EFTA01249066

IN 
THE 
CIRCUIT COURT 
OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CASE NO.: 502009CA040800XXXXMBAG 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
individually, 
, individually, 
and 
,individually, 
Defendants. 
NOTICE OF FILING 
COMES NOW the Defendant/CounterClaimant, 
, by and 
through his undersigned counsel, and hereby files the attached transcript of the telephone 
interview of 
to supplement the proffer made in support of Counter-Claimant's 
Motion for Leave to Amend to Assert Punitive Damages. 
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by 
U.S. Mail to all Counsel on the attached list on this  
/ -7  day of May 2011. 
me or re en an 
un e 
aiman 
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adv. Epstein 
Case No.: 502009CA040800XXXXMBAG 
Notice of Filing Supplement 
COUNSEL LIST 
Jack A. Goldberger, 
 Tire 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West 
FL 33401 
Phone: 
Fax: 
Attorneys for Jeffrey Epstein 
Fanner, Jaffe, Weissing, 
Fistos & 
Lehrman, PL 
425 N. Andrews Avenue, Suite 2 
Fort Lauderdale FL 33301 
Phone: 
Fax: 
Attorneys for Jeffrey Epstein 
Esquire 
Fowler White Burnett, P.A. 
901 Phillips Point West 
777 S Flagler Drive 
West Palm Beach, FL 33401-6170 
Phone 
Fax: 
Attorneys for Jeffrey Epstein 
Marc S. Nurik 
Law Offices of Marc S. Nurik 
One E Broward Blvd., Suite 700 
Fort Lauderdale, FL 33301 
Phone: 
Fax: 
Attorneys for Scott Rothstein 
2 
Martin Weinberg, Esquire 
Martin Weinberg, P.C. 
20 Park Plaza, Suite 1000 
Suffolk, MA 02116 
Attorneys for Jeffrey Epstein 
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Case No.: 502009CA040800XXXXMBAG 
Notice of Filing Supplement 
3 
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PRIVILEGED PURSUANT TO FS 766.205(4) and/or WORK PRODUCT 
TELECON 
PARTICIPANTS: 
Mit 
RE: 
DATE: 
adv. Epstein 
291874 
April 07, 2011 
B: 
BE: 
Hi 
t: 
a: 
t: 
and IM 
Hi M! Hi MI How you guys doing? 
We're doing fine, thank you. I'm sorry for all of the trouble and before we go any 
further, let me tell you, if I have your permission, I have started a tape recorder and I 
want to be able to tape this conversation from the very beginning. Is that alright with 
you? 
Sure, that's fine, s. No problem 
Ok, rid, thank you. I appreciate that. Let me start off by introducing myself. I know 
that 
has spoken to you about me but I am 
lawyer, and I assume that you can 
confirm that you and I have never had any communication before. Is that right? 
That's correct. 
Alright. I have, however, gotten some information from 
about conversations that 
you have had with him, and that will enable me, hopefully, to make this a little bit more 
efficient and take up a minimum amount of your time while still getting the information 
that we think is going to be helpful to us and to any jury that might ultimately have to 
hear these facts. 
So, let me begin by asking you first to tell us what your full name is. 
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Could you spell your last name for us? 
Alright, thank you, and where are you living right now? 
I live in 
And how long have you resided in 
That is where you are right now, correct? We've reached you in 
for this phone 
conversation? 
That is correct, yes. 
Alright. 
, the reason for this conversation is because it is our understanding that 
you know a man by the name Jeffrey Epstein, and I want to begin by asking you please to 
tell us about the circumstances of your first meeting Mr. Epstein. 
