EFTA01076720

Page 397, UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME III OF III 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. 3 Tuesday, April 6, 2010 2:07 - 5:07 p.m. 250 Australian Avenue Suite 150 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1577 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hooking (601 $d47f016-be69-47a2.9d44-6a177536c37o EFTA01076720 EFTA01076721 Page 394 Page 396 1 APPEARANCES: 1 CONTINUED PROCEEDINGS 2 On behalf of the Plaintiff: 2 3 STUART S. MERMELSTEDI, ESQUIRE MERMEISTEIN & HOROWITZ, PA. 3 THE VIDEOGRAPHER: This is the 6th day of 4 18205 Biscayne Bouleved 4 April 2010. The time is approximately 2:07 Suite 2218 5 p.m. 'Ibis is the videotaped deposition of 5 6 Jane Doe No. 3 in the matter ofJane Doe versus 6 E-mail: 7 Jeffrey Epstein. 7 On behalf o tieD t 8 This deposition is being held at 250 South 9 ROBERT D. CR1TTON,HL, ESQUIRE 9 Australian Avenue, West Palm Beach, Florida. BURMAN, CRITTON, L1JTITER & COLEMAN, LIP 9 303 Banyan Boulevard 10 My name is Daniel Downey. Iin the videographcr Suite 400 11 representing Visual Evidence. Incorporated. 10 West 'da 33401 12 Will the attorneys please announce their 11 Phone: E-mail:. 13 appearances for the record? 12 14 MR. MERMELSTEIN: • Sttiart Memielstein for 13 ALSO PRESENT: 15 the Plaintiff, Jane Doe No. 3. 14 16 MR. CRITTON: Bob Critton for Daniel Downey, Videographer 15 Visual Evidence, incorporated 17 Jeffrey Epstein. 16 18. 17 19 (JANE DOE NO. 3), 18 19 20 Having been first duly sworn or affirmed, was 20 21 examined and testified as follows: 21 22 THE WITNESS: Yes. 22 23. DIRECT EXAMINATION 23 24 24 BY MR CRITTON: 25 25 Q. Afternoon, Ms. No. 3. Page 395 Page 397 1 1 A. Hello. 2 3 INDEX 2 Q. Have you done anything to prepare for your 3 deposition today; that is, have you looked at 4 anything? EXAMINATION DIRECT CROSS REDIRECT 5 A. Yes. JANE DOE NO. 3 6 Q. Tell me what you looked at. a 7 A. My transcript. BY MR. CPSITON 396 8 Q. From the first session on February 19th? 9 9 A. Yes. 10 11 10 Q. Did it appear to be accurate to you; that 12 11 is, the testimony that you gave was accurate? 13 EXHIBITS 12 A. Yes; 14 15 13 MR. MERMELSTEIN: Objection to form. 16 EXHIBIT DESCRIPTION PAGE 14 BY MR. CRITTON: 17• 15 Q. Have you spoken with anyone other than DEFENDANT'S EX. 4 PLAINTIFFS AMENDED 426 . 16 your attorneys? 19 SUPPLEMENTAL ANSWERS TO INTERROGATORIES 17 Same kind of rules. If I ask you a 19 DEFENDANTS EX. 5 PLANTUFS 427 18 question, have you spoken with anyone, I am not — SUPPLEMENTAL ANSWERS TO 19 I'm not allowed to ask questions about discussions 20 INTERROGATORIES DEFENDANT'S EX.'6 PLAIITI1FFS ANSWERS 528 20 you've had with your attorneys, so I am excluding 21 TO DEFENDANTS FIRST 21 your attorneys and anyone who works in their office. ATIERROGATORIES 22 Okay? 22 23 A. Okay. 23 24 24 Q. Have you discussed your deposition with 25 25 anyone -- 2 (Pages 394 to 397) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. •a Electronically signed by cynthia hopkIns (601 Electronically signed by cynthla hopkIns (601 Electronically signed by cynthia hopkIns (601 8d471015-be89-47a2.9d44.6a177636c37e EFTA01076722 Page 398 Page 400 1 A. Yes. 1 Q. Okay. And that's the extent of what she 2 Q. .'-- since you gave it? 2 said about the deposition to you? 3 With whom did you discuss your deposition? 3 A. She asked me questions, what could happen. 4 A. Jane Doe No. 4 and Jane Doe No. 7. 4 Q. What do you mean? 5 Q. Have you seen Jane Doe No. 4 and/or Jane 5 A. Like what, what could take place. 6 Doe No.7 since February 19111ot2010 -- 6 Q. Oh, at her deposition? 7 A. Yes. 7 A. At a deposition. 8 Q. — your deposition? 8 Q. Oh, when, when you, when you were talking 9 On how many nrrAsions? Now, I'm talking 9 about discussing the deposition, were you talking 10 about seen them as distinct from spoken with them. 10 about your deposition with Jane Doe No. 7 or Jane 11 A. One. 11 Doe No. 7 was talking about the deposition she had 12 Q. Where, where did you-all meet? 12 given? 13 A I saw Jane Doe No. 7 only. 13 A In general. 14 Q. Saw Jane Doe No. 7. All right. And wheri 14 Q. Okay. So, she had, she just said she was 15 did you see Jane Doe No. 7? 15 nervous, but you don't know whether she had given 16 A. My birthday party. 16 the deposition and was nervous or was about to give 17 Q. All right. Where, where was with your 17 the deposition? 18 birthday party? 18 A_ Correct. 19 A. At Noche. 19 Q. All right. I understand now. 20 Q. That's". that's up in The Gardens 20 Did you tell her what had happened at your 21 near Soverel 21 deposition? 22 A. Yes. 22 A No. 23 Q. And Jane Doe No. 7 came to your party? 23 Q. So, just so the jury knows, you had given 24 A. Yes. 24 a deposition and you didn't tell her one thing about 25 Q. . How many people did you invite to your 25 the deposition that went on? Page 399 Page 401 1 party/ 1 MR. MERMELSTEIN: Objection to form. 2 A Ten. 2 BY MR. CRITTON: 3 Q. Did anyone else come who was, who is a 3 Q. Is that what you're telling us? 4 Plaintiff against Mr. Epstein? 4 A. Exactly. 5 A. No. 5 Q. All right. How long, how long — what 6 Q. Was anyone there other than Jane Doe No. 7 6 time did your party start and what time did it end? 7 who knew you were a Plaintiff? 7 A. We had dinner with my family first, and then 8 A. No. 8 we went to the club about 10:30,11:00, somewhere around 9 Q And let's see. You were born on 9 there. 10 M, so it was about a little over a month ago. 10 Q. And what time did the party shut down? 11 Had Jane Doe No. 7 given her deposition? 11 A. I left at 2:30, 3:00, around there. 12 A. I don't know. 12 Q. And did you go home? 13 Q. Did she talk about her deposition at all? 13 A. Yet 14. . A. Yes. 14 Did you go home with anyone? 15 Q. Okay. And what did she say about her 15 A. With my girlfriends. 16 deposition? 16 Q. And who's that? 17 A. She was nervous. 17 A 18 Q. Okay. She liked me? 18 Q. What' s last name? 19 A. I, I don't know. 19 20 MR. MERMELSTEIN: Objection to forth. 20 Q. A 21 THE WITNESS: I don't know. 21 A. Yes. 22 BY MR. CRITTON: 22 Q. And is the ono, I think 23 Q.' Just thafs all she said, she was nervous 23 you told tote that you had told her that you had been 24 during the deposition? 24 at Epstein's house? 25 A Yes. 25 A. Yes. 3. (Pages 398 to 401) PROSE COURT REPORTING AGENCY,. INC.:- Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8t4171015-be89-47a2-91144-6at77536c37e EFTA01076723 Page 402 Page 404 1 . Q. Does know that you were at 1 Doe No. 7 tell you what she's doing right now 2 .Mr. Epstein's house? 2 • work-wise, for fun, or is she still in school? 3 A. No. 3 . A. I know she's still in school. 4• . Q. She doesn't And she doesn't know you're 4 Q. . And do you know what she's going to be, 5 a Plaintiff in this lawsuit? 5 what she wants to be? 6 • A. No. 6 A. I think business, something to do with 7 Q. Let me just stay with the other 7 business. 8 individuals, as Question 11 in your second set of 8 Q. Did she tell you whether she was dating 9 interrogatories that was sent to you, you listed 9 anyone? • 10 people who were your five closest friends, and you 10 .. A. No. 11 apparently only named four -- 11 Q. How about — and then you said — have you 12. . A. Yes. 12 spoken with Jane Doe No. 7•-- other than seeing her 13 Q. — Prom to 201 13 the one night over the last month and a halt have . 14 ne was 14 you continued to speak with her regularly? 15 (phonetic) 15 A. Prior to spring break for her college. 16 16 Q. Which was when? 17 A. 17 A. Two weeks ago, somewhere. 18 Q Oh, You've known her since 18 Q. Where was she headed to? 19 high school? 19 A. ICey West, Miami. . 20 A. Since Wore high school. 20 Q. And you haven't talked to her since then? 21 Q. A long time? 21 A. No. 22 A. Yes. 22 Q. Other than the one time you saw her and 23 Q. And she doesn't — does she know you're a 23 the other conversations that you had, have you 24 Plaintiff in this lawsuit? 24 discussed the cases at all? 25 A. No. 25 A. No. Page 403 Page at 1 Q. Does she know — then, obviously, she 1 Q. Jane Doe No. 4, when did you speak with 2 wouldn't -- well, does she know that you ever went 2 Jane Doe No. 4, you haven't seen since 3 to Mr. Epstein's home — • 3 February 19th, correct? 4 A. No. 4 A. Correct. 5 Q. — on one occasion — 5 Q. But you've spoken with her? 6 A. No. 6 A. Yes. Q. of the four occasions that you 7 Q. Because you speak with her regularly? 8 described?. 8 A. No. 9 And M, she's still one of your best 9 Q: How many occasions have you spoken with 10 friends? 10 her? - 11 A. Yes. 11 A. Once. 12 Q. Did you — have you discussed with her the 12 Q. Okay. And what was the occasion; did she 13 deposition you gave? 13 call you or did you call her? 14 A. No. 14 A. I called her. 15 Q. And does she — she knows you went to 15 Q. About? 16 Epstein's? 16 A. Birthday. 17 A. ' Yes. 17 Q. Just to say happy birthday? 18 Q. All right. Any guys at the party or 18 A. No, my birthday. So, l invited her to my 19 a girl patty? 19 party. 20 A. There was guys at the club. 20 Q. Oh, and she said what? 21 Q. Understand that, but they came to your 21 A. Yeah. 22 party? 22 Q. But she didn't show? 23 A. Yeah. 23 A. Correct 24 Q. Separate and apart from having seen Jane 24 Q. Do you know why she didn't show? 25 Doe No. 7 -- well let me ask you this: Did Jane 25 A. No. l.e....S.Niaafted.nefeJala 4 (Pages 402 to 405) PROSE COURT 'REPORTING' AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-1)039-47a2-9d44-6a177536c37o EFTA01076724 Page 406 Page 408 i. Q. Did you ever talk to her about your 1 2 deposition in any way? 2 A. Can you rc — can you — 3 A. No. 3 Q. Sure. 4 Q. -And ill understood your testimony, the 4 A. . methin more sim le. 5 only thing you looked at is your transcript in 5 6 preparation for today? A Correct 8 Q. I see in your answers to interrogatories, 9 which is consistent with testimony, do you 9 A. Yes. 10. still work for the 10 Q. Okay. So putting aside those individuals, 11 A. 11 have you had a chance to look at your, at least the 12 • 12 physicians, psychiatrists, psychologists, et cetera. 13 that you've disclosed that you had seen. 14 A. Yes. 14 And my question to you is, is: Have them 15 Q. And you describe your, yourself now as the 15 been any psychiatrists, psychologists, therapists 16 lead hostess? 16 that you've seen for solely issues relating to your 17 A. Yes. 17 visit to pstein's home? 18 Q. Okay. And I think you told us you were 19 the maitre di. Same thing? 20 A. Yes. 21 Q. And you're working 40 hours a week? 22 A. No. 22 -- well, let me 23 Q. How many hours a week are you working now? 23 strike 24 A. liveries. 24 , didn't disclose 25 Q. What's your, your average? 25 anything about Epstein, correct? Page 407 Page 409 1 1 A. Thirty-five. 1 A. I don't know. 2 Q. Are you considered a MI-time employee? 2 Q. All right. We'll, we'll get 3 A. Yes. 3 4 Q. And did you tell me you may have told I 5 'me, are you entitled — do you get benefits, health to your visit to Mr. Epstein's home? 6 benefits? A. No. 7 A. Yes. Okay. In fact 3 Q. And have you used your health benefits at 9 all? is that correct? o A. 13 A. Yes. 11 Q. All right. If I separate — and then let 12 me just focus this, is you testified at your last 13 deposition that you went to Mr. Epstein's house on 14 four occasions, correct? 15 A. Yes. 16 Q. Okay. One time you went upstairs and gave 17 Mr. Epstein a massage. And I'm not going to go 18 through the details. We've covered that on the last 19 deposition. But one time you went upstairs and gave 20 him a massage and you described what occurred, 21 correct? 22 A. Yes. 23 Q. The second time you took, I think, Jane 24 Doe No. 2, but you stayed downstairs — 25 A. Yes. • • 1.5.0..\)eu.-44.040.• 5 (Pages 406 to 409) PROSE COURT REPORTING AGENCY, INC.. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471016-be89-4782-9d44-6af77636c37e EFTA01076725 Page 410 Page 412 1 Q. correct? know how to describe it. Just scared. I was scared. .2 The third time you took I.L., but you 2 Q. Okay. You don't know what you were scared 3 stayed downstairs. 3 of or why you were scared, but you were scared — 4 A. Yes. 4 A. !just got a feeling inside — 5 Q. And the fourth time you went, you — to Q. La me, let me finish the question. If I 6 • Mr. Epstein's house; you took Jane Doe No. 4 at her .6 understand your answer, you were scared; you were 7 request. :7 fear, fearful? 8 A. Yes. g A. Uh-huh. Yes. 9 Q. Okay. So if I refer to a one-time visit 9 Q. But you don't know why on the second 10 in my questioning to you, a one-time visit to 10 occasion? 11 Mr. Epstein's house that would be the one time that 11 A. It's a combination of things. 12 you went upstairs. Okay? • 12 ' Q. What things? 13 A. Okay. . 13 A. Not knowing the outcome, what's going on, just 14 Q. Because if I understand your testimony, 14 constant thoughts. 15 you're not alleging that anything bad happened when • 15 Q. Of what? Constant thoughts of what? • 16 you went back, or bad or inappropriate or traumatic 16 A. Many things; him, the house, the property, 17 at any time after the first visit, correct? 17 people, people that you know, staff. 18 A. No. 18 Q. But no one had ever threatened you before 19 Q. Okay. Well, what do you allege was 19 at the house, had they? 20 traumatic about your taking Jane Doe No. 2 to 20 A. What do you mean? 21. Mr. Epstein's home on the second occasion? What 21 Q. No one had threatened you; that is, either 22 happened to you that you consider traumatic? 22 verbally or physically threatened you, had they? 23 A. Many things. 23 A. A threat could be all different sorts of 24 Q. Name one. 24 things to me. 25 A. Anxiety. 25 Q. Well, had anyone physically assaulted you Page 411 Page 413 1 Q. Okay. And why, because you took a good 1 at the house? 2 friend to Mr. Epstein's house to suffer, as you've . A. Yes. 3 described it, the same emotional trauma, 3 Q. Okay. Who? 4 embarrassment, humiliation that you experienced on 4; • A. Epstein. 5 your first occasion? 5 Q. So, you were physically assaulted on — 6 MR. MERMELSTEIN: Objection to form. 6 and were you struck or touched? 7 THE WITNESS: You lost me there. 7 A. Touched. 8 :. BY MR. CRITTON: 8 • Q. You were not physically struck in any way? 9 Q. Okay. Is, is your emotional — well, let 9 A. Not hit. 10 me strike that • . 10 MR. STEIN: Objection to form. 11 You said on — as a result of having been 11 BY MR. CRITTON: 12 at Mr. Epstein's house on a second occasion when you 12 Q. I'm cony? 13 didn't I think you didn't even see Mr. Epstein on 13 A. Not hit 14 the second occasion, did you? 14 Q. So, you went back a — to Mr. Epstein's . 15 A. No. H • house on the second time because you thought you . 16 Q. Okay. So, but you say you had anxiety as 16 might be physically assaulted?. 17 a result of going there? 