EFTA01248007.pdf
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE No.502008CA037319XXXXMB AB
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
VIDEOTAPED DEPOSITION OF
VOLUME I
Tuesday, November 10, 2009
11:13 a.m. - 6:12 p.m.
250 S. Australian Avenue
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Sandra W. Townsend, FPR
PROSE COURT REPORTING AGENCY
Notary Public, State of Florida
West Palm Beach Office
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-901Po7174075
3501.182-102
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1 APPEARANCES:
2 On behalf of the Plaintiff III.:
3
On behalf of Plaintiffs
On behalf of Plaintiff
U
U
•
•
•
18 On behalf of the Defendant:
19 ROBERT CRITTON, ESQUIRE
BURMAN, CRITTON, LUTTIER & COLEMAN
20 515 North Flagler Drive
Suite 400
21 West Palm Beach, Florida 33401
Phone: 561.842.2820
22
23
24
25
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075
3501.182-102
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1 On behalf of the Witness:
6
7 ALSO PRESENT:
8
MICHAEL DOWNEY, VIDEOGRAPHER
9
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(561) 832-75C0 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-90flb7174075
3501.182-102
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1
2 EXHIBITS
3
4
NUMBER DESCRIPTION PAGE
5
6 Plaintiff:
7 Exhibit number 1 Notebook page 14
8 Exhibit number 2 Photograph 134
9 Exhibit number 3 Photograph 137
10 Exhibit number 4 Photograph 138
11 Exhibit number 5 Photograph 247
12
13 Defendant:
14 Exhibit number 1 Transcript 140
15
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401-377476-2895)
Electronically signed by Sandra Townsend (401-377476-2895) 1f88f1134663-4dad-94e740ftb7174075
3501.182-102
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1 PROCEEDINGS
2
3 Deposition taken before Sandra W. Townsend, Court
4 Reporter and Notary Public in and for the State of
5 Florida at Large, in the above cause.
6 - - -
7 VIDEOGRAPHER: We're on the video record.
8 This is the 10th day of November, the year 2009.
9 The time is approximately 11:13 a.m.
10 This is the videotaped deposition of
11 in the matter of III., Plaintiff, versus
12 Epstein, Defendant.
13 This deposition is being held at 250 South
14 Australian Avenue, West Palm Beach, Florida.
15 My name is Michael Downey. I'm the
16 videographer, employed by Visual Evidence.
17 Would the attorneys please announce their
18 appearances for the record.
19 MR. Yes. , on behalf of
20 Plaintiff III.
21 MR. on behalf of
22 Plaintiffs
23 MR. on behalf of
24 •
25 MR. CRITTON: Robert Critton, on behalf of
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401-377476-2895)
Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075
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1 Jeffrey Epstein.
2 MS. and
3 here on behalf of witness,
4 THEREUPON,
6 having been first duly sworn or affirmed, was examined
7 and testified as follows:
8 THE WITNESS: So help me God.
9 MR. CRITTON: Let me just note one thing for
10 the record, is -- it's been -- this case for this
11 depo has been noticed both in the State Court case.
12 It's been noticed as well -- cross noticed by at
13 least on behalf of his clients two
14 through eight in the Federal Court case. The only
15 two lawyers who apparently are not here, but they
16 obviously have notice of it. And Mr. didn't
17 notice it, but obviously he's -- cross notice, but
18 he's here -- Mr. on behalf of his three
19 clients, and apparently Mr. Garcia chose, they
20 chose not to come for whatever reason, but they
21 would have received notice from everybody.
22 DIRECT EXAMINATION
23 BY MR.
24 Q. Good morning.
25 A. Morning.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401-377476-2895)
Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-56634dad-94e7-90ftb7174075
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Q. Just want to make sure he was done.
