EFTA01107798

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-CIV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
Related cases: 
08-80232, 08-08380, 08-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80591, 09-80656, 09-80802, 09-81092, 
DEPOSITION OF JANE DOE #7 - VOLUME I 
(videotaped) 
Monday, March 15, 2010 
10:02 - 6:49 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Rachel W. Bridge, RMR, CRR 
Notary Public, State of Florida 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
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APPEARANCES: 
On behalf of the Plaintiffs in related eases 
Not 08-80069, 08-80119,08-80232, 08-80380, 
W40181,0IWW993,011-80994: 
ADAM D. HOROWITZ, ESQUIRE 
MERMELSTETN & HOROWITZ, P.A. 
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18205 Biscayne Boulevard 
Suite 2218 
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Miami, Florida 33160 
Telephone: 305/931-2200 
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On behalf of the Defendant Jeffrey Epstein: 
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ROBERT D. CRITION. JR., ESQUIRE 
BURMAN, CIUTFON, LUTHER & COLEMAN 
10 
393 Banyan Boulevard 
Suite 400 
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West Palm Beach, Florida 33401 
Telephone: 561/842-2820 
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Also Present: Sasha Quimby. videographer 
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PROCEEDINGS 
Deposition taken before Rachel W. Bridge, 
Certified Realtime Reporter and Notary Public in and for 
the State of Florida at Large, in the above cause. 
THE VIDEOGRAPHER: This is the 15th day of 
March, 2010. The time is 10:02 a.m. 
This is the videotape deposition of lane Doe 
#7 in the matter of' Jane Doe number two versus 
Epstein. This deposition is being held at 250 
Australian Avenue South, West Palm Beach, Florida. 
My name is Sasha Quimby. Pm the videographer 
representing Visual Evidence, Inc. 
Would the attorneys please announce their 
appearances for the record. 
MR. HOROWITZ: Sure. My name is Adam 
Horowitz, counsel for the witness, plaintiff. 
MR. CARTON: Bob Critton for Jeffrey Epstein. 
Thereupon, 
(JANE DOE #7) 
having been first duly sworn a affirmed, was examined 
and testified as follows: 
THE WITNESS: I do. 
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INDEX 
WITNESS: 
DIRECT CROSS REDIRECT RECROSS 
Jane Doe 47 
By Mr. Critton 
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EXHIBITS 
EXHIBIT 
Defendant's 1 
Defendant's 2 
Defendant's 3 
Defendant's 4 
Defendant's 5 
Defendant's 6 
Defendant's 7 
Defendant's 8 
Defendant's 9 
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DIRECT EXAMINATION 
BY MR. CRITTON: 
Q. Please tell me your hill name. 
A. lane Doe 7. 
Q. Where do you live, ma'am? 
A. I live in Orlando. 
Q. I understand that Where, give me your 
address, 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
now. 
Q. 
A. 
Page 5 
Is that apartment or a home? 
It's an apartment,M. 
And with whom do you live at that apartment? 
I have a roommate 
What's 
I think it's 
How long has 
your mommate? 
She's been my roommate for about four months 
The last name? 
Have you ever given a deposition before? 
No, l have not. 
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Q. I'm confident that Mr. Horowitz, your 
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attorney, has told you about the procedure. I get to 
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ask you a lot of questions and he may have some 
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questions at the end. You understand that? 
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A. Uh huh. 
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Q. Yes? 
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A. Yes. 
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Q. You need to answer out loud, yes, nos, l don't 
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know, I don't recall, whatever your answer is. Do you 
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understand that as well? 
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A. Yes. 
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Q. Okay. If I ask you a question that you don't 
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understand, ask me to either to rephrase it or to repeat 
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it rll be happy to do that, all right? 
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A. Uh huh 
yes. 
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Q. All right. If you answer a question, I'm 
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going to assume that you've understood it and answered 
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it truthfully. Fair? 
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A. Yes. 
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Q. All right. Any time you want to take a break, 
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let us know. Pm okay with that unless you're in the 
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middle of a question or I'm in a series of questions 
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then I'll probably balk at it, but other than that, just 
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let us know. 
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You understand you are under oath today? 
Page 
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A. I guess I wasn't under oath for that. 
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Q. Do you understand the distinction between 
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being under oath and not under oath? Is that a yes? 
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A. Yes. 
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Q. Okay. What's the distinction to you? 
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A. That you have to tell the full truth. 
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Q. Okay, all right. 
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A. Actually I don't know, because I, I don't 
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remember being under oath for the medical examiner, so 
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maybe -
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Q. So you had a medical exam by whom? 
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A. By Dr. Kilman and your medical examiner. I 
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forget his name. 
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Q. Okay. When did you see my medical examiner? 
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How long ago? 
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A. About two weeks ago. 
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Q. And you spent how long with him? 
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A. About five hours. 
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Q. And he took the history, background 
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information from you as well as you did testing, 
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correct? 
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A. Yes. 
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Q. And that was two weeks ago, but you don't 
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remember his name? 
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A. No. 
Page 7 
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A. Yes. 
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Q. And you understood when you are put under 
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oath, whether by a court reporter at a deposition or if 
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at a trial if this case goes to trial or by a police 
officer, you are required to tell the truth? 
A. Yes. 
Q. If you don't tell the truth, you may be 
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committing a crime, committing the crime of perjury. 
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Do you understand that? 
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MR. HOROWITZ: Form. 
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THE WITNESS: Yes. 
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BY MR. CRITTON: 
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Q. I'm sorry? 
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A. Yes. 
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Q. You've been put under oath before, true? 
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A. Yes. 
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Q. Okay. And you understand that you were sworn 
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to tell the truth? 
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A. Yes. 
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Q. Okay. On how many occasions have you been put 
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under oath where you have given testimony about 
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anything? 
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A. I believe I was under oath at — was that when 
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the medical examiner's, I guess it was —
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Q. Medical examiner, who was that? 
Page 9 
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Q. And you called — the evaluator or the person 
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who did the examination at your attomey's request for 
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you in this case is Dr. who? 
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A. Kilman. 
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Q. Kilman, all right. How do you think you spell 
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that? 
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A. 
I'm guessing. 
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Q. All right. Since the time you had — and I'll 
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represent to you his real name is Kliman. 
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A. Kliman, 
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Q. That's all right. Since you did your 
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examination with him in December of '08, it wa. 
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December 5th of '08, have you had any contact with him 
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whatsoever, him being Dr. Kliman? 
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A. No, I have not. 
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Q. So with both Dr. Kliman and Dr. Hall, you 
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weren't under oath, correct, as you understand it? 
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A. No, I guess not. 
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Q. I'm sorry? 
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A. No, I guess no. 
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Q. Well, did you tell him the truth? Did you 
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tell both of than the truth? 
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A. Yes. 
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Q. All right. So even though you weren't under 
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oath, so there may not be a penalty of perjury 
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associated with it if you lied, it's Your testimony that 
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you told both Dr. ICIhnan and Dr. Hall the truth? 
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A. Yes. 
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Q. Okay. And during the examination that was 
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done by Dr. Hall, did you feel that you had enough time 
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to take breaks, that you had an opportunity to fully 
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explore all of the issues that you wanted to discuss 
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with him? 
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A. Yes. 
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Q All right. Did you think he was fair with you 
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and treated you with respect during the course of the 
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interview? 
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A. Yes, I did. 
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Q. Now I think you told me you've never given a 
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deposition before like we're doing here today? 
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A. Yes. 
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Q. That's correct? 
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A. Yes. 
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Q. And you've never testified in cowl, true? 
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A. Yes. 
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Q Do you understand that if in fact this case is 
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not resolved at some point, that you will be testifying 
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in court and people will know that you are lane Doe 7 in 
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court? 
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A. Yes. 
Page 12 
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of scared, because Mcalled me and left a voicemail 
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on my phone asking about the cops. And I just like 
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didn't know what was going on. So no, I didn't tell 
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them everything that happened. 
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Q. Okay. 
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A. And my parents were there. 
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Q. Let me move to strike as nonresponsive. 
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But let me get back to you lied to the police 
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officers when they took a, from the Town of Palm 
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Beach — strike that 
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It's your testimony now even though you know 
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that you could be penalized or that you could be found 
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guilty of perjury, it didn't bother you at all to lie to 
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police officers when they put you tinder oath back in 
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October of 2005; is that correct? 
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MR. HOROWITZ: Object to form and asked and 
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answered. 
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THE WITNESS: Yes. 
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BY MR. CRITION: 
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Q. Okay. I71 ask you to assume that the police 
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officers interviewed you from the Town of Palm Beach on 
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October 4th of 2005, all right? 
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A. 1.1h huh. 
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Q. Yes? 
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A. Yes. 
Page 11 
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Q. Okay. And you may no longer be Jane Doe, and 
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whether it's a newspaper or anyone who wants to do a 
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story about this case, your name may well become public; 
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do you understand that? 
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MR. HOROWITZ: Foam 
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THE WITNESS: Yes. 
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BY MR. CRITTON: 
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Q. Affright. Now at some point did you give 
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a — you met with police officers; is that correct, 
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associated with the Town of Palm Beach? 
