UNITED STATES DISTRICT COURT

Pace UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 502008CAO2S05130000.03 AB a Plaintiff. -vs. JEFFREY EPSTEIN. Defendant VOLUME I OF II VIDEO-CONTERD4CED AND VIDEOTAPED MORMON OF I. Tbunnky, September 24,2009 9:40.5:52 p.m Repotted By: Cynthia Hopkins, RPR, FPR Notary Public. State of Florida Prose Coal Reporting 1 Appearances 2 On behalf of 3 ROBERT MARK T. 4 Page 3 rationed: the Defendant, Jeffrey Epstein: D. CRITTON, JR., ESQUIRE LUTHER ESQUIRE iLUTTIER & COLEMAN, LLP fg i i 6 one : 7 On behalf o 8 JACK A 9 10 one 11 12 13 14 15 16 3.7 18 19 WITNESS: 20 21 22 23 24 25 1, Jeffrey Epstein: ALAN GOLDBERGER, ESQUIRE URY GOLDBERGER & WEISS, PA. ALSO PRESENT: Jeffrey Epstein, via video conference Michael Downey, Videographer Visual Evidence, Incorporated IN DEX VOLUME I DIRECT CROSS REDIRECT RECROSS LIMIER 10 1 APPEARANCES: 2 On behalf of for Plainti 3 BRAD J. EDWARDSS,... RoSENFT_:LOr, AM I R 4 6 7 On Sbeli.z.241tAl: E' . KUVfN, ESQUIRE 9 10 Phone: 11 12 13 14 is 16 17 19 19 20 23. 22 23 24 25 ADAM RE On behalf o ROWITZ. P.A. Fek Page 2 1 2 3 4 5 6 7 a 9 10 11 12 :3 14 15 16 17 18 19 20 21. 22 23 24 25 P ROCEEDINGS Page 4 THE VIDEOGRAPHER: We're on the videotape record. This is the 24th day of MI., the year The time is approximately 9:46 a.m. This is the videotape deposition of ■ in the matter of fl Plaintiff versus Epstein, Defendant. This deposition is being held at. My name is Michael Downey. IM the videographer employed by Visual Evidence. Will the attorneys please announce their appearances for the record. MR. EDWARDS: Brad Edwards representing.. MR. HOROWITZ: Adam Horowitz, counsel for Plaintiffs MR. KUNIN: Spencer Kuvin on behalf of MR. GOLDBERGER: Jack Goldberger on behalf of Jeffrey Epstein. MR. CRITTON: Bob Critton on behalf of Jeffrey Epstein. MR. LUITIER: Mark Luther on behalf of Jeffrey Epstein. MR. EDWARDS: Before we get started, I know 1 (Pages 1 to 4) PROSE COURT REPORTING AGENCY, INC. EFTA02726436 Page 5 1 that we're going to use teal names during this 2 deposition rather than pseudonyms. I just want to 3 make sure that we're all on the same page that when 4 the court reporter types it up, it's going to be 5 typed up in the transcript as the initials like we 6 have in previous depositions. 7 MR. CRITTON: That, that's fine, but keep in 8 mind that we need, because a number of the 9 individuals have multiple first initials and you 10 have used initials that don't even match your 11 clients names. 12 So we're going to have to — Cindy, you're 13 going to need to, ultimately when you finish, if 14 this is agreeable with everyone, I think we did 15 this before is type up a key and then you can give 16 that only to the lawyers and do that as just a 17 privileged or as a confidential document, so that 18 we can insert those 19 MR. EDWARDS: Along those same lines, as this 20 is being videotaped, I imagine in agreement amongst 21 the parties this will remain confidential except in 22 the case that there is a court order that the 23 videotape and her image is made public in any way. 24 So, if it's going to be made public in any way, 25 then, !just ask that it only happen by way of some Page 7 1 anonymity here. And I am not going to agree to 2 that, so — 3 MR. CRITTON: Well, l can tell you I wouldn't 4 put a video on. I would not put a video that would 5 identify this individual, you're client's face. 6 All right. I would do nothing to identify her 7 face. So, her anonymity would be, quote, unquote, 8 preserved if that's your issue. 9 MIL EDWARDS: My issue is only preserving her 10 anonymity. So, I mean, are we in agreement that 13. this is not going to be a video published in a 12 public forum or any way outside of use in a 13 courtroom to be seen by the judge? 14 MR. CRITTON: To the extent her picture or her 15 name would be used, I agree with that. Other than 16 that, just go to the court. And as i said, you can 17 file a motion with the court. if your position is 18 is that the deposition, again assuming there is 19 complete anonymity and her face is blotted out, 20 that the video cannot be filed with the court or 21 used in some other fashion, right, I agree. We're 22 not going to do anything that in any way impacts 23 the anonymity absent an order from Judge Hafele in 24 this particular case. 25 MR. EDWARDS: All right. We're in agreement Page 6 1 court order, either by way of Marra or Judge 2 Hafele. 3 MR. CRITTON: This is only being done in the 4 ■case. And I will tell you what you can do 5 is we won't agree to that because Mr. )(Irvin 6 apparently gave Mr. Epstein's video to Jose 7 Lambiet, which was then immediately put on the 8 Post, and then ended up on, all over the country. 9 And be certainly had no issue associated with 10 confidentiality. So, whatever rules apply. 11 What I will tell you is with regard to the 12 video today, we'll give you whatever time you think 13 is necessary -- well, let's do it this way: Within 14 ten days fiom today you file a motion for 15 protective order in front of Hafele with regard to 16 this deposition, and we'll agree that it will 17 not — we won't touch it. 18 Mil. EDWARDS: I don't see how that's necessary 19 since we already have the Judge's agreed, we have 20 an agreed order that we can proceed anonymously. 21 Judge Hafele, as you know, has been very careful in 22 instructing yourself and everybody else in this 23 case that these individuals are to remain 24 anonymous. And obviously publishing this video in 25 any public forum will decrease or eliminate any Page 8 1 then. Okay. 2 MR- CRITTON: But, but I want to be clear, it 3 is to the extent that if the, you still need to 4 file a motion with the court to the extent that you 5 don't, that it's your position that even if her 6 face was blotted out and even if no names are used, 7 and you think that the video is to remain confidential, then you should file something with 9 the court. And I'll give you, like I said I will 10 give you ten days so you can proceed to file that 11 motion. 