UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. / Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092, / DEPOSITION OF JANE DOE #7 - VOLUME II (videotaped) Monday, March 15, 2010 10:02 - 6:49 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RMR, CRR Notary Public, State of Florida (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107831 EFTA01107832 Page 127 Page• 1 APPEARANCES: 2 On behalf of the Plaintiffs in related cases Nos 08-80069, 08-80119, 08-80232, 08-80384 3 08-80381, 03-80993, 08-80994: 4 ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 5 18205 Biscayne Boukvad Suite 2218 6 Miami, Florida 33160 Telephone: 305/931.2200 7 8 On behalf of the Defendant Jeffrey Epstein: 9 ROBERT D. CRITTON. JR, ESQUIRE BURMAN, CRl11UN, LUTHER& COLEMAN 10 303 Banyan Boulevard Suite 400 11 West Palm Beach, Florida 33401 Telephone: 561/842-2820 12 13 14 Also Present: Sasha Quimby, videographer 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROCEEDINGS THE VIDEOGRAPHER: We're back on the record at 12:19 p.m. This is marks the beginning of tape 2. BY MR. CRITTON: Q. When you took F.E. to Mr. Epstein's, 1 think you said she asked you to take her. A. Yes. She knew about It and she asked me, she said she wanted to go. Q. Okay. Did you say, and did you tell her "No, I don't think you should go'? A. No. I never said that. Q. Did you take her so you could make money' First of all, let me ask you this. Did you make money from taking F.E. to Mr. Epstein's home? A. Yes. Q. How much? A. 200. Q. Okay. And when F.E. came down, did she give Mr. Epstein a massage? A. Yes. Q. Did she ever say anything inappropriate happened during the course of the massage? A. No. Q. And you took ■ and she came, did she give 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 128 - - - INDEX WITNESS: DIRECT CROSS REDIRECT RECROSS Jane Doe N7 By Mr. Critton 5 EXHIBITS EXHIBIT Defendants 1 Defendants 2 Defendant's 3 Defendant's 4 Defendant's 5 Defendant's 6 Defendant's 7 Defendants 8 Defendant's 9 PAGE 233 233 233 263 268 274 280 294 301 Page 130 1 Mr. Epstein a massage? 2 A. Yes. 3 Q. Did she ever tell you anything inappropriate 4 had happened? A. We never really talked about it. 6 Q. Did you ask them? A. No. 8 Q. If you talk someone to Mr. Epstein's home to 9 have them give him a massage so they could earn money 10 and you could earn money, did you interpret what you 11. were doing was the same thing in essence that M. was 12 doing? 13 MR. HOROWITZ; Form. 14 THE WITNESS: No. 15 BY MR CRITTON: 16 Q. Why was it different, in your mind? 17 A. Because they wanted to go, and we were all 18 just kind of brainwashed by him. And at the time I knew 19 it was wrong, but I didn't know how it would affect them 20 or affect me in the fixture. And I was just confused by 21 everything at that time. 22 Q. You knew it was wrong, so what's confusing 23 about that? 24 A. I felt like it was wrong, but I, I just 25 thought it was -- I was just confused, and I just didn't •t ree=aa 2 (Pages 127 to 130) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107833 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 131 know how much it would affect me in the future and, you know, what kind of effects it would have on them. And, you know, that's why I feel bad about it now, but at the time I was confused and I didn't know. Q. Wellj _let me ask you this. Have you ever talked with El about her experience with Mr. Epstein, ever? A. No. She is in now. I don't know, we don't really talk. Q. What's she doing in now? A. She lives there now with her sister. Q. IIII? A. Yeah. Q. Is her mom ? A. Yes. Q. Herded? A. Yes. Q. So they are all a. Why did they go back to a, if you know? A. Because their green card etd. Q. Let me ask you again. Did ever tell you anything bad happened at Mr. Epstein's, or inappropriate? A. I don't remember. Q. So at least — did you only take her the one Page 133 1 Q. But at least as you sit here today, you can't 2 remember anything unusual about her coming down from 3 giving Mr. Epstein a massage; would that be a fair 4 statement? 5 A. I mean yeah, I don't remember. 6 Q. Same thing with F.E., you don't remember 7 anything that stands out in your mind when she came 8 downstairs because you were in the kitchen, right? 9 A. Yeah. 10 Q. Do you remember anything unusual or did she 11 say anything or did she react or have any appearance — 12 strike that. 13 Did F.E. either say anything that caused you 14 any concern or did you observe any facial features or 15 anything that she did or the way she acted that would 16 have caused you any concern that you can remember today? 17 A. Not that I can remember. 18 Q. Those are the only two people you ever took to 19 Mr. Epstein's? 20 A. Yes. 21 Q. You went down and had an interview or an 22 evaluation by Dr. Kliman, who was the psychiatrist who 23 had been hired from San Francisco to evaluate his 24 clients, including you, correct? 25 A. Yes. Page 132 1 time? 2 A. Yes. 3 Q. Do you know whether she ever went another 4 time? 5 A. I don't know. 6 Q. All right. But when she came down from giving 7 Mr. Epstein a massage, she seemed to be in good spirits, 8 didn't say anything bad had happened; fair? 9 A. She didn't really talk about it. 10 Q. Did she appear to be upset in any way? 11 A. I don't, I don't remember. 12 Q. If she had been upset, that's something you 13 generally would remember, wouldn't you, if she was upset 14 or emotional about it? 15 A. It was so long ago, I just remember taking her 16 there. I don't remember how she reacted or what 17 happened. 18 Q. Did you drive her in your car? You were the 19 transporter? 20 A. I don't remember. 21 Q. Was El able to drive at the time? 22 A. Yes. 23 Q. But you went with her, so either she drove or 24 you drove? 25 A. Yes. Page 1 1. Q. And you had to fly down from Orlando, true? 2 A. Yes. 3 Q. Do you remember telling Jane Doe 4 about your 4 eicpadence for the evaluation with Dr. Kliman? 