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Page 74 
1 
Florida that you saw over by Greenville shops about 
2 
all these instances? 
3 
A. Yes, I've — I didn't tell him about, you 
4 
know, the butter and everything, but I told him about 
5 
the eardrum. 
6 
Q. Okay. What did you, what did you tell 
7 
him? Did you tell him anything else specifically, 
8 
that is this psychologist in Florida, specifically 
9 
about your stepfather other than what you've told us 
10 
thus far? 
11 
A. Not that I recall. 
12 
Q. Okay. 
13 
A. About my stepfather --
14 
Q. Yeah. 
15 
A. — only? Yeah, not that I recall, just that 
16 
he had a bad temper and with the eardrum situation. 
17 
Q. Is your — can you hear all right today? 
18 
A. Yeah. 
19 
Q. Now, you, you told the psychologist here 
20 
in Florida that you had some verbal conflict with 
21 
your mother as well. 
22 
A. Uh-huh, yes. 
23 
Q. And what did you tell the psychologist 
24 
here in Florida when you went to see him about 
25 
conflict with your mother? 
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 r 
tumble? 
A. She just said just don't tell him that, hit 
you. 
Q. Is that something that you regret having 
done up through today? 
A. Ina way. !just try to, you know, it was in 
the past and he's apologized for it, so... 
Q. Did you how do you feel towards your 
mother now that you're older about her having even 
asked you to go tell a doctor something that wasn't 
true about you being abused by her husband? 
A. I'm sorry. What did you say? 
Q. It was a bad question. 
How does it make you feel now knowing 
that your mom asked you to go lie to a doctor to 
cover for her husband when, when —
A. Now, or at that point in time? 
Q. How does it make you feel now? 
A. It's upsetting. It hurts my feelings. 
Q. How did it make you feel then? 
A. I — you know, I was young. I didn't, that 
didn't really — I don't remember what I felt at that 
point 
Q. Mir, as you sit here today, if that 
happened to your daughter, God forbid if she had a 
Page 75 
1 
A. I had conflicts with my mother because of my 
1 
2 
stepfather. 
2 
3 
Q. And, and what was the nature of that 
4 
conflict? 
5 
A. Just that I wanted her to leave him. 
5 
6 
Q. And did you ever tell her that? 
6 
7 
A. Yes. 
7 
8 
Q. And do you remember when you first told 
9 
her that? 
9 
10 
A. No. 
10 
11 
Q. Do you know approximately when it was, how 
11 
12 
old you were? 
12 
13 
A. No, because she asked me if I fluted her to 
13 
14 
leave him when he hit me and I said no. 
14 
15 
Q. By the way, when, when he hit you and you 
15 
16 
went to see the doctor for medical cares did you, 
16 
17 
did you lie to the doctor about how you got the 
17 
18 
injury? 
18 
19 
A. Yes. 
19 
20, 
Q. And why did you do that? 
20 
21 
A. So he didn't get in trouble. 
21 
22 
Q. Did your mom encourage you to do that? 
22 
23 
A. Yes. 
23 
24 
Q. Did she tell you basically that if you 
24 
25 
told the truth that, that her husband would get in 
25 
Page 77 
similar thing happen to you, would you do the same 
thing your mom did? 
A. No. 
Q. Okay. You, you, you said that you told 
your mom that you wanted her to leave your 
stepfather and I assume that she declined to do 
. that? 
A. Yes. 
Q. That caused resentment between the two of 
you? 
A. Yes. 
Q. Has that been a source of conflict between 
the two of you ever since? 
A. To, today, I don't care, because I have my own 
family and life. But back when, you know, I was still 
like around the situations, it bothered me. 
Q. Any other conflict that you had with your 
mom other than you, you asked, you asked her to 
leave her husband and she declined to do so? 
A. Ion sorry. What did you say? 
Q. Any other conflict that you had with your 
mom? 
A. There was one instance when we were in 
Chicago. 
Q. And that's when you were about how old? 
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Page 78 
A. It was, I think it was beginning of middle 
school, around that time. I don't know the exact time 
3 
frame. 
4 
Q. Before you finished the eighth grade? 
A. Yes. 
Q. Okay. What happened in Chicago? 
A. She actually split up with my stepfather and 
3 
was dating another guy. And I walked next to the street 
9 
in Chicago and she got upset and hit me in the bathroom. 
10 
Q. I assume that upset you at the time? 
11 
A. Yes. 
12 
Q. Still upsets you? 
13 
A. It does, but... 
14 
Q. You wouldn't hit your daughter? 
15 
A. I don't, no, I don't like to hit. 
16 
Q. Still an event that when you watt to the 
17 
psychologist you told him about it? 
18 
A. Yeah. 
19 
Q. Because it was upsetting to you? 
20 
A. Yeah. 
21. 
Q. Still upsetting to you? 
22 
A. Yeah. 
23 
Q. Okay. Any other conflict that you've had 
24 
with your mom? 
25 
A. Just differences in life. 
Page 80 
1 
BY MIL LUTTIER: 
2 
Q. Okay. Anyway, all right. So you had gone 
3 
to, you lived with your mom and your step dad down 
4 
in Fort Lauderdale. They moved with you to South 
5 
Carolina. 
6 
A. Yes. 
7 
Q. But you only were in South Carolina for a 
8 
number of months. 
9 
A. Yes. 
10 
Q. You enrolled in a school up there in the 
11 
eighth grade. 
12 
A. Uh-huh. 
13 
Q. That's a yes? 
14 
A. Yes. 
15 
Q. Then you came back to Florida and you 
16 
moved in with your dad, your birth dad? 
17 
A. Yes. 
18 
Q. And you stayed with your birth dad from 
19 
the time that you were finishing up, up eighth grade 
20 
until when? 
21 
A. Eighteen. 
22 
Q. Did you have contact with your mom after 
23 
you moved back to Florida when you were in the 
24 
latter part of the eighth grade? 
25 
A. Yes. 
Page 79 
1 
Q. Do you believe your mom, as you sit her 
2 
today, let you down as a, as a child? 
3 
MR. MERMELSTEN: Form. 
4 
THE WITNESS: There were things that she 
5 
did that I didn't like. 
6 
BY MR. LIMITER: 
7 
Q. Like what, besides not leaving her 
8 
husband? 
9 
A. Just that I was her first kid and she didn't 
10 
really know how to raise me. 
11 
Q. Now, you said that you came back to 
12 
Florida to live with your dad. 
13 
A. Yes. 
14 
Q. Was it January of '07, somewhere around 
15 
there? 
16 
A. It was 
17 
Q. forgot. 
18 
A. — in the eighth grade. 
19 
Q. Okay. Lets see —
20 
MR MERMELSTEIN: Did you say '07? 
21 
MR. LUTTMR: Yeah, let me see. I don't 
22 
want to mess up the record. 
23 
MR. MERMEISTEIN: '07 she was 21. 
24 
MR. LUTHER: It wasn't in '07. 
25 
THE WITNESS: No. 
1 
2 
3 
4 
5 
6 
7 
8 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Adihtetla....
..I.axaratsaaeo 
Page 81 
• 
Q. And what kind of contact did you have with 
heel 
A. Phone. 
Q. Is that - 
A. And I saw her in summers. 
Q. Is that the only time you saw her? 
A. Yes. 
Q. And where did mom live from the time that 
you finished up the eighth grade down here in, in 
Wellington until your 18th birthday? 
A. She stayed in South Carolina and then she 
moved back to Florida probably, my, I'm going to say my 
junior year. 
Q. That would be 2003? 
A. Yes, I think so. 
Q. And when you say she came back to Florida, 
did she come back to Florida with her, your step 
dad? 
A. Yes. 
Q. And where did they come when they came 
back to Florida? 
A. They went back, they went to Boca. 
Q. Is that where they live now? 
A. They lived in a temporary house until the 
other house was
sa rdelSe.kniBec 
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Page 84 
Q. Okay. Is the house that they live in now 
2 
the one that they moved into after they were in the 
3 
temporary house? 
A. Yes. 
Q. Okay. So they've lived there continuously 
since about 2003 when they returned to Florida? 
A. Yes. 
3 
Q. And up until 2003, you would see your mom 
9 
in the summers? 
10 
A. Yes. 
11 
Q. All right. Did there oome a time before 
12 
your mom came back in 2003 that your mom took you to 
13 
see a psychologist or a psychiatrist? 
14 
A. She took me to see a psychologist 
15 
Q. Okay. So would you look at the answers to 
16 
imerrogatories and tell me — I will show you again 
17 
Interrogatory 8, and tell me which physician your 
18 
mom took you to see. 
19 
A. I don't think it's in here because I didn't 
20 
remember at this time, but I have his name and where he 
21 
is. 
22 
23 
24 
25 
Q. Where do you have his name? 
A. 1 in my mind I know his name. 
Q. O *t ,=. Well, what's his name? 
A 
1 
lawyer. 
2 
MR. LUITIER: Yeah, don't Just a yes or 
3 
no, but don't tell, I don't want to know --
4 
THE WITNESS: I'm sorry. 
5 
MR. LUTITER: About the substance of your 
6 
conversation. 
7 
THE WITNESS: All right. 
8 
MR. LUITIER: One of the reasons why Pm 
9 
asking you this is we have these 
10 
interrogatories where we ask you information, 
11 
and, and had I known who these doctors were, I 
12 
would have had their records beforehand, and 
13 
would be able to ask you about information 
14 
based on the records. And in our rules there 
15 
is a duty to continue to disclose these people. 
16 
And I, just for the record, Stuart, you 
17 
know, I've got, Pm up to six that I don't know 
18 
anything about, otherwise I would have these 
19 
records. And I think there's that duty to 
20 
disclose. And I know we are under some time 
21 
things. I'm trying to — I was going to try to 
22 
get it done, but... 
23 
MR. MERMELSTEIN: I, I understand that, 
24 
and I realized when you were going through with 
25 
it in the first hour. 
Page 83 
Q. a 
1. 
