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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 JANE DOE $17 - VOLUME III (videotaped) Monday, March 15, 2010 10:02 - 6:49 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RMR, CRR Notary Public, State of Florida (561) 832-75CC PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge 1201.272-617.4627) folb2074.4669-434d-ac93-054696fd7921 EFTA01107876
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EFTA01107877
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Page 299 Page APPEARANCES: On behalf of the Plaintiffs in related cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 0840381, os-so993, 08-86994: ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, PA. 18205 Biscayne Boulevard Suite 2218 6 Min4,040. 7 8 On behalf of the Defendant Jeffrey Epstein: 9 ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITION, LUTHER & COLEMAN 10 303 Banyan Boulevard Suite 400 11 West P 33401 Teleph 12 13 14 Also Present: Socha Quimby, videographer 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 PROCEEDINGS THE VIDEOGRAPHER: We are back on the record at 4:08 pm. BY MR. CRITTON: Q. Jane Doe 7, in your supplemental answers to interrogatories, you listed the names and addresses and phone numbers, number 18, and I don't know whether I used that as an exhibit — this will be Exhibit 9. (The document was matted Defendant's Exhibit 9 for identification.) BY MR. CRITTON: Q. There area couple of supplements you filed which as things come to you, I think, or your attorneys. Anyhow, this one deals with males that you had sexual activity. You listed Mr. Evans, Bryant — MR. HOROWITZ: You handed us two different things. This is a request to produce. MR. CRTITON: Oh, Tin sorry. MR. HOROWITZ: No problem. MR. CRT TON: Give this back. This will be number nine. (Discussion held off the record.) BY MR. CRITTON: Q. Is that the right one that has Mr. Evans? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 300 - - - INDEX WITNESS: DIRECT CROSS REDIRECT RECROSS Jane Doe #7 By Mr. Critton 5 EXHIBITS EXHIBIT PAGE Defendant's 1 233 Defendant's2 233 Defendant's 3 233 Defendant's 4 263 Defendant's 5 268 Defendant's 6 274 Defendant's 7 280 DePeadant'S 8 294 Defendant's 9 301 Page 302 1 There is a person listed as Bryant. Who is he? 2 A. He a friend from Orlando. 1 kind of dated 3 him. 4 Q. And so of the five individuals you have here, 5 Mr. Evans, Bryant, Mackenzie Russell, PJ Tao and Blake 6 Russell, are the only individuals with whom you have had 7 any type of sexual activity since the time you were ten 8 years old? 9 A. Yeah, other than like kissing. I don't 10 remember everybody I kissed and stuff like that. 11 Q. All right. 1 want to go back to a couple of 12 areas to make sure I got all the information on it. 13 At the time that you met with the officers 14 from Palm Beach, you said, do you remember one of them 15 being a person named Recarey, R-e-c-a-r-e-y, 16 Officer Recarey7 17 A. Yes. 18 Q. I think you said there were two males. Do you 19 remember who the other male was? 20 A. I think his name was Joe something. 21 Q. Joe something, all right. And, Mr. Recarey's 22 first name, Detective Recarey's first name is Joe 23 Recarey. 24 A. Oh, sorry. 25 Q. Do you remember what the other person looked '(561) 832-7500 PROSE COURT REPORTING AGENCY, 2 (Pages 299 to 302) INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617.4627) Electronically signed by Rachel Bridge (201-272-617.4627) le3b2074.4669-4a4doe93-8546961d7921 EFTA01107878
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Page 303 Page 305 1 like? Not Mr. Recarey, but the other one. 2 A. He was like just an older man. He was kind of 3 bigger, gray hair, I think. 4 Q. All right. And in terms of that individual, 5 did he say anything or was it Officer Recarey who 6 conducted the interview with you? 7 A. I think it was Officer Recarey mostly. 8 Q. Did you eves have any subsequent contact with 9 him? Did you ever talk to him after the interview on 10 October 4th of 2005? 11 A. I don't think so. I don't remember. 12 Q. When he talked to you, that is, when he 13 introduced himself to you, did he explain to you how he 14 found you, that is, how he knew that you may have had 15 some involvement with Mr. Epstein? 16 A. I think it was somebody told him. 17 Q. Did he tell you who the somebody was? 18 A. No. 19 Q. Did he tell you when you met with him, and 20 again before he started the tape of the statement, did 21 he tell you that, that he had interviewed a number of 22 other females? 23 A. I don't remember if he told me that or not. 24 Q. Did he tell you, you know, tell us everything 25 because we've heard stories from other people, so we 1 car? 2 A. Yeah, I think so. 3 Q. So they actually showed you, was it a color 4 picture or black and white picture? 5 A. .Black and white. 6 Q. So they actually had a picture of what, the 7 rear of your car that had the license plate number? 8 A. I'm almost positive. 9 Q. So when they showed you the picture of your 10 car, and you had said that earlier in your testimony, 11 you recognized right away as they knew that you had been 12 there? 13 A. Yes. 14 Q. All right Did you ask him how old the 15 picture was? 16 A. No, I didn't. 17 Q. And they just said that they had had him under 18 some surveillance fora period of time? 19 A. Yes. 20 Q. Did they show you more than one picture of 21 your car so that, that suggested that they had taken a 22 picture of your car on a number of occasions? 23 A. No. 24 Q. Did they tell you whether they knew any other 25 people who had been to his house? That is, did they use Page 304 1 have an idea of what may have occurred at Mr. Epstein's 2 house? 3 A. Like front the very beginning of me going? 4 Q. No, no, no. When you first met with him after 5 you sent Mom back into the house, did Officer Recarey 6 say to you "Hey, lane Doe 7, you can tell us what went 7 on because we've heard stories from other people, so 8 tell us everything that happened"? That is, did he try to make you comfortable so 10 you would talk to him? 11 MIt HOROWITZ: Form 12 THE WITNESS: I don't exactly remember what he 13 said, but basically he showed me the picture of my 14 car or my license plate or something. He said that 15 they have been like watching Jeffrey and they know 16 I've been there because they saw my car there. 17 BY MR. CRITTON: 18 Q. Okay. Did they tell you how long they had 19 been watching Jeffrey? 20 A. No, I don't think so. 21 Q. Did you get the impression that over the last 22 few months they had been watching him? 23 A. Yes. 24 Q. Okay. And so the picture they had, did they 25 have an actual picture of your license plate on your 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 306 any names? A. I think they j ust said other girls in my high school. Q. And the only name you gave them was Jane Doe 4? A. AndM Q. IMI:tid you give t hem too? A. And S.V., yes. Q. Did they show you any other photographs of either his house, any other cars, any other vehicles, or was it just yours? A. I think tlisiright have -- yeah, they showed me a picture of = and they asked ra tify the girl in the picture, and I identified her Q. Did you ever Imw what last name was? A. It began with al, something. Q. Did she ever introduce herself to you? A. Yes. Asil=, or did she just say my name is A. I don't remember. Q. Was she nice to you? A. Yes. Q. Friendly? A. Yes. ata....Gittet•a•45,40 , (561) 832-7500 3 (Pages 303 to 306 PROSE COURT. REPORTING. AGENCY; INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-6174627) Electronically signed by Rachel Bridge (201-272-617.4627) fe3b2074-4669-4a4d-ac93-054696fd7921 EFTA01107879
