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14 
of 18 he would place a vibrator on Jane Doe 4's 
15 
genitals? 
16 
MR. PIKE: Form. 
17 
A. I refuse to answer. 
18 
Q. Did Jeffrey Epstein admit to you that prior to 
19 
Jane Doe 4 becoming 18 years of age he would masturbate 
20 
in her presence? 
21 
A. I refuse to answer. 
22 
MR. PIKE: Form to the last question. 
23 
N.R. MERMELSTEIN: Hum? 
24 
MR. PIKE: Form Lo the last question. 
25 
Q. Did Jeffrey Epstein admit_ to you that prior to 
0125 
1 
Jane Doe 7 reaching the age of 18 years old he would 
2 
touch her breasts? 
3 
MR. PIKE: Form. 
4 
A. I refuse to answer. 
5 
Q. Did Jeffrey Epstein admit Lo you that. prior to 
6 
Jane Doe 7 reaching the age of 18 he would grope her --
7 
grope Jane Doe 7's buttocks? 
8 
MR. PIKE: Form. 
9 
A. I refuse to answer. 
IC 
Q. And did Jeffrey Epstein admit to you that. 
11 
prior to Jane Doe 7 reaching the age of 18 he would rub 
12 
Jane Doe 7's vagina? 
13 
A. I refuse to answer. 
14 
MR. PIKE: Form. 
15 
Q. Do you know who 
is? 
16 
A. I refuse to answer. 
17 
Q. Did Jeffrey Epstein instruct you to call 
18 
on numerous occasions Co recruit underage girls 
19 
to come to the Palm Beach Mansion to give Jeffrey 
20 
Epstein a massage? 
21 
MR. PIKE: Form. 
22 
A. I refuse to answer. 
23 
Q. Did Jeffrey Eostein instruct you on numerous 
24 
occasions to contact 
for the purpose of 
25 
scheduling underage girls for appointments to come to 
C126 
1 
the Palm. Beach mansion and give Jeffrey Epstein a 
2 
massage? 
3 
A. I refuse to answer. 
4 
MR. PIKE: Form. 
5 
Q 
Did Jeffrey Epstein advise you that 
6 
was his contact in western Palm Beach oun y 
7 
high schools for the purpose of recruiting underage 
8 
girls to come to the Palm Beach mansion where he would 
9 
then engage in sexual activity with them? 
IC 
A. I refuse to answer. 
11 
MR. PIKE: Form. 
12 
Q. Did 
instruct you on how to 
13 
contact underage girls for the purpose of bringing them 
14 
to the Palm Beach mansion for massages and what to say 
15 
Lo these young girls? 
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MR. PIKE: Form. 
17 
A. I refuse to answer. 
18 
Q. Did 
train you in how Lo contact 
19 
girls and recruit them Lo come to the Palm Beach 
20 
mansion and -- and provide Jeffrey Epstein with 
21 
massages? 
22 
A. I refuse to answer. 
23 
MR. PIKE: Form. 
24 
Q. Was one of your primary duties scheduling 
25 
regular appointments, at least Lwo per day, for Jeffrey 
C127 
1 
Epstein to have underage girls come to the mansion to 
2 
give him. a massage? 
3 
MR. PIKE: Asked and answered, form. 
4 
A. I refuse to answer. 
5 
MR. MERMELSTEIN: Okay. That's all I have. 
6 
MR. PIKE: I have no questions. 
7 
MR. EDWARDS: I only have a couple. 
8 
I'll go ahead and mark this as Number 4. 
9 
(Whereupon, Plaintiff's Exhibit 4 was marked 
10 
for identification.) 
11 
REDIRECT EXAMINATION 
12 
BY M.R. EDWARDS: 
13 
Q. This photograph appears to be Jeffrey Epstein, 
14 
yourself, and Maer Roshan in this photograph taken from 
15 
an Internet newspaper. Can you tell me where that 
16 
picture was Laken? 
17 
A. I refuse to answer. 
18 
MR. PIKE: May I see that, counsel? 
19 
Q. Was this related -- this event, was it related 
20 
to MC Squared? 
21 
A. I refuse to answer. 
22 
Q. All right. What is -- I know that you told us 
23 
that you're not employed now because you're in school. 
24 
What was  your last employment? 
25 
A. 
0128 
1 
Q. 
2 
A. 
3 
Q. 
4 
A. 
Q. 
6 
A. Correct. 
7 
Q. Where did you work prior to that? 
8 
A. I worked for maybe less than a month at a 
9 
clothing store. 
10 
11 
Q. What clothin store? 
A. 
12
Q. 
ere s t at. 
13 
A. South Beach. 
14 
Q. Where in South Beach? 
15 
A. IL's on Collins Avenue and I believe maybe 6th 
16 
and 8th, I'm not sure. 
