EFTA00729386.pdf

Page 2 Page 4 I APPEARANCES: 1 The other thing is that I am going to be 3 On behalf &Jane Does I through 8: 2 asking some questions. In everyday language it's JESSICA ARBOUR, ESQUIRE 3 very common for the other person to start talking MERMELSTEIN & HOROWITZ... 4 giving an answer, before the question is even done. • 18205 Biscayne Boulevard Suite 2218 5 So, what I would ask is please allow me to finish my • Miami, l ' 6 question. And then I will allow you, in nun, to Phone: 7 finish your answer before I start the next question. E-mail: And this is just to make the court reporter here On behalf 9 MICHAEL J. PIKE, ESQUIRE 9 haPPy. Okay? BURMAN, CRTTTON, LUMER & COLEMAN, UP 10 A. Okay. 10 303 Banyan Boulevard Suite 400 11 Q All right. Please state your name for the 11 Wed Palm Florida 33401 12 record. 13 A. Rocky Ore2zoli. 12 14 Q. Can you spell that, please. 13 INDEX VOLUME I 14 15 A. R-o-c-k-y, last name is, 0 -r-e-24-z-o-1-i. 15 16 Q. Where is you current residence address? 16 WITNESS: DIRECT CROSS REDIRECT RECRO&S 17 A. Delray Beach, Florida. 17 ROCKY ORE22011 38 Q. What the address? 18 19 A. 19 BY MR. PE103 3 BY MS. ARBOUR 33 20 Q How long have you lived there? 20 21 A. Six years. 21 22 Q. Okay. And where are you currently 22 23 employed? 23 24 24 A. Technically I am self-employed. 25 25 Q. What do you do? Page 3 Page 5 ' 1 PROCEEDINGS 1 A. I am a soccer coach. 2 2 Q. Okay. Where do you work? 3 Deposition taken before Cynthia Hopkins, 3 A. I work for Team Boca which is a soccer 4 Registered Professional Reporter and Florida 4 association of Boca Raton. I am contracted to work for 5 Professional Reporter, and Notary Public in and for 5 them I should say. 6 the State of Florida at Large, in the above cause. 6 Q. Is that a full-time position? 7 7 A. Yes. 8 Thereupon, 8 Q. Okay. What schools do you work at? (ROCKY OREZZOLI) 9 A. I don't work at schools. 10 Having been first duly sworn or affirmed, was 10 Q. Was there ever a time that you were a 11 examined and testified as follows: 11 soccer coach for any particular schools, high 12 DIRECT EXAMINATION 12 schools and/or college? 13 BY MR. PIKE: 13 A. Yes. 14 Q. Sir, my name is Michael Pike. 1 teprrsaa 14 Q. What roil s 15 a gentleman by the name of Jeffrey Epstein in this 15 A. I svas at 16 matter. Have you ever had your deposition taken 16 ..) ? How long were you at • kay. 17 before? 17 18 A. No. 18 A. I was an assistant there for five seasons and 19 Q. Okay. The way that it works is the person 19 also was head coach for 11 seasons. I taught sonic 20 sitting to your right and to my left is a court 20 classes there as well. 21 reporter. The machine sties typing on doesn't 21 Q. Five seasons and 11 seasons, does that 22 understand nods of the head or uh-huh and unh-unh. 22 work out in years? 23 So, what I would ask you to do is give a verbal 23 A. More or less, y 24 response so that she could take it down on the 24 Q So, were you ata for more 25 machine there. 25 than ten years? 2 (Pages 2 to 5 PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-061-976-2934) cea14d6c-3516-4ced-842b-e31268082244 EFTA00729386  Page 6 Page 8 1 A. Yes. 1 are preserving it for the record if there is 2 Q. And did you teach did you coach both 2 any future issue with the court. It doesn't 3 boys and girls soccer? 3 mean that you don't have to answer the 4 A. No, just girls. 4 question. 5 Q. Was there ever a time you worked at any 5 THE WITNESS: I was just — I didn't lmow high schools teaching soccer? 6 if there was an exchange that I had to wait. 7 A. Yes. 7 MR. PIKE: So, if you understand my 8 Q. Okay. What high schools? 8 question, then go ahead and answer it. A. Spanish River High School. 