EFTA00181297.pdf

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80893 MARR/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / Tuesday, June 15, 2010 4:06 p.m. SWORN STATEMENT OF Taken before ELAINE CRANDALL, Registered Professional Reporter and Notary Public in and for the State of Florida at Large, pursuant to Notice of Taking Unsworn Statement in the above cause. U.S. Legal Support (305) 373-8404 EFTA00181297  2 1 APPEARANCES 2 3 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN 4 BY: BRADLEY EDWARDS, ESQ. 425 North Andrews Avenue, Suite 2 5 Fort Lauderdale, Florida 33301-3268 6 ALSO PRESENT: 7 MICHAEL FISTEN 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 U.S. Legal Support (305) 373-8404 EFTA00181298  3 1 Thereupon-- 2 3 was called as a witness by the Plaintiff and, 4 after having been first duly sworn, was examined 5 and testified as follows: 6 DIRECT EXAMINATION 7 BY MR. EDWARDS: 8 Q. Tell us your name. 9 A. 10 Q. And just to the get to the point, you 11 know who Jeffrey Epstein is? 12 A. Yes. 13 Q. And you've met him before? 14 A. Yes. 15 Q. And you know who Jean-Luc Brunel is? 16 A. Yes. 17 Q. And you have met him before? 18 A. Yes. 19 Q. Which one did you meet first? 20 A. Jean-Luc Brunel. 21 Q. And where did you meet him? 22 A. In Miami Beach. 23 Q. When? 24 A. In 1998. 25 Q. And how? U.S. Legal Support (305) 373-8404 EFTA00181299  4 1 A. In his office. 2 Q. Related to what; modeling? 3 A. Working, yeah. Modeling. 4 Q. What, at that point in time, did you 5 know about Jean-Luc Brunel? 6 A. Nothing. At that time I didn't know 7 anything. 8 Q. So how did you meet with Jean-Luc Brunel 9 in his office in 1998? 10 A. Because there was a gentleman from 11 Switzerland who wanted to make business with them. 12 And I was hired by that gentleman to look through 13 all the accounts to make sure that -- you know, 14 they were kind of in bankruptcy. But he wanted to 15 know that his money, his investment, would be 16 good. So that's why I went. Like, an external 17 audit to do -- to see what was the income, the 18 expenses and something like that. 19 Q. Who is the guy from Switzerland? 20 A. I'm not going to tell you his name. 21 Q. Is that somebody who is still in touch 22 with Jean-Luc Brunel? 23 A. No. Not at all. 24 Q. What's the reason for not wanting to 25 disclose his name? Does he have anything to do U.S. Legal Support (305) 373-8404 EFTA00181300  5 1 with this case? 2 A. No. But I don't have permission. I 3 have to ask him. 4 Q. Okay. And after your meeting with 5 Jean-Luc Brunel in 1998 -- well, what company was 6 Jean-Luc Brunel with then? 7 A. Models, it was, at that time. 8 Q. K-A-R-I-N? 9 A. Yes. 10 Q. And is that the only other modeling 11 agency that you have known Jean-Luc Brunel to be 12 associated with, besides MC Squared? 13 A. Yes. 14 Q. And how long was Jean-Luc with 15 from 1998 through -- 16 A. No, Jean-Luc was the owner of 17 Before that. I think since 1986, in Paris. 18 Q. All right. And why was he no longer 19 affiliated with at some point in time? 20 A. He closed -- he -- how you say -- he 21 made a dissolution. He dissolved the company. 22 Q. Were you ever hired to work with 23 A. I was hired to work with , yeah. 24 Q. When was that? 25 A. In 1998. U.S. Legal Support (305) 373-8404 EFTA00181301  6 1 Q. What was your position? 2 A. At that time, bookkeeper. 3 Q. In Miami? 4 A. Yes. 5 Q. And how long did you stay as the 6 bookkeeper in Miami for 7 A. Until 2003, when they changed the 8 company to MC Squared. 9 Q. So when did the official change come 10 from to MC Squared? 11 A. In 2003. 12 Q. And when is the first time you met 13 Jeffrey Epstein? 14 A. I met Jeffrey Epstein only once in my 15 life. And I believe it was in 2003. Two 16 thousand -- yeah, by the end of 2003, 2004. 17 Q. Where? 18 A. In New York. 19 Q. What was the occasion? 20 A. It was the open party for MC Squared. 21 Q. Where was that held? 22 A. In a discotheque in Manhattan. 23 Q. What discotheque? 24 A. I don't know. I don't remember. 25 Q. And did you meet Elaine Maxwell? U.S. Legal Support (305) 373-8404 EFTA00181302  7 1 A. I don't know her name. But he was 2 with -- with a woman. I don't know. 3 Q. And what is your understanding or what 4 was your understanding that Jeffrey -- in terms of 5 Jeffrey Epstein's involvement with MC Squared? 