UNITED STATES DISTRICT COURT

Page 332 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 III OF III 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. 6 Tuesday, April 6, 2010 10:11 - 12:13 250 Australian Avenue Suite 150 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1577 • PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hooking (801.061.978.2934) Electronically signed by cynthia hopkins (601-051-978.2934) Electronically signed by Cynthia hopkins (601-051.978.2934) 77a4b141-af9a-4001.9083.8116a007a087 EFTA01076765 EFTA01076766 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 333 1 APPEARANCES: 2 On behalf of the Plaintiff 3 ADAM D. HOROWITZ, ESQ MERMELSTEIN & HOROWITZ7,11. 4 18205 Biscayne Boulevard Suite 2218 5 Mama Phone: 5 7 On behalf of ROBERT l). CROTON, Et, ESQUIRE BURMAN, CRITTON, LUTIliR. & COLEMAN. LIP 9 303 Banyan Boulevard Suite 400 West P rida 33401 Phone: ALSO PRESENT: Daniel Downey, Videographer Visual Evidence, Incorporated Page 335 1 CONTINUED PROCEEDINGS 2 3 THE VIDFDGRAPHER: This is the 6th day of 4 April,210. The time Is approximately 5 10:11 M. This is the videotape deposition of 6 Jane Doe No. 6 in the matter of Jane Doe versus 7 Jeffrey Epstein. 8 This deposition is being held at 250 South 9 Australian Avenue, West Palm Beach, Florida 10 My name is Daniel Downey. I'm the videographer 11 representing Visual Evidence, Incorporated. 12 Will the attorneys please announce their 13 appearances for the record. 14 MR. HOROWITZ: Sure. My name Adam 15 Horowitz,. I'm counsel for Plaintiff, Jane Doe 16 No. 6. 17 MR. CRITTON: Bob Critton on behalf of 18 Mr. Epstein. 19 Thereupon, 20 (JANE DOE NO. 6), 21 Having been first duly sworn or affirmed, was 22 examined and testified as follows: 23 THE WITNESS: Yes. 24 DIRECT EXAMINATION 25 2 3 4 5 6 / a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 334 INDEX EXAMINATION DIRECT CROSS REDIRECT Continued JANE DOE NO. 6 BY MR. CRITTON 335 EXHIBITS EXHIBIT DESCRIPTION PAGE DEFENDANTS NO. 4 November 29, 2006 Letter 396 Page 3 1 BY MR. CRITTON: 2 Q. Ms. Doe No. 6, we're going to finish your 3 deposition today. You understand that? 4 A. Yes. 5 Q. All right. Since you were here on 6 February 17th of 2010 are ou currently still 7 employed by 8 A. No. 9 Q. All right. You — when you carne here or 10 when you were here on February 17th. In fact, I 11 think you were going to work when you left. 12 A. Yes. 13 Q. Correct? 14 A. Yes. 15 Q. And I think it was, was it your cousin who 16 was the supervisor there? 17 A. Manager. 18 Q. She was the manager? 19 A. Assistant manager. 20 Q. So, you stopped working, it looks like 21 answers to your interrogatories, you stopped working 22 sometime in March. When? 23 • A. March 12th. 24 Q. All right. Which would have been about a 25 month aSfter our deposition, correct? 2 (Pages 333 to 336) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801.061.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Bactronically signed by cynthla Winkles (601.061.976.2934) 77a4b(41.afga.40e1-9063-81f5e007a067 EFTA01076767 Page 337 Page 339 A. Yes. 2 Q. Okay. And why did you stop working there? 3 A. I got fund. 4 Q. Why did they lire you? 5 MR. HOROWITZ: Form. 6 THE WITNESS: Because I didn't come into work. q BY MR. CRITTON: 9 Q. Ts that what they told you? 10 A. No. Yeah, well, it's because I didn't come 13. in. 12 13 14 15 16 17 18 ell the last name, please. 19 A. 20 Q. Oh, 21 A. Yes. 22 Q. How long had you known Mr. 23 A. Since I was ten or I I • 24 Q. And he was a very close friend of yours? 25 A. Family friend, yes. 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. Okay. And why did you not go into work that day? A. Because one of my good friends was murdered early that morning. Q. What was his or her name? A. A. Q. A. Q. Q. Is she one of your good friends? A. Yes, sheSnbest friend, Q. Okay. , A. Yes, sir. Q. And A. Q. A. A. And how was he murdered? He was shot in his house. And how did you hear about it? My friend Julie called me. What is Julie's name, last name? Yeah. I don't know how to spell it. And did she know as well? Yes. How — he was shot where? In the chest Page 338 Q. And was it, it was a — someone came into his house and shot him theft? A. Yeah. They, well, they tried to come inside.. He struggled with them, wouldn't let them in the door because his daughter and his fiancee were in the house. Q. .Okay. Was, was he selling drugs or something? Was this drug related? MR. HOROWITZ: Form. THE WITNESS: Yes. They were trziro (561) 832-75G0 1 rob him. 2 BY MR. CRITTON: 3 Q. And was he a chug dealer? 4 MR. HOROWITZ: Form. 5 THE WITNESS: I didn't know. They were 6 trying to rob him. That's what the cop said. 7 They didn't get into the house so I don't 8 BY MR. CRITION: 9 Q. tladaknow to be a drug dealer? 10 A. mother is the landlord or the, she 11 works at the office and that's how me, me and him met 12 during. 13 MR. HOROWITZ: He is asking if you knew -- 14 MR. CRITTON: I heard — 15 MR- HOROWITZ: - if you him to be a drug 16 dealer. 17 THE WITNESS: No, I didn't, I didn't know. 18 MR- CRITTON: I don't need help but that's 19 fine. 20 MR. HOROWITZ: Form. 21 THE WITNESS: I didn't know. 22 BY MR. CRITTON: 23 Q. Had you ever done drugs with M? 24 A. No. 25 Q. Are you sure? Page 340 1 A Yeah. 2 Q. So, he was shot and killed that day? 3 A. Yeah. 4 Q. And you heard about it. What time were 5 you supposed to be at work? 6 A. I was supposed to be at my meeting at 12. It 7 happened around like 9 or 10. 8 Q. In the morning? 9 A. Yes. 10 Q. On the 12th? 11 A. Yes. 12 Q. Okay. Did you call your cousin and tell 13 her? 14 A. Yeah. Well, I went to the, I was supposed to 15 go to the meeting. I went and I was crying, and they 16 told me to go home. And I was supposed to go back to 17 work at 5. 18 Q. And did you go back at 5? 