Page 452
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
-vs- VOLUME IV OF IV
JEFFREY EPSTEIN,
Defendant.
Related cases:
08-80232, 08-08380, 08-80381, 08-80994,
08-80993, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
CONTINUED VIDEOTAPED DEPOSITION OF
JANE DOE NO. 4
Friday, February 12, 2010
10:10 - 12:27 p.m.
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
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Page 453 Page 455
1 APPEARANCES: 1 PROCEEDINGS
On behalfof Jane Does I through 8:
2
4 STUART S. MERMELSTEIN, ESQUIRE 3 Deposition taken before Cynthia Hopkins,
WIT2, P.A. 4 Registered Professional Reporter and Florida
5 Professional Reporter, and Notary Public in and for
6 the State of Florida at Large, in the above cause.
I
Phone: 7
7 E-mail: 8 THE VIDEOGRAPHER: This is the 12th day of
8 9 February, 2010. The time is 10:12 ant. This
On behalfof the Dekndant, Jeffrey Epstein:
to MARK T. LUTDER, ESQUIRE 10 is the videotaped deposition of Jane Doe No. 4
LUTTIER & COLEMAN, LLP 11 in the matter of Jane Doe No. 2 versus Epstein,
11 12 Epstein.
13
El
Phone: 14
13 15 My name is Shasha Quimby. I am the
14 ALSO PRESENT: 16 videographer representing Visual Evidence, Inc.
n ShashaQuimby,Videograpixe
Visual Evidence, Ineaporated 17 Would the attorneys please announce their
16 18 appearances for the record.
17 19 MR. MERMELSTEIN: Stuart Mermelstein for
18
19 20 the Plaintiff, Jane Doe No. 4.
20 21 MR. LUTT1ER: Mark Luther for the
21 22 Defendant, Mr. Epstein.
22 23 Thereupon,
23
24 24 (JANE 110E NO.4)
25 25 Having been first duly sworn or affirmed, was
Page 454 Page 456
3. 1 examined and testified as follows:
2 2 THE WITNESS: Yes.
3 INDEX 3 THE COURT REPORTER: Thank you.
4 4 DIRECT EXAMINATION
5 WITNESS: — DIRECT CROSS REDIRECT RECROSS 5 BY MR. LUTITER:
6 JANE DOE NO.4 6 Q. Okay. Good morning, ma'am.
BY MR. LUMER 455 7 A. Morning.
8 Q. You understand this is a continuation of
9 9 your deposition —
10 10 A. Yes.
11 11 Q. before? You understand you're still
12 NO EXHIBITS 12 tinder oath?
13 13 A. Yes, I do.
14 14 Q. Same rules apply as the last depo?
15 15 A. Yes.
16 16 Q. Okay. If you need a break let me know.
17 17 If I ask you a question you don't understand, let me
18 18 know and 1 will explain it to you.
19 19 Since your deposition on October 27th,
20 20 have you had an opportunity to review the transcript
21 21 of your deposition?
22 22 A. Yes.
23 23 Q. Were there any errors that you noted?
24 24 A. No. I haven't, well, I haven't gone through
25 t4 `~25 µ the whole thing but there is a few things that 1
u
2 (Pages 453 to 456
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1 noticed. 1 A. I don't know. There was a few things that,
2 Q. What comes to mind that you noticed that 2 well, my parents already knew but just going over like,
3 was inaccurate or needed to be changed? 3 like, I don't know, like, some of the questions. I
4 A. A few misspelled words. 4 don't — just over the whole general deposition, not
5 Q. Okay. Other than misspellings, do you 5 like, I can't recall like certain questions or certain
6 suppose there are any substantive mistakes? 6 things that we talked about. Just like general
7 A. No. 7 deposition.
8 Q. And you say you haven't had a chance to 8 Q. What is it that you felt that they needed
9 review the whole thing yet? 9 to know about your deposition?
10 ell, I let them know about
11
12
A. No.
Q. Do you know how much of it you've done?
A. 'guess pan one to part two. 12
t and that's about it. I'm pretty sure.
Q. And by the way. did vou,did you discuss
13 Q. Okay. When did you start looking at it? 13 with them
14 A. I've just been skimming through it since I got 14
15 it in the mail.
16 Q. Recently? 16 Q. Okay. anYthh18
17 A. Yeah. Just recently certain dates come in to 17 else that you discussed wt
18 mind. I was skimming through it like the weeks and 18 A. Well, that's the only one thing that comes to
19 stuff. :9 mind. I'm sure there's other things that we discussed,
20 Q. Okay. Have you reviewed anything else in 20 but I don't remember what else. But that's like the one
21 preparation for the continuation of your deposition? 21 thing that I can remember.
22 A. Looked at anything else? 22 Q. You're aware that their depositions have
23 Q. Uh-huh. 23 been taken?
24 A. Unh-unti. 24 A. Yeah.
25 Q. Had any meetings with anybody other than 25 Q. Have you talked to them since their
Page 458 Page 460
1 your lawyer 1 depositions were taken?
2 A. No. 2 A. Yeah.
3 Q. — about your deposition? Talked to 3 Q. And what was the substance of those
4 anybody else about your deposition? 4 conversations?
5 A. My parents. S A. I don't know. How are you doing today? What
6 Q. When did you talk to your pm cub? 6 are you doing tomorrow? What are you doing today?
7 A. I think — I don't remember what time. I'm 7 Q. What did you ask them about their
8 not sure. Shortly after my deposition I think. 8 depositions in particular?
9 Q. After your deposition back on, in 9 A. Nothing. I didn't talk to them about their —
10 October - 10 they asked how it went, pretty much. But I know how a
11 A. Yeah. 11 deposition goes. I went through one. So, I mean we
12 Q. — of '09? 12 just discussed like a deposition in general, like what,
13 A. No, after. Was it — what did you just say 13 like how the experience is.
14 the date of my deposition was? 14 Q. You say they asked how it went, or you
15 Q. October 27th, '09? 15 asked them how it went?
16 A. Yeah. 16 A. No, I asked. I know where depositions come
17 Q. It was sometime shortly after that before 17 fromMigtilliain things, like, how
18 Christmas? 18 you guys and that's about it.
19 A. I don't remember when I talked to them but I 19 Q. Anything else you discussed with them
20 know I talked to them after my deposition. 20 about their depositions?
21 Q. And what was the purpose of that 21 A. No.
22 discussion? What did you discuss? 22 Q. Have you read any depositions in this case
23 • A. Just to go over some things that I thought my 23 other than your deposition?
24 parents should know. 24 A. No.
25 Q. Like what? 25 Q. Have you read your parents' depositions?
3 (Pages 457 to 460)
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1 A. No. 1 there for — never been there. So, we went up there'
2 Q. Have you been provided with transcripts of 2 with some friends.
3 any of the depositions? 3 Q. What was her friend's name?
4 A. No. 4 A.
S Q. Have you spoken since your last deposition 5 Q. Does have a last name?
6 with any other Plaintiffs who have claims pending 6 A. I don't know what his last name is.
7 against Mr. Epstein? 7 Q. And what was her relationship with-?
8 A. No. 8 A. Friends.
9 Q. Have you communicated in any way with any 9 Q. And what did you-all do while you were
10 other Plaintiffs who have claims pending against 10 there?
11 Mr. Epstein? 11 A. Nothing. We went withldsgi al and we — in
12 A. No. 12 part we went and saw the cit n, sightseeing.
13 MR. MERMELSTEIN: You mean before then? 13 Q. How old is. roughly?
14 THE WITNESS: Like have I talked to them? 14 A. How old is w1201._
15 MB. MERMELSIEIN: Before or after the 15 Q. How old was roughly?
16 deposition? 16 A. I don't know, probably like 40, 50's, maybe.
17 MR. LUITIER: Since your deposition on 17 I don't, 30's, 40's. I don't know.
18 October 27. 18 Q. That's a 20 year gap from 30 to 50.
19 THE WITNESS: Like have I talked to them? 19 A. I don't know how old, I don't know how old he
20 BY MR. DOTTIER: 20
21 Q. Yeah. Let me clarify what I mean by 21 Q. Is he closer to 50 than 30?
22 communication. By communication I mean any form of 22 A. No, probably not.
23 communication whether that's talking to them, some 23 Q. Was he married?
24 computerized form of communication, whether it's 24 A. No.
25 Facebook, Twitter, e-mails, text, anything like that 25 Q. Have kids?
Page 462 Page 464
1 whether you wrote something to them. 1 A. I don't know.
2 A. Yeah. lam sure I talked to Jane Doe No. 7 2 Q. Ever been married?
3 but I don't know if I lanced to Jaw Doe No. 3 after my 3 A. I don't know.
4 deposition. I might have talked to Jane Doe No. 3. 4 Q. Have a job?
5 Q. When was the last time you talked to Jane 5 A. I don't Imow. I'm sure he had a job but I
6 Doe No. 7? 6 don't {mow what it was.
7 A. Probably like two days ago. 7 Q. What did you know about hint?
Q. And for what purpose did you talk to her 8 A. Nothing. I really didn't -- I mean, he
9 two days ago? 9 to go to, or invi I No. 7 to go to
10 A. She told me about her weekend. 10 Iliriutd she invited m like four of our, of
11 Q. ligere is Jane Doe No. 7 living now? 11 our friends. l Mini( it was five of us that went down
12 A. 12 there. And pretty much I just hung out with my
13 Q. Have you ever traveled out of the State of 13 girlfriends. I didn't talk to him.
14 Florida with Jane Doe No. 7? 14 He was Jane Doe No. '7's friend. You know,
15 A. Yeah. 15 he wasn't really around. And whenever he was, it
16 Q. Where did you travel? 16 wasn't !didn't really talk to him. I was more
17 A. 17 hanging put with my frill I was talking to
18 Q. And when was that? 18 him trying to get to know
19 A. I think it was my junior summer. Yeah, my 19 Q. Did you -- where did ou-all stay?
20 junior summer. My kali:beef in college in stammer. 20 A.
21 That's when I lived in 21 Q. And did, does buying you-all
22 Q. Okay. And why did you-all go 22 anything of value?
23 A. Why did, why did we go 23 A. We went to. and he bought us all like a
24 Q. Yeah. Why did you go 24 dress to wear for that -- whenever we went out that
25 A. Her friend invited us to go we went 25 night.
4 (Pages 461 to 4 64)
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?aye 40 Page 467
Q. And where did you-all go out? 1 A. Yeah.
2 A. I don't remember what it was called. 2 Q. What is the name?
3 Q. Did he pay all the expenses for the trip? 3 A. I don't know.
4 A. Yeah. 4 Q. Can't be that name, right?
5 Q. Did anybody in your group compare him to 5 A. Yeah, I don't know what it's called, though.
6 Mr. Epstein? 6 Q. What caused you to say it was an exclusive
A. No. 7 hotel?
8 Q. Have you ever made the statement that he 8 A. Because we had wrist bands on and we didn't
9 was like Mr. Epstein? • 9 have to pay for anything, except for food or drinks.
10 A. No. 10 MR. MERMELSTEIN: You mean
11 Q. Other than the trio with lane Doe No. 7 11 all-inclusive —
12 and your other friends have you traveled 12 THE WITNESS: Yeah.
13 anyplace else with Jane Doe No. 7 outside the State 13 MR. MERMELSTETN: -- not exclusive?
14 ofFlorida? 14 THE WITNESS: Yeah.
15 A. No. 15 BY MR. LUTHER:
16 Q. When was the last time you went outside 16 Q. Okay. And there was a casino at the
17 the State of Florida? 17 hotel?
18 A. In December. 18 A. No.
19 Q. And where 19 Q. You had to go someplace else to go?
20 A. I went to th 20 A. Yes.
21 Q. And who did you go with? 21 Q. Who paid for this whole trip?
22 A. 22 A. My boyfrienckatell, yfriend paid for
23 Q. That's 23 some of the trip and and helped paid for some
24 A. Yes. 24 of it because it was her Christmas present.
25 Q. And he's still your boyfriend? 25 Q. Your boyfriend would be .
Page 466 Page 468
1 A. Yes. 1 A. Yes.
2 Q. And how long were you gone? 2 Q. And then what did II do?
3 A. Around six or seven days. 3 A. AILigjth.a helped pay for it too, her and her
4 Q. Did you go with anybody else? 4 boyfriend =.
S A. We met some friends there. 5 Q. Oh, was —
6 Q. Your friends or his friends? 6 A. It Christrnas present.
7 A. Our friends. 7 Q. -= there, too?
8 Q. And who was that? 8 A. Yeah. He showed . He had to work.
9 A. My fri 9 Q. How dig.y.91;mowIt
10 Q, is last name? 10 A. That's= good friend.
11 A (phonetic), I think. 11 Q. So, these really were friends of
12 Q. And how did you know her? 12 as a result ofyou dating him you'd come to
13 A. Through... 13 A. Yeah.
14 Q. And was there any it nIthesides 14 Q. You-all go around places together?
15 A. auk Her friend=. And 1,1know my 15 A. No. We just went over Christmas.
16 friendMI came too or this girl came. 16 . Q. Okay. They live here in the area?
17 Q. And was it a vacation? 17 A. Yeah.
18 A. Yeah. 18 Q. Did you have a good time on vacation:
19 Q. What did you-all do generally? 19 A. Yeah.
20 ed at like an all-inclusive hotel in 20 Q. Anything bad happen on vacation?
21 and hung out at the hotel, went out by the 21 A. No. What do you mean "bad?"
22 pool, went to the casino one night. I don't know if 22 Q. Well, any bad event I don't mean dinner
23 that's about it, vacation. 23 was late. I mean, you know, somebody got hurt or
24 . Did ou say it was an exclusive hotel in 24 something like that.
25 25 A. Oh, somebody got hurt or somethine„. _ aj
5 (Pages 465 to 468)
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1 Q. Yeah. 1 him now.
1 A. Oh, yeah. Somebody got hurt. 2 Q. Okay. Well, describe what your current
2
Q. What hap mj- d? 3 relationship is then between you and him.
.1 A. My friend she was going to walk off the 4 A. Well, I think it was the whole issue of going
boat and she hit her shin on the deck, on the deck. 5 through this whole deposition and being stressed out
Q. Okay. Have you, have you trawled outside 6 about it So, whenever I would go out, like I
• an lace since the tri in December to 7 couldn't -- I wasn't even comfortable being out thinking
3 8 that somebody was going to, like watching me or being
A. No. 9 paranoid.
10 Q. Have you traveled -- where you do 10 So, when we would be out together and we
11 currently live now? 11 would be drinking, slot of this deposition and a
12 A. Well, I stay at my boyfriend's house 12 lot of this whole thing that is going on with
13 • sometimes I will stay at 13 Jeffrey Epstein has brought a lot of stress on me.
