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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA01076158

46 pages
Pages 21–40 / 46
Page 21 / 46
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Page 575 
A. Yes, I did. 
Q. And did you pay on the amount of income 
you actually earned? 
4 
MR. EDWARDS: Object to the form. 
5 
THE WITNESS: It's none of your damn 
6 
business. 
BY MR. LUTTIER: 
Q. Do you know that filing a false tax return 
is a crime? 
A. Yeah, and it wasn't false. Kiss my ass. 
Q. So your, your tax return is in '08 is 
correct; is that right? Is that what you are 
telling us? 
A. No. 
Q. Is it false? 
MR. EDWARDS: Just read. 
Q. Well, ma'am —
A. Can you tell I am suffering? I hate Jeffrey 
Epstein, and I hope he burns in hell. 
On advice of counsel, I am invoking my 
Page 576 
1 
Fifth Amendment rights under the United States 
2 
Constitution. 
3 
Q. To anything in particular or just making 
4 
that statement? 
S 
A. To the question you asked me about my taxes. 
6 
Q. That question has already been answered. 
7 
A. Oh, 0 
. Next. 
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Page 577 
Pa.e 578 
20 (Pages 575 to 578) 
PROSE COURT REPORTING AGENCY, INC.'
Electronically signed by cynthia hopkIns 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
bS542fetd299-4e41-9ba6455aad2714405 
EFTA01076178
Page 22 / 46
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Page 581 
2 
3 
4 
5 
6 
7 
8 
Q. Who did 
9 
A. aezd o
10 
Q. 
11 
A. I don't know his last name. 
12 
Q. Where did you meet him? 
13 
A. I don't know. 
14 
15 
16 
17 
18 
19 
s 
some 
y you 
to . 
20 
A. No. 
21 
Q. Is he someone with whom you had some kind 
22 
of relationship? 
23 
A. Yeah. 
24 
Q. What kind of relationship did you have 
25 
with him? 
Pa •e 580 
Page 582 
1 
A. Our sons would play together. 
2 
Q. Do they still play together? 
3 
A. No. 
4 
Q. Was he a client of yours? 
5 
A. No. 
6 
7 
B 
9 
10 
el, 
o 
'ow, 
a invasion — w 
11 
do you mean when you say you've suffered invasion of 
12 
your privacy? 
13 
A. Are you serious? Well, here is one. Here is 
14 
two. 
15 
Q. So, you're talking about things that you 
16 
did --
17 
A. Investigators. 
18 
Q. — in the public? 
19 
A. All my damn, all these years that I've, after 
20 
Jeffrey they wanted -- invasion of my privacy, are you 
21 
kidding me? I can't go anywhere without anyone knowing 
22 
where I'm going. The FBI, the investigators following 
23 
me everywhere. I can't take my son out with anybody 
24 
knowing me. 
25 
Invasion of my privacy?. Everybody knows 
21 (Pages 579 to 582).
PROSE COURT REPORTING AGENCY, INC.
' 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hooking 
) 
Electronically signed by cynthia hopkins 
b664,210-d299-4•04ba6416arad27M405 
EFTA01076179
Page 23 / 46
Page 583 
1 
that Jeffrey Epstein molested me. So, if my son 
2 
wants to go out and play with somebody, oh, no, 
3 
she's the little girl that was in prostitution for 
4 
Jeffrey Epstein, so we don't want her playing with 
5 
our son. 
6 
Q. So, or do they say she's the lady that 
7 
ems her own escort service, we don't want her 
8 
playing with our son? 
9 
A. No one knows about that shit except you guys. 
10 
Q. How about when you were working for 
11 
another escort service? 
12 
A. How about what? 
13 
Q. You don't think anybody knew about that? 
14 
A. No. 
15 
Q. How about when you were —
16 
A. lam very discrete what I do. l don't put my . 
17 
name in the newspaper like Jeffrey Epstein saying that I 
18 
am a prostitute or a slave for Jeffrey Epstein. 
19 
Q. How about when you were top, dancing 
20 
topless at bars? Do you think maybe people said —
21 
A. I did that out of, like not locally. 
22 
Q. So, maybe, well, 1 mean —
23 
A. Well -
24 
Q. You wouldn't exa tl call 
25 
A. 
. I 
Page 585 
1 
all out. Everybody knows. Okay. You can sit there and 
2 
act like you, you can act like an attorney and --
3 
Q. Has the words —
4 
A. — say where has your name been? My name is 
5 
out there everywhere. Okay. l am the prostitute of 
6 
Jeffrey Epstein. I have brought young underaged girls 
7 
there. I am so horrible. 
8 
My son can't play with certain kids 
9 
because ofJeffrey Epstein now. He has ruined my 
10 
fucking life. He has brought me into this industry 
11 
that this is all I know. And now I can't even, I 
12 
can't even explain to you the hard things that I've 
13 
been through my life because of Jeffrey Epstein, 
14 
because he has taught me and many other girls how to 
15 
pull money from older men. 
16 
Q. Let's just be honest for the ladies and 
17 
gentleman of the jury: Ho didn't force you to do 
18 
anything? 
19 
A. But he taught me from a young age —
20 
Q. Wait a minute. Let me finish. 
21 
A. — when I was 13 years old. 
22 
Q. You --
23 
A. He taught me how to get money real quick. 
24 
Q. Do you — 
25 
A. — from an old man. Don't sit here and tell 
Page 584 
live in West Palm. 
2 
Q. So, you meant within the immediate 
3 
geographic area. And maybe they said, well, this is 
the lady that goes and sells her wares at all these 
5 
topless bars; we don't want our children playing 
6 
with her. 
7 
A. No, not all. They see Jeffrey Epstein and my 
8 
name all over the place and they say, you know what, I 
9 
don't even want anything to with this girl because she 
10 
was a prostitute for Jeffrey Epstein. 
11 
Can I talk to him without you in his ear? 
12 
Amidone talking? 
13 
Q. Could you just tell me one place where 
14 
your name has appeared anywhere as being someone who 
15 
saw Jeffrey Epstein? 
16 
A. It's everywhere. 
17 
Q. Well, where? Just tell me one place. 
18 
A. Where have you been? 
19 
Q. Just tell me one place. Can you cite 
20 
me — 
21 
A. Ifs in the newspaper. 
22 
Q. What newspaper ever ran your name? 
23 
A. The Initials of my name? 
24 
Q. No, your name. 
25 
A. It doesn't matter. The 
It's 
Page 586 
1 
me that I was not forced or anything like that. 
2 
Q. That's exactly what I'm suggesting. ma'am. 
3 
Do you believe that you owe, that you have a certain 
4 
le''el of responsibility for your own conduct? 
5 
A. Now I k 
6 
Q. You're.. years old. 
7 
A. When I was 13 years old, 1 didn't, I wasn't, 
8 
no, I did not have that demeanor. 
9 
Q. So, a what you thought, because you 
10 
want to clean up your imagine for your son, right? 
11 
You want him to look up — 
12 
A. Yes, I do. 
13 
Q. So, as part of tha 
ess what you 
14 
thought you would do aM is you would agree to 
15 
hire out to strange men whom you don't know for 
16 
between 3300 and $500 for what you say is to go sit 
17 
in rooms naked with them, and that's how you thought 
18 
you would prove? 
