EFTA01075988.pdf

Page 158 Page 160 APPEARANCES: 1 PROCEEDINGS 2 On behalf of the Plaintiff.: 2 3 SPENCER KUM, ESQUIRE -- LEOPOLD KUVIN, P.A 3 (Continued from Volume I.) 2925 POA Boulevard, Suite 200 Palm Florida 33410 4 VIDEOGRAPHER: We're back on the video record. Phone 5 This is the beginning of tape number three. The t 7 71ILMIrMane On behalf Does 24: 6 time is 3:02 p.m ADAM HORMEL, ESQUIRE MRMELSTEIN & HOROWITZ, PA BY MR. KUVTN: 18205 Biscayne Boulevard Suite 2218 8 Q. Okay. Let me do it this way, so we can just 9 Miami 9 back up a little bit. Phone: 10 Ms. you're aware that girls, including 10 1.1 On behalf ofPlaintiff Carolyn Andnono 11 my client, have sued Jeffrey Epstein in civil lawsuits, 12 TACK Hal, ESQUIRE 12 correct? SEARCY, DENNEY. SCAROIA, BARNHART & SHIPLEY, PA 13 2139 Palm Beach Lakes Boulevard 13 A. Yes. West ride 33409 14 Q. All right. Arc you also aware that one of the 14 Phone;till 15 RICHARD/MATS, ESQUIRE (via telephone) 15 defenses has been that these girls volunteered to go to RICHARD H. WILLITS, P.A. 16 the house so, therefore, what are they complaining 16 229010th Avenue North, Suite 404 Lake WS3461 17 about? Are you aware of that? 17 Phone 18 A. Yes, I am. 18 On behalf o the Defendant 19 ROBERT CRITTON, ESQUIRE 19 Q. Okay. You feel that way yourself? BURMAN, CRITTON, LIMIER & COLEMAN 20 A. Absolutely. 20 515 Nonh Wet Drive Suite 400 21 Q. Because you volunteered to go, right? 21 West Ptrida 33401 22 A. Absolutely. Phone: 22 23 Q. And you haven't sued Mr. Epstein, have you? 23 24 A. I have no intentions of that. 24 25 25 Q. Did you contemplate it at one point? Page 159 Page 161 1 On behalf of the Witness: 1 A. Did I contemplate it? Yeah, it crossed my 2 DOUGLAS MCINTOSH, ESQUIRE 2 mind a few times. CAMILLE E. BLANTON, ESQUIRE 3 WilYi 3 MCINTOSH, SAWRAN, PELTZ & CARTAYA, PA. 4 A. Nee. use 1 just thought it was the easy way 1601 Forum Place 4 Suite 1110 S out. And then 1 decided this is my life andl have to West Pal Fonda 33401 6 take responsibility for my own actions because 1 did 5 Phone: 7 volunteer. So I'm handling my grief and my situation a 6 8 different way, and that's by putting this shit behind ALSO PRESENT: 9 me. B 10 Q. Got you. Fair enough. MICHAEL DOWNEY, VIDEOORAPHER 9 11 What I'm wondering then — and the reason 1 10 12 asked the question initially was not to embarrass or 11 13 harass you. But since even yourself, you think to a 12 14 certain extent that these girls bear their own 13 15 responsibility for going? 14 16 A. They don't bear any responsibility. They need 15 17 to take responsibility. 16 17 18 Q. Got you. Did your dad tell you that? 18 19 A. No. I've learned that. 19 20 Q. What was his response to you about what 20 21 happened then? That's why I asked the question 21 22 initially. 22 23 MS. BLANTON: We are not going to discuss her 23 24 24 father and mother and relatives or any other 25 25 friends' reactions to these lawsuits or what she's j 2 (Pages 158 to 161) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddcH-69oe-4e 57-9cd8 -8392056001GO EFTA01075988  Page 162 Page 164 1 been through. Again, she's not a Plaintiff. She's 1 A. Yes. 2 not a Defendant. We're not going to do it. 2 Q. As you sit here today, do you think that the 3 The only purpose that serves is to upset her 3 money that he's paid you and the fact that be's paying 4 and you've seen that. 4 for your lawyers when your parents couldn't afford it 5 MR. KUVIN: I certainly don't mean to upset 5 anymore affects your testimony in any way? 6 her, but obviously I'm rep cbenting certain 6 A. Absolutely not. That's ridiculous. 