9 THE WITNESS: I'm sorry. Could you repeat 10 Q. And what else? 10 that? 3 11 A. St. Andrews High School. Actually that's a 11 BY MR. PIKE: 12 middle school and high school. 12 Q. Sure. Did she excel as a player between 13 Q. Any others? 13 14 A. High schools? 14 MS. ARBOUR: Same objection. 15 Q. Yeah. 15 MR. PIKE: do ahead. 16 A. Actually it wasn't high school when I worked 16 THE WITNESS: She did well. She had a, 17 there. It was called Boca Academy which was way back. 17 she was technically a good player and l think 18 Q. Right. 18 she had probably nonnal ups and downs as a 19 A. But I taught middle school boys there. Now 19 player but she did well. 20 it's the Pinecrest School in Boca. 20 BY MR. PIKE: 21. Q. Was there ever a time at 21 Q. How would you describe her as a playa? 22 that you came to know a lady by the name of Jane I )c,c 22 A. Technically sound. She always had a very good 23 No. 4? 23 fitness level. We gave fitness tests to the players 24 A. Yes. 24 when they came in, and she always performed very highly 25 Q. Okay. How did you come to know her? 25 on those. She was a good — I mean, she was a good Page 7 Page 9 1 A. She played for one of the local club teams. 1 player. I don't know that — it's a very open-ended 2 When I say local it means within the county. And I had 2 question so I don't know specifically what you are 3 seen her la a few times and she had been interested in 3 asking. 4 so we recruited her to attend and play 4 Q. You had an opportunity to coach her for 5 soccer at 5 approximately four years, correct? 6 Q. Okay. What local club did she play for at 6 A. Yes. 7 the time if you recall? 7 Q. And as a coach what I am asking you is how 8 A. Palm Beach United. 8 would you describe this specific player? I think 9 Q. And what did Jane Doe No. 4 come to 9 you are going a good job: Technically sound, she 10 play soccer for 10 had a high fitness level...ism her 11 Ae.al And she 11 ability decree between 12 play 12 MS. ARBOUR Form. 13 Q. What type of player was she during those 13 THE WITNESS: In terms of technical 14 years? 14 ability? 15 MS. ARBOUR: Form. 15 MR. PIKE: Yeah. 16 BY MR. PIKE: 16 171E WITNESS: No. I mean, like I said, I 17 Q. Asa coach what type of player was she? 17 think she had normal, what I would view as 18 How would you describe her abilities? 18 normal ups and downs. She had times where she 19 A. Shc was a good player. 19 played well and she had times where she 20 Q. Did she aced as a player fromMa to 20 struggled. There were different games or so 21 OMNI 21 forth. But overall I think she was a good 22 MS. ARBOUR: Form. 22 player. I think she was coachable. I believe 23 MR. PIKE: It's a legal objection. When 23 she was a good teammate that took instruction 24 another lawyer says form, they don't like the 24 well. So, those are things that you would say 25 way that I am asking the question. So, they 25 you have a good player. 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601.051.9762934) Electronically signed by cynthla hopkins (601-051.9762934) cea14d6c-3516.4cec1-842b-e312de0822od EFTA00729387  Page 1,. Page 12 1 BY MR. PIKE: 1 case for those years it didn't. It was generally 2 Q. Was she on scholarship? 2 the first week of November. 3 A. Yes. 3 Q. Between the years Vital was Jane Doe 4 Q. Olcay. What type of scholarship if you 4 No. 4 in attendance regularly for practice between 5 recall? • 5 August and let's say November? 6 A. She was on an athletic scholarship. 6 MS. ARBOUR: FO1711 7 Q. Was it a full scholarship or partial 7 THE WITNESS: For the most part I think 8 scholarship? 8 so. I believe so. 9 A. Partial scholarship. 9 BY MR. PIKE: 10 Q. Was it 50 percent or 75 percent ride or 10 Q. That's your best recollection? 