UNITED STATES DISTRICT COURT

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80893 MARR/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / Tuesday, June 15, 2010 4:06 p.m. SWORN STATEMENT OF Taken before ELAINE CRANDALL, Registered Professional Reporter and Notary Public in and for the State of Florida at Large, pursuant to Notice of Taking Unsworn Statement in the above cause. U.S. Legal Support (305) 373-8404 EFTA00181297 2 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 APPEARANCES FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN BY: BRADLEY EDWARDS, ESQ. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301-3268 ALSO PRESENT: MICHAEL FISTEN U.S. Legal Support (305) 373-8404 EFTA00181298 3 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 Thereupon -- was called as a witness by the Plaintiff and, after having been first duly sworn, was examined and testified as follows: DIRECT EXAMINATION BY MR. EDWARDS: Q. Tell us your name. A. Q. And just to the get to the point, you know who Jeffrey Epstein is? A. Yes. Q. And you've met him before? A. Yes. Q. And you know who Jean-Luc Brunel is? A. Yes. Q. And you have met him before? A. Yes. Q. Which one did you meet first? A. Jean-Luc Brunel. Q. And where did you meet him? A. In Miami Beach. Q. When? A. In 1998. Q. And how? U.S. Legal Support (305) 373-8404 EFTA00181299 4 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. In his office. Q. Related to what; modeling? A. Working, yeah. Modeling. Q. What, at that point in time, did you know about Jean-Luc Brunel? A. Nothing. At that time I didn't know anything. Q. So how did you meet with Jean-Luc Brunel in his office in 1998? A. Because there was a gentleman from Switzerland who wanted to make business with them. And I was hired by that gentleman to look through all the accounts to make sure that -- you know, they were kind of in bankruptcy. But he wanted to know that his money, his investment, would be good. So that's why I went. Like, an external audit to do -- to see what was the income, the expenses and something like that. Q. Who is the guy from Switzerland? A. I'm not going to tell you his name. Q. Is that somebody who is still in touch with Jean-Luc Brunel? A. No. Not at all. Q. What's the reason for not wanting to disclose his name? Does he have anything to do U.S. Legal Support (305) 373-8404 EFTA00181300 5 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 with this case? A. No. But I don't have permission. I have to ask him. Q. Okay. And after your meeting with Jean-Luc Brunel in 1998 -- well, what company was Jean-Luc Brunel with then? A. Models, it was, at that time. Q. K-A-R-I-N? A. Yes. Q. And is that the only other modeling agency that you have known Jean-Luc Brunel to be associated with, besides MC Squared? A. Yes. Q. And how long was Jean-Luc with from 1998 through -- A. No, Jean-Luc was the owner of Before that. Q. I think since 1986, in Paris. All right. And why was he no longer affiliated with at some point in time? A. He closed -- he -- how you say -- he made a dissolution. He dissolved the company. Q. Were you ever hired to work with A. I was hired to work with Q. When was that? A. In 1998. , yeah. U.S. Legal Support (305) 373-8404 EFTA00181301 6 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. What was your position? A. At that time, bookkeeper. Q. In Miami? A. Yes. Q. And how long did you stay as the bookkeeper in Miami for A. Until 2003, when they changed the company to MC Squared. Q. So when did the official change come from to MC Squared? A. In 2003. Q. And when is the first time you met Jeffrey Epstein? A. I met Jeffrey Epstein only once in my life. And I believe it was in 2003. Two thousand -- yeah, by the end of 2003, 2004. Q. Where? A. In New York. Q. What was the occasion? A. It was the open party for MC Squared. Q. Where was that held? A. In a discotheque in Manhattan. Q. What discotheque? A. I don't know. I don't remember. Q. And did you meet Elaine Maxwell? U.S. Legal Support (305) 373-8404 EFTA00181302 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't know her name. But he was with -- with a woman. I don't know. Q. And what is your understanding or what was your understanding that Jeffrey -- in terms of Jeffrey Epstein's involvement with MC Squared? A. Jean-Luc always said that Jeffrey was his friend, that he is a millionaire. And that Jeffrey was giving him the money to -- you know, loans or whatever -- and the apartments for the girls and things like that. Q. All right. Let's break that down. Giving money for what purpose? For furthering MC Squared? A. For -- for -- yeah, the money came to MC Squared, not to -- I don't know. Prior to 2003, I don't know if Jeffrey Epstein ever gave him money. I know that from the longest Jean-Luc was living in an apartment that belongs to Jeffrey Epstein Q. What apartment is that? A. It's in New York. I don't know the address. Q. Is that at 301 East 66th Street? A. Yeah, something like that. I think it's that one. Q. And it's my understanding that Jeffrey U.S. Legal Support (305) 373-8404 EFTA00181303 8 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 Epstein owns or controls numerous apartments in that -- at that same address; is that right? A. Yes. Yes. Q. And have you ever been to that address? A. No. Q. And how do you know that he owns or controls numerous apartments at that address? A. Because at that time Valenzeula was the office manager of the new and she was dealing personally with the assistant of Jeffrey Epstein. And she had to do the payments for the cable and, I believe, electricity. Q. And Jeffrey Epstein that was dealing with? A. I don't know. Q. A. I believe so. Q. Do you remember that name? A. Yes. Q. That's somebody who no longer lives here, right? A. I -- I believe I heard that, yeah. Q. A. who was the