EFTA01107876.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs- JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092, DEPOSITION OF JANE DOE $17 - VOLUME III (videotaped) Monday, March 15, 2010 10:02 - 6:49 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RMR, CRR Notary Public, State of Florida (561) 832-75CC PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge 1201.272-617.4627) folb2074.4669-434d-ac93-054696fd7921 EFTA01107876 EFTA01107877  Page 299 Page APPEARANCES: 1 PROCEEDINGS On behalfof the Plaintiffs in related cases 2 Nos. 08-80069, 08-80119, 08-80232, 08-80380, 0840381, os-so993, 08-86994: 3 THE VIDEOGRAPHER: We are back on the record ADAM D. HOROWITZ, ESQUIRE 4 at 4:08 pm. MERMELSTEIN & HOROWITZ, PA. 5 BY MR. CRITTON: 18205 Biscayne Boulevard 6 Q. Jane Doe 7, in your supplemental answers to Suite 2218 6 Min4,040. 7 interrogatories, you listed the names and addresses and 8 phone numbers, number 18, and I don't know whether I 7 9 used that as an exhibit — this will be Exhibit 9. 8 On behalf of the Defendant Jeffrey Epstein: 10 (The document was matted Defendant's 9 ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITION, LUTHER & COLEMAN 11 Exhibit 9 for identification.) 10 303 Banyan Boulevard 12 BY MR. CRITTON: Suite 400 13 Q. There area couple of supplements you filed 11 West P 33401 Teleph 14 which as things come to you, I think, or your attorneys. 12 15 Anyhow, this one deals with males that you had sexual 13 16 activity. You listed Mr. Evans, Bryant — 14 Also Present: Socha Quimby, videographer 17 MR. HOROWITZ: You handed us two different 15 16 18 things. This is a request to produce. 17 19 MR. CRTITON: Oh, Tin sorry. 18 20 MR. HOROWITZ: No problem. 19 20 21 MR. CRT TON: Give this back. This will be 21 22 number nine. 22 23 (Discussion held off the record.) 23 24 BY MR. CRITTON: 24 25 25 Q. Is that the right one that has Mr. Evans? Page 300 Page 302 1 There is a person listed as Bryant. Who is he? - - - 2 A. He a friend from Orlando. 1kind of dated INDEX 3 him. 4 Q. And so of the five individuals you have here, WITNESS: DIRECT CROSS REDIRECT RECROSS 5 Mr. Evans, Bryant, Mackenzie Russell, PJ Tao and Blake 6 Russell, are the only individuals with whom you have had Jane Doe #7 7 any type of sexual activity since the time you were ten By Mr. Critton 5 8 years old? 9 A. Yeah, other than like kissing. I don't 10 remember everybody I kissed and stuff like that. 11 Q. All right. 1 want to go back to a couple of EXHIBITS 9 12 areas to make sure I got all the information on it. 10 EXHIBIT PAGE 13 At the time that you met with the officers 11 Defendant's 1 233 14 from Palm Beach, you said, do you remember one of them 12 Defendant's2 233 15 being a person named Recarey, R-e-c-a-r-e-y, 13 Defendant's 3 233 14 Defendant's 4 263 16 Officer Recarey7 15 Defendant's 5 268 17 A. Yes. 16 Defendant's 6 274 18 Q. I think you said there were two males. Do you 17 Defendant's 7 280 19 remember who the other male was? 18 DePeadant'S 8 294 19 Defendant's 9 301 20 A. I think his name was Joe something. 20 21 Q. Joe something, all right. And, Mr. Recarey's 21 22 first name, Detective Recarey's first name is Joe 22 23 Recarey. 23 24 24 A. Oh, sorry. 25 25 Q. Do you remember what the other person looked 2 (Pages 299 to 302) '(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617.4627) Electronically signed by Rachel Bridge (201-272-617.4627) le3b2074.4669-4a4doe93-8546961d7921 EFTA01107878  Page 303 Page 305 1 like? Not Mr. Recarey, but the other one. 1 car? 2 A. He was like just an older man. He was kind of 2 A. Yeah, I think so. 3 bigger, gray hair, I think. 3 Q. So they actually showed you, was it a color 4 Q. All right. And in terms of that individual, 4 picture or black and white picture? 5 did he say anything or was it Officer Recarey who 5 A. .Black and white. 6 conducted the interview with you? 6 Q. So they actually had a picture of what, the 7 A. I think it was Officer Recarey mostly. 7 rear ofyour car that had the license plate number? 8 Q. Did you eves have any subsequent contact with 8 A. I'm almost positive. 