EFTA01107831.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-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 JANE DOE #7 - VOLUME II (videotaped) Monday, March 15, 2010 10:02 - 6:49 p.m. 250 Australian Avenue South Suite 1500 West Palm Beach, Florida 33401 Reported By: Rachel W. Bridge, RMR, CRR Notary Public, State of Florida (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107831 EFTA01107832  Page 127 Page• 1 APPEARANCES: 1 PROCEEDINGS 2 On behalf of the Plaintiffs in related cases 2 Nos 08-80069, 08-80119, 08-80232, 08-80384 3 08-80381, 03-80993, 08-80994: 3 THE VIDEOGRAPHER: We're back on the record at 4 ADAM D. HOROWITZ, ESQUIRE 4 12:19 p.m. This is marks the beginning of tape 2. MERMELSTEIN & HOROWITZ, P.A. 5 BY MR. CRITTON: 5 18205 Biscayne Boukvad Q. When you took F.E. to Mr. Epstein's, 1 think 6 Suite 2218 6 Miami, Florida 33160 7 you said she asked you to take her. Telephone: 305/931.2200 8 A. Yes. She knew about It and she asked me, she 7 9 said she wanted to go. 8 On behalf of the Defendant Jeffrey Epstein: 9 ROBERT D. CRITTON. JR, ESQUIRE 10 Q. Okay. Did you say, and did you tell her "No, BURMAN, CRl11UN, LUTHER& COLEMAN 11 I don't think you should go'? 10 303 Banyan Boulevard 12 A. No. I never said that. Suite 400 13 Q. Did you take her so you could make money' 11 West Palm Beach, Florida 33401 Telephone: 561/842-2820 14 First of all, let me ask you this. Did you 12 15 make money from taking F.E. to Mr. Epstein's home? 13 16 A. Yes. 14 Also Present: Sasha Quimby, videographer 17 Q. How much? 15 16 18 A. 200. 17 19 Q. Okay. And when F.E. came down, did she give 18 20 Mr. Epstein a massage? 19 20 21 A. Yes. 21 22 Q. Did she ever say anything inappropriate 22 23 happened during the course of the massage? 23 24 A. No. 24 25 25 Q. And you took ■ and she came, did she give Page 128 Page 130 1 1 Mr. Epstein a massage? --- 2 A. Yes. 2 INDEX 3 Q. Did she ever tell you anything inappropriate 3 4 had happened? WITNESS: DIRECT CROSS REDIRECT RECROSS A. We never really talked about it. 4 6 Q. Did you ask them? Jane Doe N7 5 A. No. By Mr. Critton 5 8 Q. If you talk someone to Mr. Epstein's home to 6 9 have them give him a massage so they could earn money 10 and you could earn money, did you interpret what you 8 11. were doing was the same thing in essence that M. was EXHIBITS 9 12 doing? 10 EXHIBIT PAGE 13 MR. HOROWITZ; Form. 11. Defendants 1 233 14 THE WITNESS: No. 12 Defendants 2 233 13 Defendant's 3 233 15 BY MR CRITTON: 14 Defendant's 4 263 16 Q. Why was it different, in your mind? 15 Defendant's 5 268 17 A. Because they wanted to go, and we were all 16 Defendant's 6 274 18 just kind of brainwashed by him. And at the time I knew 17 Defendant's 7 280 18 19 it was wrong, but I didn't know how it would affect them Defendants 8 294 19 Defendant's 9 301 20 or affect me in the fixture. And I was just confused by 20 21 everything at that time. 21 22 Q. You knew it was wrong, so what's confusing 22 23 about that? 23 24 24 A. I felt like it was wrong, but I, I just 25 25 thought it was -- I was just confused, and I just didn't •t ree=aa 2 (Pages 127 to 130) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107833  Page 131 Page 133 1 know how much it would affect me in the future and, you 1 Q. But at least as you sit here today, you can't 2 know, what kind ofeffects it would have on them. And, 2 remember anything unusual about her coming down from 3 you know, that's why I feel bad about it now, but at the 3 giving Mr. Epstein a massage; would that be a fair 4 time I was confused and I didn't know. 4 statement? 5 Q. Wellj let _ me ask you this. Have you ever 5 A. I mean yeah, I don't remember. 