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FBI VOL00009
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7. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 Page 575 A. Yes, I did. Q. And did you pay on the amount of income you actually earned? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: It's none of your damn 6 business. BY MR. LUTTIER: Q. Do you know that filing a false tax return is a crime? A. Yeah, and it wasn't false. Kiss my ass. Q. So your, your tax return is in '08 is correct; is that right? Is that what you are telling us? A. No. Q. Is it false? MR. EDWARDS: Just read. Q. Well, ma'am — A. Can you tell I am suffering? I hate Jeffrey Epstein, and I hope he burns in hell. On advice of counsel, I am invoking my Page 576 1 Fifth Amendment rights under the United States 2 Constitution. 3 Q. To anything in particular or just making 4 that statement? S A. To the question you asked me about my taxes. 6 Q. That question has already been answered. 7 A. Oh, 0 . Next. a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 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 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 577 Pa.e 578 20 (Pages 575 to 578) PROSE COURT REPORTING AGENCY, INC.' Electronically signed by cynthia hopkIns Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins bS542fetd299-4e41-9ba6455aad2714405 EFTA01076178
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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 581 2 3 4 5 6 7 8 Q. Who did 9 A. aezd o 10 Q. 11 A. I don't know his last name. 12 Q. Where did you meet him? 13 A. I don't know. 14 15 16 17 18 19 s some y you to . 20 A. No. 21 Q. Is he someone with whom you had some kind 22 of relationship? 23 A. Yeah. 24 Q. What kind of relationship did you have 25 with him? Pa •e 580 Page 582 1 A. Our sons would play together. 2 Q. Do they still play together? 3 A. No. 4 Q. Was he a client of yours? 5 A. No. 6 7 B 9 10 el, o 'ow, a invasion — w 11 do you mean when you say you've suffered invasion of 12 your privacy? 13 A. Are you serious? Well, here is one. Here is 14 two. 15 Q. So, you're talking about things that you 16 did -- 17 A. Investigators. 18 Q. — in the public? 19 A. All my damn, all these years that I've, after 20 Jeffrey they wanted -- invasion of my privacy, are you 21 kidding me? I can't go anywhere without anyone knowing 22 where I'm going. The FBI, the investigators following 23 me everywhere. I can't take my son out with anybody 24 knowing me. 25 Invasion of my privacy?. Everybody knows 21 (Pages 579 to 582). PROSE COURT REPORTING AGENCY, INC. ' Electronically signed by cynthia hopkins Electronically signed by cynthia hooking ) Electronically signed by cynthia hopkins b664,210-d299-4•04ba6416arad27M405 EFTA01076179
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Page 583 1 that Jeffrey Epstein molested me. So, if my son 2 wants to go out and play with somebody, oh, no, 3 she's the little girl that was in prostitution for 4 Jeffrey Epstein, so we don't want her playing with 5 our son. 6 Q. So, or do they say she's the lady that 7 ems her own escort service, we don't want her 8 playing with our son? 9 A. No one knows about that shit except you guys. 10 Q. How about when you were working for 11 another escort service? 12 A. How about what? 13 Q. You don't think anybody knew about that? 14 A. No. 15 Q. How about when you were — 16 A. lam very discrete what I do. l don't put my . 17 name in the newspaper like Jeffrey Epstein saying that I 18 am a prostitute or a slave for Jeffrey Epstein. 19 Q. How about when you were top, dancing 20 topless at bars? Do you think maybe people said — 21 A. I did that out of, like not locally. 22 Q. So, maybe, well, 1 mean — 23 A. Well - 24 Q. You wouldn't exa tl call 25 A. . I Page 585 1 all out. Everybody knows. Okay. You can sit there and 2 act like you, you can act like an attorney and -- 3 Q. Has the words — 4 A. — say where has your name been? My name is 5 out there everywhere. Okay. l am the prostitute of 6 Jeffrey Epstein. I have brought young underaged girls 7 there. I am so horrible. 8 My son can't play with certain kids 9 because ofJeffrey Epstein now. He has ruined my 10 fucking life. He has brought me into this industry 11 that this is all I know. And now I can't even, I 12 can't even explain to you the hard things that I've 13 been through my life because of Jeffrey Epstein, 14 because he has taught me and many other girls how to 15 pull money from older men. 16 Q. Let's just be honest for the ladies and 17 gentleman of the jury: Ho didn't force you to do 18 anything? 19 A. But he taught me from a young age — 20 Q. Wait a minute. Let me finish. 21 A. — when I was 13 years old. 22 Q. You -- 23 A. He taught me how to get money real quick. 24 Q. Do you — 25 A. — from an old man. Don't sit here and tell Page 584 live in West Palm. 2 Q. So, you meant within the immediate 3 geographic area. And maybe they said, well, this is the lady that goes and sells her wares at all these 5 topless bars; we don't want our children playing 6 with her. 7 A. No, not all. They see Jeffrey Epstein and my 8 name all over the place and they say, you know what, I 9 don't even want anything to with this girl because she 10 was a prostitute for Jeffrey Epstein. 11 Can I talk to him without you in his ear? 12 Amidone talking? 13 Q. Could you just tell me one place where 14 your name has appeared anywhere as being someone who 15 saw Jeffrey Epstein? 16 A. It's everywhere. 17 Q. Well, where? Just tell me one place. 18 A. Where have you been? 19 Q. Just tell me one place. Can you cite 20 me — 21 A. Ifs in the newspaper. 22 Q. What newspaper ever ran your name? 23 A. The Initials of my name? 24 Q. No, your name. 25 A. It doesn't matter. The It's Page 586 1 me that I was not forced or anything like that. 2 Q. That's exactly what I'm suggesting. ma'am. 3 Do you believe that you owe, that you have a certain 4 le''el of responsibility for your own conduct? 5 A. Now I k 6 Q. You're.. years old. 7 A. When I was 13 years old, 1 didn't, I wasn't, 8 no, I did not have that demeanor. 9 Q. So, a what you thought, because you 10 want to clean up your imagine for your son, right? 11 You want him to look up — 12 A. Yes, I do. 13 Q. So, as part of tha ess what you 14 thought you would do aM is you would agree to 15 hire out to strange men whom you don't know for 16 between 3300 and $500 for what you say is to go sit 17 in rooms naked with them, and that's how you thought 18 you would prove? 19 A. Because that's all I know. I'm Sony. 20 Q. And Jeffrey Epstein didn't make you do 21 that, did he? You decided to do that, didn't you? 22 A. You know what 23 Q. A whole new business that you decided to 24 do on your own; is that right? 25 MR. EDWARDS: Object to form. 22 (Pages 583 to 586) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421of-d299-4041-91m6.85aad2714405 EFTA01076180
