EFTA01104158.pdf

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME I OF II JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 09-80591, 09-80656, 09-80802, 09-81092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF { JANE DOE NO. 2 Wednesday, March 3, 2010 10:02 - 6:19 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.: IIII EXHIBIT_A PROSE COURT REPORTING AGENCY, INC. EFTA01104158  _ .e.s.seu.ves,4ft.ZeeeniPeei Page 199 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME II OF II JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994 08-80993, 08-80811, 08-80893, 09-80469 09-80591, 09-80656, 09-80802, 09-81092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE NO. 2 Wednesday, March 3, 2010 10:02 - 6:19 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.: MI PROSE COURT REPORTING AGENCY, INC. mimit t>9 ironically signed by cynthla hopkins ironically signed by cynthla hopkins ironically signed by cynthla hopkins 75c26181.1493-46e5-a692.6d620d5d87d6 EFTA01104159  Page 214 Page 212 1 BY MR. CRITTON: 1 either by phone or by mail? 2 Q. The only contact you had with Mr. Epstein 2 A- By mail. I got mail that's, I think that's 3 at his home or with him or someone working on his 3 how I kept in contact with everyone. i don't, I don't 4 behalf, other than me as his attorney or Dr. Hall, 4 think I had conversations with them on the phone about 5 who did a medical examination on you -- I forgot the 5 it Q. Okay. Did she ask you whether you had, 6 question. I have to start again. 6 7 Other than myself who represents 7 "she," the agent, ever ask you whether you had had 8 Mr. Epstein and other than Dr. Hall who did an 8 telephone, any telephone conversations with 9 examination of you, you've had no contact either 9 Mr. Epstein? 10 with Mr. Epstein or with anyone who has been acting 10 A. I don't think she asked me that. 11 on his behalf at any time other than that one 11 Q. Okay. And just let me ask just a coupk of questions. Is, is -- you never gave Mr. Epstein 2 occasion in December of '04; is that coned? 12 13 A. Correct. 13 or anyone on his behalf your phone number, did you? 14 Q. With the FBI, did you ever get a letter 14 A. Yes, I did. 15 Q. To whom did you give your phone number? 15 from them or from the Department of Justice, the A. The lady downstairs, his assistant. 16 United State's Attorney's Office, at any time? 16 17 A. I believe so. They were keeping me updated. 17 Q. All right A. Or whatever she is. 18 Q. Okay. And at some point did you learn 18 Q. No one, Mr.— you have never spoken with 19 that Mr. Epstein was, had pled guilty to state 19 20 offenses and was serving time in jail? 20 Mr. Epstein by phone, correct? 21 A. Yes. 21 A. Correct. 22 Q. Okay. How did you learn that? 22 Q. Okay. He has never texted you nor have 23 A. Through the, the letters that I got like once 23 you ever texted him, correct? A. Correct. 24 every couple of months or once year. 24 25 Q. And in any of the letters that you ever 25 Q. You have never communicated to him, Page 215 Page 213 1 received from the, either the FBI or the United 1 communicated with Mr. Epstein or anyone on his 2 State's Attorney's office, did they ever tell you 2 behalf over the Internet, either to or from, 3 you had the ability to bring a civil lawsuit for 3 correct? 4 money damages against Mr. Epstein? 4 A. Correct. 5 MR. HOROWITZ: Form. 5 Q. You have not used your computer Facebook, 6 . THE WITNESS: Tin not sure. I don't know 6 a social networking site, to communicate with 7 actually. 7 Mr. Epstein or anyone on his behalf correct? 8 BY MR. CRITTON: 8 A. Correct 9 Q. And how did -- again I don't want to know 9 Q. Okay. And if I may just so it's correct 10 any — is the first lawyer that you met from the law 10 you have never texted or no one on behalf — strike 11 firm that your, that your, that you currently 11 that. You have had no contact by phone, text, 12 employ, is that Mr. Herman? 12 Internet, computer with Mr. Epstein or anyone acting 13 A. Correct. 13 on Mt. Epstein's behalf, correct? 