5 A. Yes. 6 Q. And do you remember telling her that you were 7 supposed to cry a lot and be very emotional during the 8 course of the — 9 A. No, I never — 10 Q. I need to finish the question, ma'am. 11 isn't it true you told Jane Doe 4 that you 12 cried a lot during the interview and tried to be very 13 emotional, because that's what you were supposed to do? 14 A. No. 15 Q. So if you told Jane Doe 4 that, or 'Ilene 16 Doe 4 has said that to anyone, that would be a lie? 17 A. Yes. 18 MR. HOROWITZ: Form. 19 BY MR. CRITTON: 20 Q. If I use the term crocodile tear, does that 21 mean anything to you? Do you know what a crocodile tear 22 is? 23 A. Yes. 24 Q. What is It? 25 A. When somebody fake cries. (561) 832-7500 3 (Pages 131 to 134) PROSE COURT REPORTING AGENCY, INC. (561). 832-7506 EFTA01107834 Page 135 1 Q. Let me go back to when Jane Doe 4 was living 2 with you this last summer, or I'm sorry, the summer of 3 '08 and she told you that she had filed a suit against 4 Mr. Epstein. 5 As of that date, were you aware of anyone else 6 who had filed suits against Mr. Epstein? 7 A. No. 8 Q. As you sit here today, other than yourself and 9 Jane Doe 4, are you aware of any other plaintiffs or 10 individuals who are plaintiffs in lawsuits against 11 Mr. Epstein? 12 A. Yes. 13 Q Who? 14 A. Jane Doe 3. 15 Q. Flow do you know is a plaintiff in a 16 lawsuit? 17 A. Because she is my friend and she told me. 18 Q. And that's Jane Doe 3? 19 A. Yes. 20 Q. Were you aware or has Jane Doe 3 told you 21 whether she has given a deposition? 22 A. Yes. 23 Q. Okay. What did she say about it? 24 A. She said that you looked exactly like Jeffrey 25 Epstein. Page 137 1 Mr. Epstein's home? 2 A. No. 3 Q. Did she ever talk to you about what occurred 4 or what she alleges occurred at Mr. Epstein's home? 5 A. No. 6 Q. All right. Are you aware of anyone else other 7 than Jane Doe 3 and Jane Doe 4 who are plaintiffs? 8 A. Just N.R. 9 . And who is she? Again, a student at 10 with you all? 11 A. Yes 12 Q. Same grade? 13 A. She's a grade ahead of me. 14 Q. And did she tell you that she's a plaintiff in 15 a lawsuit? 16 A. No, we were just talking about it and somehow 17 she found out that I had a lawsuit and was asking me 18 about it and she said that she had one, and that's all. 19 Q. Did she tell you who her lawyer was? 20 A. No. 21. Q. Did she — when did you last talk to N.R. — 22 let me start again. 23 When did you have this conversation with N.R. 24 about the lawsuit? 25 A. I believe it was over Christmas break, I Page 136 1 Q. Did she tell you how nice and polite I was and 2 reasonable? 3 A. Yes. 4 Q. Good. 5 MR. HOROWITZ: She did? 6 THE WITNESS: No. 7 BY MR. CRITTON: 8 Q. I'm taking that as the truth. 9 A. That's a joke. 10 Q. All right. You don't think I look like 11 Mr. Epstein, do you? 12 A. Yes, kind of. 13 Q. I think that's just, l think that's the big 14 pitch, so you all can make that pitch at trial. It's a 15 nice touch, but I'm not moved by it. 16 MR. HOROWITZ: Mow to strike. 17 BY MR. CRITION: 18 Q. What else did Jane Doe 3 tell you about her 19 deposition? 20 A. She didn't really tell me anything about it. 21 She just basically said she came in here and did it. 22 Q. Were you aware that she had been at 23 Mr. Epstein's home during the time she was going? 24 A. I don't remember. 25 Q. Do you know how she came to be at 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 138 think. Q. Christmas — A. I don't know, I was home like on break I don't know if it was Christmas break or not. Q. Well- A. I was just, like I come home a lot to visit my parents. Q. Are you still in school right now? A. Yes. Q. So when was the last time you were home, Christmas before now? A. No, I came home recently to visit them, like last month. Q Was that when you talked to N.R.? A. I think so. Q. So it would have been approximately February of 2010? A. Yes. Q. And was she at your house or did you see her at a bar or were you out at a club or — A. I forget where I saw her. I ran into her -- oh, we were at Duffy's. We all went -- Q. Which Duffy's? A. to dinner. On Northlake. Q. RIM near I-95? (561) 832-7500 PROSE COURT 4 (Pages 135 to 138) REPORTING AGENCY, INC. (561) 832-7506 EFTA01107835 Page 139 Page 141 1 A. Yes. 2 Q. Who was there other than you and N.R.? 3 A. Just some friends from high school. 4 Q. Any other people that you know? Was Jane 5 Doe 4 there? 6 A. No, Jane Doe 4 wasn't there. 7 Q. Jane Doe 3, was she there? A. No. 9 Q. Anyone else that you know, any of the other 10 people you knew went to Mr. Epstein's home? 11 A. No. 12 Q. And N.R. said that she was going to file or 13 she was a plaintiff also in a lawsuit? 14 A. Yes. 15 Q. How did she know that you were a plaintiff? 16 A. I don't know who told hen 17 Q. Were you upset that she knew? 18 A. I mean she was one of my good friends in high 19 school and she kind of knew what happened, because I 20 told her before. So I, she kind of already knew, so I 21 wasn't that upset that she knew about that. 22 Q. What do you mean you told her about? 23 A. I mean she knew about me and Jane Doe 4 going 24 there. She went there before, so — 25 Q. Oh, she had gone there before you? 1 A. Well, yeah. She — yeah. 2 Q. Okay. How does she know? 3 A. Because you guys asked her questions about me, 4 and Pm sure she assumed I was a plaintiff suing 5 Jeffrey. 6 Q. How about your friend El does she know that 7 you have brought a lawsuit? 8 MR. HOROWITZ: Form. 9 THE WITNESS: I'm sure E. told her. 10 BY MR. CRITTON: 11 Q. Why would.. tell her? 12 MR. HOROWITZ: Fenn. 13 THE WITNESS: Because they are friends. 14 BY MR. CRITTON: 15 Q. How do you know El Fuld N. are friends? 16 A. Because that's what I have heard. 17 Q. When is the last time you talked to 18 A. Right around her brother's accident. 19 Q. Okay. 20 A. So probably, I don't know, like seven months 21 ago. 22 Q. That's the last time you have spoken with her? 23 A. Yes. 24 Q. Have you tried to call her or she tried to 25 contact you at all? Page 140 1 A. No. I don't, I don't remember when she had 2 gone. She went sometime in high school. 