So, going back and forth between ere 14 So, when I would drink like I would be
15 until I figure out what I want to do, where I want to 15 angry and we would argue a lot more. But now like,
16 stay, if I want to get my own place. 16 that, a lot of this is almost over, it's gotten, you
17 Q. Okay. So, your sister has a — 17 know, to the point, and after that whole thing it
18 A. I go up to my parents' house too. 18 was an eye-opener for me.
19 Q. If I remember correctly from the last 19 Q. The incident between you andIM
20 20 occurred before your deposition, correct?
21 A. Yeah. But I know I had my deposition and, you
22 A. No. She has a house. 22 know, you guys were goizgcr had investigators going to
23 Q. A house. And so, you stay there part of 23 my friends, going to my my family, you guys,
24 the time and then sometimes you stay at your 24 you know, were kind ofharassing me, I felt
25 boyfriend's? 25 Q. Well, the investigators went to your
Page 470 Page 472
1 A. ME. 1 when?
2 Does he still have the same place in 2 A. Uh-huh.
3 that he had before? 3 Q. ilifear —
4 A. Yes. 4 A.
5 Q. Is there any pattern that you follow 5 Q. At least a year before the deposition?
6 there? 6 A. w the exact date, but they
7 A. No. 7 went to sometime before my depositi.,,
st Q. Majority of is spent where? 8 Q. Yeah. But do you remember how far in
A. Probably 9 advance of your deposition?
10 Q. The last time we took your deposition, 10 A. How far in advance it was, no.
11 shortly before that deposition there had been s me 11 Q. How far before your deposition.
12 ncident between the two of u ant 12 A. No.
13 Q. Do you remember filing an
14 A. Yes. 14 affidavit about it?
15 Q. Do you recall that? 15 A. No. I know she filed.one, but I don't
16 A. 16 remember the exagaws,s,
17 17 Q. Okay. Sea called you and said
18 A. 18 somebody came, wanted to ask her questions about —
19 19 A. Yeah.
20 Q. — your involvement with Mr. Epstein?
21 A. Uh-huh.
Yeah, nothing. 22 Q. One time?
23 Q. Did you resolve whatever your differences 23 A. I don't know how many times. I recall one
24 were with your boyfriend about that? 24 time, yes.
25 A. Yeah. Things are really good between me and 25 Q. She didn't tell you about more than one
6 (Pages 469 to 472)
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Page 473 Page 475
1 time, did she? 1 let it ruin my life. I saw a change in my behavior,
2 A No. Did it happen more than one time? 2 like my attitude. It was making me stressed out.
3 Q. Not to my knowledge., but -- 3 It was making me emotional. Like I would
4 MR. MERMELSTEIN: Let, let Mr. Luther - 4 be happy one day, sad the next. You know, it was,
5 MR. LOTTER: Other than that - 5 it was like tearing my relationship with my
6 MR. MERMELSTEIN: — ask you questions. 6 boyfriend up, and we were getting in a lot more
7 THE WITNESS: Okay. 7 arguments but, I mean, it was like I was bipolar. I
8 BY MR. LUTTTER: was happy one minute and upset the next. He was
9 Q. Other than that, what other claim did you 9 like what's wrong with you.
10 make that investigators were doing anything? 10 And after this whole, after my deposition
11 A. re going around to people that I 11 and like after, like, talking to my family about
12 knew i that I went to high school with 12 some things that, you know, some secrets that I had
13 asking questions about me and my frienisi.e were 13 hidden. And I was open with him and told him
14 trying to get a hold of my ex-boyfriend, And 14 things, it relieved a lot of things and it made me
15 they were, I mean they were pretty much being ruthless 15 become a stronger person.
16 about it, the whole, everything. 16 And it helped me, like helped me through
17 Q. Basic, basically those investigators 17 it a little bit, helped me through the situation and
18 talked to the same people the police talked to, 18 it made ow relationship stronger.
19 right? 19 Q. Okay. So, your kind ofmoved on beyond
20 A. I don't know if ifs the same people. 20 that now?
21 Q. Well, you know the police had corn* out and 21 A. Well, I'm working on it.
22 talked to all your friends, didn't you? 22 Q. Have you been to see any psychologist or
23 A Did they? 23 psychiat
24 Q. Yeah. They called all ofyour friends. 24
25 A. I don't know at that time who was my, hie —
Page 474 Page 476
I don't know. I don't know who they, I don't know who 1 Q. My question is you're aware that he is not
2 they all talked to back then. 2 a ps
3 Q. Just so, just so we're clear, you were
4
5
6
well aware of tbe fact that the police were out
interviewing a number of your friends, weren't you?
A. Were they? I'm sure but the friends that
I Q. Okay. My question is specifically --
7 Me — 7 A. I thought, no.
8 MR. MERMELSTEIN: Just, just answer the B MR. MERMELSTEIN: Well, let him ask the
9 question to your knowledge. 9 question.
10 THE WITNESS: Yeah. 10 THE WITNESS: Okay.
11 MR LUTHER: Okay. 11 BY MR. LUTITER:
12 THE WITNESS: I got, like-- 12 Q. My question is specifically directed to
13 BY MR. LUTFIER: :3 whether or not you've seen any psychologist
14 Q. The police came and visited you, right? 14 A. No.
15 A Yeah. I know they came and saw me but my 15 Q. psychiatrist.
16 friends, are you referring to the people that, that, the 16 AIM Or I have seen Jeffrey — after my
17 girls that went to Jeffrey's or are you talking about 17 deposition?
18 the girls that didn't go? 18
19 Q. Anybody that you knew? 19
20 A. Yeah. 20 Q
21 after 21 A. Yeah.
22 22 Q. Okay. And you — before your deposition,
23 23 you went to see an individ our lawyers sent
24 A. Nothing. It opened my eyes. I was, how, how 24 you to. I think his name is He's the guy
25 much, this whole situation was aL" me. I can't 25 that flew in from California to see ?
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1 Q. Okay. Why — you went back to look at his
2 fish tank but do you see him someplace other than
3 his office?
4 A. No.
5 Q. Does your, does your boyfriend have some
6 relationship with him?
7 A. No.
8 Q. Are they in business together or anything
9 like that?
10 A. No.
11 Q. When you with went to see him again, did
12 you go alone?
13 A. Yes
14 Q. This visit two weeks ago?
15 A. Yeah.
16 Q. And the purpose of your visit was to go
17 see how be was doing, that is Mr.
18 A. Yeah, well, yeah, we didn'tveha like a
19 one-on-one, like, session or anything.
20 Q. What, did you just drop in the office?
21 A. Uh-huh.
22 Q. Did you have, do you have an appointment
23 scheduled, or you just happened to be there?
24 A. No, I didn't.
25 Q. Okay. So, you dropped in as friend?
Page 480
1 A. Yeah.
2 Q. And you were up there for some other
3 reason?
4
9 Q. So, you just ecided one day to drive down
10 to his office and see how he is doing?
11 A. Yeah.
12 Q. Any reason that you went to him other than
13 that?
14 A. No. I just know that he had a fish tank that,
15 that he had or whatever and I have a fish tank or my
16 boyfriend has a fish tank. So I like looking at fish
17 tanks. And he said he had it all hooked up and stuff,
18 so I wanted to go look at it.
19 Q. When did you fend out he had it all hooked
20 up?
21 A. Well, I know he got a fish tank from the last
22 Q. Do you, do you, do you 'mow him on a 22 time I went and saw him. He had an empty fish tank.
23 friendly basis? 23 So, I wanted to go see if it was like all hooked up and
24 A. No. I never hung out with him out of the 24 everything. I didn't know but I just kind of figured,
25 office. 25 last time I went there it was calland hers set i i
____....
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1 everything up from the last time I was there. So, I 1 your last deposition, you had a desire at that time
2 wanted to go look at it and see how it was progressing. 2 or expressed a desire that you might want to become
3 Q. If I understood your testimony originally, 3 a teacher?
4 you said he told you? 4 A. Yeah.
5 A. I didn't mean to say he told me. I was just 5 Q. Is that still what you're thinking about
6 saying whenever I went there, he had an empty fish tank 6 doing?
7 and I know he was like working on getting stuff set up 7 A. Yeah.
8 for it. Q. And did you tell us at u de pion
9 Q. So, was it just happenstance or out of the 9 that you had been accepted at to! --
10 blue that you decided on this particular day you 10 A. For my Master's, yes.
11. would go by and drop 11 Q. — the Master's program? Once you're
12 A. SI l was leavMa and t was 12 accepted in the program, do you have to enroll
13 taking=clown. And I was driving right by his office, 13 within some period of tine of when you get accepted?
14 so I figured I would stop in. 14 A. I'm sure. I don't know.
15 rs 15 Q. All right. Did you — do you intend to
16 40ien
Q yo l luthleavaillin 16 pursue the Master's?
17 A. No. 17 A. Yeah. think at • 1was trying to
18 Q. All right. It WAS -- 18 get my CIA atM. So, you have to enroll for your
19 A. Just that day. 19 Master's before you could sign up for your GA which is
20 Q. It was just happenstance that you were 20 Graduate Assistance Program. And I was waking to hear
21 driving by and you said, well, you would drop in to 21 back to see if I got in kb I didn't. So, I really
22 see — 22 can't afford to go to Ifs too expensive. I
23 A. I decided to stop by. 23 would mther go to
24 Q. -- what's happening? 24 Q. But if you — okay.
25 A. Yeah. 25 A. So, I'm going to get my Master's.
Page 482 Page 484
1 boyfriend also goes to this 1 Q. The idea of being that if you got in the
2 2 Graduate Assistance Program, that they had would in
3 A. Ite did go there. 3 essence pay you?
4 Q. Okay. You say that's did as in past 4 A Yeah. Then I would have pursued going to
5 tense. Does he no longer go there? 5 but since that didn't work out; I didn't get my
A. No. 6 GA, I decided to take off fora little bit and now I
Q. When did he stop going? 7 want to pursue it in, my Master's in the fall.
A. I don't ow. 8 Q. Okay. When did you find out you didn't
9 get in the Graduate Assistance Program?
10 A. Well, you're supposed to hear back I think it
11 was like the end of- I don't remember. The end of
12 A. No. 12 July, like the last month of July or something or the
13 Q. And do you know why he stopped going? 13 beginning of August.
14 A. No. 14 Certain dates, certain — like whatever
15 Q. Does he go to somebody else now? 15 you, position you like signed up for, I think it had
16 A. No. 16 a different dates of whenever you would hear back or
17 Q. You went to see, I think you said in your 17 you, yeah, different dates or something like that.
18 last deposition there were times tialswent with 18 So, 1don't ;mow. I think one was the end of July
19 your boyfriend and drove to this office 19 and the other one was maybe the beginning of August.
20 with hint is that right? 20 Q. Of '09?
21 A. Yes. 21 A. Yeah.
22 Q. But all the times you went with him were 22 Q. And when you — had you applied anyplace
23 for matters dealing with your boyfriend? 23 else until you heard about whether you were going to
24 A. Yeah. 24 get in the graduate program or —
25 Q. Okay. What, have u — if I recall from 25 A. No. Because I knew if I didn't, that I would
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Page 485 Page 487
try to look for a job fora little bit and play that / business and I don't know.
2 field out for a while, and then go back for my Master's 2 Q. Would it be comet to say that you're
3 shortly after somewhere else. 3 pursuing whatever it is you've decided you want to
4 Have you applied fora Master's degree at 4 pursue in life?
5 5 A. Yeah.
6 A. No. 6 MR. MERMELSTEIN: Objection to form.
7 Q. Is that your intention? 7 BY MR. LUTTIER:
8 A. Yes. 8 Q. Ms. -- You don't feel like there's any
9 then you would get a Master's in what 9 restrictions that have been placed upon you by what
10 10 you want to do?
11 A. 11 MR. MERMELSTEIN: Objection to form.
12 Q. Is that contingent upon you getting a 12 THE WITNESS: What I want to do, no.
13 graduate assistance there too or no? 13 BY MR. LUTTIER:
14 A. No. 14 Q. And if you wanted to go do something else,
F OkayM, you now 15 you would go do it?
16 MR. MERMELSTEIN: Objection to form,
17 A. Yeah. 17 Calls for speculation.
18 Q. -- I assume than 18 THE WITNESS: Yeah.
19 A. Yeah. 19 BY MR. LUTTIER:
20 Q. And the Master's program you understand to 20 Q. Is there any particular reason you had a
21 be, what, another year of study? 21 interest in teaching?
22 A. Yes. 22 A. (Witness shakes head.)
23 Q. And what are* after that? 23 Q. You know, friends, relatives, anything
24 A. I will get it in and then see if I 24 like that that were in it or --
25 can get involved in some • in like a school district, 25 A. No. Something that I, that I thought I would
Page 486 Page 488
1 because I want to be a school teacher. But I want to — 1 enjoy doing.
2 I just want to have my Master's for myself. I just want 2 Q. Okay. What do you do about these
3 it, so. 3 days?
4 Q. Well, you get paid more in the schools if 4
5 you have a Master's? 5
5 A. Yeah. 6
7 Q. And I think you told us the last time you 7
8 wanted to teach in the primary grades. 8
9 A. Yeah. 9
10 Q. I don't remember if it was kindergarten, 10
11 fourth grade, something like that? 11
12 A. Yeah. 12
13 Q. Still want you want to do? 13
14 A. Yeah. 14
15 Q. How long have you had an interest in 15
16 teaching? 16
17 A. When I graduated I wasn't really sure of wh 17
18 haanted to do. And I know, like, whenever I did 18
M, when I would worked there I did, worked with 19
20 little kids and I like, I like workine with little kids. 20
21. And so when I graduat 21
22 was telling me because she's a teacher and she was 22
23 telling me about it and I just started like hinting 23
24 around about it and thought about it and I said, why 24
25 not. I didn't really know what to do with this 25
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Page 489 Page 491
1 want a big family, small family?
2 kids.. Yeah.
39 thaZ
QQyLliviu
tit. IW ,h, big or small?
4 w, medium.
5 as what these days?
6 don't 'caow, probably -- l don't know — two
7
8 Okay. noes M Ilia: have any habits
don't like?
