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17 
18 
19 
20 
21 
22 
23 
24 
25 
0432 
1 
2 
3 
4 
5 
6 
Q. So, what really happened was 
7 
going to this --
8 
A. Uh-huh. 
9 
Q. -- psychiatrist, and that's really where 
10 
you got the name was from 
not from his 
11 
mother --
12 
A. Yeah. 
13 
Q. -- isn't that right? 
14 
A. Yeah. Well, his mother is the one that 
15 
referred him and so I got the name from his mother, 
16 
not from =. 
17 
Q. The
 that you, first told you about 
18 
it was =, 
wasn't it? 
19 
A. Yeah. 
20 
Q. Not his mother. 
told you who he was 
21 
going to? 
22 
A. No, like, yeah. 
23 
Q. Yeah, ri ht? 
24 
A. Yeah, 
and his mother. 
25 
Q. So, so 
then told you that he was 
0433 
1 
going to this doctor --
2 
A 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
Q. I thought you told me you told her about 
17 
it? 
18 
A. I didn't tell her about it. 
Q. Do you know her phone number? 
A. No. 
Q. Have you got it in your cellphone? 
A. No. 
was 
MR. MERMELSTEIN: Wait for a question. 
BY MR. LUTTIER: 
Q. So, you told 
mom about this 
situation, too. She's another person that knows 
about this situation. 
A. No she doesn't know about the situation; 
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19 
20 
21 
Q. Well, she's know about Jeffrey Epstein, 
22 
didn't you say? 
23 
A. No. 
24 
Q. Didn't you just say she did? 
25 
A. No. 
0434 
1 
. Okay. So what really happened was you and 
2 
went to this Dr. 
because of problems 
3 
that you two had; isn't that right? 
4 
A. No. 
5 
Q. And the two of you went to see him 
6 
together? 
7 
A. No. 
8 
Q. You didn't do that? 
9 
A. No. 
10 
Q. 
11 
A. 
12 
13 
14 
15 
16 
17 
18 
A 
19 
20 
21 
22 
23 
24 
25 
0435 
1 
2 
A. 
3 
4 
5 
6 
A. 
7 
m i. Okay. 
8 
9 
A. 
10 
11 
12 
13 
14 
15 
16 
17 
A. 
18 
Q. 
19 
A. 
20 
Q. 
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22 
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0436 
1 
2 
3 
4 
5 
6 
7 
8 
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10 
11 
12 
13 
14 
A. 
15 
16 
A. 
17 
Q. And how often do you go for these 
18 
sessions? 
19 
A. Like once or twice a week. 
20 
Q. And where in 
is this office? 
21 
A. 
22 
Q. Do you have an address? 
23 
A. No, I just know exactly where it's at from 
24 
driving there. 
25 
Q. Okay. Well, I want to make sure I have 
0437 
1 
this. It's 
(sic). 
2 
A. Yeah, best of my knowledge. 
3 
Q. Is he a psychiatrist or psychologist or 
4 
neither? 
5 
A. No, he's, he's a psychiatrist. 
6 
Q. Is he -- can he prescribe medication? 
7 
A. I think so, yeah. 
8 
Q. Has he prescribed any medication for you? 
9 
A. No. 
10 
. Has he prescribed any medication for 
11 
12 
A. No. 
13 
Q. Are you on any medication at the present 
14 
time? 
15 
A. No. 
16 
Q. And how much does he charge you for each 
17 
of these visits? 
18 
A. Like $50 a visit. 
19 
Q. Okay. 45 minute session? 
20 
A. An hour. 
21 
Q. An hour session. Have you ever seen 
22 
Jeffrey Epstein's penis? 
A. 
Q. 
A. 
Q. 
A. 
Q. 
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A. Yes. 
24 
Q. Had you seen a man's penis before you saw 
25 
Jeffrey Epstein's penis? 
0438 
1 
A. I don't remember. 
2 
Q. You don't remember? 
3 
A. You've already asked me tl,kesti,on, and 
4 
I don't remember whenever I saw 
so I 
5 
don't remember. Yeah, I think so. 
6 
Q. Okay. 
7 
MR. MERMELSTEIN: Make sure of, sure your 
8 
answer. Don't just answer for the sake of 
9 
answering. 
10 
THE WITNESS: For him, yeah, I don't 
11 
remember. 
12 
BY MR. LUTTIER: 
13 
Q. Did -- was there ever anything that you 
14 
said that you saw Mr. Epstein at some point 
15 
masturbate. I think your terms were jerking off, to 
16 
be exact. Do you recall that testimony? 