9 him? Did you ever talk to him after the interview on 9 Q. So when they showed you the picture of your 10 October 4th of2005? 10 car, and you had said that earlier in your testimony, 11 A. I don't think so. I don't remember. 11 you recognized right away as they knew that you had been 12 Q. When he talked to you, that is, when he 12 there? 13 introduced himself to you, did he explain to you how he 13 A. Yes. 14 found you, that is, how he knew that you may have had 14 Q. All right Did you ask him how old the 15 some involvement with Mr. Epstein? 15 picture was? 16 A. I think it was somebody told him. 16 A. No, I didn't. 17 Q. Did he tell you who the somebody was? 17 Q. And they just said that they had had him under 18 A. No. 18 some surveillance fora period of time? 19 Q. Did he tell you when you met with him, and 19 A. Yes. 20 again before he started the tape of the statement, did 20 Q. Did they show you more than one picture of 21 he tell you that, that he had interviewed a number of 21 your car so that, that suggested that they had taken a 22 other females? 22 picture ofyour car on a number of occasions? 23 A. I don't remember if he told me that or not. 23 A. No. 24 Q. Did he tell you, you know, tell us everything 24 Q. Did they tell you whether they knew any other 25 because we've heard stories from other people, so we 25 people who had been to his house? That is, did they use Page 304 Page 306 1 have an idea of what may have occurred at Mr. Epstein's 1 any names? 2 house? 2 A. I think they j ust said other girls in my high 3 A. Like front the very beginning ofme going? 3 school. 4 Q. No, no, no. When you first met with him after 4 Q. And the only name you gave them was Jane 5 you sent Mom back into the house, did Officer Recarey 5 Doe 4? 6 say to you "Hey, lane Doe 7, you can tell us what went 6 A. AndM 7 on because we've heard stories from other people, so 7 Q. IMI:tid you give t hem too? 8 tell us everything that happened"? 8 A. And S.V., yes. That is, did he try to make you comfortable so 9 Q. Did they show you any other photographs of 10 you would talk to him? 10 either his house, any other cars, any other vehicles, or 11 MIt HOROWITZ: Form 11 was it just yours? 12 THE WITNESS: I don't exactly remember what he 12 A. I think tlisiright have -- yeah, they showed 13 said, but basically he showed me the picture ofmy 13 me a picture of = and they asked ra tify the 14 car or my license plate or something. He said that 14 girl in the picture, and I identified her 15 they have been like watching Jeffrey and they know 15 Q. Did you ever Imw what last name was? 16 I've been there because they saw my car there. 16 A. It began with al, something. 17 BY MR. CRITTON: 17 Q. Did she ever introduce herself to you? 18 Q. Okay. Did they tell you how long they had 18 A. Yes. 19 been watching Jeffrey? 19 Asil=, or did she just say my name is 20 A. No, I don't think so. 20 21 Q. Did you get the impression that over the last 21 A. I don't remember. 22 few months they had been watching him? 22 Q. Was she nice to you? 23 A. Yes. 23 A. Yes. 24 Q. Okay. And so the picture they had, did they 24 Q. Friendly? 25 have an actual picture of your license plate on your 25 A. Yes. ata....Gittet•a•45,40 , 3 (Pages 303 to 306 (561) 832-7500 PROSE COURT. REPORTING. AGENCY; INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-6174627) Electronically signed by Rachel Bridge (201-272-617.4627) fe3b2074-4669-4a4d-ac93-054696fd7921 EFTA01107879  Page 307 Page 309 1 Q. How old did you thinavms? 1 he suggest things, like we know this, we know that? 2 A. She looked about in her nu twenties. 2 Like your car, we know you were there because here's a 3 Q. All right. And did you tell them that? Did 3 picture of your car and your license plate. Isn't that 4 they ask you about her at all? 4 your car and license plate? 