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A. Mario. 
2 
Q. Okay. And how do you know Mario? 
3 
A. He was, we met him in South Beach just like 
4 
with a friend. 
5 
Q. And who is we met him in South Beach? 
6 
A. Me and ■ 
7 
Q. 
8 
A. 
9 
Q. Did 
go on this trip too? 
10 
A. No. 
11 
Q. Why didn't she pa? 
12 
MR. HOROWITZ: Form. 
13 
THE WITNESS: She, I don't know, she was with 
14 
her boyfriend a lot. 
15 
BY MR. CRITTON: 
16 
Q. Was this after -- this was when you were a 
17 
sophomore where, at 
second year at IM? 
18 
A. I think so. 
19 
Q. Did 
go too? 
20 
A. 
and .I. 
21 
Q. 
she went too. See, l didn't go, but I 
22 
knew 
went. 
23 
A. Actually, yeah, it was 
birthday. 
24 
Sony. 
25 
Q. Oh, it was 
birthday? 
Page 201. 
1 
A. Just every once in a while when I could get 
2 
away. 
3 
Q. Where do you stay? Stay at a hotel down 
4 
there? 
5 
A. Yeah, we usually find like a cheap hotel. 
6 
Q. Down on the beach or something? 
7 
A. Uh huh. 
8 
Q. Yes? 
9 
A. Yes. 
10 
Q. Soft might be you and■ or you and some of 
11 
your other fiends that go down there? 
12 
A. Uh huh. 
13 
Q. Yes? 
14 
A. Yee 
15 
Q. Which club did you meet Mario at? 
16 
A. I don't remember. It was so long ago. 
17 
Q. How long have you known Mario? Sophomore, you 
18 
are a senior, plus one year, so it would have been about 
19 
free years ago? 
20 
A. Yeah. 
21 
Q. Okay. How many times -- does Mario live in 
22 
Chicago? 
23 
A. Yeah, he has a place in Chicago and a place 
24 
like near Miami. 
25 
Q. Have you ever been to his place in Miami or 
2 
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2/ 
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Page 200 
A. Yes. 
Q. Is 
from Chicago? 
A- No. 
Q. I thought you said you went because it was --
maybe I misunderstood you. 
A. It was =, 
it was my friend's birthday, 
her birthday, and that's why we went there. My friend 
invited us to go because it was her birthday, and she 
wanted to go somewhere for her birthday. 
Q. And Mario, how old — is Mario at. 
with 
you? 
A. No. 
Q. What's Mario do for a living? 
A. He works in like the hotel industry. 
Q. Which hotel? 
A. I have no idea what hotel. I know his dad 
like renovates hotels, stuff like that. 
Q. You met Mario in South Beach, you and 
met 
him? 
A. Yes. 
Q. Were you at a club down there? 
A. Yeah, we went down for like the weekend, me 
and her. 
24 
Q. Have you been down there 
2 
bunch of rimes
 
 to South Beach a 
Lismitt
n2es for weel
a_....
2 .a_
ids? 
Page 202 
1 
near Miami? 
2 
A. Yeah, we went there once. 
3 
Q. Who is we? 
4 
A. Me and. 
5 
Q. And when you went up to Chicago, did you stay 
6 
at Mario's place up there? 
7 
A. Yeah, he let us stay up there, because we 
8 
couldn't afford to get like a hotel room. 
9 
Q. Was Mario there at the time you were there? 
10 
A. Yeah. 
11 
Q. Okay. How big a place did he have in Chicago? 
12 
A. Just Ince a condo. 
13 
Q. I understand. Like a two-bedroom, 
14 
three-bedroom, two-bedroom, one bath, one bedroom? 
15 
A. I think it was, yeah, like two or three 
16 
bedrooms. 
17 
Q. And who stayed with you at Mario's? 
18 
A. All the girls. We all stayed in the room 
19 
together. 
20 
Q. And there was you, Jane Doe 4, Gonzalez, is 
21. 
that -
22 
A. Uh huh. 
23 
Q. And IM 1
24 
A. Yeah. 
ZS
ther
iumetLo?„.a. 
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1 
A. Yeah. 
2 
Q. So there were five of you? 
3 
A. IJh huh. 
4 
Q. Yes? 
5 
A. Yes. 
6 
Q. How old is Mario? 
7 
A. I have no idea. 
8 
Q. !she 15? Is he 20? 
9 
A. No. 
10 
Q. Is he 25? Is he 40? 
11 
A. No, he's late 20's. 
12 
Q. Late twenties. Are you sure he's not older 
13 
than that? 
14 
A. I mean I don't know. 
15 
Q. What's Mario's last name? 
16 
A. I have no idea. 
17 
Q. So you traveled to some guy's house in, or 
18 
condominium in Chicago and you don't know his name? 
19 
MR. HOROWITZ: Form. 
20 
THE WITNESS: I know ifs Mario, but I forget 
21 
his last name. Ifs been like a while since I have 
22 
talked to him. 
23 
BY W. CRITTON: 
24 
Q. When is the last time you did talk with Mario? 
25 
A. I honestly don't even remember. It's been a 
1 
A. Uh huh. 
2 
Q. So you met Dave through him? 
3 
A. Yes. 
4 
Q. All right. And so Dave had you up there to 
5 
stay at his house? 
6 
A. Well, yeah, I paid to go fly up there and 
7 
visit him, because we started like talking a little bit. 
8 
Like he was just a friend of mine. 
9 
Q. Did you pay for the ticket or did he pay? 
10 
A. I paid. 
11 
Q. And how long were you in Chicago? 
12 
A. Just for like the weekend I went up there. 
13 
Q. Had you met him down here in Orlando? 
14 
A. Yeah. 
15 
Q. And then he said why don't you come up for the 
16 
weekend? 
11 
A. Well, we talked fora little bit, bents,- he's 
18 
always down for his brother's games, so we like made 
19 
friends, and then he asked me up. I wanted to come up 
20 
there and go visit for the weekend. 
21 
Q. Did you? 
22 
A. Yee. 
23 
Q. And just you? 
24 
A. Yes, 
25 
Q. And did you stay with him at his apartment? 
Page 204 
while. 
2 
Q. How many times have you been to Chicago to 
3 
stay at his house? 
4 
A. Just once, that one trip we have been on. 
5 
Q. Are you sure you haven't been up there again? 
6 
A. No oh, actually I went up there one other 
7 
time. I have a friend that lives up there that we went 
to go visit. 
Q. So you went to Chicago a second time? 
A Yeah, I went there twice. 
Q. Who is that friend? 
A. My friend Dave. His brother plays for I. 
basketball, so I'm friends with his brother, and that
how I met hint 
THE VIDEOGRAPHER: Excuse me, miss, could you 
not play with the mike, please? 
THE WITNESS: Sony. 
BY MR. CRITTON: 
Q. So Dave is the player at. 
or Dave is the 
brother of the guy from. who plays basketball for 
A. Uh huh. 
Q. Yes? 
A. Yes. 
Q. You know the player, the Slyer fa/ 
Page 206 
1 
A. Yes. 
2 
Q. Is Dave someone you've dated? 
3 
A. We didn't — like we're just friends. 
4 
Q. Did you have any kind of sexual relationship 
5 
with David? 
6 
A. No. 
7 
Q None? Just went up for the weekend? 
8 
A. Yeah. 
9 
Q. Did you talk to Mario when you were up seeing 
10 
Dave? 
11 
A No. 
12 
Q. So Mario, you went up there — how many days 
13 
were you in Chicago? 
14 
A. We went there for like four days, I think. 
15 
Q. And where did you go? What did you do when 
16 
you were up there? 
17 
A. He like just showed us around the city. He 
18 
had to work, sole kind of like let us go wherever we 
19 
wanted and just like told us the good spots to go. 
20 
We went like out to lunch and walked around 
23. 
the city and took pictures, and we went out one night to 
22 
like one of the clubs up there. 
23 
Q. Okay. Did he have any other guys that he 
24 
introduced to you all when you was up there? 
25 
A. One other guy, but I for 
his nem 
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A. I don't remember. 
2 
Q. Charlie, did he kind of hang around with you 
3 
guys during the four days you were up there? 
A. He went out with us one night. Mario said it 
5 
was Ike one of his good friends. 
Q. Did Mario buy anything for you all when you 
were up there? 
A. Just Jane Doe 4, he bought her like i think an 
outfit. 
Q. And why would he buy Jane Doe 4, did he 
express why he bought Jane Doe 4 an outfit? 
MR. HOROWITZ: Form. 
THE WITNESS: Because she like didn't bring a 
lot of cute outfits and she saw something she liked 
in Bebe. 
BY MR. CRITTON: 
Q. So if Jane Doe 4 has testified that he bought 
dresses for all of you at Babe's, that would be 
incorrect? 
MR. HOROWITZ: Form. 
THE WITNESS: Well, I mean he did. He bought 
it for Jane Doe 4, he bought her clothes. And then 
was Re "I want something because it's my 
birthday," and then he was like, you know, 
whatever. So he bought her something too. 
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Page 207 
1 
Q. How about Charlie, does that sound familiar? 
2 
A. Yeah. 
3 
Q. Do you know what Charlie's last name is? 
A. No idea. 
Q. How old is Charlie? 
A. He was an older guy. 
Q. Fifties? 
A. Yeah, he was older. 
Q. And how did Charlie get introduced into the 
mix, so to speak? 
A. Just Mario knew him somehow, so he just 
introduced us to Charlie. 
Q. Why did he introduce you to Charlie? 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. Why did Charlie all of a sudden show up with 
the five girls? 
MR. HOROWITZ: Form. 
THE WITNESS: He was showing us around 
different hotels. 
BY MR. CRITT0N: 
Q. So Mario, now his apartment is where, what 
building, do you remember? 
A. The John Hancock 
Q. And how about Charlie, where did he live? 
.Page 209 
1 
BY MR. CRITTON: 
2 
Q. Did he buy you something too? 
3 
A. I mean yeah, but I was like kind of— he 
4 
asked Jane Doe 4 Ent It's not like we asked him to 
5 
by anything for us. She wanted to get something to go 
6 
out, because she didn't really like bring any cute 
7 
dresses. 
