EFTA00723630.pdf

Page 1 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 VIDEOTAPED COMPULSORY MEDICAL EVALUATION OF E.W. Wednesday, November 11, 2009 9:02 - 6:30 p.m. 250 Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting Services PROSE COURT REPORTING AGENCY, INC. Eiectronically signed by Jeans Fascist' (601 31,7135dc-3693-4b9f-b60e-98638afea746 EFTA00723630 EFTA00723631  Page 2 Page 4 1 APPEARANCES: 1 A. Okay. 2 On behalf of the Plaintiff: 2 Q. Again, my assistant is sitting in the room. 3 BRADLEY1 EDWARDS, ESQUIRE If you wouldn't mind, just — 1109 Northeast Second Street 3 4 Hall 33009 4 MS. YOUNG: Hi. Matisse Phone: 5 Marissa? Hi. I'm 5 6 BY DR. HALL: 6 7 Q. I believe that was an arrangement worked out 7 On behalf of the Defendant 8 ASHLIE STOKEN-BARING, PARALEGAL 8 between the lawyers that there be one person present. BURMAN, CRITTON, LUTHER & COLEMAN, LLP 9 A. Okay. 9 303 Banyan Boulevard 10 Q. As you can tell from the camera, we're going Suite 400 11 to be videotaped. I don't know what the agreement is in 10 West P 'de 33401 Phone: 12 terms of who owns the tape, if that's going to be your 11 13 attorney, shared attorneys. Iles not my — 12 14 A. Okay, that's fine. 13 ALSO PRESENT: 15 Q. This will be probably six to eight hours, 14 Dr. Ryan Hall, M.D. 15 16 dependent. But if at any time you need to take a break, 16 Jeffrey Abbot, Videographer 17 you would like to get something to eat or water, Visual Evidence, Incorporated 18 anything like that, just let me know. 17 19 A. Okay. 18 19 20 Q. I'll be keeping track of the time and things 20 21 along those lines. 1 don't know what's going to be done 21 22 for lunch. The last time, f didn't know it was going to 22 23 be in a different office, so Pm assuming whatever the 23 24 lunch break is, theyll wrangle up a sandwich or 24 25 25 something for us. Page 3 Page 5 1 EXAMINATION 1 With that, do you have any questions before we 2 2 begin? 3 BY DR. HALL: 3 A. No. 4 Q. If you want to, write the name of your counsel 4 Q. No? Okay. t, in. 5 Usually, how I do this is I Me to get a lot o A. As in Brad? 6 of background information, so I may be asking you a lot Q. As in Brad, yeah. 7 of questions that don't directly pertain to the lawsuit Then, also, we're going to be doing some 8 up front. 9 testing later on. This is again, I think this was in 9 A. Okay. 10 the original packet we sent you. I'm not sure if you 10 Q. And then well talk about what happened and 11 received that or not, the patient history questionnaire. 11 what the events were and things of that nature, all 12 A. No. 12 right? 13 Q. You did not get that? 13 A. Okay. 14 A. No. 14 Q. So with that, where were you born? 15 Q. We'll be filling that out later in the day 15 A. I was born in- 16 then. 16 Q. Okay. And I apologize, I'm a little slow with 17 A. Okay. 17 writing. 18 Q. If I can have you read this and sign this as 18 A. No, that's no problem. 19 well saying that you realize we're going to be testing. 19 Q. Is that Where 15 20 A. Okay. So I just — is this filled out by 20 at? 21 someone other than — 21 A. No, it's on the 22 Q. Right. Ifs going to be filled out by you 22 Q. Okay. And was there any problems or 23 so - 23 complicationswith your birth? 24 A. So just put my name or leave it blank? 24 A. No, not to my knowledge, but Pin pretty sure, 25 Q. Just leave it blank. 25 no. 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans RIccluti Ell1786dc-3693-4b9f-b50.48838aRia748 EFTA00723632  Page 6 Page 8 1 Q. So nobody ever told you you were in the NICU, 1 health history or problems or -- 2 PICU, had to spend longer, came early, came late, cord 2 A. Right. 3 around your neck, problem with your pregnancy, nothing 3 Q. Okay. Roughly, how old is mom and dad? 4 along those lines? 4 A. I can't — my mom is — honestly, she's lied 5 A. Nothing on those terms. 