17 A. I didn't say that. 18. . A. Yes. 18 Q. Okay. Well, if you thought you were going 19 Q. Okay. And what caused the anxiety? 19 . to be physically assaulted, or you were so scared as 20 • A. I don't know. 20 - you've just described, or so fearful as you've just 21 Q. Anything else other than anxiety on the ' 21 described, why then did you return to Mr. Epstein's . 22 . • second occasion? 22. house on the second occasion? 23 A. Fearfulness. 23 . A. Because I was young and I was vulnerable and I 24 Q. Of what? 24 • wasn't thinking. • 25 A. Just scared of 'List I don't know, I don't 25 Q. Well, but you were anxious, scared, 6 (Pages 410 to 413) (561) .832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthla hopkins (601 8d47t016•bo69-47a2.9d44.6af77636c37e EFTA01076726 Page 414 Page 416 1 fearful and thought that you might be physically . 1 and I don't remember, did you say you went into the 2 assaulted, and you still went to Mr. Epstein's house 2 • house ofyou did not go in the house? 3 on a second occasion, comet? 3 A. I didn't physically — like, I was by the 4 . MR. MERMELSTEIN: Objection to form.. The 4 pool, beach area outside. 5 first deposition covered in great length her 5. Q At that time did you feel anxious or 6 thoughts and feelings in going back the second scared? time. Tin not sure why we're revisiting all of 7 A. Yes. a that. 8 Q. Did you feel fearful or potentially 9 MR. CRITTON: Well, this isn't a first or 9 physically threatened? 10 second deposition. it's a completion of the 10 A. Yes. 11 first, the first and only deposition and Tin 11 Q. Okay. why? 12 allowed under tbe, the record -- 12 A. Because we were there forayer), long time. 13 MR. MERMELSTEIN: I understand, but ifs 13 Q. Well, did you ever see anyone that day 14 asked and answered many times. 14 when you went to the house? 15 MR. CRITTON: Okay. Fine. 15 A. No. 16 BY MR. CRITTON: 16 Q. And when Jane Doe No.4 came down, was 17 Q. You can go ahead and answer it 17 there anything — and I think, I think you've 18 A. • What's the question? 18 already said so, and I don't want to belabor the 19 MR. CRITTON: Cindy, would you read it 19 point, but she didn't Say anything or — to you that 20 back, please? 20 would have suggested that anything inappropriate or 21 (The requested portion of the record was 21 bad had occurred, did she? 22 read by the reporter.) 22 MtMERMELSTEN: Objection to form. 23 THE WITNESS: Yes. 23 THE WITNESS: No. 24 BY MR. CRITTON: 24 BY MR. CRITTON: 25 Q. . And is it your testimony that you were 25 Q. Okay. Did her appearance appear other Page 415 Page traumatized by having been at Mr. Epstein's house on 1 than normal to you? Let me rephrase that question. 2 a second occasion even though you never saw him? 2 Did -- from your observations, did 3 A. Yes. 3 everything seem to be okay with her? 4 Q. On the third occasion you went to 4 MR. MERMELSTEIN: Objection to form. 5 Mr. Epstein's house, were you, as well, traumatized? 5 THE WITNESS: I guess. • A. Yes. 6 BY MR. CRITTON: Q. Were you anxious, scared, fearful and felt 7 Q. And that was the last time you went to 8 physically threatened as well? 8 Mr. Epstein's house, correct? 9 A. Anxious and scared, yeah. . A. Yes. 10 Q. But not -- but not fearful, nor did you -- 10 Q. Why didn't you ever go again? 11 A. All of the above. 11. A. I don't know: 12 Q. — feel physically threatened? 12. Q. Did anyone ever ask you to go again? 13, A.. All of the above. 13 A. I don't remember. 14. Q. But, so my question then is — 14 Q. Pardon? 15 MR. MERMELSTEIN: Let him finish the 15 A. I don't remember. 16 question: 16 Q. Have you had an occasion to speak with 17 BY MR. CRITTON: 17 or Jane Doe No:2 since your last deposition? 18 Q. • So my question is: Why then did you go 18. A. Yes. 19 back on.a third occasion? 19 Q. With whom did you speak? 20 MR. MERMELSTEIN: Objection, asked and 20 A. 21 answered. • 21 Q. And when did yousee her? 22 THE WITNESS: I don't know. 22 A. I never saw her. 23 BY Mk CRITTON: • 23 Q. All right. You spoke with her, and you 24 Q. On the fourth occasion that you took Jane 24 did not see her, correct? • 25 Doe No. 4, or you drove Jane Doe No. 4, did you 25 • A. Comet. 7 (Pages 414 to 417) PROSE. COURT REPORTING AGENCY, INC.' Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47fO15-be89.47a2-9d44.Saf77536c370 EFTA01076727 Page 418 Page 420 I 1 Q. On how many occasions have you spoken with 1 A. January. 2 her since 2• Q. Did she ever mention to you ever about 3 A. One. 3 being a Plaintiff, you being a Plaintiff in a 4 Q. -- February 19th, 2010, which was the 4 lawsuit against Mr. Epstein? 5 start of your deposition? 5 A. She asked me. • . 6 • A. One. 6 Q. And you told her? 7 Q. Did she can you or did you call her? 7 A. No. 8 A. She called me. 8 Q. Okay. So, why would she — and again, 9 Q. Subject of the conversation? 9 when she said out of the blue, she called you after 10 A. That she heard I had settled. 10 your first deposition, the start of your deposition 11 Q. Did she tell you who she heard that from? 11 and said, I heard you settled. And did you 12 A. No. 12 specifically ask her, and say where did you ever. 13 Q. And how did she know you were even a 13 hear I was even a Plaintiff or I had even filed a 14 Plaintiff? 14 suit against Mr. Epstein? 15 A. Good question. 15 MR. MERMELSTEIN: Objection, form. 16 Q. Did you ask her? 16 Assumes facts. You don't have to file a suit 17 A. I asked. Igo: Where did you hear this from? 17 in order to settle. 18 She goes: Oh, I was contacted by someone. 18 THE WITNESS: She -- what I just said to 19 Q. Did, did you ask her whether she was a 19 you prior, she heard that I had settled. AM I 20 Plaintiff in the case? 20 go, no, I don't know what you're talking about. 21 A. No. 21 BY MR, CRITTON: 22 Q. Okay. Do you know whether she is? 22 Q. And then she changed the topic? 23 A. No. 23 A. No. She kept asking, she's like, you don't 24 Q. She has a — and she didn't indicate one 24 have a lawsuit? No. 25 way or the other whether she was a Plaintiff? 25 Q. So she pushed the envelope; she pushed you Page 419 Page 421 1 A. Correct. I to find out whether you had a lawsuit against 2 Q. So, she calls you out of the blue. When 2 Mr. Epstein? 3 was the last time you had heard from her? 3 A. Yeah. 4 A. Prior — around her birthday which is in 4 Q. And you kept telling her no? 5 February. A. Correct 6 Q. Okay. So just before your deposition? 6 Q. Anybody else call you since your -- since 7 A. I don't know exactly when her birthday is. 7 the start ofyour last deposition, or the start of 8 Q. But sometime around her birthday you had 8 your deposition about you being a Plaintiffin a 9 spoken with her? 9 lawsuit? 10 A. Yes. 10 A. No. 11 Q. Topic? 11 Q. Do you know 12 A. Going to Tree's Wings. 12 A. Yes. 13 Q. Fm sorry? 13 Q. How do you know 14 A. Going to Tree's Wings. 14 A: School. 15 Q. Which is what? 15 Q. Friends with her? 16 A. Aber/restaurant. 16 A. No. 17 Q. She wanted you to come? 17 Q. And why nee You're saying that 18 A. Uh-huh. 18 emphatically. Is there a reason that you're not 19 Q. Yes? 19 friends with her? 20 A. Yes. Sorry. 20 A. I never heard good things about her. 21 Q. And did you go? 21 Q. From whom? 22 A. No. 22 A. People. 23 Q. All right. When's the last time you 23 Q. Who do you friends with? 24 ......jr saw her physically or in person? This is 24 A. She Went to I think She didnt 25 25 ,„...s.....2121hinL to.my sch think she was hanging out a with 8 (Pages 418 to 4 21) (561)• 832-7500 • PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkIns (601 ed471015-be89-47a2-9444-6at77536c37e EFTA01076728 Page 422 Page 4.. and Jane Doe No. 7 at one point. you used it at all? 2. Q. Okay. Was she ever friends with Jane Doe 2 A. I went on there one time. 3 No. 4?, 3 Q. Okay. Did you put any information — did 4 •. :A.. I don't know. 4 you have to set up a profile? 5 Q. • And who told you anything bad about her? 5 A. That was already done. 6 A Just rumors. 6 Q. She had already done that for you? 7 Q. Okay. And what are the rumors? 7 A. Yes. 8 A. I donstimow. It was high school. 8 Q. And what, do you go on and was your 9 Q. So anybody can get a bad reputation in 9 picture on as well? 10 high school? 10 A. No. 11 A. Yeah. 11 Q. It was just some background information on 12 Q. Whether it's true or not, you have no 12 you? 13 idea? 13 A. Yes. 14 A. Correct. 14 Q. All right. Did you ever search the site 15 Q. All right. And did you say you had 15 at all, go on anyone else's site? 16 actually met her? 16 A. Yes. 17 A. Yeah. 17 Q. Did you see anybody you lilted? 18 Q. But you're not friends; you're just 18 A. No. 19 acquaintances? 19 Q. Computers, you have your own computer? 20 A. Not even that. 20 A. Yes. 21 Q. You just know who she is; she knows who 21 Q. Laptop? 22 you are? 22 A. Yes. • 23 A. Yes. 23 Q. What kind? 24 Q. You have an active Facebook? 24 A. Dell. 25 A. Yes. 25 Q. How long have you had it? Page 423 Page 425 Q. And you used to have MySpace,but that's 1 A. Since Christmas. 2 been canceled? 2 Q. And did you down — what did you have 3 A. Yes. 3 before that? 4 Q. The question was asked whether you're a 4 A. The Toshiba. number of any web site, dating web sites, and you 5 Q. Did you download — and how long had you 6 listed a fiend registered yourself for 6 had the Toshiba? 7 wealthymen.com. 7 A. Like my 19th birthday or 20th birthday. 8 A. Yes. 8 Q And before that, another laptop? • 9 . Q. Which of your good friends did that to 9 A. No, home, regular desktop. 10 you, for you? 10 Q When you got the Toshiba, that was a 11 Ltink it was. 11 laptop? 12 Q• M i? 12 A. Yes. 13 A. Yeah. 13 Q Did you download the infommtion that's on 14 Q. Okay. How did you find out that she had 14 your home computer onto that that was applicable to 15 done that? 15 you? 16 A. She told me. 16 A. No. 17 Q. And what did you say? 17 Q. Did your Toshiba, when you went from 18 A. Why would you do that? 18 Toshiba to Dell, did you download the information 19 Q. And she said? 19 from the Toshiba to the Dell? 20 A. Because you just separated from 20 A. No. 21 Q. But you've never used the site? 21 • Q. You started from scratch again? 22 A. No. 22 A. Yes. 23 Q. Never? 23 Q. 'And you run your My — Fm sorry, your 24 A. Not — no. Not like that, no. 24 Facebook from your Dell computer laptop? 25 Q. Well, excuse me: Never is never. Have 25 A. Yes. Lay 9 (Pages 422 to 425) (561) 832-7500 PROSE COURT'REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 6d471015-bei39-4732-9d44-6af77636c37e EFTA01076729 Page 426 Page 428 1 Q. Are you active on it? 1 THE WITNESS: Okay. 2. A. On Facebook? 2 MR. MERMELSTEIN: So, I guess there's — 3 Q. Yes, ma'am. 3 this, this is before this. • 4 A. l'es. 4 BY MR. CRITTON: 5: Q. Do You know ..? 5 Q. There's Jane Doe's 3's Supplemental 6. • • A. Who? 6 A11511/O'8 to Interrogatorieswhich are dated November 7 Q. A lady by the name of 7 . 13th, 2009. 8 A. No. 8 A. Yes. . Q. Do you know a person by the name of Jane 9 Q. Do you recognize — 10 Doe No. I1? 10 A. Yes. 11 A. Who? . 11 Q. — your answers to those interrogatories? 12 Q 'Jane Doe No. IL Jane Doe No. 12 - A. Yes.. 13. A. No. 13 Q. If you look at the very last page, you 14 MR. CRITTON: What's the next exhibit, No. 14 swore to the truth of the that is, the 15 4? 15 interrogatories were true and accurate on 16 THE COURT REPORTER: Yes. 16 November 6th of 2009. Do you see that? 17 (Defendant's Exhibit No. 4 was marked for 17 A. Yes. 18 identification.) 18 Q. And then you filed supplemental, these 19 BY MR. CRITTON: 19 supplemental answers, Exhibit 4, or your attorney 20 . Q. Let me show you Exhibit 4, if you want it. 20 sent them out on November 17th. 21 These are your Amended Supplemental Answers to 21 A. Mine says February. 22 Interrogatories. These, these were sent on 22 Q. Let me see what you've got. 23 February 17th, 2010, just prior to your deposition. 23 A. f have this one. 24 •• I don't see that you signed these or 24 Q Oops I'm sorry. 1 was !coking — no. Oh, 25 . executed these. So my question to you is, in 25 I'm got two. Your last page is February 17th, Page 427 Page 429 1 response to questions — well, first of all, in 1 2010? 2 response to -- start again. 2 A. On this one, on Exhibit 4. 3 Do you recognize Exhibit 4 — 3 MR. MERMELSTEIN: Well, that's not the 4 A. Yes. 4 certificate of service. That's the signature 5 Q. as being your answers to 5 on the attorney signature line. 6 interrogatories? 6 MR CRITFON: Okay. Well, look at your A. Yes. 7 certificate of service, and maybe we should 8 • Q. And the information that's provided in 8 clarify this. They were sent, faxed to me on 9 response to Questions 18,19,20, and 21, was that 9 February 17th,.2010. 10 true and accurate? 10 MR. MERMELSTEIN: Right. 11 . MR. MERIvIELSTEIN: Let me object to form. 11 MR. CRITTON: Okay. But you have a 1.2 • Let me ask: Have you read this? 12 certificate of service of November 17th, 2009. 13 .. THE WTINESS: Yeah. Give me a minute. 13 I'm going to assume that's incorrect. 14' BY MR. CRITTON: 14 MR. MERMELSTEIN: Yeah, particularly since 15 • Q. Next one is Exhibit 5, which are your 15 the fax legend on top — 16' • supplemental answers. 16 MR. CRITTON: That's what I'm saying. 17 MR. CRITTON: I will show those to you 17 • MR. MERMELSTEIN:. — shows it was 2/17. '10 first. 1$ MR. CRITTON: Okay. So, the 19 (Defendant's Exhibit No. 5 was marked for 19 certificate — 20 identification.) 20 MR. MERMELSTEIN:. That's — 21 MR. CRITTON: Five are the supplemental 21. • MR. CRITTON: — isjirst inaccurate. 22 ansWers to interrogatories. 22 MR. MERMELSTEIN: Right. 23 THE WITNESS: Are these the same? 23 BY MR. CRITTON: 24 MR. MERMELSTEIN: Amended supplemental. and 24 . Q. And the most important thing is, is these 25 then the supplemental. 25 appear to have been dated September -- I'm sorry, IMIIRIIIMWPFroK, b, ....- 1 C•A , W-femntedtbastra.rikiseuARes 10 (Pages 426 to 429) ( 561) . 8.32-7.509 PROSE COURT REPORTING AGENCY, INC. Electronically signed by eynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-be8947a2-9d44.6af77536c37o EFTA01076730 Page 430 Page 432 I February 17th, 2010. And those answers — are those 1 A. Yes. . . 2 answers; that is the amended supplemental answers to 2 Q. You list — in 2003 yoU list M, last 3 interrogatories, true and coned? 3 name unknown, correct? 4 A. Yes. 4 A. Yes. 5 Q. All right. And it appears that at least 5 Q•' And 6 Question 18 says, List separately the names, address 6 A. Yes. and phone numbers of all males including 7 Q. 8 Mr. Epstein excluding Mr. Epstein, with whom 8 correct? 9 you've had sexual activity since age ten by year. 9 A. Yes. 10 : Describe the activity, and I'm paraphrasing now, the 10 Q. Which of these individuals was the fit.: 1.1 date and whether you received money or 11 person that you had sexual intercourse with? 12 consideration. 12 A.' . The very first person? 