EFTA00157838.pdf

0166 I UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 CASE NO. 08-CIV-80119-MARRA/JOHNSON 3 4 5 Plaintin, 6 -vs- VOLUME II OF II 7 JEFFREY EPSTEIN, 8 Defendant. 9 10 Related cases: 11 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 12 09-80591, 09-80656, 09-80802, 09-81092 13 14 15 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF 16 -■- 17 18 December 4, 2009 10:25 - 5:00 p.m. 19 20 West Palm Beach, Florida 21 22 23 Reported By: Cynthia Hopkins, RPR, FPR 24 Notary Public, State of Florida Prose Court Reporting 25 0167 I APPEARANCES: 2 On behalf of 3 4 5 6 7 8 On behalf of the Defendant, Jeffrey Epstein: 9 ROBERT D. CRITTON, JR., ESQUIRE MARK T. LUTTIER, ESQUIRE 10 BURMAN, CRITTON, LUTHER & COLEMAN, LLP 11 West Palm Beach, Florida lilcifiCl/Documentstleand%20Scitings/ProductionMesktop/M. -%20Vol.%2011.txti12/11/2009 6:15:58 PNI1 3505.044 Page I of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005389 EFTA00157838  12 Phone: 13 14 15 ALSO PRESENT: 16 stein via video conference 17 Paralegal, P.A. 18 19 Stan Sanders, Videographer Visual Evidence, Incorporated 20 21 22 23 24 25 0168 I 2 INDEX VOLUME II 3 4 5 WITNESS: DIRECT CROSS REDIRECT RECROSS 6 7 CONTINUED 8 BY MR. LUTTIER 170 9 10 11 12 EXHIBITS 13 14 15 EXHIBIT DESCRIPTION PAGE 16 DEFENDANTS NO. 1 11 17 Plaintiffs Notice of Serving Second Amended Answers to Interrogatories 18 DEFENDANT'S NO. 2 29 19 Answers of Interrogatories 20 DEFENDANTS NO. 3 119 First Amended Complaint 21 DEFENDANT'S NO. 4 254 22 Plaintiffs Notice of Serving Third Amended Answers to Defendant's First 23 Interrogatories 24 25 0169 1 gi sts: 2 THE VIDEOGRAPHER: We're going back on the 3 record at 2:42. 4 BY MR. LUTTIER: 5 Q. Mom -- ma'am, at the break we had just file://fq/Documentstleand%20SettingsRroduction/Desktop .% ' 20-%20Vol.%2011.txtl12/11/2009 6:15:58 PM1 3505.044 Page 2 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005390 EFTA00157839  6 been discussing your relationship with aa 7 le You used the phrase in your testimony 8 earlier, you used the phrase "eat out." Could you 9 describe what that phrase means in the context that 10 you were usin it? 11 MR. : We will stipulate that what 12 it means is cunnilingus. 13 BY MR. LUTHER: 14 Q. Oka . Do ou know what a sex toy is? 15 MR. : Could you explain what 16 relevance or materiality your understanding of 17 that line -- 18 MR. LUTTIER: Sure. It was -- 19 MR. : -- of questioning might have 20 since there is no allegation that sex toy 21 ever employed in encounters between and 22 Mr. Epstein? 23 MR. LUTTIER: Well, I dispute that for 24 sure. I just tell you if you read the record 25 carefully, you will find out that is not at all 0170 1 true, and that's why it is relevant. Come up 2 many a 3 MR. : In connection with 4 allegations from 5 MR. LUTTIER: There and in the . 6 MR. : Okay. Well, if you 7 represent, if you represent that that's the 8 case, then proceed. 9 BY MR. LUTTIER: 10 Q. Do you know what a sex toy is? 11 A. Yes. 12 Q. Okay. And what is your understanding of 13 that term so that we are understanding each other 14 when I ask you these questions? 15 A. I guess toys used doing sexual things. 16 Q. Okay. And that would include, for 17 example, vibrators? 18 A. Yes. 19 Q. Dildos? 20 A. Yes. 21 Q. Have you used sex toys in the past? 22 A. No. 23 Q. Never? 24 A. Never. 25 0171 2 Q. Did you ever tell anybody you had? 3 A. No. 4 Q. Did you, did you ever use any sex toy with 5 Jeffrey Epstein? 6 A. He tried to use a massage thing and I told him 7 no. file:///q/Documents%20and%20ScitingsRroduction/Dcsktoe%el ,20-5£20Vol.%2011.txti12/11/2009 6:15:58 PM] 3505.044 Page 3 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005391 EFTA00157840  8 Q. What did you mean by "massage thing"? 