EFTA01107831

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. / Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092, / DEPOSITION OF JANE DOE #7 - VOLUME II (videotaped) Monday, March 15, 2010 10:02 - 6:49 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RMR, CRR Notary Public, State of Florida (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107831 EFTA01107832 Page 127 Page• 1 APPEARANCES: 1 PROCEEDINGS 2 On behalf of the Plaintiffs in related cases 2 Nos 08-80069, 08-80119, 08-80232, 08-80384 3 08-80381, 03-80993, 08-80994: 3 THE VIDEOGRAPHER: We're back on the record at 4 ADAM D. HOROWITZ, ESQUIRE 4 12:19 p.m. This is marks the beginning of tape 2. MERMELSTEIN & HOROWITZ, P.A. 5 BY MR. CRITTON: 5 18205 Biscayne Boukvad Q. When you took F.E. to Mr. Epstein's, 1 think 6 Suite 2218 6 Miami, Florida 33160 7 you said she asked you to take her. Telephone: 305/931.2200 8 A. Yes. She knew about It and she asked me, she 7 9 said she wanted to go. 8 On behalf of the Defendant Jeffrey Epstein: 9 ROBERT D. CRITTON. JR, ESQUIRE 10 Q. Okay. Did you say, and did you tell her "No, BURMAN, CRl11UN, LUTHER& COLEMAN 11 I don't think you should go'? 10 303 Banyan Boulevard 12 A. No. I never said that. Suite 400 13 Q. Did you take her so you could make money' 11 West Palm Beach, Florida 33401 Telephone: 561/842-2820 14 First of all, let me ask you this. Did you 12 15 make money from taking F.E. to Mr. Epstein's home? 13 16 A. Yes. 14 Also Present: Sasha Quimby, videographer 17 Q. How much? 15 16 18 A. 200. 17 19 Q. Okay. And when F.E. came down, did she give 18 20 Mr. Epstein a massage? 19 20 21 A. Yes. 21 22 Q. Did she ever say anything inappropriate 22 23 happened during the course of the massage? 23 24 A. No. 24 25 25 Q. And you took ■ and she came, did she give Page 128 Page 130 1 1 Mr. Epstein a massage? --- 2 A. Yes. 2 INDEX 3 Q. Did she ever tell you anything inappropriate 3 4 had happened? WITNESS: DIRECT CROSS REDIRECT RECROSS A. We never really talked about it. 4 6 Q. Did you ask them? Jane Doe N7 5 A. No. By Mr. Critton 5 8 Q. If you talk someone to Mr. Epstein's home to 6 9 have them give him a massage so they could earn money 10 and you could earn money, did you interpret what you 8 11. were doing was the same thing in essence that M. was EXHIBITS 9 12 doing? 10 EXHIBIT PAGE 13 MR. HOROWITZ; Form. 11. Defendants 1 233 14 THE WITNESS: No. 12 Defendants 2 233 13 Defendant's 3 233 15 BY MR CRITTON: 14 Defendant's 4 263 16 Q. Why was it different, in your mind? 15 Defendant's 5 268 17 A. Because they wanted to go, and we were all 16 Defendant's 6 274 18 just kind of brainwashed by him. And at the time I knew 17 Defendant's 7 280 18 19 it was wrong, but I didn't know how it would affect them Defendants 8 294 19 Defendant's 9 301 20 or affect me in the fixture. And I was just confused by 20 21 everything at that time. 21 22 Q. You knew it was wrong, so what's confusing 22 23 about that? 23 24 24 A. I felt like it was wrong, but I, I just 25 25 thought it was -- I was just confused, and I just didn't •t ree=aa 2 (Pages 127 to 130) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107833 Page 131 Page 133 1 know how much it would affect me in the future and, you 1 Q. But at least as you sit here today, you can't 2 know, what kind ofeffects it would have on them. And, 2 remember anything unusual about her coming down from 3 you know, that's why I feel bad about it now, but at the 3 giving Mr. Epstein a massage; would that be a fair 4 time I was confused and I didn't know. 4 statement? 5 Q. Wellj let _ me ask you this. Have you ever 5 A. I mean yeah, I don't remember. 6 talked withEl about her experience with Mr. Epstein, 6 Q. Same thing with F.E., you don't remember 7 ever? 7 anything that stands out in your mind when she came 8 A. No. She is in now. I don't know, we 8 downstairs because you were in the kitchen, right? 9 don't really talk. 9 A. Yeah. 10 Q. What's she doing in now? 10 Q. Do you remember anything unusual or did she 11 A. She lives there now with her sister. 11 say anything or did she react or have any appearance — 12 Q. IIII? 12 strike that. 13 A. Yeah. 13 Did F.E. either say anything that caused you 14 Q. Is her mom ? 14 any concern or did you observe any facial features or 15 A. Yes. 15 anything that she did or the way she acted that would 16 Q. Herded? 16 have caused you any concern that you can remember today? 17 A. Yes. 17 A. Not that I can remember. 18 Q. So they are all a. Why did they go 18 Q. Those are the only two people you ever took to 19 back to a, if you know? 19 Mr. Epstein's? 20 A. Because their green card etd. 20 A. Yes. 21 Q. Let me ask you again. Did ever tell you 21 Q. You went down and had an interview or an 22 anything bad happened at Mr. Epstein's, or 22 evaluation by Dr. Kliman, who was the psychiatrist who 23 inappropriate? 23 had been hired from San Francisco to evaluate his 24 A. I don't remember. 24 clients, including you, correct? 25 Q. So at least — did you only take her the one 25 A. Yes. Page 132 Page 1 1 time? 1. Q. And you had to fly down from Orlando, true? 2 A. Yes. 2 A. Yes. 3 Q. Do you know whether she ever went another 3 Q. Do you remember telling Jane Doe 4 about your 4 time? 4 eicpadence for the evaluation with Dr. Kliman? 5 A. I don't know. 5 A. Yes. 6 Q. All right. But when she came down from giving 6 Q. And do you remember telling her that you were 7 Mr. Epstein a massage, she seemed to be in good spirits, 7 supposed to cry a lot and be very emotional during the 8 didn't say anything bad had happened; fair? 8 course of the — 9 A. She didn't really talk about it. 9 A. No, I never — 10 Q. Did she appear to be upset in any way? 10 Q. I need to finish the question, ma'am. 11 A. I don't, I don't remember. 11 isn't it true you told Jane Doe 4 that you 12 Q. If she had been upset, that's something you 12 cried a lot during the interview and tried to be very 13 generally would remember, wouldn't you, if she was upset 13 emotional, because that's what you were supposed to do? 14 or emotional about it? 14 A. No. 15 A. It was so long ago, I just remember taking her 15 Q. So if you told Jane Doe 4 that, or 'Ilene 16 there. I don't remember how she reacted or what 16 Doe 4 has said that to anyone, that would be a lie? 17 happened. 17 A. Yes. 18 Q. Did you drive her in your car? You were the 18 MR. HOROWITZ: Form. 19 transporter? 19 BY MR. CRITTON: 20 A. I don't remember. 20 Q. If I use the term crocodile tear, does that 21 Q. WasEl able to drive at the time? 21 mean anything to you? Do you know what a crocodile tear 22 A. Yes. 22 is? 23 Q. But you went with her, so either she drove or 23 A. Yes. 24 you drove? 24 Q. What is It? 25 A. Yes. 25 A. When somebody fake cries. 3 (Pages 131 to 134) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561). 832-7506 EFTA01107834 Page 135 Page 137 1 Q. Let me go back to when Jane Doe 4 was living 1 Mr. Epstein's home? 2 with you this last summer, or I'm sorry, the summer of 2 A. No. 3 '08 and she told you that she had filed a suit against 3 Q. Did she ever talk to you about what occurred 4 Mr. Epstein. 4 or what she alleges occurred at Mr. Epstein's home? 5 As of that date, were you aware of anyone else 5 A. No. 6 who had filed suits against Mr. Epstein? 6 Q. All right. Are you aware of anyone else other 7 A. No. 7 than Jane Doe 3 and Jane Doe 4 who are plaintiffs? 8 Q. As you sit here today, other than yourself and 8 A. Just N.R. 9 Jane Doe 4, are you aware of any other plaintiffs or 9 . And who is she? Again, a student at 10 individuals who are plaintiffs in lawsuits against 10 with you all? 11 Mr. Epstein? 11 A. Yes 12 A. Yes. 12 Q. Same grade? 13 Q Who? 13 A. She's a grade ahead of me. 14 A. Jane Doe 3. 14 Q. And did she tell you that she's a plaintiff in 15 Q. Flow do you know is a plaintiff in a 15 a lawsuit? 16 lawsuit? 16 A. No, we were just talking about it and somehow 17 A. Because she is my friend and she told me. 17 she found out that I had a lawsuit and was asking me 18 Q. And that's Jane Doe 3? 18 about it and she said that she had one, and that's all. 19 A. Yes. 19 Q. Did she tell you who her lawyer was? 20 Q. Were you aware or has Jane Doe 3 told you 20 A. No. 21 whether she has given a deposition? 21. Q. Did she — when did you last talk to N.R. — 22 A. Yes. 22 let me start again. 23 Q. Okay. What did she say about it? 23 When did you have this conversation with N.R. 24 A. She said that you looked exactly like Jeffrey 24 about the lawsuit? 25 Epstein. 25 A. I believe it was over Christmas break, I Page 136 Page 138 1 Q. Did she tell you how nice and polite I was and 1 think. 2 reasonable? 2 Q. Christmas — 3 A. Yes. 3 A. I don't know, I was home like on break I 4 Q. Good. 4 don't know if it was Christmas break or not. 5 MR. HOROWITZ: She did? 5 Q. Well - 6 THE WITNESS: No. 6 A. I was just, like I come home a lot to visit my 7 BY MR. CRITTON: 7 parents. 8 Q. I'm taking that as the truth. 8 Q. Are you still in school right now? 9 A. That's a joke. 9 A. Yes. 10 Q. All right. You don't think I look like 10 Q. So when was the last time you were home, 11 Mr. Epstein, do you? 11 Christmas before now? 12 A. Yes, kind of. 12 A. No, I came home recently to visit them, like 13 Q. I think that's just, l think that's the big 13 last month. 14 pitch, so you all can make that pitch at trial. It's a 14 Q Was that when you talked to N.R.? 15 nice touch, but I'm not moved by it. 15 A. I think so. 16 MR. HOROWITZ: Mow to strike. 16 Q. So it would have been approximately February 17 BY MR. CRITION: 17 of 2010? 18 Q. What else did Jane Doe 3 tell you about her 18 A. Yes. 19 deposition? 19 Q. And was she at your house or did you see her 20 A. She didn't really tell me anything about it. 20 at a bar or were you out at a club or — 21 She just basically said she came in here and did it. 21 A. I forget where I saw her. I ran into her -- 22 Q. Were you aware that she had been at 22 oh, we were at Duffy's. We all went -- 23 Mr. Epstein's home during the time she was going? 23 Q. Which Duffy's? 24 A. I don't remember. 24 A. to dinner. On Northlake. 25 Q. Do you know how she came to be at 25 Q. RIM near I-95? 4 (Pages 135 to 138) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107835 Page 139 Page 141 1 A. Yes. 1 A. Well, yeah. She — yeah. 2 Q. Who was there other than you and N.R.? 2 Q. Okay. How does she know? 3 A. Just some friends from high school. 3 A. Because you guys asked her questions about me, 4 Q. Any other people that you know? Was Jane 4 and Pm sure she assumed I was a plaintiff suing 5 Doe 4 there? 5 Jeffrey. 6 A. No, Jane Doe 4 wasn't there. 6 Q. How about your friend El does she know that 7 Q. Jane Doe 3, was she there? 7 you have brought a lawsuit? A. No. 8 MR. HOROWITZ: Form. 9 Q. Anyone else that you know, any of the other 9 THE WITNESS: I'm sure E. told her. 10 people you knew went to Mr. Epstein's home? 10 BY MR. CRITTON: 11 A. No. 11 Q. Why would.. tell her? 12 Q. And N.R. said that she was going to file or 12 MR. HOROWITZ: Fenn. 13 she was a plaintiff also in a lawsuit? 13 THE WITNESS: Because they are friends. 14 A. Yes. 14 BY MR. CRITTON: 15 Q. How did she know that you were a plaintiff? 15 Q. How do you know El Fuld N. are friends? 16 A. I don't know who told hen 16 A. Because that's what I have heard. 17 Q. Were you upset that she knew? 17 Q. When is the last time you talked to 18 A. I mean she was one of my good friends in high 18 A. Right around her brother's accident. 19 school and she kind of knew what happened, because I 19 Q. Okay. 20 told her before. So I, she kind of already knew, so I 20 A. So probably, I don't know, like seven months 21 wasn't that upset that she knew about that. 21 ago. 22 Q. What do you mean you told her about? 22 Q. That's the last time you have spoken with her? 23 A. I mean she knew about me and Jane Doe 4 going 23 A. Yes. 24 there. She went there before, so — 24 Q. Have you tried to call her or she tried to 25 Q. Oh, she had gone there before you? 25 contact you at all? Page 140 Page 142 1 A. No. I don't, I don't remember when she had 1 A. Not recently. I don't think so. 2 gone. She went sometime in high school. 2 Q. After you said — around the time of her 3 Q. Did she ever tell you about her experience of 3 brother's accident, since that time, have you tried to 4 going to Mr. Epstein's home? 4 call her at all? Or seven months ago was the last time A. No. I just !mew she went. 5 you had any contact with her? 6 Q. Do you know how many times she went? 6 A. Yeah. A. No. 7 Q. Okay. At the time that Jane Doe 4 told you 8 Q. Did you say "Why are you filing a lawsuit? 8 that in the summer of '08 that she was bringing a 9 A. No. 9 lawsuit against Mr. Epstein or had brought a lawsuit 10 Q. So you don't know whether she has — strike 10 against Mr. Epstein, had you contacted an attorney at 11 that. 11 that point? 12 You don't know anything about her lawsuit 12 A. I don't remember. 13 other than she has filed a lawsuit against Mr. Epstein? 13 Q. Affright. Who was the first — strike that. 14 A. Yes. 14 Was it you or your parents who encouraged you 15 Q. So you mentioned N.R., Jane Doe 3, Jane Doe 4. 15 to bring a lawsuit? 16 Anyone else that you are aware that was a 16 MR. HOROWITZ: Form. 17 plaintiff'? 17 THE WITNESS: It was me. 18 A. No. 18 BY MR. CANTON: 19 Q. Who have you told that you area plaintiff in 19 Q. So your parents had nothing to do with you 20 a lawsuit? 20 bringing a lawsuit? 21 A. Just those girls. 21 A. No. 22 Q. So nobody else knows that you are a plaintiff? 22 Q. Are your parents aware now, were they aware at 23 A. No. 23 the time you hired a lawyer? 24 Q. How about il.? Does know you are a 24 A. Yes, I told them. 25 plaintiff? 25 Q. Did you hire a lawyer before you told your 5 (Pages 139 to 142) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107836 Page 143 Page 145 1 parents or were they involved in the decision? 1 Mr. Herniae 2 A. No, I told than after. 2 A. I don't, I don't remember when it was, but I 3 Q. And who did you contact — strike that. 3 just net, just met with him and I — 4 How did you — you know obviously Mr. Horowitz 4 MR. HOROWITZ: Fm going to ask you not to is seated immediately to your left, tweet? 5 discuss what -- 6 A. Yes. 6 MR. CRITTON: Just dealing with the time 7 Q. Is he the fast lawyer you met from that firm? 7 sequence. Don't tell me what he said right now. 3 A. No. I met with Jeffrey Herman. 8 not there yet 9 Q. How did you get in contact with Mr. Herman? 9 MR. HOROWITZ: There you go. 10 A. He called me. 10 BY MR. CRITTON: 11 Q. He called you? 11 Q. So if I understand the sequence correctly, you 12 A. Yes. 12 got a phone call out of the blue from Mr. Heenan about 13 Q. And where did he call you from? 13 Jeffrey Epstein. 14 A. I don't know. 14 A. Yes. 15 Q. Was it before or after Jane Doe 4 told you 15 Q. All right. You spoke with him, and he asked 16 that she was a plaintiff in a lawsuit? 16 you a number of questions, right? 1'7 A. 'think it was before. 17 A. All he really asked me was if I, if l was 18 Q. All right. So at the time that Jane Doe 4 18 involved with Jeffrey Epstein, If I was a witness or 19 told you she was a plaintiff in a lawsuit, had you 19 if— I can't temember exactly what he asked me. 20 already spoken with Mr. Herman? 20 Q. I'm going to come back to that in just a 21 MR. HOROWITZ: Form. 21 minute. Let me get the time sequence here if 1 can, Ms. 22 BY MR. CRITTON: 22 Jane Doe 7. 23 Q. Or did that occur after you spoke with Jane 23 First time he called you, he called you, you 24 Doe 4? 24 talked to him a little bit and you gave him the name of 25 A. I don't know who had, who did it first. I 25 Jane Doe 4? Page 144 Page 146 1 think it was me. I don't really know. I don't 1 A. Yes. 2 remember. 2 Q. Okay. And then sometime later you called him 3 Q. I'll represent that Jane Doe 4, Jane Doe 4's 3 or did he call you back? 4 lawsuit was filed well before yours. She's Jane Doe 4. 4 A. I called him. 5 A. Yes. 5 Q. How much time transpired between the first 6 Q. You are Jane Doe 7. Doesn't necessarily mean 6 call that he made and the second call that you made? 7 one came, hired the lawyer earlier or not, but 1 can 7 A. I don't know. 8 tell you her lawsuit was filed months before yours was. 8 Q. Was it a week? Was it a month? Was it 9 A. He called me originally at first, and then he 9 months? 10 asked me if I lotew any witnesses or anything, and I 10 A. I don't remember how long it was. 11 think I game him Jane Doe 4's number, but I never agreed 11 Q. Okay. On the first conversation that you had, 12 to start a lawsuit until later on. 12 how long did that conversation last? 13 Q. So when Mr. Herman called you, you gave him 13 A. Just like five minutes. 14 Jane Doe 4 — he called you about being a witness? 14 Q. Did he tell you he was representing anyone? 15 A. I believe so. 15 A. No. 16 Q. All right. And did you talk to him? 16 Q. Did you ask him how he got your name? 17 A. Yes. 17 A. No. I didn't know — the first time he 18 Q. Over the phone or in person? 18 called, I didn't I was kind of really, I didn't know 19 A. Over the phone. 19 who was who and who was representing who. So I was, 20 Q. And then you gave him the name of other 20 just kind of told him that I would take his number and I 21 individuals? 21 would think about it and call him back. 22 A. Just Jane Doe 4, I think. 22 Q. Okay. Well, think about what? 23 Q. And then sometime after you met with or Jane 23 A. Well he asked me if we wanted to meet. And I 24 Doe 4 was living with you in the summer, then did you 24 told him that I would think about it and call him back. 25 subsequently speak with him again, him meaning 25 Q. Was he pitching basically I could represent 6 (Pages 143 to 146) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107837 Page 147 Page 149 1 you in the case? 1 BY MR. CRITION: 2 A. No. He just asked me if I knew about Jeffrey 2 Q. Why did she call you? 3 and witnessed what happened with Jeffrey, and that's 3 MR. HOROWITZ: Forni 4 about it. And he asked me if we wanted to meet and 4 THE WITNESS: She called me m fill me in on 5 talk. And I said that I wasn't sure, you know, because 5 the case, and I knew she was like who she said she 6 I've had private detectives corning. 