EFTA00724274

Page 1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CIV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, 
Defendant. 
RELATED CASES: 
08-80232, 08-08380, 08-80381, 
08-80994, 08-80993, 08-80811, 
08-80893, 09-80469, 09-80591, 
09-80656, 09-80802, 09-81092 
DEPOSITION OF 
Tuesday, May 11, 2010 
9:16 A.M. - 10:59 A.M. 
PROSE COURT REPORTING AGENCY, INC. 
3111 West Dr. Martin Luther King, Jr. Boulevard 
Suite 100 
Tampa, Florida 33607 
REPORTED BY: 
MICHELLE OLSEN BADEN, RPR, FPR 
Notary Public, State of Florida at Large 
Prose Job No.: 1998 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden.M
) 
and0i404:4536-414d-8110443419Ciec569 
EFTA00724274

EFTA00724275

Electronically signed by Michelle Baden Ma 
APPEARANCES: 
2 
BRAD EDWARDS, ESQUIRE 
3 
FARMER JAFFE WEISSINO EDWARDS FISTOS & 
LEHRMAN, P1. 
4 
425 North Andrews Avenue, Suite 2 
also, 
Florida 33301 
5 
Attorney or Plaintiff in Related 
Case No0840893 
(Appeared via telephone conference call) 
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STUART S. MERMEISTEIN, ESQUIRE 
MERMELSTEIN & HOROWITZ, PA. 
18205 Biscayne Boulevard, Saute 2218 
a
ila 
33160 
Attorney for Plaintiffs in related cases 
08-80069, 08-80119, 08-80232, 08-80380, 0840381, 
0840993, 0840994 
(Appeared via telephone conference call) 
MICHAEL I. PIKE, ESQUIRE 
BURMAN CRITTON LUTHER & COLEMAN 
n Boulevard, Suite 400 
Florida 33401 
Attorney for Defendant, JEFFREY EPSTEIN 
(Appeared via telephone conference call) 
Page 
Page 4 
1 
The deposition of vas 
taken 
2 
pursuant to Subpoena by counsel for the Defendant on 
3 
Tuesday, May 11,2010, commencing at 9:16 A.M. at PROSE 
4 
COURT REPORTING AGENCY, INC., 3111 West Dr. Martin 
Luther King, Jr. Boulevard, Suite 100, Tampa, Florida 
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33607. Said deposition was reported by Michelle Olsen 
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Baden, RPR. Notary Public, State of Florida at Large. 
a 
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WHEREUPON: 
THE REPORTER: Please raise your right hand 
Do you solemnly swear or affirm that the 
testimony you give today in this matter will be the 
truth, the whole truth and nothing but the truth? 
THE WITNESS: Yes. 
a witness, having been duly sworn to tell the truth, the 
whole truth and nothing but the truth, was examined and 
testified as follows: 
EXAMINATION 
BY MR. PIKE: 
Q 
Morning, Ms. 
My name is Michael 
Plke Can you hear me clearly? 
A 
Yes. 
Q 
fm taking your deposition today via 
telephone. Usually, when we have a telephone 
1 
2 
3 
Examination By Mr. Pike 
4 
Examination By Mr. Edwards. ..... .—....--.72 
5 
6 
Certificate of Reporter.._......_ 
77 
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Catificate of Oath. ...... 
..... —...78 
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Page 3 
INDEX . 
 
PAGE 
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16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
EXHIBITS 
(No exhibits were market) 
1 
2 
3 
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5 
6 
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Page 5 
deposition, its very easy for me to talk ova you and 
vice versa. So, during this telephone deposition, 
please allow me to finish my questions and I will allow 
you to finish your answers, that way you and I can hear 
each other clearly. 
If at any time you do not understand my 
question, please stop and ask me to repeat the question 
and I will do so, especially given the fact that we are 
on the telephone. Okay? 
A No problem. 
Q 
Okay. Would you please state your name for 
the record. 
A 
Q 
woo you please spell your last name. 
A 
Q Ms. 
A I live 
Q 
A 
Q 
Q 
Q 
where is your current residence? 
And how long have you lived in 
I moved 
right befo 
And what Is your date of 
. 
Wow old are you today? 
lam. 
What is your current telephone number, both 
2 (Pages 2 to 5) 
PROSE COURT REPORTING AGENCY INC. 
IIIIIIIIIIIII 
053d0950-b535-41401118-6434195ae559 
EFTA00724276

Page 6 
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3 
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Q How long have you had that cellular telephone? 
5 
A 
As long as I have lived ha. 
6 
Q 
Cm sorry, what was the date that you 
7 
moved a, 
just the year? 
8 
A Roughly, September or — wait. October, rrn 
9 
sorry. 
10 
Q Of 2009 or 2008? 
11 
A 
12 
Q 
Where do you currently work? 
13 
A 
lam not working. 
14 
Q 
Where was 
ur last lace of em lo 
t? 
15
A 
I worked s.
16 
17 
Q 
What 
of business is that? 
18
A It tvas 
19 
Q 
Where 
that located? 
20 
A INIMMINIMMIIIMI 
21 
22 
Q Is that also a 
23 
A 
Yes, sir. 
24 
QAnd before that where did you work, 
25 
Ms. 
? 
home and cell phone? 
A IS 
have a cell, there is no home, and it 
Page 8 
1 
A 
Nowhere. That was m first lob — or no I'm 
2 
sorry. I worked 
3 
• • Q 
was your first place of 
4 
employment? 
S 
A 
Yes, sir. 
6 
Q I'm going to ask you whether or not you know 
7 
certain individuals, and I would just like you to answer 
8 
me yes, you know them or no, you do not know them. And 
9 
the ones that you do know we'll come back to later on, 
10 
after I finish figuring out who it is that you know and 
11 
who it is you don't know. Okay? 
12 
A 
Okay. 
13 
Q Do you blow a female by the name of 
14 
Jane Doe 2? 
15 
A No. 
16 
Q 
Do you 'mow a female by the name of 
17 
Jane Doe 3? 
18 
A No. 
19 
Q 
Do you know a female by the name of 
20 
Jane Doe 4? 
21 
A 
No. 
22 
Q 
Sometimes pronounced Jane Doe 4? 
23 
A 
No. 
24 
Q Do you know a female by the name of 
25 
Jane Doe 5? 
1 
2 
3 
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6 
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21. 
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A I worked 
Q 
Where was tha 
A 
street, maybe 
Q 
And befo 
A 
I worked a 
Page 7 
located? 
Not exactly sure of the 
, somewhere along there. 
where were ou employed? 
Q 
And before 
A I worked at 
Q 
And where is tha 
'located, 
areet-wise? 
A 
It's 
right there on. and 
Q 
What was our osition at 
A 
I was 
Q 
Okay. How long did you work for 
A I would say a couple months. 
Q 
And before= in 
you work? 
A I worked at — I'm not sure of the name — I 
want to say 
Q How long did you work for the 
A I would say ma be a month month or two. 
Q 
And bef 
where did you 
work? 
where did 
Page 9 
1 
A No. 
2 
Q Do you know a female by the name of 
3 
Jane Doe 6? 
4 
A 
Yes. 
5 
Q Do you 'mow a female by the name of 
6 
Jane Doe 7? 
7 
A No. 
8 
Q Do you know a female by the name of 
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Jane Doe 8? 
10 
A 
No. 
11 
Q Do you know a female by the name of 
12 
A No. 
13 
Q 
Have you ever met El? 
14 
A No. Never heard the name. 
15 
...Do 
youlmow a female by the name oil.. 
16 
17 
A No. 
18 
Q Do you know a female by the name of= 
19 
A No. 
20 
Q Do you latow a female by the name of 
21 
Jane Doe II? 
22 
A No. 
23 
Q Do you blow a female by the name of Jane Doe? 
24 
A 
Yes. 
Q Do you know a female by the name ofMIT 
1r 
 4. 
3 (Pages 6 to 9) 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden IIIMEIM) 
and09804538-04d-M18-643419bac559 
EFTA00724277

