EFTA00158904.pdf

1 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 CASE NO. 08-CIV-80119-MARRA/JOHNSON 3 4 5 Plaintiff, 6 -vs- VOLUME I OF II 7 EPSTEIN, 8 Defendant. / 9 10 Related cases: 11 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 12 09-80591, 09-80656, 09-80802, 09-81092 13 14 15 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF 16 17 18 December 4, 2009 10:25 - 5:00 19 20 21 22 23 Reported By: Cynthia Hopkins, RPR, FPR 24 Notary Public, State of Florida Prose Court Reporting 25 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008052 EFTA00158904  2 1 APPEARANCES: 2 On behalf of 3 ESQUIRE 4 5 6 7 8 On behalf of the Defendant, Epstein: 9 ROBERT D. CRITTON, JR., ESQUIRE MARK T. LUTHER, ESQUIRE 10 BURMAN, CRITTON, LUTHER & COLEMAN, LLP 11 12 13 14 15 ALSO PRESENT: 16 Jeffrey Epstein, via video conference 17 I MMI, Paralegal, P.A. 18 19 Stan Sanders, Videographer Visual Evidence, Incorporated 20 21 22 23 24 25 3 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008053 EFTA00158905  1 2 INDEX VOLUME I 3 _ _ _ 4 5 WITNESS: DIRECT CROSS REDIRECT RECROSS 6 ■• 7 BY MR. LUTTIER 5 8 9 10 11 EXHIBITS 12 13 14 EXHIBIT DESCRIPTION PAGE 15 DEFENDANT'S NO. 1 11 16 Plaintiffs Notice of Serving Second Amended Answers to Interrogatories 17 DEFENDANT'S NO. 2 29 18 Answers of Interrogatories 19 DEFENDANT'S NO. 3 119 First Amended Complaint 20 DEFENDANT'S NO. 4 254 21 Plaintiffs Notice of Serving Third Amended Answers to Defendant's First 22 Interrogatories 23 24 25 4 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008054 EFTA00158906  1 PROCEEDINGS 2 3 Deposition taken before Cynthia Hopkins, 4 Registered Professional Reporter and Florida 5 Professional Reporter, and Notary Public in and for 6 the State of Florida at Large, in the above cause. 7 - - - 8 THE VIDEOGRAPHER: Today is the 4th day of 9 December, 2009. The time is approximately 10 10:25 in the morning. This is the videotape 11 deposition of -- did I 12 pronounce it correctly? 13 THE WITNESS: Yeah. 14 THE VIDEOGRAPHER: -- in the matter of 15 No.nversus Epstein. This 16 deposition is being held at 17 in West Palm Beach, Florida. 18 My name is Stan Sanders. I am the 19 videographer representing Visual Evidence, 20 Incorporated. 21 Will the attorneys please announce their 22 appearances for the record. 23 MR. : My name I am 24 counsel on behalf. With me is 25 M, Paralegal. 5 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008055 EFTA00158907  1 MR. LUTTIER: My name is Mark Luther, and 2 I am here on behalf of the Defendant, 3 Mr. Epstein. 4 Thereupon, 5 6 Having been first duly sworn or affirmed, was 7 examined and testified as follows: 8 THE WITNESS: Absolutely. 9 THE COURT REPORTER: Thank you. 10 DIRECT EXAMINATION 11 BY MR. LUTTIER: 12 Q. Would you please tell me your full name, 13 ma'am. 14 A. 15 Q. Ms. have -- my name is Mark lb Luttier. I represent Mr. Epstein in this pending 17 lawsuit that you have brought. Have you ever had an IR opportunity to be deposed before? 19 A. What does that mean? 20 Q. That's the process that we're about to 21 engage in here is known as a deposition. 22 A. No. 23 Q. All right. I just want to explain sort of 24 the rules to you so that you understand it. First 25 of all, if you want to take a break at any time, if 6 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008056 EFTA00158908  1 you want something to drink, have to go to the 2 bathroom, just let me know. 3 MR. : If it's of any help to you, 4 and I have had an opportunity to talk 5 about the basic procedures involved. 6 MR. LUTTIER: Okay. 7 MR. : And I don't think it's necessary -- 9 MR. LUTTIER: Okay. 10 MR. : -- for you -- 11 MR. LUTTIER: All right. 12 MR. : -- to go through that with 13 her. 14 MR. LUTTIER: All right. 15 MR. : But if you think there's a 16 purpose — 17 MR. LUTTIER: No. 18 MR. : -- of doing it anyway, 19 obviously you have a right to do that. 20 BY MR. LUTTIER: 21 Q. Do you, do you understand the fact that 22 you are under oath now? 23 A. Yes. 24 Q. And do you know what the significance of 25 being under oath is? 7 1 A. Yes. file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008057 EFTA00158909 2 Q. And what is your understanding of the 3 significance of being under oath? 4 A. Not to lie to you. 5 Q. Yeah, you have to tell the truth. 