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0308 
1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 08-CV-80119-MARRA/JOHNSON 
2 
3 
4 
JANE DOE NO. 2, 
5 
Plaintiff, 
6 
-vs- 
VOLUME III OF III 
7 
JEFFREY EPSTEIN, 
8 
Defendant. 
9 
Related cases: 
08-80232, 08-08380, 08-80381, 08-80994, 
10 
08-80993, 08-80811, 08-80893, 09-80469, 
09-80591, 09-80656, 09-80802, 09-81092 
11 
 
12 
VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF 
JANE DOE NO. 4 
13 
14 
Tuesday, October 27, 2009 
11:11 - 6:05 
15 
16 
17 
250 Australian Avenue South 
Suite 115 
18 
West Palm Beach, Florida 33401 
19 
20 
21 
Reported By: 
Cynthia Hopkins, RPR, FPR 
22 
Notary Public, State of Florida 
Prose Court Reporting 
23 
24 
25 
0309 
1 
APPEARANCES: 
2 
On behalf of the Plaintiff, L.M. and E.W.: 
3 
MICHAEL J. WHEELER, ESQUIRE 
ROTHSTEIN, ROSENFELDT, ADLER 
4 
401 East Las Olas Boulevard 
Suite 1650 
5 
Fort Lauderdale Florida 33301 
Phone: 
6 
7 
On behalf of Jane Does 1 through 8: 
8 
ADAM D. HOROWITZ, ESQUIRE 
STUART S. MERMELSTEIN, ESQUIRE 
9 
MERMELSTEIN & HOROWITZ, P.A. 
18205 Biscayne Boulevard 
10 
Suite 2218 
Miami, Florida 33160 
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Phone: 
E-mail: 
12 
13 
On behalf of C.M.A.: 
14 
RICHARD HORACE WILLITS, ESQUIRE 
RICHARD H. WILLITS, P.A. 
15 
2290 10th Avenue North 
Suite 404 
16 
Lake Worth Florida 33461 
Phone: 
17 
(Via Telephone) 
18 
On behalf of the Defendant, Jeffrey Epstein: 
19 
ROBERT D. CRITTON, JR., ESQUIRE 
MARK T. LUTTIER, ESQUIRE 
20 
BURMAN, CRITTON, LUITIER & COLEMAN, LLP 
303 Banyan Boulevard 
21 
Suite 400 
West Palm Beach Florida 33401 
22 
Phone: 
23 
24 
ALSO PRESENT: Jeffrey Epstein, via video conference 
Jeff Abbott, Videographer 
25 
Visual Evidence, Incorporated 
0310 
1 
2 
INDEX
-
3 
4 
WITNESS: 
DIRECT CROSS REDIRECT RECROSS 
5 
JANE DOE NO. 4 
6 
CONTINUED 
7 
BY MR. LUTTIER 311 
8 
9 
10 
EXHIBITS 
11 
12 
13 
EXHIBIT 
DESCRIPTION 
PAGE 
14 
DEFENDANT'S EX. 1 Proposal for Settlement 
72 
15 
DEFENDANT'S EX. 2 Answers to Interrogatories 232 
16 
DEFENDANT'S EX. 3 Petition for Injunction 
348 
17 
DEFENDANTS EX. 4 Handwritten Note 
384 
18 
DEFENDANTS EX. 5 Psychological/Social History 394 
19 
20 
21 
22 
23 
24 
25 
0311 
1 
2 
CONTINUED DIRECT EXAMINATION 
3 
THE VIDEOGRAPHER: It is the beginning of 
4 
Tape Number 3. We're back on the record at 
* * * * * 
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4:19. 
6 
BY MR. LUTTIER: 
7 
. All right. 
8 
9 
A. 
10 
11 
12 
A. 
13 
14 
Q. 
15 
A. 
16 G
 
17 
18 
A 
19 
20 
Q. 
21 
A. Yeah. 
22 
Q. 
23 
A. 
24 
25 
Q. 