3 Q. Did she ever tell you about her experience of 4 going to Mr. Epstein's home? A. No. I just !mew she went. 6 Q. Do you know how many times she went? A. No. 8 Q. Did you say "Why are you filing a lawsuit? 9 A. No. 10 Q. So you don't know whether she has — strike 11 that. 12 You don't know anything about her lawsuit 13 other than she has filed a lawsuit against Mr. Epstein? 14 A. Yes. 15 Q. So you mentioned N.R., Jane Doe 3, Jane Doe 4. 16 Anyone else that you are aware that was a 17 plaintiff'? 18 A. No. 19 Q. Who have you told that you area plaintiff in 20 a lawsuit? 21 A. Just those girls. 22 Q. So nobody else knows that you are a plaintiff? 23 A. No. 24 Q. How about il.? Does know you are a 25 plaintiff? Page 142 1 A. Not recently. I don't think so. 2 Q. After you said — around the time of her 3 brother's accident, since that time, have you tried to 4 call her at all? Or seven months ago was the last time 5 you had any contact with her? 6 A. Yeah. 7 Q. Okay. At the time that Jane Doe 4 told you 8 that in the summer of '08 that she was bringing a 9 lawsuit against Mr. Epstein or had brought a lawsuit 10 against Mr. Epstein, had you contacted an attorney at 11 that point? 12 A. I don't remember. 13 Q. Affright. Who was the first — strike that. 14 Was it you or your parents who encouraged you 15 to bring a lawsuit? 16 MR. HOROWITZ: Form. 17 THE WITNESS: It was me. 18 BY MR. CANTON: 19 Q. So your parents had nothing to do with you 20 bringing a lawsuit? 21 A. No. 22 Q. Are your parents aware now, were they aware at 23 the time you hired a lawyer? 24 A. Yes, I told them. 25 Q. Did you hire a lawyer before you told your (561) 832-7500 5 (Pages 139 to 142) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107836 Page 143 1 parents or were they involved in the decision? 2 A. No, I told than after. 3 Q. And who did you contact — strike that. 4 How did you — you know obviously Mr. Horowitz is seated immediately to your left, tweet? 6 A. Yes. 7 Q. Is he the fast lawyer you met from that firm? 3 A. No. I met with Jeffrey Herman. 9 Q. How did you get in contact with Mr. Herman? 10 A. He called me. 11 Q. He called you? 12 A. Yes. 13 Q. And where did he call you from? 14 A. I don't know. 15 Q. Was it before or after Jane Doe 4 told you 16 that she was a plaintiff in a lawsuit? 1'7 A. 'think it was before. 18 Q. All right. So at the time that Jane Doe 4 19 told you she was a plaintiff in a lawsuit, had you 20 already spoken with Mr. Herman? 21 MR. HOROWITZ: Form. 22 BY MR. CRITTON: 23 Q. Or did that occur after you spoke with Jane 24 Doe 4? 25 A. I don't know who had, who did it first. I Page 145 1 Mr. Herniae 2 A. I don't, I don't remember when it was, but I 3 just net, just met with him and I — 4 MR. HOROWITZ: Fm going to ask you not to 5 discuss what -- 6 MR. CRITTON: Just dealing with the time 7 sequence. Don't tell me what he said right now. 8 not there yet 9 MR. HOROWITZ: There you go. 10 BY MR. CRITTON: 11 Q. So if I understand the sequence correctly, you 12 got a phone call out of the blue from Mr. Heenan about 13 Jeffrey Epstein. 14 A. Yes. 15 Q. All right. You spoke with him, and he asked 16 you a number of questions, right? 17 A. All he really asked me was if I, if l was 18 involved with Jeffrey Epstein, If I was a witness or 19 if— I can't temember exactly what he asked me. 20 Q. I'm going to come back to that in just a 21 minute. Let me get the time sequence here if 1 can, Ms. 22 Jane Doe 7. 23 First time he called you, he called you, you 24 talked to him a little bit and you gave him the name of 25 Jane Doe 4? Page 144 1 think it was me. I don't really know. I don't 2 remember. 3 Q. I'll represent that Jane Doe 4, Jane Doe 4's 4 lawsuit was filed well before yours. She's Jane Doe 4. 5 A. Yes. 6 Q. You are Jane Doe 7. Doesn't necessarily mean 7 one came, hired the lawyer earlier or not, but 1 can 8 tell you her lawsuit was filed months before yours was. 9 A. He called me originally at first, and then he 10 asked me if I lotew any witnesses or anything, and I 11 think I game him Jane Doe 4's number, but I never agreed 12 to start a lawsuit until later on. 13 Q. So when Mr. Herman called you, you gave him 14 Jane Doe 4 — he called you about being a witness? 15 A. I believe so. 16 Q. All right. And did you talk to him? 17 A. Yes. 18 Q. Over the phone or in person? 19 A. Over the phone. 20 Q. And then you gave him the name of other 21 individuals? 22 A. Just Jane Doe 4, I think. 23 Q. And then sometime after you met with or Jane 24 Doe 4 was living with you in the summer, then did you 25 subsequently speak with him again, him meaning Page 146 1 A. Yes. 2 Q. Okay. And then sometime later you called him 3 or did he call you back? 4 A. I called him. 5 Q. How much time transpired between the first 6 call that he made and the second call that you made? 7 A. I don't know. 8 Q. Was it a week? Was it a month? Was it 9 months? 10 A. I don't remember how long it was. 11 Q. Okay. On the first conversation that you had, 12 how long did that conversation last? 13 A. Just like five minutes. 14 Q. Did he tell you he was representing anyone? 15 A. No. 16 Q. Did you ask him how he got your name? 17 A. No. I didn't know — the first time he 18 called, I didn't I was kind of really, I didn't know 19 who was who and who was representing who. So I was, 20 just kind of told him that I would take his number and I 21 would think about it and call him back. 22 Q. Okay. Well, think about what? 23 A. Well he asked me if we wanted to meet. And I 24 told him that I would think about it and call him back. 2 5 Q. Was he pitching basically I could represent (561) 832-7500 6 (Pages 143 to 146) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107837 Page 147 Page 149 7 8 10 11 12 13 14 15 16 17 18 19 20 21. 