Page 10 
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A 
Yes. 
2 
Q Do you know a female by the name oliM 
3 
A 
Yes. 
4 
Q Do you know a female by the name of Si
5 
A 
Yes. 
6 
Q Do you know a female by the name SIM 
7 
A No. 
8 
Q 
Give me one second. Ms. 
how is it 
9 
that you know Jane Doe 6? 
10 
A 
She lives in the neighborhood I use to hang 
11 
out in. 
12 
Q 
And what nei borhood is that? 
13 
A 
14 
Q 
Would 
I that for the record. 
15 
A 
I believe. 
16 
Q 
How long have you known Jane Doe 6? 
17 
A 
I woWd say since I was 15. 
18 
Q Did you guys go to school together? 
19 
A 
No. 
20 
Q How did you meet her? 
21 
A 
She was just hanging out with friends, I 
22 
believe. Just everybody hanging out and we met. 
23 
Q 
Have you remained friends since the time you 
24 
first met her? 
25 
A 
Yes. 
1 
A 
No. 
2 
Q 
And when I ask that question I mean, from the 
3 
time that you have known her up until today's date, has 
4 
she ever mentioned to you the name Jeffrey Epstein? 
5 
A 
No. 
6 
MR. EDWARDS: I'm sorry is the "her" that 
7 
we're talking about Jane Doe 6 still? 
8 
MR. PIKE: Yes. 
9 
THE WITNESS: Yeah, no, I nova heard anything 
10 
about it. She's never mentioned that name. 
11 
BY MR. PIKE: 
12 
Q Did you ever come to team that Jane Doe 6 had 
13 
gone to Mr. Epstein's home for any reason? 
14 
A No. 
15 
Q Did Jane Doe 6 ever tell you that she went to 
16 
Mr. Epstein's home in Palm Beach to give Mr. Epstein a 
17 
massage? 
18 
A 
No. She said she went there, when I last 
19 
talked to her, but no details. 
20 
Q Did Jane Doe 6 ever tell you that Mr. Epstein 
21 
faced her to do anything against her will? 
22 
A 
No, sir. 
23 
MR. MERMELSTEIN: Object to form the question. 
24 
BY MR. PIKE: 
25 
Q 
And, Mr. 
there are two other lawyers 
Page 
Page 11 
1 
Q 
When was the last time you spoke to her? 
2 
A I spoke to her 
what is today, Tuesday. I 
3 
talked to her on Sunday. 
4 
Q 
When you spoke to her on Sunday did you speak 
5 
about this case? 
6 
A 
No. 
7 
Q Have you ever spoken to Jane Doe 6 about this 
8 
case? 
9 
A I never knew she had anything to do with this 
10 
until she told me the other day. 
11 
Q Would that be Sunday? 
12 
A No. We -- !just got back from 
13 
Q So when you were in 
you saw her face 
14 
to face? 
15 
A 
Yes. 
16 
Q 
And where did you guys meet in NEM 
17 
A I saw her at her house. I came to say hi. 
18 
Q 
What did you guys talk about relative to this 
19 
case? 
20 
A 
All I said was that I can't — 
not talking 
21 
to 
because I have to do a deposition and she just 
22 
said that she had something to do with it but that's —
23 
she didn't go into detail. 
24 
Q Did she ever talk to you about a gentleman by 
.!5 
the name ofJeffrey Epstein? 
Page 13 
1 
on the phone and they are going to be making legal 
2 
objections. Basically what that is is an attempt to 
3 
preserve the record. Those objections aren't directed 
4 
at you. Those objections are directed at my questions. 
5 
So when you do hear a lawyer make an objection. Please 
6 
hold off until we finish our dialogue and then I'll come 
7 
back to you and ask you to finish your answer. Okay? 
8 
A 
Okay. 
9 
Q Did Jane Doe 6 ever tell you that she 
10 
experienced any traumatic events at Jeffrey Epstein's 
11 
home? 
12 
MR. MERMELSTEIN: Objection to form. 
13 
THE WITNESS: No. 
14 
BY MR. PIKE: 
15 
Q Did Jane Doe 6 ever tell you that she provided 
16 
Mr. Epstein a massage while her bra was off? 
17 
A No, sir. 
18 
Q Is Jane Doe 6 one of your best friends? 
19 
A I wouldn't say best friend but she is a 
20 
friend. 
21 
Q Is she a close friend? 
22 
A I mean, when I go to 
i go and say hi 
23 
but that's about it. 
24 
Q 
Since you moved to 
how often do you 
25 
speak to Jane Doe 6? 
I 
4 (Pages 10 to 1 3) 
PROSE COURT 'REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden MMIM 
aa3d0950-6535.414d-81186434195ac559 
EFTA00724278

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Page 14 
A 
Only when I go down there, so I would call her 
before I go down there and say "Hi," but other than that 
we don't talk. 
Q 
Do you know of any traumatic events that 
Jane Doe 6 has experienced in her lifetime? 
MR. MERMELSTEIN: Objection to form. 
BY MR. PIKE: 
Q 
And your answer was, 
A 
No. 
Q 
Do you know whether or not any one of her 
boyfriends everMEMS? 
A 
Yes. 
Q 
Would you consider that a traumatic event? 
A 
Yeah. 
Q 
And your answer was, 
A 
Yes. 
What 
• 
was that, to your knowledge, 
A 
I have no idea. 
Q 
Did Jane Doe 6 ever discuss that traumatic 
event with you? 
A 
No. I heard from somebody else. 
Q 
Who did you hear from? 
A 
I have no idea. Just gossip around the 
neighborhood. I have no idea. 
Ms
? 
1 
.2 
3 
4 
5 
6 
7 
8 
10 
11. 
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Page 16 
A 
Q 
Do you know of any other close friends that 
have died in Jane Doe 6 lifetime? 
A 
No —or yes. 
Q 
And who was that? 
A 
Q 
And who is that to Jane Doe 6? 
A 
Good friend. 
Q 
Would you consider that a traumatic experience 
for her? 
MR. MERMELSTEIN: Objection to form. 
BY MR. PIKE: 
Q 
You can answer. 
A 
Slightly, yes, a little 
Q 
And how did Mr.
 die? 
A a 
And did they eve1
A 
Yes. 
Q 
And is that person= 
A 
Yes. 
Q 
Do you know whether or not Jane Doe 6 has ever 
done drugs in front of you? And by "drugs" I mean 
marijuana, amphetamine or any kind of painkillers? 
A 
Yes. 
Page 15 
1 
Q 
Did you ever have any sexual experiences with 
2 
Jane Doe 6? 
3 
A 
No. 
4 
Dkl 
ever learn that Jane Doe 6 was an 
5 
at the age of, 
A 
No. 
7 
MR, MERMELSTEIN: Objection to fonn. 
8 
BY MR. PIKE: 
9 
aor 
you know whether or not Jane Doe 6 is a 
10 
11 
12 
13' 
14 
1S 
16 
17 
18.
19 
20 
21 
22. 
23 
24 
A 
I knew shel.Mbut 
1 don't see it 
any farther than that. 
Q 
Do you know whether or not she has a 
relationship with her mother? 
A She does, as far as 1 know. 
Q 
Based upon your experience, do you know 
whether or not it is a good relationship or a bad 
relationship? 
A 
1 would say good. 
Q 
Where does her mother live, to your knowledge? 
A 
Q 
What about her relationship with her father, 
do you know anything about that? 
A 
I guess they have a good relationship. 
Q 
Do you know where her father lives? 
Page 17 
1 
Q 
And what drugs has she done, to your 
2 
knowledge? 
3 
A 
Marijuana in front of me. 
4 
Q 
What other drugs? 
5 
A 
She's never done anything else in from of me. 
6 
Q 
To your knowledge, do you know whether she has 
7 
done any other drugs, separate and apart from marijuana? 
8 
A . I'm not sure. 
9 
Q 
Do you know whether or not Jane Doe 6 drinks 
10 
alcohol? 
11 
A 
No. 
12 
Q 
When she did marijuana in front of you, how 
13 
old was she and how old were you? 
14 
A 
15 and 1 don't know how old she was. 
15 
Q 
Have you ever met Jane Doe 6's child? 
16 
A 
17 
18 
A 
19 
20 
A 
21 
22' 
A 
23 
24 
A 
25 
Yes. 
And what is 
name? 
Have you ever met the father? 
Yes. 
And what is his name? 
And his last name? 
1 have no idea. 
Do you know who Jane Doe 6 currently dates? 
5 (Pages 14 to 17) 
PROSE COURT REPORTING 
Electronically signed by Michelle Baden NM= 
AGENCY., INC. 
a53d0950-136364f4d-8118-6434195se659 
EFTA00724279

