UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME II Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 a.m. - 6:10 p.m. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Reported By: Pamela J. Sullivan, RPR, FPR, CLR Prose Reporting Agency, Inc. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772-15521 Electronically signed by Pamela Sullivan (501.333-772-1552) 41151584-6022-4050-b036-0423518c2lb5 EFTA00750740 Page 131 APPEARANCES! ▪ On behalf et the Plaintiff. Jaw Doe: 3 BRAD J. EDWARDS. ESQIARE ROTHSTEIN ROSENFELDT ADLER Las Obs City Cann, Suite 1650 40) East Les Clef Boulevard Fm Loodadok, Plaids 33301 On is . Jeffrey Epstein: ROBERT D. CRITTON. JR . ESQUIRE BURMAN. CE/TION.LATIllER & COLEMAN, LIP e 303 Banyan Boulevard Suite HO 33401 11 12 13 t1 15 14 17 18 19 20 On behalf of hint Dons I chrome, 8: ADAM D. HOROWITZ, ESQUIRE 22 MER).031STEIN & HOROWITZ, P.A. l$205 MST= TH8Mv" 23 Suite 73I8 Mimi. Met 33160 21 Om behn lathe Defendant. Jeffrey Eenciir JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY. G01E/BERGER & WEBS, EA 250 Aisle Mesa Sou& Site 1400 Were Palm Bock Florida 334014012 On behalf of Plaintiff in Related Case No. 0840469: ISIDRO M. GARCIA. &S0USE GARCIA LAW FIRM. P.A. 224 Dana Steel. Site 90D miW Palm Beech Florida 33401 24 25 1 2 3 4 5 6 7 Page 133 - - - INDEX - - VilINESS: DIRECT CROSS REDIRECT RECROSS JANE DOE BY MR. CRITTON 5 EXHIBITS MARKED 9 10 11 DESCRIFT1ON 12 Defaidrates No. 5 13 (Order) 14 15 16 17 18 19 20 21 22 23 24 25 PAGE 163 Page 132 1 On behalf of the Plaintiff= : 2 JAOC P. HILL, ESQUIRE SEARCY DENNRY SCAROLA BARNHART & SHIPLEY, PA. 3 2139 Palm Beach Lakes Boulevard West Palm Bead), Florida 33409 4 5 On behalf of the B.B.: 6 ADAM 1 LANONO, ESQUIRE LEOPOLD KUVD/ 7 2925 PGA Boulevard, Suite 200 Palm Beach Gradats, Florida 33410 9 10 11 12 13 14 15 16 17 18 19 20 21 22 -23 24 25 ALSO PRESENT: Jeffrey Epstein, via video conference Stan Sanders, Videographer 1 2 3 4 Page 134 PROCEEDINGS (Continued from Volume lof the same day.) VIDEOGRAPHER: Back on the record at 11:52. 5 BY MR. CRITTCIN: 6 Q. Ms. Jane Doe, I have in front of you, I 7 think, Exhibit 4 w be Exhibit 4, which 8 is the declaration . Do you see that? 9 A. Yes. 10 Q. And I will represent to you, and I think you 11 told me you don't know who she is; correct? 12 A. Yes 13 Q. And on Page 2, she says is, "I" — in her 14 declaration says — the first sentence says: "I am the 15 Assistant US — United States Attorney, assigned to the 16 investigation of Jeffrey Epstein," and then — "and the 17 case was investigated by the Fetal Bureau of 18 Investigation, FBI," et cetera, et cetera. 19 Do you see that up at the top? 20 A. Yes. 21. Q. Okay. That's who she says she is. And then 22 she's — on Page 7 of her declaration she says: 1 23 declare, under penalty of perjury, pursuant to 28 USC, 24 Section 1746, that the following is true and correct, to 2 5 the best of my knowledge and belief." And then she (561) 832-7500 2 (Pages 131 to_124) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (501-333-7724652) 4415158d4c22-4460-130354423518e2fb6 EFTA00750741 Page 135 1 signs this on 9th day of July 2008, and then it purports 2 to be what is her signature above her printed name. 3 Do you see that? 4 A. Yes. 5 Q. All right. If I go to paragraph three, down 6 at the bottom it says here -- there's a reference to 7 Jane Doe, Page 3 — I'm sorry — Page 2, paragraph 8 three. Are you with me? 9 A. Yes. 10 Q. Go up — not — not the footnotes. You brow 11 what a footnote is; don't you? 12 A. Yes. 13 Q. All right. Go up from the footnotes, then 14 one, two, three lines up it says: "Jane Doe was 15 identified? 16 Do you see that? 17 A. Yes. 18 Q. You are that Jane Doe; correct, Jane Doe? 19 A. Those are my initials. 20 Q. And -- and if you read in fact, I should 21 probably have you just — why don't you read to yourself 22 paragraph three, because there's a reference to 23 Mr. Edwards and three of his clients,.., M. and 24 Jane Doe. Do you see that? 25 A. Yes, I do. Page 137 1 Do you see that? 2 A. Yes. 3 Q. And then it says: "The FBI's Victim Witness 4 specialist sent a letter to Jane Doe," you, "on May 30, 5 2008." 6 Do you see that? 7 A. Yes, I do. 8 Q. Okay. You indicated that you were -- when I 9 asked you earlier today — excuse me — when you had 10 given your statements and you said, emphatically, you 11 were three and a half months pregnant; correct? 12 A. Yes. 13 . All ri t. You wouldn't dispute 14 and the FBI's agents' statement that 15 they interviewed you on May 28th 01'08; correct? 16 A. No. 17 Q. And I think you — well, I don't think. Let 18 me start again. 19 You've told us — you've testified that you 20 only talked with the FBI on one occasion, and that one 21 occasion bad to have been May 28th of '08; correct? 22 A. Yes. 23 Q. Okay. And that was the first time, at least, 24 that you had told any governmental authority, state, 25 Federal, local, that you had been to Mr. Epstein's home; Page 136 Q. Okay. fl would be M. -- 2 A. Yes. 3 Q. — you would assume. would be II., and 4 you would have to be the Jane Doe; Jane Doe? 5 A. Yes. 6 Q. Are you aware of any individuals that Miss -- 7 Mr. Edwards represents, other than you, ■ ani M.? 8 A. No. 9 Q. All right. Then it goes down — again, 1 10 take you back where it says: "Jane Doe was identified 11. via the FBI's investigation in 2007, but she initially 12 refused to speak to investigators." 13 Doyou see that? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: Yes, d do. 16 BY MR. CRJ1TON: 17 Q. And that's true; you did refirse to speak with 18 them? 19 MR. EDWARDS: Object to the form. 20 rim WITNESS: Yes. Yes,1 did. 21 BY MR. CRITTON: 22 Q. All right. And then it says: 'Jane Doe's 23 status as a victim of a Federal offense was confirmed 24 when she was interviewed by Federal agents on May 28th, 25 2008." Page 138 1 correct? 