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FBI VOL00009
EFTA00725643
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15 should have your lawyer, yeah. 16 THE WITNESS: Yeah, I have a lawyer. 17 BY MR. LUTTIER: 18 Q. Who is our lawyer? 19 A. (phonetic). 20 Q. Okay. When you say he's not charging me, 21 he didn't go get an injunction against -- 22 A No. 23 Q -- domestic violence against you? 24 A. No. 25 Q. While we're speaking about injunctions 0349 1 against domestic violence, let me get you something. 2 A. I mean, what is that? I don't know. 3 MR. MERMELSTEIN: Let him follow up and 4 ask a question. 5 MR. LUTTIER: Is this Exhibit 3? 6 THE COURT REPORTER: Yes. 7 MR. LUTTIER: Let me just -- 8 (Defendant's Exhibit No. 3 was marked for 9 identification.) 10 BY MR. LUTTIER: 11 Q. Let me show you what has been marked as 12 Exhibit 3 which purports to be a Petition for 13 Injunction for a Protection Against Dating Violence. 14 And referring to the first page, it says, I, full 15 name, Jane Doe No. 4, do you see the first page? 16 A. Yeah. 17 Q. All right. Is this, is this handwriting 18 on here yours? 19 A. Yeah. 20 Q. Let's go to the second page. Is this your 21 handwriting? 22 A. Yeah. 23 Q. Third page your handwriting? 24 A. Yeah. 25 Q. Fourth page? 0350 1 A. Yeah. 2 Q. Fifth page? 3 A. Yeah. 4 Q. Okay. So did you complete this whole 5 form? 6 A. Yeah. 7 Q. And was it true and correct when you 8 completed it? 9 A. Yeah. 10 Q. Those were the representations you were 11 making to The Court, right? 12 A. Yeah. 13 Q. And then you had a hearing? You went to 14 court? 15 A. Yeah. 16 Q. And was there at court, 9 file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM! EFTA00725663
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17 A. I don't remember. 18 Q. And you got an order that for a year, that 19 was an injunction against domestic violence against 20 him, correct? 21 A. Yeah. 22 Q. So he couldn't come around you for a year; 23 isn't that right? 24 A. Yeah. 25 Q. Okay. Let's take a look at Page 2, 0351 1 Section 1. It says down here in section, section 2 Roman Numeral III, No. 1, where it sayscSibe 3 the nature of your relationship. It says, 4 relationship began. That was 6 riting 5 to the court that our relationshi with began correct? 7 A. Yeah. 8 Q. And then you wrote, 9 relationship became intimate. That is ou were 10 writing to the court that on your 11 relationship with became intimate, 12 right? 13 A. Yeah. 14 Q. That's a specific date, 15 A. Uh-huh. 16 Q. Well, what did you mean when you say, 17 relationship became intimate? 18 A. I don't know. Kissing, I'm going to say. 19 I mean, kissing, holding hands, like, cuddling. I 20 don't know. 21 Q. Well, what you meant when you wrote this 22 was you were having sexual relations with him -- 23 MR. MERMELSTEIN: Objection to form, 24 argumentative. 25 THE WITNESS: I don't remember. 0352 1 BY MR. LUTTIER: 2 Q. Is that true or false? 3 A. Yeah. 4 Q. Okay. So as of you had 5 sexual relations with correct? 6 A. No. I don't remember. No. 7 Q. Well, why did you write on here intimate? 8 A. Intimate -- 9 MR. MERMELSTEIN: Objection, asked and 10 answered. 11 THE WITNESS: Intimate, I mean, intimate 12 can mean anything, like holding hands. When 13 I'm intimate with somebody that means, I mean, 14 anybody. I mean, it's not like, it's not sex. 15 I don't see where it says, oh, I became -- had 16 started having sex with him. At that time I 17 was 15, so intimate meant making out in the 18 movies. file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM! EFTA00725664