assistant of Who did you hear that from? U.S. Legal Support (305) 373-8404 EFTA00181304 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. And at some point in time you came to know that the models were also staying in these apartments at 301 East 66th Street, right? A. I don't know specifically they stay at Jean-Luc's apartment. But I know that the models were staying in different apartments that belong to Jeffrey Epstein. Q. And what are the names of the models that were staying there, that you remember? A. Most of them. You know, at that time, when I was there who -- all the little girls. Q. How do you spell that? A. I -- you know, that was in 2000-something. I don't recall all the names. But there is a list that you can get it from the office in New York. Q. A list -- A. They have a list of models that they were staying in those apartments. Q. If I were to request it from the office in New York, what would I ask for? A. For the models' apartment list. Chargeback for models apartments. Q. Chargeback? U.S. Legal Support (305) 373-8404 EFTA00181305 10 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, because Jeffrey Epstein never charged Jean-Luc for rent but Jean-Luc was charging rent to the girls. And in her statements it shows 301, 66 Apartment A, or Apartment B. And he was charging them, like, a thousand dollars a month. Q. How do you know that? A. Because I was doing the statements. Q. You were actually the one doing the statements? A. Not all the time. I was in New York starting 2003. Q. Through what date? You were in New York from 2003 to -- A. 2006. Q. And while you were in New York you were working for MC Squared? A. Yes. Q. And what is the proof that you have seen that Jeffrey Epstein was a partner or financial supporter of MC Squared? A. I was the one who took the papers to Mellon Bank. Q. That's in Miami? A. Yes. And Swetpaul (phonetic) -- I was U.S. Legal Support (305) 373-8404 EFTA00181306 11 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 talking at the time to Rich -- I believe his name was Rich Gany. That was one of the other assistants of Jeffrey Epstein. Q. Gany, G-A-N-Y? A. Yeah. Q. Do they call him Eric Gany? A. That is him name, yeah, Eric Gany. That's his name. I recall some things, not all the time. I recall that Mr. Epstein didn't want to sign the papers, but Mellon Bank didn't want to accept the Line of Credit if he didn't sign. So we had to return the papers to New York so he actually signed the documents. Q• And what was he actually signing, that you remember? Signing over as a Line of Credit or -- A. As a line -- as the grantor of the Line of Credit. Because the Line of Credit came from J. P. Morgan directly, but he was the grantor. He was the one who actually was responsible. Q. And how much was the Line of Credit? A. A million dollars, it was, at that time. Q. And did you ever keep track of whether or not that line was extended or any additional monies were given to MC Squared? U.S. Legal Support (305) 373-8404 EFTA00181307 12 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. No, I don't know. Q. So in addition to his financial guarantor on the Line of Credit of a million dollars, what other involvement are you aware of that Jeffrey Epstein had with MC Squared and/or the apartments at 301 East 66th Street where the models lived? A. They were planning on buying or associating with a girl in -- in France for a -- for a company. They were planning to do a company. And, actually, I gave the paper to -- to Mr. Shawn Connolly, which is an actual paper that came from the office from Jeffrey Epstein, that he was giving instructions to Jean-Luc saying that he wanted to have the same contracts as -- uh, what's his name, of Donald Trump, and that he wanted to have the same kind of benefits for the scouters. So he was giving instructions to Jean-Luc on what to do, what to -- there is a woman in Paris, I don't recall her name, (phonetic), I believe it was, and they were -- they were, the three of them, trying to do a new company. But then everything was, like, on zero. They never they never did it together. Q. And do you know why? U.S. Legal Support (305) 373-8404 EFTA00181308 13 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. No. Q. Would you know the lady's name in Paris if I -- A. If you give it to me, yeah. If you give me the name, I can recall. Q. Okay. While I'm looking for that, how many girls that were models were living in the apartments at any given time at 301 East 66th Street? A. That's -- that's not only one apartment. There are a lot of apartments there. There is not only one girl. There is not only one apartment. I believe there were, like, two or three apartments. And they were put in between four girls per apartment, I believe. Q. How many apartments? A. I believe there were, like, two or three. Q. And there is four girls per apartment? A. Yeah. Q. And you know that because you saw the documentation at MC Squared that showed where these girls were living? A. Yes. Q• Did you also have something to do with U.S. Legal Support (305) 373-8404 EFTA00181309 14 1 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 the visas that were prepared for the girls that were working? A. Yes. I was providing the names to the attorney. His name is Luis Font. He was doing the visas here in Miami. There was another Valenzuela was handling directly the visas in New York. And only when she had problems, she hired another attorney. I don't know the name of the attorney in New York. But Luis Font is the -- was, at that time, the attorney handling the visas for Miami. Q. Do you remember doing the visa for A. No, that was done in New York by III Valenzuela. Q. And visa, that you specifically remember being done, right? A. Yeah, I remember that. Because at one point, I believe, one of the renovations