9 A. Whatever it was in the hell that he had. 10 Q. Well, what -- describe what you are 11 talking about. 12 A. 'just told you. 13 Q. Well, massage thing doesn't tell me 14 anything. What are you talking about? 15 A. I don't know what it was called. I don't know 16 what it is. 17 Q. What did it look like? 18 A. It looked -- it was -- I don't know. It 19 vibrated. It looked like it was a neck massager. 20 Q. But do you know, do you know -- can you 21 describe, physically describe how big it was, what 22 color it was, what it looked like? Can you describe 23 anything about it? 24 A. It was gray and do you want me to draw you a 25 picture because I don't know how to describe what it 0172 1 looked like. 2 Q. How large was it? 3 A. It was like this big (indicating). 4 Q. Okay. 5 A. It was like a neck massager. 6 Q. You know like -- you know what Brookstone 7 is, a store? 8 A. Yeah. 9 Q. Have you ever been in there and they have 10 these massages that, like you can reach behind your 11 back and stuff like that. Are we talking about 12 something you know, like that? 13 A. Yeah, but it didn't have a wire, an electrical 14 wire. 15 Q. Okay. 16 A. It was like battery operated. 17 Q. And you say that Mr. Epstein tried to use 18 this on you and you said no? 19 A. Yeah. 20 Q. And then he -- 21 A. That was the end of that. 22 Q. -- didn't use it? 23 A. He did not, and he's never, it never was 24 brought up again. 25 Q. Have you ever desired to use any kind of 0173 1 sex toy? 2 A. No. 3 Q. And, and then not done it for some reason? 4 A No 5 6 7 8 9 file:///CVDocumentstleand%20Sctfings/Production/Deskiony 't 2iiVol ' 2011.ixill1/11/2009 6:15:58 PMJ 3505.044 Page 4 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005392 EFTA00157841  10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 017 2 3 4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 017 2 3 4 5 6 7 8 9 10 11 file:///q/Documentstleand%20Scllings/Production/Deskiopie2M20-%20Vol.%2011.uall1/11f2009 6:15:58 PM] 3505.044 Page 5 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005393 EFTA00157842  12 13 14 15 16 17 18 19 20 21 22 23 24 25 0176 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0177 1 2 3 4 5 6 7 8 9 10 11 12 13 file://fq/Documentstleand%20Settings/Production/Deskio1M.q. 20-%20Vol.%2011.txil I VIltzom 6:15:58 PNI1 3505.044 Page 6 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005394 EFTA00157843  14 15 16 17 Q. With respect to the incident that you were 18 describing earlier when you were at Mr. Epstein's 19 house and you said there was another woman present 20 who was nude, do you recall that testimony? 21 A. Yeah. 22 Q. And was there any discussion between you 23 and she before she began to perform oral sex on you? 24 A. And I told you no. 25 Q. No words at all exchanged? 0178 A. No. 2 Q. So you were just standing there and 3 this -- 4 A. Yeah. 5 Q. And what, if anything, did you say when 6 this person began to perform oral sex on you? 7 A. I didn't say anything. I just felt really 8 weird and I just stood there. 9 Q. And this is a person you had never seen 10 before? 11 A. Yes. 12 Q. And for how long a period did this person 13 perform oral sex on you? 14 A. I don't know. 15 Q. And this is while you were standing? 16 A. Yeah. 17 Q. Did, did it, when you say you don't know, 18 are we talking about this went on for 15 or 20 19 minutes or this went on for three minutes? 20 A. Like 15, 20 minutes. 