UNITED STATES DISTRICT COURT

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CIV-80119-MARRA/JOHNSON • 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, VIDEOTAPED DEPOSITION OF Friday, November 6, 2009 9:16 a.m. - 12:43 p.m. Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office Electronically signed 1,1 Electronically signed 1,1 PROSE COURT REPORTING AGENCY, INC. 98e1e8e8-1011)-4717-b728-ef54d2/14.16d 3506-001 Page 1 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006124 EFTA00158017 Page 7 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On behalf of the Defendant: MARK LUTTIER, ESQUIRE RTIRMAN. CRTTTON. LUTTIRR & COLEMAN PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-efS4d28436cf 3506-001 Pagc 2 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006125 EFTA00158018 Page 1 2 NO EXHIBITS MARKED 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 3 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006126 EFTA00158019 1 2 3 Page PROCEEDINGS Deposition taken before Sandra W. Townsend, Court 4 Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 - - - 7 VIDEOGRAPHER: This is the 6th day of 8 November, 2009. The time is 9:16 a.m. 9 This is the videotaped deposition of 10 in the matter of 11 versus Epstein. 12 This deposition is being held at 13 , West Palm Beach, Florida. 14 My name is Sasha Quinby. I'm the videographer 15 representing Visual Evidence, Inc. 16 Will the attorneys please announce their 17 appearances for the record. 18 MR. LUTTIER: Mark Luttier, on behalf of 19 Jeffrey Epstein. 20 MR. on behalf of 21 22 THEREUPON, 23 24 having been first duly sworn or affirmed, was examined 25 and testified as follows: PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d28436cf 3506-001 Pagc 4 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006127 EFTA00158020 1 2 3 BY MR. Page 5 THE WITNESS: Yes, ma'am. DIRECT EXAMINATION LUTTIER: 4 Q. Please state your full name. 5 A. III 6 Q. And, Ms. where do you presently 7 live? 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0728-ef54d28436cf 3506-001 Page 5 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006128 EFTA00158021 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-072S-ef54d28436cf 3506-001 Page 6 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006129 EFTA00158022 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Seeletie8-101b-47f7-b728-ef54d28436d 3506-001 Page 7 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006130 EFTA00158023 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743720-ef54d20436cf 3506-001 Page 8 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006131 EFTA00158024 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 9 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006132 EFTA00158025 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 10 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006133 EFTA00158026 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0728.154d28436cf 3506-001 Page 11 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006134 EFTA00158027 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47(743728-ef54d28436cf 3506-001 Page 12 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006135 EFTA00158028 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08.21e8e8-101b-471743720-ef54d28436cf 3506-001 Page 13 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006136 EFTA00158029 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 14 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006137 EFTA00158030 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 15 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006138 EFTA00158031 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47f7-6728-ef54d28436cf 3506-001 Page 16 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006139 EFTA00158032 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743720-ef54d20436cf 3506-001 Page 17 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006140 EFTA00158033 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47f7-6728-ef54d20436cf 3506-001 Page 18 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006141 EFTA00158034 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0728-ef54d20436cf 3506-001 Page 19 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006142 EFTA00158035 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 90e1ette8-101b-4717-0720-ef54d28436cf 3506-001 Page 20 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006143 EFTA00158036 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47(743728-ef54d28436cf 3506-001 Page 21 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006144 EFTA00158037 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 22 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006145 EFTA00158038 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-efS4d28436cf 3506-001 Page 23 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006146 EFTA00158039 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 24 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006147 EFTA00158040 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0728-ef54d28436cf 