EFTA01076383

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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA/JOHNSON 
JANE DOE NO. 2, 
Plaintiff, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
VOLUME I OF II 
Related cases: 
08-80232, 08-08380, 08-80381, 08-80994, 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80591, 09-80656, 09-80802, 09-81092 
VIDEOTAPED DEPOSITION OF 
JANE DOE NO. 5 
Friday, February 26, 2010 
8:07 - 3:44 III. 
250 Australian Avenue 
Suite 1500 
West Palm Beach, Florida 33401 
Reported By: 
Cynthia Hopkins, RPR, FPR 
Notary Public, State of Florida 
Prose Court Reporting Services 
Job No.: 1312 
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APPEARANCES: 
On behalf of the Plaintiff: 
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STUART S. MERMELSTELN, ES
laRMELSTEEN & HOROWITZ, M. 
18205 Biscayne Boulevard 
Suite 2218 
Miami 
Phone: 
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E-mail: 
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On behalf o the 
en 
t: 
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ROBERT D.CRJTTON,JR,ESQUIRE 
MARK T. LUTHER. ESQUIRE 
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BURMAN, CRITTON, LUTHER & COLEMAN, UP 
303 Banyan Boulevard 
Suite 400 
West P 
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• ride 33401 
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Phone: 
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ALSO PRESENT: 
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&eche Quimby, Videographer 
Visual Evidence, Incorporated 
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PROCEEDINGS 
Deposition taken before Cynthia Hopkins, 
Registered Professional Reporter and Florida 
Professional Reporter, and Notary Public in and for 
the State of Florida at Large, in the above cause. 
THE VIDEOGRAPHER: This is the 26th day of 
February, 2010. The time is 829E. This is 
the videotape deposition of Jane Doe No. 5 in 
the matter of Jane Doe No. 2 versus Epstein. 
This deposition is being held at 250 
Australian Avenue South, West Palm Beach, 
Florida. 
My name is Sascha Quimby. I'm the 
videographer representing Visual Evidence, Inc. 
Will the attorneys please announce their 
appearances for the record. 
MR. MERMELSTEIN: Stuart Mermelstein for 
Plaintiff Jane Doe No. 5. 
MR. LUTTIER: Mark Luther for 
Jeffrey Epstein. 
MR. CRITTON: Bob Critton for 
Jeffrey Epstein. 
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INDEX 
EXAMINATION 
DIRECT CROSS REDIRECT 
JANE DOE NO. 5 
BY MR. CRITTON 5 
NO EXHIBITS MARKED 
Pag 
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Thereupon, 
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• (JANE DOE NO. 5) 
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having been first duly sworn or affirmed, was 
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examined and testified as follows: 
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THE WITNESS: Yes, I do. 
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DIRECT EXAMINATION 
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BY MR. LUTTIER: 
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Q. Good morning, ma'am. My name is 
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Mark Luttier, and we're here today for purposes of 
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taking your deposition. Could you tell us your full 
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name. 
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A. Jane Doe No. 5. 
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Q. And how do you spell your middle name? 
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A. (Witness spells her middle name.) 
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Q. Okay. Ms. Doe No. 5, have you ever been 
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deposed before? 
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A. No. 
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Q. That's this process that we're doing here 
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today. 
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A. No. 
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Q. Okay. And let me explain a little bit 
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about the process. First of all, you understand 
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you're under oath? 
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A. Yes. 
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Q. Okiy. I'mxing to ask you uestions, and 
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you're going to have to give a verbal response 
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because this court reporter is going to transcribe 
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everything that you say. 
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A. Okay. 
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Q. So you can't shake your head and you've to 
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to actually say a word so she can get it down. 
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A. Okay. 
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Q. If you don't understand a question that I 
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ask, tell me you don't understand it and I will 
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explain it for you. 
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A. Okay. 
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Q. Okay. If you answer a question, I will 
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assume you understood it. 
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A. Okay. 
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Q. Okay. If during the deposition you want 
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to take a break, just let me know, and I'll be happy 
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to accommodate you. 
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A. Okay. 
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Q. If during the deposition you think that a 
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previous response that you gave me needs to be 
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amended or changed in any way, just tell me, you 
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know, I just thought of something. I need to go 
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back and correct something or supplement, whatever 
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you think has to happen. Okay? 
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A Okay. 
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A. 1 don't have an accurate date. 
Q. Well, approximately. 
A. It was before I started school. 
Q. And when you say "started school," what do 
you mean? 
A. Started cosmetology school. I just finished. 
Q. And what cosmetology school are you 
referri 
A. 
Q. And when did you start that? 
A. Last February. 
Q. That would be February 2009? 
A. Yes. 
Q. So sometime prior to 2009 
a 
psychiatrist in Florida who prescribe 
for 
you? 
A. No. My recent visit to 
was in 
Florida. I was in Virgina at the time before I went to 
Ill
id Virginia 
that's where I got my first prescription of 
e 
n 
Q. Okay. Who 
ysiclan who 
on 
you? Would it be 
a Dr 
A. It, l'm not sure, because I was seeing a 
psychologist and a psychiatrist, so I wouldn't know. I 
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Q. Are you presently under any kind of 
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medication? 
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A. No. 
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Q. In the last six months have you been under 
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any medication? 
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A. Yes. 
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Q. What medication have you been under in the 
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last six — 
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A. 
. 
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Q. — months? 
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AL =B. That's it. 
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Q. And what's the level of= 
that is 
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prescribed for you? 
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A. Twenty and then it went up e. 
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Q. Okay. Most recently it was 
milligrams? 
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A. Yes. 
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Q. And how fte
; you prescribed to take 
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.-milligrams of
ab
er 
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A. I took it once a day, once in the morning. 
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Q. And who prescribed that drug? 
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A . It was a new doctor in Florida. I do not 
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recall the name. 
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Q. Was, what kind of doctor was it? 
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A. Psychiatrist. 
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Q. And when was it first prescribed fiat. you? 
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. „ 
Page 9 
can't put a name to the face of who it was. 
Q. This is, you were seeing a psychologist 
and a psychiatrist? 
A. In Virginia. 
Q. Okay. What psychologist were you seeing? 
A. I don't remember. 
Q. And when was it you were seeing this 
psychologist and psychiatrist in Virginia? 
A. Around the same time before I started school 
in Virginia. 
Q. So were you seeing than in January of '09? 
A. Yes. 
Q. I want to refer to — I'm going to read to 
you your answers to interrogatories that you gave in 
this case which were dated by you January 26th, '09. 
Interrogatory 12 asks you to list all the 
physicians —
A. Uh-huh. 
Q. — that you had been to. I'm going to 
show that list to you. 
A. Okay. 
Q. You see Interrogatory 12 there? You don't 
mind my hand, my highlighting. And I think there's 
one name on the next page. 
A. Okay. 
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Q. So, can you tell me which of these people 
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is the psychologist that you were seeing in 
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Virginia? 
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A. I don't think ifs listed. 
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Q. Can you tell me which of those physicians 
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is the psychiatrist that you were seeing in 
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Virginia? 
A. I think it's this one, 
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Q. Read the, the name. 
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A. 
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Q. 111111..,ame? 
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A. It doesn't say. I don't know. 
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Q. Well, how long did you see this 
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psychiatrist? 
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A. I saw her — I had two visits. I'm guessing. 
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That's not 100 percent accurate. 
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Q. Okay. 
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A. That was just — 
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Q. Okay. Would you pass me those 
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interrogatories so I can see if you have a date 
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here. All right. In answer to 8 you said that —
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what you answered was, in response to an 
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interrogatory that asked you to list all of the 
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physicians and medical facilities or other health 
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care providers including psychiatrists, 
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right? 
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MR. MERMELSTEIN: Objection to form. 
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THE WITNESS: I, I don't, I don't 
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remember, honestly. 
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BY MR. LUTHER: 
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Q. Okay. Well, let me ask you this: Do you 
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have a, an absolute specific recollection that you 
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did, in fact, see a psychiatrist --
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A. Yes. 
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Q. — and psychologist in Virginia? 
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A. Yes, yes. I just don't remember. 
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Q. And the psychologist that you saw in 
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Virginia was male or female? 
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A. Psychologist Was it -- they were both 
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females. 
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Q. Okay. Do you know the difference do 
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you know there's a difference between a psychologist 
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and a psychiatrist? 
