EFTA00724010.pdf

Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NQ.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- 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 DEPOSITION OF Friday, February 12, 2010 2:09 - 2:52 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 Job No.: 1231 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-f430-4b0a-bb09-1)035b310829d EFTA00724010 l EFTA00724011  Page 2 Page 4 1 APPEARANCES: 1 me know and I will explain it for you. 2 Cm behalf of the Plaintiff. 3 SWART S. MERMELSTED4, ESQUIRE 2 A. Okay. MEFtMELSTE1N & HOROWITZ, P.A. 3 Q. If you want to take a break during the 4 18205 Biscayne Boulevard 4 deposition, just let me know and you can take a Suite 2218 5 break. If during the deposition you recall 3 Miami, Phone: 6 something and you think you need to correct an 6 E-mail: 7 answer or supplement an answer that you have already Oa behalfof Defendant: 8 given me, just let me know and you can do It. 8 MARK T. LUTTIER, ESQUIRE BURMAN, CRHION. LUI 1ibR & COLEMAN, I.LP 9 There's no tricks. 9 303 Banyan Boulevard 10 A. Okay. Suite 400 11 Q. Its a pretty informal procedure. If you 10 West P *da 33401 Thorpe. 12 need something, just let me know. 11 E-mail: 13 Are you represented by a lawyer today? 12 14 A. He's my lawyer's witness. 13 14 15 Q. What? 15 16 A. Asa witness, he is my lawyer. 17 Q. So, Mr. Mennelstein is your lawyer? 16 NO EXHIBITS MARKED • •• 18 A. Yes, sir. 17 19 Q. Do you know Jane Doe No. 4? 18 20 A. Yes. 19 20 21 Q. When did you first meet Jane Doe No. 4? 21 22 A. October '08 or September '08, I think. 22 23 Q And what were the circumstances when you 23 24 24 met her? 25 25 A. We was dating. Page 3 Page 5 1 PROCEEDINGS 1 Q. I mean how did you run into her? 2 2 A. I met her with some of her friends at a 3 Deposition taken before Cynthia Hopkins, 3 restaurant, like a restaurant bar. 4 Registered Professional Reporter and Florida 4 Q. Do you remember what restaurant bar it 5 Professional Reporter, and Notary Public in and for was? 6 the State of Florida at Large, in the above cause. 6 A. Tski bar. 7 7 Q. 8 Thereupon 8 A. 9 IMa 9 Q. Do you remember who the friends were? 10 having been first duly sworn or affirmed, was 10 A. I think one of her friends was that v.as 11 examined and testified as follows: 11 it. 12 DIRECT EXAMINATION 12 Q. Wouldthatbea 13 BY MR. LUTTIER: 13 A. Uh-buh. 14 Q. Can u tell us your name, please. 14 MR. MERMELSTEIN: You have to answer yes 15 A. 15 or no. You have to answer verbally because she 16 Q. Mr. have you ever been deposed 16 is taking everything down. 17 before? 17 THE WITNESS: Okay. 18 A. Excuse me? 18 MR. MERMELSTEIN: So, if you say uh-huh or 19 Q. This process, have you ever had a 19 nod your head, it doesn't work. 20 deposition taken before? 20 THE WITNESS: Okay. 21 A. No. 21 BY MR. LUTTIER: 22 Q. Okay. You understand you're under oath? 22 Q. Whatllow date of birth? 23 A. Yes. 23 A. 24 Q. I am going to be asking you questions. If 24 Q. S9. that makes you how old? 25 ou don't understand one of my questions,just let 25 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430.4b0a-bb09-b035b310829d EFTA00724012  Page 6 Pay E: 1 Q. 1. You ever been married? 1 this, do you all live together right now? 2 A. No. 2 A. Me and Jane Doe No. 4? 3 Q. Getting ready to get married? 3 Q. Yes. 4 A. Considering. 4 A. Yes. 5 Q. I am not going to tell what Jane Doe No. 4 Q. Where do you live? 6 said. 6 A. I 7 A. Yes. 7 Q. W tfa address? 8 Q. Do you plan on getting married to Jane Doe 8 A. 9 No.4? 9 Q. s ”a Me ent? 10 A. Yes. 10 A. Yeah. 11 Q. Okay. Any time frame? 11 Q. Is that one that you have been in? 12 A. No. 12 A. It's a condo. I own it. 13 Q. Then can I assume from that that your 13 Q. Condo. 