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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-CIV-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
/
VIDEO-CONFERENCED AND VIDEOTAPED
COMPULSORY MEDICAL EVALUATION OF
JANE DOE NO. 5
Friday, November 20, 2009
9:18 - 6:55 p.m.
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
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1 APPEARANCES: 1 A. Okay.
2 On behalf of the Plaintiff 2 Q. This is probably going to be an all-day
3 JESSICA D. ARBOUR, ESQUIRE
MERMELSTEIN &14OROWITZ, PA. 3 thing. This is not an endurance test. So, at any
4 18205 Biscayne Boulevard 4 time you need to take a break, want to get a
Suite 2218 5 cigarette smoke, use the restroom, get some water?
6 A. Okay?
Pha e: 7 Q. It's not a problem. Just let me know.
6 E-mail: 8
7 A. Okay.
8 9 Q. And we'll stop the tape. The tape
9 ALSO PRESENT: 10 switches over about every two hours, so we kind of
10 11 have little built-in breaks any way.
11 D. 12 A. Yeah, she told me that
12 Paralegal, 13
Burman, Crftton, Luther & Coleman Q. Pm a, fin a psychiatrist I have been
13 14 asked to do what they call an independent medical
14 Sextet Quimby, Videographer 15 examination. This is in the context of the lawsuit
Visual Evidence, Incorporated 16 that's going on. I think you're aware of that.
15 17 A. Yes.
16
17 18 Q. Usually when you see a doctor, there is a
18 19 notion of confidentiality, that anything you say to
19 20 the doctor will stay in the room and not be reported
20 21 others. Since this is being done for the court,
21 22 anything you tell me may end up in my report.
22
23 23 A. Yes.
24 24 Q. A copy of my report will go to both
25 25 attorneys, and the judge may or may not see it. I,
Page 3 Page 5
1 EXAMINATION 1 you know, some of the mechanics I don't fully
2 2 understand.
3 DR. HALL Thank you. 3 A. Okay.
4 JANE DOE NO. 5: I sign here? 4 Q. But it's not confidential.
5 DR HALL: Yes, please. 5 A. Yeah, I understand that.
6 JANE DOE NO. 5: Is that it for this one? 6 Q. Also usually when you see a doctor, there
7 DR. HALL: Yep. That one is a little 7 is the assumption that the doctor is going to treat
8 redundant, but the rest of them there is 8 you. I'm not going to be providing treatment
9 differences. 9 recommendations.
10 (Interruption at the door.) 10 A. Yeah.
11 DR. HALL: Yes. 11 Q. Or follow-up, whatever, yeah?
12 THE VIDEOGRAPHER: Sorry to interrupt, 12 A. Yeah.
13 Doctor. Could you move the mic a little bit 13 Q. But I just want you to be aware of that
14 closer? 14 before we start.
15 DR HALL: You don't have to — the last 15 A. Okay. Understand.
16 one doesn't apply. 16 Q. Do you have any questions, concerns,
17 JANE DOE NO. 5: Yeah. 17 comments?
18 BY DR. HALL: 18 A. No.
19 Q. Now, live introduced myself a little bit 19 Q. No. Okay. How this works is we're going
20 before the depo got started and I overheard your 20 to kind of start, get some background information,
21 lawyer talking about speak slowly, clearly -- 21 kind of go through a lot of areas during the course
22 A. Yes. 22 of the day. And I will talk to you specifically
23 Q. — because it's being transcribed. So, 23 about the allegations of the episode of Mr. Epstein.
24 appreciate that. If you have any questions at any 24 And we'll have some testing at the end.
25 time, feel free to ask me. 25 A. Oka'.
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1 Q. All right. Usually around noon or I NW 1 A. No.