11 some other sort ofbreak-out? 11 MS. ARBOUR: Form 12 MS. ARBOUR: Form. 12 THE WITNESS: Yeah. I mean, if she might 13 THE WITNESS: It was a — I didn't do it 13 have missed a training or two, I would have to 14 by percentage, and I can't remember the exact 14 think about it. But, I mean, generally she was 15 percentage because I can't remember the exact 15 there. I mean there was, there was a time or 16 cost of the school and obviously the cost of 16 two, I think, during the freshman year. She 17 school increased each year. But her 17 might have missed practice. 18 scholarship was probably — it was in the 20's 18 BY MR. PIKE: 19 in terms of thousands of dollars and costs 19 Q. Was she one to repetitively miss practice? 20 upwards ofabout 40, probably a little more 20 A. No, not unless there was some reason, I would 21 now. So, it was more than half. 21 assume. 22 BY MR. PIKE: 22 Q. I see you brought some documents with you 23 Q. And h larshi remain the same 23 today. Is that your stuff there? 24 throughout 24 A. No. 25 A. Yes. And it increased which was a normal 25 Q. Did you bring any documents with you Page 11 Patin 14 I ' 1 thing that I did with the players if it was possible and 1 SEW? 2 there was no other issues. Issues would be if the 2 A. No, I did not 3 player was not going to school or they wore doing 3 Q. Did you review anything before your 4 something they were not supposed to be, but they would 4 deposition? 5 normally get small increases as the school increased as 5 A. !did not 6 well. 6 Q. Did you speak with anybody before your 7 Q. Did Jane Doe No.4 always get an increase 7 deposition about your deposition? 8 from 2005 to 2009? 8 A. I did not. My wife. Sony, my wife I spoke A. I believe so. 9 with. 10 Q. Tell me when the season starts for the 10 . Q. And did anybody from Ms. Arbour's office 11 female soccer team at from=to 11 call you to discuss your deposition? 12 12 A. No. 13 A. The players report for pre-season generally in 13 Q. Okay. When was the last time you have 14 the middle of August. It changes from year to year 14 been in contact with Jane Doe No. 4? 15 depending on the NCA mandate for each year but it's 15 A. Probably about a year ago. 16 generally about the middle of August. Could be a 16 Q. Okay. And how did you come in contact 17 little first, first two weeks of August. 17 with her at that time? 18 Q. Okay. And from August until when? 18 A. She called me. It was actuall right about 19 A. The season would conclude, usually the regular 19 this time. I had already left as of 20 season concluded the end ofOctober or the first week of 20 last So, I 21 November. And then if the team qualified for the 21 finished what would have been Jane Doe No. 4's senior 22 conference tournament, there would be additional games. 22 year, and they had their athletic banquet around this 23 And if they qualified for the NCA tournament, which in 23 time for all the sports. She had called me with just 24 this case we did not, that would be, it could 24 kind of a question. She had a conflict with her studies 25 potentially go all the way to December. But in this 25 and the banquet and she just wanted some advice. 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkIns (601-051-976-2934) ceal4d6c-3510-44)(1-842b-s3f2de0822ed EFTA00729388  Page 14 Page 1 .Q. What advice? 1 MS. ARBOUR: You're talking justIM? 2 MS. ARBOUR: Form. 2 MR. PIKE: Yes. 3 THE WITNESS: She had some final or some 3 THE WITNESS: September it would be 4 work due for finals or research papers that she 4 . either — because our games start usually by 5 was under pressure to finish. And she didn't 5 the end of August would be the games 6 know if she could attend the banquet. She just 6 competition dates. So if we had a competition. 