Ok. I was introduced to Mr. Epstein by Ghislaine Maxwell. I was working st—
and I was prompted by Ghislaine to come to Jeffrey's 
mansion in 
that afternoon after work to make some extra money and to learn 
about massage. She met 
and I was reading a book about anatomy, so I was 
already interested in massage therapy as it was and not having any of the education or 
you know anything behind me, I thought this was a great opportunity to work for her and 
go. So, I went to Jeffrey's mansion about 5 or 6 in the afternoon. My dad drove me 
there. My dad worked 
and he met Ghislaine and she seemed like 
a nice, proper English lady, and she knows, I mean, you know, one time then _once 
before I left to travel overseas, she just seemed really nice and like she would like to help 
me out. So my dad left, and I had no problem getting home that night, one of her drivers 
would take me back after my trial. So she led me upstairs, and into Jeffrey's bedroom, 
and past that is Jeffrey's massage room, which has got his steam room and a shower and 
a massage table, and there is actually an extra room that has, that nobody knows about it, 
it's kinda like a secret room and it's got a whole bunch of decorative pictures of 
pornographic literature and sex toys and I can 
? 
what happened in there. 
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When you say that the room was hidden, a 
how was the room concealed? 
It wasn't like a door that you would normally go into, like some kind of special opening, 
you open that and then a little door, so it looks like it's a little closet so-to-speak, but 
when you walk in there, it's obviously a lot bigger than just a closet. It wasn't too big, 
but it was bigger, you know. It wasn't a gigantic room, it was just like a small room, 
which you know, it probably could fit some shoes in there, it had racks of shoes, boxes, 
some sweatshirts neatly folded, and the ceiling to the floor was covered in pornographic 
pictures of the girls that he had met. 
I : 
I: 
When you say... 
So anyways, that was getting there, and I was introduced to Jeffrey, he was laying naked 
on top of the massage table, and obviously for one, I'm a 15 year old girl and seeing him 
on the table was weird but, also learning about anatomy and massage, I thought this 
would be part of it. So obviously, I thought it was part of the massage program, so I said 
ok, this is fine. And, he then instructed me on how to touch the body, Jeffrey's body, 
how to massage him, and for the first hour, it was actually a real massage, maybe not an 
hour, maybe like 40 minutes or something, but of something like that _and that's when he 
turned over on the other side and to expose himself fully. So then Ghislaine told me that 
she wanted me to undress and began to take off my shirt and skirt, my white uniform 
from 
she also took off her shirt and got undressed, and so I was there with 
just my undies on, and she was completely bare, and made some kind of little flake about 
the underwear that I was wearing because it wasn't my normal sexy girl underwear and 
just like, I don't know, had red hearts on it or something like that; just your normal, you 
know, real cute underwear. Anyways, so during all of this I'm kind of like what's going 
on, how do I act, what do I say, I was so afraid of, not afraid or fearful for my life but 
_unsure of how all this started and wanting to obtain a profession I was so afraid 
thinking about upsetting and disappointing them, I don't know, it's a weird situation by 
far and I was expected to _Lick his nipples, instructed on how to do so by J.E and give 
him oral sex while he wanted to fondle me, and then at the end, I was told by Ghislaine to 
get on top and straddle Jeffrey sexually, and when we were done, we went and had a 
shower in the room and Jeffrey told me to wash him up and down, you know with a bar 
of soap and make sure he was all cleaned up. And then he took me downstairs and took 
me to two of the guards and told John to bring me home. John was the butler at the time. 
Let me interrupt you for just a moment there if I could, S.
 You mentioned as you 
were recounting those details that you were 15 years old at the time. What is your date of 
birth? 
And can you tell us please, as best you're able to estimate it, what the date was when this 
first encounter occurred? 
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I've got it written down. It's like - I'm not good with math — hold on — I thought I wrote 
it down but I didn't. I'm not too sure, I think it was 
off the top of my head and 
around June of=, I would say as I was turning 16 
Alright. You talked about the room where Jeffrey had the pornographic photographs. 
Did you actually see that room on the occasion of your first visit there? 
r: 
I: 
No, I got to see that room a few visits after but I was just trying to describe that room to 
you guys so you knew exactly what room I was talking about. 
