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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 IV OF IV
JEFFREY EPSTEIN
AND
Defendants.
VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF
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
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EFTA01108851
EFTA01108852
Page 503 Page 505
1 APPEARANCES: 1 PROCEEDINGS
2 On behalf of the Plaintiff. and Jane
3 BRAD J. EDWARDS.
DDe .
2
FARMER, JAFFE, WE/SSING, EDWARDS 3 THE VIDEOGRAPHER: We're back on the
I,PJ02MAt4. PL
record at 1:48 p.m.
5 BY MR. LUTHER:
6 Q. Okay, Ma'am. I want to add that during
7 On behalf o the Jeffrey Epstein: 7 the morning session, I was asking you some
3 ROBERT D. CRITTON,11t, P8QUIRE 8 questions. I just want to go over a couple of
MARK T. tura ESQUIRE
9 R • wt ft* LLITTIER & COLEMAN, ELP 9 things. One of the first things I asked you this
10 morning is whether you understood you were under
11 oath today. And you indicated you did understand
12 that?
12 On o the a r: ant, ;army Epstein: 13 A. Correct.
13 JACK ALAN GOLDBERGER. ESQUIRE
• R & WEISS, PA. 14 Q. Are you, did you, are you aware of the
14 15 fact that it is a crime known as perjury to make a
16 false statement under oath?
17 A. Correct.
16 18 Q. Are you also aware that it is a separate
17
18 ALSO PRESENT. kffrey Epstein, via video conference 19 crime, a federal crime to make a false statement to
4/”.ney, Videogmpber
Daniel C1 20 an FBI agent?
19 Visual Evidence, Incorporated 21 A. Correct.
20
21 22 Q. And you've already admitted that you
22 23 committed that federal crime; you lied to the FBI,
23
24 24 according to you.
25 25 A. I was in fear of my sorts life, correct.
Page 504 Page 506
1 1 Q. Now, l want to ask you one more time: Is
2 INDEX VOLUME I 2 there anything you want to correct about any of your
3
3 testimony this morning, especially as it relates to
4
5 "NESS: DIRECT CROSS REDIRECT RECROSS 4 working in places of employment that you have termed
5 5 to be jack shacks at or about or near Speannim
7 6 Rhino?
BY MR. LUTHER 4 7 A. Correct. I'm fine on that
8 8
9
Q. Okay. Isn't it a fact that on Saturday,
10 9 January 30th, you went to Spearmint Rhino's?
11 EXHIBITS 10 A. Yes.
12 11 Q. And you got there, what time, around 8:00?
13 2 A. Yes.
14 EXHIBIT DESCRIPTION PAGE
15 DEFENDANT'S NO.3
13 Q. And then at some point in time you la
Photo of Fantasies of Palm Beach 512 14 Spearmint Rhino's, did you not?
16 15 A. Yes.
DEFENDANTS NO. 4 518 16 Q. And you went to a place called Fantasies
17 Photo of Demon's Motorcycle ad 17 of Palm Beach, did you not?
18 DEFENDANTS NO. 5 634
•' unction for
18 A. Not that I recall. I don't know a name
19 19 Fantasies.
20 DEFENDANTS NO. 6 618 20 Q. Well, Fantasies of Palm Beach would be the
tinctice for 21 facility that's located right next door to Spearmint
21 22 Rhino's. You're familiar with that, aren't you?
22
23 23 A. I thought that was affiliated with Spearmint
24 24 Rhino.
25 25 Q. Well, so that we 'mow -
2 (Pages 503 to 506)
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EFTA01108853
Page 507 Page 509
1 (Cellphone interngtion.) 1 located, I believe it's to the left side of
2 THE WITNESS: Oh, Pm sorry, my phone. 2 Spearmint Rhino's as you look at it. It's got a
3 MR. Lill-TIER: Sure. Oo ahead. 3 separate entrance. It's got neon signs on it?
4 THE WITNESS: Okay. Sorry. 4 A. Okay.
5 BY MR. LUTHER: 5 Q. And it's known as Fantasies of Palm Beach.
6 Q. There is a — whether or not ifs 6 You're aware of that place, aren't you?
7 affiliated with Spearmint Rhino, I don't know. When 7 MR. EDWARDS: Fan
8 you referred to your testimony this morning that you 8 THE WITNESS: I'm not aware of any name.
9 didn't go anyplace other than Spearmint Rhinos and 9 BY MR. LUTTIER:
10 places affiliated did, with it, did you mean to 10 Q. Well, you were in the establishment known
11 include in those places that you went Fantasies of 11 as Fantasies of Palm Beach on the evening of
12 Palm Beach? 12 Saturday, January 30th, 2010, were you not?
13 A. I personally never heard of Fantasies of Palm 13 MR. EDWARDS: Font.
14 Beach, but I know that, there, that Spearmint Rhino has 14 THE WITNESS: If that's what it's called,
15 a couple places affiliated with them. 15 then, yes. But, as long, as far as I know,
16 Q. What places do they have that are 16 Spearmint Rhino, that's the name I know it as
17 affiliated with them? 17 you know.
18 A. The back and then there's an entrance to 18 BY MR. LUTTIER:
19 another place. That's all ! know. 19 Q. Well, this is a place that has a separate
20 Q. Well, tell me about this entrance to 20 entrance. You don't go through the entrance of
21 another place. What are you talking about? 21 Spearmint Rhino. You go into a separate entrance
22 A. Well, in the back of Spearmint Rhino there is 22 for a place called Fantasies of Palm Beach.
23 a little section that the dancers I don't know 23 A. Well -
24 exactly what they do there, but that's where I do sell 24 Q. I want to make sure we're real clear here
25 shoes and my lingerie. 25 we're not playing semantics.
Page 508 Page 510
1 And then there is another entrance that 1 A. We're not playing what?
2 you can go through and then there is another it's 2 Q. Semantics.
3 like there's, I know that there's, there's a lot of 3 A. Okay.
4 doors. I don't know what they consist of. 1 don't 4 MR. CRITTON: Word games.
know what they do there, but I know that they are 5 THE WITNESS: Oh.
6 affiliated, I thought that they were affiliated with 6 MR. LUTTIER: All right?
7 Spearmint Rhino, and that's where I also go to sell 7 THE WITNESS: Yeah.
8 my shoes and ptuses. 8 BY MR. LUTTIER:
9 Q. Okay. Well, you talked about a place in 9 Q. And, and you were, in fact, in this place
10 the back of Spearmint Rhino's that you gain access 10 called Fantasies of Palm Beach on Saturday, January
11 to by going through the Spearmint Rhino 11 30th, 2010, were you not?
12 establishment? 12 MR. EDWARDS: Object to the form.
13 A. Yes. 13 THE WITNESS: I definitely walked through
14 Q. All right. Now, what is this second place 14 an entrance and that I thought was affiliated
15 that you are talking about that you say is 15 with Spearmint Rhino.
16 affiliated with Spearmint Rhino's? 16 BY MR. LUTTIER:
17 A. Well, you can either go through out the back 17 Q. And there's a black female in there that
18 door of Spearmint Rhino and take a right, and then there 18 works at the front desk, is there not? There was on
19 is a place there that's affiliated with them. 19 Saturday night.
20 Q. Is there a name? Is there a separate 20 A. Oh, I don't know. I don't know who works
21 entrance to the place? 21 there. I don't blow.