2 break for lunch and then come back 2 Q. Tell me about your family a little bit
3 A. Okay. . 3 A. Basically my mother and Mier got married,
4 Q. With all that said, could you tell me your 4 you know. I was born. And they got divorced. I was
5 name, please? 5 around the age of three. It's not accurate, but around
6 A. Jane Doe No. 5. 6 the age of three.
7 Q. Okay. When you were born? 7 Q. And it's okay to ballpark in general.
A. October 27th, 1986. 8 A. Yeah,1 will be. You will notice I'm so
9 Q. Okay. Where were you born? 9 horrible with memory like time frames.
10 A. West Palm Beach. 10 Q. Okay.
11 Q. Okay. Any problems, complications, 11 A. I'm throwing them out.
12 problems with your birth that you're aware of? 12 Q. If I need something a little more
13 A. No. 13 specific -
14 Q. So, not born early, born late? 14 A. I will by to put, yeah —
15 A. I was bom late, actually, yes. 15 Q. Put it together.
16 Q. Do you know how late? 16 A. Okay.
17 A. I was supposed to be born October 15th on my 17 Q. And if you are kind of ballparkinp„ just
18 father's birthday. 18 let me know it's arotmd this or --
19 Q. Okay. So it looks like roughly two weeks? 19 A. Twill. Trust me. I'm horrible.
20 A. Yes. 20 Q. Okay. So divorced around age duce?
21 Q. Okay. Did they have to induce your mom 21 A. Yes. She met my stepfather, which is
22 into labor or did it — 22 III They dated for a while. That's basically -- he's
23 A. No, she went into labor. 23 been with her fora long time. They are still together
24 Q. She went. Okay. Did you need to spend 24 today. I moved to Fort Lauderdale with them. You know,
25 any additional time in the hospital afterwards, 25 they got married at some point. I don't honestly
Page 7 Page 9
1 PICU, NICU? 1 remember the age. I was probably around ten —
2 A. No. 2 Q. Okay.
3 Q. Or were you even boa in a hospital? 3 A. — whenSot married. They had, you know,
4 • A. I was bon in a hospital. 4 a daughter, We moved to South Carolina after
5 Q. Okay. 5 Fort Lauderdale. And I didn't really like it in South
6 A_ That I'm aware ofno, I didn't hear of any 6 Carolina.
7 complications after. 7 Q. Roughly how old were you when you were in
8 Q. Did you meet your normal developmental 8 South Carolina?
9 milestones such as walking and talking on time? 9 A. Twelve.
10 A. Yes. 10 Q. Okay. Middle school age?
11 Q. Any significant childhood illness? 11 A. Yes, it was middle school. It was around --
12 A. As in medically? 12 think it was, actually it was eighth grade, I remember,
13 Q. Medically needed to be rehospitalized, 13 because I went to three different middle schools in
14 surgeries? 14 eighth grade.
15 A. The only thing I'm aware of is I had colic 15 Q. Okay.
16 when I was little. 16 A. 1went from Fort Lauderdale to South Carolina
17 Q. Okay. And everybody, or most everybody 17 and then back to Wellington --
18 gets the chicken pox. Things like that. 18 Q. Okay.
19 A. Yes. 19 A. -- because I moved with my father because like
20 Q. That's not what I'm — 20 me and my stepfather were having problems and also at
21 A. Yeah. Pve had that. 21 school there was a lot of girls that wanted to, I guess
22 Q. Okay. Were you ever in foster care or 22 you put it, kill me.
23 taken way from you're biological parents? 23 Q. Okay.
24 A. No. 24 A. You know, harm me in some way.
25 q. Or Da ever involveST 29brinirif?
- 25 Q. Pm going to want to hear more about that
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1 later. 1 Q. Okay. Was this his first deployment or...
2 A. Yeah, rough draft. So I moved in with my 2 A. Yes. I mean, he's had little deployments like
3 father at the end ofmy eighth grade year. So this is 3 a month here, three weeks there, but this is his
4 my third middle school I'm attending now. And it was 4 first —
5 hard for me because I was close with my mother. And I 5 Q. Longterm.
6 moved with him, but he was gone a lot because he worked 6 A. — long deployment.
7 seven days a week. Now he's working six, but he was 7 Q. How long has he been in for?