Mother question for you, and I don't mean to be prying into your personal life, and if I 
ask you any questions at all that you're uncomfortable answering, then you just tell me 
that and we'll move on, because I appreciate your cooperation and the last I thing 1 want 
to do is impose upon that cooperation, but can you tell us please just generally what kind 
of sexual experience you had had prior to this confrontation with Jeffrey? 
So, he was gone and then I had this boyfriend who was like my school friend 
from young days but weia k
i
i
i
Hcontact with each other and we were on and off 
constantly, and that was 
and there was also another younger guy was 
near my age, 
, I can't remember his last name, but yeah, there, I mean, there 
wasn't like a string of men or anything, but there was= like I told you, and he waif 
first guy expecting me to do so-called disgusting affairs. Jeffrey actually knew 
which was quite weird when I told Jeffrey the story about =, and Jeffrey had actually 
met him, and yeah. Anyway, just another story, and yeah, there were a couple of men, 
but that gives you an idea. 
Now when you described the photographs in the room as pornographic, tell me just a 
little bit about the photographs, if you would please? First, how many of them were 
there? 
At least 100, and like I said, they covered the room from the ceiling, not the ceiling but 
from the top of the edge of the wall to the bottom of the floor. I want to say at least a 
hundred, even more, there could have been more in the boxes _Some of them were A4_ 
photographs, like the large size, some of naked women posing, you know, positions, sexy 
positions. 
Others were, you know, some girls had bikinis on, and it wasn't so 
pornographic, but it was all women, and it was all in a sexual nature. 
Were there photographs where more than one person appeared? 
Oh yeah, plenty of them. There were lots of naked photographs, I mean I was just trying 
to give you a visual range. There was anything from 5x6s to 4x8s to 8x4s. Some of them 
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had frames, some of them were out of frames, but they were all, like I said, they were all 
women, they were all sexual in nature. 
Was it your impression that there were a hundred photos of a hundred different people or 
were there multiple photos of the same woman or girl? 
There was definitely a lot of different girls. I mean it wasn't easy to sit there and say, 
you weren't finding 5 girls out of some photos, no. Were there a hundred different ones? 
There could have been pictures of some girls, I really couldn't get close necessarily to 
actually recognize faces or anything like that. But if you, you know, the range of them 
were all different, majority of them were different, yeah. 
Did there ever come a point in time when you became aware that a photograph of you 
had been added to the collection? 
Yes, there was. Ghislaine took several nude photographs of me for Jeffrey. So, yeah, 
there were pictures of me and there were pictures, he wasn't shy, that wasn't the only 
place in his house that he kept the photos. He liked photos all over his house. If you 
looked in his den or on his desk or in on the hall table, a giant hall table in his house, 
there were at least a hundred photos of girls in frames. Not all of them were naked, a lot 
of the ones that were all around his house were not naked girls posing pornographically, 
some were pictures of celebrities and politicians he had known_or things like that or had 
pants on or whatever, but yeah, there was a lot of mixed photographs in the outside ones. 
Were there any photographs of girls or young women that you knew or that you 
subsequently came to know that you saw in the house? 
Yeah, cah, there was. There was pictures of 
pictures 
, pictures MI 
pictures of me, pictures of the regulars, but a lot of the 
girls, sometimes Jeffrey could have like 7 girls a day, and he would only see those girls 
once if he got bored. I don't know. These weren't my days. I heard he's gotten a lot 
sloppier since I left. So, I don't know anyways, but when I knew him, there was just a, it 
seemed, there was such an influx of girls coming in and out, so did I recognize a lot of 
them? Maybe, maybe not, but then they were all definitely beautiful, they were all 
ranging in age, some of them young, some of them older in their 20's, I mean it was just 
they were all beautiful. 
s: 
You've told us about the first visit. Was there any discussion on the occasion of that first 
visit about your returning? 
Yes, they were very pleased with me and after the encounter was finished, the sexual 
encounter, he went and told me I did well and I have a lot of potential to become a 
massage therapist and if I'd like I could return tomorrow, you know, and do the same 
thing and get paid $200/hr, so Jeffrey insisted that I come after work, and over the next 
few days, I guess the relationship grew into more, and within a couple of weeks, not even 
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Page 6 of 23 
a couple of weeks, maybe a week, I had quit 
and I was working for Jeffrey 
MI time. 