2 
A. Yes, I'm pretty sure. 
2 
3 
Q. And, and when did you go to see 
3 
4 
Dr. Milln 
4 
5 
A. 11, it was a trip I took with my mother. She 
5 
6 
was still living in South Carolina. I don't recall 
6 
7 
exactly when it was. 
7 
8 
Q. Well, it had to be before 2003, right? 
8 
9 
A. Yes. 
9 
10 
Q. And, what do you mean, it was a trip you 
10 
11 
took with your mom? 
11 
12 
A. She went to go see him in Memphis, Tennessee. 
12 
13 
and she wanted me to go with her. 
13 
14 
Q. Now, this — how, how is it that you 
14 
15 
recall this physician's name who you saw sometime 
15 
16 
before 2003, and you know his name but you don't 
16 
17 
know the names of these other physicians that you've 
17 
18 
seen since then? 
18 
19 
A. Because I found his book the other day in my 
19 
20 
house. 
20 
21 
Q. Have you provided his name to your lawyer? 
21 
22 
A. Actually, yesterday. 
22 
23 
Q. Is there 
23 
24 
MR. MERMELSTEIN: Don't talk about 
24 
25 
anything else you've discussed with your 
25 
Page 85 
MR. LUITIER: Okay. 
MR. MERMELSTEIN: I don't I don't know if 
it's six or not. I wasn't —
MR. LUTTIER: Yeah. 
MR. MERMELSTEIN: — counting to that 
extent, but yeah, I am aware that there are 
psychological professionals, health care 
professionals that need to be disclosed. 
MR LUFTIER: Yeah, because I tried to 
get -- the idea was to get -- I subpoenaed all 
the records that I knew to try, so that I would 
have them here so that I could go through this. 
And Pm now going to have to obviously get 
those records, and I may have to still do some 
other stuff. Okay. 
MR. MERMELSTEIN: I understand. 
BY MR. LUITIER: 
Q. All right. Let me go back to Dr. =. 
Okay. So, you say you recently found aWof his 
in your house? 
A. Yes. 
Q. When you say "your house," what house are 
you referring to? 
A. Oh, Virginia. 
• 
Q. Okay. Do you — is that a book that you 
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Page 
1 
had or you read? 
2 
A. Yeah, he gave me a book when I went to sec 
3 
him. 
4 
Q. So, this is a book you got back in 
5 
sometime before '03? 
6 
A. Yes, whenever I saw him. 
7 
Q. And what's the name of the book? 
8 
A. I don't recall the books name. I just 
9 
remember his name. 
10 
Q. What's it about? 
11 
A. Stories that he's been through with his 
12 
clients and how they recovered and... 
13 
Q. Well, what kind of doctor is he? 
14 
A. He was a psychologist, I think. 
15 
Q. Does he have some specialty or particular 
16 
kinds of patients that he sees? 
17 
A. I don't know. 
18 
Q. For example, some people will specialize 
19 
in, let's say, alcohol addiction, and they might 
20 
write a book about their clients and they're all 
21 
clients that were alcoholics. And they talk about 
22 
their story and stuff like that 
23 
You mentioned that his book was 
24 
stories about clients that he had. Is there some 
25 
similarity among his clients, they arc all there for 
Page 88 
1 
conversation with your dad about the fact that you 
2 
were going there? 
3 
A. I'm sure — I don't remember that, but I'm 
4 
sure I told him where I was going. 
5 
Q. Did you know why you were going? 
6 
A. She told me it was she wanted me to, you know, 
7 
see somebody and talk to somebody. 
8 
Q. What about? 
9 
A. To help me. 
10 
Q. Help you about what? 
11 
A. Because I was depressed. 
12 
Q. And when you say you were depressed, is 
13 
that, is that a diagnosis that someone had made of 
14 
you St that time? 
15 
A. No. 
16 
Q. Or just you were -- a description of how 
17 
you felt? 
18 
A. Description of how I felt. 
19 
Q. And your mom had sensed that she also was 
20 
of the opinion you were depressed at the time? 
21 
MR. MERMELSTF_IN: Objection to form. 
22 
THE WITNESS: She just thought I was, you 
23 
know, that I needed to talk to somebody. L.. 
24 
BY MR. LIJTTIER: 
25 
Q. Were you doing anything or engaging in any 
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 87 
the same reason or something? 
A. No it was all different. 
Q. Okay. Now, you said your mother was going 
to see this person in Memphis. Was she going to see 
Dr. 
on her own for some reason for her, or was 
it just somebody she picked that she wanted to take 
you to? 
A. No, it was somebody that she was going to. 
Q. Do you know why your mom was going to see 
this person? 
A. No. 
Q. And was this — this would have been 
during the summertime, I assume, if it's your mom 
and you taking a trip? 
A. Fm pretty sure, sunvner or spring break. I 
don't recall exactly when. 
Q. And you were living at the time with your 
dad, your birth dad in Florida? 
A. Yes. 
Q. Did he know that mom was going to take you 
to this --
A. Yes. 
Q. Did you-all discuss that before you went? 
A. No. 
Page 89 
1 
kind of conduct that caused ha concern at that 
2 
time? 
3 
A. Not that I millet ulna. 
4 
Q. Had she said to you that you had changed 
5 
in any manner in your relationship with her or 
6 
someone else that caused her to think that you were, 
7 
you needed to see this person? 
A. I don't, I don't, I don't remember. It was, I 
9 
don't think so. I mean, I don't —ljustIcnow she 
10 
wanted me to go see this person. 
11 
Q. Had she said to you anything like, you 
12 
know, we used to be close and now you're a different 
13 
person, and I think you need to see somebody? 
14 
A. She saw changes in me. 
15 
Q. What kind of changes did she say she saw 
16 
in you? 
17 
A. Because I used to be very, like, close to her. 
18 
Q. Okay. 
19 
A. And I would always be home when I said I would 
20 
be home. And, you know, when I went and saw her 1 would 
21 
go do my own thing and basically not, you know, abide by 
22 
her rules. 
23 
Q. Now, when you say you went and saw her, 
24 
you mean when you went to — 
Q. Did, do you remember, having any 
25 
A. South Carolina. 
23 (Pages 
to 89) 
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Page 9
1 
Q. — South Carolina? 
2 
A. Yes. 
3 
Q. And were you — when you, the phrase you 
4 
used, you would do your own thing, what do you mean 
5 
by that? 
A. One time, for instance, I went with one of my 
7 
old friends there. I went on a ride on a golf cart, and 
a 
1 was out fora while, and she wasn't used tome, you 
9 
know, not calling her, telling her where I was, and I 
10 
just wasn't, you know, being close to her. I wasn't 
11 
telling her things. I was just doing what I wanted. 
12 
Q. And at, at, at the time, what was 
13 
happening to you in school? 
14 
A. School-wise, like grades or 
15 
Q. Like were you attending school regularly? 
16 
A. I think at that time I was. 
17 
Q. Had you started skipping school? 
18 
A. I did start skipping school my senior year. 
19 
Q. So you didn't start skipping school until 
20 
your senior year? 
21 
A. I did a little bit in my junior year, but my 
22 
senior year was my worst. 
23 
Q. And were you, were you doing similar 
24 
things down here while you were living with your 
25 
dad? 
Page 92 
Q. Okay. How else could you describe what 
your relationship with your dad, your natural 
3 
father, was at the time that your mom decided that 
4 
she wanted you to go see Dr. M? 
5 
A. We didn't really have a relationship anymore 
6 
after a while. 
7 
Q. Okay. After how long? 
8 
A. Probably after a year or two of me being 
9 
there. 
10 
Q. And that is you had no relationship with 
11 
your dad? 
12 
A. No, we weren't close —
13 
Q. Okay. 
14 
A. --after that. 
15 
Q. So you, you had come from South Carolina 
16 
where you, you left your mom and your step dad with 
17 
whom you lived for ten years. 
18 
A. Uh-huh. 
19 
Q. Right? You came down and you began living 
20 
with your dad with whom you hadn't lived for ten 
21 
years since you were three years old. 
22 
A. Yes. 
23 
Q. Do you recall during the ten-year period 
24 
that you lived with your mom from three to 13 
25 
whether you had contact with your dad? 
Page 9: 
A. Yes. 
1 
2 
Q. That is, what kinds of conduct were you 
2 
3 
engaging with him at the same time that your mom was 
3 
4 
observing that you were not as close to her and you 
4 
5 
wore doing your own thing? 
5 
6 
A. 1 would just be going out all the time, 
6 
7 
drinking, tried drugs, stay out. 
7 
8 
Q. And at that time; that is when your mom 
8 
9 
was encouraging you to go with her to see Dr. In 
9 
10 
what was your relationship with your birth father 
10 
11 
with whom you were then living primarily like? 
11 
12 
A. in the beginning it was weird. 
12 
13 
Q. When you say, win the beginning," what do 
13 
14 
you mean? 
14 
15 
A. When 1 first moved with him in eighth grade. 
15 
16 
Q. Okay. So that's, what did we decide that 
16 
17 
was, 13? 
17 
18 
A. Yeah, 12, 13. 
18 
19 
Q Okay. So, 12 or 13 when you moved back 
19 
20 
down here, it was you say weird, what do you mean by 
20 
21 
that? 
21 
22 
A. Just, I've never — you know, I don't remember 
22 
23 
living with him when I was, you know, under the age of 23 
24 
three years old, and It was just awkward. I was used to 
24 
25 
being with my mom. 
25 
Page 93 
A. Yes. 
Q. Would you go visit him on weekends and 
things like that? 
A. When we were living in Florida, yes. 
Q. Okay. So, you came back. You lived with 
your dad, not having been there for ten years, it 
was weird. And then after a year or so you had 
really no relationship with him? 
MR. MERMEISTE1N: Form. 
THE WITNESS: Yeah. 
BY MR. LUTHER: 
Q. Now, you mentioned when you went to see 
this psychologist here in Florida over at the 
Greenville shops —
A. Uh-huh. 
Q. -- that you told him about conflicts you 
had with your dad. Do you recall that testimony? 
