS42fet-d299-4e41-9ba6-85aad27f4405 EFTA01108878 Page 607 school before you ever met Jeffrey Epstein, did you 1 2 not? 2 3 A. I'm pretty sure I was going to school when I 3 Was seeing Jeffrey Epstein. 4 5 Q. But, but you made the decision to drop out 5 6 based on other facts and circumstances that had 6 7 nothing to do with seeing Jeff Epstein; isn't that 7 a correct? 9 A. Excuse me? 9 10 Q. You decided to drop out of school for your 10 11 own reasons particularly 1 think you said because 11 12 you got pregnant, didn't you? 12 13 A. No. 13 14 Q. Well, why did you decide to drop out of 14 15 school? 15 16 A. I was trying to find girls to bring to 16 17 Jeffrey's house. 17 18 Q. Well, didn't you tell us the last 18 19 deposition that you dropped out when you got 19 20 pregnant? 20 21 A. I was going to school when I was pregnant. 21 22 Q. Yeah. And then you dropped out, right? 22 23 A. I dropped out when I was four months pregnant. 23 24 Q. Why did you drop out of Palm Beach 24 25 Community School and then go to Pace school? 25 Page 609 six. But then I did go back and I got my high school diploma, and like you said I have two degrees. Q. When did you get your, your GED? A. Yes. Q. When did you get that? A. When I turned 18. Q. And who did you get that from? A. The Adult Education Center. Q. So, you got a high school equivalency diploma at the same time you would have gotten a high school graduation certificate — A. Correct. Q. -- had you stayed in school? A. Correct. Q. And then you were free to pursue the same pursuits as anybody else that had graduated from high school whether that would be college or a trade school or whatever you want to? A. No, no. If I would have stayed in school, I could have got some type of scholarship. I could have had many opportunities in school to learn higher education than just the GED. Q. Well, when you got — A. And I could have — traveled and I could have went to a college, a bigger college, a state college. Page 608 1 A. Because ever since I met Jeffrey I - before 2 Jeffrey I made wonderful grades. And then ever since I 3 met Jeffrey my grades went down and I was failing. so I 4 had to go to a school to bring my grades backup. S Q. But you opted to drop out of the Pace 6 school before you graduated? 7 A. Yes. I was four months pregnant 8 Q. And that's why you dropped out? 9 A. Well, I needed to make money to buy a house, a 10 trailer so I could have my baby. 11 Q. Because you were pregnant? 12 A. Yes. 13 Q. Had you not been pregnant, you would have 14 continued in school, correct? 15 A. I can't answer that question. I don't know. 16 Q. Well, the point is the direct reason why 17 you dropped out was you were pregnant? 18 A. And I was making so much money off of Jeffrey 19 that I didn't think school was so necessary at that 20 time. 21 Q. Did you consult with your parents or any 22 counselors about that? 23 A. I didn't tell my parents about Jeffrey. 24 Q. How much were you making at that time? 25 A. I was making $200 pretty much a day or 400 or Page 610 1 Q. How do you know that? 2 A. It's common sense. 3 Q. Well, you don't know what your grades 4 would have been, right? 5 A. No, I don't know what my grades would have 6 been. 7 Q. And at — A. Do you know what tomorrow is going to bring? 9 Q. At the time that you went into the Pace 10 school, you were practically failing, weren't you? 11 A. Yeah, but Pace, they help girls, young girls 12 bring up their grades so you can go back into high 13 school and accomplish making more, bettering your grades 14 so you can get a scholarship. 15 Q. Well, in fact you got a scholarship for 16 your massage therapy, didn't you? 17 A. No. How could I7 18 Q. Did you tell us in the last deposition 19 that you got some kind of scholarship for going 20 there? 21 A. I didn't get a scholarship for going. No. 22 I've never got a scholarship. 23 Q. Did they lend you money to go to school 24 there? 25 A. For massage therapy but not for esthetics. (561) 832-7500 28 (Pages 607 to 610) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) bS542fef-d299-4e4f-SbaSaSaad2714405 EFTA01108879 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 611 Q. That's what I was talking about was 2 massage therapy. A. That's not a scholarship. Q. Okay. • A. That's a loan that I have to still payback. Q. Did you ever travel anyplace with Jeffrey Epstein? A Nope. Q. Are you — you're a person that uses the computer now, correct? A. Yep. Q. Did you ever communicate with Jeff Epstein on the computer? A. No, not that I real Q. Who is (phonetic)? A. A boyfriend that I had when I was younger. Q. And when was he your boyfriend? A. I think I was Q. Was he beforein A. No. Q Was he after? A. , no. MM., he was before Yes Q. And was your boyfriend before you saw Jeff Epstein? Page 612 A. Yes. 2 . And did you have sexual relations with 3 4 A. I was younger when, when I dated. I was — Q. Thirteen? A. I think I just tinned 13. Q. _And you have sexual relations with Mr. A. No. Q. Well, you filed a better answers to Interrogatory 19 which asked you to identify all persons with whom you were sexually involved from age ten through September 2005. And one of the people you put was A. Okay. I'm sorry. I never had sex with Q. Did you have some kind of sexual activity with him? A. No, we 'list kissed. Q. Who is A. He lived off Drexel when I was living on Drexel. Q. Was he your boyfriend at one time? 25 A. No. (561) 832-7500 17 18 19 20 21 22 23 24 25 ua Page 613 1 Q. Did you have sex with him? 2 A. Yes. 3 Q. When? 4 A. The times I was seeing Jeffrey. 5 Q. Say when? 6 A. The time — 7 Q. While you were seeing Jeffrey? 8 A. Yes. 9 Q. And... is, was, is a former 10 boyfriend of yours? 11 A. Yes. 12 Q. Had sex with him obviously, right? 13 A. Yes. 14 Q And that was after? 15 A. Yes. 16 Q. And , another boyfriend of 17 yours with whom you had sex? 18 A. Yes. 19 Q. You had sex with while you were 20 seeing Jeffrey Epstein? 21 A. No, no. I don't know. I don't know. 22 Q. Well, you were having sex with at least 23 four people while you i s Jeffrey 24 Epstein 2 3 4 5 6 7 8 11 12 13 14 A. Yes. MR. EDWARDS: Object to the form. BY MR. LUTTD3R: Q. And you weren't having any, during that whole period you weren't having sex with Mr. Epstein; you were just doing the massages — A Yes. Q. — aSOP sexual acts wit to actually en MR. EDWARDS: Object to the form. BY MR. LUITIER: Q. Did you engage in both sexual ' and oral sex with esci of the indjvi Page 614 A. Just intercourse. Q. No oral sex with any of those individuals? A. Name the I will tell you. Q. A. Yes. Q I think you already told us yes. And by way when you say oral sex, is that both giving and' receiving? A. Giving. 29 (Pages 611 to 614) PROSE COURT REPORTING AGENCY,' INC'. (561) 832-7506 Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) b56421ef-d299-4e4f-9ba6-85aad2714406 EFTA01108880 4 5 6 7 8 9 10 11 12. 13 14 15 16 17 18 19. 20 21 22 23 24 25 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 615 Q Giving. You didn't receive any oral sex from A. Q. A. Yes, both. Q. Both? A. Give t Q• may A. sis ? A. Intercourse. Q. No oral? A. No. Q. v of those individuals Mr. his brother or ever perform any sexual act on you that you didn't want them to perform on you? A. No. Q. Ii or ever perform any sexual act on you that you d" ft want them to perform on you? A. No, it was consensual. Q. And was your sex within both sexual intercourse as well as oral sex? A. Yes. Page 617 1 mean in particular? 2 MR. EDWARDS: Form. 3 THE WITNESS: Let's just say his cock was 4 as big as Jeffrey's. 5 BY MR. LUTTIER: 6 Q. That would be an indication of size or 7 lack of size? 8 A. Lack of size. Thanks for making me laugh. 