EFTA00723105.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME 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, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 Illi. - 6:10 lli. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Reported By: Pamela J. Sullivan, RPR, FPR, CLR Prose Reporting Agency, Inc. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772-15521 Electronically signed by Pamela Sullivan (501.333-772-1552) 41151584-6022-4050-b036-0423518c2lb5 EFTA00723105  Page 131 Page 133 APPEARANCES! 1 - -- 6 On behalf of the Plaintiff, /env Doe: 2 INDEX 3 BRAD J. EDWARDS. ESQ1.7IRE ROTHSTEIN ROSIDIPELDT ADLER 3 -- Las Oles City Cant, Stitt 1650 4 DIRECT CROSS REDIRECT RECROSS 401 East Las Clef Soignee:I Fan Lsoladde, Florida 33301 5 JANE DOE 6 BY MR. curroN 5 Onel,alfoftherktadaa, Jeffrey Epstein: 7 ROBERT D. CRITTON.M. ESQUIRE BURMAN, CIUTTON.LAD1TER & COLEMAN, LLP 303 Ewan Boulevard EXHIBITS MARKED Suite 400 North Pahn Beech, Florida 33401 9 10 11 12 On Wu for the Defendant. Jeffrey Eptlein- 11 DESCRIPTION PAGE 13 JACK ALAN GOLDBERGER, ESQUIRE 12 ATTERBURY. GOIDEERGER & WEISS'S t1 250 Auendon Mesa Sou& Deft:odic:Ws No. 5 163 Suite 1400 13 (Order) 15 Were Palm Bach, Florida 334014012 14 On behalf of Plantar inRelated Cass No. 0540469 14 17 ISIDRO M. GARCIA, (RE 15 GARCIA LAW FIRM 18 224 Dame Steel, Suite 16 West Palm Beach, Pkwitla 33401 17 19 561.532.7732 [email protected] 18 20 On behalf of lone Dons 1throne, 19 21 20 ADAM D. HOROWTTZ, ESQU 22 MERMELSTERS & HOROW117M7.. 21 18205 Mayne Boatyard 22 23 Suite 2218 Ml&M Floral 33140 23 24 24 25 25 Page 132 Page 134 1 On behalf of the Plaintiff= 1 PROCEEDINGS 2 JACK P. HILL, ESQUIRE 2 SEARCY DENNEY SCAROLA BARNHART & SHIPLEYS. 3 (Continued from Volume lof the same day.) 3 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 4 VIDEOGRAPHER: Back on the record at 11:52. 4 5 BY MR. CRITTCIN: 6 Q. Ms. Jane Doe, I have in front of you, I 5 On behalf of the B.B.: 6 ADAM J. LANGNO, ESQUIRE 7 think, Malt 4 what 1 know to be Exhibit 4, which LEOPOID RUM 8 is the declaration of Ms. Villafana. Do you see that? 7 2925 PGA Boulevard, Suite 200 9 A. Yes. Palm Berndt Girders, Florida 33410 a 10 11 Q. And I will represent to you, and I think you told me you don't know who she is; correct? 9 12 A. Yes 13 Q. And on Page 2, she says is, "I" — in her 11. ALSO PRESENT: 14 declaration says — the first sentence says: "I am the 12 Jeffrey Epstein, via video conference Stan Sanders, Videograpber 15 Assistant US — United States Attorney, assigned to the 13 16 investigation of Jeffrey Epstein," and then — "and the 14 17 case was investigated by the Fetal Bureau of 15 Investigation, FBI," et cetera, et cetera. 16 18 17 19 Do you see that up at the top? 18 20 A. Yes. 19 21. Q. Okay. That's who she says she is. And then 20 21 22 she's — on Page 7 of her declaration she says: "I 22 23 declare, under penalty of perjury, pursuant to 28 USC, -23 24 Section 1746, that the following is true and correct, to 24 25 the best of my knowledge and belief." And then she 25 2 (Pages 131 t o _124 ) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333772.1662) Electronically signed by Pamela Sullivan (501-33347211652) 4415168d4k22-4c60-130364423618e2fb6 EFTA00723106  Page 135 Page 137 1 signs this on 9th day of July 2008, and then it purports 1 Do you see that? 2 Lobe what is her signature above her printed name. 2 A. Yes. 3 Do you see that? 3 Q. And then it says: "The FBI's Victim Witness 4 A. Yes. 4 specialist sent a letter to Jane Doe," you, "on May 30, 5 Q. All right. If I go to paragraph three, down 5 2008." 