5 about her age for so long time. I believe she is 6 Q. Okay. And did you meet your normal 6 probably like 45 or 46. Maybe older, I'm not really 7 developmental milestones, walking, talking on time? 7 positive. And my father is probably around SO years 8 A. Yes. 8 old, give or take. 9 Q. Any significant childhood illnesses? 9 Q. I'll put 45-ish. 10 A. I'm sorry? 10 A. Okay. 11 Q. Any significant childhood illnesses? 11 Q. Any brothers or sisters? 12 A. No. 12 A. I have one brother. Well, actually two 13 Q. I mean, other than mumps is a little rarer 13 brothers. One's my half brother, one's my biological 14 nowadays, but I mean, chicken pox or anything like that, 14 brother. And my biological brother i.. 15 nothing out of the ordinary? 15 Q. Okay. 16 A. No. 16 A. And my stir s ther iois 17 Q. aa.nd your date of birth? 17 Q. I'm sony; 18 A. 18 A. 19 Q. And can you tell me a little bit about your 19 Q And how old is 20 parents? 20 A. My brother is and my younger brother, I 21 A. My mother's name is The lives= 21. don't really have that much of a relationship with him. 22 in 22 I believe he's 23 Q. Okay. 23 Q. Okay. And is=married, single, 24 A. My father's name is 24 divorced? 25 Q. 'Thank you. 25 A. He's single. Page 7 Page 9 1 Okay, and whore is he at? 1 Q Ancl Married, single or divorced? 2 A. To be honest, I don't have a relationship with 2 A. Single, I'm sure. 3 hint 3 Q Okay. And you said is the one you 4 Q. Okay. And that's fine. If I ask you 4 didn't have much of a relationship with — 5 something you don't know, feel free to tell me. 5 A. Right No, my brother= I have a 6 A. Right. 6 relationship with him. 7 Q. And sometimes it's okay to ballpark if you 7 Q. Okay. Where doesMive? can't tell me anything more specific when we're talking 8 A. He lives in 9 about when you were five or six. 9 Q. Okay. And —s in Florida, out of 10 A. Right 10 Florida? 11 Q. It's hard to remember exact dates and things 11 A. He's inM 12 Tike that. 12 Q. Okay. Any nieces or nephews? 13 What's mom do for a living? 13 A. No. 14 A. Shen 14 Q. No? Okay. 15 Q. Okay. Does she have any medical problems? 15 Do you have any children on your own? 16 A. No, not to my knowledge. 16 A. No. 17 Q. Okay. Any psychiatric problems? 17 Q. MAW, evil and nasty question to ask. My 18 A. Not to my knowledge. 18 math is not always the best. Born in■ that would 19 Q. Okay. !know you said you don't have a 19 make you how old? 20 relationship with dad, but do you know anything about 20 23. his medical history or — 21 Q. 22 A. No, I don't, but I do believe that right now 22 what ethnicity or nationality do you 23 he's 23 consider yourself? 24 Q. I'll put that down with a question mark 24 A. I' 25 Okay. And as far as you know, no mental 25 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans RIccluti (801e) 3,6766dc-36934b9t-b50e-9861Elat0a746 EFTA00723633  Page 3.0 Page 12 1 1 or — 2 2 A. Yes. 3 3 Q. How long have they been together? 4 A. I'm not really sure what lcind of but 4 A. Probably since I've been six or seven years 5 my grandfather ha. in him on my mother's side. 5 old. 6 Q. Okay. How is your relationship with your 6 . . And how is your relationship with 7 mother? 7 Am I pronouncing that right? 8 A. Very good. 8 A. Yes Very good. 9 Q. Has it always been that way or has it Q. What's he do for a living? 10 sometbnes been better than others? 10 A. He — actually, he has two jobs. Well, 1/. A. It's definitely been better than others. 11 actually, I think right now he might have three. He 12 Q. But currently good? 12 13 A. Correct 13 ono many ents. 14 Q. Okay. 14 A. Yes. 3.5 A. Even through our ups and downs, we've always 15 Q. Now, the half brother you have, is that 16 maintained a pretty good relationship. I've always 16 through your father or through your mother? 17 confided inhet 17 A. Yes, through my father. 