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1 Q. And were you living with her at the time? 1 Q. You said the beginning IS
2 A. At the time I was. 2 that's when I transferred to
3 Q. Was there anyone else living with you and your 3
4 mother? 4 Q. arm mother's name?
5 A. My sister. 5
6 Q. And your sister's name is? 6 Q..
7 THEW : Do I have to give my sister's 7 A.1
8 name? I would really rather not give you my 8 Q. Did you liv e other than your
9 sister's name. 9 mother before the
10 BY MR. LUITIER: 10 A. My father.
inn
11 Q Would that be 11 Q.
12 A. I would rather not give you my sister's name. 12 WilliSMS.
13 Q. Is your sister's name 13 ' • u were in the
14 A. I would rather not give you my sister's name. 14 and living
15 Q. This is a yes or no, ma'am. not 15 with your mother in was your Ala; living
16 complicated. Is your sister's name 16 with you?
17 MR. EDWARDS: Object to the form. Asked and 17 A. Yes.
18 answered. The objection is a right ofp rivacy of 18 Q. And do you know how old you were in the ninth
19 third parties. She's not going to give the name. 19 grade?
20 MR. LUTHER: Are you instructing the witness 20 A. No.
21 not to answer-- 21 Q. • grade?
22 MR. EDWARDS: Yes. 22 A.
23 MR LUTHER: — the question of whether your 23 ' en you were in the
24 sister's name is 24 your mother, was she
25 MR. EDWARDS: Correct. 25 always living in
Page 82 Page 84
1 MR. LUTHER: Are you serious? 1 ir, I was in and out
2 MR. EDWARDS: Yeah. 2 house when I was i
3 MR. LUTHER: Okay. I am going to guess your 3
4 sister's name is 4 Q. What do you mean in and out —
5 THE WITNESS: You can guess that. 5 A. I don't want you to think that I
6 c full time when I was in
6 BY MR. LUTHER:
7 Q. OlcAL So, it was you and and your mom 7 I was in and
8 living at 8 house when I was in
MR. EDWARDS: Object to the form. 9 Oliveto separated. My f
10 THE WITNESS: No. It was my mother, my 10 My mother I went
11 sister, and I living-- 3.1 to several schools I went to
12 BY MR. LUTHER: 12 several schools in
13 Q. And is that different than the people I just 13 Well, you told me abou
14 said? 14 you told me about
15 MR. EDWARDS: Object to the form. 15 hoots did you alb
16 THE WITNESS: It was my mother, my sister, and 16 is ' I.
17 I living in. 17 e fo I attended
18 BY MR. LUTTIER: 18 when I was supposed to be, when I
19 Q. And for what period — 19 was i
20 A. — MM. 20 Q. Now, when you say you were in and out of your
21 Q. — of time did you and your mother and you 21 mother and father's house, what do you mean?
22 sister live in 22 A. I lived with my mother for a little while.
23 A. I was living with my mother when I ' 23 And then I would go to my father's house for a little
24 Mgrade. And when I was 24 while. You know, they were separated, so, I — there
25 , and pretty much the beginning of 25 was never a court ordered statement saying that I had to
21 (Pages 81 to 84)
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1 MOM interested into getting into drugs.
1 2 be a Q n . y w W he e r l e l, s w pe h c e i n f i y c o . u say they were separated, were 2 Q. Well, you, you had done drugs prior to the
3 4 they A s . ep T a h ra e t y e d w o e r r e w , t e h r e e y th w e e y r d e i d v i o v r o c r e c d e ? d when I was 3 4 5 t m im u A c e h y . o it u I . s m A m e n o t d k J e w e d f h f w r e e n e y e I , d c m o a e r f t r e e J w c e t f ? f ti r m ey e , s t , h a e n g d i r th ls a t t h w at a , s pretty
5 6 Q. . And , that would have been about what, 6 who brought me there, she would start giving me
7 drugs.
7
8 Q. What kind of drugs?
8 A. Sure.
9 Q. And why were you moving back and fI between 9 A. Pills, any kind of pills.
10 iiiritother and father's house as late as the= 1 1 0 1 Q A . . W An h y a t k k in in d d , V of a l p i i u l m ls? s, Percocets, Lorcets, any
1 12 1 A. Because they actually, they, they allowed it 12 kind of pills to make you I guess chill to not be
1 1 3 4 t c o h o b i e c e m . y T c h h e o y ic - e - . it Y w o a u s n k ' n t o a w b , i g th d e e y a a l. l lo If w I e w d a it n t to o d b t e o m y 1 1 4 3 ner Q vo . us W in e l f l r , o w nt h o o f i s a t 5 hi 0 -161. that you're
15 go live with my mother, I lived with my mother. If I 15 referring to? What's her last name?
1 1 6 7 wan Q te . d A to n l d i v d e i d w y it o h u m m y o f v a e t h a e ll r , y I o l u i r v e b d e l w on it g h i n m g y s f f r a o th m e r o . n e 1 1 7 6 Q A . . Y I d o o u n h 't a k v n e o n w o . recollection who this is?
18 A. No, sir.
1 18 9 hou A se . to I h th a e d o s t o h m er e ? of my stuff over at my mother's 19 Q. And this is a person that you said did what?
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22 Q. How did you know this person?
2 2 2 3 a M I w th h i e s n p y e o ri u o s d a o y f y t o i u were living with her? 2 24 3 at o A n . e o I f w m a y s f a r t i a e n ho ' use and I A a n m d n I o s t p e e x n a t c t t h l e y n -- i g I h w t o as v er
24 A. Yes.
25 Q. What was the conflict with your mother? 25 there. And I guess was one of my friend's
Page 88
Page 86
1 2 3 i e n s t c o A a l b . a a ti d W n , g j e u , l a s l t n , a d d f r t t u e h g r a s t I , ' s m a w n e d h t a J th t e f h e f y a r e p k y p e , e p I n t s e o t d n a r e te s d ca g la e t t i t n in g g a nd 1 2 3 f a t r h t i e e f i n w r d s a t . y I A s w h n a e d s e s v x h e p e r l y a a , s i n v k e e e d r d y i m s t k t e o e i p m l t l i e c w . a l a B a n u b te t o d t u h t t e o i n t m b sh e a c e k a e c u $ o s n 2 e v 0 o i 0 n f . c e A d n d
4 Q. What do you mean when you say after you met 4 me into it.
S And once I walked into that beautiful house
6 5 Jeff A re . y , A yo ft u e r g I o h t i a n d t o m d e r t u J g e s f ? fr ey, I started doing more 6 and that beautiful mansion with all those beautiful
7 girls and luxurious living with all those beautiful
8 7 and Q m . or W e a h n e d n m di o d r y e o d u r u - g - s I . a ssume you mean illegal 8 cars, I thought at that age that that's what I wanted or
9 drugs or drugs for which you didn't have a prescription? 10 9 tha Q t's . w S ha o t , I i t c w ou a l s d t h h i a s v p e e m rs a o d n e n o a f m m e y d s elf. that you
1 1 1 0 2 1 A Q A . . . C W A o n h r y a r e t d c d r t u r . u g g s s I d c i o d u y ld o u g e d t o , ? c olic, pain bile's. I 1 12 1 s ti a m y e c , o i n s v t i h n a c t e — d d yo o u I t h o a g v o e y to o u J r e f t f e i s c t y im E o p n s y te c in o r t r h e e c t f o ir n st
13 have done many drugs, ecstasy and --
13 that?
14 A. Yes, you do.
14 Q. Xanax? 15 Si _Jl,l effrey Epstein had no contact with you until
1 1 5 6 A Q . . A Is n t d h a X t a o n n a e x o . f your drugs of choice, Xanax? 16 whatever her last name is, brought you to his
17 A. What do you mean?
17 house; is that correct?
18 Q. Is that one of your drugs of choice, a popular 1 19 8 A Q . . T A h n a d t 's y o c u o r m re e c t t . at, you say at a friend's
1 2 9 0 dru A g . f or W yo h u en ? I was that age, yeah. Any drug -- 20 house. What was that friend's name?
21 Q. That age meaning what age?
21 A. I a ify sure it WaS house.
22 A. When I was seventh and eighth and ninth. Not 22 Q. MI who?
2 2 4 3 n w i h n e th n . I I w d a o s n i ' n t k s n ev o e w n t t h h e . e M xa o c re t - w - h w e h n e I n w I a w s a i s n i e n i g sc h h th o o a l n . d 2 2 3 4 Q A. . Yo I u d o w n e 't r e k n sp o e w n d h i i n s g la t s h t e n n a i m gh e t . at this person's
25 I know that when I met Jeffrey, the drugs I got, I was 25 house?
INetibMilli7.•••••••:•••0110apillilablela1101% 22 (Pages 85 to 88)
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1 the night that you spent, the night house?
1 2 A. T U H h E - h C u O h. U RT REPORTER: Is that a yes? 2 3 out A w . ith I, h I e s r a , w bu h t a w e b e d f i o tt r a e r b e e a c l a l u y s talk. S w he o u w ld as h a a n n g ic e
3 THE WITNESS: Yes.
4 girl, but she was one friends that had
4 BY MR. LUMER:
Q. So, w a boyfriend of yours? 5 introduced me to her.
6 A. No. we had, we had friends. We had 6 Q. So introduced you
7 mutual friends that we would just hang out with. 7 A. introduced met
8 and a couple of my girlfriends, and we all spent the 8 a this evening when you spent the night at
9 night over there just havn4in. 9 or before that?
10 A. No. A couple of days before
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13 that we grew up in.
13 night at his house?
14 A. Maybe — he was young as well. He was maybe 1 1 4 5 Q A . . W I g h r i e c w h u n p ei • . t? She grew up across
1 1 6 5 16. Q I . t w O a k s a h y i . s S pa o r h en is t s p ' a h r o e u n s t e s . w ere present when you at 16 the frog i e thborhood I grew up in. Near
17 this age were spending the night over at his house? 17 w. .t , t o a r s e a y y o . u referring to
18 A. Yes, they were. Yeah, his parents were there. 18 Q.
19 Q. And they were there? 19 the City o
20 A. No
20 A. Yes.
21 Q. Okay. And who were these other you said we 21 Q.
22 had mutual friends. Who is the "we" you were referring 22 A.
23 Q.
23 to?
24 A. Well, he introduced me was 24 A.
25 one of my girlfriends". and a couple of her friends, 25 Q. Okay. So, tha
Page 92
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1 development lige?
1 but mainly my girlfriend
2 Q. Well, who were these couple of her friends 2 3 A A . . T . h at's w up in known as
3 that you are referring to? :
4 A. A couple of girlfriends. I don't recall their 4
5
5 names.
6 Q. You don't know their fast name or last name? 6 ew up across the street from
7 in another development?
7 A. No.
8 A. Yes.
8 Q. No idea?
9 Q. Did it have a name?
9 A. No.
10 25 But all of you spent the night over at this 10 siathat I recall. The road was called
11. I am prettyame.
1 12 1 A. - Yeah, but that was years ago, so I really 12 Q. And you knew.... for how long, ever since you
13 don't remember. I don't hang out with them anymore. I 13 were a kid?
14 A. Yes. I probably met her when I was 11, and we
14 don't remember.