14 Q. Okay. And where did you lust meet 14 MR. HOROWITZ: Form. 15 Mr. Herman? 15 THE WITNESS: Correct. 16 A. My mother contacted him. 16 BY MR. CRiTTON: 17 Q. Okay. And how did she get in contact with 17 Q. Okay. Did, the only contact that you ever 18 him, do you know? 18 had with Mr. Epstein or really anyone on his behalf 19 A. I believe she read about one of the other 19 was that one-time visit in the latter part of 20 girls that had come out and talked and spoke about ha 20 December of 2004, correct? 21 day with Mr. Epstein, and then she wanted me to talk to 21 A. Well, Dr. Hall and now you. 22 somebody as well. 22 Q. But that's a different issue. Back in the 23 Q. Is this someone who had filed a lawsuit 23 time period — 24 against Mr. Epstein - 24 MR. HOROWITZ: That's a good answer. 25 MR. HOROWITZ: Form. 25 5 (Pages 212 to 215) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 7bc26f81-1493-46e5a692-6d620d5d87d6 Electronically signed by cynthia hopkins • EFTA01104160  Page 38 Page 40 Q. Okay. Where does live? 1 Q. I get to ask the questions. Fillet your 2 A. What do you— are you going to follow her or 2 lawyer at a break tell you why I get to ask or not 3 something? 3 ask questions. Okay? There should be no reason 4 5 6 A. She lives , Q. !just ask at. wn does she live, please? She lives in 4 5 6 that you or anyone else should be scared for their lives. A. I would hope not. 7 8 „a ? Is that a housing area? A. It's a neighborhood. 7 8 Q. Is your brother married, A. Yeah. Q. Do w what her address is? 9 . You say you told your, your best friend 10 A. 10 what had ha. , ed at Mr. Epstein's 11 house. When did you tell that? Did 11 Q. 12 A. Yes. 12 you tell her that day that you came back from 13 Q. 13 Mr. Epstein's home? 14 A. Yes. 14 MR. HOROWITZ: Object to the form. 15 . Do ou know what Michelle - or Pm song, 15 THE WITNESS: No. I told her the next 16 ' phone number is? 16 day. 17 A. Her house phone number is 17 BY MR. CFUTTON: 18 . And are you still best friends with 18 Q. Do you recall the exact date you were at 19 19 Mr. Epstein's home? 20 A- Yes. 20 A. No. 21 Q. Have you seen her since you've been down 21 Q. Okay. You went to Mr. Epstein's home on 22 here? 22 one occasion, correct? 23 A. No. 23 A. Yes. 24 Q. Do you plan to see her before you return 24 Q. Do you remember the year it was in? 25 home to Tennessee? 25 A. 2004. Pa C.: ,E! I Page 39 1 A. Yes. 1 Q. Do you remember 2 Q. When are you going to see her, tonight? 2 A. Eleventh grade. 3 A. I haven't gotten that far. 3 Q. Do you remember the month? 4 Q. How long do you plan to be in Florida now 4 A. I believe it was in December, near Christmas 5 that you're down here? 5 time. 6 A. A couple of days, a week. 6 Q. So, if I understand, when you left 7 Q. Okay. Where are you staying? 7 Mr. Epstein's home — and I'll just use late 8 A. At my brothel's house. 8 December of '04; is that okay with you? 9 Q. • Natural brother or step-brother's? 9 A. Yeah. 10 A. Natural brother. 10 Q. When you went to his home, you didn't say 11 Q. What's his name? 11 anything about your experience to Ms. Doe No. 3; is 12 A. 12 that comet? 13 Q. Where does he live? 13 MR. HOROWITZ: Feat 14 A. I have no idea. 14 THE WITNESS: I told her one thing that he 15 Q. I'm sorry? 15 tried fingering me„ and she said that it was 16 A. He lives one 1 don't know his address. 16 okay, that she, that that happened to her 17 Q. In 17 friend. 18 A. Yes. Why do you need to know where Pm 18 BY MR. CRIITON: 19 staying? I don't think that's relevant to this. That 19 Q. And did she — when she said it was okay, 20 is not — I don't want to be scared for my life. 20 did it seem, at least to Ms. Doe No. 3, that that 21 Q. There would be 110 reason that you would be 21 was no big deal? 22 scared for your life. 22 A. Yes. 23 A. Well, why — 23 Q. Okay. Did Ms. Doe No. 3 tell you, either 24 Q. Okay. 24 before or after you went to Mr. Epstein's home, that 25 A. — is the reason for you to ask where Pm at? 25 she had been with Mr. Epstein personally? -1- 