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Page 332 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. 6 Tuesday, April 6, 2010 10:11 - 12:13 250 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 cynthla hooking (801.061.978.2934) Electronically signed by cynthia hopkins (601-051-978.2934) Electronically signed by Cynthia hopkins (601-051.978.2934) 77a4b141-af9a-4001.9083.8116a007a087 EFTA01076765 EFTA01076766 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 333 1 APPEARANCES: 2 On behalf of the Plaintiff 3 ADAM D. HOROWITZ, ESQ MERMELSTEIN & HOROWITZ7,11. 4 18205 Biscayne Boulevard Suite 2218 5 Mama Phone: 5 7 On behalf of ROBERT l). CROTON, Et, ESQUIRE BURMAN, CRITTON, LUTIliR. & COLEMAN. LIP 9 303 Banyan Boulevard Suite 400 West P rida 33401 Phone: ALSO PRESENT: Daniel Downey, Videographer Visual Evidence, Incorporated Page 335 1 CONTINUED PROCEEDINGS 2 3 THE VIDFDGRAPHER: This is the 6th day of 4 April,210. The time Is approximately 5 10:11 M. This is the videotape deposition of 6 Jane Doe No. 6 in the matter of Jane Doe versus 7 Jeffrey Epstein. 8 This deposition is being held at 250 South 9 Australian Avenue, West Palm Beach, Florida 10 My name is Daniel Downey. I'm the videographer 11 representing Visual Evidence, Incorporated. 12 Will the attorneys please announce their 13 appearances for the record. 14 MR. HOROWITZ: Sure. My name Adam 15 Horowitz,. I'm counsel for Plaintiff, Jane Doe 16 No. 6. 17 MR. CRITTON: Bob Critton on behalf of 18 Mr. Epstein. 19 Thereupon, 20 (JANE DOE NO. 6), 21 Having been first duly sworn or affirmed, was 22 examined and testified as follows: 23 THE WITNESS: Yes. 24 DIRECT EXAMINATION 25 2 3 4 5 6 / a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 334 INDEX EXAMINATION DIRECT CROSS REDIRECT Continued JANE DOE NO. 6 BY MR. CRITTON 335 EXHIBITS EXHIBIT DESCRIPTION PAGE DEFENDANTS NO. 4 November 29, 2006 Letter 396 Page 3 1 BY MR. CRITTON: 2 Q. Ms. Doe No. 6, we're going to finish your 3 deposition today. You understand that? 4 A. Yes. 5 Q. All right. Since you were here on 6 February 17th of 2010 are ou currently still 7 employed by 8 A. No. 9 Q. All right. You — when you carne here or 10 when you were here on February 17th. In fact, I 11 think you were going to work when you left. 12 A. Yes. 13 Q. Correct? 14 A. Yes. 15 Q. And I think it was, was it your cousin who 16 was the supervisor there? 17 A. Manager. 18 Q. She was the manager? 19 A. Assistant manager. 20 Q. So, you stopped working, it looks like 21 answers to your interrogatories, you stopped working 22 sometime in March. When? 23 • A. March 12th. 24 Q. All right. Which would have been about a 25 month aSfter our deposition, correct? 2 (Pages 333 to 336) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801.061.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Bactronically signed by cynthla Winkles (601.061.976.2934) 77a4b(41.afga.40e1-9063-81f5e007a067 EFTA01076767 Page 337 Page 339 A. Yes. 2 Q. Okay. And why did you stop working there? 3 A. I got fund. 4 Q. Why did they lire you? 5 MR. HOROWITZ: Form. 6 THE WITNESS: Because I didn't come into work. q BY MR. CRITTON: 9 Q. Ts that what they told you? 10 A. No. Yeah, well, it's because I didn't come 13. in. 12 13 14 15 16 17 18 ell the last name, please. 19 A. 20 Q. Oh, 21 A. Yes. 22 Q. How long had you known Mr. 23 A. Since I was ten or I I • 24 Q. And he was a very close friend of yours? 25 A. Family friend, yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. And why did you not go into work that day? A. Because one of my good friends was murdered early that morning. Q. What was his or her name? A. A. Q. A. Q. Q. Is she one of your good friends? A. Yes, sheSnbest friend, Q. Okay. , A. Yes, sir. Q. And A. Q. A. A. And how was he murdered? He was shot in his house. And how did you hear about it? My friend Julie called me. What is Julie's name, last name? Yeah. I don't know how to spell it. And did she know as well? Yes. How — he was shot where? In the chest Page 338 Q. And was it, it was a — someone came into his house and shot him theft? A. Yeah. They, well, they tried to come inside.. He struggled with them, wouldn't let them in the door because his daughter and his fiancee were in the house. Q. .Okay. Was, was he selling drugs or something? Was this drug related? MR. HOROWITZ: Form. THE WITNESS: Yes. They were trziro (561) 832-75G0 1 rob him. 2 BY MR. CRITTON: 3 Q. And was he a chug dealer? 4 MR. HOROWITZ: Form. 5 THE WITNESS: I didn't know. They were 6 trying to rob him. That's what the cop said. 7 They didn't get into the house so I don't 8 BY MR. CRITION: 9 Q. tla daknow to be a drug dealer? 10 A. mother is the landlord or the, she 11 works at the office and that's how me, me and him met 12 during. 13 MR. HOROWITZ: He is asking if you knew -- 14 MR. CRITTON: I heard — 15 MR- HOROWITZ: - if you him to be a drug 16 dealer. 17 THE WITNESS: No, I didn't, I didn't know. 18 MR- CRITTON: I don't need help but that's 19 fine. 20 MR. HOROWITZ: Form. 21 THE WITNESS: I didn't know. 22 BY MR. CRITTON: 23 Q. Had you ever done drugs with M? 24 A. No. 25 Q. Are you sure? Page 340 1 A Yeah. 2 Q. So, he was shot and killed that day? 3 A. Yeah. 4 Q. And you heard about it. What time were 5 you supposed to be at work? 6 A. I was supposed to be at my meeting at 12. It 7 happened around like 9 or 10. 8 Q. In the morning? 9 A. Yes. 10 Q. On the 12th? 11 A. Yes. 12 Q. Okay. Did you call your cousin and tell 13 her? 14 A. Yeah. Well, I went to the, I was supposed to 15 go to the meeting. I went and I was crying, and they 16 told me to go home. And I was supposed to go back to 17 work at 5. 18 Q. And did you go back at 5? 19 A. No. 20 Q. Why not? 21 A. Because I called my manager. She was in 22 Chicago, so I had to call my cousin which is the 23 assistant manager. And she couldn't find nobody to 24 cover forme, so... 25 Q. Cover for you when? 3 (Pages 337 to 340) PROSE COURT REPORTING AGENCY,.. INC. C ) 832-7506 Electronically signed by eynthia hopkins (601451476-2934) Electronically signed by cynthia hopkins (601-051476-2934) Electronically signed by cynthla hopkins (601-051.976.2934) 77a4b141-af9a-40o1-9063-81f6a0072067 EFTA01076768 Page 341 1 A. For that night, 2 • Q why? 3 A. I was supposed to work 4 Q. You didn't go in on Friday, the afternoon 5 either? 6 A. No,1— my, the owner, because he 015113, 7 privately owned, he told me to go home for the meeting 8 because i was supposed to be there at 12. 9 Q. And he told you to come back at 5? 10 A. He didn't tell me to come back. 1 was 11 supposed to come back during'my shift. it was already 12 on the schedule. 13 Q. Okay. So, did you go back at 5? 14 A. No. 15 Q. Why not? 16 A. Because I couldn't go back to work. 17 Q. Why not? 18 A. Because I couldn't be sitting at 19 thinking what happened in my head. 20 Q. Did call your — anyone and tell inc them 21 that you couldn't come in bersice you were still so 22 upset? 23 A. Yeah, yeah. 24 Q. And that was your cousin? 25 A. Yeah. No, I called my manager, the manager in 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 343 soon after you were fired from did you get another job? It looks like at A. Well, I started working last Saturday but I got the job the Thursday before that. So, like two . weeks, ten days maybe. Q. All right. And have, have you been working there now? A. Yeah. Q. And is it a 40-hour-a-week job? A. Right now I am only part-lime because i am still training they say, but I have been working eight-hour days. Q. Do you get any benefits with Elt A. No. Q. If you start working there as a MI-time employee, will you get benefits? A. No. Q. Just the $7.50 an hour? A. Yes. Q. Are you doing any other employment at the current time? A. No. Q. Okay. And your boyfriend. he is still working I think heavy machinery or I Page 342 1. the morning, or, well, at 12, and she was in Chicago. ii. 2 So, ' cl she %mita do anything 1 would have to 3 call And = said she couldn't find anybody 4 which is my cousin. 5 Q. To replace you at 5? 6 A. Yeah. 7 Q. And then you just decided that you 8 couldn't go in — 9 A. She — 10' Q. — because you were so upset? 11 A. Yes. 12 Q. .And then did then say you've been 13 fired? • 14 A. No. My manager called me back and told me 15 that ifs not my immediate family, and that 1 have to 16 go; if not, she's going to have to fire me, so... 17 Q. And you said — ' 18 A. Yeah. . 19 Q. — go ahead and fire me? 20 A. (Witness nods head). 21. Q: Yes? 22 A. Yes. . 23 Q. Affright. And it appears that you then 24 got another job? 25 A. Yes. 1 2 3 4 5 7 Page 344 something? A. No, he got fired. He got laid off, as a matter of fact, a little before my son's birthday. Q. Your son's birthday was when? A. Yes. 8 MR. CRITFON: Correct. 9 MR. HOROWITZ: Of this year. 10 THE WITNESS: That's when he turned two. 11 BY MR. CRTTTON: 12 Q. And what happened, he just, they just said 13 we don't need you any more; you're getting laid off? 14 A. No. Their whole crew got laid off. 15. Q. What's he been doing? Does he get 16 unemployment? 17 A. Well, he is trying to. They are waiting. 18 Q. Is there a wait period or something? 19 A. No. I think the company is fighting for it 20 or — 21 Q. You still get insurance benefits for the 22 child though under- 23 A. No. He got it through the job, I have to — 24' Q. No, no. That's what I meant, he, he, 25 your, Aaro23sets insurance coverage trout: 4 (Pages 341 to 344) PROSE COURT REPORTING.. GENCYf INC: Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthia hopkins (601.061-976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) 77a4bf41.of9a40e1 -9063.81f 5a007a067 EFTA01076769 1 2 3 4 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 345 child — MR. HOROWITZ: Form. BY MR. CRITTON: Q. - stilt rigid? THE WITNESS: What do you mean insurance coverage? BY MR. CRITTON: Q. You testified at your last de tadjap that, that he had insurance benefits, l=? A. He has health. Q. Health insurance benefits which were applicable to your son. A. Through the job. Q. Right. So, he still has those? • A. I don't think so since he got laid off. Q. How big, how big a business is it? A. It's -- I don't know. Q. Two people? A. I just know he works there. Q. Is it 20 or 30 people, do you think? A. I don't know. I know he works there on a crew with a couple of people. Q. Tell, tell him about Cobra because under the federal law he is entitled and the employer has to pay it so... Page 347 1 current time relating to Mr. Epstein or any other 2 emotional condition that you have? 3 A. No. 4 Q. You and 5 yes or no? ' 6 A. Yeah. 7 Q. Any plans yet? 8 A. No. 9 Q. Since your deposition have ou seen or 10 spoken with either Jane Doe or M . ? 11 A. Isete funeral. 12 Q Of 13 A. Yes. 14 Q. Okay. Was it a pretty sad funeral? 15 A. Yeah. 16 Q. And did you feel -- I mean, apparently it 17 affected you enough that you didn't want to go to 18 work? 19 A. Yeah. 20 Q. Does it still affect you now? 21 A. Yeah. I think about him a lot. 22 Q. RAW'S la' you hadstbajgdividuals, you had 23 a former boyfriend, Mr. who shot himself, 24 correct? 25 A. Yes, but that's different. talk anymore about marriage, Page 346 1 A. He was -- 2 Q. He's not, he is not getting it? 3 A. He was paying his health benefits out of his 4 check, so... 5 Q. So, the company didn't pay it? 6 A. He was paying co-fees for it, so I don't — 7 co-pay, 1 don't think. 8 Q. Tell him to still check. Have you seen, 9 since your deposition on Felnuaty 17th, 2010, have 10 you seen any psychologist or psychiatrist, mental 11 health counselors for any reasons relating to 12 Epstein or any other psychiatric or psychological 13 issues? 14 A. Since the last time I seen you? 15 Q. Yes, ma'am. 16 A. No. 17 Q. Have you seen any physicians for any 18 reason? 19 A. No. 20 Q. Medical doctors, medical, been to an 21. emergency room for any reason? 22 A. No, no. 23 Q. And you have no — do you have any 24 appointments to see a psychologist or psychiatrist 25 or a mental health counselor for any reasons at the 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 348 Q. And how is that different? A. Because someone took from his two-year-old daughter. She was right behind him when he was shot. They took him from her. Q. Okay. And how does that make you feel? A. It's wrong. Q. Of course it's wrong, but how does it make you feel? A. That just -- I don't know, just I could lose, you know, my family or anybody quick. It just didn't -- it doesn't feel real. Q. Okay. And, and because the sante thing could happen with you or it could happen with A. It could happen to anybody. They, they didn't even, supposedly they didn't even know him. That's what the cops say. They didn't even know him that they just heard that he was doing something and went and knocked on the door. Q. You said "they, they heard- that he was doing something; the people who shot him? A. Yes. Q. What did they hear? What did the cops say? A. The cop said that they heard that he was, had PROSE COURT REPORTING 5 (Pages 345 to 348) AGENCY, INC. (MI) Electronically signed by cynthia bodkins (601.051.970-2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) 77•4t441419•40040634115s007•067 EFTA01076770 Page 349 I money or he was dealing drugs. I don't know. 2 Q. So, that's why they purportedly broke into 3 the house? 4 A. They didn't break in. They tried. 5 Q. Oh, and they just then shot through the 6 door? 7 A. He was standing at the door fighting with them 8 because they were trying to get into the house. 9 Q. Oh, was he actually outside of the house? 