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Page 307 1 Q. How old did you thinavms? 2 A. She looked about in her nu twenties. 3 Q. All right. And did you tell them that? Did 4 they ask you about her at all? 5 A. Yes. I think they just asked if I recognized 6 her and just asked what I saw her doing there and stuff 7 like that. 8 Q. And I think you said earlier that. called 9 you during the time, either just before or urmg the 10 time you were being interviewed by the police? 11 A. Yes. 12 Q. And did you take her call? 13 A. No. 14 Q. Did you call her back? 15 A. No. I just listened to her voicemail. 16 Q. What did — did you play the voicemail for the 17 police? 18 A. Yes. 19 Q. Okay. And did they record it? 20 A. I think so, yes. 21 Q. What did the voicemail say, to the best of 22 your knowledge or recollection? 23 A. Just that "Hi, Jane Doe 7, this is M." I 24 think she just asked if there was cops at my house and 25 if I was talking to them. And she said for me to call Page 309 1 he suggest things, like we know this, we know that? 2 Like your car, we know you were there because here's a 3 picture of your car and your license plate. Isn't that 4 your car and license plate? 5 MR. HOROWITZ: Form. 6 THE WITNESS: The only thing he suggested is 7 he just kind of knew I was there, so — 8 BY MR. CRITTON: 9 Q. Did he ever tell you what some of the other 10 females had said had occurred at Mr. Epstein's house? 11 A. I don't remember exactly what he said to me. 12 Q. Did they ever tell you that some of the other 13 females were saying that Mr. Epstein did X or Y with 14 them? X or Y could be anything, but did he say well, we 15 know Female ABC did such and such, or at least she says 16 she did such and such with Mr. Epstein or he did such 17 and such with her? 18 Did he suggest that? 19 A. I don't remember. 20 Q. Did they ever say and I think they asked 21 you, because I asked you earlier and you had told them 22 that at least in the visit that you had under oath with 23 them is that you had, he had not masturbated when you 24 were there, correct? 25 MR. HOROWITZ: Form. Page 308 1 her back. 2 Q. But you never did? 3 A. No. They told me not to. 4 Q. They being the police? 5 A. Yes. 6 Q. Did they tell you anything else to do or not 7 to do? 8 A. Just not really to talk about it with anybody. 9 Q. Did they tell you not to tell your parents? 10 A. No, they never said that. 11 Q. Did they tell you that if somebody called you 12 on behalf of Mr. Epstein not to talk to them? 13 A. Yes. 14 Q. Did they mention at that time anything about 15 the US attorney or the FBI? 16 A. No. 17 Q. Did anyone else, did either Officer Recarey or 18 anyone else from Palm Beach ever try to recontact you 19 for a followup interview or to clarify something? 20 A. No. 21 Q. And I think you told me earlier they never 22 sent you anything? 23 A. No. 24 Q. When Officer Recarey was talking to you, did 25 he — and i don't mean this in a negative way, but did Page 310 1 BY MR. CRITTON: 2 Q. mars what you told them that day? 3 MR. HOROWITZ: Form. 4 THE WITNESS: I believe so. 5 BY MR. CRITION: 6 Q. And did they say "Well, other females had said 7 that Mr. Epstein masturbated, did he do that when you 8 were there?" 9 Did they suggest things like that in askinr 10 questions? 11 A. !thinks*, yes. 12 Q. Okay. And did he reassert to you, did he tell :3 you at any time "You can tell us anything, you are not going to get in any trouble"? 15 MR. HOROWITZ: Form. 16 THE WITNESS: I don't remember if he said that 17 or not. 18 BY MR. CRITTON: 19 Q. Well, did he ever say to you if in fact you 20 received money for having taken people to Mr. Epstein's, 21 you could be charged with a crime under Florida law? 22 Did he tell you that? 23 A. No. 24 Q. Okay. Did he ever read you your Miranda 25 rights? (561) 832-7500 PROSE COURT REPORTING. AGENCY, 4 (Pages 307 to 310 INC. (561) 832-7506 Electronically signed by Rachel Bridge (201.2724174827) Electronically signod by Rachel Bridge (201.2724174627) fc3b2074.4669-4a4d-ac93-e54696td7921 EFTA01107880
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Page 311 Page 313 1 A. No. 2 Q. Were you concerned that you might be charged 3 with a crime? 4 A. Yes. Q. Because you thought you had committed a crime? MR. HOROWITZ: Form. THE WITNESS: I just thought I was going to 8 get in trouble for going there. 9 BY MR. CRITTON: 10 Q. Dkly also said that 11 called you eras you described. 12 Did you know who she was before she called 13 you? 14 A. No. 15 Q. She just called you out of the blue one day? 16 A. I think she called me and — actually, I think 17 Agent Nezbit from the FBI might have told me something 18 that she, she was the attorney general maybe, I think 19 I don't 20 Q. Nezbit is the female FBI agent, correct? 21 A. Yes. 22 Q. And then when she came to (bland° to meet with 23 you and you met at Starbuck's, she had a male agent with 24 her as well? 25 A. Yes. 1 THE WITNESS: I think so. 2 BY MR. CRITTON: 3 Q. Did she have the statement that you had given 4 to the Palm Beach police? 5 A. I think so, yes. 6 Q Did she ask you about the statement? That is, 7 did she quiz you from the statement? 8 Did it sound like she had a transcript of your 9 statement so she was asking you questions, did this 10 happen, did that happen? 11 A. Yeah, she basically asked me if what I told 12 the Palm Beach police was true. She said that she knew, 13 you know, a lot of girls did a lot more things with 14 them, what I have said, and she basically knew, you 15 know, I felt that she knew a lot more. 16 So 1 just told her the truth, that 1 lied to 17 them and that I finally, you know, broke down and told 18 her everything that happened. 19 Q. And did she encourage you to do that? I mean 20 did she tell you "A lot of other girls have come forward 21 and said XY, that XYZ happened at Mr. Epstein's, so 22 please tell us everything"? 23 MB. HOROWITZ: Form. 24 THE WITNESS: Well, she kind of acted like she 25 already knew and she knew a lot more went on than Page 312 1 Q. And I think you said you spent an hour and a 2 half, two hours with them? 3 A. Yes. 4 Q. And you recall that they took a taped 5 statement from you? 6 A. Yes. 7 Q. Much like FBI did — Pm sorry, much like the 8 Palm Beach police did? 9 A. Yes. 10 Q. Did they talk to you fora period of time 11 before they turned on their tape recorder? 12 A. I don't remember. 13 Q. You just remember them taking a taped 14 statement? 15 A. Yes. 16 Q. Okay. Did they also take notes? 17 A. Yes. 18 Q. And who was taking the notes, the male or the 19 FBI Agent Nezbit? 20 A. The male was. 21. Q. And was the Agent Nezbit, was she, did she 22. !mow that you had let me strike that. 23 Did she have the benefit of any information 24 from Palm Beach? 25 MR. HOROWITZ: Form. Page 314 1 what I told the officers in Palm Beach. 2 BY MR. CR1TTON: 3 Q. And whether she did or not, you don't blow, 4 that's how she played it, so to speak? 5 A. Yes. 6 Q. All right. Did, after the hour or two that 7 you spent with Agent Nezbit, was she someone who — did 8 you get emotional with Agent Nezbit? 9 A. Yeah, I mean I felt like i could like open up 10 to her more than I could guys, you know. 11 Q. Did she give you a hug when you left? 12 A. No. 13 Q. Shake hands? 14 A. Yes. 15 Q. Was she warm, comforting? 16 A. Yeah, she was nice. 17 Q. And did she give you her card and say "Jane 18 Doe 7, If you ever have any issues associated with this, 19 you can call me any time at this number"? 20 A. Yes. 21 Q. All right. And did you ever call her? 22 A. Yes, I called her a couple of times. 23 Q. For what? 24 A. Just called her to ask what was going on with 25 the case and if she heard any news and things like that. (561) 832-7500 5 (Pages 311 to 314) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201.272.617-4627) Electronically signed by Rachel Bridge (201.272.617-4627) fo3b2074-4669-4a4thac93 05469610921 EFTA01107881
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Page 315 1 Q. Did you ever call her back to get the name of 2 an attorney? 3 A. No. 4 Q. And I think you told me she said if you ever 5 need the name of an attorney, she could give you one, 6 but you would have to call her? 7 MR. HOROWITZ: Form. THE WITNESS: I think Marie was the one that 9 said about the attorney stuff. 10 BY MR. CRITTON: Q. Okay, when she called you, when she, meaning 12 Marie,calkdyaa 13 A. (Witness nods head up and down.) 14 Q. Did Officer Nezbit ever call you independently 15 of you calling her? 16 A. About what? 17 Q. Whatever. 18 A. No. 19 Q. You said you called her on two occasions to 20 find out status. 21 A. Yeah. 22 Q. Okay. And I think you told me you don't know 23 when you first talked to her. 24 A. She called me again to ask me if there were 25 any details that I left out or anything like that Just Page 317 1 A. Maybe a month maybe. 2 Q. Did they arrange that before they came back up 3 or did they call you out of the blue? 4 A. Well, no, they arranged it to come back up. 5 Q. Why did they tell you they needed to see you 6 again? 7 A. They just wanted to make sure everything was 8 correct and go over everything with me again. 9 Q. Did they have like a statement that they were 10 now reading ftom? 11 Did they have an outline that they were 12 reading from when they came to meet with you on the 13 second occasion? 14 A. I don't remember. 