EFTA01076383.pdf

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME I OF II 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 VIDEOTAPED DEPOSITION OF JANE DOE NO. 5 Friday, February 26, 2010 8:07 - 3:44 III. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1312 PROSE COURT REPORTING AGENCY, INC. EFTA01076383 EFTA01076384  Page 2 Page 4 APPEARANCES: PROCEEDINGS On behalf of the Plaintiff: 2 3 STUART S. MERMELSTELN, ES laRMELSTEEN & HOROWITZ, M. 3 Deposition taken before Cynthia Hopkins, 18205 Biscayne Boulevard 4 Registered Professional Reporter and Florida Suite 2218 5 Professional Reporter, and Notary Public in and for Miami Phone: 6 the State of Florida at Large, in the above cause. 6 E-mail: 7 7 On behalf o the en t: 8, THE VIDEOGRAPHER: This is the 26th day of 3 ROBERT D.CRJTTON,JR,ESQUIRE MARK T. LUTHER. ESQUIRE 9 February, 2010. The time is 829E. This is 9 BURMAN, CRITTON, LUTHER & COLEMAN, UP 10 the videotape deposition of Jane Doe No. 5 in 303 Banyan Boulevard 11 the matter of Jane Doe No. 2 versus Epstein. Suite 400 West P • • ride 33401 12 This deposition is being held at 250 31 Phone: 13 Australian Avenue South, West Palm Beach, 14 Florida. 12 13 15 My name is Sascha Quimby. I'm the 14 ALSO PRESENT: 16 videographer representing Visual Evidence, Inc. 15 Will the attorneys please announce their 16 &eche Quimby, Videographer Visual Evidence, Incorporated 18 appearances for the record. 17 19 MR. MERMELSTEIN: Stuart Mermelstein for 18 20 Plaintiff Jane Doe No. 5. 19 20 21 MR. LUTTIER: Mark Luther for 21 22 Jeffrey Epstein. 22 23 MR. CRITTON: Bob Critton for 23 24 24 Jeffrey Epstein. 25 25 Page 3 Pag 1. 1 Thereupon, 2 • (JANE DOE NO. 5) INDEX 3 having been first duly sworn or affirmed, was 5 4 examined and testified as follows: EXAMINATION DIRECT CROSS REDIRECT 5 THE WITNESS: Yes, I do. 7 6 DIRECT EXAMINATION JANE DOE NO. 5 7 BY MR. LUTTIER: 3 8 Q. Good morning, ma'am. My name is BY MR. CRITTON 5 9 Mark Luttier, and we're here today for purposes of 9 10 taking your deposition. Could you tell us your full 10 11 name. 11 12 12 A. Jane Doe No. 5. 13 13 Q. And how do you spell your middle name? NO EXHIBITS MARKED 14 A. (Witness spells her middle name.) 14 15 Q. Okay. Ms. Doe No. 5, have you ever been 15 16 deposed before? 16 17 A. No. 17 18 Q. That's this process that we're doing here 18 19 today. 19 20 A. No. 20 21 21 Q. Okay. And let me explain a little bit 22 22 about the process. First of all, you understand 23 23 you're under oath? 24 24 A. Yes. 25 25 Q. Okiy. I'mxing to ask you uestions, and 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. EFTA01076385  Page 6 Page 8 1 you're going to have to give a verbal response 1 A. 1 don't have an accurate date. 2 because this court reporter is going to transcribe 2 Q. Well, approximately. 3 everything that you say. 3 A. It was before I started school. 4 A. Okay. 4 Q. And when you say "started school," what do 5 Q. So you can't shake your head and you've to 5 you mean? 6 to actually say a word so she can get it down. 6 A. Started cosmetology school. I just finished. 7 A. Okay. 7 Q. And what cosmetology school are you 8 Q. If you don't understand a question that I 8 referri 9 ask, tell me you don't understand it and I will 9 A. 10 explain it for you. 10 Q. And when did you start that? 11 A. Okay. 11 A. Last February. 12 Q. Okay. If you answer a question, I will 12 Q. That would be February 2009? 