EFTA00770663.pdf

M., L. - Vol. September 29, 2009 Page 190 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 2 CASE NO. 502008CA028051XXXXMB AB 3 4 L.M., 5 Plaintiff, 6 -vs- VOLUME II OF II 7 JEFFREY EPSTEIN, 8 Defendant. / 9 10 11 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF L.M. 12 Thursday, September 24, 2009 13 9:40 - 5:52 p.m. 14 15 16 250 Australian Avenue South Suite 115 17 West Palm Beach, Florida 33401 18 19 20 Reported By: Cynthia Hopkins, RPR, FPR 21 Notary Public, State of Florida Prose Court Reporting 22 23 24 25 EFTA00770663 Page 191 APPEARANCES: 2 On behalf of the Plaintiff, L.M. and E.W.: 3 BRAD J. EDWARDS, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 4 401 East Las Olas Boulevard Suite 1650 5 Fort Lau 'da 33301 Phone: 6 E-mail: 7 On behalf of B.B.: 8 SPENCER T. KUVIN, ESQUIRE LEOPOLD KUVIN 9 2925 PGA Boulevard Suite 200 10 Palm Beach Gardens, Florida 33410 Phone: 11 12 On behalf of Jane Does 1 through 8: 13 ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 14 18205 Biscayne Boulevard Suite 2218 15 Miami, Florida 33160 Phone: 16 E-mail: 17 On behalf of Jane Does 101 and 102: 18 KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK 19 25 West Flagler Street Suite 800 20 Miami, Florida 33130 Phone: 21 22 23 24 25 EFTA00770664 Page 192 Appearances continued: 2 On behalf of the Defendant, Jeffrey Epstein: 3 ROBERT D. CRITTON, JR., ESQUIRE MARK T. LUTTIER, ESQUIRE 4 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard 5 Suite 400 West Palm Beach, Florida 33401 6 Phone: 7 On behalf of the Defendant, Jeffrey Epstein: 8 JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 9 250 Australian Avenue South Suite 1400 10 West Palm Beach, Florida 33401-5012 Phone: 11 12 13 ALSO PRESENT: Jeffrey Epstein, via video conference Michael Downey, Videographer 14 Stanley Sanders, Videographer Visual Evidence, Incorporated 15 16 17 18 19 20 21 22 23 24 25 EFTA00770665 Page 193 1 2 - - - 3 INDEX VOLUME II 4 - - - 5 6 WITNESS: DIRECT CROSS REDIRECT RECROSS 7 CONTINUED EXAMINATION OF 8 L.M. 9 BY MR. LUTTIER 194 10 11 - - - 12 EXHIBITS 13 - - - 14 NUMBER DESCRIPTION PAGE 15 DEFENDANT'S EX. 1 228 16 PLAINTIFF'S ANSWERS TO INTERROGATORIES 17 DEFENDANT'S EX. 2 270 PLAINTIFF'S UNVERIFIED BETTER ANSWERS TO 18 INTERROGATORIES 19 20 21 22 23 24 25 EFTA00770666 Page 194 1 PROCEEDINGS 2 3 CONTINUED DIRECT EXAMINATION 4 THE VIDEOGRAPHER: We're back on the video 5 record. The time is approximately 3:15 p.m. 6 BY MR. LUTTIER: 7 Q. Other than this woman K.G., is it your 8 testimony that you brought to Mr. Epstein other people 9 that were 12 years of age? 10 A. I have brought a couple girls over. 11 Q. Who? 12 A. I can't recall their name. 13 MR. EDWARDS: Speak up just because your 14 microphones is low. 15 BY MR. LUTTIER: 16 Q. Do you -- can you describe them? 17 A. One had brown hair. They were very petite. 18 Q. Any more description you have of them? 19 A. I know one of, the girl with the brown her, 20 her friend, she had told her friend about me. 21 Q. That is the brown haired girl told her friend 22 about you? 23 A. Yes. And she went. She was really petite. I 24 didn't need, I didn't, I didn't know, personally know 25 many of these girls. EFTA00770667 Page 195 1 Q. Well, how do you, how do you know, for 2 example, the girl with brown hair, how do you know what 3 her age was? 4 A. Because I knew at the time. 5 Q. What did you ask her? 6 A. Yeah, she was K.G.'s friend. 7 Q. So, what you would do is you would ask the 8 girls how old they were, and if they said they were 12, 9 you would take them to Mr. Epstein's; is that what you 10 are saying? 11 A. Yes. 12 Q. So you knew the age of every girl before you 13 took them? 14 A. Yes, pretty much. 15 Q. Did you tell Mr. Epstein when you took them, 16 by the way, this is someone that is 12 years old? 17 A. He asked them how old they were. 18 Q. How do you know that? 19 A. Because I was right there. 20 Q. You were present in the room when this brown 21 haired girl was there when Mr. Epstein asked her how old 22 she was; is that your testimony? 23 A. Yes. 24 Q. Prior to today have you ever told anybody 25 that? EFTA00770668 Page 196 1 MR. EDWARDS: Objection, attorney-client 2 privilege. 3 BY MR. LUTTIER: 4 Q. Other than your lawyer have you ever told 5 anybody that, what you just said? 6 A. Not that I recall. 