6 A. And God is watching me. 7 Q. In other words you understand you have to 8 tell the truth about everything? 9 A. Yes. That would fall under not lying. 10 Q. And you understand there are civil and 11 criminal consequences that could be attributed to 12 making statements that are not true while under 13 oath? 14 A. Yes. 15 Q. Okay. In this particular lawsuit, you've 16 had an opportunity to discuss your claims with 17 various other people, have you not? 18 A. One more time. 19 Q. You've had an opportunity before you came 20 here today to discuss your various claims that 21 you've made about Mr. Epstein with other people? 22 A. As in my attorneys? 23 Q. As in anybody. 24 A. I've only talked about it with my attorneys. 25 Q. Okay. Did you have a conversation at any 8 1 time prior to today with anyone from the state SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008058 EFTA00158910  2 attorney's office here in the Palm Beach County 3 State Attorney's Office? 4 A. Yes. 5 Q. Okay. 6 A. And the FBI. 7 Q. All right. Let's first talk about the 8 state attorney's office. Do you know with whom you 9 spoke? 10 A. I don't remember the name. 11 Q. Do you know if it was a man or a woman? 12 A. I have spoke to a man and a woman. 13 Q. How many times did you speak with someone 14 at the State Attorney's Office? 15 A. Once. 16 Q. And where did you speak with them? 17 A. In a building somewhere off of of 18 here. I don't remember the name of the building. 19 Q. Do you know if it was at the State 20 Attorney's Office -- 21 A. Yeah. 22 Q. -- across from the courthouse? 23 A. The United States Attorney's Office. 24 Q. Okay. Let me back up a little bit. Now 25 you mentioned the United States Attorneys? 9 1 A. That's -- 2 Q. That would be someone associated with file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008059 EFTA00158911  3 what's known as the federal system. When I was 4 asking you about the state attorney, that would be 5 someone associated with the State of Florida. 6 A. I was at a building with United, it was the 7 United State's State Attorney's Office. 8 Q. All right. And would that have been a 9 building you say here on somewhere? 10 A. Or It was somewhere in this 11 vicinity of buildings. not exactly sure where. 12 Q. Do you remember the name of either the man 13 or the woman -- 14 A. I do not. 15 Q. -- with whom you met. Did you have a 16 separate meeting with someone from the Florida State 17 Attorney's Office? 18 A. I don't remember. 19 Q. And the State Attorney's Office is located 20 across the street from the courthouse downtown in 21 West Palm Beach. 22 A. I don't remember. 23 Q. When you, when you -- and by the way, when 24 you say you don't remember, is it your intent to 25 indicate to me that you have no recollection whether 10 1 it happened or didn't happen? 2 A. It's. 1 don't remember if that was the file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008060 EFTA00158912  3 building I was in. 4 Q. Okay. Do you recall having met with 5 someone from the State of Florida, a prosecutor from 6 the State of Florida as well as someone from the 7 United States Attorney's Office? 8 A. Well, there was a lot of people there. 9 Q. This, now you're referring to the initial 10 meeting that you talked to me about? 11 A. When I had the meeting, I believe, I'm not 12 sure if it was -- I know it was the United States State 13 Attorney's Office. It could have been State of Florida. 14 There was a victim's advocate there and the FBI was 15 there. 16 Q. Okay. So, we have a man and a woman that 17 were associated with the, the State Attorney's 18 Office, whether it was the U.S. Attorney or State 19 Attorney, a victim's advocate and how many members 20 from the FBI? 21 A. I was with one lady from the FBI. 22 Q. Do you, do you know her name? 23 A. I do not remember. 