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Record · Dec. 23, 2005

Record, 2005-12-23

I 07/26/17 Page 2609 Public Records Request No.: 17-295

DA - NOTICE TO RENTERS

36173

s insurance primary: The valid and collectible liability insurance and personal injury protection insurance of any authorized rental or driver is primary for the limits of liability and personal injury coverage required by ss.324.021 (7) and 627.736, Florida Statutes.

to return rental Vehicle: Failure to return rental property or equipment upon expiration of the rental period and failure to pay all s due (including costs for damage to the property or equipment) are prima facie evidence of intent to defraud, punishable in accorvith section 812.155, Florida Statutes.

erms supersede any conflicting terms stated elsewhere.

Agreement is between the undersigned and the company identified above (the “Company”). By signature below, the undersigned acknowledges and represents that they are legally authorized to operate the rental vehicle we’s license, and that they have read and agree to the terms, conditions and notices, both printed and written, including the Loss Damage Waiver information, that appear on this Rental Statement and on the separate (the “Agreement”), which is incorporated therein. THE UNDERSIGNED AUTHORIZE THE COMPANY TO PROCESS A CHARGE TO THEIR CREDIT, DEBIT OR CHARGE CARD IN THE AMOUNT SPECIFIED ABOVE RETURN OF THE VEHICLE. ALL CHARGES SUBJECT TO AUDIT. No additional drivers are permitted without the approval.

BanninRENTER XADDITIONAL DRIVER

295

Public Records Request No

16

:S

Jeffrey E. Epstein

10 Dr. Berd

1100

to more 11° uz than

calle work at le ou

. 5

trying

Jeffrey E. Epstein

11 (rerent the cor) - contract up on 2nd of february Dollar Rond D Con Blue Dodge Noon (561) 686- 3300 Jeffrey E. Epstein 07/26/17 Page 2613 Public Records Request No.: 17-295

car extansion Imonth

29 pm butet of roses to Royal Palm Beach High school for

bive the flowers of

8:30 to sb. to give it to her fat the stage ofter performance

DTG OPERATIONS dba DOLLAR RENT A CAR 2401 Turnage Boulevard West Palm Beach, FL 0000033 866-434-2226

West Palm Beach Int’

1 2 4

i.

BANASIAK JANUSZ 358 EL BRILLO WAY

PALM BEACH

FL

33480

1270

FL

04/07/2012 ADD’L DRIVER: None

SLI PPP ESP 561-818-8361

CUSTOMER DECLINES LOW AND IS RESPON-SIBLE FOR LOSS OR DAMAGE PER TERMS OF THE RENTAL AGREEMENT. UMP DECLINED

Rate: WALK Cls: CDAR 920001

VEH.#: 817622-1 L1C.#: W28G15

NISSAN

FUEL LEVEL OUT: FULL MILEAGE OUT:

05

ACCEPT @ 11.95/DAY 322.65 DECLINED DECLINED Est Optional Coverages 322.65

STALL#:

SENTRA

11230

BY YOUR INITIALS YOU ACKNOWLEDGE YOU HAVE ACCEPTED OR DECLINED THE ABOVE OPTIONAL ITEMS: X

12/23/2005 1040HH115484-5
TIME OU
11/26/2005
TIMEIN
**RENTAL RATES**EST CHG
Hours12.00/mls
•24.99/mls
Weeks124.95/mls499.80
Xday24.99/mls
Unlimitd mls
VEH LIC FEE
FLA SRCHRG*
.47/Day12.69
FLA SRCHRG*2.03/Day54.81
Fuel5.99/gal
STATE TAX
Est Optional
6.500%36.87
Est OptionalCoverages322.65
J**ESTIMATED CHARGES**926.82
YOU ARE RESP
VIOLATIONS.IF YOU FAILTO PAYOUR
TICKET(S), ANY UNPAID TICKET5),
PENALTIES, PLUS A $25.0O FEEPER
CITATION, WILL BE BILLED TO YDUR
CREDIT CARD.x
ESTIMATED/ACTUAL CHARGES MAYARY

* FL Surchg includes $2 FL St Srchg & .03 Recycle Fee Recv CREDIT CARD AUTHORIZATION/CASH DEPOSITS VI/************************************

CUSTOMER HAS NOT USED THE AIRPORT IN THE LAST 24 HOURS.

WLK SMCKED/187

A per hour rate for late returns is charged right after the start of new Rental Day.

* 44

.

12-20-2005 14:45:56 JJ8375 JJ8375 00DTG OPERATIONSdba DOLLAR RENT A CAR
DIG OFERALIONSUDG DULLAR KENT A LAK

tuls05

Report #0492 Page 0001

Screen Print
Dollar RA OPEN HH115484 OPEN
1 NME L/F BANASIAK/JANUSZ11 RET DATE/THE 12-23-2005/1040
2 ADDRESS 358 EL BRILLO WAY12 RET LOC/DROP PBI/*
3 C/S/Z PALM BEACH/FL/3348013 VEH/CL/RT/CL 817622/CDAR/WALK/CDAR
4 PH/DOB/GEN 561-818-8361/04-07-11953/M 14 ODM/FUEL 11230/8
5 LOCL CNT 561655762615 EMP/OPEN EMP/DRW SMCKED/SMCKED/187
6 L1/ST/EX/VER B522420531270/FL/004-07-2012/*
7 FOP/#/EX V1/4470115340008274/022-07 A-RATES G-DTS/MISC
8 ATH#/AMT 050298/1066B-DB/CUST K-RA CLOSE
9 SR/TY/ID WLK/W//C-DEPOSIT N-NOTES
10 NOTES *D-OPTIONS C-OTHER WINDOWS
F1=RD ONLY F2=SWIPE F3=ERASE F6=S

— End of report —

07/26/17 Page 2617 Public Records Request No.: 17-295

IMPORTANT MESSAGE IMPORTANT MESSAGE FOR FOR TIME 10: 40 MM 105 TIME 10:00 DATE DATE SMI M OF. CF. PHONE/ PHONE 72-971-1000 MOBILEC MOBILE TELEPHONED PLEASE CALL PLEASE CALL TELEPHONED CAME TO SEE YOU CAME TO SEE YOU WILL CALL AGAIN WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION 15 MESSAGE. MESSAGE . and she can’ come today a SIGNED 8 SIGNED. 1184 1184 RIGNED 12 IMPORTANT MESSAGE FOR 10/2/05 TIME 10:20 FM DATE ono 407 M 100/1 801-3590 MAIXADO OF. PHONE/ MEGSAGE MOBILE X PLEASE CALL TELEPHONED SPECIAL ATTENTION RETURNED YOUR CALL WILL CALL AGAIN CAME TO SEE YOU HSON WANTS TO SEE YOU RUSH WANTS TO SEE YOU CAME TO SEE YOU MITT CVIT YEVIN SPECIAL ATTENTION RETURNED YOUR CALL PLEASE CALL LELEPHONED MOBILE MESSAGE. /BNOHd - 20 HO ” IN DATE Tible 50/1 2 FOR IMPORTANT MESSAGE 07/26/17 Page 2620 Public Records Request No.: 17-295 B 1184

GUERLAIN SKIN CARE R

NAME: EMAIL:

TELEPHONE:

DO YOU HAVE ANY CONCERNS WITH THE FOLLOWING?

D LINES DEHYDRATION BREAKOUTS □ IRREGULAR TEXTURE □ IRREGULAR COLOR

D PIGMENTATION

1×a week PUB 2-3 week

O

DRY

DEYE PUFFINESS DARK CIRCLES

0

HIGHLY SENSITIVE

NIGHT MOISTURIZERS:

MASKS/EXFOLIATORS:

PURIFYING INVIGORATING MASK L

BAUME DE LA FERTE LIP BALM____

SUCCESSLASER DAY CARE_

SUCCESSLASER CONCENTRATE

SUBSTANTIFIC FIRMING NECK CREME____

MOISTURIZING INVIGORATING MASK

SUBSTANTIFIC NIGHT CARE

SUCCESS NIGHT MODEL

SMOOTHING EXFOLIATOR

SPECIAL CARE:

CRÉME CAMPHRÉA

SERENISSIMA

S.O.S. CREAM

S.O.S. SERUM

WHAT WOULD YOU LIKE TO CHANGE ABOUT YOUR SKIN?

WHAT IS YOUR SKIN TYPE?

and the second second
OILY ·NORMAL/OILYNORMAL/DRY

CLEANSERS:

V PURE VEIL CLEANSING MILK

PURE DEW CLEANSING FOAMING GEL PERFECT EYE AND LIP MAKEUP REMOVER.