5 A. Yes. I think they just asked if I recognized 5 MR. HOROWITZ: Form. 6 her and just asked what I saw her doing there and stuff 6 THE WITNESS: The only thing he suggested is 7 like that. 7 he just kind of knew I was there, so — 8 Q. And I think you said earlier that. called 8 BY MR. CRITTON: 9 you during the time, either just before or urmg the 9 Q. Did he ever tell you what some of the other 10 time you were being interviewed by the police? 10 females had said had occurred at Mr. Epstein's house? 11 A. Yes. 11 A. I don't remember exactly what he said to me. 12 Q. And did you take her call? 12 Q. Did they ever tell you that some of the other 13 A. No. 13 females were saying that Mr. Epstein did X or Y with 14 Q. Did you call her back? 14 them? X or Y could be anything, but did he say well, we 15 A. No. I just listened to her voicemail. 15 know Female ABC did such and such, or at least she says 16 Q. What did — did you play the voicemail for the 16 she did such and such with Mr. Epstein or he did such 17 police? 17 and such with her? 18 A. Yes. 18 Did he suggest that? 19 Q. Okay. And did they record it? 19 A. I don't remember. 20 A. I think so, yes. 20 Q. Did they ever say and I think they asked 21 Q. What did the voicemail say, to the best of 21 you, because I asked you earlier and you had told them 22 your knowledge or recollection? 22 that at least in the visit that you had under oath with 23 A. Just that "Hi, Jane Doe 7, this is M." I 23 them is that you had, he had not masturbated when you 24 think she just asked if there was cops at my house and 24 were there, correct? 25 if I was talking to them. And she said for me to call 25 MR. HOROWITZ: Form. Page 308 Page 310 1 her back. 1 BY MR. CRITTON: 2 Q. But you never did? 2 Q. mars what you told them that day? 3 A. No. They told me not to. 3 MR. HOROWITZ: Form. 4 Q. They being the police? 4 THE WITNESS: I believe so. 5 A. Yes. 5 BY MR. CRITION: 6 Q. Did they tell you anything else to do or not 6 Q. And did they say "Well, other females had said 7 to do? 7 that Mr. Epstein masturbated, did he do that when you 8 A. Just not really to talk about it with anybody. 8 were there?" 9 Q. Did they tell you not to tell your parents? 9 Did they suggest things like that in askinr 10 A. No, they never said that. 10 questions? 11 Q. Did they tell you that if somebody called you 11 A. !thinks*, yes. 12 on behalf of Mr. Epstein not to talk to them? 12 Q. Okay. And did he reassert to you, did he tell 13 A. Yes. :3 you at any time "You can tell us anything, you are not 14 Q. Did they mention at that time anything about going to get in any trouble"? 15 the US attorney or the FBI? 15 MR. HOROWITZ: Form. 16 A. No. 16 THE WITNESS: I don't remember if he said that 17 Q. Did anyone else, did either Officer Recarey or 17 or not. 18 anyone else from Palm Beach ever try to recontact you 18 BY MR. CRITTON: 19 for a followup interview or to clarify something? 19 Q. Well, did he ever say to you if in fact you 20 A. No. 20 received money for having taken people to Mr. Epstein's, 21 Q. And I think you told me earlier they never 21 you could be charged with a crime under Florida law? 22 sent you anything? 22 Did he tell you that? 23 A. No. 23 A. No. 24 Q. When Officer Recarey was talking to you, did 24 Q. Okay. Did he ever read you your Miranda 25 he — and i don't mean this in a negative way, but did 25 rights? 4 (Pages 307 to 310 (561) 832-7500 PROSE COURT REPORTING. AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201.2724174827) Electronically signod by Rachel Bridge (201.2724174627) fc3b2074.4669-4a4d-ac93-e54696td7921 EFTA01107880  Page 311 Page 313 1 A. No. 1 THE WITNESS: I think so. 2 Q. Were you concerned that you might be charged 2 BY MR. CRITTON: 3 with a crime? 3 Q. Did she have the statement that you had given 4 A. Yes. 4 to the Palm Beach police? Q. Because you thought you had committed a crime? 5 A. I think so, yes. MR. HOROWITZ: Form. 6 Q Did she ask you about the statement? That is, THE WITNESS: I just thought I was going to 7 did she quiz you from the statement? 8 get in trouble for going there. 8 Did it sound like she had a transcript of your 9 BY MR. CRITTON: 9 statement so she was asking you questions, did this 10 Q. Dkly also said that 10 happen, did that happen? 