EFTA01076158

Page 502 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO:502008CA028051XXXXMB AB 
Plaintiff, 
-vs- 
VOLUME IV OF IV 
JEFFREY EPSTEIN 
AND 
Defendants. 
VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF 
Tuesday, February 09, 2010 
10:09 - 5:05 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting 
Job No.: 1296 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
b5542lef-d299-4e4t-gba6-85and271A405 
EFTA01076158

EFTA01076159

Page 503 
Page 505 
Is 
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1 
APPEARANCES: 
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On behalf of the Plaintiff.," 
and 
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BRAD J. EDWARDS. 
FARMER, JAFFE, WELSSREG, EDWARDS 
FESTOS & 1EHRMAN, P.L 
425 North Andrews Avenue 
5 
Suite 2 
6 
Fort 
da
'
 33301 
Phone: 
7 
On behalf o the 
Jeffrey Epstein: 
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ROBERT D. CRITTON, JR., F5QU1RE 
MARK T. Lunn, ESQUIRE 
9 
atramAN. CRJTTON, LUTTIER & COLEMAN. ELP 
303 Banyan Boulevard 
Suite 400 
West 
33401 
Phone 
2 
On he
 f ot the De 
ate, Jeffrey Epstein: 
3 
JACK ALAN GOLDTJERGER. ESQUIRE 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Avenue South 
Suite 1403 
West Pa
a 33401-5012 
Phone: 
ALSO PRESENT. kffrey Epsldn, via video conference 
Daniel C1/47.7ney, Viikographier 
Visual Evidence, Incorporated 
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PROCEEDINGS 
THE VIDEOGRAPHER: We're back on the 
record at 1:48 p.m. 
BY MR. LUTHER: 
Q. Okay, Ma'am. I want to add that during 
the morning session, I was asking you some 
questions. I just want to go over a couple of 
things. One of the first things I asked you this 
morning is whether you understood you were under 
oath today. And you indicated you did understand 
that? 
A. Comet. 
Q. Are you, did you, are you aware of the 
fact that it is a crime known as perjury to make a 
false statement under oath? 
A. Correct. 
Q. Are you also aware that it is a separate 
crime, a federal crime to make a false statement to 
an FBI agent? 
A. Correct. 
Q. And you've already admitted that you 
committed that federal crime; you lied to the FBI, 
according to you. 
A. I was in fear of my son's life, correct. 
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Page 504 
INDEX VOLUME I 
DIRECT CROSS REDIRECT RECROSS 
BY MR. LUTHER 4 
EXHIBITS 
EXHIBIT DESCRIPTION 
PAGE 
DEMI 
Photo of 
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ad 
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634 
618 
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Page 506 
Q. Now, l want to ask you one more time: Is 
there anything you want to correct about any of your 
testimony this morning, especially as it relates to 
worki 
in laces of employment thati wiltave termed 
to be 
at or about or near 
m
o
m s 
A. Correct. I'm fine on that. 
Q. Okay. Isn't it a fact that on Saturda 
January 30th, you went to
A. Yes. 
Q. And you got them, what time, around 8:00? 
A. Yes. 
some point in time you left 
did you not? 
A. Yes. 
Q. And you went to a place called 
of Palm Beach, did you riot? 
A. Not that I recall. I don't know a name 
Q. Well, 
Each'
 located right next door to 
A. I thought that was affiliated with 
. You're familiar with that, aren't, 
''. 
MI. 
Q. Well, so that ue know — 
would be the 
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PROSE COURT REPORTING AGENCY, 
INC. 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
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EFTA01076160

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Page 507 
1 
(Cellphone interruption.) 
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THE WITNESS: Oh, Pin sorry, my phone. 
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MR. LUTTIER: Sure. Oo ahead. 
4 
THE WITNESS: Okay. Sorry. 
5 
BY MR. LUTTIER: 
6 
Q. There is 
whether or not it's 
7 
affiliated with
1 don't know. When 
8 
you referred to your testimontl
ming that you 
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didn't go anyplace other than MM 
Rhinos and 
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places affiliated did, with it, did you mean to 
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include in those places that you went 
of 
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Palm Beach? 
14 
Beach, but I know that, there, that 
has 
A. I persona lly never heard ofaiir 
13 
15 
a couple places affiliated with them. 
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Q. What places do they have that are 
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affiliated with them? 
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A. The back and then there's an entrance to 
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another place. That's all ! know. 
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Q. Well, tell me about this entrance to 
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another place. What am yo 
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A Well, in the back of 
there is 
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a little section that the dancers -- I don't know 
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exactly what they do there, but that's where I do sell 
25 
shoes and my lingerie. 
Page 508 
1 
And then there is another entrance that 
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you can go through and then there is another 
it's 
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like there's, I know that there's, there's a lot of 
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doors. I don't know what they consist of. 1 don't 
know what they do there, but I know that they are 
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t that they were affiliated with 
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and that's where I also go to sell 
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my shoes and purses. 
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Q. Oka 
about a place in 
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the back of 
the ou 
• access 
11. 
to by going through the 
12 
establishment? 
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A. Yes. 
14 
Q. All right. Now, what is this second place 
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that you are talkin a out that 
u say is 
16 
affiliated with 
17 
A. 
ter go through out the back 
18 
door of 
and take a right, and then there 
19 
is a place there that's affiliated with them. 
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Q. Is there a name? Is there a separate 
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entrance to the place? 
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A. I — they're connected. 
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Q. Is there a separate name on this place? 
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A. Not that I know of 
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Q. Okay. I'm tallthsabout a place that's 
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v it's to the left side of 
as you look at it. It's got a 
separate entrance. It's got neon signs on it? 
A. Okay. 
Q. And it's known as 
You're aware of that place, aren't you 
MR. EDWARDS: Fora 
THE WITNESS: I'm not aware of any name. 
BY MR. LUTHER: 
you w 
in the establishment known 
as 
on the evening of 
Saturday, January 30th, 2010, were you not? 
MR. EDWARDS: Font 
THE WITNESS: If that's what it's called, 
MM.
long, as far as I know, 
that's the name I know it as 
of, you know. 
BY MR. LUTTIER: 
Q. Well, this is a place that has a separate 
Y 
don't go through the entrance of 
for a place called 
. 
rate entrance 
A. Well — 
Q. I want to make sure we're real clear here 
we're not playing semantics. 
Page 510 
1 
A We're not playing what? 
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Q. Semantics. 
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A. Okay. 
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MR. CRITTON: Word games. 
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THE WITNESS: Oh. 
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MR. LUTTIER: All right? 
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THE WITNESS: Yeah. 
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BY MR. LUTTIER: 
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Q. Sil dai
rwere in fact, in this place 
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called 
on Saturday, January 
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30th, 2010, were you not? 
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MR. EDWARDS: Object to the fonn. 
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THE WITNESS: I definitely walked through 
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an elmitithought 
was affiliated 
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with
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BY MR. LUTTIER: 
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Q. And there's a black female in there that 
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works at the front desk, is there not? There was on 
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Saturday night. 
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A. Oh, I don't know. I don't know who works 
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there. I don't blow. 
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Q. And the --
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A. I just know that I go into 
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I sell my — 
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Q. And — 
and 
3 (Pages 507 to 510) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
b5542fef-d299-4o4f-9ba6.85aad2714405 
EFTA01076161

Page 511. 
— items. 
2 it . 
the name that you're known as is 
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isn't that right? 
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A. I'm not known as r= 
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Q. That's the name you remember we were 
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asking you about the cards you used to use? 
