EFTA01076765.pdf

Page 332 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- VOLUME III OF III 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 DEPOSITION OF JANE DOE NO. 6 Tuesday, April 6, 2010 10:11 - 12:13 250 Australian Avenue Suite 150 West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Services Job No.: 1577 • PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hooking (801.061.978.2934) Electronically signed by cynthia hopkins (601-051-978.2934) Electronically signed by Cynthia hopkins (601-051.978.2934) 77a4b141-af9a-4001.9083.8116a007a087 EFTA01076765 EFTA01076766  Page 333 Page 335 1 APPEARANCES: 1 CONTINUED PROCEEDINGS 2 On behalf of the Plaintiff 2 3 ADAM D. HOROWITZ, ESQ MERMELSTEIN & HOROWITZ7,11. 3 THE VIDFDGRAPHER: This is the 6th day of 4 18205 Biscayne Boulevard 4 April,210. The time Is approximately Suite 2218 5 10:11 M. This is the videotape deposition of 5 Mama Phone: 6 Jane Doe No. 6 in the matter of Jane Doe versus 5 7 Jeffrey Epstein. 7 On behalf of 8 This deposition is being held at 250 South ROBERT l). CROTON, Et, ESQUIRE Australian Avenue, West Palm Beach, Florida BURMAN, CRITTON, LUTIliR. & COLEMAN. LIP 9 9 303 Banyan Boulevard 10 My name is Daniel Downey. I'm the videographer Suite 400 11 representing Visual Evidence, Incorporated. 10 West P rida 33401 12 Will the attorneys please announce their Phone: 11 13 appearances for the record. 12 14 MR. HOROWITZ: Sure. My name Adam 13 ALSO PRESENT: 15 Horowitz,. I'm counsel for Plaintiff, Jane Doe 14 16 No. 6. Daniel Downey, Videographer 15 Visual Evidence, Incorporated 17 MR. CRITTON: Bob Critton on behalf of 16 18 Mr. Epstein. 17 19 Thereupon, 18 20 19 (JANE DOE NO. 6), 20 21 Having been first duly sworn or affirmed, was 21 22 examined and testified as follows: 22 23 THE WITNESS: Yes. 23 24 24 DIRECT EXAMINATION 25 25 Page 334 Page 3 1 BY MR. CRITTON: 2 2 Q. Ms. Doe No. 6, we're going to finish your 3 3 deposition today. You understand that? 4 INDEX 4 A. Yes. 5 5 Q. All right. Since you were here on 6 6 February 17th of 2010 are ou currently still / EXAMINATION DIRECT CROSS REDIRECT 7 employed by a Continued 8 A. No. 9 JANE DOE NO. 6 9 Q. All right. You — when you carne here or 10 BY MR. CRITTON 335 10 when you were here on February 17th. In fact, I 11 11 think you were going to work when you left. 12 12 A. Yes. 13 13 Q. Correct? 14 14 A. Yes. 15 EXHIBITS 15 Q. And I think it was, was it your cousin who 16 16 was the supervisor there? 17 17 A. Manager. 18 EXHIBIT DESCRIPTION PAGE 18 Q. She was the manager? 19 DEFENDANTS NO. 4 November 29, 2006 Letter 396 19 A. Assistant manager. 20 20 Q. So, you stopped working, it looks like 21 21 answers to your interrogatories, you stopped working 22 22 sometime in March. When? 23 23 • A. March 12th. 24 24 Q. All right. Which would have been about a 25 25 month aSfter our deposition, correct? 2 (Pages 333 to 336) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins (801.061.976.2934) Electronically signed by cynthia hopkins (601-051-976-2934) Bactronically signed by cynthla Winkles (601.061.976.2934) 77a4b(41.afga.40e1-9063-81f5e007a067 EFTA01076767  Page 337 Page 339 A. Yes. 1 rob him. 2 Q. Okay. And why did you stop working there? 2 BY MR. CRITTON: 3 A. I got fund. 3 Q. And was he a chug dealer? 4 Q. Why did they lire you? 4 MR. HOROWITZ: Form. 5 MR. HOROWITZ: Form. 5 THE WITNESS: I didn't know. They were 6 THE WITNESS: Because I didn't come into 6 trying to rob him. That's what the cop said. work. 7 They didn't get into the house so I don't q BY MR. CRITTON: 8 BY MR. CRITION: 9 Q. Ts that what they told you? 9 Q. tla daknow to be a drug dealer? 