18 Q. Okay. And your father, you said you don't 18 Q. Okay. And did you ever have a stepmother or 19 20 23. have any relationship with him now -- A. Right. Q. -- but you did know him? 19 20 21 anything of that nature? A. Not for very long. Just maybe when I went over there. Her name i sb summers I'm not 22 A. No, not really. When I was younger, I would 22 sure of her last name now. 23 go to his house for summer, and the school year I would 23 Q. Fair. Fair enough. 24 be with my mother, but other than that, I — I don't 24 A. Uh-huh. 25 have any relationship with him. 25 Q. Okay. Any stepbrothers or sisters? Page 11 Page 13 1 Q. How old were you when your -- actually, were 1 A. Yeah.ad two kids 2 your parents ever married? 2 3 A. Yes. 3 Q. Any relationship with them? 4 Q. Okay. How old were you when they divorced or 4 A. I have — I sometimes, over the computer, have 5 separated? 5 talked to — maybe two years ago, I went and seen 6 A. I'd say probably two to three. I don't even 6 and her family. I talk to them on the computer every 7 remember any of that, though, so it's hard to really 7 now and then. say. 8 Q. Okay. So — 9 Q. Okay. So your earliest memories was just with 9 A. And they're located i 10 mom; dad was already out of the picture? 10 I don't know where he's located at, y, 1/. A. Pretty much, yes. 11 but I knoa and her family are in MI 12 Q. And, you know, if I say something or 12 where I was 13 paraphrase and it's not right, please correct me. 13 Q. Okay. Again, I don't want to put words in 14 A. Yeah, definitely. I mean, I do have some 14 your mouth: Cordial relationship, amicable, just kind 15 memories with my father when I was younger but I mean, 15 of there? 16 not very many; do you know what I mean? 16 A. Yeah, just on and off, acquaintance, good 17 Q. Okay. 17 acquaintance, I guess. 18 A. So... 18 Q. Does Mr. -- I apologize -- 19 Q. Were there ever any stepfathers or — 19 A. 20 A. Yes. 20 Q. you. _yeah, does he have any 21 Q. — live-in boyfriends? 21 children? 22 A. Yes. 22 A. No, no. 23 23 Q. Okay. Kind of the extended family, has them 24 Q. 24 been any issues with mental illness, depression, 25 Okay. And is your mother still with him, 25 schizophrenia, bipolar or anxiety? a.4.1.1..e..il.....rat....00.0.4.0006 ,74.4......1. 4 (Pages 10 to 13) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans Eiceluti(6011=1) 3t8786de-3693.4b91-b50e-98638a10a746 EFTA00723634  Page 14 Page 16 1 A. With? 1 that they've really diagnosed him with that, but I don't 2 Q. Aunts, uncles, grandparents, cousins. 2 see why they haven't. 3 A. 3 4 Q. Pm sorry, your grandffither? 5 6 A. Yes, my mother's dad. 6 7 7 Q. Which 8 A. 1think it was 8 Q. Do you know what he's bee i t m with? 10 A N0,1 do not 10 11 11 12 12 13 13 14 know, but other than that, I know that my grandmother, 14 15 my mom's mom, and she's going to be 80, she's a go -- 15 16 she's a, you know, she's a go-getter, she doesn't seem 16 17 ill at all. She doesn't even seem 80; she seems 17 Q. Okay. I think that's one of those things 18 probably 60. 18 that's okay to give a ballpark on. 19 My father's dad, and his name isas 19 A. Right. 20 well, my grandfather, he seems okay. I do talk to some 20 Q. Okay. Any problems with substance use in the 21 of my dad's — like my aunts and cousins end stufflike 21 family? 22 that on my dad's side. 22 A. Yes. 23 And Pm sorry, you did ask me if I had cousins 23 Q. Okay. Who's had issues with substances? 24 and stufflike that, didn't you? 24 25 Q. !rimy ofthem had mental illness. 25 Page 15 1 A. Oh, okay. No, not to my knowledge. 1 2 Q. No, I mean, there could be hundreds. 2 3 A. Right. Yeah, I do, I have a whole bunch of 3 4 them. 4 Q. And I may ask you a little more later about 5 Q. We would take up eight hours just talking 5 yourself. 6 about each and every one of them. 6 A. Okay. 7 A. Exactly. 7 Q. But how about your family? 