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY, INC. EFTA01104161  Page 42 Page 44 A. No. 1 Is Jane Doe No. 3 the one who took you to Q. Okay. Did she ever express to you any 2 Mr. Epstein's home? type of emotion, anger, being upset based upon her 3 A. Correct. having been to Mr. Epstein's home, what, whatever 4 Q. Was she — was anyone else there with you her experience had been? 5 at the time? When I say "anyone else," did anyone A. No. 6 else of your friends or acquaintances go with you to Q. Okay. When you told her that he tried to 7 Mr. Epstein's home on that one occasion in December, 8 finger you, did you, did she — other than saying, 8 late December of 2004? 9 okay, yeah, that happened with another friend of 9 A. No. 10 hers, did she say anything else? 10 Q. Okay. Do you I aber, did you know a 11 A. She said that he thought — that if he thought 11 girl named Jane Doe No. 4, Doe No. 4? 12 I was pretty, he would want me to come back again. And 12 A. I know —1 know of her. I know of her, but 13 I told her that I wasn't going to ever go back there. 13 I, I don't know her really. 14 Q. Okay. Did, did she — at least, she 14 Q. Okay. Do you remember Jane Doe No. 4 15 meaning Jane Doe No. 3, did she give at least — 15 being there with you? 16 well, let me strike that. 16 A. No. 17 Did Jane Doe No. 3 express to you that 17 Q. So, it was, did Ms. Doe No. 3 pick you up 18 she, that Ms. Doe No. 3, would like you to come back 18 in her car? 19 or may want you to come back, I mean prior to your 19 A. Yes. 20 saying that's not something that I want to do? 20 Q. And on the way to Mr. Epstein's — and I'm 21 MR. HOROWITZ: Form. 21 going to come back to this a little later, but just 22 THE WITNESS: Did she — are you asking, 22 so I get a couple of facts squared in my mind, is 23 did she want me to — did she ask me if she 23 either on the way to Mr. Epstein's or after you left 24 wanted me to go back there? 24 Mr. Epstein's; that is, the entire time you spent 25 25 with Jane Doe No. 3, did she ever say or express any Page 4 3 Page 45 1 BY MR. CRITTON: 1 concern that she had ever had being at Mr. Epstein's 2 Q. Yeah. 2 home or being around Mr. Epstein's home? 3 A. (Non verbal response.) 3 MR. HOROWITZ: Form. 4 Q. Yes? 4 THE WITNESS: No. 5 A. Yes. 5 BY MR. CRITTON: 6 Q. Okay. Did, did anything about your 6 Q. Okay. Did she, during the time you were 7 experience — well, let me strike that. 7 with her on the trip over, when you were in the 8 Did Ms. — did Jane Doe No. 3 express to 8 house, when you left the house, did Jane Doe No. 3 9 you any type of concern about your having been at 9 appear to you in any way to be anxious or, or 10 Mr. Epstein's home based on your experience? 10 nervous or unhappy; that is, did you see anything in 11 MR. HOROWITZ: Form. 11 her demeanor that, that looked to be uneasy in any 12 THE WITNESS: Did she seem concerned? 12 way? 13 BY MR. CRITTON: 13 MR. HOROWITZ Form. 14 Q. Yeah. 14 THE WITNESS: Not really. 15 A. No. 15 BY MR. CRITTON: 16 Q. Okay. Did she say anything that would 16 Q. Did Jane Doe No. 3 say to you anything 17 have led you to the, to the — led you to an 17 along the lines of, kite, this is no big deal, you 18 impression that she somehow had been emotionally 18 know, something like that? 19 traumatized at all by Mr. Epstein? 19 A. No. 20 MR. HOROWITZ: Form. 20 Q. Okay. Was Jane Doe No. 3 paid when you — 23. THE WITNESS: Not really. 21 let me strike that. 22 BY MR. CRJTTON: 22 Do you have any knowledge as to what Jane 23 Q. Okay. Did she appear to you to be 23 Doe No, 3, whether Jane Doe No. 3 received any money 24 uncomfortable; that is, when you went to 24 for your having come to Mr. Epstein's home? 25 Mr. Epstein's home with me strike that. 25 A. Yes. 12 (Pages 42 to 45) PROSE COURT REPORTING AGENCY, INC. EFTA01104162  Page 46 Page 48 1 Q. How much was she paid? 1 the privilege. 2 A. $100. 2 MR. CRITTON: I, I disagree. 3 Q. Did she have to share that with anyone to 3 MR. HOROWITZ: Don't answer. 4 your knowledge? 