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A. Yes. 
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Q. Okay. I'm now asking you about the 
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psychologist 
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A. Okay. 
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Q. There was a female psychologist. 
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A. Uh-hub. 
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Q. And do you remember her name? 
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psychologists, mental health counselor, et cetera, 
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that you had been treated for in the last ten years. 
In Number 8, you list 
and you give a PO Box. And the 
interrogatory tells you to state, as to each the 
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dates of the examination and the condition or injury 
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for which you were examined. And what you put was 
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December 2007, dermatitis. 
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Now, you understand dermatitis is a 
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skin condition? 
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A. Oka 
Well then I must be confused because 
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I did have 
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Q. Okay. So now you're saying 8 is not the 
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psychiatrist that you saw in Virginia? 
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A. No, no. 
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Q. So, in answering your interrogatories, you 
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have — you did not give us either the name of the 
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psychologist or the psychiatrist who treated you in 
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Virginia? 
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A. I guess not. No, I guess not. 
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Q. Pm not, I'm not quibbling with you over 
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words, but when, when we hear the word "guess," you 
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know, it makes us a little nervous. So, when you 
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say you guess riot, you definitively know you didn't, 
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A. No. 
Q. Do you remember her first name, her last 
name, any combination of the two? 
A. No, I don't 
Q. Do you have any records from which you can 
determine that name? 
A. At home. 
Q. Home, meaning what, here in Palm Beach 
County? 
A. Home in Virginia. 
Q. Okay. Do you have -- in your wallet, for 
example, do you have a card from, from this person? 
A. I could look if you would like me to. 
Q. Yeah, that would help us, if you would, 
please. 
MR. WrITER: And, Stuart, I invite you, 
if you know the answers to this, I invite you 
to go ahead and chime in. 
MR. MERMELSTEIN: Well —
MR. LUTTlER: I'm not looking — l'm 
looking to get to the answer. 
MR. MERMELSTEIN: I know she, she — this 
whose name you mentioned is in response 
lt.revious Interrogatory Number II. 
MR. LUTT/ER: And I don't think that's a 
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psychologist. 
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MR. MERMELSTEIN: That's a psychiatrist. 
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MR. LIMIER: I don't think it's a 
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psychiatrist. 
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MR. MERMELSTEIN: It's an I., 
right? 
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That would be a psychiatrist. 
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MR. LUTTIER: Okay. That would be, you 
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know, from the record that I'm looking at —
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okay. We'll get to that. 
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MR. MERMELSTEIN: So, yeah, I don't know 
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if that's the psychiatrist that she's referring 
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to or not. 
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THE WITNESS: No, not on me. 
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BY MR. LUTTER: 
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Q. Okay. Do you have a cellphone that lists 
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the phone number? Do you have a phone number? 
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A. I have a cellphone. 
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Q. But do you keep her phone number in there? 
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A. Well, since my husband's in the military, I go 
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back and forth from Florida to Virginia a lot, and 
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that's why I have to change constantly 'cause if he goes 
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on deployment, I come to Florida. So that's the problem 
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right now. That's why I don't remember. 
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Q. I think you're checking your cellphone to 
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see if you have the phone number there? 
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give you the original back, and that way it 
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won't be on the record. We'll just make a copy 
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so ifs not in the court file. 
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BY MR. LUTTIER: 
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Q. Okay. All right. So, let me go back. 
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The — we were talking about the female psychologist 
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in Virginia. You don't {mow her name or number. Do 
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you recall when you first went to see this 
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psychologist? 
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A. I went with my husband. No. 
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Q. Okay. You, You recall that your first 
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visit with her was one in which your husband went 
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with you? 
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A. Yes. 
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Q. Okay. Obviously, you were in Virginia at 
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the time. Did, did you go to this psychologist 
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shortly after you moved to Virginia? What I'm 
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looking for now is maybe the year. 
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A. Let me think I don't know. I can, l can 
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approximate it I just —
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Q. What's, what, what's your best estimate of 
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when you moved to Virginia? 
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A. When I moved to Virginia was 2006, 2007. 
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Q. Okay. And when you moved to Virginia in 
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2006, what time of the year was it? 
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A. Yes. I have a doctor in my phone. I don't 
know if it's the one that I saw here, while my husband 
was on deployment, for my 
I can give you the 
number. 
Q 
A. Ifs 
Q. Do you have a name associated with it? 
A. No. 
Q. You just have a — 
A. I just have it under my doctor. I can get all 
this information from my insurance company -
Q. Okay. 
A. 
or my health care. 
Q. Yeah. What, what insurance company is 
that? 
A a. 
Q. Okay. Do you have the card —
A. Yes. 
Q. —that will give us the number? Is that 
the military insurance? 
A. Yes, 
Prime. 
MR. LIMITER: Okay. Do you have a way to 
make a copy? 
THE COURT REPORTER: Yes. 
MR. LUTTIER: Okay. We're, we're going to 
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A. I moved there in January of, January of 2007. 
Q. January of 2007. 
A. Yes, because I got married in — yeah. 
Q. You got married when? 
A. December 2006. 
Q. Okay. So you know you went to Virginia 
shortly after your wedding? 
A. Yes. 
Q. Were you married down here min Virginia? 
A. Down here. 
Q. In Palm Beach County? 
A. Yes. 
Q. Okay. 
A. No, Broward County. I'm sorry. 
Q. Okay. All right. Approximately how long 
was it after you moved to Virginia that you first 
went to this female psychologist? 
A. Probably, Pm guessing, five to six months. 
Q. Okay. 
A. It's not accurate. 
Q. And, and why were you and your husband --
why did you and your husband go to this 
psychologist? 
A. Marital problems. 
Q. And specifically what were the marital 
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problems? 
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A. Fighting. 
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Q. And how many visits did you, did either 
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you alone or you and your husband have with the 
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psychologist? 
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A. Two to three. 
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Q. And were there were those visits with 
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some degree of regularity? For example, you went 
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once a week for a month, or you went for once a 
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month for two months, or... 
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A. I think it was once a month. 
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Q. Okay. So there would be approximately a 
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three-month period -
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A. Yes. 
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Q. — over which there would be about three 
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visits? 
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A. That's not accurate, so I'm just saying. 
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Q. If you know it's not, what's your most 
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accurate recollection of how many visits you had? 
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MR. MERMELSIEIN: Objection to form. 
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THE WITNESS: I mean we went three 
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times — I don't know. 
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BY MR. LIMIER: 
24 
Q. You were about to say you went three 
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times, what? 
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Q. Okay. And each of those visits was about 
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marital problems with your husband? 
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A. When he came, yes. When he was present at the 
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doctor's office with me? 
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Q. Right. 
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A. It was about us. 
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Q. Okay. How about on the — you say you 
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went one time alone. 
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A. Yes. 
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Q. What was that visit about? 
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A. Me and my personal life. 
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Q. And specifically wises about you and your 
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personal life? 
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A. Things I've been through. 
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Q. Okay. For what, what was your primers 
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complaint or purpose for you going alone on that 
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visit to the psychologist? 
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A. That I was depressed. 
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Q. So, the, the, the thing that caused you to 
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go to her alone was because you felt that you were 
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depressed? 
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A. Yeah. 
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Q. And what is it that you specifically 
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discussed with her about your personal life? 
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A. It was about my husband, it was about family, 
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A. I don't lcnow. rut not going to give an answer 
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when I'm not 100 percent sure of how many times I 
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vvent 
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Q. I want your --
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A. - or how many, how many — like a time frame. 
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Q. Well, I, I don't want you to just pick a 
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number out of the sky, but I want your best 
8 
estimate. I mean, if I had these, if I'd have had 
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this doctor's name, I would have subpoenaed the 
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records and rd know exactly, but I am trying to 
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find out who this doctor is which is why we sent the 
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interrogatories. 
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A. I'm going to say over three months. 
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Q. Okay. So your best estimate is —
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A. My best estimate. 
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Q. 'That's fine. And on each visit that you 
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went to this psychologist, was it you and your 
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husband? 
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A. I think there was, !went one time alone. 
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Q. In addition to the three with your 
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husband? 
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A. Uh-huh. 
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Q. So you maybe had — your best estimate is 
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four visits, correct? 
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A. Three to four. 
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Jeffrey Epstein was mentioned 
Q. And how do you recall that Jeffrey Epstein 
was mentioned? 