8 Q. Are there any that are significant in your 8 A. My mother, she is a recovering addict for life that you see on a monthly basis or is it kind of 9 going on three years now. 10 family get-togethers you see them? 10 Q. Okay. Good for her. 11 A. Well, they're in and my -- most of my 11 A. As well as my stepfather,IM 12 dad's family. The rest them are in -nd then 12 Q. What did mom use? 13 me and my mom and my brother and my stepfather,■ we 13 A. She was addicted to crack cocaine, both her 14 live here, but - and my 14 and my stepfather. 15 Q. Okay. Now, a lot of times terms get used, and 15 Q. Okay. And do you know roughly how long she 16 what they mean by kind of general population and what 16 used for? 17 they mean medically are a little different, so when you 17 A. Over 20 years. 18 18 Q. Okay. And this is -- you'retow, so she 19 19 started after you were born? 20 20 A. Honestly, I don't know. I don't know If she 21 21 was you know, was using and got pregnant with me and 22 22 stopped. I don't really know the whole scenario, but.. 23 23 Q. Do you know one way or the other if you may 24 111 r 24 have been exposed in the utero to cocaine? 25 A. But they haven't -- I honestly don't believe 25 A. I'm sorry? 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeans RIcelutl (801 818786dc-3693-4b91-b800.98831300e748 EFTA00723635  Page 18 Page 20 1 Q. Did she use while she was pregnant? situation was and took me in for quite a while. 2 A. She -- she's told me no, because I had asked 2 Q. Okay. Can I et the name of that person — 3 her. 3 A. Y 4 Q. Okay. All right. And was it just cocaine, or 4 ..kay. And how long did you stay with the 5 did she use anything else like alcohol or marijuana 5 6 6 A. For a while. Probably — probably three years 7 A. No, I believe just crack cocaine. 7 off and on, give or take. 8 Q. How did she get clean? 8 Q. Okay. Was DCF ever involved when you were 9 A. She had a well, she lost everything she had growing up? 10 multiple times and she just hit rock bottom. I guess 10 A. No. Weird enough, no. 11 she just was ready to change, ! suppose. Ever since, 11 Q. And how did your brother do with all of this? 12 she's held strong and hasn't gone back to that 12 Was he also kind of — 13 lifestyle. 13 A. Actually, my brother, before my mother really 14 Brief interruption in proceedings.) 14 got heavy into her addiction, I believe she was -- she 15 BY DR. HALL: 15 would always kind of maintain her house, like a 16 Q. I just had to stop there fora second due to 16 functioning addict. And so during that time, my brother 17 mechanical problems with the camera. 17 was there, but my brother kind of was going down the 18 So we were talking about mom and how she had a 18 wrong road. My mom seen that and he actually was sent 19 little bit ofa substance problem. 19 over to the West Coast with my wild side of the family, 20 A. Right. 20 my father's side, and he lived with my grandparents for 21 Q. How did that affect your relationship with 21 pretty much the whole time that my mom really was out 22 her? 22 and about doing her own thing, so... 23 A. Well, not only did it affect our relationship 23 Q. Okay. Was there ever episodes of violence 24 but it affected my whole lifestyle for when I was 24 between you and your mom related to her drug use? 25 younger. 25 Page 19 1 Q. Okay. In what way? 1 2 A. Homeless, and every way around. I mean, I 2 3 guess that's generally everything. You know, my 3 4 schooling. 4 5 Q. Okay. How long were you homeless for? 5 6 A. I mean, they always had, as in homeless, they 6 7 always had a place — they were always — had a place to 7 9 stay. They lived in efficiencies, hotels. They would 8 9 kind of jump from hotel to hotel or whatever, and I 9 Q. And roughly, what time was t. 10 could always go stay with them, but I never wanted to go 10 A. I believe I was 16. 11 stay with them because of them using, obviously. So I 11 Q. Okay. Do you remember the month or year or 12 don't think nobody wants to see that. 12 how do you kind ofkeep that straight in your head time 13 Q. Right. 