13 assume you understood it. 13 A. Yes. 14 A. Okay. 14 Q. So sometime prior to 2009 a 15 Q. Okay. If during the deposition you want 15 psychiatrist in Florida who prescribe for 16 to take a break, just let me know, and I'll be happy 16 you? 17 to accommodate you. 17 A. No. My recent visit to was in 18 A. Okay. 18 Florida. I was in Virgina at the time before I went to 19 Q. If during the deposition you think that a 19 that's where I got my first prescription of 20 previous response that you gave me needs to be 20 Ill e idn Virginia 21 amended or changed in any way, just tell me, you 21 Q. Okay. Who ysiclan who 22 know, I just thought of something. I need to go 22 on you? Would it be 23 back and correct something or supplement, whatever 23 a Dr 24 you think has to happen. Okay? 24 A. It, l'm not sure, because I was seeing a 25 A Okay. 25 psychologist and a psychiatrist, so I wouldn't know. I Page 7 Page 9 1 Q. Are you presently under any kind of 1 can't put a name to the face of who it was. 2 medication? 2 Q. This is, you were seeing a psychologist 3 A. No. 3 and a psychiatrist? 4 Q. In the last six months have you been under 4 A. In Virginia. 5 any medication? S Q. Okay. What psychologist were you seeing? 6 A. Yes. 6 A. I don't remember. 7 Q. What medication have you been under in the 7 Q. And when was it you were seeing this 8 last six — 8 psychologist and psychiatrist in Virginia? 9 A. . 9 A. Around the same time before I started school 10 Q. — months? 10 in Virginia. 11 AL =B. That's it. 11 Q. So were you seeing than in January of '09? that is 12 A. Yes. 12 13 14 15 Q. And what's the level of= prescribed for you? A. Twenty and then it went up e. Q. Okay. Most recently it was milligrams? 13 14 15 Q. I want to refer to — I'm going to read to you your answers to interrogatories that you gave in this case which were dated by you January 26th, '09. Interrogatory 12 asks you to list all the 16 A. Yes. 16 17 Q. And howab fte er; you prescribed to take 17 physicians — 18 .-milligrams of 18 A. Uh-huh. 19 A. I took it once a day, once in the morning. 19 Q. — that you had been to. I'm going to 20 Q. And who prescribed that drug? 20 show that list to you. 21 A . It was a new doctor in Florida. I do not 21 A. Okay. 22 recall the name. 22 • Q. You see Interrogatory 12 there? You don't 23 Q. Was, what kind of doctor was it? 23 mind my hand, my highlighting. And I think there's 24 A. Psychiatrist. 24 one name on the next page. 25 Q. And when was it first prescribed fiat. you? .25. „ A. Okay. 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. EFTA01076386  Page 10 Page 12 1 Q. So, can you tell me which of these people 1 right? 2 is the psychologist that you were seeing in 2 MR. MERMELSTEIN: Objection to form. 3 Virginia? 3 THE WITNESS: I, I don't, I don't 4 A. I don't think ifs listed. 4 remember, honestly. 5 Q. Can you tell me which of those physicians 5 BY MR. LUTHER: 6 is the psychiatrist that you were seeing in 6 Q. Okay. Well, let me ask you this: Do you 7 Virginia? 7 have a, an absolute specific recollection that you A. I think it's this one, 8 did, in fact, see a psychiatrist -- 9 Q. Read the, the name. 9 A. Yes. 10 A. 10 Q. — and psychologist in Virginia? 11 Q. 111111..,ame? 11 A. Yes, yes. I just don't remember. 12 A. It doesn't say. I don't know. 12 Q. And the psychologist that you saw in 13 Q. Well, how long did you see this 13 Virginia was male or female? 14 psychiatrist? 14 A. Psychologist Was it -- they were both 15 A. I saw her — I had two visits. I'm guessing. 15 females. 16 That's not 100 percent accurate. 16 Q. Okay. Do you know the difference do 17 Q. Okay. 17 you know there's a difference between a psychologist 18 A. That was just — 18 and a psychiatrist? 19 Q. Okay. Would you pass me those 19 A. Yes. 21 interrogatories so I can see if you have a date 20 Q. Okay. I'm now asking you about the 21 here. All right. In answer to 8 you said that — 21 psychologist 22 what you answered was, in response to an 22 A. Okay. 23 interrogatory that asked you to list all of the 23 Q. There was a female psychologist. 