7 individuals who are being — prosecuting their 7 Q. Okay. Fair enough. Fair enough. 8 action. And I think that the questions are 8 Do you think it was right for Mr. Epstein, 9 relevant But if you're not going to let her 9 personally, to have underage girls, girls under the age 10 11 answer, then we'll move on. BY MR. KUVIN: 10 11 of 16 come to his house and give him naked massages? You think that was okay? I 12 Q. As you sit here today, did anyone blame you, 12 MR. CRITTON: Form. 13 other than yourself for what happened? 13 THE WITNESS: I don't know. 14 MR. CRITTON: Form. 14 MS. BLANTON: Object to form. Define okay. 15 THE WITNESS: Yes. 15 BY MR. KUVIN: 16 BY MR. KUVIN: 16 Q. Well, personally. I mean, do you think there 17 Q. Who? 17 was anything wrong with that, personally? 18 A. A lot of people. 18 MR. CRITTON: Form. 19 Q. Who? Who can we talk to that blamed you, 19 THE WITNESS: I don't know. 20 other than your own personal feelings? 20 BY MR. KUVIN: 21 A. My sister. 21 Q. You have no opinion about that? 22 Q. Okay. Who else? 22 MS. BLANTON: She's answered that twice. 23 A. Ifs the only person that I care about that 23 MR. CRITTON: Form. Argumentative, if that 24 blamed me. 24 was a question. 25 Q. Well, anyone that didn't — that you don't 25 BY MR. KUVIN: Page 163 Page 165 1 care about? 1 Q. You got no opinion about that? 2 A. I think a lot of the other Plaintiffs blame 2 A. I have no opinion about that. 3 me. 3 Q. Okay. Do you remember the address of 4 Q. Okay. Do you feel any personal msponsibility 4 Mr. Epstein's home? S for any — bringing any of those girls to the house? 5 A. No, I do not. 6 MR. CRITTON: Form. Asked and answered. 6 Q. Does the name Brillo Way sound familiar to 7 THE WITNESS: Can you repeat the question? 7 you? 8 BY MR. KUVIN: 8 A. Brillo Way sounds familiar. 9 Q. Yeah. You said just now that you think some 9 Q. Did you ever take a shower in Mr. Epstein's 10 of the other girls that you brought blame you? 10 shower? 11 A. Ub-hub. 11 A. No. 12 Q. Correct? 12 Q. When you were at Mr. Epstein's house, did the 13 A. Yes. 13 chef ever prepare you guys lunch as you were them? 14 Q. Do you — 14 MR. CRITTON: Form. 15 A. Do I blame myself? 15 THE WITNESS: I don't remember. 16 Q. Yeah, for bringing them. 16 BY MR. KUVIN: 17 A. Absolutely not. 17 Q. Any one of the girls that you brought to the 18 Q. Not at all? 18 home, did any of those girls ultimately go to. 19 A. No. 19 University, as far as you know? 20 Q. If Mr. Epstein were not paying for your 20 A. Yes. 21 lawyers, think you'd feel the same way? 21 Q. Who? 22 A. I would feel this way, no matter what. 22 A. Jane Doe 4. 23 Q. If Mr. Epstein hadn't paid you in excess of 23 Q. And I apologize, but is she the one that you 24 53,000 over the years, do you think you'd feel the same 24 had heard had sex with Mr. Epstein? 25 way? 25 MR. CRITTON: Form. 3 (Pages 162 to 165) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401= Electronically signed by Sandra Townsend (401 7a82dddt-59ee.4e57-9cd8.8392056001c0 • EFTA01075989  Page 166 Page 168 1 MS. BLANTON: rm sorry. Did you -- 1 Q. So all of the girls that you brought actually 2 BY MR. KUVIN: 2 recruited other girls as well? 3 Q. There was one of the girls that you had heard 3 A. Yes. 4 had sex with them? 4 MR. CRITTON: Pont 5 A. That was and I heard that from Jane Doe 5 BY MR. KUVIN: 6 101. 