EFTA00179301.pdf
1 UNITED STATES DISTRICT COURT
2 SOUTHERN DISTRICT OF FLORIDA
3
4
5
6
UNITED STATES OF AMERICA,
Plaintiff, COPY
7 vs.
8 JEFFREY EPSTEIN, SARAH KELLEN,
ADRIANA ROSS, a/k/a Adriana Mucinska,
9 and NADIA MARCINKOVA,
10 Defendants.
11
12
13 TESTIMONY
14 OF
15 SPECIAL AGENT
16
17
18 Federal Grand Jury 07-103
Federal Building
19 U.S. Courthouse
West Palm Beach, Florida
20 Tuesday, March 18, 2008
21
22 APPEARANCES:
23
Assistant United States Attorney
24
25 Foreperson
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1 The sworn testimony of SPECIAL AGENT
2 I. was taken before the
3 Federal Grand Jury, West Palm Beach Division,
4 Federal Building, U.S. Courthouse, Palm Beach
5 County, State of Florida, on Tuesday, March 18,
6 2008.
7 , Certified Court
8 Reporter and Notary Public, State of Florida,
9 Official Reporting Service, LLC, 524 South Andrews
10 Avenue, Suite 302N, Fort Lauderdale, Florida,
11 33301 , was authorized to and did report the sworn
12 testimony.
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1 (Witness enters the Grand Jury Room.)
2 THE FOREPERSON: You do solemnly swear
3 that the testimony you give will be the
4 truth, the whole truth, and nothing but the
5 truth, so help you God?
6 THE WITNESS: I do.
7 THE FOREPERSON: Thank you. Please be
8 seated.
9 EXAMINATION
10 BY
11 Q Good afternoon, Special Agent
12 Would you just remind the grand jury
13 of your name and for whom you work?
14 A I am My official name is
15 and I work for the FBI here
16 in West Palm Beach.
17 Q All right. And you are still one of the
18 case agents on Operation Leap Year?
19 A Yes, I am.
20 Q Have additional subpoenas been issued on
21 behalf of this grand jury regarding Leap Year?
22 A Yes, they have.
23 Q And have documents been received in
24 response to those subpoenas?
25 A Yes, they have.
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1 Q What subpoenas were issued and what
2 items were received?
3 A The items that are received are in this
4 box for your review at a later time, but starting
5 with the first subpoena that we had received
6 documents back for would be from American Express.
7 The subpoena was issued and we received
8 credit card account information.
9 Q Okay.
10 A Do you want me just to --
11 Q You can just go through them.
12 A A subpoena was issued to J. Epstein
13 Virgin Island Foundation, Inc., J. Epstein and
14 Company, Epstein Interests, Financial Trust
15 Company, Inc., and we received documents on all
16 three of those except for -- all four of those
17 except for Jeffrey Epstein and Company --
18 J. Epstein and Company, which we received a letter
19 of no response.
20 The next subpoena was issued to the Palm
21 Beach County School Board and we received
22 transcript request forms. The next grand jury
23 subpoena was issued to Dan Tishler, Airport
24 Executive, Town Car Services. We received a
25 verbal that there were no records from Mr.
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1 Tishler.
2 We issued a grand jury subpoena to the
3 custodian of records for Majestic Theater, which
4 we received ticketing records for.
5 We issued a grand jury subpoena or you
6 issued a grand jury subpoena for the custodian of
7 records at the Broward Center for the Performing
8 Arts and we received ticketing records.
9 We issued a subpoena for the custodian
10 of records for the Kravis Center for the
11 Performing Arts and received a letter of no
12 records response.
13 We issued a subpoena for the custodian
14 of records for Live Nation Theatrical Broadway
15 Across America. Again, received a response letter
16 of no records.
17 We issued another subpoena for the
18 custodian of records from Live Nation Theatrical
19 Broadway Across America and that we did receive
20 some ticketing records.
21 We issued a subpoena to Bear Sterns and
22 Company, Inc., and we received personnel files and
23 account information. We issued a grand jury
24 subpoena for Wolf Camera and we received
25 transaction records.
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1 We have issued a grand jury subpoena to
2 Amazon.com and received order records. We issued
3 a grand jury subpoena to Federal Express and
4 received shipping records, and all that is
5 contained in this box.
6 Q All right.
7 And at the end of our
8 preservation, you will be welcome to look
9 through any of those records and we also will
10 bring them to the next session.
11 A GRAND JUROR: I have a question.
12 Yes.
13 A GRAND JUROR: We subpoenaed
14 information from theaters. I heard you say
15 ticketing information or records from a few
16 of them.
17 Did we subpoena that information to
18 establish location of the defendant or I
19 guess he's not a defendant yet?
20 THE WITNESS: Just as corroborating
21 evidence of testimony provided by the girls.
22 Their statements provided to us.
23 A GRAND JUROR: Okay.
24 BY
25 Q Okay. Special Agent , each
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1 member of the grand jury has before them a copy of
2 a chart. Do you also have a copy of this chart
3 entitled Revised Indictment Summary Chart
4 (by victim)?
5 A Yes.
6 Q And then you also provided to everyone a
7 list of Jane Does with photographs?
8 A Yes, I did.
9 Q Okay. Can you just explain to the grand
10 jury how -- which Jane Does we are going to be
11 talking about today?
12 A We are going to talk about Jane Does One
13 through Six and Nine and Ten, and what you have
14 here is a Jane Doe list of One through 19. We
15 will be going through the first Six and Nine and
16 Ten.
17 As you can see, if you look at these two
18 columns you'll see in the indictment we have
19 before you is going to have the new Jane Doe
20 numbers and the column to the right of that shows
21 you what their Jane Doe number used to be.
22 So Jane Does Nine and Ten, when we spoke
23 about those two before, and we will go through
24 that a little bit later, we referred to those as
25 Jane Does Six and Seven. From here on out, we
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1 will refer to them as Jane Does Nine and Ten.
2 A GRAND JUROR: I have a question about
3 Jane Doe Number One, and Amy pointed this
4 out. The date of birth is August 1983. The
5 range of activity dates is 1988 to 2003?
6 THE WITNESS: That's a typo. That
7 should be 1998.
8 Thank you for catching
9 that.
10 A GRAND JUROR: I was about ready to
11 have a problem here. I was having a real
12 problem. Yeah.
13 Okay. Thank you.
14 A GRAND JUROR: I was about to take the
15 law into my own hands.
16 THE WITNESS: Let there be noted on the
17 summary chart, there is a typo correction for
18 Jane Doe Number One. The range of activity
19 for her is 1998 to 2003.
20 This chart is a chart that we put
21 together because I have testified in the past
22 as well as you may have heard other testimony
23 regarding some of the Jane Does, and we are
24 going to be talking about them today and in a
25 later session.
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1 We want -- we provided this to you sort
2 of as an aid so that you can go back and
3 access the grand jury transcripts and go to
4 the date that the testimony was provided.
5 If you look at the last column where it
6 says, Grand Jury Transcript Pages, on this
7 form it will tell you the date of the grand
8 jury, who provided that testimony, and the
9 page number where you can find testimony
10 related to those specific Overt Acts and
11 substantive counts.
12 So the two columns next to that -- let's
13 just take Jane Doe Number Two and run through
14 that real quick. Jane Doe Number Two, we
15 have not testified about before. So that is
16 her number and will always remain her number.
17 Her date of birth is January of 1987.
18 The range of activity and that reflects the
19 range of activity that we have her connected
20 to Mr. Epstein and his assistants.
21 The next two columns are the Overt Acts
22 and the associated substantive counts. The
23 Overt Acts support those substantive counts
24 and again the last column you would at that
25 point go to my testimony on May 8th, 2007,
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1 and look on the transcript on Pages Six and
2 Seven, and that would be my testimony for the
3 Overt Acts, the supporting evidence and
4 testimony for Overt Acts One
5 through 18.
6 BY
7 Q But, Special Agent just so
8 that it is clear, when you testified back in May,
9 you weren't testifying specifically about Jane Doe
10 Number Two, but her name came up in with
11 respect to one of the other Jane Does?
12 A Exactly.
13 Q Okay. So any information related to
14 those Jane Does would be in the transcript pages?
15 A Yes.
16 Does that make sense to
17 everyone how we have organized that?
18 BY
19 Q Now Special Agent , if you
20 could look at the proposed indictment, and I'm
21 looking at the Background section of the
22 indictment specifically Paragraphs One through
23 Nine, which deal with Mr. Epstein's background and
24 who he employed.
25 Have you testified about that material.
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1 in the past?
