EFTA01076720.pdf

Page 397, UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME III OF III 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. 3 Tuesday, April 6, 2010 2:07 - 5:07 p.m. 250 Australian Avenue Suite 150 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1577 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hooking (601 $d47f016-be69-47a2.9d44-6a177536c37o EFTA01076720 EFTA01076721  Page 394 Page 396 1 APPEARANCES: 1 CONTINUED PROCEEDINGS 2 On behalf of the Plaintiff: 2 3 STUART S. MERMELSTEDI, ESQUIRE MERMEISTEIN & HOROWITZ, PA. 3 THE VIDEOGRAPHER: This is the 6th day of 4 18205 Biscayne Bouleved 4 April 2010. The time is approximately 2:07 Suite 2218 5 p.m. 'Ibis is the videotaped deposition of 5 6 Jane Doe No. 3 in the matter ofJane Doe versus 6 E-mail: 7 Jeffrey Epstein. 7 On behalf o tieD t 8 This deposition is being held at 250 South 9 ROBERT D. CR1TTON,HL, ESQUIRE 9 Australian Avenue, West Palm Beach, Florida. BURMAN, CRITTON, L1JTITER & COLEMAN, LIP 9 303 Banyan Boulevard 10 My name is Daniel Downey. Iin the videographcr Suite 400 11 representing Visual Evidence. Incorporated. 10 West 'da 33401 12 Will the attorneys please announce their 11 Phone: E-mail:. 13 appearances for the record? 12 14 MR. MERMELSTEIN: • Sttiart Memielstein for 13 ALSO PRESENT: 15 the Plaintiff, Jane Doe No. 3. 14 16 MR. CRITTON: Bob Critton for Daniel Downey, Videographer 15 Visual Evidence, incorporated 17 Jeffrey Epstein. 16 18. 17 19 (JANE DOE NO. 3), 18 19 20 Having been first duly sworn or affirmed, was 20 21 examined and testified as follows: 21 22 THE WITNESS: Yes. 22 23. DIRECT EXAMINATION 23 24 24 BY MR CRITTON: 25 25 Q. Afternoon, Ms. No. 3. Page 395 Page 397 1 1 A. Hello. 2 3 INDEX 2 Q. Have you done anything to prepare for your 3 deposition today; that is, have you looked at 4 anything? EXAMINATION DIRECT CROSS REDIRECT 5 A. Yes. JANE DOE NO. 3 6 Q. Tell me what you looked at. a 7 A. My transcript. BY MR. CPSITON 396 8 Q. From the first session on February 19th? 9 9 A. Yes. 10 11 10 Q. Did it appear to be accurate to you; that 12 11 is, the testimony that you gave was accurate? 13 EXHIBITS 12 A. Yes; 14 15 13 MR. MERMELSTEIN: Objection to form. 16 EXHIBIT DESCRIPTION PAGE 14 BY MR. CRITTON: 17• 15 Q. Have you spoken with anyone other than DEFENDANT'S EX. 4 PLAINTIFFS AMENDED 426 . 16 your attorneys? 19 SUPPLEMENTAL ANSWERS TO INTERROGATORIES 17 Same kind of rules. If I ask you a 19 DEFENDANTS EX. 5 PLANTUFS 427 18 question, have you spoken with anyone, I am not — SUPPLEMENTAL ANSWERS TO 19 I'm not allowed to ask questions about discussions 20 INTERROGATORIES DEFENDANT'S EX.'6 PLAIITI1FFS ANSWERS 528 20 you've had with your attorneys, so I am excluding 21 TO DEFENDANTS FIRST 21 your attorneys and anyone who works in their office. ATIERROGATORIES 22 Okay? 22 23 A. Okay. 23 24 24 Q. Have you discussed your deposition with 25 25 anyone -- 2 (Pages 394 to 397) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. •a Electronically signed by cynthia hopkIns (601 Electronically signed by cynthla hopkIns (601 Electronically signed by cynthia hopkIns (601 8d471015-be89-47a2.9d44.6a177636c37e EFTA01076722  Page 398 Page 400 1 A. Yes. 1 Q. Okay. And that's the extent of what she 2 Q. .'-- since you gave it? 2 said about the deposition to you? 3 With whom did you discuss your deposition? 3 A. She asked me questions, what could happen. 4 A. Jane Doe No. 4 and Jane Doe No. 7. 4 Q. What do you mean? 5 Q. Have you seen Jane Doe No. 4 and/or Jane 5 A. Like what, what could take place. 6 Doe No.7 since February 19111ot2010 -- 6 Q. Oh, at her deposition? 