EFTA00750707.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME I 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, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 a.m. - 6:10 p.m. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Reported By: Pamela J. Sullivan, RPR, FPR, CLR Prose Reporting Agency, Inc. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333.772-1552) 170ae621-3493-40cd-8666.0Do698ca2735 EFTA00750707  Page 4 1 APPEARANCES: 1 2 On Shelf deb* Plaintiff. Jane Doe 2 INDEX 3 BRAD 1. EDWARDS, ESQUIRE 3 ROTHSTEIN ROSENFELDT ADLER Las Dietary Case, Sete 1650 4 WTINESS: DIRECT CROSS REDIRECT RECROSS 401 Es Las Cass Boalceard 5 JANE DOE 5 Mont 33)01 6 BY MR. CRITTON 5 On hLlfof Alley Esidn: ROBERT D.EAMON, At, ESQUIRE BURMAN, CRITTON, LUTHER a COLEMAN.UP EXHIBITS MARKED 9 303 Banyan Hcadevar4 Sake 400 10 , Banda 33401 10 1: DESCRIPTION PAGE 12 Defendant's No. I 12 Ooh of the Defendant. WES'Engel', 13 JACK ALAN GOLDBERGER. ESQUIRE (Copy of Plaintiff)Wimess Identification Card) ATTERBURY. GOLDBERGER & WEISS, PA 13 14 250 Asinlian Mese South Defendant's No. 2 I16 Suite 1400 15 West Aim Bach, Plaids 33401-5012 14 (Victim's Petition) It OnEthan ofPUSHin Added Cu.No. 08-80469. 15 Defendant's No. 3 118 17 iSEDRO M. GARCIA. ESQUIRE GARCIA LAW FIRM. PA (Victim's Motion to Unseal Non-Prosecution Aff u.nt) le 224 Dan Street Stith 900 16 Defendant's No. 4 121 19 C 3340) 17 (Declaration of A. Marie Villafrra) 20 18 On NEN(oflane Does I duo* 8: 19 n (4" Marked off the record.) ADAM D. nortown2, ESQUIRE 20 MERMELSTEIN & HOROWITZ. P.A. 21 11205 Disease Bothnia Suite 2218 elndde 33160 24 24 25 25 Page 3 Page 5 On behalf of the Plaintiff- 1 PROCEEDINOS JACK P. MI, ESQUIRE 2 --- SEARCYDENNEY SCAROIA BARNHART & SHIPLEY, P.A. 3 Deposition taken before Pamela J. Sullivan, 3 2139 Palm Beach Lakes Boulevard :ach, Florida 33409 4 Registered Professional Court Reporter and Notary Public 4 5 in and for the State of Florida at Large, in the above 6 cause. 5 On behalf of the B.B.: 7 6 ADAM J. LAWN°, ESQUIRE LEOPOLD KUVIN (Discussion held off the record.) 2925 PGA Boulevard, Suite 200 9 MR. CRITTON: Let's get started. dens, Florida 33410 10 MR. EDWARDS: Brad Edwards, and I represent 8 11 Jane Doe. ' 9 12 MR. HILL: Jack Hill, on behalf (AM. 10 13 MR. HOROWITZ: Adam Horowitz, on behalf of 11 ALSO PRESENT: 14 Jane Does 2 through 8. 12 Jeffrey Epstein, via video conference Stan Sanders, Vidoograpber 15 MR. LANGINO: Adam Langino, on behalf of B.B. 13 16 MR. CRITTON: Bob Critton, on behalf of 14 17 Jeffrey Epstein. 15 18 MR EDWARDS: And, Mr. Critton, I don't think 16 17 19 we've had this Cant Reporter before, so maybe we 18 20 want to instruct as to how we're dealing with the 19 21 names, how they're going to be typed up. 20 21 22 MR. CRC-TON: Pamela, are you familiar with how Cindy did the names at all? 24 COURT REPORTER: Let's go over it. 24 25 MR. CRITTON: All right. What we -- what 25 2 (Pages 2 to 5) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) fleae621-3493-40cd-8666-000698ca2735 Electronically signed by Pamela Sullivan (501.333-772-1552) EFTA00750708  Page 6 Page 8 1 we've done in the past is, as with regard to anyone 1 trat 2 who's identified as a Plaintiff in the case, and 2 i t, you claimed all sorts of privileges 3 only that group, you know, absent some other 3 and, and other objections and instructed her not to 4 agreement amongst the, the clients or the parties 4 answer. Obviously, the judge has to consider a 5 and their attorneys is, is we will refer to them by 5 transcript. 6 initials only, such as Jane Doe, who's seated in 6 MR. EDWARDS: Agreed. 