14 relationship and hers is pretty good? 14 A. Yeah. 15 A. Yes. 15 Q. And were you living there before you met 16 Q. You had a couple of rocky bumps in the 16 Jane Doe No. 4? 17 road? 17 A. Yes. 18 A. Yes. 18 Q. And after you met her in and around 19 Q. There was a El thing in the 19 September of'08, did there come a time that she 20 past? 20 moved in? 21 A. What was that? 21 A. Was there what? 22 Q. There was a a 22 Q. Did there come a time that she moved in 23 A. Yes, sir. 23 with you after September of '08? 24 Q. Has that an all been smoothed over? 24 A. Yes. 25 MR. MERMELSTEIN: Objection to font'. 25 Q. And do you know about when that was? Page 7 Page 9 1 THE WITNESS: Yes. 1 A. After I think. it was right before 2 MR. MERMELSTEIN: If I make an objection. stmt & 3 it's to the form of the question just for the 3 'hat would be when she front El 4 record. You've got to answer the question 4 5 unless I tell you not to. 5 . es. 6 THE WITNESS: Okay. 6 Q. Was she still at when you were dating 7 BY MR. LUITIER: 7 her tally? 8 ,Have, have you spent any time with= 8 A. Yes. 9 and Jane Doe No.4 together since you first 9 Q. Let's see. If it's September of'08, did 10 met her? 10 she still have 11 A. Yeah es. 11 A. !twits 12 Q. Is M still someone that comes around 12 Q. H y. So, you would have 13 a lot? 13 been dating since September of'08 until June of 14 A. No. 14 '09? Did you go down and watch hand 15 Q. Do you ;mow why? 15 stuff Ince that? 16 A. No. 16 A. A couple times. 17 Q. Do you know who Jane Doe No. 4's best 17 Q. Did you grow upa 18 friend is now? 18 A. Yes. 19 A. She's got a couple of friends in . Do 19 Q. Where did you go to school? 20 you vault the name? 20 A. High School. 21 Q. Yeah. 21 Q. i! would you describe your relationship 22 23 24 A. 4 . A. Yes. and Jane Doe No. 7 probably. And would that 22 23 24 with Jane Doe No. 4? A. Now everything is good. Q. Any problems that you've identified? 25 l:Z Are these People-.LeliaLbould atz:m 25 A. Now? 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-(430-4b0a-bb09-b035b310829d EFTA00724013  Page 10 Page 12 1 Q. Yes. What were they?e 1 A. At least seven times. 2 general problems that led to th 2 Q. Over about what period of time? 3 incident? 3 A. What is it now? February. Before Christmas 4 A. There was a lot of anger and confusion and 4 probably. Let's see. No, like November and December. 5 emotional, you know, a lot of stuff from the past and a 5 . ' uld have been after the 6 lot of emotional, you know, stress and problems. 6 incidence? 7 Q. And was that anger and confusion on her 7 A. What, that we went there? 8 part or on your part? 8 Q. Yeah. 9 A. Was it what? 9 A. U before. 10 Q. Anger and confusion on her part or on your 10 incident was 11 pert? Was she the one that was angry with you, or 11 ink you started 12 were you the one that was angry and confused? 12 going there befo 13 A. She was. 13 A. Yes. 14 Q. And how did you get all that resolved? 14 Q. Okay. How far before that? 15 A. We went to a counselor. My, I have a family 15 A. Probably a couple of months. 16 counselor we go to like my parents and, you know, it's 16 Q. ions do you think you had 17 for relationships as well, helps out. She was just able 17 bet'o 18 to talk to someone and let it, you 'mow, out what was 18 A. Five. 19 bothering her. 19 Q. With freguency were you 20 Q. !stills o so ing? 20 going bef 21 A. Huh? Yeah. , 21 A. Like weekly. 22 Q. And were you going to Mr.". before 22 Q. Okay. Hour sessions? 23 you ever met Jane Doe No. 4? 