19 A. No. 20 Q. Why not? 21 A. Because I called my manager. She was in 22 Chicago, so I had to call my cousin which is the 23 assistant manager. And she couldn't find nobody to 24 cover forme, so... 25 Q. Cover for you when? 3 (Pages 337 to 340) PROSE COURT REPORTING AGENCY,.. INC. C ) 832-7506 Electronically signed by eynthia hopkins (601451476-2934) Electronically signed by cynthia hopkins (601-051476-2934) Electronically signed by cynthla hopkins (601-051.976.2934) 77a4b141-af9a-40o1-9063-81f6a0072067 EFTA01076768 Page 341 1 A. For that night, 2 • Q why? 3 A. I was supposed to work 4 Q. You didn't go in on Friday, the afternoon 5 either? 6 A. No,1— my, the owner, because he 015113, 7 privately owned, he told me to go home for the meeting 8 because i was supposed to be there at 12. 9 Q. And he told you to come back at 5? 10 A. He didn't tell me to come back. 1 was 11 supposed to come back during'my shift. it was already 12 on the schedule. 13 Q. Okay. So, did you go back at 5? 14 A. No. 15 Q. Why not? 16 A. Because I couldn't go back to work. 17 Q. Why not? 18 A. Because I couldn't be sitting at 19 thinking what happened in my head. 20 Q. Did call your — anyone and tell inc them 21 that you couldn't come in bersice you were still so 22 upset? 23 A. Yeah, yeah. 24 Q. And that was your cousin? 25 A. Yeah. No, I called my manager, the manager in 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 343 soon after you were fired from did you get another job? It looks like at A. Well, I started working last Saturday but I got the job the Thursday before that. So, like two . weeks, ten days maybe. Q. All right. And have, have you been working there now? A. Yeah. Q. And is it a 40-hour-a-week job? A. Right now I am only part-lime because i am still training they say, but I have been working eight-hour days. Q. Do you get any benefits with Elt A. No. Q. If you start working there as a MI-time employee, will you get benefits? A. No. Q. Just the $7.50 an hour? A. Yes. Q. Are you doing any other employment at the current time? A. No. Q. Okay. And your boyfriend. he is still working I think heavy machinery or I Page 342 1. the morning, or, well, at 12, and she was in Chicago. ii.2 So, ' cl she %mita do anything 1 would have to 3 call And = said she couldn't find anybody 4 which is my cousin. 5 Q. To replace you at 5? 6 A. Yeah. 7 Q. And then you just decided that you 8 couldn't go in — 9 A. She — 10' Q. — because you were so upset? 11 A. Yes. 12 Q. .And then did then say you've been 13 fired? • 14 A. No. My manager called me back and told me 15 that ifs not my immediate family, and that 1 have to 16 go; if not, she's going to have to fire me, so... 17 Q. And you said — ' 18 A. Yeah. . 19 Q. — go ahead and fire me? 20 A. (Witness nods head). 21. Q: Yes? 22 A. Yes. . 23 Q. Affright. And it appears that you then 24 got another job? 25 A. Yes. 1 2 3 4 5 7 Page 344 something? A. No, he got fired. He got laid off, as a matter of fact, a little before my son's birthday. Q. Your son's birthday was when? A. Yes. 8 MR. CRITFON: Correct. 9 MR. HOROWITZ: Of this year. 10 THE WITNESS: That's when he turned two. 11 BY MR. CRTTTON: 12 Q. And what happened, he just, they just said 13 we don't need you any more; you're getting laid off? 14 A. No. Their whole crew got laid off. 15. Q. What's he been doing? Does he get 16 unemployment? 17 A. Well, he is trying to. They are waiting. 18 Q. Is there a wait period or something? 19 A. No. I think the company is fighting for it 20 or — 21 Q. You still get insurance benefits for the 22 child though under- 23 A. No. He got it through the job, I have to — 24' Q. No, no. That's what I meant, he, he, 25 your, Aaro23sets insurance coverage trout: 4 (Pages 341 to 344) PROSE COURT REPORTING. . GENCYf INC: Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthia hopkins (601.061-976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) 77a4bf41.of9a40e1 -9063.81f 5a007a067 EFTA01076769 1 2 3 4 5 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 345 child — MR. HOROWITZ: Form. BY MR. CRITTON: Q. - stilt rigid? THE WITNESS: What do you mean insurance coverage? BY MR. CRITTON: Q. You testified at your last de tadjap that, that he had insurance benefits, l=? A. He has health. Q. Health insurance benefits which were applicable to your son. A. Through the job. Q. Right. So, he still has those? • A. I don't think so since he got laid off. Q. How big, how big a business is it? A. It's -- I don't know. Q. Two people? A. I just know he works there. Q. Is it 20 or 30 people, do you think? A. I don't know. I know he works there on a crew with a couple of people. Q. Tell, tell him about Cobra because under the federal law he is entitled and the employer has to pay it so... Page 347 1 current time relating to Mr. Epstein or any other 2 emotional condition that you have? 3 A. No. 4 Q. You and 5 yes or no? ' 6 A. Yeah. 7 Q. Any plans yet? 8 A. No. 9 Q. Since your deposition have ou seen or 10 spoken with either Jane Doe or M.? 11 A. Isete funeral. 12 Q Of 13 A. Yes. 14 Q. Okay. Was it a pretty sad funeral? 15 A. Yeah. 16 Q. And did you feel -- I mean, apparently it 17 affected you enough that you didn't want to go to 18 work? 19 A. Yeah. 20 Q. Does it still affect you now? 21 A. Yeah. I think about him a lot. 22 Q. RAW'S la' you hadstbajgdividuals, you had 23 a former boyfriend, Mr. who shot himself, 24 correct? 25 A. Yes, but that's different. talk anymore about marriage, Page 346 1 A. He was -- 2 Q. He's not, he is not getting it? 3 A. He was paying his health benefits out of his 4 check, so... 5 Q. So, the company didn't pay it? 6 A. He was paying co-fees for it, so I don't — 7 co-pay, 1 don't think. 8 Q. Tell him to still check. Have you seen, 9 since your deposition on Felnuaty 17th, 2010, have 10 you seen any psychologist or psychiatrist, mental 11 health counselors for any reasons relating to 12 Epstein or any other psychiatric or psychological 13 issues? 