📄 Extracted Text (11,824 words)
Page I
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-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
VIDEOTAPED DEPOSITION OF
JANE DOE NO. 3
Friday, February 19, 2010
10:07 - 5:09 p.m.
250 Australian Avenue
Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Nofary Public, State of Florida
Prose Court Reporting Services
Job No.: IIII
EXHIBIT
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Page 82 Page 84
1 any additional sworn testimony regarding Mr. Epstein 1 Q. Okay. Did you, did you, did she tell you
2 to anyone? 2 that before you ever went to Epstein's home?
3 A. No. 3 A. Yes.
4 Q. Did you ever give a handwritten report to 4 Q. Okay. And what was the occasion of her
5 anyone as to what occurred at Mr. Epstein's house, 5 telling -- her, telling you what had occurred
6 and I'm not interested again in what happened, once 6 at Epstein — or that she had been to Epstein's
7 you hired Mr. Herman? 7 hone? Do you want me to ask that again —
8 A. I don't remember. 8 A. Yes.
9 Q. At any time — well, let me ask it this 9 Q. — because I confused myself.
10 way: After you filed your — or after the Palm 10 You said that.. told you, before
11 Beach Police Department met with you, Officer 11 you first went to Mr. Epstein's house which you
12 Recarey met with you, did you ever discuss that 12 described as being approximately in June of '04,
13 ' that is the conversation you had with them 13 that she had been to Epstein's home; is that
14 with , that is this is what they asked me; 14 correct?
15 what did they ask you? 15 A. Yes.
16 A. What? 16 Q. Okay. And, and what was the occasion of
17 Q. You said.. was around you at the 17 her telling you, that is how did it come about that
18 dine - 18 she told you she had been to Epstein's home?
19 A. Yes. 19 A. How did she ten me?
20 Q. — when the Palm Beach Police Department 20 Q. No. What was the occasion? Where were
21 came' correct? 23. you and how did you — how did the subject come up?
22 A. Yes. 22 A. asked me if I wanted to do it.
23 Q. Okay. After — did they interview her as 23 Q. SAM meaning
24 well the same day? 24 A.
25 A. No. 25 Q. And where were you-all at the time?
Page 83 Page
1 Q. Okay. Do you know whether she ever went 1 A. At a girlfriend's house.
2 to Epstein's? 2 Q. Whose house were you at?
3 A. Yes. 3 A. Jane Doe No. 4's.
4 Q. Okay. And how, how did you know that? 4 Q. Jane Doe No. 4 who?
5 A. She told me. 5 A. Doe No. 4.
6 Q. Okay. Did she tell you before the police 6 Q. And how did you know Jane Doe No. 4?
7 A. I gew up with her in MI I went to
7 department ever contacted you?
8 A. Yes. 8 school with her.
9 Q. Okay. And did you know.. -- was she 9 Q. Same grade?
10 one of your good friends at the time? 10 A. No.
11 A. Yes. 11 Q. Older; younger?
12 Q. Okay. She's still a good friend? 12 at Older.
13 A. Yes. 13 Q. How much older?
14 Q. Okay. Do you know whether she's a 14 A. A year.
15 plaintiff or has ever filed any type of claim? 15 MR. MERMELSTEIN; Just to be dear, your
16 A. I don't know. 16 question as to who was older, her or Jane Doe
17 Q. Okay. Did you ever tell her that you had 17 Na 4?
18 filed a claim? 18 BY MR. CRITTON:
19 A. No. 19 Q. I'm assuming you meant Jane Doe No. 4 was
20 Q. She just knows that you went to Epstein's 20 a year older than you.
21 home? 21 A. Yes, sir.
22 A. Yes. 22 MR. CRITTON: I think it was just you.
23 Q. Okay. Did she ever tell you what happened 23 MR. MERMELSTEN: I'm the only one that
24 at Epstein's home? 24 was confused, right?