TONERS:

PURIFYING IRIS TONER MOISTURIZING MALLOW TONER SUCCESS SMOOTHING TONER

EYE CARE:

SUCCESS EVE TECH EYESERUM HAPPYLOGY EYE CREAM SUBSTANTIFIC EVE AND LIP

DAY MOISTURIZERS: V HAPFYLOGY CLA

  • SUCCESS MODEL SERUM
  • SUPER AQUASÉRUM
  • SUBSTANTIFIC DAY CREAM

THANK YOU FOR OFFERING ME THE OPPORTUNITY TO PROVIDE YOU WITH OUR EXCLUSIVE GUERLAIN FACIAL EXPERIENCE! 10.1.05 GRACE

PRESCRIBED BY: _

ONE SOUTH COUNTY ROAD • PALM BEACH, FL 33480 • (877) 448-3752

SCI EDULE I

THE NEW ALBANY COMPANY ANALYSIS OF THE NACO AND GEORGETOWN CAPITAL ACCOUNTS FROM 1/1/2002 - 12/31/2004 As of 1/20/2005

100 % POSITIVE CASH FLOW APPLIED TO NACO’S INTEREST PAYMENT AND A REDUCTION OF NACO’S CAPITAL ACCOUNT: INTEREST ON GEORGETOWN CAPITAL ACCRUED INTEREST ONLY APPLIED FOR THE YEAR 2004

1NACO CAPITALCash Plew from
Operations (1)(3)
Interest
Expense (2) (3)
Capital Additions/
(Reductions)(3)
Capital Account
Balance (4)
200210,546,345(4,875,000)(5.671.345)75,000,000
69,328,655
200320,162,655(4,506,363)(15,656,292)53,672,363
200418,414,244(3,488,704)(14,925,540)38,746,822
Totals49,123,244(12,870,066)(36,253,178)
IJGEORGETOWN CAPITALCash Flow from
Operations (1)(3)
Interest
Expense (2) (3)
Capital Additions/
(Reductions)(3)
Capital Account
Balance (4)
20021.6.1(650,000)650,00010,000,000
20031. The 1 .(692,250)692,25011,342,250
2004-(737,246)737,24612,079,496
Totalse .(2,079,496)2,079,496

III SUMMARY OF NACO & GEORGETOWN CAPITAL ACCOUNT ACTIVITY

Cash Flow from
Operations (1)(3)
Interest
Expease (2) (3)
Capital Additions/
(Reductions)(3)
NACO Capital
Balance (4)
Georgeto vn Capital
Bala: ce (4)
240210,546,345(5,525,000)(5,021,345)69.328,65510.650,000
200320,162,655(5,198,613)(14,964,042)53,672.36311,342,250
200418,414,244(4,225,950)(14,188,294)38,746,82212.079,496
Total49,123,244(14,949,562)(34,173,682)

(1) See page 2 of the Calculation of Estimated Performance Fee for detail of the Managed Cash Flows for years 2002-2004 . Please note New Albany Country Club is not included until 1/1/2005

All Cash Flows are used to pay NACO Interest and any excess is applied as a NACO Capital Account reduction.

(2) The Annual Interest rate is 6.5%. Interest is calculated on the previous Year’s Ending Capital Account Balance. Interest Payments and Capital Account Additions (Reductions) are applied at the end of Calendar Year.

(3) Positive Cash flow from Managed Properties is applied in the following order: (i) Interest Expense for NACO if any, and the balance applied to reduce the NACO Capital Account until balance is Zero. If the Cash Flow is insufficient to pay the current interest expense then the unpaid portion of the interest

will be added to the Capital Account Balance. Interest on Goorgetown’s Capital sources and is added to the Capital Account. Interest for 2004 is based on 124 days and a 366 day year.

(4) Capital Account Balance as of January 1, 2002 is $85,000,000. NACO is allocated $75,000,000 or $8,24% and Georgetown is allocated $10,000,000 or 11.76%. Thereafter, the Capital Account Balance is the sum of the Capital as of January 1, 2002 plus Additions and less any Reductions. The Capital Account Balance is an of the end of each Calendar Year.

Prepared by Brent Bradbury 9/30/2005

I - 1

New Albany Company Georgetown “Managed Properties” Comparison of Estimated Value and Performance Fee For the Periods 1/1/2002 and 12/31/2004

e

Estimate as of
12/31/2004
As ofEstimated
Estimated Performance Fee Payable to Georgatown
Initial Vested Amount (per agreement)
Interest from the Effective date (see Schedule I, Section II Georgetown Capital)
$ 10,000,000
2,079,496
$ 10,000,0002,079,496
20% of Estimated Incremental Change in Value (Future Amount, see calculation below)
Estimated Performance Fee Payable
29,526,315
$ 41,605,811
and the second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second s29,526,315
Calculation of Estimated “Final” Remaining Yalue
Cash Flow from Managed Properties for the year 2002 -2004(sec Schedule II)
$ 49,123,244:: 49,123,244
Estimated Value of Managed Properties Remaining (1)98,508,33213,508,332
Estimated “Final” Remaining Value$ 147,631,576$ $5,000,0001: 62,631,576
Calculation of “Besinging Value” Plus “Carry Cost”
Beginning Value
Carry Cost (see Schedulo I-1, Section III Summary of Capital Account Activity)
$ 85,000,000
14,949,562
85,000,00014,949,562
”Beginning Value” Plus “Carry Cost ”$ .85,000,000(85,000,000)
Calculation of Estimated “Future Amount”
Estimated “Final” Remaining Value
”Beginning Value” Plus “Carry Cost ”
$ 147,631,576$ 85,000,000
(85,000,000)
62,631,576
85,000,000
Estimated Incremental Change in Value (Puture Amount)$ 147,631,576s .147,631,576
20% of Estimated Incremental Change in Value (Future Amount)$ 29,526,315* : ÷29,526,315
(1) Estimated Value of Managed Properties Remaining
Sell-Out Lands Estimated Cash Flow
Discount on Sell-Out Lands
Estimate as of
12/31/2004*
$ 155,614,000
(59,828,000)
As of
1/1/2001
$169,907,696
(117,236,310)
Estimated
Change
(14,293,696)
57,408,310
Sell-Out Lands Estimated Value after disconat
Bulk Land (Licking County & Misc)
Development Projects
95,786,000
19,100,000
52,671,386
18,798,988
43,114,614
301,012
Duke JV
Market Square (12/31/2004 value reflects mortgage)
Duffy Condo JV
Signature Office (to be transformed to Excluded Properties)
JPI JV (Value/Payment included in Cash Flow from Managed Properties)
New Albany Country Club (Assumed Value is zero as of 12/31/2004)
2,266,332
3,054,000
750,000
700,000
2,144,000
6,785,626
122,332
(3,731,626)
750,000
700,000
(600,000)
(4,000,000)
Contingency and G&A Adjustment$ 121,656,332
(23,148,000)
$ 85,000,000$ 36,656,332
(23,148,000)
Estimated Value of Managed Properties Remaining$ 98,508,332$ 85,000,000$ 13,508,332

*Sell-Out Lands includes increases for properties purchased and decreases for properties sold during the 2002-2004 time p midd thereby making comparisons difficult.

Prepared by Brent Bradbury 9/30/2005

THE NEW ALBANY COMPANY

Jeffrey EpsteinBrent Bradbury
COMPANY:9/30/2005
PAX NUMBER:
212-750-0381
TOTAL NO. OF PAGES INCLUDING COVER
PHONE NUMBER:SENDER’S REPERENCE NUMBER:
Comparison of Values Managed and
Excluded Properties
YOUR REPERENCE NUMHER

NOTES/COMMENTS:

Jeffrey,

Attached is a schedule comparing the value of the Managed Properties as of 1/1/2002 and the estimated value as of 12/31/2004, including the calculation of the Performance Fee.

Regarding your request for the value of the Excluded Properties as of 1/1/2002, the E&?’ appraisal done in 2001 only included “Managed Properties”. Approximately 1,000 acres wer: not included in the E & Y appraisal because they were identified before the appraisal as Excluded Properties. In addition, a significant portion of the acres (approximately 100(1) included in the appraisal were transferred to Excluded Properties before the Beginning Valu: was finalized. If you would like me to prepare an estimate the value of the Excluded Properties as of 1/1/2002 please let me know.

Regards,

Dear Mr. Epstein:

I hope you have seen the program and other materials for the 2005 North American regional meeting coming up on November 4-6 in Montreal. We have not heard from you about attending and want to be sure you are aware of the meeting and have had a chance to consider attending. To that end, I attach the program and a reservation form.

Please let us know if you can attend or not. Just reply to this email or send in a completed reservation form.

Thanks,

Michael O’Neil

Page 1 of 1

Fage 1 of 29

GMai

FW: [Fwd: [Fwd: Re: contract]]

Razek. Ed ERazek@limItedbrands.com To: @gmail.com

Jeffrey-

FYI.

Ed

-----Original Message----From: William Mook [mailto:william.mook@mokindustries.com] Sent: Thursday, September 29, 2005 12:49 PM To: Razek, Ed Subject: [Fwd: [Fwd: Re: contract]]

Ed,

We’re working with Merrill investment bank and Delta to raise $50 million by selling at a discount the first $600 million worth of jet fuel from our production schedule. The $600 million will have an opportunity to be re-invested for equity in the fuel facility to create an opportunity for additional earnings at the investor’s option. Assuming we get a 3:1 multiplier in this second round, the $50 million could conceievably net the investors $1.8 billion in less than 3 years. We’re looking at 10 shares of $5 million each - its all spelled out in the enclosed literature.

Let me know if there is any interest by Jeffrey Epstein, or anyone you know. Let me know what you need from me to help make this happen. Where possible -and necessary- we have agreed to pay finders fees that are convertible to share interest.

Once we have the $50 million we’ll move the program past feasability to the point where project financing is possible. The Delta contract is worth nearly $18 billion. The value of the jet fuel produced by the installation once complete will be around $60 billion - assuming a 20 year life.

Thanks.

Bill Mook, Mok Industries, LLC and CHW, Inc.

begin 666 ATT907843.eml M6”U-:6UE3TQ%.B!0<F]D=6-E9”!”>21-:6-R;W-O9G0@17AC:&%N9V4@5C8N M-2XW,C(V+C -“D-O;G1E,G0M8VQA<W,Z(‘5R;CIC;VYT96YT+6-L87-S97,Z M;65S<V%G90T*4W5B:F5C=#H@6T9W9#H@4F4Z(&-O;G1R86-T70T*1&%T93H@

http://mail.google.com/mail/?&ik=b4d8b0995a&view=pt&th=106a76ce47c29f92&search… 9/:0/2005

mail.com>

Fri, Sep 30, 2005 at 10:26 AM

12

新闻日本日下。

METRO REFUNDS

PAGE 01/85

METROPOLITAN REFUNDS 138 EAST PARK AVENUE LONG BEACH, NEW YORK 11561 TEL (516) 889-6664

FAX (516) 889-6665

Property & Tax Consultants — Utility Auditors — Reducing Your Operating Costs

FACSIMILE TRANSMITTAL SHEET

Jeffrey E. EpsteinMichael Janin
COMPANY:
11 East 71st Street Trust
DATE:
9-29-05
•
FAX NUMBER:
2123718042
TELEPHONE NUMBER:
2127509790
TOTAL NO. OF PAGES INCLUDING COVER:OUR REFERENCE NUMBER:
Oil Auditing Program

Thought this would be of interest to you. Please review and call us if you are interested.

age 2628

EFTA02857178

(an come either on buturday or Sunday. She requires 4 hours minimum as she will treke day off at work. 150$ an hair. She needs car to bring her bend take her home.