7 front of us. She will be — well, except she's 7 MR. CRITTON: So I would say as to the 8 gone as lane Doe, so we should keep her as Jam B transcript, no, and with the transcript that Pamela 9 Doe. So much for that ewertion, but... 9 is going to prepare, it's going to have — it won't 10 And Mr. Hill's ellen ., will be 10 disclose Jane Doe's name or Jane Doe's name. All 11 referred to as , because that's how 11 right. So with regard to the video, as' — as 1 12 we referred to her, and she has -- she gave up 12 indicated to you to the extent that the video would 13 anonymity. 13 be necessary to be filed for any purpose or to use 14 Jane Doe's 2 through 8, we may use their real 14 for any purpose, you have 15 days to file 15 names, and then we'll just use, if it's 15 something. lf, in fact, the video was used, I 16 Sally Jones, it would be S.J. And then what you do 16 would do that which was necessary so that 17 is, is on a separate piece of paper, as Cindy did, 17 Jane Doe's face would not be disclosed, so that no 18 you will give us a key that ties in with any name 18 one could identify her. 19 that we've designated by a first or a last name — 19 MR. EDWARDS: Okay. Well, I — if you're 20 or both. 20 only talking about blocking out her face as the 21 MR. EDWARDS: All right. And one other thing 21 only way to protect her anonymity, we, we wouldn't 22 I want to — I want to put on the record, I know 22 feel that that would be accommodating enough to, to that you disagreed last time, but I think that 23 secure her anonymity. 24 it's, to make the record clear, we feel strongly 24 But now I'm understanding that you're saying 25 that this deposition and the transcript and the 25 you may file this with the court, which I have much I Page 7 Page 9 1 video remain confidential, and that the witness's 1 less a problem with than you posting it on the 2 anonymity is protected, absent some court order 2 Internet or using some other device to post it to 3 directing otherwise, as we feel that's consistent 3 the public, which is what was implied last time. 1 with the court orders that have already been 4 And I think the example you gave was that another s entered, as well as the instructions of the various attorney has posted your client's deposition on the 6 judges presiding over these cases. 6 Internet. 7 I'm assuming, if you are in disagreement of MR. CRITTON: All right. Let, let's deal 8 that, then you will allow me 15 days to file a 8 exactly what the issue is. If Spencer Kuvin, for 9 motion in that regard, if you think that's publicity, and for no other reason, contacted 10 necessary. 10 Jose A. Lambiet, who in turn then put it on his 11 MR. CRITTON: Yeah. Well we, we had this 11 website so that everyone could view the question, 12 discussion at the deposition of.l. 12 and he did it to embarrass, to humiliate, it was 13 MR. EDWARDS: Right. 13 improper, it was inappropriate, I hope I wouldn't 14 MR. CR1TTON: And you dealt specifically with 14 use the same conduct or what I would say lack 15 the video, not the transcript, is my recollection. 15 of professionalis to do something like that. m 16 And I said it, with regard to the video, there's — 16 MR. EDWARDS: Well, but, obviously, the 17 there are orders granting your client, and in her 17 difference is Mr. Epstein's anonymity has not been 18 case., and I think in Jane Doe, anonymity. And 18 protected in this case, and these victims have. 19 as such, we don't plan to violate that court enter 19 So... 20 to the extent that the transcript -- and a perfect 20 MR. CRITTON: So it's okay to humiliate and 21 mantS of it is, is, if you think that the — that 21 embarrass someone and to be unprofessional? 22 theM. transcript can't be filed, it's absurd, 22 MR EDWARDS: This has nothing to do with me 23 because.. claimed the Fifth Amendment about 30 or my clients. 24 to 50 times. So in order to get some ruling from 24 MR. CRITTON: All right. 