19 
A. Because that's all I know. I'm Sony. 
20 
Q. And Jeffrey Epstein didn't make you do 
21 
that, did he? You decided to do that, didn't you? 
22 
A. You know what 
23 
Q. A whole new business that you decided to 
24 
do on your own; is that right? 
25 
MR. EDWARDS: Object to form. 
22 (Pages 583 to 586) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
b55421of-d299-4041-91m6.85aad2714405 
EFTA01076180
Page 24 / 46
Page 587 
1 
THE WITNESS: — before! --
2 
MR. EDWARDS: Argumentative, asked and 
3 
answered. 
4 
BY MR. LUTTIER: 
5 
Q. Did Jeffrey Epstein ever give you the 
6 
business advice on a business plan to go out —
7 
A. Yes, he did. He gave me business advice. 
8 
Q. Wait. You started this in January? 
9 
A. You know what he told me this: He said, you 
10 
inc girls, this is business. Let's talk business, 
11 
I
.
 
You get me girls, twill pay you. Is that not 
12 
called business? 
13 
Q. So, and you quit doing that when? 
14 
A. You get me girls, and I brought him.two girls 
15 
a day, one girl a day, $200 each. That's not business? 
16 
Q. And when you —
17 
A. He taught me business and now I run business. 
18 
Q. And so —
19 
A. Just like you run business. 
20 
Q. And when did that, when did you start —
21 
A. Just like you learned how to do this, I 
22 
learned how to do this. 
23 
Q. What — so, you kamed to be a 
24 
prostitute? 
25 
A. Yes, I did. 
Page 588 
1 
Q. And you enjoy it? 
2 
A. No, !don't enjoy it, and I can't wait to get 
3 
the hell out of it. 
4 
Q. And that's why in January of '010 you 
5 
decided what you would do is start getting men to 
pay you S300 to $500 an hour to sit around naked 
7 
with them, is that right? 
8 
MR. EDWARDS: Form. 
9 
THE WITNESS: Yes, that's right. 
10 
BY MR. LUTTIER: 
11 
Q. And the last time you took a girl to 
12 
Jeffrey Epstein was when? 
13 
THE WITNESS: Did we already ask this 
14 
question? 
15 
MR. LUTTIER: When? No, the last time —
16 
MR. EDWARDS: Object to the form. 
17 
MR. LUTTIER: — you said you went was —
18 
MR. CRTITON: You're out of time. 
19 
MR. LUTT1ER: Okay. 
20 
THE V1DEOGRAPHER: Going off the record at 
21 
3:14 p.m. This is the end of Tape 2. 
22 
(A brief recess was held and 
23 
Mr. Goldberger did not re-enter the room.) 
24 
THE VIDEOGRAPHER: We're back on the 
25 
record at 3:24 p.m. This is the start of 
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Page 589 
Tape 3. 
MR. EDWARDS: Before we get started I just 
want to put something on the record that there 
was a hearing, I believe it was November 3rd, 
2009, and the judge suggested that the defense 
only have one attorney there. And his 
recommendation was such because of the 
breakdown —
MR. LUTTIER: Well, let's —
MR. EDWARDS: — in the first deposition. 
You can, you can make a record after. That is 
fine. Was because of the breakdown in the 
first deposition, and he thought that that type 
of intimidation by more than one attorney would 
lead to an additional meltdown. 
We have been fine thus far today despite 
there at a minimum always being two attorneys 
and in the last 15 to 20 minutes not only was 
Mark Luttier here and Bob Critton as it has 
been all day, but Jack Goldberger was also in 
the room. 
And once it was lined up three attorneys 
over there, either passing notes, talking in 
each other's ear, and otherwise assisting in 
the deposition or at least that was the feeling 
Page 590 
1 
from the witness, we began to have another 
2 
meltdown. 
3 
So, hopefully we can proceed with less 
4 
attorneys and we can get through this process. 
s 
But I just wanted to put on the record exactly 
6 
who was in the room when everything started to 
7 
break down just now. 
8 
MIL LUTIIER: Well —
9 
MR. EDWARDS: If you have something to 
10 
say, that's fine. 
11 
MR. LUTHER: That just is not factually 
12 
correct. Mr., first of all the judge ordered 
13 
that Mr. Critton and I could be present 
14 
throughout this deposition. Mr. Critton and I 
15 
have been present throughout this deposition, 
16 
and he and I have communicated throughout the 
17 
deposition. 
18 
Mr. Goldberger walked in here. I didn't 
19 
put a stopwatch on how long he was there. He 
20 
is not even here now. He was here for maybe 
21 
ten minutes. I had no communication at all 
22 
with him. He carne. He sat here. He got up 
23 
and he walked out. 
24 
This breakdown that you're talking about 
25 
occurred Ions before Mr. Goldberger ever of 
23 (Pages 587 to 590) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
Electronically signed by cynthia hopkins 
b5542fet-d299-4041-9ba6-55aad2714405 
EFTA01076181
Page 25 / 46
Page 591 
here. So, I dispute —
2 
THE WITNESS: No. 
3 
MR. LUTHER: — the facts, but it's sort 
4 
of a moot issue now anyway, so —
5 
MR. EDWARDS: But if we're going to get 
6 
into that, then every time he comes into the 
7 . 
room do we need to now put it on the record 
8 
that he is in the room? 
9 
MR. LUTHER: I have absolutely no 
10 
problem —
11 
MR. EDWARDS: And each time —
12 
MR. LUTTIER: Anytime he comes in, we'll 
13 
stop him and well let him know he can't come 
14 
in here. Quite frankly, if you would have said 
15 
something to me about it, I was examining the 
16 
witness, I would have stopped right then and 
17 
said, Jack, get out of the room. 
18 
MR. EDWARDS: And I know in all fairness 
19 
to what you just said I am not saying that to 
20 
you was not factually accurst; what you just 
21 
said, but you weren't able to see what was 
22 
behind you, the passing of the cellphone and 
23 
other things that the witnesses notices. 
24 
I am just telling you that this impacts 
25 
the deposition. So, I just want to make it 
Page 592 
1 
clear so that you would know exactly what's 
2 
happening and maybe we can get through this. 
3 
You know, it's all of our goals to get through 
4 
this day. So, I, I think the witnesses is 
5 
ready if you're ready, Mr. Luttier. 
6 
MR. LUTTIER: I'm ready. 
7 
MR. EDWARDS: Okay. 
8 
MR. CRITTON: What time did we start 
9 
because we haven't 
we've been on the record, 
10 
but we haven't asked a single question. 
11 
THE VIDEOGRAPHER: les 3:28 right now. 
12 
Three and a half minutes. 
13 
MR. CRITTON: Thank you. 
14 
BY MR. LUTTffiR: 
15 
Q. I am now referring to your, your 
16 
interrogatory answers. These are answers that you 
17 
gave to written questions that were sent to you in 
18 
this case. And they are entitled Defendant's 
19 
unverified better answers to first interrogatories. 
20 
I believe they may have been marked as Exhibit 1 to 
21 
the first deposition, but there is only one set of 
22 
them. 
23 
• 
MR. LUTHER: And Brad, they are, the date 
24 
of service on, I don't know, wait. Date of 
25 
service is August 4th, 2009. 