10 A. No. Yeah, well, it's because I didn't come 10 A. mother is the landlord or the, she 13. in. 11 works at the office and that's how me, me and him met 12 Q. Okay. And why did you not go into work 12 during. 13 that day? 13 MR. HOROWITZ: He is asking if you knew -- 14 A. Because one of my good friends was murdered 14 MR. CRITTON: I heard — 15 early that morning. 15 MR- HOROWITZ: - if you him to be a drug 16 Q. What was his or her name? 16 dealer. 17 A. 17 THE WITNESS: No, I didn't, I didn't know. 18 ell the last name, please. 18 MR- CRITTON: I don't need help but that's 19 A. 19 fine. 20 Q. Oh, 20 MR. HOROWITZ: Form. 21 A. Yes. 21 THE WITNESS: I didn't know. 22 Q. How long had you known Mr. 22 BY MR. CRITTON: 23 A. Since I was ten or I I • 23 Q. Had you ever done drugs with M? 24 Q. And he was a very close friend of yours? 24 A. No. 25 A. Family friend, yes. 25 Q. Are you sure? Page 338 Page 340 1 And how was he murdered? 1 A Yeah. 2 A. He was shot in his house. 2 Q. So, he was shot and killed that day? 3 Q. And how did you hear about it? 3 A. Yeah. 4 A. My friend Julie called me. 4 Q. And you heard about it. What time were 5 Q. What is Julie's name, last name? 5 you supposed to be at work? 6 6 A. I was supposed to be at my meeting at 12. It 7 Q. Is she one of your good friends? 7 happened around like 9 or 10. 8 A. Yes, sheSnbest friend, 8 Q. In the morning? 9 Q. Okay. , 9 A. Yes. 10 A. Yes, sir. 10 Q. On the 12th? 11 Q. And 11 A. Yes. 12 A. Yeah. I don't know how to spell it. 12 Q. Okay. Did you call your cousin and tell 13 Q. And did she know as well? 13 her? 14 A. Yes. 14 A. Yeah. Well, I went to the, I was supposed to 15 How — he was shot where? 15 go to the meeting. I went and I was crying, and they 16 A. In the chest 16 told me to go home. And I was supposed to go back to 17 Q. And was it, it was a — someone came into 17 work at 5. 18 his house and shot him theft? 18 Q. And did you go back at 5? 19 A. Yeah. They, well, they tried to come inside.. 19 A. No. 20 He struggled with them, wouldn't let them in the door 20 Q. Why not? 21 because his daughter and his fiancee were in the house. 21 A. Because I called my manager. She was in 22 Q. .Okay. Was, was he selling drugs or 22 Chicago, so I had to call my cousin which is the 23 something? Was this drug related? 23 assistant manager. And she couldn't find nobody to 24 MR. HOROWITZ: Form. 24 cover forme, so... 25 THE WITNESS: Yes. They were trziro 25 Q. Cover for you when? 3 (Pages 337 to 340) (561) 832-75G0 PROSE COURT REPORTING AGENCY,.. INC. C ) 832-7506 Electronically signed by eynthia hopkins (601451476-2934) Electronically signed by cynthia hopkins (601-051476-2934) Electronically signed by cynthla hopkins (601-051.976.2934) 77a4b141-af9a-40o1-9063-81f6a0072067 EFTA01076768  Page 341 Page 343 1 A. For that night, 1 soon after you were fired from 2 • Q why? 2 did you get another job? It looks 3 A. I was supposed to work 3 like at 4 Q. You didn't go in on Friday, the afternoon 4 A. Well, I started working last Saturday but I 5 either? 5 got the job the Thursday before that. So, like two 6 A. No,1— my, the owner, because he 015113, 6. . weeks, ten days maybe. 7 privatelyowned, he told me to go home for the meeting 7 Q. All right. And have, have you been 8 because i was supposed to be there at 12. 8 working there now? 9 Q. And he told you to come back at 5? A. Yeah. 10 A. He didn't tell me to come back. 1 was 10 Q. And is it a 40-hour-a-week job? 11 supposed to come back during'my shift. it was already 11 A. Right now I am only part-lime because i am 12 on the schedule. 12 still training they say, but I have been working 13 Q. Okay. So, did you go back at 5? 13 eight-hour days. 14 A. No. 14 Q. Do you get any benefits with Elt 15 Q. Why not? 15 A. No. 16 A. Because I couldn't go back to work. 16: Q. If you start working there as a MI-time 17 Q. Why not? 17 employee, will you get benefits? 