of her visa, something happened. And Mr. Epstein called the office while I was there and was really upset. And he spoke with Jean-Luc and they -- they were really nasty with III and, you know, it wasn't if -- it wasn't fault. It was their fault because they gave the wrong information. But, you U.S. Legal Support (305) 373-8404 EFTA00181310 15 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 know, she was only an employee and that's it. Q. How did come into the country? A. By a model's visa, I believe. Q. And was she brought in specifically by Jeffrey Epstein or Jean-Luc or do you remember? A. Mr. Epstein was paying for the visas. But, you know, all the visas were done through -- through or MC Squared. I believe she came with visa first, then everything transferred to MC Square. And I believe those visas were paid directly by Mr. Epstein. Q. How old was when she first came? A. I don't know. I wasn't in New York at that time. Because I know she came prior to me getting involved in New York. Q. And you were involved in New York in 2003? A. Yes. Q. So she came in some time before that? A. I believe so. Q. But even back in 2003, she still -- I don't know how old she is now. She's probably 24 or 25, right; do you know? U.S. Legal Support (305) 373-8404 EFTA00181311 16 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. No. Q. Have you ever met her? A. No. Q. Have you ever met (phonetic)? A. No. Q. You have only met Jeffrey Epstein once in person. How many times have you talked to him on the phone? A. Maybe once. Q. At some point in time you drove several girls or a number of girls over to Jeffrey Epstein's house; correct? A. Not me. Jean-Luc directly took them. I was making the arrangements to get a limousine or a car. And Jean-Luc himself was driving the girls to his house because he was having a party and there were supposed to be girls. Q. Which girls did he drive over there? A. One time I know he went with with uh, what's her name? Four girls from Brazil, from the same agency. is one of them because I remember her name. The other ones -- maybe if you -- S2• U.S. Legal Support (305) 373-8404 EFTA00181312 17 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. No. Q. A. No. Q. Do you know those two girls? A. Yes. Q. And were those girls somehow involved with Jean-Luc or the modeling agency? A. Yes. Q. They were both MC Squared models? A. Yes. Q. And at the time, when they began, how old were they; do you remember? A. I believe was, like, 14, 15. And was 13, 14, when she came. Q. Okay. And do you know where they are now, either one of them? A. I know is in New York. Q. When is the last time you talked to her? A. In 2006. Q. How do you know she is in New York? A. Because I saw her pictures whenever. I believe she's in New York. I don't know if she really is in New York but I believe. Q• A. , the last time I saw her was in U.S. Legal Support (305) 373-8404 EFTA00181313 18 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 2006, too. And, specifically, I don't know where she is. But if she's in the United States, I believe she's in New York. If not, she is in Brazil or in Paris. Q. All right. Do you know this person in Brazil, A. No. Q. Here is a document that we obtained related to information from Jeffrey Epstein's computer system. It says Massage Paris. It's in a square there and it continues to the next page. Tell me if you recognize any of those names. A. No. is one of the girls that went with now that I'm seeing kind of names. Lila is one of the other ones. If this is Lelita or something like that, it's a black girl that I believe she was -- she was not underage but she was going out with one of Jeffrey's best friends. Q. Who is that? A. I believe -- Q. Who is Jeffrey's best friend that she was going out with? A. I don't know. I don't know. something like that, is her name. U.S. Legal Support (305) 373-8404 EFTA00181314 19 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. All right. What information do you have about Jean-Luc being involved with underage girls at any point in time? And by that I mean being involved sexually with underage girls. A. One day he told me that he wishes he can sleep with one of those girls that was underage. And I told him that's a minor, whatever. And then -- hold on, that's my son. (Telephone interruption.) A. He had a problem, you know. I cannot say I saw them, look, because I would be lying. And I'm not going to say any lie. But the only thing that I can tell you that what I saw about Jean-Luc is that Jean-Luc is a drug addict, a cocaine addict. Q. At some point in time you actually saw evidence of that, right? A. Yes. Q. I mean, him using cocaine that somebody does every day? A. Yeah. He's an addict. He's used to drugs, as well as, you know -- I know Mr. Epstein doesn't take any alcohol, drugs. I know that. I heard that. Q. How do you know? U.S. Legal Support (305) 373-8404 EFTA00181315 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I heard that. I heard that. I don't know, because I never met -- I never -- I was never, like, around him or nothing like that. I'm just telling you what I heard. But regarding Jean-Luc, I know -- I know he has that kind of problem, no? Q. And as long as you knew Jean-Luc, he always had a cocaine problem? A. Yes. Q. What about Jeff Fuller? A. I know he had a cocaine problem, too. He was one time on the Internet, you know, like, a report on that. Q. And is Jeff Fuller somebody else who you also knew to have been associated sexually with underage girls? A. Jeff, I -- you know, I don't think Jeff. I always thought Jeff was gay. For me, he's gay. You know, that's the impression that I have. But I don't think so. Q. Did you find out that Jeffrey Epstein and/or Jean-Luc Brunel were involved in these underage girls that were staying in these apartments