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19 BY MR. LUTTIER: 20 Q. Now, do you recall previously you 21 testified that about four or five months after you 22 first dated you began having sexual 23 relations with him? 24 A. What? Repeat that. 25 Q. Do you remember earlier you testified that 0353 1 about four or five months after you began dating 2 you had sexual relations with him? 3 A. Yeah, about four or five months. 4 Q. So that would be about the same as this 5 time period here from wouldn't 6 it? 7 A. Yeah, but, I mean, intimate, like, to me, 8 when I was that young, intimate, like, meant like 9 going to the movies and making out with your 10 boyfriend in the movie theater. Intimate to me back 11 then wasn't sexual intercourse. 12 Q. Okay. I just want to make sure we're 13 clear. I want you to tell the ladies and gentlemen 14 of the jury in that camera that when you filled this 15 form out that's been marked as Exhibit 3, and you 16 wrote , relationship became intimate, 17 that you didn't mean sexual intercourse. Is that 18 right? 19 MR. MERMELSTEIN: Objection to form. 20 BY MR. LUTTIER: 21 Q. Tell the ladies and the gentlemen of the 22 jury that's not what you meant. 23 MR. MERMELSTEIN: Objection to the form 24 again. Go ahead. 25 THE WITNESS: Yeah, that's not what I 0354 1 meant. 2 BY MR. LUTTIER: 6 7 8 9 10 11 12 13 14 15 16 17 1 18 20 A. That what? 3 Q. Not what you meant. Now, when we ask your 4 mom what you meant, what's she going to say? 5 MR. MERMELSTEIN: Objection to form. That's speculative. THE WITNESS: I don't know. BY MR. LUTTIER: MR. MERMELSTEIN: Speculative. Objection. MR. LUTTIER: Can we agree -- THE WITNESS: Is that a question? BY MR. LUTHER: Q. MR. MERMELSTEIN: I think it was. BY MR. LUTHER: file:///q/Documents%20and%20Senings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PMl EFTA00725665
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21 22 23 MR. MERMELSTEIN: Objection, 24 argumentative. 25 THE WITNESS: Yeah. 0355 1 BY MR. LUTTIER: 2 • All right. So tell me, if 3 wasn't when you started having sexual 4 relationships with him, or sexual relations, when 5 did you start having a sexual relationship with him? 6 THE WITNESS: I don't remember. 7 MR. MERMELSTEIN: Objection, asked and 8 answered. 9 BY MR. LUTTIER: 10 Q. When was the first time you gave him oral 11 sex? 12 A. I don't remember. 13 Q. When was the first time he stuck his penis 14 in you and ejaculated? 15 A. I don't remember. 16 Q. Was it a significant event -- 17 A. Was that even a question? 18 Q. Yeah. 19 A. What did you say? 20 Q. When -- 21 A. Can you repeat that question? 22 Q. When did he stick his penis in you and 23 ejaculate -- 24 A. I don't remember. 25 Q. -- in any orifice? 0356 1 A. I don't remember. 2 MR. MERMELSTEIN: Objection. 3 BY MR. LUTTIER: 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 . First it says, respondent, that 20 means right? 21 A. Hold on. I'm not following what page 22 you're on. Objection to form. MR. MERMELSTEIN: BY MR. LUTTIER: Q. Can we agree with that? A. Yeah. Q. So, you still want to stand on your answer to the jury that when you said, became intimate, you weren't referring to sexual intercourse? MR. MERMELSTEIN: Objection to form. THE WITNESS: Yeah. BY MR. LUTTIER: Q. Okay. Now, let's go to Paragraph 6, the next page. Can you read out loud what ou told the court occurred on at. file:///q/Doctiments%20and%20Settings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725666
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23 Q. Paragraph 6, Page 3. This is in your 24 handwriting, right? 25 A. (No verbal response.) 0357 1 Q. Correct? 2 A. Uh-huh. 3 . All ri ht. It says, respondent; that's 4 right? 5 A. Uh-huh. 6 Q. Now, read to the ladies and entlemen of 7 the you wrote occurred on 8 with Mr. 9 A. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q. And then did you continue it onto the next 25 page? 0358 1 A. We were -- 2 Q. No, onto the next page. Turn onto what's 3 called a continuation. What else did you write? 4 A 5 6 7 8 9 10 11 12 13 14 15 Q. He humiliated you o 16 didn't he? 17 MR. MERMELSTEIN: Objection to form. 18 THE WITNESS: Humiliated me in front of -- 19 BY MR. LUTTIER: 20 Q. He humiliated you, didn't he? 21 MR. MERMELSTEIN: Objection to form again. 22 THE WITNESS: For what? Is that your -- 23 BY MR. LUTTIER: 24 Q. Do you know -- file:///q/Documents%20and%20Seitings/Production/Desktop/Doe%20No.%204.1620Jane%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 P141 EFTA00725667
