EFTA00750774.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME III 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, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 a.m. - 6:10 p.m. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Reported By: Pamela J. Sullivan, RPR, FPR, CLR Prose Reporting Agency, Inc. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (6014334724662) Electronically signed by Pamela Sullivan (601-33S-772-1552) 9205b62-38a5-4202-0350-6633a5c6813b EFTA00750774  Page 261 Page 263 APPEARANCES 1 On behalf of the Plaintiff. /me Deo BRAD J. EDWARDS, ESQUIRE 2 INDEX ROTHSTEIN ROSENFELDT ADLER 3 --- Lea au ON Cate, Suite 1650 401 East Las Otat Beamed 4 %WINES& DIRECT CROSS REDIRECT RECROSS Fart Lade/dal. Hooch 33301 5 JANE DOE 6 BY MR. CRITTON 5 0.1 behalf of the Defeedmu, kffrey Epstein: 7 ROBERT D. CRITTON, 3R. ESQUIRE BURMAN, CIUTPON, CUTTER & COLEMAN, LIP 9 303 Behan Bculevard EXHIBITS MARKED Suite 400 9 10 Nash him Bach Ronda 33401 10 11 11 PAGE 12 On behalf efthe Deem/bet. Jeffrey *Kit DESOUPTION 13 JACK ALAN OOLDBEROER, ESQUIRE 12 ATTERBURY, GOIDBERGER & WESS, PA Defendants No. 6 390 14 250 AuMeliat Aram Sotth WM 1400 13 (Plaintiffs AGSMs to Defendant's Interrogatories) 15 Wall Pam Beach, FIceicla 334014012 14 Defendants No. 7 16 On WWI of Itbittiff r Related Carr No. 01680469: 1, SIDRO M. GARCIA, ESQUIRE (Ur to Edwards from Critton %%Enclosures) GARCIA LAW FIRM, PA 15 18 224 Dama Seth Suite 900 11.1113401 16 19 17 Marked off the record.) 20 18 On behalf of hem Dom thmedh 19 21 ADAM D. HOROV/ITZ, ESQUIRE 20 22 MERMELSTEIN a HORMUZ P.A. 21 1820$ Blimp* Boulevard 23 Sulk, Z218 22 Miami. Florida 33160 23 24 24 25 25 Page 262 Page 264 1 On behalf of the Plaintiff CM.A.: 1 PROCEEDINGS 2 JACK P. HELL, ESQUIRE 2 SEARCY DENNEY SCAROIA BARNHART & SHIPLEY, PA 3 2139 Palm Beach Lalces Boulevard 3 (Continued from Volume II of the same day.) West Pabn Beach, Oneida 33409 4 BY MR. CRITTON: 4 5 Q. Ms. Jane Doe, other than speaking with your 5 On o . 6 attorney over the lunch hour, did you speak with anyone 6 ADAM J. LANGEt40, ESQUIRE 7 else? LEOPOLD KINN 8 A. No. 7 2925 PGA Boulevard, Sure 200 9 Q. Are you on any medication today? Palm Beach Galas. Florida 33410 10 A. No. 11 Q. 'When is the last time you had any pot, 9 12 marijuana? 10 13 MR. EDWARDS: Object to the form. 11 ALSO PRESENT: 12 Jeffrey Epstein, via video conference 14 BY MR. CRITTON: Stm Sanders, Videograptier 15 Q. And when I say had, smoke. 1.3 16 A. Before I was pregnant with my daughter. 14 15 17 Q. Okay. And its your testimony that, since 16 18 the time you've been pregnant, you have not taken — you 17 19 haven't smoked pot and you haven't taken any drugs or 18 20 alcohol Tm sorry — any illegal and/or — any 19 20 21 illegal drugs or prescription drugs that would have gone 21 22 to someone else, like a Xanax; is that correct? 22 23 MR. EDWARDS: Object to the form. 23 24 24 THE WITNESS: What was the question? 25 25 ..2 (P.ages_2_61 to 264) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. • • (561) 832-7506 • Electronically signed by Pamela Sullivan (501.3357724652) Electronically signed by Pamela Sullivan (501-333-7724552) 92eldb6248.5-42024360-6633a5e6813b EFTA00750775  Page 265 Page 267 BY MR. CARTON: 1 Q. You need to keep your voice up, because Pm 2 Q. Ifs your testimony that, since the time you 2 having trouble hearing you, ma'am. 3 were pregnant, you haven't had any illegal drugs and/or 3 A. She's okier than me. 4 any drugs that weren't prescribed specifically for you? 4 Q. Okay. And why did she live with you? 5 A. Yes, that's true. 5 A. ;guess her mom was staying in a — in an 6 Q. Okay. And you -- and you have roxy. I asked 6 efficiency, I guess, with herSiend, bc and I guess 7 you earlier whether you knew what that was. My 7 there really wasn't room forM. She didn't have 8 understanding is you smoke that; is that correct? 