IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502008CA037319XXXXMB AB Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF VOLUME I Tuesday, November 10, 2009 11:13 a.m. - 6:12 p.m. 250 S. Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR PROSE COURT REPORTING AGENCY Notary Public, State of Florida West Palm Beach Office (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-901Po7174075 3501.182-102 Page 1 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094347 EFTA01248007 Page 2 1 2 3 U U • • • APPEARANCES: On behalf of the Plaintiff III.: On behalf of Plaintiffs On behalf of Plaintiff 18 On behalf of the Defendant: 19 ROBERT CRITTON, ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN 20 515 North Flagler Drive Suite 400 21 West Palm Beach, Florida 33401 Phone: 561.842.2820 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 2 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094348 EFTA01248008 Page 3 1 On behalf of the Witness: 6 7 ALSO PRESENT: 8 9 MICHAEL DOWNEY, VIDEOGRAPHER 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-75C0 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-90flb7174075 3501.182-102 Pagc 3 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094349 EFTA01248009 1 2 3 4 EXHIBITS Page 4 NUMBER DESCRIPTION PAGE 5 6 Plaintiff: 7 Exhibit number 1 Notebook page 14 8 Exhibit number 2 Photograph 134 9 Exhibit number 3 Photograph 137 10 Exhibit number 4 Photograph 138 11 Exhibit number 5 Photograph 247 12 13 Defendant: 14 Exhibit number 1 Transcript 140 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f1134663-4dad-94e740ftb7174075 3501.182-102 Pagc 4 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094350 EFTA01248010 Page 5 1 2 3 4 PROCEEDINGS Deposition taken before Sandra W. Townsend, Court Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 - - - 7 VIDEOGRAPHER: We're on the video record. 8 This is the 10th day of November, the year 2009. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 The time is approximately 11:13 a.m. This is the videotaped deposition of in the matter of III., Plaintiff, versus Epstein, Defendant. This deposition is being held at 250 South Australian Avenue, West Palm Beach, Florida. My name is Michael Downey. I'm the videographer, employed by Visual Evidence. Would the attorneys please announce their appearances for the record. MR. Plaintiff III. MR. Plaintiffs MR. • Yes. , on behalf of on behalf of on behalf of MR. CRITTON: Robert Critton, on behalf of (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 5 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094351 EFTA01248011 Page 6 1 Jeffrey Epstein. 2 MS. and 3 here on behalf of witness, 4 THEREUPON, 6 having been first duly sworn or affirmed, was examined 7 and testified as follows: 8 THE WITNESS: So help me God. 9 MR. CRITTON: Let me just note one thing for 10 the record, is -- it's been -- this case for this 11 depo has been noticed both in the State Court case. 12 It's been noticed as well -- cross noticed by at 13 least on behalf of his clients two 14 through eight in the Federal Court case. The only 15 two lawyers who apparently are not here, but they 16 obviously have notice of it. And Mr. didn't 17 notice it, but obviously he's -- cross notice, but 18 he's here -- Mr. on behalf of his three 19 clients, and apparently Mr. Garcia chose, they 20 chose not to come for whatever reason, but they 21 would have received notice from everybody. 22 DIRECT EXAMINATION 23 BY MR. 24 Q. Good morning. 25 A. Morning. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-56634dad-94e7-90ftb7174075 3501.182-102 Page 6 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094352 EFTA01248012 Page 7 Q. Just want to make sure he was done. 2 I introduced myself in the beginning, but my 3 name is . I represent one of the 4 Plaintiffs in a lawsuit filed against Mr. Epstein. And 5 I'm here today to ask you a bunch of questions. 6 As you saw at the beginning, you're under 7 oath. It's just like you're on the stand at trial, 8 except there's no Judge here in the room with us. So 9 when I ask you questions, just give it a breath for a 10 minute because there may be objections for other lawyers 11 in the room. 12 Since there's not a Judge here, nobody's going 13 to rule on those objections, so the lawyer has to put 14 that objection on the record. Just pause for a minute 15 and then if you understand the question, go ahead and 16 answer. 