22 you took for the first time? 23 A. None of your business. 24 MR. : We'll stipulate that it was 25 not from Mr. Epstein. 103 1 THE WITNESS: No, it was not from 2 Mr. Epstein. 3 BY MR. LUTT1ER: 4 Q. And would you also agree that Mr. Epstein 5 didn't tell you to go get it? Mr. Epstein didn't 6 tell you to go get cocaine, did he? 7 A. No. 8 Q. Mr. Epstein never gave you any drugs. did 9 he? 10 A. No. 11 Q. Mr. Epstein never told you to take any 12 drugs, did he? 13 A. No, but Mr. Epstein knew I was taking drugs. 14 Q. And how did Mr. Epstein know you were 15 taking drugs? 16 A. Because I told him. 17 Q. And what did you tell him? 18 A. I told him that I was under the influence of 19 cocaine. 20 Q. And when did you tell him that? 21 A. When I was at his house. 22 Q. And when was that? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008152 EFTA00159004
23 A. I don't remember the exact date. 24 Q. Which occasion was it that you were at his 25 house that you told him you were under the influence 104 1 of cocaine? 2 A. I don't remember. 3 Q. And was this on one occasion? 4 A. What, that I had gone to his house under the 5 influence? 6 Q. That -- no, that you told him that you 7 were under the influence of cocaine. 8 A. No, there, there was more than one occasion 9 where I have told him. 10 Q. It was your choice to take cocaine before 11 you went to Mr. Epstein's house? 12 A. Anything to mind alter myself not to be there. 13 Q. You did that voluntarily, that is you took 14 whatever drugs you took before you went to 15 Mr. Epstein's? 16 A. Yeah. 17 Q. You bought them with money that you had; 18 is that right? 19 A. From Mr. Epstein, yes. 20 Q. Well, you didn't keep track of the money 21 that you got, right? 22 A. Well, I wasn't receiving income from any other file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008153 EFTA00159005
23 person, so -- 24 Q. And were you doing this cocaine with your 25 boyfriend? 105 1 A. At the time, yes. 2 Q. And that was Mr. 3 A. MR yes. 4 Q. And were you and he doing cocaine 5 away from Mr. Epstein; that is you did it when you 6 weren't at Mr. Epstein's house? 7 A. Yes. But I have done cocaine at Mr. Epstein's 8 house also. 9 Q. When did you do cocaine at Mr. Epstein's 10 house? 11 A. On some occasions while I was there. 12 Q. What occasions were those? 13 A. I don't recall the dates and times. 14 Q. What, where at his house were you doing 15 cocaine? 16 A. I would excuse myself and go to the bathroom. 17 Q. And who was in the bathroom when you were 18 doing this cocaine? 19 A. Myself. 20 Q. And, and what form of cocaine were you 21 using? 22 A. Powder. 23 Q. And did you tell anyone you were taking file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008154 EFTA00159006
24 cocaine? 25 A. Mr. Epstein knew I was high. 106 1 Q. Did you tell Mr. Epstein that you had gone 2 in the bathroom in his house and snorted cocaine? 3 A. Not, per se, in that form. 4 Q. Did you tell him that you were using drugs 5 in his house? 6 A. No. 7 Q. He never told you to use drugs in his 8 house, did he? 9 A. No, he never told me to. 10 Q. He never gave you alcohol in his house, 11 did he? 12 A. No. 13 Q. Did you ever have sexual intercourse with 14 Mr. Epstein? 15 A. No. 16 Q. Do you know what I mean by sexual 17 intercourse, or do I need to go through the various 18 acts? 19 A. Oh, I am pretty sure I know what sexual 20 intercourse is being I have two children. 21 Q. Well, I just want to make sure we're clear 22 about some things. Did Mr. Epstein ever insert his 23 penis into any part of your body at all? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008155 EFTA00159007
24 A. I just said that I've never had sexual 25 intercourse with Mr. Epstein and that I knew what sexual 107 1 intercourse was, and I said no. So, for you to explain 2 to me what it was unnecessary. 3 Q. Okay. Do you just want to answer my 4 question now, ma'am? 5 A. I did four times. I said no. 6 MR. LUTTIER: Would you read back the 7 question I asked? I need an answer to my 8 question. 9 MR. : We will stipulate that the 10 answer to that question is no. 11 BY MR. LUTTIER: 12 Q. Okay. Did you ever perform any sexual act 13 of any kind or nature whatsoever on Mr. Epstein 14 ever? 15 A. Now, you could define, give me a definition of 16 what that would be, because I've never -- giving him a 17 blow job, I've never had sex with him. I did squeeze 18 his nipples or whatever while he was masturbating 19 himself. 20 Q. Any other, did you ever perform any other 21 sexual act on Mr. Epstein? And by, when 1 say 22 other, I'm not acknowledging that squeezing 23 someone's nipples is a sexual act. But it seems 24 that you're defining it as such; is that right? Do file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008156 EFTA00159008
25 you think that's a sexual act? 108 1 MR. : Well, asked you for 2 a definition and - 3 MR. LUTT1ER: Well, actually what we 4 have -- 5 MR. : -- and described to you -- 6 MR. LUTT1ER: Okay. We'll do this -- 7 MR. : -- what she did. 8 BY MR. LUTT1ER: 9 Q. We'll do this, did you ever perform oral 10 sex, that is put Mr. Epstein's penis in your mouth? 11 A. Did I not just tell you -- 12 Q. Ma'am, you said you needed me to 13 explain — 14 THE WITNESS: Could I ask if you could 15 read back that I told him that I never gave him 16 a blow job and never had sex with him. 17 MR. LUTTIER: Now, I am going to explain 18 it to you. We're going to make sure we're 19 clear, ma'am, because I know you want to be 20 specific. Okay. 21 THE WITNESS: I was specific with you. 22 THE COURT REPORTER: One at a time. 23 BY MR. LUTT1ER: 24 Q. Did you ever masturbate Mr. Epstein? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008157 EFTA00159009
25 A. No. 109 1 Q. Did you ever touch Mr. Epstein's penis -- 2 A. No. 3 Q. -- in any way? 4 A. No, no. 5 Q. Did you ever penetrate with any part of 6 your body any part of Mr. Epstein's body? 7 A. Besides touching his nipples, no. 8 Q. Did you ever do anything physically to 9 Mr. Epstein other than give him a simple massage? 10 A. Squeezed his nipples. 11 Q. Was that part of the massage? 12 A. No. 13 Q. Okay. So other than squeeze his nipples 14 and give him a massage, did you do anything else 15 physically to Mr. Epstein? 16 A. No. 17 Q. Did Mr. Epstein ever make you do anything 18 that you didn't want to do ever? 19 A. Make me do anything I didn't want to do. 20 Q. Force you to do something you didn't want 21 to do, ever? 22 A. Probably squeeze his nipple. 23 Q. And why do you say he made you do that and 24 you didn't want to do it? Did you tell him -- well, 25 first of all, did he ask you to squeeze his nipples? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDERV020PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008158 EFTA00159010