24 Q. Do you remember even the first name, first 25 or last name? 11 1 A. I don't remember. 2 Q. Do you remember what race she was? 3 A. She was white. The Victim's Advocate lady, file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_0000806 I EFTA00158913  4 she was black. I remember that. 5 Q. Do you remember her name? 6 A. No. 7 MR. LUTTIER: Let me hand you what we'll 8 mark as Exhibit No. 1 which purports to be a 9 document entitled Plaintiffs Notice of Serving 10 Second Amended Answers to Interrogatories. 11 Here's your copy. 12 THE WITNESS: Do I get a copy? 13 MR. LUTTIER: Yeah, I am going to get to 14 you. I'm just going to put a stamp on one. 15 BY MR. LUTTIER: 16 Q. Now, let me hand you Exhibit 1. And the 17 first question I have for you is if you will turn to 18 the last page; is that your signature? 19 A. Yes. 20 Q. All right. Now, if you will, on the last 21 page you have represented that these answers are 22 true and correct. I want to give you an opportunity 23 to flip through these answers and look at them. 24 A. Of where, the whole packet? 25 Q. Right. And tell me if there is anything 12 1 in these answers that is not correct or is 2 incomplete? 3 MR. : I am going to object to the file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008062 EFTA00158914  4 question as compound, vague, and overly broad. 5 BY MR. LUTT1ER: 6 Q. Let me give you a chance to look through 7 them. And my first question will be is there 8 anything that is inaccurate in these answers. 9 MR. : Same objection. You can -- 10 a unless I instruct you not to answer, 11 the objections that I am making are objections 12 that are being made so that the court can look 13 at them at a later time and decide whether the 14 question was appropriate. 15 You should answer the question regardless 16 of whether I raise an objection unless I tell 17 you not to. Okay? 18 THE WITNESS: I'm so confused. 19 MR. : That's all right. Right now 20 you have been asked to look at these and to 21 determine whether there is any inaccuracy in 22 the answers that you swore to previously. 23 THE WITNESS: This is what me and you did, 24 right? Then it all should be correct unless 25 somebody else messed with it. Excuse me. 13 1 2 3 4 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008063 EFTA00158915  5 6 7 8 9 10 11 12 13 14 MR. : Is the absence of signature 15 that you are referring to Page 15? 16 MR. LUTTIER: No, I have got it on this 17 one. 18 MR. : Well, okay. 19 MR. LUTTIER: But I have got it, and it 20 may be that, it may be that that's what I was 21 looking at. 22 THE WITNESS: I was -- 23 MR. LUTTIER: But I can tell you there is 24 another set coming. 25 THE WITNESS: Referring to MM 14 2 MR. : Yes, =M? 3 THE WITNESS: For it says I 4 was paid $100. I was given the amount of $300. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008064 EFTA00158916  5 I wasn't given the extra $100 for bringing her, 6 and I gave her $100 out of my money because he 7 said she was fat. 8 MR. LUTTIER: Okay, now -- 9 MR. : Okay . 10 BY MR. LUTTIER: 11 Q. -- you're referring to your answer to 12 Interrogatory 23? 13 MR. : On Page 14, correct. 14 was just clarifying that response. 15 MR. LUTTIER: Okay. And your 16 clarification that is an 17 individual that you brought to Mr. home -- 18 Mr. Epstein's home and — 19 THE WITNESS: I was not given the extra 20 money for bringing her. 21 BY MR. LUTTIER: 22 Q. Okay. So you got paid zero for bringing 23 her? 24 A. Yes. 25 Q. Okay. 15 1 A. I got paid $300 for me going, but was not 2 given the extra hundred for bringing her. 3 Q. So, you got 300 for going. You went on 4 this occasion, but you were not given any extra 5 mone).1 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008065 EFTA00158917  6 A. The extra money. yes. 7 Q. And you brought Ms.. on that 8 occasion? 9 A. Yeah. 10 Q. Okay. And then you're indicating that 11 what you did was even though you only got paid 300, 12 you took 100 of your 300 and gave it to IM • 13 14 A. Yes. 15 Q. Okay. Any other corrections to any of 16 your answers to interrogatories? 