EFTA01076383

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME I OF II JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JANE DOE NO. 5 Friday, February 26, 2010 8:07 - 3:44 III. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1312 PROSE COURT REPORTING AGENCY, INC. EFTA01076383 EFTA01076384 Page 2 Page 4 APPEARANCES: PROCEEDINGS On behalf of the Plaintiff: 2 3 STUART S. MERMELSTELN, ES laRMELSTEEN & HOROWITZ, M. 3 Deposition taken before Cynthia Hopkins, 18205 Biscayne Boulevard 4 Registered Professional Reporter and Florida Suite 2218 5 Professional Reporter, and Notary Public in and for Miami Phone: 6 the State of Florida at Large, in the above cause. 6 E-mail: 7 7 On behalf o the en t: 8, THE VIDEOGRAPHER: This is the 26th day of 3 ROBERT D.CRJTTON,JR,ESQUIRE MARK T. LUTHER. ESQUIRE 9 February, 2010. The time is 829E. This is 9 BURMAN, CRITTON, LUTHER & COLEMAN, UP 10 the videotape deposition of Jane Doe No. 5 in 303 Banyan Boulevard 11 the matter of Jane Doe No. 2 versus Epstein. Suite 400 West P • • ride 33401 12 This deposition is being held at 250 31 Phone: 13 Australian Avenue South, West Palm Beach, 14 Florida. 12 13 15 My name is Sascha Quimby. I'm the 14 ALSO PRESENT: 16 videographer representing Visual Evidence, Inc. 15 Will the attorneys please announce their 16 &eche Quimby, Videographer Visual Evidence, Incorporated 18 appearances for the record. 17 19 MR. MERMELSTEIN: Stuart Mermelstein for 18 20 Plaintiff Jane Doe No. 5. 19 20 21 MR. LUTTIER: Mark Luther for 21 22 Jeffrey Epstein. 22 23 MR. CRITTON: Bob Critton for 23 24 24 Jeffrey Epstein. 25 25 Page 3 Pag 1. 1 Thereupon, 2 • (JANE DOE NO. 5) INDEX 3 having been first duly sworn or affirmed, was 5 4 examined and testified as follows: EXAMINATION DIRECT CROSS REDIRECT 5 THE WITNESS: Yes, I do. 7 6 DIRECT EXAMINATION JANE DOE NO. 5 7 BY MR. LUTTIER: 3 8 Q. Good morning, ma'am. My name is BY MR. CRITTON 5 9 Mark Luttier, and we're here today for purposes of 9 10 taking your deposition. Could you tell us your full 10 11 name. 11 12 12 A. Jane Doe No. 5. 13 13 Q. And how do you spell your middle name? NO EXHIBITS MARKED 14 A. (Witness spells her middle name.) 14 15 Q. Okay. Ms. Doe No. 5, have you ever been 15 16 deposed before? 16 17 A. No. 17 18 Q. That's this process that we're doing here 18 19 today. 19 20 A. No. 20 21 21 Q. Okay. And let me explain a little bit 22 22 about the process. First of all, you understand 23 23 you're under oath? 24 24 A. Yes. 25 25 Q. Okiy. I'mxing to ask you uestions, and 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. EFTA01076385 Page 6 Page 8 1 you're going to have to give a verbal response 1 A. 1 don't have an accurate date. 2 because this court reporter is going to transcribe 2 Q. Well, approximately. 3 everything that you say. 3 A. It was before I started school. 4 A. Okay. 4 Q. And when you say "started school," what do 5 Q. So you can't shake your head and you've to 5 you mean? 6 to actually say a word so she can get it down. 6 A. Started cosmetology school. I just finished. 7 A. Okay. 7 Q. And what cosmetology school are you 8 Q. If you don't understand a question that I 8 referri 9 ask, tell me you don't understand it and I will 9 A. 10 explain it for you. 10 Q. And when did you start that? 11 A. Okay. 11 A. Last February. 12 Q. Okay. If you answer a question, I will 12 Q. That would be February 2009? 13 assume you understood it. 13 A. Yes. 14 A. Okay. 14 Q. So sometime prior to 2009 a 15 Q. Okay. If during the deposition you want 15 psychiatrist in Florida who prescribe for 16 to take a break, just let me know, and I'll be happy 16 you? 17 to accommodate you. 17 A. No. My recent visit to was in 18 A. Okay. 18 Florida. I was in Virgina at the time before I went to 19 Q. If during the deposition you think that a 19 that's where I got my first prescription of 20 previous response that you gave me needs to be 20 Ill e idn Virginia 21 amended or changed in any way, just tell me, you 21 Q. Okay. Who ysiclan who 22 know, I just thought of something. I need to go 22 on you? Would it be 23 back and correct something or supplement, whatever 23 a Dr 24 you think has to happen. Okay? 24 A. It, l'm not sure, because I was seeing a 25 A Okay. 25 psychologist and a psychiatrist, so I wouldn't know. I Page 7 Page 9 1 Q. Are you presently under any kind of 1 can't put a name to the face of who it was. 2 medication? 2 Q. This is, you were seeing a psychologist 3 A. No. 3 and a psychiatrist? 4 Q. In the last six months have you been under 4 A. In Virginia. 5 any medication? S Q. Okay. What psychologist were you seeing? 6 A. Yes. 6 A. I don't remember. 7 Q. What medication have you been under in the 7 Q. And when was it you were seeing this 8 last six — 8 psychologist and psychiatrist in Virginia? 9 A. . 9 A. Around the same time before I started school 10 Q. — months? 10 in Virginia. 11 AL =B. That's it. 11 Q. So were you seeing than in January of '09? that is 12 A. Yes. 12 13 14 15 Q. And what's the level of= prescribed for you? A. Twenty and then it went up e. Q. Okay. Most recently it was milligrams? 13 14 15 Q. I want to refer to — I'm going to read to you your answers to interrogatories that you gave in this case which were dated by you January 26th, '09. Interrogatory 12 asks you to list all the 16 A. Yes. 16 17 Q. And howab fte er; you prescribed to take 17 physicians — 18 .-milligrams of 18 A. Uh-huh. 19 A. I took it once a day, once in the morning. 19 Q. — that you had been to. I'm going to 20 Q. And who prescribed that drug? 20 show that list to you. 21 A . It was a new doctor in Florida. I do not 21 A. Okay. 22 recall the name. 22 • Q. You see Interrogatory 12 there? You don't 23 Q. Was, what kind of doctor was it? 23 mind my hand, my highlighting. And I think there's 24 A. Psychiatrist. 24 one name on the next page. 25 Q. And when was it first prescribed fiat. you? .25. „ A. Okay. 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. EFTA01076386 Page 10 Page 12 1 Q. So, can you tell me which of these people 1 right? 2 is the psychologist that you were seeing in 2 MR. MERMELSTEIN: Objection to form. 3 Virginia? 3 THE WITNESS: I, I don't, I don't 4 A. I don't think ifs listed. 4 remember, honestly. 5 Q. Can you tell me which of those physicians 5 BY MR. LUTHER: 6 is the psychiatrist that you were seeing in 6 Q. Okay. Well, let me ask you this: Do you 7 Virginia? 7 have a, an absolute specific recollection that you A. I think it's this one, 8 did, in fact, see a psychiatrist -- 9 Q. Read the, the name. 9 A. Yes. 10 A. 10 Q. — and psychologist in Virginia? 11 Q. 111111..,ame? 11 A. Yes, yes. I just don't remember. 12 A. It doesn't say. I don't know. 12 Q. And the psychologist that you saw in 13 Q. Well, how long did you see this 13 Virginia was male or female? 14 psychiatrist? 14 A. Psychologist Was it -- they were both 15 A. I saw her — I had two visits. I'm guessing. 15 females. 16 That's not 100 percent accurate. 16 Q. Okay. Do you know the difference do 17 Q. Okay. 17 you know there's a difference between a psychologist 18 A. That was just — 18 and a psychiatrist? 19 Q. Okay. Would you pass me those 19 A. Yes. 21 interrogatories so I can see if you have a date 20 Q. Okay. I'm now asking you about the 21 here. All right. In answer to 8 you said that — 21 psychologist 22 what you answered was, in response to an 22 A. Okay. 23 interrogatory that asked you to list all of the 23 Q. There was a female psychologist. 24 physicians and medical facilities or other health 24 A. Uh-hub. 25 care providers including psychiatrists, 25 Q. And do you remember her name? Page 11 Page 13 1 psychologists, mental health counselor, et cetera, 1 A. No. 2 that you had been treated for in the last ten years. 2 Q. Do you remember her first name, her last In Number 8, you list 3 name, any combination of the two? and you give a PO Box. And the 4 A. No, I don't interrogatory tells you to state, as to each the 5 Q. Do you have any records from which you can 6 dates of the examination and the condition or injury 6 determine that name? 7 for which you were examined. And what you put was 7 A. At home. 8 December 2007, dermatitis. 8 Q. Home, meaning what, here in Palm Beach 9 Now, you understand dermatitis is a County? 10 skin condition? 10 A. Home in Virginia. 11 A. Oka Well then I must be confused because 11 Q. Okay. Do you have -- in your wallet, for 12 I did have 12 example, do you have a card from, from this person? 13 A. I could look if you would like me to. 14 Q. Okay. So now you're saying 8 is not the 14 Q. Yeah, that would help us, if you would, 15 psychiatrist that you saw in Virginia? 15 please. 16 A. No, no. 16 MR. WrITER: And, Stuart, I invite you, 17 Q. So, in answering your interrogatories, you 17 if you know the answers to this, I invite you 18 have — you did not give us either the name of the 18 to go ahead and chime in. 19 psychologist or the psychiatrist who treated you in 19 MR. MERMELSTEIN: Well — 20 Virginia? 20 MR. LUTTlER: I'm not looking — l'm 21 A. I guess not. No, I guess not. 21 looking to get to the answer. 22 Q. Pm not, I'm not quibbling with you over 22 MR. MERMELSTEIN: I know she, she — this 23 words, but when, when we hear the word "guess," you 23 whose name you mentioned is in response 24 know, it makes us a little nervous. So, when you 24 lt.revious Interrogatory Number II. 25 say you guess riot, you definitively know you didn't, 25 MR. LUTT/ER: And I don't think that's a 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. EFTA01076387 Page 14 Page 16 1 psychologist. 1 give you the original back, and that way it 2 MR. MERMELSTEIN: That's a psychiatrist. 2 won't be on the record. We'll just make a copy 3 MR. LIMIER: I don't think it's a 3 so ifs not in the court file. 4 psychiatrist. 4 BY MR. LUTTIER: 5 MR. MERMELSTEIN: It's an I., right? 5 Q. Okay. All right. So, let me go back. 6 That would be a psychiatrist. 6 The — we were talking about the female psychologist 7 MR. LUTTIER: Okay. That would be, you 7 in Virginia. You don't {mow her name or number. Do 8 know, from the record that I'm looking at — 8 you recall when you first went to see this 9 okay. We'll get to that. 9 psychologist? 10 MR. MERMELSTEIN: So, yeah, I don't know 10 A. I went with my husband. No. 11 if that's the psychiatrist that she's referring 11 Q. Okay. You, You recall that your first 12 to or not. 12 visit with her was one in which your husband went 13 THE WITNESS: No, not on me. 13 with you? 14 BY MR. LUTTER: 14 A. Yes. 15 Q. Okay. Do you have a cellphone that lists 15 Q. Okay. Obviously, you were in Virginia at 16 the phone number? Do you have a phone number? 16 the time. Did, did you go to this psychologist 17 A. I have a cellphone. 17 shortly after you moved to Virginia? What I'm 18 Q. But do you keep her phone number in there? 18 looking for now is maybe the year. 19 A. Well, since my husband's in the military, I go 19 A. Let me think I don't know. I can, l can 4 back and forth from Florida to Virginia a lot, and 21 approximate it I just — 21 that's why I have to change constantly 'cause if he goes 21 Q. What's, what, what's your best estimate of 22 on deployment, I come to Florida. So that's the problem 22 when you moved to Virginia? 23 right now. That's why I don't remember. 23 A. When I moved to Virginia was 2006, 2007. 24 Q. I think you're checking your cellphone to 24 Q. Okay. And when you moved to Virginia in 25 see if you have the phone number there? 25 2006, what time of the year was it? Page 15 Page 17 1 A. Yes. I have a doctor in my phone. I don't 1 A. I moved there in January of, January of 2007. 2 know if it's the one that I saw here, while my husband 2 Q. January of 2007. 3 was on deployment, for my I can give you the 3 A. Yes, because I got married in — yeah. 4 number. 4 Q. You got married when? 5 Q 5 A. December 2006. 6 A. Ifs 6 Q. Okay. So you know you went to Virginia 1 Q. Do you have a name associated with it? 7 shortly after your wedding? A. No. B A. Yes. 9 Q. You just have a — 9 Q. Were you married down here min Virginia? 0 A. I just have it under my doctor. I can get all 10 A. Down here. 11 this information from my insurance company - 11 Q. In Palm Beach County? 12 Q. Okay. 12 A. Yes. 13 A. or my health care. 13 Q. Okay. 14 Q. Yeah. What, what insurance company is 14 A. No, Broward County. I'm sorry. 15 that? 15 Q. Okay. All right. Approximately how long 16 A a. 16 was it after you moved to Virginia that you first 17 Q. Okay. Do you have the card — 17 went to this female psychologist? 18 A. Yes. 18 A. Probably, Pm guessing, five to six months. 19 Q. —that will give us the number? Is that 19 Q. Okay. 20 the military insurance? 21 A. It's not accurate. 21 A. Yes, Prime. 21 Q. And, and why were you and your husband -- 22 MR. LIMITER: Okay. Do you have a way to 22 why did you and your husband go to this 23 make a copy? 23 psychologist? 24 THE COURT REPORTER: Yes. 24 A. Marital problems. ,25 MR. LUTTIER: Okay. We're, we're going to 25 Q. And specifically what were the marital 5 (Pages 14 to 1 7) PROSE COURT REPORTING AGENCY, INC. EFTA01076388 Page 18 Page 20 1 problems? 1 Q. Okay. And each of those visits was about 2 A. Fighting. 2 marital problems with your husband? 3 Q. And how many visits did you, did either 3 A. When he came, yes. When he was present at the 4 you alone or you and your husband have with the 4 doctor's office with me? 5 psychologist? 5 Q. Right. 6 A. Two to three. 6 A. It was about us. 7 Q. And were there were those visits with 7 Q. Okay. How about on the — you say you 8 some degree of regularity? For example, you went 8 went one time alone. 9 once a week for a month, or you went for once a 9 A. Yes. 10 month for two months, or... 10 Q. What was that visit about? 11 A. I think it was once a month. 11 A. Me and my personal life. 12 Q. Okay. So there would be approximately a 12 Q. And specifically wises about you and your 13 three-month period - 13 personal life? 14 A. Yes. 14 A. Things I've been through. 15 Q. — over which there would be about three 15 Q. Okay. For what, what was your primers 16 visits? 16 complaint or purpose for you going alone on that 17 A. That's not accurate, so I'm just saying. 17 visit to the psychologist? 18 Q. If you know it's not, what's your most 18 A. That I was depressed. 19 accurate recollection of how many visits you had? 19 Q. So, the, the, the thing that caused you to 20 MR. MERMELSIEIN: Objection to form. 20 go to her alone was because you felt that you were 21 THE WITNESS: I mean we went three 21 depressed? 22 times — I don't know. 22 A. Yeah. 23 BY MR. LIMIER: 23 Q. And what is it that you specifically 24 Q. You were about to say you went three 24 discussed with her about your personal life? 25 times, what? 25 A. It was about my husband, it was about family, Page 19 Page 21 1 A. I don't lcnow. rut not going to give an answer 1 Jeffrey Epstein was mentioned 2 when I'm not 100 percent sure of how many times I 2 Q. And how do you recall that Jeffrey Epstein 3 vvent 3 was mentioned? 4 Q. I want your -- 4 A. What do you mean? 5 A. - or how many, how many — like a time frame. 5 Q. What is it that makes you recall that you 6 Q. Well, I, I don't want you to just pick a 6 know that Jeffrey Epstein's name was mentioned? 7 number out of the sky, but I want your best 7 A. Because I remember mentioning it to her, all 8 estimate. I mean, if I had these, if I'd have had 8 the things I went through in my life. 9 this doctor's name, I would have subpoenaed the 9 Q. Okay. Anything else that you recall? 10 records and rd know exactly, but I am trying to 10 A. Just about my, my past — 11 find out who this doctor is which is why we sent the 11 Q. All right. 12 interrogatories. 12 A. — you know. 13 A. I'm going to say over three months. 13 Q. And this was a 45-minute visit? 14 Q. Okay. So your best estimate is — 14 A. Yeah. I'm pretty sure. 15 A. My best estimate. 5 Q. Did you ever go back to her after the 16 Q. 'That's fine. And on each visit that you 16 visit that you went alone? 17 went to this psychologist, was it you and your 17 A. I think, yeah, after I went to her alone, my 18 husband? 18 husband and I went one more time after that. 19 A. I think there was, !went one time alone. 19 Q. But the visit that you and your husband 20 Q. In addition to the three with your 21 had was about your marital difficulties. 21 husband? A. Yes. 22 A. Uh-huh. 22 Q. And then after that last visit between you 23 Q. So you maybe had — your best estimate is 23 and your husband and her, you didn't go back? 24 four visits, correct? 24 A. No. 25 A. Three to four. 25 Q. So, somewhere in the ear 2007 tut 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. EFTA01076389 Page 22 Page 24 going to her? 1 Q. Well, these were 45-minute sessions, 2 A. Yeah. 2 right? 3 Q. All right. 3 A. Yeah, but I didn't know anybody in Virginia. 4 A. I would say. 4 It wasn't hike I had a babysitter. 5 Q. Do you recall where this doctofs office 5 Q. Well, in the two years that you lived in 6 was located? 6 Virginia, would it be a correct statement that there 7 A. No. 7 were times that, that you left your daughter with Q. I mean, do you — I don't !mow, was it in 8 somebody else while you did things? 9 the same town that you were living in in Virginia? 9 A. No, I took my daughter. 10 A. No, it was a different area because I remember 10 Q. When you went, when you went the one time 11 it was a little bit of a drive. 11 to the psychologist did you take your daughter with 12 Q. When you say "a different area," what city 12 you? 13 was it in? 13 A. Yeah, I did. 14 A. I don't remember. 14 Q. Okay. Because your daughter at that time 15 Q. Well, how long did you live in this area 15 was less than a year old, right? 16 of Virginia? 16 A. Yeah, she was young. 17 A. I lived there two years, around two years. 17 Q. All right. So having your daughter didn't 18 Q. Okay. And I assume in that two-year 18 prevent you from going to a psychologist? 19 period you became familiar with the municipalities 19 A. No. I mean, no, but it was too hard. 20 and the cities that were located in your immediate 20 Q. Well, you, you went the one time, you took 21 vicinity. 21 her with you. 22 A. No. I am horrible with direction. 22 A. It was still hard. 23 Q. Okay. Do you have, do you have any notes 23 Q. And I assume that at age less than one she 24 or anything from, that your visits with this 24 slept a fair amount of time? 25 psychologist 25 A. Uh-huh Page 23 Page 25 1 A. I don't have any. Personally, I don't, I 1 Q. That is your daughter -- 2 didn't take any notes. 2 A. — she did, but she also had colic, so it was 3 Q. Okay. Did the psychologist have any tasks 3 not easy. 4 that she asked you to do? Like, sometimes a 4 Q. Okay. But you'd done it once before. The 5 psychologist will say, you know, write something out 5 doctor, for example, didn't say, you don't come here 6 or something like that. 6 with your daughter? 7 A. No. A. No. 8 Q. So you have no documentary materials at 8 Q. The doctor didn't say, I don't want to see 9 all concerning your visits with this psychologist? 9 you anymore? 10 A. No. 10 A. No. 11 Q. Is there any record — other than your 11 Q. You made the decision you weren't going to 12 insurance company which I assume paid for part of 12 go back? 13 this psychology visit. 13 A. Yeah. 14 A. Paid for all of it 14 Q. Okay. And your testimony is that in a 15 Q. Paid for all of it. Is that — do you 15 two-year period that you lived in Virginia, you 16 have any other record from which you can determine 16 never left your daughter with anybody else? 17 who this psychologist was? 17 MR. ME RMELSTF_1N: Objection to form. 18 A. No. 18 THE WITNESS: If you mean my mother-in-law 19 Q. Did the psychologist at your last meeting 19 that came up and watched her from — 20 advise that she didn't want to see you anymore and 20 BY MR. LUTTIER: 21 that your sessions were done? 21 Q. I mean anybody. 22 A. No, I just didn't go back. 22 A. Yeah. 23 Q. Okay. Why, why didn't you go back? 23 Q. Yeah what? 24 A. Because I have a two-year-old daughter, and 24 A. Yes, my mother-in-law came to Virginia to stay 25 it's just hard for me to take the time to go. 25 a couple of times from Florida. 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. . EFTA01076390 Page 26 Page 28 1 Q. Okay. 1 Q. You said that you — I understand that you 2 A. So when she was there, she would watch my 2 went with your husband to the psychologist, but you 3 daughter so my husband and I can go out, you know, and 3 said you went to the psychologist one time alone to 4 spend some time together. 4 talk about your problems. 5 Q. Yeah. 5 A. Yes. 6 A. But she wasn't there on the occasions of, you 6 Q. There were times that your husband was 7 Imow, when l had to go to a doctor session. It wasn't, 7 home from work that he could have watched your 8 you know, it's not — I didn't have somebody on a 8 daughter, and you could have gone back to the 9 schedule there — 9 psychologist, if you chose to, to discuss whatever 10 Q. During this — 10 problems you wanted to discuss with her, right? 11 A. — that could watch my daughter. 11 A. I could have. 12 Q. During this two-year period that you were 12 Q. Okay. And the insurance company was 13 in Virginia, was your husband living with you? 13 paying whatever those charges were? 14 A. Yes. 14 A. Uh-hum. Yes. Sony. 15 Q. Were you living on a military base? 15 THE COURT REPORTER: Thank you. 16 A. No. 16 BY MR. LUTTIER: 17 Q. Okay. And was, was he in the military at 17 Q. Let's talk now about the psychiatrist that 18 the time? 18 you said you saw in Virginia. 19 A. Yes. 19 A. Yes. 20 Q. And did he have hours that he went to 20 Q. But first of all, let me go back and ask 2/ work? 21 you a question about the psychologist. How did you 22 A. Yes. 22 select that female psychologist that you saw in 23 Q. Okay. And when would he typically work; 23 Virginia? 24 what was his schedule? 24 A. It was just offered through page 25 A. His schedule often changes since he's in the 25 that, you know, provides -- they accept. Page 27 Page 29 military. He can work day, night, or mid check. I 1 Q. Okay. Okay. Now, you said you went to a don't know the exact schedule he was on at that point in 2 female psychiatrist in Virginia as well. 3 time, but day check is 6:00 to 2:30-3:00, depending on 3 A Yes. 4 what his boss wants to keep them. Mid-check is — 4 Q. Was this during the same period of time mid-check is all night long. I don't know the exact that you went to the psychologist? 6 time, but ifs all through the entire night until 6 A. That was after. That was before my husband 7 morning. And then the night check is --1 think it's 7 was about to leave on his deployment. 8 like 2:00 or 3:00 to 11:00 at night. Q. Okay. 9 Q. Okay. So either the mid check or the 9 A. I came — 10 night check, he was home during the day? 10 Q. When was your — 11 A. Yeah. 11 A. Well, I came to Florida in January. 12 Q. All right. So, there were times during 12 Q. January of - 13 this two-year period that your husband was home and 13 A. Of last year. 14 available to watch your daughter? 14 Q. — of '09? 15 A. Yeah, but I wouldn't, you know, I wanted to go 15 A. Yes. So, it was probably a couple of months 16 with my husband. 16 before that that I went and saw her. 17 Q. Well, these were visits that you went to 17 Q. Okay. And how did you select that 18 the psychology — you went alone, right? 18 psychiatrist? 19 A. Psychiatrist or — 119 A. The same way, off the Internet that the 20 Q. Psychologist 2 providers — 21 A. Psychologist? 21. Q. And what city was she located in? 22 Q. We're still on the psychologist. 22 A. I don't know. 23 A. Okay. The psychologist was also for our 23 Do you remember where her office was? 24 marriage, so I wanted him to go with me most of the 24 A. No. 25 time. 25 Q. How many times did ou see her? 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. EFTA01076391 Page 30 Page 32 1 A. Twice. 1 A. I did, but I'm not on it right now. 2 Q. Do you, do you recall about over what 2 Q. Okay. When you say "right now," do you 3 period of time you saw her? Like, was it two times 3 mean literally like today? 4 in a month? 4 A. As in the past, Ince, as in the past week I 5 A. I think it was once a month. 5 stopped taking it. 6 Q. And for what reason did you initially go 6 Q. OW. And why did you stop taking it? 7 see her? 7 A. Because I'm pregnant A. Fa - 8 Q. Is it contraindicated; that is, did your 9 Q. And, and do you mean that when you went to 9 doctors tell you if you're pregnant, don't take it? 10 her you already knew that what ou wanted to do is 10 A. I just — I haven't seen lidgfayet, but I 11 go get a prescription f 11 just know ifs not good to takelMI while you're 12 A. Not enact] , but something to help me 12 pregnant. 13 concentrate. 13 Q. Well, I suppose the first thing we should 14 Q. And so, so your, as they would say, chief 14 do is congratulate you on being pregnant 15 complaint that caused you to seek out her aid was 15 A. Oh, thanks. 16 you wanted something to help you with your 16 Q. Is this a planned pregnancy? 17 concentration? 17 A. Not necessarily. 18 A. Yes. 18 Q. Are, are you happily pregnant? Let me ask 19 Q. Was there any other problem or, or 19 you that. 20 situation that you were seeking out her counsel for? 20 A. Yeah, I mean, ifs going to be hard, but — 21 A. There was the second visit I mentioned that I 21 two kids, young age, I mean. We'll see what happens. 22 had, depression, and that's when she prescribed me 22 Q. You're, you're sure you're pregnant? 23 to try. 23 A. I took four tests. 24 Q. How — did you have sessions with her when 24 Q. Okay. Have you been to the doctor to 25 you saw her on these two occasions, or did you 25 have — Page 31 Page 33 1 simply go in and get a prescription? A. No, it's not — 2 A. The fast time !just went in and got a 2 Q. Early pregnancy? 3 prescription. The second time I spoke to her about, you 3 A. Yes. 4 know, depression medication. 4 Q. Okay. 5 Q. And, and what did you tell her about your S A. Very early. 6 depression? 6 Q. Does, does your husband know about it yet? 7 A. I just told her that I'm depressed. I'm not 7 A. Yes. 8 happy. And I asked her what would be the best, you 8 Q. Okay. ill" So, so you have, you 9 know medication to try, and she told me to try 9 stopped taking last week because of your 10 10 own decision that you didn't want to take that while 11 Q. This female psychiatrist Mat you saw in 11 you were pregnant? 12 Virginia, was she the lust medical doctor to 12 A. Yes. 13 prescribe for you? 13 Q. Not because a physician said you couldn't? 14 A. Yes. 14 A. Yes. 15 Q. And was that initially prescribed at a 15 Q. All right. And did you find the 16 level of a day? 16 was helpful to you? 17 A. I think she started me off lower than that. 17 A. Yes. 18 Q. Okay. 18 Q. It allowed you to concentrate better? 19 A. I don't, I don't recall what my — 19 A. Yes. 20 Q. Okay. 20 Q. And had you had — was there a time in the 21 A. first dosage was. 21 past — you have a brother that, that has, has 22 Q. Have you taken Adder, 22 Attention Deficit Disorder? 23 24 25 continuously since the time that you saw this female psychiatrist in Virginia in 2007 right up until today? 23 24 las 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. EFTA01076392 Page 34 Page 36 1 Q. And I think your brother at one time was 1 alternative school. 2 on the medication. 2 Q. Okay. Typically classes here graduate in 3 A. Yes. 3 June of a year. 4 Q. And you had taken some of that — 4 A. Okay. 5 A. Yes. 5 Q. So, when you say you got it late that 6 Q. -- when you were maybe in high school? 6 year, did you get it — 7 MR. MERMELSTEIN: Make sure you let him 7 A. Late. 8 finish his question before you answer. 8 . Q. — within the same calendar year that you 9 THE WITNESS: Oh, okay. 9 would have received it had you — 10 BY MR. LUTTIER: 10 A. I'm pretty sure it was in 2006. I was 11. Q. It wass like in high school you took 11 supposed to graduate 2005. 12 some otitis 12 Q. Okay. So, we know that in June if, if you 13 A. Yes. 13 had stayed in school for each year and progressed by 14 Q. And you found that it was effective in 14 passing every year, you would ordinarily have 15 terms of allowing, helping you to concentrate? 15 graduated in June of '05? 16 A. Yes. 16 A. Yes, Ida* stay back. 17 Q. Is that how you knew that when you went to 17 Q. No. Yeah,1tmderstand that 18 se.rthe chiatrist in Virginia that you wanted 18 A. Okay. 19 19 Q. Pm just going back to your birthday. 20 A. Yes. 21 That, that would mean that that would put you then 21. Q. Is there — for what riod of time did 21 at 18 years of age June of '05 when you graduated? 22 you take your brother's 22 A. Yes. 23 A. It was just for a short period of time. 23 Q. So that would put you as a sophomore, 16 24 Q. Lfice less than a month? 24 years of age? 25 A. Yes. 25 A. Yes. Page 3 Page 37 1 Q. Okay. Is there — and that would have 1 Q. Okay. So you, your best recollection is, 2 been when you were how old? 2 you, you had taken your brother's sometime 3 A. I was in high school. 3 when you were about 16 years of age. 4 Q. Freshman year? 4 A. Yes. 5 A. No. 5 Q. And then you took it for a month or two? 6 Q. Were you living in Jupiter at that time? 6 A. For about a little less than a month. A. No. This was probably my sophomore year. 7 Q. Okay. Is there -- why did you not follow 8 Q. Which would have made you 15 years old? up, if you found it to be effective, with a 9 A. Yeah, 15 or 16. 9 physician to get a prescription of your own? 10 Q. Okay. Your date of birth is =MS 10 A. !just didn't want to. I, I don't know why. 11 11 Q. Is — do you recall what it is that caused 12 A. Uh-huh. 12 you in 2007 when you went to sec the psychiatrist in 13 Q. So do you know, do you know.in your 13 Virginia to ask for the first time for 14 sophomore year how old you were? 14 A. I didn't ask for specs I1T I 15 A. No. 15 went in and asked her, yen .,w, what I, what she would, 16 Q. Okay. Let's go -- 16 you know, refer to me. And I mentioned a couple of 17 A. I was — 17 pills, but the reason is because I was going back to 18 Q. — let's go backwards. You, you got a 18 school. 19 diploina from the Palm Beach County school system. 19 Q. Okay. And, and you had arrived at the 20 A. Yes. 20 decision at that point you thought some kind of 21 Q Did you get that in the same year that, 21 medication would assist you in being able to 22 that you would have graduated from -- 22 concentrate better? 23 A. No. 23 A. Yes. In school, yes. 24 Q. — high school class? 24 Q. 25 A. I that late because I went to an 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. EFTA01076393 Page 38 Page • 1 A. Yes. 1 physician that you saw in Florida? 2 Q What doctor diagnosed you? 2 A. I saw a male. 3 A. I don't blow. I don't recall. 3 Q. And this is a medical doctor? Q. What — where was 4 A. Yes. A. I changed doctors. 5 Q What kind of practice was he in? Q. Do you recall about how old you were when 6 A. I don't know. the doctor diagnosed you? 7 Q. Where was his office located? o A. Yes. When I first started seeing the 8 A. Delray. 9 psychiatrist in Virginia 9 Q. And, and how did you come to go to this 10 Q. Okay. What doctor? Was it the, the 10 particular physician? 11 psychologist that you were seeing in Virginia that 11 A. The same way, with the on the 12 you went to with ur husband that diagnosed you as, 12 computer. 13 as — 13 Q. And what kind of doctor was it? 14 A. The psychiatrist. 14 A. Psychiatrist. 15 Q The psychiatrist, the same one that 15 Q Do you recall approximately how long you 16 d — the same one that prescribed the 16 were in Florida before you went to him? 17 to ou made a formal diagnosis that 17 A. It was when my last dosage ran out from the 18 previous doctor in Virginia 19 A. She didn't tell me that, but don't they have 19 Q Okay. So, you went to this psychiatrist 20 to do that themselves to give you the medication? 20 because you needed to have a medical doctor in order 21 Q I don'tlatow. Pills and doctors these 21 to prescribe for you again? 22 days, I don't — 22 A. No. I was in Virginia. 23 A. I mean, I would hope so. I wouldn't want 23 Q. Right. 24 to — 24 A. I SOW the doctor in Virginia to get my 25 Q Do, do you have a recollection that some 25 started. Page 39 Page physician formally diagnosed — 1 Q. Right. 2 A. One, one of them, yes. I don't -- 2 A. I came to Florida. I finished my dosage and 3 specifically her, l don't remember if she said yes or no 3 then I went to a psychiatrist. 'didn't need a referral 4 that I have it, but one of the doctors in Florida that I 4 to see a psychiatrist inFlorida. 5 did see gave me a test to see if l was. 5 Q But you went to the psychiatrist in 6 Q. That would be a doctor that you saw in 6 Florida so that you could get your prescription 7 Florida after coming back from Virginia? 7 renewed? 8 A. Yes. 8 A. Yes. Q. Okay. You said that in a recent visit to 9 Q. Okay. How many visits did you have with 10 this Florida ician, that you had gone to to get 10 this psychiatrist in Florida? 11 more 11 A. Approximating, two or three. 12 A. Uh-huh. 12 Q. And were these visits solely for purposes 13 Q Is that right? Okay. 13 of getting your prescription? 14 A. Yes. 14 A. Yes. 15 Q. When did you visit the Florida physician 15 Q. And how long I mean, were these like 16 to Rea 16 five-minute visits? 17 A. I don't recall. 17 A. Yeah. It was a script. 18 Q. Okay. It would have been -- this visit to 18 Q. You literally would just walk in and get 19 the Florida physician would have been after you 19 the script? 20 returned to Florida from Virginia? 20 A. I'd walk in, see him, and get the script. 21 A. Yes. 21 Q. Okay. Did you have any counseling with 22 Q. And that, I think you told me was, you 22 him, or did he give you any treatment or just give 23 came to Florida in January of '09. 23 you a prescription? 24 A. Yes. 24 A. No, he would just gave me a prescription. 25 Q. Okay. And was this a male or female 25 Q. Did you give him any history? That is did vas.. 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY, INC. EFTA01076394 Page 42 Page 44 1 you sit down and tell him about your life or 1 Palm Beach, right? 2 anything like that? 2 A. Yeah. '3 A. No. 3 Q. Is it like one of the complexes at Victor 4 Qiasthe r than giving you a prescription 4 Farris? Is it over by Columbia Hospital or... 5 for a he didn't render any treatment to you? 5 A. Ifs off of Indiantown. 6 A. No. 6 Q. Indiantown Road up in — 7 Q..2:abf the last physician that renewed 7 A. Yeah. 8 your arescription? 8 Q. — up in Jupiter? 9 A. No. 9 A. No, ifs not. It's not what it is. It's... 10 Q. Okay. 10 Q. What's not? What, ifs not off of 11 A. The last doctor? 11 Indiantown Road? 12 Q. Yeah 12 A. No, it's -- no. I'm, I'm trying to think of 13 A. No. 13 the road. Next to Okeechobee. Ifs one of the exits 14 Q. Who was the last doctor -- well, let me, 14 before Okeechobee. 15 let me back it up. 15 Q. Exit off 1-95? 16 You went two to three times to this 16 A. Yes. 17 Florida psychiatrist who ou don't recall for 17 Q. Palm Beach Lakes? 18 purposes of having your prescription 18 A. No. 19 renewed, right? 19 Q. North or south of Okeechobee? 20 A. Uh-huh. Yes. 20 A. I think ifs south of Okeechobee. 21 Q. Did there come a time that you didn't go 21 Q. Belvedere? 22 back to him? 22 A. No. 23 A. Yes, I didn't go back to him. 23 Q. Southern? 24 Q. Okay. And why didn't you go back to him? 24 A. No. Maybe it's north. I'm not good with 25 A. Because he was in Delray. 25 directions. Page 43 Page 45 1 Q. So, did you — 1 Q. Okay. Well, north is behind you; south 2 A. I changed it to West Palm Beach. 2 is — 3 Q. Okay. Who did you go to in West Palm 3 A. I don't know. 4 Beach? 4 Q. -- the other way. 5 A. I think that's the one that I gave you the 5 A. I don't know. 6 number. I don't recall her name either. 6 Q. So, as you sit here today — 7 Q. Okay. So you went to a you switched to 7 A. Yeah. .8 a female physician in West Palm Beach? 8 Q. — point which way you would go to get to 9 A. Yes. 9 this office. 10 Q. And is that female a psychiatrist? 10 A. I was going towards Okeechobee from 11 A.. I know she prescribes medication, but I don't 11 Wellington. 12 know if she was the actual psychiatrist of the office. 12 Q. Okay. 13 I don't know how that works. 13 A. So north. 14 Q. Okay. Well, any, any medical doctor can 14 Q. So, you had — all right. So, all you — 15 prescribe, so she could be an internal medicine 15 this phone number that you have in your phone you 16 doctor for all you know. 16 think is this doctor? 17 A. Yeah, 'don't, l don't know. 17 A. Yes. 18 Q. Was she in a group? 18 Q. ' Okay. So you -- how long -- how many — 19 A. What do you mean? 19 when did you first go to her? 20 Q. A group, she — was it a group practice or 20 A. I don't !mow the date. 21 just one doctor? 