15 Q. How long did that meeting last? 16 A. I think about an hour. 17 Q. And It was just the two of them? 18 A. Yes. 19 Q. Did they record you at that occasion again? 20 A. I think so, yes. 21 Q. So on both occasions that the FBI met with 22 you, you recall them taking a recorded statement from 23 you? 24 A. Yes. 25 Q. Or recording the session, correct? t Page 316 1 basically asked me if I remembered anything. She called 2 me about that. 3 Q. All right. And you told her what? 4 Did you add any details? 5 A. I don't remember. 6 Q. That's when she called you? 7 A. Yes. 8 Q. Okay. And then, and that's the only time she 9 ever called you after the first interview? 10 A. Well, no, they came back up to Orlando. 11 Q. A second time? 12 A. Yes. 13 Q. Oh, I didn't know that. All right, they came 14 back a second time. Meet at Starbucks again? 15 A. No, we met at the Radisson. 16 Q. All right. Were they staying there? 17 A. I think, yeah. Well, I don't know if they 18 were staying there or not actually. 19 Q. Where did you meet, in the restaurant? 20 A. No, we met like in a conference center. 21 Q. Who was t ere other than you? 22 A. The same two people, just me and her and the 23 same guy. 24 Q. How much time transpired between the first 25 visit and the second visit? Page 318 1 A. Yes. 2 Q. And on the second occasion did you provide 3 them any additional information? 4 A. I don't remember. 5 Q. Did they provide you any additional 6 information, such u we've talked to a number of other 7 females and they have told us X, Y and Z, did this 8 happen? Did that happen? 9 MR. HOROWITZ: Form. 10 THE WITNESS: I think they, yeah, they just, I 11 think they, yeah, said something like that, yeah. 12 BY MR. CRITTON: 13 Q. So they gave you some more at least 14 information. Again, you don't know whether it's true or 15 not, but they said "Well, we found out this or we found 16 out that. Did that happen to your 17 Did they ask questions like that? 18 A. I believe so. 19 Q. All right. Did they, after that second 20 occasion, did they ever recontact you? 21 A. Agent Nezbit did, just, she would call me and 22 fill me in on what was going on. 23 Q. How many more times did Agent Nezbit call? 24 A. I think once or twice after that. She didn't 25 call me a lot. 6 (Pages 315 to 318) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Sectronically signed by Rachel Bridge (201-272417-4627) Electronically signed by Rachel Bridge (201.272.817.4627) fo3b2074-4669-4a4d-ac93-05469431d7921 EFTA01107882
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!age 319 1 Q. Did she ever ask you what your feelings were 2 about any criminal prosecutions directed to Mr. Epstein? 3 A. No. 4 Q. Pardon? 5 A. No. 6 Q. Did you know who -- andIn asked you 7 et me just clarify it. Before 8 called you, did know who she was? 9 A. I want to say I don't remember. I think Agent 10 Nezbit might have said something about her to me. And 11 then she just called and -- 12 Qi.th:iiitifishat she said, she, Nezbil 13 said 14 A. No. It was towards the end of everything, and 15 I think she just updated me on everything that was going 16 at. Might have told me like who she was. 17 Q. And at the time, so if — and !know that, I 18 think you said that at the time that you spoke with Jane 19 Doe 4 in the summer of '08, you did not have an 20 attorney, a your recollection was you didn't think you 21 had an attorney at that time. You may have spoken with 22 Mr. Herman tut you may not have had an attorney. 23 Son= would have had to have spoken with 24 you sometime before Jane Doe 4 came to stay with you in 25 the suntmer of '08; is that your best recollection? 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 321 questions. Q. And you said a lawyer to protect yourself. Protect yourself from what? MR. HOROWITZ: Form. BY MR. CRHITON: Q. What did she tell you? A. I don't, I don't know what she was referring to. Q. Okay. Did she tell you you might have a civil claim or you would have a civil claim against Mr. Epstein? A. No. Q. Did she tell you the deal that the government had worked out or was attempting to work out would provide a civil remedy for individuals who had gone to Mr. Epstein, females who had gone to Mr. Epstein's house? A. No. Q. Do you ever remember receiving a letter from her that said you may have a civil remedy that you can pursue under a specific federal statute? A. I think I received a letter, but I don't remember what it said. It might have said something like that. Q. Do you ever remember receiving a letter from Page 320 A. Yes. Q. Do you remember how many months before Jane Doe 4 came there that you would have spoken wit A. Probably I think a while. Probably like, I don't know, six months. 7 Q. All right. And you only spoke with her on 8 that one occasion? 9 A. Yes. 10 Q. Did she ever tell you elf you ever have any 11 questions, you can call me? 12 A. Yeah, she gave me a number to call. 13 Q. Did you ever follow up and try to call her for 14 any reason? 15 A. No. 16 Q. When she filled you in on what was going on, 17 what exactly did she say to you? 18 A. She just told me about the criminal case. I 19 forget exactly what she said. 20 And then she just explained all the like legal 21 terms and what was going on. She said, you know, "Other 22 people am getting lawyers, if you want to protect 23 yourself, you know, you could get a lawyer too" 24 But she didn't give me any names or numbers, 25 but she did give me a number to call if I had any more Page 322 1 Robert Josefsberg from Podhurst Orseck saying he was the 2 attorney representative who had been appointed to 3 represent individuals who the government had deemed to 4 have been, quote, unquote, victims? 5 A. No, I never got a letter from Mm. 6 Q. Did you ever hear from any other government 7 agent, government agent for the United States government 8 who purported to work for thegovernment other than the 9 two FBI agents an 10 A. No, I don't think so. 11 Q. Did you ever hear from anyone else associated 12 with any other police department other than 13 Officer Recarey and whoever the other Palm Beach police 14 officer was? 15 A. No. 16 Q. Did your dad know any of the officers. having 17 been associated with the Town of Palm Beach or employed 18 by the Town of Palm Beach? 19 A. No. 20 Q. Did he ever see anyone in the Town of Palm 21 Beach about this situation, to your knowledge? That is, 22 did he ever go talk to the mayor or the chief-of-police 23 about you and Mr. Epstein? 24 A. No. 25 Q. Other than the time that you told your mom and 14.....•••••44 (561) 832-7500 PROSE COURT REPORTING AGENCY, 7 (Pages 319 to 322) INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272.617.4627) Electronically signed by Rachel Bridge (201-272-617.4627) fab20744604•44•03464N6fdril21 EFTA01107883
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1 2 3 4 S 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 323 your dad, you disclosed to them, that is the day that Officer Recarey was there, October 4 of 2005, has your mom ever discussed it with you? Not necessarily the details, but how she feels about it. A. I mean she's read the newspapers and obviously she doesn't like him, but I mine she actually didn't want me to go ahead with the lawsuit. Q. She didn't? A. No. Q. Why not? MR. HOROWITZ Form. BY MR. CRITTON: Q. What did she tell you? A. She thought it would bring more stress and anxiety on me. Q. Has it? A. I mean, of course, hearing everything, hearing his name brings anxiety and I get depressed and sad over it, yeah. Q. Over the lawsuit? MR. HOROWITZ: Form. THE WITNESS: Not just over the lawsuit, but hearing his name, it brings back memories. BY MR. CRITTON: Q. How about your dad, how did he feel about the Page 325 1 County to work? 2 A. No. They just said wherever I get a job at. 3 Q. Okay. In terms of your parents, are you 4 closer, like if you had a personal problem or an issue, 5 would you more likely call your mom or your dad? 6 A. I mean either one really. I'm not more close 7 to either of them. Q. Both would be supportive of you, both 9 emotionally and as well financially if they thought that 10 it was necessaty? 11 MR. HOROWITZ Form. 12 THE WITNESS: Yes. 13 BY MR. CRITTON: 14 Q. And that's always been true with you and your 15 family and your mom and your dad? 16 A. Yes. 17 Q. Okay. If you had a friend or friends that you 18 were going to tum to now that you needed help or 19 assistance in some fashion, you didn't want to tell your 20 mom or your dad, would Jane Doe 4 be one of the people 21 you would go to? 22 A. Yes, 23 Q. Who else? Who else would you consider would 24 be a good friend that you would go to? 25 . A. Jane Doe 4 or Jane Doe 3 really. 