A. What do you mean? 
Q. What is it that makes you recall that you 
know that Jeffrey Epstein's name was mentioned? 
A. Because I remember mentioning it to her, all 
the things I went through in my life. 
Q. Okay. Anything else that you recall? 
A. Just about my, my past —
Q. All right. 
A. — you know. 
Q. And this was a 45-minute visit? 
A. Yeah. I'm pretty sure. 
Q. Did you ever go back to her after the 
visit that you went alone? 
A. I think, yeah, after I went to her alone, my 
husband and I went one more time after that. 
Q. But the visit that you and your husband 
had was about your marital difficulties. 
A. Yes. 
Q. And then after that last visit between you 
and your husband and her, you didn't go back? 
A. No. 
Q. So, somewhere in the ear 2007 
tut 
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going to her? 
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A. Yeah. 
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Q. All right. 
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A. I would say. 
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Q. Do you recall where this doctofs office 
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was located? 
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A. No. 
Q. I mean, do you — I don't !mow, was it in 
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the same town that you were living in in Virginia? 
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A. No, it was a different area because I remember 
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it was a little bit of a drive. 
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Q. When you say "a different area," what city 
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was it in? 
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A. I don't remember. 
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Q. Well, how long did you live in this area 
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of Virginia? 
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A. I lived there two years, around two years. 
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Q. Okay. And I assume in that two-year 
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period you became familiar with the municipalities 
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and the cities that were located in your immediate 
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vicinity. 
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A. No. I am horrible with direction. 
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Q. Okay. Do you have, do you have any notes 
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or anything from, that your visits with this 
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psychologist 
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Q. Well, these were 45-minute sessions, 
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right? 
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A. Yeah, but I didn't know anybody in Virginia. 
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It wasn't hike I had a babysitter. 
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Q. Well, in the two years that you lived in 
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Virginia, would it be a correct statement that there 
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were times that, that you left your daughter with 
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somebody else while you did things? 
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A. No, I took my daughter. 
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Q. When you went, when you went the one time 
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to the psychologist did you take your daughter with 
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you? 
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A. Yeah, I did. 
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Q. Okay. Because your daughter at that time 
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was less than a year old, right? 
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A. Yeah, she was young. 
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Q. All right. So having your daughter didn't 
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prevent you from going to a psychologist? 
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A. No. I mean, no, but it was too hard. 
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Q. Well, you, you went the one time, you took 
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her with you. 
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A. It was still hard. 
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Q. And I assume that at age less than one she 
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slept a fair amount of time? 
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A. Uh-huh 
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A. I don't have any. Personally, I don't, I 
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didn't take any notes. 
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Q. Okay. Did the psychologist have any tasks 
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that she asked you to do? Like, sometimes a 
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psychologist will say, you know, write something out 
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or something like that. 
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A. No. 
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Q. So you have no documentary materials at 
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all concerning your visits with this psychologist? 
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A. No. 
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Q. Is there any record — other than your 
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insurance company which I assume paid for part of 
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this psychology visit. 
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A. Paid for all of it 
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Q. Paid for all of it. Is that — do you 
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have any other record from which you can determine 
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who this psychologist was? 
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A. No. 
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Q. Did the psychologist at your last meeting 
20 
advise that she didn't want to see you anymore and 
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that your sessions were done? 
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A. No, I just didn't go back. 
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Q. Okay. Why, why didn't you go back? 
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A. Because I have a two-year-old daughter, and 
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it's just hard for me to take the time to go. 
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Q. That is your daughter --
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A. — she did, but she also had colic, so it was 
not easy. 
Q. Okay. But you'd done it once before. The 
doctor, for example, didn't say, you don't come here 
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with your daughter? 
A. No. 
Q. The doctor didn't say, I don't want to see 
you anymore? 
A. No. 
Q. You made the decision you weren't going to 
go back? 
A. Yeah. 
Q. Okay. And your testimony is that in a 
two-year period that you lived in Virginia, you 
never left your daughter with anybody else? 
MR. ME RMELSTF_1N: Objection to form. 
THE WITNESS: If you mean my mother-in-law 
that came up and watched her from —
BY MR. LUTTIER: 
Q. I mean anybody. 
A. Yeah. 
Q. Yeah what? 
A. Yes, my mother-in-law came to Virginia to stay 
a couple of times from Florida. 
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1 
Q. Okay. 
2 
A. So when she was there, she would watch my 
3 
daughter so my husband and I can go out, you know, and 
4 
spend some time together. 
5 
Q. Yeah. 
6 
A. But she wasn't there on the occasions of, you 
7 
Imow, when l had to go to a doctor session. It wasn't, 
8 
you know, it's not — I didn't have somebody on a 
9 
schedule there — 
10 
Q. During this — 
11 
A. — that could watch my daughter. 
12 
Q. During this two-year period that you were 
13 
in Virginia, was your husband living with you? 
14 
A. Yes. 
15 
Q. Were you living on a military base? 
16 
A. No. 
17 
Q. Okay. And was, was he in the military at 
18 
the time? 
19 
A. Yes. 
20 
Q. And did he have hours that he went to 
2/ 
work? 
22 
A. Yes. 
23 
Q. Okay. And when would he typically work; 
24 
what was his schedule? 
25 
A. His schedule often changes since he's in the 
Page 28 
1 
Q. You said that you — I understand that you 
2 
went with your husband to the psychologist, but you 
3 
said you went to the psychologist one time alone to 
4 
talk about your problems. 
5 
A. Yes. 
6 
Q. There were times that your husband was 
7 
home from work that he could have watched your 
8 
daughter, and you could have gone back to the 
9 
psychologist, if you chose to, to discuss whatever 
10 
problems you wanted to discuss with her, right? 
11 
A. I could have. 
12 
Q. Okay. And the insurance company was 
13 
paying whatever those charges were? 
14 
A. Uh-hum. Yes. Sony. 
15 
THE COURT REPORTER: Thank you. 
16 
BY MR. LUTTIER: 
17 
Q. Let's talk now about the psychiatrist that 
18 
you said you saw in Virginia. 
19 
A. Yes. 
20 
Q. But first of all, let me go back and ask 
21 
you a question about the psychologist. How did you 
22 
select that female psychologist that you saw in 
23 
Virginia? 
rovides -- they accept. 
A. It was just offered through
 page 
25 
that, you know, p 
24 
Page 27 
military. He can work day, night, or mid check. I 
don't know the exact schedule he was on at that point in 
3 
time, but day check is 6:00 to 2:30-3:00, depending on 
4 
what his boss wants to keep them. Mid-check is —
mid-check is all night long. I don't know the exact 
6 
time, but ifs all through the entire night until 
7 
morning. And then the night check is --1 think it's 
8 
like 2:00 or 3:00 to 11:00 at night. 
9 
Q. Okay. So either the mid check or the 
10 
night check, he was home during the day? 
11 
A. Yeah. 
12 
Q. All right. So, there were times during 
13 
this two-year period that your husband was home and 
14 
available to watch your daughter? 
15 
A. Yeah, but I wouldn't, you know, I wanted to go 
16 
with my husband. 
17 
Q. Well, these were visits that you went to 
18 
the psychology — you went alone, right? 
19 
A. Psychiatrist or —
20 
Q. Psychologist 
21 
A. Psychologist? 
22 
Q. We're still on the psychologist. 
23 
A. Okay. The psychologist was also for our 
24 
marriage, so I wanted him to go with me most of the 
25 
time. 
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Page 29 
Q. Okay. Okay. Now, you said you went to a 
female psychiatrist in Virginia as well. 
A Yes. 
Q. Was this during the same period of time 
that you went to the psychologist? 
A. That was after. That was before my husband 
was about to leave on his deployment. 
Q. Okay. 
A. I came — 
Q. When was your — 
A. Well, I came to Florida in January. 
Q. January of - 
A. Of last year. 
Q. — of '09? 
A. Yes. So, it was probably a couple of months 
before that that I went and saw her. 
Q. Okay. And how did you select that 
psychiatrist? 
A. The same way, off the Internet that the 
providers —
And what city was she located in? 
I don't know. 
Do you remember where her office was? 
No. 
How many times did ou see her? 
Q. 
A. 
A. 
Q. 
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Page 32 
1 
A. Twice. 
2 
Q. Do you, do you recall about over what 
3 
period of time you saw her? Like, was it two times 
4 
in a month? 
