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Page 2 I APPEARANCES: 3 On behalf &Jane Does I through 8: JESSICA ARBOUR, ESQUIRE MERMELSTEIN & HOROWITZ... • 18205 Biscayne Boulevard Suite 2218 • Miami, l ' Phone: E-mail: On behalf 9 MICHAEL J. PIKE, ESQUIRE BURMAN, CRTTTON, LUMER & COLEMAN, UP 10 303 Banyan Boulevard Suite 400 11 Wed Palm Florida 33401 INDEX VOLUME I 12 13 14 15 16 17 ROCKY ORE22011 BY MR. PE103 3 19 BY MS. ARBOUR 33 20 21 22 23 24 25 18 WITNESS: DIRECT CROSS REDIRECT RECRO&S 9 10 11 12 13 14 15 16 17 38 19 20 21 22 23 24 25 Page 4 1 The other thing is that I am going to be 2 asking some questions. In everyday language it's 3 very common for the other person to start talking 4 giving an answer, before the question is even done. 5 So, what I would ask is please allow me to finish my 6 question. And then I will allow you, in nun, to 7 finish your answer before I start the next question. And this is just to make the court reporter here haPPy. Okay? A. Okay. Q All right. Please state your name for the record. A. Rocky Ore2zoli. Q. Can you spell that, please. A. R-o-c-k-y, last name is, 0 -r-e-24-z-o-1-i. Q. Where is you current residence address? A. Delray Beach, Florida. Q. What the address? A. Q How long have you lived there? A. Six years. Q. Okay. And where are you currently employed? A. Technically I am self-employed. Q. What do you do? ' 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 3 PROCEEDINGS Deposition taken before Cynthia Hopkins, Registered Professional Reporter and Florida Professional Reporter, and Notary Public in and for the State of Florida at Large, in the above cause. Thereupon, (ROCKY OREZZOLI) Having been first duly sworn or affirmed, was examined and testified as follows: DIRECT EXAMINATION BY MR. PIKE: Q. Sir, my name is Michael Pike. 1 teprrsaa a gentleman by the name of Jeffrey Epstein in this matter. Have you ever had your deposition taken before? A. No. Q. Okay. The way that it works is the person sitting to your right and to my left is a court reporter. The machine sties typing on doesn't understand nods of the head or uh-huh and unh-unh. So, what I would ask you to do is give a verbal response so that she could take it down on the machine there. 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 5 A. I am a soccer coach. Q. Okay. Where do you work? A. I work for Team Boca which is a soccer association of Boca Raton. I am contracted to work for them I should say. Q. Is that a full-time position? A. Yes. Q. Okay. What schools do you work at? A. I don't work at schools. Q. Was there ever a time that you were a soccer coach for any particular schools, high schools and/or college? A. Yes. Q. What roil s A. I svas at ..) ? kay. How long were you at • A. I was an assistant there for five seasons and also was head coach for 11 seasons. I taught sonic classes there as well. Q. Five seasons and 11 seasons, does that work out in years? A. More or less, y Q So, were you ata for more than ten years? PROSE COURT REPORTING AGENCY, INC. 2 (Pages 2 to 5 Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-061-976-2934) cea14d6c-3516-4ced-842b-e31268082244 EFTA00729386 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 6 1 A. Yes. Q. And did you teach did you coach both boys and girls soccer? A. No, just girls. Q. Was there ever a time you worked at any high schools teaching soccer? A. Yes. Q. Okay. What high schools? A. Spanish River High School. Q. And what else? A. St. Andrews High School. Actually that's a middle school and high school. Q. Any others? A. High schools? Q. Yeah. A. Actually it wasn't high school when I worked there. It was called Boca Academy which was way back. Q. Right. A. But I taught middle school boys there. Now it's the Pinecrest School in Boca. Q. Was there ever a time at that you came to know a lady by the name of Jane I )c,c No. 4? A. Yes. Q. Okay. How did you come to know her? Page 8 1 are preserving it for the record if there is 2 any future issue with the court. It doesn't 3 mean that you don't have to answer the 4 question. 5 THE WITNESS: I was just — I didn't lmow 6 if there was an exchange that I had to wait. 7 MR. PIKE: So, if you understand my 8 question, then go ahead and answer it. 9 THE WITNESS: I'm sorry. Could you repeat 10 that? 11 BY MR. PIKE: 12 Q. Sure. Did she excel as a player between 13 14 MS. ARBOUR: Same objection. 15 MR. PIKE: do ahead. 16 THE WITNESS: She did well. She had a, 17 she was technically a good player and l think 18 she had probably nonnal ups and downs as a 19 player but she did well. 20 BY MR. PIKE: 21 Q. How would you describe her as a playa? 