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25 A. Is that your opinion? 0359 1 Q. Do you know what humiliation is? 2 A. Is that your -- 3 Q. Yes. 4 A. Yeah, I do, but in, in front of who? 5 Q What -- 6 A Like humiliation is humiliating in front 7 of a crowd of people. 8 MR. MERMELSTEIN: Don't argue with him. 9 Just, just answer. 10 BY MR. LUTTIER: 11 Q. Just humiliate. To yourself, what's 12 humiliate mean to you? 13 A. Yeah, embarrassing. 14 Q. Is that all it means? 15 A. Yeah. 16 Q. I mean, he treated you worse than an 17 animal, didn't he? 18 MR. MERMELSTEIN: Objection to form, 19 argumentative. 20 THE WITNESS: An animal? 21 BY MR. LUTTIER: 22 Q. Would you treat a dog like this? 23 MR. MERMELSTEIN: Objection to form. 24 THE WITNESS: No. 25 0360 1 BY MR. LUTTIER: 2 Q. No human being ought to be treated like 3 this, should they? 4 A. No. 5 MR. MERMELSTEIN: Objection to form. 6 BY MR. LUTTIER: 7 Q. So, were you humiliated by his -- 8 A. Yeah. 9 Q. -- conduct toward you? Did it make you 10 feel bad? 11 A. Of course. 12 Q. Did it make you feel low? 13 MR. MERMELSTEIN: Objection to form. 14 THE WITNESS: Yeah. 15 BY MR. LUTTIER: 16 Q. Did it make you feel like you were 17 worthless? 18 MR. MERMELSTEIN: Objection to form. 19 THE WITNESS: Yeah. 20 BY MR. LUTTIER: 21 Q. Did it make you feel so bad that you went 22 and got a court order that said he couldn't come 23 near you for a year? 24 A. Yeah. 25 Q. Jeffrey Epstein never made you feel like 0361 file:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PMl EFTA00725668
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1 that, did he? 2 A. No, but just a lot worse. 3 Q. He was nice to you, wasn't he? 4 A. Yeah, really nice. 5 Q. And by the way, did you -- did you ever 6 touch Mr. Epstein's penis? 7 A. No. 8 Q. You had seen a man's penis before you went 9 to Jeffrey Epstein the first time, hadn't you? 10 A. Yes. 11 Q. Matter of fact, had you touched a man's 12 penis before you went to Jeffrey Epstein? 13 A. I don't remember. 14 Q. Had you placed a man's penis in your mouth 15 before you had gone to see Jeffrey Epstein? 16 A. I don't remember. 17 Q. Had you placed a man's penis in your 18 vagina before you went to Jeffrey Epstein? 19 A. I don't remember. 20 . When you made the videotape of you and 21 having sexual relations, what acts were 22 recorded on the videotape? 23 A. On the tape? 24 Q. Yeah. The tape -- 25 A. Sex. 0362 1 Q. -- you made. And you made that tape, 2 right? 3 A. Yeah. 4 Q. 5 A. 6 7 8 9 10 I. 11 12 A. 13 Q. 14 A. 15 Q. 16 A. 17 Q. 18 A. 19 Q. And how old were you at the time? 20 A. I don't remember. 21 Q. Sixteen? 22 A. I don't remember. 23 Q. Seventeen? 24 A. I don't remember. 25 Q. No more than 17, right? 0363 1 A. I don't remember. 2 Q. But you remember whether you were older Q. A. Q. file:///q/Documents%20and%20Seitings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725669
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3 than 17, don't you? 4 A. No. I don't remember. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0364 1 2 3 4 5 6 MR. MERMELSTEIN: 7 BY MR. LUTHER: 8 Q. Tell the ladies and gentlemen, look in the 9 camera and tell the ladies and gentlemen of the jury 10 you don't know if you were in high school when you 11 made this tape. 12 MR. MERMELSTEIN: Objection to form, 13 argumentative. 14 THE WITNESS: I was in high school when I 15 made this with 16 BY MR. LUTHER: 17 Q. Okay. All right. Way too young to be 18 doing this kind of stuff, right? 19 MR. MERMELSTEIN: Objection to form, 20 argumentative. 21 BY MR. LUTTIER: 22 Q. Right? Do you agree with me? 23 A. Yeah. 24 MR. MERMELSTEIN: Objection. 25 0365 1 BY MR. LUTHER: 2 . All ri ht. 3 4 A. A. Q. A. I don't remember. I don't remember when, and when, I am -- like you already stated, I have been -- Q. Okay. Did you -- MR. MERMELSTEIN: You're okay. You're doing fine. BY MR. LUTHER: MR. MERMELSTEIN: Objection to form. THE WITNESS: I don't remember. BY MR. LUTHER: A. Yes. Objection to form. 11 le:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725670