10 A. He was — he answered the door because they 11 knocked and they had a gun and tried to get into the 12 house, and his daughter was behind him. 13 Q. Did go with you to the funeral? 14 A. Yes. 15 Q. And you saw Jane Doe there. Did you talk 16 to Jane Doe at all? 17 A. No. 18 Q. You just saw her there? 19 A. Yeah. 20 Q. How about have you, have you spoken with 21 her separate and apart from seeing her at the 22 funeral? 23 A. No. 24 Q. Have you talked to M. at all? 25 A. No. Page 351 2 might die, the events with 1 you were in the car accident and thou t she they 3 are all -- 4 A. 5 Q. I am sorry, 6 a significance impact on you? 7 MR. HOROWITZ: Form. 8 BY.MR. CRITTON: • 9 Q. Is that true? 10 A. I mean he just died like two weeks ago. 11 That's why it has an impact on me. It is still fresh. 13 surrounding having committed suicide Q. Are y • that the events 12 14 so close, so close to you, no longer has an effect 15 on you? 16 A. I didn't say that. I'm just, you blow, I mean 17 it's different when somebody steals their own life, and 18 when someone gets their life stolen from them. It's way 19 different. 20 Q. You mean a suicide versus -- • 21 A. Yeah. 22 Q. — versus a random murder? 23 A. It's way different, yes. 24 Q. Which do you consider more, lice, 25 traumatic from your perspective? — all seem to Page 350 1 Q. Did you -- the ex with or what you 2 have at least seen with MI pretty 3 traumatic for you? 4 A. Yeah. It just hurts you know. It's wrong. 5 Q. Had, had any nightmares about it or — 6 A. No. 7 Q. Had any trouble sleeping? 8 A. No. I just think about him, you know, when 9 Fm in my neighborhood or go by his house or something. 10 Q. Did you know his parents? 11 A. Yeah. 12 Q. Okay. And did you go back to the house 13 for the reception 14 A. Yeah, yeah, I've been at — 15 Q. Or like the wake afterwards? 16 A. I have been at her house for like 10 days now. 17 Q. Everyday? 18 A. Yeah. 19 Q. Okay. And how is the mother doing? 20 A. She's actually keeping everybody together. 21 Q. Does he have other brothers and sisters? 22 A. Yeah. 23 Q. From listening to your testimony on 24 tua , 17th N s. Doe, events like what happened to 25 what happened with your mother when (M) 1 2 3. 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 352 MR. HOROWITZ: Form. THE WITNESS: It's all pretty traum — sad, you know, that this had to happen to good people but it's what happens. BY MR. CRITTON: Q. The incident with your mother when you were in the automobile accident back in 2004, does that still bother you as well? Well, let me strike that The accident had an impact on you at the time certainly, correct? A. Uh-huh. Q. And you found that very traumatic at the time? A. Yes. Q. Okay. Had trouble sleeping, thought your mother might di; thought she could be taken from you as well? A. Yeah. Q. Okay. And that's part of the same issue you have about driving or certainly driving on 1-95 or an interstate or a toll road, correct? A. Yeah. Q. Tell me what a typical day is for you now? What do you do, excuse me, on a typical day? A. Go to work. 6 (Pages 349 to 352) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkine (601.051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkine (601.051-976-2934) 77a4b141-af9a-40o1.9063-81f5aa007a067 EFTA01076771 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Q. In Lake Worth? 24 A. Greenacres. g umennon2.... All let. And then does, does the son 25 7 (Pages 353 to 356) 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 353 And do you have a regular, excuse me, at do you have a regular shift? A. Yeah. Igo in at 8. Q. Until when? A. Well, I can leave from 2 to 4. Depends how busy we are. Q. All right. Is it your choice or the managers? A. Well, I can — like I said it depends how busy we are. Q. So, if it's not busy, you can say I ern leaving? A. Yeah. Q. And if it's busy, then they expect you to say? A. Yes. Q. Okay. Which do you work at? Where is the location? A. Lake Worth and log. Q. All right. So, when you're not working, so you get up, you get up in the morning and take care of your baby? A. Yeah, well, I bring him to my mom's so I can get ready to work because I have, I wake up at 7 and be at work by 8. Page 1 stay with her the whole day? 2 A. Yeah, until I get off. 3 Q. And then you go and pick him up? 4 A.. Yeah. 5 Q. And when you go pick him up, then you go 6 home? 7 A. Yeah. 8 Q. Okay. And then what do you do? 9 A. Make dinner. 10 Q. All right. And what, watch TV? 11 A. Yeah. We hang out. He usually watches Elmo 12 'till - 13 Q. Your son? 14 A. Yeah. 15. Q. All right. And you hang out until you go 16 to bed around what time? 17 A. He goes to sleep at like 8. And then well 18 watch some TV and :4) to sleep. 19 Q. Okay. and you are still living 20 together? 21 A. Yeah 22 Q. Okay. What's doing now since he got 23 laid off? 24 A. Fixing our house. 25 Q. lie Is working around the house? Page 354 Q. Do you feed, feed your son, isn't it? 2 A. Yeah. Well, he is just now getting — when I 3 bring him over there, he is just getting up. So he is 4 going to take -- 5 g Does your morn then feed him? A. Yes. Q. Does she work at 7? A. Yes. Q. Is she, what — who does she work for again? A. AAffordable Insurance. Q. Okay. And when she goes to work, does she work out of the home? A. No. Q. And who takes care of your son when — A. She drops him off at my aunt's house. Q. And her name is? A. Q. Can ou s it for me? A. Q. Where does she live? A. Page 356 1 A. Uh-huh. 2 Q. Yes? 3 A. Yes. 4 Q. Is he looking for other work as well? 5 A. Well, yeah, in between trying to deal with his 6 unemployment. 7 g Okay. So, he is trying to get his 8 unemployment benefits, correct? 9 . .A. Yes. 10 Q. And then working on the house? 11 A. Yes. 12 Q. Has he applied for any other jobs? 13 A. 1 think he went to some interviews, yeah, like 14 the USD Meat. 15 g I'm sorry? 16 A. The Direct Meat or whatever, the USD Meat or 17 something. 18 Q. All right. 19 A. And some other place on Lake Worth. I didn't 20 go. 21 Q. But nobody has at least hired him as of 22 todays date? 23 A. No. 24 Q. Okay. In your answers to the second interrogatories it appears you have a, you have a PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051.976-2934) 77s4b141.09a-40e1-9063-81t5a007a067 EFTA01076772 Page 3,57 Page 359 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MySpace since 2008? A. Yeah. Q. Okay. Do you use it on a regular basis? A. Yeah. Q. And you, you have a Facebook page, but what you haven't activated it yet? A. No. Q. You haven't punched in the profile? A. Yeah. I haven't I think I signed up for it but I never went on it. I don't know how to use it. Q. And you actively use your MySpace? A. Yeah. Q. And do you use that every day? A. Maybe every other day. Q. All right. And you correspond with your friends or family? A. Yeah. Q. What kind of computer do you have? A. Well, right now I have a Dell laptop. Q. Okay. And do you take that with you to work? A. No. I have my phone. Q. Okay. And what kind of phone do you have? A. IPhone. Q. And how long have you had an iPhone? 1 like 17. 2 Q. And you bank — how long have you been 3 banking? How long have you had a bank account? 4 A. Since, yeah, I was like 18. 5 Q. Did you ever have like a savings account 6 or something that your parents set up or anyone set 7 up for you? 8 A. Well, the bank is me and my mom share the 9 same. 10 Q. Do you have the same bank account? 11 A. Yes. It's a joint bank account. 12 Q. Is it a checking account? 13 A. Yeah. 14 Q. Okay. And why do you and your mom share 15 the same account? 16 A. Because she has three accounts with Chase 17 already, so to add on, it would be easier. 18 Q. Okay. So, she has her, two of her own 19 accounts and then she has an account with you? 20 A. Yes. She — 21 Q. And you said — sorry. 22 A. She added my account to hers. 23 Q. You can use that account. It's basically 24 your account. It just happens to be in both your 25 names? Page 358 A. Since November of last year. 2 Q. Okay. So, you're on an AT&T plan? 3 A. Yeah. Q. And the iPhorte, is that, are you and 5 on the same program or the same plan? A. No. 7 Q. Okay. And do you pay for your own plan? 8 A. Yeah. Well, I share a plan with my dad. It's 9 a family plan. 10 Q. How much does that cost you a month? 11 A. One hundred bucks. 12 Q. And your laptop, did you buy — how old a 13 laptop is it? 14 A. The laptop bought in January of this year. 15 I'm malting payments on it. 16 Q. Do you have credit cards? 17 A. Yeah. 18 Q. Okay. Which credit cards do you have? I 19 am not going to ask you for numbers but what credit 20 cards do you have? 21 A. I got Capital One, Wal-Mart and that's it, and 22 I have a bank card. 23. Q. How long have you had credit cants, 24 • Ms. Doe No. 6? 25 A. My...dadFt me first credit card when I was 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 360 A. Yeah. Q. I may have asked this before, so I 'apol ting Have you ever talked with ; that is, is she aware that you're a Plaintiff in a lawsuit? A. (Witness shakes head.) THE COURT REPORTER: Is that -- BY MR. CRITFON: Q. No? A. No. also listed M , as one of your closest friends over the last four or five years. Is she aware you are a Plaintiff in a lawsuit? A. Yeah, she knows something about it Q. Okay. And how does she know about it? A. Because last time I came here, I told her that I had to, what I had to do. Q. Okay. And what, I mean that you had to testify? A. That I had to — Q. That I was asking you questions? A. — go downtown with my lawyer. And I explained to her that I was in a lawsuit and that I would tell her about it later. Cein. 8 (Pages 357 to 360) PROSE COURT REPORTING AGENCY, INC. (M) Electronically signed by cynthia bodkins (601451-976-2934 Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601.051.916.2934) 77a4bf41 -af9a-40e1 -9063-81(6a007a 067 EFTA01076773 Page 361 1 Q. So, she doesn't know anything about why 2 you're in a lawsuit? 3 A. No. 4 Q. Have you, have you ever been in a lawsuit, 5 other than this lawsuit have you ever been in a 6 lawsuit for anything before? 7 A. No. 8 Q. Was your mom involved in a lawsuit when 9 they had that automobile accident with the semi? 10 A. No. 11 Q. Did that turn into a lawsuit? 12 A. No. 13 MR. HOROWITZ: Form. 14 BY MR. CRITFON: 15 Q. Was a claim filed or do you know? 16 A. No, no. 17 Q. Your mom never filed anything? 18 A. No. 19 MR. HOROWITZ: Form. 20 BY MR. CRITTON: 21 Q. Was the car repaired? 22 A. No. 23 Q. Was it drivable? 24 A. No. 25 Q. What happened to it? Page 362 1 A It was junked. 2 Q. Okay. And how do you know that she didn't 3 file a lawsuit? 4 A Because she didn't, because I know she didn't. 5 She was filing for bankruptcy. 6 Q. Your mom was at the time? 7 A She just filed for bankruptcy in 2000 or 2002 8 or something like that. It was like six, seven years 9 ago. But, yeah, she was filing for bankruptcy. The car 10 was junked. The tires blew. It wasn't nobody's fault. 11 Thafs what they said. 12 Q. Okay. A typical day that you told me 13 about going to work, take your son to your mom's and 14 then son goes to your aunts. You work, pick up son, 15 you watch a little TV, get dinner ready, talk, I 16 assume, with and you guys go to bed; is that 17 pretty much Aug you've been doing the last couple 18 of years? 19 MR. HOROWITZ: Form. 20 BY MR. CRITTON: 21 Q. Since your son's has been born? 22 . A...No. I we take him, we went to the zoo 23 last week with daughter, his wife. I take him 24 around the neighborhood sometimes in his little wagon, 25 his little car, his little Power Wheels car that he 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 363 drives around, too. I mean, I hang out with my son most of the time, yeah. BY MR. CRT'S: Q. Does do things with you and your son, too? A. Yeah. Q. Okay. So, he is a pretty active father? A. Yeah. Q. All right. Was there a time — well, let me strike that. You, you've testified that you went to Mr. Epstein's home on one occasion, August 8th of '04, correct? A. Yeah, that was one time. Q. Prior to the time that you were at Mr. Epstein's home, I want to talk a little bit about some background that you, that you provided or that I provided at least to your attorney with regard to issues that you had with, issues that you had with police or law enforcement. Okay. Have you had a chance to look at a bunch of police reports? A. No. Q. Have you looked at any police reports? MR. HOROWITZ: Form. THE WITNESS: About who? Page 364 1 BY MR. CRITFON: 2 Q. About anything? 3 MR. HOROWITZ: Form. 4 THE WITNESS: About my case when I was on 5 house arrest? 6 BY MR. CRITTON: 7 Q. Okay. Have you looked at some of those? A. Not recently. 9 Q. Okay. When you say not recently, did you 10 look at it before you were deposed in February? 11 Before I, we started your deposition in February, 12 did you have a chance to look at that? 13 A. No. 14 Q. Okay. Do you remember an incident that at 15 least you were involved in where you were followed 16 into the woods and, by a number of girls and were 17 attacked and threatened back in August of '03? 18 MR. HOROWITZ: Form. 19 • THE WITNESS: I was followed into the 20 woods? 21 MR..CRITION: Right. 22 THE WITNESS: Was that at school? 23 BY MR. CRITTON: 24 Q. Apparently you were on your way home from 25 middle school. Do you remember that? 9 (Pages 361 to 364) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (601.051.970.