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A. Yes. 
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Q. And did they take a statement from you? 
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A. Yes, they did. 
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Q. And I asswne you told — the police officers 
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put you under oath as well, you swore to tell the whole 
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truth, nothing but the truth, so help you God? They put 
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you under oath? 
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A. Yes. 
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Q. And you told than the truth as well, correct? 
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A. I didn't tell them the complete truth. 
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Q. You lied to the police officers; is that what 
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you're saying? 
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A. Yes. I was scared and I was about 18, and I 
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was confused. They just showed up at my house with no 
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warning, and I was just kind of in shock and I was kind 
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Q. Okay. Have you read anything through today's 
date that suggests to you that you lied to the police 
officers? That is, what have you seen that makes you 
remember that you lied to the police officers? 
A. I just remember from my own memory what I told 
than, that I didn't tell them everything that went on. 
Q. Well, you keep saying I didn't tell them 
everything. In essence, you lied to the police 
officers, correct? 
MR. HOROWITZ: Firm. That's the third time 
you asked the question. 
MR. CRITTON: Well, but she keeps changing the 
answer, so —
MR. HOROWITZ: No, no, no. 
MR. CR1TTON: You can object to the form. 
MR. HOROWITZ: Bob, you are harassing her. 
MR. CRITTON: Fm not harassing her. She 
keeps saying I didn't tell them the whole thing. 
There is a distinction between a lie and not 
telling the truth. 
MR. HOROWITZ: She said —
MR. CRITTON: I understand what she's trying 
to say. 
MR. HOROWITZ: She answered your question. 
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BY MR. CRITTON: 
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Q. Back to my question, ma'am. On October 4 of 
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2005 when the police officers came to interview you and 
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you did not tell them the truth, or from your 
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perspective the complete truth, you say you were only 18 
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at the time. 
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A. I was younger and I was confused. And my 
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parents were there and they showed up without me having 
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any knowledge that they were going to be there besides a 
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telephone call I got from my parents. 
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And I showed up and I was scared. I was 
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scared I was going to get in trouble. I was scared what 
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my parents would think. I was upset. I mean a lot of 
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things were going on then. 
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Q. Okay. You were scared what your — and 
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confused as to what your parents would think, but, but 
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you weren't too scared to not tell the police officers 
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the truth, correct? 
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A. I guess you could say that, yes. 
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Q. How else would you describe it? 
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A. Just how I did. 
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Q. All right. Okay. You were 18 at the time. 
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YOU were an adult, right? 
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A. Uh huh. 
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Q. Yes? 
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A. Uhhttb. 
Q. Yes? 
A. Yes, that's correct. 
Q. And you said — so how long did it take you to 
get home? 
A. I was about five minutes away from my house. 
Q. All tight. Did you tell your parents don't 
want to talk to them, I'm scared and confined, maybe 
even in shock and I'm only 18, so tell them not to come? 
MR. HOROWITZ: Fain. 
THE WITNESS: I didn't say that at all. I 
was, I had no idea what it was about, so I had no 
idea it was about the whole Jeffrey Epstein thing. 
BY MR. CRITTON: 
Q. Well, had anybody called you and told you 
anything about Jeffrey Epstein or that the police were 
interviewing individuals related to Jeffrey Epstein? 
MR. HOROWITZ: Form. 
THE WITNESS: No, besides 
left a 
voicemail, but it was I think when I already got 
there, she left a voicemail saying about, asking if 
I had, if the cops were at my place and I was 
talking to them and if I was going to ask them any 
questions. She just left me a voicemail, so — 
Page 15 
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A. Yes. 
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Q. And you were 18? 
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MR. HOROWITZ: Form. 
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THE WITNESS: Yes. 
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BY MR. CRITTON: 
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Q. In 2005. Were you in
 at the time? 
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A. I believe went to 
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is where? 
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A. It's in Orlando. 
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Q. So you were in college at the time, correct? 
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A. Yes. 
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Q. The police officers called your home? 
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A. Yes. 
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Q. And —
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A. Well, they didn't call my home. They just 
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showed up there and my parents called me saying that 
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there were two police officers there waiting for me. 
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Q. And so you must have been home from school at 
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that time? 
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A. Yes, I was. I was on break. 
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Q. You were on break. So you had, at least your 
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parents called you and said there's two police officers 
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here from the Town of Palm Beach? 
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A. Yes. 
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Q. And they want to talk to you? 
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BY MR. CRITTON: 
Q. What about Jane Doe 4, hadn't you talked to 
Jane Doe 4, because she had been interviewed by the 
police officers, hadn't she? 
A. I don't think she was imerviewed before me. 
Q. You think your interview preceded or was 
before hoe Doe 4? 
MR. HOROWITZ: Form. 
THE WITNESS: I can't remember exactly, but I 
think so, yes. 
BY MR. CRITTON: 
Q. So you show up, you are 18, you are an adult. 
You can choose to either talk to the police or not, 
correct? 
A. Uh huh. 
Q. Yes? 
A. Yes. 
MR. HOROWITZ: Form 
BY MR. CRITTON: 
Q. All right. The confusion from your 
perspective was you didn't know why the police were 
there? 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. Right? 
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A. Yes. 
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Q. All right. You may have been scared 
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originally, why are the police at my home? 
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A. (Witness nods head up and down.) 
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Q. All right, I understand that. So you come 
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in. There are two police officers. Males, or one male, 
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one female? 
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A. There are two males. 
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Q. They introduce themselves? 
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A. Yes. 
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Q. And what did they say they wanted to talk —
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let me strike that. 
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Did you speak to the two officers together or 
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were your parents right there with you? 
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A. My parents were there when they were there and 
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I was there. 
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Q. So did you all sit down in the living room? 
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A. We sat down outside and they said they wanted 
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to talk to me. I don't exactly remember what they said, 
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but they said something about Jeffrey. And that's when 
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I asked my mom if she could go inside the house. And 
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that's when I talked to them. 
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Q. How about your dad, was he there too? 
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A. He wasn't there at the house. He was at work. 
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Q. I thought you said both your parents was 
Page 20 
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police officers? 
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Why did that not make sense to you, ma'am? 
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MR. HOROWITZ: Penn. 
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THE WITNESS: Because I did not want to hurt 
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my mom and let her find out about everything that 
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happened with Jeffrey. I don't think that's fair 
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to her to hear that from a cop without me telling 
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her first. 
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BY MR. CRITTON: 
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Q. Okay. Well, but you were confused, scared -
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and in shock. So don't most young adults who have good 
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relationships with their parents, isn't that one of the 
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first people you would want to talk to is either your 
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mother or father, have them both around? 
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MR. HOROWITZ: Object to the form. 
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THE WITNESS: No, that would be the last, I 
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wouldn't want her to find out anything until I had 
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time to sit down with her and tell her. I wouldn't 
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want to have her there while cops were 
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interrogating me. 
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BY MR. CRITTON: 
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Q. So you knew that the cops were going to 
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interrogate you — I'm using your word — right? 
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A. Yes. I'm sure they were going to ask me 
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questions about Jeffrey and what happened. 
Page 19 
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there. So it was only your mom that was there? 
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A. Well, he came home later. 
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Q. I understand that, but you left the impression 
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with me earlier that your dad was there and your mom 
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were diem, they were waiting there with the police 
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officers. That's not correct? 
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MR. HOROWITZ: Faint. 
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THE WITNESS: Well, my mom was there and then 
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my dad carne home later, so I guess --
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BY MR. CRTITON: 
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Q. When the police officers were still there? 
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A. Yes. 
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Q. So mom, the four of you sit down outside, the 
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police officers say rd like to talk to you about 
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Jeffrey Epstein, you asked your mom to go inside? 
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A. Uh huh. 
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Q. Yes? 
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A. Yes. 
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Q. You certainly have the presence of mind to say 
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'Mom, go inside"? 
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A. Yes. 
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Q. Why, if you are 18, only 38, as you describe 
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it, you are confused, you are scared and you are in 
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shock, why wouldn't you keep someone who is very close 
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to you, your mother, there before you talked to the 
Page 21 
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Q. So therefore, you certainly had the presence 
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of mind to say, after you knew why the police were 
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there, the four of you were standing or sitting outside 
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and you said, "Mom, go inside," because you wanted to be 
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able to talk --
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A. Well, actually — 
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Q. Can I finish my question, please? 
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You wanted to be able to move Mom to a 
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different section of the house so you could talk to the 
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police officers, find out what they wanted, and then 
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think about what ultimately you would tell your mom; 
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fair statement? 
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MR. HOROWITZ: Form, compound. 
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THE WITNESS: Yes, and also the cops asked her 
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to go inside too. They, they were actually the 
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ones that recommended it. And then I asked her, I 
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said, "Yes, Mom, could you go inside?" 
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BY MR. CRITTON: 
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Q. But you could have said "No, l wain my mom 
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here"? 
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A. I didn't want her there. 
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Q. I understand you didn't, but you could have 
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said 'I want my mother here"? 
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A. Of course I could have. 
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Q. All right. But again, you had the presence of 
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mind to determine whether or not you wanted your mother 
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to stay or not stay, correct? 
