EFTA00724010

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NQ.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- 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 DEPOSITION OF Friday, February 12, 2010 2:09 - 2:52 p.m. 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.: 1231 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-f430-4b0a-bb09-1)035b310829d EFTA00724010 l EFTA00724011 Page 2 Page 4 1 APPEARANCES: 1 me know and I will explain it for you. 2 Cm behalf of the Plaintiff. 3 SWART S. MERMELSTED4, ESQUIRE 2 A. Okay. MEFtMELSTE1N & HOROWITZ, P.A. 3 Q. If you want to take a break during the 4 18205 Biscayne Boulevard 4 deposition, just let me know and you can take a Suite 2218 5 break. If during the deposition you recall 3 Miami, Phone: 6 something and you think you need to correct an 6 E-mail: 7 answer or supplement an answer that you have already Oa behalfof Defendant: 8 given me, just let me know and you can do It. 8 MARK T. LUTTIER, ESQUIRE BURMAN, CRHION. LUI 1ibR & COLEMAN, I.LP 9 There's no tricks. 9 303 Banyan Boulevard 10 A. Okay. Suite 400 11 Q. Its a pretty informal procedure. If you 10 West P *da 33401 Thorpe. 12 need something, just let me know. 11 E-mail: 13 Are you represented by a lawyer today? 12 14 A. He's my lawyer's witness. 13 14 15 Q. What? 15 16 A. Asa witness, he is my lawyer. 17 Q. So, Mr. Mennelstein is your lawyer? 16 NO EXHIBITS MARKED • •• 18 A. Yes, sir. 17 19 Q. Do you know Jane Doe No. 4? 18 20 A. Yes. 19 20 21 Q. When did you first meet Jane Doe No. 4? 21 22 A. October '08 or September '08, I think. 22 23 Q And what were the circumstances when you 23 24 24 met her? 25 25 A. We was dating. Page 3 Page 5 1 PROCEEDINGS 1 Q. I mean how did you run into her? 2 2 A. I met her with some of her friends at a 3 Deposition taken before Cynthia Hopkins, 3 restaurant, like a restaurant bar. 4 Registered Professional Reporter and Florida 4 Q. Do you remember what restaurant bar it 5 Professional Reporter, and Notary Public in and for was? 6 the State of Florida at Large, in the above cause. 6 A. Tski bar. 7 7 Q. 8 Thereupon 8 A. 9 IMa 9 Q. Do you remember who the friends were? 10 having been first duly sworn or affirmed, was 10 A. I think one of her friends was that v.as 11 examined and testified as follows: 11 it. 12 DIRECT EXAMINATION 12 Q. Wouldthatbea 13 BY MR. LUTTIER: 13 A. Uh-buh. 14 Q. Can u tell us your name, please. 14 MR. MERMELSTEIN: You have to answer yes 15 A. 15 or no. You have to answer verbally because she 16 Q. Mr. have you ever been deposed 16 is taking everything down. 17 before? 17 THE WITNESS: Okay. 18 A. Excuse me? 18 MR. MERMELSTEIN: So, if you say uh-huh or 19 Q. This process, have you ever had a 19 nod your head, it doesn't work. 20 deposition taken before? 20 THE WITNESS: Okay. 21 A. No. 21 BY MR. LUTTIER: 22 Q. Okay. You understand you're under oath? 22 Q. Whatllow date of birth? 23 A. Yes. 23 A. 24 Q. I am going to be asking you questions. If 24 Q. S9. that makes you how old? 25 ou don't understand one of my questions,just let 25 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430.4b0a-bb09-b035b310829d EFTA00724012 Page 6 Pay E: 1 Q. 1. You ever been married? 1 this, do you all live together right now? 2 A. No. 2 A. Me and Jane Doe No. 4? 3 Q. Getting ready to get married? 3 Q. Yes. 4 A. Considering. 4 A. Yes. 5 Q. I am not going to tell what Jane Doe No. 4 Q. Where do you live? 6 said. 6 A. I 7 A. Yes. 7 Q. W tfa address? 8 Q. Do you plan on getting married to Jane Doe 8 A. 9 No.4? 9 Q. s ”a Me ent? 10 A. Yes. 10 A. Yeah. 11 Q. Okay. Any time frame? 11 Q. Is that one that you have been in? 12 A. No. 12 A. It's a condo. I own it. 13 Q. Then can I assume from that that your 13 Q. Condo. 14 relationship and hers is pretty good? 14 A. Yeah. 15 A. Yes. 15 Q. And were you living there before you met 16 Q. You had a couple of rocky bumps in the 16 Jane Doe No. 4? 17 road? 17 A. Yes. 18 A. Yes. 18 Q. And after you met her in and around 19 Q. There was a El thing in the 19 September of'08, did there come a time that she 20 past? 20 moved in? 21 A. What was that? 21 A. Was there what? 22 Q. There was a a 22 Q. Did there come a time that she moved in 23 A. Yes, sir. 23 with you after September of '08? 24 Q. Has that an all been smoothed over? 24 A. Yes. 25 MR. MERMELSTEIN: Objection to font'. 25 Q. And do you know about when that was? Page 7 Page 9 1 THE WITNESS: Yes. 1 A. After I think. it was right before 2 MR. MERMELSTEIN: If I make an objection. stmt & 3 it's to the form of the question just for the 3 'hat would be when she front El 4 record. You've got to answer the question 4 5 unless I tell you not to. 5 . es. 6 THE WITNESS: Okay. 6 Q. Was she still at when you were dating 7 BY MR. LUITIER: 7 her tally? 8 ,Have, have you spent any time with= 8 A. Yes. 9 and Jane Doe No.4 together since you first 9 Q. Let's see. If it's September of'08, did 10 met her? 10 she still have 11 A. Yeah es. 11 A. !twits 12 Q. Is M still someone that comes around 12 Q. H y. So, you would have 13 a lot? 13 been dating since September of'08 until June of 14 A. No. 14 '09? Did you go down and watch hand 15 Q. Do you ;mow why? 15 stuff Ince that? 16 A. No. 16 A. A couple times. 