2 A Yes, I have.
3 Q And let me just direct you to Overt Two,
4 which is at the top of Page Two. There is a
5 reference to L.G., and I don't believe we have
6 talked about L.G. before.
7 Can you tell the grand jury who that is?
8 A L.G. is Lesley Groff and she is a
9 personal assistant or an assistant for Mr. Epstein
10 in his New York office.
11 Q All right. And just for the court
12 reporter, Lesley is L-I-S-L-M-Y, and Groff is
13 G-R -O-F-F; is that correct?
14 A Yes, it is.
15 Q Then Paragraph Three talks about three
16 individuals, ., and . Can you tell
17 the grand jury who those persons are?
18 A is Tatum Miller. . is
19 is Anthony Figueroa.
20 Q And if you look at the summary chart on
21 the second page, there are columns for . and
22 Do you see those at the bottom of Page Two?
23 A Yes, I see them.
24 Q And those refer to Tatum Miller and
25 Anthony Figueroa where you have testified about
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1 them before or where III. was who
2 testified about them?
3 A Yes.
4 Q I know that you have testified about
5 Mr. Epstein's residence here in Palm Beach, but if
6 you could look at Paragraph Five of that
7 introductory section, which is on Page Two.
8 Are you -- can you provide the grand
9 jury with the location of Mr. Epstein's New York
10 residence?
11 A Mr. Epstein currently has a property
12 located at 9 East 71st Street, New York, New York.
13 Q If I could direct you to Page Five of
14 the proposed indictment in Paragraphs 18 through
15 25 of the introductory section.
16 Can you tell the grand jury about where
17 the various victims in this case attended high
18 school?
19 A I can. Starting with Paragraph 18.
20 Would you like me to just run through them?
21 Q Sure.
22 A Jane Doe Number Four attended Wellington
23 High School and Palm Beach Central High School.
24 Jane Doe Number Five attended Wellington High
25 School. Jane Doe Numbers Six, Eight, and 12,
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1 attended Palm Beach Central High School.
2 I should state that all of these high
3 schools are located in Palm Beach County. Jane
4 Doe Number Seven attended William T. Dwyer High
5 School in Palm Beach County.
6 Jane Doe Numbers Nine, 14, 15, 16, 17,
7 18, and 19 attended Royal Palm Beach High School
8 in Palm Beach County. Jane Doe Number Ten
9 attended Lake Worth High School in Palm Beach
10 County.
11 Jane Doe Number 11 attended the
12 Professional Performing Arts School, a public high
13 school located in the New York area; New York, New
14 York. Jane Doe Number 13 attended John I. Leonard
15 High School in Palm Beach County, and the Jane
16 Does attended these high schools during some point
17 of the contact with Mr. Epstein.
18 Q Now Special Agent , I know
19 that not each and everyone of the Jane Does is
20 listed in this. Did some of the Jane Does leave
21 school before they began their relationship with
22 Mr. Epstein?
23 A Yes, they did.
24 Q Now everyone was handed a copy of a
25 document entitled, Merged Flight Manifests. If I
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1 could ask you to take a look at that, and in the
2 proposed indictment if you could turn to Page 32.
3 Special Agent , I'm going to
4 ask you about Overt Acts 191 through 225. Can
5 you tell the grand jury what the basis is for the
6 allegations set forth in 191 through 225?
7 A We received through the issuance of a
8 grand jury subpoena the flight manifest from Mr.
9 Epstein's pilot and that is our evidence to show
10 the travel that Mr. Epstein did, which is
11 displayed in Overt Acts 191 through 225.
12 Q And the chart that is entitled Merged
13 Flight Manifests, what does that include?
14 A This chart will show the grand jury that
15 in January 2004 through -- basically, Mr.
16 Epstein's travel in '04 and '05 on his two
17 personal aircrafts, which would be the Boeing 727
18 and the*Gulfstream.
19 If you look at this chart, the first
20 column is the date of departure, the date that he
21 left, and you'll see airport codes in the next
22 column that tells you the airport that he left and
23 what time he left would be the next time, the
24 departure time.
25 It will tell you what airport he was
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1 arriving in and what time he arrived at that
2 airport, and the last would be the actual
3 aircraft itself, which aircraft he was traveling
4 on, and just to remind the grand jury, Hyperion
5 is the Gulfstream and JEGE is the Boeing 727.
6 Q And who created this chart, the Merged
7 Flight Manifests Chart?
8 A The FBI.
9 Q And where did they gather this
10 information from?
11 A We subpoenaed or the grand jury issued a
12 subpoena to the pilot and pilots of Mr. Epstein
13 and through counsel the pilots gave us a copy of
14. the flight manifest for those two years and I have
15 here a set of the flight manifests that were
16 provided to us by the grand jury subpoena and have
17 marked each of the Overt Acts from 191 to 225.
18 So that if any time the grand jury would
19 like to come and look at the actual manifest the
20 pilots gave us, you'll be able to see the data
21 that this form was taken from.
22 Q Okay. Thank you.
23 : Before I go on, does
24 anyone have any questions about those Overt
25 Acts and where this information came from?
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1 Yes, sir.
2 A GRAND JUROR: Is there something that
3 ties in these travel itineraries to the
4 actual fact that there was a meeting or
5 something planned? I mean, where does that
6 tie together? Traveling is not against the
7 law.
8 Right. The way that we
9 had the indictment organized before was an
10 attempt to do this in chronological order,
11 which seems to be more confusing rather than
12 less confusing.
13 So when you look at the -- when you hear
14 the testimony from Special Agent
15 and when you look at the Overt Acts related
16 to the victims and when he went to see them,
17 you'll see that the dates of travel relate to
18 the dates of his meeting with the victims.
19 Does that make sense?
20 A GRAND JUROR: Yes.
21 BY
22 Q Is there anything else, Special Agent
23 , that I should add to that?
24 A No. It will become clear once we
25 testify about the travel count.
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1 A GRAND JUROR: Can I just ask which
2 airport is ISM?
3 THE WITNESS: You know, I can in the
4 next session, I would be happy to bring the
5 airport codes.
6 A GRAND JUROR: Okay.
7 THE WITNESS: Obviously, we focused in
8 on his times when he traveled into the Palm
9 Beach County area and that would be PBIA Ol
10 PBI, but I can certainly provide all the
11 airport codes at our next session.
12 BY
13 Q All right. Now throughout the Overt
14 Acts portion where there are discussions of
15 various Jane Does, there will be mentioned a
16 telephone call.
17 So, for example, if you look at Page
18 Ten, Paragraph 17, it says on or about April 23rd,
19 2004, Defendant .Sarah Kellen placed a telephone
20 call to a telephone used by Jane Doe Number Two.
21 Do you see that?
22 A Yes.
23 Q And Special Agent , what is
24 the evidence that we have related to the telephone
25 calls that are mentioned in the Overt Acts?
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1 A We have issued administrative subpoenas
2 to telecommunication companies for cell phone
3 records for Mr. Epstein's assistants as well as
4 many of the Jane Does.
5 These specific Overt Acts are reflected
6 in those telephone records and we have also
7 prepared for the grand jury -- I brought with me
8 today, and I will bring with me next time, all of
9 the telephone records for -- that we have received
10 via administrative subpoenas.
11 Today I brought the ones pertaining to
12 the Overt Acts and what we have done is we have
13 taken those cell phone records and we have marked
14 for the grand jury all the Overt Acts that are
15 listed in the indictment.
16 You'll note when you go to that page,
17 there will be a little mark by the telephone call
18 that we are specifically talking about in the
19 Overt Acts.
20 Q And can ydu just remind the grand jury
21 what information will be on those records?
22 A It will be telephonic contact between
23 Sarah Kellen, Nadia Marcinkova, Adriana Ross or
24 Mucinska, telephonic contact between his
25 assistants and the Jane Does.
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1 Q It will show the telephone number that
2 was called and the dates and time and length of
3 the call?
4 A Yes, it will.
5 Q All right.
6 Any questions before we
7 start talking about the sexual activity
8 between the defendant and the victims? Okay.
9 No questions.
10 BY
11 Q Let's talk first about Jane Does One and
12 Two. They are grouped together in Overt Acts One
13 through 18. Who is Jane Doe Number One?
14 A Jane Doe Number One is a white female.
15 Her name is Virginia. She was born in August of
16 1983 and she lived in the Palm Beach County area
17 during the time that she had contact with Mr.
18 Epstein.
19 Q Has she been interviewed?
20 A Statements have been provided to the FBI
21 by Jane Doe Number One.
