EFTA02726436

Pace UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 502008CAO2S05130000.03 AB a Plaintiff. -vs. JEFFREY EPSTEIN. Defendant VOLUME I OF II VIDEO-CONTERD4CED AND VIDEOTAPED MORMON OF I. Tbunnky, September 24,2009 9:40.5:52 p.m Repotted By: Cynthia Hopkins, RPR, FPR Notary Public. State of Florida Prose Coal Reporting 1 Appearances 2 On behalf of 3 ROBERT MARK T. 4 Page 3 rationed: the Defendant, Jeffrey Epstein: D. CRITTON, JR., ESQUIRE LUTHER ESQUIRE i LUTTIER & COLEMAN, LLP fg i i 6 one : 7 On behalf o 8 JACK A 9 10 one 11 12 13 14 15 16 3.7 18 19 WITNESS: 20 21 22 23 24 25 1, Jeffrey Epstein: ALAN GOLDBERGER, ESQUIRE URY GOLDBERGER & WEISS, PA. ALSO PRESENT: Jeffrey Epstein, via video conference Michael Downey, Videographer Visual Evidence, Incorporated IN DEX VOLUME I DIRECT CROSS REDIRECT RECROSS LIMIER 10 1 APPEARANCES: 2 On behalf of for Plainti 3 BRAD J. EDWARDSS,... RoSENFT_:LOr, AM I R 4 6 7 On S beli.z.241tAl: E' . KUVfN, ESQUIRE 9 10 Phone: 11 12 13 14 is 16 17 19 19 20 23. 22 23 24 25 ADAM RE On behalf o ROWITZ. P.A. Fek Page 2 1 2 3 4 5 6 7 a 9 10 11 12 :3 14 15 16 17 18 19 20 21. 22 23 24 25 P ROCEEDINGS Page 4 THE VIDEOGRAPHER: We're on the videotape record. This is the 24th day of MI., the year The time is approximately 9:46 a.m. This is the videotape deposition of ■ in the matter of fl Plaintiff versus Epstein, Defendant. This deposition is being held at. My name is Michael Downey. IM the videographer employed by Visual Evidence. Will the attorneys please announce their appearances for the record. MR. EDWARDS: Brad Edwards representing.. MR. HOROWITZ: Adam Horowitz, counsel for Plaintiffs MR. KUNIN: Spencer Kuvin on behalf of MR. GOLDBERGER: Jack Goldberger on behalf of Jeffrey Epstein. MR. CRITTON: Bob Critton on behalf of Jeffrey Epstein. MR. LUITIER: Mark Luther on behalf of Jeffrey Epstein. MR. EDWARDS: Before we get started, I know 1 (Pages 1 to 4) PROSE COURT REPORTING AGENCY, INC. EFTA02726436 Page 5 1 that we're going to use teal names during this 2 deposition rather than pseudonyms. I just want to 3 make sure that we're all on the same page that when 4 the court reporter types it up, it's going to be 5 typed up in the transcript as the initials like we 6 have in previous depositions. 7 MR. CRITTON: That, that's fine, but keep in 8 mind that we need, because a number of the 9 individuals have multiple first initials and you 10 have used initials that don't even match your 11 clients names. 12 So we're going to have to — Cindy, you're 13 going to need to, ultimately when you finish, if 14 this is agreeable with everyone, I think we did 15 this before is type up a key and then you can give 16 that only to the lawyers and do that as just a 17 privileged or as a confidential document, so that 18 we can insert those 19 MR. EDWARDS: Along those same lines, as this 20 is being videotaped, I imagine in agreement amongst 21 the parties this will remain confidential except in 22 the case that there is a court order that the 23 videotape and her image is made public in any way. 24 So, if it's going to be made public in any way, 25 then, !just ask that it only happen by way of some Page 7 1 anonymity here. And I am not going to agree to 2 that, so — 3 MR. CRITTON: Well, l can tell you I wouldn't 4 put a video on. I would not put a video that would 5 identify this individual, you're client's face. 6 All right. I would do nothing to identify her 7 face. So, her anonymity would be, quote, unquote, 8 preserved if that's your issue. 9 MIL EDWARDS: My issue is only preserving her 10 anonymity. So, I mean, are we in agreement that 13. this is not going to be a video published in a 12 public forum or any way outside of use in a 13 courtroom to be seen by the judge? 14 MR. CRITTON: To the extent her picture or her 15 name would be used, I agree with that. Other than 16 that, just go to the court. And as i said, you can 17 file a motion with the court. if your position is 18 is that the deposition, again assuming there is 19 complete anonymity and her face is blotted out, 20 that the video cannot be filed with the court or 21 used in some other fashion, right, I agree. We're 22 not going to do anything that in any way impacts 23 the anonymity absent an order from Judge Hafele in 24 this particular case. 25 MR. EDWARDS: All right. We're in agreement Page 6 1 court order, either by way of Marra or Judge 2 Hafele. 3 MR. CRITTON: This is only being done in the 4 ■case. And I will tell you what you can do 5 is we won't agree to that because Mr. )(Irvin 6 apparently gave Mr. Epstein's video to Jose 7 Lambiet, which was then immediately put on the 8 Post, and then ended up on, all over the country. 9 And be certainly had no issue associated with 10 confidentiality. So, whatever rules apply. 11 What I will tell you is with regard to the 12 video today, we'll give you whatever time you think 13 is necessary -- well, let's do it this way: Within 14 ten days fiom today you file a motion for 15 protective order in front of Hafele with regard to 16 this deposition, and we'll agree that it will 17 not — we won't touch it. 18 Mil. EDWARDS: I don't see how that's necessary 19 since we already have the Judge's agreed, we have 20 an agreed order that we can proceed anonymously. 21 Judge Hafele, as you know, has been very careful in 22 instructing yourself and everybody else in this 23 case that these individuals are to remain 24 anonymous. And obviously publishing this video in 25 any public forum will decrease or eliminate any Page 8 1 then. Okay. 2 MR- CRITTON: But, but I want to be clear, it 3 is to the extent that if the, you still need to 4 file a motion with the court to the extent that you 5 don't, that it's your position that even if her 6 face was blotted out and even if no names are used, 7 and you think that the video is to remain confidential, then you should file something with 9 the court. And I'll give you, like I said I will 10 give you ten days so you can proceed to file that 11 motion. 12 MR. EDWARDS: Okay. So it's your intention to 13 use Ibis video, blot her face out and then post it 14 somewhere? 15 MR. CRITTON: I have no intentions at all. 16 MR. EDWARDS: Okay. 17 MR. CRITTON: And if you had brought this up 18 in a motion earlier, I would have addressed it at 19 the same time. 20 MR. EDWARDS: I think we're all on the same 21 page that the victims in this case are to remain 22 anonymous. i mean, everybody has been warned 23 repeatedly about using names outside of the 24 pseudonyms and exposing faces, things like that, to 25 the public outside of the court. 2 (Pages 5 to 8) PROSE COURT REPORTING AGENCY, INC. EFTA02726437 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 9 MR. CRITTON: I am aware of the court order. 2 I am also aware that is a public 3 figure now because her lawyers chose to disclose 4 her name. MR. EDWARDS.: Right. And that was her choice. 6 MR. CRi'TON: Everything associated with the 7 her is public. 8 MR. EDWARDS: Right. MR CRITTON: Tm aware of the other court orders in, that are in place and I think, well, I think we have said enough. MR. EDWARDS: Okay. Agreed. MR. LUTTIER: Would you please state your name. THE COURT REPORTER: I need to swear the witness. MR. LUTTIER: Okay. Thereupon, having been first duly sworn or affirmed, was examined and testified as follows: DIRECT EXAMINATION BY MR. LUTTIER: Q. Would you please state your full name, ma'am. A. El. Page 11 1 I don't know. 2 Q. Okay. How many times have you been deposed? 3 A. Once that I know of. 1 4 Q. Am you referring to an incident where you gave a sworn statement to the FBI? Is that what you are 4 6 referring to? 7 A. Yes, sir. 8 Q. That's what you — when you said you were 9 deposed one time, that's the incident that you're 10 referring to? 11 A. Yes, sir. 12 Q. What is ur current address? 13 1 A. 4 15 Q. And is that an apartment? 16 A. Yes, sir. 17 Q. kit in a development? 18 A. Yes, sir. 19 Q. What development is it in? 20 A. 21 Q. And where is that located? 22 A. 23 Q. How Ion have u lived there? 24 A. 25 Q. And does anybody live with you at that address I Page 10 1 Q. What's your middle name? 2 Al 3 Q. (Mr. Luttier spelled her middle name.) 4 A. Yes. S Q. is there. at the end of it? 6 A. No. 7 Q. Okay. n., have you ever been deposed 8 before? 9 A. Yes. 10 Q. When was the last time you were deposed? 11 A. The date was — I don't know when the date 12 was, but it was the last time with Jeffrey Epstein. 13 Q. What do you mean by "with Jeffrey Epstein"? 14 A. i was deposed with Jeffrey Epstein on 15 behalf - I don't know, Jim Eisenberg, the guy who is 16 actually upstairs from here. I don't know the name. 17 Q. Who do what guy is upstairs? Who are you 18 talking about? 19 A. You know the last time I was deposed. 20 Q. I don't know of any, ma'am. I assure you I 21 don't know of any time you have been deposed, so that's 22 what I am trying to find out 23 A. You don't. 24 Q. No. 25 A. Okay. When was the last time i was deposed? Page 12 1 currently? 2 A. My son. 3 Q. And what is your son's name? 4 THE WITNESS: Do I have to say my son's name? 5 MR. EDWARDS: lam, lam going to instruct her 6 not to answer. This is a minor child and she's 7 going to her son out of this litigation. This 8 is a boy. 9 MR. LUTTIER: Is that some basis - 10 THE WITNESS: i don't know why it's relevant 11 to to have my son's name. I have a 12 son. 13 MR. EDWARDS: Yeah, the basis of the objection 14 is that your client is a convicted felon and a sex 15 offender. This is a victim and she is in fear for 16 the safety of her son. And because of that fear, 17 she's not going to provide an ore identifying 18 information about her son. 19 BY MR. LUTTIER: 20 Q. Do you adopt what your lawyer just said? 21 MR. EDWARDS: Don't answer. 22 THE WITNESS: I agree. 23 MR. EDWARDS: Don't answer. 24 BY MR LUTTIER: 25 Q. Do you have some fear for the safety of your fi 3 (Pages 9 to 12) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA02726438 Page 13 1 son? 2 A. Yes, sir. 3 Q. And what is your fear? 4 A. Are you kidding me? What is my fear? 5 Q. I can tell you, ma'am, there is nothing here 6 at all today that I am going to be asking you that's a 7 joke or that I am kidding you about. a A. Okay. 9 Q. Okay. So what is the fear that you have for 10 your son? 11 A. I don't lmow if you have kids — 12 Q. Yeah, I do, ma'am 13 A. All right. Well, then, if you were in this 14 deposition, Lam in fear that this, this criminal, 15 Jeffrey Epstein, could harm him in some way bier on in 16 life like he's harmed me and many other women or girls 17 as that. And I don't want this to be publicity later on 18 in life for him to see what his mother has been through. 19 That's why I am in fear for him. 20 Q. Okay. Can you tell me specifically what it is 21 that you fear, what specific -- 22 A. I just told you. 23 Q. — act that you fear is going to happen to 24 your son? 25 A. Psychological, mental physical matters for my 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 15 Q. All right. So, you have a Somewhere I think I read his name was or something like that. And have you and he lived just the two of you at this apartment since at A. Yes. Q. Has anyone else lived with the two of you at that apartment since A. Yes. Q. Who else has lived there? A. Q. How do you spell that last name? Q. And for what period of time has lived there? A. For seven months now. Q. Is he living there now? A. Yes. Q. And is there some relationship between and yourself? A. Yes. Q. What is that relationship? A. He is my current boyfriend. Q. And what is occupation? A. He is —he does Q. Does he week for someone or is he Page 14 1 son. 2 Q. Can I, can I assume that you would take 3 whatever steps you deem necessary to protect your son 4 any time you felt that he was in any kind of danger? 5 A. Yes, sir. 6 Q. And could I assume that historically, that is 7 throughout his life as long as he has been bom, you 8 have always done anything you could to protect him from 9 any situation where he was put in danger; is that right? 10 A. Yes, sir. 11 Q. And if somebody puts your son in danger, you 12 know how to file a lawsuit against them and protect them 13 and things like that, right? 14 A. Yes, sir, but I don't want to get to that 15 point. mat's why I am not going to disclose his name. 16 Q. Well, you have filed this lawsuit, right? 17 A. For mY, for my sake, yes. 18 Q. And you would file a lawsuit to protect your 19 son if that's what you had to do, would you not? 20 A. Yes, i would. 21 Q. Would it be a fair statement to say that your 22 son is the most important thing to you in your life? 23 A. Yes. 24 Q. Okay. 25 A. Yes, yes, yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 16 self-employed? A. He works for Q. Has anyone else ever lived with you and your son since MINIM) A. No, sir. Q. Prior to, that is immediately before you moved into the where did you live? A. On Q. What was the address? A. Prom what I recall El Min Q. And whereabouts is that located in IMIE) A. On Q. What kind of structure was that? A. A townhouse. Q. And how long did you live there? A. I lived there for about seven months. I'm not really sure on that. Q Okay. Since approximately somewhere around A. I'm, I'm really not sure. Maybe — you know what, it was mo llig. n. Q. Okay. And something, it sounds like something that you were able to refer to that triggered your NEMAIrIO Niada. 10.0W9MV •thik.••••• ••••HA 4 (Pages 13 to 16) PROSE COURT REPORTING AGENCY, INC. EFTA02726439 1 2 3 4 5 6 7 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 17 memory as to when that was? A Yes. Q. What was, what incident that triggered your mano ab ten that was? A. Q. ? A. Yes. Q. How do you know the -- was there something that trigg that you recalled about that day? A. Yes, because I t ved in before and I had to get th up. Q. Did anyone --I your son lived with you when you were ? A. Always. . ' one else live with you while you were a m A. No, sir. Q. Are you currently employed? A. No, sir. Q. What are your -- what is your current means of support? A. I have a loan from school. Q. And wh ilia A. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 19 A. I have to take the exam in order for me to get the certificate to be licensed. alliiMISONS being something separate that you have to go through? grili tor me to get licensed to be a , I have to take something called the , I think it's called. And after I pass the test, then I will receive my license. studies a Q. A. Q. started? A. Yes. Q. Had you ever attended that institution before? A. Yes. Q. When had you previously attended that institutaia Q. Do you recall when? A. No, sir. Q. Was it located at the same location when You — 1 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 Page 18 Q. An wh A. Q. And are you pursuing some course of study there? A. Yes. Q. Skis of study are you pursuing? A. Q. Is that an institution where you obtain a degree upon completion of your studies? A I can be Q. When you complete your studies there, what will you get to signify that you have completed that course of study? would be A. I wool to and I Q. So, would you get a certificate? A. Yes. Q. And that after you get your certificate, you're required to take some kind of exam? A. Yes. Q. Or do you have to take the exam to get the certificate? 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 20 A. Yes, sir. Q. — attended there previously? And for what purpose had you pre: 5,1ot ...r e a lic Q. was that? long you attended it is was A. Yes, sir. Q. And then upon completion of that course of rote then take a test and get a license as an A. Yes. Q. And about when did you get your lice A. I am pretty sure it was the beginning Si And that licensure was issued by the A. Yes. Q. Did you your license after you got it in the beginning of II? A. Yes. Q. How did yomili mi A. I worked at Q. What's the name of that? 5 (Pages 17 to 20) PROSE COURT REPORTING AGENCY, INC. EFTA02726440 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Mt. Q. How do u spell that? A. Q. A. Ycs. Q. And where is that located? A. That is located (Ms. Ezell entered the deposition.) BY MR. LIMITER: Q. Is that in like a strip mall center? A. Yes. Q. And what did A. I was Q. What • A. Fad Q And what did A. I perfonna . And and basicall A. No sir. do does that kind of thin Page 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 23 at a MR. EDWARDS: Object to the form. THE WITNESS: No. Fm not sure. MR. LUTTIER: Okay. ar WITNESS: Maybe a couple months before I'm not sure. There is record on my have pay stubs. I don't know. BY Mit. Q. Okay. How did you get that job? A. I filled out a resume and I walked into the place and I asked for a job. Q. And do you have a copy of your resume? A Yes. Not with me. Q. Did you know anyone at that place of business? A. No. Q Was that the only place of business that you submitted your resume to? A. No, sir. Q. Who else did submi A. To a couple.. aroun Q. Did you interview for the job? e other jobs. I interviewed for attd they took mc in. Q. Do you recall who you interviewed with? A No, sir. Page 22 1 i i ind for what period of time did you work at 2 3 A. That's when the economy kind of went down, so 4 I didn't work there for a long period of time because 5 they were allowing me so many hours. I want to say 6 three months. 7 Q. And that, would that be starting in the 8 beginning a, like ? 9 A. I don't want to say because I'm not positively 10 sure. 11 Q. So, let me ask you this: Is that your best 12 estimate? 13 THE WITNESS: Okay. Bless you. 14 MR. EDWARDS: Excuse me. Excuse me. 15 THE WITNESS: Sometime maybe after... 16 MR. LUTTIER: Of I? 17 THE WITNESS: But like I said, Fm not sure. 18 BY MR. LLTTTIER: 19 Q. That's after of 20 A. Yes, sir. I am not exactly sure. 21 Q. Okay. I understand it's your estimate and 22 your best estimate is you worked there for approximately 23 three months? 24 A. Yes, sir. 25 Q. Which would take you from to about.. Page 24 1 Q. Did you know anyone a before 2 you went to work there? 3 MR. EDWARDS: Object to the fonn. 4 THE WITNESS: I told you, no, sir. 5 BY MR. LUTITER: 6 Q. Did you know anyone else that had ever 7 worked - 8 A. No, sir. 9 Q. - there? And what were the terms of your 10 employment? 11 A. I worked, sometimes I would work four hours 12 from 9 to — sometimes I would work from well, 9 to 1 13 three days a week, and other I was pretty 14 much on call because they just had opened and 15 the economy was going down at that time, and she 16 couldn't really afford to have me there as much as I 17 wanted to be there. 18 Q. Who is the "she" you're referring to? 19 A. I don't remember her name. 20 Q. Was it the owner? 21 A. Yes. 22 Q. And you don't -- do you recall the name of who 23 your supervisor was or the person that you reported to? 24 A. No, sir. 25 Q. Do you recall the name of anyone at 6 (Pages 21 to 24) PROSE COURT REPORTING AGENCY, INC. EFTA02726441 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 25 a st was employed there or an owner there? A. No, sir. I didn't et close to anyone there. I just, I was the only Q. How many other employees were there? A. There was actually only three other employees. Q. Do you know the names of the other employees? A. No, sir. . What other services were rendered at Milli A. Q. Anything A. No, sir. HMI Q. And what were the terms of your employment in terms of what you got paid? A. 'think she started me off at -- here again am not sure. I think she started me off around ■ maybe. Q. Per hour? A. Yes. And then gradually I would work by commission but not many people came in. So, all in all it didn't really work out financially for myself and my family. Q. Did there come a time that she increased the hourly wage — Page 27 1 A. Yes, sir, but that never ended up, that never 2 went through. 3 Q. So there did come a time that the basis of 4 your, the terms of your employment in terns of how you 5 got paid changed? 6 A. I'm going to say no because she said that I 7 was going to make commission. No one came in. Okay. 8 So I didn't make any commission. 9 Q. So she continued to pay you hourly? 10 A. Yes, sir. 11 Q. Were you supposed to get commissions on top of 12 your hourly wages? 13 A. If I worked there longer, yes, but no. 14 Q. And you still don't know the name of this 15 person that you have referred to as "she"? 16 A. No, sir, l don't 'mow the name of anyone 17 there. 18 Q. Okay. Did you participate in any type of 19 promotion for the business? 20 A. No, sir. 21 Q. Any kind of advertisement or anything like 22 that? 23 A. No, sir. 24 Q. Was your name or likeness, picture or likeness 25 used in any ldnd of promotions? Page 26 1 A. No, sir. 2 Q. — that you were being paid? 3 A. No, sir. 4 Q. Did there — when you originally were hired, 5 were you hired on an hourly basis? 6 A. Yes, sir. 7 Q. Did there cons a time that the basis of your 8 employment or your pay changed? 9 A. No, sir. 10 Q. So, you were always paid hourly by the owner 11 of the establishment? 12 A. Yes. 13 Q. Did you receive any other compensation from 14 anyone else while you were working there? For example, 15 did people or clients of yours that you did work on give 16 you tips? 17 A. No, sir. 18 Q. You mentioned something in an earlier answer 19 about being on a corrmission basis. What did you mean by 20 that? 21 A. As time went on she said you can work off of 22 commission, but no one came in. I didn't make a 23 commission. 