25 the Court, the Court's going to have to look at the 25 14/ MR. EDWARDS: So arc we noon the same page, AaiGIVaSnes%)4.0..sstnr.M.. A 3 (Pages 6 to 9) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Beetronlcally signed by Pamela Sullivan (601-333-772-1552) I reae621-3493-40cd-8666-00.3698Ca2136 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00750709  Page 10 Page 12 1 and I need to file a motion to protect the 1 Q. At the address where you're currently 2 confidentiali ty of the video and the deposition 2 residing, does anyone live with you? 3 transcript, or do you agree that it's - it should 3 A. Yes. 4 remain confidential, but for whatever motions you 4 Q. Who? 5 have to file and attachments you have to make to 5 A. My daughter and my boyfriend. 6 the court file. 6 Q. Are you living in an apartment, a house? 7 MR. CRITION: You, you need to file whatever 7 What kind of accommodations? 8 motion you think is appropriate. Pm going to do 8 A. A house. 9 nothing to breach the anonymity order that has been 9 Q. What city is the house located in? 10 entered by the Court. So if you if you think 10 MR. EDWARDS: Don't answer. 11 that some additional order is necessary, you have 11 She's not going to answer any other questions 12 15 days to file something with the Court, and then 12 about the location of her address or the location 13 I'll respond to it, Brad. 13 where she's residing, just out of fear for her own 14 MR. EDWARDS: Okay. Thanks. 14 safety and the safety of her daughter. 15 MR. CRITIC/14: Okay. 15 MR. CRJTTON: Okay. 16 And Sid Garcia showed up. 16 BY MR. CRITTON: 17 MR. GOLDBERGER: What am I? 17 Q. Ma'am, has, has anything occurred since 18 MR. CRITTON: And Jack Goldberger, too. 18 you've been represented by Mr. Edwards that causes you 19 Sony, you're not just a potted plant here. 19 concern about your safety or well-being? 20 Thereupon, 20 A. Yes. 21 JANE DOE, 21 Q. What? 22 Having been first duly sworn or affirmed, was examined 22 A. I have seen a lot of cars passing by my and testified as follows: house, watching, looldng at my house, and going by very 24 THE WITNESS: Yes. 24 slowly, several times a day. There have been cars that 25 25 were parked across the street from my house on several Page 11 Page 13 1 DIRECT EXAMINATION 1 different occasions, cars that I had never seen before. 2 BY MR CRITTON: 2 There have been people who have gone to speak to my 3 Q. Would you please tell us your full name, 3 friends and my family members and ask them questions 4 please. 4 about me. 5 A. Jane Doe. 5 Q. So why — why — well, let's start with the 6 Q. And you're going to need to speak up, ma'am, 6 cars. On how many occasions since you well, on how 7 because I could barely hear you. All right 7 many occasions have you seen what you thought were 8 A. Jane Doe. B suspicious cars, as distinct from just like — as 9 Q. What's date of birth? 9 distinct from just cars driving by? 10 A. 10 A. Them have been so many, I can't — I can't 11 Q. And where do you currently reside? 11 count 12 MR. CRITTON: Don't answer. 12 Q. Can you identity any of those suspicious 13 She's not going to give her current address, 13 cars? Color? Make? Model? 14 and it's out of fear for her safety. And that's 14 A. For one, there is a blue Durango SUV that 15 the only question you're likely not going to get an 15 comes by a lot 1,1have taken pictures of it. I have 16 answer to today. 16 taken pictures of all the cars. 17 BY MR. CR/77ON: 17 Q. Oh, you have? And where, where are those 18 Q. Let me ask you this: Do ou 18 pictures? Did you take them on a digital camera? 19 nssidecl over the years at 19 A. Yes. 20 EIR true? 20 Q. Okay. And what did you do with those 21 A. Yes. 21 pictures? 