UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME I Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 a.m. - 6:10 p.m. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Reported By: Pamela J. Sullivan, RPR, FPR, CLR Prose Reporting Agency, Inc. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333.772-1552) 170ae621-3493-40cd-8666.0Do698ca2735 EFTA00750707 17 le 19 20 n 24 25 Page 4 1 APPEARANCES: 2 On Shelf deb* Plaintiff. Jane Doe 3 BRAD 1. EDWARDS, ESQUIRE ROTHSTEIN ROSENFELDT ADLER Las Dietary Case, Sete 1650 401 Es Las Cass Boalceard 5 Mont 33)01 On hLlfof Alley Esidn: ROBERT D. EAMON, At, ESQUIRE BURMAN, CRITTON, LUTHER a COLEMAN. UP 9 303 Banyan Hcadevar4 Sake 400 10 , Banda 33401 12 Ooh of the Defendant. WES' Engel', 13 JACK ALAN GOLDBERGER. ESQUIRE ATTERBURY. GOLDBERGER & WEISS, PA 14 250 Asinlian Mese South Suite 1400 15 West Aim Bach, Plaids 33401-5012 It On Ethan of PUSH in Added Cu. No. 08-80469. iSEDRO M. GARCIA. ESQUIRE GARCIA LAW FIRM. PA 224 Dan Street Stith 900 C 3340) On NEN( of lane Does I duo* 8: ADAM D. nortown2, ESQUIRE MERMELSTEIN & HOROWITZ. P.A. 11205 Disease Bothnia Suite 2218 elndde 33160 1 2 3 4 5 6 10 1: 12 13 INDEX WTINESS: DIRECT CROSS REDIRECT RECROSS JANE DOE BY MR. CRITTON 5 EXHIBITS MARKED DESCRIPTION PAGE Defendant's No. I (Copy of Plaintiff)Wimess Identification Card) Defendant's No. 2 14 (Victim's Petition) 15 Defendant's No. 3 118 (Victim's Motion to Unseal Non-Prosecution Aff u.nt) 16 17 18 19 20 21 24 25 I16 Defendant's No. 4 121 (Declaration of A. Marie Villafrra) (4" Marked off the record.) Page 3 On behalf of the Plaintiff- JACK P. MI, ESQUIRE SEARCYDENNEY SCAROIA BARNHART & SHIPLEY, P.A. 3 2139 Palm Beach Lakes Boulevard :ach, Florida 33409 4 5 On behalf of the B.B.: 6 ADAM J. LAWN°, ESQUIRE LEOPOLD KUVIN 2925 PGA Boulevard, Suite 200 33410 8 dens, Florida 9 10 11 ALSO PRESENT: 12 Jeffrey Epstein, via video conference Stan Sanders, Vidoograpber 13 14 15 16 17 18 19 20 21 24 25 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Page 5 PROCEEDINOS - - - Deposition taken before Pamela J. Sullivan, Registered Professional Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. (Discussion held off the record.) MR. CRITTON: Let's get started. MR. EDWARDS: Brad Edwards, and I represent Jane Doe. ' MR. HILL: Jack Hill, on behalf (AM. MR. HOROWITZ: Adam Horowitz, on behalf of Jane Does 2 through 8. MR. LANGINO: Adam Langino, on behalf of B.B. MR. CRITTON: Bob Critton, on behalf of Jeffrey Epstein. MR EDWARDS: And, Mr. Critton, I don't think we've had this Cant Reporter before, so maybe we want to instruct as to how we're dealing with the names, how they're going to be typed up. MR. CRC-TON: Pamela, are you familiar with how Cindy did the names at all? 24 COURT REPORTER: Let's go over it. 25 MR. CRITTON: All right. What we -- what (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. 2 (Pages 2 to 5) (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501.333-772-1552) fleae621-3493-40cd-8666-000698ca2735 EFTA00750708 Page 6 1 we've done in the past is, as with regard to anyone 2 who's identified as a Plaintiff in the case, and 3 only that group, you know, absent some other 4 agreement amongst the, the clients or the parties 5 and their attorneys is, is we will refer to them by 6 initials only, such as Jane Doe, who's seated in 7 front of us. She will be — well, except she's 8 gone as lane Doe, so we should keep her as Jam 9 Doe. So much for that ewertion, but... 10 And Mr. Hill's ellen ., will be referred to as , because how 11 that's 12 we referred to her, and she has -- she gave up 13 anonymity. 14 Jane Doe's 2 through 8, we may use their real 15 names, and then we'll just use, if it's 16 Sally Jones, it would be S.J. And then what you do 17 is, is on a separate piece of paper, as Cindy did, 18 you will give us a key that ties in with any name 19 that we've designated by a first or a last name — 20 or both. 21 MR. EDWARDS: All right. And one other thing 22 I want to — I want to put on the record, I know that you disagreed last time, but I think that 24 it's, to make the record clear, we feel strongly 25 that this deposition and the transcript and the Page 8 trat 1 2 it, you claimed all sorts of privileges 3 and, and other objections and instructed her not to 4 answer. Obviously, the judge has to consider a 5 transcript. 6 MR. EDWARDS: Agreed. 7 MR. CRITTON: So I would say as to the B transcript, no, and with the transcript that Pamela 9 is going to prepare, it's going to have — it won't 10 disclose Jane Doe's name or Jane Doe's name. All 11 right. So with regard to the video, as' — as 1 12 indicated to you to the extent that the video would 13 be necessary to be filed for any purpose or to use 14 for any purpose, you have 15 days to file 15 something. lf, in fact, the video was used, I 16 would do that which was necessary so that 17 Jane Doe's face would not be disclosed, so that no 18 one could identify her. 19 MR. EDWARDS: Okay. Well, I — if you're 20 only talking about blocking out her face as the 21 only way to protect her anonymity, we, we wouldn't 22 feel that that would be accommodating enough to, to 23 secure her anonymity. 24 But now I'm understanding that you're saying 25 you may file this with the court, which I have much I Page 7 1 video remain confidential, and that the witness's 2 anonymity is protected, absent some court order 3 directing otherwise, as we feel that's consistent 1 with the court orders that have already been s entered, as well as the instructions of the various 6 judges presiding over these cases. 7 I'm assuming, if you are in disagreement of 8 that, then you will allow me 15 days to file a 9 motion in that regard, if you think that's 10 necessary. 11 MR. CRITTON: Yeah. Well we, we had this 12 discussion at the deposition of.l. 13 MR. EDWARDS: Right. 