21 Q. Approximately when, in the last six 22 A. No, it was a group practice. 22 months? 23 Q. Okay. Where was her office located? 23 A. Yes. 24 A. West Palm Beach. I don't know. 24 Q. And how many times have you gone? 25 Q. Okay. Well, you're familiar with West 25 A. Two to three. 010•111001WSIISSISIMAllitat 12 (Pages 42 to 45) PROSE COURT REPORTING AGENCY, INC. EFTA01076395 Page 46 Page 48 1 Q. And on each visit was it just to get the 1 estimate then that you must have seen this physician 2 prescription renewed? 2 within the last two months? 3 A. Yes. 3 A. Yes. It was just, I don't take my 4 Q. Did she ever render any treatment to you? 4 every day. 5 A. No. 5 Q. And what does the prescription advise you 6 Q. Did you ever give her any history or sit 6 to do in terms of the frequency with which you're 7 down and talk about any of your, your issues? 7 take the 8 A. No. I did see a psychologist for that when I 8 A. Take it every day. 9 was in Florida also, and I don't know the time frame. 9 Q. So, why don't you take it every day? 10 Q Are you talking — okay, now you're -- 10 A. Because it makes you very hyper and 11 now, the psychologist that you saw in Florida for 11 concentrate and stay up all night, so I didn't feel like 12 that is that yes another doctor whose name is not on 12 doing that every day. 13 these answers to interrogatories? 13 Q. And have you advised the doctors that you 14 A. Yes. These answers, this was a while when I 14 were having that side effect? 15 was in Virginia when I did these, correct? 15 A. Yes, that's one of the side effects. 16 MR. MERMELSTEIN: Yes. 16 Q. Do you know whether or not this female 17 THE WITNESS: That's why they're not on 17 psychiatrist in Florida ever made a formal diagnosis 18 there. 18 of you? 19 MR. LUITIER: Duly disclosed. 19 A. No. 20 BY MR LU'TTIER: 20 Q. How about the male doctor in Delray, do 21 Q. When was the last time you saw this female 21 you know if he made a fonnal diagnosis? 22 psychiatrist in, in West Palm Beach? 22 A. Yes. 23 A. The psychiatrist that prescribed medication? 23 Q. You know he did? 24 Q. Yes. 24 A. Yes. 25 A. It was after the male, before I went to 25 Q. Okay. And what was his diagnosis? Page 47 Fay: 1 Virginia. I don't have an exact date and time. 1 A. That I have 2 Q. Well, was it within the last month? 2 Q. And how do you know he made the formal 3 A. No. 3 diagnosis? 4 Q. Last two months? 4 A. Because he gave me a test and I asked him what 5 A. The last three to four months, maybe. Two 5 it was for and he told me that it was for to see if I 6 to I'm, I'm not sure. 6 had 7 Was she the last physician to prescribe 7 Q. Did the female doctor in West Palm Beach 8 for you? 8 that you most recently went to to renew your 9 A. Yes. prescription give you a test? 10 Q. And, and you had, you still have your last 10 A. No, not that I recall. 11 prescription, right? 11 Q. Did the psychologist that you saw in 12 A. Pm not taking it anymore. 12 Virginia give you any kind of test? 13 Q. I know you're not taking it, but you still 13 A. Not that I remember. I don't know. 14 have the pills. 14 Q. Did the psychiatrist that you saw in 15 A. Yes, in Virginia. 15 Virginia give you any kind of test? 16 Q. Well, you justsp hen did you say you 16 A. Not that — I don't remember. 17 just quit talcing those last week? 17 Q. Now, you, you mentioned when we were 18 A. Like five, yeah, five days ago. 18 speaking about the psychiatrist in West Palm Beach 19 Q. Okay. But the point is the prescription, that you, you have seen a psychologist in Florida? 20 you had not run out of the latest prescription? 21 A. Yes. 21 A. No. 21 Q. And, and who what psychologist did you 22 Q. Okay. And so for what period of time do 22 see? 23 you get a prescription; a month, two months? 23 A. I don't remember their 24. A. No, it's about a month. 24 Q. When was the last time you saw the 25 222ka. So would x a correct 25 psychologist in Florida? 13 (Pages 46 to 49) PROSE COURT REPORTING AGENCY, INC. EFTA01076396 Page 50 Page 52 A. That was when I first got to Florida Well... 1 Q. What kind of physician was that? 2 Q. That would be January of '09? 2 A. Psychologist. 3 A. Give me a second. 3 Ot kticl you said she, I assume you meant 4 Q. Sure. 4 Ms. =, tried to get you an appointment with 5 A. It was probably around March or April. I'm, this psychologist that had seen her son when he was 6 you know, Pm guessing. 6 young? 7 Q. March or April of '09? 7 A. Yes. 8 A. Yes. 8 Q. But you don't know that psychologist's Q. And was this doctor male or female? 9 name? 10 A. He was a male. 10 A. Nope. 11 Q. And I assume he probably still is a male 11 Q. AM did you ever contact that 12 but — 12 psychologist? 13 A. Yeah. 13 A. Yes. 14 Q. Where was his office located? 14 Q. So you placed a phone call, or did you go 15 A. It was in Wellington next to Greenview Shores. 15 see this psychologist? 16 Q. In the Greenview Shores strip center or 16 A. 1 placed a phone call and I saw hint 17 shopping center? 17 Q. Okay. You did both? 18 A. I'm pretty sure, yes. 18 A. Yes. 19 Q. And how did you find this psychologist? 19 Q. All right. So there, tits another 20 A. Actually, my mother-in-law. My husband went 20 physician. And where was this, the psychologist who 21 to a doctor that was really good for him when he was 21 your mother-in-law initially suggested you go see 22 younger, and she tried to get me to see the same doctor 22 who had seen your husband as a youth, where was his 23 he went to. She didn't acce so she referred 23 office located? 24 him, and he accepted 24 A. That was the one I just gave you in Green, at 25 Q. Okay. First, what's your other-in-law's 25 the Greenview Shores. Page 51 Page 53 1 name? 1 Q. Oh, I, I thought you had said, correct me 2 A. (phonetic). 2 if I'm wrong, but I thought you said your 3 Q. How wotldou spell that? 3 mother-in-law had wanted to get you in to see a 4 A. -M you could put. and I 4 psychologist that your husband had gone to in the 5 don't know how to s II her entire — 5 but that that psychologist wouldn't take 6 • =, • 6 • A. Yes. 7 A. Yes. Q. And, and is that your husband's mother? 8 Q. So, that psychologist recommended another 9 A. Yes. 9 psychologist 10 Q. Okay. She lives where? 10 A Which is hint. 11 A. In the Isles of Wellington. 11 Q. The one that you, that, that — when you 12 Q. And is that the name that she goes by now? 12 say this is him, the "him" that you're talking about 13 A. Yes, M. 13 is this psychologist that you saw in Greenville 14 Q. Is she married now? 14 shops? 15 A. Yes. 15 A. Yes. 16 Q. And her husband's last name is = 1 16 Q. All right. But that's not the 17 A. Yes. 17 psychologist that saw your husband when he was 18 Q. And do you know his first name? 18 younger? 19 A. Mervin. 19 A. No, because they didn't accept 20 Q. Okay. So your husband at some time in the 20 Q. What I wanted to know was, did you have a 21. past had seen a physician who he felt did a good job 21 conversation with the psychologist that saw your 22 for him? 22 husband when he was younger? 23 A. Yes. 23 A. No. • 24 Q. Do you know that physician's name? 24 Q. You had no contact with him? C25 A. No. 25 A. No, my mother-in-law did. Vt 14 (Pages 50 to 53) PROSE COURT REPORTING AGENCY, INC. EFTA01076397 Page 54 Page 56 1 Q. Andshetoldyouthat- 1 A. I just told him that I was very depressed and 2 A. She gave me -- 2 I don't feel happy. 3 Q. — as a result of her conversatliiiii 3 Q. And what did you tell him you believe was 4 that psychologist they wouldn't take 4 the cause of your depression? 5 A. Yes. 5 A. My past, things live gone through. Q. And then she provided the name to you to 6 Q. Did — specifically, what did you tell go see this psychologist whose name you don't recall 7 him? :3 in your Greenville shops? 8 A. Me, rve told him about me and my husband. I 9 A. Yes. 9 told him about the situation with Epstein. I told him 10 Q. Okay. Did you ask your mother-in-law to 10 about my parents, my childhood. 11 fmd a psychologist for you in, somewhere around 11 Q. What is it you told him about your parents 12 March or April of '097 12 and your childhood? 13 A. I mentioned it to her, yes. 13 A. We didn't get along sometimes. 14 Q. And how did that come up? 14 Q. Now, when, when you're referring to your 15 A. I was just, Pm very depressed, and she just 15 porous, who are you referring to? 16 mentioned somebody that her son saw that was very good. 16 A. Well, my mother and my stepfather, and my 17 Q. And was that for depression? 17 father and his girlfriend at that time. 18 A. Yes. Forme? 18 Q. And, and when you say, "your mother," 19 Q. Yeah. 19 you're talking about your birth mother? 20 A. Yes. 20 A. Yes. 21 Q. Okay. And, and how many times have you 21 22 23 been to this psychologist near Greenville shops? A. Four to five times. 22 23 A. Q. And where does she now live? 24 Q. And do you go for 45-minute sessions? 24 A. Boca Raton. 25 A. I believe so, yes. 25 Q. And your stepfather is whom that you Page 55 Page 57 1 Q. And did you go once a month, or with what 1 referred.lp? 2 degree of frequency did you go? 2 A. ar Same last name. 3 A. hives once every two weeks. 3 Q. And does he still live with your mom in 4 Q. So, if you went four to five times, you 4 Boca? 5 went for a total of about two months? 5 A. Yes. 6 A. Yeah. 6 Q. Okay. And your — when you refer to your 7 Q. So, that's going to take us until sometime 7 father, are you talking about your birth father? B around June of '09? 8 A. Yes. 9 A. Yes. 9 Q. awavhat is his name? 10 Q. And what was the purpose of you going to 10 A. OM Doe No. 5. 11 that psychologist? Was each visit designed to 11 Q. And where does he live? 12 address your depression? 12 A. He lives in Wellington. 13 A. Yes. 13 Q. And you referred to his girlfriend? 14 Q. Did the psychologist take notes? 14 A. This girlfriend that he has now is not the one 15 A. Yes. 15 that he had in the past that I had problems with. 16 Q. Did the psychologist make any formal 16 Q. Who was the girlfriend you were referring 17 diagnosis? 17 to? 18 A. No. 18 A. (phonetic). 19 Q. Did that psychologist have any work that 19 Q. And was she living with your dad at some 20 he had you do where you had to write things out? 20 point in time when you were having problems with 21 A. No. 21 her? 22 Q. Did he do any testing? 22 A. Yes. 23 A. No. 23 Q. Do you need to take a break? 24 Q. And what did you tell this psychologist 24 A. Yes. 25 about cur depression? 25_ MR. LIMIER: Yeah. if !; 15 (Pages 54 to 57) PROSE COURT REPORTING AGENCY, INC. EFTA01076398 Page 58 Page 60 1 break, just tell me. It appeared to me that 1 A. Yes, I was in South Carolina 2 you were in some kind of distress. 2 Q All right. So would it be a correct 3 THE WITNESS: No, !just -- 3 statement that his physical abuse of you ended when 4 MR. LOTTER: You don't have to wait If 4 you left South Carolina? 5 you want a break, just say. This is no — this 5 A. Yes. 6 isn't, you know, torture chambers. 6 Q. And that would have been while you were in 7 THE WITNESS: Yeah. It feels like it. 7 the eighth grade? 8 THE VIDEOGRAPHER: Off the record. 8 A Yes, the beginning. 9 (A brief recess was held.) 9 Q. And approximately on how many occasions 10 THE VIDEOGRAPHER: We're back on the 10 did he physically abuse you? 11 record at 938 a 11 A It was, it was two to three times he's really 12 BY MR. LUTTIER: 12 hit me. 13 Q. Okay. As to the psychologist, male 13 Q. Okay. And describe those incidents. 14 psychologist in Florida whose office is near 14 Well, let me ask you this, did you describe those 15 Greenville shops — 15 incidents to this psychologist, male psychologist 16 (Interruption at the door by 16 who you saw near the Greenville shops down here? 17 maintenance man.) 17 A. Yes. 18 BY MR. LUTHER: 18 Q. Okay. What, what did you tell him? I 19 Q. You said you told him about your parents, 19 assume you told that psychologist the complete 20 and your childhood. 20 story? 21 A. Yes. 21 A. Yes. 22 Q. And specifically your mom, stepfather, 22 Q. All right. You were truthild to him? 23 father and grandfather. What is it you told him 23 A. Yes. 24 about these members of your family? 24 Q By the way, you've seen a number of 25 A My dad and I had some conflicts verbally, and 25 psychologists strictly related to this lawsuit, have Page 59 Page 61 1 my mom and I also did. 1 you not? 2 Q. And those things were causing you to be 2 A. Strictly related to this lawsuit? 3 depressed, to be depressed, you thought? 3 Q. Um a Dr. You recall him? 4 A. It was some of the reason, yes. 4 A. Yes, yes. 5 Q. And what did you say about your stepfather 5 Q. Okay. You saw a Dr. a 6 and your, and your father's girlfriend? 6 A. Uh-huh, yes. 7 A. My stepfather sometimes was physically 7 Q. With respect to those two individuals, did 8 abusive. 8 you tell them the truth about everything? 9 Q. How often was he physically abusive with 9 A. Yes. 10 you. 10 Q. So if they asked you a question, you gave 11 A It was on rare occasions when he would get 11 them a response, it was a truthful response? 12 really upset. 12 A Yes. 13 Q. Did he, did he hit you more than once? 13 Q. You answered fully and completely any 14 A. Yes. 14 questions that they had? 15 Q. And did all his physical abuse of you, 15 A. Yes. 16 that is, your stepfathers physical abuse of you, 16 Q. Okay. MI right And, likewise, were, 27 occur prior to your completion of the ninth grade? 17 were you truthful with all these psychologists and 18 A. Yes. 18 psychiatrists whose name you've given me for the 19 Q. Did it, did it all occur, did he 19 first — well, whom you've identified for the first 20 physically abuse you on numerous occasions prior to 20 time in today's deposition? 21 your completion of the eighth grade? 21 A. Yes. 22 A. The eighth grade is when I left and moved with 22 MR MERYffiLSTEIN: Objection to form. 23 my father. 23 BY MR. LIMIER: 24 Q. That is you left from — at the time you 24 • • Q. And were you complete in your discussions 25 '; were living with your mother and stepfather? 25 with them, told them everything that, you know, that ••••••••11~ 16 (Pages 58 to 61) PROSE COURT REPORTING AGENCY, INC. (561) 832-750.6 EFTA01076399 Page e-e. Page 64 1 was relevant? 1 A. Yes. 2 A. Yes. 2 Q. Was the scene hysterical? 3 MR. MERMELSTEIN: Form. 3 MR. MERMELSTEN: Objection, asked and 4 BY MR. LUTTIER: 4 answered. 5 Q. Okay. Well, everything — I should say, S BY MR. LUTTIEFt: 6 you told them everything you thought was relevant to 6 Q. That is, was, was everybody that was there 7 the reason why you were there to see them? 7 in hysterics? 8 MR. MERMELSTEIN: FORTE 8 A. Yes. 9 THE WITNESS: Yes. 9 Q. Was your mom there? 10 BY MR. LUTTIER: 10 A. Yes. 11 Q. Okay. Now, tell me about then what is it 11 Q. Your mom has always loved you, right? 12 you told this psychologist, male psychologist here 12 A. Yes. 13 in Florida at the Greenville shops with respect to 13 Q. Was she hysterical? 14 the two to three times that your stepfather 14 A Yes. 15 physically abused you prior to your completion of 15 Q. What was she doing while her husband was 16 the eighth grade? 16 beating you so severely that he ruptured your 17 A. There was one occasion where he got upset 17 eardrum? 18 because I told my friend on the phone that I was, you 18 A. She was trying to push him away. 19 know, I didn't like him. And he came into my room and Q. Trying to protect you? 20 hit me across the face and threw my television down the . 2 1i A. Yes. 21 stairs and just had a bad temper. 21 Q. At that point in time was that the worst 22 Q. Okay. And let me, let me make sure I 22 thing that had ever happened to you in your life? 23 understand this. This is something that occurs when 23 A. That point in time, yeah, that was pretty bad 24 you're, what, 13 years old? 24 for me. 25 A. Yeah, 12, 13. 25 Q. Was it the worst thing that ever happened Page 63 Page 65 1 Q. Okay. AM how old was your stepfather at 1 to you in your life? 2 the time? 2 A. Yes. I was upset, yeah. 3 A. I don't laiow. 3 Q. • You sound like you're hesitant, so I 4 Q. Bigger physically? He was obviously was 4 just ;- 5 bigger than you, right? 5 A. I'm just, I'm just thinking back. 6 A. Yes. 6 Q. I want you to take your time. I want you 7 Q. And he came into your room when you were 7 to think about it. I want to — so, if you need to 8 on the phone? 8 take a minute, is that the worst thing that ever 9 A. Yes. 9 happened to you in your life as of that point in 10 Q. And he literally picked up a TV from your 10 time? 11 room and threw it down the stairs of your home? 11 A. Yes. 12 A. Yes. 12 Q. How did he beat you so as to rupture your 13 Q. Would it be safe to say that you were 13 eardrum? 14 hysterical at that time? 14 A. He hit me across the face. 15 A. Yes. 15 Q. With a closed fist? 16 Q. You were crying? 16 A. I don't recall. It was very fast. I don't 17 A Yes. 17 'mow. 18 Q. You were scared? 18 Q. Still have the phone in your hand? 19 A. Yes. 19 A. The phone? 20 Q. He then did physical violence to you? 20 Q. Did you still have the phone that you were 21 A. Yes. 21 on in your hand? 22 Q. Asa matter of fact, he beat you so badly 22 A. No, he ripped it out of my hand. 23 that he ruptured your eardrum, didn't he? 23 Q. That's the first thing he did, right, he 24 A. Yes. 24 came up and tore the phone? 25 Q. Did you fear him when he was doing that? 25 A. Yes. 17 (Pages 62 to 65) PROSE COURT REPORTING AGENCY, INC. EFTA01076400 Page 66 Page 68 Q. Did he tear up your room? 1 haunts you today, doesn't it? 2 A. He ripped the phone out of my hand, ripped it 2 MR. MERMELSTEIN: Objection to form. 3 out of the wall, took the TV, threw it down the stairs 3 THE WITNESS: Yes. 4 and hit me. 4 BY MR. LUTTIER: 5 Q. Ripped the phone out of the wall so you 5 Q. And that's when you've gone to all these 6 couldn't call for help? 6 psychologists and psychiatrists and you've talked A. He ripped it out of the wall probably because 7 about your past you have always mentioned this 3 I was on the phone with my friend telling them how I 8 incident, have you not? 9 didn't like him. 9 A. Yes. 10 Q. And do you recall why you were telling 10 Q. And it gives you concern, one of the 11 your friend that you didn't like this fellow that 11 things you worry about in life is whether anybody 12 just beat you? 12 would do anything like that to your little daughter, 13 A. As of why I was saying it? 13 isn't it? 14 Q. Yeah. 14 A. Yes. 15 A. He was just very strict. 15 Q. You're very vigilant about making sure 16 Q. Had he prior to this occasion when he 16 nobody hurts your daughter. 17 beat you so badly that he ruptured your eardrum, had 17 A. Yes. 18 he hit you before? 18 Q. And you're acutely aware of domestic 19 A. Not as bad as that. That was the, the worst. 19 violence? 20 Q. Was there, when he ruptured your eardrum, 20 A. Yes. 21 was there any blood? 21 Q. Other than that, when you went back to — 22 A. No. 22 when you went to South Carolina with him, and he 23 Q. Did you go to a physician and seek medical 23 drew things at you, other than the tub of butter, 24 care? 24 did he throw anything else at you? 25 A. Yes. 25 A. Not that I recall. He was, he, he would Page 67 Page 69 1 Q. Were you still scared even after the 1 always lose his temper. 2 incident happened? 2 Q. When you're when he beat you on that 3 A. I was scared that he had a bad temper and it 3 occasion and he ruptured your eardrum, was your 4 could happen again. It never happened again, to that 4 mother finally able to get him to stop? 5 extent again. 5 A. She told me that she would leave him if I 6 Q. But he did hit you again, didn't he? 6 Q. !mean when the incident was happening and 7 A. Yes. 7 you were there, she was present watching it, was she 8 Q. When did he next hit you? 8 not? 9 A. The instance I just gave you was in Fort 9 A. Yes. 10 Lauderdale. 10 Q. How did what caused him to stop beating 11 Q. Okay. 11 you? 12 A. And then when I moved to South Carolina, ifs 12 A. He calmed down and realized what he was doing 13 not that he hit me, but he would, like, throw things at 13 and my mom stepped in. 14 me. 14 Q. Did she, did she then come over and, and 15 Q. Did he ever hit you with anything when he 15 console you? 16 threw it at you? 16 A. Yes. 17 A. He threw a tub of butter at me in South 17 Q. Did you feel that your mother was 18 Carolina. 18 partially responsible for that action? 19 Q. But the incident where he beat you and 19 A. For that specific act that day that he did 20 your eardrum was punctured, that happened while you 20 that? 21 were in the eighth grade, right? 21 Q. Yeah. 22 A. It was the seventh or the eighth grade, 22 A. No, no. 23 because I was in Fort Lauderdale going to middle school 23 Q. How about for the fact that she had him 24 there. 24 aroma( and you were exposed to him and he had been 25 Q. Asa matter of fact, that incident still 25 conducting himself like that towards you? 18 (Pages 66 to 69) PROSE COURT REPORTING AGENCY, INC. EFTA01076401 Page 70 Page 72 1 A. Ina way, yes. Like you say, I held her 1 MR. MERMELSTEIN: Objection, form. 2 responsible for yes. 2 THE WITNESS: He told me that I was 3 Q. I mean, this stepfather treated you poorly 3 *Sage. 4 for as long as you can remember, did he not? 4 BY MR. LUTTIER: 5. A. Not any — 5 Q. And how did that make you feel? 6 MR. MERMELSTEIN: Objection to form. 6 A. Like crap. 7 THE WITNESS: Not anymore. Q. And that still bothers you too, doesn't 8 BY MR. LUITIER: 8 it? 9' Q. Well, not now, but back when you were -- 9 A. Yeah. 10 you, you lived with your mother and your stepfather, 10 Q. And do you tcunwber when he did that? 11 this fellow -- 11 A. When he did what? 12 A. Yeah. 12 Q. When he told you you were baggage. 13 Q. -- for a period of time, did you not? 13 A. He told me that recently when I was living 14 A. Yeah. 14 there. 15 Q. — and do you recall about when that was? 15 Q. Recently meaning when? 16 You can use your age; how old you were. 16 k When I was — after high school. He was 17 A. Yeah. They got together when I was three 17 apologizing for the way he acted, and basically just 18 years old. 18 said that back in the day he thought of me as baggage. 19 Q. Okay. And they, and you lived with them 19 Q. And do you recall him telling you back 20 until you came back to, to West Palm when you were 20 then that you were — that he thought you were 21 finishing up the eighth grade? 21 baggage? 22 A. Yes. 22 A. No. 23 Q. So that's when you were, what, 13 years 23 Q. Did he tell you back when you were living 24 old? 24 with him for the ten-year period that, that, that 25 A. Yeah. 25 you were sort of an inconvenience to him? Page 71 Page '73 Q. All right. So you've got years that you 1 A. No, but I could see it through his actions. 2 lived with your mother and, and this stepfather 2 Q. Do you recall other incidents where he 3 l=? 3 physically abused you? 4 A. He — in, in the beginning he didn't live with 4 A. I don't remember, like exactly,' just haw he 5 us, but he was over a lot. 5 lost his termer a lot. I don't remember specific — 6 Q. And during that ten-year period, he not 6 Q. And when he lost his temper he would 7 only physically abused you, but he verbally abused 7 strike you? 8 you, did he not? 8 A. Not just that, but he would, you 'mow, 9 A. Yes. 9 sometimes it would just be like he would throw things 10 Q. What kinds of things did he tell you? 10 or, you know, run out of the house pissed off and 11 A. He would just ten me to shut the F up, and 11 whatever, have his tantnam. 12 that I was stupid and immature and mean. 12 Q. AM these are still events that -- what 13 Q. Did, did that make — did he demean you? 13 are you, 22 years old now? 14 A. Make me feel like — 14 A. Twenty-three. 15 Q. Lice little. 15 Q. These are events that still -- 16 A. Yeah. 16 A. They're upsetting. 17 Q. Make you feel like you weren't a good 17 Q. — that you recall? And, and although you 18 person? 18 love your mother, do you hold her responsible for, 19 A. Yes. 19 for you being subjected to that kind of conduct for 20 Q. And did you resent that with your mother 20 a ten-year period? 21 that she would allow her boyfriend or her, her 21 MR. MERMELST'EIN: Objection, asked and 22 husband to treat you that way? 22 answered twice already. 23 A. Yeah. 23 THE WITNESS: Yes. 24 Q. Did he, did he ever tell you where you fit 24 BY MR. LUTHER: 25 into his view of the world? 25 .9 d u ten _E .1.4d em is ychologjst in 19 (Pages 70 to 73) PROSE COURT REPORTING AGENCY, INC. EFTA01076402 Page 74 Page r 1 Florida that you saw over by Greenville shops about 1 tumble? 2 all these instances? 2 A. She just said just don't tell him that, hit 3 A. Yes, I've — I didn't tell him about, you 3 you. 4 know, the butter and everything, but I told him about 4 Q. Is that something that you regret having 5 the eardrum. 5 done up through today? 6 Q. Okay. What did you, what did you tell 6 A. Ina way. !just try to, you know, it was in 7 him? Did you tell him anything else specifically, the past and he's apologized for it, so... 8 that is this psychologist in Florida, specifically 8 Q. Did you how do you feel towards your 9 about your stepfather other than what you've told us 9 mother now that you're older about her having even 10 thus far? 10 asked you to go tell a doctor something that wasn't 11 A. Not that I recall. 11 true about you being abused by her husband? 12 Q. Okay. 12 A. I'm sorry. What did you say? 13 A. About my stepfather -- 13 Q. It was a bad question. 14 Q. Yeah. 14 How does it make you feel now knowing 15 A. — only? Yeah, not that I recall, just that 15 that your mom asked you to go lie to a doctor to 16 he had a bad temper and with the eardrum situation. 16 cover for her husband when, when — 17 Q. Is your — can you hear all right today? 17 A. Now, or at that point in time? 18 A. Yeah. 18 Q. How does it make you feel now? 19 Q. Now, you, you told the psychologist here 19 A. It's upsetting. It hurts my feelings. 20 in Florida that you had some verbal conflict with 20 Q. How did it make you feel then? 21 your mother as well. 21 A. I — you know, I was young. I didn't, that 22 A. Uh-huh, yes. 22 didn't really — I don't remember what I felt at that 23 Q. And what did you tell the psychologist 23 point 24 here in Florida when you went to see him about 24 Q. Mir, as you sit here today, if that 25 conflict with your mother? 25 happened to your daughter, God forbid if she had a Page 75 Page 77 1 A. I had conflicts with my mother because of my 1 similar thing happen to you, would you do the same 2 stepfather. 2 thing your mom did? 3 Q. And, and what was the nature of that A. No. 4 conflict? Q. Okay. You, you, you said that you told 5 A. Just that I wanted her to leave him. 5 your mom that you wanted her to leave your 6 Q. And did you ever tell her that? 6 stepfather and I assume that she declined to do 7 A. Yes. 7 . that? 8 Q. And do you remember when you first told A. Yes. 9 her that? 9 Q. That caused resentment between the two of 10 A. No. 10 you? 11 Q. Do you know approximately when it was, how 11 A. Yes. 12 old you were? 12 Q. Has that been a source of conflict between 13 A. No, because she asked me if I fluted her to 13 the two of you ever since? 14 leave him when he hit me and I said no. 14 A. To, today, I don't care, because I have my own 15 Q. By the way, when, when he hit you and you 15 family and life. But back when, you know, I was still 16 went to see the doctor for medical cares did you, 16 like around the situations, it bothered me. 17 did you lie to the doctor about how you got the 17 Q. Any other conflict that you had with your 18 injury? 18 mom other than you, you asked, you asked her to 19 A. Yes. 19 leave her husband and she declined to do so? 20, Q. And why did you do that? 20 A. Ion sorry. What did you say? 21 A. So he didn't get in trouble. 21 Q. Any other conflict that you had with your 22 Q. Did your mom encourage you to do that? 22 mom? 23 A. Yes. 23 A. There was one instance when we were in 24 Q. Did she tell you basically that if you 24 Chicago. 25 told the truth that, that her husband would get in 25 Q. And that's when you were about how old? 20 (Pages 74 to 77) PROSE COURT REPORTING AGENCY, INC. EFTA01076403 Page 78 Page 80 A. It was, I think it was beginning of middle 1 BY MIL LUTTIER: school, around that time. I don't know the exact time 2 Q. Okay. Anyway, all right. So you had gone 3 frame. 3 to, you lived with your mom and your step dad down 4 Q. Before you finished the eighth grade? 4 in Fort Lauderdale. They moved with you to South A. Yes. 5 Carolina. Q. Okay. What happened in Chicago? 6 A. Yes. A. She actually split up with my stepfather and 7 Q. But you only were in South Carolina for a 3 was dating another guy. And I walked next to the street 8 number of months. 9 in Chicago and she got upset and hit me in the bathroom. 9 A. Yes. 10 Q. I assume that upset you at the time? 10 Q. You enrolled in a school up there in the 11 A. Yes. 11 eighth grade. 12 Q. Still upsets you? 12 A. Uh-huh. 13 A. It does, but... 13 Q. That's a yes? 14 Q. You wouldn't hit your daughter? 14 A. Yes. 15 A. I don't, no, I don't like to hit. 15 Q. Then you came back to Florida and you 16 Q. Still an event that when you watt to the 16 moved in with your dad, your birth dad? 17 psychologist you told him about it? 17 A. Yes. 18 A. Yeah. 18 Q. And you stayed with your birth dad from 19 Q. Because it was upsetting to you? 19 the time that you were finishing up, up eighth grade 20 A. Yeah. 20 until when? 21. Q. Still upsetting to you? 21 A. Eighteen. 22 A. Yeah. 22 Q. Did you have contact with your mom after 23 Q. Okay. Any other conflict that you've had 23 you moved back to Florida when you were in the 24 with your mom? 24 latter part of the eighth grade? 25 A. Just differences in life. 25 A. Yes. Page 79 Page 81 1 Q. Do you believe your mom, as you sit her 1 • Q. And what kind of contact did you have with 2 today, let you down as a, as a child? 2 heel 3 MR. MERMELSTEN: Form. 3 A. Phone. 4 THE WITNESS: There were things that she 4 Q. Is that - 5 did that I didn't like. 5 A. And I saw her in summers. 6 BY MR. LIMITER: 6 Q. Is that the only time you saw her? 7 Q. Like what, besides not leaving her 7 A. Yes. 8 husband? 8 Q. And where did mom live from the time that 9 A. Just that I was her first kid and she didn't you finished up the eighth grade down here in, in 10 really know how to raise me. 10 Wellington until your 18th birthday? 11 Q. Now, you said that you came back to 11 A. She stayed in South Carolina and then she 12 Florida to live with your dad. 12 moved back to Florida probably, my, I'm going to say my 13 A. Yes. 13 junior year. 14 Q. Was it January of '07, somewhere around 14 Q. That would be 2003? 15 there? 15 A. Yes, I think so. 16 A. It was 16 Q. And when you say she came back to Florida, 17 Q. forgot. 17 did she come back to Florida with her, your step 18 A. — in the eighth grade. 18 dad? 19 Q. Okay. Lets see — 19 A. Yes. 20 MR MERMELSTEIN: Did you say '07? 20 Q. And where did they come when they came 21 MR. LUTTMR: Yeah, let me see. I don't 21 back to Florida? 22 want to mess up the record. 22 A. They went back, they went to Boca. 23 MR. MERMEISTEIN: '07 she was 21. 23 Q. Is that where they live now? 24 MR. LUTHER: It wasn't in '07. 24 A. They lived in a temporary house until the 25 THE WITNESS: No. 25 other house sa was rdelSe.kniBec Adihtetla.... ..I.axaratsaaeo 21 (Pages 78 to 81) PROSE COURT REPORTING AGENCY, INC. EFTA01076404 Page 82 Page 84 Q. Okay. Is the house that they live in now 1 lawyer. 2 the one that they moved into after they were in the 2 MR. LUITIER: Yeah, don't Just a yes or 3 temporary house? 3 no, but don't tell, I don't want to know -- A. Yes. 4 THE WITNESS: I'm sorry. Q. Okay. So they've lived there continuously 5 MR. LUTITER: About the substance of your since about 2003 when they returned to Florida? 6 conversation. A. Yes. 7 THE WITNESS: All right. 3 Q. And up until 2003, you would see your mom 8 MR. LUITIER: One of the reasons why Pm 9 in the summers? 9 asking you this is we have these 10 A. Yes. 10 interrogatories where we ask you information, 11 Q. All right. Did there oome a time before 11 and, and had I known who these doctors were, I 12 your mom came back in 2003 that your mom took you to 12 would have had their records beforehand, and 13 see a psychologist or a psychiatrist? 13 would be able to ask you about information 14 A. She took me to see a psychologist 14 based on the records. And in our rules there 15 Q. Okay. So would you look at the answers to 15 is a duty to continue to disclose these people. 16 imerrogatories and tell me — I will show you again 16 And I, just for the record, Stuart, you 17 Interrogatory 8, and tell me which physician your 17 know, I've got, Pm up to six that I don't know 18 mom took you to see. 18 anything about, otherwise I would have these 19 A. I don't think it's in here because I didn't 19 records. And I think there's that duty to 20 remember at this time, but I have his name and where he 20 disclose. And I know we are under some time 21 is. 21 things. I'm trying to — I was going to try to 22 Q. Where do you have his name? 22 get it done, but... 23 A. 1 in my mind I know his name. 23 MR. MERMELSTEIN: I, I understand that, 24 Q. O*t ,.= Well, what's his name? 24 and I realized when you were going through with 25 A 25 it in the first hour. Page 83 Page 85 Q. a 1. MR. LUITIER: Okay. 2 A. Yes, I'm pretty sure. 2 MR. MERMELSTEIN: I don't I don't know if 3 Q. And, and when did you go to see 3 it's six or not. I wasn't — 4 Dr. Milln 4 MR. LUTTIER: Yeah. 5 A. 11, it was a trip I took with my mother. She 5 MR. MERMELSTEIN: — counting to that 6 was still living in South Carolina. I don't recall 6 extent, but yeah, I am aware that there are 7 exactly when it was. 7 psychological professionals, health care 8 Q. Well, it had to be before 2003, right? 8 professionals that need to be disclosed. 9 A. Yes. 9 MR LUFTIER: Yeah, because I tried to 10 Q. And, what do you mean, it was a trip you 10 get -- the idea was to get -- I subpoenaed all 11 took with your mom? 11 the records that I knew to try, so that I would 12 A. She went to go see him in Memphis, Tennessee. 12 have them here so that I could go through this. 13 and she wanted me to go with her. 13 And Pm now going to have to obviously get 14 Q. Now, this — how, how is it that you 14 those records, and I may have to still do some 15 recall this physician's name who you saw sometime 15 other stuff. Okay. 16 before 2003, and you know his name but you don't 16 MR. MERMELSTEIN: I understand. 17 know the names of these other physicians that you've 17 BY MR. LUITIER: 18 seen since then? 18 Q. All right. Let me go back to Dr. =. 19 A. Because I found his book the other day in my 19 Okay. So, you say you recently found aWof his 20 house. 20 in your house? 21 Q. Have you provided his name to your lawyer? 21 A. Yes. 22 A. Actually, yesterday. 22 Q. When you say "your house," what house are 23 Q. Is there 23 you referring to? 24 MR. MERMELSTEIN: Don't talk about 24 A. Oh, Virginia. 25 anything else you've discussed with your 25 • Q. Okay. Do you — is that a book that you 22 (Pages 82 to 85) PROSE COURT REPORTING AGENCY, INC. EFTA01076405 Page Page 88 1 had or you read? 1 conversation with your dad about the fact that you 2 A. Yeah, he gave me a book when I went to sec 2 were going there? 3 him. 3 A. I'm sure — I don't remember that, but I'm 4 Q. So, this is a book you got back in 4 sure I told him where I was going. 5 sometime before '03? 5 Q. Did you know why you were going? 6 A. Yes, whenever I saw him. 6 A. She told me it was she wanted me to, you know, 7 Q. And what's the name of the book? 7 see somebody and talk to somebody. 8 A. I don't recall the books name. I just 8 Q. What about? 9 remember his name. 9 A. To help me. 10 Q. What's it about? 10 Q. Help you about what? 11 A. Stories that he's been through with his 11 A. Because I was depressed. 12 clients and how they recovered and... 12 Q. And when you say you were depressed, is 13 Q. Well, what kind ofdoctor is he? 13 that, is that a diagnosis that someone had made of 14 A. He was a psychologist, I think. 14 you St that time? 15 Q. Does he have some specialty or particular 15 A. No. 16 kinds of patients that he sees? 16 Q. Or just you were -- a description ofhow 17 A. I don't know. 17 you felt? 18 Q. For example, some people will specialize 18 A. Description ofhow I felt. 19 in, let's say, alcohol addiction, and they might 19 Q. And your mom had sensed that she also was 20 write a book about their clients and they're all 20 of the opinion you were depressed at the time? 21 clients that were alcoholics. And they talk about 21 MR. MERMELSTF_IN: Objection to form. 22 their story and stuff like that 22 THE WITNESS: She just thought I was, you 23 You mentioned that his book was 23 know, that I needed to talk to somebody. L.. 24 stories about clients that he had. Is there some 24 BY MR. LIJTTIER: 25 similarity among his clients, they arc all there for 25 Q. Were you doing anything or engaging in any Page 87 Page 89 1 the same reason or something? 