EFTA01108807.pdf
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO:502008CA028051XXXXMB AB
Plaintiff,
- vs- VOLUME III OF IV
JEFFREY EPSTEIN
AND
Defendants.
VIDEO-CONFERENCED VIDEOTAPED DEPOSITION OFIIII.
Tuesday, February 09, 2010
10:09 - 5:05 p.m.
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1296
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1 APPEARANCES: 1 PROCEEDINGS
2 On beJulf ofthe Plaintiff lig! and Jane Dot 2
3 BRAD J. EDWARDS,
FARMER, JAFFE, WEISSItla EDWARDS 3 THE VIDEOGRAPHER: This is the 9th day of
4 4 February, 2010. The dine is approximately
5 10imIty.m. This is the videotaped deposition
6 OM. in the matter of M. versus Epstein.
I 7 This deposition is being held at 250 South
On of tbe Jeffrey Epstein:
ROBERT D. CROTON, JR., ESQUIRE 8 Australian Avenue, West Palm Beach, Florida.
MARK T. LUTHER. ESQUIRE 9 My name is Daniel Downey, I am the
9 LUITIER ea COLEMAN, LLP
10 videographer representing Visual Evidence,
11 Incorporated. Will the attorneys please
12 announce their appearances for the record.
•2 On bed o • • licfrroYEPslele: 13 MR. EDWARDS: Brad Edwards on behalf of
.3 JACK ALAN GOLDBERGER, ESQUIRE 14
ER Fe WEISS. PA
14 15 MR. LUTTLER: Mark Luttier with the firm
16 of Burman, Critton, Luther & Coleman on behalf
17 of Mr. Epstein.
16 18 MR. CRITMN: Bob Critton on behalf of
17 19 Mr. Epstein.
18 ALSO PRESENT: kffrey Epstein, via video conference
Daniel Downey, Videograplicr 20 Thereupon,
19 Visual Evidence, Incorporated 21
20 22 Having been first duly sworn or affirmed, was
21
22 23 examined and testified as follows:
23 24 THE WITNESS: I do.
24
25 25
Page 338 Page 340
1 1 DIRECT EXAMINATION
2 2 BY MR. LLTIT1ER:
3 INDEX VOLUME I 3 Q. Good morning, Ms... We're here for the
4 4 continuation of your deposition that was started on
5 5 September 24th, 2009. Do you understand that you're
6 WITNESS: DIRECT CROSS REDIRECT RECROSS 6 still under oath today?
7 7 A. Yes, sir.
8 BY MR. LUTHER 4 8 Q. Have you had an opportunity to reviewa
9 9 transcript of that portion of your deposition which
10 10 has been completed thus far?
11. 11 A. Yes, sir.
12 NO EXHIBITS MARKED 12 Q. Have you reviewed the full transcript?
13 13 A. Yes, sir.
14 14 Q. And were there any corrections in your
15 15 testimony?
16 16 A. Were there any corrections in my testimony?
17 17 Q. In other words, when you read it did you
18 18 see anything that was incorrect?
19 19 A. No, sir.
20 20 Q. Do you recall whether or not you silted
21 21 the transcript indicating that all of it was
22 22 accurate?
23 23 A. I signed, yes.
24 24 Q Do you know if the original got sent
25 25 anywhere or do you stil I have it or dicliou just
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1 give it to your lawyer? 1 shown to third parties and they had been asked
2 A. I gave it to my attorney. 2 whether or not they wanted to purchase an interest
3 Q. And you signed it without any corrections? 3 in your lawsuit?
4 A. Yes, sir. 4 A. No.
5 Q. Have you ever been to Mr. Edwards' former 5 Q. No one had called you and advised you that
6 law firm's office in Fort Lauderdale? That would be 6 your files were being shown to anybody?
7 the firm of Rothstein, Rosenfeldt & Adler. 7 A. No.
8 A. What is this address? Is this address on 8 Q. Have you had any discussions with anyone
9 Andrews? 9 about that issue?
10 Q. 10 A. No.
1/ A. No. 11 Q. And when I say anyone I mean
12 Q. Have you ever been to a law firm where 12 representative of the Florida Bar Association; have
13 Mr. Edwards was practicing while he's been 13 you had any discussions with anybody from the
14 representing you where there are other lawyers 14 Florida Bar?
15 besides himself present? 15 A. No, sir.
16 A. No. 16 Q. Any discussions with anybody from the FBI
17 Q. Does the name Rothstein ring a bell to 17 about that specific issue?
18 you? Do you know who that is? 18 A. About what issue, about getting —
19 A. No. 19 . Q. About someone attempting to purchase an
20 Q. Do -- have you ever met with anyone else 20 interest in your lawsuit.
21 other than your lawyer with respect to the merits of 21 A. No.
22 this lawsuit and whether or not you believed you 22 Q. Anyone from the State Attorney's office?
23 were likely to recover money in this case? 23 A. No.
24 A. No. 24 Q. Okay. Prior to coming here today, have
25 Q. Has anyone ever approached you arid -- 25 you had an opportunity to review a transcript of a
Page 342 Page 344
1 other than your lawyer -- and discussed with you the 1 hearing that was held before the court on
2 merits of this case or whether or not you believed 2 November 3rd, 2009, upon your motion to terminate
3 you were likely to recover money? 3 the continuation of this deposition?
4 A. No. 4 A. Excuse me?
Q. Have you been advised that — or let me 5 Q. Prior to coming here today have you been
6 strike that. Have you been provided any information 6 provided an opportunity to review a transcript of a
7 that your case and the information contained in it 7 hearing that was held before the court on
8 was made available to third parties to review to 8 November 3rd, 2009, on your motion to limit this
9 determine whether or not they wanted to purchase an 9 deposition?
10 interest in the outcome of your case? 10 A. I'm not understanding this.
11 A. No. 11 Q. You know what a transcript is, don't you?
12 Q. Have you, prior to me just asking you that 12 A. A transcript, yes.
13 • question, did you know that that had occurred? 13 Q. This would have been a transcript or
14 MR. EDWARDS: Object to the fonn. 14 written record of a court hearing that we had in
15 THE WITNESS: Excuse me? 15 case on November 3rd, 2009, that concerned the
16 MR. EDWARDS: I objected to the form of 16 conducting of this deposition. Have you seen any
17 the question. It assumes that it did occur. 17 such transcript?
18 BY MR. LUITIER: 18 A. A transcript of what?
19 Q. Before I asked you that question, did you 19 Q. Of that court hearing.
20 know that that had occurred. 20 A. Of what court hearing?
21 A. Sr, I'm not really understanding what you're 21 Q. The one that was held on November 3rd,
22 saying. 22 2009.
23 Q. All right. Let me repeat it. 23 A. That we recently just did, my last deposition?
24 . A. Okay. 24 Q. No. The, the hearing was held on
25 Q. Did you know that your case tiles had been 25 November 3rd, 2009. The subject matter of the
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1 hearing was a motion that was filed by your lawyer 1 was 13 years old. And on that note, he took it from
2 to limit the continuation of this deposition. 2 there to just comfort me through the, through the pain
.3 A. Yes. I knew that we were going to have 3 that I was going through and that I have been going
4 another deposition. 4 through.
5 • Have you seen the transcript of that 5 Q. Did any of these discussions concern
6 hearing wherein the judge gave some specific 6. anything else?
7 direction to you and your conduct in the 7 A. No, sir.