A. Yes. 
Q. Okay. So, was this, this situation that 
existed between you and your dad after you came back 
from South Carolina part of the conflict that you 
discussed with him? 
A. Yes. 
Q. Okay. So, so what kind of conflict were 
you having with your father at the time that your 
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Page 94 
1 
mom had decided that it would be good for you to go 
2 
see Dr. a? 
3 
A. He just, he didn't approve of the things 1 was 
4 
doing. He didn't understand why I started failing out 
5 
of school and not doing good, and basically he would 
6 
just verbally abuse me. 
7 
Q. So, was that, was that conduct that 
8 
your — and the relationship you had with your 
9 
father part of what was contributing to the, what 
10 
you described as the depression that caused our mom 
11 
to say that she wanted you to go see Dr. MM? 
12 
MR. MERMELSTEIN: Form. 
13 
MR. LUTHER: Let me rephrase the 
14 
question. 
15 
BY MR. LUTHER: 
16 
Q. Was the, the conflict that you were having 
17 
with your dad, which you just described, 
18 
contributing to what you described as depression 
19 
that you had the summer that your mom took you to 
20 
see Dr... 
21 
MR. MERMELSTE1N: Form. 
22 
THE WITNESS: Was sane of the conflict? 
23 
BY MR. LUTHER: 
24 
Q. Yeah. 
25 
A. He was 
Page 96 
1 
And he would just, you know, say nasty things and... 
2 
Q. Okay. Tell, tell me what nasty things he 
3 
said. 
4 
A. He would tell me I would amount to nothing in 
5 
life, that I was a lazy fat pig, just things like that. 
6 
Q. What's the worst thing he ever said to 
7 
you? 
8 
A. Probably, you know, the lazy fat pig; I'm 
9 
going to amount to nothing. That's why Pm recalling 
10 
that. That's why I remember that because that's one of 
11 
the things that really hurt me. 
12 
Q. Were those comments made to you before you 
13 
went to see Dr. M? 
14 
A. 1,1don't, I don't recall. 1 don't know. I 
15 
don't recall. 
16 
Q. Do you know when those comments were made 
17 
to you? 
18 
A. When I was living with him in high school at 
19 
some point. I,1 think — I don't know. I can't 
20 
remember. 
21. 
Q. Were these comments that he made to you 
22 
comments he made often? 
23 
A. I didn't see him that often. He was, he was 
24 
at work a lot. He worked a lot. He worked six days a 
25 
week. In the morning he was gone, and he wouldn't get 
Page 95 
Q. Okay. And — 
A. Yeah, some of it. 
3 
Q. And you said he didn't understand when you 
4 
were, your grades were going down? 
5 
A. Yeah. 
6 
Q. And, and tell me a little bit about what 
7 
was happening with your grades. You were in the 
8 
eighth grade when you first came down? 
9 
A. Yeah, I was fine, you know, eighth, ninth, 
.0 
tenth grade. 1 started — I'm not 100 percent sure when 
11 
my grades started going down, but if you look at, you 
12 
know, my scores and stuff, you could just see that 1 
13 
went downhill —
14 
Q. Okay. So —
15 
A. 
in high school. 
16 
Q. — your grades hadn't necessarily gone 
17 
down at the point in time you went to see Dr... 
18 
A. I don't recall. 
19 
Q. Okay. All right. What other conflict 
21 
with your dad did you have that you described to 
21 
this psychologist that you saw in Wellington? 
22 
A. My dal and I, he just, he would — you know, 
23 
he would — he was never an affectionate person, and he 
24 
just would say things out of being anger, you know, 
25 
being angry and angered at the situation that happened. 
Page 97 
1 
home at night until like 6 or 8:00. It was, he was just 
2 
never home a lot. We didn't have a relationship, and 
3 
Pm sorry, I forgot your question, 
4 
the corset question, what it was. 
5 
Q. Well, when you, when you lust came down 
6 
front South Carolina and began living with him, who 
7 
was in the household beside you and he? 
8 
A. When I first carne down, it wet just him, my 
9 
brother, and myself. 
10 
Q. aM
ur brother, what's his name? 
11 
A. =. 
Doe No. 5. 
12 
Q. And how old was =I? 
13 
A. When I moved there, I'm not sure. 
14 
Q. How old is he now? 
15 
A. He's, he's 17. 
16 
Q. Okay. So he's, he's about six years or 
17 
five years younger than you? 
18 
A. Yeah. Yes. 
19 
Q. Okay. There was just the three of you. 
20 
And then did there come a time that someone else 
21 
joined the household? 
22 
A. Yes. 
23 
Q. Who was that? 
24 
A. 
25 
Q And about when was that? 
25 (Pages 94 to 97) 
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Page 100 
1 
A. Probably my sophomore 
2 
year. 
Q. And did you and 
3 
along when she moved in? 
4 
A. When she rust moved in, yes. 
..And 
for how long did you and 
get along? 
5 
7 
A. Probably maybe six months to a year. maybe. 
9 
Q. Did there come a time that the 
9 
relationship between you and 
began 
10 
to sour? 
13. 
A. Yes. 
12 
Q. When was that? 
13 
A. When she just decided to tell my dad all these 
14 
negative things about me. 
15 
Q. And what did she tell your dad about you? 
16 
A. I don't know the specifics. !just heard that 
17 
she was talking about me to my father, my brother told 
18 
me, negatively. 
19 
Q. What, what did he tell you that 
20 
told your dad? 
21 
A. That she was just talking bad about me. That 
22 
I should, you know, go away to boot camp and things like 
23 
that. 
24 
Q. Well, I want you to give me --
25 
A. I don't 
get 
1 
you aslut? 
2 
A. Probably my junior year. But it... 
3 
Q. "But it," what? 
4 
A. I was just going to say, but it wasn't like 
5 
you are a slut. It was just in one of his letters he 
6 
left on my bed calling me, you know, a slut, pig, you 
T 
know, whatever. 
8 
Q. And why is it that you relate that to your 
9 
junior year? 
10 
A. Because that's when I recall that that's --
11 
that's — I don't know why. I'm pretty sure it was my 
12 
junior year. 
13 
Q. Is there some event that you recall? 
14 
A. I !mow it was in my 
the reason I say that 
15 
is because it was in my dad's recent house, which was 
16 
junior-senior year. I was living them. 
17 
Q. And which house was that? 
18 
A. The house in Olympia. 
19 
Q. Now, you, you say he left some letter for 
20 
you on your bed? 
21 
A. Yes. 
22 
Q. Do you still have the letter? 
23 
A. No. I threw it out when I saw it. 
24 
Q. So this, this would have been a bed that 
25 
you had at the house in Olympia? 
Page 99 
Q. - as much specifics as 
can about what 
1 
2 
your brother told you that 
was telling your 
2 
3 
dad. 
3 
4 
A. There was no — there was nothing he told me 
4 
5 
that she specifically said besides that she, she thought 
5 
6 
I should be sent away to school because I was a bad 
6 
7 
child. He wouldn't tell me anything else because he 
7 
8 
said he didn't remember. 
8 
9 
Q. And do you recall when that, you were told 
9 
10 
that that conversation happened? 
10 
11 
A. 'think that was, I'm guessing, probably my 
11 
12 
junior year, maybe. 
12 
13 
Q. Did — were there other things that your 
13 
14 
dad called you, derogatory names? 
14 
15 
A. There's things that, I mean, right now I 
15 
16 
don't, I don't remember anything else. 
16 
17 
Q. Did he ever call you any derogatory names 
17 
18 
that had sexual connotations sort of associated with 
18 
19 
them? 
19 
21 
A. I'm sorry. What? 
20 
21 
Q. You know, a name that might really be 
21 
22 
intended to reflect upon sexual conduct that you may 
22 
23 
engage in or not engage in? 
23 
24 
A. He called me a slut at one point. 
24.
25 
Q. Do you remember when your father called 
25 
Page it
_ 
A. Yes. 
Q. You have your own room there? 
A. Yes. 
Q. Okay. And, and why did your dad leave you 
a letter on your bed? 
A. Because I didn't clean my room and he wasn't 
home. 
Q. And, and what did this letter say? 
A. He just called me a 
you need to clean your 
F-ing room; you're flunking out of school, you pig, 
slut, or whatever he called me..1 don't remember the 
exact letter. 
Q. Well, how did you react when you saw a 
letter such as that written to you by your own dad? 
A. It was hurtful. 
Q. Make you ay? 
A. I don't know. 
Q. Upset you? 
A. It upset me. 
Q. Had you done something that you thought 
warranted him characterizing you in this manner? 
A. No, he just — whenever he got mad at somebody 
including my brother, he's would just say any — he's 
called my brother a fagot for no reason. It's just 
names that he throws out there. 
PROSE COURT REPORTING 
26 (Pages 98 to 101) 
AGENCY, INC. . 
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Page 102 
1 
Q. Why — do you know why he was calling you 
2 
a slut? 
3 
A. No, it's just that's my father. He'll say 
4 
anything that sounds nasty. 
5 
Q. And he said you were flunking out of 
6 
school. Were you, in fact, did you get bad grades? 
7 
A. I was, I was doing bad. 
8 
Q. Had he left written messages to you on 
9 
other occasions? 
10 
A. Written? Not that I recall. 
11 
Q. Had he, had he given other messages to you 
12 
other than in writing on other occasions? 
13 
A. On my phone. 
14 
Q. What kind of messages? 
15 
A. Lae, just voicemail messages. 
16 
Q. What kind of voicemail messages would he 
17 
leave? 
18 
A. Get your ass home. 
19 
Q. That's how he would 
that's the kind of 
20 
message aleave to you? 
21 
A. Uh-huh. Yes. 
22 
Q. I mean, is that, is that — in, in your 
23 
view of the world, is that the way a father should 
24 
be treating his daughter? 