9 Q. Are you on any prescription medication 10 now? 11 A. No. 12 Q. You testified in your last deposition that 13 you had participated in making some kind of a tape 14 in which you were engaged in sexual activities. Do 15 you recall that? 16 A. Yes. 17 Q. What, what, with whom did you make that 18 tape? 19 A. 20 Q. And when was that made? 21 A. '07. 22 Q. After Mr. Epstein? 23 A. Yes. 24 Q. Couple years after Mr. Epstein? 25 A. Yes. Page 616 Q. And how about with •=7 2 A. Yes. 3 Q. w here along the line after that you met A. Yes. Q. Where did you meet him? A. I Imewthirn fora while but I met him like January of'09 in Cheetah's nightclub. Q. And why were you in, in Cheetah night club in January of'09? A. Hanging out. Q. Were you dancing? A. No. Q. What was he doing there? A. Hanging out. Q. And, and you had sexual intercourse with him. Did you have oral sex with him? A. Yes. Q. Was the sex good? MR. EDWARDS: Object to the form. THE WITNESS: No. MR. LUTTIER: Huh? THE WITNESS: No. BY MR. LUTTIER: Q. And when you say no what, what do you (561) 832-7500 Page 618 1 Q. And what was depicted on the tape? 2 A. Just him and I having sex, oral sex, 3 intercourse, dancing, fun, fun, fun. 4 Q. And where was it made? 5 A. In the house that we lived together. 6 Q. And whose idea was it to make it? 7 A. Both of us. 8 Q And did a third party film it -- 9 A. No. 10 Q. — or did you set up a tripod? 11 A. I set up a camera. 12 Q. And what happened to the tape? 13 A. I deleted 14 Q. Did anybody see the tape? 15 A. No. 16 Q. You didn't show it to anybody? 17 A. I might have. I might have showed to M. but 18 Ideal think she cared to see it. 19 Q. Well, you infer* embarrassed about it, 20 were you? 21 A. No. 22 Q. You are, you are, would you say 23 comfortable with your body? 24 A. I guess I have to be ifl am in this industry, 25, right? 30 (Pages 615 to 618) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601-051-9764934) b5642lef-d2994•4146.646aed2714405 EFTA01108881 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 25 O., What's called a Marchnien Act Page 619 1 Q. Well, I mean being naked doesn't offend 2 you? 3 A. Yeah, it does. 4 Q. It does offend you? 5 A. Yeah 6 Q. Well, what percentage of your time when 7 you're working with your business did you spend 8 being naked? 9 A. A lot. 10 Q. But you choose to do it? 11 A. Yeah. 12 Q. You have been the victim of acts of 13 domestic violence, have you not? 14 A. Yes. 15 Q. When was the first time you were the 16 victim of an act of domestic violence? 17 A. With .M= I told you that 18 THE COURT REPORTER: Pm sorry? 19 THE WITNESS: With 20 BY MR. LUTTIER: 21 Q. Were you only a victim of domestic 22 violence on one occasion with Mr. 23 A. Yes. I was a victim, yes. 24 Q. And that was the first time that you had 25 ever been a victim of domestic violence? Page 621 1 BY MR. WITTER: 2 Q. Did you she ever approach you about that? 3 A. No. 4 Q. Did she ever tell the police she was 5 concerned about that? 6 A. No. 7 MR. EDWARDS: Object to the form. 8 BY MR. LUTTIER: 9 Q. Was your mother concerned that you were 10 sexually active at an early age? 11 MR. EDWARDS: Form, predicate. 12 MR. CRITTON: What's the form? 13 THE WITNESS: She was probably concerned 14 MR. EDWARDS: You're asking — 15 MR. LUTTIER: Was your mother — 16 MR. EDWARDS: You're asking to tell 17 you whether she knows how her mother was 18 feeling at some certain time. 19 BY MR. LUTTIER: 20 Q. The question stands. Was your mother ever 21 concerned that you were sexually active at an early 22 age? 23 MR. EDWARDS: Same objection. 24 THE WITNESS: She probably was concerned, 25 Yeah Page 620 1 A. Yes. 2 Q. Do you know of-(phonetic)? 3 A. Yeah. 4 Q. Who is that? 5 A. It's actually my sister's son or daughter's 6 father's cousin. 7 Q. Sister's daughter? Your sister has a daughter? A. Yes. Q. So daughter's cousin's father? A. y's father, his cousin. a cikay. When did you first meet A. Probably knew him since I was 11. Q. And did your mother express to you concerns as early as February of '03 that you were sexually active with him? A. I was never sexually active with him. Q. Did your mother believe that you were? MR. EDWARDS: Object to the form. BY MR. LUTTIER: Q. Do you know? MR. EDWARDS: Predicate. THE WITNESS: No. Page 622 1 BY MR. LUTTD3R: 2 Q. Why? 3 A. Who would want there daughter being sexually 4 active at a young age? 5 Q. What gave her that concern? What 6 activities were you engaging in to give her that 7 concern? 8 MR. EDWARDS: Object to the form, 9 predicate. 10 THE WITNESS: A mother's love. I don't 11 know. I can't speak for my mother. I am 12 sorry. 13 BY MR. LUTTIER: 14 Q. Were you doing something that gave her 15 that concern? 16 MR. EDWARDS: Object to the form, 17 speculation. 18 THE WITNESS: I don't know. 19 BY MR. LUTHER: 20 Q. Are you aware of the fact that your father 21 filed a Petition for Involuntary Treatment for 22 Substance Abuse with respect to you back in July of 23 '04? 24 A. He filed for what? (561) 832-7500 31 (Pages 619 to 622) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkIns (601.051.976.2934) Electronically signed by cynthla bodkins (601.051.976-2934) Electronically signed by cynthia hopkIns (601-051-976-2934) b55421et-d299-4e41-9ba6-85aad2714405 EFTA01108882 Page 623 Petition for Involuntary Treatment for Substance 2 Abuse. 3 A. I never went to any program or anything. 4 Q Yeah, but do you know he filed a petition 5 in the court claiming that you come home when you 6 want to, you're in trouble with the police, and that 7 you're taking Xanax, cocaine, and alcohol? Did you 8 know he filed that in July of '04? 9 A. No. 10 Q. You didn't know that? 11 A. (Witness shakes head.) 12 Q. Were you, in fact, taking Xanax, cocaine, 13 and alcohol in July of '04? 14 A. Yes. I apologized to my father. 15 Q So, he had a legitimate concern at that 16 time? 17 MX. EDWARDS: Form. 18 THE WITNESS: Yes. 19 BY MR. LUTHER: 20 Q. And with what degree were you taking 21 cocaine and alcohol at that time? 22 A. I was a confused little girl with Jeffrey 23 Epstein and that always, leaving Jeffrey Epstein's house 24 always lead me to do more drugs and more drugs. I was 25 uncomfortable about my body. 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 624 Q. What were you — A. I didn't like the way Jeffrey made me feel. Q. What were you uncomfortable about your body about? A. I felt insulted. I felt used. Q. Did you tell him that? A. No. Q. Did you tell anybody that? A Yeah. Q. Who did you tell? A. Q. On the, on the way over to Jeffrey Epstein's when you were taking her there? A. Yeah. We would tell each other that we didnt like the way we felt. Q. Did tu file a complaint that your boyfriend was stalking you? A. Yes. Q. Was be, in fact, stalking you? A. He got he was on coke one day, and I was scaled because he was trying to get in the house and 1 didn't want nothing to do with him. Q. Did that 'five you some concern? A. Excuse me? Q. Did that give you concern? (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 625 A Concern? Q. Yeah. I mean were you afraid? A. Only for that one night that he was on coke. He was just trying to, like, get in my house and I didn't want him in there. Q. Do you know a lady by the name of Jacqueline Miler? A Yeah. Q. How do you know Jacqueline Miller? A. Oh, my. I know her through T.J. Q. Who is T.J.? A. A friend of mine. Q. Where did you meet T.J.? A. Through Jacqueline Miller's boyfriend. Q. And who's Jacqueline Miler's boyfriend? MR. EDWARDS: Did you have a question, Bob? MR. CRITTON: He was telling me to ask her what T.J.'s — MR. EDWARDS: Oh, sony — MR. WITIER: full name is. We'll get to that. MR. EDWARDS: Okay. THE WITNESS: I don't — oh, God, I don't remember his name but they were both no good. Page 626 1 They were like gang members. 2 BY MR. LUTHER: 3 Q. That is T.J.? • 4 A. No, Jacqueline and her boyfriend. 