8 continuation of this — 8 Q Have you, since your deposition on
9 A. Yes. September 24th, 2009, had any type of contact with
10 Q. deposition? 10 anyone else who has filed asuit against
11. A. Yes. 11 Mr. Epstein?
12 Q. Okay. So you're aware of that? 12 A. Yes.
13 A. Yes. 13 Q. M.Who have you had contact with?
14 Q. Okay. Are you still living at the same 14 A
15 address that you gave me at the last deposition? 15 Q. Anyone else?
16 A. Yes, sir. 16 A. No, sir.
17 Q. Who else is living with you there now? 17 Q. And when I, I use the word contact, by
18 A. My son. 18 that I mean could be face-to-face contact, could be
19 Q. Anyone else? 19 a conversation, could be some sort of computer,
20 A. No, sir. 20 computer message, a text, Twitter, e-mail, any kind
21 Q. Has anyone else lived with you at that 21 of commuter — anything like that, could it be, it
22 address since your deposition on September 24th, 22 could be something in writing. Do you understand
23 2009, other than your son? 23 that's What I mean by communication?
24 A. No, sir. Since November, actually, Thomas 24 A. Yes, sir.
25 Souder, he had moved, he lived with me until 25 Q. And so the only person since September
Page 346 Page 348
January 1st, 2010. 1 24th, 2009,. that. yo_u had any contact with that has a
2 Q. And am I correct told us at your 2 suit pending against Mr. Epstein is E.?
3 last deposition that was then your 3 A. Yes, sir.
4 current boyfriend? 4 MR. CRITION: No, Mr
5 A. Yes. 5 THE WITNESS: No.
6 Q. Has that relationship changed now? •6 MR. CRITTON: What.did she say?
7 A. Yes. 7 THE WITNESS:
,8 Q. He is no longer your current boyfriend? 8 MR. LUU1ER:
A. Correct 9 MR. CRITTON: Oh,
10 Q. Is the apartment that you currently live 10 MR. LUTIIER: Yeah.
11 in, is that a rental apartment? 11 MR. CRITTON: Okay.
12 A. Yes. 12 MR. LUITIER: And when did you
13 Q. Is that rental apartment in your name? 13 MR. EDWARD: Fm sorry. Does she need to
14 A. Yes. 14 put her microphone on?
15 Q. Bite was the situation that caused 15 VIDEOGRAPHER: I can pick her up.
16 you and to part company? 16 MR. EDWARD: You can pick — Okay.
17 A. It was mutual. 17 THE VIDEOGRAPHER: That's fine.
18 Q. Was there any domestic violence involved? 18 MR. LUTT1ER: That would be a good idea.
19 A. No, sir. 19 MR. EDWARDS: Let's make sure we're
20 O• Did you have any discussions with 20 actually getting all of this.
21 at any time about this lawsuit? 21 MR. LUTTIEFt: Start over.
22 A. Yes. 22 MR. EDWARD: We don't need that.
23 Q. What discussions did you have? 23 BY MR. LUTTEER:
24 A. Well, he's saw the news and I pretty much told 24 Q. And when did you have communication with
25 him that Jeffrey F nCt in has been mol ting MP since I 25 Ms. Lan cry?
r.! ,
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1 A. We are awriates. We're friends. When did I 1 and we can confine (sic) in each other if anything. But
2 have a conversation with ha? 2 as in confining, I mean all I have to do is look in her
3 Q. Yes. Well, I don't want to limit it to a 3 eyes and'we just know the pain that we've went through.
4 conversation. When did you have communication with 4 Q. Am I going to assume correctly that the
her? 5 word you mean is confide, you confide in each other?
A. I have communication with her frequently but 6 You tell each other -
7 we don't talk about the Jeffrey Epstein case. My 7 A. No, I told you, as when I confine in her, it's
8 attorney is not her attorney. We don't choose to talk 8 as simple as we will go to a bar. We'll look at each
9 about it. 9 other in our eyes and we just realize the pain that
10 Q. When you said you are associates, what do 10 Jeffrey has caused us.
11 you mean? 11 Q. Do you have any other discussions with her
12 A. Well, I have my life and she has her life. 12 or have you had any other discussions with her in
13 Q. Well, you said that you were associates 13 more detail than that?
14 and then you said friends. But you used the term 14 A. I have know that she has an attorney and I
15 associates. 15 have mine. But other than that, we definitely don't
16 A. We are friends. 16 talk about the case because ifs negative. We already
17 Q. Do you have any kind of business 17 know what we went through.
18 relationship with her? 18 Q. Has she indicated to you whether she's
19 A. Not at all. 19 been in contact with other people that have pending
20 Q. Did you mean the word associates to mean 20 claims again Mr. Epstein?
21 something other than just merely being social 21 A. No, sir.
22 friends? 22 Q. Has she indicated to you whether or not
23 A. We are friends. 23 she has sought any professional help? By that I
24 Q. Do you have any kind of relationship with 24 mean a mental health professional, psychologist,
25 her other than simply friends? 25 psychiatrist, that thing, that type of thing?
Page 350 Page 352
1 A. We're just fiends. 1 A. No, sir.
2 Q. You have no common joint venture that 2 Q. There were some other — Ms..., is
3 you're pursuing? 3 that, is that an individual that you took to
4 A. No. 4 Mr. Epstein?
5 Q. No business that you're pursuing? 5 A. Yes, sir.
A. No. 6 Q. And on how many occasions did you take her
7 Q. Are you-all in clubs together? 7 to Mr. Epstein?
8 A. We go out sometimes. A. Around four times,
9 Q. By clubs I meant — I don't know what 9 Q. And did she go alone after that?
10 clubs women are in no, Junior League or 4-H, that 10 A. Yes, sir.
11 type of thing. I don't mean nightclubs. Are 11 Q. And did she tell you how many times she
12 you-all in any organizations together? 12 went?
13 A. No. 13 A. No, sir.
14 Q. Okay. Does — 14 Q. Has she indicated to you any intent to sue
15 A. We go out to a bar once in a blue moon. 15 you for taking her to Mr. Epstein?
16 Q. With what degree of frequency do you have 16 A. No, sir.
17 contact with her? 17 Q. Did the discussion ever come up?
18 A. I call her and tell her I love her once a 18 A. No, sir.
19 week. 19 - Q. Do you feel responsible in some part for
20 Q. Is that something unique to your 20 taking her to Mr. Epstein if she claims that she was
21 relationship with her? 21 somehow damaged as a result of going to sec him?
22 A. Yes. 22 A. No, sir.
23 Q. And what is it about your relationship 23 Q. And did you tell her when you first took
24 with her that's unique? 24 her to Mr. Epstein that nothing bad was going to
25 A. We've been fighting the Jeffrey Epstein case 25 hapeen, that she wasn'tring to be asked to do
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1 anything she didn't want to do? 1 anything at all that she didn't want to do that he
2 A. Correct. 2 insisted that she do?
3 Q. Did you tell her exactly what to expect 3 A. No. All she told me is that she was afraid of
4 when she went? 4 him and she did not want to go back.
5 A. No. S Q. And so what did you tell her after this
6 Q. And did she -- after she went the first first visit where you took her there and told her
7 time, did she indicate to you anything about the 7 that she could be as comfortable as she wanted and
visit? 8 she reported to you that she felt that she had to do
9 A. Yes. 9 whatever Mr. Epstein wanted her to do?
10 Q. What did she say? 10 A. Weil, I said why don't we go again and make
11 A. She told me she did not like it. 11 some money.
12 Q. That would be on the first visit? 12 Q. So, it was you that encouraged her
13 A. Yet 13 notwithstanding whatever reservations she told you
14 Q. Did she say Mr. Epstein did anything or 14 to go back to Mr. Epstein?
15 forced her to do anything that she didn't want to 15 A. Yes.