23 A. Yeah, yts. 24 A. No. 24 Q. What were the issues that were being 25 Q. How is it that you first came to go to 25 discussed as they related just to you and her? Page 11 Page 13 1 him? 1 A. Well, just her issues and problems that she 2 A. My mother. It's our family history like 2 has, you know, regarding her past. 3 started going there after I met Jane Doe No. 4 and me 3 Q. What were those? 4 and her went. 4 A. Just a lot of anger she had built up, and she 5 Q. Were you going to him after you met Jane 5 needed to let it out and talk to someone. 6 Doe No. 4 for issues that you had with your family? 6 Q. Anger built up about what? 7 A. Yes. 7 A. Her past. 8 Q. And was she initially going with you in 8 Q. Anything in particular about her past? 9 what we would calla supportive role just going 9 A. I didn't really get into everything. Like, 10 along with you while you talked about your issues in 10 she went by herself too, you know. 11 your family? 11 y herself prior to 12 A. Yes. 12 13 Q. And when she went did she just ride up to 13 A. Yes. 14 the office with you, or did she actually go in and 14 Q. Are you sure of ? The reason I 15 meet with you and the counselor? 15 ask you is we took Mr. de ' ' is 16 A. She came in. 16 agaits don't indicate visits prior to 17 Q. Okay. When she came in with those, with 17 ME? 18 you on those sessions, were those sessions just 18 A. That she never went there? 19 concerning issues that you had with your family? 19 Q. No. Prior to that date. He has got 20 A. Just everything pretty much. 20 records of visits after that date. 21 Q. Were there any issues about you and her 21 A. Before. 22 that were discussed when she went with you? 22 Q. w because you can relate 23 A. Yes. 23 it to die . 24 Q. How many times did you and she go 24 A. I would have to check my records and my. like, 25 together? 25 copies of my checks like when I wrote them. leant 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-14304b0a-bb09-b035b310829d Electronically signed by cynthia hopkins EFTA00724014  Page 14 Page 16 1 retail the exact date, you know. 1 A. Unh-unh. 2 Q. So, did you go alone sometimes to him? 2 Q. It was just that the two of you would 3 A. We would both go together and sometimes she 3 argue from time to time? 4 would go first and sometimes we would go together. 4 A. Yeah. It was basically, basically that, yeah. 5 Q. Were you working on issues of conflict 5 Q. When people use the word *basically; I am 6 between the two of you? 6 always suspicious because that indicates to me that 7 A. Some of that and the other with her. 7 there is something else. 8 Q. I know, but were you guys having problems? 8 A. Yeah. That's why we went there for, for the 9 1mean you guys were squabbling about something? 9 relationship and for, you know, so she could talk to 10 A. Just normal relationship issues, you know. 10 someone about what was, you know, what's bothering her. 11 Q. Did you, did you ask her to go up there 11 Q. So, do you — had something occurred that 12 with you? 12 you would come to the conclusion there must be 13 A. We both agreed on it. 13 something bothering her? 14 Q. Okay. What is it that made the two of 14 A. When she maid drink, she was just — anger 15 you — what was it that was the issue that made the 15 was built up in hor, you know. 16 two of you say let's go see this guy? 16 Q. Now, so was it that you made the 17 A. So, we can, you know, work out, work on our 17 observation that when she drank she was, for lack of 18 relationship, and so she could, you know, be happy and 18 a better term, an angry drunk? She would get angry 19 talk about her problems. 19 when she drank? 