0312 
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5 
6 
7 
8 
9 
10 
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12 
13 
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15 
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17 
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24 
25 
Q. 
0313 
1 
A. Yes. 
2 
Q. 
3 
A. 
4 
Q. 
5 
A. Yes. 
6 
Q. 
A. Yeah I think so. 
Q. 
A. Yeah. 
Q. 
A. Yeah. 
Q. 
A. Yeah. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. 
Q. 
A. Yeah. 
MR. MERMELSTEIN: Objection to form. 
THE WITNESS: Yeah. 
BY MR. LUTTIER: 
Q. 
A. 
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A. Yes. 
8 
Q. Who? 
9 
A. 
10 
Q. 
11 
A. 
12 
Q. 
13 
A. 
14 
15 
16 
17 
A. Yeah. 
18 
19 
20 
21 
22 
23 
24 
25 
finish. Let him finish. 
0314 
1 
BY MR. LUTHER: 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
A. No. 
15 
16 
17 
A. I don't remember. 
18 
19 
know. 
20 
. Prior to having sexual intercourse with 
21 
did you have other types of sex with him? 
22 
Specifically did you have oral sex with =? 
23 
MR. MERMELSTEIN: I'm going to object. 
24 
This applies to our Rule 412 objection. Don't 
25 
answer the question. 
0315 
1 
BY MR. LUTHER: 
2 
Q. Did you have -- do you know a uy named 
3 
Mister -- a guy by the name o 
last name 
4 
5 
A. Yes. 
6 
Q. Did you have oral sex with him? 
7 
MR. MERMELSTEIN: Don't answer the 
8 
question. 
A. 
MR. MERMELSTEIN: How about letting him 
MR. MERMELSTEIN: Objection, asked --
BY MR. LUTTIER: 
Q. 
A. No. 
MR. MERMELSTEIN: Asked and answered. 
BY MR. LUTHER: 
I don't remember -- I don't -- I don't 
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BY MR. LUTTIER: 
10 
Q. When you -- how old were you when you --
11 
MR. MERMELSTEIN: Same objection. 
12 
BY MR. LUTTIER: 
13 
. How old were you when you knew 
14 
Mr. 
15 
A. I was in middle, or middle school. 
16 
Q. What, middle school? 
17 
A. Yeah, I know him. 
18 
Q. Middle school? 
19 
A. Yeah. 
20 
Q. Do you know a 
(phonetic)? 
21 
A. Yeah. They were best friends. 
22 
MR. MERMELSTEIN: The question is, do you 
23 
know him. 
24 
THE WITNESS: Yeah. 
25 
0316 
1 
BY MR. LUTTIER: 
2 
Q And do ou know what the relationship 
3 
between 
nd Mr.Mlwas? 
4 
A. Friends. 
5 
Q. Okay. They pals or pal around together? 
6 
A. Friends. 
7 
Q. You knew them both? 
8 
A. Yeah. 
9 
Q. Did you have oral sex with both of them? 
10 
MR. MERMELSTEIN: Don't -- again, Rule 412 
11 
objection. Do not answer that question. 
12 
BY MR. LUTTIER: 
13 
Q. And, and did you associate with either of 
14 
these individuals once you got to high school? 
15 
A. Yeah. 
16 
Q. Did stit
i
ave oral sex with Mr. 
17 
and/or Mr. 
before you went to see 
18 
Mr. Epstein? 
19 
MR. MERMELSTEIN: Objection, Rule 412. Do 
20 
not answer that question. 
21 
BY MR. LUTTIER: 
22 
Q. Do you know a fellow by the name of.? 
23 
A. That's 
24 
Q. Okay. Did
 have sexual intercourse 
25 
with either Mr. 
or Mr. 
at any time? 
0317 
1 
MR. MERMELSTEIN: Objection, Rule 412. Do 
2 
not answer that question. 
3 
BY MR. LUTTIER: 
4 
. Did ou have sexual intercourse with 
5 
Mr. 
or Mr. 
before you went to see 
6 
Jeffrey Epstein? 