5 
A. I think it was once a month. 
6 
Q. And for what reason did you initially go 
7 
see her? 
A. Fa
-
9 
Q. And, and do you mean that when you went to 
10 
her you already knew that what ou wanted to do is 
11 
go get a prescription f 
12 
A. Not enact] 
, but something to help me 
13 
concentrate. 
14 
Q. And so, so your, as they would say, chief 
15 
complaint that caused you to seek out her aid was 
16 
you wanted something to help you with your 
17 
concentration? 
18 
A. Yes. 
19 
Q. Was there any other problem or, or 
20 
situation that you were seeking out her counsel for? 
21 
A. There was the second visit I mentioned that I 
22 
had, 
depression, and that's when she prescribed me 
23 
to try. 
24 
Q. How — did you have sessions with her when 
25 
you saw her on these two occasions, or did you 
1 
A. I did, but I'm not on it right now. 
2 
Q. Okay. When you say "right now," do you 
3 
mean literally like today? 
4 
A. As in the past, Ince, as in the past week I 
5 
stopped taking it. 
6 
Q. OW. And why did you stop taking it? 
7 
A. Because I'm pregnant 
8 
Q. Is it contraindicated; that is, did your 
9 
doctors tell you if you're pregnant, don't take it? 
10 
A. I just — I haven't seen lidgfayet, but I 
11 
just know ifs not good to takelMI while you're 
12 
pregnant. 
13 
Q. Well, I suppose the first thing we should 
14 
do is congratulate you on being pregnant 
15 
A. Oh, thanks. 
16 
Q. Is this a planned pregnancy? 
17 
A. Not necessarily. 
18 
Q. Are, are you happily pregnant? Let me ask 
19 
you that. 
20 
A. Yeah, I mean, ifs going to be hard, but —
21 
two kids, young age, I mean. We'll see what happens. 
22 
Q. You're, you're sure you're pregnant? 
23 
A. I took four tests. 
24 
Q. Okay. Have you been to the doctor to 
25 
have — 
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Page 31 
simply go in and get a prescription? 
A. The fast time !just went in and got a 
2 
prescription. The second time I spoke to her about, you 
3 
know, depression medication. 
4 
Q. And, and what did you tell her about your 
S 
depression? 
6 
A. I just told her that I'm depressed. I'm not 
7 
happy. And I asked her what would be the best, you 
8 
know medication to try, and she told me to try 
9 
10 
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15 
16 
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19 
20 
21 
22 
23 
24 
Q. This female psychiatrist Mat you saw in 
Virginia, was she the lust medical doctor to 
prescribe 
for you? 
A. Yes. 
Q. And was that initially prescribed at a 
level of 
a day? 
A. I think she started me off lower than that. 
Q. Okay. 
A. I don't, I don't recall what my —
Q. Okay. 
A. 
first dosage was. 
Q. Have you taken Adder, 
continuously since the time that you saw this female 
psychiatrist in Virginia in 2007 right up until 
today? 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Page 33 
No, it's not —
Early pregnancy? 
Yes. 
Okay. 
Very early. 
Does, does your husband know about it yet? 
Yes. 
Q. Okay. ill" 
So, so you have, you 
stopped taking 
last week because of your 
own decision that you didn't want to take that while 
you were pregnant? 
A. Yes. 
Q. Not because a physician said you couldn't? 
A. Yes. 
Q. All right. And did you find the 
was helpful to you? 
A. Yes. 
Q. It allowed you to concentrate better? 
A. Yes. 
Q. And had you had — was there a time in the 
past — you have a brother that, that has, has 
Attention Deficit Disorder? 
las 
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Page 34 
Q. And
 
I think your brother at one time was 
on 
the medication. 
A. Yes. 
Q. And you had taken some of that —
A. Yes. 
Q. -- when you were maybe in high school? 
MR. MERMELSTEIN: Make sure you let him 
finish his question before you answer. 
THE WITNESS: Oh, okay. 
BY MR. LUTTIER: 
Q. It wass 
like in high school you took 
some otitis 
A. Yes. 
Q. And you found that it was effective in 
terms of allowing, helping you to concentrate? 
A. Yes. 
Q. Is that how you knew that when you went to 
se.rthe
chiatrist in Virginia that you wanted 
A. Yes. 
Q. Is there — for what 
riod of time did 
you take your brother's 
A. It was just for a short period of time. 
Q. Lfice less than a month? 
A. Yes. 
Page 36 
1 
alternative school. 
2 
Q. Okay. Typically classes here graduate in 
3 
June of a year. 
4 
A. Okay. 
5 
Q. So, when you say you got it late that 
6 
year, did you get it —
7 
A. Late. 
8 
. Q. — within the same calendar year that you 
9 
would have received it had you —
10 
A. I'm pretty sure it was in 2006. I was 
11 
supposed to graduate 2005. 
12 
Q. Okay. So, we know that in June if, if you 
13 
had stayed in school for each year and progressed by 
14 
passing every year, you would ordinarily have 
15 
graduated in June of '05? 
16 
A. Yes, Ida* stay back. 
17 
Q. No. Yeah,1tmderstand that 
18 
A. Okay. 
19 
Q. Pm just going back to your birthday. 
21 
That, that would mean that that would put you then 
2 1 
at 18 years of age June of '05 when you graduated? 
22 
A. Yes. 
23 
Q. So that would put you as a sophomore, 16 
24 
years of age? 
25 
A. Yes. 
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Page 3 
Q. Okay. Is there — and that would have 
been when you were how old? 
A. I was in high school. 
Q. Freshman year? 
A. No. 
Q. Were you living in Jupiter at that time? 
A. No. This was probably my sophomore year. 
Q. Which would have made you 15 years old? 
A. Yeah, 15 or 16. 
Q. Okay. Your date of birth is =MS 
A. Uh-huh. 
Q. So do you know, do you know. in your 
sophomore year how old you were? 
A. No. 
Q. Okay. Let's go --
A. I was — 
Q. — let's go backwards. You, you got a 
diploina from the Palm Beach County school system. 
A. Yes. 
Q Did you get that in the same year that, 
that you would have graduated from --
A. No. 
Q. — high school class? 
A. I 
that late because I went to an 
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Page 37 
Q. Okay. So you, your best recollection is, 
you, you had taken your brother's 
sometime 
when you were about 16 years of age.
A. Yes. 
Q. And then you took it for a month or two? 
A. For about a little less than a month. 
Q. Okay. Is there -- why did you not follow 
up, if you found it to be effective, with a 
physician to get a prescription of your own? 
A. !just didn't want to. I, I don't know why. 
Q. Is — do you recall what it is that caused 
you in 2007 when you went to sec the psychiatrist in 
Virginia to ask for the first time for 
A. I didn't ask for 
specs
went in and asked her, yen
.,w, 
what I, what she would, 
T I
I1 
you know, refer to me. And I mentioned a couple of 
pills, but the reason is because I was going back to 
school. 
Q. Okay. And, and you had arrived at the 
decision at that point you thought some kind of 
medication would assist you in being able to 
concentrate better? 
A. Yes. In school, yes. 
Q. 
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Page • 
1 
A. Yes. 
2 
Q What doctor diagnosed you? 
3 
A. I don't blow. I don't recall. 
Q. What — where was 
A. I changed doctors. 
Q. Do you recall about how old you were when 
the doctor diagnosed you? 
o 
A. Yes. When I first started seeing the 
9 
psychiatrist in Virginia 
10 
Q. Okay. What doctor? Was it the, the 
11 
psychologist that you were seeing in Virginia that 
12 
you went to with ur husband that diagnosed you as, 
13 
as 
—
14 
A. The psychiatrist. 
15 
Q The psychiatrist, the same one that 
16 
d — the same one that prescribed the 
17 
to ou made a formal diagnosis that 
19 
20 
21 
22 
23 
24 
25 
A. She didn't tell me that, but don't they have 
to do that themselves to give you the medication? 
Q I don'tlatow. Pills and doctors these 
days, I don't — 
A. I mean, I would hope so. I wouldn't want 
to — 
Q Do, do you have a recollection that some 
1 
physician that you saw in Florida? 
2 
A. I saw a male. 
3 
Q. And this is a medical doctor? 
4 
A. Yes. 
5 
Q What kind of practice was he in? 