12 MR. EDWARDS: Okay. So it's your intention to 13 use Ibis video, blot her face out and then post it 14 somewhere? 15 MR. CRITTON: I have no intentions at all. 16 MR. EDWARDS: Okay. 17 MR. CRITTON: And if you had brought this up 18 in a motion earlier, I would have addressed it at 19 the same time. 20 MR. EDWARDS: I think we're all on the same 21 page that the victims in this case are to remain 22 anonymous. i mean, everybody has been warned 23 repeatedly about using names outside of the 24 pseudonyms and exposing faces, things like that, to 25 the public outside of the court. 2 (Pages 5 to 8) PROSE COURT REPORTING AGENCY, INC. EFTA02726437 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 9 MR. CRITTON: I am aware of the court order. 2 I am also aware that is a public 3 figure now because her lawyers chose to disclose 4 her name. MR. EDWARDS.: Right. And that was her choice. 6 MR. CRi'TON: Everything associated with the 7 her is public. 8 MR. EDWARDS: Right. MR CRITTON: Tm aware of the other court orders in, that are in place and I think, well, I think we have said enough. MR. EDWARDS: Okay. Agreed. MR. LUTTIER: Would you please state your name. THE COURT REPORTER: I need to swear the witness. MR. LUTTIER: Okay. Thereupon, having been first duly sworn or affirmed, was examined and testified as follows: DIRECT EXAMINATION BY MR. LUTTIER: Q. Would you please state your full name, ma'am. A. El. Page 11 1 I don't know. 2 Q. Okay. How many times have you been deposed? 3 A. Once that I know of. 1 4 Q. Am you referring to an incident where you gave a sworn statement to the FBI? Is that what you are 4 6 referring to? 7 A. Yes, sir. 8 Q. That's what you — when you said you were 9 deposed one time, that's the incident that you're 10 referring to? 11 A. Yes, sir. 12 Q. What is ur current address? 13 1 A. 4 15 Q. And is that an apartment? 16 A. Yes, sir. 17 Q. kit in a development? 18 A. Yes, sir. 19 Q. What development is it in? 20 A. 21 Q. And where is that located? 22 A. 23 Q. How Ion have u lived there? 24 A. 25 Q. And does anybody live with you at that address I Page 10 1 Q. What's your middle name? 2 Al 3 Q. (Mr. Luttier spelled her middle name.) 4 A. Yes. S Q. is there. at the end of it? 6 A. No. 7 Q. Okay. n., have you ever been deposed 8 before? 9 A. Yes. 10 Q. When was the last time you were deposed? 11 A. The date was — I don't know when the date 12 was, but it was the last time with Jeffrey Epstein. 13 Q. What do you mean by "with Jeffrey Epstein"? 14 A. i was deposed with Jeffrey Epstein on 15 behalf - I don't know, Jim Eisenberg, the guy who is 16 actually upstairs from here. I don't know the name. 17 Q. Who do what guy is upstairs? Who are you 18 talking about? 19 A. You know the last time I was deposed. 20 Q. I don't know of any, ma'am. I assure you I 21 don't know of any time you have been deposed, so that's 22 what I am trying to find out 23 A. You don't. 24 Q. No. 25 A. Okay. When was the last time i was deposed? Page 12 1 currently? 2 A. My son. 3 Q. And what is your son's name? 4 THE WITNESS: Do I have to say my son's name? 5 MR. EDWARDS: lam, lam going to instruct her 6 not to answer. This is a minor child and she's 7 going to her son out of this litigation. This 8 is a boy. 9 MR. LUTTIER: Is that some basis- 10 THE WITNESS: i don't know why it's relevant 11 to to have my son's name. I have a 12 son. 13 MR. EDWARDS: Yeah, the basis of the objection 14 is that your client is a convicted felon and a sex 15 offender. This is a victim and she is in fear for 16 the safety of her son. And because of that fear, 17 she's not going to provide an ore identifying 18 information about her son. 19 BY MR. LUTTIER: 20 Q. Do you adopt what your lawyer just said? 21 MR. EDWARDS: Don't answer. 22 THE WITNESS: I agree. 23 MR. EDWARDS: Don't answer. 24 BY MR LUTTIER: 25 Q. Do you have some fear for the safety of your fi 3 (Pages 9 to 12) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA02726438 Page 13 1 son? 2 A. Yes, sir. 3 Q. And what is your fear? 4 A. Are you kidding me? What is my fear? 5 Q. I can tell you, ma'am, there is nothing here 6 at all today that I am going to be asking you that's a 7 joke or that I am kidding you about. a A. Okay. 9 Q. Okay. So what is the fear that you have for 10 your son? 11 A. I don't lmow if you have kids — 12 Q. Yeah, I do, ma'am 13 A. All right. Well, then, if you were in this 14 deposition, Lam in fear that this, this criminal, 15 Jeffrey Epstein, could harm him in some way bier on in 16 life like he's harmed me and many other women or girls 17 as that. And I don't want this to be publicity later on 18 in life for him to see what his mother has been through. 19 That's why I am in fear for him. 20 Q. Okay. Can you tell me specifically what it is 21 that you fear, what specific -- 22 A. I just told you. 23 Q. — act that you fear is going to happen to 24 your son? 25 A. Psychological, mental physical matters for my 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 15 Q. All right. So, you have a Somewhere I think I read his name was or something like that. And have you and he lived just the two of you at this apartment since at A. Yes. Q. Has anyone else lived with the two of you at that apartment since A. Yes. Q. Who else has lived there? A. Q. How do you spell that last name? Q. And for what period of time has lived there? A. For seven months now. Q. Is he living there now? A. Yes. Q. And is there some relationship between and yourself? A. Yes. Q. What is that relationship? A. He is my current boyfriend. Q. And what is occupation? A. He is—he does Q. Does he week for someone or is he Page 14 1 son. 2 Q. Can I, can I assume that you would take 3 whatever steps you deem necessary to protect your son 4 any time you felt that he was in any kind of danger? 