2 A. Yes. 3 Q. And if you go to Exhibit 5 — 4 MR. CRITTON: And, Mr. Edwards, if you could 5 help your client. 6 MR- EDWARDS: I haven't seat an Exhibit 5 7 yet, Ideal think. MR. CRITTON: It's — sorry. Exhibit 5 9 to ExhilAt 4. My fault 10 MR. EDWARDS: Okay. Just to show her where 11 it is. It's -- if you look up at the upper, 12 right-hand comer, there's a May 30th letter. 13 MR. CRITTON: May 30, 2008, letter. It's: 14 "Dear Jane Doe," and it's been redacted in part. 15 MR. EDWARDS: Let's see if I can get there, 16 and then rit get her there. 17 BY MR. CRITTON: 18 Q. If you look — you're now loo at 19 Exhibit 5 to our Exhibit 4; correct, to 20 declaration? 21 A. Okay. 22 Q. And you see it's a letter from the US 23 Department ofJustice. It's dated May 30th, 2008, and 24 it says: "Dear Jane Doe," because your name has been 25 redacted; correct? (561) 832-7500 .4.1•••••..n .x4 3 (Pages 135 to 138) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (661.333-772.1652) Electronically signed by Pamela Sullivan (601-333-772-1652) 4f151584-6c22-4c50-b036o423618c2fbS EFTA00750742 Page 139 1 A. Uh-huh. Yes. 2 Q. And is this the Victim's Assistance Program, 3 a letter that you said you received sometime after you 4 met with the FBI? 5 A. Yes. 6 Q. Okay. And I think you said — your -- your 7 best recollection was within a week, which is consistent 8 with this letter, which also then reconfirms that the 9 FBI had to have met with you, as reflected in the 10 declaration on May 28th, 2008, for the very first time; 11 correct? 12 A. Yes. 13 Q. All right. At the time that you received 14 this letter, 'think you also told us that you had not 15 been represented, or you -- Mr. Edwards was not 16 representing you at that time; correct? 17 MR. EDWARDS: Object to the form. 18 THE WITNESS: Yes, it was shortly after. 19 BY MR. CRITTON: 20 Q. All right. If you then go down to Exhibit 7, 21 and it's easier to read. 22 MR. EDWARDS: Flip a few pages. 23 THE WITNESS: Here? 24 MR EDWARDS: Keep going (inaudible). 25 THE WITNESS: Okay. 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 Page 141 does that refresh your recollection that the FBI told you that you could file some sort of civil suit against Mr. Epstein? MR. EDWARDS: Object to the form. THE WITNESS: Yeah, they — they may have mentioned something of it. BY MR. CRITTON: Q. Okay. So that — that refreshes your recollection that the FBI said, You know, you may want to go get your own lawyer and bring a money — a civil suit against Mr. Epstein; we're only criminal people? M. EDWARDS: Object to the form. BY MR. CRITTON: Q. Does that refresh your recollection? A. Which document refreshes her recollection? Any of this? MR. CRITTON: No, I just quoted back to her what she said to me. MR. EDWARDS: Okay. Well, if you know the answer to what he's talking about, then answer it. THE WITNESS: They didn't — I know — I mean, I don't remember what exactly they said to me, but they did mention that I should get a lawyer. Page 140 1 BY MIL CRITTON: 2 Q. This is a letter also from the US Department 3 of Justice. It's from EMS It's directed to 4 Mr. Edwards. It's dated July 9th, 2008. 5 A. Uh-huh. 6 Q. And it says, Re: Jeffrey Epstein/S, and then 7 there's a redaction, ft/Notification of Identified 8 Victim. 9 Do you see that? 10 A. Yes, I do. 11 Q. Okay. Have you ever seen this letter before? 12 A. I don't remember seeing this. 13 Q Now, having seen the affidavit, Exhibit 4, 14 that is the declaration of that reflects 15 that you met with the FBI on May 28th, and consistent 16 with your earlier testimony, that you got the victim's 17 assistance letter shortly thereafter, which we now know, 18 from looking at one of the exhibits to the declaration, 19 was May 30th of '08. 20 Does that in any way refresh your 21 recollection how you got -- or from whom or how you got 22 the card to go find Mr. Edwards? 23 A. Well, no. 24 Q. Okay. And now, having seen the declaration 25 in exhibits -- and the exhibits that we've identified. Page 142 1 BY MR. CRITTON: 2 Q. All right. And that you might be able to get 3 money? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't — leant remember 6 them saying anything to me about money. 7 BY MR. CRITTON: 8 Q. Then why would you need a lawyer under these 9 circumstances for any reason? You weren't — or did. 10 they indicate to you that you were a target of any 11 investigation? 12 MR. EDWARDS: Object to the fain. 13 THE WITNESS: Basically, they just told me 14 that what happened to me was wrong, and that I 15 should do something about it. 16 BY MR. CRITTON: 17 Q. Okay. And you understood that doing 18 something about it was filing a lawsuit against 19 Mr. Epstein and ask for money? 20 MR. EDWARDS: Object to the form. 21 BY MR. CRITTON: 22 Q. Is that a fair statement? 23 A. Well, I wanted to have him prosecuted for 24 what he did, but I obviously can't do that. 25 Q. Because — because you know from your own (561) 832-7500 4 (Pages 139 to 142) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772.1652) Electronically signed by Pamela Sullivan (601.333.7724662) 4f15158d-8c22-4c50-b036-e423618c2fb5 EFTA00750743 Page 143 1 criminal experiences that it's either the State of 2 Florida or the United States Government that prosecutes 3 people, not individuals; true? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't understand. 6 BY MR. CRITI'ON: 7 Q. Well, you know that you can't prosecute -- a 8 citizen doesn't have the right to prosecute. It's — 9 ifs an arm of the Government, and you know from your 10 own experience. That is, when you got in trouble with 11 the law, you know it was the State of Florida versus 12 you; comet? 