13. On your ori nal answers; that is, Exhibit 13 Q. Correct 14 5, you listed correct? 14. • • A. !don't blow if you're 15' A. Yes. 15 looking at the right one. 16 Q. Okay. On the three months four months 16 Q. All ri t. Well I may have left his name 17 later, three months later you listed 17 •. off. So would have been the first 18 A. Yes. 18 person that you had sexual intercourse with? 19 Q. — correct? 19 A. Yes. 20 A. Because I didn't know exactly what the •20 Q. Okay. When was that in '03; that is, the. 21. question was in detail of. 21 beginning of '03, mid '03? 22 Q.. Okay. Do you remember getting the 22 A. Summer. 23 definitions with it? We sent definitions so that 23 Q. 'Oka . And was there any oral sex involved 24 you could understand exactly what the nature of the 24 with Mr rid yourself — 25 sexual activity was. 25 A. No. Page 431 Page 433 1 MR. MERMELSTEIN: Objection to form. 1. Q. Or strictly sexual intercourse? On how 2 THE WITNESS: Do I remember a definition? 2 many occasions? 3 BY MR. CRITTON: 3 A. One. 4 Q. Right. Do you remember receiving 4 Q. Is he someone you dated, or was this just 5 definitions along with it? 5. an event? 6 A. I don't remember. 6 A. No. I never was taken out on a proper date. 7 Q. All right. Is it your testimony that 7 Q. And where did it occur? 8 the — Exhibit 4 is the correct information 8' A. His house. 9. • A. Yes. .9 Q. Voltmtexily, consensual? 10 Q. — or the more correct information? 10 A. Yes. 11 A. Yes. 11 . Q. The next person after was 12 Q. All right. Let's sta y then with 12 . .whom? 13 Exhibit 4. The 13 A. M. 14 . That'syour husband? 14 Q. Sony:mein school, school friend? 15 A. Yes. 15 . . A. Yes. 16 Q. .Any — since the last deposition, or since 16. Q. Was a school friend? 11 Febniary 19th of 2010, any further chance of 17 • • A. No, he went to a different school. 18 reconciliation, or are you still going to move ahead 18 Q. How old was he? You — let's see, in 19. with the divorce? 19 . 2003, the Summer of 2003; you would have beer 20 '. A. I don't know. 20 A. I'm notiSwith Math. 21.. Q. . Okay. Then you talk about, and it appears 21 • Q. Well, — 2Z at least, your first sexual experiences were in the 22 A. So... 23 year 2003, correct? 23 Q. 24. A. ' Yes. 24 A. Okay. 25 Q. All_right. And youhs 25 Q. All right. And how fast — how soon after 11 (Pages 430. to 433) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be89-47a2-9d44-6077636c37e EFTA01076731 Page 434 1 did you have your relation, sexual 2 intercourse with him? 3 A. I don't know. 4* Q. A month later, a week later? A. I, I don't know. 5 A. I, I don't know. 5 Q. Had you for, for males before, had you 6 Q. Do you remember where it occurred? 6 ever taken any or all or part of your clothes off 7 A. His house. 7 fora male before on a date? Not necessarily, it 8 Q. Okay. Voluntarily, consensual? 8 doesn't haveto be a date, but when you were with a 9 A. Yes. 9 guy 10 Q. All right. You understood you had a 10 A. Have I ever taken my clothes off? 11 choice either to have sex with him or not under the 11 Q. No. Back in prior to 12 circumstances? . 12 had you ever been with a guy and you had taken all 13 A. Yes. 13 or a portion of your clothes oft? 14 Q. Strictly sexual intercourse, no oral sex? 14 A. No. 15 A. No, there was oral. 15 Q. Had you taken t on of 16 Q. Both ways? 16 your clothes off prior to 17 A' Yes. 17 A. No. 18 Q. Mr ..Third person in '03? 18 Q. Okay. was the first 19 A. 19 Did ou remove any of your clothes for 20 Q. And did n ve sexual, sexual 20 21 intercourse 21 A. Just my bottom. 22 A. No. 22 Q. Okay. And he digitally penetrated you 23 Q. And you say —you listed it as digital 23 with his hand? 24 penetration. 24 A. Yes. 25 A. Uh-huh. 25 Q. Or with his fingers Page 435 1 Q. Meaning he was using his hand? 1 A. Yes. 2 A. Yes. 2 Q. Voluntary, consensual? 3 Q. And that was the extent. Was there any 3 A Yes. 4 petting involved; that is, were you, were you, both 4 Q. And with regard to every -- well, I'll 5' of you undressed and then he digitally penetrated 5 come back to that. Did you touch him? 6 you? 6 A. Yes. 7 A. No. 7 Q. Okay. Did you touch his penis? 8 Q. Okay. Voluntary, consensual? 8 A: Yes. 9 A. . Yes. 9 Q. Did you masturbate him? 10 Q. 10 A No. 11 A. and • Were 11 Q. Okay. Did he ever climax? 12 prior to everyone I just named. I'm going to correct 12 A. Yes. 13 that. 13 Q. By himself? 14 Q. With S he would be, would . 14 A. Yes. 15 have been the first? 15 Q. All right. Did he do it himself in front 16. A. Yes. 16 of you? 17 Q. And did he take your — this you describe '17 A; Yes. 18 as digital penetration? 18 .Q. All right. And did you? 19 A. Yeah. 19 A. No. 20 Q. Did he remove your underwear? 20 Q. When I say you, did you climax? •' 21 A. Not fully. 21 A. No. 22. Q. He just reached within? 22 Q. All right. With Joseph, a? 23 A. 'Yes. 23 A. Yes. 24 • Q. All right. How old were you? This was in 24 Q. Okay. — he would have been 25 2003? This \ vas before the Summer of '03 then? 25 shortly after 12 (Pages 434 to 437) PROSE COURT REPORTING' AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (501 8647(015-6989-4762-94:144-66177536c376 EFTA01076732 Page 438 Page 410 1 A. Yes. 1. house when this occurred? 2- Q. Okay. And with where did that 2 A. Where were — 3- 3 Q. When — 4 A. His hoes 4 • A. That's broad. 5 • ' Q. Joseph where did that • 5 Q. When he digitally penetrated you, where 6 . moue? 6 • were you located? 7 A. My house. 7 A. Ina house, in — Q. Your room? 8' Q. I understand that. 9 A. Yes. 9 A. Yes. 10 Q. Any clothes come off/ 10 Q. Did you go in a bednaom or something like 11 A. No. 11 that? 12 Q. He reached underneath? 12 A. Yeah, in a roorn. . 13 A. Yet. 13 Q. All right. And did you touch him? 14 Q. All right Did you touch him? 14 A. Yes. 15 A. Yes. 15 Q. Okay. Clothes come off? 16 Q. .Okay. And did you masturbate him? . 16 A. Yes. 17 A. No. 17 Q. Yours, his, both? 18 Q_. Okay. Did he climax? 18 A. Mine. 19 A. I don't know. 19 Q. Any of his clothes come off? 20 Q. Did you? 20 A. No. I don't think so. 21 A. No. 21 Q. Okay. You touched him. Did he climax? 22 all" person, now we're back to 22 A. No. 23 23 Q. Did you? 24 A. Yes. 24 A. No. 25 Q. Okay. And that was at his house? 25 Q Okay. The next of the first five Page 439 Page 441 1 A. Yes. 1 people we talked about, in all instances it was 2 Q. Ms room? • 2 voluntary, consensual;you knew what was going on? 3 A. Nes. '3 .. A. Yes. 4 Q. And everyone —eeu then the next person 4' O. All right. 'Who is next then after 5 after that would have bee f 5 6 A. Yes. 6 A. 7 Q. Third person also still in '03 — 7 Q. 8 sorry fifth experience would have been a A. No. .It was. 9 With 9 Q. How many with on how many 10. A. Yes. 10 occasions did you have contact with him, physical 11 . Q. All right And was again 11. contact with him; just the once? 12 • digital penetration? 12 A. We were dating. . . 13 A. Yes. 13 Q. So it Was — was it more than once you had 14. Q. His house? Your house? Nobody's house? • 14 • digital penetration? 15 A. Friend's house. 15 A. Yes.' 16 Q. Which friend? 16 Q. Okay. Was it more than once that you 17 17 touched. him? 18 Q. All right And were there other people 18 A. Yes. 19 there at the time? 19 Q. Okay: And from —as time went on, was it 20 A. 'Yes. 20 nagtipleeccasions that you would have touched each 21 Q. • All right And were other people involved 21 other, had physical contact? 22 in different, as well, in having relationships. ith 22 A. Yes. 23 guys and girls? 23 Q. Okay. And did you ever masturbate him or 24 A. Not that Pm aware of. 24 did you ever see him masturbate? 25. Q. Where, where were you-all at the other 25 A. I saw him masturbate, yes. 13 (Pages 438 to 441) (561) .832-7500 PROSE COURT REPORTING AGENCY, •• INC:', . Electronically Signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 84147t016bie47a2404-0077530c374, EFTA01076733 Page 442 Page 444 1 Q. Okay. Next person you say is 1 had rw.wiltign, physical relationship withime 2 right? 2 sinca since you separated from 3 A. Yes. 3 A. 4 Q. And with him, is he someone you dated for 4 Q. So, you dated for three or 5 a period of time, or was this a one-time event? S fourinonths, you had multiple relations with him in 6 A. Excuse me. No, I dated him. which I assume removing of clothes, having sexual 7 Q. How long? 7 intercourse on multiple occasions, correct? 8 A. Three, four months. 8 A. Yes. 9 Q. Okay. And on how many occasions did you Q. 11.11s after.? 10 have sexual intercourse with him? 10 A. 11 A. I don't know. 11 Q. Is he someone you dated? Was this a 12 Q. More than ten times? 12 one-tune event? Again, you described it as 2003, 13 A. I don't — I don't know. I didn't count 13 digital penetration. 14 Q. And I'm not, I don't mean it necessarily 14 A.. We were friends. 15 exact, but multiple times? 15 Q. More than once? 16 A. Multiple times, yes. 16 A. No. 17 Q. Voluntary, consensual, you knew what was 17 Q. Okay. The one time he digitally 18 going on? You consented and he consented? 18 penetrated you, did you touch him? 19 A. Yes. 19 A. Yes. 20 Q. Are all ,e males that we've talked 20 Q. Okay. Did you masturbate him? 21 about through =at this time, are these 21 A. No. 22 individuals who are your same age or within a year 22 Q. Okay. Did he climax? 23 or two? 23 A. No. 24 A. Yes. 24 Q. You just touched -- 25 Q. An. if I remember, is the 25 A. Yes. Page 443 Page 4 4 5 1 person — the only person with whom you had a sexual 1 Q. -- one another? All right. ' 2 relatimatiLpost or after -- since you separated 2 Next would be whom, 3 from 3 A. No. No. Yes. 4 A. ' 4 Q. No, yes? Yes? 5 Q. All 5 A. Yes, yes, sorry. 6 right. 6 Q. Because he's the only other one in '03 at 7 A. 7 least that you've listed. 8 Q. Is that right? 8 Is there anyone else that you've forgotten 9 A. Uh-huh. that you should have put in the '03 period? 10 trst didn't catch the front for 10 11 Mr.. 11 Q A: on how many occasions did you 12 A. Yeah. 12 two get together physically? 13 Q. Let me start again. 13 A Three. 14 My recollection was, is your — when we 14 Q. Clothes come off? 15 • started your deposition, you said that you had had 15 A No. 16 sal relations with one on since you left 16 Q. Just he digitally penetrated you on 17 sic), and that was • 17 approximately three occasions? 18 . A. Yes. 18 A.. Yes. 19 Q. Now, are you still seeing him now? 19 Q. And did you touch him? 20 A. 20 A. Yes. 21 Q. Yes. 21 Q. And did you see — did you masturbate him? 22 A. No. 22 A. No. 23 Q, Are you seeing anyone else? 23. Q. Did he climax? 24 A. No. 24 A. No. 25 Q. And I assume then, other thanilltyou've 25 Q. Where did Iles - where did yoyset 14 (Pages 442 to 4 fib) PROSE COURT REPORTING AGENCY,. INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Ildiff0164MiS4702-9644-60776346371i EFTA01076734 Page 446 Page 448 together with 1 have been after 2 A. His house, a friend's house, that's it. 2 A. Yes. 3 Q. Any of the — any of the first eight 3 Q. Okay. And if I recall, he was 4 people we've covered ever occur at Jane Doe No. 4's 4 someone that you dated on and off fora long time'' 5 house? 5 A. Yes. 6 A. No. 6 Q. Do you ever see him anymore? 7 Q. At Jane Doe No. 7's house? 7 A. No. 8. A. No. 8 Q. Is he still around? 9 Q. Have you ever had any type of sexual 9 A. Yes. 10 activity occur, intercourse, oral sex, digital 10 Q. Did he ever get married? 11 penetration when you've been in Jane Doe No. 4's 11 A. I don't — I don't lcnow. 12 house? 12 Q. You just don't — have no connection with 13 A. I don't remember. 13 him at all? 14 Q. How about at Jane Doe No. 7's house? 14 A. I don't out him. 15 A. Yes. 15 Q. Okay.Ms someone that you had 16 Q. Okay. And who, with whom at Jane Doe No. 16 sexual intercourse. I assume if you dated over a 17 7's house? 17 four or five — three-year time period, you would 18 A. Thissuy I.P. 18 have had sexual intercourse with him, oral sex on 19 Q. Is he on this Ilst? 19 multiple occasions. Fair statement? 20 A. No. 20 A. Yes. 21 Q. 'Why not? 21 Q. And, again, everyone now through'''. 22 A. Because I, I don't know. Because We made out. 22 voluntary, knowing, intelligent, you understood, you 23 Q. All right. But you had no digital 23 agreed, your partner agreed, correct? 24 penetration, no touching? 24 A. Yes. 25 A. Nothing, just make out. 25 Q. In any of these relationships through Page 447 Page 449 1 Q. All right. Okay. After who's 1 any type of physical or verbal abuse with 2 next? 2 these individuals? 3 and then 3 A. Prior or with him? 4 4 Q. While you were dating these people or with 5 you say he's moat you have 5 these people 6 forS04 with Mr. you have for 6 A 2005. Should Mr. be in 2004? 7 Q. Was he abusive, physically abusive to you? a A. No. No, that one's correct. It was 8 A. That's such a broad statement to me. 9 That would be next Q. Okay. Did he ever strike you? 10 Q. It looks like= was the only one that 10 A. No. 11 you 1h1_— you have a long-term relationship 11 Q. Okay. Was -- did you consider him 12 wi 12 physically abusive to you? 13 A. I did. Not, not long term, no. 13 A. Yes. 14 Q. What are we talking about? 14 Q. In what way? 15 A. Three months. 15 A. He would grab me. 16 Q. And you had sexual intercourse with him on 16 Q. Where? 17 multiple occasions? 17 A. My arms. 18 A. Once. 18 Q. Leave bruises? 19 Q. And that was the only sexual, no oral sex, 19 A. No. 20 no nothing, just one time sexual intercourse in 20 Q. Why would he grab you on your arms? 21 three months? 21 A. We would be fighting, and I wouldn't get out 22 A. Yes. 22 of the way. 23 Q. aghe was the only person during 2004? 23 Q. Happen on many occasions? 24 A. 24 A. A few. 25 I. Okay. Now, I see So, 25 Q. More or less than five? , S17,..5 et e—JA...,-C- 4 17.......SnavaN....3 /4 NrCne.0,4, ...LiNje.“Vil,e3a1,14./.1%.2)....eSe.• 15 .(Pages 446 to 449) (561) '832.:.7500 PROSE COURT REPORTING AGENCY, INC. . Electronically signed by cynthia hopkins (601MI Electronically signed by cynthia hopkins (601 • Electronically signed by cynthia hopkins (601 8647f016-be89-4782-9d44-6af77636c37e EFTA01076735 Page 450 Page 452 ..1 Q. Okay. Did you ever tell him you had taken 2 anyone else to Mr. Epstein's hornet 3 A. N 4 O. Did know that you 5 6 A. I don't know. 7 . . Does anyone know you 8. . I remember ou told us that. Was he 8 tan our new and the 9 or was he 9 ith? 10 just angry with you? 10 A. Yes. 13. A. I think he was angry. 11 Q. Who? 12 Q. What had you done from his perspective; 12 A. 13. what did he say? 13 Q. 14 A. I don't know. 14 A. Yes. 15 Q. You — were you-all living, at any time 15 Because you told her 16 living together? 16 17 A. No. 17 A. No, I told her. 18 Q. Did any of these individuals that are on 18 Q. But other than your rents — do both of 19 this list, separate and apart from your husband, 19 your parents know you 20 have you lived with any of them at their home or — 20 A. Yes. 21 A. No. • 21 And dyer than morn and dad and 22 Q. — apartment? Okay. M, so. you 22 whom 've tol does anyone else 23 dated in 2004, 2005, and In 2004 tow I 23 know you 24 remember you were dating when Max -Iced if 24 A. Yes. 25 you wanted to go give a nussage to an older man'over 25 Q. Who? Page 451 Page 453 1 in Palm Beach, right? 