17 Q. Do you know who Jane Doe No. 4's best 17 Q. Did you grow upa 18 friend is now? 18 A. Yes. 19 A. She's got a couple of friends in . Do 19 Q. Where did you go to school? 20 you vault the name? 20 A. High School. 21 Q. Yeah. 21 Q. i! would you describe your relationship 22 23 24 A. 4 . A. Yes. and Jane Doe No. 7 probably. And would that 22 23 24 with Jane Doe No. 4? A. Now everything is good. Q. Any problems that you've identified? 25 l:Z Are these People-.LeliaLbould atz:m 25 A. Now? 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-(430-4b0a-bb09-b035b310829d EFTA00724013 Page 10 Page 12 1 Q. Yes. What were they?e 1 A. At least seven times. 2 general problems that led to th 2 Q. Over about what period of time? 3 incident? 3 A. What is it now? February. Before Christmas 4 A. There was a lot of anger and confusion and 4 probably. Let's see. No, like November and December. 5 emotional, you know, a lot of stuff from the past and a 5 . ' uld have been after the 6 lot of emotional, you know, stress and problems. 6 incidence? 7 Q. And was that anger and confusion on her 7 A. What, that we went there? 8 part or on your part? 8 Q. Yeah. 9 A. Was it what? 9 A. U before. 10 Q. Anger and confusion on her part or on your 10 incident was 11 pert? Was she the one that was angry with you, or 11 ink you started 12 were you the one that was angry and confused? 12 going there befo 13 A. She was. 13 A. Yes. 14 Q. And how did you get all that resolved? 14 Q. Okay. How far before that? 15 A. We went to a counselor. My, I have a family 15 A. Probably a couple of months. 16 counselor we go to like my parents and, you know, it's 16 Q. ions do you think you had 17 for relationships as well, helps out. She was just able 17 bet'o 18 to talk to someone and let it, you 'mow, out what was 18 A. Five. 19 bothering her. 19 Q. With freguency were you 20 Q. !stills o so ing? 20 going bef 21 A. Huh? Yeah. , 21 A. Like weekly. 22 Q. And were you going to Mr.". before 22 Q. Okay. Hour sessions? 23 you ever met Jane Doe No. 4? 23 A. Yeah, yts. 24 A. No. 24 Q. What were the issues that were being 25 Q. How is it that you first came to go to 25 discussed as they related just to you and her? Page 11 Page 13 1 him? 1 A. Well, just her issues and problems that she 2 A. My mother. It's our family history like 2 has, you know, regarding her past. 3 started going there after I met Jane Doe No. 4 and me 3 Q. What were those? 4 and her went. 4 A. Just a lot of anger she had built up, and she 5 Q. Were you going to him after you met Jane 5 needed to let it out and talk to someone. 6 Doe No. 4 for issues that you had with your family? 6 Q. Anger built up about what? 7 A. Yes. 7 A. Her past. 8 Q. And was she initially going with you in 8 Q. Anything in particular about her past? 9 what we would calla supportive role just going 9 A. I didn't really get into everything. Like, 10 along with you while you talked about your issues in 10 she went by herself too, you know. 11 your family? 11 y herself prior to 12 A. Yes. 12 13 Q. And when she went did she just ride up to 13 A. Yes. 14 the office with you, or did she actually go in and 14 Q. Are you sure of ? The reason I 15 meet with you and the counselor? 15 ask you is we took Mr. de ' ' is 16 A. She came in. 16 agaits don't indicate visits prior to 17 Q. Okay. When she came in with those, with 17 ME? 18 you on those sessions, were those sessions just 18 A. That she never went there? 19 concerning issues that you had with your family? 19 Q. No. Prior to that date. He has got 20 A. Just everything pretty much. 20 records of visits after that date. 21 Q. Were there any issues about you and her 21 A. Before. 22 that were discussed when she went with you? 22 Q. w because you can relate 23 A. Yes. 23 it to die . 24 Q. How many times did you and she go 24 A. I would have to check my records and my. like, 25 together? 25 copies of my checks like when I wrote them. leant 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-14304b0a-bb09-b035b310829d Electronically signed by cynthia hopkins EFTA00724014 Page 14 Page 16 1 retail the exact date, you know. 1 A. Unh-unh. 2 Q. So, did you go alone sometimes to him? 2 Q. It was just that the two of you would 3 A. We would both go together and sometimes she 3 argue from time to time? 4 would go first and sometimes we would go together. 4 A. Yeah. It was basically, basically that, yeah. 5 Q. Were you working on issues of conflict 5 Q. When people use the word *basically; I am 6 between the two of you? 6 always suspicious because that indicates to me that 7 A. Some of that and the other with her. 7 there is something else. 8 Q. I know, but were you guys having problems? 8 A. Yeah. That's why we went there for, for the 9 1mean you guys were squabbling about something? 