5 Q. Okay. But you don't remember the 6 boyfriends's name? How did you — what was your 7 relationship with Jacqueline Miller? B A. Associates. We talked once in a while. 9 Q. When did you first meet her? 10 A. In — I don't know. Maybe when I was 14. 11 Q. Did she live in your neighborhood? 12 A. No. 13 Q. How did you meet her? 14 A I'm not sure. 15 Q. Was she a friend? 16 A. She became an associate. 17 Q. Is there a difference between an associate 18 and a friend? 19 A. Yeah. A friend is someone who's always by 20 your side and who you can talk to daily, and an 23. associate is just someone you can, that you know. 22 Q. Did you socialize with her? 23 A. Yeah. 24 Q. What kinds of things did you do with her? 25 A. Not good things. 32 (Pages 623 to 626) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) 8584254441299-444,4488-88•882744408 EFTA01108883 Q. Page 627 What things? 2 A. We did, we did coke together. 3 Q. Who provided the coke? 4 A. She did. 5 Q. And anything else that you did with her? 6 A. Just drugs. 7 Q. What other drugs? A. Coke and pills. 9 Q. Who provided the pills? 10 A. She did. 11 Q. And this was during the time that you were 12 seeing Mr. Epstein? 13 A. Yeah. 14 Q. What else did you and she do together? 15 A. Nothing. 16 Q. Did you-all live together at some point? 17 A. I asked her to -- she asked me if she could 18 room with me when I was living in my trailer and I gave 19 her a chance. About a week later I found out that she 20 was not the kind of friend for me at all and she was 21 into no good things. And I have a son so I couldn't 22 have her around. 23 Q. What do you mean she was into no good 24 things? 25 A. She was into drugs and stealing and -- Page 629 1 A. Yeah. 2 Q. And she threatened to kill you? 3 A. Yeah, she threatened a lot of stuff. 4 Q. And did you believe she had the capacity 5 to do that? 6 A. No. 7 Q. What gang was she in? 8 A. Folk (phonetic). 9 Q. And did you know her to be a violent 10 person? 11 A. Yeah. But she's like 80-pounds soaking wet so 12 I'm not worried about her. She's just lost and God 13 bless her soul. 14 Q. Now, let's talk about Mr., is it =or 15 Redell (phonetic)? 16 A. 17 Q. And you have described earlier a 18 confrontation that you had with him. And was his 19 mother present for that confrontation? 20 A. Yes. 21 Q. And, and did it initially start out that 22 Mr.thr was physically abusive towards his 23 mo 24 A. Yes. I had told him to leave and his mother 25 came to pick up his daughter from my house. When she Page 628 1 Q. Did you and she have a physical 2 confrontation? 3 A. She brought -- I told her when she moved in 4 for that one week I told her do not bring anyone into 5 this house. She brought a man into my house. I opened 6 her bedroom door, found her giving him oral sex. I got 7 angry. I said, please leave. She was on drugs. 8 She got angrier and came into the bathroom 9 and hit me or tried to hit me on my head. So, I 10 pretty much held her down until the cops came 11 because I called the cops to get her out. 12 Q. Was it an upsetting event to you? 13 A. No. !just couldn't wait for her to get out. 14 Q. Was that a common thing for you to have 15 fistfights with other women? 16 A. No. I didn't throw a fist. No, it was not a 17 common thing. 18 Q. And did she threaten you on the way out? 19 A. Yes. 20 Q. And you said she was in a gang? 21 A. Yeah. 22 Q. And what did she tell you on the way out? 23 ' A. 06,1 don't remember. I'm going to regret it. 24 Q. Well, did she say, I am going to get you, 25 bitch? ' rarat===alllarACISSIIIBAL., Page 630 1 arrived, he started pushing and shoving his mother into 2 the car. I could tell that he was on drugs. So, I said 3 this is uncalled, uncalled for. I called the cops and 4 that was that. He ran. I guess you can say I have a 5 good heart and I give the wrong people chances. 6 Q. Well, that was one incident when, when the 7 mother was present, right? 8 A. Yes, and that night actually -- 9 Q. There was a second incident, was there 10 not? 11 A. Yes. That night he — that's when he pushed 12 me down a couple times and that's when I hit him and 13 then he spit blood all over the house. And that's when 14 Er, DCF got involved. So, I, three days later, 15 immediately moved out of the house and moved to Royal 16 Palm. And the next thing I know the week that I moved 17 to Royal Palm, he showed up at my house. 18 Q. Okay. Well, let's go through this slowly. 19 The first confrontation where his mother was 20 involved happened in November of '06; is that right? 21. A. If that's what the document says. 22 Q. Okay. And that's when he was pushing his 23 mother around and, and then he turned towards you 24 and pushed you around, right? 25 A. Yeah. (561) B32-7500 33 (Pages 627 to 630) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia honker's (601.051.976-2934) Electronically signed by cynthia honker's (601-051-976-2934) b5542lef-d299-4e4f-94,36-85aad27f4405 EFTA01108884 Page 631 1 Q. Now, the second time there was a 2 confrontation was March 10th of'07? 3 A. Yes. 4 Q And at that time that's when you got into, . 5 what, was there, was there another incident the 6 evening of November '06 before we got to March of 7 '07? 8 A. Yeah. That's when he pushed me down. 9 AL Okay. Then in March of'07, Mr. .10 =smacked you and choked you, interne? 11 A. Yes. Well, l moved specifically benuse of 12 him. I didn't want him in my life at all. And he found 13 out where I lived and he came to my residence, kicked 14 down the door and smacked me and choked me, yes. 15 Q. And, in fact, you filed for an injunction 16 against domestic violence on March 14th, '07, 17 against him, did you not? 18 A. Yes. 19 Q. And you claimed that you and he were 20 together for about six months, right? 21 A. Yes. 22 Q. He had problems with cocaine? 23 A. Yes. 24 Q. And then you and he took a break for a 25 couple of months, right? Page 633 1 A. Yes. 2 Q. And then he smashed glass all over your 3 house, right? 4 A. Yes. Q. And then he took his fist and he hit you 6 across the left side of your face, right? 7 A. Yes. 8 Q. And then your mother came and he picked 9 her up and threw her across the kitchen, didn't he? 10 A. Yes. 11 Q. And then he smacked your roommate in the 12 face and threw her into the wall, is that right? 13 A. Yes. 14 Q. Was all of that traumatic to you? 15 A. That night. 16 Q. And you represented to the court under 17 oath that you feared for your life; is that right? 18 A. Yes. 19 Q. And you were very scared of him? 20 A. Yes. 21 Q. And he damaged you and your son. You felt 22 that both of you were in jeopardy; is that right? 23 A. Yes. 24 Q. And he also had knives and he told you he 25 had a gun in addition; is that right? 1 A. Yes. 2 Q. And then you got back toge 3 right? 4 A. Yes. 5 Q And you had peat intimacy 6 words, right? 7 A. Okay. 8 Q. But that he was very jealou 9 A. Yes. 10 • Q. Is that accurate? 11 A. Yes. 12 Q. And you also said that on 13 . he got very violent He was 14 wouldn't let you get off your bed. 15 that? 16 A. Yes. 17 Q. He wouldn't let you get to 18 would he? 19 A. Correct. 20. Q. And when you went into 21 living room he grabbed you by yo 22 you back into your bedroom. Doy 23 A. Yes. 24 Q. And then he slammed you 25 several occasions, correct? Page 632 ther again, to use your s. March 10th, '07, restrainingyou, and he Do you remember our phone, the room, in the r neck and dragged ou remember that? on the bed on (561) 832-7500 Page 634 1 A. Yes. 2 MR. LUTHER: Let's mark this as our next, 3 whatever number we're on. 4 THE COURT REPORTER: Five. 5 MR. LUTTIER: Five. 6 (Defendants Exhibit No. 5 was marked for 7 identification) 8 BY MR. LUITIER: 9 Q. Let me show you what is now marked as 10 Exhibit Sand ask you if that's a copy of the 11 Petition for Injunction Against Domestic Violence 12 that you filed? Is that your signature on that 13 Petition.for Injunction Against Domestic Violence? 