at 301 East 66th Street? A. I really don't know that. You know, I U.S. Legal Support (305) 373-8404 EFTA00181316 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 cannot tell you. I know there were girls staying there. I never knew if they were going there or not. Q. You mean, you knew that the girls were staying there; 13, 14, 15? A. Some of the girls were underage, yeah. Q. As well as 13, 14 or so? A. Thirteen or 14, yeah. Q. Did you ever ask any of the girls if they were sexually involved with Jean-Luc and/or Jeffrey Epstein? A. No. One time there was a problem with And she was -- I believe she was 14 years old. And she tried to go -- or they took her to a discotheque in Miami Beach. And when I went to work the day after, they told me that the police was asking. So since she was doing whatever she wanted, you know, I brought her to my house and I said, you're not going out at night; you're only 13, 14, and that's my responsibility. Q. Do you know Sergio Cordero? A. Yes. Q. And do you know what Sergio's role was in getting girls or something for Jeffrey Epstein? A. Yeah. That -- that is something that U.S. Legal Support (305) 373-8404 EFTA00181317 22 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 Sergio, you know, comment with me. And he said that when Jeffrey Epstein went to Ecuador, Jean-Luc told me that he has to bring girls and this and that, because Jeffrey was coming to Ecuador. So they did such a big thing. Q• Right. But in terms of bringing girls, specifically girls, that were very young? A. Yeah, but there was girls from Ecuador. There is nothing you can do there. It's South America. Q. I understand that. I'm not saying whether it was legal or illegal. I'm just asking you, the direction was that Jean-Luc told Sergio A. Not to bring girls. Never said -- never -- Sergio knew that they like young girls. Q. By young, what are we talking about? A. Eighteen, 19. Sergio -- you know, I know Sergio. And more than anything, like, Sergio is a father. And I don't think he will put his hands on a ten, 11, 12, 13-year -old girl. You know what I mean? Q. I'm not asking about him. Do you know of Jeffrey Epstein being involved with underage girls? U.S. Legal Support (305) 373-8404 EFTA00181318 2 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I heard that, yeah. Q. You heard that through whom? I don't mean just the newspapers and things like that. mean -- A. No. Through -- through the office. Through Jean-Luc. Through -- there were conversations of Jean-Luc saying that, you know. Q. Saying what? A. That Jeffrey likes underage girls. And never directly but, you know, his conversations were like that. Q. Okay. But, specifically, I just want to know what evidence that we have, what real conversations that you heard, about Jeffrey Epstein liking underage girls. A. I'm telling you Jean-Luc saying it from his mouth. Q. Okay. And, specifically, he says Jeffrey Epstein likes underage girls or he likes 12-year -olds or likes what? A. No, he likes young girls. When they were talking in the office, there were a lot of people. So they were not stupid. They were knowing how to talk. Because they were making, like, a big thing of, oh, look, he's going out U.S. Legal Support (305) 373-8404 EFTA00181319 24 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 with Fulanita (phonetic), and we knew Fulanita was only 18 years old. She is a young girl. So that's the kind of girl he likes. You know what I mean? Q• But there is nothing illegal going out with an 18-year -old girl. And that's what I'm asking. A. No. Q• What information do we have that Jeffrey Epstein was involved with underage girls? I mean, I have a lot of information of my own. But I'm asking what information do you know. A. The only thing I heard in the office, that Jean-Luc say it, that they like -- when they say, oh, I wish I could sleep with this girl or the fact that he was taking 15, 16-year -old girls to his house. Q. Who? A. I know that because I saw him. Q. Jean-Luc was taking 15-year -old girls to his own place? A. No, to Jeffrey's house. Q. A. Q• To Jeffrey's house? Yes. And what 15-year -old girls was he taking U.S. Legal Support (305) 373-8404 EFTA00181320 25 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 to Jeffrey's house? A. At the time I'm telling you it was Lila, I don't know remember the other two girls. There is two Brazilian girls. I gave it to you before, the names. I don't remember right now. Q. Do you know A. No. Q. Do you know Khalid Mohammed? A. Yes. Q. What did he do? A. He was a scouter and a booker. Q. Scouter; what does that mean? A. Person looking for models. Q. And how legitimate was A. Khalid Salaam. Q. Salaam? A. Yeah. Q. Right. Where was he bringing models in from or looking for models? Outside the country or -- A. Inside the country. Very -- not often from outside the country, no, no. From inside. Q. Did you ever hear of any of the parties that took place on Jeffrey Epstein's island? U.S. Legal Support (305) 373-8404 EFTA00181321 26 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. In -- Q. Little St. James? A. One New Year's, I believe -- that was, like, 2004, 2005, that New Year's -- they were having a party there. Q. Who was having a party there? A. Mr. Epstein. Q. And who was at the party that you know? A. I know Jean-Luc was there. But then -- specifically, I don't know if Jean-Luc stay there, because what I do recall is that, during those days, there was, like, December 30 or 29, something like that, Jean-Luc call me from Puerto Rico that he was doing the scouting and he -- actually, he was the one who told me that he had to go to Jeffrey's island because they were having the party there for New Year's. Q. What other girls do you know of that were at that party? A. I don't know. Q• Do you know of any of the other people that