EFTA00724010.pdf

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NQ.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 DEPOSITION OF Friday, February 12, 2010 2:09 - 2:52 p.m. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1231 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-f430-4b0a-bb09-1)035b310829d EFTA00724010 EFTA00724011 Page 2 1 APPEARANCES: 2 Cm behalf of the Plaintiff. 3 SWART S. MERMELSTED4, ESQUIRE MEFtMELSTE1N & HOROWITZ, P.A. 4 18205 Biscayne Boulevard Suite 2218 3 Miami, Phone: 6 E-mail: Oa behalf of Defendant: 8 MARK T. LUTTIER, ESQUIRE BURMAN, CRHION. LUI 1 ibR & COLEMAN, I.LP 9 303 Banyan Boulevard Suite 400 10 West P *da 33401 Thorpe. 11 E-mail: 12 13 14 15 16 NO EXHIBITS MARKED • • • 17 18 19 20 21 22 23 24 25 Page 4 1 me know and I will explain it for you. 2 A. Okay. 3 Q. If you want to take a break during the 4 deposition, just let me know and you can take a 5 break. If during the deposition you recall 6 something and you think you need to correct an 7 answer or supplement an answer that you have already 8 given me, just let me know and you can do It. 9 There's no tricks. 10 A. Okay. 11 Q. Its a pretty informal procedure. If you 12 need something, just let me know. 13 Are you represented by a lawyer today? 14 A. He's my lawyer's witness. 15 Q. What? 16 A. Asa witness, he is my lawyer. 17 Q. So, Mr. Mennelstein is your lawyer? 18 A. Yes, sir. 19 Q. Do you know Jane Doe No. 4? 20 A. Yes. 21 Q. When did you first meet Jane Doe No. 4? 22 A. October '08 or September '08, I think. 23 Q And what were the circumstances when you 24 met her? 25 A. We was dating. Page 3 1 PROCEEDINGS 2 3 Deposition taken before Cynthia Hopkins, 4 Registered Professional Reporter and Florida 5 Professional Reporter, and Notary Public in and for 6 the State of Florida at Large, in the above cause. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Thereupon IMa having been first duly sworn or affirmed, was examined and testified as follows: DIRECT EXAMINATION BY MR. LUTTIER: Q. Can u tell us your name, please. A. Q. Mr. have you ever been deposed before? A. Excuse me? Q. This process, have you ever had a deposition taken before? A. No. Q. Okay. You understand you're under oath? A. Yes. Q. I am going to be asking you questions. If ou don't understand one of my questions,just let 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. I mean how did you run into her? A. I met her with some of her friends at a restaurant, like a restaurant bar. Q. Do you remember what restaurant bar it was? A. T ski bar. Q. A. A. Q. it. Page 5 Do you remember who the friends were? I think one of her friends was that v.as Q. Wouldthatbea A. Uh-buh. MR. MERMELSTEIN: You have to answer yes or no. You have to answer verbally because she is taking everything down. THE WITNESS: Okay. MR. MERMELSTEIN: So, if you say uh-huh or nod your head, it doesn't work. THE WITNESS: Okay. BY MR. LUTTIER: Q. What llow date of birth? A. Q. S9. that makes you how old? PROSE COURT REPORTING AGENCY, INC. 2 (Pages 2 to 5) Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430.4b0a-bb09-b035b310829d EFTA00724012 Page 6 1 Q. 1. You ever been married? 2 A. No. 3 Q. Getting ready to get married? 4 A. Considering. 5 Q. I am not going to tell what Jane Doe No. 4 6 said. 7 A. Yes. 8 Q. Do you plan on getting married to Jane Doe 9 No.4? 10 A. Yes. 11 Q. Okay. Any time frame? 12 A. No. 13 Q. Then can I assume from that that your 14 relationship and hers is pretty good? 15 A. Yes. 16 Q. You had a couple of rocky bumps in the 17 road? 18 A. Yes. 19 Q. There was a El thing in the 20 past? 21 A. What was that? 22 Q. There was a a 23 A. Yes, sir. 24 Q. Has that an all been smoothed over? 25 MR. MERMELSTEIN: Objection to font'. 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 7 1 THE WITNESS: Yes. 1 2 MR. MERMELSTEIN: If I make an objection. 3 it's to the form of the question just for the 3 4 record. You've got to answer the question 4 5 unless I tell you not to. 5 6 THE WITNESS: Okay. 6 7 BY MR. LUITIER: 7 8 ,Have, have you spent any time with= 8 9 and Jane Doe No.4 together since you first 9 10 met her? 10 11 A. Yeah es. 11 12 Q. Is M still someone that comes around 12 13 a lot? 13 14 A. No. 14 15 Q. Do you ;mow why? 15 16 A. No. 16 17 Q. Do you know who Jane Doe No. 4's best 17 18 friend is now? 18 19 A. She's got a couple of friends in . Do 19 20 you vault the name? 20 21 Q. Yeah. 21 22 A. and Jane Doe No. 7 probably. 22 23 4 . And would that 23 24 A. Yes. 24 25 l:Z Are these People-.LeliaLbo atz:m uld 25 this, do you all live together right now? A. Me and Jane Doe No. 4? Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Yes. Yes. I Where do you live? W tfa address? s ”a Me ent? Yeah. Is that one that you have been in? It's a condo. I own it. Condo. Yeah. Pay E: Q. And were you living there before you met Jane Doe No. 4? A. Yes. Q. And after you met her in and around September of'08, did there come a time that she moved in? A. Was there what? Q. Did there come a time that she moved in with you after September of '08? A. Yes. Q. And do you know about when that was? Page 9 A. After I think. it was right before stmt & 'hat would be when she front El . es. Q. Was she still at when you were dating her tally? A. Yes. Q. Let's see. she still have A. !twits Q. H y. So, you would have been dating since September of'08 until June of '09? Did you go down and watch hand stuff Ince that? A. A couple times. Q. Did you grow upa A. Yes. Q. Where did you go to school? A. High School. Q. i! would you describe your relationship with Jane Doe No. 4? A. Now everything is good. Q. Any problems that you've identified? A. Now? If it's September of'08, did PROSE COURT REPORTING AGENCY, INC. 3 (Pages 6 to 9) Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-(430-4b0a-bb09-b035b310829d EFTA00724013 Page 10 Page 12 1 Q. Yes. What were they?e 1 A. At least seven times. 2 general problems that led to th 2 Q. Over about what period of time? 3 incident? 3 A. What is it now? February. Before Christmas 4 A. There was a lot of anger and confusion and 4 probably. Let's see. No, like November and December. 5 emotional, you know, a lot of stuff from the past and a 5 . ' uld have been after the 6 lot of emotional, you know, stress and problems. 6 incidence? 7 Q. And was that anger and confusion on her 7 A. What, that we went there? 8 part or on your part? 8 Q. Yeah. 9 A. Was it what? 9 A. U before. 10 Q. Anger and confusion on her part or on your 10 incident was 11 pert? Was she the one that was angry with you, or 11 ink you started 12 were you the one that was angry and confused? 12 going there befo 13 A. She was. 13 A. Yes. 14 Q. And how did you get all that resolved? 14 Q. Okay. How far before that? 15 A. We went to a counselor. My, I have a family 15 A. Probably a couple of months. 16 counselor we go to like my parents and, you know, it's 16 Q. ions do you think you had 17 for relationships as well, helps out. She was just able 17 bet'o 18 to talk to someone and let it, you 'mow, out what was 18 A. Five. 19 bothering her. 19 Q. With freguency were you 20 Q. !stills o so ing? 20 going bef 21 A. Huh? Yeah. , 21 A. Like weekly. 22 Q. And were you going to Mr.". before 22 Q. Okay. Hour sessions? 23 you ever met Jane Doe No. 4? 23 A. Yeah, yts. 24 A. No. 24 Q. What were the issues that were being 25 Q. How is it that you first came to go to 25 discussed as they related just to you and her? Page 11 Page 13 1 him? 1 A. Well, just her issues and problems that she 2 A. My mother. It's our family history like 2 has, you know, regarding her past. 3 started going there after I met Jane Doe No. 4 and me 3 Q. What were those? 4 and her went. 4 A. Just a lot of anger she had built up, and she 5 Q. Were you going to him after you met Jane 5 needed to let it out and talk to someone. 6 Doe No. 4 for issues that you had with your family? 6 Q. Anger built up about what? 7 A. Yes. 7 A. Her past. 8 Q. And was she initially going with you in 8 Q. Anything in particular about her past? 9 what we would calla supportive role just going 9 A. I didn't really get into everything. Like, 10 along with you while you talked about your issues in 10 she went by herself too, you know. 11 your family? 11 y herself prior to 12 A. Yes. 12 13 Q. And when she went did she just ride up to 13 A. Yes. 14 the office with you, or did she actually go in and 14 Q. Are you sure of ? The reason I 15 meet with you and the counselor? 15 ask you is we took Mr. de ' ' is 16 A. She came in. 16 agaits don't indicate visits prior to 17 Q. Okay. When she came in with those, with 17 ME? 18 you on those sessions, were those sessions just 18 A. That she never went there? 19 concerning issues that you had with your family? 19 Q. No. Prior to that date. He has got 20 A. Just everything pretty much. 20 records of visits after that date. 21 Q. Were there any issues about you and her 21 A. Before. 22 that were discussed when she went with you? 22 Q. w because you can relate 23 A. Yes. 23 it to die . 24 Q. How many times did you and she go 24 A. I would have to check my records and my. like, 25 together? 25 copies of my checks like when I wrote them. leant 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-14304b0a-bb09-b035b310829d EFTA00724014 Page 14 Page 16 1 retail the exact date, you know. 1 A. Unh-unh. 2 Q. So, did you go alone sometimes to him? 2 Q. It was just that the two of you would 3 A. We would both go together and sometimes she 3 argue from time to time? 4 would go first and sometimes we would go together. 4 A. Yeah. It was basically, basically that, yeah. 5 Q. Were you working on issues of conflict 5 Q. When people use the word *basically; I am 6 between the two of you? 6 always suspicious because that indicates to me that 7 A. Some of that and the other with her. 7 there is something else. 8 Q. I know, but were you guys having problems? 8 A. Yeah. That's why we went there for, for the 9 1 mean you guys were squabbling about something? 