Page 593 
1 
MR EDWARDS: mats the —
2 
MR. LUTHER: Defendants unverified 
3 
better answers to first interrogatories to 
4 
Plaintiff. Later I'm going to come to the 
S 
Plaintiffs supplemental better answers to 
6 
Defendant's Interrogatory No. 19. 
7 
MR. EDWARDS: Okay. But you said the date 
8 
of service meaning you saved on us? 
9 
MR LUTHER: No, no. Your answers, 
10 
better answers. 
11 
MR. EDWARDS: Got it. I am looking as the 
12 
same document you are. 
13 
BY MR. LUTHER: 
14 
Q. All right. Ma'am, in response to some 
15 
interrogatories you stated that from the end of 2007 
16 
to November of 2008 you worked at 
17 
earning S1100 a week. So that would have been a 
18 
period of approximately one year; is that right? 
19 
MR. EDWARDS: Read. 
20 
THE WITNESS: On advice of counsel I am 
21 
invoking my Fifth Amendment rights again under 
22 
the United States Constitution. 
23 
BY MR. LUTHER: 
25 
you worked at 
 
what did you do for 
Q. From, f 
of time that 
24 
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Page 594 
your money? 
A. On advice of counsel I'm invoking my Fifth 
Amendment rights under the United States Constitution. 
Q. In continuing in answering that particular 
imar.saici 
that in 2008 
worked at 
. Where is 
located? 
A. On advice of counsel I'm invoking my Fifth 
Amendment rights under the United States Constitution. 
Q. What did you do at 
A. On advice of counsel I'm invoking my Fifth 
Amendment rights under the United States Constitution. 
Q. Did you have any communication with 
Jeffrey Epstein after the phone call you made to him 
following the FBI's interview of you? 
A. I talked to ing Oh, my God. I don't know 
what I am going through. I'm like shaking. 
Q. I am talking about now a conversation with 
Mr. Epstein. 
MR. EDWARDS: The question was, did you 
talk to him after you called him — 
MR. LUTHER: Right 
MR. EDWARDS: — after the FBI statement? 
MR. LUTHER: Right. 
24 (Pages 591 to 594) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkIns 
Electronically signed by cynthia hopkIns 
Electronically signed by cynthia hopkIns 
b55421ef-d299-4e4f-9ba6-85aad27t4405 
EFTA01076182
Page 26 / 46
9 
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13. 
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21. 
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Page 595 
BY MR. LUTTIER: 
2 
Q. And the date of your FBI statement for 
3 
your information was April 241h, 2007. Did you have 
4 
any conversation with Jeffrey Epstein after that 
. 
5 
date? 
6 
A. After I, after I had called my attorney? 
7 
Q. After April 24th, '07, which is the date 
8 
that you gave a st 
FBI. 
A. I talked toatlisic) 
or whatever her 
name is. 
Q. Did you have any conversation with Jeffrey 
Epstein? 
A. No. I don't think so, no. 
Q. Other than the witnesses you have listed 
in answer to Interrogatory No. 5, do you know of any 
other witnesses or do you intend to call any 
witnesses in the trial of this matter? 
A. What? 
MR. EDWARDS: Objection. Attorney-client 
privilege. I don't want her answering 
questions as to whether, as to information that 
she and I have spoken about in terms of what 
witnesses will be called at trial or our trial 
strategy. 
Page 597 
1 
with Mr. =bout 
being a witness? That is what 
2 
would he be offering as testimony in the case? 
3 
A. What would he be offering? 
4 
Q. Yeah. Why did you ask him about being a 
5 
witness? 
6 
A. I didn't ask him about being a witness. I 
7 
.told him about what happened to me when 1 was 13 years 
8 
old. 
9 
Q. Okay. 
10 
A. I'm not asking anybody to be a witness as of 
11 
right now. 
12 
Q. What is -- 
• 
13 
A. I'm my own witness. 
14 
MR. EDWARDS: Listen to his question. 
15 
THE WITNESS: I am trying. I can't think 
16 
right now. 
17 
MR. EDWARDS: He wasn't asking you about 
18 
being a witness. 
19 
BY MIL WrrIER: 
20 
Q. Where does Mr. =live 
now? 
21 
A. West Palm Beach. 
• 
22 
Q. 
est Palm? 
23 
A. 
24 
Q. When did you last have communication with 
25 
him? 
Page 596 
1 
BY MR. LUTHER: 
2 
Q. Have you spoken to anyone with respect to 
3 
their willingness or your intention to call them as 
4 
a witness to the trial of this matter? 
5 
MR.. EDWARDS: Not who I have spoken to. 
6 
MR. LUTHER: Yeah, you. 
7 
THE WITNESS: What? 
8 
BY MR. LUTHER: 
9 
Q. Have you spoken to anybody about being a 
10 
witness • 
• 
is matter? 
11 
A. 
12 
Q. Anyone else? 
13 
A. Not that I know of. 
14 
Q. And when did you speak with Mr. 
15 
about being a witness? 
16 
A. May `09. 
17 
Q. And what is it you told him or asked him 
18 
about being a witness? 
19 
A. I told him that Jeffrey Epstein molested me 
20 
since I was 13 years old. 
21 
Q. Okay. And he wasn't around at the time 
22 
that you alleged Mr. Epstein molested you, correct? 
23 
A. He wasn't around at the time when Jeffrey 
24 
Epstein was molesting me. 
25 
. Okay. S
aS=
st
r w hat
did you confer 
Page 598 
1 
A. January 3rd, 2010. 
2 
Q. And for what purpose did you have 
3 
communication with him on that date? 
4 
A. I had to give him some of his clothes. 
5
Q. When was the last 
were in 
6 
tion with Mr. 
that would be 
7
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
PROSE COURT REPORTING 
A. lie's my son's father. So, I talked to him two 
weeks ago. 
Q. And where was he when you talked to him? 
A. Fort Myers. 
Q. And do you know how he's employed now? 
A. .No. He says he's not employed. 
Q. Have you discussed with him in the last 
year anything about this lawsuit? 
A. Yes. . 
Q. What have you discussed with him? 
A. I told him I'm going through a lawsuit. 
Q. And what did he say? 
A. He said okay. 
Q. Have you asked him to be a witness? 
A. No. 
Q. Have you 
' 
nication with any . 
other members of Mr, 
family in the last 
two years? 
25 (Pages 595 to 598) 
AGENCY, INC'. 
Electronically signed by cynthia hopkIns 
Electronically signed by 
Cynthia
hopkIns 
Electronically signed by Cynthia hapkins 
b55421ef-d2994e4t-9ba6-85aac12714405 
EFTA01076183
Page 27 / 46
Page 599 
1 
A. Yes. 
2 
Q. 
3 
AA. 
illi
nit
c).
4 
Q. Who is 
5 
A. His sister. 
6 
Q. And where does she live? 
7 
A. Wellington. 
8 
Q And for what purpose have you been in 
9 
touch with her? 
10 
A. She's my son's aunt 
11 
Q. And with what degree of frequency are you 
12 
in communication with her? 
13 
A. She asked me to attend her wedding via e-mail 
14 
this March of '010. 
