Page 397,

Page 397, UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME III OF III 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. 3 Tuesday, April 6, 2010 2:07 - 5:07 p.m. 250 Australian Avenue Suite 150 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1577 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hooking (601 $d47f016-be69-47a2.9d44-6a177536c37o EFTA01076720 EFTA01076721 Page 394 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 STUART S. MERMELSTEDI, ESQUIRE MERMEISTEIN & HOROWITZ, PA. 4 18205 Biscayne Bouleved Suite 2218 5 6 E-mail: 7 On behalf o tieD t 9 ROBERT D. CR1TTON,HL, ESQUIRE BURMAN, CRITTON, L1JTITER & COLEMAN, LIP 9 303 Banyan Boulevard Suite 400 11 Phone: West 'da 33401 E-mail: 10 12 . 13 ALSO PRESENT: 14 15 16 17 18 19 20 21 22 23 24 25 Daniel Downey, Videographer Visual Evidence, incorporated 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 396 CONTINUED PROCEEDINGS THE VIDEOGRAPHER: This is the 6th day of April 2010. The time is approximately 2:07 p.m. 'Ibis is the videotaped deposition of Jane Doe No. 3 in the matter ofJane Doe versus Jeffrey Epstein. This deposition is being held at 250 South Australian Avenue, West Palm Beach, Florida. My name is Daniel Downey. I in the videographcr representing Visual Evidence. Incorporated. Will the attorneys please announce their appearances for the record? MR. MERMELSTEIN: • Sttiart Memielstein for the Plaintiff, Jane Doe No. 3. MR. CRITTON: Bob Critton for Jeffrey Epstein. (JANE DOE NO. 3), Having been first duly sworn or affirmed, was examined and testified as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR CRITTON: Q. Afternoon, Ms. No. 3. 1 2 3 a 9 10 11 12 13 14 15 16 17• Page 395 INDEX EXAMINATION DIRECT CROSS REDIRECT JANE DOE NO. 3 BY MR. CPSITON 396 EXHIBITS EXHIBIT DESCRIPTION PAGE DEFENDANT'S EX. 4 PLAINTIFFS AMENDED 426 . 19 SUPPLEMENTAL ANSWERS TO INTERROGATORIES 19 DEFENDANTS EX. 5 PLANTUFS 427 SUPPLEMENTAL ANSWERS TO 20 INTERROGATORIES DEFENDANT'S EX. '6 PLAIITI1FFS ANSWERS 528 21 TO DEFENDANTS FIRST ATIERROGATORIES 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 397 A. Hello. Q. Have you done anything to prepare for your deposition today; that is, have you looked at anything? A. Yes. Q. Tell me what you looked at. A. My transcript. Q. From the first session on February 19th? A. Yes. Q. Did it appear to be accurate to you; that is, the testimony that you gave was accurate? A. Yes; MR. MERMELSTEIN: Objection to form. BY MR. CRITTON: Q. Have you spoken with anyone other than your attorneys? Same kind of rules. If I ask you a question, have you spoken with anyone, I am not — I'm not allowed to ask questions about discussions you've had with your attorneys, so I am excluding your attorneys and anyone who works in their office. Okay? A. Okay. Q. Have you discussed your deposition with anyone -- (561) 832-7500 2 (Pages 394 to 397) PROSE COURT REPORTING AGENCY, INC. • a Electronically signed by cynthia hopkIns (601 Electronically signed by cynthla hopkIns (601 Electronically signed by cynthia hopkIns (601 8d471015-be89-47a2.9d44.6a177636c37e EFTA01076722 Page 398 1 A. Yes. 2 Q. .'-- since you gave it? 3 With whom did you discuss your deposition? 4 A. Jane Doe No. 4 and Jane Doe No. 7. 5 Q. Have you seen Jane Doe No. 4 and/or Jane 6 Doe No.7 since February 19111ot2010 -- 7 A. Yes. 8 Q. — your deposition? 9 On how many nrrAsions? Now, I'm talking 10 about seen them as distinct from spoken with them. 11 A. One. 12 Q. Where, where did you-all meet? 13 A I saw Jane Doe No. 7 only. 14 Q. Saw Jane Doe No. 7. All right. And wheri 15 did you see Jane Doe No. 7? 16 A. My birthday party. 17 Q. All right. Where, where was with your 18 birthday party? 19 A. At Noche. 20 Q. That's". that's up in The Gardens 21 near Soverel 22 A. Yes. 23 Q. And Jane Doe No. 7 came to your party? 24 A. Yes. 25 Q. . How many people did you invite to your Page 399 1 party/ 2 A Ten. 3 Q. Did anyone else come who was, who is a 4 Plaintiff against Mr. Epstein? 5 A. No. 6 Q. Was anyone there other than Jane Doe No. 7 7 who knew you were a Plaintiff? 8 A. No. 9 Q And let's see. You were born on 10 M, so it was about a little over a month ago. 11 Had Jane Doe No. 7 given her deposition? 12 A. I don't know. 13 Q. Did she talk about her deposition at all? 14. . A. Yes. 15 Q. Okay. And what did she say about her 16 deposition? 17 A. She was nervous. 18 Q. Okay. She liked me? 19 A. I, I don't know. 20 MR. MERMELSTEIN: Objection to forth. 21 THE WITNESS: I don't know. 22 BY MR. CRITTON: 23 Q.' Just thafs all she said, she was nervous 24 during the deposition? 25 A Yes. Page 400 1 Q. Okay. And that's the extent of what she 2 said about the deposition to you? 3 A. She asked me questions, what could happen. 4 Q. What do you mean? 5 A. Like what, what could take place. 6 Q. Oh, at her deposition? 7 A. At a deposition. 8 Q. Oh, when, when you, when you were talking 9 about discussing the deposition, were you talking 10 about your deposition with Jane Doe No. 7 or Jane 11 Doe No. 7 was talking about the deposition she had 12 given? 13 A In general. 14 Q. Okay. So, she had, she just said she was 15 nervous, but you don't know whether she had given 16 the deposition and was nervous or was about to give 17 the deposition? 18 A_ Correct. 19 Q. All right. I understand now. 20 Did you tell her what had happened at your 21 deposition? 22 A No. 23 Q. So, just so the jury knows, you had given 24 a deposition and you didn't tell her one thing about 25 the deposition that went on? 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 401 MR. MERMELSTEIN: Objection to form. BY MR. CRITTON: Q. Is that what you're telling us? A. Exactly. Q. All right. How long, how long — what time did your party start and what time did it end? A. We had dinner with my family first, and then we went to the club about 10:30,11:00, somewhere around there. Q. A. Q. A. A. Q. A Q. What' s last name? And what time did the party shut down? I left at 2:30, 3:00, around there. And did you go home? Yet Did you go home with anyone? With my girlfriends. And who's that? Q. A A. Yes. Q. And is the ono, I think you told tote that you had told her that you had been at Epstein's house? A. Yes. 3. (Pages 398 to 401) PROSE COURT REPORTING AGENCY,. INC.:- Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8t4171015-be89-47a2-91144-6at77536c37e EFTA01076723 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 402 . Q. Does know that you were at .Mr. Epstein's house? A. No. . Q. She doesn't And she doesn't know you're a Plaintiff in this lawsuit? • A. No. Q. Let me just stay with the other individuals, as Question 11 in your second set of interrogatories that was sent to you, you listed people who were your five closest friends, and you apparently only named four -- . A. Yes. Q. — Prom to 201 ne was (phonetic) A. Q Oh, high school? A. Since Wore high school. Q. A long time? A. Yes. Q. And she doesn't — does she know you're a Plaintiff in this lawsuit? A. No. You've known her since Page 404 1 Doe No. 7 tell you what she's doing right now 2 • work-wise, for fun, or is she still in school? 3 . A. I know she's still in school. 4 Q. . And do you know what she's going to be, 5 what she wants to be? 6 A. I think business, something to do with 7 business. 8 Q. Did she tell you whether she was dating 9 anyone? • 10 .. A. No. 11 Q. How about — and then you said — have you 12 spoken with Jane Doe No. 7•-- other than seeing her 13 the one night over the last month and a halt have 14 you continued to speak with her regularly? 15 A. Prior to spring break for her college. 16 Q. Which was when? 17 A. Two weeks ago, somewhere. 18 Q. Where was she headed to? 19 A. ICey West, Miami. . 20 Q. And you haven't talked to her since then? 21 A. No. 22 Q. Other than the one time you saw her and 23 the other conversations that you had, have you 24 discussed the cases at all? 25 A. No. Page 403 1 Q. Does she know — then, obviously, she 2 wouldn't -- well, does she know that you ever went 3 to Mr. Epstein's home — • 4 A. No. 5 Q. — on one occasion — 6 A. No. Q. of the four occasions that you 8 described?. 9 And M, she's still one of your best 10 friends? 11 A. Yes. 12 Q. Did you — have you discussed with her the 13 deposition you gave? 14 A. No. 15 Q. And does she — she knows you went to 16 Epstein's? 17 A. ' Yes. 18 Q. All right. Any guys at the party or 19 a girl patty? 20 A. There was guys at the club. 21 Q. Understand that, but they came to your 22 party? 23 A. Yeah. 24 Q. Separate and apart from having seen Jane 25 Doe No. 7 -- well let me ask you this: Did Jane Page at 1 Q. Jane Doe No. 4, when did you speak with 2 Jane Doe No. 4, you haven't seen since 3 February 19th, correct? 4 A. Correct. 5 Q. But you've spoken with her? 6 A. Yes. 7 Q. Because you speak with her regularly? 8 A. No. 9 Q: How many occasions have you spoken with 10 her? - 11 A. Once. 12 Q. Okay. And what was the occasion; did she 13 call you or did you call her? 14 A. I called her. 15 Q. About? 16 A. Birthday. 17 Q. Just to say happy birthday? 18 A. No, my birthday. So, l invited her to my 19 party. 20 Q. Oh, and she said what? 21 A. Yeah. 22 Q. But she didn't show? 23 A. Correct 24 Q. Do you know why she didn't show? 25 A. No. l.e....S.Niaafted.nefeJala 4 (Pages 402 to 405) PROSE COURT 'REPORTING' AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-1)039-47a2-9d44-6a177536c37o EFTA01076724 Page 406 Page 408 4 5 6 8 9 10. 11 12 • 14 15 16 17 18 19 20 21 22 23 24 25 i. Q. Did you ever talk to her about your 2 deposition in any way? 3 A. No. Q. -And ill understood your testimony, the only thing you looked at is your transcript in preparation for today? A Correct Q. I see in your answers to interrogatories, which is consistent with testimony, do you still work for the A. A. Yes. Q. And you describe your, yourself now as the lead hostess? A. Yes. Q. Okay. And I think you told us you were the maitre di. Same thing? A. Yes. Q. And you're working 40 hours a week? A. No. Q. How many hours a week are you working now? A. liveries. Q. What's your, your average? 1 2 A. Can you rc — can you — 3 Q. Sure. 4 A. . methin more sim le. 5 9 A. Yes. 10 Q. Okay. So putting aside those individuals, 11 have you had a chance to look at your, at least the 12 physicians, psychiatrists, psychologists, et cetera. 13 that you've disclosed that you had seen. 14 And my question to you is, is: Have them 15 been any psychiatrists, psychologists, therapists 16 that you've seen for solely issues relating to your 17 visit to pstein's home? 22 23 24 25 -- well, let me strike , didn't disclose anything about Epstein, correct? Page 407 1 A. Thirty-five. 2 Q. Are you considered a MI-time employee? 3 A. Yes. 4 Q. And did you tell me you may have told 5 'me, are you entitled — do you get benefits, health 6 benefits? 7 A. Yes. 3 Q. And have you used your health benefits at 9 all? o A. 1 2 3 I 13 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 409 A. I don't know. Q. All right. We'll, we'll get to your visit to Mr. Epstein's home? A. No. Okay. In fact is that correct? A. Yes. Q. All right. If I separate — and then let me just focus this, is you testified at your last deposition that you went to Mr. Epstein's house on four occasions, correct? A. Yes. Q. Okay. One time you went upstairs and gave Mr. Epstein a massage. And I'm not going to go through the details. We've covered that on the last deposition. But one time you went upstairs and gave him a massage and you described what occurred, correct? A. Yes. Q. The second time you took, I think, Jane Doe No. 2, but you stayed downstairs — A. Yes. 1 • • 1.5.0..\)eu.-44.040. • 5 (Pages 406 to 409) PROSE COURT REPORTING AGENCY, INC.. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471016-be89-4782-9d44-6af77636c37e EFTA01076725 Page 410 1 Q. correct? . 2 The third time you took I.L., but you 3 stayed downstairs. 4 A. Yes. 5 Q. And the fourth time you went, you — to 6 • Mr. Epstein's house; you took Jane Doe No. 4 at her 7 request. 8 A. Yes. 9 Q. Okay. So if I refer to a one-time visit 10 in my questioning to you, a one-time visit to 11 Mr. Epstein's house that would be the one time that 12 you went upstairs. Okay? • 13 A. Okay. . 14 Q. Because if I understand your testimony, 15 you're not alleging that anything bad happened when • 16 you went back, or bad or inappropriate or traumatic 17 at any time after the first visit, correct? 18 A. No. 19 Q. Okay. Well, what do you allege was 20 traumatic about your taking Jane Doe No. 2 to 21. Mr. Epstein's home on the second occasion? What 22 happened to you that you consider traumatic? 23 A. Many things. 24 Q. Name one. 25 A. Anxiety. 2 3 4 .6 :7 g 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 412 know how to describe it. Just scared. I was scared. Q. Okay. You don't know what you were scared of or why you were scared, but you were scared — A. !just got a feeling inside — Q. La me, let me finish the question. If I understand your answer, you were scared; you were fear, fearful? A. Uh-huh. Yes. Q. But you don't know why on the second occasion? A. It's a combination of things. ' Q. What things? A. Not knowing the outcome, what's going on, just constant thoughts. Q. Of what? Constant thoughts of what? • A. Many things; him, the house, the property, people, people that you know, staff. Q. But no one had ever threatened you before at the house, had they? A. What do you mean? Q. No one had threatened you; that is, either verbally or physically threatened you, had they? A. A threat could be all different sorts of things to me. Q. Well, had anyone physically assaulted you Page 411 1 Q. Okay. And why, because you took a good 2 friend to Mr. Epstein's house to suffer, as you've . 3 described it, the same emotional trauma, 4 embarrassment, humiliation that you experienced on 6 MR. MERMELSTEIN: Objection to form. 7 THE WITNESS: You lost me there. 8 :. BY MR. CRITTON: 9 Q. Okay. Is, is your emotional — well, let 10 me strike that • . 11 You said on — as a result of having been 12 at Mr. 's house on a second occasion when you 13 didn't I think you didn't even see Mr. Epstein on 14 the second occasion, did you? 15 A. No. 16 Q. Okay. So, but you say you had anxiety as 1 18. . A. Yes. 1 9 Q. Okay. And what caused the anxiety? 20 • A. I don't know. 21 Q. Anything else other than anxiety on the ' 22 . • second occasion? 23 A. Fearfulness. 24 Q. Of what? 25 A. Just scared of 'List I don't know, I don't 1 at the house? A. Yes. 3 Q. Okay. Who? 4 ; • A. Epstein. Page 413 5 your first occasion? 5 Q. So, you were physically assaulted on — 6 and were you struck or touched? 7 A. Touched. 8 • Q. You were not physically struck in any way? 9 A. Not hit. 10 MR. STEIN: Objection to form. 11 BY MR. CRITTON: Epstein 12 Q. I'm cony? 13 A. Not hit 14 Q. So, you went back a — to Mr. Epstein's . H • house on the second time because you thought you . 