7 
MR. MERMELSTEIN: Objection, Rule 412. Do 
8 
not answer the question. 
9 
BY MR. LUTHER: 
10 
Q. All right. 
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12 
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14 
15 
16 
A. (No verbal response.) 
17 
Q. Ri ht? 
18 
A. 
19 
Q. 
o 
20 
A. 
21 
22 
23 
A. 
24 
Q. 
25 
A. Yeah. 
0318 
1 
Q. Okay. 
2 
A. I don't remember. 
3 
4 
5 
6 
7 
8 
A. 
9 
Q. 
10 
A. 
11 
Q. 
12 
A. 
13 
Q. 
14 
A. 
15 
16 
17 
A. Yeah. 
18 
Q. 
19 
A. 
20 
Q. 
21 
A. Yeah. 
22 
Q. 
23 
A. 
24 
25 
0319 
1 
A. Yeah. 
2 
Q. 
3 
A. Yeah. 
4 
5 
6 
A. Yeah. 
9 
8 
7 
10 
A. Yeah. 
11 
. O1
4S 
IM 
12 
Q. 
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A. 
14 
15 
16 
A. Yeah. 
17 
18 
19 
A. No. 
20 
Q. 
21 
A. No. 
22 
Q. 
23 
A. 
24 
Q. 
25 
A. 
0320 
1 
Q. 
2 
A. Yeah. 
3 
Q. Do ou --
4 
A. 
5 
Q. Well, did you? 
6 
MR. MERMELSTEIN: Be certain of your 
7 
answer. 
8 
BY MR. LUTTIER: 
9 
Q. Yeah, take your time. 
10 
A. Yeah I think so. Yeah. 
11 
12 
I don't 
13 
remember. 
14 
Q. Oka 
15 
A. 
16 
17 
18 
MR. MERMELSTEIN: Make sure you're sure of 
19 
your answer before you give it. If you need to 
20 
pause for a minute after the question is asked, 
21 
do so, but make, make sure you're -- you know, 
22 
before you blurt out your answer, make, make 
23 
sure you, you recall correctly. Okay? 
24 
BY MR. LUTTIER. 
25 
Q. 
0321 
1 
2 
3 
A. Yeah. 
4 as
5
6 
A. Yeah. 
7 
8 
9 
10 
11 
12 
13 
14 
A. There. What you mean, there? 
Q. Well 
ou've of to get the actual --
A. 
SOkay. 
A. Yeah. 
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Q. 
16 
A. 
17 
Q. 
18 
A. 
19 
20 
21 
22 
A. 
23 
24 
O. 
25 
0322 
1 
A. No.
2 
3 
4 
5 
6 
7 
A. 
8 
Q. 
9 
A. Yeah. 
10 
Q. 
11 
A. Yeah. 
12 
Q. 
13 
A. 
14 
Q. 
15 
A. No. 
16 
Q. 
17 
A. 
18 
19 
20 
21 
Q. 
22 
A. No. 
23 
24 
25 
0323 
1 
A. Yeah. 
2 
3 
4 
A. 
No. 
5 
6 
7 
A. 
8 
9 
10 
11 
12 
A. No. 
13 
O.
14 
15 
A. No. 
16 
Q. 
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18 
A. Yeah. 
19 
Q. 
20 
A. 
21 
22 
23 
24 
A. No. 
25 
0324 
1 
2 
3 
4 
5 
A. 
6 
Q. Right? 
7 
A. Yeah. 
9 
10 
11 
A. 
8 
12 
13 
Q. 
14 
MR. MERMELSTEIN: Objection, form. 
15 
Objection, argumentative. 
16 
BY MR. LUTTIER• 
17 
Q. 
18 
A. Yeah. 
19 
MR. MERMELSTEIN: Objection, argumentative 
20 
again. 
21 
BY MR. LUTTIER: 
22 
Q. Is that correct? 
23 
A. Yeah. 
24 
Q. 
25 
A. 
0325 
2 
A. 