10 A. No. ell kills°
11 Q. There was a w u were —
12 A. Well, actually Sometimes at
13 Q. Okay. How would acterize -- oh, 13 nighttime whenever I am like, sit down. He has got to
14 strike that. Do you and Mr. have any 14 be running around and I am like, what are you doing.
15 intentions to get married? 15 Q. But would it be a fair statement to say
16 A. Yeah, I think so. We talked about it before. 16 that you and he enjoy each other's company?
17 Q. Okay. What's the — is he — 17 A. Yeah.
18 A. Ifs not like I'm a girl and trying to -- 18 Q. You have fun together?
19 Q. Talking about it is one thing. Has he 19 A. Uh-huh.
20 ever fonnally asked you if you want to get married? 20 Q. You like to get up in the morning and look
21 A. No. 21 fen-ward to doing stuff with him?
22 Q. But you have had discussions about that? 22 A. Yeah.
23 A. Yeah. Well, he brought it up to me but I'm 23 Q. Tell me about his business.
24 not like, well, when are you going to do it. 24 111iLlatafattggvjj mean — I don't know.
25 Q. Should he ask you that question at some 25 I . He's, I don't 'mow, busy
Page 490 Page 492
1 point in time, would you be inclined to get married? 1 right now, I guess. It's season right now. So, any
2 A. Yeah. 2 business out there right now trying to make it, if they
3 Q. Okay. So, you, this is somebody you think 3 are not making it in season right now then, I don't
4 you have found that is a special person for you? 4 know, it's not good.
5 A. Uh-huh. 5 2a And what's his relationship with.
6 Q. Well, congratulations. 6 like?
7 A. Thanks. 7 A. Good.
8 Q. And he hi --if! remember correctly, 1 8 Q. Are they close in age?
read somewhere 9 ysaLUISdc, yeah.
I
11
n
A. Yeah. They -- yeah.
10
11
A. ..,
Q.
somewhere?
obviously lives locally
12 Q. Okay. And what's the name of the 12 Yeah. No.
13 busineS, 13
14 A. 14 Q. married?
15 Q. Would you be excited about getting 15 A. Yeah.
16 married? 16 Q. Got kids?
17 A. Yeah. 17 A. No.
18 4 Okay. How about kids? Do you third( 18 Q. Do you know his wife?
19 you're -- 19 A. Yeah.
20 A. Yeah. 20 Q. Get along with her?
21 Q. Do you think you're a mom type? 21 A. Yeah.
22 A. Yeah. 22 Q. You met his parents?
23 Q. You would want to have kids? 23 A. Yeah.
24 A. Yeah. 24 Q. Where do they live?
25 Q. You have got elan about — I mean, you 25 A. His mom lives —and his dad Hymn
11 (Pages 489 to 4 92)
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1 1 Q. Okay.
2 Q. They are divorced? 2 A. But like there was like something for
3 A. Yes. 3 Walgreen's management or something like that. I put a
4 Q. Not remarried? 4 resume together and sent it in, but other than that —
5 A. Nape. 5 Q. And what would be the idea that you would
Q. No. Do you spend time with them? 6 just work for them until you got into the —
7 A. Yet 7 A. Until, until I saved some money up so I can
8 Q. Like them? 8 pay for my — save money up so I can start — save my
9 A. Yeah. 9 money up so I can start my Master's in the falL
10 Q. Has he met your parents? 10 Q. Fall meaning?
11 A. Yes. 11 A. This fall corning up in August. August of
12 Q. Okay. He goes up toMM1 tias he 12 '010.
13 gone up their to see them in the trailer park and 13 Q. August of '010. But you're okay with the
14 stuff? 14 fact that you're not actively employed at the
15 A. Yeah. 15 present time? That's doesn't bother you?
16 Q. Okay. They like him? 16 A. No.
17 A. Yeah. 17 Q. Okay. And you have got a game plan that
18 Q. So, everything is kind of lined up right? 18 you're following?
19 A. Yeah. 19 A. Yeah.
20 Q. Okay. Do you work for the business too? 20 Q. And you're really Mixt of looking for some
21 A. and like when he'll 21 kind ofhiatus job that would fill the gap between
22 now and when you go to school?
Or like he 23 A. Yeah
24 will ask me to send something and 1 am at home, I will 24 Q. Is your physical relationship with
25 send him something or send him something through e-mail, 25 acceptable to you?
Page 494 Page 496
but I don't work — lamnot out there l 1 A. What do you mean physical?
2 Q. Sexual relationship?
3 Q. I guess the real question, do you get paid 3 A. Yeah.
4 a salary? 4 Q. Do you — I think at the last —
5 A. No. 5 A. Ifs better than what I would like it. It's
6 Q. Do you have any kind of employment right 6 not on his part but on my behalf, I'm not, I am never
7 now? 7 the aggressor. I am not aggressive like I should be.
8 A. No, not as of right now. 8 And sometimes I want to, I just don't. I don't know
9 Q. Okay. When was the last time you were 9 why. I just don't pursue things sometimes. And he
10 employed? 10 always has to pursue me, so it's not on his behalf.
11 A. When I thin 11 It's on my behalf.
12 Q. Was 12 Q. I think at the last deposition you said,
13 A. Yeah, 13 and correct me if I am wrong. I might be wrong.
14 Q. Okay. So, that was what, '8; 08? 14 But that you and he were intimate two or three times
15 A. I think. 15 a week.
16 Q. Is that when you were living in 16 A. Yeah.
17 with Jane Doe No. 7? 17 Q. Have there been times in the past when
18 A. Yeah. 18 you've been intimate with an individual as much as
19 Q. Okay. Okay. Are you actively seeking 19 once a day?
20 employment or— 20 A. Uh-huh.
21 A. As of right now, yeah. 21 Q. The level of the degree of intimacy
22 Q. What kind of stuff are you looking for? 22 between you and he is okay with you?
23 A. Nothing. I mean, anything like on the 23 A. Yeah. Well —
24 Internet like for employment. Trying to think. 1 24 Q. He, of course, would want, would want
25 haven't, the last time I did it was like a month als o. ,.. 25 more?
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Page 497 Page 41' ;
1 A. I'm SUM Like there, just, yeah, ifs fine
2 with me. I mean there are sometimes where 1 want it. 1
3 just don't pursue everything, and he always has to be
4 the one to pursue me. So, lam sure be gets --1 don't
5 know.
6 Q. Has he indicated to you that your intimacy
7 level or performance is unacceptable to him?
8 A. No.
1
9 O. Okay. Since you graduated from -
10 have you undergone any surgery? Q. What's your relatbosh:p -•
Page 498 Page 500
•-
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Page 501 Page 503
1 A. Yeah.
2 Q. Have you had any discussion with him about
3 his deposition?
4 A. No.
5 Q. Not even a little discussion that, lace
6 when you left today that maybe I know your
7 deposition is going to be taken today?
8 A. Like, I, I'm aware that he has a deposition.
9 Like all this deposition stuff, that I have to give a
10 deposition tomorrow, stuff like that.
11 Q. Do you know if he met with anybody about
12 his deposition?
13 Q. Have you — when was the last time you 13 A. No.
14 used any kind of, what I am just going to call an 14 Q. You don't know or he didn't?
15 illegal drug. And by that I mean the typical sort 15 A. Ho didn't.
16 of recreational stuff you hear, whether it was 16 Q. — what's name?
17 Xanax, without prescription, Xanax, cocaine, heroin 17 A.
18 or any of those things. When was the last time you 18 Q. And is married?
19 used any of that? 19 Yes.
20 A. It would be a long time ago. I don't even 20 And does her husband live with her?
21 remember. Probably — 21
22 Q. Over a year? 22
23 A. Yeah.
24 Q. Couple of years?
25 A- Yeah.
Page 502 Page 504
1 Q. Okay. There was a time in your life when 1
2 you were younger that you used those drugs; is that 2 Q. Have kids?
3 right? 3 A. Yeah.
4 A. Yeah. 4 Q. How many?
5 Q. Is that all something you put behind you 5
6 now? 6
7 Yeah. 7
8 Q. Don't use them at all anymore? e
9 A. No. 9
10 Q. Whether marijuana? 10
11 A. No. 11
12 Q. Cocaine? 12
13 A. No. 13
14 Q. At one time, at one time did use 14
15 some cocaine? 15
16 A. No. 16 Q.
17 Q. Mra 17
18 A. Uh-huh. 18 Q.
19 Q. Okay. So, drugs is just not part of your 19 A.
20 life anymore, correct? 20 Q. Do you like babies?
21 A. No, not that I — it's something that I, like, 21 Oh-huh. Yes, sorry.
22 in nv experimenting phase in high school that I tried. 22 Id you describe your relationship
23 Nothing that ever really
ton 't m 23
24 Q. Okay. Now, Mr. deposition is 24
25 scheduled to be taken you ay.:are2f that? 25 Q. Okay. Would you describe your
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Page 505 Page 507
1 relationship your parents as being close? Sumner of junior year. That
2 A. Yeah. Yes. I
3 Q. So, at the present time could your 3 A.11 And then 1 visit there a few times. I
4 relationship with your direct family members be any 4 think lived there. I visited her a few times,
5 closer than it is? 5 and then whenever Jane Doe No.7 was living up there,
6 A. No. 6 would visit h few tine .
7 Q. And ifs just you fa? 7 Q. That's
3 8 A. Yes.
9 Q. Do you keep contact with
10 A. No.
11 Q. Have you had any contact with Mr. EIR? 11 Q. Keep contact with Jane Doe No. 7?
12 A. No. 12 A. Yes.
13 Q. When was the last time you had any contact 13 n° you 'mow, do you know where
14
15
with hith?
A. I don't remember. A long time ago.
14
15
mi A. No.
is?
16 Q. Did you see a copy of his deposition? 16 Q. Any reason why you don't keep contact with
17 A. No. 17 her?
18 ever e following statement 18 A. Yeah, she, out of the blue somewhere she like
19 to or or words to this 19 freaked out on me and didn't know where it was coming
20 of respect to this individual you visited 20 from. Sounded more like an influence than a — from
21 it We met another Epstein but more weird 21. somebody, somebody else. So, I haven't talked to her
22 and perverted? 22 since because I am just letting her do her own thing
23 A. No. 23 until she figures out what she —
24 Q. You don't recall that? 24 Q. I don't understand your answer.
25 A. No. 25 A. We were — it was an argument about something
Page 506 Page 508
1 Q. Were you, in addition to being frie 1 ridiculous that my friend she was trying to —
2 ate No. 7, are, were you friends with". 2 for h hip she was trying to get an interview
3 3 boYfrilire time. And I didn't tell
4 A. What do you mean " "? 4 about it and freaked out and was like, why
5 Q. Or are you friends with 5 arc you trying to bring another girl around my
6 A. No. I am not friends with her. 6 boyfriend, which it wasn't like that at all.
7 Q. Were you at one time? 7 She just kind of like exploded over
8 A. Yeah, acquaintances. 8 something ridiculous and used words to me that a
9 Q. Did you-all room together at one time? 9 good friend wouldn't So, [just kind of was, like,
10 A. No. 10 you know, backed off a little bit and we haven't
11 Q. Were you suppo rm with Jane Doe 11 really spoken since.
12 No. 7 at one time up in 12 Q. And when did that happen?
13 A. Yeah. 13 A. Probably a good, like, seven months ago.
14 Q. And then Jane Doe No. 7 decided to come 14 Q. Are you friends with Jane Doe No. 3?
15 here? 15 A. Yes.
16 A. No. I was to room with Jane Doe No. 16 Q. When was the last time you communicated
17 7 when I lived in Her roommate was supposed to 17 with her?
18 mow or it was like a lease thing. And I was going to 18 A. I don't know. It's been a while.
19 take over her lease, pay her rent just for the summer. 19 Q. Which means six months, more or less?
20 And she decided not to go, so I ended up getting a 20 A. Maybe like a month, two months.
21 different place in the same apartment complex. 21 Q: Okay. And is she still in the area?
22 Q. Did there sk . What period of time 22 A. I haven't spoken to her in a while. Maybe. I
23 were you up in 23 giess. Last time I talked to her she was.
24 A. In the summer of my junior year is when I 24. Q. Do you speak with her on the phone or do
25 lived there. 25 you see her in person?
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Page 509 Page 511
1 A. I saw her in person. 1 A. Not that I can recall. I don't remember what
2 Q. Where did you see her? 2 our conversation was.
3 A. We went out. 3 Q. Did she tell you anything about what to
4 Q. You and her or others? 4 expect or what was going to go on?
5 A. Me, her, and Jane Doe No. 7. Jane Doe No. 7 5 A. No. Like I said, I don't remember our
6 was in town for the weekend. 6 conversation so I don't know.
7 Q. And where did you-all go? 7 Q. Your best recollection is you believe
A. Dr. Feelgoods. 8 though on the first occasion that you went with her
9 Q. And this was about a month ago? 9 that she had been there before?
10 A. No. This was more than a couple of months 10 A. No. I don't know —
11 ago. 11 Q. Okay.
12 Q. Okay. So, you said you thought you saw 12 A. —if she had. •
13 her about a month ago. Is that a different time? 13 Q. Do you know fora fact that you went on at
14 A. No. I think I like communicated with her on 14 least on one occasion with her?
15 her Facebook or something like that like a month ago. 15 A. No. Yeah. I know that I have gone there with
16 Q. Okay. All right. So, how long ago was it 16 her, yeah.
17 that you-all got together in person? 17 Q. Did you go with her to Mr. Epstein's on
18 A. Like a couple, like several months ago. 18 more than one occasion?
19 Q. Sometime in '09? 19 A. Probably.
20 A. It might have been '09, beginning of '010. 1 20 Q. Did you have an estimate of bow many times
21 don't know. It's been a while. I don't remember. 21 you went with her?
22. Q. Did, did you and she go together to Jeff 22 A. I don't — maybe three to five times. I don't
23 Epstein's on any occasion? 23 know.
24 A. Yeah. 24 Q. And was it all a concentrated time frame,
25 Q. Were you the one that originally took her 25 or was it over a long period of time?
Page 510 Page 512
1 there? 1 A. No. I am guessing that's over a long period
2 A. I don't think so. I don't remember. 2 of time.
3 Q. There were times that — 3 Q. And what comments, if any, did she make to
4 A. I think the only person I brought was 4 you about going to Mr. Epstein's if she made any?
5 Q. On the occasions that you went there A. I don't know if she made any.
6 together, did you and she have any discussions of 6 Q. When you guys would go together, would you
7 what was, what you were going to do when you got 7 leave together?
8 there? 8 A. Yeah, I'm sure.
