EFTA01248007.pdf

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502008CA037319XXXXMB AB Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VIDEOTAPED DEPOSITION OF VOLUME I Tuesday, November 10, 2009 11:13 a.m. - 6:12 p.m. 250 S. Australian Avenue Suite 1500 West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR PROSE COURT REPORTING AGENCY Notary Public, State of Florida West Palm Beach Office (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-901Po7174075 3501.182-102 Page 1 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094347 EFTA01248007  Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff III.: 3 On behalf of Plaintiffs On behalf of Plaintiff U U • • • 18 On behalf of the Defendant: 19 ROBERT CRITTON, ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN 20 515 North Flagler Drive Suite 400 21 West Palm Beach, Florida 33401 Phone: 561.842.2820 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90flb7174075 3501.182-102 Page 2 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094348 EFTA01248008  Page 3 1 On behalf of the Witness: 6 7 ALSO PRESENT: 8 MICHAEL DOWNEY, VIDEOGRAPHER 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (561) 832-75C0 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113.5663.4dad-94e7-90flb7174075 3501.182-102 Pagc 3 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094349 EFTA01248009  Page 4 1 2 EXHIBITS 3 4 NUMBER DESCRIPTION PAGE 5 6 Plaintiff: 7 Exhibit number 1 Notebook page 14 8 Exhibit number 2 Photograph 134 9 Exhibit number 3 Photograph 137 10 Exhibit number 4 Photograph 138 11 Exhibit number 5 Photograph 247 12 13 Defendant: 14 Exhibit number 1 Transcript 140 15 16 17 18 19 20 21 22 23 24 25 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f1134663-4dad-94e740ftb7174075 3501.182-102 Pagc 4 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094350 EFTA01248010  Page 5 1 PROCEEDINGS 2 3 Deposition taken before Sandra W. Townsend, Court 4 Reporter and Notary Public in and for the State of 5 Florida at Large, in the above cause. 6 - - - 7 VIDEOGRAPHER: We're on the video record. 8 This is the 10th day of November, the year 2009. 9 The time is approximately 11:13 a.m. 10 This is the videotaped deposition of 11 in the matter of III., Plaintiff, versus 12 Epstein, Defendant. 13 This deposition is being held at 250 South 14 Australian Avenue, West Palm Beach, Florida. 15 My name is Michael Downey. I'm the 16 videographer, employed by Visual Evidence. 17 Would the attorneys please announce their 18 appearances for the record. 19 MR. Yes. , on behalf of 20 Plaintiff III. 21 MR. on behalf of 22 Plaintiffs 23 MR. on behalf of 24 • 25 MR. CRITTON: Robert Critton, on behalf of (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 5 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094351 EFTA01248011  Page 6 1 Jeffrey Epstein. 2 MS. and 3 here on behalf of witness, 4 THEREUPON, 6 having been first duly sworn or affirmed, was examined 7 and testified as follows: 8 THE WITNESS: So help me God. 9 MR. CRITTON: Let me just note one thing for 10 the record, is -- it's been -- this case for this 11 depo has been noticed both in the State Court case. 12 It's been noticed as well -- cross noticed by at 13 least on behalf of his clients two 14 through eight in the Federal Court case. The only 15 two lawyers who apparently are not here, but they 16 obviously have notice of it. And Mr. didn't 17 notice it, but obviously he's -- cross notice, but 18 he's here -- Mr. on behalf of his three 19 clients, and apparently Mr. Garcia chose, they 20 chose not to come for whatever reason, but they 21 would have received notice from everybody. 22 DIRECT EXAMINATION 23 BY MR. 24 Q. Good morning. 25 A. Morning. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-56634dad-94e7-90ftb7174075 3501.182-102 Page 6 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094352 EFTA01248012  Page 7 Q. Just want to make sure he was done. 2 I introduced myself in the beginning, but my 3 name is . I represent one of the 4 Plaintiffs in a lawsuit filed against Mr. Epstein. And 5 I'm here today to ask you a bunch of questions. 6 As you saw at the beginning, you're under 7 oath. It's just like you're on the stand at trial, 8 except there's no Judge here in the room with us. So 9 when I ask you questions, just give it a breath for a 10 minute because there may be objections for other lawyers 11 in the room. 12 Since there's not a Judge here, nobody's going 13 to rule on those objections, so the lawyer has to put 14 that objection on the record. Just pause for a minute 15 and then if you understand the question, go ahead and 16 answer. 