14 A. Since the last time I seen you? 15 Q. Yes, ma'am. 16 A. No. 17 Q. Have you seen any physicians for any 18 reason? 19 A. No. 20 Q. Medical doctors, medical, been to an 21. emergency room for any reason? 22 A. No, no. 23 Q. And you have no — do you have any 24 appointments to see a psychologist or psychiatrist 25 or a mental health counselor for any reasons at the 1 2 3. 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 348 Q. And how is that different? A. Because someone took from his two-year-old daughter. She was right behind him when he was shot. They took him from her. Q. Okay. And how does that make you feel? A. It's wrong. Q. Of course it's wrong, but how does it make you feel? A. That just -- I don't know, just I could lose, you know, my family or anybody quick. It just didn't -- it doesn't feel real. Q. Okay. And, and because the sante thing could happen with you or it could happen with A. It could happen to anybody. They, they didn't even, supposedly they didn't even know him. That's what the cops say. They didn't even know him that they just heard that he was doing something and went and knocked on the door. Q. You said "they, they heard- that he was doing something; the people who shot him? A. Yes. Q. What did they hear? What did the cops say? A. The cop said that they heard that he was, had PROSE COURT REPORTING 5 (Pages 345 to 348) AGENCY, INC. (MI) Electronically signed by cynthia bodkins (601.051.970-2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) 77•4t441419•40040634115s007•067 EFTA01076770 Page 349 I money or he was dealing drugs. I don't know. 2 Q. So, that's why they purportedly broke into 3 the house? 4 A. They didn't break in. They tried. 5 Q. Oh, and they just then shot through the 6 door? 7 A. He was standing at the door fighting with them 8 because they were trying to get into the house. 9 Q. Oh, was he actually outside of the house? 10 A. He was — he answered the door because they 11 knocked and they had a gun and tried to get into the 12 house, and his daughter was behind him. 13 Q. Did go with you to the funeral? 14 A. Yes. 15 Q. And you saw Jane Doe there. Did you talk 16 to Jane Doe at all? 17 A. No. 18 Q. You just saw her there? 19 A. Yeah. 20 Q. How about have you, have you spoken with 21 her separate and apart from seeing her at the 22 funeral? 23 A. No. 24 Q. Have you talked to M. at all? 25 A. No. Page 351 2 might die, the events with 1 you were in the car accident and thou t she they 3 are all-- 4 A. 5 Q. I am sorry, 6 a significance impact on you? 7 MR. HOROWITZ: Form. 8 BY.MR. CRITTON: • 9 Q. Is that true? 10 A. I mean he just died like two weeks ago. 11 That's why it has an impact on me. It is still fresh. 13 surrounding having committed suicide Q. Are y • that the events 12 14 so close, so close to you, no longer has an effect 15 on you? 16 A. I didn't say that. I'm just, you blow, I mean 17 it's different when somebody steals their own life, and 18 when someone gets their life stolen from them. It's way 19 different. 20 Q. You mean a suicide versus -- • 21 A. Yeah. 22 Q. — versus a random murder? 23 A. It's way different, yes. 24 Q. Which do you consider more, lice, 25 traumatic from your perspective? — all seem to Page 350 1 Q. Did you -- the ex with or what you 2 have at least seen with MI pretty 3 traumatic for you? 4 A. Yeah. It just hurts you know. It's wrong. 5 Q. Had, had any nightmares about it or — 6 A. No. 7 Q. Had any trouble sleeping? 8 A. No. I just think about him, you know, when 9 Fm in my neighborhood or go by his house or something. 10 Q. Did you know his parents? 11 A. Yeah. 12 Q. Okay. And did you go back to the house 13 for the reception 14 A. Yeah, yeah, I've been at — 15 Q. Or like the wake afterwards? 16 A. I have been at her house for like 10 days now. 17 Q. Everyday? 18 A. Yeah. 19 Q. Okay. And how is the mother doing? 20 A. She's actually keeping everybody together. 21 Q. Does he have other brothers and sisters? 22 A. Yeah. 23 Q. From listening to your testimony on 24 tua, 17th N s. Doe, events like what happened to 25 what happened with your mother when (M) 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 352 MR. HOROWITZ: Form. THE WITNESS: It's all pretty traum — sad, you know, that this had to happen to good people but it's what happens. BY MR. CRITTON: Q. The incident with your mother when you were in the automobile accident back in 2004, does that still bother you as well? Well, let me strike that The accident had an impact on you at the time certainly, correct? A. Uh-huh. Q. And you found that very traumatic at the time? A. Yes. Q. Okay. Had trouble sleeping, thought your mother might di; thought she could be taken from you as well? A. Yeah. Q. Okay. And that's part of the same issue you have about driving or certainly driving on 1-95 or an interstate or a toll road, correct? A. Yeah. Q. Tell me what a typical day is for you now? What do you do, excuse me, on a typical day? A. Go to work. 6 (Pages 349 to 352) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkine (601.051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkine (601.051-976-2934) 77a4b141-af9a-40o1.9063-81f5aa007a067 EFTA01076771 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Q. In Lake Worth? 24 A. Greenacres. gumennon2.... All let. And then does, does the son 25 7 (Pages 353 to 356) 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 353 And do you have a regular, excuse me, at do you have a regular shift? A. Yeah. Igo in at 8. Q. Until when? A. Well, I can leave from 2 to 4. Depends how busy we are. Q. All right. Is it your choice or the managers? A. Well, I can — like I said it depends how busy we are. Q. So, if it's not busy, you can say I ern leaving? A. Yeah. Q. And if it's busy, then they expect you to say? A. Yes. Q. Okay. Which do you work at? Where is the location? A. Lake Worth and log. Q. All right. So, when you're not working, so you get up, you get up in the morning and take care of your baby? A. Yeah, well, I bring him to my mom's so I can get ready to work because I have, I wake up at 7 and be at work by 8. Page 1 stay with her the whole day? 2 A. Yeah, until I get off. 3 Q. And then you go and pick him up? 4 A.. Yeah. 5 Q. And when you go pick him up, then you go 6 home? 7 A. Yeah. 8 Q. Okay. And then what do you do? 9 A. Make dinner. 