9 A. No, not that I can recall. Q. So, if you typically went together, you
10 Q. Did you tell her anything about -- by the 10 would go in the same car?
11 time you went -- strike that. 11 A. Yeah.
12 When you went with her for the first time 12 Q. And at that time were one of you driving?
13 to Mr. Epstein's, had she already been there? 13 A. I'm sure one of us wens.
14 A. I don't know. 14 Q. Okay. Did, did she ever make any
15 Q. Did she indicate to you that she had? 15 statements at all to you about what she did with
16 A. I don't know. I don't remember whenever the :6 Mr. Epstein?
17 first time we went. I think she brought me there the 17 A. No.
18 second time I went. I don't know if she had already 18 Q. Did you tell, ever tell her anything about
19 gone. I 'mow that I had already been there and I think 19 it?
20 she knew that I already had been there. So I don't 20 A. No, not that I remember, no.
21 remember what the conversation would have been about. 21 Q. Okay. If you went to, if you went to
22 Q. Well, did you — did she ask you anything 22 Mr. Epstein's together with her, did both of you go
23 about what to expect or — 23 up and perform massages on.Mr. Epstein together or
24 A. No. 24 did just one of you go?
25 Q. What had — 25 A. No, no just one.
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1 Q. Okay. And, and when you went there with 1 Q. identification card?
2 her which of you was performing the massage on 2 A. Yeah.
3 Mr. Epstein? 3 Q. It wasn't a driver's license?
4 A. I don't know. Either me or her. 4 A. No.
5 Q. Okay. So, it wasn't always — 5 Q. And so, it had her picture?
6 A. I know it was never, never was both of us. 6 A. And her information.
7 So, ifs got to be one or the other. 7 Q. So you, what you really had was her
8 Q. Okay. All right. But it wasn't always if 8 identification card?
9 you went with her, she didn't massage and you 9. A. Yeah.
10 didn't, or you did the massage and she didn't? 10 Q. And you would use that?
11 A. Yeah. 11 A. Where, yeah, certain places, Yeah-
12 Q. Sometimes it was one and sometimes it was 12 Q. Okay. Well, what kind of places would you
13 another? 13 use it?
14 A. Yeah. 14 A. Places that you needed to be 18 to get in.
15 Q. Okay. Any particular reason why the two 15 Q. Okay. Do you know whether or not Jane Doe
16 of you would go there together? 16 No.3 had a fake ID?
17 A. No. We were friends. I didn't have a vehicle 17 A. No, I don't.
18 for a while. That could have been the reason. I don't 18 Q. Did you ever do any drugs with Jane Doe
19 know. Plus we were friends. 19 No. 3?
20 Q. Is, is she older than you? 20 A. Not that I — I mean maybe drinking, like when
21 A. No, she's younger than me. 21 we went out to parties. I don't know.
22 Q. Okay. So, if you didn't — oh, when you 22 Q. Did you ever know her to do drugs?
23 said you didn't have a vehicle, you just meant that 23 A. No.
24 you didn't have a car? 24 Q. Okay. So, you didn't do them with her and
25 A. Yeah. 25 you didn't know of any drugs that she did?
Page 514 Page 516
1 Q. You, you had a license to drive though? 1 A. Yeah. Like back then whenever I was
2 A. Maybe. I might have. lam sure I would have. 2 experimenting, going through my high school stage in
3 Q Okay. 3 life, I think I maybe smoked pot with her.
4 A. I !mow I waited a while to get my license, so 4 Q. Do you 'mow — was she a person, did she
5 maybe I didn't. 5 have boyfriends and et cetera when you were taking
6 Q. Okay. Well, if you didn't have a license, 6 her to Mr., or when you went with her to
7 then she must have had the license, right? 7 Mr. Epstein's?
8 A. Yeah. Or maybe I did have a license; I just 8 A. I don't remember. I don't know.
9 didn't have a vehicle. I don't know. 9 Q. Do you know what her reputation was for
10 Q. I think at the last deposition we talked a 10 sexual activity?
11 little bit about a fake ID. Did you have a fake ID 11 A. No.
12 at some point? 12 Q. Do you know whether or not she was
13 A- Yeah. 13 sexually active with people when you took her to
14 Q. Do you recall what e it said you were? 14 Mr. Epstein's?
15 A. I had ID, ID, which said I was 15 A. No.
16 18, or, yeah. 16 Q. Do you know whether or not she ever had
17 Q. And do, do you remember when you got it? 17 terminated any pregnancies?
18 A. Probably when I was hanging out with her my 18 A. No.
19 senior yew in high school when I met her, junior year. 19 Q. Do you know whether or not she's ever gone
20 Q. And what kind of ID was it? Was it a fake 20 to a psychologist or a psychiatrist?
21 driver's license? 21 A. No.
22 A. No. It was 'rust her. a 'chat of her. It's 22 Q. Did you ever discuss with her any lawsuit
23 her, her 23 that she has?
24 Q. Okay. So, it was a, just a generic — 24 A. No.
25 A. Picture of her. 25 O. Do You know her, who, who her bo 'ends
17 (Pages 513 to 516)
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1 were? 1 11:09 a.m.
2 A. No. 2 (A brief recess was held.)
3 Q. Did you and she ever have the same 3 THE'S/IDEOGRAPH:ER: We're back on the
4 boyfriend? Not at the same time but did you ever 4 record at 11:17 a.m.
5 date the same guy? 5 BY MR. LUTHER:
6 A. No. i her than the trip down to
7 Q. Do you know whether or not she's ever been ve you, what other vacations have you
8 arrested? 8 taken in the last three
9 A. No. •;, I have go twice with
10 Q. Do you know if she's ever been married? 0 to
11
12
13
A. Yeah.
Q. Okay. And was she married?
A. !just heard about it, not through her. I
11
12
13
Q tiare
with
That's it.
them other occasions that you go
tat's been within the last year and a
I
14 just — I don't know. I don't know anything about it. 14 half?
15 I just heard that she had been or maybe she is. I don't 15 A. Yeah.
16 know. 16 Q. And what, what are those trips typically
17 Okay. What was the name of your MEI 17 consist of, weekend trips or —
18 1? 18 A. Yeah, weekend trips mostly.
19
20
A. '1111.
Q. Is he still in the area?
19
20
Q. You got a boat when you go down there?
A. Yeah. It's his dad's. We go with his dad and
21 A. No. 21 his dad's neighbors, whoever is taking their boat down.
22 Q. Where is he? 22 And how about, what was it
23 A. I don't bum.
24 Q. When was the last time you knew where he
25 was?
Page 518 Page 520
1 A. I head he was moving from 1 A. Yeah.
2 was the last I heard whenever he moved from 2 Q. Long way to go for a football gaze.
3 Q. But you didn't know where? 3 A. Yap.
4 A. No. 4 Q. Some tickets?
5 . o where? And who was your 5 A. Yeah, MIllgot tickets.
6 at 6 Q. By happenstance or is he, is he a season
7 A. 7 ticket holder for one of those teams?
8 Q. I take it it wasn't 8 A. No. He Just got tickets for the game.
9 A. No. 9 Q. Did you-all go to football games?
10 Q. Does have a last name? 10 A. We went to that football game.
11 A. Yeah. I am drawing a blank what his name — I 11 Q. Go to Dolphin games or anything?
12 it. 12 A. No. We haven't been to a Dolphin game.
13 Q. It was just kind of a one-tint deal?
■ 14 A. Yeah.
15 Q. What's your best shot at pronouncing it? 15 Q. Okay. And how about —
16 A. I don't know. I don't know what it is. 16 A. ! like the Stealers.
17 Q. Is—do youknowwher • 17 Q. You do?
18 A. I mean, l am gu 18 A.
19 Q. But, but he is When you went toll....
20
21
A. No.
Q. Do you know 21
Wilt when was that?
A. la the stunner.
22 A. No. 22 Q. This last summer?
23 MR. LUTTIER: Okay. I need to take a 23 A. Yeah. I think we went last summer, yeah.
24 quick break. 24 Q. When you say with your family, is that you
25 THE VIDEOGRAPHER: Going offthe record at 25 and ourgarents?
18 (Pages 517 to 520)
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1 A. Yeah.
2 Q. Was there anything different about going
3 to Mr. Epstein's after you were 18 than going to
4 Mr. Epstein before you were 18?
5 A. No.
1 IV =M 6 MR- MERMELSTEIN: Objection to form
Q. Your parents, your dad I think mentioned 7 BY MR. LUTHER:
9 something about you used to go toll. every 8 Q. And you acknowledge certainly that your
9 spring? 9 decision to go to his house after you were 18 was of
10 A. No. 10 your own free will?
11 Q. Did you ever go i 11 A. Yeah.
12 A Oh, yeah it was my junior year in 12 Q. And you went because be was good to you
13 college I went t for spring break. 13 and you enjoyed it?
14 Q. Okay. And did you go with a group of kids 14 MR. MERMELSTEIN: Objection to form.
15 from school? 15 THE WITNESS: Because I had been going
16 A. Yes. 16 there since 1 MS 15 years old.
17 Q. Did you take one of those cruises? 17 BY MR. LUTT1ER:
18 A No. 18 Q. Okay.
19 Q. Was it an organized spring break deal? 19 A. It ldnd of became like a nomml --
20 A. Yes. 20 Q. But at 18 you're an adult, right?
21 Q. Do you remember what it was called? 21 A. Yeah. But I was going there beforehand, so
22 A. What, was called what? 22 it's kind of like, you know, kept doing the same thing
23 Q. They usually have some name for those 23 that I was doing the day before 1 was 17.
24 things that they put together down there during 24 Q. And I think you told me in the last
25 spring break. 25 deposition that you thought Mr. Epstein treated you
Page 522 Page 524
1
2
3
„l id
A. No.
you stay — where did you stay in
1
2
3
well?
A. Yeah.
Q. Do you, do you believe Mr. Epstein ever
4 A. At an all-inclusive hotel. 4 did anything to intentionally harm you in any way?
S Q. Okay. It was one of these spring break 5 MR. MERMELSTEIN: Object to the fonn. And
6 weekend deals? 6 also to the fact that these were questions that
7 A. No, it wasn't like that. It wasn't part of 7 were asked —
8 any pa • ... .. . • ... . I was something that 8 MR. LUTT/ER: I don't think that was.
9 one of her dad organized for 9 MR. NEERMELSIEIN: — repeatedly at the
10 us. So, there was nothing, there is no like an event 10 prior deposition.
11 planner or, just a dad. 11. MR. LUMER: You can go ahead and answer.
12 Q. What kind of willies, entertainment 12 THE WITNESS: What was your question?
13 type stuff do you and = do? 13 BY MR. LUTTIER:
14 A. I don't know. We go out on the boat. We go 14 Q. Do you believe that Mr. Epstein
15 Kayaking. We've been biking. We go hang out with some 15 intentionally did anything to harm you?
16 friends at local bars. Hang out at the house a lot and 16 A. No.
17 have friends over. 17 Q. I want to ask you about the damages that
18 Q. Now, you, you turned 18 sometime I think 18 you claim you've suffered. Would it be a fair
19 right after you graduated from high school? 19 statement to say that the damage that you suffered
20 A. Yes. 20 really is the fact that it came to light that you
21 Q. You had birthday if I remember 21 had been going to Mr. Epstein's?
22 correctly? 22 MR. MERMELSTEIN: Object to fonn.
23 ' A. Yes. 23 THE WITNESS: Wait. What did you mean
24 Q. So, there was a period of time that you 24 like came to light?
25 continued to go to Mr. Epstein's after you were 18? 25
19 (Pages 521 to 524)
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1 BY MR. LUTTIER: 1 MR. MERMELSTEIN: Objection to form.
2 Q. Well, it became known. People knew that 2 111E WITNESS: Yeah.
3 you went there and you were really embarrassed about 3 BY MR. LUTTTER:
4 that fact? 4 Q. And if nobody ever knew about this, you
5 A. Yeah. I am sure that's one of many of the 5 wouldn't have had any of this embarrassment or
6 reasons. 6 having people know that the police were coming
Q. Okay. Other than being embarrassed about 7 around talking to you or anything hie that, right.
8 it, and the embarrassment was because it became 8 A. Yeahagaill at the same time like if I,
9 known to others what you did? 9 like meeting and being in this serious
10 A. No. Because I am sure some people put 10 relationship with him,like, how could, you know,
11 two-and-two together but it was not like my name was out 11 would start being lice what am I doing, you know what I
12 there in the paper. So, it's not like oh, Jane Doe 12 mean? Like having, like trying to get hie got to go to
13 No. 4, I 'mow who she is. No. 13 college, get into like a serious relationship with
14 People put the general aspect but I mean 14 somebody I love. And I want to have marriage. I want
15 at the time that it was going on, my parents didn't 15 to have all that. How would1still be going to
16 know, you know, they didn't know. 16 Jeffrey. I wouldn't be going to Jeffrey's still.
17 It wasn't a general oflike people finding 17 And looking back I would step ha& from
18 out. It was just like everything that was going on, 18 that and be like, what was I doing? Luce looking,
19 the whole situation with the cops coming and like 19 looking back on it and be like I was 15 years old.
20 harassing, like coming, not knowing what was going 20 That is sidc. I would look back on the whole
21 to happen to me, if I was going to go to jail or 21 situation and it would disturb me.
22 what was going to — 22 Q. Okay. So, help me to understand this.
23 And at the time I was, you know, like when 23 A. Not just because the cops found out about it
24 I look back on it, it was really sick, like I was 24 and now I went through some emotional thing.
25 hike on Jeffrey side. I didn't, I was, told Jeffrey 25 Regardless. I would have looked back I would have
Page 526 Page 528
1 about the situation. 1 graduated from college, I would want to build something
2 You know, like, I can't believe like how 2 for myself. So, I wouldn't go there anymore. And when
3 my mind was so, like, like I feel he like 3 I would stop going there, I would look at it and I would
4 manipulated me and formed me into something that, 4 be like that is disgusting and it would emotionally
5 you Imow,1 look back on it now and I'm just like 5 affect me that way.
6 that's disgusting. And that's why I am emotionally 6 Q. Other than you saying that it upsets you,
7 upset is like how I, you know, my parents raised me 7 okay, what, how else have you been damaged, if
8 to be this good person and how I like molded into 8 anything? Maybe that's the only thing, but is there
9 something. 9 any other damage other than it's emotionally
10 I don't know. It's just, it's disgusting. 10 upsetting to you?
1/ ft =Ices me really upset. It makes me get really 11 THE WITNESS: Yeah, like me and my —
12 emotional. And it's not just about people finding 12 MR. MERMELSTEDI: Object to the form.
