UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. / 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, / DEPOSITION OF JANE DOE #7 - VOLUME II (videotaped) Monday, March 15, 2010 10:02 - 6:49 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RMR, CRR Notary Public, State of Florida (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107831 EFTA01107832 Page 127 Page• 1 APPEARANCES: 2 On behalf of the Plaintiffs in related cases Nos 08-80069, 08-80119, 08-80232, 08-80384 3 08-80381, 03-80993, 08-80994: 4 ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 5 18205 Biscayne Boukvad Suite 2218 6 Miami, Florida 33160 Telephone: 305/931.2200 7 8 On behalf of the Defendant Jeffrey Epstein: 9 ROBERT D. CRITTON. JR, ESQUIRE BURMAN, CRl11UN, LUTHER& COLEMAN 10 303 Banyan Boulevard Suite 400 11 West Palm Beach, Florida 33401 Telephone: 561/842-2820 12 13 14 Also Present: Sasha Quimby, videographer 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROCEEDINGS THE VIDEOGRAPHER: We're back on the record at 12:19 p.m. This is marks the beginning of tape 2. BY MR. CRITTON: Q. When you took F.E. to Mr. Epstein's, 1 think you said she asked you to take her. A. Yes. She knew about It and she asked me, she said she wanted to go. Q. Okay. Did you say, and did you tell her "No, I don't think you should go'? A. No. I never said that. Q. Did you take her so you could make money' First of all, let me ask you this. Did you make money from taking F.E. to Mr. Epstein's home? A. Yes. Q. How much? A. 200. Q. Okay. And when F.E. came down, did she give Mr. Epstein a massage? A. Yes. Q. Did she ever say anything inappropriate happened during the course of the massage? A. No. Q. And you took ■ and she came, did she give 1 2 3 4 5 6 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 128 - - - INDEX WITNESS: DIRECT CROSS REDIRECT RECROSS Jane Doe N7 By Mr. Critton 5 EXHIBITS EXHIBIT Defendants 1 Defendants 2 Defendant's 3 Defendant's 4 Defendant's 5 Defendant's 6 Defendant's 7 Defendants 8 Defendant's 9 PAGE 233 233 233 263 268 274 280 294 301 Page 130 1 Mr. Epstein a massage? 2 A. Yes. 3 Q. Did she ever tell you anything inappropriate 4 had happened? A. We never really talked about it. 6 Q. Did you ask them? A. No. 8 Q. If you talk someone to Mr. Epstein's home to 9 have them give him a massage so they could earn money 10 and you could earn money, did you interpret what you 11. were doing was the same thing in essence that M. was 12 doing? 13 MR. HOROWITZ; Form. 14 THE WITNESS: No. 15 BY MR CRITTON: 16 Q. Why was it different, in your mind? 17 A. Because they wanted to go, and we were all 18 just kind of brainwashed by him. And at the time I knew 19 it was wrong, but I didn't know how it would affect them 20 or affect me in the fixture. And I was just confused by 21 everything at that time. 22 Q. You knew it was wrong, so what's confusing 23 about that? 24 A. I felt like it was wrong, but I, I just 25 thought it was -- I was just confused, and I just didn't •t ree=aa 2 (Pages 127 to 130) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107833 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 131 know how much it would affect me in the future and, you know, what kind of effects it would have on them. And, you know, that's why I feel bad about it now, but at the time I was confused and I didn't know. Q. Wellj _ let me ask you this. Have you ever talked with El about her experience with Mr. Epstein, ever? A. No. She is in now. I don't know, we don't really talk. Q. What's she doing in now? A. She lives there now with her sister. Q. IIII? A. Yeah. Q. Is her mom ? A. Yes. Q. Herded? A. Yes. Q. So they are all a. Why did they go back to a, if you know? A. Because their green card etd. Q. Let me ask you again. Did ever tell you anything bad happened at Mr. Epstein's, or inappropriate? A. I don't remember. Q. So at least — did you only take her the one Page 133 1 Q. But at least as you sit here today, you can't 2 remember anything unusual about her coming down from 3 giving Mr. Epstein a massage; would that be a fair 4 statement? 5 A. I mean yeah, I don't remember. 6 Q. Same thing with F.E., you don't remember 7 anything that stands out in your mind when she came 8 downstairs because you were in the kitchen, right? 9 A. Yeah. 10 Q. Do you remember anything unusual or did she 11 say anything or did she react or have any appearance — 12 strike that. 13 Did F.E. either say anything that caused you 14 any concern or did you observe any facial features or 15 anything that she did or the way she acted that would 16 have caused you any concern that you can remember today? 17 A. Not that I can remember. 18 Q. Those are the only two people you ever took to 19 Mr. Epstein's? 20 A. Yes. 21 Q. You went down and had an interview or an 22 evaluation by Dr. Kliman, who was the psychiatrist who 23 had been hired from San Francisco to evaluate his 24 clients, including you, correct? 25 A. Yes. Page 132 1 time? 2 A. Yes. 3 Q. Do you know whether she ever went another 4 time? 5 A. I don't know. 6 Q. All right. But when she came down from giving 7 Mr. Epstein a massage, she seemed to be in good spirits, 8 didn't say anything bad had happened; fair? 9 A. She didn't really talk about it. 10 Q. Did she appear to be upset in any way? 11 A. I don't, I don't remember. 12 Q. If she had been upset, that's something you 13 generally would remember, wouldn't you, if she was upset 14 or emotional about it? 15 A. It was so long ago, I just remember taking her 16 there. I don't remember how she reacted or what 17 happened. 18 Q. Did you drive her in your car? You were the 19 transporter? 20 A. I don't remember. 21 Q. Was El able to drive at the time? 22 A. Yes. 23 Q. But you went with her, so either she drove or 24 you drove? 25 A. Yes. Page 1 1. Q. And you had to fly down from Orlando, true? 2 A. Yes. 3 Q. Do you remember telling Jane Doe 4 about your 4 eicpadence for the evaluation with Dr. Kliman? 5 A. Yes. 6 Q. And do you remember telling her that you were 7 supposed to cry a lot and be very emotional during the 8 course of the — 9 A. No, I never — 10 Q. I need to finish the question, ma'am. 11 isn't it true you told Jane Doe 4 that you 12 cried a lot during the interview and tried to be very 13 emotional, because that's what you were supposed to do? 14 A. No. 15 Q. So if you told Jane Doe 4 that, or 'Ilene 16 Doe 4 has said that to anyone, that would be a lie? 17 A. Yes. 18 MR. HOROWITZ: Form. 19 BY MR. CRITTON: 20 Q. If I use the term crocodile tear, does that 21 mean anything to you? Do you know what a crocodile tear 22 is? 23 A. Yes. 24 Q. What is It? 25 A. When somebody fake cries. (561) 832-7500 3 (Pages 131 to 134) PROSE COURT REPORTING AGENCY, INC. (561). 832-7506 EFTA01107834 Page 135 1 Q. Let me go back to when Jane Doe 4 was living 2 with you this last summer, or I'm sorry, the summer of 3 '08 and she told you that she had filed a suit against 4 Mr. Epstein. 5 As of that date, were you aware of anyone else 6 who had filed suits against Mr. Epstein? 7 A. No. 8 Q. As you sit here today, other than yourself and 9 Jane Doe 4, are you aware of any other plaintiffs or 10 individuals who are plaintiffs in lawsuits against 11 Mr. Epstein? 12 A. Yes. 13 Q Who? 14 A. Jane Doe 3. 15 Q. Flow do you know is a plaintiff in a 16 lawsuit? 17 A. Because she is my friend and she told me. 18 Q. And that's Jane Doe 3? 19 A. Yes. 20 Q. Were you aware or has Jane Doe 3 told you 21 whether she has given a deposition? 22 A. Yes. 23 Q. Okay. What did she say about it? 24 A. She said that you looked exactly like Jeffrey 25 Epstein. Page 137 1 Mr. Epstein's home? 2 A. No. 3 Q. Did she ever talk to you about what occurred 4 or what she alleges occurred at Mr. Epstein's home? 5 A. No. 6 Q. All right. Are you aware of anyone else other 7 than Jane Doe 3 and Jane Doe 4 who are plaintiffs? 8 A. Just N.R. 9 . And who is she? Again, a student at 10 with you all? 11 A. Yes 12 Q. Same grade? 13 A. She's a grade ahead of me. 14 Q. And did she tell you that she's a plaintiff in 15 a lawsuit? 16 A. No, we were just talking about it and somehow 17 she found out that I had a lawsuit and was asking me 18 about it and she said that she had one, and that's all. 19 Q. Did she tell you who her lawyer was? 20 A. No. 21. Q. Did she — when did you last talk to N.R. — 22 let me start again. 23 When did you have this conversation with N.R. 24 about the lawsuit? 25 A. I believe it was over Christmas break, I Page 136 1 Q. Did she tell you how nice and polite I was and 2 reasonable? 3 A. Yes. 4 Q. Good. 5 MR. HOROWITZ: She did? 6 THE WITNESS: No. 7 BY MR. CRITTON: 8 Q. I'm taking that as the truth. 9 A. That's a joke. 10 Q. All right. You don't think I look like 11 Mr. Epstein, do you? 12 A. Yes, kind of. 13 Q. I think that's just, l think that's the big 14 pitch, so you all can make that pitch at trial. It's a 15 nice touch, but I'm not moved by it. 16 MR. HOROWITZ: Mow to strike. 17 BY MR. CRITION: 18 Q. What else did Jane Doe 3 tell you about her 19 deposition? 20 A. She didn't really tell me anything about it. 21 She just basically said she came in here and did it. 22 Q. Were you aware that she had been at 23 Mr. Epstein's home during the time she was going? 24 A. I don't remember. 25 Q. Do you know how she came to be at 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 138 think. Q. Christmas — A. I don't know, I was home like on break I don't know if it was Christmas break or not. Q. Well - A. I was just, like I come home a lot to visit my parents. Q. Are you still in school right now? A. Yes. Q. So when was the last time you were home, Christmas before now? A. No, I came home recently to visit them, like last month. Q Was that when you talked to N.R.? A. I think so. Q. So it would have been approximately February of 2010? A. Yes. Q. And was she at your house or did you see her at a bar or were you out at a club or — A. I forget where I saw her. I ran into her -- oh, we were at Duffy's. We all went -- Q. Which Duffy's? A. to dinner. On Northlake. Q. RIM near I-95? (561) 832-7500 PROSE COURT 4 (Pages 135 to 138) REPORTING AGENCY, INC. (561) 832-7506 EFTA01107835 Page 139 Page 141 1 A. Yes. 2 Q. Who was there other than you and N.R.? 3 A. Just some friends from high school. 4 Q. Any other people that you know? Was Jane 5 Doe 4 there? 6 A. No, Jane Doe 4 wasn't there. 7 Q. Jane Doe 3, was she there? A. No. 9 Q. Anyone else that you know, any of the other 10 people you knew went to Mr. Epstein's home? 11 A. No. 12 Q. And N.R. said that she was going to file or 13 she was a plaintiff also in a lawsuit? 14 A. Yes. 15 Q. How did she know that you were a plaintiff? 16 A. I don't know who told hen 17 Q. Were you upset that she knew? 18 A. I mean she was one of my good friends in high 19 school and she kind of knew what happened, because I 20 told her before. So I, she kind of already knew, so I 21 wasn't that upset that she knew about that. 22 Q. What do you mean you told her about? 23 A. I mean she knew about me and Jane Doe 4 going 24 there. She went there before, so — 25 Q. Oh, she had gone there before you? 1 A. Well, yeah. She — yeah. 2 Q. Okay. How does she know? 3 A. Because you guys asked her questions about me, 4 and Pm sure she assumed I was a plaintiff suing 5 Jeffrey. 6 Q. How about your friend El does she know that 7 you have brought a lawsuit? 8 MR. HOROWITZ: Form. 9 THE WITNESS: I'm sure E. told her. 10 BY MR. CRITTON: 11 Q. Why would.. tell her? 12 MR. HOROWITZ: Fenn. 13 THE WITNESS: Because they are friends. 14 BY MR. CRITTON: 15 Q. How do you know El Fuld N. are friends? 16 A. Because that's what I have heard. 17 Q. When is the last time you talked to 18 A. Right around her brother's accident. 19 Q. Okay. 20 A. So probably, I don't know, like seven months 21 ago. 22 Q. That's the last time you have spoken with her? 23 A. Yes. 24 Q. Have you tried to call her or she tried to 25 contact you at all? Page 140 1 A. No. I don't, I don't remember when she had 2 gone. She went sometime in high school. 3 Q. Did she ever tell you about her experience of 4 going to Mr. Epstein's home? A. No. I just !mew she went. 6 Q. Do you know how many times she went? A. No. 8 Q. Did you say "Why are you filing a lawsuit? 9 A. No. 10 Q. So you don't know whether she has — strike 11 that. 12 You don't know anything about her lawsuit 13 other than she has filed a lawsuit against Mr. Epstein? 14 A. Yes. 15 Q. So you mentioned N.R., Jane Doe 3, Jane Doe 4. 16 Anyone else that you are aware that was a 17 plaintiff'? 18 A. No. 19 Q. Who have you told that you area plaintiff in 20 a lawsuit? 21 A. Just those girls. 22 Q. So nobody else knows that you are a plaintiff? 23 A. No. 24 Q. How about il.? Does know you are a 25 plaintiff? Page 142 1 A. Not recently. I don't think so. 2 Q. After you said — around the time of her 3 brother's accident, since that time, have you tried to 4 call her at all? Or seven months ago was the last time 5 you had any contact with her? 6 A. Yeah. 7 Q. Okay. At the time that Jane Doe 4 told you 8 that in the summer of '08 that she was bringing a 9 lawsuit against Mr. Epstein or had brought a lawsuit 10 against Mr. Epstein, had you contacted an attorney at 11 that point? 12 A. I don't remember. 13 Q. Affright. Who was the first — strike that. 14 Was it you or your parents who encouraged you 15 to bring a lawsuit? 16 MR. HOROWITZ: Form. 17 THE WITNESS: It was me. 18 BY MR. CANTON: 19 Q. So your parents had nothing to do with you 20 bringing a lawsuit? 21 A. No. 22 Q. Are your parents aware now, were they aware at 23 the time you hired a lawyer? 24 A. Yes, I told them. 25 Q. Did you hire a lawyer before you told your (561) 832-7500 5 (Pages 139 to 142) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107836 Page 143 1 parents or were they involved in the decision? 2 A. No, I told than after. 3 Q. And who did you contact — strike that. 4 How did you — you know obviously Mr. Horowitz is seated immediately to your left, tweet? 6 A. Yes. 7 Q. Is he the fast lawyer you met from that firm? 3 A. No. I met with Jeffrey Herman. 9 Q. How did you get in contact with Mr. Herman? 10 A. He called me. 11 Q. He called you? 12 A. Yes. 13 Q. And where did he call you from? 14 A. I don't know. 15 Q. Was it before or after Jane Doe 4 told you 16 that she was a plaintiff in a lawsuit? 1'7 A. 'think it was before. 18 Q. All right. So at the time that Jane Doe 4 19 told you she was a plaintiff in a lawsuit, had you 20 already spoken with Mr. Herman? 21 MR. HOROWITZ: Form. 22 BY MR. CRITTON: 23 Q. Or did that occur after you spoke with Jane 24 Doe 4? 25 A. I don't know who had, who did it first. I Page 145 1 Mr. Herniae 2 A. I don't, I don't remember when it was, but I 3 just net, just met with him and I — 4 MR. HOROWITZ: Fm going to ask you not to 5 discuss what -- 6 MR. CRITTON: Just dealing with the time 7 sequence. Don't tell me what he said right now. 8 not there yet 9 MR. HOROWITZ: There you go. 10 BY MR. CRITTON: 11 Q. So if I understand the sequence correctly, you 12 got a phone call out of the blue from Mr. Heenan about 13 Jeffrey Epstein. 14 A. Yes. 15 Q. All right. You spoke with him, and he asked 16 you a number of questions, right? 17 A. All he really asked me was if I, if l was 18 involved with Jeffrey Epstein, If I was a witness or 19 if— I can't temember exactly what he asked me. 20 Q. I'm going to come back to that in just a 21 minute. Let me get the time sequence here if 1 can, Ms. 22 Jane Doe 7. 23 First time he called you, he called you, you 24 talked to him a little bit and you gave him the name of 25 Jane Doe 4? Page 144 1 think it was me. I don't really know. I don't 2 remember. 3 Q. I'll represent that Jane Doe 4, Jane Doe 4's 4 lawsuit was filed well before yours. She's Jane Doe 4. 5 A. Yes. 6 Q. You are Jane Doe 7. Doesn't necessarily mean 7 one came, hired the lawyer earlier or not, but 1 can 8 tell you her lawsuit was filed months before yours was. 9 A. He called me originally at first, and then he 10 asked me if I lotew any witnesses or anything, and I 11 think I game him Jane Doe 4's number, but I never agreed 12 to start a lawsuit until later on. 13 Q. So when Mr. Herman called you, you gave him 14 Jane Doe 4 — he called you about being a witness? 15 A. I believe so. 16 Q. All right. And did you talk to him? 17 A. Yes. 18 Q. Over the phone or in person? 19 A. Over the phone. 20 Q. And then you gave him the name of other 21 individuals? 22 A. Just Jane Doe 4, I think. 23 Q. And then sometime after you met with or Jane 24 Doe 4 was living with you in the summer, then did you 25 subsequently speak with him again, him meaning Page 146 1 A. Yes. 2 Q. Okay. And then sometime later you called him 3 or did he call you back? 4 A. I called him. 5 Q. How much time transpired between the first 6 call that he made and the second call that you made? 7 A. I don't know. 8 Q. Was it a week? Was it a month? Was it 9 months? 10 A. I don't remember how long it was. 11 Q. Okay. On the first conversation that you had, 12 how long did that conversation last? 13 A. Just like five minutes. 14 Q. Did he tell you he was representing anyone? 15 A. No. 16 Q. Did you ask him how he got your name? 17 A. No. I didn't know — the first time he 18 called, I didn't I was kind of really, I didn't know 19 who was who and who was representing who. So I was, 20 just kind of told him that I would take his number and I 21 would think about it and call him back. 22 Q. Okay. Well, think about what? 23 A. Well he asked me if we wanted to meet. And I 24 told him that I would think about it and call him back. 2 5 Q. Was he pitching basically I could represent (561) 832-7500 6 (Pages 143 to 146) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107837 Page 147 Page 149 7 8 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 1 you in the case? 2 A. No. He just asked me if I knew about Jeffrey 3 and witnessed what happened with Jeffrey, and that's 4 about it. And he asked me if we wanted to meet and 5 talk. And I said that I wasn't sure, you know, because 6 I've had private detectives corning. And I wasn't sure who was on whose side, so I . told him that I would call him back. Q. Was he soliciting or pitching his services to you as a lawyer? MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITPON: Q. Well, why did he want to meet with you? MR. HOROWITZ: Form. BY MR. CRITTON: Q. What did he tell you? A. He Just wanted to talk about the whole Jeffrey thing with me. Q. Why would you want to talk with him about it? MR HOROWITZ: Form. THE WITNESS: Because I heard that, you know, there's like stuff going on with, with people, so I kind of wanted to protect myself. 