22 A. 1— they're connected. 22 Q. And the --
23 Q. Is there a separate name on this place? 23 A. I just know that I go into Speannint Rhino and
24 A. Not that I know of 24 I sell my —
25 Q. Okay. I'm tallthsabout a place that's 25 Q. And —
4,1 J
3 (Pages 507 to 510)
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EFTA01108854
Page 511. Page 513
— items. 1 A. No. I say to the girls, my name is Lynn and
2 the name that you're known as is 2 they know that I sell all of my, all of my clothes and
3 isn't that right? 3 lingerie and shoes and everything else I sell.
4 A- I'm not known as 4 Q. But there is no doubt that now that you
5 Q. That's the name you -- remember we were 5 have seen this picture, you were in that
6 asking you about the cards you used to use? 6 establishment that is depicted on Exhibit No. 3 on
A. Yeah, I was known as =in '07 and '08. 7 January 30th, right?
8 O. that's the name you've used in the past 8 A. Correct.
9 is 9 Q. And you drive a white Mitsubishi Gallant;
10 A. Yes. 10 is that right?
11 Q. And in fact on Saturday, January 30th, you 11 A. Yes.
12 were working in Fantasies of Palm Beach which was. i2 Q. License plate number is 193HV; is that
13 to use your terms, a jack shack, were you not? 13 correct.
14 A. No, I was not working there. 14 A. I don't know my license plate number, but 1
15 Q. And you were charging $120 fora half hour 15 definitely drive a white Mitsubishi Gallant
16 to perform services; isn't that right? 16 Q. And is, was that vehicle parked outside
17 A. No. 17 Fantasies of the Palm Beach on Saturday night,
18 Q. Andacame out and told somebody your 18 January the 30th?
19 name was Mend that that was your charge, 19 A. Yes, but like I said before, from my
20 didn't you not? 20 knowledge, I thought this was affiliated with Spearmint
21 A. No, I did not. All I do is sell shoes and 21 Rhino.
22 purses there. 22 Q. And that car --
23 MR. LUTRER: Let me show you a picture 23 A. And they don't like me to park, they don't
24 here which we'll mark as, !guess we want to do 24 like me to park in front of Spearmint Rhino because
25 it in order. It will be Exhibit 3. 25 there are so many clientele that goes in and out. So
Page 512 Page 514
1 (Defendant's Exhibit No. 3 was marked for 1 they need as much parking space as they can.
2 identification.) 2 Q. And you stayed at Fantasies of Palm Beach
3 THE WITNESS: This place, yeah, ifs next 3 until what hour on the morning of Sunday which would
4 to Spearmint Rhino's. 4 be January 31st?
5 MR. LUTTTER: Hold on. Hold on. 5 A. I stayed until what time?
6 TI WITNESS: Sorry. 6 Q. Yeah, the morning until — what time on
7 BY MR. LUITLER: 7 the morning of Sunday, January 31st, did you leave?
8 Q. I have to ask you a couple of questions. 8 A. Well, Spearmint Rhino, I would go until
9 Do you recognize Exhibit 3? 9 closing like 5, 6. And then in the back of here, of
10 A. Yes, but what I would do, I would go out of 10 Spearmint Rhino, that's like, sometimes they have after
11 Spearmint Rhino from the back and go into the back 11 pa-ties there, something. This is what I hear from the,
12 entrance of Fantasies or whatever this place is called. 12 the manager at Spearmint Rhino. And like I said,
13 Q. So so, now upon seeing the picture, you 13 sometimes I stay there and I have a couple of drinks.
14 want to correct your testimony and say, in fact, you 14 And I'm not sure what time I left.
15 were in Fantasies of Palm Beach on Saturday? 15 Q. I don't want to know —
16 A. I, from my understanding, from my knowledge, I 16 A. As long as I keep on selling shoes and
17 thought that this place was owned by Spearmint Rhino. 17 lingerie, I'm the there.
18 Q. All right. The place of business that's 18 Q. I am not asking about sometimes. h am
19 depicted in Exhibit No.3, were you in that place of 19 talking about Sunday morning, January 31st, 2010,
20 business on Saturday, January 30th? 20 what time did you leave on that day?
21 A. Yes, selling my items. 21 A. I couldn't tell you that. 1 don't know.
22 Q. And did you, in fact, on that night, on 22 Q. Well, what's your best estimate?
23 Saturday, It 30th, tell individuals that your 23 A. I don't know, sir.
24 name was and that you charged $120 per half 24 Q. Well, first of all you closed Spearmint
25 hour? 25 Rhino at, what 5 in the morning?
4 (Pages 511 to 514)
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EFTA01108855
Page 515 Page 517
1 A. I closed it? 1 A. And we started talking to people.
2 Q. Yeah, you were them until it closed? 2 Q. Who did you talk to in particular?
3 A. Yes. 3 A. I don't know anyone else.
4 Q. And then you went over to Fantasies, 4 Q. Did you talk to a male there?
5 right? 5 A. Yeah.
6 A. That I thought was Spearmint Rhino from the 6 Q. Have him over at your table?
7 back 7 A. He came closer to — we were at the bar.
8 Q. Whatever. 8 Q. The three of you were talking, were you
9 A. Okay. 9 not?
10 Q. And then, how much longer did you stay 10 A. Yeah.
11 there? 11. Q. Do you remember the guy having a laptop?
12 A. I stayed there a little while because there is 12 A. Yes.
13 more girls there that like to buy my items. 13 Q. What did you-all do on the laptop or what
14 Q. Now, let's talk about your trip to New 14 did he do on the laptop while you were there and you
15 York 15 both were sitting there?
16 A. Okay. 16 A. Well, I told him that I modeled for Demons
17 Q. Tuesday, February 2nd, 2010. Remember 1 17 Cycles. And I told him if he would like to see my
18 asked you earlier about whether you ever used any 18 pictures, to go onto Demons Cycles.
19 business cards? 19 Q. So, did you tell him about any other
20 A. Yes. 20 websites?
21 Q. When you went on this trip to New York, 21 A. Excuse me?
22 did you have any cards? 22 Q. Did you tell him about any other websites?
23 A. No, not that I no. 23 A. No, not that I recall.
24 Q. Did have any cards? 24 MR.LIMIER: Let's mark this as
M.
25 A. Not that I know of. 25 exhibit — what's this, 4?
Page 516 Page 518
1 Q. Did you, when you went to the Palm Beach 1 THE COURT REPORTER: Four.
2 International Airport, did you give the taxicab 2 MR. urrIIER: Mark this as 4.
3 driver a card? 3 MR. EDWARDS: Is Exhibit 1 and 2 marked -
4 A. Did I give hi card? 4 MR. LUTTIER: Yeah.
5 Q. Yeah, you or ., little business card? 5 MR. EDWARDS: in the previous depo?
6 A. I didiagive him a card, no. 6 MR. LUFTIER: Yeah, the previous depo.
7 Q. Did M. give him a business sand? 7 Although I don't know where the exhibits are or
8 A. Not that I know of. • 8 they went.
9 Q. When you went into the Palm Beach 9 MR. EDWARDS: Okay.
10 International Airport, your card — do you recall 10 MR. LUTT1ER: It was like answers to
11 going to a bar? 11 interrogatories. Something like that.