10 Q. All right. And what, watch TV? 11 A. Yeah. We hang out. He usually watches Elmo 12 'till - 13 Q. Your son? 14 A. Yeah. 15. Q. All right. And you hang out until you go 16 to bed around what time? 17 A. He goes to sleep at like 8. And then well 18 watch some TV and :4) to sleep. 19 Q. Okay. and you are still living 20 together? 21 A. Yeah 22 Q. Okay. What's doing now since he got 23 laid off? 24 A. Fixing our house. 25 Q. lie Is working around the house? Page 354 Q. Do you feed, feed your son, isn't it? 2 A. Yeah. Well, he is just now getting — when I 3 bring him over there, he is just getting up. So he is 4 going to take -- 5 g Does your morn then feed him? A. Yes. Q. Does she work at 7? A. Yes. Q. Is she, what — who does she work for again? A. AAffordable Insurance. Q. Okay. And when she goes to work, does she work out of the home? A. No. Q. And who takes care of your son when — A. She drops him off at my aunt's house. Q. And her name is? A. Q. Can ou s it for me? A. Q. Where does she live? A. Page 356 1 A. Uh-huh. 2 Q. Yes? 3 A. Yes. 4 Q. Is he looking for other work as well? 5 A. Well, yeah, in between trying to deal with his 6 unemployment. 7 g Okay. So, he is trying to get his 8 unemployment benefits, correct? 9 . .A. Yes. 10 Q. And then working on the house? 11 A. Yes. 12 Q. Has he applied for any other jobs? 13 A. 1 think he went to some interviews, yeah, like 14 the USD Meat. 15 g I'm sorry? 16 A. The Direct Meat or whatever, the USD Meat or 17 something. 18 Q. All right. 19 A. And some other place on Lake Worth. I didn't 20 go. 21 Q. But nobody has at least hired him as of 22 todays date? 23 A. No. 24 Q. Okay. In your answers to the second interrogatories it appears you have a, you have a PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051.976-2934) 77s4b141.09a-40e1-9063-81t5a007a067 EFTA01076772 Page 3,57 Page 359 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MySpace since 2008? A. Yeah. Q. Okay. Do you use it on a regular basis? A. Yeah. Q. And you, you have a Facebook page, but what you haven't activated it yet? A. No. Q. You haven't punched in the profile? A. Yeah. I haven't I think I signed up for it but I never went on it. I don't know how to use it. Q. And you actively use your MySpace? A. Yeah. Q. And do you use that every day? A. Maybe every other day. Q. All right. And you correspond with your friends or family? A. Yeah. Q. What kind of computer do you have? A. Well, right now I have a Dell laptop. Q. Okay. And do you take that with you to work? A. No. I have my phone. Q. Okay. And what kind of phone do you have? A. IPhone. Q. And how long have you had an iPhone? 1 like 17. 2 Q. And you bank — how long have you been 3 banking? How long have you had a bank account? 4 A. Since, yeah, I was like 18. 5 Q. Did you ever have like a savings account 6 or something that your parents set up or anyone set 7 up for you? 8 A. Well, the bank is me and my mom share the 9 same. 10 Q. Do you have the same bank account? 11 A. Yes. It's a joint bank account. 12 Q. Is it a checking account? 13 A. Yeah. 14 Q. Okay. And why do you and your mom share 15 the same account? 16 A. Because she has three accounts with Chase 17 already, so to add on, it would be easier. 18 Q. Okay. So, she has her, two of her own 19 accounts and then she has an account with you? 20 A. Yes. She — 21 Q. And you said — sorry. 22 A. She added my account to hers. 23 Q. You can use that account. It's basically 24 your account. It just happens to be in both your 25 names? Page 358 A. Since November of last year. 2 Q. Okay. So, you're on an AT&T plan? 3 A. Yeah. Q. And the iPhorte, is that, are you and 5 on the same program or the same plan? A. No. 7 Q. Okay. And do you pay for your own plan? 8 A. Yeah. Well, I share a plan with my dad. It's 9 a family plan. 10 Q. How much does that cost you a month? 11 A. One hundred bucks. 12 Q. And your laptop, did you buy — how old a 13 laptop is it? 14 A. The laptop bought in January of this year. 15 I'm malting payments on it. 16 Q. Do you have credit cards? 17 A. Yeah. 18 Q. Okay. Which credit cards do you have? I 19 am not going to ask you for numbers but what credit 20 cards do you have? 21 A. I got Capital One, Wal-Mart and that's it, and 22 I have a bank card. 23. Q. How long have you had credit cants, 24 • Ms. Doe No. 6? 25 A. My...dadFt me first credit card when I was 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Page 360 A. Yeah. Q. I may have asked this before, so I 'apol ting Have you ever talked with ; that is, is she aware that you're a Plaintiff in a lawsuit? A. (Witness shakes head.) THE COURT REPORTER: Is that -- BY MR. CRITFON: Q. No? A. No. also listed M , as one of your closest friends over the last four or five years. Is she aware you are a Plaintiff in a lawsuit? A. Yeah, she knows something about it Q. Okay. And how does she know about it? A. Because last time I came here, I told her that I had to, what I had to do. Q. Okay. And what, I mean that you had to testify? A. That I had to — Q. That I was asking you questions? A. — go downtown with my lawyer. And I explained to her that I was in a lawsuit and that I would tell her about it later. Cein. 8 (Pages 357 to 360) PROSE COURT REPORTING AGENCY, INC. (M) Electronically signed by cynthia bodkins (601451-976-2934 Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601.051.916.2934) 77a4bf41 -af9a-40e1 -9063-81(6a007a 067 EFTA01076773 Page 361 1 Q. So, she doesn't know anything about why 2 you're in a lawsuit? 