13 MR. EDWARDS: Object to the form. 14 THE WITNESS: That's not something that I 15 specifically 'mew from my own experience, no. 16 BY MR. CRITTON: 17 Q. Okay. Well, well get to that a little 18 later. Let — let me go back to the discussions that 19 you had with the FBI. I think you told me — well, I 20 know what I wanted to ask you. If you go back to 21 Exhibit 4, Page 2 — 22 A. (Witness complies.) 23 Q. — same paragraph, paragraph three. It says: 24 Attached hereto are copies of letters provided to 25 Mister — or to Bradley Edwards, three clients,.., Page 145 1 Third sentence says: "All three of those 2 clients were victims of Jeffrey Epstein's while they 3 were minors, beginning when they were 15 years old. 4 Do you see that? 5 A. Yes, I do. 6 Q. Okay. SoMM, based upon her 7 knowledge and the interview or the conversation that she 8 had with the FBI and the information they had, have you, 9 mi. anal. all being at least 15 when you first saw 10 Mr. Epstein do you see that, at least what's 11 represented in her sworn statement — 12 MR. EDWARDS: Object to the form. 13 THE WITNESS: Yes, I can see what it says. 14 BY MR. CRITTON: 15 Q. All right. Did the FBI at any time — well, 16 let me — let me ask this question: If the FBI -- if 17 you told the FBI that you were 15 when you first saw 18 Mr. Epstein, based upon this declaration, does that now 19 refresh your recollection that you never went to 20 Mr. Epstein's home for the first time until after you 21 turned 15 which would have been sometime after Mi 22 23 MR. EDWARDS: Object to the form. 24 THE WITNESS: I remember specifically telling 25 than and Jeffrey that I was 14 when I first met Page 144 1 M. and Jane Doe. And then there's a 1 for the 2 footnote. 3 Do you see that? 4 A. Yes. 5 . All • t. And, again, recognizing that 6 is a United States Attorney, and that 7 she's signing this declaration of oath under oath, based 8 on her conversations that she had with the FBI -- at 9 least that's what it purports to say — but go down to 10 Footnote 1. It says: "Attorney Edwards filed this 11 motion on behalf of Jane Doe, without identifying which 12 of his clients is the purported victim." 13 Did I read that correctly? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: I don't know. 16 BY MR. CRITTON: 17 Q. I want you to follow along. Did I just -- 18 let me read it again. 19 A. Oh, I read it ahead of you. 20 Q. I'm sorry? You're ahead of me? 21 A. Yeah. 22 Q. Okay. Well, then, we'll just — let me go to 23 the second sentence. It says: Accortlin_glyI wil I 24 take --will address facts related toM., M. and 25 Jane Doe. Page 146 1 Jeffrey, and I told him that I was 15. 2 BY MR. CRITTON: 3 Q. Okay. Well, but you would agree with me that 4 at least Miss — the FBI and the US Attorney's Office 5 believed you were 15, based on something that you told 6 them; coned? 7 MR. EDWARDS: Object to the form. 8 THE WITNESS: It looks like that's what they 9 believed. But they obviously misinterpreted what! 10 told them, because I know what I told them. 11 BY MR. CRITTON: 12 Q. Would you agree with me that your 13 recollection back in 2000 -- May of 2008 was probably 14 better than it is today -- 15 MR. EDWARDS: Neet to the form. 16 BY MR. CRIITON: 17 Q. -- in September of 2009? 18 A. What do you mean? 19 Q. Well, would you agree that with another -- 20 let's see — with another 16 months having passed since 21 May of 2008, that your recollection as to the events 22 involving Mr. Epstein were better back in 2008 than they 23 are now? 24 MR. EDWARDS: Object to the form. 25 THE WITNESS: No. 5 (Pages 143 to 146) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1652) (561) 832-7506 4f15158d-6c22.4c50-b036-e423618c21b5 EFTA00750744 Page 147 1 BY MR. CRITTON: 2 Q. Okay. You think your recollection is better 3 now? 4 A. No, I think it's pretty much the same. 5 Q. All right. You told me the FBI well, let 6 me strike that. 7 You said you told the FBI how you came to be 8 at Mr. Epstein's the first time; correct? 9 A. Yes. 10 Q. doiaLin response to their question, you told 11 them than. took you; correct? 12 A. Yes. Yes. 13 Q. How many times did — did you go or 14 take you to Jeffrey Epstein's home? 15 A. One. 16 Q. Just the first time? 17 A. Yes. 18 Q. And what dia. tell you about -- well, let 19 me strike that. 20 You were friends within.? 21 A. Yes. 22 Q. And you say it was, at least your 23 recollection today, is it was sometime in February, plus 24 or minus a month, of '03? 25 A. Yes. Page 149 1 Initially acquaintances, but eventually friends? 2 A. Yes. 3 Q. Let's see. 4 would have been there sixth, seventh and eighth? 5 A. No. I went there for sixth grade, and I 6 moved in seventh grade. 7 Q. Dice stay there? 8 A. I don't know. 9 Q. Where did u o for seventh grade? 10 A. 11 Q. Is that because you moved locations where you 12 were living? 13 A. Yes. 14 Q. Okay. And in sixth grade you would have 15 been — lets see -- sixth grade you would have been how 16 old? 17 A. Eleven. 18 Q. Who were you living with — who were you 19 living with when ou went to 20 A. 21 Q. 22 A. Yes. 23 .O . Who were you living with when you went 24 25 A. I was in between Page 148 1 Q. All right. When you went the first time — 2 or before ou went the first time, how long had you 3 4 A. About three years. 5 Q. And did you meet — how did you meet..? 6 A. I met her in the sixth grade at school. 7 Q. Was she in your class? 8 A. No. 9 Q. Is she older or younger, same age? 10 A. I think she's a little bit younger, but she's 11 about the same age. 12 Q. You mean within a couple of months of one 13 another? 14 A. Yes. 15 Q. How tut..., by the sixth grade did you 16 already know...? 17 A. No. 18 Q. So.. was the first person you knew? 19 A. Yes. 20 Q. What school was that? 21 A. 22 Q. ou were in same si 23 different classes? 24 A. Yes. 25 Q. Did you know — and you became friends? 