9 relationship and for, you know, so she could talk to 10 A. Just normal relationship issues, you know. 10 someone about what was, you know, what's bothering her. 11 Q. Did you, did you ask her to go up there 11 Q. So, do you — had something occurred that 12 with you? 12 you would come to the conclusion there must be 13 A. We both agreed on it. 13 something bothering her? 14 Q. Okay. What is it that made the two of 14 A. When she maid drink, she was just — anger 15 you — what was it that was the issue that made the 15 was built up in hor, you know. 16 two of you say let's go see this guy? 16 Q. Now, so was it that you made the 17 A. So, we can, you know, work out, work on our 17 observation that when she drank she was, for lack of 18 relationship, and so she could, you know, be happy and 18 a better term, an angry drunk? She would get angry 19 talk about her problems. 19 when she drank? 20 Q. Was there anything specific? For example, 20 A. She would take everything out on me. 21 I am just going to give you a hypothetical. Let's 21 Q. Okay. All right. You would be the bad 22 say you had a habit ofcoming borne and throwing your 22 guy? 23 laundry on the floor and that drove her nuts so you 23 A. Pretty much. 24 guys would fight about that So, you said we're 24 Q. Can you give me sort of an example of what 25 going to go see this guy and were going to say, 25 would happen? Page 15 Page 17 1 yeah, we're going to see this guy because I used to 1 A. Well, when she drank, she would just — I mean 2 have a habit about throwing my laundry on the floor 2 the only way she knew how to let it out was like go out 3 and it upset her. And that's what I'm talking 3 and drink and, you know, that she would think about her 4 about. 4 past and let everything out on me, you know. 5 A. It wasn't really about that. 5 Q. Would it be situations where the two of 6 Q. Well, I was using that as a — 6 you would be going out and drinking together, or she 7 A. Yeah. I know but nothing like that 7 would go out and drink and cane home and unleash on 8 Q. Did you guys find yourselves fighting 8 you? 9 about things? 9 A. Together. 10 A. Yeah. We argued about things, you know. 10 Q. So, you and she would go out to a bar or 11 Q. What kinds of things did you argue about? 11 something and start drinking? 12 A. You know like when we would fight, you know, 12 A. Everything would be fine and good and then as 13 just arguments. I can't recall exactly. 13 soon as — later that night that's when it would start, 14 4 I mean did she say you drank too much for 14 you know. 15 example? 15 Q. And there was at least the one time where 16 A. No. 16 it was a physical confrontation? 17 Q. Was there a drug use problem? 17 A. Was it what? 18 A. No. 18 Q. At least one time it was a physical 19 Q. Somebody said somebody used drugs? 19 confrontation? 20 A. No. 20 A. Well, just a bad argument. And I mean, l 21 never touched her or nothing like that, w. 23. Q. You wanted to go out too much? 22 23 A. No. Q. You stayed out too late? 22 23 24 ling . Well, I was referring to but she touched, A. Yeah. She might have yeah. 24 A. No. 25 Q. How long was it into your relationship 25 Q. Anything specific? 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia bodkins 6dc078c7-f430-4b0a-bb09-b035b310829d EFTA00724015 Page 18 Page that you noticed that when she drank she got angry? 1 A. No. A. Well, when we started getting serious like 2 Q. No. So, she would just come home and tell 3 after, like before Christmas like when, you know, we 3 you you were an asshole? 4 knew each other better and started caring about each 4 A. Come home and after drinking, and that's what 5 other more and getting 5 would happen. Q. W 6 Q. How much drinking were we talking about? 7 incident 7 Would she be drunk? 8 A. Before. 8 A. Yes. Q. Okay. All right. So, then it had to be 9 Q. Was one of the problems the quantity of 10 two or three months before Christmas? 10 alcohol being consumed? 11 A. Uh-huh. 11 A. Maybe like liquor, you know. 12 Q. So, when the incident -- 12 Q. I mean was one of the things, look, you 13 A. Yes. 13 need to cut back on the alcohol because when you 14 Q. So, w the Meld 14 drink you're, it's not fun? 15 happened o you-all had gotten 15 A. Yeah. Beer, I mean she drinks beer, you know, 16 into a deeper, more serious relationship? 16 she wasn't as bad, you know. But the liquor is when it 17 A. Yes. 17 really came out. 18 Q. And you had been going to counseling 18 Q. So she - did you observe then during that 19 because she would get angry when she drank? 19 relationship that you thought maybe she had an 20 A. Yes. 20 alcohol problem? 21 Q. Had she ever hit you up until that point 21 A. I didn't think that she had an alcohol problem 22 in time? 22 I just thought that she had a lot of things built up and 23 A. No. 23 she needed to talk to someone. Just like, you know, 24 Q. And how was her anger vented to you? 24 people, a lot of people have problems and they need to 25 A. Huh? 25 talk to someone and get help with what's bothering them. Page 19 Page 21 1 Q. By that I mean would she be yelling and 1 Q. After going to this counselor, did she cut 2 screaming at you? 2 back on the amount of alcohol she drank? 