I 
■ 
I 
I 
t: 
Ok. Is your Dad aware of what is currently going on with regard to your having made 
public statements about your relationship with Jeffrey? 
Yes, he is well aware of it. I told my family even before all this stuff came out, because 
they were the fast ones contacted by the journalists-. 
I know that 
they the 
printed that I had gone out and tried to, I mean I think one of the 
photos sat tat was angry that I saw Jeffrey and the Prince walking together and that is 
why I came out and went public with everything. Not true. I mean, I am angry about 
how they are still u to their old ways together and that they're still hanging out but I 
didn't contact the 
and I didn't bring it out. I figured that everyone was 
going to bring it out anyway and I better bring it out the right way. He's known 
everything from the start, and my family is very supportive with everything going on. 
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Just for the record, neither 
nor I, nor anyone representing that they have anything to 
do with us has made any promises to you. Is that correct? 
That is correct. I'll tell you, since this is our first conversation, that nobody has made me 
feel like I've been bribed or bought or had to say anything. I've told you anything that I 
know from my own self, not some things somebody told me. If anything, 
been 
extra careful not to tell me anything and let me do all the talking, so it's quite opposite I 
think. 
Alright. Let's get back then to the story of your relationship with Jeffrey, and we've 
talked about your first encounter with him and how it evolved from that into your full 
time em loyment with Jeffrey, but what were you doing at 
before you quit 
Ok, and you were only 15 years old at the time, were they aware of how old you were at 
Of 
oc
urse, definitely. We had to go through extensive, you know, we even had to get 
drug tested and id test and so on and so forth. I mean, 
is very strict on 
employment, yeah, everybody knew. 
Ok. Was there ever any conversation with Ghislaine about how old you were before you 
were taken to Jeffrey's mansion? 
No. She didn't ask me how old I was from the start, but when I did get to Jeffrey's 
mansion, it was discussed how old I was. 
With whom? 
During the entire hour of what I call the legitimate massage I was giving him, it was cat 
and mouse games getting information from me to find out who I am, am I a willing 
participant in these kind of things, and how would I react if they were about to take the 
next step. But they got information off of me, they got my age, they got my, a little bit of 
my history so they knew I was, you know, not very stable at home, and they knew that, 
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you know, I was actually interested in making my life better by studying so what they 
were offering me was a chance to become a legitimate masseuse but it was getting 
trained. They would have people show me how to work the body and be called a 
massage therapist and get me books on it, and you know, keep me interested, and every 
time, you know, I was with Jeffrey, literally was about massages, I don't mean just going 
in and have sex with him. I mean massage, because it would always start out with 
massage and then it would lead into sometimes other things. 
Alright, once this evolved into full time employment, what did full time employment 
mean? 
U: 
That was entirely having to travel with Jeffrey in every city. When he was in Palm 
Beach, I stayed at my apartment, and he would call me to his house once or twice a day 
sometimes, and that's, you know, do things with him. Sometimes we'd go out shopping, 
sometimes we'd go out and watch a movie. You know, simple things like that, go to an 
expo or a fair, whatever it was. But when we were in other cities, I was at my 
apartment_, I lived with him full time. What I mean by full time is even in the middle of 
the night, I could get a ring on my phone next to me and tell me to come in his room, you 
know, so it was literally full time. 
When you say that when you were in Palm Beach you were living in your apartment, 
were you living on your own or were you living with members of your family at that 
time? 
No, after I 
somewhere, 
was absolutely 
him really. 
