EFTA00723885.pdf

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.502008CA028051XXXXMB AB L.M., Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. HEARING BEFORE THE HONORABLE DONALD HAFELE Thursday, February 4, 2010 Palm Beach County Courthouse West Palm Beach, Florida 33401 9:05 a.m. - 9:30 a.m. Reported By: Denise Sankary, RMR, CRR Notary Public, State of Florida Prose Court Reporting Agency, Inc. Job #1303 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sankasy (201431445.2309) 61c120365-86ao-dfol-Ixt88-25626c08ac76 EFTA00723885 EFTA00723886  Page 2 Page 4 1 APPEARANCES: 1 prior sexual history, to which both plaintiffs' 2 On behalf of the Plaintiff: 2 counsel, which the Court had ruled on, and 3 3 4 BRADLEY J. EDWARDS, ESQUIRE plaintiffs' counsel said, these are the areas FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & 4 that we're going to allow her to testify on. 5 LEHRMAN, PL 5 There's one specific area post seeing 425 N. Andrews Avenue, Suite 2 6 Mr. Epstein that was on appeal to the Fourth 6 Fort Lauderdale, Florida 33301 7 DCA at the time, but at her deposition on 7 8 8 September 24 they took a very broad view. We On behalf of the Defendant: filed a motion to compel and sanctions. 9 10 At that time we also asked for any ROBERT D. CRITTON, JR, ESQUIRE 11 journals, because she had testified on 10 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 12 deposition that she worked as a prostitute, as 303 Banyan Boulevard, Suite 400 11 West Palm Beach, Florida 33401 13 a call girl, as an escort during '06, '07, '08. 12 14 She testified, and Tye attached portions of 13 15 pages of her deposition to this motion, where 14 16 she says, I kept books. 1kept them for '06, 15 17 '07, and '08. Certainly '06 and '07 and '08. 16 17 18 She testified on pages 58 through 61 through 18 19 65, Mr. Luther, who was taking her deposition, 19 20 said you know, What do you have? She said. I 20 21 have books from '07. I've got them front '08. 21 22 One of the books has a psalm on the front of 22 23 23 the book, a passage from the Bible. 24 24 It reflects that — and he asked her on 25 25 page 63, "How many of these books are there?" Page 3 Page 5 1 PROCEEDINGS 1 She says, 'Two or three." "Where are they 2 2 currently located? "Objection to form." This 3 MR. CRITTON: Good moming, Judge. 3 is Mr. Edwards. "Don't answer. I'm invoking WE COURT: How are you? 4 her Fifth Amendment right to the location." 5 MR CRITTON: May it please the Court 5 Mr. Luttier, "How is the location going to THE COURT: Go right ahead. 6 violate the Fifth Amendment?" And he didn't — 7 MR. CRITTON: Your Honor, as you know,1 7 he, Mr. Edwards, directed his client and his 8 represent Mr. Epstein. This is an amended 8 client took the Fifth with regards to these 9 motion to compel documents responsive to a 9 books. 10 request to produce which was served on 10 But clearly she said she had them. She 11 October 21. I think this is Take 3 that we've 11 also said that she had, in another portion, she 12 been here, so I know the Court has probably 12 had videos, adult videos. This is a lady who 13 looked at the documents at least once. So I'll 13 is asking for between a million to 5 million to 14 put it in perspective. 14 $50 million. She's claiming loss of earnings 15 L.M. was deposed on September 24. 15 in the past, loss of earnings capacity in the 16 Previously we had sent some written discovery 16 future. She is, as the Court is aware, 17 to her, which included requesting information 17 claiming all sorts of emotional damage and 18 regarding income and as well information 18 mental damage. Therefore, what occurred, what 19 regarding any diary or journals that she had. 19 purportedly occurred with Mr. Epstein, and Ill 20 We came in front of the Court after her 20 represent to the Court is that she testified 21 . deposition and there were two motions. One was 21 she never had intercourse with him, never had 22 a motion for sanctions saying that the 22 anal sex with him, never had oral sex with him. 23 plaintiff and her attorney took — asserted 23 I never touched any of his private parts. So 24 privileges, privacy rights, et cetera, with 24 what are you doing with these other people? 