16 might be physically assaulted?. 7 a result of going there? 17 A. I didn't say that. 18 Q. Okay. Well, if you thought you were going 19 . to be physically assaulted, or you were so scared as 20 - you've just described, or so fearful as you've just 21 described, why then did you return to Mr. Epstein's . 22. house on the second occasion? 23 . A. Because I was young and I was vulnerable and I 24 • wasn't thinking. • 25 Q. Well, but you were anxious, scared, 6 (Pages 410 to 413) PROSE COURT REPORTING AGENCY, INC. (561) .832-7500 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthla hopkins (601 8d47t016•bo69-47a2.9d44.6af77636c37e EFTA01076726 8 9 10 11 12 13, 14. 15 16 17 18 19 20 21 22 23 24 25 Page 414 1 fearful and thought that you might be physically . 2 assaulted, and you still went to Mr. Epstein's house 3 on a second occasion, comet? 4 . MR. MERMELSTEIN: Objection to form.. The 5 first deposition covered in great length her 6 thoughts and feelings in going back the second time. Tin not sure why we're revisiting all of a that. 9 MR. CRITTON: Well, this isn't a first or 10 second deposition. it's a completion of the 11 first, the first and only deposition and Tin 12 allowed under tbe, the record -- 13 MR. MERMELSTEIN: I understand, but ifs 14 asked and answered many times. 15 MR. CRITTON: Okay. Fine. 16 BY MR. CRITTON: 17 Q. You can go ahead and answer it 18 A. • What's the question? 19 MR. CRITTON: Cindy, would you read it 20 back, please? 21 (The requested portion of the record was 22 read by the reporter.) 23 THE WITNESS: Yes. 24 BY MR. CRITTON: 25 Q. . And is it your testimony that you were 1 2 3 4 5. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 416 and I don't remember, did you say you went into the • house of you did not go in the house? A. I didn't physically — like, I was by the pool, beach area outside. Q At that time did you feel anxious or scared? A. Yes. Q. Did you feel fearful or potentially physically threatened? A. Yes. Q. Okay. why? A. Because we were there forayer), long time. Q. Well, did you ever see anyone that day when you went to the house? A. No. Q. And when Jane Doe No.4 came down, was there anything — and I think, I think you've already said so, and I don't want to belabor the point, but she didn't Say anything or — to you that would have suggested that anything inappropriate or bad had occurred, did she? MtMERMELSTEN: Objection to form. THE WITNESS: No. BY MR. CRITTON: Q. Okay. Did her appearance appear other Page 415 traumatized by having been at Mr. Epstein's house on 2 a second occasion even though you never saw him? 3 A. Yes. 4 Q. On the third occasion you went to 5 Mr. Epstein's house, were you, as well, traumatized? A. Yes. Q. Were you anxious, scared, fearful and felt physically threatened as well? A. Anxious and scared, yeah. Q. But not -- but not fearful, nor did you -- A. All of the above. Q. — feel physically threatened? A.. All of the above. Q. But, so my question then is — MR. MERMELSTEIN: Let him finish the question: BY MR. CRITTON: Q. • So my question is: Why then did you go back on.a third occasion? MR. MERMELSTEIN: Objection, asked and answered. • THE WITNESS: I don't know. BY Mk CRITTON: • Q. On the fourth occasion that you took Jane Doe No. 4, or you drove Jane Doe No. 4, did 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 than normal to you? Let me rephrase that question. Did -- from your observations, did everything seem to be okay with her? MR. MERMELSTEIN: Objection to form. THE WITNESS: I guess. • BY MR. CRITTON: Q. And that was the last time you went to Mr. Epstein's house, correct? . A. Yes. Q. Why didn't you ever go again? A. I don't know: Q. Did anyone ever ask you to go again? A. I don't remember. Q. Pardon? A. I don't remember. Q. Have you had an occasion to speak with or Jane Doe No:2 since your last deposition? A. Yes. Q. With whom did you speak? A. Q. And when did yousee her? A. I never saw her. Q. All right. You spoke with her, and you did not see her, correct? • • A. Comet. 7 (Pages 414 to 417) PROSE. COURT REPORTING AGENCY, INC.' Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47fO15-be89.47a2-9d44.Saf77536c370 EFTA01076727 Page 418 1 Q. On how many occasions have you spoken with 2 her since 3 A. One. 4 Q. -- February 19th, 2010, which was the 5 start of your deposition? . 6 • A. One. 7 Q. Did she can you or did you call her? 8 A. She called me. 9 Q. Subject of the conversation? 10 A. That she heard I had settled. 11 Q. Did she tell you who she heard that from? 12 A. No. 13 Q. And how did she know you were even a 14 Plaintiff? 15 A. Good question. 16 Q. Did you ask her? 17 A. I asked. Igo: Where did you hear this from? 18 She goes: Oh, I was contacted by someone. 19 Q. Did, did you ask her whether she was a 20 Plaintiff in the case? 21 A. No. 22 Q. Okay. Do you know whether she is? 23 A. No. 24 Q. She has a — and she didn't indicate one 25 way or the other whether she was a Plaintiff? 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. January. Q. Did she ever mention to you ever about being a Plaintiff, you being a Plaintiff in a lawsuit against Mr. Epstein? A. She asked me. • Q. And you told her? A. No. Q. Okay. So, why would she — and again, when she said out of the blue, she called you after your first deposition, the start of your deposition and said, I heard you settled. And did you specifically ask her, and say where did you ever. hear I was even a Plaintiff or I had even filed a suit against Mr. Epstein? MR. MERMELSTEIN: Objection, form. Assumes facts. You don't have to file a suit in order to settle. THE WITNESS: She -- what I just said to you prior, she heard that I had settled. AM I go, no, I don't know what you're talking about. BY MR, CRITTON: Q. And then she changed the topic? A. No. She kept asking, she's like, you don't have a lawsuit? No. Q. So she pushed the envelope; she pushed you Page 420 I Page 419 1 A. Correct. I 2 Q. So, she calls you out of the blue. When 2 3 was the last time you had heard from her? 3 4 A. Prior — around her birthday which is in 4 5 February. 6 Q. Okay. So just before your deposition? 6 7 A. I don't know exactly when her birthday is. 7 8 Q. But sometime around her birthday you had 8 9 spoken with her? 9 10 A. Yes. 10 11 Q. Topic? 11 12 A. Going to Tree's Wings. 12 13 Q. Fm sorry? 13 14 A. Going to Tree's Wings. 14 15 Q. Which is what? 15 16 A. Aber/restaurant. 16 17 Q. She wanted you to come? 17 18 A. Uh-huh. 18 19 Q. Yes? 19 20 A. Yes. Sorry. 20 21 Q. And did you go? 21 22 A. No. 22 23 Q. All right. When's the last time you 23 24......jr saw her physically or in person? This is 24 25 (561)• 832-7500 Page 421 to find out whether you had a lawsuit against Mr. Epstein? A. Yeah. Q. And you kept telling her no? A. Correct Q. Anybody else call you since your -- since the start of your last deposition, or the start of your deposition about you being a Plaintiff in a lawsuit? A. No. Q. Do you know A. Yes. Q. How do you know A: School. Q. Friends with her? A. No. Q. And why nee You're saying that emphatically. Is there a reason that you're not friends with her? A. I never heard good things about her. Q. From whom? A. People. Q. Who do you friends with? A. She Went to I think She didnt to. my sch ,„...s.....2121hinL a 25 think she was hanging out with 8 (Pages 418 to 4 2 1) • PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkIns (601 ed471015-be89-47a2-9444-6at77536c37e EFTA01076728 Page 422 Page 4.. and Jane Doe No. 7 at one point. 2. Q. Okay. Was she ever friends with Jane Doe 3 No. 4?, 4 •. : A.. I don't know. 5 Q. • And who told you anything bad about her? 6 A Just rumors. 7 Q. Okay. And what are the rumors? 8 A. I donstimow. It was high school. 9 Q. So anybody can get a bad reputation in 10 high school? 11 A. Yeah. 12 Q. Whether it's true or not, you have no 13 idea? 14 A. Correct. 15 Q. All right. And did you say you had 16 actually met her? 17 A. Yeah. 18 Q. But you're not friends; you're just 19 acquaintances? 20 A. Not even that. 21 Q. You just know who she is; she knows who 22 you are? 23 A. Yes. 24 Q. You have an active Facebook? 25 A. Yes. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you used it at all? A. I went on there one time. Q. Okay. Did you put any information — did you have to set up a profile? A. That was already done. Q. She had already done that for you? A. Yes. Q. And what, do you go on and was your picture on as well? A. No. Q. It was just some background information on you? A. Yes. Q. All right. Did you ever search the site at all, go on anyone else's site? A. Yes. Q. A. Q. A. Q. A. Q. A. Q. Did you see anybody you lilted? No. Computers, you have your own computer? Yes. Laptop? Yes. • What kind? Dell. How long have you had it? 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 423 Q. And you used to have MySpace,but that's been canceled? A. Yes. Q. The question was asked whether you're a number of any web site, dating web sites, and you listed a fiend registered yourself for wealthymen.com. A. Yes. . Q. Which of your good friends did that to you, for you? Ltink it was. Q• M i? A. Yeah. Q. Okay. How did you find out that she had done that? A. She told me. Q. And what did you say? A. Why would you do that? Q. And she said? A. Because you just separated from Q. But you've never used the site? A. No. Q. Never? A. Not — no. Not like that, no. Q. Well, excuse me: Never is never. 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 425 A. Since Christmas. Q. And did you down — what did you have before that? A. The Toshiba. Q. Did you download — and how long had you had the Toshiba? A. Like my 19th birthday or 20th birthday. Q And before that, another laptop? • A. No, home, regular desktop. Q When you got the Toshiba, that was a laptop? A. Yes. Q Did you download the infommtion that's on your home computer onto that that was applicable to you? A. No. Q. Did your Toshiba, when you went from Toshiba to Dell, did you download the information from the Toshiba to the Dell? A. No. Q. You started from scratch again? A. Yes. Q. 'And you run your My — Fm sorry, your Facebook from your Dell computer laptop? A. Yes. Lay 9 (Pages 422 to 425) (561) 832-7500 PROSE COURT'REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 6d471015-bei39-4732-9d44-6af77636c37e EFTA01076729 Page 426 1 Q. Are you active on it? 2. A. On Facebook? 3 Q. Yes, ma'am. 4 A. l'es. 5: Q. Do You know ..? 6. • • A. Who? 7 Q. A lady by the name of 8 A. No. . Q. Do you know a person by the name of Jane 10 Doe No. I1? 11 A. Who? . 12 Q 'Jane Doe No. IL Jane Doe No. 13. A. No. 14 MR. CRITTON: What's the next exhibit, No. 15 4? 16 THE COURT REPORTER: Yes. 17 (Defendant's Exhibit No. 4 was marked for 18 identification.) 19 BY MR. CRITTON: 20 . Q. Let me show you Exhibit 4, if you want it. 21 These are your Amended Supplemental Answers to 22 Interrogatories. These, these were sent on 23 February 17th, 2010, just prior to your deposition. 24 • • I don't see that you signed these or 25 . executed these. So my question to you is, in Page 427 1 response to questions — well, first of all, in 2 response to -- start again. 3 Do you recognize Exhibit 4 — 4 A. Yes. 5 Q. as being your answers to 6 interrogatories? A. Yes. 8 • Q. And the information that's provided in 9 response to Questions 18,19,20, and 21, was that 10 true and accurate? 11 . MR. MERIvIELSTEIN: Let me object to form. 1.2 • Let me ask: Have you read this? 13 .. THE WTINESS: Yeah. Give me a minute. 14' BY MR. CRITTON: 15 • Q. Next one is Exhibit 5, which are your 16' • supplemental answers. 17 MR. CRITTON: I will show those to you '10 first. 19 (Defendant's Exhibit No. 5 was marked for 20 identification.) 21 MR. CRITTON: Five are the supplemental 22 ansWers to interrogatories. 23 THE WITNESS: Are these the same? 24 MR. MERMELSTEIN: Amended supplemental. and 25 then the supplemental. IMIIRIIIMWPFroK, b, ....-1C•A, W-femntedtbastra.rikiseuARes ( 561) . 8.32-7.509 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 • 1$ 19 20 21. 22 23 24 25 Page 428 THE WITNESS: Okay. MR. MERMELSTEIN: So, I guess there's — this, this is before this. • BY MR. CRITTON: Q. There's Jane Doe's 3's Supplemental A11511/O'8 to Interrogatorieswhich are dated November 13th, 2009. A. Yes. Q. Do you recognize — A. Yes. Q. — your answers to those interrogatories? - A. Yes.. Q. If you look at the very last page, you swore to the truth of the that is, the interrogatories were true and accurate on November 6th of 2009. Do you see that? A. Yes. Q. And then you filed supplemental, these supplemental answers, Exhibit 4, or your attorney sent them out on November 17th. A. Mine says February. Q. Let me see what you've got. A. f have this one. Q Oops I'm sorry. 1 was !coking — no. Oh, I'm got two. Your last page is February 17th, Page 429 2010? A. On this one, on Exhibit 4. MR. MERMELSTEIN: Well, that's not the certificate of service. That's the signature on the attorney signature line. MR CRITFON: Okay. Well, look at your certificate of service, and maybe we should clarify this. They were sent, faxed to me on February 17th,.2010. MR. MERMELSTEIN: Right. MR. CRITTON: Okay. But you have a certificate of service of November 17th, 2009. I'm going to assume that's incorrect. MR. MERMELSTEIN: Yeah, particularly since the fax legend on top — MR. CRITTON: That's what I'm saying. MR. MERMELSTEIN:. — shows it was 2/17. MR. CRITTON: Okay. So, the certificate — MR. MERMELSTEIN:. That's — • MR. CRITTON: — isjirst inaccurate. MR. MERMELSTEIN: Right. BY MR. CRITTON: . Q. And the most important thing is, is these appear to have been dated September -- I'm sorry, 10 (Pages 426 to 429) PROSE COURT REPORTING AGENCY, INC. Electronically signed by eynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-be8947a2-9d44.6af77536c37o EFTA01076730 Page 430 February 17th, 2010. And those answers — are those 2 answers; that is the amended supplemental answers to 3 interrogatories, true and coned? 4 A. Yes. 5 Q. All right. And it appears that at least 6 Question 18 says, List separately the names, address and phone numbers of all males including 8 Mr. Epstein excluding Mr. Epstein, with whom 9 you've had sexual activity since age ten by year. 10 : Describe the activity, and I'm paraphrasing now, the 1.1 date and whether you received money or 12 consideration. 13. On your ori nal answers; that is, Exhibit 14 5, you listed correct? 15' A. Yes. 16 Q. Okay. On the three months four months 17 later, three months later you listed 18 A. Yes. 19 Q. — correct? 20 A. Because I didn't know exactly what the 21. question was in detail of. 22 Q.. Okay. Do you remember getting the 23 definitions with it? We sent definitions so that 24 you could understand exactly what the nature of the 25 sexual activity was. 