24 physicians and medical facilities or other health 24 A. Uh-hub. 25 care providers including psychiatrists, 25 Q. And do you remember her name? Page 11 Page 13 1 psychologists, mental health counselor, et cetera, 1 A. No. 2 that you had been treated for in the last ten years. 2 Q. Do you remember her first name, her last In Number 8, you list 3 name, any combination of the two? and you give a PO Box. And the 4 A. No, I don't interrogatory tells you to state, as to each the 5 Q. Do you have any records from which you can 6 dates of the examination and the condition or injury 6 determine that name? 7 for which you were examined. And what you put was 7 A. At home. 8 December 2007, dermatitis. 8 Q. Home, meaning what, here in Palm Beach 9 Now, you understand dermatitis is a County? 10 skin condition? 10 A. Home in Virginia. 11 A. Oka Well then I must be confused because 11 Q. Okay. Do you have -- in your wallet, for 12 I did have 12 example, do you have a card from, from this person? 13 A. I could look if you would like me to. 14 Q. Okay. So now you're saying 8 is not the 14 Q. Yeah, that would help us, if you would, 15 psychiatrist that you saw in Virginia? 15 please. 16 A. No, no. 16 MR. WrITER: And, Stuart, I invite you, 17 Q. So, in answering your interrogatories, you 17 if you know the answers to this, I invite you 18 have — you did not give us either the name of the 18 to go ahead and chime in. 19 psychologist or the psychiatrist who treated you in 19 MR. MERMELSTEIN: Well — 20 Virginia? 20 MR. LUTTlER: I'm not looking — l'm 21 A. I guess not. No, I guess not. 21 looking to get to the answer. 22 Q. Pm not, I'm not quibbling with you over 22 MR. MERMELSTEIN: I know she, she — this 23 words, but when, when we hear the word "guess," you 23 whose name you mentioned is in response 24 know, it makes us a little nervous. So, when you 24 lt.revious Interrogatory Number II. 25 say you guess riot, you definitively know you didn't, 25 MR. LUTT/ER: And I don't think that's a 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. EFTA01076387  Page 14 Page 16 1 psychologist. 1 give you the original back, and that way it 2 MR. MERMELSTEIN: That's a psychiatrist. 2 won't be on the record. We'll just make a copy 3 MR. LIMIER: I don't think it's a 3 so ifs not in the court file. 4 psychiatrist. 4 BY MR. LUTTIER: 5 MR. MERMELSTEIN: It's an I., right? 5 Q. Okay. All right. So, let me go back. 6 That would be a psychiatrist. 6 The — we were talking about the female psychologist 7 MR. LUTTIER: Okay. That would be, you 7 in Virginia. You don't {mow her name or number. Do 8 know, from the record that I'm looking at — 8 you recall when you first went to see this 9 okay. We'll get to that. 9 psychologist? 10 MR. MERMELSTEIN: So, yeah, I don't know 10 A. I went with my husband. No. 11 if that's the psychiatrist that she's referring 11 Q. Okay. You, You recall that your first 12 to or not. 12 visit with her was one in which your husband went 13 THE WITNESS: No, not on me. 13 with you? 14 BY MR. LUTTER: 14 A. Yes. 15 Q. Okay. Do you have a cellphone that lists 15 Q. Okay. Obviously, you were in Virginia at 16 the phone number? Do you have a phone number? 16 the time. Did, did you go to this psychologist 17 A. I have a cellphone. 17 shortly after you moved to Virginia? What I'm 18 Q. But do you keep her phone number in there? 