Page 332
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. 6
Tuesday, April 6, 2010
10:11 - 12:13
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
•
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Page 333 Page 335
1 APPEARANCES: 1 CONTINUED PROCEEDINGS
2 On behalf of the Plaintiff 2
3 ADAM D. HOROWITZ, ESQ
MERMELSTEIN & HOROWITZ7,11. 3 THE VIDFDGRAPHER: This is the 6th day of
4 18205 Biscayne Boulevard 4 April,210. The time Is approximately
Suite 2218 5 10:11 M. This is the videotape deposition of
5 Mama
Phone:
6 Jane Doe No. 6 in the matter of Jane Doe versus
5 7 Jeffrey Epstein.
7 On behalf of 8 This deposition is being held at 250 South
ROBERT l). CROTON, Et, ESQUIRE Australian Avenue, West Palm Beach, Florida
BURMAN, CRITTON, LUTIliR. & COLEMAN. LIP
9
9 303 Banyan Boulevard 10 My name is Daniel Downey. I'm the videographer
Suite 400 11 representing Visual Evidence, Incorporated.
10 West P rida 33401 12 Will the attorneys please announce their
Phone:
11
13 appearances for the record.
12 14 MR. HOROWITZ: Sure. My name Adam
13 ALSO PRESENT: 15 Horowitz,. I'm counsel for Plaintiff, Jane Doe
14 16 No. 6.
Daniel Downey, Videographer
15 Visual Evidence, Incorporated 17 MR. CRITTON: Bob Critton on behalf of
16 18 Mr. Epstein.
17 19 Thereupon,
18 20
19
(JANE DOE NO. 6),
20 21 Having been first duly sworn or affirmed, was
21 22 examined and testified as follows:
22 23 THE WITNESS: Yes.
23
24 24 DIRECT EXAMINATION
25 25
Page 334 Page 3
1 BY MR. CRITTON:
2 2 Q. Ms. Doe No. 6, we're going to finish your
3 3 deposition today. You understand that?
4 INDEX 4 A. Yes.
5 5 Q. All right. Since you were here on
6 6 February 17th of 2010 are ou currently still
/ EXAMINATION DIRECT CROSS REDIRECT 7 employed by
a Continued 8 A. No.
9 JANE DOE NO. 6 9 Q. All right. You — when you carne here or
10 BY MR. CRITTON 335 10 when you were here on February 17th. In fact, I
11 11 think you were going to work when you left.
12 12 A. Yes.
13 13 Q. Correct?
14 14 A. Yes.
15 EXHIBITS 15 Q. And I think it was, was it your cousin who
16 16 was the supervisor there?
17 17 A. Manager.
18 EXHIBIT DESCRIPTION PAGE 18 Q. She was the manager?
19 DEFENDANTS NO. 4 November 29, 2006 Letter 396 19 A. Assistant manager.
20 20 Q. So, you stopped working, it looks like
21 21 answers to your interrogatories, you stopped working
22 22 sometime in March. When?
23 23 • A. March 12th.
24 24 Q. All right. Which would have been about a
25 25 month aSfter our deposition, correct?
2 (Pages 333 to 336)
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Page 337 Page 339
A. Yes. 1 rob him.
2 Q. Okay. And why did you stop working there? 2 BY MR. CRITTON:
3 A. I got fund. 3 Q. And was he a chug dealer?
4 Q. Why did they lire you? 4 MR. HOROWITZ: Form.
5 MR. HOROWITZ: Form. 5 THE WITNESS: I didn't know. They were
6 THE WITNESS: Because I didn't come into 6 trying to rob him. That's what the cop said.
work. 7 They didn't get into the house so I don't
q BY MR. CRITTON: 8 BY MR. CRITION:
9 Q. Ts that what they told you? 9 Q. tla daknow to be a drug dealer?
10 A. No. Yeah, well, it's because I didn't come 10 A. mother is the landlord or the, she
13. in. 11 works at the office and that's how me, me and him met
12 Q. Okay. And why did you not go into work 12 during.
13 that day? 13 MR. HOROWITZ: He is asking if you knew --
14 A. Because one of my good friends was murdered 14 MR. CRITTON: I heard —
15 early that morning. 15 MR- HOROWITZ: - if you him to be a drug
16 Q. What was his or her name? 16 dealer.
17 A. 17 THE WITNESS: No, I didn't, I didn't know.
18 ell the last name, please. 18 MR- CRITTON: I don't need help but that's
19 A. 19 fine.
20 Q. Oh, 20 MR. HOROWITZ: Form.
21 A. Yes. 21 THE WITNESS: I didn't know.
22 Q. How long had you known Mr. 22 BY MR. CRITTON:
23 A. Since I was ten or I I • 23 Q. Had you ever done drugs with M?
24 Q. And he was a very close friend of yours? 24 A. No.
25 A. Family friend, yes. 25 Q. Are you sure?
Page 338 Page 340
1 And how was he murdered? 1 A Yeah.
2 A. He was shot in his house. 2 Q. So, he was shot and killed that day?
3 Q. And how did you hear about it? 3 A. Yeah.
4 A. My friend Julie called me. 4 Q. And you heard about it. What time were
5 Q. What is Julie's name, last name? 5 you supposed to be at work?
6 6 A. I was supposed to be at my meeting at 12. It
7 Q. Is she one of your good friends? 7 happened around like 9 or 10.
8 A. Yes, sheSnbest friend, 8 Q. In the morning?
9 Q. Okay. , 9 A. Yes.
10 A. Yes, sir. 10 Q. On the 12th?
11 Q. And 11 A. Yes.
12 A. Yeah. I don't know how to spell it. 12 Q. Okay. Did you call your cousin and tell
13 Q. And did she know as well? 13 her?
14 A. Yes. 14 A. Yeah. Well, I went to the, I was supposed to
15 How — he was shot where? 15 go to the meeting. I went and I was crying, and they
16 A. In the chest 16 told me to go home. And I was supposed to go back to
17 Q. And was it, it was a — someone came into 17 work at 5.
18 his house and shot him theft? 18 Q. And did you go back at 5?
19 A. Yeah. They, well, they tried to come inside.. 19 A. No.
20 He struggled with them, wouldn't let them in the door 20 Q. Why not?
21 because his daughter and his fiancee were in the house. 21 A. Because I called my manager. She was in
22 Q. .Okay. Was, was he selling drugs or 22 Chicago, so I had to call my cousin which is the
23 something? Was this drug related? 23 assistant manager. And she couldn't find nobody to
24 MR. HOROWITZ: Form. 24 cover forme, so...
25 THE WITNESS: Yes. They were trziro 25 Q. Cover for you when?
3 (Pages 337 to 340)
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Page 341 Page 343
1 A. For that night, 1 soon after you were fired from
2 • Q why? 2 did you get another job? It looks
3 A. I was supposed to work 3 like at
4 Q. You didn't go in on Friday, the afternoon 4 A. Well, I started working last Saturday but I
5 either? 5 got the job the Thursday before that. So, like two
6 A. No,1— my, the owner, because he 015113, 6. . weeks, ten days maybe.
7 privatelyowned, he told me to go home for the meeting 7 Q. All right. And have, have you been
8 because i was supposed to be there at 12. 8 working there now?
9 Q. And he told you to come back at 5? A. Yeah.
10 A. He didn't tell me to come back. 1 was 10 Q. And is it a 40-hour-a-week job?
11 supposed to come back during'my shift. it was already 11 A. Right now I am only part-lime because i am
12 on the schedule. 12 still training they say, but I have been working
13 Q. Okay. So, did you go back at 5? 13 eight-hour days.
14 A. No. 14 Q. Do you get any benefits with Elt
15 Q. Why not? 15 A. No.
16 A. Because I couldn't go back to work. 16: Q. If you start working there as a MI-time
17 Q. Why not? 17 employee, will you get benefits?
18 A. Because I couldn't be sitting at 18 A. No.
19 thinking what happened in my head. 19 Q. Just the $7.50 an hour?
20 Q. Did call your — anyone and tell inc them 20 A. Yes.
21 that you couldn't come in bersice you were still so 21 Q. Are you doing any other employment at the
22 upset? 22 current time?
23 A. Yeah, yeah. 23 A. No.
24 Q. And that was your cousin? 24 Q. Okay. And your boyfriend. I
25 A. Yeah. No, I called my manager, the manager in 25 he is still working I think heavy machinery or
Page 342 Page 344
1.
2
3
ii.
the morning, or, well, at 12, and she was in Chicago.
So,
call
' cl she %mita do anything 1 would have to
And = said she couldn't find anybody
1
2
3
something?
A. No, he got fired. He got laid off, as a
matter of fact, a little before my son's birthday.
4 which is my cousin. 4 Q. Your son's birthday was when?
5 Q. To replace you at 5? 5
6 A. Yeah.
7 Q. And then you just decided that you 7 A. Yes.
8 couldn't go in — 8 MR. CRITFON: Correct.
9 A. She — 9 MR. HOROWITZ: Of this year.
10' Q. — because you were so upset? 10 THE WITNESS: That's when he turned two.
11 A. Yes. 11 BY MR. CRTTTON:
12 Q. .And then did then say you've been 12 Q. And what happened, he just, they just said
13 fired? • 13 we don't need you any more; you're getting laid off?
14 A. No. My manager called me back and told me 14 A. No. Their whole crew got laid off.
15 that ifs not my immediate family, and that 1have to 15. Q. What's he been doing? Does he get
16 go; ifnot, she's going to have to fire me, so... 16 unemployment?
17 Q. And you said — ' 17 A. Well, he is trying to. They are waiting.
18 A. Yeah. . 18 Q. Is there a wait period or something?
19 Q. — go ahead and fire me? 19 A. No. I think the company is fighting for it
20 A. (Witness nods head). 20 or —
21. Q: Yes? 21 Q. You still get insurance benefits for the
22 A. Yes. . 22 child though under -
23 Q. Affright. And it appears that you then 23 A. No. He got it through the job, I have to —
24 got another job? 24' Q. No, no. That's what I meant, he, he,
25 A. Yes. 25 your, Aaro23sets insurance coverage trout:
4 (Pages 341 to 344)
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Page 345 Page 347
1 child — 1 current time relating to Mr. Epstein or any other
2 MR. HOROWITZ: Form. 2 emotional condition that you have?
3 BY MR. CRITTON: 3 A. No.
4 Q. - stilt rigid? 4 Q. You and talk anymore about marriage,
5 THE WITNESS: What do you mean insurance 5 yes or no?
6 coverage? ' 6 A. Yeah.
BY MR. CRITTON: 7 Q. Any plans yet?
Q. You testified at your last detadjap 8 A. No.
9 that, that he had insurance benefits, l=? 9 Q. Since your deposition have ou seen or
10 A. He has health. 10 spoken with either Jane Doe or M.?
11 Q. Health insurance benefits which were 11 A. Isete funeral.
12 applicable to your son. 12 Q Of
13 A. Through the job. 13 A. Yes.
14 Q. Right. So, he still has those? 14 Q. Okay. Was it a pretty sad funeral?
15 • A. I don't think so since he got laid off. 15 A. Yeah.
16 Q. How big, how big a business is it? 16 Q. And did you feel -- I mean, apparently it
17 A. It's -- I don't know. 17 affected you enough that you didn't want to go to
18 Q. Two people? 18 work?
19 A. I just know he works there. 19 A. Yeah.
20 Q. Is it 20 or 30 people, do you think? 20 Q. Does it still affect you now?
21 A. I don't know. I know he works there on a crew 21 A. Yeah. I think about him a lot.
22 with a couple of people. 22 Q. RAW'S la' you hadstbajgdividuals, you had
23 Q. Tell, tell him about Cobra because under 23 a former boyfriend, Mr. who shot himself,
24 the federal law he is entitled and the employer has 24 correct?
25 to pay it so... 25 A. Yes, but that's different.
Page 346 Page 348
1 A. He was -- 1 Q. And how is that different?
2 Q. He's not, he is not getting it? 2 A. Because someone took from his
3 A. He was paying his health benefits out of his 3. two-year-old daughter. She was right behind him when he
4 check, so... 4 was shot. They took him from her.
5 Q. So, the company didn't pay it? 5 Q. Okay. And how does that make you feel?
6 A. He was paying co-fees for it, so I don't — 6 A. It's wrong.
7 co-pay, 1 don't think. 7 Q. Of course it's wrong, but how does it make
8 Q. Tell him to still check. Have you seen, you feel?
9 since your deposition on Felnuaty 17th, 2010, have 9 A. That just -- I don't know, just I could lose,
10 you seen any psychologist or psychiatrist, mental 10 you know, my family or anybody quick. It just didn't --
11 health counselors for any reasons relating to 11 it doesn't feel real.
12 Epstein or any other psychiatric or psychological 12 Q. Okay. And, and because the sante thing
13 issues? 13 could happen with you or it could happen with
14 A. Since the last time I seen you? 14
15 Q. Yes, ma'am. 15 A. It could happen to anybody. They, they didn't
16 A. No. 16 even, supposedly they didn't even know him. That's what
17 Q. Have you seen any physicians for any 17 the cops say. They didn't even know him that they just
18 reason? 18 heard that he was doing something and went and knocked
19 A. No. 19 on the door.
20 Q. Medical doctors, medical, been to an 20 Q. You said "they, they heard- that he was
21. emergency room for any reason? 21 doing something; the people who shot him?