110 1 A. Yes. 2 Q. Did you tell him you didn't want to do 3 that? 4 A. Yes. 5 Q. And what did he say when you said that? 6 A. It would help him go faster or whatever. 7 Q. And did you then do it? 8 A. Yes, I did. 9 Q. Did you refuse to do it and say, no, I 10 don't want to do that? 11 A. Yes, I did refuse; and yes, I still did it. 12 Q. Well, did you do it voluntarily then? 13 A. Obviously. 14 Q. All right. Were there ever any other 15 things ever that Mr. Epstein asked you to do that 16 you refused to do? 17 A. No. 18 Q. Is it a true statement then that 19 Mr. Epstein never forced you to do anything? 20 A. I guess no. 21 22 23 24 25 111 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008159 EFTA00159011
1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 112 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMI EFIA_00008160 EFTA00159012
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 113 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008161 EFTA00159013
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 114 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008162 EFTA00159014
1 2 3 4 5 6 7 8 9 10 Q. When did you first make an acquaintance or 11 meet Mr. Epstein? 12 A. When brought me over there. 13 Q. And who is 14 A. A friend of mine who has disappeared. 15 Q. What is M. a last name? 16 A. I don't remember. 17 Q. And when you say she brought you over 18 there, what is the "there" that you are referring 19 to? 20 A. To Mr. Epstein's. 21 Q. And where is that? 22 A. It was at Palm, it was on Palm Beach. 23 Q. Are we talking about a condominium, an 24 apartment, or -- 25 A. 358 Albrillo Way. 115 1 Q. And when was it that your friend, file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008163 EFTA00159015
2 =, brought you to Mr. Epstein's at 358 3 Albrillo Way? 4 A. What you do you mean when was it? 5 Q. What date? 6 A. I don't know the date 7 Q. Do you have any record at all anywhere of 8 the date that you first went? 9 A. No. 10 Q. In your complaint you allege that the 11 first time you went was in May or June of-. Are 12 you aware of that? 13 A. Yes, I remember it was spring going into 14 summer. 15 Q. Is there any other basis upon which you 16 concluded that you first went to Mr. Epstein's in 17 May or June of a other than your recollection 18 that it was sometime in the spring? 19 A. No. 20 Q. Is there any other fact or circumstances 21 upon which you relied when you alleged that you 22 first went to Mr. Epstein's in May or June of =? 23 A. One more time. I'm sorry. 24 Q. Any other fact or circumstance that you 25 relied upon when you alleged that you first went to 116 1 Mr. Epstein's in either May or June of other — fik:///D/...20[SUBJECP%20T0%20PROTECTIVE%200RDER%20PARAGRAPHS%207,%208,%209,%2010,%2015,%20and%20171.14I2/10/2025 3:06:21 PMJ EFTA_00008164 EFTA00159016
2 A. I don't -- 3 Q. -- than it was the spring? 4 A. I don't understand. 5 Q. How did you know it was May or June of 6 when the first time that you went to 7 Mr. Epstein? 8 A. Oh, because I remember the weather. 9 Q. That's it. That's the sole basis upon 10 which you allege that you first went to 11 Mr. Epstein's in May or June of . 1 12 A. Yeah. 13 Q. Did you ever keep any kind of record of 14 your occasions that you went to Mr. Epstein's? 15 A. No. 16 Q. Did you have any communication at all with 17 Mr. Epstein himself before you went to his house for 18 the first time when MI took you there? 19 A. No, I didn't even know he existed. 20 Q. Did you ever personally see, that is 21 face-to-face, Mr. Epstein anyplace other than at 358 22 Albrillo, Palm Beach, Florida? 23 A. No. 24 Q. And I mean that from the time you first 25 went there when your friend talked 117 to you until the last time you went there. 2 A. I have only seen him at that house. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008165 EFTA00159017
3 Q. Right. Which means you haven't run into 4 him out in town or any other place? 5 A. No. 6 Q. The only time you ever did it is when you 7 went to his house? 8 A. Yes. 9 Q. Have, have you ever traveled anyplace 10 with -- Mr. Epstein ever take you anyplace? 11 A. No. 12 Q. Anyplace you know, in town, for example, 13 Palm Beach? 14 A. No. 15 Q. Ever take you to concerts? 16 A. He paid for me to go to a concert. 17 Q. Did you ever, did you ever travel outside 18 of Palm Beach County with him? 19 A. No. 20 Q. Never traveled anywhere with him at all, 21 right? 22 A. No. 23 24 25 1 2 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008166 EFTA00159018
3 4 5 6 7 8 9 10 Q. Okay. Let me ask, let me ask you a 11 different question. Did you have access to a 12 computer before you went to see Mr. Epstein for the 13 first time? 14 A. Yeah. 15 Q. All right. Did you ever communicate with 16 Mr. Epstein via computer; that is, did you ever use 17 the computer? 18 A. No. 19 Q. Did you ever e-mail him any messages? 20 A. No. 21 Q. Did you ever receive any e-mails from him? 22 A. No. 23 Q. Did you ever fax anything to him? 24 A. No. 25 Q. Did you ever receive any faxes from him? 119 1 A. No. 2 MR. LUTHER: 1 think they have to change 3 the tape. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008167 EFTA00159019
4 5 6 7 8 THE VIDEOGRAPHER: Off the record at 9 12:29. 10 (A brief recess was held.) 11 THE VIDEOGRAPHER: We're back on the 12 record at 12:40. 13 MR. LUTTIER: What exhibit are we on? 14 THE COURT REPORTER: Three. 15 MR. LUTTIER: Let me have that marked 16 as 3. 17 THE WITNESS: Exhibit 3. Thanks. 18 BY MR. LUTTIER: 19 Q. Ma'am, what I've, what I've given you is a 20 document that's been marked as Exhibit 3. That is a 21 copy of the First Amended Complaint which you filed 22 in this case. And I am giving it to you so that it 23 is available to you if you want to consult it at any 24 time during the deposition. 25 I will probably ask you some specific 120 1 questions about it, in which case I will refer you 2 to the appropriate portion. You don't have to read 3 it now but I want to make sure you're aware it's file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008168 EFTA00159020