22 Q. All t. And whose address is that? 22 A. I sent them to Brad. 23 A. 23 Q. And Brad, Mr. Edwards? 24 Q. And her name is? 24 A Yes. 25 A. 25 Q. Are you aware whether he's filed any motion 4 (Pages 10 to 13; (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (563) 832-7506 Electronically signed by Pamela Sullivan (501.333.772-1552) ffeae621-3493-40“1-8666-00e698ca2735 Electronically signed by Pamela Sullivan (501-333-772-1652) EFTA00750710  Page 14 Page 16 1 with the Court to try to identify who, to keep those 1 talked to families and friends, where they have — let 2 cars away from you? 2 me strike that. 3 A. Not that I'm aware of. 3 You indicated various individuals had done -- 4 Q. Okay. How many pictures have you taken? 4 had talked or had spoken with family and friends about 5 A. Four or five. 5 you -- 6 Q. And, and in terms of parked cars, have you 6 A. Yes. 7 taken pictures of any of the parked cars? 7 Q. correct? 8 A. One. 8 All right Tell me which family members have 9 Q. What was that car? Was that the blue 9 been contacted and asked questions about you. 10 Durango? 10 A. The only one that I really !mow of is my 11 A. No. It was a silver — Pm not sure what 11 sister. 12 kind of car it was. 12 Q. And who's that? 13 Q. Okay. Do you still have -- do you still have 13 A. your photographs of those cars on your camera? 14 Q. And what did tell you? 14 15 A. Not on my camera. 15 A. She just told me that me some people went to 16 Q. Did you take — how did you send them to 16 her house and asked her some questions about me. 17 Mr. Edwards? 17 Q. When did tell you that? 18 A. I have them on a disk. 18 A. lint not sure how long ago it was. She 19 Q. All right. And tell us — tell the members 19 actually sent me a text message. 20 of the jury how many times you've called the police 20 Q. Was it within the last week? Was it in the 21 about this. 21 last month? Was it a year ago? Give me your best 22 A. I haven't called the police, because 22 estimate. 23 they — nobody ever came out and harassed me. I just 23 A. Probably a month, maybe two months. 24 saw the cars passing my. 24 Q. And did she tell you who the people were that 25 Q. All right. So no ones harassed you; no 25 talked to her? Page 15 Page 17 1 one's intimidated you. All you've seen is cars that you 1 A. No. 2 can't identify driving by and/or parking across the 2 Q. Did you ask her? 3 street; is that correct? 3 A. Yes, I did. 4 MR. EDWARDS: Object to the form. 4 Q. And what did she say? 5 MR. CRITION: You can go ahead and answer. A. She said that they worked for 6 MR. EDWARDS: Well, Pm going to object - 6 Jeffrey Epstein. MR. CR1TTON: No, no. 7 Q. And did she say how those people got in 3 MR. EDWARDS: -- and ask her not to answer -- 8 contact with her? 9 MR. CROTON: It's form. 9 A. They went to her house and knocked on het 10 MR. EDWARDS: — if it is attorney-client 10 door. 11 privilege information. Because you're acting like 11 Q. And did she tell you what she said to them? 12 she can't identify than, when, in reality, she may 12 A. No. 13 have been able to identify them. 13 Q. Did she tell you whether she spoke with 14 MR. CRITTON: Is that a form objection? 14 her — spoke with them? 15 MR. EDWARDS: Pm telling her not to answer. 15 A. She said she did talk to them. 16 It's attorney/client information. 16 Q. She did not? 17 MR. COTTON: Would you read my question 17 A. She did. 18 back — 18 Q. All right Did she say where — did she talk 19 MR. EDWARDS: (Inaudible) her attorney. 19 to them at the house? 20 MR. CRITTON: -• please. 20 A. Yes. 21 (Whereupon, the requested portion of the 21 Q. And did she — and did you say, well, what 22 record was read aloud by the Court Reporter.) 