3 A. Yes. Just saying mean and nasty things. 3 A. Yes. 4 Q. Nasty things like what? 4 Q. Does she drink now less than she did then? 5 A. Like name calling and, you know, just saying 5 A. Yes. 6 rude things; name calling and saying rude things. 6 Q. Do you think that's been helpful? 7 Q. What kind of names would she call you? 7 A. Yes. 8 A. Well, just bringing up stuff from like -- it 8 Q Any belief by her that you had a problem 9 didn't, stuff that didn't make sense. She would just drinking too much alcohol? 10 say, you know, like, I am an asshole or stuff like that. 10 A. (Witness shakes head.) 11 And she would just, when she drank, you know, all the 11 Q. Anybody ever accuse you of drinking too 12 anger — I don't even know, it just came out on me 12 much alcohol? 13 ber-mke I was the only one there and that's how she knew 13 A. No. 14 how to let it out. 14 Q. Have you ever had a problem with alcohol? 15 Q. And anymore than calling you an asshole? 15 A. No. 16 A. Just, you !mow, I can't recall exactly, you 16 Q. When you would go out were you sober when 17 know, what she called me, what she said. 17 you came back? 18 Q. Would she accuse you of specific conduct 18 A. Sometimes. 19 or doing specific things? 19 Q. Can I assume that when you guys went out 20 A. No. 20 at least one of you were sober? 21 Q. For example, I am not saying this happened 21 A. Yes. I was driving but I had a drink or two. 22 but this is an example: She would get drunk and you 22 Q. But she would be as they would say 'a 23 would coma home and she would be mad and she would 23 couple of sheets to the wind"? 24 say, you know, you were looking at other girls in 24 A. Yes. 25 the bar, that kind of thing? 25 I. All right. Did ou attempt to • her to 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b035b310829d EFTA00724016 Page 22 Page cut back on the drinking before you started going to 1 drink? the counselor? 2 Q. Right 1 A. Yes. 3 A. Yes. 4 Q. And is that what drove you to the 4 Q. So, you have an idea of when people get counselor initially, not you individually but the 5 dmnit? 6 two of you together? 6 A. Yes. 7 A. What, the drinking? 7 Q. And when they can't remember things they 8 Q. Yeah. 8 did the night before? 9 A. Yes. That, the drinking and the, just the, 9 A. Yes. 10 you know, normal relationship issues, you know, that and 10 Q. That's generally an indication that they 11. basically, yeah, the drinking. 11 had too much to drink? 12 Q. Okay. In other words a person said, look, 12 A. Yes. 13 this alcohol is creating a problem; we have to 13 Q. And she was drinking at a level where she 14 figure out a way to get that under control. Is that 14 wouldn't remember what went on? 15 a fair statement? 15 A. Not all the time. 16 A. It wasn't all about the, about that, no. 16 Q. But sometimes? 17 Q. Well, was the result of going about that 17 A. Couple times. 18 and then the counselor dug in a little bit to try to 18 Q. And when, how much drinking are we talking 19 find out what was going on? 19 about? If you would go out, for instance, to a bar, 20 A. It wasn't about just the drinking. It was 20 are we talking about drinking two or three drinks or 21 about her past, you know, and why she would drink so 21 are you talking about we would be there for four or 22 much. 22 five hours? 23 Q. Okay. 23 A Like five drinks and then some shots, you 24 A. You know, and why she was doing the things she 24 know, probably four drinks depending on what she was 25 was doing. 25 drinking, either wine or sometimes beer or alcohol, Page 23 Page 25 1 Q. Other than drinking, what else was she 1 liquor. 2 doing? 2 Q. Plus shots? 3 A. lust, other than drinking, that's it. That's 3 A. Well, yeah, we would have a few shots, yes. 4 all she does. 4 Q. Was there ever any particular incident 5 Q. Did you ever ask her why she drank so 5 that happened when she was drunk that sod of caused 6 much? 6 )ou to say, look, stop, we have got to do something 7 A. No. She's just young, and when I was that 7 about this? 8 young, I drank a lot, too. 8 A. When she was drunk? 9 Q. What's your age difference? Let's see. 9 Q. Yes. 10 You're she's 10 A. Yes. I mean, the only time that like when I 11 A. She's 11 said that, you know,1 said, well, wait until the next 12 Q. So, she never said anything to you about 12 day so we can talk normally, you know, and then you know 13 why she drank or why she got angry at you after she 13 what were talking about and you remember what you're 14 drank? 14 talking about, because when people drink or when people 15 A. She never said anything. She never said why 15 are intoxicated, they don't, you know, remember what 16 she drank Like, she would start off normal, you know, 16 they say or what they do or you 'WOW. 17 and then after a while just she never -- she don't, she 17 Q. Okay. So, when you went with her and had 18 didn't remember what she was saying, you know. She 18 sessions with this fellow, those sessions that 19 don't even recall. 19 concerned your relationship, what did she tell the 20 Q. Can I assume that you have some experience 20 counselor? 