14 A. Yes. 15 Q. Now, this injunction references two 16 incidences, one dated November 23rd, '06 and one 17 dated March 1011), '07, right? 18 MR. EDWARDS: Same exhibit? 19 MR. LU'FIIER: Yeah. 20 BY MR. LUTHER: 21 Q. Correct? 22 A. • Yes. 23 Q. Now, there was another incident that 24 happened April 2nd of'07, wasn't there? 25 A. Yes. 34 (Pages 631 to 634) PROSE COURT REPORTING AGENCY, INC. '(561) 832-7506 Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkIns (601-051-976-2934) b5542fel-d299-4e4f-Sba6-85aad27f4405 EFTA01108885 1 2 3 4 5 6 7 8 Page 635 Q. And on that — A. This is, this is the day that he found me at my new house. Q. That's April 2nd of'07 is when he found you in your new house? A. Yes. Q. And he forced himself in? A. Yes. 1 2 3 4 5 6 7 8 Page 637 A. Yes. Q.. And then he threw the knife? A. Yes. Q. Then he picked you up — MR. LUIFIER: Or strike that. BY MR. LUTTIER: Q. And at that point you were seriously in fear for your son's and your life? 9 Q. And you were in your new house with your 9 A. Yes. 10 son, correct? 10 MR. LD7T1ER: Let me math that as 6, our 11 A. Yes. 11 next. And ask you if you can identify this 12 Q. Now, this incident scared you, didn't it? 12 document. 13 A. Yeah. 13 (Defendants Exhibit No. 6 was marked for 14 Q. I mean, he, he broke into your house. He 14 identification.) 15 took you. He took a knife. He put it in front of 15 THE WITNESS: I've had some crazy 16 your face and said I could kill you and your son, 16 boyfriends, but for three years everythings 17 didn't he? 17 been fine. 18 A. Yes. 18 BY MR. (MITER: 19 Q. And you were, when the police arrived, you 19 Q. Let me show you what has been marked as 20 were visibly shaking, you were crying and you were 20 Exhibit 6. Is that a copy of the Petition for 21 holding your son; isn't that right? 21 Injunction Against Domestic Violence that you filed? 22 A. I don't know if I was holding my son, but yes. 22 A. What about it? 23 Q. All right. And you, you swore out a 23 MR. EDWARDS: He was just showing it to 24 complaint to have him prosecuted for aggravated 24 you. 25 battery and false imprisonment, right? 25 THE WITNESS: Yes, I saw it before. Page 636 Page 638 1 A. Yes. 1 BY MR. LIJMER: 2 Q. I mean, this guy scared you, didn't he? 2 Q. Is that the copy of the petition that you 3 A. Yeah. 3 filed. That is it has your signature on it? 4 Q. And you filed an injunction for domestic 4 A. Yep. 5 violence on that incident on April 17th of'07? 5 Q. And then in August of'07, you then had a 6 A. Yes. 6 domestic v' ion with your then new 7 Q. Did you say yes? 7 boyfriend, a did you not? 8 A. Yes. 8 A. Y iinall 9 Q. And there you said under oath, that he 9 Q. And had grabbed you by the arm 10 kicked your door in at 3:00 in the morning, rushed 10 and pulled you through the house; is that right? 11 in your son's room, grabbed him up and took him in 11 A. Yeah. 12 the bathroom; is that right? 12 Q. And then he picked you up and brought you 13 A. Yes. 13 upstairs and wouldn't let you come down; is that 14 Q. That scared you, didn't it? 14 correct? 15 A. Yes, it did. 15 A. Yes. 16 Q. And after you got up and he grabbed the 16 Q. He literally picked you up and took you up 17 knife, he then kept you from getting off your bed 17 the stairs? 18 and told you he was going to kill you, didn't he? 18 A. He made sure I got up the stairs, yeah. 19 A. Yeah. 19 Q. How did he do that? 20 Q. And then he said he was going to kill your 20 A. He like grabbed my waist and make sure I went 21 son, right? 21 upstairs. 22 A. Yes. 22 Q. And why was he taking you upstairs? 23 Q. And he told you he was going take your 23 A. Because he did not want me to be downstairs. 24 insides of your body and shove them down your 24 Q. Okay. And your son was present for this, 25 throat didn't he? 25 ri ltt? (561) 832-7500 35 (Pages 635 to 638) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) b5542tef-d299-4e4f-9ba6-85aad2714405 EFTA01108886 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 639 A. He was sleeping. Q. Okay. And as a result of that incident, you were afraid, correct? A. Yes. Q. You had — A. Because I went through it before. Q. You what? A. Because I went through it before. Q. And you swore out a complaint for a battery against him, did you not? A. Yes. MR. LUTHER: I need to take a quick break. THE VIDEOGRAPHER: Going off the record at 4:19 p.m. (A brief recess was held.) THE VIDEOGRAPHER: We're back on the record at 4.30 p.m. BY MR. LUTTIER: Q. Do you actually, yourself, call Mr. Epstein's home asking him if you could come work, did you not? MR. EDWARDS: Object to the form, predicate, time-frame. Page 641 1 A. No. 2 Q. Do you know if any of them have consulted 3 with any lawyers about that other than your lawyers? 4 A. No. What they want to sue me along with 5 Jeffrey? 6 Q. Have you ever discussed yourself with them 7 their feelings about you having taken them to see 8 Mr. Epstein? 9 A. Yeah. 10 Q. And what did they tell you? 11 A. Jane Doe is very sensitive towards it. She 12 didn't like it at all. She just was a poor little girl 13 that I guess was influenced by me to go to Jeffrey's 14 house. 15 Q. But I mean has she ever asked you why did 16 you do that knowing what you knew or anything like 17 that or said she holds you responsible? 18 A. Ina way. 'don't 'mow the exact words but 19 she's definitely came to me and said why would you even 20 do that, why would we go there? You lmow, it, it hurts 21 our self-esteem. 22 And in M.'s aspect she was extremely 23 scared to go the first time. And me being one of 24 her best friends at the time, she just finally wont 25 after I begged her many times when I couldn't fad Page 640 1 BY MR. WITTER: Q. During this period of time that you were 3 going to see Mr. Epstein. Sometimes you called and 4 asked his people at his house whether, you know, you could come work, did you not? 6 A. Yeah. Because he told me to call if I had a girl. SO, l would call and ask is he available. 8 Q. Now, I want to ask you a couple questions 9 about your two friends, Jane Doe and again M . 10 A. Excuse me. 11 Q. You took Jane Doe to Mr. Epstein, did you 12 not? 13 A. Yes, I did. 14 Q. How many times did you take her? 15 A. I don't know. 16 Q. Has Jane Doe or III. or anyone else that 17 you took to Mr. Epstein discussed with you or anyone 18 else that you know of the potential for them suing 19 you? 20 A. Who suing me? 21. Q. Any girl that you took to Mr. Epstein. 22 A. No. • 23 Q. Do you know if any of them talked to their 24 lawyers about suing you as a result of you taking 25 them to see Mr. Epstein? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 642 any other girl. And no, they both didn't like it. Who would like it? Q. Did you have any friends better then M, You know, would you consider her, she was your best friend, or is your best friend? A. At that time, no. Q. Who is your best friend now? A. Q. .How about now? A. My son. Q. Okay. Other than your son, a friend not family. Is she, is she your best friend still? A. Jesus, myself, my son. Why are you looking at me crazy? Q. Is she your best friend was the question. A. I don't have a best friend. Actually, yes, l do. Faith Skyman. Q. Who? A. Faith. Q. Who is she? A. My son's God mother. Q. Is she another person that is suing Jeff Epstein? A. Nope. She was affiliated with who died. (561) 832-7500 36 (Pages 639 to 642) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601461.976.2934) Electronically signed by cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (6014151.976-2934) b5542fef-d299-4e4f-9bar3.85ead27f4406 EFTA01108887 Page 645 Page 643 1 Q. What, Faith Skyman, S-k-y-m-a-n? 2 A. Yeah. 3 S How was she affiliated with 5 A. She was good friends with her and I met 6 through her. And I took 7 to Jeffrey Epstein's house. 