6 was, because Agent at the FBI told me she 7 And I wasn't sure who was on whose side, so I . 7 would be calling me. She pretty much told me what 8 told him that I would call him back. 8 was going on in his criminal case, and that's about Q. Was he soliciting or pitching his services to 9 it. And she said you might want to protect 10 you as a lawyer? 10 yourself and get a lawyer, and that's about it. 11 MR. HOROWITZ: Form. 11 BY MIL CIRITTON: 12 THE WITNESS: No. 12 Q. Okay. Did she recommend anybody, any lawyers? 13 BY MR. CRITPON: 13 A. I don't remember. 14 Q. Well, why did he want to meet with you? 14 Q. Do you remember her giving you any names of a 15 MR. HOROWITZ: Form. 15 • lawyer saying 'Tm going it give you three names," or 16 BY MR. CRITTON: 16 "If you need some help finding a lawyer, I'll give you a 17 Q. What did he tell you? 17 name'? 18 A. He Just wanted to talk about the whole Jeffrey 18 A. She said if I wanted a lawyer, to call back. 19 thing with me. 19 And she had a list, I think, but she didn't recommend 20 Q. Why would you want to talk with him about it? 20 anybody. 21. MR HOROWITZ: Form. 21 Q. Did you ever call her back for her 22 THE WITNESS: Because I heard that, you know, 22 recommendation? 23 there's like stuff going on with, with people, so I 23 A. No. I talked to Agent about it, and 24 kind of wanted to protect myself. 24 she said basically what I was supposed to do. And she 25 25 said it was up to me basically if I wanted to hire a Page 148 Page 150 BY MR. CRITTON: 1 lawyer or not. 2 Q. What did you hear was going on with people? 2 Q. Did Agent give you any names? 3 A. Nothing. I just heard that, it was when —I 3 A. No. forget who called me and said — I think it was Maria or 4 Q. Did anyone from the FBI or US attorney's something. She said, you know, to protect yourself, you 5 office ever give you a name of a lawyer — 6 might want to get a lawyer. 6 A. No. Q. Who is Maria, MIME ) 7 Q. — to contact? 3 A. I think so. A. No. 9 Q. Was that the US attorney? 9 Q. Did you speak with — let mat back. 10 A. Yes. 10 When you spoke with Ms. 11 Q. And had you ever met with IM 11 that before or after Mr. Herman contacted you? 12 A. No. 12 A. It was before. 13 Q. You never met the lady? 13 Q. And then how much time transpired or rested 14 A. No. 14 before Mr. Herman contacted you about whether you were 15 Q. So somebody who you just referred to as 15 involved or to ask you questions about Jeffrey Epstein? 16 calls you out of the blue. Why would — 16 A. About a couple of months. 17 A. She -- 17 Q. And do you know when Mr. Herman approximately 18 Q. Let me finish my question. 18 timewise called you? 19 You said you let me ask you this. Did the 19 A. No. 20 ady, who you have now identified as 20 Q. Was it before Jane Doe 4 moved in with you 21 assistant US attorney, did she call you 21 that sununer? 22 before Mr. Hemian or after Mr. Heiman? 22 A. Yes. 23 MR. HOROWITZ: Form. 23 Q. Was it shortly aver the police had 24 THE WITNESS: Before. 24 contacted you? 25 25 A. No. It was a little while after that. 7 (Pages 147 to 150) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107838 Page 151 Page 153 i Q. Was it after the FBI interview? Q. Okay. And did you investigate him at all? 2 A. Yes. 2 A, Yes. 3 Q. Do you know when the FBI interview took pi 3 Q. Did you go online? 4 A. I third( I was a sophomore in college or 4 A. !looked his name up. 5 maybe -- 5 Q. Where? 6 Q. That's '05, that would have been -- 6 A. Online. 7 A. I think I was a sophomore or freshman. 7 Q. And what did you find out? 8 Q. So that would have been what, approximately 8 A. That he was a sexual abuse attorney. 9 '07? 9 Q. And did you ask him before you hired him 10 A. Yes. 10 whether he was representing any other people associated 11 Q. Let me just stick with — so when Mr. Haman 11 with the Epstein matter? 12 called you the first time, did he say what he was doing? 12 A. No. 13 He obviously wanted to get some information about 13 Q. When you called him back and before you hired 14 Jeffrey Epstein and you, right? 14 him, did you ask him how he ever got your name? 15 MR. HOROWITZ: Form. 15 A. No. 16 THE WITNESS: It didn't sound like it. 16 MR. HOROWITZ: going to assert the 17 BY MR. CAI-ETON: 17 privilege. I understand what you're trying to do, 18 Q. Did you say "How did you get my name?" 18 but I'm going to assert the privilege as to the 19 A. No. 19 conversation in that the entire conversation was 20 • Q. Were you surprised that sane lawyer out of the 20 leading towards the result of obtaining a lawyer. 21 blue called you to ask you about Jeffrey Epstein and you 21 So that's my position, and we can -- 22 didn't know who they were a how they had gotten your 22 BY MR. CRITTON: 23 ,me? 23 Q. Are you going to follow your lawyer's — if he 24 A. I thought — I had no idea. That's why I 24 tells you — if he claims a privilege, are you asserting 25 didn't agree to meet with him at first, because I didn't 25 that privilege? Page 152 Page 154 1 know if he was, you know, on your side or their side or 1 A. Yes. 2 hying to check me or whatever, so that's why I waited a 2 MR. HOROWITZ: Yes. I just want to tell her 3 little bit to call him back. 3 what I'm invoking. 4 Q. When you did call him back, however much time 4 As to this second telephone conversation, I'm 5 transpired, what did you say to him? 5 instructing you that you have a privilege not to 6 MR. HOROWITZ: We're going to assert the 6 answer questions about the second conversation. 7 privilege on that, but you can make the proffer. 7 THE WITNESS: Okay. 8 BY MR. CRITTON: 8 BY MR. CRITTON: 9 Q. You called him back, correct? 9 Q. Did you hire Mr. Herman in the course of the 10 A. Yes. 10 second conversation? lust yes or no. 11 Q. Okay. All you knew, he was a lawyer? 11 A. He came to Orlando and we met and then -- 12 A. Yes. 12 Q. No, no. Well get there. 13 Q. You didn't know who he represented? 13 In the second conversation, did you say "I 14 A. No. 14 want to hire you" or did you just say -- 15 Q. If anyone? 15 A. No. 16 A. No. 16 Q. — "I'd lilte to meet with you"? 17 Q. Okay. He could have been Mr. Epstein's 17 A. "I'd like to meet with you." 18 lawyer, he could have been anybody's lawyer, for all you 18 Q. Okay. So how long did the second conversation 19 'mew, right? 19 last? 20 A. I mean he told me he —10ce no, I think he . 20 A Not long. 21 told me he wasn't — he was like representing — I don't 21 • Q. • Five 'minutes? 22 know, he didn't say -- I don't know. I don't remember 22 A. Just about. 23 why I actually called him back. 23 Q. What did you tell him? 24 . Q. Why did you call him back? 24 MR. HOROWITZ: I'll instruct her not to 25 A. Because I wanted to hear what he had to say. 25 answer. Well assert the privilege, a privilege, OXISCIZA 8 (Pages 151 to 154) .. (561) 832-7500 PROSE COURT REPORTING AGENCY,: INC. (561) 832-7506 EFTA01107839 Page 155 Page 157 the attorney/client privilege. I. everybody and her parents fording out and her sister MR. CRiTFON: I understand. 2 finding out and her being depressed and humiliated, I 3 BY MR. CRITTON: 3 mean yeah, I would assume that's some trauma for her. 4 Q. And you are going to follow his direction, 4 Q. Okay. Has she told you she's depressed? 5 correct? 5 A. Yeah, and when she found, her parents found 6 A. Yes. 6 out and all that, she was depressed, she told me. Q. And until Mr. Herman came to Orlando -- strike 7 Q. The way you've described it is Jane Doe 4's that. 8 main emotional or psychological — let me strike that. 9 How much time passed between the second 9 Her main psychological injury from at least 10 conversation and Mr. Herman came to Orlando? 10 the way you've described it is she's been humiliated and 11 A. Not long. Maybe a couple weeks. 11 depressed because somebody other than her friends, in 12 Q. Did anyone else come up with Mr. Herman to 12 particular, her parents and her sister, found out that 13 meet with you? 13 she had gone to Mr. Epstein's house? 14 A. No. 14 A. Not from that. From just going when she was 15 Q. Just you and Mr. Herman met? 15 younger. She regrets it, and she even told me i wish I 16 A. Yes. 16 never went when I was younger. i was confused and -- 17 Q. Where did you meet? 17 Q. She — fm sorry. 18 A. At Starbuck's. 18 A. Go ahead. 19 Q. Okay. And did you sign an agreement then to 19 Q. Did she tell you that she went — well, you 20 have him represent you? 20 !mew she went both before she was 18 and after she was 21 A. After lmet with him and heard everything he 21 18, right? 22 said, yes, I did. 22 A. Yeah, l guess. 23 Q. Okay. Before that, that is, before you 23 Q. All right. And did she tell you she was more 24 actually hired him, bad you discussed with him what had 24 confined when she was 17 than when she was 18, or did 25 happened to you, that is — well, let me strike that. .25 she ever describe to you that there was a difference Page 156 Page 158 1 In the second conversation did you give him 1 when she went at 17 or 18? 2 any information as a witness as distinct from your own 2 A. I don't know. She never described anything to 3 personal circumstances? 3 me. 4 MR. HOROWITZ: i have to assert the privilege. 4 Q. Did she ever say "Gees, the day I turned 18 5 BY MR. CRITTON: 5 and was a freshman at college, i still went to see 6 Q. And you are going to follow his direction? 6 Mr. Epstein"? 7 MR. HOROWITZ: Yes. Good try. 7 A. No. 8 MR. CRITTON: That's not a good try. Just -- 8 Q. Okay. Did she ever say, "Well, gee, just BY MR. CRITTON: 9 before I turned 18, i had these emotional injuries, but 10 Q. Has Jane Doe 4 told you — let me strike that. 10 at 18 everything was okay when I went to Mr. Epstein's'"? 11 I'd ask you to assume that she's brought the 11. Did she ever say that to you? 12 same S50 million lawsuit that you have, different facts, 12 MR. HOROWITZ:. Fa 13 but she wants 50 million bucks too, at least in her 13 THE WITNESS: No. 14 complaint that she's asserted against Mr. Epstein. 14 BY MR. CRITTON: 15 Did she ever tell you any injuries or damages 15 Q. All right. Did she ever distinguish to you 16 that she ever sustained as a result of being at 16 having been to Mr. Epstein's before she was 18 or after 17 Mr. Epstein's home? Has she ever said anything to you 17 she was 18; that is, that any time period was different 18 about it? 18 for her? 19 A. We never really talked about her. 19 A. I don't remember. 20 Q. Even through today's date, she's never told 20 Q. You don't remember her telling you that, 21 you any damages or how she was damaged or any injuries, 21 correct? 22 psychological or otherwise, that she ever sustained at 22 A. No -- yes. I don't remember her telling me. 23 Mr. Epstein's house; is that correct? 23 Q. All right, I understand. 24 She's never discussed that with you? 24 Now you've known Jane Doe 4 for a long time? 25 A. I mean other than being humiliated by 25 A. Yes. 9 (Pages 155 to 158) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. . (561) 832-7506 EFTA01107840 Page 159 Page 161 1 Q. Since '02, I think you told me. 1 BY MR. CRITTON: 2 She's been through some rather traumatic 2 Q. Did you ever hear him call her a-? 3 events in her life, has she not? 3 A. No. 4 A. I guess you could say that. 4 Q. What kind of things did you hear say 5 Q. Well, you know she's been arrested before? 5 to her to verbally abuse her? 6 A. Yes, when we were younger. 6 A. Just bitch, and I don'ttellkAlrber. We were in 7 Q. Pardon? 7 high school. Just, I mean I never heard him call her a 8 A. When we were younger. 8 whore or anything else you said. 9 ri I. And she haditliend named 9 Q. Fm sorry? 10 You knew didn't you? 10 A. I said or anything else you said. 11 A. Yes. 11 Q. But you were aware that he was both physically 12 Q. What did you think of_? Pretty 12 and verbally abusive to her? 13 upstanding, great guy? 13 A. Yes. 14 A. No. 14 Q. All right. And did you ever tell Jane Doe 4 15 Q. Okay. He was a jerk, wasn't he? 15 `You got to get away from this guy, he's bad news"? 16 A. Yeah. 16 A. Yes. 17 Q Pardon? 17 Q. What was her reaction? 18 A. Yes. 18 A. She was in love. So she didn't really -- 19 Q. And beat Jane Doe 4, didn't he? 19 Q. And she carried oniacal, a long-term 20 Physically abused her? 20 physical relationship with did she not? 21 A. I mean he pushed her. He didn't beat her up, 21 A. Yes. 22 but yes, he pushed her before. 22 (*.you ever, were you ever aware whether she 23 Q. Did you ever see him slam her face down into 23 and were pregnant? 24 the hood of the car, into the dashboard of a car? 24 MR. HOROWITZ: Form. 25 A. No. 25 THE WITNESS: No. Page 160 Page 162 1 MR. HOROWITZ: Form. 1 MR. HOROWITZ: I bow what you mean. 2 BY MR. CRITTON: 2 BY MR. CRITTON: 3 Q. Are you aware, did she ever tell you that that 3 Q. Of coarse he can't but are you aware that 4 happened? 4 she became pregnant with ? 5 A. No. 5 A. Yes. 6 Q. Did you see spitting on her? 6 Q. Did she tell you that? 7 A. No. 7 A. Yes. 8 Q. Did you see her spitting back at 8 Q. On how many occasions did Jane Doe 4 disclose 9 A. No. 9 to you that she had become pregnant within 10 Q. Were you aware that had occurred? 10 MIL HOROWITZ: Form. 11 A. No. 11 THE WITNESS: Just once. 12 Q. Were you aware was a drug addict? 12 BY MR. CRITTON: 13 A. Yes. 13 Q. Okay. She never told you — so let me strike 14 Q. Were you aware that he was an alcoholic? 14 that. Are aware that she became pregnant, even if 15 MR. HOROWITZ: Form. 15 not with ME, on two other occasions? 16 THE WITNESS: Yes. 16 MR. HOROWITZ: Object to the form, and let me 17 BY MR. CRITTON: 17 just, I have to say this. You are potentially 18 Q. You were around when he verbally abused her 18 disclosing very intimate personal medical 19 and called her awful names, weren't you? 19 information about one person to another, and I 20 A. One or two times. 20 think you are touching on some boundaries that you 21 Q. Okay. Did you ever hear him refer to her as a 21 shouldn't be going on, but go ahead. 22 whore? 22 BY M. CRITTON: 23 MR. HOROWITZ: Form. 23 Q. Do you want the question back? 24 THE WITNESS: No. 24. A.. No. 25 25 Q. No what? That was your answer? 10 (Pages 159 to 162) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC.. (561) 832-7506 EFTA01107841 Page 163 Page 161: 1 A. I don't want the question back. 1 Q. So at least in high school, you're saying that 2 Q. Do you remember the question? 2 you drank alcohol, right? 3 A. Yes. 3 A. Yes. Q. Okay. I don't. 4 Q. Even though you were underaged? 3 (A portion of the record was read by the 5 A. Yes. reporter.) 6 Q. And did you use pot? MR. HOROWITZ: Form. 7 A. No, not in high school. THE WITNESS: I don't think that we should 8 Q. Never? 9 really be talking about her details, intimate 9 A. No. 10 details. 10 Q. Okay. Did you ever use any other type of 11 BY MR. CRITTON: 11 illegal drugs? 12 Q. Can you answer my question? 12 A. No. 13 MR. HOROWITZ: Just answer what you know. 13 Q. Any prescription drugs from someone else, like 14 THE WITNESS: I just told you I know once what 14 a XBIKax or percocet or — 15 happened. 15 MR. HOROWITZ: Talking about high school? 16 BY MR. CRITTON: 16 MR. CRITTON: High school. 17 Q. That's all you know, that she became pregnant? 17 THE WITNESS: No. 18 A. Yes. 18 BY MR. CRITTON: 19 Q. Did she tell you how the pregnancy was 19 Q. Since high school, you have continued to 20 terminated? 20 drink? 21 A. Abortion. 21 A. Yes. 22 Q. Was she pretty upset about that? 22 Q. And I've seen both in the Kliman report is you 23 A. Yes. 23 continue to drink alcohol, sometimes you will drink to 24 Q. What kind of drugs did take? Was he a 24 excess? 25 seller? Let me strike this. 25 A. Yes. Page 164 Page 166 1 Was also selling drugs? 1 Q. All right. And as well, you have used pot? A. I don't know. 2 A. Yes. Q..liou ever see Jane Doe 4 use illegal drugs 3 Q. Since high school. How often do you use with 4 marijuana? A. No. Just drink. 5 A. I have, hardly ever. 6 Q. Okay. So you guys are best friends and - 6 Q. Xanax, have you had Xanax? 7 A. She would never do it in front of me, because 7 A. No. 8 I don't do it in front of her or I would never do 8 Q. Have you ever tried cocaine? 9 anything in front of her. 9 A. Na 10 Q. If you do drugs, you don't do them in front of 10 Q. Never? So if someone says that you have used 11 her. 11 cocaine and they have seen you, that would be a lie? 12 A. Well, she knows — sorry, I didn't mean to say 12 MR. HOROWITZ: Form. 13 that. She knows I don't do drugs, so if she ever did 13 THE WITNESS: I don't ever remember doing —1 14 drugs, she would never do it in front of me, because she 14 don't do drugs at all. 15 know I was really against that in high school. 15 BY MR. CRITTON: 16 I was good. The most I would — like I drank, 16 Q. My question is if someone says they have seen 17 but so if she had ever done drugs with him, she wouldn't 17 you do coke, that would be a lie? 18 have done it in front of me. She would just drink. 18 MR. HOROWITZ: Form. 19 Q. So if she's used Xanax and she's used pot and 19 BY MR. CRITTON: 20 she's used ecstasy and if she's used cocaine, any other 20 Q. Or is it possible you did do coke and you just 21 drugs, that would be news to you? 21 don't remember? 22 A. I mean I know she did like some of that. I'm 22 A. I ?neon I might have tried it once, but I don't 23 not going to — whatever. But I, but she wouldn't do it 23 do coke atoll, so 24 in front of me, because she knew that I wasn't like 24 Q. Would the same thing be true of Xanax, that if 25 that. 25 someone said they had seen you take Xanax, you may have 11 (Pages 163 to 166) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107842 Page 167 Page 169 1 tried it once or twice, but you don't do it regularly? 