3 
MR. HOROWITZ: Form. 
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THE WITNESS: Yes. 
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BY MR. CRITTON: 
Q. Let me tell you one other thing. From time to 
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time 111 ask questions and I may not be done. If I'm 
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not done with the question, I'm going to tell you, 
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because not to be rude to you, but to be certain you 
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understand my full question, right? So that you can 
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hear the full thing. 
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If I chop you off in an answer, just let me 
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know. Say, "Critton, I'm not done with my answer," and 
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then Ill let you finish your answer, okay? So that way 
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I make certain that I hear your response as well. 
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A. Okay. 
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Q. Okay. So did you tell the police officers 
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after you had presence of mind to send your mom into the 
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house, say took, l don't really vault to talk to you 
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about this, I'd like to be able to talk to my parents 
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first and then HI talk to you later"? 
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A. I kind of wanted to know what was going on, 
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and they made it sound like I needed to talk to them or 
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I would get in trouble if I didn't talk to them. 
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Q. Why would you get in trouble? 
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not? 
2 
A. Yes, 
3 
Q. Where police officers want to cone and talk to 
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a particular witness, maybe a suspect in the crime, 
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sometimes they talk, sometimes they don't? 
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You know that, we've all seen "Law and Order" 
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and those series. You have seen them too, haven't you? 
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MR. HOROWITZ: Form. 
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THE WITNESS: Yes. 
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BY MR. CRITTON: 
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Q. Anyhow, you make a conscious decision to say 
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okay, I'm going to sit down and talk with the police 
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officers and find out what they want to ask me, right? 
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A. Yes. 
15 
Q. How long were they there? 
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A. They were there for about an hour and a half, 
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two hours. I really don't remember. 
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Q. Did they have a tape recorder with them? 
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A. I believe so. 
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Q. Did they talk to you — during the entire time 
21 
they talked to you, did they have the tape recorder on? 
22 
MR. HOROWITZ: Form. 
23 
THE WITNESS: I don't remember. 
24 
BY MR. CRITTON: 
25 
Q. Did they have it on fora portion of the 
Page 23 
A. Because -
2 
MR. HOROWITZ: Form. 
3 
THE WITNESS: -- they are the cops, and I was 
4 
young, I didn't know. 
5 
BY MR. CRITTON: 
6 
Q. You were 18. You were an adult 
7 
MR. HOROWITZ: Form. 
8 
BY MR. CRITTON: 
9 
Q. MIS? 
10 
A. Yeah, if you can — yes. 
11 
Q. All right. And other times that you were 
12 
either confined or scared, you had called your parents 
13 
and said "Hey, look, I have this particular problem or I 
14 
don't have this — or I have this particular problem, 
15 
what should I do?" 
16 
You have done that with your parents before? 
17 
A. Yes. 
18 
Q. All right. Anyhow, so you decide to sit down 
19 
and talk with police officers. You made that decision? 
20 
MR. HOROWITZ: Form. 
21 
BY MR. CRITTON: 
22 
Q. Correct? 
23 
A. Well, it was kind of like I felt like I had 
24 
to. They were at my house. I didn't know any better. 
25 
Q. Sure. You have seen TV shows before, had you 
Page 25 
1 
interview? 
2 
A. Yes. 
3 
Q. And where you raised your right hand and you 
4 
were sworn to tell the truth? 
5 
A. Yes. 
6 
Q. And they asked you a bunch of questions? 
7 
A. Yes. 
8 
Q. And if I understand your testimony, it's --
9 
your position is you didn't lie to them, you just didn't 
10 
tell them everything: is that correct? 
11 
MR. HOROWITZ: FWD. 
12 
THE WITNESS: I admitted that I lied and I 
13 
didn't tell the whole truth, but I did not tell 
14 
them everything that happened. I just told them 
15 
some of what happened. 
16 
BY MR. CRITTON: 
17 
Q. Have you ever looked at the police report or 
18 
any probable cause affidavit or police report in 
19 
preparation for your deposition today? 
20 
A. Their police report? 
21 
Q. Have you seen any portions of the police 
22 
report that related to the interview relating to you? 
23 
A. No, I don't think so. 
24 
Q. Have you looked at anything in preparation for 
25 
your deposition today? 
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A. I just read over the Kilman 
Kliman, 
sony — 
Q. Kliman what? 
A. When I had an interview with him. 
Q. You mean his questions, your answers, or his 
summary of what you said? 
MR HOROWITZ: Form. 
THE WITNESS: Just his questions and my 
answers. 
BY MR. CRITTON: 
Q. Did you read over your interrogatories, your 
answers to the interrogatories? 
A. Yes. 
Q. Okay. When did you do that? 
A. Actually, l did it right before I came in here 
just to kind of rejog my memory. 
Q. That's fine. Did you look at anything else? 
A. No. 
Q. Have you read anybody else's deposition who 
gave a deposition in this case? 
A. I haven't read anybody else's deposition. 
Q. Have you talked to anyone? You have certainly 
talked to Jane Doe 4. She is one of your best friends, 
right? 
A. Yes, I talked to her. 
Page 28 
1 
Q. Let me get back to the police here. 
2 
So the police sit and they interview you for 
3 
an hour and a half to two hours, and during that, not 
4 
only the sworn part of the testimony out of your 
S 
statement, but as well you're saying that you lied to 
6 
them during part of, part of what you've said, both 
7 
sworn and unsworn, and as well you didn't provide them 
8 
all the information, right? 
9 
A. Yes. 
10 
Q. Now, you filed your lawsuit in this case 
11 
against Mr. Epstein and you are seeking, at least your 
12 
lawyers are asking in part of the complaint for 
13 
$50 million. Are you aware of that? 
14 
A. No, my lawyers take care of all that. 
15 
Q. All right. Let me show you I'll mark as 
16 
Exhibit 1. 
17 
(The document was marked Defendant's 
18 
Exhibit I for identification.) 
19 
BY MR. CRITTON: 
20 
Q. Exhibit 1 is the amended complaint that you 
21 
filed, that your lawyers — it's the second complaint 
22 
that actually was filed in this action. The original 
23 
complaint was filed on September 10th of '08, all right? 
24 
A. I.Jh huh. 
25 
Q. Yes? 
Page 27 
1 
Q. And from my recollection of Jane Doe 4's 
2 
deposition is you guys talk almost every day? 
3 
MR. HOROWITZ: I'm sorry, are we talking about 
4 
in preparation for her depo? 
5 
MR. CRITTON: Just asking a question. 
6 
MR. HOROWITZ: You are moving off topic. 
7 
THE WITNESS: We don't talk every day, no, but 
8 
we do talk a lot. 
9 
BY MR. CRITTON: 
10 
Q. Four, five, six times a week? 
11 
A. I wouldn't say that much. 
12 
Q. How often do you still talk? 
13 
A. I talked to her recently when I was in town, 
14 
but when I'm in Orlando I don't talk to her every week. 
15 
Q. So if I got your phone records, I might find 
16 
that there are weeks or two weeks at a time that neither 
17 
one of you are speaking with anyone — with each other, 
18 
I'm sorry. 
19 
A. Yes. 
20 
Q. All right. Are you aware that Jane Doe 4 gave 
21 
a deposition in this case? 
22 
A. Yes. 
23 
Q. And you have talked to her about her 
24 
deposition, haven't you? 
25 
A. Yes. 
Page 29 
A. Yes. 
2 
Q. All right. So between the time that the 
3 
lawsuit was filed on September -- let me strike that —
4 
that you gave a statement to the police officers under 
5 
which you, about which you've admitted you did not tell 
6 
the truth on October 4,2005, up until three years 
7 
later — almost three years later, September 10th of 
8 
'08, did you recontact the police and tell the police 
9 
that you had not told them the truth? In fact, you had 
10 
lied to them and withheld information? 
11 
A. 1 told the FBI that when they came up to visit 
12 
me in Orlando. 
13 
Q. That wasn't my question. 
14 
MR. HOROWITZ: Form. 
15 
BY MR. CRITTON: 
16 
Q. My question was did you talk to the Palm Beach 
17 
police department —
18 
A. 'never talked to them after that. 
19 
Q. I need to finish the question. 
20 
A. I'm sorry. 
21 
Q. -- from the time that you first spoke with 
22 
them on October 4th of 2005 up until the time that the 
23 
complaint was filed, that is, to bring this lawsuit 
24 
seeking damages in excess of $50 million against 
25 
Mr. Epstein, did you ever call or recontact the Palm 
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Beach Police Department and tell them what happened in 
2 
tams of your interview; that is, that you didn't tell 
3 
them the truth, you lied to than? 
4 
MR. HOROWITZ: Object to the form. 
5 
THE WITNESS: No. 
BY MR. CRITTON: 
Q. Why not? 
3 
A. Well, because they never called me back to ask 
9 
me any more questions and I tried to move on fran 
10 
everything. I was in school. I was trying to, I was 
11 
scared about everything that was going on with the media 
12 
and all my friends, and I didn't want to say anything 
13 
until I knew exactly what was going on and it was safe 
14 
for me to say everything and I wasn't going to get in 
15 
trouble. 