22 A. No, no. 22 A. Yes.
23 Q. And you have no — do you have any 23 Q. What did they hear? What did the cops
24 appointments to see a psychologist or psychiatrist 24 say?
25 or a mental health counselor for any reasons at the 25 A. The cop said that they heard that he was, had
5 (Pages 345 to 348)
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Page 349 Page 351
I money or he was dealing drugs. I don't know. 1 you were in the car accident and thou t she
2 Q. So, that's why they purportedly broke into 2 might die, the events with they
3 the house? 3 are all --
4 A. They didn't break in. They tried. 4 A.
5 Q. Oh, and they just then shot through the 5 Q. I am sorry, — all seem to
6 door? 6 a significance impact on you?
7 A. He was standing at the door fighting with them 7 MR. HOROWITZ: Form.
8 because they were trying to get into the house. 8 BY.MR. CRITTON: •
9 Q. Oh, was he actually outside of the house? 9 Q. Is that true?
10 A. He was — he answered the door because they 10 A. I mean he just died like two weeks ago.
11 knocked and they had a gun and tried to get into the 11 That's why it has an impact on me. It is still fresh.
12 house, and his daughter was behind him. 12 Q. Are y • that the events
13 Q. Did go with you to the funeral? 13 surrounding having committed suicide
14 A. Yes. 14 so close, so close to you, no longer has an effect
15 Q. And you saw Jane Doe there. Did you talk 15 on you?
16 to Jane Doe at all? 16 A. I didn't say that. I'm just, you blow, I mean
17 A. No. 17 it's different when somebody steals their own life, and
18 Q. You just saw her there? 18 when someone gets their life stolen from them. It's way
19 A. Yeah. 19 different.
20 Q. How about have you, have you spoken with 20 Q. You mean a suicide versus -- •
21 her separate and apart from seeing her at the 21 A. Yeah.
22 funeral? 22 Q. — versus a random murder?
23 A. No. 23 A. It's way different, yes.
24 Q. Have you talked to M. at all? 24 Q. Which do you consider more, lice,
25 A. No. 25 traumatic from your perspective?
Page 350 Page 352
1 Q. Did you -- the ex with or what you 1 MR. HOROWITZ: Form.
2 have at least seen with MI pretty 2 THE WITNESS: It's all pretty traum —
3 traumatic for you? 3. sad, you know, that this had to happen to good
4 A. Yeah. It just hurts you know. It's wrong. 4 people but it's what happens.
5 Q. Had, had any nightmares about it or — BY MR. CRITTON:
6 A. No. 6 Q. The incident with your mother when you
7 Q. Had any trouble sleeping? 7 were in the automobile accident back in 2004, does
8 A. No. I just think about him, you know, when 8 that still bother you as well? Well, let me strike
9 Fm in my neighborhood or go by his house or something. 9 that The accident had an impact on you at the time
10 Q. Did you know his parents? 10 certainly, correct?
11 A. Yeah. 11 A. Uh-huh.
12 Q. Okay. And did you go back to the house 12 Q. And you found that very traumatic at the
13 for the reception 13 time?
14 A. Yeah, yeah, I've been at — 14 A. Yes.
15 Q. Or like the wake afterwards? 15 Q. Okay. Had trouble sleeping, thought your
16 A. I have been at her house for like 10 days now. 16 mother might di; thought she could be taken from
17 Q. Everyday? 17 you as well?
18 A. Yeah. 18 A. Yeah.
19 Q. Okay. And how is the mother doing? 19 Q. Okay. And that's part of the same issue
20 A. She's actually keeping everybody together. 20 you have about driving or certainly driving on 1-95
21 Q. Does he have other brothers and sisters? 21 or an interstate or a toll road, correct?
22 A. Yeah. 22 A. Yeah.
23 Q. From listening to your testimony on 23 Q. Tell me what a typical day is for you now?
24 tua , 17th N s. Doe, events like what happened to 24 What do you do, excuse me, on a typical day?
25 what happened with your mother when 25 A. Go to work.
6 (Pages 349 to 352)
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Page 353 Page
And do you have a regular, excuse me, at 1 stay with her the whole day?
2 do you have a regular shift? 2 A. Yeah, until I get off.
3 A. Yeah. Igo in at 8. 3 Q. And then you go and pick him up?
4 Q. Until when? 4 A.. Yeah.
5 A. Well, I can leave from 2 to 4. Depends how 5 Q. And when you go pick him up, then you go
6 busy we are. 6 home?
7 Q. All right. Is it your choice or the 7 A. Yeah.
8 managers? 8 Q. Okay. And then what do you do?
9 A. Well, I can — like I said it depends how busy 9 A. Make dinner.
10 we are. 10 Q. All right. And what, watch TV?
11 Q. So, if it's not busy, you can say I ern 11 A. Yeah. We hang out. He usually watches Elmo
12 leaving? 12 'till -
13 A. Yeah. 13 Q. Your son?
14 Q. And if it's busy, then they expect you to 14 A. Yeah.
15. say? 15. Q. All right. And you hang out until you go
16 A. Yes. 16 to bed around what time?
17 Q. Okay. Which do you work at? Where 17 A. He goes to sleep at like 8. And then well
18 is the location? 18 watch some TV and :4) to sleep.
19 A. Lake Worth and log. 19 Q. Okay. and you are still living
20 Q. All right. So, when you're not working, 20 together?
21 so you get up, you get up in the morning and take 21 A. Yeah
22 care of your baby? 22 Q. Okay. What's doing now since he got
23 A. Yeah, well, I bring him to my mom's so I can 23 laid off?
24 get ready to work because I have, I wake up at 7 and be 24 A. Fixing our house.
25 at work by 8. 25 Q. lie Is working around the house?
Page 354 Page 356
Q. Do you feed, feed your son, isn't it? 1 A. Uh-huh.
2 A. Yeah. Well, he is just now getting — when I 2 Q. Yes?
3 bring him over there, he is just getting up. So he is 3 A. Yes.
4 going to take -- 4 Q. Is he looking for other work as well?
5 g Does your morn then feed him? 5 A. Well, yeah, in between trying to deal with his
A. Yes. 6 unemployment.
7 Q. Does she work at 7? 7 g Okay. So, he is trying to get his
8 A. Yes. 8 unemployment benefits, correct?
9 Q. Is she, what — who does she work for 9 . .A. Yes.
10 again? 10 Q. And then working on the house?
11 A. AAffordable Insurance. 11 A. Yes.
12 Q. Okay. And when she goes to work, does she 12 Q. Has he applied for any other jobs?
13 work out of the home? 13 A. 1 think he went to some interviews, yeah, like
14 A. No. 14 the USD Meat.
15 Q. And who takes care of your son when — 15 g I'm sorry?
16 A. She drops him off at my aunt's house. 16 A. The Direct Meat or whatever, the USD Meat or
17 Q. And her name is? 17 something.
18 A. 18 Q. All right.
19 Q. Can ou s it for me? 19 A. And some other place on Lake Worth. I didn't
20 A. 20 go.
21 Q. Where does she live? 21 Q. But nobody has at least hired him as of
22 A. 22 todays date?
23 Q. In Lake Worth? 23 A. No.
24 A. Greenacres. 24 Q. Okay. In your answers to the second
g umennon2.... All let. And then does, does the son 25 interrogatories it appears you have a, you have a
7 (Pages 353 to 356)
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MySpace since 2008? 1 like 17.
A. Yeah. 2 Q. And you bank — how long have you been
Q. Okay. Do you use it on a regular basis? 3 banking? How long have you had a bank account?
A. Yeah. 4 A. Since, yeah, I was like 18.
Q. And you, you have a Facebook page, but 5 Q. Did you ever have like a savings account
what you haven't activated it yet? 6 or something that your parents set up or anyone set
A. No. 7 up for you?
Q. You haven't punched in the profile? 8 A. Well, the bank is me and my mom share the
9 A. Yeah. I haven't I think I signed up for it 9 same.
10 but I never went on it. I don't know how to use it. 10 Q. Do you have the same bank account?
11 Q. And you actively use your MySpace? 11 A. Yes. It's a joint bank account.
12 A. Yeah. 12 Q. Is it a checking account?
13 Q. And do you use that every day? 13 A. Yeah.
14 A. Maybe every other day. 14 Q. Okay. And why do you and your mom share
15 Q. All right. And you correspond with your 15 the same account?
16 friends or family? 16 A. Because she has three accounts with Chase
17 A. Yeah. 17 already, so to add on, it would be easier.
18 Q. What kind of computer do you have? 18 Q. Okay. So, she has her, two of her own
19 A. Well, right now I have a Dell laptop. 19 accounts and then she has an account with you?
20 Q. Okay. And do you take that with you to 20 A. Yes. She —
21 work? 21 Q. And you said — sorry.
22 A. No. I have my phone. 22 A. She added my account to hers.
23 Q. Okay. And what kind of phone do you have? 23 Q. You can use that account. It's basically
24 A. IPhone. 24 your account. It just happens to be in both your
25 Q. And how long have you had an iPhone? 25 names?
Page 358 Page 360
A. Since November of last year. 1 A. Yeah.
2 Q. Okay. So, you're on an AT&T plan? 2 Q. I may have asked this before, so I
3 A. Yeah. 3 'apol ting Have you ever talked
Q. And the iPhorte, is that, are you and 4 with ; that is, is she aware that
5 on the same program or the same plan? 5 you're a Plaintiff in a lawsuit?
A. No. 6 A. (Witness shakes head.)
7 Q. Okay. And do you pay for your own plan? 7 THE COURT REPORTER: Is that --
8 A. Yeah. Well, I share a plan with my dad. It's 8 BY MR. CRITFON:
9 a family plan. 9 Q. No?
10 Q. How much does that cost you a month? 10 A. No.
11 A. One hundred bucks. 11 also listed M
12 Q. And your laptop, did you buy — how old a 12 , as one of your closest friends over
13 laptop is it? 13 the last four or five years. Is she aware you are a
14 A. The laptop bought in January of this year. 14 Plaintiff in a lawsuit?
15 I'm malting payments on it. 15 A. Yeah, she knows something about it
16 Q. Do you have credit cards? 16 Q. Okay. And how does she know about it?
17 A. Yeah. 17 A. Because last time I came here, I told her that
18 Q. Okay. Which credit cards do you have? I 18 I had to, what I had to do.
19 am not going to ask you for numbers but what credit 19 Q. Okay. And what, I mean that you had to
20 cards do you have? 20 testify?
21 A. I got Capital One, Wal-Mart and that's it, and 21 A. That I had to —
22 I have a bank card. 22 Q. That I was asking you questions?
23. Q. How long have you had credit cants, 23 A. — go downtown with my lawyer. And I
24 • Ms. Doe No. 6? 24 explained to her that I was in a lawsuit and that I
25 A. My...dadFt me first credit card when I was 25 would tell her about it later.
Cein.
8 (Pages 357 to 360)
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1 Q. So, she doesn't know anything about why 1 drives around, too. I mean, I hang out with my son most
2 you're in a lawsuit? 2 of the time, yeah.
3 A. No. 3 BY MR. CRT'S:
4 Q. Have you, have you ever been in a lawsuit, 4 Q. Does do things with you and your
5 other than this lawsuit have you ever been in a 5 son, too?
6 lawsuit for anything before? 6. A. Yeah.
7 A. No. 7 Q. Okay. So, he is a pretty active father?
8 Q. Was your mom involved in a lawsuit when 8 A. Yeah.
9 they had that automobile accident with the semi? 9- Q. All right. Was there a time — well, let
10 A. No. 10 me strike that. You, you've testified that you went
11 Q. Did that turn into a lawsuit? 11 to Mr. Epstein's home on one occasion, August 8th of
12 A. No. 12 '04, correct?
13 MR. HOROWITZ: Form. 13 A. Yeah, that was one time.
14 BY MR. CRITFON: 14 Q. Prior to the time that you were at
15 Q. Was a claim filed or do you know? 15 Mr. Epstein's home, I want to talk a little bit
16 A. No, no. 16 about some background that you, that you provided or
17 Q. Your mom never filed anything? 17 that I provided at least to your attorney with
18 A. No. 18 regard to issues that you had with, issues that you
19 MR. HOROWITZ: Form. 19 had with police or law enforcement. Okay.
20 BY MR. CRITTON: 20. Have you had a chance to look at a bunch
21 Q. Was the car repaired? 21 of police reports?
22 A. No. 22 A. No.
23 Q. Was it drivable? 23 Q. Have you looked at any police reports?
24 A. No. 24 MR. HOROWITZ: Form.
25 Q. What happened to it? 25 THE WITNESS: About who?
Page 362 Page 364
1 A It was junked. 1 BY MR. CRITFON:
2 Q. Okay. And how do you know that she didn't 2 Q. About anything?
3 file a lawsuit? 3 MR. HOROWITZ: Form.
4 A Because she didn't, because I know she didn't. 4 THE WITNESS: About my case when I was on
5 She was filing for bankruptcy. 5 house arrest?
6 Q. Your mom was at the time? 6 BY MR. CRITTON:
7 A She just filed for bankruptcy in 2000 or 2002 7 Q. Okay. Have you looked at some of those?
8 or something like that. It was like six, seven years A. Not recently.