16 do? 16 Q. And you told her let's do that because you
17 A. Mr. Epstein always told us don't tell anybody. 17 wanted to make money; is that correct?
18 He just wanted us to find girls. So, whatever 18 A. Yes.
19 transpired between her and Mr. Jeffrey Epstein, i 19 Q. And after the second visit, did Ms. •
20 don't -- I'm not sure. 20 tell you that, anything about her visit with
21 MR. LUTHER: Move to strike as not being 21. Mr. Epstein?
22 responsive to the question. My question was, 22 A. She told me the same thing. She was very
23 if you will read back what my question was to 23 quiet about it. She said I do not want to go back.
24 the witness. 24 Q. And notwithstanding that comment did you
25 (Tbe requested portion of the record was 25 take her back a third time?
Faye 3 Page 356
1 read by the reporter.) 1 A. Yes.
2 THE WITNESS: Yes. 2 Q. And what did you tell her after she told
3 BY MR. LUTTIER: 3 you she didn't want to go back?
4 Q. What did she tell you? 4 A. I was stubborn and I said let's go back, and
5 A. She said that she felt very obligated to do 5 please make some more money.
6 what Mr. Jeffrey Epstein had asked her to do. 6 Q. So, would it be a fair statement to say
7 Q. And what did she say Mr. Epstein asked her 7 that you coerced her into going back?
8 to do? 8 A. Yes.
9 A. Take off her clothes. 9 Q. Now, why would you coerce a friend of
10 Q. And you had told her before she went that 1.0 yours to go back?
11 that was going to be requested of her, right? 11. A. Well, when you're -- at that time I was 14.
12 A. Brom what I remember, I told her that, that 12 And when you're 14 and you're poor, a young lady is
13 she would be in a room and we were going to massage his 13 going to do anything for money especially when you're
14 thighs. And then oncel left the room you can be as 14 intimidated by a man who lives in an island that was
15 comfortable as you want to be with him. 15 highly, highly known of. And i was very intimidated by
16 Q. And did she say anything other than that 16 Jeffrey, and he always wanted me to bring girls. And he
17 occurred? 17 told me, make sure you have a girl for me. So, at that
18 A. Excuse me? 18 time, I would only, at that specific time i would only
19 Q. Did she say anything other than that 19 have
20 occurred? 20 Q. Had you been brought up with any kind of
21 A. She said she wasn't comfortable. 21 moral upbringing from your parents?
22 Q. And did she say that she told Mr. Epstein 22 A. Yes.
23 that? 23 Q. And had you been taught as a, as a child
24 A. No, she was scared of him. 24 from as far back as you can remember not to do
25 Q. She indicate that she told Mr. Epstein 25 things that were wrong?
%el
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1 A. Yes. 1 Eisenberg at the statement representing you,
2 Q. And you discarded your upbringing and 2 correct?
3 decided in order to make money you would tell your, 3 A. Yes.
4 one of your good friends that notwithstanding her 4 Q. Okay. And did you tell the FBI what you
5 reservations about going back to Mr. Epstein that 5 just told me about the conversations you had with
b you wanted her to do that; is that correct? 6 el ?
7 A. Yes. 7 A. No.
8 Q. Other than Ms. E telling you that she 8 Q. In fact what you told the FBI was exactly
9 felt that she was obligated to do what Mr. Epstein 9 the opposite, was it not?
10 wanted her to do, did she tell you anything about, 10 A. Correct.
11 anything else about her conversations or 11 Q. Now, there are a number of other people
12 interactions with Mr. Epstein at any time? 12 who in the first deposition you said you had contact
13 A. She told me that if Jeffrey told her if she 13 with in the past. So, I want to make sure we
14 was to tell anybody, she would be in trouble. 14 haven't missed anybody with respect to my question
15 Q. Did she tell you anything else? 15 about communications with them since September 24th
16 A. No. 16 of '09. There was a lady you referred to in your
17 Q. Now, at some point in time before you 17 previous deposition by the name of At the
18 filed this lawsuit, the FBI came to visit with you? 18 time of your prior deposition you sae you
19 A. Yes. 19 know her last name. Do you now know her last name?
20 Q. Is that correct? 20 A. No, sir.
21 A. Yes. 21 Q. Say what?
22 Q. And they took a sworn statement from you, 22 A. No, sir.
23 correct? 23 Q. Does the name Msound familiar to
24 A. At what time? 24 you?
25 Q. They took a sworn statement sometime 25 A. No, sir.
Page 358 Page 360
1 before you filed this lawsuit? 1 Q Have you had any communications with this
2 A. Yes. 2 lady since your September 24th, '09,
3 Q And you were represented by a lawyer at 3 deposition
4 that sworn statement; is that right? 4 A. No, sir.
5. MR. EDWARDS: Object, I object to the 5 Q Have you had any communications with a
6 form. And I know that it's not your intention 6 lady by the name of Jane Doe II since your September
7 to rehash the entire first deposition, but I 7 24th, '09, deposition?
8 think this area was covered. So, to the extent 8 A. No, sir.
9 that it wasn't, then obviously the inquiry can 9 Q. Have you had any communications with a
10 proceed, but we're not going to rehash the 10 lady by the name of Jane Doe since your September
11 entire event as it happened in the first 11 24th, 2009, deposition?
12 deposition. 12 A. No, sir.
13 MR. LUTHER: I have no intention to. 13 Q. On your last deposition, you indicated to
14 BY MR. LUTHER: 14 us that at some point in tune Ms. Jane Doe,'
15 Q. You were represented by a lawyer at that 15 believe, had watched your son for you on some
16 time, correct? 16 occasion?
17 A. On Jeffreys behalf? 17 A. Yes. About two occasions.
18 Q. No, on your behalf. There was a lawyer 18 Q. Okay. Other than those two occasions that
19 there who represented to the FBI that he was your 19 you've described in the previous deposition, has
20 lawyer, is that right? 20 Ms. Jane Doe ever watched your son since then or on
21. MR. EDWARDS: Object to the form. 21 any other occasion?
22 THE WITNESS: I am not understanding this, 22 A. No, sir.
23 sir. • 23 Q Since your September 24th, '09, deposition
24 BY MR. LIMITER: 24 have you ever had anybody else watch your son or has
25 Q. There was a fellow by the name of James 25 he always been with you since then?
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1 A. I have a,1 have a babysitter. 1 A. Yes, or at night as well.
2 Q. And who is your babysitter? 2 Q. Whose shows do you sell? What line of
3 A. 3 shoes? . .
4 A. I sell BCBG, Jessica Simpson. Coach. I can
5 pretty much get any shoe.
6 6 Q. And where do you get the shoes?
7 A. Igo to Macy's. Igo to the clearance rack.
8. I buy them for really cheap, and 1 sell them for what
9 A. I'm not really sure how to spell -- 9 they are originally.
10 Q. Where — 10 Q. So, you would go into a Macy's, if there
11 A. — her 11 was a clearance and buy a half a dozen pairs of
12 Q. WherenaZ4IMI reside? 12 shoes?
13 A. She resides in the, in the acreage. I'm not 13 A. Yes. •
14 positive what the address is. 14 Q. Without knowing what anybody's size was?