6 at the bottom it says here -- there's a reference to 6 Do you see that? 7 Jane Doe, Page 3 — sorry — Page 2, paragraph 7 A. Yes, I do. 8 three. Are you with me? 8 Q. Okay. You indicated that you were -- when I 9 A. Yes. 9 asked you earlier today — excuse me — when you had 10 Q. Go up — not — not the footnotes. You brow 10 given your statements and you said, emphatically, you 11 what a footnote is; don't you? 11 were three and a half months pregnant; correct? 12 A. Yes. 12 A. Yes. 13 Q. All right Go up from the footnotes, then 13 Q. All right You wouldn't dispute 14 one, two, three lines up it says: "Jane Doe was 14 Ms. Villafana's and the FBI's agents' statement that 15 identified." 15 they interviewed you on May 28th of '08; correct? 16 Do you see that? 16 A. No. 17 A. Yes. 17 Q. And I think you — well, I don't think. Let 18 Q. You are that Jane Doe; correct, Jane Doe? 18 me start again. 19 A. Those are my initials. 19 You've told us you've testified that you 20 Q. And -- and if you read in fact, I should 20 only talked with the FBI on one occasion, and that one 21 probably have you just — why don't you read to yourself 21 occasion had to have been May 28th of '08; correct? 22 paragraph three, because there's a reference to 22 A. Yes. 23 Mr. Edwards and three of his clients, C.W. and 23 Q. Okay. And that was the first time, at least, 24 Jane Doe. Do you see that? 24 that you had told any governmental authority, state, 25 A. Yes, I do. 25 Federal, local, that you had been to Mr. Er:stain's home; Page 136 Page 138 Q. Okay. would be -- 1. correct? 2 A. Yes. 2 A. Yes. 3 Q. — you would assume. C.W. would be E.W., and 3 Q. And if you go to Exhibit 5 — 4 you would have to be the Jane Doe; Jane Doe? 4 MR. CRITTON: And, Mr. Edwards, if you could 5 A. Yes. 5 help your client. 6 Q. Are you aware of any individuals that Miss - 6 MR- EDWARDS: I haven't seat an Exhibit 5 7 Mr. Edwards represents, other than you,a and E.W.? 7 S yet, I don't think. MR. CRITTON: It's — sorry. Exhibit 5 8 A. No. 9 Q. All right. Then it goes down — again, 1 9 to Exhibit 4. My fault. 10 take you back where it says: "Jane Doe was identified 10 MR. EDWARDS: Okay. Just to show her where 11. via the FBI's investigation in 2007, but she initially 11 it is. It's -- if you look up at the upper, 12 refused to speak to investigators." 12 right-hand corner, there's a May 30th letter. 13 Do you see that? 13 MR. CRITTON: May 30,2008, letter. les: 14 MR. EDWARDS: Object to the form. 14 "Dear Jane Doe," and it's been redacted in part. 15 THE WITNESS: Yes, h do. 15 MR. EDWARDS: Let's see if I can get there, 16 BY MR. CRITTON: 16 and then ru get her there. 17 Q. And Mat's true; you did refine to speak with 17 BY MR. CRITTON: 18 them? 18 Q. If you look — you're now looking at 19 MR. EDWARDS: Object to the form. 19 Exhibit 5 to our Exhibit 4; correct, to Ms. Villafana's 20 THE WITNESS: Yes. Yes, l did. 20 declaration? 21 BY MR. CRITTON: 21 A. Okay. 22 Q. All right. And then it says: 'Jane Doe's 22 Q. And you see it's a letter from the US 23 status as a victim of a Federal offense was confirmed 23 Department ofJustice. It's dated May 30th, 2008, and 24 when she was interviewed by Federal agents on May 28th. 24 it says: "Dear Jane Doe," because your name has been 25 2008." 25 redacted; correct? 3 (Pages 135 to 138) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela moan (5014334724 (552) Electronically signed by Pamela Sullivan (601-333-7724552) 4f151584-6c22-4c50-b036o423618c2fbS EFTA00723107  Page 139 Page 141 1 A. Uh-huh. Yes. 1 does that refresh your recollection that the FBI told 2 Q. And is this the Victim's Assistance Program, 2 you that you could file some sort of civil suit against 3 a letter that you said you received sometime after you 3 Mr. Epstein? 