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 Page 150 mother. Q. Is this during the time that is — between the sixth and the seventh grade, is this the time that MR EDWARDS: Object to the form. THE WITNESS: It was summer before seventh tirade BY MR. CRITION: Q. Is that the reason that you were no longer wit at that point in time, and why you went to A. Yes. Q. Did you stay in touch withMI.? A. No. I (561) 832-7500 6 (Pages 147 to 150) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601433-772-1562) Electronically signed by Pamela Sullivan (601-333-772-1662) 4t15158d-6c22-4c50-b0364423618c2tb5 EFTA00750745 Page 151 1 Q. When you were in sixth grade, did you and 2 used to play together? 3 A. No. 4 Q. Did you -- you just knew each other from 5 school? 6 A. Yes. 7 Q. Did you ever meetEL's mom? 8 A. No. 9 Q. Have you ever met..'s mom? 10 A. No. 11 Q. Hasa. ever talked to you about her morn? 12 A. No. 13 Q. Has anyone ever told you thatle.'s mom is a 14 prostitute? 15 A. No. 16 MR. EDWARDS: Object to the form. 17 BY MR. CRITTON: 18 Q. Have you heard that before today, that..'s 19 mother was a prostitute? 20 A. No. 21 Q. Did you see. during your seventh grade at 22 all? 23 A. No. 24 Q. How about eighth grade? 25 A. We were living close to each other, so I met Page 153 1 A. No. 2 Q. -- legal or illegal? 3 A. No. 4 Q. Prescription drugs that — although they 5 weren't your prescription? 6 A. No. 7 Q. Were you aware that.. was doing drugs -- 8 A. No. 9 Q. — or alcohol back at that poim in time in 10 sixth, seventh and eighth -- sixth and seventh grade? 11 A. No. 12 Q. How about eighth grade, were you — had you 13 started drinking by the time you had hit eighth grade? 14 MR. EDWARDS: Object to the form. 15 BY MR. CRITPON: 16 Q. By drinking, I mean alcohol. 17 A. I —1 had probably had a drink at some 18 point. 19 Q. And had you started doing drugs by the time 20 you were in the eighth grade, illegal drugs? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: Yes. 23 BY MR. CRITTON: 24 Q. All right. And what had you started? 25 Smoking pot? Page 152 1 her again, yes. 2 th grade, were you still at 3 4 A. Yes. 5 Q. But you were living closer now toll., so 6 you started hanging out together or were friendly, 7 became friends again? 8 A. We hung out once in a while, not a whole lot. 9 Q. And I think you said you never have been to 10 M.'s house? 11 A. No, I had never — 12 Q. Back at that point in time. 13 A. No. 10 Q. Okay. Had she ever been — had you ever 15 brought her over to your house or your grandmother's 16 house or wherever you were living at the time? 17 A. Yes. 18 Q. And this would have been in what, in eighth 19 grade now we're talking about? 20 A. Yes. 21 Q. Okay. When you were in sixth grade and 22 around.., did you and IS ever drink alcohol 23 together? 24 A N 25 Q. Did you ever do any kind of drugs together — racc2 3 4 5 6 7 8 9 10 11 12 13 14 15. 16 17 18 19 20 21 22 23 24 25 Page 154 A. Yes. Q. All right. How about the Ecstasy, the one Ecstasy that you say you took, was that back in the eighth Veda MR. EDWARDS: Object to the form. THE WITNESS: I was either 13 or 14. BY MR. CAPTION: Q. So at least before you met Mr. Epstein, you had at least done — you were drinking alcohol, you were using pot, and you had had Ecstasy; true? MR. EDWARDS: Object to the fonn. THE WITNESS: Yes. BY MR. CRITTON: Q. And had you also had Xanax by age 12,13, 14? A. No. Q. Did you ever smoke pot with.? And Pm talking eighth grade. A Probably. Q. And how about Ecstasy, were you or. — well, let me strike that. Had you ever taken Ecstasy when.. was around? A. No. Q. Okay. Who were you with when you had the Ecstasy? (561) 832-7500 PROSE COURT REPORTING AGENCY, 7 (Pages 151 to 154) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 4,15158d-6c22-4c50-b036-e423618c211,5 EFTA00750746 1 2 O. Who? 3 4 5 6 A. I was with an old friend. Page 155 8 Q. Is she a friend of yours? 9 A. [haven't seen her or spoken to her in a few 10 years. 11 Q. Did she used to live out -- or in the area 12 that you did? 13 A. Yes. 14 Q. Is she older, younger, or same age? 15 A. Well, she went to the same school. We were 16 the same age. She was — she's a little bit younger, a 17 few months. 18 Q. Okay. And when you would smoke pot, who did 19 you get that non? 20 MR. EDWARDS: Object to the form. 2/ THE WITNESS: I don't know. 22 BY MR CR11TON: 23 Q. Okay. Did you ever get it from your 24 grandmother? 25 A. No. Page 157 1 A. She was friends with my friend. 2 Q. She being who? a? 3 A. Iff. was friends with my friendM, and 4 that's howl met her. 5 6 A. Yes. 7 Q. What age? Q. So you mean. through..? 8 A. Thirteen or 14, ma I'm not positive. 9 Q. And did you . hit it off right away, 10 once you met through 11 A. No, we did not. 12 Q Did you ever smoke pot with. back at that 13 time? Because she was using drugs, too; wasn't she? 14 MR. EDWARDS: Object to the form. 15 THE WITNESS: I don't know what she was 16 doing. 17 BY MR. CRITIC:1N: 18 Q Okay. Are you saying she wasn't using drugs, 19 or you just don't know, one way or the other? 20 A. I just don't know. 21 Q. But you've used illegal drugs within.; 22 haven't you - 23 MR. EDWARDS: Object to the form. 24 BY MR. CRITTON: 25 Q. - from the time you met her? Page 156 1 Q. Okay. Did you ever smoke pot in your 2 grandmother's house? 3 A. Probably. 4 Q. Okay. Was she aware that you were smoking 5 pot? 6 A. No. 7 Q. in., after -- during eighth grade continued a to be friends? 9 A. Yes. 10 Q. Okay. When you say you went to Epstein's 11 house for the first time, what grade were you in? 12 A. 1 was in eighth grade for the second time. 13 Q. You repeated eighth grade? 14 A. Yes. 15 Q. So ou would have still been at — at that 16 time at 17 A. In the middle of that year I believe I left 18 that school and went to an all girls school. 19 Q Was that la 20 A. Yes. 21 _9. But you were still — you would still see 22 IN. front time to time? 23 A. Yes. 24 Q. Okay. Was was., around this time, as 25 well? Were you friends now with? (561) 8 3 2-7 5 0 0 Page 158 1 A. Yes, 2 Q Now, when you first mail, where was she 3 living? 