5 A. Yes, sir. 6 Q. And could I assume that historically, that is 7 throughout his life as long as he has been bom, you 8 have always done anything you could to protect him from 9 any situation where he was put in danger; is that right? 10 A. Yes, sir. 11 Q. And if somebody puts your son in danger, you 12 know how to file a lawsuit against them and protect them 13 and things like that, right? 14 A. Yes, sir, but I don't want to get to that 15 point. mat's why I am not going to disclose his name. 16 Q. Well, you have filed this lawsuit, right? 17 A. For mY, for my sake, yes. 18 Q. And you would file a lawsuit to protect your 19 son if that's what you had to do, would you not? 20 A. Yes, i would. 21 Q. Would it be a fair statement to say that your 22 son is the most important thing to you in your life? 23 A. Yes. 24 Q. Okay. 25 A. Yes, yes, 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 Page 16 self-employed? A. He works for Q. Has anyone else ever lived with you and your son since MINIM) A. No, sir. Q. Prior to, that is immediately before you moved into the where did you live? A. On Q. What was the address? A. Prom what I recall El Min Q. And whereabouts is that located in IMIE) A. On Q. What kind of structure was that? A. A townhouse. Q. And how long did you live there? A. I lived there for about seven months. I'm not really sure on that. Q Okay. Since approximately somewhere around A. I'm, I'm really not sure. Maybe — you know what, it was mollig. n. Q. Okay. And something, it sounds like something that you were able to refer to that triggered your NEMAIrIO Niada. 10.0W9MV •thik.••••• ••••HA 4 (Pages 13 to 16) PROSE COURT REPORTING AGENCY, INC. EFTA02726439 1 2 3 4 5 6 7 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 17 memory as to when that was? A Yes. Q. What was, what incident that triggered your mano ab ten that was? A. Q. ? A. Yes. Q. How do you know the -- was there something that trigg that you recalled about that day? A. Yes, because I t ved in before and I had to get th up. Q. Did anyone --I your son lived with you when you were ? A. Always. . ' one else live with you while you were a m A. No, sir. Q. Are you currently employed? A. No, sir. Q. What are your -- what is your current means of support? A. I have a loan from school. Q. And whilia A. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 19 A. I have to take the exam in order for me to get the certificate to be licensed. alliiMISONSbeing something separate that you have to go through? grilitor me to get licensed to be a , I have to take something called the , I think it's called. And after I pass the test, then I will receive my license. studies a Q. A. Q. started? A. Yes. Q. Had you ever attended that institution before? A. Yes. Q. When had you previously attended that institutaia Q. Do you recall when? A. No, sir. Q. Was it located at the same location when You — 1 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 Page 18 Q. An wh A. Q. And are you pursuing some course of study there? A. Yes. Q. Skis of study are you pursuing? A. Q. Is that an institution where you obtain a degree upon completion of your studies? A I can be Q. When you complete your studies there, what will you get to signify that you have completed that course of study? would be A. I wool to and I Q. So, would you get a certificate? A. Yes. Q. And that after you get your certificate, you're required to take some kind of exam? A. Yes. Q. Or do you have to take the exam to get the certificate? 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 20 A. Yes, sir. Q. — attended there previously? And for what purpose had you pre:5,1ot ...re a lic Q. was that? long you attended it is was A. Yes, sir. Q. And then upon completion of that course of rote then take a test and get a license as an A. Yes. Q. And about when did you get your lice A. I am pretty sure it was the beginning SiAnd that licensure was issued by the A. Yes. Q. Did you your license after you got it in the beginning of II? A. Yes. Q. How did yomili mi A. I worked at Q. What's the name of that? 5 (Pages 17 to 20) PROSE COURT REPORTING AGENCY, INC. EFTA02726440 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Mt. Q. How do u spell that? A. Q. A. Ycs. Q. And where is that located? A. That is located (Ms. Ezell entered the deposition.) BY MR. LIMITER: Q. Is that in like a strip mall center? A. Yes. Q. And what did A. I was Q. What • A. Fad Q And what did A. I perfonna . And and basicall A. No sir. do does that kind of thin Page 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 23 at a MR. EDWARDS: Object to the form. THE WITNESS: No. Fm not sure. MR. LUTTIER: Okay. arWITNESS: Maybe a couple months before I'm not sure. There is record on my have pay stubs. I don't know. BY Mit. Q. Okay. How did you get that job? A. I filled out a resume and I walked into the place and I asked for a job. Q. And do you have a copy of your resume? A Yes. Not with me. Q. Did you know anyone at that place of business? A. No. Q Was that the only place of business that you submitted your resume to? A. No, sir. Q. Who else didsubmi A. To a couple.. aroun Q. Did you interview for the job? e other jobs. I interviewed for attd they took mc in. Q. Do you recall who you interviewed with? A No, sir. Page 22 1 iiind for what period of time did you work at 2 3 A. That's when the economy kind of went down, so 4 I didn't work there for a long period of time because 5 they were allowing me so many hours. I want to say 6 three months. 7 Q. And that, would that be starting in the 8 beginning a, like ? 9 A. I don't want to say because I'm not positively 10 sure. 11 Q. So, let me ask you this: Is that your best 12 estimate? 13 THE WITNESS: Okay. Bless you. 14 MR. EDWARDS: Excuse me. Excuse me. 15 THE WITNESS: Sometime maybe after... 16 MR. LUTTIER: Of I? 17 THE WITNESS: But like I said, Fm not sure. 18 BY MR. LLTTTIER: 19 Q. That's after of 20 A. Yes, sir. I am not exactly sure. 21 Q. Okay. I understand it's your estimate and 22 your best estimate is you worked there for approximately 23 three months? 