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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CV-80119-MARRA/JOHNSON
JANE DOE NO. 2,
Plaintiff,
-vs-
JEFFREY EPSTEIN,
Defendant.
VOLUME IV OF IV
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
CONTINUED VIDEOTAPED DEPOSITION OF
JANE DOE NO. 4
Friday, February 12, 2010
10:10 - 12:27 p.m.
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
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Electronically signed by cynthia hopkins
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APPEARANCES:
On behalf of Jane Does I through 8:
4
STUART S. MERMELSTEIN, ESQUIRE
WIT2, P.A.
I
7
8
Phone:
E-mail:
On behalf of the Dekndant, Jeffrey Epstein:
to
MARK T. LUTDER, ESQUIRE
El
LUTTIER & COLEMAN, LLP
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Phone:
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ALSO PRESENT:
n
ShashaQuimby,Videograpixe
Visual Evidence, Ineaporated
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PROCEEDINGS
Deposition taken before Cynthia Hopkins,
Registered Professional Reporter and Florida
Professional Reporter, and Notary Public in and for
the State of Florida at Large, in the above cause.
THE VIDEOGRAPHER: This is the 12th day of
February, 2010. The time is 10:12 ant. This
is the videotaped deposition of Jane Doe No. 4
in the matter of Jane Doe No. 2 versus Epstein,
Epstein.
My name is Shasha Quimby. I am the
videographer representing Visual Evidence, Inc.
Would the attorneys please announce their
appearances for the record.
MR. MERMELSTEIN: Stuart Mermelstein for
the Plaintiff, Jane Doe No. 4.
MR. LUTT1ER: Mark Luther for the
Defendant, Mr. Epstein.
Thereupon,
(JANE 110E NO.4)
Having been first duly sworn or affirmed, was
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Page 454
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3.
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examined and testified as follows:
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THE WITNESS: Yes.
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THE COURT REPORTER: Thank you.
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DIRECT EXAMINATION
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BY MR. LUTITER:
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Q. Okay. Good morning, ma'am.
7
A. Morning.
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Q. You understand this is a continuation of
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your deposition —
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A. Yes.
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Q.
before? You understand you're still
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tinder oath?
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A. Yes, I do.
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Q. Same rules apply as the last depo?
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A. Yes.
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Q. Okay. If you need a break let me know.
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If I ask you a question you don't understand, let me
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know and 1 will explain it to you.
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Since your deposition on October 27th,
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have you had an opportunity to review the transcript
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of your deposition?
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A. Yes.
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Q. Were there any errors that you noted?
2 4
A. No. I haven't, well, I haven't gone through
u
t4
`~25
µ
the whole thing but there is a few things that 1
INDEX
WITNESS:
— DIRECT CROSS REDIRECT RECROSS
JANE DOE NO.4
BY MR. LUMER 455
NO EXHIBITS
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noticed.
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Q. What comes to mind that you noticed that
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was inaccurate or needed to be changed?
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A. A few misspelled words.
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Q. Okay. Other than misspellings, do you
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suppose there are any substantive mistakes?
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A. No.
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Q. And you say you haven't had a chance to
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review the whole thing yet?
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A. No.
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Q. Do you know how much of it you've done?
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A. 'guess pan one to part two.
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Q. Okay. When did you start looking at it?
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A. I've just been skimming through it since I got
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it in the mail.
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Q. Recently?
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A. Yeah. Just recently certain dates come in to
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mind. I was skimming through it like the weeks and
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stuff.
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Q. Okay. Have you reviewed anything else in
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preparation for the continuation of your deposition?
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A. Looked at anything else?
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Q. Uh-huh.
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A. Unh-unti.
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Q. Had any meetings with anybody other than
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A. I don't know. There was a few things that,
well, my parents already knew but just going over like,
like, I don't know, like, some of the questions. I
don't — just over the whole general deposition, not
like, I can't recall like certain questions or certain
things that we talked about. Just like general
deposition.
Q. What is it that you felt that they needed
to know about your deposition?
t
ell, I let them know about
and that's about it. I'm pretty sure.
Q. And by the way. did vou,did you discuss
with them
Q. Okay.
anYthh18
else that you discussed wt
A. Well, that's the only one thing that comes to
mind. I'm sure there's other things that we discussed,
but I don't remember what else. But that's like the one
thing that I can remember.
Q. You're aware that their depositions have
been taken?
A. Yeah.
Q. Have you talked to them since their
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your lawyer
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A. No.
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Q. — about your deposition? Talked to
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anybody else about your deposition?
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A. My parents.
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Q. When did you talk to your pm cub?
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A. I think — I don't remember what time. I'm
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not sure. Shortly after my deposition I think.
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Q. After your deposition back on, in
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October -
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A. Yeah.
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Q. — of '09?
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A. No, after. Was it — what did you just say
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the date of my deposition was?
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Q. October 27th, '09?
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A. Yeah.
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Q. It was sometime shortly after that before
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Christmas?
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A. I don't remember when I talked to them but I
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know I talked to them after my deposition.
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Q. And what was the purpose of that
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discussion? What did you discuss?
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• A. Just to go over some things that I thought my
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parents should know.
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Q. Like what?
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Page 460
depositions were taken?
A. Yeah.
Q. And what was the substance of those
conversations?
A. I don't know. How are you doing today? What
are you doing tomorrow? What are you doing today?
Q. What did you ask them about their
depositions in particular?
A. Nothing. I didn't talk to them about their —
they asked how it went, pretty much. But I know how a
deposition goes. I went through one. So, I mean we
just discussed like a deposition in general, like what,
like how the experience is.
Q. You say they asked how it went, or you
asked them how it went?
A. No, I asked. I know where depositions come
fromMigtilliain
things, like, how
you guys
and that's about it.
Q. Anything else you discussed with them
about their depositions?
A. No.
Q. Have you read any depositions in this case
other than your deposition?
A. No.
Q. Have you read your parents' depositions?
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A. No.
Q. Have you been provided with transcripts of
any of the depositions?
A. No.
Q. Have you spoken since your last deposition
with any other Plaintiffs who have claims pending
against Mr. Epstein?
A. No.
Q. Have you communicated in any way with any
other Plaintiffs who have claims pending against
Mr. Epstein?
A. No.
MR. MERMELSTEIN: You mean before then?
THE WITNESS: Like have I talked to them?
MB. MERMELSIEIN: Before or after the
deposition?
MR. LUITIER: Since your deposition on
October 27.
THE WITNESS: Like have I talked to them?
BY MR. DOTTIER:
Q. Yeah. Let me clarify what I mean by
communication. By communication I mean any form of
communication whether that's talking to them, some
computerized form of communication, whether it's
Facebook, Twitter, e-mails, text, anything like that
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Q.
A.
Q. Does
have a last name?
A. I don't know what his last name is.
Q. And what was her relationship with-?
A. Friends.
Q. And what did you-all do while you were
there?
A. Nothing. We went withldsgi al and we — in
part we went and saw the cit
n, sightseeing.
Q. How old is.
roughly?
A. How old is w1201._
Q. How old was
roughly?
A. I don't know, probably like 40, 50's, maybe.
I don't, 30's, 40's. I don't know.
Q. That's a 20 year gap from 30 to 50.
A. I don't know how old, I don't know how old he
Page 463
there for — never been there. So, we went up there'
with some friends.
What was her friend's name?
Q. Is he closer to 50 than 30?
A. No, probably not.
Q. Was he married?
A. No.
Q. Have kids?
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whether you wrote something to them.
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A. Yeah. lam sure I talked to Jane Doe No. 7
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but I don't know if I lanced to Jaw Doe No. 3 after my
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deposition. I might have talked to Jane Doe No. 3.
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Q. When was the last time you talked to Jane
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Doe No. 7?
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A. Probably like two days ago.
Q. And for what purpose did you talk to her
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two days ago?
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A. She told me about her weekend.
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Q. ligere
is Jane Doe No. 7 living now?
A.
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Q. Have you ever traveled out of the State of
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Florida with Jane Doe No. 7?
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A. Yeah.
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Q. Where did you travel?
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A.
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Q. And when was that?
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A. I think it was my junior summer. Yeah, my
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junior summer. My kali:beef in college in stammer.
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That's when I lived in
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Q. Okay. And why did you-all go
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A. Why did, why did we go
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Q. Yeah. Why did you go
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A. Her friend invited us to go
we went
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A. I don't know.
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Q. Ever been married?
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A. I don't know.
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Q. Have a job?
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A. I don't Imow. I'm sure he had a job but I
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don't {mow what it was.
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Q. What did you know about hint?
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A. Nothing. I really didn't -- I mean, he
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Iliriutd she invited m
like four of our, of
to go to, or invi
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No. 7 to go to
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our friends. l Mini( it was five of us that went down
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there. And pretty much I just hung out with my
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girlfriends. I didn't talk to him.
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He was Jane Doe No. '7's friend. You know,
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he wasn't really around. And whenever he was, it
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wasn't !didn't really talk to him. I was more
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hanging put with my frill
I was talking to
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him trying to get to know
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Q. Did you -- where did ou-all stay?
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A.
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Q. And did, does
buying you-all
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anything of value?
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A. We went to.
and he bought us all like a
24
dress to wear for that -- whenever we went out that
25
night.
PROSE COURT REPORTING AGENCY,
Electronically signed by cynthia hopkins
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Q. And where did you-all go out?
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A. I don't remember what it was called.
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Q. Did he pay all the expenses for the trip?
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A. Yeah.
5
Q. Did anybody in your group compare him to
6
Mr. Epstein?
A. No.
8
Q. Have you ever made the statement that he
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was like Mr. Epstein?
•
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A. No.
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Q. Other than the trio with lane Doe No. 7
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and your other friends
have you traveled
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anyplace else with Jane Doe No. 7 outside the State
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of Florida?
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A. No.
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Q. When was the last time you went outside
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the State of Florida?
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A. In December.
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Q. And where
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A. I went to th
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Q. And who did you go with?
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A.
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Q. That's
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A. Yes.
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Q. And he's still your boyfriend?
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A. Yes.
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Q. And how long were you gone?
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A. Around six or seven days.
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Q. Did you go with anybody else?
S
A. We met some friends there.
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Q. Your friends or his friends?
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A. Our friends.
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Q. And who was that?
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A. My fri
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Q,
is
last name?
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A
(phonetic), I think.
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Q. And how did you know her?
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A. Through...
14
Q. And was there any it
nIthesides
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A. auk Her friend =.
And 1,1know my
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friend
M
I
came too or this girl
came.
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Q. And was it a vacation?
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A. Yeah.
19
Q. What did you-all do generally?
20
ed at like an all-inclusive hotel in
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and hung out at the hotel, went out by the
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pool, went to the casino one night. I don't know if
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that's about it, vacation.
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. Did ou say it was an exclusive hotel in
25
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Electronically signed by Cynthia hopkins
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A. Yeah.
2
Q. What is the name?
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A. I don't know.
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Q. Can't be that name, right?
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A. Yeah, I don't know what it's called, though.
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Q. What caused you to say it was an exclusive
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hotel?
8
A. Because we had wrist bands on and we didn't
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have to pay for anything, except for food or drinks.
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MR. MERMELSTEIN: You mean
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all-inclusive —
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THE WITNESS: Yeah.
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MR. MERMELSTETN: -- not exclusive?
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THE WITNESS: Yeah.
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BY MR. LUTHER:
16
Q. Okay. And there was a casino at the
17
hotel?
18
A. No.
19
Q. You had to go someplace else to go?
20
A. Yes.
21
Q. Who paid for this whole trip?
22
A. My boyfrienckatell,
yfriend paid for
23
some of the trip and
and
helped paid for some
24
of it because it was her Christmas present.
25
Q. Your boyfriend would be
.
Page 468
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A. Yes.
2
Q. And then what did II do?
3
A. AI Lig jth a
. helped pay for it too, her and her
4
boyfriend =.
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Q. Oh, was —
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A. It
Christrnas present.
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Q. -=
there, too?
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A. Yeah. He showed
. He had to work.
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Q. How dig.y.91 ;mow It
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A. That's= good friend.
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Q. So, these really were friends of
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as a result of you dating him you'd come to
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A. Yeah.
14
Q. You-all go around places together?
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A. No. We just went over Christmas.
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. Q. Okay. They live here in the area?
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A. Yeah.
18
Q. Did you have a good time on vacation:
19
A. Yeah.
20
Q. Anything bad happen on vacation?
21
A. No. What do you mean "bad?"
22
Q. Well, any bad event I don't mean dinner
23
was late. I mean, you know, somebody got hurt or
24
something like that.
25
A. Oh, somebody got hurt or somethine„.
_ aj
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Q. Yeah.
A. Oh, yeah. Somebody got hurt.
Q. What hap mj-
d?
A. My friend
she was going to walk off the
boat and she hit her shin on the deck, on the deck.
Q. Okay. Have you, have you trawled outside
•
an lace since the tri in December to
A. No.
Q. Have you traveled -- where you do
currently live now?
A. Well, I stay at my boyfriend's house
•
sometimes I will stay at
So, going back and forth between ere
until I figure out what I want to do, where I want to
stay, if I want to get my own place.
Q. Okay. So, your sister has a —
A. I go up to my parents' house too.
Q. If I remember correctly from the last
A. No. She has a house.
Q. A house. And so, you stay there part of
the time and then sometimes you stay at your
boyfriend's?
1
him now.
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Q. Okay. Well, describe what your current
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relationship is then between you and him.
4
A. Well, I think it was the whole issue of going
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through this whole deposition and being stressed out
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about it So, whenever I would go out, like I
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couldn't -- I wasn't even comfortable being out thinking
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that somebody was going to, like watching me or being
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paranoid.
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So, when we would be out together and we
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would be drinking, slot of this deposition and a
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lot of this whole thing that is going on with
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Jeffrey Epstein has brought a lot of stress on me.
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So, when I would drink like I would be
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angry and we would argue a lot more. But now like,
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that, a lot of this is almost over, it's gotten, you
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know, to the point, and after that whole thing it
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was an eye-opener for me.
