Page 1

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502008CA037319XXXXMB AB Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF VOLUME I Tuesday, November 10, 2009 11:13 a.m. - 6:12 p.m. 250 S. Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR PROSE COURT REPORTING AGENCY Notary Public, State of Florida West Palm Beach Office (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-901Po7174075 3501.182-102 Page 1 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094347 EFTA01248007 Page 2 1 2 3 U U • • • APPEARANCES: On behalf of the Plaintiff III.: On behalf of Plaintiffs On behalf of Plaintiff 18 On behalf of the Defendant: 19 ROBERT CRITTON, ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN 20 515 North Flagler Drive Suite 400 21 West Palm Beach, Florida 33401 Phone: 561.842.2820 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 2 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094348 EFTA01248008 Page 3 1 On behalf of the Witness: 6 7 ALSO PRESENT: 8 9 MICHAEL DOWNEY, VIDEOGRAPHER 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-75C0 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-90flb7174075 3501.182-102 Pagc 3 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094349 EFTA01248009 1 2 3 4 EXHIBITS Page 4 NUMBER DESCRIPTION PAGE 5 6 Plaintiff: 7 Exhibit number 1 Notebook page 14 8 Exhibit number 2 Photograph 134 9 Exhibit number 3 Photograph 137 10 Exhibit number 4 Photograph 138 11 Exhibit number 5 Photograph 247 12 13 Defendant: 14 Exhibit number 1 Transcript 140 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f1134663-4dad-94e740ftb7174075 3501.182-102 Pagc 4 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094350 EFTA01248010 Page 5 1 2 3 4 PROCEEDINGS Deposition taken before Sandra W. Townsend, Court Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 - - - 7 VIDEOGRAPHER: We're on the video record. 8 This is the 10th day of November, the year 2009. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 The time is approximately 11:13 a.m. This is the videotaped deposition of in the matter of III., Plaintiff, versus Epstein, Defendant. This deposition is being held at 250 South Australian Avenue, West Palm Beach, Florida. My name is Michael Downey. I'm the videographer, employed by Visual Evidence. Would the attorneys please announce their appearances for the record. MR. Plaintiff III. MR. Plaintiffs MR. • Yes. , on behalf of on behalf of on behalf of MR. CRITTON: Robert Critton, on behalf of (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 5 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094351 EFTA01248011 Page 6 1 Jeffrey Epstein. 2 MS. and 3 here on behalf of witness, 4 THEREUPON, 6 having been first duly sworn or affirmed, was examined 7 and testified as follows: 8 THE WITNESS: So help me God. 9 MR. CRITTON: Let me just note one thing for 10 the record, is -- it's been -- this case for this 11 depo has been noticed both in the State Court case. 12 It's been noticed as well -- cross noticed by at 13 least on behalf of his clients two 14 through eight in the Federal Court case. The only 15 two lawyers who apparently are not here, but they 16 obviously have notice of it. And Mr. didn't 17 notice it, but obviously he's -- cross notice, but 18 he's here -- Mr. on behalf of his three 19 clients, and apparently Mr. Garcia chose, they 20 chose not to come for whatever reason, but they 21 would have received notice from everybody. 22 DIRECT EXAMINATION 23 BY MR. 24 Q. Good morning. 25 A. Morning. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-56634dad-94e7-90ftb7174075 3501.182-102 Page 6 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094352 EFTA01248012 Page 7 Q. Just want to make sure he was done. 2 I introduced myself in the beginning, but my 3 name is . I represent one of the 4 Plaintiffs in a lawsuit filed against Mr. Epstein. And 5 I'm here today to ask you a bunch of questions. 6 As you saw at the beginning, you're under 7 oath. It's just like you're on the stand at trial, 8 except there's no Judge here in the room with us. So 9 when I ask you questions, just give it a breath for a 10 minute because there may be objections for other lawyers 11 in the room. 12 Since there's not a Judge here, nobody's going 13 to rule on those objections, so the lawyer has to put 14 that objection on the record. Just pause for a minute 15 and then if you understand the question, go ahead and 16 answer. 17 The only exception to that rule is, if your 18 two lawyers look at you and say, don't answer that 19 question. At that point I don't want you to say a word. 20 And then they lodge an objection and advise you not to 21 say anything. Okay? 22 A. Okay. 23 Q. If you do answer a question, there's two 24 things I'm going to assume. I'm going to assume that 25 you understood the question being asked and that you're (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663.4dad-94e7-90flb7174075 3501.182-102 Page 7 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094353 EFTA01248013 Page 8 1 2 3 4 answering truthfully. Fair enough? A. Yes. Q. If you don't understand any of my questions, please let me know and I'll be happy to rephrase it 5 until you can understand it. 6 It's a nerve-racking procedure and I know 7 you're nervous. It's delving into very touchy areas, so 8 it's going to be delicate. I'm going to try and handle 9 it as respectfully and delicately as possible, but I am 10 going to have to ask a whole bunch of difficult 11 questions. Okay? Fair enough? 12 A. Understand. 13 Q. Okay. If you would, could you give us your 14 full name, please? 15 A. 16 Q. Where do you currently live? 17 A. • • (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 8 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094354 EFTA01248014 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electron Gaily signed by Sandra Townsend (401.377-676.2895) Elecironicaily signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 9 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094355 EFTA01248015 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 10 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094356 EFTA01248016 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 11 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094357 EFTA01248017 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 12 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094358 EFTA01248018 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 13 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094359 EFTA01248019 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 14 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094360 EFTA01248020 (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 15 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094361 EFTA01248021 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-Ne7-90ftb7174075 3501.182-102 Page 16 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094362 EFTA01248022 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 17 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094363 EFTA01248023 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1,88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 18 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094364 EFTA01248024 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 19 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094365 EFTA01248025 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90ftb7174075 3501.182-102 Page 20 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094366 EFTA01248026 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 21 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094367 EFTA01248027 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 22 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094368 EFTA01248028 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 23 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094369 EFTA01248029 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1038f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 24 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094370 EFTA01248030 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 25 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094371 EFTA01248031 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 26 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrAJON4372 EFTA01248032 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 27 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094373 EFTA01248033 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1,88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 28 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094374 EFTA01248034 ■ ■ 12 BY MR. 13 Q. When is the first time that you ever had any 14 contact with Jeffrey Epstein? 15 A. When? 16 Q. Yes. In other words, what grade were you in 17 or how old were you? However you can peg the time in 18 your mind. 19 A. About 16. 20 Q. So would you have been in about tenth grade at 21 that point? 22 A. Tenth going into my junior year, like, towards 23 the end, beginning of 11th. 24 Q. And how was it that you came to know who 25 Jeffrey Epstein was? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 29 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_ONN4375 EFTA01248035 Page 1 A. I was approached by a: 3 Q. At that point had you just turned 17? 4 A. No. 5 Q. You were still 16 at that point? 6 A. Yes. 7 Q. And III, is ill.? 8 A. I don't know. 9 Q. 10 all? 11 12 not friends. Okay. How did you know A. We went to middle school together, but we were 15 Q. Do you know where she is today? 16 A. No. 17 Q. What were you doing at 19 A. I don't know. 20 Q. Well, is it a members only type of place? 21 A. No. 22 Q. Do you just -- 23 MR. : Wait until he finishes his 24 question. 25 BY MR. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 30 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094376 EFTA01248036 Page 2 S 6 7 8 9 10 Q. Q. How do you get in there? A. You walk in. Q. Is there a charge to get into A. Not the day I met no. Q. Had you been there before? A. Yes. Q. How many times had you been there before? A. I can't recall. Was it a place that you went to regularly at 11 that point in your life? 12 A. Yes. 13 Q. Why would you go there? 14 15 Q. Okay. Can you describe to me? I 17 we talking about 18 somewhere? Are we 19 place? 20 A. 21 or was at that point on the beach 22 23 24 They had on Sundays live music. 25 A. To go swimming, listen to music. mean, are we talking about a club? Are a -- somewhere just on the beach talking about a bar? What is this is a tiki bar on the beach had a bar. It had a restaurant. It had a pool. It was a hotel room. I mean, they had hotel rooms available. Q. Okay. When you would go there in the past, (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 31 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094377 EFTA01248037 Page 1 would you go with friends? 2 A. Yes. 3 Q. Who? 4 A. 5 Q. Anyone else you can think of? 6 A. Not that I can think of. 7 Q. Would you go with or would you go with 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Not . I did go with and at. one point. Q. Okay. When you would go to the beach resort -- and I'm talking about the day before III approaches you now. A. Uh-huh. Q. In the past when you would go there, is it a place you would go just yourself and with friends of would your parents take you there? A. friends. Q. day that you talked to A. Yes. Q. So they were been there before? A. Uh-huh, yes. Usually a place that I would go with my Had your parents ever been there before that familiar of the location and had (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) V8W113-56634dad4404WW17.WM 3501.182-102 Page 32 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O54378 EFTA01248038 Page 33 1 Q. And they would also let you go to this place 2 alone? 3 A. With friends. 4 Q. How would you get there? 5 A. Drive. 6 Q. You? 7 A. Yes. 8 Q. So you would have -- you had a driver's 9 license at 16? 10 A. Yes. 11 Q. Just going back to what we had asked at the 12 beginning. 13 Did you have your own car? 14 A. Yes. 15 Q. What kind of car were you driving back then? 16 Was it the same pickup truck that you had later? 17 A. I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 33 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094379 EFTA01248039 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 34 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094380 EFTA01248040 ml ■ ■ ■ ■ 15 16 before the day that 17 18 time for right now. 19 20 21 22 23 24 with friends? 25 A. Yes. Q. Okay. Once again, this is the period of time approaches you about Jeffrey Epstein. I just want to focus on that period of When you would go to this what was the main purpose of you going there; in other words, why were you going? A. To have fun. Q. Go hang out on the beach, get a tan, hang out. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f1134663-4dad-94e7-90ftb7174075 3501.182-102 Page 35 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094381 EFTA01248041 Page • 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (2 • Would you ever drink there at the MS. : Objection. I've already instructed her not to answer this question. You're just using this example as a back doorway into the same question. We're still prior to her meeting If you have a specific question with regard to that day, please go ahead; otherwise, it's the same objection. MR. : Okay. BY MR. Q. When you would go to the don't answer this because she's going to object -- while you were there prior to that day that approached you with Jeffrey Epstein, had anyone ever provided you with any drugs? MS. : Same objections. MR. CRITTON: Form. MS. : Do not answer. BY MR. Q. Same thing, don't answer this until she objects, if she's going to object, which she will. Had prior to that day ever provided you with any drugs? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 36 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00054382 EFTA01248042 Page 1 MS. : Same objections. 2 Do not answer. 3 BY MR. 4 Q. And by "drugs," I meant, obviously, illegal 5 drugs or drugs that were not prescribed to you by a 6 doctor. Okay? 7 MR. : Same objection? 8 MS. : Same objection. 9 Do not answer. 10 BY MR. 11 Q. All right. When you would go to the 12 prior to that day that we're going to get. 13 to in a minute, how old were the people that you were 14 going with? 15 A. My age. 16 Q. All right. Anyone that would go with you that 17 was older than you, boys or girls? 18 A. Yes. 19 Q. Who? 23 Q. Any boys that would go? 24 A. I don't remember. 25 Q. Any boys that would meet you there? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 37 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094383 EFTA01248043 Page 38 1 A. Don't remember. 2 Q. The times that you went to the 3 4 can you remember any boys that happened to show up there or meet you there or hang out with you while 5 you were there? 6 A. I don't remember. 7 Q. Were there any boys that you socialized with 8 at that point in your life? Just friends? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. At that point in my life, yes. Q. Who? A. Q • Hang on one second. A. , I think. Q. A. Q. A. Q. A. And the other name? I'm sorry. Can you spell that last name? Anyone else? Not that I can remember. Q. Were and about your age? A. No. Q. How old were they? A. This is going back when I was 16? Q. Yep. We're still at that same point in your is that (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 38 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094384 EFTA01248044 1 life right before the day Page 39 approaches you 2 about Jeffrey Epstein. 3 A. They had already graduated high school, so at 4 least 18. 5 Q. How did you know and 6 A. lived the street up from me on the corner 7 house. 8 Q. Okay. 9 • • • • • • • • • • • 21 BY MR. 22 Q. All right. When you would go to the 23 , were there ever any other boys that would 24 show up there and hang out with you guys, other than, 25 say, or (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 39 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O54385 EFTA01248045 Page 1 A. I don't remember. 