25 regard to specificall issues_relatit! to her 25 And does that cause ou any emotional scars or • 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. Esc rim ca y sgne ry or ankary (2014314464309) eftet1365-136ao-Mol -be88-25626c0Bac76 EFTA00723887  Page 6 Page 8 1 any emotional issues? So it's clearly relevant 1 Clearly privacy rights trump. She is the one 2 material. 2 who wants money in this case. 3 The Court, with regard to the motion to 3 Three, she again asserts a privacy right. 4 compel, said, look — you ordered that she 4 And interestingly, on 1, with regard to the 5 appear. You didn't grant sanctions. There was 5 book, your earnings as a prostitute or a call 6 another hearing the next day where the Court 6 girl, both I and 2 they refer to, and all ofa 7 had a hearing with regard to limiting her 7 sudden she says none, and this is after her 8 deposition that her counsel had filed on her 8 deposition that occurred on September 24. On 9 behalf saying no more time. The Court said, 9 the motion to compel, the Court said, you got 10 look, I read the deposition. It appears that 10 to produce that stuff. 11 you got about two hours of it or an hour out of 11 Just to be very specific about it, I sent 12 it, Pm going to give you, Mr. Luttier, or 12 a second request to produce. All ofa sudden 13 defense counsel another six hours to do her 13 the books she had for '06, '07, '08 are now 14 deposition. 14 "none." She doesn't have any books. And I 15 And Mr. Edwards, you need to get a copy of 15 couldn't have been more specific, because as 16 this transcript, print it up;so that you can 16 the Court recognizes, i referenced those 17 show it to your client so that she knows how 17 portions in the transcript where she said, I've 18 the deposition is to be conducted. 18 got a book, where I have books. 19 This is the lady who at her deposition 19 On 5 she says, i have none in my 20 Mr. Luther said, "How did you get to this 20 possession. Well, what's that mean? Does that 21 psychologist Amy Swan?" And she wouldn't 21 mean you dumped them to one of your friends? 22 answer. He said, "Well, did your lawyer send 22 You gave it to an investigator? You gave it to 23 you?" And she said, "You're a jackass. You're 23 someone else? You hid it in a safety deposit 24 an F-ing A blank." That was her response. So 24 box? All of a sudden it's not in your 25 this is a lady who clearly understands her 25 possession. Page 7 Page 9 responsibilities under the law. 1 On 5 I asked for her information with 2 When we sent interrogatories - Pm sorry, 2 regard to her -- basically her johns. 3 the second request to produce originally, there 3 On 7, which relates, and 8 and 9, which 4 was no timely response, and I took into account 4 relate to the adult entertainment videos, which the stay that the Court had entered when 5 she also testified, she says, 'I don't have 6 Mr. Edwards' firm, the Rothstein, Rosenfeldt & 6 them in my possession." And same with 11, you 7 Adler firm, went into or imploded, so the Court 7 know, documents that relate to your employment 3 gave them some time, but they still didn't a as she described a Bunny Ranch. Page 46 ofher 9 timely file. They did ultimately file a 9 deposition, she says, none in her possession. 10 response, and therefore, I filed an amended 10 What does that mean? 11 motion. 11 So what Pm asking for the Court, and I 12 And I'm interested really in 1, 2,4, and 12 recognize that — well, i don't recognize I 13 5. And these are the books, the journals that 13 won't editorialize too much. But what I will 14 were specifically identified at her deposition. 14 say is that clearly the plaintiff had these 15 And she was claiming, ml made between $200 and 15 books. She had records. Clearly she's gotten 16 $2,000 a night' So clearly if she has a lost 16 rid of them because she said she doesn't have 17 wage or loss of ftiture earning capacity claim, 17 them, and certain things are not in her 18 what occurred with these people, vis-a-vis 18 possession. I would ask that the Court 19 Mr. Epstein and where did any real emotional 19 overrule all the objections. Again, no Fifth 20 damage, if any, occur? 