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 432 I A. Yes. . . Q. You list — in 2003 yoU list M, last name unknown, correct? A. Yes. Q•' And A. Yes. Q. correct? A. Yes. Q. Which of these individuals was the fit.: person that you had sexual intercourse with? A.' . The very first person? Q. Correct • • A. !don't blow if you're looking at the right one. Q. All ri t. Well I may have left his name •. off. So would have been the first person that you had sexual intercourse with? A. Yes. Q. Okay. When was that in '03; that is, the. beginning of '03, mid '03? A. Summer. Q. 'Oka . And was there any oral sex involved with Mr rid yourself — A. No. Page 431 1 MR. MERMELSTEIN: Objection to form. 2 THE WITNESS: Do I remember a definition? 3 BY MR. CRITTON: 4 Q. Right. Do you remember receiving 5 definitions along with it? 6 A. I don't remember. 7 Q. All right. Is it your testimony that 8 the — Exhibit 4 is the correct information 9. • A. Yes. 10 Q. — or the more correct information? 11 A. Yes. 12 Q. All right. Let's sta y then with 13 Exhibit 4. The 14 . That'syour husband? 15 A. Yes. 16 Q. .Any — since the last deposition, or since 11 Febniary 19th of 2010, any further chance of 18 reconciliation, or are you still going to move ahead 19. with the divorce? 20 '. A. I don't know. 21.. Q. . Okay. Then you talk about, and it appears 2Z at least, your first sexual experiences were in the 23 year 2003, correct? 24. A. ' Yes. 25 Q. All_right. And youhs 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 433 Q. Or strictly sexual intercourse? On how many occasions? A. One. Q. Is he someone you dated, or was this just an event? A. No. I never was taken out on a proper date. Q. And where did it occur? A. His house. Q. Voltmtexily, consensual? A. Yes. . Q. The next person after was . . whom? A. M. Q. Sony:mein school, school friend? A. Yes. Q. Was a school friend? • • A. No, he went to a different school. Q. How old was he? You — let's see, in . 2003, the Summer of 2003; you would have beer A. I'm notiSwith Math. • Q. Well, — A. So... Q. A. Okay. Q. All right. And how fast — how soon after 11 (Pages 430. to 433) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be89-47a2-9d44-6077636c37e EFTA01076731 • ' Q. A. Page 434 1 did you have your relation, sexual 2 intercourse with him? 3 A. I don't know. 4* Q. A month later, a week later? 5 A. I, I don't know. 6 Q. Do you remember where it occurred? 7 A. His house. 8 Q. Okay. Voluntarily, consensual? 9 A. Yes. 10 Q. All right. You understood you had a 11 choice either to have sex with him or not under the 12 circumstances? . 13 A. Yes. 14 Q. Strictly sexual intercourse, no oral sex? 15 A. No, there was oral. 16 Q. Both ways? 17 A' Yes. 18 19 Q. A. Mr ..Third person in '03? 20 Q. And did n ve sexual, sexual 21 intercourse 22 A. No. 23 Q. And you say —you listed it as digital 24 penetration. 25 A. Uh-huh. Page 435 1 Q. Meaning he was using his hand? 2 A. Yes. 3 Q. And that was the extent. Was there any 4 petting involved; that is, were you, were you, both 5' of you undressed and then he digitally penetrated 6 you? 7 A. No. 8 Q. Okay. Voluntary, consensual? 9 A. . Yes. 10 11 12 prior to everyone I just named. I'm going to correct 13 that. 14 Q. With S he would be, would . 15 have been the first? 16. A. Yes. 17 Q. And did he take your — this you describe 18 as digital penetration? 19 A. Yeah. 20 Q. Did he remove your underwear? 21 A. Not fully. 22. Q. He just reached within? 23 A. 'Yes. 24 • Q. All right. How old were you? This was in 25 2003? This \ vas before the Summer of '03 then? and • Were PROSE COURT A. I, I don't know. 5 Q. Had you for, for males before, had you 6 ever taken any or all or part of your clothes off 7 fora male before on a date? Not necessarily, it 8 doesn't haveto be a date, but when you were with a 9 guy 10 A. Have I ever taken my clothes off? 11 Q. No. Back in prior to 12 had you ever been with a guy and you had taken all 13 or a portion of your clothes oft? 14 A. No. 15 Q. Had you taken t 16 your clothes off prior to on of 17 A. No. 18 Q. Okay. was the first 19 Did ou remove any of your clothes for 20 21 A. Just my bottom. 22 Q. Okay. And he digitally penetrated you 23 with his hand? 24 A. Yes. 25 Q. Or with his fingers 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. Yes. Q. Voluntary, consensual? A Yes. Q. And with regard to every -- well, I'll come back to that. Did you touch him? A. Yes. Q. Okay. Did you touch his penis? A: Yes. Q. Did you masturbate him? A No. Q. Okay. Did he ever climax? A. Yes. Q. By himself? A. Yes. Q. All right. Did he do it himself in front of you? A; Yes. .Q. All right. And did you? A. No. Q. When I say you, did you climax? A. No. Q. All right. With Joseph, a? A. Yes. Q. Okay. — he would have been shortly after 12 (Pages 434 to 437) REPORTING' AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (501 8647(015-6989-4762-94:144-66177536c376 EFTA01076732 Page 438 1 A. Yes. 2- Q. Okay. And with where did that 3 - 4 A. His hoes 5 • ' Q. Joseph where did that 6 . moue? 7 A. My house. Q. Your room? 9 A. Yes. 10 Q. Any clothes come off/ 11 A. No. 12 Q. He reached underneath? 13 A. Yet. 14 Q. All right Did you touch him? 15 A. Yes. 16 Q. .Okay. And did you masturbate him? . 17 A. No. 18 Q_. Okay. Did he climax? 19 A. I don't know. 20 Q. Did you? 21 A. No. 22 all" person, now we're back to 23 24 A. Yes. 25 Q. Okay. And that was at his house? Page 410 1 . house when this occurred? 2 A. Where were — 3 Q. When — 4 • A. That's broad. • 5 Q. When he digitally penetrated you, where 6 • were you located? A. Ina house, in — Q. I understand that. A. Yes. Q. Did you go in a bednaom or something like that? A. Yeah, in a roorn. . Q. All right. And did you touch him? A. Yes. Q. Okay. Clothes come off? A. Yes. Q. Yours, his, both? A. Mine. Q. Any of his clothes come off? A. No. I don't think so. Q. Okay. You touched him. Did he climax? A. No. Q. Did you? A. No. Okay. The next of the first five 7 8 ' 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q 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 439 A. Yes. Q. Ms room? • A. Nes. Q. And everyone —eeu then the next person after that would have bee f A. Yes. Q. Third person also still in '03 — sorry fifth experience would have been With A. Yes. . Q. All right And was again • digital penetration? A. Yes. Q. His house? Your house? Nobody's house? • A. Friend's house. Q. Which friend? Q. All right And were there other people there at the time? A. 'Yes. Q. • All right And were other people involved in different, as well, in having relationships. ith guys and girls? A. Not that Pm aware of. Q. Where, where were you-all at the other (561) .832-7500 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 441 people we talked about, in all instances it was voluntary, consensual; you knew what was going on? .. A. Yes. O. All right. 'Who is next then after A. Q. A. No. .It was. Q. How many with on how many occasions did you have contact with him, physical contact with him; just the once? A. We were dating. . . Q. So it Was — was it more than once you had digital penetration? A. Yes.' Q. Okay. Was it more than once that you touched. him? A. Yes. Q. Okay: And from —as time went on, was it nagtipleeccasions that you would have touched each other, had physical contact? A. Yes. Q. Okay. And did you ever masturbate him or did you ever see him masturbate? A. I saw him masturbate, yes. 13 (Pages 438 to 441) PROSE COURT REPORTING AGENCY, ••INC:', . Electronically Signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 84147t016bie47a2404-0077530c374, EFTA01076733 Page 442 1 Q. Okay. Next person you say is 2 right? 3 A. Yes. 4 Q. And with him, is he someone you dated for 5 a period of time, or was this a one-time event? 6 A. Excuse me. No, I dated him. 7 Q. How long? 8 A. Three, four months. 9 Q. Okay. And on how many occasions did you 10 have sexual intercourse with him? 11 A. I don't know. 12 Q. More than ten times? 13 A. I don't — I don't know. I didn't count 14 Q. And I'm not, I don't mean it necessarily 15 exact, but multiple times? 16 A. Multiple times, yes. 17 Q. Voluntary, consensual, you knew what was 18 going on? You consented and he consented? 19 A. Yes. 20 Q. Are all ,e males that we've talked 21 about through =at this time, are these 22 individuals who are your same age or within a year 23 or two? 24 A. Yes. 25 Q. An. if I remember, is the Page 443 1 person — the only person with whom you had a sexual ' 2 relatimatiLpost or after -- since you separated 3 from 4 A. ' 5 Q. 6 right. 7 A. 8 Q. Is that right? 9 A. Uh-huh. 10 . trst didn't catch the front for 11 Mr. 12 A. Yeah. 13 Q. Let me start again. 14 My recollection was, is your — when we 15 • started your deposition, you said that you had had 16 sal relations with one on since you left 17 sic), and that was • 18. A. Yes. 19 Q. Now, are you still seeing him now? 20 A. 21 Q. Yes. 22 A. No. 23 Q, Are you seeing anyone else? 24 A. No. 25 Q. And I assume then, other thanilltyou've All 1 2 3 4 S 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 10 11 12 13 14 15 16 17 18 19 20 21 22 23. 24 25 Page 444 had rw.wiltign, physical relationship withime sinca since you separated from A. Q. So, you dated for three or fourinonths, you had multiple relations with him in which I assume removing of clothes, having sexual intercourse on multiple occasions, correct? A. Yes. Q. 11.11s after.? A. Q. Is he someone you dated? Was this a one-tune event? Again, you described it as 2003, digital penetration. A.. We were friends. Q. More than once? A. No. Q. Okay. The one time he digitally penetrated you, did you touch him? A. Yes. Q. Okay. Did you masturbate him? A. No. Q. Okay. Did he climax? A. No. Q. You just touched -- A. Yes. Page 4 4 5 Q. -- one another? All right. Next would be whom, A. No. No. Yes. Q. No, yes? Yes? A. Yes, yes, sorry. Q. Because he's the only other one in '03 at least that you've listed. Is there anyone else that you've forgotten that you should have put in the '03 period? AQ: on how many occasions did you two get together physically? A Three. Q. Clothes come off? A No. Q. Just he digitally penetrated you on approximately three occasions? A.. Yes. Q. And did you touch him? A. Yes. Q. And did you see — did you masturbate him? A. No. Q. Did he climax? A. No. Q. Where did Iles - where did yoy set PROSE COURT REPORTING 14 (Pages 442 to 4 fib) AGENCY,. INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Ildiff0164MiS4702-9644-60776346371i EFTA01076734 Page 446 Page 448 together with 2 A. His house, a friend's house, that's it. 3 Q. Any of the — any of the first eight 4 people we've covered ever occur at Jane Doe No. 4's 5 house? 6 A. No. 7 Q. At Jane Doe No. 7's house? 8. A. No. 9 Q. Have you ever had any type of sexual 10 activity occur, intercourse, oral sex, digital 11 penetration when you've been in Jane Doe No. 4's 12 house? 13 A. I don't remember. 14 Q. How about at Jane Doe No. 7's house? 15 A. Yes. 16 Q. Okay. And who, with whom at Jane Doe No. 17 7's house? 18 A. Thissuy I.P. 19 Q. Is he on this Ilst? 20 A. No. 21 Q. 'Why not? 22 A. Because I, I don't know. Because We made out. 23 Q. All right. But you had no digital 24 penetration, no touching? 25 A. Nothing, just make out. 1 have been after 2 A. Yes. 3 Q. Okay. And if I recall, he was 4 someone that you dated on and off fora long time'' 5 A. Yes. 6 Q. Do you ever see him anymore? 7 A. No. 8 Q. Is he still around? 9 A. Yes. 10 Q. Did he ever get married? 11 A. I don't — I don't lcnow. 12 Q. You just don't — have no connection with 13 him at all? 14 A. I don't out him. 15 Q. Okay.Ms someone that you had 16 sexual intercourse. I assume if you dated over a 17 four or five — three-year time period, you would 18 have had sexual intercourse with him, oral sex on 19 multiple occasions. Fair statement? 20 A. Yes. 21 Q. And, again, everyone now through'''. 22 voluntary, knowing, intelligent, you understood, you 23 agreed, your partner agreed, correct? 24 A. Yes. 25 Q. In any of these relationships through 1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 447 Q. All right. Okay. After who's next? and then you say he's moat you have forS04 with Mr. you have for 2005. Should Mr. be in 2004? A. No. No, that one's correct. It was That would be next Q. It looks like= was the only one that you 1h1_— you have a long-term relationship wi A. I did. Not, not long term, no. Q. What are we talking about? A. Three months. Q. And you had sexual intercourse with him on multiple occasions? A. Once. Q. And that was the only sexual, no oral sex, no nothing, just one time sexual intercourse in three months? A. Yes. Q. aghe was the only person during 2004? A. I. Okay. Now, I see So, 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 449 any type of physical or verbal abuse with these individuals? A. Prior or with him? Q. While you were dating these people or with these people A Q. Was he abusive, physically abusive to you? A. That's such a broad statement to me. Q. Okay. Did he ever strike you? A. No. Q. Okay. Was -- did you consider him physically abusive to you? A. Yes. Q. In what way? A. He would grab me. Q. Where? A. My arms. Q. Leave bruises? A. No. Q. Why would he grab you on your arms? A. We would be fighting, and I wouldn't get out of the way. Q. Happen on many occasions? A. A few. Q. More or less than five? (561) '832.:.7500 ,S17,..5 et e—JA...,-C- 4 17.......SnavaN....3/4 NrCne.0,4, ...LiNje.“Vil,e3a1,14./.1%.2)....eSe.• 15 .(Pages 446 to 449) PROSE COURT REPORTING AGENCY, INC. . MI Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 • Electronically signed by cynthia hopkins (601 8647f016-be89-4782-9d44-6af77636c37e EFTA01076735 Page 450 8 . . I remember ou told us that. Was he 9 or was he 10 just angry with you? 13. A. I think he was angry. 12 Q. What had you done from his perspective; 13. what did he say? 14 A. I don't know. 15 Q. You — were you-all living, at any time 16 living together? 17 A. No. 18 Q. Did any of these individuals that are on 19 this list, separate and apart from your husband, 20 have you lived with any of them at their home or — 21 A. No. • 22 Q. — apartment? Okay. M, so. you 23 dated in 2004, 2005, and In 2004 tow I 24 remember you were dating when Max -Iced if 25 you wanted to go give a nussage to an older man'over Page 452 ..1 Q. Okay. Did you ever tell him you had taken 2 anyone else to Mr. Epstein's hornet 3 A. N 4 O. Did know that you 5 6 A. I don't know. 7 . . Does anyone know you 8 tan our new and and the 9 ith? A. Yes. Q. Who? A. Q. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Because you told her A. No, I told her. Q. But other than your rents — do both of your parents know you A. Yes. And dyer than morn and dad and whom 've tol does anyone else know you A. Yes. Q. Who? Page 451 1 in Palm Beach, right? 