6 A. Jean-Luc always said that Jeffrey was 7 his friend, that he is a millionaire. And that 8 Jeffrey was giving him the money to -- you know, 9 loans or whatever -- and the apartments for the 10 girls and things like that. 11 Q. All right. Let's break that down. 12 Giving money for what purpose? For furthering MC 13 Squared? 14 A. For -- for -- yeah, the money came to MC 15 Squared, not to -- I don't know. Prior to 2003, I 16 don't know if Jeffrey Epstein ever gave him money. 17 I know that from the longest Jean-Luc was living 18 in an apartment that belongs to Jeffrey Epstein 19 Q. What apartment is that? 20 A. It's in New York. I don't know the 21 address. 22 Q. Is that at 301 East 66th Street? 23 A. Yeah, something like that. I think it's 24 that one. 25 Q. And it's my understanding that Jeffrey U.S. Legal Support (305) 373-8404 EFTA00181303  8 1 Epstein owns or controls numerous apartments in 2 that -- at that same address; is that right? 3 A. Yes. Yes. 4 Q. And have you ever been to that address? 5 A. No. 6 Q. And how do you know that he owns or 7 controls numerous apartments at that address? 8 A. Because at that time Valenzeula 9 was the office manager of the new and she was 10 dealing personally with the assistant of Jeffrey 11 Epstein. And she had to do the payments for the 12 cable and, I believe, electricity. 13 Q. And who was the assistant of 14 Jeffrey Epstein that was dealing with? 15 A. I don't know. 16 Q. 17 A. I believe so. 18 Q. Do you remember that name? 19 A. Yes. 20 Q. That's somebody who no longer lives 21 here, right? 22 A. I -- I believe I heard that, yeah. 23 Q. Who did you hear that from? 24 A. 25 U.S. Legal Support (305) 373-8404 EFTA00181304  9 1 Q. Okay. And at some point in time you 2 came to know that the models were also staying in 3 these apartments at 301 East 66th Street, right? 4 A. I don't know specifically they stay at 5 Jean-Luc's apartment. But I know that the models 6 were staying in different apartments that belong 7 to Jeffrey Epstein. 8 Q. And what are the names of the models 9 that were staying there, that you remember? 10 A. Most of them. You know, at that time, 11 when I was there who -- all the little girls. 12 13 Q. How do you spell that? 14 A. I -- you know, that was in 15 2000-something. I don't recall all the names. 16 But there is a list that you can get it from the 17 office in New York. 18 Q. A list -- 19 A. They have a list of models that they 20 were staying in those apartments. 21 Q. If I were to request it from the office 22 in New York, what would I ask for? 23 A. For the models' apartment list. 24 Chargeback for models apartments. 25 Q. Chargeback? U.S. Legal Support (305) 373-8404 EFTA00181305  10 1 A. Yeah, because Jeffrey Epstein never 2 charged Jean-Luc for rent but Jean-Luc was 3 charging rent to the girls. And in her statements 4 it shows 301, 66 Apartment A, or Apartment B. And 5 he was charging them, like, a thousand dollars a 6 month. 7 Q. How do you know that? 8 A. Because I was doing the statements. 9 Q. You were actually the one doing the 10 statements? 11 A. Not all the time. I was in New York 12 starting 2003. 13 Q. Through what date? You were in New York 14 from 2003 to -- 15 A. 2006. 16 Q. And while you were in New York you were 17 working for MC Squared? 18 A. Yes. 19 Q. And what is the proof that you have seen 20 that Jeffrey Epstein was a partner or financial 21 supporter of MC Squared? 22 A. I was the one who took the papers to 23 Mellon Bank. 24 Q. That's in Miami? 25 A. Yes. And Swetpaul (phonetic) -- I was U.S. Legal Support (305) 373-8404 EFTA00181306  11 1 talking at the time to Rich -- I believe his name 2 was Rich Gany. That was one of the other 3 assistants of Jeffrey Epstein. 4 Q. Gany, G-A-N-Y? 5 A. Yeah. 6 Q. Do they call him Eric Gany? 7 A. That is him name, yeah, Eric Gany. 8 That's his name. I recall some things, not all 9 the time. I recall that Mr. Epstein didn't want 10 to sign the papers, but Mellon Bank didn't want to 11 accept the Line of Credit if he didn't sign. So 12 we had to return the papers to New York so he 13 actually signed the documents. 14 Q• And what was he actually signing, that 15 you remember? Signing over as a Line of Credit 16 or -- 17 A. As a line -- as the grantor of the Line 18 of Credit. Because the Line of Credit came from 19 J. P. Morgan directly, but he was the grantor. He 20 was the one who actually was responsible. 21 Q. And how much was the Line of Credit? 