7 A. Yes. 7 A. At a deposition. 8 Q. — your deposition? 8 Q. Oh, when, when you, when you were talking 9 On how many nrrAsions? Now, I'm talking 9 about discussing the deposition, were you talking 10 about seen them as distinct from spoken with them. 10 about your deposition with Jane Doe No. 7 or Jane 11 A. One. 11 Doe No. 7 was talking about the deposition she had 12 Q. Where, where did you-all meet? 12 given? 13 A I saw Jane Doe No. 7 only. 13 A In general. 14 Q. Saw Jane Doe No. 7. All right. And wheri 14 Q. Okay. So, she had, she just said she was 15 did you see Jane Doe No. 7? 15 nervous, but you don't know whether she had given 16 A. My birthday party. 16 the deposition and was nervous or was about to give 17 Q. All right. Where, where was with your 17 the deposition? 18 birthday party? 18 A_ Correct. 19 A. At Noche. 19 Q. All right. I understand now. 20 Q. That's". that's up in The Gardens 20 Did you tell her what had happened at your 21 near Soverel 21 deposition? 22 A. Yes. 22 A No. 23 Q. And Jane Doe No. 7 came to your party? 23 Q. So, just so the jury knows, you had given 24 A. Yes. 24 a deposition and you didn't tell her one thing about 25 Q. . How many people did you invite to your 25 the deposition that went on? Page 399 Page 401 1 party/ 1 MR. MERMELSTEIN: Objection to form. 2 A Ten. 2 BY MR. CRITTON: 3 Q. Did anyone else come who was, who is a 3 Q. Is that what you're telling us? 4 Plaintiff against Mr. Epstein? 4 A. Exactly. 5 A. No. 5 Q. All right. How long, how long — what 6 Q. Was anyone there other than Jane Doe No. 7 6 time did your party start and what time did it end? 7 who knew you were a Plaintiff? 7 A. We had dinner with my family first, and then 8 A. No. 8 we went to the club about 10:30,11:00, somewhere around 9 Q And let's see. You were born on 9 there. 10 M, so it was about a little over a month ago. 10 Q. And what time did the party shut down? 11 Had Jane Doe No. 7 given her deposition? 11 A. I left at 2:30, 3:00, around there. 12 A. I don't know. 12 Q. And did you go home? 13 Q. Did she talk about her deposition at all? 13 A. Yet 14. . A. Yes. 14 Did you go home with anyone? 15 Q. Okay. And what did she say about her 15 A. With my girlfriends. 16 deposition? 16 Q. And who's that? 17 A. She was nervous. 17 A 18 Q. Okay. She liked me? 18 Q. What' s last name? 19 A. I, I don't know. 19 20 MR. MERMELSTEIN: Objection to forth. 20 Q. A 21 THE WITNESS: I don't know. 21 A. Yes. 22 BY MR. CRITTON: 22 Q. And is the ono, I think 23 Q.' Just thafs all she said, she was nervous 23 you told tote that you had told her that you had been 24 during the deposition? 24 at Epstein's house? 25 A Yes. 25 A. Yes. 3. (Pages 398 to 401) PROSE COURT REPORTING AGENCY,. INC.:- Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8t4171015-be89-47a2-91144-6at77536c37e EFTA01076723  Page 402 Page 404 1 . Q. Does know that you were at 1 Doe No. 7 tell you what she's doing right now 2 .Mr. Epstein's house? 2 • work-wise, for fun, or is she still in school? 3 A. No. 3 . A. I know she's still in school. 4• . Q. She doesn't And she doesn't know you're 4 Q. . And do you know what she's going to be, 5 a Plaintiff in this lawsuit? 5 what she wants to be? 6 • A. No. 6 A. I think business, something to do with 7 Q. Let me just stay with the other 7 business. 8 individuals, as Question 11 in your second set of 8 Q. Did she tell you whether she was dating 9 interrogatories that was sent to you, you listed 9 anyone? • 10 people who were your five closest friends, and you 10 .. A. No. 11 apparently only named four -- 11 Q. How about — and then you said — have you 12. . A. Yes. 12 spoken with Jane Doe No. 7•-- other than seeing her 13 Q. — Prom to 201 13 the one night over the last month and a halt have . 