1 A. 2 A. Yes. 2 Q. Who is MEP 3 Q. And. the one that said no way under • 3 . A. My cousin. 4 Cod's green or something to that effect? 4 Q. ii.r plhast name? 5 A. Yes. 5 A. onetic). I don't know... 6 Q. And then after you stooped dating- 6 Q. She's your cousin, not mine. 7 you then started that you kod you again, 7 A. Iknow. 8 and you went to Mr. Epstein's house, correct? 8 Q. 9 A. Excuse me. Yes. 9 A. Yeah. 10. ' Q. Did you ever — and then, then after you 10 Q. Where does live? 11 went to Epstein's house, did you start dating= 11 A. Orlando. 12. . . . again?' When I say, when you — after you first went 12 Q. Do you know what her number is? 13 to Mr. Epstein's house, which you, I think you 13 A. No. 14. described sometime in June of 2004. 14 Q. And did you tell -- when did you tell her? 15 A. okay. . 15 A. Long, long, when I was little. 16.. Q. Okay. Did you go at some point after 16 . Q. Close with her? 17 June of 2004 start dating- again? 17 A. I was. 18 ' A. 'On and off. 18 Q. Now you're just separated by distance? 19 Q. Okay. So, when you say you dated him in ' 19 A. Yes. 20 2004.to 2006, you dated him on and off during that • 20 Q. Any reason, other reason you're not close? 21 entire time period? 21 A. No. 22. . , A.,. Yes.. ' 22 Q. After M, r? 23 Q. Did you ever tell that you had gone 23 A. Excuse me. 24 to Mr. Epstein's home? 24 Q. Is he someone you dated? 25 A. Never. 25 A. Yes. 16 (Pages 450 to 453) PROSE COURT REPORTING :AGENCY;' Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 • 8617f0154•0047•244144077538orto EFTA01076736 Page 454 Page 456 , Q. Fora long period of time? 1 Q. Okay. And did you look at any of that 2, A. No. • '2 information before you came in today? 3 Q. How long did you date him? 3' • • A. No. . . 4. • A. Four month's. •• 4 Q. Okay. Did you get that information — 5 Q. And multiple times you have had sexual 5 well, let me strike that 6 intercourse, oral sex? You now know that it was — well, let 7 A. Yes. me — let me ask it this way: You knew that you got -8: • Q. and the only other person on 8 after or right around the time of 9• your list is is that correct? 9' 10 A. Yes. 10 A. Yes. 11 Q. 'So, everyone — there's ten people that 11 or shortly thereafter? 12 you've listed that you had some type of sexual • 12 A. Yes. • 13 activity, whether it was sexual intercourse, oral 13 Q. Okay. And you knew that it was after you 14 sex, digital penetration or you touching a min's 14 got that vehicle that you had gone to Mr. Epstein's 15: penis, that occurred prior to the time that you ' 15 house for the fast occasion.. 16 first went to Mr. Epstein's house, correct? 16 A. Yes. 17 A. That all of this, excuse me, all of this 17 Q. All right. And if so, if the, if the 18 happened priar to gothg to his house? 18 records reflect, it looks it appears 19 Q. Correct. 19 transferred on or about the end of 20 A. Some. 20 which would then put youth the June time 21 Q. Well, no, listen to me. Let me ask the 21 which met with your recollection; is that correct? 22 question again. 22 MR. MERMI3LSTEIN: I am just going to 23 Everyone through MEM, who Was 23 object I think you're generally right, but 24 number ten, okay, which you listed as 2004, those 24 think the — if you look at the data as to 25 are all individuals that you had a sexual activity 25 when, you know, you know, you do the Page 455 • Page 457 1 with before you ever went to Mr. Epstein's home, 1 transaction, the deal, and you take the car and 2 correct? 2 then 3 A. Yes. 3 tbera thetillealliSli) date 4 Q. Okay. And in each of those instances, as somewhere. 5 you've described to us; that is, before you went to 5 BY MR. CRITTON: 6 Mr. Epstein's home, you were in a position to make a 6 Q. Well, there's a, t 7 . decision both consensually, voluntarily, .7. date, and then there's. 8 intelligently as to whether or not you.were going to . .B •Do you know when you actually took possession of 9 engage in any sexual activity with any of those • '.9 that car? 10 males, true? 10 • . A.. I don't know. 11 • A. Consensually, yes. 11 . Q.; Sometime, would you agree with me that you 12 Q. All right. At your last deposition you , 12. couldn't have taken possession of it before you got 13 said, or at the start of your deposition you 13. • . title to it, or at least a transfer of title? 14 said that, you said you 'mew you were at 14 • 'A.. I don't know. 15 Mr. Epstein's home in, I think you said June of 2004 15 Q. Okay. Sootou think you can get a car and • 16 oour mother had just bought you a new, used 16 start driving it before you ever buy it? 17 18 is .• A. Yes. 5 or 2006. Do you remember saying that? 17 . 18 • MR. MERMELSTEIN: Objection to forth. BY MR. CRITTON: : 19 . Q. Okay. And I was sent something, and 19 Q. Doesn't 'make sense, does it? 20 couldn't out until today, but it reflects 20 A. I'm not a dealership. I don't know how that 21 that your was not a 2004. It was rota 2005 • 21 works — 22 or a 2006, but it was an older model. • 22 Q. Okay. Would you z- 23 A: Yes. 23 - to be honest with you. 24 Q. :laded correct? 24 Q. Your recollection is you went to 25 A. Yes. 25 Mr. Epstein's sometime ln'June of '04? 17 (Pages 454 to 45 / ) PROSE COURT • .REPORT I NG AGENCY," :INC (- Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be89-07a2-9d44-6a17.7636c37e EFTA01076737 Page 458 Page 460 1 A. Yes. 1 correct? 2 MR. MERMELSTETN: Can we take a break now? 2 A. Yes. 3 • We have been going for about an hour. 3 Q. And you-all ran home or went home, 4 MR. CRITTON: Sure. 4 reported that to the police, and the police 5. THE VIDEOGRAPHER: Off the record at S ultimately did a report. They interviewed you and 6 .3:06 p.m. 6 they did a report, correct? 7 (A brief recess was held.) 1 A. Yes. 8 . THE VIDEOGRAPHER: We're back on the Q. But they never found the person? 9 record at 3.24 p.m. 9 .Y.es. 10 BY MR. CRAYON: 10 Q. That's correct? 11 Q. Ms. DoeNo. 3, I want to cover some, sane 11 A. Yes. 12 events that happened to you prior to the time that 12 Q. And I think you told us he was in a car? .13 you ever went to Mr. Epstein's. So I'm going to 13 A. Yes. 14 focus on the time period before June of '04. Okay? 14 Q. And he opened his coat or whatever, and he 15 A. Okay. 15 Dyed with his penisin your presence? 16 Q. MI right. Some of these we touched on 16 A. He played with his penis *1 n msence, yes. 17' briefly at your last deposition. Pm not going to 17 18 go into detail again, but !just want to put it in 19 • terms of tinteframe. It appears that your parents 20 were divorced when? Do you know the year? 21 ' A. I don't know the year. 21 22 Q. Okay. Do you recall if they had -- and I 23. think you have described they had both a physically 24 . and a verbally-violent relationship — 25 A. Yes. 25 Q. -- of an event that you found disturbing Page 459 Page 61 1 Q. — in your early years, true? 1 at the time? 2 A. Yes. 2 A. I don't know. 3 Q. Okay. And I think you told us, and again 3 Q. All right. Did'you fmd it distUrbing at 4 this is all prior to the time that you met 4 the time? 5 Mr. Epstein, you told us that prior to the time, or 5 A. Yes. 6 at some point in time, you discovered that your • 6 Q. Okay. And in hindsight, as you look back; 7 father had been cheating on your mother and you told 7 that is, as you look back in time, it was a 8 your mother, correct? .8 disturbing, uncomfortable; embarrassing-type 9 A. Yes. 9 situation; would that be a fair statement? 10 Q. And that was upsetting to you, upsetting 10 A. I was uncomfortable. 11 to your mother, and obviously upsetting to your 11 . ' Q. All right. And you knew that what he was 12. father, correct? 12 doing was inappropriate? 13 A. Yes. 13 A. Yes. 14 Okay. And you were born on • of 14 Q. All right. And when you saw him doing 15 %. I= so you also told us on your last deposition 16 .- that, was he in a car, or did he get out of the car? 16 that, that in March, and I'm going to refer to 16 . A. In the car. 17. specific dates. If you think that date isn't 17 Q. Okay. 'And when you saw him dciing it, you 18. accurate enough, let me know, but live provided a 18 had the good sense to run away? 19 . number of police reports with dates to your 19 A. Yes. . 20 attorney, so I'm going really from those dates. 20 Q. Because you knew what he was doing was 21. Okay? 21 inappropriate? • 22 A. Okay. 22 A. Yes. 23 Q. In — on, on or about March 20th of 2000 23 Q. All right. Then in April, approximately 24 there was a male who exposed himself and fondled 24 April 11th, 2001, you were at a slumber at 25 himself in front of ou and a few of your friends, 25 your friend's house. I think it was tutecosl:L.V.:Yeassaadv.a.te— 18 (Pages 458 to 461) (561) '.832-7500 PROSE COURT REPORTING AGENCY, INC.' Electronically signed by synth's hopkins (601 Electronically signed by cynthia honking (601 Electronically signed by cynthia hopkins (601 8d471016-be89-47a2-9d44-6af77536c37e EFTA01076738 Page 462 1 you ever hear that? 2 A. Yes. 2 A. Yes. 3 Q. And werelccosted and 3 Q. Okay. And did she ever tell you that he 4 molested b ho touched your 4 had done that? 5. breasts,'touched you in — over your clothes on your 5 A. Yes. 6 breasts; and then helouched you inhis — in your 6 Q. And herself told you that? 7 vaginal area, true? 7 A. Yes. 8 MR. MERMELSTEIN: Objection to form. 8 Q. Did she tell you that on or about that 9 THE WITNESS: Over, yes. 9 time or years later? . 10 BY.MR. CRITTON: 10 A. I don't know when it took place. 11 Q. Right.. Over your — you had on pajamas, I 11 Q. Were you, were you — ltn softy, not 12 think you described, or some type of night clothes. 12 necessarily when it took plate, but did she tell y 13 A. Nightwear, yes. 13 around that time when you were approximately II 14 Q. • All right. And over those — well, in 14 years old? • 15 fact, I should ask you: What did you have on? Did 15 A. Told me what? 16 you have on pajamas? Did you have a nightshirt on? 16 Q. That her brother had raped her. 17 A. Pajamas. 17 A. Yes. 18 Q. All right. . Which would be bottom pants 18 Q. And how did you react to that? Did you 19 with a top pants? 19 understand what rape was at that time? 20 A. • I don't know exactly what I was wearing. 20 A: Yes. 21 Q. But something like that? • 21 Q. Okay. And you understood then that her -- 22 A. Yeah. 22 did you understand that her brother had sexually -- 23 • that is, 23 had sexual intercourse with her? Is that what you 24 hetouche you. He touched 24 understood from her? 25 your breasts over your clothes. And I think you 25 A. Yes. Page 463 Page 465 said you flinched, correct? 1 Q. And what, what was her reaction to that? 2 A. Yes. 2 !mean was she crying when she told you? Was she in 3 Q. Okay. And then he, he then touched you 3 shock? 4 down in your vaginal area over your clothes? 4 • A. Yes. 5 A. Yes. 5 Q. How did you react to that? 6 Q.. All right And again you flinched or 6 k I was in shock. 7 moved away from him? 7 Q. And Ms. Doe No. 3, was that after the . 8 A. Yes. • 8 slumber party that you learned all that? 9 Q. All right. And either that day or the 9 A. Yes. 10 following day, someone -- well, let me strike that. 10 Q. And would • be a correct statement that, 11. Did yougo back and tell your parents at all? 11 ' as a result of wha at the slumber 12. A. No. 12 party in which you teamed from that you 13. Q. .Did you tell anyone that day? 13 found that a very traumatic experience? 14. A. No. 14 • MR. MERMELSTE1N: Objection to form. 15 Q. Okay. And do you recall how it happened 15 . • THE WITNESS: What happened to her? 16 that they started an investigation that ultimately 16 BY MR:CItITTON: . 17 . led back to you? 17 . Q. • What happenedto you. 18 A. 18 . A. I don't know. 19 19 Q. Didyou — were you, when he touched you 2a that night, were you in shock? 21 MR. MERMELSTEIN: Objection to form. 22 THE WITNESS: I, I don't know. 23 BYMR. CRITTON: 24 Q. Well, did you perceive were you shocked 25 at what he had done? I'm not talkin the medical 19 (Pages 462 to 465) PROSE COURT REPORTING AGENCY, INC:. Electronically signed by cynthia bodkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia bodkins (601 8d47f015-be89-47a2-9d44-6a177536c37e EFTA01076739 Page 466 Page 468 1 definition of shock. I'm talking about how you 2 felt. A. Yes. 4 Q. Did you — were you confused? 5 A. Yes. 6 Q. Were you humiliated? 7 A. I don't know. 8 Q. Were you embarrassed? 9 A. I don't know. 10 Q. Okay. Did you have what you considered to 11 be a severely, severe emotional reaction to what he 12 had done? 13 MR. MERMELSTEIN: Objection to form. 14 THE WITNESS: I don't know. 15 BY MR. CRITION: 16 Q. Maybe you did, maybe you didn't; you just 17 don't recall? 18 A. Correct. 19 Q. When your mother found out about what had 20 happened — well, let me strike that. 21 Did the police just show up at your door 22 and say we w d like t talk to your daughter about 23 being over at s house? 24 A. I don't blow how. I don't know. 25 Q. But you remember the police interviewing Page 467 Page 469 3. you? 3. N 2 A. 3 . -- for an reason? Oka . correct? 9 A. Yes. 10 Q. I'm not trying to make the math hard, I 11. think that -- I think that's accurate. 11 A. I did not. 12 Prior to that time at least it looks fro 12 Q. Did someone — did you tell anybody about 13 readin 13 it or did someone find what you had done? 14 A. Yes. 15 Q. Who? 16 A My mom. 17 17 Q. .•Did she come in when you were doing this? 18 18 A. 29 20 (Pages 466 to 469) . PROSE COURT REPORTING AGENCY, INC... Electronically signed by cynthia hopkIns (801 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hooking (601 Bd47f015-bo89.47a2.9d44.6af77536c37o EFTA01076740 Page 472 1 DI 2 3 3 A. I don't thinlcso. 4 4 Q. Does your father know? Did your mom ten 5 5 your dad? 6 A. Yes. 7 7 Q. Okay. Were they separated at that time? 8 8 A. Yes. 9 10 10 11 11 12 A. Summer. 12 13 When she saw it, what did she say? 13 14 A. I don't know. 14 15 What did you tell her? 15 16 A. The truth. 16 17 Which was what? 17 Do you remember that? 18 A. 18 A. Yes. 19 19 Q. Okay. On how many — and that was how 20 A. 20 old were you then? Is this around the same time or 21 21 were you even younger? 22 A. 22 A. I don't know. 23 23 Q. On how many times, on how many occasions 24 A. 24 did it occur when you were young, when your parents 25 25 were still together before they got a divorce, Page 471 Page 473 1 2 IIIIIIIIP MR. MERME : • don to form. 1 2 Ms. Doe No. 3, that the — either the verbal or the physical violence was so great that you and your 3 THE WITNESS: 3 mother and your sister had to leave the house? 