22 23 24 25 1 you in the case? 2 A. No. He just asked me if I knew about Jeffrey 3 and witnessed what happened with Jeffrey, and that's 4 about it. And he asked me if we wanted to meet and 5 talk. And I said that I wasn't sure, you know, because 6 I've had private detectives corning. And I wasn't sure who was on whose side, so I . told him that I would call him back. Q. Was he soliciting or pitching his services to you as a lawyer? MR. HOROWITZ: Form. THE WITNESS: No. BY MR. CRITPON: Q. Well, why did he want to meet with you? MR. HOROWITZ: Form. BY MR. CRITTON: Q. What did he tell you? A. He Just wanted to talk about the whole Jeffrey thing with me. Q. Why would you want to talk with him about it? MR HOROWITZ: Form. THE WITNESS: Because I heard that, you know, there's like stuff going on with, with people, so I kind of wanted to protect myself. 1 BY MR. CRITION: 2 Q. Why did she call you? 3 MR. HOROWITZ: Forni 4 THE WITNESS: She called me m fill me in on 5 the case, and I knew she was like who she said she 6 was, because Agent at the FBI told me she 7 would be calling me. She pretty much told me what 8 was going on in his criminal case, and that's about 9 it. And she said you might want to protect 10 yourself and get a lawyer, and that's about it. 11 BY MIL CIRITTON: 12 Q. Okay. Did she recommend anybody, any lawyers? 13 A. I don't remember. 14 Q. Do you remember her giving you any names of a 15 • lawyer saying 'Tm going it give you three names," or 16 "If you need some help finding a lawyer, I'll give you a 17 name'? 18 A. She said if I wanted a lawyer, to call back. 19 And she had a list, I think, but she didn't recommend 20 anybody. 21 Q. Did you ever call her back for her 22 recommendation? 23 A. No. I talked to Agent about it, and 24 she said basically what I was supposed to do. And she 25 said it was up to me basically if I wanted to hire a 2 3 6 3 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 148 BY MR. CRITTON: Q. What did you hear was going on with people? A. Nothing. I just heard that, it was when —I forget who called me and said — I think it was Maria or something. She said, you know, to protect yourself, you might want to get a lawyer. Q. Who is Maria, MIME ) A. I think so. Q. Was that the US attorney? A. Yes. Q. And had you ever met with IM A. No. Q. You never met the lady? A. No. Q. So somebody who you just referred to as calls you out of the blue. Why would — A. She-- Q. Let me finish my question. You said you let me ask you this. Did the ady, who you have now identified as assistant US attorney, did she call you before Mr. Hemian or after Mr. Heiman? MR. HOROWITZ: Form. THE WITNESS: Before. (561) 832-7500 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 150 lawyer or not. Q. Did Agent give you any names? A. No. Q. Did anyone from the FBI or US attorney's office ever give you a name of a lawyer— A. No. Q. — to contact? A. No. Q. Did you speak with — let mat back. When you spoke with Ms. that before or after Mr. Herman contacted you? A. It was before. Q. And then how much time transpired or rested before Mr. Herman contacted you about whether you were involved or to ask you questions about Jeffrey Epstein? A. About a couple of months. Q. And do you know when Mr. Herman approximately timewise called you? A. No. Q. Was it before Jane Doe 4 moved in with you that sununer? A. Yes. Q. Was it shortly aver the contacted you? A. No. It was a little while after that. police had 7 (Pages 147 to 150) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107838 Page 151 Q. Was it after the FBI interview? 2 A. Yes. 3 Q. Do you know when the FBI interview took pi 4 A. I third( I was a sophomore in college or 5 maybe -- 6 Q. That's '05, that would have been -- 7 A. I think I was a sophomore or freshman. 8 Q. So that would have been what, approximately 9 '07? 10 A. Yes. 11 Q. Let me just stick with — so when Mr. Haman 12 called you the first time, did he say what he was doing? 13 He obviously wanted to get some information about 14 Jeffrey Epstein and you, right? 15 MR. HOROWITZ: Form. 16 THE WITNESS: It didn't sound like it. 17 BY MR. CAI-ETON: 18 Q. Did you say "How did you get my name?" 19 A. No. 20 • Q. Were you surprised that sane lawyer out of the 21 blue called you to ask you about Jeffrey Epstein and you 22 didn't know who they were a how they had gotten your 23 ,me? 24 A. I thought — I had no idea. That's why I 25 didn't agree to meet with him at first, because I didn't Page 153 i Q. Okay. And did you investigate him at all? 2 A, Yes. 3 Q. Did you go online? 4 A. !looked his name up. 5 Q. Where? 6 A. Online. 7 Q. And what did you find out? 8 A. That he was a sexual abuse attorney. 9 Q. And did you ask him before you hired him 10 whether he was representing any other people associated 11 with the Epstein matter? 12 A. No. 13 Q. When you called him back and before you hired 14 him, did you ask him how he ever got your name? 15 A. No. 16 MR. HOROWITZ: going to assert the 17 privilege. I understand what you're trying to do, 18 but I'm going to assert the privilege as to the 19 conversation in that the entire conversation was 20 leading towards the result of obtaining a lawyer. 21 So that's my position, and we can -- 22 BY MR. CRITTON: 23 Q. Are you going to follow your lawyer's — if he 24 tells you — if he claims a privilege, are you asserting 25 that privilege? Page 152 1 know if he was, you know, on your side or their side or 2 hying to check me or whatever, so that's why I waited a 3 little bit to call him back. 4 Q. When you did call him back, however much time 5 transpired, what did you say to him? 6 MR. HOROWITZ: We're going to assert the 7 privilege on that, but you can make the proffer. 8 BY MR. CRITTON: 9 Q. You called him back, correct? 10 A. Yes. 11 Q. Okay. All you knew, he was a lawyer? 12 A. Yes. 13 Q. You didn't know who he represented? 14 A. No. 15 Q. If anyone? 16 A. No. 17 Q. Okay. He could have been Mr. Epstein's 18 lawyer, he could have been anybody's lawyer, for all you 19 'mew, right? 20 A. I mean he told me he —10ce no, I think he . 