25 
A. No. 
Page 
1 
Q. So you never knew why? 
2 
A. Why she was going? 
3 
Q. Yes. 
4 
A. For herself? 
5 
Q. Right. 
6 
A. No. 
7 
Q. But the idea was she, she told you she was 
8 
going to go and she wanted to take you as well? 
9 
A. Yes. 
10 
Q. So you would both be seeing Dr. M' 
11 
A. We both 
she went previously, I guess for 
12 
herself. I don't know what the reason was. And then 
13 
she thought he was a good doctor to see, so she brought 
14 
me with her. 
15 
Q. Okay. So your mom, before she suggested 
16 
to you to go see 
M
I
 
had, herself, seen Dr... 
17 
A. Yes. 
18 
Q. On the occasion that she said that she 
19 
wanted to take you to see Dr. a 
she was going 
20 
to go see him for what would 
ve een her second 
21 
visit? 
22 
A. Yes. 
23 
Q. And you don't know why she went for either 
24 
visit? 
25 
A 
a 
With my visit, I know it was pertaining to me, 
Page 103 
1 
MR. MERMELSTEIN: Form. 
2 
BY MR. LIMIER: 
3 
Q. How did it make you feel when your dad 
4 
would leave you messages like that? 
5 
A. I would be angry. 
6 
Q. And how did you act out that anger? 
7 
A. I would just ignore him. 
8 
Q. Would that cause conflict between you and 
9 
him? 
10 
A. No, it was better that way. 
11 
.Anything else that IN leave, messages 
12 
that El leave for you on your voicemail? 
13 
A. That I would be grounded. I mean... 
14 
Q. Okay. Was there, there anything else that 
Ell? 
15 
you know of that caused your mom to 
that
sot  
16 
she thought you should go see this Dr.
17 
A. No, not that I recall. 
18 
Q. Did aavith 
her that you should go 
19 
see this Dr.
20 
A. I don't remember if I agreed with her or if, 
21 
or if I disagreed with her. I don't — honestly, I 
22 
don't remember. 
23 
Q. And did she ever tell you why she was 
24 
going to see Dr. =7 
25 
A. No. 
Page 105 
1 
and she would talk about our relationship. 
2 
Q. All right. So, was her suggestion to you 
3 
that you and she go together to see Dr. =7 
4 
A. Yes. 
5 
Q. Okay. So the purpose of her going to 
6 
Dr. 
on the occasion that she suggested the two 
7 
of you go was about your relationship with her? 
8 
A. Yes. 
9 
Q. And did you, in fact, go see Dr. Mr) 
10 
A. Yes. 
11 
Q. Where is Dr. IMIS 
12 
A. In Memphis, irnessee. 
13 
MR. LUTTIER: Okay. I'm going to need to 
14 
take a break myself right now. Too much 
15 
coffee. 
16 
THE VIDEOGRAPHER: Going off the record at 
17 
10:27E. 
18 
(A Ref recess was held.) 
19 
MR. LUTHER: We're back on the record at 
MR. 
• 
10:38 
21 
BY 
pmER. 
20 
22 
Q. Okay. So, so did you eventually go with 
23 
your morn to see Dr. I.? 
24 
A. Yes. 
25 
Q. And for what -- do you remember what year 
27 (Pages 102 to 105) 
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Page 106 
Page 108 
1 
it was even? 
2 
A. It was probably the summer going into my 
3 
sophomore year. 
4 
Q. Okay. That makes it the summer oft, 
5 
'02? 
6 
A. Mink so. Yeah, l was, I was, it was my 
7 
freshman year, and it was probably — I'm, I'm guessing, 
8 
bee-mote it was during the summer — that it was the 
9 
summer going into my sophomore year. 
10 
Q. Okay. So, whatever that — however that 
13. 
works out by age, what you do recall is you'd 
12 
finished your first year of high schooL 
13 
A. Yes. 
14 
Q. It was the summer after your first year of 
15 
high school. 
16 
A. Yes. 
17 
Q. Okay. And, and t think you told us 
18 
earlier, your chief complaint or the reason you were 
19 
going to see him was for depression? 
20 
A. It was depression and my mom and l's 
21 
relationship was not good anymore. 
22 
Q. Okay. And it's someplace in Memphis? 
23 
A. Yes. 
24 
2Sd 
did and for how long did you go see 
25 
Dr.MI? 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A. I don't recall. 
Q. Your best recollection. 
A. Five or seven days. I don't —
Q Okay. So it was a fairly lengthy period 
of time? 
A. Yes. 
Q. And you would golgrthr„ most of the day 
over to see this fellow, DS? 
A. Yes. 
Q. Would you see just Dr
 or did you 
see other people, too? 
A. Just him. 
Q. It was just you and your mom? 
A. Yes. And he would do us separately. 
Q. Not to be flipgistit what did you and 
your mom talk to Dr..11 about all day for five to 
seven days? 
MR. MERMELS1TIN: Form. 
THE WITNESS: It would be — he would ask 
me what my problems were in high school, how 
people treated me in high school friend-wise, 
friends that I had, things that I didn't like 
that friends did, my relationship with my mom, 
why it became the way it did, my stepfather, my 
father, things of that sort. 
Page 1C 
1 
A. It was -- we went there for about a week. 
2 
Q. Oh, this is like a facility you go to? 
3 
A. He had his oven office, but he also had like an 
4 
apartment available to his clients that they would stay 
5 
there and come to him daily for a week. 
6 
Q. So, is that what you and your mom did, you 
7 
stayed in some apartment that he provided? 
8 
A. Yes. 
9 
Q. And then during the day you would go to 
10 
his office? 
11 
A. Yes. 
12 
Q. And is he, is he a physician by himself, 
13 
or was there a group? 
14 
A. It was his family, his son I think worked for 
15 
him afro. 
16 
Q. And how — and when you went over to see 
17 
him, were you, were you going for 45 minutes a day 
18 
or was it longer than that? 
19 
A. It was longer than that. I don't recall 
20 
exactly how many hours it was, but it wasn't short 
21 
periods of time. 
22 
Q. Was it Bice an all-day thing? 
23 
A. Yeah, pretty much. 
24 
Q. Okay. So, you were there for, when you 
25 
say a week, you mean five days? 
Page 109 
1 
BY MR. LOFTIER: 
2 
Q. You gave him — would it be fair to say 
3 
you give him a comprehensive history of whatever had 
4 
occurred in your life up to that point in time? 
5 
A. Yes. 
6 
Q. Would you literally sit in his office for 
7 
five or six hours? 
8 
A. Probably. I'm not sure if it was five or six, 
9 
but around that time. 
10 
Q. Okay. And, and, and then if he was 
11 
meeting just with you, your mom would be off doing 
12 
something else? 
13 
A. Yes. 
14 
Q. And If he was meeting just with her, you 
15 
would be off doing something else? 
16 
A. I would be at the apartment. 
17 
Q. At the condo. So sometimes just one of 
18 
you would go over and see him? 
19 
A. Yes. 
20 
Q. Did you take any kind of tests? 
21 
A. I don't remember if I took tests, but I know I 
22 
did some homewodc and writing, and I would have to read 
23 
his chapters io his book 
24 
Q. Is it the same book that you have at your 
25 
house? 
28 (Pages 106 to 109) 
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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 110 
A. He gave me like three of them, but the only 
one I found was the one, and I don't remember if that 
was the book that I read or not. 
Q. Did you take all three back home? 
A. I took them with me, but I don't know where 
they've gone. 
Q. Well, obviously, one of them you kept. 
A. One of them I have, but the other, l don't 
know where the other two went. 
Q. And when you say you took them home, you 
brought them back to Wellington where you were 
living with your dad? 
A. Yes. 
Q. So you apparently kept one of them since 
then. 
A. Yes. I don't know where the other two have 
gone. 
Q. 
kept? 
A. No. I did when I was there. He gave me the 
assignments. 
Q. Would you read the whole book or... 
A. No, hejust made me read like a chapter. 
Q. So you never sat down and read the book 
cover to cover? 
Have you ever read this book that you 
Page 112 
1 
A I do not know if I- I Icon, I personally 
2 
don't have them. 
3 
Q. Do you know if yout mom has them? 
4 
A. I don't know. 
5 
Q. Have you ever asked her? 
6 
A. No. 
7 
Q. Did, did Dr. =give you any formal 
8 
diagnosis? 
9 
A. No. 
10 
Q. Did he recommend that you seek any further 
11 
treatment after you left him? 
12 
A. No, not that I recall. 
13 
Q. Did he come up with any solution to your 
14 
problems? 
15 
A. Not that I remember. 
16 
Q. Did you and your mom leave at the end of 
17 
this week feeling better about each other than you 
18 
did when you got there? 
19 
A. I didn't. I don't know if she did. 
20 
Q. Still were a little upset with her? 
21 
A. Yeah, 'just felt like he did nothing forme, 
22 
but... 
23 
Q. Okay. And, and what you told 
24 
though, whether it was in these writings or m his 
25 
notes, was the truth? 
Page 111 
1 
A. No. 
2 
Q. How about the other two that you don't 
3 
have anymore, did you read them cover to cover? 
4 
A. No. 
5 
Q. And you just don't know where the other 
6 
two went? 
7 
A. No. 
8 
Q. How about the work product that you 
9 
generated? You said you would get homework. You 
10 
had to read the chapters and you had to do some 
11 
other things. 
12 
A. Yes. 
13 
Q. Did you have to do writings? 
14 
A. Yes. 
15 
Q. In like, like a diary type of writing? 
16 
A. Not a diary. • Just like fights that my mom and 
17 
I have had, or fights that my father and I have had, and 
18 
what I feel about them. 
19 
Q. And what happened with those writings? 
20 
A. 'have no idea. 
21 
Q. Did you give them to him or did you keep 
22 
them? 
23 
A. I gave them to him. I don't recall if he gave 
24 
them back or not 
25 
Q. Do you know if you have them? 
Page 113 
1 
A. Yes. 
2 
Q. And you told him the things that had 
3 
happened to you in your life up to that point in 
4 
time that you felt were significant. 
