STATES DISTRICT COURT

Page 1 STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME I OF II Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 VIDEOTAPED COMPULSORY MEDICAL EVALUATION OF E.W. Wednesday, November 11, 2009 9:02 - 6:30 p.m. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting Services PROSE COURT REPORTING AGENCY, INC. Eiectronically signed by Jeans Fascist' (601 31,7135dc-3693-4b9f-b60e-98638afea746 EFTA00723630 EFTA00723631 Page 2 Page 4 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 BRADLEY1 EDWARDS, ESQUIRE 1109 Northeast Second Street 4 Phone:Hall 33009 5 6 7 On behalf of the Defendant 8 ASHLIE STOKEN-BARING, PARALEGAL BURMAN, CRITTON, LUTHER & COLEMAN, LLP 9 303 Banyan Boulevard Suite 400 10 West P 'de 33401 Phone: 11 12 13 ALSO PRESENT: 14 Dr. Ryan Hall, M.D. 15 16 Jeffrey Abbot, Videographer Visual Evidence, Incorporated 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 A. Okay. Q. Again, my assistant is sitting in the room. If you wouldn't mind, just — MS. YOUNG: Hi. Matisse Marissa? Hi. I'm BY DR. HALL: Q. I believe that was an arrangement worked out between the lawyers that there be one person present. A. Okay. Q. As you can tell from the camera, we're going to be videotaped. I don't know what the agreement is in terms of who owns the tape, if that's going to be your attorney, shared attorneys. Iles not my — A. Okay, that's fine. Q. This will be probably six to eight hours, dependent. But if at any time you need to take a break, you would like to get something to eat or water, anything like that, just let me know. A. Okay. Q. I'll be keeping track of the time and things along those lines. 1 don't know what's going to be done for lunch. The last time, f didn't know it was going to be in a different office, so Pm assuming whatever the lunch break is, theyll wrangle up a sandwich or something for us. Page 3 1 EXAMINATION 2 3 BY DR. HALL: 4 Q. If you want to, write the name of your counsel t, in. o A. As in Brad? Q. As in Brad, yeah. Then, also, we're going to be doing some 9 testing later on. This is again, I think this was in 10 the original packet we sent you. I'm not sure if you 11 received that or not, the patient history questionnaire. 12 A. No. 13 Q. You did not get that? 14 A. No. 15 Q. We'll be filling that out later in the day 16 then. 17 A. Okay. 18 Q. If I can have you read this and sign this as 19 well saying that you realize we're going to be testing. 20 A. Okay. So I just — is this filled out by 21 someone other than — 22 Q. Right. Ifs going to be filled out by you 23 so - 24 A. So just put my name or leave it blank? 25 Q. Just leave it blank. Page 5 1 With that, do you have any questions before we 2 begin? 3 A. No. 4 Q. No? Okay. 5 Usually, how I do this is I Me to get a lot 6 of background information, so I may be asking you a lot 7 of questions that don't directly pertain to the lawsuit 8 up front. 9 A. Okay. 10 Q. And then well talk about what happened and 11 what the events were and things of that nature, all 12 right? 13 A. Okay. 14 Q. So with that, where were you born? 15 A. I was born in- 16 Q. Okay. And I apologize, I'm a little slow with 17 writing. 18 A. No, that's no problem. 19 Q. Is that Where 15 20 at? 21 A. No, it's on the 22 Q. Okay. And was there any problems or 23 complicationswith your birth? 24 A. No, not to my knowledge, but Pin pretty sure, 25 no. 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans RIccluti Ell1786dc-3693-4b9f-b50.48838aRia748 EFTA00723632 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 6 1 Q. So nobody ever told you you were in the NICU, 2 PICU, had to spend longer, came early, came late, cord 3 around your neck, problem with your pregnancy, nothing 4 along those lines? 5 A. Nothing on those terms. 6 Q. Okay. And did you meet your normal 7 developmental milestones, walking, talking on time? 8 A. Yes. Q. Any significant childhood illnesses? A. I'm sorry? Q. Any significant childhood illnesses? A. No. Q. I mean, other than mumps is a little rarer nowadays, but I mean, chicken pox or anything like that, nothing out of the ordinary? A. No. Q. aa.nd your date of birth? A. Q. And can you tell me a little bit about your parents? A. My mother's name is The lives= in Q. Okay. A. My father's name is Q. 'Thank you. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 8 health history or problems or -- A. Right. Q. Okay. Roughly, how old is mom and dad? A. I can't — my mom is — honestly, she's lied about her age for so long time. I believe she is probably like 45 or 46. Maybe older, I'm not really positive. And my father is probably around SO years old, give or take. Q. I'll put 45-ish. A. Okay. Q. Any brothers or sisters? A. I have one brother. Well, actually two brothers. One's my half brother, one's my biological brother. And my biological brother i.. Q. Okay. A. And my st irsiother is Q. I'm sony; A. Q And how old is A. My brother is and my younger brother, I don't really have that much of a relationship with him. I believe he's Q. Okay. And is =married, single, divorced? A. He's single. Page 7 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 23. 22 23 24 Q. I'll put that down with a question mark 25 Okay. And as far as you know, no mental Okay, and whore is he at? A. To be honest, I don't have a relationship with hint Q. Okay. And that's fine. If I ask you something you don't know, feel free to tell me. A. Right. Q. And sometimes it's okay to ballpark if you can't tell me anything more specific when we're talking about when you were five or six. A. Right Q. It's hard to remember exact dates and things Tike that. What's mom do for a living? A. Shen Q. Okay. Does she have any medical problems? A. No, not to my knowledge. Q. Okay. Any psychiatric problems? A. Not to my knowledge. Q. Okay. !know you said you don't have a relationship with dad, but do you know anything about his medical history or — A. No, I don't, but I do believe that right now he's 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 9 Q Ancl Married, single or divorced? A. Single, I'm sure. Q Okay. And you said is the one you didn't have much of a relationship with — A. Right No, my brother= I have a relationship with him. Q. Okay. Where doesMive? A. He lives in Q. Okay. And —s in Florida, out of Florida? A. He's inM Q. Okay. Any nieces or nephews? A. No. Q. No? Okay. Do you have any children on your own? A. No. Q. MAW, evil and nasty question to ask. My math is not always the best. Born in■ that would make you how old? Q. what ethnicity or nationality do you consider yourself? A. I' 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans RIccluti (801e) 3,6766dc-36934b9t-b50e-9861Elat0a746 EFTA00723633 Page 3.0 Page 12 1 2 3 4 5 6 7 8 9 10 1/. 