21 told me he wasn't — he was like representing — I don't 22 know, he didn't say -- I don't know. I don't remember 23 why I actually called him back. 24 . Q. Why did you call him back? 25 A. Because I wanted to hear what he had to say. Page 154 1 A. Yes. 2 MR. HOROWITZ: Yes. I just want to tell her 3 what I'm invoking. 4 As to this second telephone conversation, I'm 5 instructing you that you have a privilege not to 6 answer questions about the second conversation. 7 THE WITNESS: Okay. 8 BY MR. CRITTON: 9 Q. Did you hire Mr. Herman in the course of the 10 second conversation? lust yes or no. 11 A. He came to Orlando and we met and then -- 12 Q. No, no. Well get there. 13 In the second conversation, did you say "I 14 want to hire you" or did you just say -- 15 A. No. 16 Q. — "I'd lilte to meet with you"? 17 A. "I'd like to meet with you." 18 Q. Okay. So how long did the second conversation 19 last? 20 A Not long. 21 • Q. • Five 'minutes? 22 A. Just about. 23 Q. What did you tell him? 24 MR. HOROWITZ: I'll instruct her not to 25 answer. Well assert the privilege, a privilege, .. (561) 832-7500 PROSE COURT REPORTING OXISCIZA 8 (Pages 151 to 154) AGENCY,: INC. (561) 832-7506 EFTA01107839 Page 155 the attorney/client privilege. MR. CRiTFON: I understand. 3 BY MR. CRITTON: 4 Q. And you are going to follow his direction, 5 correct? 6 A. Yes. Q. And until Mr. Herman came to Orlando -- strike that. 9 How much time passed between the second 10 conversation and Mr. Herman came to Orlando? 11 A. Not long. Maybe a couple weeks. 12 Q. Did anyone else come up with Mr. Herman to 13 meet with you? 14 A. No. 15 Q. Just you and Mr. Herman met? 16 A. Yes. 17 Q. Where did you meet? 18 A. At Starbuck's. 19 Q. Okay. And did you sign an agreement then to 20 have him represent you? 21 A. After lmet with him and heard everything he 22 said, yes, I did. 23 Q. Okay. Before that, that is, before you 24 actually hired him, bad you discussed with him what had 25 happened to you, that is — well, let me strike that. Page 157 I. everybody and her parents fording out and her sister 2 finding out and her being depressed and humiliated, I 3 mean yeah, I would assume that's some trauma for her. 4 Q. Okay. Has she told you she's depressed? 5 A. Yeah, and when she found, her parents found 6 out and all that, she was depressed, she told me. 7 Q. The way you've described it is Jane Doe 4's 8 main emotional or psychological — let me strike that. 9 Her main psychological injury from at least 10 the way you've described it is she's been humiliated and 11 depressed because somebody other than her friends, in 12 particular, her parents and her sister, found out that 13 she had gone to Mr. Epstein's house? 14 A. Not from that. From just going when she was 15 younger. She regrets it, and she even told me i wish I 16 never went when I was younger. i was confused and -- 17 Q. She — fm sorry. 18 A. Go ahead. 19 Q. Did she tell you that she went — well, you 20 !mew she went both before she was 18 and after she was 21 18, right? 22 A. Yeah, l guess. 23 Q. All right. And did she tell you she was more 24 confined when she was 17 than when she was 18, or did .25 she ever describe to you that there was a difference 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 156 In the second conversation did you give him any information as a witness as distinct from your own personal circumstances? MR. HOROWITZ: i have to assert the privilege. BY MR. CRITTON: Q. And you are going to follow his direction? MR. HOROWITZ: Yes. Good try. MR. CRITTON: That's not a good try. Just -- BY MR. CRITTON: Q. Has Jane Doe 4 told you — let me strike that. I'd ask you to assume that she's brought the same S50 million lawsuit that you have, different facts, but she wants 50 million bucks too, at least in her complaint that she's asserted against Mr. Epstein. Did she ever tell you any injuries or damages that she ever sustained as a result of being at Mr. Epstein's home? Has she ever said anything to you about it? A. We never really talked about her. Q. Even through today's date, she's never told you any damages or how she was damaged or any injuries, psychological or otherwise, that she ever sustained at Mr. Epstein's house; is that correct? She's never discussed that with you? A. I mean other than being humiliated by Page 158 1 when she went at 17 or 18? 2 A. I don't know. She never described anything to 3 me. 4 Q. Did she ever say "Gees, the day I turned 18 5 and was a freshman at college, i still went to see 6 Mr. Epstein"? 7 A. No. 8 Q. Okay. Did she ever say, "Well, gee, just 9 before I turned 18, i had these emotional injuries, but 10 at 18 everything was okay when I went to Mr. Epstein's'"? 11. Did she ever say that to you? 12 MR. HOROWITZ:. Fa 13 THE WITNESS: No. 14 BY MR. CRITTON: 15 Q. All right. Did she ever distinguish to you 16 having been to Mr. Epstein's before she was 18 or after 17 she was 18; that is, that any time period was different 18 for her? 19 A. I don't remember. 20 Q. You don't remember her telling you that, 21 correct? 22 A. No -- yes. I don't remember her telling me. 23 Q. All right, I understand. 24 Now you've known Jane Doe 4 for a long time? 25 A. Yes. 9 (Pages 155 to 158) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. . (561) 832-7506 EFTA01107840 Page 159 Page 161 1 Q. Since '02, I think you told me. 2 She's been through some rather traumatic 3 events in her life, has she not? 4 A. I guess you could say that. 5 Q. Well, you know she's been arrested before? 6 A. Yes, when we were younger. 7 Q. Pardon? 8 A. When we were younger. 9 ri I. And she haditliend named 10 You knew didn't you? 11 A. Yes. 12 Q. What did you think of_? Pretty 13 upstanding, great guy? 14 A. No. 15 Q. Okay. He was a jerk, wasn't he? 16 A. Yeah. 17 Q Pardon? 18 A. Yes. 19 Q. And beat Jane Doe 4, didn't he? 20 Physically abused her? 21 A. I mean he pushed her. He didn't beat her up, 22 but yes, he pushed her before. 