A. Yeah, I was known as =in 
'07 and '08. 
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Q.
 that's the name you've used in the past 
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is
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A. Yes. 
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Q. And in fact on Saturda January 30th, you 
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were working in 
which was. 
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to use your terms, a 
were you not? 
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A. NA I was not working there. 
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Q. And you were charging $120 fora half hour 
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to perform services; isn't that right? 
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A. No. 
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Q. Andacame out and told somebody your 
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name was Mend that that was your charge, 
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didn't you not? 
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A. No, I did not. All I do is sell shoes and 
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purses there. 
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MR. LUTRER: Let me show you a picture 
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here which we'll mark as, !guess we want to do 
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it in order. It will be Exhibit 3. 
Page 513 
1 
A. No. I say to the girls, my name is 
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they know that I sell all of my, all of my cil
anand 
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lingerie and shoes and everything else I sell. 
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Q. But there is no doubt that now that you 
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have seen this picture, you were in that 
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establishment that is depicted on Exhibit No. 3 on 
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January 30th, right? 
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A. Correct. 
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Q. And you drive a white Mitsubishi Gallant; 
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is that right? 
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A. Yes. 
i 2 
Q. License plate number is 
is that 
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correct. 
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A. I don't know my license plate number, but 1 
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definitely drive a white Mitsubishi Gallant 
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Q. And is, was that vehicle parked outside 
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of the Palm Beach on Saturday night, 
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atu
rn
y e 30th? 
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A. Yes, but like I said before, from my 
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knowledge, I thought this was affiliated with 
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Q. And that car 
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A. And they don't like me to park, they don't 
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like me to park in front of 
because 
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there are so many clientele Agoe
fl
n., out. So 
Page 512 
1 
(Defendant's Exhibit No. 3 was marked for 
2 
identification.) 
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THE WITNESS: This place, yeah, ifs next 
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to -
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MR. LUTTIER: Hold on. Hold on. 
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THE WITNESS: Sorry. 
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BY MR. LUTTIER: 
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Q. I have to ask you a couple of questions. 
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Do you recognize Exhibit 3? 
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A. Yes but what I would do, 'would go out of 
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from the beck and go into the back 
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entrance of 
or whatever this place is called. 
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Q. SA so, now upon seeing the picture, you 
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want to correct our testimon and say, in fact, you 
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were in 
on Saturday? 
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A. I, from my understanding, from my knowledge, I 
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thought that this place was owned by 
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Q. All right. The place of business that's 
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depicted in Exhibit No.3, were you in that place of 
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business on Saturday, January 30th? 
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A. Yes, selling my items. 
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Q. And did you, in fact, on that night, on 
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Saturday, hus30th, toll individuals that your 
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24 
name was
and that you charged $120 per half 
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howl 
Page 514 
1 
they need as much parking space as they can. 
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until what hour on the 
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Q. And you stayed at 
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be January 31st? 
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A. I stayed until what time? 
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Q. Yeah, the morning until — what time on 
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the morning of Sunday, January 31st, did you leave? 
A. Well, 
I would go wail 
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closing like 5, .. •t"
.1
1 m le back of here, of 
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that's like, sometimes they have after 
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parties t
 This is what I hear from the, 
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sometimes lam/MM.; 
a couple of drinks. 
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the manager at 
And like I said, 
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And I'm not sure what time I left 
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Q. I don't want to know — 
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A. As long estkeep on selling shoes and 
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lingerie, I'm the there. 
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Q. I am not asking about sometimes. T am 
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talking about Sunday morning, January 31st, 2010, 
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what time did you leave on that day? 
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A. I couldn't tell you that. I don't know. 
Q. Well, what's your best estimate? 
A. I don't know, sir. 
Q. Well, first of all you closed 
at, what, 5 in the morning? 
a......4:01.3.4SOW.,••••••••.•...mveatilmcnista 
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PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by cynthia hopkins 
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Page 515 
1 
A. I closed it? 
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Q. Yeah, you were them until it closed? 
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A. Yes. 
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Q. And then you went over to 
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right? 
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A. That I thought was 
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back 
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Q. Whatever. 
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A. Okay. 
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Q. And then, how much longer did you stay 
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there? 
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A. I stayed there a little while because there is 
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more girls there that like to buy my items. 
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Q. Now, let's talk about your trip to New 
15 
York 
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A. Okay. 
17 
Q. Tuesday, February 2nd, 2010. Remember I 
18 
asked you earlier about whether you ever used any 
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business cards? 
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A. Yes. 
21. 
Q. When you went on this trip to New York, 
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did you have any cards? 
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A. No, not that I 
no. 
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Q. Did 
M
.
 
have any cards? 
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A. Not that I know of. 
from the 
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A. And we started talking to people. 
Q. Who did you talk to in particular? 
A. I don't know anyone else. 
Q. Did you talk to a male there? 
A. Yeah. 
Q. Have him over at your table? 
A. He came closer to — we were at the bar. 
Q. The three of you were talking, were you 
not? 
A. Yeah. 
Q. Do you remember the guy having a laptop? 
A. Yes. 
Q. What did you-all do on the laptop or what 
did he do on the laptop while you were there and you 
both were sitting there? 
Well, I told him that I modeled for 
And I told him if he would like to see my 
pictures, to go onto 
Q. So, did you tell him about any other 
websites? 
A. Excuse me? 
Q. Did you tell him about any other websites? 
A. No, not that I recall. 
MR. LIMIER: Let's mark this as 
exhibit — what's this, 4? 
Page 516 
1 
Q. Did you, when you went to the Palm Beach 
2 
International Airport, did you give the taxicab 
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driver a card? 
4 
A. Did I give hi 
card? 
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Q. Yeah, you or M., little business card? 
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A. I didagive him a card, no. 
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Q. Did M. give him a business card? 
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A. Not that I know of. 
• 
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Q. When you went into the Palm Beach 
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International Airport, your card — do you recall 
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going to a bar? 
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A. Palm Beach International Airport, yeah, I went 
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to a bar there — 
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Q. What bar do you go to? 
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A. — because I totally missed the flight. 
1.6 
Q. What bar did you go to? 
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A. I think it was Fridays, if I am not mistaken 
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or not. I don't know what it was called. 
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Q. Who went VS bar with you? 
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A. 1 went with M. to the bar and it was just 
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her and 1. 
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Q. And for how long was it just the two of 
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you? 
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A. For like ten minutes. 
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Q. And then what happened? 
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PROSE COURT 
Page 518 
THE COURT REPORTER: Four. 
MR. LUTHER: Mark this as 4. 
MR. EDWARDS: Is Exhibit 1 and 2 marked —
MR. LUITIER: Yeah. 
MR. EDWARDS: 
in the previous depo? 
MR. LUTHER: Yeah, the previous depo. 
Although I don't know where the exhibits are or 
they were. 
MR. EDWARDS: Okay. 
MR. LUTTIER: It was like answers to 
interrogatories. Something like that. 
MR. EDWARDS: Okay. 
(Defendants Exhibit No. 4 was marked for 
identification.) 
BY MR. 
Q. Let me show you what's been marked as 
Exhibit 4 and ask you if you can identify that. 
A. This is —
MR. EDWARDS: Wait until he asks you a 
question. 
BY MR. LUTHER: 
Q. Can you identify it? 
A. Yes. 
Q. What is it? 
A. This  si— 1 modeled forallitand 
it 
_ 
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REPORTING AGENCY, INC. 
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Page 519 
1 
is their advertisement now. 