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Q. The incident between you and IM
20
occurred before your deposition, correct?
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A. Yeah. But I know I had my deposition and, you
22
know, you guys were goizgcr had investigators going to
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my friends, going to my
my family, you guys,
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you know, were kind of harassing me, I felt
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Q. Well, the investigators went to your
Page 470
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st
Does he still have the same place in
that he had before?
A. Yes.
Q. Is there any pattern that you follow
there?
A. No.
Q. Majority of
is spent where?
A. Probably
10
Q. The last time we took your deposition,
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shortly before that deposition there had been s me
ncident between the two of u ant
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A. Yes.
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Q. Do you recall that?
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A.
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Yeah, nothing.
Q. Did you resolve whatever your differences
were with your boyfriend about that?
A. Yeah. Things are really good between me and
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Page 472
when?
A. Uh-huh.
Q. ilifear
—
A.
Q. At least a year before the deposition?
A.
w the exact date, but they
went to
sometime before my depositi.,,
Q. Yeah. But do you remember how far in
advance of your deposition?
A. How far in advance it was, no.
Q. How far before your deposition.
A. No.
Q. Do you remember
filing an
affidavit about it?
A. No. I know she filed.one, but I don't
remember the exagaws,s,
Q. Okay. Sea
called you and said
somebody came, wanted to ask her questions about —
A. Yeah.
Q. — your involvement with Mr. Epstein?
A. Uh-huh.
Q. One time?
A. I don't know how many times. I recall one
time, yes.
Q. She didn't tell you about more than one
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time, did she?
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A No. Did it happen more than one time?
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Q. Not to my knowledge., but --
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MR. MERMELSTEIN: Let, let Mr. Luther -
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MR. LOTTER: Other than that -
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MR. MERMELSTEIN: — ask you questions.
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THE WITNESS: Okay.
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BY MR. LUTTTER:
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Q. Other than that, what other claim did you
10
make that investigators were doing anything?
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knew i
that I went to high school with
A.
re going around to people that I
t
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asking questions about me and my frienisi.e were
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trying to get a hold of my ex-boyfriend,
And
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they were, I mean they were pretty much being ruthless
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about it, the whole, everything.
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Q. Basic, basically those investigators
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talked to the same people the police talked to,
19
right?
20
A. I don't know if ifs the same people.
21
Q. Well, you know the police had corn* out and
22
talked to all your friends, didn't you?
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A Did they?
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Q. Yeah. They called all of your friends.
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A. I don't know at that time who was my, hie —
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A. Nothing. It opened my eyes. I was, how, how
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much, this whole situation was aL"
me. I can't
Page 474
I don't know. I don't know who they, I don't know who
they all talked to back then.
Q. Just so, just so we're clear, you were
well aware of tbe fact that the police were out
interviewing a number of your friends, weren't you?
A. Were they? I'm sure but the friends that
Me —
MR. MERMELSTEIN: Just, just answer the
question to your knowledge.
THE WITNESS: Yeah.
MR LUTHER: Okay.
THE WITNESS: I got, like--
BY MR. LUTFIER:
Q. The police came and visited you, right?
A Yeah. I know they came and saw me but my
friends, are you referring to the people that, that, the
girls that went to Jeffrey's or are you talking about
the girls that didn't go?
Q. Anybody that you knew?
A. Yeah.
Page 475
let it ruin my life. I saw a change in my behavior,
like my attitude. It was making me stressed out.
It was making me emotional. Like I would
be happy one day, sad the next. You know, it was,
it was like tearing my relationship with my
boyfriend up, and we were getting in a lot more
arguments but, I mean, it was like I was bipolar. I
was happy one minute and upset the next. He was
like what's wrong with you.
And after this whole, after my deposition
and like after, like, talking to my family about
some things that, you know, some secrets that I had
hidden. And I was open with him and told him
things, it relieved a lot of things and it made me
become a stronger person.
And it helped me, like helped me through
it a little bit, helped me through the situation and
it made ow relationship stronger.
Q. Okay. So, your kind of moved on beyond
that now?
A. Well, I'm working on it.
Q. Have you been to see any psychologist or
psychiat
Page 476
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Q. My question is you're aware that he is not
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Q. Okay. My question is specifically --
A. I thought, no.
MR. MERMELSTEIN: Well, let him ask the
question.
THE WITNESS: Okay.
BY MR. LUTITER:
Q. My question is specifically directed to
whether or not you've seen any psychologist
A. No.
Q.
psychiatrist.
AIM Or I have seen Jeffrey — after my
deposition?
Q
A. Yeah.
Q. Okay. And you — before your deposition,
you went to see an individ
our lawyers sent
you to. I think his name is
He's the guy
that flew in from California to see
?
7 (Pages 473 to 476)
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Q. Do you, do you, do you 'mow him on a
23
friendly basis?
24
A. No. I never hung out with him out of the
25
office.
____....
PROSE COURT
Electronically signed by cynthia booklets
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Page 479
1
Q. Okay. Why — you went back to look at his
2
fish tank but do you see him someplace other than
3
his office?
4
A. No.
5
Q. Does your, does your boyfriend have some
6
relationship with him?
7
A. No.
8
Q. Are they in business together or anything
9
like that?
10
A. No.
11
Q. When you with went to see him again, did
12
you go alone?
13
A. Yes
14
Q. This visit two weeks ago?
15
A. Yeah.
16
Q. And the purpose of your visit was to go
17
see how be was doing, that is Mr.
18
A. Yeah, well, yeah, we didn't ha
ve like a
19
one-on-one, like, session or anything.
20
Q. What, did you just drop in the office?
21
A. Uh-huh.
22
Q. Did you have, do you have an appointment
23
scheduled, or you just happened to be there?
24
A. No, I didn't.
25
Q. Okay. So, you dropped in as friend?
Page 480
1
A. Yeah.
Q. And you were up there for some other
reason?
9
Q. So, you just ecided one day to drive down
10
to his office and see how he is doing?
11
A. Yeah.
12
Q. Any reason that you went to him other than
13
that?
14
A. No. I just know that he had a fish tank that,
15
that he had or whatever and I have a fish tank or my
16
boyfriend has a fish tank. So I like looking at fish
17
tanks. And he said he had it all hooked up and stuff,
18
so I wanted to go look at it.
19
Q. When did you fend out he had it all hooked
20
up?
21
A. Well, I know he got a fish tank from the last
22
time I went and saw him. He had an empty fish tank.
23
So, I wanted to go see if it was like all hooked up and
24
everything. I didn't know but I just kind of figured,
25
last time I went there it was calland hers set
i
i
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Page 481
everything up from the last time I was there. So, I
wanted to go look at it and see how it was progressing.
Q. If I understood your testimony originally,
you said he told you?
A. I didn't mean to say he told me. I was just
saying whenever I went there, he had an empty fish tank
and I know he was like working on getting stuff set up
for it.
Q. So, was it just happenstance or out of the
blue that you decided on this particular day you
would go by and drop
. SI
A
l was leavMa
and t was
taking=clown. And I was driving right by his office,
so I figured I would stop in.
40ien
Q yol ulthle
rs
availlin
A. No.
Q. All right. It WAS --
A. Just that day.
Q. It was just happenstance that you were
driving by and you said, well, you would drop in to
see —
A. I decided to stop by.
Q. -- what's happening?
A. Yeah.
Page 483
1
your last deposition, you had a desire at that time
2
or expressed a desire that you might want to become
3
a teacher?
4
A. Yeah.
5
Q. Is that still what you're thinking about
6
doing?
7
A. Yeah.
9
that you had been accepted at
to! --
Q. And did you tell us at u de
pion
10
A. For my Master's, yes.
11
Q. — the Master's program? Once you're
12
accepted in the program, do you have to enroll
13
within some period of tine of when you get accepted?
14
A. I'm sure. I don't know.
15
Q. All right. Did you — do you intend to
16
pursue the Master's?
17
A. Yeah.
think at •
1 was trying to
18
get my CIA at M. So, you have to enroll for your
19
Master's before you could sign up for your GA which is
20
Graduate Assistance Program. And I was waking to hear
21
back to see if I got in
kb I didn't. So, I really
22
can't afford to go to
Ifs too expensive. I
23
would mther go to
24
Q. But if you — okay.
25
A. So, I'm going to get my Master's.
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Page 482
boyfriend also goes to this
A. Ite did go there.
Q. Okay. You say that's did as in past
tense. Does he no longer go there?
A. No.
Q. When did he stop going?
A. I don't
ow.
A. No.
Q. And do you know why he stopped going?
A. No.
Q. Does he go to somebody else now?
A. No.
Q. You went to see, I think you said in your
last deposition there were times tialswent with
your boyfriend and drove to this
office
with hint is that right?
A. Yes.
Q. But all the times you went with him were
for matters dealing with your boyfriend?
A. Yeah.
Q. Okay. What, have u — if I recall from
Page 484
1
Q. The idea of being that if you got in the
2
Graduate Assistance Program, that they had would in
3
essence pay you?
4
A Yeah. Then I would have pursued going to
5
but since that didn't work out; I didn't get my
6
GA, I decided to take off fora little bit and now I
7
want to pursue it in, my Master's in the fall.
8
Q. Okay. When did you find out you didn't
9
get in the Graduate Assistance Program?
10
A. Well, you're supposed to hear back I think it
11
was like the end of- I don't remember. The end of
12
July, like the last month of July or something or the
13
beginning of August.
14
Certain dates, certain — like whatever
15
you, position you like signed up for, I think it had
16
a different dates of whenever you would hear back or
17
you, yeah, different dates or something like that.
18
So, 1 don't ;mow. I think one was the end of July
19
and the other one was maybe the beginning of August.
20
Q. Of '09?
21
A. Yeah.
22
Q. And when you — had you applied anyplace
23
else until you heard about whether you were going to
24
get in the graduate program or —
25
A. No. Because I knew if I didn't, that I would
9 (Pages 481 to 484)
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Page 485
try to look for a job fora little bit and play that
field out for a while, and then go back for my Master's
shortly after somewhere else.
Have you applied fora Master's degree at
A. No.
Q. Is that your intention?
A. Yes.
then you would get a Master's in what
A.
Q. Is that contingent upon you getting a
graduate assistance there too or no?
A. No.
F
OkayM,
you now
17
A. Yeah.
18
Q. -- I assume than
19
A. Yeah.
20
Q. And the Master's program you understand to
21
be, what, another year of study?
22
A. Yes.
25
can get involved in some •
in like a school district,
24
A. I will get it in
and then see if I
Q. And what are*
after that?
23
Page 487
/
business and I don't know.
2
Q. Would it be comet to say that you're
3
pursuing whatever it is you've decided you want to
4
pursue in life?
5
A. Yeah.
6
MR. MERMELSTEIN: Objection to form.
7
BY MR. LUTTIER:
8
Q. Ms. -- You don't feel like there's any
9
restrictions that have been placed upon you by what
10
you want to do?
11
MR. MERMELSTEIN: Objection to form.
12
THE WITNESS: What I want to do, no.
13
BY MR. LUTTIER:
14
Q. And if you wanted to go do something else,
15
you would go do it?
16
MR. MERMELSTEIN: Objection to form,
17
Calls for speculation.
18
THE WITNESS: Yeah.
19
BY MR. LUTTIER:
20
Q. Is there any particular reason you had a
21
interest in teaching?
22
A. (Witness shakes head.)
23
Q. You know, friends, relatives, anything
24
like that that were in it or --
25
A. No. Something that I, that I thought I would
Page 486
1
because I want to be a school teacher. But I want to —
2
I just want to have my Master's for myself. I just want
3
it, so.
4
Q. Well, you get paid more in the schools if
5
you have a Master's?
5
A. Yeah.
7
Q. And I think you told us the last time you
8
wanted to teach in the primary grades.
9
A. Yeah.
10
Q. I don't remember if it was kindergarten,
11
fourth grade, something like that?
12
A. Yeah.
13
Q. Still want you want to do?
14
A. Yeah.
15
Q. How long have you had an interest in
16
teaching?
17
A. When I graduated I wasn't really sure of wh
18
haanted to do. And I know, like, whenever I did
M, when I would worked there I did, worked with
20
little kids and I like, I like workine with little kids.
21.
And so when I graduat
22
was telling me because she's a teacher and she was
23
telling me about it and I just started like hinting
24
around about it and thought about it and I said, why
25
not. I didn't really know what to do with this
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Page 488
enjoy doing.
Q. Okay. What do you do about
these
days?
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Page 489
Page 491
1
want a big family, small family?
2
Yeah.
4
39
big or small?
medium.
kills°
5
ell
as what these days?
6
don't
ow, probably -- l don't know — two
'ca
noes
w,
MIlia:
7
kids..
8
thaZtit.
QQyLliviu
W
I
,h,
Okay.
have any habits
don't like?
10
11
A. No.
Q. There was a
w
u were —
12
A. Well, actually
Sometimes at
13
Q. Okay. How would
-- oh,
13
nighttime whenever I am like, sit down. He has got to
14
acterize
strike that. Do you and Mr.
have any
14
be running around and I am like, what are you doing.
15
intentions to get married?
15
Q. But would it be a fair statement to say
16
A. Yeah, I think so. We talked about it before.
16
that you and he enjoy each other's company?
17
Q. Okay. What's the — is he —
17
A. Yeah.
18
A. Ifs not like I'm a girl and trying to --
18
Q. You have fun together?
19
Q. Talking about it is one thing. Has he
19
A. Uh-huh.
20
ever fonnally asked you if you want to get married?
20
Q. You like to get up in the morning and look
21
A. No.
21
fen-ward to doing stuff with him?
22
Q. But you have had discussions about that?
22
A. Yeah.
23
A. Yeah. Well, he brought it up to me but I'm
23
Q. Tell me about his business.
24
not like, well, when are you going to do it.
24
111iLlatafattggvjj mean — I don't know.