Jeffrey E. Epstein

7eb Mail Message

AGENT RS/RS BOOKING REF ZKAZC6

SHOPPERS TRAVEL 196 PRINCETON-HIGHTSTOWN RD WEST WINDSOR NJ 08550 609 936-0808

DATE: SEP 29 2005

29SEP NEW YORK NY COLUMBUS DELTA AIR LINES 130P 318P DL 6375 THURSDAY LA GUARDIA PORT COLUMBUS Q ECONOMY TERMINAL DL NON SMOKING NON STOP RESERVATION CONFIRMED 1:48 DURATION FLIGHT OPERATED BY RP CHAUTAUQUA AIRLINES )>md AIRCRAFT: EMBRAER RJ135/140/145 UNITED AIRLINES 29SEP COLUMBUS CHARLOTTE NC 710P 828P THURSDAY PORT COLUMBUS DOUGLAS UA 2691 U ECONOMY NON STOP RESERVATION CONFIRMED 1:18 DURATION US 1543 FLIGHT OPERATED BY US US AIRWAYS AIRCRAFT: BOEING 737-300 29SEP CHARLOTTE NC FT LAUDERDA FL 930P 1127P UNITED AIRLINES UA 2065 THURSDAY DOUGLAS FLL INTL U ECONOMY TERMINAL 3 NON STOP RESERVATION CONFIRMED 1:57 DURATION US 0539 FLIGHT OPERATED BY US US AIRWAYS AIRCRAFT: BOEING 757-200/300 RESERVATION NUMBER(S) DL/28G28A UA/X2RRSW you 4:52 pm - I can have this one issued as a backup-

of 1

9/29/2005 10:38 AM Public Records Request No.: 17-295

jcp-i

:r

Jeffrey E. Epstein

Dr. Berd 00 00 5 to more for 11° wiz them work at le ou ßı Jeffrey E. Epstein Page 2633 07/26/17 Public Records Request No.: 17-295 EFTA02857183

IDA - NOTICE TO RENTERS

12

r’s insurance primary: The valid and collectible liability insurance and personal injury protection insurance of any authorized rental g driver is primary for the limits of liability and personal injury coverage required by ss.324.021 (7) and 627.736, Florida Statute

e to return rental Vehicle: Failure to return rental property or equipment upon expiration of the rental period and failure to pay nts due (including costs for damage to the property or equipment) are prima facie evidence of intent to defraud, punishable in acc with section 812.155, Florida Statutes.

terms supersede any conflicting terms stated elsewhere.

al Agreement is between the undersigned and the company identi-
driver’s license, and that they have read and agree to the terms,
driver’s license, and that they have read and agree to the terms,
ket (the “Agreement”), which is incorporated herein. THE UNDER
ket (the “Agreement”). BELOW AND FOR ALL ADDIT
SIGNED AUTHORIZE THE COMPANYTO PROCEES & CHARGE TO THEIFR CREDIT, DEBIT OR CUMear on this Hental Statement and on the separ.
ket (the “Agreement”), which is incorporate the second and FOR ALL ADDITH
S RENTAL UPON SIGNATURE BELOW AND FOR ALL ADDITH
y’s approval.
ONAL CHARGES DUE UPON RETURIN OF THE VEHICLE ALL CHARGEES SUBJECT TO AUDIT. Nto additional drivers are permitted without t
Tur. LawoulyRENTER X1 millionADDITIONAL DRIVE

Page 2634

(an come either on buturday or Sunday. She requires 4 hours minimum as she will treke day off at work. 150$ an hair. She needs cor to bring his fond take her home.

Jeffrey E. Epstein

BRANCH BANKING AND TRUST COMPANY CHARLOTTESVILLE, VIRGINIA JANUSZ BANASIAK 04/95 BEATA BANASIAK 12542 GREAT PARK CIRCLE APT 303 12542 GREAT PARK CIRCLE APT 303 BBBB Pay to the Order of 11111

PAG S Copyright 2003, Purclue Pharma L.P., Stamford, CT 05901-3431 A7368-SP PPXX05 7/03 ICICIEIN --------------------------------------Orkin DRUG STORES Pharmaceutical Security Institute Sellarin F

-1

1

Palm Beach Police Department Trash Recovery Log

Location: 358 El Bella

TRASH (Y,N)POSITIVE (Y,N)IDENTIFIER (Y.N)CONTRABAND TYPE
9.21.05 wed1YNotes
the LiteStar Net, 19
MIN CLARKER
1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1in the second second
C 10 10 10 10
1 - C - C - C - C - C - C - C - C - C -1. A. A. A. A. A. A. A. A. A. A. A. A. A.
A CONTRACTOR OF THE OWNER
Second Second Second
1. 1. 1. A**
100 March 100
S. C. S. States
A
  • Improv Suturday 1500 Bay Road Miuni Flamingos Beach

Jeffrey E. Epstein

Page 2642

DA - NOTICE TO RENTERS

s insurance primary: The valid and collectible liability insurance and personal injury protection insurance of any authorized rental ( driver is primary for the limits of liability and personal injury coverage required by ss.324.021 (7) and 627.736, Florida Statute:

to return rental Vehicle: Failure to return rental property or equipment upon expiration of the rental period and failure to pay a ts due (including costs for damage to the property or equipment) are prima facie evidence of intent to defraud, punishable in acco with section 812.155, Florida Statutes.

terms supersede any conflicting terms stated elsewhere.

Agreement is between the undersigned and the company identified above (the “Company”). By signature below, the undersigned acknowledges and represents that they are legally authorized to operate the rental vehic ver’s license, and that they have read and agree to the terms, conditions and notices, both printed and written, including the Loss Damage Waiver information, that appear on this Rental Statement and on the separit (the “Agreement”), which is incorporated berein. THE UNDERSIGNED AUTHORIZE THE COMPANY TO PROCESS A CHARGE TO THEIR CREDIT, DEBIT OR CHARGE CARD IN THE AMOUNT SPECIFIED ABD’ RENTAL UPON SIGNATURE BELOW AND FOR ALL ADDITIONAL CHARGES DUE UPON RETURN OF THE VEHICLE, ALL CHARGES SUBJECT TO AUDIT, No additional drivers are permitted without t approval.

approval.and the second second
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Jeffrey E. Epstein

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006 CF09454AXX

STATE OF FLORIDA,

  • 11S-

JEFFREY EPSTEIN,

Defendant.

DEPOSITION OF

Wednesday, February 20, 2008

2:00 p.m. - 4:30 p.m. Palm Beach County Courthouse 205 North Dixie Highway West Palm Beach, Florida 33401

Reported By: Judith F. Consor, FPR Notary Public, State of Florida Consor a, Associates Reporting and Transcription Phone - 561.682.0905

Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401

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• Repotting end Transcriptioa, lac. sor & Associates

Page 2 1 APPEARANCES: 2 On behalf of the State: 3 LANNA BELOHLAVEK, ESQ. ASSISTANT STATE ATTORNEY 4 401 North Dixie Highway West Palm Beach, Florida 33401 5 561.355.7100 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 On behalf of the Defendant: 10 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 11 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 12 WEST PALM BEACH, FLORIDA 33401 561.659.8300 13 14 ALSO PRESENT: ON BEHALF OF THE WITNESS: THEODORE J. LEOPOLD, ESQ. 15 KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL-EZE 16 17 18 19 20 21 22 23 24 25

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*
nsor & Associates
Reporttnp and Transcription. Inc
Rule
NDEX
I
1
2WITNESS:PA(;’. :
3DIRECT EXAMINATION
4BY MR. TEIN:
5
6-
-
-
7NOEXHIBITS
MARKED
8
9CERTIFIED QUESTIONS
10Page
Line
53
22
1155
1
2
59
12111
14
112
13
14
15
16
17
18
19
20
21
22
23
24
25

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sor & Associates Reporting and Transcription, Inc.

Page 4
1Deposition taken before Judith F. Consor,
2Court Reporter and Notary Public in and for the State of
3Florida at Large, in the above cause.
4
5Thereupon,
6
7having been first duly sworn or affirmed, was examined
8and testified as follows:
9THE WITNESS:
I do.
10DIRECT EXAMINATION
11BY MR. TEIN:
12Good afternoon.
Please tell me your full
Q.
13name.
14A.
15Q.
And can you please spell it.
16A.
17
18Thank you.
Q.
19May I call you
20A.
Uh-huh.
21Q.
I’m going to ask you a few
22questions, several questions today. If at any time you
23want to take a break, you just let me know.
Okay?
24A.
Okay.
25If you at any time don’t understand one of
Q.