15 Q. With what degree of frequency since 15 A. Correct.
16 September 24th, '09, have you utilized her services 16 Q. In other words you don't get somebody's
17 to watch your son? 17 order first and go fill the order?
18 A. Very frequently. Ever since December, I mean 18 A. I could do that but I really don't — I would
19 January 1st, 2010, she watches my son regularly. 19 rather go there and buy a bulk of shoes with whatever
20 Q. Is there like certain days of the week she 20 size. And if someone is interested in a nail salon, you
21 automatically watches him? 21 know, and if ifs their size, then they'll buy it
22 A. No. 22 Q. When did you first start selling these
23 Q. And, and why -- is the frequency with 23 shoes?
24 which she watches your son since January of 2010 24 A. January I st, 2010.
zs greater than the frequency with which you had people 25 Q. And did somebody introduce you to this
Page 362 Page 364
1 watch your son prior to that date? 1 business?
2 A. Excuse me? Can you — 2 A. No.
3 Q. Why is she watching your son frequently 3 Q. This is something you came up with on your
4 since January 10? 4 own?
5 A. So I can work. 5 A. Yes.
6 Q. Okay. Where are you working? 6 • Q. Okay. Who do you sell lingerie for?
7 A. I sell Mary Kay, shoes, lingerie, and clothes. 7 A. I go to different areas. I go to, I will go
8 Q. Mary Kay shoes? 8 to strip clubs and sell lingerie if they want it. My
9 A. Lingerie and clothes. 9' girlfriends. I sell lingerie to. Valentine's is coming
10 Q. Lingerie and what else? 10 up. I will be selling a lot of lingerie soon.
11 A. And clothes. 11. Q. Who do you get the lingerie from?
12 Q. Is that, is that all of that Mary ICay 12 A. Igo to local adult stores and I go to the
13 items; that is Mary Kay has a line of shoes, or are 13 clearance and I buy them in bulk, and then I sell them
14 you saying — 14 for the original or more price.
15 A. No. 15 Q So and when do you go to these strip
16 Q. — that you sell Mary Kay cosmetics, plus 16 clubs, during the day or at night?
17 you sell shoes, plus you sell lingerie, plus you • 17 A. Both.
18 sell clothes? 18 Q. And what do you do at these strip clubs?
19 A. Yes. 19 MR. EDWARDS: Object to the form You tan
20 Q. All right And do you — what hours do 20 EMSWer.
23. you work? 21 THE WITNESS: Yeah, I walk In with my
22 A. Well, 1 just, it's on my own hours. I will go 22 duffel bag MI oldie items I like to sell,
23' to tanning salons to see if anybody wants to buy. I 23 and the women get to choose what they wait to
24 will go to nail salons. .24. buy
25 Q. Is this all during the day? 25.
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1 BY MR.. LUITIER: 1 Q. So, what you are telling the ladies and
2 Q. Do you dance at any of these strip clubs? 2 gentlemen of the jury is somebody pays you three to
3 A. No, sir. 3 $500 an hour just to be in your company and not to
4 ' Q. Have you danced anywhere since September 4 have any sex with you?
5 24th, 2009? 5 MR.. EDWARDS: Object to the fonn.
6 A. No, sir. 6 BY MR. LUTTIER:
7 Q. Have you worked in any adult establishment 7 Q. Is that right?
8 of any kind or nature since September 24th, 2009? 8 MR. EDWARDS: And just so that the record
9 A. Not in a strip joint, no. 9 Is clear, the wage claim, the loss wages and
10 Q. Okay. Well, have you worked in any other 10 loss of earning capacity has been withdrawn in
11 kind of adult establishment other than a strip joint 11 the case.
12 since September 24th, '09? 12 You can answer the question, if you
13 A. Yes. 13 understand the question.
14 Q. Where have you worked? 14 BY MR. LUTTIER:
15 A. I have worked for my private clientele. 15 Q. Is that right.
1.6 Q. What do you mean by "private clientele"? 16 A. What was the question?
17 A. I have worked, I have been company to a few 17 Q. So you're telling the ladies and gentlemen
18 men that I have met ever since the last deposition, and 18 of the jury that men pay you three to $500 an hour
19 I provide company for than. 19 just for your company but you have no sex with them;
20 Q. The last time you told us you had worked 20 is that correct?
21 for an escort service. Do you recall that? 21 MR. EDWARDS: Object to the form.
22 A. Correct 22 111E WITNESS: Correct.
23 Q. Is this in essence the same thing you're 23 BY MR. LUTHER:
24 still doing? 24 Q. Or is sex an additional charge?
25 A. No. 25 A. No, I don't have sex with them.
Page 366 Page 368
1 Q. Are you working for an escort service now? 1 Q. Have you ever — or when did you start
2 A. No. 2 this little escort service that you're describing
3 Q. Have you been working for an escort 3 now?
4 service since September 24th, 2009? 4 A. Well, I don't know what your definition of
5 A. No, sir. 5 escort is. It's pretty much I offer my company to got
6 Q. Do you advertise your services somehow? 6 paid. January 5th, 2010.
7 A. No, sir. 71 Q. And how did you fix on the date
8 Q. So, how do you — how do these people know 8 January 5th?
9 to retain your services? 9 A. I had met a gentleman named Bobby in CityPlace
10 A. Word of mouth. 10 and we sat down for a drink and we just started talking.
1 Q Okay. And how do they get word of mouth? 11 Q. Had you gone there to meet him?
12 A. I have one client, Bobby, and he has referred 12 A. No, I just went there by myself. And I
13 me to three other clients. 13 just —
14 Q. And what's the difference between what you 14 Q. Did you meet him in an establishment at
15 are doling with these clients and what you did with 15 CityPlaoe?
16 the escort service? 16 A. I met him at Carousel.
17 A. Well, the difference is is that I don't 17 Q. Okay. That's a restaurant and a bar
18 perform any sexual acts. It's pretty much just I am 18 there?
19 company if — they pay me for my company. 19 A. It's a restaurant, correct.
20 Q. Well, how much do they pay you for your 20 Q. Okay. Is that Can Can --
21 company? 21 A. Can Can Carousel (sic).
22 A. It ranges anyway, any any price is from 300 22 Q. Motive or motif?
23 to 500. 23 A. Can Can Carousel.
24 g 300 to 500 what? 24 Q. Right The waitresses are in cancan
25 A. An hour. 25 outfits and dance on the tables or something like
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1 that? 1 males approximately your age would ask you out to a
2 A. Yes. 2 movie or something like that on a date. Has that
3 Q. And were, were you there -- why were you 3 happened to you?
4 there? 4 A. Yes. With these men, yes.
5 A. I was just — Igo out by myself sometimes 5 Q. So, what these people -- you consider
6 just to recuperate and have a nice drink and a nice 6 these people dates; is that what you're telling me?
7 dinner by myself. I am single. 7 A. Yes, we go out to the movies. We go out to
8 Q. So, were you there for dinner or were you 8 eat dinner.
9 there for something else? 9 Q. How many dates did you have as a youth
10 A. I was there fora drink. 10 where people paid you three to 5500 an hour —
11 Q. So you went to the bar? 11 A. Sir --
12 A. Yes. 12 Q just to have the opporttmity to date
13 Q. And this fellow happened to be at the bar? 13 you?
14 A. Yes. 14 A. Ever since Jeffrey Epstein --
15 Q. And it wasn't, it wasn't prearranged. He 15 MIL EDWARDS: Objec
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO:502008CA028051XXXXMB AB
Plaintiff,
- vs- VOLUME III OF IV
JEFFREY EPSTEIN
AND
Defendants.