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 324 lawsuit? Did he ever express any opinion? A. My dad just basically said it was up to me to do what I wanted to do. Q. Has your room ever said to you that she's angry with you for ever having gone there? A. I mean no. She was upset about it, and at first she like asked me how I could have been so stupid and why I would have went there. But I mean she understands that I was young and confiised at the time, so-- Q. Did your dad ever ask you? A. No. My dad didn't really talk about it. Q. Are you closer to your mom or your dad? You love them both, right? A. Yeah. Q. And they both love you? A. (Witness nods head up and down.) Q. Supportive of you? A. Yes. Q. And they are supportive of you getting a career, certainly a job? A. Yes. Q. Every parent wants their child to get a job, that's good. Do they want you to come back to Palm Beach Page 326 1 Q. I'm sorry? 2 A. Jane Doe 4 or Jane Doe 3. 3 Q. Jane Doe 3? 4 A. Yes. 5 Q. Looking briefly at your work history, looks 6 lila, you worked irt,IFIrm i. t ottra to Orlando you 7 worked at 8 A. Yes. 9 Q. And you were a cart girl? 10 A. Yes. 11 Q. All right. So you drove around on the golf 12 course? 13 A. Yes. 14 Q. For refreshments and food for guys? Guys and 15 gals, whoever was playing golf? 16 A. Yes. 17 Q. All right. And then you worked — and that 18 was in '07, and is the only job that you have had since 19 then, although I think you said you are working 20 someplace now. I'll get 21 Then you worked ball. in 2008, the whole 22 year? 23 A. Yeah, about a year. I don't know actually 24 have that. 25 Q. So you went £roil 110•••••050i..../ 8 (Pages 323 to 326) (561) 832-7500 • PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge (201-272-617-4627) fe3b2074-4669.4e4d-ac93-o54696fd7921 EFTA01107884
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Page 327 1 MR. HOROWITZ: Do you want to show her that? 2 MR. CRITTON: That was in Exhibit 2. She 3 should have it right in front of her. 4 MR. HOROWITZ: That was like eight exhibits 5 aga 6 MR. CRITTON: I can help you. Maybe you need 7 an assistant to help you sort through the exhibits. 8 BY MR. CRITTON: 9 say you worked 10 at 11 A. Yes. 12 Q. In 2007. That was the only job you had in 13 2007, correct? 14 A. Yes. 15 Q. Okay. And then 2008 was part of 16 your — I think you told us earlier it w pan toyour 17 work experience through school? 18 A. Yes. 19 Q. Okay. And you worked them for all of 2008? 20 A. Yes 21 Q. Did you work anyplace else in 2008? 22 A. 2008, no,1 don't believe so. 23 Q. way, were you with hum Doe 4 when she 24 w v up in Orlando and she went P 25 and tried OM as a stripper? 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 329 Q. does what? A. They are liquor too. Q. But they are two different entities? A. Yes. One is just like a modeling agency. Well, its just like an agency where they have girls that they hire to like the liquor company, and that's out of Tampa, but they have jobs in jobs in Orlando that I do. I have driven to Tampa before. Q So you will go to Tampa to do this work too? A. Yes, sometimes. Q. How much do you get paid for doing that? A. $25 an hour. Q. 25 bucks an hour? A. Uh huh. Q. All you have to do is go to a bar, look pretty, have a cute outfit on, and hand out liquor? MR. HOROWITZ: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. 'filets basically it, isn't it? MR. HOROWITZ: You are jealous. BY MR. CRITTON: Q. This is not professional work. I couldn't do it. I wouldn't look good in a skirt. But in essence, they give you 25 bucks an I Page 328 1 A. No. 2 Q. Are you aware of the circumstances of her 3 doing it? 4 A. I learned about it. 5 Q Who did you hear about it from? 6 A. Jane Doe 4 told me. 7 Q. What did she say about it? 8 Nothing really. She just said she went to 9 work and it was her birthday and they were just 10 n of joking around. 11 Q. Did she tell you she got up on the stage and 12 danced for a while and made some money? 13 A. She didn't tell me she made money. She just 14 said she did it as a joke. 15 Q. And now where are you currently working again? 16 Tell me a in. 17 A. 18 19 that, Q. That's what? Is is that all the same company? 20 21 m i l They are two differen is separate. And then 22 same co n . 23 Q. are the liquor people, 24 right? 25 A. Yes. are the 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 330 hour, and bow long is the gig usually? . A. It depends. Sometimes ifs like four bars we go to, sometimes ifs two. Sometimes it's five bars. Q. So it might be six to ten hours? A. Its neva ten hours, but ifs usually from lace three to five hours. Q. All right. Do they pay in cash? A. No, I get a paycheck. Q. So you get a 1099? A. Yes. you work or f during About during the course o a mon A. About e twice a week maybe, so — Q. Is it almost exclusively in Orlando? You said you have been to Tampa. A. Yes. Q. Have you been to any other cities other than Tampa? A. No. Q. If you have to go to Tampa, do they put you up overnight? A. No. Q. How long have you been doing this twice a week? A. I meanIdon't always do it twice a week. I (561) 832-7500 9 (Pages 327 to 330) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge (201.272-617.4627) fe3b2074-4669.4a4d-ac93-e546961d7921 EFTA01107885
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3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 331 started picking up more shifts now that I only have three classes. Last semester I was taking six classes, sol didn't really have time to do that much. Q. Now you do it approximately two times a week? A. Yeah, I try to pick up as many shifts as I can. Q. And they just go to different ban in Orlando? A. Not just bars. Restaurants too. Do you have my Advil at all? MR. CRITPON: Let's go off the record. THE VIDEOGRAPHER: Going off the record, 4:21 p.m. (A recess was taken.) THE VIDEOGRAPHER: We're back on the record at 4:48 p.m BY MR. CRITTON: Q. Ma'am, have you ever been treated in a drug or an alcohol program? A. No. Q. Have you ever had an HIV test? A. No. Q. To the best of your knowledge, you are not HIV positive? A. No. Q. All right. Have you ever had any surgery of 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 333 A. No. Q. Jane Doe? A. No. Q. Jane Doe 6? A. No. Q. Jane Doe 2? A. No. Q. L.L.? A. No. Q. K.H.? A. Yes. Q. How do you know K.H.? A. She goes to my school, or went to my school, high school. Q. How about Jane Doe 101? A. Sounds kind of familiar. Q. But you can't place her? A. I./ uh. MR. HOROWITZ: No? THE WITNESS: No. BY MR. carrroN: Q. How about L.P, does that mean anything to you? A. No. Q. Is K.H. your age or older? Page 332 1 any kind? 2 A. Just wisdom teeth. 3 Q. I'm sorry, have you ever bad any cosmetic 4 5 A. No. 6 Q. Have you ever been pregnant? 7 A. No. 8 Q. Jane Doe 3, how long have you known her? 9 A. Since i was a sophomore in high school. 10 Q. So that would have been the '03 time period? 11 A. Yes. 12 Q. And was Jane Doe 3 your age? 13 A. She was a year younger than me. 14 Q. How did you all become friends? 15 A. I believe Jane Doe 4 knew her and her sister. 16 Q. Jane Doe 4? 17 A. Jane Doe 4. 18 Q. Does she go by Jane Doe 4? 19 A. I mean no. T call her Jane Doe 4. 20 Q. Okay. It might have been my heating. So she 21 was a friend of Jane Doe 4's? 22 A. (Witness nods head up and down.) 23 Q. Have you ever met anybody by the name WM? 24 25 10.1calb:GSPAI t. A. of sounds familiar. surgery? Page 334 1 A. She's a year older than me. 2 Q. Who was she friends with? Let me rephrase the 3 question. 4 Was she friends with any of your friends, your 5 group? 6 A. Yes. 7 Q. Who? 8 A. Jane Doe 4 and Jane Doe 3. 9 Q. Do you know whethe= ever went to 10 Mr. Epstein's home? S t° 11 A. Well Id me I think she went there. 12 Q. This 13 A. Yes, she is also friends witi= too. 14 Q. I'm sorry? 15 A. She is also friends with., good friends. 1 6 Q. Were you aware, 'think you told me earlier, 17 and I may have forgotten, you told me you were aware 18 back at the time when you ing to Mr. Epstein's or 19 around that time period thaarhad been there to 20 Epstein's as well? 21 A. Yes. 22 And she told you on or about that time that 23 had been there? 24 A. No, I didn't ford out abotiM. until -- 25 Q. When did you find that out? (561) 832-7500 10 (Pages 331 to 334) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge (201.272-617-4627) te3b2074-4669-4a4d.ac93-e54696fd7921 EFTA01107886