4 available to you if you want to consult it. All 5 right? 6 A. Okay. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 BY MR. LUTT1ER: 25 Q. Did you -- have you ever had a phone 121 1 conversation directly with Mr. Epstein? 2 A. About what? 3 Q. About anything? 4 A. Yeah. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008169 EFTA00159021
5 Q. Not, not somebody at Mr. Epstein's house 6 but Mr. Epstein himself? 7 A. Yes. 8 Q. Do you recall on how many occasions you 9 have had phone conversations with him? 10 A. More than twice. 11 Q. Do you have any, are you able to estimate 12 anything more accurate than just more than twice? 13 A. No. 14 Q. From, from your estimate that it was more 15 than twice, would it be a correct statement that it 16 was infrequent that you had a direct phone 17 conversation with Mr. Epstein? 18 A. What is infrequent, like not all the time? 19 Q. Yeah. 20 A. Yeah. 21 Q. Would it be less than a dozen times? 22 A. Yeah. 23 Q. Okay. Do you recall as you sit here today 24 the substance of any of your conversations with 25 Mr. Epstein, the direct ones that you had? 122 1 A. Oh, instead of somebody else calling me to ask 2 me to come over, he called himself. 3 Q. I am just, yeah, my -- the questions I am 4 now asking you concern themselves strictly with file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008170 EFTA00159022
5 phone conversations where you were one part of the 6 conversation; Mr. Epstein himself was the other 7 party. Do you understand that? 8 A. Yeah. 9 Q. Okay. All right. Do you remember the 10 substance of any direct phone conversation you ever 11 had with Mr. Epstein? 12 A. I don't understand. 13 Q. Do you remember the specifics about what 14 he said or what you said? 15 A. About when he got me concert tickets, he 16 called me and asked me if I wanted to go. 17 Q. Okay. And do you know approximately when 18 that conversation happened? 19 A. I don't remember. 20 Q. Do you recall any other direct phone 21 conversation with Mr. Epstein other than when he 22 called you about concert tickets? 23 A. He told me he would be sending me lingerie 24 from New York. 25 Q. Do you recall any other phone conversation 123 1 directly with Mr. Epstein? 2 A. No. 3 Q. So, other than these two phone 4 conversations that you had with Mr. Epstein, was 5 there any other occasion that you and he were on the file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008171 EFTA00159023
6 phone together? 7 A. I don't remember. 8 Q. That is you don't remember any other? 9 A. Yeah. 10 Q. On, on the occasion that he called and 11 asked you about concert tickets, was Mr. Epstein at 12 his house in Palm Beach? 13 A. I'm not sure. 14 Q. Do you know where he was? 15 A. I don't. He was either in New York or in Palm 16 Beach. 17 Q. Do you know where he was? 18 A. I just said no. 19 Q. Okay. On the conversation when he called 20 and said he would be sending you lingerie, do you 21 know where Mr. Epstein was? 22 A. Unh-unh. No. 23 Q. On each of those occasions, who placed the 24 call; that is, did he call you or did you call him? 25 A. He called me. 124 1 Q. Were there ever occasions that you called 2 Mr. Epstein directly, whether or not you talked to 3 him, where you placed a call trying to get 4 Mr. Epstein? 5 A. Yes. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008172 EFTA00159024
6 Q. And how often did that happen? 7 A. More than four. 8 Q. And for what reason were you placing calls 9 to try to get Mr. Epstein? 10 A. To go over there to see him. 11 Q. Were you seeking the opportunity to go 12 over and massage him and get paid? 13 A. Yes. 14 Q. And on these occasions that you called to 15 see if you could go over there and give him a 16 massage, did you talk to him or did you talk to 17 others at his house? 18 A. I talked to or Maxwell. I have also 19 talked to -- I don't know if it's the cook or somebody 20 else that was there that took phone messages. 21 Q. Other than the four occasions when you 22 placed calls to Mr. Epstein's home looking to come 23 over and perform massages for money, were there any 24 other times that you attempted to contact 25 Mr. Epstein ever? 125 1 A. No. 2 Q. Other than the two times that Mr. Epstein 3 called you, once about concert tickets and once 4 about lingerie, to the best of your knowledge were 5 there, was there ever any other time that 6 Mr. Epstein attempted to contact you? file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008173 EFTA00159025
7 A. Not that I know of. I mean, I don't think it 8 was him. No, I don't remember it. 9 Q. Okay. What, do you recall what phone 10 number you used when you tried to call Mr. Epstein? 11 A. The Palm Beach phone, phone numbers. 12 Q. It would be the number at his house? 13 A. Yes. 14 Q. To be distinguished from a phone number 15 for example, for a cellphone? 16 A. House numbers. 17 Q. Okay. According to your first amended 18 complaint, Paragraph 195, the last time you saw 19 Mr. Epstein was August of.. 20 A. What page are you on? 21 Q. It would be Page 84. Is that correct? 22 A. Yeah. 23 Q. All right. So, for purposes of this case, 24 the total period of time that you had any 25 interaction with Mr. Epstein was between May of. 126 1 and August of 2 A. Uh-huh. 3 Q. That is another way of saying it is the 4 first time you went is May ofeind the last time 5 you went was August of 6 A. Yeah. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008174 EFTA00159026
7 Q. Didn't know Mr. Epstein at all prior to 8 May of., and had no contact with him after August 9 oft? 10 A. Correct. 11 Q. On any occasion that you have described 12 where you had a phone conversation with Mr. Epstein, 13 was anyone else on the line to the best of your 14 knowledge? 15 A. No. 16 Q. For example, you didn't have someone on 17 the extension of the phone where you were? 18 A. No. 19 Q. And to the best of your knowledge nobody 20 was on his end of the phone call? 21 A. No. 22 Q. You never had a discussion with him on a 23 speaker phone, for example? 24 A. No, not to my awareness. 25 Q. Did you ever record -- 127 1 A. No. 2 Q. -- any of your — 3 A. No. 4 Q. Let me -- did you ever record any of your 5 communications with Mr. Epstein? 6 A. No. 7 Q. And by that I would mean it could be a file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008175 EFTA00159027