2 
Q. And is this one of the pictures on your 
3 
website? 
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A. On my website? 
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Q. Yeah or your Facebook, !guess, account 
6 
or MySpace, whatever it was. 
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A. Yeah, I have posted it on there, yeah. 
8 
Q. Is, was this one of the pictures you were 
9 
telling us at your last deposition that you really 
10 
wouldn't want your four-year-old son to see? 
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A. No, that's fine if he sees this. This is, 
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this is very legit. His mother modeled and I am 
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actually very proud of this photo. 
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Q. All right. Now, did you do anything else 
15 
with this indigaial before you left the bar that 
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you, you and M. were talking to at the Palm Beach 
17 
International Airport? 
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A. Did we do anything with him? 
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Did you give him anything, either you or 
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21 
A. I don't recall givinglupt anything but —
22 
Q. Well, did you see M. give him anything? 
23 
A. No. 
24 
Q. Did either one of you give him a business 
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card? 
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Page 521 
Q. Did you do anything else that evening? 
A. Yes, we went out to dinner. 
Q. After you — did you leave the apartment 
and go look around at Grand Central Station and then 
keep on walking around or did you come back to the 
apartment? 
A. We went back to the apartment. 
Q. Okay. And then there came a time after 
you came back from sightseeing that you left the 
apartment a second time? 
A. Yes. 
Q. And that was for what purpose? 
A. We went to Angelo's. 
Q. Okay. And how did you get to Angelo's? 
A. We got to Angelo's in a taxi. 
Q. A taxi? 
A. Uh-huh. 
Q. And that was about what time? 
A. Oh, jeez, maybe, maybe 9:00. 
Q. Between the time — what time did you go 
looking at Grand Central Station? 
A. That was before 9:00. 
Q. Okay. And do you remember, do you recall 
that evening an individual by name of Martin 
Krouner? 
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Page 520 
A. I don't have any business cards. I don't —
Q. Well, I don't — you may want to be 
careful here. I don't want to trick you. lam not 
playing semantics. Did either you or 
give him 
a business card? 
MR. EDWARDS: Object to the form. 
THE WITNESS: Not that I recall, no, sir. 
We had a few drinks and, and we were off to our 
flight. 
BY MR. LUTTIER: 
Q. And then you flew to New York and you took 
a c 
and 
u went to this apartment that's located 
at 
in New Yor • is that right? That 
would be the corner of 
A. 
rings a bell. 
That's where we stayed? 
Q. Yeah. 
A. Yeah. 
Q. Now, on that evening, the first night that 
you got there on Tuesday, I think earlier you said 
you-all walked down a street and went to dinner, is 
that right? 
A. We walked down the street and we walked into 
a, I think it's Grand Central Station. I'm not sure 
because I'm not from there and we looked around. Yeah. 
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Page 522 
A. Do I know a man named Martin? 
Q. Uh.huh, Martin Krouner. 
A. No. 
Q. Do you remember getting in a black 
Series 5 BMW when you came out of the condominium? 
A. We, we did take a ride with a man. 
Q. Well, 'thought you just told me you 
walked to the restaurant. 
A. No, 'told you I took a cab to the restaurant. 
Q. Oh, took a cab to the restaurant? 
A. Yes. 
Q. Did you forget about getting in a car with 
this man? 
A. He took us a little sightseeing. No, I did 
not forget about that. 
Q. Was that before dinner? 
A. That was before dinner, yes. 
Q. Did you just fail to mention that or —
this is different than the man who took you 
sightseeing later, isn't it? 
A. Yes. 
Q. Okay. So, tell me who Martin Krouner is. 
A. I don't know his name, if that is his name. 
Q. Well, the guy that picked up in the black 
BMW, who's he? 
6 (Pages 519 to 522) 
PROSE COURT REPORTING AGENCY, INC. 
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A. I guess a friend of_. 
2 
Q. Well, tell us how old this individual was. 
3 
Describe him for us. 
4 
A. He has not a lot of hair. He's about five-six 
5 
maybe and a little chubby. 
6 
Q. For what purpose were you — and you never 
7 
met him before? 
8 
A. No. 
9 
Q. 
never met him before? 
10 
A. No. 
11 
Q. You didn't have any idea who he was? 
12 
A. No. 
13 
Q You-all climbed in 
car? 
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A. Yeah, I thinkit was 
friend. 
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Q. Okay. What did 
tell you about the 
16 
guy? 
17 
A. She's Chinese. She's like go, go; go, go have 
18 
fun, go search the town. 
19 
Q. So, where did you go with Martin? 
20 
A. We ended up meeting him at Angelo's. 
21 
Q. Wait a minute. You got — first of all 
22 
you got in Martin's car, right? 
23 
A. I got into Martin's car, yes. 
24 
Q. And then where did you go once you got in 
25 
Martin's car? 
1 
fellow here, Mr. Martin Krouner? 
2 
A. If that's his name. I don't know if we took a 
3 
picture of him, but we definitely took pictures of M. 
4 
and I. 
5 
Q. And, and where did you take those 
6 
pictures? 
7 
A. Wherever we were. 
8 • 
Q. Okay. And when this man brought you back, 
9 
did he go to darner with you? • 
10 
A. He ended up meeting us there, yes. 
11 
Q. Did he drop you at the restaurant? 
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A. He dropped us near so we can get there with a 
13 
taxi. He dropped us somewhere off of the street and we 
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went with a taxi. 
15 
Q. So, he dropped you off and then you got a 
16 
taxi to get there? 
17 
A. To go to Angelo's, yeah. 
18 
Q. And then he met you there later? 
19 
A. Lateran. 
20 
Q. Okay. About what time? 
21 
A. Oh, God, I don't know the times. Maybe this 
22 
was around, maybe around — I'm — this is total 
23 
ballpark, lace 10 maybe. 
24 
Q. Okay. Anal& and then after dinner 
25 
what did you and M. and he do? 
Page 524 
1 
A. We searched around the town. 
2 
Q. What do you mean you searched around? 
3 
A. We went sightseeing. 
4 
Q. Okay. Do you remember where you went? 
5 
A. And we went sightseeing. 
6 
Q. Do you remember where you want 
7 
sightseeing? 
8 
A. Then we took a taxi. No, because I don't know 
9 
the area. 
10 
Q. You went sightseeing in Mr. Kroner's car, 
11 
correct? 
12 
A. Yes. 
13 
Q. All right. And, and did there come a time 
14 
that you got of Mr. Kroner's car? 
15 
A. Yeah, and we looked around. It was filming 
16 
outside, so it was nice to feel the snow. 
17 
Q. And where did you get out of the car? 
18 
A. Sir, I don't know New York. I don't —
19 
Q. Well, was it at a restaurant? Was it at 
20 
the pool? Was it back at the condo? Where was it? 
21 
A. R was near a whole bunch of buildings. 
22 
Q. By the way, did you take any pictures 
23 
while you were up there? 
24 
A. I did take pictures. 
25 
2. Take a icture of you at 
and this 
Page 526 
1 
A. Well, we took a taxi back to his car. And we 
2 
went up to the, we went up to 
room and he just --
3 
we just said bye. 
4 
Q. And did you receive anything at all of 
5 
value from this man? 
6 
A. No. 
7 
Q. Did you charge him anything? 
8 
A. No. 
9 
Q. Were you paid anything for the time you 
10 
spent with him? 
11 
A. No. 
12 
Q. Now, who's Robert Fredrick Burke? 
13 
A. Robert Fredrick Burke, I have no idea. 
14 
Q. Well, on the next day on Wednesday, 
15 
February 3rd, did you go sightseeing again? 