24 Q. Did you agree to change the terms of your 25 employment from hourly to commission basis? Page 28 1 A. No, sir. 2 Q. Were you given any information from the owner 3 of this .as to how to solicit clients? 4 A. No, sir. 5 . When u other th r a at the 6 starting in 7 ' had you attended that institution on any B prior occasion before that? 9 A. No sir. 10 Q. So the first lime you wart 11 there? 12 MR. EDWARDS: Object to the form? 13 BY MR. LUTTiER: 14 Q. Correct? Was t ' 15 you went to the 16 MR. EDWARDS: Object to the form. 17 THE WITNESS: What does this mean? 18 MR. EDWARDS: You can answer if you know the 19 answer. If you don't know the answer -- 20 THE WITNESS: Fr I went 21 there. I attended the two 22 times. 23 MR. LUTHER: Okay. 24 THE WITNESS: Okay. One in l and one right 25 now. 7 (Pages 25 to 28 PROSE COURT REPORTING AGENCY, INC. EFTA02726442 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 29 BY MR. LUTTIER: . How did ou become familiar with or know about the A. Maybe the Yellow Pages. Some source of information on the Internet. Q. Do you recall which it was? Was it the Yellow Pages or was it the Internet? A. Yellow pages dot corn, MEM. Q. That's how you found it? A. Yes, sir. Q. And are you a person that considers yourself to be computer proficient? A. No, sir. Q. iE nsu use the computer on a regular basis? A. I have been. Q. What do you mean by "Mr A I have been selling a couple of items Q. What kind of items? A. Items around the house like dresses, shoes, items that i have. • Are, are you selling items as a for A. LI in them in I never pursued it. So, as of right now I am taking the products that I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 31 Q. You don't know your friend's last name? A. No, I don't know my friend's last name. Q. And you don't know last name? A. No. Q. How long did you know this friend a A. I knew ha from the neighborhood I used to live in what I was ten years old. I met ha when I was ten years old and that I bumped into her at a store. We exchanged phone numbers. She introduced me to III an I started Q. And although you knew this person since you said you were Mold, you can't recall her last name; is that right? A. That's right. Q. Is there — by the way, do, do you have any problem with your memory that you're aware of/ A. Yes. Q. What is your problem with your memory? A. With a lot of negative situations, I tend to not really, I don't really care to ri..ux.iikgsi than. just live every day as it oomes as positive as I can. I try to exclude any negativity. And when it comes to negativity, I choose, I guess I choose not to remember it. Q. Is there a difference between attanpting to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 3.6 17 18 19 20 21 22 23 24 25 Page 30 do have and I am selling them. Q. Okay. When you say that you with in what do you mean? A. I paid worth of so I could profit. Q. Turn around and sell it for a profit? A. Yes, sir. Q. Did you execute some paperwork to become a for lack of a better term with IMMI A. Yes, sir. Q. Did you deal with someone that was affiliated with when you first began to do that? A. Yes, sir. Q. And who was that? A. Q. Did you say A. Q. A. Yes, sir. I don't know her last name. Q. And how did you get in touch with her? A. Through a friend. Q. And who was the friend? A. Q. what? A. I don't know. Page 32 1 block out some negative thing and not being able to 2 remember the negative thing? 3 A. Okay. 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: 1, I do choose to block out. I 6 remember but I do choose to block out. 7 BY MR. LUTHER: 8 Q. So, you would say you're a positive type 9 person? 10 A. Yes, sir. 13. Q. You believe in positive thinking as opposed to 12 negative thinking? 13 A. Yes, sir. 14 Q. You put behind you those things that you don't 15 think were positive for you and you choose to 16 concentrate on those things that are positive? 17 A. Choose to concentrate on positive things. 18 Q. Are you a person that you would say is a 19 forward-looking person; that is a person that looks to 20 the future as opposed to the past? 21 A. I look to the, I looked to the, I look to the 22 future, but the past does haunt me. 23 Q. Okay. Now, you mention that although you try 24 to block these things that you do remember them. So, I 25 want to go back and ask you if you remember last name of 8 (Pages 29 to 32) PROSE COURT REPORTING AGENCY, INC. EFTA02726443 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 33 A. No, sir. When I was ten, I really didn't care to know anybody's last name. Q. Well, you said you first met her when you were ten, right? A. Yeah. She was an acquaintance. Q. And so how long did you know her, from ten until now? A. No, l knew of her, but she was a girl in my neighborhood that we just saw once in a while. And then as we got older, I don't know where she was. But I bas d into her at a store. And Fm like, hey, aren't you from the neighborhood. Oh, you have a kid; cool, I have a kid too. Let me get your number. Let me see how you're doing in life. I don't know her last name. Q. Okay. But in any event, she's the one that introduced you to the concept of MR. EDWARDS: Object to the form. MR. LUTTIER: Right? THE WITNESS: Yes. BY MR. LUTTIER: Q. Was she a person who that was selling NM A. Yes. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 35 A. I don't know. Q. Was it your practice to keep important legal papers that you sign? MR. EDWARDS: Object to the form. THE WITNESS: Yes. That wasn't very important to me. BY MR. LUTHER: Q. What sort of important legal documents do you keep? Or excuse me, what sort of important document do you keep? A. Keep my tax returns. I keep my sonall. I keep all of my son's records. I keep my Social Security card. 1 keep money orders that when I pay the bills. Q. Anything else that you can think of? A. No, sir. mil fter you had this happenstance meeting with iAdid you ever have any other communication with heir A. We had a co we had actually one together, and we had attended together one time. Q. Did you ever actually sell an product that you had purchased for A. Yes. °dings. Well, at my house 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 34 Q. Did she have some kind of franchievsitIttltem? A. lam pretty sure. She worked for She introduced me to -signed me up. Q. When you say signed you up, wit:1.1)cm? A. I filled out paperwork to hand ov . And did — was part of the arrangement that =would receive some sort of compensation or a portion of your sales? A. Not that I know of. Who knows? I don't know. It was just an opportunity that I went for and found out that it wasn't for me. Q. Did you read the document that you signed? A. I didn't read up to the point where it said that she was going to get profit. I didn't really care if she got a profit. If she did, good. Q. The question was, did you read the document that you signed? A. Pan of it. Q. And what part did you read? A. That I will be spending `so I can Q. Do you have a copy of the document? A. No, sir. Q. What happened to the document? Page 36 1 Q. And during what period of time did you 2 actually sell product? 3 A. When I first started, and I would just keep 4 the products in my trunk And if I was out on the 5 street at a gas station or going to the grocery store, 6 wherever a ls lisk a woman if they would like 7 some And if they did, l proceeded to 8 sell them to that woman. 9 Q. Did you have — was that your sole source of 10 support at the time? 11 A. No, sir. 12 Q. What other source of support did you have? 13 A. At what period of time? 14 Q. You what? 15 A. At what period of lime? 16 Q. aWarigiSf time while you v 17 Lag MIME= which mislaid yoiebill in 18 M. And do you recall when in IM approximately? 19 A. That was my, not my only source of ham no. 20 Approximately when did you initially MINI in 21 22 A. I couldn't tell you. 23 Q. Roughly. 24 MR. EDWARDS: Object to the form. 25 MR. LITTLER; lam not owing you to a specific team PROSE COURT REPORTING AGENCY, INC. 9 (Pages 33 to 36) EFTA02726444 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 Page 37 date. Within two months. MR. EDWARDS: Object to the form. If you know, answer; if you don't know, you don't know. MR. LUTTiER: You can't recall? THE WITNESS: i can't recall. BY MR. LUTTIER: Q. Okay. And for how long did you sell these products? A. Sr, I took the products. They weren't my full source of income. I sold them whenever I sold them. When i was at a gas station, maybe I would.. When I was at the grocery store, I might It wasn't my full source of income. It was just a little gas change. Q. Okay. And at some point you stopped attempting to sell the product and decided to try to sell them ovellIk A. Yes. Q. What, what other source of income did you have while you were trying to se A. i was workisja in and out o Q. In the yea — and you have testified earlier that, I think u said about is when you first went to, to this -- did you have any source of support, financial support? Page 39 1 reside with him? 2 A. Around five months. 3 Q. Okay. But from what date to what date? 4 A. I told you. You can do the math. I turned, I 5 was 18. 6 Q. When were you 18? 7 A. Excuse me? 8 MR. EDWARDS: Object to the form. 9 BY MR. LUTHER: 10 Q. When were you 18? 11 MR. EDWARDS: Object to the form. 12 THE WITNESS: I am 21 now. 13 BY MR. LUTTIER: 14 Q. My question is when were you 18? 15 A. When was I 18? 16 Q. Yeah. 17 A. Can you give me a piece of paper and a 18 pencil - 19 Q. Sure. 20 A. — so I can find out -- 21 Q. No problem. 22 A. — when in the hell I was 18? How about if 23 you do the math? 24 Q. There you go, ma'am. 25 A. Can you do the math? Is it — Page 38 1 A. Yes, yes. 2 li t What were your sources of financial support in 3 4 A. I had a boyfriend that supported me, my son 5 and I. 6 Q. And what what was that boyfriend's name? 7 A. 8 Q. 9 A. 10 Q. And did he provide the sole support for your 11 and son, you and your son? 12 A. Yes, he did. 13 Q. Did he live with you at some point in time? 14 A. I lived with him at some point in time. 15 Q. And when was that? 16 A. That was in — I just turned —1 was 18 when 17 lgot with him, and I just named 19. And we were 18 together for, we lived together for around five months. 19 Q. What did you mean when you said you got with 20 him when you were 18? 21 A. We started dating when I was IS. I moved in 22 his house when I was i8 and then I turned 19. I 23 remember having my 19th birthday. We lived together for 24 around five months. 25 Q. So what, what period of time then did you 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 40 MR. EDWARDS: Object to the form. She will give her date of birth, and it's a, ifs a factual issue as to when she turned 18. BY MR. LUTTIER: Q. You don't — so, are you telling us here in this deposition you don't know when you turned 18? A. Sr, i was 18 when i met the man and i turned 19. Q. And what's the date of your 18th birthday? A. i don't know of what year. Q. You don't know what year you turned 18? A. No, sir. Q. When were you born? A. IL Q. A. Yes. Q. Okay. A. I am not so wonderful with math if that's what you're asking. Q. So, when you turned 18, which if your numbers are correct and if m math is correct, that's going to put it a A. Okay. Q. So, you moved in with him in And 10 (Pages 37 to 40) PROSE COURT REPORTING AGENCY, INC. EFTA02726445 Page 41 1 you said that you were with him when you turned, that is 2 'living with him, when you turned 19? 3 A. Yes. 4 So that means you were living with hint US 5 6 A. i. 7 Q. Yes? S A. Yes. 9 Q. And then when did you move out from him? 10 A. Okay. Actually ] got with him in... 11 Q. Of what year? 12 A. 1 was 18. 13 Q. We established that was 14 A. Okay. s Q. So if it was-, that would make in. 16 right? 17 A. I was 18 when I got with him. That was in 18 IE. I don't know what year. I am not that good with 19 math. Fm sorry. 20 Q. Well, if you were, which 21 you've agreed you were, right? 22 A. Yes. 23 Q. And, and if you moved in with him in.' of 24 the year when were 18, the on,. that could be 25 would b isn't that right? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 43 A. Imoved, I moved with my, I stayed with my ji lt father for a cou le of weeks. Then I moved into the, the address o . Q . ? A. Yes. Q. Okay. And where does your dad or where did your dad live at that time? A. NIL Q. And did you move in with your dad for approximatel a two-month period between o.? of f I A. I moved in with him Q. Okay. Ofd? A. I.And then 1 moved into the on Q. And did your son move in with your dad with you? A. My son has always been with me since he was bom. Q. Has there ever been any kind of judicial proceeding or administrative proceeding brought to change where your son lives? In other words, have you ever — do you know who.. is? A. Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 42 A. Sure. Q. Okay. A. If that's correct. Q. So, it's your recollection as you sit here today that you moved in with this entleman in'. of II or that you started dating ii A. We started dating and I moved in with him about two, a month later. Q. Okay. And you lived with him for approximately five months? A. Yes. So that, that means you moved out in around A Q. i mean of I'm sorry. Right? A. I moved out when I moved into the 7 — or when 'moved into the which was or which wastzah, Q. Of.? A. Yes. Q. All right. So, that correst believe the date that you moved out was of not of M; is that right? A. 1 moved out sometime in Q. Did you live anyplace — 9 1. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 44 Q. Has there ever been any kind ollilliproceeding that you have been involved? A. Unfortunately, yes. Q. Were you involved in that proceeding; that is was the proceeding were you a party in that proceeding? A. i went through a with a previous boyfriend. Q. Okay. A. And that's how co got involved. Q. Was there a formal investigation? A. Yes. Q. And do you remember what year that was? A. '06. Q. Okay. Now, I had asked you re Wous whether you had any source of support from all forward. And told me — A. Q. — that you lived with this boyfriend. But now you have described the time that you have lived with this boyfriend and telling me that you moved out with him in lIMIE of So apparently he wasn't providing support to you in A. No. Q. Did he -- he didn't provide you support after 11 (Pages 41 to 44) PROSE COURT REPORTING AGENCY, INC. EFTA02726446 Page 45 1 you quit living with him, did he? 2 A. Correct. 3 Q. Oka . All ri ht. So let's go back tot 4 Startin 5 A. Okay. 6 Q. What means of support did you have ill.? 7 A. I worked at — 8 MR. LUTTIER: What, I mean — 9 MR. CRITTON: He can't do that. 10 MR. LUTI1ER: Whoa, whoa, whoa. I don't think 11 you can sit ova and start conferring with your 12 client when i am taking her deposition. 13 MR. EDWARDS: Okay. 14 MR LUTT1ER: I mean, if you've got a -- if 15 it's an attorney-client privilege issue — 16 MR. EDWARDS: That's why I was asking. It 17 doesn't appear there is. You can ask your 18 question. 19 MR. LUTHER: Okay. What - 20 THE WITNESS: I worked -- 21 MR. EDWARDS: The question is what she was 22 doing to make money? 23 BY MR. LUTPTER: 24 Q. What forms of su rt did you have or means of 25 support did you have in=? 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 47 1 MR. EDWARDS: Don't answer. If we're going to 2 get into specific sexual issues, this is up on 3 appeal. Fourth District Court of Appeal just 4 issued a Rule to Show Cause directed towards 5 Mr. Epstein. Until that issue is resolved, she's 6 not going to answer specific sexual issues. She's 7 admitted to being a call girl. She will continue 8 to do so. 9 She's not going answer the names of the places where she did it or any Joint's as we feel that issue has not been covered. And until that is resolved, we're instructing our client not to answer. Additionally on those questions, we are invoking her Fifth Amendarraright to remain silent, tight of privacy as toe., as well as the right of privacy of third-parry individuals. MR. LUTTIER: Okay. Let me, just so we have a clear record, I am going break those questions down and then you can -- MR. EDWARDS: Sure. MR. LIMIER: — assert your objection. BY MR. LUTT1ER: referred to l Q. You said that you worked inet are the names of the, what you where you worked? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I worked in Q. What Rind ofd? A. Page 46 Icindba m What do you mean kinds of A. I worked as an escort. Q. What do you mean by escort? A. Wow, I worked as a call girl. I worked as an escort. Do you not know what an escort is? Q. Ma'am, I want to make sure we don't have a definitional problem. So now you have said you worked as a call girl and as an escort; is that correct? A. Yes. It's the same thing. MR. EDWARDS: Object to the form. BY MR. LIMIER: Q. So, in your, in teens of this deposition, if you refer to a call girl or an escort, those things mean the same thing in your mind, correct? A. It means the same thing in everybody's mind. Q. Okay. Well, tell me what you did as a call girl, escort inl.? A. I performed sexual, sexual things for men for money. Q. And what sort of sexual things did you perform for men for money ina? Page 48 1 MR. EDWARDS: Same objection. Don't answer. 2 MR. LUTI7ER: What, what specifically is the 3 objection to that? 4 MR. EDWARDS: The objection is that this issue 5 is up on appeal. And the Fourth District Court of 6 Appeal has issued a Rule to Show Cause Order 7 directed towards Mr. Epstein. Until that issue is 8 resolved, we're not answering that questis.The 9 basis of that issue is the privacy rights °FM., 10 the privacy ripaof third parties as well as the 11 invocation ofa.'s Fifth Amendment tight to 12 remain silent on this issue. 13 MR. CRITTON: Just so, and again let me just 14 insert here so the record is clear: You, in 15 essence, took up an issue associated with interrog, 16 a portion of interrogatory 19 where you chose to 17 answer certain portions and not to answer other 18 portions. Portion dealt with, in essence, prior 19 time. And I will put it out if necessary. 20 The court has not issued, Judge Hafele didn't 21 preclude any type of questioning with regard to 22 income-related issues associated with where she 23 worked, what she did, how she made her money, bow 24 much income she did make. 25 You have a claim for loss of canting, loss of 12 (Pages 45 to 48) PROSE COURT REPORTING AGENCY, INC. EFTA02726447 Page 49 1 earning capacity here. None of that went up on 2 appeal nor did you object to that. You dealt 3 specifically with some aspects of prior sexual 4 history. 5 So I beg to differ. That's not part of what 6 the upcoming appeal is under the circumstances. 7 And I think it's inappropriate. Well, well let the judge decide what is appropriate or not under 9 the circumstance. 10 MR EDWARDS: She will testify to what money 11 she made, just not the names of the places and the 12 Johns. That's it. So I understand that we have a 13 disagreement. That's my position. 14 MR. GOLDBERGER: I need to clarify one thing. 15 Jack Goldberger on behalf of Mr Epstein. 16 You have raised three objections to that 17 question: Privacy, the issue that's on appeal and 18 the Fifth Amendment. Should your objections be 19 overruled on the right of privacy and on the issue 20 that's on appeal in the Fourth DCA, do you still 21 intend to invoke the Fifth Amendment privileges on 22 behalf of your client? 23 MR. EDWARDS: I'm sorry, what was the last 24 part? 25 MR. GOLDBERGER: Yes. Should your objections Page 511 1 BY MR. LUM. E:. 2 Q. Une? You said since, but did 3 you mean until? 4 A I stopped. Until 5 Q. Okay. Is there a specific event that you can 6 recall as marking the point in time that you quit being 7 a prostitute? 8 A. Specific event? 9 Q. Yes 10 A. 11 Q. And what is it that you can recall that allows 12 you to state that that was the date in which you quit 13 being a prostitute? 14 A. I ant sick of the lifestyle. That's what I can 15 recall. 16 Q. So, it wasn't a ecific event It was a 17 decision by you on that you no longer 18 wished to be a prostitute; is that correct? 19 A. Correct. 20 Q. And during the period from • to 21 ill of II, was there anything that prevented you from 22 making the decision at any time during that period that 23 you wished to quit being a prostitute? 24 A. i don't understand what you arc a in I me. 25 Q. Was there anything between and 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 50 be overruled, overruled on privacy issues and on the issues that are before the Fourth District Cowl of Appeal as to this question, you still intend to invoke Fifth Amendment privileges on behalf of your client? MR. EDWARDS: I do. And under that point we would concede that you are entitled to whatever adverse inferences that you believe you are entitled to under the case law. MR. LUTTIER: In 2000- MR. CRITTON: Or, or, let me just -- or whatever other relief is appropriate under the circumstances. MR. EDWARDS: Of course. Whatever the judge decides. BY MR. LUITIER: Q. MIN were you working as a prostitute? A. Yes. Q. Have you ever worked — or for what period of time in did you work as a prostitute? A. What period of time? Q. Yes. From al until when? A. Until, well, - since of I. MR. CRITTON: I'm sorry? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 52 of that prevented you from quitting being a prostitute? A. Didn't you just ask me the question, sir? Q. No. Well, yeah, you said you didn't understand it, so I asked it again. A. i said I was sick of the lifestyle.. Q. From. toll of. is there anything that prevented you from stopping being a prostitute at any time during that od? A. Well, I've beat seein and kind of realized that this life isn't for me. Can I have a tissue? Q. You were seeing ralMil between — MR. EDWARDS: Let me just grab the witness a tissue. MR. LUTHER: I am going to take a bathroom brealc. MR- EDWARDS: Okay. THE VIDEOGRAPHER: Arc we going off the MR. EDWARDS: Sure. THE VIDEOGRAPHER: Going off the record. The time is 10:41 am. (A brief recess was held.) THE VIDEOGRAPHER: We're back on the video 13 (Pages 49 to 52 PROSE COURT REPORTING AGENCY, INC. EFTA02726448 Page 53 record. The time is approximately 10:52 a.m. 2 MR. EDWARDS: Okay. We had an issue come up 3 where everybody that represents Mr. Epstein decided 4 to chime in on a certain issue. And I know that 5 that was an isolated incident. I am assuming that 6 everybody realizes, you know, the rules here and 7 you have chosen your examiner, and that's going to 8 be the person speaking for Mr. Epstein, or on his 9 behalf for the reminder of the deposition. We're 10 not going to get double or tripled teamed. 11 MR. CRITTON: I get -- let me speak to that. 12 MR. EDWARDS: Okay. 13 MR. CRIITON: You have got five lawyers, five 14 to seven lawyers here on Plaintiffs on every 15 deposition that i have attended- I have had five 16 separate Plaintiff groups that all chime in on, on 17 everything. We arc not impacted in the deposition 18 with your client at all, i.e., we're not chiming in 19 to question her at all. 20 What we are is Mr. Goldberger has certain 21 information that I am unaware of, so he deals, 22 dealt only with the objection. It was a 23 lawyer-to-lawyer issue. There are certain 24 information that I have that Mr. Luttier does not 25 have. So that's again a lawyer-to-lawyer issue Page 55 1 Q. And that would be when? What date? 2 A. 2002. 3 Q. And that's when you first became sick of what 4 you have described as the lifestyle? 5 A. Yes. 6 Q. How long have you been a prostitute? 7 A Well, ever since I was lured into Jeffrey's 8 house. 9 Q. Which is when? 10 A. 2002 when i was 13. 11 MR. GOLDBERGER: Can we just stop for a 12 second? We're having a technical issue upstairs. 13 Apparently we're, we're mooted. Can we do 14 something about that? Thanks. I appreciate it. 15 MR. LUITIER: Okay. What was the last 16 question? I mean, what was the last answer? 17 (The requested portion of the record was read 18 by the reporter.) 19 BY MR. LUTHER: 20 Q correct, you said were you 21 born 22 MR. EDWARD$: Object to the form 23 MR. LUTT1ER: And i haven't asked a question 24 yet. 25 MR. EDWARDS: Well, that's not what the Page 54 1 only on the record. It does not deal with — only 2 one lawyer is going to be asking questions. Only 3 one lawyer will do any objections or comments with 4 regard to III MR. EDWARDS: Okay. 6 BY MR. LUrlIER: 7 Q. the question I had asked you before we 8 took the break was whether there was anything that 9 prevented you from t • empluaent vat 10 prostitute between and ME of 11 A. i was sick of the lifestyle. 12 Q. Okay. And when did you become, to use your 13 words, sick of the lifestyle? 14 A. I never liked the lifestyle but you can only 15 endure so much pain for so long. 16 Q. And what you say pain, are you referring to 17 physical pain or are you referring to mental pain? 18 A. Both. 19 Q. And when did you first become, to use your 20 words, sick of the lifestyle? 21 A. Since I met Jeffrey. 22 Q. Which is when? 23 A. When' was 13 years old. 24 Q. Thirteen now. Is that what you said? 25 A. Yes, 13. Page 56 1 witness said. That's not the date of her birth, 2 That's not the answer she gave. So, i am just 3 correcting you to help you out. 4 BY MR. LUMER: 5 Q. Okay. What, what you did say your date of 6 birth wilaa'ag? 7 A. ISM - MR. LUCITE! 't read my handwriting. 9 Stand corrected. Ma Thank you counselor. to BY NINA' 11 Q. So accorgwase 12 calculations, if my math is right, EMI of 2001 is 13 when you would have turned 13, correct? 14 A. If that's, if that's right. 15 Q. And it was sometime in 2002 that you recall 16 that you first met Jeffrey? 17 A. Yes. 18 Q. Now, prior to the first time you met Jeffrey, 19 had you been a prostitute? 20 A. No. 21 Q. Did you do anything prior to the first time 22 you met Jeffrey with respect to receiving money or 23 anything of value in return for any type of sexual 24 favor? 25 A. No. J 14 (Pages 53 to 56) PROSE COURT REPORTING AGENCY, INC. EFTA02726449 Page 57 1 . Durin this period from toll, or 2 until. , when you were acting 3 as an escort and you were doing sexual things for men 4 for money, what types of acts did you perform on men? 5 MR. EDWARDS: Don't answer. This deals with 6 Interrogatory No. 19. This is part of the 7 appellate issue, instructing the client therefore 8 not to answer this question until it's resolved by 9 the Fourth District Court of Appeal as to whether 10 she has to answer on specific sexual acts So, 11 she's not going to answer today. 12 MR. LUTI1ER: Is that the sole basis of that 13 objection or are you also incorporating your 14 objection on the Fifth Amendment? 15 MR. EDWARDS: I am incorporating into that 16 objection the Fifth Amendment argument as well as 17 her right of privacy and the privacy rights of 18 third parties. 19 BY MR. LUITIER: 20 Q. How much money did you earn in.. as a 21 prostitute? 22 A. I couldn't count. A lot. 23 Q. What do you mean by "a lot"? 24 A. Do you want me to tell you how much moneyl 25 made in that whole year? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 59 self-contractor. I don't know how long that sexual need would need to be done. Sometimes it takes two minutes. Q. Well, l mean did you work days, did you work nights. Did you work both? That's what I am trying to get A. Both. Q. Would you typically work at night? A. No. So, you were worldng during the day primarily? A. Yes. Q. As an escort? A. Yeah. Q. And did you keep any record of your earnings? A. I have in the past. Q. During what period? A. Q. h.. 2And what record did you keep of your earnings in A. A day-to-day record. Q. What? A. A day-to-day, daily record. Q. Okay. Like a journal? A. Yes. Q. And what would you — was this a book that you kept? Page 58 1 Q. Yeah. I mean, I don't expect 2 A. Not possible. 3 Q. — you to know the exact dime, to the dime 4 but approximately how much did you make in IS? 5 MR. EDWARDS: Object to the form. 6 If you know. 7 THE WITNESS: I don't know. BY MR. LUTTLER: 9 Q. What did you mean when you said a lot? 10 A. I would make sometimes a thousand dollars a 11 day; sometimes $2,000 a day; sometimes $300 a day; 12 sometimes $400 a day-, maybe $500 a day; maybe $600 a 13 day. 14 Q. And, and so what was -- when you said you made 15 a lot in., what did you mean? 16 MR. EDWARDS: Same objection. 17 THE WITNESS: Sir, I don't know. Like I told 18 you, I made $200 a day once; 2, $300 a day; $400 a 19 day; one grand maybe one day; maybe two grand the 20 next day. I don't know. 21 BY MR. LUTT1ER: 22 Q. And how were you paid? 23 A. Cash. 24 Q. Did you have hours that you worked in 25 A. Did I have hours than worked? I was my own 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 60 A. Yes. Q Is it like a — describe the boot( Is it a diary or something like that? A. Yes. Q. Okay. And do you still have this diary? A. Yes. Q. Okay. What do you call this diary? A. A book. Q. Is it -- does it have a name on it? A. No. Q. Describe the book A. It's red. Q. It's got -- are them pages in it? A. Actually it has a Bible verse on it. Q. Are there pages in it? A. Yes, there's pages in it. Q. Are the pages blank? MR. EDWARDS: Object to the form. Don't answer. Invoking her Fifth Amendment right to remain silent as to what is in this book. BY MR. LUTTIER: Q. My question is are the pages blank? In other words arc they pages of blank paper or are they lined pages? A. The are lined. 15 (Pages 57 to 60) PROSE COURT REPORTING AGENCY, INC. EFTA02726450 Page 61 1 Q. Is it — does it have a name on it lac diary 2 on it? 3 A. It has a Bible verse on it. 4 Q. On the cover of it? 5 A. Yes. 6 Q. Okay. And, and you kept this book fort! 7 period of time? A. I have kept it in when I was working, and 9 i think I record my in fora year. 10 Q. From net 11 A. Alto 12 Q. Those complete calendar years? 13 A. Yes. 14 Q. Had you ever kept a record of zps.income for 15 any prior year, that is any year before =' 16 A. I have some record of a couple of months but 17 not as much as the whole year. 18 Q. Cou le of months of what year? 19 A. 20 Q. Are all of those records in the same book or 21 are they in different books? 22 A. Different books with lined paper. 23 Q. And what information did you record in these 24 books? 25 MR. EDWARDS: Don't answer. invoking her Page 63 1 BY MR. LUTITER: 2 Q. Did you keep in this book the names of any 3 individuals? 4 A. No. 5 Q. For what purpose did you keep this book? OrT 6 shouldn't say this book. These books because you, you 7 have testified there is more than one, correct? 8 MR. EDWARDS: Object to the form. Don't 9 answer this question. She is invoking her Fifth 10 Amendment right onto that as well. 11 MR. LIJITIER: The question for what purpose 12 did you keep these books? 13 MR. EDWARDS: Correct. That's something that 14 should she provide an answer could provide a link 15 in the chain 16 BY MR. LUTHER: 17 Q. Where are these — how many of these books are 18 there? 19 A. Two or three. 20. Q And where are they currently located? 21 MR. EDWARDS: Object to the form. Don't 22 answer. invoking her Fifth Amendment right as to 23 the location. 24 MR. LIMITER: How is the location going to 25 violate the Fifth Amendment? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 62 Fifth Amendment right to remain silent as to the language that is in these various books. MR. LUTTIER: Before -- MR. EDWARDS: -- outside the fact that she's admitted to keeping a tally of the money made. BY MR. LUIIIER: Q. Before we get to the, exactly what the books said, I want to ask you about what information is contained there. Does this -- A. My income. We're talking about my income. Q. So this -- A. That's what's contained in the book. Q. This book contains dollar figures? A. Yes. My income, dollar figures. Q. Does it contain -- all right. Does it reflect the date on which you received certain dollars? MR. EDWARDS: Objection. Don't answer. Invoking her Fifth Amendment right as to that question. BY MR LUTTIER: Q. Does it reflect, does the book reflect any other information whatsoever other than dollar figures? MR. EDWARDS: Don't answer. invoking her Fifth Amendment right as to that question as well. Page 64 1 MR. EDWARDS: I stated my objection. 2 BY MR. WITTER: 3 Q. (lave you shown these books to anyone? 4 A. No, sir. 5 Q. No one at all? 6 MR. EDWARDS: Object to the form, asked and 7 answered. THE WITNESS: No, sir. 9 BY MR. LUITIER: 10 Q. Did you utilize the information that was 11 contained in these books for any reason? 12 A. No, sir. My own personal knowledge 13 MR. GOLDBERGER: Can we just go off the record 14 for one second. 15 MR. LUTTIER: Sure. 16 THE VIDEOGRAPHER: Going off the video record. 17 The time is 11:05 asm 18 (A discussion was held off the record) 19 THE VIDEOGRAPILER: We're back on the record. 20 The time is 11:05. 21 BY MR. LUTTIER: 22 Q. 1 just want to clarify something. During this 23 deposition from the beginning of it until now your 24 counsel has invoked your right to the Fifth, privileges 25 afforded you under the Fifth Amendment. 16 (Pages 61 to 64) PROSE COURT REPORTING AGENCY, INC. EFTA02726451 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 65 Are you incorporating that right? Are you 'asserting that right to the Fifth Amendment? A. Am I allowing him to -- Q. Well, your lawyer said it. But are you, are you incorporating his invocation of your Fifth Amendment right? A. Am I allowing him to say it? Q. Yes. A. Yes. Q. So, it's your desire, you are invoking that Fifth Amendment right, correct? A. Yes, I am. MR. EDWARDS: Just read it whenever he says it. MR. LUTHER: This might be lawyer technical stuff, but I believe if you're going to invoke that right, you have to assert the right so -- THE WITNESS: On advice of counsel -- BY MR. LUTHER: Q. Hold on. Let me ask a question. As to those questions that you were previously asked during this deposition wherein your counsel invoked your Fifth Amendment right, do you intend to invoke that right as well? A. On advice of counsel, I invoke my Fifth Page 67 1 are, and how he is, and how he is. 2 Q. When you say how I am and my co-counsels here, 3 what do you mean by that? 4 A. I mean that if you say you have children and you are sticking up for this sick man, and ifs not just 6 me talking, but ifs so many other little girls that are 7 talking, you're sick. 8 Q. And are you referring to your past actions 9 with Mr. Epstein? 10 A. Yeah. 11 Q. And, and you believe that whatever your 12 interaction was with Mr. Epstein, that was wrong; is 13 that right? 14 A. Excuse me? 15 Q. You believe whatever your interaction with 16 Mr. Epstein was in the past, that it was wrong? 17 A. I think for a 50-year-old man to take over, 18 over 100 girls and the little girls that I brought that 19 were from the ages of 12, to have them see, to have him 20 see different vaginas without hairs on it when he is 50 21 years old, to masturbate and to get off like that, I 22 think it's pretty sick in the head. 23 And for you guys to be defending him, that's 24 pretty sick. I don't know if you guys have any 25 daughters, but would you want your daughter at Jeffrey 1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 66 Amendment rights under the United States Constitution. Q. As to each question that's been asked of you thus far where your counsel invoked those rights? A. Yes, sir. Q. Now, when we took a break during this deposition a few minutes ago, when you came back in the room, did I hear you say that you wanted to have Mr. Epstein in the room? A. I really doe care. Q. So you have no fear of Mr. Epstein being at the deposition; is that correct? A. Being here — Q. Right A. —1 don't have fear of him. 1 would actually love for him to see what he put me through if he cares. Q. Did you know you took the position in court that you didn't want him present and that you, you were fearful of having him in the room? A. Yes. Q. When did that fear disappear? A. As of about right now when you are stirring up all these emotions in me, I would love to look him right in the face. Q. Okay. A. And to tell him how sick he is and how you Page 68 1 Epstein's house while he is massaging and touching her, 2 her vagina? Would you like that? 3 Q. How long have you been of this opinion? 4 A. Of this opinion, I think everybody has an 5 opinion like that. 6 Q. How long have you held the beliefs that you 7 just expressed? 8 A. How long have I held the beliefs? 9 Q. That's right, ma'am. 10 A. Probably when I had my son and I realized, 11 wow, I have a little boy, if anybody was to touch him 12 and screw up his mind like they screwed up mine and hurt 13 me -- 14 Q. So, it was the birth of your son that was the 15 event that caused you to realize all these things? 16 A. Maybe that made me wake up a little more. 17 Q. Prior to that -- 18 A. But I knew that it was wrong at the beginning. 19 Q. When did you 'mow it was wrong? 20 A. I knew it was wrong the first second I stepped 21 into hiS house. 22 Q. Do you know what a pimp is? 23 A. Yeah, I know what a pimp is. 24 Q. What is a pimp? 25 A. A pimp to me is a man who sends out women to 17 (Pages 65 to 68) PROSE COURT REPORTING AGENCY, INC. EFTA02726452 Page 69 1 do sexual acts and bring back the money to the pimp. 2 Q. Have you ever had a relationship with a pimp? 3 A. No, sir. 4 Q. Have you ever acted as a pimp? 5 A. If you want to say when I was, you know, under 6 the age of 18 bringing girls to Jeffrey Epstein, sure. 7 You can call me Jeffreys pimp. 8 Q. And what do you mean by that? 9 A. You don't understand? 10 Q. No. I want to know what you mean, ma'am. 11 What I understand doesn't really matter. 12 A. I just gave you the definition of a pimp. 13 Okay. 14 Q. Were you — so, so, you were bringing girls to 15 Mr. Epstein - 16 A. Yeah. 17 Q. at some point, correct? 18 A. Yeah. 19 Q. You knew that the girls were going to come to 20 perform massages on Mr. Epstein when you brought them 21 is that correct? 22 A. Oh, yeah, and more. Not just massages. 23 Q. And did, and did you get paid money to do 24 that? 25 A. Yeah. 1 2 3 4 5 6 7 8 9 to 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 71 going over to his house because the answers may be different. I am not sure. BY MR. LUTHER: Q. Well, -- let me clarify. When was the last time you went to Mr. Epstein's house? A. At the beginning of -- I went there when I was 16 And I went that again after i had my So, it was after, it was either at the end of when I was 16 or at the beginning when I was 17. Q. You age 16? A. Yes, I was. Q. A. Thank God. Q. You never had sexual intercourse with Mr. Epstein, did you? A. Penis inserted into a vagina, no. Q. Did he ever insert his penis into your mouth? A. No. Q. Did ever insert his penis into your anus? A. No. Q. Did every insert his penis into your vagina? A. No. Q. Did he ever insert his penis anywhere in your body? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 70 Q. And did you share that money with anybody? A. Did I share that money with anybody? Q. Uh-huh. A. No. Why would I share my money with somebody? Q. Just asking if you shared it with anybody. A. No. Q. Now, you indicated previously that you had been seeing, I think to use your words MIS Do you recall that testimony? A. I never said IME I said I saw a Q. When is the first time in your life you ever saw a la? A. That I recall, after the Jeffrey Epstein, after seeing Jeffrey Epstein and I saw because of him. Q. My question is when was the first time? A. I don't know when the first time was. Q. When did you last see Jeffrey Epstein? A. When did I last see Jeffrey Epstein? I think I was about to tum -- no, when i was at the end of 16 or the beginning of 17. MR. EDWARDS: Just so it's clear, you, when you're asking the question when was the last time saw him, do you mean physically saw him or was Page 72 1 A. No, but he would bring my hand closer to his 2 penis. 3 Q. What do you mean by he would bring his (sic) 4 hand closer to his penis? 5 A. Do you want me to show you? Here is my hand. 6 I am Jeffrey. Here is my penis. Come closer, like 7 that 8 Q. Did you ever hold his penis in your hand? 9 A. No. 10 Q. Did you ever perform any sexual act on Jeffrey 11 Epstein? 12 A. Yeah. 13 Q. What act did you perform on Jeffrey Epstein? 14 A. Well, I would go there multiple times. 15 50-year-old man would be sitting on the couch talking on 16 the phone. i would sit there naked with my legs wide 17 open. But what really sickens me is that if this was 18 any Joe Schmo on the road who didn't have any money, he 19 would be in jail for a long time or he would be shot. 20 But he is not, right. He is the multi billionaire so he 21 is allowed. He is probably fucking jacking off right 22 now. I am sorry. I am 21. You can't jack-off to me, 23 but you lmow — 24 MR. LUTTEER: Move to strike the soliloquy as 25 not being responsive to the question. 18 (Pages 69 to 72) PROSE COURT REPORTING AGENCY, INC. EFTA02726453 Page 73 1 THE WITNESS: What did I do to Jeffrey and 2 what did Jeffrey do tome? I went up there 3 multiple times. I can't count. And I would be on 4 a massage table massaging his legs. He would turn 5 over. His penis would be hanging out He would 6 put a vagina or a vibrator to my vagina. He would 7 touch my vagina with his fingers. He would touch 8 my breasts. He would by to kiss my mouth. He 9 would bring my hands towards his penis. He would 10 ask the little girls that I was with, hey, can I 11 just see your vagina, can I just see it, even if 12 they would say no. Can I, oh, I know, but let me 13 just see it. Let me just see it. Sick mother 14 fucker. 15 I would like him in this room. 16 BY Mk LUTTLER: 17 Q. Any sexual act that you performed with Jeff? 18 A. Is that not a sexual act when you put a 19 vibrator to your wife's pussy; is that not a sexual act? 20 Q. Any act that you performed with Mr. Epstein 21 that you haven't described thus far? 22 A. Let me see. I went there multiple times. 23 There was multiple things that I have done with Jeffrey 24 and Jeffrey has done with me. 25 Q. My question stands. Did you perform any act Page 75 1 Q. You said -- 2 A. Talked one guy that morn from 3 his house to m . I would talk t . I 4 would talk to many of the girls that were just wandering 5 around his house. 6 Q. So you say, you gave us a phone number that 7 you say you called, right? 8 A. I ant not positive if that was his phone 9 nunliWi I know that a lot of his phone numbers started 10 wit... 11 Q. You mentioned and some other people. 12 Did you ever call Mr. Epstein directly? 13 A. Yeah. 14 Q. Did you ever have a conversation with him? 15 A. Yes. 16 Q. And when did that happen? 17 A. From the time that I went there to the time 18 that I stopped going there. I always talked to Jeffrey 19 on the phone. 