8 anywhere to live. 9 MR. EDWARDS: Object to the form. 9 Q. And were you living at 10 BY MR. CARTON: 10 house at the time? 11 Q. You — and it's a smokable drug? 11 A. Yes. 12 MR. EDWARDS: Object to the form. 12 Q. Okay. And how long did M. live with you? 13 1HE WITNESS: I have heard of people eating 13 A. A month or two. 14 them and snorting them and smoking them and 14 Q. AUSA. Since that other than that one 15 shooting them up. 15 time, has ever lived with you again? 16 BY MR. CRITTON: 16 A. No. 17 Q. Okay. And it's your testimony you've never 17 Q. Has she ever stayed with you again? 18 done those? 18 A. No. 19 A. Yes. 19 Q. Do you know where M. is right now? 20 Q. When is the last time you spoke with— well, 20 A. No. 21 I asked you a question earlier: Who else was living 21 Q. When is the last time you talked to M.? 22 with you and your boyfriend, MI, and your child at 22 A. Several months ago. I'm not sure. 23 your house? And your attorney instructed you not to 23 IIVOkay. And what was the event that caused you 24 answer. Do you remember that? 24 andM. to not be close anymore? 25 A. Yes. 25 A. She moved. Page 266 Page 268 1 Q. Okay. Is the person who — is it more than 1 Q. Just she moved? 2 one additional person who is living with you at that 2 A. She moved far away from me. I don't know 3 house? 3 where. And I guess she — I don't know. I guess she 4 A. No. 4 doesn't... 5 Q. Okay. Is that person still there now? 5 Q. Do you have her phone number? 6 MR. EDWARDS: Don't answer. 6 A. No. Other identifying information about the 7 Q. Okay. Did you have it before she moved? 8 address. I think it's — ifs pretty clear she's 8 A. Yes. 9 not going to answer anything that's going to 9 . Have you — when you've talked toM., does 10 indicate to you where' he's living currently. Now, 10 ever say,' -- I know where a. is, or I talked to 11 all other addresses, you know them, and she'll tell 11 . the other day? 12 you that. 12 A. No. 13 MR. CARTON: I understand. So my position 13 Q. And tell me when the last time was that you 14 is clear is that person that's been, apparently, is 14 spoke with M, 15 living there, she, she would have information — 15 A. Probably a month and a half, maybe two months 16 she or he would have Information regarding aspects 16 ago. 17 of the Plaintiffs claim clearly is a relevant 17 Q. Okay. Which would if we're in the end of 18 witness, and — 18 September, it would have been sometime in early or mid 19 MR. EDWARDS: Okay. 1understand. 19 July? 20 BY MR. CRITTON: 20 A. Yes. 21 Q. Has Ng ever lived with you? 21 Q. Okay. And did you only talk to her over the 22 A. Yes. 22 phone? 23 Q. Okay. When? 23 A. We went to the beach. 24 A. We were 14, I believe. She was 14, I was 13, 24 Q. Did you take your respective children? 25 because she's older than I am. 25 A. Yes. •.‘13, YacY•aa14,,V- 3 (Pages 265 to 268) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC.' (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772.1552) Electronically signed by Pamela Sullivan (501.333-772.1552) 92efSb62-38a5-4202-a350-6633a5c6813b EFTA00750776  Page 269 Page 271 1 Q. Okay. And you talked about this case; didn't 1 Q. Did M. ever tell you she was a call girl? 2 you — your cases? 2 A. No. 3 A. No, we did not 3 Q. You know what a call girl is? 4 Q. Subject never came up, is your testimony? 4 A. Yes. 5 k No. 5 Q. Did you ever ask M. if she was a 6 Q. That's correct? 6 prostitute? 