EFTA01108851

Page 50: 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO:502008CA028051XXXXMB AB 
Plaintiff, 
-vs- 
VOLUME IV OF IV 
JEFFREY EPSTEIN 
AND 
Defendants. 
VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF 
Tuesday, February 09, 2010 
10:09 - 5:05 p.m. 
250 Australian Avenue South 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting 
Job No.: 1296 
(561) 832-7500 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (0014151-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
b55421ef-d299-4e4f-9ba6-85and27f4405 
EFTA01108851

EFTA01108852

Page 503 
Page 505 
1 
APPEARANCES: 
2 
On behalf of the Plaintiff. 
and Jane DDe
.
3 
BRAD J. EDWARDS. 
FARMER, JAFFE, WE/SSING, EDWARDS 
I,PJ02MAt4. PL 
7 
On behalf o the 
Jeffrey Epstein: 
3 
ROBERT D. CRITTON,11t, P8QUIRE 
MARK T. tura ESQUIRE 
9 
R 
• wt ft* 
LLITTIER & COLEMAN, ELP 
12 
On 
o the a r: ant, ;army Epstein: 
13 
JACK ALAN GOLDBERGER. ESQUIRE 
• 
R & WEISS, PA. 
14
16 
17 
18 
ALSO PRESENT. kffrey Epstein, via video conference 
Daniel C1/4”.ney, Videogmpber 
19 
Visual Evidence, Incorporated 
20 
21 
22 
23 
24 
25 
1 
2 
3 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
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21 
22 
23 
24 
25 
PROCEEDINGS 
THE VIDEOGRAPHER: We're back on the 
record at 1:48 p.m. 
BY MR. LUTHER: 
Q. Okay, Ma'am. I want to add that during 
the morning session, I was asking you some 
questions. I just want to go over a couple of 
things. One of the first things I asked you this 
morning is whether you understood you were under 
oath today. And you indicated you did understand 
that? 
A. Correct. 
Q. Are you, did you, are you aware of the 
fact that it is a crime known as perjury to make a 
false statement under oath? 
A. Correct. 
Q. Are you also aware that it is a separate 
crime, a federal crime to make a false statement to 
an FBI agent? 
A. Correct. 
Q. And you've already admitted that you 
committed that federal crime; you lied to the FBI, 
according to you. 
A. I was in fear of my sorts life, correct. 
1 
2 
3 
4 
5 
5 
7 
Page 504 
INDEX VOLUME I 
"NESS: 
DIRECT CROSS REDIRECT RECROSS 
BY MR. LUTHER 4 
8 
9 
10 
11 
EXHIBITS 
12 
13 
14 
EXHIBIT DESCRIPTION 
PAGE 
15 
DEFENDANT'S NO.3 
Photo of Fantasies of Palm Beach 
512 
16 
DEFENDANTS NO. 4 
518 
17 
Photo of Demon's Motorcycle ad 
18 
DEFENDANTS NO. 5 
634 
• ' 
unction for 
19
20 
DEFENDANTS NO. 6 
618 
tinctice for 
21 
22 
23 
24 
25 
Page 506 
1 
Q. Now, l want to ask you one more time: Is 
2 
there anything you want to correct about any of your 
3 
testimony this morning, especially as it relates to 
4 
working in places of employment that you have termed 
5 
to be jack shacks at or about or near Speannim 
6 
Rhino? 
7 
A. Correct. I'm fine on that 
8 
Q. Okay. Isn't it a fact that on Saturday, 
9 
January 30th, you went to Spearmint Rhino's? 
10 
A. Yes. 
11 
Q. And you got there, what time, around 8:00? 
2 
A. Yes. 
13 
Q. And then at some point in time you la 
14 
Spearmint Rhino's, did you not? 
15 
A. Yes. 
16 
Q. And you went to a place called Fantasies 
17 
of Palm Beach, did you not? 
18 
A. Not that I recall. I don't know a name 
1 9 
Fantasies. 
20 
Q. Well, Fantasies of Palm Beach would be the 
21 
facility that's located right next door to Spearmint 
22 
Rhino's. You're familiar with that, aren't you? 
23 
A. I thought that was affiliated with Spearmint 
24 
Rhino. 
25 
Q. Well, so that we 'mow - 
(561) 832-7500 
PROSE COURT REPORTING 
2 (Pages 503 to 506) 
AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (901451.976-2934) 
Electronically signed by cynthia hopkins (601451.9762934) 
Electronically signed by cynthia hopkins (601451.9762934) 
b5542lef-d299-4e4f-9ba6-85aad27f4405 
EFTA01108853

Page 509 
Page 507 
1 
(Cellphone interngtion.) 
2 
THE WITNESS: Oh, Pm sorry, my phone. 
3 
MR. Lill-TIER: Sure. Oo ahead. 
4 
THE WITNESS: Okay. Sorry. 
5 
BY MR. LUTHER: 
6 
Q. There is a — whether or not ifs 
7 
affiliated with Spearmint Rhino, I don't know. When 
8 
you referred to your testimony this morning that you 
9 
didn't go anyplace other than Spearmint Rhinos and 
10 
places affiliated did, with it, did you mean to 
11 
include in those places that you went Fantasies of 
12 
Palm Beach? 
13 
A. I personally never heard of Fantasies of Palm 
14 
Beach, but I know that, there, that Spearmint Rhino has 
15 
a couple places affiliated with them. 
16 
Q. What places do they have that are 
17 
affiliated with them? 
18 
A. The back and then there's an entrance to 
19 
another place. That's all ! know. 
20 
Q. Well, tell me about this entrance to 
21 
another place. What are you talking about? 
22 
A. Well, in the back of Spearmint Rhino there is 
23 
a little section that the dancers 
I don't know 
24 
exactly what they do there, but that's where I do sell 
25 
shoes and my lingerie. 
Page 508 
1 
And then there is another entrance that 
2 
you can go through and then there is another 
it's 
3 
like there's, I know that there's, there's a lot of 
4 
doors. I don't know what they consist of. 1 don't 
know what they do there, but I know that they are 
6 
affiliated, I thought that they were affiliated with 
7 
Spearmint Rhino, and that's where I also go to sell 
8 
my shoes and ptuses. 
9 
Q. Okay. Well, you talked about a place in 
10 
the back of Spearmint Rhino's that you gain access 
11 
to by going through the Spearmint Rhino 
12 
establishment? 
13 
A. Yes. 
14 
Q. All right. Now, what is this second place 
15 
that you are talking about that you say is 
16 
affiliated with Spearmint Rhino's? 
17 
A. Well, you can either go through out the back 
18 
door of Spearmint Rhino and take a right, and then there 
19 
is a place there that's affiliated with them. 
20 
Q. Is there a name? Is there a separate 
21 
entrance to the place? 
22 
A. 1— they're connected. 
23 
Q. Is there a separate name on this place? 
24 
A. Not that I know of 
25 
Q. Okay. I'm tallthsabout a place that's 
(561) 832-7500 
1 
located, I believe it's to the left side of 
2 
Spearmint Rhino's as you look at it. It's got a 
3 
separate entrance. It's got neon signs on it? 
4 
A. Okay. 
5 
Q. And it's known as Fantasies of Palm Beach. 
6 
You're aware of that place, aren't you? 
7 
MR. EDWARDS: Fan 
8 
THE WITNESS: I'm not aware of any name. 
9 
BY MR. LUTTIER: 
10 
Q. Well, you were in the establishment known 
11 
as Fantasies of Palm Beach on the evening of 
12 
Saturday, January 30th, 2010, were you not? 
13 
MR. EDWARDS: Font. 
14 
THE WITNESS: If that's what it's called, 
15 
then, yes. But, as long, as far as I know, 
16 
Spearmint Rhino, that's the name I know it as 
17 
you know. 
18 
BY MR. LUTTIER: 
19 
Q. Well, this is a place that has a separate 
20 
entrance. You don't go through the entrance of 
21 
Spearmint Rhino. You go into a separate entrance 
22 
for a place called Fantasies of Palm Beach. 
23 
A. Well -
24 
Q. I want to make sure we're real clear here 
25 
we're not playing semantics. 
Page 510 
1 
A. We're not playing what? 
2 
Q. Semantics. 
3 
A. Okay. 
4 
MR. CRITTON: Word games. 
5 
THE WITNESS: Oh. 
6 
MR. LUTTIER: All right? 
7 
THE WITNESS: Yeah. 
8 
BY MR. LUTTIER: 
9 
Q. And, and you were, in fact, in this place 
1 0 
called Fantasies of Palm Beach on Saturday, January 
11 
30th, 2010, were you not? 
12 
MR. EDWARDS: Object to the form. 
13 
THE WITNESS: I definitely walked through 
14 
an entrance and that I thought was affiliated 
15 
with Spearmint Rhino. 
16 
BY MR. LUTTIER: 
17 
Q. And there's a black female in there that 
18 
works at the front desk, is there not? There was on 
19 
Saturday night. 
20 
A. Oh, I don't know. I don't know who works 
21 
there. I don't blow. 
22 
Q. And the--
2 3 
A. I just know that I go into Speannint Rhino and 
24 
I sell my — 
25 
Q. And — 
4,1 
J 
3 (Pages 507 to 510) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (801.051.976-2934) 
Electronically signed by cynthia hopkins (601451-976-2934) 
Electronically signed by cynthia hopkins (601.061-9762934) 
b5542fef-d299-404f-9ba6.85aad2714405 
EFTA01108854

Page 511. 
— items. 
2 
the name that you're known as is 
3 
isn't that right? 
4 
A- I'm not known as 
5 
Q. That's the name you -- remember we were 
6 
asking you about the cards you used to use? 
A. Yeah, I was known as =in 
'07 and '08. 
8 
O.
 that's the name you've used in the past 
9 
is 
10 
A. Yes. 
11 
Q. And in fact on Saturday, January 30th, you 
12 
were working in Fantasies of Palm Beach which was. 
13 
to use your terms, a jack shack, were you not? 