14 ne was 14 you continued to speak with her regularly? 15 (phonetic) 15 A. Prior to spring break for her college. 16 16 Q. Which was when? 17 A. 17 A. Two weeks ago, somewhere. 18 Q Oh, You've known her since 18 Q. Where was she headed to? 19 high school? 19 A. ICey West, Miami. . 20 A. Since Wore high school. 20 Q. And you haven't talked to her since then? 21 Q. A long time? 21 A. No. 22 A. Yes. 22 Q. Other than the one time you saw her and 23 Q. And she doesn't — does she know you're a 23 the other conversations that you had, have you 24 Plaintiff in this lawsuit? 24 discussed the cases at all? 25 A. No. 25 A. No. Page 403 Page at 1 Q. Does she know — then, obviously, she 1 Q. Jane Doe No. 4, when did you speak with 2 wouldn't -- well, does she know that you ever went 2 Jane Doe No. 4, you haven't seen since 3 to Mr. Epstein's home — • 3 February 19th, correct? 4 A. No. 4 A. Correct. 5 Q. — on one occasion — 5 Q. But you've spoken with her? 6 A. No. 6 A. Yes. Q. of the four occasions that you 7 Q. Because you speak with her regularly? 8 described?. 8 A. No. 9 And M, she's still one of your best 9 Q: How many occasions have you spoken with 10 friends? 10 her? - 11 A. Yes. 11 A. Once. 12 Q. Did you — have you discussed with her the 12 Q. Okay. And what was the occasion; did she 13 deposition you gave? 13 call you or did you call her? 14 A. No. 14 A. I called her. 15 Q. And does she — she knows you went to 15 Q. About? 16 Epstein's? 16 A. Birthday. 17 A. ' Yes. 17 Q. Just to say happy birthday? 18 Q. All right. Any guys at the party or 18 A. No, my birthday. So, l invited her to my 19 a girl patty? 19 party. 20 A. There was guys at the club. 20 Q. Oh, and she said what? 21 Q. Understand that, but they came to your 21 A. Yeah. 22 party? 22 Q. But she didn't show? 23 A. Yeah. 23 A. Correct 24 Q. Separate and apart from having seen Jane 24 Q. Do you know why she didn't show? 25 Doe No. 7 -- well let me ask you this: Did Jane 25 A. No. l.e....S.Niaafted.nefeJala 4 (Pages 402 to 405) PROSE COURT 'REPORTING' AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47f015-1)039-47a2-9d44-6a177536c37o EFTA01076724  Page 406 Page 408 i. Q. Did you ever talk to her about your 1 2 deposition in any way? 2 A. Can you rc — can you — 3 A. No. 3 Q. Sure. 4 Q. -And ill understood your testimony, the 4 A. . methin more sim le. 5 only thing you looked at is your transcript in 5 6 preparation for today? A Correct 8 Q. I see in your answers to interrogatories, 9 which is consistent with testimony, do you 9 A. Yes. 10. still work for the 10 Q. Okay. So putting aside those individuals, 11 A. 11 have you had a chance to look at your, at least the 12 • 12 physicians, psychiatrists, psychologists, et cetera. 13 that you've disclosed that you had seen. 14 A. Yes. 14 And my question to you is, is: Have them 15 Q. And you describe your, yourself now as the 15 been any psychiatrists, psychologists, therapists 16 lead hostess? 16 that you've seen for solely issues relating to your 17 A. Yes. 17 visit to pstein's home? 18 Q. Okay. And I think you told us you were 19 the maitre di. Same thing? 20 A. Yes. 21 Q. And you're working 40 hours a week? 22 A. No. 22 -- well, let me 23 Q. How many hours a week are you working now? 23 strike 24 A. liveries. 24 , didn't disclose 25 Q. What's your, your average? 25 anything about Epstein, correct? Page 407 Page 409 1 1 A. Thirty-five. 1 A. I don't know. 2 Q. Are you considered a MI-time employee? 