14 MR. CR1TTON: And you dealt specifically with 15 the video, not the transcript, is my recollection. 16 And I said it, with regard to the video, there's — 17 there are orders granting your client, and in her 18 case., and I think in Jane Doe, anonymity. And 19 as such, we don't plan to violate that court enter 20 to the extent that the transcript -- and a perfect 21 mantS of it is, is, if you think that the — that 22 theM. transcript can't be filed, it's absurd, 23 because.. claimed the Fifth Amendment about 30 24 to 50 times. So in order to get some ruling from 25 the Court, the Court's going to have to look at the 1 2 3 4 6 8 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 1/4 AaiGIVaSnes%)4.0..sstnr.M.. Page 9 less a problem with than you posting it on the Internet or using some other device to post it to the public, which is what was implied last time. And I think the example you gave was that another attorney has posted your client's deposition on the Internet. MR. CRITTON: All right. Let, let's deal exactly what the issue is. If Spencer Kuvin, for publicity, and for no other reason, contacted Jose A. Lambiet, who in turn then put it on his website so that everyone could view the question, and he did it to embarrass, to humiliate, it was improper, it was inappropriate, I hope I wouldn't use the same conduct or what I would say lack of professionalism to do something like that. MR. EDWARDS: Well, but, obviously, the difference is Mr. Epstein's anonymity has not been protected in this case, and these victims have. So... MR. CRITTON: So it's okay to humiliate and embarrass someone and to be unprofessional? MR EDWARDS: This has nothing to do with me or my clients. MR. CRITTON: All right. MR. EDWARDS: So arc we noon the same page, (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. A3 (Pages 6 to 9) (561) 832-7506 Beetronlcally signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) I reae621-3493-40cd-8666-00.3698Ca2136 EFTA00750709 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 Page 10 and I need to file a motion to protect the confidentiality of the video and the deposition transcript, or do you agree that it's - it should remain confidential, but for whatever motions you have to file and attachments you have to make to the court file. MR. CRITION: You, you need to file whatever motion you think is appropriate. Pm going to do nothing to breach the anonymity order that has been entered by the Court. So if you if you think that some additional order is necessary, you have 15 days to file something with the Court, and then I'll respond to it, Brad. MR. EDWARDS: Okay. Thanks. MR. CRITIC/14: Okay. And Sid Garcia showed up. MR. GOLDBERGER: What am I? MR. CRITTON: And Jack Goldberger, too. Sony, you're not just a potted plant here. Thereupon, JANE DOE, Having been first duly sworn or affirmed, was examined and testified as follows: THE WITNESS: Yes. Page 12 1 Q. At the address where you're currently 2 residing, does anyone live with you? 3 A. Yes. 4 Q. Who? 5 A. My daughter and my boyfriend. 6 Q. Are you living in an apartment, a house? 7 What kind of accommodations? 8 A. A house. 9 Q. What city is the house located in? 10 MR. EDWARDS: Don't answer. 11 She's not going to answer any other questions 12 about the location of her address or the location 13 where she's residing, just out of fear for her own 14 safety and the safety of her daughter. 15 MR. CRJTTON: Okay. 16 BY MR. CRITTON: 17 Q. Ma'am, has, has anything occurred since 18 you've been represented by Mr. Edwards that causes you 19 concern about your safety or well-being? 20 A. Yes. 21 Q. What? 22 A. I have seen a lot of cars passing by my house, watching, looldng at my house, and going by very 24 slowly, several times a day. There have been cars that 25 were parked across the street from my house on several Page 11 1 DIRECT EXAMINATION 2 BY MR CRITTON: 3 Q. Would you please tell us your full name, 4 please. 5 A. Jane Doe. 6 Q. And you're going to need to speak up, ma'am, 7 because I could barely hear you. All right 8 A. Jane Doe. 9 Q. What's date of birth? 10 A. 11 Q. And where do you currently reside? 12 MR. CRITTON: Don't answer. 13 She's not going to give her current address, 14 and it's out of fear for her safety. And that's 15 the only question you're likely not going to get an 16 answer to today. 17 BY MR. CR/77ON: 18 Q. Let me ask you this: Do ou 19 nssidecl over the years at 20 EIR true? 21 A. Yes. 22 Q. All t. And whose address is that? 23 A. 24 Q. And her name is? 25 A. Page 13 1 different occasions, cars that I had never seen before. 2 There have been people who have gone to speak to my 3 friends and my family members and ask them questions 4 about me. 5 Q. So why — why — well, let's start with the 6 cars. On how many occasions since you well, on how 7 many occasions have you seen what you thought were B suspicious cars, as distinct from just like — as 9 distinct from just cars driving by? 10 A. Them have been so many, I can't — I can't 11 count 12 Q. Can you identity any of those suspicious 13 cars? Color? Make? Model? 14 A. For one, there is a blue Durango SUV that 15 comes by a lot 1,1have taken pictures of it. I have 16 taken pictures of all the cars. 17 Q. Oh, you have? And where, where are those 18 pictures? Did you take them on a digital camera? 19 A. Yes. 20 Q. Okay. And what did you do with those 21 pictures? 22 A. I sent them to Brad. 23 Q. And Brad, Mr. Edwards? 24 A Yes. 25 Q. Are you aware whether he's filed any motion (561) 832-7500 4 (Pages 10 to 13; PROSE COURT REPORTING AGENCY, INC. (563) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1552) Electronically signed by Pamela Sullivan (501-333-772-1652) ffeae621-3493-40“1-8666-00e698ca2735 EFTA00750710 Page 14 1 with the Court to try to identify who, to keep those 2 cars away from you? 3 A. Not that I'm aware of. 4 Q. Okay. How many pictures have you taken? 