6 Q. Okay. How do you know that? 7 Q. Okay. Sony. 7 A. I know that because they told me. 8 What did Jane Doe 4 do with him, if you know? Q. Okay. Which one of them? 9 A. I don't. 9 A. Jane Doe 7 brought,. Jane Doe 4 brought 10 Q. Did you ever tell anyone that you worked for 10 Jane Doe 3 brought a couple girls, can't recall 11 Jeffrey? 11 their names.', I think, may have broughten somebody, 12 A. Did I tell anyone I worked for k 12 but I can't be accurate on that. And I don't know for 13 Q. Yes. 13 I think Jane Doe 7. may have also brought 14 15 A. Yes. Q. Who? 14 15 Wtuti but 16 A. The girls. 16 Q and., the sisters. 17 Q. What did you mean by that when you said you 17 Q. So now we're talking about around 12 girls 18 worked for Jeffrey? 18 that you brought. And then as far as you know, a lot of 19 A. Worked for Jeffrey, like, got girls to give 19 those, if not all of them, brought other girls, at least 20 him massages. When I was introduced to a girl, I would 20 one or two other girls? 21 be, like, yeah, I work forJeffrey. I find girls to 21 MR. CRITTON: Form. 22 give him massages. 22 BY MR. KUVIN: 23 Q. Okay. You weren't on any kind of a payroll or 23 Q. Is that — did I understand you correctly? 24 anything, right? 24 A. Yes, you do. 25 A. No. 25 Q. So as you sit here today, how many girls are Page 167 Page 169 1 Q. Did you ever bring a girl over with the 1 you aware of that were brought to Mr. Epstein's home? 2 initials •? - 2 A. That I'm aware of? 3 A. Pm sorry. What were the initials? 3 Q. Well, yeah, either that you brought or that 4 Q. M. 4 you know other people brought. I mean, you've already 5 A. No, not that I can remember. Not that I can 5 talked to us about 12. Then where there's -- if they 6 recall, no. 6 each brought them, then we're talking 12 more, plus some 7 Q. Do you know a girl by the name of 7 of them may have brought additional ones. You know, 8 A. No. 8 simple math, were in the twenties now. How many are 9 Q. Doesn't sound familiar to you? 9 you aware of let me strike the statement. 10 A. M.? 10 How many people are you aware of, either 11 Q. Yes. 11 directly or indirectly, girls that were brought to 12 A. Does not sound familiar at all. 12 Mr. Epstein's home? 13 Q. How about'"? 13 MR. CRITTON: Form. 14 14 THE WITNESS: At least 20. 15 Q. Does the name sound familiar to you at all? 15 BY MR. KUVIN: 16 I. as a girl that went over to Mr. Epstein's home at 16 Q. At least? 17 some point? 17 A. At least 20. 18 A. rye heard that name come up a few times. 18 Q. Could it be at least 30? 19 Q. Do you remember bringing a'. over to the 19 A. I don't know. 20 house? 20 MR. CR1TTON: Form. 21 A. I never brought a over to the house. 21 THE WITNESS: I don't want to speculate. 22 Q. Of any of the girls that you brought, do you 22 BY MR. KUVIN: 23 know if any of those girls then did similar to you in 23 Q. But through either firsthand knowledge, in 24 getting other girls? 24 addition to secondhand knowledge from the girls 25 A. All of them. 25 themselves, you're aware of at least 20? 4 (Pages 166 to 169) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddl-59ee-4e57-9cd8-1339205600fc0 EFTA01075990  Page 170 Page 172 1 A. At least. 1 whatever, at word got around campus. And 2 Q. Okay. And of those girls, other than the one 2 then girls that 1 were bringing were like, yeah, I know 3 girl that we've talked about before that was 24 years 3 so and so and she did that, like, ninth grade. But it's 4 old, as you sit here today, all those girls were under 4 hearsay. 