16 
A. Yes, we did. 
17 
Q. And you said that this fellow Bobby came 
18 
to see you at the apartment sometime the morning of 
19 
Wednesday, February 3rd? 
20 
A. He came to see us, ubhuh. I'm not sure what 
21 
time it was. I think it was around in the afternoon. 
22 
. Okay. And then after he eft, you and 
23 
did some more sightseeing? 
24 
A. Yeah, we walked around town. 
25 
Q. Do you remember getting in a vehicle with 
PROSE COURT REPORTING 
7 (Pages 523 to 5261 
AGENCY, INC. 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
b55421of-d299-4e41-9ba6.85aad2714405 
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Page 527 
Page 529 
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 
somebody that night? 
A. Yes. 
Q. Who did you get in a vehicle with? 
A. I told you, I don't know his name. 
Q. Well, where did you, where did you meet 
this person? 
A. Everybody was =friend. =has a lot 
of friends. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. I have no idea. 
Q. And where did this individual take you? 
A. He took us to sightseeing and he took us to 
the Statue of Liberty, everywhere. 
Q. Did you receive anything of value from 
him? 
A. No. 
Q. Did you charge him anything? 
Well, what did you know about the person? 
Nothing. 
How old is the person? 
I told you, I don't know anything about him. 
And what kind of vehicle did you get in? 
I don't even know the vehicle. 
Toyota Highlander? 
Ls it — I don't know. 
And what nationality is this individual? 
1 
A. I have no idea. 
2 
Q. Were they a male's clothes or female's 
3 
clothes? 
4 
A. I didn't search through the garbage. I just 
5 
know that I threw out the trash. 
6 
Q. So you're telling me you don't know whose 
7 
they were? 
8 
A. No. 
9 
Q. Oistry. Do you know 
10 
A. Yes, Id°. 
11 
Q. And how do you know 
12 
A. We grew up together. ro bly 'mew her since 
13 
1 was 12. 
14 
Q. Have you ever been engaged in any kind of 
15 
a business venture, regardless of whether it was a 
16 
formally formed business venture like a corporation, 
17 
but any kind of business venture with .M? 
18 
A. I went, we went to Jeffrey's togWer. 
19 
Q. My other kind of business venture, you 
20 
and her? 
21 
A. No. 
22 
Q. Were you ever, did you ever represent or 
23 
attempt to start a business venture with her? 
24 
A. This is years ago. 
25 
Q. How many years ago? 
Page 528 
1 
A. No. 
2 
Q. You or El? 
3 
A. I did not charahim anything. 
4 
Q. How about 
? 
5 
A. I don't know what she does but, no, I don't 
6 
think so. 
7 
Well, was there ever a time that you and 
8 
were not together in this person's presence? 
9 
A. Other than me going to the restroom, no. We, 
10 
I, we were pretty much together the whole time. 
11 
Q. On the evening of February 3rd, 2010, do 
12 
you recall throwing a bag of trash in the garbage? 
13 
MR. EDWARDS: Mat date is that? 
14 
MR. LUITIER: The evening of February 3rd, 
15 
2010, at approximately 9:00 p.m. 
16 
THE WITNESS: In the evening. 
17 
MR. LUTHER: Just before you got in the 
18 
Toyota Highlander. 
19 
THE WITNESS: Yes, we did. 
20 
BY MR. LIMIER: 
21 
Q. Okay. And do you recall what it was that 
22 
was in that bag? 
23 
A. There was whole bunch of clothes and 
24 
everything that 
did not want, so we threw it out. 
25 
Q. And whose c other were those? 
Page 530 
1 
A. Well, 13, 14, 15, like eight years ago. 
2 
Q. Okay. So, this is 2010. We're talking 
3 
about 2002? 
4 
A. Yeah. 
5 
Q. Okay. So tell us about the venture that 
6 
you were forming with her? 
7 
A. I don't know what you're talking about. 
8 
Q. Well, you were thinking about something 
9 
because you said years ago. You were the one that 
10 
picked the date. So, what was it you were thinking 
11 
about? 
12 
A. No, I said years ago we, we knew each other. 
13 
We used to hang out. Like we used to do little girl 
14 
stuff, go in the pool and — 
15 
Q. No, my question was, was there a business 
16 
venture and you said it was years ago. 
17 
A. It was years ago that I've known her. Any 
18 
type of business venture, not that I recall.
19 
Q. Have you ever told anyone at all that you 
20 
and 
were forming a business venture or had a 
21. 
business venture? 
22 
A. At 12, no, I don't — 
23 
Q. At any, I don't care, right up until 
24 
today. 
25 
A. No. 
? 
Noliedades
tliZteAlit•40
,
11.1111.7a....429>Veal
<aatia606
.44-L7fl4.i 
8 (Pages 527 to 530) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by Cynthia hopkins 
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Page 531 
1 
Q. Did you ever have any sort of a business 
2 
venture that involved in any way, shape, or form you 
3 
and/or her taking showers? 
4 
A. No. 
5 
Q. Did you ever tell anybody you did? 
6 
A. No. 
7 
Q. Did you ever have any literature or 
8 
written material describing such a venture? 
9 
A. Not that I recall, sir. 
10 
Q. Ever have anything that described such a 
11 
venture or any costs associated with procuring those 
12 
services if someone wanted to do that? 
13 
A. Taking showers? 
14 
Q. Well, taking showers or watching the two 
15 
of you take showers or any combination or 
16 
permutation that you can think of. 
17 
A. Not that I can think of unless we were like 
18 
stupid little girls who — I don't recall anything about 
19 
any shower or anything like that, no. 
20 
Q. Did you ever tell anybody that you had 
21 
such a business going? 
22 
A. No. 
23 
Q. Did you ever tell anybody you had such a 
24 
business going with someone other than e? 
25 
A. A business going, no. 
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 532 
Q. I don't mean a formal thing, Did you ever 
tell anybody that you were involved in any kind of 
activity involving taking showers for which you got 
paid money? 
A. Definitely not. I don't — I have never. 
And when was the last time you talked to 
A. Oh, boy. It's been years. Ballpark three 
years maybe. 
Q. And where did you talk to her three years 
ago? 
A. At the trailer that I had an 
at. 
Q. Now, your other friend, 
A. Uh-huh. 
Q. — when is the first time that you can 
recall having done any type of a drug with..? 
A. When we first started seeing Jeffrey we tried 
to numb each other with like downers, you know, 
Percocets or something just to ignore really what was 
going on between Jeffrey and us. 
Well, at the lad deposition you told 
who we know to bed 
first at
u 
to Jeffrey's. Do you recall that testimony? 
A. Yes. 
Page 533 
Q. And you testified that she provided you 
2 
with drugs? 
3 
A. Yes. 
4 
Q. All right. Now, who provided the drugs to 
5 
e? 
6 
A. I have no clue. 
7 
Q. Well, who provided the drugs to you that 
8 
you just claim you took when you were with
9 
A. I couldn't even say. Maybe, maybe 
10 
11 
Q. That's your boyfriend? 
12 
A. At the time he was my boyfriend. 
13 
Q. Well, he was your boyfriend. He became 
14 
the father of your child, right? 
15 
A. Yes. 
16 
Q. Okay. I mean, that would qualify as a 
17 
boyfriend, right? 
18 
A. If that's what you call it 
19 
Q. He was a drug dealer, wasn't he? 
20 
A. No. 
21 
MR. EDWARDS: Form. 