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Page 5
1my questions, will you just please let me know?
2Yes.
A.
3Q.
And if at any time you’re not feeling well
4or something like that, you’ll tell us, right?
5A.
Yes.
6Q.
Do you feel okay today?
7A.
Yes.
8Not taking any alcohol or drugs or anything
Q.
9like that, right?
10A.
No.
11So you feel ready to have your deposition
O.
12taken?
13A.
Yes.
14Q.
what is your address?
15A.
I’m currently living at my aunt’s house and
16I don’t know it off the top of my head.
17Q.
Where is it?
18A.
19Who is your aunt?
Q.
20A.
21Q.
Who else is living there?
22A.
my uncle.
23Q.
Anyone else living there?
24A.
No.
25Q.
The contempt motion that your mother filed

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6 C
Page
1against your father regarding your fifty million-dollar
2lawsuit against Jeffrey Epstein says that you live with
3your aunt and uncle and have been living there; is that
4correct?
5A.
Yes.
6Q.
How long have you been living with your
7aunt and uncle?
8A.
Since my father kicked me out.
9That was Thanksgiving of this past year?
Q.
10A.
Yes, sir.
11Okay.
Q.
Didn’t your firefighter boyfriend
12Brett Albritton get an apartment for the two of you?
13A.
No, sir.
He has an apartment, but by
14himself.
15Q.
Did he get an apartment for the two of you
16to live in?
17A.
No, sir.
18Q.
Are you planning to move in with him?
19A.
Maybe one day in the future.
20Q.
Do you have a plan to move in with him
21presently?
22A.
No.
23Q.
Have you been to the apartment that you and
24Brett Albritton have discussed moving in together?
25A.
I have been to the apartment.

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sor & Associates
Repartees end Tnesscric4100. lac.
Page 7
1Q.Where is that?
2A.Palm Beach Lakes.
3Q.Have yoU spent the night over there?
4A.No, sir.
5Q.Do you know the address there?
6A.I do not.
7Q.Isn’t your
planning on living
8with you and Brett?
9A.No.
10Q.you know that this court case is a
11criminal prosecution, correct?
12A.Correct.
13Q.And you know that it’s a criminal
14prosecution against a man who has no criminal background.
15Do you know that?
16A.I do now.
17Q.You agree that court is a very serious
18matter?
19A.Yes.
20Q.And you’re here with your lawyer
21Mr. Leopold,right?
22A.Yes.
23Q.And you know that Mr. Leopold recently
24filed a lawsuit in federal court against Jeffrey Epstein,
25seeking fifty million dollars.

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Page 8
1MR. LEOPOLD:
Let me just object.
2let me instruct you.
Anything that
3you have learned through conversations between you
4So if you know any of that
and me are protected.
5information outside of those discussions, you may
6answer.
But if the only way you know it is
7through our discussions, do not answer that
8question.
9BY MR. TEIN:
10Q.
you know that Mr. Leopold recently
11filed a lawsuit in federal court on your behalf against
12Jeffrey Epstein seeking fifty million dollars?
13MR. LEOPOLD:
Same objection.
14If you know the answer to that outside of
15our discussions, you may answer. If it is the
16only way that you know the answer is through our
17discussions, do not answer that question.
18THE WITNESS: Okay.
19MR. LEOPOLD: Attorney/client privilege.
20BY MR. TEIN:
21Q.
You can answer the question unless
22MR. LEOPOLD:
Same objection.
23MR. TEIN:
Let me finish.
24MR. LEOPOLD: Excuse me. We’re
25MR. TEIN:
No.
Let me finish.

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sor & Associates
Reportingad Trisicription, lac.
Page 9
1MR. LEOPOLD:
we’re not going to do
2that.
3MR. TEIN:
My name is not
4I’m going to finish my question.
Okay?
5MR. LEOPOLD:
Do not answer until you hear
6from me.
7BY MR. TEIN:
8Q.
Other than conversations that you have had
9with Mr. Leopold I’m not asking about that are you
10aware that Mr. Leopold has filed a lawsuit in federal
11court seeking fifty million dollars from Jeffrey Epstein
12on your behalf?
13MR. LEOPOLD: Same objection.
14Anything that you learn through
15conversations between you and me, do not answer.
16Those are protected.
If you know through any
17other realm of knowledge, you may answer.
18THE WITNESS:
No.
19BY MR. TEIN:
20Q.
You have no idea that Mr. Leopold filed a
21fifty million-dollar lawsuit on your behalf against
22Jeffrey Epstein?
23MR. LEOPOLD:
Same objection.
24Do not answer that question if it’s through
25discussions that you and I had.
Outside of that,

07126117 Page 2684 Public Records Request No.: 17-295

Page 10 1 you may answer. So do not answer that question if 2 that is the only basis by which you understand 3 that answer. 4 THE WITNESS: No. 5 BY MR. TEIN: 6 Q. You didn’t know that? 7 MR. LEOPOLD: Don’t answer that question. 8 Again, it’s attorney/client privilege. Any 9 information you’ve learned through conversations 10 between you and I are protected. If you know it 11 through any other realm, you may answer. 12 MR. TEIN: Are you going to say that for 13 every question in the deposition, Mr. Leopold? 14 MR. LEOPOLD: When you ask improper 15 questions like that without the proper — 16 MR. TEIN: You’re going to stop your 17 speaking objections right now. Okay? 18 MR. LEOPOLD: Without the proper — 19 MR. TEIN: You need to stop your speaking 20 objections. 21 Let’s continue. 22 MR. LEOPOLD: Counsel, you just asked me a 23 question and I’m going to state it on the 24 record — 25 MR. TEIN: You need to stop your speaking

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1 objections. Check your rules.

MR. LEOPOLD: Excuse me. For the record, Counsel asked me a question. I’ll state the answer on the record. He asked me the question am I going to be answering that way throughout the deposition. So long as there’s improper foundation and predicate asked by the attorney, I will protect my client and I make the record where appropriate. If counsel wishes to ask an 10 appropriate worded question with the proper foundation and predicate, I will certainly allow the client to answer the question. MR. GOLDBERGER: Why don’t you just state attorney/client privilege and just be done with it? MR. LEOPOLD: I want the record to be clear. MR. TEIN: You want to waste time is what you want to do. You were supposed to be here this morning and you totally broke the deal, the agreement that you had with us if your hearing got cancelled. But let’s move on and maybe you’ll stop obstructing this deposition. MR. LEOPOLD: I think the record is very

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sor & Associates
/O
nRepots’s ad Transcription, lac
Page 12
1clear where we stand thus far.
2Is there a recording taken of this
3deposition?
4THE COURT REPORTER:
Yes.
5MR. LEOPOLD:
Just make sure that’s
6preserved.
7BY MR. TEIN:
8Go to Exhibit 20-01 well, before you do
Q.
9are you aware that a lawyer named Jeffrey
that
10Herman filed a lawsuit on your behalf, yes or no?
11MR. LEOPOLD: Objection.
12Any conversations that you and I have had
13regarding that, if that is the only way by which
14you understand how to answer that question, do not
15It’s attorney/client privilege, as well
answer.
16as any conversations you may have had with the
17attorney from Miami. That is also attorney/client
18privilege.
And I’m assuming
19MR. TEIN:
You’re actually wrong about the
20attorney/client privilege.
21I’m assuming Counsel is not
MR. LEOPOLD:
22asking you to divulge attorney/client
23Of course not.
MR. TEIN:
24BY MR. TEIN:
25are you aware that Jeffrey Herman,
O.

07/26/17 Page 2687 Public Records Request No.: 17-295

Page 13 an attorney, filed a fifty-million-dollar lawsuit on your behalf against Jeffrey Epstein, yes or no? MR. LEOPOLD: Same objection. MR. TEIN: We’ve heard the objection 10 times already. MR. LEOPOLD: Counsel, excuse me. MR. TEIN: Just say attorney/client privilege. Stop interrupting my questions. MR. LEOPOLD: I’m entitled to make an 10 objection for the record, which I’m doing, and I’ll make the same objection. And if it calls for attorney/client privilege, any conversations you and I have had, do not answer the question. And I think that it might be appropriate, for the record, to ask questions via “Ms. as opposed to I think that would be more appropriate for this deposition. BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. A. Yes. Q. Thank you. In fact, you know that Mr. Herman held a press conference after he filed the fifty-million-dollar lawsuit on your behalf, don’t you? A. After it happened.

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sor & Associates Reporting and Transcription. lac.

Page 14
1You know that he had a press conference,
O.
2don’t you, yes or no?
3A.
Yes.
4Q.
In fact, let’s go to Exhibit 20-01.
5MR. GOLDBERGER: Look behind you.
You’ll
6see it.
7BY MR. TEIN:
8Q.
Have you ever seen that picture before?
9A.
Yes.
10Q.
Is that a picture of your father, your
11stepmother and Mr. Herman at the press conference
12regarding your lawsuit?
13A.
Yes.
14Now you know that this is a very serious
Q.
15matter, don’t you?
16MR. LEOPOLD: Asked and answered.
17Objection.
18MR. GOLDBERGER: All right.
You can
19object.
You’re representing a witness here,
20Mr. Leopold.
You can object on privilege grounds.
21You cannot make legal objections.
You have no
22standing to do so.
23MR. LEOPOLD:
I’m going to make them and
24then
25MR. GOLDBERGER:
We’re

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Page 15
1MR. LEOPOLD: We’re going to leave or we’re
2going to take a break, because his demeanor is not
3appropriate. There’s no reason to have this kind
4of demeanor.
If you want to have this kind of
5demeanor with me
6MR. TEIN:
You are obstructing this
7deposition.
8Why don’t you guys go
MR. GOLDBERGER:
9outside and just talk about
10MR. LEOPOLD: She her job is very
11difficult and she’s not going to be able to take
12us both talking at the same time.
13MR. GOLDBERGER: Off the record.
14MR. LEOPOLD: We’re not going off the
15record, Jack.
Her job is very
We’re not, Jack.
16difficult.
I’m going to make the record.
17I don’t think it is appropriate, especially
18in the small confines of this room, to be very
19aggressive with this young lady.
20MR. TEIN: That’s not happening. Stop,
21stop actually
22If you’re going to interrupt
MR. LEOPOLD:
23me, we’re going to cancel this deposition
24MR. TEIN: Stop misrepresenting.
25I need one at a time,
THE COURT REPORTER:

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sor & Associates Reporting ad Transcription. lac. Page 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 no matter who it is. MR. LEOPOLD: I think we’re going to take a break. Perhaps you might want to talk to your co-counsel — MR. TEIN: I don’t need to talk to him. MR. LEOPOLD: But we’re going to take a break. MR. TEIN: We’re not taking a break unless the witness needs a break. You’re obstructing this deposition, Ted. MR. LEOPOLD: Come on, You all want to continue in this demeanor — MR. TEIN: You’re obstructing the deposition. Stop making speeches. We’re not discussing this with you. The questions are to your client. Go take your five-minute break. MR. LEOPOLD: Fine. We need to make sure the record’s clear and clean. And I want to make sure, as I’ve already asked you — I know that you’re one of the best in town — that this audio — this needs to be preserved. Okay? MR. TEIN: Go take your five-minute break, Mr. Leopold, now.