7 A. That is correct 7 A. No. 8 Q. Other than that, have you seen or talked to 8 Q. Did you ever ask how she made her money? 9 M.? 9 A. No. 10 A. No. 10 Q. Is M. a prostitute? 11 Q. Okay. Well, didn't you baby-sit for MA 11 A. Not that I know of. 12 son? 12 Q. lies she am been a prostitute? 13 A. Yes. 13 A. Not that J 'mow of. 14 Q. Okay. When was that? 14 Q. Do you consider yourself to be a prostitute? 15 A. Ito not exactly sure. 15 A. No, l do not. 16 Q. Wasn't that after you went to the beach, 16 Q. Have you ever engaged in prostitution? 17 approximately a month and a half to two months ago? 17 A. Besides Jeffrey Epstein, no. 18 A. I don't remember if it was before or after. 18 Q. Well, what do you -- what do you consider a 19 Q. And did she drop how does — how — what 19 prostitute to be? 20 was the occasion that she asked you to sit for her son? 20 A. Somebody who gets paid for giving sexual 21 A. She had to wodc 21 favors. 22 Q. Where was she working? 22 Q. Separate and apart from any activities with 23 A. I think she was working in like a — like a 23 Mr. Epstein, have you ever performed or given sex, 24 skin care place. I'm not sure. 24 sexual favors, using your term, for money? 25 Q. How many times did you baby-sit for her son? 25 A. No. Page 270 Page 272 1 MR. EDWARDS: Object to the form. 1 Q. Now, you've worked at some strip clubs; have 2 BY MR. CRITTON: 2 you not? 3 Q. Or watch ber son? 3 A. Yes. 4 MR. EDWARDS: Ever, you mean? 4 And ou worked at -down in 5 MR. CR1TfON: Ever. 5 6 MR. EDWARDS: Eva. Okay. 6 A. Yes. 7 THE WITNESS: Probably like two or three 7 Q. -- true? 8 times. B A. Yes. 9 BY MR. CRITTON: 9 . . And I think you said you worked at 10 Q. Did she pay you? 10 for approximately eight months? 11 A. Yes. 11 A. Something Lice that, yes. 12 Q. How much did she pay you? 12 Q. Who was your boss, or who was the manager or 13 A. Well, she only paid me once, like S20 or 13 the person that you had to report to? 14 something. ' 14 A. The owner of the club was named 15 Q. Would you let ■ watch your daughter? 15 Q. Do you know what his last name was? 16 A. Absolutely. 16 A. No, I do not. 17 Q. Do you know M. to be or to have been a 17 • get — was — was anyone working 18 prostitute? 18 at• that you knew at the time you applied 19 A. No. 19 for the job, the position? 20 Q. You know what a prostitute is? 20 A. Yes. 21 A. Yes, I do. 21 • Q. Who? 22 Q. Did ■ ever tell you that she received 22 A. 23 money for giving sexual -- or performing sexual nets for 23 . And how was it that you came to get a job at 24 men? 24 that is, why? 25 A. No. 25 A. Urn. 4 (Pages 269 to 272) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 92ef5b62-35a54202-a350.6633a5c6813b EFTA00750777  Page 273 Page 275 1 Q. This was in 2006? 1 A. I was living with 2 A. It was after I was 18, so... I'm net sure 2 Q. And were you living at the apartment? 3 what year. 3 A. Yes. 4 Q. Well, you were bo correct? 4 Q. That's when she was living with a 5 A. Yes. 5 A. Yes. 6 Q. Okay. 6 Q. So you're living at the apartment, and thaim 7 All right? So if you worked seven months there or eight 7 tia you started — you knew she was working a 8 months, it would have been sometime after June — what imp so she said, why don't you come with me, or 9 would you say your birthday was? 9 something like that? 10 A. Seventeenth. 10 A. Yes. But this was the second time that I 11 Q. All right. Sometime after June 17th of '06, 11 lived with her. 12 probably miming into sometime in '07; true? 12 Q. I thought you said the second time was in 13 A. Yes. 13 2007. 