9 relationship and for, you know, so she could talk to 10 A. Just normal relationship issues, you know. 10 someone about what was, you know, what's bothering her. 11 Q. Did you, did you ask her to go up there 11 Q. So, do you — had something occurred that 12 with you? 12 you would come to the conclusion there must be 13 A. We both agreed on it. 13 something bothering her? 14 Q. Okay. What is it that made the two of 14 A. When she maid drink, she was just — anger 15 you — what was it that was the issue that made the 15 was built up in hor, you know. 16 two of you say let's go see this guy? 16 Q. Now, so was it that you made the 17 A. So, we can, you know, work out, work on our 17 observation that when she drank she was, for lack of 18 relationship, and so she could, you know, be happy and 18 a better term, an angry drunk? She would get angry 19 talk about her problems. 19 when she drank? 20 Q. Was there anything specific? For example, 20 A. She would take everything out on me. 21 I am just going to give you a hypothetical. Let's 21 Q. Okay. All right. You would be the bad 22 say you had a habit of coming borne and throwing your 22 guy? 23 laundry on the floor and that drove her nuts so you 23 A. Pretty much. 24 guys would fight about that So, you said we're 24 Q. Can you give me sort of an example of what 25 going to go see this guy and were going to say, 25 would happen? Page 15 Page 17 1 yeah, we're going to see this guy because I used to 1 A. Well, when she drank, she would just — I mean 2 have a habit about throwing my laundry on the floor 2 the only way she knew how to let it out was like go out 3 and it upset her. And that's what I'm talking 3 and drink and, you know, that she would think about her 4 about. 4 past and let everything out on me, you know. 5 A. It wasn't really about that. 5 Q. Would it be situations where the two of 6 Q. Well, I was using that as a — 6 you would be going out and drinking together, or she 7 A. Yeah. I know but nothing like that 7 would go out and drink and cane home and unleash on 8 Q. Did you guys find yourselves fighting 8 you? 9 about things? 9 A. Together. 10 A. Yeah. We argued about things, you know. 10 Q. So, you and she would go out to a bar or 11 Q. What kinds of things did you argue about? 11 something and start drinking? 12 A. You know like when we would fight, you know, 12 A. Everything would be fine and good and then as 13 just arguments. I can't recall exactly. 13 soon as — later that night that's when it would start, 14 4 I mean did she say you drank too much for 14 you know. 15 example? 15 Q. And there was at least the one time where 16 A. No. 16 it was a physical confrontation? 17 Q. Was there a drug use problem? 17 A. Was it what? 18 A. No. 18 Q. At least one time it was a physical 19 Q. Somebody said somebody used drugs? 19 confrontation? 20 A. No. 20 A. Well, just a bad argument. And I mean, l 23. Q. You wanted to go out too much? 21 never touched her or nothing like that, w. 22 A. No. 22 . Well, I was referring to 23 Q. You stayed out too late? 23 ling but she touched, 24 A. No. 24 A. Yeah. She might have yeah. 25 Q. Anything specific? 25 Q. How long was it into your relationship 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia bodkins 6dc078c7-f430-4b0a-bb09-b035b310829d EFTA00724015 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 18 that you noticed that when she drank she got angry? A. Well, when we started getting serious like after, like before Christmas like when, you know, we knew each other better and started caring about each other more and getting Q. W incident A. Before. Q. Okay. All right. So, then it had to be two or three months before Christmas? A. Uh-huh. Q. So, when the incident -- A. Yes. Q. So, w happened o you-all had gotten into a deeper, more serious relationship? A. Yes. Q. And you had been going to counseling because she would get angry when she drank? A. Yes. Q. Had she ever hit you up until that point in time? A. No. Q. And how was her anger vented to you? A. Huh? the Meld Page 1 A. No. 2 Q. No. So, she would just come home and tell 3 you you were an asshole? 4 A. Come home and after drinking, and that's what 5 would happen. 6 Q. How much drinking were we talking about? 7 Would she be drunk? 8 A. Yes. 9 Q. Was one of the problems the quantity of 10 alcohol being consumed? 11 A. Maybe like liquor, you know. 12 Q. I mean was one of the things, look, you 13 need to cut back on the alcohol because when you 14 drink you're, it's not fun? 15 A. Yeah. Beer, I mean she drinks beer, you know, 16 she wasn't as bad, you know. But the liquor is when it 17 really came out. 18 Q. So she - did you observe then during that 19 relationship that you thought maybe she had an 20 alcohol problem? 21 A. I didn't think that she had an alcohol problem 22 I just thought that she had a lot of things built up and 23 she needed to talk to someone. Just like, you know, 24 people, a lot of people have problems and they need to 25 talk to someone and get help with what's bothering them. Page 19 1 Q. By that I mean would she be yelling and 2 screaming at you? 3 A. Yes. Just saying mean and nasty things. 