20 Q. You always, what do you mean by "always." I 23. thought you said you talked AS. 22 A. I would always talk to Jeffrey eiliaktPlionc 23 I would talkctiiiii. I would talk ta. I 24 would talk t , whoever answered the phone. And 25 then sometimes Jeffrey wanted to get on the phone Page 74 1 with Mr. Epstein other than what you have described thus 2 far? 3 A. Besides standing there with my legs wide open 4 and his little fetish with me pinching his nipples — he 5 is probably getting hard right now — with my little 6 l2-year-old girlfriend standing next to me, both naked, 7 no, I can't think of any other sexual acts I have done 8 with Jeffrey. 9 Q. And, and did you say that you went there 10 multiple times? 11 A. Yeah. 12 Q. How many times would you say you went? 13 A. More than, more than 50 times. 14 Q. Did you keep a record of the number of times 15 you went? 16 A. Unfortunately I didn't. 17 Q. And were there occasions when you contacted 18 either Mr. Epstein or people on his behalf asking that 19 you be allowed to come over? 20 A. They would call me most of the time, but, yes, 21 there was multiple times I would call them. 22 Q. And for, and who did you call? 23 A. I called the house phone, I don't 24 know. There was multiple house numbers. I would talk 25 to I would tallc to the one — Page 76 1 because he wanted to tell me what kind of specific girl 2 he wanted that day or tomorrow or the next day. 3 Frequently! would talk to Jeffrey Epstein on the phone. 4 Q. You used the word "always." If I am 5 understanding correctly, you are saying you were calling 6 and you were talking to different people on different 7 occasions; is that right? 8 A. Yeah. 9 Q. Okay. And do you have any record of your 10 conversations or the number of times you called and 11 claimed that you talked to Mr. Epstein? 12 A. Do I personally have a record? 13 Q. Yeah. 14 A. No, but you can talk tole about that and 15 Jeffrey. Jeffrey has a record. 16 Q. So, you don't have it? 17 A. Unfortunately, no. 18 Q. Now, on these multiple times, how manyjim . 19 would you say you called, initiated a call asking= 20 or someone else if you could come over to Mr. Epstein? 21 A. Well, when I first started going there he 22 called and he would call and call and call and call. 23 And he told me from that point be said, listen, you 24 call me when you find somebody. Ifl didn't have 25 somebody new, then he didn't want me calling. III 19 (Pages 73 to 76) PROSE COURT REPORTING AGENCY, INC. EFTA02726454 Page 77 1 found a new girl, he wanted me calling right away. 2 Right way. I would go there two times a day. 3 Can I have a water, please? 4 MR. LUTHER: Sure. I dont see any up there. 5 MIL EDWARDS: Let's take a brief break until I 6 find a water and well come back on. 7 MR. GOLDBERGER: There is a cooler over there. 8 MR EDWARDS: It may be in the cooler but I 9 don't see 10 THE COURT REPORTER: lean go upstairs. It 11 will take me a couple of minutes. 12 THE VIDEOGRAPHER: Are we going off the 13 record? 14 MR_ EDWARDS: Yes. 15 THE VIDEOGRAPHER: Going off the video record. 16 The time is 11:01. 17 (A brief recess was held.) 18 THE VIDEOGRAPHER: We're back on the video 19 record. The time is 11:33 a.m. 20 BY MR LUTHER: 21 Q. In your, in one of your prior answers you said 22 something about a 12 year old being present with you. 23 Do you recall that testimony? 24 A. Yes. 25 Q. Who arc you referring to? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 79 Q. Well, were you a in high school — A. No. Q. — when you first went to A. No. Q. Weresillan school when you first went to A. No. Q Wereanill school when you first went to A. Might have been. Q. That would be thellEgrade? A. Might have been. attend any high school before you went toQ Did ? A. Yes. Q. What high school did u attend? A. I have attende . Q. The question is what high school did you attend? A. I am to think, sir. I have attended Q. What year? A. I don't know. Q. When I say what year I mean as a freshman or as a sophomore or junior or senior? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 78 A. That is multiple ones. I do know one. Her name is Q. what? A. I'm not -- I don't know the spelling is. Q. Is in. A. (Witness spelled name maybe. Q. And how do you -- did you Imow A. Yes. Q. How did you know her? A. School. Q. What school? A. Q. She was a student at A. Yes. Q. And when did you first make her a • tance? A. When I started going to school at Q. When did you start going to school at- III.? years. So, the first year that A. For the record, lam mall bad with math and opened up was the first year that I went. NM? Q. And what ear of school were you in when you first went to A. Like I said, I'm not good with years. MN? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 80 A. ma . Q. So as a A. Maybe. Q. Well, if wasn't the , it would have been the 10th, 1 Ith, or 1 2111: t? A. Yes, sir. Probably from what I recall. Q. You are talkin about the- located in is that correct? A. Yes. Q. And it only begins in the A. Yes. So Q. Did you attend for your entire year? A. 'don't think I did, sir. I think I transferred to and after that I transferred to Q. Well, lees sta Why did you attend by that I mean -- A. My 'nether lived in Q. Okay. Okay. Where did your mom live? A. My mother lived in Q. In a devisnent like M A. ill 20 (Pages 77 to 80) PROSE COURT REPORTING AGENCY, INC. EFTA02726455 Page 81 1 Q. And were you living with her at the time? 2 A. At the time I was. 3 Q. Was there anyone else living with you and your 4 mother? 5 A. My sister. 6 Q. And your sister's name is? 7 THEW : Do I have to give my sister's 8 name? I would really rather not give you my 9 sister's name. 10 BY MR. LUITIER: 11 Q Would that be inn 12 A. I would rather not give you my sister's name. 13 Q. Is your sister's name 14 A. I would rather not give you my sister's name. 15 Q. This is a yes or no, ma'am. not 16 complicated. Is your sister's name 17 MR. EDWARDS: Object to the form. Asked and 18 answered. The objection is a right of privacy of 19 third parties. She's not going to give the name. 20 MR. LUTHER: Are you instructing the witness 21 not to answer-- 22 MR. EDWARDS: Yes. 23 MR LUTHER: — the question of whether your 24 sister's name is 25 MR. EDWARDS: Correct. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 83 Q. You said the beginning IS that's when I transferred to Q. arm mother's name? A.1 Q.. Q. Did you liv e other than your mother before the A. My father. Q. WilliSMS. ' • u were in the and living with your mother in was your Ala; living with you? A. Yes. Q. And do you know how old you were in the ninth grade? A. No. Q. • grade? A. ' en you were in the your mother, was she always living in 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 82 MR. LUTHER: Are you serious? MR. EDWARDS: Yeah. MR. LUTHER: Okay. I am going to guess your sister's name is THE WITNESS: You can guess that. BY MR. LUTHER: Q. OlcAL So, it was you and and your mom living at MR. EDWARDS: Object to the form. THE WITNESS: No. It was my mother, my sister, and I living-- BY MR. LUTHER: Q. And is that different than the people I just said? MR. EDWARDS: Object to the form. THE WITNESS: It was my mother, my sister, and I living in. BY MR. LUTTIER: Q. And for what period — A. — MM. Q. — of time did you and your mother and you sister live in A. I was living with my mother when I ' M grade. And when I was , and pretty much the beginning of 1 2 3 4 5 6 7 8 9 10 3.1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 84 house when I was i ir, I was in and out Q. What do you mean in and out — A. I don't want you to think that I c full time when I was in I was in and house when I was in Oli veto separated. My f My mother I went to several schools I went to several schools in Well, you told me abou you told me about hoots did you alb is I. e fo I attended ' when I was supposed to be, when I was i Q. Now, when you say you were in and out of your mother and father's house, what do you mean? A. I lived with my mother for a little while. And then I would go to my father's house for a little while. You know, they were separated, so, I — there was never a court ordered statement saying that I had to 21 (Pages 81 to 84) PROSE COURT REPORTING AGENCY, INC. EFTA02726456 2 3 4 5 6 7 Page 85 1 be anywhere specific. Q. Well, when you say they were separated, were they separated or were they divorced? A. They were, they were divorced when I was Q. . And , that would have been about what, 8 A. Sure. 9 Q. And why were you moving back and fI between 10 iiiritother and father's house as late as the= 11 12 A. Because they actually, they, they allowed it 13 to be my choice. You know, they allowed it to be my 14 choice. They -- it wasn't a big deal. If I wantod to 15 go live with my mother, I lived with my mother. If I 16 wanted to live with my father, I lived with my father. 17 Q. And did you move all your belongings from one 18 house to the other? 19 A. I had some of my stuff over at my mother's 20 house and some things at my father's house as well. 21 Q. Did you have any conflict with our mother 22 a this period of ti 23 MI when you say you were living with her? 24 A. Yes. 25 Q. What was the conflict with your mother? Page 87 1 MOM interested into getting into drugs. 2 Q. Well, you, you had done drugs prior to the 3 time you met Jeffrey, correct? 4 A. I smoked weed a few times, and that was pretty 5 much it. And when I met Jeffrey, the girls that, 6 who brought me there, she would start giving me 7 drugs. 8 Q. What kind of drugs? 9 A. Pills, any kind of pills. 10 Q. What kind of pills? 11 A. Any kind, Valiums, Percocets, Lorcets, any 12 kind of pills to make you I guess chill to not be 13 nervous in front of a 50-161 14 . Q. Well, who is thi that you're 15 referring to? What's her last name? 16 A. I don't know. 17 Q. You have no recollection who this is? 18 A. No, sir. 19 Q. And this is a person that you said did what? 20 What was your relationship? 21 A. She brought me to Jeffreys the first time. 22 Q. How did you know this person? 23 A. I was at a house and I am not exactly -- I was 24 at one of my frien' And I spent the night over 25 there. And I guess was one of my friend's Page 86 1 A. Well, after I met Jeffrey, I started getting 2 into bad, just drugs, and they kept on escalating and 3 escalating, and that's what happened 4 Q. What do you mean when you say after you met 5 Jeffrey, you got into drugs? 6 A. After I had met Jeffrey, I started doing more 7 and more and more drugs. 8 Q. When did you -- I assume you mean illegal 9 drugs or drugs for which you didn't have a prescription? 10 A. Correct. 11 Q. What drugs did you do? 12 A. Any drugs I could get, colic, pain bile's. I 13 have done many drugs, ecstasy and -- 14 Q. Xanax? 15 A. And Xanax. 16 Q. Is that one of your drugs of choice, Xanax? 17 A. What do you mean? 18 Q. Is that one of your drugs of choice, a popular 19 drug for you? 20 A. When I was that age, yeah. Any drug -- 21 Q. That age meaning what age? 22 A. When I was seventh and eighth and ninth. Not 23 when I was in seventh. More when I was in eighth and 24 ninth. I don't know the exact -- when I was in school. 25 I know that when I met Jeffrey, the drugs I got, I was INetibMilli7.•••••••:•••0110apillilablela1101% Page 88 1 friend. And she asked me ill wanted to make $200. And 2 at first I was very, very skeptical about it because of 3 the way she explained it to me. But then she convinced 4 me into it. S And once I walked into that beautiful house 6 and that beautiful mansion with all those beautiful 7 girls and luxurious living with all those beautiful 8 cars, I thought at that age that that's what I wanted or 9 that's what I could have made of myself. 10 Q. So, it was this person named that you 11 say convinced you to go to Jefficy Epstein the first 12 time, is that — do I have your testimony correct on 13 that? 14 A. Yes, you do. 15 Si ll, _Jeffrey Epstein had no contact with you until 16 whatever her last name is, brought you to his 17 house; is that correct? 18 A. That's correct. 19 Q. And you met at, you say at a friend's 20 house. What was that friend's name? 21 A. I a ify sure it WaS house. 22 Q. MI who? 23 A. I don't know his last name. 24 Q. You were spending the night at this person's 25 house? 22 (Pages 85 to 88) PROSE COURT REPORTING AGENCY, INC. EFTA02726457 Page 89 1 A. Uh-huh. 2 THE COURT REPORTER: Is that a yes? 3 THE WITNESS: Yes. 4 BY MR. LUMER: Q. So, w a boyfriend of yours? 6 A. No. we had, we had friends. We had 7 mutual friends that we would just hang out with. 8 and a couple of my girlfriends, and we all spent the 9 night over there just havn4in. 10 Q. Well, how old 11 A. Oh, I'm not, I'm not sure. 12 Q. -- at the time that you were spending the 13 night at his house? 14 A. Maybe — he was young as well. He was maybe 15 16. It was his parents' house. 16 Q. Okay. So his parents were present when you at 17 this age were spending the night over at his house? 18 A. Yes, they were. Yeah, his parents were there. 19 Q. And they were there? 20 A. Yes. 21 Q. Okay. And who were these other you said we 22 had mutual friends. Who is the "we" you were referring 23 to? 24 A. Well, he introduced me was 25 one of my girlfriends". and a couple of her friends, Page 91 1 the night that you spent, the night house? 2 A. I, I saw ha before becaus would hang 3 out with her, but we di ttareally talk. She was a nice 4 girl, but she was one friends that had 5 introduced me to her. 6 Q. So introduced you 7 A. introduced me t 8 a this evening when you spent the night at 9 or before that? 10 A. No. A couple of days before Q. What was your relationship I A 11 R.? 12 A. We were good friends from the neighborhood 13 that we grew up in. 14 15 Q. Which nei t? A. I grew up • . She grew up across 16 the frog i e thborhood I grew up in. Near 17 w. .t to say. 18 Q. , are you referring to 19 the City o 20 A. No 21 Q. 22 A. 23 Q. 24 A. 25 Q. Okay. So, tha Page 90 1 but mainly my girlfriend 2 Q. Well, who were these couple of her friends 3 that you are referring to? 4 A. A couple of girlfriends. I don't recall their 5 names. 6 Q. You don't know their fast name or last name? 7 A. No. 8 Q. No idea? 9 A. No. 10 25 But all of you spent the night over at this 11 - 12 A. Yeah, but that was years ago, so I really 13 don't remember. I don't hang out with them anymore. I 14 don't remember. 15 Q. You don't hang out with who,.. anymore? 16 A. No, I don't hang out with any of them anymore. 17 You don't When was the last time you saw 18 this that you've Terra MU to? 19 A. I actually passed by her New Year's Eve. 20 Q. Of what year? 21 A. Of M. New Yeat's Eve at downtown. 22 I passed by her. I just -- we just said hi. We didn't 23 hang out. We just said hi and talked a little bit, but 24 nothing much, like, hey, how are you, howeir.. first 25 Q. Is the time that you met this 1 2 3 4 5 6 7 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 92 development lige? A. That's . w up in known as A. : ew up across the street from in another development? A. Yes. Q. Did it have a name? sia that I recall. The road was called I am prettyame. Q. And you knew.... for how long, ever since you were a kid? A. Yes. I probably met her when I was 11, and we just were little girls riding bikes and playing. Q. Do you have any recollection of when you, this evening that you spent the night at house was? A. Well, from what I, from what I remember, I am pretty sure I was — I was 13 years old and, yeah. Q. And you were going -- A. I was 13 right about to turn 14. Q.hiagarou were going to what school? So it had to be.a? A. I'm Uigie. I couldn't tell you. Q And.. lived where? 23 (Pages 89 to 92) PROSE COURT REPORTING AGENCY, INC. EFTA02726458 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 93 A. He lived iu1 somewhere. He had a 'car. We didn't have a car. I don't know where he lived. Q. Diet drive? A. Yes. Q. Sal must have been old enough to have a license? A. Yes. I told you he was around 16 vears old. Q. And was this — when you say—t, are you talking about down somewhere near where you lived? A. Yeah, it was around that area, the heart of Q. Se, were the center o oing to school somewhere clown in or someplace up in. ill A. You know what, it could have been around sununertime when we didn't have school, and I was probably at my father's house at sunnnertime. Q. Now, at that point in time at the time that you went and spent the night a house, what drugs had you experimented with? A. I have experimented with weed a couple of times, but I personally didn't care for it. Q. What other drugs? MR. EDWARDS: Are you talking about at the Page 95 1 MR- EDWARDS: Has to be yes or no so the 2 record is clear. 3 BY MR. LUITTER: 4 Q. So my question is designed to be very 5 specific. So, if you can't recall, I want you to tell 6 me. If you definitely can recall then fine, give me 7 whatever answer. But I want to ask you..m.ils as of the 8 point in time that you spent the night AIM house, 9 other than marijuana had you used any other drug that 10 was a non-prescription drug? 11 A. No. 12 Q. Had you told anyone in the world as of that 13 point in time that you had used a drug? 14 A_ Maybe to be cool I would have said, oh, yeah, 15 I tried that before, but no. 16 Q. Were there any girlfriends that you knew, any 17 at all with whom you had done any illegal 18 non-Freon drug as of the date that you spent the 19 night al= house? 20 A- No. 21 Q. And you're absolutely sure of that, correct? 22 A Yes. 23 Q. All right. 24 k Do you want to ask me again? 25 Q. Now, when was the first time that this'll. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 94 time when — MR. LUTHER.: Yeah, when you — this, as of the, the point in time that I am fixing on is whenever this incident was when you spent the night at~ house. THE WITNESS: No. We weren't doing any drugs. BY MR. LUTTIER: Q lam not saying you were doing drugs at the time. I want to know what drugs you had experimented with -- A. Weed. Q. — before that point in time. A. Marijuana. Q. Had you ever taken any other illegal or non-presaisio n drug as of the time thaiitient the night at houseand first met this lady? A. No. Q. Are you sure? A. Yes. Q. Olcay. I want, I want to clarify now. You've indicated in this deposition that sometimes you can't remember dates, right? A. (Witness nods head.) Q. So — A. Yes. Page 96 1 girl that you say you met there, gave you a drug? 2 A. She would start giving me drugs after I saw 3 Jeffrey. 4 Q. Well, my question is when was the first time? 5 A. After I saw Jeffrey. I don't know the date. 6 Q. When after, a week after? 7 A. Yeah. 8 Q. A month after? 9 A. Yeah. 10 Q A year eller? 11 A. Yeah, a week, a couple of days. 12 Q. Did she — how did she introduce or give you 13 this drug? 14 At She gave it to me with her hand, here you go, 15 here is some drugs. 16 Q. And what did she tell you? 17 A. Here. This will make you not nervous when you 18 go to Jeffreys house. Take this drug. 19 Q. And what drug did she give you? 20 A. I think it was a Valium. 21 Q. Did you pay anything for it? 22 A. No. 23 Q. Were there other occasions that she gave you 24 drugs? 25 A. Yes. After every time I went to Jeffreys 24 (Pages 93 to 96) PROSE COURT REPORTING AGENCY, INC. EFTA02726459 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 97 1 with her, she would give me drugs. 2 Q. Did you ever see her on any occasions other 3 than when you were going with her to Jeffrey's? 4 A. After a couple of months, we hung out and 5 that's when I got Jeffrey's number. And I didn't, I did 6 not no longer need her to take me to Jeffrey's. So we 7 hung out a couple of times. We would talk about Jeffrey 8 and how much money we were making from Jeffrey and 9 that's that 10 Q. What do you mean you no longer needed her to 11 get to Jeffrey's? 12 A. I bad Jeffrey's phone number so I could call 13 him so he could send a taxi over, or he could send 14 somebody from his house to come pick me up to go to 15 Jeffrey's. I didn't need her or one of her friends to 16 drive me to Jeff, to Jeffrey's anymore. And now I was 17 one of Jeffreys girls to fad more girls, so -- 18 iiAnd this, this occurred when, that is that 19 never — stopped taking you there and you began 20 to go over these on your own? 21 A. Within a month. 22 Q. Now, you said that, that, something about 23 taking a cab. Who — weren't you the person that called 24 the cab? 25 A. I have called cabs, yes. Page 99 1 BY MR. LUTHER: 2 Q. Fair statement to say you don't know if he did 3 or WO 4 A. He told me that he was going to calla cab so 5 I could get to his house. 6 Q Do you know if Jeffrey Epstein ever called a 7 cab — 8 MR. EDWARDS: Object to the fem. 9 BY MR. LUTHER: 10 Q. -- to be sent out to you to get you? 11. A. Yes. 3.2 Q. How do you 'mow that? 13 A. Because he told me. 14 Q. Is that the only basis that you have -- 15 A. Yes. 16 Q. — for making that statement? You never heard 17 him get on the phone with a cab; is that right? 18 A. No, we never made a three-way call to the cab 19 station. 20 Q. Do you know whether or not on times when you 21 claim that he told you he was going to have a cab 22 whether he called for the cab or someone else called for 23 the cab? 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: Excuse me? Page 98 1 Q. And then you rode a cab from wherever you were 2 to Jeffrey's house? 