1 1 1 5 6 7 Q A . . Y Y N o o o u , u I d d d o o o n n n 't ' ' t t h h a W a n n g h g e o n o u u t w t w a w s it i h t t h h w e a l n a h y s o t o t , f i . m t . h e e m y a o n a u y n s m y a m o w r o e r ? e . 1 1 1 5 7 6 j e u v s e t Q n w i . n e g r D e t o h li a y t t t o l y e u o g h u i a r s l v p s e e r n a id n t i y t n h g r e e b c n i o i k g l e l h e s t c a a ti n t o d n p o l f a y w in h h g e o n . u y s o e u w , t a h s i ? s
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20 Q. And you were going --
20 Q. Of what year?
2 2 2 1 I pa A ss . ed O b f y M he . r . N I e j w us Y t - e - a w t's e E ju v s e t a s t a id hi. We d d o i w dn n ' t t o wn. 2 2 2 1 A Q . . h I ia w g a a s r o 13 u r w ig e h re t a g b o o in u g t t t o o t w ur h n a t 1 s 4 c . h ool? So it had
23 hang out. We just said hi and talked a little bit, but 23 to be.a?
24 nothing much, like, hey, how are you, howeir.. 24 A. I'm Uigie. I couldn't tell you.
25 Q. Is the first time that you met this 25 Q And.. lived where?
23 (Pages 89 to 92)
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1 A. He lived iu1 somewhere. He had a 1 MR- EDWARDS: Has to be yes or no so the
2 'car. We didn't have a car. I don't know where he 2 record is clear.
3 BY MR. LUITTER:
3 lived.
4 Q. So my question is designed to be very
4 Q. Diet drive? 5 specific. So, if you can't recall, I want you to tell
6 5 Q A. . Y S e a s. l must have been old enough to have a 6 7 m wh e a . t I e f v y e o r a u n d s e w f e in r i . t e B ly u c t a I n w r a e n c t a t l o l t a h s e k n y f o in u e .m. , g .i i l v s e m as e of the
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10 you talking about down somewhere near where you lived? 10 was a non-prescription drug?
11 A. Yeah, it was around that area, the heart of 1 12 1 A Q . . N H o a . d you told anyone in the world as of that
12
1 1 3 4 the Q ce . nt S e e r , o w ere oin o g r s to o m sc e h p o la o c l e s o u m p e in w . h i e ll r e clown in 1 1 3 4 poin A t _ in M ti a m y e b e th t a o t b y e o u c o h o a l d I u w se o d u a ld d h r a u v g e ? said, oh, yeah,
15 I tried that before, but no.
1 1 5 6 A. You know what, it could have been around 16 Q. Were there any girlfriends that you knew, any
1 1 7 8 s p u ro n b u a n b e l r y ti m at e m w y h f e a n th w er e 's d h id o n u ' s t e h a a v t e s u s n c n h n o e o r l t , i m an e d . I was 1 1 7 8 n at o a n- ll F w r it e h w o h n o m d y r o u u g h a a s d o d f o th n e e a da n t y e i l t l h e a g t a y l o u spent the
19 Q. Now, at that point in time at the time that 19 night al= house?
20 you went and spent the night a house, what 20 A- No.
21 drugs had you experimented with? 21 Q. And you're absolutely sure of that, correct?
22 A. I have experimented with weed a couple of 22 A Yes.
23 times, but I personally didn't care for it. 23 Q. All right.
24 k Do you want to ask me again?
24 Q. What other drugs?
25 MR. EDWARDS: Are you talking about at the 25 Q. Now, when was the first time that this'll.
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1 girl that you say you met there, gave you a drug?
1 2 tim M e w R h . e L n U — THER.: Yeah, when you — this, as of 2 A. She would start giving me drugs after I saw
3 4 t w h h e e , n th e e v e p r o t i h n i t s i n in t c im ide e n th t a w t a I s a w m h e fi n x i y n o g u o s n p i e s n t the night 3 4
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6 THE WITNESS: No. We weren't doing any drugs. 6 Q. When after, a week after?
7 A. Yeah.
7 BY MR. LUTTIER:
8 Q lam not saying you were doing drugs at the 8 Q. A month after?
9 time. I want to know what drugs you had experimented 9 A. Yeah.
10 Q A year eller?
10 with --
11 A. Yeah, a week, a couple of days.
1 12 1 Q A. . W — e b e e d fo . re that point in time. 12 Q. Did she — how did she introduce or give you
13 this drug?
13 A. Marijuana.
14 Q. Had you ever taken any other illegal or 14 At She gave it to me with her hand, here you go,
15 non-presaision drug as of the time thaiitient the 15 here is some drugs.
16 night at houseand first met this lady? 1 1 6 7 Q A . . H A e n r d e w . T ha h t i s d i w d i s ll h m e a te k l e l y y o o u u ? n ot nervous when you
17 A. No.
18 go to Jeffreys house. Take this drug.
18 Q. Are you sure?
19 Q. And what drug did she give you?
19 A. Yes.
20 Q. Olcay. I want, I want to clarify now. You've 20 A. I think it was a Valium.
21 indicated in this deposition that sometimes you can't 21 Q. Did you pay anything for it?
22 A. No.
22 remember dates, right?
23 Q. Were there other occasions that she gave you
23 A. (Witness nods head.)
24 drugs?
24 Q. So —
25 A. Yes. After every time I went to Jeffreys
25 A. Yes.
24 (Pages 93 to 96)
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1 with her, she would give me drugs. 1 BY MR. LUTHER:
2 Q. Did you ever see her on any occasions other 2 Q. Fair statement to say you don't know if he did
3 than when you were going with her to Jeffrey's? 3 or WO
4 A. After a couple of months, we hung out and 4 A. He told me that he was going to calla cab so
5 that's when I got Jeffrey's number. And I didn't, I did 5 I could get to his house.
6 not no longer need her to take me to Jeffrey's. So we 6 Q Do you know if Jeffrey Epstein ever called a
7 hung out a couple of times. We would talk about Jeffrey 7 cab —
8 and how much money we were making from Jeffrey and 8 MR. EDWARDS: Object to the fem.
9 that's that 9 BY MR. LUTHER:
10 Q. What do you mean you no longer needed her to 10 Q. -- to be sent out to you to get you?
11 get to Jeffrey's? 11. A. Yes.
12 A. I bad Jeffrey's phone number so I could call 3.2 Q. How do you 'mow that?
13 him so he could send a taxi over, or he could send 13 A. Because he told me.
14 somebody from his house to come pick me up to go to 14 Q. Is that the only basis that you have --
15 Jeffrey's. I didn't need her or one of her friends to 15 A. Yes.
16 drive me to Jeff, to Jeffrey's anymore. And now I was 16 Q. — for making that statement? You never heard
17 i one i of J A eff n re d ys girls to fad more girls, so -- 17 him get on the phone with a cab; is that right?
18 this, this occurred when, that is that 18 A. No, we never made a three-way call to the cab
19 never — stopped taking you there and you began 19 station.
20 to go over these on your own? 20 Q. Do you know whether or not on times when you
21 A. Within a month. 21 claim that he told you he was going to have a cab
22 Q. Now, you said that, that, something about 22 whether he called for the cab or someone else called for
23 taking a cab. Who — weren't you the person that called 23 the cab?
24 the cab? 24 MR. EDWARDS: Object to the form.
25 A. I have called cabs, yes. 25 THE WITNESS: Excuse me?
Page 98 Page 100
1 Q. And then you rode a cab from wherever you were 1 BY MR. LUTTIER:
2 to Jeffrey's house? 2 Q. Do you know whether or not on those occasions
3 A. Yes. 3 where you claim that Jeffrey told you he was going to
4 Q. Did anyone else calla cab for you to take a 4 call a cab, whether he called the cab or someone else
5 ride from wherever you were to Jeff's house other than 5 called for the cab?
6 you? 6 MR EDWARDS: Object to the form.
7 A. Yes. 7 THE WITNESS: Jeffrey would get on the phone
8 Q. Who? 8 with me. Hi, Jeffrey, how am I going to get to
9 A. Ether my, one of the girls that I brought or 9 your house. Don't wort' l. , I will take care of
10 Jeffrey would call a cab or one of Jeffreys assistants. 10 it. I will call a cab. Sometimes he would say
11 Q. How do you know that — when you say Jeffrey 11 that. Sometimes he would say, don't wony, I
12 called a cab, can you tell me any incident where you 12 will have one of my assistants or III will call a
13 know that Jeffrey called a cab on your behalf? 13 cab. Sometimes I didn't talk to JaiW- .
14 A. I would call him and I would say how do i get 14 Sometimes MI picked up the phone and said she
15 there, Jeffrey. He would say don't worry, I will have a 15 would calla cab.
16 cab come to your house. I will call a cab. 16 BY MR. LUITIER:
17 Q. So, you don't know whether he called a cab or 17 Q. On how many occasions do you claim that
18 not? 18 Jeffrey allegedly told you that he was going to call a
19 MR. EDWARDS: Object to the form. 19 cab?
20 THE WITNESS: Fm, fm not, you know, fm not 20 A. Definitely over 20 times.
21 a psychic. I didn't go to his house in my mind and 21 Q. And you said that on some occasions, to use
22 see if he physically picked the phone up. He 22 your words, one of the girls would call. What girls are
23 probably told one of his maids or something to do 23 you talking about?
24 it. Maybe he called a cab. 24 A. The girls that I would recruit for hint
25 25 Q. So you were finding other girls that you would
25 (Pages 97 to 100)
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1 clothes on; sometimes he had his clothes off. Sometimes
1 take to Jeffrey's place? 2 he had a towel around him. When he walked in the room,
2 3 A Q . . Y A e n s d . you were paid money to do that? 4 3 c w o e u a c l h re ri a g d h y t h n a e d x t t h to e m th a e s m sa a g s e s a ta g b e l t e a r b e l a e d . y W . T e h w e o re u l w d a s s it a
4 5 A Q . . H Ye o s w . much were you paid? 6 5 t e h x e a r c e t . l y I w w h o a u t l h d e t e to ll l , d I m w e o u to ld in in s s tr t u ru c c t t t h th e e g g ir i l r s ls t o to d d o o .
7 6 8 to J A Q e . . f fre $ O y 2 n ' 0 s t 0 h h . o o u se se o , c w ca h s a i t o d n i s d t h yo at u y d o o u o to nc o e k y o o th u e g r o g t i r to ls the 7 8 9 H w e o u w ld o I u t a w ld k o e s u a o l y d f f g t o e e u l t l r t t h s h e h e m o m e r s t . a e k H a e e d o l y f e f i t , t h . il e , d ir s b s o e h I i o n w e s t o h . u e W l d s h e te o w ll e th r e .
1 1 0 9 1 h w o o u A u se l . d ? j W us e t s w a o y u th ld e w d a oo lk r i i n s t o h p e e h n o , u w s a e l . k S on om in e . t im So e m s h e e tim es 1 1 0 1 h g e ir r ls p a to n t t s a . k e H o e f l f ik h e e s r s it h w in h , e ta n k y e o o u f c f a h n e r t a b k r e a , o ta ff k y e o o ur f f
1 1 1 1 2 3 4 5 p s m th o e a e m o i y p d e w l s o e , n e c a e r h t e e h e g l f i s s s i e r , h l s o w o r w u o q s u h u e l o d o a t t a e r l a l n , t v u s h e w n e l q e e t u i d r m o t w h t e e e i , , t d e h m o i h t o h o i d e m r. e r l H t w s h . e o e H y u h l a e w d d e s a m r a n e i s d u w l t t h e ip a r l t t e h e 1 1 1 1 2 3 4 5 p p d a r o o n w c ti n e e e s o H d , n e p t t o r h w e m e f o e m a u r s a l a d s b s a g s l g y e a e . g t h e o i u s ta t l b o e l g f e s t h o . e n H h s e h is o lo s w v t e o e r m d , w a h c i i s p h e . l e o A gs f n f d , l a w y e would
16 massaged.