7 didn't know what she should do. 1 was not 7. we wouldn't have practice. So just to clarify, 8 involved in the banquet at the time, but 1 8 we might have three days of practice, two 9 guess she just called just to ask my thoughts 9 games, and then two days off. 10 on it. 10 MR. PIKE: Okay. 11 BY MR. PIKE: 11 THE WITNESS: That was like it wouldn't 12 Q. Okay. Betwee actually let's take 12 be abnormal. 13 them year-by-year. Ii how many times would you 13 BY MR. PIKE: • 14 see Jane Doe No. 4 during, for practice during the 14 Q. Would that be the same for October and 15 August and November practice season? 15 November? 16 A. When the players first report, when the 16 A. Correct November until the first or second 17 team — well, when the team first reports for practice 17 week until the season concluded. 18 generally we would go twice a day because it's before 18 Q. And those same questions that I just asked 19 school, before the season starts. So, for August it's 19 you and that you answered, would that also be the 20 usually about two teams a day. 20 same for the years MM. ' 21 Q. For how many days? 21 A. More or less, yes. 22 A. At least for the first seven to ten days. 22 Q. Based upon. experience in coaching 23 Q. Okay. 23 Jane Doe No. 4 in how would you describe her 24 A. Now, there might be and there certainly would 24 personality? 25 be times where we went once a day. There are some times 25 A. I mean, she's, she's a good kid. She was Page 15 Page 17 ' 1 that we would have a day off. But without consulting friendly and she took the coaching well. And she was 2 the training calendar, I wouldn't know for sure which 2 friends with ha teammates and she worked hard 3 days those were. 3 Q. Do you recall how she did in school 4 once school starts generally, 4 wise? 5 which at was usually about the first week of 5 MS. ARBOUR: Form. 6 September, give or take, although they did change 6 THE WITNESS: She did well. I think she 7 . from that time, then generally we would train once a 7 had some terms where she did okay and some 8 day. The NCA mandates that once you're in season in a terms where she did wry well. school, you have to have a day off. So, typically 9 BY MR. ME: 10 there is always one day off The other days would 10 Q.. What do you mean by okay? be training days or game days. 11 A. I only, I only I daft remember her 12 Q. And when you say training days., I guess 12 specific G.P.A.'s but normally at the end of each term 13 what I am trying to kind of narrow down is how many 13 We always got a list of the players that got a 4.0 or 14 days would you, you know, give or take the days that 14 3.5 or 3.0 or better and a lot of players were always at 15 you have off, see Jane Doe No. 4 for practice 15 least a 3.5 or 3.0 or better. Sheaornetimes was in that 16 between August and November? 16 list and sometimes she was below a 3.0. 1don't 17 MS. ARBOUR: Form. 17 remember which terms those were. T think she did better 18 THE WITNESS: You're going to count half 18 in her later seasons than her earlier seasons. 19 of August, September, October. I mean, 19 Q. Was she always a varsity player? 20 possibly 60,70 days probably. 20 A. Yeah. There is no, that is no there is 21. BY MR. PIKE: 21 only one team at one intercollegiate team. There 22 Q. How many days a week is practice in 22 was no junior varsity team. 23 August? 23 Q. Was she a starting player? 24 A. Probably six. 29 . A. She started most of I would say the majority 25 Q. Okay. Same question for September. 25 of the time. 1 moaSfazakja•RaddifiXerla=“1,114 .m*Ze..