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Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME I OF II Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JANE DOE NO. 5 Friday, February 26, 2010 8:07 - 3:44 III. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1312 PROSE COURT REPORTING AGENCY, INC. EFTA01076383 EFTA01076384 Page 2 Page 4 APPEARANCES: On behalf of the Plaintiff: 3 STUART S. MERMELSTELN, ES laRMELSTEEN & HOROWITZ, M. 18205 Biscayne Boulevard Suite 2218 Miami Phone: 6 E-mail: 7 On behalf o the en t: 3 ROBERT D.CRJTTON,JR,ESQUIRE MARK T. LUTHER. ESQUIRE 9 BURMAN, CRITTON, LUTHER & COLEMAN, UP 303 Banyan Boulevard Suite 400 West P • • ride 33401 31 Phone: 12 13 14 ALSO PRESENT: 15 16 17 18 19 20 21 22 23 24 25 &eche Quimby, Videographer Visual Evidence, Incorporated 2 3 4 5 6 7 8, 9 10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 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. THE VIDEOGRAPHER: This is the 26th day of February, 2010. The time is 829E. This is the videotape deposition of Jane Doe No. 5 in the matter of Jane Doe No. 2 versus Epstein. This deposition is being held at 250 Australian Avenue South, West Palm Beach, Florida. My name is Sascha Quimby. I'm the videographer representing Visual Evidence, Inc. Will the attorneys please announce their appearances for the record. MR. MERMELSTEIN: Stuart Mermelstein for Plaintiff Jane Doe No. 5. MR. LUTTIER: Mark Luther for Jeffrey Epstein. MR. CRITTON: Bob Critton for Jeffrey Epstein. 1. 5 7 3 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 3 INDEX EXAMINATION DIRECT CROSS REDIRECT JANE DOE NO. 5 BY MR. CRITTON 5 NO EXHIBITS MARKED Pag 1 Thereupon, 2 • (JANE DOE NO. 5) 3 having been first duly sworn or affirmed, was 4 examined and testified as follows: 5 THE WITNESS: Yes, I do. 6 DIRECT EXAMINATION 7 BY MR. LUTTIER: 8 Q. Good morning, ma'am. My name is 9 Mark Luttier, and we're here today for purposes of 10 taking your deposition. Could you tell us your full 11 name. 12 A. Jane Doe No. 5. 13 Q. And how do you spell your middle name? 14 A. (Witness spells her middle name.) 15 Q. Okay. Ms. Doe No. 5, have you ever been 16 deposed before? 17 A. No. 18 Q. That's this process that we're doing here 19 today. 20 A. No. 21 Q. Okay. And let me explain a little bit 22 about the process. First of all, you understand 23 you're under oath? 24 A. Yes. 25 Q. Okiy. I'mxing to ask you uestions, and 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. EFTA01076385 Page 6 1 you're going to have to give a verbal response 2 because this court reporter is going to transcribe 3 everything that you say. 4 A. Okay. 5 Q. So you can't shake your head and you've to 6 to actually say a word so she can get it down. 7 A. Okay. 8 Q. If you don't understand a question that I 9 ask, tell me you don't understand it and I will 10 explain it for you. 11 A. Okay. 12 Q. Okay. If you answer a question, I will 13 assume you understood it. 14 A. Okay. 15 Q. Okay. If during the deposition you want 16 to take a break, just let me know, and I'll be happy 17 to accommodate you. 18 A. Okay. 19 Q. If during the deposition you think that a 20 previous response that you gave me needs to be 21 amended or changed in any way, just tell me, you 22 know, I just thought of something. I need to go 23 back and correct something or supplement, whatever 24 you think has to happen. Okay? 25 A Okay. 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 A. 1 don't have an accurate date. Q. Well, approximately. A. It was before I started school. Q. And when you say "started school," what do you mean? A. Started cosmetology school. I just finished. Q. And what cosmetology school are you referri A. Q. And when did you start that? A. Last February. Q. That would be February 2009? A. Yes. Q. So sometime prior to 2009 a psychiatrist in Florida who prescribe for you? A. No. My recent visit to was in Florida. I was in Virgina at the time before I went to Ill id Virginia that's where I got my first prescription of e n Q. Okay. Who ysiclan who on you? Would it be a Dr A. It, l'm not sure, because I was seeing a psychologist and a psychiatrist, so I wouldn't know. I Page 7 1 Q. Are you presently under any kind of 1 2 medication? 2 3 A. No. 3 4 Q. In the last six months have you been under 4 5 any medication? S 6 A. Yes. 6 7 Q. What medication have you been under in the 7 8 last six — 8 9 A. . 9 10 Q. — months? 10 11 AL =B. That's it. 11 12 Q. And what's the level of= that is 12 13 prescribed for you? 13 14 A. Twenty and then it went up e. 14 15 Q. Okay. Most recently it was milligrams? 15 16 A. Yes. 16 17 Q. And how fte ; you prescribed to take 17 18 .-milligrams of ab er 18 19 A. I took it once a day, once in the morning. 19 20 Q. And who prescribed that drug? 20 21 A . It was a new doctor in Florida. I do not 21 22 recall the name. 22 • 23 Q. Was, what kind of doctor was it? 23 24 A. Psychiatrist. 24 25 Q. And when was it first prescribed fiat. you? .25 . „ Page 9 can't put a name to the face of who it was. Q. This is, you were seeing a psychologist and a psychiatrist? A. In Virginia. Q. Okay. What psychologist were you seeing? A. I don't remember. Q. And when was it you were seeing this psychologist and psychiatrist in Virginia? A. Around the same time before I started school in Virginia. Q. So were you seeing than in January of '09? A. Yes. Q. I want to refer to — I'm going to read to you your answers to interrogatories that you gave in this case which were dated by you January 26th, '09. Interrogatory 12 asks you to list all the physicians — A. Uh-huh. Q. — that you had been to. I'm going to show that list to you. A. Okay. Q. You see Interrogatory 12 there? You don't mind my hand, my highlighting. And I think there's one name on the next page. A. Okay. 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. EFTA01076386 Page 10 1 Q. So, can you tell me which of these people 2 is the psychologist that you were seeing in 3 Virginia? 4 A. I don't think ifs listed. 5 Q. Can you tell me which of those physicians 6 is the psychiatrist that you were seeing in 7 Virginia? A. I think it's this one, 9 Q. Read the, the name. 10 A. 11 Q. 111111..,ame? 12 A. It doesn't say. I don't know. 13 Q. Well, how long did you see this 14 psychiatrist? 15 A. I saw her — I had two visits. I'm guessing. 16 That's not 100 percent accurate. 17 Q. Okay. 18 A. That was just — 19 Q. Okay. Would you pass me those 21 interrogatories so I can see if you have a date 21 here. All right. In answer to 8 you said that — 22 what you answered was, in response to an 23 interrogatory that asked you to list all of the 24 physicians and medical facilities or other health 25 care providers including psychiatrists, Page 12 1 right? 2 MR. MERMELSTEIN: Objection to form. 3 THE WITNESS: I, I don't, I don't 4 remember, honestly. 5 BY MR. LUTHER: 6 Q. Okay. Well, let me ask you this: Do you 7 have a, an absolute specific recollection that you 8 did, in fact, see a psychiatrist -- 9 A. Yes. 10 Q. — and psychologist in Virginia? 11 A. Yes, yes. I just don't remember. 12 Q. And the psychologist that you saw in 13 Virginia was male or female? 14 A. Psychologist Was it -- they were both 15 females. 16 Q. Okay. Do you know the difference do 17 you know there's a difference between a psychologist 18 and a psychiatrist? 19 A. Yes. 20 Q. Okay. I'm now asking you about the 21 psychologist 22 A. Okay. 23 Q. There was a female psychologist. 24 A. Uh-hub. 25 Q. And do you remember her name? Page 11 1 psychologists, mental health counselor, et cetera, 2 that you had been treated for in the last ten years. In Number 8, you list and you give a PO Box. And the interrogatory tells you to state, as to each the 6 dates of the examination and the condition or injury 7 for which you were examined. And what you put was 8 December 2007, dermatitis. 9 Now, you understand dermatitis is a 10 skin condition? 11 A. Oka Well then I must be confused because 12 I did have 14 Q. Okay. So now you're saying 8 is not the 15 psychiatrist that you saw in Virginia? 16 A. No, no. 17 Q. So, in answering your interrogatories, you 18 have — you did not give us either the name of the 19 psychologist or the psychiatrist who treated you in 20 Virginia? 21 A. I guess not. No, I guess not. 22 Q. Pm not, I'm not quibbling with you over 23 words, but when, when we hear the word "guess," you 24 know, it makes us a little nervous. So, when you 25 say you guess riot, you definitively know you didn't, 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 13 A. No. Q. Do you remember her first name, her last name, any combination of the two? A. No, I don't Q. Do you have any records from which you can determine that name? A. At home. Q. Home, meaning what, here in Palm Beach County? A. Home in Virginia. Q. Okay. Do you have -- in your wallet, for example, do you have a card from, from this person? A. I could look if you would like me to. Q. Yeah, that would help us, if you would, please. MR. WrITER: And, Stuart, I invite you, if you know the answers to this, I invite you to go ahead and chime in. MR. MERMELSTEIN: Well — MR. LUTTlER: I'm not looking — l'm looking to get to the answer. MR. MERMELSTEIN: I know she, she — this whose name you mentioned is in response lt.revious Interrogatory Number II. MR. LUTT/ER: And I don't think that's a 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. EFTA01076387 Page 14 Page 16 1 psychologist. 2 MR. MERMELSTEIN: That's a psychiatrist. 3 MR. LIMIER: I don't think it's a 4 psychiatrist. 5 MR. MERMELSTEIN: It's an I., right? 6 That would be a psychiatrist. 7 MR. LUTTIER: Okay. That would be, you 8 know, from the record that I'm looking at — 9 okay. We'll get to that. 10 MR. MERMELSTEIN: So, yeah, I don't know 11 if that's the psychiatrist that she's referring 12 to or not. 13 THE WITNESS: No, not on me. 14 BY MR. LUTTER: 15 Q. Okay. Do you have a cellphone that lists 16 the phone number? Do you have a phone number? 17 A. I have a cellphone. 18 Q. But do you keep her phone number in there? 19 A. Well, since my husband's in the military, I go 4 back and forth from Florida to Virginia a lot, and 21 that's why I have to change constantly 'cause if he goes 22 on deployment, I come to Florida. So that's the problem 23 right now. That's why I don't remember. 24 Q. I think you're checking your cellphone to 25 see if you have the phone number there? 1 give you the original back, and that way it 2 won't be on the record. We'll just make a copy 3 so ifs not in the court file. 4 BY MR. LUTTIER: 5 Q. Okay. All right. So, let me go back. 6 The — we were talking about the female psychologist 7 in Virginia. You don't {mow her name or number. Do 8 you recall when you first went to see this 9 psychologist? 10 A. I went with my husband. No. 11 Q. Okay. You, You recall that your first 12 visit with her was one in which your husband went 13 with you? 14 A. Yes. 15 Q. Okay. Obviously, you were in Virginia at 16 the time. Did, did you go to this psychologist 17 shortly after you moved to Virginia? What I'm 18 looking for now is maybe the year. 19 A. Let me think I don't know. I can, l can 21 approximate it I just — 21 Q. What's, what, what's your best estimate of 22 when you moved to Virginia? 23 A. When I moved to Virginia was 2006, 2007. 24 Q. Okay. And when you moved to Virginia in 25 2006, what time of the year was it? 1 2 3 4 5 6 1 9 0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ,25 Page 15 A. Yes. I have a doctor in my phone. I don't know if it's the one that I saw here, while my husband was on deployment, for my I can give you the number. Q A. Ifs Q. Do you have a name associated with it? A. No. Q. You just have a — A. I just have it under my doctor. I can get all this information from my insurance company - Q. Okay. A. or my health care. Q. Yeah. What, what insurance company is that? A a. Q. Okay. Do you have the card — A. Yes. Q. —that will give us the number? Is that the military insurance? A. Yes, Prime. MR. LIMITER: Okay. Do you have a way to make a copy? THE COURT REPORTER: Yes. MR. LUTTIER: Okay. We're, we're going to 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 21 21 22 23 24 25 Page 17 A. I moved there in January of, January of 2007. Q. January of 2007. A. Yes, because I got married in — yeah. Q. You got married when? A. December 2006. Q. Okay. So you know you went to Virginia shortly after your wedding? A. Yes. Q. Were you married down here min Virginia? A. Down here. Q. In Palm Beach County? A. Yes. Q. Okay. A. No, Broward County. I'm sorry. Q. Okay. All right. Approximately how long was it after you moved to Virginia that you first went to this female psychologist? A. Probably, Pm guessing, five to six months. Q. Okay. A. It's not accurate. Q. And, and why were you and your husband -- why did you and your husband go to this psychologist? A. Marital problems. Q. And specifically what were the marital 5 (Pages 14 to 1 7) PROSE COURT REPORTING AGENCY, INC. EFTA01076388 Page 18 1 problems? 2 A. Fighting. 3 Q. And how many visits did you, did either 4 you alone or you and your husband have with the 5 psychologist? 6 A. Two to three. 7 Q. And were there were those visits with 8 some degree of regularity? For example, you went 9 once a week for a month, or you went for once a 10 month for two months, or... 11 A. I think it was once a month. 12 Q. Okay. So there would be approximately a 13 three-month period - 14 A. Yes. 15 Q. — over which there would be about three 16 visits? 17 A. That's not accurate, so I'm just saying. 18 Q. If you know it's not, what's your most 19 accurate recollection of how many visits you had? 20 MR. MERMELSIEIN: Objection to form. 21 THE WITNESS: I mean we went three 22 times — I don't know. 23 BY MR. LIMIER: 24 Q. You were about to say you went three 25 times, what? Page 20 1 Q. Okay. And each of those visits was about 2 marital problems with your husband? 3 A. When he came, yes. When he was present at the 4 doctor's office with me? 5 Q. Right. 6 A. It was about us. 7 Q. Okay. How about on the — you say you 8 went one time alone. 9 A. Yes. 10 Q. What was that visit about? 11 A. Me and my personal life. 12 Q. And specifically wises about you and your 13 personal life? 14 A. Things I've been through. 15 Q. Okay. For what, what was your primers 16 complaint or purpose for you going alone on that 17 visit to the psychologist? 18 A. That I was depressed. 19 Q. So, the, the, the thing that caused you to 20 go to her alone was because you felt that you were 21 depressed? 22 A. Yeah. 23 Q. And what is it that you specifically 24 discussed with her about your personal life? 25 A. It was about my husband, it was about family, Page 19 1 A. I don't lcnow. rut not going to give an answer 2 when I'm not 100 percent sure of how many times I 3 vvent 4 Q. I want your -- 5 A. - or how many, how many — like a time frame. 6 Q. Well, I, I don't want you to just pick a 7 number out of the sky, but I want your best 8 estimate. I mean, if I had these, if I'd have had 9 this doctor's name, I would have subpoenaed the 10 records and rd know exactly, but I am trying to 11 find out who this doctor is which is why we sent the 12 interrogatories. 13 A. I'm going to say over three months. 14 Q. Okay. So your best estimate is — 15 A. My best estimate. 16 Q. 'That's fine. And on each visit that you 17 went to this psychologist, was it you and your 18 husband? 19 A. I think there was, !went one time alone. 20 Q. In addition to the three with your 21 husband? 22 A. Uh-huh. 23 Q. So you maybe had — your best estimate is 24 four visits, correct? 25 A. Three to four. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 5 16 17 18 19 21 22 23 24 25 Page 21 Jeffrey Epstein was mentioned Q. And how do you recall that Jeffrey Epstein was mentioned? A. What do you mean? Q. What is it that makes you recall that you know that Jeffrey Epstein's name was mentioned? A. Because I remember mentioning it to her, all the things I went through in my life. Q. Okay. Anything else that you recall? A. Just about my, my past — Q. All right. A. — you know. Q. And this was a 45-minute visit? A. Yeah. I'm pretty sure. Q. Did you ever go back to her after the visit that you went alone? A. I think, yeah, after I went to her alone, my husband and I went one more time after that. Q. But the visit that you and your husband had was about your marital difficulties. A. Yes. Q. And then after that last visit between you and your husband and her, you didn't go back? A. No. Q. So, somewhere in the ear 2007 tut 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. EFTA01076389 Page 22 Page 24 going to her? 2 A. Yeah. 3 Q. All right. 4 A. I would say. 5 Q. Do you recall where this doctofs office 6 was located? 7 A. No. Q. I mean, do you — I don't !mow, was it in 9 the same town that you were living in in Virginia? 10 A. No, it was a different area because I remember 11 it was a little bit of a drive. 12 Q. When you say "a different area," what city 13 was it in? 14 A. I don't remember. 15 Q. Well, how long did you live in this area 16 of Virginia? 17 A. I lived there two years, around two years. 18 Q. Okay. And I assume in that two-year 19 period you became familiar with the municipalities 20 and the cities that were located in your immediate 21 vicinity. 22 A. No. I am horrible with direction. 23 Q. Okay. Do you have, do you have any notes 24 or anything from, that your visits with this 25 psychologist 1 Q. Well, these were 45-minute sessions, 2 right? 3 A. Yeah, but I didn't know anybody in Virginia. 4 It wasn't hike I had a babysitter. 5 Q. Well, in the two years that you lived in 6 Virginia, would it be a correct statement that there 7 were times that, that you left your daughter with 8 somebody else while you did things? 9 A. No, I took my daughter. 10 Q. When you went, when you went the one time 11 to the psychologist did you take your daughter with 12 you? 13 A. Yeah, I did. 14 Q. Okay. Because your daughter at that time 15 was less than a year old, right? 16 A. Yeah, she was young. 17 Q. All right. So having your daughter didn't 18 prevent you from going to a psychologist? 19 A. No. I mean, no, but it was too hard. 20 Q. Well, you, you went the one time, you took 21 her with you. 22 A. It was still hard. 23 Q. And I assume that at age less than one she 24 slept a fair amount of time? 25 A. Uh-huh Page 23 1 A. I don't have any. Personally, I don't, I 2 didn't take any notes. 3 Q. Okay. Did the psychologist have any tasks 4 that she asked you to do? Like, sometimes a 5 psychologist will say, you know, write something out 6 or something like that. 7 A. No. 8 Q. So you have no documentary materials at 9 all concerning your visits with this psychologist? 10 A. No. 11 Q. Is there any record — other than your 12 insurance company which I assume paid for part of 13 this psychology visit. 14 A. Paid for all of it 15 Q. Paid for all of it. Is that — do you 16 have any other record from which you can determine 17 who this psychologist was? 18 A. No. 19 Q. Did the psychologist at your last meeting 20 advise that she didn't want to see you anymore and 21 that your sessions were done? 22 A. No, I just didn't go back. 23 Q. Okay. Why, why didn't you go back? 24 A. Because I have a two-year-old daughter, and 25 it's just hard for me to take the time to go. 3 4 5 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 25 1 Q. That is your daughter -- 2 A. — she did, but she also had colic, so it was not easy. Q. Okay. But you'd done it once before. The doctor, for example, didn't say, you don't come here 6 with your daughter? A. No. Q. The doctor didn't say, I don't want to see you anymore? A. No. Q. You made the decision you weren't going to go back? A. Yeah. Q. Okay. And your testimony is that in a two-year period that you lived in Virginia, you never left your daughter with anybody else? MR. ME RMELSTF_1N: Objection to form. THE WITNESS: If you mean my mother-in-law that came up and watched her from — BY MR. LUTTIER: Q. I mean anybody. A. Yeah. Q. Yeah what? A. Yes, my mother-in-law came to Virginia to stay a couple of times from Florida. 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. . EFTA01076390 Page 26 1 Q. Okay. 2 A. So when she was there, she would watch my 3 daughter so my husband and I can go out, you know, and 4 spend some time together. 5 Q. Yeah. 6 A. But she wasn't there on the occasions of, you 7 Imow, when l had to go to a doctor session. It wasn't, 8 you know, it's not — I didn't have somebody on a 9 schedule there — 10 Q. During this — 11 A. — that could watch my daughter. 12 Q. During this two-year period that you were 13 in Virginia, was your husband living with you? 14 A. Yes. 15 Q. Were you living on a military base? 16 A. No. 17 Q. Okay. And was, was he in the military at 18 the time? 19 A. Yes. 20 Q. And did he have hours that he went to 2/ work? 22 A. Yes. 23 Q. Okay. And when would he typically work; 24 what was his schedule? 25 A. His schedule often changes since he's in the Page 28 1 Q. You said that you — I understand that you 2 went with your husband to the psychologist, but you 3 said you went to the psychologist one time alone to 4 talk about your problems. 5 A. Yes. 6 Q. There were times that your husband was 7 home from work that he could have watched your 8 daughter, and you could have gone back to the 9 psychologist, if you chose to, to discuss whatever 10 problems you wanted to discuss with her, right? 11 A. I could have. 12 Q. Okay. And the insurance company was 13 paying whatever those charges were? 14 A. Uh-hum. Yes. Sony. 15 THE COURT REPORTER: Thank you. 16 BY MR. LUTTIER: 17 Q. Let's talk now about the psychiatrist that 18 you said you saw in Virginia. 19 A. Yes. 20 Q. But first of all, let me go back and ask 21 you a question about the psychologist. How did you 22 select that female psychologist that you saw in 23 Virginia? rovides -- they accept. A. It was just offered through page 25 that, you know, p 24 Page 27 military. He can work day, night, or mid check. I don't know the exact schedule he was on at that point in 3 time, but day check is 6:00 to 2:30-3:00, depending on 4 what his boss wants to keep them. Mid-check is — mid-check is all night long. I don't know the exact 6 time, but ifs all through the entire night until 7 morning. And then the night check is --1 think it's 8 like 2:00 or 3:00 to 11:00 at night. 9 Q. Okay. So either the mid check or the 10 night check, he was home during the day? 11 A. Yeah. 12 Q. All right. So, there were times during 13 this two-year period that your husband was home and 14 available to watch your daughter? 15 A. Yeah, but I wouldn't, you know, I wanted to go 16 with my husband. 17 Q. Well, these were visits that you went to 18 the psychology — you went alone, right? 19 A. Psychiatrist or — 20 Q. Psychologist 21 A. Psychologist? 22 Q. We're still on the psychologist. 23 A. Okay. The psychologist was also for our 24 marriage, so I wanted him to go with me most of the 25 time. 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 18 119 2 21. 22 23 24 25 Page 29 Q. Okay. Okay. Now, you said you went to a female psychiatrist in Virginia as well. A Yes. Q. Was this during the same period of time that you went to the psychologist? A. That was after. That was before my husband was about to leave on his deployment. Q. Okay. A. I came — Q. When was your — A. Well, I came to Florida in January. Q. January of - A. Of last year. Q. — of '09? A. Yes. So, it was probably a couple of months before that that I went and saw her. Q. Okay. And how did you select that psychiatrist? A. The same way, off the Internet that the providers — And what city was she located in? I don't know. Do you remember where her office was? No. How many times did ou see her? Q. A. A. Q. 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. EFTA01076391 Page 30 Page 32 1 A. Twice. 2 Q. Do you, do you recall about over what 3 period of time you saw her? Like, was it two times 4 in a month? 5 A. I think it was once a month. 6 Q. And for what reason did you initially go 7 see her? A. Fa - 9 Q. And, and do you mean that when you went to 10 her you already knew that what ou wanted to do is 11 go get a prescription f 12 A. Not enact] , but something to help me 13 concentrate. 14 Q. And so, so your, as they would say, chief 15 complaint that caused you to seek out her aid was 16 you wanted something to help you with your 17 concentration? 18 A. Yes. 19 Q. Was there any other problem or, or 20 situation that you were seeking out her counsel for? 21 A. There was the second visit I mentioned that I 22 had, depression, and that's when she prescribed me 23 to try. 24 Q. How — did you have sessions with her when 25 you saw her on these two occasions, or did you 1 A. I did, but I'm not on it right now. 2 Q. Okay. When you say "right now," do you 3 mean literally like today? 4 A. As in the past, Ince, as in the past week I 5 stopped taking it. 6 Q. OW. And why did you stop taking it? 7 A. Because I'm pregnant 8 Q. Is it contraindicated; that is, did your 9 doctors tell you if you're pregnant, don't take it? 10 A. I just — I haven't seen lidgfayet, but I 11 just know ifs not good to takelMI while you're 12 pregnant. 13 Q. Well, I suppose the first thing we should 14 do is congratulate you on being pregnant 15 A. Oh, thanks. 16 Q. Is this a planned pregnancy? 17 A. Not necessarily. 18 Q. Are, are you happily pregnant? Let me ask 19 you that. 20 A. Yeah, I mean, ifs going to be hard, but — 21 two kids, young age, I mean. We'll see what happens. 22 Q. You're, you're sure you're pregnant? 23 A. I took four tests. 24 Q. Okay. Have you been to the doctor to 25 have — 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 31 simply go in and get a prescription? A. The fast time !just went in and got a 2 prescription. The second time I spoke to her about, you 3 know, depression medication. 4 Q. And, and what did you tell her about your S depression? 6 A. I just told her that I'm depressed. I'm not 7 happy. And I asked her what would be the best, you 8 know medication to try, and she told me to try 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q. This female psychiatrist Mat you saw in Virginia, was she the lust medical doctor to prescribe for you? A. Yes. Q. And was that initially prescribed at a level of a day? A. I think she started me off lower than that. Q. Okay. A. I don't, I don't recall what my — Q. Okay. A. first dosage was. Q. Have you taken Adder, continuously since the time that you saw this female psychiatrist in Virginia in 2007 right up until today? A. Q. A. Q. A. Q. A. Page 33 No, it's not — Early pregnancy? Yes. Okay. Very early. Does, does your husband know about it yet? Yes. Q. Okay. ill" So, so you have, you stopped taking last week because of your own decision that you didn't want to take that while you were pregnant? A. Yes. Q. Not because a physician said you couldn't? A. Yes. Q. All right. And did you find the was helpful to you? A. Yes. Q. It allowed you to concentrate better? A. Yes. Q. And had you had — was there a time in the past — you have a brother that, that has, has Attention Deficit Disorder? las 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. EFTA01076392 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 34 Q. And I think your brother at one time was on the medication. A. Yes. Q. And you had taken some of that — A. Yes. Q. -- when you were maybe in high school? MR. MERMELSTEIN: Make sure you let him finish his question before you answer. THE WITNESS: Oh, okay. BY MR. LUTTIER: Q. It wass like in high school you took some otitis A. Yes. Q. And you found that it was effective in terms of allowing, helping you to concentrate? A. Yes. Q. Is that how you knew that when you went to se.rthe chiatrist in Virginia that you wanted A. Yes. Q. Is there — for what riod of time did you take your brother's A. It was just for a short period of time. Q. Lfice less than a month? A. Yes. Page 36 1 alternative school. 2 Q. Okay. Typically classes here graduate in 3 June of a year. 4 A. Okay. 5 Q. So, when you say you got it late that 6 year, did you get it — 7 A. Late. 8 . Q. — within the same calendar year that you 9 would have received it had you — 10 A. I'm pretty sure it was in 2006. I was 11 supposed to graduate 2005. 12 Q. Okay. So, we know that in June if, if you 13 had stayed in school for each year and progressed by 14 passing every year, you would ordinarily have 15 graduated in June of '05? 16 A. Yes, Ida* stay back. 17 Q. No. Yeah,1tmderstand that 18 A. Okay. 19 Q. Pm just going back to your birthday. 21 That, that would mean that that would put you then 2 1 at 18 years of age June of '05 when you graduated? 22 A. Yes. 23 Q. So that would put you as a sophomore, 16 24 years of age? 25 A. Yes. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 3 Q. Okay. Is there — and that would have been when you were how old? A. I was in high school. Q. Freshman year? A. No. Q. Were you living in Jupiter at that time? A. No. This was probably my sophomore year. Q. Which would have made you 15 years old? A. Yeah, 15 or 16. Q. Okay. Your date of birth is =MS A. Uh-huh. Q. So do you know, do you know. in your sophomore year how old you were? A. No. Q. Okay. Let's go -- A. I was — Q. — let's go backwards. You, you got a diploina from the Palm Beach County school system. A. Yes. Q Did you get that in the same year that, that you would have graduated from -- A. No. Q. — high school class? A. I that late because I went to an 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 37 Q. Okay. So you, your best recollection is, you, you had taken your brother's sometime when you were about 16 years of age. A. Yes. Q. And then you took it for a month or two? A. For about a little less than a month. Q. Okay. Is there -- why did you not follow up, if you found it to be effective, with a physician to get a prescription of your own? A. !just didn't want to. I, I don't know why. Q. Is — do you recall what it is that caused you in 2007 when you went to sec the psychiatrist in Virginia to ask for the first time for A. I didn't ask for specs went in and asked her, yen .,w, what I, what she would, T I I1 you know, refer to me. And I mentioned a couple of pills, but the reason is because I was going back to school. Q. Okay. And, and you had arrived at the decision at that point you thought some kind of medication would assist you in being able to concentrate better? A. Yes. In school, yes. Q. 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. EFTA01076393 Page 38 Page • 1 A. Yes. 2 Q What doctor diagnosed you? 3 A. I don't blow. I don't recall. Q. What — where was A. I changed doctors. Q. Do you recall about how old you were when the doctor diagnosed you? o A. Yes. When I first started seeing the 9 psychiatrist in Virginia 10 Q. Okay. What doctor? Was it the, the 11 psychologist that you were seeing in Virginia that 12 you went to with ur husband that diagnosed you as, 13 as — 14 A. The psychiatrist. 15 Q The psychiatrist, the same one that 16 d — the same one that prescribed the 17 to ou made a formal diagnosis that 19 20 21 22 23 24 25 A. She didn't tell me that, but don't they have to do that themselves to give you the medication? Q I don'tlatow. Pills and doctors these days, I don't — A. I mean, I would hope so. I wouldn't want to — Q Do, do you have a recollection that some 1 physician that you saw in Florida? 2 A. I saw a male. 3 Q. And this is a medical doctor? 4 A. Yes. 5 Q What kind of practice was he in? 6 A. I don't know. 7 Q. Where was his office located? 8 A. Delray. 9 Q. And, and how did you come to go to this 10 particular physician? 11 A. The same way, with the 12 computer. 13 Q. And what kind of doctor was it? 14 A. Psychiatrist. 15 Q Do you recall approximately how long you 16 were in Florida before you went to him? 17 A. It was when my last dosage ran out from the 18 previous doctor in Virginia 19 Q Okay. So, you went to this psychiatrist 20 because you needed to have a medical doctor in order 21 to prescribe for you again? 22 A. No. I was in Virginia. 23 Q. Right. 24 A. I SOW the doctor in Virginia to get my 25 started. on the 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 39 physician formally diagnosed — A. One, one of them, yes. I don't -- specifically her, l don't remember if she said yes or no that I have it, but one of the doctors in Florida that I did see gave me a test to see if l was. Q. That would be a doctor that you saw in Florida after coming back from Virginia? A. Yes. Q. Okay. You said that in a recent visit to this Florida ician, that you had gone to to get more A. Uh-huh. Q Is that right? Okay. A. Yes. Q. When did you visit the Florida physician to Rea A. I don't recall. Q. Okay. It would have been -- this visit to the Florida physician would have been after you returned to Florida from Virginia? A. Yes. Q. And that, I think you told me was, you came to Florida in January of '09. A. Yes. Q. Okay. And was this a male or female 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 vas.. Page Q. Right. A. I came to Florida. I finished my dosage and then I went to a psychiatrist. 'didn't need a referral to see a psychiatrist in Florida. Q But you went to the psychiatrist in Florida so that you could get your prescription renewed? A. Yes. Q. Okay. How many visits did you have with this psychiatrist in Florida? A. Approximating, two or three. Q. And were these visits solely for purposes of getting your prescription? A. Yes. Q. And how long I mean, were these like five-minute visits? A. Yeah. It was a script. Q. You literally would just walk in and get the script? A. I'd walk in, see him, and get the script. Q. Okay. Did you have any counseling with him, or did he give you any treatment or just give you a prescription? A. No, he would just gave me a prescription. Q. Did you give him any history? That is did 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY, INC. EFTA01076394 Page 42 1 you sit down and tell him about your life or 2 anything like that? ' 3 A. No. 4 Qiasther than giving you a prescription 5 for a he didn't render any treatment to you? 6 A. No. 7 Q..2:abf the last physician that renewed 8 your arescription? 9 A. No. 10 Q. Okay. 11 A. The last doctor? 12 Q. Yeah 13 A. No. 14 Q. Who was the last doctor -- well, let me, 15 let me back it up. 16 You went two to three times to this 17 Florida psychiatrist who ou don't recall for 18 purposes of having your prescription 19 renewed, right? 20 A. Uh-huh. Yes. 21 Q. Did there come a time that you didn't go 22 back to him? 23 A. Yes, I didn't go back to him. 24 Q. Okay. And why didn't you go back to him? 25 A. Because he was in Delray. 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 44 Palm Beach, right? A. Yeah. Q. Is it like one of the complexes at Victor Farris? Is it over by Columbia Hospital or... A. Ifs off of Indiantown. Q. Indiantown Road up in — A. Yeah. Q. — up in Jupiter? A. No, ifs not. It's not what it is. It's... Q. What's not? What, ifs not off of Indiantown Road? A. No, it's -- no. I'm, I'm trying to think of the road. Next to Okeechobee. Ifs one of the exits before Okeechobee. Q. Exit off 1-95? A. Yes. Q. Palm Beach Lakes? A. No. Q. North or south of Okeechobee? A. I think ifs south of Okeechobee. Q. Belvedere? A. No. Q. Southern? A. No. Maybe it's north. I'm not good with directions. Page 43 1 Q. So, did you — 2 A. I changed it to West Palm Beach. 3 Q. Okay. Who did you go to in West Palm 4 Beach? 5 A. I think that's the one that I gave you the 6 number. I don't recall her name either. 7 Q. Okay. So you went to a you switched to .8 a female physician in West Palm Beach? 9 A. Yes. 10 Q. And is that female a psychiatrist? 11 A.. I know she prescribes medication, but I don't 12 know if she was the actual psychiatrist of the office. 13 I don't know how that works. 14 Q. Okay. Well, any, any medical doctor can 15 prescribe, so she could be an internal medicine 16 doctor for all you know. 17 A. Yeah, 'don't, l don't know. 18 Q. Was she in a group? 19 A. What do you mean? 20 Q. A group, she — was it a group practice or 21 just one doctor? 22 A. No, it was a group practice. 23 Q. Okay. Where was her office located? 24 A. West Palm Beach. I don't know. 25 Q. Okay. Well, you're familiar with West 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 45 Q. Okay. Well, north is behind you; south is — A. I don't know. Q. -- the other way. A. I don't know. Q. So, as you sit here today — A. Yeah. Q. — point which way you would go to get to this office. A. I was going towards Okeechobee from Wellington. Q. Okay. A. So north. Q. So, you had — all right. So, all you — this phone number that you have in your phone you think is this doctor? A. Yes. Q. ' Okay. So you -- how long -- how many — when did you first go to her? A. I don't !mow the date. Q. Approximately when, in the last six months? A. Yes. Q. And how many times have you gone? A. Two to three. 