Case File
efta-efta01733876DOJ Data Set 10CorrespondenceEFTA Document EFTA01733876
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DOJ Data Set 10
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EFTA DisclosureText extracted via OCR from the original document. May contain errors from the scanning process.
The truthfulness of M's allegations and testimony in M's Civil Action, have been
severely compromised by the necessity to ask for a a multi-million dollar payoutto
maintain the fraud of the .
firm. As settlements of millions of dollars were
represented to their "investors", they needed to maintain a fiction of extraordinary
damages... however under questioning, admitted to being a call girls /escort
since the age of fifteen, keeping the record of her earnings form tens of johns in her
lined bible.
In April 2007 before she was represented by
and other
attorneys at
..
gave sworn testimony to the FBI speaking of EPSTEIN in
exceptional! glowing terms and directly contradicting all of the central allegations
on which
's Civil Action a ainsUastein is now based. , However, once in the
hands of
and M, when faced with the prospect of a settlement
or verdict which
himself, has claimed numerous times to EPSTEIN's
attorneys to be worth tens of millions of dollars, M's story changed dramatically.
For example , In her sworn statement to the FBI, .
was insistent that "Jeffrey is an
awesome man." (See page 21, line 23 of Sworn FBI Statement). At the conclusion of
that tape recorded and sworn statement shestated : "I hope Jeffrey, nothing
happens to Jeffrey because he's an awesome man and it really would be a shame. It's
a shame that he has to go through this because he's an awesome guy and he didn't
do nothing wrong, nothing." (See pages 57-58 of Sworn FBI Statement). In fact, ..
spoke so highly of EPSTEIN and her interactions with him that the US Attorney
informed a federal court in July 2008 that the US Attorney could not consider .
a
victim. (See excerpt from Villafana Declaration - page 6)
Yet, by Si ember 24, 2009, the date on which ..
began her deposition in the Civil
Action, Ms new and very different tale about purported sexual misconduct under
the supposed influence of EPSTEIN had been thoroughly practiced and her
indoctrination into the
scam was complete. In her deposition in the
Civil Action, ..
declared: I don't want money
"1 want justice." (see Depo Transcript 218:14)
"He needs time in jail. He doesn't want to be - this is not right for him to be
on the streets living daily ..." (see Depo Transcript 219:21-23)
"You don't think my whole life I have lived that shitty life because of Jeffrey
Epstein?" (see Depo Transcript 222:7-8)
"... Jeffrey Epstein is going to get justice, that we're going to get justice from
him." (see Depo Transcript 222:23-24).
In her sworn testimony before she met
. ..
was emphatic that her
interactions with Epstein involved no inappropriate sexual touching in any way, in
fact exactly the opposite
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Q: So he never pulled you closer to him in a sexual way?
A: I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no.
(see page 21, lines 20-23 of Sworn FBI Statement)
Q: Did he at any point kiss you, touch you, show any kind of affection towards
you?
A: Never, never. (see page 21, lines 5-7 of Sworn FBI Statement)
However, within a month after
brought M. within the fold at the end of
mit e 2008, M. filed the Civil Action alleging, among other things, sexual battery of
M. by Epstein. B the time the Complaint was amended a second time in April
2009, after
Joined M, the allegations against EPSTEIN in C's
complaint became even more salacious. In paragraph 12 of C's Second Amended
Complaint, .. alleges among other things, that:
Jeffrey Epstein coerced, induced, or enticed ...the then minor Plaintiff to
commit various acts of sexual misconduct. These acts included, but were not
limited to, fondling and inappropriate and illegal sexual touching of the then
minor Plaintiff, forcing or inducing the then minor plaintiff into oral sex or
other sexual misconduct..."
In her sworn statement,prior to
told investigators that
the individual who first brought
to EPSTEIN's mansion, told
"make sure you're 18 because Jeffrey doesn't want any undera e irls." (see a e 8,
lines 6-8 of FBI Sworn Statement). Nevertheless, after
tutelage, M. told
a very different story:
Q: My question was what did
tell you to tell Mr. Epstein about your
age?
A: She said it didn't matter.
Q: That's your recollection about what she said? Yes, she said - I remember
her saying it doesn't matter. Don't worry about it.
(see Depo Transcript 199:20-25)
M. testified, before meeting
: "I always made sure - I had a fake ID,
anyways saying that I was 18." (see page 8 lines 5-6 of Sworn FBI Statement). Yet
when questioned about her fake ID after
Q: And did you have a fake ID?
A: No.
Q: Have you ever had a fake ID?
A: No.
(see Depo Transcript 300:5-8)
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M. also testified before
that EPSTEIN never knew she was underage:
"And, of course, he thought I was 18." (see page 13, lines 21-22 of FBI Sworn
Statement p13,121-22)
"No. No. because I always stood back from that because I didn't want him to
know that I was 16." (see page 40, lines 18-20 of FBI Sworn Statement)
"We [others M. brought to EPSTEIN) talked about it like because we were
underage, but he thought we were 18. We were like hopefully no one finds
out. Hopefully, Jeffrey doesn't find out our age." (see page 45, lines 13-16 of
FBI Sworn Statement)
Yet, once again, after
her story :
"I was scared to reveal my age to Mr. Epstein. She I
I said it
was ok. It doesn't matter. It doesn't matter. And I was scared because I
knew it was illegal, so I told Jeffrey and I told her that I was going to tell
Jeffrey that I was 17 because it was closer to 18." (see Depo Transcript
199:14-19).