4 A. She was living with her mom in — 5 Q. Do you know what her mom's name is? 6 A. Eva. 7 Q. Did you ever go ova to.'s house, back at 8 that time period — 9 A. I - 10 Q. - seventh, eighth, ninth grade? 11 A. I went outside her house once. I — I had 12 never been inside of her house. 13 Q. But you met her mom? 14 A. No. 15 Q. You never met her mom? 16 A. I have met her mom, but at that point, no. 17 Q. Okay. Did you meet her mom after this 18 lawsuit has been filed? 19 A. No. 20 Q. Did you meet her at what point in time? 21 A. I met her when I worked at 22 Q. Did she come in as a -- was she a waitress 23 there, or did she — 24 A. She worked there. 25 Q. Did she help you get your job? 8 (Pages 155 to 158) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4.16168d4c22-4c5043038-6423118c2lb5 EFTA00750747 Page 159 1 A. Yes. 2 Q. And was that when you were living within.? 3 A. Yes. 4 Q. Okay. That was when were living with 5 at the apartment with MI? 6 A. Yes. 7 Q. And when — was there &At else living 8 there at that apartment with you, andM. during 9 that few months that you were there in 2006? 10 A. No. 11 Q. And that's when you met mom — mum -- 12 mother? I'm sorry. 13 MR. EDWARDS: Foam 14 THE WITNESS: Yes. 15 BY MR. CRITTON: 16 Q. And did.. say, you need to get a job, you 17 know, why not -- maybe my mom can help you get a job at 18 IHOP? 19 A. No. I expressed to her that I wanted a job. 20 Q. Had you had a job before that point in time? 21 A. Not really a real job. I had — I had a job, 22 but I — I like went there for a week, and stopped. 23 Q. And that was where? 24 A. 'worked for named 25 Q. Who is IMMI? 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 Page 161 and you were hanging out with..? MR. EDWARDS: Object to the form. BY MR. CRITTON: Q. You were friends — were friends within.? MR. EDWARDS: Object to the form. THE ‘VITNES.S. Yes. BY MR. CRITTON: Q. And at that time that . first approached you, were you aware that been to Mr. Epstein's home? A. I didn't know fora fact, no. Q. I'm sorry? A. II did not know fora fact. Q. And what did — what did.. tell you? A. About going to left E in's house. Q. What did — what did . raise with you? That is how did the — before . ever told you or asked you whether you'd be interested in to Mr. Epstein's home, did she -- that is M. — were you aware that she had been to Mr. Epstein's home? That is had she talked about it amongst you all? MR. EDWARDS: Object to the form. THE WITNESS: I had heard about it, not from . whether or notill. had 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. He is an auctioneer. He is my uncles friend. home? A. No. Q. Another uncle? A. Yes. Q. Another brother of Mr.MIT A. Yes. Q. What's his name? A. Q. Is his first name? A. Yes. Q. What's his last name? A. Q. They - looks like there's a — was it a Page 160 The uncle who drove you to Mr. Epstein's A. Yes. Q. A and__, but they're — are they like stepbrothers with your dad? A. My dad was a first born. He has a different father. Q. All right. So I think you told me you would have been at Mr. Epstein's house you would have been in the eighth grade for the first time, eighth grade, Page 162 1 BY MR. CRITTON: 2 Q. What had you heard and from whom? 3 A. I don't remember who exactly it was. It may 4 have been..'s boyfriend at the time. 5 Q. Which boyfriend would that have been? 6 A. I don't know. I think probably her baby's 7 Either. 8 Q. ENNia? 9 A. Yes. 10 Q. Did you lmow MEM 11 A. Yes. 12 13 with . . Did you ever have sexual relationship 14 A. No. 15 Q. Did you ever have one with Ma? 16 MR. EDWARDS: Object to the form. Fm 17 instructing the witness not to answer, invoking her 18 privacy rights, privacy rights of third parties. 19 MR. CRITTON: Well, let me just do something 20 so we can get this on the record. 21 Is — lame have marked as Exhibit where 22 are we — 5. 23 (Discussion held off the record.) 24 MR. CRITTON: Four was the declaration of 25 Marie Villafana. (561) 832-7500 9 (Pages 159 to 162) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-3334724662) Electronically signed by Pamela Sullivan (501-333472-1662) 4115158d-6c22-4c50-b036-e423618c2035 EFTA00750748 Page 163 1 This is going to be marked as Exhibit 5. 2 (Discussion held off the record.) 3 (Defendants Exhibit No. 5 was marked for 4 identification.) 5 BY MR. CFUTTON: 6 Q. Exhibit 5 is the order that Judge Johnson 7 entered on September 4,2009, in the consolidated case 8 that dealt specifically with Mr. Epstein's emergency 9 motion for independent medical exam, and it was directed 10 to Mr. Ifill's client, 11 Within — within that order, on Page 2 she 12 says — or dealt with questions that could be asked, the 13 scope of the exam. But Judge Johnson — 14 MR. CHINON: And I just want to put this on 15 the record, and then we can move on, if your 16 instruction is the same, Brad. 17 But she talks about it in the first paragraph 18 on the second page, first full paragraph. She, 19 Judge Johnson, who's dealing with a discovery 20 issue, says, the remaining issues involve 21 Plaintiffs request for an order limiting the scope 22 of the proposed examination by disallowing repeated 23 questioning regarding, quote, highly sensitive 24 areas of inquiry, including Plaintiffs medical 25 history, psychiatric history, sexual history, 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 1 2 3 4 5 7 9 0 2 3 4 5 6 7 6 0 1 2 3 4 5 Page 165 support her novel position that the Plaintiff who puts her mental, emotional and psychiatric state at issue can place a limitation on the number of times defense counsel, or agents retained by him, can inquire into areas relevant to these 'Min where the subject matter involved is highly personal, embarrassing, sensitive