6 
A. I don't know. 
7 
Q. Where was his office located? 
8 
A. Delray. 
9 
Q. And, and how did you come to go to this 
10 
particular physician? 
11 
A. The same way, with the 
12 
computer. 
13 
Q. And what kind of doctor was it? 
14 
A. Psychiatrist. 
15 
Q Do you recall approximately how long you 
16 
were in Florida before you went to him? 
17 
A. It was when my last dosage ran out from the 
18 
previous doctor in Virginia 
19 
Q Okay. So, you went to this psychiatrist 
20 
because you needed to have a medical doctor in order 
21 
to prescribe 
for you again? 
22 
A. No. I was in Virginia. 
23 
Q. Right. 
24 
A. I SOW the doctor in Virginia to get my 
25 
started. 
on the 
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Page 39 
physician formally diagnosed —
A. One, one of them, yes. I don't --
specifically her, l don't remember if she said yes or no 
that I have it, but one of the doctors in Florida that I 
did see gave me a test to see if l was. 
Q. That would be a doctor that you saw in 
Florida after coming back from Virginia? 
A. Yes. 
Q. Okay. You said that in a recent visit to 
this Florida
ician, that you had gone to to get 
more 
A. Uh-huh. 
Q Is that right? Okay. 
A. Yes. 
Q. When did you visit the Florida physician 
to Rea 
A. I don't recall. 
Q. Okay. It would have been -- this visit to 
the Florida physician would have been after you 
returned to Florida from Virginia? 
A. Yes. 
Q. And that, I think you told me was, you 
came to Florida in January of '09. 
A. Yes. 
Q. Okay. And was this a male or female 
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vas.. 
Page 
Q. Right. 
A. I came to Florida. I finished my dosage and 
then I went to a psychiatrist. 'didn't need a referral 
to see a psychiatrist in Florida. 
Q But you went to the psychiatrist in 
Florida so that you could get your prescription 
renewed? 
A. Yes. 
Q. Okay. How many visits did you have with 
this psychiatrist in Florida? 
A. Approximating, two or three. 
Q. And were these visits solely for purposes 
of getting your prescription? 
A. Yes. 
Q. And how long I mean, were these like 
five-minute visits? 
A. Yeah. It was a script. 
Q. You literally would just walk in and get 
the script? 
A. I'd walk in, see him, and get the script. 
Q. Okay. Did you have any counseling with 
him, or did he give you any treatment or just give 
you a prescription? 
A. No, he would just gave me a prescription. 
Q. Did you give him any history? That is did 
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1 
you sit down and tell him about your life or 
2 
anything like that? 
' 3 
A. No. 
4 
Qiasther than giving you a prescription 
5 
for a 
he didn't render any treatment to you? 
6 
A. No. 
7 
Q..2:abf the last physician that renewed 
8 
your arescription? 
9 
A. No. 
10 
Q. Okay. 
11 
A. The last doctor? 
12 
Q. Yeah 
13 
A. No. 
14 
Q. Who was the last doctor -- well, let me, 
15 
let me back it up. 
16 
You went two to three times to this 
17 
Florida psychiatrist who 
ou don't recall for 
18 
purposes of having your
prescription 
19 
renewed, right? 
20 
A. Uh-huh. Yes. 
21 
Q. Did there come a time that you didn't go 
22 
back to him? 
23 
A. Yes, I didn't go back to him. 
24 
Q. Okay. And why didn't you go back to him? 
25 
A. Because he was in Delray. 
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Page 44 
Palm Beach, right? 
A. Yeah. 
Q. Is it like one of the complexes at Victor 
Farris? Is it over by Columbia Hospital or... 
A. Ifs off of Indiantown. 
Q. Indiantown Road up in —
A. Yeah. 
Q. — up in Jupiter? 
A. No, ifs not. It's not what it is. It's... 
Q. What's not? What, ifs not off of 
Indiantown Road? 
A. No, it's -- no. I'm, I'm trying to think of 
the road. Next to Okeechobee. Ifs one of the exits 
before Okeechobee. 
Q. Exit off 1-95? 
A. Yes. 
Q. Palm Beach Lakes? 
A. No. 
Q. North or south of Okeechobee? 
A. I think ifs south of Okeechobee. 
Q. Belvedere? 
A. No. 
Q. Southern? 
A. No. Maybe it's north. I'm not good with 
directions. 
Page 43 
1 
Q. So, did you —
2 
A. I changed it to West Palm Beach. 
3 
Q. Okay. Who did you go to in West Palm 
4 
Beach? 
5 
A. I think that's the one that I gave you the 
6 
number. I don't recall her name either. 
7 
Q. Okay. So you went to a you switched to 
.8 
a female physician in West Palm Beach? 
9 
A. Yes. 
10 
Q. And is that female a psychiatrist? 
11 
A.. I know she prescribes medication, but I don't 
12 
know if she was the actual psychiatrist of the office. 
13 
I don't know how that works. 
14 
Q. Okay. Well, any, any medical doctor can 
15 
prescribe, so she could be an internal medicine 
16 
doctor for all you know. 
17 
A. Yeah, 'don't, l don't know. 
18 
Q. Was she in a group? 
19 
A. What do you mean? 
20 
Q. A group, she — was it a group practice or 
21 
just one doctor? 
22 
A. No, it was a group practice. 
23 
Q. Okay. Where was her office located? 
24 
A. West Palm Beach. I don't know. 
25 
Q. Okay. Well, you're familiar with West 
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Page 45 
Q. Okay. Well, north is behind you; south 
is — 
A. I don't know. 
Q. -- the other way. 
A. I don't know. 
Q. So, as you sit here today —
A. Yeah. 
Q. — point which way you would go to get to 
this office. 
A. I was going towards Okeechobee from 
Wellington. 
Q. Okay. 
A. So north. 
Q. So, you had — all right. So, all you —
this phone number that you have in your phone you 
think is this doctor? 
A. Yes. 
Q. ' Okay. So you -- how long -- how many —
when did you first go to her? 
A. I don't !mow the date. 
Q. Approximately when, in the last six 
months? 
A. Yes. 
Q. And how many times have you gone? 
A. Two to three. 
010•111001WSIISSISIMAllitat 
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1 
Q. And on each visit was it just to get the 
2 
prescription renewed? 
3 
A. Yes. 
4 
Q. Did she ever render any treatment to you? 
5 
A. No. 
6 
Q. Did you ever give her any history or sit 
7 
down and talk about any of your, your issues? 
8 
A. No. I did see a psychologist for that when I 
9 
was in Florida also, and I don't know the time frame. 
10 
Q Are you talking — okay, now you're --
11 
now, the psychologist that you saw in Florida for 
12 
that is that yes another doctor whose name is not on 
13 
these answers to interrogatories? 
14 
A. Yes. These answers, this was a while when I 
15 
was in Virginia when I did these, correct? 
16 
MR. MERMELSTEIN: Yes. 
17 
THE WITNESS: That's why they're not on 
18 
there. 
19 
MR. LUITIER: Duly disclosed. 
20 
BY MR LU'TTIER: 
21 
Q. When was the last time you saw this female 
22 
psychiatrist in, in West Palm Beach? 
23 
A. The psychiatrist that prescribed medication? 
24 
Q. Yes. 
25 
A. It was after the male, before I went to 
Page 48 
1 
estimate then that you must have seen this physician 
2 
within the last two months? 
3 
A. Yes. It was just, I don't take my 
4 
every day. 
5 
Q. And what does the prescription advise you 
6 
to do in terms of the frequency with which you're 
7 
take the 
8 
A. Take it every day. 
9 
Q. So, why don't you take it every day? 
10 
A. Because it makes you very hyper and 
11 
concentrate and stay up all night, so I didn't feel like 
12 
doing that every day. 
13 
Q. And have you advised the doctors that you 
14 
were having that side effect? 
15 
A. Yes, that's one of the side effects. 
16 
Q. Do you know whether or not this female 
17 
psychiatrist in Florida ever made a formal diagnosis 
18 
of you? 
19 
A. No. 
20 
Q. How about the male doctor in Delray, do 
21 
you know if he made a fonnal diagnosis? 
22 
A. Yes. 
23 
Q. You know he did? 
24 
A. Yes. 
25 
Q. Okay. And what was his diagnosis? 
Page 47 
1 
Virginia. I don't have an exact date and time. 