8 working seven days a week and he wouldn't get home until 8 A. Four years this April, and he still has one
9 around, you know, 6 to 8:00 at night. 9 more year.
10 Q. Okay. 10 Q. Is he going to re-enlist or is he looking
11. A. So, and he was a single parent. And it was me 11 on —
12 and my brother with him. He has custody over my 12 A. He is -
13 brother. 13 Q. - various things?
14 Q. Okay. 14 A. - not sure because the economy is so
15 A. And basically I lived with him from there on 15 horrible. He would lace to become a
16 out. 16 firefighter-paramedic, but the economy is so bad at the
17 Q. Are you still with him now? 17 moment that everybody is waiting in line to do that, and
18 A. No, I'm mauled. So, actually right now I am 18 he is thinking about re-enlisting.
19 staying at his house because my husband is in the 19 Q. Okay.
20 military. So, he is going to be back in three weeks. 20 A. So, it's not for sure yet.
21 Q. Okay. What branch of the service? 21 Q. And how long have the two of you been
22 A. Navy. 22 married?
23 Q. Okay. And is he over in a combat zone or 23 A. Almost four years this December. No, three
24 is he just on -- 24 years. Pm sorry. Three years this December.
25 A. Yeah. 23 Q. Okay. So, is he — I guess you met him
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1 Q. -- regular ship deployment or... 1 before he went into the Navy?
2 A. Yeah. He is on a regular ship deployment. I 2 A. I've known him since — I met him actually the
3 mean, he's been to, you know, to Bahrain and Dubai, 3 first day I went to middle school when I went back to
4 things like that. But he is on his way back as of now. 4 Wellington.
5 He is not stopping at any more ports, but he has been in 5 Q. Okay.
6 the combat zone. Stufflike that. 6 A. I've known him since I was IZ 13, whenever I
7 Q. I'm trying to remember, that's considered 7 went back to middle school in West Palm, Wellington.
8 what, Zone 5 or Fleet 5 of the Navy, that area? 8 Q. All right. So, jumping back I think I got
9 A. 'have no idea. 9 more into the current family than kind of the —
10 Q. No idea? 10 A. Yeah.
11 A. I don't know. Pm not really sure about all 11 Q. — the original family there, but thank
12 that 12
13 Q. What type of ship is he on? 13 A. You're welcome.
14 A. He is on the USS Batten. 14 Q. Whatever the opportunity presents. How
15 Q. Okay. Is that a supply ship, frigate? 15 old is your mother?
16 A. Ifs a — 16 A. I think she's 45. Pm really terrible.
17 Q. Cruiser? 17 Q Approximately 45?
18 A. Ifs the — give me a second. For the 18 A. Forty-five, yeah.
19 helicopters the -- 19 Q. Has she had any health problems?
20 Q. Helicopter carrier? 20 A. She's had a couple lumps, but nothing
21 A. Ifs a carrier. 21 cancerous.
22 Q. Okay. How long was his deployment for? 22 Q. Okay.
23 A. It's been about, I'm guessing. I haven't even 23 A. But no.
24 averaged it out, but six to seven months. It's been a 24 Q. How did she deal with the lumps issues?
25 while. 25 A. My mom is the type of person, she would rather
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I not know. But I basically convinced her to go because 1 Q. I apologize.
2 cancer runs in my family. 2 A. That's okay. But she doesn't have her at the
3 Q. Okay. What do you think of the new 3 moment anymore.
4 guidelines on mammography and all that? 4 Q. Okay. So, how many is there biologic
5 A. As in - 5 kids, I mean you are related to by mother or father?
6 Q. Oh, they — 6 A. None. By both my mother and father, non::
/ A. Sorry. 7 Q. No.
;3 Q. They just have the recommendations on A. They are all step.
9 breast cancer screening come out. 9 Q. All step. Any half?
10 A. Oh, did they? 10 A. Wait.
11 Q. (Inaudible.) 11 Q. Half is one parent.
12 A. I wasn't even aware of that. 12 A. Fin sony. Half, they are all half, not step.
13 Q. Yeah. Now they are debating on what the 13 Pm sorry.
14 proper op to do testing is — 14 Q. Not a problem.