25
Q. Should he ask you that question at some
25
I
. He's, I don't 'mow, busy
Page 490
Page 492
1
point in time, would you be inclined to get married?
1
right now, I guess. It's season right now. So, any
2
A. Yeah.
2
business out there right now trying to make it, if they
3
Q. Okay. So, you, this is somebody you think
3
are not making it in season right now then, I don't
4
you have found that is a special person for you?
4
know, it's not good.
5
A. Uh-huh.
5
2a
And what's his relationship with.
6
Q. Well, congratulations.
6
like?
7
A. Thanks.
7
A. Good.
8
And he hi --if! remember correctly, 1
8
Q. Are they close in age?
read somewhere
9
A.
..,
ysaLUISdc, yeah.
I
Q.
n
10
Q.
obviously lives locally
11
A. Yeah. They -- yeah.
11
somewhere?
12
Q. Okay. And what's the name of the
12
Yeah. No.
13
busineS,
13
14
A.
14
Q.
married?
15
Q. Would you be excited about getting
15
A. Yeah.
16
married?
16
Q. Got kids?
17
A. Yeah.
17
A. No.
18
4
Okay. How about kids? Do you third(
18
Q. Do you know his wife?
19
you're --
19
A. Yeah.
20
A. Yeah.
20
Q. Get along with her?
21
Q. Do you think you're a mom type?
21
A. Yeah.
22
A. Yeah.
22
Q. You met his parents?
23
Q. You would want to have kids?
23
A. Yeah.
24
A. Yeah.
24
Q. Where do they live?
25
Q. You have got elan about — I mean, you
25
A. His mom lives —and
his dad Hymn
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1
2
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4
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Q. They are divorced?
A. Yes.
Q. Not remarried?
A. Nape.
Q. No. Do you spend time with them?
7
A. Yet
8
Q. Like them?
9
A. Yeah.
10
Q. Has he met your parents?
11
A. Yes.
12
Q. Okay. He goes up toMM1
tias he
13
gone up their to see them in the trailer park and
14
stuff?
15
A. Yeah.
16
Q. Okay. They like him?
17
A. Yeah.
18
Q. So, everything is kind of lined up right?
19
A. Yeah.
20
Q. Okay. Do you work for the business too?
21
A.
and like when he'll
Or like he
24
will ask me to send something and 1 am at home, I will
25
send him something or send him something through e-mail,
1
Q. Okay.
2
A. But like there was like something for
3
Walgreen's management or something like that. I put a
4
resume together and sent it in, but other than that —
5
Q. And what would be the idea that you would
6
just work for them until you got into the —
7
A. Until, until I saved some money up so I can
8
pay for my — save money up so I can start — save my
9
money up so I can start my Master's in the falL
10
Q. Fall meaning?
11
A. This fall corning up in August. August of
12
'010.
13
Q. August of '010. But you're okay with the
14
fact that you're not actively employed at the
15
present time? That's doesn't bother you?
16
A. No.
17
Q. Okay. And you have got a game plan that
18
you're following?
19
A. Yeah.
20
Q. And you're really Mixt of looking for some
21
kind of hiatus job that would fill the gap between
22
now and when you go to school?
23
A. Yeah
24
Q. Is your physical relationship with
25
acceptable to you?
Page 494
but I don't work — lam not out there
l
1
2
3
Q. I guess the real question, do you get paid
3
4
a salary?
4
5
A. No.
5
6
Q. Do you have any kind of employment right
6
7
now?
7
8
A. No, not as of right now.
8
9
Q. Okay. When was the last time you were
9
10
employed?
10
11
A. When I thin
11
12
Q. Was
12
13
A. Yeah,
13
14
Q. Okay. So, that was what, '8; 08?
14
15
A. I think.
15
16
Q. Is that when you were living in
16
17
with Jane Doe No. 7?
17
18
A. Yeah.
18
19
Q. Okay. Okay. Are you actively seeking
19
20
employment or—
20
21
A. As of right now, yeah.
21
22
Q. What kind of stuff are you looking for?
22
23
A. Nothing. I mean, anything like on the
23
24
Internet like for employment. Trying to think. 1
24
25
haven't, the last time I did it was like a month also.
,.. 25
-----,—.--
Page 496
A. What do you mean physical?
Q. Sexual relationship?
A. Yeah.
Q. Do you — I think at the last —
A. Ifs better than what I would like it. It's
not on his part but on my behalf, I'm not, I am never
the aggressor. I am not aggressive like I should be.
And sometimes I want to, I just don't. I don't know
why. I just don't pursue things sometimes. And he
always has to pursue me, so it's not on his behalf.
It's on my behalf.
Q. I think at the last deposition you said,
and correct me if I am wrong. I might be wrong.
But that you and he were intimate two or three times
a week.
A. Yeah.
Q. Have there been times in the past when
you've been intimate with an individual as much as
once a day?
A. Uh-huh.
Q. The level of the degree of intimacy
between you and he is okay with you?
A. Yeah. Well —
Q. He, of course, would want, would want
more?
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1
A. I'm SUM Like there, just, yeah, ifs fine
2
with me. I mean there are sometimes where 1 want it. 1
3
just don't pursue everything, and he always has to be
4
the one to pursue me. So, lam sure be gets --1 don't
5
know.
6
Q. Has he indicated to you that your intimacy
7
level or performance is unacceptable to him?
8
A. No.
9
O. Okay. Since you graduated from -
10
have you undergone any surgery?
1
Q. What's your relatbosh:p -•
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Page 498
Page 500
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Q. Have you — when was the last time you
used any kind of, what I am just going to call an
illegal drug. And by that I mean the typical sort
of recreational stuff you hear, whether it was
Xanax, without prescription, Xanax, cocaine, heroin
or any of those things. When was the last time you
used any of that?
A. It would be a long time ago. I don't even
remember. Probably —
Q. Over a year?
A. Yeah.
Q. Couple of years?
A- Yeah.
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A. Yeah.
Q. Have you had any discussion with him about
his deposition?
A. No.
Q. Not even a little discussion that, lace
when you left today that maybe I know your
deposition is going to be taken today?
A. Like, I, I'm aware that he has a deposition.
Like all this deposition stuff, that I have to give a
deposition tomorrow, stuff like that.
Q. Do you know if he met with anybody about
his deposition?
A. No.
Q. You don't know or he didn't?
A. Ho didn't.
Q.
— what's
name?
A.
Q. And is
married?
Yes.
And does her husband live with her?
Page 502
1
Q. Okay. There was a time in your life when
2
you were younger that you used those drugs; is that
3
right?
4
A. Yeah.
5
Q. Is that all something you put behind you
6
now?
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Q.
9
A.
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Yeah.
Don't use them at all anymore?
No.
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Q. Whether marijuana?
10
A. No.
11
Q. Cocaine?
12
A. No.
13
Q. At one time, at one time did
use
14
some cocaine?
15
A. No.
16
Q. Mra
17
A. Uh-huh.
18
Q. Okay. So, drugs is just not part of your
19
life anymore, correct?
20
A. No, not that I — it's something that I, like,
21
in nv experimenting phase in high school that I tried.
22
Nothing that ever really
'
m
ton
t
23
Q. Okay. Now, Mr.
deposition is
24
Page 504
Q. Have kids?
A. Yeah.
Q. How many?
Q.
Q.
A.
Q. Do you like babies?
Oh-huh. Yes, sorry.
Id you describe your relationship
scheduled to be taken
you ay.:are2f that?
25
Q. Okay. Would you describe your
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Electronically signed by cynthia hopkins
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6183fieb3-b5a6-47c4-9336-1208fd1246(17
EFTA00723986
1
relationship your parents as being close?
2
A. Yeah. Yes.
3
Q. So, at the present time could your
4
relationship with your direct family members be any
5
closer than it is?
A. No.
Q. And ifs just you fa?
6
7
3
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. Have you had any contact with Mr. EIR?
A. No.
Q. When was the last time you had any contact
with hith?
A. I don't remember. A long time ago.
Q. Did you see a copy of his deposition?
A. No.
ever
e following statement
to
or
or words to this
of
respect to this individual you visited
it
We met another Epstein but more weird
and perverted?
A. No.
Q. You don't recall that?
A. No.
Page 505
I
3
4
5
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7
8
9
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18
19
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21.
22
23
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Page 507
Sumner of junior year. That
A.11
And then 1 visit there a few times. I
think
lived there. I visited her a few times,
and then whenever Jane Doe No.7 was living up there,
would visit h
few tine .
Q. That's
A. Yes.
Q. Do you keep contact with
A. No.
Q. Keep contact with Jane Doe No. 7?
A. Yes.
mi
n° you 'mow, do you know where
is?
A. No.
Q. Any reason why you don't keep contact with
her?
A. Yeah, she, out of the blue somewhere she like
freaked out on me and didn't know where it was coming
from. Sounded more like an influence than a — from
somebody, somebody else. So, I haven't talked to her
since because I am just letting her do her own thing
until she figures out what she —
Q. I don't understand your answer.
A. We were — it was an argument about something
Page 506
1
Q. Were you, in addition to being frie
3
2
ate
No. 7, are, were you friends with".
4
5
A. What do you mean "
"?
Q. Or are you friends with
6
A. No. I am not friends with her.
7
Q. Were you at one time?
8
A. Yeah, acquaintances.
9
Q. Did you-all room together at one time?
10
A. No.
11
Q. Were you suppo
rm with Jane Doe
12
No. 7 at one time up in
13
A. Yeah.
14
Q. And then Jane Doe No. 7 decided to come
15
here?
16
A. No. I was
to room with Jane Doe No.
17
7 when I lived in
Her roommate was supposed to
18
mow or it was like a lease thing. And I was going to
19
take over her lease, pay her rent just for the summer.
20
And she decided not to go, so I ended up getting a
21
different place in the same apartment complex.
22
Q. Did there
sk . What period of time
23
were you up in
24
A. In the summer of my junior year is when I
25
lived there.
Page 508
1
ridiculous that my friend
she was trying to —
2
for h
hip she was trying to get an interview
3
boYfrilire time. And I didn't tell
4
about it and
freaked out and was like, why
5
arc you trying to bring another girl around my
6
boyfriend, which it wasn't like that at all.
7
She just kind of like exploded over
8
something ridiculous and used words to me that a
9
good friend wouldn't So, [just kind of was, like,
10
you know, backed off a little bit and we haven't
11
really spoken since.
12
Q. And when did that happen?
13
A. Probably a good, like, seven months ago.
14
Q. Are you friends with Jane Doe No. 3?
15
A. Yes.
16
Q. When was the last time you communicated
17
with her?
18
A. I don't know. It's been a while.
19
Q. Which means six months, more or less?
20
A. Maybe like a month, two months.
21
Q: Okay. And is she still in the area?
22
A. I haven't spoken to her in a while. Maybe. I
23
giess. Last time I talked to her she was.
24.
Q. Do you speak with her on the phone or do
25
you see her in person?
(561) 832-750.0
15 (Pages
505 to 508)
PROSE COURT REPORTING AGENCY, INC.
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Page 509
1
A. I saw her in person.
2
Q. Where did you see her?
3
A. We went out.
4
Q. You and her or others?
5
A. Me, her, and Jane Doe No. 7. Jane Doe No. 7
6
was in town for the weekend.
7
Q. And where did you-all go?
A. Dr. Feelgoods.
9
Q. And this was about a month ago?
10
A. No. This was more than a couple of months
11
ago.
12
Q. Okay. So, you said you thought you saw
13
her about a month ago. Is that a different time?
14
A. No. I think I like communicated with her on
15
her Facebook or something like that like a month ago.
16
Q. Okay. All right. So, how long ago was it
17
that you-all got together in person?
18
A. Like a couple, like several months ago.
19
Q. Sometime in '09?
20
A. It might have been '09, beginning of '010. 1
21
don't know. It's been a while. I don't remember.
22.
Q. Did, did you and she go together to Jeff
23
Epstein's on any occasion?
24
A. Yeah.
25
Q. Were you the one that originally took her
Page 511
1
A. Not that I can recall. I don't remember what
2
our conversation was.
3
Q. Did she tell you anything about what to
4
expect or what was going to go on?
5
A. No. Like I said, I don't remember our
6
conversation so I don't know.
7
Q. Your best recollection is you believe
8
though on the first occasion that you went with her
9
that she had been there before?
10
A. No. I don't know —
11
Q. Okay.
12
A. —if she had. •
13
Q. Do you know fora fact that you went on at
14
least on one occasion with her?
15
A. No. Yeah. I know that I have gone there with
16
her, yeah.
17
Q. Did you go with her to Mr. Epstein's on
18
more than one occasion?
19
A. Probably.
20
Q. Did you have an estimate of bow many times
21
you went with her?
22
A. I don't — maybe three to five times. I don't
23
know.
24
Q. And was it all a concentrated time frame,
25
or was it over a long period of time?
Page 510
1
there?
2
A. I don't think so. I don't remember.
3
Q. There were times that —
4
A. I think the only person I brought was
5
Q. On the occasions that you went there
6
together, did you and she have any discussions of
7
what was, what you were going to do when you got
8
there?
9
A. No, not that I can recall.
10
Q. Did you tell her anything about -- by the
11
time you went -- strike that.
12
When you went with her for the first time
13
to Mr. Epstein's, had she already been there?
14
A. I don't know.
15
Q. Did she indicate to you that she had?
16
A. I don't know. I don't remember whenever the
17
first time we went. I think she brought me there the
18
second time I went. I don't know if she had already
19
gone. I 'mow that I had already been there and I think
20
she knew that I already had been there. So I don't
21
remember what the conversation would have been about.
22
Q. Well, did you — did she ask you anything
23
about what to expect or —
24
A. No.
25
Q. What had —
1
2
3
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7
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10
11
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14
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:6
17
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Page 512
A. No. I am guessing that's over a long period
of time.
Q. And what comments, if any, did she make to
you about going to Mr. Epstein's if she made any?
A. I don't know if she made any.
Q. When you guys would go together, would you
leave together?
