EFTA01070501

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 Page 35 of 46 
Case 9:O8•cv 80811-KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2009 Page 5 of 14 
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this sexual assault and whatever occurred during 
these events is that -- has caused her damage. 
d therefore damagoo in the code sunk' 
as the emotional, mental, psychiatric-type 
damages are completely subjective, I mean' 
separate and apart from any medical bills !that 
may be -- which are clearly intangible. 
tho these 
are intangible damages. And the jury is
instructed, you know, you advise the greater 
weight of the evidence, what's fair and 
reasonable under the circumstances. 
So what we would have is basically this 
young lady's testimony as to what she claims her 
damages are and what the circumstances are with 
her situation with Mr. Epstein. She claims on 
page 13, you know, I love this guy, I'm dating 
this guy Chris. On page 15 --
THE COURT: Is this part of a diary for 
treatment? 
MR. CRITTON: I have no idea what it is. It 
was just produced in response to discovery. And 
she apparently started in, I think this is 
December of '08. You know I took Jay Lyntenis' 
girl to the zoo, had an amazing day, I love her, 
i.e., the girl. We have so much fun. I want a 
U.S. Le al Sue ort 
EFTA01070521

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 36 of 46 
Case 9:08-cv 80811-KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2006 
Page 6 of 14 
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baby especially with him. Okay. So I know who 
this person is. We are all so open together, I 
love him. III day and Lynn, whdL du I du wILl. 
Chris, who is another guy in her life. 
All right. This is circumstances where 
this young lady is saying, look, Jeffrey Epstein 
has ruined my life from a damage standpoint, 
okay. Let me depose other individuals with whom 
you've had a relationship. And what if 1..c turns
out -- as with some of these girls did --'is they 
had relationships or had escapades or 
circumstances with individuals, older men similar 
to Mr. Epstein well before Mr. Epstein.
And this girl, I don't know onefway or 
the other, but let's assume she had a situation 
where she was assaulted or molested or raped, ' 
that all is going to affect her emotional:and her 
mental pain and anguish and it will all fitbtor 
into evaluating damages. 
You know, it's not something that I'm 
going to spread around. I'm happy to keep it, 
you know, within the confines of the discbvery of 
this case. But if she says every other 
relationship in my life has been perfect but Jeff 
Epstein has done this to me and it has affected 
U.B. Legal Support 
EFTA01070522

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 37 of 46 
Case 9:08-cv-80811-KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2009 
Page 7 of 14 
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my ability to trust men and my sexual 
relationships with other men, which is part of 
lk 
her interpersonal retationsnips, ukay, ley-a to 
to Sam Smith. 
THE COURT: When does your client allege 
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that she had her first encounter with 
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Mr. Epstein? 
MR.. GARCIA: At what age? 
THE COURT: Well, what year? 
MR. CRITTON: June of '03. 
MR. GARCIA: June of '03, Judge.
'MR. CRITTON: She claims from June o£ '03 
through November of '04. 
MR. GARCIA: She was I believe 16at.the 
beginning and ended at 17. She was a minor 
during all this time. 
THE COURT: June of '03 to now is six years. 
Let me hear from Mr. Garcia.
MR. GARCIA: Judge, in the criminal case 
that was filed against Mr. Epstein, he would not 
have had a right to do this type of discolflarY and 
I -- if I could hand up --
THE COURT: They wouldn't care about:the 
women. 
MR. GARCIA: Right. Well, I mean --; 
U.S. Legal Su ort 
EFTA01070523

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 38 of 46 
Case 9:08-cv-80811-KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2009 Page 8 of 14 
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THE COURT: This is damages. There'S no 
they weren't seeking damages at the time.! 
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MR. GARCIA: Right. And we nave not.aiseged 
in the complaint or in the answers to 
interrogatories that her ability to have a 
relationship with a man has been affectedby 
Mr. Epstein's conduct. 
We have alleged that she has been 
hospitalized for depression, anxiety but 4e have 
not alleged any damages concerning -- the:only 
reason this would be relevant is if we were 
making a claim at her ability to have either 
sexual relations or to have emotional relations 
with men was effected by her experience with 
Mr. Epstein. 
So this damages' claim is just a smoke 
screen to attempt to get evidence to show:the 
jury that this woman has had other consensual 
relationships with young men that are 
approximately her age what I would characterize 
as a slut defense. She had it coming to her 
because she engaged in other voluntarily 
consensual --
THE COURT: Mr. Critton wouldn't try the 
slut defense in my courtroom, I'm sure. 
U.S. Legal Support 
EFTA01070524