16 
Q. Well, why would you think you would get in 
17 
trouble? I mean if you didn't hesitate to lie to the 
18 
Palm Beach Police Department, what trouble did you think 
19 
you were going to get in? 
20 
MR. HOROWITZ: Form. 
21 
THE WITNESS: I had no idea. I just, I didn't 
22 
really know at the time. I was just scared. 
23 
BY MR. CRITTON: 
24 
Q. Well, you knew that perjury was a crime back 
25 
then, didn't you? 
Page 32 
1 
to lie to the police officers, were you? 
2 
MR. HOROWITZ: Fenn. 
3 
THE WITNESS; Actually, I was scared and 
4 
confused. That is why I lied to them. 
5 
BY MR. CRITTON: 
6 
Q. All right. So what were you scared and 
7 
confused about? 
8 
A. I was scared because I knew what happened with 
9 
Jeffrey and I knew that was wrong and I, I knew that he 
10 
was possibly going to get in trouble, and I didn't know 
11 
if I was going to get in trouble for going there for 
12 
what happened. 
13 
So I mean I was mainly scared about that. I 
14 
was scared about my parents finding out. Just 
15 
everything going on with what happened, I was scared 
16 
about and confused about. 
17 
Q. Okay. When was the last time you were at 
18 
Mr. Epstein's home, that you claim you were at 
19 
Mr. Epstein's home? 
20 
A. I'm pretty sure it was the end of my junior 
21 
year of high school. 
22 
Q. Which would have been what? 
23 
A. It would have been 2004, I believe. 
24 
Q. Okay. And that was the last time you were 
25 
there, so it would have been what, approximately May of 
Page 31 
1 
MR. HOROWITZ: Form. 
7 
BY MR. CRITTON: 
Q. To lie to a police officer under oath? 
A 
Yes. I also knew what Jeffrey did was a 
crime, but I mean —
6 
Q. I'm not talking about Jeffrey. Go ahead, 
7 
finish your answer. 
8 
Again, I'm interested in specific answers to 
9 
questions, and I'm going to have to move to strike and 
10 
re-ask you the question. So I know that you may have 
11 
some things that you want to add on. Your lawyer can 
12 
certainly come back and cover that, but if you can focus 
13 
on my question, this goes a lot faster, but you can 
14 
answer anything the way you want. 
15 
My question is with regard to the police 
16 
officers, you knew, you knew that telling them a lie was 
17 
a crime, correct? 
18 
MR. HOROWITZ: Form Object to the form. 
19 
This is the third time you've asked the question, 
20 
at least. 
21 
THE WITNESS: Yeah, I already told you. 
22 
BY MR. CRITTON: 
23 
Q. Yes? 
24 
A. Yes. 
25 
Q. Okay. So you weren't too scared or confused 
(561) 832-7500 
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2004? 
2 
A. T don't remember exact dates, but I just 
3 
believe it was the end of my junior year, so probably 
4 
around May or June. 
5 
Q. 2004? 
6 
A. Yes 
7 
Q. Not 2005? 
8 
A. I don't believe I went in 2005 
9 
Q. When did you graduate from la 
10 
A. 2005. 
11 
Q. All right So the end of your —so your 
12 
senior year would have been approximately August of '04 
13 
through May of '05? 
14 
A. Yes. 
15 
Q. So where your Exhibit I, the complaint alleges 
16 
that you first went to Mr. Epstein's home when you were 
17 
16 years old and you continued to go over a period of 
18 
one and a half to two years, that's false; is that 
19 
correct? 
20 
MB. HOROWITZ: Form. 
21 
THE WITNESS: I believe so. 
22 
BY MR. CRITTON: 
23 
Q. I'm sorry? 
24 
A. I believe so. 
25 
Q. So over what period of time, when do you think 
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you first went to Mr. Epstein's home? 
2 
A. I believe I went the end of my sophomore year 
3 
611 about the end of my junior year. Fm not sure if 
4 
it was the beginning or the end of my sophomore year. 
5 
Somewhere around there. 
6 
Q. Well, you told the police that you were 
7 
approximately 17 when you first went to Mr. Epstein's 
8 
home, didn't you? 
9 
A. I don't exactly remember what, when I said 
10 
that, I first told them I went. 
11 
Q. If I asked you to assume that the police 
12 
report reflects that the statement that you gave to 
13 
them, that you were there when you wore 17 years old, 
14 
all right? 
15 
A. Okay. 
16 
Q. I 
old and you were born in, 
17 
let's see,Milir
so it would have been 
18 
approximately June, the end of June of 2004, correct, 
19 
that you first went there? 
20 
MR. HOROWITZ: Form. 
21 
THE WITNESS: I, I don't exactly know, to be 
22 
honest with you. 
23 
BY MR. CRITTON: 
24 
Q. You mean when you first went to Mr. Epstein's? 
25 
A. I can't put a date on it. I just remember it 
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Page 36 
BY MR. CRITION: 
Q. -- to the police officers? 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. Whether you were scared or confused at that 
time, you probably would have given them at least your 
accurate age when you first went to Mr. Epstein's? 
MR. HOROWITZ: Form. 
THE WITNESS: I may have said it because I was 
scared and I didn't want to them to think I 
actually went that long, or I don't know why I said 
it. I honestly don't know. 
BY MR. CRITTON: 
Q. And maybe it was the truth at the time? 
MR HOROWITZ: Form. 
THE WITNESS: I mean I really don't know. 
BY MR. CRITTON: 
Q. So it may have been the truth, it may not have 
been the truth; even today you don't know, correct, 
whether you were 17 when you first went to 
Mr. Epstein's? 
A. I believe I was 16, because I believe it was 
the end of my sophomore year. So I at least think I was 
16. 
Q. So you are meeting with two police officers 
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Page 35 
was my sophomore year to my junior year. 
Q. When you gave a statement to the police on 
October 4,2005, whether you were 16 or 17, what 
difference would it have made to the police officers? 
Why would being scared or confused, why would you Ile 
about your age when you first went to Mr. Epstein's? 
MR. HOROWITZ: Form. 
THE WITNESS: I don't know. 
BY MR. CRITTON: 
Q. Maybe in fact — 
A. I mean I did go when l was 17 too, so I may 
have just said 17,1 don't really know. 
Q. Well, you were 18 — again, would you agree 
with me that your recollection of the events involving 
Mr. Epstein would have been better in October of '05 
than it is at the current time? 
MR. HOROWITZ: Fenn. 
THE WITNESS: Yes. 
BY MR. CRITTON: 
Q. And if you told the police officers you were 
17 when you first went to Mr. Epstein's home, would you 
agree with me that that, there would have been no reason 
for you to lie about your age at that time —
MR HOROWITZ: Form. 
Page 37 
1 
from the Town of Palm Beach in basically a secure 
2 
environment, nothing can happen to you there. You told 
3 
them that you were 17 years old when you first went to 
4 
Mr. Epstein's. 
5 
Now that you arc seeking $50 million in a 
6 
lawsuit that was filed on September 10 of '08, now all 
7 
of a sudden maybe you were 16? Is that your testimony? 
8 
MR. HOROWITZ: Let me object to form. You are 
9 
mischaracterizing the testimony. 
10 
BY MR. CRITTON: 
11 
Q. You can go ahead and answer, ma'am. 
12 
A. Well, I told you that I didn't tell them the 
13 
complete truth. So what would it matter if I told them 
14 
I was 17 or 16, when I already told you I didn't tell 
15 
them the complete truth and I didn't tell them 
16 
everything that happened? 
17 
Q. Well, again, my point is merely is —
18 
A. I understand. 
19 
Q. I want you to confirm that you didn't even 
20 
tell them the correct age, or at least your position is 
21 
you may have lied to the police officers even about the 
22 
age when you first went to Mr. Epstein's house? 
23 
A. I believe the only reason 1 would have lied 
24 
about my age, because I was scared and I didn't want 
25 
them obviously when I was 16 to think that I went there 
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as well as 17 and if I didn't really want to be involved 
2 
in it, so maybe that's why I said I was 17. I don't 
3 
remember that far back what I was thinking. 
4 
Q. Okay. I understand that. But in fact it 
5 
could have been true that the first time you went to 
6 
Mr. Epstein's house you were 17 years old, correct? 
7 
MR. HOROWITZ: Form. 
8 
THE WITNESS: No, I remember going around the 
9 
end of my sophomore year. 
10 
BY MR. CR1TTON: 
11 
Q. Give me your best exact date when you first 
12 
went to Mr. Epstein's home. 
13 
A. I remembere. was in my gym class and she 
14 
asked me to go, and Fm almost positive that was my 
15 
towards the end of my sophomore year. She was in my gym 
16 
class. 
17 
Q. That takes you now to your sophomore year? 
18 
A. Yes. 
19 
Q. Okay. 
20 
A. Yet 
21 
Q. Which would have been when? 
22 
A. When I was 16. 
23 
Q. You were a senior -- lees just get the dates 
24 
right You were senior as of August of 'OS — I'm 
25 
sorry, of '04, correct? 
Page 40 
1 
Q. So now your testimony is, also under oath, is 
2 
we started maybe it was in your junior year. You told 
3 
the police it was when you were 17, which would have put 
4 
k in your senior year or just before the start of your 
5 
senior year in 2005. 