3 
Q. 
Q. 
1 
4 
A. Yeah. 
5 
Q. 
6 
A. 
7 
Q. 
8 
A. Yeah. 
9 
Q. 
10 
A. Yeah. 
11 
Q. 
12 
A. 
13 
14 
15 
16 
17 
18 
I don't remember. 
A. No. Yeah it was. 
A. 
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20 
21 
22 
23 
24 
25 
A. 
032 
1 
2 
3 
4 
65 
• 
7 
A. 
8 
9 
Okay. 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
A. 
23 
Q 
24 
A. 
25 
Q 
0327 
1 
2 
3 
• 
4 
A. Yeah. 
5 
Q. Okay. 
6 
MR. MERMELSTEIN: Objection to form, 
7 
argumentative. 
8 
BY MR. LUTHER: 
9 
Q. 
10 
MR. MERMELSTEIN: Objection to form. 
11 
BY MR. LUTHER: 
12 
13 
14 
15 
16 
17 
18 
19 
20 
A. I don't remember. 
A. Yeah. 
MR. MERMELSTEIN: Objection to form. 
BY MR. LUTTIER: 
Q. Correct? 
A. Yeah. 
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MR. MERMELSTEIN: Objection to form. 
22 
BY MR. LUTTIER. 
23 
Q. 
24 
A. Yeah. 
25 
0328 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
BY MR. LUTTIER: 
11 
Q. Did you -- did he -- had you told him 
12 
prior to that or before that occasion that you had 
13 
been sexually active with men? 
14 
A. I told him, yeah. 
15 
Q. When did you first tell your dad you were 
16 
being sexually active with men? 
17 
A. Well, I think my dad kind of -- they -- I 
18 
think my dad asked me, and I told him the truth. 
19 
Q. This was when? 
20 
A. I don't remember. 
21 
Q. At 15, at 14, at 12? 
22 
A. I don't remember. 
23 
Q. When did you first become sexually active? 
24 
MR. MERMELSTEIN: Objection to the form. 
25 
It's been asked and answered so many times 
0329 
1 
already. 
2 
BY MR. LUTHER: 
3 
Q. Just an age is all I'm looking for. 
4 
A. I don't remember. I've already told you. 
5 
Q. How long were you sexually active before 
6 
you told your dad you were sexually active? 
7 
A. I don't remember because I don't remember 
8 
when my dad told me. 
9 
Q. You were telling your dad, remember? 
10 
A. Yeah, when I asked -- when I told my dad, 
11 
sorry. 
12 
Q. Did you -- you've had a couple of 
13 
boyfriends since then, right? 
14 
A. Yeah. 
15 
16 
17 
18 
19 
2 
20 
22 
A. Yes. 
A. Yeah. 
MR. MERMELSTEIN: Ob'ection to form. 
THE WITNESS: 
A. Yeah. Well, yeah. 
Q. Are you sure? 
A. Yeah. 
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23 
Q. Have you had oral sex with your current 
24 
boyfriend? 
25 
MR. MERMELSTEIN: Objection, Rule 412. Do 
0330 
1 
not answer that question. 
2 
BY MR. LUTHER: 
4 
3 
m ian
. 
5 
A. Yeah. 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
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17 
18 
19 
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21 
22 
23 
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25 
0331 
1 
Q. 
A. No. 
Q. 
A. Never asked. 
MR. MERMELSTEIN: Objection. 
THE WITNESS: No, I've never, like gone 
out with -- no, I mean --
BY MR. LUTHER: 
A. Yes. 
2 
MR. MERMELSTEIN: Just listen to the --
3 
THE WITNESS: Wait. 
4 
MR. MERMELSTEIN: Listen to the question 
5 
that he -- make sure you listen -- before you 
6 
answer, make sure you listen to the question 
7 
and answer it. 
8 
Can you read back --
9 
THE WITNESS: Sorry. 
10 
MR. MERMELSTEIN: -- the prior question? 
11 
(The requested portion of the record was 
12 
read by the reporter.) 