11 called you eras you described. 11 A. Yeah, she basically asked me if what I told 12 Did you know who she was before she called 12 the Palm Beach police was true. She said that she knew, 13 you? 13 you know, a lot of girls did a lot more things with 14 A. No. 14 them, what I have said, and she basically knew, you 15 Q. She just called you out of the blue one day? 15 know, I felt that she knew a lot more. 16 A. I think she called me and — actually, I think 16 So 1just told her the truth, that 1lied to 17 Agent Nezbit from the FBI might have told me something 17 them and that I finally, you know, broke down and told 18 that she, she was the attorney general maybe, I think 18 her everything that happened. 19 I don't 19 Q. And did she encourage you to do that? I mean 20 Q. Nezbit is the female FBI agent, correct? 20 did she tell you "A lot of other girls have come forward 21 A. Yes. 21 and said XY, that XYZ happened at Mr. Epstein's, so 22 Q. And then when she came to (bland° to meet with 22 please tell us everything"? 23 you and you met at Starbuck's, she had a male agent with 23 MB. HOROWITZ: Form. 24 her as well? 24 THE WITNESS: Well, she kind ofacted like she 25 A. Yes. 25 already knew and she knew a lot more went on than Page 312 Page 314 1 Q. And I think you said you spent an hour and a 1 what I told the officers in Palm Beach. 2 half, two hours with them? 2 BY MR. CR1TTON: 3 A. Yes. 3 Q. And whether she did or not, you don't blow, 4 Q. And you recall that they took a taped 4 that's how she played it, so to speak? 5 statement from you? 5 A. Yes. 6 A. Yes. 6 Q. All right. Did, after the hour or two that 7 Q. Much like FBI did — Pm sorry, much like the 7 you spent with Agent Nezbit, was she someone who — did 8 Palm Beach police did? 8 you get emotional with Agent Nezbit? 9 A. Yes. 9 A. Yeah, I mean I felt like i could like open up 10 Q. Did they talk to you fora period of time 10 to her more than I could guys, you know. 11 before they turned on their tape recorder? 11 Q. Did she give you a hug when you left? 12 A. I don't remember. 12 A. No. 13 Q. You just remember them taking a taped 13 Q. Shake hands? 14 statement? 14 A. Yes. 15 A. Yes. 15 Q. Was she warm, comforting? 16 Q. Okay. Did they also take notes? 16 A. Yeah, she was nice. 17 A. Yes. 17 Q. And did she give you her card and say "Jane 18 Q. And who was taking the notes, the male or the 18 Doe 7, If you ever have any issues associated with this, 19 FBI Agent Nezbit? 19 you can call me any time at this number"? 20 A. The male was. 20 A. Yes. 21. Q. And was the Agent Nezbit, was she, did she 21 Q. All right. And did you ever call her? 22. !mow that you had let me strike that. 22 A. Yes, I called her a couple of times. 23 Did she have the benefit of any information 23 Q. For what? 24 from Palm Beach? 24 A. Just called her to ask what was going on with 25 MR. HOROWITZ: Form. 25 the case and if she heard any news and things like that. 5 (Pages 311 to 314) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201.272.617-4627) Electronically signed by Rachel Bridge (201.272.617-4627) fo3b2074-4669-4a4thac93 05469610921 EFTA01107881  Page 315 Page 317 t 1 Q. Did you ever call her back to get the name of 1 A. Maybe a month maybe. 2 an attorney? 2 Q. Did they arrange that before they came back up 3 A. No. 3 or did they call you out of the blue? 4 Q. And I think you told me she said if you ever 4 A. Well, no, they arranged it to come back up. 5 need the name of an attorney, she could give you one, 5 Q. Why did they tell you they needed to see you 6 but you would have to call her? 6 again? 7 MR. HOROWITZ: Form. 7 A. They just wanted to make sure everything was THE WITNESS: I think Marie was the one that 8 correct and go over everything with me again. 9 said about the attorney stuff. 9 Q. Did they have like a statement that they were 10 BY MR. CRITTON: 10 now reading ftom? Q. Okay, when she called you, when she, meaning 11 Did they have an outline that they were 12 Marie,calkdyaa 12 reading from when they came to meet with you on the 13 A. (Witness nods head up and down.) 13 second occasion? 