15 
Q. Have you discussed with her anything about 
16 
Mr. Epstein? 
17 
A. No. 
18 
Q. Does she to the best of your knowledge 
H 
know anything about it? 
20 
A. Yes. 
21 
Q. Did you say no? 
22 
A. Yes. 
23 
Q. Does she know anything about? 
24 
A. Yes. 
25 
Q. What does she know about it? 
Page 601 
1 
Q. Is that the last time she's seen your son? 
2 
A. Approximately, yeah. 
3 
t 
Q. 
' 
ur son when you were 
4 
down a
m 8:00 at night until 
5 
in the 
6 
A. 
7 
Q. I 
8 
identified earlier? 
9 
A. Yeah. 
10 
Q. And where was she watching him? 
11 
A. At my house. 
12 
Q. So, does she come spend the night at your 
13 
house? 
14 
A. Yes. 
15 
d there, was there ever a time that you 
16 
and 1M lived together? 
17 
A. Yes. 
18 
Q. When was that? 
19 
A. When we were 13, 14. 
20 
Q. Thirteen and 14. Was any adult living 
21 
with you? 
22 
A. My father. 
23 
Q. Since you were 13 or 14 has a 
ever 
24 
lived with you? 
25 
ANo. 
1 
2 
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11. 
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SC, 
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Page 600 
1 
A. That Jeffrey Epstein's a child molester. 
2 
Q. And how did she get that information? 
3 
A. From the news, from friends, from the 
4 
neighbor/mod --
5 
Q. Did —
6 
A. From her brother. 
7 
Q. — has she asked you any questions about 
8 
your relationship or interaction with Mr. Epstein? 
A. She said I am sorry that you're going through 
the trauma that you're going through. 
other member of Mr. 
family? 
Q. Have you 
tmitation with any 
A His mother. 
Q. illy 
t's her name? 
A. 
Q. And where is she located? 
A. Fort Myers. 
Q. And when did you last have communication 
with her? 
A. I don't know. A year ago. 
Q. And for what purpose did you have 
communication with her at that time? 
A. Dropping my son off with her. 
ho you 
rather? 
4 
Page 602 
Q. Did you tell 
why you needed 
to have haisall 
night when you were 
down at 
A. Hold her I need to work. 
Q. Do you tell her what you do for work? 
A. Yes. 
Q. What did you tell her? 
A. I sell lingerie and shoes and purses and Mary 
Kay. 
Q. Do you have any personal knowledge of the 
matters about which the witnesses listed in your 
answers to interrogatories that these witnesses 
have, have information about? 
MR. EDWARDS: Objection, attorney-client 
privilege. And we do this all the time. 
BY MR. LUITIER: 
Q. This is just a list as prepared by your 
lawyer. You don't know what any one of these 
witnesses would say? 
MR. EDWARDS: And if she does, it's going 
to be information that I have talked to her 
about which you know is protected by 
attorney-client privilege and so do L 
If you're asking her independent of her 
information I have told her, fine. 
4. , ...••••••••••••4 
26 (Pages 599 to 602 
PROSE COURT REPORTING AGENCY, INC. 
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Page 603 
1 
MR. LUTTIER: That's exactly what I am 
2 
asking her. 
3 
MR. EDWARDS: Okay. Let's ask it that way 
4 
because it doesn't sound like that. 
5 
BY MR. LUTTIER: 
6 
Q. Do you know of any information that these 
7 
witnesses have based on your communications with 
8 
them? 
9 
A. Excuse me? 
10 
Q. Do you know any information that any of 
11 
these witnesses have about this case based on your 
12 
personal contact with them? 
13 
A. What witnesses? 
14 
Q. That are listed in the Answers to 
15 
Interrogatory 5. 
16 
MR. EDWARDS: Just answer his question, 
17 
yes or no. 
18 
THE WITNESS: No. I don't know these 
19 
people. 
20 
BY MR. LUTTIER: 
21 
Q. On any visit that you went to see Jeffrey 
22 
Epstein, did he ever ask you to do anything that you 
23 
said you did not want to do? 
24 
A. Yes. 
25 
Q. What did he ask you to do that you said 
Page 604 
1 
you didn't want to do? 
2 
k 
At one occasion he wanted to stick his lingers 
3 
like all the way inside of me and 1 said no? 
4 
Q. And what did he then do when you said no. 
5 
A. He said okay. So then he just penetrated my 
6 
vagina with his tinge's. 
7 
Q. What did he, did he —when you said you 
8 
didn't want him to do that, did he respect your 
9 
wishes and not do it? 
10 
A. No. Actually he, he pushed it. He tried to 
11 
do it and he said, okay, no, it's going to be okay. 
12 
It's going to be okay. And I backed off and I said no. 
13 
Q. And then he stopped? 
14 
A. Then he decided to respect my wishes. 
15 
Q. Okay. Any other — and this is on one 
16 
occasion? 
17 
A. Many occasions. 
16 
Q. Well, on — so on many occasions he would 
19 
say he wanted to penetrate your vagna. You would 
20 
say you didn't want — well, actually what you said 
21 
was he wanted to penetrate your vagina deeply I 
22 
think And, and you said no and he respected your 
23 
wishes and didn't do it? 
24 
A. Correct. 
2 5 
Q. Okay. Was there ever anything that at 
Page 605 
1 
all that you said I don't want to do this and Jeff 
2 
said you had to do it anyway? 
3 
A. Yeah. I told him that at times I did not want 
4 
to bring girls, and he says, yes, I want you to do it 
5 
anyway; you need to do it anyway. 
6 
Q. And did you tell all the girls that you 
7 
brought that Jeffrey would respect their wishes, and 
8 
if they were uncomfortable doing anything, that they 
9 
should just tell him that, and he wouldn't ask them 
10 
to do anything that they weren't comfortable doing? 
11 
A. Yes, because I was scared. 
12 
Q. And that's, in fact, how he treated you, 
13 
fir? 
14 
A. Yes. 
15 
Q. You previously earned a degree as an 
16 
esthetician; is that right? 
17 
A Yes. 
18 
Q. And you now earned a degree since going to 
19 
Mr. Epstein in massage therapy, correct? 
20 
A. Yes. 
21 
Q. And you emillairnom 
the same 
22 
school located on 
23 
A. Yes. 
24 
Q. And you could pursue a profession as an 
25 
esthetician, a massage therapist if you so chose, 
1 
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PROSE COURT REPORTING 
Page 606 
could you not? 
A. No, not as a massage therapist. 
Q. Why not? 
A. Because I've told you once before I need to 
take the nationals. 
Q. But no one has prevented you from taking 
test, right? 
A. I have to wait to take the test. It only 
happens twice a year. 
Q. And has — did you pass the first 
opportunity you had? 
A. No. 
Q. Okay. So, when's, when's the test coming 
up? 
A. In a few months. 
Q. And are you going to take it? 
A. Yes. 
Q. And you could have been working as an 
esthetician ever since you went to Jeffrey 
Epstein's? 
A. And I did work as an esthetician. 
Q. No one has prevented you from doing that, 
correct? 
A. No. 
9. You made the decision to drop out of 
27 (Pages 603 to 606) 
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Page 607 
school before you ever met Jeffrey Epstein, did you 
2 
not? 