14 Q. And sole— what caused you to get the 14 A. I just know that I had tuned 18 since I 15 job, or why did you come — why did you come to get a 15 started dancing, sol may have been close to 19 or 19 16 job at 16 when I did start 17 A. brought me there. 17 Q. Okay. Well, now, was III living at the 18 Q. Oksy. But your choice to go; right? 18 Royal Palm Bellaire, or was she living in the 19 A. Yes. 19 apartment with 20 Q. Okay. And what did you do — what did you 20 A. TIslizal Palm Beach place was an apartment, 21 or how did it happen that you went to get the job? 21 also, and also lived there. 22 was dancing there; you knew that? 22 Q. Okay. Well, you testified earlier that in 23 A. Yes. 23 2006 you spent a few -- a few months with her. 24 Q. Okay. And she was a stripper? 24 A. Ult-huh. 25 A. Yes. 25 Q. And then — and that was in the apartment in Page 274 Page 276 Q. Did she tell you how much money she made? 1 West Palm Beach. And then the second time, 1 thought 2 A. No. 2 you said you only spent about a month. I may have been 3 Q. Did she tell you what she had to do to earn 3 wrong. 1 money? 4 A. Yes, 1 did only spend about a month. 5 A. Dance. 5 Q. Okay. Was — and the one month was at the 6 Q. What else? Royal Palm Beach house? 7 A. Take her clothes oft strip. 7 A. Yes. 8 Q. All right. And did she — did she do — did 8 Q. Okay. s' r testimony that you 9 she do bachelor pasties? 9 went to work at in 2007? 10 A. Not that I know of. 10 A. That's possible. 11 Q. Okay. Did she do lap dances? 11 Q. Well, I don't know, because I wasn't there. 12 A. Yes. 12 That's why I'm just trying to ask. Because earlier you 13 Q. All right. And did she work the stage? 13 testified it was 2006, and I think that's what your 14 A. Yes. 14 answers to interrogatories reflect. So what is it? 15 Q. Did table dances, as well? 15 A. Well, it -- 16 A. They don't have table dances. 16 Q. What's the current answer? 17 Q. What do they have? Lap dances? 17 MR. EDWARDS: Object to the form. 18 A. Yes. 18 THE WITNESS: It was definitely after I 19 Q. And what did tell you about that work? 19 armed 18. 1 don't know exactly what day it was. 20 A. She just told me that, like, you had to go on 20 I don't know what month or year. I don't know. I 21 stage and dance, and that's how you made money, by 21 don't like write down, I started stripping today. 22 dancing. 22 No, !didn't do that. 23 Q. Did you say -- what were you doing at the 23 BY MR. CRITTON: 24 time? Where were you living in 2006 when you had just 24 Q. Do you ever keep diaries? 25 turned 18? 25 A. No. 5 (Pages 273 to 276) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 92et6b62-38a6-42024350-8833a6c6813b EFTA00750778  Page 277 Page 279 1 Q. Have you kept diaries? 1 Q. Okay. Because was when you were 17? 2 A No. Never. A. Yes. 3 Q. Have you filed any tax returns? 3 Q. So what other jobs did you — had you ever A. No. 4 applied for another job, other than I.? 5 Q. Have you ever filed a tax retum? 5 A. Yes. 6 A. No. 6 Q. Where? 7 Q. Have you ever consulted anyone about whether 7 A. At the mall. 8 you need to file a tax return? 8 Q. But no one had ever hired you? 9 A. No. 9 A. No. 10 1.1 12 that When you worked — so is it your recoiled ion . was living — or you were living with II. at Royal Palm, or West Palm, at the time you started 10 11 12 Q. So how many different places did you apply for a job? A. A few. Two or three, maybe. 13 stripping? 13 Q. So you applied for the jobs. You didn't get 14 A. Royal Palm. 14 those. You quit the job voluntarily, because you 15 Q. What work — before you started stripping, 15 didn't like it; right? 16 what work had you ever done to make money, other than 16 A. Right. 