12 13 14 3.5 16 17 18 19 20 23. 22 23 24 25 A. I'm not really sure what lcind of but my grandfather ha. in him on my mother's side. Q. Okay. How is your relationship with your mother? A. Very good. Q. Has it always been that way or has it sometbnes been better than others? A. It's definitely been better than others. Q. But currently good? A. Correct Q. Okay. A. Even through our ups and downs, we've always maintained a pretty good relationship. I've always confided in het Q. Okay. And your father, you said you don't have any relationship with him now -- A. Right. Q. -- but you did know him? A. No, not really. When I was younger, I would go to his house for summer, and the school year I would be with my mother, but other than that, I — I don't have any relationship with him. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 or — A. Yes. Q. How long have they been together? A. Probably since I've been six or seven years old. . . And how is your relationship with Am I pronouncing that right? A. Yes Very good. Q. What's he do for a living? A. He — actually, he has two jobs. Well, actually, I think right now he might have three. He ono many ents. A. Yes. Q. Now, the half brother you have, is that through your father or through your mother? A. Yes, through my father. Q. Okay. And did you ever have a stepmother or anything of that nature? A. Not for very long. Just maybe bssummers when I went over there. Her name i I'm not sure of her last name now. Q. Fair. Fair enough. A. Uh-huh. Q. Okay. Any stepbrothers or sisters? 1 2 3 4 5 6 7 9 10 1/. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 11 Q. How old were you when your -- actually, were your parents ever married? A. Yes. Q. Okay. How old were you when they divorced or separated? A. I'd say probably two to three. I don't even remember any of that, though, so it's hard to really say. Q. Okay. So your earliest memories was just with mom; dad was already out of the picture? A. Pretty much, yes. Q. And, you know, if I say something or paraphrase and it's not right, please correct me. A. Yeah, definitely. I mean, I do have some memories with my father when I was younger but I mean, not very many; do you know what I mean? Q. Okay. A. So... Q. Were there ever any stepfathers or — A. Yes. Q. — live-in boyfriends? A. Yes. Q. Okay. And is your mother still with him, Page 13 1 A. Yeah.ad two kids 2 3 Q. Any relationship with them? 4 A. I have — I sometimes, over the computer, have 5 talked to — maybe two years ago, I went and seen 6 and her family. I talk to them on the computer every 7 now and then. 8 Q. Okay. So — 9 A. And they're located i 10 I don't know where he's located at, y, 11 but I knoa and her family are in MI 12 where I was 13 Q. Okay. Again, I don't want to put words in 14 your mouth: Cordial relationship, amicable, just kind 15 of there? 16 A. Yeah, just on and off, acquaintance, good 17 acquaintance, I guess. 18 Q. Does Mr. -- I apologize -- 19 A. 20 Q. you. _yeah, does he have any 21 children? 22 A. No, no. 23 Q. Okay. Kind of the extended family, has them 24 been any issues with mental illness, depression, 25 schizophrenia, bipolar or anxiety? a.4.1.1..e..il.....rat....00.0.4.0006 ,74.4......1. 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Eiceluti(6011=1) 3t8786de-3693.4b91-b50e-98638a10a746 EFTA00723634 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 14 1 A. With? 2 Q. Aunts, uncles, grandparents, cousins. 3 A. 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Q. A. Q. A Pm sorry, your grandffither? Yes, my mother's dad. Which 1 think it was Do you know what he's tm bee i with? N0,1 do not know, but other than that, I know that my grandmother, my mom's mom, and she's going to be 80, she's a go -- she's a, you know, she's a go-getter, she doesn't seem ill at all. She doesn't even seem 80; she seems probably 60. My father's dad, and his name isas well, my grandfather, he seems okay. I do talk to some of my dad's — like my aunts and cousins end stuff like that on my dad's side. And Pm sorry, you did ask me if I had cousins and stuff like that, didn't you? Q. !rimy of them had mental illness. 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 15 1 A. Oh, okay. No, not to my knowledge. 2 Q. No, I mean, there could be hundreds. 3 A. Right. Yeah, I do, I have a whole bunch of 4 them. 5 Q. We would take up eight hours just talking about each and every one of them. A. Exactly. Q. Are there any that are significant in your life that you see on a monthly basis or is it kind of family get-togethers you see them? A. Well, they're in and my -- most of my dad's family. The rest them are in -nd then me and my mom and my brother and my stepfather,■ we live here, but - and my Q. Okay. Now, a lot of times terms get used, and what they mean by kind of general population and what they mean medically are a little different, so when you 111 r A. But they haven't -- I honestly don't believe 1 2 3 4 Q. And I may ask you a little more later about 5 yourself. 6 A. Okay. 7 Q. But how about your family? 8 A. My mother, she is a recovering addict for 9 going on three years now. 10 Q. Okay. Good for her. 11 A. As well as my stepfather,IM 12 Q. What did mom use? 13 A. She was addicted to crack cocaine, both her 14 and my stepfather. 