VIDEO-CONFERENCED VIDEOTAPED DEPOSITION OFIIII.
Tuesday, February 09, 2010
10:09 - 5:05 p.m.
250 Australian Avenue South
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1296
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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}
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1 APPEARANCES: 1 PROCEEDINGS
2 On beJulf ofthe Plaintiff lig! and Jane Dot 2
3 BRAD J. EDWARDS,
FARMER, JAFFE, WEISSItla EDWARDS 3 THE VIDEOGRAPHER: This is the 9th day of
4 4 February, 2010. The dine is approximately
5 10imIty.m. This is the videotaped deposition
6 OM. in the matter of M. versus Epstein.
I 7 This deposition is being held at 250 South
On of tbe Jeffrey Epstein:
ROBERT D. CROTON, JR., ESQUIRE 8 Australian Avenue, West Palm Beach, Florida.
MARK T. LUTHER. ESQUIRE 9 My name is Daniel Downey, I am the
9 LUITIER ea COLEMAN, LLP
10 videographer representing Visual Evidence,
11 Incorporated. Will the attorneys please
12 announce their appearances for the record.
•2 On bed o • • licfrroYEPslele: 13 MR. EDWARDS: Brad Edwards on behalf of
.3 JACK ALAN GOLDBERGER, ESQUIRE 14
ER Fe WEISS. PA
14 15 MR. LUTTLER: Mark Luttier with the firm
16 of Burman, Critton, Luther & Coleman on behalf
17 of Mr. Epstein.
16 18 MR. CRITMN: Bob Critton on behalf of
17 19 Mr. Epstein.
18 ALSO PRESENT: kffrey Epstein, via video conference
Daniel Downey, Videograplicr 20 Thereupon,
19 Visual Evidence, Incorporated 21
20 22 Having been first duly sworn or affirmed, was
21
22 23 examined and testified as follows:
23 24 THE WITNESS: I do.
24
25 25
Page 338 Page 340
1 1 DIRECT EXAMINATION
2 2 BY MR. LLTIT1ER:
3 INDEX VOLUME I 3 Q. Good morning, Ms... We're here for the
4 4 continuation of your deposition that was started on
5 5 September 24th, 2009. Do you understand that you're
6 WITNESS: DIRECT CROSS REDIRECT RECROSS 6 still under oath today?
7 7 A. Yes, sir.
8 BY MR. LUTHER 4 8 Q. Have you had an opportunity to reviewa
9 9 transcript of that portion of your deposition which
10 10 has been completed thus far?
11. 11 A. Yes, sir.
12 NO EXHIBITS MARKED 12 Q. Have you reviewed the full transcript?
13 13 A. Yes, sir.
14 14 Q. And were there any corrections in your
15 15 testimony?
16 16 A. Were there any corrections in my testimony?
17 17 Q. In other words, when you read it did you
18 18 see anything that was incorrect?
19 19 A. No, sir.
20 20 Q. Do you recall whether or not you silted
21 21 the transcript indicating that all of it was
22 22 accurate?
23 23 A. I signed, yes.
24 24 Q Do you know if the original got sent
25 25 anywhere or do you stil I have it or dicliou just
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1 give it to your lawyer? 1 shown to third parties and they had been asked
2 A. I gave it to my attorney. 2 whether or not they wanted to purchase an interest
3 Q. And you signed it without any corrections? 3 in your lawsuit?
4 A. Yes, sir. 4 A. No.
5 Q. Have you ever been to Mr. Edwards' former 5 Q. No one had called you and advised you that
6 law firm's office in Fort Lauderdale? That would be 6 your files were being shown to anybody?
7 the firm of Rothstein, Rosenfeldt & Adler. 7 A. No.
8 A. What is this address? Is this address on 8 Q. Have you had any discussions with anyone
9 Andrews? 9 about that issue?
10 Q. 10 A. No.
1/ A. No. 11 Q. And when I say anyone I mean
12 Q. Have you ever been to a law firm where 12 representative of the Florida Bar Association; have
13 Mr. Edwards was practicing while he's been 13 you had any discussions with anybody from the
14 representing you where there are other lawyers 14 Florida Bar?
15 besides himself present? 15 A. No, sir.
16 A. No. 16 Q. Any discussions with anybody from the FBI
17 Q. Does the name Rothstein ring a bell to 17 about that specific issue?
18 you? Do you know who that is? 18 A. About what issue, about getting —
19 A. No. 19 . Q. About someone attempting to purchase an
20 Q. Do -- have you ever met with anyone else 20 interest in your lawsuit.
21 other than your lawyer with respect to the merits of 21 A. No.
22 this lawsuit and whether or not you believed you 22 Q. Anyone from the State Attorney's office?
23 were likely to recover money in this case? 23 A. No.
24 A. No. 24 Q. Okay. Prior to coming here today, have
25 Q. Has anyone ever approached you arid -- 25 you had an opportunity to review a transcript of a
Page 342 Page 344
1 other than your lawyer -- and discussed with you the 1 hearing that was held before the court on
2 merits of this case or whether or not you believed 2 November 3rd, 2009, upon your motion to terminate
3 you were likely to recover money? 3 the continuation of this deposition?
4 A. No. 4 A. Excuse me?
Q. Have you been advised that — or let me 5 Q. Prior to coming here today have you been
6 strike that. Have you been provided any information 6 provided an opportunity to review a transcript of a
7 that your case and the information contained in it 7 hearing that was held before the court on
8 was made available to third parties to review to 8 November 3rd, 2009, on your motion to limit this
9 determine whether or not they wanted to purchase an 9 deposition?
10 interest in the outcome of your case? 10 A. I'm not understanding this.
11 A. No. 11 Q. You know what a transcript is, don't you?
12 Q. Have you, prior to me just asking you that 12 A. A transcript, yes.
13 • question, did you know that that had occurred? 13 Q. This would have been a transcript or
14 MR. EDWARDS: Object to the fonn. 14 written record of a court hearing that we had in
15 THE WITNESS: Excuse me? 15 case on November 3rd, 2009, that concerned the
16 MR. EDWARDS: I objected to the form of 16 conducting of this deposition. Have you seen any
17 the question. It assumes that it did occur. 17 such transcript?
18 BY MR. LUITIER: 18 A. A transcript of what?
19 Q. Before I asked you that question, did you 19 Q. Of that court hearing.
20 know that that had occurred. 20 A. Of what court hearing?
21 A. Sr, I'm not really understanding what you're 21 Q. The one that was held on November 3rd,
22 saying. 22 2009.
23 Q. All right. Let me repeat it. 23 A. That we recently just did, my last deposition?
24 . A. Okay. 24 Q. No. The, the hearing was held on
25 Q. Did you know that your case tiles had been 25 November 3rd, 2009. The subject matter of the
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1 hearing was a motion that was filed by your lawyer 1 was 13 years old. And on that note, he took it from
2 to limit the continuation of this deposition. 2 there to just comfort me through the, through the pain
.3 A. Yes. I knew that we were going to have 3 that I was going through and that I have been going
4 another deposition. 4 through.
5 • Have you seen the transcript of that 5 Q. Did any of these discussions concern
6 hearing wherein the judge gave some specific 6. anything else?
7 direction to you and your conduct in the 7 A. No, sir.