22 Q In addition to her statements, who else
23 has provided information regarding Jane Doe Number
24 One?
25 A Jane Doe Number Two and Jane Doe Number
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1 One's boyfriend at the time she had contact with
2 Mr. Epstein, which is Anthony Figueroa.
3 Q Who is referred to as in the
4 indictment?
5 A Yes.
6 Q During what period of time, did Jane Doe
7 Number One have contact with Mr. Epstein?
8 A Jane Doe Number One met Mr. Epstein when
9 she was 15. So that would be in the last half of
10 1998 until 2003 that we are aware of.
11 Q How did she meet Jeffrey Epstein?
12 A She met Mr. Epstein at age 15 and
13 according to her boyfriend when she was 20, Mr.
14 Epstein sent her to Thailand for massage therapy
15 school.
16 So she -- the time frame that she was
17 with Mr. Epstein was from the age of 15 until we
18 are aware of is age 20. Anthony Figueroa never
19 saw Jane Doe Number One again after she went to
20 Thailand.
21 She would contact him by telephone, but
22 she never returned back. He stated he inherited
23 her dog. She never came back that he is aware of.
24 So the time frame that we had Jane Doe Number One
25 with Mr. Epstein is from age 15 to 20.
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1 I'm sorry, the question you asked me
2 was: How did they meet? They met by a friend of
3 Mr. Epstein's. Jane Doe Number One was working at
4 Mar-a-Lago and a friend of Mr. Epstein's,
5 Ghislaine Maxwell.
6 Would you like the spelling?
7 THE REPORTER: Yes, please.
8 THE WITNESS: G-H-I-S-L-A-I-N -I,
9 Maxwell, who was a friend of Mr. Epstein, met
10 Jane Doe Number One at Mar-a-Lago and Jane
11 Doe Number One soon after began working and
12 providing massages for Mr. Epstein.
13 BY
14 Q What sexual activity was Jane Doe Number
15 One involved in with Jeffrey Epstein?
16 A Through the statements provided by Jane
17 Doe Number Two, when Jane Doe Number Two was 14
18 years of age, she saw Jane Doe Number One naked
19 and engaged in what she believed to be sexual
20 intercourse with Mr. Epstein.
21 Q Now did Jane Doe Number One recruit any
22 one else to go to Jeffrey Epstein's home?
23 A At this time, the only Jane Doe that we
24 are aware of is Jane Doe Number Two or the only
25 individual we are aware of is Jane Doe Number Two.
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1 Q Okay. So let's talk about Jane Doe
2 Number Two. Who is she?
3 A Jane Doe Number Two is a white feinale
4 named Carolyn. She was born in January of 1987.
5 She lived in Palm Beach County, Florida, at the
6 time she had contact with Mr. Epstein.
7 Q And how -- has she been interviewed?
8 A Yes.
9 Q During -- how old was she during the
10 time frame that Jane Doe Number Two was involved
11 with Mr. Epstein?
12 A She was 14 at the time that she first
13 met Mr. Epstein.
14 Q And she was involved with him until she
15 was 17?
16 A We have in or about the beginning of
17 2001, which would make her 14 up until 2004.
18 Q And how did she come to meet Mr.
19 Epstein?
20 A Jane Doe Number One brought Jane Doe
21 Number Two to Mr. Epstein's residence for the
22 first time. Mr. Epstein was introduced to Jane
23 Doe Number Two by Jane Doe Number One.
24 There was a massage that took place with
25 the two of them and then Jane Doe Number One
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1 engaged in sexual activity that I mentioned
2 earlier where Jane Doe Number Two informed us that
3 she sat on the couch and observed what she
4 believed the two of them to engage in sexual
5 intercourse.
6 Q And at the time, Jane Doe Number One was
7 17 and Jane Doe Number Two was 14?
8 A Yes.
9 Q All right.
10 A And I'm not sure if that was actually
11 the first or second visit that she went. So it
12 was either the first visit or the second that the
13 sexual activity that I described took place.
14 They may have gone there the first time
15 and just performed a massage for Mr. Epstein, but
16 on the second occasion the sexual activity that I
17 described took place.
18 Jane Doe Number Two stated that, you
19 know, the three years that we discussed from 2001
20 to 2004, she provided Mr. Epstein with over, in
21 that three-year period, over 100 massages and all
22 but three of the massages were sexually in nature.
23 Q How much was she paid for performing
24 sexual massages for Epstein?
25 A She was paid between 200 and $400.
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1 Originally, she was paid $300 when she starting
2 performing massages for Mr. Epstein. On at least
3 two occasions, Mr. Epstein offered her $100 more
4 if she would take off her underwear, which she
5 did, and on those two occasions she was paid
6 $400.
7 When Jane Doe Number Two expressed to
8 Mr. Epstein that she did not want him touching her
9 vagina, Jane Doe Number Two informed us that he
10 dropped the amount to $200.
11 She would also receive $100 for bringing
12 any girls.
13 Q All right. Now you said that on all but
14 three occasions with Jane Doe Number Two, the
15 massages were sexual. Did Jeffrey Epstein
16 masturbate during those massages?
17 A Yes, he did.
18 Q Did he instruct Jane Doe Number Two to
19 do anything while he was masturbating?
20 A Yes. He asked her to rub and pinch h
21 nipples.
22 Q And these started when she was still 14?
23 A Yes.
24 Q What was the involvement of Sarah Kellen
25 with Jane Doe Number Two?
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1 A Sarah would schedule Jane Doe Number Two
2 and sometimes Sarah would be out of town and be in
3 New York and scheduled her to come and work, but
4 Sarah Kellen's primary role was to schedule or I
5 guess she was the one that would schedule Jane Doe
6 Number Two to come and perform the massages.
7 Q Did Sarah Kellen ever actually lead Jane
8 Doe Number Two upstairs up to the bedroom?
9 A Yes. After Jane Doe Number One took
10 Jane Doe Number Two, Jane Doe Number Two started
11 going by herself. The first time that Jane Doe
12 Number Two arrived at Mr. Epstein's by herself,
13 Sarah Kellen took Jane Doe Number Two from the
14 kitchen and took her upstairs for the massage that
15 was to be performed for Mr. Epstein.
16 Q Now you mentioned the sexual activity
17 that Jane Doe Number two observed between Jane Doe
18 Number One and Mr. Epstein. Was there ever any
19 other females involved in the sexual activity?
20 A Yes. Mr. Epstein introduced an
21 unidentified female who performed oral sex on Jane
22 Doe Number One -- I'm sorry, on Jane Doe Number
23 Two while Mr. Epstein had sexual intercourse with
24 the unidentified female.
25 Q Now you mentioned that at some point,
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1 Mr. Epstein asked Jane Doe Number Two to start
2 bringing girls; is that correct?
3 A Yes.
4 Q And did he describe what exactly he
5 wants, the type of person that he wanted her to
6 bring? Did she report that he asked her if she
7 had any younger friends that would be interested
8 in performing massages?
9 A Yes. He asked her -- can I just have a
10 moment?
11 Q Of course, yes.
12 A I'm sorry. Jane Doe Number Two, Mr.
13 Epstein asked her if she had any friends that
14 would be interested in performing these massages
15 and then he also inquired if she had any younger
16 friends that would -- that she could bring to him
17 and then he offered to pay her $100 for each
18 person that she brought.
19 Q In addition to the sexual activity with
20 Mr. Epstein, did Sarah Kellen ever involve Jane
21 Doe Number Two in any specific activity?
22 A Yes. Sarah Kellen contacted Jane Doe
23 Number Two by telephone and asked her to come to
24 Mr. Epstein's residence that Mr. Epstein wanted
25 Sarah to take pictures of Jane Doe Number Two.
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1 Sarah paid Jane Doe Number Two $500 to
2 take naked photographs of Jane Doe Number Two at
3 Mr. Epstein's residence in and around the house
4 and pool area at the request of Mr. Epstein.
5 Q And approximately how old or how old
6 does Jane Doe Number Two believe she was at the
7 time?
8 A Jane Doe Number Two informed us that she
9 was 16 years old when Sarah Kellen took the
10 photographs of her naked.
11 Q What did Jane Doe Number Two say about
12 whether Jeffrey Epstein knew her true age?
13 A Jane Doe Number Two was informed by Jane
14 Doe Number One to say if asked her age that she
15 was -- she should respond that she was 17. When
16 they went -- and went to Mr. Epstein's residence
17 and were upstairs performing massages, Mr. Epstein
18 asked Jane Doe Number Two her age.
19 She responded four --. And then he
20 said, so you're 14? And Mr. Epstein informed Jane
21 Doe Number Two that they would just keep that
22 between them.
23 Q So in other words, he knew that she was
24 14 when she started seeing him?