or otherwise humiliating. Plaintiff is seeking millions of dollars in personal injury damages for, among other things, physical injury, pain and suffering, emotional distress, psychological, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity and invasion of her privacy. And she on to describe at least specifically to And then the last two sections I want to just put on the record is on the first — first MI paragraph on Page 4. It says: Under these circumstances, where Plaintiff — MR. EDWARDS: Circumstances of-., that's what we're talking about; right? MR. CIUTTON: Right. Under these circumstances — MR. EDWARDS: Yes. MR. CRITTON: — where Plaintiff is seeking Page 164 1 social history, sexual abuse history, substance 2 abuse history, et cetera, and imposing certain time 3 restraints on the examination itself And the Court goes on to deny — the 5 Plaintiffs request to limit the scope of the 6 examination is denied. 7 And if you go over on Page 3, Judge Johnson 8 says: Presumably, Plaintiff—and there was a -- 9 there was a questionnaire that was being referenced 10 then — she says: Presumably, Plaintiff, who in 11 this instance to this older was-., but it 12 applies to every Federal court Plaintiff, will be 13 asked these questions two or more times, first by 14 defense counsel at And/tone's deposition scheduled 15 to take place shortly, and again by Dr. Hall at the 16 upcoming examination. 17 And then she goes on to say that Plaintiffs 18 objection is that, by having to answer these same 19 questions about the same subject matter three 20 separate times would only serve to embarrass, 21 humiliate, intimidate and further victimize the 22 Plaintiff. 23 She - she - Judge Johnson goes on to say at 24 the next full paragraph: Plaintiffs site no case 25 law, and independent research has uncovered none to 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 Page 166 1 to recover medical expenses associated with these 2 complex medical issues, full knowledge of the 3 Plaintiffs past and present medical, 4 psychological, familial, social histories is 5 essential. And while neither a duplication nor 6 embarrassment is desired, under the circumstances 7 presented, where the number and the scope of 8 damages claimed are vast and the Plaintiffs past 9 history eventful, it may nonetheless be 0 unavoidable. 1 And then she goes: This is not to say that 2 the restrictions on the scope of the questions may 3 never be put into effect, and if the case 4 progresses, and Plaintiff can show that Defendant's 5 invasive questioning is being done in bad faith or 6 for purposes of harassment, the Court may 7 reconsider imposing limitations of the sort 8 requested herein. 9 At this point however, the Court agrees with Defendant that to restrict the number of times 1 defense counsel may ask the Plaintiff personal and 2 sensitive questions concerning some of the pivotal 3 issues in this case would work an injustice by 4 preventing Defendant from being able to defend 5 himself. (561) 832-7500 SALL.N.a..“*.erIbLenf 10 (Pages 163 to 166) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4115158d-t3c22-4c50-b036-e423618c2145 EFTA00750749 Page 167 1 So I don't know ;whether you have seen this 2 order — 3 MR. EDWARDS: Yeah. Well,1— I haven't 4 seen it, but having read that, it certainly doesn't 5 change my position. Ifs clearly talking about a 6 different Plaintiff different set of 7 circumstances. And very seldom, if ever, does it talk about issues regarding the names of sexual 9 partners, sexual positions or sexual activity. It 10 talks about other things that I have let you 11 conduct your examination on. So... 12 MR. HILL: And the other thing is, is I filed 13 the motion so, to be included in this record, the 14 scope of the relief that I was seeking, the motion 15 for protective order. The motion to limit the Chit 16 was regarding repeated questioning in the same 17 areas of inquiry. Nothing about that motion for 18 protective order sought to prevent discussion about 19 past sexual history at all. It was to the number 20 of times it could be disclosed and discussed. 21 So to suggest that that is somehow a ruling 22 that everything is open game is not entirely 23 consistent with the relief that I was seeking in 24 that motion. 25 MR. EDWARDS: So if you want to make this an 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 Page 169 MR. EDWARDS: If it relates to sexual partners' names or sexual positions and things that are obviously intended only to humiliate, yes, that's going to be my objection. MR. CAPTION: Now, Pam, if I could get you to go back to the question I asked. So long, Adam. (Whereupon, Mr. Horowitz left the proceedings.) (Whereupon, the requested portion of the record was read aloud by the Court Reporter.) MR. CRITTON: Let me be clear on the question. Let me see the question preceding. COURT REPORTER: This is the preceding question... (Whereupon, the requested portion of the record was read aloud by the Court Reporter.) BY MR. CRITTON: Q. All right. Let me just ask the question so it is clear: Did you ever have a sexual relationship with MR. EDWARDS: And Pm instructing the witness not to answer, based on her own privacy rights, as well as the privacy rights of third-party, innocent persons. Page 168 1 exhibit, you can. 2 MR. CRITTON: I'm just saying -- 3 MR. EDWARDS: It certainly doesn't change my 4 position. 5 MR. CRITTON: All right. And I'm just saying 6 this is — we're going to come — I will certainty 7 ask the Court for relief - 8 MR. EDWARDS: Sure. 9 MR. CRITTON: -- for sanctions and the costs 10 and fees related to that. 11 ljust wanted to give you the opportunity to 12 read the order and what she said about defense 13 counsel asking repeated questions about these areas 14 or the number of times that they'll be asked, not 15 only by defense counsel — 16 MR. EDWARDS: It sounds like- 17 MR. CRITTON: -- but as well by the doctor. 