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Page 17
1You were supposed to be here at nine a.m.;
2it’s now after two. Take your break and come
3back.
4MR. LEOPOLD:
Okay.
If the demeanor keeps
5up, we will not be here beyond those five minutes.
6MR. TEIN: Take your break and come back.
7MR. LEOPOLD: Okay. So I suggest that you
8relax.
9MR. TEIN: I suggest that you take your
10break.
11MR. GOLDBERGER: Let them take that
12five-minute break.
13MR. LEOPOLD:
But I would suggest that you
14take deep breaths.
15MR. TEIN:
Go
Suggest whatever you want.
16take a break.
17(Thereupon, a recess was taken.)
18BY MR. TEIN:
19you agree that giving testimony
Q.
20today at your deposition is something very serious, don’t
21you?
22A.
Yes.
23And you respect the court, don’t you?
Q.
24A.
Yes.
25Let me show you Exhibit 31-001. Can you
Q.

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sor & Associates Reportage ad Treaseripaioe, loc. Page 18 1 read that out loud, please. 2 A. Okay. What do you want? 3 Q. Will you read that out loud, please. 4 A. 5 Q. Thank you. 6 A. Lol hah my baddd…1O1 yah i got some 7 stupid court shit on the 20th…bullshit…and damn you 8 still have court shit with him? Like after so long wow 9 im sorry… well yah well we will definitely havta make 10 plans for sure..because i miss u tons times a million and 11 no no no i love you…o and p.s. i love ur default pic 12 niggaa. Muah xo. 13 Q. Did you send that message last week to a 14 friend of yours on MySpace? 15 A. I wouldn’t know. There’s no dates and I’ve 16 deleted that MySpace, so — 17 Q. We’re going to talk about that in a second. 18 A. Okay. 19 Q. Did you send that message last week 20 A. Right. 21 Q. Let me finish my question. 22 Did you send that message last week to a 23 friend of yours on MySpace? 24 A. I wouldn’t know the date, but obviously, 25 it’s to a friend.

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Page 19
1Did you send that message to a friend of
Q.
2yours on MySpace?
3A.
Sure, yes.
4Q.
Were you referring to this deposition?
5A.
Yes.
6Q.
Do you find the term n-i-g-g-e-r offensive?
7A.
That’s not anywhere in there.
8What word did you use in there?
Q.
9MR. LEOPOLD:
Where are you referring to,
10Counsel? There’s 20 plus words in there.
11MR. TEIN:
Don’t make a speaking objection.
12THE WITNESS:
Are you referring to
13anything
14Don’t don’t -
MR. LEOPOLD:
No,
15let him ask you the question.
16BY MR. TEIN:
17What question were you asking,
Q.
18MR. LEOPOLD: She doesn’t ask questions.
19You ask the questions.
What is the question
20pending?
21BY MR. TEIN:
22what is the last word on there in
Q.
23the text of your message before the closing?
24A.
Niggaa.
25Don’t you find that term offensive?
Q.

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Reporting and Transcripcico. Inc

Page 21
1BY MR. TEIN:
2Let me ask you, M.
Q.
did you in fact
3write your friend this message about this deposition?
4A.
Yes.
50.
So you wrote your friend that this
6deposition is stupid court s-h-i-t, correct?
7Yes.
A.
8Q.Because you think this deposition is stupid
9court s-h-i-t, don’t you?
10A.
No.
11Q.You wrote that to your friend, didn’t you?
12A.
Yes.
13Q.You think that court is stupid, don’t you?
14In some cases.
A.
15Q.And you think that court is bull s-h-i-t,
16don’t you?
17A.
No.
18Q.And you think this deposition is bull
19s-h-i-t, don’t
you?
20A.
No.
21Q.You wrote that to your friend, didn’t you?
22MR. LEOPOLD:Objection.
Asked and
23answered.
24MR. TEIN: That’s not an objection.
25BY MR. TEIN:

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07’2617 Page 2696 Public Records Request No 17-295

Page 22 1 Q. You wrote that to your friend, didn’t you? MR. LEOPOLD: Objection. Asked and answered, for the fourth time. MR. TEIN: You are improperly objecting, Mr. Leopold. You have no grounds to object. And that’s not an objection. MR. LEOPOLD: It is an objection. MR. TEIN: Then terminate the deposition if you think it’s been asked and answered. 10 MR. LEOPOLD: Counsel, I am not precluded from just making an objection to the form of the question. As the courts well know, and if you practice here in West Palm Beach, many of the judges require you to set the objection with specificity. And I will do that. And if you don’t want me to, you can make the record. But I will do that. MR. TEIN: Here’s what we’ll do, Ted. You can — I will allow you to reserve an objection to form for every single one of my questions. Otherwise, all you’re doing is obstructing. MR. LEOPOLD: I won’t do that. MR. TEIN: Of course; because you want to obstruct. MR. LEOPOLD: All right.

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nsor & Associates

*Reporting and Tian SaiptICO. Inc

Page 23
1BY MR. TEIN:
2you think that giving testimony
Q.
3today, under oath, is bull s-h-i-t, don’t you?
4No.
A.
5And you wrote that to your friend on
Q.
6MySpace last week, didn’t you?
7MR. LEOPOLD:
Objection.
Asked and
8answered.
9THE WITNESS:
No, I did not.
10BY MR. TEIN:
11Q.
You didn’t write this exhibit?
12A.
I wrote that, but I didn’t write what you
13said.
14You wrote in this exhibit, “I got some
Q.
15stupid court s-h-i-t on the 20th.
Bull s-h-i-t.” Didn’t
16you write that?
17Yes.
A.
18Q.
Referring to this deposition, didn’t you?
19Referring to the court.
I was later
A.
20informed that it was a deposition.
21Q.
I’m going to ask you some questions now
22about what happened when you went to Jeff Epstein’s house
23three years ago.
Okay?
24A.
Uh-huh.
25When the police interviewed you one month
Q.

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07.26,17 Page 2698 Poetic Records Request No 17-295

Page 24 1 after you went to Epstein’s house, you swore on your 2 mother’s grave that you and Epstein did not engage in sex 3 of any kind? 4 A. Yes. 5 Q. Didn’t you tell that to the police? 6 A. Yes. And I will continue. I have never 7 had sex with him. 8 Q. Did what happened upstairs at Jeff 9 Epstein’s house take you completely by surprise, 10 A. Yes. 11 Q. Now the civil complaint that you filed 12 against Mr. Epstein for fifty million dollars alleged 13 that you were totally shocked by what happened when you 14 got there. 15 A. Yes. 16 Q. Were you totally shocked by what happened 17 when you got to Epstein’s house? 18 A. Yes. 19 Q. You didn’t expect it at all, did you? 20 A. No. 21 Q. You had absolutely no idea why your friend 22 Hayley was taking you to Epstein’s house, right? 23 A. I was informed it was a massage. 24 Q. All you thought that it was going to be was 25 a massage, correct?

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Page 25
A.
Yes.
Q.
Before you got to Epstein’s house Bayley
3never said anything to you on the telephone about sexual
4activity with Epstein, did she?
5A.
No.
6Q.
And before you got to Epstein’s house
7Bayley never sent you a message over the Internet about
8sexual activity with Epstein, did she?
9A.
No.
10Did Zack Bryan ever try to convince you to
Q.
11engage in any sexual activity with Epstein?
12A.
No.
13Q.
every try to convince
Did Anthony
14you to engage in any sexual activity with Epstein?
15A.
I don’t know who Anthony
is.
16Q.
Do you have a friend Anthony?
17A.
No.
18Before you went so Epstein’s house
Q.
Okay.
19did anyone call or e-mail you to induce you to engage in
20sexual activity with Epstein?
21A.
No.
22Q.
So you’re sure that before you got to
23Epstein’s house no one tried to persuade you to engage in
24sexual activity with Jeffrey Epstein?
25No.
A.

07:26,17 Page 2700 Pubic Records Request No 17-295

Page 26
1You’re sure that let me ask the question
Q.
2again.
3You’re sure that before you got to
4Epstein’s house no one tried to persuade you to engage in
5sexual activity with Epstein for money.
Are you?
6MR. LEOPOLD:
Objection.
Asked and
7answered.
8THE WITNESS:
No. And I’ve already
9answered that a bazillion times.
10BY MR. TEIN:
11He’s coaching you now. So I’m going to ask
Q.
12the question
13MR. LEOPOLD: Counsel, I’ve made an
14objection for the record.
15MR. TEIN: Stop speaking.
16MR. LEOPOLD:
I’m not going to stop
17speaking.
You can’t interrupt me when I’m making
18the record.
19MR. TEIN:
You’re coaching the witness.
20Counsel
MR. LEOPOLD:
21MR. TEIN:
Stop coaching the witness.
22BY MR. TEIN:
23let
Q.
me ask you
24If you continue to
MR. LEOPOLD:
25MR. TEIN:
Stop interrupting my questions.