13 out. 13 THE WITNESS: Emotionally?
14 Q. Your feelings about that are the same for 14 MIL LUITIER: Let me, let me rephrase my
15 the times that you went to him after you were 18 as 15 question.
16 they were from the time you went to him before you 16 THE WITNESS: Wait
17 were 18? 17 BY MR. LUTTIER•
18 A. Yeah. 18 Q. Other than you saying it's emotionally
19 Q. And you, you — do you agree that you have 19 upsetting to you to look back at what you did, have
20 responsibility for your own actions? 20 you suffered any other damage —
21 A. Yeah. 21 A. Yeah.
22 Q. Okay. So, you would agree certainly after 22 Q. — as a result of going to Mr. Epstein?
23 you were 18 years of age what the consequences were 23 If so, what?
24 or the consequences that were as a result of the 24 A. Whenever, I couldn't sleep at night thinking
25 actions you had decided to take? 25 about it. I would have flashbacks about like what
20 (Pages 525 to 528)
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Page 529 Page 531
1 happened. When I saw him in the hallway whenever he 1 problems sleeping now or is this something that
2 showed up for my deposition, seeing his face, giving me 2 happened in the past?
3 a smirk. I couldn't even drive in my car every single 3 A. i mean, it was a lot more frequent, frequent
4 time I would see like an old person's face, I would pop. 4 whenever everything was happening. But 1mean in
5 His head would be in my face. S certain situations, like, yeah, !get stressed out at
6 I would go out me and my boyfriend got in 6 nighttime and I will, I will have a problem sleeping.
7 arguments about it because I couldn't be myself. I 7 Like I can't, I will sit here and like analyze
8 would be normal, happy one minute and emotional and 8 everything.
9 sad, depressed the next minute. I had so much built 9 Q. Well --
10 anger inside ofme that whenever I would drink, I 10 A. And at nighttime instead of going to sleep, I
11 would like unleash all this built-up anger inside 11 will just sit there and think.
12 me. A lot of things. 12 Q. Well, when you typically lay down and go
13 Q. Okay. What -- 13 to sleep, do you sleep within an hour?
14 A. You know, !couldn't, like u tat w and 14 A. No. Normally I used to be able to go to sleep
I not even including being — 15 within like, l would put my head down and in 10 minutes
MI wondering, oh, are the cops going to come, is the 16 then I would be sleeping.
17 FBI going to come, like having that pressure, like not 17 Q. Well, how long does it take you now?
18 'mowing, of fear. 18 A. I don't know. Not every single night but
19 Q. Okay. Any other ways you have been 19 every once in a while.
20 damaged? 20 Q. What degree —
21 A. Yeah. I feel like, you know, like I was 15 21 A. Maybe like one or two hours.
22 years old when all that was happeningg. You know, like 22 Q. With what degree of frequency?
23 an old man doing that to like a younger girl, don't you 23 A. I deal know. Maybe like Nike a month.
24 think like her child adolescence, like, kind of lice get 24 Q. So, twice a month it will take you an hour
25 ruined, you know. 25 or so to get to sleep?
Page 530 Page 532
1 And him giving me that money, like, ifs 1
2 probably why my parents argued so much when I was 2
3 young. My parents are sitting here trying to raise
4 me and trying to like put me into a direction, and
5 I'm sitting here getting $300 from this old man.
6 So, to me like my dad is trying to teach me how to
7 like spend my money and how to like be a right
8 person, and I am sitting here, he is like completely
9 demolishing everything that my parents are like
10 teaching me because he, he is giving me money and I
11 am running around, like, not, like an idiot 11 Q. Okay. Now, you said flashbacks. You said
12 15-year-old person not knowing about, anything about 12 that when you see older people, you see
13 life. 13 Mr. Epstein's face?
14 Q. Any other way you have been damaged? 14 A. Like whenever, like right before my deposition
15 A. No. I think I pretty much am covering a lot. 15 or right before my deposition my first time I was
16 Q. Okay. Did you incur any what we would 16 supposed to come here. I saw Mr. Epstein in the
17 call economic damage of any kind? 17 hallway. Getting into my vehicle and like seeing his
18 A. What do you mean economic? 18 face and like giving me that Nazi smirk that he gave me.
19 Q. Loss of dollars? 19 When i would get in my car and drive, like I didn't even
20 A. No. 20 want to look up because I kept visualizing his face.
21 Q. You paid for a medical expense or 21 Q. Okay. So, that was one time you saw him?
22 something like that? 22 A. Huh?
23 A. No. 23 Q. That was one time you saw him here?
24 Q. Let me go back and break this down. First 24 A. Yeah.
25 of all said you couldn't sleep. Do you have 25 Q. Okay. Now, but you also said something
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Page 533 Page 535
about if you saw older people you would see his face 1 A. Nothing. Like I would get like I didn't
or something to that effect? 2 even want to, like, lookup. I didn't want to, like,
3 A. No. Like if I saw like an older, like, man or 3 look at anything. I would just want to, like, just like
4 something like that resembled him, like sometimes I got 4 get in my own like little, mind frame I guess, and just
5 all, like, I would freak out like, oh, God is that him. 5• sit there and like, just, like, sit there and think, you
Q. Don't you see older men every day? 6 know.
A. No, I don't. 7 Q. Were you driving a car when you had this
Q. I mean, you're out and about, aren't you, 8 flashback?
you're in your car; you're driving around? 9 A. I have, yeah.
10 A. Yeah. But like in this area when I am in Palm 10 Q. Well, what do you do when you're driving a
11 Bea ing, and I see an older person, like when 11 car and you have this flashback?
12 I am like maybe sometimes it will cross my 12 A Nothing. I guess I kind of, like, zoom in and
13 mind but I won't freak out about it, but I will be 13 focus.
14 hie — it will, it will cross my mind. • 14 Q. Okay. So, you don't have to pull over to
15 Q. So, it only happens when you are in Palm 15 the side of the road, for example?
16 Beach? 16 A. (Witness shakes head.)
17 A. It happens more frequently when I am in Palm 17 Q. All right. Can you better describe to me
18 Beach. 18 what, what's ever happened when you had these
19 Q. How often are you in Palm Beach? 19 flashbacks that you say you maybe have four times a
20 A. I am Moften lately. I have been 20 year?
21. hanging out 21 A. Nothing. I just don't like being out I
22 Q. 22 don't like being, like, in a situation. I just like
23 A. 23 want to like, if I am out somewhere, like, I will take
24 Q. If you are up where you live 24 myself out of the situation, like step outside and maybe
25 with your boyfriend — 25 like just sit there and like analyze. Maybe I will go
Page 534 Page 536
1 A. Yeah. 1 to my car and like sit down and just like —
2 Q. — and you go in the grocery store, let's 2 Q. And you say —
3 say you go into Publix and you're going to see all 3 A. — be by myself
4 kinds of older men? 4 Q. And you say this happens four times a
S A. I am saying somebody that resembles 5 year?
6 Mr. Epstein not just somebody that has dark black hair 6 A. No. It's happened, yeah.
7 that is fat, no, of course that's not going to remind me 7 Q. Now you're --
8 of Mr. Epstein because Mr. Epstein does not resemble 8 A. You said analyze or you said give me your best
9 those assets. 9 estimate of how many times this happened. I'm just
10 Q. So, this only happens if you see someone 10 saying It's probably happened like four times.
11 that looks like Mr. Epstein? 11 Q. Oh, four times since you last, since '05?
12 A. Yeah. 12 A. No, you said estimate. I don't know how many
13 Q. Well, with what degree of frequency does 13 times this happened. I'm just saying like probably four
14 that happen? 14
15 A. I don't know. I mean, not often, but —
16 Q. Maybe once a year, twice a year?
17 MR. MERMELSTEIN: Objection to form.
18 THE WITNESS: I don't know. I know after,
19 it's probably happened Ince four times a year
20 but I know after that situation after I saw him
21 that whole week I was having like flashbacks of
22 seeing him probably like twice a day. 22 Q. Has it ever happened to you when you've
23 BY MR. LUTHER: 23 been with your boyfriend out?
24 Q. Well, what would happen when you had these 24 A. No. I have gotten paranoid before around him.
25 flashbacks? 25 Q. But you never had one of these flashbacks
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Page 537 Page 539
1 when you were out with your boyfriend? 1 A. Yeah. It's happened one time when I was in
2 A. No. 2 Publix.
3 Q. Have you ever had one when you're out with 3 Q. So, you can recall a specific incident?
4 your parents? 4 A. Yeah.
5 A. No. 5 Q. All right. I want to talk about that
6 . Have u ever had one when you were out 6 specific incident. Approximately when did it
7 with 7 happen?
B A. No. 8 A. I don't remember.
Q. Have you ever had one when you were out 9 Q. The year 2008?
10 with anybody else or does it only happen when you've10 A. I don't remember when it happened.
11 been out alone? 11 g 2009?
12 A. This happens, like, when Pm out alone, like, 12 A. I don't have a date.
13 when I'm like going to the mall or something like by13 Q. AU right. What Publix were you in?
14 14
myself. I don't recall being with anybody when I have A. I don't remember.
15 had one of these flashbacks, no. Or when I was in my15 Q. Okay. Do you remember what you were doing
16 car leaSH: here by myself, I have told 16
I think I in Publix?
17 told oh, yeah, I have told him, li e, w I felt
17 A. Shopping for food.
18 like after I saw him here. But I've never been with 18 Q. Okay. So, had you been in Publix for some
19 19 period of time before this happened?
20 Okay. Other then the incident where you 20 A. I don't, I don't remember how long I was in
21 saw Mr. Epstein in this building before your depo, 21 there or how long I was out of there. I just remember
22 can you tell me the last time you had one of these 22 the incident.
23 flashbacks that you've described as occurring maybe 23 Q. Okay. Were you, were you looking in one
24 four times a year? 24 of the aisles in Publix?
25 A. Before my deposition. I don't remember when. 25 A. Yeah.
Page 538 Page 540
1 Q. Was it like six months before your depo 1 Q. With a grocery cart?
2 before you can recall it? 2 A. Yeah.
3 MR. MERMELSTEIN: Objection to form. 3 Q. Alone?
4 174E WITLESS: Yeah, probably six months. 4 A. Yeah.
5 BY MR. LUTTIER: 5 Q. Okay. All right. And then you saw
6 Q. Okay. Describe the incident that 6 somebody that you thought looked like Mr. Epstein?
7 happened. 7 A. Yeah.
8 A. Like I said I was either in Publix or I mean B Q. Okay. And was he walking by or what?
9 it's happened more than once. I don't kanevaber in what 9 A. Yeah, he was walldng by.
10 incident but — 10 Q. Okay. And so tell me now what exactly you
11 Q. Well, when? 11 did.
12 A. — !was at the mall or I was either in Publix 12 A. I ran around the other aisle.
13 and I thought I saw him and I had to like, like, 'just 13 Q. When you say ran, you don't mean you
14 started getting really emotional. I would glance if I 14 literally ran, do you?
15 saw him and like when I realized it wasn't him, I would 15 A. No.
16 just, I walked around another way and just like 16 Q. So, you pushed your cart around?
17 analyzed, sat there like for a minute just like being in 17 A. Yeah, I sped walked. I didn't have a cart. I
18 a situation but not really being there like just, like 18 had one of those little green things.
19 by myself kind of but, you know, like I am in a room. 19 Q. So you walked —
20 Like if I saw him, I would walk away and like just, like 20 A. I like walked around the corner.
21 I don't know how to explain it, lace be there but not 21 Q. You walked out of the aisle you were in
22 really there, just stand there and being like, wow. 22 into the next aisle?
23 Q. Are you saying that you recall 23 A. Yeah.
24 specifically an incident where one of these 24 Q. Okay. What happened next if anything?
25 flashbacks happened while you were in Publix? 25 A. Nothinu. I was like, didn't want to walk into
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1 that aisle. I was freaking out, like, oh, my gosh, did 1 do it as supposed to you being physically unable to
2 I really just see him, and I'm like, no. And then I 2 do?
like sat there for a minute and like, like was in my own 3 A. Yeah, I wasn't — what do you mean?
4 little, like, world. And then I just got out of there. 4 Q. All right. Did you have a list for
5 I couldn't even finish shopping because i was just so 5 example of what you needed?
6 lice, just like couldn't even like think of what I 6 A. No. I just had a list in my head.
7 wanted to get next. Like I just I had things in my cart 7 Q. Okay. All right. But nothing prevented
3 and i just left. 8 you from just kind of walking up and down the aisles
9 Q. Did you go checkout? 9 and picking up whatever you wanted?
10 A. Yeah. 10 A. No.
11 Q. All right. So, you went and checked out, 11 Q. All right. So, when you got in your car,
12 paid and left? 12 you drove home?
13 A. Yeah. 13 A. Yeah.
14 Q. So, when you walked around and you said 14 Q. You were able to drive home?
15 you stood there for a minute and gathered your 15 A. Yeah.
16 thoughts? 16 Q. Okay. All right. Now, going in reverse
17 A. Yeah, I think like — 17 order, so, now we had one time was when you saw
18 Q. Did you, did you cry? 18 Mr. Epstein here. One time was this incident in
19 A. No. I think i was just kind of like in shock. 19 Publix.
20 Q. Did anything else physically happen to 20 When was the time prior to that that you
21 you? 21 can recall any of this happening?
22 22 A. At the mall.
23 23 Q.
24 A.
25 Q. And what, what year are we talking about
Page 542 Page 544
1 Q. All right. So, this whole incident five 1 Dow?
2 minutes? 2 A. I don't know.
3 A. Probably. 3 Q. '07?
4 Q. Okay. 4 A. Probably I don't know when it was.
5 A. Ten minutes. 5 Probably sometime in '07. I don't know.
6 Q. When is the going — 6 Q. Okay. So, were you there with anybody?
7 A. But then afterwards, after I left and not 7 A. No.
8 being able to get food that i went there for and not 8 Q. Okay. You were there but were you in a
9 even — Ike being at Publix and after the situation 9 particular store or just kind of --
10 happened, I didn't, couldn't even think of what else to 10 A. No, just walking around.
11 get. Like i was just like, like my mind was just kind 11 Q. Okay. Tell me what happened.