18 So I think ifs an appropriate area. You can 19 still stay with your same instructions. 20 MR. EDWARDS: Yeah, it sounds like you can 21 ask it as many tunes as you want 22 MR. CRITTON: And you'll continue to object. 23 MR. EDWARDS: Well, it depends on the 24 question. 25 MR. CRITTON: All right. 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 Page 170 BY MR. CRITTON: Q. Were you aware that has — as of today, are you aware that at some inkaimon time she had a sexual relationship with A. No. Q. Are you aware Matter...extra' relatiomist not only with , but as well MR. CRITTON: Did I say..? Did I say — MR. EDWARDS: Well, you just asked the same question twice. BY MR. CRITTON: Q. Right. Are aware that .111e. lexual SI ! did..., with both and A. 1 }mew that-, had dated before did. Q. Okay. Were you aware that she had a — had sexual activity, both with — or with A. No. Q. Did she tell you that? A. Yes. SIsisold she had had sexual relationship with A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, 11 (Pages 167 to 170) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4f1S158d•Sc22-4c50-b036-e42361/1c2fb5 EFTA00750750 1 2 . 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 Page 171 Q. Did she tell — did she, la as well tell you she had a sexual relationship or had sexual activity with Mara A. No. Q. Did you ever tell 1M whether you had sexual activity with a A. No. Q. Did you ever tell whether you had a sexual relationship with A. No. Q. Now back to how you I Mr. Epstein. I think ou said theatlial. who was the father of IM's son? A. Yes. Q. And his name is Mt A. as son? Q. Yes. A. No. Q. What's his name? A. C.M. Ili I'm sorry. 22 COURT REPORTER: Spell? 23 BY MR. CRITTON: 24 25 Q. Sl A. ed? Page 173 1 atiSo if al has testified under oath that 2 dn't care and just said, bring home the bacon, 3 that would be a surprise to you? 4 MR EDWARDS: Object to the form. 5 THE WITNESS: 't really care whether 6 wanted her to go or not. That's none of my 7 business. 8 BY MR. CRITTON: 9 Q. And that was not my question. So I'm going 10 to ask Pamela to read it back to you, and if you could 11 answer my question, please. 12 (Whereupon, the requested portion of the 13 record was read aloud by the Court Reporter.) 14 BY MR. CRITTON: 15 Q.Latae rephrase it, then. 16 If 1M has testi under oath that 17 said, being aware that I= was getting moat this 18 old guy in Pikgpeach, that his response -- 19 response to SE was, I don't care, just bring home the 20 bacon, that — 21 A. Well, I'm sure -- 22 Q. Let me finish the question. 23 — that would be a surprise to you, based 24 least what you —your impression is from 25 is that correct? Page 172 1 COURT REPORTER: And OM 2 THE WITNESS: I w his last name — 3 MR. CRITTON: I believe. 4 That's how I've seen it answered in 5 interrogatories. 6 BY MR. CRITTON: 7 Q. What did you hear from or what did - 8 what was saying about Mr. Epstein? 9 A. That was seeing some old guy, who was 10 paying her et= 11 Q. And ME, did he think that was a good idea 12 because she was getting money? 13 MR. EDWARDS: Object to the font 14 BY MR. CRITTON: 15 Q. 11/hat did he say? 16 A. I think was probably upset %batk 17 Q. And what makskyou believe that OM may 18 have been upset about going — or seeing some old 19 guy, as you — as he described it to you, who was paying 20 her money? What did he say? 21 A. Idol* remember exactly what he said. I'm 22 sure that he wasn't happy about it, though. 23 Q. What — what makes you believe that? 24 A. Because they were living together, and they 25 were, I guess, in a relationship. Page 174 1 MR. EDWARDS: Object to the form. 2 THE WITNESS: I don't know. 3 BY MR. CRITTON: 4 Q. All right. You might not be surprised one 5 way or the other; true? 6 MR. EDWARDS: Object to the form. 7 THE WITNESS: Yeah, that's true. 8 BY MR. 9 Q. Was working at that time? 10 A. I don't know. 11 Q. How old was at the time the 12 was — he was having a relationship with MI ? And I 13 guess you both -- if I understood, she probably was in 14 the ninth grade, because you were doing the second year 15 of eighth grade; correct? 16 A. I diggliwww. 17 Q. Is older, younger? 18 A. I don't know how old — 19 Q. Were they — 20 A. —he is. 21 Q. Were they living together? 22 A. Yes. 23 Q. Where were they living together? 24 A. I don't know. Ina trailer. 25 Q. And how long had they been living together? (561) 832-7500 12 (Pages 171 to 174) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501.333-772-1552) 0151884(0.22465041036442X418c:db5 EFTA00750751 Page 175 1 A. I don't know. 2 Had you gone over and stayed -- or gone 3 to MM. and I= trailer and stayed — stayed there, 4 partied with them? 5 A. No. 6 Q. Hung out? 7 A. I had gone there before, yes. 8 Q. Okay. When was there? 9 A. Yes. 10 Q. How many months before that you — before 11 that you first went to Epstein's? Had they been living 12 together a number of months? 13 A. I don't know. 14 Q. Okay. How long before had you been to 15 their — before said something to you about IS 16 going over to — that some old guy was paying her? Was 17 that at least a month or two? 18 A. I don't know. 19 Q. Okay. Did they continue to live together for 20 a number of months? 21 A I don't know how long they lived together. 22 Q. How many times did you ever go to their 23 tails's.? 24 A. Two. 25 Q. And did... ever go with you? 