7 Q. Why not? 8 A. No. 9 Q. That would be an important fact, wouldn't it? 10 MR. EDWARDS: Object to the form. 11 THE WITNESS: It's so illegal. 12 BY MR. LUTTIER: 13 Q. Didn't happen, did it? 14 A. Excuse me? 15 Q. You, you, you didn't take any 12-year-olds to 16 Mr. Epstein and tell them that they were, him that they 17 were 12 years old, did you? 18 A. I personally did not tell Jeffrey Epstein that 19 they were 12 years old, but he asked them how old they 20 were. 21 Q. In fact, what you did was you specifically 22 told everyone you took there, don't tell Mr. Epstein 23 that you're less than 18 years of age; isn't that right? 24 A. No, that's wrong. 25 Q. Did you ever tell anyone in the world other EFTA00770669 Page 197 1 than your lawyer that you instructed everyone that you 2 took there not to tell Mr. Epstein what their age was? 3 A. The last deposition I did take, I was in fear 4 for my son and in fear for me. I was afraid of Jeffrey, 5 of his power, of his money. And when Goldenberger 6 (phonetic), I don't know his last name, when one of his 7 attorneys, the guy with the lip came into my house and 8 sat on my couch, he said you know your son is involved, 9 right? You know you have a son and that could 10 jeopardize him. 11 MR. LUTTIER: Move to strike as not being 12 responsive to my question. Would you read my 13 question back, please. 14 (The requested portion of the record was read 15 by the reporter.) 16 MR. LUTTIER: That's a yes or a no. 17 THE WITNESS: Yes. 18 BY MR. LUTTIER: 19 Q. And you told that to people from the FBI, 20 right? 21 A. Yes. 22 Q. And you told that to them under oath, correct? 23 A. Yes. 24 Q. Now, you don't know the name of this 25 brown-haired girl that you claim told you she was 12, EFTA00770670 Page 198 1 right? 2 A. No. 3 Q. And you specifically asked her, you said to 4 her, how old are you. And she said I am 12 and you 5 said, oh, well, come get in the car and I am going to 6 take you to see Mr. Epstein; is that right? 7 A. I didn't say come get in the car, but, yeah. 8 Q. Well, did you have to convince her to go? 9 A. Yes. I had to convince all these girls. 10 Q. How many times did you have to convince her? 11 A. I had to convince all these girls. 12 Q. Well, where did you find them? Where did you 13 find a 12-year-old? 14 A. It was friend. 15 Q. Were you hanging around 12-year-olds back 16 then? 17 ■ A. No, they were in the neighborhood. I mean, 18 I hung out with.= yes. 19 Q. Well, was in the grade behind you, right? 20 A. I think a couple of grades behind me. 21 Q. So these are people from the mobile home park 22 where you lived? 23 A. No. They lived in Casa, Casa Delmonte. 24 Q. That's out at Forest Hill and Jog? 25 A. Yes. EFTA00770671 Page 199 1 Q. So, you went out and found 12-year-olds? 2 A. I found girls to bring. 3 Q. And took them to Mr. Epstein's? 4 A. Yes. 5 Q. But this person, by the way, you keep 6 referring to as 7 A. I couldn't tell you. 8 Q. No. Do you, do you have a last name anywhere? 9 A. I don't know. I never knew her last name. 10 Q. Okay. What did she tell you about revealing 11 your age to Mr. Epstein? 12 A. I was scared to reveal my age to Mr. Epstein. 13 Q. Not my question. What did she tell you? 14 A. I am getting to that. I was scared to reveal 15 my age to Mr. Epstein. She said it was okay. It 16 doesn't matter. It doesn't matter. And I was scared 17 because I knew it was illegal, so I told Jeffrey and I 18 told her that I was going to tell Jeffrey that I was 17 19 because it was closer to 18. 20 Q. My question was what did tell you to 21 tell Mr. Epstein about your age? 22 A. She said it didn't matter. 23 Q. That's your recollection of what she said? 24 A. Yes, she said -- I remember her saying it 25 doesn't matter. Don't worry about it. EFTA00770672 Page 200 1 Q. And have you ever told anyone ever anything 2 contrary to that statement; that is have you ever told 3 anyone that Carolyn told you something other than that 4 it didn't matter? 5 A. Yes. 6 Q. Who did you tell that to? 7 A. The last, the deposition. 8 Q. That would be the FBI you told? 9 A. Yes. 10 Q. And what you told the FBI was that 11 told you don't disclose your age, correct? 12 A. Yes. 13 Q. Did she tell you not to disclose your age or 14 did she tell yo 11 Mr. Epstein you were 18? 15 A. No. told me it doesn't matter. She 16 said it doesn't ma er how old you are. Let's just go. 17 Q. But you told the FBI what she said was don't 18 disclose your age to Mr. Epstein? 