010•111001WSIISSISIMAllitat 12 (Pages 42 to 45) PROSE COURT REPORTING AGENCY, INC. EFTA01076395 Page 46 1 Q. And on each visit was it just to get the 2 prescription renewed? 3 A. Yes. 4 Q. Did she ever render any treatment to you? 5 A. No. 6 Q. Did you ever give her any history or sit 7 down and talk about any of your, your issues? 8 A. No. I did see a psychologist for that when I 9 was in Florida also, and I don't know the time frame. 10 Q Are you talking — okay, now you're -- 11 now, the psychologist that you saw in Florida for 12 that is that yes another doctor whose name is not on 13 these answers to interrogatories? 14 A. Yes. These answers, this was a while when I 15 was in Virginia when I did these, correct? 16 MR. MERMELSTEIN: Yes. 17 THE WITNESS: That's why they're not on 18 there. 19 MR. LUITIER: Duly disclosed. 20 BY MR LU'TTIER: 21 Q. When was the last time you saw this female 22 psychiatrist in, in West Palm Beach? 23 A. The psychiatrist that prescribed medication? 24 Q. Yes. 25 A. It was after the male, before I went to Page 48 1 estimate then that you must have seen this physician 2 within the last two months? 3 A. Yes. It was just, I don't take my 4 every day. 5 Q. And what does the prescription advise you 6 to do in terms of the frequency with which you're 7 take the 8 A. Take it every day. 9 Q. So, why don't you take it every day? 10 A. Because it makes you very hyper and 11 concentrate and stay up all night, so I didn't feel like 12 doing that every day. 13 Q. And have you advised the doctors that you 14 were having that side effect? 15 A. Yes, that's one of the side effects. 16 Q. Do you know whether or not this female 17 psychiatrist in Florida ever made a formal diagnosis 18 of you? 19 A. No. 20 Q. How about the male doctor in Delray, do 21 you know if he made a fonnal diagnosis? 22 A. Yes. 23 Q. You know he did? 24 A. Yes. 25 Q. Okay. And what was his diagnosis? Page 47 1 Virginia. I don't have an exact date and time. 2 Q. Well, was it within the last month? 3 A. No. 4 Q. Last two months? 5 A. The last three to four months, maybe. Two 6 to I'm, I'm not sure. 7 Was she the last physician to prescribe 8 for you? 9 A. Yes. 10 Q. And, and you had, you still have your last 11 prescription, right? 12 A. Pm not taking it anymore. 13 Q. I know you're not taking it, but you still 14 have the pills. 15 A. Yes, in Virginia. 16 Q. Well, you justsp hen did you say you 17 just quit talcing those last week? 18 A. Like five, yeah, five days ago. 19 Q. Okay. But the point is the prescription, 20 you had not run out of the latest prescription? 21 A. No. 22 Q. Okay. And so for what period of time do 23 you get a prescription; a month, two months? 24. A. No, it's about a month. 25 222ka. So would x a correct 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 21 21 22 23 24 Q. When was the last time you saw the 2 5 psychologist in Florida? Fay: A. That I have Q. And how do you know he made the formal diagnosis? A. Because he gave me a test and I asked him what it was for and he told me that it was for to see if I had Q. Did the female doctor in West Palm Beach that you most recently went to to renew your prescription give you a test? A. No, not that I recall. Q. Did the psychologist that you saw in Virginia give you any kind of test? A. Not that I remember. I don't know. Q. Did the psychiatrist that you saw in Virginia give you any kind of test? A. Not that — I don't remember. Q. Now, you, you mentioned when we were speaking about the psychiatrist in West Palm Beach that you, you have seen a psychologist in Florida? A. Yes. Q. And, and who what psychologist did you see? A. I don't remember their 13 (Pages 46 to 49) PROSE COURT REPORTING AGENCY, INC. EFTA01076396 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 50 A. That was when I first got to Florida Well... Q. That would be January of '09? A. Give me a second. Q. Sure. A. It was probably around March or April. I'm, you know, Pm guessing. Q. March or April of '09? A. Yes. Q. And was this doctor male or female? A. He was a male. Q. And I assume he probably still is a male but — A. Yeah. Q. Where was his office located? A. It was in Wellington next to Greenview Shores. Q. In the Greenview Shores strip center or shopping center? A. I'm pretty sure, yes. Q. And how did you find this psychologist? A. Actually, my mother-in-law. My husband went to a doctor that was really good for him when he was younger, and she tried to get me to see the same doctor he went to. She didn't acce him, and he accepted Q. Okay. First, what's your other-in-law's so she referred 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 52 Q. What kind of physician was that? A. Psychologist. Ot kticl you said she, I assume you meant Ms. =, tried to get you an appointment with this psychologist that had seen her son when he was young? A. Yes. Q. But you don't know that psychologist's name? A. Nope. Q. AM did you ever contact that psychologist? A. Yes. Q. So you placed a phone call, or did you go see this psychologist? A. 1 placed a phone call and I saw hint Q. Okay. You did both? A. Yes. Q. All right. So there, tits another physician. And where was this, the psychologist who your mother-in-law initially suggested you go see who had seen your husband as a youth, where was his office located? A. That was the one I just gave you in Green, at the Greenview Shores. 1 2 3 4 6 5 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 C25 Page 51 name? A. (phonetic). Q. How wotldou spell that? A. -M you could put. and I don't know how to s II her entire — • =, • A. Yes. Q. And, and is that your husband's mother? A. Yes. Q. Okay. She lives where? A. In the Isles of Wellington. Q. And is that the name that she goes by now? A. Yes, M. Q. Is she married now? A. Yes. Q. And her husband's last name is = 11 A. Yes. Q. And do you know his first name? A. Mervin. Okay. So your husband at some time in the Q. past had seen a physician who he felt did a good job for him? A. Yes. Q. Do you know that physician's name? A. No. Vt 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 53 Q. Oh, I, I thought you had said, correct me if I'm wrong, but I thought you said your mother-in-law had wanted to get you in to see a psychologist that your husband had gone to in the but that that psychologist wouldn't take • A. Yes. Q. So, that psychologist recommended another psychologist A Which is hint. Q. The one that you, that, that — when you say this is him, the "him" that you're talking about is this psychologist that you saw in Greenville shops? A. Yes. Q. All right. But that's not the psychologist that saw your husband when he was younger? A. No, because they didn't accept Q. What I wanted to know was, did you have a conversation with the psychologist that saw your husband when he was younger? A. No. • Q. You had no contact with him? A. No, my mother-in-law did. 14 (Pages 50 to 53) PROSE COURT REPORTING AGENCY, INC. EFTA01076397 Page 54 1 Q. Andshetoldyouthat- 2 A. She gave me -- 3 Q. — as a result of her conversatliiiii 4 that psychologist they wouldn't take 5 A. Yes. Q. And then she provided the name to you to go see this psychologist whose name you don't recall :3 in your Greenville shops? 9 A. Yes. 10 Q. Okay. Did you ask your mother-in-law to 11 fmd a psychologist for you in, somewhere around 12 March or April of '097 13 A. I mentioned it to her, yes. 14 Q. And how did that come up? 15 A. I was just, Pm very depressed, and she just 16 mentioned somebody that her son saw that was very good. 17 Q. And was that for depression? 18 A. Yes. Forme? 19 Q. Yeah. 20 A. Yes. 21 Q. Okay. And, and how many times have you 22 been to this psychologist near Greenville shops? 23 A. Four to five times. 24 Q. And do you go for 45-minute sessions? 25 A. I believe so, yes. Page 56 1 A. I just told him that I was very depressed and 2 I don't feel happy. 3 Q. And what did you tell him you believe was 4 the cause of your depression? 5 A. My past, things live gone through. 6 Q. Did — specifically, what did you tell 7 him? 8 A. Me, rve told him about me and my husband. I 9 told him about the situation with Epstein. I told him 10 about my parents, my childhood. 11 Q. What is it you told him about your parents 12 and your childhood? 13 A. We didn't get along sometimes. 14 Q. Now, when, when you're referring to your 15 porous, who are you referring to? 16 A. Well, my mother and my stepfather, and my 17 father and his girlfriend at that time. 18 Q. And, and when you say, "your mother," 19 you're talking about your birth mother? 20 A. Yes. 21 22 A. 23 Q. And where does she now live? 24 A. Boca Raton. 25 Q. And your stepfather is whom that you Page 55 1 Q. And did you go once a month, or with what 2 degree of frequency did you go? 3 A. hives once every two weeks. 4 Q. So, if you went four to five times, you 5 went for a total of about two months? 6 A. Yeah. 7 Q. So, that's going to take us until sometime B around June of '09? 9 A. Yes. 10 Q. And what was the purpose of you going to 11 that psychologist? Was each visit designed to 12 address your depression? 13 A. Yes. 14 Q. Did the psychologist take notes? 15 A. Yes. 16 Q. Did the psychologist make any formal 17 diagnosis? 18 A. No. 19 Q. Did that psychologist have any work that 20 he had you do where you had to write things out? 21 A. No. 22 Q. Did he do any testing? 23 A. No. 24 Q. And what did you tell this psychologist 25 about cur depression? 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 57 referred.lp? A. ar Same last name. Q. And does he still live with your mom in Boca? A. Yes. Q. Okay. And your — when you refer to your father, are you talking about your birth father? A. Yes. Q. awavhat is his name? A. OM Doe No. 5. Q. And where does he live? A. He lives in Wellington. Q. And you referred to his girlfriend? A. This girlfriend that he has now is not the one that he had in the past that I had problems with. Q. Who was the girlfriend you were referring to? A. (phonetic). Q. And was she living with your dad at some point in time when you were having problems with her? A. Yes. Q. Do you need to take a break? A. Yes. MR. LIMIER: Yeah. if !; 15 (Pages 54 to 5 7) PROSE COURT REPORTING AGENCY, INC. EFTA01076398 Page 58 Page 60 1 break, just tell me. It appeared to me that 2 you were in some kind of distress. 3 THE WITNESS: No, !just -- 4 MR. LOTTER: You don't have to wait If 5 you want a break, just say. This is no — this 6 isn't, you know, torture chambers. 7 THE WITNESS: Yeah. It feels like it. 8 THE VIDEOGRAPHER: Off the record. 9 (A brief recess was held.) 10 THE VIDEOGRAPHER: We're back on the 11 record at 938 a 12 BY MR. LUTTIER: 13 Q. Okay. As to the psychologist, male 14 psychologist in Florida whose office is near 15 Greenville shops — 16 (Interruption at the door by 17 maintenance man.) 18 BY MR. LUTHER: 19 Q. You said you told him about your parents, 20 and your childhood. 21 A. Yes. 22 Q. And specifically your mom, stepfather, 23 father and grandfather. What is it you told him 24 about these members of your family? 25 A My dad and I had some conflicts verbally, and 1 A. Yes, I was in South Carolina 2 Q All right. So would it be a correct 3 statement that his physical abuse of you ended when 4 you left South Carolina? 5 A. Yes. 6 Q. And that would have been while you were in 7 the eighth grade? 8 A Yes, the beginning. 9 Q. And approximately on how many occasions 10 did he physically abuse you? 11 A It was, it was two to three times he's really 12 hit me. 13 Q. Okay. And describe those incidents. 14 Well, let me ask you this, did you describe those 15 incidents to this psychologist, male psychologist 16 who you saw near the Greenville shops down here? 17 A. Yes. 18 Q. Okay. What, what did you tell him? I 19 assume you told that psychologist the complete 20 story? 21 A. Yes. 22 Q. All right. You were truthild to him? 23 A. Yes. 24 Q By the way, you've seen a number of 25 psychologists strictly related to this lawsuit, have Page 59 1 my mom and I also did. 2 Q. And those things were causing you to be 3 depressed, to be depressed, you thought? 4 A. It was some of the reason, yes. 5 Q. And what did you say about your stepfather 6 and your, and your father's girlfriend? 7 A. My stepfather sometimes was physically 8 abusive. 9 Q. How often was he physically abusive with 10 you. 11 A It was on rare occasions when he would get 12 really upset. 13 Q. Did he, did he hit you more than once? 14 A. Yes. 15 Q. And did all his physical abuse of you, 16 that is, your stepfathers physical abuse of you, 27 occur prior to your completion of the ninth grade? 18 A. Yes. 19 Q. Did it, did it all occur, did he 20 physically abuse you on numerous occasions prior to 21 your completion of the eighth grade? 22 A. The eighth grade is when I left and moved with 23 my father. 24 Q. That is you left from — at the time you 25 '; were living with your mother and stepfather? ••••••••11~ Page 61 1 you not? 2 A. Strictly related to this lawsuit? 3 Q. Um a Dr. You recall him? 4 A. Yes, yes. 5 Q. Okay. You saw a Dr. a 6 A. Uh-huh, yes. 7 Q. With respect to those two individuals, did 8 you tell them the truth about everything? 9 A. Yes. 10 Q. So if they asked you a question, you gave 11 them a response, it was a truthful response? 12 A Yes. 13 Q. You answered fully and completely any 14 questions that they had? 15 A. Yes. 16 Q. Okay. MI right And, likewise, were, 17 were you truthful with all these psychologists and 18 psychiatrists whose name you've given me for the 19 first — well, whom you've identified for the first 20 time in today's deposition? 21 A. Yes. 22 MR MERYffiLSTEIN: Objection to form. 23 BY MR. LIMIER: 24 • • Q. And were you complete in your discussions 25 with them, told them everything that, you know, that 16 (Pages 58 to 61) PROSE COURT REPORTING AGENCY, INC. (561) 832-750.6 EFTA01076399 Page e-e. Page 64 1 was relevant? 2 A. Yes. 3 MR. MERMELSTEIN: Form. 4 BY MR. LUTTIER: 5 Q. Okay. Well, everything — I should say, 6 you told them everything you thought was relevant to 7 the reason why you were there to see them? 8 MR. MERMELSTEIN: FORTE 9 THE WITNESS: Yes. 10 BY MR. LUTTIER: 11 Q. Okay. Now, tell me about then what is it 12 you told this psychologist, male psychologist here 13 in Florida at the Greenville shops with respect to 14 the two to three times that your stepfather 15 physically abused you prior to your completion of 16 the eighth grade? 17 A. There was one occasion where he got upset 18 because I told my friend on the phone that I was, you 19 know, I didn't like him. And he came into my room and 20 hit me across the face and threw my television down the . 21 stairs and just had a bad temper. 22 Q. Okay. And let me, let me make sure I 23 understand this. This is something that occurs when 24 you're, what, 13 years old? 25 A. Yeah, 12, 13. 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 21i 21 22 23 24 25 A. Yes. Q. Was the scene hysterical? MR. MERMELSTEN: Objection, asked and answered. BY MR. LUTTIEFt: Q. That is, was, was everybody that was there in hysterics? A. Yes. Q. Was your mom there? A. Yes. Q. Your mom has always loved you, right? A. Yes. Q. Was she hysterical? A Yes. Q. What was she doing while her husband was beating you so severely that he ruptured your eardrum? A. She was trying to push him away. Q. Trying to protect you? A. Yes. Q. At that point in time was that the worst thing that had ever happened to you in your life? A. That point in time, yeah, that was pretty bad for me. Q. Was it the worst thing that ever happened Page 63 1 Q. Okay. AM how old was your stepfather at 2 the time? 3 A. I don't laiow. 4 Q. Bigger physically? He was obviously was 5 bigger than you, right? 6 A. Yes. 7 Q. And he came into your room when you were 8 on the phone? 9 A. Yes. 10 Q. And he literally picked up a TV from your 11 room and threw it down the stairs of your home? 12 A. Yes. 13 Q. Would it be safe to say that you were 14 hysterical at that time? 15 A. Yes. 16 Q. You were crying? 17 A Yes. 18 Q. You were scared? 19 A. Yes. 20 Q. He then did physical violence to you? 21 A. Yes. 22 Q. Asa matter of fact, he beat you so badly 23 that he ruptured your eardrum, didn't he? 24 A. Yes. 25 Q. Did you fear him when he was doing that? 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 65 to you in your life? A. Yes. I was upset, yeah. Q. • You sound like you're hesitant, so I just ;- A. I'm just, I'm just thinking back. Q. I want you to take your time. I want you to think about it. I want to — so, if you need to take a minute, is that the worst thing that ever happened to you in your life as of that point in time? A. Yes. Q. How did he beat you so as to rupture your eardrum? A. He hit me across the face. Q. With a closed fist? A. I don't recall. It was very fast. I don't 'mow. Q. Still have the phone in your hand? A. The phone? Q. Did you still have the phone that you were on in your hand? A. No, he ripped it out of my hand. Q. That's the first thing he did, right, he came up and tore the phone? A. Yes. 17 (Pages 62 to 65) PROSE COURT REPORTING AGENCY, INC. EFTA01076400 Page 66 Page 68 Q. Did he tear up your room? 2 A. He ripped the phone out of my hand, ripped it 3 out of the wall, took the TV, threw it down the stairs 4 and hit me. 5 Q. Ripped the phone out of the wall so you 6 couldn't call for help? A. He ripped it out of the wall probably because 3 I was on the phone with my friend telling them how I 9 didn't like him. 10 Q. And do you recall why you were telling 11 your friend that you didn't like this fellow that 12 just beat you? 13 A. As of why I was saying it? 14 Q. Yeah. 15 A. He was just very strict. 16 Q. Had he prior to this occasion when he 17 beat you so badly that he ruptured your eardrum, had 18 he hit you before? 19 A. Not as bad as that. That was the, the worst. 20 Q. Was there, when he ruptured your eardrum, 21 was there any blood? 22 A. No. 23 Q. Did you go to a physician and seek medical 24 care? 25 A. Yes. 1 haunts you today, doesn't it? 2 MR. MERMELSTEIN: Objection to form. 3 THE WITNESS: Yes. 4 BY MR. LUTTIER: 5 Q. And that's when you've gone to all these 6 psychologists and psychiatrists and you've talked 7 about your past you have always mentioned this 8 incident, have you not? 9 A. Yes. 10 Q. And it gives you concern, one of the 11 things you worry about in life is whether anybody 12 would do anything like that to your little daughter, 13 isn't it? 14 A. Yes. 15 Q. You're very vigilant about making sure 16 nobody hurts your daughter. 17 A. Yes. 18 Q. And you're acutely aware of domestic 19 violence? 20 A. Yes. 21 Q. Other than that, when you went back to — 22 when you went to South Carolina with him, and he 23 drew things at you, other than the tub of butter, 24 did he throw anything else at you? 25 A. Not that I recall. He was, he, he would Page 67 1 Q. Were you still scared even after the 2 incident happened? 3 A. I was scared that he had a bad temper and it 4 could happen again. It never happened again, to that 5 extent again. 6 Q. But he did hit you again, didn't he? 7 A. Yes. 8 Q. When did he next hit you? 9 A. The instance I just gave you was in Fort 10 Lauderdale. 11 Q. Okay. 12 A. And then when I moved to South Carolina, ifs 13 not that he hit me, but he would, like, throw things at 14 me. 15 Q. Did he ever hit you with anything when he 16 threw it at you? 17 A. He threw a tub of butter at me in South 18 Carolina. 19 Q. But the incident where he beat you and 20 your eardrum was punctured, that happened while you 21 were in the eighth grade, right? 22 A. It was the seventh or the eighth grade, 23 because I was in Fort Lauderdale going to middle school 24 there. 25 Q. Asa matter of fact, that incident still Page 69 1 always lose his temper. 2 Q. When you're when he beat you on that 3 occasion and he ruptured your eardrum, was your 4 mother finally able to get him to stop? 5 A. She told me that she would leave him if I 6 Q. !mean when the incident was happening and 7 you were there, she was present watching it, was she 8 not? 9 A. Yes. 10 Q. How did what caused him to stop beating 11 you? 12 A. He calmed down and realized what he was doing 13 and my mom stepped in. 14 Q. Did she, did she then come over and, and 15 console you? 16 A. Yes. 17 Q. Did you feel that your mother was 18 partially responsible for that action? 19 A. For that specific act that day that he did 20 that? 21 Q. Yeah. 22 A. No, no. 23 Q. How about for the fact that she had him 24 aroma( and you were exposed to him and he had been 25 conducting himself like that towards you? 18 (Pages 66 to 69) PROSE COURT REPORTING AGENCY, INC. EFTA01076401 Page 70 1 A. Ina way, yes. Like you say, I held her 2 responsible for yes. 3 Q. I mean, this stepfather treated you poorly 4 for as long as you can remember, did he not? 5. A. Not any — 6 MR. MERMELSTEIN: Objection to form. 7 THE WITNESS: Not anymore. 8 BY MR. LUITIER: 9' Q. Well, not now, but back when you were -- 10 you, you lived with your mother and your stepfather, 11 this fellow -- 12 A. Yeah. 13 Q. -- for a period of time, did you not? 14 A. Yeah. 15 Q. — and do you recall about when that was? 16 You can use your age; how old you were. 17 A. Yeah. They got together when I was three 18 years old. 19 Q. Okay. And they, and you lived with them 20 until you came back to, to West Palm when you were 21 finishing up the eighth grade? 22 A. Yes. 23 Q. So that's when you were, what, 13 years 24 old? 25 A. Yeah. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 72 MR. MERMELSTEIN: Objection, form. THE WITNESS: He told me that I was *Sage. BY MR. LUTTIER: Q. And how did that make you feel? A. Like crap. Q. And that still bothers you too, doesn't it? A. Yeah. Q. And do you tcunwber when he did that? A. When he did what? Q. When he told you you were baggage. A. He told me that recently when I was living there. Q. Recently meaning when? k When I was — after high school. He was apologizing for the way he acted, and basically just said that back in the day he thought of me as baggage. Q. And do you recall him telling you back then that you were — that he thought you were baggage? A. No. Q. Did he tell you back when you were living with him for the ten-year period that, that, that you were sort of an inconvenience to him? 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 71 Q. All right. So you've got years that you lived with your mother and, and this stepfather l=? A. He — in, in the beginning he didn't live with us, but he was over a lot. Q. And during that ten-year period, he not only physically abused you, but he verbally abused you, did he not? A. Yes. Q. What kinds of things did he tell you? A. He would just ten me to shut the F up, and that I was stupid and immature and mean. Q. Did, did that make — did he demean you? A. Make me feel like — Q. Lice little. A. Yeah. Q. Make you feel like you weren't a good person? A. Yes. Q. And did you resent that with your mother that she would allow her boyfriend or her, her husband to treat you that way? A. Yeah. Q. Did he, did he ever tell you where you fit into his view of the world? Page '73 1 A. No, but I could see it through his actions. 2 Q. Do you recall other incidents where he 3 physically abused you? 4 A. I don't remember, like exactly,' just haw he 5 lost his termer a lot. I don't remember specific — 6 Q. And when he lost his temper he would 7 strike you? 8 A. Not just that, but he would, you 'mow, 9 sometimes it would just be like he would throw things 10 or, you know, run out of the house pissed off and 11 whatever, have his tantnam. 12 Q. AM these are still events that -- what 13 are you, 22 years old now? 14 A. Twenty-three. 15 Q. These are events that still -- 16 A. They're upsetting. 17 Q. — that you recall? And, and although you 18 love your mother, do you hold her responsible for, 19 for you being subjected to that kind of conduct for 20 a ten-year period? 21 MR. MERMELST'EIN: Objection, asked and 22 answered twice already. 23 THE WITNESS: Yes. 24 BY MR. LUTHER: 2 5 .9 .1.4emd _E d u ten is ychologjst in 19 (Pages 70 to 73) PROSE COURT REPORTING AGENCY, INC. EFTA01076402 Page 74 1 Florida that you saw over by Greenville shops about 2 all these instances? 3 A. Yes, I've — I didn't tell him about, you 4 know, the butter and everything, but I told him about 5 the eardrum. 6 Q. Okay. What did you, what did you tell 7 him? Did you tell him anything else specifically, 8 that is this psychologist in Florida, specifically 9 about your stepfather other than what you've told us 10 thus far? 11 A. Not that I recall. 12 Q. Okay. 13 A. About my stepfather -- 14 Q. Yeah. 15 A. — only? Yeah, not that I recall, just that 16 he had a bad temper and with the eardrum situation. 17 Q. Is your — can you hear all right today? 18 A. Yeah. 19 Q. Now, you, you told the psychologist here 20 in Florida that you had some verbal conflict with 21 your mother as well. 22 A. Uh-huh, yes. 23 Q. And what did you tell the psychologist 24 here in Florida when you went to see him about 25 conflict with your mother? 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page r tumble? A. She just said just don't tell him that, hit you. Q. Is that something that you regret having done up through today? A. Ina way. !just try to, you know, it was in the past and he's apologized for it, so... Q. Did you how do you feel towards your mother now that you're older about her having even asked you to go tell a doctor something that wasn't true about you being abused by her husband? A. I'm sorry. What did you say? Q. It was a bad question. How does it make you feel now knowing that your mom asked you to go lie to a doctor to cover for her husband when, when — A. Now, or at that point in time? Q. How does it make you feel now? A. It's upsetting. It hurts my feelings. Q. How did it make you feel then? A. I — you know, I was young. I didn't, that didn't really — I don't remember what I felt at that point Q. Mir, as you sit here today, if that happened to your daughter, God forbid if she had a Page 75 1 A. I had conflicts with my mother because of my 1 2 stepfather. 2 3 Q. And, and what was the nature of that 4 conflict? 5 A. Just that I wanted her to leave him. 5 6 Q. And did you ever tell her that? 6 7 A. Yes. 7 8 Q. And do you remember when you first told 9 her that? 9 10 A. No. 10 11 Q. Do you know approximately when it was, how 11 12 old you were? 12 13 A. No, because she asked me if I fluted her to 13 14 leave him when he hit me and I said no. 14 15 Q. By the way, when, when he hit you and you 15 16 went to see the doctor for medical cares did you, 16 17 did you lie to the doctor about how you got the 17 18 injury? 18 19 A. Yes. 19 20, Q. And why did you do that? 20 21 A. So he didn't get in trouble. 21 22 Q. Did your mom encourage you to do that? 22 23 A. Yes. 23 24 Q. Did she tell you basically that if you 24 25 told the truth that, that her husband would get in 25 Page 77 similar thing happen to you, would you do the same thing your mom did? A. No. Q. Okay. You, you, you said that you told your mom that you wanted her to leave your stepfather and I assume that she declined to do . that? A. Yes. Q. That caused resentment between the two of you? A. Yes. Q. Has that been a source of conflict between the two of you ever since? A. To, today, I don't care, because I have my own family and life. But back when, you know, I was still like around the situations, it bothered me. Q. Any other conflict that you had with your mom other than you, you asked, you asked her to leave her husband and she declined to do so? A. Ion sorry. What did you say? Q. Any other conflict that you had with your mom? A. There was one instance when we were in Chicago. Q. And that's when you were about how old? 20 (Pages 74 to 77) PROSE COURT REPORTING AGENCY, INC. EFTA01076403 Page 78 A. It was, I think it was beginning of middle school, around that time. I don't know the exact time 3 frame. 4 Q. Before you finished the eighth grade? A. Yes. Q. Okay. What happened in Chicago? A. She actually split up with my stepfather and 3 was dating another guy. And I walked next to the street 9 in Chicago and she got upset and hit me in the bathroom. 10 Q. I assume that upset you at the time? 11 A. Yes. 12 Q. Still upsets you? 13 A. It does, but... 14 Q. You wouldn't hit your daughter? 15 A. I don't, no, I don't like to hit. 16 Q. Still an event that when you watt to the 17 psychologist you told him about it? 18 A. Yeah. 19 Q. Because it was upsetting to you? 20 A. Yeah. 21. Q. Still upsetting to you? 22 A. Yeah. 23 Q. Okay. Any other conflict that you've had 24 with your mom? 25 A. Just differences in life. Page 80 1 BY MIL LUTTIER: 2 Q. Okay. Anyway, all right. So you had gone 3 to, you lived with your mom and your step dad down 4 in Fort Lauderdale. They moved with you to South 5 Carolina. 6 A. Yes. 7 Q. But you only were in South Carolina for a 8 number of months. 9 A. Yes. 10 Q. You enrolled in a school up there in the 11 eighth grade. 12 A. Uh-huh. 13 Q. That's a yes? 14 A. Yes. 15 Q. Then you came back to Florida and you 16 moved in with your dad, your birth dad? 17 A. Yes. 18 Q. And you stayed with your birth dad from 19 the time that you were finishing up, up eighth grade 20 until when? 21 A. Eighteen. 22 Q. Did you have contact with your mom after 23 you moved back to Florida when you were in the 24 latter part of the eighth grade? 25 A. Yes. Page 79 1 Q. Do you believe your mom, as you sit her 2 today, let you down as a, as a child? 3 MR. MERMELSTEN: Form. 4 THE WITNESS: There were things that she 5 did that I didn't like. 6 BY MR. LIMITER: 7 Q. Like what, besides not leaving her 8 husband? 9 A. Just that I was her first kid and she didn't 10 really know how to raise me. 11 Q. Now, you said that you came back to 12 Florida to live with your dad. 13 A. Yes. 14 Q. Was it January of '07, somewhere around 15 there? 16 A. It was 17 Q. forgot. 18 A. — in the eighth grade. 19 Q. Okay. Lets see — 20 MR MERMELSTEIN: Did you say '07? 21 MR. LUTTMR: Yeah, let me see. I don't 22 want to mess up the record. 23 MR. MERMEISTEIN: '07 she was 21. 24 MR. LUTHER: It wasn't in '07. 25 THE WITNESS: No. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Adihtetla.... ..I.axaratsaaeo Page 81 • Q. And what kind of contact did you have with heel A. Phone. Q. Is that - A. And I saw her in summers. Q. Is that the only time you saw her? A. Yes. Q. And where did mom live from the time that you finished up the eighth grade down here in, in Wellington until your 18th birthday? A. She stayed in South Carolina and then she moved back to Florida probably, my, I'm going to say my junior year. Q. That would be 2003? A. Yes, I think so. Q. And when you say she came back to Florida, did she come back to Florida with her, your step dad? A. Yes. Q. And where did they come when they came back to Florida? A. They went back, they went to Boca. Q. Is that where they live now? A. They lived in a temporary house until the other house was sa rdelSe.kniBec 21 (Pages 78 to 81) PROSE COURT REPORTING AGENCY, INC. EFTA01076404 Page 82 Page 84 Q. Okay. Is the house that they live in now 2 the one that they moved into after they were in the 3 temporary house? A. Yes. Q. Okay. So they've lived there continuously since about 2003 when they returned to Florida? A. Yes. 3 Q. And up until 2003, you would see your mom 9 in the summers? 10 A. Yes. 11 Q. All right. Did there oome a time before 12 your mom came back in 2003 that your mom took you to 13 see a psychologist or a psychiatrist? 14 A. She took me to see a psychologist 15 Q. Okay. So would you look at the answers to 16 imerrogatories and tell me — I will show you again 17 Interrogatory 8, and tell me which physician your 18 mom took you to see. 19 A. I don't think it's in here because I didn't 20 remember at this time, but I have his name and where he 21 is. 22 23 24 25 Q. Where do you have his name? A. 1 in my mind I know his name. Q. O *t ,=. Well, what's his name? A 1 lawyer. 2 MR. LUITIER: Yeah, don't Just a yes or 3 no, but don't tell, I don't want to know -- 4 THE WITNESS: I'm sorry. 5 MR. LUTITER: About the substance of your 6 conversation. 7 THE WITNESS: All right. 8 MR. LUITIER: One of the reasons why Pm 9 asking you this is we have these 10 interrogatories where we ask you information, 11 and, and had I known who these doctors were, I 12 would have had their records beforehand, and 13 would be able to ask you about information 14 based on the records. And in our rules there 15 is a duty to continue to disclose these people. 16 And I, just for the record, Stuart, you 17 know, I've got, Pm up to six that I don't know 18 anything about, otherwise I would have these 19 records. And I think there's that duty to 20 disclose. And I know we are under some time 21 things. I'm trying to — I was going to try to 22 get it done, but... 23 MR. MERMELSTEIN: I, I understand that, 24 and I realized when you were going through with 25 it in the first hour. Page 83 Q. a 1. 2 A. Yes, I'm pretty sure. 2 3 Q. And, and when did you go to see 3 4 Dr. Milln 4 5 A. 11, it was a trip I took with my mother. She 5 6 was still living in South Carolina. I don't recall 6 7 exactly when it was. 7 8 Q. Well, it had to be before 2003, right? 8 9 A. Yes. 9 10 Q. And, what do you mean, it was a trip you 10 11 took with your mom? 11 12 A. She went to go see him in Memphis, Tennessee. 12 13 and she wanted me to go with her. 13 14 Q. Now, this — how, how is it that you 14 15 recall this physician's name who you saw sometime 15 16 before 2003, and you know his name but you don't 16 17 know the names of these other physicians that you've 17 18 seen since then? 18 19 A. Because I found his book the other day in my 19 20 house. 20 21 Q. Have you provided his name to your lawyer? 21 22 A. Actually, yesterday. 22 23 Q. Is there 23 24 MR. MERMELSTEIN: Don't talk about 24 25 anything else you've discussed with your 25 Page 85 MR. LUITIER: Okay. MR. MERMELSTEIN: I don't I don't know if it's six or not. I wasn't — MR. LUTTIER: Yeah. MR. MERMELSTEIN: — counting to that extent, but yeah, I am aware that there are psychological professionals, health care professionals that need to be disclosed. MR LUFTIER: Yeah, because I tried to get -- the idea was to get -- I subpoenaed all the records that I knew to try, so that I would have them here so that I could go through this. And Pm now going to have to obviously get those records, and I may have to still do some other stuff. Okay. MR. MERMELSTEIN: I understand. BY MR. LUITIER: Q. All right. Let me go back to Dr. =. Okay. So, you say you recently found aWof his in your house? A. Yes. Q. When you say "your house," what house are you referring to? A. Oh, Virginia. • Q. Okay. Do you — is that a book that you 22 (Pages 82 to 85) PROSE COURT REPORTING AGENCY, INC. EFTA01076405 Page 1 had or you read? 2 A. Yeah, he gave me a book when I went to sec 3 him. 4 Q. So, this is a book you got back in 5 sometime before '03? 6 A. Yes, whenever I saw him. 7 Q. And what's the name of the book? 8 A. I don't recall the books name. I just 9 remember his name. 10 Q. What's it about? 11 A. Stories that he's been through with his 12 clients and how they recovered and... 13 Q. Well, what kind of doctor is he? 14 A. He was a psychologist, I think. 15 Q. Does he have some specialty or particular 16 kinds of patients that he sees? 17 A. I don't know. 18 Q. For example, some people will specialize 19 in, let's say, alcohol addiction, and they might 20 write a book about their clients and they're all 21 clients that were alcoholics. And they talk about 22 their story and stuff like that 23 You mentioned that his book was 24 stories about clients that he had. Is there some 25 similarity among his clients, they arc all there for Page 88 1 conversation with your dad about the fact that you 2 were going there? 3 A. I'm sure — I don't remember that, but I'm 4 sure I told him where I was going. 5 Q. Did you know why you were going? 6 A. She told me it was she wanted me to, you know, 7 see somebody and talk to somebody. 8 Q. What about? 9 A. To help me. 10 Q. Help you about what? 11 A. Because I was depressed. 