5 age 18; is that correct? 5 Q. I understand. M., how much older than you 6 MR. CRITTON: Form. 6 was she? 7 THE WITNESS: That I know ot yes. 7 A. My age. 8 BY MR. KUVIN: 8 Q. She was your age? 9 Q. And the on one ou're aware of that was over 9 A. She's my age now. 10 that age of 18 was 10 Q. Well then, she would have been your age then? 11 A. At 23, yes. 11 A. Yeah. 12 Q. Did Jane Doe 101 ever tell you how she first 12 Q. Right? 13 heard about Mr. Epstein? 13 A. Yeah. 14 A. No, she did not. 14 Q. Okay. Unless she's got a time machine that we 15 Q. What I'm hying to understand is, at some 15 don't know about. 16 point it seemed like, according toyour testimon that 16 A. She might. 17 there were a number of girls from High 17 Q. You had heard that she went in ninth grade? 18 School that were going over to Mr. Epstein's home during 18 A. That is what I heard. 19 this period of time in 2005, early 2006. 19 Q. Who did you hear that from? 20 What I'm trying to figure out is, if you know, 20 A. Multiple people. 21 how did Mr. Epstein or his people get entree into your 21 Q. Are you aware, other than her, of anyone else 22 high school initial) in other words, who was the first 22 that went over to Jeffrey's house before you that was 23 person at High School, if you know, 23 going to 24 that started this whole thing? 24 A. Yes. 25 MR. CRITTON: Form. 25 Q. Who else? Page 171 Page 173 1 THE WITNESS: I have no idea. I do not !mow. 1 A. 2 It wasn't me. 2 Q. When did she go? 3 BY MR. KUVIN: 3 A. I don't know if she ever worked for him or 4 Q. Right. Because Jane Doe 101 got you? 4 gave him a massage, but she was — she's been to his 5 A. Jane Doe 101 got me, that's correct. 5 house. 6 Q. And I'm sorry. I know I asked this before. 6 7 But Jane Doe 101, she was a classmate of yours at 7 8 El? 8 A. iO or (phonetics), I 9 A. No. I went to with her. 9 think. 10 Q. Okay. 10 Q. Okay. Who else? 11 A. Her, We weren't friends, didn't hang out. 11 A. On top of my head, that's all 1 can think of. 12 Just saw each other through the hallways. 12 Q. Do you know how to spell 13 Q. Well, that's interesting then. 13 A. 14 wathe Ar first girl, that you're aware of, 14 Q. 15 from High School that went to Mr. Epstein's 15 A. 16 home? 16 Q. And 17 MR. CRTTTON: Font 17 A. I. 18 THE WITNESS: No. 18 Q. And Flow do you II= 19 BY MR. KUVIN: 19 A. 20 Q. Who was the first girl that you were aware of 20 Q. Other than anyone else 21. from = that went there? 21 Brom that you're aware of that went over 22 A. 22 there? 23 Q. And how did you become aware of her going? 23 .A. 24 A. When I started going and I started bringing 24 Q. 25 girls that I was friends with, acquaintances with, 25 5 (Pages 170 to 173) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dddl•59e*Ao57-9cd8439205600fc0 EFTA01075991  Page 174 Page 176 1 1 M. was just - I don't even know what 2 A. 2 category I can put her under. 3 Q. Who else? 3 Jane Doe 3 was definitely promiscuous. 4 A. That's it, that I can think of on the top of 4 I don't really have a category to put M. 5 my head that went before I even heard about him. 5 under. She was just kind of the younger one, the not so 6 Q. Were you all at school talking about going 6 bright one. 7 over to this old guys house on the beach? Q. Got you. When you would ask girls to go, 8 MR. CRITTON: Form. would you look for the ones you thought were more BY MR. KUVIN: promiscuous? 10 Q. I mean, were there any conversations that were 10 MR. CRITTON: Form. 11 had around the hallways at school about this issue? 