1 kind of conduct that caused ha concern at that 2 A. No it was all different. 2 time? 3 Q. Okay. Now, you said your mother was going 3 A. Not that I milletulna. 4 to see this person in Memphis. Was she going to see 4 Q. Had she said to you that you had changed 5 Dr. on her own for some reason for her, or was 5 in any manner in your relationship with her or 6 it just somebody she picked that she wanted to take 6 someone else that caused her to think that you were, 7 you to? 7 you needed to see this person? 8 A. No, it was somebody that she was going to. A. I don't, I don't, I don't remember. It was, I 9 Q. Do you know why your mom was going to see 9 don't think so. I mean, I don't —ljustIcnow she 10 this person? 10 wanted me to go see this person. 11 A. No. 11 Q. Had she said to you anything like, you 12 Q. And was this — this would have been 12 know, we used to be close and now you're a different 13 during the summertime, I assume, if it's your mom 13 person, and I think you need to see somebody? 14 and you taking a trip? 14 A. She saw changes in me. 15 A. Fm pretty sure, sunvner or spring break. I 15 Q. What kind ofchanges did she say she saw 16 don't recall exactly when. 16 in you? 17 Q. And you were living at the time with your 17 A. Because I used to be very, like, close to her. 18 dad, your birth dad in Florida? 18 Q. Okay. 19 A. Yes. 19 A. And I would always be home when I said I would 20 Q. Did he know that mom was going to take you 20 be home. And, you know, when I went and saw her 1would 21 to this -- 21 go do my own thing and basically not, you know, abide by 22 A. Yes. 22 her rules. 23 Q. Did you-all discuss that before you went? 23 Q. Now, when you say you went and saw her, 24 A. No. 24 you mean when you went to — 25 Q. Did, do you remember, having any 25 A. South Carolina. 23 (Pages to 89) PROSE COURT REPORTING AGENCY, INC. EFTA01076406 Page 9 Page 92 1 Q. — South Carolina? Q. Okay. How else could you describe what 2 A. Yes. your relationship with your dad, your natural 3 Q. And were you — when you, the phrase you 3 father, was at the time that your mom decided that 4 used, you would do your own thing, what do you mean 4 she wanted you to go see Dr. M? 5 by that? 5 A. We didn't really have a relationship anymore A. One time, for instance, I went with one of my 6 after a while. 7 old friends there. I went on a ride on a golf cart, and 7 Q. Okay. After how long? a 1 was out fora while, and she wasn't used tome, you 8 A. Probably after a year or two of me being 9 know, not calling her, telling her where I was, and I 9 there. 10 just wasn't, you know, being close to her. I wasn't 10 Q. And that is you had no relationship with 11 telling her things. I was just doing what I wanted. 11 your dad? 12 Q. And at, at, at the time, what was 12 A. No, we weren't close — 13 happening to you in school? 13 Q. Okay. 14 A. School-wise, like grades or 14 A. --after that. 15 Q. Like were you attending school regularly? 15 Q. So you, you had come from South Carolina 16 A. I think at that time I was. 16 where you, you left your mom and your step dad with 17 Q. Had you started skipping school? 17 whom you lived for ten years. 18 A. I did start skipping school my senior year. 18 A. Uh-huh. 19 Q. So you didn't start skipping school until 19 Q. Right? You came down and you began living 20 your senior year? 20 with your dad with whom you hadn't lived for ten 21 A. I did a little bit in my junior year, but my 21 years since you were three years old. 22 senior year was my worst. 22 A. Yes. 23 Q. And were you, were you doing similar 23 Q. Do you recall during the ten-year period 24 things down here while you were living with your 24 that you lived with your mom from three to 13 25 dad? 25 whether you had contact with your dad? Page 9: Page 93 A. Yes. 1 A. Yes. 2 Q. That is, what kinds of conduct were you 2 Q. Would you go visit him on weekends and 3 engaging with him at the same time that your mom was 3 things like that? 4 observing that you were not as close to her and you 4 A. When we were living in Florida, yes. 5 wore doing your own thing? 5 Q. Okay. So, you came back. You lived with 6 A. 1 would just be going out all the time, 6 your dad, not having been there for ten years, it 7 drinking, tried drugs, stay out. 7 was weird. And then after a year or so you had 8 Q. And at that time; that is when your mom 8 really no relationship with him? 9 was encouraging you to go with her to see Dr. In 9 MR. MERMEISTE1N: Form. 10 what was your relationship with your birth father 10 THE WITNESS: Yeah. 11 with whom you were then living primarily like? 11 BY MR. LUTHER: 12 A. in the beginning it was weird. 12 Q. Now, you mentioned when you went to see 13 Q. When you say, win the beginning," what do 13 this psychologist here in Florida over at the 14 you mean? 14 Greenville shops — 15 A. When 1 first moved with him in eighth grade. 15 A. Uh-huh. 16 Q. Okay. So that's, what did we decide that 16 Q. -- that you told him about conflicts you 17 was, 13? 17 had with your dad. Do you recall that testimony? 18 A. Yeah, 12, 13. 18 A. Yes. 19 Q Okay. So, 12 or 13 when you moved back 19 Q. Okay. So, was this, this situation that 20 down here, it was you say weird, what do you mean by 20 existed between you and your dad after you came back 21 that? 21 from South Carolina part of the conflict that you 22 A. Just, I've never — you know, I don't remember 22 discussed with him? 23 living with him when I was, you know, under the age of 23 A. Yes. 24 three years old, and It was just awkward. I was used to 24 Q. Okay. So, so what kind of conflict were 25 being with my mom. 25 you having with your father at the time that your 24 (Pages 90 to 93) PROSE COURT REPORTING AGENCY, INC. EFTA01076407 Page 94 Page 96 1 mom had decided that it would be good for you to go 1 And he would just, you know, say nasty things and... 2 see Dr. a? 2 Q. Okay. Tell, tell me what nasty things he 3 A. He just, he didn't approve of the things 1 was 3 said. 4 doing. He didn't understand why I started failing out 4 A. He would tell me I would amount to nothing in 5 of school and not doing good, and basically he would 5 life, that I was a lazy fat pig, just things like that. 6 just verbally abuse me. 6 Q. What's the worst thing he ever said to 7 Q. So, was that, was that conduct that 7 you? 8 your — and the relationship you had with your 8 A. Probably, you know, the lazy fat pig; I'm 9 father part of what was contributing to the, what 9 going to amount to nothing. That's why Pm recalling 10 you described as the depression that caused our mom 10 that. That's why I remember that because that's one of 11 to say that she wanted you to go see Dr. MM? 11 the things that really hurt me. 12 MR. MERMELSTEIN: Form. 12 Q. Were those comments made to you before you 13 MR. LUTHER: Let me rephrase the 13 went to see Dr. M? 14 question. 14 A. 1,1don't, I don't recall. 1 don't know. I 15 BY MR. LUTHER: 15 don't recall. 16 Q. Was the, the conflict that you were having 16 Q. Do you know when those comments were made 17 with your dad, which you just described, 17 to you? 18 contributing to what you described as depression 18 A. When I was living with him in high school at 19 that you had the summer that your mom took you to 19 some point. I,1 think — I don't know. I can't 20 see Dr... 20 remember. 21 MR. MERMELSTE1N: Form. 21. Q. Were these comments that he made to you 22 THE WITNESS: Was sane of the conflict? 22 comments he made often? 23 BY MR. LUTHER: 23 A. I didn't see him that often. He was, he was 24 Q. Yeah. 24 at work a lot. He worked a lot. He worked six days a 25 A. He was 25 week. In the morning he was gone, and he wouldn't get Page 95 Page 97 Q. Okay. And — 1 home at night until like 6 or 8:00. It was, he was just A. Yeah, some of it. 2 never home a lot. We didn't have a relationship, and 3 Q. And you said he didn't understand when you 3 Pm sorry, I forgot your question, 4 were, your grades were going down? 4 the corset question, what it was. 5 A. Yeah. 5 Q. Well, when you, when you lust came down 6 Q. And, and tell me a little bit about what 6 front South Carolina and began living with him, who 7 was happening with your grades. You were in the 7 was in the household beside you and he? 8 eighth grade when you first came down? 8 A. When I first carne down, it wet just him, my 9 A. Yeah, I was fine, you know, eighth, ninth, 9 brother, and myself. .0 tenth grade. 1 started — I'm not 100 percent sure when 10 Q. aM ur brother, what's his name? 11 my grades started going down, but if you look at, you 11 A. =. Doe No. 5. 12 know, my scores and stuff, you could just see that 1 12 Q. And how old was =I? 13 went downhill — 13 A. When I moved there, I'm not sure. 14 Q. Okay. So — 14 Q. How old is he now? 15 A. in high school. 15 A. He's, he's 17. 16 Q. — your grades hadn't necessarily gone 16 Q. Okay. So he's, he's about six years or 17 down at the point in time you went to see Dr... 17 five years younger than you? 18 A. I don't recall. 18 A. Yeah. Yes. 19 Q. Okay. All right. What other conflict 19 Q. Okay. There was just the three of you. 21 with your dad did you have that you described to 20 And then did there come a time that someone else 21 this psychologist that you saw in Wellington? 21 joined the household? 22 A. My dal and I, he just, he would — you know, 22 A. Yes. 23 he would — he was never an affectionate person, and he 23 Q. Who was that? 24 just would say things out of being anger, you know, 24 A. 25 being angry and angered at the situation that happened. 25 Q And about when was that? 25 (Pages 94 to 97) PROSE COURT REPORTING AGENCY, INC. EFTA01076408 Page 98 Page 100 1 A. Probably my sophomore year. 1 you aslut? 2 Q. And did you and get 2 A. Probably my junior year. But it... 3 along when she moved in? 3 Q. "But it," what? 4 A. When she rust moved in, yes. 4 A. I was just going to say, but it wasn't like 5 ..And for how long did you and 5 you are a slut. It was just in one of his letters he get along? 6 left on my bed calling me, you know, a slut, pig, you 7 A. Probably maybe six months to a year. maybe. T know, whatever. 9 Q. Did there come a time that the 8 Q. And why is it that you relate that to your 9 relationship between you and began 9 junior year? 10 to sour? 10 A. Because that's when I recall that that's -- 13. A. Yes. 11 that's — I don't know why. I'm pretty sure it was my 12 Q. When was that? 12 junior year. 13 A. When she just decided to tell my dad all these 13 Q. Is there some event that you recall? 14 negative things about me. 14 A. I !mow it was in my the reason I say that 15 Q. And what did she tell your dad about you? 15 is because it was in my dad's recent house, which was 16 A. I don't know the specifics. !just heard that 16 junior-senior year. I was living them. 17 she was talking about me to my father, my brother told 17 Q. And which house was that? 18 me, negatively. 18 A. The house in Olympia. 19 Q. What, what did he tell you that 19 Q. Now, you, you say he left some letter for 20 told your dad? 20 you on your bed? 21 A. That she was just talking bad about me. That 21 A. Yes. 22 I should, you know, go away to boot camp and things like 22 Q. Do you still have the letter? 23 that. 23 A. No. I threw it out when I saw it. 24 Q. Well, I want you to give me -- 24 Q. So this, this would have been a bed that 25 A. I don't 25 you had at the house in Olympia? Page 99 Page it _ Q. - as much specifics as can about what 1 A. Yes. 2 your brother told you that was telling your 2 Q. You have your own room there? 3 dad. 3 A. Yes. 4 A. There was no — there was nothing he told me 4 Q. Okay. And, and why did your dad leave you 5 that she specifically said besides that she, she thought 5 a letter on your bed? 6 I should be sent away to school because I was a bad 6 A. Because I didn't clean my room and he wasn't 7 child. He wouldn't tell me anything else because he 7 home. 8 said he didn't remember. 8 Q. And, and what did this letter say? 9 Q. And do you recall when that, you were told 9 A. He just called me a you need to clean your 10 that that conversation happened? 10 F-ing room; you're flunking out of school, you pig, 11 A. 'think that was, I'm guessing, probably my 11 slut, or whatever he called me..1don't remember the 12 junior year, maybe. 12 exact letter. 13 Q. Did — were there other things that your 13 Q. Well, how did you react when you saw a 14 dad called you, derogatory names? 14 letter such as that written to you by your own dad? 15 A. There's things that, I mean, right now I 15 A. It was hurtful. 16 don't, I don't remember anything else. 16 Q. Make you ay? 17 Q. Did he ever call you any derogatory names 17 A. I don't know. 18 that had sexual connotations sort of associated with 18 Q. Upset you? 19 them? 19 A. It upset me. 21 A. I'm sorry. What? 20 Q. Had you done something that you thought 21 Q. You know, a name that might really be 21 warranted him characterizing you in this manner? 22 intended to reflect upon sexual conduct that you may 22 A. No, he just — whenever he got mad at somebody 23 engage in or not engage in? 23 including my brother, he's would just say any — he's 24 A. He called me a slut at one point. 24. called my brother a fagot for no reason. It's just 25 Q. Do you remember when your father called 25 names that he throws out there. 26 (Pages 98 to 101) PROSE COURT REPORTING AGENCY, INC. . EFTA01076409 Page 102 Page a 1 Q. Why — do you know why he was calling you 1 Q. So you never knew why? 2 a slut? 2 A. Why she was going? 3 A. No, it's just that's my father. He'll say 3 Q. Yes. 4 anything that sounds nasty. 4 A. For herself? 5 Q. And he said you were flunking out of 5 Q. Right. 6 school. Were you, in fact, did you get bad grades? 6 A. No. 7 A. I was, I was doing bad. 7 Q. But the idea was she, she told you she was 8 Q. Had he left written messages to you on 8 going to go and she wanted to take you as well? 9 other occasions? 9 A. Yes. 10 A. Written? Not that I recall. 10 Q. So you would both be seeing Dr. M' 11 Q. Had he, had he given other messages to you 11 A. We both she went previously, I guess for 12 other than in writing on other occasions? 12 herself. I don't know what the reason was. And then 13 A. On my phone. 13 she thought he was a good doctor to see, so she brought 14 Q. What kind of messages? 14 me with her. 15 A. Lae, just voicemail messages. 15 Q. Okay. So your mom, before she suggested 16 Q. What kind of voicemail messages would he 16 to you to go seeMI had, herself, seen Dr... 17 leave? 17 A. Yes. 18 A. Get your ass home. 18 Q. On the occasion that she said that she 19 Q. That's how he would that's the kind of 19 wanted to take you to see Dr. a she was going 20 message aleave to you? 20 to go see him for what would ve een her second 21 A. Uh-huh. Yes. 21 visit? 22 Q. I mean, is that, is that — in, in your 22 A. Yes. 23 view of the world, is that the way a father should 23 Q. And you don't know why she went for either 24 be treating his daughter? 24 visit? 25 A. No. 25 A With my visit, I know it was pertaining to me, Page 103 Page 105 1 MR. MERMELSTEIN: Form. 1 and she would talk about our relationship. 2 BY MR. LIMIER: 2 Q. All right. So, was her suggestion to you 3 Q. How did it make you feel when your dad 3 that you and she go together to see Dr. =7 4 would leave you messages like that? 4 A. Yes. 5 A. I would be angry. 5 Q. Okay. So the purpose of her going to 6 Q. And how did you act out that anger? 6 Dr. on the occasion that she suggested the two 7 A. I would just ignore him. 7 of you go was about your relationship with her? 8 Q. Would that cause conflict between you and 8 A. Yes. 9 him? 9 Q. And did you, in fact, go see Dr. Mr) 10 A. No, it was better that way. 10 A. Yes. 11 .Anything else that IN leave, messages 11 Q. Where is Dr. IMIS 12 that El leave for you on your voicemail? 12 A. In Memphis, irnessee. 13 A. That I would be grounded. I mean... 13 MR. LUTTIER: Okay. I'm going to need to 14 Q. Okay. Was there, there anything else that 14 take a break myself right now. Too much 15 you know of that caused your mom to sot that 15 coffee. 16 she thought you should go see this Dr. Ell? 16 THE VIDEOGRAPHER: Going off the record at 17 A. No, not that I recall. 17 10:27E. 18 Q. Did aavith her that you should go 18 (A Ref recess was held.) 19 see this Dr. 19 MR. LUTHER: We're back on the record at 20 A. I don't remember if I agreed with her or if, 20 10:38 pmER. 21 or if I disagreed with her. I don't — honestly, I 21 BY MR. • 22 don't remember. 22 Q. Okay. So, so did you eventually go with 23 Q. And did she ever tell you why she was 23 your morn to see Dr. I.? 24 going to see Dr. =7 24 A. Yes. 25 A. No. 25 Q. And for what -- do you remember what year 27 (Pages 102 to 105) PROSE COURT REPORTING AGENCY, INC. EFTA01076410 Page 106 Page 108 1 it was even? 1 A. I don't recall. 2 A. It was probably the summer going into my 2 Q. Your best recollection. 3 sophomore year. 3 A. Five or seven days. I don't — 4 Q. Okay. That makes it the summer oft, 4 Q Okay. So it was a fairly lengthy period 5 '02? 5 of time? 6 A. Mink so. Yeah, l was, I was, it was my 6 A. Yes. 7 freshman year, and it was probably — I'm, I'm guessing, 7 Q. And you would golgrthr„ most of the day 8 bee-mote it was during the summer — that it was the 8 over to see this fellow, DS? 9 summer going into my sophomore year. 9 A. Yes. 10 Q. Okay. So, whatever that — however that 10 Q. Would you see just Dr or did you 13. works out by age, what you do recall is you'd 11 see other people, too? 12 finished your first year of high schooL 12 A. Just him. 13 A. Yes. 13 Q. It was just you and your mom? 14 Q. It was the summer after your first year of 14 A. Yes. And he would do us separately. 15 high school. 15 Q. Not to be flipgistit what did you and 16 A. Yes. 16 your mom talk to Dr..11 about all day for five to 17 Q. Okay. And, and t think you told us 17 seven days? 18 earlier, your chief complaint or the reason you were 18 MR. MERMELS1TIN: Form. 19 going to see him was for depression? 19 THE WITNESS: It would be — he would ask 20 A. It was depression and my mom and l's 20 me what my problems were in high school, how 21 relationship was not good anymore. 21 people treated me in high school friend-wise, 22 Q. Okay. And it's someplace in Memphis? 22 friends that I had, things that I didn't like 23 A. Yes. 23 that friends did, my relationship with my mom, 24 2Sd did and for how long did you go see 24 why it became the way it did, my stepfather, my 25 Dr.MI? 25 father, things of that sort. Page 1C Page 109 1 A. It was -- we went there for about a week. 1 BY MR. LOFTIER: 2 Q. Oh, this is like a facility you go to? 2 Q. You gave him — would it be fair to say 3 A. He had his oven office, but he also had like an 3 you give him a comprehensive history of whatever had 4 apartment available to his clients that they would stay 4 occurred in your life up to that point in time? 5 there and come to him daily for a week. 5 A. Yes. 6 Q. So, is that what you and your mom did, you 6 Q. Would you literally sit in his office for 7 stayed in some apartment that he provided? 7 five or six hours? 8 A. Yes. 8 A. Probably. I'm not sure if it was five or six, 9 Q. And then during the day you would go to 9 but around that time. 10 his office? 10 Q. Okay. And, and, and then if he was 11 A. Yes. 11 meeting just with you, your mom would be off doing 12 Q. And is he, is he a physician by himself, 12 something else? 13 or was there a group? 13 A. Yes. 14 A. It was his family, his son I think worked for 14 Q. And If he was meeting just with her, you 15 him afro. 15 would be off doing something else? 16 Q. And how — and when you went over to see 16 A. I would be at the apartment. 17 him, were you, were you going for 45 minutes a day 17 Q. At the condo. So sometimes just one of 18 or was it longer than that? 18 you would go over and see him? 19 A. It was longer than that. I don't recall 19 A. Yes. 20 exactly how many hours it was, but it wasn't short 20 Q. Did you take any kind of tests? 21 periods of time. 21 A. I don't remember if I took tests, but I know I 22 Q. Was it Bice an all-day thing? 22 did some homewodc and writing, and I would have to read 23 A. Yeah, pretty much. 23 his chapters io his book 24 Q. Okay. So, you were there for, when you 24 Q. Is it the same book that you have at your 25 say a week, you mean five days? 25 house? 28 (Pages 106 to 109) PROSE COURT REPORTING AGENCY, INC. EFTA01076411 Page 110 Page 112 1 A. He gave me like three of them, but the only 1 A I do not know if I- I Icon, I personally 2 one I found was the one, and I don't remember if that 2 don't have them. 3 was the book that I read or not. 3 Q. Do you know if yout mom has them? 4 Q. Did you take all three back home? 4 A. I don't know. 5 A. I took them with me, but I don't know where 5 Q. Have you ever asked her? 6 they've gone. 6 A. No. 7 Q. Well, obviously, one of them you kept. 7 Q. Did, did Dr. =give you any formal 8 A. One of them I have, but the other, l don't 8 diagnosis? 9 know where the other two went. 9 A. No. 10 Q. And when you say you took them home, you 10 Q. Did he recommend that you seek any further 11 brought them back to Wellington where you were 11 treatment after you left him? 12 living with your dad? 12 A. No, not that I recall. 13 A. Yes. 13 Q. Did he come up with any solution to your 14 Q. So you apparently kept one of them since 14 problems? 15 then. 15 A. Not that I remember. 16 A. Yes. I don't know where the other two have 16 Q. Did you and your mom leave at the end of 17 gone. 17 this week feeling better about each other than you 18 Q. Have you ever read this book that you 18 did when you got there? 19 kept? 19 A. I didn't. I don't know if she did. 20 A. No. I did when I was there. He gave me the 20 Q. Still were a little upset with her? 21 assignments. 21 A. Yeah, 'just felt like he did nothing forme, 22 Q. Would you read the whole book or... 22 but... 23 A. No, hejust made me read like a chapter. 23 Q. Okay. And, and what you told 24 Q. So you never sat down and read the book 24 though, whether it was in these writings or m his 25 cover to cover? 25 notes, was the truth? Page 111 Page 113 1 A. No. 1 A. Yes. 2 Q. How about the other two that you don't 2 Q. And you told him the things that had 3 have anymore, did you read them cover to cover? 3 happened to you in your life up to that point in 4 A. No. 4 time that you felt were significant. 5 Q. And you just don't know where the other 5 A. Yes. 6 two went? 6 Q. You mentioned that you told him something 7 A. No. 7 about how you were treated in high school. 8 Q. How about the work product that you 8 A. Yes. 9 generated? You said you would get homework. You 9 Q. Do you recall what you told him about how 10 had to read the chapters and you had to do some 10 you were treated in high school? 11 other things. 11 A. When I was in South Carolina, you know, there 12 A. Yes. 12 was girls there that wanted to cut my hair off and do 13 Q. Did you have to do writings? 13 crazy things to me, and that was a word of mouth. 14 A. Yes. 14 Q. What do you mean by "crazy things"? 15 Q. In like, like a diary type of writing? 15 A. Supposedly, this is what some kid told me in 16 A. Not a diary. • Just like fights that my mom and 16 school, that they were in a gang and they wanted to, you 17 I have had, or fights that my father and I have had, and 17 !mow, cut my hair or kill me, butIdon't know if that 18 what I feel about them. 18 was accurate or not. 19 Q. And what happened with those writings? 19 Q This is someone at the school that you 20 A. 'have no idea. 20 were attending in South Carolina told you that other 21 Q. Did you give them to him or did you keep 21 kids were saying that about you? 22 them? 22 A. Yes, other girls. 23 A. I gave them to him. I don't recall if he gave 23 Q. Or should I say other — did you say other 24 them back or not 24 girl? 25 Q. Do you know if you have them? 25 A. This was a guy that told me this, but it was IllA410.1..tiaberM SI 29 (Pages 110 to 113) PROSE COURT REPORTING AGENCY, INC. EFTA01076412 Page 114 Page 116 1 about a group of girls. 1 Q. You say you told Dr. about friends Q. Okay. So a, a male fellow student at the 2 that you had? 3 school in South Carolina told you that there were 3 A. Yeah. 4 girls at that school that wanted to do these bad 4 Q. Would these have been friends that you had 5 things to you? 5 in Florida or friends that you had in South A. Yes. 6 Carolina? Q. And did you believe him when ire told you • 7 A. He was asking me about all my friends 3 these things? 8 throughout my life and good friends that have stuck by 9 A. i didn't know. I was a little bit scared for 9 me and friends that have done things to me, and those 10 my — you know, i didn't know why. You know, from what 10 girls, Fm not considering them friends, but just people 11 he told me it was scary, but I didn't know if it was the 11 in my life. 12 math or not. 12 Q. Okay. Other than going over to 13 Q. So, did you avoid interacting with these 13 Dr. ME office and meeting with him during this 14 girls? 14 one-week period, did you, did Lou do anything else 15 A. Yeah. 15 when you went to see Dr.I. in the summer of -- 16 Q. And did they ever do anything to you? 16 between your ninth and tenth grade? 17 A. They would, you know, verbally curse me out, 17 A. Did I do anything else? 18 and I would just sit there quietly and take it. 18 cI Anything else as part of that visit to 19 Q. Did they ever do anything to your hair? 19 Dr. MI other than going and sitting and talking 20 A. No, they never physically did anything to me. 20 with him. 21 Q. How about did they do, you know, kind of 21 A. No,1mean, just the books that he gave me and 22 things like stick stuff in your hair? 22 the homework. That's basically it. 23 A. No. 23 Q. Anybody else participate in that therapy, 24 Q. Gum, things like that. 24 for lack ofa better term, besides you and your morn? 25 A. That was, that was in Fort Lauderdale. 25 A. No. Page 115 Page 117 1 Q. Okay. Gum in your hair was in Fort 1 Q. Did he recommend anything at all when you 2 Lauderdale before you went to South Carolina? 2 left there that you're aware of? 3 A. That was when i was in middle school in Fort 3 A. That I'm — I don't know what he told my 4 Laudadak. 4 mother. He saw us separately at the end. But from what 5 Q. Okay. 5 I'm aware of, i don't recall. I don't know if he did or 6 A. It was a trip to Orlando, and this girl wanted 6 not. I don't remember what he said to me because I just 7 to put gum in my hair. 7 didn't feel like it helped. 8 Q. Okay. So these — how else were these 8 Q. When was the last time you had any 9 girls verbally abusive towards you? Did they call 9 communication with Dr. a? 10 you names or what? 10 A. When I went That was — 11 A. They wouldn't call me names. They would just, 11 Q. Have you attempted to contact him at 12 you know, tell me to turn the F around or just try to 12 anytime since then? 13 intimidate me. 13 A. No. 14 Q. And how would you react? 14 Q. Or contact his office? 15 A. i would just stay quiet and turn around. 15 A. No. 16 Q. And within — was that part of the reason 16 Q. Or get records from him? 17 why you left South Carolina? 17 A. No. 18 A. That was one of the reasons, you know. Also 18 Q. Have you attempted to get copies of your 19 my stepfather was part ofit 19 records from the female psychologist you said you 20 Q. Okay. This was upsetting to you to be 20 saw in Virginia? 21 going to school and having these people do these 21 A. Records? 22 things? 22 Q. Right. You know, contact their office and 23 A. Yes, it was upsetting. 23 . say, you know, give me your notes, your records, any 24 Q. And you told this Dr. about that? 24 documentation. 25 A. Yes. 25 A. I never got anybody's notes. 41103•11911iStibitIssOal•Mii....... 30 (Pages 114 to 117) PROSE COURT REPORTING AGENCY, INC. EFTA01076413 Page 118 Page 120 1 Q. Did you get anything from her? 1 Q. I'm going to show you these copies. 2 A. If I did, it might have -- I don't recall, but 2 A. Okay. 3 it might have been to get a prescription or to transfer 3 Q. I'll leave it up to your counsel. I 4 a doctor or something I don't recall that. 4 don't, I don't know that we need to attach them, but 5 Q Okay. Well, 1, I, I had more in mind. I wanted to give these to you and give you a chance 6 Did, did you or anybody on your behalf contact them 6 to look at them. 7 and try to get whatever records they had about you? 7 Now, these necords, the, there's a 8 A. Personally, I don't remember. 8 cover letter there addressed to a Dr. 9 Q. How about contacting the female 9 10 psychiatrist you said you saw in Virginia, have you 10 A. Yes. n done that and tried to get any records? 11 Q. Do you know that physician to be -- by 12 A. I don't remember. I don't think so. 12 that I mean have you ever seen that physician? 13 Q. Have you attempted to contact — have you 13 A. Yes, Ilmow that name. I just can't pronounce 14 had any contact with the female - 14 it 15 MR. LUITIER: Okay, whenever you have to 15 Q. Who is she, or why did you go to her? 16 change, just tell me. 16 A. I don't know if she — I don't know if she was 17 BY MR. LUTTLER: 17 the psychiatrist or the psychologist I went to. 18 Q. Have you made any attempt to contact the 18 Q. Are you talldngnow -- you earlier 19 female psychologist in Virginia since you, your last 19 testi ficd that you saw a female psychologist and a 20 visit with her? 20 female psychiatrist in Virginia. 21 A. Not that l remember. 21 A. Yes. 22 Q. How about with the female psychologist in 22 Q. There was, there was only one of each that 23 Virginia, since your last visit her? 23 you saw in the State of Virginia? 24 A. I don't remember. No, not that I remember. 24 A. I'm pretty sum, yes. 25 Q. Have you attempted to contact in any 25 Q. Okay. And you think this doctor is either Page 119 Page 121 1 manner the male psychiatrist who you saw in Delray 1 a psychologist or a psychiatrist? 2 Beach in Florida since you last saw him? 2 MR. MERMELSTEIN: Look at the reference. 3 A. No. 3 BY MR. LITITIER: 4 Q. Tried to get his records or anything like 4 g Yeah, feel free to look at them. And I'm 5 that? 5 just going to — there's some office notes them, 6 A. No. 6 and you'll see on the office notes, there's a 7 Q. Have you done any contact with the female 7 that came with these records that I got where it 8 psychiatrist that you went to see in West Palm Beach 8 says diagnosis, this is the one that says dermatitis 9 since you last saw her? 9 on it 10 A. No. 10 A. Okay. 11 g Tried to get her records? 11 Q. See that, that page you're looking at 12 A. No. 12 right there with the handwriting on it. Down at the 13 g Have you bad any contact with the 13 bottom left-hand corner it says, diagnosis, 14 psychologist over in the Greenville shops since you 14 dermatitis. 15 last visited with him? 15 And I, and I also point out to you 16 A. No. 16 that the physician's signature that appears on the 17 Q. And your last visit with him was about, 17 page containing the office notes dated 18 somewhere around June of '09? 18 December 18th, '07, I,I I look at that and it 19 A. Around that time. 19 looks to me like it says somebody but, you 20 Q. Did you have, have you tried to get his 20 know, I couldn't swear to it 21, records? 21 A. So, then this — 22 A. No. 22 Q. Well, believe me, you're welcome to look 23. Q. . I'm going to show you some records that we 23 at all those records. And after you've looked at 24 • obtained. They came from your lawyer. 24 them, then I want you to tell me if you can remember 25 A. Okay. 25 who this Dr. is or what she was to you, that 31 (Pages 118 to 121) PROSE COURT REPORTING AGENCY, INC. EFTA01076414 Page 122 Page 124 1 is, you blow, why you saw her. 1 history was completed for? 2 A. Is — if this was a prescription for the 2 A. This is myself, so... 3 dermatitis, then this isn't — this has to be probably 3 Q. But, I mean, do you know what doctor you 4 my PCM. 4 were — is this, is this something you did for this 5 Q. Primary cam physician? 5 doctor that, that treated you for this dermatitis? 6 A. Yeah. Yes. 6 A. I'm guessing if the — I mean, this is — came 7 Q And now you're referring to the 7 with the records. 8 prescription notice that's here that's dated 8 Q. Okay. In your answers to interrogatories 9 February I8th, '07? 9 the physician that you say you saw for dermatitis 10 A. Yeah, I don't know if this is a — 10 was a noticeoiiMtiv.t;nottr. And you 11 THE V1DEOGRAPHER: Excuse me, sir. We're 11 at least 12 going to have to change the tape. 12 at the top of the lab slip, it says 13 MR. LUTTIER: Okay. Go ahead. 13 1. anSo this is a different physician you 14 THE VIDEOGRAPHER: Going off the record at 14 saw the one that you referred to in your 15 10:55 This marks the end of Tape I. 15 answers to interrogatories? 16 (A brief recess was held.) 16 A. Yeah, I guess so. 17 THE VMEOGRAPHER: We're back on the 17 Q. And if you look at the handwritten office 18 record at 10:57 ■ This marks the beginning 18 notes the references to that are to facilities known 19 of Tape 2. 19 as 20 BY MR. LUTT1ER: 20 A Yes. 21 Q. Okay. You see these office notes, the 21 Q. So, is the — whoever's records these 22 handwritten ones that include a prescription, that 22 are- I 23 they're all dated December 18th, 2007? 23 A. Yes. 24 A. Yes. 24 Q. — that physician is not listed in these 25 Q. All right. This is -- these office notes 25 answers to interrogatories? Page 123 Page 125 1 are not from your psych, the psychologist or 1 MR. MERMELSTEIN: If I can interject here? 2 psychiatrist that you saw in Virginia; is that 2 MR. unTIER: Sure. Oh, yeah. Help any 3 coned? 3 way you can. I'm happy to get an answer. 4 A. Conect. 4 MR. MERMELSTEIN: This letter cant back in 5 Q. And there's a cover page called, called 5 response to the request made to 6 patient medical history. Was that completed by you? 6 MR LUTHER: Right 7 Right there? 7 MR. MERMELSTEIN: — 1 8 A. Yes. 8 can't pronounce that, but, but tsMi lle 9 Q. Is that your handwriting on there? 9 conic back from her as indicated in the cover 10 A. Yes. 10 letter with the initials there indicating it 11 Q. And 1 don't know, under the date it looks 11 was the same -- 12 like it says December 18th, '02. 12 MR. LUITIER: But as you can see, it 13 A. Uh-huh. 13 appears that these records are not signed kg 14 Q. Was that, is that an accurate date or — 14 her. I don't know who they're signed by. 15 when you filled that out or is it... 15 MR. MERMELSTEIN: But apparently, you 16 A. It had to have been. 16 know, she had control of them. 17 Q. Well, if you look down to the history, you 17 BY MR. LUTHER: 18 said where it says, explain, give dates and reasons 18 Q. All right. Anyway, so am-trendy there is 19 known. It said, had baby November 24th, '07. 19 another physician that's not listed on your answers 20 A. Yes. 20 to intenogatories? 21 Q. All right. So, you — this is not a 21 A. You're asking me that? 22 record you completed in '02 then apparently, because 22 Q. Yeah. 23 you had no way in '02 to say you had a baby in '07. 23 A. Yes, I mean 24 A. Oh, I guess not. 24 Q. Okay. All right All right. Other than 25 Q. Do you know who this patient medical 25 the physicians you've now told me about today -- 32 (Pages 122 to 125) PROSE COURT REPORTING AGENCY, INC. IIIIIIIIIIIIII EFTA01076415 Page 126 Page 128 1 A. Yes. 1 A. One of the doctors that I have given you the 2 Q. — and the physicians listed in your 2 names of where they're located. 3 answers to interrogatories that you provided in this 3 Q. Okay. What doctor is she? 4 case, have you seen any other doctors at all in the 4 A. Well, she — do you know if she was a 5 last five years? Well, let me put it — I don't 5 psychiatrist or a psychologist? 6 know. 6 Q. My information is that she's not a doctor. 7 Let me give you a date. Have you 7 She may be a certified nurse practitioner or 8 seen any other doctors since January 1 of 2001? 8 something. 9 10 A. Beside the ones, like, in front of me? 9 10 A. So, then, I'm guessing that mail prescribed one of my medications for Q. Right In front of you meaning your 11 answers to interrogatories — 11 Q. Where is her office? 12 A. Yes. 12 A. I, I've seen so many doctors 13 Q. — and the other doctors we've identified 13 within the past couple of years for mental health that 14 in this deposition. 14 honestly 1 cannot put a name with the face. I don't 15 A. Yeah. Not that I can remember, I mean... 15 know. 16 Q. Just, just to be complete, because 16 Q. Okay. Okay. Other than all 17 trying to trick you. I realize you saw Dr. 17 whoever she may be — you don't even know what state 18 right? 