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Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.502008CA028051XXXXMB AB L.M. , Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. HEARING BEFORE THE HONORABLE DONALD HAFELE Thursday, February 4, 2010 Palm Beach County Courthouse West Palm Beach, Florida 33401 9:05 a.m. - 9:30 a.m. Reported By: Denise Sankary, RMR, CRR Notary Public, State of Florida Prose Court Reporting Agency, Inc. Job #1303 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sankasy (201431445.2309) 61c120365-86ao-dfol-Ixt88-25626c08ac76 EFTA00723885 EFTA00723886 Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 4 BRADLEY J. EDWARDS, ESQUIRE FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & 5 LEHRMAN, PL 425 N. Andrews Avenue, Suite 2 6 Fort Lauderdale, Florida 33301 7 8 On behalf of the Defendant: 9 ROBERT D. CRITTON, JR, ESQUIRE 10 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 11 West Palm Beach, Florida 33401 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 4 1 prior sexual history, to which both plaintiffs' 2 counsel, which the Court had ruled on, and 3 plaintiffs' counsel said, these are the areas 4 that we're going to allow her to testify on. 5 There's one specific area post seeing 6 Mr. Epstein that was on appeal to the Fourth DCA at the time, but at her deposition on September 24 they took a very broad view. We filed a motion to compel and sanctions. At that time we also asked for any journals, because she had testified on deposition that she worked as a prostitute, as a call girl, as an escort during '06, '07, '08. She testified, and Tye attached portions of pages of her deposition to this motion, where she says, I kept books. 1kept them for '06, '07, and '08. Certainly '06 and '07 and '08. She testified on pages 58 through 61 through 65, Mr. Luther, who was taking her deposition, said you know, What do you have? She said. I have books from '07. I've got them front '08. One of the books has a psalm on the front of the book, a passage from the Bible. It reflects that — and he asked her on page 63, "How many of these books are there?" Page 3 1 PROCEEDINGS 1 2 2 3 MR. CRITTON: Good moming, Judge. 3 WE COURT: How are you? 4 5 MR CRITTON: May it please the Court 5 THE COURT: Go right ahead. 6 7 MR. CRITTON: Your Honor, as you know,1 7 8 represent Mr. Epstein. This is an amended 8 9 motion to compel documents responsive to a 9 10 request to produce which was served on 10 11 October 21. I think this is Take 3 that we've 11 12 been here, so I know the Court has probably 12 13 looked at the documents at least once. So I'll 13 14 put it in perspective. 14 15 L.M. was deposed on September 24. 15 16 Previously we had sent some written discovery 16 17 to her, which included requesting information 17 18 regarding income and as well information 18 19 regarding any diary or journals that she had. 19 20 We came in front of the Court after her 20 21 . deposition and there were two motions. One was 21 22 a motion for sanctions saying that the 22 23 plaintiff and her attorney took — asserted 23 24 privileges, privacy rights, et cetera, with 24 25 regard to specificall issues_relatit! to her 25 • Page 5 She says, 'Two or three." "Where are they currently located? "Objection to form." This is Mr. Edwards. "Don't answer. I'm invoking her Fifth Amendment right to the location." Mr. Luttier, "How is the location going to violate the Fifth Amendment?" And he didn't — he, Mr. Edwards, directed his client and his client took the Fifth with regards to these books. But clearly she said she had them. She also said that she had, in another portion, she had videos, adult videos. This is a lady who is asking for between a million to 5 million to $50 million. She's claiming loss of earnings in the past, loss of earnings capacity in the future. She is, as the Court is aware, claiming all sorts of emotional damage and mental damage. Therefore, what occurred, what purportedly occurred with Mr. Epstein, and Ill represent to the Court is that she testified she never had intercourse with him, never had anal sex with him, never had oral sex with him. I never touched any of his private parts. So what are you doing with these other people? And does that cause ou any emotional scars or 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. Esc rim ca y sgne ry or ankary (2014314464309) eftet1365-136ao-Mol -be88-25626c0Bac76 EFTA00723887 Page 6 1 any emotional issues? So it's clearly relevant 2 material. 3 The Court, with regard to the motion to 4 compel, said, look — you ordered that she 5 appear. You didn't grant sanctions. There was 6 another hearing the next day where the Court 7 had a hearing with regard to limiting her 8 deposition that her counsel had filed on her 9 behalf saying no more time. The Court said, 10 look, I read the deposition. It appears that 11 you got about two hours of it or an hour out of 12 it, Pm going to give you, Mr. Luttier, or 13 defense counsel another six hours to do her 14 deposition. 