14 
A. No, I was not working there. 
15 
Q. And you were charging $120 fora half hour 
16 
to perform services; isn't that right? 
17 
A. No. 
18 
Q. Andacame out and told somebody your 
19 
name was Mend that that was your charge, 
20 
didn't you not? 
21 
A. No, I did not. All I do is sell shoes and 
22 
purses there. 
23 
MR. LUTRER: Let me show you a picture 
24 
here which we'll mark as, !guess we want to do 
25 
it in order. It will be Exhibit 3. 
Page 513 
1 
A. No. I say to the girls, my name is Lynn and 
2 
they know that I sell all of my, all of my clothes and 
3 
lingerie and shoes and everything else I sell. 
4 
Q. But there is no doubt that now that you 
5 
have seen this picture, you were in that 
6 
establishment that is depicted on Exhibit No. 3 on 
7 
January 30th, right? 
8 
A. Correct. 
9 
Q. And you drive a white Mitsubishi Gallant; 
10 
is that right? 
11 
A. Yes. 
i 2 
Q. License plate number is 193HV; is that 
13 
correct. 
14 
A. I don't know my license plate number, but 1 
15 
definitely drive a white Mitsubishi Gallant 
16 
Q. And is, was that vehicle parked outside 
17 
Fantasies of the Palm Beach on Saturday night, 
18 
January the 30th? 
19 
A. Yes, but like I said before, from my 
20 
knowledge, I thought this was affiliated with Spearmint 
21 
Rhino. 
22 
Q. And that car --
23 
A. And they don't like me to park, they don't 
24 
like me to park in front of Spearmint Rhino because 
25 
there are so many clientele that goes in and out. So 
Page 512 
1 
(Defendant's Exhibit No. 3 was marked for 
2 
identification.) 
3 
THE WITNESS: This place, yeah, ifs next 
4 
to Spearmint Rhino's. 
5 
MR. LUTTTER: Hold on. Hold on. 
6 
TI
 WITNESS: Sorry. 
7 
BY MR. LUITLER: 
8 
Q. I have to ask you a couple of questions. 
9 
Do you recognize Exhibit 3? 
10 
A. Yes, but what I would do, I would go out of 
11 
Spearmint Rhino from the back and go into the back 
12 
entrance of Fantasies or whatever this place is called. 
13 
Q. So so, now upon seeing the picture, you 
14 
want to correct your testimony and say, in fact, you 
15 
were in Fantasies of Palm Beach on Saturday? 
16 
A. I, from my understanding, from my knowledge, I 
17 
thought that this place was owned by Spearmint Rhino. 
18 
Q. All right. The place of business that's 
19 
depicted in Exhibit No.3, were you in that place of 
20 
business on Saturday, January 30th? 
21 
A. Yes, selling my items. 
22 
Q. And did you, in fact, on that night, on 
23 
Saturday, It 
30th, tell individuals that your 
24 
name was 
and that you charged $120 per half 
25 
hour? 
Page 514 
1 
they need as much parking space as they can. 
2 
Q. And you stayed at Fantasies of Palm Beach 
3 
until what hour on the morning of Sunday which would 
4 
be January 31st? 
5 
A. I stayed until what time? 
6 
Q. Yeah, the morning until — what time on 
7 
the morning of Sunday, January 31st, did you leave? 
8 
A. Well, Spearmint Rhino, I would go until 
9 
closing like 5, 6. And then in the back of here, of 
10 
Spearmint Rhino, that's like, sometimes they have after 
11 
pa-ties there, something. This is what I hear from the, 
12 
the manager at Spearmint Rhino. And like I said, 
13 
sometimes I stay there and I have a couple of drinks. 
14 
And I'm not sure what time I left. 
15 
Q. I don't want to know — 
16 
A. As long as I keep on selling shoes and 
17 
lingerie, I'm the there. 
18 
Q. I am not asking about sometimes. h am 
19 
talking about Sunday morning, January 31st, 2010, 
20 
what time did you leave on that day? 
21 
A. I couldn't tell you that. 1 don't know. 
22 
Q. Well, what's your best estimate? 
23 
A. I don't know, sir. 
24 
Q. Well, first of all you closed Spearmint 
25 
Rhino at, what 5 in the morning? 
(561) 832-7500 
PROSE COURT REPORTING. 
4 (Pages 511 to 514) 
AGENCY, INC.. 
(561) 832-7506 
Electronically signed by synth's hopkIns (601-061-976.2934) 
Electronically signed by cynthia hooking (601.051-976.2934) 
Electronically signed by cynthia hopkins (601.051-976.2934) 
b5542for-d299-4c4f-9ba6-85aad2714406 
EFTA01108855

Page 515 
1 
A. I closed it? 
2 
Q. Yeah, you were them until it closed? 
3 
A. Yes. 
4 
Q. And then you went over to Fantasies, 
5 
right? 
6 
A. That I thought was Spearmint Rhino from the 
7 
back 
8 
Q. Whatever. 
9 
A. Okay. 
10 
Q. And then, how much longer did you stay 
11 
there? 
12 
A. I stayed there a little while because there is 
13 
more girls there that like to buy my items. 
14 
Q. Now, let's talk about your trip to New 
15 
York 
16 
A. Okay. 
17 
Q. Tuesday, February 2nd, 2010. Remember 1 
18 
asked you earlier about whether you ever used any 
19 
business cards? 
20 
A. Yes. 
21 
Q. When you went on this trip to New York, 
22 
did you have any cards? 
23 
A. No, not that I 
no. 
24 
Q. Did 
M
.
 
have any cards? 
25 
A. Not that I know of. 
Page 517 
1 
A. And we started talking to people. 
2 
Q. Who did you talk to in particular? 
3 
A. I don't know anyone else. 
4 
Q. Did you talk to a male there? 
5 
A. Yeah. 
6 
Q. Have him over at your table? 
7 
A. He came closer to — we were at the bar. 
8 
Q. The three of you were talking, were you 
9 
not? 
10 
A. Yeah. 
11. 
Q. Do you remember the guy having a laptop? 
12 
A. Yes. 
13 
Q. What did you-all do on the laptop or what 
14 
did he do on the laptop while you were there and you 
15 
both were sitting there? 
16 
A. Well, I told him that I modeled for Demons 
17 
Cycles. And I told him if he would like to see my 
18 
pictures, to go onto Demons Cycles. 
19 
Q. So, did you tell him about any other 
20 
websites? 
21 
A. Excuse me? 
22 
Q. Did you tell him about any other websites? 
23 
A. No, not that I recall. 
24 
MR. LIMIER: Let's mark this as 
25 
exhibit — what's this, 4? 
Page 516 
1 
Q. Did you, when you went to the Palm Beach 
2 
International Airport, did you give the taxicab 
3 
driver a card? 
4 
A. Did I give hi 
card? 
5 
Q. Yeah, you or 
., little business card? 
6 
A. I didiagive him a card, no. 
7 
Q. Did M. give him a business sand? 
8 
A. Not that I know of. 
• 
9 
Q. When you went into the Palm Beach 
10 
International Airport, your card — do you recall 
11 
going to a bar? 
12 
A. Palm Beach International Airport, yeah, I went 
13 
to a bar there — 
14 
Q. What bar do you go to? 
15 
A. — because I totally missed the flight. 
1.6 
Q. What bar did you go to? 
17 
A. I think it was Fridays, if I am not mistaken 
18 
or not. I don't know what it was called. 
19 
Q. Who went tuk bar with you? 
20 
A. 1 went with M. to the bar and it was just 
21 
her and 1. 
22 
Q. And for how long was it just the two of 
23 
you? 
24 
A. For like ten minutes. 
25 
Q. And then what happened? 
Page 518 
1 
THE COURT REPORTER: Four. 
2 
MR. urrIIER: Mark this as 4. 
3 
MR. EDWARDS: Is Exhibit 1 and 2 marked -
4 
MR. LUTTIER: Yeah. 
5 
MR. EDWARDS: 
in the previous depo? 
6 
MR. LUFTIER: Yeah, the previous depo. 
7 
Although I don't know where the exhibits are or 
8 
they went. 
9 
MR. EDWARDS: Okay. 
10 
MR. LUTT1ER: It was like answers to 
11 
interrogatories. Something like that. 
12 
MR. EDWARDS: Okay. 
13 
(Defendants Exhibit No. 4 was marked for 
14 
identification.) 
15 
BY MR. 
16 
Q. Let me show you what's been marked as 
17 
Exhibit 4 and ask you if you can identify that. 
18 
A. This is —
19 
MR. EDWARDS: Wait until he asks you a 
20 
question. 
21 
BY MR. LUTHER: 
22 
Q. Can you identify it? 
23 
A. Yes. 
24 
Q. What is it? 
25 
A. This is --1 modeled for Demon Cycles and it 
(561) 832-7500 
5 (Pages 515 to 518) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601-051.976-2934) 
Electronically signed by cynthia hopkins (601-051-976.2934) 
b5542lef-d299-4041-9ba6.85aac127f4406 
EFTA01108856

Page 519 
1 
is their advertisement now. 
2 
Q. And is this one of the pictures on your 
3 
website? 
4 
A. On my website? 
5 
Q. Yeah, or your Facebook, I guess, account 
6 
or MySpace, whatever it was. 
7 
A. Yeah, I have posted it on there, yeah. 
8 
Q. Is, was this one of the pictures you were 
9 
telling us at your last deposition that you really 
10 
wouldn't want your four-year-old son to see? 
11 
A. No, that's fine if he sees this. This is, 
12 
this is very legit. His mother modeled and I am 
13 
actually very proud of this photo. 
14 
Q. All right. Now, did you do anything else 
15 
with this inditinial before you left the bar that 
16 
you, you and M. were tenting to at the Palm Beach 
17 
International Airport? 
18 
A. Did we do anything with him? 
19 
Did you give him anything, either you or 
20 
21 
A. I don't recall givingain anything but —
22 
Q. Well, did you see M. give him anything? 
23 
A. No. 
24 
Q. Did either one of you give him a business 
25 
card? 