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 39 of 46 
Case 9:08-cv-80811-KAM 
Document 54-5 • Entered on FLSD Docket 04/02/2009 Page 9 of 14 
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MR. GARCIA: Maybe not, but certainit that's 
the way this discovery is going. And, Judge, 
what --
THE COURT: What are the damages you think 
your client is seeking? 
MR. GARCIA: She is seeking emotional 
distress damages for depression and anxiety and 
she has been hospitalized at the Oakwood Center. 
Her friend -- she was on the phone to a friend 
who called the sheriff's office because she 
thought she was suicidal. The sheriffs
responded. They Baker Acted her that day:and 
they took her eventually to the Oakwood Center. 
THE COURT: How do we know it's not 
intertwined with her rejection by three other men 
since Mr. Epstein? 
MR. GARCIA: Well, even if it was related to 
her rejection by three other men -- you mean 
other men's rejection of her? 
THE COURT: Yeah. Well, how do you not know 
that? I mean you can't do it until you do 
discovery. Has anybody attempted to review the 
records from Oakwood to find out what's going on? 
MR. CRITTON: It's like a one-time visit 
when she was Baker Acted and then there's:some 
U.S. Legal Support 
EFTA01070525

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 40 of 4q.. 
Case 9:08-cv-80811-KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2009 
Page 10 of 14 
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other --
THE COURT: She didn't receive treatment? 
that day and she's been back a couple of times. 
She's on medication. Again, I don't know:what or 
the extent but she's got -- her medical bills are 
de minimis. 
Again as an example, Judge, didlthe 
Court have an opportunity to look at the case 
that I also attached to the motion? BecaUse 
there's a case that's almost on all fours.with 
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this which I attached to our motion which;is 
called Belles versus Russo. 
THE COURT: Right.
MR. CRITTON: It was a case where the 
plaintiff was sued -- the plaintiff sued ihe 
former owners of a house of prostitution. ` So 
that part is different, but within it there were 
a number of claims including a sexual assault 
claim and they sought emotional pain, humiliation 
and emotional distress. 
Within the complaint that was filed in 
this particular case, she is seeking severe 
emotional distress, mental anguish, humiliation, 
embarrassment, past and future, compensatory 
U.B. Legal Su >ort 
EFTA01070526

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 41 of 46_, 
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Case 9:08-cv-80811-KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2009 
Page 11 of 14 
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humiliation, loss of reputation, mental anguish, 
pain and suffering, the same type of damades. 
Ana what: tht CuuLL acid 
THE COURT: How old is she now? 
MR. GARCIA: She's 21 no*. 
MR. CRITT0N: She's 21 now. What the Court 
said is, you know, if you'd only brought this 
claim under 796 evidence of past issues, it's not 
an issue. You can't use this defense for,
anything, but because you brought these other 
claims which include, you know, sexual assault 
and you're seeking damages for other causes of 
action since the information sought by discovery 
may be relevant or may lead to the discovery of 
admissible evidence in one or more of the other 
causes of action or determination of damages, we 
cannot conclude the trial:court parted fr#a 
essential requirements of law in granting'--
THE COURT: So in other words, she's'not 
only seeking -- she's seeking current emotional 
damage as a result of this relationship and 
you're trying to find out if she had prior 
relationships, that perhaps could be intertwined 
with it so that it's not just Mr. Epstein's --
MR. CRITTON: Right. A perfect exorable is 
U.S. Legal' Support 
EFTA01070527

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 42 of 46 
Case 9:08-cv-80B11-KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2009 Page 12 of 14 
20 
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one of the cases that I have is there's ECyoung 
lady who claims that she was molested in the past 
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and raped, pretty signiticant issues, welt in 
advance of her even meeting with Mr. Epstein. 
And they seem to play a large role in her' 
psychiatric and psychological evaluation.: 
We're going to come to the Court in 
this case as we have others and ask for a: 
psychological evaluation of this lady, and if she 
was raped or if she was molested or just she had 
a bad experience or some -- whether it we's a 
young or old man assaulted her in some fabhion, 
that may play a role in her damages and what --
THE COURT: What I'm going to allow for 
discovery purposes only not necessarily getting 
it in at the time trial are two years before her 
first encounter with Mr. Epstein and anything 
subsequent. 
MR. GARCIA: Judge, I just wanted to!say on 
the record because I forgot to mention it., 
there's also -- I did state an objection to the 
identity of people that are unrepresented' in this 
courtroom. They have rights too. So what I --
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THE COURT: Well, my suggestion is that you 
send thoee people a letter and tell them that 
U.S. Legal Support 
EFTA01070528

