EFTA00724274.pdf

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. RELATED CASES: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 DEPOSITION OF Tuesday, May 11, 2010 9:16 A.M. - 10:59 A.M. PROSE COURT REPORTING AGENCY, INC. 3111 West Dr. Martin Luther King, Jr. Boulevard Suite 100 Tampa, Florida 33607 REPORTED BY: MICHELLE OLSEN BADEN, RPR, FPR Notary Public, State of Florida at Large Prose Job No.: 1998 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden.M ) and0i404:4536-414d-8110443419Ciec569 EFTA00724274 EFTA00724275  Page Page 4 APPEARANCES: 1 The deposition of vas taken 2 BRADEDWARDS, ESQUIRE 2 pursuant to Subpoena by counsel for the Defendant on 3 FARMER JAFFE WEISSINO EDWARDS FISTOS & 3 Tuesday, May 11,2010, commencing at 9:16 A.M. at PROSE LEHRMAN, P1. 4 425 North Andrews Avenue, Suite 2 4 COURT REPORTING AGENCY, INC., 3111 West Dr. Martin also, Florida 33301 Luther King, Jr. Boulevard, Suite 100, Tampa, Florida 5 Attorney or Plaintiff in Related 6 33607. Said deposition was reported by Michelle Olsen Case No0840893 7 Baden, RPR. Notary Public, State of Florida at Large. (Appeared via telephone conference call) a 9 WHEREUPON: STUART S. MERMEISTEIN, ESQUIRE MERMELSTEIN & HOROWITZ,PA. 10 THE REPORTER: Please raise your right hand 18205 Biscayne Boulevard, Saute 2218 11 Do you solemnly swear or affirm that the 31 ila 33160 12 a 12 13 testimony you give today in this matter will be the truth, the whole truth and nothing but the truth? Attorney for Plaintiffs in related cases 13 08-80069, 08-80119, 08-80232, 08-80380, 0840381, 14 THE WITNESS: Yes. 0840993, 0840994 15 14 (Appeared via telephone conference call) 15 16 a witness, having been duly sworn to tell the truth, the 16 17 whole truth and nothing but the truth, was examined and MICHAELI. PIKE, ESQUIRE 17 BURMAN CRITTON LUTHER & COLEMAN 18 testified as follows: n Boulevard, Suite 400 19 EXAMINATION 18 Florida 33401 20 BY MR. PIKE: 19 21 Q Morning, Ms. My name is Michael Attorney for Defendant, JEFFREY EPSTEIN 20 (Appeared via telephone conference call) 22 Plke Can you hear me clearly? 21 22 23 A Yes. 23 24 Q fm taking your deposition today via 24 25 25 telephone. Usually, when we have a telephone Page 3 Page 5 1 INDEX . 1 deposition, its very easy for me to talk ova you and PAGE 2 vice versa. So, during this telephone deposition, 2 3 please allow me to finish my questions and I will allow 3 Examination By Mr. Pike 4 4 you to finish your answers, that way you and I can hear Examination By Mr. Edwards.......—....--.72 5 each other clearly. 5 6 If at any time you do not understand my 6 Certificate of Reporter.._......_ 77 7 question, please stop and ask me to repeat the question 7 Catificate of Oath....... .....—...78 8 and I will do so, especially given the fact that we are 9 9 on the telephone. Okay? 10 10 A No problem. 11 11 Q Okay. Would you please state your name for 12 12 the record. 13 13 A 14 14 Q woo you please spell your last name. EXHIBITS 15 A 15 16 Q Ms. where is your current residence? 16 (No exhibits were market) 17 A I live 17 18 18 19 Q And how long have you lived in 19 20 20 A I moved right befo 21 21 Q And what Is your date of . 22 23 24 22 23 24 Q Wlam. ow old are you today? 25 25 Q What is your current telephone number, both 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY INC. IIIIIIIIIIIII Electronically signed by Michelle BadenMa 053d0950-b535-41401118-6434195ae559 EFTA00724276  Page 6 Page 8 home and cell phone? 1 A Nowhere. That was m first lob — or no I'm 2 A IS have a cell, there is no home, and it 2 sorry. I worked 3 3 • •Q was your first place of 4 Q How long have you had that cellular telephone? 