19 A. Correct. 20 Q. Or did you tell the FBI what she said was tell 21 him you're 18? 22 MR. EDWARDS: Objection, improper impeachment. 23 Why don't you show her the statement and refresh 24 your recollection. 25 EFTA00770673 Page 201 1 BY MR. LUTTIER: 2 Q. Which did you do? 3 A. I told I 4 Q. I am telling what did you tell the FBI? 5 A. I told the FBI -- I lied to the FBI. 6 Q. You did? 7 A. Yes. 8 Q. Do you make a habit of lying to the FBI? 9 A. No. 10 Q. Do you know it's a federal offense to lie to 11 the FBI? 12 A. Now I do, but when my, when I was, I think I 13 was 17, or when I was 19 when I took the deposition. 14 And I was in total fear that my son was going to get 15 tooken (sic) away from me. 16 Q. My question was did you lie to the FBI? 17 A. Yes. 18 Q. And you knew it was wrong to lie, didn't you? 19 Your parents probably -- you need to answer verbally. 20 You knew it was wrong to lie? 21 A. Yes. 22 Q. You were 19 years old, right? 23 A. Yes. 24 Q. Right, at the time? And you were already a 25 mother. You had a child, right? EFTA00770674 Page 202 1 A. Yes. 2 Q. And you were a woman of the world. I mean, 3 you had a child. You were out of school. You were off 4 doing your thing at that time, weren't you? 5 A. Yes. 6 Q. And you, you had familiarity with police 7 agencies before, hadn't you, at that time? 8 A. No. 9 MR. EDWARDS: Object to the form. 10 BY MR. LUTTIER: 11 Q. You had a few run-in's with the law earlier 12 because you had a few opportunities in your life prior 13 to having a statement that you gave to the FBI of your 14 involvement with law enforcement agencies, had you not? 15 MR. EDWARDS: Object to the form. 16 THE WITNESS: I, I don't understand what you 17 are saying. 18 BY MR. LUTTIER: 19 Q. You, you recall calling the cops for various 20 things before, haven't you? 21 A. Yes, I have. 22 Q. So you've had interaction with law enforcement 23 before you gave the statement to the FBI? 24 A. Yeah, and I know it's wrong to lie. 25 Q. And you knew the last person you wanted to lie EFTA00770675 Page 203 1 to is the FBI, right, or law enforcement? 2 A. When it comes to my son -- 3 Q. You knew the last person to lie to would be 4 the FBI, wouldn't you? 5 A. No, I did not know that. 6 Q. The FBI didn't threaten anything about your 7 son, did they? 8 A. No. 9 Q. They didn't threaten you -- 10 A. But Jeffrey's attorney did. 11 Q. They didn't threaten you with anything at all, 12 did they, the FBI? 13 A. No, Jeffrey's attorney did. 14 Q. Did the FBI threaten you in any manner 15 whatsoever? 16 A. No, Jeffrey's attorney did. 17 Q. We're going to get to that. 18 A. But you're throwing it off and you're totally 19 ignoring it. 20 Q. You're, you're claiming that the lawyer 21 representing you threatened you; is that what you are 22 telling us? 23 A. I don't know his specific name. And he -- I 24 don't know who he was exactly representing. I am not 25 knowledgeable about this whole court thing. I just know EFTA00770676 Page 204 1 he came to my trailer and he said, hey, Jeffrey got 2 caught. They found out that, you know, all these girls 3 were going to his house. And I was like, oh, my gosh. 4 Okay. So now what. And he is just like, well, I just 5 remember these exact words out of his mouth: He said, 6 well, just remember you have a little boy. 7 Q. This is something you are claiming now in this 8 lawsuit that the lawyer that represented you in your 9 statement to the FBI told you; is that right? 10 MR. EDWARDS: Objection to the form. 11 THE WITNESS: What is his name? Can you tell 12 me his name. 13 MR. LUTTIER: I believe his name is Eisenberg. 14 THE WITNESS: Eisenberg, with the lip. 15 MR. LUTTIER: I am assume he's got lips, but 16 he is your lawyer, not mine? 17 MR. EDWARDS: Objection to the form. 18 MR. LUTTIER: So, I just want to make sure 19 we're clear. 20 THE WITNESS: I was trying to save, I was 21 trying not to have my son be tooken (sic) away from 22 me. 23 BY MR. LUTTIER: 24 Q. That's not my question. You are telling us 25 under oath today that the lawyer that represented you at EFTA00770677 Page 205 1 the statements you gave the FBI threatened you; is that 2 right? 3 MR. EDWARDS: Objection to the form. And tell 4 him exactly what the lawyer said rather than use 5 the word threatened, unless the answer is you 6 threatened. 