12 A. Palm Beach International Airport, yeah, I went 12 MR. EDWARDS: Okay.
13 to a bar there — 13 (Defendants Exhibit No. 4 was marked for
14 Q. What bar do you go to? 14 identification.)
15 A. — because I totally missed the flight. 15 BY MR.
1.6 Q. What bar did you go to? 16 Q. Let me show you what's been marked as
17 A. I think it was Fridays, if I am not mistaken 17 Exhibit 4 and ask you if you can identify that.
18 or not. I don't know what it was called. 18 A. This is —
19 Q. Who went tuk bar with you? 19 MR. EDWARDS: Wait until he asks you a
20 A. 1 went with M. to the bar and it was just 20 question.
21 her and 1. 21 BY MR. LUTHER:
22 Q. And for how long was it just the two of 22 Q. Can you identify it?
23 you? 23 A. Yes.
24 A. For like ten minutes. 24 Q. What is it?
25 Q. And then what happened? 25 A. This is --1 modeled for Demon Cycles and it
5 (Pages 515 to 518)
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EFTA01108856
Page 519 Page 521
1 is their advertisement now. 1 Q. Did you do anything else that evening?
2 Q. And is this one of the pictures on your 2 A. Yes, we went out to dinner.
3 website? 3 Q. After you — did you leave the apartment
4 A. On my website? 4 and go look around at Grand Central Station and then
5 Q. Yeah, or your Facebook, I guess, account 5 keep on walking around or did you come back to the
6 or MySpace, whatever it was. 6 apartment?
7 A. Yeah, I have posted it on there, yeah. 7 A. We went back to the apartment.
8 Q. Is, was this one of the pictures you were 8 Q. Okay. And then there came a time after
9 telling us at your last deposition that you really 9 you came back from sightseeing that you left the
10 wouldn't want your four-year-old son to see? 10 apartment a second time?
11 A. No, that's fine if he sees this. This is, 11 A. Yes
12 this is very legit. His mother modeled and I am 12 Q. And that was for what purpose?
13 actually very proud of this photo. 13 A. We went to Angelo's.
14 Q. All right. Now, did you do anything else 14 Q. Okay. And how did you get to Angelo's?
15 with this inditinial before you left the bar that 15 A. We got to Angelo's in a trod.
16 you, you and M. were tenting to at the Palm Beach 16 Q. Alexi?
17 International Airport? 17 A. Uh-huh.
18 A. Did we do anything with him? 18 Q. And that was about what time?
19 Did you give him anything, either you or 19 A. Oh, jeez, maybe, maybe 9:00.
20 20 Q. Between the time — what time did you go
21 A. I don't recall givingain anything but — 21 looking at Grand Central Station?
22 Q. Well, did you see M. give him anything? 22 A. That was before 9:00.
23 A. No. 23 Q. Okay. And do you remember, do you recall
24 Q. Did either one of you give him a business 24 that evening an individual by name of Martin
25 card? 25 Krouner?
Page 520 Page 522
1 A. I don't have any business cards. I don't — 1 A. Do I know a man named Martin?
2 Q. Well, I don't — you may want to be 2 Q. Uh.huh, Martin Krouner.
3 careful here. I don't want to trick you. lam not 3 A. No.
4 playing semantics. Did either you or give him 4 Q. Do you remember getting in a black
5 a business card? 5 Series 5 BMW when you came out of the condominium?
6 MR. EDWARDS: Object to the form. 6 A. We, we did take a ride with a man.
7 THE WITNESS: Not that I recall, no, sir. 7 Q. Well, 'thought you just told me you
8 We had a few drinks and, and we were off to our 8 walked to the restaurant.
9 flight. 9 A. No, 'told you I took a cab to the restaurant.
10 BY MR. LUTTIER: 10 Q. Oh, took a cab to the restaurant?
11 Q. And then you flew to New York and you took 11 A. Yes.
12 a c and u went to this apartment that's located 12 Q. Did you forget about getting in a car with
13 at 'n New York: is that ri t? That 13 this man?
14 would be the corner o anc Street? 14 A. He took us a little sightseeing. No, I did
15 A. rings a bell. 15 not forget about that.
16 That's where we stayed? 16 Q. Was that before dinner?
17. Q. Yeah. 17 A. That was before dinner, yes.
18 A. Yeah. 18 Q. Did you just fail to mention that or —
19 Q. Now, on that evening, the first night that 19 this is different than the man who took you
20 you got there on Tuesday, I think earlier you said 20 sightseeing later, isn't it?
21 you-all walked down a street and went to dinner, is 21 A. Yes.
22 that right? 22 Q. Okay. So, tell me who Martin Krouner is.
23 A. We walked down the street and we walked into 23 A. I don't know his name, if that is his name.
24 a, I think it's Grand Central Station. I'm not sure 24 Q. Well, the guy that picked up in the black
25 because I'm not from there and we looked around. Yeah. 25 BMW, who's he?
6 (Pages 519 to 522)
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Page 523 Page 525
1 A. I guess a friend of Anna's. 1 fellow here, Mr. Martin Krouner?
2 Q. Well, tell us how old this individual was. 2 A. If that's his name. I don't know if we took a
3 Describe him for us. 3 picture of him, but we definitely took pictures of..
4 A. He has not a lot of hair. He's about five-six 4 and I.
5 maybe and a little chubby. 5 Q. And, and where did you take those
6 Q. For what purpose were you — and you never 6 pictures?
7 met him before? 7 A. Wherever we were.
8 A. No. 8• Q. Okay. And when this man brought you back,
9 Q. In never met him before? 9 did he go to dinner with you? •
10 A. No. 10 A. He ended up meeting us there, yes.
11 Q. You didn't have any idea who he was? 11 Q. Did he drop you at the restaurant?
12 A. No. 12 A. He dropped us near so we can get there with a
13 Q. You-all climbed in his car? 13 taxi. He dropped us somewhere off of the street and we
14 A. Yeah, I think it was Anna's friend. 14 went with a taxi.
15 Q. Okay. What did Anna tell you about the 15 Q. So, he dropped you off and then you got a
16 guy? 16 taxi to get there?
17 A. She's Chinese. She's like go, go; go, go have 17 A. To go to Angelo's, yeah.
18 fun, go search the town. 18 Q. And then he met you there later?
19 Q. So, where did you go with Martin? 19 A. Lateran.
20 A. We ended up meeting him at Angelo's. 20 Q. Okay. About what time?
21 Q. Wait a minute. You got — first of all 21 A. Oh, God, I don't know the times. Maybe this
22 you got in Martin's car, right? 22 was around, maybe around — I'm — this is total
23 A. I got into Martin's car, yes. 23 ballpark, Mee 10 maybe.
24 Q. And then where did you go once you got in 24 Q. Okay. An d, and then after dinner
25 Martin's car? 25 what did you and M. and he do?
Page 524 Page 526
1 A. We searched around the town. 1 A. Well, we took a taxi back to his car. And we
2 Q. What do you mean you searched around? 2 went up to the, we went up to Anna's room and he just --
3 A. We went sightseeing. 3 we just said bye.
4 Q. Okay. Do you remember where you went? 4 Q. And did you receive anything at all of
5 A. And we went sightseeing. 5 value from this man?
6 Q. Do you remember where you want 6 A. No.
7 sightseeing? 7 Q. Did you charge him anything?