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Page 335 A. When I wiling =when I told you 2 recently I talked a about it. 3 Q. Did she say anything aboulM., whether she 4 had brought any kind of action against Mr. Epstein or intended to bring any action against him? o A. Yeah, I think she said she had a lawyer, but she didn't really go into detail. Q. Did she know what had happened, whether the 9 lawyer had filed a lawsuit or not? 10 A. No. 11 Q. So at least back at the time you lava, 12 but you didn't, you had no knowledge that she had been 13 to Mr. Epstein's house? 14 A. No, we weren't good friends. I just know of 15 her because she was friends with my friends. 16 Q. Of the people that you knew who went to 17 Mr. Epstein's house back in the time peril. 18 were there, it would have been Jane Doe 3 19 A. Yes. 20 Q. You are pretty sure..? 21 A. Yes. 22 Q. Jane Doe 4? 23 24 Q. 25 A. Yes. Page 337 1 A. We didn't really talk about it. The only 2 girls I talked about it with would be Jane Doe 4 and 3 Jane Doe 3. 4 Q. Okay. That's what my uestion is. Did any of 5 those individua Jane Doe 3 Doe , Jane 6 , ever say to you that anything that 7 had occurred, at the time that anything that had 8 occurred was inappropriate? 9 A. I mean I didn't talk about it with diem. 10 Q. So nobody brought it up and said "You won't 11 believe what happened"? Nobody said something like to 12 you? 13 A. No, they all kind of kept it to themselves I 14 think because they were embarrassed. 15. Q. So no one said did anyone ever tell you 16 that Mr. Epstein had been in any way aggressive with 17 them, had used any kind of physical or verbal force or 18 had coerced them to do anything, or that issue never was 19 discussed back then? 20 A. We just didn't discuss it. 21 Q. But no one raised it? If something had 22 happened and somebody had discussed it, that's something 23 that you would have remembered? 24 A. Yes, l don't know. 25 Q. With regard to Jane Doe 3, you said you knew Page 336 1 Q. 2 A. Yes. 3 Q. Anyone else have I missed? 4 A. I don't think so. S Q. okay. As to arm. A. I heard of a girall. but I didn't know her. 7 Q. Do you leumnbe last name? 8 A. No. 9 Q. If I said would that mean anything 10 to you? 11 A. I don't know if that was her last name or not. 12 Q. Just somebody name= Do you remember 13 what she looked like? 14 A. Blonde hair. 15 Q. Older? 16 A. I think she was in our grade. 17 Q. Just not in your friend group? 18 A. No. 19 Q. Of the females Jane Doe 3, 20 Jane Doe 4, did any of those people ever 21 tell you that Mr. Epstein — and tell you now, not vault 22 you assume — that anything had happened back at the 23 time, that anything had ever occurred at Mr. Epstein's 24 house that had been, they considered to be 25 inappropriate? An Page 338 1 her when she was -- so you. ould have been a junior, she 2 would have been a sophomore? 3 A. I think I knew her my sophomore year when she 4 was a freshman. 5 Q. So she would have been a freshman? 6 A. Yeah. 7 Q. Were you aware that — let me strike that. Do 8 you know whether you had gone to Mr. Epstein's before 9 Jane Doe 3 went or whether she went afterward, after you 10 had already gone? Does that make sense? 11 MR. HOROWITZ: No, try that again. 12 BY MR. CRITTON: 13 Q. Okay. Do you know whether you went to 14 Mr. Epstein's first or Jane Doe 3 went to Epstein's 15 first? 16 A. No. 17 Q. You don't remember? 18 A. No. 19 Q. Okay. if I asked you to assume that Jane Doe 20 3 says that she went to Mr. Epstein's after you had 21 already been there, would you dispute that? 22 A. I mean yes, because I don't really know, I 23 don't remember. 24 Q. But so if Jane Doe 3 said no, I asked Jane Doe 25 7 and Jane Doe 7 said she had been to Mr. Epstein's (561) 832-7500 PROSE COURT REPORTING AGENCY, 11 (Pages 335 to 338) INC. (561) 832-7506 Electronically signed by Rachel Bridge (nt-272-617-4627) Electronically signed by Rachel Bridge (201-272-617-4627) fe3b2074-4669-434d-ac93.e54696fd7921 EFTA01107887
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Page 339 Page 341 1 before -- 2 MR. HOROWITZ: Fonn. 3 THE WITNESS: If that's what she said -- 4 BY MR. CRITTON: 5 Q. Then you would go with her recollection on 6 that? 7 MR. HOROWITZ: Form. 8 THE WITNESS: Yes. 9 BY MR. CRITTON: 10 Q. Do you know how many times -- well, let me 11 strike that, because you don't remember of your own 12 independent recollection who went first, Jane Doe 3 or 13 you. 14 Did Jaw Doe 3 ever express to you that 15 anything inappropriate — let me strike that. 16 Have you ever discussed what Jane Doe 3's 17 visits were with Mr. Epstein? Did you ever discuss that 18 with her? 19 A. No. I mean she shared her feelings about him 20 with me, but she never discussed what happened. 21 Q. And when you said her feelings, is that 22 recently? 23 A. I mean I don't remember if she did back then, 24 but she has recently. 25 Q. Pardon? 1 2 3 4 5 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Q. A. A. A. Q. A. Okay. Did you go out with her? Yes. Where did you all go? Went to Noche. Up in Palm Beach Gardens? Yes. That's at the Soverel Marina? Yes. Who else Just her at and two other girls I didn't know. Q. MM. nix)? A. Q. Do you know whether J.S., was she one of your friends too back at that time? A. Yes. Q. Did she ever go to Epstein's? A. Yes. Q. How do you know that? A. Because she told me. Q. Why did she tell you? What made her tell you that? MR. HOROWITZ: Form. THE WITNESS: I don't remember. Page 340 1 A. I don't remember what she said about him back 2 then, but I mean recently she has. 3 Q. And what has she said recently? 4 A. Just that she thinks he's lice a horrible 5 person and she thinks that the justice system didn't 6 work for him at all, and she told me about how he's nov, 7 on probation and out of jail, and just stuff like that. 8 Q. With Jane Doe 3, have you ever met her 9 husband? 10 A. No. 11 Q. Did you know she was married? 12 A. Yeah, she told me. 13 Q. When is the last time you talked to Jane Doe 14 3? 15 A. I talked to her recently. 16 Q. Last couple of weeks? 17 A. Yes. 18 Q. When is the last time you saw her? 19 A. The last time I was down in Palm Beach. 20 Q. Which was when, February? 21 A. No, I don't really remember. 22 Q. Where did you see her? 23 A. Actually I saw her, I was recently, I was here 24 before I went down to Key West and I saw her. It was 25 her birthday. 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 342 BY MR. CRITTON: Q. Did she know that you had been to Epstein's? A. Yes. Q. Did she know that you area plaintiff in a lawsuit? MR. HOROWITZ: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. How did she know you were a plaintiff in a lawsuit? MR. HOROWITZ: Form. THE WITNESS: I don't know who told her. She asked me about it. BY MR. CRITTON: Q. Did you confinn to her that you had in fact brought a suit against Mr. Epstein? A. Yes. Q. If somebody asks you whether you are a plaintiff in a lawsuit against Mr. Epstein, do you tell them yes? A. If they are one of my close friends. If I don't know them, no. Q. Okay. Wein, is she a friend as you described earlier? A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, 12 (Pages 339 to 342) INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Midge (201-272.617-4627) 1e3b2074.4669.4a4d-ac93-o54696fd7921 EFTA01107888
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Page 343 Page J.] 1 Q. Or a good friend? 2 A. She's a friend, yes. 3 Q. Someone you might trust or you might not? 4 A. She knew about it before when we were in high 5 school. 6 Q. She knew what, that you had gone there? 7 A. Yes. 8 Q. How did she know? 9 MR. HOROWITZ• Form. 10 THE WITNESS: Everybody knew. She was in our 11 friend group. 12 BY MR. CRITTON: 13 Q. So ever/body who was in your Mend group knew 14 who had gone to Epstein's? 15 A. I mean basically it was me, Jane Doe 4,E, 16 lane Doe 3, we were all friends, so we all knew. 17 Q. And did J.S. ever describe her visits, visit 18 or visits to Epstein's? 19 A. I think she only watt once. 20 Q. Did she tell you why? 21 A. Yeah, she said that he like seared her or 22 something and tried to like make her do something and 23 she never went back. 24 Q. Okay. Were you still going to Epstein's at 25 the time you heard that? 1 A. Yeah. 2 Q. And she said she had given a deposition? 3 A. Yes. 4 Q. Do you know if she's married? 5 A. She said she was divorced. 6 Q. She told you she was divorced? 7 A. Or they are separated, not divorced, I think Q. Which did she tell you? 9 A. !think separated. 10 . Q. Did she tell you why? 11 A. I think she was kind of embarrassed about it, 12 so she didn't really go into detail with me. 13 Q. Did you go to her wedding %Olen she got 14 trawled? 