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 Page 177 THE WITNESS: I didn't look into it. BY MR. CRITTON: Q. I'm sorry? A. I didn't look into it. Q. Well, wby did even mention it to you? MR. EDWARDS: Object to the form. THE WITNESS: I don't know. BY MR. CRITTON: Q. Did he tell you how much money she was getting? A. No. Q. Did he tell you what she was doing with hirn — A. Q. A. was? A. No. Q. Did he tell you where the guy was — A No. Q. — or where he lived? A. No. Q. He just said, is getting money from some older guy? No. — for the money? No. Okay. Did she — did he tell you who the guy Page 176 1 A. No. 2 Q. When you went to their trailer on those two 3 occasions, would it be a correct statement that you had both alcohol and smoked pot? 5 A. No. 6 Q. Okay. On either occasion did you smoke pot 7 when you were with and M.? 8 A. Probably on one. 9 _10. OksAnd did you ever have alcohol with 10 and =, as well? 11 A. No. 12 Q. Okay. So tells you.. was getting 13 money from some older guy. Did she — 14 MR. EDWARDS: Object to the form. 15 BY MR. CRITTON: 16 g Is that correct? Before — before.. ever 17 referenced anything to you or said anything to you? 18 A. Yes. 19 Q. Okay. And when he said — when told 20 you that, was anybody else present? 21 A. I don't know. 22 Q. What was your reaction-- well, let me ask 23 you this: What did — did you say, well, what do 24 you mean she's getting money from an older guy? 25 MR. EDWARDS: Object to the form Page 178 1 A. Yes. 2 Q. Okay. And what did you interpret that in 3 your own mind to mean? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't know. 6 BY MR. CRITTON: 7 Q. Okay. Did you - did you wonder why.. was 8 being paid money by some person just to go to his house? 9 MR. EDWARDS: Object to the form. 10 THE WTINESS: Sure I wondered, but I didn't 11 at 12 BY MR. CRITTON: 13 Q. Had - to your knowledge, hadll. ever 14 received money from men for doing things, whatever those 15 things might be? 16 MR. EDWARDS: Object to the form. 17 THE WITNESS: I don't know. 18 BY MR. CRITTON: 19 Q. Okay. She may have; she may not. You just 20 don't know, at least at that point in time; right? 21 MR. EDWARDS: Object to the form. 22 THE WITNESS: I don't know. 23 BY MR. CRITTON: 24 Q. That's what I'm Listen to my 25 question. As of the time that raised the issue (561) 8 3 2 -7 5 0 0 13 (Pages 175 to 178) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501433-772-1652) Electronically signed by Pamela Sullivan (501-333-T/2-1552) 4f15158d-6c22.4c50-b036-e423618c2fb5 EFTA00750752 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 Page 179 with you, before you went to Mr. Epstein's the first time, that was getting some money from some old guy, do you do you have any knowledge whether she had ever received money from a young person or an old person for doing anything? A. No. Q. Was anybody else present when MI said that to you? A. I don't know. Q. Well, when's the next time — how much — how much time passed before again the issue of fl getting money for — from some older man — MR. EDWARDS: Object to the fbnn. BY MR. CRITTON: Q. — came up again? A. 1 don't know if it did. O. Oka . Did you tell the FRI that had mentioned that was getting money from an older guy? A. Na Q. Okay. You're tell —just telling us that now? MR. EDWARDS: Object to the form. THE MINIMS: Yes. 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. A. Q. A. Q. A. Q• A. Q. A. Q. Okay. You said there were two lawyers, but whatever the card said was who they were? MR. EDWARDS: Object to the form. THE WITNESS: Yes. BY MR. CRITTON: Q. How much time did they spend with you? A. I don't know. Q. More than five minutes? A. I don't 'mow. Q. More than an hour? A. I don't know. Q. Okay. So you can't you said two individuals who — who were there on behalf of Mr. Epstein met with you, talked with you. You don't know — you can't tell me the date or even the year, Page 181 Do you remember when that was? No. Did they give you cards? Yes. Do you still have those cards? No. What did you do with those cards? I don't know. Did you ever turn them over to Mr. Edwards? I don't think so. Page 180 1 BY MR. CRITTON: 2 Q. By the way, have you ever given any 3 statements to anyone else? Anybody else ask you about 4 Epstein at any lime? 5 MR. EDWARDS: Objection. Don't answer. 6 Attorney-client privilege. 7 BY MR. CRITTON: 8 Q. Well, except and I when I ask questions 9 Illce that — and Brad will still make his objections, 10 which will remind me — I'm not interested whether 11 some — Mr. Edwards or someone from his office asked 12 you. You know, I'm — Fm confident that he interviewed 13 you or someone from his office interviewed you. So 14 separate that. 15 Have you ever given any other statements, 16 either in writing, orally, by tape, by stenographer, to 17 any other person, other than the FBI, and talked about 18 Epstein? 19 A. Yes. 20 Q. lowborn? 21 A. I spoke to two lawyers who came to my house, 22 which apparently represented Jeffrey Epstein at the 23 time. 24 Q. On just one occasion? 25 A. Yes. 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 182 1 comet? 2 A. Yes. 3 Q. Okay. That's -- and you can't tell me how 4 long you spoke with then; whether it was five minutes or 5 three hours; correct? 6 A. It wasn't very long. 7 Q. Five to ten minutes? 8 A. Maybe. 9 Q. Did they take any notes? A. I don't know. Q. Did they record a statement from you at all? A. No. Q. Did you tell them the truth? A. I don't know. Q. Okay. Are you in the habit of lying to people? MR. EDWARDS: Object to the fonn. THE WITNESS: Na BY MR. CRITTON: Q. You have lied before, though, in a court proceeding; have you not? A. Yes, I have. Q. All right. And, in fact, in your father's proceedings that involved the charges that were brought against your father for killing is you gave a (561) 832-7500 14 (Pages 179 to 182) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501.333-772-1552) 41161584602-4e50-b03644236180fb5 EFTA00750753 Page 183 1 number of conflicting statements — 2 A. Yes. 3 Q. — not only in deposition, but as well in 4 court; true? 5 A. Yes. 6 Q. Okay. And you admitted that in those court 7 proceedings you lied on a number of those statements; 8 true? 9 MR. EDWARDS: Object