24 A. Yes, sir. 25 Q. Which would take you from to about.. Page 24 1 Q. Did you know anyone a before 2 you went to work there? 3 MR. EDWARDS: Object to the fonn. 4 THE WITNESS: I told you, no, sir. 5 BY MR. LUTITER: 6 Q. Did you know anyone else that had ever 7 worked- 8 A. No, sir. 9 Q. - there? And what were the terms of your 10 employment? 11 A. I worked, sometimes I would work four hours 12 from 9 to — sometimes I would work from well, 9 to 1 13 three days a week, and other I was pretty 14 much on call because they just had opened and 15 the economy was going down at that time, and she 16 couldn't really afford to have me there as much as I 17 wanted to be there. 18 Q. Who is the "she" you're referring to? 19 A. I don't remember her name. 20 Q. Was it the owner? 21 A. Yes. 22 Q. And you don't -- do you recall the name of who 23 your supervisor was or the person that you reported to? 24 A. No, sir. 25 Q. Do you recall the name of anyone at 6 (Pages 21 to 24) PROSE COURT REPORTING AGENCY, INC. EFTA02726441 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 25 ast was employed there or an owner there? A. No, sir. I didn't et close to anyone there. I just, I was the only Q. How many other employees were there? A. There was actually only three other employees. Q. Do you know the names of the other employees? A. No, sir. . What other services were rendered at Milli A. Q. Anything A. No, sir. HMI Q. And what were the terms of your employment in terms of what you got paid? A. 'think she started me off at -- here again am not sure. I think she started me off around ■ maybe. Q. Per hour? A. Yes. And then gradually I would work by commission but not many people came in. So, all in all it didn't really work out financially for myself and my family. Q. Did there come a time that she increased the hourly wage — Page 27 1 A. Yes, sir, but that never ended up, that never 2 went through. 3 Q. So there did come a time that the basis of 4 your, the terms of your employment in terns of how you 5 got paid changed? 6 A. I'm going to say no because she said that I 7 was going to make commission. No one came in. Okay. 8 So I didn't make any commission. 9 Q. So she continued to pay you hourly? 10 A. Yes, sir. 11 Q. Were you supposed to get commissions on top of 12 your hourly wages? 13 A. If I worked there longer, yes, but no. 14 Q. And you still don't know the name of this 15 person that you have referred to as "she"? 16 A. No, sir, l don't 'mow the name of anyone 17 there. 18 Q. Okay. Did you participate in any type of 19 promotion for the business? 20 A. No, sir. 21 Q. Any kind of advertisement or anything like 22 that? 23 A. No, sir. 24 Q. Was your name or likeness, picture or likeness 25 used in any ldnd of promotions? Page 26 1 A. No, sir. 2 Q. — that you were being paid? 3 A. No, sir. 4 Q. Did there — when you originally were hired, 5 were you hired on an hourly basis? 6 A. Yes, sir. 7 Q. Did there cons a time that the basis of your 8 employment or your pay changed? 9 A. No, sir. 10 Q. So, you were always paid hourly by the owner 11 of the establishment? 12 A. Yes. 13 Q. Did you receive any other compensation from 14 anyone else while you were working there? For example, 15 did people or clients of yours that you did work on give 16 you tips? 17 A. No, sir. 18 Q. You mentioned something in an earlier answer 19 about being on a corrmission basis. What did you mean by 20 that? 21 A. As time went on she said you can work off of 22 commission, but no one came in. I didn't make a 23 commission. 24 Q. Did you agree to change the terms of your 25 employment from hourly to commission basis? Page 28 1 A. No, sir. 2 Q. Were you given any information from the owner 3 of this .as to how to solicit clients? 4 A. No, sir. 5 . When u other th r a at the 6 starting in 7 ' had you attended that institution on any B prior occasion before that? 9 A. No sir. 10 Q. So the first lime you wart 11 there? 12 MR. EDWARDS: Object to the form? 13 BY MR. LUTTiER: 14 Q. Correct? Was t ' 15 you went to the 16 MR. EDWARDS: Object to the form. 17 THE WITNESS: What does this mean? 18 MR. EDWARDS: You can answer if you know the 19 answer. If you don't know the answer -- 20 THE WITNESS: Fr I went 21 there. I attended the two 22 times. 23 MR. LUTHER: Okay. 24 THE WITNESS: Okay. One in l and one right 25 now. 7 (Pages 25 to 28 PROSE COURT REPORTING AGENCY, INC. EFTA02726442 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 29 BY MR. LUTTIER: . How did ou become familiar with or know about the A. Maybe the Yellow Pages. Some source of information on the Internet. Q. Do you recall which it was? Was it the Yellow Pages or was it the Internet? A. Yellow pages dot corn, MEM. Q. That's how you found it? A. Yes, sir. Q. And are you a person that considers yourself to be computer proficient? A. No, sir. Q. iEnsu use the computer on a regular basis? A. I have been. Q. What do you mean by "Mr A I have been selling a couple of items Q. What kind of items? A. Items around the house like dresses, shoes, items that i have. • Are, are you selling items as a for A. LI in them in I never pursued it. So, as of right now I am taking the products that I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 31 Q. You don't know your friend's last name? A. No, I don't know my friend's last name. Q. And you don't know last name? A. No. Q. How long did you know this friend a A. I knew ha from the neighborhood I used to live in what I was ten years old. I met ha when I was ten years old and that I bumped into her at a store. We exchanged phone numbers. She introduced me to III an I started Q. And although you knew this person since you said you were Mold, you can't recall her last name; is that right? A. That's right. Q. Is there — by the way, do, do you have any problem with your memory that you're aware of/ A. Yes. Q. What is your problem with your memory? A. With