15 A. Oh, really. 15 A. I'm a little tired today.
16 Q. — and therapies and all that, so. Okay. 16 Q. And again at any time if you misspeak and
17 So, you kind of encouraged mom to go get checked 17 you need to correct, that's —
18 out? 18 A. Yeah, which I will probably will be doing
19 A. Yes. 19 Q. Please do. So, what are the names of your
20 Q. Okay. And fortunately it's come back 20 siblings?
21 negative? 21 A. Okay. There is on my father side, that is
22 A. Yes. 22 M. He is 20 — I'm giving a guess because I have
23 Q. Is that something that was worrisome for 23 never met him. He is 27. I do speak to him on
24 you or... 24 Facebook. He's 27. And he is by my father. And I'm
25 A. Yeah. You know, my mom means a lot tome. 25 not sure who the woman is. My dad didn't know about him
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1 We've had our hard times but every mother and daughter 1 until he was like eight years old.
2 does. 2 Q. Okay.
3 Q. What's she do for a living? 3 A. Then there is me with my mother. And then
4 A. She actually used to work at a law firm for 4 there is my brother He is going to be 18. He
5 Searcy & Denney — 5 is 17 at the moment.
6 Q. Okay. 6 And then there is my sister,=. And
7 A. -- Scarola, Barnhart & Shipley. 7 she lives in Colorado. And she, I'm guessing. is
8 Q. I'm sorry. I missed that last part. 8 nine. She's around the age ofnine. I see her
9 A. Oh, it's Searcy, Denney, Scarola, Barnhart & 9 usually in the summers.
10 Shipley. That's the law firm. It's all the names. 10 Q. Okay. So, that's all on your father's
11 Q. Gotcha. I'm not familiar with that firm. 11 side?
12 Is that down here? 12 A. Yeah.
13 A. It's in West Palm Beach. I'm not sure. It 13 Q. Okay. And Mom's side?
14 was a while ago. I'm not sure exactly where it is. Pm 14 A. My mom's side is me and then there is
s
i
15 horrible with directions. 15 which she's around the age of eight or nine
16 Q. That's — 16 also. Then there is which is adopted by the
17 A. Yeah, but it's around the West Palm Beach 11 same woman as her it's her half-sister.
18 area. 18 Q. °r n
19 Q. Okay. 19 A.
20 A. But now she is a stay-at-home mom because she 20 Q.
21 has, including me, four kids. But she has three young 21 A. Yes.
22 kids. 22 Q. Okay.
23 Q Okay. 23 A. And then there which is two.
24 A. She recently was fostering her step-sister's 24 Q. Okay. And is your mother's or
25 daughter. 25 adopted or...
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1 A. No, that's my mother's. And then there was 1 depression?
2 M, but she's not with her anymore because she was 2 A. It was when she was still in South Carolina.
3 fostering her. 3 Fm going to say late 30's maybe.
4 Q. Okay. was the foster? 4 Q. Okay. And I know you were relatively
5 A. Yes. 5 young, but do you remember kind of what symptoms you
6 Q. Okay. 6 noticed in her, or what others have told you was
7 A. She was about one and a half. 7 going on?
8 Q. Now, I have a large number here, so 191 8 A. She basically told me she was just, you know.
9 just kind of do a blanket statement. 9 stressed out to the max. And, you know, it was really
10 A. Yes. 10 hard for her at this age and stuff like that.
11 Q. How are they health wise, any major health 11 It wasn't — I wasn't with her at that
12 problems in any of them? 12 point. That was when I was living with my father
13 A. No. 13 and she was like calling me.
14 Q. Any major psychiatric problems or minor 14 Q. Okay.
15 psychiatric problems? 15 A. And letting me know things, and I think they
16 A. My brother, he had ADD. 16 prescribed her Xanax —
17 Q. Which brother? 17 Q. Okay.
18 A. s,Pri =, on my dad's side. 18 A. — which is to calm her down but she's not on
19 Q. Okay. How old was he when that 19 anything anymore. She's better.
20 was diagnosed? Again ballpark 20 Q. And how long of a period did that go on
21 A. I think when he started grade school. Maybe 21 for?
22 middle school. 22 A. I honestly have no idea.