-1.3 5 (Pages 14 to 17) • PROSE COURT REPORTING AGENCY,: INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkIns (601-051-9764934) cea14d6c-3516-4ced-S42b-e312de0822ed EFTA00729389  Page 18 Page 20 1 Q. And when you say that, do you mean from 1 when she was, if — like most of the kids on 2 2 the team,1say most of the girls on the team, 3 A. 1 11. was, the seasons were-, 3 I think she worked hard because it VMS 4 the fall o important to her, the soccer aspect was 5 Q. U . important to her. So, I always saw her as 6 A. There is a spring season but it's a different, working hard. 7 kind of a different, a little bit of a different animal. 7 The school work was a little up and down 8 It's a non-competitive season. 8 for her but I think she improved that as it 9 Q. BetweenIIIIIIIIIII6 there ever a time 9 went along. As far as ambitious I think 10 that you coached Jane Doe No. 4 on the off-season? 10 ambitious to be a good teammate and be a good 11 A. Well, like I said, we always had a spring 11 person and be a good soccer player and being a 12 season so typically in the in-state schools you have a 12 good student; most of the time I would 13 competitive, which a competitive part of the season 13 characterize that for her. 14 which soccer is the fall part. And then you have your 14 BY MR. PIKE: 15 non-competitive part where there is some different rules 15 Q. Was there ever • tin 'on saw Jar e 16 and regulations as to how often you can train, how much 16 Doe No. 4 unhappy in 17 you can train, how many games you're allowed to play. 17 MS. ARBOUR: Form. 18 So, the way we did it in the spring is 18 THE WITNESS: Yeah. lean, lean, I 19 typically the first month when the girls come back, 19 can't — I am tying to remember a specific 20 we would do conditioning and weight training and you 20 instance. I can remember a couple of instances 21 could do small group technical sessions. 21 where she seemed to be under pressure. I am 22 And then we would have a spring season. 22 just trying to think of the exact, the exact — 23 We would start around February 15th and go about the 23 MR. PIKE: Take your time. 24 first week of April where we usually train three 24 . THE WITNESS: dates. There was one 25 days a weelc. And we would have maybe a game on 25 incident I can actually remember it was Page 19 Page 21 1 weekends. And then once they were done in April, 1 probably during 2008 or 2009. It was kind of a 2 usually we let them just prepare for finals and that 2 freak thing. We were on a road trip and it was 3 kind of thing. 3 in the morning. We were staying in the Tampa 4 Q. You said Jane Doe No. 4 was friendly, she 4 area because we were playing one of the schools 5 had, she was friendly with her teammates and that 5 Tampa or St Leo, or probably one of those two 6 she was coachable. Did you notice whether or not 6 schools because that would have been close by. 7 Jane Doe No. 4 was a happy person? 7 We were staying at a Hampton Inn that we 8 . MS. ARBOUR: Form. 8 bad stayed at before. And our routine was we 9 THE WITNESS: Most of the time I thought 9 would have breakfast. We had a game probably 10 she was a happy person. 10 at 4:00 or 5:00 that day. So we had breakfast. 11 BY MR PIKE: 11 We had to check out of the hotel by 11:00. Our • 12 Q. Did she ever confide in you about any. • 12 game wasn't until 5. One of the teammates 13 personal matters? 13 parents lived close by in Tampa, so we would 14. A. No. 14 basically go there and have lunch: 15 Q. Never? 15 So, we had kind of the house to hang out 16 MS. ARBOUR: Form. 16 at before we went to the, go to the game. And 17 THE WITNESS: Not to my recollection. 17 there was — she had actually — something had 18 • BY MR. PIKE: 18 happened with the lock in her bathroom and she 19 Q. Okay. Would you describe Jane Doe No. 4 19 got locked in the bathroom for about three 20 as a strong-willed person? 