1 1 1 1 2 6 7 8 9 0 d r d w i o g r a o i h l l r l k . t w u B a T p y s h t i e h t s h r e e e t h s w t t a i a m a t i r s w e s a e . I s w T a t l a h e re i e n rc a n t a d r y i s y g o e k h u w n t t e i a i n t w k h t e o p t h a i t n e h le k e d f k c r t. i i a t l c l r Y . p h o e T e t u h n . e , w Y t o a o o l u k k u a p 1 1 1 2 7 8 9 0 w A gi n e r d l l l w . h o e T S u h o a l e b d o n s n b o e w e l u g e m t i e w a rl l s y o w s l u o a o l g v d u e i n p ld d g r o g h h c e i i e s s t e c s s d n c c a t a h o l l p i p s m . b b a e H a s in s c is a g k g , f m e m e e a h a t s i s h s s s a e b a g g l a i e k e c d ; e k o a . d s n e
2 2 2 2 2 2 3 4 1 5 l a b t n i h t n e a t e o d l k e t h r e h o a l d e e o l g r l m f w t t i , r h . a c l i , y T n u p g b r h r v e e o o e f r b o f e t a s o r i e b t s a t l h y y a ir e o s t p h u r , i r a c i w e g t n e u h a d r t y l . e k t e h T o a i e n r h n n s t e o t y o r h h e o l e d i u i s w s w t r a h a o i k t i l o s h e l m t b h a o i e n o g t o h r f p t e a h a r e l n i i g r t t t s h l e t on 2 2 2 2 2 2 4 3 1 5 m t t W u a a r l h k n s a s s a a t o b k T g v o e i h n e u d e r d t . n e a o v n a f e d s t r h w t y h i t n e e h g i a g n s r u g e w y : n e l a W i ' k v k e e h e s a d d t , o t o k a n i n e t n a d . d l k I a o f . s f w h H d e e e r u i h s w g a n s o v a e u w k l e e d e v d l l i e i k , k r h e e t e d o t . o o k a
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1 sip of alcohol. He said that he has never drank in his
3 2 3 4 5 7 6 . h o s r t t h a h i h n g e e n o h t r g w h l e t e i e n e n w A f t r l e g e a . n o x d s f d T t t f o a . t h t t w o h n h e A e o n e t r l h e t w . n s h e t w a e y e s r o y a a t r s u s e m o a a w w o r m o m s h a o t r i l e t o k m t e a o o i m . n l m i t n h t T r o . e e o h n h T o l e e . i h m r s e f e A t b i r w n n e e T a d d t w h s h r i o e a e n a o r s r e c e t m a h l . w o a . b s A a t a B e b s t t s h e i a g o h r d o o n s b r t o o w e e th m o d a e e m m r t o 2 3 4 5 6 7 h l c t d s if i a i u a s g e r i a g . i l l i y n r e f H e e l o i t t e . f n t e e . y H s . i e H a n e s H i d e h s o e i a t s r s h i a w n d a l i i o a d f t d e . n h h i t d . e H e e H n d y e w e o e t s a o v u a n s e k s i a t r d e m n i t d d o t o o h w o t t k a h o k e t a w k h a c t n h e h i s g a o e n i a p t w e r w k e o v w i a t n e f t s h e d r a s a a s l o c . t m b o f w W r o p h a e k e o e i e n d o l w d i p i n d l o a e i u n w l d o e u r
10 8 9 o th p a p t o h s a T it d e h , l e o o r t e p io p w n o a s s s , i t d e a i f d s fe i r d e r e s e s o n e t f r l t r o h ig t a io h t n b t n s a . e t h x I r t o r t e o o m m t e h . m at b c e lo r s I e th t ink 10 8 9 h y u o n u Q g w . o e u n A t t r w t e h i e t y h r o e . u , o d r e a sc rc ri b y i o n u g d th e i s s c h ri a b p in p g e n a i n n i g n e c v id e e ry n t t ? im e
11 they were from the Body Shop. Then there was toys 1 12 1 Q A. . E E v ve e r r y y b ti r m ae e y w o e u w w e e n n t t t , h e e v r e e r . y time you went --
1 1 2 3 inside W of h t e h n os y e o d u r o a p w e e n rs e . d up the closet, there was a 13 A. Every time I went, every time I went with a
1 1 4 5 m m a o s s s t a o g f e t h ta e b t l i e m . e E w ith e e w r o it u w ld o h u a ld v e b e to s s e e t t o t u h t e f o ta r b u le s u o p r for 1 1 4 5 girl Q . . The exact same thing you describing to a T
16 happened; is that right?
16 him.
17 We would take three big towels. Ho liked one 17 A. To a T.
18 towel laid down by his feet and two big towels laid by 1 1 8 9 Q A. . E M v o e s r t y o ti f m th e e ? time. There has been times where
1 2 2 2 2 2 2 9 0 2 3 4 1 5 h m w w g i o s o o y o u h u g d e l l i d d r a j H o W l w d g s b e . i h i t v . n h w e e a k T n o m t h a u h I e e t l e h d m n a a c w h e a d s e a m m i b f l w k e r i h o r o i k i e u n n u g o h . l t d h r h i A e t a e j . u n d s r m W o d m th o p I h i e m l e w e i n g n , o l i i s t h r k u h o l e e . l e m d , w P s e b y h r a t e e e i o l m a k t w w t h e e y , i e d s t m y r h i h . o n u o e u , c n h h d h e a e i h o d d e f a h is 2 2 2 2 2 2 0 2 3 4 5 1 j I t w u ' a v s a l e k s t e m w n d a e e M M o k n . n e R t R A d t . t h . . h n a C e W e d n r R p e d h h I I a h e T o n e T s n T d a I e w O E t t . h a o N R e n A n : r t n e e t A h W d d w e r m I e e , a a h ' s e y re a n o a t d d o u n d m h o m i d n e n o a y c e s n s i l d a e e s w a t e g w i o g t n s h n e i t w t h h t w t h i h i d h t s e e h e e t e f c r a e o e o t p e p a u i e t e p t . c . n e w h , ? a a a s n n d d I
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1 THE VIDEOGRAPHER: I need to change it. 1 schools. I brought her before that. i brow t her
2 MR. EDWARDS: Do you want to take a lunch 2 before that because I had brought which
3 is now deceased. Before I had — I had
3 break now?
4 after I brought'''. So I brought'''. before
4 MR. LUTTIE.R; Yes.
THE VIDEOGRAPHER: Going off the video record. 5 and that was way before I went to
6 The time is 12:10 p.m 6
7 (A luncheon recess was held.) Q. Now, you said you just got off the phone with
8 THE VIDEOGRAPHER: We're on the videotape 8 someone. Who did you get off the phone with?
9 record. The time is approximately 1:30 p.m. This 9 A. I would rather not say.
10 is the beginning of Tape Number 2. 10 MR. EDWARDS: I think that you are going to
11 have to tell them who you talked to.
11 BY MR. LIJTIiER:
12 Q. All right, ma'am. I want too back and ask 12 THE WITNESS: My mother.
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15 during the lunch break? You called her.
15 MI? 16 A. Yes, I was talking to her because I wanted to
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e you and she in the same class? 17 make sure, I wanted to see if she knew how old I was
18 when I was going to certain schools.
18 A. No.
1 2 2 9 0 1 clas Q A s . y o W W u h w a a y e t b r c e e l h a in s in s . d w W m a a s e s s . s h h e e i n in m fr c o o n m t o p f a r y i o s u o n o r to b e th h e in d? 1 2 2 9 0 1 a fi c g c u Q u r r . e a d t W e o t u e h t l a l d t , u I y r o m in u e g r a f l n r u i , n e l n c e h d ts , t h b a e _ c ty a o w n u d a r i s d t e . 1 s 2 t Y i a m o t u o t , h n y e y o t c u i o m u e ld t n h ' a t t b e
22 Q She was at !caste in high school? 22 you took hieir tli: aain:s if she in fact was a
23 Had to be at t? 23 student at • isn't that the truth of
24 A. I knew her before NM, but yes, 24 the matter?
25 she was definitely — she came into the school. Yeah, 25 MR. EDWARDS; Object to the form. Object to
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1 the form.
1 she was probably a
2 Q. Well, I mean testified earlier, you said 2 THE WITNESS: No, I wasn't thinking anything
3 you knew her from , correct? 3 of that. I was asking her because I know that 1
4 A. I didn't know her from that school. I ;mew 4 can't remember any of the years that you're asking
5 her, I ;mew her previously from that, from that school. 5 me and stuff. So I said, hey, mom, what school --
6 Q What did mean when you said you knew her 6 can you tell me all the schools I went to and how
7 old was I. And when you're talking, it's all
7 fro A m . S — he lived, well, I mean that's where we mostly 8 coming back to me. I don't think you remember
9 associated I s. She lived in a neighborhood 9 everything that when you were 10, 11, 12, 13, 14
1 1 0 1 c sc a h l ool. And now that ( y p o h u o n m e e t n ic t ) io . n T i h t, a I t' s r e r m ig e h m t n b e e a r r I t m ha e t t 1 1 0 1 yea B rs u o t l w d, h r e i n g h s t o o m f e f- o h n a e n e d x , p ri l g a h in t? s it to you, like, oh,
12 her through my girlfriend-. So, and then she 12 yeah, it comes back to me.
13 its- I remember she went to school to 1
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14 when I went to
15 Q. Now, when you said she went to ,you 15 looking at me like that with a smirk on your face
16 like-
16 meant..?
17 MR. LUTTIER: Move to strike. You seem to
17 A. Yes.
18 Q. Who is gi? Ell who? 18 think there is something amusing about this, but
19 A. I don't know her last name. 19 nobody else in the room does.
20 Q. And you both were attending 20 THE WITNESS: I don't think there is anything
21 at the time that you went to Jeffrey Epstein's house 21 amusing about this. Are you kidding? I think it's
22 amusing that all three of you guys are sitting
22 with her?
23 A. No, I just, I just got off the phone with 23 these, you 'mow, defending a sex offender. Are you
24 someone and I realized that I, I remember all the, how 24 kidding mc? That's what i think is flicking
25 old I was and everything when I did go to certain 25 amusing.
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1 BY MR. LUTTTER: 1 MR. EDWARDS: Same objection.
2 Q. By the way, did your mother teach you to use 2 MR. LUTTIER: As 1 understand these
3 that language or did you acquire that in school? 3 objections, none of these are Fifth Amendment
4 A. Are you being — you know what, maybe I 4 objections, coned?
5 learned it in schooL 5 MR EDWARDS: Correct.
6 Q. Is that where you learned that? 6 BY MR. LUTM3R:
A. Maybe i learned it from Jeffrey. 7 Q. And for how many years were you sexually
8 Q. And by the way, when did you quit going to 8 active prior to going to Jeffrey Epstein's house?
9 school? 9 MR. EDWARDS: Same objection.
10 A. I quit going to school right after 10 BY MR. LUTIIER:
11 Q. And please describe for me each sexual act
11
12 • 12 that you performed either with males or with females
13 prior to the time you rust went to Jeffrey Epstein's
13 (it NEM
14 Q. So, obviously you were engaging in sexual 14 house.
15 intercourse with males no later than your 16th birthday, 15 MR. EDWARDS: Same objection.