21 with being around people that have too much to drink 21 A. I wasn't in, I wasn't in there maybe one time 22 that you acquired during your lifetime? 22 with her when she went for her personal matter, you 23 A. Do I? 23 know. 24 Q. Yeah. 24 Q. So, she kept that with the counselor? 25 A. Have I been around a bunch of people that 25 That was between than? J•44.1) 7 (Pages 22 to 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc075c7-1430-4b0a-bla09-h035b310829d EFTA00724017 Pace 2 6 Page 28 A. Yes. fora little bit. 2 Q. Did she ever share that with you? 2 Q. Okay. Did you go away to college 3 A. No. 3 anywhere? 4 Q. Did she ever tell you whatever the problem 4 A. I went to ■ for a semester and then came 5 was? 5 back 6 A. Well, I mean like you can read stuff online 6 Q. I understand that 7 B about, you know, what went on, and that's MI pretty much know. 7 8 a got . I was for five years and then I had a chance 9 Q. Are we talking about this fellow Jeffrey 9 o u iness ou know. 10 Epstein? 10 an arid stuff like that. 11 A. Yes. 11 Q. And that's you, in that business now is 12 Q. Is that — what you keep saying her past 12 you and your brother? 13 and stuff, is that what you're referring to? 13 A. Correct, yes. 14 A. Yes. 14 Q. What's the age difference between you and 15 Q. Is there anything other than her 15 your 16 involvement with Mr. Epstein? 16 17 A. No. 17 Q. Is he older or are you older? 18 Q. What has she herself told you about her 18 A. I'm older. 19 involvement with Mr. Epstein? 19 Q. So, you're guiding your younger brother 20 A. I mean, I read stuff online and like I really 20 through the business? 21 don't know everything, you know. 21 A. Yes. 22 Q. Is your only knowledge — 22 Sassume he grew up locally and did he go 23 A. I don't really want to, you know, like right 23 to High too? 24 now. 24 A. Yes. 25 Q. Is your only knowledge whet you read 25 Q. All right. So, you went through the usual Page 27 Page 29 1 online? 1 high school, post high school stuff. Does anything 2 A. Yes. 2 about Jane Doe No. 4's past color your opinion or 3 Q. That would be newspaper articles? 3 *cling towards her at all? 4 A Yes. 4 A. No. Q. How about any of these friends that you 5 Q. I mean you feel about her, you don't hold 6 said that she had, Jane Doe No. 7 comes to mind, 6 her past against her or anything like that? 7 would they talk to you at all? 7 A. No. 8 A. No. 8 Q Asa matter of fact do you, do you not 9 Q. Do you know whether or not Jane Doe No. 7 9 even care to know about her past? 10 had an experience with Mr. Epstein? 10 A. I would, I would like to, you know, 11 A Do what? 11 eventually. 12 Q. Do you know whether or not her friend, 12 Q. Whagaou know about her past? You knew 13 Jane Doe No. 7, had any interaction with 13 she played MI right? She was a high school 14 Mr. Epstein? 14 athlete? 15 A. No. 15 Yeah. Played wan to 16 Q. Okay. So, you grew up locally, went to 16 M. Grew up out there in 17 local high, played ball in school? 17 Q. Oot a scholarship at — 18 A. Yes. 18 aR . 19 Q. WhatdidvouDla 19 20 A. 20 A. Smart. 21 Q. For Hi 21 Q. You knew she had to be a pretty good 22 22 athlete to get a scholarship. 23 for kit tl. laY kir I PlaYed 23 A. Yes. 24 Q. And you played pretty good tell fora high 2; iYI -24 z ;edluzosmaiS n? anclaglaYed 25 school student; you knew what that would require? 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. • Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b035b310829d EFTA00724018 Page 30 Page 32 1 A. Yes. 1 Q. And then did she come back and start 2 Q. And she's smart? 2 living with you again? 3 A. Yes. 3 A. ou know, ban ing out because we had a 4 Q. Were you an academically inclined 4 5 individual in high school? 5 ou to wait for that to got resolved? 6 A. Average. 6 A. Yeah. 7 Q. Okay. She was a hard worker, you figured 7 Q. You told th 8 that out? 8 9 A. Yes. 9 A. Yes. 10 Q. Okay. So, she kind of kept whatever she 10 Q. So, they decided not to eventually? 11 was talking to this counselor about between he and 11 A. Yes. 12 you. Did you ever have discussions with her about 12 Q. Okay. She drinks less now than she did? 13 any changes in her conduct or did it just kind of 13 A. Yes. 14 take place? 14 Q. She doesn't get angry at you anymore? 15 A. About what? 15 A. No. 16 Q. Any changes in her conduct or did she just 16 Q. I am going to guess she doesn't call you 17 start to change? 17 an asshole very much, occasionally, not a lot? 18 A. You mean now? 18 A. Sometimes. No. 19 Q. Yeah. From the time you guys first 19 Q. And my guess is you don't call her any of 20 started going until now. 20 those names? 21 A. Yeah. I mean, yes. She, she's changed, you 21 A. No. 22 know. Everything's, you know, everything is getting 22 Q. Okay. Nice lady? 23 better, you know. 23 A. Huh? 24 irin when you had the 24 Q. Nice lady? 25 incident — 25 A. Jane Doe No.4? Page 31 Page 33 1 A. We hadn't had any problems. 1 Q. I said she's a nice lady 2 Q. What led to that? Was that following a 2 A. Yes. 3 night out drinking? 