3506-001 Page 25 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006148 EFTA00158041 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 26 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006149 EFTA00158042 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 27 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006150 EFTA00158043 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 28 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006151 EFTA00158044 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 29 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006152 EFTA00158045 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47f7-6728-ef54d20436cf 3506-001 Page 30 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006153 EFTA00158046 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 31 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006154 EFTA00158047 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743720-ef54d20436cf 3506-001 Page 32 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006155 EFTA00158048 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47(743728-ef54d20436cf 3506-001 Page 33 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006156 EFTA00158049 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-efS4d28436cf 3506-001 Page 34 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006157 EFTA00158050 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1ette8-101b-4717-0720-ef54d20436cf 3506-001 Page 35 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006158 EFTA00158051 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 36 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006159 EFTA00158052 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 37 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006160 EFTA00158053 Page 38 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 Q. Did there ever come a time that you learned of any conduct that your daughter was engaged in that you didn't approve? A. Yeah. Q. And when was that? A. Probably that's when we moved to the trailer and was about 14. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 38 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006161 EFTA00158054 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 Q. Page 39 This is when you earlier said you moved to West Palm Beach? A. Yeah. 14? Q. So -- and you think that's when she was about A. Yes, sir. Q. And what kind of problems arose then? A. Well, she met some other people in the neighborhood. Q. She met some other people what? A. In that neighborhood. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 PROSE COURT REPORTING AGENCY, INC. 98e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 39 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006162 EFTA00158055 Page 40 1 Q. And who did she meet? Do you know who it was? 2 A. Yeah. and some of his friends. 3 Q. Do you know what year this was? 4 A. No. I couldn't tell you the year. 5 Q. Okay. And do you know this 6 A. Yes, I do. 7 Q. When did you first make his acquaintance? 8 A. When we first moved to that place. 9 Q. And how did you make his acquaintance? 10 A. I guess told me she was dating him. 11 Q. Well, you moved there. Obviously there was 12 day one when you moved there? 13 A. Oh, right. 14 Q. Was she already dating him? 15 A. Oh, no. No. No. No. She didn't know 16 anybody. 17 Q. Okay. 18 A. No, she didn't know anybody. But then she had 19 met and she met some of friends. So then 20 she was palling out with and some of his friends. 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 40 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006163 EFTA00158056 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47f7-6728-ef54d28436cf 3506-001 Page 41 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006164 EFTA00158057 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0728-ef54d20436cf 3506-001 Page 42 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006165 EFTA00158058 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 43 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006166 EFTA00158059 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 44 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006167 EFTA00158060 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 45 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006168 EFTA00158061 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 46 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006169 EFTA00158062 Page 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Q. Did there come a time when she quit going to 16 school entirely? 17 A. Yeah. 18 Q. When was that? 19 A. I remember trying to get her into 20 and the school at-would not accept her 21 because they told me she was too -- too mature for her 22 age. 23 Q. What do you mean by that? 24 A. Oh, that it would distract the boys. I 25 clearly remember that. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47(7-0720-ef54d28436cf 3506-001 Page 47 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006170 EFTA00158063 Page 48 1 Q. What did they -- did you ask them what they 2 meant by that? 3 A. Yeah. They said that she was -- I can't 4 pronounce the word, but she was very well built for her 5 age. 6 Q. Was she older than the students that -- in 7 whose class she would be put? 8 A. You know what? I don't believe so. I think 9 they just said that she was too -- what's that word, you 10 know? -- like, too -- she was -- her body was too 11 mature. 12 Q. Do you have any record where somebody at 13 public school system said that your child couldn't be 14 enrolled because her body was too mature? 15 A. Yeah. And that's when I tried to enroll 16 her -- that's when I just took her out. 17 Q. What do you mean, you took her out? 18 A. Yeah. They told us to go -- because she had 19 to be. Maybe that's when she went to then, because 20 I remember going to try to help her get her GED from 21 another school on Military. I just don't recall the 22 order of protection, you know, the order of 23 Q. I want to go back. She was at . So -- 24 A. But -- 25 Q. -- did there come a time that she quit going PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-4454d28436d 3506-001 Page 48 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_ONX6171 EFTA00158064 Page 1 to 2 A. Yes. 3 Q. And why was that? 4 A. She got annoyed. 5 Q. What do you mean, "she got annoyed?" 6 A. She got annoyed and she told me that she had 7 found a job. 8 Q. Well, I don't know -- I'm not understanding 9 what you mean when you said, "she got annoyed." 10 A. She got annoyed with the people that were 11 there. And at that time that's when came into 12 play. And then she told me -- she was working with me 13 for a little while in And then she 14 said she found a job in Palm Beach. 15 Q. Well, at this point she's -- what? -- 14 16 years old? 15? 17 A. Maybe 14, going on 15. 18 Q. So your daughter says she's annoyed with 19 school. What's your reaction to that? What was your 20 reaction? 21 A. I -- what was my reaction? I wasn't very 22 happy. But for some reason, I know she initially didn't 23 come out of school until she was 16, however it worked 24 out. But I know she was still, I believe, involved in 25 . And in the beginning she went to work with me a PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-ef54d28436cf 3506-001 Page 49 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006172 EFTA00158065 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 50 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006173 EFTA00158066 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47f7-0720-ef54d20436cf 3506-001 Page 51 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006174 EFTA00158067 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47(743728-ef54d28436cf 3506-001 Page 52 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006175 EFTA00158068 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47f7-0728-ef54d20436cf 3506-001 Page 53 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006176 EFTA00158069 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 54 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006177 EFTA00158070 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47f7-0720-ef54d20436cf 3506-001 Page 55 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006178 EFTA00158071 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 56 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006179 EFTA00158072 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47f7-0720-ef54d20436cf 3506-001 Page 57 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006180 EFTA00158073 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 58 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006181 EFTA00158074 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 59 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006182 EFTA00158075 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47f7-6728-ef54d28436cf 3506-001 Page 60 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006183 EFTA00158076 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 61 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006184 EFTA00158077 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47(743728-ef54d28436cf 3506-001 Page 62 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006185 EFTA00158078 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 63 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006186 EFTA00158079 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 64 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006187 EFTA00158080 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 65 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006188 EFTA00158081 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743720-ef54d20436cf 3506-001 Page 66 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006189 EFTA00158082 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 67 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006190 EFTA00158083 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6720-ef54d20436cf 3506-001 Page 68 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006191 EFTA00158084 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0728-ef54d28436cf 