22 A. A million dollars, it was, at that time. 23 Q. And did you ever keep track of whether 24 or not that line was extended or any additional 25 monies were given to MC Squared? U.S. Legal Support (305) 373-8404 EFTA00181307  12 1 A. No, I don't know. 2 Q. So in addition to his financial 3 guarantor on the Line of Credit of a million 4 dollars, what other involvement are you aware of 5 that Jeffrey Epstein had with MC Squared and/or 6 the apartments at 301 East 66th Street where the 7 models lived? 8 A. They were planning on buying or 9 associating with a girl in -- in France for a -- 10 for a company. They were planning to do a 11 company. And, actually, I gave the paper to -- to 12 Mr. Shawn Connolly, which is an actual paper that 13 came from the office from Jeffrey Epstein, that he 14 was giving instructions to Jean-Luc saying that he 15 wanted to have the same contracts as -- uh, what's 16 his name, of Donald Trump, and that he wanted to 17 have the same kind of benefits for the scouters. 18 So he was giving instructions to 19 Jean-Luc on what to do, what to -- there is a 20 woman in Paris, I don't recall her name, 21 (phonetic), I believe it was, and they were -- 22 they were, the three of them, trying to do a new 23 company. But then everything was, like, on zero. 24 They never they never did it together. 25 Q. And do you know why? U.S. Legal Support (305) 373-8404 EFTA00181308  13 1 A. No. 2 Q. Would you know the lady's name in Paris 3 if I -- 4 A. If you give it to me, yeah. If you give 5 me the name, I can recall. 6 Q. Okay. While I'm looking for that, how 7 many girls that were models were living in the 8 apartments at any given time at 301 East 66th 9 Street? 10 A. That's -- that's not only one apartment. 11 There are a lot of apartments there. There is not 12 only one girl. There is not only one apartment. 13 I believe there were, like, two or three 14 apartments. And they were put in between four 15 girls per apartment, I believe. 16 Q. How many apartments? 17 A. I believe there were, like, two or 18 three. 19 Q. And there is four girls per apartment? 20 A. Yeah. 21 Q. And you know that because you saw the 22 documentation at MC Squared that showed where 23 these girls were living? 24 A. Yes. 25 Q• Did you also have something to do with U.S. Legal Support (305) 373-8404 EFTA00181309  14 1 the visas that were prepared for the girls that 2 were working? 3 A. Yes. I was providing the names to the 4 attorney. His name is Luis Font. He was doing 5 the visas here in Miami. There was another 6 Valenzuela was handling directly the visas in New 7 York. And only when she had problems, she hired 8 another attorney. I don't know the name of the 9 attorney in New York. But Luis Font is the -- 10 was, at that time, the attorney handling the visas 11 for Miami. 12 Q. Do you remember doing the visa for 14 A. No, that was done in New York by III 15 Valenzuela. 16 Q. And visa, that you specifically 17 remember being done, right? 18 A. Yeah, I remember that. Because at one 19 point, I believe, one of the renovations of her 20 visa, something happened. And Mr. Epstein called 21 the office while I was there and was really upset. 22 And he spoke with Jean-Luc and they -- they were 23 really nasty with III and, you know, it wasn't 24 if -- it wasn't fault. It was their fault 25 because they gave the wrong information. But, you U.S. Legal Support (305) 373-8404 EFTA00181310  15 1 know, she was only an employee and that's it. 2 Q. How did come into the 3 country? 4 A. By a model's visa, I believe. 5 Q. And was she brought in specifically by 6 Jeffrey Epstein or Jean-Luc or do you remember? 7 A. Mr. Epstein was paying for the visas. 8 But, you know, all the visas were done through -- 9 through or MC Squared. I believe she came 10 with visa first, then everything 11 transferred to MC Square. And I believe those 12 visas were paid directly by Mr. Epstein. 13 Q. How old was when she 14 first came? 15 A. I don't know. I wasn't in New York at 16 that time. Because I know she came prior to me 17 getting involved in New York. 18 Q. And you were involved in New York in 19 2003? 20 A. Yes. 21 Q. So she came in some time before that? 22 A. I believe so. 23 Q. But even back in 2003, she still -- I 24 don't know how old she is now. She's probably 24 25 or 25, right; do you know? U.S. Legal Support (305) 373-8404 EFTA00181311  16 1 A. No. 2 Q. Have you ever met her? 3 A. No. 4 Q. Have you ever met 5 (phonetic)? 