3 A. Yes. 4 Q. Did anyone else calla cab for you to take a 5 ride from wherever you were to Jeff's house other than 6 you? 7 A. Yes. Q. Who? A. Ether my, one of the girls that I brought or Jeffrey would call a cab or one of Jeffreys assistants. Q. How do you know that — when you say Jeffrey called a cab, can you tell me any incident where you know that Jeffrey called a cab on your behalf? A. I would call him and I would say how do i get there, Jeffrey. He would say don't worry, I will have a cab come to your house. I will call a cab. Q. So, you don't know whether he called a cab or not? MR. EDWARDS: Object to the form. THE WITNESS: Fm, fm not, you know, fm not a psychic. I didn't go to his house in my mind and see if he physically picked the phone up. He probably told one of his maids or something to do it. Maybe he called a cab. Page 100 1 BY MR. LUTTIER: 2 Q. Do you know whether or not on those occasions 3 where you claim that Jeffrey told you he was going to 4 call a cab, whether he called the cab or someone else 5 called for the cab? 6 MR EDWARDS: Object to the form. 7 THE WITNESS: Jeffrey would get on the phone 8 with me. Hi, Jeffrey, how am I going to get to 9 your house. Don't wort' l. , I will take care of 10 it. I will call a cab. Sometimes he would say 11 that. Sometimes he would say, don't wony, I 12 will have one of my assistants or III will call a 13 cab. Sometimes I didn't talk to Jai-W. 14 Sometimes MI picked up the phone and said she 15 would calla cab. 16 BY MR. LUITIER: 17 Q. On how many occasions do you claim that 18 Jeffrey allegedly told you that he was going to call a 19 cab? 20 A. Definitely over 20 times. 21 Q. And you said that on some occasions, to use 22 your words, one of the girls would call. What girls are 23 you talking about? 24 A. The girls that I would recruit for hint 25 Q. So you were finding other girls that you would 25 (Pages 97 to 100) PROSE COURT REPORTING AGENCY, INC. EFTA02726460 Page 101 1 take to Jeffrey's place? 2 A. Yes. 3 Q. And you were paid money to do that? 4 A. Yes. 5 Q. How much were you paid? 6 A. $200. 7 Q. On those occasions that you took other girls 8 to Jeffrey's house, what did you do once you got to the 9 house? 10 A. We would walk in the house. Sometimes he 11 would just say the door is open, walk on in. Sometimes 12 someone else would answer the door. He had multiple 13 people at his house all the time, either they were 14 maids, chefs, or quote, unquote, models. He said that 15 they were girls who traveled with him would answer the 16 door. 17 By the time I already knew the drill. The 18 drill was is that we went right into the kitchen, took a 19 right There was a staircase with pink carpet. You 20 walk up the stairs. Then you take a left. You walk up 21 another thing of stairs, and then you take another 22 little left, curve to the right. There is his big 23 bedroom. There is a picture on the wall to the right on 24 the hallway before you walk into his room of a little 25 naked girl, probably three years old with her pants Page 103 1 clothes on; sometimes he had his clothes off. Sometimes 2 he had a towel around him. When he walked in the room, 3 we already had the massage table ready. There was a 4 couch right next to the massage table. We would sit 5 there. I would tell, I would instruct the girls to do 6 exactly what he told me to instruct the girls to do. 7 I would tell them take off their shoes. We 8 would take off our shoes. Heleitild be in the shower. 9 He would say get them ready,., so I would tell the 10 girls to take off her shin, take off her bra, take off 11 her pants. He likes it when you can take off your 12 panties, preferably. 13 He would get out of the shower, wipe off, lay 14 down on the massage table on his stomach. And we would 15 proceed to massage his legs. He loved his legs 16 massaged. 17 Then we would proceed to massage his back. 18 And he absolutely loved his scalp being massaged as 19 well. So one girl would get cn his back, massage; one 20 girl would be massaging his scalp. His feet he liked 21 massaged. 22 Then as we are naked, and as he is naked, he 23 turns over and the guy likes to talk. He would like to 24 talk about everything: What kind of drugs we liked. 25 What kind of things we've done. If we have ever took a Page 102 3. hanging down. 2 And then you walk into his bedroom. Big bed 3 on the left. Always white linen. And in that bedroom 4 there was another room to the left There was a steam 5 shower. There was a steam room in there. A shower 6 right next to the steam room. There was a bathroom to 7 the left of the steam room. There was a closet on the 8 opposite, opposite side of that bathroom. 9 There was a dresser right next to that closet 10 that had lotions, different lotions. I remember I think 11 they were from the Body Shop. Then there was toys 12 inside of those drawers. 13 When you opened up the closet, there was a 14 massage table. Either it would be set out for us or 15 most of the time we would have to set the table up for 16 him. 17 We would take three big towels. Ho liked one 18 towel laid down by his feet and two big towels laid by 19 his head. 20 He would walk in. And I would be with one of 21 my girls that I had brought. When he walked in, he 22 would wink at me if he hied the girl. Pretty much he 23 would give me a smirk or a smile like, yeah, you did a 24 good job. Then he would jump in the shower. 25 When he came in the room, sometimes he had his Page 104 1 sip of alcohol. He said that he has never drank in his 2 life. He said that he never took a sip of alcohol in 3 his life. He said did you smoke cigarettes. We would 4 taint yes or no. He said that he never smoked a 5 cigarette in his life. He said that he was a brain 6 surgeon. He said he wanted to know what we did in our 7 daily life. He wanted to know what kind of people we 8 hung out with. 9 Q. Are you describing this happening every time 10 you went there, or arc you describing an incident? 11 A. Every brae we went there. 12 Q. Every time you went, every time you went -- 13 A. Every time I went, every time I went with a 14 girl. 15 Q. The exact same thing you describing to a T 16 happened; is that right? 17 A. To a T. 18 Q. Every time? 19 A. Most of the time. There has been times where 20 I've went there and there was an incident where it was 21 just me. And he sat on the, and he sat on the couch and 22 talked on the phone. And I had my legs wide open, and I 23 was naked and he wanted me to massage his feet. 24 MR. CRITTON: We're done with the tape. 25 MR.. WI TIER Are you done with the tape? 26 (Pages 101 to 104) PROSE COURT REPORTING AGENCY, INC. EFTA02726461 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 105 THE VIDEOGRAPHER: I need to change it. MR. EDWARDS: Do you want to take a lunch break now? MR. LUTTIE.R; Yes. THE VIDEOGRAPHER: Going off the video record. The time is 12:10 p.m (A luncheon recess was held.) THE VIDEOGRAPHER: We're on the videotape record. The time is approximately 1:30 p.m. This is the beginning of Tape Number 2. BY MR. LIJTIiER: Q. All right, ma'am. I want too back and ask you some more questions about... Do recall her iilib he friend of yours that you knew at MI? A. Yes. Q. Were you and she in the same class? A. No. Q What class was she in m comparison to the class you were in. Was she in front of you or behind? A. Way behind me. Q She was at !caste in high school? Had to be at t? A. I knew her before NM, but yes, she was definitely — she came into the school. Yeah, 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 107 schools. I brought her before that. i brow t her before that because I had brought which is now deceased. Before I had — I had after I brought'''. So I brought'''. before and that was way before I went to Q. Now, you said you just got off the phone with someone. Who did you get off the phone with? A. I would rather not say. MR. EDWARDS: I think that you are going to have to tell them who you talked to. THE WITNESS: My mother. BY MR. LUTTIElt Q. So, you mean you got off the phone with her during the lunch break? You called her. A. Yes, I was talking to her because I wanted to make sure, I wanted to see if she knew how old I was when I was going to certain schools. Q. Well, I mean, lets be candid. You, you figured out during lunch tha_tyour testimony couldn't be accurate that your friend, was 12 at the time that you took her ti ii l: aain:s if she in fact was a student at • isn't that the truth of the matter? MR. EDWARDS; Object to the form. Object to Page 106 1 she was probably a 2 Q. Well, I mean testified earlier, you said 3 you knew her from , correct? 4 A. I didn't know her from that school. I ;mew 5 her, I ;mew her previously from that, from that school. 6 Q What did mean when you said you knew her 7 from— A. She lived, well, I mean that's where we mostly 9 associated I s. She lived in a neighborhood 10 cal (phonetic). That's right near that 11 school. And now that you mention it, I remember I met 12 her through my girlfriend-. So, and then she 13 its- I remember she went to school to 14 when I went to 15 Q. Now, when you said she went to 16 meant..? 17 A. Yes. 18 Q. Who is gi? Ell who? 19 A. I don't know her last name. 20 Q. And you both were attending 21 at the time that you went to Jeffrey Epstein's house 22 with her? 23 A. No, I just, I just got off the phone with 24 someone and I realized that I, I remember all the, how 25 old I was and everything when I did go to certain ,you Page 108 1 the form. 2 THE WITNESS: No, I wasn't thinking anything 3 of that. I was asking her because I know that 1 4 can't remember any of the years that you're asking 5 me and stuff. So I said, hey, mom, what school -- 6 can you tell me all the schools I went to and how 7 old was I. And when you're talking, it's all 8 coming back to me. I don't think you remember 9 everything that when you were 10, 11, 12, 13, 14 10 years old, right off-hand, right? 11 But when someone explains it to you, like, oh, 12 yeah, it comes back to me. 13 MR. LUITIERI In fact — 14 THE WITNESS: So, I don't know why you're 15 looking at me like that with a smirk on your face 16 like - 17 MR. LUTTIER: Move to strike. You seem to 18 think there is something amusing about this, but 19 nobody else in the room does. 20 THE WITNESS: I don't think there is anything 21 amusing about this. Are you kidding? I think it's 22 amusing that all three of you guys are sitting 23 these, you 'mow, defending a sex offender. Are you 24 kidding mc? That's what i think is flicking 25 amusing. 27 (Pages 105 to 108) PROSE COURT REPORTING AGENCY, INC. EFTA02726462 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 109 BY MR. LUTTTER: Q. By the way, did your mother teach you to use that language or did you acquire that in school? A. Are you being — you know what, maybe I learned it in schooL Q. Is that where you learned that? A. Maybe i learned it from Jeffrey. Q. And by the way, when did you quit going to school? A. I quit going to school right after (it • NEM Q. So, obviously you were engaging in sexual intercourse with males no later than your 16th birthday, right? A. If you're asking me when I lost my virginity, 1 lost my virginity when I was 14 years old. Q. And who did you lose that to? MR. EDWARDS: Object to the form. I am going to instruct the witness not to answer based on my previous notation for the record. This issue is on appeal. And until that Rule to Show Cause Order is resolved, the witness is not going to answer this question. Invoking her privacy rights and the Page 111 1 MR. EDWARDS: Same objection. 2 MR. LUTTIER: As 1 understand these 3 objections, none of these are Fifth Amendment 4 objections, coned? 5 MR EDWARDS: Correct. 6 BY MR. LUTM3R: 7 Q. And for how many years were you sexually 8 active prior to going to Jeffrey Epstein's house? 9 MR. EDWARDS: Same objection. 10 BY MR. LUTIIER: 11 Q. And please describe for me each sexual act 12 that you performed either with males or with females 13 prior to the time you rust went to Jeffrey Epstein's 14 house. 15 MR. EDWARDS: Same objection. 16 BY MR. LUTTD3R: 17 Q. Did you have — did you perform any sexual act 18 with females prior to the time that you first went to 19 Jeffrey Epstein's house? 20 MR. EDWARDS: Same objection. 21 BY MR. LUTITER: 22 Q. Prior to the time you lost your virginity, did 23 you engage in any sexual acts with any males other than 24 intercourse? 25 MR. EDWARDS: Same objection. Page 110 privacy rights of third parties. MR. LUTTIER: Okay. I am going to go through a series of questions then. /v1R. EDWARDS: Okay. MR. LUTHER: The first question is who did 6 you lose your virginity to. I heard that 7 objection. 8 BY MR. LIMIER: 9 Q. And when you say you lost your virginity, what 10 act was performed that caused you to lose your 13. virginity? 12 MR. EDWARDS: Same objection. 13 BY MR. LUTITEIR: 14 Q. And how many times did you perform this act 15 that caused you to lose your virginity? 16 MR EDWARDS: Same objection. 17 BY MR. LUTTIER: 18 Q. Did you perform an act that caused you — 19 after you lost your virginity, did you continue to have 20 sexual intercourse with other people? 21 MR EDWARDS: Same objection. 22 BY MR. LUTTIER: 23 g For how long were you having sexual 24 intercourse with individuals prior to going to Jeff 25 Epstein's house? Page 112 1 BY MR. LUTTIER: 2 Q. Did you have oral sex; that is, did you place 3 a male's penis in your mouth at any time prior to the 4 time that you went to Jeffrey Epstein's house for the 5 first time? 6 MR. EDWARDS: Same objection. 7 BY MR. LUTTIER: 8 Q. Have you ever been filmed at any time engaging 9 in any type of sexual act? 10 A. Have I been filmed? i filmed myself. 11 Q. And when was that? 12 A. I was 19. 13 Q. What year would that be? 14 A. Well, it's '09. So, that would be '07. 15 Q. And would you toll us the circumstances under 16 which you filmed yourself in a sex act when you were 19 17 in 2007? 3.8 MR. EDWARDS: Same objection and I am 19 instructing her not to answer. And she will invoke 20 her Fifth Amendment rights at this time as well. 21 MR. GOLDBERGER: She needs to do that. 22 MR. LUTTIER: Yes. 23 THE WITNESS: On advice of counsel, I invoke 24 my Fifth Amendment rights under the United States 25 Constitution. 28 (Pages 109 to 112) PROSE COURT REPORTING AGENCY, INC. EFTA02726463 Page 113 1 MR. CRITTON: Cindy, mark two pages back. 2 There is something i want from there. 3 BY MR. LU'flIER: 4 Q. When you filmed yourself in a sex act when you 5 were 19 in 2007, was anyone else performing the sex act 6 with you? 7 MR. EDWARDS: Same objection. I am instructing the witness not to answer. Invoking 9 ha Fifth Amendment rights as well. 10 MR. CARTON: She needs to read. 11 MR EDWARDS: Okay. 12 THE WITNESS: On advice of counsel I invoke my 13 Fifth Amendment rights under the United States 14 Constitution. 15 BY MR. LUTTiER: 16 Q. Did someone request you to fihn yourself in a 17 sex act when you were 19 in 2007? 18 MR. EDWARDS: Seine objection. 19 MR. LUITIER: How is that Fifth Amendment? 20 MR. EDWARDS: You're, you're going to refer to 21 the sex act — 22 MR. LUTTiER: No, i asked -- 23 MR. EDWARDS: — that's being filmed. 24 BY MR. LIMIER: 25 Q. My question is, did someone request you to Page 115 1 time. 2 BY MR. LUTHER: 3 Q. Did you ever film yourself in a sex act prior 4 to the occasion that you did it when you were 19 in 5 2007? 6 A. No. No, sir. 7 Q. Did you publish this film that you made of 8 yourself engaged in a sex act when you were 19? 9 A. No. 10 Q. Did it go on the Internet? 11 A. No. 12 Q. Did you ever show it to anyone? 13 A. No. 14 Q. Are you sure? 15 MR. EDWARDS: Objection, asked and answered. 16 THE WITNESS: I am actually positive that 17 did not show myself doing any sexual act. 18 BY MR. LUTTIER: 19 Q. For what ptupose did you film yourself in a 20 sex act when you were 19? 21 A. On advice of counsel i invoke my Fifth 22 Amendment rights under the United States Constitution. 23 Q. Did anyone make you film yourself in a sex act 24 when you were 19‘? 25 A. On advice of counsel I invoke my Fifth Page 114 1 film yourself in a sex act when you were 19 in 2007? 2 MR. EDWARDS: Same objection. And you can 3 read. 4 THE WITNESS: On advice of counsel, I invoke 5 my Fifth Amendment rights under the United States 6 Constitution. 7 BY MR. LUTTIER: Q. Well, with your invoking of the Fifth 9 Amendment suggests that you think you're going to be 10 prosecuted fix something? 11 MR. EDWARDS: You don't have to answer. 12 BY MR. LUITTER: 13 Q. Did you voluntarily film yourself in a sex act 14 nem you were 19 in 2007? 15 MR. EDWARDS: She's not answering. 16 THE WI NESS: On advice of counsel, I invoke 17 my Fifth Amendment rights under the United States 18 Constitution. 19 MR. WHIM: And that's the sole basis for 20 refusing to answer that question? 21 MR. EDWARDS: This is also precluded because 22 this is an issue that deals with the issue on 23 appeal. And until that is resolved, we're not 24 going to answer those questions. So we're resting 25 on that as well as the Fifth Amendment at this Page 116 1 Amendment rights under the United States Constitution. 2 MR. EDWARDS: And the objection is also as to 3 right of privacy as well. 4 BY MR. LUTTIER: 5 Q. Did you voluntarily film yourself in a sex act 6 when you were 19 in 2007? 7 A. On advice of counsel I invoke my Fifth 8 Amendment rights, rights under the United States 9 Constitution. 10 Q. Did you gain enjoyment as a resuh of filming 11 yourself in a sex act when you were19 in 2007? 12 MR. EDWARDS: Same objection. I am 13 instructing her not to answer this line. That 14 question may not implicate the Fifth Amendment, but 15 there are privacy issues here. And until that 16 issue is resolved, l am instructing the witness not 17 to answer. 18 BY MR. LUMER: 19 Q. Did you suffer any type of injury at all as a 20 result of filming yourself in a sex act when you were 19 21 in 2007? 22 A. Nope. 23 Q. When you filmed yourself in this sex act when 24 you were 19, were any inanimate objects used? Do you 25 know what I mean by inanimate objects? 29 (Pages 113 to 116) PROSE COURT REPORTING AGENCY, INC. EFTA02726464 Page 117 MR. EDWARDS: I am instructing the witness not 2 to answer based on my previous objection related to 3 privacy issues. 4 BY MR. WI t WR: 5 Q. Why did you film yourself in a sex act when 6 you were 19? 7 MR. EDWARDS: Same objection based on the privacy issue. She's not answering the question. 9 BY MR. LUTTTER: 10 Q. Did you film yourself on a videotape with 11 this, the sex acts when you were 19? 12 A. No. 13 Q. Did you do it on a camera? 14 A. Yes. 15 Q. Was the camera hooked up to an Internet? 16 A. No. 17 Q. What type of camera Was it? 18 A. Digital. 19 Q. Did it take still shots or video? 20 A. Video. 23. Q. And did the video ever find its way onto the 22 Hemet? 23 A. No. 24 Q. Did you over post it or any frames from that 25 video of you engaged in the sex act when you were 19 on Page 119 1 content that was on there? 2 A. I, I know that on my behalf thae has been 3 pictures and everything and notes and stuff downloaded 4 from 5 Q. My question is did you do that? 6 A. No. 7 Q. Did you give your password or pass code to 8 someone so they could do that? 9 A. Yes. 10 Q. And who did you give that information to? 11 MR. EDWARDS: Object, object to the form, 12 attorney-client privilege. 13 BY MR. LUTHER: 14 Q. Did you give that information to anyone other 15 than your lawyer who is representing you in this matter? 16 MR. EDWARDS: Objection. It's attorney-client 17 privilege. And if it was given to people 18 associated with the law firm that this witness may 19 not recognize as attorney-client privilege, same 20 objection. She's not going to answer. 21 BY MR. LUTIIBR: 22 Q. Did you give that information to anyone other 23 than your lawyer or an employee of his law firm in this 24 case? 25 A. No, sir. 1 2 3 4 5 6 7 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 118 your Facebook site? A. I have never had a Facebook site, sir. Q. You are sure of that? A. Absolutely positive I have never had a Facebook site. Q Okay. Let me correct that. A. Sorry Q. You do have a site? A. As of right now, I do not. Q. But that's because somebody told you to take it down because of this litigation, right? A. No, sir. Q. As a matter of fact, you wore ordered to produce hard copies of what was on your this lawsuit, were you not? A. No, sir. Q. Did you know that you did produce it? A. That I produced what? Q. Copies of stuff off your in this lawsuit. A. Oh, I knew that actions were going on like that sI t that's not why I proceeded to erase my Q. Did you go onto your site and make copies that were produced in this case of what the site in Page 120 1 Q. Prior to the time that you gave that 2 information to your lawyer or someone that is employed 3 by him, did you remove content from your site? 4 A. I have, ever since I've had I remove 5 and I add all sorts of pictures on there. 6 Q. And when did you first start the 7 A. That was in g. 8 Q. Is there anything at all that you ever have 9 put on your site since you first opened it that 10 you find you would find now to be embarrassing? 13. A. Embarrassing? No. I mean, there are some 12 pictures that are pretty goofy. I don't, if I thought 13 it was so embarrassing, I wouldn't have posted the 14 pictures on there. 15 Q. So that it's clear for the ladies and 16 gentlemen of the jury, if they are shown content from 17 your site from the time you first opened it 18 until the present, your testimony is you don't find any 19 of that to be embarrassing. You would only characterize 20 it as goofy, some of the things; is that right? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: Personally in everybody's life, 23 people have fun. And when they go out, they have 24 hut and they do fun things and they make ukaranies. 25 Okay. I don't think anything! have ever posted on site? ANIMPali...••••••••••••441.2.2•14•4••••:••••••%•••••••41•a•Illoorttf.