18 she's in? 19 A. Yes. 19 A. I'm guessing Virginia, but that might not be 21 Q. And you saw Dr. 1.1 20 accurate. 21 A. Yes. 21 Q. Okay. Do, do you remember her enough to 22 Q. So I know about those. 22 know if she's somebody you selected for some reason? 23 A. Yes. 23 A. If I selected her — the only doctor that was 24 Q. Other than the doctors that 24 selected out of, like, you know, somebody telling me or 25 are listed in your answers to interrogatories and 25 referring is the, the male psychologist that I saw Page 127 Page 129 the other doctors that you identified for the first 1 there. 2 time in today's deposition, are there any other 2 Q. Over in Wellington in the Greenview 3 doctors that you've seen since January of 2001? 3 plaza — 4 A. Any type of doctors, as in even my pregnancy, 4 A. Yes. 5 5 Q. — or whatever it was? 6 Q. Let's — yeah, I want to know about any 6 A. Everything else was by the list that 7 time, any kind of doctors? 7 they give on the Web si 8 A. Eye doctors, even like that? 8 Q. Okay. Now, Drt.ela that's a 9 Q. Yep, if you've seen a doctor, I want to 9 psychiatrist that you saw with respect to the 10 know who they are. 10 lawsuit that you have pending against Mr. Epstein? 11 A. Oh, my God. 11 A. Yes. 12 Q. But let's, let's, but let's start — let's 12 Q. You were sent there by your lawyer? 13 break this down. Any other mental health doctor? 13 A. Yes. 14 By mental health doctor I mean a psychologist, a 14 Q. You didn't pick him, somebody told you to 15 psychiatrist, a licensed social worker, because 15 go see him? 16 they're not technically a doctor, but any other 16 A. Yes. 17 mental health professional. 17 Q. And he hasn't rendered any treatment to 18 A. No. 18 you; is that right? 19 Q. All right. Now 19 A. Treatment, as in — 20 discovered the name 20 4 Therapy, go see him about — 21 A. 21 A. No, no, nor 22 • }fav o urer heard of the name 22 Q. He just did what's known as an evaluation 23 23 of you? 24 A. Yes. 24 A. Yes. 25 Q. 25 Q. And so where did that evaluation take 33 (Pages 126 to 129) PROSE COURT REPORTING AGENCY, INC. EFTA01076416 Page 130 Page 132 1 place; that is, where did you set him? 1 about Dr.._t before you went there? 2 A. That was in Miami. 2 A. Yes. 3 Q. Okay. I mean is actually, his 3 Q. Who did you talk to? 4 office is in California someplace? 4 A. My husband. 5 A. Yes. 5 Q. Okay. And what did you and your husband 6 Q. And so you went and met him in Miami? 6 discuss? 7 A. Yes. 7 A. That I had to see hint 8 Q. How many times? 8 Q. Okay. Did you talk about anything more? 9 A. Once. 9 A. Not that I recalL 10 Q. Did you see him more than one time? 10 Q. Did you tell your husband why you had to 11 A. No. 11 sets him? 12 Q. And how long was the visit in Miami? 12 A. Yes. 13 A. It was, it was morning to afternoon. I don't 13 Q. What did you tell him? 14 recall the times. 14 A. I had to see him for the lawsuit I was in. 15 Q. Okay. About, about a day? 15 it s Okay. So the only reason you went to 16 A. Not a day. 16 was because of this lawsuit that was pending? 17 Q. It was less than a day? 17 A. Yes. 18 A. Yeah, it was kss than a day. 18 Q. And It's somebody your lawyers told you 19 Q. Okay. I moan, four or five hours? 19 you needed to go see? 20 A. I think it was more than that. 20 A. Yes. 21 Q. Okay. But it was, all happened in one 21 Q. And since you went down there one day, you 22 day? 22 haven't seat him since? 23 A. Yes. 23 A. Yes. 24 Q. And, and did he have you do some tests? 24 Q. Meaning that my statement is correct? 25 A. Yes. 25 A. Yea Page 131 Page 133 1 Q. Okay. And you completed those tests? 1 Q. Have you had any communication with him at 2 A. Yes. 2 all? 3 Q. And they're all answered true and comet? 3 A. No. 4 A- Yes. 4 Q. Have you ever seen any materials that were 5 Q. Did you have any discussions with anyone 5 generated either by when you visited with him, such 6 about what you were to do when you went to see 6 as test results? 7 Dr. before you went there? 7 A. No. 8 MR. MERMELSTEIN: Form. 8 Answer sheets? 9 THE WITNESS: As in? 9 A. No. 10 BY MR. LUTfIER: 10 Any reports that he's done? 11 Q. Did you talk to anybody about Dr. 11 A. No. 12 before you went to see him? 12 Any transcripts of anything that went on? 13 MR. MERMELSTEIN: Other than your lawyer. 13 A. No. 14 BY MR. LUTHER: 14 Was it, was it videotaped? 15 Q. Yeah, don't tell me what your lawyer said. 15 A. Yes. 16 I assume — 16 Have you seen the videotape? 17 A. Yeah. 17 A. No. 18 Q. I assume somebod o sold you that you had an 18 Have you reviewed any of that material? 19 appointment to see Dr. at some time and in 19 A. No. 20 some place. 20 Did you review anything in preparation for 21 A. Yes. 21. your deposition today? And by review I mean did you 22 Q. And I'm going to guess that came from your 22 look at anything to get ready for today's depo? 23 lawyer's office, that part. 23 A. As in? 24 A. Yes. 24 Q. Anything. 25 Q. All right. Did you talk to anybody else 25 A. Anything? salladaSMSCIIIIIIRINDeat 34 (Pages 130 to 133) PROSE COURT REPORTING AGENCY, INC. EFTA01076417 Page 134 Page 136 1 Q. Yeah, anything. And I mean that in the 1 Q. — within the scope of reviewing. 2 broadest sense. 2 A. I didn't look through every page, no. 3 A. Yes. 3 Q. Did you look at the complaint in 4 Q. What did you review? 4 preparation for your deposition? 5 A. I just went over that paper like with my jobs 5 A. No. 6 and everything. 6 Q. Well, do you have a copy of your 7 Q. Okay. What you're pointing at now are 7 complaint? 8 your, your answers to interrogatories in this case? 8 A. Not on me. I don't - 9 A. Yes. 9 Q. Other than these answers to 10 Q. And it, and would that be the answers to 10 interrogatories that you served — that were served 11 your first set of answers to interrogatories that 11 in January of '09, that consist of, I don't know, 12 are signed by you January 26th, '09? 12 ten or IS pages, is there any other piece of paper 13 A. rm pretty sure. I mean, I didn't go over the 13 you looked at in preparation for your deposition? 14 material. I just had it on me and I looked through it 14 A. Something to be prepared for a deposition. 15 It wasn't like I sat there and, you know, read every 15 Q. What, say what? 16 little page. 16 A. To be prepared. 17 Q. What do you mean, you had it on you? 17 MR. MERMELSTEIN: That's what he's asking 18 A. I had it and I looked at it 18 you, what, what you reviewed. 19 Q. Did somebody send it to you? 19 BY MR. LUTTIER: 20 A. They sent it to me through the mail, I think. 20 Q. Did you say you did look at something 21 Q. Okay. 21 else? 22 A. Through the, through e-mail. 22 A. To be — yes. 23 Q. They were e-mailed to you, your answers to 23 Q. What did you look at? 24 interrogatories? 24 A. To how to be prepared for your deposition. 25 A. Yes. 25 Q. Oh, some kind of summary that says this is Page 135 Page 137 1 Q. So that you could review them before your 1 what you should do to get ready for your depo? 2 depo? 2 A. Yes. 3 A. Yes. 3 Q. Probably from you lawyer that says, you 4 Q. Okay. Anything else other than those 4 know, this is what a depo — 5 answers to interrogatories that you reviewed? 5 MR MERMELSTEIN: Don't talk about what it 6 A. You have to give me a second to think about 6 says. 7 it. 7 BY MR. LUTHER: 8 Q. Sure. 8 Q. Okay. All right Something you got from 9 A. Not that, I mean, that I could think of. 9 Your lawyer? 10 Q. Okay. And did you only see one set of 10 A. Yes. 11 answers to interrogatories? 11 Q. But it was a generic thing? 12 A. I think that this is? 12 MR. MERMELSTEIN: Again, don't talk about 13 Q. Right that's what that, that paper is 13 what it says. 14 there. 14 MR. LIMIER: Strike that question. 15 A. I think so. 15 BY MR. LUTHER: 16 Q. Did you review your -- the, what's known 16 Q. Any, any other piece of paper that you 17 as the complaint that you filed in this case? 17 reviewed? 18 That's the document where you made your allegations 18 A. Not that — I mean, to me these all look the 19 against Mr. Epstein. 19 same. 20 A. Did I like read through them? 20 Q. Okay. 21 Q. Yeah, review the complaint. And I don't 21 A. I mean, that's... 22 want to get hung up on semantics about what the word 22 Q. All right. So that's it. Your answers to 23 "review" means. I mean, if you looked at it as far 23 interrogatories and something from your lawyer about 24 as I'm concerned that is -- 24 preparing for the depo? 25 A. I, I didn't - 25 A. Yeah, that's all I can remember. 35 (Pages 134 to 137) PROSE COURT REPORTING AGENCY,. INC. EFTA01076418 Page 138 1-age Q. Have you ever seen any police reports of 1 A. I don't recall. 2 any kind or nature that have anything to do with 2 Q. Well, was it somebody that had involvement 3 Mr. Epstein? 3 with Mr. Epstein? 4 A. Police reports? 4 A. Most Ificely, yes. 5 Q. Police reports. Q. I mean otherwise why would this person 6 A. As in, like, on a piece of paper? 6 have - 7 Q. Well, a piece of paper, videotape or any 7 A. Yeah. 8 other way. Have you ever seen any police reports? 8 Q. — any reason to bring to your attention, 9 A. No. 9 Mr. Epstein? 10 Q. Have you ever reviewed any police reports 10 A. Yes. 11 that concern Mr. Epstein or anybody that claims they 11 Q. So, so who of your friends had involvement 12 went to Mr. Epstein? 12 with Mr. Epstein? 13 A. Reviewed any police reports? 13 A. I had — 14 Q. Right. 14 THE WITNESS: Am I allowed to say this? 15 A. Like an actual police report? 15 MR. MERMELSTEIN: The — 16 Q. Yeah. 16 THE WITNESS: To tell this? 17 A. No. 17 MR MERMELSTEIN: — the question was to 18 Q. Have you ever been told about any police 18 identify whatever friends had involvement with 19 reports by anybody, whether it's one of your 19 Epstein. 20 friends, your lawyer or anybody else? 20 THE WITNESS: So I can tell him? 21 A. No. 21 MR. LUTTIER: Yeah. 22 MR. MERMELSTEIN: Obviously, don't talk 22 THE WITNESS: I mean, I don't know if it 23 about what your lawyer said. 23 was allowed by — 24 MR. LUTHER: Yeah, don't tell me what 24 MR. LUTHER: Yeah, you can give me the 25 they said. 25 names. Page 139 Page 141 1 THE WITNESS: No, yeah. 1 THE WITNESS: Okay. 2 BY MR. LUTHER: 2 MR. MERMELSTEIN:. I, I'm not sure I 3 Q. Are you aware that there was an 3 understand why. 4 investigation by the, the Town of Palm Beach Police 4 THE WITNESS: I, I don't know. Just I 5 Department? 5 didn't want you know, I don't know if I'm - 6 A. Against Epstein? 6 I don't know. 7 Q. Yeah. 7 BY MR. LUTHER: 8 A. Yeah. 8 Q. You were concerned about whether you can 9 Q. How are you aware of that? give me their names? 10 A. 'heard about it, I think, through somebody in 10 A. Yes. 11 Virginia. 11 Q. Yeah. 12 Q. Okay. And who would that be? 12 MR. MERMELSTEIN: You mean in tams of 13 A. I don't recall who told me. It was one of my 13 confidentiality? 14 friends from Florida. They told me that he had a — he 14 THE WITNESS: Yeah. I didn't know. 15 was being arrested or something along those lines. I 15 MR. MERMELSTEIN: Well, we've been taking 16 don't recall exactly what was said. 16 care of that on the transcript. 17 Q. Okay. So, so you — when you said it was 17 MR.. LUTHER: Right. 18 information you got in Virginia, you mean you were 18 MR. MERMELSTEIN: We'll use their initials 19 in Virginia when this information was imparted to 19 for purposes of this or, or some other form to 20 you? 20 protect than. 21 A. Yes. 21 THE WITNESS: So just their initials, 22 Q. But it came from one of your friends in 22 then? 23 Florida? 23 MR. MERMELSTEIN: No, no. You give the 24 A. Yes. 24 name — 25 Q. And what friend was that? 25 THE WITNESS: Okay. Okay. 36 (Pages 138 to 141) PROSE COURT REPORTING AGENCY, INC. EFTA01076419 Page 142 Page 144 1 MR. MERMELSTEIN: — and the court 1 THE WITNESS: She just said it was, you 2 molter — 2 know, she's done with it. I don't — I, all I, 3 THE WITNESS: Oh, okay. 3 anti:now is like ifs, it's over with her. 4 MR. MERMELSTEIN: — will put the 4 BY MR. LUTI1ER: 5 initials. 5 Q. Well, would — I want you to tell me 6 THE WITNESS: All fm not used to 6 exactly what she told you about it — 7 this, so. There is M.,M. 7 A. Exactly. BY MR. LUTTIER: 8 Q. — quote, being over. 9 Q. M. what? A. She just said she's done. That's all she told 10 A E. 10 me and she won't tell me anymore. 11 11 Q. So you're, you're staying with her, right? 12 . There wasM. andM. 12 A. Yes. 13 Q. ? 13 Q. And how long have you been with her? 14 A. (Witness spells first name.) 14 A. I just got in — when did I get in? Wednesday 15 Q. (Mr. Luttier spells first name.) What's 15 she picked me up from the airport. 16 her last name? 16 Q So you've been here since Wednesday? 17 A. S. 17 A. Wednesday night. 18 Q. (Mr. Luttier partially spells last name.) 18 Q. Okay. And, and the only discussion you 19 A. Yeah, (Witness spells last name.) I think. 19 had with her about her claim with Mr. Epstein was 20 Q. Okay. Any other of your friends that have 20 you said she said it was over? a 21 had involvement with Mr. Epstein? 21 A. Yes. 22 A Not that I'm aware of. 22 Q. And she — did she tell you how it got 23 Q. Was it one ofthese girls that called you 23 resolved? 24 when you were in Virginia and told you of 2.4 A. No. 25 Mr. Frtein? 25 Q. Did you ask her? Page 143 Page 1 A Yeah, I am guessing so. I just have to think 1 A I asked her. 2 about it and remember who it was. 2 Q. What did she say in response to your 3 Q Were — which of these girls - were any 3 question? 4 of these girls what you would consider to be your 4 A I can't tell you. 5 best fricia 5 Q. Okay. Did she, although she didn't tell 6 A. M. has been close to me. 6 you with specificity, did she say anything at all 7 Q. Still close to you? 7 about how it was resolved? 8 A. I still talk to her, yes. A. No. 9 Q. When was the last time you talked to her? 9 Q. Did she show you any paperwork? 10 A. Today. 10 A. No. 11 Q. And when did you talk to her? 11 Q. Did you ask her anything more about this 12 A. Pm actually staying at her house since I flew 12 claim? 13 down from Virginia. 13 A. No. 14 Q. And she made a claim against Mr. Epstein, 14 Q. So, you — although this lady had a claim 15 right? 15 against the same person that you're making a claim 16 A. Yes. 16 against — 17 Q. And what did she tell you about that? 17 A. Uh-huh. 18 A She didn't really tell me much about it. 18 Q. — and you spent the night with her, the 19 Q. Well, my question is: What did she tell 19 totality of your conversations with her about 20 you about it. 20 Mr. Epstein and her claim was a statement that she 21 A. That she was going against Epstein. That's — 21 made to you that it was over? 22 !mean — 22 A. Yes. 23 Q. Well, she told you more. She told you 23 MR. MERMELSTEIN: Form. 24 about what's happened to her claim, hasn't she? 24 THE WITNESS: But that was before. I 25 MR. MERMELSTEN: Form. 25 mean, that wasn't since I've been here. She ===== 37 (Pages 142 to 145) PROSE COURT REPORTING AGENCY, INC. EFTA01076420 Page 146 Page 148 just told tne one day — you know, I asked her 1 best friend? 2 and she just said it was over, but of course, 2 A. She's a close friend. I mean, I have a lot of 3 I'd asked her, what happened, and she won't 3 close friends ifs, but, I mean, right now, yeah, we're 4 tell me. 4 close. 5 BY MR. LUTHER: 5 Q. How long have you knownM.? 6 Q. So, the conversation where she told you it 6 A. Since I was in Fort Lauderdale. 7 was over was a conversation that happened before you 7 Q. That goes back to — well, you were there 8 flew down here? 8 from age three, right? 9 A. Yes. 9 A. No. No. 10 Q. All right. What — 10 Q. Okay. When were you in Fort Lauderdale? 11 A. We actually haven't spoke about anything that 11 A. 'started, I was in Florida for my middle 12 happened with her since I've been here. 12 school, sixth, seventh and eighth. 13 Q. All right. Since you got here Wednesday, 13 Q. Okay. This is somebody you've known since 14 what conversations have you had withIS that, that 14 sixth grade? 15 involved in any way, shape or form Mr. Epstein and 15 A. Around seventh. I mean, we weren't close in 16 you and/or her? 16 middle school though. I just knew of her. 17 A. I mean, she knows that I'm down here, you 17 Q. And then you left Fort Lauderdale and went 18 know, for this, my case, but that's it. 18 to went to South Carolina and then you went to 19 Q. I want to know what conversations you've 19 Wellington? 20 had with her about that, that — 20 A. Yes. 21 A. She knew I had to fly down here for my case. 21 Q. Did you lose touch with her, or just did 22 I mean, that's — we, we don't get into that because we 22 you keep in touch with her? 23 know we're not really supposed to tell each other 23 A. I didn't — 'wasn't friends with her in Fort 24 things. 24 Lauderdale. 25 Q. Who told you you weren't supposed to tell 25 Q. Okay. Page 147 Page 149 1 each other things? 1 A. I just knew ofher. We had the same friends. 2 MR. MERMELSTEIN; Objection. Well - 2 We weren't close or anything, so it wasn't like we 3 MR. WITTER: Don't, if your lawyer's the 3 kept — I didn't really talk to her. 4 one that told you, just, just — you don't tell 4 Q Did you, did you strike up your 5 me what they said. So did anybody other 5 acquaintance with her again at some point in time? 6 than - 6 A. Yes. We — 7 MR. MERMELSTEIN: Well, anyhow - 7 Q. When was that? MR. LUTTIES: Let me, let me rephrase it. 9 A. When I moved with my father, her family 9 BY MR. LUMER: 9 actually moved to the same neighborhood as we were 10 Q. Did anybody other than your, than your 10 living in. And my friend f which was friends with 11 lawyer tell you you weren't allowed to talk tole. 11 both of us, told me about it, andM. got my number and 12 about your claims? 12 we started talking, and that's how we became friends. 13 A. No. 13 Q. Who would you say your best friend is? 14 Q. All right. So es never told you that 14 A. Right now? 15 she wasn't allowed to do that? 15 Q. Yeah. 16 A. She just said she couldn't tell me. I don't 16 A. My husband. 17. know why, but l'm assuming it's — the same goes for 17 Q. Okay. I mean, ofgirlfriends who is your 18 both °flu. 18 best friend? 19 Q. And did — do you know whoM.'s lawyer 19 A. The Fm closest to right now is, is 20 was? 20 Q. And M. has been your closest friend for 21 A. No.. 21 what period of time? 22 Q. Did M. give you any papers to review 22 A. I mean, I have a group of close friends. I 23 from her case? 23 mean, it's not been - we've been friends, I guess you 24 A. No. 24 could say close friends, since she came down to 25 Q. You — would you characterize, as your 25 Wellington. In Binks Forest we became close. 38 (Pages 146 to 149) PROSE COURT REPORTING AGENCY, INC. EFTA01076421 Page 150 Page 152 1 THE COURT IMPORTER: In what? Pm sorry. 1 what she was doing with that. I don't know like when 2 THE WITNESS: Wellington. 2 she was going or what she was doing or how many times 3 BY MR. LUTTIERt 3 she -- I have no idea. We didn't really — I ;mow she 4 Q. And that was when you were in high school? 4 went. I don't know if it's because she mentioned it in 5 A. Yes. 5 high school. I don't know. 6 Q. So since ninth grade? 6 Q. Well, you discussed the fact that she had 7 A. Yes. 7 a claim against Mr. Epstein with her, right? 8 Q. All right. So since you were in ninth a MR. MERMELSTEIN: Objection, foam 9 grade, you and she have been best friends? 9 BY MR. WITTER: 10 A. Yes. 10 Q. Have you discussed with her the fact that 11 Q. Okay. And, and in foie I'll get into 11 she has a claim against Mr. Epstein? 12 more of this later, but isn't IN the person that 12 A. She told me — when I was in Boca she told roc 13 went with you when you first went to see 13 she did. 14 Mr. Epstein? 14 Q. When were you in Boca? 15 A. Yes. 15 A. I'm guess — I think when I first came down 16 Q. Is there anybody or strike that. When 16 here. I think when I first came down here from when my 17 was the last time you talked to 11? 17 husband went on his deployment. 18 A. I talked to U, she — the last time I 18 Q. So this is, now we're talking about 19 talked to her was in Virginia. 19 January of— would you say '09? I mean, I can't -- 20 Q. That is you were in Virginia? 20 I— 21 A. Yes. 21 A- Yeah, it was - 22 Q. Where was she, down here? 22 Q. Refresh my memory. I don't want to give 23 A. Yes. 23. you the wrong date. 24 Q. Okay. When was that? 24 A. Yeah. January I came here, February. 25 A. When I found out I was pregnant I told her 25 Q. Of '09? Page 151 Page 153 1 because she's also pregnant 1 A. Yes. 2 Q. Any other — what did, what did she tell 2 Q. Okay. 3 you? Is that what you were calling her for when you 3 A. And then I started school. 4 were Virginia? 4 Q. Okay. So this is something you learned 5 A. Yeah. 5 for the first time, that she had a claim against 6 Q. What was your relationship with M? 6 Mr. Epstein in January of '09. Have I got that 7 A. We were close. 7 right? 8 Q. Did she go to school with you? 8 A. I don't know if it was January, but it was 9 A. Yes. 9 sometime when I moved here. 10 Q. From, all through high school? 10 Q. Was it before January of '09? 11 A. No. I met her probably around my sophomore, 11 A. No. 12 sophomore year, probably. 12 Q. And this was many, many years after she 13 Q. Met her — did you meet her before you 13 had gone to see Mr. Epstein. 14 went to Mr. Epstein's for the first time? 14 A. What do you mean? 15 A. Yes, !think so. 15 Q. Well, I'm just — years after she actually 16 Q. Did she ever go with you to Mr. Epstein's? 16 went to see Mr. Epstein that you learned for the 17 A. No. 17 first time that she, she had a claim against him. 18 Q. When did you first kam that she went to 18 A. Yes. 19 Mr. Epstein's'? 19 Q. Okay. And it was years after you had gone 20 A. We I, I don't, honestly I don't remember 20 to Mr. Epstein? 21 when I, when I -- she told me she went there. I don't 21 A. Yes. 22 remember that. 22 Q. Okay. 23 Q. Well, was it at or about the time that she 23 A. Before — can I take one more quick break? 24 went, or was it a long time later? 24 MR. LUTHER: Absolutely. 25 A. I didn't really blow what she — I didn't Icnow 25 THE WITNESS: Sony. I just -- 39 (Pages 150 to 153) PROSE COURT REPORTING AGENCY, INC. EFTA01076422 Page 154 Page 156, 1 ME VIDEOGRAPHEIt Going off the record at 1 other than over the telephone? 2 2 A. On Facebook. 3 (A brief recess was held.) 3 Q. And is she — you have a Facebook page or 4 THE V1DEOGRAPHER: We're back on the 4 whatever it is you get these days? 5 record at 11:4] 5 A. Yes. 6 BY MR. LUT1TER: 6 Q. Okay. And she's listed as one of your 7 Q. We were talking about U You said you 7 friends? 3 last talked to her while you were in Virginia. 8 A. Y 9 A. Yes. 9 Q. listed as one of your friends? 10 A. 10 11 12 Q. Are you referring to the time period when you were living in Virginia? A. Sony. Yes. 11 12 a A. No. l listed as one of your friends? 13 Q. Are you still, you still living in 13 Q- No? 14 Virginia? 14 A. No. 15 A. Yes, I'm back in Virginia. 15 Q. lila or a? 16 Q. So when, when -gLve me the — what year 16 A. 17 it was you last talked to 17 Q. is she one of your friends? 18 A. I just talked to her before I left to Florida 18 A. Yes. 19 to tell her I was pregnant when I found out. 19 Q. And are you friends on all those people's 20 Q. As in pregnant right now? 20 pages that they are friends on yours? 21 A. Yes. 21 A. Yes. 22 Q. So you talked to her in the last ten days? 22 Q. Anybody else that's listed on your 23 A. Yes. 23 Facebook as, as — or designated on your Facebook as 24 Q. And where were you when you talked to her? 24 one of your friends that's, that has had any 25 A. In my house. 25 involvement with Mr. Epstein? Page 155 Page 157 1 Q. In Virginia? 1 A. Not that I'm aware of. Just that I've told 2 A. Yes. 2 you. 3 Q. And why were you contacting within 3 Q. What school, what high school did II go 4 the last ten days? 4 to? 5 A. To tell her I was pregnant. 5 A. She went to Wellington and Palm Beach Central, 6 Q. So do you have some regular contact with 6 and then she moved to Broward. But I don't !mow what 7 her? 7 school she went to there because we lost contact for a 8 A. Yes. 8 little while. 9 Q. With what degree of frequency do you 9 Q. Well, did you and she go to school 10 communicate with her? 10 together? 11 A. It depends on how busy we both are in our 11 A. Yeah, in high school and middle school, but we 12 lives. But I mean, you {mow, we keep in contact once 12 were friends in high school. 13 every two weeks or twice a month, or I mean, k depends. 13 Q. And so you, you were a freshman together 14 I mean we're close. 14 in the same class? 15 Q. And, and what — I would like you to tell 15 A. Same class, no. Just in school to me everything that she's told you about any claim ilOkay. And you both went to, to 16 17 18 she filed against Mr. Epstein. A. She just said she had a lawyer and that was I 18 A. Yes. 19 the last I heard. I never really talked to her about I sAnd did you, did — you went to 20 that. until when? 21 Q. Okay. And what's the status of her claim 21 MR. MERMELSTEIN: Form. 22 now? 22 THE WITNESS: 2005. It's 23 A. I have no idea. I haven't talked to her about 23 switched to the alternative scholoNli r 24 that. 24 BY MR. WITTER: 25 Q. Do you communicate with M. by any method 25 Q. And when you switched to the altemath II (Pages 154 to 157) PROSE COURT REPORTING AGENCY, INC. . EFTA01076423 Page 158 Page 160 1. school was INstilt at 1 up and then they got back together later on and got 2 A. I don't think so. I don't think so. 2 married. 3 Q. She was -- was she in your same class? 3 Q. &Ehat's )as maiden name? 4 A. No. 4 A. 1M 5 Q. Where was she in relationship to you? Q. So, she - you knew her as l in NH 6 A. When? 6 school? 7 Q. Like was she a year ahead of you, a year 7 A. In high school. 8 behind? 8 Q. She didn't get married to IIII until 9 A. Oh, no, she was the same year as me. sometime after? 10 Q. Okay. So she was -- when I say your same 10 A. After high school. 11 class, I didn't mean the particular class. 11 Q. Okay. Now, who told you that -- d your 12 A. Oh, same -- 12 husband confum that he had sex with =7 13 Q. I mean the same level. 13 A. Later on, yes. At first they both denied it. 14 A. Yes, yes. 14 But this was in high school; this wasn't when we were Okay. So, had she already lef . 15 married or dating. 15 ii 17 school? by the time you went to the alternate 16 17 Q. I just want to make sure I've got these dates right. This would have been when she was 18 A. I, I don't recall, but Pm guessing she wasn't 18 19 there, 19 A. Yes. 20 Q. Why are you guessing that? 20 Q. d's name is? 21 A. Because we stopped being friends our senior 21 A. les No. 5. 22 year and she moved away, and I don't remember when she 22 Q. And you first had sex with Mr. Doe No.5. 23 moved exactly. I don't know if it was before or after 23 back in, what, the ninth grade? 24 the alternative school. 24 A. No, it was the summer going into ninth grade. 25 Q. And why did you and she stop being 25 Q. Oh, it was before you got to high school? Page 159 Page 161 1 friends? 1 A. Uh-huh. 2 A. Over a guy. 2 Q. Is when you're — it was right after you 3 Q. Who was that? 3 got out of eighth grade? 4 A. My husband, 4 A. Uh-huh. 5 Q. And what, why did you stop being friends 5 THE COURT REPORTER: Is that a yes? 6 over your husband? 6 THE WITNESS: Yes. I'm sorry. 7 A. Because my husband and I, we were, we weren't 7 BY MR. LUTTIER: 8 dating but we were together, you know, friends hanging 8 Q. So that puts you at 13? 9 out, and then she started liking him. High school 9 A. Thirteen, 14. 10 stuff. 10 Q. I'm going to get this pinned down. 11 Q. Well, what do you mean by "stuff"? Did 11 MR. MERMELSTEIN: Make, make sure you're, 12 she have sexual relations with him? 12 you're clear. 13 A. Yeah, she had sex with him. 13 BY MR. LUTHER: 14 Q. How do you know that? 14 Q. Yeah. Take your time. 15 A. Because I found out through other people. 15 A. The sinner I was 14. 16 Q. And did you have sex with In's brother? 16 Q. Are you sure about that? 17 A. Its brother? 17 A. No, I'm not positive. Thirteen. 18 Q. Yeah. 18 Q. R was thirteen? 19 A. NB doesn't have a brother. 19 A. It was the stunner. It was -- 20 Q. Is there a D. that... 20 Q. It was when you were 13 years old before 21 A. Oh, D. that's, that's her ex-husband. 21 you started high school, right? 22 Q. You had sex with her ex-husband? 22 A. It was the summer going into my high school 23 A. No. When I was in high school I dated 23 for the lust time. 24 before. After I dated M. she started 24 Q. All right. So that would make you 13? 25 dating and then they stayed -- well, they broke 25 A. Thirteen. 41 (Pages 158 to 161) PROSE COURT REPORTING AGENCY, INC. EFTA01076424 Page 162 Page 164 1 Q. Okay. And was he the first person that 1 other than your, one of your parents, I mean, before 2 you had been sexually active with? 2 you had your sex with Mr. Doe No. 5 at 13? 3 A. Yes. 3 A. No. 4 Q. And, in fact, he's, he's the individual 4 Q. No, nobody had put their hands up under 5 that you say you lost your virginity to, isn't it? 5 your blouse and 6 A. Yes. 6 A. Well - 7 Q. Now, when you say you lost your virginity, 7 Q. -- taken your bra off or anything like 8 you mean that was the first person that you had 8 that? 9 sexual intercourse with? 9 A. I mean, he felt of my breasts, yeah, 10 A. Yeah. 10 yes. 11 Q. Had you had any kind of sexual contact 11 Q. Okay. 1mean, with your bra, you mean 12 with anyone else before you had sexual intercourse 12 over your bra or under, took your bra off and -- 13 with Mr. Doe No. 5.? And by that, I mean, when 1 13 A. I don't remember. 14 say •sexual contact," anything of a sexual -- 14 Q. You don't remember that? 15 activity of a sexual nature short of actual 15 A. I don't remember if it was under my bra or 16 intercourse. So you — that would mean could be 16 over my bra. 17 oral sex, could be, you know, any kind of, ofuse of 17 Q. How about putting his hand down in your 18 body parts, anything short of actual intercourse. 18 pants? 19 A. Would you consider lensing or... 19 A. No. 21 Q. No, not kissing. I mean, you know, 20 Q. Anybody ever done that? 21 anybody ever, any male before you actually lost your 21 A. Before my husband before my 22 virginity to !viz. Doe No. 5 at 13, for example, ever 22 Q. Right. 23 rub any portion ofyour vagina with, you know, their 23 A. With=, no. 24 band, for example? 24 Q. Okay. Now, beforeMI actually had 25 A. Not that I remember. 25 sexual Intercourse With you, had you and he engaged Page 163 Page 165 1 Q. Any oral sex given by you to anyone before 1 in sexual activity, something short of actual 2 you lost your virginity to Mr. Doe No. 5 at age 13? 2 intercourse? 3 A. Not that I recall, no. 3 k Kissing. 4 Q: Well, would you recall that? 4 Q. Okay. So your testimony is that there was 5 A. I'm sorry? 5 no kind ofsexual contact, foreplay or anything like 6 Q. Would you recall that? 6 that, with Mr. Doe No. 5 until the day you actually 7 MR. MERMELSTE1N: Form. 7 had intercourse? 8 THE WITNESS: I'm, I'm thinking. You've 8 A. I mean, there was kissing and, I mean, we were 9 got to give me one second. 9 like on top ofeach other, but it wasn't — that I 10 MR. LUTTIER: Sure. 10 heuQAuber, it was just — I mean, this is so personal 11 THE WITNESS: We're going back. No, 1 11 but I mean, I would be on top ofhim kissing and stuff. 12 don't think so. 12 It wasn't like he would touch me or anything. 13 BY MR. LUTTIER: 13 Q. And you had never performed any sex act.on 14 Q. In, in other words, it would not be 14 him, whether it was masturbating him by hand or 15 uncommon that prior to the time a girl has sexual 15 anything Ince that? 16 intercourse for the first time, she has engaged in 16 A. No. 17 some sort of sexual activity short of actual 17 Q. Okay. AM right. So Mr. Doe No. 5, you, 18 intercourse, whether you — I don't know how you 18 you meet him, you have sex with him at 13? 19 want to characterize it, but you know what I'm 9 A. Uh-huh, yes. 20 talking about? 20 Q. Then were when did your friend, your 21 A. I mean even touching of the breasts? 21 best friend.., have sex with him? 22 Q. Yeah. 22 A. That was in high school. 23 A. I mean in Fort Lauderdale, I mean he 23 Q. Okay. When? 24 touched my boob, I mean, but 1... 24 A. My junior year. 25 Q. Were you ever naked in front of a male, 25 Q. So that's -- would that be before or after 42 (Pages 162 to 165) PROSE COURT REPORTING AGENCY; INC. EFTA01076425 Page 166 Page 168 you saw Mr. Epstein? 1 A. How many times did we have sex? 2 A. That would be after. 2 Q. Yeah. I mean, were you having sex 3 Q. And when was the first time you were 3 daily - 4 suspicious that had had sex with your husband? 4 A. It was — A. When — I had suspicions just by the way they - or weekly. 6 were acting. But when I first figured out they had sex 6 A. I mean, it was, you know, once or twice every 7 or when I heard about it was from somebody in my class. 7 dine weeks, maybe. 8 Q. And who was that? 8 Q. OW 9 A. Her name was =. 9 A. A month. I mean, it wasn't... 10 Q. Does she have a last name? 10 Q. And, and LI want to make sure I 11 A. She does, but I don't know her last name. 11 understand the terminology you're using When I 12 Q. And what is it thatll= told you? 12 asked you if he was your boyfriend, you seemed to 13 A. Thati.and . had sex. 13 indicate that wasn't true. 14 Q. Did she tell you how she knew? 14 A. Yes. 15 A. She said that came over to her 15 Q. So having — you, you had sex with people 16 boyfriend's house, boyfriend's house, and was 16 that weren't your boyfriend? 17 talking about how the condom broke with.. 17 A. I wanted him to be my boyfriend, but he didn't 18 Q. And did there come a time that you 18 want to make a commitment to me. 19 confronted your husband about whether or not he had 19 Q. Well, were you, were you providing sexual 20 had sex with..? 20 favors for him in order to get him to be your 21 A. Yes. 21 boyfriend? 22 Q. And when was that? 22 MR. MERMELSTEIN: Form. 23 A. Right after I found out after school. 23 THE WITNESS: No. I just — I really like 24 Q. And, and tell me how that conversation 24 him and I wanted to be with him. And we just 25 went. 25 had sex. Page 167 Page 169 1 A. Well, it didn't go good. They both denied it 1 BY MR. LUTTIER: 2 and they both were lying about it and said people were 2 Q. So at the time that this happened, in your 3 making things up. 3 junior year, for what period of time had you and he 4 Q. Well, did you have this conversation with 4 been sexually active? 5 them jointly or did you have a conversation with 5 A. It started in my junior year. 6 them -- Q. Okay. So for six months or -- 7 A. No, jointl was after school, and I 7 A. I mean, we started having sex again from when a started talking to and M. called over and 8 we took each other's virginity junior year, and then 9 they were denying it to me. 9 after I found out they had sex, I stopped talking to 10 Q. All right. And did you care at that point 10 him. 11 in time? 11 Q. Okay. Well, my question is: During this 12 A. I cared. Like it really pissed me off because 12 period oftime — when did you recommence having sex 13 she was my best friend and I was like not dating him but 13 with him after you had sex — 14 I was with him. 14 A- My — 15 Q. And when you say "with him," he was like 15 Q. — with him when you were 13? 16 your boyfriend at the time? 16 MR. MERMELSTEIN: Objection, asked and 17 A. Not boy -- we were sexually active at the 17 answered. 18 time. 18 THE WITNESS: My junior year I had sex 19 Q. Meaning you were having sex with him? 19 with him. 20 A. Yes. 20 BY MR. WITTER: 21 Q. But you - I want to go over this. You 21 Q. Yeah. I !mow, but I am trying to — 22 said at the time this occurred you were having sex 22 A. And then — 23 with, with the fellow that became your husband? 23 Q. Okay. 24 A. Yes. 24 A. And then we stopped. And then I started 25 Q. And with what degree of frequency? 25 having sex with him again my senior year. 43 (Pages 166 to 169) PROSE COURT REPORTING AGENCY, INC. EFTA01076426 Page 170 Page 172 1 Q. I want to go back to the junior year, 1 773E WITNESS: No, I was just comfortable 2 because you told me that this confrontation that you 2 with him. •3 had with he and happened in your junior year, 3 .• BY MR. LUTTD3R: 4 right 4 Q. Okay. Well, you were having sex with 5 A. Yes. 5 other people, too, weren't you? 6 Q. You said that at the time that there was 6 A. If I had a boyfriend at that time. 7 the confrontation, you and he were sexually active. 7 . Q. Well -- 8 A. Yes. 8 A. I wouldn't be with both of them. But if I had 9 Q. You told me when you were 13 you were 9 lace a break, like, if I me and my — a boyfriend 10 sexually active with him. 10 broke up, I would, you know, hang out with again 11 . A. Yet 11 and, you know, we would have sex. 12 Q. You had sexwith him and both of you lost 12 Between the first time you had sex with 13 your virginity. 