20 Amendment. There's no attorney/client There 21 She testified -- they objected based upon 21 are no privilege objections that may withstand 22 that it's not relevant or material. i don't 22 a late filing or even late objections that are 23 think I even need to argue that to the Court on 23 asserted. None of those are asserted. 24 1 and 2. 24 And secondly, that she give an affidavit 25 n On 2 they ratalth ....erty!teiright. 25 ....„_s2t ! prior to her deposition I r....2 elficall 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sankary (201-131.345.2309) Od2•365-86ae-41e1-be88-26626c08ac76 EFTA00723888  Page 10 Page 12 1 which is scheduled on February 9, I believe, is 1 That's it, period. 2 that she say what happened to these books or 2 THE COURT: The relevance, just to 3 write an affidavit to the Court as to where the 3 remember, and this was the basis of my earlier 4 information is that existed on the date of her 4 decision in dealing with the other issues, and 5 deposition now no longer exists. And with 5 that is, that we have someone who is claiming 6 regard to 'none in my possession," what's that 6 significant psychological trauma as a result of 7 mean? Who's got it? 7 her interactions with the defendant and the 8 THE COURT: All right, thank you. My 8 type of trauma that she is alleging that this 9 understanding at this point is that any 9 or that these problems stem from is sexual in 10 certiorari review by the Fourth District Court 10 nature. So there is some type of connection. 11 of Appeals has come back, and on the discovery 11. Also of import is the allegation that the 12 issue in particular was denied on the merits, 12 defendant paid her and others for whatever 13 correct? 13 intimate involvement is being alleged occurred. 14 MR. EDWARDS: On the issue of sexual 14 Sol think from a global perspective, that's 15 partners and sexual acts and things of that 15 really more of what's of interest to the Court 16 nature, that my client will be answering 16 when it comes to relevance than what the amount 17 questions to on the 9th, yes. 17 of the monetary claim is. That's not of 18 THE COURT: Okay. I just wanted to make 18 importance to me. 19 sure. 19 MR. EDWARDS: Understood. Addressing 20 MR. EDWARDS: Yes, and that was the 20 specifically this particular motion, any videos 21 substance of that prior motion to compel, and 21 that were ever in her possession depicting 22 we intend to comply fully with that. 22 sexual acts, we indicated that we would give 23 THE COURT: I'm not suggesting you aren't. 23 them. My client does not have them in her 24 I just wanted to make sure — 24 possession. If you read her deposition, at 25 MR. EDWARDS: This is a different issue. 25 some point in time she testified that — or she Page 11 Page 13 1 THE COURT: — just for my administrative 1 did engage in a sox act that was on video. She 2 understanding. 2 no longer has that video. She doesn't know 3 Mk EDWARDS: That's correct. 3 where that video is. She didn't state in her 4 THE COURT: We just get one single page 4 deposition she knew where the video was. 5 that says denied on the merits. We don't get 5 THE COURT: Well, again, Mr. Critton's 6 much of an explanation. 6 only concern is that by saying not in someone's 7 MR. EDWARDS: Right 7 possession, that there's at least potentially a 8 THE COURT: So I just wanted to make sure suggestion that it may be in someone else's 9 that that was one of the things that was 9 possession of whom she knows. 10 affirmed on the merits. Go ahead, Mr. Edwards. 10 MR. EDWARDS: And 1 expect him to ask her 11 MR EDWARDS: Many things were argued just 11 where it went and trace it to wherever it went, 12 now that don't necessarily pertain to this 12 you know. It's just not in her possession, but 13 particular hearing. And every single hearing 13 obviously it existed at one point in time. 14 that we have we listen to Mr. Critton say, 14 She's going to testify to that. 15 she's asking for SI 0 million, S50 million. 