2 Q. Any boys that you can remember that would come 3 there your age; in other words, from school that you 4 knew? S A. I can't recall. 6 Q. All right. You had mentioned that 7 you knew, but she wasn't a close friend at that 8 point, correct? 9 A. Yes. 10 Q. How did you know her, just from school? 11 A. Just from 12 Q. All right. Had you had her in classes before? 13 Was she in social activities and you just knew her? How 14 is it that you knew her? 15 A. I can't remember. 16 Q. Okay. I want you to describe for me and go 17 back to that day in which she approached you, as best 18 you can, exactly how that incident happened. 19 A. I was at the with a couple friends. 20 was walking around and me and her were standing and we 21 were talking. And she had asked me if I wanted to make 22 any money, what my situation was. We exchanged 23 information and we went on our separate ways. 24 Q. Okay. Let me ask you just a couple questions 25 about that. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 40 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094386 EFTA01248046 Page 41 You said she asked you what your situation 2 was. What did you take that to mean? 3 A. Was I living at home? What was I doing? 4 Q. Why was she asking you that, if you know? 5 A. I don't know. 6 Q. Did you tell her? 7 A. I can't recall. 8 Q. Do you know what she -- did you know what she 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 meant when she asked you whether you wanted to make some money? In other words, did she explain what she meant to you? A. Yes. Q. What did she say? A. She said she had a friend who was a billionaire in Palm Beach and if I gave massages, he would pay me. Q. All right. So she, in fact, did explain to you that this person wanted a massage? A. That's correct. Q. Did explain to you whether or not you would have to get undressed for the massage? A. She never -- she never said that. Q. Did express to you or explain to you in any way that the person or billionaire that you'd be massaging would be in any state of undress; in other (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 41 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00054387 EFTA01248047 Page 42 1 words, in his underwear? Naked? Was that discussed? 2 A. No. 3 Q. What did you respond when she explained this 4 to you? What did you say to her? 5 A. I can't recall. 6 Q. Did you say anything to incline or to make her 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 21 U think that you would be interested in any way? A. I exchanged information with her. Q. When you say you exchanged information, was it your phone number? A. Yes. Q. Did you give her anything other than your phone number? A. I don't remember. Q. Was that your cell phone that you gave her? A. Yes. Q. Not your home phone, correct? A. Q. correct, was A. That's correct. And your cell phone at the time, if I'm I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 42 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094388 EFTA01248048 Page • 2 Q. That number that I just said to you though, 3 , doesn't sound familiar to you? 4 A. It sounds familiar. 5 Q. Okay. With respect to the phone number that 6 you gave her, did you tell her to call you at any 7 particular time or make any arrangements for a phone 8 call or appointment at that point? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I can't remember. Q. When is the first time that you talked to he again about this issue; in other words, the billionaire friend that she had on Palm Beach? A. I don't remember. Q. How soon after that first meeting did you talk to again? A. I don't remember. Q. Was it years later? Months later? Days later? Weeks later? A. Days later. Q. Does she call you or do you call her? A. I don't remember. Q. What type of conversation -- tell me generally what you all spoke about when you spoke again on the phone. A. I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90ftb7174075 3501.182-102 Page 43 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00054389 EFTA01248049 Page 44 Q. Did you make an appointment to go meet or go 2 over to Mr. home? 3 A. Yes. 4 Q. And what was your understanding of what you 5 were going to be doing when you went there? 6 A. Can you repeat the question? 7 Q. Sure. When you have that phone 8 conversation -- this is after the in-person meeting you 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have with -- let me ask it this way: Did she give you any more information in the phone call about what the job was going to entail? A. I can't remember. Q. Did she tell you at that point whether you were going to have to get undressed at all? A. I don't remember. Q. Did she tell you at that conversation on the phone whether or not the billionaire Palm Beach gentleman would be undressed? A. I don't remember. Q. Did she give you his name in the phone call or in the in-person first meeting? A. Yes. Q. When did she tell you his name? A. I don't remember. Q. Was it either in the face-to-face you had at (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) if88f173.5663.4dad-94e7-90f1b7174075 3501.182-102 Page 44 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094390 EFTA01248050 Page the or the phone call? 2 A. Yes. 3 Q. And what name did she give you? 4 A. Jeffrey. 5 Q. Did she tell you his last name? 6 A. At that point, no. 7 Q. All right. So now you have this phone call. 8 Do you arrange a time to go over there for this massage. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I can't remember. Q. When is the first time that you went to Mr. Epstein's home for a massage? A. First time was when I was a junior in high school. Q. How long a period of time after that first_ meeting you had with was it that you first- went over there? Are we talking weeks? Days? Months? A. Wait. Can you repeat that? Q. Sure. I'm trying to figure out -- you have the face-to-face with . That's the first time she mentions this whole thing with Jeffrey Epstein? A. Uh-huh. Q. Yes? A. Yes. Q. Then you have a phone call to follow up because you had given her the information, correct? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (4013774764895) Electronically signed by Sandra Townsend (4013774764895) 1188f113-5663-4dad-S4e7-90ftb7174075 3501.182-102 Page 45 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094391 EFTA01248051 Page .; A. (Nods head.) 2 Q. Yes? 3 A. Yes. 4 Q. Okay. And that was within days of the first 5 meeting? 6 A. Yes. 7 Q. Okay. I assume at that phone call and 8 correct me if I'm wrong -- that during the phone call 9 there was some arrangement made for you to go over 10 there? 11 A. Yes. 12 Q. Okay. I'm trying to figure out how soon after 13 the phone call it was that you were to go over there. 14 Days? Weeks? Months? 15 A. Days. 16 Q. Okay. So within days of the in-face meeting 17 you have a phone call and you were supposed to go over 18 to the house days after, some amount of days after the 19 phone call, yes? 20 A. Yes. 21 Q. Got you. Was anyone going to go with you that 22 first time? 23 A. 24 Q. 25 Yes. Who? A. Me, or and Tony (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 46 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094392 EFTA01248052 Page 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Figueroa. Q. Who is Tony Figueroa? A. Tony Figueroa is 's friend. MS. , as soon as you're at a good stopping point, -- MR. : Sure. MS. : -- just get a quick restroom break? MR. : Absolutely. Right now. MS. : You good? MR. : Yep. VIDEOGRAPHER: Go off the record. The time is five minutes to 12:00 p.m. (Brief recess.) VIDEOGRAPHER: We're back on the video record. The time is 12:02 p.m. BY MR. Q. Okay. We left off the first time you were going over to Mr. Epstein's house and you mentioned that Tony Figueroa and were going to go with you? A. Yes. Q. Okay. How did you know Tony or did you know Tony before that day? A. I did not know him before that day. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 47 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094393 EFTA01248053 Page 48 Q. So the day you were going over to 2 Mr. Epstein's house was the first time you had ever met 3 him? 4 A. That's correct. 5 Q. How old was Tony, if you know? 6 A. I don't know. 7 Q. Was he older than you? 8 A. Yes. 9 Q. Did he appear to be in his late teens or 10 twenties or is he somebody that was much older, like in 11 their thirties or forties? 12 A. Late teens, early twenties. 13 Q. And you said that Tony was 14 friend? 15 A. Yes. 16 Q. Did you talk to Tony when you first met him 17 that day? 18 A. I can't remember. 19 Q. Did you have any conversations with him about 20 where you all were going or what you were going to be 21 doing that day? 22 A. Yes. 23 Q. Tell me about those. 24 A. When we were all together, we did talk about 25 where we were going and what we were doing. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electron tally signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 48 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094394 EFTA01248054 Page Q. Uh-huh. 2 A. He didn't say anything out of the normal that. 3 hadn't discussed with me prior. 4 Q. Okay. So Tony mentioned that you were going 5 to Mr. Epstein's home? 6 A. That's correct. 7 Q. Or Jeffrey's home? 8 A. Jeffrey's. 9 Q. Did Tony mention to you at that point that you 10 were going to have to give a massage? 11 A. Yes. 12 Q. Did he mention anything about having to get 13 undressed? 14 A. No. 15 Q. Did Tony mention anything about whether or not 16 Jeffrey would be undressed or not? 17 A. No. 18 Q. I think I know the answer to this question. 19 Had you had any training in giving massages prior to 20 this day? 21 MR. CRITTON: Form. 22 THE WITNESS: No. 23 BY MR. 24 Q. No professional training? 25 A. No. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 49 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094395 EFTA01248055 Page 50 Q. Never gone to school for anything like that? 2 A. No. 3 Q. Even to this day? 4 A. No. 5 MR. : No, not to this day? 6 BY MR. 7 Q. Still have not had any training in massages Lo 8 this day? 9 A. No. 10 Q. All right. So who drives? Was it 11 Tony? 12 A. I drove. 13 Q. In the pickup? 14 A. I can't remember. 15 Q. Did you go and get them or did they come over 16 to your house and you left from your house? 17 A. I picked them up. 18 Q. Where did you tell your parents you were 19 going? 20 A. I don't remember. 21 Q. Was that first time during a weekend or during 22 a weekday? 23 A. I don't remember. 24 Q. Was it during the summertime when you were out 25 from school or was it during the school time? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 50 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094396 EFTA01248056 Page A. I don't remember. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Q. You're doing just fine. And I'm going to ask a lot of things you probably don't remember, so you just tell me and that's a perfectly good answer. Okay? What you do remember though is, it was Tony, and yourself, you were driving and this was the first time that you were going to go to Jeffrey's house? A. Yes. Q. All right. Were you nervous? A. I don't remember. Q. Did you have any expectations of what might take place when you went; in other words, did you think that there might be something more than what- - and Tony may have told you? MR. CRITTON: Form. 17 BY MR. 18 Q. 19 A. 20 Q. Sure. 21 22 23 24 25 You can answer. Can you repeat the question? And Tony told you that you were going to have to give a massage, correct? A. Yes. Q. To an older man that lived on Palm Beach? A. Yes. Q. All right. Did you think there might be a (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 51 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094397 EFTA01248057 Page 1 little more to it at that point than just a massage? 2 MR. CRITTON: Form. 3 THE WITNESS: I don't remember. 4 BY MR. 5 Q. How did you know how to get to the house where 6 you were going? 7 A. And Tony were with me. They gave 8 me directions. 9 Q. Okay. Describe for me, if you remember, how 10 you got there; in other words, did you go over the north 11 bridge? South bridge? 12 A. I don't recall what bridge. 13 Q. When you pulled up to the house for the first. 14 time, can you describe for me what you recall it looking 15 like? 16 A. There was a driveway, landscape. I want to 17 say it was a pink color, like, a pinkish color. It was 18 huge. A lot of cars in the driveway. 19 Q. Through road? Dead end? 20 A. It was a dead road, dead end. 21 Q. You said there were a lot of cars in the 22 driveway? 23 A. (Nods head.) 24 Q. What kind of cars, if you remember? 25 A. I can recall black. That's all. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 52 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094398 EFTA01248058 2 A. 3 Q. 4 front of 5 A. 6 Q. Page Q. Do you remember seeing an Escalade? I don't remember. Okay. That's fine. Anyone meet you at the the house? Security? Anything like that? No. Describe for me what happened when you 7 arrived, as best you can recall. 8 A. As best as I can recall, Tony, 9 and I walked to the side of the house, kind of around 10 the back, to a door where somebody had opened it for u 11 and it led into the kitchen. 12 Q. Okay. You said the door was already opened. 13 Does that mean that it was unlocked or that it was 14 physically open? 15 A. No. Somebody had opened the door, like, met 16 us at the door and opened it for us. 17 Q. Got you. That person that met you at the 18 door, woman or man? 19 A. I can't remember. 20 Q. Do you remember if it was the cook? 21 A. No, I do not. 22 Q. Did you all call ahead; in other words, did 23 somebody, either Tony or call ahead on the 24 way and say, hey, we're almost there or anything like 25 that? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 53 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094399 EFTA01248059 Page A. I don't remember. 2 Q. Okay. Tell me what happens next. So somebody 3 opens the door for you? 4 A. Somebody opens the door. From what I can 5 recall, we're all, you know, in the kitchen. 6 And then I had ended up upstairs. I'm not 7 sure how I ended up there. 8 Q. Okay. Was there a staircase leading upstairs 9 from the kitchen? 10 A. From the kitchen? No. 11 Q. How would you get upstairs after entering the 12 kitchen? What different ways are there to get upstairs, 13 if you know? 14 A. You would walk through the kitchen, kind of 15 straight into another room. I don't recall if it was a 16 living room or what. And then kind of make a right. 17 And then it would lead upstairs and it would go kind of 18 around. 19 Q. Uh-huh. All right. The staircase leading up 20 that you just described, the one closest to the kitchen, 21 narrow staircase? Wide staircase? 22 MR. CRITTON: Form. 23 BY MR. 24 Q. How would you describe it? 25 A. I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 54 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094400 EFTA01248060 Page Q. Was the staircase open on both sides? Was 2 there a wall on one side? A wall on both sides? A 3 railing on one side, a wall on the other? How would you 4 describe it? 5 A. It was, like, three steps and then there was a 6 staircase that went one way and the other one kind of 7 opened up to another direction. 8 Q. All right. Do you know where each side went? 9 Do you know where each side of the staircase went? 10 A. Not each side, no. 11 Q. Where did the right side go to? 12 A. I don't know. 13 Q. Do you know where the left side went to? 14 A. No. 15 Q. Somehow though you ended upstairs? 16 A. Yes. 17 Q. And was anyone up there with you? 18 A. 19 Q. Had you ever met her before? 20 A. Prior to that day, no. 21 Q. So this was the first time that you had met 22 23 A. Yes. 24 Q. And just so we're clear, we're talking about 25 , correct? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 55 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W401 EFTA01248061 Page 56 1 A. Yes. 2 Q. What did say to you when you first met? 3 A. I don't remember. 4 Q. What did you all talk about? 