17 A. So far that's -- I don't see any. 18 Q. Okay. 19 A. That was the only thing. 20 Q. Let's then turn to, I'm going to reference 21 your answer to Interrogatory No. 5 which starts -- 22 A. What page — 23 Q. On Page 3, which asks you to give, 24 identify anybody that you believe has information 25 pertaining to this suit. And I want to -- 16 1 A. Pertaining to what? 2 Q. To this, to this claim. 3 A. Okay. 4 Q. I will refer to it sometimes as your claim 5 or to this lawsuit that you brought against file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008066 EFTA00158918  6 Mr. Epstein? 7 A. Okay. 8 Q. And by the way, I am sure Mr. 9 explained this to you, and you are doing a fine job, 10 any time I ask you a question and you're not sure 11 what I'm asking or you need me to explain it, just 12 ask me to, and I will be happy to explain it to you. 13 A. Yeah. 14 Q. Okay? Now, let me draw your attention 15 over to Page No. 10? 16 A. Well, what was the point of going to Page 17 No. 3? 18 Q. Well, Page No. 3 is the list, starts with 19 a list of names of the people that you gave that you 20 said had information concerning this claim. Okay. 21 And I want to now call your attention to Witness 22 Number 31 which is found on Page 10. 23 A. I don't understand what you just said. 24 Q. If you would turn to Page 10, you will see 25 a Number 31. See that Number 31- 17 1 A. Uh-huh. 2 Q. And it indicates that he is an attorney 3 with the Department of Justice which would be the 4 U.S. Attorney. Is, does that name refresh your 5 recollection as to whether or not he was the 6 individual with whom you met from the U.S. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008067 EFTA00158919  7 Attorney's Office? 8 MR. : Let, let's make sure we 9 understand exactly what this answer is. The 10 information provided is information that was in 11 the possession or control of And 12 obviously some of these names were not provided 13 by but were gathered through the 14 investigation conducted by her attorneys. And 15 we were obliged to disclose that information as 16 her lawyers in response to this interrogatory. 17 So, to suggest to that this 18 information originated with her would be 19 incorrect. 20 MR. LUTTIER: I wasn't suggesting 21 anything. 22 MR. : Okay. 23 MR. LUTTIER: I was just referring to the 24 fact that she gave us in an answer to 25 interrogatory that is someone 18 1 that she said she believed had knowledge about 2 the case, and the address she gave reflects he 3 is from the U.S. Department of Justice. 4 BY MR. LUTTIER: 5 Q. And my question is, seeing that name, does 6 that refresh your recollection as to whether or not file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008068 EFTA00158920  7 he was the individual -- 8 A. I don't remember. 9 Q. -- with whom you met when you say you met 10 with the -- 11 A. There was more — 12 Q. -- U.S. Attorney? 13 A. -- than four people in the room, so their 14 names, I can't remember. 15 Q. Okay. So it doesn't refresh your memory 16 looking at this? 17 A. No. 18 Q. All right. Look at the next witness which 19 is 32. Do you see the name M.S.W.? 20 A. What does M.S.W. stand for? 21 Q. I imagine it's Master of Social Work. 22 Does that refresh your recollection as to whether or 23 not that was the victim advocate with whom you met? 24 A. Yes, I remember 25 Q. Okay. And that would be the person that 19 1 you previously identified as the victim advocate 2 that was at this meeting? 3 A. Uh-huh. 4 Q. That's a yes? 5 A. I believe so. 6 Q. If you will turn to the next page, Page 7 11, Number 34, there is a name file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008069 EFTA00158921  8 A. Yeah. 9 Q. Does that name — do you recognize that 10 name -- 11 A. Yes. 12 Q. -- as being the person with whom you met, 13 and that would have been, was that the woman from 14 the U.S. Attorney's Office with whom you met on this 15 occasion that you described? 