21 Q. Okay. Did you, did you move from where 22 you were standing to some other location while she 23 was doing this? 24 A. I just said no. 25 Q. Did you have an orgasm -- 0179 1 A No 2 Q. -- as a result of her performing? Did you 3 at any time during the 15 or 20 minutes that she was 4 performing oral sex on you say anything to her? 5 A. Yeah, I told her to stop. 6 Q. And when did you tell her to stop? 7 A. After like 15 minutes, I told her to stop and 8 that I felt uncomfortable. 9 Q. And what did she do? 10 A. She stopped. And I told Jeffrey I wanted to 11 leave, and he gave me $300 and I left. 12 Q. So, the first time you told this lady to 13 stop, she stopped? 14 A. Yeah. 15 Q. And you told Jeff you wanted to leave and file:///CVDocuments%20and%20Scitings/Production/Desktop .Ma0-%2OVol.%2011.txt112/11/20D9 6:15:58 PM] 3505.044 Page 7 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005395 EFTA00157844  16 he didn't try to stop you? 17 A. No. 18 Q. Did you perform any sexual act on this 19 woman? 20 A. No. 21 Q. Did you touch her in any way? 22 A. No. 23 Q. And at the time that you were standing 24 there and this lady was performing oral sex on you, 25 I assume she was kneeling or something? 0180 A. Yes. 2 Q. And where was Mr. Epstein during this? 3 A. Behind her having sex with her. 4 Q. While she was kneeling? 5 A. Yeah. 6 Q. Did you say anything to Mr. Epstein? 7 A. Besides that I wanted to leave, no. 8 Q. Which you said after 15 minutes, right? 9 A. Yeah. 10 Q. How about during the first 15 minutes, did 11 you say anything at all? 12 A. No. 13 Q. Did you say, you know, I am uncomfortable 14 with the set-up; I want to leave? 15 A. 'just said no. 16 (Interruption at the door.) 17 18 19 20 21 22 23 24 25 0181 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 file://fq/Documentstleand%20ScuingsRroduction/Desktop 9a20-%20Vol.%2011.Lxii I VI 1/2009 6:15:58 PNI1 3505.044 Page 8 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005396 EFTA00157845  18 19 20 21 22 23 24 25 0182 2 3 4 5 6 7 8 9 10 I 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0183 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 file:///CVDocumentstleand%20Scuings/Production/Deskiopt i. 1M1-%20Vol.%2011.txti 121112(X19 6:15:58 PN11 3505.044 Page 9 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005397 EFTA00157846  20 21 22 23 24 25 018 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 018 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 file:/NC /Documentstleand%20Scuings/ProductionMeskion 21M20-5£20Vo1.562011.txti 12111/2069 6:15:58 PMJ 3505-044 Page 10 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00005398 EFTA00157847  22 23 24 25 0186 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0187 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 file:///C /Documentstleand%20SettingsRroduction/Desktop %2=20-%20Vol.%2011.txti 12111/2009 6:15:58 PM 3505.044 Page II o167 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005399 EFTA00157848  24 25 0188 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 0189 I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 file://tCpflocuments%20and9420Scuings/Production/Desktop .%20M20-%20Vol.%2011.txti 12111/2009 6:15:58 PMJ 3505-044 Page 12 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005400 EFTA00157849  0190 1 2 3 4 5 Q. Do you know other women that have brought 6 claims against Mr. Epstein? 7 A. Yes. 8 Q. What other women do you know that have 9 brought claims against Mr. Epstein? 10 A. That's not my information to give you. 11 Q. My question stands. 12 A. I don't feel comfortable telling him. 13 MR. : Well, if you know the names 14 of other women who you know have brought 15 claims. 16 THE WITNESS: I know El has. I don't 17 know her last name. And I found out after I 18 filed my suit. 19 BY MR. LUTTIER: 20 Q. Anyone else? 21 A. Not that I know of, that are my friends. 