8 tape recording, could be you making notes. You 9 never did anything like that? 10 A. No. 11 Q. All right. Have you told me in this 12 deposition now everything that you can remember 13 about your direct phone conversations with 14 Mr. Epstein? 15 A. Yes. 16 Q. When you said that Mr. Epstein called you 17 about concert tickets, was he, was he asking you to 18 go with him to the concert or just asking if you 19 wanted tickets to the concert? 20 A. If I wanted the tickets to the concert. 21 Q. And did you take the tickets? 22 A. Yes. 23 Q. All right. Would you, would you say that 24 during the period from May of. to August of• 25 Mr. Epstein was good to you? 128 1 A. Yes. 2 Q. He was polite? 3 A. Yes. 4 Q. Never forced you to do anything you didn't 5 want to do? 6 A. Yes. 7 Q. Did he help you with your self-esteem? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008176 EFTA00159028
8 A. No. 9 Q. Did he attempt to build you up and make 10 you feel good about yourself? 11 A. Yeah. 12 Q. Did he ever attempt to make you not feel 13 good about yourself? 14 A. He didn't try to make me not feel good about 15 myself. 16 Q. He never demeaned you in any way when you 17 were with him? 18 A. No. 19 Q. Did he ever -- 20 MR. 21 MR. LUTTIER: Strike you -- 22 MR. : I think you're going to need 23 to sit up because of the video camera, it's 24 going to be difficult for anybody to understand 25 your responses. Okay. Thank you. 129 1 BY MR. LUTTIER: 2 Q. Did he ever, did he ever strike you ever, 3 hit you? 4 A. No. 5 Q. You know what the phrase domestic violence 6 means? 7 A. Yes. 8 Q. Did he ever commit an act of domestic file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008177 EFTA00159029
9 violence against you? 10 A. No. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 1 2 3 4 5 6 7 8 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008178 EFTA00159030
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 13 1 Q. It's just, you know, a question that we 2 have to ask. Did, did Mr. Epstein ever threaten you 3 in any manner? 4 A. No. 5 MR. CRITTON: Pm sorry. I didn't hear 6 that. 7 THE WITNESS: I said no. 8 BY MR. LUTTIER: 9 Q. Did he ever give you any kind of a file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008179 EFTA00159031
10 substance to ingest or otherwise do anything that 11 caused you, for example, to lose consciousness? 12 A. Not to my awareness, no. 13 Q. He never attempted to drug you in any 14 manner, did he? 15 A. Not to my awareness, no. 16 Q. Never even offered you any drugs, correct? 17 A. Correct. 18 Q. What -- when you would go to 19 Mr. Epstein's, would you and he converse? 20 A. Conversate? 21 Q. Would you talk with him while you were 22 giving him massages? 23 A. Yeah. 24 Q. What types of things did you talk to 25 Mr. Epstein about? 132 1 A. He wanted to put me in massage school. 2 Q. Was that something you were interested in? 3 A. I was. 4 Q. And did you indicate to Mr. Epstein you 5 had an interest in going to massage school? 6 A. Yes. 7 Q. And what did Mr. Epstein tell you about 8 that? 9 A. He sent me a book, Massage for Dummies. And file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008180 EFTA00159032
10 he was going to put me in school for it if I really 11 wanted to do it. 12 Q. And did you indicate to him whether you 13 really wanted to do it? 14 A. Yes, I really wanted to do it, but I never, 15 he — I never went to school for it. 16 Q. Did you ever ask him if, if he would pay 17 for you to be enrolled in school? 18 A. He told me he would. 19 Q. All right. So he said he would be willing 20 to, but you had made the decision you didn't want to 21 go forward with it? 22 A. I wasn't old enough to. 23 Q. Okay. Anything else that Mr. Epstein 24 offered to do for you? 25 A. He wanted to send me on vacation somewhere but 133 1 I was too young to go. My mom wouldn't have let me go 2 out of the country. 3 Q. Did you ever represent to Mr. Epstein at 4 any time what your age was? 5 A. Yes. 6 Q. When did you first represent to 7 Mr. Epstein what your age was? 8 A. When I was going to turn 14,1 accidently said 9 I was going to be 14. And his response was, don't let 10 anybody know how old you are. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008181 EFTA00159033
11 Q. Well, you -- we've established that you 12 first went to him in May or June of.. 13 A. I was 13. 14 Q. Right? You were 15 the, right? 15 A. In.? 16 Q. Yeah. 17 A. No. Was I 15? 18 Q. What day -- yeah, maybe my math is wrong. 19 Mr. will correct me. You were born inM? 20 A. Yeah. 21 Q. Okay. If I add 15 years toM1 think I 22 get toM, unless there is someone here that says 23 my math is wrong. 24 MR. LUTTIER: Mr. NM, do you agree 25 with me that it's= 134 1 MR. : I am going to let you do 2 your own math. When the appropriate time comes 3 to correct you — 4 MR. LUTTIER: Okay. 5 MR. : -- you can be sure that I 6 will do that. 7 BY MR. LUTTIER: 8 Q. All right. Well, if we add and we 9 add 15 years to it, we get to M ; do you agree 10 with that? file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS%207,%208,%209,%2010,%20 I 5,%20and.420 I ?limp/10/2025 3:06:21 PMJ EFTA_00008182 EFTA00159034
11 A. I guess, yeah. 12 Q. Okay. All right. So, that would make you 13 15 when you went to Mr. Epstein's the first time, 14 wouldn't it? 15 A. I thought it was 14. 16 Q. But you agree with the math? 17 A. I don't know. I didn't watch you do your 18 math. 19 Q. Okay. All right. You allege in your 20 complaint two incidents in each month from late, 21 late May or early June of. through August of- 22 that you went to Mr. Epstein. In fact, you, you 23 don't have a specific record of when you actually 24 went to Mr. Epstein; is that right? 25 A. That's right. 135 1 Q. You -- and this is, this complaint only 2 contains what you, your estimate is of when you 3 actually went, correct? 4 A. Right. 5 Q. Might have gone fewer times; might have 6 gone more times? 7 A. I know I went over 100 times. 8 Q. How do you know you went over 100 times? 9 Did you count? 10 A. Because I was there. 11 Q. Do you have some place that you recorded file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008183 EFTA00159035