5 A. Four or five. 6 Q. And, and in terms of parked cars, have you 7 taken pictures of any of the parked cars? 8 A. One. 9 Q. What was that car? Was that the blue 10 Durango? 11 A. No. It was a silver — Pm not sure what 12 kind of car it was. 13 Q. Okay. Do you still have -- do you still have 14 your photographs of those cars on your camera? 15 A. Not on my camera. 16 Q. Did you take — how did you send them to 17 Mr. Edwards? 18 A. I have them on a disk. 19 Q. All right. And tell us — tell the members 20 of the jury how many times you've called the police 21 about this. 22 A. I haven't called the police, because 23 they — nobody ever came out and harassed me. I just 24 saw the cars passing my. 25 Q. All right. So no ones harassed you; no Page 16 1 talked to families and friends, where they have — let 2 me strike that. 3 You indicated various individuals had done -- 4 had talked or had spoken with family and friends about 5 you -- 6 A. Yes. 7 Q. correct? 8 All right Tell me which family members have 9 been contacted and asked questions about you. 10 A. The only one that I really !mow of is my 11 sister. 12 Q. 13 A. 14 Q. And what did tell you? 15 A. She just told me that me some people went to 16 her house and asked her some questions about me. 17 Q. When did tell you that? 18 A. lint not sure how long ago it was. She 19 actually sent me a text message. 20 Q. Was it within the last week? Was it in the 21 last month? Was it a year ago? Give me your best 22 estimate. 23 A. Probably a month, maybe two months. 24 Q. And did she tell you who the people were that 25 talked to her? And who's that? Page 15 1 one's intimidated you. All you've seen is cars that you 2 can't identify driving by and/or parking across the 3 street; is that correct? 4 MR. EDWARDS: Object to the form. 5 MR. CRITION: You can go ahead and answer. 6 MR. EDWARDS: Well, Pm going to object - MR. CR1TTON: No, no. 3 MR. EDWARDS: -- and ask her not to answer -- 9 MR. CROTON: It's form. 10 MR. EDWARDS: — if it is attorney-client 11 privilege information. Because you're acting like 12 she can't identify than, when, in reality, she may 13 have been able to identify them. 14 MR. CRITTON: Is that a form objection? 15 MR. EDWARDS: Pm telling her not to answer. 16 It's attorney/client information. 17 MR. COTTON: Would you read my question 18 back — 19 MR. EDWARDS: (Inaudible) her attorney. 20 MR. CRITTON: -• please. 21 (Whereupon, the requested portion of the 22 record was read aloud by the Court Reporter.) 23 THE WITNESS: Yes. 24 BY MR. CRITTON: 25 Q. All right. Now, you said some people have 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 17 A. No. Q. Did you ask her? A. Yes, I did. Q. And what did she say? A. She said that they worked for Jeffrey Epstein. Q. And did she say how those people got in contact with her? A. They went to her house and knocked on het door. Q. And did she tell you what she said to them? A. No. Q. Did she tell you whether she spoke with her — spoke with them? A. She said she did talk to them. Q. She did not? A. She did. Q. All right Did she say where — did she talk to them at the house? A. Yes. Q. And did she — and did you say, well, what did you say about me? A. Yes, I did. Q. Okay. And did you say, what questions did they ask? 5 (Pages 14 to 17) (561) 832-750C PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) f7eae821-3493.40cd-8080-00e888ca2735 EFTA00750711 Page 18 Page 20 1 A. Yes, I did. 2 Q. And when you said, what questions did they 3 a*, what did she say? 4 A. She, she said she doesn't really know. I 5 guess she doesn't remember. She says that she was asked 6 if she knew about my going to Jeffrey Epstein's house, 7 and she told them that she gave me a ride there before. 8 Q. And was that true? 9 A. Yes. 10 1Okay. On how many times did your sister, 11 give you a ride to Jeffrey Epstein's home? 12 A. Three, maybe four. 13 Q. And I assume you knew that she had driven you 14 to Mr. Epstein's house, separate and apart from her 15 telling you that the other day, or a month ago. 16 A. Excuse me? 17 mliassume you were aware that your sister, 18 , drove you to Mr. Epstein's house prior to the 19 last month or two; is that correct? 20 A. Yeah. 21 Q. And that is, her telling you that did not 22 refresh your recollection; you knew thatMl. had 23 driven you to Mr. Epstein's home; true? 24 A. Yes, I knew that. 25 Q. Okay. Did she say how long she had spoken to 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. All right. So we've had nine months in '09. Of, of the — of the nine months in 2009, what portion or what months can you • • that you did not have a good relationship wi ? milhave only been on speaking terms with for the past maybe three months. Q. So the past three months, which would be basically June-ish, beginning of June — A. Yeah. Q. — through today, you're on good tents with her? A. Yes. Q. All right. And good terms means you're acting like sisters — like I would say more normal sisters would, have a nice conversation, you can talk to her, you're supportive of each of one another, et cetera? A. Yes. Q. All right. Do you have any other sisters? A. Yes. Q. Okay. First of alla what's her date of ma. A. I don't know what year. Q. How old is she? Page 19 1 the people? 2 A. No. 3 Q. She, meaninga. 4 Did she — other than saying she gave a ride 5 to you to go to Mr. Epstein's house, did she tell the 6 individuals who came to her home anything else? 7 A. Not that I know of. 8 Q. Okay. How long did you — well, let me 9 strike that. 10 r, I alb /lave a good relationship with 11 your siste 12 A. It's on and off. We fight often. 