25 A. Yes. 25 MR. CRITFON: Yeah
22 (Pages 82 to 85)
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1 BY MR. CRITTON: 1 A. Don't know exactly where I was. I deal
2 Q. And Jane Doe No. 4, is she from pretty 2 remember. She told me that she gave a massage to
3 much a middle class family as well? 3 Jeffrey for $200.
4 A. Yes. 4 Q. Did she tell you how many times she'd done
5 Q. All right. AM Jane Doe No.4 is the one, 5 it?
6 she's a soccer player, wasn't she? 6 A. No.
7 A. Yes. 7 Q. Did you ask her about Jeffrey?
8 Q. And did you and Jane Doe No. 4 — well, 8 A. No.
9 let me stile that. 9 Q. Did you say, what are you doing giving
10 Let's see, if you went in 10 did she tell you how old Jeffrey was?
1.1 approximately June of'04, approximately when did 11 A. No.
12 this conversation take place, how many months before 12 Q. Okay. Had you ever heard — or let me
13 you ultimately went? 13 strike that.
14 A. What conversation? 14 At the time that., mentioned that,
15 Q. Well, you said theta asked you, if I 15 first mentioned to you that she had given a guy
16 understood you, asked you if you wanted to go? 16 named Jeffrey a massage for $200, had you, had..
17 A. Yes. 17 ever talked to you at all?
18 Q. Okay. Is that the first time.' had 18 A. Yes.
19 ever brought it up to you? 19 Q. And had talked to you a number of
20 A. No. 20 months before you eventually went to Mr. Epstein's
21 Q. So, at least at the time that 23. home; is that correct?
22 brought up going to Mr. Epstein's house or going 22 A. Yes.
23 to did you know his name was Epstein at that 23 Or to Jeffreys home. Where were you when
24 time? 24 first said something to you about
25 A. Jeffrey. 25 Jeffrey?
Page 87 Page 89
1 Q. Just Jeffrey. All right. When she said, A. Jane Doe No. 4's house.
2 she asked you, apparently again, if you were 2 Q. Okay. AM who was there at the time, you,
3 interested in going to Mr. — to, to Jeffrey's house 3 Jane Doe No.4, ; anyone else?
4 to give him a massage, at least on this occasion 4 A. Nope.
5 Jane Doe No. 4 — you were at Jane Doe No. 4's 5 Q. And how many months was this prior to your
6 house, and.. was there 6 ultimately going to Jeffreys home?
7 A. No. 7 A. I don't remember.
B Q. — as well as..? Is that wrong? Q. Four months, six months?
9 A. That is wrong. 9 A. I don't remember.
10 Q. Okay. Then let me ask a question. 10 Q. A number of months?
11 thought you — had you learned that II., had, 11 A. I really don t remember.
12 had been at Jeffrey's house sometime before this 12 Q. You don't know whether it was a day or a
13 conversation? 13 number of months?
14 A. Yes. 14 MR. MERMELSTE1N: Objection. She's
15 Q. By "this conversation," I mean when 15 answered the question.
16 asked you, you were at Jane Doe No. 4's house. 16 THE WITNESS: I don't remember. 1, I
17 A. Yes. 17 don't remember.
18 Q. How much earlier was the conversation 18 BY MR. CRITTON:
19 where told you she had been to Jeffrey's house? 19 Q. I just want you to make sure, because I
20 A. A lot earlier. 20 want to make sure that the ladies and gentlemen
21 Q. A number of months? 21 understand.
22 A. Probably, yeah. 22 So, the first conversation where
23 Q. And when • told you that, what did she 23 ever referenced going to JeffieStouse, you
were at Jane Doe No. 4 home, you, MI and Jane Doe
24 tell you; that is what were the circumstances of her 24
innanis
Who was there? Where were2 ou?
„...... 25 No. 4 were the onlyczle there, correct?
23 (Pages 86 to 89)
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1 A. Correct. 1 Q. Ever done it with a, with a guy?
2 Q. And then we know you went to Mr. Epstein's 2 A. No.
3 borne, or at least by your testimony, sometime in 3 Q. A boyfriend?