15 A. No. 16 Q. Have you ever — she has a child, doesn't she? 17 A. No. 18 Q. She doesn't have a child? 19 A. No. 20 Q. Jane Doe 3, was she someone, Jane Doe 3, did 21 you see her do, when she drank with you all in high 22 school, alcohol? 23 A. Yes. 24 Q. And did you see her do drugs in high school? 25 A. No. Page 344 1 A. I don't remember when it was. 2 Q. Did you say to her that never happened to me? 3 A. I don't remember exactly what I told her. 4 just remember her telling me that. 5 Q. Did she say that she has any interest in 6 bringing a lawsuit against him? 7 A. No. 8 Q. Did she ask you how your lawsuit was going? 9 A. Na 10 Q. When you saw Jane Doe 3, you went to Noce, 11 what time did you all meet? 12 A. I think around eleven. I was driving home 13 from Orlando to visit my parents and then go to Key 14 West. 15 Q. And how long did you stay? 16 A. Not long just like two hours. 17 Q. Had a couple of drinks and then headed home? 18 A. Yes. 19 Q. Did Jane Doe 3 tell you that she had given her 20 deposition at that point? 21 A. [don't think she has given it yet, at that 22 point, no. 23 Q. But you subsequently talked to her? .24 A. Yes, recently. 25 Q. Over the phone? (561) 832-7500 Page 346 1 Q. Okay. So if she was doing cocaine or erctacy 2 or xanax, again, you never saw it? 3 MIt HOROWITZ: Form. 4 THE WITNESS: No. My friends knew I didn't do 5 it, so some of than would tsy to hide it or not do 6 it around me. So I never really saw them, whoever 7 did what. 8 BY MR. CRITTON: 9 Q. I think you told too you've never been in a 10 hospital? 11 MR. HOROWITZ.: Form. 12 BY MR. CRITTON: 13 Q. Right? 14 A. Not that I can recall, no. 15 Q. I asked you what you told the Palm Beach 16 police the first time you went to Mr. Epstein's house. 17 what you told them as to how you ended up going to 18 Epstein's. I asked you what you had told them. 19 Now my question to you is I never asked you 20 what you told the FBI. At this point I'm beyond that, 21 so let me ask this question. 22 How did you first hear that other people in 23 your grade or at school were going to Mr. Epstein's 24 home? Who did you hear that from? 25 A. I mean I just remember the first tirne I beard 13 (Pages 343 to 346) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge (201-272.617-4627) to3b2074-4669-434d-a493-c54696fd7921 EFTA01107889
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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 347 about it w' asking me to go. And then after that, II remember Jane Doe 4 talking about it and then Q. And you said asked you to go. And at that time I think you said it was, you remembered it being in gym class or something like that. A. Yes.. Q. AndM. was in your grade? A. She was a grade ahead of me, but anybody could have gym together. Q. So what specifically clid say to you, your best recollection? A. She asked me it if I needed a job and if I needed money, and then she asked me if I knew how to give a massage. And I said yes, but not professionally. And she told me that was fine. And then she told me how she knows a guy that. lives in Palm Beach and will pay me if I give a massage. Q. You had been to Palm Beach before? A Yes. Q. And I assume based on what you told me earlier you had been to the beach in Palm Beach? A. Yes. Q. And had your dad driven you over there in Palm Beach because this is where I work, this is the kind of Page 349 1 A. No. 2 Q. All right. She just said "If you want ajob, 3 you want to make some money, you have to give a 4 massage." 5 You said, "I'm not a professional, but I've 6 given massages before"? 7 A. Yes. 8 Q. Who had you ever given a massage to? 9 A. I don't remember, just girlfriends mainly, 10 like back massages. 11 Q. So did you este when she said, you know. 12 you can make some money, did she tell you how much you 13 could make? 14 A. Yeah, l think she said 5200. 15 Q. And did she say whether she was going to make 16 any money? 17 A. No. 18 Q. And did you say okay, did you say "Yeah, I'm 19 interested"; or "No, I'm not interested, let me think 20 *bout it"? 21 A. I told ha I was interested. 22 Q. Why were you interested in any way well, 23 let me ask you this. Did you say "Well, where exactly 24 is the massage going take place?" 25 A. I didn't ask her any of the details. 'just Page 348 1 houses i inspect? 2 A. He works like downtown. He doesn't work like 3 on Palm Beach island. 4 Q. Where does he work when you say downtown, West 5 Palm? That's where his office is? 6 A. Yeah, West Palm. 7 Q. Okay. Had he ever driven you over there? 8 A. I mean yeah, he's driven over there to go to 9 the beach and stuff. 10 Q. Had you walked up and down at times, you and 11 your mom at times walked up and down Worth Avenue and 12 then gone over to the beach just to look? 13 A. !mean yeah, i guess. 14 Q. It's a tourist spot? 15 A. Yes, I've been to Worth Avenue before. 16 Q. All you were familiar with Palm 17 Beach befo said — so when she said there is a 18 guy over in Palm Beach, you knew where Palm Beach was 19 and you had been on the island before, correct? 20 A. Yes. 21 Q. And did she tell you how old the person was, 22 how old this guy yeas? 23 A. No. 24 Q. She didn't tell you whether he was 20 years 25 old or 50 years old or 100 years old? Page 350 1 was interested in making money, I 2 Q. So when is the next time yottle had some 3 conversation about it? 4 A. The next time is she just, I'm pretty sure 5 like when I actually went there. 6 Q. Did she say at school, "Hey, we're going to go 7 on Tuesday or whatever? 8 A. I don't remember. 9 Q. On any of the times that you ever went to 10 Mr. Epstein's, did you ever miss school to go? 11 A I went on — no, I usually went after school. 12 Q. What time? What time did you get out of 13 school, like two, three o'clock? 14 A. Yes. 15 Q. So you would go after you got out of school? 16 A. Yes. 17 Q. .And on the first occasion, how did you know 18 that going to go a particular day? 19 A. told me. i guess she made plans with 20 Sarah or Jeffrey. 21 Q. Tell me what you know at you guess. St 22 let me ask you again. What di say to you? 23 A. I don't remember exactly. I just remember her 24 asking me, and then I forget how we actually, when we 25 made plans to go there, like what day, but — and then I (561) 832-7500 14 (Pages 347 to 350) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201.272.617.6627) Electronically signed by Rachel Bridge (201.272.617-1627) fe3b2074-4669-4a4d-ac934,54696fd7921 EFTA01107890
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Page 351 Page 353 1 rememberus mg there. 2 Q. As= drove? 3 A. Yes. 4 Q. What did she have at the time? Did she have a 5 car, a truck, SUV? 6 A. She had a truck. 7 Q. What did it look like, do you remember? A. Maroon. 9 Q. Maroon, all right. Now before you went, did 10 you talk with her again and say "Okay, what am 1 11 supposed to wear?" 12 A. No. That first conversation, she just told me 13 to dress cute. 14 Q. Dress cute? 15 A. Yeah. 16 Q. What's that meat to you or what did that mean 17 to you? 18 A. I don't know. f just wore like my bathing 19 suit, because she said -- like we were planning on going 20 to the beach after. And then I wore a skirt and a tank 21 top? 22 Q. So you wore a bathing suit, tank top, skirt 23 and like flip-flops? 24 A. Uh huh. 25 Q. Yes? 1 A. Yes. 2 Q. What did you anticipate, and their arms and 3 their hands and their feet, necks, their head sometimes? 4 A. What did 1 anticipate I was going to do? Q. All right. If you — had you seen that on TV? 6 A. I mean yeah, !guess. 7 Q. Okay. So if you had seen that on TV, did you 8 assume that when you went over to earn money to do a 9 massage and you weren't, as you said, you weren't a 10 professional, that you were going to give some guy a 11 massage, so you would be massaging basically a large 12 part of his body? 13 A. Yes. 14 Q. And you understood, or I assume from having 15 seen it on TV, you understood that people who have 16 massages, males or females, oftentimes they are on 17 either their back or their stomach and then their 18 private parts are covered only with a towel, but they 19 are naked underneath? 20 A. Yes. 21 Q. All right. Now, so you are going over there, 22 at leas= tells you you are going to get 200 bucks 23 for giving a massage fora guy, so you knew it was a 24 male. 25 Did you ask her at the time how old is this Page 352 1 A. Yes. 2 Q. Did you say "Wait a minute, why do 1 have 3 to — even if we're going to the beach afterwards, why 4 do I have to dress cute for this massage?" 