22 did you say about me? 23 THE WITNESS: Yes. 23 A. Yes, I did. 24 BY MR. CRITTON: 24 Q. Okay. And did you say, what questions did 25 Q. All right. Now, you said some people have 25 they ask? 5 (Pages 14 to 17) (561) 832-750C PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333.772.1552) Electronically signed by Pamela Sullivan (501-333-772-1552) f7eae821-3493.40cd-8080-00e888ca2735 EFTA00750711  Page 18 Page 20 1 A. Yes, I did. 1 A. Yes. 2 Q. And when you said, what questions did they 2 Q. All right. So we've had nine months in '09. 3 a*, what did she say? 3 Of, of the — of the nine months in 2009, what portion 4 A. She, she said she doesn't really know. I 4 or what months can you • • that you did not have a 5 guess she doesn't remember. She says that she was asked 5 good relationship wi ? have only been on speaking terms with 6 7 8 if she knew about my going to Jeffrey Epstein's house, and she told them that she gave me a ride there before. Q. And was that true? 6 7 milQ. So for the past maybe three months. the past three months, which would be 9 A. Yes. 9 basically June-ish, beginning of June — 10 1Okay. On how many times did your sister, 10 A. Yeah. 11 give you a ride to Jeffrey Epstein's home? 11 Q. — through today, you're on good tents with 12 A. Three, maybe four. 12 her? 13 Q. And I assume you knew that she had driven you 13 A. Yes. 14 to Mr. Epstein's house, separate and apart from her 14 Q. All right. And good terms means you're 15 telling you that the other day, or a month ago. 15 acting like sisters — like I would say more normal 16 A. Excuse me? 16 sisters would, have a nice conversation, you can talk to 17 m liassume you were aware that your sister, 17 her, you're supportive of each of one another, 18 , drove you to Mr. Epstein's house prior to the 18 et cetera? 19 last month or two; is that correct? 19 A. Yes. 20 A. Yeah. 20 Q. All right. Do you have any other sisters? 21 Q. And that is, her telling you that did not 21 A. Yes. 22 refresh your recollection; you knew thatMl. had 22 Q. Okay. First ofalla what's her 23 driven you to Mr. Epstein's home; true? 23 date ma. of 24 A. Yes, I knew that. 24 A. I don't know what year. 25 Q. Okay. Did she say how long she had spoken to 25 Q. How old is she? Page 19 Page 21 1 the people? 1 A. She's six years older than I am. 2 A. No. 2 Q. So do you have another sister? 3 Q. She, meaninga. 3 A. Yes. 4 Did she — other than saying she gave a ride 4 Older or younger? 5 to you to go to Mr. Epstein's house, did she tell the 5 A. Older. Q. her name? 6 7 8 individuals who came to her home anything else? A. Not that I know of. Q. Okay. How long did you — well, let me 6 7 8 A. it Q. How old is-? 9 strike that. 9 A. She is two years older than I am. 10 I alb /lave a good relationship with 10 Q. ow old today? 11 your sister, 11 A. 12 A. It's on and off. We fight often. 12 Q. And 13 Q. Are you on a good relationship with her now? 13 A. She be on 14 A. Right now l aro. 14 Q. She's now. Andes is, you said, was 15 Q. Has that been true for the last six months? 15 how old, how many years — 16 A. No. 16 A. Two years older than me. 17 Q. Okay. Was it. sometime within tiniest 17 Q. So she's.? 18 six months? 18 A. Yes. 19 A. Yeah. 19 Q. All children of the same marriage, with the 20 Q. When was that? 20 same mother and 21 A. Fm not sure exactly how long ago it was. 21 A. My sister., has a different father. 22 I— 22 Q. What's her father's name? 23 Q. Let me — let me rephrase my question. We're 23 A. I don't know. 24 in the year 2009, almost at the end of September 30th 24 Q. Does she know? 25 today. You're aware of that? 25 A. No. 6 (Pages 18 to 21) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) 170a0621-3493.40cd.8666-000698ca2735 Electronically signed by Pamela Sullivan (501.333-772.1662) EFTA00750712  Page 22 Page 24 1 Q. No one knows? 