4 met with the FBI? 4 MR. EDWARDS: Object to the form. 5 A. Yes. 5 THE WITNESS: Yeah, they — they may have 6 Q. Okay. And I think you said — your your 6 mentioned something of it. 7 best recollection was within a watt, which is consistent 7 BY MR. CRITTON: 8 with this letter, which also then reconfirms that the 8 Q. Okay. So that — that refreshes your 9 FBI had to have met with you, as reflected in the 9 recollection that the FBI said, You know, you may want 10 declaration on May 28th, 2008, for the very first time; 10 to go get your own lawyer and bring a money — a civil 11 correct? 11 suit against Mr. Epstein; we're only criminal people? 12 A. Yes. 12 M. EDWARDS: Object to the form. 13 Q. All right. At the time that you received 13 BY MR. CRITTON: 14 this letter, 'think you also told us that you had not 14 Q. Does that refresh your recollection? 15 been represented, or you Mr. Edwards was not 15 A. Which document refreshes her recollection? 16 representing you at that time; correct? 16 Any of this? 17 MR. EDWARDS: Object to the form. 17 MR. CRITTON: No, I just quoted back to her 18 THE WITNESS: Yes, it was shortly after. 18 what she said to me. 19 BY MR. CRITTON: 19 MR. EDWARDS: Okay. Well, if you know the 20 Q. All right. If you then go down to Exhibit 7, 20 answer to what he's talking about, then answer it. 21 and it's easier to read. 21 THE WITNESS: They didn't — I know — I 22 MR. EDWARDS: Flip a few pages. 22 mean, I don't remember what exactly they said to 23 THE WITNESS: Here? 23 me, but they did mention that I should get a 24 MR EDWARDS: Keep going (inaudible). 24 lawyer. 25 THE WITNESS: Okay. 25 Page 140 Page 142 1 BY MIL CRITTON: I. BY MR. CRITTON: 2 Q. This is a letter also from the US Department 2 Q. All right. And that you might be able to get 3 of Justice. It's from Ms. Villafana. It's directed to 3 money? 4 Mr. Edwards. It's dated July 9th, 2008. 4 MR. EDWARDS: Object to the form. 5 A. Uh-huh. 5 THE WITNESS: I don't — leant remember 6 Q. And it says, Re: Jeffrey Epstein/S, and then 6 them saying anything to me about money. 7 there's a redaction, ft/Notification of Identified 7 BY MR. CRITTON: 8 Victim. 8 Q. Then why would you need a lawyer under these 9 Do you see that? 9 circumstances for any reason? You weren't — or did. 10 A. Yes, I do. 10 they indicate to you that you were a target of any 11 Q. Okay. Have you ever seen this letter before? 13. investigation? 12 A. I don't remember seeing this. 12 MR. EDWARDS: Object to the form. 13 Q. Now, having seen the affidavit, Exhibit 4, 13 THE WITNESS: Basically, they just told me 14 that is the declaration of Ms. V illafana that reflects 14 that what happened to me was wrong, and that I 15 that you met with the FBI on May 28th, and consistent 15 should do something about it. 16 with your earlier testimony, that you got the victim's 16 BY MR. CRITTON: 17 assistance letter shortly thereafter, which we now know, 17 Q. Okay. And you understood that doing 18 from looking at one of the exhibits to the declaration, 18 something about it was filing a lawsuit against 19 was May 30th of '08. 19 Mr. Epstein and ask for money? 20 Does that in any way refresh your 20 MR. EDWARDS: Object to the form. 21 recollection how you got -- or from whom or how you got 21 BY MR. CRITTON: 22 the card to go find Mr. Edwards? 22 Q. Is that a fair statement? 23 A. Well, no. 23 A. Well, I wanted to have him prosecuted for 24 Q. Okay. And now, having seen the declaration 24 what he did, but I obviously can't do that. 25 in exhibits -- and the exhibits that we've identified. 25 Q. Because — because you know from your own 4 (Pages 139 to 142) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601.333-772.1652) Electronically signed by Pamela Sullivan (601.333.772-'1662) 4115158d-6c22-4c50-b036-e423618c2fb5 EFTA00723108  Page 143 Page 145 1 criminal experiences that it's either the State of 1 Third sentence says: "All three of those 2 Florida or the United States Government that prosecutes 2 clients were victims of Jeffrey Epstein's while they 3 people, not individuals; true? 3 were minors, beginning when they were 15 years old. 4 MR. EDWARDS: Object to the form. 4 Do you see that? 5 THE WITNESS: I don't understand. 