4 employment? 5 A As long as I have lived ha. S A Yes, sir. 6 Q Cm sorry, what was the date that you 6 Q I'm going to ask you whether or not you know 7 moveda, just the year? 7 certain individuals, and I would just like you to answer 8 A Roughly, September or — wait. October, rrn 8 me yes, you know them or no, you do not know them. And 9 sorry. 9 the ones that you do know we'll come back to later on, 10 Q Of 2009 or 2008? 10 after I finish figuring out who it is that you know and 11 A 11 who it is you don't know. Okay? 12 Q Where do you currently work? 12 A Okay. 13 A lam not working. 13 Q Do you blow a female by the name of 14 Q Where was ur last lace of em lo t? 14 Jane Doe 2? 15 A I worked s. 15 A No. 16 16 Q Do you 'mow a female by the name of 17 Q What of business is that? 17 Jane Doe 3? 18 A It tvas 18 A No. 19 Q Where that located? 19 Q Do you know a female by the name of 20 A INIMMINIMMIIIMI 20 Jane Doe 4? 21 21 A No. 22 Q Is that also a 22 Q Sometimes pronounced Jane Doe 4? 23 A Yes, sir. 23 A No. 24 QAnd before that where did you work, 24 Q Do you know a female by the name of 25 Ms. ? 25 Jane Doe 5? Page 7 Page 9 1 A I worked 1 A No. 2 Q Where was tha located? 2 Q Do you know a female by the name of 3 A Not exactly sure of the 3 Jane Doe 6? 4 street, maybe , somewhere along there. 4 A Yes. 5 Q And befo where were ou employed? 5 Q Do you 'mow a female by the name of 6 A I worked a 6 Jane Doe 7? 7 7 A No. 8 Q And before 8 Q Do you know a female by the name of 9 A I worked at 9 Jane Doe 8? 10 Q And where is tha 'located, 10 A No. 11 areet-wise? 11 Q Do you know a female by the name of 12 A It's right there on. and 12 A No. 13 13 Q Have you ever metEl? 14 Q What was our osition at 14 A No. Never heard the name. 15 A I was 15 ...Do youlmow a female by the name oil.. 16 Q Okay. How long did you work for 16 17 A I would say a couple months. 17 A No. 18 Q And before= in where did 18 Q Do you know a female by the name of= 19 you work? 19 A No. 20 A I worked at — I'm not sure of the name — I 20 Q Do you latow a female by the name of 21. want to say 21 Jane Doe II? 22 Q How long did you work for the 22 A No. 23 A I would say ma be a month month or two. 23 Q Do you blow a female by the name of Jane Doe? 24 Q And bef where did you 24 A Yes. work? Q Do you know a female by the name ofMIT 1r 4. 3 (Pages 6 to 9) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle BadenIIIMEIM) and09804538-04d-M18-643419bac559 EFTA00724277  Page 10 Page 1 A Yes. 1 A No. 2 Q Do you know a female by the name oliM 2 Q And when I ask that question I mean, from the 3 A Yes. 3 time that you have known her up until today's date, has 4 Q Do you know a female by the name of Si 4 she ever mentioned to you the name Jeffrey Epstein? 5 A Yes. 5 A No. 6 Q Do you know a female by the name SIM 6 MR. EDWARDS: I'm sorry is the "her" that 7 A No. 7 we're talking about Jane Doe 6 still? 8 Q Give me one second. Ms. how is it 8 9 MR. PIKE: Yes. THE WITNESS: Yeah, no, I nova heard anything I 9 that you know Jane Doe 6? 10 A She lives in the neighborhood I use to hang 10 about it. She's never mentioned that name. 11 out in. 11 BY MR. PIKE: 12 Q And what nei borhood is that? 12 Q Did you ever come to team that Jane Doe 6 had 13 A 13 gone to Mr. Epstein's home for any reason? 14 Q Would I that for the record. 14 A No. 15 A I believe. 15 Q Did Jane Doe 6 ever tell you that she went to 16 Q How long have you known Jane Doe 6? 16 Mr. Epstein's home in Palm Beach to give Mr. Epstein a 17 A I woWd say since I was 15. 