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 43 of 46 
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Case 9:08-cv-80811 -KAM 
Document 54-5 
Entered on FLSD Docket 04/02/2003 
Page 13 of 14 
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you're going to disclose them and if they have a 
problem with it that they come to see me before 
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you disclose lt. 
So I'm going to give you 20 days to 
respond to this rather than the usual five and 
that will give you time to put these people on 
notice and if they want to come visit with me and 
have a John Doe, I'll have a John Doe heaking 
but, you know, this is her case. She's doing it. 
She's the one seeking damages, and he is entitled 
to be able to confront other individuals to find 
out information that may be relevant to the 
damages she's seeking or she can drop the.
damages. That's her choice. If you seeki 
damages, you've got to do it -- if you could put 
that in an order so that we have a time far him 
to do this. 
Just fill out an order, hand it back up 
to me and I'll deal with it. 
(The proceedings were concluded1) 
U.S. 
mI iimai
al
rt 
EFTA01070529

Case 9:08-cv-80119-KAM 
Document 207-4 
Entered on FLSD Docket 07/20/2009 
Page 44 of 46 
Case 9:08-cv-80811-KAM 
Document,54-5 
Entered on FLSD Docket 04/02/2009 
Page 14 of 14 
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REPORTER'S CERTIFICATE 
THE STATE OF FLORTDA. 
COUNTY OF PALM BEACH. 
I, Teresa Bell, Court Reporter, certify that 
I was authorized to and did stenographically report 
the foregoing proceedings and that the transcript is a 
true and complete record of my stenographic notes. 
I further certify that the proceedings were 
taken at the time and place shown herein and that all 
counsel and persons as hereinabove shown were present. 
•I 
I further certify that I am not a relative, 
employee, attorney or counsel of any of the patties, 
nor am I a relative or employee of any of the parties' 
attorney or counsel connected with the action, nor am 
I financially interested in the action. 
Dated this 11th day 
TERESIf BELL, 
Court Reporter 
U.S. Legal Support 
EFTA01070530

Case 9:08-cv-80119-KAM 
Document 207 
Entered on FLSD Docket 07/20/2009 
Page 8 of 9 
and Gloria C. Hakkarainen, M.D. until such time as the Court decides whether the 
statutory damages pursuant to 18 U.S.C. §2255 are available to a victim of an 
enumerated sexual offense on a per incident basis. 
CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1 
Counsel for the movant conferred via telephone with counsel for the Defendant 
and counsel for the Defendant is not in agreement with Plaintiff's Motion For Protective 
Order Regarding Treatment Records From the Parent-Child Center, Inc., Dr. Serge 
Thys, Dominique Hyppolite/School District of Palm Beach County, Good Samaritan 
Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C. Hakkarainen, 
M.D. and Incorporated Memorandum of Law. 
/s/ Jack P. Hill 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on the 20th day of July, 2009, I electronically filed the 
foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice 
of electronic filing to all counsel of record on the attached service list. 
/s/ lank P Hill 
Jack Scarola 
Florida Bar No.: 169440 
Jack P. Hill 
Florida Bar No.: 0547808 
Searcy Denney Scarola Bamhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach. 
409 
Phone: 
Fax: 
Attorneys for Plaintiff 
8 
EFTA01070531

Case 9:08-cv-80119-KAM 
Document 207 
Entered on FLSD Docket 07/20/2009 
Page 9 of 9 
COUNSEL LIST 
Richard H. Willits, Esquire 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake Worth, FL 33461 
Phone: 
Fax: 
Robert Critton, Esquire 
Burman Critton Luttier & Coleman LLP 
515 North Flagler Drive, Suite 400 
West Palm Beach FL 33414 
Phone: 
Fax: 
Jack A. Goldberger, Esquire 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South 
West Palm Beach FL 33401 
Phone: 
Bruce E. Reinhart, Esquire 
Bruce E. Reinhart, P.A. 
250 South Australian Avenue 
Suite 1400 
West Palm B 
h F 
3401 
Phone: 
Fax: 
9 
EFTA01070532