6 talked withEl about her experience with Mr. Epstein, 6 Q. Same thing with F.E., you don't remember 7 ever? 7 anything that stands out in your mind when she came 8 A. No. She is in now. I don't know, we 8 downstairs because you were in the kitchen, right? 9 don't really talk. 9 A. Yeah. 10 Q. What's she doing in now? 10 Q. Do you remember anything unusual or did she 11 A. She lives there now with her sister. 11 say anything or did she react or have any appearance — 12 Q. IIII? 12 strike that. 13 A. Yeah. 13 Did F.E. either say anything that caused you 14 Q. Is her mom ? 14 any concern or did you observe any facial features or 15 A. Yes. 15 anything that she did or the way she acted that would 16 Q. Herded? 16 have caused you any concern that you can remember today? 17 A. Yes. 17 A. Not that I can remember. 18 Q. So they are all a. Why did they go 18 Q. Those are the only two people you ever took to 19 back to a, if you know? 19 Mr. Epstein's? 20 A. Because their green card etd. 20 A. Yes. 21 Q. Let me ask you again. Did ever tell you 21 Q. You went down and had an interview or an 22 anything bad happened at Mr. Epstein's, or 22 evaluation by Dr. Kliman, who was the psychiatrist who 23 inappropriate? 23 had been hired from San Francisco to evaluate his 24 A. I don't remember. 24 clients, including you, correct? 25 Q. So at least — did you only take her the one 25 A. Yes. Page 132 Page 1 1 time? 1. Q. And you had to fly down from Orlando, true? 2 A. Yes. 2 A. Yes. 3 Q. Do you know whether she ever went another 3 Q. Do you remember telling Jane Doe 4 about your 4 time? 4 eicpadence for the evaluation with Dr. Kliman? 5 A. I don't know. 5 A. Yes. 6 Q. All right. But when she came down from giving 6 Q. And do you remember telling her that you were 7 Mr. Epstein a massage, she seemed to be in good spirits, 7 supposed to cry a lot and be very emotional during the 8 didn't say anything bad had happened; fair? 8 course of the — 9 A. She didn't really talk about it. 9 A. No, I never — 10 Q. Did she appear to be upset in any way? 10 Q. I need to finish the question, ma'am. 11 A. I don't, I don't remember. 11 isn't it true you told Jane Doe 4 that you 12 Q. If she had been upset, that's something you 12 cried a lot during the interview and tried to be very 13 generally would remember, wouldn't you, if she was upset 13 emotional, because that's what you were supposed to do? 14 or emotional about it? 14 A. No. 15 A. It was so long ago, I just remember taking her 15 Q. So if you told Jane Doe 4 that, or 'Ilene 16 there. I don't remember how she reacted or what 16 Doe 4 has said that to anyone, that would be a lie? 17 happened. 17 A. Yes. 18 Q. Did you drive her in your car? You were the 18 MR. HOROWITZ: Form. 19 transporter? 19 BY MR. CRITTON: 20 A. I don't remember. 20 Q. If I use the term crocodile tear, does that 21 Q. WasEl able to drive at the time? 21 mean anything to you? Do you know what a crocodile tear 22 A. Yes. 22 is? 23 Q. But you went with her, so either she drove or 23 A. Yes. 24 you drove? 24 Q. What is It? 25 A. Yes. 25 A. When somebody fake cries. 3 (Pages 131 to 134) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561). 832-7506 EFTA01107834  Page 135 Page 137 1 Q. Let me go back to when Jane Doe 4 was living 1 Mr. Epstein's home? 2 with you this last summer, or I'm sorry, the summer of 2 A. No. 3 '08 and she told you that she had filed a suit against 3 Q. Did she ever talk to you about what occurred 4 Mr. Epstein. 4 or what she alleges occurred at Mr. Epstein's home? 5 As of that date, were you aware of anyone else 5 A. No. 6 who had filed suits against Mr. Epstein? 