UNITED STATES DISTRICT COURT

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME 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 DEPOSITION OF JANE DOE NO. 5 Friday, February 26, 2010 8:07 - 3:44 III. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1312 PROSE COURT REPORTING AGENCY, INC. EFTA01076383 EFTA01076384 Page 2 Page 4 APPEARANCES: On behalf of the Plaintiff: 3 STUART S. MERMELSTELN, ES laRMELSTEEN & HOROWITZ, M. 18205 Biscayne Boulevard Suite 2218 Miami Phone: 6 E-mail: 7 On behalf o the en t: 3 ROBERT D.CRJTTON,JR,ESQUIRE MARK T. LUTHER. ESQUIRE 9 BURMAN, CRITTON, LUTHER & COLEMAN, UP 303 Banyan Boulevard Suite 400 West P • • ride 33401 31 Phone: 12 13 14 ALSO PRESENT: 15 16 17 18 19 20 21 22 23 24 25 &eche Quimby, Videographer Visual Evidence, Incorporated 2 3 4 5 6 7 8, 9 10 11 12 13 14 15 16 18 19 20 21 22 23 24 25PROCEEDINGS Deposition taken before Cynthia Hopkins, Registered Professional Reporter and Florida Professional Reporter, and Notary Public in and for the State of Florida at Large, in the above cause. THE VIDEOGRAPHER: This is the 26th day of February, 2010. The time is 829E. This is the videotape deposition of Jane Doe No. 5 in the matter of Jane Doe No. 2 versus Epstein. This deposition is being held at 250 Australian Avenue South, West Palm Beach, Florida. My name is Sascha Quimby. I'm the videographer representing Visual Evidence, Inc. Will the attorneys please announce their appearances for the record. MR. MERMELSTEIN: Stuart Mermelstein for Plaintiff Jane Doe No. 5. MR. LUTTIER: Mark Luther for Jeffrey Epstein. MR. CRITTON: Bob Critton for Jeffrey Epstein. 1. 5 7 3 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 3 INDEX EXAMINATION DIRECT CROSS REDIRECT JANE DOE NO. 5 BY MR. CRITTON 5 NO EXHIBITS MARKED Pag 1 Thereupon, 2 • (JANE DOE NO. 5) 3 having been first duly sworn or affirmed, was 4 examined and testified as follows: 5 THE WITNESS: Yes, I do. 6 DIRECT EXAMINATION 7 BY MR. LUTTIER: 8 Q. Good morning, ma'am. My name is 9 Mark Luttier, and we're here today for purposes of 10 taking your deposition. Could you tell us your full 11 name. 12 A. Jane Doe No. 5. 13 Q. And how do you spell your middle name? 14 A. (Witness spells her middle name.) 15 Q. Okay. Ms. Doe No. 5, have you ever been 16 deposed before? 17 A. No. 18 Q. That's this process that we're doing here 19 today. 20 A. No. 21 Q. Okay. And let me explain a little bit 22 about the process. First of all, you understand 23 you're under oath? 24 A. Yes. 25 Q. Okiy. I'mxing to ask you uestions, and 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. EFTA01076385 Page 6 1 you're going to have to give a verbal response 2 because this court reporter is going to transcribe 3 everything that you say. 4 A. Okay. 5 Q. So you can't shake your head and you've to 6 to actually say a word so she can get it down. 7 A. Okay. 8 Q. If you don't understand a question that I 9 ask, tell me you don't understand it and I will 10 explain it for you. 11 A. Okay. 12 Q. Okay. If you answer a question, I will 13 assume you understood it. 14 A. Okay. 15 Q. Okay. If during the deposition you want 16 to take a break, just let me know, and I'll be happy 17 to accommodate you. 18 A. Okay. 19 Q. If during the deposition you think that a 20 previous response that you gave me needs to be 21 amended or changed in any way, just tell me, you 22 know, I just thought of something. I need to go 23 back and correct something or supplement, whatever 24 you think has to happen. Okay? 25 A Okay. 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 A. 1 don't have an accurate date. Q. Well, approximately. A. It was before I started school. Q. And when you say "started school," what do you mean? A. Started cosmetology school. I just finished. Q. And what cosmetology school are you referri A. Q. And when did you start that? A. Last February. Q. That would be February 2009? A. Yes. Q. So sometime prior to 2009 a psychiatrist in Florida who prescribe for you? A. No. My recent visit to was in Florida. I was in Virgina at the time before I went to Ill id Virginia that's where I got my first prescription of e n Q. Okay. Who ysiclan who on you? Would it be a Dr A. It, l'm not sure, because I was seeing a psychologist and a psychiatrist, so I wouldn't know. I Page 7 1 Q. Are you presently under any kind of 1 2 medication? 2 3 A. No. 3 4 Q. In the last six months have you been under 4 5 any medication? S 6 A. Yes. 6 7 Q. What medication have you been under in the 7 8 last six — 8 9 A. . 9 10 Q. — months? 10 11 AL =B. That's it. 11 12 Q. And what's the level of= that is 12 13 prescribed for you? 13 14 A. Twenty and then it went up e. 14 15 Q. Okay. Most recently it was milligrams? 15 16 A. Yes. 16 17 Q. And how fte; you prescribed to take 17 18 .-milligrams ofaber 18 19 A. I took it once a day, once in the morning. 19 20 Q. And who prescribed that drug? 20 21 A . It was a new doctor in Florida. I do not 21 22 recall the name. 22 • 23 Q. Was, what kind of doctor was it? 23 24 A. Psychiatrist. 24 25 Q. And when was it first prescribed fiat. you? .25 . „ Page 9 can't put a name to the face of who it was. Q. This is, you were seeing a psychologist and a psychiatrist? A. In Virginia. Q. Okay. What psychologist were you seeing? A. I don't remember. Q. And when was it you were seeing this psychologist and psychiatrist in Virginia? A. Around the same time before I started school in Virginia. Q. So were you seeing than in January of '09? A. Yes. Q. I want to refer to — I'm going to read to you your answers to interrogatories that you gave in this case which were dated by you January 26th, '09. Interrogatory 12 asks you to list all the physicians — A. Uh-huh. Q. — that you had been to. I'm going to show that list to you. A. Okay. Q. You see Interrogatory 12 there? You don't mind my hand, my highlighting. And I think there's one name on the next page. A. Okay. 