15 Q. Okay. And do you know roughly how long she 16 used for? 17 A. Over 20 years. 18 Q. Okay. And this is -- you'retow, so she 19 started after you were born? 20 A. Honestly, I don't know. I don't know If she 21 was you know, was using and got pregnant with me and 22 stopped. I don't really know the whole scenario, but.. 23 Q. Do you know one way or the other if you may 24 have been exposed in the utero to cocaine? 25 A. I'm sorry? Page 16 that they've really diagnosed him with that, but I don't see why they haven't. Q. Okay. I think that's one of those things that's okay to give a ballpark on. A. Right. Q. Okay. Any problems with substance use in the family? A. Yes. Q. Okay. Who's had issues with substances? 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans RIcelutl (801 818786dc-3693-4b91-b800.98831300e748 EFTA00723635 Page 18 Page 20 1 2 3 4 5 6 Q. Did she use while she was pregnant? A. She -- she's told me no, because I had asked her. Q. Okay. All right. And was it just cocaine, or did she use anything else like alcohol or marijuana 7 A. No, I believe just crack cocaine. 8 Q. How did she get clean? 9 A. She had a well, she lost everything she had 10 multiple times and she just hit rock bottom. I guess 11 she just was ready to change, ! suppose. Ever since, 12 she's held strong and hasn't gone back to that 13 lifestyle. 14 Brief interruption in proceedings.) 15 BY DR. HALL: 16 Q. I just had to stop there fora second due to 17 mechanical problems with the camera. 18 So we were talking about mom and how she had a 19 little bit of a substance problem. 20 A. Right. 21 Q. How did that affect your relationship with 22 her? 23 A. Well, not only did it affect our relationship 24 but it affected my whole lifestyle for when I was 25 younger. 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 situation was and took me in for quite a while. Q. Okay. Can I et the name of that person — A. Y ..kay. And how long did you stay with the A. For a while. Probably — probably three years off and on, give or take. Q. Okay. Was DCF ever involved when you were growing up? A. No. Weird enough, no. Q. And how did your brother do with all of this? Was he also kind of — A. Actually, my brother, before my mother really got heavy into her addiction, I believe she was -- she would always kind of maintain her house, like a functioning addict. And so during that time, my brother was there, but my brother kind of was going down the wrong road. My mom seen that and he actually was sent over to the West Coast with my wild side of the family, my father's side, and he lived with my grandparents for pretty much the whole time that my mom really was out and about doing her own thing, so... Q. Okay. Was there ever episodes of violence between you and your mom related to her drug use? Page 19 1 Q. Okay. In what way? 1 2 A. Homeless, and every way around. I mean, I 2 3 guess that's generally everything. You know, my 3 4 schooling. 4 5 Q. Okay. How long were you homeless for? 5 6 A. I mean, they always had, as in homeless, they 6 7 always had a place — they were always — had a place to 7 9 stay. They lived in efficiencies, hotels. They would 8 9 kind of jump from hotel to hotel or whatever, and I 9 10 could always go stay with them, but I never wanted to go 10 11 stay with them because of them using, obviously. So I 11 12 don't think nobody wants to see that. 12 13 Q. Right. 13 14 A. So between the age of, I would say, 13, 14, 14 15 around about — 15 16 Q. Okay. 16 11 A. -- until she got clean three years ago, I was 17 18 kind of — I was I mean, after I turned.I — 18 19 well, before I was even= I made my own way, started 19 20 so I could, you know, make money to provide for my own 20 21 self. But before that, you know, I was — stay at a 21 22 friends house, jump from friend's to friend's house. 22 23 And a lot of the parents knew. You know, it wasn't a 23 24 secret that — what my situation was, so, you know, one 24 25 friend in particular, her father really knew what the 25 Q. And roughly, what time was t. A. I believe I was 16. Q. Okay. Do you remember the month or year or how do you kind of keep that straight in your head time wise? Any — A. I don't really remember the month or year. I would maybe say — ! honestly — ! couldn't even tell you. I couldn't even tell you. Q. Okay. Q. Okay. Yeah, I can check if I need to. I was just -- sometimes people have certain events in their lives that they remember things about — A. Right. Q. -- you know, their 16th birthday — A. Definitely. Definitely. 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricclutl 3f8785dc-3693-4b91-b60e-98638af0a746 EFTA00723636 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 22 1 Q. — fast car, somebody they were dating — 2 A. Right. 3 Q. — and they can kind of put things together 4 that way. 5 A. Put it together. 6 Q. So I was wondering if you had any time stamps 7 in your life for what you used to — 8 A. Honestly, I — now that I think about it, I think I was a little younger than age 16 when that all occurred. Q. NI put a question mark next to it. A. Right, but no. 1 mean, I know I was — I was probably — I think I was probably starting to be a Freshman Q. Okay. A. I was supposed to be going to school. I think it was in the summer time, but I could be wrong. Q. Fair enough. And that would have been about seven years ago now or eight years ago? A. Well, 1' So, yeah, about seven or eight years ago. Q. How did you get along with your stepfather? I apologize if I've already asked that. You said Page 24 1 Q. Did they ever shoot it or snort it? 2 A. I have no idea. 3 Q. You never witnessed them doing it in front of 4 you? 5 A. Right. 6 Q. Okay. I trained up in the Baltimore area. and 7 I saw a lot of very heavy cocaine use. 8 A. Oh, okay. 9 Q. Fonts up there usually would either go by 10 munber of rocks they were using or dollar amount. 