12 Q. And when you say you were depressed, is 13 that, is that a diagnosis that someone had made of 14 you St that time? 15 A. No. 16 Q. Or just you were -- a description of how 17 you felt? 18 A. Description of how I felt. 19 Q. And your mom had sensed that she also was 20 of the opinion you were depressed at the time? 21 MR. MERMELSTF_IN: Objection to form. 22 THE WITNESS: She just thought I was, you 23 know, that I needed to talk to somebody. L.. 24 BY MR. LIJTTIER: 25 Q. Were you doing anything or engaging in any 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 87 the same reason or something? A. No it was all different. Q. Okay. Now, you said your mother was going to see this person in Memphis. Was she going to see Dr. on her own for some reason for her, or was it just somebody she picked that she wanted to take you to? A. No, it was somebody that she was going to. Q. Do you know why your mom was going to see this person? A. No. Q. And was this — this would have been during the summertime, I assume, if it's your mom and you taking a trip? A. Fm pretty sure, sunvner or spring break. I don't recall exactly when. Q. And you were living at the time with your dad, your birth dad in Florida? A. Yes. Q. Did he know that mom was going to take you to this -- A. Yes. Q. Did you-all discuss that before you went? A. No. Page 89 1 kind of conduct that caused ha concern at that 2 time? 3 A. Not that I millet ulna. 4 Q. Had she said to you that you had changed 5 in any manner in your relationship with her or 6 someone else that caused her to think that you were, 7 you needed to see this person? A. I don't, I don't, I don't remember. It was, I 9 don't think so. I mean, I don't —ljustIcnow she 10 wanted me to go see this person. 11 Q. Had she said to you anything like, you 12 know, we used to be close and now you're a different 13 person, and I think you need to see somebody? 14 A. She saw changes in me. 15 Q. What kind of changes did she say she saw 16 in you? 17 A. Because I used to be very, like, close to her. 18 Q. Okay. 19 A. And I would always be home when I said I would 20 be home. And, you know, when I went and saw her 1 would 21 go do my own thing and basically not, you know, abide by 22 her rules. 23 Q. Now, when you say you went and saw her, 24 you mean when you went to — Q. Did, do you remember, having any 25 A. South Carolina. 23 (Pages to 89) PROSE COURT REPORTING AGENCY, INC. EFTA01076406 Page 9 1 Q. — South Carolina? 2 A. Yes. 3 Q. And were you — when you, the phrase you 4 used, you would do your own thing, what do you mean 5 by that? A. One time, for instance, I went with one of my 7 old friends there. I went on a ride on a golf cart, and a 1 was out fora while, and she wasn't used tome, you 9 know, not calling her, telling her where I was, and I 10 just wasn't, you know, being close to her. I wasn't 11 telling her things. I was just doing what I wanted. 12 Q. And at, at, at the time, what was 13 happening to you in school? 14 A. School-wise, like grades or 15 Q. Like were you attending school regularly? 16 A. I think at that time I was. 17 Q. Had you started skipping school? 18 A. I did start skipping school my senior year. 19 Q. So you didn't start skipping school until 20 your senior year? 21 A. I did a little bit in my junior year, but my 22 senior year was my worst. 23 Q. And were you, were you doing similar 24 things down here while you were living with your 25 dad? Page 92 Q. Okay. How else could you describe what your relationship with your dad, your natural 3 father, was at the time that your mom decided that 4 she wanted you to go see Dr. M? 5 A. We didn't really have a relationship anymore 6 after a while. 7 Q. Okay. After how long? 8 A. Probably after a year or two of me being 9 there. 10 Q. And that is you had no relationship with 11 your dad? 12 A. No, we weren't close — 13 Q. Okay. 14 A. --after that. 15 Q. So you, you had come from South Carolina 16 where you, you left your mom and your step dad with 17 whom you lived for ten years. 18 A. Uh-huh. 19 Q. Right? You came down and you began living 20 with your dad with whom you hadn't lived for ten 21 years since you were three years old. 22 A. Yes. 23 Q. Do you recall during the ten-year period 24 that you lived with your mom from three to 13 25 whether you had contact with your dad? Page 9: A. Yes. 1 2 Q. That is, what kinds of conduct were you 2 3 engaging with him at the same time that your mom was 3 4 observing that you were not as close to her and you 4 5 wore doing your own thing? 5 6 A. 1 would just be going out all the time, 6 7 drinking, tried drugs, stay out. 7 8 Q. And at that time; that is when your mom 8 9 was encouraging you to go with her to see Dr. In 9 10 what was your relationship with your birth father 10 11 with whom you were then living primarily like? 11 12 A. in the beginning it was weird. 12 13 Q. When you say, win the beginning," what do 13 14 you mean? 14 15 A. When 1 first moved with him in eighth grade. 15 16 Q. Okay. So that's, what did we decide that 16 17 was, 13? 17 18 A. Yeah, 12, 13. 18 19 Q Okay. So, 12 or 13 when you moved back 19 20 down here, it was you say weird, what do you mean by 20 21 that? 21 22 A. Just, I've never — you know, I don't remember 22 23 living with him when I was, you know, under the age of 23 24 three years old, and It was just awkward. I was used to 24 25 being with my mom. 25 Page 93 A. Yes. Q. Would you go visit him on weekends and things like that? A. When we were living in Florida, yes. Q. Okay. So, you came back. You lived with your dad, not having been there for ten years, it was weird. And then after a year or so you had really no relationship with him? MR. MERMEISTE1N: Form. THE WITNESS: Yeah. BY MR. LUTHER: Q. Now, you mentioned when you went to see this psychologist here in Florida over at the Greenville shops — A. Uh-huh. Q. -- that you told him about conflicts you had with your dad. Do you recall that testimony? A. Yes. Q. Okay. So, was this, this situation that existed between you and your dad after you came back from South Carolina part of the conflict that you discussed with him? A. Yes. Q. Okay. So, so what kind of conflict were you having with your father at the time that your 24 (Pages 90 to 93) PROSE COURT REPORTING AGENCY, INC. EFTA01076407 Page 94 1 mom had decided that it would be good for you to go 2 see Dr. a? 3 A. He just, he didn't approve of the things 1 was 4 doing. He didn't understand why I started failing out 5 of school and not doing good, and basically he would 6 just verbally abuse me. 7 Q. So, was that, was that conduct that 8 your — and the relationship you had with your 9 father part of what was contributing to the, what 10 you described as the depression that caused our mom 11 to say that she wanted you to go see Dr. MM? 12 MR. MERMELSTEIN: Form. 13 MR. LUTHER: Let me rephrase the 14 question. 15 BY MR. LUTHER: 16 Q. Was the, the conflict that you were having 17 with your dad, which you just described, 18 contributing to what you described as depression 19 that you had the summer that your mom took you to 20 see Dr... 21 MR. MERMELSTE1N: Form. 22 THE WITNESS: Was sane of the conflict? 23 BY MR. LUTHER: 24 Q. Yeah. 25 A. He was Page 96 1 And he would just, you know, say nasty things and... 2 Q. Okay. Tell, tell me what nasty things he 3 said. 4 A. He would tell me I would amount to nothing in 5 life, that I was a lazy fat pig, just things like that. 6 Q. What's the worst thing he ever said to 7 you? 8 A. Probably, you know, the lazy fat pig; I'm 9 going to amount to nothing. That's why Pm recalling 10 that. That's why I remember that because that's one of 11 the things that really hurt me. 12 Q. Were those comments made to you before you 13 went to see Dr. M? 14 A. 1,1don't, I don't recall. 1 don't know. I 15 don't recall. 16 Q. Do you know when those comments were made 17 to you? 18 A. When I was living with him in high school at 19 some point. I,1 think — I don't know. I can't 20 remember. 21. Q. Were these comments that he made to you 22 comments he made often? 23 A. I didn't see him that often. He was, he was 24 at work a lot. He worked a lot. He worked six days a 25 week. In the morning he was gone, and he wouldn't get Page 95 Q. Okay. And — A. Yeah, some of it. 3 Q. And you said he didn't understand when you 4 were, your grades were going down? 5 A. Yeah. 6 Q. And, and tell me a little bit about what 7 was happening with your grades. You were in the 8 eighth grade when you first came down? 9 A. Yeah, I was fine, you know, eighth, ninth, .0 tenth grade. 1 started — I'm not 100 percent sure when 11 my grades started going down, but if you look at, you 12 know, my scores and stuff, you could just see that 1 13 went downhill — 14 Q. Okay. So — 15 A. in high school. 16 Q. — your grades hadn't necessarily gone 17 down at the point in time you went to see Dr... 18 A. I don't recall. 19 Q. Okay. All right. What other conflict 21 with your dad did you have that you described to 21 this psychologist that you saw in Wellington? 22 A. My dal and I, he just, he would — you know, 23 he would — he was never an affectionate person, and he 24 just would say things out of being anger, you know, 25 being angry and angered at the situation that happened. Page 97 1 home at night until like 6 or 8:00. It was, he was just 2 never home a lot. We didn't have a relationship, and 3 Pm sorry, I forgot your question, 4 the corset question, what it was. 5 Q. Well, when you, when you lust came down 6 front South Carolina and began living with him, who 7 was in the household beside you and he? 8 A. When I first carne down, it wet just him, my 9 brother, and myself. 10 Q. aM ur brother, what's his name? 11 A. =. Doe No. 5. 12 Q. And how old was =I? 13 A. When I moved there, I'm not sure. 14 Q. How old is he now? 15 A. He's, he's 17. 16 Q. Okay. So he's, he's about six years or 17 five years younger than you? 18 A. Yeah. Yes. 19 Q. Okay. There was just the three of you. 20 And then did there come a time that someone else 21 joined the household? 22 A. Yes. 23 Q. Who was that? 24 A. 25 Q And about when was that? 25 (Pages 94 to 97) PROSE COURT REPORTING AGENCY, INC. EFTA01076408 Page 98 Page 100 1 A. Probably my sophomore 2 year. Q. And did you and 3 along when she moved in? 4 A. When she rust moved in, yes. ..And for how long did you and get along? 5 7 A. Probably maybe six months to a year. maybe. 9 Q. Did there come a time that the 9 relationship between you and began 10 to sour? 13. A. Yes. 12 Q. When was that? 13 A. When she just decided to tell my dad all these 14 negative things about me. 15 Q. And what did she tell your dad about you? 16 A. I don't know the specifics. !just heard that 17 she was talking about me to my father, my brother told 18 me, negatively. 19 Q. What, what did he tell you that 20 told your dad? 21 A. That she was just talking bad about me. That 22 I should, you know, go away to boot camp and things like 23 that. 24 Q. Well, I want you to give me -- 25 A. I don't get 1 you aslut? 2 A. Probably my junior year. But it... 3 Q. "But it," what? 4 A. I was just going to say, but it wasn't like 5 you are a slut. It was just in one of his letters he 6 left on my bed calling me, you know, a slut, pig, you T know, whatever. 8 Q. And why is it that you relate that to your 9 junior year? 10 A. Because that's when I recall that that's -- 11 that's — I don't know why. I'm pretty sure it was my 12 junior year. 13 Q. Is there some event that you recall? 14 A. I !mow it was in my the reason I say that 15 is because it was in my dad's recent house, which was 16 junior-senior year. I was living them. 17 Q. And which house was that? 18 A. The house in Olympia. 19 Q. Now, you, you say he left some letter for 20 you on your bed? 21 A. Yes. 22 Q. Do you still have the letter? 23 A. No. I threw it out when I saw it. 24 Q. So this, this would have been a bed that 25 you had at the house in Olympia? Page 99 Q. - as much specifics as can about what 1 2 your brother told you that was telling your 2 3 dad. 3 4 A. There was no — there was nothing he told me 4 5 that she specifically said besides that she, she thought 5 6 I should be sent away to school because I was a bad 6 7 child. He wouldn't tell me anything else because he 7 8 said he didn't remember. 8 9 Q. And do you recall when that, you were told 9 10 that that conversation happened? 10 11 A. 'think that was, I'm guessing, probably my 11 12 junior year, maybe. 12 13 Q. Did — were there other things that your 13 14 dad called you, derogatory names? 14 15 A. There's things that, I mean, right now I 15 16 don't, I don't remember anything else. 16 17 Q. Did he ever call you any derogatory names 17 18 that had sexual connotations sort of associated with 18 19 them? 19 21 A. I'm sorry. What? 20 21 Q. You know, a name that might really be 21 22 intended to reflect upon sexual conduct that you may 22 23 engage in or not engage in? 23 24 A. He called me a slut at one point. 24. 25 Q. Do you remember when your father called 25 Page it _ A. Yes. Q. You have your own room there? A. Yes. Q. Okay. And, and why did your dad leave you a letter on your bed? A. Because I didn't clean my room and he wasn't home. Q. And, and what did this letter say? A. He just called me a you need to clean your F-ing room; you're flunking out of school, you pig, slut, or whatever he called me..1 don't remember the exact letter. Q. Well, how did you react when you saw a letter such as that written to you by your own dad? A. It was hurtful. Q. Make you ay? A. I don't know. Q. Upset you? A. It upset me. Q. Had you done something that you thought warranted him characterizing you in this manner? A. No, he just — whenever he got mad at somebody including my brother, he's would just say any — he's called my brother a fagot for no reason. It's just names that he throws out there. PROSE COURT REPORTING 26 (Pages 98 to 101) AGENCY, INC. . EFTA01076409 Page 102 1 Q. Why — do you know why he was calling you 2 a slut? 3 A. No, it's just that's my father. He'll say 4 anything that sounds nasty. 5 Q. And he said you were flunking out of 6 school. Were you, in fact, did you get bad grades? 7 A. I was, I was doing bad. 8 Q. Had he left written messages to you on 9 other occasions? 10 A. Written? Not that I recall. 11 Q. Had he, had he given other messages to you 12 other than in writing on other occasions? 13 A. On my phone. 14 Q. What kind of messages? 15 A. Lae, just voicemail messages. 16 Q. What kind of voicemail messages would he 17 leave? 18 A. Get your ass home. 19 Q. That's how he would that's the kind of 20 message aleave to you? 21 A. Uh-huh. Yes. 22 Q. I mean, is that, is that — in, in your 23 view of the world, is that the way a father should 24 be treating his daughter? 25 A. No. Page 1 Q. So you never knew why? 2 A. Why she was going? 3 Q. Yes. 4 A. For herself? 5 Q. Right. 6 A. No. 7 Q. But the idea was she, she told you she was 8 going to go and she wanted to take you as well? 9 A. Yes. 10 Q. So you would both be seeing Dr. M' 11 A. We both she went previously, I guess for 12 herself. I don't know what the reason was. And then 13 she thought he was a good doctor to see, so she brought 14 me with her. 15 Q. Okay. So your mom, before she suggested 16 to you to go see M I had, herself, seen Dr... 17 A. Yes. 18 Q. On the occasion that she said that she 19 wanted to take you to see Dr. a she was going 20 to go see him for what would ve een her second 21 visit? 22 A. Yes. 23 Q. And you don't know why she went for either 24 visit? 25 A a With my visit, I know it was pertaining to me, Page 103 1 MR. MERMELSTEIN: Form. 2 BY MR. LIMIER: 3 Q. How did it make you feel when your dad 4 would leave you messages like that? 5 A. I would be angry. 6 Q. And how did you act out that anger? 7 A. I would just ignore him. 8 Q. Would that cause conflict between you and 9 him? 10 A. No, it was better that way. 11 .Anything else that IN leave, messages 12 that El leave for you on your voicemail? 13 A. That I would be grounded. I mean... 14 Q. Okay. Was there, there anything else that Ell? 15 you know of that caused your mom to that sot 16 she thought you should go see this Dr. 17 A. No, not that I recall. 18 Q. Did aavith her that you should go 19 see this Dr. 20 A. I don't remember if I agreed with her or if, 21 or if I disagreed with her. I don't — honestly, I 22 don't remember. 23 Q. And did she ever tell you why she was 24 going to see Dr. =7 25 A. No. Page 105 1 and she would talk about our relationship. 2 Q. All right. So, was her suggestion to you 3 that you and she go together to see Dr. =7 4 A. Yes. 5 Q. Okay. So the purpose of her going to 6 Dr. on the occasion that she suggested the two 7 of you go was about your relationship with her? 8 A. Yes. 9 Q. And did you, in fact, go see Dr. Mr) 10 A. Yes. 11 Q. Where is Dr. IMIS 12 A. In Memphis, irnessee. 13 MR. LUTTIER: Okay. I'm going to need to 14 take a break myself right now. Too much 15 coffee. 16 THE VIDEOGRAPHER: Going off the record at 17 10:27E. 18 (A Ref recess was held.) 19 MR. LUTHER: We're back on the record at MR. • 10:38 21 BY pmER. 20 22 Q. Okay. So, so did you eventually go with 23 your morn to see Dr. I.? 24 A. Yes. 25 Q. And for what -- do you remember what year 27 (Pages 102 to 105) PROSE COURT REPORTING AGENCY, INC. EFTA01076410 Page 106 Page 108 1 it was even? 2 A. It was probably the summer going into my 3 sophomore year. 4 Q. Okay. That makes it the summer oft, 5 '02? 6 A. Mink so. Yeah, l was, I was, it was my 7 freshman year, and it was probably — I'm, I'm guessing, 8 bee-mote it was during the summer — that it was the 9 summer going into my sophomore year. 10 Q. Okay. So, whatever that — however that 13. works out by age, what you do recall is you'd 12 finished your first year of high schooL 13 A. Yes. 14 Q. It was the summer after your first year of 15 high school. 16 A. Yes. 17 Q. Okay. And, and t think you told us 18 earlier, your chief complaint or the reason you were 19 going to see him was for depression? 20 A. It was depression and my mom and l's 21 relationship was not good anymore. 22 Q. Okay. And it's someplace in Memphis? 23 A. Yes. 24 2Sd did and for how long did you go see 25 Dr.MI? 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. I don't recall. Q. Your best recollection. A. Five or seven days. I don't — Q Okay. So it was a fairly lengthy period of time? A. Yes. Q. And you would golgrthr„ most of the day over to see this fellow, DS? A. Yes. Q. Would you see just Dr or did you see other people, too? A. Just him. Q. It was just you and your mom? A. Yes. And he would do us separately. Q. Not to be flipgistit what did you and your mom talk to Dr..11 about all day for five to seven days? MR. MERMELS1TIN: Form. THE WITNESS: It would be — he would ask me what my problems were in high school, how people treated me in high school friend-wise, friends that I had, things that I didn't like that friends did, my relationship with my mom, why it became the way it did, my stepfather, my father, things of that sort. Page 1C 1 A. It was -- we went there for about a week. 2 Q. Oh, this is like a facility you go to? 3 A. He had his oven office, but he also had like an 4 apartment available to his clients that they would stay 5 there and come to him daily for a week. 6 Q. So, is that what you and your mom did, you 7 stayed in some apartment that he provided? 8 A. Yes. 9 Q. And then during the day you would go to 10 his office? 11 A. Yes. 12 Q. And is he, is he a physician by himself, 13 or was there a group? 14 A. It was his family, his son I think worked for 15 him afro. 16 Q. And how — and when you went over to see 17 him, were you, were you going for 45 minutes a day 18 or was it longer than that? 19 A. It was longer than that. I don't recall 20 exactly how many hours it was, but it wasn't short 21 periods of time. 22 Q. Was it Bice an all-day thing? 23 A. Yeah, pretty much. 24 Q. Okay. So, you were there for, when you 25 say a week, you mean five days? Page 109 1 BY MR. LOFTIER: 2 Q. You gave him — would it be fair to say 3 you give him a comprehensive history of whatever had 4 occurred in your life up to that point in time? 5 A. Yes. 6 Q. Would you literally sit in his office for 7 five or six hours? 8 A. Probably. I'm not sure if it was five or six, 9 but around that time. 10 Q. Okay. And, and, and then if he was 11 meeting just with you, your mom would be off doing 12 something else? 13 A. Yes. 14 Q. And If he was meeting just with her, you 15 would be off doing something else? 16 A. I would be at the apartment. 17 Q. At the condo. So sometimes just one of 18 you would go over and see him? 19 A. Yes. 20 Q. Did you take any kind of tests? 21 A. I don't remember if I took tests, but I know I 22 did some homewodc and writing, and I would have to read 23 his chapters io his book 24 Q. Is it the same book that you have at your 25 house? 28 (Pages 106 to 109) PROSE COURT REPORTING AGENCY, INC. EFTA01076411 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 110 A. He gave me like three of them, but the only one I found was the one, and I don't remember if that was the book that I read or not. Q. Did you take all three back home? A. I took them with me, but I don't know where they've gone. Q. Well, obviously, one of them you kept. A. One of them I have, but the other, l don't know where the other two went. Q. And when you say you took them home, you brought them back to Wellington where you were living with your dad? A. Yes. Q. So you apparently kept one of them since then. A. Yes. I don't know where the other two have gone. Q. kept? A. No. I did when I was there. He gave me the assignments. Q. Would you read the whole book or... A. No, hejust made me read like a chapter. Q. So you never sat down and read the book cover to cover? Have you ever read this book that you Page 112 1 A I do not know if I- I Icon, I personally 2 don't have them. 3 Q. Do you know if yout mom has them? 4 A. I don't know. 5 Q. Have you ever asked her? 6 A. No. 7 Q. Did, did Dr. =give you any formal 8 diagnosis? 9 A. No. 10 Q. Did he recommend that you seek any further 11 treatment after you left him? 12 A. No, not that I recall. 13 Q. Did he come up with any solution to your 14 problems? 15 A. Not that I remember. 16 Q. Did you and your mom leave at the end of 17 this week feeling better about each other than you 18 did when you got there? 19 A. I didn't. I don't know if she did. 20 Q. Still were a little upset with her? 21 A. Yeah, 'just felt like he did nothing forme, 22 but... 23 Q. Okay. And, and what you told 24 though, whether it was in these writings or m his 25 notes, was the truth? Page 111 1 A. No. 2 Q. How about the other two that you don't 3 have anymore, did you read them cover to cover? 4 A. No. 5 Q. And you just don't know where the other 6 two went? 7 A. No. 8 Q. How about the work product that you 9 generated? You said you would get homework. You 10 had to read the chapters and you had to do some 11 other things. 12 A. Yes. 13 Q. Did you have to do writings? 14 A. Yes. 15 Q. In like, like a diary type of writing? 16 A. Not a diary. • Just like fights that my mom and 17 I have had, or fights that my father and I have had, and 18 what I feel about them. 19 Q. And what happened with those writings? 20 A. 'have no idea. 21 Q. Did you give them to him or did you keep 22 them? 23 A. I gave them to him. I don't recall if he gave 24 them back or not 25 Q. Do you know if you have them? Page 113 1 A. Yes. 2 Q. And you told him the things that had 3 happened to you in your life up to that point in 4 time that you felt were significant. 5 A. Yes. 6 Q. You mentioned that you told him something 7 about how you were treated in high school. 8 A. Yes. 9 Q. Do you recall what you told him about how 10 you were treated in high school? 11 A. When I was in South Carolina, you know, there 12 was girls there that wanted to cut my hair off and do 13 crazy things to me, and that was a word of mouth. 14 Q. What do you mean by "crazy things"? 15 A. Supposedly, this is what some kid told me in 16 school, that they were in a gang and they wanted to, you 17 !mow, cut my hair or kill me, butIdon't know if that 18 was accurate or not. 19 Q This is someone at the school that you 20 were attending in South Carolina told you that other 21 kids were saying that about you? 22 A. Yes, other girls. 23 Q. Or should I say other — did you say other 24 girl? 25 A. This was a guy that told me this, but it was IllA410.1..tiaberM SI 29 (Pages 110 to 113) PROSE COURT REPORTING AGENCY, INC. EFTA01076412 Page 114 Page 116 1 about a group of girls. Q. Okay. So a, a male fellow student at the 3 school in South Carolina told you that there were 4 girls at that school that wanted to do these bad 5 things to you? A. Yes. Q. And did you believe him when ire told you 3 these things? 9 A. i didn't know. I was a little bit scared for 10 my — you know, i didn't know why. You know, from what 11 he told me it was scary, but I didn't know if it was the 12 math or not. 13 Q. So, did you avoid interacting with these 14 girls? 15 A. Yeah. 16 Q. And did they ever do anything to you? 17 A. They would, you know, verbally curse me out, 18 and I would just sit there quietly and take it. 19 Q. Did they ever do anything to your hair? 20 A. No, they never physically did anything to me. 21 Q. How about did they do, you know, kind of 22 things like stick stuff in your hair? 23 A. No. 24 Q. Gum, things like that. 25 A. That was, that was in Fort Lauderdale. 1 Q. You say you told Dr. 2 that you had? 3 A. Yeah. 4 Q. Would these have been friends that you had 5 in Florida or friends that you had in South 6 Carolina? • 7 A. He was asking me about all my friends 8 throughout my life and good friends that have stuck by 9 me and friends that have done things to me, and those 10 girls, Fm not considering them friends, but just people 11 in my life. 12 Q. Okay. Other than going over to 13 Dr. ME office and meeting with him during this 14 one-week period, did you, did Lou do anything else 15 when you went to see Dr. I. in the summer of -- 16 between your ninth and tenth grade? 17 A. Did I do anything else? 18 cI Anything else as part of that visit to 19 Dr. MI other than going and sitting and talking 20 with him. 21 A. No,1 mean, just the books that he gave me and 22 the homework. That's basically it. 23 Q. Anybody else participate in that therapy, 24 for lack of a better term, besides you and your morn? 25 A. No. about friends Page 115 1 Q. Okay. Gum in your hair was in Fort 2 Lauderdale before you went to South Carolina? 3 A. That was when i was in middle school in Fort 4 Laudadak. 5 Q. Okay. 6 A. It was a trip to Orlando, and this girl wanted 7 to put gum in my hair. 8 Q. Okay. So these — how else were these 9 girls verbally abusive towards you? Did they call 10 you names or what? 11 A. They wouldn't call me names. They would just, 12 you know, tell me to turn the F around or just try to 13 intimidate me. 14 Q. And how would you react? 15 A. i would just stay quiet and turn around. 16 Q. And within — was that part of the reason 17 why you left South Carolina? 18 A. That was one of the reasons, you know. Also 19 my stepfather was part of it 20 Q. Okay. This was upsetting to you to be 21 going to school and having these people do these 22 things? 23 A. Yes, it was upsetting. 24 Q. And you told this Dr. about that? 25 A. Yes. 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 117 Q. Did he recommend anything at all when you left there that you're aware of? A. That I'm — I don't know what he told my mother. He saw us separately at the end. But from what I'm aware of, i don't recall. I don't know if he did or not. I don't remember what he said to me because I just didn't feel like it helped. Q. When was the last time you had any communication with Dr. a? A. When I went That was — Q. Have you attempted to contact him at anytime since then? A. No. Q. Or contact his office? A. No. Q. Or get records from him? A. No. Q. Have you attempted to get copies of your records from the female psychologist you said you saw in Virginia? A. Records? Q. Right. You know, contact their office and . say, you know, give me your notes, your records, any documentation. A. I never got anybody's notes. 41103•11911iStibitIssOal•Mii....... 30 (Pages 114 to 117) PROSE COURT REPORTING AGENCY, INC. EFTA01076413 Page 118 1 Q. Did you get anything from her? 2 A. If I did, it might have -- I don't recall, but 3 it might have been to get a prescription or to transfer 4 a doctor or something I don't recall that. 5 Q Okay. Well, 1, I, I had more in mind. 6 Did, did you or anybody on your behalf contact them 7 and try to get whatever records they had about you? 8 A. Personally, I don't remember. 9 Q. How about contacting the female 10 psychiatrist you said you saw in Virginia, have you n done that and tried to get any records? 12 A. I don't remember. I don't think so. 13 Q. Have you attempted to contact — have you 14 had any contact with the female- 15 MR. LUITIER: Okay, whenever you have to 16 change, just tell me. 17 BY MR. LUTTLER: 18 Q. Have you made any attempt to contact the 19 female psychologist in Virginia since you, your last 20 visit with her? 21 A. Not that l remember. 22 Q. How about with the female psychologist in 23 Virginia, since your last visit her? 24 A. I don't remember. No, not that I remember. 25 Q. Have you attempted to contact in any 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 120 Q. I'm going to show you these copies. A. Okay. Q. I'll leave it up to your counsel. I don't, I don't know that we need to attach them, but I wanted to give these to you and give you a chance to look at them. Now, these necords, the, there's a cover letter there addressed to a Dr. A. Yes. Q. Do you know that physician to be -- by that I mean have you ever seen that physician? A. Yes, Ilmow that name. I just can't pronounce it Q. Who is she, or why did you go to her? A. I don't know if she — I don't know if she was the psychiatrist or the psychologist I went to. Q. Are you talldng now -- you earlier testi ficd that you saw a female psychologist and a female psychiatrist in Virginia. A. Yes. Q. There was, there was only one of each that you saw in the State of Virginia? A. I'm pretty sum, yes. Q. Okay. And you think this doctor is either Page 119 1 manner the male psychiatrist who you saw in Delray 2 Beach in Florida since you last saw him? 3 A. No. 4 Q. Tried to get his records or anything like 5 that? 6 A. No. 7 Q. Have you done any contact with the female 8 psychiatrist that you went to see in West Palm Beach 9 since you last saw her? 10 A. No. 11 g Tried to get her records? 12 A. No. 13 g Have you bad any contact with the 14 psychologist over in the Greenville shops since you 15 last visited with him? 16 A. No. 17 Q. And your last visit with him was about, 18 somewhere around June of '09? 19 A. Around that time. 20 Q. Did you have, have you tried to get his 21, records? 22 A. No. 23. Q. . I'm going to show you some records that we 24 • obtained. They came from your lawyer. 25 A. Okay. Page 121 1 a psychologist or a psychiatrist? 2 MR. MERMELSTEIN: Look at the reference. 3 BY MR. LITITIER: 4 g Yeah, feel free to look at them. And I'm 5 just going to — there's some office notes them, 6 and you'll see on the office notes, there's a 7 that came with these records that I got where it 8 says diagnosis, this is the one that says dermatitis 9 on it 10 A. Okay. 11 Q. See that, that page you're looking at 12 right there with the handwriting on it. Down at the 13 bottom left-hand corner it says, diagnosis, 14 dermatitis. 15 And I, and I also point out to you 16 that the physician's signature that appears on the 17 page containing the office notes dated 18 December 18th, '07, I, I I look at that and it 19 looks to me like it says somebody but, you 20 know, I couldn't swear to it 21 A. So, then this — 22 Q. Well, believe me, you're welcome to look 23 at all those records. And after you've looked at 24 them, then I want you to tell me if you can remember 25 who this Dr. is or what she was to you, that 31 (Pages 118 to 121) PROSE COURT REPORTING AGENCY, INC. EFTA01076414 Page 124 Page 122 1 is, you blow, why you saw her. 2 A. Is — if this was a prescription for the 3 dermatitis, then this isn't — this has to be probably 4 my PCM. 5 Q. Primary cam physician? 6 A. Yeah. Yes. 7 Q And now you're referring to the 8 prescription notice that's here that's dated 9 February I8th, '07? 10 A. Yeah, I don't know if this is a — 11 THE V1DEOGRAPHER: Excuse me, sir. We're 12 going to have to change the tape. 13 MR. LUTTIER: Okay. Go ahead. 14 THE VIDEOGRAPHER: Going off the record at 15 10:55 This marks the end of Tape I. 16 (A brief recess was held.) 17 THE VMEOGRAPHER: We're back on the 18 record at 10:57 ■ This marks the beginning 19 of Tape 2. 20 BY MR. LUTT1ER: 21 Q. Okay. You see these office notes, the 22 handwritten ones that include a prescription, that 23 they're all dated December 18th, 2007? 24 A. Yes. 25 Q. All right. This is -- these office notes 1 history was completed for? 2 A. This is myself, so... 3 Q. But, I mean, do you know what doctor you 4 were — is this, is this something you did for this 5 doctor that, that treated you for this dermatitis? 6 A. I'm guessing if the — I mean, this is — came 7 with the records. 8 Q. Okay. In your answers to interrogatories 9 the physician that you say you saw for dermatitis 10 was a 11 noticeoiiMtiv.t;nottr. And you at least 14 13 1. anSo this is a different physician you 12 at the top of the lab slip, it says saw the one that you referred to in your 15 answers to interrogatories? 16 A. Yeah, I guess so. 17 Q. And if you look at the handwritten office 18 notes the references to that are to facilities known 19 as 20 A Yes. 21 Q. So, is the — whoever's records these 22 are- 23 A. Yes. 24 Q. — that physician is not listed in these 25 answers to interrogatories? I Page 123 1 are not from your psych, the psychologist or 2 psychiatrist that you saw in Virginia; is that 3 coned? 4 A. Conect. 5 Q. And there's a cover page called, called 6 patient medical history. Was that completed by you? 7 Right there? 8 A. Yes. 9 Q. Is that your handwriting on there? 10 A. Yes. 11 Q. And 1 don't know, under the date it looks 12 like it says December 18th, '02. 13 A. Uh-huh. 14 Q. Was that, is that an accurate date or — 15 when you filled that out or is it... 16 A. It had to have been. 17 Q. Well, if you look down to the history, you 18 said where it says, explain, give dates and reasons 19 known. It said, had baby November 24th, '07. 20 A. Yes. 21 Q. All right. So, you — this is not a 22 record you completed in '02 then apparently, because 23 you had no way in '02 to say you had a baby in '07. 24 A. Oh, I guess not. 25 Q. Do you know who this patient medical PROSE COURT Page 125 1 MR. MERMELSTEIN: If I can interject here? 2 MR. unTIER: Sure. Oh, yeah. Help any 3 way you can. I'm happy to get an answer. 4 MR. MERMELSTEIN: This letter cant back in 5 response to the request made to 6 MR LUTHER: Right 7 8 can't pronounce that, but, but tsMi lle MR. MERMELSTEIN: — 1 9 conic back from her as indicated in the cover 10 letter with the initials there indicating it 11 was the same -- 12 MR. LUITIER: But as you can see, it 13 appears that these records are not signed kg 14 her. I don't know who they're signed by. 15 MR. MERMELSTEIN: But apparently, you 16 know, she had control of them. 17 BY MR. LUTHER: 18 Q. All right. Anyway, so am-trendy there is 19 another physician that's not listed on your answers 20 to intenogatories? 21 A. You're asking me that? 22 Q. Yeah. 23 A. Yes, I mean 24 Q. Okay. All right All right. Other than 25 the physicians you've now told me about today -- 32 (Pages 122 to 125) REPORTING AGENCY, INC. IIIIIIIIIIIIII EFTA01076415 Page 126 1 A. Yes. 2 Q. — and the physicians listed in your 3 answers to interrogatories that you provided in this 4 case, have you seen any other doctors at all in the 5 last five years? Well, let me put it — I don't 6 know. 7 Let me give you a date. Have you 8 seen any other doctors since January 1 of 2001? 9 A. Beside the ones, like, in front of me? 10 Q. Right In front of you meaning your 11 answers to interrogatories — 12 A. Yes. 13 Q. — and the other doctors we've identified 14 in this deposition. 15 A. Yeah. Not that I can remember, I mean... 16 Q. Just, just to be complete, because 17 trying to trick you. I realize you saw Dr. 18 right? 19 A. Yes. 21 Q. And you saw Dr. 1.1 21 A. Yes. 22 Q. So I know about those. 23 A. Yes. 24 Q. Other than the doctors that 25 are listed in your answers to interrogatories and Page 128 1 A. One of the doctors that I have given you the 2 names of where they're located. 3 Q. Okay. What doctor is she? 4 A. Well, she — do you know if she was a 5 psychiatrist or a psychologist? 6 Q. My information is that she's not a doctor. 7 She may be a certified nurse practitioner or 8 something. 9 A. So, then, I'm guessing that mail 10 prescribed one of my medications for 11 Q. Where is her office? 