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. EFTA01076386 Page 10 1 Q. So, can you tell me which of these people 2 is the psychologist that you were seeing in 3 Virginia? 4 A. I don't think ifs listed. 5 Q. Can you tell me which of those physicians 6 is the psychiatrist that you were seeing in 7 Virginia? A. I think it's this one, 9 Q. Read the, the name. 10 A. 11 Q. 111111..,ame? 12 A. It doesn't say. I don't know. 13 Q. Well, how long did you see this 14 psychiatrist? 15 A. I saw her — I had two visits. I'm guessing. 16 That's not 100 percent accurate. 17 Q. Okay. 18 A. That was just — 19 Q. Okay. Would you pass me those 21 interrogatories so I can see if you have a date 21 here. All right. In answer to 8 you said that — 22 what you answered was, in response to an 23 interrogatory that asked you to list all of the 24 physicians and medical facilities or other health 25 care providers including psychiatrists, Page 12 1 right? 2 MR. MERMELSTEIN: Objection to form. 3 THE WITNESS: I, I don't, I don't 4 remember, honestly. 5 BY MR. LUTHER: 6 Q. Okay. Well, let me ask you this: Do you 7 have a, an absolute specific recollection that you 8 did, in fact, see a psychiatrist -- 9 A. Yes. 10 Q. — and psychologist in Virginia? 11 A. Yes, yes. I just don't remember. 12 Q. And the psychologist that you saw in 13 Virginia was male or female? 14 A. Psychologist Was it -- they were both 15 females. 16 Q. Okay. Do you know the difference do 17 you know there's a difference between a psychologist 18 and a psychiatrist? 19 A. Yes. 20 Q. Okay. I'm now asking you about the 21 psychologist 22 A. Okay. 23 Q. There was a female psychologist. 24 A. Uh-hub. 25 Q. And do you remember her name? Page 11 1 psychologists, mental health counselor, et cetera, 2 that you had been treated for in the last ten years. In Number 8, you list and you give a PO Box. And the interrogatory tells you to state, as to each the 6 dates of the examination and the condition or injury 7 for which you were examined. And what you put was 8 December 2007, dermatitis. 9 Now, you understand dermatitis is a 10 skin condition? 11 A. Oka Well then I must be confused because 12 I did have 14 Q. Okay. So now you're saying 8 is not the 15 psychiatrist that you saw in Virginia? 16 A. No, no. 17 Q. So, in answering your interrogatories, you 18 have — you did not give us either the name of the 19 psychologist or the psychiatrist who treated you in 20 Virginia? 21 A. I guess not. No, I guess not. 22 Q. Pm not, I'm not quibbling with you over 23 words, but when, when we hear the word "guess," you 24 know, it makes us a little nervous. So, when you 25 say you guess riot, you definitively know you didn't, 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 13 A. No. Q. Do you remember her first name, her last name, any combination of the two? A. No, I don't Q. Do you have any records from which you can determine that name? A. At home. Q. Home, meaning what, here in Palm Beach County? A. Home in Virginia. Q. Okay. Do you have -- in your wallet, for example, do you have a card from, from this person? A. I could look if you would like me to. Q. Yeah, that would help us, if you would, please. MR. WrITER: And, Stuart, I invite you, if you know the answers to this, I invite you to go ahead and chime in. MR. MERMELSTEIN: Well — MR. LUTTlER: I'm not looking — l'm looking to get to the answer. MR. MERMELSTEIN: I know she, she — this whose name you mentioned is in response lt.revious Interrogatory Number II. MR. LUTT/ER: And I don't think that's a 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. EFTA01076387 Page 14 Page 16 1 psychologist. 2 MR. MERMELSTEIN: That's a psychiatrist. 3 MR. LIMIER: I don't think it's a 4 psychiatrist. 5 MR. MERMELSTEIN: It's an I., right? 6 That would be a psychiatrist. 7 MR. LUTTIER: Okay. That would be, you 8 know, from the record that I'm looking at — 9 okay. We'll get to that. 10 MR. MERMELSTEIN: So, yeah, I don't know 11 if that's the psychiatrist that she's referring 12 to or not. 13 THE WITNESS: No, not on me. 14 BY MR. LUTTER: 15 Q. Okay. Do you have a cellphone that lists 16 the phone number? Do you have a phone number? 17 A. I have a cellphone. 18 Q. But do you keep her phone number in there? 19 A. Well, since my husband's in the military, I go 4 back and forth from Florida to Virginia a lot, and 21 that's why I have to change constantly 'cause if he goes 22 on deployment, I come to Florida. So that's the problem 23 right now. That's why I don't remember. 24 Q. I think you're checking your cellphone to 25 see if you have the phone number there? 1 give you the original back, and that way it 2 won't be on the record. We'll just make a copy 3 so ifs not in the court file. 4 BY MR. LUTTIER: 5 Q. Okay. All right. So, let me go back. 6 The — we were talking about the female psychologist 7 in Virginia. You don't {mow her name or number. Do 8 you recall when you first went to see this 9 psychologist? 10 A. I went with my husband. No. 11 Q. Okay. You, You recall that your first 12 visit with her was one in which your husband went 13 with you? 14 A. Yes. 15 Q. Okay. Obviously, you were in Virginia at 16 the time. Did, did you go to this psychologist 17 shortly after you moved to Virginia? What I'm 18 looking for now is maybe the year. 19 A. Let me think I don't know. I can, l can 21 approximate it I just — 21 Q. What's, what, what's your best estimate of 22 when you moved to Virginia? 23 A. When I moved to Virginia was 2006, 2007. 