17 massage? 18 Q Did you guys go to school together? 18 A No. She said she went there, when I last 19 A No. 19 talked to her, but no details. 20 Q How did you meet her? 20 Q Did Jane Doe 6 ever tell you that Mr. Epstein 21 A She was just hanging out with friends, I 21 faced her to do anything against her will? 22 believe. Just everybody hanging out and we met. 22 A No, sir. 23 Q Have you remained friends since the time you 23 MR. MERMELSTEIN: Object to form the question. 24 first met her? 24 BY MR. PIKE: 25 A Yes. 25 Q And, Mr. there are two other lawyers Page 11 Page 13 1 Q When was the last time you spoke to her? 1 on the phone and they are going to be making legal 2 A I spoke to her what is today, Tuesday. I 2 objections. Basically what that is is an attempt to 3 talked to her on Sunday. 3 preserve the record. Those objections aren't directed 4 Q When you spoke to her on Sunday did you speak 4 at you. Those objections are directed at my questions. 5 about this case? 5 So when you do hear a lawyer make an objection. Please 6 A No. 6 hold offuntil we finish our dialogue and then I'll come 7 Q Have you ever spoken to Jane Doe 6 about this 7 back to you and ask you to finish your answer. Okay? 8 case? 8 A Okay. 9 A I never knew she had anything to do with this 9 Q Did Jane Doe 6 ever tell you that she 10 until she told me the other day. 10 experienced any traumatic events at Jeffrey Epstein's 11 Q Would that be Sunday? 11 home? 12 A No. We -- !just got back from 12 MR. MERMELSTEIN: Objection to form. 13 Q So when you were in you saw her face 13 THE WITNESS: No. 14 to face? 14 BY MR. PIKE: 15 A Yes. 15 Q Did Jane Doe 6 ever tell you that she provided 16 Q And where did you guys meet in NEM 16 Mr. Epstein a massage while her bra was off? 17 A I saw her at her house. I came to say hi. 17 A No, sir. 18 Q What did you guys talk about relative to this 18 Q Is Jane Doe 6 one of your best friends? 19 case? 19 A I wouldn't say best friend but she is a 20 A All I said was that I can't — not talking 20 friend. 21 to because I have to do a deposition and she just 21 Q Is she a close friend? 22 said that she had something to do with it but that's — 22 A I mean, when I go to i go and say hi 23 she didn't go into detail. 23 but that's about it. 24 Q Did she ever talk to you about a gentleman by 24 Q Since you moved to how often do you .!5 the name ofJeffrey Epstein? 25 speak to Jane Doe 6? 4 (Pages 10 to 1 3) PROSE COURT 'REPORTING AGENCY, INC. Electronically signed by Michelle Baden MMIM aa3d0950-6535.414d-81186434195ac559 EFTA00724278  Page 14 Page 16 1 A Only when I go down there, so I would call her 1 A 2 before I go down there and say "Hi," but other than that .2 Q Do you know of any other close friends that 3 we don't talk. 3 have died in Jane Doe 6 lifetime? 4 Q Do you know of any traumatic events that 4 A No —or yes. 5 Jane Doe 6 has experienced in her lifetime? 5 Q And who was that? 6 MR. MERMELSTEIN: Objection to form. 6 A 7 BY MR. PIKE: 7 Q And who is that to Jane Doe 6? 8 Q And your answer was, Ms ? 8 A Good friend. 9 A No. Q Would you consider that a traumatic experience 10 Q Do you know whether or not any one of her 10 for her? 11 boyfriends everMEMS? 11. MR. MERMELSTEIN: Objection to form. 12 A Yes. 12 BY MR. PIKE: 13 Q Would you consider that a traumatic event? 