4 MR. CRAYON: Okay. We disagree on that 5 A. No. 5 Let's move on. 6 Q. Okay. Did you, when you — and were you 6 BY MR. CRTITON: 7 aware when you left Mr. Epstein's home that she 7 Q. Okay. Have, have you told anyone other 8 received $100? 8 than your lawyers you would like to sue Jane Doe 9 A. I had to give it to her. 9 No. 3 because you hold her responsible for taking 10 Q. Okay. Were you —did she tell you before 10 you to Jeffrey Epstein's home? 11 you went to Mr. Epstein's home that she would 11 A. I've thought about it I don't — I didn't 12 receive money? 12 say anything to anyone. 13 A. No. 13 Q. Okay. 14 Q. Okay. Do you think Jane Doe No. 3 shares 14 A. I already got my revenge with her. 15 responsibility for having taken you to Mr. Epstein's 15 Q. How did you get your revenge with her, 16 home? 16 Jane Doe No. 3? 17 MR. HOROWITZ: Form. 17 A. We got into an argument and a fight — 18 THE WITNESS: Yes. 18 Q. About what? Oh, I'm sorry, I didn't mean 19 BY MR. CRITTON: 19 to — that's another rule, or a pro, process here, 20 Q. Okay. Have you ever expressed to anyone 20 is if you interrupt me on a question, and I haven't 21 other than your lawyers that you think Jane Doe 21 finished my question, I am going to say, hold on, 22 No. 3 should be sued because she — but for Jane Doe 22 Ms. Doe No. 2, let me finish my question so you 23 No. 3 taking you to Mr. Epstein's home, you never 23 understand what I'm asking 24 would have met him? 24 If l interrupt you with one of your 25 MR. HOROWITZ: Form. 25 answers and you hesitate and I start with another Page 47 Page 49 1 THE WITNESS: Your question is, do I think 1 question, tell me you haven't finished and I'll let 2 Jane Doe No. 3 should be sued for taking me 2 you finish. Okay? 3 there? 3 A. Okay. 4 BY MR. CRITTON: 4 Q. You said you got into a fight with Jane 5 Q. Yeah. Because but, but for Jane Doe 5 Doe No. 3? 6 No.3, you would have never heard of Mr. Epstein, 6 A. Yes. 7 would you? 7 Q. Okay. And what was the fight about? 8 MR. HOROWITZ: Form. A. To her, it was about a boy. I'm not even sure 9 THE WITNESS: I would have never heard of 9 what it was about. She just wanted to come after me, 10 him if she hadn't cane up to me and mentioned 10 and for me it was more of, of, like, I don't like you, 13. him, yeah — 13. and I want you to know that I never want you to hurt 12 BY MR. CRTITON: 12 anybody and that she was wrong 13 Q. Okay. 13 Q. Okay. I didn't understand your answer. 14 A. -- but.. 14 From your perspective -- well, let me strike that. 15 Q. Have you ever considered suing Jane Doe 15 When did the fight occur with Jane Doe No. 3? 16 No. 3 for having taken you there? 16 A. Going— summer of going into 12th grade. 17 MR. HOROWITZ: Form. I am going to asser. 17 Q. Which would have been the summer of 2005, 18 a privilege. That would be work product. 18 or the August-ish 2005? 19 MR. CRITTON: I'm just asking her — 19 A. Yeah. 20 MR. HOROWITZ: No, I, I get that, but her, 20 Q. Okay. And you say it's Jane Doe No. 3's 21 you're asking — hold on a second. You're 21 view -- and how do you know what Jane Doe No. 3's 22 asking her what her legal theories are, and it 22 view of the fight was? 23 overlaps with what — as her counsel, we 23 A. Because she kept calling me a slut and saying 24 infiltrate our legal opinions, and I don't 24 that, that I was hanging out with this guy that she 25 think you can separate the two. I am asserting 25 liked, that I didn't like, but... IwOr:KaaawoYa..44t4+•Naiisaca....04aa..40a“tae-u. C.a.,-vaAl alaLaa%ia•IW 13 (Pages 46 to 49) PROSE COURT REPORTING AGENCY, INC. EFTA01104163  Page 34 Page 36 1 Q. All right. Now, you said when you looked 1 BY MR. CRITTON: 2 at the police report you noticed — Pm going to 2 Q. All right. And was there anything else 3 come back to this later, but just so I have a basic 3 that saw in the police officer's recordation; that 4 understanding. What did you see in the police 4 is, what he put on the page, of what you purportedly S report that was different from what you 5 said to him at that time that you — that refreshed 6 understood — or let me strike that. 6 your recollection in some way about what happened at 7 What did you see in the police report that 7 Mr. Epstein's, that, that prior to yesterday was not 8 stood out to you that you indicated that you had 8 in your recollection? 