were at that party? A. No. Q. Just Jean-Luc and Epstein? A. Yes. U.S. Legal Support (305) 373-8404 EFTA00181322 27 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. The last time that we talked, I have just the investigative report, which basically was just typed up from the things that you said. It was written that Ms. Vasquez advised that she, herself, submitted the documents to renew foreign visa on at least two occasions. A. No, not me. It was Valenzeula. I never did her visa. That visa was done by in New York. Q. When is the first time that you learned that was involved with Jeffrey Epstein? A. I believe in 2007. After I was out of the company. Q. You didn't know, when you were in the company, that they were involved? A. No. Q. All right. At some point in time, did you get in trouble, criminal trouble, related to MC Squared? Q. They accuse me in 2006. Who accused you? A. Jeff. Q. Jeff Fuller? U.S. Legal Support (305) 373-8404 EFTA00181323 28 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. What did he accuse you of? A. Of stealing money. And I had a letter from Jean-Luc authorizing me to get the money that I had, you know. Q. And did you ultimately have to plead to criminal charges because of that? A. That was my -- what my attorney told me. Q. Yeah? A. Yeah. Q. So now you're on probation or something? A. Yes. Q. How long does the probation last? A. They did it for 20 years. So I'm just trying to reduce that. Q. Twenty-year probation? A. Yeah. Q. And other than Jeff Fuller, who else was -- who else was making these accusations? A. Only Jeff. Q. How about Jean-Luc? A. I never -- my attorney told me that Jean-Luc was never interviewed, nothing. Q. Jeffrey Epstein? A. No. Q. Have you talked to Jean-Luc about the U.S. Legal Support (305) 373-8404 EFTA00181324 29 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 whole situation? A. I spoke with Jean-Luc on two or three times. I spoke with Jean-Luc, like, two or three times during -- prior to the middle of the process, I did -- and I still have an e-mail that he send me because he wanted to talk to me, I wanted to talk to him. And I never made the time because Jeff Fuller didn't allow him to talk to me. So we never got to get together to talk. Q• And they prosecuted the case in Federal Court here in Miami? A. Yes. Q• And your entire sentence was probation; there was no prison or house arrest? A. House arrest one year. That, it was done already. And then probation. Q• The last time, I have a lot of other notes about some of the models that were being brought in and signing visas, as if they were going to work here, but really they were living in the apartment and didn't really do any modeling work. A. Yeah, that is true. That is true. I told you that. Many, many girls were coming here. Many girls were coming here first without a visa, U.S. Legal Support (305) 373-8404 EFTA00181325 30 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 without a working visa. Most of the girls, they were coming in to the States as tourists. They were working -- whenever they work, they were collecting 30 percent from their income when they were not even legal. They didn't even have a Social Security or nothing but they never pay it. Neither to the government, neither to the girls, you know. And within the time, I believe Jean-Luc start getting pressure from Mr. Epstein that he didn't want to get in trouble and he put some pressure on Jean-Luc. So he wanted all the girls to have a visa. So they start working on the visas of the girls. Q. Okay. A. And they were making, like, contracts or things like that. Because, prior to that, they didn't have it. Prior to that, when Jean-Luc prior to Jean-Luc getting the money from Mr. Epstein, Jean-Luc was doing whatever he wanted. Q. Okay. A. And later, you know, Mr. Epstein put the money that he had to start taking, you know, all the invoices from Mr. Epstein. Q• Does Jeffrey Epstein know that Jean-Luc U.S. Legal Support (305) 373-8404 EFTA00181326 31 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 is a coke addict? A. I don't know. I don't even know that Mr. Epstein knows that Jean-Luc lied to him all the time. Because when he -- when I gave the Line of Credit to Jean-Luc, Jean-Luc presented false statements to him. You know, Mr. Epstein wanted to see that the company was a profitable company and we had to hide all those numbers. And we had to give him, like, positive numbers so he can see that the company was making money but in belief always was in red. Q. What do you mean by that? Jeffrey Epstein said, hey, I'm going to give you money as long as the company is positive? A. Yeah. Mr. Epstein wanted to see -- I believe -- I believe, since he's a very successful person moneywise, he was not stupid to put his money, even though he knew he was able to get girls or whatever, you know, if that was the case. But deep inside he wanted to see if these people really -- if this company was profitable for him to put a million dollars. So maybe Eric Gany, at the time, was one of his advisors. And they wanted to see the profit and loss statements and, you know, the U.S. Legal Support (305) 373-8404 EFTA00181327 32 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 balance book or whatever. I told you the name of the accountant that you could go and took all those papers, you know, make a subpoena or whatever, of Richard Fernandez, that he could give you all the information, 1998, '99, 2000, after 2005, that he did everything and you could see the company was always in red, always. Q. So the company wasn't profitable but Jean-Luc falsified documents to show to Jeffrey Epstein? A. Yes. Q. And have you seen the real documents and the falsified documents? A. Yes. Q. So you know that they were falsified? A. Yes. Q. Is it your understanding that Jeffrey