3 MR. MERMELSTE : Objection to form. 4 A. Yes. 4 BY MR. LUTTJER: 5 . And I gather from reading 5 Q. What's your hope that you and she will get 6 that you were unhappy withil.fi et n t ought 6 married and have a family? 7 may she should go someplace other than your 7 A. Yes, one day. 8 apartment? 8 Q. Okay. Do you wan o have kids? 9 A. Yes. 9 A. Yes. 10 Q. And it appeared from 10 Q. You guys have talked about that? 11 that she had a different idea? 11 A. Yes. 12 A. Yes. 12 Q. Something she wan to do? 13 Q. She was a little more physical about 13 A. Yes. 14 wanting to stay at the apartment? 14 Q. You're happy at your business? 15 A. Yes. 15 A. Yes. 16 Q. And did you and her go back to the 16 Q. Does she do a little bit of work at your 17 counselor after that incident? 17 business? 18 A. Yes. 18 A. She helps me. 19 Q. How Ion was it — I know th took her to 19 Q. And do you know wltat her plans are? 20 ■ for a When s 20 A. She, I think she wants to get her and 21 did she come back and move in with you 21 mow forward from there. 22 A. No. 22 Q. She wants to t ill? 23 Q. How long were you and she apart so to 23 A. Yes. 24 speak? 24 Q. And you're going to upport her in trying 25 A. Couple of weeks. 25 to do that? 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthla hopkins Electronically signed by cynthia hooking Electronically signed by cynthka hooking IScle078e7-f430-460a-bb09-b036b310829d EFTA00724019 Page 34 Page 1 A. Yes. 1 Q. Mentally does she seem okay? 2 Q. You think that's a good thing? 2 A. Yes. 3 A. Yes. 3 Q. Do you know of any defect that she has at 4 Q. Does she have your complete support in 4 all? 5 doing whatever she wants to do? 5 A. No. 6 A. Yes. 6 Q. When was the last time you and she went to 7 Q. Okay. What has she ever told you about 7 see this counselor? 8 Jeffrey Epstein or her involvement with him? 8 A. She goes. I haven't been. I haven't been 9 A. What has she told me? 9 able to make it up there. 10 Q. Yep. 10 Q. When was the last time you went? A. Not, not that much. !mean, l have read a lot 11 A. Before Christmas I think. 12 of it online, what happened and what was going on and 12 Q. Okay. I took her deposition this morning 13 stuffhe was doing. And we really, really didn't 13 and she said that since November, which is the last 14 discuss it too much besides what I saw online. 14 time the therapist had a record ofher goi ' 15 Q. Does it really matter to you to find out 15 been oir v:dwhen she was driving from 16 the particulars? 16 down went by his office and went in to look 17 A. Yes, it mattered. 17 at his aquarium. 18 Q. Did she tell you for what period of time 18 A. Okay. 19 she was interacting with Mr. Epstein? 19 Q. Do you know ofany visits other than that? 20 A. I just know it was when she was underage. 20 A. No. I mean, I don't, sometimes I don't even 21 Q. Did you know that she continuing to go 21 know she goes, you know, because I am real busy at work 22 after she was 18? 22 and she's busy, you know. 23 A. Huh? 23 Q. Do you pay for when she goes or does she 24 Q. Did you know she continued to go after she 24 pay? 25 was 18? 25 A. No, she pays. Page 35 Page 37 1 A. No. 1 Q. Okay. 2 Q. Has she ever mentioned to you in any way 2 A. I mean, I have paid before„ you know. 3 Mr. Epstein in any conversation? 3 Q. Were you ever in any session with her with 4 A. Just when she had to go to her, to go to court 4 this counselor where Jeffrey Epstein's name ever 5 and just deal with her lawyers and her deposition she 5 came up? 6 has to go to, stuff like that. 6 A. She might have mentioned like her — she might 7 Q. Like today? 7 have mentioned something but I wasn't in there for all 8 A. Earlier this morning and last night. 8 the details. 9 Q. Her lawyer is — is Mr. Mennelstein her 9 Q. You have been dating now fora year and a 10 lawyer? 10 half or so? 11 A. 'guess. 11 A. Uh-huh. 12 Q. Okay. And what does she just tell you 12 Q. When I asked you earlier if there was 13 she's got to go take a depo and that's the substance 13 anything about her past that you wanted to know you 14 of the conversation? 14 said a couple of different things in response. One 15 A. Pretty much, yeah. She said she had to go in 15 time you said, yeah, you would want to know. 16 one time, one more time. 16 A. Yeah. 17 Q. Okay. Have you ever been out with her 17 Q. What is it about her past that you would 18 anywhere in public and not when there is drinking 18 want to know? 19 going on but seen anything unusual about her, her 19 A. About her past? One day I would like to sit 20 having any kind of physical problems or reactions or 20 down with her and talk to her about everything, you 21 anything? 21 know, that went on with her. 22 A. No. 22 Q. Her, specifically her and Epstein? 23 Q. Do you know of any physical problems that 23 A. Yeah. 24 she has? 24 you know a guy by the name of 25 A. No. 25 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins eck078c7-1430-4b0a-bb09-b035b310829d EFTA00724020 Page 38 Page 40 1 A. Yes. 1 want to change about her? 2 Q. How much do you know about him? 2 A. No. 3 A. Not much. I just know she dated him. 3 Q. Have you met her parents? 