13 =and when you renewed your sexual relationship 14 A. Yes. 14 with him in your junior year, you had sex with a 15 Q. Then there was a time — when was the next 15 number of boys, did you not? 16 time you and he had sex after the first time when 16 A. Yet 17 you lost your virginity? 17 Q. Okay. So you were having sex with in 18 A. The date? 18 your junior year. 19 Q. No, I mean 19 A. Yes. 20 A. My junior year. 20 Q. You wanted him to be your boyfriend. 21 Q. — six months later. All right. So you 21 A. Yes. 22 go from, from after your eighth grade — 22 Q. Did, did — were you, exclusively at that 23 A. Yes. 23 time just having a relationship with him? 24 Q. — which was the first time. There's no 24 A. My Puler year? 25 sex during your ninth-grade year. There's no sex 25 Q. Yeah. Did you understand that to be an Page 171 Page 1 during your tenth-grade year. 1 exclusive relationship, you and he? 2 A. Right. 2 A. What do you mean by exclusive? 3 Q. So, it's at least two years. 3 Q. You two were the only two having — you 4 A. Yes, we didn't like each other. 4 thought he was just having sex with you and you 5 Q. Then in your junior year, did you start 5 were — 6 having sex with him at the beginning of the year? 6 A. That's — 7 A. It was — I'm going to say it was, like, maybe 7 C). — just having sex with him? 8 the middle of the year, I guess. 8 A. That's what I thought. He was just having sex 9 Q. Okay. So if you started in the middle of with me. 10 the year, at the time you' had this confrontation 10 Q. Okay. And that was your understanding? 11 with he and you and he had been having sex 11 A. Yes. 12 regularly for a period of months. 12 Q. Okay. And then it came as a surprise to 13 A. It would go off and on. 13 you when this perton told you that, that your 14 Q. Okay, but you had been off and on for a 14 best friend had sex with the fellow that you thought 15 period of months? 15 was the guy you were having an exclusive 16 A. Yes. Like, it wouldn't be like we were 16 relationship with? 17 definitely together. We'd, you know, hang out for a 17 A. Yes. I knew that there was something going 18 couple of days, and then if we had sex, we did, and we 18 on, but I didn't know it went to that level of sex with 19 wouldn't talk I mean, it was, it was a very confusing 19 them. 20 relationship with him. 20 Q. And you asked them and they denied it? 21 Q. But you, you were comfortable enough with 21 A. Constantly. 22 your sexuality that it was acceptable to you to have 22 Q. Did there come a time that husband 23 sex with individuals who you didn't consider to be 23 admitted that • had sex with El. in your junior 24 your boyfriend? 24 year or when you were having a sexual relationship 25 MR. MERMELSTE1N: Form. 25 with him? 44 (Pages 170 to 173) PROSE COURT REPORTING AGENCY, INC. EFTA01076427 Page 174 Page 176 1 A. I don't remember exactly when he told me. BY MR. LUTTIER: 2 Q. What's your best estimate? 2 Q. Once a person lies to you, especially if 3 A. Probably he accidentally admitted it to me 3 WS 8, aillEal, a man with whom you have had a 4 over either the summer going into my senior year or the 4 romantic relationship, once he lies to you, do you 5 beginning of my senior year. 5 ever trust him again? 6 Q. What do you mean, "he accidently admitted 6 MR. MERMELSIEIN: Form. 7 7 BY MR. LUTTIER: 8 A. He slipped when he actually was drinking one Q. Or Is there always that suspicion in the 9 night and told me that he had asked his mom to take him 9 back of your mind? 10 to get checked because the condom broke and he was 10 A. Yes, there's always a suspicion in the back of 11 scared that he might have something. And that's when I 11 my mind. 12 said, really, so you did have sex with 12 Q. Okay. Because he had made a specific 13 Q. Let me guess, the rest of the conversation 13 straight-out representation to you when you 14 didn't go well. 14 confronted him that it didn't happen. 15 A. No, no, not really. 15 A. Yes. 16 Q. Were you a bit upset when — 16 MR. MERMELSTEIN: Form, asked and 17 A. Well, I was upset. 17 answered. 18 Q. — so you sort of cornered him into that 18 BY MR. LUTTIER: 19 or — 19 Q. Now, when she said she had to get, that he 20 A. No, I — he, he just came out and said that. 20 had asked his mom to get him checked, had, did he 21 I don't.. 21 tell you if the reason he had to get checked was 22 Q. And so what was your reaction when you — 22 because he had some kind of symptoms or something 23 when he made these comments to you and you said, 23 that he was worried about? 24 then you did have sex with 24 A. No. He was just worried because the condom 25 A. I already knew from people telling me, you 25 broke. Page 175 Page 177 know, throughout the rest of the year, you know, that 1 Q. Well, what would he get checked for 2 they knew and they found out. And my reaction, I mean, 2 because a condom broke? 3 I already 'mew it regardless if he admitted it or not 3 A. I guess just berm CP you use a condom so much, 4 When he admitted it, I was just like he's just a liar 4 and if it breaks you just get scared. 5 that didn't tell me the truth. I was upset. 5 Q. Well, that would be scared primarily of 6 Q. So certainly that caused you at that 6 pregnancy, right? 7 point — did that cause you at that point to, to 7 A. Well, that was one of the issues also that I 8 have some level of distrust with him? 8 found out later. 9 A. Yes. 9 Q. Well, he wasn't getting checked. He 10 Q. Because he had denied something that you 10 wasn't worried about him being pregnant 11 had specifically asked him about, right? 11 A. No, but he was also getting checked just 12 A. Yeah. 12 because the penis touched the vagina and, you know, if, 13 Q. You thought you and he had a, a romantic 13 you don't know what people have. 14 relationship that was exclusive to the two of you. 14 Q. Well, was there some issue about whether 15 A. Yes 15 M. had any kind of sexually transmitted disease? 16. Q. And then you found out he lied to you. 16 A. No. 17 A. Yes. 17 Q. Did he indicate to you that he had any 18 Q. Do you think that contributed a little bit 18 symptomatology that caused him to think that maybe 19 to your, some of your marital problems down the 19 he should get checked? 20 road? 20 A. No. 21 MR. MERMELSTEIN: Pam. 21 Q. When you — did there come a time that you 22 THE WITNESS: It could. It, it could be 22 confronted II. about the fact that she had denied 23 some of it. I mean, 'don't — I wish I knew 23 that she had had sex with the, the fellow that 24 what caused our problems, but, I mean, that's 24 became your husband? 25 part of it. 25 A. I confronted her, like I said, in the parking 45 (Pages 174 to 177 PROSE COURT REPORTING AGENCY, INC. EFTA01076428 Page 178 Page 180 1 lot with a They both denied it And at first I 1 Q. Now, this is an event that happened over 2 believed them, but then I had more people telling me 2 six years ago? 3 that it was true. So I don't remember how this 3 A. Yeah, my sophomore year. 4 happened, but she ended up moving to Fort Lauderdale 4 Q. Would you agree with me that your memory 5 when, you know, I had enough people telling me that they 5 about that event now is not precise? 6 actually did have sex, and I lost it on her, and she 6 MR.MERMELSTEIN: Form. 7 still denied it when she moved away. But after that I 7 THE WITNESS: I remember pretty much what 8 don't, I don't recall her ever -- me and her ever 8 haPPened• 9 talking about it and admitting it. BY MR. LUTTIER: 10 Q. Okay. What -- when did you first meet 10 Q. That's not my question. Would you wee 11 MI? 11 with me that your memory about the incidents that 12 A. O That was middle school. I met her 12 happened in '03, specifically with respect to 13 at I think my middle school was 13 Mr. Epstein, is not precise? 14 called in Wellington, when I moved with my father. But 14 MR. MERMELSTEIN: Form. 15 I wasn't friends with her in middle school. I just knew 15 THE WITNESS: As in exactly what happened? 16 of her. 16 BY MR. LUTTIER: 17 Q. When did you become friends with her? 17 Q. Yes. 18 A. My freshman or sophomore year. I think it was 18 A. I remember pretty much what happened, yes. 19 my freshman. 19 Q. Can you say with absolute certainty 20 Q. And when did you first learn that she had 20 everything that happened? 21 been to Mr. Epstein's? 21 MR. MERMELSIEIN: Form. 22 A. She actually went with and I wont with 22 THE WITNESS: Every little, little detail, 23 in the car with them. That's the only time that I 23 probably not. But everything that I remember, 24 know of. 24 you know, I remember pretty much everything 25 Q. Okay. Let's talk about that. When did it 25 that — I mean, I know it's confusing. I'm Page 179 Page 181 1 occur, in terms of time, when you and and - 1 sure there's little things that I don't 2 went to Mr. Eain's? 2 remember, but I remember the majority of what 3 A. Well, M. and I went first. Do you want to 3 hwertd 4 know about the instance with la? 4 BY MR. LU'rITER: MR. NIERMELSIEIN: That's what he asked 5 Q. Well, you, you remember I asked you about 6 you. 6 Dr. l= earlier? 7 MR. LUTTIER: Yeah. 7 .nes. 8 THE WITNESS: Okay. The time frame? 8 Q. You told me you told Dr. the truth? 9 BY MR. LUTT/ER: 9 A. Yes. 10 Q. Yeah. 10 Q.. Whatever you told Dr. was the truth 11 A. It was sophomore year. I was withIN and 11 when you said it? 12 M. and they wanted to go to the house, and I was in 12 A. Yes. 13 the car with them. 13 Q. You told Dr. yourself that you 14 Q. Okay. How, how were you able to identify 14 couldn't remember a of specifics about your 15 it was your sophomore year? 15 visits with Dr. — I mean, with Mr. Epstein, didn't 16 A. Because when I went, it was when my father 16 you? 17 lived in Rinks Forest, and ! lived in Binks Forest for 17 MR. MERMELSTEIN: Form. 18 my freshman and my sophomore year. 18 THE WITNESS: Which hand he used and 19 Q. Do you have any record which reflects when 19 things like that; I don't seliamber specifics 20 you went to Mr. Epstein's house? 20 like that. 21. A. No. 21 BY MR. LUTTIER: 22 Q. Do you know of the existence ofany notes 22 Q. Do you remember telling Dr. ME tir. 23 that you kept or calendars or anything like that 23 your recollection about what hap was? clea; 24 where you recorded the information? 24 MR. MERMELSTEIN: Form. . 25 A. No. 25 THE WITNESS: Did he say it in a different • 46 (Pages 178 to 181) PROSE COURT REPORTING AGENCY, INC. EFTA01076429 Page 182 Page 184 1 way, or did he say it just like you're saying 1 these are your words, "what hand he used". 2 it? 2 A. I mean, if I don't remember, I don't know how 3 BY MR. LIJITIER: 3 Pm supposed to tell you. 4 Q. I'm, Pm just-- myation to you is: 4 Q. Well, for example, you would admit that 5 Do you recall telling Dr. that your 5 you don't really recall specifically what clothes, 6 recollection about events that occurred when you 6 that is, which items of clothes you had on at the 7 were at Dr. — I mean, Mr. Epstein's, wasn't clear? 7 time that you were at Mr. Epstein's, do you? 8 MR. MERMELSTEIN: Font. 8 A. I don't remember exactly what I was wearing, 9 THE WITNESS: I don't remember telling him 9 no. 10 that but, !mean, I might have. 10 Q. Well, you don't remember if you had, for 11 BY MR. LUITIER: 11 example, your bra on or you didn't have your bra on, 12 Q. Do you remember telling him that you 12 do you? 13 couldn't remember certain things about what 13 A. I took my bra off. 14 happened? 14 MR. MERMELSTEIN: Form. 15 A. Well, yeah. There's certain, like I just 15 BY MR. LUTHER: 16 said there are certain things that I probably don't 16 Q. Do you remember telling Dr. that 17 remember, but I remember the majority of it. 17 you weren't sure whether you had your bra on or off? 18 Q. But there were significant things about 18 A. Yes, and I remembered. 19 your visits with Mr. Epstein that you couldn't 19 Q. So, you told Dr. 20 recall; isn't that right? 20 A. Yes. 21 MR. MERMELSTEIN: Form, lack of 21 Q. — a year ago when you saw him, right? 22 foundation. 22 A. Yes. Was it a year? 23 THE WITNESS: But as in what? Like, you 23 Q. A year ago. Whenever it was. 24 mean — 24 A. Okay. 25 25 Q. Whenever that — okay. And you told him Page 163 Page 185 1 BY MR. LUTTIER: 1 the truth then, right? 2 Q. Well, is there anything, anything that you 2 A. Yes. 3 would consider to be a significant part of your 3 Q. So if you told Dr. a year ago that 4 visits with Mr. Epstein that you admit you cannot 4 you don't recall if you had your bra on or not, that 5 specifically recall? 5 was a true statement when you made it to him. 6 A. In any way? 6 MR. MERMELSTEIN: Form, lack of 7 Q. In any way. 7 foundation. 8 A. Yes. 8 BY MR. LUTHER: 9 Q. Okay. What significant events that would 9 Q. Is that right? 10 have occurred when you visited Mr. Epstein do you 10 A. Yes. 11 acknowledge that you do not have a specific 11 Q. All right. Are you now telling us that a 12 recollection about? 12 year later you now have a specific recollection? 13 A. As in, like, which hand he used, I don't 13 A. Yes. 14 remember. 14 MR. MERMELSTEIN: Form, lack of 15 Q. So you don't know what hand he used. 15 foundation. 16 Anything else that you can — that you admit you 16 BY MR. LUTHER: 17 don't have a specific recollection about? 17 Q. And is there something that clarified your 18 . A. You've got to give me a second. 18 recollectionteen the last time you saw 19 I mean, exactly, you know, what was 19 Dr. Lim — which I believe was in '09, and 20 on the walls, things like that, exactly what the 20 now? 21 house looked liked. 21 A. !just thought about it. Things come back to 22 Q. !want you to tell me things that you say 22 me. 23 as you sit here today you acknowledge you don't have 23 Q. So six years later, what you couldn't 24 a specific recollection about with respect to your 24 recall five years ago, or what you couldn't recall 25 visits with Mr. Epstein. So far you've told me, and 1:appened, five yeas previousl1, you noN . can 47 (Pages 182 to 185) PROSE COURT REPORTING AGENCY,. INC. EFTA01076430 Page 186 Page 188 1 recall? 1 Q. Going over your case with whom? 2 MR. MERMELSTEIN: Form, lack of 2 A. My attorneys. 3 foundation. 3 Q. Okay. So, your — 4 THE WITNESS: Yes. 4 MR MERMELSTEIN: And, of course, you kno 5 BY MR. LU'TTIER: 5 not to talk about what you discussed with your 6 Q. And is there anything that refreshed your 6 attorneys. 7 memory? 7 BY MR. LUTI1ER: 8 MR. MERMELSTEIN: Form, lack of 8 Q. So, the refreshing of your memory comes as 9 foundation. 9 a result of communications with your lawyer? 10 THE WITNESS: It could have been that I 10 MR. MERMELSTEIN: Objection to form. Do 11 mean, I don't remember if I didn't remember 11 not testify. Don't answer that question 12 when I didn't tell him or if I was embarrassed 12 because it — 13 because I didn't tell him. I don't remember 13 BY MR. LIMIER: 14 exactly why I didn't tell him or it just 14 Q. Did you tallc — 15 didn't, you know, hit me when I was talking 15 MR. to is — requires 16 about it. 16 attorney-client privileged conununications. 17 17. BY MR. LUTI1ER: 18 19 BY MR. LUMER: Q. well, you, you, you told DE whole truth. That's what you told me, right? the 18 19 Q. Have you talked to any of your girlfriends that went to see Mr. Epstein since you went to 20 A. Yes. 20 Dr. 21 Q 111ere was all kinds of sluff you told 21 A Since I went to Dr. a 22 Dr. that you would ordinarily fmd to be 22 Q. Yep. 23 enibarrassing, wasn't there? 23 A. About the - about what happened at Epstein's 24 A. Yes, 24 house? 25 Q. You told him about the most intimate 25 Q. Page 187 Page 189 1 details about your life, did you not? 1 A. Not that I recall. 2 A. Yes. 2 Q. Did you for ever have any conversations 3 Q. So you didn't not tell Dr. 3 with MI, for example, where you said, you know, 4 something because you were embarrassed, did you? 4 wont, words to the effect of, you know, do you 5 A. There was embarrassing things that, you know, 5 remember what happened and sort of discuss it or 6 that went through my mind and stuff, and I mean, I told . 6 compare notes about it? 7 him a lot, yeah. 7 A. I mean, we, we've talked about his house, but 8 Q. Now, my question is specific. There is 8 we didn't, like, discuss notes about it. 9 nothing that you did not tell Dr. when you 9 Q. I mean, when you talked about what 10 met with him because you were embarrassed to tell 10 occurred when you were at his house, did you ever, 11 him, was there? 11 from the, from the day you went to Mr. Epstein's 12 MR. MERMELSTEIN: Form. 12 until today, ever have a discussion with M. about 13 113E WITNESS: No. 13 what occurred when you and she were OW. Epstein's 14 BY MR. LUTHER: 14 house? 15 Q. Rephrase the question. Was there anything 15 A. To since the day we went to his house? 16 that you did not tell Dr. =, when you met with 16 Q. Absolutely. 17 him, because you were embarrassed to tell him about 17 A. Yes. 18 it? 18 Q. Okay. When was the first time you 19 A. No. 19 discussed it? 20 Q. Okay.&l een done anything since you 20 A. Probably right after we left. 21 met with Dr. to refresh your recollection 21 Q. Well, you say "probably." Does that mean 22 about events that occurred when you were with 22 you're not sure? 23 Mr. Epstein? 23 A. Most liltely right after we left. 24 A. Just going over my case and thinking about 24 Q. Okay. Do you have a specific recollection 25 what I did. of the conversation? 48 (Pages 186 to 189) PROSE COURT REPORTING AGENCY, INC._ EFTA01076431 Page 190 Page 192 1 A. Just that we can't believe what just happened 1 part of the year? 2 to us. 2 A. Yes. 3 Q. No. Let me — I want do this in, in 3 Q. Year starts — your sophomore year would 4 steps. Do you have a specific recollection of your 4 have started in approximately August of'02? 5 conversation with M.? 5 A. Yes. 6 A. Parts of it, yes. 6 And it concluded in approximately June of 7 Q. Okay. Are there parts of it you don't 7 '03? 8 have a specific recollection about? 8 A. It ended? 9 A. Yes. 9 Q. Yeah. 10 Q. All right. So then you acknowledge there 10 A. Yes. 11 were some things that you don't remember about your, 11 Q. Okay. So your bea recollection is you 12 the events that transpired at Mr. Epstein's; is that 12 first heard of Mr. Epstein's name sometime between 13 correct? 13 August of'02 and October of'02. You said it was 14 MR. MERMELSTEIN: Objection. You're prior 14 the beginning of the year. 15 question was just about her conversation. 15 A. Yeah. I mean, yeah 16 MR. LUTHER: Okay. Wait a minute. 16 Q. Let make:An:1TM clear. I'm not 17 Don't, don't speak. 17 trying to put a date in your memory. 18 BY MR. LUTTIER: 18 When you said -- we've identified 19 Q. We'll take it in two steps. There are, 19 that your sophomore year started in August of'02 20 there are sub-portions of the conversations you had 20 and ended in June of '03, right? 21 with ■. immediately after going to Mr. Epstein's 21 A. Yes. 22 house with her that you don't recall; is that 22 Q. Okay. So when you said you first heard of 23 correct? 23 Epstein's name in the beginning of your sophomore 24 A. As of right now, yes. 24 year — 25 Q. All right. Would you agree with me 25 A Yes. Page 191 Page 193 1 there's also events that occurred when you and M. 1 Q. -- that would be sometime after August of 2 went to see Mr. Epstein that you don't recall? 2 '02? 3 MR. MERMELSTEIN: Form, overbroad. 3 A. Yes. 4 THE WITNESS: Today? 4 Q. And when you said the beginning, what do 5 BY MR. LUTHER: 5 you mean, August, September, October, or... 6 Q. Yes. 6 A. I don't know which month. It was in the 7 A. Yes. 7 beginning of the school year. 8 Q. All right. All right. So what's your 8 Q. Within the first couple months? 9 best recollection of your discussion with ■. when 9 A. Probably. 10 you and she went to Mr. Epstein's? 10 Q. So August or September would be a fair 11 A. The story of what happened? 11 estimate? 12 Q. Well, if you want us to — let's just 12 A. Yes, I mean, I had, yes. 13 start — let me, let me back it up. 13 Q. Okay. So August or September of'02, what 14 There came a point in time that you 14 is it you first hear about Mr. Epstein? 15 heard something about somebody named Mr. Epstein; is 15 A. I don't know exactly what I heard. I just 16 that right? 16 heard something about, if you go to this man, Jeffrey 17 A. Correct. 17 Epstein's house, and you give him a body massage, you 18 Q. When did you full hear of Mr. Epstein? 18 get $200. 19 A. It was in high school. 19 Q. And in this first occasion that you heard 20 Q. When in high school? 20 about it, was — did Mr. Epstein's name come up, or 21 A. I'm going to say my sophomore year. 21 were you just told, if you go to somebody's house 22 Q. Okay. When in your sophomore year? 22 someplace you can get some money? 23 A. I'm approximating because I don't know the 23 A. It was probably somebody's place; it wasn't 24 exact date, but probably in the beginning. 24 his specific name probably. 25 Q. Okay. "Beginning" meaning in the first 25 Q. Before you first went to Mr. Epstein's 49 (Pages 190 to 193) PROSE COURT REPORTING AGENCY, INC. EFTA01076432 Page 194 Page 196 1 house for the first time, did you know his name? 1 or not — 2 A. Before -- yes, before I went to his house. 2 A. Yes, l am. 3 Q. So, at some point before you went there 3 Q. Just, if you're, if you're just 4 for the first time, you knew that you were going to 4 speculating and guessing, just, just — it would be 5 go see somebody named Jeffrey Epstein. 5 better to tell me you don't know. 6 A. Correct. 6 A. Okay. 7 Q. Do you recall when it was you first heard 7 Q. All right. But if you, if you have a a his name? 8 specific recollection, tell me. 9 A. No, l don't recall that. 9 A. Okay. 10 Q. Do you know it if you heard his name in 10 Q. But if it's — if you just don't recall, 11 the first conversation about making some money doing 11 there's nothing wrong with just saying you don't 12 a massage, or was it in a later conversation? Do 12 recall. 13 you understand my question? 13 A. Okay. 14 A. I understand your question. I just — 14 Q. All right. So I want to be fair to you. 15 Q. In other words, were you, did you 15 I don't want you to speculate. 16 initially just hear, you know, nunor, for lack of a 16 A. Okay. 17 better -- that you could go give somebody a massage 17 Q. What happened — what did you do after you 18 for $200, or was it you go give Mr. Epstein a 18 heard this conversation for the first time? 19 massage for $200? 19 A. I believe I mentioned it to 20 A. I think it was somebody a massage. 21 Q. And what did you tell 21 Q. Okay. And, and did you understand where 21 A. That I was interested in going there, but I 22 it was going to be, what town? 22 warned her to come with me. 23 A. No, I didn't have all the specifics on it. 23 Q. Well, had when — do you recall 24 Q. So, so your best recollection today is 24 whether or not, you first mentioned it to., 25 sometime in August, September, October of '02, 25 5 had heard anything about it? Page 195 Page 197 1 somebody told you that you could give somebody a 1 A. I don't recall. 2 massage and get $200. 2 Q. When did you form the opinion that you 3 A. Yes. 3 wanted to follow up on this manor that you had 4 Q. Is there anything more you can recall 4 beard? 5 about the first time you became aware of anything 5 A. I don't {MOW who told me, but the person that 6 that was related to Mr. Epstein? 6 did tell me made it seem like it was just, you go there, 7 A. With that conversation, with somebody telling 7 you give him a massage, you get $200. And to me $200,1 8 me about — 8 was hike, yeah, why not. 9 Q. Yeah, was that the first time you heard 9 Q. And do you blow how long it was from the 10 anything about any of it? 10 • time you first heard it that you approached 11 A. Yes. 11 about doing it? 12 Q. Okay. Anything else you can recall about 12 A. I don't recall. I don't know. 13 the conversation? 13 Q. Okay. So you were — you — did you 14 A. No. 14 approach anybody other than 5? 15 Q. Do you know who told you this? 15 A. No. 16 A. No. 16 Q. So you go to 5. and you tell her, I 17 Q. Was it while you were at school that you 17 heard this story that 1, we can go make $200 giving 18 heard this? 18 somebody a massage? 19 A. Yes. 19 A. Yes. 2i Q. Okay. Do you know if the person that told 21 Q. Did you tell her anything more at that 21 you was someone that had done that? 21 time? 22 A. Most likely. 22 A. That's all -- 23 Q. But you can't tell me? 23 Q. Did you know where it was going to be? 24 A. I don't know who it was, though. 24 A. No. 25 Q. So you're, you're sort of guessing whether 25 Q. Did you know it was going to be in Palm 50 (Pages 194 to 197) PROSE COURT REPORTING AGENCY, INC. EFTA01076433 Page 198 1 Beach? 2 A. No. I don't even know how 1 found out it was 3 in Palm Beach. It was — the person that told me about 4 it, I don't, I don't recall exactly what hmp_ened. But 5 somehow when I decided to go there, M, 6 Jeffrey Epstein's assistant, contacted me and was the 7 one that set up the reservations. 8 And after this, can I take, lb 9 sony, another break to use the restroom? 10 MR. LUTTIER: Sure. We might as well just 11 take a lunch break. 12 MR. MERMELSTEIN: Yeah. 13 THE VIDEOGRAPHER: Going off the record at 14 12:24 M. 15 (A luncheon recess was held.) 16 • • • • * 17 18 19 20 21 22 23 24 25 51 (Page 198) PROSE COURT REPORTING AGENCY, INC. EFTA01076434 Page 199 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME II OF II JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JANE DOE NO. 5 Friday, February 26, 2010 8:07 - 3:44 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1312 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (S01-061-976-2934) Electronically signed by cynthia hopkins (601.061-976-2934) Electronically signed by cynthia hopkins (601.051.976-2934) 1a30246a-bc9d-4107.90a14373e816de0d EFTA01076435 EFTA01076436 Page 200 Page 202 / APPEARANCE& 1 CONTINUED PROCEEDIN GS 2 On behalf of the PlaintifE 2 3 STUART S. MERMELSTE1N, ESIIRE MIRINELSTEIN & HOROWITZ, 3 THE VIDEOGRAPHER: We're back on the 18205 Biscayne Boulevard 4 record at I:38 Suite 2218 5 BY MR. LUTTI Marna, Ibrida 331 6 Phone: Q. Okay. I want to go back over one of the E-mail: 7 issues that you mentioned and ask you a little bit On be,haif o • 8 more about it. ROBERT D. CRII7ON, IR, ESQUIRE 9 Can you tell me where you were physically MARK T. LUTTLER. ESQUIRE 9 BURMAN, CR111014, LUTT1ER & COLEMAN,UP when you first heard about the opportunity to give a 303 Banyan Boulevard 11 person a massage for the $200? Suite 400 12 A. I was in school. WestPallainda s • 33401 13 11 Phone: Q. Okay. Do you know— and you said you 12 14 don't know who it is that told you. Do, do you know 13 15 what your relationship with the person was that told 14 ALSO PRESENT: 16 you about this opportunity? 15 16 Sasdra Quimby, Vicieographer 17 A. I don't remember who the person was, so I Visual Evidence, Incorporated 18 don't recall if they were a friend of mine or we were in 17 19 a group of people and somebody mentioned it I don't 19 21 recall exactly what happened. 19 20 21 Q. Do you know where you were at school when 21 22 this conversation occurred? 22 23 A. No. 23 24 24 Q. Was there anyone else present when this 25 25 unnamed person told you of this opportunity? Page 201 Page 203 1 1 A. Not that I remember. It could have been a 2 INDEX 2 group of people that were — you know, they mentioned 3 3 it, or it could have been, you know, just one person. 4 4 Q. Well, do you recall, when you first beard 5 EXAMINATION DIRECT CROSS REDIRECT 5 the nosy from this person, other people around and 6 CONTINUED EXAMINATION OF 6 saying anything about it? 7 JANE DOE NO. 5 8 7 A. No. BY MR. CRITTON 200 9 8 Q. Do you recall if this person was 10 9 addressing you alone or anybody else when the 11 1 statements were made? 12 11 A. I don't recall if — I don't recall, like, 13 12 what happened exactly when they were telling me about 13 it 14 NO EXHIBITS MARKED 14 Q. What, what can you recall about the 15 entirety of the conversation with this unnamed 15 16 person? 16 17 A. I just remember them telling me -- or it 17 18. 18 was — I don't — see, I don't remember the specifics, 19 19 but I remember, you know, they said, you go to this 20 21 guy's house, give him a massage for $200. 21 21 Q. Did you — how did you respond to that 22 22 statement? 23 23 A. I thought about it. 24 24 Q. So you didn't orally respond to the 25 25 statement? 2 (Pages 200 to 203 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801-051-976-2934) Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1a30246a-bc9d-4107-90a1-6373e816de0d EFTA01076437 Page 204 Page 206 A. Not that I recall. 1 the person, right? 2 Q. You don't recall malting any statement at 2 A. I don't recall If I did. 3 all after that? 3 Q. Okay. You —well, you didn't give this 4 A. I don't recall that. 4 person your phone number, did you? 5 Q. What's the next thing that occurred when 5 A. The person I was speaking to? 6 you and this person were having this conversation? 6 Q. Right. 7 A. I don't recall. I don't know. 7 A. It could have been a friend of mine. I don't 8 Q. And do I understand your testimony to be 8 remember the person specifically. I don't know if I 9 that you're not sure that these were the words that 9 went back to that specific person and said I was 10 were actually spoken? 10 interested, you know, here's my number. I don't, I 11 A. I know those were the wants that were actually 11 don't know. 12 spoken. That's all I knew of it, that it was a massage 12 Q. What's the vety next thing you can recall 13 for $200. 13 about your going to Mr. Epstein's after this 14 Q. So you have a specific recollection 14 conversation with this unnamed person? 15 somebody, who you don't recall, said to you at 15 A. So you're asking what did 1— what was my 16 school -- 16 next step that I remember after this person told me 17 A. 1Uh-huh, yes. 17 about — 18 Q. — although you don't know if there was 18 Q. The very »eott — yeah, the very next thing 19 anyone else present, that you could go to a person 19 that you did that had anything to do with — 20 and give him a massage and get $200. 20 A. Even if it was days later? 21 A. Yes. 21 Q. Whenever it was, ,.. kgituse that's going — 22 Q. Is there anything more you can recall 22 A. I remember I toldM. about it. 23 about the conversation? 23 Q. Okay. That's the next thing that 24 A. No. 24 happened? Nothing happened between thisag amed 1 25 Q. Was there any name used? 25 person telling you of this and you talking toM.? Page 205 Page 207 1 A. As in Jeffrey Epstein's name? 1 A. I don't 'litany, but I thinkI 2 Q. Any name. 2 probably talkedreta .ecfirst before I decided to do the 3 A. I don't recall. 3 massage for $200. 4 Q. Do you recall — I mean, when you say you 4 Q. Okay. And you talked to because she 5 don't recall, does that mean the name could have 5 was your best friend at the time? 6 been said, or you don't believe that a name was 6 A. Yes, we were close. 7 said? 7 Q. Any other reason why you, out of — 8 A. It could have been said. I don't remember. 8 THE VIDEOORAPHER: Excuse me, sir, which 9 Q. Did you, did you ask any questions in 9 button did you push? I just got a text that 10 response to this statement from this person? 10 this has been muted. 11 A. I don't remember if I did. 11 MR. MERMELSTEIN: Oh great. 12 Q. Was there any additional information given 12 THE VIDEOGRAPHER: Okay. I just got a 13 to you by this person other than that there was an 13 text from my boss saying it's been muted. 14 opportunity to go to a person's house and give the 14 (Discussion off the record.) 15 persona massage for $200? 15 THE VIDEOGRAPHER: Let muga ahead and 16 MR.. MERMELSTEIN: Objection, asked and 16 stop it. Going off the record at 3:45... 17 answered. 17 Oh, Pm sorry, 1:45. 18 THE WITNESS: All! recall is that this 18 (A brief recess was held.) 19 person told me it was a $200 mmotssage. And 19 THE VIDEIIRAPHER: We're back on the 2. somehow, I don't remember, IIM contacted us 20 record at 1:50 21 and made ttte — for us to go to his house and 21 MR. LUMER: All right. What was the 22 do the massage. 22 last question? 23 BY MR. LIMIER: 23 (The requested portion of the record was 24 Q. Okay. So, so now this person that said 24 read by the reporter.) 25 fl e.s these thin"_anz yStenee • i ous cicto 'I ' 25 j .... 3 (Pages 204 to 207 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (601-051.976.2934) Electronically signed by Cynthia hopkins (601.051.976-2934) la30246a-bc9d-4107-90a1-6373e816de0d Electronically signed by Cynthia hopkins (601-051.976.2934) EFTA01076438 Page 208 Page 210 BY MR. LUTHER: 1 it, but — 2 Q. And I apologize if I asked this, because I 2 Q. Okay. What is it that you recall that 3 lost my train of thought: How long was it between 3 causes you to say that you know it was along those 4 the time you first heard this and you talked to 4 lines? 5 5 A. What is it that I recall? Because I know she 6 A. I said I didn't recall how long it was. It 6 questioned it when I made that statement. She was 7 could have been a couple of days. I, I don't remember. 7 curious about the situation. 8 Q. Could it have been weeks? 8 Q. And, and what did you tell her in 9 A. It could have been. I don't remember response? 10 specifically. 10 A. I said, yeah, that's what I was told. 11 Q. Did it take you this period of time before 11 Q. And did you tell her who had told you 12 you &alai. to decide whether or not you were going 12 that? 13 to do this? 13 A. I don't remember. 14 A. I'm sorry. What did you say? 14 Q. Okay. 15 Q. Did it take you that period of time 15 A. !just, I mean, there's... 16 between when you first heard it and talked tea. 16 Q. After the first time this unnamed person 17 to make up your mind whether or not you wanted to do 17 told you about this opportunity, did you ever have a 18 this? 18 conversation with that unnamed person again about 19 A. Yeah. 19 it? 20 Q. So, you had given this conscious thought? 20 A. Like I said weviously, I don't recall if I 21 A. I gave it a thought of, it was a massage for 21 did, but someho got my number, so I'm guessing I 22 $200. I was young, naive, and it was $200 in my pocket 22 might have went back to the same person that told me and 23 fora massage. 23 said, yeah, I would like to do it and they probably gave 24 Q. Had you ever given anybody a massage ever 24 them my number. I don't know. Honestly, I have -- I 25 in your life up to that point in time? 25 don't really remember. Page 209 Page 211 1 A. With — you know, with my friends and stuff, 1 Q. Well, you have no recollection at all 2 like but it wasn't, l wasn't a masseuse. 2 about that; is that right? 3 Q. Did you know anything about how much a 3 A. Yes, I flies)... 4 massage cost? 4 Q. So you, you — this isn't a situation 5 A. No. 5 where you have -- you, you recall doing that, but 6 Q. Did you ask anybody? 6 you can't remember the exact words. You don't 7 A. No. 7 really have a recollection about whether you did 8 Q. Did you ever make any inquiry about 8 that or not? 9 anybody receiving $200, you know, the going rate, 9 A. As in what? Like, Ala? 10 for example, anything like that? 10 Q. That you went back to this person and 11 A. No, it sounded good. 11 said — 12 Q. Okay. So, when you toldM., what was 12 A. Yeah, I don't know. I ;mow that 13 her fast statement to you? 13 contacted me. I don't know how. 14 A. You've got to give roe a second. 14 Q. Well, let me get over there. Did you 15 I'm not 100 percent positive, but I think 15 have — do you have a specific recollection of 16 it was something along the lines as of all we have 16 giving your phone number to anybody with respect to 17 to do is give a massage for 200. That's it. 17 this opportunity? 18 Q. That's, that's Alas.,. said to you? 18 A. I don't 19 A. Yes. 19 Q. All right. Did you, did — were you the 21 Q. Was it a statement or a question? 20 person that took the next step insissing this 21. A. It was question. Like, you know, from what 21 series of events to occur, or didM. do something? 22 I've heard, I was like, yeah. 22 A. I'm pretty sure I did it. 23 Q. Okay. 23 Q. Okay. Now, isn't it afitgifiat you were 24 A. And I don't know if it was exactly that, but I 24 the one that callginthis lady, =II? 25 know it was al the lines of ou blow 25 A. I called =? 4 (Pages 208 to 211) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla napkins (001.051-976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) la30246a-bc9d-4107-90a1-6373e816de0d Electronically signed by cynthia hopkins (601-051-976.2934) EFTA01076439 Page 212 Page 214 Q. Yeah. 1 A. I'm not 2 A. I don't recall calling. I know I called to 2 Q. Specifica*ou told me that when you 3 get directions, stuff like that, but... 3 met with Dr. ou told him the absolute truth 4 Q. My, my question — have you ever told 4 about everything; isn that right? 5 anybody that you were the one that called -t o 5 A. Yes. 6 set up the, the massage? 