13 Q You can answer. A Slightly, yes, a little a 14 A Yeah. 14 15 Q And how did Mr. die? 15 Q And your answer was, 16 A Yes. 16 A 17 What • was that, to your knowledge, 17 And did they eve1 18 18 19 A I have no idea. 19 A Yes. 20 Q Did Jane Doe 6 ever discuss that traumatic 20 Q And is that person= 23. event with you? 21 A Yes. 22 A No. I heard from somebody else. 22 Q Do you know whether or not Jane Doe 6 has ever 23 Q Who did you hear from? 23 done drugs in front of you? And by "drugs" I mean 24 A I have no idea. Just gossip around the 24 marijuana, amphetamine or any kind of painkillers? 25 neighborhood. I have no idea. 25, A Yes. Page 15 Page 17 1 Q Did you ever have any sexual experiences with 1 Q And what drugs has she done, to your 2 Jane Doe 6? 2 knowledge? 3 A No. 3 A Marijuana in front of me. 4 Dkl ever learn that Jane Doe 6 was an 4 Q What other drugs? 5 at the age of, 5 A She's never done anything else in from of me. A No. 6 Q To your knowledge, do you know whether she has 7 MR, MERMELSTEIN: Objection to fonn. 7 done any other drugs, separate and apart from marijuana? 8 BY MR. PIKE: 8 A . I'm not sure. 9 aor you know whether or not Jane Doe 6 is a 9 Q Do you know whether or not Jane Doe 6 drinks 10 10 alcohol? 11 A I knew shel.Mbut 1 don't see it 11 A No. 12 any farther than that. 12 Q When she did marijuana in front of you, how 13' Q Do you know whether or not she has a 13 old was she and how old were you? 14 relationship with her mother? 14 A 15 and 1 don't know how old she was. 1S A She does, as far as 1 know. 15 Q Have you ever met Jane Doe 6's child? 16 Q Based upon your experience, do you know 16 A Yes. 17 whether or not it is a good relationship or a bad 17 And what is name? 18. relationship? 18 A 19 A 1 would say good. 19 Have you ever met the father? 20 Q Where does her mother live, to your knowledge? 20 A Yes. 21 A 21 And what is his name? 22. Q What about her relationship with her father, 22' A 23 do you know anything about that? 23 And his last name? 24 A I guess they have a good relationship. 24 A 1 have no idea. Q Do you know where her father lives? 25 Do you know who Jane Doe 6 currently dates? 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY., INC. a53d0950-136364f4d-8118-6434195se659 Electronically signed by Michelle Baden NM= EFTA00724279  Page 18 Page 20 1 A la. 1 A No. We went to the store. 2 Q And doeaMive 2 Q During the times that you hung out with her, 3 A Yes. 3 was she ever crying? 4 Q And what does he do? 4 A No. 5 A I'm not sure.alMni or something. 5 Q During the times you hung out with her 6 Q With regard to the women that you said you 6 recently, did she ever make any mention or complaint 7 knew, were you aware as to whether or not any of those 7 about Jeffrey Epstein? 8 women ever went to Jeffrey Epstein's home in Palm Beach? 8 A No. 9 A 1 only knew about Jane Doe anclia Q Did she seem depressed to you? 10 Q Did you ever go to Jeffrey Epstein's home? 10 A No. 11 A No, sir. 11 Q Did she dist-mg any emotional issues that she 12 Q Ind you ever drop anyone off at Jefftey 12 was having with you? 13 Epstein's home by vehicle? 13 A No, sir. 14 A No. I can't drive. 14 Q Did she discuss at all any happy times in her 15 Q And why can't you drive? 15 life, of the times that you visited with her most 16 A 1 don't have a license and lam afraid of the 16 recently? 17 road. 17 A No. 18 Q Have you ever had a license? 18 Q What did you guys talk about? 19 A No, slr. 19 n't know. Ii 20 Q Why is it that you are afraid of the road? 20 our friend' 21 A I got in a car accident whealwaa 21 22 Q Who was in the car with you? 22 And that would be Ma 23 A My friend= 23 A Yes, sir. 24 Q And what is her last name? 24 Q Ho ' 9 25 A 25 A He Page 19 Page 21 1 Q Anyone else? 1 Q 2 A /N. stn. 2 A Yes, sir. 3 still living today, that is did she 3 Pm sorry, you testified that Mal was Q I 4 die as a result of the car accident? 