• 
effrey offered to get me an apartment in Palm Beach 
and it was a nice apartment. He fiimished it for me, it 
uti 1, ut yeah, that's the only time I would spend time away from 
Th
epartment was on 
•
 
or out in the 
I so honestly don't remember. I've been trying to rack my brain because the FBI was 
asking the same thing and were trying to fmd it, but yeah, I'm Not sur 
I didn't get to 
spend as much time in it, I was only there about an entire week out of every month 
robabl but the majority of the time I was with Jeffrey anyways. It was somewhere in 
. I don't know about 
I don't even remember 
the 
anymore so I'm not too sure. 
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Alright. 
I would be driven, it was closer to my family than it was closer to him. I wanted to be 
close enough to everybody else so that when 1 was in town, I could just go see them 
quickly. 
a: 
I 
■: 
That's correct. 
Jeffrey got you an apartment out there. 
When he was in Palm Beach, you were generally not staying at the mansion, you were 
staying at the apartment that he got for you 
That's correct. 
Ok. 
I mean then there was times, I don't wanna say that every time I stayed at my apartment. 
There was times we'd fly back from some city maybe too late at night to really want to 
go back home, so you know, it's like 12:00 at night or 1:00 in the morning. I was just 
staying in the yellow room, or something like that; one of the guest rooms in Palm Beach. 
But majority of the time, I would definitely want to get back to my own apartment. 
Alright. What were the general hours of your full time employment when ...? 
There was not set hours. It wasn't like logging, and you know, hitting the shift button, 
nothing like that. The way I would get paid would be, ok, if I was in Palm Beach, I 
would get $200 an hour to massage Jeffrey or some of his friends and then go home. So 
it would be like that. If I was traveling with him, it would be per massage, so I would be 
getting paid per day. So I wouldn't be getting paid on an hourly rate. He wouldn't say 
ok, today you're going to work for me from 7:00 in the morning until 8:00 at night It 
never like that. I was on call all the time. 
When you were here in Palm Beach, were you actually getting paid only for the time 
spent massaging Jeffrey or were you getting paid from your arrival at his house until you 
left the house? 
From the time the massage started. 
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From the time the massage started. Ok. 
Sometimes we'd go there and I would wait for a while or talk with Ghislaine and Jeffrey 
about something or we'd meet somewhere and talk about something. A lot of times, I'd 
meet him upstairs in his room where he was ready for me. But then there was a lot of 
times where it didn't start right away, so he couldn't really pay me from the time I got 
there sometimes unless it was just paid from the time I massaged him til the time the 
massage was over. 
Alright. Did your duties for Jeffrey ever include anything other than providing him 
massages and sex in connection with the massages? Did he ever give you any other 
responsibilities to perform? 
I was asked to do the same things that I did to Jeffrey to a few of his fellow colleagues as 
well. Those were my duties. He looked at it this way is that I was going to be a 
professional massage therapist, and maybe I needed some clientele, so he had me perform 
erotic massages on a few people. 
r: 
s : 
r: 
II
■
Did that start here in Palm Beach County? 
It did. The first one did. 
Ok, and how long after you first met Jeffrey did he first ask you to provide services for 
one of his friends? 
About 9 months, I think it was. It wasn't a full year, it wasn't 6 months, but between 6 
months and a year, which is why I'm saying 9 months. 
And when you provided services to a friend of Jeffrey's, who paid you for those services? 
Jeffrey would. I would get paid the next time I saw Jeffrey, so if I was invited to the 
Breakers Hotel to give a massage, I would give a massage, I would go home, and the next 
day when I saw Jeffrey, he would pay me for what I did. So, it was paid always by him, 
it was set up by him, so he always knew what to pay me. I did get tips and things like 
that, if you call it that, you know, like a hundred dollar tip or something from a few of 
them, you know, yeah. 
Was there .. 
There was always payment from Jeffrey. 
Was there ever any discussion with Jeffrey about what was expected to happen when you 
provided massage services to one of Jeffrey's friends? 
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In a roundabout way, yes. In so many ways, Jeffrey really really had to train me, and that 
was why Ghislaine said that she and Jeffrey enjoyed me so much was because they never 
really had to speak much to me to tell me what they wanted me to do. You know, I 
wasn't waiting for you know, their directions. Jeffrey would tell me to go give an erotic 
massage to friends. He wouldn't give me much detail about it, but he would say to treat 
them like you treat me. 