22 Q. Well, misstion -- 23 A. Me and haven't talked since this accident 24 just for the record. 25 Q. My question wasn't limited to your 0191 1 friends. My question was did you know other women, 2 do you know other women that have brought claims to, 3 against Mr. Epstein? 4 A. Personally, no. 5 Q. Well, how would you know them if you 6 didn't know them personally? 7 A. I said no. 8 Q. Well, I'm, I'm getting the impression that 9 you're, yasfr being -- 10 A. I= is the only person that I know that has. 11 Q. And what did you mean when you answered 12 earlier to my question when I asked you if you knew 13 other women that had brought claims against 14 Mr. Epstein, you answered yes? 15 A. And you wrote down.' did you not? 16 Q. That's the only person that you were 17 referring to? 18 A. Yes. 19 Have you ever heard of a lady by name of 20 21 A. 22 23 A. No. 24 Q. Who -- all right. arrson,e, how 25 do you know this person, , 0192 I A. She was a friend of mine. file://flifilocuments%20and%20ScitingsRroduclion/Dcsktop .%21a20Vol.%2011.txt112/11/20D9 6:15:58 PM] 3505.044 Page 13 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000540 1 EFTA00157850  2 Q. And she was a friend of yours commencing 3 when? When did you first meet her? 4 A. I don't remember. Years ago. 5 Q. Before you went to see Mr. Epstein? 6 7 A. No. She, I met her through my friend Q. &-- what's es name? • 8 A. 9 Q. Do you know any other girls that claim to 10 have gone to Mr. Epstein's house to perform massages 11 on him? 12 A. Do what? 13 Q. Do you know any other girls that have gone 14 to Mr. Epstein's house and claimed to have performed 15 massages oli? 16 A. Me, and. those are the only girls 17 that I know. 18 . And how is it that you met through 19 20 A. How do you meet your friends through friends? 21 Q. I have no idea. I mean, were you guys at 22 a party together, did you get on the phone with each 23 other? What did you do? 24 A. We were hanging out. 25 Q. "Hanging out," what's that mean? 0193 A. When you hang out. 2 Q. Were you at a function and all three of 3 you were there, for example? 4 A. Obviously we were at something hanging out. 5 Q. And did there come a time that you took 6 anyone to Mr. Epstein's house? 7 A. Yes. 8 Q. When was that? 9 A. I don't remember the times and dates but I 10 took and 11 12 Q. &which did you take first? A. 13 Q. And in respect to when you went to 14 Mrgpstein's between May and .las_of and August 15 of'. when was it that you took ='? 16 A. Bro, I don't know. I just told you I don't 17 know times and dates. 18 Q. I realize don't know the exact time. 19 But was it in or was it in IM? 20 A. If I, if you know that I don't know the dates, 21 how would you ask me if it was in _≥ 22 Q. Well, what's your best estimate of how 23 manyes you had made to Mr. Epstein's before you 24 took 25 A. I have no idea. 0194 1 Q. More than ten? 2 A. Probably. 3 Q. How long had you known. before you file:///q/Documents%20and%20Settings/Production/Dcsktop %20Carolyn%20-%20Vol.%2011.txti 12111/2009 6:15:58 PMI 3505.044 Page 14 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005402 EFTA00157851  4 took her to Mr. Epstein's? 5 A. I have known. for years. I met El I 6 don't know. Ask me the question a am please. 7 Q. How long had you known before you 8 took her to Mr. Epstein's? 9 A. For about a year. 10 Q. And how did you meet? 11 A. She lived down the street from me. 12 Q. Was she a close friend? 13 A. Yes, she was. She was my best. 14 Q. You wouldn't do anything to harm her, 15 correct? 16 A. Correct. 17 Q. By the time you took. to 18 Mr. Epstein's, you had performed massages for 19 Mr. Epstein in the total nude; is that correct? 