6 A. No. 7 Q. You have only met Jeffrey Epstein once 8 in person. How many times have you talked to him 9 on the phone? 10 A. Maybe once. 11 Q. At some point in time you drove several 12 girls or a number of girls over to Jeffrey 13 Epstein's house; correct? 14 A. Not me. Jean-Luc directly took them. I 15 was making the arrangements to get a limousine or 16 a car. And Jean-Luc himself was driving the girls 17 to his house because he was having a party and 18 there were supposed to be girls. 19 Q. Which girls did he drive over there? 20 A. One time I know he went with 21 with uh, what's her name? Four girls from 22 Brazil, from the same agency. is one of 23 them because I remember her name. The other 24 ones -- maybe if you -- 25 S2• U.S. Legal Support (305) 373-8404 EFTA00181312  17 1 A. No. 2 Q. 3 A. No. 4 Q. Do you know those two girls? 5 A. Yes. 6 Q. And were those girls somehow involved 7 with Jean-Luc or the modeling agency? 8 A. Yes. 9 Q. They were both MC Squared models? 10 A. Yes. 11 Q. And at the time, when they began, how 12 old were they; do you remember? 13 A. I believe was, like, 14, 15. And 14 was 13, 14, when she came. 15 Q. Okay. And do you know where they are 16 now, either one of them? 17 A. I know is in New York. 18 Q. When is the last time you talked to her? 19 A. In 2006. 20 Q. How do you know she is in New York? 21 A. Because I saw her pictures whenever. I 22 believe she's in New York. I don't know if she 23 really is in New York but I believe. 24 Q• 25 A. , the last time I saw her was in U.S. Legal Support (305) 373-8404 EFTA00181313  18 1 2006, too. And, specifically, I don't know where 2 she is. But if she's in the United States, I 3 believe she's in New York. If not, she is in 4 Brazil or in Paris. 5 Q. All right. Do you know this person in 6 Brazil, 7 A. No. 8 Q. Here is a document that we obtained 9 related to information from Jeffrey Epstein's 10 computer system. It says Massage Paris. It's in 11 a square there and it continues to the next page. 12 Tell me if you recognize any of those names. 13 A. No. is one of the girls 14 that went with now that I'm seeing kind of 15 names. Lila is one of the other ones. If this is 16 Lelita or something like that, it's a 17 black girl that I believe she was -- she was not 18 underage but she was going out with one of 19 Jeffrey's best friends. 20 Q. Who is that? 21 A. I believe -- 22 Q. Who is Jeffrey's best friend that she 23 was going out with? 24 A. I don't know. I don't know. 25 something like that, is her name. U.S. Legal Support (305) 373-8404 EFTA00181314  19 1 Q. All right. What information do you have 2 about Jean-Luc being involved with underage girls 3 at any point in time? And by that I mean being 4 involved sexually with underage girls. 5 A. One day he told me that he wishes he can 6 sleep with one of those girls that was underage. 7 And I told him that's a minor, whatever. And 8 then -- hold on, that's my son. 9 (Telephone interruption.) 10 A. He had a problem, you know. I cannot 11 say I saw them, look, because I would be lying. 12 And I'm not going to say any lie. But the only 13 thing that I can tell you that what I saw about 14 Jean-Luc is that Jean-Luc is a drug addict, a 15 cocaine addict. 16 Q. At some point in time you actually saw 17 evidence of that, right? 18 A. Yes. 19 Q. I mean, him using cocaine that somebody 20 does every day? 21 A. Yeah. He's an addict. He's used to 22 drugs, as well as, you know -- I know Mr. Epstein 23 doesn't take any alcohol, drugs. I know that. I 24 heard that. 25 Q. How do you know? U.S. Legal Support (305) 373-8404 EFTA00181315  20 1 A. I heard that. I heard that. I don't 2 know, because I never met -- I never -- I was 3 never, like, around him or nothing like that. I'm 4 just telling you what I heard. But regarding 5 Jean-Luc, I know -- I know he has that kind of 6 problem, no? 7 Q. And as long as you knew Jean-Luc, he 8 always had a cocaine problem? 9 A. Yes. 10 Q. What about Jeff Fuller? 11 A. I know he had a cocaine problem, too. 12 He was one time on the Internet, you know, like, a 13 report on that. 14 Q. And is Jeff Fuller somebody else who you 15 also knew to have been associated sexually with 16 underage girls? 17 A. Jeff, I -- you know, I don't think Jeff. 18 I always thought Jeff was gay. For me, he's gay. 19 You know, that's the impression that I have. But 20 I don't think so. 21 Q. Did you find out that Jeffrey Epstein 22 and/or Jean-Luc Brunel were involved in these 23 underage girls that were staying in these 24 apartments at 301 East 66th Street? 