4 BY MR. CRITTON: A. Maybe like two times. Ii7C Q. Okay. Those are indelibly etched on your brain? MR. MERMELSTEIN: Objection to form. 8 THE WITNESS: I remember them. A. The divorce. 9 BY MR. CRITTON: 10 . Q. Your parents? 10 Q. And I would guess fora small child, they 11. • A The cheating, yes. 11 • were pretty traumatic events? 12 Q. Did you believe that you had played drole 12 MR. MERMELSTEIN: Objection to form. 13 in the divorce taking place? 13 THE WITNESS: Scary. 14 A. I did believe that. 14 BY MR. CRITTON: 15 • MR. MERMELSTEIN: Objection. 15 Q. And were you fearful for yourself? 16 BY MR. CRITTON: 16 A. No. 17 Q. Because you had told your mom that your 17 Q. For your mom? 18 dad had been cheating? 18 A. Yes. 19 A. No. 19 Q. Were you —.did you find the whole events 20 Q. What, what role did you believe that you 20 between your mother and father to be confining? 21 had played in the divorce? 21 A. Yes. 22 A. Because I was a child. I,1 don't know. 22 Q. Okay. And did you consider that those 23 laid you tell me you had a sister? Is it 23 were emotionally taxing on you? 24 24 A. Yes. 25 A. Yes. 25 Q. Did your mother take you to see any type 21 (Pages 470 to 473) (561) 8323 .500 PROSE COURT. REPORTING AGENCY, INC. EbatroNcally signed by Grebe hopldns 'Elmbonically signed by cynthis hopldna (601 • .ffeectrankally bind by Cynthia hobbit* (501 8(1471015-be89-47a2-9d44-6af77536c37e EFTA01076741 Page 474 Page 476 2 3 4 5 .6 6 Q .7 7 A. 1— I don't know. '8 8 Q. You have no recollection as you sit here 9 9 now? 10 10 MR. MERMELS • "on to form. 11 11 THE WITNESS: 12 12 BY MR. CRITTON: 13 13 Q. You say many things. What, what things 14 14 were bothering you at that time? 15 15 A. I, I don't know. I don't know.. 16 16 Q. Can you give me anything that was going 17 17 on? Okay. You're 15 years old now because you had 18 18 s permit, so we had to have been in 19 19 So you had some relationships, because we 20 20 know that fro 21. A. I don't know. When I was older. 22 Q. At that time were you dating anyone? 23 A. I don't, know. 24 24 A. Life. 25 25 Q. Was it your parents? Page 477 what happened? A. No. 2 Q. Was it your peers, your female peers? 3 A. I don't, I don't know. 4 Q. School? A. I don't — no, I don't think so. 6 Q. But you pulled a car. Did you have a Q. Relationship with a guy — 7 driver's permit at that time, a learner's permit? A. I don't know. 8 A. Yes. 9 Q. :So you would have had to have been at 10, least 15? 11 • A. 12 O. 18 18 Q: Do you know where you were? 19• Q. Was anyone in the house with you? 19 A. Taco Bell. . 20 A. No. 20 Q. • Which Taco Bell? 21 Q. Okay. And what happened? 21 A. 22 22 (Pages 474 to 477 ) PROSE .COURT ..RERORTING. AGENCY, INC. Electronically signed by cynthia honking (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f016-be69-4782-9d44-03077636c37e EFTA01076742 Page 478 Page 480 1. been just prior -- what did I say, '05? 2 MR. MERMELSTEIN: Yeah. 3 MR. CRITTON: Okay. 4 BY MR. CRITTON: Q. of—just prior to of. 6 A. Comet ). Well «h() else -- 7 MR. CRITTON:. Okay. We have to change the 8 tape. 9 THE VIDEOGRAPHER: Off the record a 3:46. 10 This is the end ofTape 1. 11 (A brief recess was held.) 12 THE VIDEOGRAPHER: We're back on the. 13 record at 3:49 p.m. This is the start of 14. Tape 2. 15 BY MR. CRITTON: 16 Q. Ms. Doe No. 3, before we changed the tape, 17 I think you said that just before your 18th 18 birthday, or before ou turned 18, you had met your • . All right. So, an 'how you took — you 19 current husband, which would have been 20 sometime prior to of.. 21 A. Correct • • 22 Q. Within a month or so. Is that a fair 23 statement? 24 A. Yes. 25 Q. Aml I saw someplace that you met him Page 479 Page 481 1 through MySpace? 2 A. Yes. 3 Q. All right. Did you converse over MySpace 4 for a period — did someone introduce you and say, 5 hey, you should hook up with this guy? A. Because of me and my current husband's 6 A. Yes. 7 situation at the time. 7 Q. All right. So you MySpaced each other, 8 Q. What was the situation'at that time? 8. you liked what each other looked like, what you said 9 A. Lying, not having like any sexual activity or, 9 .over the social networking and decided to get 10 • you know, contact or just fighting. 10 together and meet? 11 Sio you remember when you first met 11 A. Yes. 12 your husband? 12 Q. Okay. Within how long after you met did . 13 A. Yeah. 13 you start dating; that is, if I had to say, when did 14. Q. When? What year? 14 you-all start dating? 15 - • A. I was just going to be 18. 15 A. Sometime after June 26th. 16 Q. Eighteen. You were 18. So that would 16 Q. " Of2006? 17 have made you -- approximately just before of 17 A. Yes. . ' • 18 . M right? 18 Q. And I think.you were married in September 19 MR. MERMELSTEIN: No. She was bom in 19 . of '08? 20 • •. 20 A. Yes. 21 • MR. CRITTON: Right. So, just before she 21 4 . So, sometime between June 26 of '06 an,: 22 . was 18, so 17. 22 Seutember of138 23 _Wt. MERIvtELSITIN: Eighteen is of " 23 24 Ms when she turned 18. 24 A. Yep. Yes. 25 MR.CR1TTON: Right. Oh, so it could have 25 Q. Can ou —knowin: those . :meters now 23 (Pages 478 to 481) PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 8647101febe89-47•246144•177638037e EFTA01076743 Page 482 Page 484 can you give us a better point in time when that 1 had you anew: had 2 occurred? 2 sexual intercourse? 3 A. 3 A. Yes. 4 Q. Okay. But for some reason you had 5 stopped? 6 A. Yes. • Q. What happened? Tell me what you, what 7 Q. Why had you stopped? 8 happened. 8 A. Certain things that he would do to touch me 9 A. I took the pills, sat there, and thee 9 just triggered things for me. 10 called me and I talked to her, and I told her what 10 Q. Such as what? 11 happened and then she me. 11 . A. Such as what, what? 12 Q. What, what was so awful with our 13 l i hat caused you to not 34 is physical touching of you? 15' MR. MERMELSTEIN: Objection to form. 16 THE WITNESS: So what are you asking me? 17 BY MR. CRrTTOM ccuned between you and 18 Q. ram asking you, you say that something 9 19 about what he was doing with you physically you U 21 A. We were fighting. 20 21 found revolting, apparently. A Yes. 22 Q. Okay. And I think you had now -- you were 22 Q. Okay. What was he doing? 23 fighting. You said that you had no physical, no 23 A. Touching me a certain way that I didn't like. • 24 sexual relationship at the time? 24 Q. Where? 25 A. Yes, it was rough. 25 A. My breasts and my vaginal area Page 483 Page 485 Q. Okay. When you say -- not rough sexually, 1 Q. And you just didn't like what he was 2 just no sex? 2 doing? 3 A. Pretty much. 3 A. Yes. 4 Q. Okay. And that was unsatisfactory for 4 Q. Because you didn't — had other people you? 5 done that to you before? 6 A. For him. 6 A Yes. 7 Q. Okay. Because you had said, I'm not going 7 Q. Okay. Who? 8 to have sex for whatever reason? 8 A. Epstein. 9 . . !just never wanted to. 9- Q. Okay. Had you ever told anybody this? -8 Q. With him? 10' A. Told anybody what? 11 A. At all. 11 Q. What you just told me. 12 Q. Okay. At the time that you were going to .. 12 A Yes. 13 kill yourself, had you had relationship -- 13 14 had you had sex wit -14 15 A. At the time l was trying to? 15 16 Q. Yes, ma'am. 16 17 A. Prior? 17' Q. So, it should — if yoti told her that, it 18 • • Q. Yes. Let me ask it again. You said, he 18' should be in your notes? 19 obviously was complaining that you weren't having a 19 . MR. MERMELSTEIN: Objection, her notes? 20 sexual relationship, correct? 20 MR. OlITTON: Let me strike. Her notes, 21 A. Correct. 21 • 22 Q. All right. You were fighting about that 22 MR. MERMELSTEIN:. Objection to form. 23 and probably other things, correct? 23 THE WITNESS: I don't know,' Tve never 24 A. Correct. 24 seen them. 25 Q. All ria. As of the time 25 24 (Pages 482 to 485) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be89.47e2-9d44-6af77536c378 EFTA01076744 Page 486 Page 488 BY MR. CRITTON: 1 then touching me from my buttocks to my vaginal area. 2 Q. Okay. Hadpost -- prior — after the time 2 Q. You say touching your say it again, the 3 that you went to see Mr. Epstein where you were at 3 last was? 4 . his house on the one occasion when there was 4 A. My butt to my vaginal area. 5 contact between the two of you in June of '04, you 5 Q. And what do you mean by that? Describe 6 had had relations with whom? Do you remember? 6 exactly what you say Mr. Epstein did. 7 I probably should go back to Interrogatory . A. Caressed my butt and then slowly swooped from 8 Answer No.4, if you would take a look at those the crack down to the front of my vagina area. 9 again. • 9 Q. Was he between your — he, Mr. Epstein, 10 THE WITNESS: Look at this one? 10 between your legs, or was he behind your butt with 11 MR. MERMELSTEIN: Yeah, Exhibit 4. 11 his hand, and then you say swooped. Then did he go 12, THE WITNESS: Which one is Exhibit 4, that 12 behveen your legs -- 13 one? Okay. Question number what? 13 A. Yes. 14 MR. MERMELSTEIN: I'm sorry. What's the 14 Q. — to touch you in the vaginal area? 15 question, Bob? 15 ... A. Yes. 16 BY MR. CRITTON: 16 . Q. Had no other male ever done that with you? 17 Q. The qUestion is -- if you go to question 17 A. No. 18 18, is which — after Mr. Epstein -- after you had 18 Q. No other- man in, since 2003, in the 12 or 19 been at Mr. .E.? te is house, you had had sexual 19 ' 14 people that we talked about had ever touched your 20 relations with Brewer (sic), correct? 20 buttocks and then reached underneath and touched you 21 A. Brewster. 21 in the vaginal area? s Who else 22 A.. Not that way. 23 Q. Had any males ever touched you in the 25 24 -an Uh-hlis . Anyone else 24 buttocks and then touched you in the vaginal area in Q. 25 a different way? Page 487 Page 489 1 A. I think that's it. 1 A. Yes. 2 Q. Okay. And with separating out 2 Q. Okay. So again you need to tell me then 3 had you ever had an roblems with having sexual 3 what you allege Mr. Epstein did so I understand 4 relations either with with 4 exactly the move that you didn't like. 5 °r with 5 A. The swooping from the butt to the vaginal 6 A. No. 6 area. 7 Q. Okay. In each of those instanots,1 7 Q. What do you mean by "swooping"? 8 assume, in addition to the intercourse, there was 8 A. Hen's my butt; here's my vagina. He would go 9 touching? 9 over it and then he went in towards, like try to get in 10 A. Yes. 10 between my legs to touch my vagina, the way that it -- 11 Q. But that didn't bother you at all, or I 11 the way, the motion, the way that he did it. 12 won't say it didn't bother you. You enjoyed it? 12 ilOkay. And nobody else had done that until 13 MR. MERMELSTEIN: Objection to font 13 id it that way? 14 THE WITNESS: I enjoy being touched, yes. 14 A. Correct. 15 BY MR. CRITTON: 15 Q. And other males had -; well, in fact, most 16 All right. In what way was 16 of the other males that we talked about, they had touching you that somehow well, let me 17 touched your breasts before? 18 strike that. 18 A. Yes. 19 You say he was touching you in a way that, 19 Q. Okay. And they had touched your nipples? 20 what, reminded you -- you need to tell me again what 20 A. Yes. 21 you said about Epstein. What was — 21 Q. All right. And what did Mr. Epstein do 22 A. He touched me the same way Epstein touched me. 22 when he touched your breasts.or your nipples? 23 Q. Okay. Which was exactly how? Tell me 23 A. Pinched them. 24 what he was doing. 24 Q. Okay. And no other, of the 13 or 14 men 25 A. Groping my breasts, touching my nipples, and 25 that*we've described had, other than had 25 (Pages 486 to 489) (561) 832-7500 PROSE COURT 'REPORTING AGENCY, .INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d4710164**-47•24444-6a77836eare EFTA01076745 Page 490 Page 4.92 ever pinched your nipple before? 1 Q. Okay. How was he touching your breasts in • A. I,I don't know. a way that you thought was similar to what 3 Q. Alt right. So, is it, is i 3: Mr. Epstein had done? 4 testimony then -- so what wa doing that you 4. A. Just the way he grabbed them. 5 didn't like? 5 Q. How? 6 A. I just told you. 6 A. Like, I don't,I don't know how to describe 7 Q. Okay. Well, separate and apart from what 7 it. 8 you described, touching your buttocks and then you 8 9 in the vaginal area, how was he touching your — you 9 d~r ad 10 said you don't — you then — well, let me start 10 done? 11 again. • 11 MR. MERMELSTEIN: Objection to form. 12 Separate and apart from touching your • 12 THE WITNESS: Because I don't — I don't 13 buttocks and the vaginal area, which you said was 13 know. I don't know. • 14 • similar to the way Mr. Epstein had done it, correct? 14 BY MR. CFUTTON: 15 A. Yes. 15 Q. Would you agree with.me that it would not 16 kay. Had he done that fora long — he, 16 17 18 .ili MR. done that for a long period of time? MERMELSTEIN: Objection to form. 17 18 be unusual foreman to stimulate a woman's breasts her nipples, as part of foreplay? MR MERMELSTEIN: Objection to form. 19 BY MR. CRITION: 19 THE WITNESS: I don't know. 20 Q. That is, touched your buttocks and then 20 BY MR. CRITTON: 21. 21 know. Okay. So you told 22 23 touched your vaginal area in a way that you thought was similar to what Mr. Epstein had done. A. No. 22 23 s e youdon't A. Sony. didn't like that, and his response was? 24 Q. Okay. Is it something he just started 24 Q. 25 doing? 25 result of that, Page 491 Page 493 1 A. Yes. 1 2 Q. Okay. Did you tell him you didn't like . 2 3 it? 3 4 A. Yet 4 . A. Because we had been fighting and we weren't -- 5 Q. And what did he say? 5 you know, we weren't wo just were not on the same 6 A. I don't know. 6 page anymore. We were not stating well. Q. Well, if you hadn't had sexual intercourse 7 Q. All rigid. You called 8 or sex, sexual conduct -- contact for a period of 8 A. 9 time, what was occurring, then, during that time 9 10 period where you're just not being close with one 10 11 another at all -- 11 12 A. Yes. 12 Q. Did she come to get you? 13 Q. fora period of how many months? 13 A. Yes. 14 A. Fora long time. 14 Q. Where did she take you? 15 Q. Whets a long time to you? 15 A. To my house. 16 A. More than a month. 16 Q. What did you do? 17 Q. And did you tell hint that you didn't like 17 18 what he was doing? 18 19 A. Yes. 19 20 Q. And what did he say? 20 Q. What else? 21 A. Why. 21 A. Then I went to bed. 22 Q. Did you tell him? 22 Q. Did she stay there with you? 23 A. Yes. 23 A. 24 • Q. And what did he say? 24 25 A. jul i inchltlavnlc2 to say. 25 • .4 . 26 (Pages 490 to 493 PROSE COURT. REPORTING' AGENCY INC: ( Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 edaf01640947•24.144077538e379 EFTA01076746 5 A. No. 6 Q. You eventually got back together because 7 . you got married? 3 A. Yep. Q. 9 Q. Okay. How long assed before you A. 10 were back together with 10 Q. And he said fine? 11 A. I don't know, months. 11 A. No. 12 Q. Okay. Did you start having sex again, 12 Q. He went begrudgingly? 