13 
MR. MERMELSTEIN: Well --
14 
THE WITNESS: What is --
15 
BY MR. LUTTIER: 
16 
Q. If you need to correct something, go 
17 
ahead. There's no tricks here. 
18 
A. Yeah, can you ask the question one more 
19 
time? 
20 
MR. MERMELSTEIN: Well go to the first 
21 
question there and answer. I just wanted to 
22 
make sure you think about it before you blurt 
23 
it out. 
24 
BY MR. LUTHER: 
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Q. Is the answer, correct? If you want to 
0332 
1 
change it, go ahead and change it if it's wron 
2 
Fm not t in to trick ou or an thin 
3 
4 
5 
6 
7 
A. 
8 
Q. 
9 
A. Yeah. 
10 
Q. Okay. Now --
11 
MR. MERMELSTEIN: That's why you have to 
12 
be careful when you're answering the question. 
13 
Make sure you understand the question, and, 
14 
and, and think about it before you answer it. 
15 
Okay? 
16 
THE WITNESS: Uh-huh. 
17 
BY MR. LUTHER: 
18 
Q. Now, your parents know about this lawsuit, 
19 
right? 
20 
A. Yeah. 
21 
Q. Did you tell your parents about the 
22 
lawsuit before you filed it? 
23 
A. Yes. 
24 
Q. Does your sister know about the lawsuit? 
25 
A. Yes. 
0333 
1 
Q. Did you tell her before you filed it? 
2 
A. No. 
3 
Q. And why did you tell your sister? 
4 
A. Why didn't I? 
5 
Q. Why did you? 
6 
A. Because it was something I didn't -- well, 
7 
something that I thought she should know. 
8 
. Now, you mentioned that in -
9 
there's a close group of all you girls that 
10 
were going to see Mr. Epstein; is that right? 
11 
MR. MERMELSTEIN: Objection to form. 
12 
BY MR. LUTHER: 
13 
Q. Correct? You said all of you were, that 
14 
you went to school together and you were all 
15 
friends? 
16 
A. I wasn't friends with everyone that went 
17 
there, no. 
18 
Q. Okay. But, but all the girls that went to 
19 
Epstein that you know, they all know you filed this 
20 
lawsuit, right? 
21 
A. I don't know. 
22 
Q. People down a' 
know you 
23 
filed the lawsuit, right? 
24 
A. No. 
25 
Q. Well, didn't they come to the 
0334 
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to interview you? 
2 
A. Yeah, they went -- well, then. yeah.. 
3 
knows. 
4 
5 
6 
7 
8 
9 
Q. So, so he knew because the cops came 
10 
and --
11 
A. I don't know. 
12 
Q. -- had to tell him why they were there to 
13 
see you, right? 
14 
A. I don't know what the cops told him, so I 
15 
don't know what information he knew. 
16 
Q. Well, you eventually told him what was 
17 
going on, didn't you? 
18 
A. No. 
19 
Q. You never told him? 
20 
A. No. 
21 
Q. You never told him you were in the 
22 
lawsuit? 
23 
A. Never. I don't -- no. 
24 
Q. Who else now have you told that you're in 
25 
the lawsuit? 
0335 
1 
A. My mom and my dad, my sister, my current 
2 
boyfriend. 
3 
Q. Current boyfriend is who? 
4 
A. 
5 
Q. Okay. 
6 
A. My ex-boyfriend 
and who else -- and 
7 
friends, Jane Doe No. 7, 
That's it. 
8 
Q. Who is your closet friend? 
9 
A. Jane Doe No. 7. 
10 
Q. Okay. So she knows? 
11 
A. Yeah. 
12 
Q. Who's your second-closest friend? 
13 
A. My boyfriend. 
14 
Q. He knows? 
15 
A. Yeah. 
16 
Q. Who's your third-closest friend? 
17 
A. I don't hang out -- I just have a click. 
18 
That's it. That's all. I already told you the 
19 
people that I --
20 
Q. Is there any -- doesn't everybody that's 
21 
close to you or you're close to know that you filed 
22 
the lawsuit? 