9 ago. But, yeah, she was filing for bankruptcy. The car 9 Q. Okay. When you say not recently, did you
10 was junked. The tires blew. It wasn't nobody's fault. 10 look at it before you were deposed in February?
11 Thafs what they said. 11 Before I, we started your deposition in February,
12 Q. Okay. A typical day that you told me 12 did you have a chance to look at that?
13 about going to work, take your son to your mom's and 13 A. No.
14 then son goes to your aunts. You work, pick up son, 14 Q. Okay. Do you remember an incident that at
15 you watch a little TV, get dinner ready, talk, I 15 least you were involved in where you were followed
16 assume, with and you guys go to bed; is that 16 into the woods and, by a number of girls and were
17 pretty much Aug you've been doing the last couple 17 attacked and threatened back in August of '03?
18 of years? 18 MR. HOROWITZ: Form.
19 MR. HOROWITZ: Form. 19 • THE WITNESS: I was followed into the
20 BY MR. CRITTON: 20 woods?
21 Q. Since your son's has been born? 21 MR..CRITION: Right.
22 . A...No. I we take him, we went to the zoo 22 THE WITNESS: Was that at school?
23 last week with daughter, his wife. I take him 23 BY MR. CRITTON:
24 around the neighborhood sometimes in his little wagon, 24 Q. Apparently you were on your way home from
25 his little car, his little Power Wheels car that he 25 middle school. Do you remember that?
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A. Yeah. 1 finish doing my laundry, and there was some guy
Q. All right. And what happened, what 2 in my drier looking through my clothes, and he
3 occurred on that occasion? 3 turned around he had my drawers in his mouth.
A. Nothing. They pushed me around and was just 4 BY MR. CRITTON:
talking and that's it, and we didn't even fight. 5 Q. Your Underwear?
▪ Q. Okay. Then why, why did you report it? 6 A. Yes.
The only way, I assume the people who came after you 7 Q. And what did you do? Did you scream?
1 wouldn't have called the police to report that they 8 A. Nothing. I went back inside.
9 attacked you? 9 Q. Did you yell?
10 A. The school police. 10 A Yeah. I went back inside and I told my
11 MR. HOROWITZ: Form. Wait for his 11 parents, and they came outside and he was gone.
12 question. 12 Q. Did they find the person?
13 BY MR. CRITTON: 13 A They all went looking for him. I don't think
14 Q. Let me finish my question. I, I assume 14 90.
15 that the girls who attacked you wouldn't have called 15 Q.. Did the police come?
16 the police. So, how was it that the Palm Beach 16 A. I don't remember..
17 Sheriffs office became involved in August of '03 - 17 Q. Okay. !asked you to assume that there
18 MR. HOROWITZ: Fenn 18 is — do you remember —.
19 BY MR. CRITTON: 19 A Yeah.
20 Q. — as a result of that incident? 20 Q. -- looking at a police report about it?
21 MR. HOROWITZ: Form. 21 A. No. I didn't ever look at the police report.
22 THE WITNESS: Because the reason the fight 22 If you got one, ! assume there was one mat
23 broke, got we there is a school 23 Q. All right. And did the police come and
24 police and Dr. (phonetic) that would 24 interview you at all?
25 drive wound on the golf course or on the golf 25 A I don't know. I was 13.
Page 366 Page 368
1 cart and watch all the kids walk home. 1 Q. You can answer yes or no. Again --
2 So, they heard about what's happening, 2 A I don't arum nber.
3 because we're what, 13, 12 years old, a bunch 3 MR. HOROWITZ: Just say —
4 of little middle school kids. They were all 4 MR. CRITTON: Let me just -
5 loud, so the school police made a report. 5 MR. HOROWITZ: There you go.
6 I don't even remember that. I don't 6 MR. CR]TFON: I don't know what you
7 remember talking to no cops or nothing. 1 7 remember or what you don't remember. And
8 remember walking home, going to Wendy's and 8 therefore, when I'm asking you a question,
9 getting picked up. 9 don't get upset atme because I wasn't there at
10 BY MR. CRITTON: 10 the time. Do you understand that?
11 Q. Okay. And who picked you up? 11 THE WITNESS: Yeah.
12 A. My mom like always. 12 MR. CRAYON: All right. So, if I am
13 Q. All right. Do you remember another 13 asking a question, it's because I don't know
14 instance in '03 where you went into a shed and there 14 what the answer is most of the time. All •
15 was a, I guess you were doing your laundry and there 15 right?
16 was some man in the shed? 16 THE WITNESS: Yeah.
17 A. Yeah. 17 BY MR. CRITTON:
18 Q. Okay. And I would ask you to assume that 18 Q. So, you don't remember talking to the
19. at least the police reflects that it was on 19 police at all, is that correct?
20 February, I'm sorry, r Tell me what 20 A No, I don't remember.
21 you remember about that incident. 21 Q. Okay. Do you remember an incident in, an
22. A I went — 22. in November of 2003 between yourself and
23 MR. HOROWITZ: Asked and answered, but go 23 laetic)? Do you remember a person
24 ahead. 24 named
25 THE WITNESS: I went to the shed to go 25 A. What happened? I don't --
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Page 369 Page 371
1 MR. HOROWITZ: Bob, can you share that one 1 trust?
2 with me. I am not sure that — 2 A. I don't — what do you mean by that?
3 MR. CFUTTON: I sent you everything. 3 Q. Well, would you, would you, if you had a
4 MR. HOROWITZ: No. I understand, but can 4 problem, if you had an issue, would you call that
you 5 you thought you needed to talk to the police, the
MR. CRTITON: Unfortunately, I have 6 police is someone that you felt that you could call,
7 written all over all of these. 7 dial 911 and tell them if you had a problem or
8 MR. HOROWITZ: Okay. 8 somebody had done something to you that you thought
9 BY MR. CRTFT'ON: 9 was wrong or illegal or inappropriate?
10 Q. This is -- it happened, apparently you 10 A. If I had an emergency, I would call 91i .
11 were struck in the eye by Ms. You were 11 That's all. That doesn't make any sense.
12 talking with her boyfriend, and you-all, the two of 12 Q. All right. Well, did you feel like you
13 you started fighting. Does that ring a bell with 13 could tell the police what had happened in at least
14 you at all? 14 each of these dime instances, and they could
15 MR. HOROWITZ: Form. 15 evaluate whether what you were saying was hue or
16 TliE WITNESS: Yeah. Man, girls. She 16 not?
17 . thought I was talking to her boyfriend, and she 17 MR. HOROWITZ: Form.
18 came and confronted me about it and started 18 THE WITNESS: In two of those incidence,
19 trying to fight with me so. 19 or I know one of them. I didn't talk to the
20 BY MR. CR1TTON: 20 police. Do you have any daughters? I mean,
21 Q. Again, the Palm Beach Police were called 21 like, come on. Girls get into fights all the
22 again. 22 time because other girls are talking about them
23 A. Yes. 23 and it's middle school.
24 Q. So, did you have to give a statement to 24 BY MR. CRiTTON:
25 the police? 25 Q. All right. So, its pretty common for
Page 370 Page 372
1 A. Yeah. 1 middle school girls to get in fistfights?
2 Q. All right. And did they take err/ action 2 A. Yeah.
3 at that time? 3 Q. All right. And that's certainly been your
4 MR. HOROWITZ: Fonn. 4 experience?
5 THE WITNESS: I don't know. They were 5 A. I mean, all, you don't watch the news like
6 saying that they were going to press charges on 6 there was girls that took a girl in the house and, ilke,
7 me. 7 beat, there were like three of them that beat her up
8 BY MR. CRITTON: 8 inside the house. 1 mean, like, come on. The girls do
9 Q. Were any charges ever pressed? 9 it all the time. ifs not like, ifs not — it wasn't a
10 A. I don't think so. 10 big deal. I don't see why you're making a big deal out
11 Q. Okay. So, at least, I mean we've talked 11 of it. Girls will be girls. They cat fight.
12 about, these may not be all of them but an incident 12 Q. All right. And so at least in your
13 in August of '03, another incident in March of '03, 13 experience when you were in middle school pretty
14 third incident now in November of '03. Are those, 14 common for girls to get into fights and have yelling
15 at least in those three instances, the police were 15 matches or fistfights with each other and then the
16 called so you had to deal with the police. Correct? 16 next day or a few days later they are friends again?
17 MR. HOROWITZ: Fonn. 17 A. Yeah. Exactly. •
18 THE WITNESS: Yeah. 18 Q. Okay.
19 BY MR. CIUTTON: 19 A. Exactly how it goes.
20 Q. All right. And you knew, did you consider 20 Q. When you were in middle school did you
21 the police to your friends at that time? 21 get, did you get to make choices about classes that
22 A. No. 22 you were going to take?
23 Q. Did you consider the police to be bad? 23 A. No.
24 A. No. 24 Q. You had to go to certain classes?
25 Q...a.SomeoneMat you would Mist or wouldn't 25 A. Yeah.
-.vs...—.
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1 Q. It was all a structure? 1 Q. Right?
2 A. Yeah. 2 A. Yeah. That's what skipping school is.
3 Q. All right. And then as to, in terms of 3 Q. All right And if you had skipped, if you
4 your attendance at school, did you consider 4 had skipped school, you had to make a decision,
5 yourself, did you attend on a pretty regular basis 5 right? You had a choice to either, Ism going to go
6 or were you pretty truant? If I say, if I use the 6 to school today or I am not going to go to school.
7 word truant, does that mean anything to you? 7 A. Not really. It was a group ofkids, either
8 A. like - 8 they were skipping — I wasn't skipping by myself. It
9 Q. You don't go to school. 9 wasn't like l was, hum, maybe l just don't want to go to
10 A. Yeah. 10 school and I am going to go sit in this bush by myself.
11 Q. That is you skip school. Somebody who 11 it wasn't like that.
12 skips school would be considered truant 12 Q. You didn't have to sit in a bush. I mean,
13 A. Yes. I did that a lot. 13 you can —
14 Q. And, and did you do that during middle 14 A. I mewl, where else was I going to go? 1
15 school? 15 wasn't going to go home.
16 A. That's the only school I went to. I didn't go 16 Q. Why not, ifyour mom wasn't there?
17 to high school. 17 A. She comes home for lunch.
18 Q. That's right. So, by the time you, you 18 Q. Okay. So, you knew she came for lunch and
19 were in middle — or because you didn't go to high 19 if you sldpped
20 school, in middle school when you skipped school, 20 A. Yeah.
21 how often would you skip — let me start again. 21 Q. Let me finish the question. So, you knew
22 That was an awful question. 22 during middle school, 2002,2003, that if you
23 How often would you skip school when you 23 skipped school and you stayed home, mom, you would
24 were in middle school? 24 see mom at lunchtime. So you couldn't obviously
25 A. I don't know. 25 stay there, right?
Page 374 Page 376
1 Q. A third of the time, a half of the time? 1 A. Yeah.
2 A. Idon't know. 2 Q. And in terms of whether you were going to
3 Q. Once in a while, once a week? 3 skip school or not, and would you coordinate that
4 A. Maybe like once a week, once in a while. I 4 with your friends or would you get to school and a
5 don't know. I don't remember. 5 bunch of people would just say, hey, lets not go
6 Q. And if you were going to skip school would 6 today?
7 you go off to school and then just; that is, your 7 A. Yeah, that's how skipping school works.
8 mom or your, you know, whoever you were living 8 Q. And so, but it would be your choice?
9 who were you living with at that time, your mom? 9 A. I guess, yeah.
10. A My mom. 10 Q. That is, and you would have to make a
11 Q. Okay. Your mom was going to work? 11 voluntary decision, I am either going to go to
12 A. Yes. 12 school today or I am not going to go to school,
13 Q. She'd go to work and she would send you 13 right?
14 off to school? 14 A. Yeah, pretty much.
15 A. Yeah. 15 Q. All right. And if you didn't go to
16 Q. Okay. Except sometimes you wouldn't go? 16 school, you know that that was wrong because you
17 A. Yeah. 17 were supposed to be in school, right?
18 Q. All right. If you didn't go would you 18 A. Yeah, I guess.
19 stay home? 19 Q. Do you remember in May of 2000, May 20th
20 A. No. 20 of 2004 that you were punched in the head, a friend
21 Q. Where would you go? 21 punched you in the forehead with a closed fist
22 A. To whoever I was skipping with. 22 Again another police report was filed. Do you
23 Q. And if you, if you skipped school, you 23 remember that?
24 knew that you were supposed to be at school, right? 24 A. No, I don't remember that.
25 A. Yeah- 25 But consistent kind of with
4
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Page 377 Page 379
1 what had happened in the past? 1 he is 24 and I am 19, like, we don't like the same
2 A. I don't even remember what you're talking 2 stuff We just don't get along. It's just brother and
3 about. 3 sister.
4 Q. Well, see if this refreshes your 4 Q. All right. Well, every time that, is it
5 recollection is that it vias-.imr mothers name is 5 your testimony that every time there was a fight
6 how do ou that, 6 between a brother and a sister in the neighborhood,
7 A. 7 the police would show up and fill out a report?
8 Q. called the police. She 8 A. There has been a lot less that they have shown
9 advised that het daughter had a verbal argument with 9 up for.