Did he refer to it as an erotic massage or are those your words? 
Erotic massage is my words. That's exactly what it was, but he would tell me to treat 
them how he wanted it, so I'd do what he wanted without having to say to me words 
more. I mean, I complied with what he wanted because it was somewhat of a, I don't 
know, I don't know how to say it, it was just very mindboggling how I let him have so 
much control or power over me basically. The massages would be routine to what Jeffrey 
wanted with my so called new clientele, and with their own words would ask me to 
provide them with sexual pleasure after the massage. 
Did you ever report back to Jeffrey about what happened when you provided massages to 
his friends? 
I 
Of course, of course, and I knew that his friends were reporting back to him as well 
because there were times where he would instigate conversation by saying you know, so 
and so had a great time, you did wonderful, you know so and so gave me a call and told 
J.E how it went_... 
Did Jeffrey ever elicit details from you? "Tell me what happened, describe in detail what 
went on?" 
No, but he would have a laugh, he had a laugh with me a few times about some of their 
different mannerisms, I guess you would say, like some of them, one guy had a foot 
fetish and that was really weird and I mentioned it to Jeffrey, and we would have a laugh 
over it. He didn't want to know details. He wasn't asking me "so tell me what did you 
guys do exactly." No, he just basically gave me a slap on the back and said, you know, 
good job. And we had some kind of conversation about it. I can't recall any conversation 
off the top of my head. I really don't know one. It's been that long. But yeah, we did 
talk about it briefly. 
Can you give me an estimate as to the number of friends for whom Jeffrey provided and 
paid for your services? 
There was about, you know, I don't know, 8 guys possibly. 
And are you able to name those people for me? 
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No, not at this stage. I just, some of these people are really influential in power, and I 
don't want to start another shitstorm with a few of them. I'll tell you that there was some 
erotic massages given to, I'm just afraid to say it to you. 
Ok, M. 
It's like gen, I don't know if I want to, I'm really scared of where this is gonna go. 
I 
■ 
Alright. I understand that, and as I told you from the beginning, if I ask you a question 
that you are uncomfortable answering, you just tell me that, and I will move on, and I 
understand that at least right now, you are uncomfortable answering, and I am certainly 
going to respect that. 
Thank you so much,. 
No, that's quite alright. I am very appreciate of the cooperation you are providing, and I 
don't want you at any time to feel that we are taking unfair advantage of that cooperation, 
so give me the information that you're comfortable giving me, and if we get to a point 
where you're uncomfortable, I will respect that and we'll move on from there. 
Ok. 
I want to talk a little bit about the traveling that you did with Jeffiey. About how long 
into your relationship with him did that first start? 
Immediately. I started traveling immediately. Not internationally until I think about, 
Gosh, I can't remember even, I think it was a year later that we started doing international 
travel. Maybe like 9 months to a year again. Not too sure to be honest. 
So that would have been approximately the summer of_' 
Somewhere around there? 
Yes. Somewhere around there. Somewhere around a year, somewhere around there, I 
can't pinpoint it exactly. 
But like I said, we started doing domestic traveling 
immediately, so my first destination with him was New York and Santa Fe and the 
Carribcan, California, I would take trips with him occasionally. Sometimes we would go 
to 
We were traveling just about everywhere I 
think. 
How did you travel? 
Well, we took Jeffrey's private jet, and unless I was being sent somewhere by myself for 
what we were just talking about before, then I would travel on a what do you call, a 
public jet, whatever it is... 
commercial flight? 
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Yes. Just a normal flight, an e-ticket. 
Like the rest of us common folk. 
But when I was traveling with Jeffrey, the majority of the time would be on the black jet. 
Now, when you say there would be times when you would travel by yourself because he 
was sending you somewhere, tell me about that. How did that come about? 