07x26,17 Page 2701 Public Records Request No.: 17-295

Page 27 1 MR. LEOPOLD: If you do it one more time, we’re leaving. BY MR. TEIN: Q. MR. LEOPOLD: I’m going to make the record. You cannot interrupt me when I’m making the record. Out of professional conduct, you cannot do that. I’m entitled to make the record. I made an objection, asked and answered. Your demeanor 10 is inappropriate. You’re willing and you are able 11 and you’re responsible to ask a question in a professional manner, and ask the question and once you get the answer, to either follow up on it or move on, but not continuously browbeat and ask the same question over and over because you don’t like the answer. MR. TEIN: Calm down, sir. MR. LEOPOLD: Trust me, I’m very calm here. When I’m not calm, you’ll know it. I’m very calm. 20 So please continue on. But I will not allow you to continue to harass her in the demeanor that you’re doing. Ask her a question and move on. MR. TEIN: Are you done? MR. LEOPOLD: Thank you. I am.

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* nsor & Associates Rcronang and Mtn scription. Inc

Page 28
1MR. TEIN: Stop misrepresenting the record
2and calm down. I’m going to ask my question.
3Stop it.
4BY MR. TEIN:
5Q.
6I think the record is very
MR. LEOPOLD:
7clear.
8MR. GOLDBERGER: Let me just clarify
9When you object to the form of a
something.
10question, you’re not instructing the witness not
11to answer the question, are you?
12And I’m not making that
MR. LEOPOLD:
No.
13objection; only on attorney/client privilege.
14MR. TEIN: Will you stop speaking now so I
15can ask my question? Are you done?
16I’m going to ask my question.
Okay.
17BY MR. TEIN:
18Q.
Listen,
19Hold on. Stop.
MR. LEOPOLD:
20I’ve been doing this for 20 plus years and
21have met a lot of attorneys, but I’ve never had an
22experience like this where I’ve
23MR. TEIN: Stop your speeches.
24If you continue to do this,
MR. LEOPOLD:
25whether it’s with me or with my client, I will not

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07,2617 Page 2703 Pub!a: Records Request No_ 17-295

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 29 put up with it and I don’t need to put up with it and it’s not appropriate. And I’m sure Mr. Goldberger knows all this, because I know that he wouldn’t do this. So I will not put up with it. And I think it’s highly inappropriate to do this with this child sitting here, the way you’re acting, primarily towards me, and I will not put up with it. MR. TEIN: Will you please stop your speech so I can ask questions? MR. LEOPOLD: So long as you act professionally, I will do so. But if you continue to do it this way, I will leave. MR. TEIN: Suit yourself. BY MR. TEIN: Q. are you sure that before you got to Epstein’s house no one tried to persuade you to engage in sexual activity with Epstein for money? MR. LEOPOLD: Asked and answered. Objection. MR. TEIN: Did you get her answer? THE COURT REPORTER: No, I did not. THE WITNESS: I’m sure. BY MR. TEIN: 0. Let me ask you a few question:: about your.

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07)2617 Page 2704 Public Records Request No_ 17-295

Page 3C 1 contact with Jeffrey Epstein. Okay? 2 A. (Witness nods head up and down.) 3 Q. Jeff never e-mailed you, did he? 4 A. No. 5 Q. Jeff never text messaged you, did he? 6 A. No. 7 Q. Jeff never chatted in a chat room with you, 8 did he? 9 A. No. 10 Q. Before you got to Epstein’s house you had 11 never spoken to Jeff, had you? 12 A. No. 13 Q. And before you got to Epstein’s house you 14 had never met Jeff? 15 A. Correct. 16 Q. Before you got to Epstein’s house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 Q. Before you got to Epstein’s house had you 20 ever told Jeffrey that you were under 18? 21 A. No. I never spoke to the man before that. 22 Q. And you only went to Jeff Epstein’s house 23 that one time three years ago, correct? 24 A. Yes. 25 O. You never went there again, correct?

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Page 31 1 A. No. 2 Q. All right. Let me ask you two final areas 3 of questioning about this and we’ll move onto something 4 else. Okay? 5 A. Uh-huh. Yes. I’m sorry. 6 Q. Before you got to Epstein’s did anyone 7 associated with Epstein ever call you on the phone and 8 try to persuade, induce, entice or coerce you to engage 9 in any sexual activity? 10 A. No. 11 Q. Before you got to Epstein’s did anybody 12 associated with Epstein ever contact you on the Internet 13 and try to persuade, induce, entice or coerce you to 14 engage in any sexual activity? 15 A. No. 16 Q. who told you that when you got to 17 Jeff Epstein’s house you should lie to Jeff about your 18 age? 19 A. 20 Q. Was it Hayley or was it the other girl in 21 the car who you rode over with to Epstein’s house? 22 A. 23 Q. Who was the other girl in the car with you 24 that day? 25 A. I honestly don’t know.

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Page 32
1Q.
Had you ever seen her before?
2A.
No, sir.
3Q.
You told the police that when you rode over
4to Epstein’s you had no idea who she was, right?
5A.
Correct.
6Q.
You told the police that you didn’t know
7her name, but she was like really dark, kind of like a
8Spanish girl?
9A.
Yes.
10Q.
Those were your words, right?
11A.
Yes.
12Q.
Do you now know who she is?
13A.
No, sir.
14Q.
So it was
who told you to lie about
15your age to Jeff Epstein?
16A.
Yes, sir.
17Am
old you that if you weren’t 18,
Q.
18Epstein wouldn’t let you into his house, right?
19A.
That’s yes, yes.
20Q.
All right.
Let’s talk for a minute about
21when you first met Jeff. Okay?
22A.
Sure.
23Q.
When you first met Jeff he tried to find
24out how old you were, right?
25A.
Excuse me?

07 26,17 Page 2707 Public Records Request No.: 17-295

. Itoponing sad Traaraiptios, Inc. sor & Associates

Page 33
1When you first met Jeff he tried to find
Q.
2out how old you were, right?
3A.
Not when we first introduced each other;
4when we get upstairs, then, yes.
5During the massage Jeff asked you how old
Q.
6you were, correct?
7A.
Yes, yes.
8Now hadn’t you already told Jeff’s
Q.
9assistant, the one who walked you upstairs, that you went
10to college and had just moved down here from Ohio?
11A.
I never spoke to the lady.
12Q.
Do you want to rethink that answer?
13MR. LEOPOLD:
Is that a question?
14BY MR. TEIN:
15Do you want to rethink that answer?
Q.
16A.
I didn’t really speak with her that
No.
17much.
18Do you want to try to refresh your memory
Q.
19on that?
20Do you have something to
MR. LEOPOLD:
21refresh her memory with?
22MR. TEIN:
Do you want to stop making
23speaking objections?
24MR. LEOPOLD:
But to refresh someone’s
No.
25memory, you show them a document.

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Page 34
1MR. TEIN: I know how to do this.
2MR. LEOPOLD: Then show her a document.
3MR. TEIN: Stop speaking.
4MR. LEOPOLD:
I’m not going to stop
5speaking.
I’m going to continue to make the
6record.
7MR. TEIN: You’re obstructing.
tquaae
8stop.
9But if
MR. LEOPOLD:
I’m not obstructing.
10you want to refresh her recollection, you need to
11show her something.
12I object to
That’s not a proper question.
13the foundation and the predicate of that question.
14MR. TEIN:
Are you done?
15MR. LEOPOLD: I am now. Thank you.
16BY MR. TEIN:
17Q.
Do you want to try to refresh your memory
18as to whether you had any conversation with the woman who
19walked you upstairs in Epstein’s house in which you told
20her that you went to college and had just moved down from
21Ohio?
22MR. LEOPOLD: Objection. Object to the
23form of the question.
Lack of foundation and
24predicate.
25BY MR. TEIN:

07:2617 Page 2709 Public Records Request No.: 17-295

Page 35
1Q.
You can answer the question.
2A.
Sure.
3Q.
Is there anything that would refresh your
4memory that in fact you told Mr. Epstein’s assistant, the
5one who walked you upstairs, that you went to college and
6you had just moved down here from Ohio?
7A.
I don’t remember saying that, but if you
8I don’t remember saying that myself, so
9Q.
That would be a lie, right?
10A.
No.
I really don’t remember.
11So you told Jeff that you were 18 years
Q.
12old, correct?
13A.
Yes.
14Q.
Do you remember Detective
Pagan of
15the Police Department, Palm Beach Police Department?
16A.
Yes.
17Q.
Do you remember you spoke to her?
18A.
Yes.
19Q.
Do you remember that you told Detective
20Pagan that when you lied about your age to Jeff you said
21it really fast because you didn’t want to make it sound
22like you were lying?
23A.
I don’t remember the words exactly, but I
24do remember telling her I told him I was 18.
25Q.
And do you remember telling Detective Pagan

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07,2617 Page 2710 Public Records Request No.: 17-295

1

Page 36 1 that when you lied to Epstein about your age that you 2 said it really fast so Epstein wouldn’t realize you were 3 lying? 4 A. No, I don’t remember saying those words 5 exactly to her. I remember telling her that I told 6 Epstein I was 18. 7 Q. Does it sound right to you that you told 8 Detective Pagan that you said your age really fast to 9 Epstein — 10 MS. BELOHLAVEK: Objection. Asked and 11 answered. 12 BY MR. TEIN: 13 Q. — so he wouldn’t think that you were 14 lying? 15 MR. LEOPOLD: Objection. Asked and 16 answered, lack of foundation, mischaracterization 17 of her earlier testimony. She’s already answered 18 that question. 19 BY MR. TEIN: 20 Q. You can answer it. 21 MR. LEOPOLD: Same objection. It’s been 22 asked and answered. 23 You can answer. I’ve made the objection. 24 THE WITNESS: I forget the question, now. 25

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0726,17 Page 2711 Public Records Request No.: 17-295

Page 37
1BY MR. TEIN:
2Let me put it again.
Q.
3Does it sound right to you that you told
4Detective Pagan that when you lied about your age to
5Jeffrey Epstein, you said it really fast because you
6didn’t want to make it sound like you were lying?
7MR. LEOPOLD:
Objection.
Lack of
8foundation, asked and answered.
9THE WITNESS:
I could have possibly said
10that, yes.
11BY MR. TEIN:
12Q.
You didn’t want Mr. Epstein to know that
13you were lying about your age, right?
14A.
Correct.
15Q.
You didn’t want Mr. Epstein to know that
16you were not 18 yet, right?
17A.
Correct.
18You wanted Mr. Epstein to believe that you
Q.
19really were 18, right?
20A.
Correct.
210.
Do you remember when Mr. Epstein asked
22where you went to school?
23A.
Yes.
24Q.
And you told Mr. Epstein you went to
25Wellington, right?