4 Ma is that correct? 5 A No. She's still living. 5 A Yes. 6 Q When you saw Jane Doe 6 on Stmday, did she 6 vots.What were the circumstances surrounding how he 7 seem happy to you? 7 8 A I don't know. We just stopped by and said 8 A They sa r a lot of stories like 9 "Bye" so — she was just watching a movie. 9 it the but he got basically said you stopped by and said "Bye..."? 10 and then the 10 Q You 11 A Yeah, because we were driving back toME 11 people ran. . 12 Q Who was with you? 12 _10 Where was be living at the time that he was 13 A My boyfriend. 13 NE ou A iflifis mw? 14 Q What is his name? 14 A 15 Q Do you know if Mr was in a gang? 15 16 Q Does lie live in 16 A No, I don't. 17 A Yes. 17 Q Do you know iflane Doe 6 was ever in 2. 18 Q How long did you visit with Jane Doe 6 for? 18 A I don't believe so but I don't know everyb . 19 A I saw her a couple of times since I was there, 19 she knows. I live here now. 20 just hung out for a little and then I was mainly at my 20 Q Did Jane Doe 6 ever talk to you about her 21 mom's. 21. being a prostitute? 22 Q When you hung out with Jane Doe 6, where did 22 A No. 23 you go? 23 Q Do you know whether Jane Doe 6 ever was a 14 A We were at her house. 24. prostitute? 25 Q Any other places? 25 A No. 6 (Pages 18 to 21) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by Michelle Baden .53•10960-b535-0444t184434198ae569 EFTA00724280  Page 22 Page 24 1 Q That is no you don't lmow one way or the 1 A No, sir. 2 other? 2 Q Were you ever out anywhere a 3 A No, I don't know. 3 where you saw.lat a club? 4 Q Do you know whether or not Jane Doe 6 ever 4 A No. 5 vented at any strip clubs and/or gentlemen's clubs? 5 Q Dld you talk to= on the phone? 6 A No. 6 A No. 7 Q That is no, you do not know? 7 Q When was the last time you talked toile 8 A No, I do not know. 8 A !saw her at Wal-Mart when I was, probably, 9 Q Do you know if she ever hung out at any strip 9 It 10 clubs or gentlemen's clubs? 10 Q You said you saw her at Wal-Mart? 11 MR. MERMELSTEIN: Objection to form. 11 A Yeah. 12 BY MR. PIKE: 12 Q I didn't hear you if you testified to this, 13 Q You can answer. 13 Pm sorry. How long ago was that? 14 A I don't 'mow. 14 A I'd say when I was 18. I went down to visit 15 Q Do you know if Jane Doe 6 was ever involved in 15 and she was at Wal-Mart eating at the food 16 a car accident? 16 _ i "Hi." court and I said 17 A I believe so, when she was younger. 17 Q Hass. ever discussed Jeffrey Epstein with 18 Q What do you know about that car accident? 18 you? 19 A I believe it was aMill That is all I 19 A No, sir. 20 remember. 20 t f I remember correctly, you said you knew 21 Q Do you know if anybody passed away in her 21 that M. was going to Jeffrey Epstein's home? 22 vehicle? 22 A I heard Jane Doe mention it but don't know 23 A I don't know. 23 details. 24 Q Do you know if anybody came close to dying 24 Q When you say "Jane Doe" you mean Jane Doe? 25 that was in her vehicle? 25 A Yes, sir. Page 23 Page 25 1 MR. MERMELSTEIN: Objection to form. Q What did Jane Doe mention that you are 2 THE WITNESS: I don't know. 2 talking about now? 3 BY MR. PIKE: 3 A She said that she was at the house that. 4 Q Let's talk abou= You said you knewill.; 4 Q That. was at Mr. Epstein's house? 5 is that correct? 5 A Yeah. 6 A I met.. • Q Have you ever discussed.. going to 7 Q How did you meet.. 7 Mr. Epstein's house with.? 8 A Once again, just everybody knows everybody and 8 A No. 9 she was hanging out one night and I met her. Q What, if anything, do you know about... 