Page 521 
1 
Q. Did you do anything else that evening? 
2 
A. Yes, we went out to dinner. 
3 
Q. After you — did you leave the apartment 
4 
and go look around at Grand Central Station and then 
5 
keep on walking around or did you come back to the 
6 
apartment? 
7 
A. We went back to the apartment. 
8 
Q. Okay. And then there came a time after 
9 
you came back from sightseeing that you left the 
10 
apartment a second time? 
11 
A. Yes 
12 
Q. And that was for what purpose? 
13 
A. We went to Angelo's. 
14 
Q. Okay. And how did you get to Angelo's? 
15 
A. We got to Angelo's in a trod. 
16 
Q. Alexi? 
17 
A. Uh-huh. 
18 
Q. And that was about what time? 
19 
A. Oh, jeez, maybe, maybe 9:00. 
20 
Q. Between the time — what time did you go 
21 
looking at Grand Central Station? 
22 
A. That was before 9:00. 
23 
Q. Okay. And do you remember, do you recall 
24 
that evening an individual by name of Martin 
25 
Krouner? 
Page 520 
1 
A. I don't have any business cards. I don't —
2 
Q. Well, I don't — you may want to be 
3 
careful here. I don't want to trick you. lam not 
4 
playing semantics. Did either you or 
give him 
5 
a business card? 
6 
MR. EDWARDS: Object to the form. 
7 
THE WITNESS: Not that I recall, no, sir. 
8 
We had a few drinks and, and we were off to our 
9 
flight. 
10 
BY MR. LUTTIER: 
11 
Q. And then you flew to New York and you took 
12 
a c 
and 
u went to this apartment that's located 
13 
at 
'n New York: is that ri t? That 
14 
would be the corner o 
anc 
Street? 
15 
A. 
rings a bell. 
16 
That's where we stayed? 
17. 
Q. Yeah. 
18 
A. Yeah. 
19 
Q. Now, on that evening, the first night that 
20 
you got there on Tuesday, I think earlier you said 
21 
you-all walked down a street and went to dinner, is 
22 
that right? 
23 
A. We walked down the street and we walked into 
24 
a, I think it's Grand Central Station. I'm not sure 
25 
because I'm not from there and we looked around. Yeah. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 522 
A. Do I know a man named Martin? 
Q. Uh.huh, Martin Krouner. 
A. No. 
Q. Do you remember getting in a black 
Series 5 BMW when you came out of the condominium? 
A. We, we did take a ride with a man. 
Q. Well, 'thought you just told me you 
walked to the restaurant. 
A. No, 'told you I took a cab to the restaurant. 
Q. Oh, took a cab to the restaurant? 
A. Yes. 
Q. Did you forget about getting in a car with 
this man? 
A. He took us a little sightseeing. No, I did 
not forget about that. 
Q. Was that before dinner? 
A. That was before dinner, yes. 
Q. Did you just fail to mention that or —
this is different than the man who took you 
sightseeing later, isn't it? 
A. Yes. 
Q. Okay. So, tell me who Martin Krouner is. 
A. I don't know his name, if that is his name. 
Q. Well, the guy that picked up in the black 
BMW, who's he? 
(561) 832-7500 
6 (Pages 519 to 522) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by cynthia hopkins (601.051476-2834) 
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Page 523 
Page 525 
1 
A. I guess a friend of Anna's. 
2 
Q. Well, tell us how old this individual was. 
3 
Describe him for us. 
4 
A. He has not a lot of hair. He's about five-six 
5 
maybe and a little chubby. 
6 
Q. For what purpose were you — and you never 
7 
met him before? 
8 
A. No. 
9 
Q. In never met him before? 
10 
A. No. 
11 
Q. You didn't have any idea who he was? 
12 
A. No. 
13 
Q. You-all climbed in his car? 
14 
A. Yeah, I think it was Anna's friend. 
15 
Q. Okay. What did Anna tell you about the 
16 
guy? 
17 
A. She's Chinese. She's like go, go; go, go have 
18 
fun, go search the town. 
19 
Q. So, where did you go with Martin? 
20 
A. We ended up meeting him at Angelo's. 
21 
Q. Wait a minute. You got — first of all 
22 
you got in Martin's car, right? 
23 
A. I got into Martin's car, yes. 
24 
Q. And then where did you go once you got in 
25 
Martin's car? 
1 
fellow here, Mr. Martin Krouner? 
2 
A. If that's his name. I don't know if we took a 
3 
picture of him, but we definitely took pictures of.. 
4 
and I. 
5 
Q. And, and where did you take those 
6 
pictures? 
7 
A. Wherever we were. 
8 • 
Q. Okay. And when this man brought you back, 
9 
did he go to dinner with you? • 
10 
A. He ended up meeting us there, yes. 
11 
Q. Did he drop you at the restaurant? 
12 
A. He dropped us near so we can get there with a 
13 
taxi. He dropped us somewhere off of the street and we 
14 
went with a taxi. 
15 
Q. So, he dropped you off and then you got a 
16 
taxi to get there? 
17 
A. To go to Angelo's, yeah. 
18 
Q. And then he met you there later? 
19 
A. Lateran. 
20 
Q. Okay. About what time? 
21 
A. Oh, God, I don't know the times. Maybe this 
22 
was around, maybe around — I'm — this is total 
23 
ballpark, Mee 10 maybe. 
24 
Q. Okay. An
d, and then after dinner 
25 
what did you and M. and he do? 
Page 524 
1 
A. We searched around the town. 
2 
Q. What do you mean you searched around? 
3 
A. We went sightseeing. 
4 
Q. Okay. Do you remember where you went? 
5 
A. And we went sightseeing. 
6 
Q. Do you remember where you want 
7 
sightseeing? 
8 
A. Then we took a taxi. No, because I don't know 
9 
the area. 
10 
Q. You went sightseeing in Mr. Kroner's car, 
11 
correct? 
12 
A. Yes. 
13 
Q. All right. And, and did there come a time 
14 
that you got of Mr. Kroner'S car? 
15 
A. Yeah, and we looked around. It was finning 
16 
outside, so it was nice to feel the snow. 
17 
Q. And where did you get out of the car? 
18 
A. Sir, I don't know New York. I don't —
19 
Q. Well, was it at a restaurant? Was it at 
20 
the pool? Was it back at the condo? Where was it? 
21 
A. it was near a whole bunch of buildings. 
22 
Q. By the way, did you take any pictures 
23 
while you were up there? 
24 
A. I did take pictures. 
25 
a Take a picture of you and ■ 
and this 
(561) 832-7500 
Page 526 
1 
A. Well, we took a taxi back to his car. And we 
2 
went up to the, we went up to Anna's room and he just --
3 
we just said bye. 
4 
Q. And did you receive anything at all of 
5 
value from this man? 
6 
A. No. 
7 
Q. Did you charge him anything? 
8 
A. No. 
9 
Q. Were you paid anything for the time you 
10 
spent with him? 
11 
A. No. 
12 
Q. Now, who's Robert Fredrick Burke? 
13 
A. Robert Fredrick Burke, I have no idea. 
14 
Q. Well, on the next day on Wednesday, 
15 
February 3rd, did you go sightseeing again? 
16 
A. Yes, we did. 
17 
Q. And you said that this fellow Bobby came 
18 
to see you at the apartment sometime the morning of. 
19 
Wednesday, February 3rd? 
20 
A. He came to see us, uh4tuh. Pm not sure what 
21 
time it was. I think it was around in the afternoon. 
22 
. Okay. And then after he kit, you and 
23 
did some more sightseeing? 
24 
A. Yeah, we walked around town. 
25 
Q. Do you remember getting in a vehicle with 
7 (Pages 523 to 526) 
PROSE COURT REPORTING AGENCY; INC. 
(561) 832-7506' 
Electronically signed by Cynthia hopkins (601451476-2934) 
Electronically signed by cynthla hopkins (601.051-976-2934) 
Electronically signed by synth's hopkins (601.061.976.2934) 
b55421of-d299-4e41-9b416.85ead2714405 
EFTA01108858

Page 527 
Page 529 
1 
somebody that night? 
2 
A. Yes. 
3 
Q. Who did you get in a vehicle with? 
4 
A. I told you, I don't know his name. 
5 
Q. Well, where did you, where did you meet 
6 
this person? 
7 
A. Everybody was Alma's friend. Anna has a lot 
3 
of friends. 
9 
Q. Well, what did you know about the person? 
10 
A. Nothing. 
11 
Q. How old is the person? 
12 
A. I told you, I don't know anything about him. 
13 
Q. And what kind of vehicle did you get in? 
14 
A. I don't even know the vehicle. 
15 
Q. Toyota Highlander? 
16 
A. (sit — I don't know. 
17 
Q. And what nationality is this individual? 
18 
A. I have no idea. 
19 
Q. And where did this individual take you? 
20 
A. He took us to sightseeing and he took us to 
21 
the Statue of Liberty, everywhere. 
22 
Q. Did you receive anything of value from 
23 
him? 
24 
A. No. 
25 
Q. Did you charge him anything? 
1 
A. I have no idea. 
2 
Q. Were they a male's clothes or female's 
3 
clothes? 
4 
A. I didn't search through the garbage. I just 
5 
know that I threw out the trash. 
6 
Q. So you're telling me you don't know whose 
7 
they were? 
8 
A. No. 
9 
Q. Okay. Do you know 
10 
A. Yes, Id°. 
11 
Q. And how do you know 
12 
A. We grew up together. Firer ably 'mew her since 
13 
1 was 12. 
14 
Q. Have you ever been engaged in any kind of 
15 
a business venture, regardless of whether it was a 
16 
formally formed business venture like a corporation, 
17 
but any kind of business venture with .M? 
18 
A. I went, we went to Jeffrey's togWer. 
19 
Q. My other kind of business venture, you 
20 
and heft 
21 
A. No. 
22 
Q. Were you ever, did you ever represent or 
23 
attempt to start a business venture with her? 