23 
MR. MERMELSTEIN: Objection to form. 
24 
THE WITNESS: I don't know. 
25 
0336 
1 
BY MR. LUTTIER: 
2 
Q. Well, who is it that you consider to be 
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3 
very close to you that doesn't know you filed the 
4 
lawsuit? 
5 
A. My --
6 
MR. MERMELSTEIN: Objection to form. Go 
7 
ahead. 
8 
THE WITNESS: My boyfriend and my family 
9 
and my best friend, which is Jane Doe No. 7. 
10 
BY MR. LUTTIER: 
11 
Q. I thought you said they all knew? 
12 
A. What do you mean? 
13 
Q. My question was who --
14 
MR. MERMELSTEIN: Be careful. 
15 
THE WITNESS: Sorry. 
16 
BY MR. LUTTIER: 
17 
Q. Who that you're close to does not know 
18 
that you filed this lawsuit, if anybody? 
19 
A. I don't know. 
20 
. I mean, the word spread out in 
21 
among the people that live there that these 
22 
lawsuits were filed and that you were involved, 
23 
correct? 
24 
A. Yeah. 
25 
MR. MERMELSTEIN: Objection to form. 
0337 
1 
BY MR. LUTHER: 
2 
Q. If you went back to your old neighborhood, 
3 
pretty much everybody knows that you are in this 
4 
lawsuit, correct? 
5 
A. Yeah. 
6 
Q. Pretty much everybody knows that these 
7 
other people, Jane Doe No. 7 and these other girls 
8 
are involved in this lawsuit, correct? 
9 
MR. MERMELSTEIN: Objection to form. 
10 
THE WITNESS: I don't, I don't know if 
11 
they know, but if you are the -- I don't know 
12 
if they know. I don't know who knows, but I'm 
13 
sure if you go back in 
, they know 
14 
who used to hang out. And what was it, 
15 
whenever the co made statements, it's like 
16 
well, hmm, like 
17 
who, who in 
that hun out that was 
18 
acquaintances with 
? Well, 
19 
it's kind of commonsense. 
20 
So I don't know who knows and who doesn't 
21 
know, but if I went back to my hometown, people 
22 
aren't idiots. 
23 
BY MR. LUTTIER: 
24 
Q. They would --
25 
A. They would put two and two, two and two 
0338 
1 
together. 
2 
Q. They know that you filed a lawsuit and 
3 
you're involved in this? 
4 
A. I don't know if they're --
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MR. MERMELSTEIN: Objection to form. 
6 
Calls for speculation. Go ahead. 
7 
THE WITNESS: I don't know. 
8 
BY MR. LUTTIER: 
9 
Q. So, who, who that you care about doesn't 
10 
know, if anybody, that you're in this lawsuit? 
11 
A. People that I care about know that I am. 
12 
Q. Okii.ow, you mentioned this current 
13 
boyfriend,.
14 
A. Yes. 
15 
Q. What's his last name? 
16 
17 
Q. 
And you are saying he's -- do 
18 
you know whether or not he's a drug dealer? 
19 
A. No. 
20 
Q. You don't know or you're saying he's not? 
21 
A. He's not. 
22 
Q. Okay. And you're sure of that? 
23 
A. Yeah. 
24 
Q. By the way, when's the last time you were 
25 
arrested? 
0339 
1 
A. Last weekend. Or, no, not last weekend. 
2 
I don't know, like two weeks ago, maybe. 
3 
Q. You were arrested two weeks ago? 
4 
A. Uh-huh. 
5 
Q. Who were you arrested by? 
6 
A. 
cops. 
7 
Q. What for? 
8 
A. Domestic violence. 
9 
Q. Well, if you were arrested, you must have 
10 
been the person that committed the act of domestic 
11 
violence. 
12 
MR. MERMELSTEIN: Well, you're assuming 
13 
she was guilty. 