10 a friend for some unknown reason and the friend's, 10 Q. If you thought you had a problem that you
11 the friend had punched you in the forehead with her 11 needed to discuss with the police or something
12 fist. Okay. 12 illegal had happened or inappropriate happened, at
13 The person apparently lived in Tavares 3 least the police were in your neighborhood enough
14 Cove mobile home. Grabbed you by the arm, hit you 14 that you could call the police or talk to the police
15 with a closed fist. Again, just kind of a routine 15 and report it to them, right?
16 event for you in middle school during that time? 16 MR. HOROWITZ: Form.
17 A. I don't is there like a name of the person? 17 MR. CRITTON: Based on what you told me.
18 I don't. 18 THE WITNESS: I wouldn't walk up to them
19 Q. No. They have them blacked out. 19 and start talking to them, no.
20 A. See my mom called. I mean, like, she's my 20 BY MR. CRITTON:
21
22
23
mom.
Q. All right. But you don't remember
anything about that?
21
22
23
Q. Why not? If you thought someone had done
something inappropriate to you or illegal or
improper, you could certainly if the police were in
I
24 A. No. 24 your neighborhood as often as you indicated back in
25 Q. Okay. Do you remember in April of 2005, 25 the 2003, 2004 time period, you could have gone to
Page 378 Page 380
you and your brother got into a 1 the police and told them, true?
2 fight and the police were called? 2 A. If you read on all those police reports, they
3 A. He's my brother. Oh, my God. 3 were there because of me. So, I'm not going to walk up
4 MR HOROWITZ: Form. 4 to them and be like, hey, I got a probkm.
5 MR. CRITTON: Well, again, there's, 5 Q. Why not?
6 there's a distinction. There is — kids fight 6 A. Perauge they are obviously there for something
7 all the time. 7 that one of us did, so I am not going to walk over there
THE WITNESS: Do you have any other police 8 and start [Wong to them.
9 reports about whole neighborhood. I mean the 9 Q. Well, why? If you thought that somebody
10 cops are always in my neighborhood. They like 10 had done something to you, why would you not feel
11 live there. So, l mean, like they are like 11 comfortable enough to go up to the police and tell
12 there. So, when something happens, they rush 12 them what happened if you thought it was a
13 over. 13 significant event?
14 BY MR. CFUTTON: 14 A. Do you just want me to walk up to some random
15 Q. All right. So, at least as you were 15 cruiser and knock on the window and start talking to
16 growing up the police were in your neighborhood as 16 them? Why don't you try that and tell me how it goes.
17 .a, on basis? 17 They are going to tell you call 9111, call the
18 A. Yeah. 18 nonemergency number, call them, and they will call me.
19 Q. So, at least in the instance where you're, 19 That's exactly what they are going to tell you.
20 they came to your house because you and your 20 Q. Okay.
21 brother, because you and your brother were having a 21 A. They are not going to talc to you. They are
22 fight, that was just again kind of a normal 22 not going to have a Ml blown Dr. Phil conversation
23 occurrence in the neighborhood for you? 23 with you.
24 • A. Not in the neighborhood. I don't — he is my 24 Q. And so from your perspective, if you
25 brother. We don't get alone! is 23 and 1 am — or 25 really wanted the police, if you wanted to report
v2t,rlraia0ZeWi abmgfrefIV
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Page 381 Page 383
1 something that you thought had occurred illegal, 1 couple, but the police again were called. There was
2 illegally to you or some, someone had done something' apparently a fight between your mother, between your
3 inappropriate with you, you had certainly the 3 father about something silly like a bag of chips and
4 knowledge back in 2002, 2003, 2004, 2005 to call 911 4 yourself, and your mother stepped in front of you
5 and report it, true? 5 and got hit by your father instead?
6 MR. HOROWITZ: Form. 6 MR. HOROWITZ: Form.
7 THE WITNESS: I have known to call 91 1 BY MR. CRITTON:
3 since I was like six years old. 8 Q. Do you remember that event?
9 BY MR. CRITTON: 9 A. No. I
10 Q. All right 10 Q. Do you deny it happening or you just don't
11 A. So — I remember it?
12 Q. So, the answer to my question is, yes? 12 A. No. My parents never hit me or never hit my
/3 A- Yeah. 13 brother. No, I don't. I couldn't even believe that if
14 MR. HOROWITZ: Form. 14 you tried to tell me that happened, no.
15 BY MR. CRITTON: 15 Q. Let's see if this refreshes our
16 Q. Do you remember when the police were 16 recollection, is on the the
17 called in June of 2000 -- June 25th of 2005, because 17 police, the Palm Beach Sheriffs Office came to your
18 you threw a rock at a car window at one of your 18 house. The mother and father were fighting. Your
19 friends and broke it? Do you remember that? 19 father reportedly was drunk and was yelling at the
20 A. Yeah. We were playing around and I paid for 20 mother about a bag of chips being left on the
21 that window. 21 counter.
22 Q. Well, the police were called? 22 • You started to yell or you were yelling at
23 A. No, I didn't, I didn't know the police were 23 your father telling him to stop yelling at your
24 called. I know that it was the — we were all sitting 24 mother. And he got in your face and went into your
25 at the office with the manager and everybody. It's her 25 .room, got in your face, yelled at you and attempted
Page 382 Page 384
1 son. And we were all playing around throwing stuff at 1 to hit you, but the mother stepped in between you
2 each other, and I threw a rock and it just tapped his 2 and your father. Do you remember that?
3 window and it shattered. 3 MR. HOROWITZ: Font
4 Q. The rock just tapped the window? 4 THE WITNESS: No.
5 A. Yeah. 5 BY MR. CRITTON:
6 Q. And what, a windshield of a car shattered? 6 Q. Okay. You're not saying it didn't happen.
7 A. No, it was the side window. 7 You just have no recollection of it?
8 Q. Side window in the trailer? 8 A. No, t am saying it didn't happen because
9 A. No, in a car. 9 did that — is that like a police report? How would
10 Q. Oh, that's what l thought you said. So, 10 they know what happened in my house. We didn't come out
11 it's not the windshield. It was the side window in 11 and say anything because I know my mom and I know my
12 a car? 12 dad, and you are tripping. No, there is no way. I
13 A. Yeah. 13 don't know --
14. Q. And you threw a rock? 14 Q. How am, how I tripping?
15 A. Yeah. 15 A. Because that's ridiculous. My dad never hit
16 Q. Just tapped it? 16 me or my brother.
17 A. We were playing around all throwing stuff at 17 Q. How about your mom?
18 each other. I guess it just tapped the window and the 18 A. Newt'. I am telling you never.
19 whole thing spidered. If that's that's the only 19 Q. So, if tha.e is a police repon on this
20 knowledge that I know of breaking a window, because I've 20 you think someone just created it, made it up?
21 never done nothing to nobody's car. If you look I have 21 MR. HOROWITZ: Form.
22 never touched nobody's house or car or nothing. I am 22 THE WITNESS: No. I think that they have
23 not that type of person. 23 the wrong story because that's not what
24 Q. Do you remember in July, on July 20th of 24 happened. I know my dad is a drunk, but he
25 '06 police again were called. I am skipping a 25 always fell asleep before anything. My dad is
t---allt ameetwalVt•SemilaVAnn. 3141. , + , ......wa.weecna t.4" -LV•74abo2.1.1•Sah)Sawdmasi
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1 not, no. . Q. Have you ever been to Data?
2 BY MR. CRITTON: A. No.
3 Q. All right. And the other ones we've 3 MR. HOROWITZ: Asked and answered.
4 covered. Has DCF ever been to your home, Department 4 BY MR.'CRITTON:
5 of Children and Family Services? 5 Q. With regard to Growing Together, I think
6 A. Yeah. 6 you said you were in there a month or two. The
7 Q. On how many occasions? 7 records reflect sometime in April of 2006. Tell me
8 MR. HOROWITZ: Form. 8 how you came to be in Growing Together.
9 TILE WITNESS: I don't remember. I 9 MR. HOROWITZ: Form.
10 remember one time when I got out of my program. 10 THE WITNESS: I don't know. My mom
11 BY MR. CRITTON: 11 brought me there.
12 Q. Which program had you gotten out of? 12 BY MR. CRITTON:
13 A. Growing Together. 13 Q. Okay. Well, what did she tell you?
14 Q. How many different programs have you been 14 A. I don't remember. It was a doctor's
15 in for -- well, what would you have considered 15 appointment or something. She tried to tell me
16 Growing Together, what kind of a program? 16 something dumb, and we went in there and they tried --
17 A. It was a behavioral and drug program. 17 and they locked me in. I was stuck there.
18 Q. How many different programs have you been 18 Q. Okay. As of 2006, you would have been 15
19 in? 19 years old, right, April of 2006?
20 A. None. Just that one. 20 A. Yeah.
21 Q. Have you ever been in 21 Q. And how did your mom get you to go there?
22 A. Yeah. We talked about that last time. 22 A. She told me we were going to like a doctor's
23 That's when were you Baker Acted? 23 appointment or something, and I have never been to — it
24 A. Yeah. 24 was like in Riviera. I have never been out there so I
25 Q. How long were you at Growing Together? 25 didn't know. We just walked in and they kept me there.
Page 386 Page 388
1 A. Like a month, month or two. !don't remember. 1 Q. Okay. And when you walked in, what
2 Q. And who put you into Growing Together? 2 happened? Tell me.
3 A. My mom. 3 A. Nothing. We went into this room and I sat
4 Q. Do you remember the time period you were 4 there and they were like, well, you're staying here,
5 in there? 5 your mom is not taking you. They started explaining to
6 A. No. 6 me.
7 Q. Okay. 11I was to mention 2006, would .7 Q. Okay. And you say "they- how many people
8 that meet approximately with your recollection? 8 were there?
9 A. I guess. I don't know. I know it was like A. Like two.
10 March or that's when 1 went in. It was like March. 10 Q. A man, woman?
11 Q. Did you know anyone else in the program at 11 A. There was a man and a woman.
12 the time? 12 Q. And at that particular time what behavior
13 A. No. 13 drug problems did you, were you having?
14 Q. And is Growing Together, I think you said 14 MR. HOROWITZ: Form, form.
15 Growing Together has been the only program you have 15 THE WITNESS: I was on ME.
.16 ever been in, correct? 16 BY MR. CRITTON:
17 MR. HOROWITZ: Form. 17 Q. Still smoking pot on a regular basis?
18 THE WITNESS: Yeah. 18 A. Yeah. I guess that's why I went.
19 BY MR. CRITTON: 19 Q. I'm sorry?
20 Q. Did you ever go to Carp? 20 A. I guess that's why they sent me there.
21 A. No. 21 Q. Well, l am asking..
22 MR. HOROWITZ: Asked and answered. 22 A. I don't know. I don't sign myself up.
23 BY MR. CRITTON: 23 Q. All right. Because you, probably if your
24 Q. Do you know what Carp is? 24 mom had said I am taking you to a behavioral andfor,
25 A. Yeah. 25 and a drug rehab lace, ou would have said no way?
Want-, 1 1/4 44.i:44W .40
15 (Pages 385 to 388)
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Page 389 Page 391 -
1 A. No. Yeah. 1 regular, no box strings Just mattresses, blanket and a
2 Q. All right. So, when you got there, did 2 pillow and nothing in the room, no drawers, no lamps, no
3 your mom pick up and leave right away or did she sit 3 nothing, and the door is locked behind us.
4 through a couple of hours with you? 4 Q. Okay. Would that be every night?
5 A. No, she left. 5 A. Yep.
6 Q. So, she took you in. She introduced you 6 Q. Would you go to a different house every
7 to the people. Sat you down in a room and said bye? 7 night or would you be at a house for like a week at
8 A. No. She — they sat me down in the room and 8 a time?
9 they closed the door in, like behind me. So, she 9 A. Different house every day.
10 wouldn't be able I wouldn't be able to see her leave 10 Q. Different house every day. Was it the
11 or nothing like that. 11 sante for, I assume you were with three other girls?
12 I don't know what she did afterwards. She 12 A. Two other girls including myself.
13 might have went and talked to them. I don't !mow. 13 Q. Okay. So, there were three of you and you
3.4 There was already people in the room waiting for me. 14 would move from house to house for about seven or
15 Q. And what did you have with you, just the 15 eight weeks?
16 clothes that were on your back and your purse? 16 A. Well, they, yeah, they were still in there
17 A. They brought my stuff already. They had, they 17 when I let That's how the program works.
18 had it set up. 18 Q. And you sleep there at night?
19 Q. Who is "they," your mom? 19 A. Yes.
20 A. My mom and, yeah, the people. 20 Q. And what do you do during the day?
21 Q. Who else other than your mom got you to 21 A. We go back to the program.
22 that place? Did you ever ask her afterwards? 22 Q. The program back in Riviera Beach?
23 A. No, it wasn't my dad because my dad got me 23 A. Yes.
24 out. 24 Q. Okay. And what time does the program
25 Q. Your dad was the one that sprungyou from 25 start, did the program start in the morning?
Page 390 Page 392
1 the place? 1 A. Well, we got up at like 5:30, 6:00. We had to
2 . Well, my dad went — he seen me in 2 be there by 7 because some of the houses were like Port
3 and he told her that he, that I was not going 3 St Lucie or Boca. They were, you know, kind of far.