12 it? 13 A. No. 14 Q. You added it up and got to 100? 15 A. No. 16 Q. So, that's just an estimate on your 17 behalf? 18 A. Yes. 19 Q. You allege in your complaint that you went 20 twice a month for every month between June of. 21 and August of.. Do you know whether or not 22 Mr. Epstein was, in fact, in Palm Beach every month 23 between June of sand August of.? 24 A. I don't know. 25 Q. Do you know whether or not Mr. Epstein was 136 1 gone from Palm Beach County -- 2 A. I didn't -- 3 Q. -- for substantial periods of time during 4 the period from June of. to August of .? 5 A. I know that he'd go back and forth to 6 different places, but when he was in Palm Beach, I would 7 get a phone call. 8 Q. Do you know whether or not it was any 9 continuous period of time when he was not in Palm 10 Beach County between June of. and August oft 11 A. I don't know. I would get a phone call when file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008184 EFTA00159036
12 he was in Palm Beach. 13 Q. Would you -- but you would agree that if 14 he wasn't in Palm Beach, you didn't see him? 15 A. Correct. 16 Q. And you would agree that it's, that it's, 17 that it's possible that Mr. Epstein was gone during 18 periods of time that you claim you went to see him? 19 A. I can't claim anything if I don't know. 20 Q. You would agree with me that you cannot 21 recall the specifics of each visit that you had at 22 Mr. Epstein's home? 23 A. I don't remember the times and dates, but I 24 can tell you everything that happened while I was there. 25 Q. In your complaint in each count you allege 137 1 that you went to Mr. Epstein's at his request? 2 A. Uh-huh. 3 Q. In fact Mr. Epstein himself did not 4 contact you on each occasion and request you to 5 come, did he? 6 A. No. He would have or Maxwell call me. 7 Q. Well, there were also occasions when no 8 one from Mr. Epstein called, but rather you called 9 Mr. Epstein's and asked to go? 10 A. Yes. 11 Q. And that was because you wanted to go and 12 earn some money, correct? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008185 EFTA00159037
13 A. Yes. 14 Q. On each occasion that you went to 15 Mr. Epstein's, you went there voluntarily, correct? 16 A. Yes. 17 Q. On each occasion that you went to 18 Mr. Epstein's whatever acts you performed, you 19 performed them voluntarily, correct? 20 MR. : Excuse me. Let me state for 21 the record that there is no allegation of any 22 physical coercion. There is no allegation that 23 any third party compelled to engage in 24 those acts in which she engaged with 25 Mr. Epstein. 138 1 It is our contention that was 2 legally incapable of consenting to the sexual 3 misconduct in which Mr. Epstein engaged as a 4 consequence of her minority. So, maybe that 5 helps to narrow your questioning down some. 6 MR. LUTTIER: All right. So, you will 7 stipulate that neither Mr. Epstein nor anyone 8 else forced against her will to perform 9 any act; it's simply your position that given 10 her age, she could not have consented to those 11 acts? 12 MR. : That's correct. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008186 EFTA00159038
13 MR. LUTT1ER: Okay. 14 MR. : She was, she was bribed to 15 engage in that conduct; that is, she was paid 16 very large sums of money and she engaged in 17 those acts without having the legal capacity to 18 consent as a consequence of the large sums of 19 money that were offered to her as well as other 20 gifts. 21 MR. CRITTON: Ain't going to work. He, in 22 essence, he gave a speech. 23 MR. LUTT1ER: Yeah, that, I move to strike 24 that part. We were talking about a 25 stipulation. 139 1 MR. : You can move to strike 2 anything you want to, but it's on the record. 3 MR. LUTT1ER: Well, I move to strike it so 4 if it gets played to the jury, it doesn't get 5 played. 6 BY MR. LUTT1ER: 7 Q. In each count of your complaint you allege 8 that on the occasions that you went to Mr. Epstein's 9 you were paid in excess of $200. Do you know how 10 much you were paid on each occasion? 11 A. Between 200 and $300. 12 Q. How do you know which times you got paid 13 200, and which times you got paid more than 200, if file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008187 EFTA00159039
14 you know? 15 A. I remember. 16 Q. Well, how many times were you paid 200? 17 A. I was paid $200 two times and $300 the rest. 18 Q. Is there a reason why in your complaint 19 you then alleged that after the two, first two 20 visits you were simply paid in excess of $200 as 21 opposed to alleging you were paid 300? 22 A. What? 23 Q. In your complaint you just say you were 24 paid in excess of 200? 25 A. Where are you in this complaint, man? 140 1 Q. You can pick any page you want. I happen 2 to be looking at Page 84 but -- 3 MR. : Well, the form of the 4 question is improper. This an unverified 5 complaint. If you have a question about the 6 underlying facts, then you should ask the 7 question about the underlying facts. But a 8 reference to the complaint is not relevant or 9 material or reasonably calculated to lead to 10 the discovery of admissible evidence. 11 We would be happy to answer questions 12 about the underlying facts. 13 BY MR. LUTTIER: file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008188 EFTA00159040
14 Q. You, you — were you ever paid less than 15 $200. 16 A. No. 17 Q. Have you ever told anyone you were paid 18 less than $200? 19 A. No. 20 Q. What did you do with the money that you 21 were paid? 22 A. I bought things until I bought drugs. 23 Q. What kinds of things did you buy with the 24 money? 25 A. Clothes, things for my mom, things for school. 141 1 Q. Did you enjoy the things that you bought 2 with the money? 3 A. Yeah. 4 Q. Did you want to -- after the first time 5 you went to Mr. Epstein's, did you want to go back 6 and continue to perform massages and earn money? 7 A. Yeah. 8 Q. What did you say, yes? 9 A. Yes. 10 Q. Did you enjoy the occasions when you went 11 to Mr. Epstein's? 12 A. Yes. Like enjoyed collecting the money, yes. 13 Q. Well, you enjoyed what you were doing, 14 didn't you? You enjoyed spending time with him? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008189 EFTA00159041