15 THE COURT: If you're representing that 16 That's never happened. The only evidence of 16 she will testify and/or you can amend the 17 any — 17 interrogatory answer to indicate that not only 18 THE COURT: I just considered that 18 is it not in her possession, but she does not 19 rhetoric. I don't find it to be necessarily 19 know the whereabouts of same, I think that 20 persuasive. 20 would be more conclusive. 21 MR. EDWARDS: That's always the crux of 21 MR. EDWARDS: Okay. 22 the argument as to why this stuff should be 22 THE COURT: And the better answer. 23 available, and that's not really true. The 23 Let's talk about them in order, since I'm 24 only thing that's ever been alleged is it's 24 better doing it that way than I am just picking 25 over 515,000 for jurisdictional purposes. 25 them out randomly. One says, "All documents 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sanitary (201-131.345.2309) 6fd2e365- se el-be88 5 c ac EFTA00723889  Page 14 Page 16 which relate to your earnings as a prostitute 1 lawsuit, and therefore, we have very little, if 2 or call girl." It says, "Without waiving said 2 any, communication can take place between our 3 objection, none." If I'm not mistaken, I think 3 offices. And we end up in front of your Honor 4 one of the District Court of Appeals said that 4 on these issues when I think this probably 5 such an answer basically does waive the could have been eliminated if we could have 6 objection. So the answer is none. There's not just talked about the fact there's no earning 7 much I can do about that. It says none, it capacity claim. I just wanted your Honor to 8 says none. understand that we're not here to waste your 9 MR. EDWARDS: And your Honor, the only — 9 time, but we do have a communication problem 10 THE COURT: So that's going to be 10 for that reason. 11 construed as the answer. 11 ME COURT: I appreciate that. Okay, 12 The next one is the book containing the 12 well, getting back to the issue at hand, does 13 reference to a Bible verse. It says, "See 13 she have this book or doesn't she? 14 response to request to produce Number I ." I 14 MR. EDWARDS: She had it, and she has not 15 presume that when it gets to the bare bones, 15 been able to locate it, but I'm not going to 16 it's none; is that correct, or does that not 16 say she doesn't — at the time she had her 17 apply? 17 deposition taken, she thought she still had it, 18 MR. EDWARDS: She did testify in her 18 although she hadn't touched it in quite some 19 deposition about having a book, and I believe 19 time. She has moved. She's moved. So I don't 20 that it contained records regarding such 20 know if she's going to be able to locate it or 21 earnings. I did stop her from testifying to 21 not. Ifs going to be our position if she does 22 that after we conferenced about her possibly 22 locate it, that it would -- that she can invoke 23 providing information that would provide a link 23 her Fifth Amendment right as to the production 24 in the chain to a possible prosecution ofher, 24 of that document, and it should not be 25 and that it was possibly going to require her 25 discoverable for that reason. At this time, Page 15 Page 1 to admit to criminal actions, and there would 1 she doesn't have it in her possession. 2 be a Fifth Amendment invocation there. I 2 THE COURT: All right Well, let's talk 3 overlooked that apparently in my response, but 3 about the Fifth Amendment issue. 4 obviously that was the objection at that time. 4 Mr. Critton, what's your position in that 5 And just so that the Court is clear, and I 5 regard? 6 know that the relevancy that Mr. Critton cited 6 MR. aurrow: rve heard two things that 7 was the lost wage and loss earning capacity 7 are not set forth in response to the second 8 claim. The loss earning capacity claim, lost a request to produce. 9 wage claim in LIvfs case has been withdrawn. 9 THE COURT: I understand. 10 I'll say it on the record it's been withdrawn. 10 MR. CMITON: I heard too that was never 11. Ifs no longer an issue in this case. So all 11 argued with the hewing on motion to compel 12 of these requests about earning potential and 12 when you said produce your diaries and books, 13 earnings from the practice of prostitution is 13 et cetera So the withdrawal of the loss 14 not relevant right now, especially at this 14 earning claims and wages, I may have missed 15 stage because that's not an issue. And that 15 that. 16 was done strategically obviously related to the 16 I'm happy to communicate with Mr. Edwards 17 Fifth Amendment invocation not wanting to go 17 as we have no trouble in tenns of letters. So 18 down that road. 18 that's not a problem. 