16 right? 16 BY MR. LUTTD3R:
17 A. If you're asking me when I lost my virginity, 17 Q. Did you have — did you perform any sexual act
18 1 lost my virginity when I was 14 years old. 18 with females prior to the time that you first went to
19 Q. And who did you lose that to? 19 Jeffrey Epstein's house?
20 MR. EDWARDS: Object to the form. I am going 20 MR. EDWARDS: Same objection.
21 to instruct the witness not to answer based on my 21 BY MR. LUTITER:
22 previous notation for the record. This issue is on 22 Q. Prior to the time you lost your virginity, did
23 appeal. And until that Rule to Show Cause Order is 23 you engage in any sexual acts with any males other than
24 resolved, the witness is not going to answer this 24 intercourse?
25 question. Invoking her privacy rights and the 25 MR. EDWARDS: Same objection.
Page 110 Page 112
privacy rights of third parties. 1 BY MR. LUTTIER:
MR. LUTTIER: Okay. I am going to go through 2 Q. Did you have oral sex; that is, did you place
a series of questions then. 3 a male's penis in your mouth at any time prior to the
/v1R. EDWARDS: Okay. 4 time that you went to Jeffrey Epstein's house for the
MR. LUTHER: The first question is who did 5 first time?
6 you lose your virginity to. I heard that 6 MR. EDWARDS: Same objection.
7 objection. 7 BY MR. LUTTIER:
8 BY MR. LIMIER: 8 Q. Have you ever been filmed at any time engaging
9 Q. And when you say you lost your virginity, what 9 in any type of sexual act?
10 act was performed that caused you to lose your 10 A. Have I been filmed? i filmed myself.
13. virginity? 11 Q. And when was that?
12 MR. EDWARDS: Same objection. 12 A. I was 19.
13 BY MR. LUTITEIR: 13 Q. What year would that be?
14 Q. And how many times did you perform this act 14 A. Well, it's '09. So, that would be '07.
15 that caused you to lose your virginity? 15 Q. And would you toll us the circumstances under
16 MR EDWARDS: Same objection. 16 which you filmed yourself in a sex act when you were 19
17 BY MR. LUTTIER: 17 in 2007?
18 Q. Did you perform an act that caused you — 3.8 MR. EDWARDS: Same objection and I am
19 after you lost your virginity, did you continue to have 19 instructing her not to answer. And she will invoke
20 sexual intercourse with other people? 20 her Fifth Amendment rights at this time as well.
21 MR EDWARDS: Same objection. 21 MR. GOLDBERGER: She needs to do that.
22 BY MR. LUTTIER: 22 MR. LUTTIER: Yes.
23 g For how long were you having sexual 23 THE WITNESS: On advice of counsel, I invoke
24 intercourse with individuals prior to going to Jeff 24 my Fifth Amendment rights under the United States
25 Epstein's house? 25 Constitution.
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1 MR. CRITTON: Cindy, mark two pages back. 1 time.
2 There is something i want from there. 2 3 BY Q M . R D . L id U y T o H u E ev R e : r film yourself in a sex act prior
3 4 BY Q M . R W . L h U en 'f l y I o E u R f : il med yourself in a sex act when you 4 to the occasion that you did it when you were 19 in
5 were 19 in 2007, was anyone else performing the sex act 5 2007?
6 A. No. No, sir.
6 7 with y M ou R ? . EDWARDS: Same objection. I am 7 Q. Did you publish this film that you made of
instructing the witness not to answer. Invoking 8 yourself engaged in a sex act when you were 19?
9 ha Fifth Amendment rights as well. 9 A. No.
10 MR. CARTON: She needs to read. 10 Q. Did it go on the Internet?
11 A. No.
11 MR EDWARDS: Okay.
12 THE WITNESS: On advice of counsel I invoke my 12 Q. Did you ever show it to anyone?
13 Fifth Amendment rights under the United States 13 A. No.
14 Q. Are you sure?
14 Constitution. 15 MR. EDWARDS: Objection, asked and answered.
15 BY MR. LUTTiER:
1 1 6 7 sex Q a . c t D w i h d e s n o y m o e u o w n e e r r e e q 1 u 9 e i s n t 2 y 0 o 0 u 7 t ? o fihn yourself in a 1 1 6 7 did T n H o E t s W ho I w T N m E y S se S l : f d I o a in m g a a c n tu y a s l e ly x u p a o l s a it c iv t. e that
18 MR. EDWARDS: Seine objection. 18 BY MR. LUTTIER:
19 MR. LUITIER: How is that Fifth Amendment? 19 Q. For what ptupose did you film yourself in a
20 MR. EDWARDS: You're, you're going to refer to 20 sex act when you were 19?
21 A. On advice of counsel i invoke my Fifth
2 2 2 2 3 1 the M M se R R x . . a L E c U D t — T W T A iE R R D : S N : o — , i t h a a s t k 's e b d e - i - ng filmed. 2 22 3 Am Q en . d D me id n a t r n ig yo h n ts e u m n a d k e e r t y h o e u U f n ilm ite y d o S u t r a s te e s lf C in o a n s s t e it x u a ti c o t n .
24 when you were 19‘?
2 24 5 BY Q M . R M . L y I q M ue IE st R ion : is, did someone request you to 25 A. On advice of counsel I invoke my Fifth
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1 2 film y M ou R rs . e E lf D in W a A s R ex D a S c : t w Sa h m en e y o o b u je w ct e io re n . 1 9 A i n n d 2 y 0 o 0 u 7 ? c an 1 2 Amen M dm R e . n E t r D ig W ht A s R un D d S e : r t A h n e d U t n h i e te o d b S je t c a t t i e o s n C is o n a s ls ti o tu a t s io t n o .
3 right of privacy as well.
3 read.
4 5 my T F H if E th W A I m T e N n E d S m S e : n t O ri n g a h d ts v u ic n e d o er f c th o e u U ns n e i l t , e I d in S v ta o t k e e s 4 5 BY Q M . R D . L id U y T o T u I E vo R lu : ntarily film yourself in a sex act
6 when you were 19 in 2007?
6 Constitution. 7 A. On advice of counsel I invoke my Fifth
7 BY Q M . R W . L e U ll T , w TI i E th R y : o ur invoking of the Fifth 8 Amendment rights, rights under the United States
9 Amendment suggests that you think you're going to be 10 9 Con Q s . t itu D ti i o d n y . o u gain enjoyment as a resuh of filming
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Y ou don't have to answer. 11 yourself in a sex act when you were19 in 2007?
12 MR. EDWARDS: Same objection. I am
1 12 3 BY Q M . R D . L id U y I o T u T v E o R lu : ntarily film yourself in a sex act 1 1 3 4 i q n u s e tr s u ti c o t n in m g h ay e r n n o o t i t m to p a li n ca sw te e t r h t e h F is i l f i t n h e A . m T e h n a d t ment, but
1 1 1 4 5 6 nem y M T o H R u E . w E W e D re I W 1 N A 9 E R i S n D S 2 S : 0 : 0 O 7 S n ? h a e d 's v n ic o e t a o n f s c w ou e n ri s n e g l . , I invoke 1 1 5 6 i t s h s e u r e e i a s r e re p s r o iv lv a e c d y , i l s s a u m e s in h s e tr r u e. c t A in n g d th u e n w til i t t n h e a s t s not
17 my Fifth Amendment rights under the United States 17 to answer.
18 BY MR. LUMER:
1 1 2 8 9 0 C re o fu M n s s R i t n it . g u W t t i o o n a H . n s I w M er : t h A a n t q d u t e h s a t t i ' o s n th ? e sole basis for 1 2 9 0 res Q ul . t o D f f id ilm yo in u g s y u o ff u e r r s a e n lf y in ty a p s e e o x f a in ct j u w r h y e a n t a yo ll u a s w a e re 19
21 MR. EDWARDS: This is also precluded because 21 in 2007?
2 2 2 3 2 4 t a g h p o i p s in e i g s a l t a . o n A a is n n s d s u w u e e n t r h t t i a h l t o t h d s a e e t a q i l s s u e r w e s s i t t i o o h l n v t s h e . e d , S is w o s e u w ' e r e e o ' r n n e o r t e sting 2 2 2 2 3 4 you Q A w . . e N r W e o h 1 p e 9 e n , . w yo e u re f i a lm ny e i d n a y n o i u m r a s t e e lf o in b j t e h c is ts s u e s x e a d c ? t D wh o e y n o u
25 on that as well as the Fifth Amendment at this 25 know what I mean by inanimate objects?
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MR. EDWARDS: I am instructing the witness not 1 content that was on there?
2 to answer based on my previous objection related to 2 A. I, I know that on my behalf thae has been
3 privacy issues. 3 pictures and everything and notes and stuff downloaded
4 BY MR. WI t WR: 4 from
5 Q. Why did you film yourself in a sex act when 5 Q. My question is did you do that?
6 you were 19? 6 A. No.
7 MR. EDWARDS: Same objection based on the 7 Q. Did you give your password or pass code to
privacy issue. She's not answering the question. 8 someone so they could do that?
9 BY MR. LUTTTER: 9 A. Yes.
10 Q. Did you film yourself on a videotape with 10 Q. And who did you give that information to?
11 this, the sex acts when you were 19? 11 MR. EDWARDS: Object, object to the form,
12 A. No. 12 attorney-client privilege.
13 Q. Did you do it on a camera? 13 BY MR. LUTHER:
14 A. Yes. 14 Q. Did you give that information to anyone other
15 Q. Was the camera hooked up to an Internet? 15 than your lawyer who is representing you in this matter?
16 A. No. 16 MR. EDWARDS: Objection. It's attorney-client
17 Q. What type of camera Was it? 17 privilege. And if it was given to people
18 A. Digital. 18 associated with the law firm that this witness may
19 Q. Did it take still shots or video? 19 not recognize as attorney-client privilege, same
20 A. Video. 20 objection. She's not going to answer.
23. Q. And did the video ever find its way onto the 21 BY MR. LUTIIBR:
22 Hemet? 22 Q. Did you give that information to anyone other
23 A. No. 23 than your lawyer or an employee of his law firm in this
24 Q. Did you over post it or any frames from that 24 case?
25 video of you engaged in the sex act when you were 19 on 25 A. No, sir.
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1 your Facebook site? 1 Q. Prior to the time that you gave that
2 A. I have never had a Facebook site, sir. 2 information to your lawyer or someone that is employed
3 Q. You are sure of that? 3 by him, did you remove content from your site?
4 A. Absolutely positive I have never had a 4 A. I have, ever since I've had I remove
5 Facebook site. 5 and I add all sorts of pictures on there.
6 Q Okay. Let me correct that. 6 Q. And when d g id y . o u first start the site?
7 A. Sorry 7 A. That was in
8 Q. You do have a site? 8 Q. Is there anything at all that you ever have
9 A. As of right now, I do not. 9 put on your site since you first opened it that
10 Q. But that's because somebody told you to take 10 you find you would find now to be embarrassing?
11. it down because of this litigation, right? 13. A. Embarrassing? No. I mean, there are some
12 A. No, sir. 12 pictures that are pretty goofy. I don't, if I thought
13 Q. As a matter of fact, you wore ordered to 13 it was so embarrassing, I wouldn't have posted the
14 produce hard copies of what was on your site in 14 pictures on there.
15 this lawsuit, were you not? 15 Q. So that it's clear for the ladies and
16 A. No, sir. 16 gentlemen of the jury, if they are shown content from
17 Q. Did you know that you did produce it? 17 your site from the time you first opened it
18 A. That I produced what? 18 until the present, your testimony is you don't find any
19 Q. Copies of stuff off your in this 19 of that to be embarrassing. You would only characterize
20 lawsuit. 20 it as goofy, some of the things; is that right?