4 Q. Nasty things like what? 5 A. Like name calling and, you know, just saying 6 rude things; name calling and saying rude things. 7 Q. What kind of names would she call you? 8 A. Well, just bringing up stuff from like -- it 9 didn't, stuff that didn't make sense. She would just 10 say, you know, like, I am an asshole or stuff like that. 11 And she would just, when she drank, you know, all the 12 anger — I don't even know, it just came out on me 13 ber-mke I was the only one there and that's how she knew 14 how to let it out. 15 Q. And anymore than calling you an asshole? 16 A. Just, you !mow, I can't recall exactly, you 17 know, what she called me, what she said. 18 Q. Would she accuse you of specific conduct 19 or doing specific things? 20 A. No. 21 Q. For example, I am not saying this happened 22 but this is an example: She would get drunk and you 23 would coma home and she would be mad and she would 24 say, you know, you were looking at other girls in 25 the bar, that kind of thing? 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 21 Q. After going to this counselor, did she cut back on the amount of alcohol she drank? A. Yes. Q. Does she drink now less than she did then? A. Yes. Q. Do you think that's been helpful? A. Yes. Q Any belief by her that you had a problem drinking too much alcohol? A. (Witness shakes head.) Q. Anybody ever accuse you of drinking too much alcohol? A. No. Q. Have you ever had a problem with alcohol? A. No. Q. When you would go out were you sober when you came back? A. Sometimes. Q. Can I assume that when you guys went out at least one of you were sober? A. Yes. I was driving but I had a drink or two. Q. But she would be as they would say 'a couple of sheets to the wind"? A. Yes. I. All right. Did ou attempt to • her to PROSE COURT REPORTING AGENCY, INC. 6 (Pages 18 to 21) Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b035b310829d EFTA00724016 Page 22 cut back on the drinking before you started going to the counselor? 1 A. Yes. 4 Q. And is that what drove you to the counselor initially, not you individually but the 6 two of you together? 7 A. What, the drinking? 8 Q. Yeah. 9 A. Yes. That, the drinking and the, just the, 10 you know, normal relationship issues, you know, that and 11. basically, yeah, the drinking. 12 Q. Okay. In other words a person said, look, 13 this alcohol is creating a problem; we have to 14 figure out a way to get that under control. Is that 15 a fair statement? 16 A. It wasn't all about the, about that, no. 17 Q. Well, was the result of going about that 18 and then the counselor dug in a little bit to try to 19 find out what was going on? 20 A. It wasn't about just the drinking. It was 21 about her past, you know, and why she would drink so 22 much. 23 Q. Okay. 24 A. You know, and why she was doing the things she 25 was doing. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page drink? Q. Right A. Yes. Q. So, you have an idea of when people get dmnit? A. Yes. Q. And when they can't remember things they did the night before? A. Yes. Q. That's generally an indication that they had too much to drink? A. Yes. Q. And she was drinking at a level where she wouldn't remember what went on? A. Not all the time. Q. But sometimes? A. Couple times. Q. And when, how much drinking are we talking about? If you would go out, for instance, to a bar, are we talking about drinking two or three drinks or are you talking about we would be there for four or five hours? A Like five drinks and then some shots, you know, probably four drinks depending on what she was drinking, either wine or sometimes beer or alcohol, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 J•44.1) Page 23 Q. Other than drinking, what else was she doing? A. lust, other than drinking, that's it. That's all she does. Q. Did you ever ask her why she drank so much? A. No. She's just young, and when I was that young, I drank a lot, too. Q. What's your age difference? Let's see. You're she's A. She's Q. So, she never said anything to you about why she drank or why she got angry at you after she drank? A. She never said anything. She never said why she drank Like, she would start off normal, you know, and then after a while just she never -- she don't, she didn't remember what she was saying, you know. She don't even recall. Q. Can I assume that you have some experience with being around people that have too much to drink that you acquired during your lifetime? A. Do I? Q. Yeah. A. Have I been around a bunch of people that Page 25 1 liquor. 2 Q. Plus shots? 3 A. Well, yeah, we would have a few shots, yes. 4 Q. Was there ever any particular incident 5 that happened when she was drunk that sod of caused 6 )ou to say, look, stop, we have got to do something 7 about this? 8 A. When she was drunk? 9 Q. Yes. 10 A. Yes. I mean, the only time that like when I 11 said that, you know,1 said, well, wait until the next 12 day so we can talk normally, you know, and then you know 13 what were talking about and you remember what you're 14 talking about, because when people drink or when people 15 are intoxicated, they don't, you know, remember what 16 they say or what they do or you 'WOW. 17 Q. Okay. So, when you went with her and had 18 sessions with this fellow, those sessions that 19 concerned your relationship, what did she tell the 20 counselor? 