20 hours. And the workers were there trying to 21 MS. ARBOUR: Form. 21 figure out the lock. • 22 . MR. PIKE: Ambitious? 22 They had to, they couldn't drill the lock 23 MS. ARBOUR: Form. 23 out. They had to actually remove the door to 24 THE WITNESS: 'just — they are very 24 get her out. So, she was really upset by it. 25 wide-open questions. I think she worked hard 25 I mean, I think I understand. And they were Mr. 6 (Pages 18 to 21) PROSE COURT REPORTING. AGENCY, INC.' Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) eeall4d6c.-3510-4ad-842b431264822od EFTA00729390  Page 2:: Page 24 1 all apologetic. The hotel was apologetic. 1 to you between 2 They comped the room. The lock mechanism had 2 MS. ARBOUR: Form. 3. just jammed and no keys would — they actually 3 THE WITNESS: No. 4 had to take the hinges off the doors as 4. BY MR. PIKE: 5 upset abouttliii that was I • 5 Q. Was she upbeat between 6 probably. Y 6 MS. ARBOUR Form. 7 BY MR. PUCE: 7 THE WITNESS: I mean, upbeat., I mean I 8 Q. And you said there was one other instance. 8 think she had a — she's a logical person in 9 A. There was probably one or two other instances 9 terms — so that's, certainly, most of what I 10 in five and/or six. 10 remember. But was she like that every day, 11 Q. 11 every minute? I mean, no. No one is like that 12 A. Yes. The fall where she 12 all the time. 13 had — I think she had some personal matters going on 13 MR. PIKE: Understood. Understood. I am 14 and she seemed to be under pressure I think. And this 14 not asking for all the time. I am asking for, 15 is not unusual in terms of when people are having 15 you being her coach, I was, I was a wrestler 16 troubles with different parts of their life. The soccer 16 and I wrestled and I wrestled five days a week, 17 for them becomes an outlet and that's just how things 17 three hours a day and I got to know my coach 18 are for different people. 18 very well. 19 So, think that she — and I am just 19 So, these questions are, you know, related 20 probably guessing here, but I think the soccer 20 to your general understanding and your general 21 helped her because it took her mind off whatever, at 21 perception as a coach for that time period 22 least temporarily, off whatever was going on. There 22 relative to this. I am not asking for 23 was a time she had her family, she had to miss 23 anything, someone who is always up-beat. I 24 practice and it was for family matters. And then I 24 understand. 25 know in the actually had to miss a couple games 25 But separate and apart from that, did you Page 23 ' Page 25 1 because there was a family issue and I didn't delve 1. ever see any personality changes in Jane Doe 2 into the issue. I mean, I trusted that it was a, 2 No. 4 &DM WM. 3 that she was, it was a family matter that she was 3 MS. ARBOUR: Form. 4 dealing with. 4 THE WITNESS: Nothing, nothing, nothing in 5 Q. Asa player would she be required to fill 5 terms of, nothing drastic. As there are times 6 out a request for excuse, for excusal from any 6 that you can recall players maybe having a bad 7 practice or game? 7 day or just there are other things on their A. No. I mean those would just be done on a, on 8 mind, sure. But as far as a drastic 9 an individual basis with any player. 9 personality change, no. 10 Q Face-to-face with you being the catch? 10 BY MR. PIKE: 11 A. Correct 11 Q. Did Jane Doe No. 4 exhibit any behavioral 12 Q. Would you take down any records for the 12 or health issues to your knowledge between '05 and 13 NCAA in that regard? 13 '08? 