25 A. I really don't know that. You know, I U.S. Legal Support (305) 373-8404 EFTA00181316  21 1 cannot tell you. I know there were girls staying 2 there. I never knew if they were going there or 3 not. 4 Q. You mean, you knew that the girls were 5 staying there; 13, 14, 15? 6 A. Some of the girls were underage, yeah. 7 Q. As well as 13, 14 or so? 8 A. Thirteen or 14, yeah. 9 Q. Did you ever ask any of the girls if 10 they were sexually involved with Jean-Luc and/or 11 Jeffrey Epstein? 12 A. No. One time there was a problem with 13 And she was -- I believe she was 14 14 years old. And she tried to go -- or they took 15 her to a discotheque in Miami Beach. And when I 16 went to work the day after, they told me that the 17 police was asking. So since she was doing 18 whatever she wanted, you know, I brought her to my 19 house and I said, you're not going out at night; 20 you're only 13, 14, and that's my responsibility. 21 Q. Do you know Sergio Cordero? 22 A. Yes. 23 Q. And do you know what Sergio's role was 24 in getting girls or something for Jeffrey Epstein? 25 A. Yeah. That -- that is something that U.S. Legal Support (305) 373-8404 EFTA00181317  22 1 Sergio, you know, comment with me. And he said 2 that when Jeffrey Epstein went to Ecuador, 3 Jean-Luc told me that he has to bring girls and 4 this and that, because Jeffrey was coming to 5 Ecuador. So they did such a big thing. 6 Q• Right. But in terms of bringing girls, 7 specifically girls, that were very young? 8 A. Yeah, but there was girls from Ecuador. 9 There is nothing you can do there. It's South 10 America. 11 Q. I understand that. I'm not saying 12 whether it was legal or illegal. I'm just asking 13 you, the direction was that Jean-Luc told 14 Sergio 15 A. Not to bring girls. Never said -- 16 never -- Sergio knew that they like young girls. 17 Q. By young, what are we talking about? 18 A. Eighteen, 19. Sergio -- you know, I 19 know Sergio. And more than anything, like, Sergio 20 is a father. And I don't think he will put his 21 hands on a ten, 11, 12, 13-year-old girl. You 22 know what I mean? 23 Q. I'm not asking about him. Do you know 24 of Jeffrey Epstein being involved with underage 25 girls? U.S. Legal Support (305) 373-8404 EFTA00181318  23 1 A. I heard that, yeah. 2 Q. You heard that through whom? I don't 3 mean just the newspapers and things like that. 4 mean -- 5 A. No. Through -- through the office. 6 Through Jean-Luc. Through -- there were 7 conversations of Jean-Luc saying that, you know. 8 Q. Saying what? 9 A. That Jeffrey likes underage girls. And 10 never directly but, you know, his conversations 11 were like that. 12 Q. Okay. But, specifically, I just want to 13 know what evidence that we have, what real 14 conversations that you heard, about Jeffrey 15 Epstein liking underage girls. 16 A. I'm telling you Jean-Luc saying it from 17 his mouth. 18 Q. Okay. And, specifically, he says 19 Jeffrey Epstein likes underage girls or he likes 20 12-year-olds or likes what? 21 A. No, he likes young girls. When they 22 were talking in the office, there were a lot of 23 people. So they were not stupid. They were 24 knowing how to talk. Because they were making, 25 like, a big thing of, oh, look, he's going out U.S. Legal Support (305) 373-8404 EFTA00181319  24 1 with Fulanita (phonetic), and we knew Fulanita was 2 only 18 years old. She is a young girl. So 3 that's the kind of girl he likes. You know what I 4 mean? 5 Q• But there is nothing illegal going out 6 with an 18-year-old girl. And that's what I'm 7 asking. 8 A. No. 9 Q• What information do we have that Jeffrey 10 Epstein was involved with underage girls? I mean, 11 I have a lot of information of my own. But I'm 12 asking what information do you know. 13 A. The only thing I heard in the office, 14 that Jean-Luc say it, that they like -- when they 15 say, oh, I wish I could sleep with this girl or 16 the fact that he was taking 15, 16-year-old girls 17 to his house. 18 Q. Who? 19 A. I know that because I saw him. 20 Q. Jean-Luc was taking 15-year-old girls to 21 his own place? 22 A. No, to Jeffrey's house. 23 Q. To Jeffrey's house? 24 A. Yes. 25 Q• And what 15-year-old girls was he taking U.S. Legal Support (305) 373-8404 EFTA00181320  25 1 to Jeffrey's house? 