23 Q. Did you ever see him slam her face down into 24 the hood of the car, into the dashboard of a car? 25 A. No. 1 BY MR. CRITTON: 2 Q. Did you ever hear him call her a-? 3 A. No. 4 Q. What kind of things did you hear 5 to her to verbally abuse her? 6 A. Just bitch, and I don'ttellkAlrber. We were in 7 high school. Just, I mean I never heard him call her a 8 whore or anything else you said. 9 Q. Fm sorry? 10 A. I said or anything else you said. 11 Q. But you were aware that he was both physically 12 and verbally abusive to her? 13 A. Yes. 14 Q. All right. And did you ever tell Jane Doe 4 15 `You got to get away from this guy, he's bad news"? 16 A. Yes. 17 Q. What was her reaction? 18 A. She was in love. So she didn't really -- 19 Q. And she carried oniacal, a long-term 20 physical relationship with did she not? 21 A. Yes. 22 (*.you ever, were you ever aware whether she 23 and were pregnant? 24 MR. HOROWITZ: Form. 25 THE WITNESS: No. say 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 160 MR. HOROWITZ: Form. BY MR. CRITTON: Q. Are you aware, did she ever tell you that that happened? A. No. Q. Did you see spitting on her? A. No. Q. Did you see her spitting back at A. No. Q. Were you aware that had occurred? A. No. Q. Were you aware was a drug addict? A. Yes. Q. Were you aware that he was an alcoholic? MR. HOROWITZ: Form. THE WITNESS: Yes. BY MR. CRITTON: Q. You were around when he verbally abused her and called her awful names, weren't you? A. One or two times. Q. Okay. Did you ever hear him refer to her as a whore? MR. HOROWITZ: Form. THE WITNESS: No. Page 162 1 MR. HOROWITZ: I bow what you mean. 2 BY MR. CRITTON: 3 Q. Of coarse he can't but are you aware that 4 she became pregnant with ? 5 A. Yes. 6 Q. Did she tell you that? 7 A. Yes. 8 Q. On how many occasions did Jane Doe 4 disclose 9 to you that she had become pregnant within 10 MIL HOROWITZ: Form. 11 THE WITNESS: Just once. 12 BY MR. CRITTON: 13 Q. Okay. She never told you — so let me strike 14 that. Are aware that she became pregnant, even if 15 not with ME, on two other occasions? 16 MR. HOROWITZ: Object to the form, and let me 17 just, I have to say this. You are potentially 18 disclosing very intimate personal medical 19 information about one person to another, and I 20 think you are touching on some boundaries that you 21 shouldn't be going on, but go ahead. 22 BY M. CRITTON: 23 Q. Do you want the question back? 24. A.. No. 25 Q. No what? That was your answer? (561) 832-7500 10 (Pages 159 to 162) PROSE COURT REPORTING AGENCY, INC.. (561) 832-7506 EFTA01107841 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 163 1 A. I don't want the question back. 2 Q. Do you remember the question? 3 A. Yes. Q. Okay. I don't. 3 (A portion of the record was read by the reporter.) MR. HOROWITZ: Form. THE WITNESS: I don't think that we should really be talking about her details, intimate details. BY MR. CRITTON: Q. Can you answer my question? MR. HOROWITZ: Just answer what you know. THE WITNESS: I just told you I know once what happened. BY MR. CRITTON: Q. That's all you know, that she became pregnant? A. Yes. Q. Did she tell you how the pregnancy was terminated? A. Abortion. Q. Was she pretty upset about that? A. Yes. Q. What kind of drugs did take? Was he a seller? Let me strike this. 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 161: Q. So at least in high school, you're saying that you drank alcohol, right? A. Yes. Q. Even though you were underaged? A. Yes. Q. And did you use pot? A. No, not in high school. Q. Never? A. No. Q. Okay. Did you ever use any other type of illegal drugs? A. No. Q. Any prescription drugs from someone else, like a XBIKax or percocet or — MR. HOROWITZ: Talking about high school? MR. CRITTON: High school. THE WITNESS: No. BY MR. CRITTON: Q. Since high school, you have continued to drink? A. Yes. Q. And I've seen both in the Kliman report is you continue to drink alcohol, sometimes you will drink to excess? A. Yes. Page 164 1 Was also selling drugs? A. I don't know. Q..liou ever see Jane Doe 4 use illegal drugs with A. No. Just drink. 6 Q. Okay. So you guys are best friends and - 7 A. She would never do it in front of me, because 8 I don't do it in front of her or I would never do 9 anything in front of her. 10 Q. If you do drugs, you don't do them in front of 11 her. 12 A. Well, she knows — sorry, I didn't mean to say 13 that. She knows I don't do drugs, so if she ever did 14 drugs, she would never do it in front of me, because she 15 know I was really against that in high school. 16 I was good. The most I would — like I drank, 17 but so if she had ever done drugs with him, she wouldn't 18 have done it in front of me. She would just drink. 19 Q. So if she's used Xanax and she's used pot and 20 she's used ecstasy and if she's used cocaine, any other 21 drugs, that would be news to you? 22 A. I mean I know she did like some of that. I'm 23 not going to — whatever. But I, but she wouldn't do it 24 in front of me, because she knew that I wasn't like 25 that. Page 166 1 Q. All right. And as well, you have used pot? 2 A. Yes. 3 Q. Since high school. How often do you use 4 marijuana? 5 A. I have, hardly ever. 6 Q. Xanax, have you had Xanax? 7 A. No. 8 Q. Have you ever tried cocaine? 9 A. Na 10 Q. Never? So if someone says that you have used 11 cocaine and they have seen you, that would be a lie? 12 MR. HOROWITZ: Form. 13 THE WITNESS: I don't ever remember doing —1 14 don't do drugs at all. 15 BY MR. CRITTON: 16 Q. My question is if someone says they have seen 17 you do coke, that would be a lie? 18 MR. HOROWITZ: Form. 19 BY MR. CRITTON: 20 Q. Or is it possible you did do coke and you just 21 don't remember? 