a lot of negative situations, I tend to not really, I don't really care to ri..ux.iikgsi than. just live every day as it oomes as positive as I can. I try to exclude any negativity. And when it comes to negativity, I choose, I guess I choose not to remember it. Q. Is there a difference between attanpting to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 3.6 17 18 19 20 21 22 23 24 25 Page 30 do have and I am selling them. Q. Okay. When you say that you with in what do you mean? A. I paid worth of so I could profit. Q. Turn around and sell it for a profit? A. Yes, sir. Q. Did you execute some paperwork to become a for lack of a better term with IMMI A. Yes, sir. Q. Did you deal with someone that was affiliated with when you first began to do that? A. Yes, sir. Q. And who was that? A. Q. Did you say A. Q. A. Yes, sir. I don't know her last name. Q. And how did you get in touch with her? A. Through a friend. Q. And who was the friend? A. Q. what? A. I don't know. Page 32 1 block out some negative thing and not being able to 2 remember the negative thing? 3 A. Okay. 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: 1, I do choose to block out. I 6 remember but I do choose to block out. 7 BY MR. LUTHER: 8 Q. So, you would say you're a positive type 9 person? 10 A. Yes, sir. 13. Q. You believe in positive thinking as opposed to 12 negative thinking? 13 A. Yes, sir. 14 Q. You put behind you those things that you don't 15 think were positive for you and you choose to 16 concentrate on those things that are positive? 17 A. Choose to concentrate on positive things. 18 Q. Are you a person that you would say is a 19 forward-looking person; that is a person that looks to 20 the future as opposed to the past? 21 A. I look to the, I looked to the, I look to the 22 future, but the past does haunt me. 23 Q. Okay. Now, you mention that although you try 24 to block these things that you do remember them. So, I 25 want to go back and ask you if you remember last name of 8 (Pages 29 to 32) PROSE COURT REPORTING AGENCY, INC. EFTA02726443 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 33 A. No, sir. When I was ten, I really didn't care to know anybody's last name. Q. Well, you said you first met her when you were ten, right? A. Yeah. She was an acquaintance. Q. And so how long did you know her, from ten until now? A. No, l knew of her, but she was a girl in my neighborhood that we just saw once in a while. And then as we got older, I don't know where she was. But I bas d into her at a store. And Fm like, hey, aren't you from the neighborhood. Oh, you have a kid; cool, I have a kid too. Let me get your number. Let me see how you're doing in life. I don't know her last name. Q. Okay. But in any event, she's the one that introduced you to the concept of MR. EDWARDS: Object to the form. MR. LUTTIER: Right? THE WITNESS: Yes. BY MR. LUTTIER: Q. Was she a person who that was selling NM A. Yes. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 35 A. I don't know. Q. Was it your practice to keep important legal papers that you sign? MR. EDWARDS: Object to the form. THE WITNESS: Yes. That wasn't very important to me. BY MR. LUTHER: Q. What sort of important legal documents do you keep? Or excuse me, what sort of important document do you keep? A. Keep my tax returns. I keep my sonall. I keep all of my son's records. I keep my Social Security card. 1 keep money orders that when I pay the bills. Q. Anything else that you can think of? A. No, sir. milfter you had this happenstance meeting with iAdid you ever have any other communication with heir A. We had a co we had actually one together, and we had attended together one time. Q. Did you ever actually sell an product that you had purchased for A. Yes. °dings. Well, at my house 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 34 Q. Did she have some kind of franchievsitIttltem? A. lam pretty sure. She worked for She introduced me to -signed me up. Q. When you say signed you up, wit:1.1)cm? A. I filled out paperwork to hand ov . And did — was part of the arrangement that =would receive some sort of compensation or a portion of your sales? A. Not that I know of. Who knows? I don't know. It was just an opportunity that I went for and found out that it wasn't for me. Q. Did you read the document that you signed? A. I didn't read up to the point where it said that she was going to get profit. I didn't really care if she got a profit. If she did, good. Q. The question was, did you read the document that you signed? A. Pan of it. Q. And what part did you read? A. That I will be spending `so I can Q. Do you have a copy of the document? A. No, sir. Q. What happened to the document? Page 36 1 Q. And during what period of time did you 2 actually sell product? 3 A. When I first started, and I would just keep 4 the products in my trunk And if I was out on the 5 street at a gas station or going to the grocery store, 6 wherever a ls lisk a woman if they would like 7 some And if they did, l proceeded to 8 sell them to that woman. 9 Q. Did you have — was that your sole source of 10 support at the time? 11 A. No, sir. 12 Q. What other source of support did you have? 13 A. At what period of time? 14 Q. You what? 15 A. At what period of lime? 16 Q. aWarigiSf time while you v 17 Lag MIME= which mislaid yoiebill in 18 M. And do you recall when in IM approximately? 19 A. That was my, not my only source of ham no. 20 Approximately when did you initially MINI in 21 22 A. I couldn't tell you. 23 Q. Roughly. 