15 And Mr. Edwards, you need to get a copy of 16 this transcript, print it up; so that you can 17 show it to your client so that she knows how 18 the deposition is to be conducted. 19 This is the lady who at her deposition 20 Mr. Luther said, "How did you get to this 21 psychologist Amy Swan?" And she wouldn't 22 answer. He said, "Well, did your lawyer send 23 you?" And she said, "You're a jackass. You're 24 an F-ing A blank." That was her response. So 25 this is a lady who clearly understands her 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 Page 8 Clearly privacy rights trump. She is the one who wants money in this case. Three, she again asserts a privacy right. And interestingly, on 1, with regard to the book, your earnings as a prostitute or a call girl, both I and 2 they refer to, and all of a sudden she says none, and this is after her deposition that occurred on September 24. On the motion to compel, the Court said, you got to produce that stuff. Just to be very specific about it, I sent a second request to produce. All of a sudden the books she had for '06, '07, '08 are now "none." She doesn't have any books. And I couldn't have been more specific, because as the Court recognizes, i referenced those portions in the transcript where she said, I've got a book, where I have books. On 5 she says, i have none in my possession. Well, what's that mean? Does that mean you dumped them to one of your friends? You gave it to an investigator? You gave it to someone else? You hid it in a safety deposit box? All of a sudden it's not in your possession. Page 7 responsibilities under the law. 2 When we sent interrogatories - Pm sorry, 3 the second request to produce originally, there 4 was no timely response, and I took into account the stay that the Court had entered when 6 Mr. Edwards' firm, the Rothstein, Rosenfeldt & 7 Adler firm, went into or imploded, so the Court 3 gave them some time, but they still didn't 9 timely file. They did ultimately file a 10 response, and therefore, I filed an amended 11 motion. 12 And I'm interested really in 1, 2,4, and 13 5. And these are the books, the journals that 14 were specifically identified at her deposition. 15 And she was claiming, ml made between $200 and 16 $2,000 a night' So clearly if she has a lost 17 wage or loss of ftiture earning capacity claim, 18 what occurred with these people, vis-a-vis 19 Mr. Epstein and where did any real emotional 20 damage, if any, occur? 21 She testified -- they objected based upon 22 that it's not relevant or material. i don't 23 think I even need to argue that to the Court on 24 1 and 2. 25 n On 2 they ratalth ....erty!teiright. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 9 On 5 I asked for her information with regard to her -- basically her johns. On 7, which relates, and 8 and 9, which relate to the adult entertainment videos, which she also testified, she says, 'I don't have them in my possession." And same with 11, you know, documents that relate to your employment as she described a Bunny Ranch. Page 46 of her deposition, she says, none in her possession. What does that mean? So what Pm asking for the Court, and I recognize that — well, i don't recognize I won't editorialize too much. But what I will say is that clearly the plaintiff had these books. She had records. Clearly she's gotten rid of them because she said she doesn't have them, and certain things are not in her possession. I would ask that the Court overrule all the objections. Again, no Fifth Amendment. There's no attorney/client There are no privilege objections that may withstand a late filing or even late objections that are asserted. None of those are asserted. And secondly, that she give an affidavit ....„_s2t ! prior to her deposition I r el ....2 ficall 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sankary (201-131.345.2309) Od2•365-86ae-41e1-be88-26626c08ac76 EFTA00723888 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 Page 10 which is scheduled on February 9, I believe, is that she say what happened to these books or write an affidavit to the Court as to where the information is that existed on the date of her deposition now no longer exists. And with regard to 'none in my possession," what's that mean? Who's got it? THE COURT: All right, thank you. My understanding at this point is that any certiorari review by the Fourth District Court of Appeals has come back, and on the discovery issue in particular was denied on the merits, correct? MR. EDWARDS: On the issue of sexual partners and sexual acts and things of that nature, that my client will be answering questions to on the 9th, yes. THE COURT: Okay. I just wanted to make sure. MR. EDWARDS: Yes, and that was the substance of that prior motion to compel, and we intend to comply fully with that. THE COURT: I'm not suggesting you aren't. I just wanted to make sure — MR. EDWARDS: This is a different issue. Page 12 1 That's it, period. 