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia booklets (601.051.97&2934) 77a4b141-a19a-4001-9063.81t6a007a067 EFTA01076774 Page 365 Page 367 A. Yeah. Q. All right. And what happened, what 3 occurred on that occasion? A. Nothing. They pushed me around and was just talking and that's it, and we didn't even fight. ▪ Q. Okay. Then why, why did you report it? The only way, I assume the people who came after you 1 wouldn't have called the police to report that they 9 attacked you? 10 A. The school police. 11 MR. HOROWITZ: Form. Wait for his 12 question. 13 BY MR. CRITTON: 14 Q. Let me finish my question. I, I assume 15 that the girls who attacked you wouldn't have called 16 the police. So, how was it that the Palm Beach 17 Sheriffs office became involved in August of '03 - 18 MR. HOROWITZ: Fenn 19 BY MR. CRITTON: 20 Q. — as a result of that incident? 21 MR. HOROWITZ: Form. 22 THE WITNESS: Because the reason the fight 23 broke, got we there is a school 24 police and Dr. (phonetic) that would 25 drive wound on the golf course or on the golf 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 finish doing my laundry, and there was some guy in my drier looking through my clothes, and he turned around he had my drawers in his mouth. BY MR. CRITTON: Q. Your Underwear? A. Yes. Q. And what did you do? Did you scream? A. Nothing. I went back inside. Q. Did you yell? A Yeah. I went back inside and I told my parents, and they came outside and he was gone. Q. Did they find the person? A They all went looking for him. I don't think 90. Q.. Did the police come? A. I don't remember.. Q. Okay. !asked you to assume that there is — do you remember —. A Yeah. Q. -- looking at a police report about it? A. No. I didn't ever look at the police report. If you got one, ! assume there was one mat Q. All right. And did the police come and interview you at all? A I don't know. I was 13. Page 366 1 cart and watch all the kids walk home. 2 So, they heard about what's happening, 3 because we're what, 13, 12 years old, a bunch 4 of little middle school kids. They were all 5 loud, so the school police made a report. 6 I don't even remember that. I don't 7 remember talking to no cops or nothing. 1 8 remember walking home, going to Wendy's and 9 getting picked up. 10 BY MR. CRITTON: 11 Q. Okay. And who picked you up? 12 A. My mom like always. 13 Q. All right. Do you remember another 14 instance in '03 where you went into a shed and there 15 was a, I guess you were doing your laundry and there 16 was some man in the shed? 17 A. Yeah. 18 Q. Okay. And I would ask you to assume that 19. at least the police reflects that it was on 20 February, I'm sorry, r Tell me what 21 you remember about that incident. 22. A I went — 23 MR. HOROWITZ: Asked and answered, but go 24 ahead. 25 THE WITNESS: I went to the shed to go 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 368 Q. You can answer yes or no. Again -- A I don't arum nber. MR. HOROWITZ: Just say — MR. CRITTON: Let me just - MR. HOROWITZ: There you go. MR. CR]TFON: I don't know what you remember or what you don't remember. And therefore, when I'm asking you a question, don't get upset atme because I wasn't there at the time. Do you understand that? THE WITNESS: Yeah. MR. CRAYON: All right. So, if I am asking a question, it's because I don't know what the answer is most of the time. All • right? THE WITNESS: Yeah. BY MR. CRITTON: Q. So, you don't remember talking to the police at all, is that correct? A No, I don't remember. Q. Okay. Do you remember an incident in, an in November of 2003 between yourself and named laetic)? Do you remember a person A. What happened? I don't -- 10 (Pages 365 to 368) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801A51.976.2934) Electronically signed by cynthia hopkins (601.051-9762934) Electronically signed by cynthia hopkins (601.051-976.2934) 77a41041-af9a-40e1-9063-8115a007a067 EFTA01076775 Page 369 1 MR. HOROWITZ: Bob, can you share that one 2 with me. I am not sure that — 3 MR. CFUTTON: I sent you everything. 4 MR. HOROWITZ: No. I understand, but can you MR. CRTITON: Unfortunately, I have 7 written all over all of these. 8 MR. HOROWITZ: Okay. 9 BY MR. CRTFT'ON: 10 Q. This is -- it happened, apparently you 11 were struck in the eye by Ms. You were 12 talking with her boyfriend, and you-all, the two of 13 you started fighting. Does that ring a bell with 14 you at all? 15 MR. HOROWITZ: Form. 16 TliE WITNESS: Yeah. Man, girls. She 17 . thought I was talking to her boyfriend, and she 18 came and confronted me about it and started 19 trying to fight with me so. 20 BY MR. CR1TTON: 21 Q. Again, the Palm Beach Police were called 22 again. 23 A. Yes. 24 Q. So, did you have to give a statement to 25 the police? Page 371 1 trust? 2 A. I don't — what do you mean by that? 3 Q. Well, would you, would you, if you had a 4 problem, if you had an issue, would you call that 5 you thought you needed to talk to the police, the 6 police is someone that you felt that you could call, 7 dial 911 and tell them if you had a problem or 8 somebody had done something to you that you thought 9 was wrong or illegal or inappropriate? 10 A. If I had an emergency, I would call 91i . 11 That's all. That doesn't make any sense. 12 Q. All right. Well, did you feel like you 13 could tell the police what had happened in at least 14 each of these dime instances, and they could 15 evaluate whether what you were saying was hue or 16 not? 17 MR. HOROWITZ: Form. 18 THE WITNESS: In two of those incidence, 19 or I know one of them. I didn't talk to the 20 police. Do you have any daughters? I mean, 21 like, come on. Girls get into fights all the 22 time because other girls are talking about them 23 and it's middle school. 24 BY MR. CRiTTON: 25 Q. All right. So, its pretty common for Page 370 1 A. Yeah. 2 Q. All right. And did they take err/ action 3 at that time? 4 MR. HOROWITZ: Fonn. 5 THE WITNESS: I don't know. They were 6 saying that they were going to press charges on 7 me. 8 BY MR. CRITTON: 9 Q. Were any charges ever pressed? 10 A. I don't think so. 11 Q. Okay. So, at least, I mean we've talked 12 about, these may not be all of them but an incident 13 in August of '03, another incident in March of '03, 14 third incident now in November of '03. Are those, 15 at least in those three instances, the police were 16 called so you had to deal with the police. Correct? 17 MR. HOROWITZ: Fonn. 18 THE WITNESS: Yeah. 19 BY MR. CIUTTON: 20 Q. All right. And you knew, did you consider 21 the police to your friends at that time? 22 A. No. 23 Q. Did you consider the police to be bad? 24 A. No. 25 Q...a.SomeoneMat you would Mist or wouldn't Page 372 1 middle school girls to get in fistfights? 2 A. Yeah. 3 Q. All right. And that's certainly been your 4 experience? 5 A. I mean, all, you don't watch the news like 6 there was girls that took a girl in the house and, ilke, 7 beat, there were like three of them that beat her up 8 inside the house. 1 mean, like, come on. The girls do 9 it all the time. ifs not like, ifs not — it wasn't a 10 big deal. I don't see why you're making a big deal out 11 of it. Girls will be girls. They cat fight. 12 Q. All right. And so at least in your 13 experience when you were in middle school pretty 14 common for girls to get into fights and have yelling 15 matches or fistfights with each other and then the 16 next day or a few days later they are friends again? 17 A. Yeah. Exactly. • 18 Q. Okay. 19 A. Exactly how it goes. 20 Q. When you were in middle school did you 21 get, did you get to make choices about classes that 22 you were going to take? 23 A. No. 24 Q. You had to go to certain classes? 25 A. Yeah. -.vs...—. 11 (Pages 369 to 372) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-9764934) Electronically signed by cynthia hopkins (601-051.976.2934) 77a4bf41-af9a-40e1.9063-8115a007a067 EFTA01076776 Page 373 Page 375 1 Q. It was all a structure? 2 A. Yeah. 3 Q. All right. And then as to, in terms of 4 your attendance at school, did you consider 5 yourself, did you attend on a pretty regular basis 6 or were you pretty truant? If I say, if I use the 7 word truant, does that mean anything to you? 8 A. like- 9 Q. You don't go to school. 10 A. Yeah. 11 Q. That is you skip school. Somebody who 12 skips school would be considered truant 13 A. Yes. I did that a lot. 14 Q. And, and did you do that during middle 15 school? 16 A. That's the only school I went to. I didn't go 17 to high school. 18 Q. That's right. So, by the time you, you 19 were in middle — or because you didn't go to high 20 school, in middle school when you skipped school, 21 how often would you skip — let me start again. 22 That was an awful question. 23 How often would you skip school when you 24 were in middle school? 25 A. I don't know. 1 Q. Right? 2 A. Yeah. That's what skipping school is. 3 Q. All right And if you had skipped, if you 4 had skipped school, you had to make a decision, 5 right? You had a choice to either, Ism going to go 6 to school today or I am not going to go to school. 7 A. Not really. It was a group of kids, either 8 they were skipping — I wasn't skipping by myself. It 9 wasn't like l was, hum, maybe l just don't want to go to 10 school and I am going to go sit in this bush by myself. 11 it wasn't like that. 12 Q. You didn't have to sit in a bush. I mean, 13 you can — 14 A. I mewl, where else was I going to go? 1 15 wasn't going to go home. 16 Q. Why not, ifyour mom wasn't there? 17 A. She comes home for lunch. 18 Q. Okay. So, you knew she came for lunch and 19 if you sldpped 20 A. Yeah. 21 Q. Let me finish the question. So, you knew 22 during middle school, 2002,2003, that if you 23 skipped school and you stayed home, mom, you would 24 see mom at lunchtime. So you couldn't obviously 25 stay there, right? Page 374 1 Q. A third of the time, a half of the time? 2 A. Idon't know. 3 Q. Once in a while, once a week? 4 A. Maybe like once a week, once in a while. I 5 don't know. I don't remember. 6 Q. And if you were going to skip school would 7 you go off to school and then just; that is, your 8 mom or your, you know, whoever you were living 9 who were you living with at that time, your mom? 10. A My mom. 11 Q. Okay. Your mom was going to work? 12 A. Yes. 13 Q. She'd go to work and she would send you 14 off to school? 15 A. Yeah. 16 Q. Okay. Except sometimes you wouldn't go? 17 A. Yeah. 18 Q. All right. If you didn't go would you 19 stay home? 20 A. No. 21 Q. Where would you go? 22 A. To whoever I was skipping with. 23 Q. And if you, if you skipped school, you 24 knew that you were supposed to be at school, right? 25 A. Yeah- Page 376 1 A. Yeah. 2 Q. And in terms of whether you were going to 3 skip school or not, and would you coordinate that 4 with your friends or would you get to school and a 5 bunch of people would just say, hey, lets not go 6 today? 7 A. Yeah, that's how skipping school works. 8 Q. And so, but it would be your choice? 9 A. I guess, yeah. 10 Q. That is, and you would have to make a 11 voluntary decision, I am either going to go to 12 school today or I am not going to go to school, 13 right? 14 A. Yeah, pretty much. 15 Q. All right. And if you didn't go to 16 school, you know that that was wrong because you 17 were supposed to be in school, right? 18 A. Yeah, I guess. 19 Q. Do you remember in May of 2000, May 20th 20 of 2004 that you were punched in the head, a friend 21 punched you in the forehead with a closed fist 22 Again another police report was filed. Do you 23 remember that? 24 A. No, I don't remember that. 25 But consistent kind of with PROSE COURT REPORTING 12 (Pages 373 to 376 AGENCY, INC. 4 Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-061.976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) 77a4b141-at9a-400-9063-81t5a007a067 EFTA01076777 Page 377 1 what had happened in the past? 2 A. I don't even remember what you're talking 3 about. 4 Q. Well, see if this refreshes your 5 recollection is that it vias-.imr mothers name is 6 how do ou that, 7 A. 8 Q. called the police. She 9 advised that het daughter had a verbal argument with 10 a friend for some unknown reason and the friend's, 11 the friend had punched you in the forehead with her 12 fist. Okay. 13 The person apparently lived in Tavares 14 Cove mobile home. Grabbed you by the arm, hit you 15 with a closed fist. Again, just kind of a routine 16 event for you in middle school during that time? 17 A. I don't is there like a name of the person? 18 I don't. 19 Q. No. They have them blacked out. 20 A. See my mom called. I mean, like, she's my 21 mom. 22 Q. All right. But you don't remember 23 anything about that? 24 A. No. 25 Q. Okay. Do you remember in April of 2005, Page 378 you and your brother got into a 2 fight and the police were called? 3 A. He's my brother. Oh, my God. 4 MR HOROWITZ: Form. 5 MR. CRITTON: Well, again, there's, 6 there's a distinction. There is — kids fight 7 all the time. THE WITNESS: Do you have any other police 9 reports about whole neighborhood. I mean the 10 cops are always in my neighborhood. They like 11 live there. So, l mean, like they are like 12 there. So, when something happens, they rush 13 over. 14 BY MR. CFUTTON: 15 Q. All right. So, at least as you were 16 growing up the police were in your neighborhood as 17 .a, on basis? 