5 A. Yes, I do. 6 BY MR. CRITTON: 6 Q. Okay. So Ms. Villafana, based upon her 7 Q. Well, you know that you can't prosecute -- a 7 knowledge and the interview or the conversation that she 8 citizen doesn't have the right to prosecute. It's — 8 had with the FBI and the information they had, have you, 9 ifs an arm of the Government, and you know from your 9 NB. and E.W. all being at least 15 when you first saw 10 own experience. That is, when you got in trouble with 10 Mr. Epstein do you see that, at least what's 11 the law, you know it was the State ofFlorida versus 11 represented in her sworn statement — 12 you; comet? 12 MR. EDWARDS: Object to the form. 13 MR. EDWARDS: Object to the form. 13 THE WITNESS: Yes, I can see what it says. 14 THE WITNESS: That's not something that I 14 BY MR. CRITTON: 15 specifically 'mew from my own experience, no. 15 Q. All right. Did the FBI at any time — well, 16 BY MR. CRITTON: 16 let me — let me ask this question: If the FBI -- if 17 Q. Okay. Well, well get to that a little 17 you told the FBI that you were 15 when you first saw 18 later. Let — let me go back to the discussions that 18 Mr. Epstein, based upon this declaration, does that now 19 you had with the FBI. I think you told me — well, I 19 refresh your recollection that you never went to 20 know what I wanted to ask you. If you go back to 20 Mr. Epstein's home for the first time until after you 21 Exhibit 4, Page 2 — 21 turned 15, which would have been sometime after June 22 A. (Witness complies.) 22 17th of 20037 23 Q. — same paragraph, paragraph three. It says: 23 MR, EDWARDS: Object to the form. 24 Attached hereto are copies of letters provided to 24 THE WITNESS: I remember specifically telling 25 Mister — or to Bradley Edwards, three el lects,.., 25 than and Jeffrey that INNIS 14 when I first met Page 144 Page 146 1 C.W. and Jane Doe. And then there's a 1 for the 1 Jeffrey, and I told him that 1 was 15. 2 footnote. 2 BY MR. CRITTON: 3 Do you see that? 3 Q. Okay. Well, but you would agree with me that 4 A. Yes. 4 at least Miss — the FBI and the US Attorney's Office 5 Q. All right. And, again, recognizing that 5 believed you were 15, based on something that you told 6 Ms. Villafana is a United States Attorney, and that 6 them; cone& 7 she's signing this declaration of oath under oath, based 7 MR. EDWARDS: Object to the form. 8 on her conversations that she had with the FBI -- at 8 THE WITNESS: It looks like that's what they 9 least that's what it purports to say — but go down to 9 believed. But they obviously misinterpreted what! 10 Footnote 1. It says: "Attorney Edwards filed this 10 told than, because I know what I told them. 11 motion on behalf oflane Doe, without identifying which 11 BY MR. CRITTON: 12 ofhis clients is the purported victim?' 12 Q. Would you agree with me that your 13 Did I read that correctly? 13 recollection back in 2000 -- May of 2008 was probably 14 MR. EDWARDS: Object to the form. 14 better than it is today 15 THE WITNESS: I don't know. 15 MR. EDWARDS: Object to the form. 16 BY MR. CRITTON: 16 BY MR. CRTITON: 17 Q. I want you to follow along. Did I just -- 17 Q. -- in September of 2009? 18 let me read it again. 18 A. What do you mean? 19 A. Oh I read it ahead of you. 19 Q. Well, would you agree that with another -- 20 Q ■ sorry? You're ahead of me? 20 let's see - with another 16 months having passed since 21 A. Yeah. 21 May of 2008, that your recollection as to the events 22 Q. Okay. Well, then, we'll just — let me go to 22 involving Mr. Epstein were better back in 2008 than they 23 the second sentence. It says: Accordinglywill 23 are now? 24 take — I will address facts related to C.W.,M. and 24 MR. EDWARDS: Object to the form. 25 Jane Doe. 25 THE WITNESS: No. 5 (Pages 143 to 146) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) 4f15158d-6c22.4c50-b036-e423618c21b5 Electronically signed by Pamela Sullivan (501-333-772-1652) EFTA00723109  Page 147 Page 149 1 BY MR. CRTITON: 1 Initially acquaintances, but eventually friends? 