2 THE COURT: The relevance, just to 3 remember, and this was the basis of my earlier 4 decision in dealing with the other issues, and 5 that is, that we have someone who is claiming 6 significant psychological trauma as a result of 7 her interactions with the defendant and the 8 type of trauma that she is alleging that this 9 or that these problems stem from is sexual in 10 nature. So there is some type of connection. 11. Also of import is the allegation that the 12 defendant paid her and others for whatever 13 intimate involvement is being alleged occurred. 14 Sol think from a global perspective, that's 15 really more of what's of interest to the Court 16 when it comes to relevance than what the amount 17 of the monetary claim is. That's not of 18 importance to me. 19 MR. EDWARDS: Understood. Addressing 20 specifically this particular motion, any videos 21 that were ever in her possession depicting 22 sexual acts, we indicated that we would give 23 them. My client does not have them in her 24 possession. If you read her deposition, at 25 some point in time she testified that — or she Page 11 1 THE COURT: — just for my administrative 2 understanding. 3 Mk EDWARDS: That's correct. 4 THE COURT: We just get one single page 5 that says denied on the merits. We don't get 6 much of an explanation. 7 MR. EDWARDS: Right 8 THE COURT: So I just wanted to make sure 9 that that was one of the things that was 10 affirmed on the merits. Go ahead, Mr. Edwards. 11 MR EDWARDS: Many things were argued just 12 now that don't necessarily pertain to this 13 particular hearing. And every single hearing 14 that we have we listen to Mr. Critton say, 15 she's asking for SI 0 million, S50 million. 16 That's never happened. The only evidence of 17 any — 18 THE COURT: I just considered that 19 rhetoric. I don't find it to be necessarily 20 persuasive. 21 MR. EDWARDS: That's always the crux of 22 the argument as to why this stuff should be 23 available, and that's not really true. The 24 only thing that's ever been alleged is it's 25 over 515,000 for jurisdictional purposes. 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 13 did engage in a sox act that was on video. She no longer has that video. She doesn't know where that video is. She didn't state in her deposition she knew where the video was. THE COURT: Well, again, Mr. Critton's only concern is that by saying not in someone's possession, that there's at least potentially a suggestion that it may be in someone else's possession of whom she knows. MR. EDWARDS: And 1 expect him to ask her where it went and trace it to wherever it went, you know. It's just not in her possession, but obviously it existed at one point in time. She's going to testify to that. THE COURT: If you're representing that she will testify and/or you can amend the interrogatory answer to indicate that not only is it not in her possession, but she does not know the whereabouts of same, I think that would be more conclusive. MR. EDWARDS: Okay. THE COURT: And the better answer. Let's talk about them in order, since I'm better doing it that way than I am just picking them out randomly. One says, "All documents 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sanitary (201-131.345.2309) 6fd2e365- se el-be88 5 c ac EFTA00723889 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 14 which relate to your earnings as a prostitute or call girl." It says, "Without waiving said objection, none." If I'm not mistaken, I think one of the District Court of Appeals said that such an answer basically does waive the objection. So the answer is none. There's not much I can do about that. It says none, it says none. MR. EDWARDS: And your Honor, the only — THE COURT: So that's going to be construed as the answer. The next one is the book containing the reference to a Bible verse. It says, "See response to request to produce Number I ." I presume that when it gets to the bare bones, it's none; is that correct, or does that not apply? MR. EDWARDS: She did testify in her deposition about having a book, and I believe that it contained records regarding such earnings. I did stop her from testifying to that after we conferenced about her possibly providing information that would provide a link in the chain to a possible prosecution of her, and that it was possibly going to require her 1 2 3 4 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 16 lawsuit, and therefore, we have very little, if any, communication can take place between our offices. And we end up in front of your Honor on these issues when