18 A. Yeah. 19 Q. So, at least in the instance where you're, 20 they came to your house because you and your 21 brother, because you and your brother were having a 22 fight, that was just again kind of a normal 23 occurrence in the neighborhood for you? 24 • A. Not in the neighborhood. I don't — he is my 25 brother. We don't get alone! is 23 and 1 am — or v2t,rlraia0ZeWi abmgfrefIV 1 2 3 4 5 6 7 8 9 10 11 12 3 14 15 16 17 18 19 20 21 22 23 24 25 Page 379 he is 24 and I am 19, like, we don't like the same stuff We just don't get along. It's just brother and sister. Q. All right. Well, every time that, is it your testimony that every time there was a fight between a brother and a sister in the neighborhood, the police would show up and fill out a report? A. There has been a lot less that they have shown up for. Q. If you thought you had a problem that you needed to discuss with the police or something illegal had happened or inappropriate happened, at least the police were in your neighborhood enough that you could call the police or talk to the police and report it to them, right? MR. HOROWITZ: Form. MR. CRITTON: Based on what you told me. THE WITNESS: I wouldn't walk up to them and start talking to them, no. BY MR. CRITTON: Q. Why not? If you thought someone had done something inappropriate to you or illegal or improper, you could certainly if the police were in your neighborhood as often as you indicated back in the 2003, 2004 time period, you could have gone to Page 380 1 the police and told them, true? 2 A. If you read on all those police reports, they 3 were there because of me. So, I'm not going to walk up 4 to them and be like, hey, I got a probkm. 5 Q. Why not? 6 A. Perauge they are obviously there for something 7 that one of us did, so I am not going to walk over there 8 and start [Wong to them. 9 Q. Well, why? If you thought that somebody 10 had done something to you, why would you not feel 11 comfortable enough to go up to the police and tell 12 them what happened if you thought it was a 13 significant event? 14 A. Do you just want me to walk up to some random 15 cruiser and knock on the window and start talking to 16 them? Why don't you try that and tell me how it goes. 17 They are going to tell you call 9111, call the 18 nonemergency number, call them, and they will call me. 19 That's exactly what they are going to tell you. 20 Q. Okay. 21 A. They are not going to talc to you. They are 22 not going to have a Ml blown Dr. Phil conversation 23 with you. 24 Q. And so from your perspective, if you 25 really wanted the police, if you wanted to report 13 (Pages 377 to 380 PROSE COURT REPORTING AGENCY, INC. I Electronically signed by cynthia hopkIns (801.061476-2934) Electronically signed by cynthia hopicins (601.051.976.2934) Electronically signed by cynthia hooking (801-051-978-2934) 77341)141 -af9a-4001 9063-8115a 007a067 EFTA01076778 Page 381 1 something that you thought had occurred illegal, 2 illegally to you or some, someone had done something' 3 inappropriate with you, you had certainly the 4 knowledge back in 2002, 2003, 2004, 2005 to call 911 5 and report it, true? 6 MR. HOROWITZ: Form. 7 THE WITNESS: I have known to call 91 1 3 since I was like six years old. 9 BY MR. CRITTON: 10 Q. All right 11 A. So — 12 Q. So, the answer to my question is, yes? /3 A- Yeah. 14 MR. HOROWITZ: Form. 15 BY MR. CRITTON: 16 Q. Do you remember when the police were 17 called in June of 2000 -- June 25th of 2005, because 18 you threw a rock at a car window at one of your 19 friends and broke it? Do you remember that? 20 A. Yeah. We were playing around and I paid for 21 that window. 22 Q. Well, the police were called? 23 A. No, I didn't, I didn't know the police were 24 called. I know that it was the — we were all sitting 25 at the office with the manager and everybody. It's her Page 383 1 couple, but the police again were called. There was apparently a fight between your mother, between your 3 father about something silly like a bag of chips and 4 yourself, and your mother stepped in front of you 5 and got hit by your father instead? 6 MR. HOROWITZ: Form. BY MR. CRITTON: 8 Q. Do you remember that event? 9 A. No. 10 Q. Do you deny it happening or you just don't I remember it? 12 A. No. My parents never hit me or never hit my 13 brother. No, I don't. I couldn't even believe that if 14 you tried to tell me that happened, no. 16 recollection, is on the the Q. Let's see if this refreshes our 15 17 police, the Palm Beach Sheriffs Office came to your 18 house. The mother and father were fighting. Your 19 father reportedly was drunk and was yelling at the 20 mother about a bag of chips being left on the 21 counter. 22 • You started to yell or you were yelling at 23 your father telling him to stop yelling at your 24 mother. And he got in your face and went into your 25 .room, got in your face, yelled at you and attempted I Page 382 1 son. And we were all playing around throwing stuff at 2 each other, and I threw a rock and it just tapped his 3 window and it shattered. 4 Q. The rock just tapped the window? 5 A. Yeah. 6 Q. And what, a windshield of a car shattered? 7 A. No, it was the side window. 8 Q. Side window in the trailer? 9 A. No, in a car. 10 Q. Oh, that's what l thought you said. So, 11 it's not the windshield. It was the side window in 12 a car? 13 A. Yeah. 14. Q. And you threw a rock? 15 A. Yeah. 16 Q. Just tapped it? 17 A. We were playing around all throwing stuff at 18 each other. I guess it just tapped the window and the 19 whole thing spidered. If that's that's the only 20 knowledge that I know of breaking a window, because I've 21 never done nothing to nobody's car. If you look I have 22 never touched nobody's house or car or nothing. I am 23 not that type of person. 24 Q. Do you remember in July, on July 20th of 25 Page 384 1 to hit you, but the mother stepped in between you 2 and your father. Do you remember that? 3 MR. HOROWITZ: Font 4 THE WITNESS: No. 5 BY MR. CRITTON: 6 Q. Okay. You're not saying it didn't happen. 7 You just have no recollection of it? 8 A. No, t am saying it didn't happen because 9 did that — is that like a police report? How would 10 they know what happened in my house. We didn't come out 11 and say anything because I know my mom and I know my 12 dad, and you are tripping. No, there is no way. I 13 don't know -- 14 Q. How am, how I tripping? 15 A. Because that's ridiculous. My dad never hit 16 me or my brother. 17 Q. How about your mom? 18 A. Newt'. I am telling you never. 19 Q. So, if tha.e is a police repon on this 20 you think someone just created it, made it up? 21 MR. HOROWITZ: Form. 22 THE WITNESS: No. I think that they have 23 the wrong story because that's not what 24 happened. I know my dad is a drunk, but he '06 police again were called. I am skipping a 25 always fell asleep before anything. My dad is t---allt ameetwalVt•SemilaVAnn. 3141. , + , ......wa.weecna t.4" -LV•74abo2.1.1•Sah)Sawdmasi 14 (Pages 381 to 384) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins (601451-9762934) Electronically signed by Cynthia hopkins (601-051-976-2934) Electronically signed by Cynthia hopkins (601.051-976-2934) 77a41)141-af9a-4001-9063-8115a007a067 EFTA01076779 Pauc 3 8 5 Page 387 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 not, no. . BY MR. CRITTON: Q. All right. And the other ones we've covered. Has DCF ever been to your home, Department of Children and Family Services? A. Yeah. Q. On how many occasions? MR. HOROWITZ: Form. TILE WITNESS: I don't remember. I remember one time when I got out of my program. BY MR. CRITTON: Q. Which program had you gotten out of? A. Growing Together. Q. How many different programs have you been in for -- well, what would you have considered Growing Together, what kind of a program? A. It was a behavioral and drug program. Q. How many different programs have you been in? A. Q. A. A. Q. None. Just that one. Have you ever been in Yeah. We talked about that last time. That's when were you Baker Acted? Yeah. How long were you at Growing Together? Q. Have you ever been to Data? A. No. 3 MR. HOROWITZ: Asked and answered. 4 BY MR.'CRITTON: 5 Q. With regard to Growing Together, I think 6 you said you were in there a month or two. The 7 records reflect sometime in April of 2006. Tell me 8 how you came to be in Growing Together. 9 MR. HOROWITZ: Form. 10 THE WITNESS: I don't know. My mom 11 brought me there. 12 BY MR. CRITTON: 13 Q. Okay. Well, what did she tell you? 14 A. I don't remember. It was a doctor's 15 appointment or something. She tried to tell me 16 something dumb, and we went in there and they tried -- 17 and they locked me in. I was stuck there. 18 Q. Okay. As of 2006, you would have been 15 19 years old, right, April of 2006? 20 A. Yeah. 21 Q. And how did your mom get you to go there? 22 A. She told me we were going to like a doctor's 23 appointment or something, and I have never been to — it 24 was like in Riviera. I have never been out there so I 25 didn't know. We just walked in and they kept me there. Page 386 1 A. Like a month, month or two. !don't remember. 2 Q. And who put you into Growing Together? 3 A. My mom. 4 Q. Do you remember the time period you were 5 in there? 6 A. No. 7 Q. Okay. 11 I was to mention 2006, would 8 that meet approximately with your recollection? 9 A. I guess. I don't know. I know it was like 10 March or that's when 1 went in. It was like March. 11 Q. Did you know anyone else in the program at 12 the time? 13 A. No. 14 Q. And is Growing Together, I think you said 15 Growing Together has been the only program you have .16 ever been in, correct? 17 MR. HOROWITZ: Form. 18 THE WITNESS: Yeah. 19 BY MR. CRITTON: 20 Q. Did you ever go to Carp? 21 A. No. 22 MR. HOROWITZ: Asked and answered. 23 BY MR. CRITTON: 24 Q. Do you know what Carp is? 25 A. Yeah. 1 2 3 4 5 6 .7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 388 Q. Okay. And when you walked in, what happened? Tell me. A. Nothing. We went into this room and I sat there and they were like, well, you're staying here, your mom is not taking you. They started explaining to me. Q. Okay. And you say "they- how many people were there? A. Like two. Q. A man, woman? A. There was a man and a woman. Q. And at that particular time what behavior drug problems did you, were you having? MR. HOROWITZ: Form, form. THE WITNESS: I was on ME. BY MR. CRITTON: Q. Still smoking pot on a regular basis? A. Yeah. I guess that's why I went. Q. I'm sorry? A. I guess that's why they sent me there. Q. Well, l am asking.. A. I don't know. I don't sign myself up. Q. All right. Because you, probably if your mom had said I am taking you to a behavioral andfor, and a drug rehab lace, ou would have said no way? Want-, 1 1/4 44.i:44W .40 15 (Pages 385 to 388) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkIns (601-051.976.2934) Electronically signed by cynthia hopkIns (601-051.976.2934) Electronically signed by cynthia hopkIns (601-051-976-2934) 77a4b141-a193-40c1-9063-81f5a007a067 EFTA01076780 Page 389 1 A. No. Yeah. 2 Q. All right. So, when you got there, did 3 your mom pick up and leave right away or did she sit 4 through a couple of hours with you? 5 A. No, she left. 6 Q. So, she took you in. She introduced you 7 to the people. Sat you down in a room and said bye? 8 A. No. She — they sat me down in the room and 9 they closed the door in, like behind me. So, she 10 wouldn't be able I wouldn't be able to see her leave 11 or nothing like that. 12 I don't know what she did afterwards. She 13 might have went and talked to them. I don't !mow. 3.4 There was already people in the room waiting for me. 15 Q. And what did you have with you, just the 16 clothes that were on your back and your purse? 17 A. They brought my stuff already. They had, they 18 had it set up. 19 Q. Who is "they," your mom? 20 A. My mom and, yeah, the people. 21 Q. Who else other than your mom got you to 22 that place? Did you ever ask her afterwards? 23 A. No, it wasn't my dad because my dad got me 24 out. 25 Q. Your dad was the one that sprung you from Page 391 - 1 regular, no box strings Just mattresses, blanket and a 2 pillow and nothing in the room, no drawers, no lamps, no 3 nothing, and the door is locked behind us. 4 Q. Okay. Would that be every night? 5 A. Yep. 6 Q. Would you go to a different house every 7 night or would you be at a house for like a week at 8 a time? 9 A. Different house every day. 10 Q. Different house every day. Was it the 11 sante for, I assume you were with three other girls? 12 A. Two other girls including myself. 13 Q. Okay. So, there were three of you and you 14 would move from house to house for about seven or 15 eight weeks? 16 A. Well, they, yeah, they were still in there 17 when I let That's how the program works. 18 Q. And you sleep there at night? 19 A. Yes. 20 Q. And what do you do during the day? 21 A. We go back to the program. 22 Q. The program back in Riviera Beach? 23 A. Yes. 24 Q. Okay. And what time does the program 25 start, did the program start in the morning? Page 390 1 the place? 2 . Well, my dad went — he seen me in 3 and he told her that he, that I was not going 4 back over there. 5 Q. How, from — let me strike that. W s 6 in Growing Together before you got to 7 A. Yeah 8 Q. And you were in Growing T ether for a 9 month or two until you went to 10 A. Y front Going Together 1 went 11 straight to They brought me to 12 Q. At the time so during the month or two 13 that you were at Growing Together, tell me how were 14 you, what was the, what were your accommodations? 15 A. What do you mean accommodations? 16 Q. I'm song. Where did you stay? Was it 17 like a bunk-bed? 18 A. No. 19 Q. Did you have your own room? Was it like a 20 big room that had a bunch of beds in it? 21 A. No. They, we went to the parents like the 22 parents that put their kids in there, they volunteer 23 their homes and stuff like that. So, we would go to 24 different houses. They would have an empty room with 25 four beds, four beds, no mattress or mattresses —'rest Page 392 1 A. Well, we got up at like 5:30, 6:00. We had to 2 be there by 7 because some of the houses were like Port 3 St Lucie or Boca. They were, you know, kind of far. 4 Q. Okay. So, and who would transport you 5 back to the place? 