22 A. Technically sound. She always had a very good 23 fitness level. We gave fitness tests to the players 24 when they came in, and she always performed very highly 25 on those. She was a good — I mean, she was a good 3 Page 7 1 A. She played for one of the local club teams. 2 When I say local it means within the county. And I had 3 seen her la a few times and she had been interested in 4 so we recruited her to attend and play 5 soccer at 6 Q. Okay. What local club did she play for at 7 the time if you recall? 8 A. Palm Beach United. 9 10 play soccer for 11 Q. And what did Jane Doe No. 4 come to Ae.al And she 12 play 13 Q. What type of player was she during those 14 years? 15 MS. ARBOUR: Form. 16 BY MR. PIKE: 17 Q. Asa coach what type of player was she? 18 How would you describe her abilities? 19 A. Shc was a good player. 20 Q. Did she aced as a player from Ma to 21 OMNI 22 MS. ARBOUR: Form. 23 MR. PIKE: It's a legal objection. When 24 another lawyer says form, they don't like the 25 way that I am asking the question. So, they 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 9 player. I don't know that — it's a very open-ended question so I don't know specifically what you are asking. Q. You had an opportunity to coach her for approximately four years, correct? A. Yes. Q. And as a coach what I am asking you is how would you describe this specific player? I think you are going a good job: Technically sound, she had a high fitness level...ism her ability decree between MS. ARBOUR Form. THE WITNESS: In terms of technical ability? MR. PIKE: Yeah. 171E WITNESS: No. I mean, like I said, I think she had normal, what I would view as normal ups and downs. She had times where she played well and she had times where she struggled. There were different games or so forth. But overall I think she was a good player. I think she was coachable. I believe she was a good teammate that took instruction well. So, those are things that you would say you have a good player. 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051.9762934) Electronically signed by cynthla hopkins (601-051.9762934) cea14d6c-3516.4cec1-842b-e312de0822od EFTA00729387 Page 1,. 1 BY MR. PIKE: 2 Q. Was she on scholarship? 3 A. Yes. 4 Q. Olcay. What type of scholarship if you 5 recall? • 6 A. She was on an athletic scholarship. 7 Q. Was it a full scholarship or partial 8 scholarship? 9 A. Partial scholarship. 10 Q. Was it 50 percent or 75 percent ride or 11 some other sort of break-out? 12 MS. ARBOUR: Form. 13 THE WITNESS: It was a — I didn't do it 14 by percentage, and I can't remember the exact 15 percentage because I can't remember the exact 16 cost of the school and obviously the cost of 17 school increased each year. But her 18 scholarship was probably — it was in the 20's 19 in terms of thousands of dollars and costs 20 upwards of about 40, probably a little more 21 now. So, it was more than half. 22 BY MR. PIKE: 23 Q. And h larshi remain the same 24 throughout 25 A. Yes. And it increased which was a normal Page 12 1 case for those years it didn't. It was generally 2 the first week of November. 3 Q. Between the years Vital was Jane Doe 4 No. 4 in attendance regularly for practice between 5 August and let's say November? 6 MS. ARBOUR: FO1711 7 THE WITNESS: For the most part I think 8 so. I believe so. 9 BY MR. PIKE: 10 Q. That's your best recollection? 11 MS. ARBOUR: Form 12 THE WITNESS: Yeah. I mean, if she might 13 have missed a training or two, I would have to 14 think about it. But, I mean, generally she was 15 there. I mean there was, there was a time or 16 two, I think, during the freshman year. She 17 might have missed practice. 18 BY MR. PIKE: 19 Q. Was she one to repetitively miss practice? 20 A. No, not unless there was some reason, I would 21 assume. 22 Q. I see you brought some documents with you 23 today. Is that your stuff there? 24 A. No. 25 Q. Did you bring any documents with you ' 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 11 thing that I did with the players if it was possible and there was no other issues. Issues would be if the player was not going to school or they wore doing something they were not supposed to be, but they would normally get small increases as the school increased as well. Q. Did Jane Doe No.4 always get an increase from 2005 to 2009? A. I believe so. Q. Tell me when the season starts for the female soccer team at from =to A. The players report for pre-season generally in the middle of August. It changes from year to year depending on the NCA mandate for each year but it's generally about the middle of August. Could be a little first, first two weeks of