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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401¶
| Phone | Fax |
|---|---|
| 561.682.0905 | - |
1655 Paint Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401¶
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A. No.¶
Q. And we’ve learned that many of the girls, some of whom are as old as 23, were told by the government that they would get money at the end of the criminal prosecution. Does that sound familiar to you?¶
A. No, sir.¶
Q. Other than Mr. Leopold here — I’m not asking about Mr. Herman either —¶
A. Oh-huh.¶
Q. — did anyone ever discuss with you that you could get reimbursement for your damages?¶
A. No, sir.¶
Q. Did you or any member —¶
MR. LEOPOLD: Are you referring to a criminal matter or a civil matter?¶
BY MR. TEIN:¶
Q. Did you or any member —¶
MR. LEOPOLD: Excuse me. Let me object to the form of the question.¶
BY MR. TEIN:¶
Q. Did you or any member of your family ever get a victim notification letter from anyone?¶
A. I no longer live at that residence and I wouldn’t know.¶
Q. So your testimony is that you have never¶
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is it just going to be comma after comma after comma?¶
Go ahead, lawyer.¶
MR. LEOPOLD: All right. The exhibits, I can’t prevent you from taking them, but I will object and I will be bringing it to the court for sanctions. You cannot take the exhibits out of the room without them being marked. I want them marked, because you cannot identify in the record what was used. And with all due respect to Mr. Goldberger, I do not — the way this deposition is going, I do not want to rely on Counsel from Miami to mark the appropriate exhibits. I will not do that. I cannot prevent you from taking them. But if you do, I will be bringing the matter to the court with appropriate sanctions, because that is improper. That is improper. When you use something in a deposition, they are to be marked. And you have refused to do that throughout for what ever reason.¶
MR. TEIN: You’re wrong. Finish your sentence because you’re talking about something you have no idea.¶
Every single one is marked, Ted. Every single one is already marked. But you want to¶
- finish. You behave.
- MR. LEOPOLD: Don’t point your finger at me.
- MR. TEIN: Listen. Be quiet and I won’t have a need to point it at you.
- MR. LEOPOLD: Don’t point your finger at —
- MR. TEIN: Mr. Leopold —
- MR. LEOPOLD: Don’t point your finger at me.
- MR. TEIN: Mr. Leopold —
- MR. LEOPOLD: Jack, do you want to take care of this?
- MR. TEIN: Let me finish my sentence. The exhibits are marked. We are walking out of here.
- You are someone who misrepresents the record. It is absolutely atrocious what you do.
- That is not how a lawyer should behave. This deposition is over. You will get your exhibits, Mr. Leopold.
- MR. GOLDBERGER: I understand what you’re saying, Michael, and I understand Ted’s position.
- Just so there’s — we’re going to have lots
of issues in this case. We’re going to have lots of reasons to disagree.¶
I’m going to take it over sow and I’m going to make copies and I’m going to give them to Ms. Consor. If you want to go find some exhibit labels and put some exhibit labels on it, be my guest. But that’s what I’m offering to do.¶
THE WITNESS: Let me say two things, because I am happy to always disagree, and with you, I have no problem; we could always do it professionally. I have not problem.¶
I want to say two things so the record is very clear.¶
Since for whatever reason I have not been able to look at exhibits, because they have been refused to have been shown to me —¶
MR. TEIN: That’s a lie.¶
MR. LEOPOLD: — Jack, if you represent that the documents have the appropriate exhibit numbers or some identifying markings, 25, 30.000, whatever they may be, then you can take them, make copies, send me a copy, make sure the court reporter gets a copy and then send me a bill for my copies, that’s fine. I didn’t know that they are marked that way because I haven’t been able to¶
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look at them.¶
MR. GOLDBERGER: They are barcoded, and the number that we’ve made reference to in the deposition coincides with the barcoding.¶
MR. LEOPOLD: That’s fine. Eight by eleven color laser copies are fine.¶
MS. BELOHLAVEK: The State Attorneys Office is not going to charge anybody for color copies I print out.¶
MR. LEOPOLD: That’s fine. He’s going to take them back to his office.¶
Secondly — and I will be more than happy to do it, because it sounds like you all know more about it than I — but I’m happy to get affidavits from Mr. Pincus, Judge Stern, everybody else about what happened with this hearing today, because I know very little about it. But my representations are what they are.¶
MR. GOLDBERGER: They stay —¶
MR. LEOPOLD: Let me just finish for the record.¶
My representations or comments about what happened, representation about this bearing this morning, I know very little about it. I —¶
MR. GOLDBERGER: I’ll take your word on¶
I have no idea, but if your co-counsel wishes an affidavit to that effect from Mr. Pincus, I’m more than happy to get it. But I don’t know the reason why it was canceled.¶
MR. TEIN: I don’t need it. But what I do take issue with is regardless of why it was canceled, you owed us the courtesy of saying, You know what? We can start earlier this morning.¶
MR. LEOPOLD: I owe you nothing.¶
MR. TEIN: I don’t care. Don’t interrupt me.¶
Because Jack canceled his vacation plans because of you.¶
MR. GOLDBERGER: That’s all right, that’s all right.¶
MR. TEIN: And you’re selfish. And this deposition is over. Good-by Mr. Leopold.¶
MR. GOLDBERGER: You can go off the record.¶
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