20 Q. Was there anything specific? For example, 20 A. She would take everything out on me. 21 I am just going to give you a hypothetical. Let's 21 Q. Okay. All right. You would be the bad 22 say you had a habit ofcoming borne and throwing your 22 guy? 23 laundry on the floor and that drove her nuts so you 23 A. Pretty much. 24 guys would fight about that So, you said we're 24 Q. Can you give me sort of an example of what 25 going to go see this guy and were going to say, 25 would happen? Page 15 Page 17 1 yeah, we're going to see this guy because I used to 1 A. Well, when she drank, she would just — I mean 2 have a habit about throwing my laundry on the floor 2 the only way she knew how to let it out was like go out 3 and it upset her. And that's what I'm talking 3 and drink and, you know, that she would think about her 4 about. 4 past and let everything out on me, you know. 5 A. It wasn't really about that. 5 Q. Would it be situations where the two of 6 Q. Well, I was using that as a — 6 you would be going out and drinking together, or she 7 A. Yeah. I know but nothing like that 7 would go out and drink and cane home and unleash on 8 Q. Did you guys find yourselves fighting 8 you? 9 about things? 9 A. Together. 10 A. Yeah. We argued about things, you know. 10 Q. So, you and she would go out to a bar or 11 Q. What kinds of things did you argue about? 11 something and start drinking? 12 A. You know like when we would fight, you know, 12 A. Everything would be fine and good and then as 13 just arguments. I can't recall exactly. 13 soon as — later that night that's when it would start, 14 4 I mean did she say you drank too much for 14 you know. 15 example? 15 Q. And there was at least the one time where 16 A. No. 16 it was a physical confrontation? 17 Q. Was there a drug use problem? 17 A. Was it what? 18 A. No. 18 Q. At least one time it was a physical 19 Q. Somebody said somebody used drugs? 19 confrontation? 20 A. No. 20 A. Well, just a bad argument. And I mean, l 21 never touched her or nothing like that, w. 23. Q. You wanted to go out too much? 22 23 A. No. Q. You stayed out too late? 22 23 24 ling . Well, I was referring to but she touched, A. Yeah. She might have yeah. 24 A. No. 25 Q. How long was it into your relationship 25 Q. Anything specific? 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia bodkins 6dc078c7-f430-4b0a-bb09-b035b310829d EFTA00724015  Page 18 Page that you noticed that when she drank she got angry? 1 A. No. A. Well, when we started getting serious like 2 Q. No. So, she would just come home and tell 3 after, like before Christmas like when, you know, we 3 you you were an asshole? 4 knew each other better and started caring about each 4 A. Come home and after drinking, and that's what 5 other more and getting 5 would happen. Q. W 6 Q. How much drinking were we talking about? 7 incident 7 Would she be drunk? 8 A. Before. 8 A. Yes. Q. Okay. All right. So, then it had to be 9 Q. Was one of the problems the quantity of 10 two or three months before Christmas? 10 alcohol being consumed? 11 A. Uh-huh. 11 A. Maybe like liquor, you know. 12 Q. So, when the incident -- 12 Q. I mean was one of the things, look, you 13 A. Yes. 13 need to cut back on the alcohol because when you 14 Q. So, w the Meld 14 drink you're, it's not fun? 15 happened o you-all had gotten 15 A. Yeah. Beer, I mean she drinks beer, you know, 16 into a deeper, more serious relationship? 16 she wasn't as bad, you know. But the liquor is when it 17 A. Yes. 17 really came out. 18 Q. And you had been going to counseling 18 Q. So she - did you observe then during that 19 because she would get angry when she drank? 19 relationship that you thought maybe she had an 20 A. Yes. 20 alcohol problem? 