24 Q. Okay. And when you moved to Virginia in 25 2006, what time of the year was it? 1 2 3 4 5 6 1 9 0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ,25 Page 15 A. Yes. I have a doctor in my phone. I don't know if it's the one that I saw here, while my husband was on deployment, for my I can give you the number. Q A. Ifs Q. Do you have a name associated with it? A. No. Q. You just have a — A. I just have it under my doctor. I can get all this information from my insurance company - Q. Okay. A. or my health care. Q. Yeah. What, what insurance company is that? A a. Q. Okay. Do you have the card — A. Yes. Q. —that will give us the number? Is that the military insurance? A. Yes, Prime. MR. LIMITER: Okay. Do you have a way to make a copy? THE COURT REPORTER: Yes. MR. LUTTIER: Okay. We're, we're going to 1 2 3 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 21 21 22 23 24 25 Page 17 A. I moved there in January of, January of 2007. Q. January of 2007. A. Yes, because I got married in — yeah. Q. You got married when? A. December 2006. Q. Okay. So you know you went to Virginia shortly after your wedding? A. Yes. Q. Were you married down here min Virginia? A. Down here. Q. In Palm Beach County? A. Yes. Q. Okay. A. No, Broward County. I'm sorry. Q. Okay. All right. Approximately how long was it after you moved to Virginia that you first went to this female psychologist? A. Probably, Pm guessing, five to six months. Q. Okay. A. It's not accurate. Q. And, and why were you and your husband -- why did you and your husband go to this psychologist? A. Marital problems. Q. And specifically what were the marital 5 (Pages 14 to 1 7) PROSE COURT REPORTING AGENCY, INC. EFTA01076388 Page 18 1 problems? 2 A. Fighting. 3 Q. And how many visits did you, did either 4 you alone or you and your husband have with the 5 psychologist? 6 A. Two to three. 7 Q. And were there were those visits with 8 some degree of regularity? For example, you went 9 once a week for a month, or you went for once a 10 month for two months, or... 11 A. I think it was once a month. 12 Q. Okay. So there would be approximately a 13 three-month period- 14 A. Yes. 15 Q. — over which there would be about three 16 visits? 17 A. That's not accurate, so I'm just saying. 18 Q. If you know it's not, what's your most 19 accurate recollection of how many visits you had? 20 MR. MERMELSIEIN: Objection to form. 21 THE WITNESS: I mean we went three 22 times — I don't know. 23 BY MR. LIMIER: 24 Q. You were about to say you went three 25 times, what? Page 20 1 Q. Okay. And each of those visits was about 2 marital problems with your husband? 3 A. When he came, yes. When he was present at the 4 doctor's office with me? 5 Q. Right. 6 A. It was about us. 7 Q. Okay. How about on the — you say you 8 went one time alone. 9 A. Yes. 10 Q. What was that visit about? 11 A. Me and my personal life. 12 Q. And specifically wises about you and your 13 personal life? 14 A. Things I've been through. 15 Q. Okay. For what, what was your primers 16 complaint or purpose for you going alone on that 17 visit to the psychologist? 18 A. That I was depressed. 19 Q. So, the, the, the thing that caused you to 20 go to her alone was because you felt that you were 21 depressed? 22 A. Yeah. 23 Q. And what is it that you specifically 24 discussed with her about your personal life? 25 A. It was about my husband, it was about family, Page 19 1 A. I don't lcnow. rut not going to give an answer 2 when I'm not 100 percent sure of how many times I 3 vvent 4 Q. I want your -- 5 A. - or how many, how many — like a time frame. 6 Q. Well, I, I don't want you to just pick a 7 number out of the sky, but I want your best 8 estimate. I mean, if I had these, if I'd have had 9 this doctor's name, I would have subpoenaed the 10 records and rd know exactly, but I am trying to 11 find out who this doctor is which is why we sent the 12 interrogatories. 13 A. I'm going to say over three months. 14 Q. Okay. So your best estimate is — 15 A. My best estimate. 16 Q. 'That's fine. And on each visit that you 17 went to this psychologist, was it you and your 18 husband? 19 A. I think there was, !went one time alone. 20 Q. In addition to the three with your 21 husband? 22 A. Uh-huh. 23 Q. So you maybe had — your best estimate is 24 four visits, correct? 25 A. Three to four. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 5 16 17 18 19 21 22 23 24 25 Page 21 Jeffrey Epstein was mentioned Q. And how do you recall that Jeffrey Epstein was mentioned? A. What do you mean? Q. What is it that makes you recall that you know that Jeffrey Epstein's name was mentioned? A. Because I remember mentioning it to her, all the things I went through in my life. Q. Okay. Anything else that you recall? A. Just about my, my past — Q. All right. A. — you know. Q. And this was a 45-minute visit? A. Yeah. I'm pretty sure. Q. Did you ever go back to her after the visit that you went alone? A. I think, yeah, after I went to her alone, my husband and I went one more time after that. Q. But the visit that you and your husband had was about your marital difficulties. A. Yes. Q. And then after that last visit between you and your husband and her, you didn't go back? A. No. Q. So, somewhere in the ear 2007 tut 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. EFTA01076389 Page 22 Page 24 going to her? 2 A. Yeah. 3 Q. All right. 4 A. I would say. 5 Q. Do you recall where this doctofs office 6 was located? 7 A. No. Q. I mean, do you — I don't !mow, was it in 9 the same town that you were living in in Virginia? 10 A. No, it was a different area because I remember 11 it was a little bit of a drive. 12 Q. When you say "a different area," what city 13 was it in? 14 A. I don't remember. 15 Q. Well, how long did you live in this area 16 of Virginia? 17 A. I lived there two years, around two years. 18 Q. Okay. And I assume in that two-year 19 period you became familiar with the municipalities 20 and the cities that were located in your immediate 21 vicinity. 22 A. No. I am horrible with direction. 23 Q. Okay. Do you have, do you have any notes 24 or anything from, that your visits with this 25 psychologist 1 Q. Well, these were 45-minute sessions, 2 right? 3 A. Yeah, but I didn't know anybody in Virginia. 4 It wasn't hike I had a babysitter. 5 Q. Well, in the two years that you lived in 6 Virginia, would it be a correct statement that there 7 were times that, that you left your daughter with 8 somebody else while you did things? 