32 1 December 30th, 2014, that every massage given to anybody 2 at Mr. Epstein's residence was a code word for sexual 3 abuse? 4 A. It was my understanding that the term 5 "massage" was frequently, if not almost invariably, used 6 as a code word for sexual abuse, or at least sexual 7 activity, if the girl happened to be over the age of 18. 8 But in most cases at least, or in many cases depending 9 on exactly what universe you're looking at, these were 10 underage girls, under the age of consent in the State of 11 Florida, they were under the age of 18. 12 Sometimes as young as -- I think it went all 13 the way down to, gosh, I'm trying to remember now, I 14 think 13 or 14 was was the youngest age in the police 15 report. 16 Q. Is it your position that as of December 30th, 17 2014, you had a sufficient basis under the Federal Rules 18 of Procedure and applicable ethical rules to allege that 19 anyone who got a massage at Mr. Epstein's residence had 20 abused minors? 21 A. No. 22 Q. What -- back up now. With respect again to 23 other minors as of December 30th, 2014, had anyone -- 24 had any young woman, other than -- we will put -- I'm 25 going to ask about Virginia Roberts separately. ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021855