A. Yeah, I'm sure.
Q. So, if you typically went together, you
would go in the same car?
A. Yeah.
Q. And at that time were one of you driving?
A. I'm sure one of us wens.
Q. Okay. Did, did she ever make any
statements at all to you about what she did with
Mr. Epstein?
A. No.
Q. Did you tell, ever tell her anything about
it?
A. No, not that I remember, no.
Q. Okay. If you went to, if you went to
Mr. Epstein's together with her, did both of you go
up and perform massages on.Mr. Epstein together or
did just one of you go?
A. No, no just one.
16 (Pages 509 to 512
PROSE COURT REPORTING AGENCY, INC.
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Page 513
1
Q. Okay. And, and when you went there with
2
her which of you was performing the massage on
3
Mr. Epstein?
4
A. I don't know. Either me or her.
5
Q. Okay. So, it wasn't always —
6
A. I know it was never, never was both of us.
7
So, ifs got to be one or the other.
8
Q. Okay. All right. But it wasn't always if
9
you went with her, she didn't massage and you
10
didn't, or you did the massage and she didn't?
11
A. Yeah.
12
Q. Sometimes it was one and sometimes it was
13
another?
14
A. Yeah.
15
Q. Okay. Any particular reason why the two
16
of you would go there together?
17
A. No. We were friends. I didn't have a vehicle
18
for a while. That could have been the reason. I don't
19
know. Plus we were friends.
20
Q. Is, is she older than you?
21
A. No, she's younger than me.
22
Q. Okay. So, if you didn't — oh, when you
23
said you didn't have a vehicle, you just meant that
24
you didn't have a car?
25
A. Yeah.
1
Q.
identification card?
2
A. Yeah.
3
Q. It wasn't a driver's license?
4
A. No.
5
Q. And so, it had her picture?
6
A. And her information.
7
Q. So you, what you really had was her
8
identification card?
9.
A. Yeah.
10
Q. And you would use that?
11
A. Where, yeah, certain places, Yeah-
12
Q. Okay. Well, what kind of places would you
13
use it?
14
A. Places that you needed to be 18 to get in.
15
Q. Okay. Do you know whether or not Jane Doe
16
No.3 had a fake ID?
17
A. No, I don't.
18
Q. Did you ever do any drugs with Jane Doe
19
No. 3?
20
A. Not that I — I mean maybe drinking, like when
21
we went out to parties. I don't know.
22
Q. Did you ever know her to do drugs?
23
A. No.
24
Q. Okay. So, you didn't do them with her and
25
you didn't know of any drugs that she did?
Page 514
1
Q. You, you had a license to drive though?
2
A. Maybe. I might have. lam sure I would have.
3
Q Okay.
4
A. I !mow I waited a while to get my license, so
5
maybe I didn't.
6
Q. Okay. Well, if you didn't have a license,
7
then she must have had the license, right?
8
A. Yeah. Or maybe I did have a license; I just
9
didn't have a vehicle. I don't know.
10
Q. I think at the last deposition we talked a
11
little bit about a fake ID. Did you have a fake ID
12
at some point?
13
A- Yeah.
14
Q. Do you recall what e it said you were?
15
A. I had
ID, ID, which said I was
16
18, or, yeah.
17
Q. And do, do you remember when you got it?
18
A. Probably when I was hanging out with her my
19
senior yew in high school when I met her, junior year.
20
Q. And what kind of ID was it? Was it a fake
21
driver's license?
22
A. No. It was 'rust her. a 'chat of her. It's
23
her, her
24
Q. Okay. So, it was a, just a generic —
25
A. Picture of her.
Page 516
1
A. Yeah. Like back then whenever I was
2
experimenting, going through my high school stage in
3
life, I think I maybe smoked pot with her.
4
Q. Do you 'mow — was she a person, did she
5
have boyfriends and et cetera when you were taking
6
her to Mr., or when you went with her to
7
Mr. Epstein's?
8
A. I don't remember. I don't know.
9
Q. Do you know what her reputation was for
10
sexual activity?
11
A. No.
12
Q. Do you know whether or not she was
13
sexually active with people when you took her to
14
Mr. Epstein's?
15
A. No.
16
Q. Do you know whether or not she ever had
17
terminated any pregnancies?
18
A. No.
19
Q. Do you know whether or not she's ever gone
20
to a psychologist or a psychiatrist?
21
A. No.
22
Q. Did you ever discuss with her any lawsuit
23
that she has?
24
A. No.
25
O. Do You know her, who, who her bo
'ends
17 (Pages 513 to 516)
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■
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16
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25
1
were?
2
A. No.
3
Q. Did you and she ever have the same
4
boyfriend? Not at the same time but did you ever
5
date the same guy?
6
A. No.
7
Q. Do you know whether or not she's ever been
8
arrested?
9
A. No.
10
Q. Do you know if she's ever been married?
11
A. Yeah.
12
Q. Okay. And was she married?
13
A. !just heard about it, not through her. I
14
just — I don't know. I don't know anything about it.
15
I just heard that she had been or maybe she is. I don't
16
know.
17
Okay. What was the name of your MEI
18
19
A.
20
Q. Is he still in the area?
21
A. No.
22
Q. Where is he?
23
A. I don't bum.
24
Q. When was the last time you knew where he
25
was?
'1111.
1?
1
11:09 a.m.
2
(A brief recess was held.)
3
THE'S/IDEOGRAPH:ER: We're back on the
4
record at 11:17 a.m.
5
BY MR. LUTHER:
i
her than the trip down to
ve you, what other vacations have you
8
taken in the last three
•;,
I have go
0
11
12
13
14
15
16
17
18
19
20
21
22
twice with
to
That's it.
Q
are
them other occasions that you go
with
titat's been within the last year and a
half?
A. Yeah.
Q. And what, what are those trips typically
consist of, weekend trips or —
A. Yeah, weekend trips mostly.
Q. You got a boat when you go down there?
A. Yeah. It's his dad's. We go with his dad and
his dad's neighbors, whoever is taking their boat down.
And how about, what was it
I
Page 518
1
A. I head he was moving from
2
was the last I heard whenever he moved from
3
Q. But you didn't know where?
4
A. No.
5
. o where? And who was your
6
at
A.
Q. I take it it wasn't
A. No.
Q. Does
have a last name?
A. Yeah. I am drawing a blank what his name — I
it.
Q. What's your best shot at pronouncing it?
A. I don't know. I don't know what it is.
Q. Is—do
youknowwher
•
A. I mean, l am gu
Q. But, but he is
A. No.
Q. Do you know
A. No.
MR. LUTTIER: Okay. I need to take a
quick break.
THE VIDEOGRAPHER: Going offthe record at
(5E1) 832-7500
9
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Page 520
1
A. Yeah.
2
Q. Long way to go for a football gaze.
3
A. Yap.
4
Q. Some
tickets?
5
A. Yeah, MIllgot tickets.
6
Q. By happenstance or is he, is he a season
7
ticket holder for one of those teams?
8
A. No. He Just got tickets for the game.
Q. Did you-all go to football games?
A. We went to that football game.
Q. Go to Dolphin games or anything?
A. No. We haven't been to a Dolphin game.
Q. It was just kind of a one-tint deal?
A. Yeah.
Q. Okay. And how about —
A. ! like the Stealers.
Q. You do?
A.
Wilt
When you went toll....
when was that?
A. la the stunner.
Q. This last summer?
A. Yeah. I think we went last summer, yeah.
Q. When you say with your family, is that you
and ourgarents?
18 (Pages 517 to 520)
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Page 521
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Page 523
A. Yeah.
Q. Was there anything different about going
3
to Mr. Epstein's after you were 18 than going to
1
4
Mr. Epstein before you were 18?
I V
=M
5
6
A. No.
MR- MERMELSTEIN: Objection to form
Q. Your parents, your dad I think mentioned
7
BY MR. LUTHER:
9
something about you used to go toll.
every
8
Q. And you acknowledge certainly that your
9
spring?
9
decision to go to his house after you were 18 was of
10
A. No.
10
your own free will?
11
Q. Did you ever go i
11
A. Yeah.
12
A Oh, yeah
it was my junior year in
12
Q. And you went because be was good to you
13
college I went t
for spring break.
13
and you enjoyed it?
14
Q. Okay. And did you go with a group of kids
14
MR. MERMELSTEIN: Objection to form.
15
from school?
15
THE WITNESS: Because I had been going
16
A. Yes.
16
there since 1 MS 15 years old.
17
Q. Did you take one of those cruises?
17
BY MR. LUTT1ER:
18
A No.
18
Q. Okay.
19
Q. Was it an organized spring break deal?
19
A. It ldnd of became like a nomml --
20
A. Yes.
20
Q. But at 18 you're an adult, right?
21
Q. Do you remember what it was called?
21
A. Yeah. But I was going there beforehand, so
22
A. What, was called what?
22
it's kind of like, you know, kept doing the same thing
23
Q. They usually have some name for those
23
that I was doing the day before 1 was 17.
24
things that they put together down there during
24
Q. And I think you told me in the last
25
spring break.
25
deposition that you thought Mr. Epstein treated you
Page 522
Page 524
1
A. No.
1
well?
2
you stay — where did you stay in
2
A. Yeah.
3 „l id
3
Q. Do you, do you believe Mr. Epstein ever
4
A. At an all-inclusive hotel.
4
did anything to intentionally harm you in any way?
S
Q. Okay. It was one of these spring break
5
MR. MERMELSTEIN: Object to the fonn. And
6
weekend deals?
6
also to the fact that these were questions that
7
A. No, it wasn't like that. It wasn't part of
7
were asked —
8
any pa • ...
..
. • ... . I was something that
8
MR. LUTT/ER: I don't think that was.
9
one of
her dad organized for
9
MR. NEERMELSIEIN: — repeatedly at the
10
us. So, there was nothing, there is no like an event
10
prior deposition.
11
planner or, just a dad.
11.
MR. LUMER: You can go ahead and answer.
12
Q. What kind of willies, entertainment
12
THE WITNESS: What was your question?
13
type stuff do you and =
do?
13
BY MR. LUTTIER:
14
A. I don't know. We go out on the boat. We go
14
Q. Do you believe that Mr. Epstein
15
Kayaking. We've been biking. We go hang out with some 15
intentionally did anything to harm you?
16
friends at local bars. Hang out at the house a lot and
16
A. No.
17
have friends over.
17
Q. I want to ask you about the damages that
18
Q. Now, you, you turned 18 sometime I think
18
you claim you've suffered. Would it be a fair
19
right after you graduated from high school?
19
statement to say that the damage that you suffered
20
A. Yes.
20
really is the fact that it came to light that you
21
Q. You had
birthday if I remember
21
had been going to Mr. Epstein's?
22
correctly?
22
MR. MERMELSTEIN: Object to fonn.
23
'
A. Yes.
23
THE WITNESS: Wait. What did you mean
24
Q. So, there was a period of time that you
24
like came to light?
25
continued to go to Mr. Epstein's after you were 18?
25
19 (Pages 521 to 524)
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Page 525
BY MR. LUTTIER:
Q. Well, it became known. People knew that
you went there and you were really embarrassed about
that fact?
A. Yeah. I am sure that's one of many of the
reasons.
Q. Okay. Other than being embarrassed about
it, and the embarrassment was because it became
known to others what you did?
A. No. Because I am sure some people put
two-and-two together but it was not like my name was out
there in the paper. So, it's not like oh, Jane Doe
No. 4, I 'mow who she is. No.
People put the general aspect but I mean
at the time that it was going on, my parents didn't
know, you know, they didn't know.
It wasn't a general of like people finding
out. It was just like everything that was going on,
the whole situation with the cops coming and like
harassing, like coming, not knowing what was going
to happen to me, if I was going to go to jail or
what was going to —
And at the time I was, you know, like when
I look back on it, it was really sick, like I was
hike on Jeffrey side. I didn't, I was, told Jeffrey
Page 527
1
MR. MERMELSTEIN: Objection to form.
2
111E WITNESS: Yeah.
3
BY MR. LUTTTER:
4
Q. And if nobody ever knew about this, you
5
wouldn't have had any of this embarrassment or
6
having people know that the police were coming
7
around talking to you or anything hie that, right.
8
A. Yeahagaill at the same time like if I,
9
like meeting
and being in this serious
10
relationship with him, like, how could, you know,
11
would start being lice what am I doing, you know what I
12
mean? Like having, like trying to get hie got to go to
13
college, get into like a serious relationship with
14
somebody I love. And I want to have marriage. I want
15
to have all that. How would 1 still be going to
16
Jeffrey. I wouldn't be going to Jeffrey's still.
17
And looking back I would step ha& from
18
that and be like, what was I doing? Luce looking,
19
looking back on it and be like I was 15 years old.
20
That is sidc. I would look back on the whole
21
situation and it would disturb me.
22
Q. Okay. So, help me to understand this.
23
A. Not just because the cops found out about it
24
and now I went through some emotional thing.
25
Regardless. I would have looked back I would have
Page 526
1
about the situation.
2
You know, like, I can't believe like how
3
my mind was so, like, like I feel he like
4
manipulated me and formed me into something that,
5
you Imow,1 look back on it now and I'm just like
6
that's disgusting. And that's why I am emotionally
7
upset is like how I, you know, my parents raised me
8
to be this good person and how I like molded into
9
something.
10
I don't know. It's just, it's disgusting.
1/
ft =Ices me really upset. It makes me get really
12
emotional. And it's not just about people finding
13
out.
14
Q. Your feelings about that are the same for
15
the times that you went to him after you were 18 as
16
they were from the time you went to him before you
17
were 18?
18
A. Yeah.
19
Q. And you, you — do you agree that you have
20
responsibility for your own actions?
21
A. Yeah.
22
Q. Okay. So, you would agree certainly after
23
you were 18 years of age what the consequences were
24
or the consequences that were as a result of the
25
actions you had decided to take?
Page 528
1
graduated from college, I would want to build something
2
for myself. So, I wouldn't go there anymore. And when
3
I would stop going there, I would look at it and I would
4
be like that is disgusting and it would emotionally
5
affect me that way.