22 
BY MR. LUTHER: 
23 
Q. Did he provide drugs to you on more than 
24 
one occasion? 
25 
A. No, he, no, he, if anything, him and his 
Page 534 
1 
friends got together and they were stupid and young and 
2 
they did a couple of drugs, but I didn't want anything 
3 
to do with them until I met Jeffrey. And then I wanted 
4 
to numb myself to be around Jeffrey. And I know that I 
5 
would take drugs hrom him occasionally. 
6 
But he didn't like give them to me or sell 
7 
them to me or anything like that. 
8 
Q. Well, what did you do, go steal than from 
9 
him or what? 
10 
A. I would probably take him from his stash or 
11 
something but —
12 
Q. So, he had a lot of drugs? 
13 
A. No, not that I remember. I don't know where I 
14 
got these drugs from. To telLyau the truth, I really 
15 
don't recall. I don't know if.. brought them. I 
16 
don't blow if I brought them. 
17 
Q. Well, did you give these drugs toe.? 
18 
A. No, not that I recall. 
19 
Q. One thing you knew was that these were 
20 
illegal drugs, right? 
21 
A. Yes. 
22 
Q. You knew it was against the law what you 
23 
were doing? 
24 
A. Yes, especially — Jeffrey Epstein knew it was 
25 
whist t
......22!222±....t.2ndISTar-old
 girls 
9 (Pages 531 to 534) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 535 
1 
too. 
2 
MR. LUTHER: Well, Jeffrey Epstein --
3 
move to strike as not responsive. 
4 
BY MR. LUTHER: 
5 
Q. What Jeffrey Epstein told you was that you 
6 
shouldn't drink and shouldn't do drugs, didn't he? 
7 
A. He told me that he never drank or did drugs. 
8 
He was so interested in saint kind of drugs we were on. 
9 
Q. So, not withstanding what you knew to be 
10 
clearly --
11 
A. He would ask, he would be asking us so how 
12 
does Xanax make you feel, how does coke make you feel, 
13 
how does Percocets make you feel, how does this make you 
14 
feel. 
15 
Q. He never asked you to take any of those 
16 
drugs, did he? 
17 
A. No, but he would —
18 
Q. He never gave you any of those drugs, did 
19 
he? 
20 
A. No. 
21 
Q. And you claim he had all this money. He 
22, 
could have provided you with any drug he wanted if 
23 
he wanted to give you a drug, couldn't he? 
24 
A. I guess. 
25 
Q. And he never provided you with one single 
Page 537 
1 
A. Probably. 
2 
ow, you remember going 
3 
don't you? 
4 
A. Yes, l do. 
5 
Q. Two occasions you went and she went in the 
6 
room with you, didn't she? 
7 
A. She went in the room with me at the beginning, 
8 
at the first time, yes. 
9 
Q. Went in the room the second time too, 
10 
didn't she? 
11 
A. I, I think so. I'm not sure about that. 
12 
Q. Are you aware that —
13 
14 
A. I bet you have pict 
huh. 
Q. Are you aware tha 
en deposed? 
15 
A. Have been what? 
16 
Q. Has been deposed, gone through the same 
17 
process you are? 
18 
A. Oh, yes, of course. She should be. 
19 
Q. How are you aware of that fact? 
20 
A. Excuse me? 
21 
Q. How are you aware of that fact? 
22 
A. Everybody's been deposed. Most all, most of 
23 
all these girls have been deposed. 
24 
Q. Who told you that? 
25 
A. You know, the girls talk. 
there with 
Page 536 
1 
illegal drug and told you he never touched drugs? 
2 
A. No, but that's not his crime. He fondled me 
3 
when I was 13 years old. He didn't sell me drugs. 
4 
Sony, he just molested me. 
MR. LUTTIER: Move to strike. 
6 
BY MR. LUTHER: 
7 
Q. He never provided you with one illegal 
8 
drug, did he? 
9 
A. No. 
10 
Q. You went and got those all on your own? 
11 
A. Yes. 
12 
Q. You and your friends would go and take all 
13 
kinds of illegal drugs? 
14 
A. Yes, because I was scared to be around an old 
15 
man when he is touching my vagina and masturbating with 
16 
his cock in front me ejaculating all over himself, so 
17 
yes, I would, I think you would take drugs too. 
18 
Q. So, were you so scared that you said I'm 
19' 
not going anymore? 
20 
A. He was like our master. He's like IM 
21 
master. He does, anything he says, we do 
22 
because we are intimidated by him. We were scared of 
23 
him. 
24 
Q. So, if he said run out in front of 
25 
traffic, you would? 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 538 
Q. Okay. 
A. It get's around town and it's in the newspaper 
every weekend, so how 
not know? 
Q. Did you talk tc 
A. No, I did not. 
4 
Okay. So, how did you know 
had 
been deposed if she was deposed? 
MR. EDWARDS: Object to the form to the 
extent —
THE WITNESS: Of course she's been 
deposed. 
MR. EDWARDS: Hold on. Hold on — to the 
extent that you're asking for attorney-client 
privilege information which you did —
MR. LUMEII: No. 
MR. EDWARDS: — in the first deposition 
and it sounds like you're going there again --
MR: LUTHER I don't want to know 
anything your lawyer said. 
MR. EDWARDS: — about talking to my 
client 
BY MR. LUTTEER: 
Q. I don't want to know any • 
wyer 
said. Have you seen a transcript of 
de 
ition? 
10 (Pages 535 to 538) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
Electronkally signed by Cynthia hopkins 
b5542febc1299-4e41-9ba6-85aad27f4405 
EFTA01076168

Page 539 
1 
MR. EDWARDS: Object to the form. If she 
2 
has seen a transcript, that would obviously 
3 
being something that her attorney has shown 
4 
her. That is not something she would have seen 
5 
independent of that. So that would be 
6 
protected information. 
7 
MR. LUTTIER I, I mean, I don't think -
8 
1 think if you show her a copy of a deposition, 
9 
that is not protected by attorney-client 
10 
privilege. If you had a discussion with her, I 
11 
agree with you, whatever your discussions were. 
12 
But the fact that you showed her the transcript 
13 
I don't think is protected by the privilege. 
14 
BY MR LUTTIER: 
15 
Q. Have ou ever seen a co y of the 
16 
transcript o 
deposition? 
17 
A. Not that I lcnow o 
18 
Q. Well, did ou know that -- or strike that 
19 
20 
laNwere wit 
. Tstem on t e secon 
21 
occasion when she took you there, isn't it true that 
22 
you began a conversation with Jeffrey discussing 
23 
what you and your mother did and how much you 
24 
charged for various things? 
25 
A. False. 
Page 
1 
A. Am I religious? 
2 
Q. No, do you have a religious affiliation? 
3 
'Are you associated with a particular in 
4 
A. Yes. 
5 
Q. Protestant, Catholic, Jewish? 
6 
A. Yes, I am. 
7 
Q. What Illwould that be? 
8 
A. I believer m Jesus Christ. 
9 
Q. Any particular organized -- do you know 
10 
what I mean by organized religion? There's, theres 
11 
a bunch - 
12 
A. !would like to call myself a Christian but I 
13 
believe that the Lord, Catholics, Jews, Buddhism, it 
14 
doesn't matter because it shouldn't be judged. It 
15 
shouldn't be organized. The Lord doesn't — the Lord 
16 
doesn't organize anything. I just know that I am, I am 
17 
very spiritual and I do love the Lord very much. 