A. I'm pretty sure I was going to school when I 
Was seeing Jeffrey Epstein. 
5 
Q. But, but you made the decision to drop out 
6 
based on other facts and circumstances that had 
7 
nothing to do with seeing Jeff Epstein; isn't that 
a 
correct? 
9 
A. Excuse me? 
10 
Q. You decided to drop out of school for your 
11 
own reasons particularly 1 think you said because 
12 
you got pregnant, didn't you? 
13 
A. No. 
14 
Q. Well, why did you decide to drop out of 
15 
school? 
16 
A. I was trying to find girls to bring to 
17 
Jeffrey's house. 
18 
Q. Well, didn't you tell us the last 
19 
deposition that you dropped out when you got 
20 
pregnant? 
21 
A. I was going to school when I was pregnant. 
22 
Q. Yeah. And then you dropped out, right? 
23 
A. I dropped out when I was 
pregnant. 
24 ass drop out of 
25 
and then go to 
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Page 609 
six. But then I did go back and I got my high school 
diploma, and like you said I have two degrees. 
Q. When did you get your, your GED? 
A. Yes. 
Q. When did you get that? 
A. What I turned 18. 
Al 
Q. So, you got a high school equivalency 
diploma at the same time you would have gotten a 
high school graduation certificate —
A. Correct. 
Q. -- had you stayed in school? 
A. Correct. 
Q. And then you were free to pursue the same 
pursuits as anybody else that had graduated from 
high school whether that would be college or a trade 
school or whatever you want to? 
A. No, no. If I would have stayed in school, I 
could have got some type of scholarship. I could have 
had many opportunities in school to learn higher 
education than just the GED. 
Q. Well, when you got —
A. And I could have — traveled and I could have 
went to a college, a bigger college, a state college. 
Page 608 
1 
A. Because ever since I met Jeffrey I— before 
2 
Jeffrey I made wonderful grades. And then ever since I 
3 
met Jeffrey my grades went down and I was failing, so I 
4 
had to go to a school to bring my grades a 
up. 
S 
1i. But you opted to drop out of the 
6 
MIE before you graduated? 
7 
A. Yes. I was four months pregnant 
8 
Q. And that's why you dropped out? 
9 
A. Well, I needed to make money to buy a house, a 
10 
trailer so I could have my baby. 
11 
Q. Because you were pregnant? 
12 
A. Yes. 
13 
Q. Had you not been pregnant, you would have 
14 
continued in school, correct? 
15 
A. I can't answer that question. I don't know. 
16 
Q. Well, the point is the direct reason why 
17 
you dropped out was you were pregnant? 
18 
A. And I was making so much money off of Jeffrey 
19 
that I didn't think school was so necessary at that 
20 
time. 
21 
Q. Did you consult with your parents or any 
22 
counselors about that? 
23 
A. I didn't tell my parents about Jeffrey. 
24 
Q. How much were you making at that time? 
2 5 
A. 1 WaSJnakilik $200 pretty much a day or 400 or 
Page 610 
1 
Q. How do you know that? 
2 
A. les common sense. 
3 
Q. Well, you don't know what your grades 
4 
would have been, right? 
5 
A. No, I don't know what my grades would have 
6 
been. 
7 
Q. And at — 
A. Do you know what tomorrow is grimy, bring? 
9 siAt 
the 
time 
that 
you 
went 
into 
the
 MI 
10 
you were qmillpally failing, weren't you? 
11 
A. Yeah, but 
they help girls, young girls 
12 
bring up their grades so you can go back into high 
13 
school and accomplish making more, bettering your grades 
14 
so you can get a scholarship. 
15 
Q. Well, in fact you got a scholarship for 
16 
your massage therapy, didn't you? 
17 
A. No. How could I? 
18 
Q. Did you tell us in the last deposition 
19 
that you got some kind of scholarship for going 
20 
there? 
21 
A. I didn't get a scholarship for going. No. 
22 
I've never got a scholarship. 
23 
Q. Did they lend you money to go to school 
24 
there? 
25 
A. For massage therapy but not for esthetics. 
28 (Pages 607 to 610) 
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) 
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) 
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Page 611 
Page 613 
1 
Q. That's what I was talking about was 
1 
2 
massage therapy. 
2 
3 
A. That's not a scholarship. 
3 
4 
Q. Okay. 
4 
5 
A. That's a loan that I have to still payback. 
5 
6 
Q. Did you ever travel anyplace with Jeffrey 
6 
7 
Epstein? 
7 
8 
A. Nope. 
8 
9 
Q. Are you — you're a person that uses the 
9 
10 
computer now, correct? 
10 
11 
A. Yep. 
11 
12 
Q. Did you ever communicate with Jeff Epstein 
12 
13 
on the computer? 
13 
14 
A. No not that I recall 
14 
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PROSE COURT REPORTING AGENCY, INC.
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Page 620 
1 
A. Yes. 
2 
Q. Do you know of -(phonetic)? 
2 
A. Yeah. 
4 
Q. Who is that? 
5 
A. Ifs actually my sister's son or daughter's 
6 
father's cousin. 
7 
Q. Sister's daughter? Your sister has a 
8 
daughter? 
9 
A. Yes. 
10 
Q. So 
daughter's cousin's father? 
11 
A. 
y's father, his cousin. 
12 
ii?kay. 
When did you first meet 
13 
14 
A. Probabl knew him since]. was 11. 
15 
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Page 621 
1 
BY MR. LUTHER: 
2 
Q. Did you she ever approach you about that? 
3 
A. No. 
4 
Q. Did she ever tell the police she was 
concerned about that? 
A. No. 
MR. EDWARDS: Object to the form. 
9 
10 
11 
MR. EDWARDS: Form, predicate. 
12 
MR. CRITTON: What's the form? 
13 
THE WITNESS: She was probably concerned. 
14 
MR. EDWARDS: You're asking -
15 
MR. LUTTIER: Was your mother -
16 
MR. EDWARDS: You're asking 
to tell 
17 
you whether she knows how her mother was 
18 
feeling at some certain time. 
19 
Y MR. LUTHER: 
20 
21 
22 
23 
MR. EDWARDS: Same objection. 
24 
THE WITNESS: She probably was concerned, 
25 
yet 
Page 622 
1 
LTIER: 
2 
3 
4 
5 
6 
7 
8 
Tr 
" 
. 
• i 
gcm, 
9 
predicate. 
10 
THE WITNESS: A mother's love. I don't 
11 
know. I can't speak for my mother. I am 
12 
sorry. 
13 
BY MR. LUTTIER: 
14 
Q. Were you doing something that gave her 
15 
that concern? 
16 
MR. EDWARDS: Object to the form, 
17 
speculation. 
18 
THE WITNESS: I don't know. 
19 
BY MR. LUTHER: 
20 
. Are a aware of the fact that your father 
21 
22 
uly of 
23 
'04? 
24 
A. Ile filed for what? 
25 
What's called 
a 
31 (Pages 619 to 622) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 623 
A. I never went to any program or anything. 
Q Yeah, but do you know he filed a petition 
in the court claiming that you come home when you 
want to, you're in trouble with the police, and that 
Did you 
know he filed that in July of'04? 