23 Q. Okay. 23 Q. Okay.
24 A. I'm guessing. I really honestly am not sure. 24 A. I mean, it wasn't for a long, long time. It
25 Pm guessing middle school. 25 was —
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1 Q. Is he on any medicines that you're aware 1 Q. Are we talking a week, three weeks?
2 of or... 2 A. Oh, it was —
3 A. He was on Ritalin. That's all I know. I 3 Q. a month?
4 don't know what he is on now. I'm sure he is on 4 A. It was about a couple months to maybe a year.
5 something still. 5 I'm guessing. I mean, I wasn't there at that point.
6 Q. Okay. Did it help? 6 She didn't cligents it at all with me. She didn't want
7 A. Yes. He's very intelligent. It makes him 7 me to worry, but, you know, she did bring it up a couple
3 concentrate. I also have ADD. 8 times.
9 Q. Okay. 9 Q. Then it was more than just a bad week or
10 A. I'm on Addaall which is why I'm in school at 10 two?
11 the moment, because I usually don't take it when I'm not 11 A. Oh, yeah.
12 in school. 12 Q. Okay. Was she ever on any antidepressant
13 Q. We had to do this on a Friday. I assume 13 medications like Zolotl, Prone, Lexapro, Effexor,
14 that's because of the school schedule and childcare? 14 CymbaIta?
15 A. Yeah, I don't have school on Friday, so... 15 A. I think she was, but I have no idea which one.
16 Q. All right. And your mother, does she have 16 Q. Okay. Put down possible antidepressant
17 any mental health problems or... 17 A. Yeah. I'm not, yeah, rd have no idea if she
18 A. No. 1 mean, she has been through her -- she's 18 really was. I mean, I'm sure she took something because
19 been depressed, you know, at some point. 1 mean, 1 19 she mentioned something 1 don't remember.
20 don't know if you want to consider that mental health. 20 . Q. Tell me a little bit about your step-dad.
21 She just got depressed because she was overwhelmed with 21 M. you said?
22 all the kids at her age. 22 A. Yes.
23 Q. Okay. 23 Q. Is it okay if I refer to him that way?
24 A. But that's basically it. 24 A. Yeah. That's what we call him, but is
25 Q. Roughly how old was she when she had the 25 his name.
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1 know, he's fractured my eardrum that he's hit me so hard
2 A. But we call him M. A little bit about him. 2 because I said I didn't like him. You know, here and
3 He is younger than my mom. 3 there. It wasn't like a constant thing but it was when
4 Q. Okay. 4 he lost his temper. There was a couple times.
5 A. And I don't — I think ifs by four or five 5 Q. Did you ever need to go to the hospital?
6 years. I'm not sure. Maybe two or three. I really 6 A. No. I went to the doctors for my ear though.
7 don't know. I'm guessing. 7 Q. And how is your hearing now?
8 In the beginning when my morn first got 8 A. It's fine. It was just a fractured eardrum
9 with him, I personally didn't like him because I was 9 they said. But it, I couldn't hear out of -- I think
10 very close to my mom. And I felt, you know, like, 10 it I'm not sure — I think it was my right ear for
11 jealous I guess you could say because it wasn't just 11 lilce a week, but it's fme now.
12 me and her anymore. It was him, you know, coming 12 Q. Any other, and you said it's doing fine
13 because she didn't bring him around that much in the 13 now. I sometimes talk a little lower. I can
14 beginning. Then we went — you know, when I was 14 occasionally mumble. So, if I say something you
15 three. 15 don't understand, let me know.
16 But, you know, she brought him more 16 A. Okay.
17 around, you blow, a little bit later in life. And I 17 Q. I'm happy to repeat it.
18 was jealous, and I really didn't like the fact that 18 A. Okay.