6 Q. All right. Are you aware of anyone else other 7 A. No. 7 than Jane Doe 3 and Jane Doe 4 who are plaintiffs? 8 Q. As you sit here today, other than yourself and 8 A. Just N.R. 9 Jane Doe 4, are you aware of any other plaintiffs or 9 . And who is she? Again, a student at 10 individuals who are plaintiffs in lawsuits against 10 with you all? 11 Mr. Epstein? 11 A. Yes 12 A. Yes. 12 Q. Same grade? 13 Q Who? 13 A. She's a grade ahead of me. 14 A. Jane Doe 3. 14 Q. And did she tell you that she's a plaintiff in 15 Q. Flow do you know is a plaintiff in a 15 a lawsuit? 16 lawsuit? 16 A. No, we were just talking about it and somehow 17 A. Because she is my friend and she told me. 17 she found out that I had a lawsuit and was asking me 18 Q. And that's Jane Doe 3? 18 about it and she said that she had one, and that's all. 19 A. Yes. 19 Q. Did she tell you who her lawyer was? 20 Q. Were you aware or has Jane Doe 3 told you 20 A. No. 21 whether she has given a deposition? 21. Q. Did she — when did you last talk to N.R. — 22 A. Yes. 22 let me start again. 23 Q. Okay. What did she say about it? 23 When did you have this conversation with N.R. 24 A. She said that you looked exactly like Jeffrey 24 about the lawsuit? 25 Epstein. 25 A. I believe it was over Christmas break, I Page 136 Page 138 1 Q. Did she tell you how nice and polite I was and 1 think. 2 reasonable? 2 Q. Christmas — 3 A. Yes. 3 A. I don't know, I was home like on break I 4 Q. Good. 4 don't know if it was Christmas break or not. 5 MR. HOROWITZ: She did? 5 Q. Well - 6 THE WITNESS: No. 6 A. I was just, like I come home a lot to visit my 7 BY MR. CRITTON: 7 parents. 8 Q. I'm taking that as the truth. 8 Q. Are you still in school right now? 9 A. That's a joke. 9 A. Yes. 10 Q. All right. You don't think I look like 10 Q. So when was the last time you were home, 11 Mr. Epstein, do you? 11 Christmas before now? 12 A. Yes, kind of. 12 A. No, I came home recently to visit them, like 13 Q. I think that's just, l think that's the big 13 last month. 14 pitch, so you all can make that pitch at trial. It's a 14 Q Was that when you talked to N.R.? 15 nice touch, but I'm not moved by it. 15 A. I think so. 16 MR. HOROWITZ: Mow to strike. 16 Q. So it would have been approximately February 17 BY MR. CRITION: 17 of 2010? 18 Q. What else did Jane Doe 3 tell you about her 18 A. Yes. 19 deposition? 19 Q. And was she at your house or did you see her 20 A. She didn't really tell me anything about it. 20 at a bar or were you out at a club or — 21 She just basically said she came in here and did it. 21 A. I forget where I saw her. I ran into her -- 22 Q. Were you aware that she had been at 22 oh, we were at Duffy's. We all went -- 23 Mr. Epstein's home during the time she was going? 23 Q. Which Duffy's? 24 A. I don't remember. 24 A. to dinner. On Northlake. 25 Q. Do you know how she came to be at 25 Q. RIM near I-95? 4 (Pages 135 to 138) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107835  Page 139 Page 141 1 A. Yes. 1 A. Well, yeah. She — yeah. 2 Q. Who was there other than you and N.R.? 2 Q. Okay. How does she know? 3 A. Just some friends from high school. 3 A. Because you guys asked her questions about me, 4 Q. Any other people that you know? Was Jane 4 and Pm sure she assumed I was a plaintiff suing 5 Doe 4 there? 5 Jeffrey. 6 A. No, Jane Doe 4 wasn't there. 6 Q. How about your friend El does she know that 7 Q. Jane Doe 3, was she there? 7 you have brought a lawsuit? A. No. 8 MR. HOROWITZ: Form. 9 Q. Anyone else that you know, any of the other 9 THE WITNESS: I'm sure E. told her. 10 people you knew went to Mr. Epstein's home? 10 BY MR. CRITTON: 11 A. No. 11 Q. Why would.. tell her? 12 Q. And N.R. said that she was going to file or 12 MR. HOROWITZ: Fenn. 13 she was a plaintiff also in a lawsuit? 