18 A. Because I couldn't be sitting at 18 A. No. 19 thinking what happened in my head. 19 Q. Just the $7.50 an hour? 20 Q. Did call your — anyone and tell inc them 20 A. Yes. 21 that you couldn't come in bersice you were still so 21 Q. Are you doing any other employment at the 22 upset? 22 current time? 23 A. Yeah, yeah. 23 A. No. 24 Q. And that was your cousin? 24 Q. Okay. And your boyfriend. I 25 A. Yeah. No, I called my manager, the manager in 25 he is still working I think heavy machinery or Page 342 Page 344 1. 2 3 ii. the morning, or, well, at 12, and she was in Chicago. So, call ' cl she %mita do anything 1 would have to And = said she couldn't find anybody 1 2 3 something? A. No, he got fired. He got laid off, as a matter of fact, a little before my son's birthday. 4 which is my cousin. 4 Q. Your son's birthday was when? 5 Q. To replace you at 5? 5 6 A. Yeah. 7 Q. And then you just decided that you 7 A. Yes. 8 couldn't go in — 8 MR. CRITFON: Correct. 9 A. She — 9 MR. HOROWITZ: Of this year. 10' Q. — because you were so upset? 10 THE WITNESS: That's when he turned two. 11 A. Yes. 11 BY MR. CRTTTON: 12 Q. .And then did then say you've been 12 Q. And what happened, he just, they just said 13 fired? • 13 we don't need you any more; you're getting laid off? 14 A. No. My manager called me back and told me 14 A. No. Their whole crew got laid off. 15 that ifs not my immediate family, and that 1have to 15. Q. What's he been doing? Does he get 16 go; ifnot, she's going to have to fire me, so... 16 unemployment? 17 Q. And you said — ' 17 A. Well, he is trying to. They are waiting. 18 A. Yeah. . 18 Q. Is there a wait period or something? 19 Q. — go ahead and fire me? 19 A. No. I think the company is fighting for it 20 A. (Witness nods head). 20 or — 21. Q: Yes? 21 Q. You still get insurance benefits for the 22 A. Yes. . 22 child though under - 23 Q. Affright. And it appears that you then 23 A. No. He got it through the job, I have to — 24 got another job? 24' Q. No, no. That's what I meant, he, he, 25 A. Yes. 25 your, Aaro23sets insurance coverage trout: 4 (Pages 341 to 344) PROSE COURT REPORTING. . GENCYf INC: Electronically signed by cynthia hopkins (601-051-976.2934) Electronically signed by cynthia hopkins (601.061-976.2934) Electronically signed by cynthia hopkins (601.051-976-2934) 77a4bf41.of9a40e1-9063.81f5a007a067 EFTA01076769  Page 345 Page 347 1 child — 1 current time relating to Mr. Epstein or any other 2 MR. HOROWITZ: Form. 2 emotional condition that you have? 3 BY MR. CRITTON: 3 A. No. 4 Q. - stilt rigid? 4 Q. You and talk anymore about marriage, 5 THE WITNESS: What do you mean insurance 5 yes or no? 6 coverage? ' 6 A. Yeah. BY MR. CRITTON: 7 Q. Any plans yet? Q. You testified at your last detadjap 8 A. No. 9 that, that he had insurance benefits, l=? 9 Q. Since your deposition have ou seen or 10 A. He has health. 10 spoken with either Jane Doe or M.? 11 Q. Health insurance benefits which were 11 A. Isete funeral. 12 applicable to your son. 12 Q Of 13 A. Through the job. 13 A. Yes. 14 Q. Right. So, he still has those? 14 Q. Okay. Was it a pretty sad funeral? 15 • A. I don't think so since he got laid off. 15 A. Yeah. 16 Q. How big, how big a business is it? 16 Q. And did you feel -- I mean, apparently it 17 A. It's -- I don't know. 17 affected you enough that you didn't want to go to 18 Q. Two people? 18 work? 19 A. I just know he works there. 19 A. Yeah. 20 Q. Is it 20 or 30 people, do you think? 20 Q. Does it still affect you now? 21 A. I don't know. I know he works there on a crew 21 A. Yeah. I think about him a lot. 22 with a couple of people. 