2 
Q. Well, was it within the last month? 
3 
A. No. 
4 
Q. Last two months? 
5 
A. The last three to four months, maybe. Two 
6 
to I'm, I'm not sure. 
7 
Was she the last physician to prescribe 
8 
for you? 
9 
A. Yes. 
10 
Q. And, and you had, you still have your last 
11 
prescription, right? 
12 
A. Pm not taking it anymore. 
13 
Q. I know you're not taking it, but you still 
14 
have the pills. 
15 
A. Yes, in Virginia. 
16 
Q. Well, you justsp
hen did you say you 
17 
just quit talcing those 
last week? 
18 
A. Like five, yeah, five days ago. 
19 
Q. Okay. But the point is the prescription, 
20 
you had not run out of the latest prescription? 
21 
A. No. 
22 
Q. Okay. And so for what period of time do 
23 
you get a prescription; a month, two months? 
24. 
A. No, it's about a month. 
25
222ka. So would 
x a correct 
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2 
3 
4 
5 
6 
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10 
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14 
15 
16 
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21 
21 
22 
23
24 
Q. When was the last time you saw the 
2 5 
psychologist in Florida? 
Fay: 
A. That I have 
Q. And how do you know he made the formal 
diagnosis? 
A. Because he gave me a test and I asked him what 
it was for and he told me that it was for to see if I 
had 
Q. Did the female doctor in West Palm Beach 
that you most recently went to to renew your 
prescription give you a test? 
A. No, not that I recall. 
Q. Did the psychologist that you saw in 
Virginia give you any kind of test? 
A. Not that I remember. I don't know. 
Q. Did the psychiatrist that you saw in 
Virginia give you any kind of test? 
A. Not that — I don't remember. 
Q. Now, you, you mentioned when we were 
speaking about the psychiatrist in West Palm Beach 
that you, you have seen a psychologist in Florida? 
A. Yes. 
Q. And, and who 
what psychologist did you 
see? 
A. I don't remember their 
13 (Pages 46 to 49) 
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Page 50 
A. That was when I first got to Florida Well... 
Q. That would be January of '09? 
A. Give me a second. 
Q. Sure. 
A. It was probably around March or April. I'm, 
you know, Pm guessing. 
Q. March or April of '09? 
A. Yes. 
Q. And was this doctor male or female? 
A. He was a male. 
Q. And I assume he probably still is a male 
but —
A. Yeah. 
Q. Where was his office located? 
A. It was in Wellington next to Greenview Shores. 
Q. In the Greenview Shores strip center or 
shopping center? 
A. I'm pretty sure, yes. 
Q. And how did you find this psychologist? 
A. Actually, my mother-in-law. My husband went 
to a doctor that was really good for him when he was 
younger, and she tried to get me to see the same doctor 
he went to. She didn't acce 
him, and he accepted 
Q. Okay. First, what's your other-in-law's 
so she referred 
1 
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Page 52 
Q. What kind of physician was that? 
A. Psychologist. 
Ot
kticl you said she, I assume you meant 
Ms. =, 
tried to get you an appointment with 
this psychologist that had seen her son when he was 
young? 
A. Yes. 
Q. But you don't know that psychologist's 
name? 
A. Nope. 
Q. AM did you ever contact that 
psychologist? 
A. Yes. 
Q. So you placed a phone call, or did you go 
see this psychologist? 
A. 1 placed a phone call and I saw hint 
Q. Okay. You did both? 
A. Yes. 
Q. All right. So there, tits another 
physician. And where was this, the psychologist who 
your mother-in-law initially suggested you go see 
who had seen your husband as a youth, where was his 
office located? 
A. That was the one I just gave you in Green, at 
the Greenview Shores. 
1 
2 
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21. 
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C25
Page 51 
name? 
A. 
(phonetic). 
Q. How wotldou spell that? 
A. -M 
you could put. 
and I 
don't know how to s II her entire — 
• =, 
• 
A. Yes. 
Q. And, and is that your husband's mother? 
A. Yes. 
Q. Okay. She lives where? 
A. In the Isles of Wellington. 
Q. And is that the name that she goes by now? 
A. Yes, M. 
Q. Is she married now? 
A. Yes. 
Q. And her husband's last name is =
1  
A. Yes. 
Q. And do you know his first name? 
A. Mervin. 
Okay. So your husband at some time in the 
Q. 
past had seen a physician who he felt did a good job 
for him? 
A. Yes. 
Q. Do you know that physician's name? 
A. No. 
Vt 
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Page 53 
Q. Oh, I, I thought you had said, correct me 
if I'm wrong, but I thought you said your 
mother-in-law had wanted to get you in to see a 
psychologist that your husband had gone to in the 
but that that psychologist wouldn't take 
• 
A. Yes. 
Q. So, that psychologist recommended another 
psychologist 
A Which is hint. 
Q. The one that you, that, that — when you 
say this is him, the "him" that you're talking about 
is this psychologist that you saw in Greenville 
shops? 
A. Yes. 
Q. All right. But that's not the 
psychologist that saw your husband when he was 
younger? 
A. No, because they didn't accept 
Q. What I wanted to know was, did you have a 
conversation with the psychologist that saw your 
husband when he was younger? 
A. No. 
• 
Q. You had no contact with him? 
A. No, my mother-in-law did. 
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Q. Andshetoldyouthat-
2
A. She gave me --
3 
Q. — as a result of her conversatliiiii 
4 
that psychologist they wouldn't take 
5 
A. Yes. 
Q. And then she provided the name to you to 
go see this psychologist whose name you don't recall 
:3 
in your Greenville shops? 
9 
A. Yes. 
10 
Q. Okay. Did you ask your mother-in-law to 
11 
fmd a psychologist for you in, somewhere around 
12 
March or April of '097 
13 
A. I mentioned it to her, yes. 
14 
Q. And how did that come up? 
15 
A. I was just, Pm very depressed, and she just 
16 
mentioned somebody that her son saw that was very good. 
17 
Q. And was that for depression? 
18 
A. Yes. Forme? 
19 
Q. Yeah. 
20 
A. Yes. 
21 
Q. Okay. And, and how many times have you 
22 
been to this psychologist near Greenville shops? 
23 
A. Four to five times. 
24 
Q. And do you go for 45-minute sessions? 
25 
A. I believe so, yes. 
Page 56 
1 
A. I just told him that I was very depressed and 
2 
I don't feel happy. 
3 
Q. And what did you tell him you believe was 
4 
the cause of your depression? 
5 
A. My past, things live gone through. 
6 
Q. Did — specifically, what did you tell 
7 
him? 
8 
A. Me, rve told him about me and my husband. I 
9 
told him about the situation with Epstein. I told him 
10 
about my parents, my childhood. 
11 
Q. What is it you told him about your parents 
12 
and your childhood? 
13 
A. We didn't get along sometimes. 
14 
Q. Now, when, when you're referring to your 
15 
porous, who are you referring to? 
16 
A. Well, my mother and my stepfather, and my 
17 
father and his girlfriend at that time. 
18 
Q. And, and when you say, "your mother," 
19 
you're talking about your birth mother? 
20 
A. Yes. 
21 
22 
A. 
23 
Q. And where does she now live? 
24 
A. Boca Raton. 
25 
Q. And your stepfather is whom that you 
Page 55 
1 
Q. And did you go once a month, or with what 
2 
degree of frequency did you go? 
3 
A. hives once every two weeks. 
4 
Q. So, if you went four to five times, you 
5 
went for a total of about two months? 
6 
A. Yeah. 
7 
Q. So, that's going to take us until sometime 
B 
around June of '09? 
9 
A. Yes. 
10 
Q. And what was the purpose of you going to 
11 
that psychologist? Was each visit designed to 
12 
address your depression? 
13 
A. Yes. 
14 
Q. Did the psychologist take notes? 
15 
A. Yes. 
16 
Q. Did the psychologist make any formal 
17 
diagnosis? 
18 
A. No. 
19 
Q. Did that psychologist have any work that 
20 
he had you do where you had to write things out? 
21 
A. No. 
22 
Q. Did he do any testing? 
23 
A. No. 
24 
Q. And what did you tell this psychologist 
25 
about cur depression? 
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Page 57 
referred.lp? 
A. ar 
Same last name. 
Q. And does he still live with your mom in 
Boca? 