1 BY MR. CRITION: 2 Q. Why did she call you? 3 MR. HOROWITZ: Forni 4 THE WITNESS: She called me m fill me in on 5 the case, and I knew she was like who she said she 6 was, because Agent at the FBI told me she 7 would be calling me. She pretty much told me what 8 was going on in his criminal case, and that's about 9 it. And she said you might want to protect 10 yourself and get a lawyer, and that's about it. 11 BY MIL CIRITTON: 12 Q. Okay. Did she recommend anybody, any lawyers? 13 A. I don't remember. 14 Q. Do you remember her giving you any names of a 15 • lawyer saying 'Tm going it give you three names," or 16 "If you need some help finding a lawyer, I'll give you a 17 name'? 18 A. She said if I wanted a lawyer, to call back. 19 And she had a list, I think, but she didn't recommend 20 anybody. 21 Q. Did you ever call her back for her 22 recommendation? 23 A. No. I talked to Agent about it, and 24 she said basically what I was supposed to do. And she 25 said it was up to me basically if I wanted to hire a 2 3 6 3 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 148 BY MR. CRITTON: Q. What did you hear was going on with people? A. Nothing. I just heard that, it was when —I forget who called me and said — I think it was Maria or something. She said, you know, to protect yourself, you might want to get a lawyer. Q. Who is Maria, MIME ) A. I think so. Q. Was that the US attorney? A. Yes. Q. And had you ever met with IM A. No. Q. You never met the lady? A. No. Q. So somebody who you just referred to as calls you out of the blue. Why would — A. She-- Q. Let me finish my question. You said you let me ask you this. Did the ady, who you have now identified as assistant US attorney, did she call you before Mr. Hemian or after Mr. Heiman? MR. HOROWITZ: Form. THE WITNESS: Before. (561) 832-7500 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 150 lawyer or not. Q. Did Agent give you any names? A. No. Q. Did anyone from the FBI or US attorney's office ever give you a name of a lawyer — A. No. Q. — to contact? A. No. Q. Did you speak with — let mat back. When you spoke with Ms. that before or after Mr. Herman contacted you? A. It was before. Q. And then how much time transpired or rested before Mr. Herman contacted you about whether you were involved or to ask you questions about Jeffrey Epstein? A. About a couple of months. Q. And do you know when Mr. Herman approximately timewise called you? A. No. Q. Was it before Jane Doe 4 moved in with you that sununer? A. Yes. Q. Was it shortly aver the contacted you? A. No. It was a little while after that. police had 7 (Pages 147 to 150) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107838 Page 151 Q. Was it after the FBI interview? 2 A. Yes. 3 Q. Do you know when the FBI interview took pi 4 A. I third( I was a sophomore in college or 5 maybe -- 6 Q. That's '05, that would have been -- 7 A. I think I was a sophomore or freshman. 8 Q. So that would have been what, approximately 9 '07? 10 A. Yes. 11 Q. Let me just stick with — so when Mr. Haman 12 called you the first time, did he say what he was doing? 13 He obviously wanted to get some information about 14 Jeffrey Epstein and you, right? 15 MR. HOROWITZ: Form. 16 THE WITNESS: It didn't sound like it. 17 BY MR. CAI-ETON: 18 Q. Did you say "How did you get my name?" 19 A. No. 20 • Q. Were you surprised that sane lawyer out of the 21 blue called you to ask you about Jeffrey Epstein and you 22 didn't know who they were a how they had gotten your 23 ,me? 24 A. I thought — I had no idea. That's why I 25 didn't agree to meet with him at first, because I didn't Page 153 i Q. Okay. And did you investigate him at all? 2 A, Yes. 3 Q. Did you go online? 4 A. !looked his name up. 5 Q. Where? 6 A. Online. 7 Q. And what did you find out? 8 A. That he was a sexual abuse attorney. 9 Q. And did you ask him before you hired him 10 whether he was representing any other people associated 11 with the Epstein matter? 12 A. No. 13 Q. When you called him back and before you hired 14 him, did you ask him how he ever got your name? 15 A. No. 16 MR. HOROWITZ: going to assert the 17 privilege. I understand what you're trying to do, 18 but I'm going to assert the privilege as to the 19 conversation in that the entire conversation was 20 leading towards the result of obtaining a lawyer. 21 So that's my position, and we can -- 22 BY MR. CRITTON: 23 Q. Are you going to follow your lawyer's — if he 24 tells you — if he claims a privilege, are you asserting 25 that privilege? Page 152 1 know if he was, you know, on your side or their side or 2 hying to check me or whatever, so that's why I waited a 3 little bit to call him back. 4 Q. When you did call him back, however much time 5 transpired, what did you say to him? 6 MR. HOROWITZ: We're going to assert the 7 privilege on that, but you can make the proffer. 8 BY MR. CRITTON: 9 Q. You called him back, correct? 10 A. Yes. 11 Q. Okay. All you knew, he was a lawyer? 12 A. Yes. 13 Q. You didn't know who he represented? 14 A. No. 15 Q. If anyone? 16 A. No. 17 Q. Okay. He could have been Mr. Epstein's 18 lawyer, he could have been anybody's lawyer, for all you 19 'mew, right? 20 A. I mean he told me he —10ce no, I think he . 21 told me he wasn't — he was like representing — I don't 22 know, he didn't say -- I don't know. I don't remember 23 why I actually called him back. 24 . Q. Why did you call him back? 25 A. Because I wanted to hear what he had to say. Page 154 1 A. Yes. 2 MR. HOROWITZ: Yes. I just want to tell her 3 what I'm invoking. 4 As to this second telephone conversation, I'm 5 instructing you that you have a privilege not to 6 answer questions about the second conversation. 7 THE WITNESS: Okay. 8 BY MR. CRITTON: 9 Q. Did you hire Mr. Herman in the course of the 10 second conversation? lust yes or no. 11 A. He came to Orlando and we met and then -- 12 Q. No, no. Well get there. 13 In the second conversation, did you say "I 14 want to hire you" or did you just say -- 15 A. No. 16 Q. — "I'd lilte to meet with you"? 17 A. "I'd like to meet with you." 18 Q. Okay. So how long did the second conversation 19 last? 20 A Not long. 21 • Q. • Five 'minutes? 22 A. Just about. 23 Q. What did you tell him? 24 MR. HOROWITZ: I'll instruct her not to 25 answer. Well assert the privilege, a privilege, .. (561) 832-7500 PROSE COURT REPORTING OXISCIZA 8 (Pages 151 to 154) AGENCY,: INC. (561) 832-7506 EFTA01107839 Page 155 the attorney/client privilege. MR. CRiTFON: I understand. 3 BY MR. CRITTON: 4 Q. And you are going to follow his direction, 5 correct? 6 A. Yes. Q. And until Mr. Herman came to Orlando -- strike that. 9 How much time passed between the second 10 conversation and Mr. Herman came to Orlando? 11 A. Not long. Maybe a couple weeks. 12 Q. Did anyone else come up with Mr. Herman to 13 meet with you? 14 A. No. 15 Q. Just you and Mr. Herman met? 16 A. Yes. 17 Q. Where did you meet? 18 A. At Starbuck's. 19 Q. Okay. And did you sign an agreement then to 20 have him represent you? 21 A. After lmet with him and heard everything he 22 said, yes, I did. 23 Q. Okay. Before that, that is, before you 24 actually hired him, bad you discussed with him what had 25 happened to you, that is — well, let me strike that. Page 157 I. everybody and her parents fording out and her sister 2 finding out and her being depressed and humiliated, I 3 mean yeah, I would assume that's some trauma for her. 4 Q. Okay. Has she told you she's depressed? 5 A. Yeah, and when she found, her parents found 6 out and all that, she was depressed, she told me. 7 Q. The way you've described it is Jane Doe 4's 8 main emotional or psychological — let me strike that. 9 Her main psychological injury from at least 10 the way you've described it is she's been humiliated and 11 depressed because somebody other than her friends, in 12 particular, her parents and her sister, found out that 13 she had gone to Mr. Epstein's house? 14 A. Not from that. From just going when she was 15 younger. She regrets it, and she even told me i wish I 16 never went when I was younger. i was confused and -- 17 Q. She — fm sorry. 18 A. Go ahead. 19 Q. Did she tell you that she went — well, you 20 !mew she went both before she was 18 and after she was 21 18, right? 22 A. Yeah, l guess. 23 Q. All right. And did she tell you she was more 24 confined when she was 17 than when she was 18, or did .25 she ever describe to you that there was a difference 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 156 In the second conversation did you give him any information as a witness as distinct from your own personal circumstances? MR. HOROWITZ: i have to assert the privilege. BY MR. CRITTON: Q. And you are going to follow his direction? MR. HOROWITZ: Yes. Good try. MR. CRITTON: That's not a good try. Just -- BY MR. CRITTON: Q. Has Jane Doe 4 told you — let me strike that. I'd ask you to assume that she's brought the same S50 million lawsuit that you have, different facts, but she wants 50 million bucks too, at least in her complaint that she's asserted against Mr. Epstein. Did she ever tell you any injuries or damages that she ever sustained as a result of being at Mr. Epstein's home? Has she ever said anything to you about it? A. We never really talked about her. Q. Even through today's date, she's never told you any damages or how she was damaged or any injuries, psychological or otherwise, that she ever sustained at Mr. Epstein's house; is that correct? She's never discussed that with you? A. I mean other than being humiliated by Page 158 1 when she went at 17 or 18? 2 A. I don't know. She never described anything to 3 me. 4 Q. Did she ever say "Gees, the day I turned 18 5 and was a freshman at college, i still went to see 6 Mr. Epstein"? 7 A. No. 8 Q. Okay. Did she ever say, "Well, gee, just 9 before I turned 18, i had these emotional injuries, but 10 at 18 everything was okay when I went to Mr. Epstein's'"? 11. Did she ever say that to you? 12 MR. HOROWITZ:. Fa 13 THE WITNESS: No. 14 BY MR. CRITTON: 15 Q. All right. Did she ever distinguish to you 16 having been to Mr. Epstein's before she was 18 or after 17 she was 18; that is, that any time period was different 18 for her? 19 A. I don't remember. 20 Q. You don't remember her telling you that, 21 correct? 22 A. No -- yes. I don't remember her telling me. 23 Q. All right, I understand. 24 Now you've known Jane Doe 4 for a long time? 25 A. Yes. 9 (Pages 155 to 158) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. . (561) 832-7506 EFTA01107840 Page 159 Page 161 1 Q. Since '02, I think you told me. 2 She's been through some rather traumatic 3 events in her life, has she not? 4 A. I guess you could say that. 5 Q. Well, you know she's been arrested before? 6 A. Yes, when we were younger. 7 Q. Pardon? 8 A. When we were younger. 9 ri I. And she haditliend named 10 You knew didn't you? 11 A. Yes. 12 Q. What did you think of_? Pretty 13 upstanding, great guy? 14 A. No. 15 Q. Okay. He was a jerk, wasn't he? 16 A. Yeah. 17 Q Pardon? 18 A. Yes. 19 Q. And beat Jane Doe 4, didn't he? 20 Physically abused her? 21 A. I mean he pushed her. He didn't beat her up, 22 but yes, he pushed her before. 23 Q. Did you ever see him slam her face down into 24 the hood of the car, into the dashboard of a car? 25 A. No. 1 BY MR. CRITTON: 2 Q. Did you ever hear him call her a-? 3 A. No. 4 Q. What kind of things did you hear 5 to her to verbally abuse her? 6 A. Just bitch, and I don'ttellkAlrber. We were in 7 high school. Just, I mean I never heard him call her a 8 whore or anything else you said. 9 Q. Fm sorry? 10 A. I said or anything else you said. 11 Q. But you were aware that he was both physically 12 and verbally abusive to her? 13 A. Yes. 14 Q. All right. And did you ever tell Jane Doe 4 15 `You got to get away from this guy, he's bad news"? 16 A. Yes. 17 Q. What was her reaction? 18 A. She was in love. So she didn't really -- 19 Q. And she carried oniacal, a long-term 20 physical relationship with did she not? 21 A. Yes. 22 (*.you ever, were you ever aware whether she 23 and were pregnant? 24 MR. HOROWITZ: Form. 25 THE WITNESS: No. say 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 160 MR. HOROWITZ: Form. BY MR. CRITTON: Q. Are you aware, did she ever tell you that that happened? A. No. Q. Did you see spitting on her? A. No. Q. Did you see her spitting back at A. No. Q. Were you aware that had occurred? A. No. Q. Were you aware was a drug addict? A. Yes. Q. Were you aware that he was an alcoholic? MR. HOROWITZ: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. You were around when he verbally abused her and called her awful names, weren't you? A. One or two times. Q. Okay. Did you ever hear him refer to her as a whore? MR. HOROWITZ: Form. THE WITNESS: No. Page 162 1 MR. HOROWITZ: I bow what you mean. 2 BY MR. CRITTON: 3 Q. Of coarse he can't but are you aware that 4 she became pregnant with ? 5 A. Yes. 6 Q. Did she tell you that? 7 A. Yes. 8 Q. On how many occasions did Jane Doe 4 disclose 9 to you that she had become pregnant within 10 MIL HOROWITZ: Form. 11 THE WITNESS: Just once. 12 BY MR. CRITTON: 13 Q. Okay. She never told you — so let me strike 14 that. Are aware that she became pregnant, even if 15 not with ME, on two other occasions? 16 MR. HOROWITZ: Object to the form, and let me 17 just, I have to say this. You are potentially 18 disclosing very intimate personal medical 19 information about one person to another, and I 20 think you are touching on some boundaries that you 21 shouldn't be going on, but go ahead. 22 BY M. CRITTON: 23 Q. Do you want the question back? 24. A.. No. 25 Q. No what? That was your answer? (561) 832-7500 10 (Pages 159 to 162) PROSE COURT REPORTING AGENCY, INC.. (561) 832-7506 EFTA01107841 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 163 1 A. I don't want the question back. 2 Q. Do you remember the question? 3 A. Yes. Q. Okay. I don't. 3 (A portion of the record was read by the reporter.) MR. HOROWITZ: Form. THE WITNESS: I don't think that we should really be talking about her details, intimate details. BY MR. CRITTON: Q. Can you answer my question? MR. HOROWITZ: Just answer what you know. THE WITNESS: I just told you I know once what happened. BY MR. CRITTON: Q. That's all you know, that she became pregnant? A. Yes. Q. Did she tell you how the pregnancy was terminated? A. Abortion. Q. Was she pretty upset about that? A. Yes. Q. What kind of drugs did take? Was he a seller? Let me strike this. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 161: Q. So at least in high school, you're saying that you drank alcohol, right? A. Yes. Q. Even though you were underaged? A. Yes. Q. And did you use pot? A. No, not in high school. Q. Never? A. No. Q. Okay. Did you ever use any other type of illegal drugs? A. No. Q. Any prescription drugs from someone else, like a XBIKax or percocet or — MR. HOROWITZ: Talking about high school? MR. CRITTON: High school. THE WITNESS: No. BY MR. CRITTON: Q. Since high school, you have continued to drink? A. Yes. Q. And I've seen both in the Kliman report is you continue to drink alcohol, sometimes you will drink to excess? A. Yes. Page 164 1 Was also selling drugs? A. I don't know. Q..liou ever see Jane Doe 4 use illegal drugs with A. No. Just drink. 6 Q. Okay. So you guys are best friends and - 7 A. She would never do it in front of me, because 8 I don't do it in front of her or I would never do 9 anything in front of her. 10 Q. If you do drugs, you don't do them in front of 11 her. 12 A. Well, she knows — sorry, I didn't mean to say 13 that. She knows I don't do drugs, so if she ever did 14 drugs, she would never do it in front of me, because she 15 know I was really against that in high school. 16 I was good. The most I would — like I drank, 17 but so if she had ever done drugs with him, she wouldn't 18 have done it in front of me. She would just drink. 19 Q. So if she's used Xanax and she's used pot and 20 she's used ecstasy and if she's used cocaine, any other 21 drugs, that would be news to you? 22 A. I mean I know she did like some of that. I'm 23 not going to — whatever. But I, but she wouldn't do it 24 in front of me, because she knew that I wasn't like 25 that. Page 166 1 Q. All right. And as well, you have used pot? 2 A. Yes. 3 Q. Since high school. How often do you use 4 marijuana? 5 A. I have, hardly ever. 6 Q. Xanax, have you had Xanax? 7 A. No. 8 Q. Have you ever tried cocaine? 9 A. Na 10 Q. Never? So if someone says that you have used 11 cocaine and they have seen you, that would be a lie? 12 MR. HOROWITZ: Form. 13 THE WITNESS: I don't ever remember doing —1 14 don't do drugs at all. 15 BY MR. CRITTON: 16 Q. My question is if someone says they have seen 17 you do coke, that would be a lie? 18 MR. HOROWITZ: Form. 19 BY MR. CRITTON: 20 Q. Or is it possible you did do coke and you just 21 don't remember? 