11 THE WITNESS: No. No. 12 MR. CRITTON: Font 12 BY MR. KHVIN: 13 THE WITNESS: I had no idea that they had even 13 Q. How would you decide which ones to ask? 14 gone until after I met Epstein and was already done 14 A. They were my friends, the girls that I vent to 15 with my situation. 15 school with, the ones that I kicked it with after 16 BY MR. KUVIN: 16 school. They were in my circle. It was convenient. 17 Q. Right. 17 Q. Okay. Call me naive, but how do you convince 18 A. So this is information that I've learned in 18 a girl that age to go to an old man's house, even just 19 the last three years — 19 to give a massage? 20 Q. Okay. 20 MS. BLANTON: Object to the form. Go ahead. 21 A. -- that I hadn't known before. 21 I think you were handling the answer just fine. 22 The girls and the friends that I hung around 22 MR.. CRTITON: Form. 23 with, they would all talk about it in the hallways 23 BY MR. KUVIN: 24 because they knew that I was taking them or that they 24 Q. Go ahead. 25 met him through me. 25 A. That's the thing. I didn't have to convince Page 175 Page 17 Q. Right. 1 than. 2 A. But if you mean communication through 2 Q. What do you mean? 3 different cliques in the hallway, as, like, an issue, 3 A. I didn't convince anything. I proposed to 4 no, nobody ever spoke about it. 4 them. They took it. They volunteered. 5 Q. Okay. All the girls that you took, what was 5 Q. Okay. 6 their, I guess for lack a better term, social status 6 A. Sometimes the girls would come up to me and 7 within the school? I mean, were they popular girls? 7 ask me if they can work for him this weekend. There was Were they not popular girls? Were there, you know,1 8 no convincing needed. 9 mean, in sane schools there are, like, the cheerleaders 9 Q. Right. So you would just mention it and — 10 and the different groups? 10 A. They jumped on it, just like I did. 11 A. Should I be brutally honest? 11 Q. Then why did it bother you when you did it the 12 MR. HOROWITZ: I'm going to object to the form 12 first time? 13 then. 13 A. It bothered me more so because I just — I 14 BY MR. KUVIN: 14 can't explain it to you. It didn't bother me then as it 15 Q. Yes. Brutally honest. 15 bothered me now. It bothers me now for different 16 A. Do you want to include myself in this? 16 reasons. 17 Q. Let's k1 46ou out of it for the moment. 17 Q. Well, do you think you were any less sensitive 18 was the party animal. 18 than these girls? 19 20 A.a cheerleaders. and and, I believe,.. were the 19 20 A. I am definitely less sensitive than those girls. 21 Q. Okay. 21 Q. You see yourself as being more sensitive than 22 A. Jane Doe 7 and Jane Doe 4 were the promiscuous 22 them? 23 ones. 23 A. At times, yes. At other times, no. Pm a 24 was - not promiscuous, but 24 very hard person. Everybody's sensitive when they want 25 more flirtatious. 25 to be. You strike somewhere where it hurts, you're 4.4.5.-M14:41A.Vtaattor.? 6 (Pages 174 to 177) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7082dddf-59ce-4e57-9cd8-8392056001c0 EFTA01075992  Page 178 Page 180 1 going to be sensitive. You're going to &IL 1 BY MR. HOROWITZ: 2 Q. And this whole issue with Epstein obviously is 2 Q. Hi. Good afternoon. My name is Adam 3 a sensitive point with you? 3 Horowitz, as I mentioned when we started today. 