19 And I can tell you, your Honor, that these 19 That claim, has it been withdrawn as of 20 hearings would happen a lot less frequently 20 today, or have I missed something along the 21 except for the great working relationship that 21 way? 22 Mr. Critton and myselfhad at one point in time 22 MR. EDWARDS: It's been withdrawn before 23 has all but dissipated when a lawsuit was filed 23 today. 24 by Mr. Epstein against me personally. 24 MR. CRITTON: Unknown to me and it was not 25 aa Critton has signed his name to. that 25 . 2omething that was argued. 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sankary (201-131445-2309) 8fd2s386.86aa4M-bs88.25628c08ae76 EFTA00723890  Page 18 Page 20 3. THE COURT: Well, it's now on the record. 1 than to do it at an 8:45 hearing where either I So let's move on relative to that. 2 or Mr. Edwards or even the Court might act, 1 3 So taking that into consideration, there's 3 don't want to say precipitously, but without 4 still the emotional trauma issue, and there's 4 full knowledge and the ability to look at it, 1 5 still the relationship between whatever this 5 would like to see how I want to posture that. 6 woman did relative to her activities of a 6 THE COURT: I agree, and I think that's 7 sexual nature and in relationship to those 7 the best way to handle it, and I appreciate 8 allegations that she made, that she's made 8 that deference. 9 concerning Mr. Epstein of a sexual nature. So 9 With regard to any — the same thing with 10 I think there's still that ability to juxtapose 10 regard to the, not having to do with the Fifth 11 the activities that transpired prior, during 11. Amendment issues, I don't think, but relative 12 and to some degree after Mr. Epstein's 12 to the DVDs or anything ofa sexual nature, 13 engagement with this woman, if any, that may 13 that she allegedly was involved in when she was 14 pertain to the emotional trauma that she is 14 19, those would have to be more fully answered. 15 alleging resulting from the allegations of a 15 If they're not in her possession, that's one 16 sexual nature against Epstein. 16 thing. If she knows where they are, that's 17 So how do we deal with that in conjunction 17 another. If she says, as Mr. Edwards is 18 with and in recognition of LM's potential Fifth 18 proffering today, that she does not know the 19 Amendment rights? That's going to be the issue 19 whereabouts of them, or ofit, I don't want to 20 I think as far as these matters are concerned. 20 suggest that there's more than one if that's 21 I think that by admitting to what she did 21 the case, then that should be the way it's 22 in her deposition, there is at least some 22 responded to. Again, perhaps it's better done 23 argument of waiver. I'm not going to suggest 23 in five days when the deposition is being taken 24 that she — when I say "waiver," I'm talking 24 to obviate the need for any further response on 25 about waiver of the privilege to a certain 25 those particular questions, but you're Page 19 Page 21 1 degree, not the waiver of the objection. I'm 1 suggesting, I think, Mr. Critton, that you want 2 going to respect the fact that you objected on 2 these responses before the 9th. 3 the record to the questions on the Fifth 3 MR. CRITTON: Yes. And part ofit is, I 4 Amendment grounds. That's been acknowledged by 4 want on the record of what they didn't respond 5 Mr. Critton. And so even though it's not 5 to than what they did respond to what we now 6 specifically stated here in the response to the 6 heard on the record, and now the newest 7 defendant's second request for production, I'm 7 response, which is going to be the response to 8 not going to suggest that she waived her right 8 the amended response. And therefore, as the 9 to a Fifth Amendment privilege. I am, though, 9 Court suggests, if you don't have it, tell us 10 concerned about whether or not she has waived, 10 you don't have it. You don't know where its 11 to a degree, her Fifth Amendment privilege by 11 whereabout is, fine. If you know where it is, 12 virtue of a response to the questions at the 12 tell us. And you want to assert the Fifth 13 deposition. Do you understand the distinction? 