12 A. I, I've seen so many doctors 13 within the past couple of years for mental health that 14 honestly 1 cannot put a name with the face. I don't 15 know. 16 Q. Okay. Okay. Other than all 17 whoever she may be — you don't even know what state 18 she's in? 19 A. I'm guessing Virginia, but that might not be 20 accurate. 21 Q. Okay. Do, do you remember her enough to 22 know if she's somebody you selected for some reason? 23 A. If I selected her — the only doctor that was 24 selected out of, like, you know, somebody telling me or 25 referring is the, the male psychologist that I saw 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 • }fav o urer heard of the name 23 24 A. Yes. 25 Q. Page 127 the other doctors that you identified for the first time in today's deposition, are there any other doctors that you've seen since January of 2001? A. Any type of doctors, as in even my pregnancy, Q. Let's — yeah, I want to know about any time, any kind of doctors? A. Eye doctors, even like that? Q. Yep, if you've seen a doctor, I want to know who they are. A. Oh, my God. Q. But let's, let's, but let's start — let's break this down. Any other mental health doctor? By mental health doctor I mean a psychologist, a psychiatrist, a licensed social worker, because they're not technically a doctor, but any other mental health professional. A. No. Q. All right. Now discovered the name A. Page 129 1 there. 2 Q. Over in Wellington in the Greenview 3 plaza — 4 A. Yes. 5 Q. — or whatever it was? 6 A. Everything else was by the 7 they give on the Web si 8 Q. Okay. Now, Drt.ela that's a 9 psychiatrist that you saw with respect to the 10 lawsuit that you have pending against Mr. Epstein? 11 A. Yes. 12 Q. You were sent there by your lawyer? 13 A. Yes. 14 Q. You didn't pick him, somebody told you to 15 go see him? 16 A. Yes. 17 Q. And he hasn't rendered any treatment to 18 you; is that right? 19 A. Treatment, as in — 20 4 Therapy, go see him about — 21 A. No, no, nor 22 Q. He just did what's known as an evaluation 23 of you? 24 A. Yes. 25 Q. And so where did that evaluation take list that 33 (Pages 126 to 129) PROSE COURT REPORTING AGENCY, INC. EFTA01076416 Page 130 Page 132 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 place; that is, where did you set him? 2 A. That was in Miami. 3 Q. Okay. I mean is actually, his 4 office is in California someplace? 5 A. Yes. 6 Q. And so you went and met him in Miami? 7 A. Yes. 8 Q. How many times? A. Once. Q. Did you see him more than one time? A. No. Q. And how long was the visit in Miami? A. It was, it was morning to afternoon. I don't recall the times. Q. Okay. About, about a day? A. Not a day. Q. It was less than a day? A. Yeah, it was kss than a day. Q. Okay. I moan, four or five hours? A. I think it was more than that. Q. Okay. But it was, all happened in one day? A. Yes. Q. And, and did he have you do some tests? A. Yes. 1 about Dr.._t before you went there? 2 A. Yes. 3 Q. Who did you talk to? 4 A. My husband. 5 Q. Okay. And what did you and your husband 6 discuss? 7 A. That I had to see hint 8 Q. Okay. Did you talk about anything more? 9 A. Not that I recalL 10 Q. Did you tell your husband why you had to 11 sets him? 12 A. Yes. 13 Q. What did you tell him? 14 A. I had to see him for the lawsuit I was in. 15 it s Okay. So the only reason you went to 16 was because of this lawsuit that was pending? 17 A. Yes. 18 Q. And It's somebody your lawyers told you 19 you needed to go see? 20 A. Yes. 21 Q. And since you went down there one day, you 22 haven't seat him since? 23 A. Yes. 24 Q. Meaning that my statement is correct? 25 A. Yea Page 131 1 Q. Okay. And you completed those tests? 2 A. Yes. 3 Q. And they're all answered true and comet? 4 A- Yes. 5 Q. Did you have any discussions with anyone 6 about what you were to do when you went to see 7 Dr. before you went there? 8 MR. MERMELSTEIN: Form. 9 THE WITNESS: As in? 10 BY MR. LUTfIER: 11 Q. Did you talk to anybody about Dr. 12 before you went to see him? 13 MR. MERMELSTEIN: Other than your lawyer. 14 BY MR. LUTHER: 15 Q. Yeah, don't tell me what your lawyer said. 16 I assume — 17 A. Yeah. 18 Q. I assume somebod o sold you that you had an 19 appointment to see Dr. at some time and in 20 some place. 21 A. Yes. 22 Q. And I'm going to guess that came from your 23 lawyer's office, that part. 24 A. Yes. 25 Q. All right. Did you talk to anybody else 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 133 Q. Have you had any communication with him at all? A. No. Q. Have you ever seen any materials that were generated either by when you visited with him, such as test results? A. A. A. A. A. A. A. No. Answer sheets? No. Any reports that he's done? No. Any transcripts of anything that went on? No. Was it, was it videotaped? Yes. Have you seen the videotape? No. Have you reviewed any of that material? No. Did you review anything in preparation for your deposition today? And by review I mean did you look at anything to get ready for today's depo? A. As in? Q. Anything. A. Anything? salladaSMSCIIIIIIRINDeat 34 (Pages 130 to 133) PROSE COURT REPORTING AGENCY, INC. EFTA01076417 Page 134 1 Q. Yeah, anything. And I mean that in the 2 broadest sense. 3 A. Yes. 4 Q. What did you review? 5 A. I just went over that paper like with my jobs 6 and everything. 7 Q. Okay. What you're pointing at now are 8 your, your answers to interrogatories in this case? 9 A. Yes. 10 Q. And it, and would that be the answers to 11 your first set of answers to interrogatories that 12 are signed by you January 26th, '09? 13 A. rm pretty sure. I mean, I didn't go over the 14 material. I just had it on me and I looked through it 15 It wasn't like I sat there and, you know, read every 16 little page. 17 Q. What do you mean, you had it on you? 18 A. I had it and I looked at it 19 Q. Did somebody send it to you? 20 A. They sent it to me through the mail, I think. 21 Q. Okay. 22 A. Through the, through e-mail. 23 Q. They were e-mailed to you, your answers to 24 interrogatories? 25 A. Yes. Page 136 1 Q. — within the scope of reviewing. 2 A. I didn't look through every page, no. 3 Q. Did you look at the complaint in 4 preparation for your deposition? 5 A. No. 6 Q. Well, do you have a copy of your 7 complaint? 8 A. Not on me. I don't - 9 Q. Other than these answers to 10 interrogatories that you served — that were served 11 in January of '09, that consist of, I don't know, 12 ten or IS pages, is there any other piece of paper 13 you looked at in preparation for your deposition? 14 A. Something to be prepared for a deposition. 15 Q. What, say what? 16 A. To be prepared. 17 MR. MERMELSTEIN: That's what he's asking 18 you, what, what you reviewed. 19 BY MR. LUTTIER: 20 Q. Did you say you did look at something 21 else? 22 A. To be — yes. 23 Q. What did you look at? 24 A. To how to be prepared for your deposition. 25 Q. Oh, some kind of summary that says this is 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 135 Q. So that you could review them before your depo? A. Yes. Q. Okay. Anything else other than those answers to interrogatories that you reviewed? A. You have to give me a second to think about it. Q. Sure. A. Not that, I mean, that I could think of. Q. Okay. And did you only see one set of answers to interrogatories? A. I think that this is? Q. Right that's what that, that paper is there. A. I think so. Q. Did you review your -- the, what's known as the complaint that you filed in this case? That's the document where you made your allegations against Mr. Epstein. A. Did I like read through them? Q. Yeah, review the complaint. And I don't want to get hung up on semantics about what the word "review" means. I mean, if you looked at it as far as I'm concerned that is -- A. I, I didn't - 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 137 what you should do to get ready for your depo? A. Yes. Q. Probably from you lawyer that says, you know, this is what a depo — MR MERMELSTEIN: Don't talk about what it says. BY MR. LUTHER: Q. Okay. All right Something you got from Your lawyer? A. Yes. Q. But it was a generic thing? MR. MERMELSTEIN: Again, don't talk about what it says. MR. LIMIER: Strike that question. BY MR. LUTHER: Q. Any, any other piece of paper that you reviewed? A. Not that — I mean, to me these all look the same. Q. Okay. A. I mean, that's... Q. All right. So that's it. Your answers to interrogatories and something from your lawyer about preparing for the depo? A. Yeah, that's all I can remember. 35 (Pages 134 to 137) PROSE COURT REPORTING AGENCY,. INC. EFTA01076418 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 138 Q. Have you ever seen any police reports of any kind or nature that have anything to do with Mr. Epstein? A. Police reports? Q. Police reports. A. As in, like, on a piece of paper? Q. Well, a piece of paper, videotape or any other way. Have you ever seen any police reports? A. No. Q. Have you ever reviewed any police reports that concern Mr. Epstein or anybody that claims they went to Mr. Epstein? A. Reviewed any police reports? Q. Right. A. Like an actual police report? Q. Yeah. A. No. Q. Have you ever been told about any police reports by anybody, whether it's one of your friends, your lawyer or anybody else? A. No. MR. MERMELSTEIN: Obviously, don't talk about what your lawyer said. MR. LUTHER: Yeah, don't tell me what they said. 1-age 1 A. I don't recall. 2 Q. Well, was it somebody that had involvement 3 with Mr. Epstein? 4 A. Most Ificely, yes. Q. I mean otherwise why would this person 6 have - 7 A. Yeah. 8 Q. — any reason to bring to your attention, 9 Mr. Epstein? 10 A. Yes. 11 Q. So, so who of your friends had involvement 12 with Mr. Epstein? 13 A. I had — 14 THE WITNESS: Am I allowed to say this? 15 MR. MERMELSTEIN: The — 16 THE WITNESS: To tell this? 17 MR MERMELSTEIN: — the question was to 18 identify whatever friends had involvement with 19 Epstein. 20 THE WITNESS: So I can tell him? 21 MR. LUTTIER: Yeah. 22 THE WITNESS: I mean, I don't know if it 23 was allowed by — 24 MR. LUTHER: Yeah, you can give me the 25 names. Page 139 1 THE WITNESS: No, yeah. 2 BY MR. LUTHER: 3 Q. Are you aware that there was an 4 investigation by the, the Town of Palm Beach Police 5 Department? 6 A. Against Epstein? 7 Q. Yeah. 8 A. Yeah. 9 Q. How are you aware of that? 10 A. 'heard about it, I think, through somebody in 11 Virginia. 12 Q. Okay. And who would that be? 13 A. I don't recall who told me. It was one of my 14 friends from Florida. They told me that he had a — he 15 was being arrested or something along those lines. I 16 don't recall exactly what was said. 17 Q. Okay. So, so you — when you said it was 18 information you got in Virginia, you mean you were 19 in Virginia when this information was imparted to 20 you? 21 A. Yes. 22 Q. But it came from one of your friends in 23 Florida? 24 A. Yes. 25 Q. And what friend was that? 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 141 THE WITNESS: Okay. MR. MERMELSTEIN: . I, I'm not sure I understand why. THE WITNESS: I, I don't know. Just I didn't want you know, I don't know if I'm - I don't know. BY MR. LUTHER: Q. You were concerned about whether you can give me their names? A. Yes. Q. Yeah. MR. MERMELSTEIN: You mean in tams of confidentiality? THE WITNESS: Yeah. I didn't know. MR. MERMELSTEIN: Well, we've been taking care of that on the transcript. MR.. LUTHER: Right. MR. MERMELSTEIN: We'll use their initials for purposes of this or, or some other form to protect than. THE WITNESS: So just their initials, then? MR. MERMELSTEIN: No, no. You give the name — THE WITNESS: Okay. Okay. PROSE COURT REPORTING 36 (Pages 138 to 141) AGENCY, INC. EFTA01076419 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 142 MR. MERMELSTEIN: — and the court molter — THE WITNESS: Oh, okay. MR. MERMELSTEIN: — will put the initials. THE WITNESS: All fm not used to this, so. There is M., M. BY MR. LUTTIER: Q. M. what? A E. . There was M. and M. Q. ? A. (Witness spells first name.) Q. (Mr. Luttier spells first name.) What's her last name? A. S. Q. (Mr. Luttier partially spells last name.) A. Yeah, (Witness spells last name.) I think. Q. Okay. Any other of your friends that have had involvement with Mr. Epstein? A Not that I'm aware of. Q. Was it one of these girls that called you when you were in Virginia and told you of Mr. Frtein? 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2.4 25 Page 143 1 A Yeah, I am guessing so. I just have to think 1 2 about it and remember who it was. 2 3 Q Were — which of these girls - were any 3 4 of these girls what you would consider to be your 4 5 best fricia 5 6 A. M. has been close to me. 6 7 Q. Still close to you? 7 8 A. I still talk to her, yes. 9 Q. When was the last time you talked to her? 9 10 A. Today. 10 11 Q. And when did you talk to her? 11 12 A. Pm actually staying at her house since I flew 12 13 down from Virginia. 13 14 Q. And she made a claim against Mr. Epstein, 14 15 right? 15 16 A. Yes. 16 17 Q. And what did she tell you about that? 17 18 A She didn't really tell me much about it. 18 19 Q. Well, my question is: What did she tell 19 20 you about it. 20 21 A. That she was going against Epstein. That's — 21 22 !mean — 22 23 Q. Well, she told you more. She told you 23 24 about what's happened to her claim, hasn't she? 24 25 MR. MERMELSTEN: Form. 25 Page 144 THE WITNESS: She just said it was, you know, she's done with it. I don't — I, all I, anti:now is like ifs, it's over with her. BY MR. LUTI1ER: Q. Well, would — I want you to tell me exactly what she told you about it — A. Exactly. Q. — quote, being over. A. She just said she's done. That's all she told me and she won't tell me anymore. Q. So you're, you're staying with her, right? A. Yes. Q. And how long have you been with her? A. I just got in — when did I get in? Wednesday she picked me up from the airport. Q So you've been here since Wednesday? A. Wednesday night. Q. Okay. And, and the only discussion you had with her about her claim with Mr. Epstein was you said she said it was over? A. Yes. Q. And she — did she tell you how it got resolved? A. No. Q. Did you ask her? Page a A I asked her. Q. What did she say in response to your question? A I can't tell you. Q. Okay. Did she, although she didn't tell you with specificity, did she say anything at all about how it was resolved? A. No. Q. Did she show you any paperwork? A. No. Q. Did you ask her anything more about this claim? A. No. Q. So, you — although this lady had a claim against the same person that you're making a claim against — A. Uh-huh. Q. — and you spent the night with her, the totality of your conversations with her about Mr. Epstein and her claim was a statement that she made to you that it was over? A. Yes. MR. MERMELSTEIN: Form. THE WITNESS: But that was before. I mean, that wasn't since I've been here. She ===== 37 (Pages 142 to 145) PROSE COURT REPORTING AGENCY, INC. EFTA01076420 Page 146 just told tne one day — you know, I asked her 2 and she just said it was over, but of course, 3 I'd asked her, what happened, and she won't 4 tell me. 5 BY MR. LUTHER: 6 Q. So, the conversation where she told you it 7 was over was a conversation that happened before you 8 flew down here? 9 A. Yes. 10 Q. All right. What — 11 A. We actually haven't spoke about anything that 12 happened with her since I've been here. 13 Q. All right. Since you got here Wednesday, 14 what conversations have you had with IS that, that 15 involved in any way, shape or form Mr. Epstein and 16 you and/or her? 17 A. I mean, she knows that I'm down here, you 18 know, for this, my case, but that's it. 19 Q. I want to know what conversations you've 20 had with her about that, that — 21 A. She knew I had to fly down here for my case. 22 I mean, that's — we, we don't get into that because we 23 know we're not really supposed to tell each other 24 things. 25 Q. Who told you you weren't supposed to tell Page 148 1 best friend? 2 A. She's a close friend. I mean, I have a lot of 3 close friends ifs, but, I mean, right now, yeah, we're 4 close. 5 Q. How long have you known M.? 6 A. Since I was in Fort Lauderdale. 7 Q. That goes back to — well, you were there 8 from age three, right? 9 A. No. No. 10 Q. Okay. When were you in Fort Lauderdale? 11 A. 'started, I was in Florida for my middle 12 school, sixth, seventh and eighth. 13 Q. Okay. This is somebody you've known since 14 sixth grade? 15 A. Around seventh. I mean, we weren't close in 16 middle school though. I just knew of her. 17 Q. And then you left Fort Lauderdale and went 18 to went to South Carolina and then you went to 19 Wellington? 20 A. Yes. 21 Q. Did you lose touch with her, or just did 22 you keep in touch with her? 23 A. I didn't — 'wasn't friends with her in Fort 24 Lauderdale. 25 Q. Okay. Page 147 1 each other things? 2 MR. MERMELSTEIN; Objection. Well - 3 MR. WITTER: Don't, if your lawyer's the 4 one that told you, just, just — you don't tell 5 me what they said. So did anybody other 6 than- 7 MR. MERMELSTEIN: Well, anyhow - MR. LUTTIES: Let me, let me rephrase it. 9 BY MR. LUMER: 10 Q. Did anybody other than your, than your 11 lawyer tell you you weren't allowed to talk to le. 12 about your claims? 13 A. No. 14 Q. All right. So es never told you that 15 she wasn't allowed to do that? 16 A. She just said she couldn't tell me. I don't 17. know why, but l'm assuming it's — the same goes for 18 both °flu. 19 Q. And did — do you know who M.'s lawyer 20 was? 21 A. No.. 22 Q. Did M . give you any papers to review 23 from her case? 24 A. No. 25 Q. You — would you characterize, as your 25 PROSE COURT REPORTING Page 149 1 A. I just knew of her. We had the same friends. 2 We weren't close or anything, so it wasn't like we 3 kept — I didn't really talk to her. 4 Q Did you, did you strike up your 5 acquaintance with her again at some point in time? 6 A. Yes. We — 7 Q. When was that? 9 A. When I moved with my father, her family 9 actually moved to the same neighborhood as we were 10 living in. And my friend f which was friends with 11 both of us, told me about it, and M. got my number and 12 we started talking, and that's how we became friends. 13 Q. Who would you say your best friend is? 14 A. Right now? 15 Q. Yeah. 16 A. My husband. 17 Q. Okay. I mean, of girlfriends who is your 18 best friend? 19 A. The Fm closest to right now is, is 20 Q. And M. has been your closest friend for 21 what period of time? 22 A. I mean, I have a group of close friends. I 23 mean, it's not been - we've been friends, I guess you 24 could say close friends, since she came down to Wellington. In Binks Forest we became close. 38 (Pages 146 to 149) AGENCY, INC. EFTA01076421 Page 150 1 THE COURT IMPORTER: In what? Pm sorry. 2 THE WITNESS: Wellington. 3 BY MR. LUTTIERt 4 Q. And that was when you were in high school? 5 A. Yes. 6 Q. So since ninth grade? 7 A. Yes. 8 Q. All right. So since you were in ninth 9 grade, you and she have been best friends? 10 A. Yes. 11 Q. Okay. And, and in foie I'll get into 12 more of this later, but isn't I N the person that 13 went with you when you first went to see 14 Mr. Epstein? 15 A. Yes. 16 Q. Is there anybody or strike that. When 17 was the last time you talked to 11? 18 A. I talked to U, she — the last time I 19 talked to her was in Virginia. 20 Q. That is you were in Virginia? 21 A. Yes. 22 Q. Where was she, down here? 23 A. Yes. 24 Q. Okay. When was that? 25 A. When I found out I was pregnant I told her 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 152 what she was doing with that. I don't know like when she was going or what she was doing or how many times she -- I have no idea. We didn't really — I ;mow she went. I don't know if it's because she mentioned it in high school. I don't know. Q. Well, you discussed the fact that she had a claim against Mr. Epstein with her, right? MR. MERMELSTEIN: Objection, foam BY MR. WITTER: Q. Have you discussed with her the fact that she has a claim against Mr. Epstein? A. She told me — when I was in Boca she told roc she did. Q. When were you in Boca? A. I'm guess — I think when I first came down here. I think when I first came down here from when my husband went on his deployment. Q. So this is, now we're talking about January of— would you say '09? I mean, I can't -- I— A- Yeah, it was - Q. Refresh my memory. I don't want to give you the wrong date. A. Yeah. January I came here, February. Q. Of '09? Page 151 1 because she's also pregnant 2 Q. Any other — what did, what did she tell 3 you? Is that what you were calling her for when you 4 were Virginia? 5 A. Yeah. 6 Q. What was your relationship with M? 7 A. We were close. 8 Q. Did she go to school with you? 9 A. Yes. 10 Q. From, all through high school? 11 A. No. I met her probably around my sophomore, 12 sophomore year, probably. 13 Q. Met her — did you meet her before you 14 went to Mr. Epstein's for the first time? 15 A. Yes, !think so. 16 Q. Did she ever go with you to Mr. Epstein's? 17 A. No. 18 Q. When did you first kam that she went to 19 Mr. Epstein's'? 20 A. We I, I don't, honestly I don't remember 21 when I, when I -- she told me she went there. I don't 22 remember that. 23 Q. Well, was it at or about the time that she 24 went, or was it a long time later? 25 A. I didn't really blow what she — I didn't Icnow 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 153 A. Yes. Q. Okay. A. And then I started school. Q. Okay. So this is something you learned for the first time, that she had a claim against Mr. Epstein in January of '09. Have I got that right? A. I don't know if it was January, but it was sometime when I moved here. Q. Was it before January of '09? A. No. Q. And this was many, many years after she had gone to see Mr. Epstein. A. What do you mean? Q. Well, I'm just — years after she actually went to see Mr. Epstein that you learned for the first time that she, she had a claim against him. A. Yes. Q. Okay. And it was years after you had gone to Mr. Epstein? A. Yes. Q. Okay. A. Before — can I take one more quick break? MR. LUTHER: Absolutely. THE WITNESS: Sony. I just -- 39 (Pages 150 to 153) PROSE COURT REPORTING AGENCY, INC. EFTA01076422 Page 154 1 ME VIDEOGRAPHEIt Going off the record at 2 3 (A brief recess was held.) 4 THE V1DEOGRAPHER: We're back on the 5 record at 11:4] 6 BY MR. LUT1TER: 7 Q. We were talking about U You said you 3 last talked to her while you were in Virginia. 9 A. Yes. 10 Q. Are you referring to the time period when 11 you were living in Virginia? 12 A. Sony. Yes. 13 Q. Are you still, you still living in 14 Virginia? 15 A. Yes, I'm back in Virginia. 16 Q. So when, when -gLve me the — what year 17 it was you last talked to 18 A. I just talked to her before I left to Florida 19 to tell her I was pregnant when I found out. 20 Q. As in pregnant right now? 21 A. Yes. 22 Q. So you talked to her in the last ten days? 23 A. Yes. 24 Q. And where were you when you talked to her? 25 A. In my house. 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 156, other than over the telephone? A. On Facebook. Q. And is she — you have a Facebook page or whatever it is you get these days? A. Yes. Q. Okay. And she's listed as one of your friends? A. Q. A. A. Q- A. A. Q. Q. A. Q. Y listed as one of your friends? a l listed as one of your friends? No. No? No. lila or a? is she one of your friends? Yes. And are you friends on all those people's pages that they are friends on yours? A. Yes. Q. Anybody else that's listed on your Facebook as, as — or designated on your Facebook as one of your friends that's, that has had any involvement with Mr. Epstein? Page 155 1 Q. In Virginia? 2 A. Yes. 3 Q. And why were you contacting within 4 the last ten days? 5 A. To tell her I was pregnant. 6 Q. So do you have some regular contact with 7 her? 8 A. Yes. 9 Q. With what degree of frequency do you 10 communicate with her? 11 A. It depends on how busy we both are in our 12 lives. But I mean, you {mow, we keep in contact once 13 every two weeks or twice a month, or I mean, k depends. 14 I mean we're close. 15 Q. And, and what — I would like you to tell 16 me everything that she's told you about any claim 17 she filed against Mr. Epstein. 18 A. She just said she had a lawyer and that was 19 the last I heard. I never really talked to her about 20 that. 21 Q. Okay. And what's the status of her claim 22 now? 23 A. I have no idea. I haven't talked to her about 24 that. 25 Q. Do you communicate with M. by any method Page 157 1 A. Not that I'm aware of. Just that I've told 2 you. 3 Q. What school, what high school did II go 4 to? 5 A. She went to Wellington and Palm Beach Central, 6 and then she moved to Broward. But I don't !mow what 7 school she went to there because we lost contact for a 8 little while. 9 Q. Well, did you and she go to school 10 together? 11 A. Yeah, in high school and middle school, but we 12 were friends in high school. 13 Q. And so you, you were a freshman together 14 in the same class? 15 A. Same class, no. Just in school to I ilOkay. And you both went to, to 18 A. Yes. I sAnd did you, did — you went to until when? 21 MR. MERMELSTEIN: Form. 22 THE WITNESS: 2005. It's 23 switched to the alternative scholoNli r 24 BY MR. WITTER: 25 Q. And when you switched to the altemath PROSE COURT II (Pages 154 to 157) REPORTING AGENCY, INC. . EFTA01076423 Page 158 1. school was INstilt at 2 A. I don't think so. I don't think so. 3 Q. She was -- was she in your same class? 4 A. No. 5 Q. Where was she in relationship to you? 6 A. When? 7 Q. Like was she a year ahead of you, a year 8 behind? 9 A. Oh, no, she was the same year as me. 10 Q. Okay. So she was -- when I say your same 11 class, I didn't mean the particular class. 12 A. Oh, same -- 13 Q. I mean the same level. 14 A. Yes, yes. 15 ii Okay. So, had she already lef . by the time you went to the alternate 17 school? 18 A. I, I don't recall, but Pm guessing she wasn't 19 there, 20 Q. Why are you guessing that? 21 A. Because we stopped being friends our senior 22 year and she moved away, and I don't remember when she 23 moved exactly. I don't know if it was before or after 24 the alternative school. 25 Q. And why did you and she stop being 1 2 3 4 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 160 up and then they got back together later on and got married. Q. &Ehat's )as maiden name? A. 1M Q. So, she - you knew her as l in NH school? A. In high school. Q. She didn't get married to IIII until sometime after? A. After high school. Q. Okay. Now, who told you that -- d your husband confum that he had sex with =7 A. Later on, yes. At first they both denied it. But this was in high school; this wasn't when we were married or dating. Q. I just want to make sure I've got these dates right. This would have been when she was A. Yes. Q. d's name is? A. les No. 5. Q. And you first had sex with Mr. Doe No.5. back in, what, the ninth grade? A. No, it was the summer going into ninth grade. Q. Oh, it was before you got to high school? 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 159 friends? A. Over a guy. Q. Who was that? A. My husband, Q. And what, why did you stop being friends over your husband? A. Because my husband and I, we were, we weren't dating but we were together, you know, friends hanging out, and then she started liking him. High school stuff. Q. Well, what do you mean by "stuff"? Did she have sexual relations with him? A. Yeah, she had sex with him. Q. How do you know that? A. Because I found out through other people. Q. And did you have sex with In's brother? A. Its brother? Q. Yeah. A. NB doesn't have a brother. Q. Is there a D. that... A. Oh, D. that's, that's her ex-husband. Q. You had sex with her ex-husband? A. No. When I was in high school I dated before. After I dated M. she started dating and then they stayed -- well, they broke Page 161 1 A. Uh-huh. 2 Q. Is when you're — it was right after you 3 got out of eighth grade? 4 A. Uh-huh. 5 THE COURT REPORTER: Is that a yes? 6 THE WITNESS: Yes. I'm sorry. 7 BY MR. LUTTIER: 8 Q. So that puts you at 13? 9 A. Thirteen, 14. 10 Q. I'm going to get this pinned down. 11 MR. MERMELSTEIN: Make, make sure you're, 12 you're clear. 13 BY MR. LUTHER: 14 Q. Yeah. Take your time. 15 A. The sinner I was 14. 16 Q. Are you sure about that? 17 A. No, I'm not positive. Thirteen. 18 Q. R was thirteen? 19 A. It was the stunner. It was -- 20 Q. It was when you were 13 years old before 21 you started high school, right? 22 A. It was the summer going into my high school 23 for the lust time. 24 Q. All right. So that would make you 13? 25 A. Thirteen. PROSE COURT REPORTING AGENCY, 41 (Pages 158 to 161) INC. EFTA01076424 Page 162 1 Q. Okay. And was he the first person that 2 you had been sexually active with? 3 A. Yes. 4 Q. And, in fact, he's, he's the individual 5 that you say you lost your virginity to, isn't it? 6 A. Yes. 7 Q. Now, when you say you lost your virginity, 8 you mean that was the first person that you had 9 sexual intercourse with? 10 A. Yeah. 11 Q. Had you had any kind of sexual contact 12 with anyone else before you had sexual intercourse 13 with Mr. Doe No. 5.? And by that, I mean, when 1 14 say •sexual contact," anything of a sexual -- 15 activity of a sexual nature short of actual 16 intercourse. So you — that would mean could be 17 oral sex, could be, you know, any kind of, of use of 18 body parts, anything short of actual intercourse. 19 A. Would you consider lensing or... Q. No, not kissing. I mean, you know, 21 anybody ever, any male before you actually lost your 22 virginity to !viz. Doe No. 5 at 13, for example, ever 23 rub any portion of your vagina with, you know, their 24 band, for example? 25 A. Not that I remember. 21 Page 164 1 other than your, one of your parents, I mean, before 2 you had your sex with Mr. Doe No. 5 at 13? 3 A. No. 4 Q. No, nobody had put their hands up under 5 your blouse and 6 A. Well - 7 Q. -- taken your bra off or anything like 8 that? 9 A. I mean, he felt of my breasts, yeah, 10 yes. 11 Q. Okay. 1 mean, with your bra, you mean 12 over your bra or under, took your bra off and -- 13 A. I don't remember. 14 Q. You don't remember that? 15 A. I don't remember if it was under my bra or 16 over my bra. 17 Q. How about putting his hand down in your 18 pants? 19 A. No. 20 Q. Anybody ever done that? 21 A. Before my husband before my 22 Q. Right. 23 A. With=, no. 24 Q. Okay. Now, before MI actually had 25 sexual Intercourse With you, had you and he engaged Page 163 1 Q. Any oral sex given by you to anyone before 2 you lost your virginity to Mr. Doe No. 5 at age 13? 3 A. Not that I recall, no. 4 Q: Well, would you recall that? 5 A. I'm sorry? 6 Q. Would you recall that? 7 MR. MERMELSTE1N: Form. 8 THE WITNESS: I'm, I'm thinking. You've 9 got to give me one second. 10 MR. LUTTIER: Sure. 11 THE WITNESS: We're going back. No, 1 12 don't think so. 13 BY MR. LUTTIER: 14 Q. In, in other words, it would not be 15 uncommon that prior to the time a girl has sexual 16 intercourse for the first time, she has engaged in 17 some sort of sexual activity short of actual 18 intercourse, whether you — I don't know how you 19 want to characterize it, but you know what I'm 20 talking about? 21 A. I mean even touching of the breasts? 22 Q. Yeah. 23 A. I mean in Fort Lauderdale, I mean he 24 touched my boob, I mean, but 1... 25 Q. Were you ever naked in front of a male, Page 165 1 in sexual activity, something short of actual 2 intercourse? 3 k Kissing. 4 Q. Okay. So your testimony is that there was 5 no kind of sexual contact, foreplay or anything like 6 that, with Mr. Doe No. 5 until the day you actually 7 had intercourse? 8 A. I mean, there was kissing and, I mean, we were 9 like on top of each other, but it wasn't — that I 10 heuQAuber, it was just — I mean, this is so personal 11 but I mean, I would be on top of him kissing and stuff. 12 It wasn't like he would touch me or anything. 13 Q. And you had never performed any sex act.on 14 him, whether it was masturbating him by hand or 15 anything Ince that? 16 A. No. 17 Q. Okay. AM right. So Mr. Doe No. 5, you, 18 you meet him, you have sex with him at 13? 9 A. Uh-huh, yes. 20 Q. Then were when did your friend, your 21 best friend .., have sex with him? 22 A. That was in high school. 23 Q. Okay. When? 2 4 A. My junior year. 25 Q. So that's -- would that be before or after 42 (Pages 162 to 165) PROSE COURT REPORTING AGENCY; INC. EFTA01076425 Page 166 Page 168 you saw Mr. Epstein? 2 A. That would be after. 3 Q. And when was the first time you were 4 suspicious that had had sex with your husband? A. When — I had suspicions just by the way they 6 were acting. But when I first figured out they had sex 7 or when I heard about it was from somebody in my class. 8 Q. And who was that? 9 A. Her name was =. 10 Q. Does she have a last name? 11 A. She does, but I don't know her last name. 13 A. Thati.and . had sex. Q. And what is it that told you? ll= 12 14 Q. Did she tell you how she knew? 15 A. She said that came over to her 16 boyfriend's house, boyfriend's house, and was 17 talking about how the condom broke with.. 18 Q. And did there come a time that you 19 confronted your husband about whether or not he had 20 had sex with..? 21 A. Yes. 22 Q. And when was that? 23 A. Right after I found out after school. 24 Q. And, and tell me how that conversation 25 went. 1 A. How many times did we have sex? 2 Q. Yeah. I mean, were you having sex 3 daily - 4 A. It was — - or weekly. 6 A. I mean, it was, you know, once or twice every 7 dine weeks, maybe. 8 Q. OW 9 A. A month. I mean, it wasn't... 10 Q. And, and LI want to make sure I 11 understand the terminology you're using When I 12 asked you if he was your boyfriend, you seemed to 13 indicate that wasn't true. 14 A. Yes. 15 Q. So having — you, you had sex with people 16 that weren't your boyfriend? 17 A. I wanted him to be my boyfriend, but he didn't 18 want to make a commitment to me. 19 Q. Well, were you, were you providing sexual 20 favors for him in order to get him to be your 21 boyfriend? 22 MR. MERMELSTEIN: Form. 23 THE WITNESS: No. I just — I really like 24 him and I wanted to be with him. And we just 25 had sex. Page 167 1 A. Well, it didn't go good. They both denied it 2 and they both were lying about it and said people were 3 making things up. 4 Q. Well, did you have this conversation with 5 them jointly or did you have a conversation with 6 them -- 7 A. No, jointl was after school, and I a started talking to and M. called over and 9 they were denying it to me. 10 Q. All right. And did you care at that point 11 in time? 12 A. I cared. Like it really pissed me off because 13 she was my best friend and I was like not dating him but 14 I was with him. 15 Q. And when you say "with him," he was like 16 your boyfriend at the time? 17 A. Not boy -- we were sexually active at the 18 time. 19 Q. Meaning you were having sex with him? 20 A. Yes. 21 Q. But you - I want to go over this. You 22 said at the time this occurred you were having sex 23 with, with the fellow that became your husband? 24 A. Yes. 25 Q. And with what degree of frequency? 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 169 BY MR. LUTTIER: Q. So at the time that this happened, in your junior year, for what period of time had you and he been sexually active? A. It started in my junior year. Q. Okay. So for six months or -- A. I mean, we started having sex again from when we took each other's virginity junior year, and then after I found out they had sex, I stopped talking to him. Q. Okay. Well, my question is: During this period of time — when did you recommence having sex with him after you had sex — A- My — Q. — with him when you were 13? MR. MERMELSTEIN: Objection, asked and answered. THE WITNESS: My junior year I had sex with him. BY MR. WITTER: Q. Yeah. I !mow, but I am trying to — A. And then — Q. Okay. A. And then we stopped. And then I started 25 having sex with him again my senior year. 43 (Pages 166 to 169) PROSE COURT REPORTING AGENCY, INC. EFTA01076426 Page 170 1 Q. I want to go back to the junior year, 2 because you told me that this confrontation that you • 3 had with he and happened in your junior year, 4 right 5 A. Yes. 6 Q. You said that at the time that there was 7 the confrontation, you and he were sexually active. 8 A. Yes. 9 Q. You told me when you were 13 you were 10 sexually active with him. 11 . A. Yet 12 Q. You had sex with him and both of you lost 13 your virginity. 14 A. Yes. 15 Q. Then there was a time — when was the next 16 time you and he had sex after the first time when 17 you lost your virginity? 