2 A. Yes. 3 Q. And. the one that said no way under • 4 Cod's green or something to that effect? 5 A. Yes. 6 Q. And then after you stooped dating- 7 you then started that you kod you again, 8 and you went to Mr. Epstein's house, correct? 9 A. Excuse me. Yes. 10. ' Q. Did you ever — and then, then after you 11 went to Epstein's house, did you start dating= 12. . . . again?' When I say, when you — after you first went 13 to Mr. Epstein's house, which you, I think you 14. described sometime in June of 2004. 15 A. okay. . 16.. Q. Okay. Did you go at some point after 17 June of 2004 start dating- again? 18 ' A. 'On and off. 19 Q. Okay. So, when you say you dated him in ' 20 2004.to 2006, you dated him on and off during that • 21 entire time period? 22. . , A.,. Yes.. ' 23 Q. Did you ever tell that you had gone 24 to Mr. Epstein's home? 25 A. Never. Page 453 1 A. 2 Q. Who is MEP 3 . A. My cousin. 4 Q. ii.r plhast name? 5 A. onetic). I don't know... 6 Q. She's your cousin, not mine. 7 A. Iknow. 8 Q. 9 A. Yeah. 10 Q. Where does live? 11 A. Orlando. 12 Q. Do you know what her number is? 13 A. No. 14 Q. And did you tell -- when did you tell her? 15 A. Long, long, when I was little. 16 . Q. Close with her? 17 A. I was. 18 Q. Now you're just separated by distance? 19 A. Yes. 20 Q. Any reason, other reason you're not close? 21 A. No. 22 Q. After M, 23 A. Excuse me. r? 24 Q. Is he someone you dated? 25 A. Yes. 16 (Pages 450 to 453) PROSE COURT REPORTING :AGENCY;' Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 • 8617f0154•0047•244144077538orto EFTA01076736 Page 454 , Q. Fora long period of time? 2, A. No. • 3 Q. How long did you date him? 4. • A. Four month's. •• 5 Q. And multiple times you have had sexual 6 intercourse, oral sex? 7 A. Yes. -8: • Q. and the only other person on 9• your list is is that correct? 10 A. Yes. 11 Q. 'So, everyone — there's ten people that 12 you've listed that you had some type of sexual • 13 activity, whether it was sexual intercourse, oral 14 sex, digital penetration or you touching a min's 15: penis, that occurred prior to the time that you ' 16 first went to Mr. Epstein's house, correct? 17 A. That all of this, excuse me, all of this 18 happened priar to gothg to his house? 19 Q. Correct. 20 A. Some. 21 Q. Well, no, listen to me. Let me ask the 22 question again. 23 Everyone through MEM, who Was 24 number ten, okay, which you listed as 2004, those 25 are all individuals that you had a sexual activity 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 455 with before you ever went to Mr. Epstein's home, correct? A. Yes. Q. Okay. And in each of those instances, as you've described to us; that is, before you went to Mr. Epstein's home, you were in a position to make a . decision both consensually, voluntarily, intelligently as to whether or not you.were going to . engage in any sexual activity with any of those • males, true? • A. Consensually, yes. Q. All right. At your last deposition you , said, or at the start of your deposition you said that, you said you 'mew you were at Mr. Epstein's home in, I think you said June of 2004 is oour mother had just bought you a new, used 5 or 2006. Do you remember saying that? .• A. Yes. . Q. Okay. And I was sent something, and couldn't out until today, but it reflects that your was not a 2004. It was rota 2005 • or a 2006, but it was an older model. • A: Yes. Q. :laded correct? A. Yes. 1 '2 3' • 4 5 8 9' 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 5 6 .B .7. '.9 10 • . 11 12. 13. • 14 • 15 16 17 . 18 19 20 21 22 23 24 25 Page 456 Q. Okay. And did you look at any of that information before you came in today? • A. No. . . Q. Okay. Did you get that information — well, let me strike that You now know that it was — well, let me — let me ask it this way: You knew that you got after or right around the time of A. Yes. or shortly thereafter? A. Yes. • Q. Okay. And you knew that it was after you got that vehicle that you had gone to Mr. Epstein's house for the fast occasion.. A. Yes. Q. All right. And if so, if the, if the records reflect, it looks it appears transferred on or about the end of which would then put youth the June time which met with your recollection; is that correct? MR. MERMI3LSTEIN: I am just going to object I think you're generally right, but think the — if you look at the data as to when, you know, you know, you do the • Page 457 transaction, the deal, and you take the car and then thetillealliSli) tbera date somewhere. BY MR. CRITTON: Q. Well, there's a, t date, and then there's. •Do you know when you actually took possession of that car? A.. I don't know. . Q.; Sometime, would you agree with me that you couldn't have taken possession of it before you got . title to it, or at least a transfer of title? 'A.. I don't know. Q. Okay. Sootou think you can get a car and • start driving it before you ever buy it? • MR. MERMELSTEIN: Objection to forth. BY MR. CRITTON: : Q. Doesn't 'make sense, does it? A. I'm not a dealership. I don't know how that works — Q. Okay. Would you z- - to be honest with you. Q. Your recollection is you went to Mr. Epstein's sometime ln'June of '04? 17 (Pages 454 to 45 / ) PROSE COURT • .REPORT I NG AGENCY," :INC (- Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be89-07a2-9d44-6a17.7636c37e EFTA01076737 Page 458 Page 460 1 A. Yes. 2 MR. MERMELSTETN: Can we take a break now? 3 • We have been going for about an hour. 4 MR. CRITTON: Sure. 5 . THE VIDEOGRAPHER: Off the record at 6 .3:06 p.m. 7 (A brief recess was held.) 8 . THE VIDEOGRAPHER: We're back on the 9 record at 3.24 p.m. 10 BY MR. CRAYON: 11 Q. Ms. Doe No. 3, I want to cover some, sane 12 events that happened to you prior to the time that .13 you ever went to Mr. Epstein's. So I'm going to 14 focus on the time period before June of '04. Okay? 15 A. Okay. 16 Q. MI right. Some of these we touched on 17' briefly at your last deposition. Pm not going to 18 go into detail again, but !just want to put it in 19 • terms of tinteframe. It appears that your parents 20 were divorced when? Do you know the year? 21 ' A. I don't know the year. 22 Q. Okay. Do you recall if they had -- and I 23. think you have described they had both a physically 24 . and a verbally-violent relationship — 25 A. Yes. 1 2 3 4 S 6 1 9 10 11 12 13 14 15 16 17 21 correct? A. Yes. Q. And you-all ran home or went home, reported that to the police, and the police ultimately did a report. They interviewed you and they did a report, correct? A. Yes. Q. But they never found the person? .Y.es. Q. That's correct? A. Yes. Q. And I think you told us he was in a car? A. Yes. Q. And he opened his coat or whatever, and he Dyed with his penis in your presence? A. He played with his penis *1 n msence, yes. 25 Q. -- of an event that you found disturbing Page 459 1 Q. — in your early years, true? 2 A. Yes. 3 Q. Okay. And I think you told us, and again 4 this is all prior to the time that you met 5 Mr. Epstein, you told us that prior to the time, or 6 at some point in time, you discovered that your • 7 father had been cheating on your mother and you told 8 your mother, correct? 9 A. Yes. 10 Q. And that was upsetting to you, upsetting 11 to your mother, and obviously upsetting to your 12. father, correct? 13 A. Yes. 14 Okay. And you were born on • of 15 %. I= so you also told us on your last deposition 16 that, that in March, and I'm going to refer to 17. specific dates. If you think that date isn't 18. accurate enough, let me know, but live provided a 19 . number of police reports with dates to your 20 attorney, so I'm going really from those dates. 21. Okay? 22 A. Okay. 23 Q. In — on, on or about March 20th of 2000 24 there was a male who exposed himself and fondled 25 himself in front of ou and a few of your friends, tutecosl:L.V.:Yeassaadv.a.te— Page 61 1 at the time? 2 A. I don't know. 3 Q. All right. Did'you fmd it distUrbing at 4 the time? 5 A. Yes. 6 Q. Okay. And in hindsight, as you look back; 7 that is, as you look back in time, it was a .8 disturbing, uncomfortable; embarrassing-type 9 situation; would that be a fair statement? 10 A. I was uncomfortable. 11 . ' Q. All right. And you knew that what he was 12 doing was inappropriate? 13 A. Yes. 14 Q. All right. And when you saw him doing 16 .- that, was he in a car, or did he get out of the car? 16 . A. In the car. 17 Q. Okay. 'And when you saw him dciing it, you 18 had the good sense to run away? 19 A. Yes. . 20 Q. Because you knew what he was doing was 21 inappropriate? • 22 A. Yes. 23 Q. All right. Then in April, approximately 24 April 11th, 2001, you were at a slumber at 25 your friend's house. I think it was 18 (Pages 458 to 461) (561) '.832-7500 PROSE COURT REPORTING AGENCY, INC.' Electronically signed by synth's hopkins (601 Electronically signed by cynthia honking (601 Electronically signed by cynthia hopkins (601 8d471016-be89-47a2-9d44-6af77536c37e EFTA01076738 Page 462 2 A. Yes. 3 Q. And werelccosted and 4 molested b ho touched your 5 . breasts, 'touched you in — over your clothes on your 6 breasts; and then helouched you in his — in your 7 vaginal area, true? 8 MR. MERMELSTEIN: Objection to form. 9 THE WITNESS: Over, yes. 10 BY.MR. CRITTON: 11 Q. Right.. Over your — you had on pajamas, I 12 think you described, or some type of night clothes. 13 A. Nightwear, yes. 14 Q. • All right. And over those — well, in 15 fact, I should ask you: What did you have on? Did 16 you have on pajamas? Did you have a nightshirt on? 17 A. Pajamas. 18 Q. All right. . Which would be bottom pants 19 with a top pants? 20 A. • I don't know exactly what I was wearing. 21 Q. But something like that? • 22 A. Yeah. 23 • that is, 24 hetouche you. He touched 25 your breasts over your clothes. And I think you 1 you ever hear that? 2 A. Yes. 3 Q. Okay. And did she ever tell you that he 4 had done that? 5 A. Yes. 6 Q. And herself told you that? 7 A. Yes. 8 Q. Did she tell you that on or about that 9 time or years later? . 10 A. I don't know when it took place. 11 Q. Were you, were you — ltn softy, not 12 necessarily when it took plate, but did she tell y 13 around that time when you were approximately II 14 years old? • 15 A. Told me what? 16 Q. That her brother had raped her. 17 A. Yes. 18 Q. And how did you react to that? Did you 19 understand what rape was at that time? 20 A: Yes. 21 Q. Okay. And you understood then that her -- 22 did you understand that her brother had sexually -- 23 had sexual intercourse with her? Is that what you 24 understood from her? 25 A. Yes. Page 463 said you flinched, correct? 2 A. Yes. 3 Q. Okay. And then he, he then touched you 4 down in your vaginal area over your clothes? 5 A. Yes. 6 Q.. All right And again you flinched or 7 moved away from him? 8 A. Yes. • 9 Q. All right. And either that day or the 10 following day, someone -- well, let me strike that. 11. Did yougo back and tell your parents at all? 12. A. No. 13. Q. .Did you tell anyone that day? 14. A. No. 15 Q. Okay. And do you recall how it happened 16 that they started an investigation that ultimately 17 . led back to you? 18 A. 19 Page 465 1 Q. And what, what was her reaction to that? 2 !mean was she crying when she told you? Was she in 3 shock? 4 • A. Yes. 5 Q. How did you react to that? 6 k I was in shock. 7 Q. And Ms. Doe No. 3, was that after the . 8 slumber party that you learned all that? 9 A. Yes. 10 Q. And would • be a correct statement that, 11 ' as a result of wha at the slumber 12 party in which you teamed from that you 13 found that a very traumatic experience? 14 • MR. MERMELSTE1N: Objection to form. 15 . • THE WITNESS: What happened to her? 16 BY MR:CItITTON: . 17 . Q. • What happenedto you. 18 . A. I don't know. 19 Q. Did you — were you, when he touched you 2a that night, were you in shock? 21 MR. MERMELSTEIN: Objection to form. 22 THE WITNESS: I, I don't know. 23 BYMR. CRITTON: 24 Q. Well, did you perceive were you shocked 25 at what he had done? I'm not talkin the medical 19 (Pages 462 to 465) PROSE COURT REPORTING AGENCY, INC:. Electronically signed by cynthia bodkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia bodkins (601 8d47f015-be89-47a2-9d44-6a177536c37e EFTA01076739 Page 466 1 definition of shock. I'm talking about how you 2 felt. A. Yes. 4 Q. Did you — were you confused? 5 A. Yes. 6 Q. Were you humiliated? 7 A. I don't know. 8 Q. Were you embarrassed? 9 A. I don't know. 10 Q. Okay. Did you have what you considered to 11 be a severely, severe emotional reaction to what he 12 had done? 13 MR. MERMELSTEIN: Objection to form. 14 THE WITNESS: I don't know. 15 BY MR. CRITION: 16 Q. Maybe you did, maybe you didn't; you just 17 don't recall? 18 A. Correct. 19 Q. When your mother found out about what had 20 happened — well, let me strike that. 21 Did the police just show up at your door 22 and say we w d like t talk to your daughter about 23 being over at s house? 24 A. I don't blow how. I don't know. 25 Q. But you remember the police interviewing Page 467 3. you? 2 A. 3 . -- for an reason? Oka . correct? 9 A. Yes. 10 Q. I'm not trying to make the math hard, I 11. think that -- I think that's accurate. 12 Prior to that time at least it looks fro 13 readin 17 18 20 (Pages 466 to 469) . PROSE COURT REPORTING AGENCY, INC... Page 468 3. Page 469 N 11 A. I did not. 12 Q. Did someone — did you tell anybody about 13 it or did someone find what you had done? 14 A. Yes. 15 Q. Who? 16 A My mom. 17 Q. .•Did she come in when you were doing this? 18 A. 29 Electronically signed by cynthia hopkIns (801 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hooking (601 Bd47f015-bo89.47a2.9d44.6af77536c37o EFTA01076740 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. A. A. A. A. A. A. Summer. When she saw it, what did she say? I don't know. What did you tell her? The truth. Which was what? 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 472 DI A. I don't thinlcso. Q. Does your father know? Did your mom ten your dad? A. Yes. Q. Okay. Were they separated at that time? A. Yes. Do you remember that? A. Yes. Q. Okay. On how many — and that was how old were you then? Is this around the same time or were you even younger? A. I don't know. Q. On how many times, on how many occasions did it occur when you were young, when your parents were still together before they got a divorce, Page 471 1 IIIIIIIIP 2 3 MR. MERME : • don to form. THE WITNESS: 4 BY MR. CRITTON: Ii7C A. The divorce. 10 . Q. Your parents? 11. • A The cheating, yes. 12 Q. Did you believe that you had played drole 13 in the divorce taking place? 14 A. I did believe that. 15 • MR. MERMELSTEIN: Objection. 16 BY MR. CRITTON: 17 Q. Because you had told your mom that your 18 dad had been cheating? 