16 A. I just remember the last name 17 Q. As being the women that was present for 18 this meeting that you had with the U.S. Attorney? 19 A. Yes. 20 Q. Now, in reviewing these names, do you, do 21 you recognize any name in the list that you have 22 given me in response to this interrogatory that is 23 indicative of the man from the U.S. Attorney's 24 Office? 25 A. Were does indicative mean? 20 1 Q. That is the person, the man with whom you 2 met at the U.S. Attorney's Office. 3 A. Okay. Ask me the question one more time now 4 that I know what the meaning of that word is. 5 Q. You, you said that when you met with the 6 U.S. Attorney's Office there was one man and one 7 woman from the U.S. Attorney's Office. You have now file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008070 EFTA00158922  8 said that Ms. was the woman. 9 A. I remember -- 10 Q. I call your attention to this list of 11 names you gave me. Can you point out to me which 12 individual, if he's listed, was the man with whom 13 you met at that meeting? 14 A. And I told you I don't remember the name. 15 Q. All right. And, and is it, do you know 16 that the person -- 17 A. It could be possible -- 18 Q. -- that's listed -- 19 A. That's his name, yes. I don't know. I said I 20 don't know, so... 21 Q. Do you, in looking through this list, can 22 you identify the person that you described as the 23 woman from the FBI? 24 A. And now I lost my page. I'm upset. I'm 25 sorry. What page were we on? 21 1 Q. Well, we happen -- 2 A. I just -- 3 Q. The last page we were on is Page 11, but 4 feel free to look at all of the names? 5 A. Okay. I do not see the lady-from-the-FBI's 6 name. 7 Q. Do you have that information anywhere? 8 And by that I mean even if it's not on the answers file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008071 EFTA00158923  9 to interrogatories, do you someplace have the 10 information as to the name of the woman from the FBI 11 that was present at the meeting? 12 A. No, but if somebody did and showed me the 13 name, I would definitely remember because it was a weird 14 name. 15 Q. All right. So, I want you to take your 16 time to look at those lists, that list of witnesses 17 that starts on Page 3 and carefully look at them and 18 tell me if you recognize -- 19 A. That's what I am doing -- 20 Q. -- the name. 21 A. I don't see that lady's name. 22 Q. Do you know if you have that person's name 23 anywhere? 24 A. No. You asked me that already. 25 Q. Other than a man and a woman from the U.S. 22 1 Attorney's Office, one of whom you identified as 2 Ms. Ms. the victim advocate, and 3 the lady from the FBI, was anyone else present for 4 this meeting that you had with the U.S. Attorney? 5 A. Yes, and I don't know their name. 6 Q. Who else, who else, who were they that 7 were present, even if you don't know their names? 8 A. I don't know. They were -- file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008072 EFTA00158924  9 Q. I just, from what agency were they 10 associated? 11 A. I don't remember. 12 Q. Were there, was there any lawyer there? 13 A. I don't remember. 14 Q. Was there any lawyer there on your behalf? 15 A. No. 16 Q. Did you take anyone to the meeting with 17 you? 18 A. No. 19 Q. How many other people were there? You've 20 identified five thus far, plus yourself. 21 A. I believe it was five then. 22 Q. So, you now -- 23 A. I was just about to count them. 24 Q. So, you now have identified for me 25 everyone that was there? 23 1 A. I believe so. 2 Q. What was discussed at this meeting? 3 A. The incident between me and Jeffrey Epstein. 4 Q. Which incident is that? 5 A. The incident why we're here now. 6 Q. Are you referencing a single isolated 7 incident? 8 A. I am talking about the whole situation of all 9 the times I've been there, what happened. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008073 EFTA00158925  10 Q. Do you know approximately when this 11 meeting occurred? We can start with the year. 12 A. I don't remember the year. It's, it was a 13 couple of years ago. Actually it was about, I think it 14 was a couple years ago, as a couple not as in two. It 15 was longer than that. 16 Q. Is there anything that will refresh your 17 memory as to when it happened? 