13 then? 13 A. Yes. 14 A. Yes. Ear what happen' 15 Q. Okay. And was that okay with you? 16 A. No. 16 A. Nothing. 17 t is, did your sexual experience with 17 Q. Did your life improve at all? 18. i:prove? 18 A. Somewhat. 19 A. No. 19 u t s I have -- oka . Was there 20 Q. It stayed miserable from your perspective? 20 A. Yes. 21 A. I think that's it. 22 Q. Okay. Then you eventually got married? 22 I have seen various reports from 23. A. Yes. 1 uch passed mou gotbeack with y y uou Page 495 Page 497 1 were again having sexual intercourse and foreplay 1 A. Okay. 2 and then you decided to get married? 2 Can oudesc 3 MR. MERMELSTEIN: Objection to form 4 THE WITNESS: How much time passed? 5 BY MR. CRITTON: Q. A quick digression. With Jane Doe No. 4. 6 Q. Right 6 did you ever see a video that she made of another 7 A. I don't know. 7 female and herself kissing that ended up on the 8 Q. Six months, a year? 8 Internet? A. I, I don't know. 9 A. No. . 10 Q. Why did you get married to someone who you 10 Q. Okay. Did she ever tell you that he 11 didn't — it doesn't sound like you liked very well? 13. made a triple-X rated video of she and 12 MR. MERMELSIEIN: Objection to the form. 12 having oral and sexual intercourse? 13 TESS: Because we were supposed to 13 A. No. 14 and Hove him and I care 14 Q Has anyone ever told you that? 15 about hint • 15 A. No. 16 BY 16 Q. What's vour cell lone number, please? 17 17 A. Mine? 20 21 22 23 24 25 25 27 (Pages 494 to 497) (561)..832-7500 PROSE COURT REPORTING, AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthat hopkins (601 Eld471015-bel39-47e2.9d44.6a177536c370 EFTA01076747 ?eye 4 Page 500 1 A. MI 2 Q. C — spell it. ' 3 hdouse, A. I don't know. It starts with aii. Q. The first time — was the first time 4 what were you doing at 5 before you were married? 5 or her aubt's house? 6 A, Yes. 6 A. We had to a graduation party. 7. Q. And what did that relate to? 7 Q. You and 8 A. 't know. 8 A.16, — 9 9 Q . 9 A. (PheaS i 11. . Q. That's her nam 12 • A. Y.eah, 13 Q. Okay. 14 A. And her boyfriend and his brother and just a 15 . bunch of friends were there. 16 Q. At the graduation party? 17 A. Yes. • 18 Q. And then you went back tolls aunt's 19 house? . 20 A. I think it Was her alines. I don't know. 21 Q. Wh 22 - : 1 11.1. and his brother, I 23 think. 24 . Q. Wvas boyfriend? 5 . Are you — do you feel relieved the two of 25 A . Page 499 Page 501 you have split up? 1 Q. Was was Ms boyfriend? 2 MR. MERMELSTEIN: Objection to form. 2 A. Yes. THE WITNESS: No. 3 . Q. And his brothees name was? 4 BY MR. CRITTON: 4 A.Idol* )31OW. 5 Q. Do you feel less anxious, less depressed 5 Q. Brother? 6 because you made a decision to move on? 6 A. Just brother. 7 MR. MERMELSTEIN: Objection to form. 7 Q. Okay. And at the — at the graduation 8 THE WITNESS: I don't know. s party, weft you guys drinking? 9 BY MR. CRITTON: .9 A. Yes. 10 - Q You don't know as you sit here? 10. • Q. Had you had a lot to.drink? 11 A. Yeah, I don't know. • 11 . A. No. 12. Q: I have seen in the records at age 15 you . . 12 Q. Had you been smoldng pot? 13 . were, what I have seen is, date raped; is that 13 .A. No. 14 • correct? 14 Q. Had you had -- taken Ecstasy or cocaine? 15 A. Yes. 15 A. No. 16 Q. Where were you at the time? 16 Q. Had you had anything — had you had any 17 . . A. At a house. 17 type of cbugs other than alcohol? 18 Q. Whose house? 18 A. No. . 19.: A. ' A friend's house. 19 Q. Okay. Tell me what happened. . 20 Q. Right. What friend? Does the friend have 20 A. I went to the party, the graduation party. We 21 . a name? 21 were all hanging out, dancing, talking. I was drinking 22 :• A. I think she was watchin n't 22 beer out of a can. I needed another beer. They got me 23' know. It was her aunt's house. 23 a beer, came back. i 24 1philne . 24 . . Q. 7 25 who? 25 . A. brother. • 28 (Pages 498 to 501) PROSE COURT -.REPORTING AGENCY INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 86471015-0080-47a2-9444.6a177636c37o EFTA01076748 Page 502 Page 504 Q. Alizigki, 1 A. Yes. 2 A. Ot= and his brother. And I drank the 2 Q. Where? 3 ' beer. We ended up leaving. I went over to that house. 3 A. My legs. We.were.just going to spend the night there instead of • 4 Q. And could you remember from the night 5 driving all the way back out there. I fell asleep on 5 before what this guy being on you; that is, brother the couch, and then I moved into the bedroom. .. 6 being on you, that he had sexually assaulted you? 7 • I thought I locked the door, and then next. 7 . A. Yes.. 8:. • . thingyou know I have a guy on top of me, and I . 8 Q. Okay. And yoti knew that he had penetrated 9' can't move and I wake up the next morning. 9 you with his.penis? 10 Q. Who was the guy, brother? 10 A. Yes. 11 A. I think so, yeg. 11 Q. All right: And did you scream for help 12 Q. *And oil" you knew Wand you knew 12 that night? 13 her boyfriend 13 • A. I couldn't tlo anything. 14 A. Yes. ..• 14 Q. Why? 15 Q. You know what s last name was? • 15 A. Because I was lifeless. 16 A. No. 16 Q. And you think that they had given you.some • 17 Q. But yaisould have go 17 sort of drug? 18 brother's — ='s last name from true? - 18 A. Yes. . 19 A. Yes. I don't remember his last name. 19 24 When you woke up the next morning, did you 20 Q. I understand that. 20 tel 21 A. Okay. 21 A. No. 22 Q. I mean as you sit here today, but you knew 22 Q. Did youlea? 23 it back then? 23 A. No. '24 A. Yeah. 24 Q. You did tell your mother? 25 Q. All right. And the only other guy that 25 A Yes. Page 503 Page 505 • 1 was in the !Loathe only guys that were in the 1 t did our mother say? 2 house were and his brother? 2 3 A. Yes. 3 4 Q. All right. And one of the guys ended up 4 5 on top ofyou? 5 6 A. Yes. 6 7 Q. Okay. And it wasn't Mit '7 8 A. No. 8 9 Q. So, it had to have been his brother? . -9 10 • A. • Yes. 10 11 Q. So, when you woke up the next morning, 11. 12 . were your clothes off? 12 13 A.. I — . 13 14 Q. Or.pulled down? 14. 15 . A. Yeah. 15 16 Q. Okay. And - 16 17 A. My.pants. • 17 18 Q.' — you had on pants. Were you did you .. 18 19 • have on a skirt and like underwear pantl, or ate you . 19 20 :talkinglike jeans? 20 21 A. • leans, like dress pants. 21 22. ' Q.' All right. And were your pants and your 22, 23 panties pulled down? 231 24 A. Yes: 24 25 2.±,Idatt22±25:Earks on vou at all? 25. 29 (Pages 502 to 505) • . ( 561)' 83 2;777 500 'PROSE COURT.RE PORTI NG AGENCY,: INC.; Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-be89-47a2-9d44-6a177536c37e EFTA01076749 Page 506 Page 508 A. 1 happened. 2 Q. 2 • BY MR. CRITFON: 3' A. 3:. . . Q. Were you embarrassed by what had happened? 4 Q. 4. A. A little bit, yes. .5 A. 5- Q. And from 1!'.'r' re rts. 6 Q. 6. 7. . A. 7 8 Q. 8 true? 9 A. 9. A. True. to . Q. Okay. Because you.considered it to be an 11 emotionally disturbing event, true? 12 u 12, A. Somewhat, yeah. 13 had • 13 Q. Okay. So now, the fact that the guy raped 14. A. Yes. 14 you, drugged you and raped you, it's a somewhat 15 Q. Okay. I remember that. . 15 'disturbing event? . 16. . Asa result of havin been raped, did you, 16 MR. MERMELSTEIN: Objection to form. • 17. 17 BY MR. CIUTTON: 18 18 - • Q. 'just want the ladies and gentlemen of . 19 . 19 the jury to understand that's how you've described 20 • 20 that event now. 21 Q. And did your — what was your mother's 21 MR. MERMELSTEIN: Objection to form. 22. position? 22 THE WITNESS: Eve moved on. 23 A. Same. 23 BY MR. CRETTON: 24 Q. And.why didn't you?. You knew who it was, 24 Q. You've moved on. Okay. Did you sue him? 25 so why didn't you call the police? 25 Did you bring a lawsuit again the brother? Page 507 Page 509 A. I was scared. 1 A. I didn't press any charges. 2 Q. Of what? 2- Q. That's not my question. Pressing charges 3 A. lust having to go through that. 3 is criminal. Tell the ladies and gentlemen of the 4 Q. What did you think you'd have to go 4 jury whether you brought a civil suit against the through? 5 man who sexually assaulted you and drugged you and 6 A. Humiliation. 6 raped you. 7 ' Q. Okay. Did you — as a result of having .7 A. No. 8 been raped by the brother, you -- that was a 8 Q. Why not? 9 trawhatic situation for you, was it not? 9 A. . Because -- I don't !mow. 10 A.. Yes. 10 Q. Because he didn't have any money, wasn't a 11 Q. Were you in shock? 11 billionaire, maybe? 12 A. Yes. 12 A. No. 13 Q. Did you fmd it shameful and humiliating 13 MR. MERMELSTEIN: Objection, form. 14 and embarrassing? 14 Argumentative. 15 'MR. MERMELSTEIN: Objection to form. 15 BY MR. CREITON: 16 . • -THE WITNESS: No. 16 Q. How about Mr.IIM, the one who had. 17. BY MR. CRII7ON: • 17 sexually assaulted you when you were approximately 18 Q. 'Okay. You didn't you weren't ashamed 18 13 years old? Did you and/or your parents on your 19 at all— . 19 behalf institute a lawsuit against him suing him for 20 MR. MERMELSTEIN: Objection to form. 20 having sexually molested you? 21 BY MR. CRITPON: 21- A. No. 22 Q. — because he had pushed himself on you 22 Q. Why not? .. 23 and drugged you, convert 23 A. I don't know. • 24 MR. MERMELSTEIN: Objection to form. 24 Q. In 2000, in November of 2002, you and your 25 • .. THE WITNESS: I was ashamed that it 25 friend well, let me strike that. 30 (Pages 506 to 509) PROSE COURT REPORTING: AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthta hopkins (601 86171016-668047•2-9644-66177 . 5366376 EFTA01076750 Page 510 Page 512 1 Were you arrested or — well, let me . 1 • Oka • Andl 2 strike that. Did you have a — in November of 2002, 2 3 were you and one of your friends — one of you — I 3 I need to start once more. 4 Q. I'm sorry? In November of 2002, did you 5 A. We found her. 6 Q. Who is "we"? I 7 A. No. .8 9 Q. agy„ilt=zmember, you and a girl 9 10 named (phonetic) — is that one of ' 10 11 your friends? 11' 12 A. 12 13 13 14 15 , 16 A. I didn't do that 16 Q. How many times were you — let me strike 17 Q. Who did that? 17 that. 18 A. I don't know. 18 Were you only engaged to on one 19 Q. Okay. Were you accused of doing that? 19 occasion, or were you engaged on more tart one 20 A. Yes. 20 occasion; that is, then broke it off and then got 21 Q. Okay. Do you remember there was a police 21 engaged again? 22 report? 22 MR. MERMELSTEIN: Objection, form. 23 A. Yes. 23 THE WITNESS: We broke up. 24 Q. Okay. Is that the same 24 BY MR. CRITTON: 25 who you and she — she took her mom's ATM card and 25 g When you saw her— well, !erne strike Page 511 Page 513 1 1 that You, you said you broke up. At one time were I 2 you engaged and then did you call off the MR. MERMELSTEIN: Objection to form. 3 engagement? BY MR. C .4 A. Uh-huh.. Yes. Q. 5 Q. On how many occasions did you do that? 6 A. That' 6 A. Once, I think. 1 Q. Same person that was accused of.— 7. Q. You made a request for — well, let me j a Yes. 8. strike that 9 you had already been 11 A. ' Yes. 11 to Mr. Epstein's home, correct, because you had gone 12 Q. All right. And is e one 12 to his house in 2004? 13 that you got in a fight with that one time? 13. A. 14 A.. Yes. 14 15 Q. Okay. And that was over a boy? • did you? 16. A. Yes. 16. No. 17 Q 1.7 the reason you didn't • because it was not a big event I 19 at that time, was it? 20 A. Yes. 20 MR. MERMELSIEThlf Objection to form. 21 • Q. Okay. Did _do it? 21 THE WITNESS: No. 22 A. 'don't 22 • BY MR. CRITTON:. 23 ilYou saw 23 Q. At the time that you • ; is that con cct? 24' didn't have a multi-million dollar lawsuit against 25 A. Yes. 25 Mr. Epstein, did you? 31 (Pages 510 to 513) (.561) 832-7500 • PROSE COURT REPORTING AGENCY, INC. Electronically signed by synth's backlit. (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 86471015-be89-47a2-9614.6af77636c37o EFTA01076751 Page 514 Page 516 1 MR. MERMELSTEIN: Objection to form. 1 A. He's a he. 2 THE WITNESS: No. 2 3 BY MR. 4 Q. At the tiro 5 didn't have an attorney, did you? V 6 A. No. that meet with your recollection? 7 use ■ A. Yes. I and you didn't file your • At ! it ' 1 I.. lawsuit until of 2008, correct? 10 A. 11 14• Q. And? 15 A- It's right by Wildcat Way. 16 Wildcat Way? 17 A. 18 19 Did you sped fical 20 and this, and the date o 20 MR. MERMELSTEIN: The Wildcats. 21 September of 2009. Did you tel to 21 THE WITNESS: The Wildcats. 22 send records that had been requested? 22 23 A. No. 23 24 Q. Okay. So her letter, she's not telling us U 25 the truth when she's saying she was told not to send 25 A. Yeah. Over there. Page 515 Page 517 1 the records by you? 2 MR. MERMELSTEIN: Objection to form. 3 THE WITNESS: I told her what the, what 4 they were requesting, what it was in detail, 5 what case it was. BY MR. CRITTON: Q Why didn't you give her the authority, why 8 didn't you say you can send whatever records you 9 want? Why did you tell her not to send the records? 10 MR MERMELSTEIN: Objection to form. 11 That's not what she said. 12 THE WITNESS: I told her what, what I 13 needed the records for. 13 Q. did he play a role? 14 BY MR. CRrrTON: 14 A. That, myself. . 15 Q. Did you tell her specifically she didn't 15 Q And what were you feeling bad about 16 need to send the records? Yes or no. 16 yourself for? 17 A. Not that I 17 A. 1 don't know. Ijnst, I just wasn't liking I right. myself 19 22 A. Yes. 23 Q. She's also a female? 3 0. Was it before or after? 24 A. He. 24 A. Before. 25 q: Oh, he's a he? 25 0< 1askajjou to assume — well, let me 32 (Pages 514 to 517) PROSE COURT REPORTING AGENCY, INC.. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be89-47a2-9d44-6a177536c370 EFTA01076752 Page 518 Page 520 strike that. Wot statement that you 6 MR•MERMEISTEIN: Objection to form. 7 • - . THE WITNESS:. No. 8. • BY Does that meet 22 with your recollection? 23 A. Yes. 24 a the first time that you saw 25 — well, let me strike that. You saw Page 519 Page 521 1 2 3 4 5 6 7 8 a A. I need to use the restroom. .9 9 Q. Is that correct? Pardon? 10 10 A. I need to use the restroom. 11 11 Q. Okay. Let me just, just finish this one 12 12 question. 13 Q. Well, if you did tell him, why would you 13 A. Sure. 14. have told him about that? 14 Q. Dr. — you know what, 11 start when you 15 A. I dent know if i told him. 15 get back. 16 16 A Okay. 17 17 THE VIDEOGRAPIIER: Going off the record at • 18 18 4:29 p.m. • • 19 19 (A brief recess was held.) '20 Q. Are both of your parents alcoholics? 20 THE VIDEOGRAPHER: Back on the record at ' • . 21 A. No. 21 4:32 p.m. . 22 Q. Would you have described your mother as 22 BY MR. CRITTON: . • 23 having an alcohol problem? 23 Q. Ms. Doe No. 3, let me start again with 24 24 what I was asking. That way well all be on the 25 25 same stage. 33 (Pages 518 to 521) PROSE COURT REPORTING, AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-be139-47a2-9d44-6af77536c3le EFTA01076753 Page 524 11 Q. You didn't feel comfortable talking to 12 him? 13 A. 14 • 15. 16 17 18 19. . 20 Does that meet with your recollection? 21: 22 0. 