22 A. I ?neon I might have tried it once, but I don't 23 do coke atoll, so 24 Q. Would the same thing be true of Xanax, that if 25 someone said they had seen you take Xanax, you may have (561) 832-7500 11 (Pages 163 to 166) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107842 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 167 tried it once or twice, but you don't do it regularly? A. That would have a lie. I don't do Xanax. Q. You've never done it? A. No, I don't do prescription chugs. Only thing I have ever done is Adderall. Q. Did you get that from friends? A. Yes. Q. Let me go to the FBI for just a minute. When did the FBI contact you? A. I believe it was my freshman year of college, I think. Q. Let's see, that would have been the '05-'06 school year? A. Yes. Q. And now you were at EM? A. Yes. Q. And that's in Orlando. Is that a community college? A. Yes. Q. I asked two questions there. It's an Orlando community college, correct? A. Yes. ..And did you get, did you graduate from A. Yes, I did. Page 169 1 finished in May of '09, correct? 2 A. Yes. 3 Q. But you are still there right now? 4 A. Yes. 5 Q. And why are you in your fifth year? 6 A. Because Pm getting a minor too. 7 Q. Whalwasot or? 8 A. 9 Q. Wh .ik ur minor? 10 A. 11 Q. 12 A. 13 Q. 14 get the courses that you want, you had to be there an 15 extra year? 16 A. Yeah, about. I mean I could really finish 17 this semester, but I wanted to study abroad for the 18 hospitality trip in the summer, so I'm just waiting for 19 that and then I'm graduating in the summer. 20 Q. At the end of the summer? 21 A. Yes. 22 Q. Where is the summer trip taking you? 23 A. To Italy. 24 Q. All right. Where will you go? 25 A. To Florence. And when did you decide to take a minor? I decided about a year after I got there. So that's what, an extra year? In order to Page 168 1 Q. Did you get an AA degree? 2 A. Yes. 3 Q. In what? 4 A. Just general. 5 Q. Kind of liberal arts? 6 A. Yes. 7 Q. After getting your -- when did you graduate? 8 A. Around '07. 9 Q. Spring of'07? 10 A. Yes. 11 Q. And where did you go to school after that? 12 A. 13 Q. also in 14 Orlando? 15 A. Yes. 16 Q. And have you graduated ftom IN yet? 17 A. Not yet. 18 Q. So if -- you would have started ■ in the 19 fall of'07? 20 A. Yes. 21 Q. So if you had two more years, you had two more 22 years to finish at M , assuming you took full loads? 23 A. Yeah. 24 Q. All right. So '07 to '08 and '08 to '09, so 25 if you had finished in two years, you would have Page 170 1 MR. HOROWITZ: Cool. 2 BY MR. CROTON: 3 How long will you be there? 4 For about a month. 5 And this is through.? 6 Yes. 7 And who pays for this, your parents? 8 A. I'm taking out loans for it. 9 Q. And your school, did your parents do Bright 10 Futures? Start again. Were you entitled to Bright 11 Futures? 12 A. No. 13 Q. Any form of the Bright Futures program? 14 A. No. 15 Q. There is another one. 16 A. No. 17 Q. How about did your parents do prepaid at all? 18 A. I don't know. I don't think so. 19 Q. Have your parents supported you while you have 20 been at least the four years in school? 21 MR. HOROWITZ: Form. 22 THE WITNESS: Yeah, I mean I always worked 23 too. 24 BY MR. CRITTON: 25 Q. Okay. Let me just go back to the FBI for just Q. A. Q. A. Q. (561) 832-7500 12 (Pages 167 to 170) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107843 Page 171 1 a minute. So the FBI came to you during your freshman 2 year at IMMI, which would have been '05-'06. • 3 Did they come du Sthe '05 time period, that 4 is, shortly after the police, or was it into 5 the '06 time period? 6 A. I don't remember. 7 Q. Who came? 8 A. Agent=. 9 Q. Just her? 10 A. Her and another guy. I forget his name. 3.1 Q. They drove to Orlando? 12 A. Yes. 13 Q. Where did you meet them? 14 A. Starbuck's. 15 Q. Sarno place you met Mr. Herman? 16 A. Yes. 17 Q. Did you meet anybody else there? 18 A. No. 19 Q. All right. So you are at Starbudc's. How 20 much time did you spend with the FBI at Starbuck's? 21 A. Probably about two hours. 22 Q. Who bought the coffee, do you remember? 23 A. They did. 24 Q. All right. And did they take a taped 25 statement from you at all? Page 173 1 strike that. What did they say to you first? 2 A. They just asked me what happened with Jeffrey 3 and they said that, that I had to tell them, you know, 4 exactly what happened. 5 So I admitted — they asked me ill told the 6 officers everything when they came, and I admitted that, 7 you blow, I didn't tell them everything. 8 And then so I just basically went into detail 9 with them and, you know, told them everything about what 10 happened. 11 Q. Okay. Now is it your testimony that you told 12 them the truth? 13 A. Yes. 14 Q. Okay. Did you make any errors in what you 15 told -- strike that. 16 Did you misrepresent, lie or deceive the FBI 17 in any way? 18 A. No. 19 Q. So if I got the FBI statement, you would say 20 that would be accurate even if you've testified 21 differently today? 22 MR. HOROWITZ: Form. 23 BY MR. CRITTON: 24 Q. Right? 25 A. I mean yes. I told them, I didn't tell the Page 172 1 A. I can't remember if they did. 2 Q. Did they take a statement at all? Was anybody 3 writing? A. They took a statement, yeah. Q. Did you ever sign anything? A. I think so, yes. Q. Have you ever seen the statement that you B signed that you gave to the FBI? 9 A. No. 10 Q. Have you ever requested it? 11 A. No. 12 Q. Did they ever ask you to read it? 13 A. No. 14 Q. So you don't know whether they took down 15 correctly what you told them? 16 A. Yeah, I mean I actually, I think they did have 17 a tape recorder with them. 18 Q. Are you sure? 19 A. I think so, yes. 20 Q. Did they swear you to tell the truth? 21. MR. HOROWITZ: I don't know. 22 THE WITNESS: I can't remember. Pm pretty 23 sure they did. 24 BY MR. CRITTON: 25 Q. Okay. And whardid you tell them -- let me Page 174 1 cops everything, and I pretty much told them -- it took 2 me awhile, but I told them, you know, what happened. 3 Q. Okay. After you talked with the FBI on that 4 occasion, did they tell you that you might have the 5 ability to bring a civil lawsuit for money? 6 A. No. 7 Q. Did they mention anything about a civil 8 lawsuit? 9 A. No. 10 Q. Did they mention anything about any criminal 11 charges that they were investigating? 12 A. Yes. 13 . Q. Did they tell you why they were investigating 14 criminal charges, that is, why it was a federal matter 15 as distinct from a state matter? 16 A. Because I think he, I guess 'think it got 17 turned down by the state or something, because he hired 18 great lawyers that represented him well, and I don't 19 think — I think the judge turned it down. So they, the 20 federal government picked it up, because they didn't 21 think it was fair, the sentence the state gave him. 22 Q. You mean the FBI said that to you? 23 A. Well, 'think Mars what they — something 24 Ince that, l don't know. 25 Q. You could have only gotten that idea from (561) 832-7500 13 (Pages 171 to 174) PROSE COURT REPORTING AGENCY,. INC. (561) 832-7506 EFTA01107844 Page 175 1 them, because you didn't know at the time, did you? 2 A. Yeah, they just said it was a federal 3 investigation now, but now I know why. 4 Q. Did, at that time did they mention IM 5 at all, the assistant US attorney? 6 A. No, I don't think so. 7 Q Did you ever get any papers from either the 8 FBI or from the US attorney's office? 9 A. I don't remember. 10 Q. When you said — culler today you said 11 called. And then I said and you saids 12 How many times have you spoken with 13 14 A. I think just once when she pretty much wrapped 15 up the whole case. 16 Q. When you say she wrapped up the case, at the 17 time that she called you to tell you about what was 18 going on, what did she tell you? 19 A. I don't remember exactly. She just said about 20 what was, told me what happened with the criminal case 21 or what was going on with it or something. 22 MR. CRITTON: Okay. Let's go about ten more 23 minutes. Is that all right? 24 MR. HOROWITZ: Are you okay? 25 THE WITNESS: Yes. Page 177 1 Q, M? 2 A. Just the letter 3 Q. Okay. Do you have any siblings? 4 A. Just a brother. 5 Q. How old? 6 A. I think he's like 36, 37. 7 Q. Are you close? 8 A. Thirty-seven. No. I mean he lives in a 9 different state, so — 10 Q. You are how old now? 11 A. I am 22. 12 Q. So there is a 14-year difference between the 13 two of you? 14 A. I thinlc, yeah. I think he's like 36 or 37. 15 Q. So when he was almost out of high school, y ou 16 were only four years old? 17 A. Yeah, I guess so. 18 Q. He would have been about 18, you would have 19 been about four, if there is a 14-year difference. 20 A. I remember him, he was always in college. He 21 was off to college and he would come home. 22 Q. Where did he go to college? 23 A. He went to IUP. 24 Q. IUP? 25 A. Uh huh. Page 176 BY MR, CRITI'ON: 2 Q. Tell me, you were born in Pittsburgh? 3 A. Yes. 4 Q. You moved to Florida when you were a freshman 5 in high school? 6 A. Yes. 7 Q. Which would have been the 0 — 8 A. 2000. 9 Q. I'm sorry, 2000? 10 A. Yes. 11 MR. HOROWITZ: That doesn't sound right. 12 THE WITNESS: Or 2001, I think. 13 MR. HOROWITZ: Fm sorry. 14 THE WITNESS: Yeab, I think it was 2001. 15 . MR. HOROWITZ: You are right, Tin wrong. 16 BY MR. CFUTTON: 17 Q. And did you start — so it would be 2001 18 through May approximately of 2002, right? 19 A. (Witness nods head up and down.) 20 Q. Would have been your freshman year? 21 A. I believe so. 22 Q. All right. Where did our is move to? 23 A. They moved to 24 Q. What was the address? (561) 832-7500 Page 1.7 1 Q. What's that? 2 A. That's in Indiana somewhere. 3 Q. What does he do fora living? A. Hes a cop. 5 Q. When the Palm Beach police officers called 6 you — let at strike that 7 Does your brother know that you were involved 8 with Mr. Epstein or that you are involved in a lawsuit' 9 A. I've never told him, but unless my parents 10 told him, I don't think so. 11 Q. When the police called, did you ever think of 12 calling your brother, who was a police officer at the 13 time? 14 A. No. 15 Q. Why not? 3.6 A. Because we're not, we don't really share 17 everything. Like he's a guy. I didn't want him to find 18 out what happened with Jeffrey. 19 Q. Your parents, when you moved down here, 20 describe your house for me that you moved in. The house 21 on Road, did you live there during all four years in 22 high school? 23 A. Uh huh. 24 Q. Describe it forme. How big a house was it? 25 A. It was just late a three-bedroom house. 14 (Pages 175 to 178) PROSE COURT REPORTING AGENCY INC. (561) 832-7506 EFTA01107845 B 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 179 1 Q. Three bedroom, three bath, two bath? 2 A. Yeah. 3 Q. Did you have your own room? 4 A. Yes. 5 Q. Okay. And when you were what, 15, I saw in Kliman's report you got your own car, a red Cavalier? 7 Yes? A. Yes. Q. Who bought that for you, Mom and Dad? A. Yes. Q. Brand new car? A. No. It was used. Q. And did you have that so you could use it during high school? A. Yes. la d you take that car with you then to A. No. Q. Did they give you another car? A. I got into a car accident and the car got totaled. And so yeah, so they got me a Mustang that I use. Q Do you still have that today? A. Yes. Q What year is that? Page 181 1 A. Yes. 2 a...1 saw someplace else, does he have a. too? 4 A. Yeah, me and him, we had started it when I was 5 younger, but we just kind of restarted it back up 6 rece .f u So we just sel It's like an online website. 8 Q. So you order them from like a Cushnut or 9 whoever happens to be — 10 A. Buyers. 11 ▪ i. Who did yousupply — do you supply toe or individuals? 13 A. Just individuals. Like it's all online. 14 Q. So you've never had hie a warehouse where you 15 actually buy and sell means? 16 A. No. 17 Q. It's strictly parts? 18 A. And accessories, yes. 19 Q. How about your mom? Did she work outside the 20 home or was she a stay-at-home morn? 21 A. She worked at a craft store when I was 22 younger, and other than that, she was home. 23 And she just recently got a job, but she's 24 mostly home. 25 Q. What does she do now? Page 180 Page 182 1 A. She works at a craft store again. 2 Q. Okay. But basically your dad was the sole 3 source of support for you and your family? 4 A. Yes. 5 Q. And that's his be' an employee of 6 the city ot the Town o 7 A. Yes. 8 Q. All right. And would you have considered 9 yourself at least in your own mind, were you middle 10 class, upper middle class? 11 A. I would say middle class. 12 Q. Dad go to college? 13 A. No. 14 Q. Mom? 15 A. No. 16 Q. Are you the — your brother went to college? 17 A. Yes. 18 Q. And now you've been able to go to college? 19 A. Yes. 20 Q. Pretty happy childhood? 21 A. Yes. 22 Q. Any kind of traumatic events in your childhood 23 23 in anyway? 24 24 A. No. 25 Q. Soho's an employee of the cityalli a l Q. „Anyone during your life that's very close to acti 15 (Pages 179 to 182) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 A. A'99. Q. In addition, the house that you lived at on some acreage? A. It had, I think it's an acre. Q. Pool? A. Yes. Q. In-ground pool? A. Yes. Q. And your mom and dad both had cars? A. Yea. Q. Did your — what kind of work did your dad do? A. He does work for the city, building inspections. Q. Novi? A. Yeah, he still does it now. Q. Is he a contractor or was he at one point? A. I think he does some contracting. Q. So he inspects, does building inspections for what ci Q. The city o A. Uh huh. Q. Yes? A. Yes. (561) 832-7500 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 EFTA01107846 Page 183 Page 185 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you that has died, has passed any? A. No. 3 Q. Ever been in any kind of automobile accidents or any kind of accidents where you were a plaintiff in a lawsuit -- well, where you were injured? 0 A. No. 7 Q. I saw a reference someplace to Cameron & Gomalez or something like that. Do you know a lawyer named Glenn Cameron? A. (Wittsz shakes head from side to side.) Q. No? Doesn't mean anything to you? A. Uhuh. Q. Other than this lawsuit, have you ever been, have you ever made a claim against anyone? MR. HOROWITZ: Form. BY MR. CRITTON: Q. For any type of injuries? A. No. Q. Emotional or otherwise? A. No. Q. Have your parents ever been a plaintiff or a defendant in a lawsuit? MR. HOROWITZ: Form. THE WITNESS: I don't think so. 1 have on a nice Vineyard Vines shirt today. 2 A. Thank you. I like to look presentable. 3 Q. Pardon? 4 A. I said I wanted to look presentable. 5 Q. All right. Do you stay up on fashion like 6 Tory Burch, those kind of things, those types of 7 designers? Are you up on other designers? Do you like 8 to wear design clothes? 9 A. Just Abercrombie I lice, and maybe not 10 anything too expensive, but — 11 Q. And during the time that you were in high 12 school and now that you are in college, and I know you 3 said you have worked as well part of the time that you 14 were in college, do you tend to buy, to keep up with 15 fashion? Lace to dress up? 16 A. I by to. 17 Q. I'm sorry? 18 A. I try to, yes. 19 Q. All right. And during the time that you were 20 in high school, did your parents, were they able to 21 provide for you so that you always felt that you were 22 well dressed among your peers? 23 A. Actually, I had to buy all of my clothes. 24 Q. And were you working at the time? 25 A. Yes, I was. Page in; 1 BY MR. CRITTON: 2 Q. Have you ever been convicted of a crime? 3 A. No. 4 Q. Have you ever been arrested for any reason? 5 A. No. 6 Q. Have you ever had to hire the services of a 7 lawyer at any time before? A. No. 9 MR. CRITTON: All right. Let's take a break 10 for lundh. 11 THE VIDEOGRAPHER: Going off the record at 12 1:11 pm. 13 (A lunch recess was taken.) 14 THE VIDEOGRAPHER: We're back on the record at 15 1:56 pm. 16 BY MR. CRITTON: 17 Q. Jane Doe 7, we're back from lunch now, and as 18 you know, I've done, certainly you know I've done the 19 deposition of Jane Doe 4. I have also done the 20 deposition of Ms. Jane Doe 3 in pan. 21 Would it be correct to describe you as someone 22 who is interested in fashion, pretty much up on fashion, 23 likes to dress fashionably? 24 A. I guess you could say that. 25 Q. Pm not saying that's bad or good, and you Page 186 Q. All right. When you say -- your parents never 2 bought you anything? 3 A. I mean they bought me a few things, but mostly 4 I bought my clothes. 5 Q. Starting when? 6 A. About when I was in high school. 7 Q. When you were a freshman? 8 A. Yeah. 9 Q. Well, when you were still living in 10 Pittsburgh, did you ever have a job? 11. A. No. 12 Q. Okay. When you started working in, or when 13 you moved down to South Florida in your freshman year, 14 did you have a job? 15 A. No. 16 Q. When did you lust obtain any kind of 17 employment? 18 A. I first got a job, I think it was, I was at, I 19 worked at Ultimate Fitness, and I think that was when 1 20 was 16,1 think. 21 Q. Actually you say in your answer to 22 interrogatory number two, which is Exhibit 2, you say 23 your first job was at Ultimate Fitness out in Wellington 24 at the kids club at the front desk in 2004, 2005, which 25 would have been your senior year? (561) 832-7500 PROSE COURT I Sr 16 (Pages 183 to 186) REPORTING AGENCY, INC. (561) 832-7506 EFTA01107847 Page 187 Page 189 1 A. Yes, it was my senior year. 2 Q. So would it be a correct statement up until 3 the time of your senior year, your parents provided for 4 you in terms of clothes and what you needed to wear or 5 what you needed for high school? 6 A. I mean yeah, they tried to. Q. Sure. And you thought that you, amongst your 8 peers, you wore well dressed? 9 A. I mean I tried to be. 10 Q. All right. And then when you started working 11 for Ultimate Fitness, and then it looks like during the 12 summer of '05 before you went to college, you worked at 13 Abercrombie & Fitch? 14 A. Yes. 15 Q. So you got a discount on what you bought? 16 A. Yes. 17 Q. With the money you use earned from Ultimate 18 Fitness and Abercrombie, did you use that to buy 19 clothes, purses, whatever else you wanted? Was that 20 kind of like your spending money? 21 A. Yes. 22 Q. With the money that you received from 23 Mr. Epstein, did you use that to buy clothes and other 24 'Wok-knacks, do fir things that you wanted to do? 25 A. !mean I actually saved a lot of it up until 1 THE WITNESS 2 BY MR. CRI17O 3 Q. Pardon? 