12 of like, like a brain fart. Like I had to get out of 12 A. Nothing. I saw, I thought I saw somebody that
13 there. 13 looked like him and it wasn't him so I just continued my
14 And then like the whole rido home, i am 14 shopping.
15 like sifting there thinking like this is so 15 Q. All right. So, on that occasion seeing
16 pathetic, you just left Publix, you didn't even get 16 somebody that you thought was him —
17 all the things you needed to get, like, being at 17 A. And I realized that it wasn't.
18 like, you know, like, sitting in the dorm or 18 Q. Immediately realized it wasn't him?
19 wherever I was at like just being there. 19 A. Yeah. I thought it was him and then realized
20 Q. Did you try to finish up? Did you walk, 20 it wasn't
21 • just walk up and down the aisles and look for 21 Q. Okay. So, you just went in and did your
22 whatever food you wanted? 22 stuff that day?
23 A. No. I didn't even want to. !just wanted to 23 A. Yeah. But I felt like afterwards it like made
24 get out of there. 24 me sit there and think of all the things that went on,
25 Q. So, it was a matter of you not wanting to 25 you know, like I'm not saying, oh, i just saw Jeffrey
•
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Epstein, but it brings back memories of what happened 1 alcoholic and that's not something that I want
2 whenever I, whenever I see, something like a familiar' 2 in my life anymore, and that's why I got out of
3 face and I, like, visualize that it's him, like, it 3 it So, if anything I'm happy that I am not .
4 brings back memories that 1 don't want to remember. 4 him anymore and —
5 Q. Okay. But it didn't, on that particular MR. LUTHER: Okay. So --
6 occasion it didn't interfere with whatever you were 6 THE WITNESS: And I got out. It made me a
7 doing at the mall? 7 stronger person being like, wow, you're not
8 A. No. 8 with that person anymore and made me, you know,
9 Q. Would you agree with me that in your life 9 made me wiser with my decisions from then on.
10 there have been various unpleasant things that have 10 BY MR. LUTHER:
11 happened to you? 11 Q. Okay. a people that you
12 A. Yeah. 12 think look nice does it cause you
13 Q. And would you agree with me that thinking 13 any problem?
14 about those unpleasant things causes you this same 14 A. No.
15 emotional distress that you've described? 15 Q. All right. So, you're not with Jeffrey
16 A. Yeah. Certain things bothered me but — 16 Epstein anymore either, are you?
17 MR. MERMELSTEIN: Form. 17 A. No.
18 THE WITNESS: — I've, I've like worked it 18 Q. So, tell me what, why, knowing that you're
19 out with myself. 19 not with Jeffrey Epstein doesn't make you also
20 BY MR. LUTHER: 20 stronger now?
2/ . Well for example, this boyfriend that you 21 MR. MERMELSTEIN: Objection to form.
22 had, 22 THE WITNESS: qaajia it's still something
23 A. Yeah. 23 that bothers me. Like was something
24 Q. — he did some pretty bad things to you, 24 that like I choose, I loved, I met him, I like,
25 didn't he? 25 wanted to met him. I wanted to get to know
Page 546 Page 548
1 A. Uh-huh. him, like pursue love.
2 Q. Thinking about those causes you to be 2 Like Jeffrey was something that like was
3 upset, doesn't it? 3 presented to me and like I felt like he melted
4 MR. MERMELSTEIN: Objection to form. 4 me and manipulated me. And being manipulated
5 THE WITNESS: Yeah. I look back on It and 5 it still bothers me that, that I allowed that
6 Fm sure anybody would probably be upset. But 6 to happen.
7 I mean, that is something that has happened in So, I still get like upset about the whole
8 the past, and I don't — lam in a good 8 Jeffrey Epstein thing. It's disgusting. It's
9 relationship now, and I was in a good 9 disturbing. lean% believe what he has done
10 relationship afterwards. I mean, I don't look 10 to several girls about it, and he's not gotten
11 at it igau. :.ati I'm like, °b, nen, I wish I was 11 a good punishment for it.
2 with He used to be mean to me, no. 12 MR. LUTHER: Well, your, your belief —
13 BY MR. LUTTIER: 13 MR. MERMELSTEIN: Stick to the question
14 Q. No. What I am referring to is the man was 14 that's asked.
15 physically violent towards you? 15 BY MR. LUTTIER:
16 A. Yes. 16 Q. Your belief that, about those things and
17 Q. He called you vile names? 17 your feelings about that only came about after you
18 A. Yeah. That's why I got out of that situation. 18 filed this lawsuit; isn't that right?
19 Q. Okay. So, when you think back about those 19 A. I don't remember.
20 incidences when he was beating you up, when he was 20 Q. Well, you didn't have those beliefs before
21 spitting on you, when he was calling you vile names, 21 you filed this lawsuit, did you?
22 that causes you to be upset too, doesn't it? 22 A. I was, I am sure like sometirnes it crossed my
23 MR. MERMELSTEIN: Objection to form. 23 mind, but I don't think I verbally expressed it to
24 THE WITNESS: No, because I am not with 24 anybody.
25 him any more and I realize be was just an 25 In fact, after you were 18 while you were
25 (Pages 545 to 548)
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1 an adult you had expressed to several people that 1 Jeffrey Epstein ever did to you?
2 you didn't think that there was anything wrong with 2 MR. MERMBLSTEiN: Objection to form.
3 what Mr. Epstein had done? 3 THE WITNESS: No.
4 A. Yeah. At that time I didn't. I thought it 4 MR. LUITTER: Okay. Certainly
5 was — 5 Mr. Epstein —
6 Q Okay. 6 THE WITNESS: I think it's about even.
7 A. -- a normal thing to do. I was going there 7 BY MR. LUTTIER:
8 with all my friends. I even called him up and told him 8 Q. And, and what did to you
9 that the police were investigating other girls. 9 doesn't affect you at all today, does it?
10 Q. And was 10 A. No:
11 A. I was Ince on his side. I was,Ididn't know. 11 Q. Okay. Makes you stronger, tight?
12 That's how manipulated and brainwashed I was and now I 12 A. No. It made me, sorry. It made me realize
13 look beck on it and I think it's like, wow, disgusting. 13 what I didn't want. I mean, it wasn't, it wasn't
14 And I regret saying what I said. And ill, if i knew 14 healthy.
15 then what I knew now, I would have never said that. 15 Q. Okay. You, you -- let's see. We had, we
16 Q. Well, you only, you only know now what you 16 had the incident here. We had Publix. We were
17 know because you met with — 17 going back in time. We had the mall. When was the
18 A. No. 18 time prior to that that you ever had one of those
19 Q. Dr. isn't that right? 19 flashbacks?
20 MR. MERMELSTEiN: Objection to form. 20 A. I'm not sure whenever those time frames were.
21 THE WITNESS: No. 21 i don't want you categorizing it that's whenever that
22 BY MR. 22 happened and then going past. I just know that those
23 Q. Or was
was' 23 situations happened.
24 A. No. 24 Q. Okay. I want to know when was the time
25 Q. -- front Victim Services? 25 prior to you in the umll, that incident?
Page 550 Page 552
1 A. No. 1 A. I think whenever we were out one night I was
2 Q. When did you get this sudden come-over you 2 with some, some friends. I don't remember who.
that what you had done since you were 18 years of 3 Q. What year?
1
/2 age and, and your statements about Mr. Epstein 4 A. Huh?
suddenly were all wrong and -- 5 Q. What year?
A. Well, i always thought it was like really 6 A. I don't remember.
7 weird that everybody was going over there. But after a 7 Q. Where were you when this, this incident
8 while it just kind of became like normal. So, whenever 8 happened?
9 i was hearing about things going on about police 9 A. Iva
10 investigating girls and stuff like that, I think one 10 Q. Were you in college, out of college?
11 girl was 13 years old, I was disturbed about it. 11 A. Yeah, I was in college.
12 Q. Well, you, you don't know anybody that was 12 Q. Freshman, sophomore?
13 13 years old? 13 A. I don't remember what year it was.
14 A. No, I heard. 14 Q. Okay. Tell me what happened.
15 Q. That's just a rumor. 15 A. No, I was out with friends and I thought that
16 A. Alter hearing, i wouldn't put it past me 16 they didn't know about the situation. So, I thought I
17 because i know there was a lot girls that went there. I 17 saw his face and I just kind of, Mce, freaked out and
18 was disturbed by it, and that's when I just kind of 18 went to the bathroom and then came back out and was
19 started looking at things and like playing middle 19 hanging out with my friends again.
20 person. 20 Q. Were you at a bar or club?
21 tialiog i ree with me that the things 21 A. Restaurant.
22 that did to you, choking you, 22 Q. Restaurant. Were you eating or drinking?
23 grabbing you by the neck, throwing you to the 23 A. Eating,.
24 ground, spitting on you, biting you, calling you 24 Q. Okay. So, you got up and went to the
25 vile names were much more horrendous than an hing 25 restroom?
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1 A. Yeah. And then I came back and sat down. 1 Q. — specific incident?
2 Q. Okay. And how long were you gone? 2 A. I was depressed. I was emotional. I didn't
3 A. I don't know. 3 want to talk to anybody.
4 Q. Five minutes? 4 Q. Okay. I want, I want, I want to focus on
5 A. Probably like ten minutes. 5 a specific incident.
6 Q. Okay. You cant back and fmished your 6 MR. MERMELSTEIN: Objection.
7 meal? 7 THE WITNESS: Well, I can't give you
8 A. Yes. 8 specific dates because I don't remember
9 Q. Went on with your friends for the rest of 9 specific dates. I am just telling you in
10 the night? 10 general it's happened a few times and I'm just
11 A. Yeah 11 telling you how my emotions felt a few times.
12 Q. Okay. When was the time prior to that 12 I can't sit here and be like, oh, well, this
13 that you ever had one of these flashbacks? 13 date, this, this, this; no. I am saying in
14 A. I don't know. Probably just when everything 14 general, I can't —
15 was going down just thinking about it constantly. 15 BY MR. LUTHER:
16 Q. Well, when you say "when everything was 16 Q. Each of these incidents that you have
17 going down," are you talking about when the police 17 described to me would you agree are incidents that
18 were investigating that matter? 18 lasted fora fairly short period of time?
19 A. Yeah. 19 A. No.
20 Q. All right so, now we're back — 20 Q. For example, the restaurant was a
21 A. No, I'm just saying — 21 free-minute deal?
22 Q. — in '05?. 22 A. Yeah. That was a short period of time
23 A. Yeah, but I'm just saying that's one of the 23 Q. Okay. The mall was less than five
24 times. I mean, I have had a few flashbacks. 24 minutes?
25 Q. I am going to ask you about each one. 25 A. Probably. But afterwards it still affected me
Page 554 Page 556
1 A. Okay. Are you talking about every single 1 because, yeah, I went on going shopping and stuff like
2 incident? 2 that, but for the rest of the day it affected me because
3 Q. That's what I'm doing. We're going back 3 I sat there and had to think about all the things that
4 now. What's the time prior to when you were at this 4 happened-
5 restaurant with your friends? 5 Q. How did it affect you the rest of the day?
6 A. What do you mean "prior to"? 6 A. I would sit theremd think about it. 1 was
7 Q. Well, the one that preceded that? 7 Just out of it. I was emotional. Like I wasn't — I
8 A. Well, there were several occasions from 8 was depressed. I wasn't happy.
9 whenever, yeah, the police were involved, and you know, 9 Q. Who —
10 always coming around asking questions. I had a few 10 .dn't want to talk to an
11 flashbacks about what went on. 12
12 Q. Okay. That was in '05, right?
13 A. Yeah, so I mean —
14 Q. And so —
15 A. — there was a few.
16 Q. I am going to — let's talk about them. 16 Q. On those occasions when you were out with
17 A. Of not just seeing him out but just having 17 groups of people, you continued to do whatever
18 flashbacks of what was going on. 18 activities you were doing with that group for the
19 Q. While the police were making their 19 rest of the night?
20 investigation? 20 A. Yeah. I finished eating and then I went home.
21 A. No. Like afterwards or beforehand or before 21 Q. Okay. Which is what the plan was to begin
22 they came and interviewed. 22 with, right?
23 Q. Okay. Tell me what happened. I want to 23 A. No the robabl went out.
24 know about the next -- 24
25 A. Nothing.
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1 A. Well, we sat down and talked about -- no, I
r • 2 just - at that time 1was just really emotional and I
3 MR. MERMELSTEIN: Objection, asked and 3 was angry and upset, and I would take it out on him.
4 answered. 4 Q. Okay. But that doesn't happen now?
5 BY MR. LUITIER: 5 A. No.
Q. Okay. All right. So, and the only other
7 thing you said was you had, l think you had
8 arguments with your d. Did it cause you
arguments with Mr.
10 A. It, it was. Whenever a situation would happen
11 11 1, I don't know. I have a close relationship with God.
12 1,1go to church and if you read the Bible, I mean, it
13 pretty much tells you that God forgives everybody. Like
14 one of the fallen angles, he used to sin, he used to
15 Q. And how many of these arguments did you 15 cheat on his wife, he used to do all this stuff, he used
16 have with your boyfriend? 16 to, used to do all this nasty kind of stuff and the Lord
17 A. It was just funny that it was around the time 17 still forgave him and let him come up to, up to the
18 frame of everything that was going on with this 18 Lord.
19 investigation. 19 So, me having sinned and did that, I know
20 Q. So, how many arguments did you -- you've 20 that I did that and I have asked the Lord for
21 only - you've been -- 21 forgiveness. And I feel like he's forgiven me. And
22 A. I don't know. It wasn't like I can remember 22 for me, I have, you know, yeah, I was upset at the
23 every argument, but I just know we were more 23 time but it doesn't — something that I, that I've
24 argumentative. 24 dealt with. And I have asked the Lord for
25 Q. Okay. So, you're saying it's not a 25 forgiveness and I feel like he's forgiven me.
Page 558 Page 560
1 specific argument. You're just generally saying you 1 Q. You're a religious person?
2 and he were more argumentative? 2 A. Yes.
3 A. I was more depressed about it and 'was more 3 Q. You believe in forgiveness?
like emotional about the situation then. I mean — 4 A. Yes.
whenever we would get in arguments, it was always about 5 Q. You believe the Lord forgives people that
6 me being paranoid because I thought somebody was 6 commit horrendous crimes?
watching me, or you know, and then I would start 7 A. Yeah.
drinking and I would get emotionally upset and we would Q. And the Lord also will forgive Jeffrey
9 t it. 9 Epstein, light?
10 MR. MERMELSTEIN: Objection, form.
11 MR. LUTTIER: Or de you — isn't that
12 right?