June of '04; is that correct? 4 A. No.
5 A. Yes. 5 Q. Did Jane Doe No. 4 say anything at that
6 Q. So, and is it your testimony as to when 6 time when asked you?
7 this conversation first took place, where 7 A. Excuse me. I don't remember.
8 asked you if you wanted to go to Jeffrey's home, you 8 Q. Did you know that Jane Doe No. 4 had
9 don't recall whether that was a week before you 9 gone —
10 ultimately went or months; is that correct? 10 A. No.
11 A. Correct. 11 Q. — to Epstein's home at that time?
12 Q. What did say to you the first 12 A. No.
13 occasion at Jane Doe No. 4's home? 13 Q. Okay. At some point she told you, didn't
14 A. Excuse me. You can make quick money, 200 14 she?
15 bucks just to give a guy a massage. 15 A. She didn't tell me, no.
16 Q. And did she tell you about who the guy 16 Q. At some point did you come to team that
17 was? 17 Jane Doe No. 4 had been to Mr. Epstein's home?
18 A. Yeah, his name is Jeffrey Epstein. 18 A. Yes.
19 Q. And she said Epstein? 19 Q. Okay. From whom did you learn that fact?
20 A. Yes. 20 A. Word ofmouth.
21 Q. Okay. And did she tell you where he 21. Q. When you say, "word of mouth," meaning
22 lived? 22 what, it was just common knowledge?
23 A. On Palm Beach. 23 A. We all hung out together.
24 Q. I assume you'd been to Palm Beach before. 24 Q. So, at some point somebody mentioned that
25 A. Yes. 25 Jane Doe No. 4 had been to Epstein's house?
Page 91 Page 93
1 Q. And did she tell you anything about it, 1 A. Yes.
2 that is, his age, what he did? 2 Q. Did you ever ask Jane Doe No. 4, say, hey,
3 A. No. 3 how many times have you been to Epstein's house?
4 Q. Did she tell you anything about how old he 4 A. No.
5 was, that is, whether he was your age, whether he 5 Q. Okay. Did — when the word ofmouth that
6 was an older person? 6 Jane Doe No.4 had been to Mr. Epstein's house, was
7 A. No. 7 that kind of discussed when you guys would get
8 Q. Did you ask? 8 together, that is, who had been to Epstein's house?
9 A. I don't remember. 9 A. Can you repeat that, please?
10 Q. Did, did you say, wait a minute, why 10 Q. Sure. You said you learned that Jane Doe
11 would — well, let me strike that. 11 No. 4 had gone to Mr. Epstein's house by word of
12 Did she,M. say that she had been 12 mouth be you were all friends.
13 there? 13 A. Yes.
14 A. Yes. 14 Q. Okay. And somebody brought it up, but you
15 Q. Did she say that she'd given him a massage 15 can't identify who the person is that brought it up.
16 before? 16 A. Yes.
17 A. No. 17 Q. Okay. And did you team from at least a
18 Q. Okay. Did you say, why are you asking me 18 these conversations, before you ever went to
19 if I would be interested in going? 19 Mr. Epstein's house, that Jane Doe No. 4 had been
20 A. I don't remember. 20 there on many occasions?
21 Q. Okay. Had you ever given a person a 21 A. No, I did not know that.
22 massage before, before that period of time? 22 Q. Okay. Did you — you knew for sure she'd
23 A. Yes. 23 been there once, but you didn't know how many times
24 Q. Okay. To whom had you given a massage? 24 she'd been there?
25 A. My mom, my cousin. 25 A. Correct.
24 (Pages 90 to 93)
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1 Q. All right. And how much longer did you, 1 friends?
2 the two of you continue to date? 2 A. Excuse me. Yes, me and Jane Doe No. 4 were
3 A. Maybe about two years, a year and a half. 3 good friends, yes.
4 Q. Two years after that? 4 Q. Are you and Jane Doe No. 4 still good
5 A. Yes. 5 friends?
6 Q. So you dated.. about a year, a year to 6 A. No.
7 ayes' and a half before you had this conversation 7 Q. Okay. When did you, you and Jane Doe
8 about giving a massage to Mr. Epstein, and then you 8 No.4 stop being good friends?