21 Q. Had she ever hit you up until that point 21 A. I didn't think that she had an alcohol problem 22 in time? 22 I just thought that she had a lot of things built up and 23 A. No. 23 she needed to talk to someone. Just like, you know, 24 Q. And how was her anger vented to you? 24 people, a lot of people have problems and they need to 25 A. Huh? 25 talk to someone and get help with what's bothering them. Page 19 Page 21 1 Q. By that I mean would she be yelling and 1 Q. After going to this counselor, did she cut 2 screaming at you? 2 back on the amount of alcohol she drank? 3 A. Yes. Just saying mean and nasty things. 3 A. Yes. 4 Q. Nasty things like what? 4 Q. Does she drink now less than she did then? 5 A. Like name calling and, you know, just saying 5 A. Yes. 6 rude things; name calling and saying rude things. 6 Q. Do you think that's been helpful? 7 Q. What kind of names would she call you? 7 A. Yes. 8 A. Well, just bringing up stuff from like -- it 8 Q Any belief by her that you had a problem 9 didn't, stuff that didn't make sense. She would just drinking too much alcohol? 10 say, you know, like, I am an asshole or stuff like that. 10 A. (Witness shakes head.) 11 And she would just, when she drank, you know, all the 11 Q. Anybody ever accuse you of drinking too 12 anger — I don't even know, it just came out on me 12 much alcohol? 13 ber-mke I was the only one there and that's how she knew 13 A. No. 14 how to let it out. 14 Q. Have you ever had a problem with alcohol? 15 Q. And anymore than calling you an asshole? 15 A. No. 16 A. Just, you !mow, I can't recall exactly, you 16 Q. When you would go out were you sober when 17 know, what she called me, what she said. 17 you came back? 18 Q. Would she accuse you of specific conduct 18 A. Sometimes. 19 or doing specific things? 19 Q. Can I assume that when you guys went out 20 A. No. 20 at least one of you were sober? 21 Q. For example, I am not saying this happened 21 A. Yes. I was driving but I had a drink or two. 22 but this is an example: She would get drunk and you 22 Q. But she would be as they would say 'a 23 would coma home and she would be mad and she would 23 couple of sheets to the wind"? 24 say, you know, you were looking at other girls in 24 A. Yes. 25 the bar, that kind of thing? 25 I. All right. Did ou attempt to • her to 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b035b310829d EFTA00724016  Page 22 Page cut back on the drinking before you started going to 1 drink? the counselor? 2 Q. Right 1 A. Yes. 3 A. Yes. 4 Q. And is that what drove you to the 4 Q. So, you have an idea of when people get counselor initially, not you individually but the 5 dmnit? 6 two of you together? 6 A. Yes. 7 A. What, the drinking? 7 Q. And when they can't remember things they 8 Q. Yeah. 8 did the night before? 9 A. Yes. That, the drinking and the, just the, 9 A. Yes. 10 you know, normal relationship issues, you know, that and 10 Q. That's generally an indication that they 11. basically, yeah, the drinking. 11 had too much to drink? 12 Q. Okay. In other words a person said, look, 12 A. Yes. 13 this alcohol is creating a problem; we have to 13 Q. And she was drinking at a level where she 14 figure out a way to get that under control. Is that 14 wouldn't remember what went on? 15 a fair statement? 15 A. Not all the time. 16 A. It wasn't all about the, about that, no. 16 Q. But sometimes? 17 Q. Well, was the result of going about that 17 A. Couple times. 18 and then the counselor dug in a little bit to try to 18 Q. And when, how much drinking are we talking 19 find out what was going on? 19 about? If you would go out, for instance, to a bar, 20 A. It wasn't about just the drinking. It was 20 are we talking about drinking two or three drinks or 21 about her past, you know, and why she would drink so 21 are you talking about we would be there for four or 22 much. 22 five hours? 