8 continuation of this — 8 Q Have you, since your deposition on
9 A. Yes. September 24th, 2009, had any type of contact with
10 Q. deposition? 10 anyone else who has filed asuit against
11. A. Yes. 11 Mr. Epstein?
12 Q. Okay. So you're aware of that? 12 A. Yes.
13 A. Yes. 13 Q. M.Who have you had contact with?
14 Q. Okay. Are you still living at the same 14 A
15 address that you gave me at the last deposition? 15 Q. Anyone else?
16 A. Yes, sir. 16 A. No, sir.
17 Q. Who else is living with you there now? 17 Q. And when I, I use the word contact, by
18 A. My son. 18 that I mean could be face-to-face contact, could be
19 Q. Anyone else? 19 a conversation, could be some sort of computer,
20 A. No, sir. 20 computer message, a text, Twitter, e-mail, any kind
21 Q. Has anyone else lived with you at that 21 of commuter — anything like that, could it be, it
22 address since your deposition on September 24th, 22 could be something in writing. Do you understand
23 2009, other than your son? 23 that's What I mean by communication?
24 A. No, sir. Since November, actually, Thomas 24 A. Yes, sir.
25 Souder, he had moved, he lived with me until 25 Q. And so the only person since September
Page 346 Page 348
January 1st, 2010. 1 24th, 2009,. that. yo_u had any contact with that has a
2 Q. And am I correct told us at your 2 suit pending against Mr. Epstein is E.?
3 last deposition that was then your 3 A. Yes, sir.
4 current boyfriend? 4 MR. CRITION: No, Mr
5 A. Yes. 5 THE WITNESS: No.
6 Q. Has that relationship changed now? •6 MR. CRITTON: What.did she say?
7 A. Yes. 7 THE WITNESS:
,8 Q. He is no longer your current boyfriend? 8 MR. LUU1ER:
A. Correct 9 MR. CRITTON: Oh,
10 Q. Is the apartment that you currently live 10 MR. LUTIIER: Yeah.
11 in, is that a rental apartment? 11 MR. CRITTON: Okay.
12 A. Yes. 12 MR. LUITIER: And when did you
13 Q. Is that rental apartment in your name? 13 MR. EDWARD: Fm sorry. Does she need to
14 A. Yes. 14 put her microphone on?
15 Q. Bite was the situation that caused 15 VIDEOGRAPHER: I can pick her up.
16 you and to part company? 16 MR. EDWARD: You can pick — Okay.
17 A. It was mutual. 17 THE VIDEOGRAPHER: That's fine.
18 Q. Was there any domestic violence involved? 18 MR. LUTT1ER: That would be a good idea.
19 A. No, sir. 19 MR. EDWARDS: Let's make sure we're
20 O• Did you have any discussions with 20 actually getting all of this.
21 at any time about this lawsuit? 21 MR. LUTTIEFt: Start over.
22 A. Yes. 22 MR. EDWARD: We don't need that.
23 Q. What discussions did you have? 23 BY MR. LUTTEER:
24 A. Well, he's saw the news and I pretty much told 24 Q. And when did you have communication with
25 him that Jeffrey F nCt in has been mol ting MP since I 25 Ms. Lan cry?
r.! ,
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1 A. We are awriates. We're friends. When did I 1 and we can confine (sic) in each other if anything. But
2 have a conversation with ha? 2 as in confining, I mean all I have to do is look in her
3 Q. Yes. Well, I don't want to limit it to a 3 eyes and'we just know the pain that we've went through.
4 conversation. When did you have communication with 4 Q. Am I going to assume correctly that the
her? 5 word you mean is confide, you confide in each other?
A. I have communication with her frequently but 6 You tell each other -
7 we don't talk about the Jeffrey Epstein case. My 7 A. No, I told you, as when I confine in her, it's
8 attorney is not her attorney. We don't choose to talk 8 as simple as we will go to a bar. We'll look at each
9 about it. 9 other in our eyes and we just realize the pain that
10 Q. When you said you are associates, what do 10 Jeffrey has caused us.
11 you mean? 11 Q. Do you have any other discussions with her
12 A. Well, I have my life and she has her life. 12 or have you had any other discussions with her in
13 Q. Well, you said that you were associates 13 more detail than that?
14 and then you said friends. But you used the term 14 A. I have know that she has an attorney and I
15 associates. 15 have mine. But other than that, we definitely don't
16 A. We are friends. 16 talk about the case because ifs negative. We already
17 Q. Do you have any kind of business 17 know what we went through.
18 relationship with her? 18 Q. Has she indicated to you whether she's
19 A. Not at all. 19 been in contact with other people that have pending
20 Q. Did you mean the word associates to mean 20 claims again Mr. Epstein?
21 something other than just merely being social 21 A. No, sir.
22 friends? 22 Q. Has she indicated to you whether or not
23 A. We are friends. 23 she has sought any professional help? By that I
24 Q. Do you have any kind of relationship with 24 mean a mental health professional, psychologist,
25 her other than simply friends? 25 psychiatrist, that thing, that type of thing?
Page 350 Page 352
1 A. We're just fiends. 1 A. No, sir.
2 Q. You have no common joint venture that 2 Q. There were some other — Ms..., is
3 you're pursuing? 3 that, is that an individual that you took to
4 A. No. 4 Mr. Epstein?
5 Q. No business that you're pursuing? 5 A. Yes, sir.
A. No. 6 Q. And on how many occasions did you take her
7 Q. Are you-all in clubs together? 7 to Mr. Epstein?
8 A. We go out sometimes. A. Around four times,
9 Q. By clubs I meant — I don't know what 9 Q. And did she go alone after that?
10 clubs women are in no, Junior League or 4-H, that 10 A. Yes, sir.
11 type of thing. I don't mean nightclubs. Are 11 Q. And did she tell you how many times she
12 you-all in any organizations together? 12 went?
13 A. No. 13 A. No, sir.
14 Q. Okay. Does — 14 Q. Has she indicated to you any intent to sue
15 A. We go out to a bar once in a blue moon. 15 you for taking her to Mr. Epstein?
16 Q. With what degree of frequency do you have 16 A. No, sir.
17 contact with her? 17 Q. Did the discussion ever come up?
18 A. I call her and tell her I love her once a 18 A. No, sir.
19 week. 19 - Q. Do you feel responsible in some part for
20 Q. Is that something unique to your 20 taking her to Mr. Epstein if she claims that she was
21 relationship with her? 21 somehow damaged as a result of going to sec him?
22 A. Yes. 22 A. No, sir.
23 Q. And what is it about your relationship 23 Q. And did you tell her when you first took
24 with her that's unique? 24 her to Mr. Epstein that nothing bad was going to
25 A. We've been fighting the Jeffrey Epstein case 25 hapeen, that she wasn'tring to be asked to do
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1 anything she didn't want to do? 1 anything at all that she didn't want to do that he
2 A. Correct. 2 insisted that she do?
3 Q. Did you tell her exactly what to expect 3 A. No. All she told me is that she was afraid of
4 when she went? 4 him and she did not want to go back.
5 A. No. S Q. And so what did you tell her after this
6 Q. And did she -- after she went the first first visit where you took her there and told her
7 time, did she indicate to you anything about the 7 that she could be as comfortable as she wanted and
visit? 8 she reported to you that she felt that she had to do
9 A. Yes. 9 whatever Mr. Epstein wanted her to do?
10 Q. What did she say? 10 A. Weil, I said why don't we go again and make
11 A. She told me she did not like it. 11 some money.
12 Q. That would be on the first visit? 12 Q. So, it was you that encouraged her
13 A. Yet 13 notwithstanding whatever reservations she told you
14 Q. Did she say Mr. Epstein did anything or 14 to go back to Mr. Epstein?
15 forced her to do anything that she didn't want to 15 A. Yes.