••••• 30 (Pages 117 to 120) PROSE COURT REPORTING AGENCY, INC. EFTA02726465 1 2 3 4 5 6 7 a 9 10 13. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 121 would be embarrassing to me, no. Everybody can see it. BY MR. LUTlER: Q. That's wasn't my question, whether everybody can see it. A. What's your question? Q. So that it's clear to the ladies and gentleman of the jury, you would not find an of ie material that's ever been posted on your ElMisite to be embarrassing? A. No, sir. MR. EDWARDS: Object, object to the form. BY MR. LUTHER: Q. Nothing on that site would have caused you any embarrassment or humiliation, correct? MR. EDWARDS: I would object, object to the form. THE WITNESS: No. For what reason? BY MR. LUTHER: Q. No, listen to my question. A. I heard your question. No, sir, is the answer. Q. No what? A. No, I do not think anything is embarrassing en the 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 123 A. Just certain pictures of me drinking alcohol and taking shots and doing stuff like that Q. Is that it, just pictures of you drinking alcohol and taking shots? Wt. EDWARDS: Object to the form. THE WITNESS: I wouldn't want my to see pictures of me when I was modeling, you know, when I was modeling- BY MR. LUTTIER: Q. What do you mean modeling A. 1 modeled for Q. And when was that? A. hill Q. And why dein you describe for the ladies and gentlemen of the jury what those pictures depict? A. Mein a posing Q. Would you say that they were sexually suggestive pictures? MR. EDWARDS: Object to the form. THE WITNESS: No, sir, I don't. I think that people try to advertise for their, you know, their Just like if you were going to buy a car, there is a sexy girl next to it. That's what Page 122 1 Q. liaion was nothing that's ever been put 2 on your site has ever caused you any 3 embarrassment or humiliation, correct? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: Not that i recall. 6 BY MR. LUTHER: 7 Q. You have never suffered one iota of damage as 8 a result of anything that appears on your site, 9 that is appears now or ever did appear on it, correct? 10 A. Not that 1 recall. 11 Q. And anything on your site or anything 12 that's ever been put on your site, would you say 13 reflects positively on you? 3.4 MR. EDWARDS: Object to the form. 15 THE WITNESS: No. 16 BY MR. LUTTIER: 17 Q. Would it be the of thing that you would 18 like your to see? 19 A. No. 20 Q. Why not? 21 A. That's not something that a 22 should see when a 21-year-old is out having a good time 23 and making mcmoties with her friends. 24 Q. Well,specifically what is it that you would 25 not want your to see? Page 124 1 1 did. 2 BY MR. LUTTIER: 3 Q. And your, you effort in doing this for 4 was to portray yourself in a sexually 5 explicit manner in order to sell correct? 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: Sure, if that's what, how you 8 want to put it. Like that's the United States. 9 Are you kidding me? 10 BY MR. LUTTIER: 11 Q. That's, that's the society and the age that 12 you grew up in, right? 13 A. I think that you grew up in it, too. 14 Q. For example, the level of chess that you were 15 in in those pictures, you do not find to be offensive, 16 correct? 17 A. No,1 would wear it to the beach 18 Q. Okay. I mean, nudity, you don't find nudity 19 to be offensive, do you? 20 A. Yeah, 1 do. 21 Q. You do? 22 A. I do. 23 Q. And when did you first find nudity to be 24 offensive? 25 A. Nudity was offensive to me when I walked into 31 (Pages 121 to 124) PROSE COURT REPORTING AGENCY, INC. EFTA02726466 Page 125 1 kffrey's house and I had to get naked for him when he 2 was on a massage table. That kind of offended me, you 3 know. 4 Q. And so what did you say to indicate that you 5 were offended? 6 A. I was nervous as hell 7 Q. No, my question is what did you say? 8 A. What did I say? I didn't say anything because 9 i was wiLi in I paid $200. I was a little girl coining 10 from a= walking into a mansion. What do you want 11 Me to say? 12 Q. Ma'am. it's not a question of what i want. 1 13 am just asking you what you did. 14 A. Well, you're talking to me like I'm stupid, 15 and i don't appreciate it. 16 Q. You went to Jeffs. This friend of 17 yours took you there, right? 18 A. Yeah. 19 Q. And she told you some things before she took 20 you there, correct? 21 A. Yeah. 22 Q Tell me what she told you. 23 A. said, hey, do you want to make $200. 24 I said yes, that would be great; how. She says, well, 25 you just have to walk upstairs, and you have to, we just Page 127 1 MR. EDWARDS: Object to the form. 2 THE WITNESS: Now, that, when a, when a — I 3 will just let you know, when a 13-year-old little 4 girl is in front of a 50-year-old man, with a lot 5 of money and a lot of power with a big house that 6 she's never saw before and that promises you that 7 he can get you stuff from Brazil, and he can get 8 you anything you want, and that you might go and 9 model some day and, oh, I'm worth so much. And i 10 he influences you and puts this all in your head. 13. Okay. 12 And he wants to see a little peak, a little 13 peak here and a little peak thae, and if he wants 14 a little touch here and little touch there because 15 he reassures you that you're going to be better 16 when you get older, I think that little brainwash. 17 Yeah, I definitely allowed him to see it because I 18 was fucking scared. 19 MR.. LUTTTER: Well, that's all 20 THE WITNESS: It's scary. 21 BY MR. LUTTIER: 22 7batlittlesoliloquyiswhatyour 23 that you've gone to since you filed the 24 lawsuit told you, right? 25 A. Not at all. Page 126 1 have to massage a guy. And I am like, okay and I am 2 like, well, how old is this guy. Oh, he is old. Don't 3 worry. He is an old guy. And the conversation pretty 4 much said, hey, you know -- I said no a couple of times, 5 and I said I really — I was uneasy about going. I 6 really don't want to go. 7 And then it escalated that I ended up going 8 because she persuaded me into it. i was a young little 9 girl that was stupid and naive and went to go massage a 10 50-year-old man naked on a flieldng massage table and got 11 paid $200 fait. 12 Q. And after that occasion that you have just 13 described, you went back how many times, 50 times? 14 A. More than 50 times. 15 Q. Each time you went back voluntarily, correct? 16 A. Voluntarily. 17 MR. EDWARDS: Object to the form. 18 BY MR. LITiTIER: 19 Q. When you wart with 1M, you went 20 voluntarily, correct? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: Yes, sir. 23 BY MR. LUTHER: 24 Q. Mr. Epstein never made you do anything against 25 your will, correct? Page 128 1 Q. By the way - 2 A. Not at all. 3 Ss - did you ever go to a or a before you filed this lawsuit? 4 5 A. Not that I mall. 6 Q. Ever in your entire life? 7 A. Not that I recall. 8 MR. EDWARDS: Object to the form, asked and 9 answered. 10 BY MR. LUTITER: 11 Q. Did you have anything traumatic happen to you 12 in your entire life before you filed this lawsuit? 13 A. No. 14 Q. Nothing ever was traumatic to you, right? 15 A. No. 16 Q. Well, let me put this way so that it's clear 17 for the jury; Anything that happened to you prim to 18 the day you filed this lawsuit you would describe as not 19 being traumatic, right? 20 MR. EDWARDS: Object to the font. 21 THE WITNESS: Nothing happened to me from when 22 1 was younger than 13 to the day l was bom that 23 was traumatic at all. 24 BY Mit LUiTiER: 25 Q. Has anything traumatic happened to you since 32 (Pages 125 to 128) PROSE COURT REPORTING AGENCY, INC. EFTA02726467 Page 129 1 you filed this lawsuit? 2 ' A. You damn right. 3 Q. What, what has happened to you since you filed 4 this lawsuit that's traumatic? 5 A. Psychologically messed me all up in my head. 6 Okay. here's, here's a young girl 13-years-old of age 7 going and taking myself every single day to a man's 8 house, okay, to show my body, to show my vagina, to show 9 my, my boobs, you how, that I hardly didn't even have. 10 Okay. 11 Andl would bring all these girls and I would 12 beg them, come on, come on, we're going to make 5200. 13 am psychologically fucked up in the head from that. Now 14 I feel so incredibly bad that 1 brought any of these 15 little girls there. It's sickening. 16 Okay. I have got to live with this for the 17 rest of my life. That man right there he has shown me 18 that later on in life, all I've got to do is show a 19 little bit of vagina and a little bit of fucking boobs 20 so I can make some money. And now for the rest of my 21 life,1 have got to try to keep from my son that his 22 mother was a prostitute to put bread and butter on the 23 table for him. 24 Q. Well, in fairness -- 25 A. So live with that. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 131 know you're wrong. You know you're wrong, because you fucking messed with us. He messed with us. He touched us. He's sick. You are disgusting. You make me throw up. Q. You weren't 13 at the time, were you, ma'am? A. Iwas 13. Iwas 14. Iwas 15. I got Q A. No, thank the Lord have mercy. Q. You had learned to engage in sexual relations with men someplace apart from Mr. Epstein, had you not? A. I had learned from Jeffreythat it was easy money. Q. Are you saying — A. Easy money. Q. -- the father of your child paid you money to have sex with you? MR. EDWARDS: Objection to form. THE WITNESS: Not at all. MR. EDWARDS: And just — objection to the form. THE WITNESS: You're sick. MR_ EDWARDS: Wait until he asks a question. BY MR. LUTRBR: Q. Now, let's go back to your site. Are 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 3.7 18 19 20 21 22 23 24 25 Page 130 Q. -- you weren't a prostitute to bread and butter on the table for your son, were you? A. Really? For years I was. Q. That's not why you became a prostitute, was it? A. Are you -- what are you trying to say here? Q. You didn't become a prostitute because you had to feed your son, did you? A. When I met Jeffrey — Q. Just answer my question, ma'am. You didn't become a prostitute because you had to feed your son, did you? A. I don't even know how to answer this. Q. That's because you know the answer is no, don't you? You were a prostitute before your son was ever born, weren't you; isn't that right? A. You're an asshole. Q. You were a -- A. You're a fucking asshole. The truth hurts, doesn't it, ma'am? The truth hurts? Right. You were a prostitute — You know what, you're fucking representing someone that took a 13-year-old little girl, many, many little girls, and took them in their house. And you Q. A. Q. A. Page 132 1 there any other pictures other than ones of you modeling 2 for a which you would not want your son to 3 see? 4 A. Of course. 5 Q. What other pictures 6 A. Is there any pictures that you wouldn't want 7 your son or daughter to see? 8 Q. Well, ma'am, actually there is not. 9 A. You are just fucking sitting here making 10 money. 11 Q. Can you answer my question now? 12 A. There is a lot of pictures that I would not 13 want my son to see. 14 Q. Which ones? 15 A. Now what? 16 Q. Which ones? 17 A. Which ones? Multiple ones. Do you want to 18 bring them out so I can point them, pinpoint them to 19 you. 20 Q. I want you to describe them for the jury. 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: 1 have already told you, the 23 pictures, ones of me taking shots. 24 13? MR. LUTTIER: 25 Q. What do you mean taking shots? Are you 33 (Pages 129 to 132) PROSE COURT REPORTING AGENCY, INC. EFTA02726468 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 133 talking about alcohol? A. Taking tequila shots. Q. Okay. You were out parting, right? A Yeah, like normal people do like you're going to probably do after this with all your flicking money. Q. And nobody was forcing you to do anything that's depicted on these photographs that have appeared on your A. Nobody forced me to do it, no. Q. And you do, of course know that eve you have ever put on =Ellis still on don't you? A. No, I don't know. Q. And you do realize that all of that is subpoenable and can be obtained? MR. EDWARDS: Object to the font. THE WITNESS: Cool. BY MR. LUTTIER: Q. Now, can you think about — A. Who cares? Q. — any particular incidents that are reflected in pictures on your site that you would find offensive to show your son? MR. EDWARDS: Object to the form Page 135 1 There is some pictures that I don't want my son to 2 see. There am some picture that, sure, he can 3 see. Now what? What is the point here? You keep 4 on asking me these questions 20 times. 5 Does this have anything to do with what you're 6 trying to get to, because I would really like to 7 know. 8 BY MR. LUTTTER: 9 Q. Which pictures would you not want your son to 10 see? 11 A. I dim There was like 450 pictures I 12 posted on 13 Q. And just so that we can understand your 14 memory, if the jury sees the pictures, so that it's 15 clear, as you sit here today, you can't describe any of 16 the pictures I dn't want your son to sec 17 other than the modeling pictures? 18 MR. EDWARDS: Hold on. 19 MR. LUTTIER: Is that right? 20 MR. EDWARDS: I would object to the form And 21 if counsel wants to show these pictures — 22 THE WITNESS: Thank you. 23 MR. EDWARDS: -- to the witness for the 24 witness to identify which ones that her son 25 would — Page 134 1 BY MR. LUTTIER: 2 Q. Other than the 3 WITNESS: No, no, no, no. 4 BY MR. LUTTIER: 5 Q. Do you remember any kind of — 6 A. No, I don't 7 Q. Any kind of — 8 A. What are you getting to? No, I don't. 9 Q. Any kind of party that you were ever at that 10 you had sites, pictures on your site about? 11 A. No. 12 Q. Did rsever -- were the-re ever any pictures 13 on your MINE site of you engaging in any type of 14 conduct with other females that you wouldn't want your 15 son to see? 16 A. Yeah, of course I would not want my son to see 17 that. 18 Q. Describe what you were doing in those 19 photographs for the jury. 20 A. I don't remember, dr. 21 Q. So, how do you know you wouldn't want your son 22 to see them? 23 A. What are you getting to? 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: What is the whole point of this. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 136 1 THE WITNESS: I agree. 2 MR. EDWARDS: — want to see and which ones 3 she does not, okay. If she can't remember every 4 picture, she's given her answer. 5 BY MR. LIMIER: 6 Q. I don't expect you to remember but I do want 7 to find out whether your memory is good enough to 8 remember any of the ones that you wouldn't want your sec to see. So, if you have told me everything that you can recall, I am happy to accept your answer. So, is there any other photographs that you can tell the ladies and t rxm of the jury that have appeared on your that you would not want your son to see? A. I just told you. There are some pictures that I wouldn't mind him looking at. Most of them arc hint Q. And did you understand my question? A. And, and some of them, I would not want him to see. Q. Tell me the ones — A. Like my attorney just said, if you want to bring me the pictures, I will pinpoint them out to you. Q. I want to know — St I have posted over 400 pictures on 34 (Pages 133 to 136) PROSE COURT REPORTING AGENCY, INC. EFTA02726469 Page 137 1 Q. Okay. So that we're clear, you can't, as you 2 sit here today remember any photographs that you would 3 not want your son to see 4 A. Yeah. 5 Q. -- other than some pictures -- 6 A. Yeah, lean, lean damn sure remember a lot of 7 them. 8 MR. EDWARDS: Argumentative. 9 BY MR. LUTTIER: 10 Q. All right, then tell me — describe the ones 11 that you don't want your son to see. 12 A. Okay. Let's go, let's start from point A. 13 Okay. i wouldn't want my son to see me partying. I 14 wouldn't want my son to see me drinkin I wouldn't 15 want my son to see me in the, in a 16 wouldn't — oh, yeah, that's right on my picture 17 1 did kiss a girl. I really wouldn't want him to see 18 that. Let me think I can't think of anymore. 19 Q. When you say partying, what do you mean? 20 A. Just dancing and drinking a lot 21 Q. Okay. And are any of the other girls that you 22 took to Mr. Epstein's house, are any of themain ured in 23 any of these pictures that you have on your 24 site? 25 A. Yeah. 1 2 3 4 5 6 7 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 139 Q. And what did you tell her about what she was going to be doing? A. I said, hey, Ill, do you want to go to this guy's house. He will give you $200 if you stand there naked. He is going to jack-off and ejaculate in his hand, and then we're going to leave. Do you want to do it. She said no. She said no a couple of times. More than a couple of times. Then I convinced her just like convinced me. Q. Did you tell her anything else? A. From what I recall, I said we're going to go make some money. We're going to walk up some pink stairs. It's a huge mansion. And there is a chef and he can make you food. And sometimes we can get, like, free, like, bikinis and stuff that Jeffrey will give us. And Jeffrey is an old man. We have nothing to worry about. We're going make $200 standing there naked. He might use a vibrator, might use his hands. Yeah, that's it Q. So, a knew exactly what was going to happen when you took her over to Jeff Epstein's house, correct? MR. EDWARDS: Object to the form. MR LUTTIER: Correct? THE WITNESS: Correct Page 138 3. Q. Who? 2 A. 3 Q. who? 4 A. 5 Q. And why don't you tell the court what your 6 relationship with a is? 7 A. We're good friends. We have been good friends for years. 9 Q Lifelong friends, haven't you been? 10 A. Lifelong. 11 Q. Would you consider your best friend? 12 A. No. 13 Q. One of your best friends? 14 A. Sure. 15 Q. And how old is she as compared to you? 16 A. She's maybe six months younger than I, or six 17 months older than I am. 18 Q. Did you go to school with her? 19 A. No. 20 Q. And did you ever take her over to 21 Mr. Epstein's? 22 A. Yep. 23 Q. At the time that you took her over there, was 24 she one of your best friends? 25 A. Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 140 BY MR. LUTi'IER: Q. You told her? A. 1 told her. Q. She went over there with eyes wide open? A. Yeah, mind you she was 14 years old. Q. How long had you been going to Mr. Epstein's? A. Only a couple of months. Q. Before you decided to invite your friend over? A. Yep. Q. And then did you tell your friend Ng that you were going to get paid money to take her there? A. Yep. Q. When did you tell her you were getting paid money to take her there? A. When did I tell ha? Q. Yeah. A. I told her — when did I tell her? I told her the first time I told her about Jeffrey. Q. So, the first time that you told your friend Caroly W. and asked her to go to Mr. Epstein's, you told her at the same time you were going to receive money as a result of taking her there; is that correct? MR. EDWARDS: You're talking about right? MR. LUTIIER: Pm sorry. 35 (Pages 137 to 140) PROSE COURT REPORTING AGENCY, INC. EFTA02726470 Page 141 1 MR. EDWARDS: Okay. 2 THE WITNESS: From what I recall. Maybe I 3 told her I was making money. Maybe i didn't. 4 BY MR. LUTTIER: Q. Which was it? 6 A. I don't know. I forgot. 7 Q. It would be an, an event that you would 8 remember since it was one of your best Mends that you 9 were doing this with, right? 10 MR. EDWARDS: Object as to the fora 11 argumentative. 12 THE WITNESS: I brought every girl I could 13 End because it was an extra S200. 14 BY MR. LUTTIER: 15 Q. And you didn't think there was anything wrong 16 with it, right? 17 A. Oh, I knew there was definitely something 18 wining with it 19 Q. All right So, you consciously knew that you 20 shouldn't be doing what you were doing; is that a 21 correct statement? 22 A. Correct. 23 Q. You did it anyway, right? 24 A. Correct. Obviously just tike all these other 25 girls did, isn't that funny. Page 143 1 couldn't afford, the new things that were out, you know, 2 so I could be the cool kid. I would buy whatever was, 3 was cool that day. 4 Q. And where did you bank? Where did you put 5 this money that you saved? 6 A. Ina hiding place in my house. 7 Q. So, you didn't put it in a bank? 8 A. I was 13 years old. No,1 didn't put it in a 9 drum bank. 10 Q. And when you say a hiding place in your house 11 which houserou referring to? 12 A. In y 13 Q. At your fkther's? 14 A. Yeah. 15 Q. And did you tell your dad about it? 16 A. No, not at the beginning. I told my dad that 17 1 was cleaning houses later on. 18 Q. And was that a true statement? 19 A. No. 20 Q. So you lied to your father? 21 A. Yeah. 22 Q. Did you tell. anything else before you 23 took her to Mr. Epstein's house the fast time? 24 A. Not that I recall I said we're going to go 25 there in a taxi. Everything will be paid for. Page 142 1 Q. It was your free choice though? 2 A. Yeah, free choice. 3 MR. EDWARDS: Objection. 4 BY MR. LUfl1ER: 5 Q. And it was free choice to dolt? 6 A. Yeah. 7 Q. And she did it wide open because you told her 8 exactly what was going to happen? 9 A. Oh, yeah, it was so easy, let me tell you. 10 Q. And it was, it was — and you did it for the 11 money, is that right? 12 A. At that time, yes, I did, after walking into 13 his mansion. And after my dad, he had to only buy me 14 Dollar Store clothes, you drum right I did it for the 15 money. 16 Q. Did you share with or.. any of the 17 money that you got paid by Jeff Epstein for bringing 18 ha? 19 A. No, not that l recall 20 Q. So, you just kept that money. What did you do 21 with the money that you got from Jeffrey Epstein to 22 biing 23 A. I actually saved a lot of it. I would save a 24 lot of it, and i would buy clothes, clothes that I 25 didn't have. I would buy shoes, shoes that my father Page 144 1 Everything would be taken care of. Don't worry. It's a 2 quick 30 minutes. We will be in and out. We're going 3 to make $200. 