8 
And so we went into Bebe, and we never asked 
9 
him to buy anything. He was like asked Jane Doe 4, he 
10 
offered to buy her something. 
11 
Q. I asked —1'm sorry, are you done? 
12 
A. Well, yeah. !mean he did pay for it, but I 
13 
never asked him to pay for anything forme. 
14 
Q. When I rust asked the question, I said did he 
15 
buy anything for anyone, and you said he bought an 
16 
outfit for Jane Doe 4. 
17 
MI right, then I asked you the question well, 
18 
did he buy anything for anybody else? Didn't he buy 
19 
dresses for other people? And then all of a sudden you 
20 
told me. 
21 
Why didn't you tell me that the first time 
22 
when i asked you? 
23 
MR. HOROWITZ: Form. 
24 
THE WITNESS: It's not lie I asked him to buy 
25 
me anything. Just I was going to pay for it and 
Page 208 
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Page 210 
brought it to the register and then he offered to 
pay for it because he was buying Jane Doe 4 
something 
BY MR. CRITTON: 
Q. Were you confused with my question when i 
asked you whether he had bought you anything? 
MR. HOROWITZ: Form 
THE WITNESS: Well, i wasn't — I'm sorry, I 
guess I was kind of - 
BY MR. CRITTON: 
Q. Again, if you don't understand my question, 
ask me to repeat it or rephrase it. I asked you if he 
bought anything for anyone else, and all you said was 
Jane Doe 4. 
So if I hadn't followed up the question, you 
would have misled me, wouldn't you? 
MR. HOROWITZ: Form. 
THE WITNESS: I'm sorry, I didn't ask him to 
buy anything for me. I was going to pay for it and 
then he just offered. 
BY MR. CRIM)N: 
Q. Did he buy any other gifts for anybody when 
you were up there? 
A. No, he just like took us out to lunch once. 
Q. Did he pay for the tripal_ 
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A. Yes, he did. 
2 
Q. And did he pay for food wherever you all went 
3 
if he was with you; that is, dinners or lunches? 
4 
A. Like not all of them, but some of them he took 
5 
us out. 
Q. How about Charlie? Did he buy any lunches or 
7 
dinners when he was out with you? 
8 
A. Uhuh. 
9 
Q. No? 
10 
A. No. 
• 
11 
Q. You are shaking your head. You need to answer 
12 
out loud, ma'am. 
13 
I think you said you have been to Mario's. 
14 
Have you ever seen Charlie since that one trip to 
15 
Chicago? 
16 
A. No. 
17 
Q. Did you ever see Mario when he came back to 
18 
Florida again? 
19 
A. He was down in Miami. He goes down there a 
20 
lot and he calls to hangout, but I !lice live in Orlando 
21 
so I can't go, you know, that much. 
22 
But no, I don't think since Chicago 1 have 
23 
seen him. 
24 
Q. How about anyone else? Did you ever have any 
25 
kind of relationship, intimate relationship with Mario? 
Page 213 
1 
Dr. ICliman, who your lawyer has hired to testify in this 
2 
case? 
3 
A. No. 
4 
Q. During the time that you have been, during the 
5 
time that you were in high school, I assume that you 
6 
were covered under your — strike that. 
7 
Your dad has worked for the Town of -
8 
since he first came to Florida? 
9 
A. Yeah. 
10 
Q. So he has a health program through the city, 
11 
true? 
12 
A. Uh huh. 
13 
Q. For health benefits? 
14 
A. Uh huh. 
15 
Q. Yes? 
16 
A. Yes. 
17 
Q. MI right. And so any type of medical care or 
18 
treatment that you would need would be covered under 
19 
your dad's policy? 
20 
MR. HOROWITZ: Form. 
21 
BY MR. CRITTON: 
22 
Q. When you were in high school and through the 
23 
time you've been in college, as long as you are a 
24 
student, correct? 
25 
MR. HOROWITZ: Fonn. 
Page 212 
1 
A. No, not at all. 
2 
Q. Did you ever date him for any period of time? 
3 
A. No. 
4 
Q. Me you currently seeing any physicians, 
5 
psychiatrists, psychologists, mental health counselors, 
6 
professionals, for any reason which you allege is 
7 
associated with your visits to Mr. Epstein? 
MIL HOROWITZ: Form. 
9 
THE WITNESS: No. 
10 
BY MR. CRITTON: 
11 
Q. When, prior to the time that you ever went to 
12 
Mr. Epstein's home, whatever year that was, '03, '04, 
13 
'05, for the first time, had you ever seen a 
14 
psychiatrist or psychologist or counselor for any 
15 
reason?.
16 
A. No. 
17 
Q. After you went to, or from the first time you 
18 
went to Mr. Epstein's home up until the last time, did 
19 
yod ever see a physician, psychiatrist, psychologist, 
20 
mental health counselor, for any reason? 
23. 
A. No. 
22 
Q. After the last time you went to Mr. Epstein's 
23 
home, whether it was in 2004 or 2005, did you ever see a 
24 
psychiatrist or a psychologist or mental health 
25 
professional for any reason separate and apart from the 
Page 214 
1 
THE WITNESS: Yeah, but there is like his down 
2 
payments and stuff. They don't cover everything. 
3 
BY MR. CRITTON: 
4 
Q. Nobodys does. All right, so my question to 
5 
you is your dad — again recognizing you're a full-time 
6 
student, correct? 
7 
A. Uh huh. 
8 
Q. Yes?. 
9 
A. Yes. 
10 
Q. So up through the current date, you had access 
11 
to medical care and treatment? 
12 
. . 
A. Yes. 
13 
MR. HOROWITZ: Form. 
14 
BY MR. CRITTON: 
15 
Q. Through your dad's health policy, is that 
16 
true? 
17 
A. Yes. 
18 
Q. All right. And with both, I believe 
19 
through 
let me strike that. 
20 
With 
did they have a student health 
21 
center? 
22 
A. Yes. 
23 
Q. With., did they have a student health 
24 
center? 
25 
A. Yes. 
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Q. And both places as well provide for counseling 
2 
for students who need counseling, for any type of issue, 
3 
whether ifs birth control, whether it's psychological 
4 
problems, emotional issues, behavioral health issues, as 
5 
well as physical problems, those services are made 
6 
available through both 
and through.? 
7 
MR. HOROWITZ: Form. 
8 
THE WITNESS: Yes. 
9 
BY MR. CRITTON: 
10 
Q. And if I understand your testimony, you have 
11 
never used those services either through the school 
12 
programs, either 
or.-- first of all, ou 
13 
have never used those services through 
or. 
14 
as it relates to any issue associated with Mr. Epstein, 
15 
true? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: Yes. 
18 
BY MR. CRITTON: 
19 
Q. And as well, even though your father has a 
20 
health plan or a medical plan through the Town of Palm 
21 
Beach which you are covered, you have not sought the 
22 
services of any mental, psychologist, psychiatrist or 
23 
mental health counselors, correct? 
24 
. 
MR. HOROWITZ: Form. 
25 
THE WITNESS: Yes. First of all, there is 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
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Page 217 
THE WITNESS: No. 
BY MR. CRITTON: 
• 
Q. Has anyone ever told you you should see a 
psychiatrist or psychologist or a licensed mental health 
counselor other than your lawyers? I don't want to know 
what they said. I'm interested, but — 
A. Jane Doe 4 told me, she said it would really 
help me If I saw a counselor because ifs been helping 
her and —
MR. HOROWITZ: Move to strike Bob's laughter. 
MR. CRITTON: I didn't laugh. It's news to 
me. 
BY MR. CRITTON: 
Q. Who has Jane Doe 4 told you, who is the 
counselor that Jane Doe 4 said that she's gone to as a 
result of any visits or the occasions that she had to go 
to Mr. F-pstein's house? 
A. I don't know his name. 
Q. Did she tell you where he was? 
A. 'think down in Boca. 
Q. Okay. Did she tell you 
we finished taking 
her deposition within the last maybe month and she 
hadn't seen anybody. 
MR. HOROWITZ: Object to the form. 
Page 216 
1 
no — I would never go to my school and tell 
2 
anybody about what happened. I mean that's, I mean 
3 
students probably work there, for all I know. And 
4 
I don't want to get my dad and my mom involved. 
5 
And I mean l don't 
you know, that's 
6 
something that's embarrassing to me and I don't 
7 
want — I mean it should be on me, not on them. 
8 
BY MR. Clt1TTON: 
9 
Q. Let me move to strike. Let me go back to my 
10 
question. 
11 
My question solely was not the whys and the 
12 
wherefors, but since you've been under your parents' 
13 
health care Ian,particularly your father's through the 
14 
Town of 
you have never sought counseling 
15 
with a psychiatrist, psychologist, or a licensed mental 
16 
health counselor relating to any issues associated with 
17 
Mr. Epstein, correct? 
18 
MR. HOROWITZ: Fenn. 
19 
THE WITNESS: Yes. 
20 
BY MR. CRITTON: 
21 
Q. Would it also be a correct statement that 
22 
physically, as a result of your having gone to 
23 
Mr. Epstein's home, you were never physically injured in 
24 
any way, were you? 
25 
MR. HOROWITZ: Form. 
Page 2 :, 
1 
BY MR. CRITTON: 
2 
Q. 
e other than some Christian counselor that 
3 
she and 
saw.
4 
MR. HOROWITZ: Bob, you can't disclose that 
5 
stuff. You just cant 
6 
MR. CRITTON: Okay, well fine. If you want to 
7 
.move for some sort of protective order on this, 
8 
that's fine. 
9 
Mk HOROWITZ: No, but I'm appealing to you 
10 
we don't have to do that. You can't disclose 
11 
someone's confidential medical or therapy to 
12 
another witness. You just can't do that. You can 
13 
ask her what she knows, but you can't disclose it. 
14 
MR. CRITION: Yes, but the perfect example is 
15 
with this witness, she won't even answer a question 
16 
that I ask unless 1 key her, and then if I actually 
17 
know the answer to the question, then she will 
18 
=dim it, but she's not giving me answers. 
19 
So you can argue or move for protective order 
20 
wherever you think is appropriate under the 
21 
circumstances. 