2 I introduced myself in the beginning, but my
3 name is . I represent one of the
4 Plaintiffs in a lawsuit filed against Mr. Epstein. And
5 I'm here today to ask you a bunch of questions.
6 As you saw at the beginning, you're under
7 oath. It's just like you're on the stand at trial,
8 except there's no Judge here in the room with us. So
9 when I ask you questions, just give it a breath for a
10 minute because there may be objections for other lawyers
11 in the room.
12 Since there's not a Judge here, nobody's going
13 to rule on those objections, so the lawyer has to put
14 that objection on the record. Just pause for a minute
15 and then if you understand the question, go ahead and
16 answer.
17 The only exception to that rule is, if your
18 two lawyers look at you and say, don't answer that
19 question. At that point I don't want you to say a word.
20 And then they lodge an objection and advise you not to
21 say anything. Okay?
22 A. Okay.
23 Q. If you do answer a question, there's two
24 things I'm going to assume. I'm going to assume that
25 you understood the question being asked and that you're
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663.4dad-94e7-90flb7174075
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1 answering truthfully. Fair enough?
2 A. Yes.
3 Q. If you don't understand any of my questions,
4 please let me know and I'll be happy to rephrase it
5 until you can understand it.
6 It's a nerve-racking procedure and I know
7 you're nervous. It's delving into very touchy areas, so
8 it's going to be delicate. I'm going to try and handle
9 it as respectfully and delicately as possible, but I am
10 going to have to ask a whole bunch of difficult
11 questions. Okay? Fair enough?
12 A. Understand.
13 Q. Okay. If you would, could you give us your
14 full name, please?
15 A.
16 Q. Where do you currently live?
17 A.
•
•
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401-377476-2895)
Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electron Gaily signed by Sandra Townsend (401.377-676.2895)
Elecironicaily signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94.7-90flb7174075
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e740ftb7174075
3501.182-102
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EFTA 00094360
EFTA01248020
(5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-Ne7-90ftb7174075
3501.182-102
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EFTA01248022
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94.7-90flb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401-377476-2895)
Electronically signed by Sandra Townsend (401-377476-2895) 1,88f113-5663-4dad-94e740ftb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90ftb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90flb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401-377476-2895)
Electronically signed by Sandra Townsend (401-377476-2895) 1038f113-5663-4dad-94e740ftb7174075
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90ftb7174075
3501.182-102
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90ftb7174075
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1,88f113-5663-4dad-94e740ftb7174075
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12 BY MR.
13 Q. When is the first time that you ever had any
14 contact with Jeffrey Epstein?
15 A. When?
16 Q. Yes. In other words, what grade were you in
17 or how old were you? However you can peg the time in
18 your mind.
19 A. About 16.
20 Q. So would you have been in about tenth grade at
21 that point?
22 A. Tenth going into my junior year, like, towards
23 the end, beginning of 11th.
24 Q. And how was it that you came to know who
25 Jeffrey Epstein was?
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90ftb7174075
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1 A. I was approached by a:
3 Q. At that point had you just turned 17?
4 A. No.
5 Q. You were still 16 at that point?
6 A. Yes.
7 Q. And III, is ill.?
8 A. I don't know.
9 Q. Okay. How did you know
10 all?
11 A. We went to middle school together, but we were
12 not friends.
15 Q. Do you know where she is today?
16 A. No.
17 Q. What were you doing at
19 A. I don't know.
20 Q. Well, is it a members only type of place?
21 A. No.
22 Q. Do you just --
23 MR. : Wait until he finishes his
24 question.
25 BY MR.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075
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Q. How do you get in there?
2 A. You walk in.
Q. Is there a charge to get into
S A. Not the day I met no.
6 Q. Had you been there before?
7 A. Yes.
8 Q. How many times had you been there before?
9 A. I can't recall.
10 Q. Was it a place that you went to regularly at
11 that point in your life?
12 A. Yes.
13 Q. Why would you go there?
14 A. To go swimming, listen to music.
15 Q. Okay. Can you describe
to me? I mean, are we talking about a club? Are
17 we talking about a -- somewhere just on the beach
18 somewhere? Are we talking about a bar? What is this
19 place?