August. Q. Okay. And from August until when? A. The season would conclude, usually the regular season concluded the end of October or the first week of November. And then if the team qualified for the conference tournament, there would be additional games. And if they qualified for the NCA tournament, which in this case we did not, that would be, it could potentially go all the way to December. But in this 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 Patin 14 I SEW? A. No, I did not Q. Did you review anything before your deposition? A. !did not Q. Did you speak with anybody before your deposition about your deposition? A. I did not. My wife. Sony, my wife I spoke with. . Q. And did anybody from Ms. Arbour's office call you to discuss your deposition? A. No. Q. Okay. When was the last time you have been in contact with Jane Doe No. 4? A. Probably about a year ago. Q. Okay. And how did you come in contact with her at that time? A. She called me. It was actuall this time. I had already left last right about as of So, I finished what would have been Jane Doe No. 4's senior year, and they had their athletic banquet around this time for all the sports. She had called me with just and the banquet and she just wanted some advice. kind of a question. She had a conflict with her studies PROSE COURT REPORTING AGENCY, INC. 4 (Pages 10 to 13) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkIns (601-051-976-2934) ceal4d6c-3510-44)(1-842b-s3f2de0822ed EFTA00729388 Page 14 1 .Q. What advice? 2 MS. ARBOUR: Form. 3 THE WITNESS: She had some final or some 4 work due for finals or research papers that she 5 was under pressure to finish. And she didn't 6 know if she could attend the banquet. She just 7 didn't know what she should do. 1 was not 8 involved in the banquet at the time, but 1 9 guess she just called just to ask my thoughts 10 on it. 11 BY MR. PIKE: 12 Q. Okay. Betwee actually let's take 13 them year-by-year. Ii how many times would you 14 see Jane Doe No. 4 during, for practice during the 15 August and November practice season? 16 A. When the players first report, when the 17 team — well, when the team first reports for practice 18 generally we would go twice a day because it's before 19 school, before the season starts. So, for August it's 20 usually about two teams a day. 21 Q. For how many days? 22 A. At least for the first seven to ten days. 23 Q. Okay. 24 A. Now, there might be and there certainly would 25 be times where we went once a day. There are some times Page 1 MS. ARBOUR: You're talking justIM? 2 MR. PIKE: Yes. 3 THE WITNESS: September it would be 4 . either — because our games start usually by 5 the end of August would be the games 6 competition dates. So if we had a competition. 7. we wouldn't have practice. So just to clarify, 8 we might have three days of practice, two 9 games, and then two days off. 10 MR. PIKE: Okay. 11 THE WITNESS: That was like it wouldn't 12 be abnormal. 13 BY MR. PIKE: • 14 Q. Would that be the same for October and 15 November? 16 A. Correct November until the first or second 17 week until the season concluded. 18 Q. And those same questions that I just asked 19 you and that you answered, would that also be the 20 same for the years MM. ' 21 A. More or less, yes. 22 Q. Based upon. experience in coaching 23 Jane Doe No. 4 in how would you describe her 24 personality? 25 A. I mean, she's, she's a good kid. She was ' 1 2 3 4 5 6 7 8 10 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 15 that we would have a day off. But without consulting the training calendar, I wouldn't know for sure which days those were. once school starts generally, which at was usually about the first week of September, give or take, although they did change . from that time, then generally we would train once a day. The NCA mandates that once you're in season in school, you have to have a day off. So, typically there is always one day off The other days would be training days or game days. Q. And when you say training days., I guess what I am trying to kind of narrow down is how many days would you, you know, give or take the days that you have off, see Jane Doe No. 4 for practice between August and November? MS. ARBOUR: Form. THE WITNESS: You're going to count half of August, September, October. I mean, possibly 60,70 days probably. BY MR. PIKE: Q. How many days a week is practice in August? A. Probably six. Q. Okay. Same question for September. 