11 A. Oh. 12 Q. Just like kind of an idea down in 13 S how much would a rock of cocaine go for' 14 A. I'm — I don't really know. I would guess 20 15 bucks, 25 bucks, !think. 16 Q. Okay. Would that be a big rock you could 17 break up into multiples, or... 18 A. I have no idea. 19 Q. No idea? 20 A. I have no idea. 21 Q. Okay. We used to talk about $5 and $10 hits 22 all the time in Baltimore. 23 A. Okay. 24 Q. 'Just want to make sure my -- 25 A Right. I mean, they could have that down Page 23 1 generally a good relationship? 2 A. Yeah, generally good. 3 Q. Okay. Ever get into fights with him or have 4 any trouble — S A. I mean, arguments over obviously the crazy lifestyle they were living and everything else. So 7 arguments, but there was always unconditional love. I 8 could always — if there was anything ever wrong, you 9 know, sometimes they would be kind of missing in action. 10 but for the most pan, I did 'mow where they were. If 11 they were in hotel rooms, we did keep contact. If there 12 was anything ever wrong — they were using, it sounds 13 crazy, but they did give me unconditional love, like, 14 you know... 15 Q. Okay. All right. It's good to know that you 16 felt that they were at least there. 17 A. Definitely. They might not have been there, 18 you know, drug-wise. I know that they were using and 19. everything else, but my mother -- 20 Q. Do you know roughly how much they were using a 21 day? 22 A. No, I have no idea. 23 Q. Okay. And it was crack so they were smoking 24 it? 25 A. Yes. Pug( 1 here, too. Pm not really, really sure. 2 Q. They had the eight balls, which were the big 3 ones but again, you were supposed to break that up or do 4 whatever. 5 A. No. 6 Q. Okay. Any issues with alcohol or... 7 A. No. 8 Q. How did they get money to support their habit? 9 A. Like I said, my mom was always kind of like an 10 active addict, so she always carried a job, and for the 11 most pert my stepfather did, too. 12 Q. Okay. So there was no stealing or — 13 A. No. My mother was always a wait — 14 Q. -- trading sex for favors? 15 A. No. My mother was always a waitress at -- 16 like at the worked fora very long time. 17 various restaurants. She always stayed at 18 each restaurant for a year, you know. Always long term 19 for the most part 20 And my ste.pfa ever since I could 21 remember, he di til just recently when he 22 star But he's been in 23 the usiness for a really long time. 24 Q. Okay. I'm just going to... 25 And I know we talked about this a little bit, 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Fticclutl (4101==) 3f6766dc-3693.4b9f-b50o-98638af0a746 EFTA00723637 Page 26 1 so pardon me if there is a little overlap, but in 2 general, how would you describe your childhood? 3 A. It could have been better, I suppose, 1 would 4 say. 5 Q. Okay. 6 A. And more -- more of my teenage years, I guess 7 I would say. As my childhood, I always remember happy 8 memories and stuff like that. Like, I don't remember 9 ever being sad or neglected or hungry or anything like 10 that. It was more when I turned, you know, 13, when I 11 got into my teenage years. 12 Q. Okay. So teenage years were definitely worse 13 for you than -- 14 A. Definitely. 15 Q. Okay. How were you disciplined as a child 16 growing up? 17 A. I mean, if I did something wrong, talked back, 18 1 got put in time-out. There was definitely sonic form 19 of discipline. She would never let me do whatever I 20 wanted to but, you }mow, when I turned 12 and or 13, she 21 was kind of wanting to do what she wanted to do, and she 22 did kind of get more lenient on me where I was able to 23 go out. Sometimes I would leave and not tell her where 24 I was going or, you know... 25 Q. Okay. So it was never like physical Page 28 1 were younger, I never remember us getting really 2 physical with one another. 3 Q. Okay. What type of activities or clubs did 4 you belong to? 5 A. Wheal was in middle school — I was always a 6 straight A student from elementary to middle before, and 7 then I dropped out. 1 was always honor roll, straight A 8 student, I was in a lot of activities, I was on the 9 track team, I was the first chair trumpet player. 10 Q. Okay. 11 A. I was the captain of the cheerleading squad, I 12 was a mediator. 13 Q. Hold on one second. So captain of the 14 cheerleading squad, first trumpet? 15 A. First chair trumpet player. 16 Q. And that was school band I guess, or marching 17 band? 18 A. Yes. It wt this was all 19 at. 20 Q. Okay. 21 A. Whe that one teacher got shot 22 at, ifs the same. t ow if you probably heard 23 of that, around two years ago. 24 Q. No. 1 didn't grow up in 25 A. Okay. 1 2 3 4 5 Page 27 punishment like spankings or anything like that; it was time-out and grounding? A. Right, no. My mother has never put her hand 6 Q. Okay. And any major physical confrontations 7 with your brother or -- 8 A. Oh, me and him? 9 Q. Yes. 10 A. Yes. When we were younger, before he got sent 11 over to the West Coast, we used to fight like cats and 12 dogs. 13 Q. And would that be kind of like — it's hard to 14 even say, because there's no such answer to normal 15 brother/sister at times, but normal brother and sister 16 type of things? 17 A. Right. You know, I would use the phone and he 18 wants to use the phone and I'm on it first and it 19 escalated. Just very simple stupid stuff we would argue 20 . about. . 21 Q. Okay. And would it get physical or just — 22 A. I mean, a couple of times we did honestly get 23 physical with one another but, you know, that was kind 24 of when I was 12, 13, before he was sent over to the 25 West Coast, when we were a little bit older. When we Page . • 1 Q. Who igilMME 2 A. Oh, it's a teacher that actually got shot and 3 killed there. A lot of people know that school, that's 4 the only reason I brought it up. 5 Q. Did you know him? 6 A. No, I didn't know the teacher. 7 Q. And you said a mediator? 8 A. Mediator. 