25 A Yes. She did not remember to say 17 and
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1 just naturally came out four --. And then he
2 finished that statement for her, so you're 14?
3 And then stated that they would keep that between
4 them.
5 Q Now is the -- can you summarize -- does
6 .cover the evidence supporting the
your testimony.
7 allegations in Overt Acts One through 18?
8 A Yes, it does.
9 Q And if I could ask you to refer to Count
10 Two, which appears on Page 38. Is the evidence
11 that you have just summarized the basis for the
12 allegation that Jeffrey Epstein and Sarah Kellen
13 procured Jane Doe Number Two to engage in
14 commercial sex acts knowing that she was under 18?
15 A Yes.
16 Q So is there anything else that you
17 wanted to mention with respect to either Jane Doe
18 Numbers One or Two?
19 A The only other thing I didn't bring up
20 was the gifts that Mr. Epstein provided to Jane
21 Doe Number Two and Mr. Epstein would provide her
22 with lingerie.
23 He gave her tickets to a concert, a
24 local concert. He would also send her via FedEx
25 packages to her residence, and in one of those
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1 packages Jane Doe Number Two informed us that
2 there was a Massage for Dummies book that she
3 received by FedEx from Mr. Epstein.
4 And the grand jury should know that we
5 have received records from FedEx which corroborate
6 Mr. Epstein's address and packages going to Jane
7 Doe Number Two's residence.
8 Q And those records relate to Mr.
9 Epstein's personal Federal Express account?
10 A Yes.
11 A GRAND JUROR: Jane Doe Number Two, do
12 we know how old she was when Mr. Epstein
13 asked her to bring younger friends? Was she
14 already in his eyes up there and he wanted
15 them younger?
16 THE WITNESS: When Jane Doe Number Two
17 was 16, about midway through her 16th year,
18 she became pregnant and at that point she did
19 not provide Mr. Epstein with anymore
20 massages.
21 So I know she went away for a time
22 period and when she came back, you know, she
23 had a son and did not want to do massages
24 anymore. So at that point, she may have
25 brought her friends as well as prior to that.
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1 BY
2 Q Do you know exactly when she started
3 bringing other girls?
4 A I don't know that I want to say that it
5 was before or after. We just know that she was
6 asked by Mr. Epstein to bring other females and he
7 would pay $100.
8 The only other thing we haven't talked
9 about is we have message pads that were recovered
10 in the execution of the state search warrant on
11 Mr. Epstein's residence, and I think the grand
12 jury has seen copies of some of those message
13 pads.
14 We do have a message pad for Jane Doe
15 Number Two that gives you an example of -- and I
16 can pull that out and read that to the grand jury,
17 if you would like?
18 Q Sure.
19 A This particular message pad is
20 basically -- it's a carbon copy message that again
21 was recovered during the execution of the state
22 search warrant at Mr. Epstein's residence and this
23 shows that this was dated on March 11 , 2003.
24 It's from Carolyn with her phone number
25 and it's marked that she telephoned and it's
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1 marked, please call, and it was signed by one of
2 Mr. Epstein's employees. So again the date that
3 the contact here is March 11 , 2003.
4 Q And Jane Doe Number Two was still under
5 the age of 18 at that time?
6 A Yes, she was.
7 Q Okay. Now if we could turn to Jane Doe
8 Number Three and who is she?
9 A Jane Doe Number Three is a white female
10 named Cortney. She was born October 1987 and she
11 lived in the Palm Beach County area.
12 Q Has she been interviewed?
13 A Yes.
14 Q And during what period of time did Jane
15 Doe Number Three have contact with Jeffrey
16 Epstein?
17 A Beginning in or around 2003 to up 2005.
18 Q And how old was she during that time
19 frame?
20 A She was 15 when she first met Mr.
21 Epstein.
22 Q And how did she meet him?
23 A Jane Doe Number Two brought Jane Doe
24 Number Three to Mr. Epstein's house. They
25 traveled by taxi there. Jane Doe Number Two took
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1 Jane Doe Number. Three upstairs to meet Mr.
2 Epstein.
3 They provided Mr. Epstein a massage in
4 their underwear. Mr. Epstein asked Jane Doe
5 Number Two to leave and Jane Doe Number Three
6 finished the massage.
7 Mr. Epstein masturbated in front of Jane
8 Doe Number Three on that first occasion, and Jane
9 Doe Number Three, after the massage, she was paid
10 $200 and she left the residence.
11 Q All right.
12 A On other occasions after that, Sarah
13 Kellen would be the one to contact Jane Doe Number
14 Three to come to the residence to provide massages
15 for Mr. Epstein.
16 Q And you have phone records showing calls
17 from Sarah Kellen's phone to Jane Doe Number
18 Three's phone?
19 A Yes, I do.
20 Q In addition to that, the masturbation
21 during that massage, was there other sexual
22 activity that occurred between the two of them?
23 A Yes, there was. Mr. Epstein requested
24 that Jane Doe Number Three rub his chest and
25 nipples while he masturbated. He also used a
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1 massager slash vibrator on Jane Doe Number Three's
2 vagina.
3 He touched Jane Doe Number Three's
4 vagina. He also instructed Jane Doe Number Three
5 to straddle an unidentified female and fondle the
6 unidentified female as he used she believed it was
7 a vibrator or a massaging device on the
a unidentified female's vagina.
9 Q And on each of those occasions was she
10 paid?
11 A Yes, she was.
12 Q And did she tell you about the range of
13 of money that she would receive for each visit?
14 A She received $200 for the time period
15 when she would provide Mr. Epstein during the
16 massages.
17 Q Did Jane Doe Number Three recruit anyone
18 to go Mr. Epstein's house?
19 A Yes.
20 Q And did she tell you anything about what
21 Epstein's requests were in terms of who she should
22 bring?
23 A Yes. Mr. Epstein asked her to bring
24 other females. Jane Doe Number Three stated that
25 Mr. Epstein's preferences were short little white
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1 girls. Jane Doe Number Three brought girls ages
2 15 to 25 years of age.
3 Q Were there girls whom Jane Doe Number
4 Three brought to Mr. Epstein's home whom he did
5 not like?
6 A Yes. Mr. Epstein informed Jane Doe
7 Number Three that he didn't want girls with
8 tattoos, older girls, or black girls.
9 He also expressed frustration with Jane
10 Doe Number Three when she didn't have new females
11 for him.
12 Q And how would he express that
13 frustration?
14 A He hung up on her. He telephoned her.
15 He also would telephone her. Sarah Kellen and Mr.
16 Epstein would call Jane Doe Number Three and on
17 this particular occasion when she didn't have a
18 female for him, he hung up.
19 Q Now if we could go back to the girls
20 whom Mr. Epstein didn't like. You said older
21 girls, girls with tattoos, and black girls. When
22 Jane Doe Number Three brought those girls to his
23 home, did he allow them to massage him?
24 A No.
25 Q So those girls were just sent away?
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1 A They were, but they were paid for
2 coming.
3 Q Now if I could just refer you to Overt
4 Acts 29 and 31 , which are on Page 12. There is a
5 reference to two written telephone messages and
6 could you just remind the grand jury of where that
7 information comes from?
8 A I actually have copies. Overt Acts 29
9 and 31 are message pads or carbon copy messages
10 that were found at Mr. Epstein's residence when
1 1 the Town of Palm Beach Police Department executed
12 a state search warrant on his residence.
13 The first one, Overt Act 29, is a
14 message dated November 8, 2004. It was taken at
15 1 :15 p.m. The message is for Mr. Epstein from
16 Cortney with her cell phone number and in
17 quotations it says, I have a female for him. At
18 the bottom is an employee of Mr. Epstein, the
19 house manager, Alfredo Rodriguez.
20 Overt Act 31 is a message for Mr.
21 Epstein dated January 29, 2005. It looks like the
22 time was 4:10 p.m. It is from*Cortney with her
23. phone number on it and in quotations, I have a
24 female for him. Again, initialed by Mr. Epstein's
25 house manager, Alfredo Rodriguez.
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1 Q Now does your testimony today summarize
2 the evidence supporting the allegations in Overt
3 Acts 19 through 31?
4 A Yes.
5 Q And if I could just refer you to Count
6 12, which appears on Pages 40 and 41 of the
7 proposed indictment. Is this the evidence that
8 you just summarized the basis for the allegations
9 that Jeffrey Epstein and Sarah Kellen used a
10 facility of interstate commerce to persuade,
11 induce, and entice Jane Doe Number Three to engage
12 in prostitution and in sexual activity for which a
13 person can be charged with a criminal offense?