6 A. The parents, the parents that we were staying 7 at their house at night 8 Q. And did you, were the, did you understand 9 the parents themselves had kids in the program but 10 were staying at other locations? 11 • A. Yes. 12 Q. And did you, did the parents feed you at 13 night? 14 A. Yeah. 15 Q. Okay. So, would they feed you in the 16 morning? 17 A. We, they would tell us there was cereal in the 18 cabinet. 19 Q. Okay. Sp, they'd get you up at 5:30. You 20 would eat and then they would transport you to 21 Riviera Beach and then you would stay there until 22 what time? 23 A. Sometimes 7, 8:00. 24 Q. And then you would be picked up again and 25 taken back to the next house? 16 (Pages 389 to 392) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hooking (601.051476.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkIns (601.051-976.2934) 77a41)(41-af9a-40o1-9063-81f5a007a067 EFTA01076781 Page 393 1 A. Yes. 2 Q. Did you over slay in the same house more 3 then once? 4 A. Yes. 5 Q. So, you might stay there for two or three 6 days or a week? 7 A. No. We would stay there once and then go 8 there maybe next or the week after and go back to the 9 same house. 10 Q. What was the idea of moving you from house 11 to house? 12 MR. HOROWITZ: Ram. 13 THE WITNESS: I don't know. 14 BY MR. DAMON: 15 Q. Did you ever ask? 16 A. No. 17 Q. Did the program, did they have you doing 18 things during the day or was it more of a lecture to 19 you? 20 A. Well, they would read us the AA book or the NA 21 book. We would go to school at 9. We would eat lunch, 22 go back to school, do some more reading or they would 23 sing songs or whatever and eat dinner. 24 Q. Okay. When you were at Growing Together 25 and you were 15 and a half probably at that time in Page 395 1 MR. HOROWITZ: Fonn. 2 THE WITNESS: Yes. 3 MR. CRITTON: Pm sorry? 4 THE WITNESS: Yes. 5 BY MR. CRMON: 6 Q. So, when you, when you were at Growing 7 Together, they were putting you in school but you 8 really didn't want to be there because you had 9 already dropped out of school? 10 . A. No, I had to go to school. 11 Q. That was part of the program? 12 A. Yes, 13 Q. Well, I understand that. But from your 14 choice, if you had had your choice, you wouldn't 15 have gone to school because you had previously 16 dropped out of school, right? 17 A. I 'Adult have nothing else to do. 18 Q. Becauseyou were trapped in the program? 19 A. Yes. 20 Q. All right. Did, did the program get you 21 off of whatever drugs you were on during that six or 22 seven weeks or eight weeks you were there? 23 A. I started using again afterwards but.. 24 Q. Were you able to get drugs during the time 25 you were there? Page 394 1 April of '06, because I think your birthday is in 2 September -- 3 A. Yes. 4 Q. — were you still in school at the time 5 before your mom put you there or had you left 6 school? Probably -- 7 A. I'm not really sure. Q. Well, if you were 16 or almost 16, at 15 9 you would have been past middle school, wouldn't 10 you? 11 A. No. I failed sixth grade. I failed seventh 12 grade. Yeah, I failed a lot, so... 13 Q. Is that because you didn't try? 14 A. No, I mean — 15 Q. Just didn't like school? 16 A. When I went to school lgot good grades but I 17 just didn't go. I got zeros. 18 Q. Got zeros. Okay. So, when you actually 19 went to school you got good grades, correct? 20 A. Yes. 21 Q. But you got zero's because you missed, 22 skipped so much school? 23 A. Yes. 24 Q. So, you were smart enough to do the work 25 but you 'tut choose not to do it? 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. No. Q. So, as soon as you got out of the program — and let's see you went from Growing Together and then you went to is that right/ A. Yeah. Q. Did you think the program helped you at all? A. No. Q. Let me show you what I will mark as -- MR. CRIITON: Do you know what exhibit? THE COURT REPORTER: This is the first one for this one. MR. CR1TfON: For today. I know that. MR. HOROWITZ: I'll look it up. MR. CROTON: Let's go off the record for a minute. THE VIDEOGRAPHER: Off the record at I I : 10 (Defendant's Exhibit No.4 was marked for identification.) (A discussion was held off the record.) THE VIDEOGRAPHER: We're back on at 1122. I i Page 396 PROSE COURT REPORTING AGENCY, 17 (Pages 393 to 396) INC. Electronically signed by cynthia hopkins (601-051.975.2934) Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthla hopkins (601481-976-2934) 77a4b141-319a4001-9063-8115a007a067 EFTA01076782 Page 397 1 BY MR. CRITTON: 2 Q. Ms. Doe No. 6, have you had a chance to 3 look at Exhibit No. 4? 4 A. Yes. 5 Q. It appears it be a letter that was written 6 by your mother November 29th, 2006, to Dear Sir 7 and/or Madam, someone at Growing Together. Do you 3 see that? 9 A. Yes, 10 Q. Have you ever seen this letter before? 11 A. No. 12 Q. Okay. The letter reflects that at least 13 based on what your mother said is that you were put 14 in, or she took you to — you were 15 years old, you 15 were a 15-year-old person, female at the time that 16 you went to Growing Together and you went in on 17 March 10th 2006. Does that meet with your 18 recollection? 19 A. Yeah. 20 Q. I'm sorry? 21 A. Yes. 22 Q. It says that at least your mother's 23 perspective was that you had a problem with use of' 24 drugs and your diagnosis with posttraumatic stress 25 disorder. Would you agree with that? 1 2 3 4 5 6 7 8 10 11 12 13 34 15 16 17 18 19 20 21 22 23 24 25 Page 399 therapists and programs, she didn't have a good grasp of what your problems were? A. No. Q. During the 2003, 2004, 2005, 2006 time period, what did you think your problems were A. Didn't think I had a problem. Q. Okay. A. That's what drug addicts do. Q. So, all you know is is that you didn't think you had any kind of problems, either behavioral or drug problem? A. No. Q. Correct? A. Yes. Q. You think your mom was a, I guess looking back now in hindsight, looking back in time, do you think your mom was a pretty good judge of what problems you were having? A. Yes. She knew 1 had a drug problem, yeah, and was out of control. Q. She also must have talked to you or you must have expressed to her well, let me ask it this way: Do you remember talking with your mom and expressing to her how upset you were back at that time about the automobile accident that at least Page 398 1 MR. HOROWITZ: Form 2 THE WITNESS: I guess. 3 MR HOROWITZ: Would you agree with her 4 characterization? s BY MR CRITTON: Q. Would you agree, no, would you agree with 7 your mother's characterization; that is, that you 8 had a drug problem and as well you had posttraumatic 9 stress disorder relating to the automobile accident? 10 MR HOROWITZ: Form 11 THE WITNESS: I agree I had a drug problem 12 yes. I don't know about that I — 13 BY MR. CRITTON: 14 . Q. Are you denying that you had posttraumatic 15 stem disorder at that time or you just don't loxwe? 16 A. I don't balmy. 17 . MR HOROWITZ: Form. 18 • ' THE WITNESS: I have never, you know — 19 BY MR. CRITTON: 20 Q. Do you think your mother had a pretty good 21 gmsplbackiirt 2004, '5, '6 of the problems that were 22 *acting you or had an inatmet on yma 23 A. If she did, she wouldn't have tried to take me 24 to so many therapists and programs. 25 Q. You think because she took you to so many Page 400 1 from your perspective and what you told us you 2 thought she might die? 3 A. Yeah. I had, !told her I had dreams about it 4 and stuff. But it says I had posttraumatic stress 5 disorder, you know. I never — they tried to diagnose 6 me with it. I was never... So I don't see how that 7 makes any sense. 8 Q. Do you know what posttraumatic stress 9 disorder is? 10 A. I lcnow what it is but I mean — 11 Q. What do you, what do you understand if I 12 use PTSD, posttraurnatic stress disorder, what did 13 you understand that is? 14 MR. HOROWITZ: Form. 15 THE WITNESS: That something traumatic is 16 affecting your life in some kind of way. 17 BY MR. CRITTON: 18 Q. And do you think that the automobile 19 accident was something that has traumatically 20 effected your life? 21 A. Yeah. But for her to say it like that, there 22 was never no diagnosis of saying that I was PTSD. All right Has anybody ever diagnosed you 24 with PTSD to your knowledg? 25 MR. HOROWITZ: Form. 18 (Pages 397 to 400) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051.976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) 77a4b141-af9a-40e1-9063-8115a007a067 EFTA01076783 9 10 11 12 13 14 15 16 17 18 19 20 21 22. 23 24 25 2 3 4 5 6 Q. Was that Mrs. a 7 A. No. 8 Q. Who was that? A. I don't know. I only went to her one time. Q. And who sent you to that person? A. My mom. Q. Do you know what the person's name was? A. No. Q. Do you know where it was; that is, where was the location? A. Palm Beach Gardens. Q. What time frame was it? Was it before or after she took to you Growing Together? A. I don't know. It was after the accident, Page 401 THE WITNESS: The therapist, the one I went to for one time said that she thinks I have posttraumatic stress disorder but how could she figure that out with one visit BY MR. CRITTON: Q. I think it was, the accident was in '03, correct? I'm sorry. It was in 2004. That was the accident up near 1-95. I am sorry, I-4. So, if it was in 2004, she would have taken you to see a psychiatrist or psychologist? Page 402 A. Yeah, I guess. 2 Q. Did you 'mow you were going to go see a 3 psychologist or psychiatrist at the time? 4 A. Yeah. 5 Q. Did you she tell you why you were going to 6 go see somebody? 7 A. About my dreams. 8 Q. Because you were having nightmares about 9 the automobile accident? 10 A. Yes, about driving. 11 Q. Were you even more afraid of being in a 12 car back during that time period, in the '04, '05 13 time period? 14 A. Yeah. I was afraid to drive. I was more 15 cautious- 16 Q. Well, you weren't driving then. You were 17 riding, correct? 18 A. Still the same thing. 19 Q. Same thing from your — okay. Exhibit 4, 20 your mom's letter goes on to say that she ot a call 21 day of your treatment from 22 that you had been Baker Act . you see 23 that? 24 MR. HOROWITZ:' I could help her with the 25 line. 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 3. 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 403 THE WITNESS: Yeah, I see it but — MR. HOROWITZ: Never, never mind. BY MR. CRITTON: Q. Were you Baker Acted into least from your perspective? In fact, e fact, this way: How did you get into A. Growing Together. Q. And what, what happened that moved you from Growing Together to A. I flipped out on themTetr. Q. Was it intentional to flip out; that is, were you really flipped out or did you pretend to be flipped out? A. No. I like snapped on them people. !just went off. Q. Okay. Had you snapped at am time up until — A Nope. Q. — that day? A No. Q. Were you getting along pretty well with most of the people at Growing Together? A. No. I wouldn't have snapped if I was getting a long with them. . Q. I'm only asking the question — Page 404 A. No. Q. — because I wasn't there. A No. Q. So, what happened at Growing Together, that is, you were now, at least by your mom's letter you had been there 26, 27, 28, 29 days at Growing Together, correct? Agin, if she's right. A. Yeah. Q. And had you been able to communicate with your mom or your dad or any family members during the time you were at Growing Together? A. No. Q. You didn't have access to a phone, correct? A. Yes. Q. Did you want to call your mom? A. Yeah. Q. Okay. Did you want to get out of that program? A. Yeah. I wanted to see my family. Q. Were you dating anyone at the time? A. I don't know. I don't think so. I don't remember. Q. So, what happened on the date that they took you, the date as you described you flip out; 19 (Pages 401 to 404) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (801-061.976.2934) Electronically signed by cynthia hopkins (601-061.976.2934) Electronically signed by cynthia hooking (601.061.976-2934) 77a41:441-idge-404,140634064007.067 EFTA01076784 Page 405 1 that is, what, what happened that day that made you . 2 flip out? 3 A. They took me to court and my family was there 4 and they wouldn't let me talk to them. They told me we 5 were going to the dentist because recently I just had a 6 tooth pulled like the week before. So, they were • 7 supposed to take me for another dentist appointment. 8 Well, instead of taking me to the dentist, 9 they started driving me downtown. And once we got 10 in the courtroom, they were like, oh, well we're 11 trying to see, they were trying to get me, I guess, 12 court ordered to stay in Growing Together, so... 13 Q. And you had no idea at that time that they 14 were going to do that? 15 A. No. 16 Q. Did you actually get into the courtroom? 17 A. Yeah. 18 Q. Okay. Did you flip out when you were in 19 the courtroom? 20 A. No. 21 Q. What happened in the courtroom, did they 22 talk about you in front of a judge? 23 A. Yes, yeah. 24 Q. Okay. And what did the judge decide? 25 A. I don't, I don't know. I don't remember. Page 407 1 Q. You just went through the motions? 2 .A. Yes. 3 • Q. What you had to do to survive? 4 A. Yeah. 5 Q. And Ms. Doe No. 6, when you got into 6 court, did they start talking about did you hear 7 them say we would like her to be court ordered for 8 another umpteen days? 9 A. I don't, I dorft remember what they said. I 10 . was not paying attention. 