Page 101 1 have a cell phone or anything. 2 Q. And when did these conversations occur? 3 A. Exactly, I don't know when. It was just after 4 I knew that she had the job with him and stuff. 5 Q. Okay. So you were -- something about all this 6 made you suspicious that she was sexually active, is 7 8 where I think we started the question. A. It wasn't so much about that. But then I 9 started question her because she would leave, you know, 10 and occasionally I'd see her come home and I'd say, 11 , you have, like, a such a low-cut blouse on. 12 And you got such short, short shorts. Why -- I don't 13 understand. 14 Oh, Mom, I changed when I got in the house. 15 Q. Anything else that made you suspicious? 16 A. She did come home sometimes and I smelled 17 alcohol on her breath. 18 And I said, your employer lets you drink? 19 was concerned about that. 20 Q. And what did she say? 21 A. She said, yeah. She says, the people in the 22 kitchen are real nice and she was allowed to go -- I 23 guess there was a certain refrigerator or something that 24 sometimes she'd go sit in the kitchen. And the cooks 25 would cook for her, too. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Sile1eSe8-101b-47f7-b728-efS4d28436cf 3506001 Page 101 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006224 EFTA00158117
Page 102 1 Q. So what did you do? Did you pick up the phone 2 and call this person and say, I don't want my -- what 3 you said was a 15 year old daughter over there drinking? 4 A. I tried to get in touch with him. I remember 5 that. But I couldn't get through. 6 Q. Well, did you keep trying? 7 8 A. Did I keep trying? Yeah. Q. Did you ever get in touch with him? 9 A. No. It was like the man vanished. 10 Q. Did you get in the car and drive over there? 11 A. Nobody answered the door. 12 Q. Did you get in your car and drive over there? 13 A. Yes, I did and nobody answered the door. 14 Q. What did you do? Tell me about this occasion 15 when you got in the car and drove over there. Who went 16 with you? 17 A. Nobody. I went by myself. 18 Q. And when was this? 19 A. It had to be after told me that her and 20 her niece weren't interested in working for him. 21 That's -- time of year, I don't really remember. But I 22 know it was daylight out. I don't remember the time. 23 Q. So what did you do? You went to the house? 24 A. Yeah, I tried to knock on the door but there 25 was so many doors I just didn't know where I was PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e0-101b-47ff-b728-ef54d28436d 3506-001 Page 102 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 71819110/ 15, and 17 EFTA_00006225 EFTA00158118
Page 103 1 knocking. 2 Q. What, did you knock on more than one door? 3 A. Yeah. 4 Q. Which door did you knock on? 5 A. There's a garage that had a big, long thing 6 here. And then there's a front door. And there's 7 another house because said something about this 8 house in the back. 9 Q. So how many doors did you knock on? 10 A. Three. 11 Q. And -- and you're telling me -- 12 A. Nobody answered. 13 Q. -- there was nobody there and nobody answered? 14 A. No. 15 MR. : Object to the form. 16 BY MR. LUTTIER: 17 Q. So did you come across anybody on the grounds? 18 A. No. 19 Q. So what did you do next? 20 A. I got in my car and left. 21 Q. And for what purpose had you gone there on 22 that occasion? 23 A. Just because I think I wanted to know why he 24 allowed her to drink. 25 Q. Well, in fact, you were suspicious about what PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Seelelle8-101b-47ff-b728-efS4d28436cf 3506001 Page 103 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006226 EFTA00158119
Page 104 1 was going on by then, weren't you? 2 A. Yeah, after told me she didn't want to 3 work for her and didn't have the heart to tell me, 4 I guess maybe she knew more of the story than I did at 5 that point. 6 Q. Did you ask anything else, why isn't it. 7 for your niece? 8 A. Yeah, I did ask 9 Q. And what did she say? 10 A. And just said her niece just said it 11 wasn't for her. 12 Q. Did you inquire further? 13 A. No. 14 Q. Did you -- by now if you're suspicious, did 15 you ask your daughter more about what was going on? 16 A. Yeah. 17 Q. And you said your daughter was always truthful 18 with you, right? 19 A. Yeah. So she said -- 20 MR. : Object to the form. 21 THE WITNESS: Yeah. 22 So she just said, no, Mom, we're working. 23 And I said, well, why -- your hours are 24 changing now. Like, I don't understand. You know, 25 you don't do a full day or whatever. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1ette8-101b-47(7-0720-ef54d28436cf 3506-001 Page 104 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006227 EFTA00158120
Page 105 1 And she said, no. She said, Mom, his company 2 flies in all the time. 3 And sometimes I know that he's in New York, 4 so -- and she still -- she still goes over there, 5 you know. Because a couple times I knew he was in 6 New York because he called from New York. 7 called from New York and said she still had to go 8 to the house. 9 BY MR. LUTTIER: 10 Q. Who called from New York? 11 A. I'm sorry? 12 Q. Who called from New York? ? 13 A. Yeah. 14 Q. And did she talk to you? 15 A. Yeah. 16 Q. So you talked to ? 17 A. I talked to 18 Q. And when did this conversation happen? 19 A. It was late in the afternoon. She said that 20 Jeffrey was coming in with some -- with some friends, 21 but needed to be over there, I guess, like, twc 22 hours or three hours before Jeffrey came in with the 23 people to make sure everything was, I guess, in place. 24 Q. And where was ? Do you know whether or 25 not was, in fact, in Palm Beach calling you saying PROSE COURT REPORTING AGENCY, INC. DecIronically signed by Sandra Townsend (401 DecIronically signed by Sandra Townsend (401 gibrieSe8-101b-47f7-b728-0154d28436d 3506-001 Page 105 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006228 EFTA00158121