17 17 Q. Because you weren't getting along with whom? 18 A. Tithes it. 18 The boss? 19 ... and I think you told me about 19 A. No. 20 21 a. A. Yes. 20 21 Q. Who? A. It was actually M.'s brother that I was not 22 Q. That was like a, what, a week or a month or 22 getting along with. 23 24 25 something? A. A week. Q. Excuse tne. And that didn't work out; right? Page 278 23 24 25 Q. What's his name? A. Q. nwhat? Page 2.;Sfl 1 A. Right. 1 A. 2 Q. Okay. So the only odier'ob u've had in 2 Q. And why? Why weren't you getting along with 3 your entire life was working at E.? 3 him? 4 A. Yes. 4 A. Because he -- well, I thought that he stole 5 Q. OkaiyAnd why did you leave? Once you got 5 some money from the restaurant while I was working one 6 thejcb at as a waitress, why did you stop working 6 night. And he called me and said a bunch of nasty 7 at Mr/ 7 things to me, because I was basically implicating that 8 A. ljust — I don't know. Ijust didn't want 8 he had stolen some money from the restaurant. 9 to work there anymore. I guess I just wasn't getting .9 Q. Well, you believed it to be true? 10 along with everybody. 10 A. Yes. 11 Q. Okay. One month? 11 Q. Okay. And so what, what happened? 12 A. Yes. 12 A. He was just like really rude to me all the 13 Q. Okay. And you got salary or minimum wage? 13 time, and ho told me that he was like — I — I mean, I 14 A. Yes. 14 don't remember specifically what he said, but he told me 15 Q. Plus tips? 15 that, you lmow, he was going to like, you know, do 16 A- Yes. 16 something to hurt me or my family. 17 Q. How much money did you make there? 17 Q. So you stopped working. Did you tell M. 18 A Not very much. 18 that? 19 Q. All right. So now you're 18, or over 18, 19 A. Yes, I did. 20 maybe over — closer to 19. The onl er 20 Q. And so how, then, did you get the strip job? 21 had in your whole life is working at for minimum 21 M. said, well, why don't you come with me; you can 22 wage and tips; right? 22 strip. 23 A. Yes. 23 A. Yes. 24 Q. Had you been to yet? 24 Q. And did you say, l don't really want to be a 25 A. Yes. 25 stripper? 6 (Pages 277 to 280) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. ' (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1652) Electronically signed by Pamela Sullivan (501.333.772-1552) 9205662-36a5-4202-a350-6633a5c6813b EFTA00750779  Page 281 Page 283 1 A. At first I did, yes. 1 Q. Where did you get them? 2 Q. And so why did you do it? 2 A. I got a lot of them from the flea market. 3 A. Because I needed money. 3 Q. 45th Street? 4 Q. Well, you could have applied for other jobs; 4 A. Yes. 5 couldn't you? 5 Q. And they have stripper outfits'? 6 A. I tried to apply at a few places, and I never 6 A. Yes. 7 got the job. 7 Q. Did a show you any of her tricks of the 8 Q. Well, you applied for what, one or two places 8 trade, so to , so you could make money? 9 in the mall? 9 A. She just showed me how to dance. 10 A. I applied at some restaurants and some other 10 Q. Did she show you before you went up there 11 places I don't exactly remember. 11 that fast time? 12 Q. So you go down with to 12 A. Yes. 13 A. Yes. 13 Q. Where did you — did you practice at home — 14 Q. And you talked to1= 14 or at her home? 15 A. Yes. 15 A. No. 16 Q. Is he the one who hired you? 16 Q Where did you practice, or didn't you? 17 A. Yes. 17 A. At 18 Q. Did you have any experience dancing. 18 Q. So you ill:Practice during the day before 19 stripping? 19 you actually ended up on stage? 20 A. No. No. 20 A. Yes. 21 Q. And what did you have to do in order to get 21 Q. Did you know any of the other girls who 22 the job? 22 worked at before you went? 23 A. Show them my ID. 23 A. No. 24 Q. And did he say, have you stripped before? 