also advised federal investigators, before
that EPSTEIN never knew
that any of the girls she brought to EPSTEIN's mansion were underage:
"I knew the girls I brought to him were 18 or 19 or 20 - I would tell my
girlfriends just like
approached me. Tell him you're 18. Well, these
girls that I brought, I know they were 18 or 19 or 20. And the girls that I
didn't know and I don't know if they were lying or not, I would say make sure
that you tell him you're 18." (see page 22, lines 12-17 of Sworn FBI
Statement)
However, to bolster her claims in the Civil Action, M. made drastically different
allegations. Instead of the 18 or 19 or 20 year old women that M. told federal
investigators she brought to EPSTEIN's mansion, M. now claimed in her deposition
that she brought "13, 14, 15 year old" girls (see Depo Transcription 173:24-174:1),
and alleged in paragraph 13 of the Second Amended Complaint, filed on her behalf
by
and M, that:
"Defendant, Jeffrey Epstein, instructed, coerced and otherwise induced the
then minor Plaintiff to bring him other minor children for the purposes of
further satisfying his deviant sexual attraction to minors."
When
asked before
, how long she had been going to Epstein's
mansion,
stated "I saw him for a good year." (see page 19 lines 10-13 of Sworn
FBI Statement). Yet, after having the benefit of counsel from
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and others at M, Ill's "beginning in approximately August 2002 and continuing
until approximately September 2005," a period of over three years. II. tried to
stick to this script at the beginning of her deposition, stating: "I last saw Jeffrey
when I was at the end of 16 or the beginning of 17." (see Depo Transcript 70:21-22)
However, M. was not content to leave it that, and in the middle of her deposition,
sought to expand the claimed period of association with EPSTEIN, stating that she
last saw EPSTEIN, "when I was 17 in the December or January area ..
turned
seventeen 6 months prior to that January] that's the last time I saw Jeffrey Epstein.
That's the last time I entered his mansion." (see Depo Transcript 163:4-7)
M. was also emphatic before
that there were absolutely no drugs
involved in the Epstein case:
A: I never did drugs. There were no drugs.
Q: Did you ever when you were either bringing girls or when you were giving
massages, did you ever drink anything or take any drugs, whether it was
prescription drugs?
A: I heard this on the news. No. It's ridiculous.
Q: You never took any drugs?
A: Never. No.
(see page 49, lines 8-20 of Sworn FBI Statement)
However, realizing that she would need an explanation as to why she returned to
EPSTEIN's mansion so man times after she claimed EPSTEIN had sexually abused
her under counsel by
and others at M, M. rewrote the
EPSTEIN tale and included outlandish claims of drug abuse in her deposition
testimony:
A: I
I would start giving me drugs after I saw Jeffrey...
Q: And what did she tell you?
A: Here. This will make you not nervous when you go to Jeffrey's house.
Q: Where there other occasions that she gave you drugs?
A: Yes, after I every time I went to Jeffrey's with her she would give me drugs.
Q: Did you see her on any occasions other than when you were going with
her to Jeffrey's?
A: ...So we hung out a couple of times. We would talk about Jeffrey and how
much money we were making from Jeffrey and that's that.
(see Depo Transcript 96:2 - 97:9)
Ye under persistent questioning from EPSTEIN's counsel in M's deposition, even
M. had to admit, consistent with her previous testimony to the FBI, that EPSTEIN
had no involvement whatsoever with any claimed drug or alcohol usage:
Q: Jeffrey Epstein never gave you any drugs did he?
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A: No.
Q: He was an antidrug person, wasn't he?
A: That's what he said.
Q: And he made that pretty clear to you?
A: Yes.
Q: Never gave you alcohol, right?
A: Never.
Q: Told you he didn't believe in alcohol. Didn't drink it himself, right?
A: True.
Q: Always treated you well when you were at his house, didn't he?
A: Of course.
(see Depo Transcript 305:5-306:1)
A final example of how M's representation by Wand involvement in the
scam compromised
's testimony in the Civil Action can be found in
's characterization of others
brought to the Epstein mansion. In her sworn
statement prior to
described those she brought to EPSTEIN's
mansion as eager for the opportunity and content with their experiences:
A: None of my girls ever had a problem and they'd call me. They'd beg me,
you know, for us to go to Jeffrey's house because they love Jeffrey. Jeffrey is a
respectful man. He really Is. I mean, and he all thought we were of age
always. This is what's so sad about it. (see page 30, line 25 to page 31, line 6
of Sworn FBI Statement).
Q: Did any of the girls complain about what happened after they left there?
A: No. You asked me that question. No, everybody loved Jeffrey. (see page
44, lines 2-7 of Sworn FBI Statement)
•
•
•
A: Every girl that I brought to Jeffre
fhey said they were fine with it. and
like for example
- another of
clients in the Civil Actions], a lot of
girls begged me to bring them back for the money. And as far as I know, we
all had fun there. (see page 45, lines 2-7 of Sworn FBI Statement)
However, after she became ==
client and the Civil Actions were brought to
M, M. flipped her statements 180 degrees. In her deposition in her multi-million
dollar Civil Action, not surprisingly, M. re-characterized the experiences of those
she brought:
A:... Once they were there, they were scared out of their mind. They did it
anyways and some of them walked out and said M. don't ever do this to me
again. That was the worst thing that ever happened to me. (see Depo
Transcript 170:6-11)
A: A lot of girls weren't comfortable. (see Depo Transcript 171:13)
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