19 he was there. But, you 'mow, [guess they got 19 Q. You can raise the volume if need be.
20 serious at some point. And we just — he, he was 20 Okay. You said it wasn't like a daily thing, but 1
21 young at the time. He was in his 20's Pm guessing, 21 mean, can you give me a sense, I mean, was there
22 and I think he was — 22 l0ce major episodes or was there a lot of minor
23 Q. Not to sound funny but when you say 23 little episodes that —
24 guessing, that can mean a lot of different things to 24 A. Yeah, it was, it was mixed between both. It
25 a lot of different people. So, if it's kind of like 25 was, there was minor episodes. It's not where he hit me
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1 a good estimate -- 1 but he would, you know, scream and brake things and
2 A. Uh-huh. 2 throw my phone and stuff like that. And there was also
3 Q. — is that what you mean by guessing 3 times where he would, you know, hit me to where he got
A. Yes. 4 my mom to the point of, you know, asking me, do you want
5 Q. — or do you mean I am totally just 5 me to leave him.
6 pulling a number out of the air? 6 Q. Okay.
7 A. He was in his 20's. 7 A. And I just basically told her, I don't, I
8 Q. Okay. 8 don't care anymore. I really don't. I mean, I didn't
9 A. So, Pm — 9 know what to do because I knew she wanted to be with
10 Q. So, I will assume when you say he is 10 him, and I didn't want to, like, break up them, but also
11 younger, I think, I'm guessing, that that's your 11 on the other hand I was absolutely miserable.
12 best estimate? 12 Q. Okay.
13 A. Yes. 13 A. And that's one of the reasons I moved out of
14 Q. Okay. I just -- 14 South Carolina also. It wasn't just the school. It was
15 A. He was in his 20's. And we didn't really get 15 a combination of, [just, both. So I just — because I
16 along because, I mean, he's told me that basically I was 16 was supposed to go back to South Carolina like for the
17 luggage to him. 17 following school year because they, you know, it was
18 Q. Okay. 18 more about my mom had it more about the school issue.
19 A. Baggage, luggage, because he was young and he 19 There was also to me about him and, you
20 just wanted my mother and I was just a tagalong. He has 20 know, she didn't say very much to him, so I just
21 told me that to this day. I mean, he has apologized for 21 never went back to South Carolina
22 it, but he was physically abusive. 22 Q. Okay. Again, yeah, I'm just — so it's
23 Q. Okay. 23 kind of like you went down to visit your father for
24 A. Not to the point where he like, you know, 24 the summer and --
25 every day beat me. But when he lost his temper, you 25 A. Not to visit. I went to finish my eighth
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1 grade school year. 1 that's now they are all young. But he spanks them but
2 Q Okay. 2 he treats them completely different now that you
3 A. Okay. I was supposed to go back for my high 3 know, I mean he's, he's apologized to me and sat me down
4 school in South Carolina, but I didn't go back 4 and told me that he was wrong with the way he raised me.
5 Q. Okay. We're talking about the incidence 5 But I guess he was raised like that by his
6 of domestic violence with your stepfather. The 6 father. Actually, it was worse the way his father
7 serious episodes, are we talking like five, ten, 15, 7, raised him, so that's all he knew I'm guessing. And
8 20? 8 now that he has his owl kids, he sees now that's
9 A. It was probably, I mean, it wasn't — 9 horrible the way he raised me.
10 Q. Thirty, 100. 10 Q. Have you forgiven, or is it just you
11 A. No, it wasn't that many. It was like really 11 appreciate the apology but —
12 horrible, like — there is one in particular that I 12 A. I mean, ifs — I still feel like he keeps me
13 remember that when I said I didn't like him over the 13 111w this, you know, from the family. You know, he — I
14 phone, he was listening in on the conversation, he like 14 daft know. That's the way 1 feel. He says otherwise,
15 broke down the door and like ripped my TV out of the 15 but there is just little things that make me feel like
16 wall and threw it down the stairs and basically, beat 16 he would rather me not be at his house, in his home like
17 the crap out of me, and that's when he fractured my 17 living when I moved here for instance and I was staying
18 eardrum. 18 with them first when my husband first left on a
19 Q. Okay. How old were you when that 19 deployment.
20 happened? 20 Q. So, you actually went back up and stayed
21 A. I was in — it was my -- I think it was the 21 with them for a little while and --
22 beginning— oh, ballparking it? 22 A. Well, they are here now.