I think this probably could have been eliminated if we could have just talked about the fact there's no earning capacity claim. I just wanted your Honor to understand that we're not here to waste your time, but we do have a communication problem for that reason. ME COURT: I appreciate that. Okay, well, getting back to the issue at hand, does she have this book or doesn't she? MR. EDWARDS: She had it, and she has not been able to locate it, but I'm not going to say she doesn't — at the time she had her deposition taken, she thought she still had it, although she hadn't touched it in quite some time. She has moved. She's moved. So I don't know if she's going to be able to locate it or not. Ifs going to be our position if she does locate it, that it would -- that she can invoke her Fifth Amendment right as to the production of that document, and it should not be discoverable for that reason. At this time, Page 15 1 to admit to criminal actions, and there would 2 be a Fifth Amendment invocation there. I 3 overlooked that apparently in my response, but 4 obviously that was the objection at that time. 5 And just so that the Court is clear, and I 6 know that the relevancy that Mr. Critton cited 7 was the lost wage and loss earning capacity 8 claim. The loss earning capacity claim, lost 9 wage claim in LIvfs case has been withdrawn. 10 I'll say it on the record it's been withdrawn. 11. Ifs no longer an issue in this case. So all 12 of these requests about earning potential and 13 earnings from the practice of prostitution is 14 not relevant right now, especially at this 15 stage because that's not an issue. And that 16 was done strategically obviously related to the 17 Fifth Amendment invocation not wanting to go 18 down that road. 19 And I can tell you, your Honor, that these 20 hearings would happen a lot less frequently 21 except for the great working relationship that 22 Mr. Critton and myself had at one point in time 23 has all but dissipated when a lawsuit was filed 24 by Mr. Epstein against me personally. 25 aa Critton has signed his name to. that 25. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page she doesn't have it in her possession. THE COURT: All right Well, let's talk about the Fifth Amendment issue. Mr. Critton, what's your position in that regard? MR. aurrow: rve heard two things that are not set forth in response to the second request to produce. THE COURT: I understand. MR. CMITON: I heard too that was never argued with the hewing on motion to compel when you said produce your diaries and books, et cetera So the withdrawal of the loss earning claims and wages, I may have missed that. I'm happy to communicate with Mr. Edwards as we have no trouble in tenns of letters. So that's not a problem. That claim, has it been withdrawn as of today, or have I missed something along the way? MR. EDWARDS: It's been withdrawn before today. MR. CRITTON: Unknown to me and it was not 2omething that was argued. 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sankary (201-131445-2309) 8fd2s386.86aa4M-bs88.25628c08ae76 EFTA00723890 3. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 18 THE COURT: Well, it's now on the record. So let's move on relative to that. So taking that into consideration, there's still the emotional trauma issue, and there's still the relationship between whatever this woman did relative to her activities of a sexual nature and in relationship to those allegations that she made, that she's made concerning Mr. Epstein of a sexual nature. So I think there's still that ability to juxtapose the activities that transpired prior, during and to some degree after Mr. Epstein's engagement with this woman, if any, that may pertain to the emotional trauma that she is alleging resulting from the allegations of a sexual nature against Epstein. So how do we deal with that in conjunction with and in recognition of LM's potential Fifth Amendment rights? That's going to be the issue I think as far as these matters are concerned. I think that by admitting to what she did in her deposition, there is at least some argument of waiver. I'm not going to suggest that she — when I say "waiver," I'm talking about waiver of the privilege to a certain Page 20 1 than to do it at an 8:45 hearing where either I 2 or Mr. Edwards or even the Court might act, 1 3 don't want to say precipitously, but without 4 full knowledge and the ability to look at it, 1 5 would like to see how I want to posture that. 6 THE COURT: I agree, and I think that's 7 the best way to handle it, and I appreciate 8 that deference. 9 With regard to any — the same thing with 10 regard to the, not having to do with the Fifth 11. Amendment issues, I don't think, but relative 12 to the DVDs or anything of a sexual nature, 13 that she allegedly was involved in when she was 14 19, those would have to be more fully answered. 