3 A. No. 4 Q. Have you, have you ever been in a lawsuit, 5 other than this lawsuit have you ever been in a 6 lawsuit for anything before? 7 A. No. 8 Q. Was your mom involved in a lawsuit when 9 they had that automobile accident with the semi? 10 A. No. 11 Q. Did that turn into a lawsuit? 12 A. No. 13 MR. HOROWITZ: Form. 14 BY MR. CRITFON: 15 Q. Was a claim filed or do you know? 16 A. No, no. 17 Q. Your mom never filed anything? 18 A. No. 19 MR. HOROWITZ: Form. 20 BY MR. CRITTON: 21 Q. Was the car repaired? 22 A. No. 23 Q. Was it drivable? 24 A. No. 25 Q. What happened to it? Page 362 1 A It was junked. 2 Q. Okay. And how do you know that she didn't 3 file a lawsuit? 4 A Because she didn't, because I know she didn't. 5 She was filing for bankruptcy. 6 Q. Your mom was at the time? 7 A She just filed for bankruptcy in 2000 or 2002 8 or something like that. It was like six, seven years 9 ago. But, yeah, she was filing for bankruptcy. The car 10 was junked. The tires blew. It wasn't nobody's fault. 11 Thafs what they said. 12 Q. Okay. A typical day that you told me 13 about going to work, take your son to your mom's and 14 then son goes to your aunts. You work, pick up son, 15 you watch a little TV, get dinner ready, talk, I 16 assume, with and you guys go to bed; is that 17 pretty much Aug you've been doing the last couple 18 of years? 19 MR. HOROWITZ: Form. 20 BY MR. CRITTON: 21 Q. Since your son's has been born? 22 . A...No. I we take him, we went to the zoo 23 last week with daughter, his wife. I take him 24 around the neighborhood sometimes in his little wagon, 25 his little car, his little Power Wheels car that he 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 363 drives around, too. I mean, I hang out with my son most of the time, yeah. BY MR. CRT'S: Q. Does do things with you and your son, too? A. Yeah. Q. Okay. So, he is a pretty active father? A. Yeah. Q. All right. Was there a time — well, let me strike that. You, you've testified that you went to Mr. Epstein's home on one occasion, August 8th of '04, correct? A. Yeah, that was one time. Q. Prior to the time that you were at Mr. Epstein's home, I want to talk a little bit about some background that you, that you provided or that I provided at least to your attorney with regard to issues that you had with, issues that you had with police or law enforcement. Okay. Have you had a chance to look at a bunch of police reports? A. No. Q. Have you looked at any police reports? MR. HOROWITZ: Form. THE WITNESS: About who? Page 364 1 BY MR. CRITFON: 2 Q. About anything? 3 MR. HOROWITZ: Form. 4 THE WITNESS: About my case when I was on 5 house arrest? 6 BY MR. CRITTON: 7 Q. Okay. Have you looked at some of those? A. Not recently. 9 Q. Okay. When you say not recently, did you 10 look at it before you were deposed in February? 11 Before I, we started your deposition in February, 12 did you have a chance to look at that? 13 A. No. 14 Q. Okay. Do you remember an incident that at 15 least you were involved in where you were followed 16 into the woods and, by a number of girls and were 17 attacked and threatened back in August of '03? 18 MR. HOROWITZ: Form. 19 • THE WITNESS: I was followed into the 20 woods? 21 MR..CRITION: Right. 22 THE WITNESS: Was that at school? 23 BY MR. CRITTON: 24 Q. Apparently you were on your way home from 25 middle school. Do you remember that? 9 (Pages 361 to 364) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkins (601.051.970.2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia booklets (601.051.97&2934) 77a4b141-a19a-4001-9063.81t6a007a067 EFTA01076774 Page 365 Page 367 A. Yeah. Q. All right. And what happened, what 3 occurred on that occasion? A. Nothing. They pushed me around and was just talking and that's it, and we didn't even fight. ▪ Q. Okay. Then why, why did you report it? The only way, I assume the people who came after you 1 wouldn't have called the police to report that they 9 attacked you? 10 A. The school police. 11 MR. HOROWITZ: Form. Wait for his 12 question. 13 BY MR. CRITTON: 14 Q. Let me finish my question. I, I assume 15 that the girls who attacked you wouldn't have called 16 the police. So, how was it that the Palm Beach 17 Sheriffs office became involved in August of '03 - 18 MR. HOROWITZ: Fenn 19 BY MR. CRITTON: 20 Q. — as a result of that incident? 21 MR. HOROWITZ: Form. 22 THE WITNESS: Because the reason the fight 23 broke, got we there is a school 24 police and Dr. (phonetic) that would 25 drive wound on the golf course or on the golf 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 finish doing my laundry, and there was some guy in my drier looking through my clothes, and he turned around he had my drawers in his mouth. BY MR. CRITTON: Q. Your Underwear? A. Yes. Q. And what did you do? Did you scream? A. Nothing. I went back inside. Q. Did you yell? A Yeah. I went back inside and I told my parents, and they came outside and he was gone. Q. Did they find the person? A They all went looking for him. I don't think 90. Q.. Did the police come? A. I don't remember.. Q. Okay. !asked you to assume that there is — do you remember —. A Yeah. Q. -- looking at a police report about it? A. No. I didn't ever look at the police report. If you got one, ! assume there was one mat Q. All right. And did the police come and interview you at all? A I don't know. I was 13. Page 366 1 cart and watch all the kids walk home. 2 So, they heard about what's happening, 3 because we're what, 13, 12 years old, a bunch 4 of little middle school kids. They were all 5 loud, so the school police made a report. 6 I don't even remember that. I don't 7 remember talking to no cops or nothing. 1 8 remember walking home, going to Wendy's and 9 getting picked up. 10 BY MR. CRITTON: 11 Q. Okay. And who picked you up? 12 A. My mom like always. 