2 Q. All right. We'll, we'll get 3 A. Yes. 3 4 Q. And did you tell me you may have told I 5 'me, are you entitled — do you get benefits, health to your visit to Mr. Epstein's home? 6 benefits? A. No. 7 A. Yes. Okay. In fact 3 Q. And have you used your health benefits at 9 all? is that correct? o A. 13 A. Yes. 11 Q. All right. If I separate — and then let 12 me just focus this, is you testified at your last 13 deposition that you went to Mr. Epstein's house on 14 four occasions, correct? 15 A. Yes. 16 Q. Okay. One time you went upstairs and gave 17 Mr. Epstein a massage. And I'm not going to go 18 through the details. We've covered that on the last 19 deposition. But one time you went upstairs and gave 20 him a massage and you described what occurred, 21 correct? 22 A. Yes. 23 Q. The second time you took, I think, Jane 24 Doe No. 2, but you stayed downstairs — 25 A. Yes. • • 1.5.0..\)eu.-44.040.• 5 (Pages 406 to 409) PROSE COURT REPORTING AGENCY, INC.. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d471016-be89-4782-9d44-6af77636c37e EFTA01076725  Page 410 Page 412 1 Q. correct? know how to describe it. Just scared. I was scared. .2 The third time you took I.L., but you 2 Q. Okay. You don't know what you were scared 3 stayed downstairs. 3 of or why you were scared, but you were scared — 4 A. Yes. 4 A. !just got a feeling inside — 5 Q. And the fourth time you went, you — to Q. La me, let me finish the question. If I 6 • Mr. Epstein's house; you took Jane Doe No. 4 at her .6 understand your answer, you were scared; you were 7 request. :7 fear, fearful? 8 A. Yes. g A. Uh-huh. Yes. 9 Q. Okay. So if I refer to a one-time visit 9 Q. But you don't know why on the second 10 in my questioning to you, a one-time visit to 10 occasion? 11 Mr. Epstein's house that would be the one time that 11 A. It's a combination of things. 12 you went upstairs. Okay? • 12 ' Q. What things? 13 A. Okay. . 13 A. Not knowing the outcome, what's going on, just 14 Q. Because if I understand your testimony, 14 constant thoughts. 15 you're not alleging that anything bad happened when • 15 Q. Of what? Constant thoughts of what? • 16 you went back, or bad or inappropriate or traumatic 16 A. Many things; him, the house, the property, 17 at any time after the first visit, correct? 17 people, people that you know, staff. 18 A. No. 18 Q. But no one had ever threatened you before 19 Q. Okay. Well, what do you allege was 19 at the house, had they? 20 traumatic about your taking Jane Doe No. 2 to 20 A. What do you mean? 21. Mr. Epstein's home on the second occasion? What 21 Q. No one had threatened you; that is, either 22 happened to you that you consider traumatic? 22 verbally or physically threatened you, had they? 23 A. Many things. 23 A. A threat could be all different sorts of 24 Q. Name one. 24 things to me. 25 A. Anxiety. 25 Q. Well, had anyone physically assaulted you Page 411 Page 413 1 Q. Okay. And why, because you took a good 1 at the house? 2 friend to Mr. Epstein's house to suffer, as you've . A. Yes. 3 described it, the same emotional trauma, 3 Q. Okay. Who? 4 embarrassment, humiliation that you experienced on 4; • A. Epstein. 5 your first occasion? 5 Q. So, you were physically assaulted on — 6 MR. MERMELSTEIN: Objection to form. 6 and were you struck or touched? 7 THE WITNESS: You lost me there. 7 A. Touched. 8 :. BY MR. CRITTON: 8 • Q. You were not physically struck in any way? 9 Q. Okay. Is, is your emotional — well, let 9 A. Not hit. 10 me strike that • . 10 MR. STEIN: Objection to form. 11 You said on — as a result of having been 11 BY MR. CRITTON: 12 at Mr. Epstein's house on a second occasion when you 12 Q. I'm cony? 13 didn't I think you didn't even see Mr. Epstein on 13 A. Not hit 14 the second occasion, did you? 14 Q. So, you went back a — to Mr. Epstein's . 