A. Yes. 
Q. Okay. And your — when you refer to your 
father, are you talking about your birth father? 
A. Yes. 
Q. awavhat is his name? 
A. OM Doe No. 5. 
Q. And where does he live? 
A. He lives in Wellington. 
Q. And you referred to his girlfriend? 
A. This girlfriend that he has now is not the one 
that he had in the past that I had problems with. 
Q. Who was the girlfriend you were referring 
to? 
A. 
(phonetic). 
Q. And was she living with your dad at some 
point in time when you were having problems with 
her? 
A. Yes. 
Q. Do you need to take a break? 
A. Yes. 
MR. LIMIER: Yeah. if
 
!;
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Page 60 
1 
break, just tell me. It appeared to me that 
2 
you were in some kind of distress. 
3 
THE WITNESS: No, !just --
4 
MR. LOTTER: You don't have to wait If 
5 
you want a break, just say. This is no — this 
6 
isn't, you know, torture chambers. 
7 
THE WITNESS: Yeah. It feels like it. 
8 
THE VIDEOGRAPHER: Off the record. 
9 
(A brief recess was held.) 
10 
THE VIDEOGRAPHER: We're back on the 
11 
record at 938 a 
12 
BY MR. LUTTIER: 
13 
Q. Okay. As to the psychologist, male 
14 
psychologist in Florida whose office is near 
15 
Greenville shops —
16 
(Interruption at the door by 
17 
maintenance man.) 
18 
BY MR. LUTHER: 
19 
Q. You said you told him about your parents, 
20 
and your childhood. 
21 
A. Yes. 
22 
Q. And specifically your mom, stepfather, 
23 
father and grandfather. What is it you told him 
24 
about these members of your family? 
25 
A My dad and I had some conflicts verbally, and 
1 
A. Yes, I was in South Carolina 
2 
Q All right. So would it be a correct 
3 
statement that his physical abuse of you ended when 
4 
you left South Carolina? 
5 
A. Yes. 
6 
Q. And that would have been while you were in 
7 
the eighth grade? 
8 
A Yes, the beginning. 
9 
Q. And approximately on how many occasions 
10 
did he physically abuse you? 
11 
A It was, it was two to three times he's really 
12 
hit me. 
13 
Q. Okay. And describe those incidents. 
14 
Well, let me ask you this, did you describe those 
15 
incidents to this psychologist, male psychologist 
16 
who you saw near the Greenville shops down here? 
17 
A. Yes. 
18 
Q. Okay. What, what did you tell him? I 
19 
assume you told that psychologist the complete 
20 
story? 
21 
A. Yes. 
22 
Q. All right. You were truthild to him? 
23 
A. Yes. 
24 
Q By the way, you've seen a number of 
25 
psychologists strictly related to this lawsuit, have 
Page 59 
1 
my mom and I also did. 
2 
Q. And those things were causing you to be 
3 
depressed, to be depressed, you thought? 
4 
A. It was some of the reason, yes. 
5 
Q. And what did you say about your stepfather 
6 
and your, and your father's girlfriend? 
7 
A. My stepfather sometimes was physically 
8 
abusive. 
9 
Q. How often was he physically abusive with 
10 
you. 
11 
A It was on rare occasions when he would get 
12 
really upset. 
13 
Q. Did he, did he hit you more than once? 
14 
A. Yes. 
15 
Q. And did all his physical abuse of you, 
16 
that is, your stepfathers physical abuse of you, 
27 
occur prior to your completion of the ninth grade? 
18 
A. Yes. 
19 
Q. Did it, did it all occur, did he 
20 
physically abuse you on numerous occasions prior to 
21 
your completion of the eighth grade? 
22 
A. The eighth grade is when I left and moved with 
23 
my father. 
24 
Q. That is you left from — at the time you 
25 '; 
were living with your mother and stepfather? 
••••••••11~ 
Page 61 
1 
you not? 
2 
A. Strictly related to this lawsuit? 
3 
Q. Um a Dr. 
You recall him? 
4 
A. Yes, yes. 
5 
Q. Okay. You saw a Dr. a 
6 
A. Uh-huh, yes. 
7 
Q. With respect to those two individuals, did 
8 
you tell them the truth about everything? 
9 
A. Yes. 
10 
Q. So if they asked you a question, you gave 
11 
them a response, it was a truthful response? 
12 
A Yes. 
13 
Q. You answered fully and completely any 
14 
questions that they had? 
15 
A. Yes. 
16 
Q. Okay. MI right And, likewise, were, 
17 
were you truthful with all these psychologists and 
18 
psychiatrists whose name you've given me for the 
19 
first — well, whom you've identified for the first 
20 
time in today's deposition? 
21 
A. Yes. 
22 
MR MERYffiLSTEIN: Objection to form. 
23 
BY MR. LIMIER: 
24 • 
• 
Q. And were you complete in your discussions 
25 
with them, told them everything that, you know, that 
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was relevant? 
2 
A. Yes. 
3 
MR. MERMELSTEIN: Form. 
4 
BY MR. LUTTIER: 
5 
Q. Okay. Well, everything — I should say, 
6 
you told them everything you thought was relevant to 
7 
the reason why you were there to see them? 
8 
MR. MERMELSTEIN: FORTE 
9 
THE WITNESS: Yes. 
10 
BY MR. LUTTIER: 
11 
Q. Okay. Now, tell me about then what is it 
12 
you told this psychologist, male psychologist here 
13 
in Florida at the Greenville shops with respect to 
14 
the two to three times that your stepfather 
15 
physically abused you prior to your completion of 
16 
the eighth grade? 
17 
A. There was one occasion where he got upset 
18 
because I told my friend on the phone that I was, you 
19 
know, I didn't like him. And he came into my room and 
20 
hit me across the face and threw my television down the . 
21 
stairs and just had a bad temper. 
22 
Q. Okay. And let me, let me make sure I 
23 
understand this. This is something that occurs when 
24 
you're, what, 13 years old? 
25 
A. Yeah, 12, 13. 
1 
2 
3 
4 
S 
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8 
9 
10 
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12 
13 
14 
15 
16 
17 
18 
21i 
21 
22 
23 
24 
25 
A. Yes. 
Q. Was the scene hysterical? 
MR. MERMELSTEN: Objection, asked and 
answered. 
BY MR. LUTTIEFt: 
Q. That is, was, was everybody that was there 
in hysterics? 
A. Yes. 
Q. Was your mom there? 
A. Yes. 
Q. Your mom has always loved you, right? 
A. Yes. 
Q. Was she hysterical? 
A Yes. 
Q. What was she doing while her husband was 
beating you so severely that he ruptured your 
eardrum? 
A. She was trying to push him away. 
Q. Trying to protect you? 
A. Yes. 
Q. At that point in time was that the worst 
thing that had ever happened to you in your life? 
A. That point in time, yeah, that was pretty bad 
for me. 
Q. Was it the worst thing that ever happened 
Page 63 
1 
Q. Okay. AM how old was your stepfather at 
2 
the time? 
3 
A. I don't laiow. 
4 
Q. Bigger physically? He was obviously was 
5 
bigger than you, right? 
6 
A. Yes. 
7 
Q. And he came into your room when you were 
8 
on the phone? 
9 
A. Yes. 
10 
Q. And he literally picked up a TV from your 
11 
room and threw it down the stairs of your home? 
12 
A. Yes. 
13 
Q. Would it be safe to say that you were 
14 
hysterical at that time? 
15 
A. Yes. 
16 
Q. You were crying? 
17 
A Yes. 
18 
Q. You were scared? 
19 
A. Yes. 
20 
Q. He then did physical violence to you? 
21 
A. Yes. 
22 
Q. Asa matter of fact, he beat you so badly 
23 
that he ruptured your eardrum, didn't he? 
24 
A. Yes. 
25 
Q. Did you fear him when he was doing that? 
1 
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Page 65 
to you in your life? 
A. Yes. I was upset, yeah. 
Q. • You sound like you're hesitant, so I 
just ;-
A. I'm just, I'm just thinking back. 
Q. I want you to take your time. I want you 
to think about it. I want to — so, if you need to 
take a minute, is that the worst thing that ever 
happened to you in your life as of that point in 
time? 
A. Yes. 
Q. How did he beat you so as to rupture your 
eardrum? 