9 Q. Okay. Fm not familiar with that program. 10 A. You can get it as an elective, and it's when 11 counselors, the counselors of the school pick a 12 selective two or three people or four people to have it 13 as an elective, and when me as a student knows that this 14 girl and this girl is having a problem, we would call 15 them out of their class and put them in the counselor's 16 office and kind of try to mediate their problem before a 17 fight occurred or anything like that. 18 Q. Okay. How many times did you, I guess, do 19 peer mediation? 20 A. Multiple — a lot. I don't... 21 Q. Ballpark it, 5, 10, 20? 22 A. I would say 5 to 10 times. 23 Q. Were you ever threatened becimse you did this 24 type of work or have any negative repercussions from it? 25 A. No. 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciutl (601 ) 318785dc-3693.4b9f-b50e-98638at0a748 EFTA00723638 Page 30 1 When I was in middle school, I was generally 2 kind of like a popular kid, quote/unquote. I didn't 3 really have any problems with really anybody. 4 Q. I actually put the quote/unquote there. 5 Okay. And outside of school, what would you 6 lice to do? 7 A. !did all kinds of stuff when I was, you 8 know — most the time I was after after school, I 9 would be at school because I did do cheerleading and I 10 did play the trumpet and I would do track and I did, you 11 know, a lot of stuff So generally, in school, after 12 school, it kept me busy, you know, so... 13 Q. What did you rum when you ran track? 14 A. I'm sorry? 15 Q. What type of track did you do, was it 16 sprinting or long distance? 17 A. It was long, like the mile runs. 18 Q. Do you have a faith? 19 A. I'm sorry? 20 Q. Do you have a faith? Do you attend a church 21 or are you spiritual? 22 A. Oh, yes. I'm a 23 Q. Did you attend church as a child growing up? 24 A. No. 25 Q. Do you attend now? Page 32 1 Q. Did you ever witness any domestic violence in 2 either your family or your friends? 3 A. No. As in relationship, mother and Mier 4 fighting? 5 Q. Mother and father fighting. 6 A. Right, no. 7 Q. Okay. Anything else about your childhood, 8 through probably middle school and before, that I should 9 know or come to mind or I haven't directly asked about 10 that you think is important for me to understand? 11 A. That's pretty much it. I think we covered 12 most everything. 13 Q. Anybody important in your life that passed 14 away during that time? 15 A. No. 16 Q. Sometimes! - 17 A. Right. 18 Q. -- questions pop in mind. 19 A. No. 20 Q. And no tratmias during that period of time? 21 A. No. 22 Q. Or anything that you would consider- 23 A. Right, as trauma, no. 24 Q. Parting. that can be a very broad word. 25 Okay. I apologize, you were telling me a Page 31 1 A. Once in a while. My mom goes on Sundays and 2 Wednesdays each week, so sometimes I go with her. 3 Q. And again, ballpark, is that like once a week 4 type thing, once a month, four or five times a month? 5 A. I would say two to three times a month. 6 Q. Better than my friend who considers himself a 7 Christmas candle/Easter lily. He shows up on two -- 8 A. That's funny. 9 Q. Actually, I think ifs his pastor who 10 considers him that and he keeps reminding people to come 11 more often. 12 As a child growing up, were you ever 13 physically or sexually abused? 14 A. Yes, I was. 15 Q. Could you tell me about that? 16 A. Ifs —1- only one time I was sexually 17 abused, when I was introduced to Jeffrey Epstein. 18 Q. Okay. Before Jeffrey Epstein, were you ever 19 sexually or physically abused? 20 A. No. 21 Q. Okay, and we'll get more into Epstein later. 22 A. Okay. 23 Q. I'm not ignoring that. I'm trying to group 24 all of that at one time. 25 A. Right. Page 33 1 little bit about your educational history. Let me get a 2 little more in depth there. 3 A. Okay. 4 Q. Have you ever been in any special education 5 classes? 6 A. No. 7 Q. And you said you were a good student? 8 A. Yeah. I was definitely, like, the top of my 9 class from elementary to middle. I always had As and 10 Bs, sometimes a C 11 Q. Okay. But then primarily A, B? 12 A. Yeah. 13 Q. Okay. And then what happened when you went 14 from middle into high school? 15 A. Well, a lot happened. When I was in middle 16 school, you know, they put me in all honor classes, so 17 when I went to high school, I was in all honors classes 18 and it seemed to be just kind of too fast paced for me 19 and I kind of tried to talk to one of the teachers, my 20 language arts teacher about it, and she just kind of 21 said, you know, you can handle it, stick to it, but 22 really it was just too fast for me and it ldnd of made 23 me Si discouraged. 24 And around that period of time, you know, I 25 did not really have a stableylace, that I considered a 9 (Pages 30 to 33) PROSE COURT REPORTING Electronically signed by Jean. (fleeing (601.M.) AGENCY, INC. 3f676Selc-3693-4b91-b50,3-98638agia746 EFTA00723639 Page S. 1 stable place to live so I was kind of, you know, friend 2 to friend's house. And you know, around that time 3 period, I was introduced to Mr. Epstein and, you know, I 4 would go to his house and he would obviously pay me for 5 obvious things. I think we all know. 6 And once I started making money through him 7 and doing business with him, quctehniquote, I dropped 8 out of school and it was kind of my way of living for a 9 while. 10 Q. Okay. What would you have done if you hadn't 11 met him? 12 A. That's a good question. Honestly — 13 Q. It may not be one you can answer. 14 A Right, because I don't know. 15 Q. Would you have stayed in school or would you 16 have gone elsewhere or gone over to the West Coast like 17 your brother did? 18 A. Possibly. Possibly. I don't know. I 19 couldn't answer that 20 Q. Were you ever suspended or expelled from 21 school? 22 A. Na 23 Q. Did you ever get into fights with authority 24 figures, teachers or school officers, principals? 