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6 7 8 9 10 11 12 13 14 15 16 17 18 MR. MERMELSTEIN: You know, I'm going to 19 object to that, again Rule 412, and ask you not 20 to -- It's just going too far. 21 MR. LUTTIER: Well, this is a videotape 22 that she admitted she showed Mr. Epstein, so -- 23 MR. MERMELSTEIN: Yeah, but you're -- 24 MR. LUTHER: -- it's clear -- 25 MR. MERMELSTEIN: -- asking her to 0366 1 describe the acts -- 2 MR. LUTTIER: Yeah. 3 MR. MERMELSTEIN: -- on the videotape? 4 MR. LUTTIER: It's clear. It's within the 5 gambit. We're coming back. And I mean, I am 6 not going to argue, but I mean you're going 7 to -- we're going to come for fees and costs, 8 because there isn't any question about whether 9 that's a legitimate area of inquiry. So I 10 would respectfully suggest you rethink your 11 position on that. 12 MR. MERMELSTEIN: You're asking her what 13 was on the videotape in terms of sex acts. 14 MR. LUTTIER: You bet. You bet. The tape 15 that she showed Jeffrey Epstein. And there is 16 no question about whether that's fair game. 17 MR. MERMELSTEIN: I'm going to give you a 18 little bit of leeway. 19 MR. LUTTIER: Okay, fair enough. 20 THE WITNESS: Of us having sex. 21 BY MR. LUTTIER: 22 Q. I want to know the specific acts. Did it 23 reflect oral sex? 24 A. Sure. 25 Q. Were you, did it reflect you having 0367 1 penis in your mouth? 2 A. Yeah. 3 Q. Were you giving him what we would -- a 4 typical vernacular, that would be giving him a head 5 job, right? 6 MR. MERMELSTEIN: Come on. I mean, come 5 Q. A. Yeah Q. A. Yes. Q. file:///CVDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725671
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7 on. She just -- 8 BY MR. LUTTIER: 9 Q. -- in the slang? 10 MR. MERMELSTEIN: There is no need to go 11 to slang. She just told you what they -- 12 BY MR. LUTTIER: 13 Q. Did it -- did it show him licking your 14 vagina? 15 A. Yeah. 16 Q. Did, did he ejaculate in your mouth? 17 A. I don't remember. 18 Q. Did it show that on the tape? 19 A. I don't remember. 20 Q. Do you recall him ever ejaculating in your 21 mouth? 22 A. Ever? What does that have to do with the 23 tape? 24 Q. Ever. Ever. 25 MR. MERMELSTEIN: Okay. Ever, whether 0368 1 it's on the tape or not? 2 MR. LUTTIER: Any time. 3 MR. MERMELSTEIN: Okay. Don't answer that 4 question. Rule 412. 5 BY MR. LUTTIER: 6 Q. Did it -- did he insert his penis in your 7 vagina on this tape? 8 A. Yeah. 9 Q. And what position were you in at the time? 10 A. I don't know. I don't remember. 11 Q. Do you remember being on all -- what they 12 call all fours? 13 A. Could have been on all fours. Could have 14 been on my back. I don't remember. 15 Q. And, and other than him inserting his 16 penis in your vagina and in your mouth, did he 17 insert his penis in any other orifice of yours? 18 A. No. 19 Q. And did you perform any other sex acts on 20 him other than giving him oral sex on this tape? 21 A. No. 22 Q. What -- is there anything else depicted on 23 this tape? 24 A. No, not that I -- 25 MR. MERMELSTEIN: Objection to form, 0369 1 overbroad. 2 THE WITNESS: Not that I remember, no. 3 BY MR. LUTHER: 4 5 6 7 8 A. Yeah. 11 le:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725672
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9 Q. Was there anybody else that you showed the 10 tape to? 11 A. No. 12 Q. Show it to any of your girlfriends? 13 A. No. 14 Q. Was there anybody else present when you 15 showed it -- 16 A. No. 17 Q. -- to Mr. Epstein? 18 MR. MERMELSTEIN: You got -- you got to 19 wait until he finishes the question. 20 BY MR. LUTHER: 21 Q. 22 A. No. 23 Q. 24 A. Yeah. 25 Q. 0370 1 2 3 MR. MERMELSTEIN: Ob'ection to form. 4 5 6 7 8 THE WITNESS: MR. MERMELSTEIN: No. 9 10 11 12 13 14 15 16 17 18 19 A. 20 21 22 23 24 25 0371 4 6 7 2 3 5 1 A. 8 A. 9 10 MR. LUTTIER: Yeah. MR. MERMELSTEIN: Yeah. I think so. Yeah. Q. A. It was before eah. Q. A. file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM! EFTA00725673