2 Q. Okay. You think your recollection is better 2 A. Yes. 3 now? 3 Q. Lets sec. Duncan Middle School, where you 4 A. No, I think it's pretty much the same. 4 would have been there sixth, seventh and eighth? 5 Q. All right. You told me the FBI -- well, let 5 A. No. I went there for sixth grade, and I 6 me strike that. 6 moved in seventh grade. 7 You said you told the FBI how you came to be 7 Q. Dial. stay there? 8 at Mr. Epstein's the first time; correct? 8 A. 1 daft know. 9 A. Yes. 9 Q. Where did you go for seventh grade? 10 Q. diaLin response to their question, you told 10 A. Okeeheelee Middle School. 11 them than. took you; correct? 11 Q. Is that because you moved locations where you 12 A. Yes. Yes. 12 were living? 13 Q. How many times did — did you go or dical. 13 A. Yes. 14 take you to Jeffrey Epstein's home? 14 Q. Okay. And in sixth grade you would have 15 A. One. 15 been - lets see -- sixth grade you would have been how 16 Q. Just the first time? 16 old? 17 A. Yes. 17 A. Eleven. 18 Q. And what dill. tell you about -- well, let 18 Q. Who were you living with — who were you 19 me strike that. 19 living with when you went to Duncan Middle? 20 You were friends within.? 20 A. My grandmother. 21 A. Yes. 21 Q. Ms. Brewer? 22 Q. And you say it was, at least your 22 A. Yes. 23 recollection today, is it was sometime in February, plus 23 Q. (Way. Who were you living with when you went 24 or minus a month, of '03? 24 to Okeeheelee? 25 A. Yes. 25 A. I was in between my grandmother and my Page 148 Page 150 1 Q. All right. When you went the first time - 1 mother. 2 or before ou went the first time, how long had you 2 Q. Is this during the time that is between 3 known.? 3 the sixth and the seventh grade, is this the time that 4 A. About three years. 4 your — that the incident occurred whore your father had 5 Q. And did you meet — how did you meetM.? 5 been charged with, in essence, murdering Joey? 6 A. I met her in the sixth grade at school. 6 MR. EDWARDS: Object to the form. 7 Q. Was she in your class? 7 THE WITNESS: It was summer before seventh 8 A. No. 8 grade. 9 Q. Is she older or younger, same age? 9 BY MR. CRITION: 10 A. I think she's a little bit younger, but she's 10 Q. Is that the reason that you were no longer 11 about the same age. 11 with your grandmother at that point in time, and why you 12 Q. You mean within a couple of months of one 12 went to Okeeheelee? 13 another? 13 A. I was with my grandmother. My grandmother 14 A. Yes. 14 moved because my mother wanted me to go to that school 15 Q. How about E.W., by the sixth grade did you 15 because she wanted the school to believe that I was 16 already know E.W.? 16 living with her. 17 A. No. 17 Q. She wanted you to go to Okeeheelee? 18 Q. Sot was the first person you knew? 18 A. Yes. She wanted -- I dont know who really, 19 A. Yes. 19 but she wanted somebody to believe that I was living 20 Q. What school was that? 20 with her, and not with my grandmother. 21 A. Watson B. Duncan Middle School. 21 Q. So mom said, come, you're staying with me, 22 Q. You were in the same sixth grade, just 22 and — and, ultimately, you went to Okeeheelee? 23 different classes? 23 A. Yes. 24 A. Yes. 24 Q. Did you stay in touch with II.? 25 Q. Did you know -- and you became friends? 25 A. No. 6 (Pages 147 to 150) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601433-772-1552) Electronically signed by Pamela Sullivan (501-333.772.1652) 415158(1-6c22-4c50-b0364423618atb5 EFTA00723110  Page 151 Page 153 1 Q. When you were in sixth grade, did you and 1 A. No. 2 used to play together? 