6 You told me that when you met with 7 MR. MERMELSIEIN: Form 7 Dr. ou told him the absolute truth about 8 THE WITNESS: No. 8 ng. 9 BY MR. LUTTIER: 9 A. Yes. 10 Q. If you told someone that in the past, 10 . So if you made a statement to either 11 would it have been accurate when you told them that? 11 Dr. or Dr. allg ait was a true statement that 12 MERMELSTEIN: Objection to form. 12 you to him; is right? 13 THE WITNESS: No. 13 A. Yes. 14 BY MR. LUMER: 14 Q. So, if you told Dr. a Dr. 15 Q. In other words, you wouldn't have just 15 that you and/or1. call that=fime 16 made it up, right? 16 you made the sta ement to them, i was true? 17 MR. MERMELSTEIN: Objection to form, 17 MR. MERMELSTEIN: FORD. 18 foundation. 18 THE WITNESS: I didn't say that. 19 BY MR. LUTTIER: 19 BY MR. LUTITER: 20 Q. Would, would you have just made. 20 Q. Well, that's not my question. You, you 21 statement to the effect that you contacted 21 admit that if you made that statement to either 22 MR. MERMELSTEIN: Objection to onn. 22 Dr. Moe Dr. a it was true when you made 23 THE WITNESS: No. 23 the statement? 24 BY MR. LUTHER: 24 MR. MERMELSTEIN: Fonn. 25 Q All right. Did you ever tell anyone that 25 THE WITNESS: If I made a statement to Page 213 Page 215 1 it was either you or but one of the two of 1 them? 2 you, that contacted 2 BY MR. LUTHER: 3 MR. MERMELSTEIN: Form. 3 Q. Yep. 4 THE WITNESS: I don't recall that 4 A. Yes, it would be true. 5 BY MR. LUTHER: 5 Q. Okay. Now, you just said you didn't tell 6 Q. If you did tell someone that in the past, either one of those individuals that. How do you 7 was it true when you made the statement? 7 know that? 8 MR. MERMELSTEIN: Font. 8 A. Because I don't recall. All I recall is that 9 THE WITNESS: Say that one more time. 9 she called me somehow. So why would I say that — 10 BY MR. LUMER: 10 Q. fact — 11 Q.' If you did tell someone that in the past, 11 A. — that I called them? 12 was it true when you made the statement to them? 12 Q. — of the matter is that you really don't 13 MR. MERMELSTEIN: Form. 13 know whether or not ou made that statement to 14 THE WITNESS: No, because I didn't. I 14 Dr. or Dr. you're just guessing that 15 don't do that. 15 yougi make the ement, aren't you? 16 BY MR. LUTHER: 16 MR. MERMELSTEIN: Form. Your question 17 Q. Well, you would, you — if you made that 17 calls for her to guess. 18 statement, you believed at the time you made the 18 THE WITNESS: I know I, I wouldn't make 19 statement that it was a true statement, did you not? 19 that statement berange Pm telling you what 1 20 MR. MERMELSTEIN: Form. 20 feel, end what I feel is from what I remember, 21 IRE WITNESS: You're confusing me. I'm 23. is I didn't call 22 confused. 22 BY MR. L • 23 BY MR. LUITlER: 23 Q. Would it be son of to cut to the 24 Q. Well, I want to make sure you're clear 24 chase, would it be a fair statement to say you 25 about this. 25 really don't recall who called who? 5 (Pages 212 to 215) PROSE COURT REPORTING AGENCY INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1030246a-bad-4107-90a1-8373e816610d EFTA01076440 Page 216 Page 218 1 1 MR. MERMELSTEIN: Form. 1 that conversation? 2 THE WITNESS: I knovI know that I didn't 2 A. From what I remember, it was when I can go to 3 call her first. I didn't call arst. 3 the house to do the massage and how to get there. 4 BY MR. LUTHER: 4 Q. Well, wait a minute. I'm going to go take 5 Q. Well, if you, if you don't — what Pm 5 this in steps. Do you, as you sit here today, have 6 trying to find out is, is whether you have a 6 a specific recollection of the conversation? 7 specific recollection or you're just concluding what 7 A. Yes, it was along those lines. 8 happened based upon your recollection of other 8 Q. No, I want to know. Can you tell me what 9 events. Do you know what Pm saying? 9 was said to you by this person on the other end of 10 MR. MERMELSTEIN: Form. 10 the phone? 11 BY MR. LUTTIER: 11 A. I can't tell you every little detail. 12 Q. In other words, you either know for a 12 Q. Can you tell me what you said to this 13 fact, you have a specific recollection of who called 3 person on the other end of the phone? 14 who, or you don't have a recollection, but you're, 14 A. No. 15 you're assuming that they called you, or whatever, 15 Q. I want to know what -- when, when you 16 from a different set of facts. 16 first got this phone call that you claim you got, 17 A. No, l know they called me. 17 where were you? 18 Q. Okay. So if you know that they called 18 A. I was probably at home. That's not -- 19 yousa would you tell either Dr. or 19 Q. And I don't want to know probably. Are 20 Dr. that youiliodrEgla lled 20 you saying you don't know? 21 MR. ME : Form, lack of 21 A. I don't know. 22 foundation. 22 Q. Okay. Fair enough. Do you remember how 23 MR. LUTHER: If you did. 23 long it was between the time you first heard of this 24 THE WITNESS: But I didn't. 24 opportunity and when you allegedly got this call? 25 25 A. I don't blow. Page 217 Page 219 1 BY MR. LUTT1ER: 1 Q. Do you remember on what phone you received 2 Q. Okay. Well, let's just assume for the 2 this alleged call? 3 purpose of this question that you made that 3 A. It was most likely my cellphone. 4 statement Tell me why that would ever be possible 4 Q. Doyou know specifically? 5 for ou to have to have made a statement to either 5 A Yes, because I wouldn't give them my house 6 Dr. or Dr. that you or. called 6 phone. 7 7 Q. Why not? MR. MERMELSTEIN: Form, lack of 8 A. Because my cellphone is on me at all times end 9 foundation 9 I was never home. 10 THE WITNESS: I don't, I don't — I'm, Pm 10 Q. Are you, are you certain — are you 11 getting confused because you're asking me a 11 guessing that you didn't give your home phone 12 question which I don't — I didn't make a 12 because you carry your cellphone, or do you know for 13 statement about that, so how can I answer that? 13 a fact? 14 BY MR. LUTTIER: 14 A. Well, l know fora fact that's what the 15 Q. Okay. Now, do you have a specific 15 phone I use all the time. 16 recollection of a phone conversation that you 16 Q. And what— how did this person that 17 personally had with this person you say is M? 17 called, how did they introduce themselves to you? 18 A. Epstein's assistant? 18 A. She said her name, hello, I'm =. I work 19 Q. 'ever you say im is. 19 for Jeffrey Epstein. And then I In: rdru were 20 A. I., Epstein's assistant, that got the girls 20 interested in the massage, and it went along those 21 to come there? 21 lines. I don't know the exact conversation. This 22 Q. I don't know who it is. You said there 22 was — you know, it was a while ago for the phone call. 23 was somebody named that called you. 23 Q. Six, seven years ago? 24 A. Yeah, there's a 24 A. Yes. 25 ' 9. Do you have a spec] c recollection of 25 Q. And did this eaytIleir name was 6 (Pages 216 to 219) PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601-061.976-2934) Electronically signed by cynthia hopkins (601.061.976-2934) Electronically signed by cynthia hopkins (601-061.976.2934) 1O024O-bc9d-4107-90a1-6373a 6dOd EFTA01076441 Page 220 Page 222 1 a or did they tell you their full name? 1 A. Between me and this unknown person? 2 A. 1 don't remember. 2 Q. Yeah. 3 Q. And arc you sure they said they worked for 3 A. I don't know. 4 Jeffrey Epstein? 4 Q. Do you recall what day of the week it was? 5 A. Pretty sure. 5 A. It was a school day. 6 Q. Was that the first time you ever heard his 6 Q. And how do you know that? 7 name? 7 A. Because I was in school when I heard about it. 8 A. I don't recall. 8 Q. I thought I asked you where you were when 9 Q. Did you say anything to him (sic) like 9 you got the phone call, and you said you didn't 10 who's Jeffrey Epstein? 10 recall. 11 MR. MERMELSTEIN: Form. 11 A. The phone call or when I talked to the unknown 12 THE WITNESS: No, I don't — 12 person? 13 BY MR. LUTHER: 13 Q. No, when you, when you received the phone 14 Q. Have you ever in your life received a, 14 call from this person. 15 just a call out of the blue from somebody saying, 15 MR. MERMELSTEIN: Well, you know, yintre 16 gee, would you like to come over and give me a 16 confusing her because shes already identified 17 massage or give somebody a massage? 17 the person she got the phoneys!l from as 18 MR. MERMELSTEIN: Form. 18 The unknown person was the person she 19 THE WITNESS: No. 19 'poke to. 20 BY MR. LUTHER: . MR. LUTTIER: No, no. Let me go back. 21 Q. So it was an unusual phone call? 21 BY MR. LUTHER: 22 A. No, because I discussed this with somebody 22 Q. You, you're the one, I believe, that made 23 previously. 23 areference to a phone call from an unknown person. 24 Q. Well, this was ■, right? 24 The person — 25 A. Well, in high school was when somebody told me 25 MR. MERMELSTEIN: No, she said a Page 221 Page 223 1 about the situation. So, like I'm saying, I'm not going 1 consistently. 2 to give you facts when I don't know exactly when it was 2 BY MR. LUTTIER: 3 when I spoke to the person, when — I, i can't give you 3 Q. The person that you talked to that you 4 a fact of what happened ifI gave, you know, them my 4 claimed was unknown wasn't a person that you had a 5 number whenI don't remember that part. 5 phone call with, was it? 6 Q. Okay. What did you say to this person in 6 A. The person i had a phone call with was 7 response? 7 Q. Right. So the only thing you can possibly a A. What person? 8 be talking about when you talked about a phone call 9 Q. Whoever it is you claim you had a 9 here, was this alleged call with M, right? 10 conversation with. 10 A. Yeah, -was — 11 A. Like I said, l da* remember. 11 Q. Didn't you tell me earlier you didn't know 12 Q. So you can remember what they said to you, 12 where you were when you got that phone call? 13 but you have no recollection what you said to them; 13 A. No, I don't know where I was when I got the 14 is that right? 14 phone call. 15 A. There's -- no. Mores things you're going to 15 Q. So you don't know if you were at school or 16 ask me that fm going to remember and I'm not going to 16 not. 17 remember. 17 A. No. I — when I talked to the tuilmovm person, 18 Q. Well, let's what I'm going to get that 18 I was at school. 19 point — 19 Q. Well, I just asked you when you got the 20 A. Yeah. There's — 20 phone call — • 21 Q. — so that the jury understands. You can 21 A. From the unknown person. 22 remember what this person said to you, but you can't 22. Q. — and you said it vvas, it was during the 23 remember what you said to than; is that right? 23 school week, right? 24 A. Yes. 24 A. I must have miss I must have misunderstood 25 l liow long did this conversation take? 25 ou, because you said the nokociuni 7 (Pages 220 to 223) PROSE COURT REPORTING AGENCY INC.. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051-976-29341 la30246a-bc9d-4107-90a1-6373e816doOd EFTA01076442 Page 224 Page 226 1 Q. All right. So let's go back. 1 A. Like, ever again? 2 A. Okay. 2 Q. Ever. 3 Q. Where were you, what, what day of the week 3 A. Yes. She contacted me again to come back to 4 was it that yovli ic lii. call from, from the person 4 the house. 5 that you say v a 5 Q. When did she do that? 6 A. I don't recall. 6 A. I think it was after the second time that I 7 Q. What time of day was it? 7 went. 8 A. I don't know. 8 Q. After the second time you went. And the 9 Q. So you don't know where you were, don't 9 second time is when you went with your friends? 10 know what time of day it was. Do you know how long 10 A. Yes. 11 the conversation took? 11 Q. Okay. And where did that conversation 12 A. It probably wasn't that long. 12 occur? 13 Q. Do you know v4tat was discussed other than 13 A. She -- Ilmow it was at a house. I don't know 14 you say that identified who she was? 14 whose house it was because I remember sitting on the 15 A. How long did it -- I'm sorry. 15 floor doing my makeup. And she called and asked if I 16 Q. What else did you discuss? What was said 16 wanted to come back or if I referred anybody to do the 17 other than the fact that sa she introduced 17 massage. And I said, no. And — 18 herself and said she sita. ? 18 Q. Go ahead. 19 A. She introduced herself and said, you're 19 A. I was — I blow I'm taking a lot of bathroom 20 interested in the massage. I said yes, and that was 20 breaks, but I have to use the restroom after. 21 basically -- I mean, I don't recall everything, but it 21 Q. Okay. 22 was very, it was about getting there to do the massage. 22 A. You can ask a question and then I can go, 23 Q. Okay. Well, was there more to the 23 if... 24 conversation? 24 Q. Okay. How die ever get your phone 25 A. Not that I recall. 25 number? Page 225 Page 227 1 Q. Well, you just said that there was 1 A. I don't know for sure, but from what I think, 2 something about getting there. What did that mean? 2 it's from the person that told me about them. And then 3 A. Getting to his house. 3 I most likely went back to them and said I was 4 Q. So there -- in this conversation, first 4 interested. I don't know 100 percent. 5 conversation within, there must have been more 5 Q. Do you have a recollection, specific 6 discussed. 6 recollection ofhaving a second conversation with 7 A. Yeah. Like - 7 the person that first — 8 Q. Like, did you tell her anything? 8 A. No. 9 A. About what? 9 Q. -- told you about this opportunity? 10 Q. About anything that you can recall. 10 Do you want to take a bathroom break? 11 MR. MERMELSTEIN: Form. 11 A. Yes. 12 THE WITNESS: No. 12 .111VIDEOGRAPHER: Going off the record at 13 BY MR. LUTHER: 13 2 14 Q. Have you now told me every single thing 14 (A brief recess was held.) 15 you can remember about the •t =rntion you had with 15 THE VIDFL—I RAPIER: We're back on the 16 this person that you said was =? 16 record at 2:14m. 17 A. Yeah. 17 BY MR. LISITIER: 18 Q. Is there anything in the world that would 18 Q. Okay. After you had this phone call with 19 refresh your memory? 19 on that you said identified herself as 20 A. Not at this point, no. 20 illi swhat was the next thing you did with respect 21 Q. Okay. When, when -- did you have any 21 to following up on this opportunity? 22 dismission with this lady, after this phone 22 A. Like, how did I get there? 23 call that you say you had with her? 23 Q. No. Well, did you, u after you 24 A. Any time? 24 got this call, did you contactla.? 25 tl. Yeah, • time. 25 A. I don't recall if I did. I 'bably did 8 (Pages 224 to 227) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.9762934) Electronically signed by cynthia hopkins (601-051-976-2934) 1830241kebeed-4107-90a1-6373e814deed EFTA01076443 Page 228 Page 230 1 knowingthat I wanted her to go with me. 1. you? I 2 Q. Do ou recall anything specifically about 2 A. Well, I got Epstein's address fromM, and 3 contactinglta.? 3 I took the taxi to his house. 4 A. I don't remember specifically, but I'm, Pm 4 Q,S1, when did you get Epstein's address 5 sure I told her because she ended up coming with me. 5 fro t? 6 Q. Well, did you then have to contact her to 6 A. It was either from the phone call that I had 7 arrange a time that s d go? 7 with her the first time, or if I did call her back, I 8 I don't recall made a time and I told 8 don't recall. 9 It, or if I spoke . Isjan't recall. 9 Q. Well, then you must have made some notes 10 Q. Well, if you spoke toM. tout 10 of a phone call that you had with her, right, in 11 when she could go, did you then call= back and 11 order to write the address down? 12 tell her when you guys could come? 12 A. Yeah. 13 A. I would have had to, but I don't recall that. 13 Q. Well, do you recall making any notes? 14 Q. So you don't know which of those things 14 A. !don't recall malting notes, but I know I have 15 happened. You don't know the specifics about how 15 a horrible memory, and if I had I had to have his 16 the meeting was scheduled? 16 address in order to get the tail to go there. 17 A. Fvacrly. 17 QTj2do you know when you got the directions 18 44)What didfl ., dide. -- do you recall 18 from ? 19 what told you when you contacted her and said 19 A. No. 20 you'd received a call from somebody about going and 20 Q. Could hav iii in a second or third phone 21 doing this? 21 conversation with ? 22 A. From — actually from-9 22 A. It could have been. 23 Q. When you got the — when you told.. 23 Q. And you would have contacted her, if 24 about it, what, what did she say to you? 24 that's what occurred, to get the, the instructions 25 A. I don't remember. 25 from her? Page 229 Page 231 1 Q. Do you remember where she was when you had 1 A. Yes. 2 the cor ation with her about the call you got 2 Q. Did you get anything from her other than 3 from..? 3 the address? 4 A. No. 4 A. No. 5 Q. Do you remember how long it was between 5 Q. Did you know where it was? 6 the time that called you and when you 6 A. She just said Palm Beach and she gave me the 7 contacted .9 7 address. 8 A. No. 8 Q. All right. So, so, at some point in time 9 Q. Was it more than a day? 9 you contacted a cab company? 10 A. Probably not. 10 A. Yes. 11 Q. You just don't know. 11 Q. What cab company? 12 A. I don% know. I really don't. I don't 12 A. I have no idea. 13 remember. 13 Q. And, and where did this cab company pidc 14 Q. But, but do you have — do you lieve 14 you up? 15 that what you did was you contacted..? 15 A. At my father's house. 16 A. Yes. 16 Q. And, and what time of clay did they pick 17 Q. And you told her ofyour communication 17 you up? 18 with this person that you said, said they were 18 A. It was, it was during the day, but I don't 19 19 }mow what time it was. 20 A. Yes. 20 Q. Well, was thls during the school day — 21 Q. What's the next thing you recall happening 21 school week? 22 with respect to, to going to Mr. Epstein's? 22 A. No. It couldn't have been. 23 A. The next thing I recall happening is getting 23 Q. So you didn't go during the school week? 24 picked up in a taxi. 24 A. No. 25 Q. How did, how did the taxi know to come get 25 Q. So that would mean it had to be either a 9 (Pages 228 to 231) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthie hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) la30246abekl-4107-90.14373•81eds0d EFTA01076444 Page 232 Page 234 1 Saturday or Sunday-, is that right? 1 A. Yes. 2 A. Probably. Yes — 2 Q. All right. Did you or she have any money? 3 Q. Do you know? 3 A. On us? No. 4 A. because it had to be because I didn't have 4 Q. Did you have any credit cards? 5 school, so it had to be a weekend or a day I didn't have 5 A. No. 6 school. 6 Q. The cab driver say anything about how you 7 Q. Is there any reason why you say you didn't 7 were going to pay for the cab faze? 8 have school? 8 A. No. 9 A. Because I didn't skip school my sophomore 9 Q. Did you say anything to him? 10 year. 10 A. No. 11 Q. Okay. All right. So you — was it a 11 Q. Dicey. And, and you got in the cab, I 12 Saturday or a Sunday? Do you know which of those? 12 assume? 13 A. No. 13 A. Yes. 14 Q. Would you, would you have gone on Sunday? 14 Q. And who gave the cab driver instructions 15 A. I don't, I don't — I, I mean, it — as long 15 on where to go? 16 as I didn't have school, I didn't, it didn't matter to 16 A. I gave him the address. 17 me. 17 Q. Did you tell him what the address was? 18 Q. Who selected the day that you.and the 18 A. Yes. 19 time that to go, you or thi. person? 19 Q. Okay. And he took you there? 20 A. Nofl She had a schedule. 20 A. Yes. 21. Q. Dicey. So,oiliou remegalsr if you 21 Q. And any recollection of but you don't 22 called the cab or, (sic) --a. called the 22 know what time of day this was? 23 cab? 23 A. It was during the day. I just don't know what 24 A. I don't m that. 24 time it was. 25 Q. Where wa. ..z at the time you called the 25 Q. Well, do you know, was it in the rimming, Page 233 Page 235 1 cab? 1 was it in the afternoon? 2 A. She was with me at my Dad's house. 2 A. Maybe early afternoon, but that's — I mean 3 Q. So she was already at your Dad's house? 3 that's guessing. I don't know. 4 A. Yes. 4 Q. Okay. Do you remember where this house 5 Q. So, so at some point prior to the time the 5 was? 6 cab, the cab got there, she had already come over to 6 A. As in, like, the exact street, or... 7 your house. 7 Q. That's fine. Do you lynx-other the abeet? 8 A. Yes. 8 A. No. 9 Q. Was she there for some other reason, or 9 Q Do you remember where — what town it was 10 had she come specifically because you and she 10 in? 11 planned to go to Mr. Epstein's? 11 A. All I know, it was in Palm Beach on the water. 12 A. I don't recall exactly, but it was probably 12 Q. All right. When you are you talking 13 because we were going to go give the massage. 13 about the ocean? 14 Q. Do you, do you 'mow whether she spent the 14 A. Yeah., I'm pretty sure it was the ocean, yeah. 15 night the night before, for example? 15 Q. Okay. Do you remember how you got there? 16 A. I don't recall. 16 A. Alexi 17 Q. Do you remember what she was wearing? 17 Q. Do you remember the route that you took? 18 A. No. 18 A. No. I'm horrible with directions. 19 Q. Okay. And your dad was living where at 19 Q. All right Do you remember, did you, did 20 this time? 20 you go outside or were you able to view the ocean 21 A. In Binks Forest. 21 from the house? 22 Q. So, a cab, a cab from some unknown cab 22 A. The second time. 23 company comes and gets you — 23 Q. Okay. And the second time... 24 A. Yes. 24 A. I didn't go upstairs the second time. 25 a - is that ri 25 a. But, but were outside the house the 10 (Pages 232 to 235) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601.051-976.2934) Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 14302443a-be9d4107-9041413734816640d EFTA01076445 Page 236 Page 238 second time? 1 A. I don't remember. I just paid the cab with 2 A. I, I was in the kitchen, and that was a 2 it. 3 sliding glass door and you could see out back and he 3 Q. And did he — do you remember what the 4 had the pool with the ocean. 4 denomination of currency was? 5 Q. Okay. So you, you were able to — at that 5 A. No. 6 time, you were able to observe the ocean from the 6 Q. Did he answer — did you go up and ring a house? 7 doorbell? 8 A. Yes, but the first time I didn't. 8 A. I either knocked or rang the doorbell. Q. Okay. All right. When you got there in 9 Q. Do you remember which? 10 the cab, how did you pay the cab driver? 10 A. No. 11 A. Jeffrey Epstein did. 11 Q. Okay. And you say Mr. Epstein is the one 12 Q. Did he walk out of the house and pay the 12 that answered the door? 13 cab driver? 13 A. Yes. 14 A We went to the door, Jeffrey Epstein answered. 14 Q. What was he wearing? 15 He gave me the tnoney. it to the cab driver. The 15 A. Pm pretty sure he was the one that answered 16 cab driver left and then =came and took us 16 the door. 17 upstairs. 17 Q. When you say you're pretty sure — 18 Q. Is that the first time you had seen 18 A. I'm pretty he answered the door. I 19 Mr. Epstein? 19 don't know if it was answered the door and 20 A. Yes. 20 then got Jeffrey Epstein, or Jeffrey Epstein answered 21 Q. And what did — have you ever seen a 21 the door. I, I don't remember. 22 picture of Mr. Epstein? 22 Q. What was he wearing? 23 A. Before that? 23 A. Like sweats, like -- 24 Q. Yeah. 24 Q. What color? 25 A No. 25 A. Color? Page 237 Page 239 1 Q. Have you seen a picture of Mr. Epstein 1 Q. Ilh-huh. 2 since then? 2 A. I don't know. 3 A. Since - and like, now, recently? 3 Q. Did they have any writing on them? 4 Q. Anytime since then, have you ever seen a 4 A. I have no idea. 5 picture of Mr. Epstein? 5 Q. Well, are you talking about a sweatsuit, A. Yes. 6 top and bottom? 7 Q. Where have you seen a picture of him? 7 A. The top, I don't remember, but I know he had, 8 A. Actually, I was watching MTV, and a show came 8 like, sweatpants on. 9 on about the richest men in the world, and his face Q. Okay. And he personally handed you some 10 showed up one time. 10 money. 11 Q. And when was that? 11 A, Yes. 12 A. That was — I think that was one time in 12 Q. And then you say you went out and paid the 13 Virginia. 13 cab driver? 14 Q. Within the last couple of years? 14 A. Yes. 15 A. Yeah. 15 Q. What did you do next? 16 Q. Okay. So, Mr. Epstein gives you money 16 A. Then I came back to the door. 17 when you come to the door. you came to the door 17 Q. . Was Mr. Epstein standing there when you 18 out of the cab with you an ? 18 came back? 19 A I don't remember if stayed at the cab 19 • A. No. 20 while I got the money, or she came with me. I don't 20 21 recall that. I don't remember. 21 22 Q. But, but you recall Mr. Epstein handing 22 Q. Okay. And, and how did you know who this 23 you some money? 23 person was? 24 A. Yes. 24 A. She introduced herself. 25 (),; 2lowmuckah did he give you? 25 . Okay. What did she say to you? 11 (Pages 236 to 239) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051976-2934) la30246a-bc9d-4107-90a1-6373e816dead EFTA01076446 Page 240 Page 242 1 A. Hello, I'm i spoke to you over the 1 And then to the left was like a little 2 phone. 2 couch area with, like, a picture. i don't remember 3 Q. And what was she wearing? 3 if the picture was of a naked woman, but 1 remember 4 A. I have no idea. 4 there was -- I've seen a — I remember seeing a Q. What did she look like? 5 picture of a naked woman in his house. 1 don't know A. She was — I think she was light skin. 6 if it was that specific one. And then there was a, 7 mean, this is — dirty blonde hair. I don't really a shower like in front. recall exactly. Q. Okay. Was the — what color was the 9 Q. But you're sure she had blonde hair, 9 couch? 10 right? 10 A. I don't remember. 11 A. I'm not sure. I'm not going to say I'm sure 11 Q. Okay. What occurred next? 12 because the image I'm getting now, it's like a dirty 12 A. And then Jeffrey Epstein walked in and he 13 blonde hair, but I don't, I don't recall exactly. 13 removed his sweats and got into the shower. 14 Q. Yeah. 14 Q. Okay. At that point in time, when you say 15 A. So I'm not going to say definitely. 15 his sweats, did he have a top and bottom on? 16 Q. Anything else that you remember about her? 16 A. I'm pretty sure he had a top and bottom on. 17 Did she have any jewelry on? 17 Yeah, he had a top and bottom on. 18 A. I have no idea. 18 Q. And this is what time of year? 19 Q. Was — I think you already said you don't 19 A. What time of year? 20 remember what kind of — do you remember if she had 20 Q. Fall, summer? 21. pants on, a dress on, shorts, any of that? 21 A. I don't know. I was in Florida, so Florida is 22 A. I have no idea. 22 always hot. 23 Q. You don't remember anything about what she 23 Q. Okay. So he had — well, your 24 was wearing? 24 recollection is he had sweat tops on. 25 A. No. 25 A. Sweat — !don't know if it was asweat top, Page 241 Page 243 1 Q. How big a girl is she? 1 but it was like the sweatpants. 2 A. I — from what I remember, she was skinny. 2 Q. Okay. So you don't know if he had a sweat 3 Q. Skinny? 3 top on? 4 A. Tiny. 4 A. No. 5 S All right. So, anyway, you, did — was 5 Q. What, did he have a shirt on? 6 with you at that point in time? 6 A. Yes. 7 A. Yes, because we got walked upstairs. 7 Q. Okay. All right. So you say he took 8 Q. Okay. And then what happened next? 8 he took the — whatever he had on, you say he took 9 A. She took us upstairs. 9 off. 10 Q. Okay- 10 A. Fully. 11 A: Into — it was upstairs through the bedroom to 11 Q. Did he have shoes on? 12 the massage bathroom or — 12 A. I don't know. 13 Q. Okay. 13 Q. At that time back when this happened 14 A. — whatever it was. 14 describe his hair. 15 Q. All right. And did you ever — where was 15 A. His hair? 16 Mr. Epstein in this period of time? 16 Q. Uh-huh. 17 A. He wasn't there yet. • 17 A. All I remember, it was like salt and pepper. 18 Q. Okay. And what was in this massage 18 Q. Okay. 19 bathroom that you described? 19 A. That's al remember. 20 A. Anything that I remember? 20 Q. Do you remember how long it was at that 21 Q. Yeah. 21 time? 22 A. Well, when you first walk in the door, there 22 A. No. 23 was a minor to the right, and like a counter. And 23 Q. Okay. And what happened next? 24 there was, like, massage lotions, and then there was a 24 A. He got in the shower. He got fully naked and 25 massage bed in the middle. 25 got into the shower and he told us to undress. 12 (Pages 240 to 243) PROSE COURT REPORTING AGENCY, INC. • Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601.051.976.2934) 1a30246a-bc9d-4107.90a1.6373e816de0d EFTA01076447 Page 244 Page 246 1 Q. Well, what, what exact words did he use, 1. Q. Okay. 2 if you recall? 2 A. His face. 3 A. Take off your clothes. 3 Q. Was it a full glass or just a partial 4 Q. That's all he said? 4 glass? 5 A. From what I remember, yes. 5 A. I don't remember. 6 Q. Did he say, take off your clothes, or did 6 Q. Okay. And was there anybody else in the 7 he say something different than that? 7 house at the time? 8 A. No. It was take off your clothes or get 8 A. In the house? 9 undressed. It was along those lines. 9 Q. Yeah. 10 Q. Or did he say undress down to your panties 10 A. I don't — =answered the door. 11 and bra? 11 Q. Okay. 12 A. It could have been that, too. 12 A. So, I don't know if she still was in the 13 Q. Have you ever told anybody in the past 13 house. I don't recallaiggan, that all' saw was 14 that what he said was, undress down to your panties 14 Jeffrey Epstein and MI 15 and bra? 15 Q. When you first carne in the house — 16 A. Have I told anybody in the past that — 16 A. Yes. 17 Q. Yep, that that's what Mr. Epstein said to 17 Q. — did you either hear r anybody else 18 you. 18 other than Jeff Epstein and 19 A. Yes. 19 A. Not that I remember, no. 20 Q. Well, if you — and if you told them that 20 Q. And when you walked up this stairway and 21 in the past, it was true at the time you told them 21 you went into this mom, was the door open or 22 that? 22 closed? 23 A. Yes. 23 A. His bedroom door? 24 Q. That was your recollection of what had 24 Q. Whatever room you were in. 25 occurred? 25 A. Well, what do you mean, when we were walking Page 245 Page 247 1 A. Yes. 1 into it? 2 Q. So today, as you sit here today, is that 2 Q. Yeah, when you were up there in the room 3 your recollection of what he said, was undress to 3 and he said, take, whatever you said, undress. 4 your panties and bra? 4 A. Oh, the room we were in with the door. 5 A. To your panties. Q. Right 6 Q. Well, did he say panties and bra, or did 6 A. Oh, it was closed. 7 he just say panties? 7 Q. Okay. Did — was the, was the door locked 8 A. I'm pretty sure it was panties because our 8 or unlocked? 9 bras were off 9 A. I have no idea. 10 Q. Well, you don't — do you not recall? 10 Q. What kind of door was it? 11 A. I wouldn't just take off my bra for no reason. 11 A. I don't remember. 12 Q. Do you not recall? 12 Q. Okay. Did anything prevent you and II 13 A. I do not recall him specifically saying, take 13 from walking right out of the same door that you 14 off your bra, but I'm 90 percent positive that he did 14 came In? 15 because I wouldn't have done that. 15 A. Fear. 16 Q. Okay. Now, you're not — are you positive 16 Q. Okay. But that was it, right? 17 that you — well, strike that. 17 A. Yeah. 18 When he first said vitalism he said about 18 Q. Nobody blocked your ability to exit? 19 undressing, what did you and M. do? 19 A. No. 20 A. We looked at each other like what's going on, 20 Q. When he said whatever he said about 21 but we undressed. 21 undressing, you could have said to him, wait, I 22 Q. Okay. Now, he's in the shower, right, 22 don't want to do this, right? 23 taking a shower? 23 A. Yes, I could have. 24 A. Yeah, but it was glass. It was, like I 24 Q. Did you say anything at all to him in 25 know it was Rtass because I could see his head. 25 response to his request that you undress? 13 (Pages 244 to 247) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801-051-976-2934) Electronically signed by cynthia hopkins (601-061-9764934) Electronically signed by cynthia hopkins (601-051.976.2934) 1a30246a-bad-4107-9061-6373•816deOd EFTA01076448 Page 248 Page 250 A. No. 1 ever saying a word to each other, take all of 2 Q. Did you say anything to IM when he made 2 whatever clothes you have on, and the only thing you 3 that statement to you? 3 have on are whatever panties you have on? 4 A. I just looked at her vet): awkwardly. I didn't 4 A. Yes. 5 say anything 5 Q. And your recollection is that you got 6 Q. Did she say anything to you? 6 undressed when you were first requested to by 7 A. Not that I remember. I don't remember. 7 Mr. Epstein? 8 Q. Okay. So what did you and she do? 8 A. Yes. 9 A. We got undressed. 9 Q. And your recollection, as you sit here 10 Q. What do you mean by you got undressed? 10 today is you're definite and you're sure that you 11 A. We took off our clothes to our panties. 11 took your bra off? 12 Q. Okay. Well, what were you wearing at the 12 A. Yes. 13 time? 13 Q. Same with,? 14 A_ I don't remember. 14 A. Yes. 15 Q. Did you have — I mean, do you remember 15 Have you ever told anybody, including 16 anything about what you were wearing? 16 Dr. or Dr. M that you don't believe you 17 A. As in my clothes that I had on — 17 took your ra off? 18 Q. Yeah. 18 MR. MERMELST'EIN: Form, foundation. 19 A. — before? I, I mean, I always wear jeans and 19 THE WITNESS: I don't recall. 20 a shirt, so I'm pretty positive I had jeans and a shirt 20 BY MR. LUTTIER: 21 on. 21 Q. Did you, in fact, tell Dr. that you 22 Q. You're guessing that that's what you had 22 believe you did not take your brIli 23 on because you think that's what you usually wear? 23 MR. MERMELSTEIN: Form. 24 A. That's all I I don't wear shorts. I don't 24 THE WITNESS: No. 25 wear skirts, so it had to be jeans. 25 Page 249 Page 251 Q. Do you remember what kind of bra and 1 BY MR. LIJTTIER: 2 panties you had on? 2 Q. You deny having told him that? 3 A. The color or anything? 3 A. I don't recall telling him I never took my bra 4 Q. Anything about them. 4 off. 5 A. The only thing that I could imagine that I was 5 Q. Okay. Well — 6 wearing on my bottoms -- bra I don't know -- my bottoms 6 A. I said, at the point I didn't. 7 was either boy shorts or a thong. 7 Q. Is — 8 Q. Well, which was it? 8 A. Like at a certain point, I didn't take my bra A. I don't know. 9 off. io Q. What's boy shore? 10 Q. Well, wait. I didn't understand your 11 A. The ones that don't Billy cover, but they 11 answer. 12 cover half of your butt. 12 A. At a certain point I didn't take my bra off. 13 Q. But you don't recall which it was you were 13 Q. Did you tell him that there was a point 14 wearing? 14 that you didn't take your bra off? 15 A. No. 15 A. I don't remember. You're — I'm confused. 16 Q. And you don't kind, recall what kind of 16 Q. Well, I don't want to confuse you. 17 bra you had on? 17 A. Well, I am. 18 A. No. 18 Q. You testified here that you have a 19 Q. Did you ever go without a bra or back then 19 specific recollection that upon the first request by 20 did you ever go anywhere without a bra? 20 Mr. Epstein, you and M., without saying a word to 21 A. No. 21 each other, took all ofrour clothes off except your 22 Q. Did you have big breasts or small breasts? 22 panties, right? 23 A. 1have, I have small breasts. 23 A. Yes. 24 Q. Okay. So your recollection is that while 24 Q. Did you tell Dr. at any time that, in 25 Mr. Epstein is in the shower, you and without 25 fact, you don't believe ybTrook your bra off? 14 (Pages 248 to 251) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkIns (601-061.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1a30246abc9d4/07-90a1.6373s616ds0d EFTA01076449 Page 252 Page 254 MR. MERMELSTEIN: Foundation. 1 THE WITNESS: No. I 2 THE WITNESS: I don't recall. 2 BY MR. LUTITER: 3 BY MR. LUTITER: 3 Q. WelL you told him the trudi, right? 4 Q. If you told him that, it was true when you 4 A. Yes. 5 told him that, right? 5 Q. Well, what if what you told Dn. is 6 MR. MERMELSTEIN: Form. 6 totally different than what you said today? thy. 7 THE WITNESS: I don't, I don't know. 7 would you, how would you justify that or explain 8 BY MR. LUTTIER: 8 that? 9 Q. . Well, what do you mean, you don't know if 9 MR. MERMEISTEIN: Form, lack of 10 what you told him was true? 10 foundation. 11 MR. MERMELSTEIN: Form. 11 la WITNESS: You're saying what I told 12 THE WITNESS: No, I know what I told him, 12 Dr. is different than what I said today? 13 everything I told him was true. 13 BY MR. LUTTIER: 14 BY MR. LUITIER: 14 Q. No. lossaying, if it nuns out that what 15 Q. Okay. So whatever you said to him, you'll 15 you told Dr.= is different than what you said 16 live by that? 16 today, how, how do you justify the fact that you've 17 A. Yes. 17 said two different things? 18 MR. MERMELSTEIN: Form. 18 A. But I didn't. 19 BYNULLIMMER: 19 Q. You're sum? 20 Q. And if it's different than what you said 20 A. Yes. 21 go — you, you believe that what you 21 Q. Well, let's assume, for purposes of this today, y 22 told Dr.". was the truth? 