18 
Q. Okay. So you would characterize yourself 
19 
just as a, for lack of a better term Christian? 
20 
A. lam very spiritual. 
21 
Q. Okay. 
22 
A. And I pray every day. 
23 
Q. Do, do you participate it an organized 
24 
religion? 
25 
A. Do I go to chinch? 
Page 540 
1 
Q. Sexual nature. 
2 
A. No. 
3 
Q. Is there any reason 
4 
would want to make that story tqr 
5 
MR. EDWARDS: Object to the form. 
6 
THE WITNESS: I have no idea. 
7 
BY MR. LUTTIER: 
8 
Q. And isn't it true that when you began —
9 
A. She knew Jeffrey more than I did. 
10 
Q. Well, didn't --
11 
A. This is the first time or second time I had 
12 
ever been with Jeffrey. I didn't tell him anything; 
13. 
only the questions he asked nte. 
14 
Q. And, and isn't it true that when you began 
15 
to talk to Mr. Epstein and discuss with him what you 
16 
and your mom did and the prices u would charge for 
17 
things that Mr. Epstein 
to leave 
18 
the room? 
19 
A. I don't even know why my mother is brought up 
20 
in this because, no, I would never talk about my mother 
21 
as being a prostitute. She did not raise me like that. 
22 
My mother is a very beautiful person inside and out and 
23 
she would never raise me like that. 
24 
Q. By the way, what is your — do you have a 
25 
religious affiliation? 
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 
Q. 
A. 
Q. 
A. 
Page 542 
Yeah. 
Yes. 
And where did ou o? 
I've been to 
Tye been to 
was the last time you were at 
mber '08. 
Q. And where did you go, for Christmas? 
A. Before Christmas. 
Okay. And when was the last time you were 
September '08. 
Q. Okay. Are you members of either of those 
churches or you just went to them? 
A. If you want to call me a member, I —
Q. Are you a registered in them? 
A. — I attend, I attend 
yes. 
Q. Do you attend it wr some 
o 
regularity? 
A. Yes. 
Q. And how often? 
A. As often as I can. 
Q. Okay. Well, I mean, I don't want to pin 
you down to a scpecific number of!latu!.22ow many 
11 (Pages 539 to 542) 
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Page 543 
1 
days a month would you say on average you go? 
2 
A. As of tight now, one, unfortunately. 
3 
Q. And when you say unfortunately, are you 
4 
unable to go more days? 
5 
A. No, I would love to go more days. 
6 
Q Okay. Was there something that prevents 
7 
you from going more days? 
9 
A. I have a busy life. 
9 
Q. Okay. What is it that you're doing that 
10 
prevents you from going more days. 
11 
A. Well, lam trying to get my son enrolled into 
12 
Christian school, and there's a lot of bills that need 
13 
to be paid and things that need to be done, errands that 
14 
need to be ran, clothes that need to be washed, food 
15 
that needs to be bought, time I need to spend with my 
16 
son. 
17 
Q. So, it's errands and clothes, laundry, 
16 
purchasing groceries and stuff, and time with your 
19 
son that prevents you from being able to attend more 
20 
frequently; is that right? 
21 
IVIR. EDWARDS: Object to the form. 
22 
THE WITNESS: Stn. 
23 
BY W. LUTHER: 
24 
Q. You set your own work hours, right? 
25 
A. Yes. 
Page 545 
1 
A. You guys have been there before. You should 
2 
know. 
3 
Q. It's the same house she's always lived in? 
4 
A. No. She hasn't lived there her whole life. 
5 
Q. Okay. But I mean while you were a kid, 
6 
when, when you were living with her; is it the same 
7 
place that she lived in? 
8 
A. No. 
9 
Q. Bow long has she been living where she is 
10 
now? 
11 
A. I don't know. There's been a couple of years 
12 
that my mother and I haven't talked. 
13 
Q. Well, when was the last time you talked to 
14 
your mother? 
15 
A. Today. 
16 
Q. And, and when did you talk to her? 
17 
A. This morning. 
18 
Q. And why did you talk to her this morning? 
19 
A. So she could pray with me over the phone. 
20 
Q. And when was the last time you talked to 
21. 
her prior to this morning? 
22 
A. Last night 
23 
Q. Did I misunderstand? I thought you said 
24 
there was a - 
25 
A. There was a period in my life that we didn't 
Page 544 
1 
Q. Your mother is 
and I may get 
2 
this name sort of, 
is it? 
3 
A. Yeah. 
4 
Q. Did I !announce it right? 
5 
A. No. 
6 
Q. 
w ou do pronounce that? 
7 
A. 
8 
Q. 
. And is she currently married? 
9 
A. No. Can I have a tissue? 
10 
Q. And where does she currently live? 
11 
A. In 
12 
Q. In what development? 
13 
At I don't know what the developments called. 
14 
MR EDWARDS: Can we take a split second 
15 
break to take grab a tissue? 
16 
MR. LUTTIER: Sure. 
17 
MR. EDWARDS: 1 don't see one right now. 
18 
THE VIDEOGRAPHER: Going off the record at 
19 
228 pm. 
20 
(A brief recess was held.) 
21 
THE VIDEOGRAPHER: We're back on the 
22 
record at 2:32 p.m. 
23 
BY MR. LUTHER: 
24 
Q. Okay. You're saying you don't know the 
25 
development that she lives in 
PROSE COURT 
Page 546 
1 
talk. 
2 
Q. Okay. So that's some past period of time? 
3 
A. Yes. 
4 
Q. When did that change? 
5 
A. Around May '09. 
6 
Q. And what is it that caused the change in 
7 
May of '09? 
8 
A. I was living my life and she was living hers. 
9 
Q. What does that mean? 
10 
A. I was living my life and she was living hers. 
11 
Q. Okay. Why did that, why did that 
12 
facilitate — 
13 
m ire 
was taking cafe of my sister that has 
14 
and they were going through a lot, so I left it 
15 
alone. 
16 
Q. My question was what caused in May of '09 
17 
this period of estrangement between you and your 
18 
mother to end? 
19 
A. I just told you. 
20 
Q. You said that your mother - 
21 
A. My mother and I, she had — my.
was
22 
taking care ofkiter who has severe 
23 
Q. That's 
7
24 
A. Yes. 
25 
9. Oka 
You mean duri • your 
riod of 
12 (Pages 543 to 546) 
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Page 549 
Page 547 
1 
estrangement? 
2 
A. Yes. 
3 
Q. Okay. So, you didn't communicate with her 
4 
because she was taking care of your sister? 
5 
A. Yes. 
6 
Q. Did something happen in May of '09 that 
7 
changed all that? 
8 
A. My sister moved away. 
9 
Q. 'iwere  did she go to? 
10 
A. 
11 
Q. And, and when she moved, did she go with a 
12 
boyfriend? 
13 
A. Yes. 
14 
Q. And who is that? 
15 
A. Wu name is 
16 
Q. Do you know his last name? 
17 
A. No. 
18 
Q. And she's still living in IMM? 
19 
A. Yes. 
20 
Q. Now, what's the relationship between you 
21 
and your sister? 
22 
A She's, she has like she's a little slow, so 
23 
we can't really relate but other than that I love her. 
24 
Q. Well, haven't you in the past been violent 
25 
toward your sister? 
Page 548 
1 
A. Yeah. 
2 
Q. And tell us exactly what you did to your 
3 
sister. 
4 
A. Well, when I was 14, 15,14, I was like 
5 
mentally abusive to her because I guns I was just 
taking out everything, all of my pain from what was 
7 
going on with Jeffrey, and I would just take it out all 
8 
on her. 