5 A. I don't, I don't really remember. 1 was 6 confused. Q. What's confusing about that? 8 A. 1, she could have meant like dress, you know, 9 professionally, like massage people dress cute, I don't 10 know. I was like 16. I don't remember. 11. Q. Okay. Where had you ever seen -- had you ever 12 had a massage yourself? 13 A. No. 14 Q. Had you ever been to a spa? 15 A. No. I have seen spas before. I have never 16 actually been. 17 Q. Had you ever seen anyone have a professional 18 massage? 19 A. Yeah, like on W I have seen people. Not like 20 in person, but I have known the — 21 Q. And do you know when you give someone a 22 massage, that is a professional massage, you are 23 massaging their legs and their thighs and their back and 24 their neck, and then they flip over and you do the front 25 of their legs, things like that? Page 354 1 person? 2 A. No. 3 Q. Why not? 4 A. !just, I didn't think about it. I remember 5 asking her like why he doesn't just hire somebody to 6 give him a massage, and she told me he doesn't like 7 professional people, lace professional massages. 8 Q. Okay. As you described yourself earlier, you 9 said you arc of above average intelligence, so did you 10 say to her at that time wait a minute, why doesn't — 11 you had certainly the common sense to say why doesn't he 12 hire a professional masseuse, and she said well, he 13 doesn't like those. 14 Did that send off a little bell in your head 15 to go gee, why am I going and getting paid $200 versus a 16 professional massager, masseuse? 17 MR. HOROWITZ: Form. 18 THE WITNESS: I mean I didn't know. I didn't 19 really think about it. 20 BY MR. CRITTON: 21 Q. You thought about it enough to ask why doesn't 22 he get a professional, right? 23 A. Yeah. 24 Q. Did you say okay —1 assume when you have 25 seen people on TV give massages, you have seen they have (561) 832-7500 PROSE COURT REPORTING AGENCY, 15 (Pages 351 to 354) INC. (561) 832-7506 Electronically signed by Rachel Bridge (201.272.617.4627) Electronically signed by Rachel Bridge (201.272.817.4827) to3b2074.4669-4a4d-ac93-o54696td7921 EFTA01107891
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Page 355 been in basically in uniform, sometimes they are in a 2 white uniform or may have a polo shirt on and pants or 3 shorts, right? 4 MR. HOROWITZ: Form. THE WITNESS: Yes. 6 BY MK CRTITON: Q. Have you ever seen people again separate and 8 about from — well, let me strike that. 9 Have you ever seen people give massages in the 10 movies, other than when a guy is giving a girl a massage 11 that they have a relationship, where someone shows up in 12 a swimsuit or a cute little tank top and a skirt? 13 MR. HOROWITZ: Form. 14 774E WITNESS: No. 15 BY MR. CRITTON• 16 Q. All right. St tells you to dress cute. 17 You are going to give a guy who doesn't want 18 professional massage a massage, and you arc not 19 masseuse, right? 20 A. Yes. 21 Q. And you didn't ask how old he is, correct? 22 A. Correct 23 Q. Okay. Did you ask who was going to be there? 24 A. No. 25 Q. Did you ask where it's going to be done? Page 357 1 A. I think she might have said that. 2 Q. Did she, did you express any concern, like is 3 this guy going to be pushy? Is he nice? Is he an angry 4 kind of person? You know, is he going to be physical 5 with me or verbally abusive in any way? 6 Did you ask any of those questions? 7 A. No. Q. Did she say anything when you said — I said 9 did she say anything about that she he was nice and you 10 wouldn't have to worry, and you said you remember her 11 saying something about him being nice, right? 12 A. Yes. 3 Q. Okay. Did she say that he wouldn't use any 14 physical force or violence or any kind of coercion, that 15 you could feel safe? 16 MR. HOROV/ITZ: Form. 1 7 THE WITNESS: I mean she never said it that 18 way. 19 BY MR. CRTITON: 20 Q. Did you assume that? 21 A. When she said he was 22 done it, I assumed it 23 Q. Okay. Did she tell you if he, if you are 24 asked your age, to say you are over 18? 25 A. No. nice and she's already 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 356 A. Yes. Q. And she said? A. At his house. Q. Okay. Did you say "Why are we doing it at his house?" A. I don't remember. Q. Did you say "Where are you going to do it in the house?" A. I don't remember. Q. Did you ask her "Am I going to M., are you going to be there too?" A. She was the one that was bringing me, so yeah, I obviously assumed she was going to be there. Q. So you assumed she was going to be there. So what, did you say "What parts of his body do I have to massage?" A. Uh uh, ask She told me like — Q. Go ahead. A. She told me his legs and his feet is what she usually does, but I then never really. Q. Okay. Do you remem telling you that, in fact, it was an older man, late miles, fifties? A. No. Q. Do you remember her telling you he was a nice guy? Page 358 1 Q. So in. says that's what she told you, that 2 would not be hue or you just don't remember? 3 A. No, that would be a lie. 4 Q. Kind of like what you told the Palm Beach 5 police? 6 MR. HOROWITZ: Form, argumentative. 7 BY MR. CR1TTON: 8 Q. Right? 9 A. I guess you would say that. 10 Q. Did she ever say anything that you might be 11 asked to remove your clothes or take off an article of 12 clothing? 13 A. No, not the first time I went. 14 Q. Did she ever give you any indication that you 15 should be — well, let me strike that. 16 Okay, so she makes an arrangement for a time. 17 You don't know how, but she tells you we're going over 18 there at such and such a time, dress cute, right? 19 A. Uh huh. 20 Q. Yes? 21 A. Yes. 22 Q. She pit you up? 23 A. I don't — we 'night have left after school. 24 Q. So you might have left right from school? 15 A. Yes. 16 (Pages 355 to 358) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 . Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge (201.272-617-4627) fo3b2074.4669-4a4d-ac93-e54696fd7921 EFTA01107892
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Page 359 Q. Did you just take clothes with you from 2 school? 3 A. Well, we were going to the beach after, so I 4 probably, l remember wearing my bathing suit. Q. Did you in fact go to the beach afterwards? 6 A. Yes. Q. In Palm Beach? A. Yes. 9 Q. All right. So do you remember what time of 10 year it was now? In thinking of that, it had to have 11 been warm if you were going to the beach or at least 12 decent. 13 A. Yes. 14 Q. And it was just the two of you? 15 A. Yes. 16 Q. On the way over there, did you discuss what 17 you were going to be doing? Were you nervous at all? 18 A. I mean f was a little bit nervous, but I — we 19 didn't really talk about what we were going to be doing. 20 Q. So you got to the house. Did she park on the 21 driveway or on the street? 22 A. The driveway. 23 S. When you got out of the ear, did you say to 24 at any time before you got out of the car, "You 25 know, this doesn't seem like a great idea, I think I Page 361 1 A. 1 think so. I don't remember what I ate. I 2 remember like offering food. He was cooking. 3 Q. Art went upstairs. Did Mr. Epstein come 4 down? 5 A. No, I think she just came back down and told 6 me to go upstairs. 7 Q. Told you to go upstairs? 8 A. Yes. 9 Q. Tice first time that you went to the tein 10 home, did you actually go up or did ' onl go up? 11 A. I remember I went once wit hen she just 12 went up. 13 Q. Was that the first time? 14 A. Yes, I think that was the first time. 15 Q. So the first time you were there -- 16 A. Or actually — I don't remember correctly. 17 Q. Okay. 18 A. I don't, I l WIAlliber just going once with her 19 when she did her s And then — m 20 Q. She eani 21 A. Yes. So yeah, I remember the first time 1 22 went there to do it. 23 Q. Da tell you she had been there before? 24 A. Yes. 25 Q. Okay. So at least onetime you went wit= Page 360 1 don't want to do it"? 2 A I mean no. When I got there, I was kind of 3 conflated by everything, but I didn't really say that to 4 her. 5 Q. Why not? 6 A. I mean I didn't know what was going to go on. 7 Q. Well, you could have t time turned 8 around and said, "You know I don't really feel 9 like doing this," right? 10 A. Yes. 11 Q. So you had to -- again, it was your decision. 12 You could either say yes or no, and you said yes, I'm 13 going to go into the house, right? 14 A. Yes. I mean the first time she didn't tell me 15 what was going on at all, so — 16 Q. You go in the house. Was there? 17 A. There was a cook there 18 Q. And you were in the kitchen? 19 A. Yes. 20 Q. And what happened then? 21 They just like offered me food and water and 22 Milinlintroduced herself to rne. And she went up and got 23 Jeffrey. 24 Q. Okay. Did you eat anything when you were 25 there? Page 362 1 where she went up and gave the massage and you just sat 2 in the kitchen? 3 A. Yes. 4 Q. Do you remember that being the first time or 5 another time? 6 A. I think it was no, it was the second time, 7 because I didn't know the first time what — 8 Q. Okay. So the first timMeme back down 9 and she said you can go upstairs? 10 A. Yes. 11 Q. Did she take you upstairs? 12 A. Yeah, she walked up there with me. 13 Q. So you followed her? 14 A. Yes. 15 Q. Did you go up a stairway, I assume? 16 A. Stairway, yeah. 17 Q. Anything unusual about the stairway? 18 A. There were just like weird pictures like on 19 the skle of the wall. 20 Q. Of what? 21 A. They were pictures of like girls, pictures of 22 boobs, pictures of like weird drawings. 23 Q. Arts kind of pictures? 24 A. Arts, but then there was some kind of weird 25 pictures of girls with boobs and naked pictures. (561) 832-7500 17 (Pages 359 to 362) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272417-4627) Electronically signed by Rachel Bridge (201.272417.4627) fe3b2074-4669-4a4d-ac93-eS4696k17921 EFTA01107893