A. He hit me across the face. 
Q. With a closed fist? 
A. I don't recall. It was very fast. I don't 
'mow. 
Q. Still have the phone in your hand? 
A. The phone? 
Q. Did you still have the phone that you were 
on in your hand? 
A. No, he ripped it out of my hand. 
Q. That's the first thing he did, right, he 
came up and tore the phone? 
A. Yes. 
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Page 68 
Q. Did he tear up your room? 
2 
A. He ripped the phone out of my hand, ripped it 
3 
out of the wall, took the TV, threw it down the stairs 
4 
and hit me. 
5 
Q. Ripped the phone out of the wall so you 
6 
couldn't call for help? 
A. He ripped it out of the wall probably because 
3 
I was on the phone with my friend telling them how I 
9 
didn't like him. 
10 
Q. And do you recall why you were telling 
11 
your friend that you didn't like this fellow that 
12 
just beat you? 
13 
A. As of why I was saying it? 
14 
Q. Yeah. 
15 
A. He was just very strict. 
16 
Q. Had he 
prior to this occasion when he 
17 
beat you so badly that he ruptured your eardrum, had 
18 
he hit you before? 
19 
A. Not as bad as that. That was the, the worst. 
20 
Q. Was there, when he ruptured your eardrum, 
21 
was there any blood? 
22 
A. No. 
23 
Q. Did you go to a physician and seek medical 
24 
care? 
25 
A. Yes. 
1 
haunts you today, doesn't it? 
2 
MR. MERMELSTEIN: Objection to form. 
3 
THE WITNESS: Yes. 
4 
BY MR. LUTTIER: 
5 
Q. And that's when you've gone to all these 
6 
psychologists and psychiatrists and you've talked 
7 
about your past you have always mentioned this 
8 
incident, have you not? 
9 
A. Yes. 
10 
Q. And it gives you concern, one of the 
11 
things you worry about in life is whether anybody 
12 
would do anything like that to your little daughter, 
13 
isn't it? 
14 
A. Yes. 
15 
Q. You're very vigilant about making sure 
16 
nobody hurts your daughter. 
17 
A. Yes. 
18 
Q. And you're acutely aware of domestic 
19 
violence? 
20 
A. Yes. 
21 
Q. Other than that, when you went back to —
22 
when you went to South Carolina with him, and he 
23 
drew things at you, other than the tub of butter, 
24 
did he throw anything else at you? 
25 
A. Not that I recall. He was, he, he would 
Page 67 
1 
Q. Were you still scared even after the 
2 
incident happened? 
3 
A. I was scared that he had a bad temper and it 
4 
could happen again. It never happened again, to that 
5 
extent again. 
6 
Q. But he did hit you again, didn't he? 
7 
A. Yes. 
8 
Q. When did he next hit you? 
9 
A. The instance I just gave you was in Fort 
10 
Lauderdale. 
11 
Q. Okay. 
12 
A. And then when I moved to South Carolina, ifs 
13 
not that he hit me, but he would, like, throw things at 
14 
me. 
15 
Q. Did he ever hit you with anything when he 
16 
threw it at you? 
17 
A. He threw a tub of butter at me in South 
18 
Carolina. 
19 
Q. But the incident where he beat you and 
20 
your eardrum was punctured, that happened while you 
21 
were in the eighth grade, right? 
22 
A. It was the seventh or the eighth grade, 
23 
because I was in Fort Lauderdale going to middle school 
24 
there. 
25 
Q. Asa matter of fact, that incident still 
Page 69 
1 
always lose his temper. 
2 
Q. When you're when he beat you on that 
3 
occasion and he ruptured your eardrum, was your 
4 
mother finally able to get him to stop? 
5 
A. She told me that she would leave him if I 
6 
Q. !mean when the incident was happening and 
7 
you were there, she was present watching it, was she 
8 
not? 
9 
A. Yes. 
10 
Q. How did what caused him to stop beating 
11 
you? 
12 
A. He calmed down and realized what he was doing 
13 
and my mom stepped in. 
14 
Q. Did she, did she then come over and, and 
15 
console you? 
16 
A. Yes. 
17 
Q. Did you feel that your mother was 
18 
partially responsible for that action? 
19 
A. For that specific act that day that he did 
20 
that? 
21 
Q. Yeah. 
22 
A. No, no. 
23 
Q. How about for the fact that she had him 
24 
aroma( and you were exposed to him and he had been 
25 
conducting himself like that towards you? 
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1 
A. Ina way, yes. Like you say, I held her 
2 
responsible for yes. 
3 
Q. I mean, this stepfather treated you poorly 
4 
for as long as you can remember, did he not? 
5. 
A. Not any —
6 
MR. MERMELSTEIN: Objection to form. 
7 
THE WITNESS: Not anymore. 
8 
BY MR. LUITIER: 
9' 
Q. Well, not now, but back when you were --
10 
you, you lived with your mother and your stepfather, 
11 
this fellow 
--
12 
A. Yeah. 
13 
Q. -- for a period of time, did you not? 
14 
A. Yeah. 
15 
Q. — and do you recall about when that was? 
16 
You can use your age; how old you were. 
17 
A. Yeah. They got together when I was three 
18 
years old. 
19 
Q. Okay. And they, and you lived with them 
20 
until you came back to, to West Palm when you were 
21 
finishing up the eighth grade? 
22 
A. Yes. 
23 
Q. So that's when you were, what, 13 years 
24 
old? 
25 
A. Yeah. 
1 
2 
3 
4 
5 
6 
8 
9 
10 
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13 
14 
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Page 72 
MR. MERMELSTEIN: Objection, form. 
THE WITNESS: He told me that I was 
*Sage. 
BY MR. LUTTIER: 
Q. And how did that make you feel? 
A. Like crap. 
Q. And that still bothers you too, doesn't 
it? 
A. Yeah. 
Q. And do you tcunwber when he did that? 
A. When he did what? 
Q. When he told you you were baggage. 
A. He told me that recently when I was living 
there. 
Q. Recently meaning when? 
k 
When I was — after high school. He was 
apologizing for the way he acted, and basically just 
said that back in the day he thought of me as baggage. 
Q. And do you recall him telling you back 
then that you were — that he thought you were 
baggage? 
A. No. 
Q. Did he tell you back when you were living 
with him for the ten-year period that, that, that 
you were sort of an inconvenience to him? 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
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Page 71 
Q. All right. So you've got years that you 
lived with your mother and, and this stepfather 
l=? 
A. He — in, in the beginning he didn't live with 
us, but he was over a lot. 
Q. And during that ten-year period, he not 
only physically abused you, but he verbally abused 
you, did he not? 
A. Yes. 
Q. What kinds of things did he tell you? 
A. He would just ten me to shut the F up, and 
that I was stupid and immature and mean. 
Q. Did, did that make — did he demean you? 
A. Make me feel like —
Q. Lice little. 
A. Yeah. 
Q. Make you feel like you weren't a good 
person? 
A. Yes. 
Q. And did you resent that with your mother 
that she would allow her boyfriend or her, her 
husband to treat you that way? 
A. Yeah. 
Q. Did he, did he ever tell you where you fit 
into his view of the world? 
Page '73 
1 
A. No, but I could see it through his actions. 
2 
Q. Do you recall other incidents where he 
3 
physically abused you? 
4 
A. I don't remember, like exactly,' just haw he 
5 
lost his termer a lot. I don't remember specific —
6 
Q. And when he lost his temper he would 
7 
strike you? 
8 
A. Not just that, but he would, you 'mow, 
9 
sometimes it would just be like he would throw things 
10 
or, you know, run out of the house pissed off and 
11 
whatever, have his tantnam. 
12 
Q. AM these are still events that -- what 
13 
are you, 22 years old now? 
14 
A. Twenty-three. 
15 
Q. These are events that still --
16 
A. They're upsetting. 
17 
Q. — that you recall? And, and although you 
18 
love your mother, do you hold her responsible for, 
19 
for you being subjected to that kind of conduct for 
20 
a ten-year period? 
21 
MR. MERMELST'EIN: Objection, asked and 
22 
answered twice already. 
23 
THE WITNESS: Yes. 
24 
BY MR. LUTHER: 
2 5 
 
.9 
.1.4emd 
 
_E
d u ten is ychologjst in 
19 (Pages 70 to 73) 
PROSE COURT REPORTING AGENCY, INC. 
EFTA01076402