9 dated another two years after that? 9 A. When she went lit
10 A. About a year after that. 10 Q. When she went t
11 Q. Okay. 11 A. Yes.
12 A. Yeah. 12 Q. Do you know whether Jane Doe No. 4 is a
13 Q. All tight. So how much time transpired or 13 plaintiff in a lawsuit against Mr. Epstein?
14 passed before you then had a conversation with — 14 A. I don't know.
15 another conversation about the possibility of giving 15 Q. Okay. Do you know if I -- do you know
16 a massage to Jeffrey? 16 whether your current lawyer is representing Ms. Doe
17 A. 'have no idea. 17 No.4?
18 Q. Was ft a month, a week, a year, two years? 18 A. Yes.
19 A. Awhile. 19 Q. Okay. How do you know that?
20 Q. Was it after then? 20 A. Because I've spoken with her.
21 A. I was already broken up with.. 21 Q. With Jane Doe No. 4?
22 Q. All right. So it had to have been about a 22 A. (Witness nods head.)
23 year later. A year — 23 Q. Okay. And so —
24 A. Me and him were on and off. We didn't have a 24 11133 COURT REPORTER: Is that a yes?
25 steady relationship. 25 IHE WITNESS: Yes. Yes, sony.
Page 103 Page 105
1 Q. So now yout ves dating or 1 BY MR. CRITTON:
2 you're on and off with
i at this point in time? 2 Q. Okay. And she told you — when did you
3 A. Yes. 3 last speak with Jane Doe No. 4?
4 Q. And what happens? How does the topic come 4 A. A couple of days ago.
5 up again? 5 Q. All right.
6 A. I was approached again bylM. 6 A. I need to take a break, please.
7 Q. Where were you at the time? 7 Q. Can I have two more minutes?
8 A. I don't remember. 8 A. No, I'm tired. I leed to take a break,
9 Q. Do you remember who was then? 9 please.
10 A. I don't remember. 10 MR. CRITTCK All right
11 Q. How often — were you and good 11 THE VIDEOGRAPHER: We're going off the
12 friends? 12 record at 11:43 a.m.
13 A. No. 13 (A brief recess was held.)
14 Q. Were you friends? 14 THE VIDEOGRAPHER: We're back on the
15 A. Yes. 15 record at 11:57 a.m.
16 Q. Okay. More acquaintance-type friends? 16 BY MR. CRITTON:
17 A. Yes. 17 Q. We were talking about Jane Doe No. 4, and
18 Q Okay. Was she good friends with Jane Doe 18 you said that you spoke with her a couple of days
19 No.4. Were she and Jane Doe No. 4 good friends? 19 ago.
20 A. I don't 'mow their relationship. 20 A. Yes.
21 Q. Okay. Well, at least the fast time 21 Q. How long have you known that Jane Doe
22 when -- that you're at Jane Doe No. 4's house when 22 No. 4 is a plaintiff against Mr. Epstein?
23 mentioned to you, do you, were you interested 23 A. A little while.
24 in making — giving a massage to Jeffrey, there was 24 Q. What's a little while mean to you, a
25 only the three of you. So were any of you good 25 month, a week, a yea/7_
27 (Pages 102 to 105)
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1 A. Correct. 1 Q. Ever done it with a, with a guy?
2 Q. And then we know you went to Mr. Epstein's 2 A. No.
3 home, or at least by your testimony, sometime in 3 Q. A boyfriend?
4 June of '04; is that correct? 4 A. No.
5
7
A. Yes.
Q. So, and is it your testimony as
this conversation first took place, when
a 5
6
7
Q. Did t Doe No. 4 say anything at that
time where asked you?