17 The only exception to that rule is, if your 18 two lawyers look at you and say, don't answer that 19 question. At that point I don't want you to say a word. 20 And then they lodge an objection and advise you not to 21 say anything. Okay? 22 A. Okay. 23 Q. If you do answer a question, there's two 24 things I'm going to assume. I'm going to assume that 25 you understood the question being asked and that you're (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663.4dad-94e7-90flb7174075 3501.182-102 Page 7 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094353 EFTA01248013 Page 8 1 2 3 4 answering truthfully. Fair enough? A. Yes. Q. If you don't understand any of my questions, please let me know and I'll be happy to rephrase it 5 until you can understand it. 6 It's a nerve-racking procedure and I know 7 you're nervous. It's delving into very touchy areas, so 8 it's going to be delicate. I'm going to try and handle 9 it as respectfully and delicately as possible, but I am 10 going to have to ask a whole bunch of difficult 11 questions. Okay? Fair enough? 12 A. Understand. 13 Q. Okay. If you would, could you give us your 14 full name, please? 15 A. 16 Q. Where do you currently live? 17 A. • • (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 8 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094354 EFTA01248014 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electron Gaily signed by Sandra Townsend (401.377-676.2895) Elecironicaily signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 9 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094355 EFTA01248015 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 10 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094356 EFTA01248016 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 11 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094357 EFTA01248017 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 12 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094358 EFTA01248018 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 13 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094359 EFTA01248019 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 14 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094360 EFTA01248020 (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 15 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094361 EFTA01248021 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-Ne7-90ftb7174075 3501.182-102 Page 16 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094362 EFTA01248022 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 17 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094363 EFTA01248023 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1,88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 18 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094364 EFTA01248024 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 19 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094365 EFTA01248025 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90ftb7174075 3501.182-102 Page 20 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094366 EFTA01248026 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 21 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094367 EFTA01248027 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 22 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094368 EFTA01248028 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 23 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094369 EFTA01248029 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1038f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 24 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094370 EFTA01248030 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 25 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094371 EFTA01248031 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 26 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrAJON4372 EFTA01248032 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 27 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094373 EFTA01248033 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1,88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 28 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094374 EFTA01248034 ■ ■ 12 BY MR. 13 Q. When is the first time that you ever had any 14 contact with Jeffrey Epstein? 15 A. When? 16 Q. Yes. In other words, what grade were you in 17 or how old were you? However you can peg the time in 18 your mind. 19 A. About 16. 20 Q. So would you have been in about tenth grade at 21 that point? 22 A. Tenth going into my junior year, like, towards 23 the end, beginning of 11th. 24 Q. And how was it that you came to know who 25 Jeffrey Epstein was? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 29 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_ONN4375 EFTA01248035 Page 1 A. I was approached by a: 3 Q. At that point had you just turned 17? 4 A. No. 5 Q. You were still 16 at that point? 6 A. Yes. 7 Q. And III, is ill.? 8 A. I don't know. 9 Q. 10 all? 11 12 not friends. Okay. How did you know A. We went to middle school together, but we were 15 Q. Do you know where she is today? 16 A. No. 17 Q. What were you doing at 19 A. I don't know. 20 Q. Well, is it a members only type of place? 21 A. No. 22 Q. Do you just -- 23 MR. : Wait until he finishes his 24 question. 25 BY MR. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 30 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094376 EFTA01248036 Page 2 S 6 7 8 9 10 Q. Q. How do you get in there? A. You walk in. Q. Is there a charge to get into A. Not the day I met no. Q. Had you been there before? A. Yes. Q. How many times had you been there before? A. I can't recall. Was it a place that you went to regularly at 11 that point in your life? 12 A. Yes. 13 Q. Why would you go there? 14 15 Q. Okay. Can you describe to me? I 17 we talking about 18 somewhere? Are we 19 place? 20 A. 21 or was at that point on the beach 22 23 24 They had on Sundays live music. 25 A. To go swimming, listen to music. mean, are we talking about a club? Are a -- somewhere just on the beach talking about a bar? What is this is a tiki bar on the beach had a bar. It had a restaurant. It had a pool. It was a hotel room. I mean, they had hotel rooms available. Q. Okay. When you would go there in the past, (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 31 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094377 EFTA01248037 Page 1 would you go with friends? 2 A. Yes. 3 Q. Who? 4 A. 5 Q. Anyone else you can think of? 6 A. Not that I can think of. 7 Q. Would you go with or would you go with 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Not . I did go with and at. one point. Q. Okay. When you would go to the beach resort -- and I'm talking about the day before III approaches you now. A. Uh-huh. Q. In the past when you would go there, is it a place you would go just yourself and with friends of would your parents take you there? A. friends. Q. day that you talked to A. Yes. Q. So they were been there before? A. Uh-huh, yes. Usually a place that I would go with my Had your parents ever been there before that familiar of the location and had (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) V8W113-56634dad4404WW17.WM 3501.182-102 Page 32 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O54378 EFTA01248038 Page 33 1 Q. And they would also let you go to this place 2 alone? 3 A. With friends. 4 Q. How would you get there? 5 A. Drive. 6 Q. You? 7 A. Yes. 8 Q. So you would have -- you had a driver's 9 license at 16? 10 A. Yes. 11 Q. Just going back to what we had asked at the 12 beginning. 13 Did you have your own car? 14 A. Yes. 15 Q. What kind of car were you driving back then? 16 Was it the same pickup truck that you had later? 17 A. I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 33 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094379 EFTA01248039 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 34 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094380 EFTA01248040 ml ■ ■ ■ ■ 15 16 before the day that 17 18 time for right now. 19 20 21 22 23 24 with friends? 25 A. Yes. Q. Okay. Once again, this is the period of time approaches you about Jeffrey Epstein. I just want to focus on that period of When you would go to this what was the main purpose of you going there; in other words, why were you going? A. To have fun. Q. Go hang out on the beach, get a tan, hang out. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f1134663-4dad-94e7-90ftb7174075 3501.182-102 Page 35 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094381 EFTA01248041 Page • 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (2 • Would you ever drink there at the MS. : Objection. I've already instructed her not to answer this question. You're just using this example as a back doorway into the same question. We're still prior to her meeting If you have a specific question with regard to that day, please go ahead; otherwise, it's the same objection. MR. : Okay. BY MR. Q. When you would go to the don't answer this because she's going to object -- while you were there prior to that day that approached you with Jeffrey Epstein, had anyone ever provided you with any drugs? MS. : Same objections. MR. CRITTON: Form. MS. : Do not answer. BY MR. Q. Same thing, don't answer this until she objects, if she's going to object, which she will. Had prior to that day ever provided you with any drugs? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 36 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00054382 EFTA01248042 Page 1 MS. : Same objections. 2 Do not answer. 3 BY MR. 4 Q. And by "drugs," I meant, obviously, illegal 5 drugs or drugs that were not prescribed to you by a 6 doctor. Okay? 7 MR. : Same objection? 8 MS. : Same objection. 9 Do not answer. 10 BY MR. 11 Q. All right. When you would go to the 12 prior to that day that we're going to get. 13 to in a minute, how old were the people that you were 14 going with? 15 A. My age. 16 Q. All right. Anyone that would go with you that 17 was older than you, boys or girls? 18 A. Yes. 19 Q. Who? 23 Q. Any boys that would go? 24 A. I don't remember. 25 Q. Any boys that would meet you there? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 37 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094383 EFTA01248043 Page 38 1 A. Don't remember. 2 Q. The times that you went to the 3 4 can you remember any boys that happened to show up there or meet you there or hang out with you while 5 you were there? 6 A. I don't remember. 7 Q. Were there any boys that you socialized with 8 at that point in your life? Just friends? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. At that point in my life, yes. Q. Who? A. Q • Hang on one second. A. , I think. Q. A. Q. A. Q. A. And the other name? I'm sorry. Can you spell that last name? Anyone else? Not that I can remember. Q. Were and about your age? A. No. Q. How old were they? A. This is going back when I was 16? Q. Yep. We're still at that same point in your is that (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 38 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094384 EFTA01248044 1 life right before the day Page 39 approaches you 2 about Jeffrey Epstein. 3 A. They had already graduated high school, so at 4 least 18. 5 Q. How did you know and 6 A. lived the street up from me on the corner 7 house. 8 Q. Okay. 9 • • • • • • • • • • • 21 BY MR. 22 Q. All right. When you would go to the 23 , were there ever any other boys that would 24 show up there and hang out with you guys, other than, 25 say, or (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 39 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O54385 EFTA01248045 Page 1 A. I don't remember. 2 Q. Any boys that you can remember that would come 3 there your age; in other words, from school that you 4 knew? S A. I can't recall. 6 Q. All right. You had mentioned that 7 you knew, but she wasn't a close friend at that 8 point, correct? 9 A. Yes. 10 Q. How did you know her, just from school? 11 A. Just from 12 Q. All right. Had you had her in classes before? 13 Was she in social activities and you just knew her? How 14 is it that you knew her? 15 A. I can't remember. 16 Q. Okay. I want you to describe for me and go 17 back to that day in which she approached you, as best 18 you can, exactly how that incident happened. 19 A. I was at the with a couple friends. 20 was walking around and me and her were standing and we 21 were talking. And she had asked me if I wanted to make 22 any money, what my situation was. We exchanged 23 information and we went on our separate ways. 24 Q. Okay. Let me ask you just a couple questions 25 about that. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 40 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094386 EFTA01248046 Page 41 You said she asked you what your situation 2 was. What did you take that to mean? 3 A. Was I living at home? What was I doing? 4 Q. Why was she asking you that, if you know? 5 A. I don't know. 6 Q. Did you tell her? 7 A. I can't recall. 8 Q. Do you know what she -- did you know what she 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 meant when she asked you whether you wanted to make some money? In other words, did she explain what she meant to you? A. Yes. Q. What did she say? A. She said she had a friend who was a billionaire in Palm Beach and if I gave massages, he would pay me. Q. All right. So she, in fact, did explain to you that this person wanted a massage? A. That's correct. Q. Did explain to you whether or not you would have to get undressed for the massage? A. She never -- she never said that. Q. Did express to you or explain to you in any way that the person or billionaire that you'd be massaging would be in any state of undress; in other (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 41 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00054387 EFTA01248047 Page 42 1 words, in his underwear? Naked? Was that discussed? 