15 A. Not exactly spending time with him. I enjoyed 16 going to be able to collect that much money. 17 Q. Is it a fact that Mr. Epstein treated you 18 better than many of your own acquaintances treated 19 you? 20 A. No. 21 Q. Did he treat you better than your own 22 boyfriends treated you? 23 A. No. 24 Q. You had boyfriends that, that beat you up, 25 didn't you? 142 1 A. Yeah, but that doesn't mean that he treated me 2 better than my boyfriends treated me. 3 Q. Mr. Epstein ever beat you up? 4 A. No. 5 Q. You had a boyfriend that held a gun to 6 your head, didn't you? 7 A. Yes. 8 Q. Mr. Epstein never did that? 9 A. No. 10 Q. Would you agree with me that Mr. Epstein's 11 conduct towards you was better than your boyfriend's 12 conduct towards you when he beat you up and held a 13 gun to you? 14 A. I suppose, but Mr. Epstein never -- I don't file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008190 EFTA00159042
15 see how that would -- 16 Q. Did you -- have you alleged in your 17 complaint everything that occurred when you went to 18 Mr. Epstein's? 19 MR. : I'm going to object to the 20 form of that question. It is vague, overly 21 broad, ambiguous, and improper in its reference 22 to the contents of the complaint. We'll be 23 happy to answer any questions you may have 24 regarding the underlying facts. 25 MR. LUTTIER: Well, my question stands. 143 1 BY MR. LUTTIER: 2 Q. Did you allege everything that occurred -- 3 MR. : I am going to instruct -- 4 MR. LUTTIER: -- when you were at 5 Mr. Epstein's without going though every 6 word -- 7 MR. : I am going to instruct 8 not to answer that question. It's 9 really not susceptible of a response. 10 BY MR. LUTTIER: 11 Q. In your complaint -- all right. Let me, 12 let me ask you about the first time that you went to 13 Mr. Epstein's. 14 A. Uh-huh. 15 Q. Were you fully clothed during the entire file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008191 EFTA00159043
16 period of time that you were there? 17 A. No. 18 Q. For, for what period of time were you 19 fully clothed? 20 A. For the first half hour. 21 Q. Then what happened? 22 A. He asked me to take off my shirt. 23 Q. And what did you tell him? 24 A. Okay. 25 Q. Did you tell him you didn't want to? 144 1 A. Yeah. 2 Q. And what did he say? 3 A. I would get extra money if I did. 4 Q. Did you say you still didn't want to? 5 A. Yeah, but I also wanted the extra money. 6 Q. So he didn't, he didn't force you to do 7 it? 8 A. No, he bribed me to do it. 9 Q. Okay. And how much were you originally 10 going to get paid on the first occasion? 11 A. $200. 12 Q. And what did he say to you about any 13 additional money? 14 A. That if I took off my shirt, he would give me 15 extra money. So therefore he bribed me into taking off file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008192 EFTA00159044
16 my clothes for money. 17 Q. So, how much did you get paid on the first 18 visit? 19 A. $300. 20 Q. So, your testimony earlier that the first 21 two visits you only got two paid 200 is incorrect? 22 MR. : That wasn't her testimony. 23 I think you misunderstood her testimony. 24 MR. LUTTIER: Was it a form objection? It 25 was what her testimony was, but I am not going 145 1 to argue with you. 2 MR. : I disagree. That's not the 3 way I recall it, but the record is what the 4 record is. 5 MR. LUTTIER: Yeah. 6 BY MR. LUTTIER: 7 Q. When you took your shirt off, did you have 8 a bra on underneath? 9 A. Yes. 10 Q. Was it any different than going to the 11 beach in a bathing suit? 12 A. I wasn't at a beach. I was at somebody's 13 house. 14 Q. Was your bra any different than or did it 15 cover less than your bathing suit top? 16 A. No. It covered more than my bathing suit top. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008193 EFTA00159045
17 Q. Yeah. All right. So on the first 18 occasion, other than taking off your shirt off when 19 you had a bra underneath, were you othenvise 20 dressed? 21 A. Yeah. I only had, I only had my jeans and a 22 bra on. 23 Q. Okay. 24 A. Or my shorts. I was wearing shorts. I'm 25 sorry. 146 1 Q. On the -- and that was throughout the rest 2 of the time you were there on the first occasion? 3 A. Uh-huh. 4 Q. On the second - 5 A. Yes. 6 Q. On the second occasion, were you fully 7 dressed? 8 A. No. 9 Q. How were you dressed during the second 10 occasion? 11 A. I was clothed up until I was wearing a bra and 12 underwear. 13 Q. That is you started out to give this 14 massage clothed? 15 A. Yes. 16 Q. And then you removed clothing? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008194 EFTA00159046
17 A. Yes. He asked me if I would take off my 18 clothes, and I told him I didn't feel comfortable 19 getting naked like he wanted me to. So, I only, I 20 stayed in my bra and underwear. 21 Q. So, did he specifically ask you to get 22 naked? 23 A. Yeah. 24 Q. And you said you didn't want to? 25 A. Yeah. 147 1 Q. And he honored that wish? 2 A. Well, after he asked me for five minutes, and 3 I told him no, yeah. 4 Q. Did you tell him that you would be willing 5 to take your shirt and pants off and be in your 6 underwear and your bra? 7 A. Yeah. 8 Q. And then you remained in that state of 9 dress on the second occasion? 10 A. Yes. 11 Q. On the third occasion were you fully 12 dressed? 13 A. No. 14 Q. How were you dressed the third occasion? 15 A. Well, I was fully dressed when I got there, 16 yes- 17 Q. Okay. Did you — were you fully dressed file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008195 EFTA00159047
18 throughout the massage? 19 A. I took off my bra that time. 20 Q. Did he ask you to take off your bra? 21 A. Yeah. 22 Q. And what did you say? 23 A. I, 1, at first I didn't want to, and then I 24 did. 25 Q. Well, when you said you didn't want to, 148 1 did he make you take it off? 2 A. Well, he asked me. He kept asking me to. 3 Q. And you said no, right? 4 A. Yeah. 5 Q. And he honored that, your statement, 6 correct? 7 A. Yeah, but he kept asking me, so I did. 8 Q. He didn't offer you any more money, did 9 he? 10 A. No, but I wasn't going to get the money if 1 11 didn't do it so did I it. 12 Q. Who, who -- why do you say you weren't 13 going to get the money? 14 A. Because he told me I wasn't. 15 Q. What exactly did he tell you? 16 A. He said, well, then, I'm not going to pay you. 17 Q. This is on the third visit? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008196 EFTA00159048