5 A. I don't remember. 6 Q. Did she talk to you about what you were about 7 to do? 8 MR. CRITTON: Form. 9 BY MR. 10 Q. In other words, did she discuss anything about 11 the massage to you? 12 MR. CRITTON: Form. 13 THE WITNESS: I can't remember. 14 BY MR. 15 Q. Did you have any conversation with her that 16 first day? 17 A. I don't remember. 18 Q. That's fine. 19 When you get upstairs, you see 20 Is anyone else with you? In other words, where is 21 ? Where is Tony? 22 A. Downstairs in the kitchen. 23 Q. So they didn't go up with you? 24 A. Not that I remember, no. 25 Q. Prior to this day had you known whether or not (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 56 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094402 EFTA01248062 2 3 4 5 6 7 had gone words, whether and done this type of thing in the past? A. No. Q. You didn't know? A. No. Q. Page through this before; in other had come over to this house Okay. When you get upstairs in this home, are 8 you nervous? 9 A. I can't remember. 10 Q. What did you do next? 11 A. After I was upstairs? 12 Q. Yes. 13 A. Fixed the massage table. 14 Q. How did you know how to do that? 15 A. I was shown. 16 Q. By? 17 A. 18 Q. Okay. 19 A. And I was shown where the towels were and the 20 oils. And then left. 21 Q. Where were the towels and oils kept? 22 A. Towels, I don't remember. Oils were kept in a 23 bottom drawer in the massage room area. 24 Q. Where is the massage room in relationship to 25 where you first were when you remember being upstairs? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7.50f1b7174075 3501.182-102 Page 57 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W1403 EFTA01248063 Page 58 A. I don't understand the question. 2 Q. Sure. The first thing you remembered when you 3 got to the house after going through the kitchen is 4 being upstairs? 5 A. Uh-huh. 6 Q. Okay? I'm wondering, as you're upstairs, 7 where is the massage room in relationship to that? 8 A. In a bedroom in a steam room. 9 Q. Okay. How big is this area, this massage room 10 area? 11 A. Maybe half this size. 12 Q. Okay. 13 A. Big. 14 Q. It's a big room? 15 A. It's a big room. 16 Q. Size of maybe an average bedroom? 17 MR. CRITTON: Form. 18 THE WITNESS: Yes. 19 BY MR. 20 Q. What's in that room? 21 A. A shower, a steam room, a closet of some sort, 22 sinks. 23 Q. Okay. Some kind of a dresser with drawers? 24 A. Maybe. I can't be sure. 25 Q. You mentioned the oils were in a bottom (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 58 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094404 EFTA01248064 Page 1 drawer? 2 A. Uh-huh. 3 Q. What type of -- 4 A. It was a tall -- it was tall with several 5 drawers against a wall. 6 Q. Okay. How close was that to the table, the 7 massage table? 8 A. Close. 9 Q. Okay. Did you have to actually set the 10 massage table up with or was it already set up 11 when you walked in? 12 A. She showed me how to set it up. 13 Q. So it was folded up and you all had to unfold 14 it and set it up? 15 A. Yes. 16 Q. When you set it up, was there a certain 17 procedure that showed you; in other words, how it 18 needed to be done? 19 A. Yes. 20 Q. Tell us about that. 21 A. You would have to pull out the massage table 22 from the closet that it was kept in. You would 23 straighten out the legs, just put it to where the 24 cushions are facing the roof. And two big towels, one 25 would go on one cushion and the other big towel would be (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 59 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094405 EFTA01248065 Page 60 1 unfolded on the other cushion, kind of like a 2 tablecloth. 3 Q. And after that she showed you where the oils 4 were? 5 A. Yes. 6 Q. What type of oils are we talking about? 7 A. I can't remember. 8 Q. Clear? Are they lotion, like, white-colored 9 oils? I mean, what did the bottles look like? Square? 10 Circular? Anything like that? Can you remember any of 11 the names on them? Anything at all that you can tell us 12 about them? 13 A. I can't recall. 14 Q. You can't recall anything about them, color or 15 nothing? 16 A. I can't recall anything about the lotions or 17 oils. 18 Q. But they were kept in a bottom drawer? 19 A. That's correct. 20 Q. Was there anything else that you saw in the 21 bottom drawer when she got out the oils for you that 22 first time? 23 A. Yes. 24 Q. What did you see? 25 A. Massager. (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-Ne7-90ftb7174075 3501.182-102 Page 60 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000.94406 EFTA01248066 Page Q. Can you describe it for me? 2 A. It was big. I want to say it was a pinkish 3 color. 4 Q. When you say, "it was big," we're on video so 5 you can actually show us with your hands. What are we 6 talking about in size here? 7 A. Size, about that long (indicating). 8 Q. Okay. And shape? 9 A. I wouldn't really know how to describe the 10 shape. 11 Q. Tubular? 12 MR. CRITTON: Form. 13 BY MR. 14 Q. Like a bottle? 15 A. Similar to a bottle. 16 Q. Did it resemble a part of the human anatomy at 17 all? 18 A. Yes. 19 Q. Did it resemble a part of the male anatomy? 20 A. Yes. 21 Q. Sorry I got to ask you, but did it resemble a 22 man's penis? 23 A. Yes. 24 Q. And did it have a plug attached to it? 25 A. I can't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 61 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O94407 EFTA01248067 Page 62 Q. Do you know what I mean when I say, "a plug?" 2 In other words, was it one that would plug in or was it 3 battery operated, if you know? 4 A. I don't know. 5 Q. But, nonetheless, you saw that in the drawer 6 with the oils? 7 A. Yes. 8 Q. Did you see any other massage devices in that 9 drawer with the oils at that point? 10 A. No. 11 Q. Okay. What did you think when you saw that? 12 A. I don't remember. 13 Q. At this point after you've set up the massage 14 table, she shows you the oils and you see that type of 15 thing in the drawer, are you nervous now? 16 A. I don't remember. 17 Q. What happens next? 18 A. Jeffrey walks in the room. 19 Q. Describe him for me that first time that you 20 saw him. 21 A. I don't remember. 22 Q. Was he fully clothed? 23 A. I can't remember. 24 Q. What happens when he walks in? 25 A. He walks in, introduces himself, lays on the (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663-4dad-94e7.500b7174075 3501.182-102 Page 62 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94408 EFTA01248068 Page • 1 table. 2 Q. When he lays on the table, was he undressed? 3 A. He's covered. 4 Q. Okay. When you say, "covered," are you 5 talking from the waist down covered? 6 A. Yes. 7 Q. One towel? Big towel? Small towel? How is 8 he covered? 9 A. A towel. I don't know the size. 10 Q. Okay. Could you still see his legs? 11 A. Yes. 12 Q. And does leave the room at this point? 13 A. Yes. 14 Q. What happens next? 15 A. I start giving him a massage. 16 Q. Are you clothed? 17 A. Yes. 18 Q. Before leaves, does she discuss anything 19 with you about your clothes; in other words, taking them 20 off, leaving them on, anything like that? 21 A. No. 22 Q. When Mr. Epstein comes in the room for the 23 first time that time, does he say anything to you othe:. 24 than hello? 25 A. No. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4ded-Sile7-90flb7174075 3501.182-102 Page 63 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0MMI409 EFTA01248069 Page 64 Q. Does he discuss with you before he lays down 2 anything about your clothing? 3 A. Not that I can remember. 4 Q. At this point you're 16 years old? 5 A. Yes. 6 Q. Or 15? 7 A. Sixteen. 8 Q. You're in a bathroom alone with a man who'. 9 got a towel over himself and you're giving him a 10 massage. 11 (Brief interruption.) 12 BY MR. 13 Q. Sorry for the interruption. 14 At this point you're 16. You're in a bathroom 15 alone with a man you'd never met before who's 16 essentially naked but for a towel and you're giving him 17 a massage. Are you nervous? 18 A. I don't know. 19 Q. What happens next? 20 A. I start massaging him. We're talking, 21 conversating. 22 Q. About what? 23 A. Life. 24 Q. Like? 25 A. School, family. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 64 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O94410 EFTA01248070 Page 65 Q. Did you tell him you were in high school? 2 MR. CRITTON: Form. 3 THE WITNESS: No. 4 BY MR. 5 Q. You were talking about school. What are you 6 talking about? 7 A. I didn't specify. a Q. At that point does he ask you how old you are: 9 A. No. I voluntarily tell him I'm 18. 10 Q. You told him at that point? 11 A. Yes. 12 Q. And that was obviously not true? 13 A. That was not true. 14 Q. What happens next? 15 A. We're still massaging. I'm still conversating 16 with him. 17 Q. Okay. Next? 18 A. I'm sorry. Next, my skirt comes off and I'm 19 still clothed, but I'm in my thong giving him a massage. 20 He tries to touch me. I refuse and I don't let it 21 happen. And then the massage ends and before it ends, 22 he -- he masturbates. 23 Q. While you're still in the room? 24 A. Yes. 25 Q. Does he take the towel off to do this? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 65 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_ONYM411 EFTA01248071 Page 66 A. Yes. 2 Q. Do you see him? 3 A. Yes. 4 Q. All right. At that point what are you 5 thinking? 6 A. I don't remember what I was thinking. 7 Q. Now, it's obviously upsetting to you today. 8 And as I mentioned at the beginning, I'm sorry I have to 9 go through these questions, but you had gone there 10 voluntarily, right? 11 A. That's correct. 12 Q. And you told him you were 18? 13 A. Yes. 14 Q. Why is it upsetting to you still? 15 MR. CRITTON: Form. 16 THE WITNESS: Because I now know what I was 17 doing was wrong and I have so much regret for it. 18 BY MR. 19 Q. Do you think you didn't realize the full 20 extent of what was going on at that time? 21 MR. CRITTON: Form. 22 BY MR. 23 Q. Let me ask it this way: Given your age of 16 24 at the time and looking back on it now, do you think you 25 fully realized what you were getting yourself into? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 66 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W1412 EFTA01248072 Page MR. CRITTON: Form. 2 THE WITNESS: I don't think I'll ever realize 3 what I was getting myself into. I still don't know 4 what I was thinking. 5 BY MR. 6 Q. Now that you're in your twenties, do you fee_ 7 a little bit smarter about decisions you may make in 8 your life? 9 A. Yes. 10 MR. CRITTON: Form. 11 BY MR. 12 Q. You think that comes with age? 13 MR. CRITTON: Form. 14 THE WITNESS: Yes. 15 BY MR. 16 Q. Okay. All right. After this all occurs, what 17 happens next? 18 A. After the massage, I go downstairs. I ge- 19 paid. We leave. 20 Q. Who pays you? 21 A. I can't remember. 22 Q. Do you remember if the money came from 23 or Tony or whether it came from one of 24 Mr. Epstein's people, like or someone else? 25 A. Definitely not one of his people, but I (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7 3501.182-102 Page 67 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94413 EFTA01248073 Page 68 1 can't -- I can't be accurate. I don't know. 2 Q. Okay. You mentioned that the skirt came off. 3 Did you take it off or did he? 4 A. I did. 5 Q. Why? 6 A. I don't know. 7 Q. Did he ask you to? 8 A. I don't remember. 9 Q. Did your top come off at any point during 10 this? 11 A. I don't remember. 12 Q. You said that he tried to touch you and you 13 stopped him, correct? 14 A. Yes. 15 Q. Where did he try to touch you? 16 A. Below the belt. 17 Q. Did he try to touch you in the front or in the 18 back? 19 A. 20 Q. 21 A. 22 Q. 23 A. 24 Q. 25 A. In the front. At this point your skirt was off, correct? Yes. Underwear was still on? Yes. Regular type underwear? Thong type underwear? Thong. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 68 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000.94414 EFTA01248074 Page 69 Q. All right. Does he finish before you get 2 dressed or do you get dressed and then he finishes what. 3 he's doing? 4 A. I don't remember. 5 Q. At some point though you get dressed and go 6 downstairs? 7 A. Yes. 8 Q. How do you know how to get downstairs? Does 9 somebody meet you up outside the room and guide you down 10 or you just know where to go? 11 A. I don't remember. 12 Q. Does he say anything to you after he finishes? 13 A. Yes. 14 Q. What? 15 A. He told me that if I can bring my friends, 16 that for every girl that I bring to him he would pay me 17 $200. 18 Q. What do you think of that at that point? 19 A. At that point, I don't know. 20 Q. All right. When you go downstairs are 21 and Tony waiting for you? 22 A. Yes. 23 Q. Are they waiting in the kitchen? 24 A. Yes. 25 Q. Do you talk to them about what happened? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 69 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094415 EFTA01248075 Page A. I don't remember. 2 Q. Do you all get in your pickup to leave at some 3 point? 4 A. Yes. 5 Q. When you come downstairs and meet them in tilt- 6 kitchen, do you get the money and then immediately go or 7 do you stick around at all? 8 A. We don't stick around. We go. 9 Q. How long does this entire encounter occur? In 10 other words, we're talking about from the time when you 11 pull up to the house to the time that you leave, is it 12 approximately an hour? Two hours? Three hours? 13 A. Approximately an hour. 14 Q. When you all get in the truck to leave, at any 15 point do you have a conversation with Tony and 16 III about what had just happened? 17 A. I don't remember. 18 Q. Were you in any state of shock at that point? 19 MR. CRITTON: Form. 20 THE WITNESS: I don't remember. 21 BY MR. 22 Q. This next question your attorney is going to 23 object to, so I don't want you to say anything until she 24 says objection or not. 25 Is this the first sexual experience that you (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 70 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0MM416 EFTA01248076 Page 1 had ever had in your life? 2 MS. : Predicate. Relevance. Privacy. 3 Do not answer that question. 4 BY MR. 5 Q. Same thing. Is this the first sexual 6 experience you had in your life with a man that was not 7 close to your age? 8 MS. : Same objection. 9 Do not answer. 10 BY MR. 11 Q. When you got to the house and saw Mr. Epstein 12 for the first time, could you give us an idea on how old 13 he looked; in other words, what age you thought he was, 14 approximately? 15 A. Late forties, early fifties. 16 Q. Okay. Clearly not your age? 17 A. Clearly. 18 MR. CRITTON: Form. 19 BY MR. 20 Q. Your age being 16? 21 A. Yes. 22 Q. All right. After that first time, you leave 23 and get in the car with and Tony, are you 24 driving? 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94e7-90flb7174075 3501.182-102 Page 71 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000.94417 EFTA01248077 Page 72 Q. 2 you go? 9 10 11 12 13 what you did with it? 14 15 Q. 16 17 18 19 20 21 22 next time. 23 24 25 Do you drop them back off somewhere? Where do 3 A. I don't remember. 4 Q. You got paid $200? 5 A. Yes. 6 Q. Cash? 7 A. Yes. 8 Q. What do you do with it? A. Shopping. Q. Where did you go? A. I don't remember. Q. Do you remember what you went shopping for o.c A. I don't. I can't recall. When you leave the house, do you all go somewhere in between taking and Tony home; in other words, do you go to eat, do you go to a store, anything like that, that you can remember doing or do you just go and take them home? A. I really can't recall. Q. All right. Let's talk about now the -- the What's the next time that anything occurs where you are going to go to Mr. Epstein's house or you hear anything about Jeffrey? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 72 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_ONYM1418 EFTA01248078 Page A. Is when I brought a girl over. 2 Q. Okay. How did you know to do that? Was it 3 the conversation you had in the room with him that first 4 time? 5 A. -- I had exchanged my number with 6 Q. Okay. 7 A. And I don't know how we came into contact 8 after that day, but the next time was with a woman, a 9 girl. 10 Q. Okay. So at some point you gave your phone 11 number to 12 A. Yes. 13 Q. Was it -- that before or after you had gone in 14 the room for the massage with Jeffrey? 