4 back over there. 4 Q. Okay. So, and who would transport you
5 Q. How, from — let me strike that. W s 5 back to the place?
6 in Growing Together before you got to 6 A. The parents, the parents that we were staying
7 A. Yeah 7 at their house at night
8 Q. And you were in Growing T ether for a 8 Q. And did you, were the, did you understand
9 month or two until you went to 9 the parents themselves had kids in the program but
10 A. Y front Going Together 1 went 10 were staying at other locations?
11 straight to They brought me to 11 • A. Yes.
12 Q. At the time so during the month or two 12 Q. And did you, did the parents feed you at
13 that you were at Growing Together, tell me how were 13 night?
14 you, what was the, what were your accommodations? 14 A. Yeah.
15 A. What do you mean accommodations? 15 Q. Okay. So, would they feed you in the
16 Q. I'm song. Where did you stay? Was it 16 morning?
17 like a bunk-bed? 17 A. We, they would tell us there was cereal in the
18 A. No. 18 cabinet.
19 Q. Did you have your own room? Was it like a 19 Q. Okay. Sp, they'd get you up at 5:30. You
20 big room that had a bunch of beds in it? 20 would eat and then they would transport you to
21 A. No. They, we went to the parents like the 21 Riviera Beach and then you would stay there until
22 parents that put their kids in there, they volunteer 22 what time?
23 their homes and stuff like that. So, we would go to 23 A. Sometimes 7, 8:00.
24 different houses. They would have an empty room with 24 Q. And then you would be picked up again and
25 four beds, four beds, no mattress or mattresses —'rest 25 taken back to the next house?
16 (Pages 389 to 392)
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Page 393 Page 395
I
1 A. Yes. 1 MR. HOROWITZ: Fonn.
2 Q. Did you over slay in the same house more 2 THE WITNESS: Yes.
3 then once? 3 MR. CRITTON: Pm sorry?
4 A. Yes. 4 THE WITNESS: Yes.
5 Q. So, you might stay there for two or three 5 BY MR. CRMON:
6 days or a week? 6 Q. So, when you, when you were at Growing
7 A. No. We would stay there once and then go 7 Together, they were putting you in school but you
8 there maybe next or the week after and go back to the 8 really didn't want to be there because you had
9 same house. 9 already dropped out of school?
10 Q. What was the idea of moving you from house 10 . A. No, I had to go to school.
11 to house? 11 Q. That was part of the program?
12 MR. HOROWITZ: Ram. 12 A. Yes,
13 THE WITNESS: I don't know. 13 Q. Well, I understand that. But from your
14 BY MR. DAMON: 14 choice, if you had had your choice, you wouldn't
15 Q. Did you ever ask? 15 have gone to school because you had previously
16 A. No. 16 dropped out of school, right?
17 Q. Did the program, did they have you doing 17 A. I 'Adult have nothing else to do.
18 things during the day or was it more of a lecture to 18 Q. Becauseyou were trapped in the program?
19 you? 19 A. Yes.
20 A. Well, they would read us the AA book or the NA 20 Q. All right. Did, did the program get you
21 book. We would go to school at 9. We would eat lunch, 21 off of whatever drugs you were on during that six or
22 go back to school, do some more reading or they would 22 seven weeks or eight weeks you were there?
23 sing songs or whatever and eat dinner. 23 A. I started using again afterwards but..
24 Q. Okay. When you were at Growing Together 24 Q. Were you able to get drugs during the time
25 and you were 15 and a half probably at that time in 25 you were there?
i
Page 394 Page 396
1 April of '06, because I think your birthday is in 1 A. No.
2 September -- 2 Q. So, as soon as you got out of the
3 A. Yes. 3 program — and let's see you went from Growing
4 Q. — were you still in school at the time 4 Together and then you went to is that
5 before your mom put you there or had you left 5 right/
6 school? Probably -- 6 A. Yeah.
7 A. I'm not really sure. 7 Q. Did you think the program helped you at
Q. Well, if you were 16 or almost 16, at 15 8 all?
9 you would have been past middle school, wouldn't 9 A. No.
10 you? 10 Q. Let me show you what I will mark as --
11 A. No. I failed sixth grade. I failed seventh 11. MR. CRIITON: Do you know what exhibit?
12 grade. Yeah, I failed a lot, so... 12 THE COURT REPORTER: This is the first one
13 Q. Is that because you didn't try? 13 for this one.
14 A. No, I mean — 14 MR. CR1TfON: For today. I know that.
15 Q. Just didn't like school? 15 MR. HOROWITZ: I'll look it up.
16 A. When I went to school lgot good grades but I 16 MR. CROTON: Let's go off the record for
17 just didn't go. I got zeros. 17 a minute.
18 Q. Got zeros. Okay. So, when you actually 18 THE VIDEOGRAPHER: Off the record at I I :10
19 went to school you got good grades, correct? 19
20 A. Yes. 20 (Defendant's Exhibit No.4 was marked for
21 Q. But you got zero's because you missed, 21. identification.)
22 skipped so much school? 22 (A discussion was held off the record.)
23 A. Yes. 23 THE VIDEOGRAPHER: We're back on at
24 Q. So, you were smart enough to do the work 24
25
1122.
25 but you 'tut choose not to do it?
17 (Pages 393 to 396)
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Page 397 Page 399
1 BY MR. CRITTON: 1 therapists and programs, she didn't have a good
2 Q. Ms. Doe No. 6, have you had a chance to 2 grasp of what your problems were?
3 look at Exhibit No. 4? 3 A. No.
4 A. Yes. 4 Q. During the 2003, 2004, 2005, 2006 time
5 Q. It appears it be a letter that was written 5 period, what did you think your problems were
6 by your mother November 29th, 2006, to Dear Sir 6 A. Didn't think I had a problem.
7 and/or Madam, someone at Growing Together. Do you 7 Q. Okay.
3 see that? 8 A. That's what drug addicts do.
9 A. Yes, Q. So, all you know is is that you didn't
10 Q. Have you ever seen this letter before? 10 think you had any kind of problems, either
11 A. No. 11 behavioral or drug problem?
12 Q. Okay. The letter reflects that at least 12 A. No.
13 based on what your mother said is that you were put 13 Q. Correct?
14 in, or she took you to — you were 15 years old, you 34 A. Yes.
15 were a 15-year-old person, female at the time that 15 Q. You think your mom was a, I guess looking
16 you went to Growing Together and you went in on 16 back now in hindsight, looking back in time, do you
17 March 10th 2006. Does that meet with your 17 think your mom was a pretty good judge of what
18 recollection? 18 problems you were having?
19 A. Yeah. 19 A. Yes. She knew 1had a drug problem, yeah, and
20 Q. I'm sorry? 20 was out of control.
21 A. Yes. 21 Q. She also must have talked to you or you
22 Q. It says that at least your mother's 22 must have expressed to her well, let me ask it
23 perspective was that you had a problem with use of' 23 this way: Do you remember talking with your mom and
24 drugs and your diagnosis with posttraumatic stress 24 expressing to her how upset you were back at that
25 disorder. Would you agree with that? 25 time about the automobile accident that at least
Page 398 Page 400
1 MR. HOROWITZ: Form 1 from your perspective and what you told us you
2 THE WITNESS: I guess. 2 thought she might die?
3 MR HOROWITZ: Would you agree with her 3 A. Yeah. I had, !told her I had dreams about it
4 characterization? 4 and stuff. But it says I had posttraumatic stress
s BY MR CRITTON: 5 disorder, you know. I never — they tried to diagnose
Q. Would you agree, no, would you agree with 6 me with it. I was never... So I don't see how that
7 your mother's characterization; that is, that you 7 makes any sense.
8 had a drug problem and as well you had posttraumatic 8 Q. Do you know what posttraumatic stress
9 stress disorder relating to the automobile accident? 9 disorder is?
10 MR HOROWITZ: Form 10 A. I lcnow what it is but I mean —
11 THE WITNESS: I agree I had a drug problem 11 Q. What do you, what do you understand if I
12 yes. I don't know about that I — 12 use PTSD, posttraurnatic stress disorder, what did
13 BY MR. CRITTON: 13 you understand that is?
14 . Q. Are you denying that you had posttraumatic 14 MR. HOROWITZ: Form.
15 stem disorder at that time or you just don't loxwe? 15 THE WITNESS: That something traumatic is
16 A. I don't balmy. 16 affecting your life in some kind of way.
17 . MR HOROWITZ: Form. 17 BY MR. CRITTON:
18 • ' THE WITNESS: I have never, you know — 18 Q. And do you think that the automobile
19 BY MR. CRITTON: 19 accident was something that has traumatically
20 Q. Do you think your mother had a pretty good 20 effected your life?
21 gmsplbackiirt 2004, '5, '6 of the problems that were 21 A. Yeah. But for her to say it like that, there
22 *acting you or had an inatmet on yma 22 was never no diagnosis of saying that I was PTSD.
23 A. If she did, she wouldn't have tried to take me All right Has anybody ever diagnosed you
24 to so many therapists and programs. 24 with PTSD to your knowledg?
25 Q. You think because she took you to so many 25 MR. HOROWITZ: Form.
18 (Pages 397 to 400)
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THE WITNESS: The therapist, the one I 1 THE WITNESS: Yeah, I see it but —
2 went to for one time said that she thinks I 2 MR. HOROWITZ: Never, never mind.
3 have posttraumatic stress disorder but how 3 BY MR. CRITTON:
4 could she figure that out with one visit 4 Q. Were you Baker Acted into
5 BY MR. CRITTON: 5 least from your perspective? In fact, e
6 Q. Was that Mrs. a 6 this way: How did you get into
7 A. No. 7 A. Growing Together.
8 Q. Who was that? 8 Q. And what, what happened that moved you
9 A. I don't know. I only went to her one time. 9 from Growing Together to
10 Q. And who sent you to that person? 10 A. I flipped out on themTetr.
11 A. My mom. 11 Q. Was it intentional to flip out; that is,
12 Q. Do you know what the person's name was? 12 were you really flipped out or did you pretend to be
13 A. No. 13 flipped out?
14 Q. Do you know where it was; that is, where 14 A. No. I like snapped on them people. !just
15 was the location? 15 went off.
16 A. Palm Beach Gardens. 16 Q. Okay. Had you snapped at am time up
17 Q. What time frame was it? Was it before or 17 until —
18 after she took to you Growing Together? 18 A Nope.
19 A. I don't know. It was after the accident, 19 Q. — that day?
20 20 A No.
21 Q. I think it was, the accident was in '03, 21 Q. Were you getting along pretty well with
22. correct? I'm sorry. It was in 2004. That was the 22 most of the people at Growing Together?
23 accident up near 1-95. I am sorry, I-4. So, if it 23 A. No. I wouldn't have snapped if I was getting
24 was in 2004, she would have taken you to see a 24 a long with them.
25 psychiatrist or psychologist? 25 . Q. I'm only asking the question —
Page 402 Page 404
A. Yeah, I guess. 3. A. No.
2 Q. Did you 'mow you were going to go see a 2 Q. — because I wasn't there.
3 psychologist or psychiatrist at the time? 3 A No.
4 A. Yeah. 4 Q. So, what happened at Growing Together,
5 Q. Did you she tell you why you were going to 5 that is, you were now, at least by your mom's letter
6 go see somebody? 6 you had been there 26, 27, 28, 29 days at Growing
7 A. About my dreams. 7 Together, correct? Agin, if she's right.
8 Q. Because you were having nightmares about 8 A. Yeah.
9 the automobile accident? 9 Q. And had you been able to communicate with
10 A. Yes, about driving. 10 your mom or your dad or any family members during
11 Q. Were you even more afraid of being in a 11 the time you were at Growing Together?
12 car back during that time period, in the '04, '05 12 A. No.
13 time period? 13 Q. You didn't have access to a phone,
14 A. Yeah. I was afraid to drive. I was more 14 correct?
15 cautious- 15 A. Yes.
16 Q. Well, you weren't driving then. You were 16 Q. Did you want to call your mom?
17 riding, correct? 17 A. Yeah.
18 A. Still the same thing. 18 Q. Okay. Did you want to get out of that
19 Q. Same thing from your — okay. Exhibit 4, 19 program?
20 your mom's letter goes on to say that she ot a call 20 A. Yeah. I wanted to see my family.
21 day of your treatment from 21 Q. Were you dating anyone at the time?
22 that you had been Baker Act . you see 22 A. I don't know. I don't think so. I don't
23 that? 23 remember.
24 MR. HOROWITZ:' I could help her with the 24 Q. So, what happened on the date that they
25 line. 25 took you, the date as you described you flip out;
19 (Pages 401 to 404)
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Page 405 Page 407
1 that is, what, what happened that day that made you . 1 Q. You just went through the motions?
2 flip out? 2 .A. Yes.
3 A. They took me to court and my family was there 3 • Q. What you had to do to survive?
4 and they wouldn't let me talk to them. They told me we 4 A. Yeah.
5 were going to the dentist because recently I just had a 5 Q. And Ms. Doe No. 6, when you got into
6 tooth pulled like the week before. So, they were 6 court, did they start talking about did you hear
•7 supposed to take me for another dentist appointment. 7 them say we would like her to be court ordered for
8 Well, instead of taking me to the dentist, 8 another umpteen days?
9 they started driving me downtown. And once we got 9 A. I don't, I dorft remember what they said. I
10 in the courtroom, they were like, oh, well we're 10 . was not paying attention.
11 trying to see, they were trying to get me, I guess, 11 Q. But you, I thought you said that the whole
12 court ordered to stay in Growing Together, so... 12 'preceding —
13 Q. And you had no idea at that time that they 13 A. Yeah.
14 were going to do that? 14 Q. — was about keeping you there?