22 A. I ?neon I might have tried it once, but I don't 23 do coke atoll, so 24 Q. Would the same thing be true of Xanax, that if 25 someone said they had seen you take Xanax, you may have (561) 832-7500 11 (Pages 163 to 166) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107842 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 167 tried it once or twice, but you don't do it regularly? A. That would have a lie. I don't do Xanax. Q. You've never done it? A. No, I don't do prescription chugs. Only thing I have ever done is Adderall. Q. Did you get that from friends? A. Yes. Q. Let me go to the FBI for just a minute. When did the FBI contact you? A. I believe it was my freshman year of college, I think. Q. Let's see, that would have been the '05-'06 school year? A. Yes. Q. And now you were at EM? A. Yes. Q. And that's in Orlando. Is that a community college? A. Yes. Q. I asked two questions there. It's an Orlando community college, correct? A. Yes. ..And did you get, did you graduate from A. Yes, I did. Page 169 1 finished in May of '09, correct? 2 A. Yes. 3 Q. But you are still there right now? 4 A. Yes. 5 Q. And why are you in your fifth year? 6 A. Because Pm getting a minor too. 7 Q. Whalwasot or? 8A. 9 Q. Wh.ikur minor? 10 A. 11 Q. 12 A. 13 Q. 14 get the courses that you want, you had to be there an 15 extra year? 16 A. Yeah, about. I mean I could really finish 17 this semester, but I wanted to study abroad for the 18 hospitality trip in the summer, so I'm just waiting for 19 that and then I'm graduating in the summer. 20 Q. At the end of the summer? 21 A. Yes. 22 Q. Where is the summer trip taking you? 23 A. To Italy. 24 Q. All right. Where will you go? 25 A. To Florence. And when did you decide to take a minor? I decided about a year after I got there. So that's what, an extra year? In order to Page 168 1 Q. Did you get an AA degree? 2 A. Yes. 3 Q. In what? 4 A. Just general. 5 Q. Kind of liberal arts? 6 A. Yes. 7 Q. After getting your -- when did you graduate? 8 A. Around '07. 9 Q. Spring of'07? 10 A. Yes. 11 Q. And where did you go to school after that? 12 A. 13 Q. also in 14 Orlando? 15 A. Yes. 16 Q. And have you graduated ftom IN yet? 17 A. Not yet. 18 Q. So if -- you would have started ■ in the 19 fall of'07? 20 A. Yes. 21 Q. So if you had two more years, you had two more 22 years to finish at M, assuming you took full loads? 23 A. Yeah. 24 Q. All right. So '07 to '08 and '08 to '09, so 25 if you had finished in two years, you would have Page 170 1 MR. HOROWITZ: Cool. 2 BY MR. CROTON: 3 How long will you be there? 4 For about a month. 5 And this is through.? 6 Yes. 7 And who pays for this, your parents? 8 A. I'm taking out loans for it. 9 Q. And your school, did your parents do Bright 10 Futures? Start again. Were you entitled to Bright 11 Futures? 12 A. No. 13 Q. Any form of the Bright Futures program? 14 A. No. 15 Q. There is another one. 16 A. No. 17 Q. How about did your parents do prepaid at all? 18 A. I don't know. I don't think so. 19 Q. Have your parents supported you while you have 20 been at least the four years in school? 21 MR. HOROWITZ: Form. 22 THE WITNESS: Yeah, I mean I always worked 23 too. 24 BY MR. CRITTON: 25 Q. Okay. Let me just go back to the FBI for just Q. A. Q. A. Q. (561) 832-7500 12 (Pages 167 to 170) PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107843 Page 171 1 a minute. So the FBI came to you during your freshman 2 year at IMMI, which would have been '05-'06. • 3 Did they come duSthe '05 time period, that 4 is, shortly after the police, or was it into 5 the '06 time period? 6 A. I don't remember. 7 Q. Who came? 8 A. Agent=. 9 Q. Just her? 10 A. Her and another guy. I forget his name. 3.1 Q. They drove to Orlando? 12 A. Yes. 13 Q. Where did you meet them? 14 A. Starbuck's. 15 Q. Sarno place you met Mr. Herman? 16 A. Yes. 17 Q. Did you meet anybody else there? 18 A. No. 19 Q. All right. So you are at Starbudc's. How 20 much time did you spend with the FBI at Starbuck's? 21 A. Probably about two hours. 22 Q. Who bought the coffee, do you remember? 23 A. They did. 24 Q. All right. And did they take a taped 25 statement from you at all? Page 173 1 strike that. What did they say to you first? 2 A. They just asked me what happened with Jeffrey 3 and they said that, that I had to tell them, you know, 4 exactly what happened. 5 So I admitted — they asked me ill told the 6 officers everything when they came, and I admitted that, 7 you blow, I didn't tell them everything. 8 And then so I just basically went into detail 9 with them and, you know, told them everything about what 10 happened. 11 Q. Okay. Now is it your testimony that you told 12 them the truth? 13 A. Yes. 14 Q. Okay. Did you make any errors in what you 15 told -- strike that. 16 Did you misrepresent, lie or deceive the FBI 17 in any way? 18 A. No. 19 Q. So if I got the FBI statement, you would say 20 that would be accurate even if you've testified 21 differently today? 22 MR. HOROWITZ: Form. 23 BY MR. CRITTON: 24 Q. Right? 25 A. I mean yes. I told them, I didn't tell the Page 172 1 A. I can't remember if they did. 2 Q. Did they take a statement at all? Was anybody 3 writing? A. They took a statement, yeah. Q. Did you ever sign anything? A. I think so, yes. Q. Have you ever seen the statement that you B signed that you gave to the FBI? 9 A. No. 10 Q. Have you ever requested it? 11 A. No. 12 Q. Did they ever ask you to read it? 13 A. No. 14 Q. So you don't know whether they took down 15 correctly what you told them? 16 A. Yeah, I mean I actually, I think they did have 17 a tape recorder with them. 18 Q. Are you sure? 19 A. I think so, yes. 20 Q. Did they swear you to tell the truth? 21. MR. HOROWITZ: I don't know. 22 THE WITNESS: I can't remember. Pm pretty 23 sure they did. 24 BY MR. CRITTON: 25 Q. Okay. And whardid you tell them -- let me Page 174 1 cops everything, and I pretty much told them -- it took 2 me awhile, but I told them, you know, what happened. 3 Q. Okay. After you talked with the FBI on that 4 occasion, did they tell you that you might have the 5 ability to bring a civil lawsuit for money? 6 A. No. 7 Q. Did they mention anything about a civil 8 lawsuit? 9 A. No. 10 Q. Did they mention anything about any criminal 11 charges that they were investigating? 