2 Q. -- legal or illegal? 3 A. No. 3 A. No. 4 Q. Did you -- you just knew each other from 4 Q. Prescription drugs that — although they 5 school? 5 weren't your prescription? 6 A. Yes. 6 A. No. 7 Q. Did you ever meet..'s mom? 7 Q. Were you aware that.. was doing drugs -- 8 A. No. 8 A. No. 9 Q. Have you ever met..'s mom? 9 Q. — or alcohol back at that poim in time in 10 A. No. 10 sixth, seventh and eighth -- sixth and seventh grade? 11 Q. Has.. ever talked to you about her morn? 11 A. No. 12 A. No. 12 Q. How about eighth grade, were you — had you 13 Q. Has anyone ever told you that..'s mom is a 13 started drinking by the time you had hit eighth grade? 14 prostitute? 14 MR. EDWARDS: Object to the form. 15 A. No. 15 BY MR. CRITPON: 16 MR. EDWARDS: Object to the form. 16 Q. By drinking, I mean alcohol. 17 BY MR. CRITTON: 17 A. I — I had probably had a drink at some 18 Q. Have you heard that before today, that..'s 18 point. 19 mother was a prostitute? 19 Q. And had you started doing drugs by the time 20 A. No. 20 you were in the eighth grade, illegal drugs? 21 Q. Did you seell. during your seventh grade at 21 MR. EDWARDS: Object to the form. 22 all? 22 THE WITNESS: Yes. 23 A. No. 23 BY MR. CRITTON: 24 Q. How about eighth grade? 24 Q. All right. And what had you started? 25 A. We were living close to each other, so I met 25 Smoking pot? Page 152 Page 154 1 her again, yes. A. Yes. 2 Q. In eighth grade, were you still at 2 Q. All right. How about the Ecstasy, the one 3 Okeeheelee? 3 Ecstasy that you say you took, was that back in the 4 A. Yes. 4 eighth grade? 5 Q. But you were living closer now to.., so 5 MR. EDWARDS: Object to the form. 6 you started hanging out together or were friendly, 6 THE WITNESS: I was either 13 or 14. 7 became friends again? 7 BY MR. CAPTION: 8 A. We hung out once in a while, not a whole lot. 8 Q. So at least before you met Mr. Epstein, you 9 Q. And I think you said you never have been to 9 had at least done — you were drinking alcohol, you were 10 M.'s house? 10 using pot, and you had had Ecstasy; true? 11 A. No, I had never — 11 MR. EDWARDS: Object to the fonn. 12 Q. Back at that point in time. 12 THE WITNESS: Yes. 13 A. No. 13 BY MR. CR1TTON: 14 Q. Okay. Had she ever been — had you ever 14 Q. And had you also had Xanax by age 12,13, 14? 15 brought her over to your house or your grandmother's 15. A. No. 16 house or wherever you were living at the time? 16 Q. Did you ever smoke pot with..? And. 17 A. Yes. 17 talking eighth grade. 18 Q. And this would have been in what, in eighth 18 A Probably. about? 19 Q. And how about Ecstasy, were you or. — 19 grade now we're talking 20 A. Yes. 20 well, let me strike that. 21 Q. Okay. When you were in sixth grade and 21 Had you ever taken Ecstasy when.. was 22 around., did you and. ever drink alcohol 22 around? 23 together? 23 A. No. 24 A N 24 Q. Okay. Who were you with when you had the 25 Q. Did you ever do any kind of drugs together — 25 Ecstasy? racc 7 (Pages 151 to 154) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1652) 4,15158d-6c22-4c50-b036-e423618c211,5 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00723111  Page 155 Page 157 1 A. I was with an old friend. 1 A. She was friends with my friend. 2 Q. Who? 2 Q. She being who? E.W.? 3 A. Melissa. 3 A. E.W. was friends with my friend, Melissa, and 4 Q. What's Melissa's last name? 4 that's how I met her. 5 A. Kapusta. 5 Q. So you met E.W. through Melissa? 6 Q. • sorry? 6 A. Yes. 7 A. K-a-p-u-s-t-a. 7 Q. What age? 8 Q. Is she a friend of yours? 8 A. Thirteen or 14, maybe. S not positive. 9 A. I haven't seen her or spoken to her in a few 9 Q. And did you and E.W. hit it offright away, 10 years. 10 once you met through Melissa? 