21 A. I wasn't in, I wasn't in there maybe one time 22 with her when she went for her personal matter, you 23 know. 24 Q. So, she kept that with the counselor? 25 That was between than? 7 (Pages 22 to 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc075c7-1430-4b0a-bla09-h035b310829d EFTA00724017 Pace 2 6 A. Yes. 2 Q. Did she ever share that with you? 3 A. No. 4 Q. Did she ever tell you whatever the problem 5 was? 6 A. Well, I mean like you can read stuff online 7 about, you know, what went on, and that's MI pretty B much know. 9 Q. Are we talking about this fellow Jeffrey 10 Epstein? 11 A. Yes. 12 Q. Is that — what you keep saying her past 13 and stuff, is that what you're referring to? 14 A. Yes. 15 Q. Is there anything other than her 16 involvement with Mr. Epstein? 17 A. No. 18 Q. What has she herself told you about her 19 involvement with Mr. Epstein? 20 A. I mean, I read stuff online and like I really 21 don't know everything, you know. 22 Q. Is your only knowledge — 23 A. I don't really want to, you know, like right 24 now. 25 Q. Is your only knowledge whet you read Page 27 1 online? 2 A. Yes. 3 Q. That would be newspaper articles? 4 A Yes. Q. How about any of these friends that you 6 said that she had, Jane Doe No. 7 comes to mind, 7 would they talk to you at all? 8 A. No. 9 Q. Do you know whether or not Jane Doe No. 7 10 had an experience with Mr. Epstein? 11 A Do what? 12 Q. Do you know whether or not her friend, 13 Jane Doe No. 7, had any interaction with 14 Mr. Epstein? 15 A. No. 16 Q. Okay. So, you grew up locally, went to 17 local high, played ball in school? 18 A. Yes. 19 Q. WhatdidvouDla 20 A. 21 Q. For Hi 22 23 for kit tl. laY kir I PlaYed 2; iYI -24;edlu zzosmaiS n? anclaglaYed 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 28 fora little bit. Q. Okay. Did you go away to college anywhere? A. I went to ■ for a semester and then came back Q. I understand that a got . I was for five years and then I had a chance o u iness ou know. an arid stuff like that. Q. And that's you, in that business now is you and your brother? A. Correct, yes. Q. What's the age difference between you and your Q. Is he older or are you older? A. I'm older. Q. So, you're guiding your younger brother through the business? A. Yes. Sassume he grew up locally and did he go to High too? A. Yes. Q. All right. So, you went through the usual Page 29 high school, post high school stuff. Does anything about Jane Doe No. 4's past color your opinion or *cling towards her at all? A. No. Q. I mean you feel about her, you don't hold her past against her or anything like that? A. No. Q Asa matter of fact do you, do you not even care to know about her past? A. I would, I would like to, you know, eventually. Q. Whagaou know about her past? You knew she played MI right? She was a high school athlete? Yeah. Played wan to M. Grew up out there in Q. Oot a scholarship at — aR . A. Smart. Q. You knew she had to be a pretty good athlete to get a scholarship. A. Yes. Q. And you played pretty good tell fora high school student; you knew what that would require? 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. • Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b035b310829d EFTA00724018 Page 30 1 A. Yes. 2 Q. And she's smart? 3 A. Yes. 4 Q. Were you an academically inclined 5 individual in high school? 6 A. Average. 7 Q. Okay. She was a hard worker, you figured 8 that out? 9 A. Yes. 10 Q. Okay. So, she kind of kept whatever she 11 was talking to this counselor about between he and 12 you. Did you ever have discussions with her about 13 any changes in her conduct or did it just kind of 14 take place? 15 A. About what? 16 Q. Any changes in her conduct or did she just 17 start to change? 18 A. You mean now? 19 Q. Yeah. From the time you guys first 20 started going until now. 21 A. Yeah. I mean, yes. She, she's changed, you 22 know. Everything's, you know, everything is getting 23 better, you know. 24 irin when you had the 25 incident — 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And then did she come living with you again? A. ou know, ban Page 32 back and start ou to wait for that A. Yeah. Q. You told th A. Yes. ing out because we had a to got resolved? Q. So, they decided not to eventually? A. Yes. Q. Okay. She drinks less now than she did? A. Yes. Q. She doesn't get angry at you anymore? A. No. Q. I am going to guess she doesn't call you an asshole very much, occasionally, not a lot? A. Sometimes. No. Q. And my guess is you don't call her any of those names? A. No. Q. Okay. Nice lady? A. Huh? Q. Nice lady? A. Jane Doe No.4? Page 31 1 A. We hadn't had any problems. 2 Q. What led to that? Was that following a 3 night out drinking? 4 A. Yes. 5 . And I gather from reading 6 that you were unhappy with et il.fi n t ought 7 may she should go someplace other than your 8 apartment? 