16 do? 16 Q. And you told her let's do that because you
17 A. Mr. Epstein always told us don't tell anybody. 17 wanted to make money; is that correct?
18 He just wanted us to find girls. So, whatever 18 A. Yes.
19 transpired between her and Mr. Jeffrey Epstein, i 19 Q. And after the second visit, did Ms. •
20 don't -- I'm not sure. 20 tell you that, anything about her visit with
21 MR. LUTHER: Move to strike as not being 21. Mr. Epstein?
22 responsive to the question. My question was, 22 A. She told me the same thing. She was very
23 if you will read back what my question was to 23 quiet about it. She said I do not want to go back.
24 the witness. 24 Q. And notwithstanding that comment did you
25 (Tbe requested portion of the record was 25 take her back a third time?
Faye 3 Page 356
1 read by the reporter.) 1 A. Yes.
2 THE WITNESS: Yes. 2 Q. And what did you tell her after she told
3 BY MR. LUTTIER: 3 you she didn't want to go back?
4 Q. What did she tell you? 4 A. I was stubborn and I said let's go back, and
5 A. She said that she felt very obligated to do 5 please make some more money.
6 what Mr. Jeffrey Epstein had asked her to do. 6 Q. So, would it be a fair statement to say
7 Q. And what did she say Mr. Epstein asked her 7 that you coerced her into going back?
8 to do? 8 A. Yes.
9 A. Take off her clothes. 9 Q. Now, why would you coerce a friend of
10 Q. And you had told her before she went that 1.0 yours to go back?
11 that was going to be requested of her, right? 11. A. Well, when you're -- at that time I was 14.
12 A. Brom what I remember, I told her that, that 12 And when you're 14 and you're poor, a young lady is
13 she would be in a room and we were going to massage his 13 going to do anything for money especially when you're
14 thighs. And then oncel left the room you can be as 14 intimidated by a man who lives in an island that was
15 comfortable as you want to be with him. 15 highly, highly known of. And i was very intimidated by
16 Q. And did she say anything other than that 16 Jeffrey, and he always wanted me to bring girls. And he
17 occurred? 17 told me, make sure you have a girl for me. So, at that
18 A. Excuse me? 18 time, I would only, at that specific time i would only
19 Q. Did she say anything other than that 19 have
20 occurred? 20 Q. Had you been brought up with any kind of
21 A. She said she wasn't comfortable. 21 moral upbringing from your parents?
22 Q. And did she say that she told Mr. Epstein 22 A. Yes.
23 that? 23 Q. And had you been taught as a, as a child
24 A. No, she was scared of him. 24 from as far back as you can remember not to do
25 Q. She indicate that she told Mr. Epstein 25 things that were wrong?
%el
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1 A. Yes. 1 Eisenberg at the statement representing you,
2 Q. And you discarded your upbringing and 2 correct?
3 decided in order to make money you would tell your, 3 A. Yes.
4 one of your good friends that notwithstanding her 4 Q. Okay. And did you tell the FBI what you
5 reservations about going back to Mr. Epstein that 5 just told me about the conversations you had with
b you wanted her to do that; is that correct? 6 el ?
7 A. Yes. 7 A. No.
8 Q. Other than Ms. E telling you that she 8 Q. In fact what you told the FBI was exactly
9 felt that she was obligated to do what Mr. Epstein 9 the opposite, was it not?
10 wanted her to do, did she tell you anything about, 10 A. Correct.
11 anything else about her conversations or 11 Q. Now, there are a number of other people
12 interactions with Mr. Epstein at any time? 12 who in the first deposition you said you had contact
13 A. She told me that if Jeffrey told her if she 13 with in the past. So, I want to make sure we
14 was to tell anybody, she would be in trouble. 14 haven't missed anybody with respect to my question
15 Q. Did she tell you anything else? 15 about communications with them since September 24th
16 A. No. 16 of '09. There was a lady you referred to in your
17 Q. Now, at some point in time before you 17 previous deposition by the name of At the
18 filed this lawsuit, the FBI came to visit with you? 18 time of your prior deposition you sae you
19 A. Yes. 19 know her last name. Do you now know her last name?
20 Q. Is that correct? 20 A. No, sir.
21 A. Yes. 21 Q. Say what?
22 Q. And they took a sworn statement from you, 22 A. No, sir.
23 correct? 23 Q. Does the name Msound familiar to
24 A. At what time? 24 you?
25 Q. They took a sworn statement sometime 25 A. No, sir.
Page 358 Page 360
1 before you filed this lawsuit? 1 Q Have you had any communications with this
2 A. Yes. 2 lady since your September 24th, '09,
3 Q And you were represented by a lawyer at 3 deposition
4 that sworn statement; is that right? 4 A. No, sir.
5. MR. EDWARDS: Object, I object to the 5 Q Have you had any communications with a
6 form. And I know that it's not your intention 6 lady by the name of Jane Doe II since your September
7 to rehash the entire first deposition, but I 7 24th, '09, deposition?
8 think this area was covered. So, to the extent 8 A. No, sir.
9 that it wasn't, then obviously the inquiry can 9 Q. Have you had any communications with a
10 proceed, but we're not going to rehash the 10 lady by the name of Jane Doe since your September
11 entire event as it happened in the first 11 24th, 2009, deposition?
12 deposition. 12 A. No, sir.
13 MR. LUTHER: I have no intention to. 13 Q. On your last deposition, you indicated to
14 BY MR. LUTHER: 14 us that at some point in tune Ms. Jane Doe,'
15 Q. You were represented by a lawyer at that 15 believe, had watched your son for you on some
16 time, correct? 16 occasion?
17 A. On Jeffreys behalf? 17 A. Yes. About two occasions.
18 Q. No, on your behalf. There was a lawyer 18 Q. Okay. Other than those two occasions that
19 there who represented to the FBI that he was your 19 you've described in the previous deposition, has
20 lawyer, is that right? 20 Ms. Jane Doe ever watched your son since then or on
21. MR. EDWARDS: Object to the form. 21 any other occasion?
22 THE WITNESS: I am not understanding this, 22 A. No, sir.
23 sir. • 23 Q Since your September 24th, '09, deposition
24 BY MR. LIMITER: 24 have you ever had anybody else watch your son or has
25 Q. There was a fellow by the name of James 25 he always been with you since then?
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1 A. I have a,1 have a babysitter. 1 A. Yes, or at night as well.
2 Q. And who is your babysitter? 2 Q. Whose shows do you sell? What line of
3 A. 3 shoes? . .
4 A. I sell BCBG, Jessica Simpson. Coach. I can
5 pretty much get any shoe.
6 6 Q. And where do you get the shoes?
7 A. Igo to Macy's. Igo to the clearance rack.
8. I buy them for really cheap, and 1 sell them for what
9 A. I'm not really sure how to spell -- 9 they are originally.
10 Q. Where — 10 Q. So, you would go into a Macy's, if there
11 A. — her 11 was a clearance and buy a half a dozen pairs of
12 Q. WherenaZ4IMI reside? 12 shoes?
13 A. She resides in the, in the acreage. I'm not 13 A. Yes. •
14 positive what the address is. 14 Q. Without knowing what anybody's size was?