6 
And now your testimony is it may have been in 
7 
your sophomore year, is that correct? 
8 
A. I'm not trying to lie or mislead you. 1 
9 
honestly can't remember if it was my sophomore or my 
10 
junior year 1 wasn't going by age or anything. I just 
11 
could not remember what year I started going. 
12 
Q. All right. At least for todays deposition 
13 
under oath, tell me what your position is as to when you 
14 
went to Mr. Epstein's home. Now I've got senior year, 
15 
junior or sophomore year, so my question --
16 
A. It wasn't my senior year. I don't believe I 
17 
remember going my senior year, so I'm pretty sure it was 
18 
my sophomore year and then into my junior year. 
19 
Q. All right. Give me an approximate time. If 
20 
you are now claiming it's in your sophomore year, give 
21 
me an approximate date when'. first approached you. 
22 
A. I believe It was towards the end of my 
23 
sophomore year. 
24 
Q. We're talking about April, May? 
25 
A. The end. I really don't -- I can't answer 
Page 33 
1 
A. Yes. 
2 
Q. And as of August of '04, you would have been 
3 
17 years old as a senior; is that correct? 
4 
A. Yes. 
5 
Q. Okay. So as a junior, you would have been 16 
6 
years old and you would have started in August of '03 to 
7 
'04, right? 
8 
A. Yes. 
9 
Q. If '05, 04-05 is your senior year and you were 
10 
17 during your whole senior year, is that correct? 
11 
A. Yes. 
12 
Q. All right. So you would have been 16 during 
13 
your entire junior year? 
14 
A. Uh huh. 
15 
Q. Yes? 
16 
A. Yes. 
17 
Q. Okay. But you just said. asked you to go 
18 
to Mr. Epstein's house now when you were in your 
19 
sophomore year. 
20 
A. Yes. 
21 
Q. Okay. So you would have been 15 then? 
22 
A. I guess so. I wasn't really going by age. I 
23 
was just trying to remember when she was in my gym 
24 
class, and I can't remember if it was my sophomore or my 
25 
junior year. 
Page 41 
1 
you, because I don't want to tell you something that 
2 
I — !just believe it was towards the end of my 
3 
sophomore year. 
4 
Q. If you look at Exhibit 1, paragraph nine says, 
5 
the last sentence says, "In or about 2004 Jane Doe"-
6 
which is you, Jane Doe 7 — am I saying that right, Jane 
7 
Doe 7? 
8 
A. Yes. 
9 
Q. "then approximately I6 years old, fell into 
10 
Epstein's trap." 
11 
Okay, you see that? 
12 
A. Uh huh. 
13 
Q. So at least the lawsuit that was filed 
14 
initially, your amended complaint that was filed on 
15 
September -- Fm sorry, February 27 of '09, it alleges 
16 
sometime in 2004, right? Which would have had to have 
17 
been after your sophomore year, but into your junior 
18 
year, correct? 
19 
A. Yes. 
20 
Q. So you are saying now that that complaint is 
21 
wrong? At least based on what you're claiming to be the 
22 
truth today; is that right? 
23 
A. I told you 'couldn't remember correctly if it 
24 
was my sophomore or my junior year when she was in my 
25 
gym class, so — 
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Q. So now you are saying it realty could be the 
junior year? 
A. I really, I really don't know. I can't 
remember. I just icutemlmr her being in my gym class 
asking me to go. 
Q. So maybe it's '03, maybe its '04, maybe it's 
'05, you are just not sure? 
MR. HOROWITZ: Form. 
THE WITNESS: Ifs not '05. It was either 
2003, I'm pretty sure it was 2003 — or 2002 or 
2003 through 2004. it wasn't 2005 at all. 
BY MR. CRITTON: 
Q All right. Let me show you what I'll mark as 
Exhibit 2. 
(The doe-meta was marked Defendant's Exhibit 
2 for identification.) 
MR. CRiTTON: Here's extra copy for you. 
MR. HOROWITZ: Okay. 
BY MR. CRITTON: 
Q. These are interrogatory answers that you 
signed on January 23, 2008. Do you see that? 
A. Yes. 
Q. Would you go to the second, go to the 
second-to-last page. 
MR. HOROWITZ: What, is there a question? 
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Page 44 
these interrogatories and you understood that, true? 
A. Uh huh, yes. 
Q. All right. And it says, the question is "List 
all dates you allege you were at Mr. Epstein's home in 
Florida. Include the date, time arrived and left, the 
name of anyone else who went with you to the home, when 
you were there, the time spent with Mr. Epstein, and the 
names and addresses of individuals who were present in 
the house with Mr. Epstein and you." 
Okay. And why don't you read for the ladies 
and gentlemen of the jury what your answer was, at least 
the first part of the answer. 
A. "Plaintiff went to the defendant's estate 
approximately eight to ten times during her junior and 
senior years of high school, from 2004 to 2005." 
Q. All right. So you already told us that you 
lied to the police about certain aspects of your 
statement. Are you now telling us that on January 23rd 
of 2009 when you answered these interrogatories you were 
again lying about the dates you were at Mr. Epstein's 
home? 
MR. HOROWITZ: Form. 
THE WITNESS: I wasn't lying at all. I, I 
told you before i don't exactly remember the exact 
dates. 
2 
Page 43 
1 
MR. CRITTON: Yes, go to the last page, 
2 
second to last page. 
3 
BY MR. CRITTON: 
4 
Q. The
 is a signature there that says 
go to 
5 
the second-to-last page, please, ma'am. These are 
6 
plaintiff Jane Doe 7's, Ms. Jane Doc 7's answers to 
7 
first set or first interrogatories, correct? 
8 
A. Yes. 
9 
Q. All right. And you see there is a 
10 
verification that says Jane Doe 7, "being duly sworn, 
11 
deposes and says that the foregoing answers to 
12 
interrogatories are true and correct to the best of her 
13 
knowledge, information and belief." 
14 
That's your signature, is it not? 
15 
A. Yes. 
16 
Q. It reflects "Sworn and subscribed to the 23rd 
17 
day of January 20(18." in fact, I think it's 2009, based 
18 
upon the certificate page, because you didn't have a 
19 
lawsuit as of January of 2008. So I'm sure it was that 
20 
same January issue that a lot of people have, so let's 
21 
assume, we'll agree that it was January 23, 2009, 
22 
correct? 
23 
A. Yes. 
24 
Q. All tight. So then if you go to Question 
25 
No. 15, again you're under oath again and swearing to 
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1 
BY MR. CRITTON: 
2 
Q Well, you're giving this information --
3 
A. I know I went my junior year. I don't 
4 
remember if it started my sophomore — i think it ended 
5 
my senior. I just, Pm telling the truth. I don't know 
6 
exact dates. It's hard for me to remember. 
7 
Q. Do you even know what my question was? 
8 
A. Yes, 1 did. 
9 
Q. You IM me ask one word and then you just 
10 
started talking. 
11 
A. I'm sorry, you are just trying to make me out 
12 
to look like a liar when I told you I don't remember 
13 
exact dates. 
14 
Q. I'll make it very clear. I'm not trying to 
15 
make you out as anything, all right? The record is 
16 
going to speak for itself whether you are telling the 
17 
bulb or not. Somebody else can judge that. That's not 
18 
my job. 
19 
All I'm saying is at least in your answers to 
20 
interrogatories, and I assume you completed these in 
21 
conjunction with your attorneys, right? You had t:..: 
22 
opportunity to sit with your attorneys? 
23 
A. Yes. 
24 
Q. lo fact, you sat with Jessica Arbour at the 
25 
time, who is now an attorney with Mermelstein & 
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Horowitz, correct? 
2 
A. Uh huh. 
3 
Q. Yes? 
4 
A. Yes. 
Q. And you understood in answering these 
6 
questions that you were to answer them to the best of 
7 
your ability. because you would be sworn that they were 
8 
truthful, correct? 
9 
A. Yes. 
10 
Q. All right So now we've got 
see if we can 
11 
sort through this. 
12 
Under oath, you told the police officers you 
13 
were 17 when you came to Mr. Epstein's, which would have 
14 
had to have been in .04, that is after lune 30th of 
15 
2004, which would have put you after completion of your 
16 
junior year and into your senior year, right? That's at 
17 
least what you told the police? 
18 
A. Yes, 
19 
Q. In your answers to interrogatories you say you 
20 
went to Mr. Epstein's home 2004 and 2005, during both 
21 
your junior and senior years, correct? 
22 
A. Yes. 
23 
Q. And you've told us under oath here today that 
24 
you may have gone to Mr. Epstein's when you were 15 as a 
25 
sophomore, you may have gone when you were 16 as a 
1 
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Page 48 
THE WITNESS: Can you read that one more time, 
please? Sorry. 
(A portion of the record was read by the 
Mom•) 
THE WITNESS: I definitely went when I was a 
junior. I wasn't sure if I went when I was a 
sophomore, so yes. 