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Page 587 1 THE WITNESS: — before! -- 2 MR. EDWARDS: Argumentative, asked and 3 answered. 4 BY MR. LUTTIER: 5 Q. Did Jeffrey Epstein ever give you the 6 business advice on a business plan to go out — 7 A. Yes, he did. He gave me business advice. 8 Q. Wait. You started this in January? 9 A. You know what he told me this: He said, you 10 inc girls, this is business. Let's talk business, 11 I . You get me girls, twill pay you. Is that not 12 called business? 13 Q. So, and you quit doing that when? 14 A. You get me girls, and I brought him.two girls 15 a day, one girl a day, $200 each. That's not business? 16 Q. And when you — 17 A. He taught me business and now I run business. 18 Q. And so — 19 A. Just like you run business. 20 Q. And when did that, when did you start — 21 A. Just like you learned how to do this, I 22 learned how to do this. 23 Q. What — so, you kamed to be a 24 prostitute? 25 A. Yes, I did. Page 588 1 Q. And you enjoy it? 2 A. No, !don't enjoy it, and I can't wait to get 3 the hell out of it. 4 Q. And that's why in January of '010 you 5 decided what you would do is start getting men to pay you S300 to $500 an hour to sit around naked 7 with them, is that right? 8 MR. EDWARDS: Form. 9 THE WITNESS: Yes, that's right. 10 BY MR. LUTTIER: 11 Q. And the last time you took a girl to 12 Jeffrey Epstein was when? 13 THE WITNESS: Did we already ask this 14 question? 15 MR. LUTTIER: When? No, the last time — 16 MR. EDWARDS: Object to the form. 17 MR. LUTTIER: — you said you went was — 18 MR. CRTITON: You're out of time. 19 MR. LUTT1ER: Okay. 20 THE V1DEOGRAPHER: Going off the record at 21 3:14 p.m. This is the end of Tape 2. 22 (A brief recess was held and 23 Mr. Goldberger did not re-enter the room.) 24 THE VIDEOGRAPHER: We're back on the 25 record at 3:24 p.m. This is the start of 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 589 Tape 3. MR. EDWARDS: Before we get started I just want to put something on the record that there was a hearing, I believe it was November 3rd, 2009, and the judge suggested that the defense only have one attorney there. And his recommendation was such because of the breakdown — MR. LUTTIER: Well, let's — MR. EDWARDS: — in the first deposition. You can, you can make a record after. That is fine. Was because of the breakdown in the first deposition, and he thought that that type of intimidation by more than one attorney would lead to an additional meltdown. We have been fine thus far today despite there at a minimum always being two attorneys and in the last 15 to 20 minutes not only was Mark Luttier here and Bob Critton as it has been all day, but Jack Goldberger was also in the room. And once it was lined up three attorneys over there, either passing notes, talking in each other's ear, and otherwise assisting in the deposition or at least that was the feeling Page 590 1 from the witness, we began to have another 2 meltdown. 3 So, hopefully we can proceed with less 4 attorneys and we can get through this process. s But I just wanted to put on the record exactly 6 who was in the room when everything started to 7 break down just now. 8 MIL LUTIIER: Well — 9 MR. EDWARDS: If you have something to 10 say, that's fine. 11 MR. LUTHER: That just is not factually 12 correct. Mr., first of all the judge ordered 13 that Mr. Critton and I could be present 14 throughout this deposition. Mr. Critton and I 15 have been present throughout this deposition, 16 and he and I have communicated throughout the 17 deposition. 18 Mr. Goldberger walked in here. I didn't 19 put a stopwatch on how long he was there. He 20 is not even here now. He was here for maybe 21 ten minutes. I had no communication at all 22 with him. He carne. He sat here. He got up 23 and he walked out. 24 This breakdown that you're talking about 25 occurred Ions before Mr. Goldberger ever of 23 (Pages 587 to 590) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fet-d299-4041-9ba6-55aad2714405 EFTA01076181
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Page 591 here. So, I dispute — 2 THE WITNESS: No. 3 MR. LUTHER: — the facts, but it's sort 4 of a moot issue now anyway, so — 5 MR. EDWARDS: But if we're going to get 6 into that, then every time he comes into the 7 . room do we need to now put it on the record 8 that he is in the room? 9 MR. LUTHER: I have absolutely no 10 problem — 11 MR. EDWARDS: And each time — 12 MR. LUTTIER: Anytime he comes in, we'll 13 stop him and well let him know he can't come 14 in here. Quite frankly, if you would have said 15 something to me about it, I was examining the 16 witness, I would have stopped right then and 17 said, Jack, get out of the room. 18 MR. EDWARDS: And I know in all fairness 19 to what you just said I am not saying that to 20 you was not factually accurst; what you just 21 said, but you weren't able to see what was 22 behind you, the passing of the cellphone and 23 other things that the witnesses notices. 24 I am just telling you that this impacts 25 the deposition. So, I just want to make it Page 592 1 clear so that you would know exactly what's 2 happening and maybe we can get through this. 3 You know, it's all of our goals to get through 4 this day. So, I, I think the witnesses is 5 ready if you're ready, Mr. Luttier. 6 MR. LUTTIER: I'm ready. 7 MR. EDWARDS: Okay. 8 MR. CRITTON: What time did we start 9 because we haven't we've been on the record, 10 but we haven't asked a single question. 11 THE VIDEOGRAPHER: les 3:28 right now. 12 Three and a half minutes. 13 MR. CRITTON: Thank you. 14 BY MR. LUTTffiR: 15 Q. I am now referring to your, your 16 interrogatory answers. These are answers that you 17 gave to written questions that were sent to you in 18 this case. And they are entitled Defendant's 19 unverified better answers to first interrogatories. 20 I believe they may have been marked as Exhibit 1 to 21 the first deposition, but there is only one set of 22 them. 23 • MR. LUTHER: And Brad, they are, the date 24 of service on, I don't know, wait. Date of 25 service is August 4th, 2009. Page 593 1 MR EDWARDS: mats the — 2 MR. LUTHER: Defendants unverified 3 better answers to first interrogatories to 4 Plaintiff. Later I'm going to come to the S Plaintiffs supplemental better answers to 6 Defendant's Interrogatory No. 19. 