18 A. The date? 19 Q. No, I mean 20 A. My junior year. 21 Q. — six months later. All right. So you 22 go from, from after your eighth grade — 23 A. Yes. 24 Q. — which was the first time. There's no 25 sex during your ninth-grade year. There's no sex Page 172 1 773E WITNESS: No, I was just comfortable 2 with him. 3 . • BY MR. LUTTD3R: 4 Q. Okay. Well, you were having sex with 5 other people, too, weren't you? 6 A. If I had a boyfriend at that time. 7 . Q. Well -- 8 A. I wouldn't be with both of them. But if I had 9 lace a break, like, if I me and my — a boyfriend 10 broke up, I would, you know, hang out with again 11 and, you know, we would have sex. 12 Between the first time you had sex with 13 =and when you renewed your sexual relationship 14 with him in your junior year, you had sex with a 15 number of boys, did you not? 16 A. Yet 17 Q. Okay. So you were having sex with in 18 your junior year. 19 A. Yes. 20 Q. You wanted him to be your boyfriend. 21 A. Yes. 22 Q. Did, did — were you, exclusively at that 23 time just having a relationship with him? 24 A. My Puler year? 25 Q. Yeah. Did you understand that to be an Page 171 1 during your tenth-grade year. 2 A. Right. 3 Q. So, it's at least two years. 4 A. Yes, we didn't like each other. 5 Q. Then in your junior year, did you start 6 having sex with him at the beginning of the year? 7 A. It was — I'm going to say it was, like, maybe 8 the middle of the year, I guess. 9 Q. Okay. So if you started in the middle of 10 the year, at the time you' had this confrontation 11 with he and you and he had been having sex 12 regularly for a period of months. 13 A. It would go off and on. 14 Q. Okay, but you had been off and on for a 15 period of months? 16 A. Yes. Like, it wouldn't be like we were 17 definitely together. We'd, you know, hang out for a 18 couple of days, and then if we had sex, we did, and we 19 wouldn't talk I mean, it was, it was a very confusing 20 relationship with him. 21 Q. But you, you were comfortable enough with 22 your sexuality that it was acceptable to you to have 23 sex with individuals who you didn't consider to be 24 your boyfriend? 25 MR. MERMELSTE1N: Form. 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 exclusive relationship, you and he? A. What do you mean by exclusive? Q. You two were the only two having — you thought he was just having sex with you and you were — A. That's — C). — just having sex with him? A. That's what I thought. He was just having sex with me. Q. Okay. And that was your understanding? A. Yes. Q. Okay. And then it came as a surprise to you when this perton told you that, that your best friend had sex with the fellow that you thought was the guy you were having an exclusive relationship with? A. Yes. I knew that there was something going on, but I didn't know it went to that level of sex with them. Q. And you asked them and they denied it? A. Constantly. Q. Did there come a time that husband admitted that • had sex with El. in your junior year or when you were having a sexual relationship with him? 44 (Pages 170 to 173) PROSE COURT REPORTING AGENCY, INC. EFTA01076427 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 174 A. I don't remember exactly when he told me. Q. What's your best estimate? A. Probably he accidentally admitted it to me over either the summer going into my senior year or the beginning of my senior year. Q. What do you mean, "he accidently admitted A. He slipped when he actually was drinking one night and told me that he had asked his mom to take him to get checked because the condom broke and he was scared that he might have something. And that's when I said, really, so you did have sex with Q. Let me guess, the rest of the conversation didn't go well. A. No, no, not really. Q. Were you a bit upset when — A. Well, I was upset. Q. — so you sort of cornered him into that or — A. No, I — he, he just came out and said that. I don't.. Q. And so what was your reaction when you — when he made these comments to you and you said, then you did have sex with A. I already knew from people telling me, you Page 176 BY MR. LUTTIER: 2 Q. Once a person lies to you, especially if 3 WS 8, aillEal, a man with whom you have had a 4 romantic relationship, once he lies to you, do you 5 ever trust him again? 6 MR. MERMELSIEIN: Form. 7 BY MR. LUTTIER: Q. Or Is there always that suspicion in the 9 back of your mind? 10 A. Yes, there's always a suspicion in the back of 11 my mind. 12 Q. Okay. Because he had made a specific 13 straight-out representation to you when you 14 confronted him that it didn't happen. 15 A. Yes. 16 MR. MERMELSTEIN: Form, asked and 17 answered. 18 BY MR. LUTTIER: 19 Q. Now, when she said she had to get, that he 20 had asked his mom to get him checked, had, did he 21 tell you if the reason he had to get checked was 22 because he had some kind of symptoms or something 23 that he was worried about? 24 A. No. He was just worried because the condom 25 broke. Page 175 know, throughout the rest of the year, you know, that 2 they knew and they found out. And my reaction, I mean, 3 I already 'mew it regardless if he admitted it or not 4 When he admitted it, I was just like he's just a liar 5 that didn't tell me the truth. I was upset. 6 Q. So certainly that caused you at that 7 point — did that cause you at that point to, to 8 have some level of distrust with him? 9 A. Yes. 10 Q. Because he had denied something that you 11 had specifically asked him about, right? 12 A. Yeah. 13 Q. You thought you and he had a, a romantic 14 relationship that was exclusive to the two of you. 15 A. Yes 16. Q. And then you found out he lied to you. 17 A. Yes. 18 Q. Do you think that contributed a little bit 19 to your, some of your marital problems down the 20 road? 21 MR. MERMELSTEIN: Pam. 22 THE WITNESS: It could. It, it could be 23 some of it. I mean, 'don't — I wish I knew 24 what caused our problems, but, I mean, that's 25 part of it. Page 177 1 Q. Well, what would he get checked for 2 because a condom broke? 3 A. I guess just berm CP you use a condom so much, 4 and if it breaks you just get scared. 5 Q. Well, that would be scared primarily of 6 pregnancy, right? 7 A. Well, that was one of the issues also that I 8 found out later. 9 Q. Well, he wasn't getting checked. He 10 wasn't worried about him being pregnant 11 A. No, but he was also getting checked just 12 because the penis touched the vagina and, you know, if, 13 you don't know what people have. 14 Q. Well, was there some issue about whether 15 M. had any kind of sexually transmitted disease? 16 A. No. 17 Q. Did he indicate to you that he had any 18 symptomatology that caused him to think that maybe 19 he should get checked? 20 A. No. 21 Q. When you — did there come a time that you 22 confronted II. about the fact that she had denied 23 that she had had sex with the, the fellow that 24 became your husband? 25 A. I confronted her, like I said, in the parking 45 (Pages 174 to 177 PROSE COURT REPORTING AGENCY, INC. EFTA01076428 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 178 lot with a They both denied it And at first I believed them, but then I had more people telling me that it was true. So I don't remember how this happened, but she ended up moving to Fort Lauderdale when, you know, I had enough people telling me that they actually did have sex, and I lost it on her, and she still denied it when she moved away. But after that I don't, I don't recall her ever -- me and her ever talking about it and admitting it. Q. Okay. What -- when did you first meet MI? A. O That was middle school. I met her at I think my middle school was called in Wellington, when I moved with my father. But I wasn't friends with her in middle school. I just knew of her. Q. When did you become friends with her? A. My freshman or sophomore year. I think it was my freshman. Q. And when did you first learn that she had been to Mr. Epstein's? A. She actually went with and I wont with in the car with them. That's the only time that I know of. Q. Okay. Let's talk about that. When did it 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 180 Q. Now, this is an event that happened over six years ago? A. Yeah, my sophomore year. Q. Would you agree with me that your memory about that event now is not precise? MR. MERMELSTEIN: Form. THE WITNESS: I remember pretty much what haPPened• BY MR. LUTTIER: Q. That's not my question. Would you wee with me that your memory about the incidents that happened in '03, specifically with respect to Mr. Epstein, is not precise? MR. MERMELSTEIN: Form. THE WITNESS: As in exactly what happened? BY MR. LUTTIER: Q. Yes. A. I remember pretty much what happened, yes. Q. Can you say with absolute certainty everything that happened? MR. MERMELSIEIN: Form. THE WITNESS: Every little, little detail, probably not. But everything that I remember, you know, I remember pretty much everything that — I mean, I know it's confusing. I'm Page 179 1 occur, in terms of time, when you and and - 2 went to Mr. Eain's? 3 A. Well, M. and I went first. Do you want to 4 know about the instance with la? MR. NIERMELSIEIN: That's what he asked 6 you. 7 MR. LUTTIER: Yeah. 8 THE WITNESS: Okay. The time frame? 9 BY MR. LUTT/ER: 10 Q. Yeah. 11 A. It was sophomore year. I was with IN and 12 M. and they wanted to go to the house, and I was in 13 the car with them. 14 Q. Okay. How, how were you able to identify 15 it was your sophomore year? 16 A. Because when I went, it was when my father 17 lived in Rinks Forest, and ! lived in Binks Forest for 18 my freshman and my sophomore year. 19 Q. Do you have any record which reflects when 20 you went to Mr. Epstein's house? 21. A. No. 22 Q. Do you know of the existence of any notes 23 that you kept or calendars or anything like that 24 where you recorded the information? 25 A. No. Page 181 1 sure there's little things that I don't 2 remember, but I remember the majority of what 3 hwertd 4 BY MR. LU'rITER: 5 Q. Well, you, you remember I asked you about 6 Dr. l= earlier? 7 .nes. 8 Q. You told me you told Dr. the truth? 9 A. Yes. 10 Q.. Whatever you told Dr. was the truth 11 when you said it? 12 A. Yes. 13 Q. You told Dr. yourself that you 't 14 couldn remember a of specifics about your 15 visits with Dr. — I mean, with Mr. Epstein, didn't 16 you? 17 MR. MERMELSTEIN: Form. 18 THE WITNESS: Which hand he used and 19 things like that; I don't seliamber specifics 20 like that. 21 BY MR. LUTTIER: 22 Q. Do you remember telling Dr. ME tir. 23 your recollection about what hap was? clea; 24 MR. MERMELSTEIN: Form. . 2 5 THE WITNESS: Did he say it in a different • 46 (Pages 178 to 181) PROSE COURT REPORTING AGENCY, INC. EFTA01076429 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 182 way, or did he say it just like you're saying it? BY MR. LIJITIER: Q. I'm, Pm just-- myation to you is: Do you recall telling Dr. that your recollection about events that occurred when you were at Dr. — I mean, Mr. Epstein's, wasn't clear? MR. MERMELSTEIN: Font. THE WITNESS: I don't remember telling him that but, !mean, I might have. BY MR. LUITIER: Q. Do you remember telling him that you couldn't remember certain things about what happened? A. Well, yeah. There's certain, like I just said there are certain things that I probably don't remember, but I remember the majority of it. Q. But there were significant things about your visits with Mr. Epstein that you couldn't recall; isn't that right? MR. MERMELSTEIN: Form, lack of foundation. THE WITNESS: But as in what? Like, you mean — Page 184 1 these are your words, "what hand he used". 2 A. I mean, if I don't remember, I don't know how 3 Pm supposed to tell you. 4 Q. Well, for example, you would admit that 5 you don't really recall specifically what clothes, 6 that is, which items of clothes you had on at the 7 time that you were at Mr. Epstein's, do you? 8 A. I don't remember exactly what I was wearing, 9 no. 10 Q. Well, you don't remember if you had, for 11 example, your bra on or you didn't have your bra on, 12 do you? 13 A. I took my bra off. 14 MR. MERMELSTEIN: Form. 15 BY MR. LUTHER: 16 Q. Do you remember telling Dr. that 17 you weren't sure whether you had your bra on or off? 18 A. Yes, and I remembered. 19 Q. So, you told Dr. 20 A. Yes. 21 Q. — a year ago when you saw him, right? 22 A. Yes. Was it a year? 23 Q. A year ago. Whenever it was. 24 A. Okay. 25 Q. Whenever that — okay. And you told him Page 163 1 BY MR. LUTTIER: 2 Q. Well, is there anything, anything that you 3 would consider to be a significant part of your 4 visits with Mr. Epstein that you admit you cannot 5 specifically recall? 6 A. In any way? 7 Q. In any way. 8 A. Yes. 9 Q. Okay. What significant events that would 10 have occurred when you visited Mr. Epstein do you 11 acknowledge that you do not have a specific 12 recollection about? 13 A. As in, like, which hand he used, I don't 14 remember. 15 Q. So you don't know what hand he used. 16 Anything else that you can — that you admit you 17 don't have a specific recollection about? 18 . A. You've got to give me a second. 19 I mean, exactly, you know, what was 20 on the walls, things like that, exactly what the 21 house looked liked. 22 Q. !want you to tell me things that you say 23 as you sit here today you acknowledge you don't have 24 a specific recollection about with respect to your 25 visits with Mr. Epstein. So far you've told me, and Page 185 1 the truth then, right? 2 A. Yes. 3 Q. So if you told Dr. a year ago that 4 you don't recall if you had your bra on or not, that 5 was a true statement when you made it to him. 6 MR. MERMELSTEIN: Form, lack of 7 foundation. 8 BY MR. LUTHER: 9 Q. Is that right? 10 A. Yes. 11 Q. All right. Are you now telling us that a 12 year later you now have a specific recollection? 13 A. Yes. 14 MR. MERMELSTEIN: Form, lack of 15 foundation. 16 BY MR. LUTHER: 17 Q. And is there something that clarified your 18 recollectionteen the last time you saw 19 Dr. Lim — which I believe was in '09, and 20 now? 21 A. !just thought about it. Things come back to 22 me. 23 Q. So six years later, what you couldn't 24 recall five years ago, or what you couldn't recall 1:appened, five yeas previousl1, s you noN. can 47 (Pages 182 to 185) PROSE COURT REPORTING AGENCY,. INC. EFTA01076430 Page 186 Page 188 1 recall? 2 MR. MERMELSTEIN: Form, lack of 3 foundation. 4 THE WITNESS: Yes. 5 BY MR. LU'TTIER: 6 Q. And is there anything that refreshed your 7 memory? 8 MR. MERMELSTEIN: Form, lack of 9 foundation. 10 THE WITNESS: It could have been that I 11 mean, I don't remember if I didn't remember 12 when I didn't tell him or if I was embarrassed 13 because I didn't tell him. I don't remember 14 exactly why I didn't tell him or it just 15 didn't, you know, hit me when I was talking 16 about it. 17 BY MR. LUMER: 18 Q. well, you, you, you told DE the 19 whole truth. That's what you told me, right? 20 A. Yes. 21 Q 111ere was all kinds of sluff you told 22 Dr. that you would ordinarily fmd to be 23 enibarrassing, wasn't there? 24 A. Yes, 25 Q. You told him about the most intimate 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 Q. Going over your case with whom? A. My attorneys. Q. Okay. So, your — MR MERMELSTEIN: And, of course, you kno not to talk about what you discussed with your attorneys. BY MR. LUTI1ER: Q. So, the refreshing of your memory comes as a result of communications with your lawyer? MR. MERMELSTEIN: Objection to form. Do not testify. Don't answer that question because it — BY MR. LIMIER: Q. Did you tallc — MR. to is — requires attorney-client privileged conununications. BY MR. LUTI1ER: Q. Have you talked to any of your girlfriends that went to see Mr. Epstein since you went to Dr. A Since I went to Dr. a Q. Yep. A. About the - about what happened at Epstein's house? Q. Page 187 1 details about your life, did you not? 2 A. Yes. 3 Q. So you didn't not tell Dr. 4 something because you were embarrassed, did you? 5 A. There was embarrassing things that, you know, 6 that went through my mind and stuff, and I mean, I told . 7 him a lot, yeah. 8 Q. Now, my question is specific. There is 9 nothing that you did not tell Dr. when you 10 met with him because you were embarrassed to tell 11 him, was there? 12 MR. MERMELSTEIN: Form. 13 113E WITNESS: No. 14 BY MR. LUTHER: 15 Q. Rephrase the question. Was there anything 16 that you did not tell Dr. =, when you met with 17 him, because you were embarrassed to tell him about 18 it? 19 A. No. 20 Q. Okay. &l een done anything since you 21 met with Dr. to refresh your recollection 22 about events that occurred when you were with 23 Mr. Epstein? 24 A. Just going over my case and thinking about 25 what I did. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 189 A. Not that I recall. Q. Did you for ever have any conversations with MI, for example, where you said, you know, wont, words to the effect of, you know, do you remember what happened and sort of discuss it or compare notes about it? A. I mean, we, we've talked about his house, but we didn't, like, discuss notes about it. Q. I mean, when you talked about what occurred when you were at his house, did you ever, from the, from the day you went to Mr. Epstein's until today, ever have a discussion with M. about what occurred when you and she were OW. Epstein's house? A. To since the day we went to his house? Q. Absolutely. A. Yes. Q. Okay. When was the first time you discussed it? A. Probably right after we left. Q. Well, you say "probably." Does that mean you're not sure? A. Most liltely right after we left. Q. Okay. Do you have a specific recollection of the conversation? 48 (Pages 186 to 189) PROSE COURT REPORTING AGENCY, INC._ EFTA01076431 Page 190 1 A. Just that we can't believe what just happened 2 to us. 3 Q. No. Let me — I want do this in, in 4 steps. Do you have a specific recollection of your 5 conversation with M.? 6 A. Parts of it, yes. 7 Q. Okay. Are there parts of it you don't 8 have a specific recollection about? 9 A. Yes. 10 Q. All right. So then you acknowledge there 11 were some things that you don't remember about your, 12 the events that transpired at Mr. Epstein's; is that 13 correct? 14 MR. MERMELSTEIN: Objection. You're prior 15 question was just about her conversation. 16 MR. LUTHER: Okay. Wait a minute. 17 Don't, don't speak. 18 BY MR. LUTTIER: 19 Q. We'll take it in two steps. There are, 20 there are sub-portions of the conversations you had 21 with ■. immediately after going to Mr. Epstein's 22 house with her that you don't recall; is that 23 correct? 24 A. As of right now, yes. 25 Q. All right. Would you agree with me 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 192 part of the year? A. Yes. Q. Year starts — your sophomore year would have started in approximately August of'02? A. Yes. '03? A. It ended? Q. Yeah. A. Yes. Q. Okay. So your bea recollection is you first heard of Mr. Epstein's name sometime between August of'02 and October of'02. You said it was the beginning of the year. A. Yeah. I mean, yeah Q. Let make:An:1TM clear. I'm not trying to put a date in your memory. When you said -- we've identified that your sophomore year started in August of'02 and ended in June of '03, right? A. Yes. Q. Okay. So when you said you first heard of Epstein's name in the beginning of your sophomore year — A Yes. And it concluded in approximately June of Page 191 1 there's also events that occurred when you and M. 2 went to see Mr. Epstein that you don't recall? 3 MR. MERMELSTEIN: Form, overbroad. 4 THE WITNESS: Today? 5 BY MR. LUTHER: 6 Q. Yes. 7 A. Yes. 8 Q. All right. All right. So what's your 9 best recollection of your discussion with ■. when 10 you and she went to Mr. Epstein's? 11 A. The story of what happened? 12 Q. Well, if you want us to — let's just 13 start — let me, let me back it up. 14 There came a point in time that you 15 heard something about somebody named Mr. Epstein; is 16 that right? 17 A. Correct. 18 Q. When did you full hear of Mr. Epstein? 19 A. It was in high school. 20 Q. When in high school? 21 A. I'm going to say my sophomore year. 22 Q. Okay. When in your sophomore year? 23 A. I'm approximating because I don't know the 24 exact date, but probably in the beginning. 25 Q. Okay. "Beginning" meaning in the first Page 193 1 Q. -- that would be sometime after August of 2 '02? 3 A. Yes. 4 Q. And when you said the beginning, what do 5 you mean, August, September, October, or... 6 A. I don't know which month. It was in the 7 beginning of the school year. 8 Q. Within the first couple months? 9 A. Probably. 10 Q. So August or September would be a fair 11 estimate? 12 A. Yes, I mean, I had, yes. 13 Q. Okay. So August or September of'02, what 14 is it you first hear about Mr. Epstein? 15 A. I don't know exactly what I heard. I just 16 heard something about, if you go to this man, Jeffrey 17 Epstein's house, and you give him a body massage, you 18 get $200. 19 Q. And in this first occasion that you heard 20 about it, was — did Mr. Epstein's name come up, or 21 were you just told, if you go to somebody's house 22 someplace you can get some money? 23 A. It was probably somebody's place; it wasn't 24 his specific name probably. 25 Q. Before you first went to Mr. Epstein's 49 (Pages 190 to 193) PROSE COURT REPORTING AGENCY, INC. EFTA01076432 8 9 10 11 12 13 14 15 16 17 18 19 2i 21 22 23 24 25 Page 194 1 house for the first time, did you know his name? 2 A. Before -- yes, before I went to his house. 3 Q. So, at some point before you went there 4 for the first time, you knew that you were going to 5 go see somebody named Jeffrey Epstein. 6 A. Correct. 7 Q. Do you recall when it was you first heard a his name? 9 A. No, l don't recall that. 10 Q. Do you know it if you heard his name in 11 the first conversation about making some money doing 12 a massage, or was it in a later conversation? Do 13 you understand my question? 14 A. I understand your question. I just — 15 Q. In other words, were you, did you 16 initially just hear, you know, nunor, for lack of a 17 better -- that you could go give somebody a massage 18 for $200, or was it you go give Mr. Epstein a 19 massage for $200? 20 A. I think it was somebody a massage. 21 Q. Okay. And, and did you understand where 22 it was going to be, what town? 23 A. No, I didn't have all the specifics on it. 24 Q. So, so your best recollection today is 25 sometime in August, September, October of '02, Page 196 1 or not — 2 A. Yes, l am. 3 Q. Just, if you're, if you're just 4 speculating and guessing, just, just — it would be 5 better to tell me you don't know. 6 A. Okay. 7 Q. All right. But if you, if you have a 8 specific recollection, tell me. 9 A. Okay. 10 Q. But if it's — if you just don't recall, 11 there's nothing wrong with just saying you don't 12 recall. 13 A. Okay. 14 Q. All right. So I want to be fair to you. 15 I don't want you to speculate. 16 A. Okay. 17 Q. What happened — what did you do after you 18 heard this conversation for the first time? 19 A. I believe I mentioned it to 21 Q. And what did you tell 21 A. That I was interested in going there, but I 22 warned her to come with me. 23 Q. Well, had when — do you recall 24 whether or not, you first mentioned it to., 25 5 had heard anything about it? Page 195 1 somebody told you that you could give somebody a 2 massage and get $200. 3 A. Yes. 4 Q. Is there anything more you can recall 5 about the first time you became aware of anything 6 that was related to Mr. Epstein? 7 A. With that conversation, with somebody telling me about — Q. Yeah, was that the first time you heard anything about any of it? A. Yes. Q. Okay. Anything else you can recall about the conversation? A. No. Q. Do you know who told you this? A. No. Q. Was it while you were at school that you heard this? A. Yes. Q. Okay. Do you know if the person that told you was someone that had done that? A. Most likely. Q. But you can't tell me? A. I don't know who it was, though. Q. So you're, you're sort of guessing whether Page 197 1 A. I don't recall. 2 Q. When did you form the opinion that you 3 wanted to follow up on this manor that you had 4 beard? 5 A. I don't {MOW who told me, but the person that 6 did tell me made it seem like it was just, you go there, 7 you give him a massage, you get $200. And to me $200,1 8 was hike, yeah, why not. 9 Q. And do you blow how long it was from the 10 time you first heard it that you approached • 11 about doing it? 12 A. I don't recall. I don't know. 13 Q. Okay. So you were — you — did you 14 approach anybody other than 5? 15 A. No. 16 Q. So you go to 5. and you tell her, I 17 heard this story that 1, we can go make $200 giving 18 somebody a massage? 19 A. Yes. 21 Q. Did you tell her anything more at that 21 time? 22 A. 23 Q. 24 A. 25 Q. That's all -- Did you know where it was going to be? No. Did you know it was going to be in Palm 50 (Pages 194 to 197) PROSE COURT REPORTING AGENCY, INC. EFTA01076433 Page 198 1 Beach? 2 A. No. I don't even know how 1 found out it was 3 in Palm Beach. It was — the person that told me about 4 it, I don't, I don't recall exactly what hmp_ened. But 5 somehow when I decided to go there, M, 6 Jeffrey Epstein's assistant, contacted me and was the 7 one that set up the reservations. 8 And after this, can I take, lb 9 sony, another break to use the restroom? 10 MR. LUTTIER: Sure. We might as well just 11 take a lunch break. 12 MR. MERMELSTEIN: Yeah. 13 THE VIDEOGRAPHER: Going off the record at 14 12:24 M. 15 (A luncheon recess was held.) 16 • • • • * 17 18 19 20 21 22 23 24 25 51 (Page 198) PROSE COURT REPORTING AGENCY, INC. EFTA01076434 Page 199 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME II OF II Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED DEPOSITION OF JANE DOE NO. 5 Friday, February 26, 2010 8:07 - 3:44 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1312 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (S01-061-976-2934) Electronically signed by cynthia hopkins (601.061-976-2934) Electronically signed by cynthia hopkins (601.051.976-2934) 1a30246a-bc9d-4107.90a14373e816de0d EFTA01076435 EFTA01076436 11 12 13 14 15 16 Page 200 APPEARANCE& 2 On behalf of the PlaintifE 3 STUART S. MERMELSTE1N, ESIIRE MIRINELSTEIN & HOROWITZ, 18205 Biscayne Boulevard Suite 2218 Marna, Ibrida 331 Phone: E-mail: On be,haif o • ROBERT D. CRII7ON, IR, ESQUIRE MARK T. LUTTLER. ESQUIRE 9 BURMAN, CR111014, LUTT1ER & COLEMAN,UP 303 Banyan Boulevard Suite 400 West Pallainda s • 33401 17 19 19 20 21 22 23 24 25 Phone: ALSO PRESENT: Sasdra Quimby, Vicieographer Visual Evidence, Incorporated 1 2 3 4 5 6 7 8 9 11 12 13 14 15 16 17 18 19 21 21 22 23 24 25 CONTINUED PROCEEDIN Page 202 GS / THE VIDEOGRAPHER: We're back on the record at I:38 BY MR. LUTTI Q. Okay. I want to go back over one of the issues that you mentioned and ask you a little bit more about it. Can you tell me where you were physically when you first heard about the opportunity to give a person a massage for the $200? A. I was in school. Q. Okay. Do you know— and you said you don't know who it is that told you. Do, do you know what your relationship with the person was that told you about this opportunity? A. I don't remember who the person was, so I don't recall if they were a friend of mine or we were in a group of people and somebody mentioned it I don't recall exactly what happened. Q. Do you know where you were at school when this conversation occurred? A. No. Q. Was there anyone else present when this unnamed person told you of this opportunity? 1 2 3 4 5 6 7 8 9 10 11 12 13 Page 201 INDEX EXAMINATION DIRECT CROSS REDIRECT CONTINUED EXAMINATION OF JANE DOE NO. 5 BY MR. CRITTON 200 14 NO EXHIBITS MARKED 15 16 17 18. 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 1 11 12 13 14 15 16 17 18 19 21 21 22 23 24 25 Page 203 A. Not that I remember. It could have been a group of people that were — you know, they mentioned it, or it could have been, you know, just one person. Q. Well, do you recall, when you first beard the nosy from this person, other people around and saying anything about it? A. No. Q. Do you recall if this person was addressing you alone or anybody else when the statements were made? A. I don't recall if — I don't recall, like, what happened exactly when they were telling me about it Q. What, what can you recall about the entirety of the conversation with this unnamed person? A. I just remember them telling me -- or it was — I don't — see, I don't remember the specifics, but I remember, you know, they said, you go to this guy's house, give him a massage for $200. Q. Did you — how did you respond to that statement? A. I thought about it. Q. So you didn't orally respond to the statement? 2 (Pages 200 to 203 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801-051-976-2934) Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1 a30246a-bc9d-4107-90a1-6373e816de0d EFTA01076437 Page 204 A. Not that I recall. 2 Q. You don't recall malting any statement at 3 all after that? 4 A. I don't recall that. 5 Q. What's the next thing that occurred when 6 you and this person were having this conversation? 7 A. I don't recall. I don't know. 8 Q. And do I understand your testimony to be 9 that you're not sure that these were the words that 10 were actually spoken? 11 A. I know those were the wants that were actually 12 spoken. That's all I knew of it, that it was a massage 13 for $200. 14 Q. So you have a specific recollection 15 somebody, who you don't recall, said to you at 16 school -- 17 A. 1Uh-huh, yes. 18 Q. — although you don't know if there was 19 anyone else present, that you could go to a person 20 and give him a massage and get $200. 21 A. Yes. 22 Q. Is there anything more you can recall 23 about the conversation? 24 A. No. 25 Q. Was there any name used? Page 206 1 the person, right? 2 A. I don't recall If I did. 3 Q. Okay. You —well, you didn't give this 4 person your phone number, did you? 5 A. The person I was speaking to? 6 Q. Right. 7 A. It could have been a friend of mine. I don't 8 remember the person specifically. I don't know if I 9 went back to that specific person and said I was 10 interested, you know, here's my number. I don't, I 11 don't know. 12 Q. What's the vety next thing you can recall 13 about your going to Mr. Epstein's after this 14 conversation with this unnamed person? 15 A. So you're asking what did 1— what was my 16 next step that I remember after this person told me 17 about — 18 Q. The very »eott — yeah, the very next thing 19 that you did that had anything to do with — 20 A. Even if it was days later? 21 Q. Whenever it was, ,.. kgituse that's going — 22 A. I remember I toldM. about it. 23 Q. Okay. That's the next thing that 24 happened? Nothing happened between this ag amed 1 25 person telling you of this and you talking toM.? Page 205 1 A. As in Jeffrey Epstein's name? 1 2 Q. Any name. 2 3 A. I don't recall. 3 4 Q. Do you recall — I mean, when you say you 4 5 don't recall, does that mean the name could have 5 6 been said, or you don't believe that a name was 6 7 said? 7 8 A. It could have been said. I don't remember. 8 9 Q. Did you, did you ask any questions in 9 10 response to this statement from this person? 10 11 A. I don't remember if I did. 11 12 Q. Was there any additional information given 12 13 to you by this person other than that there was an 13 14 opportunity to go to a person's house and give the 14 15 persona massage for $200? 15 16 MR.. MERMELSTEIN: Objection, asked and 16 17 answered. 17 18 THE WITNESS: All! recall is that this 18 19 person told me it was a $200 mmotss age. And 19 2. somehow, I don't remember, IIM contacted us 20 21 and made ttte — for us to go to his house and 21 22 do the massage. 22 23 BY MR. LIMIER: 23 24 Q. Okay. So, so now this person that said 24 25 these thin" fl i ous _anz e.sySteneecicto • 'I ' 25 .... Page 207 A. I don't 'litany, but I thinkI probably talkedreta e.cfirst before I decided to do the massage for $200. Q. Okay. And you talked to because she was your best friend at the time? A. Yes, we were close. Q. Any other reason why you, out of — THE VIDEOORAPHER: Excuse me, sir, which button did you push? I just got a text that this has been muted. MR. MERMELSTEIN: Oh great. THE VIDEOGRAPHER: Okay. I just got a text from my boss saying it's been muted. (Discussion off the record.) THE VIDEOGRAPHER: Let muga ahead and stop it. Going off the record at 3:45... Oh, Pm sorry, 1:45. (A brief recess was held.) THE VIDEIIRAPHER: We're back on the record at 1:50 MR. LUMER: All right. What was the last question? (The requested portion of the record was read by the reporter.) j 3 (Pages 204 to 207 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (601-051.976.2934) Electronically signed by Cynthia hopkins (601.051.976-2934) Electronically signed by Cynthia hopkins (601-051.976.2934) la30246a-bc9d-4107-90a1-6373e816de0d EFTA01076438 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 208 BY MR. LUTHER: Q. And I apologize if I asked this, because I lost my train of thought: How long was it between the time you first heard this and you talked to A. I said I didn't recall how long it was. It could have been a couple of days. I, I don't remember. Q. Could it have been weeks? A. It could have been. I don't remember specifically. Q. Did it take you this period of time before you &alai. to decide whether or not you were going to do this? A. I'm sorry. What did you say? Q. Did it take you that period of time between when you first heard it and talked tea. to make up your mind whether or not you wanted to do this? A. Yeah. Q. So, you had given this conscious thought? 20 A. I gave it a thought of, it was a massage for 21 $200. I was young, naive, and it was $200 in my pocket 22 fora massage. 23 Q. Had you ever given anybody a massage ever 24 in your life up to that point in time? 25 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 Page 210 it, but — Q. Okay. What is it that you recall that causes you to say that you know it was along those lines? A. What is it that I recall? Because I know she questioned it when I made that statement. She was curious about the situation. Q. And, and what did you tell her in response? A. I said, yeah, that's what I was told. Q. And did you tell her who had told you that? A. I don't remember. Q. Okay. A. !just, I mean, there's... Q. After the first time this unnamed person told you about this opportunity, did you ever have a conversation with that unnamed person again about it? A. Like I said weviously, I don't recall if I did, but someho got my number, so I'm guessing I might have went back to the same person that told me and said, yeah, I would like to do it and they probably gave them my number. I don't know. Honestly, I have -- I don't really remember. Page 209 1 A. With — you know, with my friends and stuff, 1 2 like but it wasn't, l wasn't a masseuse. 2 3 Q. Did you know anything about how much a 3 4 massage cost? 4 5 A. No. 5 6 Q. Did you ask anybody? 6 7 A. No. 7 8 Q. Did you ever make any inquiry about 8 9 anybody receiving $200, you know, the going rate, 9 10 for example, anything like that? 10 11 A. No, it sounded good. 11 12 Q. Okay. So, when you toldM., what was 12 13 her fast statement to you? 13 14 A. You've got to give roe a second. 14 15 I'm not 100 percent positive, but I think 15 16 it was something along the lines as of all we have 16 17 to do is give a massage for 200. That's it. 17 18 Q. That's, that's Alas.,. said to you? 18 19 A. Yes. 19 21 Q. Was it a statement or a question? 20 21. A. It was question. Like, you know, from what 21 22 I've heard, I was like, yeah. 22 23 Q. Okay. 23 24 A. And I don't know if it was exactly that, but I 24 25 know it was al the lines of ou blow 25 Page 211 Q. Well, you have no recollection at all about that; is that right? A. Yes, I flies)... Q. So you, you — this isn't a situation where you have -- you, you recall doing that, but you can't remember the exact words. You don't really have a recollection about whether you did that or not? A. As in what? Like, Ala? Q. That you went back to this person and said — A. Yeah, I don't know. I ;mow that contacted me. I don't know how. Q. Well, let me get over there. Did you have — do you have a specific recollection of giving your phone number to anybody with respect to this opportunity? A. I don't Q. All right. Did you, did — were you the person that took the next step insissing this series of events to occur, or didM. do something? A. I'm pretty sure I did it. Q. Okay. Now, isn't it afitgifiat you were the one that callginthis lady, =II? A. I called =? 4 (Pages 208 to 211) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla napkins (001.051-976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601-051-976.2934) la30246a-bc9d-4107-90a1-6373e816de0d EFTA01076439 Page 212 Q. Yeah. 2 A. I don't recall calling. I know I called to 3 get directions, stuff like that, but... 4 Q. My, my question — have you ever told 5 anybody that you were the one that called -t o 6 set up the, the massage? 