1 finished in May of '09, correct? 2 A. That would have a lie. I don't do Xanax. 2 A. Yes. . 3 Q. You've never done it? 3 Q. But you are still there right now? 4 A. No, I don't do prescription chugs. Only thing 4 A. Yes. 5 I have ever done is Adderall. 5 Q. And why are you in your fifth year? 6 Q. Did you get that from friends? 6 A. Because Pm getting a minor too. 7 A. Yes. 7 Q. Whalwasot or? 8 Q. Let me go to the FBI for just a minute. When 8 A. 9 did the FBI contact you? 9 Q. .ik Wh ur minor? 10 A. I believe it was my freshman year of college, 10 A. 11 I think. 11 Q. And when did you decide to take a minor? 12 Q. Let's see, that would have been the '05-'06 12 A. I decided about a year after I got there. 13 school year? 13 Q. So that's what, an extra year? In order to 14 A. Yes. 14 get the courses that you want, you had to be there an 15 Q. And now you were at EM? 15 extra year? 16 A. Yes. 16 A. Yeah, about. I mean I could really finish 17 Q. And that's in Orlando. Is that a community 17 this semester, but I wanted to study abroad for the 18 college? 18 hospitality trip in the summer, so I'm just waiting for 19 A. Yes. 19 that and then I'm graduating in the summer. 20 Q. I asked two questions there. It's an Orlando 20 Q. At the end of the summer? 21 community college, correct? 21 A. Yes. 22 23 24 ..And A. Yes. did you get, did you graduate from 22 23 24 Q. Where is the summer trip taking you? A. To Italy. Q. All right. Where will you go? 25 A. Yes, I did. 25 A. To Florence. Page 168 Page 170 1 Q. Did you get an AA degree? 1 MR. HOROWITZ: Cool. 2 A. Yes. 2 BY MR. CROTON: 3 Q. In what? 3 Q. How long will you be there? 4 A. Just general. 4 A. For about a month. 5 Q. Kind of liberal arts? 5 Q. And this is through.? 6 A. Yes. 6 A. Yes. 7 Q. After getting your -- when did you graduate? 7 Q. And who pays for this, your parents? 8 A. Around '07. 8 A. I'm taking out loans for it. 9 Q. Spring of'07? 9 Q. And your school, did your parents do Bright 10 A. Yes. 10 Futures? Start again. Were you entitled to Bright 11 Q. And where did you go to school after that? 11 Futures? 12 A. 12 A. No. 13 Q. also in 13 Q. Any form of the Bright Futures program? 14 Orlando? 14 A. No. 15 A. Yes. 15 Q. There is another one. 16 Q. And have you graduated ftomIN yet? 16 A. No. 17 A. Not yet. 17 Q. How about did your parents do prepaid at all? 18 Q. So if -- you would have started ■ in the 18 A. I don't know. I don't think so. 19 fall of'07? 19 Q. Have your parents supported you while you have 20 A. Yes. 20 been at least the four years in school? 21 Q. So if you had two more years, you had two more 21 MR. HOROWITZ: Form. 22 years to finish at M, assuming you took full loads? 22 THE WITNESS: Yeah, I mean I always worked 23 A. Yeah. 23 too. 24 Q. All right. So '07 to '08 and '08 to '09, so 24 BY MR. CRITTON: 25 if you had finished in two years, you would have 25 Q. Okay. Let me just go back to the FBI for just 12 (Pages 167 to 170) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107843 Page 171 Page 173 1 a minute. So the FBI came to you during your freshman 1 strike that. What did they say to you first? 2 year at IMMI, which would have been '05-'06. 2 A. They just asked me what happened with Jeffrey • 3 Did they come du Sthe '05 time period, that 3 and they said that, that I had to tell them, you know, 4 is, shortly after the police, or was it into 4 exactly what happened. 5 the '06 time period? 5 So I admitted — they asked me ill told the 6 A. I don't remember. 6 officers everything when they came, and I admitted that, 7 Q. Who came? 7 you blow, I didn't tell them everything. 8 A. Agent=. 8 And then so I just basically went into detail 9 Q. Just her? 9 with them and, you know, told them everything about what 10 A. Her and another guy. I forget his name. 10 happened. 3.1 Q. They drove to Orlando? 11 Q. Okay. Now is it your testimony that you told 12 A. Yes. 12 them the truth? 13 Q. Where did you meet them? 13 A. Yes. 14 A. Starbuck's. 14 Q. Okay. Did you make any errors in what you 15 Q. Sarno place you met Mr. Herman? 15 told -- strike that. 16 A. Yes. 16 Did you misrepresent, lie or deceive the FBI 17 Q. Did you meet anybody else there? 17 in any way? 18 A. No. 18 A. No. 19 Q. All right. So you are at Starbudc's. How 19 Q. So if I got the FBI statement, you would say 20 much time did you spend with the FBI at Starbuck's? 20 that would be accurate even if you've testified 21 A. Probably about two hours. 21 differently today? 22 Q. Who bought the coffee, do you remember? 22 MR. HOROWITZ: Form. 23 A. They did. 23 BY MR. CRITTON: 24 Q. All right. And did they take a taped 24 Q. Right? 25 statement from you at all? 25 A. I mean yes. I told them, I didn't tell the Page 172 Page 174 1 A. I can't remember if they did. 1 cops everything, and I pretty much told them -- it took 2 Q. Did they take a statement at all? Was anybody 2 me awhile, but I told them, you know, what happened. 3 writing? 3 Q. Okay. After you talked with the FBI on that A. They took a statement, yeah. 4 occasion, did they tell you that you might have the Q. Did you ever sign anything? 5 ability to bring a civil lawsuit for money? A. I think so, yes. 6 A. No. Q. Have you ever seen the statement that you 7 Q. Did they mention anything about a civil B signed that you gave to the FBI? 8 lawsuit? 9 A. No. 9 A. No. 10 Q. Have you ever requested it? 10 Q. Did they mention anything about any criminal 11 A. No. 11 charges that they were investigating? 12 Q. Did they ever ask you to read it? 12 A. Yes. 13 A. No. 13 . Q. Did they tell you why they were investigating 14 Q. So you don't know whether they took down 14 criminal charges, that is, why it was a federal matter 15 correctly what you told them? 15 as distinct from a state matter? 16 A. Yeah, I mean I actually, I think they did have 16 A. Because I think he, I guess 'think it got 17 a tape recorder with them. 17 turned down by the state or something, because he hired 18 Q. Are you sure? 18 great lawyers that represented him well, and I don't 19 A. I think so, yes. 19 think — I think the judge turned it down. So they, the 20 Q. Did they swear you to tell the truth? 20 federal government picked it up, because they didn't 21. MR. HOROWITZ: I don't know. 21 think it was fair, the sentence the state gave him. 22 THE WITNESS: I can't remember. Pm pretty 22 Q. You mean the FBI said that to you? 23 sure they did. 23 A. Well, 'think Mars what they — something 24 BY MR. CRITTON: 24 Ince that, l don't know. 25 Q. Okay. And whardid you tell them -- let me 25 Q. You could have only gotten that idea from 13 (Pages 171 to 174) (561) 832-7500 PROSE COURT REPORTING AGENCY,. INC. (561) 832-7506 EFTA01107844 Page 175 Page 177 1 them, because you didn't know at the time, did you? 1 Q, M? 2 A. Yeah, they just said it was a federal 2 A. Just the letter 3 investigation now, but now I know why. 3 Q. Okay. Do you have any siblings? 4 Q. Did, at that time did they mention IM 4 A. Just a brother. 5 at all, the assistant US attorney? 5 Q. How old? 6 A. No, I don't think so. 6 A. I think he's like 36, 37. 7 Q Did you ever get any papers from either the 7 Q. Are you close? 8 FBI or from the US attorney's office? 8 A. Thirty-seven. No. I mean he lives in a 9 A. I don't remember. 9 different state, so — 10 Q. When you said — culler today you said 10 Q. You are how old now? 11 called. And then I said and you saids 11 A. I am 22. 12 How many times have you spoken with 12 Q. So there is a 14-year difference between the 13 13 two of you? 14 A. I think just once when she pretty much wrapped 14 A. I thinlc, yeah. I think he's like 36 or 37. 15 up the whole case. 15 Q. So when he was almost out of high school, y ou 16 Q. When you say she wrapped up the case, at the 16 were only four years old? 17 time that she called you to tell you about what was 17 A. Yeah, I guess so. 18 going on, what did she tell you? 18 Q. He would have been about 18, you would have 19 A. I don't remember exactly. She just said about 19 been about four, if there is a 14-year difference. 20 what was, told me what happened with the criminal case 20 A. I remember him, he was always in college. He 21 or what was going on with it or something. 21 was off to college and he would come home. 22 MR. CRITTON: Okay. Let's go about ten more 22 Q. Where did he go to college? 23 minutes. Is that all right? 23 A. He went to IUP. 24 MR. HOROWITZ: Are you okay? 24 Q. IUP? 25 THE WITNESS: Yes. 25 A. Uh huh. Page 176 Page 1.7 BY MR, CRITI'ON: 1 Q. What's that? 2 Q. Tell me, you were born in Pittsburgh? 2 A. That's in Indiana somewhere. 3 A. Yes. 3 Q. What does he do fora living? 4 Q. You moved to Florida when you were a freshman A. Hes a cop. 5 in high school? 5 Q. When the Palm Beach police officers called 6 A. Yes. 6 you — let at strike that 7 Q. Which would have been the 0 — 7 Does your brother know that you were involved 8 A. 2000. 8 with Mr. Epstein or that you are involved in a lawsuit' 9 Q. I'm sorry, 2000? 9 A. I've never told him, but unless my parents 10 A. Yes. 10 told him, I don't think so. 11 MR. HOROWITZ: That doesn't sound right. 11 Q. When the police called, did you ever think of 12 THE WITNESS: Or 2001, I think. 12 calling your brother, who was a police officer at the 13 MR. HOROWITZ: Fm sorry. 13 time? 14 THE WITNESS: Yeab, I think it was 2001. 14 A. No. 15 . MR. HOROWITZ: You are right, Tin wrong. 15 Q. Why not? 16 BY MR. CFUTTON: 3.6 A. Because we're not, we don't really share 17 Q. And did you start — so it would be 2001 17 everything. Like he's a guy. I didn't want him to find 18 through May approximately of 2002, right? 18 out what happened with Jeffrey. 19 A. (Witness nods head up and down.) 19 Q. Your parents, when you moved down here, 20 Q. Would have been your freshman year? 20 describe your house for me that you moved in. The house 21 A. I believe so. 21 on Road, did you live there during all four years in 22 Q. All right. Where did our is move to? 22 high school? 23 A. They moved to 23 A. Uh huh. 24 Q. What was the address? 24 Q. Describe it forme. How big a house was it? 25 A. It was just late a three-bedroom house. 14 (Pages 175 to 178) (561) 832-7500 PROSE COURT REPORTING AGENCY INC. (561) 832-7506 EFTA01107845 Page 179 Page 181 1 Q. Three bedroom, three bath, two bath? 1 A. Yes. 2 A. Yeah. 2 a...1 saw someplace else, does he have a. 3 Q. Did you have your own room? too? 4 A. Yes. 4 A. Yeah, me and him, we had started it when I was 5 Q. Okay. And when you were what, 15, I saw in 5 younger, but we just kind of restarted it back up Kliman's report you got your own car, a red Cavalier? 6 .f rece u So we just sel 7 Yes? It's like an online website. B A. Yes. 8 Q. So you order them from like a Cushnut or Q. Who bought that for you, Mom and Dad? 9 whoever happens to be — 10 A. Yes. 10 A. Buyers. 11 Q. Brand new car? Who did yousupply — do you supply toe 12 13 A. No. It was used. Q. And did you have that so you could use it ▪11 i. 13 or individuals? A. Just individuals. Like it's all online. 14 during high school? 14 Q. So you've never had hie a warehouse where you 15 A. Yes. 15 means? actually buy and sell 16 d you take that car with you then to 16 A. No. 17 18 la A. No. 17 18 Q. It's strictly A. And accessories, yes. parts? 19 Q. Did they give you another car? 19 Q. How about your mom? Did she work outside the 20 A. I got into a car accident and the car got 20 home or was she a stay-at-home morn? 21 totaled. And so yeah, so they got me a Mustang that I 21 A. She worked at a craft store when I was 22 use. 22 younger, and other than that, she was home. 23 Q Do you still have that today? 23 And she just recently got a job, but she's 24 A. Yes. 24 mostly home. 25 Q What year is that? 25 Q. What does she do now? Page 180 Page 182 1 A. A'99. 1 A. She works at a craft store again. 2 Q. In addition, the house that you lived at on 2 Q. Okay. But basically your dad was the sole 3 some acreage? 3 source of support for you and your family? 4 A. It had, I think it's an acre. 4 A. Yes. 5 Q. Pool? 5 Q. And that's his be' an employee of 6 A. Yes. 6 the city ot the Town o 7 Q. In-ground pool? 7 A. Yes. 8 A. Yes. 8 Q. All right. And would you have considered 9 Q. And your mom and dad both had cars? 9 yourself at least in your own mind, were you middle 10 A. Yea. 10 class, upper middle class? 11 Q. Did your — what kind of work did your dad do? 11 A. I would say middle class. 12 A. He does work for the city, building 12 Q. Dad go to college? 13 inspections. 13 A. No. 14 Q. Novi? 14 Q. Mom? 15 A. Yeah, he still does it now. 15 A. No. 16 Q. Is he a contractor or was he at one point? 16 Q. Are you the — your brother went to college? 17 A. I think he does some contracting. 17 A. Yes. 18 Q. So he inspects, does building inspections for 18 Q. And now you've been able to go to college? 19 what ci 19 A. Yes. 20 20 Q. Pretty happy childhood? 21 Q. The city o 21 A. Yes. 22 A. Uh huh. 22 Q. Any kind of traumatic events in your childhood 23 Q. Yes? 23 in anyway? 24 A. Yes. 24 A. No. 25 Q. Soho's an employee of the cityalli a l Q. „Anyone during your life that's very close to acti 15 (Pages 179 to 182) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107846 Page 183 Page 185 you that has died, has passed any? 1 have on a nice Vineyard Vines shirt today. A. No. 2 A. Thank you. I like to look presentable. 3 Q. Ever been in any kind of automobile accidents 3 Q. Pardon? or any kind of accidents where you were a plaintiff in a 4 A. I said I wanted to look presentable. lawsuit -- well, where you were injured? 5 Q. All right. Do you stay up on fashion like 0 A. No. 6 Tory Burch, those kind of things, those types of 7 Q. I saw a reference someplace to Cameron & 7 designers? Are you up on other designers? Do you like Gomalez or something like that. 8 to wear design clothes? 9 Do you know a lawyer named Glenn Cameron? 9 A. Just Abercrombie I lice, and maybe not 10 A. (Wittsz shakes head from side to side.) 10 anything too expensive, but — 11 Q. No? Doesn't mean anything to you? 11 Q. And during the time that you were in high 12 A. Uhuh. 12 school and now that you are in college, and I know you 13 Q. Other than this lawsuit, have you ever been, 3 said you have worked as well part of the time that you 14 have you ever made a claim against anyone? 14 were in college, do you tend to buy, to keep up with 15 MR. HOROWITZ: Form. 15 fashion? Lace to dress up? 16 BY MR. CRITTON: 16 A. I by to. 17 Q. For any type ofinjuries? 17 Q. I'm sorry? 18 A. No. 18 A. I try to, yes. 19 Q. Emotional or otherwise? 19 Q. All right. And during the time that you were 20 A. No. 20 in high school, did your parents, were they able to 21 Q. Have your parents ever been a plaintiff or a 21 provide for you so that you always felt that you were 22 defendant in a lawsuit? 22 well dressed among your peers? 23 MR. HOROWITZ: Form. 23 A. Actually, I had to buy all ofmy clothes. 24 THE WITNESS: I don't think so. 24 Q. And were you working at the time? 25 25 A. Yes, I was. Page in; Page 186 1 BY MR. CRITTON: Q. All right. When you say -- your parents never 2 Q. Have you ever been convicted ofa crime? 2 bought you anything? 3 A. No. 3 A. I mean they bought me a few things, but mostly 4 Q. Have you ever been arrested for any reason? 4 I bought my clothes. 5 A. No. 5 Q. Starting when? 6 Q. Have you ever had to hire the services of a 6 A. About when I was in high school. 7 lawyer at any time before? 7 Q. When you were a freshman? A. No. 8 A. Yeah. 9 MR. CRITTON: All right. Let's take a break 9 Q. Well, when you were still living in 10 for lundh. 10 Pittsburgh, did you ever have a job? 11 THE VIDEOGRAPHER: Going off the record at 11. A. No. 12 1:11 pm. 12 Q. Okay. When you started working in, or when 13 (A lunch recess was taken.) 13 you moved down to South Florida in your freshman year, 14 THE VIDEOGRAPHER: We're back on the record at 14 did you have a job? 15 1:56 pm. 15 A. No. 16 BY MR. CRITTON: 16 Q. When did you lust obtain any kind of 17 Q. Jane Doe 7, we're back from lunch now, and as 17 employment? 18 you know, I've done, certainly you know I've done the 18 A. I first got a job, I think it was, I was at, I 19 deposition of Jane Doe 4. I have also done the 19 worked at Ultimate Fitness, and I think that was when1 20 deposition ofMs. Jane Doe 3 in pan. 20 was 16,1 think. 21 Would it be correct to describe you as someone 21 Q. Actually you say in your answer to 22 who is interested in fashion, pretty much up on fashion, 22 interrogatory number two, which is Exhibit 2, you say 23 likes to dress fashionably? 23 your first job was at Ultimate Fitness out in Wellington 24 A. I guess you could say that. 24 at the kids club at the front desk in 2004, 2005, which 25 Q. Pm not saying that's bad or good, and you 25 would have been your senior year? I Sr 16 (Pages 183 to 186) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107847 Page 187 Page 189 1 A. Yes, it was my senior year. 1 THE WITNESS: Yes. 2 Q. So would it be a correct statement up until 2 BY MR. CRI17ON: 3 the time of your senior year, your parents provided for 3 Q. Pardon? 4 you in terms of clothes and what you needed to wear or 4 A. Yes. 5 what you needed for high school? 5 Q. Okay. So i n the '04, for the '04 time period 6 A. I mean yeah, they tried to. 6 that you were working for Ultimate, because they 1099'd Q. Sure. And you thought that you, amongst your 7 you, then you had o do like a 1040 form, tax return? 8 peers, you wore well dressed? 8 MR. HOW WITZ: Form. 9 A. I mean I tried to be. 9 BY MR. CRITTON: 10 Q. All right. And then when you started working 10 Q. Did you put in any of the money you had 11 for Ultimate Fitness, and then it looks like during the 11 received finm Mr. Epstein? 12 summer of '05 before you went to college, you worked at 12 MR. HOROWITZ: Form. 13 Abercrombie & Fitch? 13 THE WITNESS: He never made me fill out a tax 14 A. Yes. 14 form, so — 15 Q. So you got a discount on what you bought? 