20 A. is a tiki bar on the beach
21 or was at that point on the beach
22 had a bar. It had a restaurant. It had a pool. It was
23 a hotel room. I mean, they had hotel rooms available.
24 They had on Sundays live music.
25 Q. Okay. When you would go there in the past,
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94.7-90flb7174075
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1 would you go with friends?
2 A. Yes.
3 Q. Who?
4 A.
5 Q. Anyone else you can think of?
6 A. Not that I can think of.
7 Q. Would you go with or would you go with
8
9 A. Not . I did go with and at.
10 one point.
11 Q. Okay. When you would go to the beach
12 resort -- and I'm talking about the day before
13 III approaches you now.
14 A. Uh-huh.
15 Q. In the past when you would go there, is it a
16 place you would go just yourself and with friends of
17 would your parents take you there?
18 A. Usually a place that I would go with my
19 friends.
20 Q. Had your parents ever been there before that
21 day that you talked to
22 A. Yes.
23 Q. So they were familiar of the location and had
24 been there before?
25 A. Uh-huh, yes.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
Electronically signed by Sandra Townsend (401.377-676.2895) V8W113-56634dad4404WW17.WM
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1 Q. And they would also let you go to this place
2 alone?
3 A. With friends.
4 Q. How would you get there?
5 A. Drive.
6 Q. You?
7 A. Yes.
8 Q. So you would have -- you had a driver's
9 license at 16?
10 A. Yes.
11 Q. Just going back to what we had asked at the
12 beginning.
13 Did you have your own car?
14 A. Yes.
15 Q. What kind of car were you driving back then?
16 Was it the same pickup truck that you had later?
17 A. I don't remember.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075
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(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075
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15 Q. Okay. Once again, this is the period of time
16 before the day that approaches you about
17 Jeffrey Epstein. I just want to focus on that period of
18 time for right now.
19 When you would go to this
20 what was the main purpose of you going there; in other
21 words, why were you going?
22 A. To have fun.
23 Q. Go hang out on the beach, get a tan, hang out.
24 with friends?
25 A. Yes.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401477476-2895)
Electronically signed by Sandra Townsend (401477476-2895) 1f88f1134663-4dad-94e7-90ftb7174075
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(2• Would you ever drink there at the
2
3 MS. : Objection. I've already
4 instructed her not to answer this question. You're
5 just using this example as a back doorway into the
6 same question. We're still prior to her meeting
7 If you have a specific question
8 with regard to that day, please go ahead;
9 otherwise, it's the same objection.
10 MR. : Okay.
11 BY MR.
12 Q. When you would go to the
13 don't answer this because she's
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE No.502008CA037319XXXXMB AB
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
VIDEOTAPED DEPOSITION OF
VOLUME I
Tuesday, November 10, 2009
11:13 a.m. - 6:12 p.m.
250 S. Australian Avenue
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Sandra W. Townsend, FPR
PROSE COURT REPORTING AGENCY
Notary Public, State of Florida
West Palm Beach Office
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by Sandra Townsend (401.377-676.2895)
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1 APPEARANCES:
2 On behalf of the Plaintiff III.:
3
On behalf of Plaintiffs
On behalf of Plaintiff
U
U
•
•
•
18 On behalf of the Defendant:
19 ROBERT CRITTON, ESQUIRE
BURMAN, CRITTON, LUTTIER & COLEMAN
20 515 North Flagler Drive
Suite 400
21 West Palm Beach, Florida 33401
Phone: 561.842.2820
22
23
24
25
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1 On behalf of the Witness:
6
7 ALSO PRESENT:
8
MICHAEL DOWNEY, VIDEOGRAPHER
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1
2 EXHIBITS
3
4
NUMBER DESCRIPTION PAGE
5
6 Plaintiff:
7 Exhibit number 1 Notebook page 14
8 Exhibit number 2 Photograph 134
9 Exhibit number 3 Photograph 137
10 Exhibit number 4 Photograph 138
11 Exhibit number 5 Photograph 247
12
13 Defendant:
14 Exhibit number 1 Transcript 140
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1 PROCEEDINGS
2
3 Deposition taken before Sandra W. Townsend, Court
4 Reporter and Notary Public in and for the State of
5 Florida at Large, in the above cause.
6 - - -
7 VIDEOGRAPHER: We're on the video record.
8 This is the 10th day of November, the year 2009.
9 The time is approximately 11:13 a.m.
10 This is the videotaped deposition of
11 in the matter of III., Plaintiff, versus
12 Epstein, Defendant.
13 This deposition is being held at 250 South
14 Australian Avenue, West Palm Beach, Florida.
15 My name is Michael Downey. I'm the
16 videographer, employed by Visual Evidence.
17 Would the attorneys please announce their
18 appearances for the record.
19 MR. Yes. , on behalf of
20 Plaintiff III.
21 MR. on behalf of
22 Plaintiffs
23 MR. on behalf of
24 •
25 MR. CRITTON: Robert Critton, on behalf of
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1 Jeffrey Epstein.
2 MS. and
3 here on behalf of witness,
4 THEREUPON,
6 having been first duly sworn or affirmed, was examined
7 and testified as follows:
8 THE WITNESS: So help me God.
9 MR. CRITTON: Let me just note one thing for
10 the record, is -- it's been -- this case for this
11 depo has been noticed both in the State Court case.
12 It's been noticed as well -- cross noticed by at
13 least on behalf of his clients two
14 through eight in the Federal Court case. The only
15 two lawyers who apparently are not here, but they
16 obviously have notice of it. And Mr. didn't
17 notice it, but obviously he's -- cross notice, but
18 he's here -- Mr. on behalf of his three
19 clients, and apparently Mr. Garcia chose, they
20 chose not to come for whatever reason, but they
21 would have received notice from everybody.
22 DIRECT EXAMINATION
23 BY MR.
24 Q. Good morning.
25 A. Morning.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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Q. Just want to make sure he was done.
2 I introduced myself in the beginning, but my
3 name is . I represent one of the
4 Plaintiffs in a lawsuit filed against Mr. Epstein. And
5 I'm here today to ask you a bunch of questions.
6 As you saw at the beginning, you're under
7 oath. It's just like you're on the stand at trial,
8 except there's no Judge here in the room with us. So
9 when I ask you questions, just give it a breath for a
10 minute because there may be objections for other lawyers
11 in the room.
12 Since there's not a Judge here, nobody's going
13 to rule on those objections, so the lawyer has to put
14 that objection on the record. Just pause for a minute
15 and then if you understand the question, go ahead and
16 answer.
17 The only exception to that rule is, if your
18 two lawyers look at you and say, don't answer that
19 question. At that point I don't want you to say a word.
20 And then they lodge an objection and advise you not to
21 say anything. Okay?
22 A. Okay.
23 Q. If you do answer a question, there's two
24 things I'm going to assume. I'm going to assume that
25 you understood the question being asked and that you're
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1 answering truthfully. Fair enough?
2 A. Yes.
3 Q. If you don't understand any of my questions,
4 please let me know and I'll be happy to rephrase it
5 until you can understand it.
6 It's a nerve-racking procedure and I know
7 you're nervous. It's delving into very touchy areas, so
8 it's going to be delicate. I'm going to try and handle
9 it as respectfully and delicately as possible, but I am
10 going to have to ask a whole bunch of difficult
11 questions. Okay? Fair enough?
12 A. Understand.
13 Q. Okay. If you would, could you give us your
14 full name, please?
15 A.
16 Q. Where do you currently live?
17 A.
•
•
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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12 BY MR.
13 Q. When is the first time that you ever had any
14 contact with Jeffrey Epstein?