15 A. I don't remember. 16 Q. Was it before you left the house that day; in 17 other words -- 18 A. Yes. 19 Q. -- did you call her and give her the number or 20 did you just give it to her in person when you were 21 there? 22 A. Yes, I gave it to her in person. 23 Q. Okay. And did she call you about getting 24 another girl for Jeffrey or did you call her that first. 25 time? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 73 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW1419 EFTA01248079 Page 1 A. I don't remember. 2 Q. Who was the first girl that you brought over 3 to Jeffrey's house? 4 A. I don't know. 5 Q. How many girls ultimately did you bring over 6 to Jeffrey's house? 7 A. Maybe a dozen. 8 Q. Why? 9 A. I don't know. I don't know. 10 Q. For the money? 11 MR. CRITTON: Form. 12 THE WITNESS: I don't know. 13 BY MR. 14 Q. Looking back on it, bad decision? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes. 17 BY MR. 18 Q. You regret doing it? 19 A. Yes. 20 MR. CRITTON: Form. 21 BY MR. 22 Q. Why? 23 A. It's consumed so much of my life. 24 Q. Thinking about the other girls for a moment, 25 you think it was a bad decision bringing them over? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 74 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094420 EFTA01248080 Page MR. CRITTON: Form. 2 THE WITNESS: Yes. 3 BY MR. 4 Q. Why? 5 A. I wouldn't be in this position if I didn't. 6 Q. Do you think it was harmful to them at all? 7 A. I don't know. 8 MR. CRITTON: Form. 9 BY MR. 10 Q. Did you think about them at any point? 11 A. No. 12 Q. How it may affect them or their lives? 13 A. Nope. 14 Q. How about today? 15 MR. CRITTON: Form. 16 THE WITNESS: Yes. 17 BY MR. 18 Q. What do you think? 19 MR. CRITTON: Form. 20 THE WITNESS: I don't know what to think. 21 BY MR. 22 Q. Do you think it may have negatively affected 23 those girls that you brought over? 24 MR. CRITTON: Form. 25 THE WITNESS: I don't know. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401377476-2895) Electronically signed by Sandra Townsend (401377476-2895) (561) 832-7506 1f88f113-5663-4ded-Sile7-90flb7174075 3501.182-102 Page 75 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94421 EFTA01248081 Page 1 BY MR. 2 Q. Obviously it's bothered you even today, 3 correct? 4 A. Yes. 5 MR. CRITTON: Form. 6 BY MR. 7 Q. Think it was a bad decision for you? 8 MR. CRITTON: Form. 9 MS. : Asked and answered as well, 10 several times. 11 THE WITNESS: Yes. 12 BY MR. 13 Q. Equally was bad for them? 14 MR. CRITTON: Form. 15 THE WITNESS: I don't know. 16 BY MR. 17 Q. Okay. Do you remember the names of the 18 approximately 12 girls that you brought over? 19 A. Yes. 20 Q. Let's go through them. 21 A. 22 Another girl named II 23 Q. 24 A. Yeah. I'm sorry. I'm having -- 25 Q. It's okay. (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 76 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA J30O94422 EFTA01248082 Page Who else? 2 A. That's all I can remember right now. 3 Q. Okay. How soon after that first time that you 4 went over did you bring the first girl over with you? 5 A. Days. 6 Q. How did you explain to that first girl what 7 she was going to be getting into or what she was going 8 to do? 9 A. Same way I was explained. 10 Q. Did you explain to that girl that she might 11 have to get undressed or did you leave that out? 12 A. No, I didn't say that. 13 Q. You left that part of it out? 14 A. Yes. 15 Q. Why? 16 A. I don't know. 17 Q. Think it would have been harder to convince a 18 girl to go over to the house if they knew they might 19 have to get naked? 20 A. I don't know. 21 MR. CRITTON: Form. 22 BY MR. 23 Q. Would you have gone over that first time III 24 told you that you might have to take your clothes off? 25 MR. CRITTON: Form. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 77 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94423 EFTA01248083 Page THE WITNESS: I don't know. 2 BY MR. 3 Q. All right. But nonetheless you left that part 4 out when you explained to the first girl about what was 5 going to happen, correct? 6 A. Yes. 7 Q. And that first girl that you explained this 8 thing to, did you tell her she was going to make money 9 going over there for a massage? 10 A. Yes. 11 Q. Did you tell her that it was an older man that 12 lived on the Island? 13 A. Yes. 14 Q. Did you tell her it was a rich billionaire 15 that lived on the Island? 16 A. Yes. 17 Q. You don't remember that first girl's name or 18 which one that was? 19 A. No, I do not. 20 Q. The girls that you brought over to Jeffrey's 21 home, 12-some-odd girls, were all of them under the age 22 of 18? 23 A. I'm sorry. Can you repeat that? 24 Q. Yeah. The 12-some-odd girls that you brought 25 over to Jeffrey's house, were they all under the age of (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-SW-90flb7174075 3501.182-102 Page 78 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTAJOIMM424 EFTA01248084 18? 2 A. No. 3 Q. You brought an older girl over in her -- 4 A. Yes. 5 Q. -- twenties, right? 6 A. Yes. 7 Q. What was her name? 8 A. 9 Q. How did you know 10 A. Through her brother. 11 Q. And was about what? -- 23? 24? 12 A. I believe 23. 13 Q. Okay. After you brought over, what did 14 Jeffrey say about her? 15 A. She was old. 16 Q. Did he tell you what he meant by that? 17 A. No. 18 Q. What did you take that to mean? 19 MR. CRITTON: Form. 20 THE WITNESS: That she was old. 21 BY MR. 22 Q. Did you get the impression that Jeffrey wanted 23 girls that were about your age; in other words, around 24 16 years old? 25 MR. CRITTON: Form. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94e7 3501.182-102 Page 79 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_OMM425 EFTA01248085 Page 80 1 THE WITNESS: I don't understand that 2 question. 3 BY MR. 4 Q. Other than , had you brought any girls 5 over that were in their twenties? 6 A. No. 7 Q. Was she the only girl that you can remember 8 bringing over that was over the age of 18? 9 A. Yes. 10 Q. So all the other girls that you brought over 11 were how old? I mean, what was the youngest? Wail' 12 the youngest? 13 A. II was the youngest. 14 Q. She was how old? 15 A. Fourteen. 16 Q. Fourteen the first time you brought her over, 17 correct? 18 A. Yes. 19 Q. And you knewIll through your cousin? 20 A. Yes. 21 Q. Okay. So you were bringing girls over from 22 age 14 to age 17, right? 23 MR. CRITTON: Form. 24 THE WITNESS: Yes. 25 BY MR. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 80 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094426 EFTA01248086 Page 81 1 Q. Did you have an understanding that that's what 2 Jeffrey liked, girls that were around that age, 14 to 17 3 years old? 4 MR. CRITTON: Form. THE WITNESS: I don't understand your 6 question. 7 BY MR. 8 Q. Well, he told you that was too old, 9 right? 10 A. Yes. 11 Q. Why were you bringing girls, all of them 12 except for , 14 to 17? 13 MS. : Object, to the extent that 14 you're asking her to speculate as to what 15 Mr. Epstein was thinking and feeling. 16 MR. : Don't want that. 17 BY MR. 18 Q. I want what you're thinking. 19 MS. : If she has specific -- 20 BY MR. 21 Q. I want what you were thinking. 22 Why did you only bring girls, except for 23 that were 14 to 17? 24 A. Because those are girls that I knew that 25 went to school with. It was easy access. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 81 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094427 EFTA01248087 Page 82 Q. Okay. Did Jeffrey tell you that he liked any 2 of them that you brought over in particular? 3 A. Yes. 4 Q. Which one? 5 A. 6 Q. Anyone else? 7 A. 8 Q. Anyone else? 9 10 11 12 13 14 and 15 16 17 18 Okay? 19 20 21 22 23 24 25 A. Not that I can remember. Q. Did he tell you why he liked the most? A. No. Q. Did he tell you what he did with A. No. Q. All right. We're going to change the tape, so we're going to take a five-minute break real quick. VIDEOGRAPHER: Going off the video record. This is the end of tape one. The time is 12:35 p.m. (Brief recess.) VIDEOGRAPHER: We're back on the video record. This is the beginning of tape two. The time is 12:45 p.m. (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377476.2895) Electronically signed by Sandra Townsend (401477-676-2895) 1f88f113.5663.4dad-94e7 3501.182-102 Page 82 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW1428 EFTA01248088 Page 83 1 BY MR. 2 Q. I want to go back, just a couple of things I 3 wanted to cover about that first time before we move on. 4 At some point you spoke to police about 5 Jeffrey Epstein, correct? 6 A. Yes. 7 Q. You gave, I believe, a couple of interviews 8 actually to the police officers about what had happened? 9 A. A couple? 10 Q. Did you talk to them -- well, let me ask you. 11 How many times did you talk to police in total, if you 12 remember? 13 A. One time to the police. 14 Q. Did they call you on the phone and talk to you 15 that time? 16 A. No. 17 Q. Did they talk to you in person? 18 A. Yes. 19 Q. Brought you down to the police department: 20 A. Yes. 21 Q. Was anyone with you when you went? 22 A. No. 23 Q. One police officer was there? 24 A. Two. 25 Q. Do you remember who they were? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113.5663.4dad-94e7-90flb7174075 3501.182-102 Page 83 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW429 EFTA01248089 Page 84 A. No. 2 Q. Are you also aware that at some point you had 3 phone calls with II that had been recorded? 4 A. At some point, yes. 5 Q. Somebody told you about those? 6 A. Yes. 7 Q. Who told you about those? 8 MS. : And, again, if you learned this 9 through myself, or any other attorney that's 10 represented the same to you, do not disclose that. 11 You are not 12 MR. : Absolutely. 13 MS. : -- to discuss anything that 14 you've learned through a conversation with one of 15 your attorneys. 16 BY MR. 17 Q. I'll clarify. Did you learn from a source 18 other than your attorneys that you had had conversations 19 with over the phone that had been recorded? 20 A. No. 21 Q. During the conversations with the police, do 22 you know if those were recorded? 23 A. Yes. 24 Q. Okay. Would you agree with me that your 25 memory back then when the police first interviewed you (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 84 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O94430 EFTA01248090 Page 85 1 might have been a little bit fresher than it is today, 2 some, we're talking three, four years later? 3 A. Yes. 4 Q. In looking through the police records, I just 5 wanted to clarify a couple things. And if you remember 6 them different, you tell me. 7 One of the things you mentioned to me was that 8 during the incident he may have touched you in the front 9 and you stopped him? 10 A. Yes. 11 Q. All right. In the police records, it mentions 12 that Epstein grabbed your buttocks and you felt 13 uncomfortable. 14 MR. CRITTON: I'm sorry. 15 BY MR. 16 Q. As you sit here today, do you recall whether 17 he tried to touch you in the front or in the rear? 18 MS. : I object to you using this 19 record at all. I'm not sure if you're looking at a 20 statement or if you're just looking at a probable 21 cause affidavit and representing that a police 22 officer said this or that. 23 If you have a particular statement that she's 24 given, we'd like to see that and let her review it . 25 Otherwise, this isn't proper impeachment. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377.676.2895) Electronically signed by Sandra Townsend (401.377.676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 85 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW431 EFTA01248091 Page 86 1 BY MR. 2 Q. All I'm asking is, is, I just want to know if 3 you remember specifically whether he tried to touch you 4 in the front or it may have been in the back in the 5 buttocks. 6 A. I know for a fact that he tried to touch me in 7 the front. As far as the buttocks, it's possible. That 8 was many years ago. I can't recall. 9 Q. Okay. One of the police officers said that 10 you told him that Epstein expressed, the younger the 11 better, when it came to girls being brought to the 12 house. 13 MS. : And, again, I'm going to object 14 and ask you to clarify. Are you reading from a 15 deposition? Have you learned specifically from a 16 police officer himself? Do you have a statement 17 that has given that you're representing to 18 her? Because right now you're just telling her 19 what a police officer has said. 20 MR. : Okay. 21 MS. : And I think she's entitled to 22 know what exactly you're trying to do, if this is 23 impeachment. What are you asking her? 24 MR. CRITTON: Let me just note my objection, 25 too. It's -- a police statement is not necessarily (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 86 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA _00094432 EFTA01248092 Page 8, 1 accurate or inaccurate. But my objection is to 2 form because I think it's inaccurate. 3 MR. : Did you have a question at the 4 end of your statement? 5 MR. : I was waiting for all the 6 objections because there wasn't one. 7 BY MR. 8 Q. All right. Let me ask the question now. 9 A. Okay. 10 Q. Do you recall Mr. Epstein, Jeffrey, ever 11 saying to you with respect to girls being brought to the 12 house, the younger the better? 13 MR. CRITTON: Form. 14 THE WITNESS: Yes. 15 BY MR. 16 Q. When did he say that? 17 A. I don't know. I can't recall. 18 Q. Was it after that first time? 19 A. I don't know. 20 Q. What did you take that to mean, the younger 21 the better? 22 A. Not old. 23 Q. And old being obviously 24 A. 25 Q. Who was 23? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 87 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094433 EFTA01248093 Page 88 A. Yes. 2 Q. Okay. The first time you were there, you 3 mentioned you got paid 200. 4 Do you know if or Tony got paid? 5 A. Yes. 6 Q. How do you know that? 7 A. One of which had told me,III had told me. 8 don't know how much. 9 Q. But you know that • got paid for taking you 10 there? 11 A. That's correct. 12 Q. Got you. Which would have been similar to the 13 deal that he explained to you, if you bring someone, 14 I'll give you 200 bucks? 15 A. Yes. 16 Q. Okay. The first girl you brought, you 17 mentioned that you didn't tell her that she would have 18 to get naked in any way. 19 Did you tell any of the subsequent girls that. 20 you brought that they might have to undress? 21 A. I don't remember. 22 Q. Okay. Very important, and I want to be 23 specific about this. You said you brought about 12 24 girls, approximately, to Jeffrey's home for these 25 massages, all of which were under the age of 18 except (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electron tally signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-SW-90flb7174075 3501.182-102 Page 88 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094434 EFTA01248094 Page 89 for 2 As you sit here today, can you recall telling 3 any of them that they would have to get naked at any 4 point during the massage? 5 A. I really do not remember. 6 Q. Would you agree with me then at the very least 7 that none of these girls that you brought would have 8 known that they would have to get naked before they 9 showed up at the house? 10 A. I don't understand your question. 11 Q. If you didn't tell them or you don't remember 12 telling them that they would have to get naked at any 13 point, would these girls have been able to hear it from 14 anyone else, if you know? 15 A. I don't know. 16 MR. CRITTON: Form. 17 BY MR. 18 Q. Do you know if anyone else had approached any 19 of the same girls that you brought to the home to 20 discuss what was going to happen there? 21 A. I don't know. 22 Q. Was anyone with you, other than the girl that 23 you would bring, on the times that you brought these 24 girls to Epstein's home? 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 89 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O94435 EFTA01248095 Page Q. Who? 2 A. One occasion 3 Q. What's her last name? 4 A. Coincidentally, I. S Q. And who was..? Was she also a friend about. 