10 Q Where did u meet her? 10 going to Mr. Epstein's home?. 11 A at the bead, I believe. 11 MR. EDWARDS: Form. 12 Q How long have you known ha? 12 THE WITNESS: I don't know anything besides 13 A I not her on my 15th birthday, !believe. 13 that she went there. 14 Q Okay. So you have 'mown her for, what,. 14 BY MR. PIKE: 15 years, approximately? 15 Q Do you know whether or not she did anything of 16 A Well, I have only — in that whole time, I 16 sexual in nature at Mr. Epstein's home? 17 have only hung out with her for maybe lute three times. 17 A I have no idea. 18 So that is why I don't say like she's a friend. She's 18 I know that you said you didn't bang out with 19 just an acquaintance. I met her. 19 M. that much, but I have to ask you these questions 20 Q When you hung out with her for those three 20 and I'll try to make them short. 21 times, where did you guys hang out? 21 Did.. discuss with you any traumatic events 22 A We were at the beach. The other times we were 22 that happened to her at Mr. Epstein's home? 23 just, I don't know. I know she was at Jane Doe's once. 23 A No, sir. 24 And then I don't !mow. 24 Q Has.. called you to discuss at all any 25 Q Did you guys ever go out to clubs together? 25 emotional issues that she allegedly has by virtue of 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. at3d0950-b536-4f4d4018-643419Sec669 Electronically signed by Michelle Baden IMMIMID EFTA00724281  Page 26 Page 28 1 having visited Mr. Epstein's home? 1 BY MR. PIKE: 2 A No. 2 Have you ever been AMMAN 3 Q Do you know whether or nail worked at 3 4 strip clubs? 4 A No, sir. 5 A I don't 'mow. 5 Q Do you know whale) is? 6 Q As you sit here coda our testimony is you A A gentlemen's club. 7 don't know whether or node. ever worked as a stripper 7 Q Do you know t nextd Mien- - 8 at a snip club? 8 club is a place call 9 A I have no idea. 9 A I don't even latow is located. 10 Q Did Jane Doe ever tell you than. ever 10 Q Have you ever heard the term "jack shack"? 11 worked at any strip club? 11 A Yeah. Movies. 12 A No. 12 Q What -- bow do you understand that term? 13 Q Do you know whether or no is an admitted 13 A I guess, basically, a place where you go and 14 prostitute? 14 sell yourself. 15 A I don't know. 15 Q Do you know whether or no.. has ever 16 MR. MERMELSTEIN: Form. 16 worked at any jack shacks? 17 BY MR. PIKE: 17 A No. 18 Q Do you know whether or not- ever sold her 18 MR. EDWARDS: Object to the form. 19 body for sex? 19 BY MR. PIKE: 20 MR. EDWARDS: Objection to form. 20 Q That is no, you don't know? 21 THE WITNESS: I have no idea. 21 A No, I don't know. 22 BY MR. PIKE: 22 Q All right let's move on toM. You did 23 Do you know whether or no= ever 23 testify earlier that you knew her, correct? 24 when shewaiters old? 24 A Yes. 25 A I have no idea. 25 Q How do you known.? Page 27 Page 29 1 MR. EDWARDS: Objection to the form of that 1 and 2 3 4 question as well. BY MR. PIKE: Q Do you know whether or no sa 2 3 4 Q A was was that? 5 prostitute? 5 Q And did you go to HAM for. 6 A I don't know. 6 years? 7 142. EDWARDS: Same objection. 7 . A No. 8 BY MR. PUCE: 8 Q 11. ur long did you go- 9 Q Had you ever heard than...as a 9 A El years. 10 prostitute? 10 Q And how long did.. go to that school for? 11 A No. 11 A I'mnql.tia. 12 Q Do you know who.. is currently dating? 12 .Q What= were you in when you first met 13 A No. 13 14 Q What else can you tell me about., if 14 A I was 15 anything, that we haven't discussed during your 15 Q Did You Pr 16 deposition today? 