6
Q. Other than you saying that it upsets you,
7
okay, what, how else have you been damaged, if
8
anything? Maybe that's the only thing, but is there
9
any other damage other than it's emotionally
10
upsetting to you?
11
THE WITNESS: Yeah, like me and my —
12
MR. MERMELSTEDI: Object to the form.
13
THE WITNESS: Emotionally?
14
MIL LUITIER: Let me, let me rephrase my
15
question.
16
THE WITNESS: Wait
17
BY MR. LUTTIER•
18
Q. Other than you saying it's emotionally
19
upsetting to you to look back at what you did, have
20
you suffered any other damage —
21
A. Yeah.
22
Q. — as a result of going to Mr. Epstein?
23
If so, what?
24
A. Whenever, I couldn't sleep at night thinking
25
about it. I would have flashbacks about like what
(561) 832-7500
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PROSE COURT REPORTING AGENCY, INC.
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Page 529
1
happened. When I saw him in the hallway whenever he
2
showed up for my deposition, seeing his face, giving me
3
a smirk. I couldn't even drive in my car every single
4
time I would see like an old person's face, I would pop.
5
His head would be in my face.
6
I would go out me and my boyfriend got in
7
arguments about it because I couldn't be myself. I
8
would be normal, happy one minute and emotional and
9
sad, depressed the next minute. I had so much built
10
anger inside of me that whenever I would drink, I
11
would like unleash all this built-up anger inside
12
me. A lot of things.
13
Q. Okay. What--
14
A. You know, !couldn't, like u tat w and
I
not even including being —
MI wondering, oh, are the cops going to come, is the
17
FBI going to come, like having that pressure, like not
18
'mowing, of fear.
19
Q. Okay. Any other ways you have been
20
damaged?
21
A. Yeah. I feel like, you know, like I was 15
22
years old when all that was happeningg. You know, like
23
an old man doing that to like a younger girl, don't you
24
think like her child adolescence, like, kind of lice get
25
ruined, you know.
Page 531
1
problems sleeping now or is this something that
2
happened in the past?
3
A. i mean, it was a lot more frequent, frequent
4
whenever everything was happening. But 1 mean in
S
certain situations, like, yeah, !get stressed out at
6
nighttime and I will, I will have a problem sleeping.
7
Like I can't, I will sit here and like analyze
8
everything.
9
Q. Well --
10
A. And at nighttime instead of going to sleep, I
11
will just sit there and think.
12
Q. Well, when you typically lay down and go
13
to sleep, do you sleep within an hour?
14
A. No. Normally I used to be able to go to sleep
15
within like, l would put my head down and in 10 minutes
16
then I would be sleeping.
17
Q. Well, how long does it take you now?
18
A. I don't know. Not every single night but
19
every once in a while.
20
Q. What degree —
21
A. Maybe like one or two hours.
22
Q. With what degree of frequency?
23
A. I deal know. Maybe like Nike a month.
24
Q. So, twice a month it will take you an hour
25
or so to get to sleep?
Page 530
1
And him giving me that money, like, ifs
2
probably why my parents argued so much when I was
3
young. My parents are sitting here trying to raise
4
me and trying to like put me into a direction, and
5
I'm sitting here getting $300 from this old man.
6
So, to me like my dad is trying to teach me how to
7
like spend my money and how to like be a right
8
person, and I am sitting here, he is like completely
9
demolishing everything that my parents are like
10
teaching me because he, he is giving me money and I
11
am running around, like, not, like an idiot
12
15-year-old person not knowing about, anything about
13
life.
14
Q. Any other way you have been damaged?
15
A. No. I think I pretty much am covering a lot.
16
Q. Okay. Did you incur any what we would
17
call economic damage of any kind?
18
A. What do you mean economic?
19
Q. Loss of dollars?
20
A. No.
21
Q. You paid for a medical expense or
22
something like that?
23
A. No.
24
Q. Let me go back and break this down. First
25
of all
said you couldn't sleep. Do you have
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Page 532
Q. Okay. Now, you said flashbacks. You said
that when you see older people, you see
Mr. Epstein's face?
A. Like whenever, like right before my deposition
or right before my deposition my first time I was
supposed to come here. I saw Mr. Epstein in the
hallway. Getting into my vehicle and like seeing his
face and like giving me that Nazi smirk that he gave me.
When i would get in my car and drive, like I didn't even
want to look up because I kept visualizing his face.
Q. Okay. So, that was one time you saw him?
A. Huh?
Q. That was one time you saw him here?
A. Yeah.
Q. Okay. Now, but you also said something
21 (Pages 529 to 532)
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Page 533
about if you saw older people you would see his face
or something to that effect?
3
A. No. Like if I saw like an older, like, man or
4
something like that resembled him, like sometimes I got
5
all, like, I would freak out like, oh, God is that him.
Q. Don't you see older men every day?
A. No, I don't.
Q. I mean, you're out and about, aren't you,
you're in your car; you're driving around?
10
A. Yeah. But like in this area when I am in Palm
11
Bea
ing, and I see an older person, like when
12
I am
like maybe sometimes it will cross my
13
mind but I won't freak out about it, but I will be
14
hie — it will, it will cross my mind.
•
15
Q. So, it only happens when you are in Palm
16
Beach?
17
A. It happens more frequently when I am in Palm
18
Beach.
19
Q. How often are you in Palm Beach?
20
A. I am
M
o
f
t
e
n
lately. I have been
21.
hanging out
22
Q.
23
A.
24
Q. If you are up where you live
25
with your boyfriend —
Page 535
1
A. Nothing. Like I would get
like I didn't
2
even want to, like, lookup. I didn't want to, like,
3
look at anything. I would just want to, like, just like
4
get in my own like little, mind frame I guess, and just
5 •
sit there and like, just, like, sit there and think, you
6
know.
7
Q. Were you driving a car when you had this
8
flashback?
9
A. I have, yeah.
10
Q. Well, what do you do when you're driving a
11
car and you have this flashback?
12
A Nothing. I guess I kind of, like, zoom in and
13
focus.
14
Q. Okay. So, you don't have to pull over to
15
the side of the road, for example?
16
A. (Witness shakes head.)
17
Q. All right. Can you better describe to me
18
what, what's ever happened when you had these
19
flashbacks that you say you maybe have four times a
20
year?
21
A. Nothing. I just don't like being out I
22
don't like being, like, in a situation. I just like
23
want to like, if I am out somewhere, like, I will take
24
myself out of the situation, like step outside and maybe
25
like just sit there and like analyze. Maybe I will go
Page 534
1
A. Yeah.
2
Q. — and you go in the grocery store, let's
3
say you go into Publix and you're going to see all
4
kinds of older men?
S
A. I am saying somebody that resembles
6
Mr. Epstein not just somebody that has dark black hair
7
that is fat, no, of course that's not going to remind me
8
of Mr. Epstein because Mr. Epstein does not resemble
9
those assets.
10
Q. So, this only happens if you see someone
11
that looks like Mr. Epstein?
12
A. Yeah.
13
Q. Well, with what degree of frequency does
14
that happen?
15
A. I don't know. I mean, not often, but —
16
Q. Maybe once a year, twice a year?
17
MR. MERMELSTEIN: Objection to form.
18
THE WITNESS: I don't know. I know after,
19
it's probably happened Ince four times a year
20
but I know after that situation after I saw him
21
that whole week I was having like flashbacks of
22
seeing him probably like twice a day.
23
BY MR. LUTHER:
24
Q. Well, what would happen when you had these
25
flashbacks?
Page 536
1
to my car and like sit down and just like —
2
Q. And you say —
3
A. — be by myself
4
Q. And you say this happens four times a
5
year?
6
A. No. It's happened, yeah.
7
Q. Now you're --
8
A. You said analyze or you said give me your best
9
estimate of how many times this happened. I'm just
10
saying It's probably happened like four times.
11
Q. Oh, four times since you last, since '05?
12
A. No, you said estimate. I don't know how many
13
times this happened. I'm just saying like probably four
14
22
Q. Has it ever happened to you when you've
23
been with your boyfriend out?
2 4
A. No. I have gotten paranoid before around him.
25
Q. But you never had one of these flashbacks
22 (Pages 533 to 536)
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Page 537
when you were out with your boyfriend?
A. No.
Q. Have you ever had one when you're out with
your parents?
A. No.
. Have
u ever had one when you were out
with
A. No.
Q. Have you ever had one when you were out
with anybody else or does it only happen when you've
been out alone?
A. This happens, like, when Pm out alone, like,
when I'm like going to the mall or something like by
myself. I don't recall being with anybody when I have
had one of these flashbacks, no. Or when I was in my
car leaSH: here by myself, I have told
I think I
told
oh, yeah, I have told him, li e,
w I felt
like after I saw him here. But I've never been with
Okay. Other then the incident where you
saw Mr. Epstein in this building before your depo,
can you tell me the last time you had one of these
flashbacks that you've described as occurring maybe
four times a year?
A. Before my deposition. I don't remember when.
Page 539
1
A. Yeah. It's happened one time when I was in
2
Publix.
3
Q. So, you can recall a specific incident?
4
A. Yeah.
5
Q. All right. I want to talk about that
6
specific incident. Approximately when did it
7
happen?
8
A. I don't remember.
9
Q. The year 2008?
10
A. I don't remember when it happened.
11
g
2009?
12
A. I don't have a date.
13
Q. AU right. What Publix were you in?
14
A. I don't remember.
15
Q. Okay. Do you remember what you were doing
16
in Publix?
17
A. Shopping for food.
18
Q. Okay. So, had you been in Publix for some
19
period of time before this happened?
20
A. I don't, I don't remember how long I was in
21
there or how long I was out of there. I just remember
22
the incident.
23
Q. Okay. Were you, were you looking in one
24
of the aisles in Publix?
25
A. Yeah.
Page 538
1
Q. Was it like six months before your depo
2
before you can recall it?
3
MR. MERMELSTEIN: Objection to form.
4
174E WITLESS: Yeah, probably six months.
5
BY MR. LUTTIER:
6
Q. Okay. Describe the incident that
7
happened.
8
A. Like I said I was either in Publix or I mean
9
it's happened more than once. I don't kanevaber in what
10
incident but —
11
Q. Well, when?
12
A. — !was at the mall or I was either in Publix
13
and I thought I saw him and I had to like, like, 'just
14
started getting really emotional. I would glance if I
15
saw him and like when I realized it wasn't him, I would
16
just, I walked around another way and just like
17
analyzed, sat there like for a minute just like being in
18
a situation but not really being there like just, like
19
by myself kind of but, you know, like I am in a room.
20
Like if I saw him, I would walk away and like just, like
21
I don't know how to explain it, lace be there but not
22
really there, just stand there and being like, wow.
23
Q. Are you saying that you recall
24
specifically an incident where one of these
25
flashbacks happened while you were in Publix?
Page 540
1
Q. With a grocery cart?
2
A. Yeah.
3
Q. Alone?
4
A. Yeah.
5
Q. Okay. All right. And then you saw
6
somebody that you thought looked like Mr. Epstein?
7
A. Yeah.
B
Q. Okay. And was he walking by or what?
9
A. Yeah, he was walldng by.
10
Q. Okay. And so tell me now what exactly you
11
did.
12
A. I ran around the other aisle.
13
Q. When you say ran, you don't mean you
14
literally ran, do you?
15
A. No.
16
Q. So, you pushed your cart around?
17
A. Yeah, I sped walked. I didn't have a cart. I
18
had one of those little green things.
19
Q. So you walked —
20
A. I like walked around the corner.
21
Q. You walked out of the aisle you were in
22
into the next aisle?
23
A. Yeah.
24
Q. Okay. What happened next if anything?
A. Nothinu. I was like, didn't want to walk into
25
23 (Pages 537 to 540
PROSE COURT REPORTING AGENCY, INC. .
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Page 541
that aisle. I was freaking out, like, oh, my gosh, did
I really just see him, and I'm like, no. And then I
like sat there for a minute and like, like was in my own
little, like, world. And then I just got out of there.
I couldn't even finish shopping because i was just so
lice, just like couldn't even like think of what I
wanted to get next. Like I just I had things in my cart
and i just left.
Q. Did you go checkout?
A. Yeah.
Q. All right. So, you went and checked out,
paid and left?
A. Yeah.
Q. So, when you walked around and you said
you stood there for a minute and gathered your
thoughts?
A. Yeah, I think like —
Q. Did you, did you cry?
A. No. I think i was just kind of like in shock.
Q. Did anything else physically happen to
you?
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Page 543
do it as supposed to you being physically unable to
do?
A. Yeah, I wasn't — what do you mean?
Q. All right. Did you have a list for
example of what you needed?
A. No. I just had a list in my head.
Q. Okay. All right. But nothing prevented
you from just kind of walking up and down the aisles
and picking up whatever you wanted?
A. No.
Q. All right. So, when you got in your car,
you drove home?
A. Yeah.
Q. You were able to drive home?
A. Yeah.
Q. Okay. All right. Now, going in reverse
order, so, now we had one time was when you saw
Mr. Epstein here. One time was this incident in
Publix.
When was the time prior to that that you
can recall any of this happening?
A. At the mall.
Q.
A.
Q. And what, what year are we talking about
Page 542
1
Q. All right. So, this whole incident five
2
minutes?
3
A. Probably.
4
Q. Okay.
5
A. Ten minutes.
6
Q. When is the going —
7
A. But then afterwards, after I left and not
8
being able to get food that i went there for and not
9
even — Ike being at Publix and after the situation
10
happened, I didn't, couldn't even think of what else to
11
get. Like i was just like, like my mind was just kind
12
of like, like a brain fart. Like I had to get out of
13
there.
14
And then like the whole rido home, i am
15
like sifting there thinking like this is so
16
pathetic, you just left Publix, you didn't even get
17
all the things you needed to get, like, being at
18
like, you know, like, sitting in the dorm or
19
wherever I was at like just being there.