22 question that yiyu did say something different: How 23 A. But it's not different. 23 would you justify how it is today you would be 24 MR. MERMELSTEIN: Form. 24 saying soothing different happened than what you 25 25 told Dr...? Page 253 Page 255 1 BY MR. LUTTIER: 1 MR. MERMELSTEIN: Form. 2 Q. Well, okay. Well, whatever it is. 2 THE WITNESS: But I wouldn't. 3 Whatever it is, it is, right? 3 BY MR. LUTTIER: 4 MR. MERMELSTEIN: Form. 4 Q. No. I'm asking you what's known as a 5 THE WITNESS: Yes. 5 hypothetical question which means I'm asking you, 6 BY MR. LUTTIER: 6 for purpoo of this question, to assume what you 7 Q. Okay. And wiaayou, would you stand by 7 told Dr.= about this incident is different than 8. whatever you told Dr.M? 8 what you've testified to today. So, do you 9 MR. MI3RMELSTEI&Eorm. 9 understand what I mean by — 10 THE WITNESS: Dr...? 10 A. I — 11 BY MR. LUITIER: 11 Q. — a hypothetical question? 12 . Q. Yeah 12 A. Yes, but — 13 A. That's the second one. Yes. 13 Q. Well, wait a minute. Let me — I want to 14 Q. Okay. And it if what you told Dr.. 14 make sure you understand this. 15 is different than what you said today, would yolu 15 A. Okay. 16 with — would you agree that what you told Dr. El 16 Q. So you have to assume for the purposes of 17 was the more accurate statement? 17 the question I'm about to ask that that's the, 18 . MR. MERMELSTEIN: Form. 18 that's the true facts. It's a hypothetical. 19 THE WITNESS: Hold mg truth. 19 A. Okay. 20 BY MR. LUTTIER: 20 Q. Okay. Now, so assuming that those are the 21 t's not my question. If what you told 21 do you explain that what you told 22 Dr. is different than what you said today, 22 tits different than what you said today? 23 would you agreetisthe more accurate statement is 23 MR. MERMELSTEIN: Fenn. 24 what you told Dr. 24 BY MR. LUTTIER: 25 MR. MERMELSTEIN: Form. 25 O. If you have an explanation. 15 (Pages 252 to 255) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. . Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601.061-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) la30241a4x9d4107-90a14373•1116440d EFTA01076450 Page 256 Page 258 1 A. But there — I don't, I don't, how can I make 1 THE VIDEOGRAPHER: Excuse me, sit Sony 2 an explanation of something that's not even true? 2 to interrupt. I'm going to have to change the 3 Q. So you can't explain any difference; is 3 tape, now. 4 that right? 4 MR. LUTT1ER: Okay. 5 A. Yes. 5 COURT: Going off the record at 2:37 6 Q Okay. What kind of panties wash. 6 S. This marks the end of Tape 2. 7 wearing? 7 (A briefrecess was held.) 8 A. I'm not sure. THE VIDIQQRAPHER: We're back on the 9 Q. Did she have any on? 9 record at 2:3811.b. This marks the beginning 10 A. Yes. 10 ofTape 3. 11 Q. You don't know if it was a thong or 11 BY MR. LUTHER: 12 something else? 12 Q. Okay. I want to take this slow. You said 13 A. I don't recall. 13 that he asked what you did and you told him you went 14 Q. Don't know what color? 14 to school; is that right? 15 A. No. 15 A. Yes. 16 Q. What kind of bra she had? 16 Q. Did you tell him what school that you went 17 A. No. 17 to? 18 Q. And while you guys were undressing, you 18 A. I don't recall. 19 didn't say a single word to each other; is that 19 Q. Well — and what were the next words that 20 right? 20 he spoke to you? 21 A. Not that I recall. 21 A. 1 don't remember the exact next words, but I 22 Q. And you were perfectly comfortable just 22 know that, you know, he told us he was a brain 23 taking all your clothes off down to your panties in 23 scientist, and that — along the lines that he would 24 this stranger's house? 24 help us with our careers, and we told him our ages. 25 A. Not at all. 25 Q. Well, wait a minute. I want to go slow. Page 257 Page 259 1 Q. But you didn't do anything about it? 1 We're talking about the next, the next words he 2 A. We were young. 2 spoke to you. You say you don't recall what they 3 Q. My answer -- let me finish my questions: 3 were. 4 You didn't do anything about it? 4 A. !recall words that he said, but I can't tell 5 A. No. 5 you word by word. 6 Q. All right. What happens next? 6 Q. Where was he when he spoke these words to 7 A. He gets out of the shower with a towel. And 7 you? 10 9 5. he lays on his massage table face down with his towel over his butt. was massaging his upper back, and I was massaging his leg, feet and legs. 8 9 10 A. He was on the massage bed, face down. Q. So he got out of the shower and walked to the massage bed without saying anything, and then he 11 Q. Well, before we get to massaging him, did, 11 began to talk to you once he laid down on the 12 did he speak more words to you after he got out of 12 massage bed; is that right? 13 the shower? 13 A. Yes. 14 A. While he was laying on the bed? 14 Q. Okay. And you said something about 15 Q. At any time after he got out of the 15 careers. Did you tell him something about your 16 shower, did he speak any words to you? 16 career? 17 A. Yes. 17 A. I personally d rtember that I did. 1 18 Q. What did he say? 18 don't ber what . said to him. I don't recall 19 A. It's not exact but he asked, you know, what we 19 whatM. was talking to him about 20 did, and we told him we went to school. And something 20 Q. gill, you're standing in the room right 21 about he would help us with our careers, that he was a 21 next toM., right? 22 brain scientist. And we told him we were in high school 22 A. Yes, I was. 23 and we did tell him our age. 23 Q. You can recall what Mr. Epstein said, 24 Q. How do you recall that you told him your 24 but — 25 25 A. Yes — 16 (Pages 256 to 259) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) 1a30246a-bc9d-4107-90a1.6373e816de0d EFTA01076451 Page 260 Page 262 1 Q. — but you can't recall what . said. 1 undress and he was naked. That's when it all seemed 2 A. Correct. 2 odd. 3 Q. And you can't recall what you said? 3 Q. Now, have you ever heard the phrase, "18 4 A. Correct 4 will get you 20?" Have you ever heard that phrase? 5 Q. Okay. And the fact of the matter is, you 5 A. What is it? 6 don't have a specific recollection of the 6 Q. "Eighteen will get you 20? conversation with Mr. Epstein, do you? 7 A. No. 8 A. Late, to the tee, the exact words? 8 Q. Did it occur to you at any time that now 9 Q. Yeah. 9 you say you were what, 16 years old at the time of 10 A. No. 10 this? 11 Q. You, you're just guessing what was said, 11 A. Yeah, 15,16. 12 aren't you? 12 Q. All right. Did it ever occur to you that 13 A. I'm not guessing. 13 this was kind of a strange setup, a strange sort of 14 MR MERMELSTEIN: Objection to form 14 circumstances? 15 BY MR. LUITIER: 15 A. It was very strange. 16 Q. You're not guessing? 16 Q. You knew all along, as soon as he said 17 A. I'm not guessing. 17 something about taking your clothes off, that it was 18 Q. What are you doing then if you're not 18 a bad idea, didn't you? 19 guessing? 19 A. Yes. 20 A. I'm summing up things that he said from what I 20 Q. You knew you ought to get out of there, 21 remember. 21 didn't you? 22 Q. What, what you think was said? 22 A. Yes. 23 MR. MERMELSTEEN: Objection, form. 23 Q. Okay. All right. Did.you tell him, wait 24 THE WITNESS: What I heard him say. 24 a minute, I don't want to take my clothes off? 25 25 A. No. Page 261 Page 263 1 BY MR. LUMER: 1 Q. Did you tell him, wait a minute, I don't 2 Q. Okay. An right So what was the next 2 want to take my bra off? 3 thing you heard him say? 3 A. No. 4 A. That's all I i bo-mber when we were having the 4 Q. Are you sure? 5 conversation through the massage. 5 A. Yes. 6 Q All he said was something about, you know, 6 Q. Did you tell him, I'm not comfortable 7 that he was a brain scientist and, and what school 7 taking my bra off? 8 you went to? 8 A. No. I don't — 9 A. No, not what school we went to. We told him Q. Are you sure? 10 we were in high school. 10 A. Pm pretty positive. It's, I mean, it's not 11 Q. Well, before I asked you something about 11 . 100 percent. I don't recall every little detail. 12 the school, and didn't I ask you what school you 12 Q. So you might have said it? 13 said you went to? 13 A. I might have. I don't recall exactly. 14 A. No. 14 Q. And if you said it, that means you didn't 15 Q. If I did — 15 take your bra off, doesn't it? 16 A. You did ask me before, but no, we didn't tell 16 A. No, but l did take my bra off. 17 him what school we went to. He didn't ask. 17 Q. Did you ever tell anybody that you told 18 Q And you said you told him your age. 18 him you didn't feel comfortable taking your bra off? 19 A. Yes. MR. MER/vIELS7EIN: Form. 20 Q. And do you have a specific recollection of 21 1 1"HE WITNESS: I don't recall. 21 telling him your age? 21 BY MR. LUTHER: 22 A. Yes. 22 Q. Okay. All right. So did Mr. Epstein — 23 Q. Did it seem odd to you this guy would be 23 what's the next thing you recall Mr. Epstein saying 24 asking what your age was? 24 to you? 25 A. I, it seemed odd to me when he told us to 25 A. Saying to me? I don't remember anything else 17 (Pages 260 to 263) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) 1a30246a-bc9d-4107-90a1.6373e816de0d Electronically signed by cynthia hopkins (601.051-976.2934) EFTA01076452 Page 264 Page 266 1 said, to be honest with you. 1 A. Yes. 2 Q. At all? 2 Q. Did you say — speak any words toe. 3 A. Well, until he flipped over and started 3 during this? 4 touching himself. 4 A. No. 5 Q. Okay. So, so you and.. began doing 5 Q. And at the time that you're beginning this 6 what? 6 massage, your testimony is you and she are standing 7 A. From when be flipped over? 7 there in your panties. 8 Q. No, when you — you say he came and laid 8 A. Yes. 9 down on the, on the, the massage table. You say he 9 Q. Got no neither one of you have your 10 put a towel on him? 10 bras on. 11 A. He put a towel on his butt. 11 A. Correct. 12 Q. Okay. And, and what color was that towel, 12 Q. Okay. And then what's the next thing you 13 you said? 13 recall happening? 14 A. 1 never said that the towel was colored. 14 A. The next thing I real' happening is he 15 Q. What color was it? 15 flipped over and started touching himself. 3.6 A. I don't know. 16 Q. What do you mean by touching himself? 17 Q. And what !dad of towel was it? Was it a 17 A. Jacking off with his penis. 18 big bath towel, a small towel? 18 Q. You said when he laid down face down on 19 A. I don't recall. 19 the table, that he had a towel over him. 20 Q. Okay. And, and your recollection is he 20 A. Yes, he did. 21 laid face down on the massage table? 21 Q. Okay. What was the towel over? 22 A. Yes. 22 A Ills butt. 23 Q. Okay. And did, did he give you any 23 Q. All right. Now, when he rolled over, what 24 instruction about the massage? 24 happened to the towel? 25 A. I don't remember — 25 A. It was gone. Page 265 Page 267 1 Q. So, so — 1 Q. Well, but what happened to it? Did, did 2 exactly. 2 somebody remove it? 3 Q And what did you and.. know to do? 3 A. I, Iclikt touch it. 4 A. Give him a massage. That was what, that's 4 Q. DidIM. touch it? 5 what we were there for. 5 A. No. 6 Q. But you had never given a massage before, 6 Q. Did Mr. Epstein touch it? 7 right? 7 A. I'm guessing so. 8 A. Well, to my friends, but it wasn't — I'm not 8 Q. Well, you're guessing? 9 a massage, you know, a massage therapist. A. I know for a fact he removed his towel. 10 Q. So what did you, what part of his body did 10 Q. Well, how do yo ow fora fact he did? 11 you start rubbing? 11 A. Because me and... didn't do it. 12 A. Iris feet and his legs. 12 Q. So you' oncluding, because you don't 13 Q. And why did you decide, decide to do that? 13 recall you and M. doing it, that Mr. Epstein did 14 A. Because it was the furthest away from him, so 14 it? 15 that's where I went. 15 A. Correct. 16 Q. Well, did he ask you to do that? 16 Q. And you don't recall seeing Mr. Epstein do 17 A. Not that I recall. 17 it though? 18 Q. Okay. And what did■. do? 18 A. No, because it was a shock to me that he 19 A. She massaged his back. 19 turned around and started playing with his penis. 20 Q. And why did she start there? 20 Q. Did he — do you have any recollection at 21 A. Maybe because I took his feet and legs first 23. all about what happened to that towel? 22 Q. Did he ask her to? 22 A. I have no idea. I wasn't paying attention to 23 A. Not that 1 recall. 23 the towel. 24 Q. Okay. So, for some period of time, you 24 Q. So, you don't know if somebody took it 25 began to massage him? /flirt.. 25 off, it fell off. You don't know what happened. 18 (Pages 264 to 267) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (6014)51476-2934) Electronically signed by cynthia hopkins (6014151-976-2934) 100246e-beed-4107-90a1-61730814deed Electronically signed by cynthia hopkins (6014)51.976.2934) EFTA01076453 Page 268 Page 270 1 A. No. 1 A. I — mentally I was just thinking to myself, 2 Q. Okay. At the time that he turns over, 2 like, what is going on. 3 And what, and what were your observations 3 4 5 where are you standing? A. I'm still at his feet. Q. You were at the feet And.. is up at, 4 5 k A. I wasn't even — I was --jggiestly, I,1 6 at -- by his shoulders? 6 wasn't even paying attention to... I was — I didn't 7 A. Yes. 7 know what to do. 8 Q. Are you both standing on the same side of 8 Q. Did you say anything to her? 9 the massage table? 9 A. At that certain time, no. I was -- 10 A. She was like, if you're looking at the 10 Q. Did she say anything to you? 11 massage table from where the shower is, and the front 11 A. No, it just — no. 12 door is right there, she's on this side, on the right 12 Q. Did either you or she say anything to 13 side, and I was by the feet. 13 Mr. Epstein? 14 Q. Okay. So — and, and up to thisspitt in 14 A. Not that' — at that point, at that moment? 15 time, you haven't spoken any words to ? 15 Q. Yeah. 16 A. About the situation? 16 A. Not that I recall. 17 Q. Yeah, about anything. 17 Q. Did either of you say, were uncomfortable 18 A. Not that I recall. 18 with this, or we, we want to slop? 19 Q. Okay. So he flips over. 19 A. Not at that point 20 A. He flips over. 20 Q. Did either of you say you want to leave? 21 Q. Okay. And, and what occurs, then? 21 A. Not at this point. 22 A. He starts playing with his penis. 22 Q. Did either of you walk towards the door? 23 Q. Okay. And, now, you're standing at his 23 A. Not at this point, no. 24 feet, right? 24 Q. Okay. Whaljappened next? 25 A. Yeah. 25 A. And he toldia. that he wants her to play Page 269 Page 271 1 Q. So you have a clear view of this? 1 with his nipples. 2 A. Yeah. 2 Q. Okay. So did she do that? 3 Q. Now, at that point in time, you've seen 3 A. Yes, she did. 4 his entire body; is that right? 4 Q. Okay. What happened next? 5 A Correct. 5 A. I walked behind her, like, I stood behind her. 6 Q. Okay. Tell me what, if any, tattoos you 6 Q. Okay. 7 observed on Mr. Epstein. 7 A. She was doing it and I stood behind her while 8 A. 'didn't see any tattoos. I wasn't — if he a he was playing with himself. has any, I didn't see any. 9 Q. Okay. So you're not touching him at all 10 Q. Okay. 10 at that point. 11 A. I don't know. 11 A. I wasn't, no. 12 Q. All right. Now, when you say Mr. Epstein 12 Q. Okay. So what happens next? 13 began to, to — what did you say he began to do? 13 A. So I, you know, was just standing there? And 14 A. Playing with himself. 14 he's playing with himself, and she — you know,,bf's. 15 Q. Play with himself. Did you observe that 15 you know,. 16 or were you concluding that he was doing that based 17 on something you saw? 17 Q. Did . say anything? 18 A. No, he was doing that. 18 A. I don't remember. I, I was in shock. 19 Q. Okay. And did you say anything to him at 19 Q. Did you say anything? 20 that time? 20 A. Not at that moment, no. 21 A. No. I don't remember. I honestly don't 21 Q. Okay. What happened ne 22 remember if I said anything. I was in shock. 22 A. So he was doing that with M., and then he 23 Q. Okay. And how did that evidence itself? 23 started moving towards 24 What did you do that, that, that would evidence to 24 Q. When you say, ' " what do you 25 anybody that You were in shock? 25 mean? 19 (Pages 268 to 271) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1a30246a-bc9d-4107.90a1.6373e816de0d EFTA01076454 Page 272 Page 274 1 A. With her, I wasn't certain because I was 1 object generally to the paraphrasing ca. 2 behind her. 2 You're not showing her a transcript 3 Q. So you couldn't see. 3 MR. LUTHER: No, no speaking objections. 4 A. I couldn't see. 4 Just start and state your form objection. 5 Q. An right 5. MR. MERMELSTEIN: But you keep doing the 6 A. But do you want me to go to the next? 6 some thing. 7 Q Sure. 7 MR. LIMIER: I know. 8 ' A. Okay. So then he started touching me. 8 MR MERMELSTEIN: Objection to form. 9 Q. 9 BY MR. LUTHER: 10 Q. That's what you told Dr... was he did 11 not put his hands in your panties, didn't you? 12 A. No. 13 A. Yes. 13 Q. You didn't say that to him? 14 Q. With what? 14 A. Not that I recall, no. 15 A. With his hand. 15 Q. Well, which is it? You didn't say it to 16 Q. pky. And this is while you're standing 16 him, or you don't recall saying it to him? 17 behind...? 17 A. No, I didn't say Liliggp. 18 A. Yes. 18 Q. Okay. So if Dr.IM says that's what 19 Q. Okay. 19 you said, how do you rectify that? 20 A. It was.., and then I was behind kith but I 20 MR. MERMELSTEIN: Form. 21 don't know how to explain it. Like, this is . This 21 THE WITNESS: How would I rectify 22 is me, and he was reaching around. 22 something I didn't say? 23 Q. Okay. 23 BY MR. LUTTLER: 24 A. I was, like, right behind her. 24 Q. Okay. You told DM that, that 25 Q. What happened next? 25 Mr. Epstein did not put his hands in your panties, Page 273 Page 21 5 1 didn't you? 2 A. No. 3 MR. MERMELSTEIN: Form. 4 BY MR. LUTTIER: Q. Okay. All rigalislin years later A. Yeah, he tried to, yes. 9 Q. Uh, uh, uh. You say he tried to, or he 10 did? 11 12 A. I dent recall saying that 13 Q If you told them that, when you told them, 14 it was true, right? 15 MR. MERMELSTEIN: Form. 16 THE WITNESS: When I — yeah, I told the 17 truth, Yes. 18 BY MR. LIJITIER: 19 Q. Let, let's be honest Dr. asked 20 you all about this incident, didn't he? 21 A. Yes. 22 Q. And you told Dr. that, that 23 Mr. Epstein did not put his hands inside your 24 panties, didn't you? 25 MR. MERMELSTEIN: Form. I, I'm 20 (Pages 272 to 275 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkIns (601.051.978-2834) 1a30246a-bc9d-4107-90a1-63734816de0d Electronically signed by cynthia hopkins (601-051.976-2934) EFTA01076455 Page 276 1 Q. Did you pull away? 1 A. I don't ;mow. I don't recall. 2 A. 1 pushed him away. 2 Q. And when did you first see it? 3 Q. Ok• nd and wh ned next? 3 A. Well, !first noticed it when he started he 4 was going to start using it, when he pulled it out. 5 Q. Did he put— did he pick it up from some 6 place? 7 A. Yeah, picked it up on the right, or, like, A. Not that I recall, no. 8 the, you know, mirror and the desk was. 9 Q. Well, you would recall that, wouldn't you? 9 Q. Off a countertop? 10 A. 10 A. I don't know if ark II in ad 11 s was on the outside of her 18 panties? 19 A. I don't know because I was behind her so — 20 Q. You, you couldn't really see what was 21 going on? 22 A. No, with N. 23 Q. Did./ say anything? 24 A. Not that — I don't remember. A. No. 25 Q. Did you hear her say, don't do that? Page 277 Page 279 ( 1 A. I don't recall what.. said. I was in 2 shock I — 3 Q. Okay. What, what happened next? Q. When you say, "pulled you around," what do 9 you mean? 10 A. Like, he grabbed my arm and pulled me around. 11 Q. Well, did he ask you to come over, move 12 Q. When you say, "using it," what do you 12 from where you were? 13 A. N he can ou lease over. 13 mean? 14 A. It was, it was like a back massager vibrator. 14 15 Q. What color was it? 15 Q. Did he, did he pull you with such force 16 A. I think it was white. 16 that he left any marks on your body, for example? 17 Q. How big was it? • 17 A. No. 18 A. It was like this, big. It was like, it looked 18 Q. Any bruising or anything like that? 19 like a back massager, like it didn't look like -- 19 A. No. • 20 Q. Describe it. 20 Q. Okay. Did you say anything to him when 21 A. It had like a white head on it. 21 he, to use your words, pulled you over? 22 Q. Okay. 22 A. I don't recall. I don't remember. 23 A. And then like a body that you would hold it 23 sOka . What ha ,i ahWhT ne, next? mmi 24 by. It vibrated. 24 ■ 25 Q. Was it one Sed11 into the wall? 25 21 (Pages 276 to 279) PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051.976.2934) 1al0246a-bc9d-4107-90a1-6373e816de0d EFTA01076456 Page 280 Page 2F^ 1 Q. Did you say anything to him when he 1 2 started doing that? 2 3 A. I told him I didn't feel comfortable, and he 3 4 lcept telling me to just let it go. 4 5 Q. Did, did you pull away? 5 A. Yes, that's... 6 A. There was a couple of times that I pushed 6 Q. Okay. So for a couple of seconds he's 7 away. I was just, I don't feel comfortable, not that I 7 doing that, and during that couple of seconds, 8 went all the, you know, all the way back in a corner, 8 you're saying to him, Pm uncomfortable. 9 but I did push him, and l said, I don't feel 9 A. Yes. 10 comfortable. 10 Q. Does he stop after a couple ofseconds? 11 Q. Okay. 11 A. No, he. 12 A. And he kept persisting and doing it and kept 12 13 saying the same thing, lust let it go. 13 14 A. I have no idea. It seemed like forever. 15 Q. It was a matter of seconds, right? 16 A. No. A matter of seconds is when I let — 17 Q. While he's sitting on the table? 17 like, sort of like just let it go and just ignored the 18 A. Yeah. Ile was on the table, like leaned over. 18 fact that, I was, you know, in this situation. 19 Q. Okay. And what did you say? 19 Q. Okay. If you let it go fora matter of 20 A. 1kept saying, I don't feel comfortable. 20 seconds; what did you do after the seconds passed? 21 Q. Did you, did you eventually pull away and 2/ A. What do you mean? 22 ask him to stop? 22 Q. Well, you said you let it go for a matter 23 A. I, I pulled away a couple of times, and then 23 of seconds. You must have done something, then, 24 at one point a thought, a thought ran through my mind, 24 when that, that time period of seconds expired. 25 ifIjust get this over with I could leave. 25 What did you do? Page 281 Page 283 1 Q. Did you ever ask him to stop? 1 A. While I was letting him do it? 2 A. I just kept telling him I didn't feel 2 Q. Yeah, did you pull away? 3 comfortable. 1don't know if I told him to stop or not. 3 A. I was just sit — I was just sitting there 4 Q. O What hay.ened next? 4 letting him do it. I wasn't trying to say stop at some 5 A 5 Pant 6 Q. So, you let him do it for, what you 7 described as, a matter of seconds? 8 A. Yes. 9 Q. All right. And what did you do? 10 A. Then,!kept, I just — I was like, !can't do 11 this. I don't feel comfortable. 12 Q. And did he stop? 13 A. No, he kept going u 14 9 ,r• II I I M, did you just stand there? 22 A. For a little bit, I did. 23 Q. For how long? 24 A. A couple of seconds. 25 Q. Okay. So for two seconds, he took a, 25 A. I don't remember how ►on a time. 22 (Pages 280 to 283) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) 1a30246a-bc9d-4107-90a1-6373e816deOd EFTA01076457 Page 284 Page 286 1 Q. A matter of a few mo o 1 Q. Did you ever — 2 A. I don't know. 1 mean. 2 A. —just let it go. 3 Q. Did you ever just say no and walk t4 4 A matter of — 4 steps away? 5 Q. How long a while? 5 A. I said I don't feel comfortable, and I took a 6 A. Huh? 6 step back, yes. 7 Q. How long a while, a minute or two? 7 Q. Well, full steps so he couldn't reach you. A. No. 8 A. No, I was still an ann's length. 9 Q. First he did something to.., according 9 Q. Did you ever step back beyond his reach 10 to you, right? 10 and say I don't want to do this? 11 12 13 A. Yes, but I'm saying since the vibrator came out of the drawer. Q. Was it less than a minute? 11 12 14 swirl A. No. A. No. 14 A. Or whatever it came out of. It wasage than 15 a couple of minutes, because he used it onM. first 15 Q. Okay. So at some point he stops? 16 and then he used it on me. 16 A. Yes. 17 Q. How about you? It was less than a minute 17 Q. You don't know how long it is? 18 on you, wasn't it? 18 A. No. 19 A. No. I mean, I don't know the exact time, but 19 Q. Okay. What happens next? 20 it wasn't less than a minute because — 20 A. And then be finishes him' tlf off. 21 Q. How do you know it wasn't less than a 21 Q. When you, when you say "finishes himsel f 22 minute if you don't know the exact time? 22 off," what do you mean? 23 A. Well, to me it seemed like a while. 23 A. That he ejaculated. 24 Q. It seemed like a while, but 24 Q. Did you actually see him ejaculate? 25 A. To me it did. 25 A. Yes, I did. Page 285 Page 287 1 Q. — in fact, it could have been less than a 1 Q. Okay. And.. is standing next to you? 2 minute, couldn't it? 2 A. Yes. 3 MR. MERMELSTEIN: Fonn. 3 Q. And did you say anything to her? 4 THE WITNESS: No, definitely not 4 A. I think I told her in her ear, like, we need 5 BY MR. LUTTIER: 5 to get out of here. 6 Q. Well, how long was it? 6 Q You said that to.. at this point? 7 A. I don't 7 A. Yeah. 8 rightIMMINIME 8 Q. Have you ever, prior to today, told that 9 to anybody that you made that statement? 10 A. Yes. 11 Q. All right. So there came a time when he 11 Q. Okay. Who have you told that to? 12 stopped, right? 12 A. Anybody I told the story to. 13 A. Yeah. 13 if you said it if you told the story 14 Q. Did you — did there 14 to 15 some ooint in time, 15 A. Yes. 16 Q. — and if you told to its you've told 17 both of ti that what you said at that point in 18 time to . was we've got to get out of here? 19 A. Yes. 20 Q. Okay. What did she say to you? 21 A. She just — I mean, he was still right there, He didn't pull you back. 22 so she just sort of like nodded her head, like, yeah, I !23 You could have just stepped back, couldn't you? 23 know. 24 A. He would, like, grab the side of me and pull 24 Q. Well, you said this audibly so she could 25 me close and -- 25 hear it. 23 (Pages 284 to 287) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1a30246a-bc9d-4107-90a1.6373e816de0d EFTA01076458 Page 288 Page 290 1 A. It wasn't, it wasn't like, hey, we need to get 1 Q. Okay. And what didfl. say? 2 out of here. It was more like we need to get out of 2 A. I don't remember. 3 here. 3 Q. Okay. But you were standing right there, 4 Q. Well, what did Epstein say when you said 4 right? 5 that? 5 A. Yes, but I don't remember. 6 A. He didn't hear me. He was — 6 Q. All right. So what happened next? 7 Q. How do you know he didn't hear you? 7 A. So then we left. 8 A. — cleaning himself. Because he didn't. 8 Q. What was the total amount of time you were 9 Q. Okay. What happened next? 9 up there in this — doing this massage on 10 A. He cleaned himself up, and then he gave us 10 Mr. Epstein? And by that I mean the total time you 11 money and said if you bring back a girl for a massage 11 were up in this room that you've described. 12 for $200, I'll give you 400. 12 A. The -- from the massage and everything? 13 Q. Well, when you, when you say he gave you 13 Q. Yeah. From the time you walked in and, 14 money, what did he give you? 14 and he first asked you to, you say, take your 15 A. $200. 15 clothes off, to the point in time that you walked 16 Q. $100 bills? 16 out that door that you came in. 17 A. Bills, yes. 17 A. I don't have the exact time frame, because I 18 Q. TWo $100 bills? 18 didn't sit and time it. But 1 know from -- the massage 19 A. I don't recall if it was — what kind it was. 19 was 45 minutes to an hour. And I don't know how I know 20 I don't know. I just wanted to get out of there. 20 that. I don't know if the person that told me that it 21 Q. So you don't know what the denominations 21 was only a 45-minute or an hour massage, but I know the 22 of the bills were? 22 massage was at least 45 minutes. 23 A. No, I don't. 23 Q. Okay. And, and how long did it take 24 Q. And did he give you money and... money? 24 Mr. Epstein to masturbate and ejaculate out of this 25 A. Yes. 25 45 minutes? Page 289 Page 291 3. Q. And what did you-all say when he gave you 1 A. Forty-five minutes wasn't including that part. 2 this money? 2 Q. Was not? 3 A. Nothing. 3 A. Was not. Q. And you're standing there naked at this 4 Q. Oh, that was in addition to the massage? 5 time? 5 A. Yes. 6 A. I don't remember at that point if we were 6 Q. So what did you do, finish the massage 7 dressed a not dressed. I don't i 7 first? 8 Q. Okay. And what happened next? 8 A. We gave him the massage, yes. 9 A. So, then I told you what he said about you 9 Q. Okay. 10 bring a girl, rit give you 400. 10 A. And that's when he flipped over and it wasn't 11 Q. Okay. What did you say? 11 a massage anymore. 12 A. No. 12 Q. Okay. So the total amount of time you're 13 Q. Okay. So just told him, no. You didn't 13 in the room is something between 45 and 60 minutes. 14 have any problem telling saying. no to him, did you? 14 A. For the massage. The massage at least was 45 15 A. With that statement When he's sitting there 15 minutes. 16 sexually touching you, ifs a little bit uncomfortable 16 Q. Listen to my question. What is your best 17 when you're that age. 17 estimate of the total amount of time that you were 18 Q. You didn't have any problems saying to 18 up there in this room with Mr. Epstein? 19 him — when he said if you bring a girl III give 19- A. Total? I don't know. 20 you $400, you didn't have any problem saying to him, 20 Q. Less than an hour? 21 no. 21 A. No. 22 A. Yes, because he gave me an option. 22 Q. More than an hour? 23 Q. Okay. And so you said, no, I'm not going 23 A. Yeah. 24 to do that? 24 Q. Well, how much more than an hour? 25 A. Yes. 25 A. I don't know. 24 (Pages 288 to 291 ; PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by Cynthia health's (601-051.976-2934) Electronically signed by cynthia hopkIns (601.051-976.2934) 1830246a-bc9d-4107-90a1-63738816deOd EFTA01076459 Page 292 Page 294 • Q. Fact of the matter is you don't know how A. Where the front door was. I don't recall if 2 long you were there, do you? 2 he walked us all the way down the stairs or halfway 3 A. No. 3 down, and there was the door. 4 Q. Okay. Less than an hour and five minutes? 4 Q. Okay. Did you ever see this.. person 5 A. I have no idea. 5 again? 6 Q. Okay. That's the truth of the matter, is 6 A. No. 7 you don't know how long you were there, right? 7 Q. Did you see anybody else in the house? 8 A. Right 8 A. I don't — no, I just left 9 Q. Okay. And did — who left the room first? 9 Q. What did you do when you got to the door? 10 A. Out of all three of us? 10 A. I called a taxi. 11 Q. Yeah. it Q. So what — how did you call the taxi? 12 A. I don't recall. It was probably — I man, 12 A. With my phone. 13 I'm not going to say because I don't know. 13 Q. Through the cellphone? 14 Q. Well, when did you and — did you and.. 14 A. Yes. 15 get dressed again? 15 Q. Cellphone you brought? 16 A. Yeah. 16 A. Yeah. 17 Q. When did you do that? 17 Q. Did you know the phone number? 18 A. I don't remember. 18 A. Yes. I had the guy's card from the taxi. 19 Q. Did you have any discussion while you were 19 Q. Okay. So you dial on your cellphone and 20 getting dressed? 20 call the cab? 21 A. No, became I'm sure he was in the room. He 21 A. Yes. 22 didn't leave the room again. 22 Q. All right. So how long did it take for 23 Q. So, now you do know who, who was in the 23 the cab to get there? 24 room when you were getting dressed. 24 A. He knew that we were going to leave. He knew 25 A. We all three were in the room. I said I don't 25 that we were going to give a massage and we were going Page 293 Page 295 1 remember when we got dressed. 1 to leave — well, he didn't know we were going to give a 2 Q. So he's in the room while you get dressed, 2 massage, but we told lim — 3 right? 3 Q. Right 4 A. Yes. 4 A. — we wouldn't belong, so he said he mould 5 Q. You and. don't have any conversation? 5 wait down the street. 6 A. No. 6 Q. Okay. So bow long did it take for the cab 7 Q. Are you getting dressed before or after he 7 to get there? 8 gives you the money? 8 A. Couple manna maybe. 9 A. I don't remember. 9 Q. Okay. And you waited in the house with 10 Q. What happens after you get dressed? 10. Mr. Epstein? 11 A. I don't know if we took the money, if it was 11 A. No, we waited 12 before or after, but we left. 12 Q. Okay. 13 Q. Is was Mr. Epstein dressed at the time 13 A. Outside of the gates. 14 you left? 14 Q. And, and when ymwemommde, did you 15 A. I don't remember. 15 have a conversation with 16 Q. Was be still in the room when you left? 16 A. I don't recall the conversation right outside, 17 A. No, I think he walked us out. 17 when we first gotoutside. 18 Q. Was he clothed? 18 . Q. When dorm recall do you recall 19 A. I'm pretty sure. 19 . getting in the cab with her? 20 Q. What clothes did he put on? 20 A. Getting in, yes. 21 A. I have no idea. 21 Q. Do you recall saying anything to her when 22 Q. Okay. All right. So when you say he 22 you got in the ode 23 walked you out, where did he take you? 23 A. I don't recall the exact conversation. I know 24 A. He took us down the stairs. 24 we were both disgusted. 25 Q. All ri t To what? 25 Q. Well, how do you kno2;p iyou were disgusted? 25 (Pages 292 to 295) PROSE COURT REPORTING AGENCY',. Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) 1a30246a-bc9d-4107-90a1-6373e816de0d EFTA01076460 Page 296 Page 298 1 A. Because look what just happened. How can 1 wasn't -- 2 anybody not see that? 2 Q. Did she appear to be upset at all? 3 Q. What did you say to her? 3 A. I don't remember. 4 A. I just said, I can't believe what happened. 4 Q. Did she cry? 5 Q. What did she say to you? 5 A. No. A. I know. And that's all - 6 Q. Did she say anything to you other than, "I 7 Q. So it was a horrible experience? 7 know"? • 8 A. Yes. 8 A. I don't recall. experience? 9 4 Did you say anything more to her to Q. Traumatic 10 indicate any — what your emotions were at the time? 10 A. Yes. 11 Q. Sixty minutes of pure trauma? 11 A. I don't remember. 12 A. Yes. 12 Q. Did you-all enjoy the money? 13 Q. One that you would never want to replay 13 A. The money? 14 again? 14 Q. Yeah. 15 A. Yes. 15 A. Who doesn't enjoy money. 16 Q. And so as a result of that, did you ever 16 So you don't recall any comment 17 go back to Mr. Epstein's? 17 thatfl. made when she got in the cab, right? 18 A. Yes. 18 A. Yes. 19 Q. Even though it was a traumatic experience? 19 Q. And you don't recall any comments you made 20 A. Yes, because I didn't know that they were 20 in the cab ride from Mr. Epstein's to — back to 21 going there. 21 wherever you went. 22 Q. Okay. Did you ever see Mr. Epstein again? 22 A. Yeah, I don't even remember where we went. 23 A. Yes. 23 Q. I was — that's my next question. Where 24 Q. Him, personally. 24 did you go in the cab? 25 A. Yes. 25 A. It was either back to my house orig.'s Page 297 Page 299 1 Q. When did you see him again? 1 house. I think it was my house, butIm not sure. 2 A. Second time. 2 Q. How long ofa drive was that? 3 Q. And, and how did you get there the second 3 A. A while. We went from his house in Palm Beach 4 time? 4 to Wellington. 5 A. The second tit. and were going. 5 Q. Can you tell me anything about the 6 Q. Again, this is — .'s the person that 6 conversation in the car between you and. on the 7 had been there the first time -- 7 ride back? 8 A. Yes. 8 A. No, I don't remember.. 9 Q — that was thoroughly disgusted with what 9 Q. can you describe her in any manner'? 1O happened. 10 A. No. 11' A. Yes, Imam, I'm speaking for myself here. 11 Q. Was there music playing in the cab? 12 Q. VAIL' a minute. Did I understand you to 12 A. I don't know. 13 say thatM. said to you when you got in the cab 13 Q. Did you say anything to the cab driver? 14 that she couldn't believe what it was and that she 14 A. Not that I know of. 15 was disgusted? 15 Q. Did be say anything to you? 16 A. I said that. 16 A. Not that II ranember, no: 17 MR, MERMELSTEIN: Objection, form. 17 Q. Did you-all make any calls on your 18 MR. LUTTIER: Did — well -- 18 eellphones? 19 THE WITNESS: I saidI, I can't believe 19 A. I don't remember. 20 what just happened. And she said, I know. 20 Q. Did the cab driver ask you if there was 21 That's all I said. 21 anything wrong with you? 22 BY MR. LUITIER: 22 A. No: 23. Q. Did she, did she appear to be upset at 23. Q. Was . crying? 24 all? 24 A. No. 25 A. I was, worried about myself.. 25 Q. Were you crying? 26 (Pages 296 to 2 99) PROSE COURT REPORTING AGENCY, INC. . Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-978.2934) 1a30246a-bc9d-4107.90a1-6373e816de0d Electronically signed by cynthia hopkins (601-051.976-2934) EFTA01076461 Page 300 Page 302 A. No. 1 A. I mean, I don't know. 2 Q. All right. Do you know whether or not 2 Q. So there's a second incident that comes 3 you-all made jokes on the way back to the - 3 up. 4 A. We didn't make jokes because we were in shock. 