21 A. Oh, I knew that actions were going on like 21 MR. EDWARDS: Object to the form.
22 that sI t that's not why I proceeded to erase my 22 THE WITNESS: Personally in everybody's life,
23 23 people have fun. And when they go out, they have
24 Q. Did you go onto your site and make 24 hut and they do fun things and they make ukaranies.
25 copies that were produced in this case of what the 25 Okay. I don't think anything! have ever posted on
ANIMPali...••••••••••••441.2.2•14•4••••:••••••%•••••••41•a•Illoorttf.•••••
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1 would be embarrassing to me, no. Everybody 2 and A t . a k J in u g st s c h e o r t t s a i a n n p d i c d t o u i r n e g s s o tu f m ff l e ik d e r i t n h k a in t g alcohol
2 can see it. 3 Q. Is that it, just pictures of you drinking
3 BY MR. LUTlER:
4 Q. That's wasn't my question, whether everybody 4 5 alcoho W l an t. d E ta D k W in A g R sh D o S ts : ? Object to the form.
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9 that's ever been posted on your ElMisite to be 10 9 BY Q M . R W . L h U a T t d T o I E yo R u : mean modeling
10 embarrassing?
11 A. 1m odeled for
13. A. No, sir.
12 MR. EDWARDS: Object, object to the form. 12 Q. And when was that?
13 A. hill
1 1 1 3 4 5 B yo Y u Q M a . n R y N . e L o m U th b T i a n r H g ra E o s R n sm t : h e a n t t or humilia s t i i t o e n w , c o o u r l r d e h c a t? v e caused 1 1 4 5 gen Q tle . m A e n n d o w f t h h y e d ju e r i y n w y h o a u t d th e o sc s r e i b p e ic f t o u r r e th s e d l e a p d i i c e t? s and
16 MR. EDWARDS: I would object, object to the 1 1 6 7 A Q . . M W e ou in ld a y ou say p t o h s a i t n t g h ey were sexually
17 form.
18 THE WITNESS: No. For what reason? 18 suggestive pictures?
19 MR. EDWARDS: Object to the form.
19 BY MR. LUTHER: 20 THE WITNESS: No, sir, I don't. I think that
2 2 0 1 Q A . . N I h o e , a li r s d t e y n o u to r q m u y e q st u io e n st . i o N n o . , sir, is the 21 people try to advertise for their, you know, their
22
22 answer.
23
2 2 3 4 Q A . . N N o o , w I h d a o t ? n ot think anything is embarrassing en 24 Just like if you were going to buy a
25 car, there is a sexy girl next to it. That's what
25 the
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6 7 BY Q M . R Y . L o U u h T a H v E e n R e : v er suffered one iota of damage as 7 THE WITNESS: Sure, if that's what, how you
8 a result of anything that appears on your site, 8 want to put it. Like that's the United States.
9 that is appears now or ever did appear on it, correct? 9 Are you kidding me?
10 BY MR. LUTTIER:
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your site or anything 11 Q. That's, that's the society and the age that
12 that's ever been put on your site, would you say 12 you grew up in, right?
1 1 3. 3 5 4 reflect M T s p H R o E . s E i W t D iv I W e T l N y A E o R S n D S y S : o : u N ? O o b . ject to the form. 1 1 14 3 5 in i A Q n . . t ho F I s o t e h r p i n e ic x k t a u t m h r a e p t s l e y , y , o t o u h u e g d r le e o w v n e u o l p o t f i f i n n ch d i e t , t s o s to b t o h e . a o t f y fe o n u s w iv e e r , e
16 correct?
16 BY MR. LUTTIER:
17 Q. Would it be the of thing that you would 17 A. No,1 would wear it to the beach
18 like your to see? 18 Q. Okay. I mean, nudity, you don't find nudity
19 to be offensive, do you?
19 A. No.
20 A. Yeah, 1d o.
20 Q. Why not?
21 A. That's not something that a 21 Q. You do?
2 2 2 3 s a h n o d u m ld a s k e in e g w m he c n m a o t 2 ie 1 s -y w e i a t r h - o h l e d r i s fr i o e u n t d h s a . ving a good time 2 2 2 3 A Q . . I A d n o d . when did you first find nudity to be
2 24 5 not Q w . a n W t y e o ll u ,s r pecifically wh t a o t s i e s e it ? that you would 2 2 4 5 offe A n . s iv N e u ? dity was offensive to me when I walked into
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1 2 k w f a fr s e o y n 's a h m o a u s s s e a a g n e d ta I b h le a . d T to h g a e t k t n in a d k e o d f o fo ff r e h n i d m e d w m he e n , y h o e u 1 2 3 wil M T l j H u R s E . t E W le D t I T W y N o A u E R k S D n S o S : w : N , O w o b w h j e e , n c th t a a t o t 1 , 3 w th -y h e e e f a n o r r - a m o , l w . d h li e tt n le a — I
3 4 kno Q w . . And so what did you say to indicate that you 4 5 g o i f r m l is o n in ey f r a o n n d t a o l f o a t 5 o 0 f - p ye o a w r e -o r l w d i m th a a n b , w ig it h h o a u s lo e t t hat
5 were offended? 6 she's never saw before and that promises you that
1 6 0 8 7 9 i fr w o Q m A a A s . . . a w I N W = w i o i h L n a , a m s Ii t n p d y w e a i q d r a i v u d I l o k e $ s u i s n 2 a s t g i y 0 o a ? 0 i n s n . I h i t s I o d e w w a i l d l a h m n s a ' a t t a n s d l a s i i t d y io t l a n y e n o . g y u W t i s h rl h a i n c y a g o ? t i b d n e o in c y a g o u u se w ant 10 7 8 9 h y m h e o e o u c i d n a a e f n l n l u y g s e o t e n h m t c i n y e e o g s d u y y a o s o y u t u a u w n a ff d n a f , d n r o o t p , h m u a , t n B I s ' d m r t a h th i z w s a i l o a t , r y a l t l o h n i u n d s m o h y e o m ig u c u h r a c t h n h g e g . o a e d A a t . n n d d i
13. Okay.
11 Me to say?
1 1 1 2 3 4 am Q A ju . . s t M W a a s e k 'a l i l n m , g y . o y it u o 's ' u r e n w o ta h t a l a k t i q n y u o g e u t s o d ti m o id n e . o li f k w e h I' a m t i s w tu a p n id t. , 1 1 1 1 1 2 4 3 5 p h a e e li a t r A k e tl n a e h s d e t s r o h u e u e r e a c w s n h a d y h n o e a t u r s l e i t t t h a t o l a n e s t d e p y l e e o i t a a u t k l ' l e r i e t t t h t l o g e a u o e p c in , e h g a a t n h k to d , e a r i b e f l e i h b t b t e e l e c e w t a t e u a s r n e ts
1 1 1 6 5 7 a y n o d u Q r i s . d to o Y o n o k 't u a y p o w p u e r t n e h t c e t ia o re t e J , r e i i t g f . f h s t . ? T his friend of 1 1 6 7 Y w e h a e h n , y I o d u e g fi e n t i t o e ld ly e a r, ll I o w th e in d k h t i h m a t t o lit s tl e e e b it r a b i e n c w a a u s s h e . I
18 was fucking scared.
18 A. Yeah.
19 Q. And she told you some things before she took 19 MR.. LUTTTER: Well, that's all
20 THE WITNESS: It's scary.
20 you there, correct?
21 BY MR. LUTTIER:
21 A. Yeah.
2 2 2 3 Q A. Tell me w sa h i a d t , s h h e e y , t o d l o d y y o o u u . w ant to make $200. 2 2 2 3 7batli t t h t a le t s y o o l u i ' l v o e q g u o y n i e s w to h s a i t n y c o e u y r o u filed the
24 I said yes, that would be great; how. She says, well, 24 lawsuit told you, right?
25 you just have to walk upstairs, and you have to, we just 25 A. Not at all.
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1 have to massage a guy. And I am like, okay and I am 1 Q. By the way -
3 2 l w ik o e r , r y w . e H ll, e h i o s w a n o o ld ld is g t u h y is . g A u n y d . t O he h , c h o e n v is e r o s l a d t . i o D n o p n re 't t ty 3 2 S A. s N - o d t i d at y a o l u l. ever go to a or a
4 much said, hey, you know -- I said no a couple of times, 4 before you filed this lawsuit?
5 and I said I really — I was uneasy about going. I 5 A. Not that I mall.
6 Q. Ever in your entire life?
6 really don't want to go.
8 7 becaus A e n s d h e th p e e n rs i u t a e d s e c d a l m at e e d in th to a t i t I . e i n w de a d s u a p y o g u o n in g g l ittle 8 7 A. M N R o . t E th D a W t I A re R c D al S l. : Object to the form, asked and
9 girl that was stupid and naive and went to go massage a 9 answered.
10 50-year-old man naked on a flieldng massage table and got 1 10 1 BY Q M . R D . L id U y T o I u T h E a R v : e anything traumatic happen to you
1 12 1 paid Q $ . 20 A 0 n f d a a i f t te . r that occasion that you have just 12 in your entire life before you filed this lawsuit?
13 described, you went back how many times, 50 times? 1 1 3 4 A Q . . N N o o t . h ing ever was traumatic to you, right?
14 A. More than 50 times.
15 Q. Each time you went back voluntarily, correct? 1 1 5 6 A Q . . N W o e . ll, let me put this way so that it's clear
1 1 6 7 A. M V R o . lu E n D ta W ril A y R . DS: Object to the form. 1 1 7 8 t f h o e r t d h a e y j u y r o y u ; fi A le n d y t t h h i i s n g la t w ha s t u h it a y p o p u e n w e o d u t l o d y d o e u sc p r r ib im e a t s o n ot
18 BY MR. LITiTIER:
19 Q. When you wart with1 M, you went 1 2 9 0 being t M ra R um . E a D tic W , r A ig R h D t? S : Object to the font.
2 2 0 1 volunt M ar R ily . , E co D r W rec A t R ? DS: Object to the form. 2 2 2 1 1 w T as H y E o u W n I g T e N r t E h S an S : 1 3 N t o o t h th in e g d h a a y p l p w e a n s e d b t o o m m t e ha fr t om when
22 THE WITNESS: Yes, sir.
23 was traumatic at all.
23 BY MR. LUTHER:
24 Q. Mr. Epstein never made you do anything against 2 2 4 5 BY Q M . i H t a L s U a i n T y iE th R ing : traumatic happened to you since
25 your will, correct?
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1 know you're wrong. You know you're wrong, because you
1 you filed this lawsuit? 2 fucking messed with us. He messed with us. He touched
2 3 ' A Q . . Y W o h u a d t, a w m h n a t r i h g a h s t . h appened to you since you filed 3 us. He's sick. You are disgusting. You make me throw
4 up.
4 5 this A la . w P su sy it c t h h o a l t o 's g t i r c a a u ll m y a m ti e c s ? s ed me all up in my head. 5 Q. You weren't 13 at the time, were you, ma'am?
6 Okay. here's, here's a young girl 13-years-old of age 6 A. Iwas 13. Iwas 14. Iwas 15. I got
7 going and taking myself every single day to a man's
8 9 h m o y u , s m e, y o b k o ay o , b t s o , y s o h u o w h o m w y , b t o h d a y t , I t o ha s r h d o ly w d m id y n ' v t a e g v i e n n a , h t a o v s e h . ow 10 8 9 Q A Q . . N Y o o , u t h ha a n d k l e t a h r e n L ed o r t d o h e a n v g e a g m e e i r n c y se . xual relations
1 1 0 1 Okay. Andl would bring all these girls and I would 11 with men someplace apart from Mr. Epstein, had you not?