13 Amendment, then at least I can address it 14 MR. EDWARDS: I understand, your Honor. 14 properly. 15 MR. CRITTON: Here's what I would like to 15 THE COURT: The only other thing I want in 16 do, your Honor, because — I would ask that -- 16 address, and these gentlemen and ladies have 17 she's set for deposition on February 9. I 17 been very patient, is what the medication or 18 would ask that Mr. Edwards, on her behalf, be 18 medications have to do with the matter. I 19 required to file an amended response to our 19 don't recall if I did. I just don't recall 20 second request for production. So if he wants 20 reading anything in the deposition about 21 to assert the Fifth so it's there, so that I 21 medications, but I may have missed it. 22 have a record ofit, and then I want to be able 22 MR. CRITTON: It probably wasn't in at 23 to respond to it based on how she's responded 23 least the portion that was given to you, but 24 previously in her deposition and how she 24 there's been substantial testimony regarding 25 responds at this particular time. And rather 25 different types of drugs, both prescription and %A& 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Seamy (201.1314454309) EFTA00723891  Page 22 Page 24 1 nonprescription that they took. So if they 1 of admissible evidence. The admissible 2 took Xanax or other type drugs, which seems to 2 evidence, in my view, is not so much whether or 3 be typical among a number of the individuals 3 not this person is on any form of medication. 4 who are plaintiffs in this case, or other 4 The importance is, one, whether she's on that 5 prescription medication, what did you take? 5 medication at the time of the deposition, and 6 Did you have a prescription for it? If you 6 two, whether or not there's any allegation that 7 have it, give it to us. If you don't have it the reason that she's on the medication has 8 in your possession, tell us that you don't. have 8 anything to do with the claims against the 9 it. But if you're taking medication, tell 9 defendant 10 about it, in particular, as it may affect 10 MR. CRITTON: May I say just one thing, 11 either their testimony or what they did or what 11 your Honor? 12 their, what their issues are associated with 12 THE COURT: Briefly, please. 13 the emotional and mental and psychological 13 Mr. Glatthom is looking at the ceiling in 14 damages. Medications have a significant 14 obvious impatience. I say that jokingly. 15 impact. And not only the plaintiffs' experts, 15 MR. CRITTON: If the plaintiff was taking 16 not in this case because we haven't seen their 16 medications, say, for an STD, how did you get 17 report, but every physician that's examined 17 it? What. were the circumstances? How does 18 them are always very interested in having their 18 that affect your emotional state? Let's say, 19 medication past history as it affects their 19 as a result of her having been a prostitute, by 20 mental state. 20 her own testimony, for a long period of time, 21 THE COURT: Mr. Edwards. 21 she's HIV positive. It affects her lifespan. 22 MR. EDWARDS: He's asking for the 22 It affects damages into the figure, and it 23 medication that she's taking now or that she 23 certainly would affect her emotional state, if 24 has in her possession now when we were talking 24 she's on kidney dialysis or kidney medication 25 about something that happened when she was 13, 25 or other significant medication that may be Page 23 Page 2 5 1 14, 15, 16 years old. There can be no 1 life-threatening or life-altering in some 2 relevance to any medication that's she 2 fashion. She has a young child. That 3 prescribed now, unless we were claiming that 3 certainly would have an impact upon her 4 the medications she's prescribed now is 4 emotional state, and therefore, it's relevant. 