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 106 that Mr. Epstein was coming in and wanted your daughter to come over? A. Honestly, I don't know. Q. Okay. And by the way, when you're having these conversations with either the time that Mr. Epstein called or when you say you talked to did you ever ask them about -- more about what was going on? A. No. They informed me that she was cleaning and she was doing a good job. They were happy to have her. Q. Well, you told me that Mr. Epstein said she was ironing; is that right? A. She was ironing and she was in charge of, like, the ironing and the laundry. Q. Did you ever have any other conversation with Mr. Epstein where you asked him what was going on? A. No. Q. Did you have a conversation with whe' she called and asked her what was going on? A. No. Q. Did you ever directly confront your daughter about what was going on? A. No. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e0-101b-47ff-b728-e154d28436d 3506.001 Page 106 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006229 EFTA00158122
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Page 108 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Q. Now, by the time that she met and you 17 claim that she was going over to Mr. Epstein's house, 18 had you discovered that your daughter was using drugs? 19 A. I suspected it because I'll tell you what. 20 and this girl, this girl, 21 and , because and used to 22 drive over there a lot. 23 Q. Over where? 24 A. To Jeffrey Epstein's, because I know 25 I worked for him and he was sending MI Lc PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 108 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006231 EFTA00158124
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 109 1 school, too. 2 And then -- I don't know. Then I found out -- 3 I guess then I found out she went to or something, 4 somewhere weird. And we -- I never talked to her -- you 5 know, we never talked to her again. But III s working for Jeffrey, too, cleaning. That's how actually got the job, was through Ililland Q. So what -- the question was about being suspicious that she was using drugs. A. Because -- I'll tell you why. Because I noticed a couple times that -- when I'd see in III II and , they had white powder on their nose. Q. And you knew what that was, right? A. I'm sure it wasn't baby powder. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 109 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006232 EFTA00158125
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1 2 3 4 5 6 Q. When did you first suspect she was using Xanax? 7 A. I didn't know about Xanax. 8 Q. When did you first suspect she was using 9 Xanax? 10 A. I guess when her friends -- I guess when her 11 friends and Jeffrey Epstein turned her on and had her 12 doctor shopping. 13 Q. Well, what do you mean by that? You said two 14 things. 15 A. Oh, she came from Jeffrey Epstein's a few 16 times a little looped. 17 Q. What was she looped on? 18 A. I couldn't tell you because I wasn't there. 19 Q. Well then, how do you know she came from 20 Jeffrey Epstein's looped? 21 A. Because the last I knew she was working. 22 Q. No. No. I want to know, you said she came 23 from Jeffrey Epstein's looped. Did you see her when she 24 came from Jeffrey Epstein's looped? 25 A. Well, when I got to the house and she was PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 90e1e8e0-101b-47ff-b728-ef54d28436d 3506-001 Page 112 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 71819110/ 15, and 17 EFTA_00006235 EFTA00158128
Page 113 1 looped and she told me she just got off of work, that's 2 where I assumed she'd been. 3 Q. Oh, you assumed, -- 4 A. Yes. 5 Q. -- but you didn't know? 6 So you didn't go pick her up from Jeffrey 7 Epstein's? 8 A. No, sir. 9 Q. Well, let's assume that -- that she told you 10 that she'd just gotten off work and you saw her and she 11 was looped. That would have then caused you even 12 greater concern about what was going on at 13 Mr. Epstein's, right? 14 A. Yeah. 15 Q. So did you pick up the phone or go over to 16 Mr. Epstein's at that point to find out why your 17 daughter was -- to use your words -- looped? 18 A. Honestly, no, I didn't. 19 Q. Okay. Because you weren't that concerned 20 about it? 21 A. No, sir. That's not why. 22 Q. Okay. Was she still hanging out with this 23 fellow, , at the time? 24 A. Yes, she was, and 25 Q. And what did you do, if anything, about PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47(743728-ef54d28436cf 3506-001 Page 113 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006236 EFTA00158129