8 Q. Where does Faith Skyman live? 9 A. Rhode Island. 10 Q. Do you have the phone number for this 11 babysitter you say you use? 12 A. Yes. 13 Q. Debra Carrot? 14 A. Yes. 15 Q. What's her number? 16 A. I don't know it off the top of my head. 17 Q. Is she listed in the phone book? 18 A. Probably. 19 Q. Is she — you say she lives in the 20 Acreage? 21 A. Yes. 22 Q. Is she married? 23 A. No. 24 Q. Have you ever been to her house? 25 A. Yeah. 1 times you actually went? 2 MR. EDWARDS: Form. 3 THE WITNESS: What does that mean? 4 MR. EDWARDS: Answer if you know what that 5 means. Do you have physical proof, videotape. 6 Answer his question if you know what the answer 7 is.. THE WITNESS: No. No one videotaped me 9 and no, we didn't keep a log, no. 10 BY MR.. LUTI1ER: 11 Q. There is no record that you could consult 12 that would say I know I went 21 times or exactly how 13 many times because you kept a record of it? 14 MR. EDWARDS: Fonn. 15 THE WITNESS: No. 16 MR. EDWARDS: This is outside of whatever 17 records are in your client's possession. 18 BY MR. LUTTIER: 19 Q. And since you and Jane Doe and are 20 all represented by the same lawyer, do you recognize 21 that there is an inherent conflict amon:tathree 22 of you in terms of any accusations that M. and 23 Jane Doe would have against you for taking them to 24 Mr. Epstein? 25 MR. EDWARDS: Object to the form. Page 644 1. Q. Does she rent, does she own, do you know? 2 A. No. 3 Q. Live alone or with somebody else? 4 A. Her brother. 5 Q. Same last name -- 6 A. I don't know. 7 Q. — as her and her brother, last name is Carrot? 9 A. I don't know. 10 THE VIDEOGRAPHER: Your mic is on your 11 chair. 12 BY MR. WITTER: 13 Q. Now, you've told us when you believe you 14 first went to Jeffrey Epstein and when you went the 15 last time. If 1 -- and I may have asked you at the 16 last deposition: You have no physical proof of when 17 you actually went, right, the actual dates that you 18 went? 19 MR. EDWARDS: Object to the form. 20 MR. LUTTIER: That would be like a 21 calendar or notes, something like that. 22 MR. EDWARDS: Form. 23 THE WITNESS: Nope. 24 BY MR. LUTTIER: 25 Q. And you have no physical proof of how many (561) 832-7500 PROSE Page 646 THE WITNESS: I don't understand what the 2 hell — 3 BY MR. LUTTIER: 4 Q. There is a conflict of interest. 5 Mr. Edwards can't represent one, one client suing 6 another one of his clients; you recognize that, 7 don't you? 8 MR. EDWARDS: Form. 9 THE WITNESS: Okay. 10 BY MR. WITTER: 11 Q. Have you seen Jane Doe's deposition? 12 A. No. 13 Q. Have you been told anything about it? 14 A. No. 15 O. Have you been told anything about 16 case? 17 A. No. 18 Q. Who is actually representing you now? Do 19 you know the name of the law firm that now 20 represents you? 21 A. Whatever this law firm's called. 22 Q. Is it — did you sign a new fee agreement 23 with the new law firm? 24 25 A. Yes. ......„amia ll ihasniw o it's whatever firm 37 (Pages 643 to 646) COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601-051.076-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkIns (601.051476.2934) b55421ef-d299-4e4f-9ba6.85and2714405 EFTA01108888 Page 647 1 with? 2 A. Yes. 3 Q. And did you ever meet any of the people 4 from the Rothstein, Adler firm? 5 A. No. 6 Q. Did you meet any investigators from the 7 Rothstein, Adler firm? 8 A. No. 9 Q. Have you ever been interviewed by any of 10 the investigators from there? 11 A. No. 12 Q. Do you know a man by the name of Jay 13 Hawell? 14 A. No. 15 Q. Have you ever heard of his name? 16 A. Of Jay Hawell? 17 Q. Jay Hawell, 18 A. No. 19 Q. Do you have this babysitter's phone number 20 in your cellphone? 21 A. No. I don't keep it in my cellphone. 22 Q. You, you don't keep your babysitters 23 number in your cellphone? 24 A. No. 25 Q. And you don't have it memorized? Page 648 1 A. No. 2 Q. So, what do you have to do when you want 3 to call a babysitter? 4 A. It's at home. 5 Q. So, if you're out and about and you need 6 to call the babysitter and tell her you'll be — 7 A. I usually keep it in my purse. Q. — there late you don't have any way to do 9 that until you get home? 10 A. I usually keep it in my purse and I am not 11 late. 12 Q. Where do you keep it? Do you have a phone 13 book in your purse? 14 A. No. I have a piece of paper with her number. 15 Q. Okay. Do you have that with you here 16 today? 17 A. No. 18 Q. So, as you sit here today you do not have 19 on your person anywhere Ms. Carrot's phone number, 20 is that right? 21 A. I do not have her number with me, no. 22 Q. Do you know somebody by the name of Paul 23 Cassel (phonetic)? 24 A. No. What time is it? 25 Q. 4:41. 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19. 20 21 22 23 24 25 Page 649 A. Okay. I have to pick my son up by 6 so — MR. EDWARDS: Well be done. BY MR. LUTTIER: Q. At the beginning of this deposition you asked a question about whether or not somebody else was going to be here I think on behalf of you. And you made some reference to somebody you had met with about this deposition. Do you recall making that statement, asking whether or not this other person was going to be here? A. Uh.huh, yes. Q. Who were you referring to? A. His name is — I don't know his name. Q. Is it a lawyer? A. He's an attorney. Q. Not a paralegal. A guy named Farmer, Mr. Farmer? A. Ideal know. Q. Have you met this other person? A. Yes. Q. Where did you meet this other person? A. At the law firm. Q. Mr. Edward's law firm? A. Yes. Q. Down in Fort Lauderdale? Page 650 A. Yes. Q. So, you've been down to his new law firm? 3 A. Yes. 4 Q. Did you review anything in preparation for 5 today's deposition? 6 A. Yesterday I talked to my attorney. 7 Q. Did you review any documents? 8 A. I reviewed a document, yes. 9 Q. What document? 10 A. I don't know. I don't know what document, 11. sir. Sorry. 12 Q. You say you reviewed a document or 13 documents? 14 A. I reviewed a document. 15 Q. One piece of paper? 16 A. A few, a few pieces of paper. 17 Q. Okay. What were they? What did they have 18 on them? 19 MR. EDWARDS: Objection as to this line of 20 questioning calls for attorney-client privilege 21 information. She's not going it answer it as 22 to exactly what we went over in preparation for 23 the deposition. 24 BY MR. LUTTIER: 25 O. Other than notes mated b our la er 38 (Pages 647 to 650) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. • (561) 832-7506' Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) b5542lef-d299-4e4f-gba6-85aad2714405 EFTA01108889 Page 651 which I don't want to know about, did you review any 2 other documents in preparation for your deposition? 3 A. No. I have to be out of here at 5:30. 4 Q. Are you aware of the fact that the U.S. 5 attorney has alleged that your, the firm that 6 represented you initially, the Rothstein, Adler 7 firm, they've, they've alleged that it was a 3 criminal enterprise? 9 A. I heard that they did some naughty acts, yeah. 10 MR. EDWARDS: Form. 11 BY MR. LUTHER: 12 Q. And that the head of their firm was 13 charged with criminal racketeering? 14 A. Yes. 15 Q. Did you ever hear any specifics about 16 that, why they were charged with those things? 17 A. Some guy took some money. I don't know. I 18 don't care. 19 Q. Did you hear where, where he was getting 20 the money from? 21 A. No. 22 Q. Did you ever hear anything about how your 23 case may have been involved in any of that? 24 A. No. It's irrelevant to me right now. 25 Q. Does that mean you have never heard Page 653 1 in the garbage. 2 Q. Well, at the time we took your deposition 3 in September, you told us under oath that it was at 4 your home. Did you do something with it since -- 5 A. No. 6 Q. — your deposition on September 24th? 7 A. No. 8 Q. Well, it just didn't disappear, did it? 9 MR. EDWARDS: Form. 10 THE WITNESS: No. Me you being sarcastic 11 with me? 12 BY MR. LUTHER: 13 Q. No. I mean you had to do something with 14 it, right? 