9 forgotten? 9 A. Those were the only two things. 10 A. The fact that he unsnapped my bra and was 10 Q. All right. Now, if the police officer — 11 touching me on my breasts. 11 you indicated that Item I is, is that he unsnapped 12 Q. Okay. Anything else? 12 your bra and touched your breasts, correct? 13 A. That his fingers went slightly inside my 13 A. Correct. 14 vagina. 14 Q. And when you say "he" — had that not been 15 Q. And you is that something when you 15 in the police report, is that something that you, at 16 saw -You can take a break anytime you want. 16 least as of yesterday, you didn't remember? 17 THE VIDEOGRAPHER: Going off the record at 17 MR. HOROWITZ: Form, improper 18 10:33. 18 hypothetical. 19 (A brief recess taken.) 19 THE WITNESS: I remember it being worse 20 TIM VIDEOGRAPHER We're back on the 20 than what I keep telling everybody had 21 record at 10:38 am. 21 happened, because I don't want people to think, 22 BY ME- CR1TTON: 22 think that some old man touched me like that 23 Q. Jane Doe No. 2, you indicated that the, in 23 and was allowed to get away with it and 24 reviewing the police report you were talking about 24 everything was okay. 25 the areas of the police report that reminded you, or 25 Page 35 Page 3 1 when you saw them you now recall that this, these 1 BY MR.. CIUTTON: 2 two events may have happened; one is, you say he, 2 Q. Well, what do you - what do you mean, 3 he, I assume you mean Mr. Epstein, unsnapped your 3 he's been allowed to get away with it? 4 bra and touched your breasts, is item I, correct, if 4 A. No matter what 1 say or do, nothing is going 5 I understood you? 5 to happen to him. And that's the only thing that I 6 A. Correct. 6 want. 7 Q. And the second is you say you think his 7 Q. What - fingers may have slightly gone inside or touched you 8 A. I want him to know that what he did was wrong 9 inside your, your vagina; is that correct? 9 and to never ever do that to anybody, because nobody 10 A. I don't think. 'know. 10 deserves to feel the way that I deserve — that I felt 11 Q. Well, with regard to anything else that 11 that day. I would never want anyone to have to go 12 you saw in the police report that, as you've 12 through that. 13 described, quotehinquote, reminded you or called — 13 Q. Okay. And did — that day you were at 14 made you able to recall what occurred at 14 Mr. Epstein's home, when you left did you express 15 Mr. Epstein's home as you sit here today now? 15 just what you did on the video camera and to the 16 A. What was the question? 16 court reporter here, did you express that to your 17 Q. Okay. Was there anything else that you 17 close personal friend, Jane Doe No. 3? 18 saw from the police report that you indicate; that 18 A. Close personal was not — she was not close 19 is, the police — let me strike that. 19 and personal. She was a girl that I went to school 20 Just so it's clear, it's, the police 20 with. 'did not express that to her because she was the 21 report is not what you said, it's what a police 21 person that had brought me there. 1 expressed that same 22 officer recorded in his or her report that you said 22 statement to my best friend, the only person in this 23 to them; is that correct? 23 entire world that I told. 24 MR. HOROWITZ: Form. 24 Q. Who was that? 25 THE WITNESS: Yes. That's correct. 