7 MR. EDWARDS: Okay. But you said the date 8 of service meaning you saved on us? 9 MR LUTHER: No, no. Your answers, 10 better answers. 11 MR. EDWARDS: Got it. I am looking as the 12 same document you are. 13 BY MR. LUTHER: 14 Q. All right. Ma'am, in response to some 15 interrogatories you stated that from the end of 2007 16 to November of 2008 you worked at 17 earning S1100 a week. So that would have been a 18 period of approximately one year; is that right? 19 MR. EDWARDS: Read. 20 THE WITNESS: On advice of counsel I am 21 invoking my Fifth Amendment rights again under 22 the United States Constitution. 23 BY MR. LUTHER: 25 you worked at what did you do for Q. From, f of time that 24 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 594 your money? A. On advice of counsel I'm invoking my Fifth Amendment rights under the United States Constitution. Q. In continuing in answering that particular imar.saici that in 2008 worked at . Where is located? A. On advice of counsel I'm invoking my Fifth Amendment rights under the United States Constitution. Q. What did you do at A. On advice of counsel I'm invoking my Fifth Amendment rights under the United States Constitution. Q. Did you have any communication with Jeffrey Epstein after the phone call you made to him following the FBI's interview of you? A. I talked to ing Oh, my God. I don't know what I am going through. I'm like shaking. Q. I am talking about now a conversation with Mr. Epstein. MR. EDWARDS: The question was, did you talk to him after you called him — MR. LUTHER: Right MR. EDWARDS: — after the FBI statement? MR. LUTHER: Right. 24 (Pages 591 to 594) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns Electronically signed by cynthia hopkIns Electronically signed by cynthia hopkIns b55421ef-d299-4e4f-9ba6-85aad27t4405 EFTA01076182
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9 10 13. 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 595 BY MR. LUTTIER: 2 Q. And the date of your FBI statement for 3 your information was April 241h, 2007. Did you have 4 any conversation with Jeffrey Epstein after that . 5 date? 6 A. After I, after I had called my attorney? 7 Q. After April 24th, '07, which is the date 8 that you gave a st FBI. A. I talked toatlisic) or whatever her name is. Q. Did you have any conversation with Jeffrey Epstein? A. No. I don't think so, no. Q. Other than the witnesses you have listed in answer to Interrogatory No. 5, do you know of any other witnesses or do you intend to call any witnesses in the trial of this matter? A. What? MR. EDWARDS: Objection. Attorney-client privilege. I don't want her answering questions as to whether, as to information that she and I have spoken about in terms of what witnesses will be called at trial or our trial strategy. Page 597 1 with Mr. =bout being a witness? That is what 2 would he be offering as testimony in the case? 3 A. What would he be offering? 4 Q. Yeah. Why did you ask him about being a 5 witness? 6 A. I didn't ask him about being a witness. I 7 .told him about what happened to me when 1 was 13 years 8 old. 9 Q. Okay. 10 A. I'm not asking anybody to be a witness as of 11 right now. 12 Q. What is -- • 13 A. I'm my own witness. 14 MR. EDWARDS: Listen to his question. 15 THE WITNESS: I am trying. I can't think 16 right now. 17 MR. EDWARDS: He wasn't asking you about 18 being a witness. 19 BY MIL WrrIER: 20 Q. Where does Mr. =live now? 21 A. West Palm Beach. • 22 Q. est Palm? 23 A. 24 Q. When did you last have communication with 25 him? Page 596 1 BY MR. LUTHER: 2 Q. Have you spoken to anyone with respect to 3 their willingness or your intention to call them as 4 a witness to the trial of this matter? 5 MR.. EDWARDS: Not who I have spoken to. 6 MR. LUTHER: Yeah, you. 7 THE WITNESS: What? 8 BY MR. LUTHER: 9 Q. Have you spoken to anybody about being a 10 witness • • is matter? 11 A. 12 Q. Anyone else? 13 A. Not that I know of. 14 Q. And when did you speak with Mr. 15 about being a witness? 16 A. May `09. 17 Q. And what is it you told him or asked him 18 about being a witness? 19 A. I told him that Jeffrey Epstein molested me 20 since I was 13 years old. 21 Q. Okay. And he wasn't around at the time 22 that you alleged Mr. Epstein molested you, correct? 23 A. He wasn't around at the time when Jeffrey 24 Epstein was molesting me. 25 . Okay. S aS= st r w hat did you confer Page 598 1 A. January 3rd, 2010. 2 Q. And for what purpose did you have 3 communication with him on that date? 4 A. I had to give him some of his clothes. 5 Q. When was the last were in 6 tion with Mr. that would be 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING A. lie's my son's father. So, I talked to him two weeks ago. Q. And where was he when you talked to him? A. Fort Myers. Q. And do you know how he's employed now? A. .No. He says he's not employed. Q. Have you discussed with him in the last year anything about this lawsuit? A. Yes. . Q. What have you discussed with him? A. I told him I'm going through a lawsuit. Q. And what did he say? A. He said okay. Q. Have you asked him to be a witness? A. No. Q. Have you ' nication with any . other members of Mr, family in the last two years? 25 (Pages 595 to 598) AGENCY, INC'. Electronically signed by cynthia hopkIns Electronically signed by Cynthia hopkIns Electronically signed by Cynthia hapkins b55421ef-d2994e4t-9ba6-85aac12714405 EFTA01076183
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Page 599 1 A. Yes. 2 Q. 3 AA. illi nit c). 4 Q. Who is 5 A. His sister. 6 Q. And where does she live? 7 A. Wellington. 8 Q And for what purpose have you been in 9 touch with her? 10 A. She's my son's aunt 11 Q. And with what degree of frequency are you 12 in communication with her? 13 A. She asked me to attend her wedding via e-mail 14 this March of '010. 15 Q. Have you discussed with her anything about 16 Mr. Epstein? 17 A. No. 18 Q. Does she to the best of your knowledge H know anything about it? 20 A. Yes. 21 Q. Did you say no? 22 A. Yes. 23 Q. Does she know anything about? 24 A. Yes. 25 Q. What does she know about it? Page 601 1 Q. Is that the last time she's seen your son? 2 A. Approximately, yeah. 3 t Q. ' ur son when you were 4 down a m 8:00 at night until 5 in the 6 A. 7 Q. I 8 identified earlier? 9 A. Yeah. 10 Q. And where was she watching him? 11 A. At my house. 12 Q. So, does she come spend the night at your 13 house? 14 A. Yes. 15 d there, was there ever a time that you 16 and 1M lived together? 17 A. Yes. 18 Q. When was that? 19 A. When we were 13, 14. 20 Q. Thirteen and 14. Was any adult living 21 with you? 22 A. My father. 23 Q. Since you were 13 or 14 has a ever 24 lived with you? 25 ANo. 1 2 3 7 8 9 9 10 10 11 11. 