4 Q. Did she ever indicate to 1 • s 4 A. Yes. 5 herself, had been a victim o 5 Q. Where did ms? 6 1 t ebody has committed acts of 6 A. At one of hi nd when they come 7 her? 7 in town to visit. 8 A. Huh? No. 8 Q. Do they come over to your place? 9 Q. Did she ever mention to this counselor any 9 A. Yes. 10 of that? 10 Q. Get along well with them? 11 A. I don't recall. I can't remember if she did. 11 A. Yes. 12 I just know she dated him and that's pretty much it. I 12 Q. And she's been to your parents? 13 didn't really get into all the details of them. 13 A. Yes. 14 Q. Did you ever look him up online? 14 Q. And they get along well with her? 15 A. Have 1? 15 A. Yes. 16 Q. Yes. Yes. 16 Q. When was the — what is the most amount of 17 A. Yes. 17 time you spend with Jane Doe No. 7? 18 Q. What did you fmd out about him? 18 A. Randomly, rarely. 19 A. Piece of crap. I don't know. He's just — I 19 Q. I mean does she, for example, does she 20 saw ifs like he got arrested and stuff. Just curious. 20 have her girlfriends come over and they are at home 21 Q. If you-all live together, you-all sleep in 21 when you get home and stufflike that? 22 the same bed? 22 A. Sometimes. We normally do everything 23 A. Yes. 23 together. 24 Q. Do you have any problems, sleep problems 24 Q. So, do you work six days a week? 25 going to bed at night? 25 A. Sometimes on Saturdays. Normally five. Page 39 Page 41 A. What? 1 Q. Okay. And what are your recreational 2 Q. Do you have any sleep problems? Are you 2 pursuits? You're outdoors type people? 3 one of those guys that goes to bed and gets to sleep 3 A. Fishing, boating. diving, surfing. 4 right way? 4 Q. And does, does Jane Doe No. 7 ever go 5 A. Sometimes I have problems sleeping. But most 5 along with you on those things? 6 likely when I'm out, I'm out. I work. 1work hard, 6 A. She has been on the boat a couple times or one 7 come home, eat. Sometimes I pass out. Sometimes I stay 7 time I think. 8 up late. 8 Q. And what kind of have you and Jane Doe 9 Q. What are your observations about her sleep 9 No. 4 taken vacations together? 10 habits? 10 A. Yes. 11 A. Her sleep habits are pretty good. 11 Q. And where, what kind of places have you 12 Q. Is your sexual relationship satisfactory 12 gone? nt to the and the 13 14 15 to you? A. Yes. Q. Has she indicated to you that your sexual 13 14 15 WaQ. Have a good time? 16 relationships are satisfactory to her? 16 A. Yes. 17 A. Yes. She says, yes. 17 Q. Have a fun time when you're on vacation 18 Q. Any complaints from her? 18 when you go? 19 A. No. 19 A. Yes. 20 Q. That is I say any complaints, I mean any 20 Q. Does she make you happy? 21 complaints about you or any complaints about her? 21 A. Jane Doe No. 4? 22 A. No. 22 Q. Yes. 23 Q. Voiced by her? 23 A. Yes. 24 A. No. 24 Q. And as far as you can tell, you make her 25 Q. Is there anything about her that you would 25 ha py? 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c74430-4b0a-bb09-1D035b310829c1 EFTA00724021 Page 42 Page 44 1 A. Yes. 1 found her sitting in the corner crying 2 Q. Has she ever given you a list of 2 uncontrollably or something like that? 3 complaints about you? 3 A. She's been upset, you know, like after her 4 A. No. 4 seeing the counselor and stuff like that. 5 Q. Okay. Did she tell you she loves you? 5 Q. Okay. And if she goes to see the 6 A. Yes. 6 counselor, she might come back upset for a while? 7 Q. You tell her you love her? 7 A. Yes. 8 A. Yes. 8 Q. And then she is fine the next day? 9 Q. Has she ever complained to you that she's 9 A. Somewhat, that I could see. 10 had any kind of physical problems during the day? 10 Q. Does she ever tell you what she was upset 11 A. No. 11 about after corning back from the counselor? 12 Q. Ever complain about flashbacks or anything 12 A. Not in details, just discussing her past. 13 like that? 13 Q. When you say discussing her past -- 14 A. No. 14 A. Jeffrey. 15 Q. Ever complain about an inability to get to 15 Q. Is that generally what she says is 16 sleep? 16 discussing her past? 17 A. No. 17 A. Yes. 18 Q. What, if anything, do you know about any 18 Q. Does she define whether it's necessarily 19 drug usage in the past by her? 19 limited j • r %whether it includes 20 A. No, none at all. 20 things li and a few other things? 21 Q. Do you ' the name or a woman 21 A. Just Epstein. 22 by the name o 22 Q. When did you first find out she was 23 A. Yes. 23 bringing a lawsuit against Mr. Epstein? 24 Q. And have you met her? 24 A. I can't remember. 25 A. Yes. 25 Q. Was it early on in your relationship? Page 43 Page 45 1 Q. Where have you met her? 1 A. Probably halfway or something. 2 A. I think we, when we went out one night. Jane 2 Q. Do you know who else knows that she is a 3 Doe No. 4 introduced me to her. We ran into her that 3 Plaintiff bringing a lawsuit against Mr. Epstein? 4 was it. 4 A. No. Her family, that's it. 5 Q. So, you met her one time? 5 Q. And she's never had any discussion with 6 A. Yes. 6 you about Jeff Epstein? 