24 MR. EDWARDS: Object to the form. 25 MR. LITTLER; lam not owing you to a specific team PROSE COURT REPORTING AGENCY, INC. 9 (Pages 33 to 36) EFTA02726444 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 Page 37 date. Within two months. MR. EDWARDS: Object to the form. If you know, answer; if you don't know, you don't know. MR. LUTTiER: You can't recall? THE WITNESS: i can't recall. BY MR. LUTTIER: Q. Okay. And for how long did you sell these products? A. Sr, I took the products. They weren't my full source of income. I sold them whenever I sold them. When i was at a gas station, maybe I would.. When I was at the grocery store, I might It wasn't my full source of income. It was just a little gas change. Q. Okay. And at some point you stopped attempting to sell the product and decided to try to sell them ovellIk A. Yes. Q. What, what other source of income did you have while you were trying to se A. i was workisja in and out o Q. In the yea — and you have testified earlier that, I think u said about is when you first went to, to this -- did you have any source of support, financial support? Page 39 1 reside with him? 2 A. Around five months. 3 Q. Okay. But from what date to what date? 4 A. I told you. You can do the math. I turned, I 5 was 18. 6 Q. When were you 18? 7 A. Excuse me? 8 MR. EDWARDS: Object to the form. 9 BY MR. LUTHER: 10 Q. When were you 18? 11 MR. EDWARDS: Object to the form. 12 THE WITNESS: I am 21 now. 13 BY MR. LUTTIER: 14 Q. My question is when were you 18? 15 A. When was I 18? 16 Q. Yeah. 17 A. Can you give me a piece of paper and a 18 pencil- 19 Q. Sure. 20 A. — so I can find out -- 21 Q. No problem. 22 A. — when in the hell I was 18? How about if 23 you do the math? 24 Q. There you go, ma'am. 25 A. Can you do the math? Is it — Page 38 1 A. Yes, yes. 2 lit What were your sources of financial support in 3 4 A. I had a boyfriend that supported me, my son 5 and I. 6 Q. And what what was that boyfriend's name? 7 A. 8 Q. 9 A. 10 Q. And did he provide the sole support for your 11 and son, you and your son? 12 A. Yes, he did. 13 Q. Did he live with you at some point in time? 14 A. I lived with him at some point in time. 15 Q. And when was that? 16 A. That was in — I just turned —1 was 18 when 17 lgot with him, and I just named 19. And we were 18 together for, we lived together for around five months. 19 Q. What did you mean when you said you got with 20 him when you were 18? 21 A. We started dating when I was IS. I moved in 22 his house when I was i8 and then I turned 19. I 23 remember having my 19th birthday. We lived together for 24 around five months. 25 Q. So what, what period of time then did 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 40 MR. EDWARDS: Object to the form. She will give her date of birth, and it's a, ifs a factual issue as to when she turned 18. BY MR. LUTTIER: Q. You don't — so, are you telling us here in this deposition you don't know when you turned 18? A. Sr, i was 18 when i met the man and i turned 19. Q. And what's the date of your 18th birthday? A. i don't know of what year. Q. You don't know what year you turned 18? A. No, sir. Q. When were you born? A. ILQ. A. Yes. Q. Okay. A. I am not so wonderful with math if that's what you're asking. Q. So, when you turned 18, which if your numbers are correct and if m math is correct, that's going to put it a A. Okay. Q. So, you moved in with him in And 10 (Pages 37 to 40) PROSE COURT REPORTING AGENCY, INC. EFTA02726445 Page 41 1 you said that you were with him when you turned, that is 2 'living with him, when you turned 19? 3 A. Yes. 4 So that means you were living with hint US 5 6 A. i. 7 Q. Yes? S A. Yes. 9 Q. And then when did you move out from him? 10 A. Okay. Actually ] got with him in... 11 Q. Of what year? 12 A. 1 was 18. 13 Q. We established that was 14 A. Okay. s Q. So if it was-, that would make in. 16 right? 17 A. I was 18 when I got with him. That was in 18 IE. I don't know what year. I am not that good with 19 math. Fm sorry. 20 Q. Well, if you were, which 21 you've agreed you were, right? 22 A. Yes. 23 Q. And, and if you moved in with him in.' of 24 the year when were 18, the on,. that could be 25 would b isn't that 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 43 A. Imoved, I moved with my, I stayed with my jilt father for a cou le of weeks. Then I moved into the, the address o . Q . ? A. Yes. Q. Okay. And where does your dad or where did your dad live at that time? A. NIL Q. And did you move in with your dad for approximatel a two-month period between o.? of f I A. I moved in with him Q. Okay. Ofd? A. I.And then 1 moved into the on Q. And did your son move in with your dad with you? A. My son has always been with me since he was bom. Q. Has there ever been any kind of judicial proceeding or administrative proceeding brought to change where your son lives? In other words, have you ever — do you know who.. is? A. 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 Page 42 A. Sure. Q. Okay. A. If that's correct. Q. So, it's your recollection as you sit here today that you moved in with this entleman in'. of II or that you started dating ii A. We started dating and I moved in with him about two, a month later. Q. Okay. And you lived with him for approximately five months? A. Yes. So that, that means you moved out in around A Q. i mean of I'm sorry. Right? A. I moved out when I moved into the 7 — or when 'moved into the which was or which wastzah, Q. Of.? A. Yes. Q. All right. So, that correst believe the date that you moved out was of not of M; is that right? A. 1 moved out sometime in Q. Did you live anyplace — 9 1. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 44 Q. Has there ever been any kind ollilliproceeding that you have been involved? A. Unfortunately, yes. Q. Were you involved in that proceeding; that is was the proceeding were you a party in that proceeding? A. i went through a with a previous boyfriend. Q. Okay. A. And that's how co got involved. Q. Was there a formal investigation? A. Yes. Q. And do you remember what year that was? A. '06. Q. Okay. Now, I had asked you reWous whether you had any source of support from all forward. And told me — A. Q. — that you lived with this boyfriend. But now you have described the time that you have lived with this boyfriend and telling me that you moved out with him in lIMIE of So apparently he wasn't providing support to you in A. No. Q. Did he -- he didn't provide you support after 11 (Pages 41 to 44) PROSE COURT REPORTING AGENCY, INC. EFTA02726446 Page 45 1 you quit living with him, did he? 2 A. Correct. 