14 A Yes.
15 Q Was Jane Doe Number Three under the age
16 of 16 during part of her
2 SOUTHERN DISTRICT OF FLORIDA
3
4
5
6
UNITED STATES OF AMERICA,
Plaintiff, COPY
7 vs.
8 JEFFREY EPSTEIN, SARAH KELLEN,
ADRIANA ROSS, a/k/a Adriana Mucinska,
9 and NADIA MARCINKOVA,
10 Defendants.
11
12
13 TESTIMONY
14 OF
15 SPECIAL AGENT
16
17
18 Federal Grand Jury 07-103
Federal Building
19 U.S. Courthouse
West Palm Beach, Florida
20 Tuesday, March 18, 2008
21
22 APPEARANCES:
23
Assistant United States Attorney
24
25 Foreperson
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1 The sworn testimony of SPECIAL AGENT
2 I. was taken before the
3 Federal Grand Jury, West Palm Beach Division,
4 Federal Building, U.S. Courthouse, Palm Beach
5 County, State of Florida, on Tuesday, March 18,
6 2008.
7 , Certified Court
8 Reporter and Notary Public, State of Florida,
9 Official Reporting Service, LLC, 524 South Andrews
10 Avenue, Suite 302N, Fort Lauderdale, Florida,
11 33301 , was authorized to and did report the sworn
12 testimony.
13
14
15
16
17
18
19
20
21
22
23
24
25
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1 (Witness enters the Grand Jury Room.)
2 THE FOREPERSON: You do solemnly swear
3 that the testimony you give will be the
4 truth, the whole truth, and nothing but the
5 truth, so help you God?
6 THE WITNESS: I do.
7 THE FOREPERSON: Thank you. Please be
8 seated.
9 EXAMINATION
10 BY
11 Q Good afternoon, Special Agent
12 Would you just remind the grand jury
13 of your name and for whom you work?
14 A I am My official name is
15 and I work for the FBI here
16 in West Palm Beach.
17 Q All right. And you are still one of the
18 case agents on Operation Leap Year?
19 A Yes, I am.
20 Q Have additional subpoenas been issued on
21 behalf of this grand jury regarding Leap Year?
22 A Yes, they have.
23 Q And have documents been received in
24 response to those subpoenas?
25 A Yes, they have.
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1 Q What subpoenas were issued and what
2 items were received?
3 A The items that are received are in this
4 box for your review at a later time, but starting
5 with the first subpoena that we had received
6 documents back for would be from American Express.
7 The subpoena was issued and we received
8 credit card account information.
9 Q Okay.
10 A Do you want me just to --
11 Q You can just go through them.
12 A A subpoena was issued to J. Epstein
13 Virgin Island Foundation, Inc., J. Epstein and
14 Company, Epstein Interests, Financial Trust
15 Company, Inc., and we received documents on all
16 three of those except for -- all four of those
17 except for Jeffrey Epstein and Company --
18 J. Epstein and Company, which we received a letter
19 of no response.
20 The next subpoena was issued to the Palm
21 Beach County School Board and we received
22 transcript request forms. The next grand jury
23 subpoena was issued to Dan Tishler, Airport
24 Executive, Town Car Services. We received a
25 verbal that there were no records from Mr.
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1 Tishler.
2 We issued a grand jury subpoena to the
3 custodian of records for Majestic Theater, which
4 we received ticketing records for.
5 We issued a grand jury subpoena or you
6 issued a grand jury subpoena for the custodian of
7 records at the Broward Center for the Performing
8 Arts and we received ticketing records.
9 We issued a subpoena for the custodian
10 of records for the Kravis Center for the
11 Performing Arts and received a letter of no
12 records response.
13 We issued a subpoena for the custodian
14 of records for Live Nation Theatrical Broadway
15 Across America. Again, received a response letter
16 of no records.
17 We issued another subpoena for the
18 custodian of records from Live Nation Theatrical
19 Broadway Across America and that we did receive
20 some ticketing records.
21 We issued a subpoena to Bear Sterns and
22 Company, Inc., and we received personnel files and
23 account information. We issued a grand jury
24 subpoena for Wolf Camera and we received
25 transaction records.
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1 We have issued a grand jury subpoena to
2 Amazon.com and received order records. We issued
3 a grand jury subpoena to Federal Express and
4 received shipping records, and all that is
5 contained in this box.
6 Q All right.
7 And at the end of our
8 preservation, you will be welcome to look
9 through any of those records and we also will
10 bring them to the next session.
11 A GRAND JUROR: I have a question.
12 Yes.
13 A GRAND JUROR: We subpoenaed
14 information from theaters. I heard you say
15 ticketing information or records from a few
16 of them.
17 Did we subpoena that information to
18 establish location of the defendant or I
19 guess he's not a defendant yet?
20 THE WITNESS: Just as corroborating
21 evidence of testimony provided by the girls.
22 Their statements provided to us.
23 A GRAND JUROR: Okay.
24 BY
25 Q Okay. Special Agent , each
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1 member of the grand jury has before them a copy of
2 a chart. Do you also have a copy of this chart
3 entitled Revised Indictment Summary Chart
4 (by victim)?
5 A Yes.
6 Q And then you also provided to everyone a
7 list of Jane Does with photographs?
8 A Yes, I did.
9 Q Okay. Can you just explain to the grand
10 jury how -- which Jane Does we are going to be
11 talking about today?
12 A We are going to talk about Jane Does One
13 through Six and Nine and Ten, and what you have
14 here is a Jane Doe list of One through 19. We
15 will be going through the first Six and Nine and
16 Ten.
17 As you can see, if you look at these two
18 columns you'll see in the indictment we have
19 before you is going to have the new Jane Doe
20 numbers and the column to the right of that shows
21 you what their Jane Doe number used to be.
22 So Jane Does Nine and Ten, when we spoke
23 about those two before, and we will go through
24 that a little bit later, we referred to those as
25 Jane Does Six and Seven. From here on out, we
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1 will refer to them as Jane Does Nine and Ten.
2 A GRAND JUROR: I have a question about
3 Jane Doe Number One, and Amy pointed this
4 out. The date of birth is August 1983. The
5 range of activity dates is 1988 to 2003?
6 THE WITNESS: That's a typo. That
7 should be 1998.
8 Thank you for catching
9 that.
10 A GRAND JUROR: I was about ready to
11 have a problem here. I was having a real
12 problem. Yeah.
13 Okay. Thank you.
14 A GRAND JUROR: I was about to take the
15 law into my own hands.
16 THE WITNESS: Let there be noted on the
17 summary chart, there is a typo correction for
18 Jane Doe Number One. The range of activity
19 for her is 1998 to 2003.
20 This chart is a chart that we put
21 together because I have testified in the past
22 as well as you may have heard other testimony
23 regarding some of the Jane Does, and we are
24 going to be talking about them today and in a
25 later session.
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1 We want -- we provided this to you sort
2 of as an aid so that you can go back and
3 access the grand jury transcripts and go to
4 the date that the testimony was provided.
5 If you look at the last column where it
6 says, Grand Jury Transcript Pages, on this
7 form it will tell you the date of the grand
8 jury, who provided that testimony, and the
9 page number where you can find testimony
10 related to those specific Overt Acts and
11 substantive counts.
12 So the two columns next to that -- let's
13 just take Jane Doe Number Two and run through
14 that real quick. Jane Doe Number Two, we
15 have not testified about before. So that is
16 her number and will always remain her number.
17 Her date of birth is January of 1987.
18 The range of activity and that reflects the
19 range of activity that we have her connected
20 to Mr. Epstein and his assistants.
21 The next two columns are the Overt Acts
22 and the associated substantive counts. The
23 Overt Acts support those substantive counts
24 and again the last column you would at that
25 point go to my testimony on May 8th, 2007,
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1 and look on the transcript on Pages Six and
2 Seven, and that would be my testimony for the
3 Overt Acts, the supporting evidence and
4 testimony for Overt Acts One
5 through 18.
6 BY
7 Q But, Special Agent just so
8 that it is clear, when you testified back in May,
9 you weren't testifying specifically about Jane Doe
10 Number Two, but her name came up in with
11 respect to one of the other Jane Does?
12 A Exactly.
13 Q Okay. So any information related to
14 those Jane Does would be in the transcript pages?
15 A Yes.
16 Does that make sense to
17 everyone how we have organized that?
18 BY
19 Q Now Special Agent , if you
20 could look at the proposed indictment, and I'm
21 looking at the Background section of the
22 indictment specifically Paragraphs One through
23 Nine, which deal with Mr. Epstein's background and
24 who he employed.
25 Have you testified about that material.
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1 in the past?