23 24 25 Page 525 Do you recall that? A. No, no 14 A. 1 guess. I don't — 15 ' ' Q. You just didn't rentember that;is that A. No. 16 *. correct?. : 17 A. Yeah. 18 ' Do•• on know why 21 Q. Oh, they share the same office? 22 A Y 23 34 (Pages 522 to 525) PROSE. COURT- ItEeORTING.AGENCY; .INC. (- Electronically signed by cynthia hookIns (001 Electronically signed by cynthia hopkIns (001 Electronically signed by cynthia hopkins (001 8d47f015-bo89-47a2.9d44.6af77536c370 EFTA01076754 Page 526 Page 528 O 3. 2 3.. 4 5 6 7 ow that you had a lawsuit pending? a. . MR. MERMELSTEIN: Objection to form. 9 THE WITNESS: No. 10 MR. CRITTON: Okay. I have one other area 11 I would like to go into, and then I think Pm 12 pretty well done. Give me — well, let me show 13 you — 14. What's the next exhibit, 6? 15. THE COURT REPORTER: Yes. 16 16 THE WITNESS: This is 4 and 5. 17 17 (Defendant's Exhibit No. 6 was marked for 18 identification.) 19 BY MR. CItITION: 20 Q. Let me show it to your attorney. Your 21 . answers to the first interrogatories. If you will 22 go to the second to the last page, it appears you're 23 verifying that the answers to: the interrogatories 24 are true and correct. Tell me if that's your 25 signature for these; that is, you're verifying as to Page 527 Page 529 3. the content and your answers to the first set of 2 interrogatories. 3 A. Yes. 4 Q. Go to Question 2. 5 A. Uh-huh. • 6 Q. In 2000 — it starts off — its a 7 question about your employment history. And if - 8 if I understand your q 9 MR. MERMELSTEIN: Objection to form. 10. THE WITNESS: Not when you're seeking years old during 11 help. 11 that time period. Is that the first time you had 12 BY 12 any type of job? 13 A. Yes. , you didn't have a lawsuit seeking 14 Q. Then it appears that at least during 2005, 15 millions of dollars from Mr. Epstein, did you? 15 you had about eight different jobs. .16 • MR. MERMELSTEIN: Objection to form. 16 A. Yes. 17 THE WITNESS: No. 17 Q. All right. Were these all part-time jobs? 18 . BY MR. az= 18 A. Yes. 19 19 Q. Okay. the rder that you had 20 them; that is, w your first job as 21 a hostess? 22 A. Yes. 23 Q. Okay. Did you quit that job or were you 24 At that time you do have a pending lawsuit 24 terminated? 25 seeking millions of dollars aest Mr. Epstein, 25 A. Ouit. 35 (Pages 526 to 529) (561) 832-3500 PROSE COURT REPORTING AGENCY, INC. : Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-be89-47a2-9d44-6af77536c37e EFTA01076755 Page 530 Page 532 9. Okay. And then you did 1 more like her babysitter or groceries and cleaning. It 2 Nice touch. You were a dog sitter? 2 was — it took place at her house. 3 A. Yes. • 3 Q. Oh, you mean she ran the business out of 4 Q. Did you quit that job or were you 4 the house? 5 terminated? 5 A. Yeah. 6 A. I quit. 6 Q. So, you became like her personal — 7 Q. And why d"t the first two jobs? '7 A. Yeah. 8 A. To -- I qui elgotajobata Q. assistant? 9 dog place, and I wanted to go to school to become a A. Pretty much. 10 veterinarian. And I quit that place because it was too Q. So, even though you were getting ten bucks 11 far. 11 an hour, it wasn't — Pm sorry, seven and a 12 Q. To drive? 12 quarter, it wasn't worth it? 13 A. Yeah. Yes. Sony. 13 A. No. 14 Q. You were driving your own car at that I .9. So, you quit there and went to... 15 time? which did what? 16 A. Yes. 16 A. It actually — I think that's thea. 17 Q. Then you worked — went to work at your 17 Q. I'm sorry? 18 aunts restaurant? 18 A. Yeah, Chars the M=. It's 19 A. Yes. 19 Q 20 Q. And is that is 20 A then 21 22 23 A. am? A. Yeah. 21- 22 23 Q. A. Yes. Is it a tanning parlor? Q. Okay. So you would check people in and 24 Q. That's your aunt? 24 out? 25 A. Yes. 25 A. Yes. Page 531 Page 533 1 Q. So she would say good things about you? 1 Q. Got ten bucks an hour? 2 A. I guess. 2 A. Yes. 3 Q. The — you quit 3 Q. Did you quit that job? 4 you went to Why? And is 4 A. I got let go. 5 A. It's ajewelry box — a jewelry box. 5 Q. Why? 6 Q. Working in the mall? 6 A. Because I changed the music in the CD player. 7 A. Yes. 7' Q. And you then got a job at IMM? 8 Q. Were you still working at at the 8 A. Yes. 9 time? 9 . Q. How long did you work there? 10 A. No. 10 A. Three days. 11 Q. And you quit that to work at -- did you 11 Q. Why did you quite that job? Did you quit 12 quit that or were you terminated? 12 or did they terminate you? . . 13 A. I quit. 13 A. I quit 14 Q.' And then you went to 14 Q Why? 15 How long did you work there? 15 A. Because I was just standing there, and 1 16 A. A week or two. 16 didn't want to just stand. 17 Q. Crummy job? 17 w, you had a job animal -- 18 • A. It was telemarketing. I didn't like it. 18 19 . And then you went to 19 A. Yes. 20 20 Q. — in Palm Beach? 21 A. Yes. 21. A. Cana. 22. Q. How long were you there? 22 . 'Q. How long did you work there? 23 A. A couple of months. 23 . A. Oh, a few months. • 24 Q. • Why did you leave there? 24 • • Q. Okay. And why did you — were you 25 A. The location of the place was not -- I was 25 terminated or did ou quit? INELd••••••••.......ast--...tottrealts14.004711•••••••14.1, a 4. 36 (Pages 530 to 533) PROSE COURT REPORTING. AGENCY INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (801 807t0164:44947a24d4444077/53007* EFTA01076756 Page 534 Page 536 1 . A. Yes, terminated. ' 1. ' . Q. And.your is that right? 2 Q. Why were you terminated? 2 . A. Yes. 3 A. I came hi late three times. 3 • Q. How long did you stay at 4 Q. And they said we can't have you bPrance 4 ' A. A year. 5 you're late too often? 5 Q. Why did you leave there? 6 A. Yes.. 6 A. Due to the construction business and the S . And theni you went to 7 economy. Q. They let you go? which is the alarm business? A. Yes 10 A. Yes. 10 Q. Buti. works there? 11 Q. And that's where you were when you were 11 A. Yes. 12 interviewed by the FBI? 12 Q. And I may — I need to ask you this:. Did 13. A. Yes. 13 you tell me that your mom and dad are remarried, or 14 Q. You stayed there or were you terminated or 14 they just live together? 15 did you quit? 15 A. They're engaged. 16 A. I was terminated. 16 Q. How long have they been engaged? 17 Q. Why? 17 A. Christmas. 18 A. It was — I work, I worked for 18 Q. All right. So they're going to get 19 Q. Ise? 19 remarried again? 20 A. a job placement employment. So 20 A. Yes. 21 they only needed me for a short amount of time. 21 22 . All ri t. Then you went to 22 23 ailim the I Number 7 references thatM Can you even remember where 24 A. Yes. 24 A 25 Q. What were you doing? 25 Page 535 Page 537 1 A. Well, I was maintaining the web sites, escrow, 1 Q. Was it — and I think you said it was a 2 HUDs, just, you know. 2 woman? 3 Q. How long did you work there? 3 A. Yeah, it was a woman. 4 A. A while. More than a couple of months. Q. Did you ever ask your mom if she remembers 3 Q. Did you quit or were you terminated? who she took you to? 6 A. I got let gO. 6 A. Yeah, we tried to look for her. 7 Q Why? 7 Q. Number 9. 8 A. The business was not good. 8 ' A. Okay. All ri u. Then ou went tol l 9 Q. Okay. It says: Describe each injury 10 (physical, emotional, mental) for which you are 11 A. Yes. 11 claiming damages in this ease specifying the part of 12 Q. And you got a salary there at 23,000 bucks 12 the body that was injured, the nature of the injury 13 a year. 13 and any injuries you contend are permanent, the 14 A. 14 effects on you that you claim are permanent. Okay. 15 a. WIthal Atlildits 15 That is damages you are claiming in this case. Do 16 A. I got — I mean, yes. 16 you see that? 17 Q. Like health insurance, 401(1c), things lice 17 A. Yes. 18 that? 18 Q. All right. And just take a minute and 19 A. Yes. 19 look at your answer, please, and just tell me when 20 Q.' What, what was your job? You say accounts 20 you're done. 21 payable? 21 A. Okay. 22 A. Accounts payable. 22 Q. All right. You say, you suffered severe 23 Q. So, you would — did you do that over the 23 psychological, emotional, and psychical injuries. 24 computer? 24 Do you know what a psychical injury is? 25 A. Yes. 25 A. Something to do with my head. 37 (Pages 534 to 537) (561) 832-.7500 PROSE 'COURT REPORTING AGENCY,. INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-bef19-47.2-9d44-6af77536c37e EFTA01076757 Page 538 Page 540 1 Q. All, right. By the way, is this your 1 A. To some point 2 answer 2 Q. Is it your testimony that having been 3. • A. I don't — 3 molested at age 13 and having been raped at age 15 4 Q.. — that is, did you, did you come up with 4 are less significant events than your being in 5 all the words that are in Number 9? 5 Mr. Epstein's presence for 20 or 30 minutes -- 6 A No. I had assistance, yes. 6 MR. MERMELSTEIN: Objection — 7 Q. Okay. • • 7 MR. CRITTON: — in June of '04? MR. MERMELSTEIN: Tm going to object to 8 MR. MERMELSTEEN: Objection to form. 9 the extent that it's assistance of counsel. 9 THE WITNESS: Yes. 10 She shouldn't disclose her conversations with 10 BY MR. CRITTON: 11 counsel. 11 Q. Why? 12 BYMR. CRITTON: 12 A. Because I don't feel like I have to worry 13 Q. I don't want to know the conversation, but 13 about those prior incidents anymore. 1.4 would it be a correct statement that at least the 14 Q. Why would you have to worry — but for 15 paragraph that has all your answers in here, that 15 your having filed a lawsuit against Mr. Epstein 16 this was done with the assistance of counsel? 16 seeking millions of dollars, why would you have to 17 A. Correct. 17 worry about that incident at all anymore? 18 Q. All right. And would it be a correct 18 MR. MERMELSTEIN: Objection. 19 statement that these words are not words that you 19 BY MR. CRITTON: 20 chose, but they were done in conjunction with your. 20 Q. Again, that's four years in your past 21 attorneys? 21 Well, it's almost six years in your past now. Why 22 A. No. 22 would you have to worry about that now? 23 Q. That's not correct or that is correct? 23 MR MERMELSTEIN: Objection to form. 24 A. No, I close these words. 24. THE WITNESS: Because I don't have to be 25 Q. Okay. So tell me about — so severe ' 25 afraid of naming into those other people. Page 539 Page 541 1 psychological, emotional and psychical injuries. 1 Unlike Epstein, I can still run into him; I 2 A. That was assisted. 2 could still see him. 3 Q. Ok ri r our ever seeing 3 BY MR. CRITTON: . 4 Mr. Epstein correct? 4 Q. Well, since other than your voluntarily 5 A. What was it? 5 going back to Mr. Epstein's house on three occasions 6 Q. Prioat tr-; ;rig Mr. Epstein in 6 after June of '04, where have you ever seen :7 June of '04, let me strike that 7 Mr. Epstein in person again? B Tm going to ask it a diffei wet way. 8 A. Here. 9 Would it be a correct statement, in your, 9. Q. Okay. Well, that was when you were here 10 your emotional state, your mental state, your 10 for your exam? 11 psychological state, prior to th • 11 A. Uh-huh. 12 12 Q. All right. And it was as part of the • true? 13 i u were here for an exam. You were out 14 A. Before him? 14 ,correct? 15 Q. Yes. Over other events in your life. 15 A. Correct 16 A. Not necessarily. 16 Q. Okay. And he left the building for 17 So when you were molested by 17 reasons -- I actually think he was corning to see me 18 at age 13, you didn't consider that a 18 that day, but that's neither here nor there.. 19 severe psychological and emotional event? 19 our being out having and taking a 20. MR. MERMELSTEIN: Objection to form. 20 you never would have seen 21 THE WITNESS: I don't know. 21 Mr. Epstein, would you? ' 22 BY MR CRITTON: 22 MR MERMELSTEIN: Objection to form. 23 Q. When you were raped at age 15, you didn't 23 THE WITNESS: Novi don't believe that. 24 consider that to be a severe and psychological and 24 BY MR. CRITTON: 25 emotionally troubling event? 25 Q. Okay. Well, if ou ou So ar c‘ Linto 38 (Pages 538 to 541) (561) 832:7500 PROSE COURT REPORTING AGENCY, INC. . Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hookers (601 Eld471015-h089-47a2-9d44-6af77536c37o EFTA01076758 Page 542 Page 544 1 .. him outside — well, let me strike that. 1 BY MR. CRITTON: 2 You were sitting there with our attorney. 2 Q Okay. Other than that one occasion, had :.3 Jessica Arb0ur having a correct 3 you seen him since June — approximately June of • 4 A. Yes. 4 '04 5 during the time that you were having 5 A. No. 6 the cam by Dr. Hall, correct?' 6 Q. —in person? 7 A- Yes. 7 A. No. . 8 • Q. You chose the time that you were going to 8 Q. Okay. And have you seen him since? 9 have the break, true? 9: A. No. 10 A. Yes. 10 Q. You indicate as well in our answer to 11 • • Q. All right. And Mr. Epstein left the 11 ber 9. you say you've had 12 building and got into a car, correct? u've told us 13 A' Yes. 13 about 14 . Q. All right. And what makes you think that 14 None of those three events did you describe earlier 15 you would have seen Mr. Epstein for any other reason • 15 had any relationshto with Mr. Epstein. 16 but for our having chosen a particular time to take 16 So what 17 a d he kft the building? 18 MR. MERMELSTEIN: Objection to form. 18 . . MR. MERMELSTEIN Objection to form. WITNESS: Because he — I work oil. 19. BY MR. CRITTON:' 19 21 ar He lives on Palm Beach. I, I always worry about seeing him. . 20 21 Q.' or your visit to Mr. Epstein? MR. MERMELSTEIN: Objection to form. 22 BY MR. CRITTON: 22 THE WITNESS: Just the way that I feel I 23 Q. Why, dv lynts1 • worry about seeing him? • 23 mean, I don't, I don't know. 24 YOU wbrk in correct? 24 BY MR. CRITTON: ' 25 A .Yeah 25 Q. You indicate you have feelings of Page 543 Page 545 1 Q. Okay? Do you know where his house is? 1 self-blame. What do you mean by that? 2 A. Yet 2 A. That maybe if I would have said something or 3 . Q. All right. And have you seen him since 3 maybe if I would have screamed or something. I — it 4 the time you ve been working? I mean other than 4 wouldn't have happened. 5 during your S have you, have you seen him 5 Q. You mean the first time you were there? 6 in pason since the last time you were at his house? 6 A. Mall. At all. 7 In fact, really the, I guess, the third time that 7 Q. What do you mean, Nat all"? 8 you were at his house? A. At all. At any time that I was over there. .9 A; No. 9 Q. Well, but if you had the feeling of 10 Q. And the only times that you had seen 10 self-blame, and if you had screamed or yelled the - 11 Mr. Epstein in ur whole attire life, other than 11 very first time you were there, why then did you go 12 during • 'n 2009,2010, I don't . 12 back a second, third, and fourth time and take 13 remember -- the day that you saw Dr. Hall, was that 13 people there? • 14 in 2009; last year? 14 MR. MERMELSTEIN: Objection to form. 15 MR. MERMELSTEIN: It was in the Fall of ' 15 Asked and answered numerous times. 16. '09. 16 THE WITNESS: So, do I have to answer? 17 BY MR. CRITTON: . . 17 MR. MERMELSTEIN: Go ahead. You know, 18 Q. Okay. So in the Fall of '09, you had an . . 