19 A. No. 20 Q. What, what role did you believe that you 21 had played in the divorce? 22 A. Because I was a child. I,1 don't know. 23 laid you tell me you had a sister? Is it 24 25 A. Yes. (561) 8323.500 Page 473 1 Ms. Doe No. 3, that the — either the verbal or the 2 physical violence was so great that you and your 3 mother and your sister had to leave the house? A. Maybe like two times. Q. Okay. Those are indelibly etched on your brain? MR. MERMELSTEIN: Objection to form. 8 THE WITNESS: I remember them. 9 BY MR. CRITTON: 10 Q. And I would guess fora small child, they 11 • were pretty traumatic events? 12 MR. MERMELSTEIN: Objection to form. 13 THE WITNESS: Scary. 14 BY MR. CRITTON: 15 Q. And were you fearful for yourself? 16 A. No. 17 Q. For your mom? 18 A. Yes. 19 Q. Were you —.did you find the whole events 20 between your mother and father to be confining? 21 A. Yes. 22 Q. Okay. And did you consider that those 23 were emotionally taxing on you? 24 A. Yes. 25 Q. Did your mother take you to see any type 21 (Pages 470 to 473) PROSE COURT. REPORTING AGENCY, INC. EbatroNcally signed by Grebe hopldns • 'Elmbonically signed by cynthis hopldna (601 .ffeectrankally bind by Cynthia hobbit* (501 8(1471015-be89-47a2-9d44-6af77536c37e EFTA01076741 2 3 4 5 .6 '8 .7 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 474 A. I don't know. When I was older. Q. At that time were you dating anyone? A. I don't, know. what happened? 6 Q. But you pulled a car. Did you have a 7 driver's permit at that time, a learner's permit? 8 A. Yes. 9 Q. :So you would have had to have been at 10, least 15? 11 • A. 12 O. 18 19• 20 21 Q. Was anyone in the house with you? A. No. what Q. Okay. And happened? Page 476 6 Q 7 A. 1— I don't know. 8 Q. You have no recollection as you sit here 9 now? 10 MR. MERMELS • "on to form. 11 THE WITNESS: 12 BY MR. CRITTON: 13 Q. You say many things. What, what things 14 were bothering you at that time? 15 A. I, I don't know. I don't know.. 16 Q. Can you give me anything that was going 17 on? Okay. You're 15 years old now because you had 18 s permit, so we had to have been in 19 So you had some relationships, because we 20 know that fro 24 A. Life. 25 Q. Was it your parents? Page 477 A. No. 2 Q. Was it your peers, your female peers? 3 A. I don't, I don't know. 4 Q. School? A. I don't — no, I don't think so. Q. Relationship with a guy — A. I don't know. 18 19 20 21 22 Q: Do you know where you were? A. Taco Bell. . Q. • Which Taco Bell? A. 22 (Pages 474 PROSE .COURT ..RERORTING. AGENCY, INC. Electronically signed by cynthia honking (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 to 477 ) 8d47f016-be69-4782-9d44-03077636c37e EFTA01076742 Page 478 Page 480 ). Well «h() else -- • . All right. So, an 'how you took — you 1. been just prior -- what did I say, '05? 2 MR. MERMELSTEIN: Yeah. 3 MR. CRITTON: Okay. 4 BY MR. CRITTON: Q. of—just prior to of. 6 A. Comet 7 MR. CRITTON:. Okay. We have to change the 8 tape. 9 THE VIDEOGRAPHER: Off the record a 3:46. 10 This is the end of Tape 1. 11 (A brief recess was held.) 12 THE VIDEOGRAPHER: We're back on the. 13 record at 3:49 p.m. This is the start of 14. Tape 2. 15 BY MR. CRITTON: 16 Q. Ms. Doe No. 3, before we changed the tape, 17 I think you said that just before your 18th 18 birthday, or before ou turned 18, you had met your 19 current husband, which would have been 20 sometime prior to of.. 21 A. Correct • • 22 Q. Within a month or so. Is that a fair 23 statement? 24 A. Yes. 25 Q. Aml I saw someplace that you met him Page 479 Page 481 1 through My Space? 2 A. Yes. 3 Q. All right. Did you converse over MySpace 4 for a period — did someone introduce you and say, 5 hey, you should hook up with this guy? A. Because of me and my current husband's 6 A. Yes. 7 situation at the time. 7 Q. All right. So you MySpaced each other, 8 Q. What was the situation'at that time? 8. you liked what each other looked like, what you said 9 A. Lying, not having like any sexual activity or, 9 .over the social networking and decided to get 10 • you know, contact or just fighting. 10 together and meet? 11 Sio you remember when you first met 11 A Yes. 12 your husband? 12 . Q. Okay. Within how long after you met did . 13 A. Yeah. 13 you start dating; that is, if I had to say, when did 14. Q. When? What year? 14 you-all start dating? 15 - • A. I was just going to be 18. 15 A. Sometime after June 26th. 16 Q. Eighteen. You were 18. So that would 16 Q. " Of 2006? 17 have made you -- approximately just before of 17 A. Yes. . ' • 18 . M right? 18 Q. And I think.you were married in September 19 MR. MERMELSTEIN: No. She was bom in 19 . of '08? 20 • •. 20 A. Yes. 21 • MR. CRITTON: Right. So, just before she 21 4 . So, sometime between June 26 of '06 an,: 22 . was 18, so 17. 22 Seutember of138 23 _Wt. MERIvtELSITIN: Eighteen is of " 23 24 Ms when she turned 18. 24 A. Yep. Yes. 25 MR.CR1TTON: Right. Oh, so it could have 25 Q. Can ou —knowin: those . :meters now 23 (Pages 478 to 481) PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 8647101febe89-47•246144•177638037e EFTA01076743 2 3 8 9 10 11 9 U 21 22 23 • 24 25 Page 482 can you give us a better point in time when that occurred? A. Q. What happened? Tell me what you, what happened. A. I took the pills, sat there, and thee called me and I talked to her, and I told her what happened and then she me. ccuned between you and A. We were fighting. Q. Okay. And I think you had now -- you were fighting. You said that you had no physical, no sexual relationship at the time? A. Yes, it was rough. Page 484 1 had you anew: had 2 sexual intercourse? 3 A. Yes. 4 Q. Okay. But for some reason you had 5 stopped? 6 A. Yes. • 7 Q. Why had you stopped? 8 A. Certain things that he would do to touch me 9 just triggered things for me. 10 Q. Such as what? 11 . A. Such as what, what? 12 Q. What, what was so awful with our 13 l i hat caused you to not 34 is physical touching of you? 15' MR. MERMELSTEIN: Objection to form. 16 THE WITNESS: So what are you asking me? 17 BY MR. CRrTTOM 18 Q. ram asking you, you say that something 19 about what he was doing with you physically you 20 found revolting, apparently. 21 A Yes. 22 Q. Okay. What was he doing? 23 A. Touching me a certain way that I didn't like. 24 Q. Where? 25 A. My breasts and my vaginal area 2 3 4 6 7 8 9 -8 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 483 Q. Okay. When you say -- not rough sexually, just no sex? A. Pretty much. Q. Okay. And that was unsatisfactory for you? A. For him. Q. Okay. Because you had said, I'm not going to have sex for whatever reason? . . !just never wanted to. Q. With him? A. At all. Q. Okay. At the time that you were going to .. kill yourself, had you had relationship -- had you had sex wit A. At the time l was trying to? Q. Yes, ma'am. A. Prior? • • Q. Yes. Let me ask it again. You said, he obviously was complaining that you weren't having a sexual relationship, correct? A. Correct. Q. All right. You were fighting about that and probably other things, correct? A. Correct. Q. All ria. As of the time Q. So, it should — if yoti told her that, it should be in your notes? . MR. MERMELSTEIN: Objection, her notes? MR. OlITTON: Let me strike. Her notes, • MR. MERMELSTEIN:. Objection to form. THE WITNESS: I don't know,' Tve never 24 seen them. 25 1 2 3 4 5 6 7 8 9- 10' 11 12 13 -14 15 16 17' 18' 19 20 21 22 23 Page 485 Q. And you just didn't like what he was doing? A. Yes. Q. Because you didn't — had other people done that to you before? A Yes. Q. Okay. Who? A. Epstein. Q. Okay. Had you ever told anybody this? A. Told anybody what? Q. What you just told me. A Yes. 24 (Pages 482 to 485) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be89.47e2-9d44-6af77536c378 EFTA01076744 Page 486 BY MR. CRITTON: 2 Q. Okay. Hadpost -- prior — after the time 3 that you went to see Mr. Epstein where you were at 4 . his house on the one occasion when there was 5 contact between the two of you in June of '04, you 6 had had relations with whom? Do you remember? 7 I probably should go back to Interrogatory 8 Answer No.4, if you would take a look at those 9 again. • 10 THE WITNESS: Look at this one? 11 MR. MERMELSTEIN: Yeah, Exhibit 4. 12, THE WITNESS: Which one is Exhibit 4, that 13 one? Okay. Question number what? 14 MR. MERMELSTEIN: I'm sorry. What's the 15 question, Bob? 16 BY MR. CRITTON: 17 Q. The qUestion is -- if you go to question 18 18, is which — after Mr. Epstein -- after you had 19 been at Mr. ?.E..te is house, you had had sexual 20 relations with Brewer (sic), correct? 21 A. Brewster. s Who else 24 25 Q. Uh -an-hlis . Anyone else Page 487 1 A. I think that's it. 2 Q. Okay. And with separating out 3 had you ever had an roblems with having sexual 4 relations either with with 5 °r with 6 A. No. 7 Q. Okay. In each of those instanots,1 8 assume, in addition to the intercourse, there was 9 touching? 10 A. Yes. 11 Q. But that didn't bother you at all, or I 12 won't say it didn't bother you. You enjoyed it? 13 MR. MERMELSTEIN: Objection to font 14 THE WITNESS: I enjoy being touched, yes. 15 BY MR. CRITTON: 16 All right. In what way was touching you that somehow well, let me 18 strike that. 19 You say he was touching you in a way that, 20 what, reminded you -- you need to tell me again what 21 you said about Epstein. What was — 22 A. He touched me the same way Epstein touched me. 23 Q. Okay. Which was exactly how? Tell me 24 what he was doing. 25 A. Groping my breasts, touching my nipples, and Page 488 1 then touching me from my buttocks to my vaginal area. 2 Q. You say touching your say it again, the 3 last was? 4 A. My butt to my vaginal area. 5 Q. And what do you mean by that? Describe 6 exactly what you say Mr. Epstein did. . A. Caressed my butt and then slowly swooped from the crack down to the front of my vagina area. 9 Q. Was he between your — he, Mr. Epstein, 10 between your legs, or was he behind your butt with 11 his hand, and then you say swooped. Then did he go 12 behveen your legs -- 13 A. Yes. 14 Q. — to touch you in the vaginal area? 15 ... A. Yes. 16 . Q. Had no other male ever done that with you? 17 A. No. 18 Q. No other- man in, since 2003, in the 12 or 19 ' 14 people that we talked about had ever touched your 20 buttocks and then reached underneath and touched you 21 in the vaginal area? 22 A.. Not that way. 23 Q. Had any males ever touched you in the 24 buttocks and then touched you in the vaginal area in 25 a different way? Page 489 1 A. Yes. 2 Q. Okay. So again you need to tell me then 3 what you allege Mr. Epstein did so I understand 4 exactly the move that you didn't like. 5 A. The swooping from the butt to the vaginal 6 area. 7 Q. What do you mean by "swooping"? 8 A. Hen's my butt; here's my vagina. He would go 9 over it and then he went in towards, like try to get in 10 between my legs to touch my vagina, the way that it -- 11 the way, the motion, the way that he did it. 12 ilOkay. And nobody else had done that until 13 id it that way? 14 A. Correct. 15 Q. And other males had -; well, in fact, most 16 of the other males that we talked about, they had 17 touched your breasts before? 18 A. Yes. 19 Q. Okay. And they had touched your nipples? 20 A. Yes. 21 Q. All right. And what did Mr. Epstein do 22 when he touched your breasts.or your nipples? 23 A. Pinched them. 24 Q. Okay. And no other, of the 13 or 14 men 25 that* we've described had, other than had 25 (Pages 486 to 489) (561) 832-7500 PROSE COURT 'REPORTING AGENCY, .INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d4710164**-47•24444-6a77836eare EFTA01076745 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 490 ever pinched your nipple before? • A. I, I don't know. Q. Alt right. So, is it, is i testimony then -- so what wa doing that you didn't like? A. I just told you. Q. Okay. Well, separate and apart from what you described, touching your buttocks and then you in the vaginal area, how was he touching your — you said you don't — you then — well, let me start • again. Separate and apart from touching your • buttocks and the vaginal area, which you said was • similar to the way Mr. Epstein had done it, correct? A. Yes. . ili kay. Had he done that fora long — he, done that for a long period of time? MR. MERMELSTEIN: Objection to form. BY MR. CRITION: Q. That is, touched your buttocks and then touched your vaginal area in a way that you thought was similar to what Mr. Epstein had done. A. No. Q. Okay. Is it something he just started doing? Page 491 1 A. Yes. 2 Q. Okay. Did you tell him you didn't like . 3 it? 4 A. Yet 5 Q. And what did he say? 6 A. I don't know. Q. Well, if you hadn't had sexual intercourse 8 or sex, sexual conduct -- contact for a period of 9 time, what was occurring, then, during that time 10 period where you're just not being close with one 11 another at all -- 12 A. Yes. 13 Q. fora period of how many months? 14 A. Fora long time. 15 Q. Whets a long time to you? 16 A. More than a month. 17 Q. And did you tell hint that you didn't like 18 what he was doing? 19 A. Yes. 20 Q. And what did he say? 21 A. Why. 22 Q. Did you tell him? 23 A. Yes. 24 • Q. And what did he say? 25 A. jul inichltlavnlc2 to say. 25 • 1 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 Page 4.92 Q. Okay. How was he touching your breasts in a way that you thought was similar to what Mr. Epstein had done? A. Just the way he grabbed them. Q. How? A. Like, I don't, I don't know how to describe it. d~r ad done? MR. MERMELSTEIN: Objection to form. THE WITNESS: Because I don't — I don't know. I don't know. • BY MR. CFUTTON: Q. Would you agree with.me that it would not be unusual foreman to stimulate a woman's breasts her nipples, as part of foreplay? MR MERMELSTEIN: Objection to form. THE WITNESS: I don't know. BY MR. CRITTON: s e don't know. Okay. So you told you didn't like that, and his response was? A. Sony. Q. of that, result Page 493 . A. Because we had been fighting and we weren't -- you know, we weren't wo just were not on the same page anymore. We were not stating well. Q. All rigid. You called A. Q. Did she come to get you? A. Yes. Q. Where did she take you? A. To my house. Q. Q. What else? A. Then I went to bed. Q. Did she stay there with you? A. What did you do? .4 . PROSE COURT. REPORTING' AGENCY 26 (Pages 490 to 493 INC: ( Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 edaf01640947•24.144077538e379 EFTA01076746 7 8 10 11 12 13 14 15 16 17 25 5 A. No. 6 Q. You eventually got back together because 7 . you got married? 3 A. Yep. 9 Q. Okay. How long assed before you 10 were back together with 11 A. I don't know, months. 12 Q. Okay. Did you start having sex again, 13 then? 14 A. Yes. 15 Q. Okay. And was that okay with you? 16 A. No. 17 t is, did your sexual experience with 18. i:prove? 