12 12 13 13. 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23. 25 2: 25 SC, 24 24 Page 600 1 A. That Jeffrey Epstein's a child molester. 2 Q. And how did she get that information? 3 A. From the news, from friends, from the 4 neighbor/mod -- 5 Q. Did — 6 A. From her brother. 7 Q. — has she asked you any questions about 8 your relationship or interaction with Mr. Epstein? A. She said I am sorry that you're going through the trauma that you're going through. other member of Mr. family? Q. Have you tmitation with any A His mother. Q. illy t's her name? A. Q. And where is she located? A. Fort Myers. Q. And when did you last have communication with her? A. I don't know. A year ago. Q. And for what purpose did you have communication with her at that time? A. Dropping my son off with her. ho you rather? 4 Page 602 Q. Did you tell why you needed to have haisall night when you were down at A. Hold her I need to work. Q. Do you tell her what you do for work? A. Yes. Q. What did you tell her? A. I sell lingerie and shoes and purses and Mary Kay. Q. Do you have any personal knowledge of the matters about which the witnesses listed in your answers to interrogatories that these witnesses have, have information about? MR. EDWARDS: Objection, attorney-client privilege. And we do this all the time. BY MR. LUITIER: Q. This is just a list as prepared by your lawyer. You don't know what any one of these witnesses would say? MR. EDWARDS: And if she does, it's going to be information that I have talked to her about which you know is protected by attorney-client privilege and so do L If you're asking her independent of her information I have told her, fine. 4. , ...••••••••••••4 26 (Pages 599 to 602 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421ef-d299-4e4f-9ba6-85aad2714405 EFTA01076184
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Page 603 1 MR. LUTTIER: That's exactly what I am 2 asking her. 3 MR. EDWARDS: Okay. Let's ask it that way 4 because it doesn't sound like that. 5 BY MR. LUTTIER: 6 Q. Do you know of any information that these 7 witnesses have based on your communications with 8 them? 9 A. Excuse me? 10 Q. Do you know any information that any of 11 these witnesses have about this case based on your 12 personal contact with them? 13 A. What witnesses? 14 Q. That are listed in the Answers to 15 Interrogatory 5. 16 MR. EDWARDS: Just answer his question, 17 yes or no. 18 THE WITNESS: No. I don't know these 19 people. 20 BY MR. LUTTIER: 21 Q. On any visit that you went to see Jeffrey 22 Epstein, did he ever ask you to do anything that you 23 said you did not want to do? 24 A. Yes. 25 Q. What did he ask you to do that you said Page 604 1 you didn't want to do? 2 k At one occasion he wanted to stick his lingers 3 like all the way inside of me and 1 said no? 4 Q. And what did he then do when you said no. 5 A. He said okay. So then he just penetrated my 6 vagina with his tinge's. 7 Q. What did he, did he —when you said you 8 didn't want him to do that, did he respect your 9 wishes and not do it? 10 A. No. Actually he, he pushed it. He tried to 11 do it and he said, okay, no, it's going to be okay. 12 It's going to be okay. And I backed off and I said no. 13 Q. And then he stopped? 14 A. Then he decided to respect my wishes. 15 Q. Okay. Any other — and this is on one 16 occasion? 17 A. Many occasions. 16 Q. Well, on — so on many occasions he would 19 say he wanted to penetrate your vagna. You would 20 say you didn't want — well, actually what you said 21 was he wanted to penetrate your vagina deeply I 22 think And, and you said no and he respected your 23 wishes and didn't do it? 24 A. Correct. 2 5 Q. Okay. Was there ever anything that at Page 605 1 all that you said I don't want to do this and Jeff 2 said you had to do it anyway? 3 A. Yeah. I told him that at times I did not want 4 to bring girls, and he says, yes, I want you to do it 5 anyway; you need to do it anyway. 6 Q. And did you tell all the girls that you 7 brought that Jeffrey would respect their wishes, and 8 if they were uncomfortable doing anything, that they 9 should just tell him that, and he wouldn't ask them 10 to do anything that they weren't comfortable doing? 11 A. Yes, because I was scared. 12 Q. And that's, in fact, how he treated you, 13 fir? 14 A. Yes. 15 Q. You previously earned a degree as an 16 esthetician; is that right? 17 A Yes. 18 Q. And you now earned a degree since going to 19 Mr. Epstein in massage therapy, correct? 20 A. Yes. 21 Q. And you emillairnom the same 22 school located on 23 A. Yes. 24 Q. And you could pursue a profession as an 25 esthetician, a massage therapist if you so chose, 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 PROSE COURT REPORTING Page 606 could you not? A. No, not as a massage therapist. Q. Why not? A. Because I've told you once before I need to take the nationals. Q. But no one has prevented you from taking test, right? A. I have to wait to take the test. It only happens twice a year. Q. And has — did you pass the first opportunity you had? A. No. Q. Okay. So, when's, when's the test coming up? A. In a few months. Q. And are you going to take it? A. Yes. Q. And you could have been working as an esthetician ever since you went to Jeffrey Epstein's? A. And I did work as an esthetician. Q. No one has prevented you from doing that, correct? A. No. 9. You made the decision to drop out of 27 (Pages 603 to 606) AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by synth's hopkins Electronically signed by cynthia hopkins b5542fef-c1299-4e41-9ba6-85aad27f4405 EFTA01076185
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Page 607 school before you ever met Jeffrey Epstein, did you 2 not? A. I'm pretty sure I was going to school when I Was seeing Jeffrey Epstein. 5 Q. But, but you made the decision to drop out 6 based on other facts and circumstances that had 7 nothing to do with seeing Jeff Epstein; isn't that a correct? 9 A. Excuse me? 10 Q. You decided to drop out of school for your 11 own reasons particularly 1 think you said because 12 you got pregnant, didn't you? 13 A. No. 14 Q. Well, why did you decide to drop out of 15 school? 16 A. I was trying to find girls to bring to 17 Jeffrey's house. 18 Q. Well, didn't you tell us the last 19 deposition that you dropped out when you got 20 pregnant? 21 A. I was going to school when I was pregnant. 22 Q. Yeah. And then you dropped out, right? 23 A. I dropped out when I was pregnant. 