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11 Q. 12 A. 13 14 15 16 Q. 17 A. 18 19 20 21 22 A. 23 Q. Okay. And was it idea or your 24 • ? 25 A. idea. 0372 1 Q. Where is that tape today? 2 A. I don't have it. It's mined. 3 Q. Who mined it? 4 A. I did. 5 Q. And when did you min it? 6 A. A while, I don't remember. A while ago. 7 Q. You didn't ruin it until after you filed 8 this lawsuit, did you? 9 MR. MERMELSTEIN: Objection to form. 10 THE WITNESS: No, I did. It was before. 11 BY MR. LUTTIER: 12 Q. But how do you know that? 13 A. Because I don't -- I just -- it was 14 definitely not after. I don't even know, no. 15 Q. Well, I don't understand. First you're 16 saying you don't know when you did it, now you're 17 saying you did it -- 18 MR. MERMELSTEIN: No, no. no. 19 THE WITNESS: No, I, I was -- I remember 20 it was before I filed my lawsuit, but I don't 21 remember the exact date that I mined it, but 22 it was before I was even in this lawsuit. 23 BY MR. LUTTIER: 24 Q. Other than the videotape you made of 25 having sex and other sexual acts with 0373 1 and the photograph of you in your 2 underwear with this other girl when you were in high 3 school, have you been depicted in any other 4 videotapes performing sex acts? 5 A. No. 6 Q. Have you been depicted in any other 7 photographs in any state of undress, that is, either 8 topless or completely naked? 9 A. No. 10 Q. You said that at some point in time after 11 you went to Mr. Epstein's and you, you voluntarily 12 removed your under pants, correct? Remember that file:///CyDocuments%20and%20Seitings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725674
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13 testimony? 14 A. Yes. 15 Q. And do ou recall at what point whether 16 you were when you were 17 removing your pants and doing complete nude 18 massages to -- 19 A. No, I was, I was -- yeah. Sorry. Ask the 20 question. I coincompletely interrupted you. 21 Q. Where were you when you 22 were ivin complete nude massa es to Mr. E. stein? 23 A. 24 25 Q. Okay. You said there came a point in 0374 1 time, something about a vibrator. 2 A. Yeah. 3 Q. What happened with the vibrator? 4 A. He used it on my clit. 5 Q. What do you mean, he used it on your clit? 6 A. He turned the vibrator on and would put it 7 by my vagina. 8 Q. Okay. Did you have your underwear on or 9 off? 10 A. They were -- they were off. 11 Q. Oka . And when did this ha en? 12 A. 13 Everything happened in 14 15 MR. MERMELSTEIN: Objection, 16 argumentative. 17 THE WITNESS: Yeah, it, like I said, first 18 time I visit, second time I visit. It got 19 where, it got to the point where he would use a 20 vibrator on me, and then he started fingering 21 me, then he started using both on me, and then 22 he would ejaculate. I mean, after I had all my 23 clothes off, I mean it was -- I mean, it was 24 always the same thing. It was -- 25 0375 1 BY MR. LUTTIER: 2 Q Did he ask you to use the vibrator on you? 3 A. Yeah. 4 Q. And did you say okay? 5 A. Yeah. 6 Q. So, you did that voluntarily, too, 7 correct? 8 A. Yeah. 9 MR. MERMELSTEIN: Objection. 10 BY MR. LUTTIER: 11 Q. Was there ever a point in time that you 12 said no to the use of a vibrator? 13 A. No. 14 Q. You, you know what an orgasm is, I assume? 11 le:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725675