1 A. She does not have a home phone number. 2 A. No. 2 Q. Does she have a cell phone? 3 Q. So your mother -- your mother — obviously, 3 A. Yes. 4 same mother? 4 Q. Do you consider a cell phone a phone number? 5 6 7 a A. Yes. Q. A. And your mother's name is what? 5 6 7 A. Yes, but not her home number. Q. A. allit her cell phone number? 8 Q. Lt name? 8 Q. What's your cell phone number? 9 A. 9 A. My cell phone number? 10 Q. Where does she live? 10 Q. Yes, ma'am. 11 A. I don't }mow her address. 11 MR. EDWARDS: Don't answer. 12 Q. When is the last time you saw her? 12 mean, you're not going to call her, so I'm, 13 A. About a week or so ago. 13 I'm objecting and, and in the witness not 14 Q. :Where did you see her? 14 to give out her cell phone number on the record 15 A. She came to my house. 15 right now. 16 Q. So at least you — you at least told your mom 16 BY MR. CRITfON: 17 where you live? 17 Q. Okay. Why don't you want to — well, you're 18 A. Yeah. 18 going to follow your lawyer's instruction? If he tells 19 Q. All right. Now, what — what's her 19 you not to answer a question, you're going to follow 20 date of 20 that instruction? 21 A. 21 A. Yes. 22 Q. Good relationship with int 22 Q. Okay. And — 23 A. We don't speak on a regular basis, but we are 23 (Discussion held off the record.) 24 nice to each other, I guess. 24 BY MR. CRITTON: 25 Q. Where does she live? 25 Q. How long have you — the current cell phone Page 23 Page 25 1 A. Alabama. 1 that you have now, how long have you had it? 2 Q. Do you know her address? 2 A. About two years. 3 A. No, I do not. 3 Q. Did you have a cell phone before that time? 4 Q. Is she married? 4 A. Yes. 5 A. No. 5 Q. Okay. Bow long did you have that cell phone? 6 Q. Any children? 6 A. I'm not sure. I didn't have it for very long, and I lost it. 7 8 A. Yes. Q. How many? 7 8 9 A. umber? A. Two. 10 Q. And ever been married? 10 Q. Did you ever use a cell phone to call 11 A. No. 11 Mr. Epstein's home? 12 Q. What does she do for a living? How does she 12 A. Yes. 13 support herself? 13 Q. issirt the number you would have 14 A. I — I'm 14 used, the 15 Q. Okay. where does she live? 15 A. No. 16 A. 16 Q. Okay. Did you have a prior cell phone 17 Which is whey o 17 number? 18 A. Ws off of 18 A. Yes. 19 Q. West Palm Beach? 19 Q. All right What was that number? 20 A. Yes. 20 A. I don't remember the full number. I remember 21 Q. Does she live there with anyone? 21 that it started with 352. 22 A. Yes. 22 Q. Was it your own? Was it under your name? Q. Do you know her address, exact address? A. No. 24 A. No. 24 Q. issis it under? 25 Q. Do you know her phone number? 25 A. 7 (Pages 22 to 25) (561) 8 32-7 5 0 0 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501.333-772-1652) 17eae621-3493-40cd-8666-00c693ca2735 Electronically signed by Pamela Sullivan (501-333-772-1552) EFTA00750713  Page S Page 28 1 Q. III..? 1 At some point, Mr. Edwards came to represent 2 A. Yes. 2 you; true? 3 Q. Does she still have that same cell phone? 3 A. Yes. 4 A. NO. 4 Q. All right. And when did Mr. Edwards — when 5 Who was the service provider, her number? 5 did you hire Mr. Edwards to represent you? 6 A. Sprint, i believe. 6 A. Pm not sure exactly what day that was. 7 Who's your service provider right now? Q. Clearly, it was before the lawsuit was filed, 8 A. Metro. 8 which was August 13th; correct? 9 Q. I'm sorry? 9 A. Ulbhult Yeah. 10 A. Metro PCS. 10 Q. All right How many months prior to that 11 Q. Have you used your cell phone is a 11 lawsuit being filed did Mr. Edwards begin to represent 12 friend of yours? 12 you? 13 A. Yes. 13 A. I'm not exactly score. 14 Q. Okay. is a friend of yours? 