Epstein is still involved, from a financial aspect, in MC Squared? A. I believe so. Because, as far as I know, the Line of Credit wasn't paid. The million dollars wasn't paid. Q. And Jean-Luc and Jeffrey Epstein are still friends? U.S. Legal Support (305) 373-8404 EFTA00181328 33 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. Yes. Jean-Luc is still living in Jeffrey Epstein's apartment in New York. Q. How do you know that? A. Well, because -- because I know. Q. From A. Yes. Q. Is still working for MC Squared? A. No. Q. Do you know who is working for MC Squared? A. It was working until not too long ago a very -- goddaughter, , she was working there. Q. How do you spell it? A. Q. Okay. Anybody else? A. In Europe? Q. Yes, or here. A. No, that was related to Q• No, Who works in the MC Squared office here? A. Here, I knew other things, because Amanda Grant and -- I gave you her name more than one time. Amanda was working with them until 2008. And she got a lot of information. And she U.S. Legal Support (305) 373-8404 EFTA00181329 34 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 wanted -- you know, she call -- I arrange she call Immigration, because they screw her. And, actually, they made her leave the company because she has -- she is a single mother, four kids. And they were giving her a lot of bad -- bad time. (Telephone interruption.) Q. How do you spell her name, Amanda Grand, G-R-A-N-D? A. N-T. Amanda Grant. Q. And do you know her address, phone number; something like that? A. I have -- you can get it in Facebook. She's in Facebook. Amanda Grant. Q. Do you have it? A. Not in this phone. My other phone broke so I don't. I can get it for you, if you want. Q. Yeah, I would appreciate it. A. Yeah. Amanda had also the information of monies, as I told you before, that took monies that they were transferred to the British Virgin Islands. Q. Monies transferred to the British Virgin Islands? A. Yes. U.S. Legal Support (305) 373-8404 EFTA00181330 35 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. From what account to what? A. Jean-Luc opened an account there because Jeffrey told him that it was better to open an account there. So there was money -- like, for example, if the monies were going to Manuel Cruz to do a shoot or something, Jean-Luc was negotiating with the girls and say, okay, if you go to do the sunny photos, I give you $2,000 cash, no reports, whatever. So Jean-Luc had -- as billing that company from another company, or from the British Virgin Islands. So he was neither paying taxes here and maybe he was making $20,000 on that shooting and he was giving the girl only $2,000 and that money never came to be reported here. Q. Okay. Other than you saying that you know that a 15-year -old or so went to Jean-Luc's house with him, how else do we know that Jean-Luc and/or Jeffrey Epstein, I'm more concerned with Jeffrey Epstein, were involved sexually with underage girls? A. How do I know? I -- I -- I cannot tell you that I saw -- that I was there because that's not true. I never saw anything. Q• Right. But sometimes you just know? U.S. Legal Support (305) 373-8404 EFTA00181331 36 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, sometimes -- and that's -- that's what I can tell you. I know because -- I can tell you about Jean-Luc, that I know because I met him for ten years. Okay? I can put my hands on fire and I can tell you that he did it. About Jean-Luc I can say it. I don't know about Mr. Epstein because I was never -- I met him once in my life. I saw him once in my life. And after that, when I saw him, was in the newspapers; that's it. Q. And, otherwise, you just heard that Jeffrey Epstein likes underage girls? A. Underage girls, yeah. Q. And there was a time where Sergio -- well, I've talked to Sergio, so I'll talk to him about whatever the Ecuador trip was. A. Yes. Q. All right. Do you know of this company, COUQ -- A. No. Q• -- Foundation. All right. Do you know of somebody by the name of A. No. Q. Somebody who provided Jeffrey Epstein girls? A. No. U.S. Legal Support (305) 373-8404 EFTA00181332 37 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. How about A. No. Q. Never heard that name? A. No. Q• A. I believe I heard that name. But I -- Q. She works up in New York and I believe she works for Jeffrey Epstein in some capacity. Do you know what that is? A. I believe so. No. Q. Okay. A. The person who can tell you that is III. Because III was very involved with Jeffrey Epstein's office. Q. What is number again? A. Q. Do you know Jojo Fontanella? A. No. Q. No? Other than Jean-Luc, what other people that are friends with Jean-Luc share this interest in underage girls, that you know of? A. No. Q• I mean, who are his friends? Who are the guys he hangs out with? A. Jeff. When he was in Miami, Jeff, U.S. Legal Support (305) 373-8404 EFTA00181333 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 Corrado. Q. Who is Corrado? A. A friend of Jean-Luc. An Italian guy. They were always like that, Corrado and Luc. I met Jean-Luc's friends in Ecuador, like people that had to be -- people that they were involved with modeling agencies in Europe, in South America, but very different people, very different people. I met some people from France. Pero, really, even if they were guys or whatever, gentlemen. You know, like, very proper people. Like, from Brazil, too. And the womans, you know. Q. How about Simon Parra; you know who that is? A. Simon Parra, yeah. Q. How do you know him? A. I met him through Jean-Luc. Q. And what's his story? A. Mr. Parra was a very good friend of the office. I cannot say of Jean-Luc because he was only a friend of him. He was a very good friend of the office, because Mr. Parra is a gentleman. He was lending money to the office. Whenever I requested, he always gave it to me for the