4 A. It is. 4 A. Okay. 5 Q. Did like the fact that went over 5 Q. I represent seven of the Plaintiffs. Pm 6 them, if you know? 6 going to be asking you some questions, sort of filling 7 A. I don't know. 7 in some blanks in my mind based on the previous 8 Q. Did you ever hear that he was upset about you 8 questions and also some particular questions about my 9 bringing..? 9 clients. Okay? 10 A. We did have a falling out. 10 Sort of at the beginning of the deposition you 11 Q. After you brought'.? 11 told us that Jute Doe 101 first mentioned Jeffrey 12 A. After I brought When he found out that I 12 Bpstein's tune to you at the Beach Resort; is 13 Ness going to bring her, yeah, he distanced himself from 13 that right? 14 her and me. 14 A. That is correct. 15 Q. Do you know why? 15 Q. Before that time, you had never heard ofhim; 16 A. No. 16 is that right? 17 Q. Did you hear that he actually punched a wall 17 A. That's right. I had never heard of him 18 he was so upset? 18 before. 19 MR. CRITTON: Form. 19 Q. But you know now that certain 20 BY MR. KUVIN: 20 classmates of yours wore already going to his house? 21 Q. Did someone tell you that? 21 A. That's correct. 22 A. No. 22 Q. Did Jane Doe 101 ever tell you that she, 23 Q. Have you talked to him since? 23 herself, had gotten paid for giving Mr. Epstein a 24 A. We're not as close. 24 massage or was she simply a recruiter for him? 25 Q. Have you talked to him at all since? 25 A. We news discussed that Page 179 Page 181 1 A. Yes. 1 MR. CRITTON: Form. 2 Q. Did you talk to him about this incident? 2 BY MR. HOROWITZ: 3 A. No. Ifs not a conversation that me and him 3 Q. Do you — as we sit here today, do you know of 4 have had. Ifs not a conversation that I would like to 4 anything that took place when Jane Doe 101 went to 5 have with him. 5 Jeffrey's house? 6 Q. Is that the only reason you can think of that 6 A. No. 7 you two had a falling out? 7 Q. Do you know if she ever gave him a massage? 8 A. Yes. 8 A. No, l don't 9 Q. When you were in the room with Mr. Epstein, 9 Q. Do you know if they ever had sexual contact? 10 did you actually see his genitals? 10 A. No, I do not. 11 A. I don't remember. I tried not to look. 11 Q. And you told us that Jane Doe 101 did not 12 Q. Okay. So as you sit here today, you couldn't 12 forewarn you that Jeffrey Epstein would touch you in a 13 describe them? 13 sexual manner, is that correct? 14 A. No. I could not describe them for you. 14 MR. CRITTON: Form. 15 Q. I don't mean obviously his face. I'm talking 15 THE WITNESS: That's correct. 16 about his genitals. You could not describe those? 16 BY MR. HOROWITZ: 17 A. I could not describe his genitals for you. 17 Q. Did she ever say that he would touch your 18 Q. Okay. Did you ever talk tot's parents? 18 private parts? 19 A. No. 19 A. No. He never did she never did. 20 MR. KUVIN: All right. I appreciate it. 20 Q. She never told you that? 21 That's all the questions I have at this point 21 A. Sony. 22 Other attorneys, I'm sure, are going to have some 22 Q. Did you ever tell her that, in fact, he had 23 for you. 23 touched you, as you said, below the belt in the front? 24 (Discussion held off the record.) 24 MR. CRITTON: Form. 25 CROSS EXAMINATION 25 THE WITNESS: I don't remember. I 7 (Pages 178 to 181) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82dridt-Sgee-4e57-9cd8-8392056001c0 EFTA01075993  Page 182 Page 184 1 BY MR. HOROWITZ: 1 going to touch you in a sexual manner? 2 Q. You don't know if you ever told her that? 2 MR. CRITTON: Form. 3 A. I don't know if l ever told her that. 3 THE WITNESS: Yes. 4 Q. Was it upsetting to you that she didn't tell 4 BY MR. HOROWITZ: S you that that might occur? 