9 
Q. What do you mean by you would take it out 
10 
on her? 
11 
A. I was mentally abusive to her. 
12 
Q Well, describe what it is you actually 
13 
did. 
14 
stuttered; l would make fun of her. She 
15 
has 
I wouldn't respect it. 
16 
Q. And did your sister actually have to get a 
17 
restraining order against you? 
18 
A. No. 
19 
Q. Did your sister ever get a restraining 
20 
order against you? 
21 
A. Not that I know of. She's slow. She's not 
22 
all there. She has like part =. 
23 
Q. Now, did your mother discuss with you 
24 
about whether she ever had any discussions about you 
25 
with an
 else? 
A. Excuse me? 
2 
Q. Did your mother ever discuss with you 
3 
whether she had any conversations about you with 
4 
anybody else with respect to this lawsuit? 
5 
MR. EDWARDS: Is this in addition or 
6 
different than the previous discussion that wm 
7 
discussed at the first deposition? 
8 
MR. LurnER: I won't know until she 
9 
ansmms 
10 
MR. EDWARDS: But is this a separate 
11 
occurrence from what she was asked at the last 
12 
deposition? 
13 
THE WITNESS: No, she's never discussed 
14 
anything else with anyone else, no. 
15 
BY MR pima 
16 
Q. Okay. 
17 
A Not to my knowledge. 
historically as a child you used 
would she be 
Q. And if yourmothertnld
ry that 
18 
20 
telling the truth? 
21 
A. Yes. 
22 
Q. Do you mho• 
23 
A Yes, I dm 
24 
Q. And who is that? 
25 
A Ekriumrent boyfriend. 
is? 
Page 550 
1 
Q. And do you believe him to be a truthful 
2 
individual? 
3 
A. Yes. 
4 
Q. And how long has he known your mother? 
5 
A. For 15 years. 
6 
Q Do you know of anything he has told 
7 
anybody else about what it is your mother used to do 
8 
fora living? 
9 
A. No. 
10 
Q Is the first time that you've heard any 
11 
reference to your mother being a prostitute in this 
12 
case? 
13 
A. No. 
14 
Q. When else have you heard that? 
15 
A. I have never heard that my mother was a 
16 
prostitute. 
17 
Q So, what I am saying is, is the first time 
18 
that you have heard that issue even come up in this 
19 
case? 
20 
A. This is the first time I am hearing this, yes. 
21 
Q. Did you discuss with your mother the 
22 
activities you were engaging in with Mr. Epstein at 
23 
the time that you were engaging in them? 
24 
A. I kept everything a secret until years later 
25 
when after I had my son and then 1 told her what went 
13 (Pages 547 to 550) 
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Page 551 
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on. 
2 
. Earlier ou said at 15 you worked for 
3 
4 
A. Yes, 
5 
Q. And my notes are unclear. I believe I 
6 
asked you, did you tell them how old you were. Do 
7 
you remember me asking you that question? 
8 
A. (Witness nods head). 
9 
Q. And what did you respond? 
10 
A. I told them 1was 19. 
11 
Q. Okay. Did you provide them with any kind 
12 
of proof/ 
13 
A. No. 
14 
Q. And why did you lie to them and tell them 
15 
you were 19 if you were really 15? 
16 
A. Becausei wouldn't be able to work there. 
17 
Q. Did you tell other people that you were 
18 
older than you really were? 
19 
A. Yes. 
20 
Q. Who else did you tell you were older than 
21 
you really were? 
22 
A. Probably everybody I came across. 
23 
Q. So, that would be many people? 
24 
A. Yes. 
25 
Q. All of the various adult entertainment 
1 
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Page 553 
at
WITNESS: I worked at 
Once I turned 18, I told everybody my 
age-
BY MR. LUTHER: 
Q. Well, you worked at a place called 
when 
you? 
A. 
I told them I was 19 as well. 
Q. When you were how old, 14? 
A. Yes. 
Q. Okay. And then what, what was the next 
place yobiliavent to do topless dancing? 
We'll do 
separate from to less dancing. 
A. I don't know. I worked at 
when 
1 was 14. I worked at 
when I was 
15, and I worked for Jeffrey throughout all those years. 
Q. X2v 
Mfr
.
s_
 t a lot of other
besides 
and MN= 
didn't you? 
A. Not when 115. 
Q. Well, I want to start there and keep on 
going. 
A. We already know the places I've worked at. 
We've been through this. We've went through this for 
the last deposition. 
Q. That's why — 
Page 552 
1 
places you worked at. The places, the topless bars 
2 
you worked at, did you tell all of them you were 
3 
older than you really were? 
4 
*iad of time when I worked at 
5 
I told everyone I was 19. Jeffrey knew 
6 
how old I was. And Jeffrey new how old every girl I 
7 
brought there was, and he wanted young girls all the 
8 
time. 
9 
Q. Does that have anything to do with the 
10 
question that I asked? 
11 
MR. LUTT1EFt: 1 move to strike. 
12 
THE WITNESS: The question you asked has 
13 
nothing do with Jeffrey. 
14 
MR. LIJTTIER: Let's, let's go back. If 
15 
you will read the question that I asked. If 
16 
you will listen to this question, that's the 
17 
one I would like you to answer. 
18 
THE WITNESS: I know you guys love to get 
19 
paid but — 
20 
(Ile requested portion of the record was 
21 
read by the reporter.) 
22 
THE WITNESS: At what period of time? 
23 
MR. LUTTIER: At any time. From the time 
24 
you first worked at one to the last time you 
25 
worked. 
Page 554 
1 
A. And we've already been through this for this 
2 
deposition. 
3 
Q. — I am giving you the chance to 
4 
sturunarize, so let's just go down and —
5 
A. You already know the places I worked. 
6 
Q. I am asking you as to each one, how old 
7 
you told them you were. 
8 
A. When I was underage, I told theml was 19 
9 
years old. 
10 
Q. Every place that you worked? 
11 
A. Yes. Except Jeffrey's, Jeffrey knew that 
12 
was 13. I'm sick of this. 
13 
Q. So, at 
you told than 19. Is that 
14 
just the number you picked? 
15 
A. On advice of counsel I am invoking my Fifth 
16 
Amendment rights under the United States constitution. 
17 
MR. EDWARDS: Do you want to take a break 
18 
or are you all right? 
19 
MR LIMIER: Yeah, do you want to take a 
20 
break? 
21 
THE WITNESS: No. I want to get this done 
22 
and over with. I am sick of it. Jeffrey is —
23 
it's disgusting. 
24 
BY MR. LUTHER: 
25 
Q. Flirts xou told them tou were 19? 
14 (Pages 551 to 554) 
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Page 555 
A I was — on advice of counsel, l am invoking 
2 
my Fifth Amendment rights under the United States 
3 
Constittigis. 
4 
Q. 
whatever, = 
whatever it 
5 
was, you told them you were 19? 
A. 
Q. 
whatever. 
A. I was of age. 
Okay. How about when you were at ■ 
were you of age then? 
A. 
Q. 
Showgirls? 
A. Yes, I was of a . 
Q. And how about 
were you 
of age then? 
A. On advice of counsel I invoke my Fifth 
Amendment rights under the United States Constitution. 
Q. Did you wort( ata 
A. On advice of council I'm invoking my Fifth 
Amendment rights under the United States Constitution. 
And what work did you do at 
A. I'm over this shit. 
MR. EDWARDS: Let's take a break. 