13 Q. Are you on a good relationship with her now? 14 A. Right now l aro. 15 Q. Has that been true for the last six months? 16 A. No. 17 Q. Okay. Was it. sometime within tiniest 18 six months? 19 A. Yeah. 20 Q. When was that? 21 A. Fm not sure exactly how long ago it was. 22 I — 23 Q. Let me — let me rephrase my question. We're 24 in the year 2009, almost at the end of September 30th 25 today. You're aware of that? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 21 A. Q. A. A. Q. A. Q. A. Q. A. Q. And A. She be on Q. She's now. Andes is, you said, was how old, how many years — A. Two years older than me. Q. So she's.? A. Yes. Q. All children of the same marriage, with the same mother and A. My sister., has a different father. Q. What's her father's name? A. I don't know. Q. Does she know? A. No. She's six years older than I am. So do you have another sister? Yes. Older or younger? itOlder. her name? How old is-? She is two years older than I am. ow old today? (561) 832-7500 PROSE COURT REPORTING AGENCY, 6 (Pages 18 to 21) INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501.333-772.1662) 170a0621-3493.40cd.8666-000698ca2735 EFTA00750712 Page 22 1 Q. No one knows? 2 A. No. 3 Q. So your mother -- your mother — obviously, 4 same mother? 5 A. Yes. 6 Q. a And your mother's name is what? 7 A. 8 Q. Lt name? 9 A. 10 Q. Where does she live? 11 A. I don't }mow her address. 12 Q. When is the last time you saw her? 13 A. About a week or so ago. 14 Q. :Where did you see her? 15 A. She came to my house. 16 Q. So at least you — you at least told your mom 17 where you live? 18 A. Yeah. 19 Q. All right. Now, what — what's her 20 date of 21 A. 22 Q. Good relationship with int 23 A. We don't speak on a regular basis, but we are 24 nice to each other, I guess. 25 Q. Where does she live? 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. Q. A. Q. A. Q. A. Page 24 She does not have a home phone number. Does she have a cell phone? Yes. Do you consider a cell phone a phone number? Yes, but not her home number. allither cell phone number? Q. What's your cell phone number? A. My cell phone number? Q. Yes, ma'am. MR. EDWARDS: Don't answer. mean, you're not going to call her, so I'm, I'm objecting and, and in the witness not to give out her cell phone number on the record right now. BY MR. CRITfON: Q. Okay. Why don't you want to — well, you're going to follow your lawyer's instruction? If he tells you not to answer a question, you're going to follow that instruction? A. Yes. Q. Okay. And — (Discussion held off the record.) BY MR. CRITTON: Q. How long have you — the current cell phone 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 Q. Do you know her phone number? Page 23 A. Alabama. Q. Do you know her address? A. No, I do not. Q. Is she married? A. No. Q. Any children? A. Yes. Q. How many? A. Two. Q. And ever been married? A. No. Q. What does she do for a living? How does she support herself? A. I — I'm Q. Okay. where does she live? A. A. Q. A. Q. Does she live there with anyone? A. Yes. Do you know her address, exact address? Q. A. No. Ws off of Which is whey o West Palm Beach? Yes. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 Page 25 1 that you have now, how long have you had it? 2 A. About two years. 3 Q. Did you have a cell phone before that time? 4 A. Yes. 5 Q. Okay. Bow long did you have that cell phone? 6 A. I'm not sure. I didn't have it for very 7 long, and I lost it. 8 umber? A. Q. Did you ever use a cell phone to call Mr. Epstein's home? A. Yes. Q. issirt the number you would have used, the A. No. Q. Okay. Did you have a prior cell phone number? A. Yes. Q. All right What was that number? A. I don't remember the full number. I remember that it started with 352. Q. Was it your own? Was it under your name? A. No. Q.issis it under? A. (561) 8 32-7 5 0 0 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 17eae621-3493-40cd-8666-00c693ca2735 EFTA00750713 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. III..? A. Q. A. NO. A. A. Q. A. Page S Yes. Does she still have that same cell phone? Who was the service provider, her number? Sprint, i believe. Who's your service provider right now? Metro. I'm sorry? Metro PCS. Q. Have you used your cell phone is a friend of yours? A. Yes. Q. Okay. is a friend of yours? A. Yes. Q. Okay. Are you aware of any other individuals who are Plaintiffs in — and are suing Mr. Epstein for money? A. No. Q. Do you call — do you have a home phone? A. Yes. Q. A land line? A. Yes. All right. I assume you've called bode midi.. on your cell phone? Page 28 1 At some point, Mr. Edwards came to represent 2 you; true? 3 A. Yes. 4 Q. All right. And when did Mr. Edwards — when 5 did you hire Mr. Edwards to represent you? 6 A. Pm not sure exactly what day that was. Q. Clearly, it was before the lawsuit was filed, 8 which was August 13th; correct? 9 A. Ulbhult Yeah. 10 Q. All right How many months prior to that 11 lawsuit being filed did Mr. Edwards begin to represent 12 you? 13 A. I'm not exactly score. 14 . There was another suit that was filed 15 hair:mit, Jane Doe. It dealt with a claim of, 16 of asserting some sort of victim rights. Were you that 17 Jane Doe? 18 A. I don't know. 19 Q. Okay. Well, are you aware of any other 20 lawsuit that's been filed — that was ever filed on your 21 behalf, where Mr. Edwards represented you, other than 22 the current lawsuit, Jane Doe versus Jeffiey Epstein? 23 A. I don't know. 24 Q. Okay. So you — you're unaware of any 25 lawsuit that Mr. Edwards has ever filed on your behalf; Page 27 1 A. Yes. 2 Q. All right. And I assume that you talked to 3 them about your cases from time to time; true? 4 A. No. 5 Q. You so if I ask you is it your testimony, 6 as you sit here today, that since the time you filed the 7 lawsuit against MrStein, you have never discussed 8 your lawsuit withM.? 