13 THE WITNESS: Because they are friends. 14 A. Yes. 14 BY MR. CRITTON: 15 Q. How did she know that you were a plaintiff? 15 Q. How do you know El Fuld N. are friends? 16 A. I don't know who told hen 16 A. Because that's what I have heard. 17 Q. Were you upset that she knew? 17 Q. When is the last time you talked to 18 A. I mean she was one of my good friends in high 18 A. Right around her brother's accident. 19 school and she kind of knew what happened, because I 19 Q. Okay. 20 told her before. So I, she kind of already knew, so I 20 A. So probably, I don't know, like seven months 21 wasn't that upset that she knew about that. 21 ago. 22 Q. What do you mean you told her about? 22 Q. That's the last time you have spoken with her? 23 A. I mean she knew about me and Jane Doe 4 going 23 A. Yes. 24 there. She went there before, so — 24 Q. Have you tried to call her or she tried to 25 Q. Oh, she had gone there before you? 25 contact you at all? Page 140 Page 142 1 A. No. I don't, I don't remember when she had 1 A. Not recently. I don't think so. 2 gone. She went sometime in high school. 2 Q. After you said — around the time of her 3 Q. Did she ever tell you about her experience of 3 brother's accident, since that time, have you tried to 4 going to Mr. Epstein's home? 4 call her at all? Or seven months ago was the last time A. No. I just !mew she went. 5 you had any contact with her? 6 Q. Do you know how many times she went? 6 A. Yeah. A. No. 7 Q. Okay. At the time that Jane Doe 4 told you 8 Q. Did you say "Why are you filing a lawsuit? 8 that in the summer of '08 that she was bringing a 9 A. No. 9 lawsuit against Mr. Epstein or had brought a lawsuit 10 Q. So you don't know whether she has — strike 10 against Mr. Epstein, had you contacted an attorney at 11 that. 11 that point? 12 You don't know anything about her lawsuit 12 A. I don't remember. 13 other than she has filed a lawsuit against Mr. Epstein? 13 Q. Affright. Who was the first — strike that. 14 A. Yes. 14 Was it you or your parents who encouraged you 15 Q. So you mentioned N.R., Jane Doe 3, Jane Doe 4. 15 to bring a lawsuit? 16 Anyone else that you are aware that was a 16 MR. HOROWITZ: Form. 17 plaintiff'? 17 THE WITNESS: It was me. 18 A. No. 18 BY MR. CANTON: 19 Q. Who have you told that you area plaintiff in 19 Q. So your parents had nothing to do with you 20 a lawsuit? 20 bringing a lawsuit? 21 A. Just those girls. 21 A. No. 22 Q. So nobody else knows that you are a plaintiff? 22 Q. Are your parents aware now, were they aware at 23 A. No. 23 the time you hired a lawyer? 24 Q. How about il.? Does know you are a 24 A. Yes, I told them. 25 plaintiff? 25 Q. Did you hire a lawyer before you told your 5 (Pages 139 to 142) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107836  Page 143 Page 145 1 parents or were they involved in the decision? 1 Mr. Herniae 2 A. No, I told than after. 2 A. I don't, I don't remember when it was, but I 3 Q. And who did you contact — strike that. 3 just net, just met with him and I — 4 How did you — you know obviously Mr. Horowitz 4 MR. HOROWITZ: Fm going to ask you not to is seated immediately to your left, tweet? 5 discuss what -- 6 A. Yes. 6 MR. CRITTON: Just dealing with the time 7 Q. Is he the fast lawyer you met from that firm? 7 sequence. Don't tell me what he said right now. 3 A. No. I met with Jeffrey Herman. 8 not there yet 9 Q. How did you get in contact with Mr. Herman? 9 MR. HOROWITZ: There you go. 10 A. He called me. 10 BY MR. CRITTON: 11 Q. He called you? 11 Q. So if I understand the sequence correctly, you 12 A. Yes. 12 got a phone call out of the blue from Mr. Heenan about 13 Q. And where did he call you from? 13 Jeffrey Epstein. 