3 Q. Oka . All ri ht. So let's go back tot 4 Startin 5 A. Okay. 6 Q. What means of support did you have ill.? 7 A. I worked at — 8 MR. LUTTIER: What, I mean — 9 MR. CRITTON: He can't do that. 10 MR. LUTI1ER: Whoa, whoa, whoa. I don't think 11 you can sit ova and start conferring with your 12 client when i am taking her deposition. 13 MR. EDWARDS: Okay. 14 MR LUTT1ER: I mean, if you've got a -- if 15 it's an attorney-client privilege issue — 16 MR. EDWARDS: That's why I was asking. It 17 doesn't appear there is. You can ask your 18 question. 19 MR. LUTHER: Okay. What - 20 THE WITNESS: I worked -- 21 MR. EDWARDS: The question is what she was 22 doing to make money? 23 BY MR. LUTPTER: 24 Q. What forms of su rt did you have or means of 25 support did you have in=? 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 47 1 MR. EDWARDS: Don't answer. If we're going to 2 get into specific sexual issues, this is up on 3 appeal. Fourth District Court of Appeal just 4 issued a Rule to Show Cause directed towards 5 Mr. Epstein. Until that issue is resolved, she's 6 not going to answer specific sexual issues. She's 7 admitted to being a call girl. She will continue 8 to do so. 9 She's not going answer the names of the places where she did it or any Joint's as we feel that issue has not been covered. And until that is resolved, we're instructing our client not to answer. Additionally on those questions, we are invoking her Fifth Amendar raright to remain silent, tight of privacy as toe., as well as the right of privacy of third-parry individuals. MR. LUTTIER: Okay. Let me, just so we have a clear record, I am going break those questions down and then you can -- MR. EDWARDS: Sure. MR. LIMIER: — assert your objection. BY MR. LUTT1ER: referred tol Q. You said that you worked inet are the names of the, what you where you worked? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I worked in Q. What Rind ofd? A. Page 46 Icindbam What do you mean kinds of A. I worked as an escort. Q. What do you mean by escort? A. Wow, I worked as a call girl. I worked as an escort. Do you not know what an escort is? Q. Ma'am, I want to make sure we don't have a definitional problem. So now you have said you worked as a call girl and as an escort; is that correct? A. Yes. It's the same thing. MR. EDWARDS: Object to the form. BY MR. LIMIER: Q. So, in your, in teens of this deposition, if you refer to a call girl or an escort, those things mean the same thing in your mind, correct? A. It means the same thing in everybody's mind. Q. Okay. Well, tell me what you did as a call girl, escort inl.? A. I performed sexual, sexual things for men for money. Q. And what sort of sexual things did you perform for men for money ina? Page 48 1 MR. EDWARDS: Same objection. Don't answer. 2 MR. LUTI7ER: What, what specifically is the 3 objection to that? 4 MR. EDWARDS: The objection is that this issue 5 is up on appeal. And the Fourth District Court of 6 Appeal has issued a Rule to Show Cause Order 7 directed towards Mr. Epstein. Until that issue is 8 resolved, we're not answering that questis.The 9 basis of that issue is the privacy rights °FM., 10 the privacy ripaof third parties as well as the 11 invocation ofa.'s Fifth Amendment tight to 12 remain silent on this issue. 13 MR. CRITTON: Just so, and again let me just 14 insert here so the record is clear: You, in 15 essence, took up an issue associated with interrog, 16 a portion of interrogatory 19 where you chose to 17 answer certain portions and not to answer other 18 portions. Portion dealt with, in essence, prior 19 time. And I will put it out if necessary. 20 The court has not issued, Judge Hafele didn't 21 preclude any type of questioning with regard to 22 income-related issues associated with where she 23 worked, what she did, how she made her money, bow 24 much income she did make. 25 You have a claim for loss of canting, loss of 12 (Pages 45 to 48) PROSE COURT REPORTING AGENCY, INC. EFTA02726447 Page 49 1 earning capacity here. None of that went up on 2 appeal nor did you object to that. You dealt 3 specifically with some aspects of prior sexual 4 history. 5 So I beg to differ. That's not part of what 6 the upcoming appeal is under the circumstances. 7 And I think it's inappropriate. Well, well let the judge decide what is appropriate or not under 9 the circumstance. 10 MR EDWARDS: She will testify to what money 11 she made, just not the names of the places and the 12 Johns. That's it. So I understand that we have a 13 disagreement. That's my position. 14 MR. GOLDBERGER: I need to clarify one thing. 15 Jack Goldberger on behalf of Mr Epstein. 16 You have raised three objections to that 17 question: Privacy, the issue that's on appeal and 18 the Fifth Amendment. Should your objections be 19 overruled on the right of privacy and on the issue 20 that's on appeal in the Fourth DCA, do you still 21 intend to invoke the Fifth Amendment privileges on 22 behalf of your client? 23 MR. EDWARDS: I'm sorry, what was the last 24 part? 25 MR. GOLDBERGER: Yes. Should your objections Page 511 1 BY MR. LUM.E:. 2 Q. Une? You said since, but did 3 you mean until? 4 A I stopped. Until 5 Q. Okay. Is there a specific event that you can 6 recall as marking the point in time that you quit being 7 a prostitute? 8 A. Specific event? 9 Q. Yes 10 A. 11 Q. And what is it that you can recall that allows 12 you to state that that was the date in which you quit 13 being a prostitute? 14 A. I ant sick of the lifestyle. That's what I can 15 recall. 16 Q. So, it wasn't a ecific event It was a 17 decision by you on that you no longer 18 wished to be a prostitute; is that correct? 19 A. Correct. 