23 Q. Ballparking it. 23 Q. Oh, they're back now?
24 A. Seventh or eighth grade year in middle school 24 A. So, they are in Boca. I'm sorry I should have
25 in Fort Lauderdale. 25 told you that.
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1 Q. Okay. And again, just so I got the 1 Q. No, that's fine.
2 timeline straight, you were in Fort Lauderdale since 2 A. They're back. They're in Boca.
eighth grade. Moved up to South Carolina You were 3 Q. How often do you go over and see them?
<l in South Carolina for less than a year — 4 A. I go, I go over there probably once every two
5 A. Oh, less — 5 weeks or something. You know, he is usually at work and
6 Q. And came back 6 I go to see my mom because she's a stay-at-home mother.
A. It was a couple months. 7 She's actually watching my daughter today.
8 Q. Couple months. 8 Q. Okay. Now, what type of work does he do?
9 A. Because 1 did eighth grade in Fort Lauderdale. 9 A. He is a general manager at a golf course.
10 1 went to South Carolina, did eighth grade. And then 1 10 It's a — it's in, off of Commercial.
11 went to Wellington and did eighth grade. 11 Q. Okay.
12 Q. Okay. 12 A. Coral Ridge Country Cub.
13 A. So, yeah. 13 Q. And you said you get along well with your
14 Q. And this happened before you left, though? 14 mom now?
15 A. Yes. It was in Fort Lauderdale. 15 A. Yeah. We get along. I mean, don't get me
16 Q. Okay. Was there any abuse between your 16 wrong, we have our differences like every mother and
17 mother and, and =7 17 daughter does. You know, I have my opinion. She has
18 A. (Witness shakes head.) 18 hers. And you know, we get into it sometimes but it's
19 Q. Okay. So, he never hit her? 19 about stupid things. You know.
20 A. No. 20 Q. And can you give me an example?
21 Q. Did he ever hit your brother or any of the 21 A. Example. This is, you know, actually recent.
22 other children? 22 They are very and they don't believe in lying
23 A. Those were all his kids. 23 to their children and telling them there is a Santa
24 Q. Okay. And did he hit any of them? 24 Claus when it's about Jesus's birthday.
25 A. I mean, he spanks them now, you know, because 25 .Q. Okay.
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1 A. So, my uncle is coming down but he tells his 100 percent know.
2 son that he is -- you know, Santa Claus is real. 2 Q. Okay.
3 My mom feels the need if his son asks my 3 A. I'm very bad with those dates.
4 mother if Santa Claus is real, she's going to tell 4 Q. So, closer to II than 16?
5 him no. And I told her it's not her place to tell 5 A. Yes.
6 somebody else's son that Santa Claus isn't real. 6 Q. Okay. And again it's okay to ballpark.
7 That's the parents' place. And she's like, well, 7 If I need something more specific —
8 it's my home. So, that's a conflict. Something 8 A. Yeah.
9 like that. Very minor but I give my opinion. 9 Q. — we'll work through it.
10 Q. No, l appreciate the example? 10 A. Ifs so hard for me to do dates really.
11 A. Yeah. 11 Q. Do you know why they got separated the
12 Q. Was there ever any abuse from mom? 12 first time?
13 A. No. Mentally when I was younger, you know, 13 A. I have no idea. I don't know.
14 she — she lost it on me here and there a lot, you know, 14 Q. Do you know why your mother and your
15 for stupid things. I guess I should have said yes, but 15 biological father got separated?
16 I don't, you know. 16 A. Yes. Because he was doing drugs and cheated
17 Q. Well, let me — any physical abuse? 17 on my mother.
18 A. There was one time that she got upset with me 18 Q. What drugs was he doing?
19 because her and my stepfather split up. I didn't tell 19 A. Cocaine.