11 Q. Did she used to live out -- or in the area 11 A. No, we did not. 12 that you did? 12 Q. Did you ever smoke pot with E.W. back at that 13 A. Yes. 13 time? Because she was using drugs, too; wasn't she? 14 Q. Is she older, younger, or same age? 14 MR. EDWARD$: Object to the form. 15 A. Well, she went to the same school. We were 15 THE WITNESS: I don't know what she was 16 the same age. She was — she's a little bit younger, a 16 doing. 17 few months. 17 BY MR. CRITION: 18 Q. Okay. And when you would smoke pot, who did 18 Q. Okay. Are you saying she wasn't using drugs, 19 you get that Ran? 19 or you just don't know, one way or the other? 20 MR. EDWARDS: Object to the form. 20 A. I just don't know. 21 THE WITNESS: I don't know. 21 Q. But you've used illegal dings with E.W.; 22 BY MR. CRITION: 22 haven't you — 23 Q. Okay. Did you ever get it from your 23 MR. EDWARDS: Object to the form. 24 grandmother? 24 BY MR. CRITTON: 25 A. Na 25 Q. - from the time you met her? Page 156 Page 158 1 Q. Okay. Did you ever smoke pot in your 1 A. Yes. 2 grandmother's house? 2 Q. Now, when you first met E.W., where was she 3 A. Probably. 3 living? 4 Q. Okay. Was she aware that you were smoking 4 A. She was living with her mom in — 5 pot? 5 Q. Do you know what her morn's name is? 6 A. No. 6 A. Eva. 7 Q. after -- during eighth grade continued 7 Q. Did you ever go over to E.W.'s house, back at 8 to be friends? 8 that time period — 9 A. Yes. 9 A. I - 10 Q. Okay. When you say you went to Epstein's 10 Q. - seventh, eighth, ninth grade? 11 house for the first time, what grade were you in? 11 A. I went outside her house once. I — I had 12 A. I was in eighth grade for the second time. 12 never been inside ofher house. 13 Q. You repeated eighth grade? 13 Q. But you met her mom? 14 A. Yes. 14 A No. 15 Q. So you would have still been at — at that 15 Q. You never met her mom? 16 time at Okeeheelee? 16 A. I have met her mom, but at that point, no. 17 A. In the middle of that year 1 believe I left 17 Q Okay. Did you meet her mom after this 18 that school and went to an all girls school. 18 lawsuit has been filed? 19 Q. Was that Pace? 19 A. No. 20 A. Yes. 20 Q Did you meet her at what point in time? 21 But you were still — you would still see 21 A. I met her when I worked at IHOP. 22 M. from time to time? 22 Q. Did she come in as a -- was she a waitress 23 k Yes. 23 there, or did she — 24 Q. Okay. Was was E.W. around this time, as 24 A. She worked there. 25 well? Were you friends now with E.W.? 25 Q. Did she help you get your job? • ..4.••••••.••....laaa••••••••••....... 114• ••./.....• 8 (Pages 155 to 158) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (601-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) 4.16168tHic22-4c6043636-6423618c2k6 EFTA00723112  Page 159 Page 161 1 A. Yes. 1 and you were hanging out with..? 2 Q. And was that when you were living with E.W.? 2 MR. EDWARDS: Object to the form. 3 A. Yes. 3 BY MR. CRITTON: 4 Q. Okay. That was when you were living with 4 Q. You were friends — were friends with..? 5 E.W. at the apartment with Jessie? 5 MR. EDWARDS: Object to the Porn. 6 A. Yes. 6 THE WITNESS: Yes. 7 Q. And when — was there anybody else living 7 BY MR. CRITTON: 8 there at that apartment with you, Jessie and E.W. during 8 Q. And at that time that M. first approached 9 that few months that you were there in 2006? 9 you, were you aware that E.W. — whether or not E.W. had 10 A. No. 10 been to Mr. Epstein's home? 11 Q. And that's when you met mom — mum — E.W.'s 11 A. I didn't know fora fact, no. 12 mother? sorry. 12 Q ESOrrY? 13 MR. EDWARDS: Foam 13 A. II did not know fora fact. 14 THE WITNESS: Yes. 14 Q. And what did — what did III. tell you? 15 BY MR. CRITTON: 15 A. About going to Jefft E ins house. 16 Q. And did E.W. say, you need to get a job, you 16 Q. What did — what did . raise with you? 17 know, why