5 
A. Yes. 
6 
Q. You mentioned that you told him something 
7 
about how you were treated in high school. 
8 
A. Yes. 
9 
Q. Do you recall what you told him about how 
10 
you were treated in high school? 
11 
A. When I was in South Carolina, you know, there 
12 
was girls there that wanted to cut my hair off and do 
13 
crazy things to me, and that was a word of mouth. 
14 
Q. What do you mean by "crazy things"? 
15 
A. Supposedly, this is what some kid told me in 
16 
school, that they were in a gang and they wanted to, you 
17 
!mow, cut my hair or kill me, butIdon't know if that 
18 
was accurate or not. 
19 
Q This is someone at the school that you 
20 
were attending in South Carolina told you that other 
21 
kids were saying that about you? 
22 
A. Yes, other girls. 
23 
Q. Or should I say other — did you say other 
24 
girl? 
25 
A. This was a guy that told me this, but it was 
IllA410.1..tiaberM SI 
29 (Pages 110 to 113) 
PROSE COURT REPORTING AGENCY, INC. 
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Page 114 
Page 116 
1 
about a group of girls. 
Q. Okay. So a, a male fellow student at the 
3 
school in South Carolina told you that there were 
4 
girls at that school that wanted to do these bad 
5 
things to you? 
A. Yes. 
Q. And did you believe him when ire told you 
3 
these things? 
9 
A. i didn't know. I was a little bit scared for 
10 
my — you know, i didn't know why. You know, from what 
11 
he told me it was scary, but I didn't know if it was the 
12 
math or not. 
13 
Q. So, did you avoid interacting with these 
14 
girls? 
15 
A. Yeah. 
16 
Q. And did they ever do anything to you? 
17 
A. They would, you know, verbally curse me out, 
18 
and I would just sit there quietly and take it. 
19 
Q. Did they ever do anything to your hair? 
20 
A. No, they never physically did anything to me. 
21 
Q. How about did they do, you know, kind of 
22 
things like stick stuff in your hair? 
23 
A. No. 
24 
Q. Gum, things like that. 
25 
A. That was, that was in Fort Lauderdale. 
1 
Q. You say you told Dr. 
2 
that you had? 
3 
A. Yeah. 
4 
Q. Would these have been friends that you had 
5 
in Florida or friends that you had in South 
6 
Carolina? 
• 7 
A. He was asking me about all my friends 
8 
throughout my life and good friends that have stuck by 
9 
me and friends that have done things to me, and those 
10 
girls, Fm not considering them friends, but just people 
11 
in my life. 
12 
Q. Okay. Other than going over to 
13 
Dr. ME office and meeting with him during this 
14 
one-week period, did you, did Lou do anything else 
15 
when you went to see Dr. I. 
in the summer of --
16 
between your ninth and tenth grade? 
17 
A. Did I do anything else? 
18 
cI
Anything else as part of that visit to 
19 
Dr. MI other than going and sitting and talking 
20 
with him. 
21 
A. No,1 mean, just the books that he gave me and 
22 
the homework. That's basically it. 
23 
Q. Anybody else participate in that therapy, 
24 
for lack of a better term, besides you and your morn? 
25 
A. No. 
about friends 
Page 115 
1 
Q. Okay. Gum in your hair was in Fort 
2 
Lauderdale before you went to South Carolina? 
3 
A. That was when i was in middle school in Fort 
4 
Laudadak. 
5 
Q. Okay. 
6 
A. It was a trip to Orlando, and this girl wanted 
7 
to put gum in my hair. 
8 
Q. Okay. So these — how else were these 
9 
girls verbally abusive towards you? Did they call 
10 
you names or what? 
11 
A. They wouldn't call me names. They would just, 
12 
you know, tell me to turn the F around or just try to 
13 
intimidate me. 
14 
Q. And how would you react? 
15 
A. i would just stay quiet and turn around. 
16 
Q. And within — was that part of the reason 
17 
why you left South Carolina? 
18 
A. That was one of the reasons, you know. Also 
19 
my stepfather was part of it 
20 
Q. Okay. This was upsetting to you to be 
21 
going to school and having these people do these 
22 
things? 
23 
A. Yes, it was upsetting. 
24 
Q. And you told this Dr. 
about that? 
25 
A. Yes. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 117 
Q. Did he recommend anything at all when you 
left there that you're aware of? 
A. That I'm — I don't know what he told my 
mother. He saw us separately at the end. But from what 
I'm aware of, i don't recall. I don't know if he did or 
not. I don't remember what he said to me because I just 
didn't feel like it helped. 
Q. When was the last time you had any 
communication with Dr. a? 
A. When I went That was —
Q. Have you attempted to contact him at 
anytime since then? 
A. No. 
Q. Or contact his office? 
A. No. 
Q. Or get records from him? 
A. No. 
Q. Have you attempted to get copies of your 
records from the female psychologist you said you 
saw in Virginia? 
A. Records? 
Q. Right. You know, contact their office and 
. say, you know, give me your notes, your records, any 
documentation. 
A. I never got anybody's notes. 
41103•11911iStibitIssOal•Mii....... 
30 (Pages 114 to 117) 
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Page 118 
1 
Q. Did you get anything from her? 
2 
A. If I did, it might have -- I don't recall, but 
3 
it might have been to get a prescription or to transfer 
4 
a doctor or something I don't recall that. 
5 
Q Okay. Well, 1, I, I had more in mind. 
6 
Did, did you or anybody on your behalf contact them 
7 
and try to get whatever records they had about you? 
8 
A. Personally, I don't remember. 
9 
Q. How about contacting the female 
10 
psychiatrist you said you saw in Virginia, have you 
n 
done that and tried to get any records? 
12 
A. I don't remember. I don't think so. 
13 
Q. Have you attempted to contact — have you 
14 
had any contact with the female-
15 
MR. LUITIER: Okay, whenever you have to 
16 
change, just tell me. 
17 
BY MR. LUTTLER: 
18 
Q. Have you made any attempt to contact the 
19 
female psychologist in Virginia since you, your last 
20 
visit with her? 
21 
A. Not that l remember. 
22 
Q. How about with the female psychologist in 
23 
Virginia, since your last visit her? 
24 
A. I don't remember. No, not that I remember. 
25 
Q. Have you attempted to contact in any 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 120 
Q. I'm going to show you these copies. 
A. Okay. 
Q. I'll leave it up to your counsel. I 
don't, I don't know that we need to attach them, but 
I wanted to give these to you and give you a chance 
to look at them. 
Now, these necords, the, there's a 
cover letter there addressed to a Dr. 
A. Yes. 
Q. Do you know that physician to be -- by 
that I mean have you ever seen that physician? 
A. Yes, Ilmow that name. I just can't pronounce 
it 
Q. Who is she, or why did you go to her? 
A. I don't know if she — I don't know if she was 
the psychiatrist or the psychologist I went to. 
Q. Are you talldng now -- you earlier 
testi ficd that you saw a female psychologist and a 
female psychiatrist in Virginia. 
A. Yes. 
Q. There was, there was only one of each that 
you saw in the State of Virginia? 
A. I'm pretty sum, yes. 
Q. Okay. And you think this doctor is either 
Page 119 
1 
manner the male psychiatrist who you saw in Delray 
2 
Beach in Florida since you last saw him? 
3 
A. No. 
4 
Q. Tried to get his records or anything like 
5 
that? 
6 
A. No. 
7 
Q. Have you done any contact with the female 
8 
psychiatrist that you went to see in West Palm Beach 
9 
since you last saw her? 
10 
A. No. 
11 
g 
Tried to get her records? 
12 
A. No. 
13 
g Have you bad any contact with the 
14 
psychologist over in the Greenville shops since you 
15 
last visited with him? 
16 
A. No. 
17 
Q. And your last visit with him was about, 
18 
somewhere around June of '09? 
19 
A. Around that time. 
20 
Q. Did you have, have you tried to get his 
21, 
records? 
22 
A. No. 
23. 
Q. . I'm going to show you some records that we 
24 
• obtained. They came from your lawyer. 
25 
A. Okay. 
Page 121 
1 
a psychologist or a psychiatrist? 
2 
MR. MERMELSTEIN: Look at the reference. 
3 
BY MR. LITITIER: 
4 
g 
Yeah, feel free to look at them. And I'm 
5 
just going to — there's some office notes them, 
6 
and you'll see on the office notes, there's a 
7 
that came with these records that I got where it 
8 
says diagnosis, this is the one that says dermatitis 
9 
on it 
10 
A. Okay. 
11 
Q. See that, that page you're looking at 
12 
right there with the handwriting on it. Down at the 
13 
bottom left-hand corner it says, diagnosis, 
14 
dermatitis. 
15 
And I, and I also point out to you 
16 
that the physician's signature that appears on the 
17 
page containing the office notes dated 
18 
December 18th, '07, I, I I look at that and it 
19 
looks to me like it says 
somebody but, you 
20 
know, I couldn't swear to it 
21 
A. So, then this — 
22 
Q. Well, believe me, you're welcome to look 
23 
at all those records. And after you've looked at 
24 
them, then I want you to tell me if you can remember 
25 
who this Dr. 
is or what she was to you, that 
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Page 122 
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is, you blow, why you saw her. 
2 
A. Is — if this was a prescription for the 
3 
dermatitis, then this isn't — this has to be probably 
4 
my PCM. 
5 
Q. Primary cam physician? 
6 
A. Yeah. Yes. 
7 
Q And now you're referring to the 
8 
prescription notice that's here that's dated 
9 
February I8th, '07? 
10 
A. Yeah, I don't know if this is a —
11 
THE V1DEOGRAPHER: Excuse me, sir. We're 
12 
going to have to change the tape. 
13 
MR. LUTTIER: Okay. Go ahead. 
14 
THE VIDEOGRAPHER: Going off the record at 
15 
10:55 
This marks the end of Tape I. 
16 
(A brief recess was held.) 
17 
THE VMEOGRAPHER: We're back on the 
18 
record at 10:57 ■ 
This marks the beginning 
19 
of Tape 2. 