Page 18 
1 
A la. 
2 
Q 
And doeaMive 
3 
A 
Yes. 
4 
Q 
And what does he do? 
5 
A 
I'm not sure. alMni 
or something. 
6 
Q 
With regard to the women that you said you 
7 
knew, were you aware as to whether or not any of those 
8 
women ever went to Jeffrey Epstein's home in Palm Beach? 
9 
A 
1 only knew about Jane Doe anclia 
10 
Q Did you ever go to Jeffrey Epstein's home? 
11 
A 
No, sir. 
12 
Q Ind you ever drop anyone off at Jefftey 
13 
Epstein's home by vehicle? 
14 
A 
No. I can't drive. 
15 
Q 
And why can't you drive? 
16 
A 
1 don't have a license and lam afraid of the 
17 
road. 
18 
Q 
Have you ever had a license? 
19 
A 
No, slr. 
20 
Q 
Why is it that you are afraid of the road? 
21 
A 
I got in a car accident whealwaa 
22 
Q 
Who was in the car with you? 
23 
A My friend= 
24 
Q 
And what is her last name? 
25 
A 
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Page 20 
A No. We went to the store. 
Q During the times that you hung out with her, 
was she ever crying? 
A 
No. 
Q During the times you hung out with her 
recently, did she ever make any mention or complaint 
about Jeffrey Epstein? 
A 
No. 
Q Did she seem depressed to you? 
A 
No. 
Q Did she dist-mg any emotional issues that she 
was having with you? 
A No, sir. 
Q Did she discuss at all any happy times in her 
life, of the times that you visited with her most 
recently? 
A No. 
Q 
What did you guys talk about? 
n't know. Ii 
our friend' 
A 
Q 
A 
And that would be Ma 
Yes, sir. 
Ho 
' 
9
He 
Page 19 
1 
Q 
Anyone else? 
2 
A 
/N.
stn. 
3 
Q I
 still living today, that is did she 
4 
die as a result of the car accident? 
5 
A No. She's still living. 
6 
Q 
When you saw Jane Doe 6 on Stmday, did she 
7 
seem happy to you? 
8 
A I don't know. We just stopped by and said 
9 
"Bye" so — she was just watching a movie. 
10 
Q 
You said you stopped by and said "Bye..."? 
11 
A 
Yeah, because we were driving back toME 
12 
Q 
Who was with you? 
13 
A My boyfriend. 
14 
Q 
What is his name? 
15 
A 
16 
Q Does lie live in
17 
A 
Yes. 
18 
Q How long did you visit with Jane Doe 6 for? 
19 
A 
I saw her a couple of times since I was there, 
20 
just hung out for a little and then I was mainly at my 
21 
mom's. 
22 
Q 
When you hung out with Jane Doe 6, where did 
23 
you go? 
14 
A 
We were at her house. 
25 
Q 
Any other places? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
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20 
21.
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24. 
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Page 21 
Q 
A 
Yes, sir. 
Pm sorry, you testified that Mal 
was 
Ma  is that correct? 
A 
Yes. 
vots.What were the circumstances surrounding how he 
A 
They sa r a lot of stories like 
it 
the 
but he got basically 
and then the 
people ran. 
. 
_10 
Where was be living at the time that he was 
NEA if ou
lifis
mw? 
Q Do you know if Mr 
was in a gang? 
A No, I don't. 
Q Do you know iflane Doe 6 was ever in 2. 
A I don't believe so but I don't know everyb . 
she knows. I live here now. 
Q Did Jane Doe 6 ever talk to you about her 
being a prostitute? 
A No. 
Q Do you know whether Jane Doe 6 ever was a 
prostitute? 
A No. 
6 (Pages 18 to 21) 
PROSE COURT REPORTING. AGENCY, INC. 
Electronically signed by Michelle Baden 
.53•10960-b535-0444t184434198ae569 
EFTA00724280