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 29 25 Page 17 friendly and she took the coaching well. And she was friends with ha teammates and she worked hard Q. Do you recall how she did in school wise? MS. ARBOUR: Form. THE WITNESS: She did well. I think she had some terms where she did okay and some terms where she did wry well. BY MR. ME: Q.. What do you mean by okay? A. I only, I only I daft remember her specific G.P.A.'s but normally at the end of each term We always got a list of the players that got a 4.0 or 3.5 or 3.0 or better and a lot of players were always at least a 3.5 or 3.0 or better. Sheaornetimes was in that list and sometimes she was below a 3.0. 1 don't remember which terms those were. T think she did better in her later seasons than her earlier seasons. Q. Was she always a varsity player? A. Yeah. There is no, that is no there is only one team at one intercollegiate team. There was no junior varsity team. Q. Was she a starting player? . A. She started most of I would say the majority of the time. • PROSE COURT REPORTING AGENCY,: INC. 1 moaSfazakja•RaddifiXerla=“1,114 .m*Ze..-1.3 5 (Pages 14 to 17) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkIns (601-051-9764934) cea14d6c-3516-4ced-S42b-e312de0822ed EFTA00729389 Page 18 1 Q. And when you say that, do you mean from 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. was, the seasons were-, 1 11. the fall o Q. U . A. There is a spring season but it's a different, kind of a different, a little bit of a different animal. It's a non-competitive season. Q. Between IIIIIIIIIII6 there ever a time that you coached Jane Doe No. 4 on the off-season? A. Well, like I said, we always had a spring season so typically in the in-state schools you have a competitive, which a competitive part of the season which soccer is the fall part. And then you have your non-competitive part where there is some different rules and regulations as to how often you can train, how much you can train, how many games you're allowed to play. So, the way we did it in the spring is typically the first month when the girls come back, we would do conditioning and weight training and you could do small group technical sessions. And then we would have a spring season. We would start around February 15th and go about the first week of April where we usually train three days a weelc. And we would have maybe a game on 1 2 3 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 . 25 Page 20 when she was, if — like most of the kids on the team,1 say most of the girls on the team, I think she worked hard because it VMS important to her, the soccer aspect was important to her. So, I always saw her as working hard. The school work was a little up and down for her but I think she improved that as it went along. As far as ambitious I think ambitious to be a good teammate and be a good person and be a good soccer player and being a good student; most of the time I would characterize that for her. BY MR. PIKE: Q. Was there ever • tin 'on saw Jar e Doe No. 4 unhappy in MS. ARBOUR: Form. THE WITNESS: Yeah. lean, lean, I can't — I am tying to remember a specific instance. I can remember a couple of instances where she seemed to be under pressure. I am just trying to think of the exact, the exact — MR. PIKE: Take your time. THE WITNESS: dates. There was one incident I can actually remember it was Page 19 1 weekends. And then once they were done in April, 2 usually we let them just prepare for finals and that 3 kind of thing. 4 Q. You said Jane Doe No. 4 was friendly, she 5 had, she was friendly with her teammates and that 6 she was coachable. Did you notice whether or not 7 Jane Doe No. 4 was a happy person? 8 . MS. ARBOUR: Form. 9 THE WITNESS: Most of the time I thought 10 she was a happy person. 11 BY MR PIKE: 12 Q. Did she ever confide in you about any. • 13 personal matters? 14. A. No. 15 Q. Never? 16 MS. ARBOUR: Form. 17 THE WITNESS: Not to my recollection. 18 • BY MR. PIKE: 19 Q. Okay. Would you describe Jane Doe No. 4 20 as a strong-willed person? 21 MS. ARBOUR: Form. 22 . MR. PIKE: Ambitious? 23 MS. ARBOUR: Form. 24 THE WITNESS: 'just — they are very 25 wide-open questions. I think she worked hard 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 21 probably during 2008 or 2009. It was kind of a freak thing. We were on a road trip and it was in the morning. We were staying in the Tampa area because we were playing one of the schools Tampa or St Leo, or probably one of those two schools because that would have been close by. We were staying at a Hampton Inn that we bad stayed at before. And our routine was we would have breakfast. We had a game probably at 4:00 or 5:00 that day. So we had breakfast. We had to check out of the hotel by 11:00. Our • game wasn't until 5. One of the teammates parents lived close by in Tampa, so we would basically go there and have lunch: So, we had kind of the house to hang out at before we went to the, go to the game. And there was — she had actually — something had happened with the lock in her bathroom and she got locked in the bathroom for about three hours. And the workers were there trying to figure out the lock. • They had to, they couldn't drill the lock out. They had to actually remove the door to get her out. So, she was really upset by it. I mean, I think I understand. And they were Mr. PROSE COURT REPORTING. AGENCY, 6 (Pages 18 to 21) INC.' Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) eeall4d6c.-3510-4ad-842b431264822od EFTA00729390 Page 2:: Page 24 1 all apologetic. The hotel was apologetic. 2 They comped the room. The lock mechanism had 3. just jammed and no keys would — they actually 4 had to take the hinges off the doors as 5 upset abouttliii that was I • 6 probably. Y 7 BY MR. PUCE: 8 Q. And you said there was one other instance. 9 A. There was probably one or two other instances 10 in five and/or six. 11 Q. 12 A. Yes. The fall where she 13 had — I think she had some personal matters going on 14 and she seemed to be under pressure I think. And this 15 is not unusual in terms of when people are having 16 troubles with different parts of their life. The soccer 17 for them becomes an outlet and that's just how things 18 are for different people. 19 So, think that she — and I am just 20 probably guessing here, but I think the soccer 21 helped her because it took her mind off whatever, at 22 least temporarily, off whatever was going on. There 23 was a time she had her family, she had to miss 24 practice and it was for family matters. And then I 25 know in the actually had to miss a couple games 1 to you between 2 MS. ARBOUR: Form. 3 THE WITNESS: No. 4 . BY MR. PIKE: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Was she upbeat between MS. ARBOUR Form. THE WITNESS: I mean, upbeat., I mean I think she had a — she's a logical person in terms — so that's, certainly, most of what I remember. But was she like that every day, every minute? I mean, no. No one is like that all the time. MR. PIKE: Understood. Understood. I am not asking for all the time. I am asking for, you being her coach, I was, I was a wrestler and I wrestled and I wrestled five days a week, three hours a day and I got to know my coach very well. So, these questions are, you know, related to your general understanding and your general perception as a coach for that time period relative to this. I am not asking for anything, someone who is always up-beat. I understand. But separate and apart from that, did you Page 23 1 because there was a family issue and I didn't delve 2 into the issue. I mean, I trusted that it was a, 3 that she was, it was a family matter that she was 4 dealing with. 5 Q. Asa player would she be required to fill 6 out a request for excuse, for excusal from any 7 practice or game? A. No. I mean those would just be done on a, on 9 an individual basis with any player. 10 Q Face-to-face with you being the catch? 11 A. Correct 12 Q. Would you take down any records for the 13 NCAA in that regard? 14 A. NCA, no. 15 Q. So, the procedure would be just a common 16 procedure. If a player was having a personal issue 17 they would come to you and say, coach, I am not • 18 going to be able to be here; l have a family issue. 19 I don't want to delve into it, but that's what it 20 is. 21 MS. ARBOUR: Form. 22 THE WITNESS: I don't know if I would put 23 it exactly that way but that's the gist. 24 BY MR. PIKE: 25 Q. Has Jane Doe No. 4 ever seemed depressed 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 25 ever see any personality changes in Jane Doe No. 4 &DM WM. MS. ARBOUR: Form. THE WITNESS: Nothing, nothing, nothing in terms of, nothing drastic. As there are times that you can recall players maybe having a bad day or just there are other things on their mind, sure. But as far as a drastic personality change, no. BY MR. PIKE: Q. Did Jane Doe No. 4 exhibit any behavioral or health issues to your knowledge between '05 and '08? MS. ARBOUR: Form. THE WITNESS: Nothing. I think that was outside the context of playing like an injury. BY MR. PIKE: Q. Do you know anything about Jane Doe No. 4 health? And when I say health I mean mental health? MS. ARBOUR: At any time? MR. PIKE: Between la THE WITNESS: Do I know anything? MR. PIKE: Yeah. THE WITNESS: Yeah. PROSE COURT REPORTING AGENCY, 7 (Pages 22 to 25) INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-9764934) coal 4d6c-3516.4ced.842b-e3t2cle0822ed EFTA00729391 Page 26 Page 28 1 BY MR. PIKE: 3. Epstein prior to today? 