13 Q. All right. Do you remember another 14 instance in '03 where you went into a shed and there 15 was a, I guess you were doing your laundry and there 16 was some man in the shed? 17 A. Yeah. 18 Q. Okay. And I would ask you to assume that 19. at least the police reflects that it was on 20 February, I'm sorry, r Tell me what 21 you remember about that incident. 22. A I went — 23 MR. HOROWITZ: Asked and answered, but go 24 ahead. 25 THE WITNESS: I went to the shed to go1 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 368 Q. You can answer yes or no. Again -- A I don't arum nber. MR. HOROWITZ: Just say — MR. CRITTON: Let me just - MR. HOROWITZ: There you go. MR. CR]TFON: I don't know what you remember or what you don't remember. And therefore, when I'm asking you a question, don't get upset atme because I wasn't there at the time. Do you understand that? THE WITNESS: Yeah. MR. CRAYON: All right. So, if I am asking a question, it's because I don't know what the answer is most of the time. All • right? THE WITNESS: Yeah. BY MR. CRITTON: Q. So, you don't remember talking to the police at all, is that correct? A No, I don't remember. Q. Okay. Do you remember an incident in, an in November of 2003 between yourself and named laetic)? Do you remember a person A. What happened? I don't -- 10 (Pages 365 to 368) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801A51.976.2934) Electronically signed by cynthia hopkins (601.051-9762934) Electronically signed by cynthia hopkins (601.051-976.2934) 77a41041-af9a-40e1-9063-8115a007a067 EFTA01076775 Page 369 1 MR. HOROWITZ: Bob, can you share that one 2 with me. I am not sure that — 3 MR. CFUTTON: I sent you everything. 4 MR. HOROWITZ: No. I understand, but can you MR. CRTITON: Unfortunately, I have 7 written all over all of these. 8 MR. HOROWITZ: Okay. 9 BY MR. CRTFT'ON: 10 Q. This is -- it happened, apparently you 11 were struck in the eye by Ms. You were 12 talking with her boyfriend, and you-all, the two of 13 you started fighting. Does that ring a bell with 14 you at all? 15 MR. HOROWITZ: Form. 16 TliE WITNESS: Yeah. Man, girls. She 17 . thought I was talking to her boyfriend, and she 18 came and confronted me about it and started 19 trying to fight with me so. 20 BY MR. CR1TTON: 21 Q. Again, the Palm Beach Police were called 22 again. 23 A. Yes. 24 Q. So, did you have to give a statement to 25 the police? Page 371 1 trust? 2 A. I don't — what do you mean by that? 3 Q. Well, would you, would you, if you had a 4 problem, if you had an issue, would you call that 5 you thought you needed to talk to the police, the 6 police is someone that you felt that you could call, 7 dial 911 and tell them if you had a problem or 8 somebody had done something to you that you thought 9 was wrong or illegal or inappropriate? 10 A. If I had an emergency, I would call 91i . 11 That's all. That doesn't make any sense. 12 Q. All right. Well, did you feel like you 13 could tell the police what had happened in at least 14 each of these dime instances, and they could 15 evaluate whether what you were saying was hue or 16 not? 17 MR. HOROWITZ: Form. 18 THE WITNESS: In two of those incidence, 19 or I know one of them. I didn't talk to the 20 police. Do you have any daughters? I mean, 21 like, come on. Girls get into fights all the 22 time because other girls are talking about them 23 and it's middle school. 24 BY MR. CRiTTON: 25 Q. All right. So, its pretty common for Page 370 1 A. Yeah. 2 Q. All right. And did they take err/ action 3 at that time? 4 MR. HOROWITZ: Fonn. 5 THE WITNESS: I don't know. They were 6 saying that they were going to press charges on 7 me. 8 BY MR. CRITTON: 9 Q. Were any charges ever pressed? 10 A. I don't think so. 11 Q. Okay. So, at least, I mean we've talked 12 about, these may not be all of them but an incident 13 in August of '03, another incident in March of '03, 14 third incident now in November of '03. Are those, 15 at least in those three instances, the police were 16 called so you had to deal with the police. Correct? 17 MR. HOROWITZ: Fonn. 18 THE WITNESS: Yeah. 19 BY MR. CIUTTON: 20 Q. All right. And you knew, did you consider 21 the police to your friends at that time? 22 A. No. 23 Q. Did you consider the police to be bad? 24 A. No. 25 Q...a.SomeoneMat you would Mist or wouldn't Page 372 1 middle school girls to get in fistfights? 2 A. Yeah. 3 Q. All right. And that's certainly been your 4 experience? 5 A. I mean, all, you don't watch the news like 6 there was girls that took a girl in the house and, ilke, 7 beat, there were like three of them that beat her up 8 inside the house. 1 mean, like, come on. The girls do 9 it all the time. ifs not like, ifs not — it wasn't a 10 big deal. I don't see why you're making a big deal out 11 of it. Girls will be girls. They cat fight. 12 Q. All right. And so at least in your 13 experience when you were in middle school pretty 14 common for girls to get into fights and have yelling 15 matches or fistfights with each other and then the 16 next day or a few days later they are friends again? 17 A. Yeah. Exactly. • 18 Q. Okay. 19 A. Exactly how it goes. 20 Q. When you were in middle school did you 21 get, did you get to make choices about classes that 22 you were going to take? 23 A. No. 24 Q. You had to go to certain classes? 25 A. Yeah. -.vs...—. 11 (Pages 369 to 372) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051.976.2934) Electronically signed by cynthia hopkins (601.051-9764934) Electronically signed by cynthia hopkins (601-051.976.2934) 77a4bf41-af9a-40e1.9063-8115a007a067 EFTA01076776 Page 373 Page 375 1 Q. It was all a structure? 2 A. Yeah. 3 Q. All right. And then as to, in terms of 4 your attendance at school, did you consider 5 yourself, did you attend on a pretty regular basis 6 or were you pretty truant? If I say, if I use the 7 word truant, does that mean anything to you? 8 A. like- 9 Q. You don't go to school. 