20 
BY MR. LUTT1ER: 
21 
Q. Okay. You see these office notes, the 
22 
handwritten ones that include a prescription, that 
23 
they're all dated December 18th, 2007? 
24 
A. Yes. 
25 
Q. All right. This is -- these office notes 
1 
history was completed for? 
2 
A. This is myself, so... 
3 
Q. But, I mean, do you know what doctor you 
4 
were — is this, is this something you did for this 
5 
doctor that, that treated you for this dermatitis? 
6 
A. I'm guessing if the — I mean, this is — came 
7 
with the records. 
8 
Q. Okay. In your answers to interrogatories 
9 
the physician that you say you saw for dermatitis 
10 
was a 
11 
noticeoiiMtiv.t;nottr. 
And you 
at least 
14 
13 
1.
anSo this is a different physician 
you 
12 
at the top of the lab slip, it says 
saw 
the one that you referred to in your 
15 
answers to interrogatories? 
16 
A. Yeah, I guess so. 
17 
Q. And if you look at the handwritten office 
18 
notes the references to that are to facilities known 
19 
as 
20 
A Yes. 
21 
Q. So, is the — whoever's records these 
22
are-
23 
A. Yes. 
24 
Q. — that physician is not listed in these 
25 
answers to interrogatories? 
I 
Page 123 
1 
are not from your psych, the psychologist or 
2 
psychiatrist that you saw in Virginia; is that 
3 
coned? 
4 
A. Conect. 
5 
Q. And there's a cover page called, called 
6 
patient medical history. Was that completed by you? 
7 
Right there? 
8 
A. Yes. 
9 
Q. Is that your handwriting on there? 
10 
A. Yes. 
11 
Q. And 1 don't know, under the date it looks 
12 
like it says December 18th, '02. 
13 
A. Uh-huh. 
14 
Q. Was that, is that an accurate date or —
15 
when you filled that out or is it... 
16 
A. It had to have been. 
17 
Q. Well, if you look down to the history, you 
18 
said where it says, explain, give dates and reasons 
19 
known. It said, had baby November 24th, '07. 
20 
A. Yes. 
21 
Q. All right. So, you — this is not a 
22 
record you completed in '02 then apparently, because 
23 
you had no way in '02 to say you had a baby in '07. 
24 
A. Oh, I guess not. 
25 
Q. Do you know who this patient medical 
PROSE COURT 
Page 125 
1 
MR. MERMELSTEIN: If I can interject here? 
2 
MR. unTIER: Sure. Oh, yeah. Help any 
3 
way you can. I'm happy to get an answer. 
4 
MR. MERMELSTEIN: This letter cant back in 
5 
response to the request made to 
6 
MR LUTHER: Right 
7 
8 
can't pronounce that, but, but tsMi
lle 
MR. MERMELSTEIN: — 
1 
9 
conic back from her as indicated in the cover 
10 
letter with the initials there indicating it 
11 
was the same --
12 
MR. LUITIER: But as you can see, it 
13 
appears that these records are not signed kg 
14 
her. I don't know who they're signed by. 
15 
MR. MERMELSTEIN: But apparently, you 
16 
know, she had control of them. 
17 
BY MR. LUTHER: 
18 
Q. All right. Anyway, so am-trendy there is 
19 
another physician that's not listed on your answers 
20 
to intenogatories? 
21 
A. You're asking me that? 
22 
Q. Yeah. 
23 
A. Yes, I mean 
24 
Q. Okay. All right All right. Other than 
25 
the physicians you've now told me about today --
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A. Yes. 
2 
Q. — and the physicians listed in your 
3 
answers to interrogatories that you provided in this 
4 
case, have you seen any other doctors at all in the 
5 
last five years? Well, let me put it — I don't 
6 
know. 
7 
Let me give you a date. Have you 
8 
seen any other doctors since January 1 of 2001? 
9 
A. Beside the ones, like, in front of me? 
10 
Q. Right In front of you meaning your 
11 
answers to interrogatories —
12 
A. Yes. 
13 
Q. — and the other doctors we've identified 
14 
in this deposition. 
15 
A. Yeah. Not that I can remember, I mean... 
16 
Q. Just, just to be complete, because 
17 
trying to trick you. I realize you saw Dr. 
18 
right? 
19 
A. Yes. 
21 
Q. And you saw Dr. 1.1 
21 
A. Yes. 
22 
Q. So I know about those. 
23 
A. Yes. 
24 
Q. Other than 
the doctors that 
25 
are listed in your answers to interrogatories and 
Page 128 
1 
A. One of the doctors that I have given you the 
2 
names of where they're located. 
3 
Q. Okay. What doctor is she? 
4 
A. Well, she — do you know if she was a 
5 
psychiatrist or a psychologist? 
6 
Q. My information is that she's not a doctor. 
7 
She may be a certified nurse practitioner or 
8 
something. 
9 
A. So, then, I'm guessing that mail
10 
prescribed one of my medications for 
11 
Q. 
Where is her office? 
12 
A. 
I, I've seen so many doctors 
13 
within the past couple of years for mental health that 
14 
honestly 1 cannot put a name with the face. I don't 
15 
know. 
16 
Q. Okay. Okay. Other than all 
17 
whoever she may be — you don't even know what state 
18 
she's in? 
19 
A. I'm guessing Virginia, but that might not be 
20 
accurate. 
21 
Q. Okay. Do, do you remember her enough to 
22 
know if she's somebody you selected for some reason? 
23 
A. If I selected her — the only doctor that was 
24 
selected out of, like, you know, somebody telling me or 
25 
referring is the, the male psychologist that I saw 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
• 
}fav
o urer 
heard of the name 
23 
24 
A. Yes. 
25 
Q. 
Page 127 
the other doctors that you identified for the first 
time in today's deposition, are there any other 
doctors that you've seen since January of 2001? 
A. Any type of doctors, as in even my pregnancy, 
Q. Let's — yeah, I want to know about any 
time, any kind of doctors? 
A. Eye doctors, even like that? 
Q. Yep, if you've seen a doctor, I want to 
know who they are. 
A. Oh, my God. 
Q. But let's, let's, but let's start — let's 
break this down. Any other mental health doctor? 
By mental health doctor I mean a psychologist, a 
psychiatrist, a licensed social worker, because 
they're not technically a doctor, but any other 
mental health professional. 
A. No. 
Q. All right. Now 
discovered the name 
A. 
Page 129 
1 
there. 
2 
Q. Over in Wellington in the Greenview 
3 
plaza — 
4 
A. Yes. 
5 
Q. — or whatever it was? 
6 
A. Everything else was by the 
7 
they give on the Web si 
8 
Q. Okay. Now, Drt.ela 
that's a 
9 
psychiatrist that you saw with respect to the 
10 
lawsuit that you have pending against Mr. Epstein? 
11 
A. Yes. 
12 
Q. You were sent there by your lawyer? 
13 
A. Yes. 
14 
Q. You didn't pick him, somebody told you to 
15 
go see him? 
16 
A. Yes. 
17 
Q. And he hasn't rendered any treatment to 
18 
you; is that right? 
19 
A. Treatment, as in —
20 
4 
Therapy, go see him about —
21 
A. No, no, nor 
22 
Q. He just did what's known as an evaluation 
23 
of you? 
24 
A. Yes. 
25 
Q. And so where did that evaluation take 
list that 
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1 
place; that is, where did you set him? 
2 
A. That was in Miami. 
3 
Q. Okay. I mean 
is actually, his 
4 
office is in California someplace? 
5 
A. Yes. 
6 
Q. And so you went and met him in Miami? 
7 
A. Yes. 
8 
Q. How many times? 
A. Once. 
Q. Did you see him more than one time? 
A. No. 
Q. And how long was the visit in Miami? 
A. It was, it was morning to afternoon. I don't 
recall the times. 
Q. Okay. About, about a day? 
A. Not a day. 
Q. It was less than a day? 
A. Yeah, it was kss than a day. 
Q. Okay. I moan, four or five hours? 
A. I think it was more than that. 
Q. Okay. But it was, all happened in one 
day? 
A. Yes. 
Q. And, and did he have you do some tests? 
A. Yes. 
1 
about Dr.._t before you went there? 
2 
A. Yes. 
3 
Q. Who did you talk to? 
4 
A. My husband. 
5 
Q. Okay. And what did you and your husband 
6 
discuss? 
7 
A. That I had to see hint 
8 
Q. Okay. Did you talk about anything more? 
9 
A. Not that I recalL 
10 
Q. Did you tell your husband why you had to 
11 
sets him? 
12 
A. Yes. 
13 
Q. What did you tell him? 
14 
A. I had to see him for the lawsuit I was in. 
15 
it
s Okay. So the only reason you went to 
16 
was because of this lawsuit that was pending? 
17 
A. Yes. 
18 
Q. And It's somebody your lawyers told you 
19 
you needed to go see? 
20 
A. Yes. 
21 
Q. And since you went down there one day, you 
22 
haven't seat him since? 
23 
A. Yes. 
24 
Q. Meaning that my statement is correct? 
25 
A. Yea 
Page 131 
1 
Q. Okay. And you completed those tests? 
2 
A. Yes. 
3 
Q. And they're all answered true and comet? 
4 
A- Yes. 
5 
Q. Did you have any discussions with anyone 
6 
about what you were to do when you went to see 
7 
Dr. 
before you went there? 
8 
MR. MERMELSTEIN: Form. 
9 
THE WITNESS: As in? 
10 
BY MR. LUTfIER: 
11 
Q. Did you talk to anybody about Dr. 
12 
before you went to see him? 
13 
MR. MERMELSTEIN: Other than your lawyer. 
14 
BY MR. LUTHER: 
15 
Q. Yeah, don't tell me what your lawyer said. 
16 
I assume —
17 
A. Yeah. 
18 
Q. I assume somebod
o sold you that you had an 
19 
appointment to see Dr. 
at some time and in 
20 
some place. 