A. No. 
Q. You didn't know that? 
A. (Witness shakes head.) 
Q.
 you, in fact, taking 
in July of'04? 
A. Yes. I apologized to my father. 
Q. So, he had a legitimate concern at that 
time? 
MR. EDWARDS: Form. 
THE WITNESS: Yes. 
BY MR. LUTTIER: 
And with what degree were you taking 
at that time? 
A. I was a confused little girl with Jeffrey 
Epstein and that always, leaving Jeffrey Epstein's house 
always lead me to do more drugs and more drugs. I was 
uncomfortable about my body. 
Page 624 
Q. What were you — 
A. I didn't like the way Jeffrey made me feel. 
Q. What were you uncomfortable about your 
body about? 
A. I felt insulted. I felt used. 
Q. Did you tell him that? 
A. No. 
Q. Did you tell anybody that? 
A. Yeah. 
Q. Who did you tell? 
A. a 
Q. On the, on the way over to Jeffrey 
Epstein's when you were taking her there? 
A. Yeah. We would tell each other that we didn't 
like the way we felt. 
Q. Did tu file a complaint that your 
boyfriend 
was stalking you? 
A. Yes. 
Q. Was be, in fact, stalking you? 
A. He got -- he was on coke one day, and I was 
scared because he was trying to get in the house and I 
didn't want nothing to do with him. 
Q. Did that give you some concern? 
A. Excuse me? 
Q. Did that give you concern? 
1. 
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Page 625 
A. Concern? 
Q. Yeah. I mean were you afraid? 
A. Only for that one night that he was on coke. 
He was just trying to, like, get in my house and I 
didn't want him in there. 
Q. D#
o ou know a lady by the name of 
* 
A. Ob, my. I know herii.r 
Q. How do you know 
Q. Who is 
A. A friaamine. 
Q. Where did ou meet 
? 
A 'Through 
yfriend. 
Q. And wbos 
boyfriend? 
MR. EDW 
: 
you 
ve a question, 
Bob? 
MR. CRITTON: He was telling me to ask her 
what n's -- 
IvfirEDWARDS: Oh, sony --
MR. LUIT1ER: -- full name is. We'll get 
to that. 
MR. EDWARDS: Okay. 
THE WITNESS: I don't — oh, God, I don't 
remember his name but they were both no good. 
Page 626 
1 
They were like gang members. 
2 
BY MR. LLITTIER: 
3 
Q. That is 
7 
+ 
4 
A. No, 
and her boyfriend. 
5 
Q. Okay. 
you don't remember the 
6 
boyfriends's name? How did you — what was your 
7 
relationship with 
B 
A. AssociatePPIII, 
in a while. 
9 
Q. When did you first meet her? 
10 
A. In — I don't know. Maybe when I was 14. 
11 
Q. Did she live in your neighborhood? 
12 
A. No. 
13 
Q. How did you meet her? 
14 
A. I'm not sure. 
15 
Q. Was she a friend? 
16 
A. She became an associate. 
17 
Q. Is there a difference between an associate 
18 
and a friend? 
19 
A. Yeah. A friend is someone who's always by 
20 
your side and who you can talk to daily, and an 
23. 
associate is just someone you can, that you know. 
22 
Q. Did you socialize with her? 
23 
A. Yeah. 
24 
Q. What kinds of things did you do with her? 
25 
A. Not good things. 
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PROSE COURT REPORTING AGENCY, INC. 
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Page 627 
Q. And this was during the time that you were 
seeing Mr. Epstein? 
A. Yeah. 
Q. What else did you and she do together? 
A. Nothing. 
Q. Did you-all live together at some point? 
A. I asked her to -- she asked me if she could 
room with me when I was living in my trailer and 1 gave 
her a chance. About a week later 1 found out that she 
was not the kind of friend for me at all and she was 
into no good things. And I have a son so I couldn't 
have her around. 
Q. What do you mean she was into no good 
things? 
A. She was into drugs and stealing and --
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Page 629 
A. Yeah. 
Q. And she threatened to kill you? 
A. Yeah, she threatened a lot of stuff. 
Q. And did you believe she had the capacity 
to do that? 
A. No. 
Q. What gang was she in? 
A. y(phonetic). 
Q. 
did you know her to be a violent 
person? 
A. Yeah. But she's like 80-pounds soaking wet so 
Tut not worried about her. She's just lost and God 
bless her soul. 
Q. Now, let's talk about Mr., is it =or 
a
(phonetic)? 
Q. "And 
you have described earlier a 
confrontation that you had with him. And was his 
mother present for that confrontation? 
A. Yes. 
Q. And, and did it initially start out that 
Mr.thr 
was physically abusive towards his 
mo 
A. Yes. I had told him to leave and his mother 
came to pick up his daughter from my house. When she 
Page 628 
1 
Q. Did you and she have a physical 
2 
confrontation? 
3 
A. She brought --1 told her when she moved in 
4 
for that one week I told her do not bring anyone into 
5 
this house. She brought a man into my house. I opened 
6 
her bedroom door, found her giving him oral sex. I got 
7 
angry. I said, please leave. She was on drugs. 
8 
She got angrier and came into the bathroom 
9 
and hit me or tried to hit me on my head. So, I 
10 
pretty much held her down until the cops came 
11 
because 1 called the cops to get her out. 
12 
Q. Was it an upsetting event to you? 
13 
A. No. I just couldn't wait for her to get out. 
14 
Q. Was that a common thing for you to have 
5 
fistfights with other women? 
16 
A. No. I didn't throw a fist. No, it was not a 
17 
common thing. 
18 
Q. And did she threaten you on the way out? 
19 
A. Yes. 
20 
Q. And you said she was in a gang? 
21 
A. Yeah. 
22 
Q. And what did she tell you on the way out? 
23 
' A. O6,1 don't remember. I'm going to regret it. 
24 
Q. Well, did she say, I am going to get you, 
25 
bitch? 
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Page 630 
arrived, he started pushing and shoving his mother into 
the car. I could tell that he was on drugs. So, I said 
this is uncalled, uncalled for. I called the cops and 
that was that. He ran. I guess you can say 1 have a 
good heart and I give the wrong people chances. 
Q. Well, that was one incident when, when the 
mother was present, right? 
A. Yes, and that night actually --
Q. There was a second incident, was there 
not? 
A. Yes. That night he — that's when he pushed 
me down a couple times and that's when I hit him and 
then he spit blood all over the house. And that's when 
immediately moved out of the house and moved to 
D, DCF got involved. So, 1, three days later, 
And the next thing I know the week that 1 move
. wed 
at m house. 
33 (Pages 627 to 630 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkins 
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Page 634 
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A. Yes. 
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MR. LUITTER: Let's mark this as our next, 
3 
whatever number we're on. 
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THE COURT REPORTER: Five. 
5 
MR. LUTTIER: Five. 
6 
(Defendants Exhibit No. 5 was marked for 
7 
identification) 
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BY MR. LUTTIER: 
9 
Q. Let me show you what is now marked as 
10 
Exhibit 5 and ask ou if that's a co 
of the 
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Electronically signed by cynthia hopkins 
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PROSE COURT REPORTING AGENCY, INC. 
Page 637 
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MR. LUTT1ER: Let me mark that as 6, our 
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next. And ask you if you can identify this 
12 
document. 