15 Q. With what degree of frequency since 15 A. Correct.
16 September 24th, '09, have you utilized her services 16 Q. In other words you don't get somebody's
17 to watch your son? 17 order first and go fill the order?
18 A. Very frequently. Ever since December, I mean 18 A. I could do that but I really don't — I would
19 January 1st, 2010, she watches my son regularly. 19 rather go there and buy a bulk of shoes with whatever
20 Q. Is there like certain days of the week she 20 size. And if someone is interested in a nail salon, you
21 automatically watches him? 21 know, and if ifs their size, then they'll buy it
22 A. No. 22 Q. When did you first start selling these
23 Q. And, and why -- is the frequency with 23 shoes?
24 which she watches your son since January of 2010 24 A. January I st, 2010.
zs greater than the frequency with which you had people 25 Q. And did somebody introduce you to this
Page 362 Page 364
1 watch your son prior to that date? 1 business?
2 A. Excuse me? Can you — 2 A. No.
3 Q. Why is she watching your son frequently 3 Q. This is something you came up with on your
4 since January 10? 4 own?
5 A. So I can work. 5 A. Yes.
6 Q. Okay. Where are you working? 6 • Q. Okay. Who do you sell lingerie for?
7 A. I sell Mary Kay, shoes, lingerie, and clothes. 7 A. I go to different areas. I go to, I will go
8 Q. Mary Kay shoes? 8 to strip clubs and sell lingerie if they want it. My
9 A. Lingerie and clothes. 9' girlfriends. I sell lingerie to. Valentine's is coming
10 Q. Lingerie and what else? 10 up. I will be selling a lot of lingerie soon.
11 A. And clothes. 11. Q. Who do you get the lingerie from?
12 Q. Is that, is that all of that Mary ICay 12 A. Igo to local adult stores and I go to the
13 items; that is Mary Kay has a line of shoes, or are 13 clearance and I buy them in bulk, and then I sell them
14 you saying — 14 for the original or more price.
15 A. No. 15 Q So and when do you go to these strip
16 Q. — that you sell Mary Kay cosmetics, plus 16 clubs, during the day or at night?
17 you sell shoes, plus you sell lingerie, plus you • 17 A. Both.
18 sell clothes? 18 Q. And what do you do at these strip clubs?
19 A. Yes. 19 MR. EDWARDS: Object to the form You tan
20 Q. All right And do you — what hours do 20 EMSWer.
23. you work? 21 THE WITNESS: Yeah, I walk In with my
22 A. Well, 1 just, it's on my own hours. I will go 22 duffel bag MI oldie items I like to sell,
23' to tanning salons to see if anybody wants to buy. I 23 and the women get to choose what they wait to
24 will go to nail salons. .24. buy
25 Q. Is this all during the day? 25.
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1 BY MR.. LUITIER: 1 Q. So, what you are telling the ladies and
2 Q. Do you dance at any of these strip clubs? 2 gentlemen of the jury is somebody pays you three to
3 A. No, sir. 3 $500 an hour just to be in your company and not to
4 ' Q. Have you danced anywhere since September 4 have any sex with you?
5 24th, 2009? 5 MR.. EDWARDS: Object to the fonn.
6 A. No, sir. 6 BY MR. LUTTIER:
7 Q. Have you worked in any adult establishment 7 Q. Is that right?
8 of any kind or nature since September 24th, 2009? 8 MR. EDWARDS: And just so that the record
9 A. Not in a strip joint, no. 9 Is clear, the wage claim, the loss wages and
10 Q. Okay. Well, have you worked in any other 10 loss of earning capacity has been withdrawn in
11 kind of adult establishment other than a strip joint 11 the case.
12 since September 24th, '09? 12 You can answer the question, if you
13 A. Yes. 13 understand the question.
14 Q. Where have you worked? 14 BY MR. LUTTIER:
15 A. I have worked for my private clientele. 15 Q. Is that right.
1.6 Q. What do you mean by "private clientele"? 16 A. What was the question?
17 A. I have worked, I have been company to a few 17 Q. So you're telling the ladies and gentlemen
18 men that I have met ever since the last deposition, and 18 of the jury that men pay you three to $500 an hour
19 I provide company for than. 19 just for your company but you have no sex with them;
20 Q. The last time you told us you had worked 20 is that correct?
21 for an escort service. Do you recall that? 21 MR. EDWARDS: Object to the form.
22 A. Correct 22 111E WITNESS: Correct.
23 Q. Is this in essence the same thing you're 23 BY MR. LUTHER:
24 still doing? 24 Q. Or is sex an additional charge?
25 A. No. 25 A. No, I don't have sex with them.
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1 Q. Are you working for an escort service now? 1 Q. Have you ever — or when did you start
2 A. No. 2 this little escort service that you're describing
3 Q. Have you been working for an escort 3 now?
4 service since September 24th, 2009? 4 A. Well, I don't know what your definition of
5 A. No, sir. 5 escort is. It's pretty much I offer my company to got
6 Q. Do you advertise your services somehow? 6 paid. January 5th, 2010.
7 A. No, sir. 71 Q. And how did you fix on the date
8 Q. So, how do you — how do these people know 8 January 5th?
9 to retain your services? 9 A. I had met a gentleman named Bobby in CityPlace
10 A. Word of mouth. 10 and we sat down for a drink and we just started talking.
1 Q Okay. And how do they get word of mouth? 11 Q. Had you gone there to meet him?
12 A. I have one client, Bobby, and he has referred 12 A. No, I just went there by myself. And I
13 me to three other clients. 13 just —
14 Q. And what's the difference between what you 14 Q. Did you meet him in an establishment at
15 are doling with these clients and what you did with 15 CityPlaoe?
16 the escort service? 16 A. I met him at Carousel.
17 A. Well, the difference is is that I don't 17 Q. Okay. That's a restaurant and a bar
18 perform any sexual acts. It's pretty much just I am 18 there?
19 company if — they pay me for my company. 19 A. It's a restaurant, correct.
20 Q. Well, how much do they pay you for your 20 Q. Okay. Is that Can Can --
21 company? 21 A. Can Can Carousel (sic).
22 A. It ranges anyway, any any price is from 300 22 Q. Motive or motif?
23 to 500. 23 A. Can Can Carousel.
24 g 300 to 500 what? 24 Q. Right The waitresses are in cancan
25 A. An hour. 25 outfits and dance on the tables or something like
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1 that? 1 males approximately your age would ask you out to a
2 A. Yes. 2 movie or something like that on a date. Has that
3 Q. And were, were you there -- why were you 3 happened to you?
4 there? 4 A. Yes. With these men, yes.
5 A. I was just — Igo out by myself sometimes 5 Q. So, what these people -- you consider
6 just to recuperate and have a nice drink and a nice 6 these people dates; is that what you're telling me?
7 dinner by myself. I am single. 7 A. Yes, we go out to the movies. We go out to
8 Q. So, were you there for dinner or were you 8 eat dinner.
9 there for something else? 9 Q. How many dates did you have as a youth
10 A. I was there fora drink. 10 where people paid you three to 5500 an hour —
11 Q. So you went to the bar? 11 A. Sir --
12 A. Yes. 12 Q just to have the opporttmity to date
13 Q. And this fellow happened to be at the bar? 13 you?
14 A. Yes. 14 A. Ever since Jeffrey Epstein --
15 Q. And it wasn't, it wasn't prearranged. He 15 MIL EDWARDS: Objec