24 
A. This is years ago. 
25 
Q. How many years ago? 
Page 528 
1 
A. No. 
2 
Q. You or El? 
3 
A. I did not charahim anything. 
4 
Q. How about 
? 
5 
A. I don't know what she does but, no, I don't 
6 
think so. 
7 
Well, was there ever a time that you and 
8 
were not together in this person's presence? 
9 
A. Other than me going to the restroom, no. We, 
10 
I, we were pretty much together the whole time. 
11 
Q. On the evening of February 3rd, 2010, do 
12 
you recall throwing a bag of trash in the garbage? 
13 
MR. EDWARDS: Mat date is that? 
14 
MR. LUITIER: The evening of February 3rd, 
15 
2010, at approximately 9:00 p.m. 
16 
THE WITNESS: In the evening. 
17 
MR. LUTHER: Just before you got in the 
18 
Toyota Highlander. 
19 
THE WITNESS: Yes, we did. 
20 
BY MR. WITTER: 
21 
Q. Okay. And do you recall what it was that 
22 
was in that bag? 
23 
A. There was whole bunch of clothes and 
24 
everything that Anna did not want, so we threw it out. 
25 
Q. And whose clothes were those? 
Page 530 
1 
A. Well, 13, 14, 15, like eight years ago. 
2 
Q. Okay. So, this is 2010. We're talking 
3 
about 2002? 
4 
A. Yeah. 
5 
Q. Okay. So tell us about the venture that 
6 
you were forming with her? 
7 
A. I don't know what you're talking about. 
8 
Q. Well, you were thinking about something 
9 
because you said years ago. You were the one that 
10 
picked the date. So, what was it you were thinking 
11 
about? 
12 
A. No, I said years ago we, we knew each other. 
13 
We used to hang out. Like we used to do little girl 
14 
stuff, go in the pool and —
15 
Q. No, my question was, was there a business 
16 
venture and you said it was years ago. 
17 
A. It was years ago that I've known her. Any 
18 
type of business venture, not that I recall.
19 
Q. Have you ever told anyone at all that you 
20 
and 
were forming a business venture or had a 
21. 
business venture? 
22 
A. At 12, no, I don't — 
23 
Q. At any, I don't care, right up until 
24 
today. 
25 
A. No. 
9
(561) 832-7500 
PROSE COURT REPORTING AGENCY, 
8 (Pages 527 to 530) 
INC.' 
.(561) 832-7506 
Electronically signed by cynthia hopkins (601-061-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (001-061.976.2934) 
b55421ef.d299-4e4f-9bat3-85aad2714405 
EFTA01108859

Page 531 
1 
Q. Did you ever have any sort of a business 
2 
venture that involved in any way, shape, or form you 
3 
and/or her taking showers? 
4 
A. No. 
5 
Q. Did you ever tell anybody you did? 
6 
A. No. 
7 
Q. Did you ever have any literature or 
8 
written material describing such a venture? 
9 
A. Not that I recall, sir. 
10 
Q. Ever have anything that described such a 
11 
venture or any costs associated with procuring those 
12 
services if someone wanted to do that? 
13 
A. Taking showers? 
14 
Q. Well, taking showers or watching the two 
15 
of you take showers or any combination or 
16 
permutation that you can think of. 
17 
A. Not that I can think of unless we were like 
18 
stupid little girls who — I don't recall anything about 
19 
any shower or anything like that, no. 
20 
Q. Did you ever tell anybody that you had 
21 
such a business going? 
22 
A. No. 
23 
Q. Did you ever tell anybody you had such a 
24 
business going with someone other than e? 
25 
A. A business going, no. 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 532 
Q. I don't mean a formal thing, Did you ever 
tell anybody that you were involved in any kind of 
activity involving taking showers for which you got 
paid money? 
A. Definitely not. I don't — I have never. 
And when was the last time you talked to 
A. Oh, boy. It's been years. Ballpark three 
years maybe. 
Q. And where did you talk to her three years 
ago? 
A. At the trailer that I had an 
at. 
Q. Now, your other friend, 
A. Uh-huh. 
Q. — when is the first time that you can 
recall having done any type of a drug with..? 
A. When we first started seeing Jeffrey we tried 
to numb each other with like downers, you know, 
Percocets or something just to ignore really what was 
going on between Jeffrey and us. 
deposition you toll =
wn 
first took you 
at testimony? 
sir, a 
tha 
who we know to be 
to Jeffrey's. Do you recall 
A. Yes. 
(561) 832-7500 
1 
2 
3 
4 
5 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
23. 
22 
23 
24 
25 
Page 533 
Q. And you testified that she provided you 
with drugs? 
A. Yes. 
e Q. All right. Now, who provided the drugs to 
A. I have no clue. 
Q. Well, who provided the drugs to you that 
you just claim you took when you were with
A. I couldn't even say. Maybe, maybe 
Q. That's your boyfriend? 
A. At the time he was my boyfriend. 
Q. Well, he was your boyfriend. He became 
the father of your child, right? 
A. Yes. 
Q. Okay. I mean, that would qualify as a 
boyfriend, right? 
A. If that's what you call it 
Q. He was a drug dealer, wasn't he? 
A. No. 
MR. EDWARDS: Form. 
BY MR. LUTHER: 
Q. Did he provide drugs to you on more than 
one occasion? 
A. No, he, no, he, if anything, him and his 
Page 534 
1 
friends got together and they were stupid and young and 
2 
they did a couple of drugs, but I didn't want anything 
3 
to do with them until I met Jeffrey. And then I wanted 
4 
to numb myself to be around Jeffrey. And I know that I 
5 
would take drugs from him occasionally. 
6 
But he didn't like give them tome or sell 
7 
them to me or anything like that. 
8 
Q. Well, what did you do, go steal than from 
9 
him or what? 
10 
A. I would probably take him from his stash or 
11 
something but —
12 
Q. So, he had a lot of drugs? 
13 
A. No, not that I remember. I don't know where I 
14 
got these drugs from. To telLyau the truth, I really 
15 
don't recall. I don't blow if.. brought them. I 
16 
don't blow if I brought them. 
17 
Q. Well, did you give these drugs toe.? 
18 
A. No, not that I recall. 
19 
Q. One thing you knew was that these were 
20 
illegal drugs, right? 
21 
A. Yes. 
22 
Q. You knew it was against the law what you 
23 
were doing? 
24 
A. Yes, especially — Jeffrey Epstein knew it was 
25 
against2.11:jaw to be fondlin
 14-yearold girls 
g 
9 (Pages 531 to 534) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (601.061.976.2934) 
Electronically signed by cynthia hopkins (601.061.976.2934) 
Electronically signed by cynthia hopkins (601.061.976.2934) 
b5542fel-d299-4e4f-9ba6.85aad27,4405 
EFTA01108860

Page 535 
1 
too. 
2 
MR. LUTHER: Well, Jeffrey Epstein --
3 
move to strike as not responsive. 
4 
BY MR. LUTHER: 
5 
Q. What Jeffrey Epstein told you was that you 
6 
shouldn't drink and shouldn't do drugs, didn't he? 
7 
A. He told me that he never drank or did drugs. 
8 
He was so interested in what kind of drugs we were on. 
9 
Q. So, not withstanding what you knew to be 
10 
clear/y--
11 
A. He would ask, he would be asking us so how 
12 
does =make you feel, how does coke make you feel, 
13 
how does Percocets make you feel, how does this make you 
14 
feel. 
15 
Q. He never asked you to take any of those 
16 
drugs, did he? 
17 
A. No, but he would —
18 
Q. He never gave you any of those drugs. did 
19 
he? 
20 
A. No. 
21 
Q. And you claim he had all this money. He 
22, 
could have provided you with any drug he wanted if 
23 
he wanted to give you a drug, couldn't he? 
24 
A. I guess. 
25 
Q. And he never provided you with one single 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 537 
1 
A. Probably. 
all
ow, you remember going there with 
don't you? 
A. Yes, l do. 
Q. Two occasions you went and she went in the 
room with you, didn't she? 
A. She went in the room with me at the beginning, 
at the first time, yes. 
Q. Went in the room the second time too, 
didn't she? 
A. I, I think so. I'm not sure about that. 
Q. Are you aware that —
A. I bet you have pict 
huh. 
Q. Are you aware tha 
en deposed? 
A. Have been what? 
Q. Has been deposed, gone through the same 
process you are? 
A. Oh, yes, of course. She should be. 
Q. How are you aware of that fact? 
A. Excuse me? 
Q. How are you aware of that fact? 
A. Everybodys been deposed. Most all, most of 
all these girls have been deposed. 
Q. Who told you that? 
A. You know, the girls talk. 
Page 536 
1 
illegal drug and told you he never touched drugs? 
2 
A. No, but that's not his crime. He fondled me 
3 
when I was 13 years old. He didn't sell me drugs. 
4 
Sony, he just molested me. 
MR. LUTTIER: Move to strike. 
6 
BY MR. LUT17812: 
7 
Q. He never provided you with one illegal 
8 
drug, did he? 
9 
A. No. 
10 
Q. You went and got those all on your own? 
11 
A. Yes. 
12 
Q. You and your friends would go and take all 
13 
kinds of illegal drugs? 
14 
A. Yes, because I was scared to be around an old 
15 
man when he is touching my vagina and masturbating with 
16 
his cock in front me ejaculating all over himself, so 
17 
yes, I would, I think you would take drugs too. 
18 
Q. So, were you so scared that you said I'm 
19 
not going anymore? 
20 
A. He was like our master. He's like= 
21. 
master. He does, anything he says, we do 
22 
because we are intimidated by him. We were scared of 
23 
him. 
24 
Q. So, if he said run out in front of 
24 
25 
traffic, you would? 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
(561) 832-7500 
Page 538 
1. 
Q. Okay. 
2 
A. It get's around town and it's in the newspaper 
3 
every weekend, so how 
not know? 
4
Q. Did you talk to 
5 
A. No, I did not. 
6 
Q. Okay. So, how did you know al 
had 
7 
been deposed if she was deposed? 