14 A. I don't know. 14 A. Yes. 15 Q. Was it before or after Jane Doe 4 told you 15 Q. All right. You spoke with him, and he asked 16 that she was a plaintiff in a lawsuit? 16 you a number of questions, right? 1'7 A. 'think it was before. 17 A. All he really asked me was if I, if l was 18 Q. All right. So at the time that Jane Doe 4 18 involved with Jeffrey Epstein, If I was a witness or 19 told you she was a plaintiff in a lawsuit, had you 19 if— I can't temember exactly what he asked me. 20 already spoken with Mr. Herman? 20 Q. I'm going to come back to that in just a 21 MR. HOROWITZ: Form. 21 minute. Let me get the time sequence here if 1 can, Ms. 22 BY MR. CRITTON: 22 Jane Doe 7. 23 Q. Or did that occur after you spoke with Jane 23 First time he called you, he called you, you 24 Doe 4? 24 talked to him a little bit and you gave him the name of 25 A. I don't know who had, who did it first. I 25 Jane Doe 4? Page 144 Page 146 1 think it was me. I don't really know. I don't 1 A. Yes. 2 remember. 2 Q. Okay. And then sometime later you called him 3 Q. I'll represent that Jane Doe 4, Jane Doe 4's 3 or did he call you back? 4 lawsuit was filed well before yours. She's Jane Doe 4. 4 A. I called him. 5 A. Yes. 5 Q. How much time transpired between the first 6 Q. You are Jane Doe 7. Doesn't necessarily mean 6 call that he made and the second call that you made? 7 one came, hired the lawyer earlier or not, but 1 can 7 A. I don't know. 8 tell you her lawsuit was filed months before yours was. 8 Q. Was it a week? Was it a month? Was it 9 A. He called me originally at first, and then he 9 months? 10 asked me if I lotew any witnesses or anything, and I 10 A. I don't remember how long it was. 11 think I game him Jane Doe 4's number, but I never agreed 11 Q. Okay. On the first conversation that you had, 12 to start a lawsuit until later on. 12 how long did that conversation last? 13 Q. So when Mr. Herman called you, you gave him 13 A. Just like five minutes. 14 Jane Doe 4 — he called you about being a witness? 14 Q. Did he tell you he was representing anyone? 15 A. I believe so. 15 A. No. 16 Q. All right. And did you talk to him? 16 Q. Did you ask him how he got your name? 17 A. Yes. 17 A. No. I didn't know — the first time he 18 Q. Over the phone or in person? 18 called, I didn't I was kind of really, I didn't know 19 A. Over the phone. 19 who was who and who was representing who. So I was, 20 Q. And then you gave him the name of other 20 just kind of told him that I would take his number and I 21 individuals? 21 would think about it and call him back. 22 A. Just Jane Doe 4, I think. 22 Q. Okay. Well, think about what? 23 Q. And then sometime after you met with or Jane 23 A. Well he asked me if we wanted to meet. And I 24 Doe 4 was living with you in the summer, then did you 24 told him that I would think about it and call him back. 25 subsequently speak with him again, him meaning 25 Q. Was he pitching basically I could represent 6 (Pages 143 to 146) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107837  Page 147 Page 149 1 you in the case? 1 BY MR. CRITION: 2 A. No. He just asked me if I knew about Jeffrey 2 Q. Why did she call you? 3 and witnessed what happened with Jeffrey, and that's 3 MR. HOROWITZ: Forni 4 about it. And he asked me if we wanted to meet and 4 THE WITNESS: She called me m fill me in on 5 talk. And I said that I wasn't sure, you know, because 5 the case, and I knew she was like who she said she 6 I've had private detectives corning. 6 was, because Agent at the FBI told me she 7 And I wasn't sure who was on whose side, so I . 