5 something that is as a direct result of 5 THE COURT: Well, again, 1 don't have a 6 anything that happened with Mr. Epstein. 6 problem with asking specific questions, but the 7 THE COURT: Well, that's basically the 7 question that's indicated here I think is 8 question I think is best phrased, and that is, 8 properly objectionable. The question reads, 9 are you claiming that any of the medications 9 quote, "All prescription bottles, receipts or 10 that you are presently taking are related in 10 documents reflecting medication you were 11 any way to your contact with Jeffrey Epstein? 11 prescribed." I have no idea what that means. 12 I think That the defendant is able to ask 12 I don't know what the time frame is, and it's 13 genetically at the deposition whether you are 13 not as pointed as you have brought out. I 14 on any drugs or alcohol or anything of that 14 don't have a problem with you asking those 15 nature, any mind-altering substance at the time 15 pointed questions at deposition, because they 16 of the deposition to see if that person is in 16 do have some relevance, and we do have to 17 fact lucid and not under the influence. 17 remember that this woman, as well as others, 18 1 don't have a problem with that question 18 are the plaintiffs in a lawsuit. So they have 19 being asked at any deposition, frankly, because 19 brought their case before the Court and do have 20 it's not unusual that someone is on some type 20 to reveal some things that may otherwise be 21 of medication, and I think that's fair game as 21 personal by virtue of their position in the 22 a litigant in a case. 22 lawsuit 23 But again, I don't want to get into a 23 That does not have endless bounds. I 24 lengthy diatribe here on issues that are not 24 understand. However, I think some of the 25 reasonabl calculated to lead to the discov 25 uestions that Mr. Critton 'ust raised are 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Denise Sankary (201431-3464309) efd2e36 - ae e - e - c ac EFTA00723892  Page 26 Page 28 1 relevant, can be asked at the deposition, but 1 CERTIFICATE 2 Question 10 I find to be overly broad and 2 3 therefore properly objectionable. IT sustain 3 STATE OF FLORIDA 4 the objection as indicated in Question 10. 4 COUNTY OF PALM BEACH 5 I do have to move on, gentlemen, but 5 6 again, I allow you to ask the same type of 6 7 pointed questions without going into great 7 I, Denise Sanktuy, Registered Professional 8 detail and not invading this woman's privacy to a Reporter, State of Florida at large, certify that I was 9 a degree that it's going to be harassing. But 9 authorized to and did stenographically report the 10 when it comes to pointed questions regarding 10 foregoing proceedings and that the transcript is a true 11 medication that could deal with lifespan, that 11 and complete record of my stenographic notes. 12 Dated this 8th day of February, 2010. 12 could deal with STDs, that could deal with HIV 13 13 positive, we're now going into another 14 14 sacrosanct ground, but read up on the cases 15 15 before you get into that so we're not going to DENISE SANKARY, frlz 16 be back on another issue. 16 17 And again, whether or not she's on any 17 18 medication or anything else of a mind-altering 18 19 nature at the time of the deposition being 19 20 retaken or whether she was on any medication at 20 21 the time of the prior deposition was taken 21 22 think is flu. game. 22 23 All right. So that's the best I can do 23 24 today with the limited time that we have. I do 24 25 have to move on, gentlemen. Thank you. 25 Page 27 MR. CRITTON: Could 1 get the response by Monday by mail? THE COURT: You could fax it by Monday. That's fine. MR. CRITTON: Do you want us to prepare an order and then provide it? THE COURT: The best you can. MR. CRITTON: HI just refer to the 9 transcript 10 THE COURT: Try to continue your 11 communication. 12 MR. CRITTON: Thank you, your Honor. 13 MR. EDWARDS: Thank you, your Honor. 14 (The hearing was concluded at 9:30 a.m.) 15 16 17 18 19 20 21. 22 23 24 25 8 (Pages 26 to 28) PROSE COURT REPORTING AGENCY, INC. Electronically signed by DOTIISO Sankary (2014314454309) 6822•38511M1115 EFTA00723893