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Page 363 1 Q. Describe — you said there were some art 2 pictures on the wall that had what, naked people or 3 portions of torsos or something? 4 A. Yeah. 5 Q. And then you saw a picture of another 6 picture where women were, didn't have tops on? 7 A. And I saw a picture of a little girl. 8 Q. Okay. And how was she dressed? 9 A. She had like a dress on. 10 Q. All right. 11 A. I think that was his daughter that I saw there 12 before. 13 And then I walked into the room and there were 14 more pictures there of girls and weird art pictures. 15 Q. Again, just, you say weird art pictures, 16 just - 17 A. Just I don't know, weird torso and boob 18 pictures, I guess. 19 Q. Of different parts of bodies, pictures? 20 A. Yes. 21. Q. And there were other pictures of girls? 22 A. Yes. 23 Q. Anyone that you recognized? 24 A. No. 25 Q. Anyone that you had ever seen at the house? Page 365 1 A. Yes. 2 Q. Did she tell you what you were supposed to do 3 or what you were supposed to use or anything like that? 4 A. She said there was like massage oil, and she 5 like pointed to the massage oil. And that's all I think 6 I can remember her saying. 7 Q. Were you nervous at all? 8 A. Yes. 9 Q. Did you say UM "You knew what, I dont 10 think I want to do this, l think I'm out of here"? 1 A. I fek like I was kind of pressured and put in 12 a weird position where I just felt hie I kind of had to 13 do it because I there. 4 Q. Becaus had put you in that position? 15 A. I mean - 16 MR. HOROWITZ: Form. 17 THE W'ffNESS: Well, Jeffrey walked in. 18 BY MR. CRITION: 19 Q. No, before Jeffrey got there. 20 A. Well, not just because' no. Just in 2.1 general, I already said I would do it. 22 Q. Because you committed kind of? 23 A. Yes. 24 Q. So you felt that you — well, all right So 25 you got up there, she shows you the lotions. Does= Page 364 1 A. I don't think so. 2 Q. Were they clothed or unclothed? 3 A. I think they were undressed. 4 Q. Completely or just tops? A. I remember their breasts were showing. Q. That's what you remember seeing? 7 A. Yes. Q. And you don't know who they were? 9 A. No. 10 Q. Or how old they were? 11 A. No. 12 Q. Did they appear to be adults to you? 13 A. They could have.. 14 Q. So then you go i walks you into a 15 room? 16 A. Yet 17 Q. And whafs there? 18 A. There was a shower, like a vanity, the massage 19 table. She like already had it set up. 20 Q. Had you ever seen a massage table before? 21. A. Just not l mean in movies. 22 Q. Movies again. Did she say anything to you? 23 A. She just said that Jeffrey would be in 24 shortly. 25 Q. And did she leave then? (561) 832-7500 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 366 leave before Jeffrey comes into the room? A. I think so, yes. Q. Okay. So you are what, just standing by the table? A. Yeah. Q. And what happens? A. And then Jeffrey comes in. Q. And what's he do? How is he dressed? A. I think he just had a towel around him. Q. Okay. What color was the towel? A. White. Q. And describe it. A. He just had it like around his waist. Q. Describe Mr. Epstein. A. Like his body? Q. Yes. Tall, short? A. He's a taller guy, has gray hair, kind of hairy, kind of bigger, not fat, but like bigger build, blue eyes, like a longer face. Q. All right Did he introduce himself? A. Yes. Q. What did he say? A. Just said "Hi, I'm Jeffrey." Q. And you said? A. I said, "Hi, I'm Jane Doe 7, Es friend." 18 ( Pages 363 to 366) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-2724174627) Electronically signed by Rachel Bridge (201.272417.4627) to3b2074-4669-4a4d-ac93-0546961d7921 EFTA01107894
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Page 367 Page 369 Q. Did you shake hands? 2 A. I thirdcso. 3 Q. And what did he do? 4 A. And then that's when he got on the massage S table and he, that's when basically like the first time lgave a massage and he said that he would like his feet 7 and his calves massaged, and he was turned over. Q. So he was on his back. How long did the 9 session last? 10 A. It lasted for about, about half an hour, I 11 think. 12 Q. About 30 minutes? 13 A. Yes. 14 Q. All right. And did you massage his feet? 15 A. Yes. 16 Q. Did you pick the oil that you were going to 17 use? 18 A. Yes. 19 Q. Had you ever used massage oil before? 20 A. No. 21 vita did you know which one to pick, just from 22 told you? 23 A. Yes. 24 Q. So you used the massage oil. You did his 25 calves and his feet? 1 Q. Next to his right ann? 2 A. Well, I mean if you are looking at him this 3 way, I was over here. 4 Q. Well, you say he was lying down, so as he was 5 lying down, were you near his right shoulder or his left 6 shoulder? 7 A. When he was lying down, l was near his left 8 shoulder. 9 Q. As you were massaging his chest — 10 MR. HOROWITZ: You mean lying down en his back 11 or his stomach? 12 BY MR. CRITTON: 13 Q. You said he was lying on his back? 14 A. Yes. 15 Q. So you were near his right shoulder? 16 A. His left shoulder. 17 Q. His left shoulder, all right. And were you 18 standing at his side er were you standing at the top of 19 his head, massaging his chest? 20 A. On the side. 21 Q. All right And you say you Is.ard a humming 22 and then what happened? 23 A. And then he just started reaching under his 24 towel and then he kind of like grabbed, he grabbed me 25 towards him and pulled me towards him. Page 368 1 A. Yes 2 Q. Did he turn over then? 3 A. Towards the end, yes. 4 Q. So after what, you are 90 percent done, then 5 he turned over? A. Yeah. 7 Q. Okay. And he had a towel over him the entire 8 time? 9 A. Yes. 10 Q. Okay. And when he turned over, what did 11 you — did you continue the massage? 12 A. He turned over and then he asked me if I could 13 like massage his chest. 14 Q. And did you? 15 A. Yes. 16 Q. All right. And then what? 17 A. And then I was massaging his chest, and I 18 don't know, he started making noises. 19 Q. Like what? 20 A. Just like humming noises. 21 Q. Hununing? 22. A. Yeah. Just, I don't know, weird noises. And 23 then — . 24 Q. Were you standing to his left or his right? 25 A. I was standing on his right. Page 370 1 Q. Where did he grab you? 2 A. He grabbed my buttocks and pulled me to him. 3 Q. When you say grabbed you, he put his hand 4 behind your buttocks and pulled you toward him? 5 A. Yes. 6 Q. Which hand? 7 A. His left hand. 8 Q. When he did that, what did you do? 9 A. Felt really awkward arid got really scared. I 10 think he could tell I was scared. And I got nervous and 11 he, he kind of asked me if I was okay. 12 And I just told him I felt, I felt nervous. 13 And that's, that's when he like started to masturbate, 14 and that's when — 15 Q. How do you know he was masturbating? 16 A. Because I could, I could tell. 17 Q. Had you ever seen a guy masturbate before? 18 . A. .Yes. 19 Q. Where? 20 A. Die on TV. 21 Q. On what, like a porno movie or something like 22 that? 23 A. I don't know, I knew what it was. 24 Q. Everybody learns about it at some point in sex 25 education, right, male and female masturbation, right? (5 6 1) 8 32 — 7 50 0 19 (Pages 367 to 370) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272417-4627) Electronically signed by Rachel Bridge (201.272417.4627) fe3b2074-4669-4a4d-ac93o54696fd7921 EFTA01107895
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