15 BY MR. CRI TTON: 16 A. Yes. 16 Q You wouldnit. Mr. Epstein is not the IRS, but 17 Q. With the money you use earned from Ultimate 17 the IRS expects you to record income that you've 18 Fitness and Abercrombie, did you use that to buy 18 received. 19 clothes, purses, whatever else you wanted? Was that 19 MIL HOROWM: Form. 20 kind of like your spending money? 20 BY MR. CRITTON: 21 A. Yes. 21 Q. Did you put that on your 2004 tax return? 22 Q. With the money that you received from 22 A. No, I never filed taxes. 23 Mr. Epstein, did you use that to buy clothes and other 23 Q. Did you ever file a tax return? 24 'Wok-knacks, do fir things that you wanted to do? 24 A. I don't mil ly know. 1 fill out whatever they 25 A. !mean I actually saved a lot of it up until 25 make me till out for a job. Page 188 Page 190 1 college, but I'm sure I spent some of it on food and 1 Q. I don't know what you have done or haven't 2 clothes, I mean whatever. 2 done. My question to you is have you ever filled out a 3 Q. How much money did you earn during the time 3 form to report your income to the IRS? 4 that you went to Mr. Epstein's house? 4 A. Yes. 5 A. Mini( it was around 2000 over — 5 Q. And did you strut doing that when you rust 6 Q. Did you put that on your tax rennet? 6 started working for Ultimate? MR. HOROWITZ: Form. 7 A. Yes. 8 THE WITNESS: No. 8 Q. During the time you worked for Ultimate, which 9 BY MR. CRITTON: 9 was 2004, which is one of the years that different 10 Q. Did you file loxes during that time period? 10 places that you have alleged that you were with 11 A. )(didn't make enough money to have to file 11 Mr. Epstein, did you ever report any of the income that 12 taxes. 12 you received from Mr. Epstein? 13 Q. When you worked at Ultimate in '04 and '05, 13 MR. HOROWITZ: Form. 14 they would have given you — were you an employee or 14 THE WITNESS: No. 15 were you an independent contractor, they gave you a 15 BY MR. CRITTON: 16 1099? 16 Q. Okay. And some of the money that you did earn 17 A. Yes. 17 (tom Mr. Epstein, ifl understood it, you saved it and 18 Q. Yes, a 1099? 18 you used it for college or during your college years? 19 A. Yes. 19 A. I mean I saved it. I don't really remember 20 Q. Did you therefore have to pay taxes? 20 what I used it for. 21 MR. HOROWITZ: Form. 21 Q. Okay. You indicated earlier that you would 22' BY MR. CRITTON: 22 drink alcohol prior to your turning 21, so you were 23 Q. Let me withdraw that. 23 drinking as an underaged person, correct? 24 Did you have to fill out a tax return? 24 A. Yes. MR. HOROWITZ. Form. 25 Q. And it looks -- not looks, but from having 17 (Pages 187 to 190) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107848 Page 191 Page 193 deposed Ms. Jane Doe 3 and Ms. Jane Doe 4, it appears 1 Q. Did you use the hike ID from time to time to that you all go to clubs and have been going to clubs 2 get into clubs which required you to be 21 or to drink 3 for a long period of time. 3 alcohol? MR. HOROWITZ: Form. 4 A. Yes. BY MR. CRITTON: 5 Q. And you knew that that was a crime? 6 Q. Fair statement? 6 MR. HOROWITZ: Form. A. I mean yes, I go out. 7 . THE WITNESS: Yes. 3 Q. Okay. And before you were 21, did you have a 8 BY MR. CRITTON: 9 fake ID? 9 Q. And were you ever stopped by the police and — 10 A. Yes. 10. well, let me strike that. 11 Q. All right. And when did you first start using 11 Did the police ever look at your fake ID, that 12 a fake ID, ma'am? 12 • is, were you ever in a club when you were ID'd and 13 A. I don't remember. 13 someone said this isn't your ED? 14 Q. Was it when you watt away to college or did 14 A. No. 15 you have one when you were in high school? 15 Q. You were able to successfully use the fake ID 16 A. 1 thinIcI had one in high school. 16 without ever being called on it, is that correct? 17 Q. And obviously it said you were what, 21 ? 17 A- Right 18 A. Eighteen. 18 . Q. And even though you knew it was a crime, you 19 Q. Well, falce ID to say you were 18? 19 still did it, correct? 20 A. Toga into the clubs, you only needed to be 20 MR. HOROWITZ: Form. 21 18. 21 BY MR. CRITTON: 22 Q. So your first fake ID said you were 18 so you 22 Q. You still used the ID? 23 could get into the clubs? 23 A. Yes. 24 A. (Witness nods head up and down.) 24 Q. Any tattoos? 25 Q. Yes? 25 A. No. Page 192 Page 194 A. Yes. 1 Q. Morality? 2 Q. And did you eventually obtain a fake ID that 2 A. Just my ears, 3 said you were 21? 3 Q. During the time that you were through the 4 A. Yes. 4 time you were In high school, which would be the summer, 5 Q. MI right. And how many different fake IDs 5 la ss the summer of '05 before you went away to 6 did you have? 6 did you and your parents go away for 7 A. I don't remember. 7 vacations? 8 Q. More than one? 8 A. We had just gone up to Pennsylvania to go 9 A. Yeah. Maybe like two or three. 9 visit my family up there, and we went down to Key West 10 Q. And who did you get them from? 10. once or twice. 11 A. I don't remember. 11 Q. Where did you stay when you went down to Key 12 Q. Did you have them made or was it a fiend's 12 West? older sister or something like that? 13 A. We stayed in Islamorada at a hotel. Sony, we 14 A. People that looked like me. 14 went to Islamorada once, and then we went to Key West 15 Q. And how would you get it? How would you get 15 and stayed at a hotel down there. 16 the fake ID? 16 Q. On another trip or the same trip? 17 A Just gave it to me, people that looked like 17 A. Another trip. 18 me. 18 Q. Have you ever been to the Bahamas? 19 Q. If they looked like you and they were over 21, 19 A. Yes. 20 they would give you their fake ID? 20 - Q. Where? 21 A Yeah. I remember one girl that I worked with, 21 A. Nassau. 22 she kind of looked like me and she gave me her II) 22 Q, With whom did you go to Nassau? 23 because she had two of them. 23 A. I went on senior cruise. 24 Q. When she had to what? 24 Q. Senior mINIa 25 A. She gave me her ID because she had two. 25 Yes, a senior trip. 18 (Pages 191 to 194) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107849 Page 195 Page 197 1 Q. ForI 1 Q. Are they friends from.? 2 A. Yes. 2 A. Yes. 3 Q. How many days were you gone? 3 Q. And when did you go to New York? 4 A Three days. 4. A. I weriaphomore year. 5 Q. Who were your roommates? 5 Q. At 6 A. I think Jane Doe 4. 6 A. Actually, maybe it was my junior year at 7 Q. Jane Doe 4? 7 I think. 8 A. Yes. 8 Q. Were you there for five, six days? 9 Q. Anyone else? How about Ms. Jane Doe 3, was 9 A. I think we were there for like five days. 10 she there too? 10 Q. And where did you stay? 11 A. No. 11 A. Her aunt has a place in the city. She's like 12 Q. Is she younger than you? 12 a stockbroker and she has a place in the city she let us 13 A. Yes. 13 stay at 14 Q. Other than the cruise to Nassau, is that the 14 Q. Did you go see shows when you were there, any 15 only time you've been to the Bahamas? 15 shows? 16 A. Yes. 16 A. No. 17 Q. Have you ever been, other than being 17 Q. Shopped? 18 Pittsburgh -- Fm sorry, Pennsylvania when you have 18 A. We went to Canal Street. 19 driven up there and been to the Bahamas, have you ever 19 Q. Any other trips outside the state of Florida? 20 been outside of the state ofFlorida other than that? 20 A. Chicago. 21 A. Yes. 21 Q. When did you go to Chicago? 22 Q. Where have you gone? 22 A. We went there I think when I was a sophomore 23 A. I went to, for like my 21st birthday, me and a 23 in college or junior. 24 group ofgirls went to Vegas. 24 Q. And who, when you went to Chicago, with whom 25 Q. Where did you stay? 25 did you go? Page 196 Page 198 1 A We stayed in The Palms. 1 A. I went with Jane Doe 4. 2 Q. The Palms, all right. Upscale. 2 Q. Which Jane Doe 4? 3 A. Well — 3 A. Jane Doe 4. 4 Q. Did you get to go upstairs on the spike where 4 Q. Who else? 5 the club was on the top of The Palms? 5 A. My friend=I. 6 A. Oh, yeah. My friends mom paid for like ow 6 Q. All right. Anyone else? 7 trip and then she paid for the hotel room, so we all — 7. A. M other friend, 8 Q. Who went? 8 Q. Is.= the one you went to Vegas with? 9 A Me and my friend and then her friend 9 A. Yes. 10 = and 1forget the other girl's name that went. 10 Q. Anyone else? 11 Q. How many days were you in Vegas? 11 A. I don't think so, WI uh. 12 A. For about four days. 12 Q. How did you get up to Chicago? 13 Q. She flew you out there from West 13 A. A friend of mine, like it was my friend's 14 A. Well, I paid for my ticket. 14 birthday. 15 Q. You paid for your ticket, but they paid for 15 Q. Which friend's. 16 the room, friend? 16 A. My friendEl it was her birthday, so we 17 . A. Yeah. 17 went to — my friend invited us up there for her 18 Q. All right. Where else have you been outside 18 birthday. 19 the state ofFlorida? 19 • Q. Olcay. Where did you stay? Which hotel? 20 A. I went to New Yost 20 ' A. My friend has a place up there, so he let us 21 Q. When did you go to New York? 21 stay at his place. 22 A. We went there on a spring break trip. 22 Q. Your friend, it was your friend's birthday. 23 Q. Who is we? 23 Is it a he? 24 A. Me and m friend =I a different =, 24 . A. Yes. l—ess 2 5 and my friend 25 Q. What was his name? • 19 (Pages 195 to 198) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. .1561) 832-7506. EFTA01107850 Page 199 Page 201. 1 A. Mario. 1 A. Just every once in a while when I could get 2 Q. Okay. And how do you know Mario? 2 away. 3 A. He was, we met him in South Beach just like 3 Q. Where do you stay? Stay at a hotel down 4 with a friend. 4 there? 5 Q. And who is we met him in South Beach? 5 A. Yeah, we usually find like a cheap hotel. 6 A. Me and ■ 6 Q. Down on the beach or something? 7 Q. 7 A. Uh huh. 8 A. 8 Q. Yes? 9 Q. Did go on this trip too? 9 A. Yes. 10 A. No. 10 Q. Soft might be you and■ or you and some of 11 Q. Why didn't she pa? 11 your other fiends that go down there? 12 MR. HOROWITZ: Form. 12 A. Uh huh. 13 THE WITNESS: She, I don't know, she was with 13 Q. Yes? 14 her boyfriend a lot. 14 A. Yee 15 BY MR. CRITTON: 15 Q. Which club did you meet Mario at? 16 Q. Was this after -- this was when you were a 16 A. I don't remember. It was so long ago. 17 sophomore where, at second year at IM? 17 Q. How long have you known Mario? Sophomore, you 18 A. I think so. 18 are a senior, plus one year, so it would have been about 19 Q. Did go too? 19 free years ago? 20 A. and .I. 20 A. Yeah. 21 Q. she went too. See, l didn't go, but I 21 Q. Okay. How many times -- does Mario live in 22 knew went. 22 Chicago? 23 A. Actually, yeah, it was birthday. 23 A. Yeah, he has a place in Chicago and a place 24 Sony. 24 like near Miami. 25 Q. Oh, it was birthday? 25 Q. Have you ever been to his place in Miami or Page 200 Page 202 A. Yes. 1 near Miami? 2 Q. Is from Chicago? 2 A. Yeah, we went there once. 3 A- No. 3 Q. Who is we? 4 Q. I thought you said you went because it was -- 4 A. Me and. 5 maybe I misunderstood you. 5 Q. And when you went up to Chicago, did you stay 6 A. It was =, it was my friend's birthday, 6 at Mario's place up there? 7 her birthday, and that's why we went there. My friend 7 A. Yeah, he let us stay up there, because we invited us to go because it was her birthday, and she 8 couldn't afford to get like a hotel room. 9 wanted to go somewhere for her birthday. 9 Q. Was Mario there at the time you were there? 10 Q. And Mario, how old — is Mario at. with 10 A. Yeah. 11 you? 11 Q. Okay. How big a place did he have in Chicago? 12 A. No. 12 A. Just Ince a condo. 13 Q. What's Mario do for a living? 13 Q. I understand. Like a two-bedroom, 14 A. He works in like the hotel industry. 14 three-bedroom, two-bedroom, one bath, one bedroom? 15 Q. Which hotel? 15 A. I think it was, yeah, like two or three 16 A. I have no idea what hotel. I know his dad 16 bedrooms. 17 like renovates hotels, stuff like that. 17 Q. And who stayed with you at Mario's? 18 Q. You met Mario in South Beach, you and met 18 A. All the girls. We all stayed in the room 19 him? 19 together. 20 A. Yes. 20 Q. And there was you, Jane Doe 4, Gonzalez, is 2/ Q. Were you at a club down there? 21. that - 22 A. Yeah, we went down for like the weekend, me 22 A. Uh huh. 23 and her. 23 Q. AndIM 1 24 Q. Have you been down there to South Beach a 24 A. Yeah. Lismittbunch of rimes 2 n2es for weel a_.... 2 .a_ ids? ZS ther iumetLo?„.a. 20 (Pages 199 to 202) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107851 Page 203 Page 205 1 A. Yeah. 1 A. Uh huh. 2 Q. So there were five of you? 2 Q. So you met Dave through him? 3 A. IJh huh. 3 A. Yes. 4 Q. Yes? 4 Q. All right. And so Dave had you up there to 5 A. Yes. 5 stay at his house? 6 Q. How old is Mario? 6 A. Well, yeah, I paid to go fly up there and 7 A. I have no idea. 7 visit him, because we started like talking a little bit. 8 Q. !she 15? Is he 20? 8 Like he was just a friend of mine. 9 A. No. 9 Q. Did you pay for the ticket or did he pay? 10 Q. Is he 25? Is he 40? 10 A. I paid. 11 A. No, he's late 20's. 11 Q. And how long were you in Chicago? 12 Q. Late twenties. Are you sure he's not older 12 A. Just for like the weekend I went up there. 13 than that? 13 Q. Had you met him down here in Orlando? 14 A. I mean I don't know. 14 A. Yeah. 15 Q. What's Mario's last name? 15 Q. And then he said why don't you come up for the 16 A. I have no idea. 16 weekend? 17 Q. So you traveled to some guy's house in, or 11 A. Well, we talked fora little bit, bents,- he's 18 condominium in Chicago and you don't know his name? 18 always down for his brother's games, so we like made 19 MR. HOROWITZ: Form. 19 friends, and then he asked me up. I wanted to come up 20 THE WITNESS: I know ifs Mario, but I forget 20 there and go visit for the weekend. 21 his last name. Ifs been like a while since I have 21 Q. Did you? 22 talked to him. 22 A. Yee. 23 BY W. CRITTON: 23 Q. And just you? 24 Q. When is the last time you did talk with Mario? 24 A. Yes, 25 A. I honestly don't even remember. It's been a 25 Q. And did you stay with him at his apartment? Page 204 Page 206 while. 1 A. Yes. 2 Q. How many times have you been to Chicago to 2 Q. Is Dave someone you've dated? 3 stay at his house? 3 A. We didn't — like we're just friends. 4 A. Just once, that one trip we have been on. 4 Q. Did you have any kind of sexual relationship 5 Q. Are you sure you haven't been up there again? 5 with David? 6 A. No oh, actually I went up there one other 6 A. No. 7 time. I have a friend that lives up there that we went 7 Q None? Just went up for the weekend? 8 to go visit. 8 A. Yeah. 9 Q. So you went to Chicago a second time? 9 Q. Did you talk to Mario when you were up seeing 10 A Yeah, I went there twice. 10 Dave? 11 Q. Who is that friend? 11 A No. 12 A. My friend Dave. His brother plays for I. 12 Q. So Mario, you went up there — how many days 13 basketball, so I'm friends with his brother, and that 13 were you in Chicago? 14 how I met hint 14 A. We went there for like four days, I think. 15 THE VIDEOGRAPHER: Excuse me, miss, could you 15 Q. And where did you go? What did you do when 16 not play with the mike, please? 16 you were up there? 17 THE WITNESS: Sony. 17 A. He like just showed us around the city. He 18 BY MR. CRITTON: 18 had to work, sole kind of like let us go wherever we 19 Q. So Dave is the player at. or Dave is the 19 wanted and just like told us the good spots to go. 20 brother of the guy from. who plays basketball for 20 We went like out to lunch and walked around 21 23. the city and took pictures, and we went out one night to 22 A. Uh huh. 22 like one of the clubs up there. 23 Q. Yes? 23 Q. Okay. Did he have any other guys that he 24 A. Yes. 24 introduced to you all when you was up there? 25 Q. You know the player, the Slyer fa/ 25 A. One other guy, but I for his nem 21 (Pages 203 to 206) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107852 Page 207 .Page 209 1 Q. How about Charlie, does that sound familiar? 1 BY MR. CRITTON: 2 A. Yeah. 2 Q. Did he buy you something too? 3 Q. Do you know what Charlie's last name is? 3 A. I mean yeah, but I was like kind of— he A. No idea. 4 asked Jane Doe 4 Ent It's not like we asked him to Q. How old is Charlie? 5 by anything for us. She wanted to get something to go A. He was an older guy. 6 out, because she didn't really like bring any cute 7 Q. Fifties? 7 dresses. A. Yeah, he was older. 8 And so we went into Bebe, and we never asked 9 Q. And how did Charlie get introduced into the 9 him to buy anything. He was like asked Jane Doe 4, he 10 mix, so to speak? 10 offered to buy her something. 11 A. Just Mario knew him somehow, so he just 11 Q. I asked —1'm sorry, are you done? 12 introduced us to Charlie. 12 A. Well, yeah. !mean he did pay for it, but I 13 Q. Why did he introduce you to Charlie? 13 never asked him to pay for anything forme. 14 MR. HOROWITZ: Form. 14 Q. When I rust asked the question, I said did he 15 BY MR. CRITTON: 15 buy anything for anyone, and you said he bought an 16 Q. Why did Charlie all of a sudden show up with 16 outfit for Jane Doe 4. 17 the five girls? 17 MI right, then I asked you the question well, 18 MR. HOROWITZ: Form. 18 did he buy anything for anybody else? Didn't he buy 19 THE WITNESS: He was showing us around 19 dresses for other people? And then all of a sudden you 20 different hotels. 20 told me. 21 BY MR. CRITT0N: 21 Why didn't you tell me that the first time 22 Q. So Mario, now his apartment is where, what 22 when i asked you? 23 building, do you remember? 23 MR. HOROWITZ: Form. 24 A. The John Hancock 24 THE WITNESS: It's not lie I asked him to buy 25 Q. And how about Charlie, where did he live? 25 me anything. Just I was going to pay for it and Page 208 Page 210 A. I don't remember. 1 brought it to the register and then he offered to 2 Q. Charlie, did he kind of hang around with you 2 pay for it because he was buying Jane Doe 4 3 guys during the four days you were up there? 3 something A. He went out with us one night. Mario said it 4 BY MR. CRITTON: 5 was Ike one of his good friends. 