24 ass drop out of 25 and then go to 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 609 six. But then I did go back and I got my high school diploma, and like you said I have two degrees. Q. When did you get your, your GED? A. Yes. Q. When did you get that? A. What I turned 18. Al Q. So, you got a high school equivalency diploma at the same time you would have gotten a high school graduation certificate — A. Correct. Q. -- had you stayed in school? A. Correct. Q. And then you were free to pursue the same pursuits as anybody else that had graduated from high school whether that would be college or a trade school or whatever you want to? A. No, no. If I would have stayed in school, I could have got some type of scholarship. I could have had many opportunities in school to learn higher education than just the GED. Q. Well, when you got — A. And I could have — traveled and I could have went to a college, a bigger college, a state college. Page 608 1 A. Because ever since I met Jeffrey I— before 2 Jeffrey I made wonderful grades. And then ever since I 3 met Jeffrey my grades went down and I was failing, so I 4 had to go to a school to bring my grades a up. S 1i. But you opted to drop out of the 6 MIE before you graduated? 7 A. Yes. I was four months pregnant 8 Q. And that's why you dropped out? 9 A. Well, I needed to make money to buy a house, a 10 trailer so I could have my baby. 11 Q. Because you were pregnant? 12 A. Yes. 13 Q. Had you not been pregnant, you would have 14 continued in school, correct? 15 A. I can't answer that question. I don't know. 16 Q. Well, the point is the direct reason why 17 you dropped out was you were pregnant? 18 A. And I was making so much money off of Jeffrey 19 that I didn't think school was so necessary at that 20 time. 21 Q. Did you consult with your parents or any 22 counselors about that? 23 A. I didn't tell my parents about Jeffrey. 24 Q. How much were you making at that time? 2 5 A. 1 WaSJnakilik $200 pretty much a day or 400 or Page 610 1 Q. How do you know that? 2 A. les common sense. 3 Q. Well, you don't know what your grades 4 would have been, right? 5 A. No, I don't know what my grades would have 6 been. 7 Q. And at — A. Do you know what tomorrow is grimy, bring? 9 siAt the time that you went into the MI 10 you were qmillpally failing, weren't you? 11 A. Yeah, but they help girls, young girls 12 bring up their grades so you can go back into high 13 school and accomplish making more, bettering your grades 14 so you can get a scholarship. 15 Q. Well, in fact you got a scholarship for 16 your massage therapy, didn't you? 17 A. No. How could I? 18 Q. Did you tell us in the last deposition 19 that you got some kind of scholarship for going 20 there? 21 A. I didn't get a scholarship for going. No. 22 I've never got a scholarship. 23 Q. Did they lend you money to go to school 24 there? 25 A. For massage therapy but not for esthetics. 28 (Pages 607 to 610) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins ) Electronically signed by cyntNa hopkins ) b5542fef-d299-4e4f-9ba645aad2714405 EFTA01076186
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Page 611 Page 613 1 Q. That's what I was talking about was 1 2 massage therapy. 2 3 A. That's not a scholarship. 3 4 Q. Okay. 4 5 A. That's a loan that I have to still payback. 5 6 Q. Did you ever travel anyplace with Jeffrey 6 7 Epstein? 7 8 A. Nope. 8 9 Q. Are you — you're a person that uses the 9 10 computer now, correct? 10 11 A. Yep. 11 12 Q. Did you ever communicate with Jeff Epstein 12 13 on the computer? 13 14 A. No not that I recall 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 124 24 25 25 29 (Pages 611 to 614) PROSE COURT REPORTING AGENCY, INC. ' Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b56421ef-d299-4e4f-9ba6.85aad2714405 EFTA01076187
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2 3 4 5 6 7 a 9 10 11. 12 13 14 15 16 17 1.8 19 20 21 22 23 24 25 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 615 e 616 1 2 3 4 5 6 7 8 9 10 1 1 12 13 14 15 16 17 18 19 20 21 22 23 24 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 25 Page 617 Page 618 30 (Pages 615 to 618) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fef-d299-4e4f-9ba6-85aad27f4406 EFTA01076188
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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 620 1 A. Yes. 2 Q. Do you know of -(phonetic)? 2 A. Yeah. 4 Q. Who is that? 5 A. Ifs actually my sister's son or daughter's 6 father's cousin. 7 Q. Sister's daughter? Your sister has a 8 daughter? 9 A. Yes. 10 Q. So daughter's cousin's father? 11 A. y's father, his cousin. 12 ii?kay. When did you first meet 13 14 A. Probabl knew him since]. was 11. 15 16 17 18 19 20 21 22 23 24 25 Page 621 1 BY MR. LUTHER: 2 Q. Did you she ever approach you about that? 3 A. No. 4 Q. Did she ever tell the police she was concerned about that? A. No. MR. EDWARDS: Object to the form. 9 10 11 MR. EDWARDS: Form, predicate. 12 MR. CRITTON: What's the form? 13 THE WITNESS: She was probably concerned. 14 MR. EDWARDS: You're asking - 15 MR. LUTTIER: Was your mother - 16 MR. EDWARDS: You're asking to tell 17 you whether she knows how her mother was 18 feeling at some certain time. 19 Y MR. LUTHER: 20 21 22 23 MR. EDWARDS: Same objection. 24 THE WITNESS: She probably was concerned, 25 yet Page 622 1 LTIER: 2 3 4 5 6 7 8 Tr " . • i gcm, 9 predicate. 10 THE WITNESS: A mother's love. I don't 11 know. I can't speak for my mother. I am 12 sorry. 13 BY MR. LUTTIER: 14 Q. Were you doing something that gave her 15 that concern? 16 MR. EDWARDS: Object to the form, 17 speculation. 18 THE WITNESS: I don't know. 19 BY MR. LUTHER: 20 . Are a aware of the fact that your father 21 22 uly of 23 '04? 24 A. Ile filed for what? 25 What's called a 31 (Pages 619 to 622) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins Electronically signed by cynthia hopkins b55421ef-d299-4e41-9ba6-85aad2714405 EFTA01076189