14 A. NCA, no. 14 MS. ARBOUR: Form. 15 Q. So, the procedure would be just a common 15 THE WITNESS: Nothing. I think that was 16 procedure. If a player was having a personal issue 16 outside the context of playing like an injury. 17 they would come to you and say, coach, I am not • 17 BY MR. PIKE: 18 going to be able to be here; l have a family issue. 18 Q. Do you know anything about Jane Doe No. 4 19 I don't want to delve into it, but that's what it 19 health? And when I say health I mean mental health? 20 is. 20 MS. ARBOUR: At any time? 21 MS. ARBOUR: Form. 21 MR. PIKE: Betweenla 22 THE WITNESS: I don't know if I would put 22 THE WITNESS: Do I know anything? 23 it exactly that way but that's the gist. 23 MR. PIKE: Yeah. 24 BY MR. PIKE: 24 THE WITNESS: Yeah. 25 Q. Has Jane Doe No. 4 ever seemed depressed 25 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-9764934) coal 4d6c-3516.4ced.842b-e3t2cle0822ed EFTA00729391  Page 26 Page 28 1 BY MR. PIKE: 3. Epstein prior to today? 2 Q. Do you know whether Of not Jane Doe No. 4 2 A. Yes. 3 was seeing a psychologist, psychiatrist or social 3 Q. How have you heard that name? 4 worker or any cotunelor between 4 A. It's in the papers. 5 MS. ARBOUR.: Form. 5 4 Okay. And what have you read? 6 . THE WITNESS: I do not recall that, no. 6 A. That he is a wealthy guy that's got in trouble 7 BY MR. PIKE: 7 for some stuffhe should not be doing. Something about 8 4 Okay. Do you know whether or not Jane Doe 8 paying girls for massages. 9 No. 4 had any problems with drugs or alcohol between 9 Q. Did you ever come to learn that Jane Doe 10 '05 and '08? 10 No. 4 flied a lawsuit against Jeffrey Epstein? 11 MS. ARBOUR: Form. 11 A. No. 12 THE WITNESS: No. 12 Q. So, when you were reading those articles 13 BY MR. PIKE: 13 you had no idea that Jane Doe No. 4 filed a lawsuit 14 Q. Do you know where Jane Doe No. 4 worked at 14 against Mr. Epstein? 15 anyplace of employment between an? 15 MS. ARBOUR: Form. 16 MS. ARBOUR: Form 16 THE WITNESS: No. 17 THE WITNESS: No. 17 BY MR. PIKE: 18 BY MR. PIKE: 18 Q. But for my having told you that today, 19 Q. You have no idea where she was employed 19 have you ever heard oflane Doe No. 4 being involved 20 during those years? 20 with a gentleman by the name ofJeffrey Epstein? 21 MS. ARBOUR: Form. Asked and answered. 21 A. No. 22 MR. PIKE: You can answer. 22 Q. Based upon your interactions with Jane Doe 23 THE WITNESS: I don't think, !mean I 23 No. 4 between '05 and '08, would you describe her as 24 didn't necessarily know where they worked. I 24 angry, bitter, disliking herself or depressed? 25 am trying to think if I recall if she did work. 25 MS. ARBOUR: Form. Page 27 Page 29 1 I mean, it's not a question that I would 1 THE WITNESS: No. 2 normally know because ifit didn't conflict 2 BY MR. PIKE: 3 with ha studios or her school or her soccer, 3 Q. Are you familiar with any medical history 4 then it wouldn't be something that would 4 relative to Jane Doe No. 4? 5 normally come up. Wait. She did work at Pine 5 MS. ARBOUR: Form. 6 Tree Camps one summer. 6 MR. PIKE: Well, do you want me to go into 7 BY MR. PIKE: 7 it? 8 Q. And is that a soccer camp? 8 MS. ARBOUR: Well, you already asked him. 9 A. Well, has a summer camp that 9 MR. PIKE: If you withdraw the form, I am 10 they, that it's kind of auxiliary for the school for 10 going to let him ask I am trying to be nice 11 most of the younger kids. So, it's not a soccer camp 11 here. 12 it's just a camp. So, she worked as a counselor there. 12 MS. ARBOUR: Okay. I appreciate that. 1 13 Certainly, I think between either before the season so 13 noticed. 14 it would have been the summer of 2008, 2007 and/or 2008. 14 MR. PIKE: I am going to ask the question 15 I can't recall for sure if it was both or just one. 15 one more time. . 