18 A. That's what I am trying to think about. 19 Q. Did you make a note of it, for example? 20 A. My mom would know. 21 Q. Why would she know? 22 A. Because I called her and told her the FBI was 23 at our house. 24 Q. Was where, at her house? 25 A. Was at the house, yeah. The FBI came to the 24 1 house. 2 Q. Was this before this meeting that you had 3 with the U.S. Attorney? 4 A. It was before that meeting, yes. 5 Q. Okay. So, you've had to two meetings with 6 the FBI? 7 A. I had the meeting when they first came and 8 knocked on the door and asked me if I know who 9 Mr. Epstein was. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008074 EFTA00158926  10 Q. Okay. 11 A. And then they were at the meeting with the 12 United States people, attorney people. But my mom would 13 remember. 14 Q. Okay. Let's go back then. Let's talk 15 about what we'll describe as the first meeting with 16 the FBI. You say they came to your house? 17 A. Yes. 18 Q. Where was this house located? 19 A. West Palm Beach 20 Florida 21 Q. I take it you were living there at the 22 time? 23 A. Yeah. 24 Q. Was anyone else living with you at that 25 time at that residence? 25 1 A. My brothers, my mother. 2 Q. All three of your brothers? 3 A. And I believe it was my daughter's father was 4 living with me then too. 5 Q. That would be Mr. 6 A. Yes. 7 Q. Do you recall when that meeting took 8 place? 9 A. I just said no. I said my mom would 10 approximately know approximately when it happened. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008075 EFTA00158927  11 Q. How many members of the FBI came to meet 12 with you on that occasion? 13 A. Two, a man and a woman. 14 Q. Were -- 15 A. And I do not recall the names. 16 Q. Looking at this list of witnesses that you 17 gave me in these answers to interrogatories which 18 have been marked as Exhibit I, do you recognize the 19 name of either of these -- 20 A. And I said no. 21 Q. Well, actually I haven't asked you the 22 question yet. So, do you recognize the name of any 23 of these individuals as being the FBI agents that 24 came to your house at 25 A. And I said no. I already knew you were going 26 1 to ask me that. That's why I said no. 2 Q. And was it two men or a man and a women or 3 two woman? 4 A. A man and a woman. 5 MR. : You already asked that 6 question, and you were told it was a man and a 7 woman. 8 BY MR. LUTTIER: 9 Q. And did they meet with you on that 10 occasion? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008076 EFTA00158928  11 MR. : You already asked that 12 question. 13 MR. LUTTIER: Who, was any-- 14 MR. said that a man a 15 woman came to see her and she was there. So 16 there obviously was a meeting. 17 BY MR. LUTTIER: 18 Q. Did you meet inside the house or outside 19 the house? 20 A. Outside the house. 21 Q. Was there anyone else present besides you 22 and these two persons from the FBI? 23 A. No. 24 Q. Did anyone make any notes during this 25 meeting, the first meeting -- 27 1 A. The FBI people did. 2 Q. Do you know whether or not you, anything 3 you said was recorded? And by that I mean like with 4 a tape recording. 5 A. Not at that present time, no. It was recorded 6 when we went to the United States place. 7 Q. And was it recorded by via tape recorder, 8 was there a court reporter there like we have here? 9 A. No, it was on tape recorder. 10 Q. Have you ever been provided with a 11 transcript, that is a paper writing that reflects file:///D/...20(SUBJECPY.20TO%20PROTECT 1 V E%20ORDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008077 EFTA00158929  12 what was said at the meeting that was recorded? 13 A. No. 14 Q. Have you ever asked for it? 15 A. No. I didn't know I could have. 16 Q. Were you under oath at the meeting that 17 was recorded? 18 A. I don't believe so. 19 Q. Did you -- 20 A. I, I probably was. 21 Q. Whether you under oath or not, did you 22 tell them the truth at that meeting? 