18 looking for now is maybe the year. 19 A. Well, since my husband's in the military, I go 19 A. Let me think I don't know. I can, l can 4 back and forth from Florida to Virginia a lot, and 21 approximate it I just — 21 that's why I have to change constantly 'cause if he goes 21 Q. What's, what, what's your best estimate of 22 on deployment, I come to Florida. So that's the problem 22 when you moved to Virginia? 23 right now. That's why I don't remember. 23 A. When I moved to Virginia was 2006, 2007. 24 Q. I think you're checking your cellphone to 24 Q. Okay. And when you moved to Virginia in 25 see if you have the phone number there? 25 2006, what time of the year was it? Page 15 Page 17 1 A. Yes. I have a doctor in my phone. I don't 1 A. I moved there in January of, January of 2007. 2 know if it's the one that I saw here, while my husband 2 Q. January of 2007. 3 was on deployment, for my I can give you the 3 A. Yes, because I got married in — yeah. 4 number. 4 Q. You got married when? 5 Q 5 A. December 2006. 6 A. Ifs 6 Q. Okay. So you know you went to Virginia 1 Q. Do you have a name associated with it? 7 shortly after your wedding? A. No. B A. Yes. 9 Q. You just have a — 9 Q. Were you married down here min Virginia? 0 A. I just have it under my doctor. I can get all 10 A. Down here. 11 this information from my insurance company - 11 Q. In Palm Beach County? 12 Q. Okay. 12 A. Yes. 13 A. or my health care. 13 Q. Okay. 14 Q. Yeah. What, what insurance company is 14 A. No, Broward County. I'm sorry. 15 that? 15 Q. Okay. All right. Approximately how long 16 A a. 16 was it after you moved to Virginia that you first 17 Q. Okay. Do you have the card — 17 went to this female psychologist? 18 A. Yes. 18 A. Probably, Pm guessing, five to six months. 19 Q. —that will give us the number? Is that 19 Q. Okay. 20 the military insurance? 21 A. It's not accurate. 21 A. Yes, Prime. 21 Q. And, and why were you and your husband -- 22 MR. LIMITER: Okay. Do you have a way to 22 why did you and your husband go to this 23 make a copy? 23 psychologist? 24 THE COURT REPORTER: Yes. 24 A. Marital problems. ,25 MR. LUTTIER: Okay. We're, we're going to 25 Q. And specifically what were the marital 5 (Pages 14 to 1 7) PROSE COURT REPORTING AGENCY, INC. EFTA01076388  Page 18 Page 20 1 problems? 1 Q. Okay. And each of those visits was about 2 A. Fighting. 2 marital problems with your husband? 3 Q. And how many visits did you, did either 3 A. When he came, yes. When he was present at the 4 you alone or you and your husband have with the 4 doctor's office with me? 5 psychologist? 5 Q. Right. 6 A. Two to three. 6 A. It was about us. 7 Q. And were there were those visits with 7 Q. Okay. How about on the — you say you 8 some degree of regularity? For example, you went 8 went one time alone. 9 once a week for a month, or you went for once a 9 A. Yes. 10 month for two months, or... 10 Q. What was that visit about? 11 A. I think it was once a month. 11 A. Me and my personal life. 12 Q. Okay. So there would be approximately a 12 Q. And specifically wises about you and your 13 three-month period - 13 personal life? 14 A. Yes. 14 A. Things I've been through. 15 Q. — over which there would be about three 15 Q. Okay. For what, what was your primers 16 visits? 16 complaint or purpose for you going alone on that 17 A. That's not accurate, so I'm just saying. 17 visit to the psychologist? 18 Q. If you know it's not, what's your most 18 A. That I was depressed. 19 accurate recollection of how many visits you had? 19 Q. So, the, the, the thing that caused you to 20 MR. MERMELSIEIN: Objection to form. 20 go to her alone was because you felt that you were 21 THE WITNESS: I mean we went three 21 depressed? 