9 A. No. 10 Q. That's not true — that's not correct? 11 A. What is not correct? 12 Q. All right. Listen -- let me ask the question 3.3 again. 14 Is it a correct statement, that is what Fr() 15 going to say, is this true, that since the time you 16 filed your lawsuit in August of 2008, you have not 17 discussed your lawsuit with M.; is that correct? 18 A. That is comsat. 19 Q. And you've not discussed either your lawsuit 20 or any aspect of your lawsuit or your interaction with 21 Mr. Epstein with.. since August 13th, 2008; is that 22 correct? 23 A. Yes. 24 Q. All right Since August 13th — well, let me 25 strike that. Page 29 other than Jane Doe versus Jeffrey Epstein; is that 2 correct? 3 A. Well, I would probably be aware, but I'm 4 obviously not a lawyer, so I don't really know. 5 Q. You're — before Mr. Edwards filed your 6 lawsuit here, in this instance, you had to give him 7 authority; didn't you? 8 A. Yeah. 9 Q. Okay. Have you ever given Mr. Edwards 10 authority to fide any other lawsuit anyplace on your 11 behalf; yes or no? 12 A. I don't know. 13 Q. Okay. Well, you can't answer that just so 14 for the jury — ladies and gentlemen of the jury, you 15 can't answer that question yes or no; is that what 16 you're telling us? 17 MR. EDWARDS: She's not going to answer the 18 question because you're asking attorney/client 19 privilege information. 20 MR. CRITTON: She's already asked — she 21 already answered the question, so you waived the 22 attorney/client privilege. So now — 23 MR. GARCIA: Right 24 MR. EDWARDS: That's your — that's your 25 opinion, but she's not going to answer — answer (561) 832-7500 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) fteao621-3493-40cd-8666-000698ca2735 EFTA00750714 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 1 any more questions along this line. So — 2 MR. CRITTON: Okay. 3 MR. GARCIA: —you can ask as many questions 4 as you want. 5 MR. CRITTON: She's not your client -- 6 MR GARCIA: That's right. 7 MR. CRTITON: — all right, Mr. Garcia? 8 She — she — 9 MR. GARCIA: You made a misstatement of the 10 law. You can't waive attorney-client privilege. 11 MR. CRITTON: Sure, you can. 12 MR- GARCIA: It has to be knowing and 13 intelligence. And she -- she — 14 MR CRITTON: Well, you bow — okay. Is 15 your objection as to form? 16 MR GARCIA: Fm just saying it's a 17 misstatement of the law. 18 MR. CRAYON: Fine. Then you can object to 19 form. 20 BY MR. CRITTON: 21 Q. Have you hired any other lawyers, or at any 22 time did you hire any other lawyers than Mr. Edwards to 23 pursue your claim? 24 A. No. 25 Q. Okay. Do you know a person by the name of 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 32 A. Last Thursday. Q. You say he's at Okaloosa? A. Right now he's in Martin County, but he was at Okaloosa Prison. Q. Okay. And he's serving a sentence for having murdered a young boy a true? A. Yes. Q. And that occurred when you were how old? A. Twelve. Q. How long have you had the tattoo, ma'am? A. Since lives 18. Where did you get the tattoo done? At the 45th Street flea market Q. Do you remember the name of the place? A. No. Q. Do you have any other tattoos? A. Yes. Where? On my legs. And what are they of? Are they visible? Yes. Q. A. Q. A. Q. A. Q. Okay. Could I see them, please? A. (Witness standing.) That's my nephews (indinting). Q. Page 31 1 Jay Howell? 2 A. No. 3 Q. Okay. Ever heard of the name Jay Howell? 4 A. No. 5 Q. Have you authorized him to represent you? 6 A. No. Q. Ms. Jane Doe, I notice you have a tattoo on your right arm, your right, upper arm; is that correct? A. Yes. Q. And what does it say? A. Q. that's what it spells, IME? A. That's what it would spell, but it's actually Q. That's A. Yes. Q. When did you -- where does he currently reside? A. Martin County jail. Q. And he's serving a sentence there; correct? A. Urn, actually, he's, urn -- he's down from Okaloosa Prison for a hearing Q. Did you see him when he was here? A. Yes. Q. When did you last see him? Page 33 1 A. That's my other sister's two children, niece 2 and nephew (nephew). 3 Q. All right And they — 4 A. Q. And she as one child? 6 A. Yes. 7 Q. Okay. And the other tattoos on your left -- 8 around your left ankle are your -- children? 9 A. Yes. 10 Q. All right. When -- when did you receive, or 11 when did you have the tattoo of= ptn on? 12 A. That was my first one, and so l gotragr 13 I named 18. 14 Q. Where? Where did you get it? 15 A. On my right leg. 16 Q. I'm sorry? 17 A. On my right -- 18 Q. No, no. 1, !saw that. Where, 19 location-wise, did you have the tattoo put on? 20 A. I had tern all done at the same place. 21 Q. 45th Street flea market? 22 A. Yes. 23 Q. And where is the 45th Street flea market? 24 A. On 45th Street 25 Q.. I gathered that, but where? Is it toward is whose child? (561) 832-7500 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-7724662) Electronically signed by Pamela Sullivan (501-333-772-1542) f7eae621-3493-40cd-8666.00e698ca2735 EFTA00750715 Page 34 1 'Dail? Is it toward the dump? Is it toward 2 45th Street toward — toward — toward the east? 3 A. Um, it's it's west of the hospital. 4 Q. Pardon? 5 A. West of the hospital, St. Mary's, that is 6 also on 45th Street. 7 Q. All right. Do you know where s? 