15 A. No. H • house on the second time because you thought you . 16 Q. Okay. So, but you say you had anxiety as 16 might be physically assaulted?. 17 a result of going there? 17 A. I didn't say that. 18. . A. Yes. 18 Q. Okay. Well, if you thought you were going 19 Q. Okay. And what caused the anxiety? 19 . to be physically assaulted, or you were so scared as 20 • A. I don't know. 20 - you've just described, or so fearful as you've just 21 Q. Anything else other than anxiety on the ' 21 described, why then did you return to Mr. Epstein's . 22 . • second occasion? 22. house on the second occasion? 23 A. Fearfulness. 23 . A. Because I was young and I was vulnerable and I 24 Q. Of what? 24 • wasn't thinking. • 25 A. Just scared of 'List I don't know, I don't 25 Q. Well, but you were anxious, scared, 6 (Pages 410 to 413) (561) .832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthla hopkins (601 8d47t016•bo69-47a2.9d44.6af77636c37e EFTA01076726  Page 414 Page 416 1 fearful and thought that you might be physically . 1 and I don't remember, did you say you went into the 2 assaulted, and you still went to Mr. Epstein's house 2 • house ofyou did not go in the house? 3 on a second occasion, comet? 3 A. I didn't physically — like, I was by the 4 . MR. MERMELSTEIN: Objection to form.. The 4 pool, beach area outside. 5 first deposition covered in great length her 5. Q At that time did you feel anxious or 6 thoughts and feelings in going back the second scared? time. Tin not sure why we're revisiting all of 7 A. Yes. a that. 8 Q. Did you feel fearful or potentially 9 MR. CRITTON: Well, this isn't a first or 9 physically threatened? 10 second deposition. it's a completion of the 10 A. Yes. 11 first, the first and only deposition and Tin 11 Q. Okay. why? 12 allowed under tbe, the record -- 12 A. Because we were there forayer), long time. 13 MR. MERMELSTEIN: I understand, but ifs 13 Q. Well, did you ever see anyone that day 14 asked and answered many times. 14 when you went to the house? 15 MR. CRITTON: Okay. Fine. 15 A. No. 16 BY MR. CRITTON: 16 Q. And when Jane Doe No.4 came down, was 17 Q. You can go ahead and answer it 17 there anything — and I think, I think you've 18 A. • What's the question? 18 already said so, and I don't want to belabor the 19 MR. CRITTON: Cindy, would you read it 19 point, but she didn't Say anything or — to you that 20 back, please? 20 would have suggested that anything inappropriate or 21 (The requested portion of the record was 21 bad had occurred, did she? 22 read by the reporter.) 22 MtMERMELSTEN: Objection to form. 23 THE WITNESS: Yes. 23 THE WITNESS: No. 24 BY MR. CRITTON: 24 BY MR. CRITTON: 25 Q. . And is it your testimony that you were 25 Q. Okay. Did her appearance appear other Page 415 Page traumatized by having been at Mr. Epstein's house on 1 than normal to you? Let me rephrase that question. 2 a second occasion even though you never saw him? 2 Did -- from your observations, did 3 A. Yes. 3 everything seem to be okay with her? 4 Q. On the third occasion you went to 4 MR. MERMELSTEIN: Objection to form. 5 Mr. Epstein's house, were you, as well, traumatized? 5 THE WITNESS: I guess. • A. Yes. 6 BY MR. CRITTON: Q. Were you anxious, scared, fearful and felt 7 Q. And that was the last time you went to 8 physically threatened as well? 8 Mr. Epstein's house, correct? 9 A. Anxious and scared, yeah. . A. Yes. 10 Q. But not -- but not fearful, nor did you -- 10 Q. Why didn't you ever go again? 11 A. All of the above. 