Page 22 
1 
Q 
That is no you don't lmow one way or the 
2 
other? 
3 
A 
No, I don't know. 
4 
Q 
Do you know whether or not Jane Doe 6 ever 
5 
vented at any strip clubs and/or gentlemen's clubs? 
6 
A 
No. 
7 
Q 
That is no, you do not know? 
8 
A 
No, I do not know. 
9 
Q 
Do you know if she ever hung out at any strip 
10 
clubs or gentlemen's clubs? 
11 
MR. MERMELSTEIN: Objection to form. 
12 
BY MR. PIKE: 
13 
Q 
You can answer. 
14 
A 
I don't 'mow. 
15 
Q 
Do you know if Jane Doe 6 was ever involved in 
16 
a car accident? 
17 
A 
I believe so, when she was younger. 
18 
Q 
What do you know about that car accident? 
19 
A I believe it was aMill 
That is all I 
20 
remember. 
21 
Q 
Do you know if anybody passed away in her 
22 
vehicle? 
23 
A 
I don't know. 
24 
Q 
Do you know if anybody came close to dying 
25 
that was in her vehicle? 
Page 24 
1 
A No, sir. 
2 
Q 
Were you ever out anywhere a 
3 
where you saw.lat a club? 
4 
A 
No. 
5 
Q 
Dld you talk to= on the phone? 
6 
A 
No. 
7 
Q 
When was the last time you talked toile 
8 
A !saw her at Wal-Mart when I was, probably, 
9 
It 
10 
Q You said you saw her at Wal-Mart? 
11 
A 
Yeah. 
12 
Q 
I didn't hear you if you testified to this, 
13 
Pm sorry. How long ago was that? 
14 
A 
I'd say when I was 18. I went down to visit 
15 
and she was at Wal-Mart eating at the food 
16 
court and I _
i
said "Hi." 
17 
Q Hass. ever discussed Jeffrey Epstein with 
18 
you? 
19 
A 
No, sir. 
20 
t 
f I remember correctly, you said you knew 
21 
that M. was going to Jeffrey Epstein's home? 
22 
A 
I heard Jane Doe mention it but don't know 
23 
details. 
24 
Q 
When you say "Jane Doe" you mean Jane Doe? 
25 
A 
Yes, sir. 
Page 23 
1 
MR. MERMELSTEIN: Objection to form. 
2 
THE WITNESS: I don't know. 
3 
BY MR. PIKE: 
4 
Q 
Let's talk abou= You said you knewill.; 
5 
is that correct? 
6 
A 
I met.. 
7 
Q 
How did you meet.. 
8 
A 
Once again, just everybody knows everybody and 
9 
she was hanging out one night and I met her. 
10 
Q 
Where did 
u meet her? 
11 
A 
at the bead, I believe. 
12 
Q 
How long have you known ha? 
13 
A 
I not her on my 15th birthday, !believe. 
14 
Q 
Okay. So you have 'mown her for, what,. 
15 
years, approximately? 
16 
A 
Well, I have only — in that whole time, I 
17 
have only hung out with her for maybe lute three times. 
18 
So that is why I don't say like she's a friend. She's 
19 
just an acquaintance. I met her. 
20 
Q 
When you hung out with her for those three 
21 
times, where did you guys hang out? 
22 
A 
We were at the beach. The other times we were 
23 
just, I don't know. I know she was at Jane Doe's once. 
24 
And then I don't !mow. 
25 
Q 
Did you guys ever go out to clubs together? 
2 
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Page 25 
Q 
What did Jane Doe mention that you are 
talking about now? 
A 
She said that she was at the house that. 
Q That. was at Mr. Epstein's house? 
A 
Yeah. 
• Q 
Have you ever discussed.. going to 
Mr. Epstein's house with.? 
A 
No. 
Q 
What, if anything, do you know about... 
going to Mr. Epstein's home?. 
MR. EDWARDS: Form. 
THE WITNESS: I don't know anything besides 
that she went there. 
BY MR. PIKE: 
Q 
Do you know whether or not she did anything of 
sexual in nature at Mr. Epstein's home? 
A 
I have no idea. 
I know that you said you didn't bang out with 
M. that much, but I have to ask you these questions 
and I'll try to make them short. 
Did.. discuss with you any traumatic events 
that happened to her at Mr. Epstein's home? 
A 
No, sir. 
Q Has.. called you to discuss at all any 
emotional issues that she allegedly has by virtue of 
7 (Pages 22 to 25) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden IMMIMID 
at3d0950-b536-4f4d4018-643419Sec669 
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Page 26 
1 
having visited Mr. Epstein's home? 
2 
A 
No. 
3 
Q 
Do you know whether or nail 
worked at 
4 
strip clubs? 
5 
A I don't 'mow. 
6 
Q 
As you sit here coda 
our testimony is you 
7 
don't know whether or node. ever worked as a stripper 
8 
at a snip club? 
9 
A I have no idea. 
10 
Q Did Jane Doe ever tell you than. ever 
11 
worked at any strip club? 
12 
A No. 
13 
Q Do you know whether or no
 is an admitted 
14 
prostitute? 
15 
A I don't know. 
16 
MR. MERMELSTEIN: Form. 
17 
BY MR. PIKE: 
18 
Q Do you know whether or not- ever sold her 
19 
body for sex? 
20 
MR. EDWARDS: Objection to form. 
21 
THE WITNESS: I have no idea. 
22 
BY MR. PIKE: 
23 
Do you know whether or no= ever 
24 
when shewaiters old? 
25 
A I have no idea. 
1 
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Page 28 
BY MR. PIKE: 
Have you ever been AMMAN 
A No, sir. 
Q Do you know whale) 
is? 
A 
A gentlemen's club. 
Q Do you know 
t nextd 
Mien- - 
club is a place call 
A I don't even latow 
is located.
Q 
Have you ever heard the term "jack shack"? 
A 
Yeah. Movies. 
Q 
What -- bow do you understand that term? 
A I guess, basically, a place where you go and 
sell yourself. 
Q Do you know whether or no.. has ever 
worked at any jack shacks? 
A No. 
MR. EDWARDS: Object to the form. 
BY MR. PIKE: 
Q 
That is no, you don't know? 
A No, I don't know. 
Q All right let's move on toM. You did 
testify earlier that you knew her, correct? 
A 
Yes. 
Q How do you known.? 
Page 27 
1 
MR. EDWARDS: Objection to the form of that 
2 
question as well. 
3 
BY MR. PIKE: 
4 
Q Do you know whether or no 
s a 
5 
prostitute? 
6 
A 
I don't know. 
7 
142. EDWARDS: Same objection. 
8 
BY MR. PUCE: 
9 
Q Had you ever heard than...as 
a 
10 
prostitute? 
11 
A No. 
12 
Q Do you know who.. is currently dating? 
13 
A No. 
14 
Q 
What else can you tell me about., if 
15 
anything, that we haven't discussed during your 
16 
deposition today? 
17 
A !can say nothing because I don't talk to her. 
18 
I've only hung out with her a couple times and didn't 
19 
really, you know, talk-talk. Just hung out. I don't 
20 
know her. I don't know anything. 
21 
Q Do you know whether 
22 
works at a lace call 
23 
in 
24 
A I don't ;mow. 
15 
MR. EDWARDS: Object to form. 
ently 
right by 
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18.
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23. 
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Page 29 
and 
was 
Q 
was that? 
A 
Q And did you go to HAM 
for. 
years? 
. A No. 
Q 11. ur long did you go -
A El years. 
Q 
And how long did.. go to that school for? 
A I'm nql.tia. 
.Q What= were you in when you first met 
A I was 
Q Did You Pr 
A No. 
Q How did you meet her? 
A I met her brother and then I went to her house 
and met ha. 
Q How did you meet her bro  ? 
• 
A 
Just around the neighborhood, like everybody 
knows everybody. 
Q Did you ever date her brother? 
A No. 
Q Did you ever have any sexual experiences with 
8 (Pages 26 to 29) 
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Electronically signed by Michelle Baden . 
and095043536-414d-8116-6434195ac669 
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Page 30 
her brother? 
A 
No. 
!ti 
Did you ever have any sexual experiences with 
..? 
A 
No. 
Q Are you aware that.. and.. are friends? 
A 
Yes. 
Q How are ou aware of that? 
A 
. htzg_out with me and then she 
started hanging out with., and then we basically 
an 
talk an more. We went separate ways. 
Did 
. ever tell you that.. ever worked 
A No. I haven't talked to.. maybe since I 
was 15. 
Q 
And why did you stop talking to..? 
A 
Well, she always came to hang out with me and 
then, I don't know, we went our separate ways and, I 
don't knowzie•ust lost contact 
Q Did
. ever discuss whether she went to 
Mr. Epstein's home in Palm Beach? 
A 
No, sir. 
Q 
She never discussed that with you? 
A 
No. 
Q Did.. ever tell you that she worked at 
Page 32 
1 
MR. EDWARDS: Form. 
2 
BY MR. PIKE: 
3 
Q 
When was the last time I 'mow you said you 
4 
haven't spoke a. 
in a while. When was the last 
5 
time you spoke to her? 
6 
A 
I talked to her, I would say, maybe two years 
7 
ago on the phone. She was with Jane Doe, I believe, and 
8 
I just said "Hi" you know, caught up and asked how we 
9 
were doing and that was it. 
10 
Q Did she tell you what she was up to worlovise 
11 
in that telephone call? 
12 
A No. 
13 
Q How long did that telephone call last? 
14 
A I would say maybe five, 10 minutes. I was at 
15 
a store, Thad to go. 
16 
2 How did you learn or di 
ever learn that 
17 
M. went over to her home in 
18 
A 
Basically you told me. !had I10 idea. 
19 
Q 
So you had no idea — you had no idea up until 
20 
today's date? 
21 
A 
Yes, no idea. 
22 
Q Did Jane Doe or anyone ever tell you that I. 
23 
had some sort of experience with Mr. Epstein? 
24 
A No. 
25 
Q Did anyone ever tell you that.. ever gave 
Page 31 
1 
2 
A No. 
3 
Q How long were you friends with..? 
4 
A 
Well, I have known her — I met her when 1 was 
5 
likes and we hung out for a couple of years, and then 
6 
we just didn't hang out any more, so two years. 
7 
Q Pro sorry? 
8 
A Like two years. 
9 
Q 
So you knew her for two yews? 
10 
A 
Yeah. 
12 
tell you that she worked a 
Q 
And durittg that two- ear eriod, did she ever 
11 
13 
A 
No. 
14 
Q Did you ever come to learn at any 
even 
15 
up through today's date, that she worked at 
16 
A 
Yeah. 
17 
Q How did you learn that? 
18 
A 
Jane Doe. 
19 
Q 
What did Jane Doe tell you about that? 
20 
A 
She just told me she w 
21 
Q Did she tell you which 
22 
A No. 
23 
Q Did she tell you that 
ever worked at any 
?4 
jack shacks? 
A 
No. 
Page 33 
1 
Nix. Epstein massages in exchange for money? 
2 
A No. 
3 
Q Do you know whetbirar not, during the time 
4 
that you were friends withM. that she ever used 
5 
drugs? 
6 
A 
Marijuana. 
7 
Q 
And how old was she when she was using 
8 
marijuana? 
9 
A 
15,14. 
10 
Q Do you know whether or not she used marijuana 
11 
on a weekly basis or on a daily basis during that time? 
12 
A I think it was just like a weekend thing. 
13 
Q Do you know whether or not she ever did 
14 
Ecstasy? 
15 
A I have no idea. 
16 
Q 
What about 
do you know whether or not 
17 
she did Ecstasy? 
18 
A I have no idea. 
19 
Q 
And Jane Doe 6, do you know whether or not she 
20 
ever did Ecstasy? 
21 
A I don't think so. 
22 
Q 
Other than marijuana, are you aware at joy. 
23 
time, even up until today's date, whether or not EMI. 
24 
used any other drugs? 
25 
A No. 
9 (Pages 30 to 33) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden lIMM. 
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Page 34 
1 
Q 
No, you are not aware? 
2 
A 
No, I don't know. I'm not aware. 
3 
Q 
The last time you spoke with., which was 
4 
approximately two years ago, did she discuss whether or 
5 
not she was experiencing any emotional or traumatic 
6 
experiences in her life? 
7 
A 
No, sir. 
8 
Q 
Give me one second. 
9 
A 
Olcay 
10 
Q DWI... ever ask you to go to Mr. Epstein's 
11 
home? 
12 
A 
No. 
13 
Q 
Were you ever asked by anyone to go to 
1.4 
Mr. Epstein's home? 
15 
A 
Yes, by Jane Doe. 
16 
Q 
And wall. around at the time that Jane Doe 
17 
asked you that? 
18 
A 
No. 
19 
Q DidM. ever attempt to persuade you in any 
20 
way to go to Mr. Epstein's home? 
21 
A 
No. 
22 
Q 
Let's talk about Jane Doe. When was the first 
23 
time you came to know Jane Doe? 
24 
A 
25 
Q 
Did you guys live close to each other? 
1 
2 
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4. 
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Page 36 
BY MR. PIKE: 
Q 
You can answer. 
A 
Oh. 
Q 
And are 
u aware as to why
A 
or something along 
those lines. 
Now are ou aware as to whether or not he was 
A 
I think so. 
ai
d do you know the circumstances surrounding 
A 
No. 
Q 
Do you know whether or not Jane Doe witnessed 
an 
in related to that 
A 
I believe she was there when it happened. 
Q 
What, to you
ed? 
A 
I heard that and 
she 
woke up and he was 
Q 
And who was that, 
relative to 
Jane Doe? 
A 
Do 
u know whether or not her 
A I don't know. 
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2 
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!p 
Page 35 
A 
Q 
Would you consider yourselves to be best 
friends? 
A 
We were. 
Q 
So how lonuere you best friends? 
A 
Since i was. and then I moved here and we 
just don't talk too much any more. We don't talk any 
more, 
Q 
So is it a fair statement that you were best 
friends for approximately= years? 
A 
Yes. 
Q 
And that would be approximately from the time 
that you both were, up until the time that you were 
about. 
A 
Yeah. I would say 
Q 
And why aren't you best friends today? 
A 
Well, I would consider her my best friend but 
then we went separate ways. I moved here and !just 
haven't talked to her. Since I've moved here I have 
only talked to her a couple of times. 
Q 
I want to talk a little bit about Jane Doe and 
her childhood. What traumatic experiences are you aware 
of that she experienced in her childhood? 
MR. EDWARDS: I object to the form of the 
question. 
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Page 37 
Q 
Do oulmow what — did Jane Doe ever tell ou 
that her 
A 
No. 
Q 
Do you know whether or not lane Doe gave any 
itions related to 
A 
I think so. 
Se 
Do you know whether or not she lied for her 
in deposition? 
A 
I don't know. 
ME
Did she ever tell you that she lied for her 
in those depositions? 
A 
No, sir. 
• 
Do you know how old the 1, 
was that 
A 
I don't know. I'm not sure. 
Q 
You testified that 
as a 
result of this incident, as we speak today, correct? 
A 
Yes. • 
Q 
Do you know whether or not Jane Doe has a 
relationship with her 
today? 
A 
I don't know. 
Q 
D
o
i" 
know whether or not she has gone to 
visit 
in the last two years? 
10 (Pages 34 to 37) 
PROSE COURT REPORTING AGENCY,. INC. 
Beetronicany signed by Michelle Baden =EMS 
a53(10950-b535-4f4d-8f18-6434195ac559 
EFTA00724284