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. Q. A. Q. A. Q. A. A. Not exactly. Do you know what s? Yes, 'do. sin an a t s I I Okay. Are you aware it's a gentlemen's club? Excuse me? Are you aware it's a gentlemen's club? No. I -- Adult entertainment? Yes. Q. Okay. So in addition to being it's also -- it has adult entertainment, with — with women who take off their clothes, strippers; true? A. What does that have to do with anything? Q. Can you answer my question, yes or no? A. I, I would guess that that is true, yes. Q. Okay. Well, you're familiar with gentlemen'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 36 east of the hospital? A. West. Q. West of the hospital. And it's actually on 45th Street? A. Yes. Q. Okay. Is do you know where the Oalcv/ood Center is, what used to be the 45th Street Community Mental Health Center? A. No. Q. Okay. Do you know where Australian Avenue is on 45th Street? A. Yes. Q. Okay. So the flea market would be between Congress and Australian? A. I think it might be before that. I'm not — I haven't been there in a long time. Q. Okay. When you had the tattoos put on, the three tattoos, two around your ankle and one on your right, upper arm, were they all put on at the same time? A. No. Q. Did they have you fill out a form each time? A. I don't remember. Q. Okay. Over what period of time did you have the three tattoos put on? A. In between 18 and 19. Page 35 1 clubs; true? 2 A. Yes. 3 Q. Adult entertainmeM? 4 A. Yes. 5 Q. Becaur you've worked at them; true? 6 A. Yes. 7 a so when you said was aMI a you also ;mew at the time you answered that 9 question that it had adult entertainment; that is, it 10 was a strip club, as well; true? 11. A. I have never been to before, so, no, 12 I wouldn't know that. speak, that Q. But you know that from general — fro. 14 having been in the buness, so to speak, 13 15 as well, in addition to serving food, as well, is a 16 strip club; true? 17 A. How would I know that? 18 Q MI right. You can tell me you don't know 19 that. I'm okay with that answer, too. I just want the 20 gentlemen — the ladies and gentlemen of the jury to 21 understand that you — that today is the first time that 22 you learned that actually had adult 23 entertainment is that correct? 24 A. Yes. 2 5 Q. All right. 45th Street flea market, so it'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 37 Q. Do you have any other tattoos, other than the tine? A. No. Q. Were you required to show a form of ID? A. Yes. Q. All right. Did you show them your driver's license? A. No. Q. What did you show them? A. My ID card. Q. And when you say your ID card, what's an ID card? A. It's a card with your picture on it and your O917IC. Q. All right. And what's it — and where did you get your ID card? A. At the MEV. Q. All right So do you have a driver's license? A. No. Q. All right. Have you ever had a driven license? A. No. Q. How long have you had a D -- an ID card? A. Since I was 17. (561) 832-7500 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (501-333-772-1552) 17eae821.3493-40cd-8666-00e898ca2735 EFTA00750716 Page 38 1 Q. Do you have the same card now? .2 A. Yes. 3 Q. Do you have it with you today? 4 A. Yes. 5 Q. Could I see it so we can mark it as an 6 exhibit, make a copy and mark it as an exhibit? 7 MR. CRITTON: Go ahead. 8 THE WITNESS: (Handing to Mr. Edwards.) 9 BY MR. CRITTON: 10 Q. What you've handed me and what we'll mark as 11 Exhibit 1, is that a true and accurate well, is that 12 the only ID card you've ever had? 13 A. Yes. 14 MR. GOLDBER.Glift It's a duplicate. 15 THE WITNESS: Yes, it's a duplicate. 16 BY MR. CRTITON: 17 Q. Okay. And why is it a duplicate? So do you 18 have another card, as well? 19 A. No, I lost it 20 Q. And this obviously doesn't have your current 21 address on it, because that's the address that you won't 22 disclose; correct? 23 A. Yes. 24 Q. All right. And the 25 address is not your current address; correct? 1 2 3 4 5 6 7 B 10 11 12 13' 14 15 16 17 18 19 20 21 22 23 24 25 Page 40 Where - what adult entertainment establishments have you worked at? A. Q. Pm so A. Q. Where? A. Q. A. Q. Ali ri t. Where else? Where is that located? A. West Palm Beach. Q. What's the address forailli? A. I don't know. Do you know what street ifs on? A. It's on Q. •MAnd A. 'think Q. During what time 'dad well, let me ask you this: With , were you required to show the individuals who hired you that you had an adult entertainment card? A. No. Q. Wasn't an adult entertainment card required at that time? where is that located in Page 39 1. MR. EDWARDS: Objection. She's not going to 2 answer the question. 3 MR. CRITTON: Well — well, we'll get a copy. a If you will just leave that out, Ms. Jane Doe, 5 we're going to make a copy of that, and then well 6 attach that to the to the deposition. 7 (Whereupon, Mr. Garcia left the proceedings.) 8 BY MR. CRJTTON: 9 Q. Ms. Jane Doe, how many fake ID's have you 10 had? 11 A. Zero. 12 Q. It's your testimony that you've never had a 13 fake ID? 14 A. Yes. 15 Q. Okay. So if there will be witnesses in this 16 case that will testify that you had a fake ID, they 17 would be lying; is that true? 18 A. Absolutely. 19 Q. Have you ever had an adult entertainment 20 card? 21 A. No. 22 Q But you worked at adult entertainment en , 24 A. Yes. 25 Q. Did — did — well, let me ask you this: 1 2 3 4 5 6 7 8 11 12 13 14 15 16 17 18 19 20 21 22 24 25 Page 4 A. Excuse me? Q. Was there a requirement within the County that you have an adult entertainment card at the time you worked at A. I don't know. Q. How about-, did they ever require WO adult entertainment card? A. No. I only showed ID. Q. And Mats the same ID that you have with you today that, I assume, is the duplicate, except you have the original? A. Yes. Q. Okay. And when did you get your duplicate? A. I'm not sure. Q. All right. Was it within the last six months, within the last year? A. I'm not — I'm not sure where — when I got it Q. I want to go back to a question I asked you earlier. I asked you whether you had any conversations — well, let me strike that. Now. I asked you when you retained the ormr. didn't know. All you know, it was sometime before the lawsuit was filed in August, on or about August 13th of (561) 832-7500 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) fleac621-3403-40cd-8666-000698ca2738 EFTA00750717 Page 42 1 2008; correct? 