22 
BY MR. CRITTON: 
• 
23 
Q. Let me ask you this. You say that Jane Doe 4 
24 
has told you that she's gone -- did she ever tell you 
25 
she saw a counselor up in the Stuart, Jensen Beach area? 
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2 
3 
4 
5 
6 
A. 
Q. 
A. 
Q. 
A. 
Q. 
No. 
Do you know who 
Yes. 
Have you ever met M? 
Yes. 
Do you know what he does? 
is? 
7 
A. He does like construction and landscing. 
8 
Q. All right. Do you know whether = 
has any 
9 
sort of drug problem? 
10 
A. No. 
11 
Q. Have you ever known that Mr. Bullard is 
12 
alleged to have been a seller of drugs? 
13 
MR. HOROWITZ: Form. 
14 
THE WITNESS: No. 
15 
BY MR. CRITTON: 
16 
Q. Do you know whether he takes drugs, illegal 
17 
drugs? 
18 
A. No. 
19 
Q. Has Jane Doe 4 told you that her relationship 
20 
with 
is very positive, good relationship? 
21 
A. Yes. 
22 
Q. She seems to be very happy? 
23 
A. Yes. 
24 
Q. Is she currently working at all? 
25 
A. Yes. 
1 
A. I don't think so. 
2 
Q. How do they !mow Jane Doe 4 is a plaintiff? 
3 
A. Because she's one of my good friends. 
4 
Q. Did you tell your parents? 
5 
A. !thinks°. 
6 
Q. You said Jane Doe 4 told you that she had seen 
7 
a counselor in Boca. Did she say it was a man or a 
8 
female? 
9 
A. I think she said it was a male. 
10 
Q. And did she tell you when she started seeing 
11 
the counselor in Boca? 
12 
A. No. 
13 
Q. Did she tell you it had helped her? 
14 
A. Yes. 
15 
Q. And in what way? 
16 
A. She said it just helped her like just when she 
17 
is like emotional with the all the thing coming up, with 
18 
all the questions for the lawsuit and the media or 
19 
people — well, not media, but, you know, when all her 
20 
friends found out and stuff, she was really emotional 
21 
and crying, and he just really helped her emotionally. 
22 
Q. What friends did she say found out? 
23 
A. Whoever you guys asked, talked to, I guess. 
24 
So 1 mean IM 
I don't really remember everybody she 
25 
said. 
Page 220 
1 
Q. What kind of work is she doing now? 
2 
A. She's doing cleaning, like housecleaning and 
3 
stuff. 
4 
Q. She's a college graduate? 
5 
A. Yes. She's starting her own business, like 
6 
housecleaning. 
7 
Q. So she's going out, she's doing some cleaning 
8 
herself, kind of learn the business, and then she's 
9 
going to get people to work for her? 
10 
A. Yes. 
11 
Q. Did she say her business is going well, good, 
12 
bad or indifferent? 
13 
A. Yeah, she said it's going good. 
14 
Q. Do she and 
have any plans to get 
15 
married? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: Not that I know of. 
18 
BY MR. CRITTON: 
19 
Q. She's living with him MI time? 
20 
A_ Yes. 
21 
Q. Do your parents know that Jane Doe 4 is a 
22 
plaintiff in one of these lawsuits or the lawsuit 
23 
against Mr. Epstein? 
24 
A. Yes, I think so. 
25 
Do 
know that Jane Doe 3 is? 
Page 222 
1 
Q. Did she tell you that before MI was ever 
2 
deposed that she had already told him about having been 
3 
involved with Mr. Epstein? 
4 
A. I don't remember. 
5 
Q. Did she try to blame that on the lawyers in 
6 
some way? 
7 
MR. HOROWITZ: Form. 
8 
THE WITNESS: I don't think she told him, you 
9 
know, the extent of everything. I don't really 
10 
know what she told him. 
11 
BY MR. CRITTON: 
12 
Q. All right So she told you that at least she 
13 
is seeing somebody, a male in Boca Raton? 
14 
A. lib huh. 
15 
Q. Did she tell you how she had gotten to see 
16 
somebody in Boca? 
17 
A. No. 
18 
Q. So how long ago did she tell you this, in the 
19 
last month or so? 
20 
A. Yes. 
21 
Q. Okay. Did she, as a result of her telling you 
22 
you should see someone, have you made an appointment to 
23 
see anyone? 
24 
A. No. She told me that you guys are going to 
25 
depose her therapist, and that made me not want to see 
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anybody, because I don't want my whole life story, you 
2 
know, to be out there. 
3 
Q. What whole life story? 
4 
A. I mean I don't feel comfortable talking to a 
5 
therapist. Like I'd rather wait until everything is 
6 
over with to talk to somebody. That's why I haven't 
done anything. 
Q. Why? What makes you think talking to a 
9 
therapist after the lawsuit is over is of any benefit to 
10 
you? 
11 
A. Because like I had heard that you guys already 
12 
deposed her therapist, and I don't want everything, you 
13 
know, I say to be just public knowledge to every lawyer. 
14 
Q. You understood what you said to Dr. Kliman is 
15 
public knowledge, in essence? It's public within the 
16 
confines of this lawsuit. You understand that, don't 
17 
you? 
18 
MR. HOROWITZ: Form. 
19 
THE WITNESS: Yes. 
20 
BY MR. CRITTON: 
21 
Q. And everything you have said to Dr. Hall is 
22 
shared not only with me, but as well shared with your 
23 
attorney, correct? 
24 
A. Yes. 
25 
Q. Okay. So what were you concerned that you 
Page 225 
1 
MR. HOROWITZ: Form. 
2 
THE WITNESS: That's what people say, but 
3 
there are students that work in those offices, and 
4 
I don't want people at my school like 'mowing my 
5 
business. 
6 
BY MR. CRITTON: 
7 
Q. Did you try get some assistance? Did you talk 
8 
to your parents and say "Hey, look, I think it would be 
9 
of some benefit for me to go see a psychologist or a 
10 
psychiatrist"? 
11 
A. I'm like kind of embarrassed to ask them. Td 
12 
rather do it on my own. 
13 
Q. Isn't the reason that you haven't gone to go 
14 
see someone, ma'am, is you don't feel the need to do 
15 
that? 
16 
MR. HOROWITZ: Pont 
17 
THE WITNESS: No, I do feel the need. I want 
18 
to go see somebody, but I just don't feel 
19 
comfortable doing it now. 
20 
BY MR. CRITTON: 
21 
Q. But why? I mean it doesn't make sense -- let 
22 
me strike that. 
23 
In the year 2010, have you been on any trips? 
24 
A. Yes. 
25 
Q. Where did you go? 
Page 224 
might tell a psychologist --just a minute, I need to 
ask the question, ma'am. 
3 
What were you concerned with that I might ask 
4 
that you might toll a psychologist or psychiatrist that 
you wouldn't want he or she to repeat to me? 
6 
A. Nothing. I just talked to those because I had 
1 
to talk to those people, and I'd rather just wait until 
8 
everything is over, because I don't feel comfortable 
9 
like talking to people right now. 
10 
And also, like I'm in college. I don't have, 
11 
you know, money right now to go see somebody. And 1 
12 
don't, and my parents aren't going to like — I mean I'm 
13 
not going to pay $40 a visit every week or two weeks, 
14 
whatever. Like I have like $100 a week I have to live 
15 
on in college basically, so — 
16 
Q. Have you actually gone to the. 
center where 
17 
they have psychologists and psychiatrists? 
18 
MR. HOROWITZ: Form. 
19 
THE WITNESS: I definitely don't want to go to 
20 
center. 
21 
BY MR. CRITTON: 
22 
Q. Why wouldn't you do that? Because your 
23 
medical records or your psychiatric records or 
24 
behavioral, psychological records are supposed to be 
25 
completely privileged. 
Page 226 
1 
A. I mean I went to Key West. 
2 
Q. With whom? 
3 
A. I went with just my friend =. 
4 
Q. M
t? 
5 
A. Uh huh. 
6 
Q. Where did you stay? 
7 
A. We stayed at my friend's ex-boyfriend's place 
8 
down in Key West. 
9 
Q. My friend's ex-boyfriend. Your friend, whose 
10 
name is? 
11 
A. My friend M, 
my old roommate. Her 
12 
ex-boyfriend lives in Key West. 
13 
Q. His name is? 
14 
A. Nick. 
15 
Q. Nick? 
16 
A. Yes. 
17 
Q. Was Nick there when you were there? 
18 
A. Yes. 
19 
Q. Where does he live in Key West? 
20 
A. He just lives in a small apartment off Duval 
21 
Street. 
22 
Q. So you stayed with him for what, a week? 
23 
A. Yeah, for like five days. 
24 
Q. Four to five days? 
25 
A. Uh huh. 
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Q. Yes? 
2 
A. Yes. 
3 
Q. Okay. And I assume you partied every night, 
4 
went out every night? 
A. I mean we went out some and we just went to 
6 
the beach a lot. 
Q. Okay. So it's your testimony during the four 
a 
or five nights that you were there -- what time period 
9 
were you there, spring break? 
10 
A. Yes. 
11 
Q. So you were there for spring break, a million 
12 
other college kids there? 
13 
MR. HOROWITZ: Form. 
14 
THE WITNESS: Yes. 
15 
BY MR. CRITTON: 
16 
Q. All right. It would be a fair statement --
17 
well, let me be acanate. It was during the four or 
18 
five days that you were there, is it your testimony that 
19 
you only went out one or two nights to party and to go 
20 
to clubs? 
21 
MR. HOROWITZ: Form. 
22 
BY MR. CRITTON: 
23 
Q. Or did you go out every night? 
24 
A. I went out a lot when we were there. It was 
25 
spring break. 
A. We both split it 
2 
Q. All right. Who paid for your drinks when you 
3 
went out, when you even had too much to drink? 
4 
MR. HOROWITZ: Form. 
5 
THE WITNESS: I mean we did sometimes. 
6 
BY MR. CRITTON: 
7 
Q. All right. And then if you were lucky, maybe 
8 
some guy would buy you a drink or drinks? 