8 
MR. EDWARDS: Object to the form to the 
extent —
THE WITNESS: Of course she's been 
deposed. 
MR. EDWARDS: Hold on. Hold on — to the 
extent that you're asking for attorney-client 
privilege information which you did —
MR. LUMER: No. 
MR. EDWARDS: - in the first deposition 
and it sounds like you're going there again — 
MR: LUTHER: I don't want to know 
anything your lawyer said. 
MR. EDWARDS: — about talking to my 
client 
BY MR. LUITIER: 
Q. I don't want to know anythi 
wyer 
said. Have you seen a transcript of 
10 (Pages 535 to 538) 
PROSE COURT REPORTING AGENCY, INC. 
(561) 832-7506 
Electronically signed by Cynthia hopkins (601-051.976.2934) 
Electronically signed by cynthia hopkins (601.051.976-2934) 
Electronically signed by cynthia hopkins (601.051-976-2934) 
b5542fehc1299-041-9ba6-85aad27f4405 
EFTA01108861

Page 539 
1 
MR. EDWARDS: Object to the form. If she 
2 
has seen a transcript, that would obviously 
3 
being something that her attorney has shown 
4 
her. That is not something she would have seen 
5 
independent of that. So that would be 
6 
protected information. 
7 
MR. LUTITER: I, I mean, I don't think —
8 
I think if you show her a copy of a deposition, 
9 
that is not protected by attorney-client 
10 
privilege. If you had a discussion with her, I 
11 
agree with you, whatever your discussions were. 
12 
But the fact that you showed her the transcript 
13 
I don't think is protected by the privilege. 
14 
BY MR LUTTIER: 
15 
Q. Havesher seen a co y of the 
16 
transcript of 
deposition? 
17 
A. Not that I Icnow o 
18 
Q. Well, did u know that -- or strike that 
19 
as 
and 
20 
were wit 
.Epstein on t e secon 
21 
occasion when she took you there, isn't it true that 
22 
you began a conversation with Jeffrey discussing 
23 
what you and your mother did and how much you 
24 
charged for various things? 
25 
A. False. 
Page 
1 
A. Am I religious? 
2 
Q. No, do you have a religious affiliation? 
3 
'Are you associated with a particular faith? 
4 
A. Yes. 
5 
Q. Protestant, Catholic, Jewish? 
6 
A. Yes, I am. 
7 
Q. What faith would that be? 
8 
A. I believer in Jesus Christ. 
9 
Q. Any particular organized -- do you know 
10 
what I mean by organized religion? There's, theres 
11 
a bunch — 
12 
A. !would Ince to call myself a Christian but 
13 
believe that the Lord, Catholics, Jews, Buddhism, it 
14 
doesn't matter because it shouldn't be judged. It 
15 
shouldn't be organized. The Lord doesn't — the Lord 
16 
doesn't organize anything. I just know that I am, I am 
17 
very spiritual and I do love the Lord very much. 
18 
Q. Okay. So you would characterize yourself 
19 
just as a, for lack of a better term Christian? 
20 
A. lam very spiritual. 
21 
Q. Okay. 
22 
A. And I pray every day. 
23 
Q. Do, do you participate it an organized 
24 
religion? 
25 
A. Do I go to church? 
Page 540 
1 
Q. Sexual nature. 
2 
A. No. 
3 
Q. Is there any reason why 
4 
would want to make that story II. 
5 
MR. EDWARDS: Object to the form. 
6 
THE WITNESS: I have no idea. 
7 
BY MR. LUTTIER: 
8 
Q. And isn't it true that when you began — 
9 
A. She knew Jeffrey more than I did. 
10 
Q. Well, didn't -- 
11 
A. This is the first time or second time I had 
12 
ever been with Jeffrey. I didn't tell him anything; 
13. 
only the questions he asked nte. 
14 
Q. And, and isn't it true that when you began 
15 
to talk to Mr. Epstein and discuss with him what you 
16 
and your mom did and the prices you would charge for 
17 
things that Mr. Epstein asked Ms. 
to leave 
18 
the room? 
19 
A. I don't even know why my mother is brought up 
20 
in this because, no, I would never talk about my mother 
21 
as being a prostitute. She did not raise me like that. 
22 
My mother is a very beautiful person inside and out and 
23 
she would never raise me like that. 
24 
Q. By the way, what is your — do you have a 
25 
religious affiliation? 
(561) 832-7500 
PROSE 
Page 542 
1 
Q. Yeah. 
2 
A. Yes. 
3 
Q. And where did you go? 
4 
A. I've been to Christ Fellowship. I've been to 
5 
First Baptist. 
6 
Q. When was the last time you were at Christ 
7 
Fellowship? 
8 
A. In December '08. 
9 
Q. And where did you go, for Christmas? 
10 
A. Before Christmas. 
11 
Q. Okay. And when was the last time you were 
12 
at First Baptist? 
13 
A. Maybe September '08. 
14 
Q. Okay. Are you members of either of those 
15 
churches or you just went to them? 
16 
A. If you want to call me a member, I — 
17 
Q. Are you a registered in them?
18 
A. — I attend, I attend Christ Fellowship, yes. 
19 
Q. Do you attend it with some degree of 
20 
regularity? 
21 
A. Yes. 
22 
Q. And how often? 
23 
A. As often as I can. 
24 
. 
Q. Okay. Well, I mean, I don't want to pin 
25 ~rou 
ecific
er of days, 
many
11 (Pages 539 to 542) 
COURT REPORTING AGENCY, INC. 
(561)'832-7506 
Electronically signed by cynthia hopkins (601451.976-2934) 
Electronically signed by cynthia hopkins (601451-976-2934) 
Electronically signed by cynthia hopkins (601-051476-2934) 
b5542lef-d299-4c41-9ba6-85aad2714405 
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Page 543 
1 
days a month would you say on average you go? 
2 
A. As of tight now, one, unfortunately. 
3 
Q. And when you say unfortunately, are you 
4 
unable to go more days? 
5 
A. No, I would love to go more days. 
6 
Q Okay. Was there something that prevents 
7 
you from going more days? 
a 
A. I have a busy life. 
9 
Q. Okay. What is it that you're doing that 
10 
prevents you from going more days. 
11 
A. Well, lam trying to get my son enrolled into 
12 
Christian school, and there's a lot of bills that need 
13 
to be paid and things that need to be done, errands that 
14 
need to be ran, clothes that need to be washed, food 
15 
that needs to be bought, time I need to spend with my 
16 
son. 
17 
Q. So, it's errands and clothes, laundry, 
16 
purchasing groceries and stuff, and time with your 
19 
son that prevents you from being able to attend more 
20 
frequently; is that right? 
21 
IVIR. EDWARDS: Object to the form. 
22 
THE WITNESS: Stn. 
23 
BY MR LUTHER: 
24 
Q. You set your own work hours, right? 
25 
A. Yes. 
Page 545 
1 
A. You guys have been there before. You should 
2 
know. 
3 
Q. It's the same house she's always lived in? 
4 
A. No. She hasn't lived there her whole life. 
5 
Q. Okay. But I mean while you were a kid, 
6 
when, when you were living with her; is it the same 
7 
place that she lived in? 
8 
A. No. 
9 
Q. How long has she been living where she is 
10 
now? 
11 
A. I don't know. There's been a couple of years 
12 
that my mother and I haven't talked. 
13 
Q. Well, when was the last time you talked to 
14 
your mother? 
15 
A. Today. 
16 
Q. And, and when did you talk to her? 
17 
A. This morning. 
18 
Q. And why did you talk to her this morning? 
19 
A. So she could pray with me over the phone. 
20 
Q. And when was the last time you talked to 
21. 
her prior to this morning? 
22 
A. Last night 
23 
Q. Did I misunderstand? I thought you said 
24 
there was a - 
25 
A. There was a period in my life that we didn't 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
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Page 544 
Q. Your mother i 
and I may get 
this name sort of 
is it? 
A. Yeah. 
Q. Did I pronounce it right? 
A. No. 
Q. Ilow you do pronounce that? 
A. 
. And is she currently married? 
A. No. Can I have a tissue? 
Q. And where does she currently live? 
A. In Palm Beach Gardens. 
Q. In what development? 
A. I don't know what the development's called. 
MR. EDWARDS: Can we take a split second 
break to take grab a tissue? 
MR. LUTTIER: Sure. 
MR. EDWARDS: I don't see one right now. 
THE VIDEOGRAPHER: Going off the record at 
228 pm. 
(A brief recess was held.) 
THE VIDEOGRAPHER: We're back on the 
record at 2:32 p.m. 
BY MR. LINTER: 
Q. Okay. You're saying you don't know the 
development that she lives in Palm Beach Gardens? 
Page 546 
1 
talk. 
2 
Q. Okay. So that's some past period of time? 
3 
A. Yes. 
4 
Q. When did that change? 
5 
A. Around May '09. 
6 
Q. And what is it that caused the change in 
7 
May of '09? 
8 
A. I was living my life and she was living hers. 
9 
Q. What does that mean? 
10 
A. I was living my life and she was living hers. 
11 
Q. Okay. Why did that, why did that 
12 
facilitate — 
13 
A. She was taking care of my sister that has 
14 
diabetes and they were going through a lot, so I left it 
15 
alone. 
16 
Q. My question was what caused in May of '09 
17 
this period of estrangement between you and your 
18 
mother to end? 
19 
A. I just told you. 
20 
Q. You said that your mother — 
21 
A. My mother and I, she had — my mother was 
22 
taking care ofkiter who has severe diabetes. 
23 
Q. That's 
7
24 
A. Yes. 
25 
S. Oka 
You mean duri 
our 
riod of 
(561) 832-7500 
12 (Pages 543 to 546) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by cynthia hopkins (601.051-976-2934) 
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Page 549 
Page 547 
1 
estrangement? 
2 
A. Yes. 
3 
Q. Okay. So, you didn't communicate with her 
4 
because she was taking care of your sister? 