21 
A. Yes. 
22 
Q. And I'm going to guess that came from your 
23 
lawyer's office, that part. 
24 
A. Yes. 
25 
Q. All right. Did you talk to anybody else 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21. 
22 
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Page 133 
Q. Have you had any communication with him at 
all? 
A. No. 
Q. Have you ever seen any materials that were 
generated either by when you visited with him, such 
as test results? 
A. 
A. 
A. 
A. 
A. 
A. 
A. 
No. 
Answer sheets? 
No. 
Any reports that he's done? 
No. 
Any transcripts of anything that went on? 
No. 
Was it, was it videotaped? 
Yes. 
Have you seen the videotape? 
No. 
Have you reviewed any of that material? 
No. 
Did you review anything in preparation for 
your deposition today? And by review I mean did you 
look at anything to get ready for today's depo? 
A. As in? 
Q. Anything. 
A. Anything? 
salladaSMSCIIIIIIRINDeat 
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1 
Q. Yeah, anything. And I mean that in the 
2 
broadest sense. 
3 
A. Yes. 
4 
Q. What did you review? 
5 
A. I just went over that paper like with my jobs 
6 
and everything. 
7 
Q. Okay. What you're pointing at now are 
8 
your, your answers to interrogatories in this case? 
9 
A. Yes. 
10 
Q. And it, and would that be the answers to 
11 
your first set of answers to interrogatories that 
12 
are signed by you January 26th, '09? 
13 
A. rm pretty sure. I mean, I didn't go over the 
14 
material. I just had it on me and I looked through it 
15 
It wasn't like I sat there and, you know, read every 
16 
little page. 
17 
Q. What do you mean, you had it on you? 
18 
A. I had it and I looked at it 
19 
Q. Did somebody send it to you? 
20 
A. They sent it to me through the mail, I think. 
21 
Q. Okay. 
22 
A. Through the, through e-mail. 
23 
Q. They were e-mailed to you, your answers to 
24 
interrogatories? 
25 
A. Yes. 
Page 136 
1 
Q. — within the scope of reviewing. 
2 
A. I didn't look through every page, no. 
3 
Q. Did you look at the complaint in 
4 
preparation for your deposition? 
5 
A. No. 
6 
Q. Well, do you have a copy of your 
7 
complaint? 
8 
A. Not on me. I don't - 
9 
Q. Other than these answers to 
10 
interrogatories that you served — that were served 
11 
in January of '09, that consist of, I don't know, 
12 
ten or IS pages, is there any other piece of paper 
13 
you looked at in preparation for your deposition? 
14 
A. Something to be prepared for a deposition. 
15 
Q. What, say what? 
16 
A. To be prepared. 
17 
MR. MERMELSTEIN: That's what he's asking 
18 
you, what, what you reviewed. 
19 
BY MR. LUTTIER: 
20 
Q. Did you say you did look at something 
21 
else? 
22 
A. To be — yes. 
23 
Q. What did you look at? 
24 
A. To how to be prepared for your deposition. 
25 
Q. Oh, some kind of summary that says this is 
1 
2 
3 
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Page 135 
Q. So that you could review them before your 
depo? 
A. Yes. 
Q. Okay. Anything else other than those 
answers to interrogatories that you reviewed? 
A. You have to give me a second to think about 
it. 
Q. Sure. 
A. Not that, I mean, that I could think of. 
Q. Okay. And did you only see one set of 
answers to interrogatories? 
A. I think that this is? 
Q. Right that's what that, that paper is 
there. 
A. I think so. 
Q. Did you review your -- the, what's known 
as the complaint that you filed in this case? 
That's the document where you made your allegations 
against Mr. Epstein. 
A. Did I like read through them? 
Q. Yeah, review the complaint. And I don't 
want to get hung up on semantics about what the word 
"review" means. I mean, if you looked at it as far 
as I'm concerned that is --
A. I, I didn't - 
1 
2 
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Page 137 
what you should do to get ready for your depo? 
A. Yes. 
Q. Probably from you lawyer that says, you 
know, this is what a depo —
MR MERMELSTEIN: Don't talk about what it 
says. 
BY MR. LUTHER: 
Q. Okay. All right Something you got from 
Your lawyer? 
A. Yes. 
Q. But it was a generic thing? 
MR. MERMELSTEIN: Again, don't talk about 
what it says. 
MR. LIMIER: Strike that question. 
BY MR. LUTHER: 
Q. Any, any other piece of paper that you 
reviewed? 
A. Not that — I mean, to me these all look the 
same. 
Q. Okay. 
A. I mean, that's... 
Q. All right. So that's it. Your answers to 
interrogatories and something from your lawyer about 
preparing for the depo? 
A. Yeah, that's all I can remember. 
35 (Pages 134 to 137) 
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Page 138 
Q. Have you ever seen any police reports of 
any kind or nature that have anything to do with 
Mr. Epstein? 
A. Police reports? 
Q. Police reports. 
A. As in, like, on a piece of paper? 
Q. Well, a piece of paper, videotape or any 
other way. Have you ever seen any police reports? 
A. No. 
Q. Have you ever reviewed any police reports 
that concern Mr. Epstein or anybody that claims they 
went to Mr. Epstein? 
A. Reviewed any police reports? 
Q. Right. 
A. Like an actual police report? 
Q. Yeah. 
A. No. 
Q. Have you ever been told about any police 
reports by anybody, whether it's one of your 
friends, your lawyer or anybody else? 
A. No. 
MR. MERMELSTEIN: Obviously, don't talk 
about what your lawyer said. 
MR. LUTHER: Yeah, don't tell me what 
they said. 
1-age 
1 
A. I don't recall. 
2 
Q. Well, was it somebody that had involvement 
3 
with Mr. Epstein? 
4 
A. Most Ificely, yes. 
Q. I mean otherwise why would this person 
6 
have -
7 
A. Yeah. 
8 
Q. — any reason to bring to your attention, 
9 
Mr. Epstein? 
10 
A. Yes. 
11 
Q. So, so who of your friends had involvement 
12 
with Mr. Epstein? 
13 
A. I had — 
14 
THE WITNESS: Am I allowed to say this? 
15 
MR. MERMELSTEIN: The — 
16 
THE WITNESS: To tell this? 
17 
MR MERMELSTEIN: — the question was to 
18 
identify whatever friends had involvement with 
19 
Epstein. 
20 
THE WITNESS: So I can tell him? 
21 
MR. LUTTIER: Yeah. 
22 
THE WITNESS: I mean, I don't know if it 
23 
was allowed by — 
24 
MR. LUTHER: Yeah, you can give me the 
25 
names. 
Page 139 
1 
THE WITNESS: No, yeah. 
2 
BY MR. LUTHER: 
3 
Q. Are you aware that there was an 
4 
investigation by the, the Town of Palm Beach Police 
5 
Department? 
6 
A. Against Epstein? 
7 
Q. Yeah. 
8 
A. Yeah. 
9 
Q. How are you aware of that? 
10 
A. 'heard about it, I think, through somebody in 
11 
Virginia. 
12 
Q. Okay. And who would that be? 
13 
A. I don't recall who told me. It was one of my 
14 
friends from Florida. They told me that he had a — he 
15 
was being arrested or something along those lines. I 
16 
don't recall exactly what was said. 
17 
Q. Okay. So, so you — when you said it was 
18 
information you got in Virginia, you mean you were 
19 
in Virginia when this information was imparted to 
20 
you? 
21 
A. Yes. 
22 
Q. But it came from one of your friends in 
23 
Florida? 
24 
A. Yes. 
25 
Q. And what friend was that? 
1 
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Page 141 
THE WITNESS: Okay. 
MR. MERMELSTEIN: . I, I'm not sure I 
understand why. 
THE WITNESS: I, I don't know. Just I 
didn't want 
you know, I don't know if I'm - 
I don't know. 
BY MR. LUTHER: 
Q. You were concerned about whether you can 
give me their names? 
A. Yes. 
Q. Yeah. 
MR. MERMELSTEIN: You mean in tams of 
confidentiality? 
THE WITNESS: Yeah. I didn't know. 
MR. MERMELSTEIN: Well, we've been taking 
care of that on the transcript. 
MR.. LUTHER: Right. 
MR. MERMELSTEIN: We'll use their initials 
for purposes of this or, or some other form to 
protect than. 
THE WITNESS: So just their initials, 
then? 
MR. MERMELSTEIN: No, no. You give the 
name —
THE WITNESS: Okay. Okay. 
PROSE COURT REPORTING 
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Page 142 
MR. MERMELSTEIN: — and the court 
molter —
THE WITNESS: Oh, okay. 
MR. MERMELSTEIN: — will put the 
initials. 
THE WITNESS: All
 fm not used to 
this, so. There is M., M. 
BY MR. LUTTIER: 
Q. M. what? 
A E. 
. There was M. and M. 
Q. 
? 
A. 
(Witness spells first name.) 
Q. (Mr. Luttier spells first name.) What's 
her last name? 
A. S. 
Q. (Mr. Luttier partially spells last name.) 
A. Yeah, (Witness spells last name.) I think. 
Q. Okay. Any other of your friends that have 
had involvement with Mr. Epstein? 
A Not that I'm aware of. 
Q. Was it one of these girls that called you 
when you were in Virginia and told you of 
Mr. Frtein? 
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Page 143 
1 
A Yeah, I am guessing so. I just have to think 
1 
2 
about it and remember who it was. 
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3 
Q Were — which of these girls - were any 
3 
4 
of these girls what you would consider to be your 
4 
5 
best fricia 
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6 
A. M. has been close to me. 
6 
7 
Q. Still close to you? 
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8 
A. I still talk to her, yes. 
9 
Q. When was the last time you talked to her? 
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10 
A. Today. 
10 
11 
Q. And when did you talk to her? 
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A. Pm actually staying at her house since I flew 
12 
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down from Virginia. 
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Q. And she made a claim against Mr. Epstein, 
14 
15 
right? 
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A. Yes. 