5 Q. Were you confused with my question when i Q. Did Mario buy anything for you all when you 6 asked you whether he had bought you anything? were up there? 7 MR. HOROWITZ: Form 3 A. Just Jane Doe 4, he bought her like i think an 8 THE WITNESS: Well, i wasn't — I'm sorry, I outfit. 9 guess I was kind of - 10 Q. And why would he buy Jane Doe 4, did he 10 BY MR. CRITTON: 11 express why he bought Jane Doe 4 an outfit? 11 Q. Again, if you don't understand my question, 12 MR. HOROWITZ: Form. 12 ask me to repeat it or rephrase it. I asked you if he 13 THE WITNESS: Because she like didn't bring a 13 bought anything for anyone else, and all you said was 14 lot of cute outfits and she saw something she liked 14 Jane Doe 4. 15 in Bebe. 15 So if I hadn't followed up the question, you 16 BY MR. CRITTON: 16 would have misled me, wouldn't you? 17 Q. So if Jane Doe 4 has testified that he bought 17 MR. HOROWITZ: Form. 18 dresses for all of you at Babe's, that would be 18 THE WITNESS: I'm sorry, I didn't ask him to 19 incorrect? 19 buy anything for me. I was going to pay for it and 20 MR. HOROWITZ: Form. 20 then he just offered. 21 THE WITNESS: Well, I mean he did. He bought 21 BY MR. CRIM)N: 22 it for Jane Doe 4, he bought her clothes. And then 22 Q. Did he buy any other gifts for anybody when 23 was Re "I want something because it's my 23 you were up there? 24 birthday," and then he was like, you know, 24 A. No, he just like took us out to lunch once. 25 whatever. So he bought her something too. 25 Q. Did he pay for the tripal_ 22 (Pages 207 to 210) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107853 Page 211 Page 213 1 A. Yes, he did. 1 Dr. ICliman, who your lawyer has hired to testify in this 2 Q. And did he pay for food wherever you all went 2 case? 3 if he was with you; that is, dinners or lunches? 3 A. No. 4 A. Like not all of them, but some of them he took 4 Q. During the time that you have been, during the 5 us out. 5 time that you were in high school, I assume that you Q. How about Charlie? Did he buy any lunches or 6 were covered under your — strike that. 7 dinners when he was out with you? 7 Your dad has worked for the Town of - 8 A. Uhuh. 8 since he first came to Florida? 9 Q. No? 9 A. Yeah. 10 A. No. • 10 Q. So he has a health program through the city, 11 Q. You are shaking your head. You need to answer 11 true? 12 out loud, ma'am. 12 A. Uh huh. 13 I think you said you have been to Mario's. 13 Q. For health benefits? 14 Have you ever seen Charlie since that one trip to 14 A. Uh huh. 15 Chicago? 15 Q. Yes? 16 A. No. 16 A. Yes. 17 Q. Did you ever see Mario when he came back to 17 Q. MI right. And so any type of medical care or 18 Florida again? 18 treatment that you would need would be covered under 19 A. He was down in Miami. He goes down there a 19 your dad's policy? 20 lot and he calls to hangout, but I !lice live in Orlando 20 MR. HOROWITZ: Form. 21 so I can't go, you know, that much. 21 BY MR. CRITTON: 22 But no, I don't think since Chicago 1 have 22 Q. When you were in high school and through the 23 seen him. 23 time you've been in college, as long as you are a 24 Q. How about anyone else? Did you ever have any 24 student, correct? 25 kind of relationship, intimate relationship with Mario? 25 MR. HOROWITZ: Fonn. Page 212 Page 214 1 A. No, not at all. 1 THE WITNESS: Yeah, but there is like his down 2 Q. Did you ever date him for any period of time? 2 payments and stuff. They don't cover everything. 3 A. No. 3 BY MR. CRITTON: 4 Q. Me you currently seeing any physicians, 4 Q. Nobodys does. All right, so my question to 5 psychiatrists, psychologists, mental health counselors, 5 you is your dad — again recognizing you're a full-time 6 professionals, for any reason which you allege is 6 student, correct? 7 associated with your visits to Mr. Epstein? 7 A. Uh huh. MIL HOROWITZ: Form. 8 Q. Yes?. 9 THE WITNESS: No. 9 A. Yes. 10 BY MR. CRITTON: 10 Q. So up through the current date, you had access 11 Q. When, prior to the time that you ever went to 11 to medical care and treatment? 12 Mr. Epstein's home, whatever year that was, '03, '04, 12 . . A. Yes. 13 '05, for the first time, had you ever seen a 13 MR. HOROWITZ: Form. 14 psychiatrist or psychologist or counselor for any 14 BY MR. CRITTON: 15 reason?. 15 Q. Through your dad's health policy, is that 16 A. No. 16 true? 17 Q. After you went to, or from the first time you 17 A. Yes. 18 went to Mr. Epstein's home up until the last time, did 18 Q. All right. And with both, I believe 19 yod ever see a physician, psychiatrist, psychologist, 19 through let me strike that. 20 mental health counselor, for any reason? 20 With did they have a student health 23. A. No. 21 center? 22 Q. After the last time you went to Mr. Epstein's 22 A. Yes. 23 home, whether it was in 2004 or 2005, did you ever see a 23 Q. With., did they have a student health 24 psychiatrist or a psychologist or mental health 24 center? 25 professional for any reason separate and apart from the 25 A. Yes. 23 (Pages 211 to 214) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107854 Page 215 Page 217 1 Q. And both places as well provide for counseling 1 THE WITNESS: No. 2 for students who need counseling, for any type of issue, 2 BY MR. CRITTON: 3 whether ifs birth control, whether it's psychological 3 • Q. Has anyone ever told you you should see a 4 problems, emotional issues, behavioral health issues, as 4 psychiatrist or psychologist or a licensed mental health 5 well as physical problems, those services are made 5 counselor other than your lawyers? I don't want to know 6 available through both and through.? 6 what they said. I'm interested, but — 7 MR. HOROWITZ: Form. 7 A. Jane Doe 4 told me, she said it would really 8 THE WITNESS: Yes. 8 help me If I saw a counselor because ifs been helping 9 BY MR. CRITTON: 9 her and — 10 Q. And if I understand your testimony, you have 10 MR. HOROWITZ: Move to strike Bob's laughter. 11 never used those services either through the school 11 MR. CRITTON: I didn't laugh. It's news to 12 programs, either or.-- first ofall, ou 12 me. 13 have never used those services through or. 13 BY MR. CRITTON: 14 as it relates to any issue associated with Mr. Epstein, 14 Q. Who has Jane Doe 4 told you, who is the 15 true? 15 counselor that Jane Doe 4 said that she's gone to as a 16 MR. HOROWITZ: Form. 16 result of any visits or the occasions that she had to go 17 THE WITNESS: Yes. 17 to Mr. F-pstein's house? 18 BY MR. CRITTON: 18 A. I don't know his name. 19 Q. And as well, even though your father has a 19 Q. Did she tell you where he was? 20 health plan or a medical plan through the Town ofPalm 20 A. 'think down in Boca. 21 Beach which you are covered, you have not sought the 21 Q. Okay. Did she tell you we finished taking 22 services of any mental, psychologist, psychiatrist or 22 her deposition within the last maybe month and she 23 mental health counselors, correct? 23 hadn't seen anybody. 24 . MR. HOROWITZ: Form. 24 MR. HOROWITZ: Object to the form. 25 THE WITNESS: Yes. First of all, there is 25 Page 216 Page 2 :, 1 no — I would never go to my school and tell 1 BY MR. CRITTON: 2 anybody about what happened. I mean that's, I mean 2 Q. e other than some Christian counselor that 3 students probably work there, for all I know. And 3 she and saw. 4 I don't want to get my dad and my mom involved. 4 MR. HOROWITZ: Bob, you can't disclose that 5 And I mean l don't you know, that's 5 stuff. You just cant 6 something that's embarrassing to me and I don't 6 MR. CRITTON: Okay, well fine. If you want to 7 want — I mean it should be on me, not on them. 7 .move for some sort ofprotective order on this, 8 BY MR. Clt1TTON: 8 that's fine. 9 Q. Let me move to strike. Let me go back to my 9 Mk HOROWITZ: No, but I'm appealing to you 10 question. 10 we don't have to do that. You can't disclose 11 My question solely was not the whys and the 11 someone's confidential medical or therapy to 12 wherefors, but since you've been under your parents' 12 another witness. You just can't do that. You can 13 health care Ian,particularly your father's through the 13 ask her what she knows, but you can't disclose it. 14 Town of you have never sought counseling 14 MR. CRITION: Yes, but the perfect example is 15 with a psychiatrist, psychologist, or a licensed mental 15 with this witness, she won't even answer a question 16 health counselor relating to any issues associated with 16 that I ask unless 1key her, and then if I actually 17 Mr. Epstein, correct? 17 know the answer to the question, then she will 18 MR. HOROWITZ: Fenn. 18 =dim it, but she's not giving me answers. 19 THE WITNESS: Yes. 19 So you can argue or move for protective order 20 BY MR. CRITTON: 20 wherever you think is appropriate under the 21 Q. Would it also be a correct statement that 21 circumstances. 22 physically, as a result of your having gone to 22 BY MR. CRITTON: • 23 Mr. Epstein's home, you were never physically injured in 23 Q. Let me ask you this. You say that Jane Doe 4 24 any way, were you? 24 has told you that she's gone -- did she ever tell you 25 MR. HOROWITZ: Form. 25 she saw a counselor up in the Stuart, Jensen Beach area? 24 (Pages 215 to 218) (561) 832-7500 PROSE COURT REPORTING. AGENCY,. INC.. .(561) 832-7506 EFTA01107855 Page 219 Page 221 1 A. No. 1 A. I don't think so. 2 Q. Do you know who is? 2 Q. How do they !mow Jane Doe 4 is a plaintiff? 3 A. Yes. 3 A. Because she's one of my good friends. 4 Q. Have you ever met M? 4 Q. Did you tell your parents? 5 A. Yes. 5 A. !thinks°. 6 Q. Do you know what he does? 6 Q. You said Jane Doe 4 told you that she had seen 7 A. He does like construction and landscing. 7 a counselor in Boca. Did she say it was a man or a 8 Q. All right. Do you know whether = has any 8 female? 9 sort of drug problem? 9 A. I think she said it was a male. 10 A. No. 10 Q. And did she tell you when she started seeing 11 Q. Have you ever known that Mr. Bullard is 11 the counselor in Boca? 12 alleged to have been a seller of drugs? 12 A. No. 13 MR. HOROWITZ: Form. 13 Q. Did she tell you it had helped her? 14 THE WITNESS: No. 14 A. Yes. 15 BY MR. CRITTON: 15 Q. And in what way? 16 Q. Do you know whether he takes drugs, illegal 16 A. She said it just helped her like just when she 17 drugs? 17 is like emotional with the all the thing coming up, with 18 A. No. 18 all the questions for the lawsuit and the media or 19 Q. Has Jane Doe 4 told you that her relationship 19 people — well, not media, but, you know, when all her 20 with is very positive, good relationship? 20 friends found out and stuff, she was really emotional 21 A. Yes. 21 and crying, and he just really helped her emotionally. 22 Q. She seems to be very happy? 22 Q. What friends did she say found out? 23 A. Yes. 23 A. Whoever you guys asked, talked to, I guess. 24 Q. Is she currently working at all? 24 So 1 mean IM I don't really remember everybody she 25 A. Yes. 25 said. Page 220 Page 222 1 Q. What kind of work is she doing now? 1 Q. Did she tell you that before MI was ever 2 A. She's doing cleaning, like housecleaning and 2 deposed that she had already told him about having been 3 stuff. 3 involved with Mr. Epstein? 4 Q. She's a college graduate? 4 A. I don't remember. 5 A. Yes. She's starting her own business, like 5 Q. Did she try to blame that on the lawyers in 6 housecleaning. 6 some way? 7 Q. So she's going out, she's doing some cleaning 7 MR. HOROWITZ: Form. 8 herself, kind of learn the business, and then she's 8 THE WITNESS: I don't think she told him, you 9 going to get people to work for her? 9 know, the extent of everything. I don't really 10 A. Yes. 10 know what she told him. 11 Q. Did she say her business is going well, good, 11 BY MR. CRITTON: 12 bad or indifferent? 12 Q. All right So she told you that at least she 13 A. Yeah, she said it's going good. 13 is seeing somebody, a male in Boca Raton? 14 Q. Do she and have any plans to get 14 A. lib huh. 15 married? 15 Q. Did she tell you how she had gotten to see 16 MR. HOROWITZ: Form. 16 somebody in Boca? 17 THE WITNESS: Not that I know of. 17 A. No. 18 BY MR. CRITTON: 18 Q. So how long ago did she tell you this, in the 19 Q. She's living with him MI time? 19 last month or so? 20 A_ Yes. 20 A. Yes. 21 Q. Do your parents know that Jane Doe 4 is a 21 Q. Okay. Did she, as a result of her telling you 22 plaintiff in one of these lawsuits or the lawsuit 22 you should see someone, have you made an appointment to 23 against Mr. Epstein? 23 see anyone? 24 A. Yes, I think so. 24 A. No. She told me that you guys are going to 25 Do know that Jane Doe 3 is? 25 depose her therapist, and that made me not want to see 25 (Pages 219 to 222) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107856 Page 223 Page 225 1 anybody, because I don't want my whole life story, you 1 MR. HOROWITZ: Form. 2 know, to be out there. 2 THE WITNESS: That's what people say, but 3 Q. What whole life story? 3 there are students that work in those offices, and 4 A. I mean I don't feel comfortable talking to a 4 I don't want people at my school like 'mowing my 5 therapist. Like I'd rather wait until everything is 5 business. 6 over with to talk to somebody. That's why I haven't 6 BY MR. CRITTON: done anything. 7 Q. Did you try get some assistance? Did you talk Q. Why? What makes you think talking to a 8 to your parents and say "Hey, look, I think it would be 9 therapist after the lawsuit is over is of any benefit to 9 of some benefit for me to go see a psychologist or a 10 you? 10 psychiatrist"? 11 A. Because like I had heard that you guys already 11 A. I'm like kind of embarrassed to ask them. Td 12 deposed her therapist, and I don't want everything, you 12 rather do it on my own. 13 know, I say to be just public knowledge to every lawyer. 13 Q. Isn't the reason that you haven't gone to go 14 Q. You understood what you said to Dr. Kliman is 14 see someone, ma'am, is you don't feel the need to do 15 public knowledge, in essence? It's public within the 15 that? 16 confines of this lawsuit. You understand that, don't 16 MR. HOROWITZ: Pont 17 you? 17 THE WITNESS: No, I do feel the need. I want 18 MR. HOROWITZ: Form. 18 to go see somebody, but I just don't feel 19 THE WITNESS: Yes. 19 comfortable doing it now. 20 BY MR. CRITTON: 20 BY MR. CRITTON: 21 Q. And everything you have said to Dr. Hall is 21 Q. But why? I mean it doesn't make sense -- let 22 shared not only with me, but as well shared with your 22 me strike that. 23 attorney, correct? 23 In the year 2010, have you been on any trips? 24 A. Yes. 24 A. Yes. 25 Q. Okay. So what were you concerned that you 25 Q. Where did you go? Page 224 Page 226 might tell a psychologist --just a minute, I need to 1 A. I mean I went to Key West. ask the question, ma'am. 2 Q. With whom? 3 What were you concerned with that I might ask 3 A. I went with just my friend =. 4 that you might toll a psychologist or psychiatrist that 4 Q. M t? you wouldn't want he or she to repeat to me? 5 A. Uh huh. 6 A. Nothing. I just talked to those because I had 6 Q. Where did you stay? 1 to talk to those people, and I'd rather just wait until 7 A. We stayed at my friend's ex-boyfriend's place 8 everything is over, because I don't feel comfortable 8 down in Key West. 9 like talking to people right now. 9 Q. My friend's ex-boyfriend. Your friend, whose 10 And also, like I'm in college. I don't have, 10 name is? 11 you know, money right now to go see somebody. And 1 11 A. My friend M, my old roommate. Her 12 don't, and my parents aren't going to like — I mean I'm 12 ex-boyfriend lives in Key West. 13 not going to pay $40 a visit every week or two weeks, 13 Q. His name is? 14 whatever. Like I have like $100 a week I have to live 14 A. Nick. 15 on in college basically, so — 15 Q. Nick? 16 Q. Have you actually gone to the. center where 16 A. Yes. 17 they have psychologists and psychiatrists? 17 Q. Was Nick there when you were there? 18 MR. HOROWITZ: Form. 18 A. Yes. 19 THE WITNESS: I definitely don't want to go to 19 Q. Where does he live in Key West? 20 center. 20 A. He just lives in a small apartment off Duval 21 BY MR. CRITTON: 21 Street. 22 Q. Why wouldn't you do that? Because your 22 Q. So you stayed with him for what, a week? 23 medical records or your psychiatric records or 23 A. Yeah, for like five days. 24 behavioral, psychological records are supposed to be 24 Q. Four to five days? 25 completely privileged. 25 A. Uh huh. 26 (Pages 223 to 226) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107857 Page 227 Page 229 1 Q. Yes? A. We both split it 2 A. Yes. 2 Q. All right. Who paid for your drinks when you 3 Q. Okay. And I assume you partied every night, 3 went out, when you even had too much to drink? 4 went out every night? 4 MR. HOROWITZ: Form. A. I mean we went out some and we just went to 5 THE WITNESS: I mean we did sometimes. 6 the beach a lot. 6 BY MR. CRITTON: Q. Okay. So it's your testimony during the four 7 Q. All right. And then if you were lucky, maybe a or five nights that you were there -- what time period 8 some guy would buy you a drink or drinks? 9 were you there, spring break? 9 A. Yes. 10 A. Yes. 10 Q. I'm sorry? 11 Q. So you were there for spring break, a million 11 A. Yes. 12 other college kids there? 12 Q. All right. And isn't it a true statement, 13 MR. HOROWITZ: Form. 13 Jane Doe 7, is if you really wanted to see a 14 THE WITNESS: Yes. 14 psychologist, you have maybe not every week, but you 15 BY MR. CRITTON: 15 would have had the fiuids to do that, you just choose to 16 Q. All right. It would be a fair statement -- 16 use your funds in a different, for different purposes at 17 well, let me be acanate. It was during the four or 17 the current tint? 18 five days that you were there, is it your testimony that 18 MR. HOROWITZ: Fonn. 19 you only went out one or two nights to party and to go 19 THE WITNESS: No, that's not the main reason. 20 to clubs? 20 The main reason was1 wanted to wait until after 21 MR. HOROWITZ: Form. 21 the lawsuit. 