12 beg them, come on, come on, we're going to make 5200. 12 A. I had learned from Jeffreythat it was easy
13 am psychologically fucked up in the head from that. Now 13 money.
14 I feel so incredibly bad that 1 brought any of these 14 Q. Are you saying —
1 1 5 6 little g O irl k s a t y h . e r I e h . a I v t e 's g s o ic t k t e o n l i i n v g e . with this for the 1 16 5 Q A . . E -- a t s h y e m fa o t n h e e y r . o f your child paid you money to
17 rest of my life. That man right there he has shown me 17 have sex with you?
18 that later on in life, all I've got to do is show a 18 MR. EDWARDS: Objection to form.
1 2 9 0 s li o tt l I e c b a i n t m of a v k a e g s i o n m a a e n m d o a n l e it y t . l e A b n it d o n f o f w uc f k o i r n t g h b e o r o e b st s of my 1 2 9 0 T M H R E . E W D I W TN A E R S D S S : : N A ot n a d t j a u l s l t . — objection to the
21 life,1 have got to try to keep from my son that his 21 form.
22 mother was a prostitute to put bread and butter on the 2 2 2 3 T M H R E _ E W D I W TN A E R S D S S : : Y W ou a 'r it e u s n ic ti k l . he asks a question.
23 table for him.
24 BY MR. LUTRBR:
24 Q. Well, in fairness -- 25 Q. Now, let's go back to your site. Are
25 A. So live with that.
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1 2 but Q te . r o - n - t y h o e u t a w b e l r e e f n o 't r a y o p u ro r s s t o it n u , t e w t e o r e b r y e o a u d ? a nd 1 2 t f h o e r r a e any other pi w ct h u i r c e h s y o o th u e w r t o h u a l n d o n n o e t s w o a f n y t o y u o u m r o s d o e n l i t n o g
3 A. Really? For years I was. 3 see?
4 Q. That's not why you became a prostitute, was 4 A. Of course.
5 Q. What other pictures
6 5 it? A. Are you -- what are you trying to say here? 6 A. Is there any pictures that you wouldn't want
7 Q. You didn't become a prostitute because you had 7 your son or daughter to see?
8 Q. Well, ma'am, actually there is not.
8
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10 Q. Just answer my question, ma'am. You didn't 10 money.
11 become a prostitute because you had to feed your son, 1 12 1 Q A . . C Th an er y e o i u s a a n lo sw t o e f r p m ic y t u q r u e e s s t t i h o a n t n I o w w o ? u ld not
12 did you?
13 A. I don't even know how to answer this. 13 want my son to see.
14 Q. That's because you know the answer is no, 14 Q. Which ones?
15 don't you? You were a prostitute before your son was 15 A. Now what?
16 ever born, weren't you; isn't that right? 1 1 6 7 Q A . . W W h h i i c c h h o o n n e e s s ? ? Multiple ones. Do you want to
3.7 A. You're an asshole. 18 bring them out so I can point them, pinpoint them to
18 Q. You were a --
1 2 9 0 Q A. . T Y h o e u ' t r r e u a th f h uc u k rt i s n , g d a o s e s s h n o 't l e it . , ma'am? 1 2 2 9 0 1 you Q . . M I R w . a E nt D y W ou A t R o D de S s : c O rib b e je t c h t e t m o t f h o e r f th o e rm ju . ry.
2 2 2 2 1 3 A Q A . . . T Y R h i o g e u h t k t r . u n t Y o h w o h u w u r w h ts a e ? r t, e y a o p u r 'r o e s t f i u tu ck te i n — g representing 2 2 2 3 THE WIT pi N ct E u S re S s : , 1 on h e a s v o e f a m lre e a t d a y k i t n o g ld s y h o o u ts , . the
2 24 5 s l o it m tle e o g n ir e ls t , h a a n t d t o t o o k o k a t 1 h 3 e - m ye i a n r - t o h l e d ir l h it o tl u e s g e i . r l A , m nd a n y y o , u m any 2 24 5 13? Q M . R W . L h U at T d T o I E yo R u : mean taking shots? Are you
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1 talking about alcohol? 1 There is some pictures that I don't want my son to
2 A. Taking tequila shots. 2 see. There am some picture that, sure, he can
3 Q. Okay. You were out parting, right? 3 see. Now what? What is the point here? You keep
4 A Yeah, like normal people do like you're going 4 on asking me these questions 20 times.
5 to probably do after this with all your flicking money. 5 Does this have anything to do with what you're
6 Q. And nobody was forcing you to do anything 6 trying to get to, because I would really like to
7 that's depicted on these photographs that have appeared 7 know.
8 on your 8 BY MR. LUTTTER:
A. Nobody forced me to do it, no. 9 Q. Which pictures would you not want your son to
10 Q. And you do, of course know that eve 10 see?
11 you have ever put on =Ellis still on don't 11 A. I dim There was like 450 pictures I
12 you?
12 posted on
13 A. No, I don't know. 13 Q. And just so that we can understand your
14 Q. And you do realize that all of that is 14 memory, if the jury sees the pictures, so that it's
15 subpoenable and can be obtained? 15 clear, as you sit here today, you can't describe any of
16 MR. EDWARDS: Object to the font. 16 the pictures I dn't want your son to sec
17 THE WITNESS: Cool. 17 other than the modeling pictures?
18 BY MR. LUTTIER: 18 MR. EDWARDS: Hold on.
19 Q. Now, can you think about — 19 MR. LUTTIER: Is that right?
20 A. Who cares? 20 MR. EDWARDS: I would object to the form And
21 Q. — any particular incidents that are reflected 21 if counsel wants to show these pictures —
22 in pictures on your site that you would find 22 THE WITNESS: Thank you.
23 offensive to show your son? 23 MR. EDWARDS: -- to the witness for the
24 MR. EDWARDS: Object to the form 24 witness to identify which ones that her son
25 25 would—
Page 134 Page 136
1 BY MR. LUTTIER: 1 THE WITNESS: I agree.
2 Q. Other than the 2 MR. EDWARDS: — want to see and which ones
3 WITNESS: No, no, no, no. 3 she does not, okay. If she can't remember every
4 BY MR. LUTTIER: 4 picture, she's given her answer.
5 Q. Do you remember any kind of — 5 BY MR. LIMIER:
6 A. No, I don't 6 Q. I don't expect you to remember but I do want
7 Q. Any kind of — 7 to find out whether your memory is good enough to
8 A. What are you getting to? No, I don't. 8 remember any of the ones that you wouldn't want your sec
9 Q. Any kind of party that you were ever at that 9 to see. So, if you have told me everything that you can
10 you had sites, pictures on your site about? 10 recall, I am happy to accept your answer.
11 A. No. 11 So, is there any other photographs that you
12 Q. Did rsever -- were the-re ever any pictures 12 can tell the ladies and t rxm of the jury that
13 on your MINE site of you engaging in any type of 13 have appeared on your that you would not want
14 conduct with other females that you wouldn't want your 14 your son to see?
15 son to see? 15 A. I just told you. There are some pictures that
16 A. Yeah, of course I would not want my son to see 16 I wouldn't mind him looking at. Most of them arc hint
17 that. 17 Q. And did you understand my question?
18 Q. Describe what you were doing in those 18 A. And, and some of them, I would not want him to
19 photographs for the jury. 19 see.
20 A. I don't remember, dr. 20 Q. Tell me the ones —
21 Q. So, how do you know you wouldn't want your son 21 A. Like my attorney just said, if you want to
22 to see them?
22 bring me the pictures, I will pinpoint them out to you.
23 A. What are you getting to? 23 Q. I want to know —
24 MR. EDWARDS: Object to the form. 24 St I have posted over 400 pictures on
25 THE WITNESS: What is the whole point of this. 25
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1 Q. Okay. So that we're clear, you can't, as you 1 Q. And what did you tell her about what she was
2 3 s n i o t t h w er a e n t t o y d o a u y r r s e o m n e t m o s b e e e r any photographs that you would 2 3 goi A ng . to I b s e a i d d o , h in e g y ? , Ill, do you want to go to this
4 guy's house. He will give you $200 if you stand there
4 A. Yeah.
5 6 Q A . . - Y - e o a th h e , l r e th a a n n , l s e o a m n e d p a ic m tu n r e s s u r - e - remember a lot of 5 6 7 n h it a a . k n S e d h d , e . a n H s d a e i t d h is n e o g n o . w i S n e h g 'r e e to s g j a o a i i d c n k n g - o o to a f f l e c a o a n v u d e p e . l e ja D o c o u f t l y a im o te u e i s w n . a h M n is t o t r o e d o
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MR. EDWARDS: Argumentative. 8 than a couple of times. Then I convinced her just like
9 convinced me.
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19 Q. When you say partying, what do you mean? 19 it
20 A. Just dancing and drinking a lot 20 Q. So, a knew exactly what was going to happen
21 Q. Okay. And are any of the other girls that you 21 when you took her over to Jeff Epstein's house, correct?
22 took to Mr. Epstein's house, are any of themauirned in 22 MR. EDWARDS: Object to the form.
23 any of these pictures that you have on your 23 MR LUTTIER: Correct?
24 THE WITNESS: Correct
24 site?
25
25 A. Yeah.
Page 140
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1 BY MR. LUTi'IER:
3. Q. Who?
2 Q. You told her?
2 A.
3 A. 1 told her.
3 Q. who?
4 Q. She went over there with eyes wide open?
4 A.
5 Q. And why don't you tell the court what your 6 5 A Q . . H Ye o a w h , lo m n i g n d h a y d o y u o s u h e b e w e a n s g 1 o 4 in y g e a to rs M ol r d . . E pstein's?
6 relationship with a is?
7 A. We're good friends. We have been good friends 8 7 A Q . . B O e n f l o y r a e c y o o u u p d le e c o id f m ed o t n o t h in s v . ite your friend over?
for years.
9 Q Lifelong friends, haven't you been? 10 9 A Q . . A Ye n p d . then did you tell your friend N g that
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12 A. Yep.
12 A. No.
13 Q. When did you tell her you were getting paid
13 Q. One of your best friends?
14 money to take her there?
14 A. Sure.
15 Q. And how old is she as compared to you? 15 A. When did I tell ha?
16 A. She's maybe six months younger than I, or six 16 Q. Yeah.
17 A. I told her — when did I tell her? I told her
17 months older than I am.
18 Q. Did you go to school with her? 18 the first time I told her about Jeffrey.
19 Q. So, the first time that you told your friend
1 2 2 9 0 1 Mr. Q A E . . p s N A te o n in . d ' s d ? id you ever take her over to 2 2 0 1 C he a r r a o t l y t h W e . s a a n m d e a ti s m ke e d y h o e u r w to e g re o g to o i M ng r . t o E p re s c te e i i n v ' e s , m y o o n u e t y o l a d s
22 a result of taking her there; is that correct?
22 A. Yep.
23 Q. At the time that you took her over there, was 23 MR. EDWARDS: You're talking about
24 right?
24 she one of your best friends?
25 MR. LUTIIER: Pm sorry.
25 A. Yes.
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1 2 M TH R E . E W D I W TN A E R S D S S : : F O ro k m ay w . hat I recall. Maybe I 1 2 c s o o u I l c d o n u 't l a d f f b o e r d th , e th c e o o n l e w ki d th . in I g w s o th u a ld t b w u e y re w o h u a t t , e y v o e u r k w n a o s, w ,
3 told her I was making money. Maybe i didn't. 3 4 was Q c . o o A l n th d a w t d h a e y re . did you bank? Where did you put
4 BY MR. LUTTIER:
5 this money that you saved?