18 ' we're about a half hour past the time that we, 19 I, who is our expert. You take a 19 we agreed on here. 20 As you're outside having a 20 So you can go ahead and answer the ' 21 Mr. Epstein laves the building that he's had an 21 question, but very little time left, so... 22 . office In for over a year, and you see him; correct? 22 THE WITNESS: Because I was young I 23 A Correct -- 23' wasn't thinking.1 really wasn't. 24 MR. MERMEISTEIN: Objection to fonn. . 24 BY MR. CRITTON: 25 THE WITNESS: — I saw him. 25 Q. You sa fluctuations In wel t and 39 (Pages 542 to 545) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be139-47a2-9d44-6af77536c37e EFTA01076759 Page 546 Page 548 appetite. You had fluctuations in weight and 1 you file a lawsuit against Mr. Epstein then, ma'am? 2 appetite long before you ever met Mr. Epstein, true? 2 A. Because I was scared. I was scared to come 3 A. No. 3 forward. • a So some of the earlier orts 4 Q. For what? Why were you seared? 5 A. !didn't, !don't Icnow• what —.I didn't know 6 what could happen. 7 Q. What's happened? 8 • MR. IVIERNIELSTEIN: Objection to form. MR:MERMELSTEIN: Objection to form 9 BY MR CRITTON: 10 THE WITNESS: Maybe they must have 10 Q Do you think your, your being scared was 11 misunderstood. 11 misplaced? 12 BY MR. CRITTON: 12 A. What do you mean? 13 Q. Okay. And do you consider yourself heavy 13 Q. Well, you said you were scared. 14 now or light, or tight, just right? 14 A. Right 13 A. Like a person? 15 Q. Are you still scared? 16 Q. No, no. We — I'm talking about weight 16 A. Sometimes. 17 gains. 17 .Q. About what? 18 A. I blow. I don't — I don't 'mow. 18 A. 'What he could do next, 19. Q. Do you feel like you're at a good weight 19 Q. What has he ever done to you? What has he 20 right nova 20 ever done to you other than your four voluntary, 21 A. Yeah, sire. 21 consensual visits that you made to his house? 22 Q. Have you weighed more than you do now? 22 MERMELSFEIN: Objection to form. 23 A. Yes. 23 • THE WITNESS: He's made me suffer. 24 Q. Have you weighed less? 24 BY MR CRITTON: • . 25 A. Yeah. • 25 Q. How? Page 547 Page 549 1 1 A. I, I just feel, I feel -- you know, I feel 2 scared. I feel traumatized. I feel I just, I just 3 don't feel comfortable anymore. 4 Q. And you say that's related to Mr. Epstein Q. You, you indicate in Answer 10 that you 5 as distinct from all of the problems you've had with had a loss of earning, loss of earnings, or a loss 6 your estranged husband? of earning capacity. 7 A. Stress and — 7 A. I'm afraid to go to my job and see if he's 8 MR'. MERMELSTEIN: Objection to form. 8. ever going to walk in, or anyone that remotely looks 9 BY MR. CRITTON: 9 like him, I'm afraid, always looking over my shoulder if 10 Q. Pm sorry? 10 that's hitn. 11 A. Stress. Q. Why are you working ittri then? 12 Q. Stress over the lawsuit? 12 A. Due to the economy, because I — that's the 13 MR. MERMELSTEIN: Objection to form. 13 only place I got hired. 14 THE WITNESS: Stress, just this whole 14 Q. Well, if you have a loss of earnings, it • 15 situation. 15 means that you've lost something. Can you describe 16 BY MR. CRITTON: 16 any earnings that you've lost as a result of having 17 Q. Whole situation being the ongoing laitsuit? : 17 been to Mr. Epstein's home?. • 18 A. NO; . 18 • ' , MR. MERMELSTEIN: Objection, form. Paris 19.. Q. What situation then? 19 fora legal conclusion. 20 A. What the, the way that I was — the way that 20 BY MR. CRITTON: 21 this took place, this Epstein case. 21 Q. IS there any money that you can describe 22 Q. Why didn't you file a lawsuit after the 22 that yOu've lost? 23 last time you were at Mr:Epstein's house? Why 23 MR. MERMELSTEIN: Again same objection to 24 didn't you tell your mother and then go hire a 24 form. 25 lawyer in 2004 or 2005 or 2006 or 2007? Why didn't 25 THE WITNESS: I delft know. 40 (Pages 546 to 549) (5'61) 812-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by synth,' hopkins (601 Electronically signed by cynthla hopkIns (601 Electronically signed by synth,' hopkins (601 8d47f016-be89-47a2-ScI44.6a177536c37e EFTA01076760 Page 550 Page 552 BY MR. CRITTON: 1. A Not all the time. 2 Q. You also claim a loss of earnings — of 2 Q. Is it anyone who has gray hair? 3 earning capacity in the future. Why do you 3 MR. MERMELSTEIN: Objection, fonn, 4 believe — and not legally. I'm not, Pm not 4 argumentative. 5 looking for a legal opinion — 5 THE WITNESS: I don't know. 6 Why do you believe you have lost your 6 BY MR. CRITTON: ability to eam money in the figure because of your 7 Q. Well you said, older men, so... 8 basically one-time visit with Mr. Epstein in 2000 -- 8 A. I mean like the same style, the same 9 June of 2004? 9 arrogance, the same persona as he carried, the same 10 MR. MERMELSTEIN: Objection to form. 10 creepy smile. 11 THE WITNESS: Like I said, working at 11 Q. You met — other than seeing Mr. Epstein, 12 where I work, I'm always afraid. 12 I guess on tisthird occasion when he came down the 13 BY MR. CRITTON: . 13. stairs with M., you met him or spent time with 14 Q. What's — how does that affect your 14 him, what, 20 or 30 minute on one occasion? 15 ability to earn money in the future because you went 15 A. Correct. 16 to Mr. Epstein's home? What loss have you 16 Q. Did you ever see him in a sweatsuit? 17 sustained, you believe you would sustained in the 17 A. Yes. 18 . flame — let me ask the question this way. Let me 18 Q. On that occasion? 19 withdraw that. 19 A. No. 20 What ability to earn money in the future 20 Q. Okay. You saw him in a sweatsuit, on 21 do you believe you have lost as a result of having 21 whatsn one occasion when he came down the stair 22 gone to Mr. Epstein's house on four occasions, only 22 withN.? 23 once being with him? 23 A. Yes. 24 A. Because I can't be arotmd old people. 24 Q. That's the only time you've ever seen him 25 Q. But you're around them all the time? 25 in a sweatsult? Page 551 Page 553 1 A. And I can't be around them -- 1 A. And here. 2 Q. I'm sorry. 2 Q. When you were taking youtIMMthat 3 A. — that, you know, wear creepy sweatsuits and 3 one day? 4 look like him and has the same color hair, or you know.. 4 A. Yes. 5 even the same type of car. 5. MR CRITTON: Okay. Got about two more 6 Q. What kind of car does he have? minutes, and then I'm done. 7 A. A Mercedes. 7 BY MR. CRITTON: 8 Q. How do you 'mow? 8 You describe yourself as having lower 9 • A. Because I've seen it numerous times. 9 energy or lower ambition in answer to Number 9. Do 10 Q. Where have you seen it? 10 you see that? 11 A ' At his house and out here. 11 A. In answer to number what? 12 Q. Okay. Well, you said numerous times. You 12 Q. Nine. 13 were at his house four times, so you saw it then? 13 A. Yes. 14.; A. And outside here. 14 Q. Okay. In fact, you — it seems like you 15 .. Q. Okay. There, it was a Mercedes that he 15 maintained a job almost continuously the last few 16 got into that day? 16 years. You lose a job; you get a job right back, 17 A. Yes, sir. 17 correct? 18 Q. Other than those times, have you ever seen 18 A. Not necessarily. I will look for a job, yes. 19 his car? 19 Siloan have you been working at the 20 A. No. 20 21 Q. Okay. And you say the job that you have 21- A. Seven months. 22 right now, you're around older people, true? 22 . Q. All right. Continuously? 23 A. Yes. 23 A. Yes. 24 Q. . Okay. Do you see a lot of people that you 24' Q. Are you looking for another job now? 25 . think look like Mr. Epstein? Is it anyone — 25 A. Yes. ,—ememommummow 41 (Pages 550 to 553) PROSE COURT REPORTING AGENCY, INC.. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47l015-be89-47a2-9d44-6077536c37e EFTA01076761 Page 554 Q. Where? In what line of work? 1 BY MR. CRITION: A. My career field. 2 3 Q. To be a vet? 3 A. Yes. I Q. And what kind of job are you looking for? Q Okay. You said you have corruption of 6 A. Kennel,.a dog bather, groomer, anything. • 6 morals and values. Have you done anything as a Q. Do you think you can earn more money or 7 result of having been at Mr. Epstein's house and 3 less money doing that? 8 seen him really on the one occasion in June of '04 A. Less. • 9 that you believe has lead to a corruption of your 10 Q. But that's something that you want to 10 morals or values? 11 learn more about, so you're willing to take a cut in 11 A. I don't think they are as high as they used to 12 pay? 12 be. 13 A. Yes. 13 Q And this is after you had been with — 14 Q. But before you take a new job — I'm 14 well, I'll save that. 15 sorry, before you quit your existing job, will you 15 Well, et me ask it this way: Prior to 16 make certain that you have another job? 16 meeting Mr. Epstein you had been with approximately 17 A. ru try. 17 ten or II males, correct, before you ever even met 18 Q. Well, would you just quit your job — are 18 Mr. Epstein from age 13? . 19 you living at home now, did you say? 19 A. Not from age 13. 20 A. Yes, I moved back home. 20 MR. MERMELSTEIN: Objection to form. 21 Q. Do you contribute toward the rent, the 21 BY ILNISSEJTTON: 22 electric or anything? 22 Q you would have been age I5? 23 A. No, no. 23 A. Uh-huh. 24 Q. You have no expenses? 24 Q. Fourteen and 15? 25 A. No, l pay for my own, my own bills 25 A. Yes. Page 555 Page 557 Q. But you have no expenses associated with 1 Q. And how do you think Mr. Epstein corrupted 2 the place where you're living? 2 your morals? 3 A. I buy food. That's it. 3 A. Because he's an old man. Q. For yourself? 4 Q. Other than him being an old man, can you A. No. think of any other reason he corrupted your morals? Q. For you and your mom? 6 A. I think he took something away from me that he 7 A. Yes. 7 shouldn't, he shouldn't have had any right to. a Q. And your dad? 8. Q. And what was that? • 9 A. Yes. 9 A. Innocence, youth. 10 Q. Okay. Other than -- and would it be a 10 MR. CRITTON: I have no other questions. 11 correct t before you would quit the — 11 MIt MERMELSTEIN: Okay. 12 A. 12 THE VI:GEOGRAPHER:. Off the record at 5:07 13 Q. that you would have another job 13 p.m. This is the end of Tape 2 and the end of 14 lined up because you would want to stay employed? 14 the deposition. 15. A. I would want to. 15 THE COURT REPORTER: Do you want to order 16 MR. CRITTON: Objection to form. 16 this? 17 BY 17 MIt CRITTON: Yes. 18 Q. 18 MR. MERMESTEIN: I'll take a copy. 19 (Witness excused.) I before you ever met 20 (Deposition was concluded.) 21 Mr. Epstein, didn't you? 21 22 A. No, I don't think so. 22 23 Sginj„; 2, you only really_ 23 after you met Mr. Epstein? 24' 25 MR. MERMELSTEIN22e.c_ chon, form. 25 42 (Pages 554 to 557) PROSE COURT REPORTING •AGENCY INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthla hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-b1189-47a2-9d44-63f77536c37e EFTA01076762 Page 558 Page 560 1 1 DATE Ar4lc 2010 CERTIFICATE OF OATH 2 • - TO JANE DOE NO.3 2 THE STATE OF FLORIDA Siuse S Ilarnelock.Esq:e AITAKELSITIN & HOROWITZ. PA 3 COUNTY OF PALM BEACH I 5205 &soy= Rotolo! 4 Siiit 2218 Mimi floods 3)160 5 5 IN RE Tim Dos Net 2 vs. Epstein I, the undersigned authority, certify that 41 JANE DOE NO.3 personally appeared before me 7 CASE No' 01-ev4011924ARRAVHNSON 8 and was duly sworn on the 6th day of April, Mom late notfot St 66 of 9 2010. Apt 20104w save your clecotkiei in IN a:a...knee owner At Ow dm. 414 ice 10 waive sigashre k is sow malty to sign yew *ohm 11 Dated this 19th day of April, 2010. ow As pre, 4c...27 0.2val k 02,00121 wilt tA 12 Itl6tka l to TIP km* 222 orsisit Plea* read the ScAaning Senecas ortfully 13 hi the cedar the thescrincu with:due :2 errata sheet As )w tad) air depot '.ear 14 thy go a orreakni dim ye. wish h maks 'build 15 be raid cm 04 errata sheet meg page and he • ItIntlf of nil clop DO NOT met on she :4 unsays nett Oti.+4 pm kw mid eta 16 ascsc1/2 4 and noted mazurkas, be no soap .rd at. dwonna Owl end mum One pin ,{1 Cynthia Hopkins, RPR, FPR V ,co do re. rem' mid sign the ukseition 17 Notary Public - State of Florida whim I twimbla ten Ow 010q whit las My Commission.Expires: February 25, 2011 *cat/ been krAwvtd to en atkint ineneKe,a, be Malmo Clakcf the Court Fru wish 18 My Commission No.: DD 643788 town. )a.it Noah^ ii.En yams mow ht the blsel, 19. M do team et itit leses teams sous 20 van burrera ro 21 22 Aplgsge_n:1_42:k_s Cpuhia Heedins, RP& )PR 23 22 I do haby solve my siVuhra 24 24 25 ZS lama bos NO Page 559 Page 561 1 CERTIFICATE 1. CERTIFICATE 2 113E STATE OF FLORIDA 3 COUNTY OF PALM BEACH 2. 3 THE STATE OF FLORIDA 5 I. Cynthia Hopkim, Registered Professional Reporter, Florida Professional Report and Notary 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 certify that I was mnborrced to and did 7 report sad deposition in stenotype; and that the 6 deposition by me given and that the statements foregoing pages arc a one and correct transcription contained herein arc true and correct to the best of $ of my shorthand notes of said deposition. 8 my knowledge and belief, with the exception of any 9 1 finger certify that saki deposition was tal=n at die time and place hertinaLo- ve set forth corrections or notations made on the errata sheet, -10 and Thai the taking of said deposition was commenced 10 if one was executed. and completed as hereinatove set out. 11 11 I further cat that I am not anorney or 12 Dated this day of 12 counsel of any of the psnies, nor anal a relatim or employee of any attorney or counsed et patty 13 2010. 13 comected with the action, nor ten I financially 14 imerested m the action. 14 15 The foregoing confkation of this transcript 16 15 does not apply to any reproduction of the same by 17 any means unless ender the direct control andfor 16 direction of the certifying reporter 18 17 Dated this I 9th day of April, 20(0. 19 JANE DOE NO. 3 Is 19 20 Job #1298 20 21. 21 7449.14-IAS grethia Fleckber, RPFE, PPR 22 22 23 23 • 24 24. 23 25 43 (Pages 558 to 561) :(561) 832-75OOH -PROSE COURT REPORTING AGENCY, INC. . Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signod by cynthia bodkins (601 8d47f0154309-471241/41444•177538e37• EFTA01076763 Page 562 1 ERRATA SHEET 2 IN RE: JANE DOE NO.2 VS. EPSTEIN • • CR: Cynthia Hopldns 3 DEPOSMON OF: JANE DOE NO.3 TAKEN: April 6th, 2010 4 JOB NO.: 1298 5 DO NOTAVIUTE ON TRANSCRIPT - ENTER CHANGES HERE PAGED LJNE e CHANGE REASON 6 7 8 9 10 11 12 13 14 15 16 17 Please forward the original signed meta shed to this office so that copies may be distributed to all 18 parties, 19 Under paialty of pajury, I declare that t have read my deposition and that it is true and correct 20 subject to wry changes in font or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 I 44 (Page 562) PROSE COURT.REPORTING.AGENCY;.:INC-* Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (801 Electronically signed by cynthia honk ins (601 86171016-be89-4702-9d44-60/7636c370 EFTA01076764