So, one of his colleagues would be at the Carribean or Santa Fe or even New York, or 
wherever, and he would call me up on those days where I am not working with him or in 
Palm Beach with him, and he would ask me to get on the next plane to so and so and go 
meet so and so, and that's when I would take e-tickets. His secretary or special assistant, 
whatever, would organize it for me and give me the details and I would just walk up the 
line and they'd let me right through. 
Can you give me any ideas as to how many times it happened that Jeffrey would send 
you off to meet some friend of his at some location outside of Palm Beach? 
How many times it happened? I'm not too sure. Probably about 10-15 times. 
Ok. And on those occasions, how much time would you spend with one of Jeffrey's 
friends when you were sent to a location that you would have to travel to? 
Only a couple of days. Only 2 days, that's it. 
And how were you paid for those trips? 
I would be paid in cash upon my arrival back with Jeffrey. So, whenever I was back with 
Jeffrey, he would count up how many days I've had, sometimes give me even more than 
what I deserved, not deserved, but what I earned and give me a little extra. 
Was there a daily rate for those trips or was that per massage also? 
Per massage. With Jeffrey, I would be honest. I wouldn't tell him I did 15 massages if I 
didn't. He knew he could trust me. He could always come back to the other person that 
he sent me to give massages and ask them as well, so you know, it was always by per 
massage. 
Alright. When we've been talking about massages, tell me exactly what it is we're 
talking about when we speak about massages. 
Same thing I would do to Jeffrey. Again, it would start out as a massage, which would 
start with them being naked, and me giving him a legitimate massage to begin with, so 
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I'd start with his feet, go up to his calves, up his legs, buttocks, back, his neck, his head, 
his arms, yada yada, and then it would be time to flip over, and some of the men would 
want me w continue on massaging the front side of them and they would instigate me to 
begin having sex with them or foreplay, whatever you want to call it. 
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So routinely, these massages involved sexual activity. Is that accurate? 
That is accurate. 
Ok. Let's talk about the travel that you were involved in when you were on Jeffrey's 
private plane. Generally speaking, who were the passengers on the plane when you 
traveled. 
Well, Larry was the pilot, and then there was a short, small solid guy, I don't know his 
name, but he was a co-pilot, and then he changed and there was another guy brought in 
later on. Generally speaking, there was always Jeffrey, sometimes Ghislaine, sometimes 
MB sometimes a whole bunch of other girls, sometimes famous people, sometimes 
some politicians or yeah, just about anybody could fly on his plane. There was never no 
any set routine who would come and who would go. It was an influx of people on 
Jeffrey's airplane. 
I want to deal with these things separately in order to respect some of the reservations 
that you have, so I'm going to ask you who the people were that you remember flying 
with Jeffrey on his plane when you were personally present without regard to whether 
there was any sexual activity that occurred on the plane or not. So I'm not asking you to 
implicate any of these famous people in improper conduct, but just tell me what the 
names of the people are that you remember that you consider to be famous people. 
Ok, there was Naomi Campbell, Heidi Klum, there was Bill Clinton- There was Al (?) 
Gore, there was a whole bunch of models, I wouldn't really honestly be able to give their 
names. There was Matt Droning the producer of the simpons cartoon, 
CCousteau's 
granddaughter a lot of interior designers, architects, politicians. I am just trying to think 
of as many names as possible for you. Off the top of my head, that's as good as I can get 
for now. 
Ok, alright, that's fine. And again, I am not implying by my questions, nor do I want 
your answers to be interpreted as your suggesting that any of those people that you have 
just identified were engaged in any improper activities on any particular flight, but I want 
to talk to you now about what went on on occasion on the airplane. Ok? 
Ok. It was a lot of the same thing that went down on the ground. A lot of times, it would 
be just be me and Jeffrag me and Jeffrsand Ghislaine, or me and Jeffrey and some 
other girl, sometimes 
S 
and 
aThere would be sexual conduct, 
there would be foreplay,
 was a bed in there, so we could basically reenact exactly 
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what was happening in the house. It would start off with massaging or we would start off 
with foreplay, sometimes it would lead to, you know, orgies. 