25 A. My friend 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. EFTA01104164  Page 62 Page 64 The police talked to you about a year 1 you? 2 later, which would have been in approximately 2 A. Yes. 3 Decanber of 'OP 3 Q. Did you ever talk to the FBI? 4 A. Yes. 4 A. Yes. 5 Q. Between the time that you went to S Q. All right. What did you tell.. 6 Mr. Epstein's home and the police talked to you in 6 happened? What did you tell him about Jane Doe 7 December of 'OS, had you, other than speaking with 7 No. 3 and what happened at Mr. Epstein's? 8 had you spoken -- had you told anyone 8 A. About the note and about how she — 9 else what purportedly happened to you at 9 Q. The note? 10 Mr. Epstein's home? 10 A. The note that she wrote to me in class about 11 MR. HOROWITZ.: Form. 11 what she, how she wanted me to go and give just old guys 12 THE WITNESS: Ito 12 a massage and you get like $200. And I said, okay. 13 because I had worked with him that 13 It's right around Christmastime. I have eight people in 14 she did some bad things and that she wasn't a 14 my family that I have to get presents for, you know. 15 good person. 15 And, and then she said if I ever told anybody that she 16 BY MR. CRI7TON: 16 would punch me in the face or beat me up, and -- 17 Q. "She" meaning Jane Doe No. 37 17 Q. Did she say something like, In beat your 18 A. Yes. 18 ass or something like that? 19 Q. Okay. And what did he say? 19 A. Yeah. 20 A. He just couldn't believe. I didn't tell him 20 Q. That's what she said? 21 like the full-on story. I just told him some of the 21 A. Yeah. 22 things that happened and how she had lied to me about 22 Q. All right. So she basically gave you a 23 everything. And then he was, you know, very comforting, 23 note and said, do you have an interest in going to 24 gave me a hug and said, you know, that was wrong, she 24 a- to give a massage to this old — an old guy or 25 should have never done that, you know. 25 8PYs7 Page 63 Page 65 1 Q. Are you aware of anyone else that Jane Doe 1 A. She said it's in the — you know, it's in a 2 No. 3 ever took to Mr. Epstein's home? 2 place where there's a bunch of old guys and there's 3 A. 'heard ofa girl, but I don't, 'don't know 3 young girls. You don't need experience, and you just 4 her name. I heard of a girl going there and the boys 4 give them a massage and they pay good matey just to have 5 were all talking to me at school saying how they can't 5 you massage them. 6 believe some girl went there and she was young and she 6 Q. This is what lane Doe No. 3 told you in 7 did things to him. And I thought at first they were 7 the note? 8 talldng about me, and then it ended up they said this 8 A. Yeah. 9 other girl's name, and I was like, who's that, and then 9 Q. And then she said, if you tell anybody, 10. that was it. And that's all I heard. 10 I'm going to beat you up or I'll beat your ass? 11 Q. Okay. So you don't !mow anyone else who 11 A. Yeah. 12 ever went to Mr. Epstein's home, any other females 12 Q. Okay. And was lane Doe No. 3 a friend of 13 that went? 13 yours at the time? 14 A. I now {mow that a couple of girls were the 14 A. She was -- she sat next to me in classes, and 15 recruiters. 15 she — I'd known her since middle school and high 16 Q. Who? 16 school. 17 A. Ism heard of that Jane Doe No. 4. I don't 17 Q. What was Jane Doe No. 3's reputation; that 18 . know her last name. I know °feed Jane Doe No. 103 18 is, was she someone who was tlice, did you 19 and • 19 consider here tmthful person? 20 Q. With , what did you tell - 20 MR. HOROWITZ: Form. 21 did you tell within a few_imti — well, let me 21 THE WITNESS: She was just more of -- 22 strike that. When did you tell.. about Jane Doe 22 like, she hung cut with more of; like, the 23 No. 3 and what she had done? 23 cooler girls and she, she — !just, !just 24 A. It was weeks afterward. 24 personally didn't really ward to hang out with 25 lint bekeihe PalnsiL aaPolice talked to each 25 her until high school we hung out in the same alti•CIWagiat 17 (Pages 62 to 65) PROSE COURT REPORTING AGENCY, INC. EFTA01104165  Page 212 Page 214 either by phone or by lull'? 1 BY MR. CRITTON: 2 A. By mail. I got mail that's, I think that's 2 Q. The only contact you had with Mr. Epstein 3 how I kept in contact with everyone. I don't, I don't 3 at his home or with him or someone working on his 4 think I had conversations with them on the phone about 4 behalf, other than me as his attorney or Dr. Hall, it 5 who did a medical examination on you — I forgot the 6 Q. Okay. Did she ask you whether you had, 6 question. I have to start again. 