2 A. No. 3 Q. What did you respond when she explained this 4 to you? What did you say to her? 5 A. I can't recall. 6 Q. Did you say anything to incline or to make her 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 21 U think that you would be interested in any way? A. I exchanged information with her. Q. When you say you exchanged information, was it your phone number? A. Yes. Q. Did you give her anything other than your phone number? A. I don't remember. Q. Was that your cell phone that you gave her? A. Yes. Q. Not your home phone, correct? A. Q. correct, was A. That's correct. And your cell phone at the time, if I'm I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 42 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094388 EFTA01248048 Page • 2 Q. That number that I just said to you though, 3 , doesn't sound familiar to you? 4 A. It sounds familiar. 5 Q. Okay. With respect to the phone number that 6 you gave her, did you tell her to call you at any 7 particular time or make any arrangements for a phone 8 call or appointment at that point? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I can't remember. Q. When is the first time that you talked to he again about this issue; in other words, the billionaire friend that she had on Palm Beach? A. I don't remember. Q. How soon after that first meeting did you talk to again? A. I don't remember. Q. Was it years later? Months later? Days later? Weeks later? A. Days later. Q. Does she call you or do you call her? A. I don't remember. Q. What type of conversation -- tell me generally what you all spoke about when you spoke again on the phone. A. I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90ftb7174075 3501.182-102 Page 43 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00054389 EFTA01248049 Page 44 Q. Did you make an appointment to go meet or go 2 over to Mr. home? 3 A. Yes. 4 Q. And what was your understanding of what you 5 were going to be doing when you went there? 6 A. Can you repeat the question? 7 Q. Sure. When you have that phone 8 conversation -- this is after the in-person meeting you 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have with -- let me ask it this way: Did she give you any more information in the phone call about what the job was going to entail? A. I can't remember. Q. Did she tell you at that point whether you were going to have to get undressed at all? A. I don't remember. Q. Did she tell you at that conversation on the phone whether or not the billionaire Palm Beach gentleman would be undressed? A. I don't remember. Q. Did she give you his name in the phone call or in the in-person first meeting? A. Yes. Q. When did she tell you his name? A. I don't remember. Q. Was it either in the face-to-face you had at (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) if88f173.5663.4dad-94e7-90f1b7174075 3501.182-102 Page 44 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094390 EFTA01248050 Page the or the phone call? 2 A. Yes. 3 Q. And what name did she give you? 4 A. Jeffrey. 5 Q. Did she tell you his last name? 6 A. At that point, no. 7 Q. All right. So now you have this phone call. 8 Do you arrange a time to go over there for this massage. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I can't remember. Q. When is the first time that you went to Mr. Epstein's home for a massage? A. First time was when I was a junior in high school. Q. How long a period of time after that first_ meeting you had with was it that you first - went over there? Are we talking weeks? Days? Months? A. Wait. Can you repeat that? Q. Sure. I'm trying to figure out -- you have the face-to-face with . That's the first time she mentions this whole thing with Jeffrey Epstein? A. Uh-huh. Q. Yes? A. Yes. Q. Then you have a phone call to follow up because you had given her the information, correct? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (4013774764895) Electronically signed by Sandra Townsend (4013774764895) 1188f113-5663-4dad-S4e7-90ftb7174075 3501.182-102 Page 45 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094391 EFTA01248051 Page .; A. (Nods head.) 2 Q. Yes? 3 A. Yes. 4 Q. Okay. And that was within days of the first 5 meeting? 6 A. Yes. 7 Q. Okay. I assume at that phone call and 8 correct me if I'm wrong -- that during the phone call 9 there was some arrangement made for you to go over 10 there? 11 A. Yes. 12 Q. Okay. I'm trying to figure out how soon after 13 the phone call it was that you were to go over there. 