Page 114 1 interceding with her at her age, which was -- what? 2 15, hanging out with this III I and and 3 , who you now have said as to III land 4 , you observed them with white powder on their 5 nose? 6 A. Sir, you know what? It's a very hard thing to 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 say because, you know what? I went to business. So it's just like you if you have children. When you leave your house, do you know what your kids do 24/7? No, I don't. When I leave to go to work, I don't know. My daughter could say she's home and, sir, I don't know if she's there or if she stepped out. Q. Okay. So you say the first time you were aware or concerned about your daughter using Xanax was on some occasion when she was with her friends? A. I didn't say my daughter -- I didn't -- I didn't say I was concerned about my daughter using Xanax at all. You said it, not me. Q. Well, the truth of the matter is, you did believe your daughter was using Xanax, didn't you? A. No, I can't honestly say I did. I had suspicion. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47ff-0728-ef54d28436d 3506-001 Page 114 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006237 EFTA00158130
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Page 117 1 We have to change tapes. 2 VIDEOGRAPHER: Going off the record at 11:28 3 a.m. This marks the end of tape one. 4 (Brief recess.) 5 VIDEOGRAPHER: We're back on the record at 6 11:30 a.m. This marks the beginning of tape two. 7 BY MR. LUTTIER: 8 Q. Now, you say that there were several 9 occasions, I think you described two, where you say you, 10 personally, talked to Jeffrey Epstein on the phone. Do 11 you recall that? 12 A. Yes, I talked to him personally on the phone. 13 Q. Do you know how many times? 14 A. No. 15 Q. And were these occasions when he was at his 16 house in Palm Beach? 17 A. You know, I know a couple of occasions he was 18 in New York getting ready to come back. And just that 19 told when he was coming back to -- that he needs 20 her to work at the house. 21 Q. When you say, he told , I thought you 22 were having this conversation with him? 23 A. No. Sometimes would be there and I'd 24 give her the phone. 25 Q. I want to know PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 SeeletieS-101b-47f7-b728-ef54d28436cf 3506-001 Page 117 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_OYX6240 EFTA00158133
Page 118 1 A. But I know he called. 2 Q. I want to know about now specifically the 3 conversations that you, personally, had with Mr. Epstein 4 on the other end of the phone. That's my question. How 5 many times did it occur that you, personally, had phone 6 conversations with Mr. Epstein? 7 A. I would say, maybe three, four, because he 8 called a couple times to tell me there was some kind of 9 music tickets coming -- he was Fed-Exing her music 10 tickets. 11 Q. On those occasions that you had direct phone 12 contact with Mr. Epstein, was he in his house in Palm 13 Beach? 14 A. I don't know, sir. 15 Q. Do you know where he was? 16 A. No, sir. 17 Q. Now, you said, and there were other phone 18 conversations where he called and all you did was give 19 the phone to 20 A. Yes. 21 Q. You didn't participate in those phone 22 conversations? 23 A. No. If was there, I handed her the 24 phone directly. But on occasion that they would tell me 25 just if I, you know, when I contacted her, let her know PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1eSe8-101b-47ff-b728-ef54d28436d 3506.001 Page 118 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_0000624I EFTA00158134
Page 119 1 if she could work this day or time or whatever. 2 Q. Do you -- did your daughter ever tell you what 3 the basis of her compensation was? 4 MR. : Object to the form. Asked and 5 answered. 6 BY MR. LUTTIER: 7 Q. Did she get paid hourly or by the day? 8 A. No. I never discussed that with her. 9 Q. All right. And did she ever tell you what the 10 total compensation she received was? 11 MR. : Object to the form. Asked and 12 answered. 13 THE WITNESS: No. 14 BY MR. LUTTIER: 15 Q. And by "total," I mean, you know, collectively 16 for a month or two months. 17 A. No. 18 Q. Now, this happened -- this was all occurring 19 during a period of time that you claim you thought she 20 was in school; is that right? 21 A. Yes. 22 Q. Didn't you know that she had already dropped 23 out of school by then? 24 A. No. 25 Q. And you -- were you home on all occasions when PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47f7-b728-ef54d28436cf 3506-001 Page 119 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006242 EFTA00158135
Page 120 1 your daughter went to Mr. Epstein's? 2 A. Absolutely not. 3 Q. So you didn't really know where she was? 4 A. Absolutely not. 5 Q. So in the day, all you knew is, you left and 6 you had no idea if she was in school or at Mr. Epstein's 7 8 or at the beach or anyplace else? A. Correct. 9 Q. And when you came home, all you knew is she 10 was either home or she wasn't home, right? 11 A. That's correct. 12 Q. Did you ever tell her that you didn't want her 13 hanging out with this guy, 14 A. Yeah. 15 Q. And what did you tell her specifically? 16 A. I told her I just didn't want her to hang out 17 with him, that his aunt didn't want them to hang out 18 and... 19 Q. Whose aunt? 20 A. aunt. 21 Q. aunt? 22 A. Yeah. 23 Q. And how did you know aunt didn't want 24 them to hang out? 25 A. Because we've had conversations. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47f7-b728-ef54d28436cf 3506-001 Page 120 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006243 EFTA00158136