0/ 26 17 Page 2712 Public Records Request No.. 17-295

sor & Associates Reportingad Tranicripan. lac Page 38 1 2 3 4 5 6 7 8 A. Yes. Q. Was that the truth? A. No. Q. In fact, you went to right? A. Yes. Q. So you lied to Mr. Epstein again, correct? A. Yes. Q. Is Wellington the college that you told 9 Jeff’s assistant that you were attending? 10 A. I don’t remember having that conversation 11 with her, so I wouldn’t know if that’s what I said. 12 Q. That was a lie, though, wasn’t it? 13 MR. LEOPOLD: Objection to the form of the 14 question, lack of foundation. You’re making an 15 16 17 18 19 20 21 22 23 24 25 assumption. She just answered you she can’t tell you that. MR. TEIN: Speaking objection. And you well know that, Mr. Leopold. MR. LEOPOLD: She can’t answer that question. The way you phrased that question, you’re purposely making her not be honest in her testimony. She can’t answer a question like that. She doesn’t remember. So then you say, “So you were lying.” That’s improper and you know that. That’s not a proper question. And any attorney

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07126117 Page 2713 Public Records Request No.: 17-295

Page 3
,
1that would do that to a witnesses or to a person
2that’s sitting in this chair is not acting
3You can’t ask a question like
professionally.
4that.
You can do it, but it’s not proper.
And
5I’m sure you weren’t trained that way, certainly
6not ethically.
7MR. TEIN:
Will you stop?
8MR. LEOPOLD: I’m not going to stop,
9because the way you’re asking that question is
10improper and you know it.
11MR. TEIN:
You’re losing your cool.
12BY MR. TEIN:
13Q.
14MR. LEOPOLD:
Trust me.
I’m very calm.
15When I lose my cool, you’ll know it.
16MR. TEIN:
I do know it.
17BY MR. TEIN:
18Q.
Mr. Epstein never asked you
19to do anything other than massage him, correct?
20A.
Incorrect; because he asked me to take off
21my bra, so that would be two things he’s asked me to do.
22Q.
Other than asking you to take your bra off,
23Mr. Epstein never asked you to do anything with him other
24than massage, correct?
25Foundation,
MR. LEOPOLD: Objection.

07 26 17 Page 2714 Public Records Request No.: 17-295

*Rerornne and Transcornca. Inc nsor & Associates Page 40 1 predicate. 2 THE WITNESS: Correct. 3 BY MR. TEIN: 4 Q. You told the police, in your words, that 5 you did not whack him off, right? 6 A. Correct. 7 Q. What does that mean? 8 A. Whack, like whacking off? 9 Q. Your term, what does that mean? 10 A. Masturbating. 11 Q. Mr. Epstein never tried at any time to grab 12 your hand, did he? 13 A. No. 14 Q. Mr. Epstein never tried to put your hand 15 anywhere, did he? 16 A. 17 Q. 18 penis, did 19 A. 20 Q. 21 A. 22 4. 23 he touch me.” Were you lying to the police then? 24 A. No. Well, I wasn’t being fully truthful, 25 but I wasn’t lying. No. At no time did you touch Mr. Epstein’s you? No. And he did not touch you, correct? Incorrect. Well, you told the police, “At no time did

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Page 41
1You told the police twice when you spoke to
O.
2that “at no time did he touch me.” Didn’t
3you say that to the police?
4A.
Yeah.
5And you’re saying that that was not fully
Q.
6truthful.
Is that what you’re saying now?
7A.
Correct.
8Q.
And you’re saying if you’re not fully
9truthful, that’s not a lie. Correct?
10You took that out of context like really
A.
11Touching my legs and
bad.
I didn’t mean like that.
12he never kept his hands to himself the entire time.
13That’s what I’m trying to say.
14Q.
You told the police, “At no times did he
15touch me.” You agree with that, correct?
16A.
No, I don’t agree with that, because he did
17touch me.
18Did you tell the police that he did not
Q.
19touch you, yes or no?
20A.
It’s a possibility, but I do not remember.
21And you did not have any type of sex
Okay.
Q.
22with Jeff, correct?
23A.
No.
24And you did not have any type of oral sex
Q.
25with Jeff, correct?

07.26,17 Page 2716 Pubic Records Request No 17-295

Page 42
1A.
No.
2Q.
No type of intercourse with Jeff, correct?
3A.
Correct.
4Q.
All right.
Let’s talk about what happened
5after the massage was over.
6A.
Okay.
7Q.
After the massage, you told Epstein that
8you wanted to bring your twin sister back so she could
9make some money, correct?
10A.
Incorrect.
11Q.
Your twin sister is
right?
12A.
Correct.
13Q.
And you love
very much, don’t you?
14A.
Yes.
15Q.
And when you left the house you were joking
16with the other girls, weren’t you?
17A.
Incorrect.
18Q.
Well, when Hayley and the other girl in the
19car that day made their statements to the police they
20told the police that you were joking afterwards.
Are you
21saying that they were lying to the police about that?
22A.
But a question or questions from
No.
23Hayley like she asked me questions, but it wasn’t
24joking. She was kind of like in a happy way, like,
25what did you do?
What did you do?” Like those kind of

07/28/17 Page 2717 Public Records Request No.: 17-295

Pdqu 4 3
1things, but
it wasn’t joking about it at all.
2Q.
You joked about it, didn’t you?
3A.
No.
4Q.
You said to
that if you did this
5every weekend you’d be rich, didn’t you?
6That’s
A.
No.
told me.
what
7You didn’t tell that to
Q.
8Objection.
Asked and
MR. LEOPOLD:
9answered.
10THE WITNESS:
No.
11BY MR. TEIN:
12After you left Epstein’s house you took the
Q.
13nd the other
money and you went shopping with
14girl in the car, correct?
15I didn’t spend any of the
A.
Incorrect.
16money.
17Q.
You went to Marshall’s, didn’t you?
18I went along, yes, but I didn’t
A.
19You went shopping with them at Marshall’s,
Q.
20didn’t you?
21MR. LEOPOLD:
Objection.
22I guess you could say that.
THE WITNESS:
23Objection. Lack of predicate
MR. LEOPOLD:
24Mischaracterization of earlier
and foundation.
25testimony.

07’26 17 Page 2718 Pubic Records Request No 17295

Page 44
1BY MR. TEIN:
2Q.
And Bayley bought a purse, right?
3A.
Yes.
4Q.
And you were with her the whole time at
5Marshall’s, correct?
6A.
Yes.
7Q.
Now tell me about when the federal
8prosecutors told you about getting reimbursed.
9A.
I have no idea what you’re talking about.
10Q.
Tell me about when the federal prosecutors
11spoke to you about getting money you feel you’re entitled
12to from Mr. Epstein.
13A.
I don’t know what you’re talking about.
14Do you know who
Q.
is?
15A.
No, sir.
16Did you ever meet with any federal
Q•
17prosecutors?
18A.
I think yeah.
I think they were
19think they were like FBI.
20Uh-huh.
Did you meet with federal
Q.
21prosecutors?
22A.
They came to my house one time, yes.
23Q.
When did they come to your house?
24A.
Very long ago.
25Q.
Was it this year, 2008?

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Page 45
1A.It was not this year, no.
2Q.Was it 2007?
3A.I’d have to say at least two years ago or a
4year ago, yeah.So it would be 2007, 2006; but it was a
Swhile ago.
6Q.How many federal prosecutors or FBI agents
7came to your house?
8A.I’m trying to remember.
I want to say four
9people came.
10Q.Did they give you their business cards?
11A.If they did, I don’t remember, and they
12weren’t toward me.Maybe my parents have them.
I don’t
13know.
14Q.Did they give you their cell phone numbers?
15A.No.
16Q.Did you ever speak to them on their cell
17phones?
18A.No, sir.
19Q.Did they speak to your parents?
20A.That’s something you’d have to ask my
21parents.
22Q.Do you know whether they spoke to your
23parent’s?
24A.No, sir.
25Q.You have no idea?