24 Q. Did you ever work at a place where - 25 A. No. 25 worked? Page 282 Page 284 1 Q. Did he ask you any questions at all? 1 A. No. 2 A. No. 2 Q. Were you aware where worked? 3 Q. Had you ever danced before anyplace? 3 A. No. 4 A. No. 4 Q. Okay. Were you ever aware that 5 Q. Did tell you how — show you how you'd 5 6 have to dance, in order to make money? 6 at .A 10. 7 A. Yes. 7 Q. Do you know what a jack shack is? 8 . Oka . During the time you worked at 8 A. I've heard of it. did you have a stage name, or did 9 Q. Okay. Do you know whether M. worked 10 you just use your own name? 10 shacks? 11 A. Yes, I did. 11 A. Not that I know of. 12 Q. Yes, you did what? Have a stage name? 12 Q. Did you ever ask ha'? 13 A. I had a stage name. 13 A. Na 14 Q. What was your stage name? 14 Q. Do you know a lady -- a person named a? 15 MR. EDWARDS: Form. 15 A. No,I do not. 16 THE WITNESS: 16 Q. You sure? 17 BY MR.CRITrON: 17 A. Yes. 18 Q. 18 She's a fried ofE's. You don't know 19 20 A. Yes. Q. Okay. And what kind of outfits did you wear? 19 20 a? MR. EDWARDS: Object to the form. Asked and 21 Did you have one outfit that was like the -- your 21 answered. 22 trademark, so to speak? 22 THE WfTNESS: I don't know her. 23 A. No. 23 BY MR. CRITTON: 24 Q. What kind of outfits did you wear? 24 Q. What were your hours at 25 A. Stripper outfits; I don't know. 25 A. Seven to 2:00. 7 (Pages 281 to 284) (561) 8 32-7 500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1652) 92et5b62-38x5.4202.a350.6633a5c6813b EFTA00750780  Page 285 Page 287 1 Q. Seven p.m. -- 1 Have you ever had any kind of plastic surgery? 2 A. Yes. 2 A. No. 3 Q. — to 2:00 in the morning? 3 Q. Any kind of had any kind of breast 4 A. Yes. 4 implants? 5 Q. Okay. And how were you paid? 5 A. No. 6 A. Tips. 6 Q. In tents ofa in addition to Q. Did you have to share any with the house? 7 doing the dancing on the stage, did you ever do bachelor a A. Yes. 8 parties? 9 Q. And what was the percent that you got to 9 A. No. 10 keep, and the percent that you had to pay the house? 10 Q. Okay. Did you do lap dances? 11 A. I just had to tip the DJ and the manager like 13. A. Yes. 12 $15 each, or something. 12 Q. And how much did you charge for a lap dance? 13 Q. Okay. And how much did you make generally a 13 A. There was a house fee, so it was like 25 or 14 night? 14 $30 for like one song. 15 A. I don't know. Couple of hundred dollars. 15 Q. So in addition to your stage dancing, where 16 MR. EDWARDS: Speak a little bit louder, just 16 you get tips, you also did lap dances? 17 so that they can hear you. 17 A. Yes. 18 BY MR. CRITTON: 18 Q. All right. And 'Awe they friction dances? 19 Q. Couple ofhundred dollars? 19 A. Yes. 20 A. Yes. 20 Q. And in terms of the men that you — and these 21 Q. Okay. Did you ever make more than that? 21 were always all with men; I assume. Any women? Did you 22 A. Not really. 22 have to do lap dances for women at times, too? 23 Q. That was pretty much your average take? 23 A. Like once or twice. 24 A. Yes. 24 Q. And when you would do the lap dances for the 25 Q. How many days a week did you work? 25 men, in addition to the house charge, you would try to Page 286 Page 288 1 A. Whenever I wanted to. 1 do more so that you could get a bettor tip; true? 2 Q. All right. How many days a week did you want 2 A. No. 3 to work? 3 Q. Okay. Well, you were doing friction dances, 4 A. Sometimes it was every night; sometimes it 4 and flictice dances are where you're rubbing up against 5 was one or two nights. 5 the men; right? 6 Q. And how would you decide, just if you needed 6 A. Yes. 7 money? 7 Q. All right. And men get erections; truc? 8 A. Pretty much, or if I felt like it. 8 MR. EDWARDS: Object to the form. 9 Q. In addition to doing — you'd dance and you'd . 