14 Q. Did Officer Nezbit ever call you independently 14 A. I don't remember. 15 of you calling her? 15 Q. How long did that meeting last? 16 A. About what? 16 A. I think about an hour. 17 Q. Whatever. 17 Q. And It was just the two of them? 18 A. No. 18 A. Yes. 19 Q. You said you called her on two occasions to 19 Q. Did they record you at that occasion again? 20 find out status. 20 A. I think so, yes. 21 A. Yeah. 21 Q. So on both occasions that the FBI met with 22 Q. Okay. And I think you told me you don't know 22 you, you recall them taking a recorded statement from 23 when you first talked to her. 23 you? 24 A. She called me again to ask me if there were 24 A. Yes. 25 any details that I left out or anything like that Just 25 Q. Or recording the session, correct? Page 316 Page 318 1 basically asked me if I remembered anything. She called 1 A. Yes. 2 me about that. 2 Q. And on the second occasion did you provide 3 Q. All right. And you told her what? 3 them any additional information? 4 Did you add any details? 4 A. I don't remember. 5 A. I don't remember. 5 Q. Did they provide you any additional 6 Q. That's when she called you? 6 information, such u we've talked to a number of other 7 A. Yes. 7 females and they have told us X, Y and Z, did this 8 Q. Okay. And then, and that's the only time she 8 happen? Did that happen? 9 ever called you after the first interview? 9 MR. HOROWITZ: Form. 10 A. Well, no, they came back up to Orlando. 10 THE WITNESS: I think they, yeah, they just, I 11 Q. A second time? 11 think they, yeah, said something like that, yeah. 12 A. Yes. 12 BY MR. CRITTON: 13 Q. Oh, I didn't know that. All right, they came 13 Q. So they gave you some more at least 14 back a second time. Meet at Starbucks again? 14 information. Again, you don't know whether it's true or 15 A. No, we met at the Radisson. 15 not, but they said "Well, we found out this or we found 16 Q. All right. Were they staying there? 16 out that. Did that happen to your 17 A. I think, yeah. Well, I don't know if they 17 Did they ask questions like that? 18 were staying there or not actually. 18 A. I believe so. 19 Q. Where did you meet, in the restaurant? 19 Q. All right. Did they, after that second 20 A. No, we met like in a conference center. 20 occasion, did they ever recontact you? 21 Q. Who was t ere other than you? 21 A. Agent Nezbit did, just, she would call me and 22 A. The same two people, just me and her and the 22 fill me in on what was going on. 23 same guy. 23 Q. How many more times did Agent Nezbit call? 24 Q. How much time transpired between the first 24 A. I think once or twice after that. She didn't 25 visit and the second visit? 25 call me a lot. 6 (Pages 315 to 318) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Sectronically signed by Rachel Bridge (201-272417-4627) Electronically signed by Rachel Bridge (201.272.817.4627) fo3b2074-4669-4a4d-ac93-05469431d7921 EFTA01107882  !age 319 Page 321 1 Q. Did she ever ask you what your feelings were 1 questions. 2 about any criminal prosecutions directed to Mr. Epstein? 2 Q. And you said a lawyer to protect yourself. 3 A. No. 3 Protect yourself from what? 4 Q. Pardon? 4 MR. HOROWITZ: Form. 5 A. No. 5 BY MR. CRHITON: 6 Q. Did you know who -- andIn asked you 6 Q. What did she tell you? 7 et me just clarify it. Before 7 A. I don't, I don't know what she was referring 8 called you, did know who she was? 8 to. 9 A. I want to say I don't remember. I think Agent 9 Q. Okay. Did she tell you you might have a civil 10 Nezbit might have said something about her to me. And 10 claim or you would have a civil claim against 11 then she just called and -- 11 Mr. Epstein? 12 Qi.th:iiitifishat she said, she, Nezbil 12 A. No. 13 said 13 Q. Did she tell you the deal that the government 14 A. No. It was towards the end of everything, and 14 had worked out or was attempting to work out would 15 I think she just updated me on everything that was going 15 • provide a civil remedy for individuals who had gone to 16 at. Might have told me like who she was. 16 Mr. Epstein, females who had gone to Mr. Epstein's 17 Q. And at the time, so if — and !know that, I 17 house? 