3506-001 Page 69 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006192 EFTA00158085 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47(7-0728-ef54d20436cf 3506-001 Page 70 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006193 EFTA00158086 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743720-ef54d20436cf 3506-001 Page 71 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006194 EFTA00158087 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 90e1e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 72 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006195 EFTA00158088 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0728-ef54d28436cf 3506-001 Page 73 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006196 EFTA00158089 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47f7-0720-ef54d20436cf 3506-001 Page 74 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFIA_00006197 EFTA00158090 Page 1 2 3 4 5 6 7 8 9 10 Q. Okay. Back to . You moved into 11 How long was it after you moved to this 12 trailer on before you met this fellow? 13 A. Before I met him personally? 14 Q. Yeah. 15 A. Probably -- because I worked I used to 16 clean houses a lot in for the elders. 17 don't know. Maybe two, three months. 18 Q. And you came to know him because your -- did 19 your daughter introduce you to him or -- 20 A. Yeah, he came over with some of his friends 21 and, yeah, my daughter introduced me to him. Seemed 22 like a nice, respectable boy at the time. 23 Q. And how old was he in relation to your 24 daughter? 25 A. Honestly, I don't know. I don't -- at that PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47(7-0720-ef54d20436cf 3506-001 Page 75 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006198 EFTA00158091 1 2 3 Page time I don't know. Q. And, so, you thought he was a fine guy? A. Yeah. He dressed very nice. His family lived 4 5 diagonally across. Nice aunt. Nice he came from a nice house. 6 7 Q. So you had no problem with your daughter hanging out with him? 8 A. No, I didn't, you know. 9 10 Q. Did there ever come a time that you learned anything else about Mr. ? 11 A. Yeah. 12 Q. When was that? 13 A. Probably a little bit after that. 14 15 Q. Meaning, a little bit after the couple months after -- 16 A. Yeah. After I met him. 17 Q. So give me an approximation. When you say, "a 18 little bit after," are we talking about a month later? 19 A. Maybe a month, two months. 20 Q. So this would be about three months -- 21 A. Three months maybe. 22 Q. -- after you moved over to 23 A. Uh-huh. 24 Q. Okay. Well, what did you learn? 25 A. Well, was hanging out with these Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 PROSE COURT REPORTING AGENCY, INC. 98e1e8e8-1011)-47174:428.efS4d28436cf 3506-001 Page 76 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_OYX6199 EFTA00158092 Page 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 people and -- Q. A. and a boy. Q. And who do you mean by, "these people?" and his friends. There was another girl What are their names? A. I don't remember. I remember the girl working I want to say I know it, but I know she attended School with because wa attending School. I don't remember her name. Q. What do you mean by ' School?" Q• Well, what is it you learned about him at that time? A. I just told , like, kind of beware, you know. It seemed to me like he was a player -type guy. Q. What do you mean by "player?" A. You know, he dressed nice, appeared nice, but -- how would I describe a player? Like, he kind of knows, like, he knew everything and he was, like, you know, he was the thing. Q• Well, what gave you concern about that? A. What gave me the concern about that? Because PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eleSe8-101b4717-6728-ef54d28436cf 3506-GUI Page 77 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006200 EFTA00158093 Page 78 1 a couple of times didn't get home on time and I, 2 you know, I questioned where she was, what she was 3 doing. 4 And then it wasn't long after that 5 told me that and this other girl that they were 6 hanging out with helped her get a job. And that was 7 down in -- down in Palm Beach over a bridge. 8 MR. LUTTIER: Okay. I'll take a break now. 9 Go to the restroom. 10 VIDEOGRAPHER: Going off the record at 10:33 11 a.m. 12 (Brief recess.) 13 VIDEOGRAPHER: We're back on the record at 14 10:40 a.m. 15 BY MR. LUTTIER: 16 Q. Okay. We were talking before the break about 17 this fellow . And you said there were a 18 couple times when your daughter didn't come home on time 19 and apparently was out with him? 20 A. Yes, sir. 21 Q. Did there ever come a time that you learned 22 his age? 23 A. No. I don't think I -- I didn't know it at 24 that time. 25 Q. Did you ever ask her if it was -- PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b4717-6728-ef54d28436d 3506.001 Page 78 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006201 EFTA00158094 Page 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. Yeah. Q. -- somebody her age? A. But I think I was told he was, like, 7 maybe 16 or 17. Q. And your daughter would have been 14? A. Fifteen. She was, like, I believe she was, like, 14, going on 15. Q. And did you come -- come a time that you learned that wasn't true? A. Oh, many years later. Q. But she told you he was approximately the same age she was? A. Yeah. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 79 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006202 EFTA00158095 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-471743720.154d20436cf 3506-001 Page 80 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006203 EFTA00158096 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 81 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006204 EFTA00158097 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-471743720-ef54d20436cf 3506-001 Page 82 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006205 EFTA00158098 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08.21e8e8-101b-47(743720-ef54d28436cf 3506-001 Page 83 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006206 EFTA00158099 Page 1 2 3 4 5 6 7 Q. All right. For example, she told you this 8 fellow, , was an age that he wasn't? 9 A. Correct. 10 Q. And she obviously knew how old he was, right? 11 MR. : Object to the form. 12 THE WITNESS: I don't know that to be true. 13 BY MR. LUTTIER: 14 Q. And she knew that you would disapprove with 15 her hanging around with him if he was much older than 16 her? 17 A. Oh, absolutely she'd know that. 18 Q. Because you told her that, right? 19 A. She knows that. 20 Q. And when you said that he was a player, what 21 exactly did you tell her about somebody that was a 22 player? What did you caution her about, if anything? 23 A. A smooth talker. 24 Q. I mean, right down graphically what did you 25 tell her about that, if anything else? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-ef54d20436cf 3506-001 Page 84 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006207 EFTA00158100 Page 85 1 A. I just told her to watch her step. 2 Q. Meaning, what? 3 A. He's a nice dresser. He's a smooth talker. 4 He likes to talk to this woman, talk to that girl, talk 5 to this girl, that girl, whatever. And I just consider 6 a person like that just to be a smooth talker. 7 Q. Did you tell your daughter anything other than 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he was a smooth talker? A. No. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 85 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006208 EFTA00158101 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47f7-0728-ef54d28436cf 3506-001 Page 86 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006209 EFTA00158102 Page 1 2 3 4 5 6 7 8 9 10 11 12 13 Q. Well, did there come a time that you were 14 suspicious that she was sexually active? 15 A. Was there a time? 16 Yeah, there was. 17 Q. And when was that? 18 A. That was after my concrete evidence of 19 being sexually active was after , we moved to 20 . And some people were calling me on my cell 21 phone to talk to and she got gifts in the mail, 22 negligees and a massage book. I clearly remember that. 23 Q. Did you ask her about those? 24 A. Yes, I did. 25 Q. What did she say? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-47(7-0720-ef54d28436cf 3506-001 Page 87 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006210 EFTA00158103 Page 88 1 A. She told me that the man she was -- the 2 household, the man in the household that she was working 3 for in Palm Beach, she was doing ironing and cleaning, 4 is what I understood. But this man offered to send her 5 to school. 6 Q. And, so, is that all? You accepted that as a 7 response to your question? 8 A. Yeah. I can say I did at that point. 9 Q. So getting gifts of lingerie fit into that 10 description to you, that she was cleaning his house and 11 he was going to send her to massage school and that's 12 why she got gifts -- 13 A. It wasn't -- how can I explain? It wasn't 14 lingerie that came -- it came from, like, I understood 15 it was a wife that, you know, she goes to New York to 16 these -- she was a model or something and she went to 17 these nice places. And it wasn't like a -- like a 18 frilly negligee that I would consider something to be 19 sexual. It was just, like, you know. But, I mean, then 20 I thought it was nice that the wife thought of her like 21 that. 22 Q. Did your daughter tell you that she got these 23 gifts from some person's wife? 24 A. Yeah, she did. 25 Q. And you saw these gifts, correct? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-ef54d28436d 3506-001 Page 88 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006211 EFTA00158104 Page 89 1 A. Absolutely. 2 Q. Did you open the packages when they came? 3 A. No. 4 Q. How is it you saw them? 5 A. It just so happened that one day I had been 6 there. The package came. And then I saw the book and 7 she said that this was -- came from the family she was 8 working for in Palm Beach, because they were going to 9 send her to school because she had discussed that she 10 wanted to be a massage therapist, because supposedly 11 that's what the wife did or something. 