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Q 
Who is that? 
2 
A 
Her ex-boyfriend. 
3 
Q 
Do you know how long they dated for? 
4 
A 
I would say over a year. 
5 
Q 
And how old was Jane Doe when she started 
6 
dating Mr. a/ 
7 
A 
I would say 16 — no, 16, 17, maybe, yeah. 
8 
16, 17. 
9 
Q Ma
in know whether or not she had intercourse 
10 
with Mr.
during the time that she was dating
11 
him? . 
12. 
A 
Yes. 
13 
Q 
The answer is, yes, she did have intercourse? 
14 
A 
Yes. 
15
Q Dosi
row whether or not she ever gave oral 
16 
sex to Mr.
17 
A 
I don't know. 
18 
Q 
Did she ever discuss that with you? 
19 
A 
No. 
20 
Q 
Do you IcnoW whether or not Mr. 
21 
performed oral sex on her? 
• 
22 
A 
I don't know. 
23 
Q 
Did she ever discuss that with you? 
24 
A 
No. 
25 
Q 
Who else are you aware — actually, let's back 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A 
No. 
Q 
No, she has not or no you don't know? 
A 
No, I don't know. 
o lio 
you know whether or not her -
A 
I don't 'mow. I think so but I don't know for 
sure. il
Do you lmow, as 
u sit here today, what her 
may have 
A 
No. 
Q Do you know whether or not Jane Doe has a 
relationship with her father? 
A 
No. 
Do 
u know whether or not her father ever 
A !don't know. 
Q 
Did Jane Doe ever discuss with you her 
fathers MOM? 
A 
No. 
Q 
Did Jane Doe ever discuss with you her 
Page 38 
was ever 
father 
A 
No. 
Ali
o you know a gentleman by the name of IM 
A 
Yes. 
Page 40 
1 
up. Did you ever witness an
 or physical 
2 
altercations between Mr. 
and Jane Doe? 
3 
A 
No. 
4 
Q 
Do you Imo" whether or not Mr. 
ever 
5 
EJane Doe? 
6 
A 
No, I don't ;mow. 
7 
Q 
What other gentleman are you aware of that 
8 
Ms. Jane Doe dated, from age 13 up until today's date? 
9 
A 
Umm. 
10 
Q 
Let's start from the age 13 and move forward. 
11 
A 
Wow. Well, she dated — I don't know. The 
12 
people she dated was only for a little and I didn't 
13 
even — I don't know. Let's see. She dated. Oh, she 
14 
dated 
15 
Q 
How long did she date him for? 
16 
A 
Not too long, couple months. 
17 
told 
was she when she was dating 
18 
Mr. 
1919 
A 
14,13. 
20 
Q 
Did she have intercourse with Mr. IMF 
21. 
A 
Yes. 
22
Q Dost 
how many times she had intercourse 
23 
with Mr. 
24 
A 
No. 
25 
Q 
Do you know how many times she had intercourse 
Page 39 
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10 
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12 
13 
14 
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ever 
20 
21 
22 
23 
24 
Page 41 
with Mr.M? 
A 
No. 
Q 
Do 
know whether or not she performed oral 
sex on Mr. 
A 
I don't know. 
Q 
Do you know whether or not he performed oral 
sex on her? 
A 
I don't know. 
• 
Q 
How did you become aware that Jane Doe had 
intercourse with Mr. 
and Mr.M? 
A 
She told me but that's about it. No details. 
Q 
As you sit here today, do it inow whether or 
not she had intercourse with Mr.
 more than five 
times? 
A 
Probably. 
Q 
And, as you sit here today, do you know 
whether or not she had sexual. ntercourse with 
Mr. 
more than five times? 
A 
Probably. 
Q 
Dayou know whether or not she did any drugs 
with Mr. 
and Mr. a 
MR. EDWARDS: Object to form. 
THE WITNESS: Marijuana. 
BY MR. PIKE: . 
25 
Q 
So your testimony is that you have seen her do 
11 (Pages 38 to 41) 
PROSE COURT REPORTING AGENCY; INC.' . 
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Page 42 
marijuana with Mr. 
and Mr. IIIIP 
A 
Yeah. 
MR.. EDWARDS: Object to the form. 
BY MR. PIKE: 
Q 
Let me rephrase the question. Have you seen 
Jane Doe do marijuana with Mr. 
and Mr.
A 
Yes. 
Q 
And how old was she, approximately, when you 
witnessed these events? 
A 
14 and 16, roughly, yeah. 14, 16 
Q.o weve tented about Mr. 
and 
A Uh-huh. 
Q I want yoti to think a bit and tell me who else 
you can recall that Jane Doe dated? 
A 
Some kid namedMI. That was a long time 
ego and that only lasted for a little while. 
Q 
Do you know whether or not she had sexual 
intercourse with-? 
A No, I don't know. 
Q How long ago was it that she dated Mr. IM? 
A 
15. She was 15. 
Q Do you know how long she dated 
for? 
A Not long at all. 
Q Do you blow 
last name? 
Page 43 
1 
A 
No idea. Don't even !mow his real first name. 
2 
Q 
I figured that. Do you know who Jane Doe is 
3 
currently dating? 
4 
A 
Somebody named 
5 
Q Is that his real name? 
6' 
A 
I have no idea. 
7 
Q Do you 'mow whether or not they live together? 
8 
A 
I think so, yes. 
9 
Q 
Where does Jane Doe currently live, to your 
10 
Icnowleci 
11 
A 
12 
13 
wiQ 
Do 
know whether or not she still lives 
14 
A 
Yes. 
15 
Q 
And does Mr.. live there with them in that 
16 
residence? 
17 
A 
I'm not positive but as far as I know. 
18 
Q 
How did she meet Mr. In? 
19 
A 
No idea. 
20 
Q 
Do you know whether or not Mr. 
has 
21 
been — has ever been 
22 
23 
A 
I have no idea. 
14 
O 
Does Jane Doe ever tell you that Mr.Ill was 
25 
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2 
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Page 44
A 
No. 
MR. EDWARDS: Object to form. 
MR. PIKE: For the record, if the form is I 
don't mear~ 
THE WITNESS: Yeah. No. Since she's been 
withM, I haven't talked to her. 
BY MR. PIKE: 
Q 
And how long has it been since you've last 
spoken to Jane Doe? 
A 
I saw her whe 
Do ot ica
mi
whethex or not Jane Doe ever al 
A 
Yes. 
Q 
And how old was she when 
A 
The time I know about, I think, slue was 
St 
Okay. And what were the reasons why she • 
to your knowledge? 
A IfigrAtheYmellIIIIIIIIIIII 
Q 
What do you mean 
that?
A 
I don't knowl 
Q 
And when 
u set " 
who do ou mean? 
A 
Q And do you know wiry they were trying to 
Page 45 
MK 
in your words? 
A No. 
Q 
Have you ever heard of the tent 
A 
Yes. 
Q 
Were they trying to 
A 
I not sure. Might have, but I don't know. I 
was young too so I just — I don't know. 
Q 
And do you know, when sheMINIME 
A 
It was jus 
situation. 
Q 
Did Jane Doe eye 
period of time? 
A 
I mean, you could say 
We were Just always together. 
Q 
Let me try — was there a time that she ever 
due 
A 
She came to.. 
• ' 
Q 
And at that time were both of your parents 
or was it just one parent? 
and she didn't know the 
Or a 
to her 
A 
I would say a couple of dayilIMI with 
me. 
Q At the time that you testified that her 
parents were 
do you know whether 
12 (Pages 42 to 
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Electronically signed by Michelle Baden IIMM) 
853d0950-8535-O48-8118-6434195ac559 
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Page 46 
or not she was doing drugs or alcohol? 
A I don't think it was her 
trying to 
IIIIIIIthMkftwas 
But I don't think 
so. Maybe, if it was, marijuana. 
Q Do you know whether or not Jane Doe was ever 
arrested at any time? 
A I think 
Q 
What was she arrested for? 
A I think Mahe 
said. 
Q Do you know what she 
A No. 
Q Do you know whether or not Jane Doe was ever 
arrested for 
A No. 
Do ou know whether or not Jane Doe ever. 
A 
Oh, yes. Yes. 
Q How many times? 
A 
Q 
And was she arrested for that? 
A I believe so, now that you mention it. 
Q 
So there is another arrest that you weren't 
aware of, correct? 
A 
Well, now that you bring it up I'd say yes, I 
was aware of it, but I didn't even remember that. 
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Page 48 
hand jobs for mono 
a 
A No, sir. 
Have 
ever heard of the term of the 
A I have heard the term, yes. 
Do you know whether or not Jane Doe worked in 
A I don't know. 
Q 
Have you ever heard the term 
A No. 
Q 
Have you ever heard the tenni...? 
A 
Yes. 
Q Do 
you know whether or not Jane Doe ever gave 
to men in exchange for money? 
A I don't know. 
Q 
She never told you? 
A No. 
Q 
Okay. What did Jane Doe discuss with you 
about working at these two sIES, that you are 
aware of? 
A 
All she said is she works there. I don't talk 
to her much at all. I say, "Hey, what are you doing? 
She says, "Hey, I work hero," and I leave it like that 
because I don't want to know the details. 
Q 
Would she tell you how much money she made? 
Page 47 
1 
Q You understand you are under oath today, 
2 
correct? 
3 
A 
Yes, sir. 
4 
Q 
And that oath is for you to tell the truth? 
5 
A 
Yes. 
6 
Q 
So I'm going to ask you a question. I want 
7 
you to take some time and think about this question. 
8 
As you sit here today, having known Jane Doe 
9 
from the time that you were 13 up until todays date, 
10 
other than the two arrests that we have just discussed, 
11 
are you aware and do you recall any other arrests? 
12 
A No, sir. 
13 
Q Ares= 
whether or not Jane Doe ever 
14 
worked at
15 
A 
Yes. 
16 
Q 
Whs'
 arc you aware of that she 
17 
wonted at? 
18 
A 
19 
Q 
What others? 
20 
A 
I don't Icnow. 
21 
S
. But you are aware that there were other". 
22 
but you don't know the names; is that correct? 
23 
A 
I think one other one but J don't know the 
• 
24 
name. 
25 
Q 
Okay. Did Jane Doe tell you that she gave men 
25 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20. 
21 
22 
23 
24 
Page 49 
A No. 
Q Did she ever tell you that she sold her body 
for sex? 
A No. 
Q Back when you were 14 to 17, who did Jane Doe 
live with? 
A 
Q 
And where was her 
to your knowledge, 
at this time period? 
A At her house. 
Q 
When you say "her house" do you mean the 
house or a separate home? 
A No. A separate home. 
Q 
Why did lime Doe and her 
live apart? 
A 
They have never got along. I'm not sure the 
reason why they — she left but they have never got 
along, basically. 
Do you know whether or not Jane Doe has a. 
A No. 
Q Do you know whether or not 
married? 
A 
Oh, wait. Yes. I don't know if she's married 
but it's a guy named 
if I'm correct with the name. 
 