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15 A. Yeah. 16 Q. Did you ever have an orgasm while you were 17 at Mr. Epstein's? 18 A. Yeah. 19 Q. More than once? 20 A. Yeah. 21 Q. You enjoyed those? 22 MR. MERMELSTEIN: Objection, 23 argumentative. 24 BY MR. LUTTIER: 25 Q. Did you not? 0376 1 A. Yeah. 2 Q. You told him you enjoyed them, didn't you? 3 A. I didn't tell him. It was pretty obvious. 4 Q. You kept coming back because you enjoyed 5 it, didn't you? 6 MR. MERMELSTEIN: Objection. 7 BY MR. LUTTIER: 8 Q. Plus you were getting paid money. 9 A. Yeah. 10 Q. All right. Did you have an orgasm when 11 you were at Mr. Epstein's when he used the vibrator 12 on you? 13 A. Yeah. 14 Q. Yeah. And how many occasions did you go 15 back after the first time that he used the vibrator 16 on you? 17 A. Whenever he would call me up I would go. 18 Q. Do you know how many times that was? 19 A. After that, every single time he was in 20 town, two to three times a week. 21 Q. Fro how 22 many times did you go to Mr. Epstein and he used the 23 vibrator on you? 24 MR. MERMELSTEIN: Objection. Objection to 25 form. 0377 1 THE WITNESS: From -9 2 BY MR. LUTHER: 3 Q. 4 A. I don't -- I don't know. 5 Q. More than once? 6 A. Yeah. 7 MR. MERMELSTEIN: Objection. 8 BY MR. LUTTIER: 9 Q. Did ou have or arms more than one time 10 between 11 A. Yeah. 12 MR. MERMELSTEIN: Objection to form. 13 BY MR. LUTHER: 14 Q. Now, did there come a time -- sorry. 15 MR. MERMELSTEIN: Focus. You know, he's 16 asking about specific dates, so make sure file:///q/Documents%20and%20Seitings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725676
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17 you're sure of your answer. 18 THE WITNESS: I don't know how many times 19 20 BY MR. LUTTIER: 21 Q. Did there come a time that you say -- huh? 22 A. I don't know how many times I've been 23 there. 24 MR. MERMELSTEIN: No, well, he's asking 25 you a very specific date, so make sure you're 0378 1 sure of your answer. 2 THE WITNESS: From like, 3 MR. MERMELSTEIN: He's now asking you 4 5 MR. LUTTIER: All right. Let's not have a 6 speaking objection. 7 MR. MERMELSTEIN: -- 8 9 MR. LUTTIER: She knows how to answer and 10 that's a speaking objection. 11 MR. MERMELSTEIN: No, she doesn't. 12 MR. LUTTIER: Oh, she knows, trust me. 13 She, she is very streetwise and knows exactly 14 what's being asked of her. 15 BY MR. LUTTIER: 16 Q. Was there ever a time -- 17 MR. MERMELSTEIN: Objection to that 18 characterization. 19 BY MR. LUTTIER: 20 Q. Was there ever a time that you told 21 Mr. Epstein not to use the vibrator on you? 22 A. No. 23 Q. Were there times that you asked him to use 24 the vibrator on you? 25 A. No. 0379 1 Q. Did there come a time that Mr. Epstein 2 gave you a vibrator? 3 A. Yeah. 4 Q. Do you remember what kind of vibrator? 5 A. A Rocket Pocket. 6 Q. Okay. And what did you do with the Rocket 7 Pocket? 8 A. I have -- I had the Rocket Pocket in my 9 drawer at school. I don't know. 10 Q. The drawer at school? What school? 11 A. I have it with -- I had it with my -- 12 where I lived. 13 Q. Did you say you had the vibrator at your 14 drawer at school? 15 A. I had it at home and then I had it where I 16 lived. I, it was mine. So, with all my belongings 17 to my current address that I was staying at, that's 18 where I have it. file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 P141 EFTA00725677
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19 Q. When did he first give it to you? 20 A. I don't remember. I know I had it at my 21 house though when I was in high school. 22 Q. All right. And where did you keep it at 23 home? 24 A. In the drawer. 25 Q. Did your mom and dad know about it? 0380 1 A. No. 2 Q. Did you tell them about it? 3 A. No. 4 Q. Did you use it at home? 5 A. Yeah. 6 Q. Okay. You enjoy it? 7 A. Yeah. 8 Q. You had orgasms with it? 9 A. Yeah. 10 Q. Okay. Did you take it to college with 1I you? 12 A. Yeah. 13 Q. Did you use it at college? 14 A. Yeah. 15 Q. Did you enjoy it? 16 A. Yeah. 17 Q. Have orgasms with it? 18 A. Yeah. 19 Q. Still have it today? 20 A. No. 21 Q. Do you have a different one now? 22 A. A different one? 23 Q. Yeah, a different vibrator. 24 A. Yeah. 25 Q. Still use a vibrator today? 0381 1 A. Yeah. 2 Q. You think there's anything wrong with 3 using a vibrator? 4 A. No. 5 Q. Okay. You went out and bought your own, 6 right? 7 A. Yeah. 8 Q. Okay. All right. Then you said there was 9 a time, came a point in time that he put his finger 10 in your vagina? 11 A. Yeah. 12 Q. And when was that? 13 A. The next time, next visit after he used 14 the vibrator on me. 15 Q. Hov loou know that that was before you 16 were a a' ? 17 A. Before I was a 18 Q. Ri ht. 19 A. 20 file:///Cl/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PMl EFTA00725678