2 Q. Do you know whether Of not Jane Doe No. 4 2 A. Yes. 3 was seeing a psychologist, psychiatrist or social 3 Q. How have you heard that name? 4 worker or any cotunelor between 4 A. It's in the papers. 5 MS. ARBOUR.: Form. 5 4 Okay. And what have you read? 6 . THE WITNESS: I do not recall that, no. 6 A. That he is a wealthy guy that's got in trouble 7 BY MR. PIKE: 7 for some stuff he should not be doing. Something about 8 4 Okay. Do you know whether or not Jane Doe 8 paying girls for massages. 9 No. 4 had any problems with drugs or alcohol between 9 Q. Did you ever come to learn that Jane Doe 10 '05 and '08? 10 No. 4 flied a lawsuit against Jeffrey Epstein? 11 MS. ARBOUR: Form. 11 A. No. 12 THE WITNESS: No. 12 Q. So, when you were reading those articles 13 13 you had no idea that Jane Doe No. 4 filed a lawsuit BY MR. PIKE: 14 Q. Do you know where Jane Doe No. 4 worked at 14 against Mr. Epstein? 15 anyplace of employment between an? 15 MS. ARBOUR: Form. 16 MS. ARBOUR: Form 16 THE WITNESS: No. 17 THE WITNESS: No. 17 BY MR. PIKE: 18 BY MR. PIKE: 18 Q. But for my having told you that today, 19 Q. You have no idea where she was employed 19 have you ever heard of lane Doe No. 4 being involved 20 during those years? 20 with a gentleman by the name ofJeffrey Epstein? 21 MS. ARBOUR: Form. Asked and answered. 21 A. No. 22 MR. PIKE: You can answer. 22 Q. Based upon your interactions with Jane Doe 23 THE WITNESS: I don't think, !mean I 23 No. 4 between '05 and '08, would you describe her as 24 didn't necessarily know where they worked. I 24 angry, bitter, disliking herself or depressed? 25 am trying to think if I recall if she did work. 25 MS. ARBOUR: Form. Page 27 Page 29 1 I mean, it's not a question that I would 1 THE WITNESS: No. 2 normally know because if it didn't conflict 2 BY MR. PIKE: 3 with ha studios or her school or her soccer, 3 Q. Are you familiar with any medical history 4 then it wouldn't be something that would 4 relative to Jane Doe No. 4? 5 normally come up. Wait. She did work at Pine 5 MS. ARBOUR: Form. 6 Tree Camps one summer. 6 MR. PIKE: Well, do you want me to go into 7 BY MR. PIKE: 7 it? 8 Q. And is that a soccer camp? 8 MS. ARBOUR: Well, you already asked him. 9 A. Well, has a summer camp that 9 MR. PIKE: If you withdraw the form, I am 10 they, that it's kind of auxiliary for the school for 10 going to let him ask I am trying to be nice 11 most of the younger kids. So, it's not a soccer camp 11 here. 12 it's just a camp. So, she worked as a counselor there. 12 MS. ARBOUR: Okay. I appreciate that. 1 13 Certainly, I think between either before the season so 13 noticed. 14 it would have been the summer of 2008, 2007 and/or 2008. 14 MR. PIKE: I am going to ask the question 15 I can't recall for sure if it was both or just one. 15 one more time. . 16 Q. Do you know whether or not Jane Doe Na 4 16. THE WITNESS: 'have a comment. Cm ahead. 17 had a boyfriend named Illia , 17 This is before that. Can I go back? 18 A. No. 18 MR. PIKE: Sure. 19 Q. Had you ever met any of Jane Doe No. 4's 19 THE WITNESS: Only because I am thinking 20 boyfriends between illEallia 20 about the relationship with Epstein. 21 A. No. 21 MR. PIKE: Understood. 22 Q. Have you ever met any of Jane Doe No. 4's 22 TIE WITNESS: o miss a game 23 boyfriends at any time that you're aware of? 23 because of a family matter in Al t and it was a 24 A. No. 24 legal issue that she said it was a family 25 Q. Have you over heard the name Jeffrey 25 issue, a legal issue. So, I asked her for the 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (801-051-97(4-2934) ceatild6c-3516-4catl-842b-e3f2da0822ed EFTA00729392 Page 30 1 paper just so I had something and she handed me 2 a sheet of paper that had like a case on it. 3 BY MR. PIKE: 4 Q. Do you remember what it said? 5 A. It was a — it WaS a, it wasn't like a — it 6 wasn't like a subpoena. Was it a subpoena? I just 7 remember. I remember it was a legal issue. Her name 8 was on it. There was a few other names as Defendants. 9 So I took it as legitimate. It was Palm Beach, 10 whatever. And I just, you 'mow, so that was kind of I 11 wanted to make sure that there was — you asked about 12 permission so we didn't do a permission slip. 13 Q. Understood. 14 A. If you were going to miss for a reason and 15 this was something that I could file, I wasn't going to 16 question it any further. 17 Q. To your recollection was her name on that 18 paper as a Defendant? 19 A. No. It wasn't a Defendant. It wasn't as a 20 Defendant, but I am trying to remember if it was, if the 21 name Epstein was on the paper. 