9 
Okay. Do pan, kno tv whether 
tu
fr2i
not 
la 7:e 
is 
13 (Pages 46 to 49' 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden IMES 
a53d0950-b535-414d-8118-6434195ac559 
EFTA00724287

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Page 50 
Doe had a relationship, good relationship? 
A 
1 dolt think they got along either. 
Q 
Do you know why? 
A 
No. I think he was just a mean guy. 
Q 
Did he ever do anything mean to Jane Doe? 
MR- EDWARDS: Object to the form. 
BY MR. PIKE: 
Q 
You said he was a mean guy, so I just want to 
know did he ever do anything mean to Jane Doe, to your 
knowledge? 
A 
No. Maybe just be an ass. Sorry for my 
language. 
Q 
Have you ever witnessed any altercations 
beriveen Jane Doe and her mother --
A 
No. 
Q 
-- between the ages of 13 and 17? 
A 
No. 
Q 
Do you know whether or not Jane Doe ever 
kick 
A 
No. 
Have 
u ever seen Jane Doe physically hurt 
A 
No. 
Have ou ever seen Jane Doe physically touch 
in an aperessive manner? 
Page 52 
1 
we were like 14, 15 and — yeah. 
2 
Q 
Hold on one second, please. 
3 
I want to backtrack a little bit We talked 
4 
about Mr. 
and Mr. 
and we talked about 
5 
and we talked about 
6 
A 
Uh-huh. 
7 
Q 
Having discussed them today, are you aware of 
8 
anyone else that she's dated? 
9 
A 
Off the top of my head, 1can't think of 
10 
anybody right now. I'm thinking but she was with --
11 
yeah, I think after 
yeah, after 
she was still 
12 
dating him when I moved to 
13 
Q 
And do you know whether or not Mr. 
14 
verbally and physically abusive to her? 
• 
15 
A 
I don't know. 
16 
MR. EDWARDS: Objection; form. 
17 
BY MR. PIKE: 
18 
Q 
You don't know? 
19 
A 
I don't ;mow. 
20 
Q 
Do you know whether or not Jane Doe has ever 
21 
tried cocaine? 
22 
A 
I third( -- yeah. 
23 
Q 
Do you know whether or not she's ever tried 
24 
Ecstasy? 
25 
A 
Yes. 
was 
Page 51 
1 
A 
No. 
2 
Have ou ever known Jane Doe to do drugs in 
3 
home? 
4 
A 
No. 
5 
Q 
As you sit here today, your testimony is that 
6 
do not know that Jane Doe has ever done drugs in her 
7 
home? 
8 
A 
Well, marijuana And that was when we were 
9 
like 15 
no, not even 15. 14, 13. 
10 
Q 
How many times? 
11 
A 
I don't know. More than once. Like four 
12 
times, couple times. 
13 
Q 
And who was with you guys at the time you were 
14 
doing marijuana? That is, who else was doing it with 
15 
you, if anyone? 
16 
A 
It was just us. 
17 
Q 
And back in those days, where would you 
18 
purchase the marijuana? 
19 
A 
I don't !mow. She gait. 
20 
Q 
Do you have any idea where she got it from? 
21 
A • No. We would just hang out after school. 
22 
Q 
Do you know whether or not 
23 
did not want her around because she worked at 
24 
and did drugs? 
.5 
A 
No. When -- last time I even heard about 
(....•••443•Jdnesaryi4a.an 
Page 53 
1 
Q 
Do you know whether or not she's ever tried 
2 
pain pills? 
3 
A 
No. 
4 
Q 
Do you Imow whether or not she's ever tried 
5 
methamphetamines? 
6 
A 
No. 
7 
Q 
How do yoti know she tried cocaine? 
8 
. A 
She told me. 
9 
Q 
How many tines? 
10 
A 
I'm not sure. Maybe a couple. 1 don't loww. 
11 
We were young. I don't know. 
12 
Q 
Do you know how many times she tried Ecstacy? 
13 
-A 
I don't blow. 
14 
Q 
Were you with her when she tried Ecstacy? 
15 
A 
Yeah. 
16 
Q 
All right. Where were you guys? 
17 
A 
Well, we were hanging outside and then we went 
18 
to my house. 
19 
Q 
So you guys were doing Ecstacy outside and at 
20 
your house? 
21 
A 
Yeah. 
22 
Q 
How many times did you do Ecstacy with her? 
23 
A . A couple. 
24 
Q 
Did you guys ever go to any raves? 
25 
A 
No. 
iarl
 