7 MR. CRITTON: Let's not testify. 8 THE WITNESS: He sat me down and he said, just 9 remember, you have a little boy and you know we 10 wouldn't want anything to happen there. You never 11 know what can happen. 12 So, as a mother, as any mother -- sorry -- as 13 any mother, I would do anything to protect my son. 14 So, I did lie to the FBI, and I did lie to many 15 people and said that Jeffrey didn't do anything. 16 BY MR. LUTTIER: 17 Q. And you lied to everybody until you filed this 18 lawsuit, right? 19 MR. EDWARDS: Objection to the form. 20 MR. LUTTIER: Is that right? 21 THE WITNESS: Correct. 22 BY MR. LUTTIER: 23 Q. And then since you the filed lawsuit, now 24 everything you say is the truth; is that right? 25 A. Correct. EFTA00770678 Page 206 1 Q. And before you filed the lawsuit, you had no 2 prospect, you had no thought of recovering money from 3 Mr. Epstein, right? 4 A. Before the lawsuit -- 5 Q. Before you filed this lawsuit, you didn't have 6 any idea that you would recover any kind of money from 7 Mr. Epstein, did you? 8 A. I, I don't really care about money. 9 Q. Okay. But once you filed the lawsuit you 10 understood that what you were doing is you were going to 11 sue Mr. Epstein and try to get money from him, right? 12 A. Actually at that time I understood that we 13 were going to, we're were doing this for justice, and I 14 didn't know I was going to get any money from it. 15 Q. Wh told you you were doing this for justice? 16 A. told me we're definitely going to do this 17 for justice, and I want to do this for justice, and that 18 I didn't know, I didn't know that we were going to get 19 money out of this. 20 Q. Have you 21 A. I am not knowledgeable on this stuff. 22 Q. So -- 23 A. Now, I found out that, yes, there is money 24 involved. 25 Q. You, you didn't know that by filing a lawsuit EFTA00770679 Page 207 1 you were going to get money. That's what you are 2 telling the ladies and gentlemen of the jury, right? 3 A. Correct. 4 Q. Okay. And the first person that said anything 5 to you about anything in this lawsuit was that E.W. told 6 you that, that you were going to get justice by filing a 7 lawsuit? 8 A. Yes, because he was supposed to go to jail for 9 only 18 months or something, and that's ridiculous. 10 Q. Was she the one that came to you and told you 11 about filing a lawsuit? 12 A. No. I walked into her house one day and I saw 13 a calendar on a desk that said Jeffrey Epstein is going 14 to jail. And I said, why do you, why are you -- I 15 started like why are you even concerned about Jeffrey 16 right now. And she's like, well, you don't understand. 17 There is like a huge, you know, lawsuit going against 18 him. There is a huge, there is a whole bunch of 19 attorneys and this guy is in big trouble. And I was 20 like, oh, really. And I was like, well, what is going 21 on. 22 And we talked about it. And when we got to 23 talking, it kind of hit a spot in my heart that, that, 24 it hit a spot that he really did mess us up mentally and 25 our future. So, I said, wow, we do need to do something EFTA00770680 Page 208 1 about this. 2 Q. And about what date was this that this 3 A. Oh, God. 4 Q. -- this meeting happened at 's house? 5 A. I don't, I don't know. 6 Q. What year? 7 A. Maybe -- well, I contacted Brad Edwards maybe 8 like a month after that, so whenever that date was. 9 Q. Do you remember when -- I assume after you 10 contacted Brad Edwards, you retained him to represent 11 you? 12 A. Yes. 13 Q. Do you know approximately when you retained 14 Mr. Edwards to represent you? 15 A. No, I don't recall the date. 16 Q. What year? 17 A. Maybe early '08. I don't know though. 18 Q. Okay. And, and at that time was he already 19 representing IIII[ 20 A. Yes. 21 Q. Is that how you got to him? 22 A. Yes. 23 Q. Now, let me go back to the meeting with E.W. 24 This is a meeting that happens at her house that you've 25 described? EFTA00770681 Page 209 1 A. Yes. It wasn't a called meeting, but it was a 2 discussion. 3 Q. Why were you going to her house on that 4 occasion? 5 A. Oh, I know I haven't saw her in a while, so I 6 think I was just kind of like, you know, going there and 7 reuniting with her in a way and seeing how life was. 8 Q. Had you maintained contact with her? 9 A. I have a family, sir. I don't really maintain 10 contact with any of my friends like really close 11 anymore. I just -- we talk once in a blue moon. 12 Q. I am talking about back then when you went to 13 see Let's see if we can figure out what year was 14 this. 15 A. It wasn't too long ago. 16 Q. You said you saw something on calendar? 