20 A. Uh-huh. 21 THE COURT REPORTER: Is that a yes? 22 THE WITNESS: Yes. 23 BY MR. LUTTIER: 24 Q. You had already had this sexual 25 relationship with this woman that you described 0195 I earlier at Mr. Epstein's? 2 A. Yes. 3 Q. You mentioned earlier that on these 4 occasions when you gave Mr. Epstein a massage, he 5 would masturbate I believe you said; is that right? 6 A. Yes. 7 Q. Did that occur, that is Mr. Epstein 8 masturbating, on each and every occasion when you 9 went to Mr. Epstein's from the first occasion to the 10 last occasion? 11 A. Yes. 12 Q. Did you physically see him masturbating? 13 A. Yes. 14 Q. That is there was no towel covering his 15 genitalia or anything like that? 16 A. No. 17 18 19 20 21 22 23 24 25 0196 2 3 4 5 file://fq/Documentstleand9420ScuingsRroduclion/Dcsktop .%21M0-%20Vol.%2011.txtl12/11/2009 6:15:58 PM] 3505.044 Page 15 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005403 EFTA00157852  6 7 8 9 10 1 12 13 14 15 16 17 18 19 Q. Had, have you ever been photographed in 20 the nude? 21 A. No. At Mr. Epstein's, yes. 22 Q. How about any place other than 23 Mr. Epstein's? 24 A. No. 25 Q. And who photographed you in the nude at 0197 Epstein's? 2 A. 3 Q. who? 4 A. 5 Q. And when in this time period that you went 6 to Mr. Epstein's did photograph you in the 7 nude? 8 A. It had to have been in the summer. It was in 9 the summer. 10 Q. And why do you know it was in the summer? 11 A. Because it was summertime. 12 Q. And where did this photographing occur? 13 A. In Mr. Epstein's house. 14 Q. Where in the house? 15 A. Everywhere in the house, outside by the pool, 16 and outside off the dock by the Intracoastal. 17 Q. Were you photographed on more than one 18 occasion? 19 A. No. 20 Q. Let me rephrase the question. You 21 mentioned that you were photographed everywhere in 22 the house? 23 A. Yes. 24 Q. Was there -- 25 A. It was in the same day. 0198 Q. But more than one picture was taken? 2 A. Yes. 3 Q. All right. And what type of, do you know 4 what type of camera was used? Was it a digital 5 camera or a -- 6 A. A digital camera. 7 Q. All right. file:///q/Documentstleand%20Scuings/Production/Desktop .a20-%20Vol.%2011.txtl12/11/2009 6:15:58 PM] 3505.044 Page 16 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005404 EFTA00157853  8 A. It was digital -- it wasn't like a digital 9 camera like, it was like a photography digital camera 10 like a professional camera, a professional digital 11 photography camera. 12 Q. Are you, are you -- 13 A. Not like one you buy at Wal-Mart. 14 Q. When you're describing it as a 15 professional digital camera, are you talking about a 16 camera that's got a big lens on it? 17 A. Yes. 18 Q. And did this -- 19 A. And there, and there was a regular digital 20 camera. She used two different cameras. 21 Q. And you say this was, in addition to being 22 in the house, was that on a dock? 23 A. Yes. 24 Q. And, and were you completely nude for all 25 of these photographs? 0199 1 A. Yes. 2 Q. So this happened in the daytime? 3 A. Yes. 4 Q. I assume the dock is out somewhere near 5 the Intracoastal? 6 A. Yes. 7 Q. Out in plain view? 8 A. But there was nobody outside. I made sure 9 there was nobody that could see me. 10 Q. Had anyone before that occasion ever 11 photographed you in the complete nude? 12 A. And I already said no. 13 Q. And how many photographs would you 14 estimate were taken? 15 A. I don't know. At least ten. 16 Q. Did you -- how, how is it that it -- well, 17 strike that. 18 Did, did ask you if she could take 19 photographs of you in the nude? 20 A. She called me and told me that Mr. Epstein 21 would pay me $500 if there could be nude pictures taken 22 of me. And my words to her were only if you take them; 23 I will not let Mr. Epstein take them of me. 24 Q. All right. So you set the conditions 25 under which the photographs were to be taken? 