17 The only exception to that rule is, if your 18 two lawyers look at you and say, don't answer that 19 question. At that point I don't want you to say a word. 20 And then they lodge an objection and advise you not to 21 say anything. Okay? 22 A. Okay. 23 Q. If you do answer a question, there's two 24 things I'm going to assume. I'm going to assume that 25 you understood the question being asked and that you're (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663.4dad-94e7-90flb7174075 3501.182-102 Page 7 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094353 EFTA01248013  Page 8 1 answering truthfully. Fair enough? 2 A. Yes. 3 Q. If you don't understand any of my questions, 4 please let me know and I'll be happy to rephrase it 5 until you can understand it. 6 It's a nerve-racking procedure and I know 7 you're nervous. It's delving into very touchy areas, so 8 it's going to be delicate. I'm going to try and handle 9 it as respectfully and delicately as possible, but I am 10 going to have to ask a whole bunch of difficult 11 questions. Okay? Fair enough? 12 A. Understand. 13 Q. Okay. If you would, could you give us your 14 full name, please? 15 A. 16 Q. Where do you currently live? 17 A. • • (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Pagc 8 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094354 EFTA01248014  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electron Gaily signed by Sandra Townsend (401.377-676.2895) Elecironicaily signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 9 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094355 EFTA01248015  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 10 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094356 EFTA01248016  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 11 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094357 EFTA01248017  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 12 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094358 EFTA01248018  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 13 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094359 EFTA01248019  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 14 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094360 EFTA01248020  (5611 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 15 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094361 EFTA01248021  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-Ne7-90ftb7174075 3501.182-102 Page 16 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094362 EFTA01248022  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 17 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrA_00094363 EFTA01248023  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1,88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 18 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094364 EFTA01248024  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 19 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094365 EFTA01248025  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90ftb7174075 3501.182-102 Page 20 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094366 EFTA01248026  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 21 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094367 EFTA01248027  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-S4e7-90flb7174075 3501.182-102 Page 22 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094368 EFTA01248028  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1(88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 23 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094369 EFTA01248029  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401-377476-2895) Electronically signed by Sandra Townsend (401-377476-2895) 1038f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 24 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094370 EFTA01248030  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1188f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 25 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094371 EFTA01248031  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 26 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFrAJON4372 EFTA01248032  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 27 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094373 EFTA01248033  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1,88f113-5663-4dad-94e740ftb7174075 3501.182-102 Page 28 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094374 EFTA01248034  ■ ■ 12 BY MR. 13 Q. When is the first time that you ever had any 14 contact with Jeffrey Epstein? 15 A. When? 16 Q. Yes. In other words, what grade were you in 17 or how old were you? However you can peg the time in 18 your mind. 19 A. About 16. 20 Q. So would you have been in about tenth grade at 21 that point? 