22 times — I don't know. 22 A. Yeah. 23 BY MR. LIMIER: 23 Q. And what is it that you specifically 24 Q. You were about to say you went three 24 discussed with her about your personal life? 25 times, what? 25 A. It was about my husband, it was about family, Page 19 Page 21 1 A. I don't lcnow. rut not going to give an answer 1 Jeffrey Epstein was mentioned 2 when I'm not 100 percent sure of how many times I 2 Q. And how do you recall that Jeffrey Epstein 3 vvent 3 was mentioned? 4 Q. I want your -- 4 A. What do you mean? 5 A. - or how many, how many — like a time frame. 5 Q. What is it that makes you recall that you 6 Q. Well, I, I don't want you to just pick a 6 know that Jeffrey Epstein's name was mentioned? 7 number out of the sky, but I want your best 7 A. Because I remember mentioning it to her, all 8 estimate. I mean, if I had these, if I'd have had 8 the things I went through in my life. 9 this doctor's name, I would have subpoenaed the 9 Q. Okay. Anything else that you recall? 10 records and rd know exactly, but I am trying to 10 A. Just about my, my past — 11 find out who this doctor is which is why we sent the 11 Q. All right. 12 interrogatories. 12 A. — you know. 13 A. I'm going to say over three months. 13 Q. And this was a 45-minute visit? 14 Q. Okay. So your best estimate is — 14 A. Yeah. I'm pretty sure. 15 A. My best estimate. 5 Q. Did you ever go back to her after the 16 Q. 'That's fine. And on each visit that you 16 visit that you went alone? 17 went to this psychologist, was it you and your 17 A. I think, yeah, after I went to her alone, my 18 husband? 18 husband and I went one more time after that. 19 A. I think there was, !went one time alone. 19 Q. But the visit that you and your husband 20 Q. In addition to the three with your 21 had was about your marital difficulties. 21 husband? A. Yes. 22 A. Uh-huh. 22 Q. And then after that last visit between you 23 Q. So you maybe had — your best estimate is 23 and your husband and her, you didn't go back? 24 four visits, correct? 24 A. No. 25 A. Three to four. 25 Q. So, somewhere in the ear 2007 tut 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. EFTA01076389  Page 22 Page 24 going to her? 1 Q. Well, these were 45-minute sessions, 2 A. Yeah. 2 right? 3 Q. All right. 3 A. Yeah, but I didn't know anybody in Virginia. 4 A. I would say. 4 It wasn't hike I had a babysitter. 5 Q. Do you recall where this doctofs office 5 Q. Well, in the two years that you lived in 6 was located? 6 Virginia, would it be a correct statement that there 7 A. No. 7 were times that, that you left your daughter with Q. I mean, do you — I don't !mow, was it in 8 somebody else while you did things? 9 the same town that you were living in in Virginia? 9 A. No, I took my daughter. 10 A. No, it was a different area because I remember 10 Q. When you went, when you went the one time 11 it was a little bit of a drive. 11 to the psychologist did you take your daughter with 12 Q. When you say "a different area," what city 12 you? 13 was it in? 13 A. Yeah, I did. 14 A. I don't remember. 14 Q. Okay. Because your daughter at that time 15 Q. Well, how long did you live in this area 15 was less than a year old, right? 16 of Virginia? 16 A. Yeah, she was young. 17 A. I lived there two years, around two years. 17 Q. All right. So having your daughter didn't 18 Q. Okay. And I assume in that two-year 18 prevent you from going to a psychologist? 19 period you became familiar with the municipalities 19 A. No. I mean, no, but it was too hard. 20 and the cities that were located in your immediate 20 Q. Well, you, you went the one time, you took 21 vicinity. 21 her with you. 22 A. No. I am horrible with direction. 