13 wise? Any — 14 A. So between the age of, I would say, 13, 14, 14 A. I don't really remember the month or year. I 15 around about — 15 would maybe say — ! honestly — ! couldn't even tell 16 Q. Okay. 16 you. I couldn't even tell you. 11 A. -- until she got clean three years ago, I was 17 Q. Okay. 18 kind of — I was I mean, after I turned.I — 18 19 well, before I was even= I made my own way, started 19 20 so I could, you know, make money to provide for my own 20 Q. Okay. Yeah, I can check if I need to. I was 21 self. But before that, you know, I was — stay at a 21 just -- sometimes people have certain events in their 22 friends house, jump from friend's to friend's house. 22 lives that they remember things about — 23 And a lot of the parents knew. You know, it wasn't a 23 A. Right. 24 secret that — what my situation was, so, you know, one 24 Q. -- you know, their 16th birthday — 25 friend in particular, her father really knew what the 25 A. Definitely. Definitely. 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricclutl 3f8785dc-3693-4b91-b60e-98638af0a746 EFTA00723636  Page 22 Page 24 1 Q. — fast car, somebody they were dating — 1 Q. Did they ever shoot it or snort it? 2 A. Right. 2 A. I have no idea. 3 Q. — and they can kind of put things together 3 Q. You never witnessed them doing it in front of 4 that way. 4 you? 5 A. Put it together. 5 A. Right. 6 Q. So I was wondering if you had any time stamps 6 Q. Okay. I trained up in the Baltimore area. and 7 in your life for what you used to — 7 I saw a lot of very heavy cocaine use. 8 A. Honestly, I — now that I think about it, I 8 A. Oh, okay. 9 think I was a little younger than age 16 when that all 9 Q. Fonts up there usually would either go by 10 occurred. 10 munber ofrocks they were using or dollar amount. 11 Q. NI put a question mark next to it. 11 A. Oh. 12 A. Right, but no. 1 mean, I know I was — I was 12 Q. Just like kind of an idea down in 13 probably — I think I was probably starting to be a 13 S how much would a rock of cocaine go for' 14 Freshman 14 A. I'm — I don't really know. I would guess 20 15 Q. Okay. 15 bucks, 25 bucks, !think. 16 A. I was supposed to be going to school. I think 16 Q. Okay. Would that be a big rock you could 17 it was in the summer time, but I could be wrong. 17 break up into multiples, or... 18 Q. Fair enough. 18 A. I have no idea. 19 And that would have been about seven years ago 19 Q. No idea? 20 now or eight years ago? 20 A. I have no idea. 21 A. Well, 1' 21 Q. Okay. We used to talk about $5 and $10 hits 22 So, yeah, about 22 all the time in Baltimore. 23 seven or eight years ago. 23 A. Okay. 24 Q. How did you get along with your stepfather? I 24 Q. 'Just want to make sure my -- 25 apologize if I've already asked that. You said 25 A Right. I mean, they could have that down Page 23 Pug( 1 generally a good relationship? 1 here, too. Pm not really, really sure. 2 A. Yeah, generally good. 2 Q. They had the eight balls, which were the big 3 Q. Okay. Ever get into fights with him or have 3 ones but again, you were supposed to break that up or do 4 any trouble — 4 whatever. S A. I mean, arguments over obviously the crazy 5 A. No. lifestyle they were living and everything else. So 6 Q. Okay. Any issues with alcohol or... 7 arguments, but there was always unconditional love. I 7 A. No. 8 could always — if there was anything ever wrong, you 8 Q. How did they get money to support their habit? 9 know, sometimes they would be kind of missing in action. 9 A. Like I said, my mom was always kind oflike an 10 but for the most pan, I did 'mow where they were. If 10 active addict, so she always carried a job, and for the 11 they were in hotel rooms, we did keep contact. If there 11 most pert my stepfather did, too. 12 was anything ever wrong — they were using, it sounds 12 Q. Okay. So there was no stealing or — 13 crazy, but they did give me unconditional love, like, 13 A. No. My mother was always a wait — 14 you know... 14 Q. -- trading sex for favors? 