17 
A. Yeah. 
18 
Q. And when did that first occur? 
19 
A. After I started getting naked after, like, 
20 
my fifth or sixth visit. After I had already, like, 
21 
whenever I started taking clothings off. 
22 
Q. Did he ask you if he could do that? 
23 
A. No. 
24 
Q. Did you tell him not to do that? 
25 
A. No. 
0439 
1 
Q. Was anyone else ever present for your 
2 
sessions between you and Mr. Epstein? 
3 
A. No. 
4 
Q. Did you ever tell Mr. Epstein you didn't 
5 
want him to masturbate? 
6 
A. No. 
7 
Q. Did Mr. Epstein ever penetrate any orifice 
8 
of your body with a vibrator? 
9 
A. No. 
10 
Q. He just put it on the top of your clit? 
11 
A. Yeah. 
12 
Q. Did Mr. Epstein ever penetrate your anus 
13 
with any object? 
14 
A. No. 
15 
Q. Did he ever penetrate your anus with any 
16 
organ of his body? 
17 
A. No. 
18 
Q. Did you ever tell Mr. Epstein on any of 
19 
these sessions that you had with him that you 
20 
enjoyed it? 
21 
A. Not that I remember. 
22 
Q. Did you ever use any words to that effect 
23 
with him --
24 
A. Not that I remember. 
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25 
Q. -- saying that that was great or I enjoyed 
0440 
1 
it. 
2 
MR. MERMELSTEIN: Objection to form. 
3 
THE WITNESS: I don't remember. 
4 
BY MR. LUTTIER: 
5 
Q. Did you ever tell anyone that you wished 
6 
your boyfriend was more like Mr. Epstein, in 
7 
particularly that you would like it if your 
8 
boyfriend was rougher like Mr. Epstein in having 
9 
sex? 
10 
MR. MERMELSTEIN: Objection to form. 
11 
THE WITNESS: No, I don't remember. 
12 
BY MR. LUTHER: 
13 
Q. Do you recall telling 
that? 
14 
A. No, I don't remember saying that. 
15 
Q. If, if you told him that, it was true, 
16 
wasn't it? 
17 
MR. MERMELSTEIN: Objection to form, 
18 
speculation. 
19 
THE WITNESS: I don't remember saying 
20 
that, so like, I don't know. 
21 
BY MR. LUTTIER: 
22 
Q. Do you remember telling 
that you --
23 
A. No I don't remember saying that to 
24 
A.
25 
Q. You and 
were talking about 
0441 
1 
it, and you and the other girls and you kid that you 
2 
wished your boyfriends were more like, more like 
3 
Mr. Epstein. 
4 
A. I don't remember talking to him about it, 
5 
no. I'm sorry. 
6 
Q. But you did talk to your girlfriends about 
7 
your -- communicatively you-all talked about your 
8 
sexual experiences with Mr. Epstein? 
9 
A. Girlfriends? Yeah, we did. 
10 
Q. Yeah. The other girls that were going to 
11 
see him. 
12 
A. Yeah. 
13 
Q. And you-all knew what each other were 
14 
doing, right? 
15 
A. Yeah. 
16 
Q. You knew who was letting them finger them, 
17 
to use your words? 
18 
A. No, not -- not exactly. 
19 
Q. Who was doing what? 
20 
A. No, we just knew -- I mean, pretty much, 
21 
if you got $200, you weren't doing things. If you 
22 
got $300, you're doing more than just giving him a 
23 
massage and leaving. So if you say, how much money 
24 
did you get, and then that referred to, oh, you must 
25 
have done something --
0442 
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1 
Q. And you knew --
2 
A. -- and just referring, because you knew 
3 
what you've done, so not saying, oh, this is, this 
4 
is me giving you details, Jane Doe No. 7, of what 
5 
I've done, no. It was, you know, oh, how much money 
6 
did you get, oh, okay. So then it was kind of like 
7 
in the back of your mind you're -- you know. 
8 
MR. LUTTIER: Well, I'm going to have to 
9 
stop now because I've got another appointment 
10 
that I have to get to, so this would be a good 
11 
place to stop as any. 
12 
THE VIDEOGRAPHER: Going off the record. 
13 
It is 6:04. It's the end of Tape 3 of 3. 
14 
MR. LUTTIER: We're just adjourning the 
15 
depo. 
16 
MR. MERMELSTEIN: We understand that. 
17 
MR. LUTTIER: Okay. 