22 A. It was still hard. 23 Q. Okay. Do you have, do you have any notes 23 Q. And I assume that at age less than one she 24 or anything from, that your visits with this 24 slept a fair amount of time? 25 psychologist 25 A. Uh-huh Page 23 Page 25 1 A. I don't have any. Personally, I don't, I 1 Q. That is your daughter -- 2 didn't take any notes. 2 A. — she did, but she also had colic, so it was 3 Q. Okay. Did the psychologist have any tasks 3 not easy. 4 that she asked you to do? Like, sometimes a 4 Q. Okay. But you'd done it once before. The 5 psychologist will say, you know, write something out 5 doctor, for example, didn't say, you don't come here 6 or something like that. 6 with your daughter? 7 A. No. A. No. 8 Q. So you have no documentary materials at 8 Q. The doctor didn't say, I don't want to see 9 all concerning your visits with this psychologist? 9 you anymore? 10 A. No. 10 A. No. 11 Q. Is there any record — other than your 11 Q. You made the decision you weren't going to 12 insurance company which I assume paid for part of 12 go back? 13 this psychology visit. 13 A. Yeah. 14 A. Paid for all of it 14 Q. Okay. And your testimony is that in a 15 Q. Paid for all of it. Is that — do you 15 two-year period that you lived in Virginia, you 16 have any other record from which you can determine 16 never left your daughter with anybody else? 17 who this psychologist was? 17 MR. ME RMELSTF_1N: Objection to form. 18 A. No. 18 THE WITNESS: If you mean my mother-in-law 19 Q. Did the psychologist at your last meeting 19 that came up and watched her from — 20 advise that she didn't want to see you anymore and 20 BY MR. LUTTIER: 21 that your sessions were done? 21 Q. I mean anybody. 22 A. No, I just didn't go back. 22 A. Yeah. 23 Q. Okay. Why, why didn't you go back? 23 Q. Yeah what? 24 A. Because I have a two-year-old daughter, and 24 A. Yes, my mother-in-law came to Virginia to stay 25 it's just hard for me to take the time to go. 25 a couple of times from Florida. 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. . EFTA01076390  Page 26 Page 28 1 Q. Okay. 1 Q. You said that you — I understand that you 2 A. So when she was there, she would watch my 2 went with your husband to the psychologist, but you 3 daughter so my husband and I can go out, you know, and 3 said you went to the psychologist one time alone to 4 spend some time together. 4 talk about your problems. 5 Q. Yeah. 5 A. Yes. 6 A. But she wasn't there on the occasions of, you 6 Q. There were times that your husband was 7 Imow, when l had to go to a doctor session. It wasn't, 7 home from work that he could have watched your 8 you know, it's not — I didn't have somebody on a 8 daughter, and you could have gone back to the 9 schedule there — 9 psychologist, if you chose to, to discuss whatever 10 Q. During this — 10 problems you wanted to discuss with her, right? 11 A. — that could watch my daughter. 11 A. I could have. 12 Q. During this two-year period that you were 12 Q. Okay. And the insurance company was 13 in Virginia, was your husband living with you? 13 paying whatever those charges were? 14 A. Yes. 14 A. Uh-hum. Yes. Sony. 15 Q. Were you living on a military base? 15 THE COURT REPORTER: Thank you. 16 A. No. 16 BY MR. LUTTIER: 17 Q. Okay. And was, was he in the military at 17 Q. Let's talk now about the psychiatrist that 18 the time? 18 you said you saw in Virginia. 19 A. Yes. 19 A. Yes. 20 Q. And did he have hours that he went to 20 Q. But first of all, let me go back and ask 2/ work? 21 you a question about the psychologist. How did you 22 A. Yes. 22 select that female psychologist that you saw in 23 Q. Okay. And when would he typically work; 23 Virginia? 24 what was his schedule? 