7 would be calling me. She pretty much told me what 8 told him that I would call him back. 8 was going on in his criminal case, and that's about Q. Was he soliciting or pitching his services to 9 it. And she said you might want to protect 10 you as a lawyer? 10 yourself and get a lawyer, and that's about it. 11 MR. HOROWITZ: Form. 11 BY MIL CIRITTON: 12 THE WITNESS: No. 12 Q. Okay. Did she recommend anybody, any lawyers? 13 BY MR. CRITPON: 13 A. I don't remember. 14 Q. Well, why did he want to meet with you? 14 Q. Do you remember her giving you any names of a 15 MR. HOROWITZ: Form. 15 • lawyer saying 'Tm going it give you three names," or 16 BY MR. CRITTON: 16 "If you need some help finding a lawyer, I'll give you a 17 Q. What did he tell you? 17 name'? 18 A. He Just wanted to talk about the whole Jeffrey 18 A. She said if I wanted a lawyer, to call back. 19 thing with me. 19 And she had a list, I think, but she didn't recommend 20 Q. Why would you want to talk with him about it? 20 anybody. 21. MR HOROWITZ: Form. 21 Q. Did you ever call her back for her 22 THE WITNESS: Because I heard that, you know, 22 recommendation? 23 there's like stuff going on with, with people, so I 23 A. No. I talked to Agent about it, and 24 kind of wanted to protect myself. 24 she said basically what I was supposed to do. And she 25 25 said it was up to me basically if I wanted to hire a Page 148 Page 150 BY MR. CRITTON: 1 lawyer or not. 2 Q. What did you hear was going on with people? 2 Q. Did Agent give you any names? 3 A. Nothing. I just heard that, it was when —I 3 A. No. forget who called me and said — I think it was Maria or 4 Q. Did anyone from the FBI or US attorney's something. She said, you know, to protect yourself, you 5 office ever give you a name of a lawyer — 6 might want to get a lawyer. 6 A. No. Q. Who is Maria, MIME ) 7 Q. — to contact? 3 A. I think so. A. No. 9 Q. Was that the US attorney? 9 Q. Did you speak with — let mat back. 10 A. Yes. 10 When you spoke with Ms. 11 Q. And had you ever met with IM 11 that before or after Mr. Herman contacted you? 12 A. No. 12 A. It was before. 13 Q. You never met the lady? 13 Q. And then how much time transpired or rested 14 A. No. 14 before Mr. Herman contacted you about whether you were 15 Q. So somebody who you just referred to as 15 involved or to ask you questions about Jeffrey Epstein? 16 calls you out of the blue. Why would — 16 A. About a couple of months. 17 A. She -- 17 Q. And do you know when Mr. Herman approximately 18 Q. Let me finish my question. 18 timewise called you? 19 You said you let me ask you this. Did the 19 A. No. 20 ady, who you have now identified as 20 Q. Was it before Jane Doe 4 moved in with you 21 assistant US attorney, did she call you 21 that sununer? 22 before Mr. Hemian or after Mr. Heiman? 22 A. Yes. 23 MR. HOROWITZ: Form. 23 Q. Was it shortly aver the police had 24 THE WITNESS: Before. 24 contacted you? 25 25 A. No. It was a little while after that. 7 (Pages 147 to 150) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 EFTA01107838  Page 151 Page 153 i Q. Was it after the FBI interview? Q. Okay. And did you investigate him at all? 2 A. Yes. 2 A, Yes. 3 Q. Do you know when the FBI interview took pi 3 Q. Did you go online? 4 A. I third( I was a sophomore in college or 4 A. !looked his name up. 5 maybe -- 5 Q. Where? 6 Q. That's '05, that would have been -- 6 A. Online. 7 A. I think I was a sophomore or freshman. 7 Q. And what did you find out? 8 Q. So that would have been what, approximately 8 A. That he was a sexual abuse attorney. 9 '07? 9 Q. And did you ask him before you hired him 10 A. Yes. 10 whether he was representing any other people associated 11 Q. Let me just stick with — so when Mr. Haman 11 with the Epstein matter? 