1 2 3 4 Q. A. Q. A. Page 121 Well, did she tell you something? No. That is, did aunt tell you something? No. It was just that's when I found out 5 that was a little older than and -- 6 Q. When did you find that out? 7 A. -- the people that -- I would say, maybe 8 was the end of 16, going on 17. And 9 think, was 21, 20. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 121 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006244 EFTA00158137
Page 122 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. But on the other hand, you told me that was taking her to Mr. Epstein's? A. Correct. But I wasn't aware of that. I was at work. Q. So I thought you -- so the only way you know that was taking her to Epstein's is something somebody told you at some point later in time? A. No, because in the very beginning when met Mr. Epstein through and this girl, because Mr. Epstein needed additional help at his estate. Q. Well, somebody told you that, right? Somebody told you that Mr. Epstein needed additional help? A. Yeah, my daughter did. She says -- she was PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 122 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006245 EFTA00158138
Page 123 1 very excited that M I and brought her to 2 this estate and she was going to have a job. 3 Q. So this is the story that your daughter told 4 you? 5 A. Absolutely. 6 Q. So you had -- you and aunt wanted 7 and your daughter not to see each other? 8 A. Right. But I didn't know. 9 Q. So you told her not to hang around with 10 A. Right. Because he was much older than she 11 was. 12 Q. So you never physically were present to see 13 pick her up and take her anywhere? 14 A. I really can't say that because I know 15 sometimes he borrowed my car to take her. 16 Q. Let's see now. You just told me that you 17 didn't want and your daughter to hang out. You 18 told your daughter not to hang out with him? 19 A. Yeah. But that was prior -- that was prior 20 to -- that was prior to us declaring that we didn't want 21 them to hang out. 22 Q. What was prior to you declaring that you 23 didn't -- 24 A. That had taken to Jeff Epstein's 25 a couple of times in my car. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 90e1e8e0-101b-47ff-b728-ef54d28436d 3506-001 Page 123 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 71819110, 15, and 17 EFTA_00006246 EFTA00158139
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Did there come a time that your daughter told you a different story about what was going on when she went to Mr. Epstein's? A. No. Q. Right up until today? A. I'll be honest with you. The way I found out is when an FBI agent knocked on my door. Q. Okay. And when did that happen? A. We were living at the trailer then, so it was PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 127 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006250 EFTA00158143
1 2 somewhere trailer in the time that we were Page 128 living at this , a man and a woman 3 came to the house. And they told me I couldn't even 4 listen to the conversation, it had nothing to do with 5 me, it pertained to my daughter. 6 Q. So who was present at this meeting? 7 A. A woman, a man and my daughter. And they said 8 they were from the FBI. 9 Q. And did you participate in this conversation? 10 A. No, I didn't, sir. They wouldn't let me. 11 Q. Well, they said you couldn't participate, but 12 were you -- 13 A. No, I wasn't. I was in the house. 14 Q. How old was your daughter at the time? 15 A. Oh, this just -- it happened while we were at 16 the trailer, so it was probably about -- maybe a year 17 and a half ago. 18 Q. She was over 18 by then? 19 A. Yeah, uh-huh, I think so. 20 Q. And that's the first time that you suspected 21 22 that something different was going on than cleaning the house? 23 A. That's the first time I found out something 24 different was going on. 25 Q. And how did you find it out, if you weren't PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47ff-b728-ef54d28436d 3506-001 Page 128 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA J)0006251 EFTA00158144
Page 129 1 present in that meeting? 2 A. Because when they were done with my daughter, 3 I specifically asked these people. And they said they 4 had to talk to her about Jeffrey Epstein. So that's the 5 person she worked for, so I just assumed being the 6 brilliant person I am that, you know, something more is 7 going on. 8 Q. Okay. But did these -- did these two people 9 that you've identified as FBI agents tell you anything 10 else was going on? 11 A. No, I don't recall them. 12 Q. Did your daughter ever tell you anything else 13 was going on? 14 A. That's when my daughter spilled the beans. 15 And she told me she was going to Mr. Epstein's and she 16 was bringing girls there from school and she'd get 17 paid a hundred dollars for every girl she brought there, 18 plus she would get $300. And that's when she told me 19 that what was going on, because she felt like it didn't 20 matter now because she hadn't been over there for, you 21 know, for a -- you know, a year or two years, whatever 22 it was, a year. So, I mean, it was like water under the 23 bridge. And that's when told me. 24 And she goes, Mom, the negligees, and he took 25 pictures of me. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Seelegeg-101b-47ff-b728-efS4d28436cf 3506-001 Page 129 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006252 EFTA00158145