14 Days? Weeks? Months? 15 A. Days. 16 Q. Okay. So within days of the in-face meeting 17 you have a phone call and you were supposed to go over 18 to the house days after, some amount of days after the 19 phone call, yes? 20 A. Yes. 21 Q. Got you. Was anyone going to go with you that 22 first time? 23 A. 24 Q. 25 Yes. Who? A. Me, or and Tony (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 46 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094392 EFTA01248052 Page 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Figueroa. Q. Who is Tony Figueroa? A. Tony Figueroa is 's friend. MS. , as soon as you're at a good stopping point, -- MR. : Sure. MS. : -- just get a quick restroom break? MR. : Absolutely. Right now. MS. : You good? MR. : Yep. VIDEOGRAPHER: Go off the record. The time is five minutes to 12:00 p.m. (Brief recess.) VIDEOGRAPHER: We're back on the video record. The time is 12:02 p.m. BY MR. Q. Okay. We left off the first time you were going over to Mr. Epstein's house and you mentioned that Tony Figueroa and were going to go with you? A. Yes. Q. Okay. How did you know Tony or did you know Tony before that day? A. I did not know him before that day. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 47 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094393 EFTA01248053 Page 48 Q. So the day you were going over to 2 Mr. Epstein's house was the first time you had ever met 3 him? 4 A. That's correct. 5 Q. How old was Tony, if you know? 6 A. I don't know. 7 Q. Was he older than you? 8 A. Yes. 9 Q. Did he appear to be in his late teens or 10 twenties or is he somebody that was much older, like in 11 their thirties or forties? 12 A. Late teens, early twenties. 13 Q. And you said that Tony was 14 friend? 15 A. Yes. 16 Q. Did you talk to Tony when you first met him 17 that day? 18 A. I can't remember. 19 Q. Did you have any conversations with him about 20 where you all were going or what you were going to be 21 doing that day? 22 A. Yes. 23 Q. Tell me about those. 24 A. When we were all together, we did talk about 25 where we were going and what we were doing. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electron tally signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 48 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094394 EFTA01248054 Page Q. Uh-huh. 2 A. He didn't say anything out of the normal that. 3 hadn't discussed with me prior. 4 Q. Okay. So Tony mentioned that you were going 5 to Mr. Epstein's home? 6 A. That's correct. 7 Q. Or Jeffrey's home? 8 A. Jeffrey's. 9 Q. Did Tony mention to you at that point that you 10 were going to have to give a massage? 11 A. Yes. 12 Q. Did he mention anything about having to get 13 undressed? 14 A. No. 15 Q. Did Tony mention anything about whether or not 16 Jeffrey would be undressed or not? 17 A. No. 18 Q. I think I know the answer to this question. 19 Had you had any training in giving massages prior to 20 this day? 21 MR. CRITTON: Form. 22 THE WITNESS: No. 23 BY MR. 24 Q. No professional training? 25 A. No. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 49 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094395 EFTA01248055 Page 50 Q. Never gone to school for anything like that? 2 A. No. 3 Q. Even to this day? 4 A. No. 5 MR. : No, not to this day? 6 BY MR. 7 Q. Still have not had any training in massages Lo 8 this day? 9 A. No. 10 Q. All right. So who drives? Was it 11 Tony? 12 A. I drove. 13 Q. In the pickup? 14 A. I can't remember. 15 Q. Did you go and get them or did they come over 16 to your house and you left from your house? 17 A. I picked them up. 18 Q. Where did you tell your parents you were 19 going? 20 A. I don't remember. 21 Q. Was that first time during a weekend or during 22 a weekday? 23 A. I don't remember. 24 Q. Was it during the summertime when you were out 25 from school or was it during the school time? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 50 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094396 EFTA01248056 Page A. I don't remember. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Q. You're doing just fine. And I'm going to ask a lot of things you probably don't remember, so you just tell me and that's a perfectly good answer. Okay? What you do remember though is, it was Tony, and yourself, you were driving and this was the first time that you were going to go to Jeffrey's house? A. Yes. Q. All right. Were you nervous? A. I don't remember. Q. Did you have any expectations of what might take place when you went; in other words, did you think that there might be something more than what- - and Tony may have told you? MR. CRITTON: Form. 17 BY MR. 18 Q. 19 A. 20 Q. Sure. 21 22 23 24 25 You can answer. Can you repeat the question? And Tony told you that you were going to have to give a massage, correct? A. Yes. Q. To an older man that lived on Palm Beach? A. Yes. Q. All right. Did you think there might be a (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 51 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094397 EFTA01248057 Page 1 little more to it at that point than just a massage? 