11. A. I don't know: 12 Q. — feel physically threatened? 12. Q. Did anyone ever ask you to go again? 13, A.. All of the above. 13 A. I don't remember. 14. Q. But, so my question then is — 14 Q. Pardon? 15 MR. MERMELSTEIN: Let him finish the 15 A. I don't remember. 16 question: 16 Q. Have you had an occasion to speak with 17 BY MR. CRITTON: 17 or Jane Doe No:2 since your last deposition? 18 Q. • So my question is: Why then did you go 18. A. Yes. 19 back on.a third occasion? 19 Q. With whom did you speak? 20 MR. MERMELSTEIN: Objection, asked and 20 A. 21 answered. • 21 Q. And when did yousee her? 22 THE WITNESS: I don't know. 22 A. I never saw her. 23 BY Mk CRITTON: • 23 Q. All right. You spoke with her, and you 24 Q. On the fourth occasion that you took Jane 24 did not see her, correct? • 25 Doe No. 4, or you drove Jane Doe No. 4, did you 25 • A. Comet. 7 (Pages 414 to 417) PROSE. COURT REPORTING AGENCY, INC.' Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 8d47fO15-be89.47a2-9d44.Saf77536c370 EFTA01076727  Page 418 Page 420 I 1 Q. On how many occasions have you spoken with 1 A. January. 2 her since 2• Q. Did she ever mention to you ever about 3 A. One. 3 being a Plaintiff, you being a Plaintiff in a 4 Q. -- February 19th, 2010, which was the 4 lawsuit against Mr. Epstein? 5 start of your deposition? 5 A. She asked me. • . 6 • A. One. 6 Q. And you told her? 7 Q. Did she can you or did you call her? 7 A. No. 8 A. She called me. 8 Q. Okay. So, why would she — and again, 9 Q. Subject of the conversation? 9 when she said out of the blue, she called you after 10 A. That she heard I had settled. 10 your first deposition, the start of your deposition 11 Q. Did she tell you who she heard that from? 11 and said, I heard you settled. And did you 12 A. No. 12 specifically ask her, and say where did you ever. 13 Q. And how did she know you were even a 13 hear I was even a Plaintiff or I had even filed a 14 Plaintiff? 14 suit against Mr. Epstein? 15 A. Good question. 15 MR. MERMELSTEIN: Objection, form. 16 Q. Did you ask her? 16 Assumes facts. You don't have to file a suit 17 A. I asked. Igo: Where did you hear this from? 17 in order to settle. 18 She goes: Oh, I was contacted by someone. 18 THE WITNESS: She -- what I just said to 19 Q. Did, did you ask her whether she was a 19 you prior, she heard that I had settled. AM I 20 Plaintiff in the case? 20 go, no, I don't know what you're talking about. 21 A. No. 21 BY MR, CRITTON: 22 Q. Okay. Do you know whether she is? 22 Q. And then she changed the topic? 23 A. No. 23 A. No. She kept asking, she's like, you don't 24 Q. She has a — and she didn't indicate one 24 have a lawsuit? No. 25 way or the other whether she was a Plaintiff? 25 Q. So she pushed the envelope; she pushed you Page 419 Page 421 1 A. Correct. I to find out whether you had a lawsuit against 2 Q. So, she calls you out of the blue. When 2 Mr. Epstein? 3 was the last time you had heard from her? 3 A. Yeah. 4 A. Prior — around her birthday which is in 4 Q. And you kept telling her no? 5 February. A. Correct 6 Q. Okay. So just before your deposition? 6 Q. Anybody else call you since your -- since 7 A. I don't know exactly when her birthday is. 7 the start ofyour last deposition, or the start of 8 Q. But sometime around her birthday you had 8 your deposition about you being a Plaintiffin a 9 spoken with her? 9 lawsuit? 10 A. Yes. 10 A. No. 11 Q. Topic? 11 Q. Do you know 12 A. Going to Tree's Wings. 12 A. Yes. 13 Q. Fm sorry? 13 Q. How do you know 14 A. Going to Tree's Wings. 14 A: School. 15 Q. Which is what? 15 Q. Friends with her? 16 A. Aber/restaurant. 