Page 130 1 And I said, well, what do you mean? 2 And took pictures of her and this Maxine 3 or Max -- Max -- I don't know, but all's I know it was 4 Max something. 5 Q. Maxine what? What was she saying about this 6 Maxine person? 7 A. That -- that this Maxine person would take 8 pictures and would -- she modeled for them. 9 And she said, Mom, that's why, you know, that 10 different lingerie -- it was just, like, you know, stuff 11 like that. 12 And I said, well, what's this massage book 13 about? 14 And that's when she told me. 15 Q. Told you what? 16 A. That's when actually admitted to me 17 that would put on these little outfits and 18 Jeffrey Epstein would ejaculate in front of her. 19 Q. Is that what she told you? 20 A. Uh-huh. 21 Q. Now, is this all in this immediately following 22 the occasion that the -- 23 A. FBI came. 24 Q. -- two people from the FBI? So it happened 25 right after that meeting on the same day? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 130 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006253 EFTA00158146
Page 131 1 A. That's -- well, pretty much so, yeah. That's 2 when I questioned . And I said, could you please 3 tell me what's really going on? What kind of trouble 4 are you in? 5 And she said, Mom, I'm not in no trouble. 6 I said, well, what is this all about? 7 And that's when told me. She says, 8 you know that place you took me to with Jeffrey Epstein 9 and you met him and his nice car? Well, that's Jeffrey 10 Epstein and he took pictures of me. 11 Q. Did she tell you anything more about other 12 than just that he, quote, took pictures of me? 13 A. No. He would do sex acts with some other 14 girl. I guess it was his wife. 15 Q. Sex acts -- when she said pictures, did she 16 describe anything more about the pictures, what her 17 state of dress was, whether she was in lingerie? 18 A. No. Just that she was in lingerie and 19 sometimes she wasn't. And he would go into a bath -- 20 guess this room was a bathroom or something and Jeffrey 21 would just come out with a towel wrapped around him. 22 And then one time he asked her to sit on him 23 or -- I don't know -- sit on him or something. And 24 -- I don't know whether she did or didn't 25 because I was really getting disgusted and sick to my PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Sile1eSe8-101b-47f7-b728-ef54d28436d 3506-001 Page 131 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9 10, 15, and 17 EFTA_00006254 EFTA00158147
Page 132 1 stomach. 2 Q. Well, back to the pictures. You said 3 sometimes she said she was in lingerie and sometimes she 4 wasn't? 5 A. Yeah. 6 Q. Meaning, what was she in, if she wasn't in the 7 lingerie? 8 A. I guess she was nude. 9 Q. Did she tell you she was nude or she just said 10 she was in some other outfit? 11 A. No. She just said that just sometimes she was 12 in lingerie and she wasn't. 13 Q. Did she tell you she was nude? 14 A. Honestly, I don't recall. 15 Q. How about these other pictures that you claim 16 that either or this Maxine -- did she claim that 17 or Maxine took pictures of her? 18 A. Yeah. 19 Q. And what did she say her state of dress was 20 for that? 21 A. She was wearing a -- she said she was wearing, 22 like, lingerie-type clothing. 23 Q. Is that for both the pictures that took 24 and the pictures that allegedly -- 25 A. Honestly, I'm not sure. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47f7-b728-ef54d28436d 3506.001 Page 132 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA _00006255 EFTA00158148
Page 133 1 Q. -- Maxine took? 2 Did she ever tell you that she was ever -- 3 anybody took any picture of her when she was naked or is 4 that just the assumption you made? 5 A. I don't recall her telling me that. 6 Q. And then -- so have you now told me everything 7 she told you about anyone taking pictures of her? 8 A. As -- yeah. 9 Q. And then you said did she say that she gave 10 massages to Mr. Epstein? 11 A. Yeah. That's why he was sending her massage 12 books because -- 13 Q. Did she describe those massages at all to you? 14 A. She told me she didn't want to discuss it with 15 me because it would hurt me. 16 Q. So she didn't tell you about it? 17 A. No. She just said that she was -- that she 18 would give Jeffrey massages. 19 Q. Then you say she said that -- what did she 20 tell you about what Mr. Epstein -- 21 A. I asked her what she massaged. 22 Q. Okay. And what did she say? 23 A. She says, Mom, I don't want to get into it. 24 You know enough. 25 Q. Did you ever push at any time after that to PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 gile1eSe8-101b-47ff-b728-ef54d28436cf 3506.001 Page 133 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006256 EFTA00158149
Page 134 1 find out more? 2 A. No. 3 Q. Then you say Mr. Epstein would ejaculate? 4 A. Yes. 5 Q. What did she specifically say about that? 6 A. He would jerk himself off -- 7 Q. Okay. Did she tell you -- 8 A. -- while took pictures. 9 Q. Of who? 10 A. Honestly, I'm not sure. 11 Q. Did she tell you anything else about the 12 massages? 13 A. No. But she did tell me that occasionally 14 there was other men that were present. And whether it 15 was a one-on-one with that man and her or however it 16 worked, I don't know, but my daughter didn't tell me 17 specifics. 18 Q. Did she say she was involved with other men? 19 A. Jeffrey Epstein brought people there, I guess, 20 yeah. 21 Q. But was she telling you -- what was she 22 telling you about the other men as it related to her? 23 A. Oh, that the phone call, I guess, the phone 24 calls that I was getting for to meet at the 25 house was because there was men, I guess, other men PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47f7-b728-ef54d28436d 3506.001 Page 134 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006257 EFTA00158150