13 
(Defendants Exhibit No. 6 was marked for 
14 
identification.) 
15 
THE WITNESS: I've had some crazy 
16 
boyfriends, but for three years everything's 
17 
been fine. 
18 
BY MR. LUTHER: 
19 
Q. Let a show ou what has been marked as 
20 
Exhibit 6. 
21 
22 
A. 
tat a outa. 
23 
MR. EDWARDS: lie was just showing it to 
24 
you. 
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THE WITNESS: Yes, I saw it before. 
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Page 639 
MR. LUTTIER: I need to take a quick 
break. 
THE VIDEOGRAPHER: Going off the record at 
4:19 p.m. 
(A brief recess was held.) 
THE VIDEOGRAPHER: We're back on the 
record at 4.30 p.m. 
BY MR. LUTTIER: 
Q. Do you actually, yourself, call 
Mr. Epstein's home asking him if you could come 
work, did you not? 
MR. EDWARDS: Object to the form, 
predicate, time-frame. 
Page 641 
3. 
A. No. 
2 
Q. Do you know if any of them have consulted 
3 
with any lawyers about that other than your lawyers? 
4 
A. No. What they want to sue me along with 
S 
Jeffrey? 
6 
Q. Have you ever discussed yourself with them 
7 
their feelings about you having taken them to see 
8 
Mr. Epstein? 
9 
A. Yeah. 
10 
Q. ./that did they tell you? 
11 
A. 
is very sensitive towards it. She 
12 
didn't like it at all. She just was a poor little girl 
13 
that I guess was influenced by me to go to Jeffrey's 
14 
house. 
15 
Q. But I mean has she ever asked you why did 
16 
you do that knowing what you knew or anything like 
17 
that or said she holds you responsible? 
18 
A. In
 'don't 'mow the exact words but 
19 
she's definitely came to me and said why would you even 
20 
do that, why would we go there? You know, it, it hurts 
21 
our self-esteem. 
22 
And in M.'s aspect she was extremely 
23 
scared to go the first time. And me being one of 
24 
her best friends at the time, she just finally wont 
25 
after I begged her many times when I couldn't fmd 
Page 640 
1 
BY MR. WITIER: 
Q. During this period of time that you were 
3 
going to see Mr. Epstein. Sometimes you called and 
4 
asked his people at his house whether, you know, you 
5 
could come work, did you not? 
6 
A. Yeah. Because he told me to call if I had a 
7 
girl. SO, I would call and ask is he available. 
8 
Q. Now, I want to askot
couple questions 
9 
about your ttke friends, 
and again M. 
10 
A. Excuse me. 
11 
Q. You took 
to Mr. Epstein, did you 
12 
not? 
13 
A. Yes, I did. 
14 
Q. How many times did you take her? 
15 
A. I dolifiv. 
16 
Q. Has 
or III. or anyone else that 
17 
you took to Mr. Epstein discussed with you or anyone 
18 
else that you know of the potential for them suing 
19 
you? 
20 
A. Who suing me? 
21 
Q. My girl that you took to Mr. Epstein. 
22 
A. No. 
• 
23 
Q. Do you know if any of them talked to their 
24 
lawyers about suing you as a result of you taking 
25 
them to see Mr. Epstein? 
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ti 4006......146.44.114
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Page 642 
any other girl. And no, they both didn't like it. 
Who would like it? 
Q. Did you have any friends better then M, 
You know, would you consider her, she was your best 
friend, or is your best friend? 
A. At that time, no. 
Q. Who is your best friend now? 
A. 
Q. .How about now? 
A. My son. 
Q. Okay. Other than your son, a friend not 
family. is she, is she your best friend still? 
A. Jesus, myself, my son. Why are you looking at 
me crazy? 
Q. Is she your best friend was the question. 
A. I don't have a best friend. Actually, yes, l 
do. 
Q. Who? 
A. 
Q. Who is she? 
A. 
Q. Is she another person that is suing Jeff 
Epstein? 
A. Nope. She was affiliated with 
who died. 
36 (Pages 639 to 642) 
PROSE COURT REPORTING AGENCY, INC. 
Electronically signed by cynthia hopkIns 
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Page 645 
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Q Wbala? 
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A. Yeah. 
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'allow 
was she affiliated with
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A. She was good friends with ha and I met 
through her. And If took 
to Jeffiey Epstein's house. 
Q. Where does 
live? 
A. Rhode Island. 
Q. Do you have the phone number for this 
babysitter you say you use? 
A. Yes. 
Q. 
A. Yes. 
Q. What's her number? 
A. I don't know it off the top of my head. 
Q. Is she listed in the phone book? 
A. Probably. 
Q. Is she — you say she lives in the 
Acreage? 
A. Yes. 
Q. Is she married? 
A. No. 
Q. Have you ever been to her house? 
A. Yeah. 
1 
times you actually went? 
2 
MR. EDWARDS: Form. 
3 
THE WITNESS: What does that mean? 
4 
MR. EDWARDS: Answer if you know what that 
5 
means. Do you have physical proof, videotape. 
6 
Answer his question if you know what the answer 
7 
is.. 
THE WITNESS: No. No one videotaped me 
9 
and no, we didn't keep a log, no. 
10 
BY MR. LUTIIER: 
11 
Q. There is no record that you could consult 
12 
that would say I !mow I went 21 times or exactly how 
13 
many times because you kept a record of it? 
14 
MR. EDWARDS: Font 
15 
THE WITNESS: No. 
16 
MR. EDWARDS: This is outside of whatever 
17 
records are in your client's possession. 
18 
BY MR. LUTTIER: 
19 
Q. And since you and ed.. 
are 
20 
all represented by the same lawyer, do you recognize 
21 
that there is an inherent conflict amonathree 
22 
in terms of any accusations that M. and 
23 
would have against you for taking them to 
24 
Mr. Epstein? 
25 
MR. EDWARDS: Object to the form. 
Page 644 
Q. Does she rent, does she own, do you know? 
A. No. 
Q. Live alone or with somebody else? 
A. Her brother. 
Q. Same last name -- 
A. I don't know. 
as her and her brother, last name is 
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BY MR- LUTTIER: 
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Q. And you have no physical proof of how many 25 
A. I don't know. 
• 
THE VIDEOGRAPHER: Your Sc is on your 
chair. 
BY MR. WITTER: 
Q. Now, you've told us when you believe you 
first went to Jeffrey Epstein and when you went the 
last time. If I 
and I may have asked you at the 
last deposition: You have no physical proof of when 
you actually went, right, the actual dates that you 
went? 
MR. EDWARDS: Object to the form. 
MR. LUTTIER: That would be like a 
calendar or notes, something like that. 
MR. EDWARDS: Form. 
THE WITNESS: Nope. 
PROSE COURT REPORTING 
Page 646 
THE WITNESS: I don't understand what the 
hell — 
BY MR. LUTTER: 
Q. There is a conflict of interest. 
Mr. Edwards can't represent one, one client suing 
another one of his clients; you recognize that, 
don't you? 
MR. EDWARDS: Form. 
THE WITNESS: Okay. 
BY MR. LU1TIER: 
Q. Have you seen 
deposition? 