4 A. Yes. 5 Q. Okay. So i 6 that you were work 7 you, then you had 8 MR. HOW 9 BY MR. 10 Q. Did you pu 11 received finm Mr. 12 MR. HORO 13 THE WITNESS 14 form, so — 15 BY MR. 16 Q You wouldn 17 the IRS expects you 18 received. 19 MIL HORO 20 BY MR. CRITTO 21 Q. Did you put 22 A. No, I never 23 Q. Did you ev 24 A. I don't mil 25 make me till out f : Yes. N: n the '04, for the '04 time period ing for Ultimate, because they 1099'd o do like a 1040 form, tax return? WITZ: Form. CRITTON: t in any of the money you had Epstein? WITZ: Form. : He never made me fill out a tax CRI TTON: it. Mr. Epstein is not the IRS, but to record income that you've WM: Form. N: that on your 2004 tax return? filed taxes. er file a tax return? ly know. 1 fill out whatever they or a job. Page 188 1 college, but I'm sure I spent some of it on food and 2 clothes, I mean whatever. 3 Q. How much money did you earn during the time 4 that you went to Mr. Epstein's house? 5 A. Mini( it was around 2000 over — 6 Q. Did you put that on your tax rennet? MR. HOROWITZ: Form. 8 THE WITNESS: No. 9 BY MR. CRITTON: 10 Q. Did you file loxes during that time period? 11 A. )(didn't make enough money to have to file 12 taxes. 13 Q. When you worked at Ultimate in '04 and '05, 14 they would have given you — were you an employee or 15 were you an independent contractor, they gave you a 16 1099? 17 A. Yes. 18 Q. Yes, a 1099? 19 A. Yes. 20 Q. Did you therefore have to pay taxes? 21 MR. HOROWITZ: Form. 22' BY MR. CRITTON: 23 Q. Let me withdraw that. 24 Did you have to fill out a tax return? MR. HOROWITZ. Form. (561) 832-7500 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 190 Q. I don't know what you have done or haven't done. My question to you is have you ever filled out a form to report your income to the IRS? A. Yes. Q. And did you strut doing that when you rust started working for Ultimate? A. Yes. Q. During the time you worked for Ultimate, which was 2004, which is one of the years that different places that you have alleged that you were with Mr. Epstein, did you ever report any of the income that you received from Mr. Epstein? MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITTON: Q. Okay. And some of the money that you did earn (tom Mr. Epstein, ifl understood it, you saved it and you used it for college or during your college years? A. I mean I saved it. I don't really remember what I used it for. Q. Okay. You indicated earlier that you would drink alcohol prior to your turning 21, so you were drinking as an underaged person, correct? A. Yes. Q. And it looks -- not looks, but from having 17 (Pages 187 to 190) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107848 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 6 3 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 191 deposed Ms. Jane Doe 3 and Ms. Jane Doe 4, it appears that you all go to clubs and have been going to clubs 3 for a long period of time. MR. HOROWITZ: Form. BY MR. CRITTON: Q. Fair statement? A. I mean yes, I go out. Q. Okay. And before you were 21, did you have a fake ID? A. Yes. Q. All right. And when did you first start using a fake ID, ma'am? A. I don't remember. Q. Was it when you watt away to college or did you have one when you were in high school? A. 1 thinIcI had one in high school. Q. And obviously it said you were what, 21 ? A. Eighteen. Q. Well, falce ID to say you were 18? A. Toga into the clubs, you only needed to be 18. Q. So your first fake ID said you were 18 so you could get into the clubs? A. (Witness nods head up and down.) Q. Yes? Page 192 A. Yes. 2 Q. And did you eventually obtain a fake ID that 3 said you were 21? 4 A. Yes. Q. MI right. And how many different fake IDs did you have? A. I don't remember. Q. More than one? A. Yeah. Maybe like two or three. Q. And who did you get them from? A. I don't remember. Q. Did you have them made or was it a fiend's older sister or something like that? A. People that looked like me. Q. And how would you get it? How would you get the fake ID? A Just gave it to me, people that looked like me. Q. If they looked like you and they were over 21, they would give you their fake ID? A Yeah. I remember one girl that I worked with, she kind of looked like me and she gave me her II) because she had two of them. Q. When she had to what? A. She gave me her ID because she had two. (561) 832-7500 Page 193 1 Q. Did you use the hike ID from time to time to 2 get into clubs which required you to be 21 or to drink 3 alcohol? 4 A. Yes. 5 Q. And you knew that that was a crime? 6 MR. HOROWITZ: Form. 7 . THE WITNESS: Yes. 8 BY MR. CRITTON: 9 Q. And were you ever stopped by the police and — 10. well, let me strike that. 11 Did the police ever look at your fake ID, that 12 • is, were you ever in a club when you were ID'd and 13 someone said this isn't your ED? 14 A. No. 15 Q. You were able to successfully use the fake ID 16 without ever being called on it, is that correct? 17 A- Right 18 . Q. And even though you knew it was a crime, you 19 still did it, correct? 20 MR. HOROWITZ: Form. 21 BY MR. CRITTON: 22 Q. You still used the ID? 23 A. Yes. 24 Q. Any tattoos? 25 A. No. Page 194 1 Q. Morality? 2 A. Just my ears, 3 Q. During the time that you were through the 4 time you were In high school, which would be the summer, 5 la ss the summer of '05 before you went away to 6 did you and your parents go away for 7 vacations? 8 A. We had just gone up to Pennsylvania to go 9 visit my family up there, and we went down to Key West 10. once or twice. 11 Q. Where did you stay when you went down to Key 12 West? 13 A. We stayed in Islamorada at a hotel. Sony, we 14 went to Islamorada once, and then we went to Key West 15 and stayed at a hotel down there. 16 Q. On another trip or the same trip? 17 A. Another trip. 18 Q. Have you ever been to the Bahamas? 19 A. Yes. 20 - Q. Where? 21 A. Nassau. 22 Q, With whom did you go to Nassau? 23 A. I went on senior cruise. 24 Q. Senior mINIa 25 Yes, a senior trip. 18 (Pages 191 to 194) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107849 Page 195 Page 197 1 Q. ForI 2 A. Yes. 3 Q. How many days were you gone? 4 A Three days. 5 Q. Who were your roommates? 6 A. I think Jane Doe 4. 7 Q. Jane Doe 4? 8 A. Yes. 9 Q. Anyone else? How about Ms. Jane Doe 3, was 10 she there too? 11 A. No. 12 Q. Is she younger than you? 13 A. Yes. 14 Q. Other than the cruise to Nassau, is that the 15 only time you've been to the Bahamas? 16 A. Yes. 17 Q. Have you ever been, other than being 18 Pittsburgh -- Fm sorry, Pennsylvania when you have 19 driven up there and been to the Bahamas, have you ever 20 been outside of the state of Florida other than that? 21 A. Yes. 22 Q. Where have you gone? 23 A. I went to, for like my 21st birthday, me and a 24 group of girls went to Vegas. 25 Q. Where did you stay? 1 Q. Are they friends from.? 2 A. Yes. 3 Q. And when did you go to New York? 4 . A. I weriaphomore year. 5 Q. At 6 A. Actually, maybe it was my junior year at 7 I think. 8 Q. Were you there for five, six days? 9 A. I think we were there for like five days. 10 Q. And where did you stay? 11 A. Her aunt has a place in the city. She's like 12 a stockbroker and she has a place in the city she let us 13 stay at 14 Q. Did you go see shows when you were there, any 15 shows? 16 A. No. 17 Q. Shopped? 18 A. We went to Canal Street. 19 Q. Any other trips outside the state of Florida? 20 A. Chicago. 21 Q. When did you go to Chicago? 22 A. We went there I think when I was a sophomore 23 in college or junior. 24 Q. And who, when you went to Chicago, with whom 25 did you go? Page 196 1 A We stayed in The Palms. 2 Q. The Palms, all right. Upscale. 3 A. Well — 4 Q. Did you get to go upstairs on the spike where 5 the club was on the top of The Palms? 6 A. Oh, yeah. My friends mom paid for like ow 7 trip and then she paid for the hotel room, so we all — 8 Q. Who went? 9 A Me and my friend and then her friend 10 = and 1 forget the other girl's name that went. 11 Q. How many days were you in Vegas? 12 A. For about four days. 13 Q. She flew you out there from West 14 A. Well, I paid for my ticket. 15 Q. You paid for your ticket, but they paid for 16 the room, friend? 17 . A. Yeah. 18 Q. All right. Where else have you been outside 19 the state of Florida? 20 A. I went to New Yost 21 Q. When did you go to New York? 22 A. We went there on a spring break trip. 23 Q. Who is we? 24 A. Me and m friend =I a different =, 2 l—ess 5 and my friend (561) 832-7500 • Page 198 1 A. I went with Jane Doe 4. 2 Q. Which Jane Doe 4? 3 A. Jane Doe 4. 4 Q. Who else? 5 A. My friend =I. 6 Q. All right. Anyone else? 7. A. M other friend, 8 Q. Is .= the one you went to Vegas with? 9 A. Yes. 10 Q. Anyone else? 11 A. I don't think so, WI uh. 12 Q. How did you get up to Chicago? 13 A. A friend of mine, like it was my friend's 14 birthday. 15 Q. Which friend's. 16 A. My friend El it was her birthday, so we 17 went to — my friend invited us up there for her 18 birthday. 19 • Q. Olcay. Where did you stay? Which hotel? 20 ' A. My friend has a place up there, so he let us 21 stay at his place. 22 Q. Your friend, it was your friend's birthday. 23 Is it a he? 24 . A. Yes. 25 Q. What was his name? 19 (Pages 195 to 198) PROSE COURT REPORTING AGENCY, INC. .1561) 832-7506. EFTA01107850 Page 199 1 A. Mario. 2 Q. Okay. And how do you know Mario? 3 A. He was, we met him in South Beach just like 4 with a friend. 5 Q. And who is we met him in South Beach? 6 A. Me and ■ 7 Q. 8 A. 9 Q. Did go on this trip too? 10 A. No. 11 Q. Why didn't she pa? 12 MR. HOROWITZ: Form. 13 THE WITNESS: She, I don't know, she was with 14 her boyfriend a lot. 15 BY MR. CRITTON: 16 Q. Was this after -- this was when you were a 17 sophomore where, at second year at IM? 18 A. I think so. 19 Q. Did go too? 20 A. and .I. 21 Q. she went too. See, l didn't go, but I 22 knew went. 23 A. Actually, yeah, it was birthday. 24 Sony. 25 Q. Oh, it was birthday? Page 201. 1 A. Just every once in a while when I could get 2 away. 3 Q. Where do you stay? Stay at a hotel down 4 there? 5 A. Yeah, we usually find like a cheap hotel. 6 Q. Down on the beach or something? 7 A. Uh huh. 8 Q. Yes? 9 A. Yes. 10 Q. Soft might be you and■ or you and some of 11 your other fiends that go down there? 12 A. Uh huh. 13 Q. Yes? 14 A. Yee 15 Q. Which club did you meet Mario at? 16 A. I don't remember. It was so long ago. 17 Q. How long have you known Mario? Sophomore, you 18 are a senior, plus one year, so it would have been about 19 free years ago? 20 A. Yeah. 21 Q. Okay. How many times -- does Mario live in 22 Chicago? 23 A. Yeah, he has a place in Chicago and a place 24 like near Miami. 25 Q. Have you ever been to his place in Miami or 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 2/ 22 23 Page 200 A. Yes. Q. Is from Chicago? A- No. Q. I thought you said you went because it was -- maybe I misunderstood you. A. It was =, it was my friend's birthday, her birthday, and that's why we went there. My friend invited us to go because it was her birthday, and she wanted to go somewhere for her birthday. Q. And Mario, how old — is Mario at. with you? A. No. Q. What's Mario do for a living? A. He works in like the hotel industry. Q. Which hotel? A. I have no idea what hotel. I know his dad like renovates hotels, stuff like that. Q. You met Mario in South Beach, you and met him? A. Yes. Q. Were you at a club down there? A. Yeah, we went down for like the weekend, me and her. 24 Q. Have you been down there 2 bunch of rimes to South Beach a Lismitt n2es for weel a_.... 2 .a_ ids? Page 202 1 near Miami? 2 A. Yeah, we went there once. 3 Q. Who is we? 4 A. Me and. 5 Q. And when you went up to Chicago, did you stay 6 at Mario's place up there? 7 A. Yeah, he let us stay up there, because we 8 couldn't afford to get like a hotel room. 9 Q. Was Mario there at the time you were there? 10 A. Yeah. 11 Q. Okay. How big a place did he have in Chicago? 12 A. Just Ince a condo. 13 Q. I understand. Like a two-bedroom, 14 three-bedroom, two-bedroom, one bath, one bedroom? 15 A. I think it was, yeah, like two or three 16 bedrooms. 17 Q. And who stayed with you at Mario's? 18 A. All the girls. We all stayed in the room 19 together. 20 Q. And there was you, Jane Doe 4, Gonzalez, is 21. that - 22 A. Uh huh. 23 Q. And IM 1 24 A. Yeah. ZS ther iumetLo?„.a. 20 (Pages 199 to 202) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107851 Page 203 Page 205 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 A. Yeah. 2 Q. So there were five of you? 3 A. IJh huh. 4 Q. Yes? 5 A. Yes. 6 Q. How old is Mario? 7 A. I have no idea. 8 Q. !she 15? Is he 20? 9 A. No. 10 Q. Is he 25? Is he 40? 11 A. No, he's late 20's. 12 Q. Late twenties. Are you sure he's not older 13 than that? 14 A. I mean I don't know. 15 Q. What's Mario's last name? 16 A. I have no idea. 17 Q. So you traveled to some guy's house in, or 18 condominium in Chicago and you don't know his name? 19 MR. HOROWITZ: Form. 20 THE WITNESS: I know ifs Mario, but I forget 21 his last name. Ifs been like a while since I have 22 talked to him. 23 BY W. CRITTON: 24 Q. When is the last time you did talk with Mario? 25 A. I honestly don't even remember. It's been a 1 A. Uh huh. 2 Q. So you met Dave through him? 3 A. Yes. 4 Q. All right. And so Dave had you up there to 5 stay at his house? 6 A. Well, yeah, I paid to go fly up there and 7 visit him, because we started like talking a little bit. 8 Like he was just a friend of mine. 9 Q. Did you pay for the ticket or did he pay? 10 A. I paid. 11 Q. And how long were you in Chicago? 12 A. Just for like the weekend I went up there. 13 Q. Had you met him down here in Orlando? 14 A. Yeah. 15 Q. And then he said why don't you come up for the 16 weekend? 11 A. Well, we talked fora little bit, bents,- he's 18 always down for his brother's games, so we like made 19 friends, and then he asked me up. I wanted to come up 20 there and go visit for the weekend. 21 Q. Did you? 22 A. Yee. 23 Q. And just you? 24 A. Yes, 25 Q. And did you stay with him at his apartment? Page 204 while. 2 Q. How many times have you been to Chicago to 3 stay at his house? 4 A. Just once, that one trip we have been on. 5 Q. Are you sure you haven't been up there again? 6 A. No oh, actually I went up there one other 7 time. I have a friend that lives up there that we went to go visit. Q. So you went to Chicago a second time? A Yeah, I went there twice. Q. Who is that friend? A. My friend Dave. His brother plays for I. basketball, so I'm friends with his brother, and that how I met hint THE VIDEOGRAPHER: Excuse me, miss, could you not play with the mike, please? THE WITNESS: Sony. BY MR. CRITTON: Q. So Dave is the player at. or Dave is the brother of the guy from. who plays basketball for A. Uh huh. Q. Yes? A. Yes. Q. You know the player, the Slyer fa/ Page 206 1 A. Yes. 2 Q. Is Dave someone you've dated? 3 A. We didn't — like we're just friends. 4 Q. Did you have any kind of sexual relationship 5 with David? 6 A. No. 7 Q None? Just went up for the weekend? 8 A. Yeah. 9 Q. Did you talk to Mario when you were up seeing 10 Dave? 11 A No. 12 Q. So Mario, you went up there — how many days 13 were you in Chicago? 14 A. We went there for like four days, I think. 15 Q. And where did you go? What did you do when 16 you were up there? 17 A. He like just showed us around the city. He 18 had to work, sole kind of like let us go wherever we 19 wanted and just like told us the good spots to go. 20 We went like out to lunch and walked around 23. the city and took pictures, and we went out one night to 22 like one of the clubs up there. 23 Q. Okay. Did he have any other guys that he 24 introduced to you all when you was up there? 25 A. One other guy, but I for his nem (561) 832-7500 21 (Pages 203 to 206) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107852 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't remember. 2 Q. Charlie, did he kind of hang around with you 3 guys during the four days you were up there? A. He went out with us one night. Mario said it 5 was Ike one of his good friends. Q. Did Mario buy anything for you all when you were up there? A. Just Jane Doe 4, he bought her like i think an outfit. Q. And why would he buy Jane Doe 4, did he express why he bought Jane Doe 4 an outfit? MR. HOROWITZ: Form. THE WITNESS: Because she like didn't bring a lot of cute outfits and she saw something she liked in Bebe. BY MR. CRITTON: Q. So if Jane Doe 4 has testified that he bought dresses for all of you at Babe's, that would be incorrect? MR. HOROWITZ: Form. THE WITNESS: Well, I mean he did. He bought it for Jane Doe 4, he bought her clothes. And then was Re "I want something because it's my birthday," and then he was like, you know, whatever. So he bought her something too. (561) 832-7500 PROSE COURT 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 207 1 Q. How about Charlie, does that sound familiar? 2 A. Yeah. 3 Q. Do you know what Charlie's last name is? A. No idea. Q. How old is Charlie? A. He was an older guy. Q. Fifties? A. Yeah, he was older. Q. And how did Charlie get introduced into the mix, so to speak? A. Just Mario knew him somehow, so he just introduced us to Charlie. Q. Why did he introduce you to Charlie? MR. HOROWITZ: Form. BY MR. CRITTON: Q. Why did Charlie all of a sudden show up with the five girls? MR. HOROWITZ: Form. THE WITNESS: He was showing us around different hotels. BY MR. CRITT0N: Q. So Mario, now his apartment is where, what building, do you remember? A. The John Hancock Q. And how about Charlie, where did he live? .Page 209 1 BY MR. CRITTON: 2 Q. Did he buy you something too? 3 A. I mean yeah, but I was like kind of— he 4 asked Jane Doe 4 Ent It's not like we asked him to 5 by anything for us. She wanted to get something to go 6 out, because she didn't really like bring any cute 7 dresses. 8 And so we went into Bebe, and we never asked 9 him to buy anything. He was like asked Jane Doe 4, he 10 offered to buy her something. 