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2 3 6 5 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 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 25 Page 623 A. I never went to any program or anything. Q Yeah, but do you know he filed a petition in the court claiming that you come home when you want to, you're in trouble with the police, and that Did you know he filed that in July of'04? A. No. Q. You didn't know that? A. (Witness shakes head.) Q. you, in fact, taking in July of'04? A. Yes. I apologized to my father. Q. So, he had a legitimate concern at that time? MR. EDWARDS: Form. THE WITNESS: Yes. BY MR. LUTTIER: And with what degree were you taking at that time? A. I was a confused little girl with Jeffrey Epstein and that always, leaving Jeffrey Epstein's house always lead me to do more drugs and more drugs. I was uncomfortable about my body. Page 624 Q. What were you — A. I didn't like the way Jeffrey made me feel. Q. What were you uncomfortable about your body about? A. I felt insulted. I felt used. Q. Did you tell him that? A. No. Q. Did you tell anybody that? A. Yeah. Q. Who did you tell? A. a Q. On the, on the way over to Jeffrey Epstein's when you were taking her there? A. Yeah. We would tell each other that we didn't like the way we felt. Q. Did tu file a complaint that your boyfriend was stalking you? A. Yes. Q. Was be, in fact, stalking you? A. He got -- he was on coke one day, and I was scared because he was trying to get in the house and I didn't want nothing to do with him. Q. Did that give you some concern? A. Excuse me? Q. Did that give you concern? 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 625 A. Concern? Q. Yeah. I mean were you afraid? A. Only for that one night that he was on coke. He was just trying to, like, get in my house and I didn't want him in there. Q. D# o ou know a lady by the name of * A. Ob, my. I know herii.r Q. How do you know Q. Who is A. A friaamine. Q. Where did ou meet ? A 'Through yfriend. Q. And wbos boyfriend? MR. EDW : you ve a question, Bob? MR. CRITTON: He was telling me to ask her what n's -- IvfirEDWARDS: Oh, sony -- MR. LUIT1ER: -- full name is. We'll get to that. MR. EDWARDS: Okay. THE WITNESS: I don't — oh, God, I don't remember his name but they were both no good. Page 626 1 They were like gang members. 2 BY MR. LLITTIER: 3 Q. That is 7 + 4 A. No, and her boyfriend. 5 Q. Okay. you don't remember the 6 boyfriends's name? How did you — what was your 7 relationship with B A. AssociatePPIII, in a while. 9 Q. When did you first meet her? 10 A. In — I don't know. Maybe when I was 14. 11 Q. Did she live in your neighborhood? 12 A. No. 13 Q. How did you meet her? 14 A. I'm not sure. 15 Q. Was she a friend? 16 A. She became an associate. 17 Q. Is there a difference between an associate 18 and a friend? 19 A. Yeah. A friend is someone who's always by 20 your side and who you can talk to daily, and an 23. associate is just someone you can, that you know. 22 Q. Did you socialize with her? 23 A. Yeah. 24 Q. What kinds of things did you do with her? 25 A. Not good things. 32 (Pages 623 to 626) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 10842444d299-Se4SabaSattaad2714406 EFTA01076190
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1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 627 Q. And this was during the time that you were seeing Mr. Epstein? A. Yeah. Q. What else did you and she do together? A. Nothing. Q. Did you-all live together at some point? A. I asked her to -- she asked me if she could room with me when I was living in my trailer and 1 gave her a chance. About a week later 1 found out that she was not the kind of friend for me at all and she was into no good things. And I have a son so I couldn't have her around. Q. What do you mean she was into no good things? A. She was into drugs and stealing and -- 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 629 A. Yeah. Q. And she threatened to kill you? A. Yeah, she threatened a lot of stuff. Q. And did you believe she had the capacity to do that? A. No. Q. What gang was she in? A. y(phonetic). Q. did you know her to be a violent person? A. Yeah. But she's like 80-pounds soaking wet so Tut not worried about her. She's just lost and God bless her soul. Q. Now, let's talk about Mr., is it =or a (phonetic)? Q. "And you have described earlier a confrontation that you had with him. And was his mother present for that confrontation? A. Yes. Q. And, and did it initially start out that Mr.thr was physically abusive towards his mo A. Yes. I had told him to leave and his mother came to pick up his daughter from my house. When she Page 628 1 Q. Did you and she have a physical 2 confrontation? 3 A. She brought --1 told her when she moved in 4 for that one week I told her do not bring anyone into 5 this house. She brought a man into my house. I opened 6 her bedroom door, found her giving him oral sex. I got 7 angry. I said, please leave. She was on drugs. 8 She got angrier and came into the bathroom 9 and hit me or tried to hit me on my head. So, I 10 pretty much held her down until the cops came 11 because 1 called the cops to get her out. 12 Q. Was it an upsetting event to you? 13 A. No. I just couldn't wait for her to get out. 14 Q. Was that a common thing for you to have 5 fistfights with other women? 16 A. No. I didn't throw a fist. No, it was not a 17 common thing. 18 Q. And did she threaten you on the way out? 19 A. Yes. 20 Q. And you said she was in a gang? 21 A. Yeah. 22 Q. And what did she tell you on the way out? 23 ' A. O6,1 don't remember. I'm going to regret it. 24 Q. Well, did she say, I am going to get you, 25 bitch? 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 630 arrived, he started pushing and shoving his mother into the car. I could tell that he was on drugs. So, I said this is uncalled, uncalled for. I called the cops and that was that. He ran. I guess you can say 1 have a good heart and I give the wrong people chances. Q. Well, that was one incident when, when the mother was present, right? A. Yes, and that night actually -- Q. There was a second incident, was there not? A. Yes. That night he — that's when he pushed me down a couple times and that's when I hit him and then he spit blood all over the house. And that's when immediately moved out of the house and moved to D, DCF got involved. So, 1, three days later, And the next thing I know the week that 1 move . wed at m house. 33 (Pages 627 to 630 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins IDS542lef-d299-4e4f-94a6-55aad27f4405 EFTA01076191
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Page 631 213 4 5 6 7 8 9 .10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 34 (Pages 631 to 634) PROSE COURT REPORTING AGENCY, INC. 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 633 Page 634 1 A. Yes. 2 MR. LUITTER: Let's mark this as our next, 3 whatever number we're on. 4 THE COURT REPORTER: Five. 5 MR. LUTTIER: Five. 6 (Defendants Exhibit No. 5 was marked for 7 identification) 8 BY MR. LUTTIER: 9 Q. Let me show you what is now marked as 10 Exhibit 5 and ask ou if that's a co of the 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fel-d299-4e4f-9ba6-85aad27f4405 EFTA01076192