A. Excuse me. I don't remember.
8 asked you if you wanted to go to Jeffrey's home, you 8 Q. Did you know that Jane Doe No. 4 had
9 don't recall whether that was a week before you
10 ultimately went or months; is that correct? 10 A. No.
11 A. Correct. 11 Q. — to Epstein's home at that time?
12 Q. What di.. say to you the first 12 A. No.
13 occasion at Jane Doe No. 4's home? 13 Q. Okay. At some point she told you, didn't
14 A. Excuse me. You can make quick money, 200 14 she?
15 lucks just to give a guy a massage. 15 A. She didn't tell me, no.
16 Q. And did she tell you about who the guy 16 Q. At some point did you come to learn that
17 was? 17 Jane Doe No. 4 had been to Mr. Epstein's home?
18 A. Yeah, his name is Jeffrey Epstein. 18 A. Yes.
19 Q. And she said Epstein? 19 Q. Okay. From whom did you learn that fact?
20 A. Yes. 20 A. Word of mouth.
21 Q. Okay. And did she tell you where he 21 Q. When you say, "word of mouth," meaning
22 lived? 22 what, it was just common knowledge?
23 A On Palm Beach. 23 A. We all hung out together.
24 Q. I assume you'd been to Palm Beach before. 24 Q. So, at some point somebody mentioned that
25 A. Yes. 25 Jane Doe No. 4 had been to Epstein's house?
Page Page 93
1 Q. And did she tell you anything about it, 1 A. Yes.
2 that is, his age, what he did? 2 Q. Did you ever ask Jane Doe No. 4, say, hey,
3 A. No. 3 how many times have you been to Epstein's house?
4 Q. Did she tell you anything about how old he 4 A. No.
5 was, that is, whether he was your age, whether he 5 Q. Okay. Did -- when the word of mouth that
6 was an older person? 6 Jane Doe No. 4 had been to Mr. Epstein's house, was
7 A. No. 7 that kind of diqmosed when you guys would get
8 Q. Did you ask? 8 together, that is, who had been to Epstein's house?
9 A. I don't remember. 9 A. Can you repeat that, please?
10 Q. Did, did you say, wait a minute, why 10 Q. Sure. You said you learned that Jane Doe
11 would — well, let mE rike that. 11 No.4 had gone to Mr. Epstein's house by word of
12 Did she,MR, say that she had been 12 mouth because you were all friends.
13 there? 13 A. Yes.
14 A. Yes. 14 Q. Okay. And somebody brought it up, but you
15 Q. Did she say that she'd given him a massage 15 can't identify who the person is that brought it up.
16 before? 16 A. Yes.
17 A. No. 17 Q. Okay. And did you learn from at least
18 Q. Okay. Did you say, why are you asking me 18 these conversations, before you ever went to
19 if I would be interested in going? 19 Mr. Epstein's house, that Jane Doe No. 4 had been
20 A. I don't remember. 20 there on many occasions?
21 Q. Okay. Had you ever given a person a 21 A. No, I did not know that.
22 massage before, before that period of time? 22 Q. Okay. Did you — you knew for sure she'd
23 A. Yes. 23 been there once, but you didn't know how many times
24 Q. Okay. To whom had you given a massage? 24 she'd been there?
25 A. My mom, my cousin. 25 A. Correct.
aoaata- ekrikgeWAX•Stsfause... face.140-•—
24 (Pages 90 to 93)
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Q. Okay. Did, did you at some point get the 1 A Not that I remember, no.
Okay. Well, did you say, did you say to
2
3
4
drift — not the drift — did you, did you come to
at least understand, based on the conversations that
were going on before you ever went to Mr. Epstein's,
2
3
4
MI as well, what do I have to do for $200?
A. Yes.
5 that she had been there a number of times? 5 Q. Okay. And what did she say?