16 A. No. 17 Q. She wanted you to come? 17 Q. And why nee You're saying that 18 A. Uh-huh. 18 emphatically. Is there a reason that you're not 19 Q. Yes? 19 friends with her? 20 A. Yes. Sorry. 20 A. I never heard good things about her. 21 Q. And did you go? 21 Q. From whom? 22 A. No. 22 A. People. 23 Q. All right. When's the last time you 23 Q. Who do you friends with? 24 ......jr saw her physically or in person? This is 24 A. She Went to I think She didnt 25 25 ,„...s.....2121hinL to.my sch think she was hanging out witha 8 (Pages 418 to 4 21) (561)• 832-7500 • PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkIns (601 Electronically signed by cynthia hopkIns (601 ed471015-be89-47a2-9444-6at77536c37e EFTA01076728  Page 422 Page 4.. and Jane Doe No. 7 at one point. you used it at all? 2. Q. Okay. Was she ever friends with Jane Doe 2 A. I went on there one time. 3 No. 4?, 3 Q. Okay. Did you put any information — did 4 •. :A.. I don't know. 4 you have to set up a profile? 5 Q. • And who told you anything bad about her? 5 A. That was already done. 6 A Just rumors. 6 Q. She had already done that for you? 7 Q. Okay. And what are the rumors? 7 A. Yes. 8 A. I donstimow. It was high school. 8 Q. And what, do you go on and was your 9 Q. So anybody can get a bad reputation in 9 picture on as well? 10 high school? 10 A. No. 11 A. Yeah. 11 Q. It was just some background information on 12 Q. Whether it's true or not, you have no 12 you? 13 idea? 13 A. Yes. 14 A. Correct. 14 Q. All right. Did you ever search the site 15 Q. All right. And did you say you had 15 at all, go on anyone else's site? 16 actually met her? 16 A. Yes. 17 A. Yeah. 17 Q. Did you see anybody you lilted? 18 Q. But you're not friends; you're just 18 A. No. 19 acquaintances? 19 Q. Computers, you have your own computer? 20 A. Not even that. 20 A. Yes. 21 Q. You just know who she is; she knows who 21 Q. Laptop? 22 you are? 22 A. Yes. • 23 A. Yes. 23 Q. What kind? 24 Q. You have an active Facebook? 24 A. Dell. 25 A. Yes. 25 Q. How long have you had it? Page 423 Page 425 Q. And you used to have MySpace,but that's 1 A. Since Christmas. 2 been canceled? 2 Q. And did you down — what did you have 3 A. Yes. 3 before that? 4 Q. The question was asked whether you're a 4 A. The Toshiba. number of any web site, dating web sites, and you 5 Q. Did you download — and how long had you 6 listed a fiend registered yourself for 6 had the Toshiba? 7 wealthymen.com. 7 A. Like my 19th birthday or 20th birthday. 8 A. Yes. 8 Q And before that, another laptop? • 9 . Q. Which of your good friends did that to 9 A. No, home, regular desktop. 10 you, for you? 10 Q When you got the Toshiba, that was a 11 Ltink it was. 11 laptop? 12 Q• M i? 12 A. Yes. 13 A. Yeah. 13 Q Did you download the infommtion that's on 14 Q. Okay. How did you find out that she had 14 your home computer onto that that was applicable to 15 done that? 15 you? 16 A. She told me. 16 A. No. 17 Q. And what did you say? 17 Q. Did your Toshiba, when you went from 18 A. Why would you do that? 18 Toshiba to Dell, did you download the information 19 Q. And she said? 19 from the Toshiba to the Dell? 20 A. Because you just separated from 20 A. No. 21 Q. But you've never used the site? 21 • Q. You started from scratch again? 22 A. No. 22 A. Yes. 23 Q. Never? 23 Q. 'And you run your My — Fm sorry, your 24 A. Not — no. Not like that, no. 24 Facebook from your Dell computer laptop? 25 Q. Well, excuse me: Never is never. Have 25 A. Yes. Lay 9 (Pages 422 to 425) (561) 832-7500 PROSE COURT'REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 Electronically signed by cynthia hopkins (601 6d471015-bei39-4732-9d44-6af77636c37e