19 A. No. 20 Q. It stayed miserable from your perspective? A. Yes. 22 Q. Okay. Then you eventually got married? 23. A. Yes. uch passed myou got be ack with uyou Page 495 1 were again having sexual intercourse and foreplay 2 and then you decided to get married? 3 MR. MERMELSTEIN: Objection to form 4 THE WITNESS: How much time passed? 5 BY MR. CRITTON: 6 Q. Right A. I don't know. Q. Six months, a year? A. I, I don't know. Q. Why did you get married to someone who you didn't — it doesn't sound like you liked very well? MR. MERMELSIEIN: Objection to the form. TESS: Because we were supposed to and Hove him and I care about hint • BY (561)..832-7500 10 11 12 13 16 17 18 19 20 21 22 1 1 2 6 7 8 9 10 13. 12 13 14 15 16 17 20 21 22 23 24 25 Q. A. Q. And he said fine? A. No. Q. He went begrudgingly? A. Yes. Ear what happen' A. Nothing. Q. Did your life improve at all? A. Somewhat. u t s I have -- oka . Was there A. I think that's it. I have seen various reports from Page 497 A. Okay. Can oudesc Q. A quick digression. With Jane Doe No. 4. did you ever see a video that she made of another female and herself kissing that ended up on the Internet? A. No. . made a triple-X rated video of she and Q. Okay. Did she ever tell you that he having oral and sexual intercourse? A. No. Q Has anyone ever told you that? A. No. Q. What's vour cell lone number, please? A. Mine? 27 (Pages 494 to 497) PROSE COURT REPORTING, AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthat hopkins (601 Eld471015-bel39-47e2.9d44.6a177536c370 EFTA01076747 ?eye 4 Q. The first time — was the first time before you were married? A, Yes. Q. And what did that relate to? A. 't know. . Are you — do you feel relieved the two of Page 499 5 6 7. 8 9 5 Page 500 1 A. MI 2 Q. C — spell it. ' 3 A. I don't know. It starts with a 4 what were ii. you doing at 5 hdouse, or her aubt's house? 6 A. We had to a graduation party. 7 Q. You and 8 A.16, . — 9 Q 9 A. (PheaS i 11. . Q. That's her nam 12 • A. Y.eah, 13 Q. Okay. 14 A. And her boyfriend and his brother and just a 15 . bunch of friends were there. 16 Q. At the graduation party? 17 A. Yes. • 18 Q. And then you went back tolls aunt's 19 house? . 20 A. I think it Was her alines. I don't know. 21 Q. : Wh 1 11.1. 22 - and his brother, I 23 think. 24 . Q. Wvas boyfriend? 25 A . Page 501 1 Q. Was was Ms boyfriend? 2 2 A. Yes. 3 . Q. And his brothees name was? 4 4 A. Idol* )31OW. 5 5 Q. Brother? 6 6 A. Just brother. 7 7 Q. Okay. And at the — at the graduation 8 s party, weft you guys drinking? 9 . 9 A. Yes. 10 - 10. • Q. Had you had a lot to.drink? 11 11 . A. No. 12. 12 Q. Had you been smoldng pot? 13 . 13 .A. No. 14 • 14 Q. Had you had -- taken Ecstasy or cocaine? 15 15 A. No. 16 16 Q. Had you had anything — had you had any 17 . . 17 type of cbugs other than alcohol? 18 18 A. No. . 19.: 19 Q. Okay. Tell me what happened. . 20 20 A. I went to the party, the graduation party. We 21 . 21 were all hanging out, dancing, talking. I was drinking 22 :• 22 beer out of a can. I needed another beer. They got me 23' know. It was her aunt's house. 23 a beer, came back. i 24 1philne . 25 who? 24 . . Q. 7 you have split up? MR. MERMELSTEIN: Objection to form. THE WITNESS: No. BY MR. CRITTON: Q. Do you feel less anxious, less depressed because you made a decision to move on? MR. MERMELSTEIN: Objection to form. THE WITNESS: I don't know. BY MR. CRITTON: Q You don't know as you sit here? A. Yeah, I don't know. • Q: I have seen in the records at age 15 you .. were, what I have seen is, date raped; is that correct? A. Yes. Q. Where were you at the time? A. At a house. Q. Whose house? A. ' A friend's house. Q. Right. What friend? Does the friend have a name? A. I think she was watchin n't 25 . A. brother. PROSE COURT-.REPORTING AGENCY INC. • 28 (Pages 498 to 501) Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 86471015-0080-47a2-9444.6a177636c37o EFTA01076748 7 • 8:. • . 9' 10 11 12 13 14 15 16 17 18 19 20 21 22 23 '24 25 Page 502 Q. Alizigki, 2 A. Ot= and his brother. And I drank the 3 ' beer. We ended up leaving. I went over to that house. We.were.just going to spend the night there instead of 5 driving all the way back out there. I fell asleep on the couch, and then I moved into the bedroom. .. I thought I locked the door, and then next. thing you know I have a guy on top of me, and I . can't move and I wake up the next morning. Q. Who was the guy, brother? A. I think so, yeg. Q. *And oil" you knew Wand you knew her boyfriend A. Yes. ..• Q. You know what A. No. Q. But yaisould have go brother's — ='s last name from true? - A. Yes. I don't remember his last name. Q. I understand that. A. Okay. Q. I mean as you sit here today, but you knew it back then? A. Yeah. Q. All right. And the only other guy that s last name was? • Page 504 1 A. Yes. 2 Q. Where? 3 A. My legs. • 4 Q. And could you remember from the night 5 before what this guy being on you; that is, brother 6 being on you, that he had sexually assaulted you? 7 . A. Yes.. 8 Q. Okay. And yoti knew that he had penetrated 9 you with his.penis? 10 A. Yes. 11 Q. All right: And did you scream for help 12 that night? 13 • A. I couldn't tlo anything. 14 Q. Why? 15 A. Because I was lifeless. 16 Q. And you think that they had given you.some • 17 sort of drug? 18 A. Yes. . 19 24 When you woke up the next morning, did you 20 tel 21 A. No. 22 Q. Did youlea? 23 A. No. 24 Q. You did tell your mother? 25 A Yes. Page 503 • 1 was in the !Loathe only guys that were in the 2 house were and his brother? 3 A. Yes. 4 Q. All right. And one of the guys ended up 5 on top of you? 6 A. Yes. 7 Q. Okay. And it wasn't Mit 8 A. No. 9 Q. So, it had to have been his brother? . 10 • A. • Yes. 11 Q. So, when you woke up the next morning, 12 . were your clothes off? 13 A.. I — 14 Q. Or.pulled down? 15 . A. Yeah. 16 Q. Okay. And - 17 A. My.pants. • 18 Q.' — you had on pants. Were you did you .. 19 • have on a skirt and like underwear pantl, or ate you 20 :talking like jeans? 21 A. • leans, like dress pants. 22. ' Q.' All right. And were your pants and your 23 panties pulled down? 24 A. Yes: 25 2.±,Idatt22±25:Earks on vou at all? 1 2 3 4 5 6 '7 8 -9 10 11. 12 . 13 14. 15 16 17 18 . 19 20 21 22, 231 24 25. 29 (Pages 502 to 505) t did our mother say? • . ( 561)' 83 2;777 500 'PROSE COURT. RE PORT I NG AGENCY,: INC.; Page 505 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-be89-47a2-9d44-6a177536c37e EFTA01076749 Page 506 Page 508 • A. 1 2 Q. 2 3' A. 3:. 4 Q. 4. . 5 A. 5 - 6 Q. 6. 7. . A. 7 8 Q. 8 9 A. 9. to 11 12 u 12, 13 had • 13 14. A. Yes. 14 15 Q. Okay. I remember that. . 15 16. . Asa result of havin been raped, did you, 16 17. 17 18 18 19 . 19 20 • 20 21 Q. And did your — what was your mother's 21 22. position? 22 23 A. Same. 23 24 Q. And.why didn't you?. You knew who it was, 24 25 so why didn't you call the police? 25 happened. • BY MR. CRITFON: . . Q. Were you embarrassed by what had happened? A. A little bit, yes. Q. And from 1!'.'r' re rts. true? A. True. . Q. Okay. Because you.considered it to be an emotionally disturbing event, true? A. Somewhat, yeah. Q. Okay. So now, the fact that the guy raped you, drugged you and raped you, it's a somewhat 'disturbing event? . MR. MERMELSTEIN: Objection to form. BY MR. CIUTTON: - • Q. 'just want the ladies and gentlemen of . the jury to understand that's how you've described that event now. MR. MERMELSTEIN: Objection to form. THE WITNESS: Eve moved on. BY MR. CRETTON: Q. You've moved on. Okay. Did you sue him? Did you bring a lawsuit again the brother? 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17. 18 19 20 21 22 Page 507 A. I was scared. Q. Of what? A. lust having to go through that. Q. What did you think you'd have to go through? A. Humiliation. ' Q. Okay. Did you — as a result of having been raped by the brother, you -- that was a trawhatic situation for you, was it not? A.. Yes. Q. Were you in shock? A. Yes. Q. Did you fmd it shameful and humiliating and embarrassing? 'MR. MERMELSTEIN: Objection to form. . • -THE WITNESS: No. BY MR. CRII7ON: • Q. 'Okay. You didn't you weren't ashamed at all— . MR. MERMELSTEIN: Objection to form. BY MR. CRITPON: 1 2 - 3 4 5 6 .7 8 9 10 11 12 13 14 15 16 17 18 19 20 21- Q. — because he had pushed himself on you 22 23 and drugged you, convert 23 24 MR. MERMELSTEIN: Objection to form. 24 25 • . . THE WITNESS: I was ashamed that it 25 Page 509 A. I didn't press any charges. Q. That's not my question. Pressing charges is criminal. Tell the ladies and gentlemen of the jury whether you brought a civil suit against the man who sexually assaulted you and drugged you and raped you. A. No. Q. Why not? A. . Because -- I don't !mow. Q. Because he didn't have any money, wasn't a billionaire, maybe? A. No. MR. MERMELSTEIN: Objection, form. Argumentative. BY MR. CREITON: Q. How about Mr.IIM, the one who had. sexually assaulted you when you were approximately 13 years old? Did you and/or your parents on your behalf institute a lawsuit against him suing him for having sexually molested you? A. No. Q. Why not? .. A. I don't know. • Q. In 2000, in November of 2002, you and your friend well, let me strike that. PROSE COURT REPORTING: AGENCY, 30 (Pages 506 to 509) INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthta hopkins (601 86171016-668047•2-9644-66177 . 5366376 EFTA01076750 1 2 3 I I 9 10 11 12 13 16 17 18 19 20 21 22 23 24 25 1 I 6 1 9 11 12 13 14 15 16. 17 I 20 21 22 A. 'don't • 23 ilYou saw ; is that con cct? 25 A. Yes. Page 510 Were you arrested or — well, let me . strike that. Did you have a — in November of 2002, were you and one of your friends — one of you — I need to start once more. In November of 2002, did you A. No. Q. agy„ilt=zmember, you and a girl named (phonetic) — is that one of ' your friends? A. A. I didn't do that Q. Who did that? A. I don't know. Q. Okay. Were you accused of doing that? A. Yes. Q. Okay. Do you remember there was a police report? A. Yes. Q. Okay. Is that the same who you and she — she took her mom's ATM card and Page 511 MR. MERMELSTEIN: Objection to form. BY MR. C Q. A. That' Q. Same person that was accused of.— j a Yes. A. ' Yes. Q. All right. And is e one that you got in a fight with that one time? A.. Yes. Q. Okay. And that was over a boy? A. Yes. Q A. Yes. • Q. Okay. Did _do it? (.561) 832-7500 • 1 2 3 4 Page 512 • Oka • Andl Q. I'm sorry? 5 A. We found her. 6 Q. Who is "we"? 7 .8 9 10 11' 12 13 14 15 , 16 Q. How many times were you — let me strike 17 that. 19 occasion, or were you engaged on more tart one 18 Were you only engaged to on one 20 occasion; that is, then broke it off and then got 21 engaged again? 22 MR. MERMELSTEIN: Objection, form. 23 THE WITNESS: We broke up. 24 BY MR. CRITTON: 25 g When you saw her— well, !erne strike Page 513 1 that You, you said you broke up. At one time were 2 you engaged and then did you call off the 3 engagement? . 4 A. Uh-huh.. Yes. 5 Q. On how many occasions did you do that? 6 A. Once, I think. 7. Q. You made a request for — well, let me 8 . strike that you had already been 11 to Mr. Epstein's home, correct, because you had gone 12 to his house in 2004? 13. A. 14 • 16. 1.7 • 19 20 21 22 • 23 24' 25 did you? No. the reason you didn't because it was not a big event at that time, was it? MR. MERMELSIEThlf Objection to form. THE WITNESS: No. BY MR. CRITTON:. Q. At the time that you didn't have a multi-million dollar lawsuit against Mr. Epstein, did you? 31 (Pages 510 to 513) PROSE COURT REPORTING AGENCY, INC. Electronically signed by synth's backlit. (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 86471015-be89-47a2-9614.6af77636c37o EFTA01076751 1 2 3 4 5 6 7 I 10 11 19 20 21 22 23 24 25 Page 514 MR. MERMELSTEIN: Objection to form. THE WITNESS: No. BY MR. Q. At the tiro didn't have an attorney, did you? A. No. use ■ and you didn't file your lawsuit until of 2008, correct? A. Did you sped fical and this, and the date o September of 2009. Did you tel send records that had been requested? A. No. Q. Okay. So her letter, she's not telling us the truth when she's saying she was told not to send to Page 516 1 A. He's a he. 2 V that meet with your recollection? A. Yes. • At ! it ' 1 I.. 14• 15 16 17 18 20 21 22 U 23 25 Q. A- A. And? It's right by Wildcat Way. Wildcat Way? MR. MERMELSTEIN: The Wildcats. THE WITNESS: The Wildcats. A. Yeah. Over there. 1 2 3 4 5 8 9 10 11 12 13 14 15 16 17 22 A. Yes. 23 Q. She's also a female? 24 A. He. 25 q: Oh, he's a he? PROSE Page 515 the records by you? MR. MERMELSTEIN: Objection to form. THE WITNESS: I told her what the, what they were requesting, what it was in detail, what case it was. BY MR. CRITTON: Q Why didn't you give her the authority, why didn't you say you can send whatever records you want? Why did you tell her not to send the records? MR MERMELSTEIN: Objection to form. That's not what she said. THE WITNESS: I told her what, what I needed the records for. BY MR. CRrrTON: Q. Did you tell her specifically she didn't need to send the records? Yes or no. A. Not that I I right. 13 14 15 16 17 19 Page 517 Q. did he play a role? A. That, myself. . Q And what were you feeling bad about yourself for? A. 1 don't know. Ijnst, I just wasn't liking myself 3 0. Was it before or after? 24 A. Before. 25 0< 1askajjou to assume — well, let me COURT REPORTING AGENCY, INC.. 32 (Pages 514 to 517) Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be89-47a2-9d44-6a177536c370 EFTA01076752 strike that. Wot Page 518 statement that you 6 MR•MERMEISTEIN: Objection to form. 7 • - . THE WITNESS:. No. 8. • BY 8 .9 10 11 12 13 14. 15 16 17 • 18 • 19 '20 ' • . 21 . 22 • 23 24 25 Page 519 Q. Well, if you did tell him, why would you have told him about that? A. I dent know if i told him. Q. Are both of your parents alcoholics? A. No. Q. Would you have described your mother as having an alcohol problem? Page 520 Does that meet 22 with your recollection? 23 A. Yes. 24 a the first time that you saw 25 — well, let me strike that. You saw Page 521 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 A. I need to use the restroom. Q. Is that correct? Pardon? A. I need to use the restroom. Q. Okay. Let me just, just finish this one question. A. Sure. Q. Dr. — you know what, 11 start when you get back. A Okay. THE VIDEOGRAPIIER: Going off the record at 4:29 p.m. • (A brief recess was held.) THE VIDEOGRAPHER: Back on the record at 4:32 p.m. BY MR. CRITTON: . Q. Ms. Doe No. 3, let me start again with what I was asking. That way well all be on the same stage. 33 (Pages 518 to 521) PROSE COURT REPORTING, AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-be139-47a2-9d44-6af77536c3le EFTA01076753 A. No, no A. No. Do you recall that? Page 524 11 Q. You didn't feel comfortable talking to 12 him? 13 A. 14 • 15. 16 17 18 19. . 20 Does that meet with your recollection? 21: 22 0. 