12 called you the first time, did he say what he was doing? 12 A. No. 13 He obviously wanted to get some information about 13 Q. When you called him back and before you hired 14 Jeffrey Epstein and you, right? 14 him, did you ask him how he ever got your name? 15 MR. HOROWITZ: Form. 15 A. No. 16 THE WITNESS: It didn't sound like it. 16 MR. HOROWITZ: going to assert the 17 BY MR. CAI-ETON: 17 privilege. I understand what you're trying to do, 18 Q. Did you say "How did you get my name?" 18 but I'm going to assert the privilege as to the 19 A. No. 19 conversation in that the entire conversation was 20 • Q. Were you surprised that sane lawyer out of the 20 leading towards the result of obtaining a lawyer. 21 blue called you to ask you about Jeffrey Epstein and you 21 So that's my position, and we can -- 22 didn't know who they were a how they had gotten your 22 BY MR. CRITTON: 23 ,me? 23 Q. Are you going to follow your lawyer's — if he 24 A. I thought — I had no idea. That's why I 24 tells you — if he claims a privilege, are you asserting 25 didn't agree to meet with him at first, because I didn't 25 that privilege? Page 152 Page 154 1 know if he was, you know, on your side or their side or 1 A. Yes. 2 hying to check me or whatever, so that's why I waited a 2 MR. HOROWITZ: Yes. I just want to tell her 3 little bit to call him back. 3 what I'm invoking. 4 Q. When you did call him back, however much time 4 As to this second telephone conversation, I'm 5 transpired, what did you say to him? 5 instructing you that you have a privilege not to 6 MR. HOROWITZ: We're going to assert the 6 answer questions about the second conversation. 7 privilege on that, but you can make the proffer. 7 THE WITNESS: Okay. 8 BY MR. CRITTON: 8 BY MR. CRITTON: 9 Q. You called him back, correct? 9 Q. Did you hire Mr. Herman in the course of the 10 A. Yes. 10 second conversation? lust yes or no. 11 Q. Okay. All you knew, he was a lawyer? 11 A. He came to Orlando and we met and then -- 12 A. Yes. 12 Q. No, no. Well get there. 13 Q. You didn't know who he represented? 13 In the second conversation, did you say "I 14 A. No. 14 want to hire you" or did you just say -- 15 Q. If anyone? 15 A. No. 16 A. No. 16 Q. — "I'd lilte to meet with you"? 17 Q. Okay. He could have been Mr. Epstein's 17 A. "I'd like to meet with you." 18 lawyer, he could have been anybody's lawyer, for all you 18 Q. Okay. So how long did the second conversation 19 'mew, right? 19 last? 20 A. I mean he told me he —10ce no, I think he . 20 A Not long. 21 told me he wasn't — he was like representing — I don't 21 • Q. • Five 'minutes? 22 know, he didn't say -- I don't know. I don't remember 22 A. Just about. 23 why I actually called him back. 23 Q. What did you tell him? 24 . Q. Why did you call him back? 24 MR. HOROWITZ: I'll instruct her not to 25 A. Because I wanted to hear what he had to say. 25 answer. Well assert the privilege, a privilege, OXISCIZA 8 (Pages 151 to 154) .. (561) 832-7500 PROSE COURT REPORTING AGENCY,: INC. (561) 832-7506 EFTA01107839  Page 155 Page 157 the attorney/client privilege. I. everybody and her parents fording out and her sister MR. CRiTFON: I understand. 2 finding out and her being depressed and humiliated, I 3 BY MR. CRITTON: 3 mean yeah, I would assume that's some trauma for her. 4 Q. And you are going to follow his direction, 4 Q. Okay. Has she told you she's depressed? 5 correct? 