2 A Yes, I have.
3 Q And let me just direct you to Overt Two,
4 which is at the top of Page Two. There is a
5 reference to L.G., and I don't believe we have
6 talked about L.G. before.
7 Can you tell the grand jury who that is?
8 A L.G. is Lesley Groff and she is a
9 personal assistant or an assistant for Mr. Epstein
10 in his New York office.
11 Q All right. And just for the court
12 reporter, Lesley is L-I-S-L-M-Y, and Groff is
13 G-R -O-F-F; is that correct?
14 A Yes, it is.
15 Q Then Paragraph Three talks about three
16 individuals, ., and . Can you tell
17 the grand jury who those persons are?
18 A is Tatum Miller. . is
19 is Anthony Figueroa.
20 Q And if you look at the summary chart on
21 the second page, there are columns for . and
22 Do you see those at the bottom of Page Two?
23 A Yes, I see them.
24 Q And those refer to Tatum Miller and
25 Anthony Figueroa where you have testified about
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1 them before or where III. was who
2 testified about them?
3 A Yes.
4 Q I know that you have testified about
5 Mr. Epstein's residence here in Palm Beach, but if
6 you could look at Paragraph Five of that
7 introductory section, which is on Page Two.
8 Are you -- can you provide the grand
9 jury with the location of Mr. Epstein's New York
10 residence?
11 A Mr. Epstein currently has a property
12 located at 9 East 71st Street, New York, New York.
13 Q If I could direct you to Page Five of
14 the proposed indictment in Paragraphs 18 through
15 25 of the introductory section.
16 Can you tell the grand jury about where
17 the various victims in this case attended high
18 school?
19 A I can. Starting with Paragraph 18.
20 Would you like me to just run through them?
21 Q Sure.
22 A Jane Doe Number Four attended Wellington
23 High School and Palm Beach Central High School.
24 Jane Doe Number Five attended Wellington High
25 School. Jane Doe Numbers Six, Eight, and 12,
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1 attended Palm Beach Central High School.
2 I should state that all of these high
3 schools are located in Palm Beach County. Jane
4 Doe Number Seven attended William T. Dwyer High
5 School in Palm Beach County.
6 Jane Doe Numbers Nine, 14, 15, 16, 17,
7 18, and 19 attended Royal Palm Beach High School
8 in Palm Beach County. Jane Doe Number Ten
9 attended Lake Worth High School in Palm Beach
10 County.
11 Jane Doe Number 11 attended the
12 Professional Performing Arts School, a public high
13 school located in the New York area; New York, New
14 York. Jane Doe Number 13 attended John I. Leonard
15 High School in Palm Beach County, and the Jane
16 Does attended these high schools during some point
17 of the contact with Mr. Epstein.
18 Q Now Special Agent , I know
19 that not each and everyone of the Jane Does is
20 listed in this. Did some of the Jane Does leave
21 school before they began their relationship with
22 Mr. Epstein?
23 A Yes, they did.
24 Q Now everyone was handed a copy of a
25 document entitled, Merged Flight Manifests. If I
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1 could ask you to take a look at that, and in the
2 proposed indictment if you could turn to Page 32.
3 Special Agent , I'm going to
4 ask you about Overt Acts 191 through 225. Can
5 you tell the grand jury what the basis is for the
6 allegations set forth in 191 through 225?
7 A We received through the issuance of a
8 grand jury subpoena the flight manifest from Mr.
9 Epstein's pilot and that is our evidence to show
10 the travel that Mr. Epstein did, which is
11 displayed in Overt Acts 191 through 225.
12 Q And the chart that is entitled Merged
13 Flight Manifests, what does that include?
14 A This chart will show the grand jury that
15 in January 2004 through -- basically, Mr.
16 Epstein's travel in '04 and '05 on his two
17 personal aircrafts, which would be the Boeing 727
18 and the*Gulfstream.
19 If you look at this chart, the first
20 column is the date of departure, the date that he
21 left, and you'll see airport codes in the next
22 column that tells you the airport that he left and
23 what time he left would be the next time, the
24 departure time.
25 It will tell you what airport he was
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1 arriving in and what time he arrived at that
2 airport, and the last would be the actual
3 aircraft itself, which aircraft he was traveling
4 on, and just to remind the grand jury, Hyperion
5 is the Gulfstream and JEGE is the Boeing 727.
6 Q And who created this chart, the Merged
7 Flight Manifests Chart?
8 A The FBI.
9 Q And where did they gather this
10 information from?
11 A We subpoenaed or the grand jury issued a
12 subpoena to the pilot and pilots of Mr. Epstein
13 and through counsel the pilots gave us a copy of
14. the flight manifest for those two years and I have
15 here a set of the flight manifests that were
16 provided to us by the grand jury subpoena and have
17 marked each of the Overt Acts from 191 to 225.
18 So that if any time the grand jury would
19 like to come and look at the actual manifest the
20 pilots gave us, you'll be able to see the data
21 that this form was taken from.
22 Q Okay. Thank you.
23 : Before I go on, does
24 anyone have any questions about those Overt
25 Acts and where this information came from?
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1 Yes, sir.
2 A GRAND JUROR: Is there something that
3 ties in these travel itineraries to the
4 actual fact that there was a meeting or
5 something planned? I mean, where does that
6 tie together? Traveling is not against the
7 law.
8 Right. The way that we
9 had the indictment organized before was an
10 attempt to do this in chronological order,
11 which seems to be more confusing rather than
12 less confusing.
13 So when you look at the -- when you hear
14 the testimony from Special Agent
15 and when you look at the Overt Acts related
16 to the victims and when he went to see them,
17 you'll see that the dates of travel relate to
18 the dates of his meeting with the victims.
19 Does that make sense?
20 A GRAND JUROR: Yes.
21 BY
22 Q Is there anything else, Special Agent
23 , that I should add to that?
24 A No. It will become clear once we
25 testify about the travel count.
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1 A GRAND JUROR: Can I just ask which
2 airport is ISM?
3 THE WITNESS: You know, I can in the
4 next session, I would be happy to bring the
5 airport codes.
6 A GRAND JUROR: Okay.
7 THE WITNESS: Obviously, we focused in
8 on his times when he traveled into the Palm
9 Beach County area and that would be PBIA Ol
10 PBI, but I can certainly provide all the
11 airport codes at our next session.
12 BY
13 Q All right. Now throughout the Overt
14 Acts portion where there are discussions of
15 various Jane Does, there will be mentioned a
16 telephone call.
17 So, for example, if you look at Page
18 Ten, Paragraph 17, it says on or about April 23rd,
19 2004, Defendant .Sarah Kellen placed a telephone
20 call to a telephone used by Jane Doe Number Two.
21 Do you see that?
22 A Yes.
23 Q And Special Agent , what is
24 the evidence that we have related to the telephone
25 calls that are mentioned in the Overt Acts?
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1 A We have issued administrative subpoenas
2 to telecommunication companies for cell phone
3 records for Mr. Epstein's assistants as well as
4 many of the Jane Does.
5 These specific Overt Acts are reflected
6 in those telephone records and we have also
7 prepared for the grand jury -- I brought with me
8 today, and I will bring with me next time, all of
9 the telephone records for -- that we have received
10 via administrative subpoenas.
11 Today I brought the ones pertaining to
12 the Overt Acts and what we have done is we have
13 taken those cell phone records and we have marked
14 for the grand jury all the Overt Acts that are
15 listed in the indictment.
16 You'll note when you go to that page,
17 there will be a little mark by the telephone call
18 that we are specifically talking about in the
19 Overt Acts.
20 Q And can ydu just remind the grand jury
21 what information will be on those records?
22 A It will be telephonic contact between
23 Sarah Kellen, Nadia Marcinkova, Adriana Ross or
24 Mucinska, telephonic contact between his
25 assistants and the Jane Does.
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1 Q It will show the telephone number that
2 was called and the dates and time and length of
3 the call?
4 A Yes, it will.
5 Q All right.
6 Any questions before we
7 start talking about the sexual activity
8 between the defendant and the victims? Okay.
9 No questions.
10 BY
11 Q Let's talk first about Jane Does One and
12 Two. They are grouped together in Overt Acts One
13 through 18. Who is Jane Doe Number One?
14 A Jane Doe Number One is a white female.
15 Her name is Virginia. She was born in August of
16 1983 and she lived in the Palm Beach County area
17 during the time that she had contact with Mr.
18 Epstein.
19 Q Has she been interviewed?
20 A Statements have been provided to the FBI
21 by Jane Doe Number One.
22 Q In addition to her statements, who else
23 has provided information regarding Jane Doe Number
24 One?
25 A Jane Doe Number Two and Jane Doe Number
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1 One's boyfriend at the time she had contact with
2 Mr. Epstein, which is Anthony Figueroa.
3 Q Who is referred to as in the
4 indictment?