15 MR. EDWARDS: Form. 16 THE WITNESS: I didn't touch it. I can't 17 find it. I don't know where it is. It's not 18 in the house, so, song. 19 BY MR. LUTHER: 20 Q. Well, where did you think it was when you 21 testified definitively that it was in your home? 22 A. I thought it was in a couple of my papers that 23 I have and it's not. I thought it was where my Social 24 Security card was. It's not them, sir. End of 25 discussion. Page 652 1 anything or you just disregarded what you heard? 2 A. I disregarded what I heard. 3 Q. So, what did you hear? 4 MR. EDWARDS: You're asking her though 5 what she heard outside of any conversation with 6 me obviously? 7 MR. LUTHER: Yeah, oh, yeah. I don't 8 want you to tell me, I don't want you to ever 9 tell me anything your lawyer told you. 10 THE WITNESS: Oh, no, I didn't hear 11 nothing. 12 BY MR. LUTTIER: 13 Q. Okay. Now, in your previous deposition 14 you indicated that you had a book. I think you said 15 it had a red — it was a red book. !don't remember 16 if the color was right and you said it had a Bible 17 verse on it. Do you remember that testimony? 18 A. Yes. 19 Q. And at that deposition you told us 20 definitively that you had that at your home? 21 A. Yes. 22 Q. Where is that book now? 23 A. I can't find it. It's nowhere to be found. 24 Q. Well, what did you do with it? 25 A. I don't know. I moved a lot so it's probably Page 654 1 Q. Do you know the names of any of your 2 clients that you had when you were working — other 3 than the ones you've aheady identified here, 4 clients you had when you were working for any of the 5 escort services? 6 A. No. Why would they want me to know their 7 names? I don't want to know their names either. 8 Q. I have no idea. 9 A. They have wives. 10 Q. All your clients have wives? 11 A. Probably. We don't — it's not about 12 relationships, man. It's about — 13 Q. When you were working for those -- 14 A. — money and out. 15 Q. — escort services, you were performing 16 sexual favors for their clients? 17 A. Okay. What about it? 18 MR. EDWARDS: Form 19 MR. LUTHER: Right? 20 MR. EDWARDS: Form. 21 BY MR. LUTHER: 22 Q. Did that give you any cause for any guilt 23 or feel bad about the fact that'you were out having 24 sex with married men? 25 A. Of course. • (561) 832-7500 39 (Pages 651 to 654 PROSE COURT REPORTING AGENCY,'INC.' (561) 832-7506 Electronically signed by cynthla hopkins (901.051476.2934) Electronically signed by cynthia hopkins (601.051.976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) b55421ef-d299.4e41-9ba6.85aad2714405 EFTA01108890 Page 655 1 Q. Well, why did you do it? 2 • A. That's all I know. It's what Jeffrey taught 3 inc. 4 Q. Did you — well, you could have had sex 5 with single people, couldn't you? 6 A. Yeah. 1 Q. Well, Jetty wasn't married, was he? 8 A. I don't know. 9 Q. Well, did you ever ask him? 10 A. He lied to me about everything. 11 Q. Did you ever ask him? 12 A. Yeab, I think I did. 13 Q. And what did he tell you? 14 A. He said no. 15 Q. Do you have any information that Jeffrey 16 Epstein is married? 17 A. No. 18 Q. Do you have any information that he was 19 ever married when you were -- 20 A. No, and I don't care. 21 Q. So, you would agree with me that giving 22 massages to a single man is different than having 23 sexual intercourse with a married man, wouldn't you? 24 A. Yeah, it's wrong. 25 Q. And Page 657 1 And you know I don't want to do this in the 2 future. I absolutely despise what I do. I 3 hate what I do. I don't want to do what I do. 4 This is what I have learned from Jeffrey 5 Epstein and I hate it, and I can't wait to get 6 out of it. 7 BY MR. LUTTIER: 8 Q. That's what you said in June of '09, 9 wasn't it? 10 A. Yeah. 11 Q. Didn't stop you, did it? You still went 12 ahead and you keep on doing the same thing you've 13 always done? 14 MR. EDWARDS: Form. 15 BY MR.. LUTTIER: 16 Q. — bentledl you want the money, isn't that 17 right? 18 A. Yeah. 19 Q. That's the — the bottom line is -- 20 A. Well, actually I put myself through school 21 through it. 22 Q. The bottom line is — 23 A. I wanted to go back to school. Bottom line, I 24 wanted to go back to school so I did it to go to school. 25 Q. Well, have you saved up money to go to Page 656 1 A. Ifs wrong either way. 2 Q. So, wouldn't you agree with me, I mean, 3 doesn't the fact that you're out making a living, 4 having sexual relations with married men, cause you 5 any kind of grief or psychological trauma as opposed 6 to giving a massage to a single man? 7 A. Yes. 8 Q. So, how do you — 9 A. Actually — 10 Q. — justify yourself of the fact that -- 11. A. Married or single, it still causes me to feel 12 guilty about it. It's not the right thing to do. 13 Q. Well, how do you, how do you justify going 14 around getting paid money and taking men that you 15 know are married and having sex with them when you 16 know their wives don't know what you're doing? 17 A. How do you justify you sitting here 18 representing a pedophile? You know? You're silly. But 19 I'm sorry. 20 MR. LUTTIER: Move to strike? 21 THE WITNESS: I don't know. 22 MR. LIMIER: And now answer my question. 23 THE WITNESS: I have to go home every day 24 and put a poker face in front of my son. 25 don't ever want him to know what I have done. Page 658 1 school? 2 A. Yes, I did. 3 Q. How inch have you saved? 4 MR. EDWARDS: Form. 5 THE WITNESS: It's none of your business. 6 BY MR. LUTTIER: 7 Q. Where's the money? 8 A. None of your business. 9 MR. EDWARDS: Form. 10 BY MR.. LUTTIER: 11 Q. Got it in a bank account? 12 MR. EDWARDS: Form. 13 'ME WITNESS: It's none of your business. 14 BY Kt. LUTTIER: 15 Q. Well, how are we going to test the 16 credibility of what you say when you say you saved 17 money unless we know where it is? 18 A. Who cares? Who gives a shit if you, if I save 19 money or not and if I -- you know, the money I saved, 20 who cares. You got money? 21 Q. Well, your justification as I understand 22 it for doing what you do is so that you can save 23 money to go to school, is that right? 24 A. Yeah, and sorry son can go to Christian 25 school. (561) 832-7500 PROSE COURT REPORTING 40 (Pages 655 to 658) AGENCY, INC.. (561) 832-7506 Electronically signed by cynthia hopkins (8014514184934) Electronically signed by cynthia hopkins (801-051-978-2934) Electronically signed by cynthia hopkins (801 451476-2934) b5542fet•d299-4e41-9ba6-85aad27f4405 EFTA01108891 Page 659 1 Q. So, I am asking you, did you save money 2 and if so where is the money? 3 MR. EDWARDS: Form. 4 THE WITNESS: Yeah. 1 saved money and 3 it's under my bed. 6 MR. EDWARDS: Don't be sarcastic. Just give him an answer, the truth. 3 THE WITNESS: No, Fm not. It's under my 9 bed with rubber-bands. 10 BY MR. LUTTIER: 11 Q. All right. Well, how much have you saved 12 then since it's under your bed? 13 MR. EDWARDS: Object to the form. 14 BY MR. LUTTIER: 15 Q. How much have you saved? 16 MR. EDWARDS: Form, asked and answered. 17 Harassing at this point. 18 BY MR. LUTTIER: 19 Q. Do you have a record of it anywhere? 20 A. Nope. I have headache. 21 Q. Have you ever applied, applied for 22 financial assistance at any college or university? 23 A. Yes. 24 Q. Where did you apply for assistance? 25 A. Through the Academy of Health and Beauty. 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 660 Q. And did you get any financial aide? A. Yep. Q. What? A. Yeah. Q. Was that the loan you described earlier? A. Yes. Q. So, you have been able to finance your education by simply applying for financial aide? A. Correct. Q. So, you didn't have to do what you're doing in order to go to college. A. Thad to finance and then I had to make the money back to pay for it. I don't have a mommy and daddy that takes care of me and I am not going to be working at Burger King. Q. What's wrong with working at Burger King? A. You make $7 an hour. Q. And thafs really why you do what you want to do is you don't want to go get a job that pays less than the amount of money you can make doing what you do, isn't that right? A. No, you're wrong. MR. EDWARDS: Object to the form. BY MR. LUTHER: Page 661 1 A 1 Ma 2 Q. How many jobs have you applied for? 3 A. I used to work at Revitese Day Spa being an 4 esthetician. 