9 A. No, I took my daughter. 10 Q. When you went, when you went the one time 11 to the psychologist did you take your daughter with 12 you? 13 A. Yeah, I did. 14 Q. Okay. Because your daughter at that time 15 was less than a year old, right? 16 A. Yeah, she was young. 17 Q. All right. So having your daughter didn't 18 prevent you from going to a psychologist? 19 A. No. I mean, no, but it was too hard. 20 Q. Well, you, you went the one time, you took 21 her with you. 22 A. It was still hard. 23 Q. And I assume that at age less than one she 24 slept a fair amount of time? 25 A. Uh-huh Page 23 1 A. I don't have any. Personally, I don't, I 2 didn't take any notes. 3 Q. Okay. Did the psychologist have any tasks 4 that she asked you to do? Like, sometimes a 5 psychologist will say, you know, write something out 6 or something like that. 7 A. No. 8 Q. So you have no documentary materials at 9 all concerning your visits with this psychologist? 10 A. No. 11 Q. Is there any record — other than your 12 insurance company which I assume paid for part of 13 this psychology visit. 14 A. Paid for all of it 15 Q. Paid for all of it. Is that — do you 16 have any other record from which you can determine 17 who this psychologist was? 18 A. No. 19 Q. Did the psychologist at your last meeting 20 advise that she didn't want to see you anymore and 21 that your sessions were done? 22 A. No, I just didn't go back. 23 Q. Okay. Why, why didn't you go back? 24 A. Because I have a two-year-old daughter, and 25 it's just hard for me to take the time to go. 3 4 5 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 25 1 Q. That is your daughter -- 2 A. — she did, but she also had colic, so it was not easy. Q. Okay. But you'd done it once before. The doctor, for example, didn't say, you don't come here 6 with your daughter? A. No. Q. The doctor didn't say, I don't want to see you anymore? A. No. Q. You made the decision you weren't going to go back? A. Yeah. Q. Okay. And your testimony is that in a two-year period that you lived in Virginia, you never left your daughter with anybody else? MR. ME RMELSTF_1N: Objection to form. THE WITNESS: If you mean my mother-in-law that came up and watched her from — BY MR. LUTTIER: Q. I mean anybody. A. Yeah. Q. Yeah what? A. Yes, my mother-in-law came to Virginia to stay a couple of times from Florida. 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC.. EFTA01076390 Page 26 1 Q. Okay. 2 A. So when she was there, she would watch my 3 daughter so my husband and I can go out, you know, and 4 spend some time together. 5 Q. Yeah. 6 A. But she wasn't there on the occasions of, you 7 Imow, when l had to go to a doctor session. It wasn't, 8 you know, it's not — I didn't have somebody on a 9 schedule there — 10 Q. During this — 11 A. — that could watch my daughter. 12 Q. During this two-year period that you were 13 in Virginia, was your husband living with you? 14 A. Yes. 15 Q. Were you living on a military base? 16 A. No. 17 Q. Okay. And was, was he in the military at 18 the time? 19 A. Yes. 20 Q. And did he have hours that he went to 2/ work? 22 A. Yes. 23 Q. Okay. And when would he typically work; 24 what was his schedule? 25 A. His schedule often changes since he's in the Page 28 1 Q. You said that you — I understand that you 2 went with your husband to the psychologist, but you 3 said you went to the psychologist one time alone to 4 talk about your problems. 5 A. Yes. 6 Q. There were times that your husband was 7 home from work that he could have watched your 8 daughter, and you could have gone back to the 9 psychologist, if you chose to, to discuss whatever 10 problems you wanted to discuss with her, right? 11 A. I could have. 12 Q. Okay. And the insurance company was 13 paying whatever those charges were? 14 A. Uh-hum. Yes. Sony. 15 THE COURT REPORTER: Thank you. 16 BY MR. LUTTIER: 17 Q. Let's talk now about the psychiatrist that 18 you said you saw in Virginia. 19 A. Yes. 20 Q. But first of all, let me go back and ask 21 you a question about the psychologist. How did you 22 select that female psychologist that you saw in 23 Virginia? rovides -- they accept. A. It was just offered through page 25 that, you know, p 24 Page 27 military. He can work day, night, or mid check. I don't know the exact schedule he was on at that point in 3 time, but day check is 6:00 to 2:30-3:00, depending on 4 what his boss wants to keep them. Mid-check is — mid-check is all night long. I don't know the exact 6 time, but ifs all through the entire night until 7 morning. And then the night check is --1 think it's 8 like 2:00 or 3:00 to 11:00 at night. 9 Q. Okay. So either the mid check or the 10 night check, he was home during the day? 11 A. Yeah. 12 Q. All right. So, there were times during 13 this two-year period that your husband was home and 14 available to watch your daughter? 15 A. Yeah, but I wouldn't, you know, I wanted to go 16 with my husband. 17 Q. Well, these were visits that you went to 18 the psychology — you went alone, right? 19 A. Psychiatrist or — 20 Q. Psychologist 21 A. Psychologist? 22 Q. We're still on the psychologist. 23 A. Okay. The psychologist was also for our 24 marriage, so I wanted him to go with me most of the 25 time. 1 2 3 4 6 7 9 10 11 12 13 14 15 16 17 18 119 2 21. 22 23 24 25 Page 29 Q. Okay. Okay. Now, you said you went to a female psychiatrist in Virginia as well. A Yes. Q. Was this during the same period of time that you went to the psychologist? A. That was after. That was before my husband was about to leave on his deployment. Q. Okay. A. I came — Q. When was your — A. Well, I came to Florida in January. Q. January of - A. Of last year. Q. — of '09? A. Yes. So, it was probably a couple of months before that that I went and saw her. Q. Okay. And how did you select that psychiatrist? A. The same way, off the Internet that the providers — And what city was she located in? I don't know. Do you remember where her office was? No. How many times did ou see her? Q. A. A. Q. 