2 A. Yes. 3 Q. Okay. How many months prior to the filing of 4 the lawsuit had you hired Mr. Edwards? S A. I don't !mow. 6 Q. A month? A week? 7 MR. EDWARDS: Objection. Asked and answered. 8 BY MR. CRITTON: 9 Q. Two months? Your best estimate. 10 MR. EDWARDS: Object to the form. 11 THE WITNESS: I don't know. 12 BY MR. CRITTON: 13 Q. Did you hire Mr. Edwards in 2007? 14 A. I don't bow what year it was. 15 Q. Do you know if it was in 2006 that you hired 16 Mr. Edwards? 17 A. I don't know. 18 Q. Okay. So you don't know whether you hired 19 Mr. Edwards in 2006, 2007 or 2008; is that your 20 testimony? 21 A. Yes. 22 Q. At the time that you hired Mr. Edwards, was 23 he representing either III or IIN? 24 A. I don't —1 don't know. 25 Q. How did you get to Mr. Edwards? Page 44 1 A. 2 Q. So people -- you say there were people that 3 were going to those houses? 4 A. People who worked for the FBI. 5 Q All right So the FBI was corning to your 6 mother's house, your sister's house and your 7 grandmother's house; did you say? 8 A. Yes. 9 Q. And how did you learn that fact? Fran them? 10 A. They left cards. They spoke to my family 11 members who told me about it. 12 Q. Okay. Anyone else? That is, other than your 13 grandmother, your mother, -; and your 14 sister, did the FBI talk to anyone else — 15 MR. EDWARDS: Object to the form. 16 BY MR. CRITTON: 17 Q. — that you're aware ot about -- about you? 18 A. I don't know. 19 Q. All you remember is that Ma NB and 20 your grandmother told you that the FBI had come to their 21 house, asking questions about you — 22 A. Yes. 23 Q. and had left their card? 24 A. Yes. 25 Q. Who were the people from the FBI; do you Page 43 1 A. I, I got his card somehow. I guess he had 2 spoken to somebody else and gave them his card, and they 3 gave it to me. 4 Q. Okay. Who was the person who gave you 5 Mr. Edwards' card? 6 A. I don't remember. 7 Q. 'Ibis is the person who gave you a card for a 8 lawyer, now your lawyer, Mr. Edwards, and you don't 9 remember or have any idea who that person was; is that 10 correct? 11 A. Yes. 12 Q. All right. And you don't remember whether 13 that was in 2006, 2007 or 2008; correct? 14 A. Yes. 15 Q. Do you remember whether it was a man or a 16 woman, male or female that gave you the card? 17 A. No, I don't remember who it was. 18 Q. Do you remember how they happened to give you 19 the card; that is, what was the event or circumstance 20 that caused them to give you the card? 21 A. Um, there were, I guess, people who worked 22 for the FBI who were going to my house and my mother's 23 house and my sister's house, trying to find me, to speak 24 tome. 25 Q. Which sister? 1 2 3 5 7 8 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 Page 45 know — that were leaving cards? A. One of their names was Jason. Q. And — A. There was a woman, but I don't remember her name. A. Q-A. A. A. wallet? A. Yes. Q. Did you — do you remember the timeframe that the FBI was coming, hying to contact you, that is going to your family members' houses to contact you? A. I was pregnant. Q. All right. And you have a daughter? A. Yes. Q. And what's her name? Were those cards given to you by — Yes. — by any of your family members? Yes. Do you still have them today? No. What did you do with them? I don't know. How do you know you don't have them, then? Because I use my wallet often. All right. And the cards were in your (561) 832-7500 PROSE COURT REPORTING g ya..{.,..,.:¢1 ‘,....,,,Q•YISI.Com.1 am...... ..,••••3O24.41 : 12 (Pages 42 to 45 AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (5a1-333.772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) thae621-3493-40cd-8666-00e698ca273S EFTA00750718 8 9 10 11. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 46 1 2 3 4 5 6 Q. Bow pregnant were you with the time 7 that the -- you were hearing from your family members 8 that Jason and some other female FBI agent were 9 interested in speaking with you? 10 A. I heard that they had been there months 11 before when I was not pregnant. And when I had actually 12 spoken to them, I was three or four months pregnant -- 13 three and a half months pregnant. 14 Q. You're sure of that? 15 A. Yes. 16 Q Okay. And how are you sure you were only 17 three and a half months pregnant? 18 A. Because I went to a doctor. 19 Q. All right. Okay. When when do you 20 believe your -- that — that you first became pregnant? 21 Just give me a time that you believe that conception 22 occurred, I guess, is probably the best way to describe 23 it 24 A. I don't !mow. 25 Q. All right. Do you know the date that you Page 48 1 A. Yes. 2 Q. An individual who identified herself as an 3 FBI, at least on her card? 4 A. Yes. 5 Q. All right. Did you ever return any of the 6 phone calls to these individuals? 7 A. Yes, I did. 8 Q. At what point in time did you contact them? 9 And just give me that -- well, I think you said — well, 10 let me strike that 11 You said you met with them three and a 12 half you were approximately three and a half months 13 pregnant at the time; correct? 14 A. Yes. 15 Q. Okay. And you're sure of that? 16 A. Yes. 17 Q. AU right. And who did you call; which FBI 18 person did you call? 19 A. I don't remember. 20 Q. Okay. And why did you call the FBI person? 21 A. I don't know. 22 Q. At time that the FBI contacted you, had you 23 heard anything about anyone contemplating a lawsuit for 24 money damages against Mr. Epstein? 25 A. No. Page 47 1 met, actually met with FBI individuals? 2 A. I do not know the exact date. 3 Q. Did you meet with the FBI individuals on more 4 than one occasion? 