18 think you said that at the time that you spoke with Jane 18 A. No. 19 Doe 4 in the summer of '08, you did not have an 19 Q. Do you ever remember receiving a letter from 20 attorney, a your recollection was you didn't think you 20 her that said you may have a civil remedy that you can 21 had an attorney at that time. You may have spoken with 21 pursue under a specific federal statute? 22 Mr. Herman tut you may not have had an attorney. 22 A. I think I received a letter, but I don't 23 Son= would have had to have spoken with 23 remember what it said. It might have said something 24 you sometime before Jane Doe 4 came to stay with you in 24 like that. 25 the suntmer of '08; is that your best recollection? 25 Q. Do you ever remember receiving a letter from Page 320 Page 322 A. Yes. 1 Robert Josefsberg from Podhurst Orseck saying he was the Q. Do you remember how many months before Jane 2 attorney representative who had been appointed to Doe 4 came there that you would have spoken wit 3 represent individuals who the government had deemed to 4 have been, quote, unquote, victims? A. Probably I think a while. Probably like, I 5 A. No, I never got a letter from Mm. don't know, six months. 6 Q. Did you ever hear from any other government 7 Q. All right. And you only spoke with her on 7 agent, government agent for the United States government 8 that one occasion? 8 who purported to work for thegovernment other than the 9 A. Yes. 9 two FBI agents an 10 Q. Did she ever tell you elf you ever have any 10 A. No, I don't think so. 11 questions, you can call me? 11 Q. Did you ever hear from anyone else associated 12 A. Yeah, she gave me a number to call. 12 with any other police department other than 13 Q. Did you ever follow up and try to call her for 13 Officer Recarey and whoever the other Palm Beach police 14 any reason? 14 officer was? 15 A. No. 15 A. No. 16 Q. When she filled you in on what was going on, 16 Q. Did your dad know any of the officers. having 17 what exactly did she say to you? 17 been associated with the Town ofPalm Beach or employed 18 A. She just told me about the criminal case. I 18 by the Town ofPalm Beach? 19 forget exactly what she said. 19 A. No. 20 And then she just explained all the like legal 20 Q. Did he ever see anyone in the Town ofPalm 21 terms and what was going on. She said, you know, "Other 21 Beach about this situation, to your knowledge? That is, 22 people am getting lawyers, if you want to protect 22 did he ever go talk to the mayor or the chief-of-police 23 yourself, you know, you could get a lawyer too" 23 about you and Mr. Epstein? 24 But she didn't give me any names or numbers, 24 A. No. 25 but she did give me a number to call if I had any more 25 Q. Other than the time that you told your mom and 14.....•••••44 7 (Pages 319 to 322) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272.617.4627) Electronically signed by Rachel Bridge (201-272-617.4627) fab20744604•44•03464N6fdril21 EFTA01107883  Page 323 Page 325 1 your dad, you disclosed to them, that is the day that 1 County to work? 2 Officer Recarey was there, October 4 of 2005, has your 2 A. No. They just said wherever I get a job at. 3 mom ever discussed it with you? Not necessarily the 3 Q. Okay. In terms of your parents, are you 4 details, but how she feels about it. 4 closer, like if you had a personal problem or an issue, S A. I mean she's read the newspapers and obviously 5 would you more likely call your mom or your dad? 6 she doesn't like him, but I mine she actually didn't 6 A. I mean either one really. I'm not more close 7 want me to go ahead with the lawsuit. 7 to either of them. 8 Q. She didn't? Q. Both would be supportive of you, both A. No. 9 emotionally and as well financially if they thought that 10 Q. Why not? 10 it was necessaty? 