0260¶
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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