Page 135 1 flying in from somewhere and they wanted -- I guess 2 Jeffrey Epstein set a date up for and the other 3 man. 4 Q. You keep saying, you guess. Do you not know? 5 A. Well, sir, it's only what I heard. I don't 6 know for surely. I wasn't there. 7 Q. It's not something you know. All right. 8 Did your daughter tell you on any occasion she 9 went and there was some male person there 10 A. Yes, she did. 11 Q. What did she tell you about that? 12 A. She just told me that there was another -- 13 another -- she had to meet one of Jeffrey Epstein's 14 friends. 15 Q. When she said, meet, what was she telling you? 16 What do you mean, meet one of Jeffrey Epstein's friends? 17 A. She just told me that she had to meet one of 18 Jeffrey Epstein's friends at the house. 19 Q. What did she tell you happened when -- did she 20 tell you that she actually met this person? 21 A. Yeah. 22 Q. What did she tell you happened when she met 23 this person? 24 A. Honestly, I don't remember because I was just 25 totally disgusted by the whole situation. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Sile1eSe8-101b-47ff-b728-ef54d28436cf 3506-001 Page 135 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9 10, 15, and 17 EFTA_00006258 EFTA00158151
Page 136 1 Q. Did she claim that she had performed a massage 2 on someone other than Mr. Epstein? 3 A. Yes. In Mr. Epstein's presence, yes. 4 Q. So she told you specifically that there was an 5 occasion that she went to Mr. Epstein's house and 6 performed a massage on some other man and Mr. Epstein 7 was present? 8 A. Yes. 9 Q. Did she tell you anything about that massage? 10 A. No. 11 Q. Did she tell you whether or not that happened 12 on any occasion more than this one occasion? 13 A. Well, I know also told me about 14 something about two girls and Mr. Epstein observed it. 15 Q. What did she tell you about two girls? 16 A. Well, actually I think Mr. Epstein, I guess 17 his wife -- I guess it was his wife is what she told me, 18 that he -- Mr. Epstein wanted and his wife to 19 perform sexual acts on each other. 20 Q. Did she say what acts? 21 A. Honestly, I said, please don't go any further 22 because it's turning my stomach. 23 Q. Did she tell you whether she, in fact, engaged 24 in any sexual act with this per -- 25 A. No. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 SifeleSeS-101b-47f7-b728-efSild28436cf 3506-001 Page 136 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9 10, 15, and 17 EFTA_00006259 EFTA00158152
Page 137 1 Q. She didn't tell you or she said she didn't? 2 A. No, I didn't say she didn't. I don't know 3 because my daughter knew I was not feeling easy with the 4 situation. And she already knew that I was diagnosed 5 being sick, and my daughter just didn't want to put any 6 more on my head. 7 Q. Okay. Did she tell you anything else about 8 going over to Mr. Epstein's, other than what you've told 9 me thus far? 10 A. No. 11 Q. Did she tell you how much she was getting paid 12 for each of these visits? 13 A. After -- when the FBI, I found out she was 14 getting $300 per session. And every time she brought a 15 friend there he would pay a hundred to $200 to her, just 16 like a finder's fee. 17 Q. And you say the FBI told you that? 18 A. No. I said did. 19 Q. Okay. 20 And she told you she was bringing people from 21 the school? 22 A. Yes. 23 Q. Did she ever tell you who she brought? 24 A. No. 25 Q. Did she ever tell you anything more about PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 SeeletieS-101b-47ff-b728-ef54d28436cf 3506.001 Page 137 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006260 EFTA00158153
Page 138 1 this -- who was this person that you said that -- 2 A. 3 Q. Yeah, • Did she tell you anything 4 more about this MI person? 5 A. I met IIIII quite -- a very, very nice 6 girl, very attractive. And I don't -- I don't know what 7 happened to II because she was, like, there one 8 day and gone the next. 9 And then I guess talked to somebody or 10 talked to somebody and they told me that Jeffrey 11 Epstein sent her somewhere to go to school to increase 12 her knowledge in, I guess, physical therapist then. 13 And then I heard she got married to 14 somebody -- I don't remember where they told me she got 15 married. And that's where she is, but... 16 Q. Have you had any other contact with 17 Mr. Epstein, other than what you've described 18 A. No, uh-uh. 19 Q. -- in this deposition? 20 A. No. 21 Q. Now, your daughter told you these things, 22 whatever day it was the FBI came by, and you think that 23 was around a year ago? 24 MR. : No. Object to the form. 25 MR. LUTTIER: Did I get that wrong? PROSE COURT REPORTING AGENCY, INC. MectronkallysIgmdbySmckerownserW001 MectronkallysIgmdby&mdranownserW001 Seeletie8-101b-47f7-0728-054d28436d 3506-001 Page 138 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9 10, 15, and 17 EFTA_00006261 EFTA00158154