11 Q. But you, I thought you said that the whole 12 'preceding — 13 A. Yeah. 14 Q. — was about keeping you there? 15 A. No. There was a, there was a courtroom filled 16 with people, different people but they weren't talking 17 about me at a certain moment. 18. Q. Okay. And when they talked about you, did 19 you, if I understood you correctly they wanted to 20 keep you there? 21 A. • Yeah. I know that's what, when we pulled up 22 that's what they told me we were coming to court for. 23 Q. And what — 24 A. I didn't pay attention because I was watching 25 my mom. Page 406 1 Q. Was your family there? 2 A. Yeah. 3 Q. Did you get to wave to them? 4 A. No. I was not able to talk to nobody. I had 5 to stand in the corner. 6 Q. And not move at all? 7 A. Yeah. I wasn't allowed to talk to no officer, 8 nobody. 9. Q. Was there any other kids from Growing 10 Together or just you? 11 A. Just me and another girl that she had to, 12 like, watch me. 13 Q. She was, she was like the person who was 14 assigned to be with you that, from Growing Together? 15 A. Yes. Because she was on a higher step than 16 me, so she was supposed to watch me. 17 Q. Were you still at the bottom nue 18 A. Yeah. 19 Q. Had you made any progress in Growing 20 Together at all? 21 A. No. 22 Q. Okay. Were you fighting the program? 23 A. I just didn't like sing and like stand up in front of everybody, no. I just — I didn't fight them 25 but I just didn't like volunteer myself to do Page 408 20 (Pages 405 to 408) PROSE COURT' FIEPORTING AGENCY, • INC. Electronically signed by cynthia hopkIns (601-051476-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthla hopkIns (601-051-976-2934) 77a4h141-af9a-40e1-9063-81153007a067 1 Q. What did you say then? 2 A. Huh? 3 Q. What did you say when they said we want to 4 keep you? 5 A. What? When we got there? 6 Q. Before you got to the courtroom. 7 A. I told them they were crazy. 8 Q. Why, because you wanted to get out? 9 A. Yeah. I didn't want to stay in there. 10 Q. Did you thhik that you, your time was up 11 so to speak? 12 A. I don't know. I just, I wasn't going to stay 13 there for long. 14 Q. You wanted out of the program? 15 A. Yes. 16 Q. You wanted to get back home and do what 17 you were ever doing? 18 A. 'just, they — 19 Q. Go ahead, I'm sorry. 20 A. They kept me away from my family. I wanted to 21 be with my family. 22 Q. You wanted to get back to your family and 23 start doing drugs again, too? 24 A. I don't — J.know i wanted to be with my stuff. EFTA01076785 Page 409 Q When you did get out, though, you started 2 doing drugs again? 3 A. Not right away. 4 Q. How long? 5 A. It took mo like three months I was relapsed I 6 would say. 7 Q. So, you are in the courtroom. You hear 8. they want to keep you. Did you get to talk at all 9 or speak during the proceeding? 10 A. No. 11 Q. What did the judge order? 12 A. I don't know. 13 MR. HOROWITZ: Form. 14 THE WITNESS: That he obviously didn't 15 order nothing because I got out that day or a 16 couple of days later. 17 BY MR. CRITTON: 18 Q. Okay. You get, at what point did you flip 19 out? 20 A. When I, we got back. 21 Q. In the program in Riviera Beach? 22 A. Yeah. 23 Q. And what, what did you do that flipped you 24 out? 25 A. I told them I didn't know why they tried to do Page 411 1 because I know the cops because I was in the cafeteria 2 area in the front doors like over here. They were like 3 blocked of so I don't know if they heard me or — I 4 ath — I know I wasn't yelling at them when they got 5 there. 6 Q. At the police? 7 A. Yeah. 8 Q. So, when the police came, did you talk to 9 them? 10 A. No. They just put me in handcuffs and... 11 Q. Handcuffs behind your back, in front of 12 your back? 13 A. In front of my back 14 Q. In front of your back. Behind you; in 15 front of you? 16 A. In front of me. 17 Q. And then they took you to M' 18 A. Yeith. Ifs right across jttareet. 19 Q. Had you ever been to before? 20 A. No. 21 Q. So, they take you to M. Well, let 22 me, before I get off this, I want to get back to 23 your mother's letter for just a minute. Did you 24 understand that ou were being Baker Acted when you 25 went to Page 410 1 that. I don't know why they, like, tried to trick me 2 and say I was going somewhere else when I wasn't. They 3 should have just told me right then and there, we are 4 going to court and this is what we were doing. 5 Q. If they had said that, what would you have 6 said? A. I still would have went but I mean — Q. Would you have flipped out earlier? A. Probably. Q. Okay. So, when you say you flipped out, were you yelling, screaming at them? A. Yeah. I was just yelling at them. Q. Were you throwing anything? 7 8 10 11 12 13 14 A. No. 15 Q. Were you in any way physically violent? 16 A. No,Ijust-- 17 Q. You were just yelling and screaming? 18 A. Yeah. I was just flipping out. 19 Q. And what did they say to you? 20 A. They, they called the cops. 21 Q. So, the police actuall came? 22 A. They escorted me to 23 Q. And what did they tell you — were you 24 still screaming when the cops came? 25 A. I don't know. I was — I don't remember, 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 _2, -o. - Page 412 A. I heard it afterwards. That's what they told me. Q. Did you know what, did you know what a Backer Act was? A. No. Q. And now you get to, you get to And what do they do for you? A. They call my parents. They had me sit in a room. I watched TV for like the fast time in weeks. Q. Is that a good deal? A. It felt nice. Q. How long do you recall your how long do you recall, you recall you were at A. Three days, 72 hours they said. That's why I don't know where that April l0th thing comes from because we tried to return the day I got out of to get to, to get my stuff. Q. From. A. From Growing Together. Q. Okay. What stuff did they have? A. Like all my toiletries, like my toothbrush and my brush and stuff like that. Q. When you, when you went to a, you said you sat in a room for a few hours arid watched TV? II. 832-7500 PROSE COURT REPORTING AGENCY, 4 Cr el•.•••,a a 0.-A-ISIZSMSN 21. (Pages 409 to 412) INC. Electronically signed by cynthia hopkins (601.061.9763934) Electronically signed by cynthia hopkins (6O-051-976-2934) Electronically signed by cynthia hopkins (601-051.976.2934) 77a41041-al9a-400-9063-81150007a067 EFTA01076786 Page 413 Page 415 1 A. (Witness nods head.) 2 Q. Did anybody come in yes? 3 A. Yeah. 4 Q. Did anybody come in and talk to you? 5 A. Just the nurses like they, you know, take my 6 blood pressure, check my temperature, stuff like that. 7 Q. Okay. Did they have you sign a bunch of 8 forms or did your parents have to come in? 9 A. I had my — I know my parents had to come in 10 and sign paperwork. 11 Q. Okay. Do you remember signing forms too? 12 A. I don't, I don't know. 13 MR. CRITTON: Okay. Well, these are 14 records that were provided by your attorneys 15 and let me just, without, unless you want to 16 mark one. I have no real intention to mark the 17 whole exhibit. 18 MR. HOROWTTZ: It came from us. 19 MR. CRITTON: Yeah. No. It came from us. 20 It was sent to us and then you got copies. I'm 21 sorry, because it went to Jessica Cadwell. Let 22 me just show you one. This is a notice of 23 patient's rights and privile es. It's just a 24 document, and it's dated 25 can ask Mr. Horowitz to pass it to you. I j ust 1 A. Yeah. My mom and dad. 2 Q. What did they say to you? 3 A. My dad said I wasn't going back. My morn 4 always says, we'll see, well see. 5 Q. Had you, had your mom I know you said 6 your mom had taken you for a psychologist or 7 psychiatric visit up in the Gardens, you told us 8 that — 9 A. Yeah. 10 Q. — at some point because you were having 11 nightmares after the automobile accident in '04, 12 correct? 13 A. Yeah. 14 Q. Had you, had you — before Growing 15 Together, had you ever seen another psychiatrist or 16 psychologist for any reason or counselor? 17 A. I don't know. I know I seen another 18 psychiatrist on Southern and Military at the fire 19 station or whatever. I guess that's where her office 20 was. The fire department of, like the little fire 21 station there. 22 Q. Southern and what? 23 A. It's like a fire station. Its like the 24 Department of Fire Rescue or something. 25 Q. That's where her office was located? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 got into_? 17 18 19 20 21. 22 23 24 25 Page 414 want to see if that's your signature. THE WITNESS: Yeah. BY MR. CRITTON: Q. Okay. Did you recognize at least your signature on the document? A. Yeah. Q. That's alit want to know because then I will be able to identify the handwriting elsewhere. Did they have you sign other forms, too, that you can recall? A. I don't even remember signing that one. Q. Did your parents ever come and see you while you were in a? A. Yeah. Q. Were they able to see you the vety day you A. Yeah. Q. And what conversations did you have with your parents at that time? A. Told them I wasn't going back. Q. To Growing Together? A. Yeah. Q. Okay. And what did they say? What did you mom — who was it was, your mom and dad or just your mom? 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 416 A. Yeah. Off on Southern, off of Southern on Military. But I don't know when that was. Tat's the only psychiatrist I've seen other than the one that I told you the two about. Q. There was a lady name Susan Does that name mean anything to you? A. That's, that's not her. That's — she's one of the psychiatrists at the office that I was going to but the — Q. This, this lady is in—_ office is in the Gardens. A. Yeah. That's a different one. That was my probation officer. The lady that seen the physiatrist, that's her office is But the lady I seen er name was — Q• A. A. Yeah. No no no not Q. isalilliN0 — A. ../ A. Q. A. or something. something like that. Yeah, Okay. You did like her? Yeah. 22 (Pages 413 to 416) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601.061-976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) Electronically signed by cynthia hopkins (601-061.976.2934) 77a4b141-af9a-40e1-9063.81f5a007a067 EFTA01076787 Page 417 1 Q. And did you see her as part of your 2 probation? 3 A. Yes. 4 Q. That is part of your, the, I'd say the theft charge that you pled guilty to? O A. Yes. I thought I had the card. 7 Q. Other than, and I think you saw, I will 8 get to those visits, but you haven't seen her in a 9 number of years? 10 A. Since my son was born February of 200/3 is 11 the last time I seen her. 12 Q. That's the last time you saw her? 13 A. Yes. 14 Q. Was the, was she; thiljgaithen you saw 15 her ORS that is Ms. =Nand 16 Ms. == they both, at least in looking through 17 the records, they appear to both be involved with 18 the criminal justice situation. 19 A. I don't know. 20 Q. Okay. Was, did you -- when your mom took 21 you to see a psychologist ttp Beach Gardens, 22 was that di or you think 23 that was Msfille 24 A. No, that was different. 25 Q. But you don't remember that person's name? Page 418 1 A. No. 2 Q. Was that a male or a female? 3 A. That was a female. 4 Q. That was the one-time visit? 5 A. Yes. 6 Q. That was the, dealt with the nightmares? 7 A. Yes. 8 Q. Then there was another one that you saw at 9 Southern and Military. 10 A. Yea And I don't remember her name either. I 11 am not good with names. 12 Q. How many, how many times did you see that 13 person? 14 A. I saw her fora couple of weeks, like once a 15 week or something. 16 Q. For how long? 17 A. I don't really remember. It wasn't, it wasn't 18 like the last one. I went to her for like six months, 19 or eight months or something. It was only like two 20 months maybe. 21 Q. And did your mom take you there as well 22 for nightmares you were having relating to the 23 automobile accident? 24 A. I don't even know why we went there. I just 25 know we went. Page 419 1 Q. Do you know what point in time when that 2 was, Ms. Doe No. 6. Was that before she took you to 3 Growing Together? • 4 A. I don't remember what year it was. That's why 5 lam not good with — 6 Q. That's why I am not giving you a year or 7 not asking for a year. Do you remember whether it 8 was before she tSGrowing Together and then 9 you ended up at 10 A. I don't remember. 11 Q. One of the reasons I'm asking it that way 12 is because it looks like in at least from a, from a 13 time sequence, is the automobile accident happened 14 in 2004. The, in March of '06 you w in 'ng 15 Together. In April of '06 you were at 16 And then the criminal problems that you had from the 17 theft, that was in, it looks like it was in '07. 18 So, do you remember whether your mom took 19 you to see that psychologist at Military near the 20 fire station before Growing Together? 21 A. I don't remember. 22 Q. Okay. Do you remember why she took you 23 there? 