22 A. Tenth going into my junior year, like, towards 23 the end, beginning of 11th. 24 Q. And how was it that you came to know who 25 Jeffrey Epstein was? (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad44.7-90ftb7174075 3501.182-102 Page 29 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_ONN4375 EFTA01248035  Page 1 A. I was approached by a: 3 Q. At that point had you just turned 17? 4 A. No. 5 Q. You were still 16 at that point? 6 A. Yes. 7 Q. And III, is ill.? 8 A. I don't know. 9 Q. Okay. How did you know 10 all? 11 A. We went to middle school together, but we were 12 not friends. 15 Q. Do you know where she is today? 16 A. No. 17 Q. What were you doing at 19 A. I don't know. 20 Q. Well, is it a members only type of place? 21 A. No. 22 Q. Do you just -- 23 MR. : Wait until he finishes his 24 question. 25 BY MR. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 30 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094376 EFTA01248036  Page Q. How do you get in there? 2 A. You walk in. Q. Is there a charge to get into S A. Not the day I met no. 6 Q. Had you been there before? 7 A. Yes. 8 Q. How many times had you been there before? 9 A. I can't recall. 10 Q. Was it a place that you went to regularly at 11 that point in your life? 12 A. Yes. 13 Q. Why would you go there? 14 A. To go swimming, listen to music. 15 Q. Okay. Can you describe to me? I mean, are we talking about a club? Are 17 we talking about a -- somewhere just on the beach 18 somewhere? Are we talking about a bar? What is this 19 place? 20 A. is a tiki bar on the beach 21 or was at that point on the beach 22 had a bar. It had a restaurant. It had a pool. It was 23 a hotel room. I mean, they had hotel rooms available. 24 They had on Sundays live music. 25 Q. Okay. When you would go there in the past, (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) 1f88f113-5663-4dad-94.7-90flb7174075 3501.182-102 Page 31 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00094377 EFTA01248037  Page 1 would you go with friends? 2 A. Yes. 3 Q. Who? 4 A. 5 Q. Anyone else you can think of? 6 A. Not that I can think of. 7 Q. Would you go with or would you go with 8 9 A. Not . I did go with and at. 10 one point. 11 Q. Okay. When you would go to the beach 12 resort -- and I'm talking about the day before 13 III approaches you now. 14 A. Uh-huh. 15 Q. In the past when you would go there, is it a 16 place you would go just yourself and with friends of 17 would your parents take you there? 18 A. Usually a place that I would go with my 19 friends. 20 Q. Had your parents ever been there before that 21 day that you talked to 22 A. Yes. 23 Q. So they were familiar of the location and had 24 been there before? 25 A. Uh-huh, yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377-676.2895) V8W113-56634dad4404WW17.WM 3501.182-102 Page 32of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00O54378 EFTA01248038  Page 33 1 Q. And they would also let you go to this place 2 alone? 3 A. With friends. 4 Q. How would you get there? 5 A. Drive. 6 Q. You? 7 A. Yes. 8 Q. So you would have -- you had a driver's 9 license at 16? 10 A. Yes. 11 Q. Just going back to what we had asked at the 12 beginning. 13 Did you have your own car? 14 A. Yes. 15 Q. What kind of car were you driving back then? 16 Was it the same pickup truck that you had later? 17 A. I don't remember. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 33 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094379 EFTA01248039  (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f113-5663-4dad-94e7-90ftb7174075 3501.182-102 Page 34 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094380 EFTA01248040  ml ■ ■ ■ ■ 15 Q. Okay. Once again, this is the period of time 16 before the day that approaches you about 17 Jeffrey Epstein. I just want to focus on that period of 18 time for right now. 19 When you would go to this 20 what was the main purpose of you going there; in other 21 words, why were you going? 22 A. To have fun. 23 Q. Go hang out on the beach, get a tan, hang out. 24 with friends? 25 A. Yes. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401477476-2895) Electronically signed by Sandra Townsend (401477476-2895) 1f88f1134663-4dad-94e7-90ftb7174075 3501.182-102 Page 35 of 156 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00094381 EFTA01248041  Page • (2• Would you ever drink there at the 2 3 MS. : Objection. I've already 4 instructed her not to answer this question. You're 5 just using this example as a back doorway into the 6 same question. We're still prior to her meeting 7 If you have a specific question 8 with regard to that day, please go ahead; 9 otherwise, it's the same objection. 10 MR. : Okay. 11 BY MR. 12 Q. When yo