office. You know, that I signed -- I had to sign papers U.S. Legal Support (305) 373-8404 EFTA00181334 39 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 for him or whatever, to -- to do the payrolls or whatever. But Mr. Parra is a guy that he likes to be surrounded by girls. But not underage girls. Q. Okay. What was Jeffrey Epstein getting out of MC Squared? A. The only thing that I can think he was getting was the girls. Nothing else. Because he has all the money. Q. And the company wasn't making money anyway? A. No. Q. And you know the company wasn't making money? A. It wasn't at all. At all. So the only thing that he was -- I believe that he wanted to get involved was because of the girls, that's it. Pero, he wanted to do it legally, like, girls coming here, even if they were underage or whatever, with visas. Q. Because the modeling industry is one of those industries where there is a lot of girls underage coming in the country, right? A. Yes. Q• girls? That's pretty easy access to underage U.S. Legal Support (305) 373-8404 EFTA00181335 40 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. Yes. Q. And they come in the country and they don't have their parents? A. Yes. Q. So they don't really have any parental supervision while they're here? A. Not at all. Q. So the modeling industry is one that some guys use that to get underage girls and that's happened for a long time, really, right? A. Yes. Q. So is that what Jean-Luc Brunel still does? A. Yes. Q. Still uses it to get underage girls to sleep with, really, right? A. Yes. Q. And Jeffrey Epstein, too? A. I cannot tell you that because I don't know. I know if there is -- there is kind of a relationship, I believe they will or he will. You know, he still does it. But I don't know. I cannot tell you because I was never -- I was never -- what I can say that I know, because I was with that person for the longest, was with U.S. Legal Support (305) 373-8404 EFTA00181336 41 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 Jean-Luc. The same thing that I can tell you, that even if he has a daughter, whatever, I put my hands on fire that Jeff Fuller is gay. Q. Okay. And Jean-Luc, you saw him use cocaine at work? A. Not in the office. But sometimes he was coming to the office, like, with blood coming from the nose and white things here, that he had to go, oh, you go and clean yourself or whatever, you know. Q. Would he talk about his cocaine addiction? A. Not directly, but it was a box properly, everyone knew about that. And he was the one the kind of person who didn't feel ashamed to tell. For example, Sergio was there and I was here and he was there and he was, like, Sergio, go and get me the best one, you know. And Sergio was going and getting it for him. Q. So he didn't really hide the fact that he used cocaine? A. No. No. But not in the office, not in front of the bookers. Q. Where is the office in New York? A. Six West 14th Street. U.S. Legal Support (305) 373-8404 EFTA00181337 42 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• now? And do you know what Khalid is doing A. No. Q. Is he in Miami? A. Yes, he's in Miami. Q. Do you know his number? A. No, I don't know his number. Q. How about Mike Sanka? A. Michael Sanka, he's in California. Q. What did he do? A. He represents -- he represents artists, players. He is, like, a manager. Q. Did he have any role in procuring underage girls for anybody? A. Never. No. Not at all. Q. How about Arnaud Brunel? A. He's Jean-Luc's brother. Q. Is he here in Miami? A. No. Q. Where is he? A. France. Q. Has he ever been here in Miami? A. Yes. Q. When is the last time you talked to him? Been a while? U.S. Legal Support (305) 373-8404 EFTA00181338 43 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. 2006. No, 2003. Q• Okay. Is he close with Jean-Luc? A. No. Well, he's his brother, you know. Q. Yeah. A. There is a blood relation there. But I can tell you it's, like, oil and water, two different persons. Two different heads. Two different mentalities. Q. Who are the people -- A. A gentleman and a beast. Mr. Arnaud Brunel is a gentleman, a very correct person, very transparent. The other is the opposite. Q. Do you know this guy, Etienne? A. Etienne Rau. He was another partner of Jean-Luc, in . Another gentleman, another real good person. Actually, Jean-Luc screw him and he took him out from . He closed here in Miami, without Mr. Etienne's knowledge. Q. And if we talk to Etienne, he would not have nice things to say about Jean-Luc? A. No. Not at all. Q. What about -- A. Ruth. Q. Who is that? U.S. Legal Support (305) 373-8404 EFTA00181339 44 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. Ruth, the other lady in Paris. It's the same thing. She will tell you everything. Jean-Luc came from Paris -- Q. How do you spell her name? A. I don't know her name. Her last name I don't know. Her name is Ruth. R-U-T-H. Like, he came from Paris. Because if he stay in Paris, he had to pay taxes and this and that. Everything that he was avoiding. Q. Who, Jean-Luc? A. Jean-Luc. Q. Do you know how he and Jeffrey Epstein became friends? A. No. Q. Or why they became friends? A. No. Q. I mean, other than underage girls, what else do those two have in common? A. That's the only thing, I believe. And it's very -- you know, like, I saw Mr. Epstein once in a gym, in a church, very simple. And you see Jean-Luc on the same place and you see Jean-Luc with a -- Prada pants and with a Gucci T-shirt and with Dolce Cabana sunglasses. It's like two different characters. U.S. Legal Support (305) 373-8404 EFTA00181340 45 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. And how many girls, at any one time, would MC Squared have under them? A. A lot. Like, over 200, 300. Q. Other than the one time where four girls were taken to Jeffrey Epstein's house -- and all