7 MR. MERMELSIEIN: Form 8 THE WITNESS: No. 9 BY MR. LUTTIER: 10 Q. If you told someone that in the past, 11 would it have been accurate when you told them that? 12 MERMELSTEIN: Objection to form. 13 THE WITNESS: No. 14 BY MR. LUMER: 15 Q. In other words, you wouldn't have just 16 made it up, right? 17 MR. MERMELSTEIN: Objection to form, 18 foundation. 19 BY MR. LUTTIER: 20 Q. Would, would you have just made. 21 statement to the effect that you contacted 22 MR. MERMELSTEIN: Objection to onn. 23 THE WITNESS: No. 24 BY MR. LUTHER: 25 Q All right. Did you ever tell anyone that Page 214 1 A. I'm not 3 met with Dr. ou told him the absolute truth Q. Specifica*ou told me that when you 2 4 about everything; isn that right? 5 A. Yes. 6 You told me that when you met with 7 Dr. ou told him the absolute truth about 8 ng. 9 A. Yes. 10 . So if you made a statement to either 11 Dr. or Dr. allg ait was a true statement that 12 you to him; is right? 13 A. Yes. 14 Q. So, if you told Dr. a Dr. 15 that you and/or 1. call that=fime 16 you made the sta ement to them, i was true? 17 MR. MERMELSTEIN: FORD. 18 THE WITNESS: I didn't say that. 19 BY MR. LUTITER: 20 Q. Well, that's not my question. You, you 21 admit that if you made that statement to either 22 Dr. Moe Dr. a it was true when you made 23 the statement? 24 MR. MERMELSTEIN: Fonn. 25 THE WITNESS: If I made a statement to Page 213 1 it was either you or but one of the two of 2 you, that contacted 3 MR. MERMELSTEIN: Form. 4 THE WITNESS: I don't recall that 5 BY MR. LUTHER: 6 Q. If you did tell someone that in the past, 7 was it true when you made the statement? 8 MR. MERMELSTEIN: Font. 9 THE WITNESS: Say that one more time. 10 BY MR. LUMER: 11 Q.' If you did tell someone that in the past, 12 was it true when you made the statement to them? 13 MR. MERMELSTEIN: Form. 14 THE WITNESS: No, because I didn't. I 15 don't do that. 16 BY MR. LUTHER: 17 Q. Well, you would, you — if you made that 18 statement, you believed at the time you made the 19 statement that it was a true statement, did you not? 20 MR. MERMELSTEIN: Form. 21 IRE WITNESS: You're confusing me. I'm 22 confused. 23 BY MR. LUITlER: 24 Q. Well, I want to make sure you're clear 25 about this. 1 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 215 them? BY MR. LUTHER: Q. Yep. A. Yes, it would be true. Q. Okay. Now, you just said you didn't tell either one of those individuals that. How do you know that? A. Because I don't recall. All I recall is that she called me somehow. So why would I say that — Q. fact — A. — that I called them? Q. — of the matter is that you really don't know whether or not ou made that statement to gi Dr. or Dr. you're just guessing that you make the ement, aren't you? MR. MERMELSTEIN: Form. Your question calls for her to guess. THE WITNESS: I know I, I wouldn't make that statement berange Pm telling you what 1 feel, end what I feel is from what I remember, is I didn't call BY MR. L • Q. Would it be son of to cut to the chase, would it be a fair statement to say you really don't recall who called who? PROSE COURT REPORTING AGENCY 5 (Pages 212 to 215) INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1030246a-bad-4107-90a1-8373e816610d EFTA01076440 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 216 1 MR. MERMELSTEIN: Form. 2 THE WITNESS: I knovI know that I didn't 3 call her first. I didn't call arst. 4 BY MR. LUTHER: 5 Q. Well, if you, if you don't — what Pm 6 trying to find out is, is whether you have a 7 specific recollection or you're just concluding what 8 happened based upon your recollection of other events. Do you know what Pm saying? MR. MERMELSTEIN: Form. BY MR. LUTTIER: Q. In other words, you either know for a fact, you have a specific recollection of who called who, or you don't have a recollection, but you're, you're assuming that they called you, or whatever, from a different set of facts. A. No, l know they called me. Q. Okay. So if you know that they called yousa would you tell either Dr. or Dr. that you iliodrEgla lled ME MR. : Form, lack of foundation. MR. LUTHER: If you did. THE WITNESS: But I didn't. 1 that conversation? 2 A. From what I remember, it was when I can go to 3 the house to do the massage and how to get there. 4 Q. Well, wait a minute. I'm going to go take 5 this in steps. Do you, as you sit here today, have 6 a specific recollection of the conversation? 7 A. Yes, it was along those lines. 8 Q. No, I want to know. Can you tell me what 9 was said to you by this person on the other end of 10 the phone? 11 A. I can't tell you every little detail. 12 Q. Can you tell me what you said to this 3 person on the other end of the phone? 14 A. No. 15 Q. I want to know what -- when, when you 16 first got this phone call that you claim you got, 17 where were you? 18 A. I was probably at home. That's not -- 19 Q. And I don't want to know probably. Are 20 you saying you don't know? 21 A. I don't know. 22 Q. Okay. Fair enough. Do you remember how 23 long it was between the time you first heard of this 24 opportunity and when you allegedly got this call? 25 A. I don't blow. Page 218 1 Page 217 1 BY MR. LUTT1ER: 2 Q. Okay. Well, let's just assume for the 3 purpose of this question that you made that 4 statement Tell me why that would ever be possible 5 for ou to have to have made a statement to either 6 Dr. or Dr. that you or. called 7 MR. MERMELSTEIN: Form, lack of 9 foundation 10 THE WITNESS: I don't, I don't — I'm, Pm 11 getting confused because you're asking me a 12 question which I don't — I didn't make a 13 statement about that, so how can I answer that? 14 BY MR. LUTTIER: 15 Q. Okay. Now, do you have a specific 16 recollection of a phone conversation that you 17 personally had with this person you say is M? 19 Q. 'ever you say im is. 18 A. Epstein's assistant? 20 A. I . , Epstein's assistant, that got the girls 21 to come there? 22 Q. I don't know who it is. You said there 23 was somebody named that called you. 24 A. Yeah, there's a 25 ' 9. Do you have a spec] c recollection of Page 219 1 Q. Do you remember on what phone you received 2 this alleged call? 3 A. It was most likely my cellphone. 4 Q. Doyou know specifically? 5 A Yes, because I wouldn't give them my house 6 phone. 7 Q. Why not? 8 A. Because my cellphone is on me at all times end 9 I was never home. 10 Q. Are you, are you certain — are you 11 guessing that you didn't give your home phone 12 because you carry your cellphone, or do you know for 13 a fact? 14 A. Well, l know fora fact that's what the 15 phone I use all the time. 16 Q. And what— how did this person that 17 called, how did they introduce themselves to you? 18 A. She said her name, hello, I'm =. I work 19 for Jeffrey Epstein. And then I In: rdru were 20 interested in the massage, and it went along those 21 lines. I don't know the exact conversation. This 22 was — you know, it was a while ago for the phone call. 23 Q. Six, seven years ago? 24 A. Yes. 25 Q. And did this eaytIleir name was PROSE COURT REPORTING 6 (Pages 216 to 219) AGENCY; INC. Electronically signed by cynthia hopkins (601-061.976-2934) Electronically signed by cynthia hopkins (601.061.976-2934) Electronically signed by cynthia hopkins (601-061.976.2934) 1O024O-bc9d-4107-90a1-6373a 6dOd EFTA01076441 Page 220 1 a or did they tell you their full name? 2 A. 1 don't remember. 3 Q. And arc you sure they said they worked for 4 Jeffrey Epstein? 5 A. Pretty sure. 6 Q. Was that the first time you ever heard his 7 name? 8 A. I don't recall. 9 Q. Did you say anything to him (sic) like 10 who's Jeffrey Epstein? 11 MR. MERMELSTEIN: Form. 12 THE WITNESS: No, I don't — 13 BY MR. LUTHER: 14 Q. Have you ever in your life received a, 15 just a call out of the blue from somebody saying, 16 gee, would you like to come over and give me a 17 massage or give somebody a massage? 18 MR. MERMELSTEIN: Form. 19 THE WITNESS: No. 20 BY MR. LUTHER: 21 Q. So it was an unusual phone call? 22 A. No, because I discussed this with somebody 23 previously. 24 Q. Well, this was ■, right? 25 A. Well, in high school was when somebody told me Page 221 1 about the situation. So, like I'm saying, I'm not going 2 to give you facts when I don't know exactly when it was 3 when I spoke to the person, when — I, i can't give you 4 a fact of what happened if I gave, you know, them my 5 number when I don't remember that part. 6 Q. Okay. What did you say to this person in 7 response? a A. What person? 9 Q. Whoever it is you claim you had a 10 conversation with. 11 A. Like I said, l da* remember. 12 Q. So you can remember what they said to you, 13 but you have no recollection what you said to them; 14 is that right? 15 A. There's -- no. Mores things you're going to 16 ask me that fm going to remember and I'm not going to 17 remember. 18 Q. Well, let's what I'm going to get that 19 point — 20 A. Yeah. There's — 21 Q. — so that the jury understands. You can 22 remember what this person said to you, but you can't 23 remember what you said to than; is that right? 24 A. Yes. 25 l liow long did this conversation take? Page 222 1 A. Between me and this unknown person? 2 Q. Yeah. 3 A. I don't know. 4 Q. Do you recall what day of the week it was? 5 A. It was a school day. 6 Q. And how do you know that? 7 A. Because I was in school when I heard about it. 8 Q. I thought I asked you where you were when 9 you got the phone call, and you said you didn't 10 recall. 11 A. The phone call or when I talked to the unknown 12 person? 13 Q. No, when you, when you received the phone 14 call from this person. 15 MR. MERMELSTEIN: Well, you know, yintre 16 confusing her because shes already identified 17 the person she got the phoneys!l from as 18 The unknown person was the person she 19 'poke to. . MR. LUTTIER: No, no. Let me go back. 21 BY MR. LUTHER: 22 Q. You, you're the one, I believe, that made 23 a reference to a phone call from an unknown person. 24 The person — 25 MR. MERMELSTEIN: No, she said a Page 223 1 consistently. 2 BY MR. LUTTIER: 3 Q. The person that you talked to that you 4 claimed was unknown wasn't a person that you had a 5 phone call with, was it? 6 A. The person i had a phone call with was 7 Q. Right. So the only thing you can possibly 8 be talking about when you talked about a phone call 9 here, was this alleged call with M, right? 10 A. Yeah, -was — 11 Q. Didn't you tell me earlier you didn't know 12 where you were when you got that phone call? 13 A. No, I don't know where I was when I got the 14 phone call. 15 Q. So you don't know if you were at school or 16 not. 17 A. No. I — when I talked to the tuilmovm person, 18 I was at school. 19 Q. Well, I just asked you when you got the 20 phone call — • 21 A. From the unknown person. 22. Q. — and you said it vvas, it was during the 23 school week, right? 24 A. I must have miss I must have misunderstood 25 ou, because you said the nokociuni 7 (Pages 220 to 223) PROSE COURT REPORTING AGENCY INC.. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051-976-29341 la30246a-bc9d-4107-90a1-6373e816doOd EFTA01076442 Page 224 1 Q. All right. So let's go back. 2 A. Okay. 3 Q. Where were you, what, what day of the week 4 was it that yov ic lii. call from, from the person 5 that you say v li a 6 A. I don't recall. 7 Q. What time of day was it? 8 A. I don't know. 9 Q. So you don't know where you were, don't 10 know what time of day it was. Do you know how long 11 the conversation took? 12 A. It probably wasn't that long. 13 Q. Do you know v4tat was discussed other than 14 you say that identified who she was? 15 A. How long did it -- I'm sorry. 16 Q. What else did you discuss? What was said 17 other than the fact that sa she introduced 18 herself and said she sita. ? 19 A. She introduced herself and said, you're 20 interested in the massage. I said yes, and that was 21 basically -- I mean, I don't recall everything, but it 22 was very, it was about getting there to do the massage. 23 Q. Okay. Well, was there more to the 24 conversation? 25 A. Not that I recall. Page 226 1 A. Like, ever again? 2 Q. Ever. 3 A. Yes. She contacted me again to come back to 4 the house. 5 Q. When did she do that? 6 A. I think it was after the second time that I 7 went. 8 Q. After the second time you went. And the 9 second time is when you went with your friends? 10 A. Yes. 11 Q. Okay. And where did that conversation 12 occur? 13 A. She -- Ilmow it was at a house. I don't know 14 whose house it was because I remember sitting on the 15 floor doing my makeup. And she called and asked if I 16 wanted to come back or if I referred anybody to do the 17 massage. And I said, no. And — 18 Q. Go ahead. 19 A. I was — I blow I'm taking a lot of bathroom 20 breaks, but I have to use the restroom after. 21 Q. Okay. 22 A. You can ask a question and then I can go, 23 if... 24 Q. Okay. How die ever get your phone 25 number? Page 225 1 Q. Well, you just said that there was 2 something about getting there. What did that mean? 3 A. Getting to his house. 4 Q. So there -- in this conversation, first 5 conversation within, there must have been more 6 discussed. 7 A. Yeah. Like - 8 Q. Like, did you tell her anything? 9 A. About what? 10 Q. About anything that you can recall. 11 MR. MERMELSTEIN: Form. 12 THE WITNESS: No. 13 BY MR. LUTHER: 14 Q. Have you now told me every single thing 15 you can remember about the •t =rntion you had with 16 this person that you said was =? 17 A. Yeah. 18 Q. Is there anything in the world that would 19 refresh your memory? 20 A. Not at this point, no. 21 Q. Okay. When, when -- did you have any 22 dismission with this lady, after this phone 23 call that you say you had with her? 24 A. Any time? 25 tl. Yeah, • time. Page 227 1 A. I don't know for sure, but from what I think, 2 it's from the person that told me about them. And then 3 I most likely went back to them and said I was 4 interested. I don't know 100 percent. 5 Q. Do you have a recollection, specific 6 recollection of having a second conversation with 7 the person that first — 8 A. No. 9 Q. -- told you about this opportunity? 10 Do you want to take a bathroom break? 11 A. Yes. 12 .111VIDEOGRAPHER: Going off the record at 13 2 14 (A brief recess was held.) 15 THE VIDF L—I RAPIER: We're back on the 16 record at 2:14m. 17 BY MR. LISITIER: 18 Q. Okay. After you had this phone call with 19 on that you said identified herself as 20 illi swhat was the next thing you did with respect 21 to following up on this opportunity? 22 A. Like, how did I get there? 23 Q. No. Well, did you, u after you 24 got this call, did you contactla.? 25 A. I don't recall if I did. I 'bably did 8 (Pages 224 to 227) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.9762934) Electronically signed by cynthia hopkins (601-051-976-2934) 1830241kebeed-4107-90a1-6373e814deed EFTA01076443 Page 228 1 knowingthat I wanted her to go with me. 2 Q. Do ou recall anything specifically about 3 contactinglta.? 4 A. I don't remember specifically, but I'm, Pm 5 sure I told her because she ended up coming with me. 6 Q. Well, did you then have to contact her to 7 arrange a time that s d go? 8 I don't recall made a time and I told 9 It, or if I spoke . Isjan't recall. 10 Q. Well, if you spoke toM. tout 11 when she could go, did you then call= back and 12 tell her when you guys could come? 13 A. I would have had to, but I don't recall that. 14 Q. So you don't know which of those things 15 happened. You don't know the specifics about how 16 the meeting was scheduled? 17 A. Fvacrly. 18 44)What did fl ., dide. -- do you recall 19 what told you when you contacted her and said 20 you'd received a call from somebody about going and 21 doing this? 22 A. From — actually from -9 23 Q. When you got the — when you told.. 24 about it, what, what did she say to you? 25 A. I don't remember. Page 230 1. you? 2 A. Well, I got Epstein's address fromM, and 3 I took the taxi to his house. 4 Q,S1, when did you get Epstein's address 5 fro t? 6 A. It was either from the phone call that I had 7 with her the first time, or if I did call her back, I 8 don't recall. 9 Q. Well, then you must have made some notes 10 of a phone call that you had with her, right, in 11 order to write the address down? 12 A. Yeah. 13 Q. Well, do you recall making any notes? 14 A. !don't recall malting notes, but I know I have 15 a horrible memory, and if I had I had to have his 16 address in order to get the tail to go there. 17 QT j2do you know when you got the directions 18 from ? 19 A. No. 20 Q. Could hav iii in a second or third phone 21 conversation with ? 22 A. It could have been. 23 Q. And you would have contacted her, if 24 that's what occurred, to get the, the instructions 25 from her? I Page 229 1 Q. Do you remember where she was when you had 2 the cor ation with her about the call you got 3 from..? 4 A. No. 5 Q. Do you remember how long it was between 6 the time that called you and when you 7 contacted .9 8 A. No. 9 Q. Was it more than a day? 10 A. Probably not. 11 Q. You just don't know. 12 A. I don% know. I really don't. I don't 13 remember. 14 Q. But, but do you have — do you lieve 15 that what you did was you contacted..? 16 A. Yes. 17 Q. And you told her of your communication 18 with this person that you said, said they were 19 20 A. Yes. 21 Q. What's the next thing you recall happening 22 with respect to, to going to Mr. Epstein's? 23 A. The next thing I recall happening is getting 24 picked up in a taxi. 25 Q. How did, how did the taxi know to come get Page 231 1 A. Yes. 2 Q. Did you get anything from her other than 3 the address? 4 A. No. 5 Q. Did you know where it was? 6 A. She just said Palm Beach and she gave me the 7 address. 8 Q. All right. So, so, at some point in time 9 you contacted a cab company? 10 A. Yes. 11 Q. What cab company? 12 A. I have no idea. 13 Q. And, and where did this cab company pidc 14 you up? 15 A. At my father's house. 16 Q. And, and what time of clay did they pick 17 you up? 18 A. It was, it was during the day, but I don't 19 }mow what time it was. 20 Q. Well, was thls during the school day — 21 school week? 22 A. No. It couldn't have been. 23 Q. So you didn't go during the school week? 24 A. No. 25 Q. So that would mean it had to be either a 9 (Pages 228 to 231) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthie hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) la30246abekl-4107-90.14373•81eds0d EFTA01076444 Page 232 1 Saturday or Sunday-, is that right? 2 A. Probably. Yes — 3 Q. Do you know? 4 A. because it had to be because I didn't have 5 school, so it had to be a weekend or a day I didn't have 6 school. 7 Q. Is there any reason why you say you didn't 8 have school? 9 A. Because I didn't skip school my sophomore 10 year. 11 Q. Okay. All right. So you — was it a 12 Saturday or a Sunday? Do you know which of those? 13 A. No. 14 Q. Would you, would you have gone on Sunday? 15 A. I don't, I don't — I, I mean, it — as long 16 as I didn't have school, I didn't, it didn't matter to 17 me. 18 Q. Who selected the day that you. and the 19 time that to go, you or thi. person? 20 A. Nofl She had a schedule. 21. Q. Dicey. So,oiliou remegalsr if you 22 called the cab or, (sic) --a. called the 23 cab? 24 A. I don't m that. 25 Q. Where ..z wa. at the time you called the Page 233 1 cab? 2 A. She was with me at my Dad's house. 3 Q. So she was already at your Dad's house? 4 A. Yes. 5 Q. So, so at some point prior to the time the 6 cab, the cab got there, she had already come over to 7 your house. 8 A. Yes. 9 Q. Was she there for some other reason, or 10 had she come specifically because you and she 11 planned to go to Mr. Epstein's? 12 A. I don't recall exactly, but it was probably 13 because we were going to go give the massage. 14 Q. Do you, do you 'mow whether she spent the 15 night the night before, for example? 16 A. I don't recall. 17 Q. Do you remember what she was wearing? 18 A. No. 19 Q. Okay. And your dad was living where at 20 this time? 21 A. In Binks Forest. 22 Q. So, a cab, a cab from some unknown cab 23 company comes and gets you — 24 A. Yes. 25 a - is that ri Page 234 1 A. Yes. 2 Q. All right. Did you or she have any money? 3 A. On us? No. 4 Q. Did you have any credit cards? 5 A. No. 6 Q. The cab driver say anything about how you 7 were going to pay for the cab faze? 8 A. No. 9 Q. Did you say anything to him? 10 A. No. 11 Q. Dicey. And, and you got in the cab, I 12 assume? 13 A. Yes. 14 Q. And who gave the cab driver instructions 15 on where to go? 16 A. I gave him the address. 17 Q. Did you tell him what the address was? 18 A. Yes. 19 Q. Okay. And he took you there? 20 A. Yes. 21 Q. And any recollection of but you don't 22 know what time of day this was? 23 A. It was during the day. I just don't know what 24 time it was. 25 Q. Well, do you know, was it in the rimming, Page 235 1 was it in the afternoon? 2 A. Maybe early afternoon, but that's — I mean 3 that's guessing. I don't know. 4 Q. Okay. Do you remember where this house 5 was? 6 A. As in, like, the exact street, or... 7 Q. That's fine. Do you lynx-other the abeet? 8 A. No. 9 Q Do you remember where — what town it was 10 in? 11 A. All I know, it was in Palm Beach on the water. 12 Q. All right. When you are you talking 13 about the ocean? 14 A. Yeah., I'm pretty sure it was the ocean, yeah. 15 Q. Okay. Do you remember how you got there? 16 A. Alexi 17 Q. Do you remember the route that you took? 18 A. No. I'm horrible with directions. 19 Q. All right Do you remember, did you, did 20 you go outside or were you able to view the ocean 21 from the house? 22 A. The second time. 23 Q. Okay. And the second time... 24 A. I didn't go upstairs the second time. 25 a. But, but were outside the house the 10 (Pages 232 to 235) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601.051-976.2934) Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 14302443a-be9d4107-9041413734816640d EFTA01076445 2 3 4 5 6 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 236 second time? A. I, I was in the kitchen, and that was a sliding glass door and you could see out back and he had the pool with the ocean. Q. Okay. So you, you were able to — at that time, you were able to observe the ocean from the house? A. Yes, but the first time I didn't. Q. Okay. All right. When you got there in the cab, how did you pay the cab driver? A. Jeffrey Epstein did. Q. Did he walk out of the house and pay the cab driver? A We went to the door, Jeffrey Epstein answered. He gave me the tnoney. it to the cab driver. The cab driver left and then =came and took us upstairs. Q. Is that the first time you had seen Mr. Epstein? A. Yes. Q. And what did — have you ever seen a picture of Mr. Epstein? A. Before that? Q. Yeah. A No. Page 238 1 A. I don't remember. I just paid the cab with 2 it. 3 Q. And did he — do you remember what the 4 denomination of currency was? 5 A. No. 6 Q. Did he answer — did you go up and ring a 7 doorbell? 8 A. I either knocked or rang the doorbell. 9 Q. Do you remember which? 10 A. No. 11 Q. Okay. And you say Mr. Epstein is the one 12 that answered the door? 13 A. Yes. 14 Q. What was he wearing? 15 A. Pm pretty sure he was the one that answered 16 the door. 17 Q. When you say you're pretty sure — 18 A. I'm pretty he answered the door. I 19 don't know if it was answered the door and 20 then got Jeffrey Epstein, or Jeffrey Epstein answered 21 the door. I, I don't remember. 22 Q. What was he wearing? 23 A. Like sweats, like -- 24 Q. What color? 25 A. Color? Page 237 1 Q. Have you seen a picture of Mr. Epstein 2 since then? 3 A. Since - and like, now, recently? 4 Q. Anytime since then, have you ever seen a 5 picture of Mr. Epstein? A. Yes. 7 Q. Where have you seen a picture of him? 8 A. Actually, I was watching MTV, and a show came 9 on about the richest men in the world, and his face 10 showed up one time. 11 Q. And when was that? 12 A. That was — I think that was one time in 13 Virginia. 14 Q. Within the last couple of years? 15 A. Yeah. 16 Q. Okay. So, Mr. Epstein gives you money 17 when you come to the door. you came to the door 18 out of the cab with you an ? 19 A I don't remember if stayed at the cab 20 while I got the money, or she came with me. I don't 21 recall that. I don't remember. 22 Q. But, but you recall Mr. Epstein handing 23 you some money? 24 A. Yes. 25 (),; 2lowmuckah did he give 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 239 Q. Ilh-huh. A. I don't know. Q. Did they have any writing on them? A. I have no idea. Q. Well, are you talking about a sweatsuit, top and bottom? A. The top, I don't remember, but I know he had, like, sweatpants on. Q. Okay. And he personally handed you some money. A, Yes. Q. And then you say you went out and paid the cab driver? A. Yes. Q. What did you do next? A. Then I came back to the door. Q. . Was Mr. Epstein standing there when you came back? • A. No. Q. Okay. And, and how did you know who this person was? A. She introduced herself. . Okay. What did she say to you? 11 (Pages 236 to 239) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051976-2934) la30246a-bc9d-4107-90a1-6373e816dead EFTA01076446 Page 240 1 A. Hello, I'm i spoke to you over the 2 phone. 3 Q. And what was she wearing? 4 A. I have no idea. Q. What did she look like? A. She was — I think she was light skin. 7 mean, this is — dirty blonde hair. I don't really recall exactly. 9 Q. But you're sure she had blonde hair, 10 right? 11 A. I'm not sure. I'm not going to say I'm sure 12 because the image I'm getting now, it's like a dirty 13 blonde hair, but I don't, I don't recall exactly. 14 Q. Yeah. 15 A. So I'm not going to say definitely. 16 Q. Anything else that you remember about her? 17 Did she have any jewelry on? 18 A. I have no idea. 19 Q. Was — I think you already said you don't 20 remember what kind of — do you remember if she had 21. pants on, a dress on, shorts, any of that? 22 A. I have no idea. 23 Q. You don't remember anything about what she 24 was wearing? 25 A. No. Page 241 1 Q. How big a girl is she? 2 A. I — from what I remember, she was skinny. 3 Q. Skinny? 4 A. Tiny. 5 S All right. So, anyway, you, did — was 6 with you at that point in time? 7 A. Yes, because we got walked upstairs. 8 Q. Okay. And then what happened next? 9 A. She took us upstairs. 10 Q. Okay- 11 A: Into — it was upstairs through the bedroom to 12 the massage bathroom or — 13 Q. Okay. 14 A. — whatever it was. 15 Q. All right. And did you ever — where was 16 Mr. Epstein in this period of time? 17 A. He wasn't there yet. • 18 Q. Okay. And what was in this massage 19 bathroom that you described? 20 A. Anything that I remember? 21 Q. Yeah. 22 A. Well, when you first walk in the door, there 23 was a minor to the right, and like a counter. And 24 there was, like, massage lotions, and then there was a 25 massage bed in the middle. Page 242 1 And then to the left was like a little 2 couch area with, like, a picture. i don't remember 3 if the picture was of a naked woman, but 1 remember 4 there was -- I've seen a — I remember seeing a 5 picture of a naked woman in his house. 1 don't know 6 if it was that specific one. And then there was a, a shower like in front. Q. Okay. Was the — what color was the 9 couch? 10 A. I don't remember. 11 Q. Okay. What occurred next? 12 A. And then Jeffrey Epstein walked in and he 13 removed his sweats and got into the shower. 14 Q. Okay. At that point in time, when you say 15 his sweats, did he have a top and bottom on? 16 A. I'm pretty sure he had a top and bottom on. 17 Yeah, he had a top and bottom on. 18 Q. And this is what time of year? 19 A. What time of year? 20 Q. Fall, summer? 21 A. I don't know. I was in Florida, so Florida is 22 always hot. 23 Q. Okay. So he had — well, your 24 recollection is he had sweat tops on. 25 A. Sweat — !don't know if it was asweat top, Page 243 1 but it was like the sweatpants. 2 Q. Okay. So you don't know if he had a sweat 3 top on? 4 A. No. 5 Q. What, did he have a shirt on? 6 A. Yes. 7 Q. Okay. All right. So you say he took 8 he took the — whatever he had on, you say he took 9 off. 10 A. Fully. 11 Q. Did he have shoes on? 12 A. I don't know. 13 Q. At that time back when this happened 14 describe his hair. 15 A. His hair? 16 Q. Uh-huh. 17 A. All I remember, it was like salt and pepper. 18 Q. Okay. 19 A. That's al remember. 20 Q. Do you remember how long it was at that 21 time? 22 A. No. 23 Q. Okay. And what happened next? 24 A. He got in the shower. He got fully naked and 25 got into the shower and he told us to undress. PROSE COURT REPORTING 12 (Pages 240 to 243) AGENCY, INC. • Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601.051.976.2934) 1a30246a-bc9d-4107.90a1.6373e816de0d EFTA01076447 Page 244 1 Q. Well, what, what exact words did he use, 2 if you recall? 3 A. Take off your clothes. 4 Q. That's all he said? 5 A. From what I remember, yes. 6 Q. Did he say, take off your clothes, or did 7 he say something different than that? 8 A. No. It was take off your clothes or get 9 undressed. It was along those lines. 10 Q. Or did he say undress down to your panties 11 and bra? 12 A. It could have been that, too. 13 Q. Have you ever told anybody in the past 14 that what he said was, undress down to your panties 15 and bra? 16 A. Have I told anybody in the past that — 17 Q. Yep, that that's what Mr. Epstein said to 18 you. 19 A. Yes. 20 Q. Well, if you — and if you told them that 21 in the past, it was true at the time you told them 22 that? 23 A. Yes. 24 Q. That was your recollection of what had 25 occurred? 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 246 Q. Okay. A. His face. Q. Was it a full glass or just a partial glass? A. I don't remember. Q. Okay. And was there anybody else in the house at the time? A. In the house? Q. Yeah. A. I don't — = a n s w e r e d the door. Q. Okay. A. So, I don't know if she still was in the house. I don't recallaiggan, that all' saw was Jeffrey Epstein and MI Q. When you first carne in the house — A. Yes. Q. — did you either hear r anybody else other than Jeff Epstein and A. Not that I remember, no. Q. And when you walked up this stairway and you went into this mom, was the door open or closed? A. His bedroom door? Q. Whatever room you were in. A. Well, what do you mean, when we were walking 1 A. Yes. 2 Q. So today, as you sit here today, is that 3 your recollection of what he said, was undress to 4 your panties and bra? 5 A. To your panties. 6 Q. Well, did he say panties and bra, or did 7 he just say panties? 8 A. I'm pretty sure it was panties because our 9 bras were off 9 10 Q. Well, you don't — do you not recall? 10 11 A. I wouldn't just take off my bra for no reason. 11 12 Q. Do you not recall? 12 13 A. I do not recall him specifically saying, take 13 14 off your bra, but I'm 90 percent positive that he did 14 15 because I wouldn't have done that. 15 16 Q. Okay. Now, you're not — are you positive 16 17 that you — well, strike that. 17 18 When he first said vitalism he said about 18 19 undressing, what did you and M. do? 19 20 A. We looked at each other like what's going on, 20 21 but we undressed. 21 22 Q. Okay. Now, he's in the shower, right, 22 23 taking a shower? 23 24 A. Yeah, but it was glass. It was, like I 24 25 know it was Rtass because I could see his head. 25 Page 245 1 2 3 4 6 7 8 Page 247 into it? Q. Yeah, when you were up there in the room and he said, take, whatever you said, undress. A. Oh, the room we were in with the door. Q. Right A. Oh, it was closed. Q. Okay. Did — was the, was the door locked or unlocked? A. I have no idea. Q. What kind of door was it? A. I don't remember. Q. Okay. Did anything prevent you and II from walking right out of the same door that you came In? A. Fear. Q. Okay. But that was it, right? A. Yeah. Q. Nobody blocked your ability to exit? A. No. Q. When he said whatever he said about undressing, you could have said to him, wait, I don't want to do this, right? A. Yes, I could have. Q. Did you say anything at all to him in response to his request that you undress? 13 (Pages 244 to 247) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801-051-976-2934) Electronically signed by cynthia hopkins (601-061-9764934) Electronically signed by cynthia hopkins (601-051.976.2934) 1a30246a-bad-4107-9061-6373•816deOd EFTA01076448 7 8 io 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 248 A. No. 2 Q. Did you say anything to IM when he made 3 that statement to you? 4 A. I just looked at her vet): awkwardly. I didn't 5 say anything 6 Q. Did she say anything to you? A. Not that I remember. I don't remember. Q. Okay. So what did you and she do? A. We got undressed. Q. What do you mean by you got undressed? A. We took off our clothes to our panties. Q. Okay. Well, what were you wearing at the time? A_ I don't remember. Q. Did you have — I mean, do you remember anything about what you were wearing? A. As in my clothes that I had on — Q. Yeah. A. — before? I, I mean, I always wear jeans and a shirt, so I'm pretty positive I had jeans and a shirt on. Q. You're guessing that that's what you had on because you think that's what you usually wear? A. That's all I I don't wear shorts. I don't wear skirts, so it had to be jeans. Page 249 Q. Do you remember what kind of bra and 2 panties you had on? 3 A. The color or anything? 4 Q. Anything about them. 5 A. The only thing that I could imagine that I was 6 wearing on my bottoms -- bra I don't know -- my bottoms was either boy shorts or a thong. Q. Well, which was it? A. I don't know. Q. What's boy shore? A. The ones that don't Billy cover, but they cover half of your butt. Q. But you don't recall which it was you were wearing? A. No. Q. And you don't kind, recall what kind of bra you had on? A. No. Q. Did you ever go without a bra or back then did you ever go anywhere without a bra? A. No. Q. Did you have big breasts or small breasts? A. 1 have, I have small breasts. Q. Okay. So your recollection is that while Mr. Epstein is in the shower, you and without 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 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 250 ever saying a word to each other, take all of whatever clothes you have on, and the only thing you have on are whatever panties you have on? A. Yes. Q. And your recollection is that you got undressed when you were first requested to by Mr. Epstein? A. Yes. Q. And your recollection, as you sit here today is you're definite and you're sure that you took your bra off? A. Yes. Q. Same with,? A. Yes. Have you ever told anybody, including Dr. or Dr. M that you don't believe you took your ra off? MR. MERMELST'EIN: Form, foundation. THE WITNESS: I don't recall. BY MR. LUTTIER: believe you did not take your brIli Q. Did you, in fact, tell Dr. that you MR. MERMELSTEIN: Form. THE WITNESS: No. Page 251 BY MR. LIJTTIER: Q. You deny having told him that? A. I don't recall telling him I never took my bra off. Q. Okay. Well — A. I said, at the point I didn't. Q. Is — A. Like at a certain point, I didn't take my bra off. Q. Well, wait. I didn't understand your answer. A. At a certain point I didn't take my bra off. Q. Did you tell him that there was a point that you didn't take your bra off? A. I don't remember. You're — I'm confused. Q. Well, I don't want to confuse you. A. Well, I am. Q. You testified here that you have a specific recollection that upon the first request by Mr. Epstein, you and M., without saying a word to each other, took all ofrour clothes off except your panties, right? A. Yes. Q. Did you tell Dr. at any time that, in fact, you don't believe ybTrook your bra off? PROSE COURT REPORTING 14 (Pages 248 to 251) AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkIns (601-061.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1a30246abc9d4/07-90a1.6373s616ds0d EFTA01076449 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 252 MR. MERMELSTEIN: Foundation. THE WITNESS: I don't recall. BY MR. LUTITER: Q. If you told him that, it was true when you told him that, right? MR. MERMELSTEIN: Form. THE WITNESS: I don't, I don't know. BY MR. LUTTIER: Q. . Well, what do you mean, you don't know if what you told him was true? MR. MERMELSTEIN: Form. THE WITNESS: No, I know what I told him, everything I told him was true. BY MR. LUITIER: Q. Okay. So whatever you said to him, you'll live by that? A. Yes. MR. MERMELSTEIN: Form. BYNULLIMMER: Q. And if it's different than what you said today, y go — you, you believe that what you told Dr.". was the truth? A. But it's not different. MR. MERMELSTEIN: Form. Page 253 1 BY MR. LUTTIER: 2 Q. Well, okay. Well, whatever it is. 3 Whatever it is, it is, right? 4 MR. MERMELSTEIN: Form. 5 THE WITNESS: Yes. 6 BY MR. LUTTIER: 7 Q. Okay. And wiaayou, would you stand by 8. whatever you told Dr.M? 9 MR. MI3RMELSTEI&Eorm. 10 THE WITNESS: Dr...? 11 BY MR. LUITIER: 12 . Q. Yeah 13 A. That's the second one. Yes. 14 Q. Okay. And it if what you told Dr.. 15 is different than what you said today, would yolu 16 with — would you agree that what you told Dr. El 17 was the more accurate statement? 