9 
A. Yes. 
10 
Q. I'm sorry? 
11 
A. Yes. 
12 
Q. All right. And isn't it a true statement, 
13 
Jane Doe 7, is if you really wanted to see a 
14 
psychologist, you have maybe not every week, but you 
15 
would have had the fiuids to do that, you just choose to 
16 
use your funds in a different, for different purposes at 
17 
the current tint? 
18 
MR. HOROWITZ: Fonn. 
19 
THE WITNESS: No, that's not the main reason. 
20 
The main reason was1 wanted to wait until after 
21 
the lawsuit. 
22 
BY MR. CRITTON: 
23 
Q. So people !Bre me who represent Mr. Epstein 
24 
maybe can't look at what you tell a psychologist? 
25 
A. I mean I just feel uncomfortable like saying 
Page 228 
1 
Q. Exactly. My point is that you went down there 
2 
for spring break and you went out every night and you 
3 
partied, didn't you? 
4 
A. Yeah, ifs spring break 
5 
Q. And you had fun? 
6 
A. Yeah, I did. 
7 
Q. And you had a great time? 
8 
A. Yes. 
9 
Q. And you drank alcohol, I assume? 
10 
A. Yes. 
11 
Q. You had a cocktail here and there? 
12 
A. Yes. 
13 
Q. And there were some nights that you had too 
14 
many cocktails? 
15 
A. Yes. 
16 
Q. And how did you get down there? Whose car did 
17 
you drive down from Orlando? 
18 
A. I drove. 
19 
Q. All right. And who paid for your meals when 
20 
you were there? 
21 
A. We did. We went food shopping before we even 
22 
got there and we like -- when we got there, we went food 
23 
shopping and just mainly made food to like saw money, 
24 
because food is like expensive down there. 
25 
Q. Who paid for the gas? 
Page 230 
1 
everything right now. 
2 
Q. What makes you think you will be more 
3 
comfortable after a lawsuit talking with someone? 
4 
A. Just because when everything is like done and 
5 
over with, I feel like it will be a better time to just 
6 
help me get over everything. 
7 
Q. Isn't it true, though, if you really wanted to 
8 
sec — well, let me ask you this. 
9 
After the police came to you, the Palm Beach 
10 
Police Department came and interviewed you back on 
11 
October 4th of 2005 and you had sent Mom into the house. 
12 
when the Palm Beach police left, did Mom say to you 
13 
"What in heaven's name is this about, Jane Doe 7r 
14 
A. Yeah, she asked me about it. 
15 
Q. And by that time, Dad was home? 
16 
A. Yes. 
17 
Q. All right. And did you, did they both sit 
18 
down and say "Young Lady," or "Jane Doe 7, come on. 
19 
what's the deal here? 
20 
A. Yes. 
21 
Q. "What happened? How long did that 
22 
conversation last? 
23 
A. I mean I obviously didn't tell them everything 
24 
that happened. So I mean I don't know, I Just told them 
25 
briefly what I told the cops. 
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Q. So you only told them what you had told the 
2 
polioe, that you were at Mr. Epstein's twice, one time 
3 
you gave Mr. Epstein a massage, another time you just 
4 
took somebody else? 
5 
A. Yes. 
6 
Q. That's what you told them? 
7 
A. Yes. 
8 
Q. Have you ever told them anything differently? 
9 
A. No. 
10 
Q. So as far as your parents !mow at this point 
11 
in time, as far as they !mow is that you went to 
12 
Mr. Epstein's — let me strike that. 
13 
As of today's date, your parents only know 
14 
what you told them the day that the Palm Beach Police 
15 
Department was there interviewing you? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: They never asked me about it 
18 
They don't really want to know or care to know 
19 
everything. They already don't like Jeffrey. They 
20 
read the papers. They know what goes on and went 
21 
on. I mean they are not stupid 
22 
BY MR. CRITTON: 
23 
Q. Well, they have no idea what went on with you 
24 
and whether your circumstances are similar to or even 
25 
close to what someone, some other person's situation 
Page 233 
1 
MR. HOROWITZ: Form. 
2 
THE WITNESS: 1 mean I'm sure they would try 
3 
to help me out. It's just like embarrassing to say 
4 
that to them and its just something I would rather 
5 
just deal with on my own. 
6 
BY MR. CPJTTON: 
7 
Q. You sent me some, or your attorney sent me 
8 
some additional answers to interrogatories the other 
9 
day. 
10 
!AR. CRITTON: Lets go off the record for a 
11 
minute. 
12 
THE VIDEOGRAPHER: Going off the record at 
13 
2:41 p.m. 
14 
(Discussion held off the record.) 
15 
THE VIDEOGFtAPHER: Were back on the record a 
16 
2:46 p.m 
17 
(The documents were marked Defendant's 
18 
Exhibits 1.3 for identification.) 
19 
BY MR. CRITTON: 
20 
Q. Before I get back to the interrogatories, you 
21 
wouldn't, growing up, from the time that you were 
22 
freshman through even your current status, you wouldn't 
23 
have considered yourself economically disadvantaged, 
24 
would you? 
25 
A. What does that man? 
Page 232 
I 
might be, true? 
2 
MR. HOROWITZ: Form. 
.3 
THE WITNESS: Yeah, but I — they don't really 
4 
want to know. I mean they, I told them what I told 
5 
than and I mean that's all that Imean they know, 
6 
and from reading other people's things like what he 
7 
did or tried to do to most girls. So --
8 
BY MR. CRITTON: 
9 
Q. Have they ever asked you, has your mother ever 
10 
asked you 'Hey, Jane Doe 7, what happened when you were 
11 
at Mr. Epstein's home?" 
12 
A. Just the first time that the cop--
13 
Q. Since that day, she's never asked and you've 
14 
never offered? 
15 
A. No. 
16 
Q. Correct? 
17 
A. Correct 
18 
Q. Same thing with Dad? 
19 
A. Correct 
20 
Q. Is it your testimony that if you went to your 
21 
parents and you said "Look, I think I might need some --
22 
I'd like to see a psychiatrist or a psychologist to help 
23 
me deal with some issues relating to Mr. Epstein,* 
24 
assuming you said that to them, it's your testimony that 
el imil isomia..
eur
ts
paren would say no? 
1 
2 
3 
4 
5 
6 
7 
a 
9 
10 
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13 
14 
15 
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18 
19 
20 
21 
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24 
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Page 234 
Q. I'm not sure. Did you feel economically 
deprived when you were a freshman or a sophomore or a 
junior or a senior in high school, that your parents had 
economically deprived you, or did you feel that you were 
fine economically? 
MR. HOROWITZ: Form. 
BY MR. CUT-TON: 
Q. I mean everybody would !Ore to have more 
money. 
A. I mean my parents had to work really hard for 
their money, so it's not like I had everything given to 
me, like my dad made me work for it If I ever wanted 
money, I had to like wash his car or do something, so I 
mean-
Q. Those are good things, though, you had chores? 
A. Yeah, but — 
Q. You didn't consider yourself economically 
disadvantaged, did you? 
MR. HOROWITZ: Form. 
THE WITNESS: I guess not. 
BY MR. CRITTON: 
Q. Jane Doe 4, I had an opportunity to meet her 
parents. I wouldn't describe her as being economically 
disadvantaged, but you don't care what I think, so my 
question to you is do you think Jane Doe 4's parents or 
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Page 235 
1 
her family life or that she was in any way economically 
2 
disadvantaged? 
3 
MR. HOROWITZ: Form. 
4 
THE WITNESS: I don't think so. 
5 
BY MR. CRITTON: 
6 
Q. How about lane Doe 3, did she have similar 
7 
middle class circumstances like yourself and Jane Doe 4? 
8 
MR. HOROWITZ: Form. 
9 
THE WITNESS: Yes. 
10 
BY MR. CRITTON: 
11 
Q. Okay. So you wouldn't have considered her 
12 
economically disadvantaged, would you? 
13 
MR.. HOROWITZ: Form. 
14 
THE WITNESS: Yes. 
15 
BY MR. CRITTON: 
16 
Q You would? 
17 
A. No, I wouldn't. 
18 
Q. All right. In your answers to interrogatories 
19 
you listed, which is Exhibit 2, you listed the only 
20 
medical, physicians, medical facilities, health care 
21 
providers — and I'm paraphrasing -- psychiatrists, 
22 
psychologists, et cetera, that you had seen in the past 
23 
ten years, you listed the walk-in medical center at 
24 
Orlando, at University Boulevard, Orlando, 2005 to the 
25 
present. 
1 
2 
3 
4 
5 
6 
7 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 237 
Page 236 
1 
I assume that's the school clinic? 
2 
A. No. Just a clinic that was by my house. 
3 
Q. Like a doe-in-the-box? 
4 
A. Yeah. 
5 
Q. And if you had a cold or got the flu or 
6 
something, you would go there for medical care and 
7 
treatment? 
A. Yes. 
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21 
22 
23 
24 
25 
BY MR. CRITTON: 
Q. Okay. Tell me about at the current time, I 
know you have told us other than seeing Dr. Kliman, you 
have never seen a psychiatrist, psychologist, mental 
health counselor for any reasons relating to damages you 
claim for which you seek money damages against Mr.— let 
me start that again. 
You filed a lawsuit seeking money damages from 
Mr. Epstein for money, right? 
MR. HOROWITZ: Penn. 
THE WITNESS: Yes. 
BY MR. CR1TTON: 
Q. Okay. And what do you think your damages are? 
1 
wasn't thinking. 
2 
And it's just something I wish I could take 
3 
back, something that happened to me. And ifs something 
4 
I'll never be able to forget for the rest of my life, 
5 
and just the pain that I caused my parents and other 
6 
people. Ifs just —
7 
Q. What pain have you caused — what other person 
8 
have you caused pain? 
9 
A. I mean mainly my parents like more than 
10 
anything. It was heartbreaking for me when they found 
11 
out. And I mean I wish I could take it back, and —
12 
Q. What did your parents say to you when you told 
13 
them that you had been to Mr. Epstein's twice? 
14 
A. I mean they were just asking me why, why would 
15 
you do that? Like how -- I mean they understand now 
16 
that, you know, it was, he was just a predator mainly,
17 
but, you know, at the time they just, they were upset 
18 
Q. Okay. I don't want to — let me ask my 
19 
question again. 