12 And said, Mom, there's good money in 13 this and they're willing to help me with school. And, 14 Lord knows, I couldn't afford it because I was 15 supporting three kids on my own. 16 And I said, , well, that's nice. And 17 honestly I didn't think anything of it because I house 18 clean and I've had my clients pull together to buy me a 19 car, you know, for compensation of helping them out and 20 things like that. So -- or they had allowed me to take 21 a small loan from them and pay them back a little bit 22 every week. 23 So I just -- I didn't really think anything 24 further into the picture because I knew that had 25 this job in Palm Beach. She was making money. She was PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98elette8-101b-47t7-b728.efS4d28436cf 3506-001 Page 89 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006212 EFTA00158105 Page 90 1 coming home. She was coming home. She was fine. Her 2 attitude was fine. She was happy. And I didn't really 3 think much of it. 4 Q. Now, you began this area of discussion when I 5 asked you when was the first time you became suspicious 6 that your daughter had been sexually active. And this 7 is the event that you have described to us. 8 So what is it about this event that caused you 9 to wonder whether or not your daughter was sexually 10 active? 11 A. The way she started carrying herself. 12 Q. Was this before or after this event? You're 13 talking about an event where you -- she got gifts? 14 A. It was after this event. 15 Q. What do you mean by "carrying herself?" 16 A. I could kind of see her demeanor change where 17 she was now wearing low-cut blouses and tight pants. 18 And she was very -- very prevalent about she always had 19 to have make up on when she went to work and, you know, 20 that was, again, it just -- I don't know. Something 21 didn't seem right. 22 And then I questioned her. 23 And she said, no, Mom. I'm just cleaning 24 house, that where she cleans, I understood there was 25 several people that worked there, that there was, like, PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b4717-6728-ef54d28436d 3506.001 Page 90 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA _00006213 EFTA00158106 Page 91 1 a crew, they had a cleaning crew, a cooking crew, and... 2 Q. Okay. Well, did there ever come another point 3 in time that you -- strike that. 4 Is there anything else about this conversation 5 that you had with her when she got these gifts that made 6 you think that she was perhaps sexually active, other 7 than the fact the way she carried herself? 8 A. No. 9 Q. Did there was there ever another time that 10 you questioned whether or not she was sexually active? 11 A. Yes. 12 Q. When was that? 13 A. I -- I guess the people, something happened 14 with the transportation because they would come and get 15 or would take her to her job because they 16 were kind of dating at that point, so I didn't think 17 anything of it. would take her to her job or the 18 people would send a car for 19 And, like I said, I didn't think anything of 20 it because I've had clients come and pick me, you know, 21 people that I worked for come and pick me up. 22 And then one day -- I don't know -- something 23 happened, but it was -- had to get to her job 24 and had to get to her job and I drove her there. 25 Q. And when was this? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47174,7284d54d28436cf 3506001 Page 91 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006214 EFTA00158107 Page 1 A. The exact date, I don't remember. I -- T 2 don't remember the exact date. 3 Q. Do you know what year it was? 4 A. No. No. -- it all evolves in the 5 time between maybe 15. Maybe 15. 6 Q. Do you have any record of when this event 7 would have occurred -- 8 A. Do I have any record? 9 Q. -- when you drove her to this place? 10 A. No. I can't say I wrote it down. 11 Q. Well, did you create any record at any time 12 about it to pinpoint when it happened? 13 A. No. I remember it was a nice day. Time of 14 year, I can't remember. 15 Q. Did she ask you to take her there? 16 A. Yeah. She said if I take her there, her 17 employer would pay me for my travel, you know, to bring 18 her there, because I was very frugal about the way I 19 spent my money because I was supporting three children 20 by myself. 21 And I said, , I don't have, you know, _ 22 have to get through the week. And I remember not having 23 enough gas money to get there. 24 And I said, , I have gas, but what's in 25 my tank has to stay there. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47174,7284d54d28436d 3506-001 Page 92 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006215 EFTA00158108 Page 1 So I dropped -- I went down there with 2 . I didn't pull in a driveway. I remember it 3 being on the street. 4 And then went in a driveway. 5 And then she said, Mom, I'll be right out. 6 They're going to give you money for gas so you don't 7 have to worry. 8 And I said, okay. 9 So -- and then she was taking, like, a minute, 10 so I started to proceed to walk in the driveway. 