0200 1 A. Yes. 2 Q. And the photographs were taken with your 3 knowledge and consent, correct? 4 A. (Witness nods head.) 5 Q. Did you ever see the photographs? 6 A. Since that day, no. I saw them on the camera. 7 I've never seen the actual photographs. 8 Q. Did you make any comment to about 9 the photographs? file:///CVDocumentstl eand%20Salings/Production/Deskiona 20-%20Vol.%2011.txti12/11/2009 6:15:58 PM) 3505.044 Page 17 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005405 EFTA00157854  10 A. Yeah, I asked them what would happen with 11 them, and she told me that they were for Mr. Epstein's 12 personal enjoyment. 13 Q. Was Mr. Epstein present when these 14 photographs were taken? 15 A. No, not to my awareness. 16 Q. You -- that is on the occasion that you 17 went to the house when these photographs were taken, 18 you never saw Mr. Epstein? 19 A Yet I didn't tee Mr Pntgrin Nn 20 21 22 23 24 25 0201 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 0202 1 2 3 4 5 6 7 8 9 10 11 file://fq/Documentstleand%20Scllings/Production/Deskia.%20M20-%2OVol.%2011.txtl12/11/20D9 6:15:58 PM] 3505.044 Page 18 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005406 EFTA00157855  12 13 14 15 16 17 18 19 20 21 22 23 24 25 0203 I 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0204 2 3 4 5 6 7 8 9 10 11 12 13 file:///Cl/Documents%2Dand%20Scuings/Production/Deskiop/MISi2M120-%20Vol.%2011.txtr12/11/20D9 6:15:58 PMJ 3505.044 Page 19 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005407 EFTA00157856  14 15 16 17 18 19 20 21 22 23 24 25 0205 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0206 2 3 4 5 6 7 8 9 10 12 13 14 15 file:///q/Documents%20and%20Scuings/Production/Desktop .%20e1-%20Vol.%2011.txti 12/1120096:15:58 PMJ 3505.044 Page 20 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005408 EFTA00157857  16 17 IS 19 20 21 23 24 25 020 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Q. When did you first meet Mr. 21 A. When I was 13. 22 Q. Did you, did you meet him before you first 23 went to Mr. Epstein's? 24 A. Yes. 25 Q. Had you had a sexual relationship with 0208 1 Mr. =, obviously? 2 A. Yes. 3 Q. Had you had sex with Mr. before you 4 went to Mr. Epstein's the first time? 5 A. Yes. 6 Q. And what sexual acts had you engaged in 7 with Mr. before you went to Mr. Epstein's? 8 A. Intercourse. 9 Q. And did you consider Mr. to be your 10 boyfriend? 11 A. Yeah. 12 Q. And were you dating him during the entire 13 period of time that you went to Mr. Epstein's? 14 A. Yeah. 15 Q. And did Mr. ever physically bring 16 you to Mr. Epstein's house? 17 A. Yes. file:///q/Docurnents%20and%20Scuings/Production/Deskia.%a0-%2OVol.%2011.txt112/11/2009 6:15:58 PM] 3505-044 Page 21 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005409 EFTA00157858  18 Q. Did you ever pay Mr. any money for 19 bringing you to Mr. Epstein's house? 20 A. No. 21 Q. Did Mr. ever bring anyone else to 22 Mr. Epstein's house? 23 A. My brother came with us but he didn't bring 24 any other females, 25 Q. How about II? 0209 1 A. Oh,IS and when I went with them. He 2 didn't bring them there by themselves. 3 Q. Let me go back and make sure my question 4 is clear. Was there, was there ever an occasion 5 that Mr. drove a vehicle in which there were 6 other girls that were delivered to Mr. Epstein's 7 house other than just yourself? 8 A. You say delivered like we're a bunch of 9 flowers for him. 10 Q. Pick whatever, what word would you prefer, 11 dropped off? 12 A. Yes, that sounds a lot more better than 13 delivered. 