15 Q. Okay. All right. It's good to know that you 15 A. No. My mother was always a waitress at -- 16 felt that they were at least there. 16 like at the worked fora very long time. 17 A. Definitely. They might not have been there, 17 various restaurants. She always stayed at 18 you know, drug-wise. I know that they were using and 18 each restaurant for a year, you know. Always long term 19. everything else, but my mother -- 19 for the most part 20 Q. Do you know roughly how much they were using a 20 And my ste.pfa ever since I could 21 day? 21 remember, he di til just recently when he 22 A. No, I have no idea. 22 star But he's been in 23 Q. Okay. And it was crack so they were smoking 23 the usiness for a really long time. 24 it? 24 Q. Okay. I'm just going to... 25 A. Yes. 25 And I know we talked about this a little bit, 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Fticclutl (4101==) 3f6766dc-3693.4b9f-b50o-98638af0a746 EFTA00723637  Page 26 Page 28 1 so pardon me if there is a little overlap, but in 1 were younger, I never remember us getting really 2 general, how would you describe your childhood? 2 physical with one another. 3 A. It could have been better, I suppose, 1would 3 Q. Okay. What type of activities or clubs did 4 say. 4 you belong to? 5 Q. Okay. 5 A. Wheal was in middle school — I was always a 6 A. And more -- more of my teenage years, I guess 6 straight A student from elementary to middle before, and 7 I would say. As my childhood, I always remember happy 7 then I dropped out. 1was always honor roll, straight A 8 memories and stuff like that. Like, I don't remember 8 student, I was in a lot of activities, I was on the 9 ever being sad or neglected or hungry or anything like 9 track team, I was the first chair trumpet player. 10 that. It was more when I turned, you know, 13, when I 10 Q. Okay. 11 got into my teenage years. 11 A. I was the captain of the cheerleading squad, I 12 Q. Okay. So teenage years were definitely worse 12 was a mediator. 13 for you than -- 13 Q. Hold on one second. So captain of the 14 A. Definitely. 14 cheerleading squad, first trumpet? 15 Q. Okay. How were you disciplined as a child 15 A. First chair trumpet player. 16 growing up? 16 Q. And that was school band I guess, or marching 17 A. I mean, if I did something wrong, talked back, 17 band? 18 1got put in time-out. There was definitely sonic form 18 A. Yes. It wt this was all 19 of discipline. She would never let me do whatever I 19 at. 20 wanted to but, you }mow, when I turned 12 and or 13, she 20 Q. Okay. 21 was kind of wanting to do what she wanted to do, and she 21 A. Whe that one teacher got shot 22 did kind of get more lenient on me where I was able to 22 at, ifs the same. t ow if you probably heard 23 go out. Sometimes I would leave and not tell her where 23 of that, around two years ago. 24 I was going or, you know... 24 Q. No. 1didn't grow up in 25 Q. Okay. So it was never like physical 25 A. Okay. Page 27 Page . • 1 punishment like spankings or anything like that; it was 1 Q. Who igilMME 2 time-out and grounding? 2 A. Oh, it's a teacher that actually got shot and 3 A. Right, no. My mother has never put her hand 3 killed there. A lot of people know that school, that's 4 4 the only reason I brought it up. 5 5 Q. Did you know him? 6 Q. Okay. And any major physical confrontations 6 A. No,I didn't know the teacher. 7 with your brother or -- 7 Q. And you said a mediator? 8 A. Oh, me and him? 8 A. Mediator. 9 Q. Yes. 9 Q. Okay. Fm not familiar with that program. 