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Page 635 2 3 4 5 6 7 8 9 10 11 12 13 1.4 15 16 17 18 19 20 21 22 23 24 25 Page 636 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 35 (Pages 635 to 638) PROSE COURT REPORTING AGENCY, INC. Page 637 1 2 3 4 5 6 7 8 9 10 MR. LUTT1ER: Let me mark that as 6, our 11 next. And ask you if you can identify this 12 document. 13 (Defendants Exhibit No. 6 was marked for 14 identification.) 15 THE WITNESS: I've had some crazy 16 boyfriends, but for three years everything's 17 been fine. 18 BY MR. LUTHER: 19 Q. Let a show ou what has been marked as 20 Exhibit 6. 21 22 A. tat a outa. 23 MR. EDWARDS: lie was just showing it to 24 you. 25 THE WITNESS: Yes, I saw it before. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 638 Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b6642/04112994,4f4balaudilt4406 EFTA01076193
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1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 639 MR. LUTTIER: I need to take a quick break. THE VIDEOGRAPHER: Going off the record at 4:19 p.m. (A brief recess was held.) THE VIDEOGRAPHER: We're back on the record at 4.30 p.m. BY MR. LUTTIER: Q. Do you actually, yourself, call Mr. Epstein's home asking him if you could come work, did you not? MR. EDWARDS: Object to the form, predicate, time-frame. Page 641 3. A. No. 2 Q. Do you know if any of them have consulted 3 with any lawyers about that other than your lawyers? 4 A. No. What they want to sue me along with S Jeffrey? 6 Q. Have you ever discussed yourself with them 7 their feelings about you having taken them to see 8 Mr. Epstein? 9 A. Yeah. 10 Q. ./that did they tell you? 11 A. is very sensitive towards it. She 12 didn't like it at all. She just was a poor little girl 13 that I guess was influenced by me to go to Jeffrey's 14 house. 15 Q. But I mean has she ever asked you why did 16 you do that knowing what you knew or anything like 17 that or said she holds you responsible? 18 A. In 'don't 'mow the exact words but 19 she's definitely came to me and said why would you even 20 do that, why would we go there? You know, it, it hurts 21 our self-esteem. 22 And in M.'s aspect she was extremely 23 scared to go the first time. And me being one of 24 her best friends at the time, she just finally wont 25 after I begged her many times when I couldn't fmd Page 640 1 BY MR. WITIER: Q. During this period of time that you were 3 going to see Mr. Epstein. Sometimes you called and 4 asked his people at his house whether, you know, you 5 could come work, did you not? 6 A. Yeah. Because he told me to call if I had a 7 girl. SO, I would call and ask is he available. 8 Q. Now, I want to askot couple questions 9 about your ttke friends, and again M. 10 A. Excuse me. 11 Q. You took to Mr. Epstein, did you 12 not? 13 A. Yes, I did. 14 Q. How many times did you take her? 15 A. I dolifiv. 16 Q. Has or III. or anyone else that 17 you took to Mr. Epstein discussed with you or anyone 18 else that you know of the potential for them suing 19 you? 20 A. Who suing me? 21 Q. My girl that you took to Mr. Epstein. 22 A. No. • 23 Q. Do you know if any of them talked to their 24 lawyers about suing you as a result of you taking 25 them to see Mr. Epstein? 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 ti 4006......146.44.114 ••••>...•••••••• Page 642 any other girl. And no, they both didn't like it. Who would like it? Q. Did you have any friends better then M, You know, would you consider her, she was your best friend, or is your best friend? A. At that time, no. Q. Who is your best friend now? A. Q. .How about now? A. My son. Q. Okay. Other than your son, a friend not family. is she, is she your best friend still? A. Jesus, myself, my son. Why are you looking at me crazy? Q. Is she your best friend was the question. A. I don't have a best friend. Actually, yes, l do. Q. Who? A. Q. Who is she? A. Q. Is she another person that is suing Jeff Epstein? A. Nope. She was affiliated with who died. 36 (Pages 639 to 642) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b5542fef-d299-4e41-9ba13.85aad27f4406 EFTA01076194
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643 Page 645 I Q Wbala? 2 A. Yeah. 3 4 'allow was she affiliated with 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page A. She was good friends with ha and I met through her. And If took to Jeffiey Epstein's house. Q. Where does live? A. Rhode Island. Q. Do you have the phone number for this babysitter you say you use? A. Yes. Q. A. Yes. Q. What's her number? A. I don't know it off the top of my head. Q. Is she listed in the phone book? A. Probably. Q. Is she — you say she lives in the Acreage? A. Yes. Q. Is she married? A. No. Q. Have you ever been to her house? A. Yeah. 1 times you actually went? 2 MR. EDWARDS: Form. 3 THE WITNESS: What does that mean? 4 MR. EDWARDS: Answer if you know what that 5 means. Do you have physical proof, videotape. 6 Answer his question if you know what the answer 7 is.. THE WITNESS: No. No one videotaped me 9 and no, we didn't keep a log, no. 10 BY MR. LUTIIER: 11 Q. There is no record that you could consult 12 that would say I !mow I went 21 times or exactly how 13 many times because you kept a record of it? 14 MR. EDWARDS: Font 15 THE WITNESS: No. 16 MR. EDWARDS: This is outside of whatever 17 records are in your client's possession. 18 BY MR. LUTTIER: 19 Q. And since you and ed.. are 20 all represented by the same lawyer, do you recognize 21 that there is an inherent conflict amonathree 22 in terms of any accusations that M. and 23 would have against you for taking them to 24 Mr. Epstein? 25 MR. EDWARDS: Object to the form. Page 644 Q. Does she rent, does she own, do you know? A. No. Q. Live alone or with somebody else? A. Her brother. Q. Same last name -- A. I don't know. as her and her brother, last name is 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 • 22 23 1 2 2 3 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 BY MR- LUTTIER: 24 25 Q. And you have no physical proof of how many 25 A. I don't know. • THE VIDEOGRAPHER: Your Sc is on your chair. BY MR. WITTER: Q. Now, you've told us when you believe you first went to Jeffrey Epstein and when you went the last time. If I and I may have asked you at the last deposition: You have no physical proof of when you actually went, right, the actual dates that you went? MR. EDWARDS: Object to the form. MR. LUTTIER: That would be like a calendar or notes, something like that. MR. EDWARDS: Form. THE WITNESS: Nope. PROSE COURT REPORTING Page 646 THE WITNESS: I don't understand what the hell — BY MR. LUTTER: Q. There is a conflict of interest. Mr. Edwards can't represent one, one client suing another one of his clients; you recognize that, don't you? MR. EDWARDS: Form. THE WITNESS: Okay. BY MR. LU1TIER: Q. Have you seen deposition? A. No. Q. Have you been told anything about it? A. No. O. Have you been told anything about case . A. No. Q. Who is actually representing you now? Do you know the name of the law firm that now represents you? A. Whatever this law firm's called. Q. Is it — did you sign a new fee agreement with the new law firm? A. Yes. Q. So, it's whatever firm IMINIM is now 37 (Pages 643 to 646) AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421ef-d299-4e4f-9ba6.85and2714405 EFTA01076195