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. EFTA01076391 Page 30 Page 32 1 A. Twice. 2 Q. Do you, do you recall about over what 3 period of time you saw her? Like, was it two times 4 in a month? 5 A. I think it was once a month. 6 Q. And for what reason did you initially go 7 see her? A. Fa - 9 Q. And, and do you mean that when you went to 10 her you already knew that what ou wanted to do is 11 go get a prescription f 12 A. Not enact] , but something to help me 13 concentrate. 14 Q. And so, so your, as they would say, chief 15 complaint that caused you to seek out her aid was 16 you wanted something to help you with your 17 concentration? 18 A. Yes. 19 Q. Was there any other problem or, or 20 situation that you were seeking out her counsel for? 21 A. There was the second visit I mentioned that I 22 had, depression, and that's when she prescribed me 23 to try. 24 Q. How — did you have sessions with her when 25 you saw her on these two occasions, or did you 1 A. I did, but I'm not on it right now. 2 Q. Okay. When you say "right now," do you 3 mean literally like today? 4 A. As in the past, Ince, as in the past week I 5 stopped taking it. 6 Q. OW. And why did you stop taking it? 7 A. Because I'm pregnant 8 Q. Is it contraindicated; that is, did your 9 doctors tell you if you're pregnant, don't take it? 10 A. I just — I haven't seen lidgfayet, but I 11 just know ifs not good to takelMI while you're 12 pregnant. 13 Q. Well, I suppose the first thing we should 14 do is congratulate you on being pregnant 15 A. Oh, thanks. 16 Q. Is this a planned pregnancy? 17 A. Not necessarily. 18 Q. Are, are you happily pregnant? Let me ask 19 you that. 20 A. Yeah, I mean, ifs going to be hard, but — 21 two kids, young age, I mean. We'll see what happens. 22 Q. You're, you're sure you're pregnant? 23 A. I took four tests. 24 Q. Okay. Have you been to the doctor to 25 have — 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 31 simply go in and get a prescription? A. The fast time !just went in and got a 2 prescription. The second time I spoke to her about, you 3 know, depression medication. 4 Q. And, and what did you tell her about your S depression? 6 A. I just told her that I'm depressed. I'm not 7 happy. And I asked her what would be the best, you 8 know medication to try, and she told me to try 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q. This female psychiatrist Mat you saw in Virginia, was she the lust medical doctor to prescribe for you? A. Yes. Q. And was that initially prescribed at a level of a day? A. I think she started me off lower than that. Q. Okay. A. I don't, I don't recall what my — Q. Okay. A. first dosage was. Q. Have you taken Adder, continuously since the time that you saw this female psychiatrist in Virginia in 2007 right up until today? A. Q. A. Q. A. Q. A. Page 33 No, it's not — Early pregnancy? Yes. Okay. Very early. Does, does your husband know about it yet? Yes. Q. Okay. ill" So, so you have, you stopped taking last week because of your own decision that you didn't want to take that while you were pregnant? A. Yes. Q. Not because a physician said you couldn't? A. Yes. Q. All right. And did you find the was helpful to you? A. Yes. Q. It allowed you to concentrate better? A. Yes. Q. And had you had — was there a time in the past — you have a brother that, that has, has Attention Deficit Disorder? las 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. EFTA01076392 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 34 Q. And I think your brother at one time was on the medication. A. Yes. Q. And you had taken some of that — A. Yes. Q. -- when you were maybe in high school? MR. MERMELSTEIN: Make sure you let him finish his question before you answer. THE WITNESS: Oh, okay. BY MR. LUTTIER: Q. It wass like in high school you took some otitis A. Yes. Q. And you found that it was effective in terms of allowing, helping you to concentrate? A. Yes. Q. Is that how you knew that when you went to se.rthe chiatrist in Virginia that you wanted A. Yes. Q. Is there — for what riod of time did you take your brother's A. It was just for a short period of time. Q. Lfice less than a month? A. Yes. Page 36 1 alternative school. 2 Q. Okay. Typically classes here graduate in 3 June of a year. 4 A. Okay. 5 Q. So, when you say you got it late that 6 year, did you get it — 7 A. Late. 8 . Q. — within the same calendar year that you 9 would have received it had you — 10 A. I'm pretty sure it was in 2006. I was 11 supposed to graduate 2005. 12 Q. Okay. So, we know that in June if, if you 13 had stayed in school for each year and progressed by 14 passing every year, you would ordinarily have 15 graduated in June of '05? 16 A. Yes, Ida* stay back. 17 Q. No. Yeah,1tmderstand that 18 A. Okay. 19 Q. Pm just going back to your birthday. 21 That, that would mean that that would put you then 21 at 18 years of age June of '05 when you graduated? 22 A. Yes. 23 Q. So that would put you as a sophomore, 16 24 years of age? 25 A. Yes. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 3 Q. Okay. Is there — and that would have been when you were how old? A. I was in high school. Q. Freshman year? A. No. Q. Were you living in Jupiter at that time? A. No. This was probably my sophomore year. Q. Which would have made you 15 years old? A. Yeah, 15 or 16. Q. Okay. Your date of birth is =MS A. Uh-huh. Q. So do you know, do you know. in your sophomore year how old you were? A. No. Q. Okay. Let's go -- A. I was — Q. — let's go backwards. You, you got a diploina from the Palm Beach County school system. A. Yes. Q Did you get that in the same year that, that you would have graduated from -- A. No. Q. — high school class? A. I that late because I went to an 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 37 Q. Okay. So you, your best recollection is, you, you had taken your brother's sometime when you were about 16 years of age. A. Yes. Q. And then you took it for a month or two? A. For about a little less than a month. Q. Okay. Is there -- why did you not follow up, if you found it to be effective, with a physician to get a prescription of your own? A. !just didn't want to. I, I don't know why. Q. Is — do you recall what it is that caused you in 2007 when you went to sec the psychiatrist in Virginia to ask for the first time for A. I didn't ask for specs went in and asked her, yen.,w, what I, what she would, T II1 you know, refer to me. And I mentioned a couple of pills, but the reason is because I was going back to school. Q. Okay. And, and you had arrived at the decision at that point you thought some kind of medication would assist you in being able to concentrate better? A. Yes. In school, yes. Q. 10 (Pages 34 to 37) PROSE COURT REPORTING AGENCY, INC. EFTA01076393 Page 38 Page • 1 A. Yes. 2 Q What doctor diagnosed you? 3 A. I don't blow. I don't recall. Q. What — where was A. I changed doctors. Q. Do you recall about how old you were when the doctor diagnosed you? o A. Yes. When I first started seeing the 9 psychiatrist in Virginia 10 Q. Okay. What doctor? Was it the, the 11 psychologist that you were seeing in Virginia that 12 you went to with ur husband that diagnosed you as, 13 as — 14 A. The psychiatrist. 15 Q The psychiatrist, the same one that 16 d — the same one that prescribed the 17 to ou made a formal diagnosis that 19 20 21 22 23 24 25 A. She didn't tell me that, but don't they have to do that themselves to give you the medication? Q I don'tlatow. Pills and doctors these days, I don't — A. I mean, I would hope so. I wouldn't want to — Q Do, do you have a recollection that some 1 physician that you saw in Florida? 2 A. I saw a male. 3 Q. And this is a medical doctor? 4 A. Yes. 5 Q What kind of practice was he in? 6 A. I don't know. 7 Q. Where was his office located? 8 A. Delray. 9 Q. And, and how did you come to go to this 10 particular physician? 11 A. The same way, with the 12 computer. 13 Q. And what kind of doctor was it? 14 A. Psychiatrist. 15 Q Do you recall approximately how long you 16 were in Florida before you went to him? 17 A. It was when my last dosage ran out from the 18 previous doctor in Virginia 19 Q Okay. So, you went to this psychiatrist 20 because you needed to have a medical doctor in order 21 to prescribe for you again? 22 A. No. I was in Virginia. 23 Q. Right. 24 A. I SOW the doctor in Virginia to get my 25 started. on the 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 39 physician formally diagnosed — A. One, one of them, yes. I don't -- specifically her, l don't remember if she said yes or no that I have it, but one of the doctors in Florida that I did see gave me a test to see if l was. Q. That would be a doctor that you saw in Florida after coming back from Virginia? A. Yes. Q. Okay. You said that in a recent visit to this Florida ician, that you had gone to to get more A. Uh-huh. Q Is that right? Okay. A. Yes. Q. When did you visit the Florida physician to Rea A. I don't recall. Q. Okay. It would have been -- this visit to the Florida physician would have been after you returned to Florida from Virginia? A. Yes. Q. And that, I think you told me was, you came to Florida in January of '09. A. Yes. Q. Okay. And was this a male or female 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 vas.. Page Q. Right. A. I came to Florida. I finished my dosage and then I went to a psychiatrist. 'didn't need a referral to see a psychiatrist in Florida. Q But you went to the psychiatrist in Florida so that you could get your prescription renewed? A. Yes. Q. Okay. How many visits did you have with this psychiatrist in Florida? A. Approximating, two or three. Q. And were these visits solely for purposes of getting your prescription? A. Yes. Q. And how long I mean, were these like five-minute visits? A. Yeah. It was a script. Q. You literally would just walk in and get the script? A. I'd walk in, see him, and get the script. Q. Okay. Did you have any counseling with him, or did he give you any treatment or just give you a prescription? A. No, he would just gave me a prescription. Q. Did you give him any history? That is did 11 (Pages 38 to 41) PROSE COURT REPORTING AGENCY, INC. EFTA01076394 Page 42 1 you sit down and tell him about your life or 2 anything like that? ' 3 A. No. 4 Qiasther than giving you a prescription 5 for a he didn't render any treatment to you? 6 A. No. 7 Q..2:abf the last physician that renewed 8 your arescription? 9 A. No. 10 Q. Okay. 11 A. The last doctor? 12 Q. Yeah 13 A. No. 14 Q. Who was the last doctor -- well, let me, 15 let me back it up. 16 You went two to three times to this 17 Florida psychiatrist who ou don't recall for 18 purposes of having your prescription 19 renewed, right? 20 A. Uh-huh. Yes. 21 Q. Did there come a time that you didn't go 22 back to him? 23 A. Yes, I didn't go back to him. 24 Q. Okay. And why didn't you go back to him? 25 A. Because he was in Delray. 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 44 Palm Beach, right? A. Yeah. Q. Is it like one of the complexes at Victor Farris? Is it over by Columbia Hospital or... A. Ifs off of Indiantown. Q. Indiantown Road up in — A. Yeah. Q. — up in Jupiter? A. No, ifs not. It's not what it is. It's... Q. What's not? What, ifs not off of Indiantown Road? A. No, it's -- no. I'm, I'm trying to think of the road. Next to Okeechobee. Ifs one of the exits before Okeechobee. Q. Exit off 1-95? A. Yes. Q. Palm Beach Lakes? A. No. Q. North or south of Okeechobee? A. I think ifs south of Okeechobee. Q. Belvedere? A. No. Q. Southern? A. No. Maybe it's north. I'm not good with directions. Page 43 1 Q. So, did you — 2 A. I changed it to West Palm Beach. 3 Q. Okay. Who did you go to in West Palm 4 Beach? 