17 A. I walked in and she was showing me her house. 18 Q. Okay. And her house was where? 19 A. On Fern, Fern, Fern, Fernly (phonetic). I 20 don't know. It's in Canvas States (phonetic). 21 Q. What did you say? 22 A. Canvas States. 23 Q. Can -- Canvas? Where is that? 24 A. I don't know how to spell that. I don't 25 even -- EFTA00770682 Page 210 1 Q. What part? Is it West Palm? 2 A. West Palm Beach. 3 Q. Whereabouts, west, east? 4 A. It's actually next to Drexel Road. 5 Q. Oh, out near where your mobile home park is? 6 A. Yeah. 7 Q. Okay. All right. So you walk in her house? 8 A. Yeah, her and her boyfriend moved in together, 9 and maybe that's why I was there, to see the new house. 10 They were renting a new house and they were excited 11 about it. So I went there. And I remember she was 12 showing me her little office area because she was 13 cleaning at the time. 14 And I looked down and there was a big, you 15 know, one of those calendars that sit on a desk. There 16 was that and in a big square it said Jeffrey Epstein 17 went to jail. 18 Q. So, this was, apparently this meeting is 19 sometime after Mr. Epstein is sentenced? 20 A. I think so, yeah, because it said Jeffrey went 21 to jail. It might have said goes to jail. 22 Q. Now -- 23 A. So I don't know. 24 Q. -- at that point in time, you -- I mean you 25 read the newspaper, right? EFTA00770683 Page 211 1 A. No. 2 Q. You never read the newspaper? 3 A. No. 4 Q. Did you know what was going on? 5 A. No, sir. I don't watch TV or read the 6 newspaper. 7 Q. You had already been interviewed by the FBI, 8 by then hadn't you? 9 A. Yeah, but they've never, they didn't contact 10 me after. 11 Q. So, you get interviewed by the FBI. And by 12 the way you had called Mr. Epstein to let him know that 13 the police were contacting you to ask you questions, did 14 you not? 15 A. I called him? 16 Q. You, you remember that, don't you? You 17 remember a police agency calling you and you telling 18 them that you didn't want to talk to them. And you 19 picked up the phone and called Mr. Ep -- Epstein to let 20 him know that the cops were asking questions, didn't 21 you? 22 A. I called Sarah. 23 MR. LUTTIER: Not my question. All right. 24 Strike that. 25 EFTA00770684 Page 212 1 BY MR. LUTTIER: 2 Q. So you called Sarah. You called Sarah to tell 3 her what? 4 A. I called Sarah afterwards. No, excuse me. I 5 called Sarah when people started coming to my doors and 6 saying something about Jeffrey. And I was, I am pretty 7 sure it was after, after I had a deposition. And I did 8 talk to Sarah and I said, hey, are these people, I 9 didn't want to get in trouble. I was scared. And I 10 wanted to be on Jeffrey's side because I was scared. 11 And I said, are these people okay to talk to. 12 Am I -- you know, is everything okay? And she is like, 13 yeah, yeah, you can talk to them. 14 Q. As a matter of fact the reason why you wanted 15 to be on Jeffrey's side was you thought he was a nice 16 guy, didn't you? 17 A. No, I didn't think he was a nice guy. 18 Q. You told people he was a nice guy, didn't you? 19 A. The only reason I would ever tell anybody that 20 Jeffrey is a nice guy is if I was bringing a girl there 21 to make money and that makes plenty of sense. 22 Q. Did you tell people that Jeffrey was a nice 23 guy? 24 A. Yes. 25 Q. Did you tell them that he was respectful? EFTA00770685 Page 213 1 MR. EDWARDS: Object to the form. Are you 2 asking did she tell him that? 3 MR. LUTTIER: No, anybody. 4 BY MR. LUTTIER: 5 Q. Did you tell anybody that Jeffrey was 6 respectful? 7 A. I've told that in my deposition. 8 Q. When you say deposition, are you talking about 9 you told the FBI that under oath, right? 10 A. Yes. 11 Q. Okay. Now, you were contacted by the Palm 12 Beach Police Department, were you not? 13 A. I don't recall. I mean -- 14 Q. And you said you told them you wouldn't talk 15 to them, didn't you? 16 A. Probably. 17 Q. And then you called and told her that 18 the Palm Beach Police Department had called you asking 19 questions about Jeff, didn't you? 20 A. Yes, now -- 21 Q. Because you wanted him to know that the cops 22 were asking questions? 