15 A. No. 15 A. No. There was a, there was a courtroom filled
16 Q. Did you actually get into the courtroom? 16 with people, different people but they weren't talking
17 A. Yeah. 17 about me at a certain moment.
18 Q. Okay. Did you flip out when you were in 18. Q. Okay. And when they talked about you, did
19 the courtroom? 19 you, if I understood you correctly they wanted to
20 A. No. 20 keep you there?
21 Q. What happened in the courtroom, did they 21 A. • Yeah. I know that's what, when we pulled up
22 talk about you in front of a judge? 22 that's what they told me we were coming to court for.
23 A. Yes, yeah. 23 Q. And what —
24 Q. Okay. And what did the judge decide? 24 A. I didn't pay attention because I was watching
25 A. I don't, I don't know. I don't remember. 25 my mom.
Page 406 Page 408
1 Q. Was your family there? 1 Q. What did you say then?
2 A. Yeah. 2 A. Huh?
3 Q. Did you get to wave to them? 3 Q. What did you say when they said we want to
4 A. No. I was not able to talk to nobody. I had 4 keep you?
5 to stand in the corner. 5 A. What? When we got there?
6 Q. And not move at all? 6 Q. Before you got to the courtroom.
7 A. Yeah. I wasn't allowed to talk to no officer, 7 A. I told them they were crazy.
8 nobody. 8 Q. Why, because you wanted to get out?
9. Q. Was there any other kids from Growing 9 A. Yeah. I didn't want to stay in there.
10 Together or just you? 10 Q. Did you thhik that you, your time was up
11 A. Just me and another girl that she had to, 11 so to speak?
12 like, watch me. 12 A. I don't know. I just, I wasn't going to stay
13 Q. She was, she was like the person who was 13 there for long.
14 assigned to be with you that, from Growing Together? 14 Q. You wanted out of the program?
15 A. Yes. Because she was on a higher step than 15 A. Yes.
16 me, so she was supposed to watch me. 16 Q. You wanted to get back home and do what
17 Q. Were you still at the bottom nue 17 you were ever doing?
18 A. Yeah. 18 A. 'just, they —
19 Q. Had you made any progress in Growing 19 Q. Go ahead, I'm sorry.
20 Together at all? 20 A. They kept me away from my family. I wanted to
21 A. No. 21 be with my family.
22 Q. Okay. Were you fighting the program? 22 Q. You wanted to get back to your family and
23 A. I just didn't like sing and like stand up in 23 start doing drugs again, too?
front of everybody, no. I just — I didn't fight them 24 A. I don't — J.know i wanted to be with my
25 but I just didn't like volunteer myself to do stuff.
20 (Pages 405 to 408)
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Q When you did get out, though, you started 1 because I know the cops because I was in the cafeteria
2 doing drugs again? 2 area in the front doors like over here. They were like
3 A. Not right away. 3 blocked of so I don't know if they heard me or — I
4 Q. How long? 4 ath — I know I wasn't yelling at them when they got
5 A. It took mo like three months I was relapsed I 5 there.
6 would say. 6 Q. At the police?
7 Q. So, you are in the courtroom. You hear 7 A. Yeah.
8. they want to keep you. Did you get to talk at all 8 Q. So, when the police came, did you talk to
9 or speak during the proceeding? 9 them?
10 A. No. 10 A. No. They just put me in handcuffs and...
11 Q. What did the judge order? 11 Q. Handcuffs behind your back, in front of
12 A. I don't know. 12 your back?
13 MR. HOROWITZ: Form. 13 A. In front ofmy back
14 THE WITNESS: That he obviously didn't 14 Q. In front of your back. Behind you; in
15 order nothing because I got out that day or a 15 front of you?
16 couple of days later. 16 A. In front ofme.
17 BY MR. CRITTON: 17 Q. And then they took you toM'
18 Q. Okay. You get, at what point did you flip 18 A. Yeith. Ifs right acrossjttareet.
19 out? 19 Q. Had you ever been to before?
20 A. When I, we got back. 20 A. No.
21 Q. In the program in Riviera Beach? 21 Q. So, they take you toM. Well, let
22 A. Yeah. 22 me, before I get off this, I want to get back to
23 Q. And what, what did you do that flipped you 23 your mother's letter for just a minute. Did you
24 out? 24 understand that ou were being Baker Acted when you
25 A. I told them I didn't know why they tried to do 25 went to
Page 410 Page 412
1 that. I don't know why they, like, tried to trick me 1 A. I heard it afterwards. That's what they told
2 and say I was going somewhere else when I wasn't. They 2 me.
3 should have just told me right then and there, we are 3 Q. Did you know what, did you know what a
4 going to court and this is what we were doing. 4 Backer Act was?
5 Q. If they had said that, what would you have 5 A. No.
6 said? 6 Q. And now you get to, you get to
7 A. I still would have went but I mean — 7 And what do they do for you?
8 Q. Would you have flipped out earlier? 8 A. They call my parents. They had me sit in a
A. Probably. 9 room. I watched TV for like the fast time in weeks.
10 Q. Okay. So, when you say you flipped out, 10 Q. Is that a good deal?
11 were you yelling, screaming at them? 11 A. It felt nice.
12 A. Yeah. I was just yelling at them. 12 Q. How long do you recall your how long do
13 Q. Were you throwing anything? 13. you recall, you recall you were at
14 A. No. 14 A. Three days, 72 hours they said. That's why I
15 Q. Were you in any way physically violent? 15 don't know where that April l0th thing comes from
16 A. No,Ijust-- 16 because we tried to return the day I got out of
17 Q. You were just yelling and screaming? 17 to get to, to get my stuff.
18 A. Yeah. I was just flipping out. 18 Q. From.
19 Q. And what did they say to you? 19 A. From Growing Together.
20 A. They, they called the cops. 20 Q. Okay. What stuff did they have?
21 Q. So, the police actuall came? 21 A. Like all my toiletries, like my toothbrush and
22 A. They escorted me to 22 my brush and stuff like that.
23 Q. And what did they tell you — were you 23 Q. When you, when you went to a, you
24 still screaming when the cops came? 24 said you sat in a room for a few hours arid watched
25 A. I don't know. I was — I don't remember, 25 TV?
_2, -o. - 4 Crel•.•••,a a 0.-A-ISIZSMSN
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Page 413 Page 415
1 A. (Witness nods head.) 1 A. Yeah. My mom and dad.
2 Q. Did anybody come in yes? 2 Q. What did they say to you?
3 A. Yeah. 3 A. My dad said I wasn't going back. My morn
4 Q. Did anybody come in and talk to you? 4 always says, we'll see, well see.
5 A. Just the nurses like they, you know, take my 5 Q. Had you, had your mom I know you said
6 blood pressure, check my temperature, stuff like that. 6 your mom had taken you for a psychologist or
7 Q. Okay. Did they have you sign a bunch of 7 psychiatric visit up in the Gardens, you told us
8 forms or did your parents have to come in? 8 that —
9 A. I had my — I know my parents had to come in 9 A. Yeah.
10 and sign paperwork. 10 Q. — at some point because you were having
11 Q. Okay. Do you remember signing forms too? 11 nightmares after the automobile accident in '04,
12 A. I don't, I don't know. 12 correct?
13 MR. CRITTON: Okay. Well, these are 13 A. Yeah.
14 records that were provided by your attorneys 14 Q. Had you, had you — before Growing
15 and let me just, without, unless you want to 15 Together, had you ever seen another psychiatrist or
16 mark one. I have no real intention to mark the 16 psychologist for any reason or counselor?
17 whole exhibit. 17 A. I don't know. I know I seen another
18 MR. HOROWTTZ: It came from us. 18 psychiatrist on Southern and Military at the fire
19 MR. CRITTON: Yeah. No. It came from us. 19 station or whatever. I guess that's where her office
20 It was sent to us and then you got copies. I'm 20 was. The fire department of, like the little fire
21 sorry, because it went to Jessica Cadwell. Let 21 station there.
22 me just show you one. This is a notice of 22 Q. Southern and what?
23 patient's rights and privile es. It's just a 23 A. It's like a fire station. Its like the
24 document, and it's dated 24 Department of Fire Rescue or something.
25 can ask Mr. Horowitz to pass it to you. I j ust 25 Q. That's where her office was located?
Page 414 Page 416
1 want to see if that's your signature. 1 A. Yeah. Off on Southern, off of Southern on
2 THE WITNESS: Yeah. 2 Military. But I don't know when that was. Tat's the
3 BY MR. CRITTON: 3 only psychiatrist I've seen other than the one that I
4 Q. Okay. Did you recognize at least your 4 told you the two about.
5 signature on the document? 5 Q. There was a lady name Susan
6 A. Yeah. 6 Does that name mean anything to you?
7 Q. That's alit want to know because then I 7 A. That's, that's not her. That's — she's one
8 will be able to identify the handwriting elsewhere. 8 of the psychiatrists at the office that I was going to
9 Did they have you sign other forms, too, 9 but the —
10 that you can recall? 10 Q. This, this lady is in—_
11 A. I don't even remember signing that one. 11 office is in the Gardens.
12 Q. Did your parents ever come and see you 12 A. Yeah. That's a different one. That was my
13 while you were in a? 13 probation officer. The lady that seen the
14 A. Yeah. 14 physiatrist, that's her office is But the
15 Q. Were they able to see you the vety day you 15 lady I seen er name was —
16 got into_? 16 Q•
17 A. Yeah. 17 A. or something.
18 Q. And what conversations did you have with 18
19 your parents at that time? 19 A. Yeah. No no no not
20 A. Told them I wasn't going back. 20 Q. isalilliN0 —
21. Q. To Growing Together? 21 A. something like that.
22 A. Yeah. 22
23 Q. Okay. And what did they say? What did 23 A. Yeah,
24 you mom — who was it was, your mom and dad or just 24 Q. Okay. You did like her?
25 your mom? 25 A. Yeah.
../
22 (Pages 413 to 416)
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Page 417 Page 419
1 Q. And did you see her as part of your 1 Q. Do you know what point in time when that
2 probation? 2 was, Ms. Doe No. 6. Was that before she took you to
3 A. Yes. 3 Growing Together? •
4 Q. That is part of your, the, I'd say the 4 A. I don't remember what year it was. That's why
theft charge that you pled guilty to? 5 lam not good with —
O A. Yes. I thought I had the card. 6 Q. That's why I am not giving you a year or
7 Q. Other than, and I think you saw, I will 7 not asking for a year. Do you remember whether it
8 get to those visits, but you haven't seen her in a 8 was before she tSGrowing Together and then
9 number of years? 9 you ended up at
10 A. Since my son was born February of 200/3 is 10 A. I don't remember.
11 the last time I seen her. 11 Q. One of the reasons I'm asking it that way
12 Q. That's the last time you saw her? 12 is because it looks like in at least from a, from a
13 A. Yes. 13 time sequence, is the automobile accident happened
14 Q. Was the, was she; thiljgaithen you saw 14 in 2004. The, in March of '06 you w in 'ng
15 her ORS that is Ms. =Nand 15 Together. In April of'06 you were at
16 Ms. == they both, at least in looking through 16 And then the criminal problems that you had from the
17 the records, they appear to both be involved with 17 theft, that was in, it looks like it was in '07.
18 the criminal justice situation. 18 So, do you remember whether your mom took
19 A. I don't know. 19 you to see that psychologist at Military near the
20 Q. Okay. Was, did you -- when your mom took 20 fire station before Growing Together?
21 you to see a psychologist ttp Beach Gardens, 21 A. I don't remember.
22 was that di or you think 22 Q. Okay. Do you remember why she took you
23 that was Ms fille 23 there?
24 A. No, that was different. 24 A. No. Like I said, I just, I went along for the
25 Q. But you don't remember that person's name? 25 ride. She just told me I had to go somewhere and --
Page 418 Page 42C
1 A. No. 1 Q. Did your parents, did your parents come
2 Q. Was that a male or a female? ee you every day when you were at
3
4
A. That was a female.
Q. That was the one-time visit?
2
3
4
S A. My mom came back every day to see me, yeah.
5 A. Yes. 5 Q. Did you your dad come back at all?
6 Q. That was the, dealt with the nightmares? 6 A. No. He went the first day. He seen me.
7 A. Yes. 7 Q. And he wanted you out?
8 Q. Then there was another one that you saw at 8 A. Yeah.
9 Southern and Military. Q. And why did he want you out?
10 A. Yea And I don't remember her name either. I 10 MR. HOROWITZ: Form.
11 am not good with names. 11 BY MR. CRITTON:
12 Q. How many, how many times did you see that 12 Q. Did he tell you?
13 person? 13 A. Reantse he didn't want me to go back to —
14 A. I saw her fora couple of weeks, like once a 14 because I told him I didn't want to go back to Growing
15 week or something. 15 Together. •
16 Q. For how long? 16 Q. Did you understand that you had to spend
17 A. I don't really remember. It wasn't, it wasn't 17 70, because • gBaker Acted, you had to be
18 like the last one. I went to her for like six months, 18 72 hours at
19 or eight months or something. It was only like two 19 A. Yeah, that's why he didn't come back, because
20 months maybe. 20 he knew I was going to comjakafter the 72 hours.