15 If they're not in her possession, that's one 16 thing. If she knows where they are, that's 17 another. If she says, as Mr. Edwards is 18 proffering today, that she does not know the 19 whereabouts of them, or of it, I don't want to 20 suggest that there's more than one if that's 21 the case, then that should be the way it's 22 responded to. Again, perhaps it's better done 23 in five days when the deposition is being taken 24 to obviate the need for any further response on 25 those particular questions, but you're Page 19 1 degree, not the waiver of the objection. I'm 2 going to respect the fact that you objected on 3 the record to the questions on the Fifth 4 Amendment grounds. That's been acknowledged by 5 Mr. Critton. And so even though it's not 6 specifically stated here in the response to the 7 defendant's second request for production, I'm 8 not going to suggest that she waived her right 9 to a Fifth Amendment privilege. I am, though, 10 concerned about whether or not she has waived, 11 to a degree, her Fifth Amendment privilege by 12 virtue of a response to the questions at the 13 deposition. Do you understand the distinction? 14 MR. EDWARDS: I understand, your Honor. 15 MR. CRITTON: Here's what I would like to 16 do, your Honor, because — I would ask that -- 17 she's set for deposition on February 9. I 18 would ask that Mr. Edwards, on her behalf, be 19 required to file an amended response to our 20 second request for production. So if he wants 21 to assert the Fifth so it's there, so that I 22 have a record of it, and then I want to be able 23 to respond to it based on how she's responded 24 previously in her deposition and how she 25 responds at this particular time. And rather %A& Page 21 1 suggesting, I think, Mr. Critton, that you want 2 these responses before the 9th. 3 MR. CRITTON: Yes. And part of it is, I 4 want on the record of what they didn't respond 5 to than what they did respond to what we now 6 heard on the record, and now the newest 7 response, which is going to be the response to 8 the amended response. And therefore, as the 9 Court suggests, if you don't have it, tell us 10 you don't have it. You don't know where its 11 whereabout is, fine. If you know where it is, 12 tell us. And you want to assert the Fifth 13 Amendment, then at least I can address it 14 properly. 15 THE COURT: The only other thing I want in 16 address, and these gentlemen and ladies have 17 been very patient, is what the medication or 18 medications have to do with the matter. I 19 don't recall if I did. I just don't recall 20 reading anything in the deposition about 21 medications, but I may have missed it. 22 MR. CRITTON: It probably wasn't in at 23 least the portion that was given to you, but 24 there's been substantial testimony regarding 25 different types of drugs, both prescription and 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Seamy (201.1314454309) EFTA00723891 Page 22 1 nonprescription that they took. So if they 1 2 took Xanax or other type drugs, which seems to 2 3 be typical among a number of the individuals 3 4 who are plaintiffs in this case, or other 4 5 prescription medication, what did you take? 5 6 Did you have a prescription for it? If you 6 7 have it, give it to us. If you don't have it 8 in your possession, tell us that you don't. have 8 9 it. But if you're taking medication, tell 9 10 about it, in particular, as it may affect 10 11 either their testimony or what they did or what 11 12 their, what their issues are associated with 12 13 the emotional and mental and psychological 13 14 damages. Medications have a significant 14 15 impact. And not only the plaintiffs' experts, 15 16 not in this case because we haven't seen their 16 17 report, but every physician that's examined 17 18 them are always very interested in having their 18 19 medication past history as it affects their 19 20 mental state. 20 21 THE COURT: Mr. Edwards. 21 22 MR. EDWARDS: He's asking for the 22 23 medication that she's taking now or that she 23 24 has in her possession now when we were talking 24 25 about something that happened when she was 13, 2 5 Page 24 of admissible evidence. The admissible evidence, in my view, is not so much whether or not this person is on any form of medication. The importance is, one, whether she's on that medication at the time of the deposition, and two, whether or not there's any allegation that the reason that she's on the medication has anything to do with the claims against the defendant MR. CRITTON: May I say just one thing, your Honor? THE COURT: Briefly, please. Mr. Glatthom is looking at the ceiling in obvious impatience. I say that jokingly. MR. CRITTON: If the plaintiff was taking medications, say, for an STD, how did you get it? What. were the circumstances? How does that affect your emotional state? Let's say, as a result of her having been a prostitute, by her own testimony, for a long period of time, she's HIV positive. It affects her lifespan. It affects damages into the figure, and it certainly would affect her emotional state, if she's on kidney dialysis or kidney medication or other significant medication that may be Page 23 1 14, 15, 16 years old. There can be no 2 relevance to any medication that's she 3 prescribed now, unless we were claiming that 4 the medications she's prescribed now is 5 something that is as a direct result of 6 anything that happened with Mr. Epstein. 