8 your age? 9 A. She was a friend. I don't know her age. 10 Q. Was she in high school with you? 11 A. I don't know. 12 Q. How was it that she came to be with you on one 13 occasion when you brought a girl? 14 A. We were friends. There's a lot of speculation 15 about her age. She said she went to but I 16 don't -- never saw her. We were just friends. We met 17 out and about. 18 Q. Okay. How did she end up with you that day 19 though? 20 A. I called her to ask her if she wanted to tag 21 along. 22 Q. And who were you bringing that particular day? 23 A. 24 Q. So on that particular day, it was you, II and 25 that went? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 90 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94436 EFTA01248096 Page A. Yes. 2 Q. And was going to be the one giving the 3 massage at that point? 4 A. That's correct. 5 Q. How many times did you go with II? 6 A. One time. 7 Q. Do you know whether she went other times 8 without you? 9 A. I do not. 10 Q. You don't know for sure one way or the other? 11 A. I do not know for sure one way or the other. 12 Q. Other than that first time that you went, were 13 there any other times that you actually gave Jeffrey a 14 massage? 15 A. One time. 16 Q. How long after that first time was that? 17 A. I only gave one massage. I don't think I 18 understand -- I don't think I understand your question. 19 Q. Okay. And I think you clarified it. 20 You mentioned that you went that first time 21 and gave him a massage. Okay? 22 A. (Nods head.) 23 Q. Other than that one time, did you ever again 24 give him a massage? 25 A. No. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94e7 3501.182-102 Page 91 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W1437 EFTA01248097 Page 92 Q. So all the other times that you went back to 2 the home, you were just bringing other girls? 3 A. Yes. 4 Q. Got you. I had asked you whether the reason 5 you were bringing these girls was the money. You 6 remember that question? 7 A. Yes, I do. 8 Q. If not the maybe only reason you were doing 9 it, would you agree with me that the money you were 10 getting paid was at least one of the reasons why you 11 were bringing girls there? 12 MR. CRITTON: Form. 13 THE WITNESS: Yes. 14 BY MR. 15 Q. Can you think of any other reason, other than 16 the money, that you would have been bringing girls there 17 to his house? 18 A. Being rebellious. 19 Q. Were you doing anything else in your life that 20 was rebellious, other than this, at this point? 21 MS. : Objection. And I'm going to 22 instruct her not to answer that question, based on 23 the same objections as earlier. 24 BY MR. 25 Q. Okay. When you went to Jeffrey's home, did (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 92 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094438 EFTA01248098 Page 93 1 you ever meet up with the chef in the kitchen at any 2 point? 3 A. The chef was there. 4 Q. Okay. Maybe not every time or was it every 5 time that the chef was there? 6 A. Not every time. 7 Q. Describe the chef for me. Male or female? 8 A. Male. 9 Q. Race? White? Ethnic? Anything? 10 A. I can't remember. 11 Q. Okay. Approximate age? 12 A. Can't remember. 13 Q. Did you ever have any conversations with the 14 chef? 15 A. I can't remember. 16 Q. Did you ever have any conversations with the 17 house staff at all, either security or anyone in the 18 house, other than 19 A. No, not that I can remember at all. 20 Q. All right. While you don't remember the first 21 girl that you brought, do you remember the next one 22 after that? 23 A. No. 24 Q. Do you remember any of the order in which you 25 brought these girls? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 93 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA _00094439 EFTA01248099 Page A. Yes. 2 Q. Tell me about that. 3 A. I only remember the last one being. 4 Q. That was the last one? 5 A. The last one. 6 Q. Why was she the last? 7 A. Because -- because I was 18. I had just 8 turned 18. And I didn't even really want to bring her 9 but she had kind of asked me to, so I did it. 10 And then after that, there were a lot of 11 people warning me about her, that she was trying to set 12 me up. So after that I stopped. 13 Q. Okay. But II was the last one you brought? 14 A. Yes. 15 Q. Did you stop bringing girls to the house 16 because the police started the investigation right after 17 the. incident? 18 A. No. 19 Q. Do you think that you would have stopped 20 bringing girls to the house, had the police not started 21 their investigation? 22 MR. CRITTON: Form. Speculation. 23 THE WITNESS: I don't know. 24 BY MR. 25 Q. After you brought.., obviously there was a (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 94 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O94440 EFTA01248100 9 10 11 12 13 14 15 16 17 18 19 20 U U Page 1 big investigation that started, correct? 2 A. Yes. 3 Q. And you were caught up in that investigation? 4 A. Yes. S Q. Obviously, because you were called down to the 6 police department to give an interview, right? 7 A. Yes. 8 Q. How long after you brought I. did you first have a conversation with police? A. Definitely months later. Q. Okay. A. That's all I know. Q. Okay. Do you still talk to I. at all? A. No. Q. Were you ever friendly with her? A. Yes. Q. How did that come about; in other words, how did you first become friends with I.? A. 23 Q. Okay. How old were you when you met her, 17 24 at that point? 18? 25 A. About 17, turning 18. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1188f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 95 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094441 EFTA01248101 Page 96 Q. All right. And you would have been a senior? 2 A. That's correct. 3 Q. And she was -- what? -- a sophomore? 4 A. No. 5 Q. Junior? Younger? What grade was she in? 6 A. At that time, I didn't know. 7 Q. She's 14. So did you come to learn what grade 8 she was in later? 9 A. I came to know what age she was after the fact. • • • • • • • id you first meet her? 19 A. I.? 20 Q. Yeah. 21 A. Through my -- 22 Q. I mean, was it at a party or did bring 23 her over to the house? 24 A. brought her to the house. That's it. 25 Just, it was his girlfriend, just brought her around. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 96 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094442 EFTA01248102 Page Q. How old was at the time? 2 A. I don't remember. 3 Q. Younger than you? 4 A. Yes. 5 Q. How is it that she learned about Jeffrey? 6 MR. CRITTON: Form. 7 BY MR. 8 Q. If you know. 9 A. I can't remember. 10 Q. Did you tell her? 11 A. Yes. 12 Q. Okay. Did she learn about Jeffrey for the 13 first time, if you know, from you? 14 A. I don't know. 15 Q. Obviously you're aware that I. ultimately 16 reported what had happened to the police? 17 A. Yes. 18 MR. CRITTON: Form to the last question. 19 BY MR. 20 Q. I'm assuming it made you a little upset. 21 Would you agree with that? 22 A. Yes. 23 Q. And do you sit here today thinking that if it. 24 had not been for I. maybe all this wouldn't have 25 happened? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 97 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O94443 EFTA01248103 Page 98 MR. CRITTON: Form. 2 THE WITNESS: I don't know. 3 BY MR. 4 Q. Do you blame her for all of this? 5 A. No. 6 Q. At all? 7 A. No. 8 (Brief interruption.) 9 BY MR. 10 Q. Are you upset with I. for having started all 11 this -- 12 A. Not at all. 13 Q. even in the least bit? 14 A. No. 15 Q. No? 16 A. No. 17 Q. Are you upset with anyone that all this 18 happened; in other words, this being the whole criminal 19 investigation and all these lawsuits and anything like 20 that, are you upset with anyone over all this? 21 MR. CRITTON: Form. 22 THE WITNESS: Yes. 23 BY MR. 24 Q. Who? 25 A. Myself. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90ftb7174075 3501.182-102 Page 98 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094444 EFTA01248104 9 10 11 12 13 14 15 16 • • • • • Page Q. Why? 2 A. Because I made a stupid decision. 3 Q. Do you think the stupid decision you made had 4 at least partly to do with your age at the time? 5 MR. CRITTON: Form. Asked and answered about 6 three times. 7 THE WITNESS: Yes. 8 BY MR. Q. All right. That time that you took you said that she talked to you or asked you about going? A. Yes. Q. All right. At that point in your life were you -- had you started your job at A. Yes. Q. When did you start that job? A. I don't know. I cannot remember. 22 Q. But you don't remember how old you were when 23 you started that job? 24 A. I do not remember how old I was when I started 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 99 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094445 EFTA01248105 2 Q. Page 100 When you first went to Jeffrey's home for the first time, were you working at then? 3 A. I don't remember. Q. 6 A. 7 Q. 8 A. 9 Q. And 10 the one 11 A. 12 Q. 13 A. 14 Q. 15 16 17 Did you work anywhere else beforellIIIII Before Yeah. I don't remember. we're talking about is in Yes. I think it's on Yes. Got you. Okay. Tell me about that first time you took I. How did that occur and what happened? A. Me and I. picked her up from her house. III 19 Q. Okay. 20 A. We drove to Jeffrey's house. We had a 21 discussion in the car about expectations. 22 Q. Tell me about that discussion. 23 A. I pretty much told her what was told to me, if 24 he asks your age, lie, say that you're 18. Don't 25 indicate that you're still in high school. The more you (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f173.5663-4dad-94e7 3501.182-102 Page 100 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094446 EFTA01248106 Page 101 1 do is the more you make. 2 Q. What did you mean by that? 3 A. The more you're willing to do is the more that 4 he's going to pay you. 5 Q. I don't mean to play naive, but I need you to 6 be specific, if you know. What did you mean by "the 7 more you do?" 8 A. The more you do, the more you make, meaning, 9 if you were obviously going to take off your skirt or 10 your top and do it in a bra or if you were to do other 11 things or allow him to do things to you, you were going 12 to make more money. 13 Q. By "do things to you," you mean, sexually? 14 MR. CRITTON: Form. 15 THE WITNESS: Yes. 16 BY MR. 17 Q. Is what -- what did you mean by -- because he 18 objected -- what did you mean by "do things to you?" 19 A. The massager. 20 Q. Okay. How did you first learn about the 21 massager? 22 A. Well, I first saw it when I went over there 23 the first time -- 24 Q. Right. 25 A. -- in the bottom drawer. But through hearsay (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 101 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094447 EFTA01248107 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 102 I did hear a few of the girls mention the massager 2 throughout me taking different girls. 3 Q. Okay. And what did you hear from the other 4 girls about the massager? 5 A. That he would use it on them. 6 Q. Did you learn that the girls that allowed him 7 to use the massager would make more money? 8 A. From what they said, yes. Q. Were there any other things that he would do during these incidents that you heard about from the other girls, other than the massager? A. That I heard about from the other girls? Q. Yeah. A. I heard from another girl, from that he had slept with a girl named and had made a thousand dollars. Q. Okay. Was that girl someone you knew from high school as well? A. Somebody that I knew on a first name basis in middle school Q. Was she about your age? A. Yes. Q. And you heard that from A. Yes. Q. Other than the massager and this girl that may (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 102 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O94448 EFTA01248108 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 103 1 have slept with him that you heard about from 2 III, were there any other acts that the girls told you 3 about that would get them more money? 4 A. No. 5 Q. Did any of the girls tell you if he had sex 6 with them they would get paid more? 7 MR. CRITTON: Form. 8 THE WITNESS: No. BY MR. Q. Did any of the girls say that if they got completely naked they would get more money? A. No. Q. I'm trying to find out, other than the massager then and that one time that you heard about a thousand bucks, what did you mean by if you do more, you get paid; A. Q. A. Q. A. Q. do more A. in other words, where did you learn that? I was told that. From who? Anyone else tell you that? No. So at some point told you, if you with Jeffrey, you'll get paid more? That's correct. Q. When did she tell you that? Was it before the (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f173-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 103 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O94449 EFTA01248109 Page 104 1 first time you went? After that first time you went? 2 A. I can't recall when. 3 Q. Did you ever discuss that with Jeffrey? 4 A. No. 5 Q. The times that you would bring the other 6 girls, you would get paid money, correct? 7 A. Yes. 8 Q. Who would give you the money? 9 A. Jeffrey. 10 Q. Anyone else? 11 A. No. 12 Q. How would you get it from him? Would he come 13 downstairs or would you go upstairs? 14 A. I don't remember. 15 Q. You mentioned that you brought 12-some-odd 16 girls. Does that mean that you went there to the house 17 those times with the girls when you brought them every 18 time? 19 A. Yes. 20 Q. Did you go there more than just those 12 21 times, plus the time that you went, so we got 13 now. 22 Did you go there more often? 23 A. I don't remember. 24 Q. Did you bring some girls more than once? 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90ftb7174075 3501.182-102 Page 104 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094450 EFTA01248110 Q. Page 105 Which ones did you bring more often than not? 2 MR. CRITTON: Form. 3 THE WITNESS: I don't remember. 4 BY MR. 5 Q. Did you bring I. more than once? 6 A. No. 7 Q. What about 8 A. Yes. 9 Q. Do you remember how many times you brough- 10 her? 11 A. No. 12 Q. Did you bring any of the girls more than a 13 couple times; in other words, did you bring some of them 14 a lot, like, more than five? 15 A. No. 16 Q. Of any of the girls that you brought, after it 17 was over and they came back downstairs, did any of them 18 seem upset? 19 A. Yes. 20 Q. Which ones? 21 A. 22 Q. Tell me about that. 23 A. Apparently her and Jeffrey got into an 24 argument about money. She felt she should have earned 25 more and he didn't feel the same way. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 105 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000.94451 EFTA01248111 Page 106 Q. Did you talk to II about what had occurred? 2 A. Briefly. 3 Q. Was this the time where Jeffrey accused her of 4 looking at the clock? 5 MR. CRITTON: Form. 6 THE WITNESS: I don't know anything about 7 that. 8 BY MR. 9 Q. What did she tell you? 10 A. II just came downstairs. She was very upset. 11 As soon as we left, I had asked her why she was so 12 upset. 13 And she was, like, you know, I should have 14 gotten paid more. I took off my top. I thought I was 15 going to get 300. I didn't get the amount I wanted. 16 And I just looked at her and I told her, don't 17 argue money. Just let it go. 18 Q. Any of the other girls after this incident had 19 occurred with them and they came back downstairs and met 20 with you, did you notice that any of them were 21 apparently upset or didn't seem to like the incident in 22 any way? 23 A. No. 24 Q. You mentioned that Jeffrey paid you the $200. 25 Was that every time or did give you the money some (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 106 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094452 EFTA01248112 Page 107 1 2 3 4 5 6 7 of the time? A. I don't remember. Q. Was there -- when you were bringing girls, was there a routine; in other words, was there something that you knew you had to do every time you got there to the house for you? A. No. 8 Q. Well, when you went the first time, 9 showed you how to set up the table? 