23 A. Yeah. 24 Q. Did you tell the FBI the truth when they 25 came to your house? 28 1 A. Yes. I have no absolutely no reason to lie 2 about this situation. 3 Q. Other than the meeting when the FBI came 4 to your house and when you met with the U.S. 5 Attorney that you have described thus far, have you 6 had any other contact with the FBI? 7 A. No. 8 Q. Have you had any other contact with anyone 9 from the U.S. Attorney's Office? 10 A. No. 11 MR. LUTTIER: Let's mark this as file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008078 EFTA00158930  12 Exhibit 2. 13 THE WITNESS: Is this mine to keep? 14 MR. LUTT1ER: Yeah. 15 16 17 18 19 20 21 22 23 24 25 29 1 2 3 4 5 (Defendant's Exhibit No. 2 was marked for 6 identification.) 7 THE WITNESS: Sorry about that. Like 8 that, right? Okay. I'm sorry now. 9 BY MR. LUTTIER: 10 Q. Okay. Now I have handed you what has been 11 marked as Exhibit No. 2 which is a document that is 12 entitled Notice of Serving Answers to file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008079 EFTA00158931  13 Interrogatories. 14 A. Okay. 15 Q. And this is similar to Exhibit 1 which was 16 supplemental interrogatories; that is they are 17 written questions that were submitted to you. If 18 you turn to Page 19, is that your signature? 19 A. Yes. 20 Q. Now, I notice that your signature here 21 does not purport to be a representation under oath 22 that the answers are true and correct? 23 A. That what? 24 Q. I notice that your signature on Page 19 25 does no purport to represent that your answers are 30 1 true and correct? 2 MR. : We will stipulate that it is 3 indeed a representation that -- 4 MR. LUTT1ER: Okay. Good enough. 5 MR. : answers are 6 true and correct. 7 BY MR. LUTT1ER: 8 Q. If you will turn to Page 18, please. You 9 will notice in answer to Interrogatory 23, you state 10 that you were interviewed by the FBI and a State 11 Attorney. In that answer, are you referring to two 12 separate interviews? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008080 EFTA00158932  13 A. That would be Number 22. 14 Q. Correct. 15 A. Not 23. 16 MR. : You did say 23. 17 MR. LUTTIER: Okay. I'm sorry. 18 THE WITNESS: Now, okay. So, now what was 19 the question? 20 BY MR. LUTTIER: 21 Q. You answered in answer to 22 Interrogatory 22, that you were interviewed by the 23 FBI and a State Attorney? 24 A. Yeah. 25 Q. Are you referring now to two separate 31 1 meetings or -- 2 A. One. 3 Q. All right. And is the reference in this 4 answer to the meeting that you've described thus 5 far? 6 A. Okay. Listen. The FBI came to my house one 7 time. And then at this meeting the FBI and the State 8 Attorneys were there. 9 Q. Okay. 10 A. So, there was two meetings with the FBI: One 11 when they came to my house and then one when the State 12 Attorney was there and one in that building somewhere 13 around here. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008081 EFTA00158933  14 Q. All right. 15 A. Does that help you? 16 Q. Yep. 17 A. Okay. Good. 18 19 20 21 22 23 24 25 32 1 2 3 4 5 6 7 8 9 10 11 12 13 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008082 EFTA00158934  14 BY MR. LUTTIER: 15 16 17 18 19 20 21 22 23 24 25 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008083 EFTA00158935  15 16 17 18 19 20 21 22 23 24 25 34 1 2 3 4 5 6 7 8 10 11 12 13 14 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008084 EFTA00158936  15 16 17 18 19 20 21 22 23 24 25 3 1 2 3 4 5 6 7 8 10 11 12 13 14 15 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008085 EFTA00158937  16 17 18 19 20 21 22 23 24 25 36 1 2 3 4 5 6 7 8 10 11 12 13 14 15 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008086 EFTA00158938  16 17 18 19 20 21 22 23 24 25 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008087 EFTA00158939  17 18 19 20 21 22 23 24 25 3 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008088 EFTA00158940  17 18 19 20 21 22 23 24 25 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2