25 A. No. Page 36 1 and I got the GED test and I read it from front to back 2 twice, and they have a CD torn that it comes with as 3 well, so I'm pretty — generally, I'm pretty good. I'm 4 not sometimes I have problems with spelling but 5 reading overall, I'm pretty good. 6 Q. Okay. So you had some, but you think that may 7 have been school rust for a lack of a better word? 8 A. Right, exactly. 9 Q. Okay. You ever been diagnosed with dyslexia 10 or a learning disability or anything like that? 1/. A. Na 12 Q. Okay. When you we younger, any problems 13 with fire setting, cruelty to animals, bedwetting? 14 A. No. 15 Q. What type of jobs have you had? 16 A. I've waitressed, I've — when I was younger, I 17 bussed tables, waitressed, hostess, everything in the 18 restaurant business, bartender, I have danced. 19 Q. What do you mean by danced? 20 A. Exotic dancer. 21 Q. Okay. Where have you danced at? 22 A. It wasEMIIMI 23 Q. Spelling is not one of my strong suits either, 24 so how do you spell 25 A. I think ha honestly, I'm not really Page 25 1 Q. Did you ever repeat any yews? 2 A. No. 3 Q. Ninth grade is the last grade you were in or completed? 5 A. No. Eighth grade was the last grade I 6 completed. Q. Have you tried to get back to school or get a 8 GliilY7 9 A. Yes. 10 Q. When was that? 11 A. Actually, I'm waiting to take the test. It 12 should be sent to my house either today or tomorrow, 13 so... and ifs a correspondence school that I'm going 14 through, a Christian correspondence school. 15 Q. Okay. How long have you been doing that for? 16 A. For the past month I've been studying for it 17 Q. Okay. How do you feel your chances are? 18 A. No, I'm ready to take the test 19 Q. You're ready to take it? 20 A. Yes. 21. Q. Good. 22 Any problems with reading or math or — 23 A Yeah, I do have a little bit of difficulties. 24 A lot of this stuff I just kind of forgot about, just 25 basic stuff. But now that I went to Barnes & Noble's Page 37 1. 3 2 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 know if you want me to list all of those because a lot sure It was called before it got shut down, but ifs gone out of business. I worked there. I worked a ilitwo places A. No. I've worked at — do you want me to name them all? Q. Yes. A. Okay. I'm trying to think of - Sin told you about, I worked an Q. That's two different ones? A. Yeah. Q. Okay. A. And right here ini there was off of narria 'Than when I first danced when I was -- I there was a club. I kind of forgot the was even way too young, but they never checked my ID, so I was able to. It was, I think, ta The somethin I've worked at - n I've worked at a lot of the clubs. Q. Okay. A. And a lot of them were just fora day, do you what I mean? I went there to check it out so I don't 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Riccluti (601) 3f6765dc-3693-4b91-13500-98638alga746 EFTA00723640 Page 38 1 of the other ones I just worked at — generally, those 2 are the ones that I worked at. 3 Q. Again, I don't know much about how that 4 business works. So I mean how would you get a job at 5 one of those places? 6 A. You just go in and you ask them if you — that 7 you want a job dancing. And most of the times I asked 8 if I could work that day, and a lot of the times they 9 would say, okay, if you want to go in the back and get 10 dressed. And they audition you on the stage just, you 11 know, make sure that you're not all crazy looking, I 12 suppose, and either they hire you or they don't. 13 Q. Okay. And do you basically work for tips or 14 do they pay you or — 15 A. No. 16 Q. Do you pay for your stage time? 17 A. No, it's all tips and then we pay. And then 18 you have to pay them obviously to work there, like 19 house. And if we do the dances, $25, you have to 20 give — the house gets 5, you know. But on stage, you 21 gm to keep all your tips. 22 Q. Okay. And how much did you make a day 23 dancing? 24 A. It varies. You can — nowadays, you can't -- 25 I can't make very much money, but in the past I've made Page 40 1 Q. Okay. Have you ever had any problems with a 2 patron being too fresh or out of control? 3 A. What, like a customer? 4 Q. Customer. 5 A. Yes, I have had problems with that. 6 Q. And how do you deal with that or — 7 A. There are bouncers. It's always -- nothing 8 has ever gotten out of control where, you know -- if I 9 ever had a problem with the customer, I just go up to 10 the closest floor guy, bouncer that there is. Normally, 11 they handle it. 12 Q. When I've talked with some people who've done 13 this type of work, and usually they were more at one 14 place — 15 A. Right. 16 Q. -- they said that they would have a very close 17 relationship with the bouncers. 18 A. Right. 19 Q. Did you have anybody in particular or any of 20 the bouncers that you felt were very protective of you? 21 A. Yeah, defmitely. I -- when I worked at 22 e bouncer, =and also 23 another bouncer I was very close with them. 24 Q. Okay. And usually folks describe them almost 25 like a brother/sister type of relationship. 1 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Page 39 anywhere from $100 to 1,000. 1 mean, it really varies. Q. Okay. Are you still dancing currently? A. Once in a while. The last time I danced was two weeks ago. Q. Okay. Where was that at? A. AtIIII=Ip And before — I mean, I really haven mean, core that, before two weeks ago, I hadn't danced in like two months, so... Q. Okay. Was there any place where you were Idnd of like a regular that you were working out for like a month or a year or — A. Yeah, that was atIMIII the lippe. the same club. I worke ere forayer)! Q. Okay. Were you ever fired from a club or — A. No. There was clubs that I walked out of, Q. Which ones were those? A. I've walked out of before, the last time I worked them. Q. Okay. Why would you walk out? A. I just felt like it was a number — there was so many girls, there wasn't — it was just kind of a 24 waste of my time. I wasn't making any money, I was 25 frustrated. Page 4: 1 A. Yeah, definitely. 