5 
A. Yes. 
6 
Q. Did something happen in May of '09 that 
7 
changed all that? 
8 
A. My sister moved away. 
9 
Q. And where did she go to? 
10 
A. Orlando. 
11 
Q. And, and when she moved, did she go with a 
12 
boyfriend? 
13 
A. Yes. 
14 
Q. And who is that? 
15 
A. Rs name is David. 
16 
Q. Do you know his last name? 
17 
A. No. 
18 
Q. And she's still living in Orlando? 
19 
A. Yes. 
20 
Q. Now, what's the relationship between you 
21 
and your sister? 
22 
A She's, she has like she's a little slow, so 
23 
we can't really relate but other than that I love her. 
24 
Q. Well, haven't you in the past been violent 
25 
toward your sister? 
Page 548 
A. Yeah. 
2 
Q. And tell us exactly what you did to your 
3 
sister. 
4 
A. Well, when I was 14, 15, 14,1 was like 
5 
mentally abusive to her because I guns I was just 
taking out everything, all of my pain from what was 
7 
going on with Jeffrey, and I would just take it out all 
8 
on her. 
9 
Q. What do you mean by you would take it out 
10 
on her? 
11 
A. I was mentally abusive to her. 
12 
Q. Well, describe what it is you actually 
13 
did. 
14 
A. She stuttered; l would make fun of her. She 
15 
has diabetes; I wouldn't respect it. 
16 
Q. And did your sister actually have to get a 
17 
restraining order against you? 
18 
A. No. 
19 
Q. Did your sister ever get a restraining 
20 
order against you? 
21 
A. Not that I know of. She's slow. She's not 
22 
all there. She has like part autism. 
23 
Q. Now, did your mother discuss with you 
24 
about whether she ever had any discussions about you 
25 
withanybodyelse? 
(561) 832-7500 
1 
A. Excuse me? 
2 
Q. Did your mother ever discuss with you 
3 
whether she had any conversations about you with 
4 
anybody else with respect to this lawsuit? 
5 
MR. EDWARDS: Is this in addition or 
6 
different than the previous discussion that was 
7 
discussed at the first deposition? 
8 
MR. LUTHER: I won't know until she 
9 
answers it. 
10 
MR. EDWARDS: But is this a separate 
11 
occurrence from what she was asked at the last 
12 
deposition? 
13 
THE WITNESS: No, she's never discussed 
14 
anything else with anyone else, no. 
15 
BY MR. LUTHER: 
16 
Q. Okay. 
17 
A Not to my knowledge. 
18 
Q. And if your mother told anybody that 
19 
historically as a child you used Xanax, would she be 
20 
telling the truth? 
21 
A. Yes. 
22 
Q. Do you who• 
23 
A. Yes, Id°. 
24 
Q. And who is that? 
25 
A. Her current boyfriend. 
is? 
Page 550 
1 
Q. And do you believe him to be a truthful 
2 
individual? 
3 
A. Yes. 
4 
Q. And how long has he known your mother? 
5 
A. For 15 years. 
6 
Q. Do you know of anything he has told 
7 
anybody else about what it is your mother used to do 
8 
fora living? 
9 
A. No. 
10 
Q. Is the first time that you've heard any 
11 
reference to your mother being a prostitute in this 
12 
case? 
13 
A. No. 
14 
Q. When else have you heard that? 
15 
A. I have never heard that my mother was a 
16 
prostitute. 
17 
Q. So, what I am saying is, is the first time 
18 
that you have heard that issue even come up in this 
19 
case? 
20 
A. This is the first time 1 am hearing this, yes. 
21 
Q. Did you discuss with your mother the 
22 
activities you were engaging in with Mr. Epstein at 
23 
the time that you were engaging in them? 
24 
A. I kept everything a secret until years later 
25 
when after I had my son and then 1 told her what went j 
13 (Pages 547 to 550) 
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Electronically signed by cynthla hopkins (601-051-976-2934) 
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b55421cf-d299-4e4(-9ba6-85aad2714405 
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Page 551 
1. 
on. 
2 
Q. Earlier you said at 15 you worked for 
3 
Jamie's photo studio? 
4 
A. Yes. 
5 
Q. And my notes are unclear. I believe I 
6 
asked you, did you tell them how old you were. Do 
7 
you remember me asking you that question? 
8 
A. (Witness nods head). 
9 
Q. And what did you respond? 
10 
A. I told the.m1was 19. 
11 
Q. Okay. Did you provide them with any kind 
12 
of proof? 
13 
A. No. 
14 
Q. And why did you lie to them and tell them 
15 
you were 19 if you were really 15? 
16 
A. Because! wouldn't be able to work there. 
17 
Q. Did you tell other people that you were 
18 
older than you really were? 
19 
A. Yes. 
20 
Q. Who else did you tell you were older than 
21 
you really were? 
22 
A. Probably everybody I came across. 
23 
Q. So, that would be many people? 
24 
A. Yes. 
25 
Q. All of the various adult entertainment 
1 
2 
3 
4 
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9 
10 
11 
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Page 553 
THE WITNESS: I worked at Jamie's photo 
studio. Once I turned 18, I told everybody my 
BY MR. 
MR. LUTHER: 
Q. Well, you worked at a place called Cabaret 
when you were 14, didn't you? 
A. Curves Cabaret. I told them I was 19 as well. 
Q. When you were how old, 14? 
A. Yes. 
Q. Okay. And then what, what was the next 
place you did, you went to do topless dancing? 
We'll do jack shacks separate front topless dancing. 
A. I don't know. I worked at Curves Cabaret when 
I was 14. I worked at Jamie's photo studio when I was 
15, and I worked for Jeffrey throughout all those years. 
Q. You worked fora lot of other places 
besides Jamie's photo studio and Curves Cabaret, 
didn't you? 
A. Not when 115. 
Q. Well, I want to start there and keep on 
Pin& 
A. We already know the places I've worked at. 
We've been through this. We've went through this for 
the last deposition. 
Q. That's why — 
Page 552 
1 
places you worked at. The places, the topless bars 
2 
you worked at, did you tell all of them you were 
3 
older than you really were? 
4 
A. The period of time when I worked at Jamie's 
5 
photo studio, I told everyone 1 was 19. Jeffrey knew 
6 
how old I was. And Jeffrey new how old every girl I 
7 
brought there was, and he wanted young girls all the 
8 
time. 
9 
Q. Does that have anything to do with the 
10 
question that I asked? 
11 
MR. LUTT1EFt: I move to strike. 
12 
THE WITNESS: The question you asked has 
13 
nothing do with Jeffrey. 
14 
MR. L1JTTIER: Let's, let's go back. If 
15 
you will read the question that I asked. If 
16 
you will listen to this question, that's the 
17 
one I would like you to answer. 
18 
TILE WITNESS: I know you guys love to get 
19 
paid but — 
20 
(The requested portion of the record was 
21 
read by the reporter.) 
22 
THE WITNESS: At what period of time? 
23 
MR. LUTTIER: At any time. From the time 
24 
you first worked at one to the last time you 
25 
worked. 
(56]) 832-7500 
Page 554 
1 
A. And we've already been through this for this 
2 
deposition. 
3 
Q. — I am giving you the chance to 
4 
sturunarize, so let's just go down and —
5 
A. You already know the places I worked. 
6 
Q. I am asking you as to each one, how old 
7 
you told them you were. 
8 
A. When 1 was underage, I told them I was 19 
9 
years old. 
10 
Q. Every place that you worked? 
11 
A. Yes. Except Jeffrey's, Jeffrey knew that I 
12 
was 13. I'm sick of this. 
13 
Q. So, at Abby's you told them 19. Is that 
14 
just the number you picked? 
15 
A. On advice of counsel I am invoking my Fifth 
16 
Amendment rights under the United States constitution. 
17 
MR. EDWARDS: Do you want to take a break 
18 
or are you all right? 
19 
MR. LIMIER: Yeah, do you want to take a 
20 
break.? 
21 
THE WITNESS: No. I want to get this done 
22 
and over with. lam sick of it. Jeffrey is —
23 
it's disgusting. 
24 
BY MR. LUTTIER: 
25 
Q. Flirts you told them you were 19? 
14 (Pages 551 to 554) 
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(561) 832-7506 
Electronically signed by Cynthia hopkins (601-061-976-2934) 
Electronically signed by cynthia hopkins (601.051-976-2934) 
Electronically signed by Cynthia hopkins (601-051-976.2934) 
b5542101-d299-4e41-9ba6.65aad27(4405 
EFTA01108865

Page 555 
A I was — on advice of counsel, l am invoking 
2 
my Fifth Amendment rights under the United States 
3 
Constitution. 
4 
Q. Lennie's, whatever, Laurie's, whatever it 
5 
was, you told them you were I9? 
A. Lauren's. 
Q. Lauren's, whatever. 
A. I was of age. 
9 
Q. Okay. How about when you were at Pure 
10 
Platinum, were you of age then? 
11 
A. Pure Platinum. 
12 
Q. Platinum Showgirls? 
13 
A. Yes, I was of age. 
14 
Q. And how about Elegance Day Spa, were you 
15 
of age then? 
16 
A. On advice of counsel I invoke my Fifth 
17 
Amendment rights under the United States Constitution. 
18 
Q. Did you work at Elegance Day Spa? 
19 
A. On advice of council I'm invoking my Fifth 
20 
Amendment rights under the United States Constitution. 
21 
Q. And what work did you do at Elegance Day 
22 
Spa? 
23 
A. I'm over this shit. 
24 
MR. EDWARDS: Let's take a break. 
25 
THE WITNESS: No. On advice of counsel I 
1 
a — 
2 
A. 
3 
Q. 
4 
A. 
5 
Q. 
6 
A. 
Yes. 
— store? 
Yes. 
And that was upsetting to you? 
Yes. 
Page 557 
7 
Q. Why was it upsetting to you? 
8 
A. i was trying to say hello
 
sa
little sister 
9 
who was three at the time. And 
was mad at my 
10 
father and she didn't want me talking to my little 
11 
sister. So, she doesn't know the American rights 
12 
because she's from Mexico and she totally mazed me when 
13 
I was trying to hug my little sister. 