16 A No. 17 A !can say nothing because I don't talk to her. 17 Q How did you meet her? 18 I've only hung out with her a couple times and didn't 18. A I met her brother and then I went to her house 19 really, you know, talk-talk. Just hung out. I don't 19 and met ha. 20 know her. I don't know anything. 20 Q How did you meet her bro ? • 21 Q Do you know whether ently 21 A Just around the neighborhood, like everybody 22 works at a lace call right by 22 knows everybody. 23 in 23. Q Did you ever date her brother? 24 A I don't ;mow. 24 A No. 15 MR. EDWARDS: Object to form. 25 Q Did you ever have any sexual experiences with 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Michelle Baden . and095043536-414d-8116-6434195ac669 EFTA00724282  Page 30 Page 32 1 her brother? 1 MR. EDWARDS: Form. 2 A No. 2 BY MR. PIKE: 3 !ti Did you ever have any sexual experiences with 3 Q When was the last time I 'mow you said you 4 ..? 4 haven't spoke a. in a while. When was the last 5 A No. 5 time you spoke to her? 6 Q Are you aware that.. and.. are friends? 6 A I talked to her, I would say, maybe two years 7 A Yes. 7 ago on the phone. She was with Jane Doe, I believe, and 8 Q How are ou aware of that? 8 I just said "Hi" you know, caught up and asked how we 9 A . htzg_out with me and then she 9 were doing and that was it. 10 started hanging out with., and then we basically 10 Q Did she tell you what she was up to worlovise 11 talk an more. We went separate ways. 11 in that telephone call? 12 Did . ever tell you that.. ever worked 12 A No. 13 13 Q How long did that telephone call last? 14 A No. I haven't talked to.. maybe since I 14 A I would say maybe five, 10 minutes. I was at 15 was 15. 15 a store, Thad to go. 16 Q And why did you stop talking to..? 16 2 How did you learn or di ever learn that 17 A Well, she always came to hang out with me and 17 M. went over to her home in 18 then, I don't know, we went our separate ways and, I 18 A Basically you told me. !had I10 idea. 19 don't knowzie•ust lost contact 19 Q So you had no idea — you had no idea up until 20 Q Did . ever discuss whether she went to 20 today's date? 21 Mr. Epstein's home in Palm Beach? 21 A Yes, no idea. 22 A No, sir. 22 Q Did Jane Doe or anyone ever tell you thatI. 23 Q She never discussed that with you? 23 had some sort of experience with Mr. Epstein? 24 A No. 24 A No. 25 Q Did.. ever tell you that she worked at 25 Q Did anyone ever tell you that.. ever gave Page 31 Page 33 1 1 Nix. Epstein massages in exchange for money? 2 A No. 2 A No. 3 Q How long were you friends with..? 3 Q Do you know whetbirar not, during the time 4 A Well, I have known her — I met her when 1 was 4 that you were friends withM. that she ever used 5 likes and we hung out for a couple of years, and then 5 drugs? 6 we just didn't hang out any more, so two years. 6 A Marijuana. 7 Q Pro sorry? 7 Q And how old was she when she was using 8 A Like two years. 8 marijuana? 9 Q So you knew her for two yews? 9 A 15,14. 10 A Yeah. 10 Q Do you know whether or not she used marijuana 11 Q And durittg that two- ear eriod, did she ever 11 on a weekly basis or on a daily basis during that time? 12 tell you that she worked a 12 A I think it was just like a weekend thing. 13 A No. 13 Q Do you know whether or not she ever did 14 Q Did you ever come to learn at any even 14 Ecstasy? 15 up through today's date, that she worked at 15 A I have no idea. 16 A Yeah. 16 Q What about do you know whether or not 17 Q How did you learn that? 17 she did Ecstasy? 18 A Jane Doe. 18 A I have no idea. 19 Q What did Jane Doe tell you about th