2 A. At the time I'm telling you it was Lila, 3 I don't know remember the other two 4 girls. There is two Brazilian girls. I gave it 5 to you before, the names. I don't remember right 6 now. 7 Q. Do you know 8 A. No. 9 Q. Do you know Khalid Mohammed? 10 A. Yes. 11 Q. What did he do? 12 A. He was a scouter and a booker. 13 Q. Scouter; what does that mean? 14 A. Person looking for models. 15 Q. And how legitimate was 16 A. Khalid Salaam. 17 Q. Salaam? 18 A. Yeah. 19 Q. Right. Where was he bringing models in 20 from or looking for models? Outside the country 21 or -- 22 A. Inside the country. Very -- not often 23 from outside the country, no, no. From inside. 24 Q. Did you ever hear of any of the parties 25 that took place on Jeffrey Epstein's island? U.S. Legal Support (305) 373-8404 EFTA00181321  26 1 A. In -- 2 Q. Little St. James? 3 A. One New Year's, I believe -- that was, 4 like, 2004, 2005, that New Year's -- they were 5 having a party there. 6 Q. Who was having a party there? 7 A. Mr. Epstein. 8 Q. And who was at the party that you know? 9 A. I know Jean-Luc was there. But then -- 10 specifically, I don't know if Jean-Luc stay there, 11 because what I do recall is that, during those 12 days, there was, like, December 30 or 29, 13 something like that, Jean-Luc call me from Puerto 14 Rico that he was doing the scouting and he -- 15 actually, he was the one who told me that he had 16 to go to Jeffrey's island because they were having 17 the party there for New Year's. 18 Q. What other girls do you know of that 19 were at that party? 20 A. I don't know. 21 Q• Do you know of any of the other people 22 that were at that party? 23 A. No. 24 Q. Just Jean-Luc and Epstein? 25 A. Yes. U.S. Legal Support (305) 373-8404 EFTA00181322  27 1 Q. The last time that we talked, I have 2 just the investigative report, which basically was 3 just typed up from the things that you said. It 4 was written that Ms. Vasquez advised that she, 5 herself, submitted the documents to renew 6 foreign visa on at least two occasions. 7 A. No, not me. It was Valenzeula. 8 I never did her visa. That visa was done by 9 in New York. 10 Q. When is the first time that you learned 11 that was involved with Jeffrey 12 Epstein? 13 A. I believe in 2007. After I was out of 14 the company. 15 Q. You didn't know, when you were in the 16 company, that they were involved? 17 A. No. 18 Q. All right. At some point in time, did 19 you get in trouble, criminal trouble, related to 20 MC Squared? 21 They accuse me in 2006. 22 Q. Who accused you? 23 A. Jeff. 24 Q. Jeff Fuller? 25 U.S. Legal Support (305) 373-8404 EFTA00181323  28 1 Q. What did he accuse you of? 2 A. Of stealing money. And I had a letter 3 from Jean-Luc authorizing me to get the money that 4 I had, you know. 5 Q. And did you ultimately have to plead to 6 criminal charges because of that? 7 A. That was my -- what my attorney told me. 8 Q. Yeah? 9 A. Yeah. 10 Q. So now you're on probation or something? 11 A. Yes. 12 Q. How long does the probation last? 13 A. They did it for 20 years. So I'm just 14 trying to reduce that. 15 Q. Twenty-year probation? 16 A. Yeah. 17 Q. And other than Jeff Fuller, who else 18 was -- who else was making these accusations? 19 A. Only Jeff. 20 Q. How about Jean-Luc? 21 A. I never -- my attorney told me that 22 Jean-Luc was never interviewed, nothing. 23 Q. Jeffrey Epstein? 24 A. No. 25 Q. Have you talked to Jean-Luc about the U.S. Legal Support (305) 373-8404 EFTA00181324  29 1 whole situation? 2 A. I spoke with Jean-Luc on two or three 3 times. I spoke with Jean-Luc, like, two or three 4 times during -- prior to the middle of the 5 process, I did -- and I still have an e-mail that 6 he send me because he wanted to talk to me, I 7 wanted to talk to him. And I never made the time 8 because Jeff Fuller didn't allow him to talk to 9 me. So we never got to get together to talk. 10 Q• And they prosecuted the case in Federal 11 Court here in Miami? 12 A. Yes. 13 Q• And your entire sentence was probation; 14 there was no prison or house arrest? 15 A. House arrest one year. That, it was 16 done already. And then probation. 