22 Q. As you sit here today do you recall 23 whether or not Epstein's name was on that paper? 24 A I don't loww. It may have beat. 25 Q. Do you know for certain? 1 =MP 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 32 A. No. Q. Okay. Did Jane Doe No. 4 • he soccer team for any reason during ? A. No. Q. Okay. Was she a committed player to the and to her teammates between.. and MS. ARBOUR: Fonn. THE WITNESS: I think so, yes. BY MR. PIKE: Q. Did it ever seem like school and sports were too much for Jane Doe No.4 to handle in tandem? MS. ARBOUR: Form. THE WITNESS: I don't think so. I only would just refer-- BY MR. PIKE: Q. Let me rephrase the question. Based upon your experience and involvement with Jane Doe No. 4 as her coach between '05 and '08, did it ever seem to you that school and sports were too much for Jane Doe No. 4 to handle in tandem? A. No. MR. PIKE: I have no further questions. Page 31 1 A. I don't remember. 2 Q. So, as you sit here today you don't 3 recall? 4 A. I guess that's the safest. That's the safest 5 answer, yes. 6 Q. Okay. Did Jane Doe No. 4 ever dieross her 7 medical history with you in any context? 8 A. Not that I recall. 9 Q. Okay. Did Jane Doe No. 4 ever have to 10 fill out any papers for relative to 11 her position as a soccer player delineating her 12 medical history to your knowledge? 13 A. When the players enter for the fist time 14 before their fieshtnan year, they have to do a bunch of 15 forms that go to ow athletic trainer that include a 16 physical and a participation medical history farm. So, 17 our athletic training staff at M, athletic training 18 staff gets those forms. 19 Q. Did Jane Doe No. 4 ever have to be excused 20 from practice for any sort of surgical procedure, if 21 you recall? I don't want you to guess. 22 A. I don't recall. If then is something 23 specific, lean% I moan, fatal recall. 24 Q. Are you aware of any surgical procedures 25 that Jane Doe No.4 underwent betw en the rots • Page 33 1 MS. ARBOUR: Okay. I just have a couple 2 quick ones. 3 MIL PIKE: She's quick. 4 MS. ARBOUR: And I talk fast 5 CROSS (ROCKY ORBZZOLI) 6 BY MS. ARBOUR: 7 Q. Okay. Outside of soccer practice and 8 soccer games, how often did you interact with Jane 9 Doe No. 4 between 10 A. Not that much. In the recruiting process 11 which would be during, would be.during the junior and 12 senior year, you do have probably interaction whore you 13 call them once a week. It's kind of hike a check-in, 14 call kind of stuff. Once in school, after preseason you 15 see them all the time, I feel like, because they are the 16 only ones on campus. But aside from maybe individual 17 meetings that might take place once in the fall and once 18 in the spring and just occasionally seeing them on 19 campus, you know, not, not that often at a practice. 20 Sometimes but not, not that often. 21 Q. Okay. So, outside of soccer would it be 22 fair to say you didn't have a social relationship 23 with Jane Doe No. 4? 24 A. That's fair. 25 Q. Okay. naIwta seasons PROSE COURT REPORTING AGENCY, INC. 9 (Pages 30 to 33) Electronically signed by cynthia hook ins (601-051-976-2934) Electronically signed by cynthia hopkIns (601-051.976-2934) cea14d6c-3516-4ced-842b-e3f2de0822od EFTA00729393 Page 34 1 what were the consequences, if any, for missing • 2 practice repeatedly? 3 A. Well, 1 mean, if you missed an unexcused 4 practice, I mean 1 guess if you miss repeatedly, the end 5 result would be removal from the team and tosser 6 scholarship. 7 Q. Okay. 8 A I guess if that's — obviously, there would be 9 kind of steps to get to that point, but that would be 10 the end result. 11 Q. Okay. So, if there was a pattern of 12 missing practices, there would be consequences for 13 that? 14 A. Yeah, absolutely. 15 Q. Okay. Did someone tell you before today 16 that you were here to give a deposition of Jane Doe 17 No. 4? 18 A. Yes, the -- 19 Q. Paralegal? 20 A. No. The thing that I had had her name on it, 21 so I could only assume that. And then when I spoke to 22 Jessica, she only explained that because it just said 23 Jane Doe No. 4 versus John Doe or something like that. 24 So, so, she just explained that they were representing 25 the Defendant and they wanted the deposition. Page 36 1 MIL PIKE: FORM 2 THE WITNESS: I guess, 3 BY MS. ARBOUR: 4 Q. The family matt= that Jane Doe No. 4 5 missed practice for ina— you said she missed a 6 practice and a couple of games; is that right? 7 A. Yeah. she missed her — I only I ober 8 that because it was actually a trip where we were away. 9 So, it was the opening games of owl iteason. We 10 were flying to Charlotte and she had this court date was 11 on the Friday, and I think we were leaving Wednesday or 12 Thursday. 