6 A. No. 6 A. A massage.
7 Q. Just that she had been there? 7 Q. Okay. Did you say, what's the massage
8 A. Correct. 8 consist of?
9 Q. All right. But you understood that she A. I did not say that.
10 had also gone to Epstein's to give him a massage? 10 Q. Okay. Did you say, how long does it have
11 A. Correct 11 to last?
12 Q. Who else did you lean other thanMI 12 A. Yes.
13 and Jane Doe No. 4, at least on the first occasion, 13 Q. And what did she say?
14 did you learn or know that had given Mr. Epstein a 14 A. Half an hour.
15 massage, or purport had given him a massage? 15 Q. All right. And did she tell you where
16 A. I didn't know given, has given Epstein a 16 you'd have to go?
17 massage. 17 A. Yes.
18 Q. You just }mew that she asked you if you 18 Q. Did you say, well, who's going to go there
19 would be interested? 19 with me?
20 A. Yes. 20 A. Yes.
21 Q. Okay. And did you ask her at that time, 21 Q. All right. And she said?
22 say, did you give — have you ever given him a 22 A. She would.
23 massage? 23 Q. All right And did she say — did you
24 A. No. 24 discuss how you were to get there?
25 Q. Okay. At the time she asked — first 25 A. She already said she would drive.
Page 95 Page 97
1 asked you, when you were at Jane Doe No. 4's house, 1 Q. Okay. And what, what in, at least in your
2 what was your response? 2 thinking process at that time would cause you even
3 A. I don't know; I'll have to think about it. 3 to Nththat you might have some interest in doing
4 Q. Okay. What questions did you ask before 4 that, that is, going to give some unknown person,
5 you even said, I don't know; TR have to think 5 unknown to you, at their home a half-hour massage
6 about it? 6 for 200 bucks?
7 A. What happens? 7 M.R. MERMELSTEN: Objection to form.
8 Q. Did you — and what did she say? 8 THE WITNESS: Can you repeat that?
9 A. You give him a massage. 9 MR. CRITTON: No, but Cindy can. Cindy
10 Q. Okay. And what did you say, well, I have 10 will. She can and will.
11 never really given --1have never given a man a 11 THE WITNESS: Okay.
12 massage, did you tell her that? 12 (The requested portion of the record was
13 A. No. 13 read by the reporter.)
14 Q. And have you ever given a boyfriend a 14 THE WITNESS: So you want to know my
15 massage, did I ask you that? 15 interest?
16 A. You did ask me that. 16 BY MR. CRITTON:
17 Q. Okay. You were, you were — had, already 17 Q. Yeah, why, why — why you, who is
18 at that point in your time, 2004, had had 18 apparently about 16 at the time would have any
19 relationships with other males, true? 19 interest in giving a massage to some unknown male
20 A. Yes. 20 that you had never met, a half-hour massage which
21 Q. Okay. And you were sexually active at 21 you didn't know what it consisted of, for 200 bucks?
22 that point in time, true? 22 A. I was young and it was $7.00.
23 A. Yes. 23 Q. And if I understood your earlier
24 Q. All right And you had never given a male 24 testimony, you didn't say, well,Et have you
25 a massage? 25 dame it?
25 (Pages 94 to 97)
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anything improper or otherwise. 1 after your 17th birthday. You just don't remember?
2 Is there — what, if anything, has caused 2 A. I first visited Jeffrey, like I stated before,
•
3 you now that we have finished about an hour or 3 soon after I turned 16.
4 45-minute lunch break that maybe June of'04 was not 4 Q. Okay. But we established just by simple
5 the right date, approximately, that you went to 5 math —
6 Mr. Epstein's home for the first time? 6 A. I'm not a math genius.
7 A. Okay. 7 Q. None ails arc, that's why we Gan I.
8 THE VIDEOGRAPHER: You're fine. 8 if l add 16 to MI because you were born in M. M.
9 THE WITNESS: Okay. Just thinking about 9 that takes me to 2004, Mardi of 2004. Ail rig t:.
10 it, like, I don't want, I don't want to matte 10 I'm not hying to be tricky here. I'm hying to •
11 exact dates and may be wrong. 11 would you agree with me, 16 and IN is
12 BY MR. CRITTON: 12 A. Sixteen, yes.
13 Q. Could it have been *05? 13 Q. All right. So if it MS Sal/clime after
14 A. It could have been, yes. 14 that, then it had to have been in '04, or do you
15 Q. Would it have been before your birthday in 15 want to say it still could have been '05?
16 '05 for the first time, or could it have been 16 A. 'still say it was alter I was 16.