18 
MR. MERMELSTEIN: And I understand that 
19 
you had a discussion before regarding the 
20 
seven-hour time limit with Mr. Horowitz here. 
21 
MR. LUTTIER: Well, no, we didn't have any 
22 
discussions at all before about it. 
23 
MR. CRITTON: He raised the seven-hour 
24 
time limit, and I told him if he looked at the 
25 
consolidation order, the consolidation order 
0443 
did not limit, visa vis it was removed. 
2 
MR. MERMELSTEIN: I don't think so. Well, 
3 
the seven-hour time limit is by rule within the 
4 
Federal Rules. 
5 
MR. LUTTIER: Yeah, but there's an order 
6 
that's been entered since then. 
7 
MR. MERMELSTEIN: Yes, it gives you a 
8 
one-day deposition. And a one-day deposition 
9 
in the Federal -- in the Federal Rules is seven 
10 
hours, so our position is you have seven hours. 
11 
MR. LUTTIER: I understand. 
12 
MR. CRITTON: I'm telling you that Judge 
13 
Marra, in the consolidation order, is very 
14 
specific with regard to the seven-hour rule 
15 
with regard to this case. 
16 
MR. MERMELSTEIN: You turn into a pumpkin 
17 
at seven hours. If you want, if you want more, 
18 
you're going to have to go back to the judge. 
19 
MR. CRITTON: So the judge has entered an 
20 
order; you're saying you're not going to obey 
21 
that order? 
22 
MR. MERMELSTEIN: I am saying the judge 
23 
had -- show me an order where he says you get 
24 
more than seven hours. The consolidation order 
25 
you refer to, I have it right here in my hand, 
0444 
1 
it says you get one day. That to me is seven 
2 
hours. The Federal Rules provide seven hours. 
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3 
I think it's clear. 
4 
MR. CRITTON: Let me read it. Let me read 
5 
it. 
6 
MR. LUTTIER: I think the only reference 
7 
to specific hours is when he said that. 
8 
MR. MERMELSTEIN: Yeah, let me read it. 
9 
Let me read it. As to each of the ten above 
10 
styled cases, the Defendant is limited to a 
11 
single deposition of each Plaintiff. 
12 
MR. LUTTIER: Single deposition, it 
13 
doesn't say that. At any rate, everybody knows 
14 
what the other person's interpretation is. 
15 
MR. MERMELSTEIN: Right. Well, yeah. I 
16 
mean, but to say that there's a clear order 
17 
here which gives you the right to take a longer 
18 
deposition, that's not the case. 
19 
MR. CRITTON: This is an order, and just 
20 
so it's clear, this is Docket Entry 86. There 
21 
was a subsequent order that he entered. 
22 
MR. LUTTIER: Okay. 
23 
MR. CRITTON: Or a prior order. 
24 
MR. MERMELSTEIN: If that's the case, 
25 
provide it to me. I mean, you refer to the 
0445 
1 
consolidation of --
2 
MR. CRITTON: I'm not going to provide you 
3 
that, but I'll refer to you -- I'll send you 
4 
the document. 
5 
MR. MERMELSTEIN: We're supposed to 
6 
cooperate. I mean, if I'm missing something, 
7 
then --
8 
MR. CRITTON: No, no, listen to me, 
9 
Stuart. 
10 
MR. MERMELSTEIN: -- let me know. 
11 
MR. CRITTON: Listen to me, Stuart. 
12 
MR. MERMELSTEIN: What? 
13 
MR. CRITTON: I said what I will do is 
14 
I'll reference the docket number so you can 
15 
look it up because it will be in your file. 
16 
MR. MERMELSTEIN: That, that's fine. 
17 
MR. LUTTIER: Give me a chance. It's like 
18 
your witness. If you listen to the question, 
19 
you're going to get an answer. Okay? 
20 
MR. MERMELSTEIN: All right. 
21 
MR. CRITTON: You guys are gone. We're 
22 
going to stay here until I know. I am assuming 
23 
I am going to give you three minutes to escape 
24 
from the building. 
25 
MR. MERMELSTEIN: Five minutes. 
0446 
1 
MR. CRITTON: Yeah, yeah. 
2 
THE COURT REPORTER: Are you ordering 
3 
this? 
4 
MR. CRITTON: Yes. 
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EFTA00725709

5 
(Witness excused.) 
6 
(Deposition was adjourned.) 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0447 
1 
CERTIFICATE OF OATH 
2 
THE STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
5 
I, the undersigned authority, certify that 
6 
JANE DOE NO. 4 personally appeared before me and was 
7 
duly sworn on the 27th day of October, 2009. 