22 BY MR. CRITTON: 22 BY MR. CRITTON: 23 Q. Or did you go out every night? 23 Q. So people !Bre me who represent Mr. Epstein 24 A. I went out a lot when we were there. It was 24 maybe can't look at what you tell a psychologist? 25 spring break. 25 A. I mean I just feel uncomfortable like saying Page 228 Page 230 1 Q. Exactly. My point is that you went down there 1 everything right now. 2 for spring break and you went out every night and you 2 Q. What makes you think you will be more 3 partied, didn't you? 3 comfortable after a lawsuit talking with someone? 4 A. Yeah, ifs spring break 4 A. Just because when everything is like done and 5 Q. And you had fun? 5 over with, I feel like it will be a better time to just 6 A. Yeah, I did. 6 help me get over everything. 7 Q. And you had a great time? 7 Q. Isn't it true, though, if you really wanted to 8 A. Yes. 8 sec — well, let me ask you this. 9 Q. And you drank alcohol, I assume? 9 After the police came to you, the Palm Beach 10 A. Yes. 10 Police Department came and interviewed you back on 11 Q. You had a cocktail here and there? 11 October 4th of 2005 and you had sent Mom into the house. 12 A. Yes. 12 when the Palm Beach police left, did Mom say to you 13 Q. And there were some nights that you had too 13 "What in heaven's name is this about, Jane Doe 7r 14 many cocktails? 14 A. Yeah, she asked me about it. 15 A. Yes. 15 Q. And by that time, Dad was home? 16 Q. And how did you get down there? Whose car did 16 A. Yes. 17 you drive down from Orlando? 17 Q. All right. And did you, did they both sit 18 A. I drove. 18 down and say "Young Lady," or "Jane Doe 7, come on. 19 Q. All right. And who paid for your meals when 19 what's the deal here? 20 you were there? 20 A. Yes. 21 A. We did. We went food shopping before we even 21 Q. "What happened? How long did that 22 got there and we like -- when we got there, we went food 22 conversation last? 23 shopping and just mainly made food to like saw money, 23 A. I mean I obviously didn't tell them everything 24 because food is like expensive down there. 24 that happened. So I mean I don't know, I Just told them 25 Q. Who paid for the gas? 25 briefly what I told the cops. tamoll•ImStaa....F.rsa.asnar 27 (Pages 227 to 230) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107858 Page 231 Page 233 Q. So you only told them what you had told the 1 MR. HOROWITZ: Form. 2 polioe, that you were at Mr. Epstein's twice, one time 2 THE WITNESS: 1 mean I'm sure they would try 3 you gave Mr. Epstein a massage, another time you just 3 to help me out. It's just like embarrassing to say 4 took somebody else? 4 that to them and its just something I would rather 5 A. Yes. 5 just deal with on my own. 6 Q. That's what you told them? 6 BY MR. CPJTTON: 7 A. Yes. 7 Q. You sent me some, or your attorney sent me 8 Q. Have you ever told them anything differently? 8 some additional answers to interrogatories the other 9 A. No. 9 day. 10 Q. So as far as your parents !mow at this point 10 !AR. CRITTON: Lets go off the record for a 11 in time, as far as they !mow is that you went to 11 minute. 12 Mr. Epstein's — let me strike that. 12 THE VIDEOGRAPHER: Going off the record at 13 As of today's date, your parents only know 13 2:41 p.m. 14 what you told them the day that the Palm Beach Police 14 (Discussion held off the record.) 15 Department was there interviewing you? 15 THE VIDEOGFtAPHER: Were back on the record a 16 MR. HOROWITZ: Form. 16 2:46 p.m 17 THE WITNESS: They never asked me about it 17 (The documents were marked Defendant's 18 They don't really want to know or care to know 18 Exhibits 1.3 for identification.) 19 everything. They already don't like Jeffrey. They 19 BY MR. CRITTON: 20 read the papers. They know what goes on and went 20 Q. Before I get back to the interrogatories, you 21 on. I mean they are not stupid 21 wouldn't, growing up, from the time that you were 22 BY MR. CRITTON: 22 freshman through even your current status, you wouldn't 23 Q. Well, they have no idea what went on with you 23 have considered yourself economically disadvantaged, 24 and whether your circumstances are similar to or even 24 would you? 25 close to what someone, some other person's situation 25 A. What does that man? Page 232 Page 234 I might be, true? 1 Q. I'm not sure. Did you feel economically 2 MR. HOROWITZ: Form. 2 deprived when you were a freshman or a sophomore or a .3 THE WITNESS: Yeah, but I — they don't really 3 junior or a senior in high school, that your parents had 4 want to know. I mean they, I told them what I told 4 economically deprived you, or did you feel that you were 5 than and I mean that's all that Imean they know, 5 fine economically? 6 and from reading other people's things like what he 6 MR. HOROWITZ: Form. 7 did or tried to do to most girls. So -- 7 BY MR. CUT-TON: 8 BY MR. CRITTON: a Q. I mean everybody would !Ore to have more 9 Q. Have they ever asked you, has your mother ever 9 money. 10 asked you 'Hey, Jane Doe 7, what happened when you were 10 A. I mean my parents had to work really hard for 11 at Mr. Epstein's home?" 11 their money, so it's not like I had everything given to 12 A. Just the first time that the cop -- 12 me, like my dad made me work for it If I ever wanted 13 Q. Since that day, she's never asked and you've 13 money, I had to like wash his car or do something, so I 14 never offered? 14 mean - 15 A. No. 15 Q. Those are good things, though, you had chores? 16 Q. Correct? 16 A. Yeah, but — 17 A. Correct 17 Q. You didn't consider yourself economically 18 Q. Same thing with Dad? 18 disadvantaged, did you? 19 A. Correct 19 MR. HOROWITZ: Form. 20 Q. Is it your testimony that if you went to your 20 THE WITNESS: I guess not. 21 parents and you said "Look, I think I might need some -- 21 BY MR. CRITTON: 22 I'd like to see a psychiatrist or a psychologist to help 22 Q. Jane Doe 4, I had an opportunity to meet her 23 me deal with some issues relating to Mr. Epstein,* 23 parents. I wouldn't describe her as being economically 24 assuming you said that to them, it's your testimony that 24 disadvantaged, but you don't care what I think, so my el imil eur isomia.. parents would say no? 25 question to you is do you think Jane Doe 4's parents or 28 (Pages 231 to 234) (561) 832-750.0 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107859 Page 235 Page 237 1 her family life or that she was in any way economically 1 2 disadvantaged? 2 3 MR. HOROWITZ: Form. 3 4 THE WITNESS: I don't think so. 4 5 BY MR. CRITTON: 5 6 Q. How about lane Doe 3, did she have similar 6 7 middle class circumstances like yourself and Jane Doe 4? 7 8 MR. HOROWITZ: Form. 9 THE WITNESS: Yes. 9 10 BY MR. CRITTON: 10 11 Q. Okay. So you wouldn't have considered her 11 12 economically disadvantaged, would you? 12 13 MR.. HOROWITZ: Form. 13 14 THE WITNESS: Yes. 14 15 BY MR. CRITTON: 15 16 Q You would? 16 17 A. No, I wouldn't. 17 18 Q. All right. In your answers to interrogatories 18 19 you listed, which is Exhibit 2, you listed the only 19 20 medical, physicians, medical facilities, health care 20 21 providers — and I'm paraphrasing -- psychiatrists, 21 22 psychologists, et cetera, that you had seen in the past 22 23 ten years, you listed the walk-in medical center at 23 24 Orlando, at University Boulevard, Orlando, 2005 to the 24 25 present. 25 Page 236 Page 1 I assume that's the school clinic? 1 2 A. No. Just a clinic that was by my house. 2 3 Q. Like a doe-in-the-box? 3 4 A. Yeah. 4 5 Q. And if you had a cold or got the flu or 5 6 something, you would go there for medical care and 6 7 treatment? 7 8 A. Yes. 8 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24. 25 25 29 (Pages 235 to 238) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107860 Page 2.39 Page 241 1 wasn't thinking. 2 And it's just something I wish I could take 3 back, something that happened to me. And ifs something 4 I'll never be able to forget for the rest ofmy life, 5 and just the pain that I caused my parents and other 6 people. Ifs just — 7 Q. What pain have you caused — what other person 8 have you caused pain? 9 A. I mean mainly my parents like more than 10 10 anything. It was heartbreaking for me when they found 11 11 out. And I mean I wish I could take it back, and — 12 12 Q. What did your parents say to you when you told 13 BY MR. CRITTON: 13 them that you had been to Mr. Epstein's twice? 14 Q. Okay. Tell me about at the current time, I 14 A. I mean they were just asking me why, why would 15 know you have told us other than seeing Dr. Kliman, you 15 you do that? Like how -- I mean they understand now 16 have never seen a psychiatrist, psychologist, mental 16 that, you know, it was, he was just a predator mainly, 17 health counselor for any reasons relating to damages you 17 but, you know, at the time they just, they were upset 18 claim for which you seek money damages against Mr.— let 18 Q. Okay. I don't want to — let me ask my 19 me start that again. 19 question again. 20 You filed a lawsuit seeking money damages from 20 MR. CRITTON: Okay, let me see it again. Run 21 Mr. Epstein for money, right? 21 It down for me, Rachel. 22 MR. HOROWITZ: Penn. 22 BY MR. CRITTON: 23 23 Q. What specifically, when you told your parents 24 25 THE WITNESS: Yes. BY MR. CR1TTON: Q. Okay. And what do you think your damages are? 24 25 e you had been to Mr. Epstein's twice, once with and you had given him a massage, he meaning Mr. Epstein, did Page 240 Page 242 1 That is, what elements or items of damage do you think 1 you tell them that he never touched you, that you never 2 you have sustained as a result of your having been to 2 touched him, that nothing occurred other than you gave 3 Mr. Epstein's home? 3 him a massage, just like you told the police? 4 MR. HOROWITZ: Form. 4 MR HOROVrITZ: Fenn. 5 BY MR. CRITTON: 5 THE WITNESS: I told them that he tried, you 6 Q. In your words. 6 know, to touch me and do things with me, but 7 A. Well, for like the last six years I've been 7 obviously I couldn't tell my parents everything. I 8 like, live had a lot of things happen to me. I've been 8 mean they know now, you know, what's, what went on 9 depressed a lot. I have anxiety. I just feel like that 9 there and, you know, just from assuming and hearing 10 happened and I can, something I could never take back. 10 from other people and reading things. 11 I feel like I'm damaged, you know, and it's just like I 11 BY MR. CRITTON: 12 feel litre dirty almost for doing that and Pm really 12 Q. Okay. Let me move to strike as nonresponsive. 13 like self-conscious about it. 13 I don't want to know what they assumed, okay? 14 I mean I have like flashbacks a lot of going, 14 I'm not interested in that. I'm interested in what you 15 and then I get really depressed. Every time I hear his 15 told them. 16 name or something come up about it, I get depressed 16 So if you listen to my question, you keep 17 where I don't eat and I can't sleep. I just have really 17 adding on, but Pm assuming and they read this and they 18 bad anxiety. lust my memory a lot too. I mean I have 18 read that. I'm not — Pm glad they have read, or it's 19 memory problems. 19 up to them what they want to read or not. !just want 20 I tried to like hide all the memories, just to 20 to know what they have told you and what you have said 21 try to get over everything. And I mean ifs just hard. 21 to them, okay? So focus on my question if you would, 22 Like when people bring it up and I have to talk about 22 ma'am. 23 it it's embarrassing. It's hard. It just makes me 23 You told me earlier, a couple of times, that 24 feel like just I did something and it's -- I know now, 24 you told them the day that the Palm Beach police were • 25 you know, that it's not my fault, but at the time I 'tat 25 there at your house the same thing that you had said to 30 (Pages 239 to 242) (561) 832-7500 PROSE COURT. REPORTING.AGENCY, INC.' (561) 832-7506 EFTA01107861 Page 243 Page 245 1 the police, correct? 1 BY MR. CRITTON: 2 A. Yes. 2 Q. At the current time? 3 Q. Okay. And what you would have said to them 3 MR HOROWITZ: Form. 4 was, is that you gave him a massage on one occasion, he 4 THE WITNESS: A lot, especially lately, me 5 never touched you, and you never touched any of his 5 having to go through all this. 6 private parts, right? 6 BY MR. CRITTON: 7 MR. HOROWITZ: Form. 7 Q. You mean having to do this deposition? 8 BY MR. CRITTON: 8 A. I mean this whole — I mean it depends. I 9 Q. You told him that? 9 mean sometimes it's worse than others. Like when they 10 A. Yes. 10 bring up his name or, you know, my mom will call me 11 Q. And you told them the second time you went, 11 saying she read something in the newspaper, I won't be 12 you took somebody else, you mayiurve gone with Jane 12 able to eat for like a week. III get depressed. 13 Doe 4, you may have gone with but you didn't go 13 have bad anxiety. Ifs hard for me to like do 14 upstairs, correct? 14 schoolwork. It will bring like flashbacks back. 15 A. Yes. 15 Just every day I feel like disgusting, and 16 Q. Okay. So at least as of that date, as of the 16 every time I hear his name, it just brings back 17 date that you spoke with them, which you have testified 17 memories. 18 as well today is the only time you have ever talked to 18 Q. This is an everyday thing for you? 19 them about what occurred at Mr. Epstein's house, as far 19 MR. HOROWITZ: Form. 20 as they know, you gave Mr. Epstein a massage on one 20 IRE WITNESS: Not every day, I mean some 21 occasion, you were fully clothed and he was completely 21 days -- 22 covered, true? 22 BY MR. CRITTON: 23 MR. HOROWITZ: Form. 23 Q. You -- 24 THE WITNESS: I mean at that point, that's 24 MR. HOROWITZ: She wasn't done, I don't think. 25 Alai I told them, yes. 25 MR. CRITTON: She keeps changing anyway. It Page 244 Page 246 1 BY MR. CRITTON: 1 doesn't make any difference. 2 Q. Right. And they may have read things in the 2 MR. HOROWITZ: Move to strike. 3 newspaper, but you have never told them anything 3 BY MR. CRITTON: 4 different than what you told them that one occasion back 4 Q. Are you done? Are you going to add more to 5 on October 4th of2005, correct? 5 it? 6 MR HOROWITZ: Form. 6 A. What else were you going to ask me? 7 THE WITNESS: Yes. I meanI also told the 7 Q. Your lawyer thought you had more to say, so 8 cops that he did try to grab me in my butt and I I'm going to give you the chance. 9 believe I told my parents that too. 9 rm trying to find out how often this bothers 10 BY MR. CRITTON: 10 you. Say over the last six months or a year, how often 11 Q. Okay. So you told them that too. And that's, 11 do any of those symptoms seem to bother you? 12 as far as they know, that's all that occurred, true? 12 A. I mean every week. 13 A. Yes. 13 Q. Every — 14 MR. HOROWITZ: Form. 14 A. Basically. I mean I try do other things to 15 BY MR. CRITTON: 15 like you know, I mean I try to go out with my friends 16 Q. Okay. Now, you gave a list ofissues that you 16 and hang out and just to kind of get it offmy mind, but 17 have, including depressed, anxiety, you feel damaged or 17 I mean something always comes back to remind me or bring 18 dirty, self-conscious. You don't eat, sleep, things of 18 it up, or I'll hear something and I just fall into like 19 that nature. 19 depression again. 20 How often do any of those symptoms or those 20 Q. Okay. So has this been true since the day 21 issues bother you? 21 that the Palm Beach police came to your home on 22 MR. HOROWITZ: Form. 22 October 4th of2005? 23 BY MR. CRITTON: 23 MR HOROWITZ: Form. 24 Q. Or cause you any concern? 24 THE WITNESS: Yes. MR, HOROWITZLIonn. 25 31 (Pages 243 to 246) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-75O6 EFTA01107862 Page 24 Page 249 1 BY MR. CRITTON: MR. HOROWITZ: Farm. 2 Q. Is that when it started, when all of a sudden 2 THE WITNESS: The first time I really became 3 you knew that someone else might know? 3 depressed was like after the last time I went when 4 MR. HOROWITZ: Fa 4 he really tried to, you know, do stuff with me 3 THE WITNESS: It started before then, like 5 forcefully, and then I just felt disgusting and I even when I was going like I would be depressed and 6 got depressed, and that's why I just stopped going. I would just, like I don't know why I kept going. 7 BY MR. CRITTON: I was confined, but I mean I just felt dirty kind 8 Q. Okay. And time flame again you are not sure, 9 of and I was upset then. So I mean it's been going 9 it might have been in '04, it might have been in '05, 10 on for a while, not just after the police. 10 you are just not sure, correct? 11 BY MR. CRITTON: 11 MR. HOROWITZ: Form. 12 Q. So now it's your testimony that from the first 12 BY MR. CRITTON: 13 time you went to Mr. Epstein's home, you were depressed? 13 Q. When the last time you went to Mr. Epstein's? 14 MR. HOROWITZ: Form. 14 A. I can't remember the exact date. 15 THE WITNESS: Not the first time. 15 Q. Sometime in 2004, 2005? 16 BY MR. CRITTON: 16 A. Yes. 17 Q. How about the second time? 17 Q. All right And prior to the last time you 18 MR. HOROWITZ: Fonn. 18 were there, you had never been depressed when you had 19 THE WITNESS: I mean if you're really going to 19 been at Mr. Epstein's home; is that correct? 20 start doing that to me, !mean it's — 20 MR. HOROWITZ: Form. 21 BY MR. CRITTON: 21 THE WITNESS: I mean I was upset. I 22 Q. It's not doing it to you, ma'am. I need to 22 wouldn't — I don't, I can't — I don't know, I 23 know. You are claiming $50 million against Mr. Epstein 23 can't prescribe myself I'm not a psychologist, I 24 in this case, so I need to know when -- 24 don't — 25 A. Well, you are like belittling everything I am 25 Page 213 Page 250 =Yin& 1 BY MR. CRITTON: 2 Q. Tin not belittling it, okay? I'm not at all. 2 Q. Well, were you ever anxious when you left 3 MR. HOROWITZ: I think you are, Bob. You are 3 Mr. Epstein's house? 4 snickering. 4 A. Yeah, every time I left his house, I just 5 MR. CRITTON: I am not snickering at all, all 5 thought what did I just do? And I don't know why I kept 6 right? 