14 Q. Fine. Whateysixtv want. Ever any 15 occasion where Mr. brought any females that 16 he dropped off at Mr. E stein's other than -- 17 A. Yes,me and ., and me and 18 Q. Did In. or ever pay 19 money for bringing them? 20 A. No. 21 Q. Did you ever receive any money from 22 Mr. Epstein for bringing 23 A. Yes. 24 Q. How much did you get? 25 A. An extra $100. 0210 1 Q. And did you tell S. that you were paid 2 $100 by Mr. Epstein to bring her to him? 3 A. Yes. 4 Q. And what was her response? 5 A. I want half. 6 Q. And what did you say to that? 7 A. Okay. 8 Q. So, you gave her 50 of the $100? 9 A. Yeah. 10 Q. And everybody was happy? 11 A. Yeah. 12 Q. Did you bring S. on more than one 13 occasion? 14 A. Yes. 15 Q. Did you get paid $100 on each occasion -- 16 A. Yes. 17 g. -- that you brought S.? Did you tell 18 on each occasion when you got paid $100 to 19 bring her? file:///q/Documents%20and%20Scifings/ProductionMesktaM:1-%20Vol.%2011.txt[12/11/2009 6:15:58 PM] 3505-044 Page 22 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005410 EFTA00157859  20 A. Yes. 21 Q. And did you give her half the 100 or S50 22 every time -- 23 A. Yes. 24 Q. -- that you were paid? On how many 25 occasions did bring S. and get paid $100? 0211 A. Three or four times. 2 Q. How much did S. get paid to come to 3 Mr. Epstein's? 4 A. 200, sometimes three. I'm not sure which 5 times. Probabl the times when she went there herself. 6 Q. Did M. go to Mr. Epstein's on occasions 7 other than when she went with you? 8 A. Yes. 9 Q. But she had never been there until you 10 took her the first time? 11 A. Yes. 12 Q. Were the individual that first 13 suggested to M. that she go to Mr. Epstein's? 14 A. Obviously if I'm the one who brought her there 15 for the first time. 16 Q. Well, it would be possible that she could 17 have heard of Mr. Epstein from someplace else. 18 A. No. 19 Q. So the first time she heard the name 20 Jeffrey Epstein was from you? 21 A. Yes. 22 . And on the first occasion when you told 23 about Jeffrey Epstein, what did you tell her? 24 A. That we would go there and give him a massage 25 and he might ask you to get topless. 0212 1 Q. Did you tell her at the time that you 2 first discussed it with her everything that you had 3 experienced in going to Mr. Epstein's? 4 A. No. 5 Q. Why not? 6 A. Because I knew she wouldn't be exposed to it. 7 Q. And this was your best friend? 8 A. Yes. 9 Q. And you say you knew what? 10 A. I knew that she wouldn't be exposed to it. 11 Q. What do you mean she wouldn't be exposed 12 to it? 13 A. Because I knew that I felt uncomfortable with 14 the thing with the girl. And I told Jeffrey if he did 15 it to my friends, I would not bring them. 16 Q. Okay. 17 A. So I knew that she wouldn't have been exposed 18 to it. 19 Q. So, in your, you had some conversation at 20 some point in time with Jeffrey Epstein about -- 21 A. I took -- when he asked me to bring some girls file://fiCYDocuments%20and%20ScitingsRroduction/Deskiop/Ml.q a-Vi20Vol.%2011.txtl12/11/2009 6:15:58 PM] 3505.044 Page 23 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFfA_000054II EFTA00157860  22 my age, I told him that I would not bring my friend if, 23 if that situation was to occur with her because I didn't 24 like it. I felt uncomfortable, and I would not subject 25 my friend to it. 0213 1 Q. Is that the only thing that had occurred 2 lyign you were at Mr. Epstein's that you did not tell 3 about? 4 A. Yes. 5 Q. So, you had told M. that Mr. Epstein 6 might masturbate while she was there? 7 A. Yes. 8 Q. Did you tell her that he might ejaculate 9 while she was there? 