5 A Yes.
6 Q During what period of time, did Jane Doe
7 Number One have contact with Mr. Epstein?
8 A Jane Doe Number One met Mr. Epstein when
9 she was 15. So that would be in the last half of
10 1998 until 2003 that we are aware of.
11 Q How did she meet Jeffrey Epstein?
12 A She met Mr. Epstein at age 15 and
13 according to her boyfriend when she was 20, Mr.
14 Epstein sent her to Thailand for massage therapy
15 school.
16 So she -- the time frame that she was
17 with Mr. Epstein was from the age of 15 until we
18 are aware of is age 20. Anthony Figueroa never
19 saw Jane Doe Number One again after she went to
20 Thailand.
21 She would contact him by telephone, but
22 she never returned back. He stated he inherited
23 her dog. She never came back that he is aware of.
24 So the time frame that we had Jane Doe Number One
25 with Mr. Epstein is from age 15 to 20.
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1 I'm sorry, the question you asked me
2 was: How did they meet? They met by a friend of
3 Mr. Epstein's. Jane Doe Number One was working at
4 Mar-a-Lago and a friend of Mr. Epstein's,
5 Ghislaine Maxwell.
6 Would you like the spelling?
7 THE REPORTER: Yes, please.
8 THE WITNESS: G-H-I-S-L-A-I-N -I,
9 Maxwell, who was a friend of Mr. Epstein, met
10 Jane Doe Number One at Mar-a-Lago and Jane
11 Doe Number One soon after began working and
12 providing massages for Mr. Epstein.
13 BY
14 Q What sexual activity was Jane Doe Number
15 One involved in with Jeffrey Epstein?
16 A Through the statements provided by Jane
17 Doe Number Two, when Jane Doe Number Two was 14
18 years of age, she saw Jane Doe Number One naked
19 and engaged in what she believed to be sexual
20 intercourse with Mr. Epstein.
21 Q Now did Jane Doe Number One recruit any
22 one else to go to Jeffrey Epstein's home?
23 A At this time, the only Jane Doe that we
24 are aware of is Jane Doe Number Two or the only
25 individual we are aware of is Jane Doe Number Two.
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1 Q Okay. So let's talk about Jane Doe
2 Number Two. Who is she?
3 A Jane Doe Number Two is a white feinale
4 named Carolyn. She was born in January of 1987.
5 She lived in Palm Beach County, Florida, at the
6 time she had contact with Mr. Epstein.
7 Q And how -- has she been interviewed?
8 A Yes.
9 Q During -- how old was she during the
10 time frame that Jane Doe Number Two was involved
11 with Mr. Epstein?
12 A She was 14 at the time that she first
13 met Mr. Epstein.
14 Q And she was involved with him until she
15 was 17?
16 A We have in or about the beginning of
17 2001, which would make her 14 up until 2004.
18 Q And how did she come to meet Mr.
19 Epstein?
20 A Jane Doe Number One brought Jane Doe
21 Number Two to Mr. Epstein's residence for the
22 first time. Mr. Epstein was introduced to Jane
23 Doe Number Two by Jane Doe Number One.
24 There was a massage that took place with
25 the two of them and then Jane Doe Number One
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1 engaged in sexual activity that I mentioned
2 earlier where Jane Doe Number Two informed us that
3 she sat on the couch and observed what she
4 believed the two of them to engage in sexual
5 intercourse.
6 Q And at the time, Jane Doe Number One was
7 17 and Jane Doe Number Two was 14?
8 A Yes.
9 Q All right.
10 A And I'm not sure if that was actually
11 the first or second visit that she went. So it
12 was either the first visit or the second that the
13 sexual activity that I described took place.
14 They may have gone there the first time
15 and just performed a massage for Mr. Epstein, but
16 on the second occasion the sexual activity that I
17 described took place.
18 Jane Doe Number Two stated that, you
19 know, the three years that we discussed from 2001
20 to 2004, she provided Mr. Epstein with over, in
21 that three-year period, over 100 massages and all
22 but three of the massages were sexually in nature.
23 Q How much was she paid for performing
24 sexual massages for Epstein?
25 A She was paid between 200 and $400.
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1 Originally, she was paid $300 when she starting
2 performing massages for Mr. Epstein. On at least
3 two occasions, Mr. Epstein offered her $100 more
4 if she would take off her underwear, which she
5 did, and on those two occasions she was paid
6 $400.
7 When Jane Doe Number Two expressed to
8 Mr. Epstein that she did not want him touching her
9 vagina, Jane Doe Number Two informed us that he
10 dropped the amount to $200.
11 She would also receive $100 for bringing
12 any girls.
13 Q All right. Now you said that on all but
14 three occasions with Jane Doe Number Two, the
15 massages were sexual. Did Jeffrey Epstein
16 masturbate during those massages?
17 A Yes, he did.
18 Q Did he instruct Jane Doe Number Two to
19 do anything while he was masturbating?
20 A Yes. He asked her to rub and pinch h
21 nipples.
22 Q And these started when she was still 14?
23 A Yes.
24 Q What was the involvement of Sarah Kellen
25 with Jane Doe Number Two?
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1 A Sarah would schedule Jane Doe Number Two
2 and sometimes Sarah would be out of town and be in
3 New York and scheduled her to come and work, but
4 Sarah Kellen's primary role was to schedule or I
5 guess she was the one that would schedule Jane Doe
6 Number Two to come and perform the massages.
7 Q Did Sarah Kellen ever actually lead Jane
8 Doe Number Two upstairs up to the bedroom?
9 A Yes. After Jane Doe Number One took
10 Jane Doe Number Two, Jane Doe Number Two started
11 going by herself. The first time that Jane Doe
12 Number Two arrived at Mr. Epstein's by herself,
13 Sarah Kellen took Jane Doe Number Two from the
14 kitchen and took her upstairs for the massage that
15 was to be performed for Mr. Epstein.
16 Q Now you mentioned the sexual activity
17 that Jane Doe Number two observed between Jane Doe
18 Number One and Mr. Epstein. Was there ever any
19 other females involved in the sexual activity?
20 A Yes. Mr. Epstein introduced an
21 unidentified female who performed oral sex on Jane
22 Doe Number One -- I'm sorry, on Jane Doe Number
23 Two while Mr. Epstein had sexual intercourse with
24 the unidentified female.
25 Q Now you mentioned that at some point,
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1 Mr. Epstein asked Jane Doe Number Two to start
2 bringing girls; is that correct?
3 A Yes.
4 Q And did he describe what exactly he
5 wants, the type of person that he wanted her to
6 bring? Did she report that he asked her if she
7 had any younger friends that would be interested
8 in performing massages?
9 A Yes. He asked her -- can I just have a
10 moment?
11 Q Of course, yes.
12 A I'm sorry. Jane Doe Number Two, Mr.
13 Epstein asked her if she had any friends that
14 would be interested in performing these massages
15 and then he also inquired if she had any younger
16 friends that would -- that she could bring to him
17 and then he offered to pay her $100 for each
18 person that she brought.
19 Q In addition to the sexual activity with
20 Mr. Epstein, did Sarah Kellen ever involve Jane
21 Doe Number Two in any specific activity?
22 A Yes. Sarah Kellen contacted Jane Doe
23 Number Two by telephone and asked her to come to
24 Mr. Epstein's residence that Mr. Epstein wanted
25 Sarah to take pictures of Jane Doe Number Two.
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1 Sarah paid Jane Doe Number Two $500 to
2 take naked photographs of Jane Doe Number Two at
3 Mr. Epstein's residence in and around the house
4 and pool area at the request of Mr. Epstein.
5 Q And approximately how old or how old
6 does Jane Doe Number Two believe she was at the
7 time?
8 A Jane Doe Number Two informed us that she
9 was 16 years old when Sarah Kellen took the
10 photographs of her naked.
11 Q What did Jane Doe Number Two say about
12 whether Jeffrey Epstein knew her true age?
13 A Jane Doe Number Two was informed by Jane
14 Doe Number One to say if asked her age that she
15 was -- she should respond that she was 17. When
16 they went -- and went to Mr. Epstein's residence
17 and were upstairs performing massages, Mr. Epstein
18 asked Jane Doe Number Two her age.
19 She responded four --. And then he
20 said, so you're 14? And Mr. Epstein informed Jane
21 Doe Number Two that they would just keep that
22 between them.
23 Q So in other words, he knew that she was
24 14 when she started seeing him?