10 A. Yes. When we were younger, before he got sent 10 A. You can get it as an elective, and it's when 11 over to the West Coast, we used to fight like cats and 11 counselors, the counselors of the school pick a 12 dogs. 12 selective two or three people or four people to have it 13 Q. And would that be kind of like — it's hard to 13 as an elective, and when me as a student knows that this 14 even say, because there's no such answer to normal 14 girl and this girl is having a problem, we would call 15 brother/sister at times, but normal brother and sister 15 them out of their class and put them in the counselor's 16 type of things? 16 office and kind of try to mediate their problem before a 17 A. Right. You know, I would use the phone and he 17 fight occurred or anything like that. 18 wants to use the phone and I'm on it first and it 18 Q. Okay. How many times did you, I guess, do 19 escalated. Just very simple stupid stuff we would argue 19 peer mediation? 20 . about. . 20 A. Multiple — a lot. I don't... 21 Q. Okay. And would it get physical or just — 21 Q. Ballpark it, 5, 10, 20? 22 A. I mean, a couple of times we did honestly get 22 A. I would say 5 to 10 times. 23 physical with one another but, you know, that was kind 23 Q. Were you ever threatened becimse you did this 24 of when I was 12, 13, before he was sent over to the 24 type of work or have any negative repercussions from it? 25 West Coast, when we were a little bit older. When we 25 A. No. 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Jeana Ricciutl (601 ) 318785dc-3693.4b9f-b50e-98638at0a748 EFTA00723638  Page 30 Page 32 1 When I was in middle school, I was generally 1 Q. Did you ever witness any domestic violence in 2 kind of like a popular kid, quote/unquote. I didn't 2 either your family or your friends? 3 really have any problems with really anybody. 3 A. No. As in relationship, mother and Mier 4 Q. I actually put the quote/unquote there. 4 fighting? 5 Okay. And outside ofschool, what would you 5 Q. Mother and father fighting. 6 lice to do? 6 A. Right, no. 7 A. !did all kinds ofstuff when I was, you 7 Q. Okay. Anything else about your childhood, 8 know — most the time I was after after school, I 8 through probably middle school and before, that I should 9 would be at school because I did do cheerleading and I 9 know or come to mind or I haven't directly asked about 10 did play the trumpet and I would do track and I did, you 10 that you think is important for me to understand? 11 know, a lot of stuff So generally, in school, after 11 A. That's pretty much it. I think we covered 12 school, it kept me busy, you know, so... 12 most everything. 13 Q. What did you rum when you ran track? 13 Q. Anybody important in your life that passed 14 A. I'm sorry? 14 away during that time? 15 Q. What type of track did you do, was it 15 A. No. 16 sprinting or long distance? 16 Q. Sometimes! - 17 A. It was long, like the mile runs. 17 A. Right. 18 Q. Do you have a faith? 18 Q. -- questions pop in mind. 19 A. I'm sorry? 19 A. No. 20 Q. Do you have a faith? Do you attend a church 20 Q. And no tratmias during that period of time? 21 or are you spiritual? 21 A. No. 22 A. Oh, yes. I'm a 22 Q. Or anything that you would consider - 23 Q. Did you attend church as a child growing up? 23 A. Right, as trauma, no. 24 A. No. 24 Q. Parting. that can be a very broad word. 25 Q. Do you attend now? 25 Okay. I apologize, you were telling me a Page 31 Page 33 1 A. Once in a while. My mom goes on Sundays and 1 little bit about your educational history. Let me get a 2 Wednesdays each week, so sometimes I go with her. 2 little more in depth there. 3 Q. And again, ballpark, is that like once a week 3 A. Okay. 4 type thing, once a month, four or five times a month? 4 Q. Have you ever been in any special education 5 A. I would say two to three times a month. 5 classes? 6 Q. Better than my friend who considers himself a 6 A. No. 7 Christmas candle/Easter lily. He shows up on two -- 7 Q. And you said you were a good student? 8 A. That's funny. 8 A. Yeah. I was definitely, like, the