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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 647 with? A. Yes. Q. meet any of the people from the A. No. ' any investigators from the A. No. Q. Have you ever been interviewed by any of the investigators from there? A. No. ar Do you know a man by the name of II A. No. Q. Ha v heard of his name? A. Q- A. No. Q. Do you have this babysitter's phone number in your cellphone? A. No. I don't keep it in my cellphone. Q. You, you don't keep your babysitters number in your cellphone? A. No. Q. And you don't have it memorized? Page 648 1 A. No. 2 Q. So, what do you have to do when you want 3 to call a babysitter? 4 A. Ifs at home. 5 Q. So, if you're out and about and you need 6 to call the babysitter and tell her you'll be 7 A. I usually keep it in my purse. 8 Q. — there late you don't have any way to do 9 that until you get home? 10 A. I usually keep it in my purse and I am not 11 late. 12 Q. Where do you keep it? Do you have a phone 13 book in your purse? 14 A. No. I have a piece of paper with her number. 15 Q. Okay. Do you have that with you here 16 today? 17 A. No. 18 Q. So, as you sit here todq=illo not have 19 on your person anywhere Ms. phone number, 20 is that right? 21 A. I do not have her number with me, no. 22 Q Do you know somebody by the name of ■ 23 (phonetic)? 24 A. No. What time is it? 25 Q. 4:41. Page 649 1 A. Okay. I have to pick my son up by 6 so — 2 MR. EDWARDS: Well be done. 3 BY MR. LUTHER: 4 Q. At the beginning of this deposition you 5 asked a question about whether or not somebody else 6 was going to be here I think on behalf of you. And 7 you made some reference to somebody you had met with 8 about this deposition. Do you recall making that 9 statement, asking whether or not this other person 10 was going to be here? 1 A. Uhhuh, yes. 12 Q. Who were you referring to? 13 A. His name is I don't know his name. 14 Q. Is it a lawyer? 15 A. Hp's an attorney. 16 Q. Not a paralegal. A guy named Fanner, 17 Mr. Farmer? 18 A. I daft know. 19. Q. Have you net this other person? 20 A. Yes. 21 Q. Where did you meet this other person? 22 A. At the law firm. 23 Q. Mr. Edward's law firm? 24 A. Yes. 25 Q. Down in Fort Lauderdale? 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 650 A. Yes. Q. So, you've been down to his new law firm? A. Yes. Q. Did you review anything in preparation for today's deposition? A. Yesterday I talked to my attorney. Q. Did you review any documents? A. I reviewed a document, yes. Q. What document? A. I don't know. I don't know what document, sir. Sorry. Q. You say you reviewed a document or documents? A. I reviewed a document. Q. One piece of paper? A. A few, a few pieces of paper. Q. Okay. What were they? What did they have on them? MR. EDWARDS: Objection as to this line of questioning calls for attorney-client privilege information. She's not going it answer it as to exactly what we went over in preparation for the deposition. BY MR. LUTTIER: . Other than notes created by our lawyer ewe 38 (Pages 647 to 650) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421ef-d299-4e4f-aba6-85aad2714405 EFTA01076196
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 651 which I don't want to know about, did you review any other documents in preparation for your deposition? A. No. I have to be out of here at 5:30. Q. Did you ever hear anything about how your case may have been involved in any of that? A. No. It's irrelevant to me right now. Q. Does that mean you have never heard Page 653 1 in the garbage. 2 Q. Well, at the time we took your deposition 3 in September, you told us under oath that it was at 4 your home. Did you do something with it since -- 5 A. No. 6 Q. — your deposition on 7 A. No. 8 Q. Well, it just didn't disappear, did it? 9 MR. EDWARDS: Form. 10 THE WITNESS: No. Are you being sarcastic 11 with me? 12 BY MR. LUTHER: 13 Q. No. I mean you had to do something with 14 it, right? 15 MR. EDWARDS: Form. 16 THE WITNESS: I didn't touch it. I can't 17 find it. I don't know where it is. It's not 18 in the house, so, song. 19 BY MR. LUTTIER: 20 Q. Well, where did you think it was when you 21 testified definitively that it was in your home? 22 A. I thought it was in a couple of my papers that 23 I have and it's not. I thought it was where my Social 24 Security card was. It's not them, sir. End of 25 dismission. Page 652 1 anything or you just disregarded what you heard? 2 A. I disregarded what I heard. 3 Q. So, what did you hear? 4 MR. EDWARDS: You're asking her though 5 what she heard outside of any conversation with 6 me obviously? 7 MR. LUTHER: Yeah, oh, yeah. I don't 8 want you to tell me, I don't want you to ever 9 tell me anything your lawyer told you. 10 THE WITNESS: Oh, no, I didn't hear 11 nothing. 12 BY MR. LUTTIER: 13 Q. Okay. Now, in your previous deposition 14 you indicated that you had a book. I think you said 15 it had a red — it was a red book. !don't remember 16 if the color was right and you said it had a Bible 17 verse on it. Do you remember that testimony? 18 A. Yes. 19 Q. And at that deposition you told us 20 definitively that you had that at your home? 21 A. Yes. 22 Q. Where is that book now? 23 A. I can't find it. It's nowhere to be found. 24 Q. Well, what did you do with it? 25 A. I don't know. I moved a lot so it's rehab! 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 654 Q. Do you know the names of any of your clients that you had when you were working — other than the ones you've aheady identified here, clients you had when you were working for any of the escort services? A. No. Why would they want me to know their names? I don't want to know their names either. Q. I have no idea. A. They have wives. Q. All your clients have wives? A. Probably. We don't — it's not about relationships, man. It's about — Q. When you were wmtirag for those — A — mo and out. MR. EDWARDS: Form. MR. LUTTIER: Right? MR. EDWARDS: Fonn. BY MR. LUTTIER: 39 (Pages 651 to 654 PROSE COURT REPORTING AGENCY,. INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins b55421ef-d299.4e41-9ba6.85aad2714405 EFTA01076197