Page 139 1 BY MR. LUTTIER: 2 Q. Refresh my memory. About how long ago do you 3 think this meeting was with the FB -- 4 A. Oh, I don't know. All's I could tell you is 5 exactly it was the time we were living in this trailer. 6 Q. The one you're in now or -- 7 A. Uh-huh. 8 Q. All right. Was the statement recorded, do you 9 know? 10 A. I couldn't tell you, sir. 11 Q. Were they in a separate room from where you 12 were? 13 A. Sir, they were sitting outside on my patio. 14 was in the house. 15 Q. For the entire conference? 16 A. Yes, sir. 17 Q. And you say it was a man and a woman? 18 A. Yes, sir. 19 Q. Black? White? 20 A. Sir, I don't remember. 21 Q. To the best of your knowledge, were there any 22 other meetings with the FBI? 23 A. Sir, I don't know. 24 Q. Has your daughter discussed it? Other than 25 the discussion you had with her immediately following PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 Seele8e8-101b-47ff-b728-efS4d28436cf 3506-001 Page 139 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFFA_00006262 EFTA00158155
Page 140 1 her meeting with the FBI, have you had any other 2 discussions with her 3 A. No, sir. 4 Q. -- about Jeffrey Epstein? 5 A. No, sir. 6 Q. Right up until today? 7 A. No. Because she knows the way I feel about 8 it. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0728-ef54d20436cf 3506-001 Pagc 140 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006263 EFTA00158156
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Page 151 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Your daughter had a lot of issues involving drugs and psychiatric care, did she not? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d28436cf 3506-001 Page 154 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006277 EFTA00158170
Page 155 1 MR. : Object to the form. 2 THE WITNESS: Let me put it to you this way: 3 I wouldn't say anything out of the normal for a 4 child growing up, but it got progressively worse 5 after she met Mr. Epstein. Okay? Thank you very 6 much. 7 BY MR. LUTTIER: 8 Q. Well, it also got progressively worse after 9 she fell in with this fellow, and got pregnant by 10 him, didn't it? 11 A. Well, was the one that introduced her to 12 Mr. Epstein, sir. 13 Q. And the drug use that she was using was when 14 she was away from Mr. Epstein's house, wasn't it? 15 A. Sir, I couldn't testify to that because I 16 don't know. 17 Q. So you don't know. You don't know whether or 18 not was giving her the drugs or she was buying it 19 off the street, do you? 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98eletieS-101b-47f7-b728-ef54d28436d 3506-001 Page 155 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006278 EFTA00158171
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Page 164 1 2 3 4 S 6 7 8 9 10 11 Q. By the way, did your daughter ever say that 12 Mr. Epstein ever hit her? 13 A. No. 14 Q. Ever say that he gave her drugs? 15 A. Not directly, no. 16 Q. Ever say that he physically hurt her? 17 A. Physically hurt her? No. 18 Q. Yes. 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0728-ef54d20436cf 3506-001 Pagc 164 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006287 EFTA00158180
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Page 172 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Was there ever anything that your daughter asked that she be permitted to do with Mr. Epstein that you forbad her to do? A. No. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-471743728-ef54d20436cf 3506-001 Page 172 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006295 EFTA00158188
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Page 175 1 What you're describing as normal with your 2 kids is telling your kids, call me to let me know that 3 you're not dead and in a dumpster yet; is that right? 4 A. No. Actually, I've said that to my daughter 5 because she disappears. 6 Q. And that's been a consistent problem, correct? 7 A. Not until recent. 8 Q. What do you mean by recently? 9 A. Not until after her escapades with Jeffrey 10 Epstein. That's when she really became out of control. 11 Q. That's when she ran off with this 12 and went to right? 13 A. Yep. 14 15 16 17 Q. Okay. But had a baby with him, right? 18 A. Yes. 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47(7-0720-ef54d20436cf 3506-001 Pagc 175 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7/ 8/ 91101151 and 17 EFTA_00006298 EFTA00158191
Page 176 1 2 Q. Mr. Epstein doesn't have anything to do with 3 any of that, does he? 4 MR. : Object to the form. 5 BY MR. LUTTIER: 6 Q. Wasn't around for any of that, was he, ma'am? 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't know. PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-471743720-ef54d20436cf 3506-001 Page 176 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006299 EFTA00158192
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 paw:, 178 MR. LUTTIER: Okay. Let me take a break and might be done. VIDEOGRAPHER: Going off the record at 12:29 p.m. (Brief recess.) VIDEOGRAPHER: We are back on the record at 12:39 p.m. BY MR. LUTTIER: Q. Other than the occasions that you took your daughter to the -- to the location in Palm Beach where you said Mr. Epstein lived, have you ever taken your daughter anybody place else to meet Mr. Epstein? PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 178 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006301 EFTA00158194