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Were there occasions when you were in Jeffrey's company, whether on the ground or in 
the air, where there were other girls present whom you knew to be under age 18? 
Yes. There was a constant influx of girls coming in and going out. And we were all very 
young. On occasion, there was some older girls, and i don't mean older as in like in their 
30s or anything, I mean like 28, 29, something like that, just very rarely. The majority of 
the girls that Jeffrey actually met or had on his plane or in his house were under age. 
Do you know how it is that Jeffrey established with any of these underage girls? 
Yes, I do. He would send me personally or with other girls to clubs or shops, to _pick up 
anywhere, I mean we were constantly on the look for other girls that might satisfy 
Jeffrey. 
What instructions were you given about what to look for? 
Young, pretty, you know, a fun personality. They couldn't be black. If they were any 
other descent other than white, they had to be exotically beautiful. That was just about it. 
Who gave you those criteria? 
They both gave us the instructions, and it wasn't just me, Jeffrey asked most girls to bring 
a friend and make extra money. They would use us young girls So that way it probably 
looked a lot more safer to a girl that we were procuring to younger girls that were already 
doing it. That was the way that Jeffrey had it. 
Were you given any instruction at all on how to approach these girls? 
Yes. 
Jeffrey and Ghislaine both taught me to, depending on the circumstances, 
depending on the girl, you could offer them a job as a massage therapist or you could tell 
them you have a really rich friend with, you know, great contacts in the acting world or 
modeling world and he loves pretty girls, you should come back and meet him, make 
some money, you know, we had a whole bunch of ways to be able to procure girls. 
Can you give me any idea as to the total number of underage girls that you know engaged 
in sexual conduct with Jeffrey during the period of time you had your relationship with 
him? 
I would have no way of estimating that whatsoever. I mean, there could be a hundred, 
there could be more, honestly I'm not too sure how many girls, really. I wish I did know. 
I mean like I said there were so many over the course of I years with Jeffrey. 
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Let me see if we can try to narrow it down a little bit. Is there any doubt in your mind 
that it was more than 10? 
Yes, there was definitely more than 10. 
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Ok, what I want you to do is to give me the highest number that you are comfortable in 
saying there were definitely more than X number of underage girls that I know Jeffrey 
Epstein engaged in sex with while I had a relationship with him. How would you fill in 
that blank? Definitely more than how many? 
I'd say definitely more than a hundred. 
Alright. Did Jeffrey ever help to pick out your clothes? 
Oh yes. I mean he wasn't out to dress me like a porn star or anything. He would always 
dress me very classy, but we'd just go shopping all the time together. 
Did he ever express any style preferences in terms of how he wanted you to dress? 
Besides dressing classy, I'm, you know, any other suggestion to you about how he 
wanted you dressed? 
He didn't, like I said, wasn't trying to dress me in any prostitute way or anything like 
that. It was nice, classy outfits I was wearing like Gucci, Dolce Gabbana, Chanel, things 
like that. He was buying me a lot of very, very nice clothing. It was provocative. I mean 
I was wearing miniskirts, and tight short shorts and little shirts that showed my belly and 
my cleavage and everything, but they were very expensive clothes. 
Was there every any dress up role playing? 
Yes. There was. Lots of it. Jeffrey loved the latex outfits Ghislane had for us girls, he 
had bondage outfits, he had all different kinds of outfits, but his favorite was the 
schoolgirl. 
Tell me about that. 
Well, you know, Ghislaine would take me to dress me up to surprise J.E or Jeffrey would 
ask me to get dressed up, that would include wearing a tiny little skirt with nothing 
underneath, a white collared shirt that you would be wearing to school with a tie in it, tied 
up _in a bow, my hair in pigtails, stockings on up to my knees, and I would go in there 
and act like a kid and we'd do role playing sexing. 
Did Jeffrey ever brag to you about the age of any of the girls with whom he had 
relationships? 
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