5 A. No. 6 Q. Let me just go back. So you heard from 7 family members that the FBI — certain individuals from the FBI, one person being Jason someone, because you had a cant at one point in time, wanted to speak with you, and that was approximately four or five months before they ultimately spoke with you? MR. EDWARDS: Form. THE WITNESS: Yes. BY Fat CRITTON: Q. All right. Did — did your — who -- who gave you the FBI cards? A. and my my mother and my sister. Q. fniala A. A. A. my mother and my sister. Were all the cards from the same people? No. There were different cards? One was from a woman. But an FBI person? 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 49 Q. Okay. At the time that you contacted the FBI, based on the cards that were given to you, had you spoken with anyone about what you allege occurred at Mr. Epstein's home -- with anyone, anyone from law enforcement? A. No. Q. Had you ever been contacted by the — by the Palm Beach County State Attorney's office? A. I don't /mow. Q. Have you ever spoken with anyone from the Palm Beach County — Palm Beach County State Attorneys office? A. I don't know. Q. Okay. Well, when I say, spoken with them about, obviously about your -- similar to the allegations that you've made in your complaint directed to Mr. Epstein. So what I meant, saying, have you spoken with anybody at the State Attorney's office or anyplace else, I'm interested as to the allegations that you've raised in this complaint do you understand that? A. Yes, I understand that Q. Have you ever spoken with anyone who represented themselves to be a State Attorney with the Palm Beach County State Attorney's office about Mr. Epstein? (561) P32-7500 PROSE COURT REPORTIN • 13 (Pages 46 to 49) G AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1562) Electronically signed by Pamela Sullivan (601-333-772-1662) freae621-3493-40ed-B666-00e698ca2735 EFTA00750719 Page 50 1 A. Not that I know of. 2 g Well, you'd know if you spoke with someone — 3 MR. EDWARDS: Object to the form. 4 BY MR. CRITTON: 5 Q. -- from the State Attorney's office; wouldn't 6 you? 7 A. Excuse me? 8 Q. I said, you would !mow if someone said, Pro 9 from — Pm Sam Smith from the State -- Palm Beach 10 County State Attorney's office, I want to talk to you. 11 You would remember that; wouldn't you? 12 MR. EDWARDS: Form. 13 THE WITNESS: There were a lot of people that 14 came to my house, wanting to talk to me. 15 BY MR. CRITTON: 16 Q. You need to answer my question. Okay? Would 17 you Re it read beck to you? 18 A. I don't remember. 19 Q. Have you ever spoken at any time in your life 20 about anything with a State -- the State Attorney or an 21 Assistant State Attorney from Palm Beach County about 22 anything? 23 A. I don't know. 24 Q. Okay. Well, you've been in trouble with the 25 law before; correct? Page 52 1 be from the office of the United States Attorney? 2 A. No. 'don't — !don't remember if I did or 3 not. 4 Q So the, the individuals, at least 5 governmental, • or state or local 6 officials, that you've ever discussed any of the 7 allegations that you've alleged in your complaint 8 against Mr. Fprin would have been with the FBI 9 MR. EDWARDS: Object to the form. 10 BY MR. CRITTON: 11 Q — is that correct? 12 MR. EDWARDS: Fonn. 13 THE WITNESS: Yes. 14 BY MR.. CRITTON: 15 Q. Is that correct? I'm sorry. 16 A. Yes. 17 Q. Asa result of the cards that you received, 18 did you contact one of those individuals? That is, your 19 family gave you cards for the FBI; then you contacted 20 them? 21 A. Yes. 22 Q. Okay. Had your mother, your sister or your 23 grandmother told the FBI where you could be found? 24 A. I don't know. 25 Q. Where were you living at the tine? Page 51 1 A. Yes. 2 Q. Okay. And have you had to deal with State 3 Attorneys under those circumstances? 4 MR. EDWARDS: Object to the form. 5 THE WITNESS: I don't know. 6 BY MR. CR1TTON: 7 Q. The State Attorneys, though, you — you 8 understand those are the ones that prosecute you — 9 would have prosecuted you; true? 10 A. Yes. 11 Q. All right. Okay. Have you — and it's your 12 testimony you can't remember -- it's — you have no 13 recollection of having spoken with anyone from the Palm 14 Beach County State Attorney's office? 15 A. No, I do not 16 Q. That's correct. 17 All right. Did you ever speak with anyone 18 from the Palm Beach Police Department regarding any of 19 your allegations that are set forth in your complaint 20 directed to Mr. Epstein? 21 A. No. 22 Q. Did you ever speak with a United States -- 23 well, let me strike that. 24 Did you ever speak with an assistant attorney 25 or an attorney from -- who represented him or herself to Page 53 1 A. With a friend. 2 Q. Who? 3 4 Q. Olcayhiou were living with. at the time. 5 Where does= reside — or where was she living at 6 that time? 7 A. 8 Q. Address, please? 9 A. I don't know the address. 10 Q. What street? 11 A. I don't know the name of the street. 12 Q. HoW did you know how to get there? 13 A. I knew what the neighborhood looked like. 14 Q. Okay. You don't drive a car? 15 A. No. 16 Q. Okay. Have you ever had a car, owned a car? 17 A. No. 18 Q. Have you ever driven a car? 19 A. Yes. 20 Q All right. So you have driven a car, but you 21 haven't had a license? 22 A. Yes. 23 Q. All right. Do you still drive a car, say 24 over the past year, without a license? 25 A. No. b6 ...Y0J•Wawn w.wwW•sa.C.••• •••••••10. .1A4 (561) 832-7500 14 (Pages 50 to 53) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (601.333-772-1552) 17eae621-3493.40cd-8668-00e698ca2736 EFTA00750720 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 54 1 Q. How would you get around when you were living 2 with MI? 3 A. She would take me. 4 How long -- how long had you been living with 5 — well, let me strike that. 6 On how many occasions have you lived with A. Two. Q. During what time -- you and have been childhood friends? A. No. Q. When did you meet s? A. I believe I was 13 when I met her. Q. Do you bow what l's date