2 Q. Has there ever been a bouncer that you dated? 3 A. No. 4 Q. What's kind of the worst thing that's happened 5 at one of these clubs? 6 A. As in? 7 Q. Well, you said there were times when you would 8 have to go get a bouncer. 9' A. Just like, you know, you're giving a dance to 10 a guy, and they're not supposed to touch you, they're 11 supposed to keep their hands by their side. They try 12 touching you. You know, I by to be nice about it and 13 say, I'm sorry, but you can't touch me as I'm dancing, 14 and they'll try to get a cheap shot in, you know, grab 15 your private parts or whatever if they get the chance 16 to. And basically anytime that's happened, I stopped 17 what I'm doing, go get a bouncer and make them give me 18 the money for, you know and either give me the money. 19 Sometimes they give me the money and then they kick them 20 out or, you know, or that's the tidiest extent of It, 21 really. I've never had anything outlandish, crazy, you 22 know. 23 Q. So nobody has ever dumped you off or slapped 24 you or-- 25 A. No. 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Joana Ricelutt (801 3f8788dc-3693.4b9f-bsoe-98638af0a748 EFTA00723641 Page 42 1 Q. But somebody would try to grab you? Did they 2 ever try to insert a finger in your vagina or anything 3 like that? 4 A. Right, that has happened. 1 mean, they've 5 tried but never succeeded, but anytime that's ever 6 happened, I've always stopped what I'm doing and walked 7 away and get the bouncer and let them handle it. 8 Q. Okay. Have you ever been propositioned while 9 you were working at one of these clubs? 10 A. As in? 11 Q. As in doing something extra after hours or 12 prostitution or - 13 A. Right, no. 14 Q. — sexual favors, or... 15 A. No. 16 Q. It sounds like we're getting a little bit of a 17 tropical depression. 18 Anything else, any work that you did that you 19 think I should know or that would be helpful for me to 20 understand? 21 A. I guess that's about it. I think we covered 22 pretty much the basics. 23 Q. Okay. Now, I understand that a lot of times 24 there could be a lot of drugs and stuff in those clubs. 25 A. Definitely. Page 44 1 Q. Okay. What other types of jobs have you had 2 besides, I guess, the exotic dancing, you said? .3 A. Right. 4 Q. I know you said waitressing, but where else 5 have you worked? 6 A. I worked at a bagel shop not too long ago. I 7 was a waitress there for about a . I o ed up my 8 own business. It's called I cleaned 9 houses. 10 Q. Okay. 11 A. rve bartended. 12 Q. Do you know the name of the bagel shop? Was 13 it Rice Einstein Brothers — 14 A. No, it was called was actually 15 the name of it. 16 Q. Truth in advertising. 17 A. Yes. 18 Q. Okay. 19 ow ong ow do that for? 20 A. The I did that for about a 21 year, &little over a year. 22 Q. Now, was that like a franchise thing or was 23 that your own business? 24 A. No, that was just my own business. 25 Q. And how many clients did you have? Page 43 Page 45 1 Q. Have people come up and offered you drugs 1 A. I would have, at the end, I had probably 30. 2 while you've been working? 2 Q. That's a good number. 3 A. Yeah, definitely. 3 A. Yeah. A lot of them came fro 4 Q. Have you over used while working? 4 which that was right S A. Yes. 5 people. So a la of the times it was a mixture of 6 Q What would they offer you and what have you 6 cleaning their house, going grocery shopping for them, 7 used? 7 you know what I mean, kind of helping them out, their 8 A. Eve used in the past. I was addicted to 8 laundry, you know. 9 pills. 9 Q. Why did you give that up? 10 Q. Okay. Prescription medicines — 10 A. I actually moved farther down south. 1 11 A. Right. 11 actually got out of a relationship I was with and — 12 Q. — not like heroin or cocaine? 12 with my ex, so l kind of just left this area. 13 A. No, nothing ever like that, never. 13 Q. Okay. So that's the reason you shut down? 14 Q. Okay. And how old were you when you started 14 A. Yeah. That happened about a year ago. I quit 15 doing that type of work? 15 all that a 16 A. I was 16. 16 Q. Sr housecleaning, bartending. 17 Q. And how much would you do when you were 16 -- 17 Where did you attend bar at? 18 A. Actually, I was 15 when my — the first club I 18 A. Right now I'm actually still tending bar. 19 ever worked at was tha 19 It's call to and ifs in And 20 that I was telling you abou , a on ru y 20 right now, it's not -- you know, l don't have a set 21 remember. I was 15. 21 schedule. It's more of the, you know, whenever somebody 22 Q. And were you working like one night a week or 22 calls out or can't really make it, I'm staying right 23 was this like a weekend — 23 there — literally right behind the so... 24 A. No. I was working as much as I could because 24 Q. If they need someone, it's -- 25 at that time, I needed the money. 25 A. Right, its more of a call-in, yeah, at the —====i=issisa=tocemeset irte=====sserscerarisssezinst 12 (Pages 42 to 45) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Joana Mesta (601a 316766dc-3693-4b9f-b60048638af0a746 EFTA00723642 Page 46 Page 48 1 2 3 4 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Any other jobs a anything else you've done for work? A. 1 mean, like I said, bartended, cocktail waitressed, I've cleaned houses, I have...oh, I did telemarketing for a while. I was still Q. What's the longest job you've A. I would say probably -- other than dancing? Q. Sure. A. I would say when I worked at and I had my own business. Q. Okay. And when you were dancing, what's the longest you stayed at any one club or — A. I stayed aintil from — round about from 16 to 20. Q. So for about four years then? A. Uh-huh. Q. Okay. And Ilmow you said in the beginning it was kind of like an every-night type of thing. On average, how many nights would you go in? A. Actually, longer than — I mean, for probably two years, or even three years, I would try to go almost every night I would say about three nights on average a week. Q. Okay. Were you ever in the military? 