14 
(Mr. Goldberger entered the deposition 
15 
room.) 
16 
THE WITNESS: Utast hope Jeffrey gets 
17 
what he deserves. 
18 
BY MR. LUTTIER: 
19 
Q. And what's that, Ma'am? 
20 
A. Punishment for putting us girls through all 
21 
this. 
22 
Q. That is those things that you are talking 
23 
about the times that you elected to go back to his 
24 
house and get paid to give him massages? 
25 
A. He demanded us to over the phone, sir. 
Page 556 
1 
am invoking my Fifth Amendment rights under the 
2 
United States Constitution. 
3 
BY MR. LUTHER: 
4 
Q. Are you fearful that you're going to be 
5 
prosecuted for something about Elegance Day Spa? 
6 
A. No. 
7 
Q. So, well then, what are you asserting the 
8 
Fifth Amendment for? 
9 
A. Because I want to. 
10 
Q. Because what? 
11 
A. Because I want to. 
12 
MR. EDWARDS: Listen, don't engage with 
13 
him. Just read. 
14 
BY MR. LUITIER: 
15 
Q. Do you know 
16 
(phonetic). 
17 
A. I know a 
18 
Q. Okay. And who is that? 
19 
A. My step-mother. 
20 
Q. Married to your father,_? 
21 
A. Yes, sir. 
22 
Q. And have you had a confrontation with her? 
23 
A. What kind of confrontation is this now? 
24 
Q. Did you ever have a confrontation with 
25 
here physical confrontation in the parking lot of 
(561) 832-7500 
Page 558 
1 
Q. But nobody made you do it, right? 
2 
A. No. But Jeffrey demanded us for us to do it. 
3 
And as young girls we were scared ofJeffrey. And you 
4 
'mow what, be will get what be deserves. 
5 
Q. Let's see. You lived out Okeechobee by 
6 
Drexel Road? 
7 
A. Yes, I did. 
8 
Q. He lived in Palm Beach? 
9 
A. Yes. 
10 
Q. How many miles was it, would you say 
11 
between those two houses? 
12 
A. I don't know, five, six. 
13 
Q. And you didn't, you didn't have a car 
14 
because you weren't driving, right? 
15 
A. No. He sent taxies to my house to come get 
16 
me. 
17 
Q. So, then you could have said I am not 
18 
getting in any of the taxies you wanted me to. You 
19 
could have said I'm not going, just like a bunch of 
20 
your friends did, right? They said after, boom, I 
21 
don't want to go anymore, right? 
22 
A. I could have said no. 
23 
Q. As a matter of fact you had friends that 
24 
you took, you found them, Jeffrey Epstein didn't 
25 
find them, you found them. 
 J 
15 (Pages 555 to 558) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by cynthia hopkIns (601-051-976-2934) 
Electronically signed by cynthia hopkIns (601-051.976.2934) 
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Page 559 
1 
A. Yeah. Because he wanted me to find them. He 
2 
said you better find me a girl the next day, or I am not 
3 
going to call you anymore. 
4 
Q. And you took them to Jeffrey Epstein's and 
5 
you told them don't worry, this is what's going to 
6 
happen, ifs easy money, right? 
7 
A. Yeah, because I was tried of Jeffry. 
8 
Q. And some of those girls went one time and 
9 
said they didn't want to go back, right? 
10 
A. Correct. Because they ;we afraid of Jeffrey. 
11 
Q. And you could have done the same thing, 
12 
couldn't you? 
13 
A. Correct. 
14 
Q. But you wanted the money? 
15 
A. I was a poor little girl who couldn't even 
16 
afford a pair of shoes, yes. 
17 
Q. You wanted the money? 
18 
A. Yes. 
19 
Q. And net only did you want the money but 
20 
you wanted to make money taking other girls there? 
21 
A. Yes. 
22 
Q. Now, you allege in your complaint that's 
23 
the, the pleadings that you have filed in this case, 
24 
that you have suffered physical injury and a bunch 
25 
of other things. What physical injury have you 
1 
2 
3 
4 
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7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
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22 
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Page 561 
mental damage, and red marks on you as a result of 
anything that Jeffrey Epstein did, if any? 
A. Physical? 
Q. Yes, physical. 
A. Not mentally --
Q. I am going to come to that. 
A. — or psychologically? 
Q. Physical injury. 
A. Physically, well, now I can't — lam not even 
anormal person anymore. My mentality is totally 
different. 
Q. So, how does that --
A. I was molested for years. 
Q. How does that physically evidence itself? 
A. I don't know. You tell me. You get molested 
for years and tell me how you feel. 
Q. Well, I'm asking you, you're the one that 
filed the complaint and alleged that you have 
suffered physical injuries in the past. You've told 
us that --
A. If you're asking me if the guy has ever hit 
me, no. 
Q. No. I am asking you —
A. Smacked me on my butt a couple times. 
Q. I need to find out what you are alleging 
Page 560 
1 
suffered in the past as a result of anything that 
2 
Jeffrey Epstein did? 
3 
A. Stress, my heart, mental damage. 
4 
Q. My other physical injury? 
5 
A. Besides the red marks he would leave on my 
6 
pussy. 
7 
Q. And how would he do that? 
8 
A. He left red mutts on my vagina with his 
9 
fingers, with his vibrator. 
10 
Q. And how did that injure you? 
11 
A.  Well, it kind of hurt. 
12 
Q. Did you tell him that? 
13 
A. No. I was scared to tell him anything that he 
14 
didn't want to hear. 
15 
Q. Did you seek medical treatment for that? 
16 
A. No. 
17 
Q. What other physical injury do you allege 
18 
you suffered as a result of anything that Jeffrey 
19 
Epstein did? 
20 
A. Stress, stress, and more stress. 
21 
Q. Anything else? 
22 
A. No. 
23 
Q. Do you allege that -- and I should break 
24 
that down. What physical injuries due you allege 
25 
you suffered in the past other than stress heart, 
561 ) 832-7500 
Page 562 
1 
so I can defend it. So, what physical injuries, if 
2 
any, other than stress, heart, mental damage and red 
3 
marks? 
4 
MR. EDWARDS: Objection, asked and 
5 
answered. 
6 
BY MR. LUTHER: 
7 
Q. inhere isn't any, fine. If there is 1 
8 
want to get them that's all. Do you know of any 
9 
others? 
10 
A. No. 
11 
Q. All right. You allege that you're going 
12 
to suffer in the future physical injury that's 
13 
physical injures that you haven't suffered yet. 
14 
Well, what physical injury do you allege you will 
15 
suffix in the future as a result of anything that 
16 
Jeffrey Epstein did? 
17 
A. Fucking heart attack. 
18 
Q. Heart attack. Anything else? 
19 
A. Mental stress. 
20. 
Q. Mental stress. Anything else? 
21 
A. All day, every day. My son is going to suffer 
22 
from it beranse I'm suffering from it. 
23 
Q. Okay. And you're son is going to suffer 
24 
from what? 
25 
A. He can feel his mother's stress. 
16 (Pages 559 to 562) 
PROSE COURT REPORTING AGENCY, INC. 
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Electronically signed by cynthia hopkins (601.051-976-2934) 
Electronically signed by cynthia hopkins (601-051-976-2934) 
Electronically signed by cynthia hopkins (601.051-976-2934) 
b55421of-d299.4c41-9ba6-85aad2714108 
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Page 563 
1 
Q. Any, anything else? 
2 
A. Physically, no. 
3 
Q. All right. Have you obtained any medical 
4 
care or treatment in the past for any physical 
5 
injury that you allege you suffered as a result of 
6 
anything Jeffrey Epstein did? 
7 
A. No. He told me if I tell anyone what is going 
8 
on it's going to be, I'm going to be in trouble. So, I 
9 
would not dare tell anybody what Jeffrey did to me. 
10 
• 
Q. Did you ever go to any doctor or healer of 
11 
any kind, person, whether it was a chiropractor or 
12 
anything else, with respect to treatment of any 
13 
injury that you allege you suffered in the past as a 
14 
result of anything that Jeffrey Epstein did? 
15 
A. In the past? 
16 
Q. Yep. 
17 
A. No. 
18 
Q. Have you incurred any medical expense at 
19 
all as a result of any physical injury you allege 
20 
you suffered in the past as a result of anything 
21 
Jeffrey Epstein did? 
22 
A. No, but he still molested me for years. 
23 
Q. He what? 
24 
A. He still molested me for years. Sony he is 
25 
not a physical abuser, you know, or a whatever, a 
1 
2 
3 
4 
5 
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8 
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10 
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13 
14 
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17 
18 
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23 
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Page 565 
responsive. Please, listen to the question. 
The court reporter is going to read it back and 
just answer my question. 
(The requested portion of the record was 
read by the reporter.) 
THE WITNESS: No. 
BY MR. LUTTIER: 
Q. Has any person with professional knowledge 
or expertise told you that you're going to suffer 
mental stress in the future as a result of anything 
Jeffrey Epstein did? 
A. Yes. 
Q. Who? 
A. 
Q. 
? 
A. 
n 
P 
ow 
E 
her last name, but she's a 
counselor. 
A. frier 
name? 
Q. Victim's Services lady? 
A. Yep. 
Q. And when did you see her last? 
A. I don't know the dates, sir. 
Q. Well, in last year? 
A. Yep. 
Page 564 
1 
violent, you know — 
2 
Q. Have you gone --
3 
A. - VA)111231beater. 
4 
Q. Have you gone to any doctor at all with 
5 
respect to any physical injury that you allege you 
6 
suffered in the past as a result of anything that 
7 
Jeffrey Epstein did? 
8 
A. No. Because I was afraid of the man. I 
9 
didn't know what he would do to me. He was powerful to 
10 
me. He was like a master to me. Anything he said I 
11 
would do. 