14 
BY MR. LUTTIER: 
15 
Q. Someone thought you were --
16 
A. I can't --
17 
MR. MERMELSTEIN: It's a presumption of 
18 
innocence, right? 
19 
THE WITNESS: And I can't talk about it 
20 
either. All right? 
21 
BY MR. LUTTIER: 
22 
Q. Who told you you can't talk about it? 
23 
It's a matter of public record. 
24 
A. I don't know. I don't know. 
25 
Q. So, who told you couldn't talk about it? 
0340 
1 
A. Nobody did. I'm just assuming that 
2 
myself. 
3 
Q. So, you were arrested --
4 
MR. MERMELSTEIN: He can ask you questions 
5 
about it. 
6 
THE WITNESS: Oh. 
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BY MR. LUTTIER: 
8 
Q. Tell me, this event happened on what day 
9 
of the week? 
10 
A. On a Friday. 
11 
Q. Friday night? 
12 
A. Yeah. 
13 
And, and can we assume that because the 
14 
lice were summoned, it happened someplace 
15 
16 
A. Yeah. 
17 
Q. And what time did it happen? 
18 
A. Probably like around 1:00. 
19 
Q. A.m.? 
20 
A. Yeah. 
21 
Q. And where did it happen? 
22 
A. 
house. 
23 
Q. Which is where? 
24 
A. In 
25 
Q. Okay. I mean, do you have an address? 
0341 
1 
A. 
2 
• 
Do you know anything more than= 
3 
?tea big street. 
4 
A. 
5 
Q. 
Do you live with him? 
6 
A. No. 
7 
Q. Were you staying there? 
8 
A. Yes. 
9 
Q. Do you stay there with any degree of 
10 
regularity? 
11 
A. What do you mean, regularity? 
12 
Q. On any kind of regular basis, like, I go 
13 
up there for the weekends, or --
14 
A. Yeah. 
15 
Q. Is that where ou o on the weekends when 
16 
you're not down a 
9 
17 
A. Why would I be at 
18 
Q. Well, I don't know if you were still 
19 
there. Are you still a student there? 
20 
A. No, I graduated. 
21 
Q. 
kay. When did you graduate? 
22 
A. 
23 
Q. 
24 
A. 
25 
Q. 
What did you get a degree in? 
0342 
1 
A. 
2 
Q. 
3 
A. 
4 
Q.
5 
A. Yeah. 
6 
Q. And --
7 
MR. MERMELSTEIN: 
8 
BY MR. LUTTIER: 
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Q. Wait. Okay. 
10 
We'll settle for that. Bachelor's Degree in 
11 
right? 
12 
A. Uh-huh. 
13 
Q. How did you do? Did you do well? 
14 
A. Yeah. 
15 
Q. Do you know what your GPA was? 
16 
A. Like a 
17 
Q. And do you have plans to go further with 
18 
your education? 
19 
A. Yes. 
20 
Q. What are your plans? 
21 
A. To get my Master's. 
22 
Q. Master's? 
23 
A. Yes. 
24 
Q. Have you applied? 
25 
A. Yes. 
0343 
1 
Q. Where? 
2 
A. 
3 
Q. Been accepted? 
4 
A. Yes. 
5 
Q. When will you start? 
6 
A. I am not going to go to 
-- or I 
7 
was -- maybe spring. 
8 ..ring. 
By the way, you went to 
9 
undergrad on a scholarship? 
10 
A. Yeah. 
11 
Q. Who paid for this? Who sponsored you? 
I 2 
Who ave ou the scholarship? 
13 
A. 
14 
Q. Okay. Are you going to be scholarshipped 
15 
for your Master's? 
16 
A. No. I signed up for my graduate 
17 
assistance program. 
18 
Q. So, you plan to teach while you're taking 
19 
your Master's? 
20 
A. No it's where you work for 
21 
and they pay for your Master's. 
22 
Q. Okay. And do you have plans after you get 
23 
your Master's? 