17 Q• The last time, I have a lot of other 18 notes about some of the models that were being 19 brought in and signing visas, as if they were 20 going to work here, but really they were living in 21 the apartment and didn't really do any modeling 22 work. 23 A. Yeah, that is true. That is true. I 24 told you that. Many, many girls were coming here. 25 Many girls were coming here first without a visa, U.S. Legal Support (305) 373-8404 EFTA00181325  30 1 without a working visa. Most of the girls, they 2 were coming in to the States as tourists. They 3 were working -- whenever they work, they were 4 collecting 30 percent from their income when they 5 were not even legal. They didn't even have a 6 Social Security or nothing but they never pay it. 7 Neither to the government, neither to the girls, 8 you know. And within the time, I believe Jean-Luc 9 start getting pressure from Mr. Epstein that he 10 didn't want to get in trouble and he put some 11 pressure on Jean-Luc. So he wanted all the girls 12 to have a visa. So they start working on the 13 visas of the girls. 14 Q. Okay. 15 A. And they were making, like, contracts or 16 things like that. Because, prior to that, they 17 didn't have it. Prior to that, when Jean-Luc 18 prior to Jean-Luc getting the money from 19 Mr. Epstein, Jean-Luc was doing whatever he 20 wanted. 21 Q. Okay. 22 A. And later, you know, Mr. Epstein put the 23 money that he had to start taking, you know, all 24 the invoices from Mr. Epstein. 25 Q• Does Jeffrey Epstein know that Jean-Luc U.S. Legal Support (305) 373-8404 EFTA00181326  31 1 is a coke addict? 2 A. I don't know. I don't even know that 3 Mr. Epstein knows that Jean-Luc lied to him all 4 the time. Because when he -- when I gave the Line 5 of Credit to Jean-Luc, Jean-Luc presented false 6 statements to him. You know, Mr. Epstein wanted 7 to see that the company was a profitable company 8 and we had to hide all those numbers. And we had 9 to give him, like, positive numbers so he can see 10 that the company was making money but in belief 11 always was in red. 12 Q. What do you mean by that? Jeffrey 13 Epstein said, hey, I'm going to give you money as 14 long as the company is positive? 15 A. Yeah. Mr. Epstein wanted to see -- I 16 believe -- I believe, since he's a very successful 17 person moneywise, he was not stupid to put his 18 money, even though he knew he was able to get 19 girls or whatever, you know, if that was the case. 20 But deep inside he wanted to see if these people 21 really -- if this company was profitable for him 22 to put a million dollars. 23 So maybe Eric Gany, at the time, was one 24 of his advisors. And they wanted to see the 25 profit and loss statements and, you know, the U.S. Legal Support (305) 373-8404 EFTA00181327  32 1 balance book or whatever. 2 I told you the name of the accountant 3 that you could go and took all those papers, you 4 know, make a subpoena or whatever, of Richard 5 Fernandez, that he could give you all the 6 information, 1998, '99, 2000, after 2005, that he 7 did everything and you could see the company was 8 always in red, always. 9 Q. So the company wasn't profitable but 10 Jean-Luc falsified documents to show to Jeffrey 11 Epstein? 12 A. Yes. 13 Q. And have you seen the real documents and 14 the falsified documents? 15 A. Yes. 16 Q. So you know that they were falsified? 17 A. Yes. 18 Q. Is it your understanding that Jeffrey 19 Epstein is still involved, from a financial 20 aspect, in MC Squared? 21 A. I believe so. Because, as far as I 22 know, the Line of Credit wasn't paid. The million 23 dollars wasn't paid. 24 Q. And Jean-Luc and Jeffrey Epstein are 25 still friends? U.S. Legal Support (305) 373-8404 EFTA00181328  33 1 A. Yes. Jean-Luc is still living in 2 Jeffrey Epstein's apartment in New York. 3 Q. How do you know that? 4 A. Well, because -- because I know. 5 Q. From 6 A. Yes. 7 Q. Is still working for MC Squared? 8 A. No. 9 Q. Do you know who is working for MC 10 Squared? 11 A. It was working until not too long ago a 12 very -- goddaughter, , she was 13 working there. 14 Q. How do you spell it? 15 A. 16 Q. Okay. Anybody else? 17 A. In Europe? 18 Q. Yes, or here. 19 A. No, that was related to No, 20 21 Q• Who works in the MC Squared office here? 22 A. Here, I knew other things, because 23 Amanda Grant and -- I gave you her name more than 24 one time. Amanda was working with them until 25 2008. And she got a lot of information. And she U.S. Legal Support (305) 373-8404 EFTA00181329  34 1 wanted -- you know, she call -- I arrange she call 2 Immigration, because they screw her. And, 3 actually, they made her leave the company because 4 she has -- she is a single mother, four kids. And 5 they were giving her a lot of bad -- bad time. 6 (Telephone interruption.) 