11 Q. I asked —1'm sorry, are you done? 12 A. Well, yeah. !mean he did pay for it, but I 13 never asked him to pay for anything forme. 14 Q. When I rust asked the question, I said did he 15 buy anything for anyone, and you said he bought an 16 outfit for Jane Doe 4. 17 MI right, then I asked you the question well, 18 did he buy anything for anybody else? Didn't he buy 19 dresses for other people? And then all of a sudden you 20 told me. 21 Why didn't you tell me that the first time 22 when i asked you? 23 MR. HOROWITZ: Form. 24 THE WITNESS: It's not lie I asked him to buy 25 me anything. Just I was going to pay for it and Page 208 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 210 brought it to the register and then he offered to pay for it because he was buying Jane Doe 4 something BY MR. CRITTON: Q. Were you confused with my question when i asked you whether he had bought you anything? MR. HOROWITZ: Form THE WITNESS: Well, i wasn't — I'm sorry, I guess I was kind of - BY MR. CRITTON: Q. Again, if you don't understand my question, ask me to repeat it or rephrase it. I asked you if he bought anything for anyone else, and all you said was Jane Doe 4. So if I hadn't followed up the question, you would have misled me, wouldn't you? MR. HOROWITZ: Form. THE WITNESS: I'm sorry, I didn't ask him to buy anything for me. I was going to pay for it and then he just offered. BY MR. CRIM)N: Q. Did he buy any other gifts for anybody when you were up there? A. No, he just like took us out to lunch once. Q. Did he pay for the tripal_ 22 (Pages 207 to 210) REPORTING AGENCY, INC. (561) 832-7506 EFTA01107853 Page 211 1 A. Yes, he did. 2 Q. And did he pay for food wherever you all went 3 if he was with you; that is, dinners or lunches? 4 A. Like not all of them, but some of them he took 5 us out. Q. How about Charlie? Did he buy any lunches or 7 dinners when he was out with you? 8 A. Uhuh. 9 Q. No? 10 A. No. • 11 Q. You are shaking your head. You need to answer 12 out loud, ma'am. 13 I think you said you have been to Mario's. 14 Have you ever seen Charlie since that one trip to 15 Chicago? 16 A. No. 17 Q. Did you ever see Mario when he came back to 18 Florida again? 19 A. He was down in Miami. He goes down there a 20 lot and he calls to hangout, but I !lice live in Orlando 21 so I can't go, you know, that much. 22 But no, I don't think since Chicago 1 have 23 seen him. 24 Q. How about anyone else? Did you ever have any 25 kind of relationship, intimate relationship with Mario? Page 213 1 Dr. ICliman, who your lawyer has hired to testify in this 2 case? 3 A. No. 4 Q. During the time that you have been, during the 5 time that you were in high school, I assume that you 6 were covered under your — strike that. 7 Your dad has worked for the Town of - 8 since he first came to Florida? 9 A. Yeah. 10 Q. So he has a health program through the city, 11 true? 12 A. Uh huh. 13 Q. For health benefits? 14 A. Uh huh. 15 Q. Yes? 16 A. Yes. 17 Q. MI right. And so any type of medical care or 18 treatment that you would need would be covered under 19 your dad's policy? 20 MR. HOROWITZ: Form. 21 BY MR. CRITTON: 22 Q. When you were in high school and through the 23 time you've been in college, as long as you are a 24 student, correct? 25 MR. HOROWITZ: Fonn. Page 212 1 A. No, not at all. 2 Q. Did you ever date him for any period of time? 3 A. No. 4 Q. Me you currently seeing any physicians, 5 psychiatrists, psychologists, mental health counselors, 6 professionals, for any reason which you allege is 7 associated with your visits to Mr. Epstein? MIL HOROWITZ: Form. 9 THE WITNESS: No. 10 BY MR. CRITTON: 11 Q. When, prior to the time that you ever went to 12 Mr. Epstein's home, whatever year that was, '03, '04, 13 '05, for the first time, had you ever seen a 14 psychiatrist or psychologist or counselor for any 15 reason?. 16 A. No. 17 Q. After you went to, or from the first time you 18 went to Mr. Epstein's home up until the last time, did 19 yod ever see a physician, psychiatrist, psychologist, 20 mental health counselor, for any reason? 23. A. No. 22 Q. After the last time you went to Mr. Epstein's 23 home, whether it was in 2004 or 2005, did you ever see a 24 psychiatrist or a psychologist or mental health 25 professional for any reason separate and apart from the Page 214 1 THE WITNESS: Yeah, but there is like his down 2 payments and stuff. They don't cover everything. 3 BY MR. CRITTON: 4 Q. Nobodys does. All right, so my question to 5 you is your dad — again recognizing you're a full-time 6 student, correct? 7 A. Uh huh. 8 Q. Yes?. 9 A. Yes. 10 Q. So up through the current date, you had access 11 to medical care and treatment? 12 . . A. Yes. 13 MR. HOROWITZ: Form. 14 BY MR. CRITTON: 15 Q. Through your dad's health policy, is that 16 true? 17 A. Yes. 18 Q. All right. And with both, I believe 19 through let me strike that. 20 With did they have a student health 21 center? 22 A. Yes. 23 Q. With., did they have a student health 24 center? 25 A. Yes. (561) 832-7500 23 (Pages 211 to 214) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107854 Page 215 1 Q. And both places as well provide for counseling 2 for students who need counseling, for any type of issue, 3 whether ifs birth control, whether it's psychological 4 problems, emotional issues, behavioral health issues, as 5 well as physical problems, those services are made 6 available through both and through.? 7 MR. HOROWITZ: Form. 8 THE WITNESS: Yes. 9 BY MR. CRITTON: 10 Q. And if I understand your testimony, you have 11 never used those services either through the school 12 programs, either or.-- first of all, ou 13 have never used those services through or. 14 as it relates to any issue associated with Mr. Epstein, 15 true? 16 MR. HOROWITZ: Form. 17 THE WITNESS: Yes. 18 BY MR. CRITTON: 19 Q. And as well, even though your father has a 20 health plan or a medical plan through the Town of Palm 21 Beach which you are covered, you have not sought the 22 services of any mental, psychologist, psychiatrist or 23 mental health counselors, correct? 24 . MR. HOROWITZ: Form. 25 THE WITNESS: Yes. First of all, there is 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 217 THE WITNESS: No. BY MR. CRITTON: • Q. Has anyone ever told you you should see a psychiatrist or psychologist or a licensed mental health counselor other than your lawyers? I don't want to know what they said. I'm interested, but — A. Jane Doe 4 told me, she said it would really help me If I saw a counselor because ifs been helping her and — MR. HOROWITZ: Move to strike Bob's laughter. MR. CRITTON: I didn't laugh. It's news to me. BY MR. CRITTON: Q. Who has Jane Doe 4 told you, who is the counselor that Jane Doe 4 said that she's gone to as a result of any visits or the occasions that she had to go to Mr. F-pstein's house? A. I don't know his name. Q. Did she tell you where he was? A. 'think down in Boca. Q. Okay. Did she tell you we finished taking her deposition within the last maybe month and she hadn't seen anybody. MR. HOROWITZ: Object to the form. Page 216 1 no — I would never go to my school and tell 2 anybody about what happened. I mean that's, I mean 3 students probably work there, for all I know. And 4 I don't want to get my dad and my mom involved. 5 And I mean l don't you know, that's 6 something that's embarrassing to me and I don't 7 want — I mean it should be on me, not on them. 8 BY MR. Clt1TTON: 9 Q. Let me move to strike. Let me go back to my 10 question. 11 My question solely was not the whys and the 12 wherefors, but since you've been under your parents' 13 health care Ian,particularly your father's through the 14 Town of you have never sought counseling 15 with a psychiatrist, psychologist, or a licensed mental 16 health counselor relating to any issues associated with 17 Mr. Epstein, correct? 18 MR. HOROWITZ: Fenn. 19 THE WITNESS: Yes. 20 BY MR. CRITTON: 21 Q. Would it also be a correct statement that 22 physically, as a result of your having gone to 23 Mr. Epstein's home, you were never physically injured in 24 any way, were you? 25 MR. HOROWITZ: Form. Page 2 :, 1 BY MR. CRITTON: 2 Q. e other than some Christian counselor that 3 she and saw. 4 MR. HOROWITZ: Bob, you can't disclose that 5 stuff. You just cant 6 MR. CRITTON: Okay, well fine. If you want to 7 .move for some sort of protective order on this, 8 that's fine. 9 Mk HOROWITZ: No, but I'm appealing to you 10 we don't have to do that. You can't disclose 11 someone's confidential medical or therapy to 12 another witness. You just can't do that. You can 13 ask her what she knows, but you can't disclose it. 14 MR. CRITION: Yes, but the perfect example is 15 with this witness, she won't even answer a question 16 that I ask unless 1 key her, and then if I actually 17 know the answer to the question, then she will 18 =dim it, but she's not giving me answers. 19 So you can argue or move for protective order 20 wherever you think is appropriate under the 21 circumstances. 22 BY MR. CRITTON: • 23 Q. Let me ask you this. You say that Jane Doe 4 24 has told you that she's gone -- did she ever tell you 25 she saw a counselor up in the Stuart, Jensen Beach area? (561) 832-7500 24 (Pages 215 to 218) PROSE COURT REPORTING. AGENCY,. INC.. .(561) 832-7506 EFTA01107855 Page 219 Page 221 1 2 3 4 5 6 A. Q. A. Q. A. Q. No. Do you know who Yes. Have you ever met M? Yes. Do you know what he does? is? 7 A. He does like construction and landscing. 8 Q. All right. Do you know whether = has any 9 sort of drug problem? 10 A. No. 11 Q. Have you ever known that Mr. Bullard is 12 alleged to have been a seller of drugs? 13 MR. HOROWITZ: Form. 14 THE WITNESS: No. 15 BY MR. CRITTON: 16 Q. Do you know whether he takes drugs, illegal 17 drugs? 18 A. No. 19 Q. Has Jane Doe 4 told you that her relationship 20 with is very positive, good relationship? 21 A. Yes. 22 Q. She seems to be very happy? 23 A. Yes. 24 Q. Is she currently working at all? 25 A. Yes. 1 A. I don't think so. 2 Q. How do they !mow Jane Doe 4 is a plaintiff? 3 A. Because she's one of my good friends. 4 Q. Did you tell your parents? 5 A. !thinks°. 6 Q. You said Jane Doe 4 told you that she had seen 7 a counselor in Boca. Did she say it was a man or a 8 female? 9 A. I think she said it was a male. 10 Q. And did she tell you when she started seeing 11 the counselor in Boca? 12 A. No. 13 Q. Did she tell you it had helped her? 14 A. Yes. 15 Q. And in what way? 16 A. She said it just helped her like just when she 17 is like emotional with the all the thing coming up, with 18 all the questions for the lawsuit and the media or 19 people — well, not media, but, you know, when all her 20 friends found out and stuff, she was really emotional 21 and crying, and he just really helped her emotionally. 22 Q. What friends did she say found out? 23 A. Whoever you guys asked, talked to, I guess. 24 So 1 mean IM I don't really remember everybody she 25 said. Page 220 1 Q. What kind of work is she doing now? 2 A. She's doing cleaning, like housecleaning and 3 stuff. 4 Q. She's a college graduate? 5 A. Yes. She's starting her own business, like 6 housecleaning. 7 Q. So she's going out, she's doing some cleaning 8 herself, kind of learn the business, and then she's 9 going to get people to work for her? 10 A. Yes. 11 Q. Did she say her business is going well, good, 12 bad or indifferent? 13 A. Yeah, she said it's going good. 14 Q. Do she and have any plans to get 15 married? 16 MR. HOROWITZ: Form. 17 THE WITNESS: Not that I know of. 18 BY MR. CRITTON: 19 Q. She's living with him MI time? 20 A_ Yes. 21 Q. Do your parents know that Jane Doe 4 is a 22 plaintiff in one of these lawsuits or the lawsuit 23 against Mr. Epstein? 24 A. Yes, I think so. 25 Do know that Jane Doe 3 is? Page 222 1 Q. Did she tell you that before MI was ever 2 deposed that she had already told him about having been 3 involved with Mr. Epstein? 4 A. I don't remember. 5 Q. Did she try to blame that on the lawyers in 6 some way? 7 MR. HOROWITZ: Form. 8 THE WITNESS: I don't think she told him, you 9 know, the extent of everything. I don't really 10 know what she told him. 11 BY MR. CRITTON: 12 Q. All right So she told you that at least she 13 is seeing somebody, a male in Boca Raton? 14 A. lib huh. 15 Q. Did she tell you how she had gotten to see 16 somebody in Boca? 17 A. No. 18 Q. So how long ago did she tell you this, in the 19 last month or so? 20 A. Yes. 21 Q. Okay. Did she, as a result of her telling you 22 you should see someone, have you made an appointment to 23 see anyone? 24 A. No. She told me that you guys are going to 25 depose her therapist, and that made me not want to see (561) 832-7500 25 (Pages 219 to 222) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107856 Page 223 1 anybody, because I don't want my whole life story, you 2 know, to be out there. 3 Q. What whole life story? 4 A. I mean I don't feel comfortable talking to a 5 therapist. Like I'd rather wait until everything is 6 over with to talk to somebody. That's why I haven't done anything. Q. Why? What makes you think talking to a 9 therapist after the lawsuit is over is of any benefit to 10 you? 11 A. Because like I had heard that you guys already 12 deposed her therapist, and I don't want everything, you 13 know, I say to be just public knowledge to every lawyer. 14 Q. You understood what you said to Dr. Kliman is 15 public knowledge, in essence? It's public within the 16 confines of this lawsuit. You understand that, don't 17 you? 18 MR. HOROWITZ: Form. 19 THE WITNESS: Yes. 20 BY MR. CRITTON: 21 Q. And everything you have said to Dr. Hall is 22 shared not only with me, but as well shared with your 23 attorney, correct? 24 A. Yes. 25 Q. Okay. So what were you concerned that you Page 225 1 MR. HOROWITZ: Form. 2 THE WITNESS: That's what people say, but 3 there are students that work in those offices, and 4 I don't want people at my school like 'mowing my 5 business. 6 BY MR. CRITTON: 7 Q. Did you try get some assistance? Did you talk 8 to your parents and say "Hey, look, I think it would be 9 of some benefit for me to go see a psychologist or a 10 psychiatrist"? 11 A. I'm like kind of embarrassed to ask them. Td 12 rather do it on my own. 13 Q. Isn't the reason that you haven't gone to go 14 see someone, ma'am, is you don't feel the need to do 15 that? 16 MR. HOROWITZ: Pont 17 THE WITNESS: No, I do feel the need. I want 18 to go see somebody, but I just don't feel 19 comfortable doing it now. 20 BY MR. CRITTON: 21 Q. But why? I mean it doesn't make sense -- let 22 me strike that. 23 In the year 2010, have you been on any trips? 24 A. Yes. 25 Q. Where did you go? Page 224 might tell a psychologist --just a minute, I need to ask the question, ma'am. 3 What were you concerned with that I might ask 4 that you might toll a psychologist or psychiatrist that you wouldn't want he or she to repeat to me? 6 A. Nothing. I just talked to those because I had 1 to talk to those people, and I'd rather just wait until 8 everything is over, because I don't feel comfortable 9 like talking to people right now. 10 And also, like I'm in college. I don't have, 11 you know, money right now to go see somebody. And 1 12 don't, and my parents aren't going to like — I mean I'm 13 not going to pay $40 a visit every week or two weeks, 14 whatever. Like I have like $100 a week I have to live 15 on in college basically, so — 16 Q. Have you actually gone to the. center where 17 they have psychologists and psychiatrists? 18 MR. HOROWITZ: Form. 19 THE WITNESS: I definitely don't want to go to 20 center. 21 BY MR. CRITTON: 22 Q. Why wouldn't you do that? Because your 23 medical records or your psychiatric records or 24 behavioral, psychological records are supposed to be 25 completely privileged. Page 226 1 A. I mean I went to Key West. 2 Q. With whom? 3 A. I went with just my friend =. 4 Q. M t? 5 A. Uh huh. 6 Q. Where did you stay? 7 A. We stayed at my friend's ex-boyfriend's place 8 down in Key West. 9 Q. My friend's ex-boyfriend. Your friend, whose 10 name is? 11 A. My friend M, my old roommate. Her 12 ex-boyfriend lives in Key West. 13 Q. His name is? 14 A. Nick. 15 Q. Nick? 16 A. Yes. 17 Q. Was Nick there when you were there? 18 A. Yes. 19 Q. Where does he live in Key West? 20 A. He just lives in a small apartment off Duval 21 Street. 22 Q. So you stayed with him for what, a week? 23 A. Yeah, for like five days. 24 Q. Four to five days? 25 A. Uh huh. (561) 832-7500 26 (Pages 223 to 226) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107857 Page 227 Page 229 1 Q. Yes? 2 A. Yes. 3 Q. Okay. And I assume you partied every night, 4 went out every night? A. I mean we went out some and we just went to 6 the beach a lot. Q. Okay. So it's your testimony during the four a or five nights that you were there -- what time period 9 were you there, spring break? 10 A. Yes. 11 Q. So you were there for spring break, a million 12 other college kids there? 13 MR. HOROWITZ: Form. 14 THE WITNESS: Yes. 15 BY MR. CRITTON: 16 Q. All right. It would be a fair statement -- 17 well, let me be acanate. It was during the four or 18 five days that you were there, is it your testimony that 19 you only went out one or two nights to party and to go 20 to clubs? 21 MR. HOROWITZ: Form. 22 BY MR. CRITTON: 23 Q. Or did you go out every night? 24 A. I went out a lot when we were there. It was 25 spring break. A. We both split it 2 Q. All right. Who paid for your drinks when you 3 went out, when you even had too much to drink? 4 MR. HOROWITZ: Form. 5 THE WITNESS: I mean we did sometimes. 6 BY MR. CRITTON: 7 Q. All right. And then if you were lucky, maybe 8 some guy would buy you a drink or drinks? 9 A. Yes. 10 Q. I'm sorry? 11 A. Yes. 12 Q. All right. And isn't it a true statement, 13 Jane Doe 7, is if you really wanted to see a 14 psychologist, you have maybe not every week, but you 15 would have had the fiuids to do that, you just choose to 16 use your funds in a different, for different purposes at 17 the current tint? 18 MR. HOROWITZ: Fonn. 19 THE WITNESS: No, that's not the main reason. 