6 going. 7 MR. HOROWITZ: You did several times. 7 THE VIDEOGRAPHER: Five minutes till tape MR. CRITTON: I did not 8 change. 9 MR. HOROWITZ: You have rolled your eyes 9 BY MR. CRITTON: 10 several times. 10 Q. Even though you were anxious, you knew what 11 MR. CRITTON: Well, there's a lot of things 11 was going on at lean from your own words earlier was 12 that you've rolled your eyes at and I don't call 12 inappropriate, you continued to go back to 13 you on it, and with the changes of testimony this 13 Mr. Epstein's; nue? 14 lady has, it's a wonder my eyes can stay normal 14 MR. HOROWITZ: Fenn. 15 anyway with the level -- anyway, be that as it may, 15 THE WITNESS: Yes. 16 you can object to form all you want. 16 BY MR. CRITTON: 17 BY MR. CRITTON: 17 Q. And you chose voluntarily to get in your car 18 Q. So let me clear it up with you, ma'am. I'm 18 and go back to Mr. Epstein's; true? 19 interested in what your damages are in this case. Do 19 A. Yes. 20 you understand that? 20 Q. All right Did you feel self-conscious? 21 A. Yes. 21 A. I mean of course I did. 22 • Q. Okay. So have you been depressed since the 22 Q. After the first time you went to Mr. Epstein's 23 first time you went to Mr. Epstein's home? And if not, 23 home? 24 tell me when you first became depressed as a result of 24 A. I mean yeah. I just, I felt like somebody is 25 having met Mr. Epstein. 25 going to find out or I mean I vms just, the whole time ] 32 (Pages 247 to 250) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107863 Page 251 Page 253 was just, I just felt disgusting for going there. 1 by the FBI and then just everything came back. And 2 Q. All right. And at that time did you have, 2 that's when it started getting really bad and I was 1 during the time you were going to Mr. Epstein's, did you 3 really upset then. 4 have flashbacks? 4 And, you know, just having to talk to the FBI, A. No, they started after. 5 and l mean that was like depressing and scary and Q. When? 6 like I just had really bad anxiety and I felt like 7 A. After I stopped going there. 7 I was having panic attach. 8 Q. The day after the last time you were there, 8 And I mean, so I mean it kind of started back 9 did they start? up. 10 A. No. Ifs like when my friends would say, you 10 BY MR. CRITTON: 11 know, they went to Jeffrey's or something, then I would 11 Q. Okay. So sometimes it's more, sometimes its 12 get flashbacks. 12 less? 13 Q. Which of your friends did you tell after the 13 A. Yes. 14 last time you went to Mr. Epstein's that you were either 14 Q. And is it because again someone brought it to 15 depressed, you were anxious, you felt disgusting, 15 your attention or wants to talk about it that that 16 self-conscious, or that you were having flashbacks? 16 causes you anxiety? 17 MR. HOROWITZ: Form. 17 MR. HOROWITZ: Form. 18 BY MR. CRITTON: 18 THE WITNESS: I mean of course some people 19 Q. Which of the friends did you tell? 19 like bring it up and I hear about it, I get, you 20 A. I believe just Jane Doe 4. 20 know, anxiety and it just brings back everything. 21 Q. Okay. And you told Jane Doe 4 that you were 21 BY MR. CRITTON: 22 having all these symptoms, right? 22 Q. Do you think this lawsuit creates anxiety for 23 A. I mean no. 23 you? 24 MR. HOROWITZ: Form. 24 A. I mean of course. 25 THE WITNESS: I don't exactly remember what I 25 Q. All right. And you think when this lawsuit is Page 252 Page 254 1 told her. ljust remember telling her I was upset 1 over, a lot of the anxiety that you have and the 2 about it 2 feelings that you have will go away? 3 BY MR. CRITTON: 3 MR. HOROWITZ: Form. 4 Q. But you knew she was still going? 4 THE WITNESS: I'm hoping after it's over, I 5 A. Yes. 5 can just kind of get help and get past everything. 6 Q. Okay. Did you say "Jane Doe 4, I feel 6 BY MR. CRITTON: 7 depressed, anxious, disgusting, self-conscious, Pm 7 Q. And whetter you recover a dollar from 8 having flashbacks, I'm not eating and sleeping, I'm 8 Mr. Epstein or S100,000, do you think that your ability 9 having memory problems. Why in heaven's name would you 9 to gel better will be the same? 10 continue to go see Mr. Epstein?" 10 MR. HOROWITZ: Rem. 11 Did you have that conversation with your very 11 TIlE WITNESS: Idol* think there is any 12 best friend? 12 amount of money that could ever, you know -- I mean 13 MR. HOROWITZ: Fonn. 13 !would much rather have never had this happen to 14 THE WITNESS: No. 14 me than have any amount of money. There is 15 BY MR. CRITTON: 15 nothing, amount of money that somebody could give 16 Q. What have these symptoms that you've expressed 16 me to help me get through everything, but I mean 17 of depression, anxiety, feeling disgusting, 17 I'm just hoping that when everything is over, you 18 self-conscious, flashbacks, have those symptoms been 18 know,1 can just try to see somebody to help me and 19 pretty much the same since you last sent to 19 try to forget about it and move on with my life. 20 Mr. Epstein's up through the current time? 20 MR CRITTON: Need to change tape. 2/ MR. HOROWITZ: Form. 21 THE VIDEOGRAPHER: Going off the record at 22 THE WITNESS: I mean right around when I 22 3:07 p.m This madcs the end of tape two. 23 stopped going, they were really bad. And then, you 23 (Discussion held off the record.) 24 know, it just kind of, you know, I tried to forget 24 THE VIDEOGRAPHER: We're back on the record at i125 about it up until, you know, when I got contacted 25 3:09 p.m. This marks the beginning of tape three. 33 (Pages 251 to 254) (561) 832-7500 PROSE COURT.REPORTING AGENCY, INC. (561) 832-7506 EFTA01107864 Page 255 Page 257 1 BY MR. CR1TTON: 1 working? 2 Q. Jane Doe 7, do you believe that you've lost 2 A. Yes, !worked for my dad and my dad's friend 3 . any money; that is, have you lost any wages, jobs as a 3 in the aMbusiness. 4 result of your having been to Mr. Epstein's home? 4 Q. licnnti • tit was real life experience? 5 MR. HOROWITZ: Form. 5 A. Pretty much. 6 THE WITNESS: No. 6 Q. All right. And what kind ofgrades did you 7 BY MR. CRITTON: 7 get at 8 Q. Okay. Do you believe you have lost the 8 A. I just got average grades, l think. 9 ability to earn money in the future as a result of 9 Q. B's, A's and B's? 10 having been to Mr. Epstein's home? 10 A. Yeah, hire Ws. 11 MR. HOROWITZ: Fenn. 11 Q. What was your grade point from 12 THE WITNESS: I do believe I could have got a 12 A. I don't remember. I think it was111 13 lot better grades if I wasn't going through this 13 know. 14 all of college. 14 Q. How about since you've been ate what's 15 BY MR. CIUTTON: 15 your grade point there? 16 Q. Well, in high school it looks like you, and 16 A. I think it's around like a 2.8 or 2.9. 17 particularly your senior year after you alleged in part 17 Q. So it's Ince a B minus? 18 that you stopped seeing Mr. Epstein, you got almost all 18 A. Yeah. 19 A's and a few Ws; did you not? 19 Q. 3.0 is a B, so you are almost at a B? 20 A. Yes. 20 A. Yes. 21 Q. Okay. And it appears in looking at least to 21 Q. And would you describe yourself - if someone 22 your junior and sophomore years is your grades after you 22 described you as a party animal; would that be accurate? 23 stopped seeing Mr. Epstein, at least you say you stopped 23 A. No. 24 seeing Mr. Epstein improved substantially; is that true? 24 Q. So yourarely go out to clubs, to bars? 25 MR. HOROWITZ: Form. 25 A. I mean I go out, of course, I'm in college, Page 256 Page 258 1 THE WITNESS: The only reason why I got all 1 but Pm not a party animal. I still got my schoolwork 2 A's is because l had O1T. 2 done and do all my responsibilities that I have to do. 3 BY MR. CRTTTON: 3 Q. Okay. Just berause you are a party animal 4 Q. What's on? 4 doesn't necessarily mean you don't do your work. 5 A. On-the-job training where they let you out of 5 Let me ask it more this way. YOU go out with 6 school earlier for three hours. 6 your friends two to three, four times a week, might go 7 Q. Well, in looking at your transcript from 7 to a club, to a bar or something hie that and hang out? 8 twelfth grade, it looks like you took English 3 -- Pm 8 A. Yes. 9 sorry, English 4, you got a B. That's not OJT, is it? 9 Q. Usually go out every weekend? 10 A. No. 10 A. I mean yeah, sometimes. 11 Q. American economics, that's not OJT, is it? 11 Q. Has that been hue both since you have been at 12 You got a B in that? 12 and since you have been at M? 13 A. Uh huh. 13 A. Yes. 14 Q. Correct? 14 Q. This spring break you went to Key West. Where 15 A. Yes. 15 did you go last spring break? 16 Q. TY production, you got an A in that? 16 A. Key West. 17 A. Yes. 17 Q. Did you stay at Nick's house again? 18 Q. And then you had Work Experience 2, and three 18 A. No. 19' other O./Ts that you all got A's in, correct? 19 Q. Where did you stay at that time? 20 A. Yes, 20 A. Four or five of us split a hotel there. 21 Q. And you took - you did get one l in American 21. Q. Very common for college kids to go down and 22 Political Systems, I see that, but all ofyour work 22 stay a week and split a room and put a bunch of people 23 experience and Offs you got A's in, correct? 23. in? Yes? 24 A. Yes. 24 A. Yes. 25 Q. And OJT is where you learn, you are out 25 • Q. You partied every night when you were down 34 (Pages 255 to 258) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107865 Page 259 Page 261 there just like all the other college kids do? 1 A. No. I mean I would have to stay late. My 2 A. Yes. 2 reason for working there, it was an internship. 3 Q. Did you ever feel so depressed or anxious or 3 Q. But you got paid too? 4 self-conscious or one of the times that you were not 4 A. Yes, I got paid, but I had to work in a 5 eating or sleeping during spring break? 5 hospitality establishment for my internship and I had to 6 A. I was actually happy to get away from Orlando 6 do three internships, so that was my reason for working. 7 and get away from everything, so that was kind of like 7 Q. What did you — I'm sorry, what do you plan to 8 me getting way from everything was going on spring break do when you finish? 9 a taking trips. It was like me getting away from 9 A. I honestly have no idea, but hopefully get a 10 everything. 10 job. 11 Q. My question to you was did your depression, 11 Q. You have bola and now aS 12 anxiety, self-consciousness, feeling disgusting, having 12 a minor: 13 flashbacks and not being able to eat and sleep, memory 13 A. Llh huh. 14 problems, did any of those symptoms cause you not to go 14 Q. Have you started looking for a job at all? 15 on a spring break since you've been in college? 15 A. No, not now. 16 MR. HOROWITZ: Form. 16 Q. Have you tried to do any internships through 17 THE WITNESS: No, that was why l went on 17 school where you could ultimately move into, like 18 spring break was to get away from everything. 18 Cheyenne, is it a chain or is it just a sole building? 19 BY MR. CRITTON: 19 A. It's actually closed down now. 20 Q. Okay. And in the summer you are going to 20 Q. All right. Have you talked to any other 21 Italy for a month. 21 restaurant chains or any other hotels or hospitality 22 A. Yes. 22 type situations to see if you could get an internship so 23 Q. Is that another escape so you can get away 23 you could get into the program and work your way up? 24 from things? 24 A. No, because I'm leaving for Italy, so I — 25 A. No, it's just something I always wanted to do 25 there is no point in me starting to work somewhere now. Page 260 Page 262 I. is study abroad. 1 I want to wait until I get back. 2 Q. And how about separate and apart from last 2 Q. So when you get back from Italy, you will have 3 summer, you stayed up in Orlando. Were you still in 3 to then start looking for a job? 4 school, or this past summer, 2009, did you stay in 4 A. Yes. 5 school? 5 Q. Do you plan to return to Orlando or do you 6 A. Yes. 6 plan to return home? 7 Q. Okay. And did you work during that time 7 A. I don't know yet. 8 period? B Q. What have your parents said, or I guess you 9 A. Last summer, I think I worked at Cheyenne's. 9 are an adult, so you can decide what you want to do, 10 Q. Cheyenne's is like a bar, saloon? 10 right? 11 A. Like a restaurant. 11 A. Yes. 12 Q. Restaurant. And what do you do there? 12 Q. But you have made no plans? 13 A. I was just waitressing. 13 A. No, not yet. 14 g How longhave you worked there? 14 Q. Is there anything, is there any activity that 15 A. I worked there for about a year. 15 you haven't done as a result of what you claim are 16 Q. You make like a minimum wage plus tips? 16 injuries or damages you sustained from being at 17 A. Yes. 17 Mr. Epstein's home? Is there anything you haven't done? 18 Q. And in addition to doing your waitressing, 18 A. I don't really know. 19 were you also in college; that is, were you taking some 19 Q. You can't think ofanything? 20 courses? 20 MR. HOROWITZ: Form. 21 A. Yes. 21 THE WITNESS: I mean I don't know. 22 Q. All right. And as well, would you go out 22 BY MR. CRTITON: 23 with this last year, Jane Doe 4 is with you hi '08, 23 Q. All right As you're sitting here, you can't 24 so this last year you would go out with your friends or 24 think of any activity or any trip or any school that you 25• stay out late when you finished your shifts? 25 have not done or a course that you haven't taken as a nes.w.o.sea....cotadva. 35 (Pages 259 to 262) 1561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107866 Page 263 Page 265 1 result of having been at Mr. Fpoein's home; is that 1 MR. HOROWITZ: I didn't raise my eyes. I said 2 correct? 2 she was responding to your question. 3 MR. HOROWITZ: Form. 3 You wanted her to say that she could still 4 THE WITNESS: Yes. 4 haveagoodtime- 5 BY bollt. CRITTON: 5 MR. CRITTON: Let Rachel read the question 6 Q. Let me show you Salt — are we on 6 back. Don't use up my time. 7 Exhibit 4? 7 (A portion of the record was read by the 8 (The document was marked Defendant's 8 reporter.) 9 Exhibit 4 for identification.) 9 BY MR. CRITTON: 10 BY MR CRITTON: 10 Q. Let me repeat the question so ifs clear. 11 Q. All right, let me show you Exhibit 4. Can 11 Exhibit 4 depicts you and out at 12 you — 12 Halloween in costumes drinking 27 days after the police 13 A. I see you guys have access to my MySpace and 13 interviewed you, and you told your parents for the first 14 Facebook. 14 time what, at least a wuncated version of what occurred 15 Q. My question is do you recognize that photo? 15 at Mr. Epstein's house, right? 16 A. Yes, Id°. 16 A. Yes. 17 Q. And who is that depicted in the photo? 17 Q. And you were able, certainly not just 18 A. That's.. 18 Halloween, but before that, after that you continued to 19 Q. And? 19 party and go to parties, correct? 20 A. And me. 20 A. I told you I used that, like me going to 21 Q. All right. And where were you at the time? 21 parties has nothing to do with my anxiety and all of 22 A. We wore — it was Halloween. We were 22 that. 23 somewhere for Halloween. 23 It's me trying to get, just trying to get ova 24 Q. All right So is it, Halloween is usually, I 24 everything and hang out with my friends and forget about 25 think it's October 30th? 25 everything that was going on. Page 2€1 Page 266 1 MR. HOROWITZ: Every year. 1 Q. Before you ever went to Mr. Epstein's house, 2 BY MR. CRITTON: 2 you hung out with your friends, right? 3 Q. Every year, or 3Ist, whatever it is. Probably 3 A Yes. 4 the 31st So that would have been October 3Ist That 4 Q. Before you ever went to Mr. Epstein's house, 5 would have been approximately 27 days after the police 5 while you may not have taken drugs, you did drink 6 took your, or interviewed you in the beginning of 6 alcohol, didn't you? 7 October of 2005; is that correct? 7 A. Not really. 8 A. Yes. 8 Q. So if people say before you ever went to 9 Q. So you were still able to go out, go to 9 Mr. Epstein's you never had alcohol or you had 10 parties, do those kinds of things even after the police 10 alcohol — I've got to start again. 11 interviewed you? 11 Is it your testimony that you never drank 12 A. A lot of times l use drinking as like a way to 12 alcohol before you went to Mr. Epstein's? 13 help me forget about what happened and forget about, you 13 A. I don't remember if I ever drank or not, but 14 know, the stress I was under because of it and about the 14 it definitely wasn't like I do now. Like I wasn't 15 whole thing. 15 partying. I might have had a beer or two beers, but I 16 MR. CRITTON: Okay. I'm going to move to 16 don't really remember. 17 strike as nonresponsive. So let me have Rachel 17 I remember starting to chink around my junior 18 read the question back to you and see if you can 18 year of college. 19 answer my question. 19 Q Olcay. 20 MR. HOROWITZ: That was responsive. 20 A I mean, sorry, high school. 21 MR. CRITTON: Yeah, right. 21 Q. And is it now your testimony that you arc 22 MR. HOROWITZ: It's not the response you 22 relating your drinking because you went to 23 wanted, but it's responsive. 23 Mr. Epstein's? 24 MR. CRITTON: Stop rolling your eyes or 24 A. Pm not relating. It just helps me cope with 25 raising your eyebrows in support of your position. 25 eve2thirsiand forjet about it. ObIRIOgietuAo...4?....4.citadareasmt.cacangde.4".. 36 (Pages 263 to 266) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107867 Page 267 Page 269 1 Q College kids are notorious for drinking, 1 BY MR. CRITTON: 2 right? I mean kids drink in college? 2 Q. What did I say? 3 MR HOROWITZ: Form. 3 A. Faoebook. 4 IIIE WI NESS: Yes. 4 Q. Facebook, okay, MySpace. Do you still have a 5 BY MR. CRITTON: 5 MySpace account? 6 Q. • All right. And you drink and you drink to 6 A. I do. 7 excess from time to time, just like other college kids 7 Q. Do you have a Facebook as well? 8 do? 8 A. Em sure you guys know. Yes, I do. 9 A. Yes. 9 Q. I get to ask questions. I don't even know 10 Q Okay, because your college experience is very 10 what I know sometimes. You still use Facebook? 