23 Q. Okay. 23 A Like five drinks and then some shots, you 24 A. You know, and why she was doing the things she 24 know, probably four drinks depending on what she was 25 was doing. 25 drinking, either wine or sometimes beer or alcohol, Page 23 Page 25 1 Q. Other than drinking, what else was she 1 liquor. 2 doing? 2 Q. Plus shots? 3 A. lust, other than drinking, that's it. That's 3 A. Well, yeah, we would have a few shots, yes. 4 all she does. 4 Q. Was there ever any particular incident 5 Q. Did you ever ask her why she drank so 5 that happened when she was drunk that sod of caused 6 much? 6 )ou to say, look, stop, we have got to do something 7 A. No. She's just young, and when I was that 7 about this? 8 young, I drank a lot, too. 8 A. When she was drunk? 9 Q. What's your age difference? Let's see. 9 Q. Yes. 10 You're she's 10 A. Yes. I mean, the only time that like when I 11 A. She's 11 said that, you know,1 said, well, wait until the next 12 Q. So, she never said anything to you about 12 day so we can talk normally, you know, and then you know 13 why she drank or why she got angry at you after she 13 what were talking about and you remember what you're 14 drank? 14 talking about, because when people drink or when people 15 A. She never said anything. She never said why 15 are intoxicated, they don't, you know, remember what 16 she drank Like, she would start off normal, you know, 16 they say or what they do or you 'WOW. 17 and then after a while just she never -- she don't, she 17 Q. Okay. So, when you went with her and had 18 didn't remember what she was saying, you know. She 18 sessions with this fellow, those sessions that 19 don't even recall. 19 concerned your relationship, what did she tell the 20 Q. Can I assume that you have some experience 20 counselor? 21 with being around people that have too much to drink 21 A. I wasn't in, I wasn't in there maybe one time 22 that you acquired during your lifetime? 22 with her when she went for her personal matter, you 23 A. Do I? 23 know. 24 Q. Yeah. 24 Q. So, she kept that with the counselor? 25 A. Have I been around a bunch of people that 25 That was between than? J•44.1) 7 (Pages 22 to 25 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc075c7-1430-4b0a-bla09-h035b310829d EFTA00724017  Pace 2 6 Page 28 A. Yes. fora little bit. 2 Q. Did she ever share that with you? 2 Q. Okay. Did you go away to college 3 A. No. 3 anywhere? 4 Q. Did she ever tell you whatever the problem 4 A. I went to ■ for a semester and then came 5 was? 5 back 6 A. Well, I mean like you can read stuff online 6 Q. I understand that 7 B about, you know, what went on, and that's MI pretty much know. 7 8 a got . I was for five years and then I had a chance 9 Q. Are we talking about this fellow Jeffrey 9 o u iness ou know. 10 Epstein? 10 an arid stuff like that. 11 A. Yes. 11 Q. And that's you, in that business now is 12 Q. Is that — what you keep saying her past 12 you and your brother? 13 and stuff, is that what you're referring to? 13 A. Correct, yes. 14 A. Yes. 14 Q. What's the age difference between you and 15 Q. Is there anything other than her 15 your 16 involvement with Mr. Epstein? 16 17 A. No. 17 Q. Is he older or are you older? 18 Q. What has she herself told you about her 18 A. I'm older. 19 involvement with Mr. Epstein? 19 Q. So, you're guiding your younger brother 20 A. I mean, I read stuff online and like I really 20 through the business? 21 don't know everything, you know. 21 A. Yes. 22 Q. Is your only knowledge — 22 Sassume he grew up locally and did he go 23 A. I don't really want to, you know, like right 23 to High too? 24 now. 24 A. Yes. 25 Q. Is your only knowledge whet you read 25 Q. All right. So, you went through the usual Page 27 Page 29 1 online? 