8 
9 
Dated this 6th day of November, 2009. 
10 
11 
12 
13 
14 
Cynthia Hopkins, RPR, FPR 
Notary Public - State of Florida 
15 
My Commission Expires: February 25, 2011 
My Commission No.: DD 643788 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
0448 
1 
CERTIFICATE 
2 
THE STATE OF FLORIDA 
3 
COUNTY OF PALM BEACH 
4 
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5 
I, Cynthia Hopkins, Registered Professional 
Reporter, Florida Professional Reporter and Notary 
6 
Public in and for the State of Florida at large, do 
hereby certify that I was authorized to and did 
7 
report said deposition in stenotype; and that the 
foregoing pages are a true and correct transcription 
8 
of my shorthand notes of said deposition. 
9 
I further certify that said deposition was 
taken at the time and place hereinabove set forth 
10 
and that the taking of said deposition was commenced 
and completed as hereinabove set out. 
11 
I further certify that I am not attorney or 
12 
counsel of any of the parties, nor am I a relative 
or employee of any attorney or counsel of party 
13 
connected with the action, nor am I financially 
interested in the action. 
14 
The foregoing certification of this transcript 
15 
does not apply to any reproduction of the same by 
any means unless under the direct control and/or 
16 
direction of the certifying reporter. 
17 
Dated this 6th day of November, 2009. 
18 
19 
20 
21 
Cynthia Hopkins, RPR, FPR 
22 
23 
24 
25 
0449 
1 
DATE: 
November 6th, 2009 
2 
TO: 
JANE DOE NO. 4 
c/o Adam D. Horowitz, Esquire 
3 
MERMELSTEIN & HOROWITZ, P.A. 
18205 Biscayne Boulevard 
4 
Suite 2218 
Miami, Florida 33160 
5 
IN RE: Jane Doe No. 2 vs. Epstein 
6 
CASE NO.: 08-CIV-80119-MARRAHOHNSON 
7 
Please take notice that on Tuesday, the 27th of 
8 
October, 2009, you gave your deposition in the 
above-referred matter. At that time, you did not 
9 
waive signature. It is now necessary that you sign 
your deposition. 
10 
As previously agreed to, the transcript will be 
furnished to you through your counsel. Please read 
11 
the following instructions carefully: 
At the end of the transcript you will find an 
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12 
errata sheet. As you read your deposition, any 
changes or corrections that you wish to make should 
13 
be noted on the errata sheet, citing page and line 
number of said change. DO NOT write on the 
14 
transcript itself. Once you have read the 
transcript and noted any changes, be sure to sign 
15 
and date the errata sheet and return these pages to 
me. 
16 
If you do not read and sign the deposition 
within a reasonable time, the original, which has 
17 
already been forwarded to the ordering attorney, may 
be filed with the Clerk of the Court. If you wish 
18 
to waive your signature, sign your name in the blank 
at the bottom of this letter and return it to us. 
19 
Very truly yours, 
20 
21 
22 
Cynthia Hopkins, RPR, FPR 
23 
I do hereby waive my signature. 
24 
25 
JANE DOE NO.4 
0450 
1 
CERTIFICATE 
2 
3 
THE STATE OF FLORIDA 
4 
COUNTY OF PALM BEACH 
5 
I hereby certify that I have read the foregoing 
6 
deposition by me given, and that the statements 
7 
contained herein are true and correct to the best of 
8 
my knowledge and belief, with the exception of any 
9 
corrections or notations made on the errata sheet, 
10 
if one was executed. 
11 
12 
Dated this 
day of 
13 
2009. 
14 
15 
16 
17 
18 
19 
JANE DOE NO.4 
20 
21 
22 
23 
24 
25 
0451 
1 
ERRATA SHEET 
2 
IN RE: JANE DOE NO. 2 VS. EPSTEIN 
CR: Cynthia Hopkins 
3 
DEPOSITION OF: JANE DOE NO.4 
TAKEN: October 27, 2009. 
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5 
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 
PAGE # LINE # CHANGE 
REASON 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
Please forward the original signed errata sheet to 
this office so that copies may be distributed to all 
18 
parties. 
19 
Under penalty of perjury, I declare that I have read 
my deposition and that it is true and correct 
20 
subject to any changes in form or substance entered 
here. 
21 
22 
DATE: 
23 
24 
SIGNATURE OF 
DEPONENT: 
25 
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