11. similar to what other college kids' experience is, from 11 A. Yes. 12 what you've observed, true? 12 Q. And is it still — what's your — what's the 13 A. I don't think ifs half as similar as what 13 word that you key into if someone wanted to look at your 14 other college kids had to go through. And if they had 14 MySpace? They would look at what? What would they have 15 to go through this, Fm sure they would drink too in 15 to print in? 16 excess. 16 MR. HOROWITZ: Form. 17 MR- CRITTON: I'll move to strike as 17 THE WITNESS: What do you mean? 18 nonresponsive. 18 BY MR. CRITTON: 19 BY MR. CRAYON: 19 Q. What do you use as like your call — I should 20 Q. My question to you is other college kids go 20 know this, as your location. There is a word for that 21 out and party two, three, four times a week; that's not 21 and I can't — it says Jane Doe 7 on it, but what would 22 unusual, is it? 22 I type in to come to your MySpace page? 23 A. I mean some do, some don't. 23 MR. HOROWITZ: Are you asking her for a 24 Q. All right. And you are with a crowd that does 24 password? I don't think she has to give you that. 25 and you like to do that, don't you? 25 MR. CRITTON: No, I'm not asking for a Page 268 Page 270 1 MR. HOROWITZ: Form. 1 password, but just to get on your Facebook. 2 THE WITNESS: I mean I like to hang out with 2 THE WITNESS: You have to fiend request me. 3 my friends and drink. 3 BY MR. CRITTON: 4 BY MR. CRITTON: 4 Q. I'm sorry? 5 Q. All right. And you have described what your 5 A. You have to friend request me. 6 symptoms are after the last time you saw Mr. Epstein as 6 Q. If I just typed in Jane Doe 7, would your name 7 being — lees see what you described it -- as 7 come up under MySpace? 8 depressed, anxious, felt disgusting, self-conscious, 8 A. Yes. 9 flashbacks, can't eat and sleep. 9 Q. Same thing with Facebook? 10 Let me show you Exhibit 5. 10 A. Yes 11 MR. HOROWITZ: I'm going to object to these 11 Q. And then you would decide whether you want me 12 exhibits, particularly under rule 26. You guys got 12 to be your friend? 13 to turn this stuff over. You can't just come to a 13 A. Yes. 14 deposition with these things. And you haven't 14 Q. And I would be pretty confident that if I 15 produced tin 15 wrote to you, you would say no, right? 16 (The document was marked Defendant's 16 A. Probably, yes. 17 Exhibit 5 for identification.) 17 Q. All right, good. Let's stick with Exhibit S. 18 MR. CRITTON: Here. 18 This is your Faceboolc? 19 MR. HOROWITZ: Take a look at this. 19 A. My MySpace. 20 BY MR. CRITTON: 20 Q. I'm sorry, MySpace. It has Jane Doe 7's 21 Q. Do you recognize this as being part of your 21 blurbs, which means that you would have created that 22 Facebook space from the 2005 time period? 22 yourself, tight? 23 MR. HOROWITZ: Form. 23 A. Yes. 24 THE WITNESS: No. It's part of my MySpace. 24 Q. Could you read for the ladies and gentlemen of 25 25 the jury what you have under your blurb? 37 (Pages 267 to 270) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107868 Page 271 Page 273 A. Where is my blurb at? 1 A. Yes. Q. Under the Welcome. 2 Q. Where the lady is buying on her back with the A. This is ridiculous. I mean everybody has a 3 foot on maybe the pool attendant, is that a picture tha MySpace. 4 you would have chosen? Q. I'm just asking you to read it, nufam. 5 A. Yeah, I was a fan of Paris Hilton. A. 6 Q. Is that Paris? 7 A. Yes. 8 Q. All right. The Jane Doe 4 again on page two, 9 is the Jane Doe 4 there, is that — that's not Jane 10 Doe 4, is it, or is it or can y0u tell? 11 A. Yeah, that's Jane Doe 4. 12 Q Jane Doe 4 who? 13 A. Jane Doe 4. 14 Q Oh, that is Jane Doe 4, all right. 15 Ova on page four, where it says, which quote. 16 is that? 17 Q. All I'm asking you is to read it. I don't 17 18 want you to editorialize, please. 18 Q. All right. And over on page six there is an 19 A. I mean I see how you are going to turn 19 In fact, at the top of page six it has Jane Doe 4, 20 everything around, so — 20 11/29105. "Jane Doe 7, you need to call me. I was 21 Q. Please continue readin: 21 drunk last night when you called and only remember bits 22 A. 22 of what was going on. Call me, love you all." 23 Is that Jane Doe 4? 24 A. Yes. 25 Q. And under that is. also the same day. Page 272 Page 274 1 Says "I'm having a party, party girl. Talk to 2 about it. Losay2u." 3 Is than who you took to Mr. Epstein's 4 home? 5 A. Yes. 6 Q. And if you go over to page two, you say "Who 6 Q. So did you continue to remain friends with her rd like to meet" That's also what you wrote; Is that 7 fora period of time? true? 8 A. Yes. 9 A. Yes. 9 Q. Do you ever hear from her now? 10 Q. Read to the ladies and gentlemen of the jury 10 A. Uhuh. 11 what you put in December of '05, or at least what was on 11 Q. I'm sorry? 12 your MySpace account in December of '05. 12 A. No. 13 A. "I like guys who are fun and outgoing. Hike 13 Q. Let me show you what I'll show you as 14 guys who like to go out but at the same time don't mind 14 Exhibit 6. 15 staying in and watching a movie. Being too serious or 15 (The document wMS marked Defendant's 16 conceited is a turnoff. I don't like guys that are 16 Exhibit 6 for identification.) 17 really jealous either. I don't like getting hurt, so 17 MR. HOROWITZ: I'm going to again object in 18 Pm not one to get attached to one guy quickly. I 18 that the defendant to this day has not produced 19 believe there is someone for everyone. Ws just a 19 these things, despite their obligation under Wile 20 matter of them finding you? 20 26. 21 Q. Look on the pictures or page two. Do you get 21 BY MR. CARTON: 22 to choose the pictures that you put on MySpace? 22 Q. Now this is again from your MySpace pag 23 A. Yes. 23 A. Yes. 24 Q. Okay. So like the Dior one would be something 24 Q All right. And again, the photographs or 11e 25 you would have chosen and put in? 25 information say it's on_page one, that's you, correc 38 (Pages 271 to 274) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107869 Page 275 Page 277 left side? 1 A. Yes. A. Yes. 2 Q. All right. And then hanging out in the lofts Q. And in fact, this one says last login, 3 pool. Lofts is where you were living at the time? 7/14/2006. 4 A. Yes. Does that mean that's the date, that is tlx: 5 Q. The guy, do you know him? 6 last time you would have logged in to this? 6 A. Yeah, he's a friend ofmine. 7 MR. HOROWITZ: Form 7 Q. Boyfriend or just a guy friend? :3 THE WITNESS: At that time. 8 A. Just a friend. 9 BY MR. CRITTON: 9 Q. It says "Getting some sun in South Beach." 10 Q. All right. It says "Jane Doe Ts interests. 10 The picture on the right, who is that? 11 If you go to page two, it has Jane Doe Ts interests. 11 A. Me and. 12 This is now, this is you on July 14 of '06 12 Q 13 that you would have beeii.lis would have been the 13 A. Yes. • 14 end of your first year at 14 Q. Is that when you had met Mario? 15 A. (Witness nods head up and down.) 15 A. Yes. 16 Q. Correct? 16 Q. All right. Pictures on.page three, and again, 17 A. Yes. 17 let me, if I go back to page two where it gives a little 18 Q. Did you stay up in Orlando during that time 18 history of yourself, again, 19 period? 19 again, that's what you put on Facebook, correct? 20 A. Yes. 20 A. IvIYSPace• 21 Q. All right. What does it say Jane Doe Ts 21 Q. I'm sorry, MySpace. All right, and then the 22 interests are, general? Could you read that to the 22 pictures on page four, those again were ones that you 23 ladies and gentlemen of the jury? 23 chose, true? 24 A. "I love anything on the water and getting a 24 A. Yes. 25 tan. I rode horses since I was like four and still love 25 MR. HOROWITZ: Bob, how is it that you didn't Page 276 Page 278 1 it. I also like relaxing girls' nights out, surfing, 1 produce these things? I'm having a hard time, I'm 2 the beach, goofing off, partying, being in love, coming 2 still sat of wrestling with this. 3 up with funny dnmken sayings. I'm not going to lie. 1 3 MR. CRITTON: If you want to file a motion, 4 like to watch football. I'm a huge Steele fan and I 4 that's fine, and I'll explain to the Judge. 5 like baseball. Watching the Steelers isn't too bad 5 MR. HOROWITZ: I want her not to answer any 6 either." 6 questions about this stuff 7 Q. Are you pretty active even today on Facebook 7 MR. CRITTON: I think this is all impeachment 8 and MySpace? 8 information anyway. 9 A. Just Facebook. I don't use MySpace anymore 9 MR. HOROWITZ: I don't care, you have to 10 really. 10 produce it. 11 Q. MI right. Over on, the bottom picture on 11 MR. CRITTON: No,I don't 12 page two, who is in that picture? 12 MR. HOROWITZ: Yes, you do. 13 MR. HOROWITZ: Form 13 MR. CRITTON: We will respectfully disagree. 14 BY MR. CRITTON: 14 BY MR. CRITTON: 15 Q. Can you tell? 15 Q. If you to to page II. 16 A. Right here? 1.6 THE WITNESS: Do I have to answer this? • 17 • Q. Pardon? 17 MR. HOROWITZ: I don't know what the question 18 A. • 'tight here? 18 is, but l might tell you not to. 19 Q. No, the lower picture, it has three females. 19 BY MR. CRITTON: 20 A. Me and Jane Doe 4 and.. 20. Q. On page 11 it has a Jane Doe 4 and it looks 21 Q. Jane Doe 4 ant ? 21 Ifice the two of you were, or two faces arc hanging there 22 A. Yes. 22 . with their tongues out. Who is that? 23 Q. All right. Go over to page three. It has 23 MR. HOROWITZ: Is that impeachment? 24 pictures again. It has "A dangerous combo." Is that 24 Don't answer it. You guys aren't playing 25 you in the truck? 25 tinder the rules. You are not producing stuff that "IMPIIMIWaia,'••••••• l-Lo..Coar-muwiac-J.kt....V. , %12. 17.3.144g46faNNIAINISJosinh•OA 39 (Pages 275 to 278) .(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107870 Page 279 Page 281 1 you have to. Don't answer it. 1 Q. Do you remember who you did it for? 2 BY MR. CRITTON: 2 A. It says Kliman, I thirdc. 3 Q. Who is that, ma'am? 3 • Q. And is this the only form that you ever filled 4 MR. HOROWITZ: Don't answer it. 4 out for Mr. Kliman, Dr. Kliman? 5 MR. CRiTTON: On what grounds? 5 A. I mean i filled out a couple of forms. 6 MR. HOROWITZ: Because you are supposed to 6 Q. Was it testing or was it like background 7 produce this. 7 information on yourself? 8 BY MR. CRITTON: 8 A. I think both 9 Q. The next iS down where there is a picture 9 Q. I'm sorry? 10 and it says "Go fuck yourself;" 7/2/2006, who is that 10 A. I think both 11 ma'am? 11 Q. Okay. And just so I'm — in looking at this, 12 MR. HOROWITZ: Don't answer it. Don't answer 12 it looks like what you did is you blacked out any 13 it. 13 portion or kind of circled any aspect that you felt was 14 Bob, you need to produce this stuff. You 14 applicable to you; is that how you answered these? 15 can't just surprise people. 15 A. Yes. 16 BY MR. CRITTON 16 Q. Okay. Would you consider your intellectual 17 Q. There is an in here. Who is 17 ability to be above average? 18 please? 18 A. Td like to think I'm smart. 19 MR. HOROWITZ: Don't answer it. 19 Q. Okay. My question is do you rate your 20 BY MR. CRITTON: 20 intellectual ability as above average? 21 Q. Do you know a person named 21 MR. HOROWITZ: Form 22 MR. HOROWITZ: All right. 22 THE WITNESS: Is that on here? 23 THE WITNESS: I'm not going to answer it 23 BY MR. CRITTON: 24 MR. CIUTION: On what grounds? 24 Q. Can you just answer my question? 25 25 A. Yes. Page 280 Page 282 1 BY MR. CRiTTON: 1 Q. And if you look at question 18, you consider 2 Q. I'm not talking about tins exhibit if you 2 your intellectual ability above average, right? 3 know somebody named 3 A. Yes. 4 MR. HOROWITZ: Go ahead and answer it. 4 Q. Never held back in school, you made mostly A's 5 THE WITNESS: What are you talking 5 and B's, right? 6 about? 6 A. Yes. 7 BY MR. CRITTON: 7 Q. Never had trouble in school, never had trouble 8 Q. Do you know a girl named that was a 8 learning to read? 9 friend of yours? 9 A. No. 10 A. When? 10 Q. Did you have a little trouble with math? 11 Q. 2006. 11 A. Yes. 12 A. Yes. 12 • Q. Okay. Neither your peers, none of your peers 13 Q. Who is, what's her last name? 13 ever teased you, made fun of you while you were in 14 A. I think it's=, if that's the girl you 14 school, correct? 15 are talking about. 15 A. No. 16 (The document was matted Defendant's 16 Q. And when you were in high school, were you a 17 Exhibit 7 for identification.) 17 cheerleada'? 18 BY MR. CRiTTON: 18 A. Yes. 19 Q. Let me show you Exhibit 7. Do you recognize 19 Q. Howniany years? 20 what Exhibit 7 is, ma'am? 20 A. I think for two years. i did basketball 21 A. Yes. 21 cheerleading. 22 Q. What is it? 22 Q. In what, your junior and senior year? 23 A. My psychological social history. 23 A It was my sophomore and junior year. 24 Q. And when did you do this? Q. Sophomore and junior year, all right. Were L25 ±Jdmftren ber _ 25 you in any clubs, any extracurricular activities? 40 (Pages 279 to 282) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC.. ( 561) 832-7506 EFTA01107871 Page 283 Page 285 A. No. 1 A. I do like marketing and promotions. 2 Q. Did you play lacrosse? 2 Q. In what way? 3 A. !didn't actually play for tern. I tried out 3 A. Just like sampling productsand promoting 4 for the team, but I never 4 products. Q The club team? 5 Q. What do you mean sampling products? Do you A. Yeah, but I never played on the team. 6 get paid to drink liquor? 7 Q. What else did you do other than cheerleading? 7 A. You are not allowed to drink at the job. A. I just did track for like, fora year. 8 Q. What are you sampling then? 9 Q. Which year? 9 A. I give other people samples of different 10 A. I think it was my sophomore year. 10 liquors so they can try it 11 Q. Student council? Were you on student council? 11 Q. Do you go to like ABC Liquor store or Total 12 A. No. 12 Wine or someplace like that? 13 Q. Did you do any kind of volunteer work, helping 13 A. We go to bars and restaurants. 14 other people? 14 Q. What kind of products do you push? Talking 15 A. I mean I didn't do any volunteer work, no. 15 like scotch and bourbons or you are doing wines? 16 Q. Did you do any volunteer work in college? 16 A. I do American Honey and Malibu and Jameson. 17 A. Yeah, I was part of where like we had this 17 Q. As pan of the marketing, do you dress up for 18 hospitality group and I like donate to them and stuff. 18 this? 19 Q. What do you mean you donate? You donate -- 19 A. Yes. 20 A. Money to them. 20 Q. What do you wear? 21 Q. More importantly, did you donate time? Did 21 A. We have to wear cowboy boots, a skirt, and 22 you go and work for any charities like boys' club, 22 then just a shirt that says American Honey on it. 23 girls' club, any type of church or other nonprofit 23 Q. Is it kind of like a modeling gig in addition 24 organization during the time you've been in Orlando? 24 to the marketing? 25 A. I mean I had a MI load of classes and I was 25 A. Sort of yes. Page 284 Page 286 1 working. I don't have time to, l mean like do a lot of 1 Q. And your skirt, short skirts or calf lengths 2 stuff. 2 or cowboy skirts? 3 Q. How many hours do you take right now? 3 A. Just normal size. They don't give any size. 4 A. Right now is my easiest semester. I'm taking 4 Just normal jeans skirt. 5 three classes. 5 Q. Is that what you are doing in terms of with 6 Q. Three classes? 6 the liquor? A. IA huh. 7 A. Yes. 8 Q. How many hours is that? 8 Q. And how many days a week do you do that? 9 A. Lae twelve. 9 A. Whenever I get scheduled for it. 10 Q. Twelve hours or nine? 10 Q. How many times a month would that be? 11 A. Time. Yeah, nine hours. 11 A. Probably about two times a week, three times a 12 Q. How many days do you go to school? 12 week 13 A. Tuesday and Thursday. 13 Q. And then you said that on the — you help your 14 Q. So all your classes are on Iliesdays and 14 dad. That's through the interact sales, right? 15 Thursdays. Are you working at the current time? 15 A. Yes. 16 A. Yes. 16 Q. But you have free time, don't you? 17 Q. Where are you working? 17 A. I mean everybody has free time. 18 A. I'm worldng with my dad and I'm also working 18 Q. Okay. At least again, this was on 19 and Fin trying to start like a business of my own, and 19 December 5th of '08, it says which of the following have 20 I'm also working for three different liquor companies. 20 you used, and of the drugs you listed marijuana, right? 21. Q. 'three different what? 21 Which you told me earlier today. I'm on 52. 22 A. Liquor companies. 22 A. Uh huh. 23 Q. Liquor companies? 23 Q. Do you see that? It says, "Has there ever 24 A. Yes. 24 been a time in essence you drank too much alcohol?" 25 Q. What do you do for them? 25 You say "Yes, on more than several occasions," 41 (Pages 283 to 286) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107872 Page 287 which Is consistent with what you told me, and you also 1 2 told me you drink several times a week, all of which 2 3 would be true, correct? 3 4 k Yes. 4 5 Q. At this time it says you were single, but 5 6 involved in an intimate relationship. 6 7 Who was that relationship with? 7 8 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 Page 288 1 2 3 4 5 b 6 7 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 42 (Pages 287 to 290 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107873 Page 291 Page 293 1 2 2 3 3 4 4 5 5 6 6 7 8 9 9 10 10 11 11. 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 Page 292 Page 294 1 2 2 3 3 1 4 5 5 6 6 I 7 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 sba , ..0•44#4,64.4, 43 (Pages 291 to 294) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107874 Page 295 Page 297 1 1 2 2 3 4 5 6 6 7 8 8 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 MR. CRITTON: Let's take a break for five or 21 21 ten. 22 22 THE VIDEOGRAPIIER: Going off the record at 23 23 3:54 p.m. 24 24 (A recess was taken.) 25 25 (End of Volume II) Page 296 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • ••.A.N.4.1 ea+-1344. arssimerazraxesi 44 (Pages 295 to 297) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107875