24 
A. Yeah, to work. 
25 
Q. Okay. And you've got some plan --
0344 
1 
A. Yeah. 
2 
Q. -- kind of a general plan of what you want 
3 
to do in life? 
4 
A. Yeah, eah I want to be a 
5 
Q. Oka 
6 
A. 
7 
8 
Q. Okay. Let's go back to this domestic 
9 
violence thing. Had you and your boyfriend been 
10 
someplace on this Friday night when this happened? 
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A. At home. 
12 
Q. And were you anyplace earlier that night? 
13 
A. Yeah. 
14 
Q. Where were you? 
15 
A. 
16 
Q. Where? 
17 
A. 
18 
Q. 
is that the name of a bar or 
19 
something? 
20 
A. Yeah. 
21 
Q. Where? 
22 
A. 
23 
Q. Had you been an 
lace else? 
24 
A. Yeah we went to 
for dinner. 
25 
Q. 
where is that? 
0345 
1 
A. In 
2 
Q. Anyplace else? 
3 
A. No. 
4 
Q. Had you been out looking for anybody that 
5 
night? 
6 
A. No. 
7 
Q. Had you been down south to 
8 
that night? 
9 
A. No. 
10 
Q. Had you been down south to 
11 
at any time in the week prior to that? 
12 
A. No. 
13 
Q. Okay. So tell me what happened. What was 
14 
the -- what, what occurred at this incident that 
15 
occurs at 1:00 at= 
house? 
16 
A. It was just, it was over something silly. 
17 
I don't -- it was -- just got in an argument about 
18 
being out in the beginning of the night. 
19 
Q. What do you mean? 
20 
A. Nothing. It was just, like, like, real --
21 
being in a relationship you fight over stupid 
22 
things, and whenever he was -- I don't know, 
23 
whenever you have alcohol in your system, you know, 
24 
it brings up, like, silly little fights become big 
25 
dramatic. 
0346 
1 
Q. What was the fi ht about? 
2 
A. 
3 
4 
5 
6 
7 
8 
Q. So, did this argument turn physical? 
9 
A. Yeah. 
10 
Q. What ha ened? 
11 
A. 
12 
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13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0347 
1 
know. You said, I'm sorry, I just realized I 
2 
should ask you, somebody told you not to talk 
3 
about what happened? 
4 
THE WITNESS: Yeah. 
5 
MR. MERMELSTEIN: Was it a lawyer? 
6 
THE WITNESS: Yeah. 
7 
MR. MERMELSTEIN: All right. I -- I'm 
8 
going to plead the Fifth then. If she's 
9 
already gotten advice by a lawyer, I'm going to 
10 
plead the Fifth. 
11 
MR. LUTTIER: Well, she has to -- she's 
12 
going to --
13 
THE WITNESS: I'm going to have to plead 
14 
the Fifth. I have a lawyer and I'm not 
15 
supposed to talk about it. 
16 
BY MR. LUTTIER: 
17 
Q. Are you charged with criminal -- a crime? 
18 
A. Yeah, well, the State's picking up -- he's 
19 
not charging -- press, he's not press -- charging 
20 
these things, but I'm sure this automatically in 
21 
domestic violence in the State of Florida, they 
22 
automatically -- it doesn't get dropped, the State 
23 
automatically picks it up. 
24 
MR. MERMELSTEIN: Is it civil or is it 
25 
criminal? 
0348 
1 
THE WITNESS: Civil, I think. I don't 
2 
know. 
3 
MR. MERMELSTEIN: Well, I'm going to --
4 
I'm going to --
5 
BY MR. LUTTIER: 
6 
Q. The State attorney -- has the State 
7 
attorney advised you whether they're going to charge 
8 
you or not? 
9 
A. Not -- no, I think -- well, I don't know. 
10 
They said that he's not charging me. I have a 
11 
lawyer. Am I allowed to talk about it? I don't 
12 
know. 
13 
MR. MERMELSTEIN: Well, he's not -- if 
14 
your lawyer -- if you could talk about it, you 
MR. MERMELSTEIN: Before you go on, let me 
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