9 A. Yes. 10 Q. And it appeared from 11 that she had a different idea? 12 A. Yes. 13 Q. She was a little more physical about 14 wanting to stay at the apartment? 15 A. Yes. 16 Q. And did you and her go back to the 17 counselor after that incident? 18 A. Yes. 19 Q. How Ion was it — I know th took her to 20 ■ for a When s 21 did she come back and move in with you 22 A. No. 23 Q. How long were you and she apart so to 24 speak? 25 A. Couple of weeks. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 33 Q. I said she's a nice lady A. Yes. MR. MERMELSTE : Objection to form. BY MR. LUTTJER: Q. What's your hope that you and she will get married and have a family? A. Yes, one day. Q. Okay. Do you wan A. Yes. Q. You guys have talked A. Yes. Q. Something she wan A. Yes. Q. You're happy at your A. Yes. Q. Does she do a little business? A. She helps me. Q. And do you know wl A. She, I think she want mow forward from there. Q. She wants to t A. Yes. Q. And you're going to to do that? o have kids? about that? to do? business? bit of work at your tat her plans are? s to get her ill? upport her in trying and 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by cynthla hopkins Electronically signed by cynthia hooking Electronically signed by cynthka hooking IScle078e7-f430-460a-bb09-b036b310829d EFTA00724019 Page 34 1 A. Yes. 2 Q. You think that's a good thing? 3 A. Yes. 4 Q. Does she have your complete support in 5 doing whatever she wants to do? 6 A. Yes. 7 Q. Okay. What has she ever told you about 8 Jeffrey Epstein or her involvement with him? 9 A. What has she told me? 10 Q. Yep. A. Not, not that much. !mean, l have read a lot 12 of it online, what happened and what was going on and 13 stuff he was doing. And we really, really didn't 14 discuss it too much besides what I saw online. 15 Q. Does it really matter to you to find out 16 the particulars? 17 A. Yes, it mattered. 18 Q. Did she tell you for what period of time 19 she was interacting with Mr. Epstein? 20 A. I just know it was when she was underage. 21 Q. Did you know that she continuing to go 22 after she was 18? 23 A. Huh? 24 Q. Did you know she continued to go after she 25 was 18? Page 1 Q. Mentally does she seem okay? 2 A. Yes. 3 Q. Do you know of any defect that she has at 4 all? 5 A. No. 6 Q. When was the last time you and she went to 7 see this counselor? 8 A. She goes. I haven't been. I haven't been 9 able to make it up there. 10 Q. When was the last time you went? 11 A. Before Christmas I think. 12 Q. Okay. I took her deposition this morning 13 and she said that since November, which is the last 14 time the therapist had a record of her goi ' 15 been oir v:dwhen she was driving from 16 down went by his office and went in to look 17 at his aquarium. 18 A. Okay. 19 Q. Do you know of any visits other than that? 20 A. No. I mean, I don't, sometimes I don't even 21 know she goes, you know, because I am real busy at work 22 and she's busy, you know. 23 Q. Do you pay for when she goes or does she 24 pay? 25 A. No, she pays. Page 35 1 A. No. 2 Q. Has she ever mentioned to you in any way 3 Mr. Epstein in any conversation? 4 A. Just when she had to go to her, to go to court 5 and just deal with her lawyers and her deposition she 6 has to go to, stuff like that. 7 Q. Like today? 8 A. Earlier this morning and last night. 9 Q. Her lawyer is — is Mr. Mennelstein her 10 lawyer? 11 A. 'guess. 12 Q. Okay. And what does she just tell you 13 she's got to go take a depo and that's the substance 14 of the conversation? 15 A. Pretty much, yeah. She said she had to go in 16 one time, one more time. 17 Q. Okay. Have you ever been out with her 18 anywhere in public and not when there is drinking 19 going on but seen anything unusual about her, her 20 having any kind of physical problems or reactions or 21 anything? 22 A. No. 23 Q. Do you know of any physical problems that 24 she has? 25 A. No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 37 Q. Okay. A. I mean, I have paid before„ you know. Q. Were you ever in any session with her with this counselor where Jeffrey Epstein's name ever came up? A. She might have mentioned like her — she might have mentioned something but I wasn't in there for all the details. Q. You have been dating now fora year and a half or so? A. Uh-huh. Q. When I asked you earlier if there was anything about her past that you wanted to know you said a couple of different things in response. One time you said, yeah, you would want to know. A. Yeah. Q. What is it about her past that you would want to know? A. About her past? One day I would like to sit down with her and talk to her about everything, you know, that went on with her. Q. Her, specifically her and Epstein? A. Yeah. you know a guy by the name of 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins eck078c7-1430-4b0a-bb09-b035b310829d EFTA00724020 Page 38 1 A. Yes. 2 Q. How much do you know about him? 3 A. Not much. I just know she dated him. 4 Q. Did she ever indicate to 1 • s 5 herself, had been a victim o 6 1 t ebody has committed acts of 7 her? 8 A. Huh? No. 9 Q. Did she ever mention to this counselor any 10 of that? 11 A. I don't recall. I can't remember if she did. 12 I just know she dated him and that's pretty much it. I 13 didn't really get into all the details of them. 14 Q. Did you ever look him up online? 