12 
Q. Now, you allege that the physical injury 
13 
you're going to receive or you're going to suffer in 
14 
the future is a heart attack. Has any person with 
15 
professionalized, with professional knowledge or 
16 
experience told you that you're going to suffer a 
17 
heart in the future because of anything that Jeffrey 
18 
Epstein did? 
19 
A. Anybody that knows that so much stress and so 
20 
much heartache each and every day worried about what you 
21 
are doing and worried about, you know. who, how this guy 
22 
managed me in the past, that's stress. And yeah, you 
23 
can definitely suffer from a heart attack or a stroke or 
24 
panic attacks, anything. 
25 
MR. LUTTlER: Move to strike. Not 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
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13 
14 
15 
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17 
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19 
20 
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Page 566 
Q. Did you say, yes? 
A. Yes. 
Q. How many times --
A. Not 2010 but '09. 
Q. '09? How man times did you see her? 
A. And 
i 
has told me the same thing. 
Q. How 
es 
r 
av 
ie you see her in '09? 
A. Three. 
Q. Do you go with any degree of regularity? 
A. No, but I'm going to. 
Q. Have you gone to her -- how many times 
have ou gone in total to her, that is 
.tir.ft times. 
Q. And the last time was sometime in '09? 
A. Yes. 
Q. When was the first time? 
A. '09, I guess, or '08, '08. 
Q. And then you sec' 
last time you saw 
A. In '09. 
Q. How many times have you seen her? 
A. Three. 
Q. When was the first time? 
A. In '09. 
When was the 
(562) 832-7500 
17 (Pages 563 to 566) 
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Page 567 
1 
Q. Okay. And I believe at the last 
2 
deposition you said you had seen her twice. Do you 
3 
recall that? 
4 
A. Yeah. I saw her three times though. 
5 
Q. Okay. So, you have seen her one more 
6 
time? You have seen her once since your deposition 
7 
on September 24th '09? 
8 
A. Yes. She came to my house. 
9 
Q. Since September 24th '09? 
10 
A. Since September 24th. 
11 
Q. And for what reason — I can't hear what 
12 
you're saying. Did you say she did come to your 
13 
house since September 24th, '09? 
14 
A. I don't know the dare, sir, but I did a whole 
15 
psychological paper. 
16 
Q. Well, last time in your deposition you 
17 
testified you had seen her twice. That one time you 
18 
saw her on Clematis —
19 
A. Yeah. 
20 
Q. — in somebody else's office and you 
21 
thought you had done some sort of evaluation. Do 
22 
you recall that testimony? 
23 
A. Yes. 
24 
Q. All right. That, that would have been one 
25 
time. That was the second time. Where, where did 
Page 569 
1 
Clematis Street? 
2 
A. That's the last time I saw her. She came to 
3 
my house. 
4 
Q. Okay. So, she's been to your house twice? 
5 
A. From what I recall, yeah, but I can't 
6 
remember. 
7 
Q. Did she go to the apartment that you live 
8 
in now? 
9 
A. Yes. 
10 
Q. Previously, did she come out to a trailer 
11 
where you live, or did she come to the same 
12 
apartment that you live —
13 
A. I don't live in a trailer. 
14 
Q. So, both times that she came to your house 
15 
she's come to the apartment that you live in now? 
16 
A. Yes, if she came two times. I might have saw 
17 
her two times or I might have saw her two, three, who 
18 
cares? 
19 
Q. For the last, on the last —
20 
A. You drive me crazy. 
21 
Q. — time she came for what purpose did she 
22 
come? 
23 
A. For an evaluation to counsel me. 
24 
Q. Well, are those things in your mind the 
25 
same? 
Page 568 
1 
you see her the very first time? 
2 
A. In the office. 
3 
Q. Whose office? 
4 
A. Her's. 
5 
Q. Where is that? 
6 
A. The place you just named. 
7 
Q. Well, an office on Clematis? 
8 
A. Yes. 
9 
Q. All right. So, you saw her there once and 
10 
then you went back and saw her at that same office 
11 
the second time on Clematis Street? 
12 
A. I think I had to go back there. It might have 
13 
been two times. I'm not sure, sir. She saw me at my 
14 
house either once or twice at my house and then either 
15 
once or twice at that office. 
16 
Q. Well, when you say she saw you at your 
17 
house, was that, I believe, and your memory may be 
18 
different than mine or better. I believe you 
19 
testified at your last deposition that one time she 
20 
came out to your house and one time you saw her at 
21 
an office on Clematis Street that was somebody 
22 
else's office that she was borrowing? 
23 
A. Yes. 
24 
Q. Okay. Now, have you seen her since that 
25 
visit thatru had with her in the office on 
(561) 832-7500 
PROSE COURT REPORTING 
Page 570 
1 
A. No. 
2 
Q. Okay. So, did she come to do an 
3 
evaluation or did she come to give you counseling? 
4 
A. Both. 
5 
Q. How long was she there? 
6 
A. Fora few hours. 
7 
Q. Have you had any communication with her 
8 
other than those three occasions that you say she 
9 
visited with you? 
10 
A. She sent me a Christmas card. 
11 
Q. Have you received treatment from any 
12 
mental health specialisalathan assuming there 
13 
was any treatment by 
Any other 
14 
psychologist, psychiatrist? 
15 
A. No. But you're damn right I will after this. 
16 
Q. And you last saw Mr. Epstein in 2005? 
17 
A. I went to his house pregnant when I was --
18 
2006, or no,I was pregnant. I had my son 2005, and 
19 
then I went to his house after I was pregnant 
20 
Q. I believe you told us in the last 
21 
deposition the latest you could have seen him was 
22 
September of '05. Are you changing that or is that 
23 
correct? 
24 
A. Sir, you know what, when people go through a 
25 
lot of drama in their life, they h
ot to really 
18 (Pages 567 to 570 
AGENCY, INC. 
(561) 832-7506 
Electronically signed by cynthia hopkins (601-051.976.2934) 
Electronically signed by Cynthia hopkins (601451-976-2934) 
Electronically signed by cynthia hopkins (601-0514164934) 
b55421ef-d299-4c41-9ba6.85aad2714405 
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Page 571 
1 
recall a lot of stuff but I know I saw him after I had 
2 
my son. 
3 
Q. Well, you had your son June 29th '05, 
4 
right? 
5 
A. Yes. So, it could have been July, August, 
6 
September, October, November, December. Then maybe it 
7 
could have went on to '0,'06. 
8 
Q. Well, do you know? 
9 
A. I'm not positive but I know that I went there 
10 
after I was pregnant. 
11 
Q. That's all you --
12 
A. That's al can tell you. 
13 
Q. All right. 
14 
A. And he didn't want me because he doesn't like 
15 
women that had a kid regardless of what their age is. 
16 
So, I had to bring another girl. 
17 
Q. And that was upsetting to you? 
18 
A. No. 
19 
Q. You thought you were his favorite girl at 
20 
one point? 
21. 
A. No. 
22 
Q. That's what you told us in the last depo, 
23 
didn't you? 
24 
A. I told I was his favorite girl? 
25 
Q. That you thought you were special and you 
Page 573 
1 
Q. Is that November, December? 
2 
A. Maybe. 
3 
Q. Who did you go to? 
4 
A. I went to a cardiac specialist center. I 
5 
don't know what it's called. 
6 
Q. What's the doctor's name? 
7 
A. I have no idea. 
8 
Q. Did you go to a hospital? 
9 
A. No, but they put patches all over my heart and 
10 
a monitor to monitor my heart. 
11. 
Q. And, and, and why did you go? What were 
12 
your symptom? 
13 
A. I have panic attacks all the time. I'm always 
14 
stressed out. I'm depressed. 
15 
Q. And what, what if anything, what if any 
16 
treatment did the doctor render to you? 
17 
A. I ended up not going back because I didn't 
18 
have enough money to pay for that. 
19 
Q. Well, what do you mean you didn't have 
20 
enough money? 
21 
A. What don't you understand about that? 
22 
Q. Well, how much did it cost? 
23 
A. A lot of money. 
24 
Q. How much? 
25 
A. A lot of money. More than grands. 
Page 572 
1 
were his favorite girl? 
2 
A. He made me feel special. He made me feel like 
3 
I was his favorite girl. 
4 
Q. And it upset you when you found out there 
5 
were other people going? 
6 
A. Did it upset me? 
7 
Q. Yeah. 
8 
A. No. 
9 
Q. So, for the last four years, a little bit 
10 
more than four years, the only person you've seen 
11 
with respect to any alleged mental illness or harm 
12 
has been 
and 
who was 
13 
provided by the Victim Services Bureau of the State 
14 
Attorneys office? 
15 
A. Yes. 
16 
Q. Have you gone to any cardiologists or any 
17 
physician specializing in --
18 
A. Yes, I have. 
19 
Q. Who did you go to? 
20 
A. A place in Wellington to see if my heart was 
21 
okay. 
22 
Q. When was that? 
23 
A. The end of '08. 
24 
Q. What do you mean by end of '08? 
25 
A. One of the months that is at the end of '08. 
Page 574 
1 
Q. Well, how much? You said you —
2 
A. Like two grand. I don't know. Why don't you 
3 
check my records? 
4 
Q. You said you made two grand on a night, 
5 
right? 
6 
A. Okay. Great. Well, that goes to my son. 
7 
MR. EDWARDS: Object to form, 
8 
argumentative. 
9 
BY MR. LUTTIER: 
10 
Q. You would go and sell your wares, your 
11 
shoes. 
12 
A. So, what all the money I owe, or all the money 
13 
that l eam, goes to my son. 
14 
Q. And you didn't even pay --
15 
A. Not to suits. 
16 
Q. You didn't even --
17 
A. Not to 'ceipts. 
18 
Q. You didn't even —
19 
A. Not to paper. 
20 
Q. And you didn't even pay taxes on money you 
21 
earned, did you? 
22 
MR. EDWARDS: Object to the form. 
23 
THE WITNESS: I did pay taxes. 
24 
BY MR. LUTTIER: 
25 
4. Did ou 
taxes in '08? 
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