16 Q. Do you know whether or not Jane Doe Na 4 16 . THE WITNESS: 'have a comment. Cm ahead. 17 had a boyfriend named Illia , 17 This is before that. Can I go back? 18 A. No. 18 MR. PIKE: Sure. 19 Q. Had you ever met any of Jane Doe No. 4's 19 THE WITNESS: Only because I am thinking 20 boyfriends between illEallia 20 about the relationship with Epstein. 21 A. No. 21 MR. PIKE: Understood. 22 Q. Have you ever met any of Jane Doe No. 4's 22 TIE WITNESS: o miss a game 23 boyfriends at any time that you're aware of? 23 because of a family matter int Al and it was a 24 A. No. 24 legal issue that she said it was a family 25 Q. Have you over heard the name Jeffrey 25 issue, a legal issue. So, I asked her for the 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (801-051-97(4-2934) ceatild6c-3516-4catl-842b-e3f2da0822ed EFTA00729392  Page 30 Page 32 1 paper just so I had something and she handed me 1 =MP 2 a sheet of paper that had like a case on it. 2 A. No. 3 BY MR. PIKE: 3 Q. Okay. Did Jane Doe No. 4 • he 4 Q. Do you remember what it said? 4 soccer team for any reason during ? 5 A. It was a — it WaS a, it wasn't like a — it 5 A. No. 6 wasn't like a subpoena. Was it a subpoena? I just 6 Q. Okay. Was she a committed player to the 7 remember. I remember it was a legal issue. Her name 7 and to her teammates between..and 8 was on it. There was a few other names as Defendants. 8 9 So I took it as legitimate. It was Palm Beach, 9 MS. ARBOUR: Fonn. 10 whatever. And I just, you 'mow, so that was kind of I 10 THE WITNESS: I think so, yes. 11 wanted to make sure that there was — you asked about 11 BY MR. PIKE: 12 permission so we didn't do a permission slip. 12 Q. Did it ever seem like school and sports 13 Q. Understood. 13 were too much for Jane Doe No.4 to handle in 14 A. If you were going to miss for a reason and 14 tandem? 15 this was something that I could file, I wasn't going to 15 MS. ARBOUR: Form. 16 question it any further. 16 THE WITNESS: I don't think so. I only 17 Q. To your recollection was her name on that 17 would just refer-- 18 paper as a Defendant? 18 BY MR. PIKE: 19 A. No. It wasn't a Defendant. It wasn't as a 19 Q. Let me rephrase the question. Based upon 20 Defendant, but I am trying to remember if it was, if the 20 your experience and involvement with Jane Doe No. 4 21 name Epstein was on the paper. 21 as her coach between '05 and '08, did it ever seem 22 Q. As you sit here today do you recall 22 to you that school and sports were too much for Jane 23 whether or not Epstein's name was on that paper? 23 Doe No. 4 to handle in tandem? 24 A I don't loww. It may have beat. 24 A. No. 25 Q. Do you know for certain? 25 MR. PIKE: I have no further questions. Page 31 Page 33 1 A. I don't remember. 1 MS. ARBOUR: Okay. I just have a couple 2 Q. So, as you sit here today you don't 2 quick ones. 3 recall? 3 MIL PIKE: She's quick. 4 A. I guess that's the safest. That's the safest 4 MS. ARBOUR: And I talk fast 5 answer, yes. 5 CROSS (ROCKY ORBZZOLI) 6 Q. Okay. Did Jane Doe No. 4 ever dieross her 6 BY MS. ARBOUR: 7 medical history with you in any context? 7 Q. Okay. Outside of soccer practice and 8 A. Not that I recall. 8 soccer games, how often did you interact with Jane 9 Q. Okay. Did Jane Doe No. 4 ever have to 9 Doe No. 4 between 10 fill out any papers for relative to 10 A. Not that much. In the recruiting process 11 her position as a soccer player delineating her 11 which would be during, would be.during the junior and 12 medical history to your knowledge? 12 senior year, you do have probably interaction whore you 13 A. When the players enter for the fist time 13 call them once a week. It's kind of hike a check-in, 14 before their fieshtnan year, they have to do a bunch of 14 call kind of