10 A. Uh-huh. 11 Q. Showed you where the towels were? Yes? 12 A. Yes. 13 Q. Showed you where the massage oils were? 14 A. Yes. 15 Q. Did you have to do that for the other girls 16 when you brought them, too? 17 A. Not all the time. It was either or me, 18 depending on if she was around. 19 Q. So if wasn't around, you would have to 20 do essentially what did for you that first time? 21 A. correct. 22 Q. And if was around, you'd let her do 23 that? 24 A. Yes. 25 Q. Do you know whether or not ever gave (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 107 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000.94453 EFTA01248113 Page 108 1 Jeff massages? 2 A. I don't know. 3 Q. Did you see any other girls at the house, 4 other than the ones you may have brought and 5 A. Yes. 6 Q. Who? 7 A. I don't know their names. I did hear tha - 8 they were models. They were tall, thin, attractive. 9 They spoke a different language. Don't know their 10 names. 11 Q. How many? Two? 12 A. I don't -- I don't remember. 13 Q. Do you ever recall meeting someone by the name 14 of ? Does that name sound familiar to you? 15 A. Sounds familiar. 16 Q. Any other names that come to your head? 17 A. Not that I can remember, no. 18 Q. All right. Did you ever meet any older women 19 that may have been at the house when you were there? 20 A. No. 21 Q. You say that with a smile. Did you ever see 22 any women at his house that appeared to be over their 23 twenties in any way to you? 24 A. A couple of the models looked older. 25 Q. Any others? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 108 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094454 EFTA01248114 Page 109 A. That I saw? No. 2 Q. Any girls that you ever saw at the house that 3 looked his age? 4 A. No. 5 Q. For all the times that you brought these girls 6 to the house, was it essentially the same routine, you 7 would bring them, they would go upstairs, they would dc 8 whatever they were going to do for Jeffrey, they would 9 then be done, you would get paid $200 and you'd leave? 10 MR. CRITTON: Form. 11 THE WITNESS: Yes. 12 BY MR. 13 Q. I'm wondering whether any of those times that 14 it was different than what I just generally described to 15 you. 16 A. No. 17 Q. So regardless of who the girl was, the routine 18 essentially was the same? 19 A. That's correct. 20 Q. Okay. Other thanill telling you about the 21 disagreement she had, did you have any discussions with 22 any of the other girls about what occurred in the room 23 during the massage? 24 A. Yes. 25 Q. Tell me about those. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 109 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094455 EFTA01248115 Page 110 A. Sometimes when we would walk -- when I would 2 walk to the car with the other girls to go home, I would 3 try to start conversation, asking them what had took 4 place. 5 Q. Okay. 6 A. A lot of them would just look at me and say, 7 nothing. Some would describe the same situation that : 8 went through the first time I gave a massage. 9 Q. Okay. 10 A. That's it. 11 Q. All right. Did any of the other girls tell 12 you that they told Jeffrey to stop at any point? 13 A. No. 14 Q. You told him to stop, correct? 15 A. Yes. 16 Q. As you sit here today though, you don't know 17 what went on in the room with those other girls, do you? 18 A. I do not know what happened. 19 Q. Okay. The staircase leading up to the 20 upstairs, do you recall seeing any pictures on the walls 21 as you went up? 22 A. I did see a couple pictures on the walls. 23 looked like artwork. 24 Q. Did you see any pictures of young girls, that. 25 you can recall? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 110 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094456 EFTA01248116 Page 111 A. Young girls? I don't remember that. 2 Q. Girls? 3 A. I don't remember what sex. 4 Q. Do you recall seeing any photographs of naked 5 women in the house? 6 A. Yes. 7 Q. Where? 8 A. Throughout the house. I can't be sure where. 9 There was a photograph, black and white of a woman's 10 torso, no arms, and her breasts. 11 Q. You don't remember where that was? 12 A. I don't remember what wall that was on or what 13 room. 14 Q. Upstairs or downstairs? 15 A. I don't remember. 16 Q. Do you recall seeing any paintings of naked 17 women in the house? 18 A. Paintings? 19 Q. Paintings. 20 A. I don't remember. 21 Q. When you gave Epstein a massage, did you have 22 to at any point get onto the table with him? 23 A. No. 24 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 111 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W457 EFTA01248117 Page 112 • 10 Q. Okay. When you went to the police station for 11 the first time when they came to your house, were your 12 parents home when the cops first came? 13 A. No. My mom had just left. 14 Q. After the massage you gave to Mr. Epstein, did 15 he ever express to you that he understood you weren't 16 comfortable with what had happened? 17 MR. CRITTON: Form. 18 THE WITNESS: We didn't talk about it. 19 BY MR. 20 Q. At some point did you change your cell number? 21 A. At some point, yes. 22 Q. Why? 23 A. Many reasons. 24 Q. Was one of the reasons so that would 25 stop calling you? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 112 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094458 EFTA01248118 Page 113 1 MR. CRITTON: Form. 2 BY MR. 3 Q. 4 A. One of the reasons was because I was moving on 5 with my life and I had left a lot of that in my past. T 6 was getting prank calls and I was moving. 7 Q. All right. The police came to your house in a approximately October of 2005; is that about right? 9 10 11 A. Don't remember. Q. You were about 17 when they first came to th- house or had you turned 18 yet? 12 A. I don't remember. Wait. What was the date on 13 that? 14 Q. October of 2005. 15 A. October 2005? 16 17 A. I was 18 then. 18 Q. You were 18 at that point? 19 A. Yes. 20 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 113 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094459 EFTA01248119 Page 114 1 3 Q. All right. Do you remember when you changed 4 your cell number, was it before or after the police came 5 to talk to you? 6 A. I believe before. I don't know. 7 Q. Before the police came to talk to you, had 8 called you and talked to you and said anything 9 about police? 10 A. No. 11 Q. After they came to talk to you, she called you 12 and told you about the police, didn't she? 13 MR. CRITTON: Form. 14 THE WITNESS: No. Somebody had called my 15 house from that number. 16 BY MR. 17 Q. Right. 18 A. I did not answer it. It was not spoken about . 19 I did not talk to her or Epstein about any police. 20 Q. Okay. At any time do you recall telling the 21 police that someone, likely it was called you and 22 said the police are conducting an investigation, don't 23 talk to them? 24 MR. CRITTON: Form. 25 THE WITNESS: No. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 114 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW460 EFTA01248120 Page 115 1 MR. : Just answer his questions. 2 THE WITNESS: No. 3 MR. : Then he'll ask you another 4 question. 5 BY MR. 6 Q. Go ahead. Did someone call you? 7 MS. : She said, no. 8 BY MR. 9 Q. Did someone call you? 10 A. Someone called me. I did not speak to them. 11 Q. Okay. Would call you on your cell phone 12 to tell you when Mr. Epstein was in town? 13 A. Yes. 14 Q. Is that how you know or knew when to bring 15 girls to the house? 16 MR. CRITTON: Form. 17 THE WITNESS: Yes. 18 BY MR. 19 Q. Was there anyone else that would call you and 20 tell you that he was going to be in town, other than 21 22 A. No. 23 Q. Was your only contact point and 24 Mr. Epstein? 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 115 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094461 EFTA01248121 Page 116 MR. CRITTON: Form. 2 BY MR. 3 Q. Would Jeffrey ever call you? 4 A. No. 5 Q. He never called you himself? 6 A. No. 7 Q. So it was all through 8 A. Yes. 9 Q. Did you ever tell police that still, 10 even in October of 2005, was trying to call your house 11 and leaving messages for you? 12 MR. CRITTON: Form. 13 THE WITNESS: Don't remember. 14 BY MR. 15 Q. Do you recall calling your house and 16 leaving messages for you after the police started their 17 investigation? 18 A. I don't remember. 19 Q. Did you save any phone conversations or 20 messages that had left at your home? 21 A. I don't remember. 22 Q. Do you remember giving police a tape from the 23 phone message machine where had called your house? 24 A. I don't remember. 25 Q. After speaking to the police that first (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electron tally signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-Ne7-90ftb7174075 3501.182-102 Page 116 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0MM462 EFTA01248122 Page 117 1 time -- well, let me ask you about that, first of all. 2 When the police talked to you that first 3 occasion, did they read you your Miranda Rights? 4 A. I don't remember. 5 Q. Do you recall if they ever told you, you had 6 the right to remain silent? 7 A. No, they never said that. 8 Q. Did you ever sign a document with them; in 9 other words, sign any paper? 10 A. I don't remember. 11 Q. Were your parents with you at that point? 12 A. No. 13 Q. Do you recall the police telling you that you 14 could be criminally prosecuted when they were talking to 15 you? 16 A. Yes. 17 Q. And at what point in the conversation did that 18 occur? Was it at the beginning? The middle? The end? 19 A. I don't remember. 20 Q. What did they say? 21 A. It was at the station. And they had said that 22 I had admitted to some sort of felony and that I can be 23 arrested for it. 24 Q. Okay. The police drove you back to your 25 house? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-Ne7-90ftb7174075 3501.182-102 Page 117 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW1463 EFTA01248123 Page 118 1 A. Yes. 2 Q. Did you know they had a recording device in 3 their car at the time? 4 A. At that time? No. 5 Q. Did you learn later? 6 A. Yes. 7 Q. Did you say something in the car when you were 8 on your way home? 9 A. Yes. 10 Q. Why don't you tell us what you said. 11 MR. : Hang on. I want to have a 12 conference with my client before she answers that 13 question. 14 MR. : On what basis? 15 MR. : Potential privilege. 16 MR. : Which privilege? 17 MR. : Fifth Amendment. 18 MR. : Okay. 19 VIDEOGRAPHER: Going off the record. The time 20 is 1:22 p.m. 21 (Brief recess.) 22 VIDEOGRAPHER: We're back on the video record. 23 The time is 1:30 p.m. 24 MR. : After your break, Madame Court 25 Reporter, if you could go back and just read my (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 118 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094464 EFTA01248124 Page 119 last question before we broke. 2 (Pending question was read.) 3 MS. : I am going to instruct Lc 4 assert her Fifth Amendment Right in order to 5 protect her Fifth, Sixth and 14th, and specifically 6 with regard to any further conversation or 7 statement she had or made to police officers. 8 We've allowed you free reign with regard to her 9 interactions and involvement and dealings with 10 Jeffrey Epstein. But at this point I'm going to 11 instruct her to assert her Fifth Amendment Rights. 12 And I'll repeat it with each question, if you want, 13 or I'll let you ask her and she can assert it 14 herself. 15 MR. : Yeah, I think that procedurally 16 the way we've been handling it in this case so far 17 is that the witness' -- it's the witness' 18 privilege, so the witness has to actually assert 19 that privilege. 20 MS. : Okay. So you need to ask it 21 again. 22 MR. : Right. So I'm going to go through 23 each question that I may ask in sequence really 24 quickly on this topic and then if she's going to 25 assert her Fifth, then I would ask that she do that (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 119 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW465 EFTA01248125 Page 120 individually. Okay? All right. 2 BY MR. 3 Q. The last question I asked is: What did you 4 say in the car after the police interviewed you? 5 A. I'm going to assert my Fifth. 6 Q. Did you tell police, quote, I'm like a Heidi 7 Fleiss? 8 MR. : Stop. You instruct. Get the 9 procedure down. 10 THE WITNESS: I'm going to assert my Fifth 11 Amendment. 12 BY MR. 13 Q. Do you know who Heidi Fleiss is? 14 A. I'm going assert my Fifth Amendment Right. 15 Q. Are you aware that Heidi Fleiss is a 16 relatively famous madame who brought girls or arranged 17 for girls with respect to prostitution in California? 18 A. I'm going to assert my Fifth Amendment Right. 19 Q. At some point after the interview with police, 20 did you learn that they had recorded that conversation? 21 Let me put it this way: Did you learn that 22 they had recorded a conversation that you had in the 23 police car? 24 MS. : That's fine. You can answer. 25 THE WITNESS: Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 120 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_G0ON466 EFTA01248126 Page 121 1 BY MR. 2 Q. Did you ever see a transcript of that 3 conversation? 4 A. No. 5 Q. Did you ever see a probable cause affidavit 6 that had been drafted with respect to you? 7 A. No. 8 Q. Never read it? 9 A. Never read it. I don't even know what you're 10 talking about. 11 Q. Okay. One last thing before we break for 12 lunch. 13 A. Uh-huh. 14 Q. We were talking before about phone calls that 15 had been made to you after police started their 16 investigation. Do you recall those questions generally? 17 A. Yes. 18 Q. I want to ask it this way: After the 19 investigation began, other than the one call that you 20 discussed with us where someone called your house 21 wanting to talk to you, 22 A. Uh-huh. 23 Q. did anyone else ever call your home to 24 discuss with you the investigation, other than your 25 lawyers? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 121 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0MM467 EFTA01248127 Page 122 A. No, not that I can remember, no. 2 Q. Were there any other phone calls that were 3 made to your house after the investigation began about 4 Jeffrey? 5 A. No, not that I can remember. 6 Q. And as you sit here today, your testimony is, 7 you never talked to someone that said they worked for 8 Jeffrey that told you not to talk about the incident; is 9 that your testimony? 10 A. I don't remember ever having a conversation 11 like that. 12 MR. : Okay. All right. Let's take a 13 break for lunch and we'll come back -- and do you 14 need 45 or an hour? 15 VIDEOGRAPHER: Off the record. 16 (Lunch recess.) 17 VIDEOGRAPHER: We're back on the video record. 18 The time is 2:20 p.m. 19 BY MR. 20 Q. Okay. When we left off we were talking about 21 after the police got done with their interview of you 22 and you were going home. 23 I want to go back for just one second. I did 24 forget to ask you something. 25 The questions I was asking you about whether (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401377476-2895) Electronically signed by Sandra Townsend (401377476-2895) 1f88f113.5663.4dad-94e7-90flb7174075 3501.182-102 Page 122 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW468 EFTA01248128 Page 123 1 or not someone who worked for Jeffrey or represented 2 him, that they were from Jeffrey, whether they called 3 you after the police had first contacted you. 4 I want to go to before the police got to you: 5 house and came and talked to you. 6 A. Okay. 7 Q. Before that point when the police came, did 8 anyone talk to you and say anything about the police 9 investigating, what you should say, anything like that? 10 A. I do not ever remember getting a call at all. 11 Q. How about in-person conversations? 12 A. No. 13 Q. Okay. Just so we're clear, no conversations 14 that you can recall, as you sit here today, either 15 before or after the police investigation started, from 16 either Jeffrey, or anyone that represented that 17 they were calling on behalf of Jeffrey or talking to you 18 in person on behalf of Jeffrey, talked to you about what 19 to say or what not to say during the investigation? 