20 you this either, but her and my stepfather split up at 20 Q. Okay. Was he selling or just using or...
21 one point before they got married, and she dated this 21. A. Both.
22 guy. And I didn't like him at all, and he went to 22 Q. Did any of that come home with him or...
23 Chicago. This is just a scenario of what happened. 23 A. My mom said the time that she left him was
24 I was walking in the streets of Chicago 24 when I got a hold of a bag of coke, and that's when she
25 and she got pissed because I wasn't listening to 25 was fed up. Now, this is from what she told me. You
Page 31 Page 33
1 her. So she took the in the bathroom and hit me a 1 know, there's her side, his side, and the truth, so...
2 couple of times to be like, you 'mow, wake the hell 2 They told me two different stories.
3 up, and what are you doing walking in the streets of 3 Q. And what's his version of events?
4 Chicago? 4 A. She was jealous and he couldn't deal with it,
5 Q. Okay. Was it like a spanking or slapping 5 so that's why they split up. So, I mean, I don't blow
6 in the face or - 6 if he wants me to know or — I mean, he is foe now, you
7 A. She hit me with her hands a couple of times 7 know, he's --
8 and slammed my head against the wall. But it was just, 8 Q. How much clean time has he had?
9 she was really mad. 9 A. He's a while. I mean, this is when I was
10 Q. And you were roughly four, five — 10 younger. I don't,1 don't know honestly. lean% tell
11 A. No. 11 you. I have no idea, but I mean, I remember scenarios
12 Q. — ten, 20? 12 when I was in Jupiter visiting him, and I, I mean, not
13 A. No. I'm going to say between, like — I said 13 that I knew at that time, but I look back and I'm like,
14 they got married when I was around ten. So, maybe like, 14 he had to be on drugs the way he — it was just, he
15 you know what, they got married when 1 was around ten. 15 didn't give a crap about anything, you know. He would
16 They got married twice. I'm sorry. There's things that 16 throw my brother in a bed and my brother would cry to
17 pop back up to me. 17 sleep. And 1 would just — it was horrible. But that's
18 They got married when I was ten. They got 18 when I was -- I have no idea what age. I was yotmg. It
19 a divorce and they got re-married in a courthouse, 19 was when he lived in Jupiter, Jupiter Farms.
20 which I totally forgot about. 20 Q. Okay.
21 Q. Okay. 21 A. But fora while now he's — a great job, makes
22 A. You're going to see I do that. I forget and 22 good money.
23 then I start remembering. And I think it was when they 23 Q. I forgot to ask about him. So, what, what
24
25
got their divorce. So Pm guessing around the age of
like 11 or so. Pin, I'm ballparlcing it. I really don't
24
25
is his job?
A. He's the finance director of a, two
1
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1 dealerships, car dealerships. 1 still comes into his life, I'm going to pick you up next
2 Q. Okay. 2 week; never shows up. She's back in jail. Ifs I can't
3 A. He still works a lot. He works six days a 3 imagine what he goes through and he tries to act now
4 week. tie's a hard worker. He's dating somebody but he 4 like, oh, I don't give a, you know, whatever he uses
5 hasn't been married since my mother. 5 these words, and I know it hurts.
6 Q. Okay. 6 Q. Yeah. All right. So, and just an
7 A. I don't {mow if he has a commitment problem or 7 interesting history. And thank you. So, I'm just
8 what it is. But, you know, he's basically raised my 8 trying to make sure I've got it and haven't skipped
9 brother. My brother's mom turned into a druggie. And I 9 anything.
10 don't know if she got that, started from my father. But 10 A. Yeah.
11 she was a real nice woman when I knew her, but she's 11 Q. So, dad's working at a car dealership,
12 literally a druggie, disgustingly and -- 12 staying in his house right now?
13 Q. Do you have any dealings with her or... 13 A. Uh-huh.
14 A. I'm sorry?
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