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. When did the first one start? A. The first one started — trying to go backwards here. Probably when I was like 15. Q. Okay. How long did that last for? A. Not very long. Probably like a month or so. We just kind of dated. Q. Okay. A. He was like my first boyfriend. Q. Can I,S01 you remember? A. Yeah (phonetic). Q. Okay. And youdated him for a month? A. Give or take. Maybe longer, maybe a month, two months. Q. Okay. Next one? A. I'm trying — I was with (phonetic). Q. Could ou II that? A. I think it's but l could be wrong. Q. You'll get a question mark next to it. A. Okay. Q. How long did you dataror? A. I dated him for over a year. Q. Okay. All right. And the one after that? A. I dated — his name is and I dated him Page 4"' 1 A. No, no. 2 Q. Did you ever take the ASVABs or anything like 3 that in school? 4 A. No. 5 Q. Ever date anyone in the military'? 6 A. No. 7 Q. Okay. Pm just going to talk a little bit 8 about your relationship history some. 9 A. Okay. 10 Q. What age did you start dating? 11 A. I started dating when I was probably like — 12 probably around 14, 14,15. 13 Q. Okay. And what type of dates would those be? 14 A. Just, you know, kind of more like crushes, 15 going to the movies, you know, just kind of hanging out, 16 nothing... 17 Q. Okay. How many significant relationships have 18 you had? 19 A. As in sexual relationships, or — 20 Q. No, just significant. 21 A. Like long-term dating 22 Q. Long-term dating. 23 A. — you would say? I would say — I'm trying 24 to do -- probably — one, two, three like four or 25 five. Four or five. Page 49 1 for about six months or so. 2 Q. aCinDo you know 'ast name? 3 A. 4 Q. TM! 5 A. And then I was — I'm trying... 6 Q S° I Sot IMINIMIM 7 A. And I dal 8 Q. 9 A. 10 Q. 11 A. and I was with him fora while, 12 actually. We always liked each other, but I was with 13, him for over two years. 14 Q. Okay. 15 A. But we had kind of through, you know, that 16 whole timeline, we always talked and always liked each 17 other, but we never did anything with one another. 18 Q. So you knew him for at least — 19 A. Yeah, 1 knew him when I was - 20 Q. —12 or 13 — 21 A. Yes. 22 Q. —or are we talking—is that earlier? 2 3 A. No. I blew him when I was probably 12 or 13 24 years old. 25 Q. Okay. n (Pages 46 to 49) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Joana Riccluti (601a 3f6785dc-3693-4b9f-b50o-98638af0a746 EFTA00723643 Page 50 Page 52 1 A. And I just — we just broke up last — it's 2 been a year now that we haven't been together. 3 Q. All right. Have you been dating since then, 4 or -- 5 A. Yeah. I m bo iend 6 Q. I'm sorry, 7 A. 8 Q ()kW. 9 A. And I've been dating him for a little under a 10 year. 11 Q. Okay. Just kind of going through, why did 12 things break up with 13 A. We were I was just young and so was he. 14 Q. Okay. But I mean, did anything happen or did 15 you just say, yeah, it's — 16 A. Yeah, we just really weren't into each other. 17 I guess we thought we hied each other, and... 18 Q. Okay. How about 19 A. had a drug addiction problem, and he went 20 to rehab for it. And when he went to rehab for it, 21 we — me and his mother drove to Louisiana and dropped 22 him off at the rehab, and it was best that we didn't 23 have a relationship at that time so he could better 24 himself. 25 Q. Okay. What was he using? 1 A. Yeah. 2 Q. And then 3 A. Yeah. I still have an ongoing relationship 4 with him right now. 5 Q. Where did you guys meet? 6 A. We actually met I met him through a good 7 friend of mine, probably in '05, in '05, and we 8 were friends. 9 Q. Okay. I apologize. 'just realized there was 10 a question I forgot to ask you about work Did you ever 11 receive any awards at any of the places you worked? 12 A. No. 13 Q. Okay. And school, did you receive any awards? 14 A. Yes. 15 Q. Okay. Which ones did you get in school? 16 A. Student of the year, most improved student of 17 the year for band, cheerleading awards. I mean, 18 trophies -- I have all kind of trophies, but... 19 Q. Okay. Ever receive any disciplinary actions 20 or reprimands from school? 21. A. No. 22 Q. How about at work, any disciplinary? 23 A. No. 24 And I don't know if this is important, but 25 he's deceased. 6 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q. Okay. Is it okay if I put in quotes, wife 25 .- figure? SOW Page 51 1 A. I believe it was cocaine. He was really 2 sneaky, so honestly I don't — I don't know -- 3 Q. Question mark 4 A. - what he was doing, right. 5 Q. A. Me and him, I've known him from when I was very young, like, probably eight, nine growing up in an old neighborhood that I used to live in. So me and him were really good Mends and tried to do the whole dating thing, but it wasn't really working out so we kind of, you know, just went back to being friends, you know. We didn't want to mess that up. Q. Okay. MI A. Q. sorry. A. s okay. We were very much in love with each other, and I still love him to this day and I'm sure he still loves me to this day, and things just didn't work out, I suppose you could say. I just felt like there -- we weren't spending enough time with one another, like I wasn't being appreciated. I felt like I was kind of doing a wife figure to him and it wasn't equal.2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 53 Q. When did that happen? A. That happened this year. Q. Do you know what happened? A. It happened in March. He committed suicide. Q. Were you in contact with him at the time? A. No. I wasn't — I mean, no, I wasn't in contact with him. I've always stayed in very good contact with his family to this day, but... Q. Okay. A. We always remained good friends after he got out of rehab and so we always kept in touch. Q. Okay. Did you find him or somebody else found him? A. 14 (Pages 50 to 53) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana RI