4 A. Yes. ' 5 Q. Well -- 5 Q. And it's you ma/. and was itM.? 6 A. lyres in shock. 6 A. MI. 7 Q. if you don't know what was said I mean, 7 MR. LUTHER: Okay. l'm going to take a 8 ifs.ftne to tell me, if you don't know what was 8 little break and go to the bathroom. 9 said, you don't know what was said. 9 WE WITNESS: Okay. Me, too. 10 A. Yeah, I don't know what was said. 10 HayIDEOGRAPHER: Going off the record at 11 Q. So, it would be a fair statement you just 11 3:09M. 12 don't have any recollection at an of what happened 12 (A brief recess was held.) 13 with the ride back? 13 7HE VIDEDQ. RAMER: We're back on the 14 A. Basically, yes. 14 record at 3:18ln. 15 Q. Okay. And you don't know if you went to 15 BY MR. LUTHER: 16 your house or her house? 16 Q. Okay. There, there came a, another 17 A. Correct. 17 occasion when you went to Mr. Epstein's house; is 18 Q. Who did you next see after you got dropped 18 that right? 19 off either at your house or her house? 19 A. Yes. 20 A. I don't remember. 20 Q. Do you remember how long that was after 21 Q. And this was -- 21 the first time? 22 A. I don't remember. 22 A. No. 23 Q. This was a Saturday or Sunday? 23 Q. Was it a matter of months, years? 24 A. I don't know exactly what day it was. It was 24 MR. MERMELSTEIN: I think that this has 25 a day l didn't have school. 25 been asked and answered. Page 301 Page 303 1. Q. All right So did you tell your mom or 1 MR. LUTHER: Well, if I do, I don't 2 your dad? 2 recall it, but you can tell me what the answer 3 A. No. 3 was. I will accept your representation. 4 Q. Did you call the police? 4 MR. MERMELSTEIN: You can, you can answer 5 A. No. 5 it again. 6 Q. Did you tell anybody? 6 773E WITNESS: I don't, I don't know. I 7 A. No. 7 don't remember what — 8 Q. All right. But at some point in time, you 8 BY MR. LUTHER: 9 hooked up within. and your other friend and you 9 Q. Do you, do you have any — what's your 10 went back to Epstein's; is that right? 10 best recollection of the amount of time between 11 A. Yes. 11 these two visits? 12 Q. Okay. And, now, I just want to make sure 12 A. It was — I mean, it wasn't that far after. I 13 I understand this. Did you get the impression from 13 know it wasn't years after. It could have been weeks or 14 anything that.. said or did that she appeared to 14 months, but it wasn't... 15 be at all upset about this incident? 15 Q. Okay. Your best recollection is, it was 16 A. The time that we — 16 either weeks or months — 17 Q. Yeah. 17 A. Yes, it wasn't — 18 A. I, I don't remember. You mean, like, from 18 Q. but it was more than a few days? 19 that to the second time that we went? 19 A. Yes. Q. Yeah. 20 Q. Okay. And how were you contacted about 21 21 A. I mean, I don't !mow. 21 the second occasion? 22 Q. Did you, did you, you and she ever discuss 22 A. I v . I was actually in the vehicle with 23 it? 23 and , and they were going over there. 24 A. I don't =all that, no. 24 Q. And whose vehicle was it? 25 . a 25 27 (Pages 300 to 303) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) a andisa-bcsdA 107-goal nk816d0d EFTA01076462 Page 304 Page 306 1 Q. And, and how was it that you were in 1 A. I don't know exactly where we were at, but we 2 M.'s vehicle? 2 were all together. 3 A. I don't know why I, I was with her. I don't 3 Q. And you don't know why all of you had 4 know if I was just hanging out with them, and I guess 4 gotten in the car initially? 5 they wanted to go over there. 5 A. Exactly. Q. And when did you first learn, when you 6 Q. So you don't know if you were going to the 7 were in this vehicle, that where you were going was 7 movies or shop or whatever? 8 Epstein's? 8 A. Yeah, ! don't remember. 9 A. They mentioned it in the car that that's where 9 Q. But your best recollection is, about ten 10 they were going. 10 minutes after you got in this vehicle for some 11 Q. And where were you geographically when 11 unknown purpose, you heard for the first time that 12 they mentioned to you in this car that they were 12 this car was headed to Jeffrey Epstein's? 13 going there? 13 A. Yes. 14 A. Like what area? 14 Q. Who told you that? 15 Q. Yeah. 15 A. I don't remember who told me. One of them 16 A. I have no idea. 16 mentioned it. 17 Q. Where, where were you in this — do you 17 Q. And what did they say? 18 remember what day of the week it was? 18 A. That they're going to Jeffrey Epstein's house. 19 A. No. Q. And what was your reaction? 20 Q. Do you remember what time of day it was? I A. I don't want to go. 21 A. No. 21 Q. And what did they say? 22 Q. Do you remember in what area of the city 22 A. Well, you're going to come with us. 23 you were, if you were in the city? 23 Q. And did you, at any time say, stop, I want 24 A. No, I don't know. I don't recall. 24 to get out? 25 Q. All you know is you were in a car with 25 A. No. Page 305 Page 307 Q. And did you say anything else to them 2 a? A. Correct. 1 2 besides that you didn't want to go? 3 Q. And how long had you been in the car 3 A. I, I argued with them about not going and that 4 before you learned that they were going to 4 it was disgusting = do that. 5 Epstein's? 5 Q. Had — dide indicate to you at that 6 A. It was a little while. I'm not sure exactly 6 time or anytime before that conversation whether she 7 how long. 7 had been back to Epstein's since your first visit? 8 Q. Roughly, your best estimate, how long? 8 A. Between the time we're in the car and the 9 A. Maybe ten minutes, 15 minutes. 9 first visit we went? 10 Q. And why were you in the car? 10 Q. Yeah. 11 A. I was — 11 A. Not that I know. 12 Q. Were you — was there a plan that you were 12 Q. All right. To the best of your knowledge, 13 going to be going someplace? 13 was that her second visit? 14 A. I was just hanging out with them, and 14 A. Yeah, to the best of my knowledge. 15 don't — I mean, I don't know if we were supposed to be 15 Q. Did you know laga you were in the 16 going somewhere or what was going on. 16 car that, whether or not... had ever been 17 Q. Had they picked you up from some place. 17 there? 18 A. No, I think I was with them, like hanging out 18 A. I, I don't -111tink — I don't know for 19 with them. 19 sure, but I thinkM. walaing. her. 20 Q. Okay. And when you got 'M.'s car, 20 Q. So you think that'll. had not been there 21 where were you? 21 before? 22 A. In the backseat 22 A. That's what I think. 23 Q. I mean, were you at, for example, her 23 . Okay. Did you have a conversation with 24 house when you got in the car, or were you someplace 24 25 else when ou-all t in the car? 25 A. Yeah I told her -- 28 (Pages 304 to 307) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthia hopkins (601.061-976-2934) 1a30246a•bc9d-4107-90a1-6373e816de0d Electronically signed by cynthia hopkins (601.051-976-2934) EFTA01076463 ge 3:J Page 310 1 Q. — where you warned her? 1 Q. What did, what did the fight consist of? 2 A. I told her not to go in the car. 2 A. That I thought she was stupid for going. 3 Q. What did you tell her? 3 Q. And your best friend was in the car, e, 4 A. I told her It's not a massage, that it's other 4 right? 5 things. 5 A. Yes. 6 Q. You said you told her not to get in the 6 Q. And did you argue With. about it? 7 car? You mean, she was already in the car - 7 A. I don't remember if I did or not. 8 A. Yeah, we were in the car. 8 Q. Did you tell anything like, you know, 9 Q. -- and while in the car you told her? you remember what appened last time; we shouldn't 10 A. Yes. 10 go there? 11 Q. What is -- specifically, did you tell her? 11 A. I don't recall exactly saying that. I could 12 A. That she shouldn't go because ifs not just a 12 have said that, but I don't know. 13 massage; it's other sexual acts. 13 Q. Do you remember anything about what you 14 Q. Well, did you specifically tell her about. 14 told 15 your experience? 15 A.., it was more about 16 A. I don't remember exactly, but I'm sure — I 16 Q. Well, you were worric a out your best 17 mean, I'm sure I did if I was flying to justify why she 17 friend, weren't you? 18 shouldn't go there. 18 A. Yes, but she already knows what happened. 19 Q. I mean, you gave her as much detail as 19 20 possible, didn't you, to discourage her from doing 20 Q. Were you in shock that your best friend 21 it? 21 would be doing this? 22 MR MERMELSTEIN: Form. 22 A. WASagain, Yes. 23 BY MR. LUTTIER: 23 Q. And this was a driving this car, right? 24 Q. Did you give her as much detail as 24 A. Yes. 25 possible in order to discourage her from going? 25 Q. Did that suggest to you that maybe, Page Page 1 MR. MERMELSTEIN: Form. 1 wasn't so traumatized by whatever occurred? 2 THE WITNESS: I don't know. I don't 2 MR. MERMELSTEIN: Form. 3 remember. 3 THE WITNESS: I don't know. 4 BY MR. LUTHER: 4 BY MR LUTITER: 5 Q. Did you tell her that it was a, an a — an 5 Q. Were you surprised? 6 older man who was going to be naked on a massage 6 A. I was surprised. 7 table? 7 Q. Did you ever have a conversation with A. Uh-huh, yes. a about why she went back the second time? 9 Q. Did you tell her he was going to — he was 9 A. No. 10 likely going to masturbate in front of her? 10 Q. Did M. tell you whether she was getting 11 A. Yes. 11 any money , feW7or taking M.? 12 Q. Did you tell her that he was likely going 12 A. No, I didn't know. 13 to touch her? 13 Q. Okay. So, do you, sO — 14 A. Yes. 14 A. I — Go ahead. 15 Q. Did you tell her that she would likely be 15 Q. I didrft mean to cut you off. 16 unclothed? 16 A. I was just going to say I figured that's what 17 A Yes. 17 was happening. 18 Q. And what was her response when you told 18 Q. Did you ask her? 19 her all of those things? 1.9 A. No. 21 A. didn't care. 21 Q. Did you tell M. that was going to 21 Q. Did you, did you tell her -- did you get 21 get money for taking r? 22 angry at her? 22 A. No. 23 A. Yeah, we got in a about it 23 Q. Did you tell M. whether she was going to 24 Q. That is you and M.? 24 get paid for going? 25 A. Yes. 25 A. No. • 29 (Pages 308 to 311) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976.2934) 1O0M6a-bc9d.4107-90a1-6373e816de0d EFTA01076464 Page 312 Page 314 Q. Did M. indicate whether she knew she was 1 this, and the driveway goes to the side of the house, 2 getting paid? 2 and there's — I think there was garages on the side. 3 A. I'm sure she did. That's the was going. 3 Q. Okay. And, and what kind of car did M. 4 Q. And what specifically did M. tell you in 4 have? 5 response to your warnings? 5 A. At that time? A. She didn't care. 6 Q. Yeah. 7 Q. All right So how long did this ride take 7 A. She's had a couple of cars. I'm going — I'm 8 to get to Epstein's? 8 going to, I'm going to guess it was her, a Lexus. 9 A. I don't know, I mean — 9 Q. You say you're guessing? 10 Q. More than a half hour? 10 A. I'm pretty sure it was a texas. I don't know 11 A. From — I mean, I don't even know where we 11 100 percent because she borrowed her mom's car and stuff 12 were at but it was, it was more than 20 minute. 12 like that. 13 Q. And this whole time is it dedicated to you 13 Q. Was this her mom's ear that you-all were 14 telling your girlfriends that you don't want to go? 14 in? 15 A. Not the entire time. I tried to talk them out 15 A. Her mom gave her that ear. 16 of it or tried to ta out of it fora little 16 Q. Okay. So it was — do you remember what 17 while, and she — . didn't listen, so... 17 model it *as? 18 Q. Okay. Son was navigating the car. 18 A. No. 19 She apparently remembered how to get to Epstein's 19 Q. Leather interior? 20 house. 20. A. I think it was leather. 21 A. I don't lmow how she — I mean, I don't know 21 Q. Okay. All right So you get to the 22 if she spoke to again. I don't know exactly along 22 house. 23 the lines how she got there again. 23 A. Uh-huh. 24 Q. But she navigated the car to Epstein's 24 Q. Where are you, where are you in the car, 25 house. 25 in the Bent seat or bwleceat? Page 313 Page 315 1 A. Yeah, she got to Epstein's house, but I don't 1 A. I'm in the backseat. 2 know how. 2 Q. And, and who — and M.'s driving. Is it 3 Q. Okay. When you got to the house, what did 3 bucket seats in the front? 4 you do? 4 A. What's bucket seats? 5 A. I — 5 Q. You know, were they bucket seats or a 6 Q. I mean where did you park the car? 6 bench seat in the front? 7 A. I think she's pulled — !mean, ha not going 7 MR. MERMELSIEIN: Do they make bench seats 8 to say definite, because I don't remember that, but I 8 in the front anymore? 9 think she pulled into the, the driveway that he had 9 MR: LurflER: I'm, I'm dating myself. 10 through the gates. 10 • BY MR. LUTITER: 11 Q. What kind of driveway is it? 11 Q. Do you know what a, a bench seat would 12 A. What do you mean, what kind of driveway? 12 be — a bucket seat was, is, is individual seats. 13 Q. Well, describe the driveway as best you 13 A. Oh, it's individual seats. 14 can. 14 Q. There's a console so you can't — 15' A. I know there was gates. I don't recall, I 15. A. Oh, yeah, that's how it is. 16 don't know if there was two entrances or one. 16 Q. All right. So you're in the backseat 17 Q. I mean, is it, is it like an asphalt-paved 17 A. Uh-huh. 18 driveway? 18 Q. Do you remember if you're behind the 19 A. Oh, I have no idea- 19 driver or the passenger? 20 Q. Do you know any — do you know anything 20 A. I think I was in the middle. 21 about the driveway? 21 Q.. All right. All right. 22 A. I don't remember. 22 A. I think because I was -- 23 Q: Where's the driveway in relationship to 23 Q.. So sitting on the hump, as they say? 24 the house? 24. A. Yes. 25 A. Ifs —you go in, and then the house is like 25 Q. And what were you wearing? HinrAnrILSCAPALA 30 (Pages 312 to 315) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601-061-976-2934) Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by Cynthia hopkins (601-051-976-2934) 1a30246a-bc9d-410740a1.6373a616da0d EFTA01076465 Page 316 Page 338 1 A. I have no idea. 1 Q. This house, this is this evil house that 2 Q. What was wearing? 2 you've been to -- 3 A. I have no igs& 3 A. .Yes. Q. What was M. wearing? 4 Q. — where you had a traumatic experience, A. I have no idea. 5 right? 6 Q. And you don't know what time of day it 6 A Yes. 7 was? 7 Q. So why didn't you just not go in the A. No. 8 house? 9 Q. Okay. 9 A. I don't know. 10 A. During the day. 10 Q. Okay. But, anyway, you get to the door. 11 Q. When, when you get there, what happens? 11 What happens? 12 A. I don't, I don't recall how we got in the 12 A. They go upstairs. I don't — 13 house or I don't remember how thaliappeasa All I 13 Q Wait a minute. Somebody has to answer the 14 remember is they went upstairs, M. and and I 14 door, right? 15 stayed in the kitchen area with the chef. There was a 15 A. I don't remember that. 16 chef there. 16 Q. Who answers the door? 17 Q. Let's go back imo the driveway. Did 17 A. I don't remember. 18 anybody come out of the house to meet you? 18 Q. Was it Jeffrey Epstein? 19 A. Not that I recall. 19 A. Honestly, I don't recall. I don't know. 20 Q. Did you-all get out of the car and walk 20 Q. You don't know who was there, so you can't 21 someplace? 21 describe what they were wearing? 22 A. We walked — I mean, I think we walked into 22 A. No. 23 the house. I don't recall. 23 Q. Were there other people in the house? 24 Q. Well, did you just walk in the house, or 24 A. All I remember is the chef. 25 did you walk to a door, or his door? 25 Q. Okay. And what's his name? Page 317 Page 319 1 A. I'm sure we walked to a door. 1 A. I have no i 2 Q. What door? 2 Q. Did you see on this occasion? 3 A. The front door. 3 A. I don't remember seeing her, no. 4 Q. The front of the house? 4 Q. Okay. Well, if you don't remember seeing 5 A. Yes. 5 her and there was a chef, but you can't tell us who 6 Q. Okay. Do you remember what the door was 6 answered the door? 7 like? 7 A. No. 8 A. No. 8 Q. Do you recall seeing Jeffrey Epstein on 9 Q. Is it a double door or single door? 9 this occasion? 10 A. I have no idea. 10 A. Yes, I did. 11 Q. Has it got anything on it? 11. Q. Okay. When did you see him? 12 A. I don't recall that. 12 A. At the end of everything. 13 Q. All duce of you walked up to the door? 13 Q. Okay. And you had not seen him since you 14 A. From what I vaguely remember. 14 left the previous time? 15 Q. Okay. Is there anything that prevented 15 A. Exactly. 16 you from just staying right in the car? 16 Q. All right. So, you say In end.. 17 A. No. 17 walked upstairs. 18 Q. Why didn't you just sit in the car? 18 A. Yes. 19 A. I don't know. 19 Q. You weren't up there? 20 Q. Why didn't you walk away? 20 A. No. 21 A. Walk away where? 21 Q. And you don't know what happened up there? 22 Q. Just walk away; walk down the street 22 A. I figured — 23 A. To go where? 23 Q. You don't know what happened? 24 Q. Anywhere you wanted to. 24 A. I don't know what happened up there with them. 25 A. Down to thewd.._...g !lei .a ..b 00d? ......, 25 Q. Did anybottell ru tat happened up 31 (Pages 316 to 319) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (8014514704934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (501.061.976.2934) 1a30246a-bc9d-4107-90a1-6373e8166e0d EFTA01076466 Page 320 Page 322 1 there? 1 A. Yes. '31 2 A. No. 2 Q. Tell me what words you used. 3 Q. When you kfl, did they tell you what 3 A. I don't know the exact words. 4 happened up there? 4 Q. Well, what's your best recollection of the A. No, not that I remember. They didn't tell me 5 words? anything about it. 6 A. I don't have a best recollection because I Q. And you walked from the front door to the 7 don't remember. 3 kitchen. 8 Q. Well, why did you tell him to pay you 9 A. — from the front door to the kitchen? 9 money? 10 Q. Yeah. 10 A. Because I was upset with even being there. 11 A. Yeah, I'm guessing. How else would I get 11 Q. Well, what had you done that you thought 12 there? 12 you were entitled to money for? 13 Q. Well, did somebody meet you at the front 13 A. I didn't do anything. 14 door? They must have, right. 14 Q. So why did you think he would pay you 15 A. There must have been somebody, but I cannot 15 money? 16 recall who it was. 16 A. Because I don't !mow why. I just — for 17 Q. You didn't just walk into the guy's house. 17 being in his house and him putting me through what he 18 A. No. 18 did, I was pissed off and -- 19 Q. So somebody met you there. 19 Q. What even made you think that he would 20 A. Yes. 20 give you mo 21 • anAdr usposm ?dy, did that somebody take taierbso 21 A. Becal:M. was there. 22 22 _Q. Oh, were you asking for money for bringing 23 A. Yes. 23 M.? 24 Q. Sow you when that somebody 24 A. No, because 1didn't bring her. 25 started takingM. and M. upstairs? 25 Q. Okay. So how much did you ask for? Page 321 Page 323 1 A. They probably took me to the kitchen first, 1 A. He gave me 200. 2 and then they took them. I didn't just walk to the 2 Q. How much did you ask for? 3 kitchen, I know that. 3 A. I didn't ask for anything. 4 Q. If you don't recall, tell me you don't 4 Q. Well, you just told me you told him that recall. I don't want to, I don't want you to guess. 5 you wanted money. o A. Okay. I don't recall. I just know I wasn't 6 A. Yeah, but I didn't ask for a specific amount. 7 upstairs and I ended up in the kitchen. 7 Q. So you well, you — did you just say, 8 Q. Okay. So you don't know whether you told 8 want money? 9 somebody you didn't want to go upstairs or you just 9 A. I don't recall how I asked him. 10 walked to the kitchen? 10 Q. So you might have asked him fora specific 11 A. I know I didn't walk to the kitchen alone. 11 amount 12 Q. All right. So you go to the kitchen. All 12 A. I don't think I did. 13 right. You get paid no money for going there. 13 Q. You just have no recollection? 14 A. No, I did get paid. 14 A. !don't have no, no. 15 Q. You did? 15 Q. But you know you got money. 16 A. Yes. 16 A. Yes. 17 Q. Well, who paid you money for going there? 17 Q. You went to this horrible place and you 18 A. Jeffrey Epstein. 18 got money for going there? 19 Q. What did you get paid for? 19 k Yes. 20 A. Because I was there and I was pissed off, so I 20 Q. And you took the money? 21 told him that he needs to give me money. 21 A. Yes. 22 Q. So you demanded of Jeffrey Epstein -- 22 Q. Asa matter of fact, you demanded the 23 A. Not demanded, but... 23 money. 24 Q. Did you say the words to him that you 24 MR. MERMEISTEN: Form. 25 wanted money? 25 THE WITNESS: I didn't demand it. 32 (Pages 320 to 323) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.061.976.2934) Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601-061.976-2934) • 1a30246a-bc9d-4107-90a1-6373o816de0d EFTA01076467 Page. 324 Page 3: 1 BY MR. LUITIER: 1 A. I don't, I don't, I really don't know. 2 Q. You asked for it? 2 Q. Was she there an hour? 3 A. Yes. 3 A. I really don't know. 4 Q. But no recollection about the amount? 4 Q. Okay. And when she came down, did she 5 A. No. have any money? 6 Q. Do you know what the denominations of the 6 A. Yeah, she had money. 7 bills were? 7 Q. What did she have? 8 A. No, I know he gave me $200. 8 A. I don't remember how much money she had 9 Q. Okay. Was it cash? 9 Q. Did she have cash? 10 A. Yes. 10 A. Yes. 11 Q. Do you know what the denominations were? 11 Q. Did you see the cash? 12 A. No. 12 A. I remember seeing the cash, but — 13 Q. When you asked for the money, what did he 13 Q. What denominations were they? 14 say to you, if anything? 14 A. I have no idea. 15 A. He said no. 15 Did you ask her what she got paid for? 16 Q. And then what was the discussion between 16 A. I figured what she got paid for. 17 you and he? 17 Q. Did you ask her what she got paid for? 18 A. Then we left, and then he called me back to 18 A. No. 19 come back and get it. 19 Q. Did you — 20 Q. Oh, so it wasn't when you were in the 20 A. I assumed it. 21 house initially? 21 Q. Did she tell you what she got paid for? 22 A. No, it was. I don't know where it was, but it 22 A. No. 23 was in the house or outside of the house. 23 Q. And you don't know how much it was? 24 Q. Well, stop. La's go slow. 24 A. No. 25 A. Okay. 25 Q. When you say you, you know what she got Page 32 Page 327 1 Q. Whore were you on this occasion the second paid for, did she -- what did you think she was 2 time when you first laid eyes on Jeffrey Epstein? 2 getting paid for? 3 A. I was in the kitchen. 3 A. I was thinking she was getting paid $400. 4 Q. Okay. 4 Q. For what? 5 A. I don't remember if he came down to the 5 A. Bringing-. 6 kitchen and got us to walk us out, or how it happened. 6 Q. Okay. And so after she comes down, when 7 I cannot tell you because I don't remember. 7 do you next sec either. or Mr. Epstein? 8 Q. Well, did he come down from upstairs? Did A. comes down. I don't remember -- I mean, 9 he come down alone? 9 .., I think I saw came down in the kitchen, and I 10 A. I was in the kitchen. 10 don't remember how, but I know I saw Jeffrey Epstein. 11 Q. W e the other two girls with him? 11 And we left after I... 12 A. M. came down first. 12 Q. Well, when you saw Mr. Epstein, you were 13 Q. Oka rad — 13 in the kitchen? 14 14 15 16 Q. there was you, and in the kitchen? n, and the chef 15 16 A. I'm, Pm pretty sure. I don't remember exactly is what I'm say to you. Q. Was, were both and present when 17 A. Yes. Like, it was me first. And then I guess 17 you saw Mr. Epstein for the first occasion on this 18 went upstairs. I don't know what they did, but she 18 second visit? 19 cant down, and then.. was still up them for a little 19 A. Yes, yes. 20 while. 20 Q. Did you speak words to him? 21 Q. How long was upstairs? 21. A. Yes. 22 A. I don't know. 22 Q And is that when you asked him for the 23 Q. Did.. tell you what happened? 23 money? 24 A. No. 24 A. Yes. 25 Q. Was she there more than a half hour? 25 Okay. And what did he say to you at that 33 (Pages 324 to 327) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051-976-2834) Electronically signed by cynthia hopkins (601-061.976.2934) 1a30246a•bc9d.4107.90a1.9373e816deOd EFTA01076468 Page 328 Page 330 1 time, no? 1 Q. Did M. tell you anything? 2 A. No. 2 A. No. 3 Q. What happened next? 3 Q. Did you ask either of them anything? 4 A. I said, fine, and I left. 4 A. No. 5 Q. Okay. When is it that he, that he 5 Q. So, this traumatic event that you had, you 6 contacted you? 6 went back, you sat down. You had warned your friend 7 A. He called me like two seconds after we left 7 don't do it. 8 the house. 8 A. Yes. 9 Q How did he contact you? 9 Q. But when you got in the car, you had no 10 A. By phone. 10 conversation with either girl about what happened 11 Q. Okay. And you spoke directly with him? 11 upstairs; is that right? 12 A. Yes. 12 A. I already — you're right, yes. 13 Q. And what did he say to you? 13 Q. Were you in tears? 14 A. Come back and get the money. 14 A. Was I in tears? 15 Q. And so what did you do? 15 Q. Yeah. 16 A. I went right back and got the money and left. 16 A. No. 17 Q. Well, you, you had to tell somebody in the 17 Q. Did you feel horrible? 18 car to turn arotmd. 18 A. !didn't want to be there. 19 A. Well, yeah, ■. 19 Q. Did you feel so bad that you wanted to get 20 Q. Okay. And what did you tell them? 20 money from Mr. Epstein? 21 A. They heard the phone. They heard what I said 21. A. !felt, I felt mad about being there — 22 on the phone. 22 Q. Did you -- 23 Q. Yeah. Okay. And so you went back. Did 23 MR. MERMELSTEIN: Form. 24 you go up to the door? 24 BY MR. LUTTIElt: 25 A. Yeah. 25 Q. -- feel like you did anything to get paid Page 329 Page 331 1 Q. Were you met at the door by anybody? 1 for? 2 A. Him. 2 A. No. 3 Q. Okay. And what did he do? 3 Q. Just an opportunity to get money? 4 A. Here. 4 MR. MERMELSTEIN: Form. 5 Q. But you don't know how much he gave you? 5 THE WITNESS: No. 6 A. No, no, 200. He gave me 200. 6 BY MR. LUTTIER: 7 Q. He gave you 200, right. And then you got 7 Q. Didn't bother you to take the money, did 8 in the car? 8 it? 9 A. Yes. 9 A. No. 10 Q. And you left. Have you seen Mr. Epstein 10' Q. What did you use the money for? 11 since? 11 A. I have no idea. 12 A. No. 12 Q. Did you spend it on luxury items that you 13 Q. Okay. And when you got in the car to 13 wanted? 14 ride, did you guys leave there and go someplace? 14 MR. MERMELSTEIN: Form. 15 A. I don't recall. 15. THE WITNESS: I don'treinewber. It could 16 Q. You don't know where you went? 16 have been anything. It could have been from 17 A. No. 17 food to — I have — like, I don't — I really 18 Q. Do you know how long you were in the car don't know. 19 together? 19 BY MR. LUTTIER: 20 A. No. 20 Q. Did you ever have a conversation with 21 Q. Did M. ever tell you what happened 21 at any time about what °muffed? 22 upstairs? 22 A. Not that I recall. I mean, I could have, but 23 A. No, I already, I figured what happened. 23 . I don't recall it 24 O. My question is did II tell you? 24 Q. Do you recall where you returned to — 25 A. No. 25 A. No. 34 (Pages 328 to 331) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-061.976-2934) Electronically signed by cynthia hopkins (601-05141764934) Electronically signed by cynthia hopkins (601-061-976-2934) 1a30246a-bc9d.4107-90a1.6373e816deOd EFTA01076469 Page 332 Page 334 1 Q. — alter this visit? 1 Q. Right up to today. 2 A. No. 2 A. I mean, I. and I vaguely talked about it, 3 Q. Did ever tell you if she ever went 3 but it's not like we got into it. It was, it was 4 back to Mr. Epstein's? 4 nothing really. A. I think she went back again. 5 Q. Okay. So both of these incidents happened Q. Did I. tell you whether she ever went 6 sometime in the year 2002? back to Mr. Epstein's? 7 A. Yes. A. I don't I don't know what instance she was 8 Q. And since 2002, for the last seven-Plus 9 telling me about. She told me she had a bad experience 4, you've never had a conversation with IIIII or 10 with him. 10 about it? 11 Q. Did la ever tell you whether she went 11 I can't remember if I have or not. 12 back to Mr. Epstein's? 12 Q. Who is the first person you ever had a 13 A. I don't know about 13 conversation with, or told anything about the 14 Q. Okay. And since that day when you went up 14 Epstein matters? 15 and took the money in your hand from Mr. Epstein, 15 A. I honestly — 16 your 5200 for sitting in his kitchen, you've never 16 MR. MERMELSTEIN: You're, you're. 17 seen him since then? 17 MR. LUITIER: Not your lawyer, yeah. 18 A. No. 18 MR. MERMELSTEIN: No, not the lawyer, no. 19 Q. Okay. When was the first time you told 19 You're talking about any visit? 20 anybody about that incident? 20 MR. LUITIER: Yeah. 21 A. The first time I told anybody besides like 21 MR. MERMELSTEIN: Okay. 22 • already knowing? 22 MR. LUTHER: Any, any visit. 23 Q. Yeah. 23 THE WITNESS: The only person I can think 24 A. First time I told an y? 24 of that I lust told, because it was . 25 Q. Yeah, other than an and 25 embarrassing to me, it was probably a Page 333 Page 335 A. I don't — anybody? Like any, anybody at all? 1 therapist. 2 Q. Anybody, Yeah, anybody. 2 BY MR. LUTTLER: 3 A. I don't recall the first person that I told. 3 Q. Well, who was that? 4 Q. How long was it after that that you told 4 A. I can't recall. 5 somebody? 5 Q. Well, what — in what state? 6 A. It was a little while. 6 A It was probably in Virginia. 7 Q. How long is a little while? 7 Q Okay. And, and you didn't go to Virginia 8 A. Well, I held it in fora while, so l don't — 8 until what year? 9 I mean, I don't have an exact time frame It's just — 9 A. 2006. 10 Q. Less than a month? 10 Q Okay. And so is it one of those two 11 A. No. 11 therapists you told me, the psychologists or the 12 Q. More than a month? 12 psychiatrist that you told me you went to see in 13 A. No. It was years. 13 Virginia? 14 Q. Years, plural, years? 14 A. Yeah. 15 A. A year. Q. So for, what, over four years you remained 16 17 Q. So, after — other than you — strike that. s and I., did . • 15 16 17 silent and never said anything to anybody about it? A. Kept it inside, yes. 18 Didi nou have any further conversation with 18 Q. Okay. And you didn't tell your boyfriend 19 IN and about going to Epstein's house; that 19 about it? 20 is, either e times that you went the first time or 20 A. No. I recently told my husband about it. 21 the second time? Ell ou have, ever have any other 21 Q. When, what you say recently, when was the 22 conversation with or El. about it? 22 first time you told your husband about it? 23 A. Not that I can recall, no. 23 A. In Virginia. 24 Q. Ever'? 24 Q. After your wedding? 25 A. Not that I can recall. 25 A. Yes. 35 (Pages 332 to 335) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by cynthia hopkins (601-061-976.2934) Electronically signed by cynthia Hopkins (601-051-976-2934) Electronically signed by cynthia trot:tins (601-051-976-2934) la30244a4x9d410740043730111dad EFTA01076470 Page 336 Page 338 1 Q. And what was his reaction? 1 A. But ho might reenlist. 2 A Disgusted. 2 Q. All right. 3 Q. What did he say? 3. A. So I don't know. 4 A. Why would you go to an older man's house to 4 MR. LUTHER: Okay. 5 give him a massage and do sexual things that happened. 5' ' THE VIDEOGRAPHER: Going off the record at 6 He still gets upset about it. 6 3:44 k This marks the end of this portion 7 MR. LUTHER: I'm not going to finish. 7 of the deposition. 8 This is probably as good a place as any to 8 (Witness excused.) 9 stop. Ifs a quarter to 4:00, and we'll just 9 (Deposition was adjourned) 10 arrange a time to reconvene. 10 11 BY MR. LUTHER: 11. 12 Well, let me, let me ask a couple of 12 13 things. Where do you live now? 13 14 A I live in Virginia 14 15 Q. Olat.y. What, what's the address? 15 16 A. Its — 16 17 Yeah. 17 18 A. 18 19 Yeah. 19 20 A. Apartment 20 21 Q. And you live there with your husband? 21 22 A. Yes, and my -- 22 23 Q. Is he out — is he badc to the US? 23 24 A. Yes. 24 25 Q. So he's stationed at a base there? 25 Page 337 Page 339 1 A. No, I mean, he's at the Norfolk base, but he 1. CERTIFICATE OF OATH 2 comes home on a daily basis. 2 THE STATE OF FLORIDA 3 Q. Okay. But he's here in the US? 3 COUNTY OF PALM BEACH 4 A. Yes. 4 5 5 Q. And how long has he been back? 6 I, the undersigned authority, certify that 6 A. What was it? When did he get back? When I 7 JANE DOE NO.5 personally appeared before me 7 finished — Dec -- Fm going to say December. 8 and was duly sworn on the 26th day of May, 8 Q. ()fit° — of 9? 9 2010. 9 A. Yea. 10 10 Q. Okay. And, and what are your immediate 11 Dated this 10th day ofMay, 2010. 11 plans about where you-all are going to live? 12 12 A. After he gets out of the military? 13 14 13 Q. No, right now. I mean, do you plan to 15 14 15 continue to live in Virginia? A. Yes. Orka.c: att•isiAs 16 16 Q. How often do you come to Florida? Cynthia Hopkins, RPR, FPR 17 A. I, when he's there, I rarely come here. 17 Notary Public - State of Florida 18 Q. Okay. And is he scheduled to go out on My Commission Expires: February 25, 2011 19 any other deployments? 18 My Commission No.: DD 643788 20 A. As of now, no. 19 20 21 Q. When does he get out of the military? 21 22 A. Next April. 22 23 Q. Apiil °fit° or April of '11? 23 24 A. 'U. 24 25 Q. Okay. 25 ..etASZT=St 36 (Pages 336 to 339) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051478-2934) Electronically signed by cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (601451476.2934) 1.30240tbc9d4107-9024-6373•1116ds0d EFTA01076471 Page 340 Page 342 • 1 CERTIFICATE 1 CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OFPALM BEACH 2 3 THE STATE OF FLORIDA 5 I, Crthia Hopkins, Registered Professional Reporter, Florida Professional Reporter and Wary 4 COUNTY OF PALM BEACH 6 Public in and for the State of Florida at large, do 5 I hereby certify that I have read the foregoing hereby cerillY that I was atthaized to and did report said deposition in stenotype; and that the 6 deposition by me given, and that the statements foregoing pages we a true and correct transcription 7 contained herein are true and correct to the best of 8 ofmy shorthand notes of said deposition. 9 I further artily that said deposition was 8 my knowledge and belief, with the exception of any taken at the time and place hereinabove set forth 9 corrections or notations made an the errata sheet, 10 and that rho taking of said deposition was commenced 10 if one was executed. and completed as hereinabove set out. It 11 I further catty that I am not attorney or 12 Dated this day of :2 counsel of any of the parties. nor am I a relative or employee of any attorney of counsel of party 13 2010. 13 connected with the action. nor am I financially 14 interested in the action. 14 15 The foregoing cauficanon of this transcript 16 15 does not apply to any reproduction of the same by any means Wens under the direct control and/or 17 16 direction of the certifying reporter. 18 17 Dated this IOth day of March, 2010 18 19 JANE DOE NO. 5 19 20 Job #1312 20 crlie AS 21 21 Cynthia Hopkins, RP FPR 22 22 23 23 24 24 25 25 Page 341 Page 343 I DMZ Much 10k 2010 ERRATA SHEET TO. JAM DOE NO.S do Sart S. klornetagia 2 INRE: JANE DOE NO. 2 VS. EPSTEIN 5fERMELS1804 &HOROWITZ, r at Cynthia11°0So 18101lesottec Ocoletor0 Sae 211i 3 DEPOSITION OR JANE DOE No. 5 Allot Marl& 13140 TAKEN: Maury 26,2010 IN RE to Melt 2n Fp*: 4 JOB NO.: 1312 5 DO NOT WIT ON TRANSC1UPT - ENTER CHANGES HERE CASENO : ell-th40119-MARRABOHMON PAGE # LINE S CHANGE REASON flea it notlot tat coPS*, the 204k ct 6 Petony. 2010, you toe rye dcpmeica 7 abtherefttn4 mime. Al the lime, we. 464 8 9 wain *eon It it thaw remssary Ixoya. svi rue tkpositko. 9 to As 10004421eweed 4:k S llMnnplu'abi 10 furnith:d toyaz drat), sox Goad Pkoe read 11 eke falemiwz metrocums mnfully. 11. At die the dt taLlemptrzu W fin: at 12 12 enact 'Sm. As you mei yeti' eltscrjoon. toy c/angen or ortcticat Iha>oe with v mac 0:001a I3 I) be toed co Qc ernes 3xvt. sung F"," 4'4 bx 14 mmtedred elarits DO NOT one ens 15 14 um...no Go:e you hen twite ttamars ar:Intm: arty tots. be smelt/ %In 16 15 god dye Qw ones stem ad room tee pipe Io 17 Please forward the original signed arato sheet to me la t.aadorctrcadrd tip tl* depceLixa this office so that copies may be distributed to all withe. a ffe•Enilth. erne, the original. tulOch ha 18 potties. 13 lma>, trot fcr.v.v&I to deaden% beeeery, ml) be fkd with Fs Clete eldt Gun Wyoo ant 19 Under penalty ofperjury, I declare that I have read le .0 *any Yme .Sostwt Mope sot ova In the Wat, my deposition and that it is true and correct at the bon= delis otter 4114140211 t taus 20 subject to any changes in form or substance entered 19 Voyeurs ritia here. 20 21 rAlcoAs 22 DATE: 21 1.FPR C3m1W414 4,161. 1111 23 22 23 10o keeeby vents eipxoeet 24 SIGNATURE OF 24 DEPONENT: 25 Waft NO. 5 25 37 (Pages 340 to 343) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601-051.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1a30246a4acgd-4107-90.14373•816defld EFTA01076472