BY PAR. CRITTON: 
Q. So now you were a junior. At least what 
you're saying today, separate and apart from what you 
told the police officer, separate and apart flan what 
you put in your answers to interrogatories, separate and 
apart from what you have previously testified today, 
it's now your testimony under oath again that you went 
sometime in your junior year, which would have been 
what, in '04? 
A. Yes. 
Q. And your best recollection as to when you went 
would have been when? 
MR. HOROWITZ: Which visit are you talking 
about? 
MR. CANTON: First went to Mr. Epstein. 
MR. HOROWITZ: First went. 
THE WITNESS: First was with 
Page 47 
1 
junior, but you don't know? 
2 
A I think I put this because —
3 
Q. No, I'm not asking why you put that. 
4 
My question to you is that's what you've told 
5 
us at least today? 
6 
MR. HOROWITZ: Form. 
7 
THE WITNESS: I put this because I was sure 
8 
that I went my junior year. 1 didn't remember if I 
9 
went my senior year and I didn't remember if I went 
10 
my sophomore year at all. Maybe towards the end, 
11 
lice I told you earlier. 
12 
But I definitely remember going my Junior 
13 
year. So that's maybe why 1 left out the sophomore 
14 
year. I don't remember if I went my sophomore 
15 
year. I'm not saying that 1 did. 1 don't 
16 
remember. 
17 
MR. CRITTON: Let me move to strike as 
18 
nonresponsive. 
19 
Would you read the question back to her, 
20 
please. 
21 
(A portion of the record was read by the 
22 
reporter.) 
23 
BY MR. CRITTON: 
24 
Q. Is that correct? 
25 
MR. HOROWITZ: Fonn. 
Page 49 
1 
BY MR. CRITTON: 
2 
Q. I understand that's your testimony. Datewise, 
3 
sometime in April or May of 2004? 
4 
MR. HOROWITZ: No, she said end of her 
5 
sophomore is her best-
6 
MR. CRMON: No, she just said junior. Well, 
7 
wait a minute, let's clear it up, Mr. Horowitz. 
8 
Lets go back and read it. 
9 
(A portion of the record was read by the 
10 
reporter.) 
11 
MR. HOROWITZ: Right You are talking about 
12 
the first visit there. You we talking about —
13 
MR. CRITTON: No, I'm talking about the first 
14 
visit 
15 
MR. HOROWITZ: Okay. 
16 
MR. CRITTON: She said junior year and then 
17 
you said no, sophomore. 
18 
MR. HOROWITZ: No, but the question wasn't 
19 
about — I'm not testifying. 
20 
MR. CRITTON: I'll clear it up again. 
21 
MR. HOROWITZ; Please clear it up. 
22 
MR. CRITTON: Because she's all over the 
23 
world. She can give us Ifice 40 years here. 
24 
BY MR. CRITTON: 
25 
Q. My question to you is is it your position that 
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1. 
you first went to Mr. Epstein's home in the latter part 
2 
of your junior year, which would have been sometime 
3 
April, May of 2004? 
4 
A. When I first went there? 
5 
Q. Yes, ma'am. 
6 
A. No. 
7 
Q. Okay, what is it now? 
8 
MR. HOROWITZ: Form. 
9 
THE WITNESS: Wby did you try to trick me like 
10 
that when I told you —
11 
BY MR. CRITTON: 
12 
Q. fin not trying to trick you. You have said 
13 
about 19 different things. I'm going to ask a clean 
14 
question so maybe we can get a clean answer from you 
15 
here. 
16 
My question to you is what is your position as 
17 
to when you first went to Mr. Epstein's home? 
18 
A. My position is I believe it was towards the 
19 
end of my sophomore year or the beginning of my junior 
20 
year. I don't really remember the exact dates. 
21 
Q. If it was the end of your sophomore year, that 
22 
would have put it sometime in 2003, right? 
23 
A. Yes. 
24 
Q. Okay. If it was the beginning of your junior 
25 
year, it still would have been sometime in '03, but you 
1 
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Page 52 
Q. Okay, I'm asking you. I'm don't want to trick 
you here. I just want to make certain that you 
understand —
A. No, that's fine. I just wish we could move 
past this. 
Q. Then in paragraph 14 the allegation is that 
you 
and Pm paraphrasing -- is that you returned on 
many occasions to Mr. Epstein's home over a period of 18 
to 24 months, right? 
A. Yes. 
Q. All right So 18 to 24 months would be 
another year and a half to two years, which would now 
be, based on what you are testifying today, would have 
been sometime in '03 through sometime in '05, right? 
A. I suppose, yes. 
Q. Well, two years on to '03 takes me to '05, 
right? I'm just doing the math, ma'am. 
A. I honestly don't remember the dates and I 
don't remember how many months exactly. I don't -- but 
if you go by this, then yes. 
Q. Okay. 
A. I don't remember, I don't recall dates, and 
I'm sari, like I don't remember the first time I went 
there, I don't remember the date when I first went 
there. I don't remember the month. 'just remember 
Page 51 
1 
would have now been 16 years old, correct? 
2 
A. Yes. 
3 
Q. Whereas if it was the latter part of your 
4 
sophomore year, you would have been 15? 
5 
A. Yes. 
6 
Q. So the complaint, Exhibit I, where it says you 
7 
first went in 2004, that's not true, correct? 
MR. HOROWITZ: Object to form. 
9 
BY MR. CRITTON: 
10 
Q. Well, let me go back to it again. 
11 
Paragraph nine where it says "In or about 2004 
12 
Jane Doe, then approximately 16 years old, fell into 
13 
Mr. Epstein's -- fell into Epstein's trap and became one 
14 
of his victims." Okay? 
15 
The first time you were there now you are 
16 
saying would have been in '03? 
17 
MR. HOROWITZ: Form. 
18 
BY MR. CRTTTON: 
19 
Q. Right? 
20 
A. The end of nw sophomore year, that's 2003, 
21 
yes. 
22 
Q. You tell me, okay? Please. Don't let me lead 
23 
you in that. You tell me what the end of your sophomore 
24 
year would have been, what year. 
25 
A. Yes, if it was the end of 2003. 
1 
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Page 53 
being in gym class with -was the first time. 
Q. Then if I go to your answers to 
interrogatories, which are Exhibit 2, question 15, where 
it says 'Plaintiff' — this is your answer under oath, 
okay? There is no lawyer. 
In fact, the only lawyers that were there were 
Ms. Arbour, paralegal and now lawyer. So you are 
certainly not — well, let me strike that 
When you answered these interrogatories, you 
did them in conjunction as reflected in answer number 
one with Ms. Arbour, who was a paralegal for the 
Mermelstein & Horowitz firm, correct? 
A. Yes. 
Q. You weren't scared, were you? 
A. No. 
Q. You weren't dazed? 
A. No. 
Q. You weren't confused? 
A. No. 
Q. You had good presence of mind, you had the 
ability to think about the question as long as you 
wanted to, true? 
MR. HOROWITZ: Form. 
THE WITNESS: Yes. 
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1 
BY MR. CRITTON: 
2 
Q. All right. And at least in this answer under 
3 
oath you said, 'Plaintiff went to defendant's estate 
4 
approximately eight to ten times during her junior and 
5 
senior years of high school, from 2004 and 2005." 
6 
Right? 
7 
A. Uh huh. 
8 
Q. Yes? 
9 
A. Yes. 
10 
Q. Okay. Now you said you also gave — well, let 
11 
me strike that. Let me stay with the police statement 
12 
that you gave a minute. 
13 
Now the first time
 went to Mr. Epstein's 
14 
home, you went with 
is that true? 
15 
A. Yes. 
16 
Q. Okay. And did you — and I'm going to come 
17 
back and ask a lot more questions about this. I just 
18 
want to get what you told the Palm Beach Police 
19 
Department under oath. 
20 
You told them that you went with. Did you 
21 
go upstairs on the very first visit to Mr. Epstein's 
22 
home? 
23 
MR. HOROMTIZ: Tin sorry, are you asking 
24 
ha — 
25 
MR. CRITTON: What she told the police. 
Page 56 
1 
Q. And now you are saying that may not be right, 
2 
I may have lied to them, right? 
3 
A. Yes. 
4 
Q. All right. So you told them you went to 
5 
Mr. Epstein's home the first tint with 
6 
Was that true? 
7 
A. Yes. 
8 
Q. Why did you tell them that? 
9 
A. Because that was the first time I went_ 
10 
Q. But why did you, if you were confused and 
11 
scared, why didn't you just tell the police you never 
12 
went to Mr. Epstein's home if you didn't want to get in 
13 
trouble? 
14 
If you were one of the first people that they 
15 
were lancing to and no one had clued you in that they 
16 
were talking to anyone else, why didn't you just tell 
17 
the police officers if you were going to lie, 9 never 
18 
went to Epstein's house, I don't know what you are 
19 
talking about"? 
20 
MR. HOROWITZ: Form. 
21 
THE WITNESS: Because they pretty much sounded 
22 
like they knew that I already went, from what they 
23 
told me. And they said they have records of my car 
24 
being there, and they pretty much said they already 
25 
knew I went. So that is why I told them, you know, 
1 
2 
3 
4 
5 
8 
9 
10 
it 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
let's put it back in the scenario that you told me. 