18 A. So I said fine. 19 Q. Was anyone else present for this 20 conversation? 21 A. No. 22 Q. Okay. So you got $300 on that occasion? 23 A. Yeah. 24 Q. And you were topless? 25 A. (Witness nods head.) 149 1 Q. On the fourth time that you went, were you 2 fully dressed? 3 A. I don't remember from, like -- I don't 4 remember the specific fourth, fifth, sixth, seventh, 5 eighth times I was there. So, if you're going to 6 continue on the fifth and the sixth and the seventh, I'm 7 not -- I don't remember so -- 8 Q. Well -- 9 A. I am trying to help you out here. 10 Q. Is it true that when you went, you 11 voluntarily removed your clothes? 12 A. He bribed me with money. 13 Q. Wait a minute. You, you told me that the 14 most you got was 300 and you got that by the third 15 visit, correct? 16 A. Yeah. So — 17 Q. So — 18 A. I guess, yes, it would be voluntarily I took file:///D/...20[SUBJECPY•20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008197 EFTA00159049
19 my clothes off. 20 Q. Were you -- did there come a time that 21 when you went to give a massage, would you just go 22 over there and take all your clothes off before you 23 started the massage? 24 A. He asked me to take my clothes off. 25 Q. At the beginning of the massage? 150 1 A. Yeah. 2 Q. All right. And you said okay? 3 A. Yeah. 4 Q. Was there ever a time that you said, I 5 don't want to, and he said, no, you have to? 6 A. Yeah, there were times where he said that. 7 Q. Okay. And did you not take them off? 8 A. No, l took them off. 9 Q. Well, when did he say you had to take your 10 clothes off? 11 A. When he told me I have to take my clothes off 12 Q. And, and but did you just remove your 13 clothes, or did you say I don't want to? 14 A. I said I don't want to. 15 Q. Did you leave? 16 A. And he said, well, can you remove your 17 clothes? 18 Q. And what you did say then? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008198 EFTA00159050
19 A. I said 1 would prefer not to, but I did it 20 anyways. 21 Q. Okay. He didn't force you to do it 22 though? 23 A. If he -- he didn't physically take them off of 24 me, no. 25 Q. You could have left. Nothing prevented 151 1 you from leaving? 2 A. Right. 3 Q. You said that some friend of yours named 4 • • whose last name you can't remember, 5 took you there for the first time? 6 A. Yeah. 7 Q. How did you know this person, IM • 8 9 A. Through friends of mine. 10 Q. What friends? 11 A. My, my son's father, MB and his 12 friend. It was his friend, his friend's girlfriend. 13 Q. Okay. It was 14 was friend girlfriend? 15 A. Yes. 16 Q. Who was friend? 17 A. 18 Q. Did you know from 19 anyplace? • IM file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008199 EFTA00159051
20 A. No. I knew him from went to 21 school him. 22 Q. Okay. And this MI was 23 girlfriend? 24 A. Yes. 25 Q. When did she -- how was it that she came 152 1 about taking you over to Epstein? 2 A. She asked me. 3 Q. And when did she ask you in relationship 4 to when you went? 5 A. What do you mean? 6 Q. Well, was it the day before you went that 7 she asked you? 8 A. No, it was the same day. 9 Q. So, was that the first time she asked you? 10 A. Yeah. 11 Q. So, the day that you went, sometime 12 earlier that day, she asked you if you wanted to do 13 what? 14 A. She didn't explain to me what was going to 15 happen. All she said was a friend of mine, we can go 16 over there. You give him a massage and he will pay. 17 Q. Did you know how old he was? 18 A. No. 19 Q. And did she tell you, did she tell you file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMI EFTA_00008200 EFTA00159052
20 anything about roughly how old he was? 21 A. She said he was older. 22 Q. Okay. And what did you understand that to 23 mean? 24 A. He was older than me. 25 Q. And when you got there, you saw him, 153 1 correct? 2 A. Yeah. 3 Q. Could have left at that point, right? 4 A. Oh, well, not exactly, because being that I 5 that was her car and I didn't know where the hell I was. 6 Q. Did you tell MIMI when you saw 7 Mr. Epstein, stop, 1 don't want to do this. 8 A. No, because I didn't know I was going to have 9 to remove any clothes. 10 Q. All right. Did she tell you anything 11 other than you were going to go over and give a 12 massage to an older man? 13 A. No. 14 Q. Certainly after the first time you knew 15 what was involved, right? 16 A. Not exactly. I didn't know I was going to 17 have to get naked in the future. 18 Q. Well, at the very first time after you 19 left there, you knew what that incident involved 20 because you just experienced it, right? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_0000820 I EFTA00159053
21 A. Well, he only -- he never forced me to take 22 off my clothes other than -- yes, I took off my shirt 23 and I stayed in my bra and my jeans. 24 Q. Right. My point is that after the first 25 time, if you didn't want to, you could have simply 154 1 said I am not going back under any circumstances, 2 right? 3 A. Right, but -- 4 Q. Okay. Now, when this • 5 took you over, after you left did — what did you 6 tell her, if anything, about having been there? 7 A. I didn't really talk to her about it. 8 Q. Did IM • give you any kind of 9 drug before you went there? 10 A. No. 11 Q. Did you give MM any of the 12 money that you received when you went there the 13 first time? 14 A. No. 15 Q. Did I. MI get paid to take you 16 there the first time, do you know? 17 A. I have no idea. 18 Q. Did there, did you go with MI 19 on more than one occasion? 20 A. No. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008202 EFTA00159054
21 Q. The second time you went did anybody take 22 you there? 23 A. No. 24 Q. Have you ever told anyone that you went 25 with or that took 155 1 you there on more than one occasion? 2 A. No. 3 Q. Had, did anyone else ever take you to 4 Mr. Epstein's, any other girl other than 5 6 A. No. 7 Q. And why is it that, under, under what set 8 of circumstances did you go back to Mr. Epstein's 9 without going with MM? 10 A. Because Mr. Epstein asked me for my phone 11 number and I gave it to him and he called me for me to 12 go over there. 13 Q. Did you and ever have a 14 disagreement about that fact? 15 A. No. 16 Q. Did you know that M. I was 17 getting paid money take you there? 18 A. No. 19 Q. Did there come a time that you asked 20 others to go to Mr. Epstein's? 21 A. Yes. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008203 EFTA00159055