13 Q. Did you tell MI that that's why you 13 THE WITNESS: Is he religious? Does he
14 were getting upset? 14 believe in the Lord?
15 A. Yeah. 15 BY MR. LUTTIER:
16 Q. How many of these arguments did you have? 16 Q. You're the ono that has the religious
17 A. I don't blow. Maybe a few. 17 belief, right?
18 Q. And you've only, what a year and a half 18 A. I think for the people that believe in God,
19 you have been going out with him? 19 yeah.
20 A. Yeah. 20 Q. Okay. So, you're a person that believes
21. Q. So, you've had few in a year and a half. 21. in God?
22 Did you always make up atter your arguments? 22 A. Yeah.
23 A. Yeah. 23 Q. And, and one of the things you believe,
24 Q. And, and is there something new now that 24 you shouldn't judge others?
25 has changed and you don't have these arguments? 25 A. cap- yeah, I can't -- what happened, I
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1 don't know what his beliefs are. So, you know, if he 1 MR. LUTTIER: Well, wait a minute.
2 doesn't believe in that, then I don't know — 2 THE WITNESS: I don't think he has.
3 Q. Well, that would be his problem, right? 3' .MR. LUTHER: I'm not asking about —
4 A. Yeah. 4 THE WITNESS: So, I don't know.
5 Q. But I am talking about your - 5 BY MR. LU1
6 A. It's something that be needs to ask for 6 Q. I am not asking about Mr. Epstein. I'm
7 forgiveness for. 7 talking about your ability to gain comfort by saying
8 Q. Okay. That's his problem. That's not 8 the Lord forgives people that make mistakes. And
9 something you have any control over, right? 9 you've said that you got that comfort, right?
10 A. So, if something bad were to happen to him — 10 A. Yes. I feel like I have.
11 I am saying this is what I forgive, this is bow, this is 11 Q. Okay. And, and you think it would be
12 what I want forgiveness for, for myself. For him, I 12 certainly appropriate if the Lord forgave
13 don't want it. He deserves for'whatever he gives. 13 Mr. Epstein, too?
14 Q. I want to take this carefully because you 14 MR. MERMELSTEIN: Objection to form.
15 have now told me you are a religious person and that 15 She's answered that question three times
16 you believe the Lord forgives, right? 16 already.
17 A. Yeah. 17 MR. LUTHER: I don't think she has.
18 Q. And it has given you great comfort knowing 18 MR. MERMELSTEIN: Very specifically.
19 the Lord forgives — 19 THE WITNESS: No.
20 20 MR. MERMELSTEIN: She, she has answered
21 the question.
22 BY MR. LUTHER:
I 23 Q. So, if I get this right there is a double
24 Q. You also believe that because you are a 24 standard that is you want to apply a different
25 religious person that it's not your responsibility 25 standard in your religious beliefs to Mr. Epstein?
Page 562 Page 564
1 to judge others, I assume; is that right? 1 A. No, I am not putting a double standard —
2 A. No, but people do. 2 MR. MERMELSTEIN: Objection. You clearly
3 Q. No. But your religious. Just like you're 3 don't understand what she's saying.
4 able to say the Lord has forgiven you with respect 4 THE WITNESS: lam not putting, I'm not
5 to what you have done? 5 putting a double standard on that. I am just
A. And, yes, in that certain situation, yes. 6 saying as myself in the Lord and me having a
7 Q. You need to wait until I finish. Just 7 belief in that, I have asked for, one-on-one
8 lace you believe that the Lord forgave you, you 8 for that. Now, what his belief is, I don't
believe it's not your position to judge others, 9 know.
10 right? 30 MR. LUTTIER: Okay.
11 MR. MERMELSTEIN: Object to the form. 11 THE WITNESS: I don't think that he has
12 THE WITNESS: No. There, here's been 12 asked for forgiveness, and I don't think, you
13 times where. 13 know, I don't think he should get forgiveness.
14 MR. LUTTIER: And so — 14 But if he does get it, then, you know, good for
15 THE WITNESS: I've had judgment — 15 him. That's his, whatever he believes. But
16 MR. LIMIER: So, you believe. 16 honestly I don't think he wants —1 don't even
17 THE WITNESS: — on others. 17 think he cares.
18 BY MR. LUTTIER: 18 BY MR. LUTTIER:
19 Q. So, you believe the Lord will forgive 19 Q. Well, you wouldn't even know if he asked
20 Mr. Epstein too, don't you? 20 for it or if he got it or anything else, would you,
21 A. No. 21 right?
22 Q. So, there is a different standard. 22 A. No, I. ivouldn't.
23 MR. MERMELSTEIN: Object to form. 23 Q. So, from your perspective, becaimp you can
24 THE WITNESS: Maybe he will. I don't 24 only be responsible for yourself, right?
25 know, I don't what he's asked for forgiveness. 25 A. Yeah.
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1 Q. Okay. From your perspective, you gained 1 A. Probably like six, seven months ago, eight
2 comfort in saying, you know, ! believe in the Lord, 2 months ago. Ifs been a while. I don't even know. It
3 and he's forgiven me for whatever I have done? 3 might have even been longer.
4 A. Yeah. 4 Q. There is a girjjyhose first name escapes
5 Q. And, and you moved on, right? 5 me but lag name of M. Do you know her?
6 MR. MERMELSTEIN: Objection to Iona 6 A.
7 THE WITNESS: Ifs helped me move on, yes. 7 Q. Yeah.
8 BY MR. LUTHER: a A. Sam& hpuilkalLissa ,; ut a -
9 Q. Okay. So, we have now discussed all the 9 Q. Who is (phonetic)?
10 damages that you allege you have suffered as a 10 A. Was my college roommate.
11 result of any interaction with Mr. Epstein, correct? 11 Q. And what's your relationship with her?
12 A. Uh-huh. 12 A. Friends with her. Acquaintances. I don't
13 MR. MERMELSTEIN: Objection to form. 13 talk to her anymore.
14 BY MR. LUTTIER: 14 Q. Is that because of anything in particular
15 Q. Did you — what was your answer? 15 or you just --
16 A. What did you just say? Sorry. 16 A. No. We were maiiSnds. We
17 Q. We have now discussed all of the damages 17 were acquaintances. W and
18 that you have alleged you have suffered as a result 18 stuff. But now that I graduated and she graduated, we
19 of your interaction with Mr. Epstein? 19 don't — we're not around. . We don't talk anymore.
20 MR. MERMELSTEIN: Again, form. 20 Q. Was she your roommate for all four —
21 THE WITNESS: Yes. 21 A. Just average friends.
22 BY MR. LUTTIER: 22 Q. Was she your roommate for all four years?
23 Q. d.Wl was your best friend in college? 23 A. Thee, three years.
24 A. and Jane Doe No. 7. 24 Q. What three years?
25 Q. And was that throughout college? 25 A. I think. Freshman, sophomore, and junior.
Page 566 Page 568
1 A. Yes. 1 Q. illicit did she come from?
2 Q. That's la 2 A.
3 A. Yes. 3 Q. And do you know her parents?
4 Q. There was a baseball player you dated? 4 A. Yes.
5 A. Yes. 5 Q. And how do you know her parer
6 isn't coming to me. MIE. 6 A. Fle4M Kethey would come to mall', games.
7 laillir eWhere does he live now? 7 Q. Have you had any communication with them?
8 A. I don't know. 8 A. Since when?
9 Q. When was the last time you had any contact 9 Well, since you graduated from-, from
10 with him? 10
11 A. When I saw him for graduation probably. 11. A. No.
12 Q. Okay. Your relationship with him was 12 Q. Who, who do you-all mmvs that you
13 okay? 13 that you are a Plaintiff in one of these lawsuits?
14 A. Yeah. 14 A. Do I bow whet
15 Q. And you just decided that he wasn't the 15 Q. Do you know right now there is a pseudonym
16 perfect one for you? 16 for you so your name isn't displayed?
17 A. Yeah. 17 A. I don't know them
18 Q. Okay. Was there somebody else that you 18 Q.Litalthan your friends like lane Doe No.
19 had a relatio h in college? 19 7 and Iggidoes anybody else know? Have you told
20 A. Prior I wasn't in any 20 any other people you are a Plaintiff in a lawsuit
21 boyfriend-girlfriend, no. 21 mherihm your parents and your boyfriend?
22 Q. Okay. When was the last time you had 22 A. Not that I mean maybe Jane Doe No. 3..1
23 any — I think I asked you this. If I (lid I 23 don't think I told her anything. I think maybe she
24 apol i . Your last time you had any communication 24 assumes or knows.
25 with 25 Q. Have you had discussions Nvith other
• • V ea - • 4Y-•.4.0.L•WelaISISKJ • WEN,m•••
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1. People -- 1 when did you it?
2 A. No. 2 A. No, I mean was not —
3 Q. -- that have lawsuits going on? Did 3 Q. Okay.
4 there, was there a time that you went up to sic Jane A. I was not — I wasn't tipsy.
7 in and you decided to Q. So, you were underage for being in there,
I 6 weren't you?
7 A. I didn't go inside to try. I was hanging out. 7 A. You only to be 18 to be in there.
8 I wait there for I think my birthday weekend. And I was 8 Q. You had to be 21 to drink though. right?
9 drinking at the pool all day. And was livin with 9 A. I was at the pool drinkin before went.
10 Jane Doe No. 7 at the time and 10 Q. I'm talking abo your
11 and asked me to go. And me not being in the right state 11 recollection?
12 of mind,1 was like, sure, why not. And she went in at 12 A. I wasn't drinking there.
13 4:00 in the afternoon. I went with her. And then 1,1 13 Your recollection is you could be=
14 wasn't even there for, I think I did one song. I felt 14 at 18?
15 so uncomfortable and I had to leave right away. I was 15 A. Apparently, yeah.
16 there for maybe 20 minutes at the most. 16 Q. Do you have a fake ID to show it?
17 Q. When, when was this? 17 A. No. It was around my 18th birthday.
18 A. I think around my 18th birthday. 18 Q. Did they, did this establishment ask you
19 19 for your identification?
20 20 A. Yeah.
21 Q. Before you moved up there? 21 Q. And what did you tell them your age was?
22 A. Yeah. I was way before — I went there for my 22 A. I gave them my license.
23 birthday. I think I went there to celebrate my birthday 23 Q. Your license reflected —
24 weekend. 24 A. Yeah.
25 Q. This was while you — 25 Q. So, did they interview you or something?
Page 570 Page 572
1 A. I was there for having fun. Huh? 1 A. No.
2 Q. This is before you stopped going to see 2 Q. All right.
3 Jeff Epstein? 3 A. They just, was working there so they --
4 A. Yeah. 4 she was just like, :I friend here —
5
6
7
adand kay. So, in '05 sometimiln go up to
A. Well,
rune your friend ='?
lived with Jane Doe No. 7.
6
7
youjt
A. No. It was clothes.
Q. Okay. And she's working at -- what was 8 Q. So, you went and put on a costume to begin
the name of this place? 9 with?
.0 A. I don't even know. 10 A. Yeah.
11
13
14 A. Yes, that's what that's called.
11
12
13
14
• And then
A. Yeah.
Q
15 Q. And you went here? 15 A. There was nobody there. It was at 4:00 in the
16 A. Yes 16 afternoon.
17 17 Q. Did you --
18 A. There might have been two people there.
19 Q. Okay. Was that the first time you did
20 that?
21 A. No. It was kind of a, it was a bad decision 21 A. Yeah.
22 that I made, being going there, having celebrated my 22 Q. First time in your whole life?
23 birthday all weekend and then drinking at the pool and 23 A. Yeah.
24 not being in the right state of mind. 24 Q. Have you ever done it since?
25 Q. Are ou going to tell me you were drunk 25 A. No.
31 (Pages 569 to 572)
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Page 573 Page 575
1 Q. Okay. Now, while ou were u seeing your 1 testimony?
2 friend Jane Doe No. 7 and did you stay 2 Q. How do you know her depo was taken?
3 at the apartment they were in? 3 A. Because I heard that her deposition was taken.
4 A. Yeah. 4 Q. What did you hear about her deposition?
5 Q. Okay. And cident 5 A. Nothing. !just heard it was taken.
6 involving you and boyfriend? 6 Q. She testified that you spent the night at
7 A. No. 7 the apartment that she shared with Jane Doe No. 7,
8 Q. Was there — v know an individual by 8 and that she got up in the night to come out and
9 the name of 9 find ou ivin her boyfriend who she defined as
10 A. No. 10 oral sex?
11 Q. Do you recall — 11 A. That never happened. She's lying.
12 A. I know, I know that, that name sounds familiar 12 Q. That's just
13 but I don't know. 13 A. der_ dated never h cad up
14 Q. Well, doac tcall on any occasion when 14 with a don't even know if —
15 you were up in and you stayed wherever 15 sounds familiar from Don't even
16 was staying, spent the night. Do you recall that 16 know if al was ever in That never
17 ever happening? 17 happened.
18 A. That never happened. 18 Q. Are you saying you know who
19 Q. You never wentaSere and spent the 19 is or —
20 night in the same place = was spending the 20 A. No. That name sounds familiar from high
21 night? 21 school in not in . That just never
22 A. Probably. I am sure when, in whenever 22 happened. I've never hooked up with any ofher
23 was Jane Doe No. Ts roommate, they had two 23 boyfriends, never had her ever walk in on me doing
24 diffettlia-drooms, you know. I don't, never stayed 24 anythini like at. That just never happened.
25 with=. I stayed at Jane Doe No. 7's. 25
Page 574 Page 576
1 Q. I want to breakdown semantics. and 1 A. None of it adds, none, from the name to
2 Jane Doe No. 7 had an apartment? nothing adds u
3 A. Yeah. that
4 Q. Did you ever spend the night in that
5 apartment? 5 A. I don't know what it was called.
6 A. Yeah. 6 Q. What did your conversation with your
7 Q. Did you en md the night in that 7 parents consist of after the last deposition
8 apartment when was also in that apartment? 8 regarding Specific, that issue.
9 A. Yeah. 9 A. Oh, that issue?
10 Q. All right You just weren't in the same 10 Q. Yeah. What did you tell them?
11 bedroom as her, right? 11 A. Nothing. I told them a little bit about it
12 A. Yeah. I don't even know if she was home. I 12 beforehand, and then when we were going over on the
13 think she had a boyfriend. I don't even know if that 13 phone, and they just -- I mean, they were upset of
14 weekend she was even around, or she even, either 14 course. I mean, what parent wouldn't be upset.
or with her boyfriend. I don't even 15 Q. So, this was a conversation that happened
16 know if she was there because by the time I went to bed, 16 over the phone, not face-to-face?