23 24 25 Page 525 14 A. 1 guess. I don't — 15 ' ' Q. You just didn't rentember that; is that 16 *. correct?. : 17 A. Yeah. 18 ' Do•• on know why 21 Q. Oh, they share the same office? 22 A Y 23 34 (Pages 522 to 525) PROSE. COURT- ItEeORTING.AGENCY; .INC. (- Electronically signed by cynthia hookIns (001 Electronically signed by cynthia hopkIns (001 Electronically signed by cynthia hopkins (001 8d47f015-bo89-47a2.9d44.6af77536c370 EFTA01076754 Page 526 Page 528 O 16 17 Page 527 9 10. 11 12 MR. MERMELSTEIN: Objection to form. THE WITNESS: Not when you're seeking help. BY , you didn't have a lawsuit seeking 15 millions of dollars from Mr. Epstein, did you? .16 • MR. MERMELSTEIN: Objection to form. 17 THE WITNESS: No. 18 . BY MR. az= 19 24 At that time you do have a pending lawsuit 25 seeking millions of dollars aest Mr. Epstein, (561) 832-3500 3. 2 3.. 4 5 6 7 a. . 9 10 11 12 13 14. 15. 16 17 18 19 20 21 . 22 23 24 25 ow that you had a lawsuit pending? MR. MERMELSTEIN: Objection to form. THE WITNESS: No. MR. CRITTON: Okay. I have one other area I would like to go into, and then I think Pm pretty well done. Give me — well, let me show you — What's the next exhibit, 6? THE COURT REPORTER: Yes. THE WITNESS: This is 4 and 5. (Defendant's Exhibit No. 6 was marked for identification.) BY MR. CItITION: Q. Let me show it to your attorney. Your answers to the first interrogatories. If you will go to the second to the last page, it appears you're verifying that the answers to: the interrogatories are true and correct. Tell me if that's your signature for these; that is, you're verifying as to 3. 2 3 4 5 6 7 8 Page 529 the content and your answers to the first set of interrogatories. A. Yes. Q. Go to Question 2. A. Uh-huh. • Q. In 2000 — it starts off — its a question about your employment history. And if - if I understand your q years old during 11 that time period. Is that the first time you had 12 any type of job? 13 A. Yes. 14 Q. Then it appears that at least during 2005, 15 you had about eight different jobs. 16 A. Yes. 17 Q. All right. Were these all part-time jobs? 18 A. Yes. 19 Q. Okay. the rder that you had 20 them; that is, w your first job as 21 a hostess? 22 A. Yes. 23 Q. Okay. Did you quit that job or were you 24 terminated? 25 A. Ouit. 35 (Pages 526 to 529) PROSE COURT REPORTING AGENCY, INC. : Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-be89-47a2-9d44-6af77536c37e EFTA01076755 Page 530 9. Okay. And then you did 2 Nice touch. You were a dog sitter? 3 A. Yes. • 4 Q. Did you quit that job or were you 5 terminated? 6 A. I quit. 7 Q. And why d"t the first two jobs? 8 A. To -- I qui elgotajobata 9 dog place, and I wanted to go to school to become a 10 veterinarian. And I quit that place because it was too 11 far. 12 Q. To drive? 13 A. Yeah. Yes. Sony. 14 Q. You were driving your own car at that 15 time? 16 A. Yes. 17 Q. Then you worked — went to work at your 18 aunts restaurant? 19 A. Yes. 20 Q. And is that is 21 A. 22 23 A. Yeah. 24 Q. That's your aunt? 25 A. Yes. am? Page 532 1 more like her babysitter or groceries and cleaning. It 2 was — it took place at her house. 3 Q. Oh, you mean she ran the business out of 4 the house? 5 A. Yeah. 6 Q. So, you became like her personal — '7 A. Yeah. Q. assistant? A. Pretty much. Q. So, even though you were getting ten bucks 11 an hour, it wasn't — Pm sorry, seven and a 12 quarter, it wasn't worth it? 13 A. No. I .9. So, you quit there and went to... which did what? 16 A. It actually — I think that's thea. 17 Q. I'm sorry? 18 A. Yeah, Chars the M=. It's 19 Q 20 A then 21- Q. Is it a tanning parlor? 22 A. 23 Q. 24 out? 25 A. Yes. Yes. Okay. So you would check people in 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 531 Q. So she would say good things about you? A. I guess. you went to Q. The — you quit Why? And is A. It's ajewelry box — a jewelry box. Q. Working in the mall? A. Yes. Q. Were you still working at at the time? A. No. Q. And you quit that to work at -- did you quit that or were you terminated? A. I quit. Q.' And then you went to How long did you work there? A. A week or two. Q. Crummy job? • A. It was telemarketing. I didn't like it. . And then you went to A. Yes. Q. How long were you there? A. A couple of months. Q. • Why did you leave there? A. The location of the place was not -- I was INELd••••••••.......ast--...tottrealts14.004711•••••••14.1, Page 533 1 Q. Got ten bucks an hour? 2 A. Yes. 3 Q. Did you quit that job? 4 A. I got let go. 5 Q. Why? 6 A. Because I changed the music in the CD player. 7' Q. And you then got a job at IMM? 8 A. Yes. 9 . Q. How long did you work there? 10 A. Three days. 11 Q. Why did you quite that job? Did you quit 12 or did they terminate you? . . 13 A. I quit 14 Q Why? 15 A. Because I was just standing there, and 1 16 didn't want to just stand. 17 w, you had a job animal -- 18 19 A. Yes. 20 Q. — in Palm Beach? 21. A. Cana. 22 . 'Q. How long did you work there? 23 . A. Oh, a few months. • 24 • • Q. Okay. And why did you — were you 25 a 4. terminated or did ou quit? 36 (Pages 530 to 533) PROSE COURT REPORTING. AGENCY INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (801 807t0164:44947a24d4444077/53007* EFTA01076756 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 534 1 . A. Yes, terminated. 2 Q. Why were you terminated? 3 A. I came hi late three times. 4 Q. And they said we can't have you bPrance 5 you're late too often? 6 A. Yes.. And S i . then you went to which is the alarm business? 10 A. Yes. 11 Q. And that's where you were when you were 12 interviewed by the FBI? 13. A. Yes. 14 Q. You stayed there or were you terminated or 15 did you quit? 16 A. I was terminated. 17 Q. Why? 18 A. It was — I work, I worked for 19 Q. Ise? 20 A. a job placement employment. So 21 they only needed me for a short amount of time. 22 . All ri t. Then you went to 24 A. Yes. 25 Q. What were you doing? 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 536 ' 1. ' . Q. And.your is that right? 2 . A. Yes. 3 • Q. How long did you stay at 4 ' A. A year. 5 Q. Why did you leave there? 6 A. Due to the construction business and the 7 economy. Q. They let you go? A. Yes Q. Buti. works there? A. Yes. Q. And I may — I need to ask you this:. Did you tell me that your mom and dad are remarried, or they just live together? A. They're engaged. Q. How long have they been engaged? A. Christmas. Q. All right. So they're going to get remarried again? A. Yes. ailim Number 7 references thatM Can you even remember where the I A Page 535 1 A. Well, I was maintaining the web sites, escrow, 2 HUDs, just, you know. 3 Q. How long did you work there? 4 A. A while. More than a couple of months. 3 Q. Did you quit or were you terminated? 6 A. I got let gO. 7 Q Why? 8 A. The business was not good. All ri u. Then ou went tol l A. Yes. Q. And you got a salary there at 23,000 bucks a year. a. A. WIthal Atlildits A. I got — I mean, yes. Q. Like health insurance, 401(1c), things lice that? A. Yes. Q.' What, what was your job? You say accounts payable? A. Accounts payable. Q. So, you would — did you do that over the computer? A. Yes. Page 537 1 Q. Was it — and I think you said it was a 2 woman? 3 A. Yeah, it was a woman. Q. Did you ever ask your mom if she remembers who she took you to? 6 A. Yeah, we tried to look for her. 7 Q. Number 9. 8 ' A. Okay. 9 Q. Okay. It says: Describe each injury 10 (physical, emotional, mental) for which you are 11 claiming damages in this ease specifying the part of 12 the body that was injured, the nature of the injury 13 and any injuries you contend are permanent, the 14 effects on you that you claim are permanent. Okay. 15 That is damages you are claiming in this case. Do 16 you see that? 17 A. Yes. 18 Q. All right. And just take a minute and 19 look at your answer, please, and just tell me when 20 you're done. 21 A. Okay. 22 Q. All right. You say, you suffered severe 23 psychological, emotional, and psychical injuries. 24 Do you know what a psychical injury is? 25 A. Something to do with my head. (561) 832-.7500 37 (Pages 534 to 537) PROSE 'COURT REPORTING AGENCY,. INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471015-bef19-47.2-9d44-6af77536c37e EFTA01076757 Page 538 Page 540 1 Q. All, right. By the way, is this your 2 answer 3. • A. I don't — 4 Q.. — that is, did you, did you come up with 5 all the words that are in Number 9? 6 A No. I had assistance, yes. 7 Q. Okay. • • MR. MERMELSTEIN: Tm going to object to 9 the extent that it's assistance of counsel. 10 She shouldn't disclose her conversations with 11 counsel. 12 BYMR. CRITTON: 13 Q. I don't want to know the conversation, but 1.4 would it be a correct statement that at least the 15 paragraph that has all your answers in here, that 16 this was done with the assistance of counsel? 17 A. Correct. 18 Q. All right. And would it be a correct 19 statement that these words are not words that you 20 chose, but they were done in conjunction with your. 21 attorneys? 22 A. No. 23 Q. That's not correct or that is correct? 24 A. No, I close these words. 25 Q. Okay. So tell me about — so severe ' 1 2 3 4 5 6 :7 B 9 10 11 12 • 14 15 16 17 18 19 20. 21 22 23 24 25 Page 539 psychological, emotional and psychical injuries. A. That was assisted. Q. Ok ri r our ever seeing Mr. Epstein correct? A. What was it? Q. Prioat tr-; ;rig Mr. Epstein in June of '04, let me strike that Tm going to ask it a diffei wet way. Would it be a correct statement, in your, your emotional state, your mental state, your psychological state, prior to th • true? A. Before him? Q. Yes. Over other events in your life. A. Not necessarily. So when you were molested by at age 13, you didn't consider that a severe psychological and emotional event? MR. MERMELSTEIN: Objection to form. THE WITNESS: I don't know. BY MR CRITTON: Q. When you were raped at age 15, you didn't consider that to be a severe and psychological and emotionally troubling event? (561) 832:7500 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. To some point Q. Is it your testimony that having been molested at age 13 and having been raped at age 15 are less significant events than your being in Mr. Epstein's presence for 20 or 30 minutes -- MR. MERMELSTEIN: Objection — MR. CRITTON: — in June of '04? MR. MERMELSTEEN: Objection to form. THE WITNESS: Yes. BY MR. CRITTON: Q. Why? A. Because I don't feel like I have to worry about those prior incidents anymore. Q. Why would you have to worry — but for your having filed a lawsuit against Mr. Epstein seeking millions of dollars, why would you have to worry about that incident at all anymore? MR. MERMELSTEIN: Objection. BY MR. CRITTON: Q. Again, that's four years in your past Well, it's almost six years in your past now. Why would you have to worry about that now? MR MERMELSTEIN: Objection to form. THE WITNESS: Because I don't have to be afraid of naming into those other people. Page 541 1 Unlike Epstein, I can still run into him; I 2 could still see him. 3 BY MR. CRITTON: . 4 Q. Well, since other than your voluntarily 5 going back to Mr. Epstein's house on three occasions 6 after June of '04, where have you ever seen 7 Mr. Epstein in person again? 8 A. Here. 9. Q. Okay. Well, that was when you were here 10 for your exam? 11 A. Uh-huh. 12 Q. All right. And it was as part of the 13 i u were here for an exam. You were out 14 ,correct? 15 A. Correct 16 Q. Okay. And he left the building for 17 reasons -- I actually think he was corning to see me 18 that day, but that's neither here nor there.. 19 our being out having and taking a 20 you never would have seen 21 Mr. Epstein, would you? ' 22 MR MERMELSTEIN: Objection to form. 23 THE WITNESS: Novi don't believe that. 24 BY MR. CRITTON: 25 Q. Okay. Well, if ou ou So ar c‘Linto 38 (Pages 538 to 541) PROSE COURT REPORTING AGENCY, INC. . Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hookers (601 Eld471015-h089-47a2-9d44-6af77536c37o EFTA01076758 Page 542 Page 544 1 .. him outside — well, let me strike that. 2 You were sitting there with our attorney. :.3 Jessica Arb0ur having a correct 4 A. Yes. 5 during the time that you were having 6 the cam by Dr. Hall, correct?' 7 A- Yes. 8 • Q. You chose the time that you were going to 9 have the break, true? 10 A. Yes. 11 • • Q. All right. And Mr. Epstein left the 12 building and got into a car, correct? 13 A' Yes. 14 . Q. All right. And what makes you think that 15 you would have seen Mr. Epstein for any other reason • 16 but for our having chosen a particular time to take 17 a d he kft the building? 18 MR. MERMELSTEIN: Objection to form. 19 ar WITNESS: Because he — I work oil. He lives on Palm Beach. I, I always . 21 worry about seeing him. 22 BY MR. CRITTON: 23 Q. Why, dv lynts1 • worry about seeing him? • 24 YOU wbrk in correct? 25 A .Yeah 1 2 3 4 5 6 7 8 9: 10 11 13 14 15 16 18 . 19. 20 21 22 23 24 25 BY MR. CRITTON: Q Okay. Other than that one occasion, had you seen him since June — approximately June of • '04 A. No. Q. —in person? A. No. . Q. Okay. And have you seen him since? A. No. Q. You indicate as well in our answer to ber 9. you say you've had u've told us about None of those three events did you describe earlier had any relationshto with Mr. Epstein. So what . MR. MERMELSTEIN Objection to form. BY MR. CRITTON:' Q.' or your visit to Mr. Epstein? MR. MERMELSTEIN: Objection to form. THE WITNESS: Just the way that I feel I mean, I don't, I don't know. BY MR. CRITTON: ' Q. You indicate you have feelings of 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 543 Q. Okay? Do you know where his house is? A. Yet . Q. All right. And have you seen him since the time you ve been working? I mean other than during your S have you, have you seen him in pason since the last time you were at his house? In fact, really the, I guess, the third time that you were at his house? A; No. Q. And the only times that you had seen Mr. Epstein in ur whole attire life, other than during • 'n 2009,2010, I don't . remember -- the day that you saw Dr. Hall, was that in 2009; last year? MR. MERMELSTEIN: It was in the Fall of ' '09. BY MR. CRITTON: . . Q. Okay. So in the Fall of '09, you had an . . I, who is our expert. You take a As you're outside having a Mr. Epstein laves the building that he's had an . office In for over a year, and you see him; correct? A Correct-- MR. MERMEISTEIN: Objection to fonn. . THE WITNESS: — I saw him. 