You get a call from your mom, the Palm Beach 
police are there to interview you. You drive home for 
five minutes. The four of you, including your mother, 
are outside talking. They want to ask questions about 
Mr. Epstein. 
You make the decision to send Morn inside, 
correct? 
A. Yes. 
Q. Okay. That's 
you sit down? 
A. Yes. 
Q. So you are sitting down with the other two 
police officers, and as they are taking your sworn 
statement and talking to you, you told them -- they 
asked you when is the first time you went to 
Mr. Epstein's house, correct? 
A. Yes. 
Q. They ask you how old you were, and at least 
they reflect that you told them 17, correct? 
A. Yes. 
Page 55 
MR HOROWITZ: Do you understand he's asking 
1 
what you told the police? 
2 
BY MR. CRITTON: 
3 
Q. The Palm Beach Police Department. And again, 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
where we are. Do the three of 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 57 
that the first time that I went with. 
And I just didn't tell them everything about 
when I went the other times. 
BY MR. CRITTON: 
Q. So you actually drove your car to 
Mr. Epstein's? 
A. I don't remember if I drove the first time, 
no. 
Q. I'm not saying the first time, but you 
actually drove to Mr. Epstein's on your own? 
A. Yes. 
Q. So you had to actually get in your car, make a 
decision to go to Mr. Epstein's, and you went by 
yourself on occasions? 
A. I don't remember if I ever went by myself, but 
yes. Usually. was with me. 
Q. Usually. Always? 
A. Not always. 
Q. Okay. By the way, did you really go eight to 
ten times to Mr. Epstein's house? 
A. Yes. 
Q. Okay. 
A. That I remember. 
Q. At least in the interrogatory, Exhibit 2 that 
we talked about, question 15, you are saying its wrong 
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with regard to 20042005 time period, but you are saying 
2 
at least it's right with regard to the number of times 
3 
you went; is that correct? 
1 
A. I said I don't remember the exact dates and 
5 
years. 
Q. Well, if it's 2004 and 2005, it would be at 
7 
the end of your junior year, latter part of your junior 
8 
year into your senior year, correct? 
9 
A. Yes. 
10 
Q. All right. So, and I thought you told me five 
11 
minutes ago that that time period was not correct, or 
12 
now you are not so sure again. 
13 
MR. HOROWITZ: Form. 
14 
THE WITNESS: I told you that I didn't 
15 
remember the dates. And I do remember going there 
16 
from eight to ten times, but I don't remember the 
17 
exact dates of when I started going there. 
18 
BY MR. CRITTON: 
19 
Q. Okay. That's my question to you is you don't 
20 
remember the exact dates, but at least that part of the 
21 
interrogatory where it says the number of times you 
22 
went, you think that's maybe accurate? 
23 
A. Yes, it is accurate. 
24 
Q. Eight to ten times, okay. Well, you told the 
25 
police, the Palm Beach Police Department when you were 
Page E ,
1 
Q. 71te rust time you went, you went with El 
2 
right? 
3 
A. Yes. 
4 
Q. Let me get back to my question. They seemed 
5 
to know that you were at Mr. Epstein's home, that is, 
6 
the police officers? 
7 
A. Yes. 
8 
Q. Because they had seen your car there? 
9 
A. Yes. 
10 
Q. All right. And so if your car was them, l 
11 
assume you don't let other people drive your car 
12 
generally? 
13 
Let me ask this question. Did you ever let 
14 
any other person drive your car to Mr. Epstein's home? 
15 
A. No. 
16 
Q. Okay. So you in each of those instances would 
17 
have had to make the voluntary decision that you were 
18 
going to go to Mr. Epstein's home, right? 
19 
A- Yes. 
20 
Q. All right. So you told than on the first 
21 
occasion you went with- right? 
22 
A. Yes. 
23 
Q. And what did you tell them who. was? 
24 
A. She was a friend in high school. 
25 
Q. All right. So you went with. She was a 
Page 59 
1 
interviewed that you only went two times, didn't you? 
2 
A. Yes, I already admitted that I did not tell 
3 
them the whole truth. 
4 
Q. I know. Well, what I'm trying to do is figure 
5 
out how many things you told them that may have been 
6 
true, that is -- well, let me strike that. 
7 
Pm trying to find out now from looking at the 
8 
police report what you told them may have been true 
9 
versus what was not true or might be a half truth or 
10 
something that you omitted. That's what I'm trying to 
11 
do here, okay? 
12 
A. Okay. 
13 
Q. Do you understand that? 
14 
A. Yes. 
15 
Q. All right. So we know it's your testimony now 
16 
that you lied to them about your age. Did you lie to 
17 
them about the number of times you went to Mr. Epstein's 
18 
home, they being the Palm Beach Police Department? 
19 
A. I told you I didn't tell them all the times I 
20 
went. I only told them two. 
21 
Q. Well, you told them you went only two times? 
22 
A. Yes. 
23 
Q. Is that a lie? 
24 
A. I told you yes. I told you at the very 
25 
beginning. 
Page 61 
1 
friend. She was a good friend at the time? 
2 
A I don't remember if she was a good friend. I 
3 
think we were fighting. Me and her like would fight a 
4 
lot and then make up. So I don't remember if we were 
5 
good friends at the time or just friends. 
6 
Q. Okay. Good friend is someone you trust, have 
7 
almost complete faith in? That's not a play on words 
8 
with your name, but would you consider a good friend 
9 
someone that you would feel very comfortable with and 
10 
you could trust? 
11 
A. Yes. 
12 
Q. Okay. And if it was just a friend, maybe you 
13 
would trust and maybe you wouldn't? 
14 
A. Yes. 
15 
Q. So you go with 
who you have now 
16 
described as a friend, someone you might trust or not 
17 
trust, right? 
18 
A. Yes. 
19 
Q. To Mr. Epstein's home. Again, I'm going to 
20 
get into details later. 
21 
So you go to Mr. Epstein's home the first 
22 
time, and what happens, or what did you tell the police, 
23 
your best recollection? 
24 
A. I just remember I told them that I went there 
25 
and I saw the cooks there, I sawn. 
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I just remember that I, like 1 told them how I 
2 
went upstairs and I did the massage. And I don't think 
3 
I went into detail with them about what happened. 
4 
Q. So -- I'm sorry. 
5 
MR. HOROWITZ: Go ahead 
6 
THE WITNESS: I don't remember going into 
7 
detail with them about what happened. 
8 
And then I also remember going once with., 
9 
and I think I told there about that orM. 
10 
Honestly, I don't --
11 
BY MR. CRITTON: 
12 
Q. So I'm clear, at least you told the police 
13 
officers, your best recollection of what you told the 
14 
police officers, the first time you went to 
15 
Mr. Epstein's home, you went there wide 
you met 
16 
the cook, you met El? 
17 
A. Yes. 
18 
Q. Do you know who 
is? 
19 
A. Yes. 
20 
Q. Who ism 
21 
A. Jeffreys assistant. 
22 
Q. And how do you know that? 
23 
A. Because she is the one that would call me 
24 
every time she wanted me to come there, and she would 
25 
always be there doing, making calls. She would call 
Page 64 
1 
with Jeffrey Epstein by phone? 
2 
A. I don't remember. 
3 
Q. Can you cite any instances to me where you 
4 
think that maybe you spoke with him or you just have no 
5 
recollection of having spoken with him? 
6 
A. I don't remember if he ever called me or 
7 
didn't call me, honestly. I remember talking to Sarah. 
8 
Q. Have you ever totted Mr. Epstein or has he 
9 
ever totted you? 
10 
A. No. 
11 
Q. Have you ever spoken or communicated through a 
12 
computer in any way with Mr. Epstein, either he to you 
13 
or you to him? 
14 
A. No. 
15 
Q. Would it be a correct statement that the only 
16 
conversations that you have ever had with Mr. Epstein 
17 
would have been at Mr. Epstein's home? 
18 
MR. HOROWITZ: Form. 
19 
THE WITNESS: Well, as to what I can remember, 
20 
yes. 
21 
BY MR. CRTITON: 
22 
Q. Well, again, you are here under oath. You 
23 
knew you were going to be deposed? 
24 
A. Yes. 
25 
Q. So at least as you sit here today thinking 
Page 63 
1 
other girls too. 
2 
Sol assume that she was his assistant. She 
3 
also told me about how to set up the massage table and 
4 
other things like that 
5 
Q. How do you know 
called other females? 
6 
A. 1 know because they told me. 
7 
Q. Who is the they? 
8 
A. Jane Doe 4. 
9 
Q. Jane Doe 4? 
10 
A 1.1h huh. 
11 
Q. Yes? 
12 
A And L.A., yes. 
13 
Q. LA. who? 
14 
A L.A. 
15 
Q. Okay. Jane Doe 4 and L.A., are they still 
16 
friends of yours? 
17 
A. Yes. 
18 
Q. Good friends of yours? 
19 
A Jane Doe 4 is, yes. 
20 
Q. How about L.A., what's her status these days? 
21 
A Just a friend. 
22 
Q. Would It be a correct statement that you have 
23 
never spoken with Mr. Epstein by phone? 