15 A. Have 1? 16 Q. Yes. Yes. 17 A. Yes. 18 Q. What did you fmd out about him? 19 A. Piece of crap. I don't know. He's just — I 20 saw ifs like he got arrested and stuff. Just curious. 21 Q. If you-all live together, you-all sleep in 22 the same bed? 23 A. Yes. 24 Q. Do you have any problems, sleep problems 25 going to bed at night? Page 39 A. What? 2 Q. Do you have any sleep problems? Are you 3 one of those guys that goes to bed and gets to sleep 4 right way? 5 A. Sometimes I have problems sleeping. But most 6 likely when I'm out, I'm out. I work. 1 work hard, 7 come home, eat. Sometimes I pass out. Sometimes I stay 8 up late. 9 Q. What are your observations about her sleep 10 habits? 11 A. Her sleep habits are pretty good. 12 Q. Is your sexual relationship satisfactory 13 to you? 14 A. Yes. 15 Q. Has she indicated to you that your sexual 16 relationships are satisfactory to her? 17 A. Yes. She says, yes. 18 Q. Any complaints from her? 19 A. No. 20 Q. That is I say any complaints, I mean any 21 complaints about you or any complaints about her? 22 A. No. 23 Q. Voiced by her? 24 A. No. 25 Q. Is there anything about her that you would Page 40 1 want to change about her? 2 A. No. 3 Q. Have you met her parents? 4 A. Yes. 5 Q. Where did ms? 6 A. At one of hi nd when they come 7 in town to visit. 8 Q. Do they come over to your place? 9 A. Yes. 10 Q. Get along well with them? 11 A. Yes. 12 Q. And she's been to your parents? 13 A. Yes. 14 Q. And they get along well with her? 15 A. Yes. 16 Q. When was the — what is the most amount of 17 time you spend with Jane Doe No. 7? 18 A. Randomly, rarely. 19 Q. I mean does she, for example, does she 20 have her girlfriends come over and they are at home 21 when you get home and stuff like that? 22 A. Sometimes. We normally do everything 23 together. 24 Q. So, do you work six days a week? 25 A. Sometimes on Saturdays. Normally five. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 41 Q. Okay. And what are your recreational pursuits? You're outdoors type people? A. Fishing, boating. diving, surfing. Q. And does, does Jane Doe No. 7 ever go along with you on those things? A. She has been on the boat a couple times or one time I think. Q. And what kind of have you and Jane Doe No. 4 taken vacations together? A. Yes. Q. And where, what kind of places have you gone? Wa nt to the and the Q. Have a good time? A. Yes. Q. Have a fun time when you're on vacation when you go? A. Yes. Q. Does she make you happy? A. Jane Doe No. 4? Q. Yes. A. Yes. Q. And as far as you can tell, you make her ha py? PROSE COURT REPORTING AGENCY, INC. 11 (Pages 38 to 41) Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c74430-4b0a-bb09-1D035b310829c1 EFTA00724021 Page 42 1 A. Yes. 2 Q. Has she ever given you a list of 3 complaints about you? 4 A. No. 5 Q. Okay. Did she tell you she loves you? 6 A. Yes. 7 Q. You tell her you love her? 8 A. Yes. 9 Q. Has she ever complained to you that she's 10 had any kind of physical problems during the day? 11 A. No. 12 Q. Ever complain about flashbacks or anything 13 like that? 14 A. No. 15 Q. Ever complain about an inability to get to 16 sleep? 17 A. No. 18 Q. What, if anything, do you know about any 19 drug usage in the past by her? 20 A. No, none at all. 21 Q. Do you ' the name or a woman 22 by the name o 23 A. Yes. 24 Q. And have you met her? 25 A. Yes. Page 44 1 found her sitting in the corner crying 2 uncontrollably or something like that? 3 A. She's been upset, you know, like after her 4 seeing the counselor and stuff like that. 5 Q. Okay. And if she goes to see the 6 counselor, she might come back upset for a while? 7 A. Yes. 8 Q. And then she is fine the next day? 9 A. Somewhat, that I could see. 10 Q. Does she ever tell you what she was upset 11 about after corning back from the counselor? 12 A. Not in details, just discussing her past. 13 Q. When you say discussing her past -- 14 A. Jeffrey. 15 Q. Is that generally what she says is 16 discussing her past? 17 A. Yes. 18 Q. Does she define whether it's necessarily 19 limited j • r %whether it includes 20 things li and a few other things? 21 A. Just Epstein. 22 Q. When did you first find out she was 23 bringing a lawsuit against Mr. Epstein? 24 A. I can't remember. 25 Q. Was it early on in your relationship? 