20
Q. Did you try to finish up? Did you walk,
21 •
just walk up and down the aisles and look for
22
whatever food you wanted?
23
A. No. I didn't even want to. !just wanted to
24
get out of there.
25
Q. So, it was a matter of you not wanting to
•
Page 544
1
Dow?
2
A. I don't know.
3
Q. '07?
4
A. Probably
I don't know when it was.
5
Probably sometime in '07. I don't know.
6
Q. Okay. So, were you there with anybody?
7
A. No.
8
Q. Okay. You were there but were you in a
9
particular store or just kind of --
10
A. No, just walking around.
11
Q. Okay. Tell me what happened.
12
A. Nothing. I saw, I thought I saw somebody that
13
looked like him and it wasn't him so I just continued my
14
shopping.
15
Q. All right. So, on that occasion seeing
16
somebody that you thought was him —
17
A. And I realized that it wasn't.
18
Q. Immediately realized it wasn't him?
19
A. Yeah. I thought it was him and then realized
20
it wasn't
21
Q. Okay. So, you just went in and did your
22
stuff that day?
23
A. Yeah. But I felt like afterwards it like made
24
me sit there and think of all the things that went on,
25
you know, like I'm not saying, oh, i just saw Jeffrey
24 (Pages 541 to 544)
PROSE COURT REPORTING AGENCY, INC.
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Page 545
Epstein, but it brings back memories of what happened
2
whenever I, whenever I see, something like a familiar'
3
face and I, like, visualize that it's him, like, it
4
brings back memories that 1 don't want to remember.
5
Q. Okay. But it didn't, on that particular
6
occasion it didn't interfere with whatever you were
7
doing at the mall?
8
A. No.
9
Q. Would you agree with me that in your life
10
there have been various unpleasant things that have
11
happened to you?
12
A. Yeah.
13
Q. And would you agree with me that thinking
14
about those unpleasant things causes you this same
15
emotional distress that you've described?
16
A. Yeah. Certain things bothered me but —
17
MR. MERMELSTEIN: Form.
18
THE WITNESS: — I've, I've like worked it
19
out with myself.
20
BY MR. LUTHER:
2/
. Well for example, this boyfriend that you
22
had,
23
A. Yeah.
24
Q. — he did some pretty bad things to you,
25
didn't he?
Page 547
1
alcoholic and that's not something that I want
2
in my life anymore, and that's why I got out of
3
it So, if anything I'm happy that I am not .
4
him anymore and —
MR. LUTHER: Okay. So --
6
THE WITNESS: And I got out. It made me a
7
stronger person being like, wow, you're not
8
with that person anymore and made me, you know,
9
made me wiser with my decisions from then on.
10
BY MR. LUTHER:
11
Q. Okay.
a people that you
12
think look nice
does it cause you
13
any problem?
14
A. No.
15
Q. All right. So, you're not with Jeffrey
16
Epstein anymore either, are you?
17
A. No.
18
Q. So, tell me what, why, knowing that you're
19
not with Jeffrey Epstein doesn't make you also
20
stronger now?
21
MR. MERMELSTEIN: Objection to form.
22
THE WITNESS: qaajia it's still something
23
that bothers me. Like
was something
24
that like I choose, I loved, I met him, I like,
25
wanted to met him. I wanted to get to know
Page 546
1
A. Uh-huh.
2
Q. Thinking about those causes you to be
3
upset, doesn't it?
4
MR. MERMELSTEIN: Objection to form.
5
THE WITNESS: Yeah. I look back on It and
6
Fm sure anybody would probably be upset. But
7
I mean, that is something that has happened in
8
the past, and I don't — lam in a good
9
relationship now, and I was in a good
10
relationship afterwards. I mean, I don't look
11
at it igau. :.ati I'm like, °b, nen, I wish I was
2
with
He used to be mean to me, no.
13
BY MR. LUTTIER:
14
Q. No. What I am referring to is the man was
15
physically violent towards you?
16
A. Yes.
17
Q. He called you vile names?
18
A. Yeah. That's why I got out of that situation.
19
Q. Okay. So, when you think back about those
20
incidences when he was beating you up, when he was
21
spitting on you, when he was calling you vile names,
22
that causes you to be upset too, doesn't it?
23
MR. MERMELSTEIN: Objection to form.
24
THE WITNESS: No, because I am not with
25
him any more and I realize be was just an
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Page 548
him, like pursue love.
Like Jeffrey was something that like was
presented to me and like I felt like he melted
me and manipulated me. And being manipulated
it still bothers me that, that I allowed that
to happen.
So, I still get like upset about the whole
Jeffrey Epstein thing. It's disgusting. It's
disturbing. lean% believe what he has done
to several girls about it, and he's not gotten
a good punishment for it.
MR. LUTHER: Well, your, your belief —
MR. MERMELSTEIN: Stick to the question
that's asked.
BY MR. LUTTIER:
Q. Your belief that, about those things and
your feelings about that only came about after you
filed this lawsuit; isn't that right?
A. I don't remember.
Q. Well, you didn't have those beliefs before
you filed this lawsuit, did you?
A. I was, I am sure like sometirnes it crossed my
mind, but I don't think I verbally expressed it to
anybody.
In fact, after you were 18 while you were
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Page 549
1
an adult you had expressed to several people that
2
you didn't think that there was anything wrong with
3
what Mr. Epstein had done?
4
A. Yeah. At that time I didn't. I thought it
5
was —
6
Q Okay.
7
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A. -- a normal thing to do. I was going there
with all my friends. I even called him up and told him
that the police were investigating other girls.
Q. And was
A. I was Ince on his side. I was,Ididn't know.
That's how manipulated and brainwashed I was and now I
look beck on it and I think it's like, wow, disgusting.
And I regret saying what I said. And ill, if i knew
then what I knew now, I would have never said that.
Q. Well, you only, you only know now what you
know because you met with —
A. No.
Q. Dr.
isn't that right?
MR. MERMELSTEiN: Objection to form.
THE WITNESS: No.
BY MR.
was'
Q. Or was
A. No.
Q. -- front Victim Services?
1
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Page 551
Jeffrey Epstein ever did to you?
MR. MERMBLSTEiN: Objection to form.
THE WITNESS: No.
MR. LUITTER: Okay. Certainly
Mr. Epstein —
THE WITNESS: I think it's about even.
BY MR. LUTTIER:
Q. And, and what
did to you
doesn't affect you at all today, does it?
A. No:
Q. Okay. Makes you stronger, tight?
A. No. It made me, sorry. It made me realize
what I didn't want. I mean, it wasn't, it wasn't
healthy.
Q. Okay. You, you -- let's see. We had, we
had the incident here. We had Publix. We were
going back in time. We had the mall. When was the
time prior to that that you ever had one of those
flashbacks?
A. I'm not sure whenever those time frames were.
i don't want you categorizing it that's whenever that
happened and then going past. I just know that those
situations happened.
Q. Okay. I want to know when was the time
prior to you in the umll, that incident?
Page 550
1
A. No.
2
Q. When did you get this sudden come-over you
that what you had done since you were 18 years of
1/2
age and, and your statements about Mr. Epstein
suddenly were all wrong and --
A. Well, i always thought it was like really
7
weird that everybody was going over there. But after a
8
while it just kind of became like normal. So, whenever
9
i was hearing about things going on about police
10
investigating girls and stuff like that, I think one
11
girl was 13 years old, I was disturbed about it.
12
Q. Well, you, you don't know anybody that was
13
13 years old?
14
A. No, I heard.
15
Q. That's just a rumor.
16
A. Alter hearing, i wouldn't put it past me
17
because i know there was a lot girls that went there. I
18
was disturbed by it, and that's when I just kind of
19
started looking at things and like playing middle
20
person.
21
tialiog
i
ree with me that the things
22
that
did to you, choking you,
23
grabbing you by the neck, throwing you to the
24
ground, spitting on you, biting you, calling you
25
vile names were much more horrendous than an hing
Page 552
1
A. I think whenever we were out one night I was
2
with some, some friends. I don't remember who.
3
Q. What year?
4
A. Huh?
5
Q. What year?
6
A. I don't remember.
7
Q. Where were you when this, this incident
8
happened?
9
A. Iva
10
Q. Were you in college, out of college?
11
A. Yeah, I was in college.
12
Q. Freshman, sophomore?
13
A. I don't remember what year it was.
14
Q. Okay. Tell me what happened.
15
A. No, I was out with friends and I thought that
16
they didn't know about the situation. So, I thought I
17
saw his face and I just kind of, Mce, freaked out and
18
went to the bathroom and then came back out and was
19
hanging out with my friends again.
20
Q. Were you at a bar or club?
21
A. Restaurant.
22
Q. Restaurant. Were you eating or drinking?
23
A. Eating,.
24
Q. Okay. So, you got up and went to the
25
restroom?
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Page 553
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A. Yeah. And then I came back and sat down.
2
Q. Okay. And how long were you gone?
3
A. I don't know.
4
Q. Five minutes?
5
A. Probably like ten minutes.
6
Q. Okay. You cant back and fmished your
7
meal?
8
A. Yes.
9
Q. Went on with your friends for the rest of
10
the night?
11
A. Yeah
12
Q. Okay. When was the time prior to that
13
that you ever had one of these flashbacks?
14
A. I don't know. Probably just when everything
15
was going down just thinking about it constantly.
16
Q. Well, when you say "when everything was
17
going down," are you talking about when the police
18
were investigating that matter?
19
A. Yeah.
20
Q. All right so, now we're back —
21
A. No, I'm just saying —
22
Q. — in '05?.
23
A. Yeah, but I'm just saying that's one of the
24
times. I mean, I have had a few flashbacks.
25
Q. I am going to ask you about each one.
Page 555
1
Q. — specific incident?
2
A. I was depressed. I was emotional. I didn't
3
want to talk to anybody.
4
Q. Okay. I want, I want, I want to focus on
5
a specific incident.
6
MR. MERMELSTEIN: Objection.
7
THE WITNESS: Well, I can't give you
8
specific dates because I don't remember
9
specific dates. I am just telling you in
10
general it's happened a few times and I'm just
11
telling you how my emotions felt a few times.
12
I can't sit here and be like, oh, well, this
13
date, this, this, this; no. I am saying in
14
general, I can't —
15
BY MR. LUTHER:
16
Q. Each of these incidents that you have
1 7
described to me would you agree are incidents that
18
lasted fora fairly short period of time?
19
A. No.
20
Q. For example, the restaurant was a
21
free-minute deal?
22
A. Yeah. That was a short period of time
23
Q. Okay. The mall was less than five
24
minutes?
25
A. Probably. But afterwards it still affected me
Page 554
1
A. Okay. Are you talking about every single
2
incident?
3
Q. That's what I'm doing. We're going back
4
now. What's the time prior to when you were at this
5
restaurant with your friends?
6
A. What do you mean "prior to"?
7
Q. Well, the one that preceded that?
8
A. Well, there were several occasions from
9
whenever, yeah, the police were involved, and you know,
10
always coming around asking questions. I had a few
11
flashbacks about what went on.
12
Q. Okay. That was in '05, right?
13
A. Yeah, so I mean —
14
Q. And so —
15
A. — there was a few.
16
Q. I am going to — let's talk about them.
17
A. Of not just seeing him out but just having
18
flashbacks of what was going on.
19
Q. While the police were making their
20
investigation?
21
A. No. Like afterwards or beforehand or before
22
they came and interviewed.
23
Q. Okay. Tell me what happened. I want to
24
know about the next --
25
A. Nothing.
1
2
3
4
5
6
7
8
9
10
12
Page 556
because, yeah, I went on going shopping and stuff like
that, but for the rest of the day it affected me because
I sat there and had to think about all the things that
happened-
Q. How did it affect you the rest of the day?
A. I would sit theremd think about it. 1 was
Just out of it. I was emotional. Like I wasn't — I
was depressed. I wasn't happy.
Q. Who —
.dn't want to talk to an
16
Q. On those occasions when you were out with
17
groups of people, you continued to do whatever
18
activities you were doing with that group for the
19
rest of the night?
20
A. Yeah. I finished eating and then I went home.
21
Q. Okay. Which is what the plan was to begin
22
with, right?
23
A. No the
robabl went out.
24
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Page 557
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•
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MR. MERMELSTEIN: Objection, asked and
4
answered.
5
BY MR. LUITIER:
Q. Okay. All right. So, and the only other
7
thing you said was you had, l think you had
8
arguments with your
d. Did it cause you
arguments with Mr.
10
11
15
16
17
18
19
20
21
22
23
24
25
Q. And how many of these arguments did you
have with your boyfriend?
A. It was just funny that it was around the time
frame of everything that was going on with this
investigation.
Q. So, how many arguments did you -- you've
only - you've been --
A. I don't know. It wasn't like I can remember
every argument, but I just know we were more
argumentative.
Q. Okay. So, you're saying it's not a
Page 559
1
A. Well, we sat down and talked about -- no, I
2
just - at that time 1 was just really emotional and I
3
was angry and upset, and I would take it out on him.
4
Q. Okay. But that doesn't happen now?
5
A. No.
11
12
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14
15
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A. It, it was. Whenever a situation would happen
1, I don't know. I have a close relationship with God.
1,1 go to church and if you read the Bible, I mean, it
pretty much tells you that God forgives everybody. Like
one of the fallen angles, he used to sin, he used to
cheat on his wife, he used to do all this stuff, he used
to, used to do all this nasty kind of stuff and the Lord
still forgave him and let him come up to, up to the
Lord.
So, me having sinned and did that, I know
that I did that and I have asked the Lord for
forgiveness. And I feel like he's forgiven me. And
for me, I have, you know, yeah, I was upset at the
time but it doesn't — something that I, that I've
dealt with. And I have asked the Lord for
forgiveness and I feel like he's forgiven me.
Page 558
1
specific argument. You're just generally saying you
2
and he were more argumentative?