17 afterwards? 17 Q. Okay. And it still could, could have been
18 A. After, I think. 18 in '04; it could have been in 'OS. You're just not
19 Q. Okay. 19 sure?
20 A. I don't know. 20 A. Correct
21 Q. So all you know is that you went to 21 Q. All right. Okay. So let's just stick with
22 Mr. Epstein's home four times. It could have 22 the first Umiak& So they — I know you, you
23 started in '05. It could have started in '04. You 23 told us that =asked if you wanted to go. You
24 just can't tell us as you sit here today? 24 were with Jane Doe No. 4 only. You were at Jane Doe
25 A. Right, I can't tell you exact dates. 25 No. 4's house, just the three of you. You said
Page 215 Page 217
1 Q. Okay. And you can't tell us — I mean, 1 you'd think alugatiaiwient back. You talked
2 there's nothing about — well, there, there was. 2 about it with IMeho was your boyfriend
3 You said that one of the visits you had you 3 at that time. He basically said, he discouraged
4 remembered seeing a — some sort of Christmas 4 you, as you described earlier, comet?
5 decoration. 5 A. Yes.
6 A. Correct. 6 . Then sometime later there, now you i
7 Q. Okay. And instead of being in 7 and were either between, either weren't dating
8 December-ish of'04, assuming that's when Christmas 8 anymore or you were — I think you said yigialaren't
9 decorations come out, it could have been as well 9 dating anymore, so somebody — was that Mlagain
10 December of '05. Is that possible? 10 asked you then again?
11 A. I don't know. 11 A. Yes
12 Q. Well, Pm asking you, is that possible, it 12 Okay. And where were you at the time
13 could have been December of '05 as distinct from 13 =asked you?
14 December of'04, or you just don't know one way or 14 A. I don't remember.
15 the other? 15 Q. All right. And when she asked you, do you
16 A. I just know that it was around Christmas one 16 remember whether anyone else was there at the time?
17 of the times. 17 A. I don't remember.
18 Q. But you can't tell me whether it was '04 18 Q. And did — what did she say to you?
19 or '05? 19 A. Do you want to make 5200 and give a guy a
20 A. Correct. 20 massage, or Jeffrey a massage.
21 Q. Because you don't remember when the first 21 Q. And you said — did you say something
22 time was? 22 like, we talked about this before, I said, no?
23 A. Correct. 23 A. No.
24 Q. And that could have been sometime in — 24 Q. Okay. What did you say this time?
25 after your 16th birthday. Could have even been 25 A. I'll call you back. nit get back toyou,
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something along that line. 1 that you had had. She had set it up and she said,
Q. And what happened then? 2 okay, we're going to go at such-and-such a time.
3 A. I agreed to do so and she set it up. 3 And that's all she had said to you at least up until
4 Q. Did you, did you call her or did she call 4 the time that she picked you up?
5 you or did you just see her again? 5 A. Cared.
6 A. She initiated it 6 Q. Okay. That is the phone conversations,
7 Q. Okay. What, she called you or did she see 7 that is the in-person conversations, time one, when
8 you? 8 you decided no; the second time you said, I'll think
A. She called sm. 9 about it the third time is you called her back and
10 Q. Okay. And is, and as far as you, you were 10 said, it's okay,FIldo it; and the fourth time is,
11 concerned is that at least you were going to go 11 she said — she calkd you back and said, okay, l
12 there, give this Jeffrey chap a massage, and that 12 set it up for such-and-such a time and I'll pick you
13 was the extent of the conversation? 13 up at such-and-such a time. Is that substantially