22 Q. And for how long had you been going to 23 Mr. Epstein's before you asked someone else to go? 24 A. Couple of months, more — well, I can't — a 25 couple, more than two. 156 1 Q. And at the point in time that you asked 2 someone to go, had you, had you performed massages 3 for Mr. Epstein totally nude? 4 A. Yes. 5 Q. What else had occurred during your 6 massages with Mr. Epstein at the point in time that 7 you asked others to go? Do you understand my 8 question? 9 A. No. 10 Q. All right. You, you had been giving him 11 massages in the nude, right? 12 A. Uh-huh. 13 Q. Anything else? 14 A. Has anything else happened while I was there? 15 Q. Up to that point in time involving you? 16 A. He had some girl eat me out and he had sex 17 with her. 18 Q. And that was before you asked someone else 19 to go? 20 A. Yeah. 21 Q. And do you recall when that was? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008204 EFTA00159056
22 A. I don't remember the dates and times. 23 Q. Have you ever told anyone prior to today 24 that that event occurred? 25 A. Besides my attorneys, no. Oh, and those 157 1 people I talked to, the FBI and the state people. 2 Q. Do you remember me asking as there is 3 nothing in your complaint about this. So, do you 4 know why that would be? 5 MR. : That's an improper question. 6 You don't need to answer that. 7 MR. LUTTIER: Did you review — 8 MR. : It's not required, it's not 9 required to be in her complaint. The 10 suggestion that it is improper. Questioning 11 her about the contents of the complaint is 12 improper. 13 MR. LUTTIER: If you want to tell her not 14 to answer, that's fine. We don't need to go 15 through it. 16 MR. : That's fine. 17 BY MR. LUTTIER: 18 Q. Did you read the complaint before it was 19 filed? 20 A. Yeah, I read the complaint. 21 Q. Did you -- when you read the complaint did 22 you notice there was anything missing from it? file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008205 EFTA00159057
23 A. No, I trust my attorneys. That's why they're 24 my attorneys. 25 Q. Did you tell anyone, your lawyers or 158 1 anybody else that there was, there were other facts 2 and circumstances that weren't included -- 3 MR. : Don't answer that question. 4 That is obviously a privileged communication. 5 BY MR. LUTTIER: 6 Q. All right. When did this event happen 7 where you say there was another girl involved? 8 A. I just told you I didn't know the dates and 9 times. 10 Q. Well, you said that, correct me if I am 11 wrong -- well, let me rephrase the question. 12 Approximately how many months had you been going 13 before you asked someone else, or took somebody else 14 there? 15 A. I don't know. More than two months. 16 Q. More than two. Anything more specific? 17 Could it have been a year? 18 A. Three, four, five, maybe even six months. 19 Q. All right. So, sometime within the first 20 six months this event happened involving this other 21 girl? 22 A. Yeah. file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008206 EFTA00159058
23 Q. All right. Tell me the facts and 24 circumstances that occurred on that occasion 25 starting with when you went to Mr. Epstein. 159 1 A. I got there and some other girl came in and 2 said she was going to help me. And -- or he came in and 3 introduced me to her. He took a shower. She said she 4 was going to help me do the massage. And the next thing 5 I know, that's what was happening. 6 Q. Well, who was this person? 7 A. I don't remember her name. She was really 8 pretty, though. 9 Q. Had you ever seen her before? 10 A. No. And I have never seen her again. 11 Q. Did she identify herself to you? 12 A. I don't remember her name. 13 Q. At the time did she introduce herself to 14 you? 15 A. Yes. 16 Q. Did she say who she was? 17 A. Yes. 18 Q. What did she say? 19 A. I don't remember her name. 20 Q. Okay. Other than her name did she say -- 21 A. She said hi, I'm — and I am going to help you 22 today. 23 Q. She didn't say, for example, I am the lawn file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008207 EFTA00159059
24 man here or something like that? She didn't 25 identify what her status or position was, if any? 160 1 A. I just told you no. 2 Q. Okay. 3 A. I just told you what she said to me. 4 Q. Okay. So, this, this, a girl is in the 5 room. Mr. Epstein takes a shower. What occurs 6 next? 7 A. I was standing there ready for him to like lay 8 on the massage table. And she got down on her knees and 9 started eating me out. 10 Q. Were you dressed at the time? 11 A. No, I was naked. 12 Q. Had you removed your clothes voluntarily 13 at that point? 14 A. Yes. 15 Q. Was this other woman dressed! 16 A. No, she was naked too. 17 Q. When did she get naked in relationship to 18 when you came in the room? 19 A. She came into the room and Mr. Epstein asked 20 us to get naked and he got into the shower. So we were 21 already naked by the time he got out of the shower. 22 Q. Okay. So, that, did that, the fact that 23 this other girl was naked in the room cause you, did file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFFA_00008208 EFTA00159060
24 you say anything like I want to leave or -- 25 A. No. 161 1 Q. Did you ask her any questions? 2 A. No. 3 Q. Seem unusual to you? 4 A. No. 5 Q. Okay. Wasn't the first time you saw 6 another woman naked, right? 7 A. No. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008209 EFTA00159061
25 1( 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008210 EFTA00159062
25 Q. So, a one-year period? 163 1 2 3 4 5 6 7 8 9 1 11 12 13 14 15 16 17 18 19 2 21 22 23 24 25 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008211 EFTA00159063
164 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 16 file:///D/...20[SUBJECPY.20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFTA_00008212 EFTA00159064
1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 * * * * * 22 23 24 25 file:///D/...20[SUBJECPY*20T0%20PROTECTIVE%200RDER%20PARAGRAPHS°4207,%208,%209,%2010,%2015,%20and%20171.1412/10/2025 3:06:21 PMJ EFIA_00008213 EFTA00159065