24 A. No. Like I said, I just, I went along for the 25 ride. She just told me I had to go somewhere and -- 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 42C Q. Did your parents, did your parents come S ee you every day when you were at A. My mom came back every day to see me, yeah. Q. Did you your dad come back at all? A. No. He went the first day. He seen me. Q. And he wanted you out? A. Yeah. Q. And why did he want you out? MR. HOROWITZ: Form. BY MR. CRITTON: Q. Did he tell you? A. Reantse he didn't want me to go back to — because I told him I didn't want to go back to Growing Together. • Q. Did you understand that you had to spend 70, because • g Baker Acted, you had to be 72 hours at A. Yeah, that's why he didn't come back, because he knew I was going to comjakafter the 72 hours. Q. The reports from at least the records that I am looking at, it says reflect, it says reason for admit, patients own words, my thoughts of suicide, just thinking about cutting m elf. Do ou remember telli them at -- 23 (Pages 417 to 420) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (801-051-976-2934) Electronically signed by cynthia hopkIns (601.051.976.2934) Electronically signed by cynthia hopkIns (601.061.978.2934) 77a4b141-al9a-4001-9063,81f5a007a067 EFTA01076788 Page 421 Page 423 1 A. No 2 Q. - UM that? 3 A. No. 4 Q. Are you denying you said that? 5 A. No. I don't remember telling them that. 6 Q. It goes on to say, and again I am reading 7 from the record: I have had these thoughts at 8 Growing Together. told Growing Together 9 when she was using patient would have ' 10 thoughts and has cut her wrists specifically. 11 Had you cut your wrists before? 12 MR. HOROWITZ: Form. 13 THE WITNESS: Before, yeah. 14 BY MR. CRITTON: 15 Q.. And when you cut your wrists, where were 16 you at the time? 17 A. At home. 18 Q. How old were you at the time? 19 A. It was right before then I guess. I don't 20 really remember. I was high, I mean... 21 Q. All right. When you were high, what did 22 you cut your wrists with? 23 A. A razor, I guess. 24 Q. And do you, do you still have any scars 25 from that? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Tape 2. BY MR. CRITTON: Q. Ms. Doe No. 6, when you went to were you, ! don't want to say glad to be thalin ' were you glad to be out of Growing Together? A. Yeah. Q. And did you understand from at least talking with theumagad the psychiatrist and the people there at EM, they were trying to do an evaluation of you to determine whether or not they could let you go? A. I guess. Q. All right. And would it be a comet statement that you wanted to give them accurate information so they could give you a good evaluation? A. !don't know. They let me out in three days Q. Well, did you intentionally lie to those people when they asked you questions, or did you tell them the truth? A. I don't remember them asking me questions. Q. So, if— you don't remember any discussions that you had with those people? A. No. I remember like we had circles where we Page 422 1 A. Not really. 2 Q. They seem to have gone away? 3 A. Yeah. 4 Q. Did you cut both wrists? 5 A. No. 6 Q. Just your right wrist? 7 A. Just my right wrist. 8 Q. You have a band on right now. What's that 9 for? 10 A. It's my Twilight band. 11 Q. I'm song? 12 A. Twilight, New Moon. 13 Q. All right. les from the last Twilight 14 movie that came out? 15 A. Yes. 16 Q. And you were reading the Twilight books 17 when we came in today. Do you like the books as 18 well? 19 THE VIDEOGRAPHER: Mr. Critton, we need to 20 change the tape. 21 'MR. CRITION: Okay. 22 DEOGRAPHER Going off the record at 23 11:14 1. This is the end of tape one. 24. THE VID HER: We're back on the • 25 record at 11:58 . and this is the sten of 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 424 all, that everybody would talk but like, like, before I don't say nothing. 1 don't like voluntarily just like put my business out there. Q. Well, do you remember being evaluated by a psychiatrist and a psychologist at different times? A. I remember they came in the room and asked how them I was doing. Q. Do you remember meeting with a psychiatrist named or psychologist named Dr. A. That guy came one time and it was because they we trying to give me than, bipolar things. And he was trying to --1 only seen that guy one time. MR. HOROWITZ: Pardon me for interrupting. Jane Doe No. 6, just answer his question. BY MR. CRITTON: Q. Do &remember meeting with and speaking with Dr. A. Yes. Q. And do you remember him asking you a bunch of questions and you giving him a bunch of answers? A. Yeah, I guess. Q. And can I assume that if he asked you a questionyou gave him an honest answer? MR. HOROWITZ: Form. 24 (Pages 421 to 424) PROSE COURT REPORTING AGENCY, INC. (.1) 832-75O6 . Electronically signed by cynthia hopkIns (601.061.976.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkIns (601-061476-2034) 77646141-afea-40•141063441154007•067 EFTA01076789 Page 425 1 THE WITNESS: Yeah. 2 BY MR. CRITTON: 3 Q. He said, he talked about or at least the 4 history that you gave us just a little bit ago is 5 you remember that you cut your right twist. Is that 6 the only time that you have ever cut your wrist, or 7 have you cut yourself on more than one occasion? 8 A. No. I have only cut my — what do you mean by 9 only on one occasion? 10 Q. Well, you said — we know that you related 11 the history of at least an attempted suicide by 12 cutting your wrists; is that true? 13 A. Yes. 14 Q. Okay. And was it your intent at that time 15 to kill yourself/ 16 A. I guess, yeah. 17 Q. Okay. And who found you? 18 A. Nobody. I went to sleep in my iwdt, and my 19 arm was all bloody. 20 Q. Okay. You just don't remember doing IT? 21 A. Yeah, no. 22 Q. You said yeah, no. 23 A. No, I don't. 24 Q. All right 25 A. I don't remember. Page 427 1 Q. Do you remember that she took you there 2 because you had taken a weapon to school. Do you 3 remember taking a knife to school? 4 MR. HOROWITZ: Form. 5 THE WITNESS: Yeah. 6 BY MR. CRITTON: 7 Q. Okay. Why, why did you take a knife to 8 school? 9 A. I didn't They caught me skipping school with 10 a knife in my purse. Q. Were you on school property when they 12 caught you? A. No. 14 15 10 17 18 19 20 21 22 that, at the dine? 23 A. 24 Q. 25 that day? Q. Where were you? A. I was walking to Forest Hill and Military. Q. Who caught you? A. The school police. Q. Were you near school ground? A. I was a block or two away. I was at the next light. were you walking, what school was Had you been in school Page 426 1 Q. You woke up and your arm was bloody? 2 A. Yeah. 3 Q. Were you still bleeding at THE time? 4 A. No. 5 Q. So, you had cut your wrists. Was it both 6 wrists or just one? 7 A. Just one. 8 Q. And you had cut it and either passed out 9 or fallen asleep? 10 A. Yes. 11 Q. And you woke up and there was blood all 12 over? 13 A. Yes. 14 Q. But you had stopped bleeding? 15 A. Yes. 16 Q. Did you tell your mom? 17 A. Yeah. 18 Q. And what did she say? Did she freak out? 19 A. I don't — yeah, I guess. I don't remember. 20 Q. Okay. Your mother referenced that you 21 were seeing a psychiatrist or a therapist at the 22 corner of Gun Club and Military. Do you remember 23 that? Is that where you're telling me about near 24 the fireplace, fire station? 25 A. Yeah. It's in between Gun Club and Southern. Page 428 1 A. No. 2 Q. And you were walking away? 3 A. Yeah. 4 Q. Let's start again. Had you been in school 5 that 6 A. No. 7 Q. Were you intending to go to school that 8 day? 9 A. No. 10 Q. You were just out walking on a school day? 11 A. No. I got dropped off across the street at 12 the store My mom dropped me off at the store. And 13 then when she leaves. I walked away. 14 Q. So, that's when you decided to skip' 15 school? 16 A. Yes. 17 Q. Where were you going do you know? 18 A. I don't know. Me and this girl were just 19 walking to the bus stop. 20 Q. And you just jumped on the bus and go 21 wherever you were going? 22 A. I guess wherever she was going. 23 Q. And you had a knife in your purse. What 24 kind of knife? 25 A. 1 don't know. Just one of them little 25 (Pages 425 to 428) PROSE COURT-REPORTING AGENCY, INC. . Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (801-051-976-2934) Electronically signed by cynthia hopkins (801-051.976.2934) 77a4bf41-af9a-40o1-9063.81t6a007a067 EFTA01076790 Page 429 1 pull-out knives. The ones that just comes out. It was 2 just a little blade. It wasn't — 3 Q. And did the police, how did the police — 4 how did the school police see you? 5 MR. HOROWITZ: Form 6 THE WITNESS: I guess they seen me 7 walking. 8 BY MR. CRITTON: 9 Q. How would they know you were a student? 10 MR. HOROWITZ: Form. 11 THE WITNESS: Because I had my book bag on 12 . and my uniform on. 13 BY MR. CRIlli m 14 Q. Okay, required a uniform? 15 A. Yes. 16 Q. So your, your mom let you off at the 17 store. Mom takes off. You and your friend are 18 going to jump on the bus and take off? 19 A. Yes. 20 Q. School police see you because you have a 21 uniform and a book bag on? 22 A. Yeah. 23 Q. They come over, and do they look in your 24 book bag and your purse? 25 A. No. They asked me where am I going. I told 1 A. Maybe like a couple of days. 2 Q. And then you said that's it; I am done 3 with school? 4 A. No. I just didn't, I wasn't going to that 5 school. 6 Q. Okay. Did you ever go back to school 7 again after you got kicked out of 8 you got to sent ton correct? 9 A. Yes. 10 Q. Okay. .Did you go to a few days? 11 A. Yeah, a couple of days. 12 Q. Why didn't you lice it? 13 A. Because of the neighborhood and all the people 14 that were there. 15 Q. What were all the people that were them? 16 A. There was -- it was in the ghetto, around all 17 kinds of black people. 18 Q. Where? 19 A. All 'rinds of drug dealers. 20 Q. What? 21 A. On Tamarind and like 2nd Avenue or something. 22 That's where the school was. 23 Q. All rigid. Had you been in school with a 24 lot black kids before? 25 A. No. Page 430 them I was going home. I tried to make something up and they were like, well, we're going to take you back to 3 school. They brought me back to school and brought me 4 to the principal's office and searched my stuff 5 Q. And then searched your stuff? 6 A. Yes. Q. And then you had the knife and they called 8 the police? 9 A. I guess, yeah. 10 Q. And do you recall that was the reason you 11 had to go see the therapist? 12 MR. HOROWITZ: Form. 13 THE WITNESS: No. 1 didn't know that that 14 was why. 15 BY MR. CRITTON: 16 Q. What's School? 17 A. That's I got lacked out of 18 after all that 19 Q. Because of the knife incident? 20 A. Yea 21 Q. And so you were sent to 22 A. Yes. 23 Q. Did you skip school from wan 24 A. I told my mom I wasn't going to that school. 25 Q. Did you ever go? 1 2 3 4 5 6 7 8 9 10 tl 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 432 Q. All right. Was that something that you did not want to do? A. Yes. Q. Okay. Are you uncomfortable around black people? A. So, some of them. Q. And there were a bunch of drug dealers there too? A. Well, they stand at the cornet Q. Okay. Did you ever buy any drugs from them? A. No. Q. Because you were doing drugs at the time, weren't you? A. I was at a school though. Q. Well, so, you had to buy your drugs someplace, is different. I have to get, I have to take off my jacket or anything. They take a metal detector around my legs. I have to take off my shoes. I can only bring a pencil and a piece of paper or a folder with a piece of paper in it. Q. Okay. So, they do searches? A. Yes. IL•VLLTY. 26 (Pages 429 to 432) PROSE COURT REPORTING AGENCY, INC.' (M) 832-7506 Electronically signed by cynthia hopkins (601.051.975.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (501.091.976-2934) 77a4b141-09a-40e1-9063-81f5a007a067 EFTA01076791 Page 433 1 Q. In and out of the school? 2 A. Yes. And we walk in a line going to and from 3 class. . 4 Q. So, you went there a couple of days. Did you ever going k h I a in after that? o A. I went to to do Q. Okay. Right after or just later on? 9 10 11 12 13 14 15 Q. DuSwhat time period were you working 16 on your M.? 17 A. Lace 2008. 18 Q. And how far did you get? 19 A. I went a couple of months but -- 20 Q. How Isu lid it take, how long does it 21 take to get a M.? 22 A. It depends what, what, you know, what level 23 you are in and certain things. 24 Q. What level do you think you are in or were 25 you tested out at? A. Later on. Q. When did you obtain your =.? A. I haven't got it yet. Q. Still working on it? A. No, not right know now. I am working right now. 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 434 1 A. Well, I was really bad in language arts so I 2 need a lot of work there. And I was like at like a 3 seventh grade level in reading and a tenth grade level 4 in math. So I needed work in reading and language arts. 5 Q. Do you intend to finish that? o A. Soon. 7 Q. All right. Also, now back to the 8 records. The report also indicates that your 9 parents were divorced in June of '97. That was 10 true, but they were back living together; is that 11 correct? 12 A. Yeah. 13 Q. All right. And you started using in 14 2000? 15 A. No: 16 Q. When do you think you started using 17 A. I don't }mow, like 2004,2005. 18 Q. All right. You don't remember? 19 A. It wasn't 2000. I know it wasn't 2000. I 20 would have been ten. 21 Q. All right. You indicated to the doctor 22 that you had a stressful relationship with your 23 mother; is that true? 24 A. Yeah. We fight sometimes. 