20 A. That's correct. That conversation in person, 21 over the phone never happened or on behalf of Jeffrey 22 Epstein. 23 Q. No e-mails? 24 A. No e-mails. 25 Q. No texting? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 123 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW1469 EFTA01248129 Page 124 A. No texting. 2 Q. Did you ever text anything with 3 A. I don't believe I ever did, no. 4 Q. Did you ever e-mail with 5 A. Never e-mail. 6 Q. Were there any other communications that you 7 ever had with , other than phone conversations, in 8 any other format, electronic or otherwise? 9 A. No. 10 Q. Okay. After the police dropped you off after 11 that initial interview, what did you do? 12 A. Well, I had explained to my parents what had 13 just happened and just taken place. 14 My -- I don't recall if my dad was there. My 15 mom was. 16 I sat her down and I discussed what was going 17 on and what had happened. 18 My dad was immediately contacted. • • • • • • • (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 124 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA -00094470 EFTA01248130 Page 125 3 Q. Oh, okay. So at that point a criminal 4 attorney was hired by your parents? 5 A. That's correct. 6 Q. Are you still represented by that criminal 7 attorney to this day? 8 A. 'Til this day? 9 MS. : I don't really know that that's 10 an appropriate question. I'm going to instruct her 11 not to answer it if the only way she knows the 12 answer to that is through talking with her criminal 13 attorney or with a civil attorney. 14 BY MR. 15 Q. All right. Well then, I guess, let me ask it 16 this way: The attorneys that are here representing you 17 here today are your civil attorneys. 18 A. Yes. 19 Q. Do you understand that? 20 A. Uh-huh. 21 Q. Yes? 22 A. Yes, I do understand that. 23 Q. Who's paying their bill? 24 MS. : I'm going to ask her not to 25 answer that if the only way she knows that (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 125 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94471 EFTA01248131 Page 126 information is through her attorneys. 2 BY MR. 3 Q. Okay. Do you know who is paying their bill, 4 other than what the attorneys may have said to you? 5 A. No. I know who's paying my bill from what my 6 attorneys have told me. 7 Q. And that's the only way you know it? 8 A. And that's the only way I know it. 9 Q. Let me ask it this way: Are you paying for 10 the civil attorneys? 11 A. No. 12 Q. Are your parents paying for the civil 13 attorneys? 14 A. No. 15 Q. Are any of your relatives paying for the civil 16 attorneys? 17 A. No. 18 Q. Did you find the civil attorneys? 19 A. Did I find the civil attorneys? 20 Q. Yes. It's a very good law firm that's 21 representing you here today in this civil litigation 22 context. 23 A. No, I did not find my attorneys. My criminal 24 lawyer did. 25 Q. Okay. You got paid $200 every time that you (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 126 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA J30094472 EFTA01248132 Page 127 1 took a girl to Jeffrey's house. But do you know, as you 2 sit here today, the total amount of money that you made 3 taking girls there? 4 A. I do not know. 5 Q. Would you agree with me that it had to be in 6 the thousands? 7 A. Yes, I can say that. 8 Q. Had to be in the multiples of thousands? 9 A. I wouldn't say, multiples of thousands. 10 Q. Well, if we're talking -- 11 A. Wait. What do you mean, "multiples?" Two 12 thousand? Three thousand? 13 Q. Yes. 14 A. Yes. I'm sorry. I thought you were talking 15 about double digits. 16 Q. No. Let me be more specific. 17 If we look at just the 12, the dozen at 200 18 each time, that's about $2,400. 19 A. Plus the time that I massaged, which would 20 bring it up to 2600. 21 Q. And then you brought some girls more than 22 once? 23 A. Okay. 24 Q. Right? 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 127 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94473 EFTA01248133 Page 128 Q. So would you agree with me that the number 2 that you made just bringing girls would have to be in 3 excess of 3,000? 4 A. I don't know. 5 Q. Did you deposit any of the money that you made 6 into a bank account? 7 A. No. 8 Q. You just kept the cash and then spent it? 9 A. Yes. 10 Q. Did Mr. Epstein give you -- let me ask it this 11 way: Did Mr. Epstein or someone on his behalf give you 12 any money, other than when you brought girls? 13 A. No. 14 Q. Did you get a Christmas bonus? 15 A. No. 16 Q. Did you get a Western Union telegram of money 17 at any point? 18 A. No. 19 Q. Are you aware that other girls did? 20 MR. CRITTON: Form. 21 THE WITNESS: I guess I am now. 22 BY MR. 23 Q. Are you learning that through me or did you 24 learn that -- 25 A. I learned through bonuses. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94e7-90flb7174075 3501.182-102 Page 128 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000.94474 EFTA01248134 Page 129 Q. That's what I'm looking for. Did you get 2 bonuses? 3 A. I did not personally, no. 4 Q. Did Mr. Epstein give you any gifts? 5 A. No. 6 Q. Have you heard that he paid for certain baby 7 showers of some girls? 8 A. A baby shower? No. 9 MR. CRITTON: Form. 10 BY MR. 11 Q. Never heard about that? 12 A. No. 13 Q. Did he ever rent you a car? 14 A. No. 15 Q. Did you ever ask him to rent you a car and he 16 said no? 17 A. No. 18 Q. Did he ever pay for anything, that you can 19 think of as you sit here today? 20 A. He never paid for anything. 21 Q. So the only thing he gave you was the $200 22 cash every time you brought a girl and the time that you 23 did the massage yourself? 24 A. Can I have a minute? 25 Q. Sure. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7.50f1b7174075 3501.182-102 Page 129 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O94475 EFTA01248135 Page 130 MR. CRITTON: What was the question? Would 2 you read it back, please? 3 MR. : Yeah. 4 MS. : Go ahead. 5 MR. : Yeah. While you figure it out, 6 let her read it back. 7 (Pending question was read.) 8 MS. : I think we've answered that. 9 MR. : Okay. 10 THE WITNESS: That was the only time he paid. 11 That's the only time I received money from him. 12 BY MR. 13 Q. Did you receive anything else from him, other 14 than money? 15 A. No. 16 Q. Did you get anything from , other 17 than money? 18 A. No. 19 Q. Did you get money from 20 A. No. 21 Q. Did you get money from anyone other than 22 Jeffrey or that said that they were working on 23 behalf of Jeffrey or that you knew was working on behalf 24 of Jeffrey? 25 A. The only person that ever gave me money was (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 130 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA J30O94476 EFTA01248136 Page 131 1 Epstein. And I have not received anything else. 2 Q. No one on his behalf? 3 A. No one on his behalf. 4 Q. Gave you anything? 5 A. Gave me anything. 6 Q. Okay. All right. After the investigation 7 began and you talked to police, did you ever have any 8 further conversations with Mr. Epstein after that date? 9 A. No. 10 Q. Did you ever have any further conversations 11 with after that date? 12 A. No. 13 Q. Do you remember before the police came to your 14 house, III. calling you at III 15 A. Yes, I do recall that. 16 Q. What did she say to you during that 17 conversation, as best you can recall? 18 A. As best as I can recall, she called once. 19 They told her I was busy, to call back later. 20 She called back a second time, asked to speak 21 with me. 22 I then picked up the line. 23 She had asked me if she can work for Jeffrey 24 again. 25 I told her no. I told her that she was (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7 3501.182-102 Page 131 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW1477 EFTA01248137 Page 132 1 basically full of herself and that I heard she was 2 trying to set me up and trying to -- to rat me out, is 3 basically what I had said to her. 4 Q. Have you seen the transcript of that phone 5 conversation that you had with her? 6 A. I have not seen the transcript, no. 7 Q. Okay. There were two phone calls that you can 8 recall, one where you weren't available and the second 9 one where you actually talked to her? 10 A. That's correct. 11 Q. Because your attorney asked before to see, let 12 me just show this to your attorney really quickly. 13 MR. CRITTON: You going to mark it as an 14 Exhibit? 15 MR. : No. 16 MS. : What are you showing me? 17 MR. : The phone call. 18 MS. : Can you clarify, like, how this 19 was transcribed? Is this something your office 20 did? 21 MR. : From the police. No, it was given 22 to me from the State Attorney and the police 23 department. 24 THE WITNESS: And it was recorded. 25 MS. : And is this a document you're (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 132 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 BFTA_O0O94478 EFTA01248138 Page 133 going to ask some questions about now? 2 MR. : Yes. 3 MS. : Then I'm going to have her read 4 it as well. 5 MR. : Okay. That's fine. I didn't know 6 if you wanted to read it first. 7 MR. CRITTON: Before you start, let me read 8 it, too. 9 MS. : Do you want to get a couple 10 copies? 11 MR. : Do you want to take a second so we 12 can all read this? 13 THE WITNESS: What is this? Is U-N-K unknown 14 caller? Is that me? 15 MR. : It's one of the things I was going 16 to ask you. 17 MS. : Let's get copies of all this for 18 everybody, since no one seems to have it. 19 MR. CRITTON: Why don't you mark it as an 20 Exhibit, too. Why don't we call it Exhibit 2 and 21 have it copied, put a sticker on it, please. 22 MR. : They got to stop talking for you 23 to copy it. I know. 24 VIDEOGRAPHER: You want to go off the record? 25 MR. : Yeah. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 133 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA J)0O94479 EFTA01248139 Page 134 1 VIDEOGRAPHER: Going off the video record. 2 The time is 2:35 p.m. 3 (Brief recess.) 4 VIDEOGRAPHER: We're back on the video record. 5 The time is 2:35 p.m. 6 BY MR. 7 Q. While they're making copies of the other 8 document I was going to ask you about, I want to go 9 through some of these photographs, if I could, for a 10 minute. 11 I'm going to mark this one as Exhibit 2 to 12 your deposition. Let me just hold it up for the camera 13 first. 14 MR. CRITTON: I think we marked the statement 15 number 2. 16 MR. : No. You wanted to mark the 17 statement number 2, but I never agreed to that. 18 this is number 2. 19 VIDEOGRAPHER: That's fine. 20 (Exhibit number 2 was marked for 21 identification purposes.) 22 BY MR. 23 Q. All right. I'm going to show you what is 24 Exhibit 2. And let me just ask you, first, do you 25 recognize the photograph? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 134 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA j0O94480 EFTA01248140 Page 135 A. Yes. 2 Q. Who took it? 3 A. 4 Q. What was it for? 5 A. 6 Q. And how old were you in this photo? 7 A. Eighteen, 19 maybe. 8 Q. And this is you? 9 A. This is me. 10 Q. Where was this posted on the Internet? 11 A. This was posted on my -- 12 Q. Initially? 13 A. Initially on My Space page. 14 Q. Subsequently it was posted a lot of different 15 places on the Internet. You're aware of that, correct? 16 A. No. What are you talking about? 17 Q. In news stories regarding Mr. Epstein, have 18 you seen this posted in other places? 19 A. Yes. 20 Q. They've used this photograph when talking 21 about -- 22 A. Wait. I'm confused. 23 Q. Let me back up. 24 This is a photo that you put on the Internet 25 yourself? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5683-4dad-94e7 3501.182-102 Page 135 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W481 EFTA01248141 Page 136 1 A. Yes. 2 Q. On your My Space page? 3 A. Yes. 4 Q. And it shows you at around 18 years old? 5 A. Yes. 6 Q. Have you seen it 7 MR. CRITTON: Form of the last question. You 8 said 18 or 19. 9 MR. : Eighteen or 19. 10 BY MR. 11 Q. Have you seen this posted any other place, 12 other than your My Space page, on the Internet? 13 A. That, and a lot of the blogs about Epstein and 14 the whole situation in Google. Other than that, no. 15 Q. This particular photo of you, have you had any 16 physical changes to your body subsequent to this 17 photograph being taken? 18 MS. : Objection. I'm not sure where 19 or why you're going with this. I don't think it's 20 relevant. You haven't laid any type of predicate. 21 And this is a private matter for , who is not 22 a Plaintiff or a Defendant in this case. 23 I'm going to instruct her not to answer that 24 question. 25 BY MR. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 136 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094482 EFTA01248142 Page 137 Q. Okay. Did you post any photos of yourself on 2 the Internet younger than the age of 18; in other words, 3 on your My Space page, were there any photos of you 4 younger than 18? 5 A. I don't remember. 6 Q. You have photos of you at the time when you 7 were 16, 15, 17 years old? 8 A. Possibly. 9 Q. At home? 10 A. Yeah. 11 Q. Okay. Let me show you what we'll mark as 12 Exhibit 3. Ask you if you recognize anyone in this 13 particular photograph. 14 (Exhibit number 3 was marked for 15 identification purposes.) 16 MR. : And hold this up for the camera 17 first. 18 VIDEOGRAPHER: Okay. 19 MR. CRITTON: Let me see it again, please. 20 MR. : Got your own. 21 BY MR. 22 Q. Take a look at that photo. 23 Do you recognize anyone in the photograph 24 we've marked as Exhibit 3? 25 A. The middle girl looks like (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 137 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O94483 EFTA01248143 Page 138 Q. Recognize any of the men in that photograph? 2 A. No, I don't. 3 Q. All right. When you say, ' ," you mean, 4 5 A. Yeah. 6 Q. And is the girl that you met at 7 Jeffrey Epstein's house? 8 A. Yes. 9 Q. Let me show you what we'll mark as Exhibit 10 MR. CRITTON: Did you have any extra copies of 11 Exhibit 2 for us all? 12 MR. : I do. 13 MR. CRITTON: Thank you. 14 MR. : Mark the photograph as Exhibit 4. 15 (Exhibit number 4 was marked for 16 identification purposes.) 17 BY MR. 18 Q. Show this one to you. Camera first. 19 Okay? Let me show you what we marked as 20 Exhibit 4. 21 First of all, do you recognize the gentleman 22 in that photograph? 23 A. Mr. Jeffrey Epstein. 24 Q. Do you recognize the girl in that photo? 25 A. No. I don't remember her. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electron Gaily signed by Sandra Townsend (401.377-676.2895) Elecnonicaily signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94e7-90flb7174075 3501.182-102 Page 138 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O94484 EFTA01248144 Page 139 Q. Does not look familiar to you? 2 A. I don't remember her. 3 Q. Let's go now. 4 MR. : We've got the copies of the 5 statement brought back? 6 MS. : Yes. You need a copy? 7 MR. : You got my original? 8 MS. : Take your time and read the 9 whole thing. 10 MR. : Somebody's got one that's 11 highlighted. Who's got it? 12 THE WITNESS: I think I have it. 13 MR. CRITTON: I think I do. 14 THE WITNESS: Nevermind. 15 BY MR. 16 Q. Go ahead. I want you to read it. It's only 17 four pages. 18 MR. CRITTON: Can we mark it as Exhibit 5? Do 19 you have any objection to doing that? If not, I'll 20 just mark it as a Defense Exhibit. It's an Exhibit 21 you're showing to her. 22 MR. : I just don't know. Let me ask 23 some questions and I'll figure it out. 24 MR. CRITTON: Well, I'm going to direct it be 25 marked by the reporter. It's a statement that's (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7 3501.182-102 Page 139 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O94485 EFTA01248145 Page 140 being shown to her. 2 Mark it as Defense Exhibit 1, please. 3 MR. : I think you can only do that 4 during your examination, but... 5 MR. : I think so, too, but... 6 MR. CRITTON: I'm doing it now. Call me in 7 front of the Judge on it. 8 MR. : Bob Critton rules of taking 9 deposition. It's a different rule book. 10 Get up in years, you're allowed to do that. 11 (Defendant's Exhibit number 1 was marked for 12 identification purposes.) 