8 A. Then we took a taxi. No, because I don't know 8 A. No.
9 the area. 9 Q. Were you paid anything for the time you
10 Q. You went sightseeing in Mr. Kroner's car, 10 spent with him?
11 correct? 11 A. No.
12 A. Yes. 12 Q. Now, who's Robert Fredrick Burke?
13 Q. All right. And, and did there come a time 13 A. Robert Fredrick Burke, I have no idea.
14 that you got of Mr. Kroner'S car? 14 Q. Well, on the next day on Wednesday,
15 A. Yeah, and we looked around. It was finning 15 February 3rd, did you go sightseeing again?
16 outside, so it was nice to feel the snow. 16 A. Yes, we did.
17 Q. And where did you get out of the car? 17 Q. And you said that this fellow Bobby came
18 A. Sir, I don't know New York. I don't — 18 to see you at the apartment sometime the morning of.
19 Q. Well, was it at a restaurant? Was it at 19 Wednesday, February 3rd?
20 the pool? Was it back at the condo? Where was it? 20 A. He came to see us, uh4tuh. Pm not sure what
21 A. it was near a whole bunch of buildings. 21 time it was. I think it was around in the afternoon.
22 Q. By the way, did you take any pictures 22 . Okay. And then after he kit, you and
23 while you were up there? 23 did some more sightseeing?
24 A. I did take pictures. 24 A. Yeah, we walked around town.
25 a Take a picture of you and ■ and this 25 Q. Do you remember getting in a vehicle with
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Page 527 Page 529
1 somebody that night? 1 A. I have no idea.
2 A. Yes. 2 Q. Were they a male's clothes or female's
3 Q. Who did you get in a vehicle with? 3 clothes?
4 A. I told you, I don't know his name. 4 A. I didn't search through the garbage. I just
5 Q. Well, where did you, where did you meet 5 know that I threw out the trash.
6 this person? 6 Q. So you're telling me you don't know whose
7 A. Everybody was Alma's friend. Anna has a lot 7 they were?
3 of friends. 8 A. No.
9 Q. Well, what did you know about the person? 9 Q. Okay. Do you know
10 A. Nothing. 10 A. Yes, Id°.
11 Q. How old is the person? 11 Q. And how do you know
12 A. I told you, I don't know anything about him. 12 A. We grew up together. Firerably 'mew her since
13 Q. And what kind of vehicle did you get in? 13 1was 12.
14 A. I don't even know the vehicle. 14 Q. Have you ever been engaged in any kind of
15 Q. Toyota Highlander? 15 a business venture, regardless of whether it was a
16 A. (sit — I don't know. 16 formally formed business venture like a corporation,
17 Q. And what nationality is this individual? 17 but any kind of business venture with .M?
18 A. I have no idea. 18 A. I went, we went to Jeffrey's togWer.
19 Q. And where did this individual take you? 19 Q. My other kind of business venture, you
20 A. He took us to sightseeing and he took us to 20 and heft
21 the Statue ofLiberty, everywhere. 21 A. No.
22 Q. Did you receive anything of value from 22 Q. Were you ever, did you ever represent or
23 him? 23 attempt to start a business venture with her?
24 A. No. 24 A. This is years ago.
25 Q. Did you charge him anything? 25 Q. How many years ago?
Page 528 Page 530
1 A. No. 1 A. Well, 13, 14, 15, like eight years ago.
2 Q. You or El? 2 Q. Okay. So, this is 2010. We're talking
3 A. I did not charahim anything. 3 about 2002?
4 Q. How about ? 4 A. Yeah.
5 A. I don't know what she does but, no, I don't 5 Q. Okay. So tell us about the venture that
6 think so. 6 you were forming with her?
7 Well, was there ever a time that you and 7 A. I don't know what you're talking about.
8 were not together in this person's presence? 8 Q. Well, you were thinking about something
9 A. Other than me going to the restroom, no. We, 9 because you said years ago. You were the one that
10 I, we were pretty much together the whole time. 10 picked the date. So, what was it you were thinking
11 Q. On the evening ofFebruary 3rd, 2010, do 11 about?
12 you recall throwing a bag of trash in the garbage? 12 A. No, I said years ago we, we knew each other.
13 MR. EDWARDS: Mat date is that? 13 We used to hang out. Like we used to do little girl
14 MR. LUITIER: The evening of February 3rd, 14 stuff, go in the pool and —
15 2010, at approximately 9:00 p.m. 15 Q. No, my question was, was there a business
16 THE WITNESS: In the evening. 16 venture and you said it was years ago.
17 MR. LUTHER: Just before you got in the 17 A. It was years ago that I've known her. Any
18 Toyota Highlander. 18 type of business venture, not that I recall.
19 THE WITNESS: Yes, we did. 19 Q. Have you ever told anyone at all that you
20 BY MR. WITTER: 20 and were forming a business venture or had a
21 Q. Okay. And do you recall what it was that 21. business venture?
22 was in that bag? 22 A. At 12, no, I don't —
23 A. There was whole bunch of clothes and 23 Q. At any, I don't care, right up until
24 everything that Anna did not want, so we threw it out. 24 today.
25 Q. And whose clothes were those? 25 A. No. 9
8 (Pages 527 to 530)
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Page 531 Page 533
1 Q. Did you ever have any sort of a business 1 Q. And you testified that she provided you
2 venture that involved in any way, shape, or form you 2 with drugs?
3 and/or her taking showers? 3 A. Yes.
4 A. No. 4 e Q. All right. Now, who provided the drugs to
5 Q. Did you ever tell anybody you did? 5
6 A. No. A. I have no clue.
7 Q. Did you ever have any literature or 7 Q. Well, who provided the drugs to you that
8 written material describing such a venture? 8 you just claim you took when you were with
9 A. Not that I recall, sir. 9 A. I couldn't even say. Maybe, maybe
10 Q. Ever have anything that described such a 10
11 venture or any costs associated with procuring those 11 Q. That's your boyfriend?
12 services if someone wanted to do that? 12 A. At the time he was my boyfriend.
13 A. Taking showers? 13 Q. Well, he was your boyfriend. He became
14 Q. Well, taking showers or watching the two 14 the father of your child, right?
15 ofyou take showers or any combination or 15 A. Yes.
16 permutation that you can think of. 16 Q. Okay. I mean, that would qualify as a
17 A. Not that I can think ofunless we were like 17 boyfriend, right?
18 stupid little girls who — I don't recall anything about 18 A. If that's what you call it
19 any shower or anything like that, no. 19 Q. He was a drug dealer, wasn't he?
20 Q. Did you ever tell anybody that you had 20 A. No.
21 such a business going? 23. MR. EDWARDS: Form.
22 A. No. 22 BY MR. LUTHER:
23 Q. Did you ever tell anybody you had such a 23 Q. Did he provide drugs to you on more than
24 business going with someone other than e? 24 one occasion?
25 A. A business going, no. 25 A. No, he, no, he, if anything, him and his
Page 532 Page 534
1 Q. I don't mean a formal thing, Did you ever 1 friends got together and they were stupid and young and
2 tell anybody that you were involved in any kind of 2 they did a couple of drugs, but I didn't want anything
3 activity involving taking showers for which you got 3 to do with them until I met Jeffrey. And then I wanted
4 paid money? 4 to numb myself to be around Jeffrey. And I know that I
5 A. Definitely not. I don't — I have never. 5 would take drugs fro
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO:502008CA028051XXXXMB AB
Plaintiff,
-vs- VOLUME IV OF IV
JEFFREY EPSTEIN
AND
Defendants.
VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF
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
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Page 503 Page 505
1 APPEARANCES: 1 PROCEEDINGS
2 On behalf of the Plaintiff. and Jane
3 BRAD J. EDWARDS.
DDe .
2
FARMER, JAFFE, WE/SSING, EDWARDS 3 THE VIDEOGRAPHER: We're back on the
I,PJ02MAt4. PL
record at 1:48 p.m.
5 BY MR. LUTHER:
6 Q. Okay, Ma'am. I want to add that during
7 On behalf o the Jeffrey Epstein: 7 the morning session, I was asking you some
3 ROBERT D. CRITTON,11t, P8QUIRE 8 questions. I just want to go over a couple of
MARK T. tura ESQUIRE
9 R • wt ft* LLITTIER & COLEMAN, ELP 9 things. One of the first things I asked you this
10 morning is whether you understood you were under
11 oath today. And you indicated you did understand
12 that?
12 On o the a r: ant, ;army Epstein: 13 A. Correct.
13 JACK ALAN GOLDBERGER. ESQUIRE
• R & WEISS, PA. 14 Q. Are you, did you, are you aware of the
14 15 fact that it is a crime known as perjury to make a
16 false statement under oath?
17 A. Correct.
16 18 Q. Are you also aware that it is a separate
17
18 ALSO PRESENT. kffrey Epstein, via video conference 19 crime, a federal crime to make a false statement to
4/”.ney, Videogmpber
Daniel C1 20 an FBI agent?
19 Visual Evidence, Incorporated 21 A. Correct.
20
21 22 Q. And you've already admitted that you
22 23 committed that federal crime; you lied to the FBI,
23
24 24 according to you.
25 25 A. I was in fear of my sorts life, correct.
Page 504 Page 506
1 1 Q. Now, l want to ask you one more time: Is
2 INDEX VOLUME I 2 there anything you want to correct about any of your
3
3 testimony this morning, especially as it relates to
4
5 "NESS: DIRECT CROSS REDIRECT RECROSS 4 working in places of employment that you have termed
5 5 to be jack shacks at or about or near Speannim
7 6 Rhino?
BY MR. LUTHER 4 7 A. Correct. I'm fine on that
8 8
9
Q. Okay. Isn't it a fact that on Saturday,
10 9 January 30th, you went to Spearmint Rhino's?
11 EXHIBITS 10 A. Yes.
12 11 Q. And you got there, what time, around 8:00?
13 2 A. Yes.
14 EXHIBIT DESCRIPTION PAGE
15 DEFENDANT'S NO.3
13 Q. And then at some point in time you la
Photo of Fantasies of Palm Beach 512 14 Spearmint Rhino's, did you not?
16 15 A. Yes.
DEFENDANTS NO. 4 518 16 Q. And you went to a place called Fantasies
17 Photo of Demon's Motorcycle ad 17 of Palm Beach, did you not?
18 DEFENDANTS NO. 5 634
•' unction for
18 A. Not that I recall. I don't know a name
19 19 Fantasies.
20 DEFENDANTS NO. 6 618 20 Q. Well, Fantasies of Palm Beach would be the
tinctice for 21 facility that's located right next door to Spearmint
21 22 Rhino's. You're familiar with that, aren't you?
22
23 23 A. I thought that was affiliated with Spearmint
24 24 Rhino.
25 25 Q. Well, so that we 'mow -
2 (Pages 503 to 506)
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Page 507 Page 509
1 (Cellphone interngtion.) 1 located, I believe it's to the left side of
2 THE WITNESS: Oh, Pm sorry, my phone. 2 Spearmint Rhino's as you look at it. It's got a
3 MR. Lill-TIER: Sure. Oo ahead. 3 separate entrance. It's got neon signs on it?
4 THE WITNESS: Okay. Sorry. 4 A. Okay.
5 BY MR. LUTHER: 5 Q. And it's known as Fantasies of Palm Beach.
6 Q. There is a — whether or not ifs 6 You're aware of that place, aren't you?
7 affiliated with Spearmint Rhino, I don't know. When 7 MR. EDWARDS: Fan
8 you referred to your testimony this morning that you 8 THE WITNESS: I'm not aware of any name.
9 didn't go anyplace other than Spearmint Rhinos and 9 BY MR. LUTTIER:
10 places affiliated did, with it, did you mean to 10 Q. Well, you were in the establishment known
11 include in those places that you went Fantasies of 11 as Fantasies of Palm Beach on the evening of
12 Palm Beach? 12 Saturday, January 30th, 2010, were you not?
13 A. I personally never heard of Fantasies of Palm 13 MR. EDWARDS: Font.
14 Beach, but I know that, there, that Spearmint Rhino has 14 THE WITNESS: If that's what it's called,
15 a couple places affiliated with them. 15 then, yes. But, as long, as far as I know,
16 Q. What places do they have that are 16 Spearmint Rhino, that's the name I know it as
17 affiliated with them? 17 you know.
18 A. The back and then there's an entrance to 18 BY MR. LUTTIER:
19 another place. That's all ! know. 19 Q. Well, this is a place that has a separate
20 Q. Well, tell me about this entrance to 20 entrance. You don't go through the entrance of
21 another place. What are you talking about? 21 Spearmint Rhino. You go into a separate entrance
22 A. Well, in the back of Spearmint Rhino there is 22 for a place called Fantasies of Palm Beach.
23 a little section that the dancers I don't know 23 A. Well -
24 exactly what they do there, but that's where I do sell 24 Q. I want to make sure we're real clear here
25 shoes and my lingerie. 25 we're not playing semantics.
Page 508 Page 510
1 And then there is another entrance that 1 A. We're not playing what?
2 you can go through and then there is another it's 2 Q. Semantics.
3 like there's, I know that there's, there's a lot of 3 A. Okay.
4 doors. I don't know what they consist of. 1 don't 4 MR. CRITTON: Word games.
know what they do there, but I know that they are 5 THE WITNESS: Oh.
6 affiliated, I thought that they were affiliated with 6 MR. LUTTIER: All right?
7 Spearmint Rhino, and that's where I also go to sell 7 THE WITNESS: Yeah.
8 my shoes and ptuses. 8 BY MR. LUTTIER:
9 Q. Okay. Well, you talked about a place in 9 Q. And, and you were, in fact, in this place
10 the back of Spearmint Rhino's that you gain access 10 called Fantasies of Palm Beach on Saturday, January
11 to by going through the Spearmint Rhino 11 30th, 2010, were you not?
12 establishment? 12 MR. EDWARDS: Object to the form.
13 A. Yes. 13 THE WITNESS: I definitely walked through
14 Q. All right. Now, what is this second place 14 an entrance and that I thought was affiliated
15 that you are talking about that you say is 15 with Spearmint Rhino.
16 affiliated with Spearmint Rhino's? 16 BY MR. LUTTIER:
17 A. Well, you can either go through out the back 17 Q. And there's a black female in there that
18 door of Spearmint Rhino and take a right, and then there 18 works at the front desk, is there not? There was on
19 is a place there that's affiliated with them. 19 Saturday night.