17 she was never home. 17 A. No. We talked about it afterwards
18 Q. Are you aware that deposition's 18 face-to-face when they came into town.
19 been taken? 19 Q. So, there were two conversations?
20 A. Yeah. 20 A. Sure. I don't know. I'm sure it got brought
21 Q. Are you aware of the substance of her 21 up.
22 testimony? 22 Q. Well, I don't want you to guess.
23 A. No. 23 A. I think it got brought up on the phone or
24 Q. How do you know -- 24 maybe we talked face-to-face.
25 A. What do you mean the substance of her 25 Q. So, after your deposition you called them
32 (Pages 573 to 576)
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Page 577 Page 579
1 m
on Die Ione to tell them abou' I a little girl?
2 A. Yeah.
A. Not really right after, but I told them about 3 Q. So, did it make it particularly difficult
it, yeah. 4 for auto
5 Q. Okay. How did that conversation go? Okay.
A. Well, I have an open relationship with my 6 A. What's that? Well, after I told her, yeah, it
7 parents and I tell them a lot of things. So that was 7 was hard but --
one thing that I didn't tell them, of course, you know 8 Q. It had to be upsetting to you?
9 that. And so, whenever I told them, ofcourse they were 9 A. Yeah. Well, it was upsetting but it was
10 upset like any parent would be, but at the same time 10 something that my mom told me when I was younger when I
11 they were just kind of like, you know, I am your 11 was 15 years old and starting to sleep around. She told
12 parents; I am going to be here for you; have you like, 12 me that things to scare me. I mean, after the situation
13 you know, asked me, have you asked God for forgiveness 13 already happened, what are you going to do? You can't
14 and — • 14 scare me anymore. I'm not IS, you know, 15 years old.
15 Q. And were there tears during that 15 So, it kind of, you know, lace, you know this happened.
16 conversation? 16 I'm sorry it happened. You know, what are you going to
17 A. I don't remember. I'm — I think I was more 17 do? The situation already happened.
18 like frustrated and upset. I don't know. I don't 18 I 'mow she's not going to talk, not talk
19 remember. 19 to me anymore. I think it's something she, it's a
20 Q. Well, this conversation had to happen 20 scare tactic that she used to --
21 since -- 21 Q. Okay.
22 A I might have gotten teary-eyed about it 22 A. — probably prevent the situation.
23 Q. Wait a minute. 23 Q. And that --
24 A. I don't know. 24 A. And then after it's already happened, what are
25 Q. Wait a minute. Let me finish my question. 25 you going to do? Yeah, I am sure l was upset whenever
Page 578 Page 580
1 This conversation that you can't remember happened 1 told her about it, but I mean she told me then and
2 sometime after October 27th of '09, right? 2 there, I love you, lam going to be here for you, sorry
3 A. Yeah. 3 to hear that that happened, I wish I would have known, I
4 Q. Okay. 4 wish, you know. And then, you know, it made me and my
5 A. But I'm sure — I mean, the conversation, I'm 5 parents even closer that we had that conversation.
6 sure, maybe I did get teary-eyed. I don't. know. I 6 Q. And there was -- they came here personally
7 don't remember if I got teary-eyed or the exact and you saw them?
8 conversation that took place. 8 A. No, not for that. They came here for just
9 Q. Do you remember whether or not your folks 9 visiting or something like that and not just to come
10 were each on an extension on were you talking to 10 down and talk to me about that, just come down to visit
11. them separately? 11 and —
12 A. No, a speaker phone. 12 Do ou have an thou: is or concerns that
13 Q. Okay. What did your mother tell you? 13
14 A. My mom didn't really say anything. My dad
15 said most of everything.
16 Q. Had your mother told you --
17 A. My dad was like your mom is upset and my mom 17 MR. MERMELSTEIN: Objection, calls for
18 was just kind of in the background listening to me and 18 speculation.
19 my dad, Lice, have conversation. 19 THE WITNESS: Yeah. I'm sure.
20 Your mother testified that she had told 20 BY MR. LUTTIER:
21 71 Q. What are your thoughts about that?
22 A. I haven't thought about it, but I am sure if
23 A. She told me that beforehand, but she didn't 23 the situation occurs, thenl will.
2,1 tell me in that conversation. 24 Q. And what do you think your emotion is
25 Q. Okay. But that is something you heard as 25 going to be at that time?
33 (Pages 577 to 580)
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Page 581 Page 583
1 MR. MERMELSTEIN: Objection to form. 1
2 THE WITNESS: I don't know. I haven't
3 thought about it.
4 BY MR. LUTHER: 4 Q. Do you recall, with respect to
5 Q. Did you ever travel anyplace with Jeffrey 5 death, how old were you?
6 Epstein? 6 A. I think I might have been 14, 15.
7 A. No, but he asked me to. 7 Q. And he was the guy that you had dated for
8 Q. Okay. Did you, were you a person when — 8 sane period of time, right?
9 A. I wasn't old enough to go. 9 A. No. I knew him and he took me out one time.
tirimuwere in high school, were you
I
10 Q. Okay. And then it took you a fair amount,
11 amotmt of time to get over his death, didn't it?
12 A. Yeah. 12 MR. MERMELSTEIN: Objection to form.
13 Q. Did you, did you communicate with 13 MR. LUTTE31t: Did n take you --
14 Mr. Epstein on a computer? 1.1 THE WITNESS: Maybe it was my freshman
15 A. No. 15 year, and then maybe sophomore year whenever
16 MR. LUTITER: Somebody got the time? 16 his death came out I thought about it. But if
17 THE VIDEOGRAPHER: It is 12:11 p.m. 17 you ask me what date he died today, I couldn't
18 MR. List TIER: No. But I mean how much more 18 tell you.
19 time do we have to go? 19 BY MR. WMER:
20 THE VIDEOGRAPHER: Five more minutes, sir. 20 Q. Did you have another really good friend
21 BY MR. LUTTIER: 21. named In that died?
22 Q. Okay. You had a friend named -- 22 A. I was friends with her, acquaintances with
23 A. Yeah. 23 her. She was somebody I knew but not gocd, best friends
24 Q. — that died 24 or somebody that I hung out with like every day. 1 knew
25 A Yes. 25 her through high school.
Page 582 Page 584
1
2
3
with M?
What was your, what was your relationship
A. We were good friends. He took me out on a
1
2
3
airA. Nisi=
you know a lady by the name of ht.
4 date once. 4 Q. Yeah?
5 Q. Had you ever been intimate with him? 5 A. No.
6 A. No. 6 vi somebody by the name of
7
8
Q. You gave some answers to interrogatories
and you listed four individuals
7
8
tial
A. Yeah.
ti
9 IliSexual relations with: 9 Q. And how do you know
10 =, and 10 A. High school.
11 A. Yes. 11 Q. And what kind of relationship did you have
12 Q. Were there, in fact, others with whom you 12 with her?
13 had sexual relations? 13 A. Just acquaintance, acquaintance, hang out at
14 A. No. 14 parties; I guess, high school parties.
15 Q. Do ou know a fellow by the name of I 15 Q. Did you socialize with her?
16 think it's 16 A. Huh?
17 A. Yeah. 17 Q. Did you socialize with her?
18 Q. And a EIM? 18 A. Yeah.
19 A. Yeah. 19 Q. Do you know if she ever went to see
20 Q. Ever have sex with either of them? 20 Mr. Epstein?
21 21 A. I think she did.
22 22 Q. And how do you }mow that?
23 A. Because she hung out in a group of friends
24 that I hung out with and pretty much every one of those
25 girls went.
34 (Pages 581 to 584)
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Page 585 Page 587
Q. Do you know who took her there? THE WITNESS: Yeah.
2 A. No. 2 BY MR. LUTTIVL.
3 Q. Do you know how Mien she went? 3 O. Mr. the individual that
4 A. No. 4
5 Q. When was the last time you talked to her? 5 A. Yeah. !guess.
o A. Since high school. 6 Q. Within the first year that you were dating
7 Q. Do you remember a Ms.IMP 7 with Mr..., he had used cocaine; is that
8 A. No. What did you say the first person's name 8 right?
) was, 9 A. No, not that I'm aware of.
10 Q. Yeah. 10
11 A. It sounds familiar but I can't — 11
12 Q. Do you know that person? 12
13 A. I don't know. I don't think so, but it sounds 13
14 familiar. Is that the first name? 14
15 Q. No, last name. 15
16 A. Oh, no. Like I said, the last name sounds 16
17 familiar but 1 don't know. 17
18 Q. Have you ever told your parents everything 19
19 that occurred when you were at Mr. Epstein's? 19
20 A. Briefly. 20
21 THE VIDEOGRAPHER: I am sorry to interpret 21
22 but now might be a good time to change the 22
23 tape. 23
24 ME- LUTITER: Okay. 24
25 THE VIDEOGRAPHER: Going off the record at 25
Page 586 Page 588
1 12:15. This is the end of Video Tape One. 1
2 (A briefrecess was held.).
3 THE VIDEOGRAPHER: We're back on the
4 record at 12:17 p.m. This marks the beginning
5 ofTape Two.
6 BY MR.. LUTTIEFt:
7 you, while were you dating
8
9
Iti while you were in high school you did
cocaine with him; isn't that right? 9
MR. MERMELSTEIN: Objection, asked and
answered.
10 A. Yeah. 10 BY MR. LUTTIER:
11 Q. And you started drinldng when you were 11 Q. You never felt threatened when you were
12 about 15? 12 with Mr. Epstein, did you?
13 Pro 13
14 14
20 Q. You were smoking pot in high school?
21 A. I wasn't — in high school l tried it once or
22 twice, didn't like it never clid it again.
23 Q. Okay. Mr. ME, our bo riend at the
24 time, was the individual that
25 MR. MERMELSTEIN: Objection to fonn.
35 (Pages 585 to 588)
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Page 589 Page 591
1 CERTIFICATE OF OATH
2 THE STATE OF FLORIDA
3 COUNTY OF PALM BEACH
4
5 I, the undersigned authority, certify that
6 JANE DOE NO.4 personally appeared before me and was
7 duly sworn on the 12th day of February, 2010.
8
9 Dated this 22nd day of February, 2010.
10
11
12
13 0 6444J.LC: cAisms
14 Cynthia Hopkins, RPR, FP
Notary Public - State of Florida
15 My Commission Expi 25.2011
My Commission No.:
16
17
18
19
20 m atte] when initially took you, 20
21 ook you to Jeffrey Epstein's and she told 21
22 you what was going to happen, did she specifically 22
23 tell you not to tell him your age? 23
24 A. Yeah, I think so. 24
25 Q. And so you dichit tell him your age, 25
Page 590 Page 592
1 right? 1 CERTIFICATE
2 THE STATE OF FLORIDA
2 A. Yeah, I didn't. 3 COUNTY OF PALM BEACH
3 Q. You said, yeah, you did not? 4
I. Cynthia Hopidm, Registered Professional
4 A. I didn't tell him my age. Reporter, Florida PrefasioratReperter aid Nola",
5 Q. Okay. 6 Public in and for the State ofFlorida at larpt, do
hereby co,* that Into sudvxned wand did
6 MR. MERMELSTEIN: I think we're out of 7 report said deposition in stenotype, and that the
1 time. If there is anything pertinent -- foregoing pages we a Due and cared a:intent:nen
MR. LUTTIER: I don't have any other 8 ofmy slxxthassd notes of said deposntect
9 I N:Ikr certify lint said deposition was
9 questions. Sam at the time and puce harcinabon set forth
10 MR. MERMELSTEIN: Nothing further. 10 and that the taking of said deposition was commenced
and correletcd as Mien:above set out.
11 THE VIDEOGRAPHER: Going off the record at 11
12 1223 pa This marks the end of the I fiance certify that I an rot attorneye
12 wand of any of the conies, nor anal a relative
13 deposition. or oriployce any aticcncy cc counwi of pub.
14 (Witness excused.) 13 corrected with Sr action• nor am I finathally
15 (Deposition was concluded.) imaested in the action
14
16 The foregoing certification of this transcript
17 15 does not apply to any repodunion of tit tame by
any means unless under the diettet COCIrni andfor
18 16 • direction of the praying repxter.
19 11 Dated this 22nd day of Folmar)/ 2010.
20 19
2/ 20 nn
21 n -7 CtittS
22 Hopitire, RPR,
23 22
24 23
24
25 25
36 (Pages 589 to 592)
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Page 593 Page 595
t DAM Newsy 22m2 2010 1 ERRATA SHEET
2 110.. /NEDOE NO. 4
el> Start S. Ilearrebaina noon, 2 INRE: JANE DOENO. 2 VS. EPSTEIN
• 117, PA at Cynthia Hopidns
3 DEPOSMON OF: JANE DOE NO. 4
TAKEN: February 12th, 20'0.
INRE lame Doe M. 2n F110.1.1)
6 S DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERB
CASE NO at-QV-201I94AARRA10102SON PAGE # LINEN CHANGE REASON
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Item* keg Oirsooto tote red to 16
titracdpi selesed awes. In sa.to to ,se
:5 odds themes sleet eed rem:See ppe 17 Please (Award the original signed errata sheet to
mo this office so that copies may be distributed to nil
16 HA:969m road and ttip to decciacta
%fawn mutable tin, theaired. Alsach be 18 parties.
17 idiom>, bee Rowed leis sa4trwas arsomay.111.Y 19 Under penalty of perjury, I declare that I brat read
bofikai veh le actor the Cam Use wsta my deposition and that it is true and correct
It to ens year sieesse., skos wur rune the bleak
at are Foams the Se end mum emw 20 subject to any changes in form or substance entered
19 hat.
Vey MA, Aum
20 21
22 DATE:
at 23
CplIm14Aslow. Mt APR
22 kb hereby rent ter sacstrA 24 SiGNATUREOP
23 DEPONENT*
25 Wanonwo 4 25
25
Page 594
CERTIFICATE
2
3 THE STATE OF FLORIDA
4 COUNTY OF PALM BEACH
5 I hereby certify that I have read the foregoing
6 deposition by me given, and that the statements
7 contained herein are true and correct to the best of
8 my knowledge and belief; with the exception of any
9 corrections or notations made on the errata sheet,
10 if one was executed.
11
12 Dated this day of
13 2010.
14
15
16
17
18
19 JANE DOE NO. 4
20
21
22
23
24
25
••••1101:1=5,====.ttta -J
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