10 A. Yeah. 11 Q. That is you skip school. Somebody who 12 skips school would be considered truant 13 A. Yes. I did that a lot. 14 Q. And, and did you do that during middle 15 school? 16 A. That's the only school I went to. I didn't go 17 to high school. 18 Q. That's right. So, by the time you, you 19 were in middle — or because you didn't go to high 20 school, in middle school when you skipped school, 21 how often would you skip — let me start again. 22 That was an awful question. 23 How often would you skip school when you 24 were in middle school? 25 A. I don't know. 1 Q. Right? 2 A. Yeah. That's what skipping school is. 3 Q. All right And if you had skipped, if you 4 had skipped school, you had to make a decision, 5 right? You had a choice to either, Ism going to go 6 to school today or I am not going to go to school. 7 A. Not really. It was a group of kids, either 8 they were skipping — I wasn't skipping by myself. It 9 wasn't like l was, hum, maybe l just don't want to go to 10 school and I am going to go sit in this bush by myself. 11 it wasn't like that. 12 Q. You didn't have to sit in a bush. I mean, 13 you can — 14 A. I mewl, where else was I going to go? 1 15 wasn't going to go home. 16 Q. Why not, ifyour mom wasn't there? 17 A. She comes home for lunch. 18 Q. Okay. So, you knew she came for lunch and 19 if you sldpped 20 A. Yeah. 21 Q. Let me finish the question. So, you knew 22 during middle school, 2002,2003, that if you 23 skipped school and you stayed home, mom, you would 24 see mom at lunchtime. So you couldn't obviously 25 stay there, right? Page 374 1 Q. A third of the time, a half of the time? 2 A. Idon't know. 3 Q. Once in a while, once a week? 4 A. Maybe like once a week, once in a while. I 5 don't know. I don't remember. 6 Q. And if you were going to skip school would 7 you go off to school and then just; that is, your 8 mom or your, you know, whoever you were living 9 who were you living with at that time, your mom? 10. A My mom. 11 Q. Okay. Your mom was going to work? 12 A. Yes. 13 Q. She'd go to work and she would send you 14 off to school? 15 A. Yeah. 16 Q. Okay. Except sometimes you wouldn't go? 17 A. Yeah. 18 Q. All right. If you didn't go would you 19 stay home? 20 A. No. 21 Q. Where would you go? 22 A. To whoever I was skipping with. 23 Q. And if you, if you skipped school, you 24 knew that you were supposed to be at school, right? 25 A. Yeah-Page 376 1 A. Yeah. 2 Q. And in terms of whether you were going to 3 skip school or not, and would you coordinate that 4 with your friends or would you get to school and a 5 bunch of people would just say, hey, lets not go 6 today? 7 A. Yeah, that's how skipping school works. 8 Q. And so, but it would be your choice? 9 A. I guess, yeah. 10 Q. That is, and you would have to make a 11 voluntary decision, I am either going to go to 12 school today or I am not going to go to school, 13 right? 14 A. Yeah, pretty much. 15 Q. All right. And if you didn't go to 16 school, you know that that was wrong because you 17 were supposed to be in school, right? 18 A. Yeah, I guess. 19 Q. Do you remember in May of 2000, May 20th 20 of 2004 that you were punched in the head, a friend 21 punched you in the forehead with a closed fist 22 Again another police report was filed. Do you 23 remember that? 24 A. No, I don't remember that. 25 But consistent kind of with PROSE COURT REPORTING 12 (Pages 373 to 376 AGENCY, INC. 4 Electronically signed by cynthia hopkins (601-051.976-2934) Electronically signed by cynthia hopkins (601-061.976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) 77a4b141-at9a-400-9063-81t5a007a067 EFTA01076777 Page 377 1 what had happened in the past? 2 A. I don't even remember what you're talking 3 about. 4 Q. Well, see if this refreshes your 5 recollection is that it vias-.imr mothers name is 6 how do ou that, 7 A. 8 Q. called the police. She 9 advised that het daughter had a verbal argument with 10 a friend for some unknown reason and the friend's, 11 the friend had punched you in the forehead with her 12 fist. Okay. 13 The person apparently lived in Tavares 14 Cove mobile home. Grabbed you by the arm, hit you 15 with a closed fist. Again, just kind of a routine 16 event for you in middle school during that time? 17 A. I don't is there like a name of the person? 18 I don't. 19 Q. No. They have them blacked out. 20 A. See my mom called. I mean, like, she's my 21 mom. 22 Q. All right. But you don't remember 23 anything about that? 24 A. No. 25 Q. Okay. Do you remember in April of 2005, Page 378 you and your brother got into a 2 fight and the police were called? 3 A. He's my brother. Oh, my God. 4 MR HOROWITZ: Form. 5 MR. CRITTON: Well, again, there's, 6 there's a distinction. There is — kids fight 7 all the time. THE WITNESS: Do you have any other police 9 reports about whole neighborhood. I mean the 10 cops are always in my neighborhood. They like 11 live there. So, l mean, like they are like 12 there. So, when something happens, they rush 13 over. 14 BY MR. CFUTTON: 15 Q. All right. So, at least as you were 16 growing up the police were in your neighborhood as 17 .a, on basis? 18 A. Yeah. 19 Q. So, at least in the instance where you're, 20 they came to your house because you and your 21 brother, because you and your brother were having a 22 fight, that was just again kind of a normal 23 occurrence in the neighborhood for you? 24 • A. Not in the neighborhood. I don't — he is my 25 brother. We don't get alone! is 23 and 1 am — or v2t,rlraia0ZeWi abmgfrefIV 1 2 3 4 5 6 7 8 9 10 11 12 3 14 15 16 17 18 19 20 21 22 23 24 25 Page 379 he is 24 and I am 19, like, we don't like the same stuff We just don't get along. It's just brother and sister. Q. All right. Well, every time that, is it your testimony that every time there was a fight between a brother and a sister in the neighborhood, the police would show up and fill out a report? A. There has been a lot less that they have shown up for. Q. If you thought you had a problem that you needed to discuss with the police or something illegal had happened or inappropriate happened, at least the police were in your neighborhood enough that you could call the police or talk to the police and report it to them, right? MR. HOROWITZ: Form. MR. CRITTON: Based on what you told me. THE WITNESS: I wouldn't walk up to them and start talking to them, no. BY MR. CRITTON: Q. Why not? If you thought someone had done something inappropriate to you or illegal or improper, you could certainly if the police were in your neighborhood as often as you indicated back in the 2003, 2004 time period, you could have gone to Page 380 1 the police and told them, true? 2 A. If you read on all those police reports, they 3 were there because of me. So, I'm not going to walk up 4 to them and be like, hey, I got a probkm. 