25 Q. Okay. And you had a difficult 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 PROSE COURT REPORTING Page 435 relationship with your father because you had told him that you were attracted to females, correct? A. Yeah. Q. Do you remember as well you told the doctor that you were molested by a random man in the neighborhood? A. No. What doctor did i tell that to? A. No. Q. Okay. He touched you over the top of your clothes in private areas and then he ran away and that's why you brought the knife to school to protect yourself. Do you remember telling him that? A. No. Q. Okay. Well, he couldn't have made it up. So, where else -- was there anyone else in the room with you at the time that the questions were asked about your history? MR. HOROWITZ: Form THE WITNESS: I don't, I don't even remember those questions. BY MR. CRITTON: Q. So, if the doctor's report says the history of abuse and you say patient shared that she was molested by a random man in the neighborhood. Page 436 He touched her over the top of her clothes in private areas. Patient, you, ran away, and this is when she brought a knife with her for protection and it was found on her at school. Do you recall that occurring? A. No. Q. Are you saying that the doctor made that up? MR. HOROWITZ: Form. THE WITNESS: No. I Just, I don't know where that whole paper came from. BY MR. CRITTON: Q. Well, it is true because you -- well, let me strike that. Isn't it nue that a random man in the neighborhood, in fact, molested you and touched you in private areas? A. No. The same thing with I don't know bow they said I was cutting myself hersince I wasn't doing that. Q. Do you ever recall telling the doctor that "'sere oing to go to Carp after you left A. No. sai d you think at the time that you entered that you were both depressed and suicidal? A. 1 was depressed. 27 (Pages 433 to 436) AGENCY, INC. Electronically signed by cynthia hopkins (801-051-978-2934) Electronically signed by cynthia hopkins (601-051-978-2934) Electronically signed by cynthia hopkins (601-051-978-2934) 77a4bf41-a19a-40o1.9063.8115a007a067 EFTA01076792 8 10 11 12 13 14 15 16 17 18 19 20 21' 22 23 24 25 Page 437 Q. Did you consider yourself suicidal? A- No. Q. Do you remember, well, let me strike that. Did you ever cut your legs? A. No. O. Prior to April, your admission to A. No. Q. If you have scars on your leg the upper portion of the thigh of either your left or right le& do you know what those scars are from? A. I don't have any scars. Q. When were you discharged from Were you discharged with any medication? A. No. Q. Okay. Were ot sk aced on any medication when you were in A.. No, I don't think so. Q. Do ou remember meeting with a social worker at A. No. Q. Would it be a correct statement Ms. Doe No. 6 you told individuals at that you were sad as a result of the car accident in September of '04 where you thought your mother was dead, do you 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 nor to Growing Together that you had ever been touched in any inappropriate way by Mr. Epstein, did you? A. I never told them I was molested by anyone. Q. You may not have but at least their records, I am just representing to you that their records reflect what you said with regard to the random man molesting you in your neighborhood which you now deny, correct? A. Their records also say1 was cutting myself. Q. Well, you told — MR. HOROWITZ: Just answer his question. THE WITNESS: No. That's, l guess that's what they say I guess, I don't — BY MR. CIIITTON: Q. But you did cut yourself because you -- A. Before. Q. — you pointed to your — let me finish, you did cut yourself because you pointed to your left wrist where you were cut, correct? A. Yes, before. Q. Before? A. Before and Growing Together I was cutting myself. Q. Right. And that's what their records Page 438 remember telling them that? 2 A. No. I have told everybody that that — I 3 don't, I thought my mom was, I was going to lose my mom. 4 Q. Do you remember after the automobile 5 accident you started using ='? 6 A. I guess. I mean, like said, I don't know when 7 1 started. (1.31 ice . In another report other than 9 Dr. there is, she also admits to being 10 molested by a random man in her neighborhood where 11 he touched her on the top of her clothes and she ran 12 away. She then was carrying a knife and she got 13 caught with the knife at school. Do you remember 14 that, saying that to someone? 15 A. Where they, no. I don't remember that's what 16 1 am saying. They must have been in the same room 17 because I didn't talk to, I only talk to people in that, 18 in that circle. 19 Q. Are you now denying that you were molested 20 by a man in your neighborhood? 21 A. No. I am saying it didn't happen. 22 Q. All right. So, you're saying that you 23 were never molested by anyone? 24 A. In my neighborhood, no. 25 Q. All right. Well, you never mentioned to 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 440 said. It's a history of having done that. History means it happened in the past. Do you understand that? A. Yeah. Q. All right. So, they weren't saying at Growing Together you were cutting yourself or that you had just done it, but that you had done it previously. Okay? A. They also said that I was suicidal and that's why I was sent there, and that's not why. Even in this letter says that they don't know why I was sent. Q. Your mother's letter, Exhibit 4? A. Yeah. She was never told why I was there so how would they say and how would I be seen by a bunch of people when I have to be seen when my mom was there. Right? Q. Now, Ms. and Ms. you believe you saw through as a result through the correctional department? A. Yes Q. As a result of the theft charge? A. Yes, burglary. Q. Burglary. That was a felony to which you pled guilty? A. Yes. 28 (Pages 437 to 440) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkIns (601-061-978-2934) Electronically signed by cynthia hopkins (601.051-976-2934) Electronically signed by cynthia hopkins (601.061.976.2934) 77a41441-M9a400-9063-81f6a007a067 EFTA01076793 Page 441 1 ou ever mention to Ms. or 2 Ms. — well, let me strike that. 3 What waste, what did yau4srstand the 4 f bewaseenbyMs. and 5 Ms. was? 6 A. It was part of my probation. Q. It was required? 8 A. Yes. 9 Q. And as part of your probation what did you 10 understand that they were supposed to do for you? 11 A. I don't know. I know it was something I had 12 to do, or I was going to be violated. 13 Q. What did they talk to you about? 14 A. We talked about beings — I was pregnant at 15 the time she talked about being a new mom. 16 Q. Did she ever ask about your history? 17 A. Yeah, we might have. 18 Q. Did you ever talk to her about the car 19 accident? 20 A. Yeah. 21 Q. Okay. Did you talk to her about having — 22 well, let me strike that. Did you talk to her about 23 your criminal charge? 24 A. Yes: 25 Q. Did she, did you talk to her about having Page 443 1 her but I didn't hang out with her anymore, no. 2 Q. And up until the time that the lawsuit was 3 filed by your attorneys seeking millions of dollars 4 in damage from Mr. Epstein, you had never seen a 5 psychologist, a psychiatrist, or a therapist for any • 6 reason, true, relating to Mr. Epstein? 7 A. What? 8 Q. Up until the time that you filed the 9 lawsuit against Mr. Epstein seeking millions of 10 dollars, you had never seen a psychologist, a 11 psychiatrist, a therapist, or a doctor for any 12 reason relating to Mr. Epstein; is that correct? 13 MR. HOROWITZ: Porn). 14 THE WITNESS: No. 15 BY MR. CRITTON: 16 Q. That's not correct or that's correct? 17 A. No. That's correct, yeah. 18 Q. AU right And since you filed the 19 lawsuit, the only person or therapist that you've 20 talked to, well, really — let me strike that 21 Since you filed the lawsuit, the only individuals 22 wh ve seen that are psychiatrists would be ' 23 Dr. whom you were sent to by your attorneys, • 24 and Dr. who did an evaluation of you by me, 25 correct? 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 442 brought a knife to school? A. I don't know. Maybe, I guess. Q. Okay. Did you talk to her about the man who molested you in the neighborhood? A. No, because it didn't happen. Q. Is there any reason — well, let me strike that Did you talk to her about your allegations that you went to Mr. Epstein's house? A. No. Q. Until you, until you were contacted by the FBI, the only person who purportedly would have known that you were at Mr. Epstein's house would havelr horn? A. M. who I went with. MR. HOROWITZ: You mean besides Epstein? . MR. ORMI0N: I am talking about someone you knew. M. would have been the only • person? THE WITNESS: She went with me, yes. BY MR. aarroN: And I think you told me last time you and were not friends after that; that is, you had wry little dealings with her after that period of time? A. Yeah. I didn't real! -- I talked -- I seen 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 444 A. Yeah. Q. And at no time during yolibilait Together at the time you were at at the time that you were seen by any other therapist or psychologist or psychiatrist, did you ever mention that Mr., that anything had occurred in inappropriately when you were at Mr. Epstein's house, true? MR. HOROWITZ: Form. THE WITNESS: I never told none of them people that I was molested in any way. That's why I don't go to psychiatrists now, because you see I have done been to like five. That's why I am not — so, I don't go. tam grown now. I don't have to I don't need somebody telling me that I need to go see a counselor. BY MR. CRITFON: Q. Okay. And you have no intention of seeing a counselor in the firture, do you? ' A. I don't — probably not. ' MR. CRiTTON: I have no other questions. Thank you. • MR. HOROWITZ: That's it. EOGRAPHER: Off the record at 12:13 This is attend of 2 and the 29 (Pages 441 to 444) PROSE COURT REPORTING AGENCY, INC. (M) Electronically signed by cynthia hooking (601.05140764934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia bodkins (601.061-976.2934) 77a41O41 -alga -40o1 -9063-81f5a007a067 EFTA01076794 Page 445 Page 447 1 2 3 end of the deposition. (Witness excused.) (Deposition was concluded.) CERTIFICATE OF OATH THE STATE OF FLORIDA 7 COUNTY OF PALM BEACH 8 9 10 11 12 13 14 15 16 17 18 19 20 I, the undersigned authority, certify that JANE DOE NO. 6 personally appeared before me and was duly swum on the 6th day of February, 2010. Dated this 20th day of April, 2010. 4 4$ Cynthia Hopkins, RPR, FPR 21 Notary Public - State of Florida My Commission Expires: February 25, 2011 22 My Commission No.: DD 643788 23 24 25 I DATE Apnl 20* 20/0 2 TO Ms lane Dot 15\s 6 do ADAM 0 HOROWITZ. SSP= 3 AILIAGSLSTEIN l HOROWIT2-.M. 181O5 Biceps %stewed 4 891•211S Mani. Norsk 33160 5 4 IN RR Jae Doe No.1 ss Epstein CASE NO: 084:19-80/1911ARRAM41515(94 Flow ais naiad* as Wobatclay, Cc Oh 8 of Panty. 2010, ycn your 6:299677 in the abose-orgniad wan« Al the t tent, psi, ed not 9 vinne signe....e. n now xcesse7 that sou sign yen- *position. 10 A, .i-evxcaly %tad to. the Israciipt well be fuirinlicd lo you tIscugh yams 904444 [lessen:al 11 the tithe untnctions carefidly Al the eAl age uansorsn so:* will fed an 22 era shed As ma reedyour depssiticn My chinas of C0110CIMIlkil Walh to apt dwell 13 be cc the ergs cassg sew sof line "'other of bed Chine DO NOT nein oft the 14 tennis as& Oise son Miro sceJ die usescript ad noted esy down be new sign 15 mad dote disown SS and mu, limn mesas a. 16 Egon Isnot sanitssd sip the deposition Mail • nem& Reg Os wig:94 aide has 17 okay Ice fonserdetl to te eaten% ettestay. cry bland with the CMOS* Court If goo Aids IS a wan. year Sat" 1gri groannte Maw bask tbe balm of tkis delta IS as 19 20 21 Von IMY 301a. Arli escfr_C4310 AS CYaha Hogkis. Rpft FPR 22 23 1 do ?webs wain as signing°. 24 23 JANE DOO NO.4 1 CERTIFICATE 2 THE STATE OP FLORIDA 3 COUNTY OF PAU4 BEACH 4 5 1, Cynthia liopkiin, Registered Professional Reporter, Florida Professional Reponer and Notary 6 Public in and for the State of Florida al large, do hereby certify that I was authorized to and did 7 report said deposition in stamtype; and that the foregoing pogo are a hue and correct transenplon 3 of my shorthand no of said deposition. I (Inter cat$' that said deposition was taken at the the and place hercir.above set forth lo and (WA the taking of said deposition was COITIMaKed and conthleted as hereinatove set out I further catty that tam not attorney or 12 counsel of any of the patties, nor am I a relative or employee of any attorney or counsel of party 13 connected with the action, nor ton I financially interested in the action. t1 14 The foregoing certification of this transact 15 does not apply to any reproduction of the saute by any means unkss under the direct control mita 16 direction of the eernfying reports/ 17 Dated this 1O111 day of Apt '1,2010 18 19 20 21 22 23 24 25 in tiop a 4S ek 1115 Page 446 Page 448 1 CERTIFICATE 2 3 THE STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 I hereby certify that I have read the foregoing 6 deposition by me given, and that the statements 7 contained herein are true and correct to the best of 8 my knowledge and belief, with the exception of any 9 corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2009. 14 15 16 17 18 19 JANE DOE NO. 6 20 21 22 23 24 25 30 (Pages 445 to 448) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051.976-2934) 77a4h141-af9a-40e1-9063.81f6a007a067 EFTA01076795 Page 449 1 ERRATA SHEET 2 IN RE: JANE DOE NO. 2 VS. EPSTEIN CR: Cynthia Hopkins, RPR, Fit 3 1DEPOSMON OF: JANE DOE NO. 6 TAKEN: April 6,2010 4 5 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE 6 UNIT II CHANGE REASON 6 7 9 10 11 12 13 14 15 16 17 Please foment the original signed crate sheet to this office so that copies may be distributed to all 16 parties. 19 Under penalty of perjuryjdedatt that I have read my deposition and that it is cue and comet 20 subject to any changes in foam or substance entered Inc. 21 22 DATE: 23 24 SIGNATURE OP DEPONENT: 25 .• ./..elaa•faealet 31 (Page 449) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthis hopkins (601.061476-2934) Electronically signed by cyntMa hopkins (601-061-976-2934) Electronically signed by cynthla hope's; (601.061.976-2934) 77a4b1.41-af9a-40o1-9063-81f6a0078067 EFTA01076796