15 A. When?
16 Q. Yes. In other words, what grade were you in
17 or how old were you? However you can peg the time in
18 your mind.
19 A. About 16.
20 Q. So would you have been in about tenth grade at
21 that point?
22 A. Tenth going into my junior year, like, towards
23 the end, beginning of 11th.
24 Q. And how was it that you came to know who
25 Jeffrey Epstein was?
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1 A. I was approached by a:
3 Q. At that point had you just turned 17?
4 A. No.
5 Q. You were still 16 at that point?
6 A. Yes.
7 Q. And III, is ill.?
8 A. I don't know.
9 Q. Okay. How did you know
10 all?
11 A. We went to middle school together, but we were
12 not friends.
15 Q. Do you know where she is today?
16 A. No.
17 Q. What were you doing at
19 A. I don't know.
20 Q. Well, is it a members only type of place?
21 A. No.
22 Q. Do you just --
23 MR. : Wait until he finishes his
24 question.
25 BY MR.
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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Q. How do you get in there?
2 A. You walk in.
Q. Is there a charge to get into
S A. Not the day I met no.
6 Q. Had you been there before?
7 A. Yes.
8 Q. How many times had you been there before?
9 A. I can't recall.
10 Q. Was it a place that you went to regularly at
11 that point in your life?
12 A. Yes.
13 Q. Why would you go there?
14 A. To go swimming, listen to music.
15 Q. Okay. Can you describe
to me? I mean, are we talking about a club? Are
17 we talking about a -- somewhere just on the beach
18 somewhere? Are we talking about a bar? What is this
19 place?
20 A. is a tiki bar on the beach
21 or was at that point on the beach
22 had a bar. It had a restaurant. It had a pool. It was
23 a hotel room. I mean, they had hotel rooms available.
24 They had on Sundays live music.
25 Q. Okay. When you would go there in the past,
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
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1 would you go with friends?
2 A. Yes.
3 Q. Who?
4 A.
5 Q. Anyone else you can think of?
6 A. Not that I can think of.
7 Q. Would you go with or would you go with
8
9 A. Not . I did go with and at.
10 one point.
11 Q. Okay. When you would go to the beach
12 resort -- and I'm talking about the day before
13 III approaches you now.
14 A. Uh-huh.
15 Q. In the past when you would go there, is it a
16 place you would go just yourself and with friends of
17 would your parents take you there?
18 A. Usually a place that I would go with my
19 friends.
20 Q. Had your parents ever been there before that
21 day that you talked to
22 A. Yes.
23 Q. So they were familiar of the location and had
24 been there before?
25 A. Uh-huh, yes.
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1 Q. And they would also let you go to this place
2 alone?
3 A. With friends.
4 Q. How would you get there?
5 A. Drive.
6 Q. You?
7 A. Yes.
8 Q. So you would have -- you had a driver's
9 license at 16?
10 A. Yes.
11 Q. Just going back to what we had asked at the
12 beginning.
13 Did you have your own car?
14 A. Yes.
15 Q. What kind of car were you driving back then?
16 Was it the same pickup truck that you had later?
17 A. I don't remember.
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15 Q. Okay. Once again, this is the period of time
16 before the day that approaches you about
17 Jeffrey Epstein. I just want to focus on that period of
18 time for right now.
19 When you would go to this
20 what was the main purpose of you going there; in other
21 words, why were you going?
22 A. To have fun.
23 Q. Go hang out on the beach, get a tan, hang out.
24 with friends?
25 A. Yes.
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(2• Would you ever drink there at the
2
3 MS. : Objection. I've already
4 instructed her not to answer this question. You're
5 just using this example as a back doorway into the
6 same question. We're still prior to her meeting
7 If you have a specific question
8 with regard to that day, please go ahead;
9 otherwise, it's the same objection.
10 MR. : Okay.
11 BY MR.
12 Q. When you would go to the
13 don't answer this because she's