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21 22 Q. And did he ask to put his finger in your 23 vagina? 24 A. It wasn't quite like after he -- after I 25 was orgasming orgasming me from the vibrator, he 0382 1 flipped me around and I was on all fours, and he 2 stuck his finger in my vagina, and he didn't ask 3 questions. I was already orgasming, so it's not 4 like I told him stop. 5 Q. Did you say no? 6 A. No. 7 Q. Did you stop him? 8 A. No. 9 Q. Did you come back any time -- 10 A. He didn't ask me though. 11 Q. Did you come back any time after the first 12 time he put his fingers in your vagina? 13 A. (No verbal response.) 14 Q. Did you ever come back after that? 15 A. Yeah. 16 Q. Did he put his fingers in your vagina any 17 time after that? 18 A. Yeah, pretty much every time after that. 19 Q. Did you ever tell him not to? 20 A. No. 21 Q. You enjoyed it, didn't you? 22 A. Yeah. 23 Q. It was all part of the orgasm, wasn't it? 24 MR. MERMELSTEIN: Objection. 25 THE WITNESS: Yeah. 0383 1 BY MR. LUTTIER: 2 Q. The reality here, the truth is that you 3 enjoyed going to Mr. Epstein's and having an orgasm 4 and getting paid $200 for giving a massage; isn't 5 that the truth? 6 MR. MERMELSTEIN: Objection to form. 7 THE WITNESS: Yeah. 8 BY MR. LUTTIER: 9 Q. Okay. And you weren't traumatized by any 10 of it, were you? 11 MR. MERMELSTEIN: Objection to form, calls 12 for a conclusion. 13 BY MR. LUTTIER: 14 Q. What damages have you suffered as a result 15 of going to Mr. Epstein? 16 A. Honestly? Everything, like, emotionally. 17 MR. MERMELSTEIN: Take your time. 18 THE WITNESS: I mean, how does it make me, 19 emotionally, like, with my parents, disrespect 20 from my parents, family, friends. It's 21 relationship-wise, like trusting people-wise, I 22 don't know. I couldn't -- a lot of things, a file:///q/Documents%20and%20Seitings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725679
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23 lot of different things emotionally, like, a 24 lot of things. 25 0384 1 BY MR. LUTTIER: 2 Q. Well, you, you kept going back to 3 Mr. Epstein. You never said no, I don't want to 4 come, did you? 5 A. I thought he was my friend. 6 MR. MERMELSTEIN: Objection, 7 argumentative. 8 BY MR. LUTTIER: 9 Q. You never once said to Mr. Epstein, I 10 don't want to come, did you? 11 A. No. 12 Q. As a matter of fact, you gave Mr. Epstein 13 a little feedback, didn't you? 14 MR. MERMELSTEIN: Take your time. 15 BY MR. LUTTIER: 16 Q. You gave him a little feedback, didn't 17 you? 18 A. What do you mean by that? 19 Q. You told him you liked what he was doing, 20 didn't you? Didn't you? 21 A. I don't know. I don't remember. 22 Q. Do you recall? 23 MR. LUTHER: What are we on, No. 4? 24 THE COURT REPORTER: Yeah. 25 MR. LUTTIER: Let's mark that as 4. 0385 1 (Defendant's Exhibit No. 4 was marked for 2 identification.) 3 BY MR. LUTTIER: 4 Q. Let me show what's been marked as Exhibit 5 No. 4. Is that your handwriting? 6 A. No. Love always, Jane Doe No. 4. This 7 is, this, for a good time, call -- 8 Q. Yes. 9 s A. -- that's not miStot handwriting; 10 that's that' handwriting. 11 Q. Okay. And then below that the hearts and 12 then it's signed Jane Doe No. 4 and That's 13 your handwriting, the hearts? 14 A. Yeah, the heart, the heart -- 15 Q. Right. 16 A. -- the heart, and then heart, Jane Doe 17 No. 4. that's me. But for a good time and 18 then I didn't, like, put m number there. That's 19 for a good time, call that's 20 handwriting. And then that's her heart and 21 Q. Whose number is 22 A. That was my number. 23 Q. Okay. So you were present when this note 24 was created? 11 le:///q/Documents%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 PM1 EFTA00725680