5 Q. How many — in the last two years, how 6 many jobs have you applied for? 7 A. I actually worked under the table for the Post B Office sending out things for amazon.com. I do side 9 jobs. I do cleaning jobs. There is a lot of jobs I do 10 to make money. 11 Q. First of all, my question was how many 12 jobs have you applied for in the last two years? 13 A. In the last two years probably five, and I 14 have got them all. 15 Q. Okay. Where did you, where did you put in 16 your applications for these five jobs? 17 A. One for a personal place, amazon.com. 18 Q. What do you mean a personal place? 19 A. Amazon.com and then E-Bay. 20 Q. Wait a minute. Is, is the personal place 21 that you applied something different than 22 amazon.com? 23 A. No. Ifs just amazon.com. 24 Q. So, the big company, amazon.com, you 25 submitted an application? Page 662 1 A. Yeah. 2 Q. And did you get hired? 3 A. Yep. 4 Q. Okay. How much did they pay you? 5 A Fifteen bucks an hour. 6 Q. So, you were able to get jobs in the labor 7 market just like everybody else, right? 8 A. Yeah. 9 Q. Where else did you apply? 10 A. I have applied Revitese Day Spa. 11 Q. Where? 12 A. Revitese Day Spa. 13 Q. Okay. In the last two years? 14 A. Yeah. 15 Q. And did you get hired? 16 A. Yep. 17 Q. And how much did they pay you? 18 A. Twelve an hour. 19 Q. Okay. So, you can get that job. Are you 20 still working for amazon.com? 21 A. No. 22 Q. Why did you quit? 23 A. It was seasonal. 24 Q. Are you still forking for Revitese Day Q. You could go work at Bur Kit2A riet? 2 5 Spa? (561) 832-7500 41 (Pages 659 to 662) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Bectronteeliy signed by eynthia hopkins (601.061.978-2934) Electronically signed by Cynthia hopkins (601.061.976-2934) Electronically signed by cynthia hopkins (601.061.976-2934) b5542fef-d299.4e41-9ba6-85aad2714405 EFTA01108892 Page 663 Page 665 1 A. Nope. 2 Q. Why did you quit? 3 A. The economy just went down and she only could 4 hire me three days out of the week so — Q. Where else did you apply in the last two 6 years? 7 A. I always sell stuff on ebay. 8 Q. Well, that's not an application, is it? 9 A. Well, you got to sign up to get on ebay. 10 Q. That's just you selling stuff that you 11 have on ebay? 12 A. Okay. Well, if that's how you want it. 13 Q. Where else have you applied for a job? 14 A. I've been at Petco and they paid me under the 15. table. 16 Q. When did you apply fora job at Petco? 17 A. Last year. 18 Q. What did you do for them? 19 A. I washed the dogs. 20 Q. Okay. How much did you get paid? 21 A. That was like $9 an hour. 22 Q. Okay. Where else did you apply? 23 A. Cats Gymnastics. 24 Q. What did you do there? 25 A. I was one of the instructors for the four and 1 A. Ten dollars an hour. 2 Q. And when was the last time you did that? 3 A. Like before I went to New York. 4 Q. And whose houses, did you clean the same 5 clients' houses? 6 A. It's just actually friends' houses. 7 Q. Anyplace else you've applied for work? 8 A. No, that I can recall. 9 Q. You said you worked for the U.S. Postal 10 Service. Did I hear that? 11 A. Well, that was for, that's incorporated with 12 amazon.com. 13 Q. The United States Post Office never 14 employed you, did they? 15 A. That is in — intertwined with amazon.com. 16 Q. My -- listen to my question. The United 17 States Post Office never employed you, did they? 18 A. No. I didn't apply for the U.S. Post Office, 19 so they couldn't deny me. 20 Q. Well, you suggested they were paying you 21 under the table. The United States Post Office 22 never paid you under the table. 23 A. I never, l never worked for the U.S. Post 24 Office, sir. So keep on bring it up so we can keep on 25 going over it again. Page 664 1 five-year-old group. 2 Q. And, and how much did you get paid for 3 that? 4 A. Nine dollars an hour. 5 Q. And are you still working there? 6 A. No. 7 Q. Why not? 8 A. Because it's not paying the bills. 9 so, you quit? 10 A. Yeah. 11 Q Did you quit Petco? 12 A No. 13 Q. Did they fire you? 14 A. No. 15 Q. Still there? 16 A No. 17 Q. What happened? 18 A. They, they just needed help fora couple 19 months. 20 Q. Okay. Any other places you have applied 21 for jobs? 22 A. I clean houses 23 Q. For who? 24 A. —once in a while. For people. 25 Q. How much do toticet paid to clean a house? .(561) 832-7500 • Page 666 1 THE WITNESS: What time is it? 2 MR. EDWARDS: You got time. It's 5. 3 BY MR. LUTTIER: 4 Q. Do you still have an adult entertainment 5 license? 6 A. Yep. 7 Q. Is it current? 8 A. I don't know. I don't use it. 9 Q. Were you provided with a copy of a 10 document that's called a proposal for settlement in 11 this case? 12 A. I don't know: Was 1? 13 Q. I mean l can show it to you. !don't want 14 to mark it on the I don't want to have it in the 15 record because I don't want it to be a — but I will 16 show it to you so you can recognize the document. 17 Let me just show you the document. 18 • . A. You can't help me. 19 Q. Just go ahead and read it. 20 A. Jeffrey Epstein is not admitting, he is in 21 fact denying all liability or responsibility because he 22 did it - 23 THE COURT REPORTER: If you could read -- 24 MR. EDWARDS: Just read it to yourself 25 because if you say the words, she has to take 42 (Pages 663 to 666) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthia hopkins (601481-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-081-976-2934) b55421e1-c1299.4e41-9ba6-85aad2714405 EFTA01108893 Page 667 Page 669 1 them down. 2 THE WITNESS: Oh, okay. I don't want to 3 read anymore. I'm good. 4 BY MR. LI/171ER: 5 Q. Did you see that — 6 A. Yeah. 7 Q. Have you seen that before today? 8 A. You know what, send Jeffrey to jail for 20 9 years and then I will take zero dollars. I need 10 justice. I want what's fair for all of us, for all of 11 us guts. 12 Q. What you want is money, right? 13 A. No. I want justice and 1 want what's fair. 14 And what's fair is that he should serve jail time. He 15 didn't sense jail time forme and my girlfriends. He 16 sat with his little rich bus 17 Q. And who told you that? 18 A. — in a little office doing community service 19 which was probably nothing for him because money talks. 20 And you know what, I want justice. So, I tell you what, 21 give me no money right now and send Jeffrey to jail for 22 20 years, and lwill walk out of here with a smile from 23 ear to ear. 24 Q. Have you ever gone to jail, ma'am? 25 A. Nope. 1 A. 2 Q. Do you — well, other than the fact that 3 you're out tmtil 5:00 -- 4 A. Actually, I tun prescribed'. 5 Q. Other, other than the fact that you're out 6 until 5:00 in the morning at strip clubs, do you 7 have any problem sleeping? 8 A. Oh, you're so cute. I have trouble sleeping 9 over Jeffrey, yeah. :0 Q. Well, I mean, it doesn't keep you from 11 going out to Spearmint Rhino's until 5:00 in the 12 morning, does it? 13 A. It keeps me up. 14 Q. Okay. 1 5 A. People got to do what you got to do. Just 16 like you got sit here and defend a child molester, you 17 know. I got sit here and go to Speannint Rhino and make 18 money, too. What's the difference, right? 19 Q. Now, you testified lest time that you were 20 a call girl with others. With whom else were you a 21 call girl? 22 A. Girls. I don't know. 23 Q. What are their names? 