24 A. It was just offered through page 25 A. His schedule often changes since he's in the 25 that, you know, provides -- they accept. Page 27 Page 29 military. He can work day, night, or mid check. I 1 Q. Okay. Okay. Now, you said you went to a don't know the exact schedule he was on at that point in 2 female psychiatrist in Virginia as well. 3 time, but day check is 6:00 to 2:30-3:00, depending on 3 A Yes. 4 what his boss wants to keep them. Mid-check is — 4 Q. Was this during the same period of time mid-check is all night long. I don't know the exact that you went to the psychologist? 6 time, but ifs all through the entire night until 6 A. That was after. That was before my husband 7 morning. And then the night check is --1 think it's 7 was about to leave on his deployment. 8 like 2:00 or 3:00 to 11:00 at night. Q. Okay. 9 Q. Okay. So either the mid check or the 9 A. I came — 10 night check, he was home during the day? 10 Q. When was your — 11 A. Yeah. 11 A. Well, I came to Florida in January. 12 Q. All right. So, there were times during 12 Q. January of - 13 this two-year period that your husband was home and 13 A. Of last year. 14 available to watch your daughter? 14 Q. — of '09? 15 A. Yeah, but I wouldn't, you know, I wanted to go 15 A. Yes. So, it was probably a couple of months 16 with my husband. 16 before that that I went and saw her. 17 Q. Well, these were visits that you went to 17 Q. Okay. And how did you select that 18 the psychology — you went alone, right? 18 psychiatrist? 19 A. Psychiatrist or — 119 A. The same way, off the Internet that the 20 Q. Psychologist 2 providers — 21 A. Psychologist? 21. Q. And what city was she located in? 22 Q. We're still on the psychologist. 22 A. I don't know. 23 A. Okay. The psychologist was also for our 23 Do you remember where her office was? 24 marriage, so I wanted him to go with me most of the 24 A. No. 25 time. 25 Q. How many times did ou see her? 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. EFTA01076391  Page 30 Page 32 1 A. Twice. 1 A. I did, but I'm not on it right now. 2 Q. Do you, do you recall about over what 2 Q. Okay. When you say "right now," do you 3 period of time you saw her? Like, was it two times 3 mean literally like today? 4 in a month? 4 A. As in the past, Ince, as in the past week I 5 A. I think it was once a month. 5 stopped taking it. 6 Q. And for what reason did you initially go 6 Q. OW. And why did you stop taking it? 7 see her? 7 A. Because I'm pregnant A. Fa - 8 Q. Is it contraindicated; that is, did your 9 Q. And, and do you mean that when you went to 9 doctors tell you if you're pregnant, don't take it? 10 her you already knew that what ou wanted to do is 10 A. I just — I haven't seen lidgfayet, but I 11 go get a prescription f 11 just know ifs not good to takelMI while you're 12 A. Not enact] , but something to help me 12 pregnant. 13 concentrate. 13 Q. Well, I suppose the first thing we should 14 Q. And so, so your, as they would say, chief 14 do is congratulate you on being pregnant 15 complaint that caused you to seek out her aid was 15 A. Oh, thanks. 16 you wanted something to help you with your 16 Q. Is this a planned pregnancy? 17 concentration? 17 A. Not necessarily. 18 A. Yes. 18 Q. Are, are you happily pregnant? Let me ask 19 Q. Was there any other problem or, or 19 you that. 20 situation that you were seeking out her counsel for? 20 A. Yeah, I mean, ifs going to be hard, but — 21 A. There was the second visit I mentioned that I 21 two kids, young age, I mean. We'll see what happens. 22 had, depression, and that's when she prescribed me 22 Q. You're, you're sure you're pregnant? 23 to try. 23 A. I took four tests. 