20 The main reason was1 wanted to wait until after 21 the lawsuit. 22 BY MR. CRITTON: 23 Q. So people !Bre me who represent Mr. Epstein 24 maybe can't look at what you tell a psychologist? 25 A. I mean I just feel uncomfortable like saying Page 228 1 Q. Exactly. My point is that you went down there 2 for spring break and you went out every night and you 3 partied, didn't you? 4 A. Yeah, ifs spring break 5 Q. And you had fun? 6 A. Yeah, I did. 7 Q. And you had a great time? 8 A. Yes. 9 Q. And you drank alcohol, I assume? 10 A. Yes. 11 Q. You had a cocktail here and there? 12 A. Yes. 13 Q. And there were some nights that you had too 14 many cocktails? 15 A. Yes. 16 Q. And how did you get down there? Whose car did 17 you drive down from Orlando? 18 A. I drove. 19 Q. All right. And who paid for your meals when 20 you were there? 21 A. We did. We went food shopping before we even 22 got there and we like -- when we got there, we went food 23 shopping and just mainly made food to like saw money, 24 because food is like expensive down there. 25 Q. Who paid for the gas? Page 230 1 everything right now. 2 Q. What makes you think you will be more 3 comfortable after a lawsuit talking with someone? 4 A. Just because when everything is like done and 5 over with, I feel like it will be a better time to just 6 help me get over everything. 7 Q. Isn't it true, though, if you really wanted to 8 sec — well, let me ask you this. 9 After the police came to you, the Palm Beach 10 Police Department came and interviewed you back on 11 October 4th of 2005 and you had sent Mom into the house. 12 when the Palm Beach police left, did Mom say to you 13 "What in heaven's name is this about, Jane Doe 7r 14 A. Yeah, she asked me about it. 15 Q. And by that time, Dad was home? 16 A. Yes. 17 Q. All right. And did you, did they both sit 18 down and say "Young Lady," or "Jane Doe 7, come on. 19 what's the deal here? 20 A. Yes. 21 Q. "What happened? How long did that 22 conversation last? 23 A. I mean I obviously didn't tell them everything 24 that happened. So I mean I don't know, I Just told them 25 briefly what I told the cops. (561) 832-7500 tamoll•ImStaa....F.rsa.asnar 27 (Pages 227 to 230) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107858 Page 231 Q. So you only told them what you had told the 2 polioe, that you were at Mr. Epstein's twice, one time 3 you gave Mr. Epstein a massage, another time you just 4 took somebody else? 5 A. Yes. 6 Q. That's what you told them? 7 A. Yes. 8 Q. Have you ever told them anything differently? 9 A. No. 10 Q. So as far as your parents !mow at this point 11 in time, as far as they !mow is that you went to 12 Mr. Epstein's — let me strike that. 13 As of today's date, your parents only know 14 what you told them the day that the Palm Beach Police 15 Department was there interviewing you? 16 MR. HOROWITZ: Form. 17 THE WITNESS: They never asked me about it 18 They don't really want to know or care to know 19 everything. They already don't like Jeffrey. They 20 read the papers. They know what goes on and went 21 on. I mean they are not stupid 22 BY MR. CRITTON: 23 Q. Well, they have no idea what went on with you 24 and whether your circumstances are similar to or even 25 close to what someone, some other person's situation Page 233 1 MR. HOROWITZ: Form. 2 THE WITNESS: 1 mean I'm sure they would try 3 to help me out. It's just like embarrassing to say 4 that to them and its just something I would rather 5 just deal with on my own. 6 BY MR. CPJTTON: 7 Q. You sent me some, or your attorney sent me 8 some additional answers to interrogatories the other 9 day. 10 !AR. CRITTON: Lets go off the record for a 11 minute. 12 THE VIDEOGRAPHER: Going off the record at 13 2:41 p.m. 14 (Discussion held off the record.) 15 THE VIDEOGFtAPHER: Were back on the record a 16 2:46 p.m 17 (The documents were marked Defendant's 18 Exhibits 1.3 for identification.) 19 BY MR. CRITTON: 20 Q. Before I get back to the interrogatories, you 21 wouldn't, growing up, from the time that you were 22 freshman through even your current status, you wouldn't 23 have considered yourself economically disadvantaged, 24 would you? 25 A. What does that man? Page 232 I might be, true? 2 MR. HOROWITZ: Form. .3 THE WITNESS: Yeah, but I — they don't really 4 want to know. I mean they, I told them what I told 5 than and I mean that's all that Imean they know, 6 and from reading other people's things like what he 7 did or tried to do to most girls. So -- 8 BY MR. CRITTON: 9 Q. Have they ever asked you, has your mother ever 10 asked you 'Hey, Jane Doe 7, what happened when you were 11 at Mr. Epstein's home?" 12 A. Just the first time that the cop-- 13 Q. Since that day, she's never asked and you've 14 never offered? 15 A. No. 16 Q. Correct? 17 A. Correct 18 Q. Same thing with Dad? 19 A. Correct 20 Q. Is it your testimony that if you went to your 21 parents and you said "Look, I think I might need some -- 22 I'd like to see a psychiatrist or a psychologist to help 23 me deal with some issues relating to Mr. Epstein,* 24 assuming you said that to them, it's your testimony that el imil isomia.. eur ts paren would say no? 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 234 Q. I'm not sure. Did you feel economically deprived when you were a freshman or a sophomore or a junior or a senior in high school, that your parents had economically deprived you, or did you feel that you were fine economically? MR. HOROWITZ: Form. BY MR. CUT-TON: Q. I mean everybody would !Ore to have more money. A. I mean my parents had to work really hard for their money, so it's not like I had everything given to me, like my dad made me work for it If I ever wanted money, I had to like wash his car or do something, so I mean- Q. Those are good things, though, you had chores? A. Yeah, but — Q. You didn't consider yourself economically disadvantaged, did you? MR. HOROWITZ: Form. THE WITNESS: I guess not. BY MR. CRITTON: Q. Jane Doe 4, I had an opportunity to meet her parents. I wouldn't describe her as being economically disadvantaged, but you don't care what I think, so my question to you is do you think Jane Doe 4's parents or (561) 832-750.0 PROSE COURT 28 (Pages 231 to 234) REPORTING AGENCY, INC. (561) 832-7506 EFTA01107859 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 235 1 her family life or that she was in any way economically 2 disadvantaged? 3 MR. HOROWITZ: Form. 4 THE WITNESS: I don't think so. 5 BY MR. CRITTON: 6 Q. How about lane Doe 3, did she have similar 7 middle class circumstances like yourself and Jane Doe 4? 8 MR. HOROWITZ: Form. 9 THE WITNESS: Yes. 10 BY MR. CRITTON: 11 Q. Okay. So you wouldn't have considered her 12 economically disadvantaged, would you? 13 MR.. HOROWITZ: Form. 14 THE WITNESS: Yes. 15 BY MR. CRITTON: 16 Q You would? 17 A. No, I wouldn't. 18 Q. All right. In your answers to interrogatories 19 you listed, which is Exhibit 2, you listed the only 20 medical, physicians, medical facilities, health care 21 providers — and I'm paraphrasing -- psychiatrists, 22 psychologists, et cetera, that you had seen in the past 23 ten years, you listed the walk-in medical center at 24 Orlando, at University Boulevard, Orlando, 2005 to the 25 present. 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 237 Page 236 1 I assume that's the school clinic? 2 A. No. Just a clinic that was by my house. 3 Q. Like a doe-in-the-box? 4 A. Yeah. 5 Q. And if you had a cold or got the flu or 6 something, you would go there for medical care and 7 treatment? A. Yes. (561) 832-7500 Page 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24. 25 29 (Pages 235 to 238) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107860 Page 2.39 Page 241 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. CRITTON: Q. Okay. Tell me about at the current time, I know you have told us other than seeing Dr. Kliman, you have never seen a psychiatrist, psychologist, mental health counselor for any reasons relating to damages you claim for which you seek money damages against Mr.— let me start that again. You filed a lawsuit seeking money damages from Mr. Epstein for money, right? MR. HOROWITZ: Penn. THE WITNESS: Yes. BY MR. CR1TTON: Q. Okay. And what do you think your damages are? 1 wasn't thinking. 2 And it's just something I wish I could take 3 back, something that happened to me. And ifs something 4 I'll never be able to forget for the rest of my life, 5 and just the pain that I caused my parents and other 6 people. Ifs just — 7 Q. What pain have you caused — what other person 8 have you caused pain? 9 A. I mean mainly my parents like more than 10 anything. It was heartbreaking for me when they found 11 out. And I mean I wish I could take it back, and — 12 Q. What did your parents say to you when you told 13 them that you had been to Mr. Epstein's twice? 14 A. I mean they were just asking me why, why would 15 you do that? Like how -- I mean they understand now 16 that, you know, it was, he was just a predator mainly, 17 but, you know, at the time they just, they were upset 18 Q. Okay. I don't want to — let me ask my 19 question again. 20 MR. CRITTON: Okay, let me see it again. Run 21 It down for me, Rachel. 22 BY MR. CRITTON: 23 Q. What specifically, when you told your parents 24 you had been to Mr. Epstein's twice, once with e and 25 you had given him a massage, he meaning Mr. Epstein, did Page 240 1 That is, what elements or items of damage do you think 1 2 you have sustained as a result of your having been to 2 3 Mr. Epstein's home? 3 4 MR. HOROWITZ: Form. 4 5 BY MR. CRITTON: 5 6 Q. In your words. 6 7 A. Well, for like the last six years I've been 7 8 like, live had a lot of things happen to me. I've been 8 9 depressed a lot. I have anxiety. I just feel like that 9 10 happened and I can, something I could never take back. 10 11 I feel like I'm damaged, you know, and it's just like I 11 12 feel litre dirty almost for doing that and Pm really 12 13 like self-conscious about it. 13 14 I mean I have like flashbacks a lot of going, 14 15 and then I get really depressed. Every time I hear his 15 16 name or something come up about it, I get depressed 16 17 where I don't eat and I can't sleep. I just have really 17 18 bad anxiety. lust my memory a lot too. I mean I have 18 19 memory problems. 19 20 I tried to like hide all the memories, just to 20 21 try to get over everything. And I mean ifs just hard. 21 22 Like when people bring it up and I have to talk about 22 23 it it's embarrassing. It's hard. It just makes me 23 24 feel like just I did something and it's -- I know now, 24 • 25 you know, that it's not my fault, but at the time I 'tat 25 Page 242 you tell them that he never touched you, that you never touched him, that nothing occurred other than you gave him a massage, just like you told the police? MR HOROVrITZ: Fenn. THE WITNESS: I told them that he tried, you know, to touch me and do things with me, but obviously I couldn't tell my parents everything. I mean they know now, you know, what's, what went on there and, you know, just from assuming and hearing from other people and reading things. BY MR. CRITTON: Q. Okay. Let me move to strike as nonresponsive. I don't want to know what they assumed, okay? I'm not interested in that. I'm interested in what you told them. So if you listen to my question, you keep adding on, but Pm assuming and they read this and they read that. I'm not — Pm glad they have read, or it's up to them what they want to read or not. !just want to know what they have told you and what you have said to them, okay? So focus on my question if you would, ma'am. You told me earlier, a couple of times, that you told them the day that the Palm Beach police were there at your house the same thing that you had said to 30 (Pages 239 to 242) (561) 832-7500 PROSE COURT. REPORTING. AGENCY, INC.' (561) 832-7506 EFTA01107861 Page 243 Page 245 1 the police, correct? 2 A. Yes. 3 Q. Okay. And what you would have said to them 4 was, is that you gave him a massage on one occasion, he 5 never touched you, and you never touched any of his 6 private parts, right? 7 MR. HOROWITZ: Form. 8 BY MR. CRITTON: 9 Q. You told him that? 10 A. Yes. 11 Q. And you told them the second time you went, 12 you took somebody else, you mayiurve gone with Jane 13 Doe 4, you may have gone with but you didn't go 14 upstairs, correct? 15 A. Yes. 16 Q. Okay. So at least as of that date, as of the 17 date that you spoke with them, which you have testified 18 as well today is the only time you have ever talked to 19 them about what occurred at Mr. Epstein's house, as far 20 as they know, you gave Mr. Epstein a massage on one 21 occasion, you were fully clothed and he was completely 22 covered, true? 23 MR. HOROWITZ: Form. 24 THE WITNESS: I mean at that point, that's 25 Alai I told them, yes. 1 BY MR. CRITTON: 2 Q. At the current time? 3 MR HOROWITZ: Form. 4 THE WITNESS: A lot, especially lately, me 5 having to go through all this. 6 BY MR. CRITTON: 7 Q. You mean having to do this deposition? 8 A. I mean this whole — I mean it depends. I 9 mean sometimes it's worse than others. Like when they 10 bring up his name or, you know, my mom will call me 11 saying she read something in the newspaper, I won't be 12 able to eat for like a week. III get depressed. 13 have bad anxiety. Ifs hard for me to like do 14 schoolwork. It will bring like flashbacks back. 15 Just every day I feel like disgusting, and 16 every time I hear his name, it just brings back 17 memories. 18 Q. This is an everyday thing for you? 19 MR. HOROWITZ: Form. 20 IRE WITNESS: Not every day, I mean some 21 days -- 22 BY MR. CRITTON: 23 Q. You -- 24 MR. HOROWITZ: She wasn't done, I don't think. 25 MR. CRITTON: She keeps changing anyway. It Page 244 1 BY MR. CRITTON: 2 Q. Right. And they may have read things in the 3 newspaper, but you have never told them anything 4 different than what you told them that one occasion back 5 on October 4th of 2005, correct? 6 MR HOROWITZ: Form. 7 THE WITNESS: Yes. I mean I also told the 8 cops that he did try to grab me in my butt and I 9 believe I told my parents that too. 10 BY MR. CRITTON: 11 Q. Okay. So you told them that too. And that's, 12 as far as they know, that's all that occurred, true? 13 A. Yes. 14 MR. HOROWITZ: Form. 15 BY MR. CRITTON: 16 Q. Okay. Now, you gave a list of issues that you 17 have, including depressed, anxiety, you feel damaged or 18 dirty, self-conscious. You don't eat, sleep, things of 19 that nature. 20 How often do any of those symptoms or those 21 issues bother you? 22 MR. HOROWITZ: Form. 23 BY MR. CRITTON: 24 Q. Or cause you any concern? MR, HOROWITZLIonn. (561) 832-7500 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 246 doesn't make any difference. MR. HOROWITZ: Move to strike. BY MR. CRITTON: Q. Are you done? Are you going to add more to it? A. What else were you going to ask me? Q. Your lawyer thought you had more to say, so I'm going to give you the chance. rm trying to find out how often this bothers you. Say over the last six months or a year, how often do any of those symptoms seem to bother you? A. I mean every week. Q. Every — A. Basically. I mean I try do other things to like you know, I mean I try to go out with my friends and hang out and just to kind of get it off my mind, but I mean something always comes back to remind me or bring it up, or I'll hear something and I just fall into like depression again. Q. Okay. So has this been true since the day that the Palm Beach police came to your home on October 4th of 2005? MR HOROWITZ: Form. THE WITNESS: Yes. 31 (Pages 243 to 246) PROSE COURT REPORTING AGENCY, INC. (561) 832-75O6 EFTA01107862 Page 24 Page 249 1 BY MR. CRITTON: 2 Q. Is that when it started, when all of a sudden 3 you knew that someone else might know? 4 MR. HOROWITZ: Fa 3 THE WITNESS: It started before then, like even when I was going like I would be depressed and I would just, like I don't know why I kept going. I was confined, but I mean I just felt dirty kind 9 of and I was upset then. So I mean it's been going 10 on for a while, not just after the police. 11 BY MR. CRITTON: 12 Q. So now it's your testimony that from the first 13 time you went to Mr. Epstein's home, you were depressed? 14 MR. HOROWITZ: Form. 15 THE WITNESS: Not the first time. 16 BY MR. CRITTON: 17 Q. How about the second time? 18 MR. HOROWITZ: Fonn. 19 THE WITNESS: I mean if you're really going to 20 start doing that to me, !mean it's — 21 BY MR. CRITTON: 22 Q. It's not doing it to you, ma'am. I need to 23 know. You are claiming $50 million against Mr. Epstein 24 in this case, so I need to know when -- 25 A. Well, you are like belittling everything I am 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. HOROWITZ: Farm. THE WITNESS: The first time I really became depressed was like after the last time I went when he really tried to, you know, do stuff with me forcefully, and then I just felt disgusting and I got depressed, and that's why I just stopped going. BY MR. CRITTON: Q. Okay. And time flame again you are not sure, it might have been in '04, it might have been in '05, you are just not sure, correct? MR. HOROWITZ: Form. BY MR. CRITTON: Q. When the last time you went to Mr. Epstein's? A. I can't remember the exact date. Q. Sometime in 2004, 2005? A. Yes. Q. All right And prior to the last time you were there, you had never been depressed when you had been at Mr. Epstein's home; is that correct? MR. HOROWITZ: Form. THE WITNESS: I mean I was upset. I wouldn't — I don't, I can't — I don't know, I can't prescribe myself I'm not a psychologist, I don't — Page 213 =Yin& 2 Q. Tin not belittling it, okay? I'm not at all. 3 MR. HOROWITZ: I think you are, Bob. You are 4 snickering. 5 MR. CRITTON: I am not snickering at all, all 6 right? 7 MR. HOROWITZ: You did several times. MR. CRITTON: I did not 9 MR. HOROWITZ: You have rolled your eyes 10 several times. 