20 
MR. CRITTON: Okay, let me see it again. Run 
21 
It down for me, Rachel. 
22 
BY MR. CRITTON: 
23 
Q. What specifically, when you told your parents 
24 
you had been to Mr. Epstein's twice, once with e 
and 
25 
you had given him a massage, he meaning Mr. Epstein, did 
Page 240 
1 
That is, what elements or items of damage do you think 
1 
2 
you have sustained as a result of your having been to 
2 
3 
Mr. Epstein's home? 
3 
4 
MR. HOROWITZ: Form. 
4 
5 
BY MR. CRITTON: 
5 
6 
Q. In your words. 
6 
7 
A. Well, for like the last six years I've been 
7 
8 
like, live had a lot of things happen to me. I've been 
8 
9 
depressed a lot. I have anxiety. I just feel like that 
9 
10 
happened and I can, something I could never take back. 
10 
11 
I feel like I'm damaged, you know, and it's just like I 
11 
12 
feel litre dirty almost for doing that and Pm really 
12 
13 
like self-conscious about it. 
13 
14 
I mean I have like flashbacks a lot of going, 
14 
15 
and then I get really depressed. Every time I hear his 
15 
16 
name or something come up about it, I get depressed 
16 
17 
where I don't eat and I can't sleep. I just have really 
17 
18 
bad anxiety. lust my memory a lot too. I mean I have 
18 
19 
memory problems. 
19 
20 
I tried to like hide all the memories, just to 
20 
21 
try to get over everything. And I mean ifs just hard. 
21 
22 
Like when people bring it up and I have to talk about 
22 
23 
it it's embarrassing. It's hard. It just makes me 
23 
24 
feel like just I did something and it's -- I know now, 
24 
• 25 
you know, that it's not my fault, but at the time I 'tat 
25 
Page 242 
you tell them that he never touched you, that you never 
touched him, that nothing occurred other than you gave 
him a massage, just like you told the police? 
MR HOROVrITZ: Fenn. 
THE WITNESS: I told them that he tried, you 
know, to touch me and do things with me, but 
obviously I couldn't tell my parents everything. I 
mean they know now, you know, what's, what went on 
there and, you know, just from assuming and hearing 
from other people and reading things. 
BY MR. CRITTON: 
Q. Okay. Let me move to strike as nonresponsive. 
I don't want to know what they assumed, okay? 
I'm not interested in that. I'm interested in what you 
told them. 
So if you listen to my question, you keep 
adding on, but Pm assuming and they read this and they 
read that. I'm not — Pm glad they have read, or it's 
up to them what they want to read or not. !just want 
to know what they have told you and what you have said 
to them, okay? So focus on my question if you would, 
ma'am. 
You told me earlier, a couple of times, that 
you told them the day that the Palm Beach police were 
there at your house the same thing that you had said to 
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the police, correct? 
2 
A. Yes. 
3 
Q. Okay. And what you would have said to them 
4 
was, is that you gave him a massage on one occasion, he 
5 
never touched you, and you never touched any of his 
6 
private parts, right? 
7 
MR. HOROWITZ: Form. 
8 
BY MR. CRITTON: 
9 
Q. You told him that? 
10 
A. Yes. 
11 
Q. And you told them the second time you went, 
12 
you took somebody else, you mayiurve gone with Jane 
13 
Doe 4, you may have gone with 
but you didn't go 
14 
upstairs, correct? 
15 
A. Yes. 
16 
Q. Okay. So at least as of that date, as of the 
17 
date that you spoke with them, which you have testified 
18 
as well today is the only time you have ever talked to 
19 
them about what occurred at Mr. Epstein's house, as far 
20 
as they know, you gave Mr. Epstein a massage on one 
21 
occasion, you were fully clothed and he was completely 
22 
covered, true? 
23 
MR. HOROWITZ: Form. 
24 
THE WITNESS: I mean at that point, that's 
25 
Alai I told them, yes. 
1 
BY MR. CRITTON: 
2 
Q. At the current time? 
3 
MR HOROWITZ: Form. 
4 
THE WITNESS: A lot, especially lately, me 
5 
having to go through all this. 
6 
BY MR. CRITTON: 
7 
Q. You mean having to do this deposition? 
8 
A. I mean this whole — I mean it depends. I 
9 
mean sometimes it's worse than others. Like when they 
10 
bring up his name or, you know, my mom will call me 
11 
saying she read something in the newspaper, I won't be 
12 
able to eat for like a week. III get depressed. 
13 
have bad anxiety. Ifs hard for me to like do 
14 
schoolwork. It will bring like flashbacks back. 
15 
Just every day I feel like disgusting, and 
16 
every time I hear his name, it just brings back 
17 
memories. 
18 
Q. This is an everyday thing for you? 
19 
MR. HOROWITZ: Form. 
20 
IRE WITNESS: Not every day, I mean some 
21 
days --
22 
BY MR. CRITTON: 
23 
Q. You --
24 
MR. HOROWITZ: She wasn't done, I don't think. 
25 
MR. CRITTON: She keeps changing anyway. It 
Page 244 
1 
BY MR. CRITTON: 
2 
Q. Right. And they may have read things in the 
3 
newspaper, but you have never told them anything
4 
different than what you told them that one occasion back 
5 
on October 4th of 2005, correct? 
6 
MR HOROWITZ: Form. 
7 
THE WITNESS: Yes. I mean I also told the 
8 
cops that he did try to grab me in my butt and I 
9 
believe I told my parents that too. 
10 
BY MR. CRITTON: 
11 
Q. Okay. So you told them that too. And that's, 
12 
as far as they know, that's all that occurred, true? 
13 
A. Yes. 
14 
MR. HOROWITZ: Form. 
15 
BY MR. CRITTON: 
16 
Q. Okay. Now, you gave a list of issues that you 
17 
have, including depressed, anxiety, you feel damaged or 
18 
dirty, self-conscious. You don't eat, sleep, things of 
19 
that nature. 
20 
How often do any of those symptoms or those 
21 
issues bother you? 
22 
MR. HOROWITZ: Form. 
23 
BY MR. CRITTON: 
24 
Q. Or cause you any concern? 
MR, HOROWITZLIonn. 
(561) 832-7500 
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Page 246 
doesn't make any difference. 
MR. HOROWITZ: Move to strike. 
BY MR. CRITTON: 
Q. Are you done? Are you going to add more to 
it? 
A. What else were you going to ask me? 
Q. Your lawyer thought you had more to say, so 
I'm going to give you the chance. 
rm trying to find out how often this bothers 
you. Say over the last six months or a year, how often 
do any of those symptoms seem to bother you? 
A. I mean every week. 
Q. Every —
A. Basically. I mean I try do other things to 
like you know, I mean I try to go out with my friends 
and hang out and just to kind of get it off my mind, but 
I mean something always comes back to remind me or bring 
it up, or I'll hear something and I just fall into like 
depression again. 
Q. Okay. So has this been true since the day 
that the Palm Beach police came to your home on 
October 4th of 2005? 
MR HOROWITZ: Form. 
THE WITNESS: Yes. 
31 (Pages 243 to 246) 
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Page 249 
1 
BY MR. CRITTON: 
2 
Q. Is that when it started, when all of a sudden 
3 
you knew that someone else might know? 
4 
MR. HOROWITZ: Fa 
3 
THE WITNESS: It started before then, like 
even when I was going like I would be depressed and 
I would just, like I don't know why I kept going. 
I was confined, but I mean I just felt dirty kind 
9 
of and I was upset then. So I mean it's been going 
10 
on for a while, not just after the police. 
11 
BY MR. CRITTON: 
12 
Q. So now it's your testimony that from the first 
13 
time you went to Mr. Epstein's home, you were depressed? 
14 
MR. HOROWITZ: Form. 
15 
THE WITNESS: Not the first time. 
16 
BY MR. CRITTON: 
17 
Q. How about the second time? 
18 
MR. HOROWITZ: Fonn. 
19 
THE WITNESS: I mean if you're really going to 
20 
start doing that to me, !mean it's —
21 
BY MR. CRITTON: 
22 
Q. It's not doing it to you, ma'am. I need to 
23 
know. You are claiming $50 million against Mr. Epstein 
24 
in this case, so I need to know when --
25 
A. Well, you are like belittling everything I am 
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MR. HOROWITZ: Farm. 
THE WITNESS: The first time I really became 
depressed was like after the last time I went when 
he really tried to, you know, do stuff with me 
forcefully, and then I just felt disgusting and I 
got depressed, and that's why I just stopped going. 
BY MR. CRITTON: 
Q. Okay. And time flame again you are not sure, 
it might have been in '04, it might have been in '05, 
you are just not sure, correct? 
MR. HOROWITZ: Form. 
BY MR. CRITTON: 
Q. When the last time you went to Mr. Epstein's? 
A. I can't remember the exact date. 
Q. Sometime in 2004, 2005? 
A. Yes. 
Q. All right And prior to the last time you 
were there, you had never been depressed when you had 
been at Mr. Epstein's home; is that correct? 
MR. HOROWITZ: Form. 
THE WITNESS: I mean I was upset. I 
wouldn't — I don't, I can't — I don't know, I 
can't prescribe myself I'm not a psychologist, I 
don't — 
Page 213 
=Yin& 
2 
Q. Tin not belittling it, okay? I'm not at all. 
3 
MR. HOROWITZ: I think you are, Bob. You are 
4 
snickering. 
5 
MR. CRITTON: I am not snickering at all, all 
6 
right? 
7 
MR. HOROWITZ: You did several times. 
MR. CRITTON: I did not 
9 
MR. HOROWITZ: You have rolled your eyes 
10 
several times. 
11 
MR. CRITTON: Well, there's a lot of things 
12 
that you've rolled your eyes at and I don't call 
13 
you on it, and with the changes of testimony this 
14 
lady has, it's a wonder my eyes can stay normal 
15 
anyway with the level -- anyway, be that as it may, 
16 
you can object to form all you want. 
17 
BY MR. CRITTON: 
18 
Q. So let me clear it up with you, ma'am. I'm 
19 
interested in what your damages are in this case. Do 
20 
you understand that? 