14 A. At first, yes. 14 correct, or correct?
15 Q. When you say "at first," you mean at 15 A. She asked me the first time. I had spoken
16 least, at least from the first time she told you — 16 with my boyfriend, so no. And then she asked me the
17 A. Yes. 17 second time, I told her rd to think about it. I agreed
18 Q. — the second time? 18 to it, she set it up.
19 A. Yes. 19 Q. Okay. So second time you did — I thought
20 Q. Okay. And even when she spoke to you on 20 you said you, you told her you'd think about it.
21 the phone, she basically said — or let me say it, 21. A. I said I would think about it, and that I
22 the first time she asked you if you want, you were, 22 agreed to it.
23 when you were at Jane Doe No. 4's house, if you 23 Q. The same —
24 wanted to go give this — give Jeffrey a massage for 24 A. The second time.
25 200 bucks, that was the extent of the conversation, 25 Q. Right there at the second occasion that
Page 219 Page 221
1 correct? 1 she mentioned it to you?
2 A. Yes. 2 A. Right
3 Q. Okay. The second time that she mentioned 3 Q. You didn't call her back? You said --
4 it, again, it was pretty similar as it was give this 4 A. No, I —
5 Jeffrey chap a massage, 200 bucks? 5 Q. You thought about it right then and there?
6 A. Yes. 6 A. No, I called her back.
7 Q. If you want to do it. And you said, I'll 7 Q. Okay. That's what rm getting at.
8 think about it? 8 A. Yes.
9 A. Yes. 9 Q. And you called her back and said this was
10 Q. You called her back and said, rit do it? 10 what, a two, a ten-second conversation, and said,
11 A. Yes. 11 okay, ru do it?
12 Q. Okay. And then she said, okay, P11 let 12 A. Then she said she'll --
13 you know? 13 Q. Yes? First of all, is that yes?
14 A. Shell set it up. 14 A. Yet
15 Q. All right And so at least at that time, 15 Q. It was like a second ten-second
16 when you talked to her on the phone and she then 16 conversation?
17 called you back and set it up, as far as you were 17 A. Yes.
18 concerned at that time you were going to give a 18 Q. And then she called you back for another
19 half-hour massage for 200 bucks? 19 ten-second conversation that said, okay, I have set
20 A. Yes. 20 it up for such-and-such a time, and I'll pick you
21 Q. And that was the extent of the 21 up?
22 conversation or, at least, the two conversations and 22 A. Yes.
23 the two phone calls that you two had had? 23 Q. Okay. And that was the extent of the
24 A. At that — what do you mean? 24 conversation, just basically a scheduling issue?
25 0. That was the extent of the conversations 25 A. Correct
11 (Pages 218 to 221)
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by cynthia hooking
Electronically signed by cynthia hopkins da88od07-Occo-4c7a-95ol.d4dVlob3cf36
Electronically signed by Cynthia hopkins
EFTA01104179
Page I 4 2 Page 144
1 THE WrINESS: Could you restate that? 1 BY MR. CM-TON:
2 BY MR. CRITTON: 2 Q. Because if any of those four people, li ad
3 Q. Sure. You said before you went to 3 Jane Doe No. 4, Jane Doe No. 7 or
4 r or.n.tein's the first time, you learned or heard 4 said anything that would have caused you any
5 that she and Mr. Epstein had gotten into a 5 concern, would it be a correct statement you, more
6 disagreement, correct? 6 likely than not, would not have gone?
7 A. Yes. 7 MR. MERMELSIE1N: Objection to form.
8 Q. Okay. Did you ask her what the nature of 8 THE WITNESS: Yeah.
9 the disagreement was? Because you wouldn't want to 9 BY MR. CRITTON:
10 go to someplace where you might have a disagreement, 10 Q. All right. Because they were friends of
11 right? 11 yours?
12 A. Coned. 12 A. Yes.
13 Q. All right. And what did she say to you 13 Q. All right. And if somethi
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