23 A. Yes, yes, true. 24 Q. You didn't want him to get in any trouble, did 25 you? EFTA00770686 Page 214 1 A. I was cared. 2 Q. And you told the FBI, as a matter of fact, 3 that you thought it was unjust that anybody would punish 4 Mr. Epstein, didn't you? 5 A. I said that but it was a lie. 6 Q. Okay. Well, we'll get to that. We'll come 7 back to that. 8 A. Okay. 9 Q. So, you at least knew before you went to see 10 E.W. that the Palm Beach Police Department had called 11 you, that you had given a sworn statement to the FBI, 12 you -- and you had a conversation with And you 13 are telling the ladies and gentlemen of the jury that 14 you didn't follow in the news at all, whether it was on 15 the news or on the Internet or in the newspaper, what 16 was going on in Mr. Epstein's case? 17 A. True, I did not. I saw his articles when he 18 did go to jail when it said that he only received 18 19 months or something. That was because E.W. did have it. 20 Other than that, I personally don't watch any TV or read 21 the newspaper, or follow-up on anything. 22 Q. So you -- 23 A. Like, I don't even watch it now. 24 Q. So, you go over tol and the time that 25 you went to her house when yol ooking at it that EFTA00770687 Page 215 1 you have described, had she already been to Mr. Edwards 2 by then? 3 A. Yes. 4 Q. So, at that meeting that you had in her house 5 on this occasion, is that when she told you about 6 Mr. Edwards and the fact that she had filed suit? 7 A. Yes. 8 Q. And what did she tell you about having filed 9 that suit? 10 A. Well, when we were having the discussion about 11 Jeffrey, she pretty much told me that, you know, this 12 has really messed me up. And we have lived a life of 13 lies and that there needs to be justice served because 14 if this was any regular person on the street that owned 15 a regular house and was walking in regular shoes, then 16 they would have been in jail way longer. 17 Q. And what -- 18 A. So -- 19 Q. -- did she say about recovering money? 20 A. We didn't, we didn't say anything about money. 21 Q. When you went to see Mr. Edwards, you signed 22 some kind of fee agreement? 23 MR. EDWARDS: Object to the form. We're 24 talking about a different lawsuit. She's talking 25 about one lawsuit. You're talking about a lawsuit EFTA00770688 Page 216 1 against Jeffrey Epstein. She's talking about a 2 lawsuit against the United States of America. Two 3 different things. 4 MR. LUTTIER: Let me go back. 5 MR. EDWARDS: So, so the wires are crossed 6 here. 7 BY MR. LUTTIER: 8 Q. The lawsuit that E.W. was talking about was 9 the lawsuit she had filed against Jeffrey Epstein. 10 A. I don't know what E.W. specifically filed. I 11 have heard from her mouth she said that I am going to 12 court on behalf, I have an attorney on behalf of Jeffrey 13 Epstein. 14 Q. On behalf of Jeffrey Epstein or against? 15 A. See, I don't even know these words. On -- 16 against Jeffrey Epstein. 17 Q. And that attorney was Brad Edwards? 18 A. Yes. 19 Q. And that's why you went to Brad Edwards? 20 A. Yes. 21 Q. And when you went to Brad Edwards and retained 22 him, you signed a fee agreement, correct? 23 A. I signed -- I don't know if I signed a fee 24 agreement. 25 Q. Well, what's your arrangement with him in EFTA00770689 Page 217 1 terms of getting, paying his attorney's fees in this 2 case. 3 MR. EDWARDS: Object to the form. And I'm, I 4 am going to ask the witness not to answer this 5 question only because if we're talking about the 6 lawsuit against Jeffrey Epstein, she can answer as 7 to the fee arrangement. But if you're talking 8 about the time where L.M. signed, signed up with me 9 initially -- 10 MR. LUTTIER: Don't give me, don't give me a 11 speaking objection. I know what you're saying. I 12 will clarify that. 13 MR. EDWARDS: -- we're talking about a 14 different lawsuit. 15 MR. LUTTIER: I understand. 16 BY MR. LUTTIER: 17 0. Do you have a fee -- you have a fee agreement 18 with Mr., Mr. Edwards in this case, right? 19 A. Yes. 20 Q. And it's a percentage. What's called a 21 contingency fee, correct? 22 A. I don't know. 23 Q. Are you going to tell, are you going to tell 24 the ladies and gentlemen of the jury now you don't know 25 if you, if you agreed to pay Mr. Edwards a percentage of EFTA00770690 Page 218 1 what you recover as his fee? 2 A. Yeah, in general -- 3 MR. EDWARDS: I am going to object, 4 attorney-client privilege. 