21 
A. Yes. 
22 • 
Q. Okay. So have you been depressed since the 
23 
first time you went to Mr. Epstein's home? And if not, 
24 
tell me when you first became depressed as a result of 
25 
having met Mr. Epstein. 
Page 250 
1 
BY MR. CRITTON: 
2 
Q. Well, were you ever anxious when you left 
3 
Mr. Epstein's house? 
4 
A. Yeah, every time I left his house, I just 
5 
thought what did I just do? And I don't know why I kept 
6 
going. 
7 
THE VIDEOGRAPHER: Five minutes till tape 
8 
change. 
9 
BY MR. CRITTON: 
10 
Q. Even though you were anxious, you knew what 
11 
was going on at lean from your own words earlier was 
12 
inappropriate, you continued to go back to 
13 
Mr. Epstein's; nue? 
14 
MR. HOROWITZ: Fenn. 
15 
THE WITNESS: Yes. 
16 
BY MR. CRITTON: 
17 
Q. And you chose voluntarily to get in your car 
18 
and go back to Mr. Epstein's; true? 
19 
A. Yes. 
20 
Q. All right Did you feel self-conscious? 
21 
A. I mean of course I did. 
22 
Q. After the first time you went to Mr. Epstein's 
23 
home? 
24 
A. I mean yeah. I just, I felt like somebody is 
25 
going to find out or I mean I vms just, the whole time ] 
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was just, I just felt disgusting for going there. 
2 
Q. All right. And at that time did you have, 
1 
during the time you were going to Mr. Epstein's, did you 
4 
have flashbacks? 
A. No, they started after. 
Q. When? 
7 
A. After I stopped going there. 
8 
Q. The day after the last time you were there, 
9 
did they start? 
10 
A. No. Ifs like when my friends would say, you 
11 
know, they went to Jeffrey's or something, then I would 
12 
get flashbacks. 
13 
Q. Which of your friends did you tell after the 
14 
last time you went to Mr. Epstein's that you were either 
15 
depressed, you were anxious, you felt disgusting, 
16 
self-conscious, or that you were having flashbacks? 
17 
MR. HOROWITZ: Form. 
18 
BY MR. CRITTON: 
19 
Q. Which of the friends did you tell? 
20 
A. I believe just Jane Doe 4. 
21 
Q. Okay. And you told Jane Doe 4 that you were 
22 
having all these symptoms, right? 
23 
A. I mean no. 
24 
MR. HOROWITZ: Form. 
25 
THE WITNESS: I don't exactly remember what I 
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Page 253 
by the FBI and then just everything came back. And 
that's when it started getting really bad and I was 
really upset then. 
And, you know, just having to talk to the FBI, 
and l mean that was like depressing and scary and 
like I just had really bad anxiety and I felt like 
I was having panic attach. 
And I mean, so I mean it kind of started back 
up. 
BY MR. CRITTON: 
Q. Okay. So sometimes it's more, sometimes its 
less? 
A. Yes. 
Q. And is it because again someone brought it to 
your attention or wants to talk about it that that 
causes you anxiety? 
MR. HOROWITZ: Form. 
THE WITNESS: I mean of course some people 
like bring it up and I hear about it, I get, you 
know, anxiety and it just brings back everything. 
BY MR. CRITTON: 
Q. Do you think this lawsuit creates anxiety for 
you? 
A. I mean of course. 
Q. All right. And you think when this lawsuit is 
Page 252 
1 
told her. ljust remember telling her I was upset 
2 
about it 
3 
BY MR. CRITTON: 
4 
Q. But you knew she was still going? 
5 
A. Yes. 
6 
Q. Okay. Did you say "Jane Doe 4, I feel 
7 
depressed, anxious, disgusting, self-conscious, Pm 
8 
having flashbacks, I'm not eating and sleeping, I'm 
9 
having memory problems. Why in heaven's name would you 
10 
continue to go see Mr. Epstein?" 
11 
Did you have that conversation with your very 
12 
best friend? 
13 
MR. HOROWITZ: Fonn. 
14 
THE WITNESS: No. 
15 
BY MR. CRITTON: 
16 
Q. What have these symptoms that you've expressed 
17 
of depression, anxiety, feeling disgusting, 
18 
self-conscious, flashbacks, have those symptoms been 
19 
pretty much the same since you last sent to 
20 
Mr. Epstein's up through the current time? 
2/ 
MR. HOROWITZ: Form. 
22 
THE WITNESS: I mean right around when I 
23 
stopped going, they were really bad. And then, you 
24 
know, it just kind of, you know, I tried to forget 
i125 
about it up until, you know, when I got contacted 
(561) 832-7500 
Page 254 
1 
over, a lot of the anxiety that you have and the 
2 
feelings that you have will go away? 
3 
MR. HOROWITZ: Form. 
4 
THE WITNESS: I'm hoping after it's over, I 
5 
can just kind of get help and get past everything. 
6 
BY MR. CRITTON: 
7 
Q. And whetter you recover a dollar from 
8 
Mr. Epstein or S100,000, do you think that your ability 
9 
to gel better will be the same? 
10 
MR. HOROWITZ: Rem. 
11 
TIlE WITNESS: Idol* think there is any 
12 
amount of money that could ever, you know -- I mean 
13 
!would much rather have never had this happen to 
14 
me than have any amount of money. There is 
15 
nothing, amount of money that somebody could give 
16 
me to help me get through everything, but I mean 
17 
I'm just hoping that when everything is over, you 
18 
know,1 can just try to see somebody to help me and 
19 
try to forget about it and move on with my life. 
20 
MR CRITTON: Need to change tape. 
21 
THE VIDEOGRAPHER: Going off the record at 
22 
3:07 p.m This madcs the end of tape two. 
23 
(Discussion held off the record.) 
24 
THE VIDEOGRAPHER: We're back on the record at 
2 5 
3:09 p.m. This marks the beginning of tape three. 
33 (Pages 251 to 254) 
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Page 257 
1 
BY MR. CR1TTON: 
2 
Q. Jane Doe 7, do you believe that you've lost 
3 
. any money; that is, have you lost any wages, jobs as a 
4 
result of your having been to Mr. Epstein's home? 
5 
MR. HOROWITZ: Form. 
6 
THE WITNESS: No. 
7 
BY MR. CRITTON: 
8 
Q. Okay. Do you believe you have lost the 
9 
ability to earn money in the future as a result of 
10 
having been to Mr. Epstein's home? 
11 
MR. HOROWITZ: Fenn. 
12 
THE WITNESS: I do believe I could have got a 
13 
lot better grades if I wasn't going through this 
14 
all of college. 
15 
BY MR. CIUTTON: 
16 
Q. Well, in high school it looks like you, and 
17 
particularly your senior year after you alleged in part 
18 
that you stopped seeing Mr. Epstein, you got almost all 
19 
A's and a few Ws; did you not? 
20 
A. Yes. 
21 
Q. Okay. And it appears in looking at least to 
22 
your junior and sophomore years is your grades after you 
23 
stopped seeing Mr. Epstein, at least you say you stopped 
24 
seeing Mr. Epstein improved substantially; is that true? 
25 
MR. HOROWITZ: Form. 
1 
working? 
2 
A. Yes, !worked for my dad and my dad's friend 
3 
in the aMbusiness. 
4 
Q. licnnti• tit was real life experience? 
5 
A. Pretty much. 
6 
Q. All right. And what kind of grades did you 
7 
get at 
8 
A. I just got average grades, l think. 
9 
Q. B's, A's and B's? 
10 
A. Yeah, hire Ws. 
11 
Q. What was your grade point from 
12 
A. I don't remember. I think it was111 
13 
know. 
14 
Q. How about since you've been ate what's 
15 
your grade point there? 
16 
A. I think it's around like a 2.8 or 2.9. 
17 
Q. So it's Ince a B minus? 
18 
A. Yeah. 
19 
Q. 3.0 is a B, so you are almost at a B? 
20 
A. Yes. 
21 
Q. And would you describe yourself - if someone 
22 
described you as a party animal; would that be accurate? 
23 
A. No. 
24 
Q. So you rarely go out to clubs, to bars? 
25 
A. I mean I go out, of course, I'm in college, 
Page 256 
1 
THE WITNESS: The only reason why I got all 
2 
A's is because l had O1T. 
3 
BY MR. CRTTTON: 
4 
Q. What's on? 
5 
A. On-the-job training where they let you out of 
6 
school earlier for three hours. 
7 
Q. Well, in looking at your transcript from 
8 
twelfth grade, it looks like you took English 3 -- Pm 
9 
sorry, English 4, you got a B. That's not OJT, is it? 
10 
A. No. 
11 
Q. American economics, that's not OJT, is it? 
12 
You got a B in that? 
13 
A. Uh huh. 
14 
Q. Correct? 
15 
A. Yes. 
16 
Q. TY production, you got an A in that? 
17 
A. Yes. 
18 
Q. And then you had Work Experience 2, and three 
19' 
other O./Ts that you all got A's in, correct? 
20 
A. Yes, 
21 
Q. And you took - you did get one l in American 
22 
Political Systems, I see that, but all of your work 
23 
experience and Offs you got A's in, correct? 
24 
A. Yes. 
25 
Q. And OJT is where you learn, you are out 
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Page 258 
but Pm not a party animal. I still got my schoolwork 
done and do all my responsibilities that I have to do. 
Q. Okay. Just berause you are a party animal 
doesn't necessarily mean you don't do your work. 
Let me ask it more this way. YOU go out with 
your friends two to three, four times a week, might go 
to a club, to a bar or something hie that and hang out? 
Yes. 
Usually go out every weekend? 
I mean yeah, sometimes. 
Has that been hue both since you have been at 
and since you have been at M? 
A. Yes. 
Q. This spring break you went to Key West. Where 
did you go last spring break? 
A. Key West. 
Q. Did you stay at Nick's house again? 
A. No. 
Q. Where did you stay at that time? 
A. Four or five of us split a hotel there. 
Q. Very common for college kids to go down and 
stay a week and split a room and put a bunch of people 
in? Yes? 
A. Yes. 
• Q. You partied every night when you were down 
A. 