7 Q. So, have you ever observed anything that 7 A. Just not in detail about what not much. 8 appears to be any kind of problem with Jane Doe No. a Q. Okay. If she's does, will you just tell 4? 9 her, forgot about it, don't worry about it? 10 A. Have I ever observed — 10 A. !just told her its not her fault and, you 11 MR. MERMELSTEIN: Objection to form. 11 know, pretty much what you said. I mean, can't dwell on 12 MR. LUTHER: Yeah. Anything you thought 12 it, you know, talk about it and let it out. 13 was a problem. 13 MR. LUTTIER: I don't have any other 14 MR MERMELSTEIN: You can answer if you 14 questions. 15 understand the question. 15 MR. MERMELSTEDI: I don't have any either. 16 THE WITNESS: Have I ever observed 16 THE WITNESS: That's it? 17 anything that what? 17 MR. LUTTIER. Yeah. 18 MR. LUTHER: -- you thought was a problem 18 THE COURT REPORTER: Do you want to order 19 with Jane Doe No. 4. 19 this? 20 THE WITNESS: That I thought was a 20 MR. LUITIER: Yes. 21 problem? 21. THE COURT REPORTER: Would you like a 22 MR. LUTHER Yeah. 22 copy? 23 THE WITNESS: No. 23 MR. MERMELSTEIN: Yes, I will get a copy. 24 BY MR. LUTTIER: 24 Thanks. Okay. 25 For instance, you never come home and 25 (Witness excused.) 12 (Pages 42 to 45) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b035b310829d EFTA00724022 Page 46 1 (Deposition was concluded.) 1 CERTIFICATE 2 THE STATE OF FLORIDA 2 3 COUNTY OF PALM BEACH 3 1 5 I, Crank Hockina Repaired Einflusional 4 Reporter, F/Drida Professional Reporter, sod Notay 5 6 eiblic In and fa the Stile of Florida at huge, do hereby certify Elitism authorized so arid did 6 7 report said deposition in stonMypo; and that the 7 foregoing rages axe a true and coned transaiption a of ray shcnthand notes of said deposition 8 9 I fUrther ce, that said deposition me 9 taken at dre lime and pace bereinabow ca bib 10 and that the taking of said dopositom was commenced 10 and completed as here/whose set at. 11 II I WS certify that I am not attorney or 12 12 camel of any of the panics, our an I a relative 13 or employee of any attorney or counsel of pany 13 connected with the action nor am I financially 14 thurestol in the action 15 14 The foregoing certificationof des ttartocript 16 15 does not only to any reproduction of the same by 17 my mean unless under the direct control andsx 16 direction of the tangelo; repeater. 18 17 Dated this and day of Febnuuy, 2010 19 18 19 20 20 21 22 21 22 4a 4g,si, *AS Hopkins. RP& ER 23 Johli123I 23 24 24 25 25 Page 47 1 2 CERTIFICATE OF OATH THE STATE OF FLORIDA 1 2 DATE TO: distiob STUART 11231 TEIN, ESQUIRE. 3 COUNTY OF PALM BEACH 3 1.*F ENot NORM= RA 4 12205 Biscayne Boulovad a Suite 2218 5 Mani, Florida 33160 6 authority, certify that Di RE: JaneDoc No 2 vs ;effigy Epstein 7 personally appeared before me and 6 Et was duly sworn on e 12th day of February, CASE NO.: 08c/40119-MARRA/JOHNSON 9 2010. Please Se maim that on Friday. the 17th of 10 Fetroary, 2010, you pro yotr deposition io the 11. Dated this 22nd day of February, 2010. atommethrod monor. At duo tient you did not 9 waive signature. It is now lithetSaly Marra sign 12 yew dopottiort 13 10 Math call ow other at the telowthrted 14 Wu toothed& an acominoment taween Mohan 11 of 9.00 am and 4:30 pm, Monday through Friday, 15' at the Esgoire office located rinumi you. Orpikizn-: 44/0As If you!. not nod mil tiger the rkposIdat within snsionable time, the original. which bit 16 13 oath born for aided to the adoring wormy, may Cynthia Hopkins, RPR. FPR be filed with thirChnk elthe Comet If you widi 17 Notary Public State of Florida 11 ionise yaw groefl sign yew ant in the Hank m die bathe of No lest, and mum it to is My Commission Expires: February 25,2011 15 18 My Commission No.: DD 643788 Very truly sours, 19 16 17 Job #1231 18 Cynthia Hopkins, ReR, FPR 20 19 20 1 de hereby wren my simmers 21. 21 22 22 23 23 trilia wa sangt twicLutda, Esquire Swan Mennehiem Esquire 24 24 No copy 25 25 13 (Pages 46 to 49) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cyntHa hopkins Electronically signed by cynttits hopkins Electronically signed by Cynthia hopkins 6dc078c74430-4b0a-bb094)035b310829d EFTA00724023 Page 50 CERTIFICATE 2 - 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are true and correct to the best of B my knowledge and belief, with the exception of any 9 corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2010. 14 15 16 17 18 19 20 Job #1231 21 22 23 24 25 Page 51 ERRATA SHEET INRE JANEDOENO 2 VS JEFFREY EPSTEIN CR: CyrAia HopE DEPOSMON OF: TAKEN. February I , lu 4 J06 NO.:1231 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGEiI LINEI CHANGE REASON 9 10 11 12 13 14 15 16 17 Pk= Award the original srgned errata sheet so this office so the copra nay bet/Mauled to ari le patties 19 Under malty ofpeijmy. I declare that I have read my deposition and that it is nue and correct 20 stbject to nny changes in form or substanos entered here 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 -waSINIIMIlr=====1111INII 14 ( Pages 50 to 51) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b0351/310829d EFTA00724024