25 A Yes. She did not remember to say 17 and
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1 just naturally came out four --. And then he
2 finished that statement for her, so you're 14?
3 And then stated that they would keep that between
4 them.
5 Q Now is the -- can you summarize -- does
6 .cover the evidence supporting the
your testimony.
7 allegations in Overt Acts One through 18?
8 A Yes, it does.
9 Q And if I could ask you to refer to Count
10 Two, which appears on Page 38. Is the evidence
11 that you have just summarized the basis for the
12 allegation that Jeffrey Epstein and Sarah Kellen
13 procured Jane Doe Number Two to engage in
14 commercial sex acts knowing that she was under 18?
15 A Yes.
16 Q So is there anything else that you
17 wanted to mention with respect to either Jane Doe
18 Numbers One or Two?
19 A The only other thing I didn't bring up
20 was the gifts that Mr. Epstein provided to Jane
21 Doe Number Two and Mr. Epstein would provide her
22 with lingerie.
23 He gave her tickets to a concert, a
24 local concert. He would also send her via FedEx
25 packages to her residence, and in one of those
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1 packages Jane Doe Number Two informed us that
2 there was a Massage for Dummies book that she
3 received by FedEx from Mr. Epstein.
4 And the grand jury should know that we
5 have received records from FedEx which corroborate
6 Mr. Epstein's address and packages going to Jane
7 Doe Number Two's residence.
8 Q And those records relate to Mr.
9 Epstein's personal Federal Express account?
10 A Yes.
11 A GRAND JUROR: Jane Doe Number Two, do
12 we know how old she was when Mr. Epstein
13 asked her to bring younger friends? Was she
14 already in his eyes up there and he wanted
15 them younger?
16 THE WITNESS: When Jane Doe Number Two
17 was 16, about midway through her 16th year,
18 she became pregnant and at that point she did
19 not provide Mr. Epstein with anymore
20 massages.
21 So I know she went away for a time
22 period and when she came back, you know, she
23 had a son and did not want to do massages
24 anymore. So at that point, she may have
25 brought her friends as well as prior to that.
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1 BY
2 Q Do you know exactly when she started
3 bringing other girls?
4 A I don't know that I want to say that it
5 was before or after. We just know that she was
6 asked by Mr. Epstein to bring other females and he
7 would pay $100.
8 The only other thing we haven't talked
9 about is we have message pads that were recovered
10 in the execution of the state search warrant on
11 Mr. Epstein's residence, and I think the grand
12 jury has seen copies of some of those message
13 pads.
14 We do have a message pad for Jane Doe
15 Number Two that gives you an example of -- and I
16 can pull that out and read that to the grand jury,
17 if you would like?
18 Q Sure.
19 A This particular message pad is
20 basically -- it's a carbon copy message that again
21 was recovered during the execution of the state
22 search warrant at Mr. Epstein's residence and this
23 shows that this was dated on March 11 , 2003.
24 It's from Carolyn with her phone number
25 and it's marked that she telephoned and it's
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1 marked, please call, and it was signed by one of
2 Mr. Epstein's employees. So again the date that
3 the contact here is March 11 , 2003.
4 Q And Jane Doe Number Two was still under
5 the age of 18 at that time?
6 A Yes, she was.
7 Q Okay. Now if we could turn to Jane Doe
8 Number Three and who is she?
9 A Jane Doe Number Three is a white female
10 named Cortney. She was born October 1987 and she
11 lived in the Palm Beach County area.
12 Q Has she been interviewed?
13 A Yes.
14 Q And during what period of time did Jane
15 Doe Number Three have contact with Jeffrey
16 Epstein?
17 A Beginning in or around 2003 to up 2005.
18 Q And how old was she during that time
19 frame?
20 A She was 15 when she first met Mr.
21 Epstein.
22 Q And how did she meet him?
23 A Jane Doe Number Two brought Jane Doe
24 Number Three to Mr. Epstein's house. They
25 traveled by taxi there. Jane Doe Number Two took
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1 Jane Doe Number. Three upstairs to meet Mr.
2 Epstein.
3 They provided Mr. Epstein a massage in
4 their underwear. Mr. Epstein asked Jane Doe
5 Number Two to leave and Jane Doe Number Three
6 finished the massage.
7 Mr. Epstein masturbated in front of Jane
8 Doe Number Three on that first occasion, and Jane
9 Doe Number Three, after the massage, she was paid
10 $200 and she left the residence.
11 Q All right.
12 A On other occasions after that, Sarah
13 Kellen would be the one to contact Jane Doe Number
14 Three to come to the residence to provide massages
15 for Mr. Epstein.
16 Q And you have phone records showing calls
17 from Sarah Kellen's phone to Jane Doe Number
18 Three's phone?
19 A Yes, I do.
20 Q In addition to that, the masturbation
21 during that massage, was there other sexual
22 activity that occurred between the two of them?
23 A Yes, there was. Mr. Epstein requested
24 that Jane Doe Number Three rub his chest and
25 nipples while he masturbated. He also used a
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1 massager slash vibrator on Jane Doe Number Three's
2 vagina.
3 He touched Jane Doe Number Three's
4 vagina. He also instructed Jane Doe Number Three
5 to straddle an unidentified female and fondle the
6 unidentified female as he used she believed it was
7 a vibrator or a massaging device on the
a unidentified female's vagina.
9 Q And on each of those occasions was she
10 paid?
11 A Yes, she was.
12 Q And did she tell you about the range of
13 of money that she would receive for each visit?
14 A She received $200 for the time period
15 when she would provide Mr. Epstein during the
16 massages.
17 Q Did Jane Doe Number Three recruit anyone
18 to go Mr. Epstein's house?
19 A Yes.
20 Q And did she tell you anything about what
21 Epstein's requests were in terms of who she should
22 bring?
23 A Yes. Mr. Epstein asked her to bring
24 other females. Jane Doe Number Three stated that
25 Mr. Epstein's preferences were short little white
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1 girls. Jane Doe Number Three brought girls ages
2 15 to 25 years of age.
3 Q Were there girls whom Jane Doe Number
4 Three brought to Mr. Epstein's home whom he did
5 not like?
6 A Yes. Mr. Epstein informed Jane Doe
7 Number Three that he didn't want girls with
8 tattoos, older girls, or black girls.
9 He also expressed frustration with Jane
10 Doe Number Three when she didn't have new females
11 for him.
12 Q And how would he express that
13 frustration?
14 A He hung up on her. He telephoned her.
15 He also would telephone her. Sarah Kellen and Mr.
16 Epstein would call Jane Doe Number Three and on
17 this particular occasion when she didn't have a
18 female for him, he hung up.
19 Q Now if we could go back to the girls
20 whom Mr. Epstein didn't like. You said older
21 girls, girls with tattoos, and black girls. When
22 Jane Doe Number Three brought those girls to his
23 home, did he allow them to massage him?
24 A No.
25 Q So those girls were just sent away?
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1 A They were, but they were paid for
2 coming.
3 Q Now if I could just refer you to Overt
4 Acts 29 and 31 , which are on Page 12. There is a
5 reference to two written telephone messages and
6 could you just remind the grand jury of where that
7 information comes from?
8 A I actually have copies. Overt Acts 29
9 and 31 are message pads or carbon copy messages
10 that were found at Mr. Epstein's residence when
1 1 the Town of Palm Beach Police Department executed
12 a state search warrant on his residence.
13 The first one, Overt Act 29, is a
14 message dated November 8, 2004. It was taken at
15 1 :15 p.m. The message is for Mr. Epstein from
16 Cortney with her cell phone number and in
17 quotations it says, I have a female for him. At
18 the bottom is an employee of Mr. Epstein, the
19 house manager, Alfredo Rodriguez.
20 Overt Act 31 is a message for Mr.
21 Epstein dated January 29, 2005. It looks like the
22 time was 4:10 p.m. It is from*Cortney with her
23. phone number on it and in quotations, I have a
24 female for him. Again, initialed by Mr. Epstein's
25 house manager, Alfredo Rodriguez.
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1 Q Now does your testimony today summarize
2 the evidence supporting the allegations in Overt
3 Acts 19 through 31?
4 A Yes.
5 Q And if I could just refer you to Count
6 12, which appears on Pages 40 and 41 of the
7 proposed indictment. Is this the evidence that
8 you just summarized the basis for the allegations
9 that Jeffrey Epstein and Sarah Kellen used a
10 facility of interstate commerce to persuade,
11 induce, and entice Jane Doe Number Three to engage
12 in prostitution and in sexual activity for which a
13 person can be charged with a criminal offense?
14 A Yes.
15 Q Was Jane Doe Number Three under the age
16 of 16 during part of her