13 BY MR. 14 Q. Okay. Does that help refresh your 15 recollection about the phone call that I. placed to you 16 that was being recorded? 17 A. I don't really remember it like this, but, 18 then again, it was years ago. I do remember her calling 19 twice though. 20 Q. And you noticed in this, what's now, I guess, 21 been marked as Defendant's Exhibit 1, you remember or 22 you've seen that there's two phone calls noted here in 23 this Exhibit? 24 A. Well, I was kind of confused because it looked 25 like she called my house. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-Sile7-90ftb7174075 3501.182-102 Page 140 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA j0O94486 EFTA01248146 Page 141 Q. Right. 2 A. And then it looks like she called my house 3 again. 4 And then it looked like maybe she called • I 6 Q. Okay. In looking at the conversation 7 beginning on page 3, do you see that? 8 A. Yes. 9 Q. All right. Let's start from the top. 10 Do you know whether there was a III working at 11 12 A. Yes. 13 Q. -- when you worked there? 14 Who? III who? 15 A. 16 Q. Okay. Friendly with her? Just a working 17 friend? 18 A. Employee. 19 Q. Do you recall III being the one that took the 20 call and got you to get you on the phone? 21 A. I don't remember. 22 Q. Do you recall I. calling you and saying, I 23 need some money, I was wondering if you could take me to 24 Jeff's house? 25 A. I remember I was having a conversation about (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 141 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0OW487 EFTA01248147 Page 142 1 me taking her back to Jeff's house. 2 Q. And it says here on line 11: "I was wondering 3 if you could take me back to Jeff's house." 4 Do you recall her saying that? S A. No. But like I said, this was a couple years 6 ago. 7 Q. It notes here, the next line on page -- on 8 line 12 and 13: "I don't know. The last time I did 9 that, um, I heard that your dad wanted to press charges 10 and stuff." 11 What were you referring to? 12 A. Well, went around telling everybody that 13 she was going to have me arrested and she was going to 14 have her parents press charges against me because of 15 everything that took place. So once I found out about 16 that, I pretty much let her knew -- let her know that : 17 knew what was going on. 18 Q. Okay. How did you hear about that? 19 A. • (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f1134663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 142 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094488 EFTA01248148 Page 143 Q. So you heard from that I. was telling 2 3 4 5 6 7 people that she was going to press charges or somebody from her family was going to press charges? A. That's correct. Q. Made you upset? A. Shocked. Q. Made you mad? 8 A. No. Shocked. 9 Q. Okay. Weren't mad at her at all for this? 10 A. Shocked. 11 Q. Do you recall her saying in response: "I 12 don't even live with my dad anymore?" 13 A. I don't remember that. 14 Q. It says here on line 15: "Oh, well. I don't 15 know. It was going around that you were going to press 16 charges and get me in trouble and shit." 17 Do you remember saying something like that? 18 A. I don't remember. Like I said, this was years 19 ago. I can't recall it. 20 Q. Okay. Despite what may have been said, do you 21 recall mentioning to her that you would call Jeffrey and 22 see if you could set it up? 23 A. I don't recall that, either. 24 Q. Because it appears on the next page, line 5, 25 you say: "Okay. I'll definitely give you a call (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f173.5663-4dad-94e7 3501.182-102 Page 143 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA j0O94489 EFTA01248149 Page 144 1 tomorrow." 2 Do you remember saying anything like that? 3 A. I don't, no. 4 Q. Okay. Did you have any further conversations 5 with I. about Jeffrey after this phone call, that you 6 can recall? 7 A. I don't ever recall her -- I don't ever recall 8 calling her back after this took place. I don't ever 9 recall setting up another appointment with Epstein. 10 could have just been telling her what she wanted to 11 hear. 12 Q. Do you think that if it hadn't been for I. 13 that this would have never -- "this," being, the 14 criminal and civil and all this other stuff -- would 15 have never happened? 16 MR. CRITTON: Form. 17 MS. : Objection. You're asking her to 18 speculate. 19 THE WITNESS: I don't know. 20 BY MR. 21 Q. Before I had asked you about who was paying 22 for your civil attorneys. Do you recall those 23 questions? 24 A. Yeah, I do. 25 Q. Going back to that subject for a moment. Was (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 144 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W490 EFTA01248150 Page 145 1 your mom ever with you when you had conversations with 2 the civil attorneys? 3 A. No. 4 Q. Physically present in the room at any point? 5 A. No. 6 Q. Does your mom know who's paying for the civ._ 7 attorneys? 8 A. Yes. 9 Q. How does she know? 10 A. I told her. 11 Q. What did you tell her? 12 A. I told her what I was told. 13 Q. Which was? 14 A. I told her that my attorney was being paid by 15 Mr. Epstein. 16 Q. Why is he paying for your civil attorney, if 17 you know? 18 A. 23 MS. : I'm going to stop you there. 24 anything beyond this point is specifically with 25 regard to conversations you've had with (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 145 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094491 EFTA01248151 Page 146 1 and and/or myself, I do not want you 2 to disclose any of the information. 3 THE WITNESS: Okay. 4 And took us to 7 BY Mr. 8 Q. I don't want to know about conversations 9 you've had with the civil attorneys. 10 But why did you think -- you -- think that you 11 needed civil attorneys to help you in this process? 12 20 BY MR. 21 Q. And I don't want to know anything the lawyers 22 said to you. I want to know why you think you need 23 civil attorneys for something -- 24 MS. : And if the reason is because 25 your criminal or civil attorney told you, you need (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f1134663-4dad-94e7-90ftb7174075 3501.182-102 Page 146 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094492 EFTA01248152 Page 147 a civil attorney, you do not need to disclose that 2 reason. 3 THE WITNESS: Okay. 4 I'm going to plead the Fifth on that one. 5 MS. : You don't have to plead the 6 Fifth. 7 THE WITNESS: Whatever. This is confusing. 8 I'm not answering it. 9 MS. : No. You do not need to answer 10 that. 11 THE WITNESS: I'm not answering it. 12 MS. : If it is -- if it is a 13 conversation you had with one of your attorneys, 14 you do not need to disclose any of that 15 conversation. That is all privileged. 16 BY MR. 17 Q. So we can avoid conversations you've had with 18 attorneys, let's just talk about family now. 19 A. Uh-huh. 20 Q. You're over the age of 18. You're an adult. 21 But you still, nonetheless, had conversations with you 22 mother and your father about this whole thing, I assume? 23 A. Yes. 24 Q. Did you talk to them about having an attorney 25 present for your deposition here today? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f173.5663-4dad-94e7 3501.182-102 Page 147 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94493 EFTA01248153 Page 148 A. Of course. 2 Q. Okay. And, in fact, your mom was here 3 earlier? 4 A. Yes. 5 Q. Okay. I assume you had a conversation with 6 her about why you felt you would need an attorney here 7 today. Did you? 8 A. No. 9 Q. Never talked to her about why you'd be 10 represented by a lawyer here at this deposition? 11 A. Me and my mom never had a conversation like 12 that, no. 13 Q. You mentioned life savings and retirement and 14 all that. 15 A. Uh-huh. 16 Q. Did that get used up with respect to the 17 criminal proceeding, -- 18 A. Yes. 19 Q. -- paying the criminal lawyers? 20 A. Yes. 21 Q. Did you come out of pocket at all to help pay 22 for the criminal lawyers? 23 A. Not me, personally, no. 24 Q. Your parents paid for that? 25 A. That's correct. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 148 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O94494 EFTA01248154 Page 149 Q. All right. Has anyone told you, other than 2 the lawyers, that there is no concern for criminal 3 prosecution, as you sit here today, other than what the 4 civil or criminal lawyers have told you? In other 5 words, did a -- did your parents tell you that you don't 6 have to worry about criminal prosecution anymore? Did 7 any witnesses tell you that? Anything like that? 8 A. Yes. 9 Q. Who? 10 A. My father. 11 Q. What did he say? 12 A. Just told me that the criminal part is pretty 13 much over. This is the civil part. This is where 14 things get ugly, messy, and then it will all be 15 finished. 16 Q. Okay. All right. What did your father think 17 of this when this whole thing broke open? 18 MR. CRITTON: Form. 19 THE WITNESS: I don't know. 20 BY MR. 21 Q. Did you talk to him about it? I mean, you 22 obviously had to inform him after you went and talked to 23 the police? 24 A. I did. 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 149 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94495 EFTA01248155 I I 4 Q. What was his reaction? 5 MR. CRITTON: Object to form. The question 6 serves no purpose, other than you're trying to 7 harass her and intimidate her or make her life 8 miserable at this point. 9 MS. : And I'm allowing a little bit, 10 but not much more. 11 MR. : Actually, I'm not. I'm showing 12 what the common, ordinary individual's reaction 13 would be to a man molesting a 16 year old little 14 girl, if you really want to get into it. 15 MR. CRITTON: Same. 16 BY MR. 17 Q. What did your father think of all this when 18 you told him about what had happened? 19 A. He cried. 20 Q. Did he blame you? 21 MR. CRITTON: Form. 22 MS. : Objection. And I'm going to 23 instruct her not to answer that question. 24 MR. : Come on. 25 MS. : I don't think it's relevant to (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7 3501.182-102 Page 150 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0MM496 EFTA01248156 1 2 this case. MR. : Page 151 I'll tell you exactly why it's 3 relevant. 4 MR. CRITTON: Let her finish. 5 MR. : I'm sorry. Go ahead. 6 MS. : She's not a Plaintiff. She's 7 not a Defendant. She has not put her character at a issue. This is a private matter. It serves no 9 purpose, other than to upset and harass her, as you 10 can see it's doing right now. 11 MR. : I have no intent to upset her or 12 harass her. But when a pervert like Jeffrey 13 Epstein is molesting 16 year old girls, I have 14 every right to ask a girl who's been through it 15 what it made ordinary people think of. And when 16 he's saying in defense to the civil action that 17 these girls had it coming to them because they 18 volunteered for it, I'm curious what an ordinary 19 individual's parent would think, much like all of 20 the other girls that were brought to this home fo:: 21 this man to molest. 22 MS. : You have not noticed her father 23 or her mother for deposition today. 24 MR. : And I don't want to have to go 25 there. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 151 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094497 EFTA01248157 Page 152 MS. : You're asking her how her 2 parents feel. You're asking her to speculate as to 3 how her parents feel. And that serves no other 4 purpose than to 5 MR. : I don't want to know what her 6 parents felt. I want to know what her parents' 7 reaction was that she witnessed and heard. And I 8 think that's entirely relevant to, not only the 9 claims in this case, but the defenses that have 10 been raised by Mr. Epstein. 11 MR. CRITTON: Let me add to my form objection. 12 It is, number one, I object to your speech. I 13 think it was inappropriate. 14 Number two is, many of the Plaintiffs' lawyers 15 have fought me even getting this kind of 16 information from Plaintiffs in this case, less some 17 witness who has -- is neither a party, nor has any 18 involvement in the case, other than is a 19 third-party witness. 20 So I would suggest, is that, with the 21 difficulty and the fighting that I've had from 22 Plaintiffs' lawyers to get responses to those 23 questions, I'm not sure that either Judge Hafele in 24 this particular -- Judge Hafele, who I think will 25 have an opportunity to look at this record if it's (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-SW-90flb7174075 3501.182-102 Page 152 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W498 EFTA01248158 Page 153 brought in front of him, would necessarily find 2 that that's appropriate questioning. But that's 3 just my form objection. And obviously she has 4 her -- she has her own lawyer that's going to 5 instruct her to do, so you and I can talk as long 6 as we want, but it's not going to change her 7 lawyer's directions, I assume. 8 MS. : I'm instructing you not to 9 answer that question now absent a Court Order. 10 (Brief interruption.) 11 MR. : Hello. 12 MR. : Yes. I'm calling in to take 13 place. 14 MR. : He's sitting right here. 15 MR. : Does that mean I'm out, 16 MR. : You're out. 17 MR. : All right, buddy. 18 MR. : The A team is coming in. 19 MR. CRITTON: I'd like that on the record, 20 please. 21 MR. : All right. I'm going to shut it 22 down, but, , you have -- you have the baton, so 23 to speak. 24 MR. : Okay. 25 BY MR. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 153 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_O0O.94499 EFTA01248159 Page 154 Q. All right. I'm going to ask the question and 2 a lawyer, your lawyer is going to either let you respond 3 or not let you respond, so just wait, if you would. 4 You already told us that when you told your 5 father about what had happened with Jeffrey Epstein that 6 he cried. What I'm asking now is: What did he say to 7 you; in other words, did he say, it's your fault? Did 8 he blame you? 9 MS. : Objection. Predicate. 10 Relevance. And I believe these questions serve nc 11 purpose, other than to harass and upset Ms. 12 who, again, is not a Plaintiff or a Defendant. 13 She's merely a witness and should not be subjected 14 to what she's going through right now. Absent a 15 Court Order, I'm asking her to refrain from 16 answering those questions. And I'd also ask for a 17 break, if we could take one, so she can compose 18 herself. 19 MR. : Okay. I'll definitely give you 20 the break. I certainly don't think I'm harassing, 21 but I'll give you the break. 22 VIDEOGRAPHER: Going off the record on tape 23 number two. The time is 2:57 p.m. 24 (Brief recess.) 25 (Deposition continued to Volume II.) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 154 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094500 EFTA01248160 Page 155 1 2 3 4 5 CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF PALM BEACH 6 I, the undersigned authority, certify that 7 8 sworn on the 10th day of November, 2009. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 personally appeared before me and was duly Dated this 20th day of November, 2009. Sandra W. Townsend, Court Repo? Notary Public - State of Florida My Commission Expires: 6/26/12 My Commission No.: DD 793913 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1188f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 155 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094501 EFTA01248161 Page 156 CERTIFICATE 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I, Sandra W. Townsend, Court Reporter and Notary Public in and for the State of Florida at Large, do hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth; that I was authorized to and did report said deposition in stenotype; and that the foregoing pages numbered 1 to 154, inclusive, are a true and correct transcription of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. I further certify that I am not attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. Dated this 20th day of November, 2009. Sandra W. Townsend, Court Reporter (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7 3501.182-102 Page 156 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094502 EFTA01248162