THE WTTNESS: No. On advice of counsel I 
1 
a — 
2 
A. 
3 
Q. 
4 
A. 
5 
Q. 
6 
A. 
Yes. 
— store? 
Yes. 
And that was upsetting to you? 
Yes. 
Page 557 
7 
Q. Why was it upsetting to you? 
8 
A. I was trying to say hello tomitle sister 
9 
who was three at the time. And 
was mad at my 
10 
father and she didn't want me talking to my little 
11 
sister. So, she doesn't know the American rights 
12 
because she's from Mexico and she totally mazed me when 
13 
I was trying to hug my little sister. 
14 
(Mr. Goldberger entered the deposition 
15 
room.) 
16 
THE WITNESS: I just hope Jeffrey gets 
17 
what he deserves. 
18 
BY MR. LUTT1ER: 
19 
Q. And what's that, Ma'am? 
20 
A. Punishment for putting us girls through all 
21 
this. 
22 
Q. That is those things that you are talking 
23 
about the times that you elected to go back to his 
24 
house and get paid to give him massages? 
25 
A. He demanded us to over the phone, sir. 
Page 556 
1 
am invoking my Fifth Amendment rights under the 
2 
United States Constitution. 
3 
BY MR. LUTTIER: 
4 
Q. Are you fearful that you're 
in to be 
5 
prosecuted for something about 
? 
6 
A. No. 
7 
Q. So, well then, what are you asserting the 
8 
Fifth Amendment for? 
9 
A. Because I want to. 
10 
Q. Because what? 
11 
A. Because I want to. 
12 
MR. EDWARDS: Listen, don't engage with 
13 
him. Just read. 
14 
BY MR. LUTTIER: 
15 
Q. Do you know 
16 
(phonetic). 
17 
A. I know a 
18 
Q. Okay. And who is that? 
19 
A. My step-mother. 
20 
Q. Married to your father, 
21 
A. Yes, sir. 
22 
Q. And have you had a confrontation with her? 
23 
A. What kind of confrontation is this now? 
24 
Q. Did you ever have a confrontation with 
25 
her, a physical confrontation in the parking lot of 
1 
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Page 558 
Q. But nobody made you do it, right? 
A. No. But Jeffrey demanded us for us to do it. 
And as young girls we were scared of Jeffrey. And you 
know what, he will get what he deserves 
IS
t's see. You lived out 
by 
A. Yes, I did. 
Q. He lived in Palm Beach? 
A. Yes. 
Q. How many miles was it, would you say 
between those two houses? 
A. I don't know, five, six. 
Q. And you didn't, you didn't have a car 
because you weren't driving, right? 
A. No. He sent taxies to my house to come get 
me. 
Q. So, then you could have said I am not 
getting in any of the taxies you wanted me to. You 
could have said I'm not going, just like a bunch of 
your friends did, right? They said after, boom, I 
don't want to go anymore, tight? 
A. I could have said no. 
Q. As a matter of fact you had friends that 
you took, you found them, Jeffrey Epstein didn't 
find them, ru found them. 
 J 
15 (Pages 555 to 558) 
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Page 559 
A. Yeah. Because he wanted me to find them. He 
2 
said you better find me a girl the next day, or I am not 
3 
going to call you anymore. 
4 
Q. And you took them to Jeffrey Epstein's and 
5 
you told them don't worry, this is what's going to 
6 
happen, ifs easy money, right? 
7 
A. Yeah, because I was tried of Jeffrey. 
8 
Q. And some of those girls went one time and 
9 
said they didn't want to go back, right? 
10 
A. C,omxt. Because they were afraid of Jeffrey. 
11 
Q. And you could have done the same thing, 
12 
couldn't you? 
13 
A. Correct. 
14 
Q. But you wanted the money? 
15 
A. I was a poor little girl who couldn't even 
16 
afford a pair of shoes, yes. 
17 
Q. You wanted the money? 
18 
A. Yes. 
19 
Q. And not only did you want the money but 
20 
you wanted to make money taking other girls there? 
21 
A. Yes. 
22 
23 
24 
25 
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Page 560 
Page 562 
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4 
MR. EDWARDS: Objection, asked and 
5 
answered. 
6 
BY MR. LUTHER: 
7 
Q. If there isn't any, fine. If there is I 
8 
want to get them that's all. Do you know of any 
9 
others? 
10 
A. No. 
11 
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20.
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16 (Pages 559 to 562) 
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17 (Pages 563 to 566) 
PROSE COURT REPORTING AGENCY, INC. 
MR. LUTTIER: Move to strike. Not 
Page 565 
1 
responsive. Please, listen to the question. 
2 
The court reporter is going to read it back and 
3 
just answer my question. 
4 
(The requested portion of the record was 
5 
read by the reporter.) 
6 
THE WITNESS: No. 
7 
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16 
Q. And you last saw Mr. Epstein in 2005? 
17 
A. I went to his house pregnant when I was --
18 
2006, or no, I was pregnant. 1 had my son 2005, and 
19 
then 1 went to his house after 1 was pregnant 
20 
Q. I believe you told us in the last 
21 
deposition the latest you could have seen him was 
22 
September of '05. Are you changing that or is that 
23 
comet? 
24 
A. Sir, you know what, when people go through a 
25 
lot of drama in their life, 
choose not to really 
18 (Pages 567 to 570 
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Page 571 
1 
recall a lot of stuff but I blow I saw him after I had 
2 
my son. 
3 
Q. Well, you had your so. 
4 
right? 
5 
A. Yes. So, it could have been July, August, 
6 
September, October, November, December. Then maybe it 
7 
could have went on to '0,'06. 
8 
Q. Well, do you know? 
9 
A. I'm not positive but I know that I went there 
10 
after I was pregnant. 
11 
Q. That's all you --
12 
A. That's all l can tell you. 
13 
Q. All right. 
14 
A. And he didn't want me because he doesn't like 
15 
women that had a kid regardless of what their age is. 
16 
So, I had to bring another girl. 
17 
Q. And that was upsetting to you? 
18 
A. No. 
19 
Q. You thought you were his favorite girl at 
20 
one point? 
21. 
A. No. 
22 
Q. That's what you told us in the last depo, 
23 
didn't you? 
24 
A. I told I was his favorite girl? 
25 
Q. That you thought you were special and you 
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Page 573 
Page 572 
1 
were his favorite girl? 
2 
A. He made me feel special. He made me feel like 
3 
I was his favorite girl. 
4 
Q. And it upset you when you found out there 
5 
were other people going? 
6 
A. Did it upset me? 
7 
Q. Yeah. 
8 
A. No. 
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Page 574 
1 
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4 
you 
e two 
5 
right? 
6 
A. Okay. Great. Well, that goes to my son. 
7 
MR. EDWARDS: Object to form, 
8 
argumentative. 
9 
BY MR. LUTTIER: 
10 
Q. You would go and sell your wares, your 
11 
shoes. 
12 
A. So, what all the money I owe, or all the money 
13 
that l eam, goes to 'iv son. 
14 
Q. And you didn't even pay --
15 
A. Not to suits. 
16 
Q. You didn't even --
17 
A. Not to 'ceipts. 
18 
Q. You didn't even —
19 
A. Not to paper. 
20 
Q. And you didn't even pay taxes on money you 
21 
earned, did you? 
22 
MR. EDWARDS: Object to the form. 
23 
THE WITNESS: I did pay taxes. 
24 
BY MR. LUTTIER: 
25 
 
Q. Did you ?ay taxes in '08? 
19 (Pages 571 to 574) 
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