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1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

2 CASE NO. 08-CIV-80119-MARRa

3 JANE DOE NO. 2,

4 Plaintiff, 5 -vs-VOLUME III

6 JEFFREY EPSTEIN, 7 Defendant.

8 Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 9 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-801092

I0 II 12 13 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE

14 15 Wednesday, September 30, 2009 9:37 a.m. - 6:10 p.m.

16 One Clearlake Centre 17 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401

18 19 20 Reported SE, Pamela J. RPR, FPR, CLR 21 Prose Reporting Agency, Inc.

22 23 24 25 0261

I APPEARANCES: 2 On behalf of the Plaintiff Jane Doe: 3 BRAD J. ESQUIRE ROTHSTEIN ROSENFELDT ADLER 4 Las Olas City Centre, Suite 1650 401 East Las Olas Boulevard 5 Fort Lauderdale, Florida 33301 954.315.7273 6 bedwards@rra-law.com 7 On behalf of the Defendant, Jeffrey Epstein: 8 ROBERT D. CR1TTON, JR., ESQUIRE BURMAN, CR1TTON, LUTHER & COLEMAN, LLP 9 303 Banyan Boulevard Suite 400

"01-MK A"

18 Q. Okay. Turn -- flip the page. There was a\
19 document -- the letter is -- and just so the record is\
20 clear -- I'm enclosing a proposal for settlement in\
21 order to resolve the action which has been filed by your\
22 client. And then attached -- and that's paraphrasing --\
23 attached to the letter is a proposal of settlement, sent\
24 by Mr. Epstein to you, in the amount of \$45,000, plus\
25 \$5,000 for attorney's fees.

0425

1 Were you aware sometime in March of '09 that\
2 you were offered \$45,000 to resolve the case?

3 A. Yes.

4 Q. Okay. And did you understand that -- that\
5 if, in fact, Mr. Epstein comes back and gets an award of\
6 a sum something less than \$45,000, say \$30,000, or\
7 you're not successful in getting a judgment in excess of\
8 35 -- 30,000, \$32,000, that you'll be responsible -- or\
9 you may be responsible for all of Mr. Epstein's\
10 attorney's fees and costs that were incurred after the\
11 proposal for settlement?

12 MR. \[REDACTED\]: Form.

13 BY MR. CRITTON:

14 Q. That is that Mr. Epstein can get a judgment\
15 against you, maybe hundreds of thousands of dollars, are\
16 you aware of that fact?

17 A. No.

18 Q. Okay. And do you know that that will be\
19 against you for your entire life until you pay that off?

20 MR. \[REDACTED\]: Form.

21 THE WITNESS: No.

22 MR. \[REDACTED\]: How is that reasonably calculated\
23 to lead to admissible evidence?

24 BY MR. CRITTON:

25 Q. Ms. Jane Doe, we've talked about the first

0426

1 time you went to Mr. Epstein's house and, I believe, the\
2 second time you went to Mr. Epstein's house; correct?

3 MR. \[REDACTED\]: Form.

4 THE WITNESS: Yes.

5 BY MR. CRITTON:

6 Q. Okay. And you've testified that you went to\
7 Mr. Epstein's house another approximately 18 times; is\
8 that correct?

9 A. Yes.

10 Q. All right. And we have not discussed any of\
11 those events, at least as of this point today; have we?

12 MR. \[REDACTED\]: Form.

13 THE WITNESS: I know that I have told you\
14 that every time I ever went to his house, he\
15 touched me, and I gave him a massage.

16 BY MR. CRITTON:

19 occurred or what occurred at each of those massages;\
20 have we -- other than what you generally have told me;\
21 correct?

22 MR. \[REDACTED\]: Form.

23 THE WITNESS: Correct.

24 MR. CRITTON: I'm going to adjourn the\
25 deposition now. It is about five after 6:00, and\
0427

1 the Court's order said that we could, if\
2 appropriate, go longer than seven hours. There are\
3 a number of additional areas that I want to cover\
4 with your client, including some background\
5 information that was not disclosed in her answers\
6 to interrogatories that I've not yet gotten to.

7 I'd like to go into the other visits that she\
8 had with Mr. Epstein, that is who she saw, what\
9 occurred, both by her and with Mr. Epstein, and\
10 anyone else who may have been present at the time.

11 I want to review the various counts of the\
12 complaint with her, separate and apart from the\
13 allegations of the various visits.

14 There's some other background -- family\
15 background information I want to cover with her,\
16 and I want to cover with her any other areas of\
17 which she may have knowledge regarding witnesses,\
18 including with regard to either L.M. issues, E.W.\
19 issue, or potentially other individuals who are\
20 Plaintiffs in this case.

21 There are some other additional, as I said,\
22 family background that I wish to explore, as well\
23 as the medical records, which I have not yet had an\
24 opportunity to discuss with her, which we obtained,\
25 and her school records.

0428

1 My best estimate for the time for completing\
2 her deposition is approximately two and half to\
3 three hours. If I can do it in a more reasonable\
4 or a quicker fashion, I will certainly do that.

5 And as I advised you, Brad, I am going out of\
6 town on Friday. I'm in the process of moving my\
7 house. It's supposed to occur on Monday or Tuesday\
8 of next week. We -- it is now, as I said,\
9 6 o'clock. We started about a little before\
10 10 o'clock today. I think that the request is not\
11 unreasonable, and I will also have opportunity to\
12 have reviewed the transcript, so that I'm not --\
13 that I don't ask duplicative questions or retread\
14 some area that we've already covered that I think\
15 has been properly covered.

16 As I indicated earlier is we spent almost\
17 eight hours with a person named Rodriguez, who was\
18 a house manager for Mr. Epstein for approximately\
19 six months, who was, I'd say, a small-time player.

20 And this is a young lady who is seeking

21 extensive damages, whose -- damages in excess of\
22 \$50 million for both compensatory and punitive\
23 damages. And I think we have a right to fully\
24 explore. It's certainly not the intent to harass,\
25 intimidate or to cause her any undue stress. I'll

0429

1 be glad to work out a time that works for both you\
2 and Ms. Jane Doe.

3 MR. \[REDACTED\]: Just so that it is clear, we --\
4 we will not be in agreement to your proposal. I\
5 wrote down the various areas you intend to go into.\
6 Every single one of them was covered. I will be\
7 able to point to those areas in the transcript when\
8 we have a hearing on this matter.

9 As you pointed out earlier, Mr. Critton, the\
10 seven-hour time limit was relieved by way of the\
11 consolidation order, and it was done in the context\
12 of depositions that are going to require multiple\
13 attorneys -- because there are so many attorneys\
14 involved in this ultimate litigation -- multiple\
15 attorneys to ask questions of a particular witness\
16 whose deposition is going to exceed seven hours,\
17 such as Mr. Rodriguez, who was asked questions by\
18 all seven or eight attorneys. This witness is\
19 being asked questions by one attorney. That was\
20 not the intent of the Court's order, and I think\
21 that Judge Marra is going to have to rule on that\
22 issue again. Every single one of the issues that\
23 you intend to go into was covered.

24 And I'd like to also put on the record that\
25 in your last 15 minutes you proceeded to go into

0430

1 proposals for settlement, which you know are not\
2 admissible, nor reasonably calculated to lead to\
3 admissible evidence, and you did that at your own\
4 peril. And so, if we are going to resume any\
5 deposition of Jane Doe, then it will be by way of\
6 court order.

7 MR. CRITTON: We're done. end 6:09 p.m.\
8 (Whereupon, the Deposition was suspended at\
9 6:09 p.m.)

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