14 (Pages 50 to 53) 
'PROSE COURT REPORTING AGENCY, INC: 
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Page 54 
1 
Q 
Where did you do Etstacy? 
2. 
A 
We would take it and then we would go inside 
3 
and hide from my mother. 
4 
Q Did you purchase the Ecstacy? 
5 
A 
No. 
6 
Q 
Who got the Ecstacy for you? 
7 
A 
I'm not even sure. 
8 
Q Did Jane Doe get it? 
9 
A 
I don't know. Maybe. I don't know how we got 
10 
it. 
11 
Q Do you know whether or not Jane Doe has ever 
12 
done acid? 
13 
A 
I don't think so. 
14 
Q Do you ;mow whether or not Jane Does 
15 
was a serious 
user? 
16 
A I heard. did drugs. 
17 
MR. EDWARDS: Form. 
18 
BY MR. PIKE: 
19 
Q 
Let me rephrase thesestion. Do you know 
20 
whether or not Jane Doe's... ever did drugs? 
21 
A 
Yeah. 
22 
Q 
What do you know about that? 
23 
A 
I think Jane Doe said ■ 
24 
0 
Do you know for how ion 
25 
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 56 
Q 
Do you know where 
What 
I mean by that is state and county or just the county? 
A I just know 
Do you know how old Jane Doe was at the time 
she 
A 
Younger than 
Q 
Did she ever discuss that with ou? 
A 
She said she woke up and 
and that's all I know. 
Q Do you know whether or not that was 
psychologically impacting for her? 
MR. EDWARDS: Object to form. 
THE WITNESS: Probably. 
BY Mt. PIKE: 
Q 
And, once again, I'm just going to ask the 
question. Did she ever discuss the incident with you at 
all? 
A 
Yeah. 
Q 
And what did she discuss with youseparate and 
ai
m telling you that she woke up an' 
there? 
A 
Oh, well that's it. She said she woke up and 
there was MEN 
and said "Oh, m 
osh, look" or something and she looked 
up and sass 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
to, quote, 
19 
she currently lived in? 
20 
A 
No, I have no idea. 
21 
22 
A 
23 
Q 
And 
24 
25 
A 
I believe so. 
I'm not sure. 
What is her 
name? 
Oh, my gosh, leaf* even think of it right 
Is itelliffM? 
Yes. 
Do ou know Jane Doe's 
name? 
Page 55 
A 
Q 
now. 
Q 
A 
Q Do you know whether or not Jane Doe was ever 
forcibly taken from her home by her 
A 
I have no idea. 
Q 
Did you know whether or not her mother and her 
father had several physical fights in front of Jane Doe? 
A No. 
Do ou know whether or not there was any 
n Jane Doe's home? 
A 
No, I don't know. 
Q 
Do you know whether or not there was ever an 
incident back in 
where 
or Jane Doe threatened 
that 
as his 
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 57 
Q 
Is that it? 
A 
Yes, sir. 
Q Let me ask you this question. Did she ever 
tell you that 
and that her 
was 
becoming angry as a result of that? 
A 
No. 
Sr 
Did Jane Doe ever tell ou that she saw that 
was not 
that evening and that 
she went to he 
tell him the 
same? 
A 
No. 
Q Did Jane Doe ever discuss with you the to
statement that she gave to
n or around ME 
A No, sir. 
Q Do you know whether or not Jane Doe ever 
testified that helIMIMIMIIMI 
A I know she testified but I have no idea what 
happened. 
Do ou know whether or not her 
laxly? 
ever 
A No. I don't know. 
Did Jane Doe ever tell you that her 
'7 
A 
No. 
15 (Pages 54 to 57) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden Mlle 
a53d0950-b535-414d-8f18-6434195ac559 
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Page 58 
Q 
You testified earlier that you know of the 
name Jeffrey Epstein, correct? 
A 
Yes. 
Q 
And do you know whether or not Jane Doe had 
any dealings with Mr. Epstein? 
A 
Yeah. 
Q 
And what are you aware of? 
A 
I'm aware that she went to his house by taxi 
and went there and massaged him naked for money. 
Q 
And when you say she was naked, can you 
explain that for me? And what I mean is did she have 
her panties on and her bra off or everything off? 
A 
I heard everything. 
MR. EDWARDS: Object to the form of the 
question. 
BY MR. PIKE: 
Q 
Ybu can answer. What do you mean by "naked"? 
A 
No clothes. 
Q 
What else did she, Jane Doe, tell you about 
having gone to Mr. Epstein's house? 
A 
That there were other girls there and that's 
it. 
Q 
Did Jane Doe tell you how many times she went 
to Mr. Epstein's home? 
A 
I don't know. All I !mow of is like two 
Page 60 
1 
A 
No, sir. 
2 
Q 
Did she seem happy about receiving the money? 
3 
A 
I don't know. I don't even think i was there 
4 
when — she wasn't even around when she got the money. 
5 
I have never even physically seen money. 
6 
• Q 
Did she ever seem upset about going 
7 
Mr. Epstein's home? 
8 
A 
Well, she wasn't with me when she went. She 
9 
just told me, so I wasn't even around her. 
10 
Q 
When she told you, did she seem upset? 
11 
A 
Maybe a little, but I don't know. She just 
1 2 
told me she went and that's it. 
13 
Q 
Was she crying when she told you this? 
14 
A 
No. 
15 
Q 
Did she ever seem emotionally disturbed as a 
16 
result of going to Mr. Epstein's home, to your 
17 
knowledge? 
18 
A 
Not to my knowledge. 
19 
Q Did she seem to be under any emotional 
20 
distress as a result of going to Mr. Epstein's home? 
21 
MR. EDWARDS: Object to form. 
22 
THE WITNESS: Not to my knowledge. 
23 
BY MR. PIKE: 
24 
Q 
Do you know whether or not Jane Doe attempted 
25 
to reauit other girls to allegedly go to Mr. Epstein's 
Page 59 
1 
times, three times. 
2 
Q 
And other than giving him a massage, did Jane 
3 
Doe say she would do anything else for Mr. Epstein? 
4 
A 
No, sir. 
5 
MR. EDWARDS: Object to the form. 
6 
THE WITNESS: No, sir. 
7 
BY MR. PIKE: 
8 
Q Did Jane Doe ever tell you that Mr. Epstein 
9 
forced her to do anything inappropriate? 
10 
A 
No, sir. 
11 
MR. EDWARDS: Object to the form. 
12 
MR. PIKE: You didn't like that answer, did 
13 
you, Brad? 
14 
MR. EDWARDS: I didn't like your question. 
15 
BY MR. PIKE: 
16 
Q 
Did Jane Doe ever all you that Mr. Epstein 
17 
forced her to do anything? 
18 
A 
No. 
19 
Q 
Did Jane Doe tell you that she gave 
20 
Mr. Epstein a massage in exchange for money? 
21 
A 
Yes. 
22 
Q 
What did she tell you, just that? 
23 
A 
Yes. 
24 
Q 
Do you know how much she claims Mr. Epstein 
25 
gave you? 
Page 
1 
home? 
2 
A 
She asked me and that is all I 'mow. 
3 
Q 
And at that time you were her best friend, 
4 
correct? 
5 
A 
Correct 
6 
Q 
And what did you say when she asked you to go 
7 
to Mr. Epstein's home. 
8 
A 
Absolutely not. 
9 
Q 
Okay. And why did you make that decision? 
10 
A 
Because I would never do that or put myself in 
11 
a position to do anything like that. 
12 
Q 
Did she tell you what she did for Mr. Epstein 
13 
when she made this offer for you to go to his home? 
14 
A .Yeah, I Ian the circumstances. 
15 
Q 
Explain to me how you understood the 
16 
circumstances at that time? 
17 
A 
Well, she told me she would massage him naked 
18 
and I said, "Pm never going. 1 would never do that" 
19 
Q 
Did she ever say that she touched his penis? 
20 
A 
No. 
21 
Q 
And where would she massage him, to your 
22 
knowledge? 
23 
A 
In atom. 
24 
Q 
Ina room? 
25 
A 
Yeah. 
?1,1UNSOAEAredites.... .....00,4•4•4 
16 (Pages 58 to 61) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden MIMI 
a53d0250-b535-414d-M18-6434195ac559 
EFTA00724290

Page 62 
1 
Q 
What body parts did she touch, to your 
2 
knovdedge, if at all? 
3 
A 
I don't know if she touched anything. I don't 
4 
know anything like that 
5 
Q 
So, to your knowledge, the massage was just a 
6 
regular massage but naked? 
7 
A 
Yes. To my knowledge, yes. 
8 
Q 
Do you know whether or not Mr. Epstein ever 
9 
touched her in a sexual nature? 
10 
A 
I have no idea. 
11 
Q 
Did she ever tell you that Mr. Epstein 
12 
masturbated during any one of these alleged massages? 
13. 
A 
Yes. 
14 
Q 
What did she tell you? 
15 
A 
She said he masturbated while she massaged him 
16 
or something. 
17 
Q 
And when she told you this, was she laughing? 
18 
A 
No. 
19 
Q 
Was she crying? 
20 
A 
No. 
21 
Q 
Did she seem depressed? 
22 
A 
No. 
23 
Q 
How much money did she tell you she received 
24 
as a result of this massage? 
25 
A 
She never told me money amount. 
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 64 
Q 
You can answer the miestion, if you recall. 
A 
I don't know about every day. I don't !mow 
about every day. 
Q 
What about every other day, do you have any 
knowledge as to that? 
A 
No. 
Q 
Have you ever done cocaine with Jane Doe? 
A 
Yes. 
Q 
And where did you do cocaine with Jane Doe 
venue-wise? Where was the location? 
A 
My house hiding from my mother. 
Q 
And did ou ever do cocaine with Jane Doe at 
Jane Doe's 
house? 
A 
No, sir. 
Q 
How many times did you do cocaine with Jane 
Doe? 
A 
I don't know. More than once. 
Q 
More than five times? 
A 
No. She stopped. She didn't like it anymore. 
Q 
After she stopped using cocaine, what other 
drugs, if any, did she continue to use? 
A 
I don't think any. Just marijuana, I think, 
if that 
Q 
Did she ever tell you that Mr. Epstein 
threatened or intimidated her for any reason? 
Page 63 
1 
Q 
So when she told you that she would give 
2 
Mr. Epstein a massage naked and she invited you to come 
3 
with her, she didn't tell you how much money you could 
4 
make? 
5 
A 
No, because I basically wanted to end the 
6 
conversation because I don't want to hear about that. 
7 
Q 
Do you know whether or not Jane Doe recruited 
8 
any other girls? 
9 
A 
I don't know. 
10 
Q 
Do you know whether or not Jane Doe and 
11 
worked at the same 
12 
A 
I don't know. 
13 
Q 
Do you know whether or not Jane Doe's drug use 
14 
affected her memory? 
15 
A I don't blow. 
16 
Q 
I'll have ou assume that Jane Doe testified 
17 
that sh
un an every-day basis. Does that 
18 
refresh our recollection as to whether or not Jane Doe 
19 
n an every-day basis? 
20 
MR. EDWARDS: Object to the form as it 
21 
completely mischaracterizes the witness' testimony. 
22 
If this witness Is going to be basing her answer on 
23 
a hypothetical then Pm going to object to all of 
24 
those questions. 
.5 
BY MR. PIKE: 
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 65 
A 
No, sir. 
Q 
Did she ever tell you that Mr. Epstein forced 
her to do anything? 
A 
No. 
Q 
When she discussed having you potentially come 
over to Mr. Epstein's home, did she tell you you would 
have to lie about your age? 
A 
No. 
Q 
Did she discuss anything about your quote, 
age? 
A 
No. 
Q 
Do you know whether or not Jane Doe was seeing 
a psychologist or a counselor between the ages Aland 
today's date? 
A 
Maybe a counselor, but I don't know. 
Q 
Have you ever heard the tenn 
A 
Yes. 
Q 
How did you come to learn about that term? 
A 
TV, just learning it. 
Qail
mm
i
t
ane Doe ever tell ou that she suffered 
froci 
A 
No. 
Q 
Did Jane Doe ever tell you that she had any 
emotional disorders? 
17 (Pages 62 to 65) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden IMIEM 
aS3d0950-b535-414d-8118-6434195ac559 
EFTA00724291