Page 179 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. No. Q. Have you described for me in this deposition all personal contact, that is, one-on-one contact you've had with Mr. Epstein? A. Just one time. Q. And I meant, which would either be when you, personally, saw him or you, personally, spoke to the person who you believe is him -- A. No. I'm talking about when I physically was on his property in his driveway. Q. And have you described for me in this deposition all occasions when you've personally spoken with him on the phone? A. Yeah. Q. Has your daughter told you anything else about Mr. Epstein, other than what you've told me -- A. No. Q. -- during this deposition? MR. LUTTIER: I don't have any other questions. MR. : I don't have lien PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0728-ef54d28436cf 3506-001 Page 179 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006302 EFTA00158195
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIDEOGRAPHER: Going off the record at 12:43 p.m. This marks the end of the deposition. MR. LUTTIER: You have the right to either this will get typed up. You have the right to read it, in which case you can read the transcript and if there's any inaccuracies, you can change it. THE WITNESS: No. I want to read it. MR. LUTTIER: And she'll make arrangements through you, I assume, to take care of it. (Witness excused.) (Deposition was concluded.) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-47(7-0720-ef54d20436cf 3506-001 Page 182 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006305 EFTA00158198
Page 183 1 CERTIFICATE OF OATH 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 6 I, the undersigned authority, certify that 7 personally appeared before me and was 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 duly sworn on the 6th day of November, 2009. Dated this 19th day of November, 2009. Sandra W. Townsend, Court Repd1 Notary Public - State of Florida My Commission Expires: 6/26/12 My Commission No.: DD 793913 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98.21e8e8-101b-471743720-ef54d28436cf 3506-001 Page 183 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006306 EFTA00158199
Page 184 1 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 CERTIFICATE 5 I, Sandra W. Townsend, Court Reporter and Notary Public in and for the State of Florida at Large, 6 do hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth; that I 7 was authorized to and did report said deposition in stenotype; and that the foregoing pages numbered 1 to 8 182, inclusive, are a true and correct transcription of my shorthand notes of said deposition. 9 I further certify that said deposition was 10 taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and 11 completed as hereinabove set out. 12 I further certify that I am not attorney or counsel of any of the parties, nor am I a relative or 13 employee of any attorney or counsel of party connected with the action, nor am I financially interested in the 14 action. 15 The foregoing certification of this transcript does not apply to any reproduction of the same by any 16 means unless under the direct control and/or direction of the certifying reporter. 17 18 19 20 21 22 23 24 25 Dated this 19th day of November, 2009. Sandra W. Townsend, Court Reporter PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08.21e8e8-101b-4717-0720-ef54d20436cf 3506-001 Pagc 184 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006307 EFTA00158200
Page 185 1 DATE: November 19, 2009 2 TO: c o , Esquire 3 4 IN RE: III II vs. Epstein 5 CASE NO.: 08-CIV-80119-MARRA/JOHNSON 6 Please take notice that on Friday, the 6th of 7 November, 2009, you gave your deposition in the above-referred matter. At that time, you did not waive 8 signature. It is now necessary that you sign your deposition. 9 Please call our office at the below-listed number to schedule an appointment between the hours of 10 9:00 a.m. and 4:30 p.m., Monday through Friday, at the Esquire office located nearest you. 11 If you do not read and sign the deposition within a reasonable time, the original, which has 12 already been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive 13 your signature, sign your name in the blank at the bottom of this letter and return it to us. 14 Very truly yours, 15 16 17 Sandra W. Townsend, FPR PROSE COURT REPORTING AGENCY 18 19 20 I do hereby waive my signature. 21 22 23 I do hereby waive my signature: 24 cc: Via transcript: All Counsel of Record; file copy 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d20436cf 3506-001 Page 185 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006308 EFTA00158201
Page 186 1 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the 6 foregoing deposition by me given, and that the 7 statements contained herein are true and correct to the 8 best of my knowledge and belief, with the exception of 9 any corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2009. 14 15 16 17 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 08e1e8e8-101b-4717-0720-ef54d20436cf 3506-001 Pagc 186 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006309 EFTA00158202
Page 187 1 ERRATA SHEET 2 IN RE: MI VS. EPSTEIN CR: S. TOWNSEND 3 DEPOSITION OF: 4 TAKEN: 11/6/09 5 6 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 7 PAGE 4 LINE 4 CHANGE REASON 8 9 10 11 12 13 14 15 16 17 18 Please forward the original signed errata sheet to this office so that copies may be distributed to all parties. 19 Under penalty of perjury, I declare that I have read my 20 deposition and that it is true and correct subject to any changes in form or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 98e1e8e8-101b-4717-0728-ef54d28436cf 3506-001 Page 187 of 187 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00006310 EFTA00158203