5 A. I think that's the one that I gave you the 6 number. I don't recall her name either. 7 Q. Okay. So you went to a you switched to .8 a female physician in West Palm Beach? 9 A. Yes. 10 Q. And is that female a psychiatrist? 11 A.. I know she prescribes medication, but I don't 12 know if she was the actual psychiatrist of the office. 13 I don't know how that works. 14 Q. Okay. Well, any, any medical doctor can 15 prescribe, so she could be an internal medicine 16 doctor for all you know. 17 A. Yeah, 'don't, l don't know. 18 Q. Was she in a group? 19 A. What do you mean? 20 Q. A group, she — was it a group practice or 21 just one doctor? 22 A. No, it was a group practice. 23 Q. Okay. Where was her office located? 24 A. West Palm Beach. I don't know. 25 Q. Okay. Well, you're familiar with West 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 45 Q. Okay. Well, north is behind you; south is — A. I don't know. Q. -- the other way. A. I don't know. Q. So, as you sit here today — A. Yeah. Q. — point which way you would go to get to this office. A. I was going towards Okeechobee from Wellington. Q. Okay. A. So north. Q. So, you had — all right. So, all you — this phone number that you have in your phone you think is this doctor? A. Yes. Q. ' Okay. So you -- how long -- how many — when did you first go to her? A. I don't !mow the date. Q. Approximately when, in the last six months? A. Yes. Q. And how many times have you gone? A. Two to three. 010•111001WSIISSISIMAllitat 12 (Pages 42 to 45) PROSE COURT REPORTING AGENCY, INC. EFTA01076395 Page 46 1 Q. And on each visit was it just to get the 2 prescription renewed? 3 A. Yes. 4 Q. Did she ever render any treatment to you? 5 A. No. 6 Q. Did you ever give her any history or sit 7 down and talk about any of your, your issues? 8 A. No. I did see a psychologist for that when I 9 was in Florida also, and I don't know the time frame. 10 Q Are you talking — okay, now you're -- 11 now, the psychologist that you saw in Florida for 12 that is that yes another doctor whose name is not on 13 these answers to interrogatories? 14 A. Yes. These answers, this was a while when I 15 was in Virginia when I did these, correct? 16 MR. MERMELSTEIN: Yes. 17 THE WITNESS: That's why they're not on 18 there. 19 MR. LUITIER: Duly disclosed. 20 BY MR LU'TTIER: 21 Q. When was the last time you saw this female 22 psychiatrist in, in West Palm Beach? 23 A. The psychiatrist that prescribed medication? 24 Q. Yes. 25 A. It was after the male, before I went to Page 48 1 estimate then that you must have seen this physician 2 within the last two months? 3 A. Yes. It was just, I don't take my 4 every day. 5 Q. And what does the prescription advise you 6 to do in terms of the frequency with which you're 7 take the 8 A. Take it every day. 9 Q. So, why don't you take it every day? 10 A. Because it makes you very hyper and 11 concentrate and stay up all night, so I didn't feel like 12 doing that every day. 13 Q. And have you advised the doctors that you 14 were having that side effect? 15 A. Yes, that's one of the side effects. 16 Q. Do you know whether or not this female 17 psychiatrist in Florida ever made a formal diagnosis 18 of you? 19 A. No. 20 Q. How about the male doctor in Delray, do 21 you know if he made a fonnal diagnosis? 22 A. Yes. 23 Q. You know he did? 24 A. Yes. 25 Q. Okay. And what was his diagnosis? Page 47 1 Virginia. I don't have an exact date and time. 2 Q. Well, was it within the last month? 3 A. No. 4 Q. Last two months? 5 A. The last three to four months, maybe. Two 6 to I'm, I'm not sure. 7 Was she the last physician to prescribe 8 for you? 9 A. Yes. 10 Q. And, and you had, you still have your last 11 prescription, right? 12 A. Pm not taking it anymore. 13 Q. I know you're not taking it, but you still 14 have the pills. 15 A. Yes, in Virginia. 16 Q. Well, you justsp hen did you say you 17 just quit talcing those last week? 18 A. Like five, yeah, five days ago. 19 Q. Okay. But the point is the prescription, 20 you had not run out of the latest prescription? 21 A. No. 22 Q. Okay. And so for what period of time do 23 you get a prescription; a month, two months? 24. A. No, it's about a month. 25 222ka. So would x a correct 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 21 21 22 23 24 Q. When was the last time you saw the 2 5 psychologist in Florida? Fay: A. That I have Q. And how do you know he made the formal diagnosis? A. Because he gave me a test and I asked him what it was for and he told me that it was for to see if I had Q. Did the female doctor in West Palm Beach that you most recently went to to renew your prescription give you a test? A. No, not that I recall. Q. Did the psychologist that you saw in Virginia give you any kind of test? A. Not that I remember. I don't know. Q. Did the psychiatrist that you saw in Virginia give you any kind of test? A. Not that — I don't remember. Q. Now, you, you mentioned when we were speaking about the psychiatrist in West Palm Beach that you, you have seen a psychologist in Florida? A. Yes. Q. And, and who what psychologist did you see? A. I don't remember their 13 (Pages 46 to 49) PROSE COURT REPORTING AGENCY, INC. EFTA01076396 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 50 A. That was when I first got to Florida Well... Q. That would be January of '09? A. Give me a second. Q. Sure. A. It was probably around March or April. I'm, you know, Pm guessing. Q. March or April of '09? A. Yes. Q. And was this doctor male or female? A. He was a male. Q. And I assume he probably still is a male but — A. Yeah. Q. Where was his office located? A. It was in Wellington next to Greenview Shores. Q. In the Greenview Shores strip center or shopping center? A. I'm pretty sure, yes. Q. And how did you find this psychologist? A. Actually, my mother-in-law. My husband went to a doctor that was really good for him when he was younger, and she tried to get me to see the same doctor he went to. She didn't acce him, and he accepted Q. Okay. First, what's your other-in-law's so she referred 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 52 Q. What kind of physician was that? A. Psychologist. Otkticl you said she, I assume you meant Ms. =, tried to get you an appointment with this psychologist that had seen her son when he was young? A. Yes. Q. But you don't know that psychologist's name? A. Nope. Q. AM did you ever contact that psychologist? A. Yes. Q. So you placed a phone call, or did you go see this psychologist? A. 1 placed a phone call and I saw hint Q. Okay. You did both? A. Yes. Q. All right. So there, tits another physician. And where was this, the psychologist who your mother-in-law initially suggested you go see who had seen your husband as a youth, where was his office located? A. That was the one I just gave you in Green, at the Greenview Shores. 