5 THE WITNESS: Yeah, that's what happens. 6 MR. EDWARDS: Don't answer. I am going to 7 object to this as all attorney-client privilege. 8 MR. LUTTIER: Well, she's already answered so. 9 BY MR. LUTTIER: 10 Q. So, you understand what you are doing in this 11 lawsuit is you are suing to recover money, right? 12 A. Sir -- 13 Q. Is that right? 14 A. I want justice. 15 Q. Yes or no. No, what you want is money. 16 A. No. 17 Q. That's what you want. 18 A. No. 19 Q. So if you -- 20 MR. EDWARDS: Objection, argumentative. 21 BY MR. LUTTIER: 22 Q. If you get a zero in this case and the jury 23 just comes back and says Mr. Epstein shouldn't have done 24 what he did, you will feel like you got justice, and 25 that's all you want, right? EFTA00770691 Page 219 1 A. You know what, you damn right. 2 Q. Okay. So you don't want money in this case, 3 is that right? 4 A. Oh, it would help gratefully. But you know 5 what, I am in here for justice. I am not like you. I 6 am not defending a sex offender for money, no. 7 Q. You don't want money then? 8 A. Doesn't every, anybody want money? 9 Q. Right. So you are sue -- 10 A. Are you, are you acting like I am in this for 11 the money? 12 Q. Ma'am, you are suing to recover money in this 13 case, are you not? 14 MR. EDWARDS: Object to the form, asked and 15 answered, argumentative. 16 BY MR. LUTTIER: 17 Q. Right? Yes or no. 18 A. I'm not going to answer this because it's 19 ridiculous. I want justice. 20 Q. Well, what do you call justice? 21 A. He needs time in jail. He doesn't want to 22 be -- this is not right for him to be on the streets 23 living daily -- 24 Q. So that's all you want -- 25 because he is going to do it again to many EFTA00770692 Page 220 1 other daughters. 2 Q. So, that's all you want is what you have now 3 described as justice, right? 4 A. Yeah. 5 Q. Now, has anybody explained to you that that's 6 not a possible outcome of this case, that Jeffrey 7 Epstein is not going to go to jail because of this 8 lawsuit? 9 A. Oh, God. 10 MR. EDWARDS: Object to the form, attorney 11 client-privilege. And I don't want you to answer 12 this line of questioning that obviously deals with 13 conversations between myself and yours. 14 BY MR. LUTTIER: 15 Q. Don't tell me about anything that you have had 16 a conversation with your lawyer. But has anybody 17 explained to you that there is no possibility that an 18 outcome of this lawsuit will be that Jeffrey Epstein 19 will go to jail? 20 A. Can you say that again? 21 Q. Has anybody explained to you that it is not 22 possible for the outcome of this lawsuit to be that 23 Jeffrey Epstein goes to jail? 24 A. No. 25 Q. Do you think that that's what is going to EFTA00770693 Page 221 1 happen in this lawsuit is that if you prevail Jeffrey 2 Epstein is going to go to jail? 3 A. I would hope so. 4 Q. So, so that's all you want in this lawsuit, 5 right? 6 A. You know what, you're asking like -- 7 Q. Just a yes or no. 8 A. -- stupid questions. 9 Q. Do you understand my question? 10 MR. LUTTIER: Would you read the question back 11 to her. 12 (The requested portion of the record was read 13 by the reporter.) 14 BY MR. LUTTIER: 15 Q. So, you don't seek money or money in this 16 case? 17 A. Actually, after all this time and suffering, I 18 would love some money. 19 Q. Oh, so it's now just changed just in the five 20 minutes we have had this discussion, you have now 21 changed. 22 A. You made me realize that after all this, sure, 23 I would love some money. 24 Q. And that wasn't a realization that you just 25 came to. The day you filed this lawsuit, that's what EFTA00770694 Page 222 1 you wanted was money? 2 A. No, I didn't give a damn about no money. 3 Q. All right. So that just came -- 4 A. You don't think that Jeffrey damaged me at 5 all? My whole life I was in prostitution because he 6 brought me into it because he showed me and taught me 7 how to do it? You don't think my whole life I have 8 lived that shitty life because of Jeffrey Epstein? 9 Q. Ma'am, I don't -- it would be inappropriate 10 for me to answer that question, so I will decline to 11 answer the question. 12 A. Yeah, because you know it's true. 13 Q. But you just changed your mind and decided 14 right here today that now you want money; is that right? 15 A. Yes. 16 Q. Okay. And when you had this conversation with 17 E.W., did you discuss that, that the possibility existed 18 to recover money? 