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 545 self-blame. What do you mean by that? A. That maybe if I would have said something or maybe if I would have screamed or something. I — it wouldn't have happened. Q. You mean the first time you were there? A. Mall. At all. Q. What do you mean, Nat all"? A. At all. At any time that I was over there. Q. Well, but if you had the feeling of self-blame, and if you had screamed or yelled the - very first time you were there, why then did you go back a second, third, and fourth time and take people there? • MR. MERMELSTEIN: Objection to form. Asked and answered numerous times. THE WITNESS: So, do I have to answer? MR. MERMELSTEIN: Go ahead. You know, ' we're about a half hour past the time that we, we agreed on here. So you can go ahead and answer the ' question, but very little time left, so... THE WITNESS: Because I was young I wasn't thinking.1 really wasn't. BY MR. CRITTON: Q. You sa fluctuations In wel t and 39 (Pages 542 to 545) PROSE COURT REPORTING. AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-be139-47a2-9d44-6af77536c37e EFTA01076759 Page 546 appetite. You had fluctuations in weight and 2 appetite long before you ever met Mr. Epstein, true? 3 A. No. a So some of the earlier orts MR:MERMELSTEIN: Objection to form 10 THE WITNESS: Maybe they must have 11 misunderstood. 12 BY MR. CRITTON: 13 Q. Okay. And do you consider yourself heavy 14 now or light, or tight, just right? 13 A. Like a person? 16 Q. No, no. We — I'm talking about weight 17 gains. 18 A. I blow. I don't — I don't 'mow. 19. Q. Do you feel like you're at a good weight 20 right nova 21 A. Yeah, sire. 22 Q. Have you weighed more than you do now? 23 A. Yes. 24 Q. Have you weighed less? 25 A. Yeah. • Page 548 1 you file a lawsuit against Mr. Epstein then, ma'am? 2 A. Because I was scared. I was scared to come 3 forward. • 4 Q. For what? Why were you seared? 5 A. !didn't, !don't Icnow• what —.I didn't know 6 what could happen. 7 Q. What's happened? 8 • MR. IVIERNIELSTEIN: Objection to form. 9 BY MR CRITTON: 10 Q Do you think your, your being scared was 11 misplaced? 12 A. What do you mean? 13 Q. Well, you said you were scared. 14 A. Right 15 Q. Are you still scared? 16 A. Sometimes. 17 .Q. About what? 18 A. 'What he could do next, 19 Q. What has he ever done to you? What has he 20 ever done to you other than your four voluntary, 21 consensual visits that you made to his house? 22 MERMELSFEIN: Objection to form. 23 • THE WITNESS: He's made me suffer. 24 BY MR CRITTON: • . 25 Q. How? 1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19.. 20 21 22 23 24 25 Page 547 Q. And you say that's related to Mr. Epstein as distinct from all of the problems you've had with your estranged husband? A. Stress and — MR'. MERMELSTEIN: Objection to form. BY MR. CRITTON: Q. Pm sorry? A. Stress. Q. Stress over the lawsuit? MR. MERMELSTEIN: Objection to form. THE WITNESS: Stress, just this whole situation. BY MR. CRITTON: Q. Whole situation being the ongoing laitsuit? : A. NO; . Q. What situation then? A. What the, the way that I was — the way that this took place, this Epstein case. Q. Why didn't you file a lawsuit after the last time you were at Mr: Epstein's house? Why didn't you tell your mother and then go hire a lawyer in 2004 or 2005 or 2006 or 2007? Why didn't (5'61) 812-7500 Page 549 1 A. I, I just feel, I feel -- you know, I feel 2 scared. I feel traumatized. I feel I just, I just 3 don't feel comfortable anymore. Q. You, you indicate in Answer 10 that you had a loss of earning, loss of earnings, or a loss of earning capacity. 7 A. I'm afraid to go to my job and see if he's 8. ever going to walk in, or anyone that remotely looks 9 like him, I'm afraid, always looking over my shoulder if 10 that's hitn. Q. Why are you working ittri then? 12 A. Due to the economy, because I — that's the 13 only place I got hired. 14 Q. Well, if you have a loss of earnings, it • 15 means that you've lost something. Can you describe 16 any earnings that you've lost as a result of having 17 been to Mr. Epstein's home?. • 18 • ' , MR. MERMELSTEIN: Objection, form. Paris 19 fora legal conclusion. 20 BY MR. CRITTON: 21 Q. IS there any money that you can describe 22 that yOu've lost? 23 MR. MERMELSTEIN: Again same objection to 24 form. 25 THE WITNESS: I delft know. 40 (Pages 546 to 549) PROSE COURT REPORTING AGENCY, INC. Electronically signed by synth,' hopkins (601 Electronically signed by cynthla hopkIns (601 Electronically signed by synth,' hopkins (601 8d47f016-be89-47a2-ScI44.6a177536c37e EFTA01076760 Page 550 Page 552 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. CRITTON: Q. You also claim a loss of earnings — of earning capacity in the future. Why do you believe — and not legally. I'm not, Pm not looking for a legal opinion — Why do you believe you have lost your ability to eam money in the figure because of your basically one-time visit with Mr. Epstein in 2000 -- June of 2004? MR. MERMELSTEIN: Objection to form. THE WITNESS: Like I said, working at where I work, I'm always afraid. BY MR. CRITTON: . Q. What's — how does that affect your ability to earn money in the future because you went to Mr. Epstein's home? What loss have you sustained, you believe you would sustained in the . flame — let me ask the question this way. Let me withdraw that. What ability to earn money in the future do you believe you have lost as a result of having gone to Mr. Epstein's house on four occasions, only once being with him? A. Because I can't be arotmd old people. Q. But you're around them all the time? 1. A Not all the time. 2 Q. Is it anyone who has gray hair? 3 MR. MERMELSTEIN: Objection, fonn, 4 argumentative. 5 THE WITNESS: I don't know. 6 BY MR. CRITTON: 7 Q. Well you said, older men, so... 8 A. I mean like the same style, the same 9 arrogance, the same persona as he carried, the same 10 creepy smile. 11 Q. You met — other than seeing Mr. Epstein, 12 I guess on tis third occasion when he came down the 13. stairs with M., you met him or spent time with 14 him, what, 20 or 30 minute on one occasion? 15 A. Correct. 16 Q. Did you ever see him in a sweatsuit? 17 A. Yes. 18 Q. On that occasion? 19 A. No. 20 Q. Okay. You saw him in a sweatsuit, on 21 whatsn one occasion when he came down the stair 22 with N.? 23 A. Yes. 24 Q. That's the only time you've ever seen him 25 in a sweatsult? Page 551 1 A. And I can't be around them -- 2 Q. I'm sorry. 3 A. — that, you know, wear creepy sweatsuits and 4 look like him and has the same color hair, or you know.. 5 even the same type of car. 6 Q. What kind of car does he have? 7 A. A Mercedes. 8 Q. How do you 'mow? 9 • A. Because I've seen it numerous times. 10 Q. Where have you seen it? 11 A ' At his house and out here. 12 Q. Okay. Well, you said numerous times. You 13 were at his house four times, so you saw it then? 14.; A. And outside here. 15 .. Q. Okay. There, it was a Mercedes that he 16 got into that day? 17 A. Yes, sir. 18 Q. Other than those times, have you ever seen 19 his car? 20 A. No. 21 Q. Okay. And you say the job that you have 22 right now, you're around older people, true? 23 A. Yes. 24 Q. . Okay. Do you see a lot of people that you 25 . think look like Mr. Epstein? Is it anyone — ,—ememommummow 1 2 3 4 5. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21- 22 . 23 24' 25 Page 553 A. And here. Q. When you were taking youtIMMthat one day? A. Yes. MR CRITTON: Okay. Got about two more minutes, and then I'm done. BY MR. CRITTON: You describe yourself as having lower energy or lower ambition in answer to Number 9. Do you see that? A. In answer to number what? Q. Nine. A. Yes. Q. Okay. In fact, you — it seems like you maintained a job almost continuously the last few years. You lose a job; you get a job right back, correct? A. Not necessarily. I will look for a job, yes. Siloan have you been working at the A. Seven months. Q. All right. Continuously? A. Yes. Q. Are you looking for another job now? A. Yes. PROSE COURT REPORTING AGENCY, 41 (Pages 550 to 553) INC.. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47l015-be89-47a2-9d44-6077536c37e EFTA01076761 Page 554 6 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Where? In what line of work? A. My career field. 3 Q. To be a vet? A. Yes. Q. And what kind of job are you looking for? A. Kennel,.a dog bather, groomer, anything. • Q. Do you think you can earn more money or less money doing that? A. Less. • Q. But that's something that you want to learn more about, so you're willing to take a cut in pay? A. Yes. Q. But before you take a new job — I'm sorry, before you quit your existing job, will you make certain that you have another job? A. ru try. Q. Well, would you just quit your job — are you living at home now, did you say? A. Yes, I moved back home. Q. Do you contribute toward the rent, the electric or anything? A. No, no. Q. You have no expenses? A. No, l pay for my own, my own bills 1 2 3 I 6 7 8 9 10 11 12 be. 13 Q And this is after you had been with — 14 well, I'll save that. 15 Well, et me ask it this way: Prior to 16 meeting Mr. Epstein you had been with approximately 17 ten or II males, correct, before you ever even met 18 Mr. Epstein from age 13? . 19 A. Not from age 13. 20 MR. MERMELSTEIN: Objection to form. 21 BY IL NISSEJTTON: 22 Q you would have been age I5? 23 A. Uh-huh. 24 Q. Fourteen and 15? 25 A. Yes. BY MR. CRITION: Q Okay. You said you have corruption of morals and values. Have you done anything as a result of having been at Mr. Epstein's house and seen him really on the one occasion in June of '04 that you believe has lead to a corruption of your morals or values? A. I don't think they are as high as they used to Page 555 Q. But you have no expenses associated with 2 the place where you're living? 3 A. I buy food. That's it. Q. For yourself? A. No. Q. For you and your mom? 7 A. Yes. a Q. And your dad? 9 A. Yes. 10 Q. Okay. Other than -- and would it be a 11 correct t before you would quit the — 12 A. 13 Q. that you would have another job 14 lined up because you would want to stay employed? 15. A. I would want to. 16 MR. CRITTON: Objection to form. 17 BY 18 Q. I 21 Mr. Epstein, didn't you? 22 A. No, I don't think so. 23 Sginj„; 2, you only really_ after you met Mr. Epstein? 25 MR. MERMELSTEIN22e.c_ chon, form. 25 before you ever met 8. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24' Page 557 1 Q. And how do you think Mr. Epstein corrupted 2 your morals? 3 A. Because he's an old man. 4 Q. Other than him being an old man, can you think of any other reason he corrupted your morals? 6 A. I think he took something away from me that he 7 shouldn't, he shouldn't have had any right to. Q. And what was that? • A. Innocence, youth. MR. CRITTON: I have no other questions. MIt MERMELSTEIN: Okay. THE VI:GEOGRAPHER:. Off the record at 5:07 p.m. This is the end of Tape 2 and the end of the deposition. THE COURT REPORTER: Do you want to order this? MIt CRITTON: Yes. MR. MERMESTEIN: I'll take a copy. (Witness excused.) (Deposition was concluded.) PROSE COURT REPORTING •AGENCY 42 (Pages 554 to 557) INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthla hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-b1189-47a2-9d44-63f77536c37e EFTA01076762 Page 558 Page 560 1 2 3 4 5 8 9 10 11 12 13 14 15 16 Cynthia Hopkins, RPR, FPR 17 Notary Public - State of Florida My Commission.Expires: February 25, 2011 18 My Commission No.: DD 643788 19. 20 21 22 23 24 25 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that JANE DOE NO.3 personally appeared before me and was duly sworn on the 6th day of April, 2010. Dated this 19th day of April, 2010. 1 DATE Ar4lc 2010 2 • - TO JANE DOE NO.3 Siuse S Ilarnelock.Esq:e AITAKELSITIN & HOROWITZ. PA I 5205 &soy= Rotolo! Siiit 2218 Mimi floods 3)160 5 41 7 :2 :4 ro 22 24 ZS IN RE Tim Dos Net 2 vs. Epstein CASE No' 01-ev4011924ARRAVHNSON Mom late notfot St 66 of Apt 20104w save your clecotkiei in IN a:a...knee owner At Ow dm. 414 ice waive sigashre k is sow malty to sign yew *ohm As pre,4c...27 0.2val ow k 02,00121 wilt tA Itl6tkal to TIP km* 222 orsisit Plea* read the ScAaning Senecas ortfully hi the cedar the thescrincu with:due errata sheet As )w tad) air depot '.ear thy go a orreakni dim ye. wish h maks 'build be raid cm 04 errata sheet meg page and he • ItIntlf of nil clop DO NOT met on she unsays nett Oti.+4 pm kw mid eta ascsc1/2 4 and noted mazurkas, be no soap .rd at. dwonna Owl end mum One pin ,{1 V ,co do re. rem' mid sign the ukseition whim I twimbla ten Ow 010q whit las *cat/ been krAwvtd to en atkint ineneKe,a, be Malmo Clakcf the Court Fru wish town. )a.it Noah^ ii.En yams mow ht the blsel, M do team et itit leses teams sous van burr era Aplgsge_n:1_42:k_s Cpuhia Heedins, RP& )PR I do haby solve my siVuhra lama bos NO 1 CERTIFICATE 2 113E STATE OF FLORIDA 3 COUNTY OF PALM BEACH 5 I. Cynthia Hopkim, Registered Professional Reporter, Florida Professional Report and Notary 6 Public in and for the State of Florida at large, do hereby certify that I was mnborrced to and did 7 report sad deposition in stenotype; and that the foregoing pages arc a one and correct transcription $ of my shorthand notes of said deposition. 9 1 finger certify that saki deposition was tal=n at die time and place hertinaLo- ve set forth -10 and Thai the taking of said deposition was commenced and completed as hereinatove set out. I further cat that I am not anorney or 12 counsel of any of the psnies, nor anal a relatim or employee of any attorney or counsed et patty 13 comected with the action, nor ten I financially imerested m the action. The foregoing confkation of this transcript 15 does not apply to any reproduction of the same by any means unless ender the direct control andfor 16 direction of the certifying reporter 17 Dated this I 9th day of April, 20(0. Is 19 20 21 11 14 22 23 • 24 23 7449.14-IAS grethia Fleckber, RPFE, PPR Page 559 1. 2. 3 4 5 6 8 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24. 25 Page 561 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH I hereby certify that I have read the foregoing deposition by me given and that the statements contained herein arc true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of 2010. JANE DOE NO. 3 Job #1298 :(561) 832-75OOH -PROSE COURT REPORTING AGENCY, 43 (Pages 558 to 561) INC. . Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signod by cynthia bodkins (601 8d47f0154309-471241/41444•177538e37• EFTA01076763 Page 562 1 ERRATA SHEET 2 IN RE: JANE DOE NO.2 VS. EPSTEIN • • CR: Cynthia Hopldns 3 DEPOSMON OF: JANE DOE NO.3 TAKEN: April 6th, 2010 4 JOB NO.: 1298 5 DO NOTAVIUTE ON TRANSCRIPT - ENTER CHANGES HERE PAGED LJNE e CHANGE REASON 6 7 8 9 10 11 12 13 1 4 15 16 17 Please forward the original signed meta shed to this office so that copies may be distributed to all 18 parties, 19 Under paialty of pajury, I declare that t have read my deposition and that it is true and correct 20 subject to wry changes in font or substance entered here. 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 I 44 (Page 562) PROSE COURT.REPORTING.AGENCY;.:INC-* Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (801 Electronically signed by cynthia honk ins (601 86171016-be89-4702-9d44-60/7636c370 EFTA01076764