5 Q. Now, you -- do you know if she recruited other 6 A. I don't remember. 6 girls to go to Jeffrey's house? 7 Q. Are you, as we sit here today, upset — if she 7 A. I don't know. 8 knew — strike that. 8 Q. Has she ever told you that she recruited other 9 If she knew that Jeffrey Epstein had a sexual 9 girls to go to Jeffrey's house? 10 interest in girls, would you have liked to have known 10 A. I can't remember. 11 that before you went to his house? 11 Q. Have you heard from anyone that Jane Doe 101 12 MR. CRITFON: Form. 12 recruited other girls to go to Jeffrey's house? 13 THE WITNESS: I don't know. 13 A. Nobody said anything, no. 14 BY MR. HOROWITZ: 14 Q. As we sit here today, are you aware— is it 15 Q. That might be something you didn't care about 15 your understanding that you are the only person that she 16 before you went to his house? 16 recruited or do you have some other fountain of 17 A. I don't know how to answer that. I don't 17 information? 18 know. I'm not being put in that position. 18 A. To my knowledge, I'm the only girl that she 19 Q. Well, was it upsetting to you when he touched 19 recruited. 20 you in a sexual manner and you had no idea he was going 20 Q. And when she recruited you, did she talk about 21 to do that? 21 the range of girls that Jeffrey preferred? 22 A. I don't know. I can't recall my feelings at 22 A. No. 23 that point in time. 23 Q. Did she indicate to you at any point how long 24 Q. And you don't recall whether you ever told her 24 it is that she was -- had been recruiting for Jeffrey 25 what had taken place? 25 Epstein? Page 183 Page 185 1 A. I don't know if I ever told her. 1 A. No, she did not. Q. Now, when you got done with this 2 Q. And you told us that when you recruited for 3 massage/touching encounter, you went downstairs and you 3 Jeffrey Epstein, you told the girls that you worked for I saw her on the first floor of the house? 4 Jeffrey; is that eorree.t? 5 MR. CRITTON: Form. 5 A. Yes. 6 BY MR. HOROWITZ: 6 Q. Did she make a similar pitch to you, I work 7 Q. is that right? for Jeffrey and I'd like you to come for a massage? A. I went downstairs. I don't know if she came 8 A. I can't remember. 9 up and got me or inflict her down there, but she was 9 Q. Okay. Turning your attention to the encounter 10 waiting for me with yes. 10 when you were in the massage room with Jeffrey. When 11 Q. And then you proceeded to ride home -- 11 Jeffrey Epstein reached below your belt in the front, as 12 A. Together. 12 you described it, did you push him away? 13 Q. Together? Did you tell her any of the events 13 A. I pushed his hand away. 14 that had taken place upstairs in the massage room? 14 Q. You pushed his hand away. 15 A. I can't recall. 15 Did you, like, move away as well? 16 Q. Do you think she should have told you that 16 A. I don't remember. 17 Jeffrey Epstein was going to touch you in a sexual 17 Q. Was that your -- was that your indication to 18 manna? 18 him that you were uncomfortable with what it is he was 19 A. Should she have? 19 doing? 20 MR. CRITTON: Form. 20 A. Yes. 21 THE WITNESS: I don't know. Yes. 21 Q. What I'm trying to get at is, that's why you 22 BY MR. HOROWITZ: 22 pushed him away, to indicate to him you didn't want him 23 Q. Well, which is it] don't know or yes? I'll 23 to touch you that way? 24 ask the question again so it's clear. 24 A. That's correct. 25 Should she have told you that Jeff Epstein was 25 Q. In a sexual way? Y.