11 MR. CRITTON: Well, there's a lot of things 12 that you've rolled your eyes at and I don't call 13 you on it, and with the changes of testimony this 14 lady has, it's a wonder my eyes can stay normal 15 anyway with the level -- anyway, be that as it may, 16 you can object to form all you want. 17 BY MR. CRITTON: 18 Q. So let me clear it up with you, ma'am. I'm 19 interested in what your damages are in this case. Do 20 you understand that? 21 A. Yes. 22 • Q. Okay. So have you been depressed since the 23 first time you went to Mr. Epstein's home? And if not, 24 tell me when you first became depressed as a result of 25 having met Mr. Epstein. Page 250 1 BY MR. CRITTON: 2 Q. Well, were you ever anxious when you left 3 Mr. Epstein's house? 4 A. Yeah, every time I left his house, I just 5 thought what did I just do? And I don't know why I kept 6 going. 7 THE VIDEOGRAPHER: Five minutes till tape 8 change. 9 BY MR. CRITTON: 10 Q. Even though you were anxious, you knew what 11 was going on at lean from your own words earlier was 12 inappropriate, you continued to go back to 13 Mr. Epstein's; nue? 14 MR. HOROWITZ: Fenn. 15 THE WITNESS: Yes. 16 BY MR. CRITTON: 17 Q. And you chose voluntarily to get in your car 18 and go back to Mr. Epstein's; true? 19 A. Yes. 20 Q. All right Did you feel self-conscious? 21 A. I mean of course I did. 22 Q. After the first time you went to Mr. Epstein's 23 home? 24 A. I mean yeah. I just, I felt like somebody is 25 going to find out or I mean I vms just, the whole time ] (561) 832-7500 32 (Pages 247 to 250) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107863 Page 251 was just, I just felt disgusting for going there. 2 Q. All right. And at that time did you have, 1 during the time you were going to Mr. Epstein's, did you 4 have flashbacks? A. No, they started after. Q. When? 7 A. After I stopped going there. 8 Q. The day after the last time you were there, 9 did they start? 10 A. No. Ifs like when my friends would say, you 11 know, they went to Jeffrey's or something, then I would 12 get flashbacks. 13 Q. Which of your friends did you tell after the 14 last time you went to Mr. Epstein's that you were either 15 depressed, you were anxious, you felt disgusting, 16 self-conscious, or that you were having flashbacks? 17 MR. HOROWITZ: Form. 18 BY MR. CRITTON: 19 Q. Which of the friends did you tell? 20 A. I believe just Jane Doe 4. 21 Q. Okay. And you told Jane Doe 4 that you were 22 having all these symptoms, right? 23 A. I mean no. 24 MR. HOROWITZ: Form. 25 THE WITNESS: I don't exactly remember what I 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 253 by the FBI and then just everything came back. And that's when it started getting really bad and I was really upset then. And, you know, just having to talk to the FBI, and l mean that was like depressing and scary and like I just had really bad anxiety and I felt like I was having panic attach. And I mean, so I mean it kind of started back up. BY MR. CRITTON: Q. Okay. So sometimes it's more, sometimes its less? A. Yes. Q. And is it because again someone brought it to your attention or wants to talk about it that that causes you anxiety? MR. HOROWITZ: Form. THE WITNESS: I mean of course some people like bring it up and I hear about it, I get, you know, anxiety and it just brings back everything. BY MR. CRITTON: Q. Do you think this lawsuit creates anxiety for you? A. I mean of course. Q. All right. And you think when this lawsuit is Page 252 1 told her. ljust remember telling her I was upset 2 about it 3 BY MR. CRITTON: 4 Q. But you knew she was still going? 5 A. Yes. 6 Q. Okay. Did you say "Jane Doe 4, I feel 7 depressed, anxious, disgusting, self-conscious, Pm 8 having flashbacks, I'm not eating and sleeping, I'm 9 having memory problems. Why in heaven's name would you 10 continue to go see Mr. Epstein?" 11 Did you have that conversation with your very 12 best friend? 13 MR. HOROWITZ: Fonn. 14 THE WITNESS: No. 15 BY MR. CRITTON: 16 Q. What have these symptoms that you've expressed 17 of depression, anxiety, feeling disgusting, 18 self-conscious, flashbacks, have those symptoms been 19 pretty much the same since you last sent to 20 Mr. Epstein's up through the current time? 2/ MR. HOROWITZ: Form. 22 THE WITNESS: I mean right around when I 23 stopped going, they were really bad. And then, you 24 know, it just kind of, you know, I tried to forget i125 about it up until, you know, when I got contacted (561) 832-7500 Page 254 1 over, a lot of the anxiety that you have and the 2 feelings that you have will go away? 3 MR. HOROWITZ: Form. 4 THE WITNESS: I'm hoping after it's over, I 5 can just kind of get help and get past everything. 6 BY MR. CRITTON: 7 Q. And whetter you recover a dollar from 8 Mr. Epstein or S100,000, do you think that your ability 9 to gel better will be the same? 10 MR. HOROWITZ: Rem. 11 TIlE WITNESS: Idol* think there is any 12 amount of money that could ever, you know -- I mean 13 !would much rather have never had this happen to 14 me than have any amount of money. There is 15 nothing, amount of money that somebody could give 16 me to help me get through everything, but I mean 17 I'm just hoping that when everything is over, you 18 know,1 can just try to see somebody to help me and 19 try to forget about it and move on with my life. 20 MR CRITTON: Need to change tape. 21 THE VIDEOGRAPHER: Going off the record at 22 3:07 p.m This madcs the end of tape two. 23 (Discussion held off the record.) 24 THE VIDEOGRAPHER: We're back on the record at 2 5 3:09 p.m. This marks the beginning of tape three. 33 (Pages 251 to 254) PROSE COURT.REPORTING AGENCY, INC. (561) 832-7506 EFTA01107864 Page 255 Page 257 1 BY MR. CR1TTON: 2 Q. Jane Doe 7, do you believe that you've lost 3 . any money; that is, have you lost any wages, jobs as a 4 result of your having been to Mr. Epstein's home? 5 MR. HOROWITZ: Form. 6 THE WITNESS: No. 7 BY MR. CRITTON: 8 Q. Okay. Do you believe you have lost the 9 ability to earn money in the future as a result of 10 having been to Mr. Epstein's home? 11 MR. HOROWITZ: Fenn. 12 THE WITNESS: I do believe I could have got a 13 lot better grades if I wasn't going through this 14 all of college. 15 BY MR. CIUTTON: 16 Q. Well, in high school it looks like you, and 17 particularly your senior year after you alleged in part 18 that you stopped seeing Mr. Epstein, you got almost all 19 A's and a few Ws; did you not? 20 A. Yes. 21 Q. Okay. And it appears in looking at least to 22 your junior and sophomore years is your grades after you 23 stopped seeing Mr. Epstein, at least you say you stopped 24 seeing Mr. Epstein improved substantially; is that true? 25 MR. HOROWITZ: Form. 1 working? 2 A. Yes, !worked for my dad and my dad's friend 3 in the aMbusiness. 4 Q. licnnti• tit was real life experience? 5 A. Pretty much. 6 Q. All right. And what kind of grades did you 7 get at 8 A. I just got average grades, l think. 9 Q. B's, A's and B's? 10 A. Yeah, hire Ws. 11 Q. What was your grade point from 12 A. I don't remember. I think it was111 13 know. 14 Q. How about since you've been ate what's 15 your grade point there? 16 A. I think it's around like a 2.8 or 2.9. 17 Q. So it's Ince a B minus? 18 A. Yeah. 19 Q. 3.0 is a B, so you are almost at a B? 20 A. Yes. 21 Q. And would you describe yourself - if someone 22 described you as a party animal; would that be accurate? 23 A. No. 24 Q. So you rarely go out to clubs, to bars? 25 A. I mean I go out, of course, I'm in college, Page 256 1 THE WITNESS: The only reason why I got all 2 A's is because l had O1T. 3 BY MR. CRTTTON: 4 Q. What's on? 5 A. On-the-job training where they let you out of 6 school earlier for three hours. 7 Q. Well, in looking at your transcript from 8 twelfth grade, it looks like you took English 3 -- Pm 9 sorry, English 4, you got a B. That's not OJT, is it? 10 A. No. 11 Q. American economics, that's not OJT, is it? 12 You got a B in that? 13 A. Uh huh. 14 Q. Correct? 15 A. Yes. 16 Q. TY production, you got an A in that? 17 A. Yes. 18 Q. And then you had Work Experience 2, and three 19' other O./Ts that you all got A's in, correct? 20 A. Yes, 21 Q. And you took - you did get one l in American 22 Political Systems, I see that, but all of your work 23 experience and Offs you got A's in, correct? 24 A. Yes. 25 Q. And OJT is where you learn, you are out 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 258 but Pm not a party animal. I still got my schoolwork done and do all my responsibilities that I have to do. Q. Okay. Just berause you are a party animal doesn't necessarily mean you don't do your work. Let me ask it more this way. YOU go out with your friends two to three, four times a week, might go to a club, to a bar or something hie that and hang out? Yes. Usually go out every weekend? I mean yeah, sometimes. Has that been hue both since you have been at and since you have been at M? A. Yes. Q. This spring break you went to Key West. Where did you go last spring break? A. Key West. Q. Did you stay at Nick's house again? A. No. Q. Where did you stay at that time? A. Four or five of us split a hotel there. Q. Very common for college kids to go down and stay a week and split a room and put a bunch of people in? Yes? A. Yes. • Q. You partied every night when you were down A. Q. A. Q. (561) 832-7500 34 (Pages 255 to 258) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107865 Page 259 there just like all the other college kids do? 2 A. Yes. 3 Q. Did you ever feel so depressed or anxious or 4 self-conscious or one of the times that you were not 5 eating or sleeping during spring break? 6 A. I was actually happy to get away from Orlando 7 and get away from everything, so that was kind of like 8 me getting way from everything was going on spring break 9 a taking trips. It was like me getting away from 10 everything. 11 Q. My question to you was did your depression, 12 anxiety, self-consciousness, feeling disgusting, having 13 flashbacks and not being able to eat and sleep, memory 14 problems, did any of those symptoms cause you not to go 15 on a spring break since you've been in college? 16 MR. HOROWITZ: Form. 17 THE WITNESS: No, that was why l went on 18 spring break was to get away from everything. 19 BY MR. CRITTON: 20 Q. Okay. And in the summer you are going to 21 Italy for a month. 22 A. Yes. 23 Q. Is that another escape so you can get away 24 from things? 25 A. No, it's just something I always wanted to do 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 261 A. No. I mean I would have to stay late. My reason for working there, it was an internship. Q. But you got paid too? A. Yes, I got paid, but I had to work in a hospitality establishment for my internship and I had to do three internships, so that was my reason for working. Q. What did you — I'm sorry, what do you plan to do when you finish? A. I honestly have no idea, but hopefully get a job. Q. You have bola and now aS a minor: A. Llh huh. Q. Have you started looking for a job at all? A. No, not now. Q. Have you tried to do any internships through school where you could ultimately move into, like Cheyenne, is it a chain or is it just a sole building? A. It's actually closed down now. Q. All right. Have you talked to any other restaurant chains or any other hotels or hospitality type situations to see if you could get an internship so you could get into the program and work your way up? A. No, because I'm leaving for Italy, so I — there is no point in me starting to work somewhere now. Page 260 I. is study abroad. 2 Q. And how about separate and apart from last 3 summer, you stayed up in Orlando. Were you still in 4 school, or this past summer, 2009, did you stay in 5 school? 6 A. Yes. 7 Q. Okay. And did you work during that time 8 period? 9 A. Last summer, I think I worked at Cheyenne's. 10 Q. Cheyenne's is like a bar, saloon? 11 A. Like a restaurant. 12 Q. Restaurant. And what do you do there? 13 A. I was just waitressing. 14 g How long have you worked there? 15 A. I worked there for about a year. 16 Q. You make like a minimum wage plus tips? 17 A. Yes. 18 Q. And in addition to doing your waitressing, 19 were you also in college; that is, were you taking some 20 courses? 21 A. Yes. 22 Q. All right. And as well, would you go out 23 with this last year, Jane Doe 4 is with you hi '08, 24 so this last year you would go out with your friends or 25• stay out late when you finished your shifts? 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 262 I want to wait until I get back. Q. So when you get back from Italy, you will have to then start looking for a job? A. Yes. Q. Do you plan to return to Orlando or do you plan to return home? A. I don't know yet. Q. What have your parents said, or I guess you are an adult, so you can decide what you want to do, right? A. Yes. Q. But you have made no plans? A. No, not yet. Q. Is there anything, is there any activity that you haven't done as a result of what you claim are injuries or damages you sustained from being at Mr. Epstein's home? Is there anything you haven't done? A. I don't really know. Q. You can't think of anything? MR. HOROWITZ: Form. THE WITNESS: I mean I don't know. BY MR. CRTITON: Q. All right As you're sitting here, you can't think of any activity or any trip or any school that you have not done or a course that you haven't taken as a 1561) 832-7500 nes.w.o.sea....cotadva. 35 (Pages 259 to 262) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107866 Page 263 1 result of having been at Mr. Fpoein's home; is that 2 correct? 3 MR. HOROWITZ: Form. 4 THE WITNESS: Yes. 5 BY bollt. CRITTON: 6 Q. Let me show you Salt — are we on 7 Exhibit 4? 8 (The document was marked Defendant's 9 Exhibit 4 for identification.) 10 BY MR CRITTON: 11 Q. All right, let me show you Exhibit 4. Can 12 you — 13 A. I see you guys have access to my MySpace and 14 Facebook. 15 Q. My question is do you recognize that photo? 16 A. Yes, Id°. 17 Q. And who is that depicted in the photo? 18 A. That's.. 19 Q. And? 20 A. And me. 21 Q. All right. And where were you at the time? 22 A. We wore — it was Halloween. We were 23 somewhere for Halloween. 24 Q. All right So is it, Halloween is usually, I 25 think it's October 30th? Page 265 1 MR. HOROWITZ: I didn't raise my eyes. I said 2 she was responding to your question. 3 You wanted her to say that she could still 4 haveagoodtime- 5 MR. CRITTON: Let Rachel read the question 6 back. Don't use up my time. 7 (A portion of the record was read by the 8 reporter.) 9 BY MR. CRITTON: 10 Q. Let me repeat the question so ifs clear. 11 Exhibit 4 depicts you and out at 12 Halloween in costumes drinking 27 days after the police 13 interviewed you, and you told your parents for the first 14 time what, at least a wuncated version of what occurred 15 at Mr. Epstein's house, right? 16 A. Yes. 17 Q. And you were able, certainly not just 18 Halloween, but before that, after that you continued to 19 party and go to parties, correct? 20 A. I told you I used that, like me going to 21 parties has nothing to do with my anxiety and all of 22 that. 23 It's me trying to get, just trying to get ova 24 everything and hang out with my friends and forget about 25 everything that was going on. Page 2€1 1 MR. HOROWITZ: Every year. 2 BY MR. CRITTON: 3 Q. Every year, or 3Ist, whatever it is. Probably 4 the 31st So that would have been October 3Ist That 5 would have been approximately 27 days after the police 6 took your, or interviewed you in the beginning of 7 October of 2005; is that correct? 8 A. Yes. 9 Q. So you were still able to go out, go to 10 parties, do those kinds of things even after the police 11 interviewed you? 12 A. A lot of times l use drinking as like a way to 13 help me forget about what happened and forget about, you 14 know, the stress I was under because of it and about the 15 whole thing. 16 MR. CRITTON: Okay. I'm going to move to 17 strike as nonresponsive. So let me have Rachel 18 read the question back to you and see if you can 19 answer my question. 20 MR. HOROWITZ: That was responsive. 21 MR. CRITTON: Yeah, right. 22 MR. HOROWITZ: It's not the response you 23 wanted, but it's responsive. 24 MR. CRITTON: Stop rolling your eyes or 25 raising your eyebrows in support of your position. ObIRIOgietuAo...4?....4.citadareasmt.cacangde.4".. (561) 832-7500 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 266 Q. Before you ever went to Mr. Epstein's house, you hung out with your friends, right? A Yes. Q. Before you ever went to Mr. Epstein's house, while you may not have taken drugs, you did drink alcohol, didn't you? A. Not really. Q. So if people say before you ever went to Mr. Epstein's you never had alcohol or you had alcohol — I've got to start again. Is it your testimony that you never drank alcohol before you went to Mr. Epstein's? A. I don't remember if I ever drank or not, but it definitely wasn't like I do now. Like I wasn't partying. I might have had a beer or two beers, but I don't really remember. I remember starting to chink around my junior year of college. Q Olcay. A I mean, sorry, high school. Q. And is it now your testimony that you arc relating your drinking because you went to Mr. Epstein's? A. Pm not relating. It just helps me cope with eve2thirsiand forjet about it. 36 (Pages 263 to 266) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107867 Page 267 1 Q College kids are notorious for drinking, 2 right? I mean kids drink in college? 3 MR HOROWITZ: Form. 4 IIIE WI NESS: Yes. 5 BY MR. CRITTON: 6 Q. • All right. And you drink and you drink to 7 excess from time to time, just like other college kids 8 do? 9 A. Yes. 10 Q Okay, because your college experience is very 11. similar to what other college kids' experience is, from 12 what you've observed, true? 13 A. I don't think ifs half as similar as what 14 other college kids had to go through. And if they had 15 to go through this, Fm sure they would drink too in 16 excess. 