22 Q. RAW'S la' you hadstbajgdividuals, you had 23 Q. Tell, tell him about Cobra because under 23 a former boyfriend, Mr. who shot himself, 24 the federal law he is entitled and the employer has 24 correct? 25 to pay it so... 25 A. Yes, but that's different. Page 346 Page 348 1 A. He was -- 1 Q. And how is that different? 2 Q. He's not, he is not getting it? 2 A. Because someone took from his 3 A. He was paying his health benefits out of his 3. two-year-old daughter. She was right behind him when he 4 check, so... 4 was shot. They took him from her. 5 Q. So, the company didn't pay it? 5 Q. Okay. And how does that make you feel? 6 A. He was paying co-fees for it, so I don't — 6 A. It's wrong. 7 co-pay, 1 don't think. 7 Q. Of course it's wrong, but how does it make 8 Q. Tell him to still check. Have you seen, you feel? 9 since your deposition on Felnuaty 17th, 2010, have 9 A. That just -- I don't know, just I could lose, 10 you seen any psychologist or psychiatrist, mental 10 you know, my family or anybody quick. It just didn't -- 11 health counselors for any reasons relating to 11 it doesn't feel real. 12 Epstein or any other psychiatric or psychological 12 Q. Okay. And, and because the sante thing 13 issues? 13 could happen with you or it could happen with 14 A. Since the last time I seen you? 14 15 Q. Yes, ma'am. 15 A. It could happen to anybody. They, they didn't 16 A. No. 16 even, supposedly they didn't even know him. That's what 17 Q. Have you seen any physicians for any 17 the cops say. They didn't even know him that they just 18 reason? 18 heard that he was doing something and went and knocked 19 A. No. 19 on the door. 20 Q. Medical doctors, medical, been to an 20 Q. You said "they, they heard- that he was 21. emergency room for any reason? 21 doing something; the people who shot him? 22 A. No, no. 22 A. Yes. 23 Q. And you have no — do you have any 23 Q. What did they hear? What did the cops 24 appointments to see a psychologist or psychiatrist 24 say? 25 or a mental health counselor for any reasons at the 25 A. The cop said that they heard that he was, had 5 (Pages 345 to 348) PROSE COURT REPORTING AGENCY, INC. (MI) Electronically signed by cynthia bodkins (601.051.970-2934) Electronically signed by cynthia hopkins (601.051-976.2934) Electronically signed by cynthia hopkins (601.051.976.2934) 77•4t441419•40040634115s007•067 EFTA01076770  Page 349 Page 351 I money or he was dealing drugs. I don't know. 1 you were in the car accident and thou t she 2 Q. So, that's why they purportedly broke into 2 might die, the events with they 3 the house? 3 are all -- 4 A. They didn't break in. They tried. 4 A. 5 Q. Oh, and they just then shot through the 5 Q. I am sorry, — all seem to 6 door? 6 a significance impact on you? 7 A. He was standing at the door fighting with them 7 MR. HOROWITZ: Form. 8 because they were trying to get into the house. 8 BY.MR. CRITTON: • 9 Q. Oh, was he actually outside of the house? 9 Q. Is that true? 10 A. He was — he answered the door because they 10 A. I mean he just died like two weeks ago. 11 knocked and they had a gun and tried to get into the 11 That's why it has an impact on me. It is still fresh. 12 house, and his daughter was behind him. 12 Q. Are y • that the events 13 Q. Did go with you to the funeral? 13 surrounding having committed suicide 14 A. Yes. 14 so close, so close to you, no longer has an effect 15 Q. And you saw Jane Doe there. Did you talk 15 on you? 16 to Jane Doe at all? 16 A. I didn't say that. I'm just, you blow, I mean 17 A. No. 17 it's different when somebody steals their own life, and 18 Q. You just saw her there? 18 when someone gets their life stolen from them. It's way 19 A. Yeah. 19 different. 