four of those girls were underage at the time, right? A. Yes. Q. They were 14 or 15 at the time? A. Yeah, 15, 16, 14; something like that. Q. Other than that time, what other occasion -- jog your memory, think this through -- have you known of Jeffrey Epstein to be in the same vicinity as any of the models? Was there ever a time that Jean-Luc says, hey, Jeffrey Epstein is coming up to New York this weekend, we're going to hang out at the apartment or Jeffrey Epstein is this? A. No. Never. Jean-Luc never mentioned his name until 2003, when, actually, Mr. Epstein got involved. To me, you know, to me. Prior to that, one more time, you can talk to III. She knew Jeffrey Epstein prior -- prior to me. Q. Before you did? A. Yes. U.S. Legal Support (305) 373-8404 EFTA00181341 46 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• have? And she has seen him more often than you A. Of course, because she was in New York all the time. She live in New York and I never live there. I was, like, commuting one week in New York, two weeks in Miami. One week in New York, two weeks in Miami. Q. Are you leaving to go to Colombia soon? A. To Peru. Q. To Peru? A. Yeah. Q. When? A. The 24th. Q. And do you know when you're going to be back? A. The 28th. Q. All right. Like I said, I would hope and think that this whole thing -- that your involvement is completely done. However, there is one case that Jeffrey Epstein has not settled right now that could go to trial. If it went to trial, then we could be called at trial. But it's highly unlikely that is going to happen. I'm just letting you know there is a possibility. do you know who that is? U.S. Legal Support (305) 373-8404 EFTA00181342 47 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. No. Q. A. No. Q. A. No. Q• A. No. Q. - A. No. Q. A. I know -- I didn't mention her because I didn't remember her name. Now you say it, was a girl who was working for She was not underage but she was a young girl. She was working for . She was studying and she was living at Jeffrey Epstein's apartment. She was living at his place. Q. And what was her involvement with Jean-Luc and/or Jeffrey Epstein? A. She was working at lot? Q• Okay. As a model? A. No. She was a -- an employee. Q• She traveled on his airplane with him a A. Yeah, because she's a personal friend of U.S. Legal Support (305) 373-8404 EFTA00181343 48 1 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 Jeffrey. She was living in his place. Q. Anything else about him that -- A. No. Q. Or about her? A. No. Q. A. No. Q. Any other people that you know that were living in that apartment at any time? A. No. Q. Other than the people that you named already, which are now A. I don't think lived there. was living in one of the models' apartment that we rent. Because besides those two apartments, we rent apartments in New York for the girls. Q. Who decides whether the girls live in -- A. Jean-Luc. Q. Jean-Luc decides whether the girls live at 301 that's owned by Jeffrey Epstein or the other apartments that are rented by MC Squared? A. Yeah. Q. And how does he make that determination? A. He's the owner. U.S. Legal Support (305) 373-8404 EFTA00181344 49 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. Oh, but, I mean, what are the qualifications? I mean, if he likes the girl or they're underage or they're -- A. No, if there were, like, good girls, girls that they could make money, they were living in an expensive place. If they were, like, regular girls, they were living in shitty places. Q. Okay. But which one is Jeffrey Epstein's place? A. An expensive place. Q. Okay. So the better models were living there? A. Yes. Q. do you know who that is? A. No. Q. Did you ever meet with A. No. Q. Did you know that she was friends with Jeffrey Epstein? A. No. Q. Did you ever meet A. That's the woman that was involved with Mr. Epstein, no? Q. No. is the owner of U.S. Legal Support (305) 373-8404 EFTA00181345 50 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 Victoria's Secret? A. No. No. He was a writer. Q. No. He's the owner of Victoria's Secret, The Limited, Abercrombie. A. No. No. Q. Did you ever hear anything about Jeffrey Epstein's relationships, who he was with: Male, female, a person's name? A. I knew, because III told me that he had a relationship with a woman that her father was very wealthy and that's how he started his own money. And if you tell me the name, maybe I can remember. But I don't -- Q. Ghislaine Maxwell? A. Yes. Q. And her father was Robert Maxwell? A. Yes. Q. Other than that relationship, are you aware of any other relationships of Jeffrey Epstein? A. No. Q. How many times are you aware of Jean-Luc bringing underage girls to Jeffrey Epstein's home in Palm Beach? A. While I was there, when I was working U.S. Legal Support (305) 373-8404 EFTA00181346 51 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 with them, maybe -- maybe two, three times a year. The last year; you know, 2003, 2004, 2005. Q. And how would you know -- A. Not prior to that. Q. How would you know that Jean-Luc was taking underage girls to Jeffrey Epstein's house during those years? A. Because he was saying in the office: There is a party at Jeffrey's house; I'm taking the girls. And the girls, that they were in town, they were, like, underage girls. Q. We are still talking about 14, 15? A. Sixteen, yeah. Q. Sixteen, at the oldest? A. Yes. And they were going, the other girls, too, but he -- he personally was taking the little ones. Because the other ones, they could go in their own cars or whatever, you know, with their boyfriends. Q. Did you ever say anything to him about taking underage girls to Jeffrey Epstein's house? A. You know, as a mother I always told him that they were underage girls. And he was saying, oh, that I'm the father. Q• But you knew what was going on