17 MR- CRITTON: I'll move to strike as 18 nonresponsive. 19 BY MR. CRAYON: 20 Q. My question to you is other college kids go 21 out and party two, three, four times a week; that's not 22 unusual, is it? 23 A. I mean some do, some don't. 24 Q. All right. And you are with a crowd that does 25 and you like to do that, don't you? Page 269 1 BY MR. CRITTON: 2 Q. What did I say? 3 A. Faoebook. 4 Q. Facebook, okay, MySpace. Do you still have a 5 MySpace account? 6 A. I do. 7 Q. Do you have a Facebook as well? 8 A. Em sure you guys know. Yes, I do. 9 Q. I get to ask questions. I don't even know 10 what I know sometimes. You still use Facebook? 11 A. Yes. 12 Q. And is it still — what's your — what's the 13 word that you key into if someone wanted to look at your 14 MySpace? They would look at what? What would they have 15 to print in? 16 MR. HOROWITZ: Form. 17 THE WITNESS: What do you mean? 18 BY MR. CRITTON: 19 Q. What do you use as like your call — I should 20 know this, as your location. There is a word for that 21 and I can't — it says Jane Doe 7 on it, but what would 22 I type in to come to your MySpace page? 23 MR. HOROWITZ: Are you asking her for a 24 password? I don't think she has to give you that. 25 MR. CRITTON: No, I'm not asking for a 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 268 MR. HOROWITZ: Form. THE WITNESS: I mean I like to hang out with my friends and drink. BY MR. CRITTON: Q. All right. And you have described what your symptoms are after the last time you saw Mr. Epstein as being — lees see what you described it -- as depressed, anxious, felt disgusting, self-conscious, flashbacks, can't eat and sleep. Let me show you Exhibit 5. MR. HOROWITZ: I'm going to object to these exhibits, particularly under rule 26. You guys got to turn this stuff over. You can't just come to a deposition with these things. And you haven't produced tin (The document was marked Defendant's Exhibit 5 for identification.) MR. CRITTON: Here. MR. HOROWITZ: Take a look at this. BY MR. CRITTON: Q. Do you recognize this as being part of your Facebook space from the 2005 time period? MR. HOROWITZ: Form. THE WITNESS: No. It's part of my MySpace. Page 270 1 password, but just to get on your Facebook. 2 THE WITNESS: You have to fiend request me. 3 BY MR. CRITTON: 4 Q. I'm sorry? 5 A. You have to friend request me. 6 Q. If I just typed in Jane Doe 7, would your name 7 come up under MySpace? 8 A. Yes. 9 Q. Same thing with Facebook? 10 A. Yes 11 Q. And then you would decide whether you want me 12 to be your friend? 13 A. Yes. 14 Q. And I would be pretty confident that if I 15 wrote to you, you would say no, right? 16 A. Probably, yes. 17 Q. All right, good. Let's stick with Exhibit S. 18 This is your Faceboolc? 19 A. My MySpace. 20 Q. I'm sorry, MySpace. It has Jane Doe 7's 21 blurbs, which means that you would have created that 22 yourself, tight? 23 A. Yes. 24 Q. Could you read for the ladies and gentlemen of 25 the jury what you have under your blurb? (561) 832-7500 37 (Pages 267 to 270) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107868 Page 271 Page 273 17 18 19 20 21 22 A. Where is my blurb at? Q. Under the Welcome. A. This is ridiculous. I mean everybody has a MySpace. Q. I'm just asking you to read it, nufam. A. quote. Q. All I'm asking you is to read it. I don't want you to editorialize, please. A. I mean I see how you are going to turn everything around, so — Q. Please continue readin: A. Page 272 6 Q. And if you go over to page two, you say "Who rd like to meet" That's also what you wrote; Is that true? 9 A. Yes. 10 Q. Read to the ladies and gentlemen of the jury 11 what you put in December of '05, or at least what was on 12 your MySpace account in December of '05. 13 A. "I like guys who are fun and outgoing. Hike 14 guys who like to go out but at the same time don't mind 15 staying in and watching a movie. Being too serious or 16 conceited is a turnoff. I don't like guys that are 17 really jealous either. I don't like getting hurt, so 18 Pm not one to get attached to one guy quickly. I 19 believe there is someone for everyone. Ws just a 20 matter of them finding you? 21 Q. Look on the pictures or page two. Do you get 22 to choose the pictures that you put on MySpace? 23 A. Yes. 24 Q. Okay. So like the Dior one would be something 25 you would have chosen and put in? 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 A. Yes. 2 Q. Where the lady is buying on her back with the 3 foot on maybe the pool attendant, is that a picture tha 4 you would have chosen? 5 A. Yeah, I was a fan of Paris Hilton. 6 Q. Is that Paris? 7 A. Yes. 8 Q. All right. The Jane Doe 4 again on page two, 9 is the Jane Doe 4 there, is that — that's not Jane Doe 4, is it, or is it or can y0u tell? A. Yeah, that's Jane Doe 4. Q Jane Doe 4 who? A. Jane Doe 4. Q Oh, that is Jane Doe 4, all right. Ova on page four, where it says, which is that? Q. All right. And over on page six there is an In fact, at the top of page six it has Jane Doe 4, 11/29105. "Jane Doe 7, you need to call me. I was drunk last night when you called and only remember bits of what was going on. Call me, love you all." Is that Jane Doe 4? A. Yes. Q. And under that is. also the same day. Page 274 1 Says "I'm having a party, party girl. Talk to 2 about it. Losay2u." 3 Is than who you took to Mr. Epstein's 4 home? 5 A. Yes. 6 Q. So did you continue to remain friends with her 7 fora period of time? 8 A. Yes. Q. Do you ever hear from her now? A. Uhuh. Q. I'm sorry? A. No. Q. Let me show you what I'll show you as Exhibit 6. (The document w MS marked Defendant's Exhibit 6 for identification.) MR. HOROWITZ: I'm going to again object in that the defendant to this day has not produced these things, despite their obligation under Wile 26. BY MR. CARTON: Q. Now this is again from your MySpace pag A. Yes. Q All right. And again, the photographs or 11e information say it's on_page one, that's you, correc 38 (Pages 271 to 274) REPORTING AGENCY, INC. (561) 832-7506 EFTA01107869 Page 275 Page 277 left side? A. Yes. Q. And in fact, this one says last login, 7/14/2006. Does that mean that's the date, that is tlx: 6 last time you would have logged in to this? 7 MR. HOROWITZ: Form :3 THE WITNESS: At that time. 9 BY MR. CRITTON: 10 Q. All right. It says "Jane Doe Ts interests. 11 If you go to page two, it has Jane Doe Ts interests. 12 This is now, this is you on July 14 of '06 13 that you would have beeii.lis would have been the 14 end of your first year at 15 A. (Witness nods head up and down.) 16 Q. Correct? 17 A. Yes. 18 Q. Did you stay up in Orlando during that time 19 period? 20 A. Yes. 21 Q. All right. What does it say Jane Doe Ts 22 interests are, general? Could you read that to the 23 ladies and gentlemen of the jury? 24 A. "I love anything on the water and getting a 25 tan. I rode horses since I was like four and still love 1 A. Yes. 2 Q. All right. And then hanging out in the lofts 3 pool. Lofts is where you were living at the time? 4 A. Yes. 5 Q. The guy, do you know him? 6 A. Yeah, he's a friend of mine. 7 Q. Boyfriend or just a guy friend? 8 A. Just a friend. 9 Q. It says "Getting some sun in South Beach." 10 The picture on the right, who is that? 11 A. Me and. 12 Q 13 A. Yes. • 14 Q. Is that when you had met Mario? 15 A. Yes. 16 Q. All right. Pictures on.page three, and again, 17 let me, if I go back to page two where it gives a little 18 history of yourself, again, 19 again, that's what you put on Facebook, correct? 20 A. IvIYSPace• 21 Q. I'm sorry, MySpace. All right, and then the 22 pictures on page four, those again were ones that you 23 chose, true? 24 A. Yes. 25 MR. HOROWITZ: Bob, how is it that you didn't Page 276 1 it. I also like relaxing girls' nights out, surfing, 2 the beach, goofing off, partying, being in love, coming 3 up with funny dnmken sayings. I'm not going to lie. 1 4 like to watch football. I'm a huge Steele fan and I 5 like baseball. Watching the Steelers isn't too bad 6 either." 7 Q. Are you pretty active even today on Facebook 8 and MySpace? 9 A. Just Facebook. I don't use MySpace anymore 10 really. 11 Q. MI right. Over on, the bottom picture on 12 page two, who is in that picture? 13 MR. HOROWITZ: Form 14 BY MR. CRITTON: 15 Q. Can you tell? 16 A. Right here? 17 • Q. Pardon? 18 A. • 'tight here? 19 Q. No, the lower picture, it has three females. 20 A. Me and Jane Doe 4 and.. 21 Q. Jane Doe 4 ant ? 22 A. Yes. 23 Q. All right. Go over to page three. It has 24 pictures again. It has "A dangerous combo." Is that 25 you in the truck? Page 278 1 produce these things? I'm having a hard time, I'm 2 still sat of wrestling with this. 3 MR. CRITTON: If you want to file a motion, 4 that's fine, and I'll explain to the Judge. 5 MR. HOROWITZ: I want her not to answer any 6 questions about this stuff 7 MR. CRITTON: I think this is all impeachment 8 information anyway. 9 MR. HOROWITZ: I don't care, you have to 10 produce it. 11 MR. CRITTON: No, I don't 12 MR. HOROWITZ: Yes, you do. 13 MR. CRITTON: We will respectfully disagree. 14 BY MR. CRITTON: 15 Q. If you to to page II. 1.6 THE WITNESS: Do I have to answer this? • 17 MR. HOROWITZ: I don't know what the question 18 is, but l might tell you not to. 19 BY MR. CRITTON: 20. Q. On page 11 it has a Jane Doe 4 and it looks 21 Ifice the two of you were, or two faces arc hanging there 22 . with their tongues out. Who is that? 23 MR. HOROWITZ: Is that impeachment? 24 Don't answer it. You guys aren't playing 25 tinder the rules. You are not producing stuff that l-Lo..Coar-muwiac-J.kt....V. , %12.17.3.144g46faNNIAINISJosinh•OA "IMPIIMIWaia,'••••••• .(561) 832-7500 832-7500 39 (Pages 275 to 278) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107870 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 279 you have to. Don't answer it. BY MR. CRITTON: Q. Who is that, ma'am? MR. HOROWITZ: Don't answer it. MR. CRiTTON: On what grounds? MR. HOROWITZ: Because you are supposed to produce this. BY MR. CRITTON: Q. The next iS down where there is a picture and it says "Go fuck yourself;" 7/2/2006, who is that ma'am? MR. HOROWITZ: Don't answer it. Don't answer it. Bob, you need to produce this stuff. You can't just surprise people. BY MR. CRITTON Q. There is an in here. Who is please? MR. HOROWITZ: Don't answer it. BY MR. CRITTON: Q. Do you know a person named MR. HOROWITZ: All right. THE WITNESS: I'm not going to answer it MR. CIUTION: On what grounds? Page 281 1 Q. Do you remember who you did it for? 2 A. It says Kliman, I thirdc. 3 • Q. And is this the only form that you ever filled 4 out for Mr. Kliman, Dr. Kliman? 5 A. I mean i filled out a couple of forms. 6 Q. Was it testing or was it like background 7 information on yourself? 8 A. I think both 9 Q. I'm sorry? 10 A. I think both 11 Q. Okay. And just so I'm — in looking at this, 12 it looks like what you did is you blacked out any 13 portion or kind of circled any aspect that you felt was 14 applicable to you; is that how you answered these? 15 A. Yes. 16 Q. Okay. Would you consider your intellectual 17 ability to be above average? 18 A. Td like to think I'm smart. 19 Q. Okay. My question is do you rate your 20 intellectual ability as above average? 21 MR. HOROWITZ: Form 22 THE WITNESS: Is that on here? 23 BY MR. CRITTON: 24 Q. Can you just answer my question? 25 A. Yes. Page 280 1 BY MR. CRiTTON: 2 Q. I'm not talking about tins exhibit if you 3 know somebody named 4 MR. HOROWITZ: Go ahead and answer it. 5 THE WITNESS: What are you talking 6 about? 7 BY MR. CRITTON: 8 Q. Do you know a girl named that was a 9 friend of yours? 10 A. When? 11 Q. 2006. 12 A. Yes. 13 Q. Who is, what's her last name? 14 A. I think it's=, if that's the girl you 15 are talking about. 16 (The document was matted Defendant's 17 Exhibit 7 for identification.) 18 BY MR. CRiTTON: 19 Q. Let me show you Exhibit 7. Do you recognize 20 what Exhibit 7 is, ma'am? 21 A. Yes. 22 Q. What is it? 23 A. My psychological social history. 24 Q. And when did you do this? 25 ±Jdmftren L ber _ Page 282 1 Q. And if you look at question 18, you consider 2 your intellectual ability above average, right? 3 A. Yes. 4 Q. Never held back in school, you made mostly A's 5 and B's, right? 6 A. Yes. 7 Q. Never had trouble in school, never had trouble 8 learning to read? 9 A. No. 10 Q. Did you have a little trouble with math? 11 A. Yes. 12 • Q. Okay. Neither your peers, none of your peers 13 ever teased you, made fun of you while you were in 14 school, correct? 15 A. No. 16 Q. And when you were in high school, were you a 17 cheerleada'? 18 A. Yes. 19 Q. Howniany years? 20 A. I think for two years. i did basketball 21 cheerleading. 22 Q. In what, your junior and senior year? 23 A It was my sophomore and junior year. Q. Sophomore and junior year, all right. Were 25 you in any clubs, any extracurricular activities? 40 (Pages 279 to 282) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC.. ( 561) 832-7506 EFTA01107871 Page 283 Page 285 A. No. 2 Q. Did you play lacrosse? 3 A. !didn't actually play for tern. I tried out 4 for the team, but I never Q The club team? A. Yeah, but I never played on the team. 7 Q. What else did you do other than cheerleading? A. I just did track for like, fora year. 9 Q. Which year? 10 A. I think it was my sophomore year. 11 Q. Student council? Were you on student council? 12 A. No. 13 Q. Did you do any kind of volunteer work, helping 14 other people? 15 A. I mean I didn't do any volunteer work, no. 16 Q. Did you do any volunteer work in college? 17 A. Yeah, I was part of where like we had this 18 hospitality group and I like donate to them and stuff. 19 Q. What do you mean you donate? You donate -- 20 A. Money to them. 21 Q. More importantly, did you donate time? Did 22 you go and work for any charities like boys' club, 23 girls' club, any type of church or other nonprofit 24 organization during the time you've been in Orlando? 25 A. I mean I had a MI load of classes and I was 1 A. I do like marketing and promotions. 2 Q. In what way? 3 A. Just like sampling products and promoting 4 products. 5 Q. What do you mean sampling products? Do you 6 get paid to drink liquor? 7 A. You are not allowed to drink at the job. 8 Q. What are you sampling then? 9 A. I give other people samples of different 10 liquors so they can try it 11 Q. Do you go to like ABC Liquor store or Total 12 Wine or someplace like that? 13 A. We go to bars and restaurants. 14 Q. What kind of products do you push? Talking 15 like scotch and bourbons or you are doing wines? 16 A. I do American Honey and Malibu and Jameson. 17 Q. As pan of the marketing, do you dress up for 18 this? 19 A. Yes. 20 Q. What do you wear? 21 A. We have to wear cowboy boots, a skirt, and 22 then just a shirt that says American Honey on it. 23 Q. Is it kind of like a modeling gig in addition 24 to the marketing? 25 A. Sort of yes. Page 284 1 working. I don't have time to, l mean like do a lot of 2 stuff. 3 Q. How many hours do you take right now? 4 A. Right now is my easiest semester. I'm taking 5 three classes. 6 Q. Three classes? A. IA huh. 8 Q. How many hours is that? 9 A. Lae twelve. 10 Q. Twelve hours or nine? 11 A. Time. Yeah, nine hours. 12 Q. How many days do you go to school? 13 A. Tuesday and Thursday. 14 Q. So all your classes are on Iliesdays and 15 Thursdays. Are you working at the current time? 16 A. Yes. 17 Q. Where are you working? 18 A. I'm worldng with my dad and I'm also working 19 and Fin trying to start like a business of my own, and 20 I'm also working for three different liquor companies. 21. Q. 'three different what? 22 A. Liquor companies. 23 Q. Liquor companies? 24 A. Yes. 25 Q. What do you do for them? (561) 832-7500 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 286 Q. And your skirt, short skirts or calf lengths or cowboy skirts? A. Just normal size. They don't give any size. Just normal jeans skirt. Q. Is that what you are doing in terms of with the liquor? A. Yes. Q. And how many days a week do you do that? A. Whenever I get scheduled for it. Q. How many times a month would that be? A. Probably about two times a week, three times a week Q. And then you said that on the — you help your dad. That's through the interact sales, right? A. Yes. Q. But you have free time, don't you? A. I mean everybody has free time. Q. Okay. At least again, this was on December 5th of '08, it says which of the following have you used, and of the drugs you listed marijuana, right? Which you told me earlier today. I'm on 52. A. Uh huh. Q. Do you see that? It says, "Has there ever been a time in essence you drank too much alcohol?" You say "Yes, on more than several occasions," 41 (Pages 283 to 286) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107872 Page 287 which Is consistent with what you told me, and you also 2 told me you drink several times a week, all of which 3 would be true, correct? 4 k Yes. 5 Q. At this time it says you were single, but 6 involved in an intimate relationship. 7 Who was that relationship with? 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 288 b 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 42 (Pages 287 to 290 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107873 Page 291 Page 293 2 3 4 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 3 1 5 6 I 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 1 2 3 4 5 6 7 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 292 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 294 sba , ..0•44#4,64.4, 43 (Pages 291 to 294) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107874 Page 295 Page 297 1 1 2 2 3 4 5 6 6 7 8 8 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 MR. CRITTON: Let's take a break for five or 21 21 ten. 22 22 THE VIDEOGRAPIIER: Going off the record at 23 23 3:54 p.m. 24 24 (A recess was taken.) 25 25 (End of Volume II) Page 296 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.N.4.1 ea+-1344. arssimerazraxesi 44 (Pages 295 to 297) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107875