4 Q. Each? 5 A. Each. 6 Q. Right. And did you tell her anything about, 7 anything she should say about her age? A. Not that I recall. I said just don't say 9 anything. 10 Q. What do you mean? I don't understand what you 11 mesa. 12 A. I said don't say anything. 13 Q. Don't say anything about what? 14 A. Don't say anything about your age. 15 Q. Oh, so you did say something to her about age? 16 A. Yes. 17 Q. All right. Tell me as best as you can recall 18 what you told-- 19 A. I said.. -- 2o Q. Wait a minute. Let me finish my question — 21 what you told with respect to any questions asked 22 about age? 23 A. I said N., don't say anything about your 24 age. 25 Q. Did you say why? 4333.3. , 3“J..+.1.33WORMINIIM.33.3.3a.•;33333.3 3.3 4.3...{..• 36 (Pages 141 to 144) PROSE COURT REPORTING AGENCY, INC. EFTA02726471 Page 145 1 A. Well, I said we're not over 18, and this is 2 like really bad. This is like really illegal. We're 3 not supposed to even be here, so don't say a damn thing 4 about your age. 5 Q. Anclimsaid all of the things that you just 6 said here ton.. before she went to Mr. Epstein's the 7 first time? 8 A. Yes, sir. 9 Q. You, according to you then, you knew at least 10 at that point in time, or were of the belief that what 11 you were doing was illegal? 12 A. Yes. 13 Q. But you did it anyway? 14 A. Yeah, because I am the bad guy, right? 15 Q. Actually, at that point in time that you first 16 went to Mr. Epstein's, had you done other illegal 17 things? 18 A. No. 19 Q. None at all? 20 A. I smoked weed. 21 Q. That was the only other illegal thing you had 22 done? 23 A. Yeah. I smoked weed. 24 Q. Okay. And what, if anything, did you tell 25 M. about Mr. Epstein himself before you took her to Page 147 1 shirt off and you have your panties off. I didn't say 2 anything about being -- how comfortable are you when 3 you're naked in front of a 50-year-old man? I didn't 4 say anything about her being comfortable, xou know, 5 just be comfortable, be comfortable naked,M. What do 6 you want me to say? 7 Q. Did you tell her anything about Mr. Epstein 8 not being an individual that would request her to do 9 anything that she wasn't comfortable doing? 10 A. No, I didn't say anything like that. I said, 11 I did say everything is going to be okay. 12 Q. You didn't say any words to the effect of -- 13 because I don't want to attempt to quote exactly -- 14 that, that Mr. Epstein never asks anybody to do anything 15 they don't want to do? 16 A. No, I just brought her there. 17 Q. — or words to that effect? 18 A. No. 19 Q. Did you convey that message to her in any 20 manner before you took her there? 21 A. No. I said let's go. Don't worry. We're 22 going to make $200. We'll be in and out. 23 Q. And in fact, Mr. Epstein never forced you to 24 do anything that you didn't agree to do, did he? 25 A. Nope, but we were — you know, he pushed on Page 146 1 his house? 2 A. I said oh, my God, this gay is so rich. He 3 has so much money. Oh, you're not going to believe this 4 house when you see it. Ws absolutely gorgeous. Oh, 5 he has, he like lives right on the water. He lives on 6 the Palm Beach Island which is like really expensive. 7 And I was very intimidated. !just told her how 8 wonderful his house looked and how, how much money he 9 had. 10 Q. Did you tell her anything about whether or not 11 Mr. Epstein was respectful? 12 A. I said, yeah,1 was like don't worry. He is, 13 he is an easy-going guy. He will give us our money and 14 we will leave. 15 Q. Did you tell him anything did you tell her 16 anything about whether or not she had no worry that if 17 she didn't want to do anything, that Mr. Epstein 18 wouldn't push her or ask her to do anything she wasn't 19 comfortable with? 20 A. I said just, I said do what you want. Do, you 21 know, be as comfortable as you want to be. I didn't 22 want to make her feel uncomfortable or she wouldn't go. 23 Q. Did you tell her that Mr. Epstein wouldn't ask 24 her to do anything that she wasn't comfortable doing? 25 A. I said, listen, he films when you have your •2•40.4fetmblthiakedeam.I., Page 148 1 it. He pushed on us. Like if, for instance, when he 2 was on the table and his penis, he was, it was out. He 3 was naked. He would pull my hand towards -- this is his 4 penis. He would pull my hand towards his penis and say, 5 oh, just come on, come on. And I would be like no, no, 6 because T wasn't comfortable. I would say no. 7 Q. Do I understand your testimony from this 8 morning, you never touched his penis? 9 A. I never touched his penis, but he would pull 10 his hand, my hand towards his penis. 11 Q. And when you said you were uncomfortable, that 12 stopped? 13 A. Yeah. 14 Q. When you first went to Mr. Epstein's, the 15 first time you went, . was there -- I mean this 16 friend of yours, , was there with you? 17 A. Uh-huh. Yes. 18 Q. What did she tell you before you went there 19 about what Mr. Epstein was like? 20 A. She said, hey, there is a 50-year-old or 21 whatever old man on, in this huge, in this huge mansion 22 and we can make 5200. So, do you want to go? All we've 23 got to do is massage him And I was very scared. And I 24 was, like, are you kidding me, like I am scared. But 25 she convinced me into doing it and I went there. 37 (Pages 145 to 148) PROSE COURT REPORTING AGENCY, INC. EFTA02726472 Page 149 Q. Did she tell you anything to the effect that, 2 don't worry, Mr. Epstein will never ask you to do 3 something you're not comfortable doing? 4 A. She said don't veony, I will handle things. 5 She said don't worry. Just, you know, we're going to be 6 safe. She did say that we're going to be safe because I 7 was very concerned about that. 8 Q. What did she mean by -- 9 MR. EDWARDS: Object to the form. 10 BY MR. LUTTIER: 11 Q. — when she said we're going to be safe? 12 MR. EDWARDS: Same objection. 13 THE WITNESS: That we're obviously not going 14 to get hurt. 15 BY MR. LUTHER 16 Q. Okay. And do you know — what was she talking 17 about, physically banned? 18 A. I guess that's the way interpreted it when I 19 was 13, sure. 20 Q. Did she say anything to the effect that you 21 won't have to do anything you don't want to do? 22 A. No. She just told me, go in there. Take my 23 shin off. Take my pants off. He likes his legs 24 massaged, his arms, legs, back, scalp massaged, and he's 25 going to ejaculate. He is going to masturbate and Page 151 1 A. I did not voluntarily take my top off the 2 first time. 3 Q. Did you ever tell any of your friends that you 4 had gone to Mr. Epstein's and voluntarily removed your 5 top? 6 A. Did I say that I — 7 Q. That you voluntarily, you went and took your 8 top off without even being asked? 9 A. Not the first time. The first time I did not 10 voluntarily do anything. He directed me. 11 Q And eas standing right there with 12 you; is that right? 13 MR EDWARDS: Objection to the form. 14 MR LUTIIER: I mean 15 THE WITNESS: No, not — MR LUTHER: Wait, 16 whatever — 17 THE WITNESS: Get your story straight 18 MR. LUTlIER: Whatever the last name was. 19 was there — 21 to me and then she le the room and she said just 20 THE WITNESS: was sitting there next 22 listen to Jeffrey. He will tell you what to do. 23 BY MR. LUTHER 24 Q. You mentioned earlier today that on the cover 25 of these books that you kept, these diaries, there was a was Page 150 1 ejaculate, and then you get paid and you're out there. 2 Q. So, you knew all of that before you went the 3 first time? 4 A. Uh-hub, yes. 5 Q. And according to you, you were asked by her on 6 more than one occasion to go initially and you said no? 7 A. !said, I said no. I was scared, yes. 8 Q. Somehow you decided you weren't scared any 9 longer and you decided to go? 10 MR. EDWARDS: Object to the form. 11 BY MR. LUTHER: 12 Q. Is that right? 13 A. Yes. 14 Q. When you went the first time, did you 15 voluntarily take your top off/ 16 MR. EDWARDS: Object to the form. 17 THE WITNESS: He asked me — no, because I 18 remember exactly what I was wearing. I was wearing 19 a red shirt that had lute a half sleeve on it, and 20 some jeans. And I didn't know what the hell to do. 21 And he said, okay, girls, you guys can, you guys 22 can get undressed now. 23 BY MR. LUTHER: 24 Q. So, you deny that you voluntarily took your 25 top off the rust time? Page 152 1 Bible verse. Were these books that you kept books that 2 were acquired with the Bible verse on it, or was this 3 something you put on it? 4 A. It was there already. 5 Q. Was this a book that you got from some 6 religious place? 7 A. Yes. 8 Q. Where did you get the book? 9 A. I don't recall. 10 Q. Did you buy the book or did you get it some 11 other way? 12 I bought the book 13 And what verse was on the cover? 14 Psalms something. 15 What Psalm? 16 I don't know. 17 You don't remember? 18 No. 19 Do you remember where you bought it? 20 No. 21 Do you remember why you bought it? 22 To keep a journal. 23 A journal of what? 24 Of my life. 25 a So when did you start this book? A Q. A. Q. A. Q. A. Q. A. A. Q. A. 38 (Pages 149 to 152) PROSE COURT REPORTING AGENCY, INC. EFTA02726473 Page 153 1 A. When I started making a lot of money. 2 Q. Which was when? 3 A. When I started working 4 Q. What do you mean by 5 A. I told you this before, places where 6 men go to receive sexual favors. 7 Q. This was after you had gone to Mr. Epstein? 8 A. Yes. 9 Q This was after you had quit going to 10 Mr. Epstein, wasn't it? 11 A. Yes. 12 MR. EDWARDS: Objection to the form. Just for 13 clarification, do you mean after she quit going the 14 first time or after — 15 MR. LUTI1ER: No. 16 MR. EDWARDS: the last time, the last time 17 she ever saw him? 18 MR. LINDER: No, period. She knew what I 19 meant. After she quit going to Epstein's. 20 BY MR. LUTTIER: 21 Q. And is there some particular reason why you 22 purchased this particular book with this particular 23 verse on it to do this? 24 A. No. 25 Q. You have no recollection at all where you got Page 155 1 A. Until now? 2 Q. Yes. 3 A. It's somewhere. I don't know. It's 4 somewhere. I mean -- 5 Q. You have already testified earlier this 6 morning that you had it and you knew where it was, so -- 7 MR. EDWARDS: Object to the form. THE WITNESS: Okay. Well, its somewhere in 9 the house. 10 MR. LUTTIER: Okay. 11 THE WITNESS: I don't know if it's in the damn 12 kitchen or in the — you need to -- you're making 13 me angry. I don't know, just the way you're 14 looking at me, the way he is looking at me, staring 15 at me like Pin the criminal. 16 MR. LUTTIER: Ma'am -- move to strike. 17 THE WITNESS: I guess that's what you get paid 18 for. I'm sorry. 19 MR. LUTTIER: Move to strike the soliloquy. 20 BY MR. LUTTIER: 21 Q. When was the last time you made an entry in 22 that book? 23 A. Oh, I believe I only had it for the year of 24 4 And the last time I ever opened it and made an 25 entry in it was probably in 1. Page 154 1 this book? 2 A. No. 3 Q. But you 'mow you bought it? 4 A. Yes. 5 Q. And do you, can you recite any of this verse 6 that you say is on it? 7 A. No. 8 Q. I ran Psalms is kind of a big book? 9 A. Correct 10 Q. And you can't remember anything about what it 11 is? 12 A. No. It said the verse. It said Psalms 13 something, something. It didn't say, literally say the 14 verse. 15 Q. The verse wasn't printed out. 16 A. No. 17 Q. It was just a citation to a verse in the book 18 of Psalms? 19 A. Yes. 20 Q. And you never looked up the verse to see vilat 21 it was? 22 A. No. 23 Q. From the time you first began keeping that 24 book, did you continue to keep that book right through 25 the present time? Page 156 1 Q. Did you describe in that book events that 2 happened in your life that you thought were of 3 significance? 4 A. No. I kind of lived a second life so I would 5 never do that. 6 Q. What do you mean you lived a second life? 7 A. Well, I lived a life as a prostitute, and I B lived a life as a mother as well, so — 9 Q. So, how does that relate to my question about 10 whether or not you -- 11 A. You asked me how did I live a second life. I 12 am mother when I go home. I am a prostitute when I mak 13 money. That's like two different lives. Okay. So I 14 kept one secret from the other. 15 Q. Well, then my question was did you record in 16 the book significant events that occurred in your life? 17 A. Significant events, like what is significant 18 to you? 19 Q. Well, since you're the one putting the entries 20 in the book, I guess you would make that determination. 21 A. The answer it no. 22 Q. Did you record any events that occurred to you 23 in your life in that book? 24 A. Yes. 25 Q. What events did you record? 39 (Pages 153 to 156) PROSE COURT REPORTING AGENCY, INC. EFTA02726474 Page 157 1 MR. EDWARDS: Don't answer. We're invoking 2 her Fifth Amendment right to remain silent. If you 3 want, she will read it. In addition she's in, we 4 arc resting on our privacy rights objection as well 5 as the objection to privacy of third parties. Go 6 ahead. 7 THE WITNESS: On advice of counsel, I invoke 8 the Fifth Amendment rights under the United States 9 Constitution. 10 BY MR. LUTHER: 11 Q. You earlier said that in the year I. some 12 days you made a thousand dollars a day, some days you 13 made $2,000 a day. How many days out of the year would 14 you say you made a thousand dollars a day or more in the 15 year 16 A. 1 don't know. 17 Q. Well, what's your best approximation? 18 MR. EDWARDS: Object to the form. 19 THE WITNESS: I don't know. 20 BY MR. LU'TTIER: 21 Q. More than 50? 22 A. i don't know, sir. 23 Q. More than 100? 24 A. I don't know, sir. 25 Q. And this is — these are events that would Page 159 1 question has turned into $2,000 a day. 2 BY MR. LLTITIER: 3 Q. If you made more than $1,000 in a day, how 4 many hours are you referring to as a day? 5 A. Sometimes it could be 10 minutes. Sometimes 6 it could be 24 hours. 7 Q. When you say it was 24 hours, that suggests to 8 me that your workday involved you keeping the company o 9 someone for an entire 24-hour period; is that right? 10 A. Sometimes. 13. Q. And did you do that in town or did you travel 12 to do that? 13 A. In town and travel. 14 Q. Did you ever engage in any of those activities 15 with any of the girls that you had come to !mow from 16 either taking them to Mr. Epstein's or knowing them from 17 Mr. Epstein's? 18 MR EDWARDS: Don't answer. And I am 19 invoking -- I am objecting based on privacy rights 20 of a as well as these third parties you are 21 referring to, and as well as the Fifth Amendment. 22 She will read. 23 THE W/TNESS: On advice of counsel, I invoke 24 my Fifth Amendment rights under the United States 25 Page 158 1 have happened less than 12 months ago, but you, as you 2 sit here today, your recollection is not good enough for 3 you to answer that; is that correct? 4 MR. EDWARDS: Object to the form. If you 5 know, tell him. I don't want you to guess. 6 THE WITNESS: I'm not guessing. 7 BY MR. LUTTIER: 8 Q. I'm not asking you to guess. Don't want you 9 to guess. Tell me what your best estimate is. 10 MR. EDWARDS: That's the same thing as 11 guessing and I am instructing her not to guess. If 12 you }mow, tell him though. If you do not ;mow, 13 don't. Object to the form. 14 MR. LITITIER: Let's not have speaking 15 objections. 16 MR. EDWARDS: I apologize. 17 BY MR. LUTHER: 18 Q. Was it more than ten? 19 A. Maybe. 20 Q. More than 20? 21 A. Maybe. 22 Q. And by then, by when you made like $2,000 in a 23 day, how many hours arc you referring to as a day? 24 MR. EDWARDS: Object to the form. The 25 question dealt with $1,000 a day. And now this Page 160 1 THE VIDEOGILAPHER: Excuse me. You're 2 microphone got turned inside out here. 3 BY MR. LUTTIFR: 4 Q. Before lunch you testified that you would sit 5 naked in front of Mr. Epstein. Do you recall that 6 testimony? 7 A. Yes. 8 Q. Is this, was this the first occasion that you 9 went to sec Mr. Epstein? 10 A. Where I sat in front of him naked? 11 Q. lih-huh. 12 A. No. The first occasion when I saw Jeffrey, I 13 stood in front of him naked. 14 Q. Okay. And did each time that you went to see 15 Mr. Epstein or you went to his house, did you actually 16 go into a room and perform massages with Mr. Epstein? 3.7 A. Yes. 18 Q. Were there occasions when you went to his 19 house and you didn't perform massages on Mr. Epstein? 20 A. Yes. 21 Q. And what (tensions were those? 22 A. When I was bringing another girl to perform 23 massage on Mr. Jeffrey Epstein. 24 Q. Did there come a time that, that Mr. Epstein 25 didn't, or that you didn't perform massage on 40 (Pages 157 to 160) PROSE COURT REPORTING AGENCY, INC. EFTA02726475 Page 161 1 Mr. Epstein? 2 A. No, that was the whole point. 3 Q. So, you performed massages on Mr. Epstein 4 right up until when? A. 'performed? 6 Q. That's what 1 asked, yeah. 7 A. He didn't like anybody pregnant. So, I had to 8 stop seeing Mr. Jeffrey Epstein after I had my son. 9 Q. Well, after you had your son, you wouldn't 1 0 have been pregnant, right? 11 A. He didn't want women or girls sorry, he 12 didn't want girls that had aldd at all. That was a big 13 no-no - 14 Q. Weft, so -- 15 A. — in his book. 16 Q. So, is it your testimony that while you were 17 pregnant you went to Mr. Epstein's and performed 18 massages? 19 A. When I was pregnant, I brought girls to 20 Jeffrey Epstein's house to perform sexual acts. 21 Q. Did you perform massages on Mr. Epstein while 22 you were pregnant? 23 A. No. 24 Q. So, do you remember when you got pregnant? 25 A. Yeah. Page 163 1 Q. What year was that? 2 A. I don't kno r. Itom you I an bad with 3 math, and I am not gang to do the subs so you can sit 4 there and do he math was born MEM. When I was 5 17 i area, that's the last time 1 6 saw Jeffrey Epstein hat's the last time I entered his 7 mansion. 8 Q. The fact of th matter is you don't know when 9 the last time was t t ra went, do you? 10 A. I don't kno e specific date or the month or 11 the day, ta 1 don't. 12 An I know my mm w 13 14 Q. Between 15 and when you clai ou went for the last time, did you 16 not perform any ges during that period? 17 A. No. 18 MR EDWARDS: Objectto the form. 19 MR LUTY RI No, meaning — 20 THE S: He doesn't like pregnant girls. 21 He doesn't like gjr s who have had babies. 22 BY MR. LUTTIE 23 Q. Okay. So period of time over which, 24 according to you, you performed mas& 25 Mr. Epstein was time in late untih when You PAM Page 162 1 Q. 2 A. 3 Q. 4 5 Q. 6 A. 7 8 Q. Of whati ? A. 9 Q. Okay. So, from M, and when do you 10 say was the last time you went to Mr. Epstein's? 11 A. 1 personally lace went there? 12 Q. Yeah. 13 A. Just even if I brought a girl? 14 Q. Right. 15 A. l brought, 'brought girls them after I was, 16 after I had my son. So, I was 17 the last time I went 17 to Jeffrey's house. 18 Q. My question was when was the last time you 19 went? 20 A. I was 17. 21 Q. Well, you're 17 for 12 months. When was the 22 last time you went? 23 A. Well, 24 Q. Of what year? 25 A. Whatever year I was 17. When was that a xirnately? That west' AA.= So that's — So 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 164 MR. EDW) MR. L THE WTTN for him? MR. nv • Massages or whatever you did. THE S: Yes. BY MR. Q. The first t' you went was sometime in the summer of., a rding to you; is that right? A. Yes. Q. And between the summer of II andliall II, you can't tell ow many times you went, right? A. Oh, I can dfnitely tell you it was over — 1, I personally went vex 50, over 60, over 70 times. Q. Well, whit, is it 50, 60, or 70? A. I would sa 70. Q. All right. And what's that based on? A. That's based on the girls that 1 brought. I know that I brought ver 70 girls. Q. It's now 70 that you brought. Have you ever — A. I have brought many, many, many girls. Q. Have you 1...ked at your answers to interrogatories to see what you said under oath about S: Object to the form. : Is that right? ≥: When I performed sexual favors 41 (Pages 161 to 164) PROSE COURT REPORTING AGENCY, INC. EFTA02726476 Page 165 I. the number of girls that you brought? 2 A. What, at the last whatever it was? What is 3 this called? 4 Q. Your number keeps getting higher as the case 5 goes on, doesn't it? 6 A. Sir, are you talking about the last — what is 7 it called — deposition that I took for Jeffrey? 8 Q. No, I am talking about your answers to 9 interrogatories. 10 A. What's my answers — I don't know any of these 11 slick words that you guys use as attorneys, so can you 12 please explain to me in like — 13 Q. These would be the things that you signed 14 under other as being true. You, you would pay attention 15 to a document if you were siring it under oath, 16 wouldn't you, to make sure it was true? 17 A. Yeah, but if it's in fear for my son, I will 18 do anything I can. 19 Q. Well, while you have been represented by 20 Mr. Edwards, you haven't had an fear for your son, have 21 you? 22 A. Brad Edwards, no, I have not had any fear of 23 my son. 24 Q. So, anything you have signed since you have 25 been represented by Mr. Edwards under oath is something Page 167 1 don't know. When the discussion comes up and they see 2 him on the news, you know, I have told a couple of 3 people. I can't recall their names. 4 Q. You don't know -- I have got.. and your 5 mother. Who else did you tell that you kept a list of 6 how many times you went to Mr. Epstein's? 7 A. I can't recall. Maybe you can ask 8 Mr. Epstein. He would know. 9 Q. No, we're talking about the list you said you 10 kept. And my question is -- 11 A. Oh, sorry. 