7 Q. How do you spell her name, Amanda Grand, 8 G-R-A-N-D? 9 A. N-T. Amanda Grant. 10 Q. And do you know her address, phone 11 number; something like that? 12 A. I have -- you can get it in Facebook. 13 She's in Facebook. Amanda Grant. 14 Q. Do you have it? 15 A. Not in this phone. My other phone broke 16 so I don't. I can get it for you, if you want. 17 Q. Yeah, I would appreciate it. 18 A. Yeah. 19 Amanda had also the information of 20 monies, as I told you before, that took monies 21 that they were transferred to the British Virgin 22 Islands. 23 Q. Monies transferred to the British Virgin 24 Islands? 25 A. Yes. U.S. Legal Support (305) 373-8404 EFTA00181330  35 1 Q. From what account to what? 2 A. Jean-Luc opened an account there because 3 Jeffrey told him that it was better to open an 4 account there. So there was money -- like, for 5 example, if the monies were going to Manuel Cruz 6 to do a shoot or something, Jean-Luc was 7 negotiating with the girls and say, okay, if you 8 go to do the sunny photos, I give you $2,000 cash, 9 no reports, whatever. 10 So Jean-Luc had -- as billing that 11 company from another company, or from the British 12 Virgin Islands. So he was neither paying taxes 13 here and maybe he was making $20,000 on that 14 shooting and he was giving the girl only $2,000 15 and that money never came to be reported here. 16 Q. Okay. Other than you saying that you 17 know that a 15-year-old or so went to Jean-Luc's 18 house with him, how else do we know that Jean-Luc 19 and/or Jeffrey Epstein, I'm more concerned with 20 Jeffrey Epstein, were involved sexually with 21 underage girls? 22 A. How do I know? I -- I -- I cannot tell 23 you that I saw -- that I was there because that's 24 not true. I never saw anything. 25 Q• Right. But sometimes you just know? U.S. Legal Support (305) 373-8404 EFTA00181331  36 1 A. Yeah, sometimes -- and that's -- that's 2 what I can tell you. I know because -- I can tell 3 you about Jean-Luc, that I know because I met him 4 for ten years. Okay? I can put my hands on fire 5 and I can tell you that he did it. About Jean-Luc 6 I can say it. I don't know about Mr. Epstein 7 because I was never -- I met him once in my life. 8 I saw him once in my life. And after that, when I 9 saw him, was in the newspapers; that's it. 10 Q. And, otherwise, you just heard that 11 Jeffrey Epstein likes underage girls? 12 A. Underage girls, yeah. 13 Q. And there was a time where Sergio -- 14 well, I've talked to Sergio, so I'll talk to him 15 about whatever the Ecuador trip was. 16 A. Yes. 17 Q. All right. Do you know of this company, 18 COUQ -- 19 A. No. 20 Q• -- Foundation. All right. Do you know 21 of somebody by the name of 22 A. No. 23 Q. Somebody who provided Jeffrey Epstein 24 girls? 25 A. No. U.S. Legal Support (305) 373-8404 EFTA00181332  37 1 Q. How about 2 A. No. 3 Q. Never heard that name? 4 A. No. 5 Q• 6 A. I believe I heard that name. But I -- 7 Q. She works up in New York and I believe 8 she works for Jeffrey Epstein in some capacity. 9 Do you know what that is? 10 A. I believe so. No. 11 Q. Okay. 12 A. The person who can tell you that is III. 13 Because III was very involved with Jeffrey 14 Epstein's office. 15 Q. What is number again? 16 A. 17 Q. Do you know Jojo Fontanella? 18 A. No. 19 Q. No? Other than Jean-Luc, what other 20 people that are friends with Jean-Luc share this 21 interest in underage girls, that you know of? 22 A. No. 23 Q• I mean, who are his friends? Who are 24 the guys he hangs out with? 25 A. Jeff. When he was in Miami, Jeff, U.S. Legal Support (305) 373-8404 EFTA00181333  38 1 Corrado. 2 Q. Who is Corrado? 3 A. A friend of Jean-Luc. An Italian guy. 4 They were always like that, Corrado and Luc. I 5 met Jean-Luc's friends in Ecuador, like people 6 that had to be -- people that they were involved 7 with modeling agencies in Europe, in South 8 America, but very different people, very different 9 people. I met some people from France. Pero, 10 really, even if they were guys or whatever, 11 gentlemen. You know, like, very proper people. 12 Like, from Brazil, too. And the womans, you know. 13 Q. How about Simon Parra; you know who that 14 is? 15 A. Simon Parra, yeah. 16 Q. How do you know him? 17 A. I met him through Jean-Luc. 18 Q. And what's his story? 19 A. Mr. Parra was a very good friend of the 20 office. I cannot say of Jean-Luc because he was 21 only a fri