2 MR. CRITTON: Form. 3 THE WITNESS: I don't remember. 4 BY MR. 5 Q. How did you know how to get to the house where 6 you were going? 7 A. And Tony were with me. They gave 8 me directions. 9 Q. Okay. Describe for me, if you remember, how 10 you got there; in other words, did you go over the north 11 bridge? South bridge? 12 A. I don't recall what bridge. 13 Q. When you pulled up to the house for the first. 14 time, can you describe for me what you recall it looking 15 like? 16 A. There was a driveway, landscape. I want to 17 say it was a pink color, like, a pinkish color. It was 18 huge. A lot of cars in the driveway. 19 Q. Through road? Dead end? 20 A. It was a dead road, dead end. 21 Q. You said there were a lot of cars in the 22 driveway? 23 A. (Nods head.) 24 Q. What kind of cars, if you remember? 25 A. I can recall black. That's all. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 52 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094398 EFTA01248058 2 A. 3 Q. 4 front of 5 A. 6 Q. Page Q. Do you remember seeing an Escalade? I don't remember. Okay. That's fine. Anyone meet you at the the house? Security? Anything like that? No. Describe for me what happened when you 7 arrived, as best you can recall. 8 A. As best as I can recall, Tony, 9 and I walked to the side of the house, kind of around 10 the back, to a door where somebody had opened it for u 11 and it led into the kitchen. 12 Q. Okay. You said the door was already opened. 13 Does that mean that it was unlocked or that it was 14 physically open? 15 A. No. Somebody had opened the door, like, met 16 us at the door and opened it for us. 17 Q. Got you. That person that met you at the 18 door, woman or man? 19 A. I can't remember. 20 Q. Do you remember if it was the cook? 21 A. No, I do not. 22 Q. Did you all call ahead; in other words, did 23 somebody, either Tony or call ahead on the 24 way and say, hey, we're almost there or anything like 25 that? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 53 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094399 EFTA01248059 Page A. I don't remember. 2 Q. Okay. Tell me what happens next. So somebody 3 opens the door for you? 4 A. Somebody opens the door. From what I can 5 recall, we're all, you know, in the kitchen. 6 And then I had ended up upstairs. I'm not 7 sure how I ended up there. 8 Q. Okay. Was there a staircase leading upstairs 9 from the kitchen? 10 A. From the kitchen? No. 11 Q. How would you get upstairs after entering the 12 kitchen? What different ways are there to get upstairs, 13 if you know? 14 A. You would walk through the kitchen, kind of 15 straight into another room. I don't recall if it was a 16 living room or what. And then kind of make a right. 17 And then it would lead upstairs and it would go kind of 18 around. 19 Q. Uh-huh. All right. The staircase leading up 20 that you just described, the one closest to the kitchen, 21 narrow staircase? Wide staircase? 22 MR. CRITTON: Form. 23 BY MR. 24 Q. How would you describe it? 25 A. I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 54 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094400 EFTA01248060 Page Q. Was the staircase open on both sides? Was 2 there a wall on one side? A wall on both sides? A 3 railing on one side, a wall on the other? How would you 4 describe it? 5 A. It was, like, three steps and then there was a 6 staircase that went one way and the other one kind of 7 opened up to another direction. 8 Q. All right. Do you know where each side went? 9 Do you know where each side of the staircase went? 10 A. Not each side, no. 11 Q. Where did the right side go to? 12 A. I don't know. 13 Q. Do you know where the left side went to? 14 A. No. 15 Q. Somehow though you ended upstairs? 16 A. Yes. 17 Q. And was anyone up there with you? 18 A. 19 Q. Had you ever met her before? 20 A. Prior to that day, no. 21 Q. So this was the first time that you had met 22 23 A. Yes. 24 Q. And just so we're clear, we're talking about 25 , correct? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 55 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W401 EFTA01248061 Page 56 1 A. Yes. 2 Q. What did say to you when you first met? 3 A. I don't remember. 4 Q. What did you all talk about? 5 A. I don't remember. 6 Q. Did she talk to you about what you were about 7 to do? 8 MR. CRITTON: Form. 9 BY MR. 10 Q. In other words, did she discuss anything about 11 the massage to you? 12 MR. CRITTON: Form. 13 THE WITNESS: I can't remember. 14 BY MR. 15 Q. Did you have any conversation with her that 16 first day? 17 A. I don't remember. 18 Q. That's fine. 19 When you get upstairs, you see 20 Is anyone else with you? In other words, where is 21 ? Where is Tony? 22 A. Downstairs in the kitchen. 23 Q. So they didn't go up with you? 24 A. Not that I remember, no. 25 Q. Prior to this day had you known whether or not (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 56 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094402 EFTA01248062 2 3 4 5 6 7 had gone words, whether and done this type of thing in the past? A. No. Q. You didn't know? A. No. Q. Page through this before; in other had come over to this house Okay. When you get upstairs in this home, are 8 you nervous? 9 A. I can't remember. 10 Q. What did you do next? 11 A. After I was upstairs? 12 Q. Yes. 13 A. Fixed the massage table. 14 Q. How did you know how to do that? 15 A. I was shown. 16 Q. By? 17 A. 18 Q. Okay. 19 A. And I was shown where the towels were and the 20 oils. And then left. 21 Q. Where were the towels and oils kept? 22 A. Towels, I don't remember. Oils were kept in a 23 bottom drawer in the massage room area. 24 Q. Where is the massage room in relationship to 25 where you first were when you remember being upstairs? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7.50f1b7174075 3501.182-102 Page 57 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_000W1403 EFTA01248063 Page 58 A. I don't understand the question. 2 Q. Sure. The first thing you remembered when you 3 got to the house after going through the kitchen is 4 being upstairs? 5 A. Uh-huh. 6 Q. Okay? I'm wondering, as you're upstairs, 7 where is the massage room in relationship to that? 8 A. In a bedroom in a steam room. 9 Q. Okay. How big is this area, this massage room 10 area? 11 A. Maybe half this size. 12 Q. Okay. 13 A. Big. 14 Q. It's a big room? 15 A. It's a big room. 16 Q. Size of maybe an average bedroom? 17 MR. CRITTON: Form. 18 THE WITNESS: Yes. 19 BY MR. 20 Q. What's in that room? 21 A. A shower, a steam room, a closet of some sort, 22 sinks. 23 Q. Okay. Some kind of a dresser with drawers? 24 A. Maybe. I can't be sure. 25 Q. You mentioned the oils were in a bottom (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1 f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 58 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094404 EFTA01248064 Page 1 drawer? 2 A. Uh-huh. 3 Q. What type of -- 4 A. It was a tall -- it was tall with several 5 drawers against a wall. 6 Q. Okay. How close was that to the table, the 7 massage table? 8 A. Close. 9 Q. Okay. Did you have to actually set the 10 massage table up with or was it already set up 11 when you walked in? 12 A. She showed me how to set it up. 13 Q. So it was folded up and you all had to unfold 14 it and set it up? 15 A. Yes. 16 Q. When you set it up, was there a certain 17 procedure that showed you; in other words, how it 18 needed to be done? 19 A. Yes. 20 Q. Tell us about that. 21 A. You would have to pull out the massage table 22 from the closet that it was kept in. You would 23 straighten out the legs, just put it to where the 24 cushions are facing the roof. And two big towels, one 25 would go on one cushion and the other big towel would be (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 59 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094405 EFTA01248065 Page 60 1 unfolded on the other cushion, kind of like a 2 tablecloth. 3 Q. And after that she showed you where the oils 4 were? 5 A. Yes. 6 Q. What type of oils are we talking about? 7 A. I can't remember. 8 Q. Clear? Are they lotion, like, white -colored 9 oils? I mean, what did the bottles look like? Square? 10 Circular? Anything like that? Can you remember any of 11 the names on them? Anything at all that you can tell us 12 about them? 13 A. I can't recall. 14 Q. You can't recall anything about them, color or 15 nothing? 16 A. I can't recall anything about the lotions or 17 oils. 18 Q. But they were kept in a bottom drawer? 19 A. That's correct. 20 Q. Was there anything else that you saw in the 21 bottom drawer when she got out the oils for you that 22 first time? 23 A. Yes. 24 Q. What did you