3
A. I was more depressed about it and 'was more
like emotional about the situation then. I mean —
whenever we would get in arguments, it was always about
6
me being paranoid because I thought somebody was
watching me, or you know, and then I would start
drinking and I would get emotionally upset and we would
t
it.
9
13
Q. Did you tell MI that that's why you
14
were getting upset?
15
A. Yeah.
16
Q. How many of these arguments did you have?
17
A. I don't blow. Maybe a few.
18
Q. And you've only, what a year and a half
19
you have been going out with him?
20
A. Yeah.
21.
Q. So, you've had few in a year and a half.
22
Did you always make up atter your arguments?
23
A. Yeah.
24
Q. And, and is there something new now that
24
25
has changed and you don't have these arguments?
25
1
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
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21.
22
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Page 560
Q. You're a religious person?
A. Yes.
Q. You believe in forgiveness?
A. Yes.
Q. You believe the Lord forgives people that
commit horrendous crimes?
A. Yeah.
Q. And the Lord also will forgive Jeffrey
Epstein, light?
MR. MERMELSTEIN: Objection, form.
MR. LUTTIER: Or de you — isn't that
right?
THE WITNESS: Is he religious? Does he
believe in the Lord?
BY MR. LUTTIER:
Q. You're the ono that has the religious
belief, right?
A. I think for the people that believe in God,
yeah.
Q. Okay. So, you're a person that believes
in God?
A. Yeah.
Q. And, and one of the things you believe,
you shouldn't judge others?
A. cap- yeah, I can't -- what happened, I
28 (Pages 557 to 560)
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Q. You also believe that because you are a
25
religious person that it's not your responsibility
Page 561
don't know what his beliefs are. So, you know, if he
doesn't believe in that, then I don't know —
Q. Well, that would be his problem, right?
A. Yeah.
Q. But I am talking about your-
A. It's something that be needs to ask for
forgiveness for.
Q. Okay. That's his problem. That's not
something you have any control over, right?
A. So, if something bad were to happen to him —
I am saying this is what I forgive, this is bow, this is
what I want forgiveness for, for myself. For him, I
don't want it. He deserves for'whatever he gives.
Q. I want to take this carefully because you
have now told me you are a religious person and that
you believe the Lord forgives, right?
A. Yeah.
Q. And it has given you great comfort knowing
the Lord forgives —
Page 563
1
MR. LUTTIER: Well, wait a minute.
2
THE WITNESS: I don't think he has.
3'
.MR. LUTHER: I'm not asking about —
4
THE WITNESS: So, I don't know.
5
BY MR. LU1
6
Q. I am not asking about Mr. Epstein. I'm
7
talking about your ability to gain comfort by saying
8
the Lord forgives people that make mistakes. And
9
you've said that you got that comfort, right?
10
A. Yes. I feel like I have.
11
Q. Okay. And, and you think it would be
12
certainly appropriate if the Lord forgave
13
Mr. Epstein, too?
14
MR. MERMELSTEIN: Objection to form.
15
She's answered that question three times
16
already.
17
MR. LUTHER: I don't think she has.
18
MR. MERMELSTEIN: Very specifically.
19
THE WITNESS: No.
20
MR. MERMELSTEIN: She, she has answered
21
the question.
22
BY MR. LUTHER:
23
Q. So, if I get this right there is a double
24
standard that is you want to apply a different
25
standard in your religious beliefs to Mr. Epstein?
1
2
3
4
5
7
8
10
11
12
13
14
15
16
17
18
19
20
21
22
Q. So, there is a different standard.
23
MR. MERMELSTEIN: Object to form.
24
THE WITNESS: Maybe he will. I don't
25
know, I don't what he's asked for forgiveness.
Page 562
to judge others, I assume; is that right?
A. No, but people do.
Q. No. But your religious. Just like you're
able to say the Lord has forgiven you with respect
to what you have done?
A. And, yes, in that certain situation, yes.
Q. You need to wait until I finish. Just
lace you believe that the Lord forgave you, you
believe it's not your position to judge others,
right?
MR. MERMELSTEIN: Object to the form.
THE WITNESS: No. There, here's been
times where.
MR. LUTTIER: And so —
THE WITNESS: I've had judgment —
MR. LIMIER: So, you believe.
THE WITNESS: — on others.
BY MR. LUTTIER:
Q. So, you believe the Lord will forgive
Mr. Epstein too, don't you?
A. No.
Page 564
1
A. No, I am not putting a double standard —
2
MR. MERMELSTEIN: Objection. You clearly
3
don't understand what she's saying.
4
THE WITNESS: lam not putting, I'm not
5
putting a double standard on that. I am just
6
saying as myself in the Lord and me having a
7
belief in that, I have asked for, one-on-one
8
for that. Now, what his belief is, I don't
9
know.
30
MR. LUTTIER: Okay.
11
THE WITNESS: I don't think that he has
12
asked for forgiveness, and I don't think, you
13
know, I don't think he should get forgiveness.
14
But if he does get it, then, you know, good for
15
him. That's his, whatever he believes. But
16
honestly I don't think he wants —1 don't even
17
think he cares.
18
BY MR. LUTTIER:
19
Q. Well, you wouldn't even know if he asked
20
for it or if he got it or anything else, would you,
21
right?
22
A. No, I. ivouldn't.
23
Q. So, from your perspective, becaimp you can
24
only be responsible for yourself, right?
25
A. Yeah.
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Page 565
1
Q. Okay. From your perspective, you gained
2
comfort in saying, you know, ! believe in the Lord,
3
and he's forgiven me for whatever I have done?
4
A. Yeah.
5
Q. And, and you moved on, right?
6
MR. MERMELSTEIN: Objection to Iona
7
THE WITNESS: Ifs helped me move on, yes.
8
BY MR. LUTHER:
9
Q. Okay. So, we have now discussed all the
10
damages that you allege you have suffered as a
11
result of any interaction with Mr. Epstein, correct?
12
A. Uh-huh.
13
MR. MERMELSTEIN: Objection to form.
14
BY MR. LUTTIER:
15
Q. Did you — what was your answer?
16
A. What did you just say? Sorry.
17
Q. We have now discussed all of the damages
18
that you have alleged you have suffered as a result
19
of your interaction with Mr. Epstein?
20
MR. MERMELSTEIN: Again, form.
21
THE WITNESS: Yes.
22
BY MR. LUTTIER:
23
Q. Wl
d.
was your best friend in college?
24
A.
and Jane Doe No. 7.
25
Q. And was that throughout college?
Page 567
1
A. Probably like six, seven months ago, eight
2
months ago. Ifs been a while. I don't even know. It
3
might have even been longer.
4
Q. There is a girjjyhose first name escapes
5
me but lag name of M. Do you know her?
6
A.
7
Q. Yeah.
a
A. Sam& hpuilkalLissa
,;
ut a -
9
Q. Who is
(phonetic)?
10
A. Was my college roommate.
11
Q. And what's your relationship with her?
12
A. Friends with her. Acquaintances. I don't
13
talk to her anymore.
14
Q. Is that because of anything in particular
15
or you just --
16
A. No. We were maiiSnds.
We
17
were acquaintances. W
and
18
stuff. But now that I graduated and she graduated, we
19
don't — we're not around. . We don't talk anymore.
2 0
Q. Was she your roommate for all four —
21
A. Just average friends.
22
Q. Was she your roommate for all four years?
23
A. Thee, three years.
24
Q. What three years?
25
A. I think. Freshman, sophomore, and junior.
Page 566
1
A. Yes.
2
Q. That's la
3
A. Yes.
4
Q. There was a baseball player you dated?
5
A. Yes.
6
isn't coming to me. MIE.
7
laillir
eWhere does he live now?
8
A. I don't know.
9
Q. When was the last time you had any contact
10
with him?
11
A. When I saw him for graduation probably.
12
Q. Okay. Your relationship with him was
13
okay?
14
A. Yeah.
15
Q. And you just decided that he wasn't the
16
perfect one for you?
17
A. Yeah.
18
Q. Okay. Was there somebody else that you
19
had a relatio
h in college?
20
A. Prior
I wasn't in any
21
boyfriend-girlfriend, no.
22
Q. Okay. When was the last time you had
23
any — I think I asked you this. If I (lid I
24
apol
i . Your last time you had any communication
25
with
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COURT REPORTING
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Page 568
Q. illicit
did she come from?
A.
Q. And do you know her parents?
A. Yes.
Q. And how do you know her parer
A. Fle4M Kethey would come to mall', games.
Q. Have you had any communication with them?
A. Since when?
Well, since you graduated from-, from
A. No.
Q. Who, who do you-all mmvs that you
that you are a Plaintiff in one of these lawsuits?
A. Do I bow whet
Q. Do you know right now there is a pseudonym
for you so your name isn't displayed?
A. I don't know them
Q.Litalthan your friends like lane Doe No.
7 and Iggidoes anybody else know? Have you told
any other people you are a Plaintiff in a lawsuit
mherihm your parents and your boyfriend?
A. Not that
I mean maybe Jane Doe No. 3..1
don't think I told her anything. I think maybe she
assumes or knows.
Q. Have you had discussions Nvith other
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People --
A. No.
Q. -- that have lawsuits going on? Did
there, was there a time that you went up to sic Jane
7 in
and you decided to
A. I didn't go inside to try. I was hanging out.
I wait there for I think my birthday weekend. And I was
drinking at the pool all day. And
was livin with
Jane Doe No. 7 at the time and
and asked me to go. And me not being in the right state
of mind,1 was like, sure, why not. And she went in at
4:00 in the afternoon. I went with her. And then 1,1
wasn't even there for, I think I did one song. I felt
so uncomfortable and I had to leave right away. I was
there for maybe 20 minutes at the most.
Q. When, when was this?
A. I think around my 18th birthday.
Q. Before you moved up there?
A. Yeah. I was way before — I went there for my
birthday. I think I went there to celebrate my birthday
weekend.
Q. This was while you —
1
when did you it?
2
A. No, I mean was not —
3
Q. Okay.
A. I was not — I wasn't tipsy.
Q. So, you were underage for being in there,
6
weren't you?
7
A. You only to be 18 to be in there.
8
Q. You had to be 21 to drink though. right?
9
A. I was at the pool drinkin before went.
10
Q. I'm talking abo
your
11
recollection?
12
A. I wasn't drinking there.
13
Your recollection is you could be=
14
at 18?
15
A. Apparently, yeah.
16
Q. Do you have a fake ID to show it?
17
A. No. It was around my 18th birthday.
18
Q. Did they, did this establishment ask you
19
for your identification?
20
A. Yeah.
21
Q. And what did you tell them your age was?
22
A. I gave them my license.
23
Q. Your license reflected —
24
A. Yeah.
25
Q. So, did they interview you or something?
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Page 570
A. I was there for having fun. Huh?
Q. This is before you stopped going to see
Jeff Epstein?
A. Yeah. and
ad
kay. So, in '05 sometimiln go up to
rune your friend ='?
A. Well,
lived with Jane Doe No. 7.
Q. Okay. And she's working at -- what was
the name of this place?
A. I don't even know.
A. Yes, that's what that's called.
Q. And you went here?
A. Yes
A. No. It was kind of a, it was a bad decision
that I made, being going there, having celebrated my
birthday all weekend and then drinking at the pool and
not being in the right state of mind.
Q. Are ou going to tell me you were drunk
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•
A. Yeah.
Q
A. There was nobody there. It was at 4:00 in the
afternoon.
Q. Did you --
A. There might have been two people there.
Q. Okay. Was that the first time you did
that?
A. Yeah.
Q. First time in your whole life?
A. Yeah.
Q. Have you ever done it since?
A. No.
Page 572
A. No.
Q. All right.
A. They just,
was working there so they --
she was just like, :I
friend here —
youjt
A. No. It was
clothes.
Q. So, you went and put on a costume to begin
with?
A. Yeah.
And then
31 (Pages 569 to 572)
PROSE COURT REPORTING AGENCY, INC.
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Page 573
Page 575
1
Q. Okay. Now, while ou were u seeing your
2
friend Jane Doe No. 7 and
did you stay
3
at the apartment they were in?
4
A. Yeah.
5
Q. Okay. And
cident
6
involving you and
boyfriend?
7
A. No.
8
Q. Was there —
v
know an individual by
9
the name of
10
A. No.
11
Q. Do you recall —
12
A. I know, I know that, that name sounds familiar
13
but I don't know.
14
Q. Well, do ac
tcall on any occasion when
15
you were up in
and you stayed wherever
16
was staying, spent the night. Do you recall that
17
ever happening?
18
A. That never happened.
19
Q. You never wentaSere and spent the
20
night in the same place =
was spending the
21
night?
22
A. Probably. I am sure when, in
whenever
23
was Jane Doe No. Ts roommate, they had two
24
diffettlia-drooms, you know. I don't, never stayed
25
with =.
I stayed at Jane Doe No. 7's.
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testimony?
Q. How do you know her depo was taken?
A. Because I heard that her deposition was taken.
Q. What did you hear about her deposition?
A. Nothing. !just heard it was taken.
Q. She testified that you spent the night at
the apartment that she shared with Jane Doe No. 7,
and that she got up in the night to come out and
find ou ivin her boyfriend who she defined as
oral sex?
A. That never happened. She's lying.
Q. That's just
der_ dated
with a
don't even know if —
never h
cad up
A.
sounds familiar from
know if al
happened.
Q. Are you saying you know who
is or —
A. No. That name sounds familiar from high
school in
not in
. That just never
happened. I've never hooked up with any of her
boyfriends, never had her ever walk in on me doing
anythini like at. That just never happened.
Don't even
was ever in
That never
Page 574
1
Q. I want to breakdown semantics.
and
2
Jane Doe No. 7 had an apartment?
3
A. Yeah.
4
Q. Did you ever spend the night in that
5
apartment?
6
A. Yeah.
7
Q. Did you en md the night in that
8
apartment when
was also in that apartment?
9
A. Yeah.
10
Q. All right You just weren't in the same
11
bedroom as her, right?