• 8 (Pages 182 to 185) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 7a82ddd1.59o0.4057.9cd8.839205600fc0 EFTA01075994  Page 186 Page 188 A. That's correct. 1 Q. He said what? 2 Q. Did he continue masturbating after you told 2 A. He had just made a comment about her age when 3 him — after you pushed his hand away? 3 he was paying me. He just made a comment, like, you 4 MR. CRITTON: Form. 4 know, she was old. 5 THE WITNESS: Yes. 5 Q. Meaning, the previous girl -- 6 BY MR. HOROWITZ: 6 A. Yes. 7 Q. And you — did you hear him, like, breathing 7 Q. — was old? 8 heavy? 8 Did Jeffrey — now, you told us that the range 9 MR. CRITTON: Form. 9 of the other girls you brought was between ages 14 and 10 THE WITNESS: I can't remember. 10 17; is that alma 11 BY MR. HOROWITZ: 11 A. Besid that's right. 12 Q. Was he masturbating, like, with his hand on 12 Q. Did Jeffrey Epstein ever express displeasure 13 his penis? 13 with the 14 to 17 year old girls that you brought? 14 A. Yes, 14 A. !don't know. 15 MR. CRITTON: Form. 15 Q. I'm just asking, did he ever express it to 16 BY MR. HOROWITZ: 16 you? 17 Q. And had you looked that way, would his 17 A. He never expressed it to me. 18 genitals have been exposed? 18 Q. Now, when you were bringing these girls over 19 A. Yes. 19 to Jeffrey Epstein's house, did you believe that these 20 Q. And did he suddenly stop masturbating, as in, 20 girls were going ova to Epstein's house so that Epstein 21. when someone has a climax or orgasm? 21 could have sexual contact with them? 22 A. Yes. 22 A. I don't know. 23 Q. You distinctly recall that? 23 Q. Now — go ahead. 24 A. Yes. 24 A. 1don't know. I never directly stated 25 Q. At the conclusion of this encounter in the 25 anything about sexual contact Page 187 Page 189 1 massage room, you told us, I think, that Jeffrey Epstein 1 Q. I got that I'm not asking what you said. 2 asked you to bring other girls. Did I get that right? 2 But in your own mind, when you're bringing these girls 3 A. Yes. 3 over, did you think in your own mind, these girls are 4 Q. What was your response? 4 going over to Ertein's house and Epstein is going to 5 A. I told him, okay. 5 have some type of sexual contact with them, the same way 6 Q. You were comfortable with that? 6 he did with me? 7 A. Yes. 7 MR. CRITTON: Form. 8 Q. And did you tell him, I'll be in touch, or THE WITNESS: I don't know. 9 anything along those lines? 9 BY MR. HOROWITZ: 10 A. I don't tensanber. 10 Q. It didn't cross your mind that — 11 Q. But by then you already had lumber, 11 A. I don't know what crossed my mind seven years 12 telephone number? 12 ago. 13 A. At some point 1had number. I don't 13 Q. Okay. Did you believe that you were being 14 recall if it was before or after the massage. 14 paid cash to bring over girls to Epstein's house for 15 Q. Okay. All right. Now, you told us that 15 sexual pleasure? 16 on one occasion brought an older girl named is 16 A. No. 17 that right? 17 MR. CRITTON: Form. 18 A. That is right. 18 BY MR. HOROWITZ: 19 Q. Was it Jeffrey Epstein who told you she was 19 Q. What did you think the purpose of the money 20 too old? 20 that you were getting was? 21 A. Yes. 21 A. To introduce him to girls for massages. 22 Q. And did he tell you that when you arrived in 22 Q. For massages? 23 the first floor of the house or after the massage or 23 A. Yes. 24 when did that conversation take place? 24 Q. You thought that a reason that you were 25 A. The next girl I brought.