20 Q. And during the period from • to 21 ill of II, was there anything that prevented you from 22 making the decision at any time during that period that 23 you wished to quit being a prostitute? 24 A. i don't understand what you arc ain I me. 25 Q. Was there anything between and 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 50 be overruled, overruled on privacy issues and on the issues that are before the Fourth District Cowl of Appeal as to this question, you still intend to invoke Fifth Amendment privileges on behalf of your client? MR. EDWARDS: I do. And under that point we would concede that you are entitled to whatever adverse inferences that you believe you are entitled to under the case law. MR. LUTTIER: In 2000- MR. CRITTON: Or, or, let me just -- or whatever other relief is appropriate under the circumstances. MR. EDWARDS: Of course. Whatever the judge decides. BY MR. LUITIER: Q. MIN were you working as a prostitute? A. Yes. Q. Have you ever worked — or for what period of time in did you work as a prostitute? A. What period of time? Q. Yes. From al until when? A. Until, well, - since of I. MR. CRITTON: I'm sorry? 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 52 of that prevented you from quitting being a prostitute? A. Didn't you just ask me the question, sir? Q. No. Well, yeah, you said you didn't understand it, so I asked it again. A. i said I was sick of the lifestyle.. Q. From. toll of. is there anything that prevented you from stopping being a prostitute at any time during that od? A. Well, I've beat seein and kind of realized that this life isn't for me. Can I have a tissue? Q. You were seeing ralMil between — MR. EDWARDS: Let me just grab the witness a tissue. MR. LUTHER: I am going to take a bathroom brealc. MR- EDWARDS: Okay. THE VIDEOGRAPHER: Arc we going off the MR. EDWARDS: Sure. THE VIDEOGRAPHER: Going off the record. The time is 10:41 am. (A brief recess was held.) THE VIDEOGRAPHER: We're back on the video 13 (Pages 49 to 52 PROSE COURT REPORTING AGENCY, INC. EFTA02726448 Page 53 record. The time is approximately 10:52 a.m. 2 MR. EDWARDS: Okay. We had an issue come up 3 where everybody that represents Mr. Epstein decided 4 to chime in on a certain issue. And I know that 5 that was an isolated incident. I am assuming that 6 everybody realizes, you know, the rules here and 7 you have chosen your examiner, and that's going to 8 be the person speaking for Mr. Epstein, or on his 9 behalf for the reminder of the deposition. We're 10 not going to get double or tripled teamed. 11 MR. CRITTON: I get -- let me speak to that. 12 MR. EDWARDS: Okay. 13 MR. CRIITON: You have got five lawyers, five 14 to seven lawyers here on Plaintiffs on every 15 deposition that i have attended- I have had five 16 separate Plaintiff groups that all chime in on, on 17 everything. We arc not impacted in the deposition 18 with your client at all, i.e., we're not chiming in 19 to question her at all. 20 What we are is Mr. Goldberger has certain 21 information that I am unaware of, so he deals, 22 dealt only with the objection. It was a 23 lawyer-to-lawyer issue. There are certain 24 information that I have that Mr. Luttier does not 25 have. So that's again a lawyer-to-lawyer issue Page 55 1 Q. And that would be when? What date? 2 A. 2002. 3 Q. And that's when you first became sick of what 4 you have described as the lifestyle? 5 A. Yes. 6 Q. How long have you been a prostitute? 7 A Well, ever since I was lured into Jeffrey's 8 house. 9 Q. Which is when? 10 A. 2002 when i was 13. 11 MR. GOLDBERGER: Can we just stop for a 12 second? We're having a technical issue upstairs. 13 Apparently we're, we're mooted. Can we do 14 something about that? Thanks. I appreciate it. 15 MR. LUITIER: Okay. What was the last 16 question? I mean, what was the last answer? 17 (The requested portion of the record was read 18 by the reporter.) 19 BY MR. LUTHER: 20 Q correct, you said were you 21 born 22 MR. EDWARD$: Object to the form 23 MR. LUTT1ER: And i haven't asked a question 24 yet. 25 MR. EDWARDS: Well, that's not what the Page 54 1 only on the record. It does not deal with — only 2 one lawyer is going to be asking questions. Only 3 one lawyer will do any objections or comments with 4 regard to III MR. EDWARDS: Okay. 6 BY MR. LUrlIER: 7 Q. the question I had asked you before we 8 took the break was whether there was anything that 9 prevented you from t • empluaent vat 10 prostitute between and ME of 11 A. i was sick of the lifestyle. 12 Q. Okay. And when did you become, to use your 13 words, sick of the lifestyle? 14 A. I never liked the lifestyle but you can only 15 endure so much pain for so long. 16 Q. And what you say pain, are you referring to 17 physical pain or are you referring to mental pain? 18 A. Both. 19 Q. And when did you first become, to use your 20 words, sick of the lifestyle? 21 A. Since I met Jeffrey. 22 Q. Which is when? 23 A. When' was 13 years old. 24 Q. Thirteen now. Is that what you said? 25 A. Yes, 13. Page 56 1 witness said. That's not the date of her birth, 2 That's not the answer she gave. So, i am just 3 correcting you to help you out. 4 BY MR. LUMER: 5 Q. Okay. What, what you did say your date of 6 birth wilaa'ag? 7 A. ISM - MR. LUCITE! 't read my handwriting. 9 Stand corrected. Ma Thank you counselor. to BY NINA' 11 Q. So accorgwase 12 calculations, if my math is right, EMI of 2001 is 13 when you would have turned 13, correct? 14 A. If that's, if that's right. 15 Q. And it was sometime in 2002 that you recall 16 that you first met Jeffrey? 17 A. Yes. 18 Q. Now, prior to the first time you met Jeffrey, 19 had you been a prostitute? 20 A. No. 21 Q. Did you do anything prior to the first time 22 you met Jeffrey with respect to receiving money or 23 anything of value in return for any type of sexual 24 favor? 25 A. No. J 14 (Pages 53 to 56) PROSE COURT REPORTING AGENCY, INC. EFTA02726449 Page 57 1 . Durin this period from toll, or 2 until. , when you were acting 3 as an escort and you were doing sexual thing