12
A. Yeah. I don't even know if she was home. I
13
think she had a boyfriend. I don't even know if that
14
weekend she was even around, or she even, either
or with her boyfriend. I don't even
16
know if she was there because by the time I went to bed,
17
she was never home.
18
Q. Are you aware that
deposition's
19
been taken?
20
A. Yeah.
21
Q. Are you aware of the substance of her
22
testimony?
23
A. No.
24
Q. How do you know --
25
A. What do you mean the substance of her
1
Page 576
A. None of it adds, none, from the name to
nothing adds u
that
5
A. I don't know what it was called.
6
Q. What did your conversation with your
7
parents consist of after the last deposition
8
regarding
Specific, that issue.
9
A. Oh, that issue?
10
Q. Yeah. What did you tell them?
11
A. Nothing. I told them a little bit about it
12
beforehand, and then when we were going over on the
13
phone, and they just -- I mean, they were upset of
14
course. I mean, what parent wouldn't be upset.
15
Q. So, this was a conversation that happened
16
over the phone, not face-to-face?
17
A. No. We talked about it afterwards
18
face-to-face when they came into town.
19
Q. So, there were two conversations?
20
A. Sure. I don't know. I'm sure it got brought
21
up.
22
Q. Well, I don't want you to guess.
23
A. I think it got brought up on the phone or
24
maybe we talked face-to-face.
25
Q. So, after your deposition you called them
32 (Pages 573 to 576)
PROSE COURT REPORTING AGENCY, INC.
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Page 577
on Di
m
e Ione to tell them abou'
A. Not really right after, but I told them about
it, yeah.
Q. Okay. How did that conversation go?
A. Well, I have an open relationship with my
parents and I tell them a lot of things. So that was
one thing that I didn't tell them, of course, you know
that. And so, whenever I told them, of course they were
upset like any parent would be, but at the same time
they were just kind of like, you know, I am your
parents; I am going to be here for you; have you like,
you know, asked me, have you asked God for forgiveness
and — •
Q. And were there tears during that
conversation?
A. I don't remember. I'm — I think I was more
like frustrated and upset. I don't know. I don't
remember.
Q. Well, this conversation had to happen
since --
A I might have gotten teary-eyed about it
Q. Wait a minute.
A. I don't know.
Q. Wait a minute. Let me finish my question.
I
a little girl?
2
A. Yeah.
3
Q. So, did it make
4
for auto
Okay.
it particularly difficult
Page 579
6
A. What's that? Well, after I told her, yeah, it
7
was hard but --
8
Q. It had to be upsetting to you?
9
A. Yeah. Well, it was upsetting but it was
10
something that my mom told me when I was younger when I
11
was 15 years old and starting to sleep around. She told
12
me that things to scare me. I mean, after the situation
13
already happened, what are you going to do? You can't
14
scare me anymore. I'm not IS, you know, 15 years old.
15
So, it kind of, you know, lace, you know this happened.
16
I'm sorry it happened. You know, what are you going to
17
do? The situation already happened.
18
I 'mow she's not going to talk, not talk
19
to me anymore. I think it's something she, it's a
20
scare tactic that she used to --
21
Q. Okay.
22
A. — probably prevent the situation.
23
Q. And that --
24
A. And then after it's already happened, what are
25
you going to do? Yeah, I am sure l was upset whenever
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Page 578
This conversation that you can't remember happened
sometime after October 27th of '09, right?
A. Yeah.
Q. Okay.
A. But I'm sure — I mean, the conversation, I'm
sure, maybe I did get teary-eyed. I don't. know. I
don't remember if I got teary-eyed or the exact
conversation that took place.
Q. Do you remember whether or not your folks
were each on an extension on were you talking to
them separately?
A. No, a speaker phone.
Q. Okay. What did your mother tell you?
A. My mom didn't really say anything. My dad
said most of everything.
Q. Had your mother told you --
A. My dad was like your mom is upset and my mom
was just kind of in the background listening to me and
my dad, Lice, have conversation.
Your mother testified that she had told
A. She told me that beforehand, but she didn't
tell me in that conversation.
Q. Okay. But that is something you heard as
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Page 580
told her about it, but I mean she told me then and
there, I love you, lam going to be here for you, sorry
to hear that that happened, I wish I would have known, I
wish, you know. And then, you know, it made me and my
parents even closer that we had that conversation.
Q. And there was -- they came here personally
and you saw them?
A. No, not for that. They came here for just
visiting or something like that and not just to come
down and talk to me about that, just come down to visit
and —
Do ou have an thou: is or concerns that
MR. MERMELSTEIN: Objection, calls for
speculation.
THE WITNESS: Yeah. I'm sure.
BY MR. LUTTIER:
Q. What are your thoughts about that?
A. I haven't thought about it, but I am sure if
the situation occurs, thenl will.
Q. And what do you think your emotion is
going to be at that time?
33 (Pages 577 to 580)
PROSE COURT REPORTING AGENCY, INC.
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Page 581
1
MR. MERMELSTEIN: Objection to form.
2
THE WITNESS: I don't know. I haven't
3
thought about it.
4
BY MR. LUTHER:
5
Q. Did you ever travel anyplace with Jeffrey
6
Epstein?
7
A. No, but he asked me to.
8
Q. Okay. Did you, were you a person when —
9
A. I wasn't old enough to go.
tirimuwere
in high school, were you
I
A. Yeah.
Q. Did you, did you communicate with
Mr. Epstein on a computer?
A. No.
MR. LUTITER: Somebody got the time?
THE VIDEOGRAPHER: It is 12:11 p.m.
MR. List TIER: No. But I mean how much more
time do we have to go?
THE VIDEOGRAPHER: Five more minutes, sir.
BY MR. LUTTIER:
Q. Okay. You had a friend named
--
A. Yeah.
Q. — that died
A Yes.
12
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22
23
24
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Page 583
1
4
Q. Do you recall, with respect to
5
death, how old were you?
6
A. I think I might have been 14, 15.
7
Q. And he was the guy that you had dated for
8
sane period of time, right?
9
A. No. I knew him and he took me out one time.
10
Q. Okay. And then it took you a fair amount,
11
amotmt of time to get over his death, didn't it?
12
MR. MERMELSTEIN: Objection to form.
13
MR. LUTTE31t: Did n take you --
1.1
THE WITNESS: Maybe it was my freshman
15
year, and then maybe sophomore year whenever
16
his death came out I thought about it. But if
17
you ask me what date he died today, I couldn't
18
tell you.
19
BY MR. WMER:
20
Q. Did you have another really good friend
21.
named In that died?
22
A. I was friends with her, acquaintances with
23
her. She was somebody I knew but not gocd, best friends
24
or somebody that I hung out with like every day. 1 knew
25
her through high school.
1
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Page 582
What was your, what was your relationship
with M?
A. We were good friends. He took me out on a
date once.
Q. Had you ever been intimate with him?
A. No.
Q. You gave some answers to interrogatories
and you listed four individuals
Ili Sexual relations with:
=,
and
A. Yes.
Q. Were there, in fact, others with whom you
had sexual relations?
A. No.
Q. Do ou know a fellow by the name of I
think it's
A. Yeah.
Q. And a EIM?
A. Yeah.
Q. Ever have sex with either of them?
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Page 584
air
y
t.
you know a lady b the name of h
A. Nisi=
Q. Yeah?
A. No.
tial
ti
vi somebody by the name of
A. Yeah.
Q. And how do you know
A. High school.
Q. And what kind of relationship did you have
with her?
A. Just acquaintance, acquaintance, hang out at
parties; I guess, high school parties.
Q. Did you socialize with her?
A. Huh?
Q. Did you socialize with her?
A. Yeah.
Q. Do you know if she ever went to see
Mr. Epstein?
A. I think she did.
Q. And how do you }mow that?
A. Because she hung out in a group of friends
that I hung out with and pretty much every one of those
girls went.
34 (Pages 581 to 584)
PROSE COURT REPORTING AGENCY; INC.
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Page 587
Q. Do you know who took her there?
2
A. No.
3
Q. Do you know how Mien she went?
4
A. No.
5
Q. When was the last time you talked to her?
o
A. Since high school.
7
Q. Do you remember a Ms. IMP
8
A. No. What did you say the first person's name
)
was,
10
Q. Yeah.
11
A. It sounds familiar but I can't —
12
Q. Do you know that person?
13
A. I don't know. I don't think so, but it sounds
14
familiar. Is that the first name?
15
Q. No, last name.
16
A. Oh, no. Like I said, the last name sounds
17
familiar but 1 don't know.
18
Q. Have you ever told your parents everything
19
that occurred when you were at Mr. Epstein's?
20
A. Briefly.
21
THE VIDEOGRAPHER: I am sorry to interpret
22
but now might be a good time to change the
23
tape.
24
ME- LUTITER: Okay.
25
THE VIDEOGRAPHER: Going off the record at
2
3
4
5
6
7
8
right?
9
A. No, not that I'm aware of.
10
11
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13
14
15
16
17
19
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20
21
22
23
24
25
THE WITNESS: Yeah.
BY MR. LUTTIVL.
O.
Mr.
the individual that
A. Yeah. !guess.
Q. Within the first year that you were dating
with Mr...,
he had used cocaine; is that
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Page 586
12:15. This is the end of Video Tape One.
(A brief recess was held.).
THE VIDEOGRAPHER: We're back on the
record at 12:17 p.m. This marks the beginning
of Tape Two.
BY MR.. LUTTIEFt:
Iti
you, while were you dating
while you were in high school you did
cocaine with him; isn't that right?
A. Yeah.
Q. And you started drinldng when you were
about 15?
Pro
Q. You were smoking pot in high school?
A. I wasn't — in high school l tried it once or
twice, didn't like it never clid it again.
Q. Okay. Mr. ME,
our bo riend at the
time, was the individual that
MR. MERMELSTEIN: Objection to fonn.
1
9
10
11
12
13
14
Page 588
MR. MERMELSTEIN: Objection, asked and
answered.
BY MR. LUTTIER:
Q. You never felt threatened when you were
with Mr. Epstein, did you?
35 (Pages 585 to 588)
PROSE COURT REPORTING AGENCY, INC.
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Page 589
Page 591
20
m atte] when
initially took you,
21
ook you to Jeffrey Epstein's and she told
22
you what was going to happen, did she specifically
23
tell you not to tell him your age?
24
A. Yeah, I think so.
25
Q. And so you dichit tell him your age,
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CERTIFICATE OF OATH
THE STATE OF FLORIDA
COUNTY OF PALM BEACH
I, the undersigned authority, certify that
JANE DOE NO.4 personally appeared before me and was
duly sworn on the 12th day of February, 2010.
Dated this 22nd day of February, 2010.
0 6444J.LC: cAisms
Cynthia Hopkins, RPR, FP
Notary Public - State of Florida
15
My Commission Expi
25.2011
My Commission No.:
16
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2 4
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Page 590
right?
A. Yeah, I didn't.
Q. You said, yeah, you did not?
A. I didn't tell him my age.
Q. Okay.
MR. MERMELSTEIN: I think we're out of
time. If there is anything pertinent --
MR. LUTTIER: I don't have any other
questions.
MR. MERMELSTEIN: Nothing further.
THE VIDEOGRAPHER: Going off the record at
1223 pa This marks the end of the
deposition.
(Witness excused.)
(Deposition was concluded.)
1
CERTIFICATE
2
THE STATE OF FLORIDA
3
COUNTY OF PALM BEACH
4
I. Cynthia Hopidm, Registered Professional
Reporter, Florida PrefasioratReperter aid Nola",
6
Public in and for the State of Florida at larpt, do
hereby co,* that Into sudvxned wand did
7
report said deposition in stenotype, and that the
foregoing pages we a Due and cared a:intent:nen
8
of my slxxthassd notes of said deposntect
9
I N:Ikr certify lint said deposition was
Sam at the time and puce harcinabon set forth
10
and that the taking of said deposition was commenced
and correletcd as Mien:above set out.
11
I fiance certify that I an rot attorneye
12
wand of any of the conies, nor anal a relative
or oriployce any aticcncy cc counwi of pub.
13
corrected with Sr action• nor am I finathally
imaested in the action
14
The foregoing certification of this transcript
15
does not apply to any repodunion of tit tame by
any means unless under the diettet COCIrni andfor
16 •
direction of the praying repxter.
11
Dated this 22nd day of Folmar)/ 2010.
19
20
21
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23
24
25
nn
n -7 CtittS
Hopitire, RPR,
Page 592
36 (Pages 589 to 592)
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Page 593
Page 595
t
DAM Newsy 22m2 2010
2
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/NE DOE NO. 4
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23
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Vey MA, Aum
1
ERRATA SHEET
2
IN RE: JANE DOE NO. 2 VS. EPSTEIN
at
Cynthia Hopidns
3
DEPOSMON OF: JANE DOE NO. 4
TAKEN: February 12th, 20'0.
S
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERB
PAGE # LINEN CHANGE
REASON
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Please (Award the original signed errata sheet to
this office so that copies may be distributed to nil
18
parties.
19
Under penalty of perjury, I declare that I brat read
my deposition and that it is true and correct
20
subject to any changes in form or substance entered
hat.
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DATE:
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24
SiGNATUREOP
25
DEPONENT*
Page 594
CERTIFICATE
2
3
THE STATE OF FLORIDA
4
COUNTY OF PALM BEACH
5
I hereby certify that I have read the foregoing
6
deposition by me given, and that the statements
7
contained herein are true and correct to the best of
8
my knowledge and belief; with the exception of any
9
corrections or notations made on the errata sheet,
10
if one was executed.
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12
Dated this
day of
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2010.
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JANE DOE NO. 4
••••1101:1=5,====.ttta
-J
37 (Pages 593 to 595)
PROSE COURT REPORTING AGENCY, INC.
Electronically signed by cynthia hopkins
Electronically signed by cynthia hopkins
Electronically signed by cynthia hopkIns
Electronically signed by cynthia hopkins
Electronically signed by cynthia hopkins
6f83eob3-b5a6-47c4-9336.1208fd1246d7
EFTA00724009
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