17 
Q. Okay. Why'd you leave there? 
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10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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24 
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0130 
1 
2 
3 
4 
5 
6 
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8 
9 
1C 
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18 
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21 
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0129 
1 
2 
3 
4 
5 
6 
7 
A. The clothing store? 
Q. Correct. 
A. Because I got the 
Q. And that's what y 
u said? 
A. Yes, um-hum. 
O, Oka , 
 And I suppose that you left the 
because you went to school to finish 
your orytert 
A. Well, I was working part-tine and going Lo 
school part-Lime and it just became too challenging. 
The 
program. is very demanding, so I wanted 
to e icate myself to study. 
Q. How long were you at this 
A. Maybe two and a half years about maybe. 
8 
Something like that. 
Q. All right. So we're in -- when was it that_ 
you left there? 
A. May of 2009. 
Q. Okay. May '09, so chat brings us back to late 
2006 or something when you started there? 
A. Yes. That would be about right, yes. 
Q. And then it was sometime earlier than that in 
2006 when you were at the clothing store? 
A. Yes. 
Q. And you were there for about a month? 
A. About, yes. 
Q. Give or take --
A. Yes. 
Q. -- a week or so? 
clothing store 
A. 
Where -- w 
' 
I was 
you work prior to the 
Q. And where were you modeling? 
A. In Miami. New York. 
Q. For what agency? 
A. In Miami I was with 
I was with 
Q. Who's that? 
A. 
Q. 
A. 
Q. Okay. 
at was in Miami? 
A. YeS. 
O. And then what agency did you work through in 
New York  
A. 
Q. 
A. 
Q. 
A. 
Q. 
Yes
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21 
22 
23 
at 
24 
25 
0131 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
2C 
21 
22 
23 
24 
25 
0132 
1 
A. Um-hum. 
2 
Q. There's a period of time from 2002 throuoh 
3 
2006 where -- 
w, 20C6 you start wit 
4 
and again with 
I know when you came over ere 
5 
in 2002 you were with 
also, right? 
6 
A. I'm sorry, you re confusing me with the 
7 
Limerrame. 
8 
Q. I'm confusing myself, how about that. Let's 
9 
start over. 
10 
2002 you 
ver to the United States, 
11 
you're working at 
12 
A. Yes, I've been invited by 
13 
Q. Okay. And then if I understand you correctly 
14 
over Lime you continue to work with or through 
15 
A. Well, I've been, you know, changing a
.LIM 
16 
throughout the period. 
17 
Q. Okay. What are some of the other modeling 
18 
agencies you have worked for or with? 
19 
A. I refuse to answer. 
20 
Q. Okay. The only other names of modeling 
21 
agencies that you can answer are 
Person that got you hooked up 
A. My husband had that contact. 
Q. Okay. How long did you work with 
A. I'm trying to think. I do not recall exact 
timeframe. 
Q. All right. Well, if the clothing store was 
sometime late 2006 are we talking a' 
lier in the 
when you were working wit 
in 
in New York? 
Miami and 
. . ROSS: I'm going to ask you to invoke. 
THE WITNESS: I'm sorry? 
MR. ROSS: You should invoke with regard to 
this timeframe you're talking about now. 
MR. EDWARDS: Okay. 
A. I refuse to answer. 
Q. Okay. Can you tell me about any job that ou 
had modelin or otherwise prior to working at
or with 
? 
A. 
ecall -- just name any --
Q. Any -- what was your -- what employment did 
"Ili( 
ve just prior to working with 
. I was working as a model in Europe. I 
graduated from high school in 2002 and I dedicated that 
year to modeling and so I was modeling. I did not have 
employment. 
Q. All right. So just so I understand you were 
modeling in Europe, you came over here in 2002. 
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22 
is that correct? 
23 
THE WITNESS: Should I? 
24 
MR. ROSS: Well, she's already answered also 
25 
0133 
1 
MR. EDWARDS: But I thought that was somebody 
2 
through Elite, like they're --
3 
MR. ROSS: NO no no, 
is 
4 
MR. EDWARDS: Different, 
1. 
5 
Q. All right. Is there anybody else that you're 
6 
able Lo -- to tell me where you worked? 
7 
MR. ROSS: Invoke as Lo any further 
8 
information. 
9 
THE WITNESS: I'm sorry? 
10 
MR. ROSS: Invoke your privilege. 
11 
A. I refuse to answer any questions. 
12 
MR. EDWARDS: All right. That's all I got. 
13 
MR. MERMELSTEIN: Can I just follow up a 
14 
couple? 
15 
RECROSS-EXAMINATION 
16 
BY M.R. MERMELSTEIN: 
17 
Q. In what has been marked as Exhibit 2C is a 
18 
phone message from you Loillill-- from you to Jeffrey 
19 
Epstein dated September 1 t , - 005 at. 1:15 p.m. 
20 
And the message that you left was 1111111 
21 
confirmed 4 p.m.", is that correct? 