14 . There was another suit that was filed 15 A. Yes. 15 hair:mit, Jane Doe. It dealt with a claim of, 16 Q. Okay. Are you aware of any other individuals 16 of asserting some sort of victim rights. Were you that 17 who are Plaintiffs in — and are suing Mr. Epstein for 17 Jane Doe? 18 money? 18 A. I don't know. 19 A. No. 19 Q. Okay. Well, are you aware of any other 20 Q. Do you call — do you have a home phone? 20 lawsuit that's been filed — that was ever filed on your 21 A. Yes. 21 behalf, where Mr. Edwards represented you, other than 22 Q. A land line? 22 the current lawsuit, Jane Doe versus Jeffiey Epstein? 23 A. Yes. 23 A. I don't know. 24 All right. I assume you've called bode 24 Q. Okay. So you — you're unaware of any 25 midi.. on your cell phone? 25 lawsuit that Mr. Edwards has ever filed on your behalf; Page 27 Page 29 1 A. Yes. other than Jane Doe versus Jeffrey Epstein; is that 2 Q. All right. And I assume that you talked to 2 correct? 3 them about your cases from time to time; true? 3 A. Well, I would probably be aware, but I'm 4 A. No. 4 obviously not a lawyer, so I don't really know. 5 Q. You so if I ask you is it your testimony, 5 Q. You're — before Mr. Edwards filed your 6 as you sit here today, that since the time you filed the 6 lawsuit here, in this instance, you had to give him 7 lawsuit against MrStein, you have never discussed 7 authority; didn't you? 8 your lawsuit withM.? 8 A. Yeah. 9 A. No. 9 Q. Okay. Have you ever given Mr. Edwards 10 Q. That's not true — that's not correct? 10 authority to fide any other lawsuit anyplace on your 11 A. What is not correct? 11 behalf; yes or no? 12 Q. All right. Listen -- let me ask the question 12 A. I don't know. 3.3 again. 13 Q. Okay. Well, you can't answer that just so 14 Is it a correct statement, that is what Fr() 14 for the jury — ladies and gentlemen of the jury, you 15 going to say, is this true, that since the time you 15 can't answer that question yes or no; is that what 16 filed your lawsuit in August of 2008, you have not 16 you're telling us? 17 discussed your lawsuit with M.; is that correct? 17 MR. EDWARDS: She's not going to answer the 18 A. That is comsat. 18 question because you're asking attorney/client 19 Q. And you've not discussed either your lawsuit 19 privilege information. 20 or any aspect of your lawsuit or your interaction with 20 MR. CRITTON: She's already asked — she 21 Mr. Epstein with.. since August 13th, 2008; is that 21 already answered the question, so you waived the 22 correct? 22 attorney/client privilege. So now — 23 A. Yes. 23 MR. GARCIA: Right 24 Q. All right Since August 13th — well, let me 24 MR. EDWARDS: That's your — that's your 25 strike that. 25 opinion, but she's not going to answer — answer 8 (Pages 26 to 29) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Pamela Sullivan (501-333-772-1552) Electronically signed by Pamela Sullivan (501-333-772-1552) fteao621-3493-40cd-8666-000698ca2735 EFTA00750714  Page Page 32 1 any more questions along this line. So — 1 A. Last Thursday. 2 MR. CRITTON: Okay. 2 Q. You say he's at Okaloosa? 3 MR. GARCIA: —you can ask as many questions 3 A. Right now he's in Martin County, but he was 4 as you want. 4 at Okaloosa Prison. 5 MR. CRITTON: She's not your client -- 5 Q. Okay. And he's serving a sentence for having 6 MR GARCIA: That's right. 6 murdered a young boy a true? 7 MR. CRTITON: — all right, Mr. Garcia? 7 A. Yes. 8 She — she — 8 Q. And that occurred when you were how old? 9 MR. GARCIA: You made a misstatement of the 9 A. Twelve. 10 law. You can't waive attorney-client privilege. 10 Q. How long have you had the tattoo, ma'am? 11 MR. CRITTON: Sure, you can. 11 A. Since lives 18. 12 MR- GARCIA: It has to be knowing and 12 Q. Where did you get the tattoo done? 13 intelligence. And she -- she — 13 A. At the 45th Street flea market 14 MR CRITTON: Well,