24 Q. How — did you have sessions with her when 24 Q. Okay. Have you been to the doctor to 25 you saw her on these two occasions, or did you 25 have — Page 31 Page 33 1 simply go in and get a prescription? A. No, it's not — 2 A. The fast time !just went in and got a 2 Q. Early pregnancy? 3 prescription. The second time I spoke to her about, you 3 A. Yes. 4 know, depression medication. 4 Q. Okay. 5 Q. And, and what did you tell her about your S A. Very early. 6 depression? 6 Q. Does, does your husband know about it yet? 7 A. I just told her that I'm depressed. I'm not 7 A. Yes. 8 happy. And I asked her what would be the best, you 8 Q. Okay. ill" So, so you have, you 9 know medication to try, and she told me to try 9 stopped taking last week because of your 10 10 own decision that you didn't want to take that while 11 Q. This female psychiatrist Mat you saw in 11 you were pregnant? 12 Virginia, was she the lust medical doctor to 12 A. Yes. 13 prescribe for you? 13 Q. Not because a physician said you couldn't? 14 A. Yes. 14 A. Yes. 15 Q. And was that initially prescribed at a 15 Q. All right. And did you find the 16 level of a day? 16 was helpful to you? 17 A. I think she started me off lower than that. 17 A. Yes. 18 Q. Okay. 18 Q. It allowed you to concentrate better? 19 A. I don't, I don't recall what my — 19 A. Yes. 20 Q. Okay. 20 Q. And had you had — was there a time in the 21 A. first dosage was. 21 past — you have a brother that, that has, has 22 Q. Have you taken Adder, 22 Attention Deficit Disorder? 23 24 25 continuously since the time that you saw this female psychiatrist in Virginia in 2007 right up until today? 23 24 las 9 (Pages 30 to 33) PROSE COURT REPORTING AGENCY, INC. EFTA01076392  Page 34 Page 36 1 Q. And I think your brother at one time was 1 alternative school. 2 on the medication. 2 Q. Okay. Typically classes here graduate in 3 A. Yes. 3 June of a year. 4 Q. And you had taken some of that — 4 A. Okay. 5 A. Yes. 5 Q. So, when you say you got it late that 6 Q. -- when you were maybe in high school? 6 year, did you get it — 7 MR. MERMELSTEIN: Make sure you let him 7 A. Late. 8 finish his question before you answer. 8 . Q. — within the same calendar year that you 9 THE WITNESS: Oh, okay. 9 would have received it had you — 10 BY MR. LUTTIER: 10 A. I'm pretty sure it was in 2006. I was 11. Q. It wass like in high school you took 11 supposed to graduate 2005. 12 some otitis 12 Q. Okay. So, we know that in June if, if you 13 A. Yes. 13 had stayed in school for each year and progressed by 14 Q. And you found that it was effective in 14 passing every year, you would ordinarily have 15 terms of allowing, helping you to concentrate? 15 graduated in June of '05? 16 A. Yes. 16 A. Yes, Ida* stay back. 17 Q. Is that how you knew that when you went to 17 Q. No. Yeah,1tmderstand that 18 se.rthe chiatrist in Virginia that you wanted 18 A. Okay. 19 19 Q. Pm just going back to your birthday. 20 A. Yes. 21 That, that would mean that that would put you then 21. Q. Is there — for what riod of time did 21 at 18 years of age June of '05 when you graduated? 22 you take your brother's 22 A. Yes. 23 A. It was just for a short period of time. 23 Q. So that would put you as a sophomore, 16 24 Q. Lfice less than a month? 24 years of age? 25 A. Yes. 25 A. Yes. Page 3 Page 37 1 Q. Okay. Is there — and that would have 1 Q. Okay. So you, your best recollection is, 2 been when you were how old? 2 you, you had taken your brother's sometime 3 A. I was in high school. 3 when you were about 16 years of age. 4 Q. Freshman year? 4 A. Yes. 5 A. No. 5 Q. And then you took it for a month or two? 6 Q. Were you livi