7 "she," the agent, ever ask you whether you had had 7 Other than myself who represents B telephone, any telephone conversations with 8 Mr. Epstein and other than Dr. Hall who did an 9 Mr. Epstein? 9 examination of you, you've had no contact either 10 A. 'don't think she asked me that 10 with Mr. Epstein or with anyone who has been acting 11 Q. Okay. And just let me ask just a couple 11 on his behalf at any time other than that one 12 of questions. Is, is you never gave Mr. Epstein 12 occasion in December of '04; is that correct? 13 or anyone on his behalf your phone number, did you? 13 A. Correct. 14 A. Yes, !did. 14 Q. With the FBI, did you ever get a letter 15 Q. To whom did you give your phone number? 15 from them or from the Department of Justice, the 16 A. The lady downstairs, his assistant 16 United State's Attorney's Office, at any time? 17 Q. All right. 17 A. I believe so. They were keeping me updated. 18 A. Or whatever she is. 18 Q. Okay. And at some point did you learn 19 Q. No one, Mr.— you have never spoken with 19 that Mr. Epstein was, had pled guilty to state 20 Mr. Epstein by phone, correct? 20 offenses and was serving time in jail? 21 A. Correct. 21 A. Yes. 22 Q. Okay. He has never texted you nor have 22 Q. Okay. How did you team that? 23 you ever texted him, correct? 23 A. Through the, the letters that I got like once 24 A. Correct. 24 every couple of months or once year. 25 Q. You have never communicated to him, 25 Q. And in any of the letters that you ever Page 213 Page 215 1 communicated with Mr. Epstein or anyone on his 1 received from the, either the FBI or the United 2 behalf over the Internet, either to or from, 2 State's Attorney's office, did they ever tell you 3 correct? 3 you had the ability to bring a civil lawsuit for 4 A. Comet. 4 money damages against Mr. Epstein? 5 Q. You have not used your computer Facebook, 5 MR. HOROWITZ: Form. 6 asocial networking site, to communicate with 6 THE WITNESS: I'm not sure. I don't know 7 Mr. Epstein or anyone on his behalf, correct? 7 actually. 8 A. Correct 8 BY MR. CRITTON: 9 Q. Okay. And if I may just so it's correct 9 Q. And how did — again [ don't want to know 10 you have never texted or no one on behalf — strike 10 any — is the first lawyer that you met from the law 11 that. You have had no contact by phone, text, 11 firm that your, that your, that you currently 12 Internet, computer with Mr. Epstein or anyone acting 12 employ, is that Mr. Herman? 13 on Mr. Epstein's behalf correct? 13 A. Correct. 14 MR. HOROWITZ: Form. 14 Q. Okay. And where did you first meet 15 THE WITNESS: Correct, 15 Mr. Herman? 16 BY MR. CRITTON: 16 A. My mother contacted him. 17 Q. Okay. Did, the only contact that you ever 17 Q. Okay. And bow did she get in contact with 18 had with Mr. Epstein or really anyone on his behalf 18 him, do you know? 19 was that one-time visit in the latter part of 19 A. I believe she read about one of the other 20 December of 2004, correct? 20 girls that had come out and talked and spoke about her 21 A. Well, Dr. Hall and now you. 21 day with Mr. Epstein, and then she wanted me to talk to 22 Q. But that's a different issue. Back in the 22 somebody as well. 23 time period — 23 Q. Is this someone who had filed a lawsuit 24 MR. HOROWITZ: That's a good answer. 24 against Mr. Epstein — 25 25 MR. HOROWITZ: Form. 5 (Pages 212 to 215) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 7be26481-1493-4605-a692-6d620d5447d6 EFTA01104166  Page 2 :") Page 32 1 would that be generally -- well, let me see. When 1 times a week on that,1 would say, a regular basis; 2 you saw Dr. Kliman that was about a year ago, I 2 would that be a fair statement? 3 think his visit with you. And I actually, I think I 3 A. Yes. 4 have the date someplace. It was, I think it was on 4 Q. And I assume that's a choice that you 5 December 4th of '08. I'll represent to you that's 5 make. You obvi