9 THE WITNESS: That's probably true, but I 10 take your clothes off; right? 10 never touched anybody at the strip club there. 11 A. Yes. 11 BY MR. CRITTON: 12 • Q. Okay. And did you take all your clothes off? 12. Q. OkaySo u're saying you danced for eight 13 A. Yes. 13 months at you're doing friction dances, 14 Q. Okay. Everything, tops and bottoms? 14 dancing with men, and it's your testimony you never 15 MR. EDWARDS: Object to the form. 15 know you never knew whether any of them ever got an 16 THE WITNESS: Yes. 16 erection; is that true? 17 BY MR. CRITTON: 17 MR. EDWARDS: Fenn. 18 Q. And you did that sometimes seven days a week, 18 THE WITNESS: Yes: 19 • sometimes only two or three or four times a week, for 19 BY MR. CRITTON: 20 eight months; is that correct? 20 Q. Did you -- did they have a champagne room. or 21 A. Yeah. Sometimes I didn't go for two weeks 21 some equivalent ofthat, at — excuse me — 22 and, you know, I — I just went whenever I felt like it. 22 23 I mean, sometimes I didn't go for a month. 23 A. Yes. 24 . Did — and and prior to starting at 24 Q. Okay. Did you ever go back into the 25 or let me ask you — ask you this: 25 champagne room? 8 (Pages 285 to 288) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 1561) 832-7506 Electronically signed by Pamela Sullivan (5014334124652) Electronically signed by Pamela Sullivan (601.333.772-1652) 92efSb62-38a5-4202-a350-6633a5c6813b EFTA00750781  Page 289 Page 291 1 A. Yes. 1 BY MR. CRITTON: 2 Q. On how many occasions? At least once a week? 2 Q. And did you get more money for that, as well? 3 Twice a week? More? 3 A. Yes. 4 A. I don't — 4 Q. Okay. And did you strip naked in the 5 MR. EDWARDS: Form. 5 champagne room? 6 THE WITNESS: I don't know. Once a week. 6 A. I didn't take my bottoms off. 7 BY MR. CRITTON: 7 Q. Took your top off? 8 Q. All right. And when you would go back in the 8 A. Yes. 9 champagne room, it would be you and — and just one man, 9 Q. And then you did a — would it be a fair 10 generally? 10 statement to say that would have been a serious friction 11 A. And a bouncer outside the door. 11 dance in the champagne room? 12 Q. Okay. So ifyou needed help, or if 12 A. No. It just made it so that other people 13 something -- • 13 couldn't see. 14 MR. EDWARDS: Form. 14 Q. All right. Well, is — isn't it true, when 15 BY MR. CRITTON: 15 you went into the champagne room, there's — oftentimes 16 Q. — happened that was inappropriate, then you 16 there was some form of sex that occurred? 17 can call for the bouncer? 17 MR. EDWARDS: Fenn. 18 A. Yes. 18 THE WITNESS: That is not true. 19 Q. Okay. And just when you were at -- when you 19 BY MR. CRITTON: 20 were at that club, if something inappropriate happened, 20 Q. So it's your testimony that in all of the 21 you could turn around and say you could leave the 21 times that you went in the champagne room, that you 22 room; right? 22 never had any type of sexual activity with the men in 23 A. Yes. 23 the champagne room? 24 Q. All right And you — and you knew that -- 24 A. That is correct 25 A. Yes. 25 Q. And consistent with what you told me earlier, Page 290 Page 292 1 Q. — that if something inappropriate happened, 1 you never even saw whether a man got an erection when 2 and that you could leave the room, because it was -- it 2 you were in those rooms; is that your testimony? 3 was voluntary for you to either go into the room or not 3 A. Yes. 4 go into the room? 4 Q. During the time you worked at 5 A. Yes. 5 how many men did you go home with? 6 Q. You could stay as long or as little as you 6 A. Zero. 7 warn? 7 Q. In addition to -- did you ever do a bachelor