20 Q. Is there a name? Is there a separate 20 A. Oh, I don't know. I don't know who works
21 entrance to the place? 21 there. I don't blow.
22 A. 1— they're connected. 22 Q. And the --
23 Q. Is there a separate name on this place? 23 A. I just know that I go into Speannint Rhino and
24 A. Not that I know of 24 I sell my —
25 Q. Okay. I'm tallthsabout a place that's 25 Q. And —
4,1 J
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Page 511. Page 513
— items. 1 A. No. I say to the girls, my name is Lynn and
2 the name that you're known as is 2 they know that I sell all of my, all of my clothes and
3 isn't that right? 3 lingerie and shoes and everything else I sell.
4 A- I'm not known as 4 Q. But there is no doubt that now that you
5 Q. That's the name you -- remember we were 5 have seen this picture, you were in that
6 asking you about the cards you used to use? 6 establishment that is depicted on Exhibit No. 3 on
A. Yeah, I was known as =in '07 and '08. 7 January 30th, right?
8 O. that's the name you've used in the past 8 A. Correct.
9 is 9 Q. And you drive a white Mitsubishi Gallant;
10 A. Yes. 10 is that right?
11 Q. And in fact on Saturday, January 30th, you 11 A. Yes.
12 were working in Fantasies of Palm Beach which was. i2 Q. License plate number is 193HV; is that
13 to use your terms, a jack shack, were you not? 13 correct.
14 A. No, I was not working there. 14 A. I don't know my license plate number, but 1
15 Q. And you were charging $120 fora half hour 15 definitely drive a white Mitsubishi Gallant
16 to perform services; isn't that right? 16 Q. And is, was that vehicle parked outside
17 A. No. 17 Fantasies of the Palm Beach on Saturday night,
18 Q. Andacame out and told somebody your 18 January the 30th?
19 name was Mend that that was your charge, 19 A. Yes, but like I said before, from my
20 didn't you not? 20 knowledge, I thought this was affiliated with Spearmint
21 A. No, I did not. All I do is sell shoes and 21 Rhino.
22 purses there. 22 Q. And that car --
23 MR. LUTRER: Let me show you a picture 23 A. And they don't like me to park, they don't
24 here which we'll mark as, !guess we want to do 24 like me to park in front of Spearmint Rhino because
25 it in order. It will be Exhibit 3. 25 there are so many clientele that goes in and out. So
Page 512 Page 514
1 (Defendant's Exhibit No. 3 was marked for 1 they need as much parking space as they can.
2 identification.) 2 Q. And you stayed at Fantasies of Palm Beach
3 THE WITNESS: This place, yeah, ifs next 3 until what hour on the morning of Sunday which would
4 to Spearmint Rhino's. 4 be January 31st?
5 MR. LUTTTER: Hold on. Hold on. 5 A. I stayed until what time?
6 TI WITNESS: Sorry. 6 Q. Yeah, the morning until — what time on
7 BY MR. LUITLER: 7 the morning of Sunday, January 31st, did you leave?
8 Q. I have to ask you a couple of questions. 8 A. Well, Spearmint Rhino, I would go until
9 Do you recognize Exhibit 3? 9 closing like 5, 6. And then in the back of here, of
10 A. Yes, but what I would do, I would go out of 10 Spearmint Rhino, that's like, sometimes they have after
11 Spearmint Rhino from the back and go into the back 11 pa-ties there, something. This is what I hear from the,
12 entrance of Fantasies or whatever this place is called. 12 the manager at Spearmint Rhino. And like I said,
13 Q. So so, now upon seeing the picture, you 13 sometimes I stay there and I have a couple of drinks.
14 want to correct your testimony and say, in fact, you 14 And I'm not sure what time I left.
15 were in Fantasies of Palm Beach on Saturday? 15 Q. I don't want to know —
16 A. I, from my understanding, from my knowledge, I 16 A. As long as I keep on selling shoes and
17 thought that this place was owned by Spearmint Rhino. 17 lingerie, I'm the there.
18 Q. All right. The place of business that's 18 Q. I am not asking about sometimes. h am
19 depicted in Exhibit No.3, were you in that place of 19 talking about Sunday morning, January 31st, 2010,
20 business on Saturday, January 30th? 20 what time did you leave on that day?
21 A. Yes, selling my items. 21 A. I couldn't tell you that. 1 don't know.
22 Q. And did you, in fact, on that night, on 22 Q. Well, what's your best estimate?
23 Saturday, It 30th, tell individuals that your 23 A. I don't know, sir.
24 name was and that you charged $120 per half 24 Q. Well, first of all you closed Spearmint
25 hour? 25 Rhino at, what 5 in the morning?
4 (Pages 511 to 514)
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Page 515 Page 517
1 A. I closed it? 1 A. And we started talking to people.
2 Q. Yeah, you were them until it closed? 2 Q. Who did you talk to in particular?
3 A. Yes. 3 A. I don't know anyone else.
4 Q. And then you went over to Fantasies, 4 Q. Did you talk to a male there?
5 right? 5 A. Yeah.
6 A. That I thought was Spearmint Rhino from the 6 Q. Have him over at your table?
7 back 7 A. He came closer to — we were at the bar.
8 Q. Whatever. 8 Q. The three of you were talking, were you
9 A. Okay. 9 not?
10 Q. And then, how much longer did you stay 10 A. Yeah.
11 there? 11. Q. Do you remember the guy having a laptop?
12 A. I stayed there a little while because there is 12 A. Yes.
13 more girls there that like to buy my items. 13 Q. What did you-all do on the laptop or what
14 Q. Now, let's talk about your trip to New 14 did he do on the laptop while you were there and you
15 York 15 both were sitting there?
16 A. Okay. 16 A. Well, I told him that I modeled for Demons
17 Q. Tuesday, February 2nd, 2010. Remember 1 17 Cycles. And I told him if he would like to see my
18 asked you earlier about whether you ever used any 18 pictures, to go onto Demons Cycles.
19 business cards? 19 Q. So, did you tell him about any other
20 A. Yes. 20 websites?
21 Q. When you went on this trip to New York, 21 A. Excuse me?
22 did you have any cards? 22 Q. Did you tell him about any other websites?
23 A. No, not that I no. 23 A. No, not that I recall.
24 Q. Did have any cards? 24 MR.LIMIER: Let's mark this as
M.
25 A. Not that I know of. 25 exhibit — what's this, 4?
Page 516 Page 518
1 Q. Did you, when you went to the Palm Beach 1 THE COURT REPORTER: Four.
2 International Airport, did you give the taxicab 2 MR. urrIIER: Mark this as 4.
3 driver a card? 3 MR. EDWARDS: Is Exhibit 1 and 2 marked -
4 A. Did I give hi card? 4 MR. LUTTIER: Yeah.
5 Q. Yeah, you or ., little business card? 5 MR. EDWARDS: in the previous depo?
6 A. I didiagive him a card, no. 6 MR. LUFTIER: Yeah, the previous depo.
7 Q. Did M. give him a business sand? 7 Although I don't know where the exhibits are or
8 A. Not that I know of. • 8 they went.
9 Q. When you went into the Palm Beach 9 MR. EDWARDS: Okay.
10 International Airport, your card — do you recall 10 MR. LUTT1ER: It was like answers to
11 going to a bar? 11 interrogatories. Something like that.