Q. Which was it?
6 A. Ina hiding place in my house.
6 A. I don't know. I forgot.
7 Q. It would be an, an event that you would 7 Q. So, you didn't put it in a bank?
8 remember since it was one of your best Mends that you 8 A. I was 13 years old. No,1 didn't put it in a
10 9 were d M oin R g . t E h D is W w A it R h, D ri S g : h t O ? bject as to the fora 10
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11 which houserou referring to?
11 argumentative.
12 THE WITNESS: I brought every girl I could 12 A. In y
13 End because it was an extra S200. 13 Q. At your fkther's?
14 A. Yeah.
14 BY MR. LUTTIER:
15 Q. And you didn't think there was anything wrong 1 1 5 6 Q A . . A N n o d , n d o id t a y t o t u h e te b l e l g y i o n u n r i n d g a . d a I b to o l u d t m it? y dad that
16 with it, right?
17 A. Oh, I knew there was definitely something 17 1 was cleaning houses later on.
18 Q. And was that a true statement?
18 wining with it
19 Q. All right So, you consciously knew that you 19 A. No.
20 shouldn't be doing what you were doing; is that a 20 Q. So you lied to your father?
21 A. Yeah.
21 correct statement?
22 Q. Did you tell. anything else before you
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25 girls did, isn't that funny.
Page 144
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1 Q. It was your free choice though? 1 2 E qu v i e c r k y t 3 h 0 in m g i w nu o t u e l s d . b W e t e a k w e i n ll c b a e r e in o a f. n d D o o u n t ' . t w W o e rr 'r y e . g I o t' i s n a g
2 A. Yeah, free choice.
3 to make $200.
3 MR. EDWARDS: Objection.
4 Q. Each?
4 BY MR. LUfl1ER:
5 Q. And it was free choice to dolt? 6 5 A Q. . E R a ig c h h t . . And did you tell her anything about,
6 A. Yeah.
7 Q. And she did it wide open because you told her 7 anything she should say about her age?
A. Not that I recall. I said just don't say
8 exactly what was going to happen?
10 9 Q A . . O An h d , y i e t a w h a , s it , i w t w as a s s o — e a a s n y d , y le o t u m d e i d te i l t l f y o o r u th . e 10 9 any Q th . in W g. hat do you mean? I don't understand what you
11 mesa.
11 money, is that right?
12 A. At that time, yes, I did, after walking into 12 A. I said don't say anything.
13 his mansion. And after my dad, he had to only buy me 13 Q. Don't say anything about what?
14 Dollar Store clothes, you drum right I did it for the 1 1 4 5 Q A. . D O o h n , s 't o s a y y o u an d y id th s in ay g s a o b m ou e t t h y i o n u g r t a o g h e. e r about age?
15 money.
1 1 6 7 mo Q ne . y t D h i a d t y y o o u u s g h o a t r p e a w id i t b h y Jeff Eps o te r in .. f or b a r n i y n g o i f n t g h e 1 16 7 Q A. . A Ye ll s r . ight. Tell me as best as you can recall
18 what you told--
18 ha?
19 A. I said.. --
1 2 2 9 0 1 wit A Q h . . t he N S m o o , , o y n n o o e u t y t j t h u h a s a t t t l k y e r o e p u c t a g th l o l a t t f m ro o m n e J y e . f f W rey h a E t p d s i t d e i y n o t u o do 2 2o 1 wh Q at . y o W u a to it l d a minut w e. i t L h e r t e s m p e e c f t i n to is a h n m y y q q u u es e t s i t o io n n s a — sked
22 about age?
2 22 3 biin A g . I actually saved a lot of it. I would save a 23 A. I said N., don't say anything about your
24 age.
24 lot of it, and i would buy clothes, clothes that I
25 didn't have. I would buy shoes, shoes that my father 25 Q. Did you say why?
4333.3. ,3“J..+.1.33WORMINIIM.33.3.3a.•;33333.3 3.3 4.3...{..• 36 (Pages 141 to 144)
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1 A. Well, I said we're not over 18, and this is 1 shirt off and you have your panties off. I didn't say
2 like really bad. This is like really illegal. We're 2 anything about being -- how comfortable are you when
3 not supposed to even be here, so don't say a damn thing 3 you're naked in front of a 50-year-old man? I didn't
4 say anything about her being comfortable, xou know,
4 about your age.
5 Q. Anclimsaid all of the things that you just 5 just be comfortable, be comfortable naked,M. What do
6 said here ton.. before she went to Mr. Epstein's the 6 you want me to say?
7 Q. Did you tell her anything about Mr. Epstein
7 first time?
8 A. Yes, sir. 8 not being an individual that would request her to do
9 Q. You, according to you then, you knew at least 9 anything that she wasn't comfortable doing?
10 at that point in time, or were of the belief that what 10 A. No, I didn't say anything like that. I said,
11 you were doing was illegal? 11 I did say everything is going to be okay.
12 A. Yes. 12 Q. You didn't say any words to the effect of --
13 Q. But you did it anyway? 13 because I don't want to attempt to quote exactly --
14 A. Yeah, because I am the bad guy, right? 14 that, that Mr. Epstein never asks anybody to do anything
15 Q. Actually, at that point in time that you first 15 they don't want to do?
16 went to Mr. Epstein's, had you done other illegal 16 A. No, I just brought her there.
17 things? 17 Q. — or words to that effect?
18 A. No. 18 A. No.
19 Q. None at all? 19 Q. Did you convey that message to her in any
20 A. I smoked weed. 20 manner before you took her there?
21 Q. That was the only other illegal thing you had 21 A. No. I said let's go. Don't worry. We're
22 done? 22 going to make $200. We'll be in and out.
23 A. Yeah. I smoked weed. 23 Q. And in fact, Mr. Epstein never forced you to
24 Q. Okay. And what, if anything, did you tell 24 do anything that you didn't agree to do, did he?
25 M. about Mr. Epstein himself before you took her to 25 A. Nope, but we were — you know, he pushed on
Page 146 Page 148
1 his house? 1 it. He pushed on us. Like if, for instance, when he
2 A. I said oh, my God, this gay is so rich. He 2 was on the table and his penis, he was, it was out. He
3 has so much money. Oh, you're not going to believe this 3 was naked. He would pull my hand towards -- this is his
4 house when you see it. Ws absolutely gorgeous. Oh, 4 penis. He would pull my hand towards his penis and say,
5 he has, he like lives right on the water. He lives on 5 oh, just come on, come on. And I would be like no, no,
6 the Palm Beach Island which is like really expensive. 6 because T wasn't comfortable. I would say no.
7 And I was very intimidated. !just told her how 7 Q. Do I understand your testimony from this
8 wonderful his house looked and how, how much money he 8 morning, you never touched his penis?
9 had. 9 A. I never touched his penis, but he would pull
10 Q. Did you tell her anything about whether or not 10 his hand, my hand towards his penis.
11 Mr. Epstein was respectful? 11 Q. And when you said you were uncomfortable, that
12 A. I said, yeah,1 was like don't worry. He is, 12 stopped?
13 he is an easy-going guy. He will give us our money and 13 A. Yeah.
14 we will leave. 14 Q. When you first went to Mr. Epstein's, the
15 Q. Did you tell him anything did you tell her 15 first time you went, . was there -- I mean this
16 anything about whether or not she had no worry that if 16 friend of yours, , was there with you?
17 she didn't want to do anything, that Mr. Epstein 17 A. Uh-huh. Yes.
18 wouldn't push her or ask her to do anything she wasn't 18 Q. What did she tell you before you went there
19 comfortable with? 19 about what Mr. Epstein was like?
20 A. I said just, I said do what you want. Do, you 20 A. She said, hey, there is a 50-year-old or
21 know, be as comfortable as you want to be. I didn't 21 whatever old man on, in this huge, in this huge mansion
22 want to make her feel uncomfortable or she wouldn't go. 22 and we can make 5200. So, do you want to go? All we've
23 Q. Did you tell her that Mr. Epstein wouldn't ask 23 got to do is massage him And I was very scared. And I
24 her to do anything that she wasn't comfortable doing? 24 was, like, are you kidding me, like I am scared. But
25 A. I said, listen, he films when you have your 25 she convinced me into doing it and I went there.
•2•40.4fetmblthiakedeam.I.,
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Q. Did she tell you anything to the effect that, 1 A. I did not voluntarily take my top off the
2 3 4 s d o o m n A ' e t . t w h o i S n r h r g y e y , s o M a u id ' r r . e d E o n p o n s t ' t t e c v i o e n m o w n f y o il , r l t I n a w b ev l i e l e l r d h o a a s i n n k d g y l ? e o u th t i o n g d s o . 2 3 4 f h i a rs d Q t g t . i o m n D e e . i t d o y M ou r. e E v p e s r t e te in ll ' s a n an y d o v f o y l o u u n r t a f r r i i l e y n d re s m th o a v t e y d o y u o ur
6 5 S sa h f e e . s a S id h e d o d n id 't s w ay o r t r h y a . t J w u e s ' t r , e y g o o u i n k g n o to w b , e w s e a 'r f e e g b o e i c n a g u s to e b I e 5 6 7 top Q A ? . . T D h id a t I y s o a u y v th o a lu t n I t — ar ily, you went and took your
7 was very concerned about that. 8 top off without even being asked?
8 9 Q. M W R h . a E t D d W id A sh R e D m S e : a n O b b y je - c - t to the form. 10 9 vol A un . ta N ril o y t d th o e a f n i y rs th t i t n im g. e . H T e h d e i r f e ir c s t t e t d i m m e e . I did not
1 1 1 1 0 2 1 3 BY Q M . M T R — H . R L w E . U E h W T e D n T I W T s IE N h A R e E R s : S a D S i S d : : w T S h e a ' a r m t e w e g o e o ' i b r n e j g e o c t b t o i v o b i n o e . u s s a l f y e n ? ot going 1 1 1 1 2 1 3 4 you Q ; i s M M t A h R R n at d E L r e i D g U a h W T s t? I A IE R R D : S : I m O e b a s j n e ta c n ti d o i n n t g o r t i h gh e t f t o h r e m re . with
14 to get hurt. 15 THE WITNESS: No, was not —
1 1 5 6 BY Q M . R O . k L a U y. T A H n E d R d o you know — what was she talking 1 1 6 7 T M H R E L W U I T TN H E E S R S : : W G a e i t t , your story w st h r a a t i e g v h e t r —
1 1 7 8 abo A u . t , p I h g y u s e ic s a s l t l h y a b t' a s n t n h e e d w ? a y interpreted it when I 1 1 8 9 MR. L w U as T t l h I e E r R e : — Whatever the last name was.