1 2 3 4 6 5 9 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 C25Page 51 name? A. (phonetic). Q. How wotldou spell that? A. -M you could put. and I don't know how to s II her entire — • =, • A. Yes. Q. And, and is that your husband's mother? A. Yes. Q. Okay. She lives where? A. In the Isles of Wellington. Q. And is that the name that she goes by now? A. Yes, M. Q. Is she married now? A. Yes. Q. And her husband's last name is =11 A. Yes. Q. And do you know his first name? A. Mervin. Okay. So your husband at some time in the Q. past had seen a physician who he felt did a good job for him? A. Yes. Q. Do you know that physician's name? A. No. Vt 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 53 Q. Oh, I, I thought you had said, correct me if I'm wrong, but I thought you said your mother-in-law had wanted to get you in to see a psychologist that your husband had gone to in the but that that psychologist wouldn't take • A. Yes. Q. So, that psychologist recommended another psychologist A Which is hint. Q. The one that you, that, that — when you say this is him, the "him" that you're talking about is this psychologist that you saw in Greenville shops? A. Yes. Q. All right. But that's not the psychologist that saw your husband when he was younger? A. No, because they didn't accept Q. What I wanted to know was, did you have a conversation with the psychologist that saw your husband when he was younger? A. No. • Q. You had no contact with him? A. No, my mother-in-law did. 14 (Pages 50 to 53) PROSE COURT REPORTING AGENCY, INC. EFTA01076397 Page 54 1 Q. Andshetoldyouthat- 2 A. She gave me -- 3 Q. — as a result of her conversatliiiii 4 that psychologist they wouldn't take 5 A. Yes. Q. And then she provided the name to you to go see this psychologist whose name you don't recall :3 in your Greenville shops? 9 A. Yes. 10 Q. Okay. Did you ask your mother-in-law to 11 fmd a psychologist for you in, somewhere around 12 March or April of '097 13 A. I mentioned it to her, yes. 14 Q. And how did that come up? 15 A. I was just, Pm very depressed, and she just 16 mentioned somebody that her son saw that was very good. 17 Q. And was that for depression? 18 A. Yes. Forme? 19 Q. Yeah. 20 A. Yes. 21 Q. Okay. And, and how many times have you 22 been to this psychologist near Greenville shops? 23 A. Four to five times. 24 Q. And do you go for 45-minute sessions? 25 A. I believe so, yes. Page 56 1 A. I just told him that I was very depressed and 2 I don't feel happy. 3 Q. And what did you tell him you believe was 4 the cause of your depression? 5 A. My past, things live gone through. 6 Q. Did — specifically, what did you tell 7 him? 8 A. Me, rve told him about me and my husband. I 9 told him about the situation with Epstein. I told him 10 about my parents, my childhood. 11 Q. What is it you told him about your parents 12 and your childhood? 13 A. We didn't get along sometimes. 14 Q. Now, when, when you're referring to your 15 porous, who are you referring to? 16 A. Well, my mother and my stepfather, and my 17 father and his girlfriend at that time. 18 Q. And, and when you say, "your mother," 19 you're talking about your birth mother? 20 A. Yes. 21 22 A. 23 Q. And where does she now live? 24 A. Boca Raton. 25 Q. And your stepfather is whom that you Page 55 1 Q. And did you go once a month, or with what 2 degree of frequency did you go? 3 A. hives once every two weeks. 4 Q. So, if you went four to five times, you 5 went for a total of about two months? 6 A. Yeah. 7 Q. So, that's going to take us until sometime B around June of '09? 9 A. Yes. 10 Q. And what was the purpose of you going to 11 that psychologist? Was each visit designed to 12 address your depression? 13 A. Yes. 14 Q. Did the psychologist take notes? 15 A. Yes. 16 Q. Did the psychologist make any formal 17 diagnosis? 18 A. No. 19 Q. Did that psychologist have any work that 20 he had you do where you had to write things out? 21 A. No. 22 Q. Did he do any testing? 23 A. No. 24 Q. And what did you tell this psychologist 25 about cur depression? 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 57 referred.lp? A. ar Same last name. Q. And does he still live with your mom in Boca? A. Yes. Q. Okay. And your — when you refer to your father, are you talking about your birth father? A. Yes. Q. awavhat is his name? A. OM Doe No. 5. Q. And where does he live? A. He lives in Wellington. Q. And you referred to his girlfriend? A. This girlfriend that he has now is not the one that he had in the past that I had problems with. Q. Who was the girlfriend you were referring to? A. (phonetic). Q. And was she living with your dad at some point in time when you were having problems with her? A. Yes. Q. Do you need to take a break? A. Yes. MR. LIMIER: Yeah. if !; 15 (Pages 54 to 5 7) PROSE COURT REPORTING AGENCY, INC. EFTA01076398 Page 58 Page 60 1 break, just tell me. It appeared to me that 2 you were in some kind of distress. 3 THE WITNESS: No, !just -- 4 MR. LOTTER: You don't have to wait If 5 you want a break, just say. This is no — this 6 isn't, you