24 
A. I don't remember. 
25 
Q. As you sit here today, have you ever spoken 
Page 65 
1 
back over the time that you knew Mr. Epstein, it's your 
2 
best recollection as you sit here today that you have 
3 
never spoken with him except at his home; is that true? 
4 
A My best recollection, yes. 
S 
Q. You have never, and would it also be true that 
6 
you never saw Mr. Epstein other than at his home? 
7 
A. I saw him on the beach before jogging with 
8 
where he came over and said hi to me. 
9 
Q. Were you on the beach at the time? 
10 
A. Yes. 
11 
Q. Who were you there with? 
12 
A I forget. Just one of my girlfriends. 
13 
Q. You used to go to Palm Beach beach, the beach 
14 
in Palm Beach from time to time? 
15 
A. Yes. 
16 
Q. From the time you were a young girl up 
17 
probably even through now? 
18 
A. Uh huh, yes. 
19 
Q. All rid& So one time you saw him on the 
20 
beach with NM, he said hello to you? 
21 
A Yeah, he came over and said hi and asked me 
22 
bow I was. And he just said he was jogging. He had his 
23 
jogging outfit on. 
24 
Q. Is that the extent of the conversation? 
25 
A. From what I can remember. I don't know, it 
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was like a long time ago. I don't — 
2 
Q. And you talked to him? 
3 
A. Yes. 
4 
Q. He said "Hi, how are your 
5 
A. Uh huh. 
6 
Q. Yes? 
7 
A. Yes. 
8 
Q. And did you, was that after you stopped going 
9 
to Mr. Epstein's house or during the time that you were 
10 
going to Mr. Epstein's house that you saw him jogging on 
11 
the beach? 
12 
A. I don't exactly remember when it was. I think 
13 
It was when I was still going. 
14 
Q. Okay. So the only time that you've ever 
15 
spoken with Mr. Epstein outside of his home would have 
16 
been the one time you saw him out jogging on the beach 
17 
and you were at the beach over in Palm Beach, correct? 
18 
MR. HOROWITZ: Form. 
19 
THE WITNESS: Yeah, I thought I saw him in Key 
20 
West once, but T wasn't sure that was him. But 
21 
yeah, other than that, yes. 
22 
BY MR. CRITTON: 
23 
Q. Okay. You have never traveled with 
24 
Mr. Epstein? 
25 
A. No. 
Page 68 
1 
touch your buttocks, correct? 
2 
A. Yes. 
3 
Q. Okay. And that's all he touched was your 
4 
buttocks, correct? 
5 
MR.. HOROWITZ: Form. Again, you are talking 
• 6 
about the conversation? 
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BY MR. CRITTON: 
8 
Q. Only what you told the Palm Beach police. 
9 
A. As to what I can remember, Pm not — if you 
10 
could show me, I don't exactly remember. 
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Q. I'm asking your best recollection. Pm 
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!with% at the police report. 
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A. Okay. 
14 
Q. Did you also tell the Palm Beach police that 
15 
at no time did he touch any of your private areas? 
16 
A. I don't remember telling them that he did. 
17 
Q. Okay. In fact, you told them he 
18 
specifically — they asked you, did he touch, did he 
19 
touch you in your private main your vaginal area, 
20 
and you said no, correct? 
21 
A. Yes. 
22 
Q. And they asked you whether he had touched your 
23 
breast, and you said no, correct? 
24 
A. I don't remember. 
25 
Q. Aloha whatever ultimately, whatever the 
Page 67 
1 
Q. And Mr. Epstein has never flown you or asked 
2 
you to travel anyplace, has he, where you traveled? 
3 
A. No. 
4 
Q. That's correct? 
5 
A. Yes. 
6 
Q. All right. First time, at least what you told 
7 
the police officers, your best recollection is that you 
8 
went over there with 
you went upstairs, and you 
9 
gave Mr. Epstein a massage, correct? 
10 
A. Yes. 
11 
Q Okay. And during the cause of the massage, 
12 
you kept your clothes on, true? 
13 
A. I believe that's what I told them. 
14 
Q. All right. And you also told the police that 
15 
at no then did he try to touch you or did he touch you, 
16 
correct? 
17 
A. I told them that he did try to touch my butt. 
18 
Q. Okay. He did try? 
19 
A. Or he did, l think' said. 
20 
Q. What's the difference between trying and 
21 
touching? 
22 
A. I don't exactly remember the words I said. I 
23 
think I did tell them that he did. 
24 
Q. So its now your testimony that you recall 
25 
telling the Palm Beach Police Department that he did 
(561) 832-7500 
Page 69 
1 
statement says, that's what you would have told them. 
2 
If I ask you to assume that that's at least 
3 
the information that they have is that he did not touch 
4 
you in any, quote, unquote, private area, that would be 
5 
accurate? 
6 
MR HOROWITZ: Form. 
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THE WITNESS: Yes. 
8 
BY MR. CRITTON: 
9 
Q. That's what you had told them? 
10 
A. Yes. 
11 
Q. And you didn't touch him in any of his private 
12 
areas, did you? 
13 
MR. HOROWITZ: Form. 
14 
THE WITNESS: No. 
15 
BY MR. CRITTON: 
16 
Q. In fact, in any of the visits you ever went to 
17 
Mr. Epstein's home, you never touched him in his genital 
18 
area, did you? 
19 
A. No. 
20 
MR. HOROWITZ: Form. Pm sorry, Pm doing 
21 
this to have a clear record, because you stern to be 
22 
drifting between —
23 
MR. CRITTON: Pm not drifting. Pm asking 
24 
specific questions. 
25 
MR HOROWITZ: I understand, but you arc 
I a 7210 Ow • • • 
18 (Pages 66 to 69) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 70 
alternating between the conversation versus events. 
2 
MR. CRITTON: Is that a form? 
3 
MR. HOROWITZ: Yes. 
4 
MR CRTITON: Ern not trying to trick her. 
5 
BY MR CRITTON: 
6 
Q. You understand when I said on all of the 
7 
visits you went to Mr. Epstein's home, you never touched 
8 
his private areas, his genital area, correct? 
9 
A. Yes. 
10 
Q. Now I'm asking away from the Palm Beach police 
11 
statement. You understood that, didn't you? 
12 
A. Yes. I did not. 
13 
Q. Same questions now. 
14 
Now I'm away from the statements you gave 
15 
under oath to the Palm Beach Police Department 
16 
At no time did you touch any of his genital 
17 
area, correct? 
18 
A. Yes. 
19 
Q. All right. At no time did you have sexual 
20 
intercourse with Mr. Epstein, correct? 
21 
A. Yes. 
22 
MR HOROWITZ: Form. 
23 
BY MR. CR1TTON: 
24 
Q. At no time did you have any oral or anal sex 
25 
with Mr. Epstein, correct? 
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Page 72 
that you received any money for having given Mr. Epstein 
a massage? 
A. I believe I told them I did. 
Q. Okay. So you got money for doing a massage, 
although there was nothing of a sexual nature that was 
involved at all, at least what you told the Palm Beach 
police, correct? 
A. Yes. 
Q. Had you ever given a massage for money before? 
A. 
Q. 
A. 
A. 
Q. 
No. 
Had you given massages before? 
Just to friends. 
To boys and girls, males and females? 
Yes. 
Did you ever receive money for giving a 
massage before? 
A. No. 
Q. And how much money did you get from 
Mr. Epstein? 
A. $200. 
Q. Did he hand it to you? 
A. Yes. 
Q. After the first occasion — and again, 
back to what you told the Palm Beach police. 
On the second occasion what did you tell the, 
?age 71 
1 
A. Yes. 
2 
Q. At no time did Mr. Epstein in any way 
3 
penetrate any portion of your vaginal area, did he? 
4 
A. I mean he did touch it and I wouldn't —
5 
penetrate with what? 
6 
Q. With either an object or his fingers. At no 
7 
time did Mr. Epstein ever penetrate your vagina with 
8 
either his 
or an object, did he? 
A. 
MR. HOROWITZ: Let her fmish. 
BY MR. CRITTON: 
Q. But you didn't let him, did you? 
Q. He never penetrated, did he? 
A. No. 
Q. Now back to the police statement or the 
statement that you gave to the Palm Beach police. You 
told them that you only went to Mr. Epstein's borne —
well, let me strike that. Let me stay with the first 
occasion. 
On the first occasion did you tell the police 
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Page 73 
that is, the second time you went to Mr. Epstein's, I 
think you said you tolighe P&each Police Department 
you we 
•Cher with MI or 
A. 
Q. 
A. Well, yes. 
Q. You either went with Illor •right? 
A. Yes. 
Q. How did you get to Mr. Epstein's? What did 
you tell the police? Getting back to what you told the 
police. 
A. I don't exactly remember. I think I said I 
drove there. 
Q. Okay. ir go the second time? 
A. I think 
went, yes. I don't retnem 
Q. So it would have been the three of you,
you — well 
a
 sure, but you would have gone 
and either 
or MI right? 
A. Yes. 
Q. And maybe 
A. Yes. 
Q. And you think you drove? 
MR. HOROWITZ: Fame. 
THE WITNESS: I don't remember. 
(561) 832-7500 
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