11 And then walked out and introduced me 12 to her employer. And I shook her employer's hand and 13 that was Jeffrey. And I shook his hand. He seemed like 14 a very nice person. He said that my daughter, you know, 15 was doing a wonderful job. And, you know, he asked 16 several -- you know, it was a huge house. I never was 17 inside, but there was, like, quarters in the back of it. 18 And I'm telling you there had be 20 beautiful cars that 19 were parked. 20 And I just said, well, , this is a good 21 deal, you know, you make good money in Palm Beach. I 22 would have liked to have had a cleaning job in Palm 23 Beach. 24 And I had asked, you know, -- and I said, 25 , you know, if they need help, let me know. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47t7-b728.efS4d28436cf 3506001 Page 93 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006216 EFTA00158109 Page 94 1 And she said, no. 2 And I left there. 3 And the man -- Jeffrey said, you know, 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Mr. Epstein said, don't worry, we'll get your daughter home. You know, -- I think her name was she talks with a, I guess, a British accent -- came out and assured me that she would get my daughter home. So I said, okay. Thank you. And I went about my business. Q. Did anybody give you money on that occasion? A. Yeah. Yeah. Q. How much money did you get? A. I think $50, because I was totally amazed. But then I thought about it, well, these people are in Palm Beach, they have money. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d28436cf 3506-001 Page 94 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006217 EFTA00158110 Page 1 2 3 4 5 6 7 8 Q. Who gave you the $50? 9 A. Mr. Epstein. 10 Q. Did you ever ask Mr. Epstein what your 11 daughter was doing? 12 A. Yeah. He told me she was ironing. She was 13 doing ironing work and the laundry. She was in part of 14 the laundry. 15 Q. Did you ever wonder about your -- how old did 16 you say your daughter was at this time? 17 A. She, I think, was about 16. 18 Q. Did you ever wonder about your daughter 19 working at age 16 doing this? 20 A. No. No. Because back in New York I worked 21 I lied and worked at Burger King at 15, so I didn't 22 think anything of it. My daughter is 16 working. And 23 before that when I was in high school, I used to work 24 and clean houses for the elderly people because I had 25 such good grades. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98elette8-101b4M-b728.efS4d28436cf 3506001 Page 95 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006218 EFTA00158111 Page 96 1 Q. Did your -- did your daughter -- did you take 2 your daughter to this location on any other occasion? 3 A. Maybe two other times. And it was only she 4 was running in to get her pay. 5 Q. And how much was her pay? 6 A. $300. 7 Q. And that was supposed to be for how long? 8 A. Honestly, I don't know. I don't know. 9 Q. Did you know how much she was getting? 10 A. No. 11 Q. Did you ask her? 12 A. Yeah. 13 Q. And what did she tell you? 14 A. Well, a couple of times she told me she was 15 getting a hundred dollars. And then she told me on 16 several -- well, I guess, at one point Mr. Epstein, I 17 guess, some of his help was going somewhere and asked 18 if she could bring anybody to work. And as a 19 matter of fact, I was very big in church back then and : 20 21 22 23 24 25 had asked one of the church sisters if she needed to make money to go, you know, that this Mr. Epstein was looking for other help. Because I was too busy, you know, so I gave it to somebody else. Q. So did the nun go? A. She wasn't a nun. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-6728-ef54d28436d 3506-001 Page 96 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006219 EFTA00158112 Page 1 Q. Or a sister, you referred to it? 2 A. I call her my sister. Yes, she did. 3 Q. And what was her name? 4 A. 5 Q. what? 6 A. Do you want the truth? I don't remember her 7 last name. 8 Q. So went over there -- 9 MR. : Yes, he wants the truth. 10 THE WITNESS: I don't remember her last name. 11 BY MR. LUTTIER: 12 Q. So went over there and did some -- what_ 13 was it? -- ironing? 14 A. went over there with her -- with her 15 her niece. 16 Q. And did they ever contact you after that and 17 tell you what they did? 18 A. Well, said she left, but she left her 19 niece there, because I think drove her niece there 20 was the whole thing. But I wasn't close with her niece 21 to have, like, a -- I didn't have her phone number, she 22 didn't have mine and everything was through You 23 know, and I said to , you can go ahead and go 24 there. 25 And -- I got the directions because PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47(7-0720-ef54d20436cf 3506-001 Page 97 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006220 EFTA00158113 1 2 3 Page 98 that British lady called. I know he was looking for help and couldn't go one day and that's why I think I called Sister in a hurry and said, do you 4 want to make some money, that this guy had people coming 5 in and they needed extra help. 6 And then called me and told me that she 7 left there but she left her niece there. 8 Q. Now, when you say, Sister that's not 9 really your sister? 10 A. No. No. No. No. No. It's church term. 11 Q. What church is it that you -- 1