20 Q. How about have you, have you spoken with 20 Q. You mean a suicide versus -- • 21 her separate and apart from seeing her at the 21 A. Yeah. 22 funeral? 22 Q. — versus a random murder? 23 A. No. 23 A. It's way different, yes. 24 Q. Have you talked to M. at all? 24 Q. Which do you consider more, lice, 25 A. No. 25 traumatic from your perspective? Page 350 Page 352 1 Q. Did you -- the ex with or what you 1 MR. HOROWITZ: Form. 2 have at least seen with MI pretty 2 THE WITNESS: It's all pretty traum — 3 traumatic for you? 3. sad, you know, that this had to happen to good 4 A. Yeah. It just hurts you know. It's wrong. 4 people but it's what happens. 5 Q. Had, had any nightmares about it or — BY MR. CRITTON: 6 A. No. 6 Q. The incident with your mother when you 7 Q. Had any trouble sleeping? 7 were in the automobile accident back in 2004, does 8 A. No. I just think about him, you know, when 8 that still bother you as well? Well, let me strike 9 Fm in my neighborhood or go by his house or something. 9 that The accident had an impact on you at the time 10 Q. Did you know his parents? 10 certainly, correct? 11 A. Yeah. 11 A. Uh-huh. 12 Q. Okay. And did you go back to the house 12 Q. And you found that very traumatic at the 13 for the reception 13 time? 14 A. Yeah, yeah, I've been at — 14 A. Yes. 15 Q. Or like the wake afterwards? 15 Q. Okay. Had trouble sleeping, thought your 16 A. I have been at her house for like 10 days now. 16 mother might di; thought she could be taken from 17 Q. Everyday? 17 you as well? 18 A. Yeah. 18 A. Yeah. 19 Q. Okay. And how is the mother doing? 19 Q. Okay. And that's part of the same issue 20 A. She's actually keeping everybody together. 20 you have about driving or certainly driving on 1-95 21 Q. Does he have other brothers and sisters? 21 or an interstate or a toll road, correct? 22 A. Yeah. 22 A. Yeah. 23 Q. From listening to your testimony on 23 Q. Tell me what a typical day is for you now? 24 tua , 17th N s. Doe, events like what happened to 24 What do you do, excuse me, on a typical day? 25 what happened with your mother when 25 A. Go to work. 6 (Pages 349 to 352) (M) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkine (601.051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkine (601.051-976-2934) 77a4b141-af9a-40o1.9063-81f5aa007a067 EFTA01076771  Page 353 Page And do you have a regular, excuse me, at 1 stay with her the whole day? 2 do you have a regular shift? 2 A. Yeah, until I get off. 3 A. Yeah. Igo in at 8. 3 Q. And then you go and pick him up? 4 Q. Until when? 4 A.. Yeah. 5 A. Well, I can leave from 2 to 4. Depends how 5 Q. And when you go pick him up, then you go 6 busy we are. 6 home? 7 Q. All right. Is it your choice or the 7 A. Yeah. 8 managers? 8 Q. Okay. And then what do you do? 9 A. Well, I can — like I said it depends how busy 9 A. Make dinner. 10 we are. 10 Q. All right. And what, watch TV? 11 Q. So, if it's not busy, you can say I ern 11 A. Yeah. We hang out. He usually watches Elmo 12 leaving? 12 'till - 13 A. Yeah. 13 Q. Your son? 14 Q. And if it's busy, then they expect you to 14 A. Yeah. 15. say? 15. Q. All right. And you hang out until you go 16 A. Yes. 16 to bed around what time? 17 Q. Okay. Which do you work at? Where 17 A. He goes to sleep at like 8. And then well 18 is the location? 18 watch some TV and :4) to sleep. 19 A. Lake Worth and log. 19 Q. Okay. and you are still living 20 Q. All right. So, when you're not working, 20 together? 21 so you get up, you get up in the morning and take 21 A. Yeah 22 care of your baby? 22 Q. Okay. What's doing now since he got 23 A. Yeah, well, I bring him to my mom's so I can 23 laid off? 24 get ready to work because I have, I wake up at 7 and be 24 A. Fixing our house. 