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 43 Q. Where have you met her? A. I think we, when we went out one night. Jane Doe No. 4 introduced me to her. We ran into her that was it. Q. So, you met her one time? A. Yes. Q. So, have you ever observed anything that appears to be any kind of problem with Jane Doe No. 4? A. Have I ever observed — MR. MERMELSTEIN: Objection to form. MR. LUTHER: Yeah. Anything you thought was a problem. MR MERMELSTEIN: You can answer if you understand the question. THE WITNESS: Have I ever observed anything that what? MR. LUTHER: -- you thought was a problem with Jane Doe No. 4. THE WITNESS: That I thought was a problem? MR. LUTHER Yeah. THE WITNESS: No. BY MR. LUTTIER: For instance, you never come home and 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 45 A. Probably halfway or something. Q. Do you know who else knows that she is a Plaintiff bringing a lawsuit against Mr. Epstein? A. No. Her family, that's it. Q. And she's never had any discussion with you about Jeff Epstein? A. Just not in detail about what not much. Q. Okay. If she's does, will you just tell her, forgot about it, don't worry about it? A. !just told her its not her fault and, you know, pretty much what you said. I mean, can't dwell on it, you know, talk about it and let it out. MR. LUTTIER: I don't have any other questions. MR. MERMELSTEDI: I don't have any either. THE WITNESS: That's it? MR. LUTTIER. Yeah. THE COURT REPORTER: Do you want to order this? MR. LUITIER: Yes. THE COURT REPORTER: Would you like a copy? MR. MERMELSTEIN: Yes, I will get a copy. Thanks. Okay. (Witness excused.) PROSE COURT REPORTING AGENCY, INC. 12 (Pages 42 to 45) Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b035b310829d EFTA00724022 Page 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Deposition was concluded.) 1 2 3 1 5 6 7 a 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH I, Crank Hockina Repaired Einflusional Reporter, F/Drida Professional Reporter, sod Notay eiblic In and fa the Stile of Florida at huge, do hereby certify Elitism authorized so arid did report said deposition in stonMypo; and that the foregoing rages axe a true and coned transaiption of ray shcnthand notes of said deposition I fUrther ce, that said deposition me taken at dre lime and pace bereinabow ca bib and that the taking of said dopositom was commenced and completed as here/whose set at. I WS certify that I am not attorney or camel of any of the panics, our an I a relative or employee of any attorney or counsel of pany connected with the action nor am I financially thurestol in the action The foregoing certificationof des ttartocript does not only to any reproduction of the same by my mean unless under the direct control andsx direction of the tangelo; repeater. Dated this and day of Febnuuy, 2010 4a 4g,si, *AS Hopkins. RP& ER Johli123I 1 2 3 4 5 6 7 Et 9 10 11. 12 13 14 15' 16 Page 47 CERTIFICATE OF OATH THE STATE OF FLORIDA COUNTY OF PALM BEACH authority, certify that personally appeared before me and was duly sworn on e 12th day of February, 2010. Dated this 22nd day of February, 2010. Orpikizn-: 44/0As Cynthia Hopkins, RPR. FPR 17 Notary Public State of Florida My Commission Expires: February 25,2011 18 My Commission No.: DD 643788 19 Job #1231 20 21. 22 23 24 25 1 2 3 a 6 9 10 11 13 11 15 16 17 18 19 20 21 22 23 24 25 DATE TO: distiob 11231 STUART TEIN, ESQUIRE. 1.*F ENot NORM= RA 12205 Biscayne Boulovad Suite 2218 Mani, Florida 33160 Di RE: JaneDoc No 2 vs ;effigy Epstein CASE NO.: 08c/40119-MARRA/JOHNSON Please Se maim that on Friday. the 17th of Fetroary, 2010, you pro yotr deposition io the atommethrod monor. At duo tient you did not waive signature. It is now lithetSaly Marra sign yew dopottiort Math call ow other at the telowthrted Wu toothed& an acominoment taween Mohan of 9.00 am and 4:30 pm, Monday through Friday, at the Esgoire office located rinumi you. If you!. not nod mil tiger the rkposIdat within snsionable time, the original. which bit oath born for aided to the adoring wormy, may be filed with thirChnk elthe Comet If you widi ionise yaw groefl sign yew ant in the Hank m die bathe of No lest, and mum it to is Very truly sours, Cynthia Hopkins, ReR, FPR 1 de hereby wren my simmers tri a wa li sangt twicLutda, Esquire Swan Mennehiem Esquire No copy PROSE COURT REPORTING AGENCY, INC. 13 (Pages 46 to 49) Electronically signed by cyntHa hopkins Electronically signed by cynttits hopkins Electronically signed by Cynthia hopkins 6dc078c74430-4b0a-bb094)035b310829d EFTA00724023 Page 50 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 B my knowledge and belief, with the exception of any 9 corrections or notations made on the errata sheet, 10 if one was executed. 11 12 Dated this day of 13 2010. 14 15 16 17 18 19 20 Job #1231 21 22 23 24 25 Page 51 ERRATA SHEET IN RE JANE DOE NO 2 VS JEFFREY EPSTEIN CR: CyrAia HopE DEPOSMON OF: TAKEN. February I , lu 4 J06 NO.:1231 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGEiI LINE I CHANGE REASON 9 10 11 12 13 14 15 16 17 Pk= Award the original srgned errata sheet so this office so the copra nay bet/Mauled to ari le patties 19 Under malty of peijmy. I declare that I have read my deposition and that it is nue and correct 20 stbject to nny changes in form or substanos entered here 21 22 DATE: 23 24 SIGNATURE OF DEPONENT: 25 -waSINIIMIlr=====1111INII PROSE COURT REPORTING AGENCY, INC. 14 ( Pages 50 to 51) Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b0351/310829d EFTA00724024