Q. 
A. 
Q. 
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there just like all the other college kids do? 
2 
A. Yes. 
3 
Q. Did you ever feel so depressed or anxious or 
4 
self-conscious or one of the times that you were not 
5 
eating or sleeping during spring break? 
6 
A. I was actually happy to get away from Orlando 
7 
and get away from everything, so that was kind of like 
8 
me getting way from everything was going on spring break 
9 
a taking trips. It was like me getting away from 
10 
everything. 
11 
Q. My question to you was did your depression, 
12 
anxiety, self-consciousness, feeling disgusting, having 
13 
flashbacks and not being able to eat and sleep, memory 
14 
problems, did any of those symptoms cause you not to go 
15 
on a spring break since you've been in college? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: No, that was why l went on 
18 
spring break was to get away from everything. 
19 
BY MR. CRITTON: 
20 
Q. Okay. And in the summer you are going to 
21 
Italy for a month. 
22 
A. Yes. 
23 
Q. Is that another escape so you can get away 
24 
from things? 
25 
A. No, it's just something I always wanted to do 
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Page 261 
A. No. I mean I would have to stay late. My 
reason for working there, it was an internship. 
Q. But you got paid too? 
A. Yes, I got paid, but I had to work in a 
hospitality establishment for my internship and I had to 
do three internships, so that was my reason for working. 
Q. What did you — I'm sorry, what do you plan to 
do when you finish? 
A. I honestly have no idea, but hopefully get a 
job. 
Q. You have bola 
and 
now aS 
a minor: 
A. Llh huh. 
Q. Have you started looking for a job at all? 
A. No, not now. 
Q. Have you tried to do any internships through 
school where you could ultimately move into, like 
Cheyenne, is it a chain or is it just a sole building? 
A. It's actually closed down now. 
Q. All right. Have you talked to any other 
restaurant chains or any other hotels or hospitality 
type situations to see if you could get an internship so 
you could get into the program and work your way up? 
A. No, because I'm leaving for Italy, so I —
there is no point in me starting to work somewhere now. 
Page 260 
I. 
is study abroad. 
2 
Q. And how about separate and apart from last 
3 
summer, you stayed up in Orlando. Were you still in 
4 
school, or this past summer, 2009, did you stay in 
5 
school? 
6 
A. Yes. 
7 
Q. Okay. And did you work during that time 
8 
period? 
9 
A. Last summer, I think I worked at Cheyenne's. 
10 
Q. Cheyenne's is like a bar, saloon? 
11 
A. Like a restaurant. 
12 
Q. Restaurant. And what do you do there? 
13 
A. I was just waitressing. 
14 
g 
How long have you worked there? 
15 
A. I worked there for about a year. 
16 
Q. You make like a minimum wage plus tips? 
17 
A. Yes. 
18 
Q. And in addition to doing your waitressing, 
19 
were you also in college; that is, were you taking some 
20 
courses? 
21 
A. Yes. 
22 
Q. All right. And as well, would you go out 
23 
with this last year, Jane Doe 4 is with you hi '08, 
24 
so this last year you would go out with your friends or 
25• 
stay out late when you finished your shifts? 
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Page 262 
I want to wait until I get back. 
Q. So when you get back from Italy, you will have 
to then start looking for a job? 
A. Yes. 
Q. Do you plan to return to Orlando or do you 
plan to return home? 
A. I don't know yet. 
Q. What have your parents said, or I guess you 
are an adult, so you can decide what you want to do, 
right? 
A. Yes. 
Q. But you have made no plans? 
A. No, not yet. 
Q. Is there anything, is there any activity that 
you haven't done as a result of what you claim are 
injuries or damages you sustained from being at 
Mr. Epstein's home? Is there anything you haven't done? 
A. I don't really know. 
Q. You can't think of anything? 
MR. HOROWITZ: Form. 
THE WITNESS: I mean I don't know. 
BY MR. CRTITON: 
Q. All right As you're sitting here, you can't 
think of any activity or any trip or any school that you 
have not done or a course that you haven't taken as a 
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1 
result of having been at Mr. Fpoein's home; is that 
2 
correct? 
3 
MR. HOROWITZ: Form. 
4 
THE WITNESS: Yes. 
5 
BY bollt. CRITTON: 
6 
Q. Let me show you Salt — are we on 
7 
Exhibit 4? 
8 
(The document was marked Defendant's 
9 
Exhibit 4 for identification.) 
10 
BY MR CRITTON: 
11 
Q. All right, let me show you Exhibit 4. Can 
12 
you — 
13 
A. I see you guys have access to my MySpace and 
14 
Facebook. 
15 
Q. My question is do you recognize that photo? 
16 
A. Yes, Id°. 
17 
Q. And who is that depicted in the photo? 
18 
A. That's.. 
19 
Q. And? 
20 
A. And me. 
21 
Q. All right. And where were you at the time? 
22 
A. We wore — it was Halloween. We were 
23 
somewhere for Halloween. 
24 
Q. All right So is it, Halloween is usually, I 
25 
think it's October 30th? 
Page 265 
1 
MR. HOROWITZ: I didn't raise my eyes. I said 
2 
she was responding to your question. 
3 
You wanted her to say that she could still 
4 
haveagoodtime-
5
MR. CRITTON: Let Rachel read the question 
6 
back. Don't use up my time. 
7 
(A portion of the record was read by the 
8 
reporter.) 
9 
BY MR. CRITTON: 
10 
Q. Let me repeat the question so ifs clear. 
11 
Exhibit 4 depicts you and 
out at 
12 
Halloween in costumes drinking 27 days after the police 
13 
interviewed you, and you told your parents for the first 
14 
time what, at least a wuncated version of what occurred 
15 
at Mr. Epstein's house, right? 
16 
A. Yes. 
17 
Q. And you were able, certainly not just 
18 
Halloween, but before that, after that you continued to 
19 
party and go to parties, correct? 
20 
A. I told you I used that, like me going to 
21 
parties has nothing to do with my anxiety and all of 
22 
that. 
23 
It's me trying to get, just trying to get ova 
24 
everything and hang out with my friends and forget about 
25 
everything that was going on. 
Page 2€1 
1 
MR. HOROWITZ: Every year. 
2 
BY MR. CRITTON: 
3 
Q. Every year, or 3Ist, whatever it is. Probably 
4 
the 31st So that would have been October 3Ist That 
5 
would have been approximately 27 days after the police 
6 
took your, or interviewed you in the beginning of 
7 
October of 2005; is that correct? 
8 
A. Yes. 
9 
Q. So you were still able to go out, go to 
10 
parties, do those kinds of things even after the police 
11 
interviewed you? 
12 
A. A lot of times l use drinking as like a way to 
13 
help me forget about what happened and forget about, you 
14 
know, the stress I was under because of it and about the 
15 
whole thing. 
16 
MR. CRITTON: Okay. I'm going to move to 
17 
strike as nonresponsive. So let me have Rachel 
18 
read the question back to you and see if you can 
19 
answer my question. 
20 
MR. HOROWITZ: That was responsive. 
21 
MR. CRITTON: Yeah, right. 
22 
MR. HOROWITZ: It's not the response you 
23 
wanted, but it's responsive. 
24 
MR. CRITTON: Stop rolling your eyes or 
25 
raising your eyebrows in support of your position. 
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Page 266 
Q. Before you ever went to Mr. Epstein's house, 
you hung out with your friends, right? 
A Yes. 
Q. Before you ever went to Mr. Epstein's house, 
while you may not have taken drugs, you did drink 
alcohol, didn't you? 
A. Not really. 
Q. So if people say before you ever went to 
Mr. Epstein's you never had alcohol or you had 
alcohol — I've got to start again. 
Is it your testimony that you never drank 
alcohol before you went to Mr. Epstein's? 
A. I don't remember if I ever drank or not, but 
it definitely wasn't like I do now. Like I wasn't 
partying. I might have had a beer or two beers, but I 
don't really remember. 
I remember starting to chink around my junior 
year of college. 
Q Olcay. 
A I mean, sorry, high school. 
Q. And is it now your testimony that you arc 
relating your drinking because you went to 
Mr. Epstein's? 
A. Pm not relating. It just helps me cope with 
eve2thirsiand forjet about it. 
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1 
Q College kids are notorious for drinking, 
2 
right? I mean kids drink in college? 
3 
MR HOROWITZ: Form. 
4 
IIIE WI NESS: Yes. 
5 
BY MR. CRITTON: 
6 
Q. • All right. And you drink and you drink to 
7 
excess from time to time, just like other college kids 
8 
do? 
9 
A. Yes. 
10 
Q Okay, because your college experience is very 
11. 
similar to what other college kids' experience is, from 
12 
what you've observed, true? 
13 
A. I don't think ifs half as similar as what 
14 
other college kids had to go through. And if they had 
15 
to go through this, Fm sure they would drink too in 
16 
excess. 
17 
MR- CRITTON: I'll move to strike as 
18 
nonresponsive. 
19 
BY MR. CRAYON: 
20 
Q. My question to you is other college kids go 
21 
out and party two, three, four times a week; that's not 
22 
unusual, is it? 
23 
A. I mean some do, some don't. 
24 
Q. All right. And you are with a crowd that does 
25 
and you like to do that, don't you? 
Page 269 
1 
BY MR. CRITTON: 
2 
Q. What did I say? 
3 
A. Faoebook. 
4 
Q. Facebook, okay, MySpace. Do you still have a 
5 
MySpace account? 
6 
A. I do. 
7 
Q. Do you have a Facebook as well? 
8 
A. Em sure you guys know. Yes, I do. 
9 
Q. I get to ask questions. I don't even know 
10 
what I know sometimes. You still use Facebook? 
11 
A. Yes. 
12 
Q. And is it still — what's your — what's the 
13 
word that you key into if someone wanted to look at your 
14 
MySpace? They would look at what? What would they have 
15 
to print in? 
16 
MR. HOROWITZ: Form. 
17 
THE WITNESS: What do you mean? 
18 
BY MR. CRITTON: 
19 
Q. What do you use as like your call — I should 
20 
know this, as your location. There is a word for that 
21 
and I can't — it says Jane Doe 7 on it, but what would 
22 
I type in to come to your MySpace page? 