7 THE COURT: Well, that's basically the 8 question I think is best phrased, and that is, 9 are you claiming that any of the medications 10 that you are presently taking are related in 11 any way to your contact with Jeffrey Epstein? 12 I think That the defendant is able to ask 13 genetically at the deposition whether you are 14 on any drugs or alcohol or anything of that 15 nature, any mind-altering substance at the time 16 of the deposition to see if that person is in 17 fact lucid and not under the influence. 18 1 don't have a problem with that question 19 being asked at any deposition, frankly, because 20 it's not unusual that someone is on some type 21 of medication, and I think that's fair game as 22 a litigant in a case. 23 But again, I don't want to get into a 24 lengthy diatribe here on issues that are not 25 reasonabl calculated to lead to the discov Page 1 life-threatening or life-altering in some 2 fashion. She has a young child. That 3 certainly would have an impact upon her 4 emotional state, and therefore, it's relevant. 5 THE COURT: Well, again, 1 don't have a 6 problem with asking specific questions, but the 7 question that's indicated here I think is 8 properly objectionable. The question reads, 9 quote, "All prescription bottles, receipts or 10 documents reflecting medication you were 11 prescribed." I have no idea what that means. 12 I don't know what the time frame is, and it's 13 not as pointed as you have brought out. I 14 don't have a problem with you asking those 15 pointed questions at deposition, because they 16 do have some relevance, and we do have to 17 remember that this woman, as well as others, 18 are the plaintiffs in a lawsuit. So they have 19 brought their case before the Court and do have 20 to reveal some things that may otherwise be 21 personal by virtue of their position in the 22 lawsuit 23 That does not have endless bounds. I 24 understand. However, I think some of the 25 uestions that Mr. Critton 'ust raised are 2 5 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sankary (201431-3464309) efd2e36 - ae e - e - c ac EFTA00723892 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 Page 26 relevant, can be asked at the deposition, but Question 10 I find to be overly broad and therefore properly objectionable. IT sustain the objection as indicated in Question 10. I do have to move on, gentlemen, but again, I allow you to ask the same type of pointed questions without going into great detail and not invading this woman's privacy to a degree that it's going to be harassing. But when it comes to pointed questions regarding medication that could deal with lifespan, that could deal with STDs, that could deal with HIV positive, we're now going into another sacrosanct ground, but read up on the cases before you get into that so we're not going to be back on another issue. And again, whether or not she's on any medication or anything else of a mind-altering nature at the time of the deposition being retaken or whether she was on any medication at the time of the prior deposition was taken think is flu. game. All right. So that's the best I can do today with the limited time that we have. I do have to move on, gentlemen. Thank you. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 28 CERTIFICATE STATE OF FLORIDA COUNTY OF PALM BEACH I, Denise Sanktuy, Registered Professional Reporter, State of Florida at large, certify that I was authorized to and did stenographically report the foregoing proceedings and that the transcript is a true and complete record of my stenographic notes. Dated this 8th day of February, 2010. DENISE SANKARY, frlz 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 27 MR. CRITTON: Could 1 get the response by Monday by mail? THE COURT: You could fax it by Monday. That's fine. MR. CRITTON: Do you want us to prepare an order and then provide it? THE COURT: The best you can. MR. CRITTON: HI just refer to the transcript THE COURT: Try to continue your communication. MR. CRITTON: Thank you, your Honor. MR. EDWARDS: Thank you, your Honor. (The hearing was concluded at 9:30 a.m.) 8 (Pages 26 to 28) PROSE COURT REPORTING AGENCY, INC. Electronically signed by DOTIISO Sankary (2014314454309) 6822•38511M1115 EFTA00723893