5 A. Yeah, and when she found, her parents found 6 A. Yes. 6 out and all that, she was depressed, she told me. Q. And until Mr. Herman came to Orlando -- strike 7 Q. The way you've described it is Jane Doe 4's that. 8 main emotional or psychological — let me strike that. 9 How much time passed between the second 9 Her main psychological injury from at least 10 conversation and Mr. Herman came to Orlando? 10 the way you've described it is she's been humiliated and 11 A. Not long. Maybe a couple weeks. 11 depressed because somebody other than her friends, in 12 Q. Did anyone else come up with Mr. Herman to 12 particular, her parents and her sister, found out that 13 meet with you? 13 she had gone to Mr. Epstein's house? 14 A. No. 14 A. Not from that. From just going when she was 15 Q. Just you and Mr. Herman met? 15 younger. She regrets it, and she even told me i wish I 16 A. Yes. 16 never went when I was younger. i was confused and -- 17 Q. Where did you meet? 17 Q. She — fm sorry. 18 A. At Starbuck's. 18 A. Go ahead. 19 Q. Okay. And did you sign an agreement then to 19 Q. Did she tell you that she went — well, you 20 have him represent you? 20 !mew she went both before she was 18 and after she was 21 A. After lmet with him and heard everything he 21 18, right? 22 said, yes, I did. 22 A. Yeah, l guess. 23 Q. Okay. Before that, that is, before you 23 Q. All right. And did she tell you she was more 24 actually hired him, bad you discussed with him what had 24 confined when she was 17 than when she was 18, or did 25 happened to you, that is — well, let me strike that. .25 she ever describe to you that there was a difference Page 156 Page 158 1 In the second conversation did you give him 1 when she went at 17 or 18? 2 any information as a witness as distinct from your own 2 A. I don't know. She never described anything to 3 personal circumstances? 3 me. 4 MR. HOROWITZ: i have to assert the privilege. 4 Q. Did she ever say "Gees, the day I turned 18 5 BY MR. CRITTON: 5 and was a freshman at college, i still went to see 6 Q. And you are going to follow his direction? 6 Mr. Epstein"? 7 MR. HOROWITZ: Yes. Good try. 7 A. No. 8 MR. CRITTON: That's not a good try. Just -- 8 Q. Okay. Did she ever say, "Well, gee, just BY MR. CRITTON: 9 before I turned 18, i had these emotional injuries, but 10 Q. Has Jane Doe 4 told you — let me strike that. 10 at 18 everything was okay when I went to Mr. Epstein's'"? 11 I'd ask you to assume that she's brought the 11. Did she ever say that to you? 12 same S50 million lawsuit that you have, different facts, 12 MR. HOROWITZ:. Fa 13 but she wants 50 million bucks too, at least in her 13 THE WITNESS: No. 14 complaint that she's asserted against Mr. Epstein. 14 BY MR. CRITTON: 15 Did she ever tell you any injuries or damages 15 Q. All right. Did she ever distinguish to you 16 that she ever sustained as a result of being at 16 having been to Mr. Epstein's before she was 18 or after 17 Mr. Epstein's home? Has she ever said anything to you 17 she was 18; that is, that any time period was different 18 about it? 18 for her? 19 A. We never really talked about her. 19 A. I don't remember. 20 Q. Even through today's date, she's never told 20 Q. You don't remember her telling you that, 21 you any damages or how she was damaged or any injuries, 21 correct? 22 psychological or otherwise, that she ever sustained at 22 A. No -- yes. I don't remember her telling me. 23 Mr. Epstein's house; is that correct? 23 Q. All right, I understand. 24 She's never discussed that with you? 24 Now you've known Jane Doe 4 for a long time? 25 A. I mean other than being humiliated by 25 A. Yes. 9 (Pages 155 to 158) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. . (561) 832-7506 EFTA01107840  Page 159 Page 161 1 Q. Since '02, I think you told me. 1 BY MR. CRITTON: 2 She's been through some rather traumatic 2 Q. Did you ever