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25 A. Yeah, we both were there. 0386 1 Q. This 2 A. Yeah. 3 Q. Okay. And so you both created this note 4 and left it for Mr. Epstein? 5 A. She wrote it there, and then I signed it, 6 yeah. 7 Q. You knew what you were doing, right? 8 MR. MERMELSTEIN: Objection, form, 9 argumentative. 10 THE WITNESS: No. I wasn't the one that 11 wrote it. 12 BY MR. LUTTIER: 13 Q. You knew what you were doing when you 14 signed it with hearts and put your name and left it 15 there, didn't you? 16 MR. MERMELSTEIN: Objection to form. 17 THE WITNESS: Yeah. 18 BY MR. LUTTIER: 19 Q. Nobody made you do that, did they? 20 A. No. 21 Q. You were telling him you wanted him to 22 call, you were having a good time, you wanted to 23 come back, weren't you? 24 MR. MERMELSTEIN: Objection to form. 25 THE WITNESS: Well, he was a very, like, 0387 1 sexual, like he was always joking around like 2 sex talk, like, I said, for example, he 3 would -- had me, like, go up to, like, joking 4 around like sexual, like, telling me how to 5 give head to a guy, or like always joking 6 around sexu• 7 So with -- he was that way with a 8 lot of different girls, always joking around 9 sexually with girls. 10 So whenever -- I didn't write this, I 11 didn't tell to write this. This was 12 intentions, and I was just joking 13 around and signed it. I didn't -- my 14 intentions weren't to write this, for a 000d 15 time, call Jane Doe No. 4. This is 16 intentions, not mine. 17 BY MR. LUTHER: 18 Q. Wait a minute. Wait a minute. Let's back 19 up. You saw the words and you read the words when 20 it was handed to you to sign, didn't you? 21 A. Oh, she didn't tell me, sign it, I 22 joking -- 23 Q. Oh, you did that voluntarily? 24 A. Yeah. 25 Q. So, she handed you this piece of paper, 0388 file:///CyDocuments%20and%20Settings/Production/Desktop/Doe%20No.%204.162Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 P141 EFTA00725681
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1 that is, 2 A. No, it was -- she wrote it. There was a 3 notepad -- 4 Q. Okay. 5 A. -- on, on the table. She wrote it, and 6 picking up -- I just picked up the pen after she 7 wrote something, joking around, because everybody, 8 like jokes around with Jeffrey Epstein, like, 9 sexually like that, picked it up and signed my name. 10 Q. Okay. Let's go through it. When did this 11 happen, by the way? 12 A. I don't remember. 13 Q. You were already at at 14 this time, or before that? 15 A. I don't remember. 16 Q. So your testimony is that wrote on 17 a pad at Jeffrey Epstein's house, for a good time 18 call, and put your number, right? 19 A. Yeah. 20 Q. And did you put her number too? 21 A No. 22 Q Is that her number? 23 A. It might have been her old number. I 24 don't remember. 25 Q. Okay. So she wrote all of that, right, 0389 1 first? 2 THE WITNESS: Can I have a tissue? Oh, 3 never mind. I have it right here. 4 BY MR. LUTFIER: 5 Q. Did she write all of the words that appear 6 in this notepad before you put anything on it? 7 A. Did she write anything before -- wait. 8 Ask me the question again. 9 Q. Did she write all the words that appear in 10 this notepad before you put anything on it? 11 A. No, she wrote, for a good time call. 12 Q. So when, when you originally got this 13 note, when you were standing there, this is down in 14 the kitchen of his house? 15 A. Yeah, I think so. I don't remember where 16 we were. 17 Q. Both of you were there for some reason? 18 A. Yeah. 19 Q. Had you both been there giving Mr. Epstein 20 a massage? 21 A. Yeah. She had gone there. 22 Q. But you were both there at the same time? 23 A. Yeah. 24 Q. Were you there -- were you both giving him 25 a massage at the same time? 0390 1 A. No. 2 Q. By the way, do you know what a three-way file:///q/Documents%20and%20Senings/Production/Desktop/Doe%20No.%204.%2Ohne%20-%20Vol.%20Ill.txtl11/6/2009 5:12:34 P141 EFTA00725682