13 So, she couldn't goon the trip which is a 14 pretty big deal that you can't go on the trip. So 15 that's why I asked for the, just the sheet of paper. 16 And you know, once I saw it, 1 just said okay. And 17 that was after the fact actually. 18 Q. Do you recall if that paper referred to a 19 federal grand jury? 20 A. 1 don't recall. 21 Q. Okay. The family matters that she missy, 22 a practice for as well, did you ever inquire what 23 that was about? 24 A. Later in 25 Q. Yes. Page 35 1 And there is a contact between to — 2 because there was a -- originally they thought I 3 lived in Brovrard County. So, it was originally 4 going to be down there, and it had to be changed. 5 So all I knew was basically that obviously I would 6 be talking about Jane Doe No. 4 because that was the 7 only person I knew on the list. 8 Q. Okay. And was that conversation you said 9 Jessica, was that Jessica Cadwell here at Mr. Pike's 10 office? 11 A. Yes, I'm sorry. 12 Q. Yoh said Jane Doc No. 4's name was on the 13 subpoena that you received? 14 A. Yes. 15 Q. And did anyone from Mr. Pike's office tell 16 you who the Defendant was? 17 A. No. 18 Q. Okay. Is today the first day that there 19 is any suggestion that Jane Doe No. 4 is suing 20 Jeffrey Epstein? 21 A. Yes. 22 Q. Okay. Is today the first suggestion 23 that's been made to you that Jane Doe No. 4 was, I 24 think Mr. Pikes words were involved with Jeffrey 25 Epstein? Page 37 1 A. Later in =I did not inquire. Well,1 mean 2 I inquired to the point where, you know, if she needed 3 to tell me something or if she needed help with anything 4 that she just said it was a personal family matter and I 5 didn't press it any further. 6 MS. ARBOUR: Okay. That's all I have. .7 KR. PIKE: I will order. 8 MS. ARBOUR: Do you want to explain read 9 or waive to him? 10 MR. PIKE: You have an opportunity to read 11 your deposition or waive your deposition. What 12 that means is you can read it. The eclat 13 reporter will send it to you and if you feel 14 like you have been, if you feel like you need 15 to make any corrections to the deposition. 16 There is an errata sheet provided on the back. 17 Ifs just a blank sheet with lines through 18 it, and you can correct your deposition or you 19 can waive that right today if everything you 20 feel was honest here today that you don't need 21 to make any corrections you can waive that 22 right and the deposition will be transcribed 23 and produced based on your spoken word here 24 today. 25 TIIE WITNESS: I think, I think we're good. ••••••14-, • I 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934( coa14d6c-3516 4cod 842b cat2de0822ed EFTA00729394 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 38 MS. ARBOUR: You will waive? ME WITNESS: I will waive. MS. ARBOUR: Okay. I will just a take a mini or an electronic. (Witness excused.) (Deposition was concluded.) 1 2 3 6 7 8 9 10 11 13 11 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE STATE OF FLORIDA COUNTY OF PA114 BEACH I, Ofielhis llopacin Rosin Pm(essissi Repotter.flexida Profeetimul Reporter, end Noisy Fa in affix the Suit of Florida at Lame, dn barby unify that the aforemasioned witness was by me tins duly sawn lo testify die whole UM: that I van authoeseml wand did (rpm said 641420linn m stenot)Fc and that the foresonsg pants minimise ed Ito 40, •15 a hue and correct tratteriscim of my shentamd notes of said dmk • I far rattly Clot said &position was talus a the time and rim ~Ism set kith and that the taking of stet deposition was commenced and completed at lestoinehow set out. I timber ecnify that 1 am not ancency or monad elms of the pan inh nor an I te retain: ce employee of any anesney cc counsel of party contested with the action. ore or 1 entoretted e its *ton. ibe foregoing: certification of lien tentmenpl does not assly to any it:prods:lion of this son e by any mews ankra wake the direct cannot and/or directima of the cenifyinc repartee. Dated this 12th My of /day, 2010. Sd kilt) AS Ojendeis Hans, RPR TER kb 01939 Page 40 1 2 3 4 5 7 8 9 10 11 12 13 14 15 Cynthia Hopkins, RPR, FPR 16 Notary Public - State of Florida My Commission Expires: February 25, 2011 17 My Commission No.: DD 643788 18 19 Job /1939 20 21 22 23 24 25 Page 39 CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that ROCKY OREZZOLIpersonally appeared before me and was duly sworn. Dated this 12th day of May, 2010. ereuts 4muAs e•h•C- -f5-+ ,Fe-n»t4~ j 11 (Pages 38 to 40) PROSE COURT REPORTING 'AGENCY, INC. . Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-9762934) COalrldec-3516-4ced-842b-e312de0822ed EFTA00729395