11 MR. HOROWITZ Form. 11 MR. HOROWITZ Form. 12 BY MR. CRITTON: 12 THE WITNESS: Yes. 13 Q. What did she tell you? 13 BY MR. CRITTON: 14 A. She thought it would bring more stress and 14 Q. And that's always been true with you and your 15 anxiety on me. 15 family and your mom and your dad? 16 Q. Has it? 16 A. Yes. 17 A. I mean, of course, hearing everything, hearing 17 Q. Okay. If you had a friend or friends that you 18 his name brings anxiety and I get depressed and sad over 18 were going to tum to now that you needed help or 19 it, yeah. 19 assistance in some fashion, you didn't want to tell your 20 Q. Over the lawsuit? 20 mom or your dad, would Jane Doe 4 be one of the people 21 MR. HOROWITZ: Form. 21 you would go to? 22 THE WITNESS: Not just over the lawsuit, but 22 A. Yes, 23 hearing his name, it brings back memories. 23 Q. Who else? Who else would you consider would 24 BY MR. CRITTON: 24 be a good friend that you would go to? 25 Q. How about your dad, how did he feel about the 25 . A. Jane Doe 4 or Jane Doe 3 really. Page 324 Page 326 1 lawsuit? Did he ever express any opinion? 1 Q. I'm sorry? 2 A. My dad just basically said it was up to me to 2 A. Jane Doe 4 or Jane Doe 3. 3 do what I wanted to do. 3 Q. Jane Doe 3? 4 Q. Has your room ever said to you that she's angry 4 A. Yes. 5 with you for ever having gone there? 5 Q. Looking briefly at your work history, looks 6 A. I mean no. She was upset about it, and at 6 lila, you worked irt,IFIr t m i.ottra to Orlando you 7 first she like asked me how I could have been so stupid 7 worked at 8 and why I would have went there. But I mean she 8 A. Yes. 9 understands that I was young and confiised at the time, 9 Q. And you were a cart girl? 10 so-- 10 A. Yes. 11 Q. Did your dad ever ask you? 11 Q. All right. So you drove around on the golf 12 A. No. My dad didn't really talk about it. 12 course? 13 Q. Are you closer to your mom or your dad? You 13 A. Yes. 14 love them both, right? 14 Q. For refreshments and food for guys? Guys and 15 A. Yeah. 15 gals, whoever was playing golf? 16 Q. And they both love you? 16 A. Yes. 17 A. (Witness nods head up and down.) 17 Q. Allright. And then you worked — and that 18 Q. Supportive of you? 18 was in '07, and is the only job that you have had since 19 A. Yes. 19 then, although I think you said you are working 20 Q. And they are supportive of you getting a 20 someplace now. I'll get 21 career, certainly a job? 21 Then you worked a b ll. in 2008, the whole 22 A. Yes. 22 year? 23 Q. Every parent wants their child to get a job, 23 A. Yeah, about a year. I don't know actually 24 that's good. 24 have that. 25 Do they want you to come back to Palm Beach 25 Q. So you went £roil 110•••••050i..../ 8 (Pages 323 to 326) (561) 832-7500 • PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Rachel Bridge (201-272-617-4627) Electronically signed by Rachel Bridge (201-272-617-4627) fe3b2074-4669.4e4d-ac93-o54696fd7921 EFTA01107884  Page 327 Page 329 1 2 MR. HOROWITZ: Do you want to show her that? MR. CRITTON: That was in Exhibit 2. She 1 2 Q. A. They are liquor too. does what? I 3 should have it right in front of her. 3 Q. But they are two different entities? 4 MR. HOROWITZ: That was like eight exhibits 4 A. Yes. One is just like a modeling agency. 5 aga 5 Well, its just like an agency where they have girls 6 MR. CRITTON: I can help you. Maybe you need 6 that they hire to like the liquor company, and that's 7 an assistant to help you sort through the exhibits. 7 out of Tampa, but they have jobs in jobs in Orlando that 8 BY MR. CRITTON: 8 I do. I have driven to Tampa before. 9 say you worked 9 Q So you will go to Tampa to do this work too? 10 at 10 A. Yes, sometimes. 11 A. Yes. 11 Q. How much do you get paid for doing that? 12 Q. In 2007. That was the only job you had in 12 A. $25 an hour. 13 2007, correct? 13 Q. 25 bucks an hour? 14 A. Yes. 14 A. Uh huh. 15 Q. Okay. And then 2008 was part of 15 Q. All you have to do is go to a bar, look 16 your — I think you told us earlier it w toyour pan 16 pretty, have a cute outfit on, and hand out liquor? 17 work experience through school? 17 MR. HOROWITZ: Form. 18 A. Yes. 18 THE WITNESS: Yes. 19 Q. Okay. And you worked them for all of 2008? 19 BY MR. CRITTON: 20 A. Yes 20 Q. 'filets basic