12 Q. -- how many people you told you kept the list 13 of the number of limes you went to Mr. Epstein's. So 14 far you told me.. and your mother. Who else? 15 A. I can't recall. 16 Q. You can't recall anybody else? 17 A. No, I'm sorry. 18 Q. How about dad? Did you tell dad? 19 A. No, I didn't tell my father. Q. How about other friends of yours? 21 A. Yeah, but I can't recall who -- 22 Q. Can't recall anybody? 23 A. Who I mean, it really was like, it was like 24 irrelevant. You blow, okay, I brought over 60, 70 girls 25 there. Page 166 1 that you carefully looked at? 2 A. Carefully. 3 Q. And made sure it was true? 4 A. Yeah. 5 Q. And you told the whole truth? 6 A. Whole truth, nothing but the truth. 7 Q. Nothing but the truth. 8 A. So help me God. 9 Q. Didn't omit, didn't omit anything, right? 10 A. I didn't leave anything out. 11 Q. Okay. Now, do you have any record of how many 12 times you went? 13 A. No. But at one point in time I did, and I 14 don't have that anymore. But I used to keep lists and 15 lists of girls and I would just go in order. 16 Q. Have you ever told anybody before today that 17 you ever kept a record of how many times you went to 18 Mr. Epstein's? 19 A. Yes. 20 Q. Who did you tell? 21 A. I have told many people. 22 Q. Who? 23 A. I have told. 24 Q. Okay. Who else? 25 A. T have told. I have told my mother, and I Page 168 1 Q. What happened to this list that you kept of 2 the number of times that you went to Mr. Epstein's? 3 A. It's misplaced. I have no idea where it is. 4 Q. What do you mean by misplaced? 5 A. !wish I knew where it was so I could get all 6 those little girls justice. Sorry. I don't know. 7 Misplaced, do you know the definition of misplaced? Q. No, but 1 want you to define it What do you 9 mean by misplaced? 10 A. Misplaced, that means like, you know, when you 11 lose stuff, like, oh, my God, I accidently lost this 12 paper. You know. 13 Q. And do I understand there were two lists. One 14 was the number of times you went to Mr. Epstein's and a 15 second list was a list of the names of the people that 16 you took? 17 A. No, it was specifically the girls and the 18 girls' numbers, and there was many, many, many girls on 19 there. 20 Q. So, it was a list of names and phone numbers? 21 A. Yes. 22 Q. Didn't reflect the number of times that you 23 took these people? 24 A. I took each girl there over that many times, 25 over -- I took each girl either once or twice, or if he 42 (Pages 165 to 168) PROSE COURT REPORTING AGENCY, INC. EFTA02726477 Page 169 1 really liked than, I took them three times. But I took 2 each girl. If I had a, if I had a notepad of 85 girls, 3 I took those girls. Those were the girls that I have 4 took. So, when I was done with those 85, 'could caft 5 the first one up and say, hey, do you want to go to 6 Jeffrey's; he needs to see a new vagina. 7 Q. The — is that what you told him? You called 8 them and told them, before you took them, do you want to 9 go to Jeffrey's; he needs to see a new vagina? Is that 10 what you told them? 11 MR. EDWARDS: Object to form. 12 THE WITNESS: I told them, hey, he wants to 13 see a new face. He doesn't like seeing the same 14 little girl every day. 15 BY MR. LUTITER: 16 Q. Well, did you tell them that he wanted to see 17 a face or wanted to see a vagina? 18 A. I said face. 19 Q. So, you misspoke earlier when you said that 20 what you told him was he wants to see a new vagina? 21 A. I didn't misspeak or spoke at all. They knew 22 what he wanted to see. They didn't just go there and 23 say, hey, I am here, Jeffrey Epstein. They took their 24 fucking pants off, and they said, here, pay me 5200. 25 Q. So, every girl, your testimony is every girl 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 She's not as comfortable as others are. Q. So, you would call another girl on list and specifically tell her not only what was happen, but you would tell her that someone before her had gone and wasn't comfortable? MR. EDWARDS: Object to the form. BY MR. LUTTIER: Q. Naha A. No. MR. EDWARDS: Object to the form. THE WITNESS: I would say — I would call -- I knew the girls who were comfortable. And then a lot of girls weren't comfortable. BY MIL LUTTIER: Q. Well, how did you know who was comfortable? A. Because when they went, they would tell me. Q. Oh, so, some of the girls came and they specifically told you they were comfortable with whatever occurred; is that right? A. They didn't tell me they were comfortable. MR. EDWARDS: Object to the form THE WITNESS: They said, you 'mow -- BY MR- LUTITER: Q. But you just told me that. A. !can maybe do this again, but the thing is is Page 171 your going to Page 170 1 that you took there knew exactly what was going to 2 occur? 3 A. Some didet because!,! would lie to them and 4 I would say, hey, you know, he is not really going to de 5 anything. You don't really need to take your clothes 6 off, you know, just to get them there. But once they 7 were there, they were scared out of their mind. They 8 did it anyways and some of them walked out. Some of 9 them did it, did the action and walked out and said I., 10 don't ever do this to me again. That was the worst 11 thing that ever happened in my life. 12 Q. Have you eva told anybody prior to today that 13 anyone you took there ever said such things to you? 14 A. Yes. 15 Q. Who have you told that to? 16 A. I have told than to - 17 MR. EDWARDS: Objection, attorney-client 18 privilege. 19 BY MR. LUTITER: 20 Q. Other than your lawyer, who have you made that 21 statement to? 22 A. !have made it to many of the girls. All the 23 girls who I have brought, I would get on the phone with 24 them, and I would say, hey, so-and-so, you know, never 25 wanted to go again. She had a really bad experience. ••••••••mze.uoa.......4. Page 172 1 that Jeffrey didn't like seeing the same girl again. 2 Q. Well, wait a minute. 3 A. He wanted to see one girl. 4 Q. Wait a minute. You just said, and I can have 5 her go back and read it 6 A. Okay. Go ahead. 7 Q. But you just said that the way you knew they 8 were comfortable was they told you they were 9 comfortable. Is that a true statement? 10 A. They were -- yeah, they were more — 11 Q. It is a true statement? 12 A. Yes. 13 Q. Okay. Which ones told you after they went 14 there that they were comfortable? 15 A. Couple of them. I can't name their names. 16 Q. Okay. Well, you said you referred to a list 17 of 85 people, and so I am sure you can remember some 18 names fix us. Which ones — 19 MR. EDWARDS: Object to the form. 20 MR. LUTTD3R: -- told you they were 21 comfortable. 22 THE WITNESS: My attorney knows some names. 23 MR. EDWARDS: Object to the form. 24 BY MR. IMITIER: 25 Q. Which ones told you they were comfortable? -••••••}4•••••••••4 43 (Pages 169 to 172) PROSE COURT REPORTING AGENCY, INC. EFTA02726478 Page 173 1 A. Obviously go She was comfortable because 2 *she went there a couple more times. 3 Q. Did you say a couple more times? 4 A. Actually-- 5 Q. Is that what you said, a couple? 6 A. She went there many times. I don't know 7 Q. Did I hear you say that she said she went 8 there a couple of times? 9 MR. EDWARDS: Object to the form, 10 argumentative. If you want to describe what you 11 mean — 12 THE WITNESS: A lot of these girls -- 13 MR. EDWARDS: -- say it. 14 THE WITNESS: Listen, all of these little 15 girls, we weren't like so comfortable, like, yeah, 16 let me go take my clothes off in front of a 17 50-year-old pervert No, they weren't comfortable. 18 They just dealt with it so they could get $200 in 19 their pocket. 20 BY MR. LUTITER: 21 Q. Well, did you — unless I misunderstood what 22 you said, you just got done testifying that these girls 23 told you they were comfortable? 24 A. You are being slick right now. You know what, 25 when I say comfortable, you know 1 am not saying that a Page 175 1 THE WITNESS: You know, this girl, she did not 2 feel, she did not feel comfortable doing this. Or 3 I would say, yeah, you know, she felt okay with it. 4 Shell go again because, you know, she can make $200. But the point is, is that Jeffrey didn't see 6 girls. He only saw certain girls over and over and 7 over again. Okay. He didn't care to see the same 8 girl a second time. He only wanted to see a little 9 girl one time, and he was — 10 MR. LUTTIER: Move — 11 THE WITNESS: happy and fun with it. 12 NHL LIMITER: Move to strike as not 13 responsive. Would you read back the question that 14 I asked her. 15 And would you listen carefully and answer my 16 question, please. 17 THE WITNESS: You're disgusting. 18 MR. EDWARDS: 19 THE WITNESS: Absolutely. 20 MR. EDWARDS: Try to answer his question. If 21 you need to elaborate, you can, but answer the 22 question. 23 THE WITNESS: I hope your daughter — I hope 24 you have — do you have a daughter? If you do -- 25 MR. LlIffIER: I am not being deposed. Page 174 1 13, 14, 15 year old girl is saying, oh, so 2 comfortable, let me just take my damn clothes off in 3 front of a 50-year-old man. 4 Q. Well, in fact, you have told others 5 specifically that you were comfortable with everything. 6 A. You're a good attorney, I will tell you. 7 Q. Isn't that right? 8 A. You're a joke. 9 Q. Haven't you told others, specifically -- 10 A. Specifically, okay, I will tell you -- 11 Q. That you were comfortable -- well, let me 12 finish 13 A. -- the conversation. 14 THE COURT REPORTER: One at a time. 15 BY MR LUTTIER: 16 Q. One at a time. You have specifically told 17 others that you were comfortable with everything that 18 happened between you and Jeff Epstein, haven't you? 19 A. I said when I would get on the phone with 20 them - 21 Q. Yes or no. 22 A. When I would get on the phone with them- 23 Q. Yes or no. 24 A. I would say, hey. 25 MR. LUTTIER: Move to strike. Page 176 1 THE WITNESS: If you do, I hope that she finds 2 out exactly what you are doing and who you are 3 defending later on in life. 4 MR. LUTTIER: That would be unprofessional for 5 me to respond to your remarks. 6 THE WITNESS: It's unprofessional for you to 7 do this — 8 MR. LUTHER: I don't — 9 THE WITNESS: — actually, and moral-wise. 10 MR. LUTTIER: I don't, I don't take offense 11 with anything you say. 12 THE WITNESS: I know you don't, because you're 13 just making money sitting on your ass sticking up for, sticking up for a child molester. What a good 15 MI you are. 16 (The requested portion of the record was read 17 by the reporter.) 18 THE WITNESS: Yes. 19 BY MR. LUTTIER: 20 Q. How many people have you told -- 21 A. I don't know. 22 Q. - that you were comfortable? More than ten, 23 isn't it? 24 A. No. 25 Q. What did you tell your mother about it? 44 (Pages 173 to 176) PROSE COURT REPORTING AGENCY, INC. EFTA02726479 Page 177 1 A. I told her that, actually, I really truthfully 2 did not tell her anything. She doesn't know anything. 3 I would keep stuff from her. 4 Q. Let me see if I, if I understand your answer. 5 Are you telling us that as you sit here today, your 6 mother doesn't know anything about you going to 7 Mr. Epstein's? 8 A. Yeah, especially after the fact. After the 9 fact, she does. 10 Q. Listen to my question. Are you telling us as 11 you sit here today that your mother doesn't know 12 anything about you going to Mr. Epstein's? 13 MR. EDWARDS: Does or doesn't? 14 MR. LUITIER: Does not know anything about you 15 going to Mr. Epstein. 16 THE WITNESS: Yes, she does. 17 BY MR. LUTHER: 18 Q. As a matter of fact she's told you people have 19 come and talked to her about it, hasn't she? 20 A. Yeah. This is after the fact, after I haven't 21 saw just Jeffrey when I was 17. 22 Q. And do you recall when your mother first told 23 you that people had come to talk to her about you going 24 to see Jeff Epstein? 25 A. Yeah, I remember. She called me July 27th of Page 179 1 Q. Did your mom tell you anything else that she 2 told them about your background? 3 A. Nope. 4 Q. By the way, what's your current relationship 5 with your mom like? 6 A. It's fine. 7 Q. When you mean fine, what do you mean? 8 A. It's positive. 9 Q. Would you characterize it as a good 10 relationship? 11 A. Yes. Ifs positive. 12 Q. Okay. Has it always been positive? 13 A. No. 14 Q. And when wasn't it positive? 15 A. I think we went over this before when I 16 started getting into drugs when 1 was 14 years old. 77 Q. And the drugs that you're talking about is 18 what this gave you when you went to 19 Mr. Epstein's? 20 A. Yes, and then it escalated. 21 Q. And, andaiarted to take drugs at times 22 other than when was taking you to Mr. Epstein's, 23 correct? 24 A. Correct 25 Q. And describe for us the escalation of your Page 178 1 '09 and said, hey, by the way, a couple of investigators 2 came by my house and asked if she knew anything. 3 Q. Well, what specifically did she tell you? 4 A. I just told you. 5 Q. Just said, just couple investigators came by 6 and asked what, if she knew anything? 7 A. Yes. 8 Q. Anything about what? 9 A. About the -- about Jeffrey Epstein. Arc you 10 kidding me? 11 Q. What did you tell her? 12 A. I said, okay. What did you say. She's like 13 nothing because I don't know. 14 Q. And that's, that's all she told you? 15 A. Yes. 16 Q. Did she tell you anything else about what she 17 told the people that came by to see her? 18 A. No. 19 Q. Did she tell you anything about what she told 20 them about you and her relationship? 21 A. No. Well, she said, actually she said I told 22 them that we don't really talk. 23 Q. That is your mom told you that she had told 24 these investigators that you and she don't talk? 25 A. Yes. Page 180 1 drug use after the first trip that you took to 2 Mr. Epstein's. 3 A. Well, after seeing Jeffrey so many times and 4 getting on a buzz of a pill, you start getting addicted 5 to that one pill so -- 6 Q. These are pills that gave you? 7 A. gave me some pills and then I, and 8 then I got pills from other people. 9 Q. From who? 10 A. Fr. Illpeople on the street. 11 Q. Like who? 12 A. Do I know their name? No, I don't. 13 Q. Well, you got them flow friends of yours, 14 didn't you? 15 A. No, it was, no, it was not a friend. 16 Q. Where did you go to get these pills? 17 A. On the street. 18 . Where on the street? Did you drive down 19 and buy them or where did you go? 20 A. Something like that. 21 Q. Is that where vou want? 22 A. No, not 23 Q. Okay. And how were you getting to the street 24 where you were buying these pills? 25 A. Walking. 45 (Pages 177 to 180) PROSE COURT REPORTING AGENCY, INC. EFTA02726480 Page 181 1 Q. So, you would walk where to buy pills? 2 A. Down the sued. 3 oLLmean, are u talking about over by your, 4 the where, where you were 5 living? 6 A. Yeah, Uh-huh. 7 Q. Or are you talking about someplace else? 8 A. Yes. 9 Q And who else would go with you when you were 10 out walltl: the streets to buy pills? 11 A. M . actually. 12 Q. And would both of you buy pills? 13 A. Yeah. 14 Q. And what kind of pills were you asking for? 15 A. Percocets, Lorcets, Vellums, Xanax, Soma, or 16 whatever they are called, Somas. 17 Q Any others? 18 A. Not that I recall. For extra, extra fun we 19 would ask for some coke or some ecstasy or -- 20 Q. Now, when you first went to Mr. Epstein's, I 21 think you described the summer of '07-, were you enrolled 22 in school? 23 A. it was the sunnier, so i don't think I had been 24 enrolled. 25 Q. So I mean, let's say it was the stunner of '02. Page 183 A. 2 Q. 3 A. 4 Q. A. 6 Q. 7 A. No. You weren't living with either one? No. Who were you living with? i was living with my son's father. Who is? 8 Q. Were you living with 9 got pregnant? 10 A. No. 11 Q. You only began living with him after you found 12 out that you were pregnant? 13 k Yes. 14 Q. Had you lived away from your home prior to the 15 time you got pregnant? 16 A. No. I was always at my mother's or father's 17 house. 18 Q. So, up until the time that you found out you 19 were pregnant, you had always been living at either 20 mom's or your dad's? 21 A. Yes. 22 Q. Is their a reason why you quit living at mom's 23 or dad's once you found out you were pregnant? 24 A. Yes, becaise when you find out you're 25 pregnant, you naturally want to by to make a family and before you Page 182 1 So it would be the '02-'03 school year? 2 A. Yes. 3 Q. And that would have been at 4 or at 5 A. 6 Q. Okay. Did there come a time that you quit 7 going to school? 8 A. Yes. 9 Q When was that? 10 A. When I was around- pregnant- 11 Q. Is, is that the reason you quit going is 12 because you were pregnant? 13 A. That was some of the reason. 14 Q. I mean, I assume that you didn't want to be in 15 school when it would begin to show that you were 16 pregnant? 17 A. No, it wasn't embarrassing to me. 18 Q. Okay. Well, what other -- other than the fact 19 that you were pregnant, what were the other reasons why 20 you quit going to school? 21 A. I felt l needed to make money for the baby. 22 Q. Well, you knew who the dad was, right? 23 A. Yeah. 24 Q. Were you living with your mother or your 25 father at the time that you became pregnant? Page 184 1 live with your son's father. 2 Q. Did either your mother or father tell you you 3 couldn't live, continue to live with them because you 4 were pregnant? 5 A. Na 6 Q. So, you had the choice to just stay with one 7 of your folks? 8 A. Yes. 9 Q. Do you remember which one you were living with 10 at the time? 11 A. My father. 12 Q Okay. So, your father didn't kick you out or 13 anything like that? 14 A. No. 15 Q. Did there come a time ever in your life when 16 you, you were living with your dad that you ran away? 17 A. No. If there was an argument, i went to my 18 mother's house. 19 Q. Did there ever come a time that you, you left 20 your father's house and left a note for him telling him 21 you weren't coming back? 22 A. No. 23 Q. Ever a time that your father had to report you 24 as missing, for example? 25 A. No. 46 (Pages 181 to 184) PROSE COURT REPORTING AGENCY, INC. EFTA02726481 Page 185 1 Q. If any of these things had happened, those, 2 would you agree with me that would have been a traumatic 3 event in your life? 4 MR. EDWARDS: Object to the form. Object to 5 lack of predicate. 6 THE WITNESS: Yeah, if I ran away, I think 7 that would be traumatic. 8 BY MR. LUTTIER: 9 Q. Did you ever ask either your mother or your 10 father or tell them that you wanted to be emancipated? 11 A. No, no. I — but there was an issue when 1 12 needed to get my license when I did have it and I was 13 trying to figure out a way around that, because they 14 weren't going to allow me to get my license unless 1 was 15 enrolled in school since I was 16. And we did talk 16 about that, but it never went through. We never really 17 were specific or on top of the subject. 18 Q. So, now you're talkie about some incident 19 that happened after 20 A. Yeah, I wanted to get my license. 21 Q. But before I am talking about now before 22 was there ever a time that you expressed 23 a desire to your mother or your father or anyone else 24 that you wanted to be emancipated? 25 A. No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 187 Q. Which is -- was he born sometime around.? kIll Q. Okay. So, you and were together until about 117 A. If that's — Q M— A. The correct math. Q MIS A. If that's the correct math. Q. Why did you and MR. EDWARDS: Object to the form. BY MR. LLITTIER: Q. . lam sorry. You said it was fo when was aboutall'? A. Yes. Q. All right. Then my math would be wrong, and that would take us until A. Okay. Q. And then did you and A 'twits., a Page 186 1 Q. Do you know what emancipated means? 2 A. Yes. 3 Q. And what does it mean? 4 A. It means that you want to be your own adult. 5 Q And you don't recall ever doing that? 6 MR. EDWARDS: Object to the form, asked and 7 answered. 8 IRE WITNESS: No. 9 BY MR. LUTT1ER: 11 you decide you're going to move in with Q. Okay. So, once you find out you're p ant, 10 12 A. Right. 13 . Now, and that would be sometime after 14 15 around I think wejust discussed before, is when you became 16 pregnant? 17 A. Yes. 18 Q. And you lived with then from 19 somewhere around to what point in 20 time? 21 A. We ended up buying all. with a lot of the 22 money I saved up from Jeffrey. We fixed it up and he, 23 Jeffrey actually threw my =M. He had 24 come over with a whole bunch of gifts, and we lived in 25 that-.. We were together since, until my son Page 188 1 Q Okay. Is there an event that 2 you can recall that helps you focus on that date? 3 A. M 4 Q. So, you and lived in this 5 that you had purchased until around 6 A. Yes. 7 Q. And when you say you purchased it, was it 8 purchased in your name, his name, joint names? 9 A. My 10 Q. Oh, it was in 11 A. Yes. 12 Q. Was there a reason why it went in 13 name as opposed to your name? 14 A. twos 16. 15 Q Did you provide the money? 16 A. I provided the money to fix up the place. I 17 am, I ended up paying him back after when we sold it, 18 but no, he paid for it. 19 Q. That is he being...? 20 A. Yes. 21 Q. And ballpark how much money did you spend 22 facing it up? 23 A. Throe grand, ballpark. 24 Q. Okay. And why -- 25 MR. GOLDBERGER: Excuse me, Mark, do you mind name? 47 (Pages 185 to 188) PROSE COURT REPORTING AGENCY, INC. EFTA02726482 Page 189 1 if we tabs a little break? 2 MR. LUITIER: No. THE VIDEOGRAPHER: Off the record. Time is 4 approximately 2:52 p.m. s (A brief recess was held.) 6 • * it it 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I 48 (Page 189) PROSE COURT REPORTING AGENCY, INC. EFTA02726483