A. No. 
Q. Have you been told anything about it? 
A. No. 
O. Have you been told anything about 
case . 
A. No. 
Q. Who is actually representing you now? Do 
you know the name of the law firm that now 
represents you? 
A. Whatever this law firm's called. 
Q. Is it — did you sign a new fee agreement 
with the new law firm? 
A. Yes. 
Q. So, it's whatever firm IMINIM  is now 
37 (Pages 643 to 646) 
AGENCY, INC. 
Electronically signed by cynthia hopkins 
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Page 647 
with? 
A. Yes. 
Q. 
meet any of the people 
from the 
A. No. 
' 
any investigators from the 
A. No. 
Q. Have you ever been interviewed by any of 
the investigators from there? 
A. No. 
ar
Do you know a man by the name of II 
A. No. 
Q. Ha 
v heard of his name? 
A. 
Q-
A. No. 
Q. Do you have this babysitter's phone number 
in your cellphone? 
A. No. I don't keep it in my cellphone. 
Q. You, you don't keep your babysitters 
number in your cellphone? 
A. No. 
Q. And you don't have it memorized? 
Page 648 
1 
A. No. 
2 
Q. So, what do you have to do when you want 
3 
to call a babysitter? 
4 
A. Ifs at home. 
5 
Q. So, if you're out and about and you need 
6 
to call the babysitter and tell her you'll be 
7 
A. I usually keep it in my purse. 
8 
Q. — there late you don't have any way to do 
9 
that until you get home? 
10 
A. I usually keep it in my purse and I am not 
11 
late. 
12 
Q. Where do you keep it? Do you have a phone 
13 
book in your purse? 
14 
A. No. I have a piece of paper with her number. 
15 
Q. Okay. Do you have that with you here 
16 
today? 
17 
A. No. 
18 
Q. So, as you sit here todq=illo not have 
19 
on your person anywhere Ms. 
phone number, 
20 
is that right? 
21 
A. I do not have her number with me, no. 
22 
Q Do you know somebody by the name of ■ 
23 
(phonetic)? 
24 
A. No. What time is it? 
25 
Q. 4:41. 
Page 649 
1 
A. Okay. I have to pick my son up by 6 so —
2 
MR. EDWARDS: Well be done. 
3 
BY MR. LUTHER: 
4 
Q. At the beginning of this deposition you 
5 
asked a question about whether or not somebody else 
6 
was going to be here I think on behalf of you. And 
7 
you made some reference to somebody you had met with 
8 
about this deposition. Do you recall making that 
9 
statement, asking whether or not this other person 
10 
was going to be here? 
1 
A. Uhhuh, yes. 
12 
Q. Who were you referring to? 
13 
A. His name is I don't know his name. 
14 
Q. Is it a lawyer? 
15 
A. Hp's an attorney. 
16 
Q. Not a paralegal. A guy named Fanner, 
17 
Mr. Farmer? 
18 
A. I daft know. 
19. 
Q. Have you net this other person? 
20 
A. Yes. 
21 
Q. Where did you meet this other person? 
22 
A. At the law firm. 
23 
Q. Mr. Edward's law firm? 
24 
A. Yes. 
25 
Q. Down in Fort Lauderdale? 
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Page 650 
A. Yes. 
Q. So, you've been down to his new law firm? 
A. Yes. 
Q. Did you review anything in preparation for 
today's deposition? 
A. Yesterday I talked to my attorney. 
Q. Did you review any documents? 
A. I reviewed a document, yes. 
Q. What document? 
A. I don't know. I don't know what document, 
sir. Sorry. 
Q. You say you reviewed a document or 
documents? 
A. I reviewed a document. 
Q. One piece of paper? 
A. A few, a few pieces of paper. 
Q. Okay. What were they? What did they have 
on them? 
MR. EDWARDS: Objection as to this line of 
questioning calls for attorney-client privilege 
information. She's not going it answer it as 
to exactly what we went over in preparation for 
the deposition. 
BY MR. LUTTIER: 
. Other than notes created by our lawyer
ewe 
38 (Pages 647 to 650) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 651 
which I don't want to know about, did you review any 
other documents in preparation for your deposition? 
A. No. I have to be out of here at 5:30. 
Q. Did you ever hear anything about how your 
case may have been involved in any of that? 
A. No. It's irrelevant to me right now. 
Q. Does that mean you have never heard 
Page 653 
1 
in the garbage. 
2 
Q. Well, at the time we took your deposition 
3 
in September, you told us under oath that it was at 
4 
your home. Did you do something with it since --
5 
A. No. 
6 
Q. — your deposition on 
7 
A. No. 
8 
Q. Well, it just didn't disappear, did it? 
9 
MR. EDWARDS: Form. 
10 
THE WITNESS: No. Are you being sarcastic 
11 
with me? 
12 
BY MR. LUTHER: 
13 
Q. No. I mean you had to do something with 
14 
it, right? 
15 
MR. EDWARDS: Form. 
16 
THE WITNESS: I didn't touch it. I can't 
17 
find it. I don't know where it is. It's not 
18 
in the house, so, song. 
19 
BY MR. LUTTIER: 
20 
Q. Well, where did you think it was when you 
21 
testified definitively that it was in your home? 
22 
A. I thought it was in a couple of my papers that 
23 
I have and it's not. I thought it was where my Social 
24 
Security card was. It's not them, sir. End of 
25 
dismission. 
Page 652 
1 
anything or you just disregarded what you heard? 
2 
A. I disregarded what I heard. 
3 
Q. So, what did you hear? 
4 
MR. EDWARDS: You're asking her though 
5 
what she heard outside of any conversation with 
6 
me obviously? 
7 
MR. LUTHER: Yeah, oh, yeah. I don't 
8 
want you to tell me, I don't want you to ever 
9 
tell me anything your lawyer told you. 
10 
THE WITNESS: Oh, no, I didn't hear 
11 
nothing. 
12 
BY MR. LUTTIER: 
13 
Q. Okay. Now, in your previous deposition 
14 
you indicated that you had a book. I think you said 
15 
it had a red — it was a red book. !don't remember 
16 
if the color was right and you said it had a Bible 
17 
verse on it. Do you remember that testimony? 
18 
A. Yes. 
19 
Q. And at that deposition you told us 
20 
definitively that you had that at your home? 
21 
A. Yes. 
22 
Q. Where is that book now? 
23 
A. I can't find it. It's nowhere to be found. 
24 
Q. Well, what did you do with it? 
25 
A. I don't know. I moved a lot so it's rehab! 
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Page 654 
Q. Do you know the names of any of your 
clients that you had when you were working — other 
than the ones you've aheady identified here, 
clients you had when you were working for any of the 
escort services? 
A. No. Why would they want me to know their 
names? I don't want to know their names either. 
Q. I have no idea. 
A. They have wives. 
Q. All your clients have wives? 
A. Probably. We don't — it's not about 
relationships, man. It's about — 
Q. When you were wmtirag for those — 
A 
— mo 
and out. 
MR. EDWARDS: Form. 
MR. LUTTIER: Right? 
MR. EDWARDS: Fonn. 
BY MR. LUTTIER: 
39 (Pages 651 to 654 
PROSE COURT REPORTING AGENCY,. INC. 
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