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17 
Q. And what did she tell you about that? 
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A She didn't really tell me much about it. 
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19 
Q. Well, my question is: What did she tell 
19 
20 
you about it. 
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A. That she was going against Epstein. That's — 
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!mean — 
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Q. Well, she told you more. She told you 
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about what's happened to her claim, hasn't she? 
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MR. MERMELSTEN: Form. 
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Page 144 
THE WITNESS: She just said it was, you 
know, she's done with it. I don't — I, all I, 
anti:now is like ifs, it's over with her. 
BY MR. LUTI1ER: 
Q. Well, would — I want you to tell me 
exactly what she told you about it —
A. Exactly. 
Q. — quote, being over. 
A. She just said she's done. That's all she told 
me and she won't tell me anymore. 
Q. So you're, you're staying with her, right? 
A. Yes. 
Q. And how long have you been with her? 
A. I just got in — when did I get in? Wednesday 
she picked me up from the airport. 
Q So you've been here since Wednesday? 
A. Wednesday night. 
Q. Okay. And, and the only discussion you 
had with her about her claim with Mr. Epstein was 
you said she said it was over? 
A. Yes. 
Q. And she — did she tell you how it got 
resolved? 
A. No. 
Q. Did you ask her? 
Page 
a 
A I asked her. 
Q. What did she say in response to your 
question? 
A I can't tell you. 
Q. Okay. Did she, although she didn't tell 
you with specificity, did she say anything at all 
about how it was resolved? 
A. No. 
Q. Did she show you any paperwork? 
A. No. 
Q. Did you ask her anything more about this 
claim? 
A. No. 
Q. So, you — although this lady had a claim 
against the same person that you're making a claim 
against —
A. Uh-huh. 
Q. — and you spent the night with her, the 
totality of your conversations with her about 
Mr. Epstein and her claim was a statement that she 
made to you that it was over? 
A. Yes. 
MR. MERMELSTEIN: Form. 
THE WITNESS: But that was before. I 
mean, that wasn't since I've been here.  She 
===== 
37 (Pages 142 to 145) 
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Page 146 
just told tne one day — you know, I asked her 
2 
and she just said it was over, but of course, 
3 
I'd asked her, what happened, and she won't 
4 
tell me. 
5 
BY MR. LUTHER: 
6 
Q. So, the conversation where she told you it 
7 
was over was a conversation that happened before you 
8 
flew down here? 
9 
A. Yes. 
10 
Q. All right. What — 
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A. We actually haven't spoke about anything that 
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happened with her since I've been here. 
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Q. All right. Since you got here Wednesday, 
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what conversations have you had with IS that, that 
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involved in any way, shape or form Mr. Epstein and 
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you and/or her? 
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A. I mean, she knows that I'm down here, you 
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know, for this, my case, but that's it. 
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Q. I want to know what conversations you've 
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had with her about that, that —
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A. She knew I had to fly down here for my case. 
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I mean, that's — we, we don't get into that because we 
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know we're not really supposed to tell each other 
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things. 
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Q. Who told you you weren't supposed to tell 
Page 148 
1 
best friend? 
2 
A. She's a close friend. I mean, I have a lot of 
3 
close friends ifs, but, I mean, right now, yeah, we're 
4 
close. 
5 
Q. How long have you known M.? 
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A. Since I was in Fort Lauderdale. 
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Q. That goes back to — well, you were there 
8 
from age three, right? 
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A. No. No. 
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Q. Okay. When were you in Fort Lauderdale? 
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A. 'started, I was in Florida for my middle 
12 
school, sixth, seventh and eighth. 
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Q. Okay. This is somebody you've known since 
14 
sixth grade? 
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A. Around seventh. I mean, we weren't close in 
16 
middle school though. I just knew of her. 
17 
Q. And then you left Fort Lauderdale and went 
18 
to went to South Carolina and then you went to 
19 
Wellington? 
20 
A. Yes. 
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Q. Did you lose touch with her, or just did 
22 
you keep in touch with her? 
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A. I didn't — 'wasn't friends with her in Fort 
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Lauderdale. 
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Q. Okay. 
Page 147 
1 
each other things? 
2 
MR. MERMELSTEIN; Objection. Well -
3 
MR. WITTER: Don't, if your lawyer's the 
4 
one that told you, just, just — you don't tell 
5 
me what they said. So did anybody other 
6 
than-
7 
MR. MERMELSTEIN: Well, anyhow - 
MR. LUTTIES: Let me, let me rephrase it. 
9 
BY MR. LUMER: 
10 
Q. Did anybody other than your, than your 
11 
lawyer tell you you weren't allowed to talk to le. 
12 
about your claims? 
13 
A. No. 
14 
Q. All right. So es never told you that 
15 
she wasn't allowed to do that? 
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A. She just said she couldn't tell me. I don't 
17. 
know why, but l'm assuming it's — the same goes for 
18 
both °flu. 
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Q. And did — do you know who M.'s lawyer 
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was? 
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A. No.. 
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Q. Did 
M
.
 
give you any papers to review 
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from her case? 
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A. No. 
25 
Q. You — would you characterize, as your 
25 
PROSE COURT REPORTING 
Page 149 
1 
A. I just knew of her. We had the same friends. 
2 
We weren't close or anything, so it wasn't like we 
3 
kept — I didn't really talk to her. 
4 
Q Did you, did you strike up your 
5 
acquaintance with her again at some point in time? 
6 
A. Yes. We — 
7 
Q. When was that? 
9 
A. When I moved with my father, her family 
9 
actually moved to the same neighborhood as we were 
10 
living in. And my friend f 
which was friends with 
11 
both of us, told me about it, and M. got my number and 
12 
we started talking, and that's how we became friends. 
13 
Q. Who would you say your best friend is? 
14 
A. Right now? 
15 
Q. Yeah. 
16 
A. My husband. 
17 
Q. Okay. I mean, of girlfriends who is your 
18 
best friend? 
19 
A. The 
Fm closest to right now is, is 
20 
Q. And M. has been your closest friend for 
21 
what period of time? 
22 
A. I mean, I have a group of close friends. I 
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mean, it's not been - we've been friends, I guess you 
24 
could say close friends, since she came down to 
Wellington. In Binks Forest we became close. 
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Page 150 
1 
THE COURT IMPORTER: In what? Pm sorry. 
2 
THE WITNESS: Wellington. 
3 
BY MR. LUTTIERt 
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Q. And that was when you were in high school? 
5 
A. Yes. 
6 
Q. So since ninth grade? 
7 
A. Yes. 
8 
Q. All right. So since you were in ninth 
9 
grade, you and she have been best friends? 
10 
A. Yes. 
11 
Q. Okay. And, and in foie I'll get into 
12 
more of this later, but isn't 
I
N
 
the person that 
13 
went with you when you first went to see 
14 
Mr. Epstein? 
15 
A. Yes. 
16 
Q. Is there anybody or strike that. When 
17 
was the last time you talked to 11? 
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A. I talked to U,  she — the last time I 
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talked to her was in Virginia. 
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Q. That is you were in Virginia? 
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A. Yes. 
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Q. Where was she, down here? 
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A. Yes. 
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Q. Okay. When was that? 
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A. When I found out I was pregnant I told her 
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Page 152 
what she was doing with that. I don't know like when 
she was going or what she was doing or how many times 
she -- I have no idea. We didn't really — I ;mow she 
went. I don't know if it's because she mentioned it in 
high school. I don't know. 
Q. Well, you discussed the fact that she had 
a claim against Mr. Epstein with her, right? 
MR. MERMELSTEIN: Objection, foam 
BY MR. WITTER: 
Q. Have you discussed with her the fact that 
she has a claim against Mr. Epstein? 
A. She told me — when I was in Boca she told roc 
she did. 
Q. When were you in Boca? 
A. I'm guess — I think when I first came down 
here. I think when I first came down here from when my 
husband went on his deployment. 
Q. So this is, now we're talking about 
January of— would you say '09? I mean, I can't --
I—
A- Yeah, it was - 
Q. Refresh my memory. I don't want to give 
you the wrong date. 
A. Yeah. January I came here, February. 
Q. Of '09? 
Page 151 
1 
because she's also pregnant 
2 
Q. Any other — what did, what did she tell 
3 
you? Is that what you were calling her for when you 
4 
were Virginia? 
5 
A. Yeah. 
6 
Q. What was your relationship with M? 
7 
A. We were close. 
8 
Q. Did she go to school with you? 
9 
A. Yes. 
10 
Q. From, all through high school? 
11 
A. No. I met her probably around my sophomore, 
12 
sophomore year, probably. 
13 
Q. Met her — did you meet her before you 
14 
went to Mr. Epstein's for the first time? 
15 
A. Yes, !think so. 
16 
Q. Did she ever go with you to Mr. Epstein's? 
17 
A. No. 
18 
Q. When did you first kam that she went to 
19 
Mr. Epstein's'? 
20 
A. We 
I, I don't, honestly I don't remember 
21 
when I, when I -- she told me she went there. I don't 
22 
remember that. 
23 
Q. Well, was it at or about the time that she 
24 
went, or was it a long time later? 
25 
A. I didn't really blow what she — I didn't Icnow 
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Page 153 
A. Yes. 
Q. Okay. 
A. And then I started school. 
Q. Okay. So this is something you learned 
for the first time, that she had a claim against 
Mr. Epstein in January of '09. Have I got that 
right? 
A. I don't know if it was January, but it was 
sometime when I moved here. 
Q. Was it before January of '09? 
A. No. 
Q. And this was many, many years after she 
had gone to see Mr. Epstein. 
A. What do you mean? 
Q. Well, I'm just — years after she actually 
went to see Mr. Epstein that you learned for the 
first time that she, she had a claim against him. 
A. Yes. 
Q. Okay. And it was years after you had gone 
to Mr. Epstein? 
A. Yes. 
Q. Okay. 
A. Before — can I take one more quick break? 
MR. LUTHER: Absolutely. 
THE WITNESS: Sony. I just --
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