18 . MR. MERMELSTEIN: Form. 19 THE WITNESS: Hold mg truth. 20 BY MR. LUTTIER: 21 t's not my question. If what you told 22 Dr. is different than what you said today, 23 would you agreetisthe more accurate statement is 24 what you told Dr. 25 MR. MERMELSTEIN: Form. Page 254 1 THE WITNESS: No. 2 BY MR. LUTITER: 3 Q. WelL you told him the trudi, right? 4 A. Yes. 5 Q. Well, what if what you told Dn. is 6 totally different than what you said today? thy. 7 would you, how would you justify that or explain 8 that? 9 MR. MERMEISTEIN: Form, lack of 10 foundation. 11 la WITNESS: You're saying what I told 12 Dr. is different than what I said today? 13 BY MR. LUTTIER: 14 Q. No. lossaying, if it nuns out that what 15 you told Dr.= is different than what you said 16 today, how, how do you justify the fact that you've 17 said two different things? 18 A. But I didn't. 19 Q. You're sum? 20 A. Yes. 21 Q. Well, let's assume, for purposes of this 22 question that yiyu did say something different: How 23 would you justify how it is today you would be 24 saying soothing different happened than what you 25 told Dr...? Page 255 1 MR. MERMELSTEIN: Form. 2 THE WITNESS: But I wouldn't. 3 BY MR. LUTTIER: 4 Q. No. I'm asking you what's known as a 5 hypothetical question which means I'm asking you, 6 for purpoo of this question, to assume what you 7 told Dr.= about this incident is different than 8 what you've testified to today. So, do you 9 understand what I mean by — 10 A. I — 11 Q. — a hypothetical question? 12 A. Yes, but — 13 Q. Well, wait a minute. Let me — I want to 14 make sure you understand this. 15 A. Okay. 16 Q. So you have to assume for the purposes of 17 the question I'm about to ask that that's the, 18 that's the true facts. It's a hypothetical. 19 A. Okay. 20 Q. Okay. Now, so assuming that those are the 21 do you explain that what you told 22 tits different than what you said today? 23 MR. MERMELSTEIN: Fenn. 24 BY MR. LUTTIER: 25 O. If you have an explanation. I 15 (Pages 252 to 255) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. . Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601.061-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) la30241a4x9d4107-90a14373•1116440d EFTA01076450 Page 256 1 A. But there — I don't, I don't, how can I make 2 an explanation of something that's not even true? 3 Q. So you can't explain any difference; is 4 that right? 5 A. Yes. 6 Q Okay. What kind of panties wash. 7 wearing? 8 A. I'm not sure. 9 Q. Did she have any on? 10 A. Yes. 11 Q. You don't know if it was a thong or 12 something else? 13 A. I don't recall. 14 Q. Don't know what color? 15 A. No. 16 Q. What kind of bra she had? 17 A. No. 18 Q. And while you guys were undressing, you 19 didn't say a single word to each other; is that 20 right? 21 A. Not that I recall. 22 Q. And you were perfectly comfortable just 23 taking all your clothes off down to your panties in 24 this stranger's house? 25 A. Not at all. Page 258 1 THE VIDEOGRAPHER: Excuse me, sit Sony 2 to interrupt. I'm going to have to change the 3 tape, now. 4 MR. LUTT1ER: Okay. 5 S. COURT: Going off the record at 2:37 6 This marks the end of Tape 2. 7 (A brief recess was held.) THE VIDIQQRAPHER: We're back on the 9 record at 2:3811.b. This marks the beginning 10 of Tape 3. 11 BY MR. LUTHER: 12 Q. Okay. I want to take this slow. You said 13 that he asked what you did and you told him you went 14 to school; is that right? 15 A. Yes. 16 Q. Did you tell him what school that you went 17 to? 18 A. I don't recall. 19 Q. Well — and what were the next words that 20 he spoke to you? 21 A. 1 don't remember the exact next words, but I 22 know that, you know, he told us he was a brain 23 scientist, and that — along the lines that he would 24 help us with our careers, and we told him our ages. 25 Q. Well, wait a minute. I want to go slow. 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 257 Q. But you didn't do anything about it? A. We were young. Q. My answer -- let me finish my questions: You didn't do anything about it? A. No. Q. All right. What happens next? A. He gets out of the shower with a towel. And he lays on his massage table face down with his towel over his butt. 5. was massaging his upper back, and I was massaging his leg, feet and legs. Q. Well, before we get to massaging him, did, did he speak more words to you after he got out of the shower? A. While he was laying on the bed? Q. At any time after he got out of the shower, did he speak any words to you? A. Yes. Q. What did he say? A. It's not exact but he asked, you know, what we did, and we told him we went to school. And something about he would help us with our careers, that he was a brain scientist. And we told him we were in high school and we did tell him our age. Q. How do you recall that you told him your Page 259 1 We're talking about the next, the next words he 2 spoke to you. You say you don't recall what they 3 were. 4 A. !recall words that he said, but I can't tell 5 you word by word. 6 Q. Where was he when he spoke these words to 7 you? 8 A. He was on the massage bed, face down. 9 Q. So he got out of the shower and walked to 10 the massage bed without saying anything, and then he 11 began to talk to you once he laid down on the 12 massage bed; is that right? 13 A. Yes. 14 Q. Okay. And you said something about 15 careers. Did you tell him something about your 16 career? 17 A. I personally d rtember that I did. 1 18 don't ber what . said to him. I don't recall 19 what M. was talking to him about 20 Q. gill, you're standing in the room right 21 next toM., right? 22 A. Yes, I was. 23 Q. You can recall what Mr. Epstein said, 24 but — 25 A. Yes — 16 (Pages 256 to 259) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) 1a30246a-bc9d-4107-90a1.6373e816de0d EFTA01076451 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 260 Q. — but you can't recall what . said. A. Correct. Q. And you can't recall what you said? A. Correct Q. Okay. And the fact of the matter is, you don't have a specific recollection of the conversation with Mr. Epstein, do you? A. Late, to the tee, the exact words? Q. Yeah. A. No. Q. You, you're just guessing what was said, aren't you? A. I'm not guessing. MR MERMELSTEIN: Objection to form BY MR. LUITIER: Q. You're not guessing? A. I'm not guessing. Q. What are you doing then if you're not guessing? A. I'm summing up things that he said from what I remember. Q. What, what you think was said? MR. MERMELSTEEN: Objection, form. THE WITNESS: What I heard him say. Page 262 1 undress and he was naked. That's when it all seemed 2 odd. 3 Q. Now, have you ever heard the phrase, "18 4 will get you 20?" Have you ever heard that phrase? 5 A. What is it? 6 Q. "Eighteen will get you 20? 7 A. No. 8 Q. Did it occur to you at any time that now 9 you say you were what, 16 years old at the time of 10 this? 11 A. Yeah, 15,16. 12 Q. All right. Did it ever occur to you that 13 this was kind of a strange setup, a strange sort of 14 circumstances? 15 A. It was very strange. 16 Q. You knew all along, as soon as he said 17 something about taking your clothes off, that it was 18 a bad idea, didn't you? 19 A. Yes. 20 Q. You knew you ought to get out of there, 21 didn't you? 22 A. Yes. 23 Q. Okay. All right. Did.you tell him, wait 24 a minute, I don't want to take my clothes off? 25 A. No. 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 261 BY MR. LUMER: Q. Okay. An right So what was the next thing you heard him say? A. That's all I i bo-mber when we were having the conversation through the massage. Q All he said was something about, you know, that he was a brain scientist and, and what school you went to? A. No, not what school we went to. We told him we were in high school. Q. Well, before I asked you something about the school, and didn't I ask you what school you said you went to? A. No. Q. If I did — A. You did ask me before, but no, we didn't tell him what school we went to. He didn't ask. Q And you said you told him your age. A. Yes. Q. And do you have a specific recollection of telling him your age? A. Yes. Q. Did it seem odd to you this guy would be asking what your age was? A. I, it seemed odd to me when he told us to 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 121 21 22 23 24 25 Page 263 Q. Did you tell him, wait a minute, I don't want to take my bra off? A. No. Q. Are you sure? A. Yes. Q. Did you tell him, I'm not comfortable taking my bra off? A. No. I don't — Q. Are you sure? A. Pm pretty positive. It's, I mean, it's not . 100 percent. I don't recall every little detail. Q. So you might have said it? A. I might have. I don't recall exactly. Q. And if you said it, that means you didn't take your bra off, doesn't it? A. No, but l did take my bra off. Q. Did you ever tell anybody that you told him you didn't feel comfortable taking your bra off? MR. MER/vIELS7EIN: Form. 1"HE WITNESS: I don't recall. BY MR. LUTHER: Q. Okay. All right. So did Mr. Epstein — what's the next thing you recall Mr. Epstein saying to you? A. Saying to me? I don't remember anything else 17 (Pages 260 to 263) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) 1a30246a-bc9d-4107-90a1.6373e816de0d EFTA01076452 Page 264 1 said, to be honest with you. 2 Q. At all? 3 A. Well, until he flipped over and started 4 touching himself. 5 Q. Okay. So, so you and.. began doing 6 what? 7 A. From when be flipped over? 8 Q. No, when you — you say he came and laid 9 down on the, on the, the massage table. You say he 10 put a towel on him? 11 A. He put a towel on his butt. 12 Q. Okay. And, and what color was that towel, 13 you said? 14 A. 1 never said that the towel was colored. 15 Q. What color was it? 3.6 A. I don't know. 17 Q. And what !dad of towel was it? Was it a 18 big bath towel, a small towel? 19 A. I don't recall. 20 Q. Okay. And, and your recollection is he 21 laid face down on the massage table? 22 A. Yes. 23 Q. Okay. And did, did he give you any 24 instruction about the massage? 25 A. I don't remember — Page 265 1 Q. So, so — 2 exactly. 3 Q And what did you and.. know to do? 4 A. Give him a massage. That was what, that's 5 what we were there for. 6 Q. But you had never given a massage before, 7 right? 8 A. Well, to my friends, but it wasn't — I'm not 9 a massage, you know, a massage therapist. 10 Q. So what did you, what part of his body did 11 you start rubbing? 12 A. Iris feet and his legs. 13 Q. And why did you decide, decide to do that? 14 A. Because it was the furthest away from him, so 15 that's where I went. 16 Q. Well, did he ask you to do that? 17 A. Not that I recall. 18 Q. Okay. And what did ■. do? 19 A. She massaged his back. 20 Q. And why did she start there? 21 A. Maybe because I took his feet and legs first 22 Q. Did he ask her to? 23 A. Not that 1 recall. 24 Q. Okay. So, for some period of time, you 25 began to massage him? /flirt.. Page 266 1 A. Yes. 2 Q. Did you say — speak any words toe. 3 during this? 4 A. No. 5 Q. And at the time that you're beginning this 6 massage, your testimony is you and she are standing 7 there in your panties. 8 A. Yes. 9 Q. Got no neither one of you have your 10 bras on. 11 A. Correct. 12 Q. Okay. And then what's the next thing you 13 recall happening? 14 A. The next thing I real' happening is he 15 flipped over and started touching himself. 16 Q. What do you mean by touching himself? 17 A. Jacking off with his penis. 18 Q. You said when he laid down face down on 19 the table, that he had a towel over him. 20 A. Yes, he did. 21 Q. Okay. What was the towel over? 22 A Ills butt. 23 Q. All right. Now, when he rolled over, what 24 happened to the towel? 25 A. It was gone. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 25 Page 267 Q. Well, but what happened to it? Did, did somebody remove it? A. I, Iclikt touch it. Q. DidIM. touch it? A. No. Q. Did Mr. Epstein touch it? A. I'm guessing so. Q. Well, you're guessing? A. I know for a fact he removed his towel. Q. Well, how do yo ow fora fact he did? A. Because me and... didn't do it. Q. So you' oncluding, because you don't recall you and M. doing it, that Mr. Epstein did it? A. Correct. Q. And you don't recall seeing Mr. Epstein do it though? A. No, because it was a shock to me that he turned around and started playing with his penis. Q. Did he — do you have any recollection at all about what happened to that towel? A. I have no idea. I wasn't paying attention to the towel. Q. So, you don't know if somebody took it off, it fell off. You don't know what happened. 18 (Pages 264 to 267) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (6014)51476-2934) Electronically signed by cynthia hopkins (6014151-976-2934) Electronically signed by cynthia hopkins (6014)51.976.2934) 100246e-beed-4107-90a1-61730814deed EFTA01076453 Page 268 1 A. No. 2 Q. Okay. At the time that he turns over, 3 where are you standing? 4 A. I'm still at his feet. 5 Q. You were at the feet And.. is up at, 6 at -- by his shoulders? 7 A. Yes. 8 Q. Are you both standing on the same side of 9 the massage table? 10 A. She was like, if you're looking at the 11 massage table from where the shower is, and the front 12 door is right there, she's on this side, on the right 13 side, and I was by the feet. 14 Q. Okay. So — and, and up to thisspitt in 15 time, you haven't spoken any words to ? 16 A. About the situation? 17 Q. Yeah, about anything. 18 A. Not that I recall. 19 Q. Okay. So he flips over. 20 A. He flips over. 21 Q. Okay. And, and what occurs, then? 22 A. He starts playing with his penis. 23 Q. Okay. And, now, you're standing at his 24 feet, right? 25 A. Yeah. 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 269 Q. So you have a clear view of this? A. Yeah. Q. Now, at that point in time, you've seen his entire body; is that right? A Correct. Q. Okay. Tell me what, if any, tattoos you observed on Mr. Epstein. A. 'didn't see any tattoos. I wasn't — if he has any, I didn't see any. Q. Okay. A. I don't know. Q. All right. Now, when you say Mr. Epstein began to, to — what did you say he began to do? A. Playing with himself. Q. Play with himself. Did you observe that or were you concluding that he was doing that based on something you saw? A. No, he was doing that. Q. Okay. And did you say anything to him at that time? A. No. I don't remember. I honestly don't remember if I said anything. I was in shock. Q. Okay. And how did that evidence itself? What did you do that, that, that would evidence to anybody that You were in shock? 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 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 17 18 19 20 21 22 23 24 25 Page 270 A. I — mentally I was just thinking to myself, like, what is going on. k And what, and what were your observations A. I wasn't even — I was --jggiestly, I,1 wasn't even paying attention to... I was — I didn't know what to do. Q. Did you say anything to her? A. At that certain time, no. I was -- Q. Did she say anything to you? A. No, it just — no. Q. Did either you or she say anything to Mr. Epstein? A. Not that' — at that point, at that moment? Q. Yeah. A. Not that I recall. Q. Did either of you say, were uncomfortable with this, or we, we want to slop? A. Not at that point Q. Did either of you say you want to leave? A. Not at this point. Q. Did either of you walk towards the door? A. Not at this point, no. Q. Okay. Whaljappened next? A. And he toldia. that he wants her to play Page 271 with his nipples. Q. Okay. So did she do that? A. Yes, she did. Q. Okay. What happened next? A. I walked behind her, like, I stood behind her. Q. Okay. A. She was doing it and I stood behind her while he was playing with himself. Q. Okay. So you're not touching him at all at that point. A. I wasn't, no. Q. Okay. So what happens next? A. So I, you know, was just standing there? And he's playing with himself, and she — you know,,bf's. you know,. Q. Did . say anything? A. I don't remember. I, I was in shock. Q. Did you say anything? A. Not at that moment, no. Q. Okay. What happened ne A. So he was doing that with M., and then he started moving towards Q. When you say, ' " what do you mean? 19 (Pages 268 to 271) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1a30246a-bc9d-4107.90a1.6373e816de0d EFTA01076454 Page 272 1 A. With her, I wasn't certain because I was 2 behind her. 3 Q. So you couldn't see. 4 8 7 9 ' A. Okay. So then he started touching me. A. I couldn't see. 5 A. But do you want me to go to the next? Q. An right 6 Q Sure. Q. 13 14 15 16 17 18 19 20 21 22 23 24 25 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. With what? A. With his hand. Q. pky. And this is while you're standing behind...? A. Yes. Q. Okay. A. It was.., and then I was behind kith but I don't know how to explain it. Like, this is . This is me, and he was reaching around. Q. Okay. A. I was, like, right behind her. Q. What happened next? Page 273 A. I dent recall saying that Q If you told them that, when you told them, it was true, right? MR. MERMELSTEIN: Form. THE WITNESS: When I — yeah, I told the truth, Yes. BY MR. LIJITIER: Q. Let, let's be honest Dr. asked you all about this incident, didn't he? A. Yes. Q. And you told Dr. that, that Mr. Epstein did not put his hands inside your panties, didn't you? MR. MERMELSTEIN: Form. I, I'm Page 274 1 object generally to the paraphrasing ca. 2 You're not showing her a transcript 3 MR. LUTHER: No, no speaking objections. 4 Just start and state your form objection. 5. MR. MERMELSTEIN: But you keep doing the 6 some thing. 7 MR. LIMIER: I know. 8 MR MERMELSTEIN: Objection to form. 9 BY MR. LUTHER: 10 Q. That's what you told Dr... was he did 11 not put his hands in your panties, didn't you? 12 A. No. 13 Q. You didn't say that to him? 14 A. Not that I recall, no. 15 Q. Well, which is it? You didn't say it to 16 him, or you don't recall saying it to him? 17 A. No, I didn't say Liliggp. 18 Q. Okay. So if Dr. IM says that's what 19 you said, how do you rectify that? 20 MR. MERMELSTEIN: Form. 21 THE WITNESS: How would I rectify 22 something I didn't say? 23 BY MR. LUTTLER: 24 Q. Okay. You told DM that, that 25 Mr. Epstein did not put his hands in your panties, Page 21 5 1 didn't you? 2 A. No. 3 MR. MERMELSTEIN: Form. 4 BY MR. LUTTIER: Q. Okay. All rigalislin years later A. Yeah, he tried to, yes. 9 Q. Uh, uh, uh. You say he tried to, or he 10 did? 11 20 (Pages 272 to 275 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkIns (601.051.978-2834) Electronically signed by cynthia hopkins (601-051.976-2934) 1 a30246a-bc9d-4107-90a1-63734816de0d EFTA01076455 Page 276 1 Q. Did you pull away? 2 A. 1 pushed him away. 3 Q. Ok• nd and wh ned next? 9 10 11 A. Not that I recall, no. Q. Well, you would recall that, wouldn't you? A. Page 277 A. No. ( 12 Q. When you say, "using it," what do you 13 mean? 14 A. It was, it was like a back massager vibrator. 15 Q. What color was it? 16 A. I think it was white. 17 Q. How big was it? • 18 A. It was like this, big. It was like, it looked 19 like a back massager, like it didn't look like -- 20 Q. Describe it. 21 A. It had like a white head on it. 22 Q. Okay. 23 A. And then like a body that you would hold it 24 by. It vibrated. 25 Q. Was it one 11 Sed into the wall? 1 2 3 4 5 6 7 8 9 10 18 19 20 21 22 23 24 25 A. I don't ;mow. I don't recall. Q. And when did you first see it? A. Well, !first noticed it when he started he was going to start using it, when he pulled it out. Q. Did he put— did he pick it up from some place? A. Yeah, picked it up on the right, or, like, the, you know, mirror and the desk was. Q. Off a countertop? A. I don't know if ark II in ad s was on the outside of her panties? A. I don't know because I was behind her so — Q. You, you couldn't really see what was going on? A. No, with N. Q. Did./ say anything? A. Not that — I don't remember. Q. Did you hear her say, don't do that? 1 2 3 Page 279 A. I don't recall what.. said. I was in shock I — Q. Okay. What, what happened next? Q. When you say, "pulled you around," what do 9 you mean? 10 A. Like, he grabbed my arm and pulled me around. 11 Q. Well, did he ask you to come over, move 12 from where you were? 13 A. N he can ou lease over. er. 14 15 Q. Did he, did he pull you with such force 16 that he left any marks on your body, for example? 17 A. No. 18 Q. Any bruising or anything like that? 19 A. No. • 20 Q. Okay. Did you say anything to him when 21 he, to use your words, pulled you over? 22 A. I don't recall. I don't remember. 23 Oka . What ha ne s , ,i mmi ahWhTnext? 24 ■ 25 21 (Pages 276 to 279) PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051.976.2934) 1 al0246a-bc9d-4107-90a1-6373e816de0d EFTA01076456 Page 280 1 Q. Did you say anything to him when he 2 started doing that? 3 A. I told him I didn't feel comfortable, and he 4 lcept telling me to just let it go. 5 Q. Did, did you pull away? 6 A. There was a couple of times that I pushed 7 away. I was just, I don't feel comfortable, not that I 8 went all the, you know, all the way back in a corner, 9 but I did push him, and l said, I don't feel 10 comfortable. 11 Q. Okay. 12 A. And he kept persisting and doing it and kept 13 saying the same thing, lust let it go. 17 Q. While he's sitting on the table? 18 A. Yeah. Ile was on the table, like leaned over. 19 Q. Okay. And what did you say? 20 A. 1 kept saying, I don't feel comfortable. 21 Q. Did you, did you eventually pull away and 22 ask him to stop? 23 A. I, I pulled away a couple of times, and then 24 at one point a thought, a thought ran through my mind, 25 if Ijust get this over with I could leave. 1 2 3 4 5 Page 281 Q. Did you ever ask him to stop? A. I just kept telling him I didn't feel comfortable. 1 don't know if I told him to stop or not. Q. O What hay.ened next? A M , did you just stand there? 22 A. For a little bit, I did. 23 24 25 Q. For how long? A. A couple of seconds. Q. Okay. So for two seconds, he took a, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2/ 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 25 Page 2F^ A. Yes, that's... Q. Okay. So for a couple of seconds he's doing that, and during that couple of seconds, you're saying to him, Pm uncomfortable. A. Yes. Q. Does he stop after a couple of seconds? A. No, he. A. I have no idea. It seemed like forever. Q. It was a matter of seconds, right? A. No. A matter of seconds is when I let — like, sort of like just let it go and just ignored the fact that, I was, you know, in this situation. Q. Okay. If you let it go fora matter of seconds; what did you do after the seconds passed? A. What do you mean? Q. Well, you said you let it go for a matter of seconds. You must have done something, then, when that, that time period of seconds expired. What did you do? Page 283 A. While I was letting him do it? Q. Yeah, did you pull away? A. I was just sit — I was just sitting there letting him do it. I wasn't trying to say stop at some Pant Q. So, you let him do it for, what you described as, a matter of seconds? A. Yes. Q. All right. And what did you do? A. Then, !kept, I just — I was like, !can't do this. I don't feel comfortable. Q. And did he stop? A. No, he kept going u 9 ,r• II I I A. I don't remember how ►on a time. 22 (Pages 280 to 283) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) 1a30246a-bc9d-4107-90a1-6373e816deOd EFTA01076457 Page 284 1 Q. A matter of a few mo o 2 A. I don't know. 1 mean. 4 A matter of — 5 Q. How long a while? 6 A. Huh? 7 Q. How long a while, a minute or two? A. No. 9 Q. First he did something to.., according 10 to you, right? 11 A. Yes, but I'm saying since the vibrator came 12 out of the drawer. 13 Q. Was it less than a minute? 14 A. Or whatever it came out of. It was age than 15 a couple of minutes, because he used it onM. first 16 and then he used it on me. 17 Q. How about you? It was less than a minute 18 on you, wasn't it? 19 A. No. I mean, I don't know the exact time, but 20 it wasn't less than a minute because — 21 Q. How do you know it wasn't less than a 22 minute if you don't know the exact time? 23 A. Well, to me it seemed like a while. 24 Q. It seemed like a while, but 25 A. To me it did. 1 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 Page 286 Q. Did you ever — A. —just let it go. Q. Did you ever just say no and walk t4 steps away? A. I said I don't feel comfortable, and I took a step back, yes. Q. Well, full steps so he couldn't reach you. A. No, I was still an ann's length. Q. Did you ever step back beyond his reach and say I don't want to do this? A. No. swirl A. No. Q. Okay. So at some point he stops? A. Yes. Q. You don't know how long it is? A. No. Q. Okay. What happens next? A. And then be finishes him' tlf off. Q. When you, when you say "finishes himsel f off," what do you mean? A. That he ejaculated. Q. Did you actually see him ejaculate? A. Yes, I did. 1 2 3 4 5 6 7 8 Page 285 Q. — in fact, it could have been less than a minute, couldn't it? MR. MERMELSTEIN: Fonn. THE WITNESS: No, definitely not BY MR. LUTTIER: Q. Well, how long was it? A. I don't rightIMMINIME 11 Q. All right. So there came a time when he 12 stopped, right? 13 A. Yeah. 14 Q. Did you — did there 15 some ooint in time, He didn't pull you back. !23 You could have just stepped back, couldn't you? 24 A. He would, like, grab the side of me and pull 25 me close and -- 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 287 Q. Okay. And.. is standing next to you? A. Yes. Q. And did you say anything to her? A. I think I told her in her ear, like, we need to get out of here. Q You said that to.. at this point? A. Yeah. Q. Have you ever, prior to today, told that to anybody that you made that statement? A. Yes. Q. Okay. Who have you told that to? A. Anybody I told the story to. to if you said it if you told the story A. Yes. Q. — and if you told to its you've told both of ti that what you said at that point in time to . was we've got to get out of here? A. Yes. Q. Okay. What did she say to you? A. She just — I mean, he was still right there, so she just sort of like nodded her head, like, yeah, I know. Q. Well, you said this audibly so she could hear it. 23 (Pages 284 to 287) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1a30246a-bc9d-4107-90a1.6373e816de0d EFTA01076458 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 288 A. It wasn't, it wasn't like, hey, we need to get out of here. It was more like we need to get out of here. Q. that? A. He didn't hear me. He was — Q. How do you know he didn't hear you? A. — cleaning himself. Because he didn't. Q. Okay. What happened next? A. He cleaned himself up, and then he gave us money and said if you bring back a girl for a massage for $200, I'll give you 400. Q. Well, when you, when you say he gave you money, what did he give you? A. $200. Q. $100 bills? A. Bills, yes. Q. TWo $100 bills? A. I don't recall if it was — what kind it was. I don't know. I just wanted to get out of there. Q. So you don't know what the denominations of the bills were? A. No, I don't. Q. And did he give you money and... money? A. Yes. Well, what did Epstein say when you said Page 290 1 Q. Okay. And what didfl. say? 2 A. I don't remember. 3 Q. Okay. But you were standing right there, 4 right? 5 A. Yes, but I don't remember. 6 Q. All right. So what happened next? 7 A. So then we left. 8 Q. What was the total amount of time you were 9 up there in this — doing this massage on 10 Mr. Epstein? And by that I mean the total time you 11 were up in this room that you've described. 12 A. The -- from the massage and everything? 13 Q. Yeah. From the time you walked in and, 14 and he first asked you to, you say, take your 15 clothes off, to the point in time that you walked 16 out that door that you came in. 17 A. I don't have the exact time frame, because I 18 didn't sit and time it. But 1 know from -- the massage 19 was 45 minutes to an hour. And I don't know how I know 20 that. I don't know if the person that told me that it 21 was only a 45-minute or an hour massage, but I know the 22 massage was at least 45 minutes. 23 Q. Okay. And, and how long did it take 24 Mr. Epstein to masturbate and ejaculate out of this 25 45 minutes? Page 289 3. Q. And what did you-all say when he gave you 2 this money? 3 A. Nothing. Q. And you're standing there naked at this 5 time? 6 A. I don't remember at that point if we were 7 dressed a not dressed. I don't i 8 Q. Okay. And what happened next? 9 A. So, then I told you what he said about you 10 bring a girl, rit give you 400. 11 Q. Okay. What did you say? 12 A. No. 13 Q. Okay. So just told him, no. You didn't 14 have any problem telling saying. no to him, did you? 15 A. With that statement When he's sitting there 16 sexually touching you, ifs a little bit uncomfortable 17 when you're that age. 18 Q. You didn't have any problems saying to 19 him — when he said if you bring a girl III give 20 you $400, you didn't have any problem saying to him, 21 no. 22 A. Yes, because he gave me an option. 23 Q. Okay. And so you said, no, I'm not going 24 to do that? 25 A. Yes. 1 A. 2 Q. 3 A. 4 Q. 5 A. 6 Q. 7 first? Page 291 Forty-five minutes wasn't including that part. Was not? Was not. Oh, that was in addition to the massage? Yes. So what did you do, finish the massage 8 A. We gave him the massage, yes. 9 Q. Okay. 10 A. And that's when he flipped over and it wasn't 11 a massage anymore. 12 Q. Okay. So the total amount of time you're 13 in the room is something between 45 and 60 minutes. 14 A. For the massage. The massage at least was 45 15 minutes. 16 Q. Listen to my question. What is your best 17 estimate of the total amount of time that you were 18 up there in this room with Mr. Epstein? 19- A. Total? I don't know. 20 Q. Less than an hour? 21 A. No. 22 Q. More than an hour? 23 A. Yeah. 24 Q. Well, how much more than an hour? 25 A. I don't know. 24 (Pages 288 to 291 ; PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by Cynthia health's (601-051.976-2934) Electronically signed by cynthia hopkIns (601.051-976.2934) 1830246a-bc9d-4107-90a1-63738816deOd EFTA01076459 Page 292 • Q. Fact of the matter is you don't know how 2 long you were there, do you? 3 A. No. 4 Q. Okay. Less than an hour and five minutes? 5 A. I have no idea. 6 Q. Okay. That's the truth of the matter, is 7 you don't know how long you were there, right? 8 A. Right 9 Q. Okay. And did — who left the room first? 10 A. Out of all three of us? 11 Q. Yeah. 12 A. I don't recall. It was probably — I man, 13 I'm not going to say because I don't know. 14 Q. Well, when did you and — did you and.. 15 get dressed again? 16 A. Yeah. 17 Q. When did you do that? 18 A. I don't remember. 19 Q. Did you have any discussion while you were 20 getting dressed? 21 A. No, became I'm sure he was in the room. He 22 didn't leave the room again. 23 Q. So, now you do know who, who was in the 24 room when you were getting dressed. 25 A. We all three were in the room. I said I don't Page 294 A. Where the front door was. I don't recall if 2 he walked us all the way down the stairs or halfway 3 down, and there was the door. 4 Q. Okay. Did you ever see this.. person 5 again? 6 A. No. 7 Q. Did you see anybody else in the house? 8 A. I don't — no, I just left 9 Q. What did you do when you got to the door? 10 A. I called a taxi. it Q. So what — how did you call the taxi? 12 A. With my phone. 13 Q. Through the cellphone? 14 A. Yes. 15 Q. Cellphone you brought? 16 A. Yeah. 17 Q. Did you know the phone number? 18 A. Yes. I had the guy's card from the taxi. 19 Q. Okay. So you dial on your cellphone and 20 call the cab? 21 A. Yes. 22 Q. All right. So how long did it take for 23 the cab to get there? 24 A. He knew that we were going to leave. He knew 25 that we were going to give a massage and we were going Page 293 1 remember when we got dressed. 2 Q. So he's in the room while you get dressed, 3 right? 4 A. Yes. 5 Q. You and. don't have any conversation? 6 A. No. 7 Q. Are you getting dressed before or after he 8 gives you the money? 9 A. I don't remember. 10 Q. What happens after you get dressed? 11 A. I don't know if we took the money, if it was 12 before or after, but we left. 13 Q. Is was Mr. Epstein dressed at the time 14 you left? 15 A. I don't remember. 16 Q. Was be still in the room when you left? 17 A. No, I think he walked us out. 18 Q. Was he clothed? 19 A. I'm pretty sure. 20 Q. What clothes did he put on? 21 A. I have no idea. 22 Q. Okay. All right. So when you say he 23 walked you out, where did he take you? 24 A. He took us down the stairs. 25 Q. All ri t To what? PROSE COURT REPORTING Page 295 1 to leave — well, he didn't know we were going to give a 2 massage, but we told lim — 3 Q. Right 4 A. — we wouldn't belong, so he said he mould 5 wait down the street. 6 Q. Okay. So bow long did it take for the cab 7 to get there? 8 A. Couple manna maybe. 9 Q. Okay. And you waited in the house with 10. Mr. Epstein? 11 A. No, we waited 12 Q. Okay. 13 A. Outside of the gates. 14 Q. And, and when ymwemommde, did you 15 have a conversation with 16 A. I don't recall the conversation right outside, 17 when we first got outside. 18 . Q. When dorm recall do you recall 19 . getting in the cab with her? 20 A. Getting in, yes. 21 Q. Do you recall saying anything to her when 22 you got in the ode 23 A. I don't recall the exact conversation. I know 24 we were both disgusted. 25 Q. Well, how do you kno2;piyou were disgusted? 25 (Pages 292 to 295) AGENCY',. Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601.051-976.2934) 1a30246a-bc9d-4107-90a1-6373e816de0d EFTA01076460 1 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 296 A. Because look what just happened. How can anybody not see that? Q. What did you say to her? A. I just said, I can't believe what happened. Q. What did she say to you? A. I know. And that's all - Q. A. Q. So it was a horrible experience? Yes. Traumatic experience? A. Yes. Sixty minutes of pure trauma? A. Yes. Q. One that you would never want to replay again? A. Yes. Q. And so as a result of that, did you ever go back to Mr. Epstein's? A. Yes. Q. Even though it was a traumatic experience? A. Yes, because I didn't know that they were going there. Q. Okay. Did you ever see Mr. Epstein again? A. Yes. Q. Him, personally. A. Yes. Q. Page 297 1 Q. When did you see him again? 2 A. Second time. 3 Q. And, and how did you get there the second 4 time? 5 A. The second tit. and were going. 6 Q. Again, this is — .'s the person that 7 had been there the first time -- 8 A. Yes. 9 Q — that was thoroughly disgusted with what 1O happened. 11' A. Yes, Imam, I'm speaking for myself here. 12 Q. VAIL' a minute. Did I understand you to 13 say that M. said to you when you got in the cab 14 that she couldn't believe what it was and that she 15 was disgusted? 16 A. I said that. 17 MR, MERMELSTEIN: Objection, form. 18 MR. LUTTIER: Did — well -- 19 THE WITNESS: I said I, I can't believe 20 what just happened. And she said, I know. 21 That's all I said. 22 BY MR. LUITIER: 23. Q. Did she, did she appear to be upset at 24 all? 25 A. I was, worried about myself.. PROSE Page 298 1 wasn't -- 2 Q. Did she appear to be upset at all? 3 A. I don't remember. 4 Q. Did she cry? 5 A. No. 6 Q. Did she say anything to you other than, "I 7 know"? • 8 A. I don't recall. 9 4 Did you say anything more to her to 10 indicate any — what your emotions were at the time? 11 A. I don't remember. 12 Q. Did you-all enjoy the money? 13 A. The money? 14 Q. Yeah. 15 A. Who doesn't enjoy money. 16 So you don't recall any comment 17 thatfl. made when she got in the cab, right? 18 A. Yes. 19 Q. And you don't recall any comments you made 20 in the cab ride from Mr. Epstein's to — back to 21 wherever you went. 22 A. Yeah, I don't even remember where we went. 23 Q. I was — that's my next question. Where 24 did you go in the cab? 25 A. It was either back to my house orig.'s 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 Q. Were you crying? Page 299 house. I think it was my house, butIm not sure. Q. How long of a drive was that? A. A while. We went from his house in Palm Beach to Wellington. Q. Can you tell me anything about the conversation in the car between you and. on the ride back? A. No, I don't remember.. Q. can you describe her in any manner'? A. No. Q. Was there music playing in the cab? A. I don't know. Q. Did you say anything to the cab driver? A. Not that I know of. Q. Did be say anything to you? A. Not that II ranember, no: Q. Did you-all make any calls on your eellphones? A. I don't remember. Q. Did the cab driver ask you if there was anything wrong with you? A. No: Q. Was . crying? A. No. 26 (Pages 296 to 2 99) COURT REPORTING AGENCY, INC. . Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-978.2934) Electronically signed by cynthia hopkins (601-051.976-2934) 1a30246a-bc9d-4107.90a1-6373e816de0d EFTA01076461 Page 300 A. No. 2 Q. All right. Do you know whether or not 3 you-all made jokes on the way back to the - 4 A. We didn't make jokes because we were in shock. 5 Q. Well-- 6 A. lyres in shock. 7 Q. if you don't know what was said I mean, 8 ifs.ftne to tell me, if you don't know what was 9 said, you don't know what was said. 10 A. Yeah, I don't know what was said. 11 Q. So, it would be a fair statement you just 12 don't have any recollection at an of what happened 13 with the ride back? 14 A. Basically, yes. 15 Q. Okay. And you don't know if you went to 16 your house or her house? 17 A. Correct. 18 Q. Who did you next see after you got dropped 19 off either at your house or her house? 20 A. I don't remember. 21 Q. And this was -- 22 A. I don't remember. 23 Q. This was a Saturday or Sunday? 24 A. I don't know exactly what day it was. It was 25 a day l didn't have school. Page 302 1 A. I mean, I don't know. 2 Q. So there's a second incident that comes 3 up. 4 A. Yes. ' 5 Q. And it's you ma/. and was itM.? 6 A. MI. 7 MR. LUTHER: Okay. l'm going to take a 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 little break and go to the bathroom. WE WITNESS: Okay. Me, too. HayIDEOGRAPHER: Going off the record at 3:09M. (A brief recess was held.) 7HE VIDEDQ. RAMER: We're back on the record at 3:18ln. BY MR. LUTHER: Q. Okay. There, there came a, another occasion when you went to Mr. Epstein's house; is that right? A. Yes. Q. Do you remember how long that was after the first time? A. No. Q. Was it a matter of months, years? MR. MERMELSTEIN: I think that this has been asked and answered. Page 301 1. Q. All right So did you tell your mom or 2 your dad? 3 A. No. 4 Q. Did you call the police? 5 A. No. 6 Q. Did you tell anybody? 7 A. No. 8 Q. All right. But at some point in time, you 9 hooked up within. and your other friend and you 10 went back to Epstein's; is that right? 11 A. Yes. 12 Q. Okay. And, now, I just want to make sure 13 I understand this. Did you get the impression from 14 anything that.. said or did that she appeared to 15 be at all upset about this incident? 16 A. The time that we — 17 Q. Yeah. 18 A. I, I don't remember. You mean, like, from 19 that to the second time that we went? 21 Q. Yeah. 21 A. I mean, I don't !mow. 22 Q. Did you, did you, you and she ever discuss 23 it? 24 A. I don't =all that, no. 24 25 . a 25 Page 303 1 MR. LUTHER: Well, if I do, I don't 2 recall it, but you can tell me what the answer 3 was. I will accept your representation. 4 MR. MERMELSTEIN: You can, you can answer 5 it again. 6 773E WITNESS: I don't, I don't know. I 7 don't remember what — 8 BY MR. LUTHER: 9 Q. Do you, do you have any — what's your 10 best recollection of the amount of time between 11 these two visits? 12 A. It was — I mean, it wasn't that far after. I 13 know it wasn't years after. It could have been weeks or 14 months, but it wasn't... 15 Q. Okay. Your best recollection is, it was 16 either weeks or months — 17 A. Yes, it wasn't — 18 Q. but it was more than a few days? 19 A. Yes. 20 Q. Okay. And how were you contacted about 21 the second occasion? 22 A. I v . I was actually in the vehicle with 23 and , and they were going over there. Q. And whose vehicle was it? 27 (Pages 300 to 303) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) a andisa-b csdA 107-goal n k816d0d EFTA01076462 Page 304 1 Q. And, and how was it that you were in 1 2 M.'s vehicle? 2 3 A. I don't know why I, I was with her. I don't 3 4 know if I was just hanging out with them, and I guess 4 5 they wanted to go over there. 5 Q. And when did you first learn, when you 6 7 were in this vehicle, that where you were going was 7 8 Epstein's? 8 9 A. They mentioned it in the car that that's where 9 10 they were going. 10 11 Q. And where were you geographically when 11 12 they mentioned to you in this car that they were 12 13 going there? 13 14 A. Like what area? 14 15 Q. Yeah. 15 16 A. I have no idea. 16 17 Q. Where, where were you in this — do you 17 18 remember what day of the week it was? 18 19 A. No. 20 Q. Do you remember what time of day it was? I 21 A. No. 21 22 Q. Do you remember in what area of the city 22 23 you were, if you were in the city? 23 24 A. No, I don't know. I don't recall. 24 25 Q. All you know is you were in a car with 25 Page 305 a? 2 A. Correct. 3 Q. And how long had you been in the car 4 before you learned that they were going to 5 Epstein's? 6 A. It was a little while. I'm not sure exactly 7 how long. 8 Q. Roughly, your best estimate, how long? 9 A. Maybe ten minutes, 15 minutes. 10 Q. And why were you in the car? 11 A. I was — 12 Q. Were you — was there a plan that you were 13 going to be going someplace? 14 A. I was just hanging out with them, and 15 don't — I mean, I don't know if we were supposed to be 16 going somewhere or what was going on. 17 Q. Had they picked you up from some place. 18 A. No, I think I was with them, like hanging out 19 with them. 20 Q. Okay. And when you got 'M.'s car, 21 where were you? 22 A. In the backseat 23 Q. I mean, were you at, for example, her 24 house when you got in the car, or were you someplace 25 else when ou-all t in the car? 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 306 A. I don't know exactly where we were at, but we were all together. Q. And you don't know why all of you had gotten in the car initially? A. Exactly. Q. So you don't know if you were going to the movies or shop or whatever? A. Yeah, ! don't remember. Q. But your best recollection is, about ten minutes after you got in this vehicle for some unknown purpose, you heard for the first time that this car was headed to Jeffrey Epstein's? A. Yes. Q. Who told you that? A. I don't remember who told me. One of them mentioned it. Q. And what did they say? A. That they're going to Jeffrey Epstein's house. Q. And what was your reaction? A. I don't want to go. Q. And what did they say? A. Well, you're going to come with us. Q. And did you, at any time say, stop, I want to get out? A. No. Page 307 Q. And did you say anything else to them besides that you didn't want to go? A. I, I argued with them about not going and that it was disgusting = do that. Q. Had — dide indicate to you at that time or anytime before that conversation whether she had been back to Epstein's since your first visit? A. Between the time we're in the car and the first visit we went? Q. Yeah. A. Not that I know. Q. All right. To the best of your knowledge, was that her second visit? A. Yeah, to the best of my knowledge. Q. Did you know laga you were in the car that, whether or not... had ever been there? A. I, I don't -111tink — I don't know for sure, but I thinkM. walaing. her. Q. So you think that'll. had not been there before? A. That's what I think. . Okay. Did you have a conversation with A. Yeah I told her -- 28 (Pages 304 to 307) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthia hopkins (601.061-976-2934) Electronically signed by cynthia hopkins (601.051-976-2934) 1a30246a•bc9d-4107-90a1-6373e816de0d EFTA01076463 ge 3:J 1 Q. — where you warned her? 2 A. I told her not to go in the car. 3 Q. What did you tell her? 4 A. I told her It's not a massage, that it's other 5 things. 6 Q. You said you told her not to get in the 7 car? You mean, she was already in the car - 8 A. Yeah, we were in the car. 9 Q. -- and while in the car you told her? 10 A. Yes. 11 Q. What is -- specifically, did you tell her? 12 A. That she shouldn't go because ifs not just a 13 massage; it's other sexual acts. 14 Q. Well, did you specifically tell her about. 15 your experience? 16 A. I don't remember exactly, but I'm sure — I 17 mean, I'm sure I did if I was flying to justify why she 18 shouldn't go there. 19 Q. I mean, you gave her as much detail as 20 possible, didn't you, to discourage her from doing 21 it? 22 MR MERMELSTEIN: Form. 23 BY MR. LUTTIER: 24 Q. Did you give her as much detail as 25 possible in order to discourage her from going? Page 1 MR. MERMELSTEIN: Form. 2 THE WITNESS: I don't know. I don't 3 remember. 4 BY MR. LUTHER: 5 Q. Did you tell her that it was a, an a — an 6 older man who was going to be naked on a massage 7 table? A. Uh-huh, yes. 9 Q. Did you tell her he was going to — he was 10 likely going to masturbate in front of her? 11 A. Yes. 12 Q. Did you tell her that he was likely going 13 to touch her? 14 A. Yes. 15 Q. Did you tell her that she would likely be 16 unclothed? 17 A Yes. 18 Q. And what was her response when you told 19 her all of those things? 21 A. didn't care. 21 Q. Did you, did you tell her -- did you get 22 angry at her? 23 A. Yeah, we got in a about it 24 Q. That is you and M.? 25 A. Yes. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 1.9 21 21 22 23 24 25 • Page 310 Q. What did, what did the fight consist of? A. That I thought she was stupid for going. Q. And your best friend was in the car, e, right? A. Yes. Q. And did you argue With. about it? A. I don't remember if I did or not. Q. Did you tell anything like, you know, you remember what appened last time; we shouldn't go there? A. I don't recall exactly saying that. I could have said that, but I don't know. Q. Do you remember anything about what you told A.., it was more about Q. Well, you were worric a out your best friend, weren't you? A. Yes, but she already knows what happened. Q. Were you in shock that your best friend would be doing this? A. WAS again, Yes. Q. And this was a driving this car, right? A. Yes. Q. Did that suggest to you that maybe, Page wasn't so traumatized by whatever occurred? MR. MERMELSTEIN: Form. THE WITNESS: I don't know. BY MR LUTITER: Q. Were you surprised? A. I was surprised. Q. Did you ever have a conversation with about why she went back the second time? A. No. Q. Did M. tell you whether she was getting any money feW7or , taking M.? A. No, I didn't know. Q. Okay. So, do you, sO — A. I — Go ahead. Q. I didrft mean to cut you off. A. I was just going to say I figured that's what was happening. Q. Did you ask her? A. No. Q. Did you tell M . that was going to get money for taking r? A. No. Q. Did you tell M. whether she was going to get paid for going? A. No. 29 (Pages 308 to 311) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976.2934) 1O0M6a-bc9d.4107-90a1-6373e816de0d EFTA01076464 Page 312 Q. Did M. indicate whether she knew she was 2 getting paid? 3 A. I'm sure she did. That's the was going. 4 Q. And what specifically did M. tell you in 5 response to your warnings? A. She didn't care. 7 Q. All right So how long did this ride take 8 to get to Epstein's? 9 A. I don't know, I mean — 10 Q. More than a half hour? 11 A. From — I mean, I don't even know where we 12 were at but it was, it was more than 20 minute. 13 Q. And this whole time is it dedicated to you 14 telling your girlfriends that you don't want to go? 15 A. Not the entire time. I tried to talk them out 16 of it or tried to ta n out of it fora little 17 while, and she — . didn't listen, so... 18 Q. Okay. So was navigating the car. 19 She apparently remembered how to get to Epstein's 20 house. 21 A. I don't lmow how she — I mean, I don't know 22 if she spoke to again. I don't know exactly along 23 the lines how she got there again. 24 Q. But she navigated the car to Epstein's 25 house. Page 314 1 this, and the driveway goes to the side of the house, 2 and there's — I think there was garages on the side. 3 Q. Okay. And, and what kind of car did M. 4 have? 5 A. At that time? 6 Q. Yeah. 7 A. She's had a couple of cars. I'm going — I'm 8 going to, I'm going to guess it was her, a Lexus. 9 Q. You say you're guessing? 10 A. I'm pretty sure it was a texas. I don't know 11 100 percent because she borrowed her mom's car and stuff 12 like that. 13 Q. Was this her mom's ear that you-all were 14 in? 15 A. Her mom gave her that ear. 16 Q. Okay. So it was — do you remember what 17 model it *as? 18 A. No. 19 Q. Leather interior? 20. A. I think it was leather. 21 Q. Okay. All right So you get to the 22 house. 23 A. Uh-huh. 24 Q. Where are you, where are you in the car, 25 in the Bent seat or bwleceat? Page 313 1 A. Yeah, she got to Epstein's house, but I don't 2 know how. 3 Q. Okay. When you got to the house, what did 4 you do? 5 A. I — 6 Q. I mean where did you park the car? 7 A. I think she's pulled — !mean, ha not going 8 to say definite, because I don't remember that, but I 9 think she pulled into the, the driveway that he had 10 through the gates. 11 Q. What kind of driveway is it? 12 A. What do you mean, what kind of driveway? 13 Q. Well, describe the driveway as best you 14 can. 15' A. I know there was gates. I don't recall, I 16 don't know if there was two entrances or one. 17 Q. I mean, is it, is it like an asphalt-paved 18 driveway? 19 A. Oh, I have no idea- 20 Q. Do you know any — do you know anything 21 about the driveway? 22 A. I don't remember. 23 Q: Where's the driveway in relationship to 24 the house? 25 A. Ifs —you go in, and then the house is like HinrAnrILSCAPALA Page 315 1 A. I'm in the backseat. 2 Q. And, and who — and M.'s driving. Is it 3 bucket seats in the front? 4 A. What's bucket seats? 5 Q. You know, were they bucket seats or a 6 bench seat in the front? 7 MR. MERMELSIEIN: Do they make bench seats 8 in the front anymore? 9 MR: LurflER: I'm, I'm dating myself. 10 • BY MR. LUTITER: 11 Q. Do you know what a, a bench seat would 12 be — a bucket seat was, is, is individual seats. 13 A. Oh, it's individual seats. 14 Q. There's a console so you can't — 15. A. Oh, yeah, that's how it is. 16 Q. All right. So you're in the backseat 17 A. Uh-huh. 18 Q. Do you remember if you're behind the 19 driver or the passenger? 20 A. I think I was in the middle. 21 Q.. All right. All right. 22 A. I think because I was -- 23 Q.. So sitting on the hump, as they say? 24. A. Yes. 25 Q. And what were you wearing? 30 (Pages 312 to 315) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601-061-976-2934) Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by Cynthia hopkins (601-051-976-2934) 1a30246a-bc9d-410740a1.6373a616da0d EFTA01076465 Page 316 1 A. I have no idea. 2 Q. What was wearing? 3 A. I have no igs& Q. What was M. wearing? A. I have no idea. 6 Q. And you don't know what time of day it 7 was? A. No. 9 Q. Okay. 10 A. During the day. 11 Q. When, when you get there, what happens? 12 A. I don't, I don't recall how we got in the 13 house or I don't remember how thaliappeasa All I 14 remember is they went upstairs, M. and and I 15 stayed in the kitchen area with the chef. There was a 16 chef there. 17 Q. Let's go back imo the driveway. Did 18 anybody come out of the house to meet you? 19 A. Not that I recall. 20 Q. Did you-all get out of the car and walk 21 someplace? 22 A. We walked — I mean, I think we walked into 23 the house. I don't recall. 24 Q. Well, did you just walk in the house, or 25 did you walk to a door, or his door? 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 338 Q. This house, this is this evil house that you've been to -- A. .Yes. Q. — where you had a traumatic experience, right? A Yes. Q. So why didn't you just not go in the house? A. I don't know. Q. Okay. But, anyway, you get to the door. What happens? A. They go upstairs. I don't — Q Wait a minute. Somebody has to answer the door, right? A. I don't remember that. Q. Who answers the door? A. I don't remember. Q. Was it Jeffrey Epstein? A. Honestly, I don't recall. I don't know. Q. You don't know who was there, so you can't describe what they were wearing? A. No. Q. Were there other people in the house? A. All I remember is the chef. Q. Okay. And what's his name? Page 317 1 A. I'm sure we walked to a door. 2 Q. What door? 3 A. The front door. 4 Q. The front of the house? 5 A. Yes. 6 Q. Okay. Do you remember what the door was 7 like? 8 A. No. 9 Q. Is it a double door or single door? 10 A. I have no idea. 11 Q. Has it got anything on it? 12 A. I don't recall that. 13 Q. All duce of you walked up to the door? 14 A. From what I vaguely remember. 15 Q. Okay. Is there anything that prevented 16 you from just staying right in the car? 17 A. No. 18 Q. Why didn't you just sit in the car? 19 A. I don't know. 20 Q. Why didn't you walk away? 21 A. Walk away where? 22 Q. Just walk away; walk down the street 23 A. To go where? 24 Q. Anywhere you wanted to. 25 A. Down to the !lei b wd.._...g.a .. ......, 00d? PROSE Page 319 1 A. I have no i 2 Q. Did you see on this occasion? 3 A. I don't remember seeing her, no. 4 Q. Okay. Well, if you don't remember seeing 5 her and there was a chef, but you can't tell us who 6 answered the door? 7 A. No. 8 Q. Do you recall seeing Jeffrey Epstein on 9 this occasion? 10 A. Yes, I did. 11. Q. Okay. When did you see him? 12 A. At the end of everything. 13 Q. Okay. And you had not seen him since you 14 left the previous time? 15 A. Exactly. 16 Q. All right. So, you say In end.. 17 walked upstairs. 18 A. Yes. 19 Q. You weren't up there? 20 A. No. 21 Q. And you don't know what happened up there? 22 A. I figured — 23 Q. You don't know what happened? 24 A. I don't know what happened up there with them. 25 Q. Did anybottell ru tat happened up 31 (Pages 316 to 319) COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (8014514704934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (501.061.976.2934) 1 a30246a-bc9d-4107-90a1-6373e8166e0d EFTA01076466 Page 320 1 there? 2 A. No. 3 Q. When you kfl, did they tell you what 4 happened up there? A. No, not that I remember. They didn't tell me anything about it. Q. And you walked from the front door to the 3 kitchen. 9 A. — from the front door to the kitchen? 10 Q. Yeah. 11 A. Yeah, I'm guessing. How else would I get 12 there? 13 Q. Well, did somebody meet you at the front 14 door? They must have, right. 15 A. There must have been somebody, but I cannot 16 recall who it was. 17 Q. You didn't just walk into the guy's house. 18 A. No. 19 Q. So somebody met you there. 20 A. Yes. 21 • anAdr usposmtaierbso?dy, did that somebody take 22 23 A. Yes. 24 Q. Sow you when that somebody 25 started takingM. and M. upstairs? Page 321 1 A. They probably took me to the kitchen first, 2 and then they took them. I didn't just walk to the 3 kitchen, I know that. 4 Q. If you don't recall, tell me you don't recall. I don't want to, I don't want you to guess. o A. Okay. I don't recall. I just know I wasn't 7 upstairs and I ended up in the kitchen. 8 Q. Okay. So you don't know whether you told 9 somebody you didn't want to go upstairs or you just 10 walked to the kitchen? 11 A. I know I didn't walk to the kitchen alone. 12 Q. All right. So you go to the kitchen. All 13 right. You get paid no money for going there. 14 A. No, I did get paid. 15 Q. You did? 16 A. Yes. 17 Q. Well, who paid you money for going there? 18 A. Jeffrey Epstein. 19 Q. What did you get paid for? 20 A. Because I was there and I was pissed off, so I 21 told him that he needs to give me money. 22 Q. So you demanded of Jeffrey Epstein -- 23 A. Not demanded, but... 24 Q. Did you say the words to him that you 25 wanted money? 1 A. Yes. 2 Q. Tell me what words you used. 3 A. I don't know the exact words. 4 Q. Well, what's your best recollection of the 5 words? 6 A. I don't have a best recollection because I 7 don't remember. 8 Q. Well, why did you tell him to pay you 9 money? 10 A. Because I was upset with even being there. 11 Q. Well, what had you done that you thought 12 you were entitled to money for? 13 A. I didn't do anything. 14 Q. So why did you think he would pay you 15 money? 16 A. Because I don't !mow why. I just — for 17 being in his house and him putting me through what he 18 did, I was pissed off and -- 19 Q. What even made you think that he would 20 give you mo 21 A. Becal:M. was there. 22 _Q. Oh, were you asking for money for bringing 23 M.? 24 A. No, because 1 didn't bring her. 25 Q. Okay. So how much did you ask for? Page 322 '13 Page 323 1 A. He gave me 200. 2 Q. How much did you ask for? 3 A. I didn't ask for anything. 4 Q. Well, you just told me you told him that 5 you wanted money. 6 A. Yeah, but I didn't ask for a specific amount. 7 Q. So you well, you — did you just say, 8 want money? 9 A. I don't recall how I asked him. 10 Q. So you might have asked him fora specific 11 amount 12 A. I don't think I did. 13 Q. You just have no recollection? 14 A. !don't have no, no. 15 Q. But you know you got money. 16 A. Yes. 17 Q. You went to this horrible place and you 18 got money for going there? 19 k Yes. 20 Q. And you took the money? 21 A. Yes. 22 Q. Asa matter of fact, you demanded the 23 money. 24 MR. MERMEISTEN: Form. 25 THE WITNESS: I didn't demand it. 32 (Pages 320 to 323) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.061.976.2934) Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601-061.976-2934) • 1a30246a-bc9d-4107-90a1-6373o816de0d EFTA01076467 Page. 324 Page 3: 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 BY MR. LUITIER: 2 Q. You asked for it? 3 A. Yes. 4 Q. But no recollection about the amount? 5 A. No. 6 Q. Do you know what the denominations of the 7 bills were? 8 A. No, I know he gave me $200. Q. Okay. Was it cash? A. Yes. Q. Do you know what the denominations were? A. No. Q. When you asked for the money, what did he say to you, if anything? A. He said no. Q. And then what was the discussion between you and he? A. Then we left, and then he called me back to come back and get it. Q. Oh, so it wasn't when you were in the house initially? A. No, it was. I don't know where it was, but it was in the house or outside of the house. Q. Well, stop. La's go slow. A. Okay. 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't, I don't, I really don't know. Q. Was she there an hour? A. I really don't know. Q. Okay. And when she came down, did she have any money? A. Yeah, she had money. Q. What did she have? A. I don't remember how much money she had Q. Did she have cash? A. Yes. Q. Did you see the cash? A. I remember seeing the cash, but — Q. What denominations were they? A. I have no idea. A. Q. A. Q. A. Q. A. Q. A. Q. Did you ask her what she got paid for? I figured what she got paid for. Did you ask her what she got paid for? No. Did you — I assumed it. Did she tell you what she got paid for? No. And you don't know how much it was? No. When you say you, you know what she got Page 32 1 Q. Whore were you on this occasion the second 2 time when you first laid eyes on Jeffrey Epstein? 3 A. I was in the kitchen. 4 Q. Okay. 5 A. I don't remember if he came down to the 6 kitchen and got us to walk us out, or how it happened. 7 I cannot tell you because I don't remember. 8 Q. Well, did he come down from upstairs? Did he come down alone? A. I was in the kitchen. Q. W e the other two girls with him? A. M. came down first. Q. Oka rad — Q. there was you, and n, and the chef in the kitchen? A. Yes. Like, it was me first. And then I guess went upstairs. I don't know what they did, but she cant down, and then.. was still up them for a little while. Q. How long was upstairs? A. I don't know. Q. Did.. tell you what happened? A. No. Q. Was she there more than a half hour? 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 327 paid for, did she -- what did you think she was getting paid for? A. I was thinking she was getting paid $400. Q. For what? A. Bringing-. Q. Okay. And so after she comes down, when do you next sec either. or Mr. Epstein? A. comes down. I don't remember -- I mean, .., I think I saw came down in the kitchen, and I don't remember how, but I know I saw Jeffrey Epstein. And we left after I... Q. Well, when you saw Mr. Epstein, you were in the kitchen? A. I'm, Pm pretty sure. I don't remember exactly is what I'm say to you. Q. Was, were both and present when you saw Mr. Epstein for the first occasion on this second visit? A. Yes, yes. Q. Did you speak words to him? A. Yes. Q And is that when you asked him for the money? A. Yes. Okay. And what did he say to you at that (561) 832-7500 33 (Pages 324 to 327) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051-976-2834) Electronically signed by cynthia hopkins (601-061.976.2934) 1 a30246a•bc9d.4107.90a1.9373e816deOd EFTA01076468 Page 328 Page 330 1 time, no? 2 A. No. 3 Q. What happened next? 4 A. I said, fine, and I left. 5 Q. Okay. When is it that he, that he 6 contacted you? 7 A. He called me like two seconds after we left 8 the house. 9 Q How did he contact you? 10 A. By phone. 11 Q. Okay. And you spoke directly with him? 12 A. Yes. 13 Q. And what did he say to you? 14 A. Come back and get the money. 15 Q. And so what did you do? 16 A. I went right back and got the money and left. 17 Q. Well, you, you had to tell somebody in the 18 car to turn arotmd. 19 A. Well, yeah, ■. 20 Q. Okay. And what did you tell them? 21 A. They heard the phone. They heard what I said 22 on the phone. 23 Q. Yeah. Okay. And so you went back. Did 24 you go up to the door? 25 A. Yeah. 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 Q. Did M. tell you anything? A. No. Q. Did you ask either of them anything? A. No. Q. So, this traumatic event that you had, you went back, you sat down. You had warned your friend don't do it. A. Yes. Q. But when you got in the car, you had no conversation with either girl about what happened upstairs; is that right? A. I already — you're right, yes. Q. Were you in tears? A. Was I in tears? Q. Yeah. A. No. Q. Did you feel horrible? A. !didn't want to be there. Q. Did you feel so bad that you wanted to get money from Mr. Epstein? A. !felt, I felt mad about being there — Q. Did you -- MR. MERMELSTEIN: Form. BY MR. LUTTIElt: Q. -- feel like you did anything to get paid 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 together? 20 A. No. 21 22 23 24 25 Page 329 Q. Were you met at the door by anybody? A. Him. Q. Okay. And what did he do? A. Here. Q. But you don't know how much he gave you? A. No, no, 200. He gave me 200. Q. He gave you 200, right. And then you got in the car? A. Yes. Q. And you left. Have you seen Mr. Epstein since? A. No. Q. Okay. And when you got in the car to ride, did you guys leave there and go someplace? A. I don't recall. Q. You don't know where you went? A. No. Q. Do you know how long you were in the car Q. Did M. ever tell you what happened upstairs? A. No, I already, I figured what happened. O. My question is did II tell you? A. No. 1 2 3 4 5 6 7 8 9 10' 11 12 13 14 15. 16 17 19 20 21 22 23 24 25 Page 331 for? A. No. Q. Just an opportunity to get money? MR. MERMELSTEIN: Form. THE WITNESS: No. BY MR. LUTTIER: Q. Didn't bother you to take the money, did it? A. No. Q. What did you use the money for? A. I have no idea. Q. Did you spend it on luxury items that you wanted? MR. MERMELSTEIN: Form. THE WITNESS: I don'treinewber. It could have been anything. It could have been from food to — I have — like, I don't — I really don't know. BY MR. LUTTIER: Q. Did you ever have a conversation with at any time about what °muffed? A. Not that I recall. I mean, I could have, but . I don't recall it Q. Do you recall where you returned to — A. No. 34 (Pages 328 to 331) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-061.976-2934) Electronically signed by cynthia hopkins (601-05141764934) Electronically signed by cynthia hopkins (601-061-976-2934) 1a30246a-bc9d.4107-90a1.6373e816deOd EFTA01076469 Page 332 Page 334 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 Q. — alter this visit? 2 A. No. 3 Q. Did ever tell you i f she ever went 4 back to Mr. Epstein's? A. I think she went back again. Q. Did I. tell you whether she ever went back to Mr. Epstein's? A. I don't I don't know what instance she was 9 telling me about. She told me she had a bad experience 10 with him. 11 Q. Did la ever tell you whether she went 12 back to Mr. Epstein's? 13 A. I don't know about 14 Q. Okay. And since that day when you went up 15 and took the money in your hand from Mr. Epstein, 16 your 5200 for sitting in his kitchen, you've never 17 seen him since then? 18 A. No. 19 Q. Okay. When was the first time you told 20 anybody about that incident? 21 A. The first time I told anybody besides like 22 • already knowing? 23 Q. Yeah. 24 A. First time I told an y? 25 Q. Yeah, other than an and Page 333 A. I don't — anybody? Like any, anybody at all? 2 Q. Anybody, Yeah, anybody. 3 A. I don't recall the first person that I told. 4 Q. How long was it after that that you told 5 somebody? 6 A. It was a little while. 7 Q. How long is a little while? A. Well, I held it in fora while, so l don't — I mean, I don't have an exact time frame It's just — Q. Less than a month? A. No. Q. More than a month? A. No. It was years. Q. Years, plural, years? A. A year. Q. So, after — other than s and I., did . you — strike that. • Did ou have any further conversation with i n IN and about going to Epstein's house; that is, either e times that you went the first time or the second time? Ell ou have, ever have any other conversation with or El. about it? A. Not that I can recall, no. Q. Ever'? A. Not that I can recall. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 Q. Right up to today. A. I mean, I. and I vaguely talked about it, but it's not like we got into it. It was, it was nothing really. Q. Okay. So both of these incidents happened sometime in the year 2002? A. Yes. Q. And since 2002, for the last seven-Plus you've never had a conversation with IIIII or 4, about it? I can't remember if I have or not. Q. Who is the first person you ever had a conversation with, or told anything about the Epstein matters? A. I honestly — MR. MERMELSTEIN: You're, you're. MR. LUITIER: Not your lawyer, yeah. MR. MERMELSTEIN: No, not the lawyer, no. You're talking about any visit? MR. LUITIER: Yeah. MR. MERMELSTEIN: Okay. MR. LUTHER: Any, any visit. THE WITNESS: The only person I can think of that I lust told, because it was . embarrassing to me, it was probably a Page 335 therapist. BY MR. LUTTLER: Q. Well, who was that? A. I can't recall. Q. Well, what — in what state? A It was probably in Virginia. Q Okay. And, and you didn't go to Virginia until what year? A. 2006. Q Okay. And so is it one of those two therapists you told me, the psychologists or the psychiatrist that you told me you went to see in Virginia? A. Yeah. Q. So for, what, over four years you remained silent and never said anything to anybody about it? A. Kept it inside, yes. Q. Okay. And you didn't tell your boyfriend about it? A. No. I recently told my husband about it. Q. When, what you say recently, when was the first time you told your husband about it? A. In Virginia. Q. After your wedding? A. Yes. 35 (Pages 332 to 335) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by cynthia hopkins (601-061-976.2934) Electronically signed by cynthia Hopkins (601-051-976-2934) Electronically signed by cynthia trot:tins (601-051-976-2934) la30244a4x9d41 07400 43730111dad EFTA01076470 Page 336 Page 338 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 Q. And what was his reaction? A Disgusted. Q. What did he say? A. Why would you go to an older man's house to give him a massage and do sexual things that happened. He still gets upset about it. MR. LUTHER: I'm not going to finish. This is probably as good a place as any to stop. Ifs a quarter to 4:00, and we'll just arrange a time to reconvene. BY MR. LUTHER: things. A Q. A. A. A. Q. A. Q. A. Q. Well, let me, let me ask a couple of Where do you live now? I live in Virginia Olat.y. What, what's the address? Its — Yeah. Yeah. Apartment And you live there with your husband? Yes, and my -- Is he out — is he badc to the US? Yes. So he's stationed at a base 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 A. But ho might reenlist. Q. All right. A. So I don't know. MR. LUTHER: Okay. ' THE VIDEOGRAPHER: Going off the record at 3:44 k This marks the end of this portion of the deposition. (Witness excused.) (Deposition was adjourned) Page 337 1 A. No, I mean, he's at the Norfolk base, but he 2 comes home on a daily basis. 3 Q. Okay. But he's here in the US? 4 A. Yes. 5 Q. And how long has he been back? 6 A. What was it? When did he get back? When I 7 finished — Dec -- Fm going to say December. 8 Q. ()fit° — of 9? 9 A. Yea. 10 Q. Okay. And, and what are your immediate 11 plans about where you-all are going to live? 12 A. After he gets out of the military? 13 Q. No, right now. I mean, do you plan to 14 continue to live in Virginia? 15 A. Yes. 16 Q. How often do you come to Florida? 17 A. I, when he's there, I rarely come here. 18 Q. Okay. And is he scheduled to go out on 19 any other deployments? 20 A. As of now, no. 21 Q. When does he get out of the military? 22 A. Next April. 23 Q. Apiil °fit° or April of '11? 24 A. 'U. 25 Q. Okay. 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 339 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that JANE DOE NO.5 personally appeared before me and was duly sworn on the 26th day of May, 2010. Dated this 10th day of May, 2010. Orka.c: att•isiAs Cynthia Hopkins, RPR, FPR Notary Public - State of Florida My Commission Expires: February 25, 2011 My Commission No.: DD 643788 ..etASZT=St 36 (Pages 336 to 339) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051478-2934) Electronically signed by cynthia hopkins (601451-976-2934) Electronically signed by cynthia hopkins (601451476.2934) 1.30240tbc9d4107-9024-6373•1116ds0d EFTA01076471 Page 340 Page 342 • 1 CERTIFICATE 2 THE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 5 I, Crthia Hopkins, Registered Professional Reporter, Florida Professional Reporter and Wary 6 Public in and for the State of Florida at large, do hereby cerillY that I was atthaized to and did report said deposition in stenotype; and that the foregoing pages we a true and correct transcription 8 of my shorthand notes of said deposition. 9 I further artily that said deposition was taken at the time and place hereinabove set forth 10 and that rho taking of said deposition was commenced and completed as hereinabove set out. It I further catty that I am not attorney or :2 counsel of any of the parties. nor am I a relative or employee of any attorney of counsel of party 13 connected with the action. nor am I financially interested in the action. 14 The foregoing cauficanon of this transcript 15 does not apply to any reproduction of the same by any means Wens under the direct control and/or 16 direction of the certifying reporter. 17 Dated this IOth day of March, 2010 18 19 20 21 AS crlie Cynthia Hopkins, RP FPR 22 23 24 25 1 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are true and correct to the best of 8 my knowledge and belief, with the exception of any 9 corrections or notations made an the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2010. 14 15 16 17 18 19 JANE DOE NO. 5 20 Job #1312 21 22 23 24 25 I DMZ Much 10k 2010 TO. JAM DOE NO.S do Sart S. klornetagia 5fERMELS1804 &HOROWITZ, r 18101 lesottec Ocoletor0 Sae 211i Allot Marl& 13140 9 to 11 12 I) 14 15 la 13 le 19 20 21 22 23 24 25 IN RE to Melt 2n Fp*: CASENO : ell-th40119-MARRABOHMON flea it notlot tat co PS*, the 204k ct Petony. 2010, you toe rye dcpmeica abtherefttn4 mime. Al the lime, we. 464 wain *eon It it thaw remssary Ixoya. svi rue tkpositko. As 10004421eweed 4:k S llMnnplu'abi furnith:d toyaz drat), sox Goad Pkoe read eke falemiwz metrocums mnfully. At die the dt taLlemptrzu W fin: at enact 'Sm. As you mei yeti' eltscrjoon. toy c/angen or ortcticat Iha>oe with v mac 0:001a be toed co Qc ernes 3xvt. sung F"," 4'4 bx mmtedred elarits DO NOT one ens um...no Go:e you hen twite ttamars ar:Intm: arty tots. be smelt/ %In god dye Qw ones stem ad room tee pipe Io me t.aadorctrcadrd tip tl* depceLixa withe. a ffe•Enilth. erne, the original. tulOch ha lma>, trot fcr.v.v&I to deaden% beeeery, ml) be fkd with Fs Clete el dt Gun Wyoo ant .0 *any Yme .Sostwt Mope sot ova In the Wat, at the bon= delis otter 4114140211 t taus Voyeurs ritia rAlcoAs C3m1W414 4,161. 11111.FPR 10o keeeby vents eipxoeet Waft NO. 5 Page 341 Page 343 ERRATA SHEET 2 IN RE: JANE DOE NO. 2 VS. EPSTEIN at Cynthia11°0So 3 DEPOSITION OR JANE DOE No. 5 TAKEN: Maury 26,2010 4 JOB NO.: 1312 5 DO NOT WIT ON TRANSC1UPT - ENTER CHANGES HERE PAGE # LINE S CHANGE REASON 6 7 8 9 10 11. 12 I3 14 15 16 17 Please forward the original signed arato sheet to this office so that copies may be distributed to all 18 potties. 19 Under penalty of perjury, I declare that I have read my deposition and that it is true and correct 20 subject to any changes in form or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 37 (Pages 340 to 343) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601-051.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) 1 a30246a4acgd-4107-90.14373•816defld EFTA01076472