25 at work by 8. 25 Q. lie Is working around the house? Page 354 Page 356 Q. Do you feed, feed your son, isn't it? 1 A. Uh-huh. 2 A. Yeah. Well, he is just now getting — when I 2 Q. Yes? 3 bring him over there, he is just getting up. So he is 3 A. Yes. 4 going to take -- 4 Q. Is he looking for other work as well? 5 g Does your morn then feed him? 5 A. Well, yeah, in between trying to deal with his A. Yes. 6 unemployment. 7 Q. Does she work at 7? 7 g Okay. So, he is trying to get his 8 A. Yes. 8 unemployment benefits, correct? 9 Q. Is she, what — who does she work for 9 . .A. Yes. 10 again? 10 Q. And then working on the house? 11 A. AAffordable Insurance. 11 A. Yes. 12 Q. Okay. And when she goes to work, does she 12 Q. Has he applied for any other jobs? 13 work out of the home? 13 A. 1 think he went to some interviews, yeah, like 14 A. No. 14 the USD Meat. 15 Q. And who takes care of your son when — 15 g I'm sorry? 16 A. She drops him off at my aunt's house. 16 A. The Direct Meat or whatever, the USD Meat or 17 Q. And her name is? 17 something. 18 A. 18 Q. All right. 19 Q. Can ou s it for me? 19 A. And some other place on Lake Worth. I didn't 20 A. 20 go. 21 Q. Where does she live? 21 Q. But nobody has at least hired him as of 22 A. 22 todays date? 23 Q. In Lake Worth? 23 A. No. 24 A. Greenacres. 24 Q. Okay. In your answers to the second g umennon2.... All let. And then does, does the son 25 interrogatories it appears you have a, you have a 7 (Pages 353 to 356) PROSE COURT REPORTING AGENCY; INC. Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601-051-976-2934) Electronically signed by cynthia hopkins (601.051.976-2934) 77s4b141.09a-40e1-9063-81t5a007a067 EFTA01076772  Page 3,57 Page 359 MySpace since 2008? 1 like 17. A. Yeah. 2 Q. And you bank — how long have you been Q. Okay. Do you use it on a regular basis? 3 banking? How long have you had a bank account? A. Yeah. 4 A. Since, yeah, I was like 18. Q. And you, you have a Facebook page, but 5 Q. Did you ever have like a savings account what you haven't activated it yet? 6 or something that your parents set up or anyone set A. No. 7 up for you? Q. You haven't punched in the profile? 8 A. Well, the bank is me and my mom share the 9 A. Yeah. I haven't I think I signed up for it 9 same. 10 but I never went on it. I don't know how to use it. 10 Q. Do you have the same bank account? 11 Q. And you actively use your MySpace? 11 A. Yes. It's a joint bank account. 12 A. Yeah. 12 Q. Is it a checking account? 13 Q. And do you use that every day? 13 A. Yeah. 14 A. Maybe every other day. 14 Q. Okay. And why do you and your mom share 15 Q. All right. And you correspond with your 15 the same account? 16 friends or family? 16 A. Because she has three accounts with Chase 17 A. Yeah. 17 already, so to add on, it would be easier. 18 Q. What kind of computer do you have? 18 Q. Okay. So, she has her, two of her own 19 A. Well, right now I have a Dell laptop. 19 accounts and then she has an account with you? 20 Q. Okay. And do you take that with you to 20 A. Yes. She — 21 work? 21 Q. And you said — sorry. 22 A. No. I have my phone. 22 A. She added my account to hers. 23 Q. Okay. And what kind of phone do you have? 23 Q. You can use that account. It's basically 24 A. IPhone. 24 your account. It just happens to be in both your 25 Q. And how long have you had an iPhone? 25 names? Page 358 Page 360 A. Since November of last year. 1 A. Yeah. 2 Q. Okay. So, you're on an AT&T plan? 2 Q. I may have asked this before, so I 3 A. Yeah. 3 'apol ting Have you ever talked Q. And the iPhorte, is that, are you and 4 with ; that is, is she aware that 5 on the same program or the same plan? 5 you're a Plaintiff in a lawsuit? A. No. 6 A. (Witness shakes head.) 7 Q. Okay. And do you pay for your own plan? 7 THE COURT REPORTER: Is that -- 8 A. Yeah. Well, I share a plan with my dad. It's 8 BY MR. CRITFON: 9 a family plan. 9 Q. No? 10 Q. How much does that cost you a month? 