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15. 
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17 
18 
19 
Does that refresh your recollection? 
20 
A 
I have no idea. 
21 
Do you know whether or not Jane Doe was ever 
22 
23 
A 
No. 
24 
Q 
Other than the individuals we've discussed 
15 
today, are you aware of anyone else that allegedly went 
1 
3 
4 
5 
6 
8 
10 
11 
12 
13 
14 
15 • 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 66 
A 
No. 
Q 
Did Jane Doe ever tell you that she had any 
emotional problems? 
A 
I mean, her life has been crazy. Her whole 
life, so 
Q 
And what do you mean by that, if you could be 
a little more specific? 
A 
I mean, *ust her growiad 
then the stuff 
with 
oing on and 
i
has nothing to do 
with her. The only person that cares for her is her 
=I, 
so, I don't know. 
Q 
Have you 'mown Jane Doe since you were. 
A 
Yes. 
Q 
Did you see any emotional change or emotional 
distress after you learned that Jane Doe was going to 
Mr. Epatein's home? 
A 
No. 
Q 
Do you know whether or not Jane Doe worked at 
A 
I believe she might have mentioned that one, 
the MMIIM 
kind of rings a bell but I'm not sure. 
.1.3o 
you know whether or not she ever worked at 
A 
I have no idea. 
Q 
What about 
Page 68 
1 
to Mr. Epstein's home? 
2 
A 
No, sir. 
3 
Q 
Give me one second. When was the last time 
4 
you talked to Jane Doe? 
5 
A 
Last time I talked to her is when sant. 
6 
came to serve me these papers and I was i 
and 
7 
I called her and I asked why they were giving me papers. 
8 
Q 
And what did she tell you? 
9 
A 
She told me because I was her friend and they 
10 
wanted to ask me questions. 
11 
Q 
Have you ever been contacted by any 
12 
investigators to discuss this matter? 
13 
A 
No, sir. 
14 - 
Q 
Have you been contacted by any lawyers at any 
15 
time to discuss this matter? 
16 
A 
No. 
17 
Q 
Has Mr. Edwards ever talked with you over the 
18 
phone or in person? 
19 
A 
No. 
20 
Q 
Has anyone by the name of Stuart Mermelstein, 
21 
Adam Horowitz or Jessica Arbor (phonetic) ever talked to 
22 
you over the phone or face to face? 
23 
A 
No. 
24 
Q 
Tell me exactly — understanding that you're 
25 
under oath, tell me exactly, ma'am, what Jane Doe talked 
Page 67 
1 
A 
I have no idea. 
2 
Q 
What abo 
3 
A 
No idea. The only one I ;mow is liken 
4 
5 
Q 
Do you know whether or not Jane Doe's uncle 
6 
took her to Mr. Epstein's home? 
7 
A 
I have no idea. 
8 
Q 
You said that you learned that Jane Doe went 
9 
to Mr. Epstein's home by cab? 
A 
Yes. 
Q 
How did you learn that? 
A 
She told me. 
Q 
And did she tell you how many times she went 
to Mr. Epstein's home by cab? 
A 
No, sir. 
Q 
Do you know whether or not it was ever 
to the police that Jane Doe 
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 69 
with you about relative to this case at any time? 
A 
Okay. She told me she would get in a cab and 
go to Palm Beach. There would be other girls at the 
house, and she would go in a room and massage him naked 
and he would give her money and she would leave. And 
that's all 1 know. 
Q 
Did she tell you that she filed a lawsuit 
against Mr. Epstein? 
A 
Yes. 
Q 
What did she tell you about that? 
A 
That's it. Just ended it right there at that. 
Q 
Did she tell you that she wanted to file a 
lawsuit or that she was convinced by lawyers to file a 
lawsuit? 
A 
She just said there was a lawsuit and that's 
all! know. Like I haven't talk to her. 
Q 
Have you talked to anyone, other than Jane Doe 
about this lawsuit? 
A 
I briefly scanned over to my family but not 
giving details, just because they asked why I was 
getting served papers. 
Q 
Let's talk about you for a minute. Have you 
ever been arrested? 
A 
No, sir. 
Q 
Have you ever been charged with a crime? 
18 (Pages 66 to 69, 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by Michelle Baden a 
aS3d0950-b5354f4d-8118-6434195ac559 
EFTA00724292

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Page 70 
A No. 
Q Have you ever been detained by a police 
officer? 
A No, sir. 
Q Have you ever worked at any strip clubs? 
A No. 
Q 
What about jack shacks? 
A No. 
Q Have you ever sold your body for sex? 
A No. 
Q 
Has anyone offered you any money in this case 
relative to your testimony today? 
A No. Well, I have a $45 witness fee. That's 
it. 
Q Thank you. 
A I just looked over to that. 
Q 
When you spoke to Jane Doe 6, did Jane Doe 6 
tell you that she was assaulted or humiliated by 
Jeffrey Epstein? 
MR. MERMELSTEIN: Objection to form. 
THE WITNESS: No. 
BY MR. PIKE: 
Q Did she ever tell you that? 
A Na 
Q 
Give me one second. 
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Page 72 
I was liken and I haven't talked to her probably 
since then. 
Did ou talk with her at all while she was in 
A No. 
Q Do you know whether or not 
does drugs or 
not? 
A I have no idea. 
• 
Q 
When is the last time you s eke to her? 
A 
Probabl when I w 
lik 
Maybe like 
see her 
be like
"Hp, 
Q 
What reputation, if any, do you recall her 
having in middle school? 
A 'don't know. She was a good kid. 
Q Do you recall any of her boyfriends in middle 
school? 
A No. 
Q Do you know whether or not she had intercourse 
while she was in middle school? 
A I have no idea. 
Q 
Okay. I have no further questions. 
MR. EDWARDS: All right. I have a few. 
EXAMINATION 
BY MR. EDWARDS: 
Page 71 
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A 
Okay. 
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Q Let me ask you this: What was -- if you 
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recall, what was Jane Doe's reputation in high school? 
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A 
She never went to high school with me. 
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Q Do you know what her reputation was though? 
6 
A No. 
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Q 
Was she ever referred to as a girl that was 
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easy to get sex from? 
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A No. 
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Q 
What about Jane Doe 6? 
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A No. 
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Q 
What about...? 
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A I don't know. I don't even know her but no, I 
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haven't heard anythirs_. 
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Q 
What aboutM., to your knowledge, has her 
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reputation ever been to be an easy girl? 
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A No, not when I knew her. 
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Q Tell me about., what do you know about 
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her? 
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A 
Thad no idea she was even in this case, but I 
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A 
Absolute nothing. !just know her from 
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. She use to come to my birthdays when 
went t. 
with her. 
Q Tell me what you know about her, other than 
Page 73 
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Q Melissa, this is Brad Edwards and I represent 
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Jane Doe and I also reportlill. and.. 
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A 
Uh-huh. 
4 
Q My question is do you know how many girls 
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Jeffrey Epstein has molested? 
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A I have no idea. 
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MR. PIKE: Object to forth on that. 
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Hey, let's do the court reporter a favor. 
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Let's kind of slow down the question and answer so I 
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can get a "coml." in. 
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MR. EDWARDS: I'll just assume you are going 
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to object to the form of every one of my questions 
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consistent with form. 
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MR. PIKE: I agree, I probably will. If the 
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court reporter doesn't hear it, then madam court 
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reporter let's put a form objection in there for 
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each of his objections, but twill put one on the 
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record as well. Okay. 
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BY MR. EDWARDS: 
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Q 
Melissa, do you know how many underage females 
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that Jeffrey Epstein has performed oral sex on? 
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MR. PIKE: Form. 
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THE WITNESS: I have no idea. 
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BY MR. EDWARDS: 
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Q Do you know whether Jeffrey Epstein has 
19 (Pages 70 to 73) 
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