1 high school, post high school stuff. Does anything 2 A. Yes. 2 about Jane Doe No. 4's past color your opinion or 3 Q. That would be newspaper articles? 3 *cling towards her at all? 4 A Yes. 4 A. No. Q. How about any of these friends that you 5 Q. I mean you feel about her, you don't hold 6 said that she had, Jane Doe No. 7 comes to mind, 6 her past against her or anything like that? 7 would they talk to you at all? 7 A. No. 8 A. No. 8 Q Asa matter of fact do you, do you not 9 Q. Do you know whether or not Jane Doe No. 7 9 even care to know about her past? 10 had an experience with Mr. Epstein? 10 A. I would, I would like to, you know, 11 A Do what? 11 eventually. 12 Q. Do you know whether or not her friend, 12 Q. Whagaou know about her past? You knew 13 Jane Doe No. 7, had any interaction with 13 she played MI right? She was a high school 14 Mr. Epstein? 14 athlete? 15 A. No. 15 Yeah. Played wan to 16 Q. Okay. So, you grew up locally, went to 16 M. Grew up out there in 17 local high, played ball in school? 17 Q. Oot a scholarship at — 18 A. Yes. 18 aR . 19 Q. WhatdidvouDla 19 20 A. 20 A. Smart. 21 Q. For Hi 21 Q. You knew she had to be a pretty good 22 22 athlete to get a scholarship. 23 for kit lt . laY kir I PlaYed 23 A. Yes. 24 Q. And you played pretty good tell fora high 2; iYI -24 ;edlu z zosmaiS n? anclaglaYed 25 school student; you knew what that would require? 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. • Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 6dc078c7-1430-4b0a-bb09-b035b310829d EFTA00724018  Page 30 Page 32 1 A. Yes. 1 Q. And then did she come back and start 2 Q. And she's smart? 2 living with you again? 3 A. Yes. 3 A. ou know, ban ing out because we had a 4 Q. Were you an academically inclined 4 5 individual in high school? 5 ou to wait for that to got resolved? 6 A. Average. 6 A. Yeah. 7 Q. Okay. She was a hard worker, you figured 7 Q. You told th 8 that out? 8 9 A. Yes. 9 A. Yes. 10 Q. Okay. So, she kind of kept whatever she 10 Q. So, they decided not to eventually? 11 was talking to this counselor about between he and 11 A. Yes. 12 you. Did you ever have discussions with her about 12 Q. Okay. She drinks less now than she did? 13 any changes in her conduct or did it just kind of 13 A. Yes. 14 take place? 14 Q. She doesn't get angry at you anymore? 15 A. About what? 15 A. No. 16 Q. Any changes in her conduct or did she just 16 Q. I am going to guess she doesn't call you 17 start to change? 17 an asshole very much, occasionally, not a lot? 18 A. You mean now? 18 A. Sometimes. No. 19 Q. Yeah. From the time you guys first 19 Q. And my guess is you don't call her any of 20 started going until now. 20 those names? 21 A. Yeah. I mean, yes. She, she's changed, you 21 A. No. 22 know. Everything's, you know, everything is getting 22 Q. Okay. Nice lady? 23 better, you know. 23 A. Huh? 24 irin when you had the 24 Q. Nice lady? 25 incident — 25 A. Jane Doe No.4? Page 31 Page 33 1 A. We hadn't had any problems. 1 Q. I said she's a nice lady 2 Q. What led to that? Was that following a 2 A. Yes. 3 night out drinking? 3 MR. MERMELSTE : Objection to form. 4 A. Yes. 4 BY MR. LUTTJER: 5 . And I gather from reading 5 Q. What's your hope that you and she will get 6 that you were unhappy withil.fi et n t ought 6 married and have a family? 7 may she should go someplace other than your 7 A. Yes, one day. 8 apartment? 8 Q. Okay. Do you wan o have kids? 9 A. Yes. 9 A. Yes. 10 Q. And it appeared from 10 Q. You guys have talked about that? 11 that she had a different idea? 11 A. Yes. 12 A. Yes. 12 Q. So