10 A. No. 11 A. One hundred bucks. 11 also listed M 12 Q. And your laptop, did you buy — how old a 12 , as one of your closest friends over 13 laptop is it? 13 the last four or five years. Is she aware you are a 14 A. The laptop bought in January of this year. 14 Plaintiff in a lawsuit? 15 I'm malting payments on it. 15 A. Yeah, she knows something about it 16 Q. Do you have credit cards? 16 Q. Okay. And how does she know about it? 17 A. Yeah. 17 A. Because last time I came here, I told her that 18 Q. Okay. Which credit cards do you have? I 18 I had to, what I had to do. 19 am not going to ask you for numbers but what credit 19 Q. Okay. And what, I mean that you had to 20 cards do you have? 20 testify? 21 A. I got Capital One, Wal-Mart and that's it, and 21 A. That I had to — 22 I have a bank card. 22 Q. That I was asking you questions? 23. Q. How long have you had credit cants, 23 A. — go downtown with my lawyer. And I 24 • Ms. Doe No. 6? 24 explained to her that I was in a lawsuit and that I 25 A. My...dadFt me first credit card when I was 25 would tell her about it later. Cein. 8 (Pages 357 to 360) PROSE COURT REPORTING AGENCY, INC. (M) Electronically signed by cynthia bodkins (601451-976-2934 Electronically signed by cynthia hopkins (601-061-976-2934) Electronically signed by cynthia hopkins (601.051.916.2934) 77a4bf41-af9a-40e1-9063-81(6a007a 067 EFTA01076773  Page 361 Page 363 1 Q. So, she doesn't know anything about why 1 drives around, too. I mean, I hang out with my son most 2 you're in a lawsuit? 2 of the time, yeah. 3 A. No. 3 BY MR. CRT'S: 4 Q. Have you, have you ever been in a lawsuit, 4 Q. Does do things with you and your 5 other than this lawsuit have you ever been in a 5 son, too? 6 lawsuit for anything before? 6. A. Yeah. 7 A. No. 7 Q. Okay. So, he is a pretty active father? 8 Q. Was your mom involved in a lawsuit when 8 A. Yeah. 9 they had that automobile accident with the semi? 9- Q. All right. Was there a time — well, let 10 A. No. 10 me strike that. You, you've testified that you went 11 Q. Did that turn into a lawsuit? 11 to Mr. Epstein's home on one occasion, August 8th of 12 A. No. 12 '04, correct? 13 MR. HOROWITZ: Form. 13 A. Yeah, that was one time. 14 BY MR. CRITFON: 14 Q. Prior to the time that you were at 15 Q. Was a claim filed or do you know? 15 Mr. Epstein's home, I want to talk a little bit 16 A. No, no. 16 about some background that you, that you provided or 17 Q. Your mom never filed anything? 17 that I provided at least to your attorney with 18 A. No. 18 regard to issues that you had with, issues that you 19 MR. HOROWITZ: Form. 19 had with police or law enforcement. Okay. 20 BY MR. CRITTON: 20. Have you had a chance to look at a bunch 21 Q. Was the car repaired? 21 of police reports? 22 A. No. 22 A. No. 23 Q. Was it drivable? 23 Q. Have you looked at any police reports? 24 A. No. 24 MR. HOROWITZ: Form. 25 Q. What happened to it? 25 THE WITNESS: About who? Page 362 Page 364 1 A It was junked. 1 BY MR. CRITFON: 2 Q. Okay. And how do you know that she didn't 2 Q. About anything? 3 file a lawsuit? 3 MR. HOROWITZ: Form. 4 A Because she didn't, because I know she didn't. 4 THE WITNESS: About my case when I was on 5 She was filing for bankruptcy. 5 house arrest? 6 Q. Your mom was at the time? 6 BY MR. CRITTON: 7 A She just filed for bankruptcy in 2000 or 2002 7 Q. Okay. Have you looked at some of those? 8 or something like that. It was like six, seven years A. Not rec