12 A. Palm Beach International Airport, yeah, I went 12 MR. EDWARDS: Okay.
13 to a bar there — 13 (Defendants Exhibit No. 4 was marked for
14 Q. What bar do you go to? 14 identification.)
15 A. — because I totally missed the flight. 15 BY MR.
1.6 Q. What bar did you go to? 16 Q. Let me show you what's been marked as
17 A. I think it was Fridays, if I am not mistaken 17 Exhibit 4 and ask you if you can identify that.
18 or not. I don't know what it was called. 18 A. This is —
19 Q. Who went tuk bar with you? 19 MR. EDWARDS: Wait until he asks you a
20 A. 1 went with M. to the bar and it was just 20 question.
21 her and 1. 21 BY MR. LUTHER:
22 Q. And for how long was it just the two of 22 Q. Can you identify it?
23 you? 23 A. Yes.
24 A. For like ten minutes. 24 Q. What is it?
25 Q. And then what happened? 25 A. This is --1 modeled for Demon Cycles and it
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Page 519 Page 521
1 is their advertisement now. 1 Q. Did you do anything else that evening?
2 Q. And is this one of the pictures on your 2 A. Yes, we went out to dinner.
3 website? 3 Q. After you — did you leave the apartment
4 A. On my website? 4 and go look around at Grand Central Station and then
5 Q. Yeah, or your Facebook, I guess, account 5 keep on walking around or did you come back to the
6 or MySpace, whatever it was. 6 apartment?
7 A. Yeah, I have posted it on there, yeah. 7 A. We went back to the apartment.
8 Q. Is, was this one of the pictures you were 8 Q. Okay. And then there came a time after
9 telling us at your last deposition that you really 9 you came back from sightseeing that you left the
10 wouldn't want your four-year-old son to see? 10 apartment a second time?
11 A. No, that's fine if he sees this. This is, 11 A. Yes
12 this is very legit. His mother modeled and I am 12 Q. And that was for what purpose?
13 actually very proud of this photo. 13 A. We went to Angelo's.
14 Q. All right. Now, did you do anything else 14 Q. Okay. And how did you get to Angelo's?
15 with this inditinial before you left the bar that 15 A. We got to Angelo's in a trod.
16 you, you and M. were tenting to at the Palm Beach 16 Q. Alexi?
17 International Airport? 17 A. Uh-huh.
18 A. Did we do anything with him? 18 Q. And that was about what time?
19 Did you give him anything, either you or 19 A. Oh, jeez, maybe, maybe 9:00.
20 20 Q. Between the time — what time did you go
21 A. I don't recall givingain anything but — 21 looking at Grand Central Station?
22 Q. Well, did you see M. give him anything? 22 A. That was before 9:00.
23 A. No. 23 Q. Okay. And do you remember, do you recall
24 Q. Did either one of you give him a business 24 that evening an individual by name of Martin
25 card? 25 Krouner?
Page 520 Page 522
1 A. I don't have any business cards. I don't — 1 A. Do I know a man named Martin?
2 Q. Well, I don't — you may want to be 2 Q. Uh.huh, Martin Krouner.
3 careful here. I don't want to trick you. lam not 3 A. No.
4 playing semantics. Did either you or give him 4 Q. Do you remember getting in a black
5 a business card? 5 Series 5 BMW when you came out of the condominium?
6 MR. EDWARDS: Object to the form. 6 A. We, we did take a ride with a man.
7 THE WITNESS: Not that I recall, no, sir. 7 Q. Well, 'thought you just told me you
8 We had a few drinks and, and we were off to our 8 walked to the restaurant.
9 flight. 9 A. No, 'told you I took a cab to the restaurant.
10 BY MR. LUTTIER: 10 Q. Oh, took a cab to the restaurant?
11 Q. And then you flew to New York and you took 11 A. Yes.
12 a c and u went to this apartment that's located 12 Q. Did you forget about getting in a car with
13 at 'n New York: is that ri t? That 13 this man?
14 would be the corner o anc Street? 14 A. He took us a little sightseeing. No, I did
15 A. rings a bell. 15 not forget about that.
16 That's where we stayed? 16 Q. Was that before dinner?
17. Q. Yeah. 17 A. That was before dinner, yes.
18 A. Yeah. 18 Q. Did you just fail to mention that or —
19 Q. Now, on that evening, the first night that 19 this is different than the man who took you
20 you got there on Tuesday, I think earlier you said 20 sightseeing later, isn't it?
21 you-all walked down a street and went to dinner, is 21 A. Yes.
22 that right? 22 Q. Okay. So, tell me who Martin Krouner is.
23 A. We walked down the street and we walked into 23 A. I don't know his name, if that is his name.
24 a, I think it's Grand Central Station. I'm not sure 24 Q. Well, the guy that picked up in the black
25 because I'm not from there and we looked around. Yeah. 25 BMW, who's he?
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1 A. I guess a friend of Anna's. 1 fellow here, Mr. Martin Krouner?
2 Q. Well, tell us how old this individual was. 2 A. If that's his name. I don't know if we took a
3 Describe him for us. 3 picture of him, but we definitely took pictures of..
4 A. He has not a lot of hair. He's about five-six 4 and I.
5 maybe and a little chubby. 5 Q. And, and where did you take those
6 Q. For what purpose were you — and you never 6 pictures?
7 met him before? 7 A. Wherever we were.
8 A. No. 8• Q. Okay. And when this man brought you back,
9 Q. In never met him before? 9 did he go to dinner with you? •
10 A. No. 10 A. He ended up meeting us there, yes.
11 Q. You didn't have any idea who he was? 11 Q. Did he drop you at the restaurant?
12 A. No. 12 A. He dropped us near so we can get there with a
13 Q. You-all climbed in his car? 13 taxi. He dropped us somewhere off of the street and we
14 A. Yeah, I think it was Anna's friend. 14 went with a taxi.
15 Q. Okay. What did Anna tell you about the 15 Q. So, he dropped you off and then you got a
16 guy? 16 taxi to get there?
17 A. She's Chinese. She's like go, go; go, go have 17 A. To go to Angelo's, yeah.
18 fun, go search the town. 18 Q. And then he met you there later?
19 Q. So, where did you go with Martin? 19 A. Lateran.
20 A. We ended up meeting him at Angelo's. 20 Q. Okay. About what time?
21 Q. Wait a minute. You got — first of all 21 A. Oh, God, I don't know the times. Maybe this
22 you got in Martin's car, right? 22 was around, maybe around — I'm — this is total
23 A. I got into Martin's car, yes. 23 ballpark, Mee 10 maybe.
24 Q. And then where did you go once you got in 24 Q. Okay. An d, and then after dinner
25 Martin's car? 25 what did you and M. and he do?
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1 A. We searched around the town. 1 A. Well, we took a taxi back to his car. And we
2 Q. What do you mean you searched around? 2 went up to the, we went up to Anna's room and he just --
3 A. We went sightseeing. 3 we just said bye.
4 Q. Okay. Do you remember where you went? 4 Q. And did you receive anything at all of
5 A. And we went sightseeing. 5 value from this man?
6 Q. Do you remember where you want 6 A. No.
7 sightseeing? 7 Q. Did you charge him anything?