21 Q. And did your mom take you there as well 21 Q. The reports from at least the
22 for nightmares you were having relating to the 22 records that I am looking at, it says reflect, it
23 automobile accident? 23 • says reason for admit, patients own words, my
24 A. I don't even know why we went there. I just 24 thoughts of suicide, just thinking about cutting
25 know we went. 25 m elf. Do ou remember telli them at --
23 (Pages 417 to 420)
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Page 421 Page 423
1 A. No 1 Tape 2.
2 Q. - UM that? 2 BY MR. CRITTON:
3 A. No. 3 Q. Ms. Doe No. 6, when you went to
4 Q. Are you denying you said that? 4 were you, ! don't want to say glad to be thalin '
5 A. No. I don't remember telling them that. 5 were you glad to be out of Growing Together?
6 Q. It goes on to say, and again I am reading 6 A. Yeah.
7 from the record: I have had these thoughts at 7 Q. And did you understand from at least
8 Growing Together. told Growing Together 8 talking with theumagad the psychiatrist and the
9 when she was using patient would have ' 9 people there at EM, they were trying to do an
10 thoughts and has cut her wrists specifically. 10 evaluation of you to determine whether or not they
11 Had you cut your wrists before? 11 could let you go?
12 MR. HOROWITZ: Form. 12 A. I guess.
13 THE WITNESS: Before, yeah. 13 Q. All right. And would it be a comet
14 BY MR. CRITTON: 14 statement that you wanted to give them accurate
15 Q.. And when you cut your wrists, where were 15 information so they could give you a good
16 you at the time? 16 evaluation?
17 A. At home. 17 A. !don't know. They let me out in three days
18 Q. How old were you at the time? 18
19 A. It was right before then I guess. I don't 19 Q. Well, did you intentionally lie to those
20 really remember. I was high, I mean... 20 people when they asked you questions, or did you
21 Q. All right. When you were high, what did 21 tell them the truth?
22 you cut your wrists with? 22 A. I don't remember them asking me questions.
23 A. A razor, I guess. 23 Q. So, if— you don't remember any
24 Q. And do you, do you still have any scars 24 discussions that you had with those people?
25 from that? 25 A. No. I remember like we had circles where we
Page 422 Page 424
1 A. Not really. 1 all, that everybody would talk but like, like, before I
2 Q. They seem to have gone away? 2 don't say nothing. 1 don't like voluntarily just like
3 A. Yeah. 3 put my business out there.
4 Q. Did you cut both wrists? 4 Q. Well, do you remember being evaluated by a
5 A. No. 5 psychiatrist and a psychologist at different times?
6 Q. Just your right wrist? 6 A. I remember they came in the room and asked how
7 A. Just my right wrist. 7 them I was doing.
8 Q. You have a band on right now. What's that Q. Do you remember meeting with a
9 for? 9 psychiatrist named or psychologist named
10 A. It's my Twilight band. 10 Dr.
11 Q. I'm song? 11 A. That guycame one time and it was because they
12 A. Twilight, New Moon. 12 we trying to give me than, bipolar things. And
13 Q. All right. les from the last Twilight 13 he was trying to --1 only seen that guy one time.
14 movie that came out? 14 MR. HOROWITZ: Pardon me for interrupting.
15 A. Yes. 15 Jane Doe No. 6, just answer his question.
16 Q. And you were reading the Twilight books 16 BY MR. CRITTON:
17 when we came in today. Do you like the books as 17 Q. Do &remember meeting with and speaking
18 well? 18 with Dr.
19 THE VIDEOGRAPHER: Mr. Critton, we need to 19 A. Yes.
20 change the tape. 20 Q. And do you remember him asking you a bunch
21 'MR. CRITION: Okay. 21 of questions and you giving him a bunch of answers?
22 DEOGRAPHER Going off the record at 22 A. Yeah, I guess.
23 11:14 .1 This is the end of tape one. 23 Q. And can I assume that if he asked you a
24. THE VID HER: We're back on the • 24 questionyou gave him an honest answer?
25 record at 11:58 . and this is the sten of 25 MR. HOROWITZ: Form.
24 (Pages 421 to 424)
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Page 425 Page 427
1 THE WITNESS: Yeah. 1 Q. Do you remember that she took you there
2 BY MR. CRITTON: 2 because you had taken a weapon to school. Do you
3 Q. He said, he talked about or at least the 3 remember taking a knife to school?
4 history that you gave us just a little bit ago is 4 MR. HOROWITZ: Form.
5 you remember that you cut your right twist. Is that 5 THE WITNESS: Yeah.
6 the only time that you have ever cut your wrist, or 6 BY MR. CRITTON:
7 have you cut yourself on more than one occasion? 7 Q. Okay. Why, why did you take a knife to
8 A. No. I have only cut my — what do you mean by 8 school?
9 only on one occasion? 9 A. I didn't They caught me skipping school with
10 Q. Well, you said — we know that you related 10 a knife in my purse.
11 the history of at least an attempted suicide by Q. Were you on school property when they
12 cutting your wrists; is that true? 12 caught you?
13 A. Yes. A. No.
14 Q. Okay. And was it your intent at that time 14 Q. Where were you?
15 to kill yourself/ 15 A. I was walking to Forest Hill and Military.
16 A. I guess, yeah. 10 Q. Who caught you?
17 Q. Okay. And who found you? 17 A. The school police.
18 A. Nobody. I went to sleep in my iwdt, and my 18 Q. Were you near school ground?
19 arm was all bloody. 19 A. I was a block or two away. I was at the next
20 Q. Okay. You just don't remember doing IT? 20 light.
21 A. Yeah, no. 21 were you walking, what school was
22 Q. You said yeah, no. 22 that, at the dine?
23 A. No, I don't. 23 A.
24 Q. All right 24 Q. Had you been in school
25 A. I don't remember. 25 that day?
Page 426 Page 428
1 Q. You woke up and your arm was bloody? 1 A. No.
2 A. Yeah. 2 Q. And you were walking away?
3 Q. Were you still bleeding at THE time? 3 A. Yeah.
4 A. No. 4 Q. Let's start again. Had you been in school
5 Q. So, you had cut your wrists. Was it both 5 that
6 wrists or just one? 6 A. No.
7 A. Just one. 7 Q. Were you intending to go to school that
8 Q. And you had cut it and either passed out 8 day?
9 or fallen asleep? 9 A. No.
10 A. Yes. 10 Q. You were just out walking on a school day?
11 Q. And you woke up and there was blood all 11 A. No. I got dropped off across the street at
12 over? 12 the store My mom dropped me off at the store. And
13 A. Yes. 13 then when she leaves. I walked away.
14 Q. But you had stopped bleeding? 14 Q. So, that's when you decided to skip'
15 A. Yes. 15 school?
16 Q. Did you tell your mom? 16 A. Yes.
17 A. Yeah. 17 Q. Where were you going do you know?
18 Q. And what did she say? Did she freak out? 18 A. I don't know. Me and this girl were just
19 A. I don't — yeah, I guess. I don't remember. 19 walking to the bus stop.
20 Q. Okay. Your mother referenced that you 20 Q. And you just jumped on the bus and go
21 were seeing a psychiatrist or a therapist at the 21 wherever you were going?
22 corner of Gun Club and Military. Do you remember 22 A. I guess wherever she was going.
23 that? Is that where you're telling me about near 23 Q. And you had a knife in your purse. What
24 the fireplace, fire station? 24 kind of knife?
25 A. Yeah. It's in between Gun Club and Southern. 25 A. 1 don't know. Just one of them little
25 (Pages 425 to 428)
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Page 429
1 pull-out knives. The ones that just comes out. It was 1 A. Maybe like a couple of days.
2 just a little blade. It wasn't — 2 Q. And then you said that's it; I am done
3 Q. And did the police, how did the police — 3 with school?
4 how did the school police see you? 4 A. No. I just didn't, I wasn't going to that
5 MR. HOROWITZ: Form 5 school.
6 THE WITNESS: I guess they seen me 6 Q. Okay. Did you ever go back to school
7 walking. 7 again after you got kicked out of
8 BY MR. CRITTON: 8 you got to sent ton correct?
9 Q. How would they know you were a student? 9 A. Yes.
10 MR. HOROWITZ: Form. 10 Q. Okay. .Did you go to a few days?
11 THE WITNESS: Because I had my book bag on 11 A. Yeah, a couple of days.
12 .and my uniform on. 12 Q. Why didn't you lice it?
13 BY MR. CRIlli m 13 A. Because of the neighborhood and all the people
14 Q. Okay, required a uniform? 14 that were there.
15 A. Yes. 15 Q. What were all the people that were them?
16 Q. So your, your mom let you off at the 16 A. There was -- it was in the ghetto, around all
17 store. Mom takes off. You and your friend are 17 kinds of black people.
18 going to jump on the bus and take off? 18 Q. Where?
19 A. Yes. 19 A. All 'rinds ofdrug dealers.
20 Q. School police see you because you have a 20 Q. What?
21 uniform and a book bag on? 21 A. On Tamarind and like 2nd Avenue or something.
22 A. Yeah. 22 That's where the school was.
23 Q. They come over, and do they look in your 23 Q. All rigid. Had you been in school with a
24 book bag and your purse? 24 lot black kids before?
25 A. No. They asked me where am I going. I told 25 A. No.
Page 430 Page 432
them I was going home. I tried to make something up and 1 Q. All right. Was that something that you
they were like, well, we're going to take you back to 2 did not want to do?
3 school. They brought me back to school and brought me 3 A. Yes.
4 to the principal's office and searched my stuff 4 Q. Okay. Are you uncomfortable around black
5 Q. And then searched your stuff? 5 people?
6 A. Yes. 6 A. So, some of them.
Q. And then you had the knife and they called 7 Q. And there were a bunch of drug dealers
8 the police? 8 there too?
9 A. I guess, yeah. 9 A. Well, they stand at the cornet
10 Q. And do you recall that was the reason you 10 Q. Okay. Did you ever buy any drugs from
11 had to go see the therapist? tl them?
12 MR. HOROWITZ: Form. 12 A. No.
13 THE WITNESS: No. 1didn't know that that 13 Q. Because you were doing drugs at the time,
14 was why. 14 weren't you?
15 BY MR. CRITTON: 15 A. I was at a school though.
16 Q. What's School? 16 Q. Well, so, you had to buy your drugs
17 A. That's I got lacked out of 17 someplace,
18 after all that 18 is different.
19 Q. Because of the knife incident? 19 I have to get, I have to take
20 A. Yea 20 off my jacket or anything. They take a metal detector
21 Q. And so you were sent to 21 around my legs. I have to take off my shoes. I can
22 A. Yes. 22 only bring a pencil and a piece of paper or a folder
23 Q. Did you skip school from wan 23 with a piece of paper in it.
24 A. I told my mom I wasn't going to that school. 24 Q. Okay. So, they do searches?
25 Q. Did you ever go? 25 A. Yes.
IL•VLLTY.
26 (Pages 429 to 432)
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Page 433 Page 435
1 Q. In and out of the school? 1 relationship with your father because you had told
2 A. Yes. And we walk in a line going to and from 2 him that you were attracted to females, correct?
3 class. . 3 A. Yeah.
4 Q. So, you went there a couple of days. Did 4 Q. Do you remember as well you told the
you ever going k h I a in after that? 5 doctor that you were molested by a random man in the
o A. I went to to do 6 neighborhood?
Q. Okay. Right after or just later 7 A. No. What doctor did i tell that to?
on? 8
9 A. Later on. A. No.
10 Q. When did you obtain your =.? 10 Q. Okay. He touched you over the top of your
11 A. I haven't got it yet. 11 clothes in private areas and then he ran away and
12 Q. Still working on it? 12 that's why you brought the knife to school to
13 A. No, not right know now. I am working right 13 protect yourself. Do you remember telling him that?
14 now. 14 A. No.
15 Q. DuSwhat time period were you working 15 Q. Okay. Well, he couldn't have made it up.
16 on your M.? 16 So, where else -- was there anyone else in the room
17 A. Lace 2008. 17 with you at the time that the questions were asked
18 Q. And how far did you get? 18 about your history?
19 A. I went a couple of months but -- 19 MR. HOROWITZ: Form
20 Q. How Isu lid it take, how long does it 20 THE WITNESS: I don't, I don't even
21 take to get a M.? 21 . remember those questions.
22 A. It depends what, what, you know, what level 22 BY MR. CRITTON:
23 you are in and certain things. 23 Q. So, if the doctor's report says the
24 Q. What level do you think you are in or were 24 history of abuse and you say patient shared that she
25 you tested out at? 25 was molested by a random man in the neighborhood.
Page 434 Page 436
1 A. Well, I was really bad in language arts so I 1 He touched her over the top of her clothes in
2 need a lot of work there. And I was like at like a 2 private areas. Patient, you, ran away, and this is
3 seventh grade level in reading and a tenth grade level 3 when she brought a knife with her for protection and
4 in math. So I needed work in reading and language arts. 4 it was found on her at school. Do you recall that
5 Q. Do you intend to finish that? 5 occurring?
o A. Soon. 6 A. No.
7 Q. All right. Also, now back to the 7 Q. Are you saying that the doctor made that
8 records. The report also indicates that your 8 up?
9 parents were divorced in June of '97. That was 9 MR. HOROWITZ: Form.