1 2 2 2 2 2 2 9 0 2 1 4 3 5 w s w m g h o a o a i i s Q n A s n n s ' 1 t g . . a o 3 h g f t , D a N f o e s . v d i u e o e d T , j r . a h e t s a c o S . i h k u s h d e e l a e a o s m r t a j m a e u y y n . s s p a y t , H n a t l t h e o n y e g i l t t n i d s h s s g , i o m n g b y f g o a f e o . i c , t u n o k g H g d , o t e s o h t o i c n e n l a i ' m t k e l t p h f w e a f e s m s e a r t h c n e u a t i t . r s s t b t s h T o l a a e a a t g d g t e k e s o y e a d ? o n , m u d a n y d he's 2 2 2 2 2 2 0 2 1 3 4 5 B of Y t l t Q h i o M s e . t m s e R T e n Y e H . b t a L o E o o n u U o d W J k m e T t s f I h e f H T t r e n h e N n E t a y i E o t R s . h y n S H e e o S d u e l : e e k w a e i r p t l l h l i t e , e t e r t r h l t o l o e o y s d w m e o a u a y d a s i w t n a s h r d h i a i t a e t t s i t s h o n , t e n g o t h s t t d a h e h o i r e e d e . r c e w j o u n v a s e e s t x r a t
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1 2 ejac Q u . l at S e o , , a y n o d u t h k e n n e w yo a u l l g o et f p th a a id t b a e n f d o r y e o y u o 'r u e w ou e t n t t h t e h r e e . 1 2 3 w B so i e m b r l e e e t a v h c e i q n r u s g e i r y . e o d W u w p e i r u t e h t t o t h h n e e s i t e B ? b ib o l o e k v s e t r h s a e t o y n o u it , k o e r p t w b a o s o t k h s is t hat
3 first time? 4 A. It was there already.
4 6 5 mo A Q re . . th U A an h n - d o h n a u e c b c , o o y c r e c d s a i . s n i g o n to t o y o g u o , i y n o i u ti a w ll e y r e a n a d sk y e o d u b s y a i h d e n r o o ? n 6 5 7 reli Q A gi . . o u W Y s p e a s l s a . c th e i ? s a book that you got from some
7 8 A Q . . ! S s o a m id e , h I o s w a i y d o n u o d . e I c i w d a e s d s y c o a u re w d e , r y e e n s ' . t scared any 8 9 Q A . . W I d h o e n r ' e t r d e i c d a y ll o . u get the book?
10 9 longer M an R d . y E o D u W de A c R id D ed S : t o O g b o j ? e ct to the form. 1
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11 BY MR. LUTHER: 12 A I bought the book
12 Q. Is that right? 13 Q. And what verse was on the cover?
1 1 3 4 A Q . . Y W e h s e . n you went the first time, did you 1 14 5 Q A . . W Ps h al a m t P s s s a o l m m e ? t hing.
1 1 1 6 5 7 volunt M T ar H i R l E y . E t W a D k I e W T y N A o E R u S r D S to S : p : H o O e f b f a / j s e k c e t d to m th e e — f o n r o m , b . ecause I 1 1 6 7 A Q . . I Y d o o u n d 't o k n n 't o r w em . ember?
1 1 2 2 8 9 0 1 a r s A e o r m n m e d d e e m h s j e h e b i a s e r n a r t i s t e d . h x , a A a o t c k n h t a l d a y y d I , w l g d u h i i t r d a e l t n s a , I 't y w h k o a n a u l o s f g w s w u l e e w y e a s h v r c i a e n a t o g n th . n , e y I i t o h w , u e a a l n g l s d u t w o y s e d a o r . i ng 1 1 2 2 2 8 9 0 2 1 A Q A A . . . . N D N T D o o o o o . . k y y e o o e u u p r r a e e m m jo e e u m m rn b b a e e l r r . w w h h e y r e y o y u o u b o b u o g u h g t h i t t ? it ?
22 can get undressed now. 23 Q. A journal of what?
2 2 4 3 BY Q M . R S . o L , U yo T u H d E e R ny : that you voluntarily took your 2 24 5 A a . O So f m wh y e l n if d e. i d you start this book?
25 top off the rust time?
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Page 155
Page 153
1 A. When I started making a lot of money. 1 A. Until now?
2 Q. Yes.
2 Q. Which was when?
3 A. It's somewhere. I don't know. It's
3 A. When I started working
4 somewhere. I mean --
4 Q. What do you mean by
5 A. I told you this before, places where 5 6 mo Q rn . i n Y g t o h u a t h y a o v u e a h l a r d e a i d t y an te d s y ti o f u ie k d n e e a w rl i w er h t e h r i e s it was, so --
6 men go to receive sexual favors.
7 Q. This was after you had gone to Mr. Epstein? 7 M TH R E . E W D I W TN A E R S D S S : : O O k b a j y e . c t W to e l t l h , e i t f s o s rm om . ewhere in
8 A. Yes.
9 Q This was after you had quit going to 9 the house.
10 MR. LUTTIER: Okay.
10 Mr. Epstein, wasn't it? 11 THE WITNESS: I don't know if it's in the damn
1 12 1 A. M Y R e . s . E DWARDS: Objection to the form. Just for 12 kitchen or in the — you need to -- you're making
13 clarification, do you mean after she quit going the 1 1 3 4 m lo e o k a i n n g g r y a . t m I d e, o t n h 't e k w n a o y w h , j e u i s s t l t o h o e k w in a g y a y t o m u' e r , e s taring
14 first time or after —
1 16 5 M M R R . . L E U DW TI A 1E R R D : S N : o. the last time, the last time 1 1 1 5 6 7 at m M T e H R l E i . k L e W U P I T i T n T N t I h E E e S R c S : r : i m M I i g a n ' u a a e l m . s s - - th m at o 's v e w t h o a s t t y ri o k u e g . et paid
17 she ever saw him?
1 1 8 9 me M an R t. . A L f I t N er D sh E e R q : u N it o g , o p in e g ri o to d . E p S s h t e e i k n n 's e . w what I 1 19 8 for. M I R 'm . L so U rr T y T . IER: Move to strike the soliloquy.
20 BY MR. LUTTIER:
2 2 0 1 BY Q M . R A . L nd U i T s T th IE er R e : s ome particular reason why you 21 Q. When was the last time you made an entry in
22 purchased this particular book with this particular 2 2 2 3 tha A t b . o o O k h ? , I believe I only had it for the year of
23 verse on it to do this? 24 4 And the last time I ever opened it and made an
24 A. No.
25 Q. You have no recollection at all where you got 25 entry in it was probably in 1.
Page 156
Page 154
1 Q. Did you describe in that book events that
1 this book? 2 happened in your life that you thought were of
2 A. No.
3 significance?
3 Q. But you 'mow you bought it? 4 A. No. I kind of lived a second life so I would
4 A. Yes.
5 Q. And do you, can you recite any of this verse 5 6 nev Q er . do W th h a at t . d o you mean you lived a second life?
6 that you say is on it? 7 A. Well, I lived a life as a prostitute, and I
7 A. No.
8 Q. I ran Psalms is kind of a big book? B 9 live Q d . a l S if o e , a h s o w a m do o e th s e t r h a a s t r w el e a l t l e , s t o o — my question about
9 A. Correct
10 Q. And you can't remember anything about what it 1 1 0 1 whe A th . er Y o o r u n a o s t k y e o d u m -- e how did I live a second life. I
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14 kept one secret from the other.
1 1 4 5 ver Q se . . The verse wasn't printed out. 1 1 5 6 the Q bo . ok W s e ig ll n , i t f h i e c n an m t e y v q e u n e t s s t t i h o a n t w oc a c s u d r i r d e d y o in u y re o c u o r r l d i f i e n ?
1 1 6 7 A Q . . N It o w . as just a citation to a verse in the book 17 A. Significant events, like what is significant
18 to you?
18 of Psalms? 19 Q. Well, since you're the one putting the entries
1 2 9 0 Q A. . Y A e n s d . you never looked up the verse to see vilat 20 in the book, I guess you would make that determination.
21 A. The answer it no.
21 it was? 22 Q. Did you record any events that occurred to you
22 A. No.
23 Q. From the time you first began keeping that 23 in your life in that book?
24 book, did you continue to keep that book right through 24 A. Yes.
25 Q. What events did you record?
25 the present time?
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1 MR. EDWARDS: Don't answer. We're invoking 1 question has turned into $2,000 a day.
2 her Fifth Amendment right to remain silent. If you 2 BY MR. LLTITIER:
3 want, she will read it. In addition she's in, we 3 Q. If you made more than $1,000 in a day, how
4 arc resting on our privacy rights objection as well 4 many hours are you referring to as a day?
5 as the objection to privacy of third parties. Go 5 A. Sometimes it could be 10 minutes. Sometimes
6 ahead. 6 it could be 24 hours.
7 THE WITNESS: On advice of counsel, I invoke 7 Q. When you say it was 24 hours, that suggests to
8 the Fifth Amendment rights under the United States 8 me that your workday involved you keeping the company o
9 Constitution. 9 someone for an entire 24-hour period; is that right?
10 BY MR. LUTHER: 10 A. Sometimes.
11 Q. You earlier said that in the year I. some 13. Q. And did you do that in town or did you travel
12 days you made a thousand dollars a day, some days you 12 to do that?
13 made $2,000 a day. How many days out of the year would 13 A. In town and travel.
14 you say you made a thousand dollars a day or more in the 14 Q. Did you ever engage in any of those activities
15 year
15 with any of the girls that you had come to !mow from
16 A. 1 don't know. 16 either taking them to Mr. Epstein's or knowing them from
17 Q. Well, what's your best approximation? 17 Mr. Epstein's?
18 MR. EDWARDS: Object to the form. 18 MR EDWARDS: Don't answer. And I am
19 THE WITNESS: I don't know. 19 invaokin g -- I am objecting based on privacy rights
20 BY MR. LU'TTIER: 20 of as well as these third parties you are
21 Q. More than 50? 21 referring to, and as well as the Fifth Amendment.
22 A. i don't know, sir. 22 She will read.
23 Q. More than 100? 23 THE W/TNESS: On advice of counsel, I invoke
24 A. I don't know, sir. 24 my Fifth Amendment rights under the United States
25 Q. And this is — these are events that would 25
Page 158 Page 160
1 have happened less than 12 months ago, but you, as you 1 THE VIDEOGILAPHER: Excuse me. You're
2 sit here today, your recollection is not good enough for 2 microphone got turned inside out here.
3 you to answer that; is that correct? 3 BY MR. LUTTIFR:
4 MR. EDWARDS: Object to the form. If you 4 Q. Before lunch you testified that you would sit
5 know, tell him. I don't want you to guess. 5 naked in front of Mr. Epstein. Do you recall that
6 THE WITNESS: I'm not guessing. 6 testimony?
7 BY MR. LUTTIER: 7 A. Yes.
8 Q. I'm not asking you to guess. Don't want you 8 Q. Is this, was this the first occasion that you
9 to guess. Tell me what your best estimate is. 9 went to sec Mr. Epstein?
10 MR. EDWARDS: That's the same thing as 10 A. Where I sat in front of him naked?
11 guessing and I am instructing her not to guess. If 11 Q. lih-huh.
12 you }mow, tell him though. If you do not ;mow, 12 A. No. The first occasion when I saw Jeffrey, I
13 don't. Object to the form. 13 stood in front of him naked.
14 MR. LITITIER: Let's not have speaking 14 Q. Okay. And did each time that you went to see
15 objections. 15 Mr. Epstein or you went to his house, did you actually
16 MR. EDWARDS: I apologize. 16 go into a room and perform massages with Mr. Epstein?
17 BY MR. LUTHER: 3.7 A. Yes.
18 Q. Was it more than ten? 18 Q. Were there occasions when you went to his
19 A. Maybe. 19 house and you didn't perform massages on Mr. Epstein?
20 Q. More than 20? 20 A. Yes.
21 A. Maybe. 21 Q. And what (tensions were those?
22 Q. And by then, by when you made like $2,000 in a 22 A. When I was bringing another girl to perform
23 day, how many hours arc you referring to as a day? 23 massage on Mr. Jeffrey Epstein.
24 MR. EDWARDS: Object to the form. The 24 Q. Did there come a time that, that Mr. Epstein
25 question dealt with $1,000 a day. And now this 25 didn't, or that you didn't perform massage on
40 (Pages 157 to 160)
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