5 Q. Why not? 6 A. Perauge they are obviously there for something 7 that one of us did, so I am not going to walk over there 8 and start [Wong to them. 9 Q. Well, why? If you thought that somebody 10 had done something to you, why would you not feel 11 comfortable enough to go up to the police and tell 12 them what happened if you thought it was a 13 significant event? 14 A. Do you just want me to walk up to some random 15 cruiser and knock on the window and start talking to 16 them? Why don't you try that and tell me how it goes. 17 They are going to tell you call 9111, call the 18 nonemergency number, call them, and they will call me. 19 That's exactly what they are going to tell you. 20 Q. Okay. 21 A. They are not going to talc to you. They are 22 not going to have a Ml blown Dr. Phil conversation 23 with you. 24 Q. And so from your perspective, if you 25 really wanted the police, if you wanted to report 13 (Pages 377 to 380 PROSE COURT REPORTING AGENCY, INC. I Electronically signed by cynthia hopkIns (801.061476-2934) Electronically signed by cynthia hopicins (601.051.976.2934) Electronically signed by cynthia hooking (801-051-978-2934) 77341)141 -af9a-4001 9063-8115a 007a067 EFTA01076778 Page 381 1 something that you thought had occurred illegal, 2 illegally to you or some, someone had done something' 3 inappropriate with you, you had certainly the 4 knowledge back in 2002, 2003, 2004, 2005 to call 911 5 and report it, true? 6 MR. HOROWITZ: Form. 7 THE WITNESS: I have known to call 911 3 since I was like six years old. 9 BY MR. CRITTON: 10 Q. All right 11 A. So — 12 Q. So, the answer to my question is, yes? /3 A- Yeah. 14 MR. HOROWITZ: Form. 15 BY MR. CRITTON: 16 Q. Do you remember when the police were 17 called in June of 2000 -- June 25th of 2005, because 18 you threw a rock at a car window at one of your 19 friends and broke it? Do you remember that? 20 A. Yeah. We were playing around and I paid for 21 that window. 22 Q. Well, the police were called? 23 A. No, I didn't, I didn't know the police were 24 called. I know that it was the — we were all sitting 25 at the office with the manager and everybody. It's her Page 383 1 couple, but the police again were called. There was apparently a fight between your mother, between your 3 father about something silly like a bag of chips and 4 yourself, and your mother stepped in front of you 5 and got hit by your father instead? 6 MR. HOROWITZ: Form. BY MR. CRITTON: 8 Q. Do you remember that event? 9 A. No. 10 Q. Do you deny it happening or you just don't I remember it? 12 A. No. My parents never hit me or never hit my 13 brother. No, I don't. I couldn't even believe that if 14 you tried to tell me that happened, no. 16 recollection, is on the the Q. Let's see if this refreshes our 15 17 police, the Palm Beach Sheriffs Office came to your 18 house. The mother and father were fighting. Your 19 father reportedly was drunk and was yelling at the 20 mother about a bag of chips being left on the 21 counter. 22 • You started to yell or you were yelling at 23 your father telling him to stop yelling at your 24 mother. And he got in your face and went into your 25 .room, got in your face, yelled at you and attempted I Page 382 1 son. And we were all playing around throwing stuff at 2 each other, and I threw a rock and it just tapped his 3 window and it shattered. 4 Q. The rock just tapped the window? 5 A. Yeah. 6 Q. And what, a windshield of a car shattered? 7 A. No, it was the side window. 8 Q. Side window in the trailer? 9 A. No, in a car. 10 Q. Oh, that's what l thought you said. So, 11 it's not the windshield. It was the side window in 12 a car? 13 A. Yeah. 14. Q. And you threw a rock? 15 A. Yeah. 16 Q. Just tapped it? 17 A. We were playing around all throwing stuff at 18 each other. I guess it just tapped the window and the 19 whole thing spidered. If that's that's the only 20 knowledge that I know of breaking a window, because I've 21 never done nothing to nobody's car. If you look I have 22 never touched nobody's house or car or nothing. I am 23 not that type of person. 24 Q. Do you remember in July, on July 20th of 25 Page 384 1 to hit you, but the mother stepped in between you 2 and your father. Do you remember that? 3 MR. HOROWITZ: Font 4 THE WITNESS: No. 5 BY MR. CRITTON: 6 Q. Okay. You're not saying it didn't happen. 7 You just have no recollection of it? 8 A. No, t am saying it didn't happen because 9 did that — is that like a police report? How would 10 they know what happened in my house. We didn't come out 11 and say anything because I know my mom and I know my 12 dad, and you are tripping. No, there is no way. I 13 don't know-- 14 Q. How am, how I tripping? 15 A. Because that's ridiculous. My dad never hit 16 me or my brother. 17 Q. How about your mom? 18 A. Newt'. I am telling you never. 19 Q. So, if tha.e is a police repon on this 20 you think someone just created it, made it up? 21 MR. HOROWITZ: Form. 22 THE WITNESS: No. I think that they have 23 the wrong story because that's not what 24 happened. I know my dad is a drunk, but he '06