10 true, but they were back living together; is that 10 THE WITNESS: No. I Just, I don't know
11 correct? 11 where that whole paper came from.
12 A. Yeah. 12 BY MR. CRITTON:
13 Q. All right. And you started using in 13 Q. Well, it is true because you -- well, let
14 2000? 14 me strike that. Isn't it nue that a random man in
15 A. No: 15 the neighborhood, in fact, molested you and touched
16 Q. When do you think you started using 16 you in private areas?
17 A. I don't }mow, like 2004,2005. 17 A. No. The same thing with I don't know bow they
18 Q. All right. You don't remember? 18 said I was cutting myself hersince I wasn't doing that.
19 A. It wasn't 2000. I know it wasn't 2000. I 19 Q. Do you ever recall telling the doctor that
20 would have been ten. 20 "'sere oing to go to Carp after you left
21 Q. All right. You indicated to the doctor 21.
22 that you had a stressful relationship with your 22 A. No.
23 d you think at the time that you entered
23
24
25
mother; is that true?
A. Yeah. We fight sometimes.
Q. Okay. And you had a difficult
24
25
sai that you were both depressed and suicidal?
A. 1was depressed.
27 (Pages 433 to 436)
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Page 437 Page 439
Q. Did you consider yourself suicidal? 1 nor to Growing Together that you had ever
A- No. 2 been touched in any inappropriate way by
Q. Do you remember, well, let me strike that. 3 Mr. Epstein, did you?
Did you ever cut your legs? 4 A. I never told them I was molested by anyone.
A. No. 5 Q. You may not have but at least their
O. Prior to April, your admission to 6 records, I am just representing to you that their
7 records reflect what you said with regard to the
8 A. No. 8 random man molesting you in your neighborhood which
Q. If you have scars on your leg the upper 9 you now deny, correct?
10 portion of the thigh of either your left or right 10 A. Their records also say1 was cutting myself.
11 le& do you know what those scars are from? 11 Q. Well, you told —
12 A. I don't have any scars. 12 MR. HOROWITZ: Just answer his question.
13 Q. When were you discharged from 13 THE WITNESS: No. That's, l guess that's
14 Were you discharged with any medication? 14 what they say I guess, I don't —
15 A. No. 15 BY MR. CIIITTON:
16 Q. Okay. Were sk ot aced on any medication 16 Q. But you did cut yourself because you --
17 when you were in 17 A. Before.
18 A.. No, I don't think so. 18 Q. — you pointed to your — let me finish,
19 Q. Do ou remember meeting with a social 19 you did cut yourself because you pointed to your
20 worker at 20 left wrist where you were cut, correct?
21' A. No. 21 A. Yes, before.
22 Q. Would it be a correct statement Ms. Doe 22. Q. Before?
23 No. 6 you told individuals at that you were 23 A. Before and Growing Together I was
24 sad as a result of the car accident in September of 24 cutting myself.
25 '04 where you thought your mother was dead, do you 25 Q. Right. And that's what their records
Page 438 Page 440
remember telling them that? 1 said. It's a history of having done that. History
2 A. No. I have told everybody that that — I 2 means it happened in the past. Do you understand
3 don't, I thought my mom was, I was going to lose my mom. 3 that?
4 Q. Do you remember after the automobile 4 A. Yeah.
5 accident you started using ='? 5 Q. All right. So, they weren't saying at
6 A. I guess. I mean, like said, I don't know when 6 Growing Together you were cutting yourselfor that
7 1 started. 7 you had just done it, but that you had done it
(1.31 ice. In another report other than 8 previously. Okay?
9 Dr. there is, she also admits to being 9 A. They also said that I was suicidal and that's
10 molested by a random man in her neighborhood where 10 why I was sent there, and that's not why. Even in this
11 he touched her on the top ofher clothes and she ran 11 letter says that they don't know why I was sent.
12 away. She then was carrying a knife and she got 12 Q. Your mother's letter, Exhibit 4?
13 caught with the knife at school. Do you remember 13 A. Yeah. She was never told why I was there so
14 that, saying that to someone? 14 how would they say and how would I be seen by a bunch of
15 A. Where they, no. I don't remember that's what 15 people when I have to be seen when my mom was there.
16 1 am saying. They must have been in the same room 16 Right?
17 because I didn't talk to, I only talk to people in that, 17 Q. Now, Ms. and Ms. you
18 in that circle. 18 believe you saw through as a result through the
19 Q. Are you now denying that you were molested 19 correctional department?
20 by a man in your neighborhood? 20 A. Yes
21 A. No. I am saying it didn't happen. 21 Q. As a result of the theft charge?
22 Q. All right. So, you're saying that you 22 A. Yes, burglary.
23 were never molested by anyone? 23 Q. Burglary. That was a felony to which you
24 A. In my neighborhood, no. 24 pled guilty?
25 Q. All right. Well, you never mentioned to 25 A. Yes.
28 (Pages 437 to 440)
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1 ou ever mention to Ms. or 1 her but I didn't hang out with her anymore, no.
2 Ms. — well, let me strike that. 2 Q. And up until the time that the lawsuit was
3 What waste, what didyau4srstand the 3 filed by your attorneys seeking millions of dollars
4 f bewaseenbyMs. and 4 in damage from Mr. Epstein, you had never seen a
5 Ms. was? 5 psychologist, a psychiatrist, or a therapist for any
6 A. It was part ofmy probation. •6 reason, true, relating to Mr. Epstein?
Q. It was required? 7 A. What?
8 A. Yes. 8 Q. Up until the time that you filed the
9 Q. And as part of your probation what did you 9 lawsuit against Mr. Epstein seeking millions of
10 understand that they were supposed to do for you? 10 dollars, you had never seen a psychologist, a
11 A. I don't know. I know it was something I had 11 psychiatrist, a therapist, or a doctor for any
12 to do, or I was going to be violated. 12 reason relating to Mr. Epstein; is that correct?
13 Q. What did they talk to you about? 13 MR. HOROWITZ: Porn).
14 A. We talked about beings — I was pregnant at 14 THE WITNESS: No.
15 the time she talked about being a new mom. 15 BY MR. CRITTON:
16 Q. Did she ever ask about your history? 16 Q. That's not correct or that's correct?
17 A. Yeah, we might have. 17 A. No. That's correct, yeah.
18 Q. Did you ever talk to her about the car 18 Q. AU right And since you filed the
19 accident? 19 lawsuit, the only person or therapist that you've
20 A. Yeah. 20 talked to, well, really — let me strike that
21 Q. Okay. Did you talk to her about having — 21 Since you filed the lawsuit, the only individuals
22 well, let me strike that. Did you talk to her about 22 wh ve seen that are psychiatrists would be '
23 your criminal charge? 23 Dr. whom you were sent to by your attorneys, •
24 A. Yes: 24 and Dr. who did an evaluation of you by me,
25 Q. Did she, did you talk to her about having 25 correct?
Page 442 Page 444
brought a knife to school? A. Yeah.
2 A. I don't know. Maybe, I guess. 2 Q. And at no time during yolibilait
3 Q. Okay. Did you talk to her about the man 3 Together at the time you were at
4 who molested you in the neighborhood? 4 at the time that you were seen by any other
5 A. No, because it didn't happen. 5 therapist or psychologist or psychiatrist, did you
6 Q. Is there any reason — well, let me strike ever mention that Mr., that anything had occurred in
7 that Did you talk to her about your allegations 7 inappropriately when you were at Mr. Epstein's
8 that you went to Mr. Epstein's house? 8 house, true?
9 A. No. MR. HOROWITZ: Form.
10 Q. Until you, until you were contacted by the 10 THE WITNESS: I never told none of them
11 FBI, the only person who purportedly would have 11 people that I was molested in any way. That's
12 known that you were at Mr. Epstein's house would 12 why I don't go to psychiatrists now, because
13 havelr horn? 13 you see I have done been to like five. That's
14 A. M. who I went with. 14 why I am not — so, I don't go. tam grown
15 MR. HOROWITZ: You mean besides Epstein? . 15 now. I don't have to I don't need somebody
16 MR. ORMI0N: I am talking about someone 16 telling me that I need to go see a counselor.
17 you knew. M. would have been the only 17 BY MR. CRITFON:
18 • person? 18 Q. Okay. And you have no intention of seeing
19 THE WITNESS: She went with me, yes. 19 a counselor in the firture, do you?
20 BY MR. aarroN: 20 ' A. I don't — probably not.
21 And I think you told me last time you and 21 ' MR. CRiTTON: I have no other questions.
22 were not friends after that; that is, you had 22 Thank you. •
23 wry little dealings with her after that period of 23 MR. HOROWITZ: That's it.
. 24 time? 24 EOGRAPHER: Off the record at
25 A. Yeah. I didn't real! -- I talked -- I seen 25 12:13 This is attend of 2 and the
29 (Pages 441 to 444)
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I DATE Apnl 20* 20/0
1 end of the deposition. 2 TO Ms lane Dot 15\s 6
2 (Witness excused.) do ADAM 0 HOROWITZ. SSP=
3 AILIAGSLSTEIN l HOROWIT2-.M.
3 (Deposition was concluded.) 181O5 Biceps %stewed
4 891•211S
Mani. Norsk 33160
CERTIFICATE OF OATH 5
THE STATE OF FLORIDA 4 IN RR Jae Doe No.1ss Epstein
CASE NO: 084:19-80/1911ARRAM41515(94
7 COUNTY OF PALM BEACH
8 Flow ais naiad* as Wobatclay, Cc Oh
8 ofPanty. 2010, ycn your 6:299677 in the
9 abose-orgniad wan« Al thet tent, psi, ed not
9 vinne signe....e. n now xcesse7 that sou sign
10 I, the undersigned authority, certify that yen- *position.
11 JANE DOE NO. 6 personally appeared before me 10 A, .i-evxcaly %tad to. the Israciipt well be
fuirinlicd lo you tIscugh yams 904444 [lessen:al
12 and was duly swum on the 6th day of February, 11 the ti the untnctions carefidly
13 2010. Al the eAl age uansorsn so:* will fed an
22 era shed As ma reedyour depssiticn My
14 chinas of C0110CIMIlkil Walh to apt dwell
15 Dated this 20th day of April, 2010. 13 be cc the ergs cassg sew sof line
"'other of bed Chine DO NOT nein oft the
16 14 tennis as& Oise son Miro sceJ die
17 usescript ad noted esy down mu, be new sign
15 mad dote disown SS and limn mesas
18 a.
19 16 EgonIsnot sanitssd sip the deposition
20
4 4$
17
IS
Mail • nem&Reg Os wig:94 aide has
okay Ice fonserdetl to te eaten% ettestay. cry
bland with the CMOS* Court If goo Aids
a wan. year Sat"delta1gri groannte Maw bask
Cynthia Hopkins, RPR, FPR 19
tbe balm oftkis IS as
21 Notary Public - State of Florida Von IMY 301a.
A
My Commission Expires: February 25, 2011 20
rli escfr_C4310 AS
22 My Commission No.: DD 643788 21
23 CYaha Hogkis. Rpft FPR
22
24 23 1 do ?webs wain as signing°.
24
25 23 JANE DOO NO.4
Page 446 Page 448
1 CERTIFICATE 1 CERTIFICATE
2 THE STATE OP FLORIDA
3 COUNTY OF PAU4 BEACH 2
4 3 THE STATE OF FLORIDA
5 1, Cynthia liopkiin, Registered Professional
Reporter, Florida Professional Reponer and Notary 4 COUNTY OF PALM BEACH
6 Public in and for the State of Florida al large, do 5 I hereby certify that I have read the foregoing
hereby certify that I was authorized to and did
7 report said deposition in stamtype; and that the 6 deposition by me given, and that the statements
foregoing pogo are a hue and correct transenplon 7 contained herein are true and correct to the best of
3 of my shorthand no of said deposition. 8 my knowledge and belief, with the exception of any
I (Inter cat$' that said deposition was
taken at the the and place hercir.above set forth 9 corrections or notations made on the errata sheet,
lo and (WA the taking of said deposition was COITIMaKed 10 if one was executed.
and conthleted as hereinatove set out
t1 11
I further catty that tam not attorney or 12 Dated this day of
12 counsel of any of the patties, nor am I a relative
or employee of any attorney or counsel of party 13 2009.
13 connected with the action, nor ton I financially 14
interested in the action.
14 15
The foregoing certification of this transact 16
15 does not apply to any reproduction of the saute by
any means unkss under the direct control mita
17
16 direction of the eernfying reports/ 18
17 Dated this 1O111 day of Apt '1,2010 19 JANE DOE NO. 6
18
19 20
20 21
21
a in
4Stiop
ek 1115 22
22 23
23
24 24
25 25
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1 ERRATA SHEET
2 IN RE: JANE DOE NO. 2 VS. EPSTEIN
CR: Cynthia Hopkins, RPR, Fit
3 1DEPOSMON OF: JANE DOE NO. 6
TAKEN: April 6,2010
4
5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
PAGE 6 UNIT II CHANGE REASON
6
7
9
10
11
12
13
14
15
16
17 Please foment the original signed crate sheet to
this office so that copies may be distributed to all
16 parties.
19 Under penalty of perjuryjdedatt that I have read
my deposition and that it is cue and comet
20 subject to any changes in foam or substance entered
Inc.
21
22 DATE:
23
24 SIGNATURE OP
DEPONENT:
25
.• ./..elaa•faealet
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