10 A. Not on her but yes. 11 Q. Well, did Mr. Epstein ever ejaculate on 12 you? 13 A. No. 14 Q. All right. What did you tell M. before 15 you took her there for the first time about what the 16 state of dress that she would be in? 17 A. I just told her to wear clothes. 18 Q. Did you tell her that she may be asked to 19 be totally nude? 20 A. I said that she, she might ask to take off 21 some of her clothes. I didn't specifically say you're 22 going to have to get naked. 23 Q. But you had been, at that point in time 24 that you first took M. there, you had been totally 25 nude for months while performing massages for 0214 1 Mr. Epstein, correct? 2 A. So. 3 Q. Correct? 4 A. Yes. 5 Q. But you didn't tell your best friend that? 6 A. No, because if he was going ask her, that 7 would be him asking her and that would be her own 8 decision. 9 Q. You didn't consider there to be anything 10 dangerous about going to Mr. Epstein, did you? 11 A. No. 12 Q. I mean, you never felt like you were in 13 danger when you went to Mr. Epstein's did you? 14 A. No. 15 Q. You never felt that any harm was going to 16 come to you? 17 A. No. 18 Q. And you really never had any fear about 19 going there, correct? 20 21 22 23 file:///CVDocumentstleand9420ScuingsRroduclion/Deskiopa 1MI-%20Vol.%2011.txtl12/11/20D9 6:15:58 PM] 3505-044 Page 24 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005412 EFTA00157861  24 25 0215 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0216 1 2 3 4 5 6 7 Q. Did there -- there obvio a time 8 that you got pregnant with Mr. 9 A. Obviously. 10 Q. Did you and Mr. leave the State of 11 Florida together at some point in time? 12 A. Yes. 13 Q. And approximately when was that? 14 A. I was in July when I was 16. 15 Q. 16 A. eah. 17 Q. Is that the same time that you stopped 18 going to Mr. Epstein's? 19 A. Uh-huh. 20 Q. And is that, in fact -- 21 MR. LUTTIER: Did you get that answer? 22 THE COURT REPORTER: Uh-huh. 23 BY MR. LUTTIER: 24 Q. -- is that in fact why you stopped l 25 to Mr. Epstein's, because you and Mr. were file:ffill/Documents%20and%20Settings/Production/Deskton %20Vol.%2011.txt[12/11/20D9 6:15:58 PMJ 3505.044 Page 25 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005413 EFTA00157862  0217 1 leaving? 2 A. Yes. 3 Q. And where did ,ou and Mr. go? 4 A To 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 021 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0219 file://fq/Documentstleand%20ScItingsRroduclion/Dcsktop .%a20-%20Vol.%2011.txt112/11/2009 6:15:58 P141 3505.044 Page 26 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00005414 EFTA00157863  2 3 4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 there a point in time that you and 23 Mr. returned to Florida? 24 A. Yes. 25 Q. When was that? 0220 A. When I was months pregnant. So. in 2 February. 3 Q. Of 1? 4 A. Yeah. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 022 2 3 file:///q/Documentstleand%20SettingsRroduction/Dcsktop %2=20-%20Vol.%2011.txt112111/2009 6:15:58 PMJ 3505.044 Page 27 of 67 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00005415 EFTA00157864  4 5 6 7 8 9 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 02 2 3 4 5 6 7 8 9 10 11 How would you describe your life from July 12 en you, approximate when you moved to 13 rough February of g? 14 A. Frustrating. 15 Q. And why was it frustrating? 16 A. Because I had a lot of secrets that I had held 17 from about Mr. Epstein, and I was just felt like I 18 was losin m • mind. 19 20 21 22 23 24 25 022 You say you held secrets rom What 2 secrets did you hold from 3 A. What exactly was happening at Mr. Epstein's 4 house. 5 Q. Well, you indicated that took you to file://fq/Documentstleand%20Scitings