23 
MR. HOROWITZ: Are you asking her for a 
24 
password? I don't think she has to give you that. 
25 
MR. CRITTON: No, I'm not asking for a 
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Page 268 
MR. HOROWITZ: Form. 
THE WITNESS: I mean I like to hang out with 
my friends and drink. 
BY MR. CRITTON: 
Q. All right. And you have described what your 
symptoms are after the last time you saw Mr. Epstein as 
being — lees see what you described it -- as 
depressed, anxious, felt disgusting, self-conscious, 
flashbacks, can't eat and sleep. 
Let me show you Exhibit 5. 
MR. HOROWITZ: I'm going to object to these 
exhibits, particularly under rule 26. You guys got 
to turn this stuff over. You can't just come to a 
deposition with these things. And you haven't 
produced tin 
(The document was marked Defendant's 
Exhibit 5 for identification.) 
MR. CRITTON: Here. 
MR. HOROWITZ: Take a look at this. 
BY MR. CRITTON: 
Q. Do you recognize this as being part of your 
Facebook space from the 2005 time period? 
MR. HOROWITZ: Form. 
THE WITNESS: No. It's part of my MySpace. 
Page 270 
1 
password, but just to get on your Facebook. 
2 
THE WITNESS: You have to fiend request me. 
3 
BY MR. CRITTON: 
4 
Q. I'm sorry? 
5 
A. You have to friend request me. 
6 
Q. If I just typed in Jane Doe 7, would your name 
7 
come up under MySpace? 
8 
A. Yes. 
9 
Q. Same thing with Facebook? 
10 
A. Yes 
11 
Q. And then you would decide whether you want me 
12 
to be your friend? 
13 
A. Yes. 
14 
Q. And I would be pretty confident that if I 
15 
wrote to you, you would say no, right? 
16 
A. Probably, yes. 
17 
Q. All right, good. Let's stick with Exhibit S. 
18 
This is your Faceboolc? 
19 
A. My MySpace. 
20 
Q. I'm sorry, MySpace. It has Jane Doe 7's 
21 
blurbs, which means that you would have created that 
22 
yourself, tight? 
23 
A. Yes. 
24 
Q. Could you read for the ladies and gentlemen of 
25 
the jury what you have under your blurb? 
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A. Where is my blurb at? 
Q. Under the Welcome. 
A. This is ridiculous. I mean everybody has a 
MySpace. 
Q. I'm just asking you to read it, nufam. 
A. 
quote. 
Q. All I'm asking you is to read it. I don't 
want you to editorialize, please. 
A. I mean I see how you are going to turn 
everything around, so — 
Q. Please continue readin: 
A. 
Page 272 
6 
Q. And if you go over to page two, you say "Who 
rd like to meet" That's also what you wrote; Is that 
true? 
9 
A. Yes. 
10 
Q. Read to the ladies and gentlemen of the jury 
11 
what you put in December of '05, or at least what was on 
12 
your MySpace account in December of '05. 
13 
A. "I like guys who are fun and outgoing. Hike 
14 
guys who like to go out but at the same time don't mind 
15 
staying in and watching a movie. Being too serious or 
16 
conceited is a turnoff. I don't like guys that are 
17 
really jealous either. I don't like getting hurt, so 
18 
Pm not one to get attached to one guy quickly. I 
19 
believe there is someone for everyone. Ws just a 
20 
matter of them finding you? 
21 
Q. Look on the pictures or page two. Do you get 
22 
to choose the pictures that you put on MySpace? 
23 
A. Yes. 
24 
Q. Okay. So like the Dior one would be something 
25 
you would have chosen and put in? 
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1 
A. Yes. 
2 
Q. Where the lady is buying on her back with the 
3 
foot on maybe the pool attendant, is that a picture tha 
4 
you would have chosen? 
5 
A. Yeah, I was a fan of Paris Hilton. 
6 
Q. Is that Paris? 
7 
A. Yes. 
8 
Q. All right. The Jane Doe 4 again on page two, 
9 
is the Jane Doe 4 there, is that — that's not Jane 
Doe 4, is it, or is it or can y0u tell? 
A. Yeah, that's Jane Doe 4. 
Q Jane Doe 4 who? 
A. Jane Doe 4. 
Q Oh, that is Jane Doe 4, all right. 
Ova on page four, where it says, 
which 
is that? 
Q. All right. And over on page six there is an 
In fact, at the top of page six it has Jane Doe 4, 
11/29105. "Jane Doe 7, you need to call me. I was 
drunk last night when you called and only remember bits 
of what was going on. Call me, love you all." 
Is that Jane Doe 4? 
A. Yes. 
Q. And under that is. 
also the same day. 
Page 274 
1 
Says "I'm having a party, party girl. Talk to 
2 
about it. Losay2u." 
3 
Is than 
who you took to Mr. Epstein's 
4 
home? 
5 
A. Yes. 
6 
Q. So did you continue to remain friends with her 
7 
fora period of time? 
8 
A. Yes. 
Q. Do you ever hear from her now? 
A. Uhuh. 
Q. I'm sorry? 
A. No. 
Q. Let me show you what I'll show you as 
Exhibit 6. 
(The document w MS marked Defendant's 
Exhibit 6 for identification.) 
MR. HOROWITZ: I'm going to again object in 
that the defendant to this day has not produced 
these things, despite their obligation under Wile 
26. 
BY MR. CARTON: 
Q. Now this is again from your MySpace pag
A. Yes. 
Q All right. And again, the photographs or 11e 
information say it's on_page one, that's you, correc 
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Page 277 
left side? 
A. Yes. 
Q. And in fact, this one says last login, 
7/14/2006. 
Does that mean that's the date, that is tlx: 
6 
last time you would have logged in to this? 
7 
MR. HOROWITZ: Form 
:3 
THE WITNESS: At that time. 
9 
BY MR. CRITTON: 
10 
Q. All right. It says "Jane Doe Ts interests. 
11 
If you go to page two, it has Jane Doe Ts interests. 
12 
This is now, this is you on July 14 of '06 
13 
that you would have beeii.lis would have been the 
14 
end of your first year at 
15 
A. (Witness nods head up and down.) 
16 
Q. Correct? 
17 
A. Yes. 
18 
Q. Did you stay up in Orlando during that time 
19 
period? 
20 
A. Yes. 
21 
Q. All right. What does it say Jane Doe Ts 
22 
interests are, general? Could you read that to the 
23 
ladies and gentlemen of the jury? 
24 
A. "I love anything on the water and getting a 
25 
tan. I rode horses since I was like four and still love 
1 
A. Yes. 
2 
Q. All right. And then hanging out in the lofts 
3 
pool. Lofts is where you were living at the time? 
4 
A. Yes. 
5 
Q. The guy, do you know him? 
6 
A. Yeah, he's a friend of mine. 
7 
Q. Boyfriend or just a guy friend? 
8 
A. Just a friend. 
9 
Q. It says "Getting some sun in South Beach." 
10 
The picture on the right, who is that? 
11 
A. Me and. 
12 
Q 
13 
A. Yes. 
• 
14 
Q. Is that when you had met Mario? 
15 
A. Yes. 
16 
Q. All right. Pictures on.page three, and again, 
17 
let me, if I go back to page two where it gives a little 
18 
history of yourself, again, 
19 
again, that's what you put on Facebook, correct? 
20 
A. IvIYSPace• 
21 
Q. I'm sorry, MySpace. All right, and then the 
22 
pictures on page four, those again were ones that you 
23 
chose, true? 
24 
A. Yes. 
25 
MR. HOROWITZ: Bob, how is it that you didn't 
Page 276 
1 
it. I also like relaxing girls' nights out, surfing, 
2 
the beach, goofing off, partying, being in love, coming 
3 
up with funny dnmken sayings. I'm not going to lie. 1 
4 
like to watch football. I'm a huge Steele fan and I 
5 
like baseball. Watching the Steelers isn't too bad 
6 
either." 
7 
Q. Are you pretty active even today on Facebook 
8 
and MySpace? 
9 
A. Just Facebook. I don't use MySpace anymore 
10 
really. 
11 
Q. MI right. Over on, the bottom picture on 
12 
page two, who is in that picture? 
13 
MR. HOROWITZ: Form 
14 
BY MR. CRITTON: 
15 
Q. Can you tell? 
16 
A. Right here? 
17 
• Q. Pardon? 
18 
A. • 'tight here? 
19 
Q. No, the lower picture, it has three females. 
20 
A. Me and Jane Doe 4 and.. 
21 
Q. Jane Doe 4 ant
? 
22 
A. Yes. 
23 
Q. All right. Go over to page three. It has 
24 
pictures again. It has "A dangerous combo." Is that 
25 
you in the truck? 
Page 278 
1 
produce these things? I'm having a hard time, I'm 
2 
still sat of wrestling with this. 
3 
MR. CRITTON: If you want to file a motion, 
4 
that's fine, and I'll explain to the Judge. 
5 
MR. HOROWITZ: I want her not to answer any 
6 
questions about this stuff 
7 
MR. CRITTON: I think this is all impeachment 
8 
information anyway. 
9 
MR. HOROWITZ: I don't care, you have to 
10 
produce it. 
11 
MR. CRITTON: No, I don't 
12 
MR. HOROWITZ: Yes, you do. 
13 
MR. CRITTON: We will respectfully disagree. 
14 
BY MR. CRITTON: 
15 
Q. If you to
 to page II. 
1.6 
THE WITNESS: Do I have to answer this? • 
17 
MR. HOROWITZ: I don't know what the question 
18 
is, but l might tell you not to. 
19 
BY MR. CRITTON: 
20. 
Q. On page 11 it has a Jane Doe 4 and it looks 
21 
Ifice the two of you were, or two faces arc hanging there 
22 
. with their tongues out. Who is that? 
23 
MR. HOROWITZ: Is that impeachment? 
24 
Don't answer it. You guys aren't playing 
25 
tinder the rules. You are not producing stuff that 
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"IMPIIMIWaia,'••••••• 
.(561) 832-7500 
832-7500 
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PROSE COURT REPORTING AGENCY, INC. 
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