8 A. Then we took a taxi. No, because I don't know 8 A. No.
9 the area. 9 Q. Were you paid anything for the time you
10 Q. You went sightseeing in Mr. Kroner's car, 10 spent with him?
11 correct? 11 A. No.
12 A. Yes. 12 Q. Now, who's Robert Fredrick Burke?
13 Q. All right. And, and did there come a time 13 A. Robert Fredrick Burke, I have no idea.
14 that you got of Mr. Kroner'S car? 14 Q. Well, on the next day on Wednesday,
15 A. Yeah, and we looked around. It was finning 15 February 3rd, did you go sightseeing again?
16 outside, so it was nice to feel the snow. 16 A. Yes, we did.
17 Q. And where did you get out of the car? 17 Q. And you said that this fellow Bobby came
18 A. Sir, I don't know New York. I don't — 18 to see you at the apartment sometime the morning of.
19 Q. Well, was it at a restaurant? Was it at 19 Wednesday, February 3rd?
20 the pool? Was it back at the condo? Where was it? 20 A. He came to see us, uh4tuh. Pm not sure what
21 A. it was near a whole bunch of buildings. 21 time it was. I think it was around in the afternoon.
22 Q. By the way, did you take any pictures 22 . Okay. And then after he kit, you and
23 while you were up there? 23 did some more sightseeing?
24 A. I did take pictures. 24 A. Yeah, we walked around town.
25 a Take a picture of you and ■ and this 25 Q. Do you remember getting in a vehicle with
7 (Pages 523 to 526)
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1 somebody that night? 1 A. I have no idea.
2 A. Yes. 2 Q. Were they a male's clothes or female's
3 Q. Who did you get in a vehicle with? 3 clothes?
4 A. I told you, I don't know his name. 4 A. I didn't search through the garbage. I just
5 Q. Well, where did you, where did you meet 5 know that I threw out the trash.
6 this person? 6 Q. So you're telling me you don't know whose
7 A. Everybody was Alma's friend. Anna has a lot 7 they were?
3 of friends. 8 A. No.
9 Q. Well, what did you know about the person? 9 Q. Okay. Do you know
10 A. Nothing. 10 A. Yes, Id°.
11 Q. How old is the person? 11 Q. And how do you know
12 A. I told you, I don't know anything about him. 12 A. We grew up together. Firerably 'mew her since
13 Q. And what kind of vehicle did you get in? 13 1was 12.
14 A. I don't even know the vehicle. 14 Q. Have you ever been engaged in any kind of
15 Q. Toyota Highlander? 15 a business venture, regardless of whether it was a
16 A. (sit — I don't know. 16 formally formed business venture like a corporation,
17 Q. And what nationality is this individual? 17 but any kind of business venture with .M?
18 A. I have no idea. 18 A. I went, we went to Jeffrey's togWer.
19 Q. And where did this individual take you? 19 Q. My other kind of business venture, you
20 A. He took us to sightseeing and he took us to 20 and heft
21 the Statue ofLiberty, everywhere. 21 A. No.
22 Q. Did you receive anything of value from 22 Q. Were you ever, did you ever represent or
23 him? 23 attempt to start a business venture with her?
24 A. No. 24 A. This is years ago.
25 Q. Did you charge him anything? 25 Q. How many years ago?
Page 528 Page 530
1 A. No. 1 A. Well, 13, 14, 15, like eight years ago.
2 Q. You or El? 2 Q. Okay. So, this is 2010. We're talking
3 A. I did not charahim anything. 3 about 2002?
4 Q. How about ? 4 A. Yeah.
5 A. I don't know what she does but, no, I don't 5 Q. Okay. So tell us about the venture that
6 think so. 6 you were forming with her?
7 Well, was there ever a time that you and 7 A. I don't know what you're talking about.
8 were not together in this person's presence? 8 Q. Well, you were thinking about something
9 A. Other than me going to the restroom, no. We, 9 because you said years ago. You were the one that
10 I, we were pretty much together the whole time. 10 picked the date. So, what was it you were thinking
11 Q. On the evening ofFebruary 3rd, 2010, do 11 about?
12 you recall throwing a bag of trash in the garbage? 12 A. No, I said years ago we, we knew each other.
13 MR. EDWARDS: Mat date is that? 13 We used to hang out. Like we used to do little girl
14 MR. LUITIER: The evening of February 3rd, 14 stuff, go in the pool and —
15 2010, at approximately 9:00 p.m. 15 Q. No, my question was, was there a business
16 THE WITNESS: In the evening. 16 venture and you said it was years ago.
17 MR. LUTHER: Just before you got in the 17 A. It was years ago that I've known her. Any
18 Toyota Highlander. 18 type of business venture, not that I recall.
19 THE WITNESS: Yes, we did. 19 Q. Have you ever told anyone at all that you
20 BY MR. WITTER: 20 and were forming a business venture or had a
21 Q. Okay. And do you recall what it was that 21. business venture?
22 was in that bag? 22 A. At 12, no, I don't —
23 A. There was whole bunch of clothes and 23 Q. At any, I don't care, right up until
24 everything that Anna did not want, so we threw it out. 24 today.
25 Q. And whose clothes were those? 25 A. No. 9
8 (Pages 527 to 530)
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1 Q. Did you ever have any sort of a business 1 Q. And you testified that she provided you
2 venture that involved in any way, shape, or form you 2 with drugs?
3 and/or her taking showers? 3 A. Yes.
4 A. No. 4 e Q. All right. Now, who provided the drugs to
5 Q. Did you ever tell anybody you did? 5
6 A. No. A. I have no clue.
7 Q. Did you ever have any literature or 7 Q. Well, who provided the drugs to you that
8 written material describing such a venture? 8 you just claim you took when you were with
9 A. Not that I recall, sir. 9 A. I couldn't even say. Maybe, maybe
10 Q. Ever have anything that described such a 10
11 venture or any costs associated with procuring those 11 Q. That's your boyfriend?
12 services if someone wanted to do that? 12 A. At the time he was my boyfriend.
13 A. Taking showers? 13 Q. Well, he was your boyfriend. He became
14 Q. Well, taking showers or watching the two 14 the father of your child, right?
15 ofyou take showers or any combination or 15 A. Yes.
16 permutation that you can think of. 16 Q. Okay. I mean, that would qualify as a
17 A. Not that I can think ofunless we were like 17 boyfriend, right?
18 stupid little girls who — I don't recall anything about 18 A. If that's what you call it
19 any shower or anything like that, no. 19 Q. He was a drug dealer, wasn't he?
20 Q. Did you ever tell anybody that you had 20 A. No.
21 such a business going? 23. MR. EDWARDS: Form.
22 A. No. 22 BY MR. LUTHER:
23 Q. Did you ever tell anybody you had such a 23 Q. Did he provide drugs to you on more than
24 business going with someone other than e? 24 one occasion?
25 A. A business going, no. 25 A. No, he, no, he, if anything, him and his
Page 532 Page 534
1 Q. I don't mean a formal thing, Did you ever 1 friends got together and they were stupid and young and
2 tell anybody that you were involved in any kind of 2 they did a couple of drugs, but I didn't want anything
3 activity involving taking showers for which you got 3 to do with them until I met Jeffrey. And then I wanted
4 paid money? 4 to numb myself to be around Jeffrey. And I know that I
5 A. Definitely not. I don't — I have never. 5 would take drugs fro