2 4 A. Fruity-Tutty. I don't know. They have stage 2 5 names. I really could not tell you. Page 668 1 Q. You don't know how long Mr. Epstein was in 2 jail, do you? 3 A. Hamad he was in jail for 18 months but -- 4 Q. You don't know what it was like in jail, 5 do you? 6 A. Oh, God. For Jeffrey, poor old Jeffrey, oh, 7 he went to jail because he molested over 100 little 8 girls. I hope he was molested or rapped, whatever the 9 definition is. He needs more torture than that, jail. 10' Yeah, he needs to stay in there for 20 years, not 18 11 months. 12 Q. What do you think you should do as a 13 result of you having taken a bunch of your best 14 friends and girlfriends and knowing exactly what was 15 going to happen in taking them to Jeffrey Epstein? 16 A. Call all of them and say, I am sorry,1 was 13 17 years old, I apologize for being naive and a stupid 18 little girl and I hope that everybody can get 19 counseling. And 1 hope that everybody can get served 20 justice. I hope we can see Jeffrey's face in the 21 newspaper saying that finally this jerk-off is in jail 22 for 20 years, and now all of us can go to sleep 23 'peacefully. 24 Page 670 1 Q. Well, did you guys work together? 2 A. A few times. 3 Q. And when you say you worked together, what 4 does that mean? 5 A. That we worked together. 6 Q. Does that mean the two of you would go out 7 with one person or you meant the two of you would 8 nm a service together? 9 A. Run a service together, what does that mean? 10 Q. Well, I don't know. Tell me how you and 11 your, any other girl worked together in the escort 12 business or the call-girl business? 13 A. Either we would make, you know, we would 14 either call two guys and go out with two guys, have a 15 nice diluter, get paid for it, orwe would go together 16 and have one guy pay for it or — 17 Q. Well, this is, your answer was we were all 18 call girls together. That means you were having sex 19 with guys, right? 20 MR. EDWARDS: Object to the form. 21 THE WITNESS: No. 22 BY MR. LUTTIER: 23 Q. Oh, a call girl to you doesn't indicate 24 you were having sex? 25 A. No, sir. (561) 832-7500 43 (Pages 667 to 670) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Cynthia hopkins (801-051-976-2934) Electronically signed by Cynthia hopkins (601-051-976-2934) Electronically signed by synth's hopkins (801-061-976-2934) b5542fef-d299-4o41-9ba6.85aad2714406 EFTA01108894 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 671 Q. Well, when you were, before you were doing 2 your escort service, when you were doing escort 3 services for others, you were having sex with your 4 clients, weren't you? A. Sometimes. So, will Jeffrey go to jail for 20 6 years if he gives nobody money or he can't stand it? 7 Q. Have you sold any interest in this lawsuit S to anybody? 9 A. No. 10 Q. In other words have you received money 11 from anybody and in return given them an interest in 12 this lawsuit? 13 A. No. 14 Q. Have you received any money or any other 15 kind of consideration from any company with respect 16 to this lawsuit? 17 A. No. 18 Q. Any attorney with respect to this lawsuit? 19 A. No. 20 Q. Any other person with respect to this 21 lawsuit? 22 A. No. 23 Q. Have you been provided any money advances, 24 that is money — 25 A. No. 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 Page 673 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH the undersigned authority, certify that M. personally appeared before me and was duly sworn on the 9th day of February, 2010. Dated this 19th day of February, 2010. Cynthia Hopkins, RPR, FPR 17 Notary Public - State of Florida My Commission Expires: February 25, 2011 My Commission No.: DD 643788 Page 672 Q. — as an advance against an outcome in 2 return for a sharing of the percentage of it? 3 A. No. Q. Have you assigned any interest in this lawsuit to anyone? A. No. MR. LUTTIER: Okay. Fm done. Any cross? MR. EDWARDS: We'll read. THE V1DEOGRAPHER: Going off the record at 5:05 p.m. This is the end of Tape 3 of the deposition. THE COURT REPORTER: Do you want to order this? MR. LUTT1ER: Yes. THE COURT REPORTER: Would you like a core MR. EDWARDS: Yes, please. (Witness excused.) (Deposition was concluded.) 1 2 3 4 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH 5 ;Cynthia Hopkins, Registered Professional Regency. Florida Professional Repents and Notary 6 Public in and for the State of Florida at large, do hereby otraly that I v.as authorized to and did 7 report said deposition in stenotype and that the foregoing pages arc a true and cornet transcription 8 of my shorthand notes of said deposition 9 I further cent!), that said deposition usts talsnat the tirne and pace hereinabove set forth 10 and that the taking of said deposition was commenced and completed as hereinabove set out. I Ratter certify that lam not anocney or 12 camel of any of the ponies, nor am a relative or employee of any anerney or counsel of party 13 connected with the action, nor am I financially interested in the amen. 14 The foregoing cendicatke of this transcript 15 does not *ply to any reproduction of the same by any meal., Wan' under the dinxt control andfix 16 direction of the certifying reporter. 17 Dated this 19th day of February. 2010 113 19 20 11 21 qA gme, AS ia Hopkins, 22 23 24 25 Page 674 (561) 832-7500 44 (Pages 671 to 674) PROSE COURT REPORTING AGENCY, INC. (561)'832-7506 Electronically signed by cynthia hopkins (601-0614764934) Electronically signed by cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (601-061-976-2934) b5542lol-d299.4044-9ba6-135and27f 4405 EFTA01108895 Page 675 Page 677 I DATE: February 19th, 2030 2 TO. do IAD I. EDWARDS, ESQUIRE 3 FARMER, JAFFE, WEISSING. EDWARDS FISTOS & LEBRMAN. a 41$ Nonh Anshan Avenue Suite 2 5 CASE. NO. CA02205I =OMB RE: vs. Epstein PortC e. Florid' 33101 5 AB Phase take nctesc dal on Tawdry. the 9th of February. 20)0. you gam your deposition lathe abo.e-refinsed mina At that sum; au did not watt ligature. It it now neassay that yea sign you deposition As meant agreed to, the transcript all be : 0 (trashed to you Pro* stout counsel Max read the (oilcan instruolioas carefully. At the end of the transcript you all find in arra sheet As you read you( depOtihon, any t 2 changes or careahoos that you with to make should be noted on the errata that, ding page and his 13 samba of raid things DO NC' wad On the VXMCrird itself. Once you law read the 14 transciipt al need any chmga. be use to Ng and doe the earn tam and return time pages to me If you do not lead and sign the deposition 16 within a reasonabk time, the original. which toe abraly been foiremded n the Wrung attorney, may 17 be filed writ the Oak of the Can lf you ash to waive yaw sigatuir sip your name in the blank 10 arc bottom of his later and tenor it to us 19 Vety aunty yeas. 20 21 22 23 l eo hereby waive my signora 24 2s 15 Cr 49 g ger a 4 5 6 7 8 10 11 12 13 14 15 16 17 Please forward the original signed meta sheet to this office so that copies may be distnlnued to all 18 panics. 19 Under penalty of pajury, I declare that I have mid my deposition and that it is true and correct 20 subject to any changes in form or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 1 ERRATA SHEET 2 IN RE: VS. EPSTEIN 3 DEPOSITIOHopl N OF: arl i ft, PPR CE: TAKEN: February , i 0 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 1 PAGE t LINEN CHANGE REASON I I I 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 676 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH I hereby certify that I have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of 2009. (561) 832-7500 ar- 45 (Pages 675 to 67.7) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 I Electronically signed by cynthia honking; (601-051-976-2934) Electronically signed by cyMhia hopkIns (601-051-976-2934) Electronically signed by cymhla hopkIns (601-051.976.2934) b5542fel-c1299-4O41-9ba6.B5aad27f44O6 EFTA01108896