22 
A. I refuse to answer. 
23 
. Is the 
referred Lo in this message 
24 
25 
MR. PIKE: Form. 
0134 
1 
A. I refuse to answer. 
2 
Q. And did you schedule 
3 
MR. PIKE: Form. 
4 
Q. -- 
to come to the Palm Beach 
5 
mansion as 
to give Jeffrey Epstein 
6 
massages? 
7 
MR. PIKE: Form. 
8 
A. I refuse to answer. 
9 
Q. Also what has been marked as Exhibit 2F is a 
10 
phone message from you to Jeffrey Epstein dated 
11 
September 11th, 2005 at 9:15 a.m.. And the message was 
12 
that, you got a car for a particular person. Do you 
13 
recall that? 
14 
MR. PIKE: Form. 
15 
A. I refuse to answer. 
16 
Q. Is Lhe car that. you obtained on 
17 
September 11th, 2005 for Jane Doe 4? 
18 
MR. PIKE: Form. 
19 
A. I refuse to answer. 
20 
Q. And Jane Doe 4 is a girl who had been coming 
21 
to the Palm Beach mansion to give Jeffrey Epstein a 
22 
massage and engage in sexual activities with him for a 
23 
substantial period of time; is that correct? 
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24 
A. I refuse to answer. 
25 
Q. And also what has been marked as Exhibit 21 --
0135 
1 
actually --
2 
MR. EDWARDS: Is that G? 
3 
MR. MERMELSTEIN: Are they similar? 
4 
M.R. EDWARDS: Yeah, I guess they blocked out 
5 
names on one of them and they didn't on the other. 
6 
MR. MERMELSTEIN: Right. Okay. 
7 
Q. And what has been marked as Exhibit 2G is a 
8 
message from you to Jeffrey Epstein dated 
9 
September 3rd, 2005 at 8:5C p.m. And the message you 
10 
left is, quote, "I left message for 
to confirm 
11 
for 11:0C a.m. and 
for 4:30 p.m." 
12 
Did you, in act, leave that. message? 
13 
MR. PIKE: Form. 
14 
A. I refuse to answer. 
15 
Q. And this message that you left confirmed an 
16 
appointment for Jane Doe 4 for 4:30 p.m., correct? 
17 
A. I refuse to answer. 
18 
MR. MERMELSTEIN: All right. That's all I 
19 
have. 
20 
MR. ROSS: Waive. 
21 
MR. MERMELSTEIN: All right. 
22 
VIDEOGRAPHER: Off the record, 12:42 p.m. 
23 
THE REPORTER: Are you ordering? 
24 
M.R. EDWARDS: Yes. 
25 
MR. PIKE: I want a copy, a mini, no ASCii, 
0136 
1 
and no word index. 
2 
MR. MERMELSTEIN: I'll take a copy with a 
3 
mini. 
4 
(The deposition was concluded at 12:42 p.m.) 
5 
(Reading and signing of the deposition was 
6 
waived by the witness and all parties.) 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
2C 
21 
22 
23 
24 
25 
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0137 
1 
CERTIFICATE OF OATH 
2 
STATE OF FLORIDA 
3 
COUNTY OF BROWARD 
4 
5 
I, Janet L. McKinney, Registered Professional 
6 
Reporter, Florida Professional Reporter, Certified 
7 
LiveNote Re 
4 tary Public, Slate of Florida, 
8 
certify tha 
ROSS personally appeared before me 
9 
on March 15, 
. was duly sworn. 
10 
Signed this 21st. day of March, 2010. 
11 
12 
13 
14 
Janet L. McKinney 
Registered Professional Reporter 
15 
Florida Professional Reporter 
Certified LiveNote Reporter 
16 
Notary Public, State of Florida 
Commission No.: DD552183 
17 
Expires: June 2, 2010 
18 
19 
20 
21 
22 
23 
24 
25 
0138 
1 
CERTIFICATE OF REPORTER 
2 
STATE OF FLORIDA 
3 
COUNTY OF BROWARD 
4 
5 
I, Janet McKinney, Registered Professional 
6 
Reporter, Florida Professional Reporter, Certified 
7 
LiveNote Reporter, certify that I was authorized to and 
8 
did stenographically report the deposition of 
9 
pages 1 through 138; that a review of the 
le 
transcript was not requested; and that the transcript 
11 
is a true record of my stenographic notes. 
12 
I further certify that. I not a relative, 
13 
employee, attorney, or counsel of any of the parties, 
14 
nor am I a relative or employee of any of the parties' 
15 
attorneys or counsel connected with the action, nor am 
16 
I financially interested in the action. 
17 
Dated this 21st day of March, 2010. 
18 
19 
Janet L. McKinney, RPR, FPR, CLR 
2C 
Registered Professional Reporter 
Florida Professional Reporter 
21 
Certified LiveNote Reporter 
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