19 A. We didn't talk about money, sir. I told you 20 this five times: We did not talk about money 21 Q. What else did you discuss with E.W. about 22 filing a lawsuit? 23 A. That Jeffrey Epstein is going to get justice, 24 that we're going to get justice from him. That's all we 25 talked about. We talked about our past, how messed up EFTA00770695 Page 223 1 it was because of him, what he introduced us to. We 2 cried together about the things that we used to do with 3 him. That's what our discussion was about. 4 Q. And you never cried about the things that you 5 did with him until after E.W. and you filed lawsuits 6 against him; is that right? 7 A. Excuse me? 8 Q. You never had these discussions or cried about 9 the things that you did with him until you-all filed 10 these lawsuits? 11 A. Yes, of course we did. 12 Q. You mentioned earlier that you had gone to 13 some psychiatrists? 14 A. Yeah. 15 Q. What's the name of every psychiatrist that you 16 have gone to? 17 A. I saw Amy Swan one time. 18 Q. Who -- and where is Amy Swan? 19 A. I saw Amy Swan one time and that was I just 20 filled out papers. 21 Q. Where is Amy Swan located? 22 A. I don't know. She came to me. 23 Q. Came to you from where? 24 A. I don't know, sir. I didn't ask her where she 25 lived. EFTA00770696 Page 224 1 Q. Did you find it a little strange that a -- is 2 she a psychologist or psychiatrist? 3 A. I don't know, sir. 4 Q. Did she tell you what she was? 5 A. Sir, they sound the same to me. 6 Q. Do you have a habit of just talking to 7 people -- 8 A. I just care -- 9 Q. -- before -- 10 A. -- for taking care of my son and like going to 11 school. 12 Q. Where did she come to see you? 13 A. She came to see me at my house and I went to 14 her to an office, it wasn't even hers, on Clematis 15 Street. We saw each other two different times. One, 16 like -- in two consecutive dates. 17 Q. And when was that? 18 A. Like a couple of months ago. 19 Q. And for what reason did you go to her? 20 A. To evaluate psychological things for the 21 Jeffrey Epstein case. 22 Q. So, you went to her for this lawsuit, that's 23 why you went to her? 24 MR. EDWARDS: Object to the form, 25 argumentative. EFTA00770697 Page 225 1 MR. LUTTIER: Correct? 2 THE WITNESS: I went for her, I went to her 3 for psychiatrist's help. 4 BY MR. LUTTIER: 5 Q. For this lawsuit? 6 A. Yes. 7 Q. You, you had -- you didn't get any treatment 8 from her, did you? 9 MR. EDWARDS: Object to the form. 10 THE WITNESS: That's what I initially went 11 there for was for treatment. 12 BY MR. LUTTIER: 13 Q. Have you ever received any treatment from her? 14 A. Yeah, for two days we went through 15 psychological -- 16 Q. That was an evaluation, right? You never went 17 to psychotherapy with her or anything like that, right? 18 A. We talked. 19 Q. So, this was someone your lawyer sent you to, 20 wasn't it? Let's be honest. 21 A. Okay. Let's be honest. 22 Q. Did your lawyer send? 23 A. Yeah, jackass. You're a fucking asshole. 24 Q. Okay. 25 A. You are. EFTA00770698 Page 226 1 Q. So your lawyer sent you to this Amy Swan. Is 2 that the first psychologist or psychiatrist that you 3 went to see? 4 A. No. s Q. Who was the first one you went to see? 6 A. Her name is -- 7 THE WITNESS: What was her name, Jerry? Can 8 you talk to me or you're not allowed to talk to me? 9 I don't know her name. 10 BY MR. LUTTIER: 11 Q. Another person your lawyer sent you to? 12 MR. EDWARDS: Objection, attorney-client 13 privilege. 14 THE WITNESS: No. 15 MR. EDWARDS: Do not answer. 16 THE WITNESS: He did not send me. 17 BY MR. LUTTIER: 18 Q. Who sent you to this Jerry person? 19 A. My -- E.W. was seeing her and said that she 20 was really good and that helped her out. 21 Q. When did you go see this Jerry person? 22 A. Over nine months ago, I think. Just about 23 nine months ago. 24 Q. And where did you go see her? 25 A. At the courthouse. EFTA00770699 Page 227 1 Q. At the courthouse? 2 A. Yeah. She had an office in the courthouse. 3 Q. Is this someone with Victim's Services? 4 A. Yeah, I think so. 5 Q. How many times did you go to her? 6 A. Three. 7 Q. And, and she didn't render any treatment to 8 you, did she? 9 A. No. 10 Q. And likewise Amy Swan didn't render any 11 treatment to you, correct? 12 MR. EDWARDS: Objection to the form. 13 THE WITNESS: Not yet. 14 BY MR. LUTTIER: 15 Q. And do you know Jerry's last name? 16