12 A. Yes. 13 . Q. Did they tell you why they were investigating 14 criminal charges, that is, why it was a federal matter 15 as distinct from a state matter? 16 A. Because I think he, I guess 'think it got 17 turned down by the state or something, because he hired 18 great lawyers that represented him well, and I don't 19 think — I think the judge turned it down. So they, the 20 federal government picked it up, because they didn't 21 think it was fair, the sentence the state gave him. 22 Q. You mean the FBI said that to you? 23 A. Well, 'think Mars what they — something 24 Ince that, l don't know. 25 Q. You could have only gotten that idea from (561) 832-7500 13 (Pages 171 to 174) PROSE COURT REPORTING AGENCY,. INC. (561) 832-7506 EFTA01107844 Page 175 1 them, because you didn't know at the time, did you? 2 A. Yeah, they just said it was a federal 3 investigation now, but now I know why. 4 Q. Did, at that time did they mention IM 5 at all, the assistant US attorney? 6 A. No, I don't think so. 7 Q Did you ever get any papers from either the 8 FBI or from the US attorney's office? 9 A. I don't remember. 10 Q. When you said — culler today you said 11 called. And then I said and you saids 12 How many times have you spoken with 13 14 A. I think just once when she pretty much wrapped 15 up the whole case. 16 Q. When you say she wrapped up the case, at the 17 time that she called you to tell you about what was 18 going on, what did she tell you? 19 A. I don't remember exactly. She just said about 20 what was, told me what happened with the criminal case 21 or what was going on with it or something. 22 MR. CRITTON: Okay. Let's go about ten more 23 minutes. Is that all right? 24 MR. HOROWITZ: Are you okay? 25 THE WITNESS: Yes. Page 177 1 Q, M? 2 A. Just the letter 3 Q. Okay. Do you have any siblings? 4 A. Just a brother. 5 Q. How old? 6 A. I think he's like 36, 37. 7 Q. Are you close? 8 A. Thirty-seven. No. I mean he lives in a 9 different state, so — 10 Q. You are how old now? 11 A. I am 22. 12 Q. So there is a 14-year difference between the 13 two of you? 14 A. I thinlc, yeah. I think he's like 36 or 37. 15 Q. So when he was almost out of high school, y ou 16 were only four years old? 17 A. Yeah, I guess so. 18 Q. He would have been about 18, you would have 19 been about four, if there is a 14-year difference. 20 A. I remember him, he was always in college. He 21 was off to college and he would come home. 22 Q. Where did he go to college? 23 A. He went to IUP. 24 Q. IUP? 25 A. Uh huh. Page 176 BY MR, CRITI'ON: 2 Q. Tell me, you were born in Pittsburgh? 3 A. Yes. 4 Q. You moved to Florida when you were a freshman 5 in high school? 6 A. Yes. 7 Q. Which would have been the 0 — 8 A. 2000. 9 Q. I'm sorry, 2000? 10 A. Yes. 11 MR. HOROWITZ: That doesn't sound right. 12 THE WITNESS: Or 2001, I think. 13 MR. HOROWITZ: Fm sorry. 14 THE WITNESS: Yeab, I think it was 2001. 15 . MR. HOROWITZ: You are right, Tin wrong. 16 BY MR. CFUTTON: 17 Q. And did you start — so it would be 2001 18 through May approximately of 2002, right? 19 A. (Witness nods head up and down.) 20 Q. Would have been your freshman year? 21 A. I believe so. 22 Q. All right. Where did our is move to? 23 A. They moved to 24 Q. What was the address? (561) 832-7500 Page 1.7 1 Q. What's that? 2 A. That's in Indiana somewhere. 3 Q. What does he do fora living? A. Hes a cop. 5 Q. When the Palm Beach police officers called 6 you — let at strike that 7 Does your brother know that you were involved 8 with Mr. Epstein or that you are involved in a lawsuit' 9 A. I've never told him, but unless my parents 10 told him, I don't think so. 11 Q. When the police called, did you ever think of 12 calling your brother, who was a police officer at the 13 time? 14 A. No. 15 Q. Why not? 3.6 A. Because we're not, we don't really share 17 everything. Like he's a guy. I didn't want him to find 18 out what happened with Jeffrey. 19 Q. Your parents, when you moved down here, 20 describe your house for me that you moved in. The house 21 on Road, did you live there during all four years in 22 high school? 23 A. Uh huh. 24 Q. Describe it forme. How big a house was it? 25 A. It was just late a three-bedroom house. 14 (Pages 175 to 178) PROSE COURT REPORTING AGENCY INC. (561) 832-7506 EFTA01107845 B 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 179 1 Q. Three bedroom, three bath, two bath? 2 A. Yeah. 3 Q. Did you have your own room? 4 A. Yes. 5 Q. Okay. And when you were what, 15, I saw in Kliman's report you got your own car, a red Cavalier? 7 Yes? A. Yes. Q. Who bought that for you, Mom and Dad? A. Yes. Q. Brand new car? A. No. It was used. Q. And did you have that so you could use it during high school? A. Yes. lad you take that car with you then to A. No. Q. Did they give you another car? A. I got into a car accident and the car got totaled. And so yeah, so they got me a Mustang that I use. Q Do you still have that today? A. Yes. Q What year is that? Page 181 1 A. Yes. 2 a...1 saw someplace else, does he have a. too? 4 A. Yeah, me and him, we had started it when I was 5 younger, but we just kind of restarted it back up 6 rece.fu So we just sel It's like an online website. 8 Q. So you order them from like a Cushnut or 9 whoever happens to be — 10 A. Buyers. 11 ▪ i.Who did yousupply — do you supply toe or individuals? 13 A. Just individuals. Like it's all online. 14 Q. So you've never had hie a warehouse where you 15 actually buy and sell means? 16 A. No. 17 Q. It's strictly parts? 18 A. And accessories, yes. 19 Q. How about your mom? Did she work outside the 20 home or was she a stay-at-home morn? 21 A. She worked at a craft store when I was 22 younger, and other than that, she was home. 23 And she just recently got a job, but she's 24 mostly home. 25 Q. What does she do now? Page 180 Page 182 1 A. She works at a craft store again. 2 Q. Okay. But basically your dad was the sole 3 source of support for you and your family? 4 A. Yes. 5 Q. And th