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Page 46
1A.
No, sir.
2MR. LEOPOLD:
Objection.
Asked and
3answered.
4BY MR. TEIN:
5Q.
So if I say the name to you
6Villafona, you don’t know who that is?
7A.
No, sir.
8Q.
How many women and how many men came to
9your house?
10A.
I want to say two ladies and two guys.
11Q.
Did someone named Jeffrey Sloman come to
12your house?
13A.
I don’t know names, sir.
14Q.
Do you know who Jeffrey Sloman is?
15No, sir.
A.
16Do you know who Jeffrey Herman is?
Q.
17A.
Yes.
18That’s the lawyer who first sued Epstein on
Q.
19your behalf, right?
20A.
Yes.
21Q.
Has Mr. Herman advanced your family any
22money?
23MR. LEOPOLD:
Any conversations that you’ve
24had with Mr. Herman regarding that issue, you are
25not to disclose.
If you’ve learned in some other

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Page 47
1fashion, you may answer.
2THE WITNESS:
Okay.
3I wouldn’t know.
4BY MR. TEIN:
5Q.
You don’t know?
6A.
No.
7MR. LEOPOLD:
Objection.
Foundation.
8Attorney/client privilege.
9BY MR. TEIN:
10Q.
And you say you don’t know who Jeff Sloman
11is?
12A.
No, sir.
13Does it refresh your recollection that he’s
Q.
14the number two prosecutor at the U.S. Attorney’s Office?
15A.
No.
16That he’s
boss?
Q.
17A.
No.
18Does it refresh your memory that he’s the
Q.
19ex-partner of Jeff Herman, the first lawyer who sued
20you sued Mr. Epstein on your behalf for fifty million
21dollars?
22A.
No, sir.
I don’t know who he is.
23Q.
Without telling me any conversations that
24you’ve had with your lawyers, how is it that you selected
25Mr. Herman as your lawyer from the 81,000 members of the

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Reponas ad Tnescriptieo, lac.

Page
1Florida Bar?
2A.I did not select him.
3Q.Who did?
4A.My father.
5Q.Did you ever meet Mr. Herman?
6A.Once.
7Q.Don’t don’t tell me what you discussed
8with him.Where did you meet him?
9A.I was shopping in my he showed up at my
10friend’s house.
11Q.Whose house?
12A.My friend
13Q.Is that
from the Quarterdeck
14Tavern?
15A.Yes.
16Q.And did you have a meeting with him at
17ouse?
18A.Yes.
I guess you could say that.
19Q.And who else was there?
20A.My Aunt
21Q.And what was that meeting about?
22MR. LEOPOLD: Objection. That calls for
23attorney/client privilege.
24BY MR. TEIN:
25Q.What discussions did you have with

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Page 49 1 Mr. Herman in the presence of Tiffany Rich? 2 A. None. 3 Q. What discussions did you have in the 4 presence of her aunt? 5 A. Of my aunt? 6 MR. GOLDBERGER: It’s the witness’s aunt. 7 BY MR. TEIN: 8 Q. II, of your aunt. 9 A. The only one that we’ve ever discussed or 10 ever had. 11 Q. And so you were in a conversation with 12 Mr. Herman and your aunt? 13 A. Yes, sir. 14 Q. And you discussed privileged matters during 15 that conversation? 16 MR. LEOPOLD: Object to the form. I think 17 you might have to educate her on that question. 18 BY MR. TEIN: 19 Q. You discussed the lawsuit? 20 A. Yes. 21 Q. Did Tiffany Rich tell you about any 22 conversations that she had with Mr. Herman? 23 A. As far as I’m concerned, she’s never spoken 24 or she’s never had a conversation. She only opened the 25 door and then left. She’s the one who answered the door.

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Page 50
1why did the meeting take place at Tiffany
Q.
2Rich’s house?
3I spent the night that night at her house.
A.
4Q.
And when was this?
5A while ago.
A.
6Q.
How long ago?
7A.
A month and a half ago.
I’m guessing.
8Q.
A month and a half ago?
9A.
Uh-huh.
10So was it before of after Mr. Herman file°
Q.
11the fifty-million-dollar lawsuit against Epstein?
12A.
After.
13Q.
Did you meet with an FBI agent named
14Nesbitt Kurkendall, a woman?
15I don’t know.
A.
16speak to you about
Q.
Did
17getting reimbursed from Mr. Epstein?
18I’ve never had a discussion with anyone
A.
19about getting reimbursed from Mr. Epstein.
20Have you met with an agent named Jason
Q.
21Richards?
22Not to my knowledge.
A.
2 3How about an agent named Tim Slater?
O.
24No, sir.
A.
25How about an agent named Junior Ortiz?
O.

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Page 51
1A.
No.
2And we’ve learned that many of the girls,
Q.
3some of whom are as old as 23, were told by the
4government that they would get money at the end of the
5Does that sound familiar to you?
criminal prosecution.
6A.
No, sir.
7Other than Mr. Leopold here I’m not
Q.
8asking about Mr. Herman either
9A.
Uh-huh.
10did anyone ever discuss with you that
Q.
11you could get reimbursement for your damages?
12No, sir.
A.
13Did you or any member
Q.
14MR. LEOPOLD: Are you referring to a
15criminal matter or a civil matter?
16BY MR. TEIN:
17Did you or any member
Q.
18Let me object to
MR. LEOPOLD:
Excuse me.
19the form of the question.
20BY MR. TEIN:
21Did you or any member of your family ever
Q.
22get a victim notification letter from anyone?
23I no longer live at that residence and I
A.
24wouldn’t know.
25Q.
So your testimony is that you have never

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Page 52
1received a victim notification letter, correct?
2A.
Correct.
3Q.
And your testimony is that you don’t know
4if your parents have ever received a victim notification
5letter, correct?
6A.
Correct.
7Q.
Have you given any evidence to prosecutors
8or law enforcement in this case?
9What do you mean by evidence?
A.
10Anything that you can touch or feel.
Q.
Well.
11A.
No.
12Objection to the form of the
MR. LEOPOLD:
13question.
14BY MR. TEIN:
15Q.
So you haven’t given anything physical -
16A.
No.
17Q.
any item to any prosecutor, police
18officer or law enforcement agent, correct?
19My cell phone four years ago or three years
A.
20ago, but that’s it.
21Q.
You gave your cell phone to whom?
22A.
23Q.
Did she keep it?
24A.
Ask her.
25Q.
You gave it to her and then you didn’t get

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Page 53 1 it back at the end of the meeting? 2 A. No. They — yeah. No. They have it. I’m 3 guessing. I don’t have it. 4 Q. How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7 question. Attorney/client privilege. 8 BY MR. TEIN: 9 Q. How much money are you hoping to get, you, 10 yourself, hoping to get out of Epstein? 11 MR. LEOPOLD: Same. Same objection, 12 attorney/client privilege. 13 Don’t answer the question. 14 BY MR. TEIN: 15 Q. I’m not asking about what your lawyer told 16 you. 17 MR. LEOPOLD: I’m instructing her not to 18 answer the question, because any of those 19 conversations involve her counsel. 20 MR. TEIN: Certify that. 21 MR. LEOPOLD: Please. 22 CERTIFIED QUESTION 23 BY MR. TEIN: 24 Q. Now, you lied to get out of this 25 deposition, didn’t you? Ph. 561.682.0905 - Fax. 561.682.1771

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Page 54 1 A. No, sir. 2 Q. You didn’t want to come to court today and 3 tell the story that you had told to the police under 4 oath, did you? 5 MR. LEOPOLD: Object to the form of the 6 question. Lack of foundation, predicate. 7 THE WITNESS: No. I have no problem coming 8 here and talking to you. 9 BY MR. TEIN: 10 Q. And to avoid getting served with a lawful 11 subpoena, you lied about your name, didn’t you? 12 A. No. 13 Q. And in fact, just lying yourself wasn’t 14 enough, was it? 15 MR. LEOPOLD: Objection to the form of the 16 question. 17 Don’t answer it. It’s not a question. 18 Object to the form of the question. Lack 19 of foundation. 20 MR. TEIN: Are you instructing her not to 21 answer? 22 MR. LEOPOLD: I am. 23 MR. TEIN: Certify it. 24 MR. LEOPOLD: Please. 25

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Page 55
1CERTIFIED QUESTION
2BY MR. TEIN:
3You asked your co-workers
Q.
4MR. LEOPOLD:
It’s vague and ambiguous.
5BY MR. TEIN:
6You asked your co-workers at the
Q.
7Quarterdeck Tavern to lie for you, didn’t you?
8A.
I informed my boss about what was
No.
9going on and he told me that he would help in any way
10that he can.
11Q.
Okay.
You got your
lie
12by switching name tags with you, correct?
13A.
Incorrect. It was a coincidence that same
14night she was not wearing her name tag; she was wearing
15But I was also not wearing I was wearing my
mine.
16It just so
name tag.
Everyone switches name tags.
17happens it was a coincidence that same night the people
18came with the papers.
19Will you put up Exhibit 18-001?
MR. TEIN:
20MR. GOLDBERGER:
And mark 18-001 for
21identification purposes to this deposition.
22None of them have been marked
MR. LEOPOLD:
23Can we mark them and put them as attachment
yet.
24to the depositions? Because I think you’ve shown
25three photos now. And this is the only one that

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Page 56
1has been marked for identification yet.
2BY MR. TEIN:
3Q.
4MR. LEOPOLD: Hold on just a second.
Just
5so the record is clear
6MR. TEIN:
I’m not speaking to you.
7MR. LEOPOLD: Okay.
Then don’t speak to me
8then.
But I’ll speak to Mr. Goldberger, perhaps.
9But at least for the record, can we put on
10the record what the previous two photographs were
11marked for identification?
12MR. GOLDBERGER:
We will make sure that the
13record is clear at the end of the deposition so
14that there’s no ambiguity.
15MR. LEOPOLD:
Thank you.
16BY MR. TEIN:
17I’ve put a photograph marked 18-001
Q.
18up on the screen.
Do you see that?
19A.
Yup.
20Who is that in the photo?
Q.
21Tiffany on the left and me on the right.
A.
22Q.
Tiffany Rich, right?
23A.
Yes.
24Tiffany Rich, your friend at the
Q.
25Quarterdeck Tavern, right?

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Page 57
A.
Yes.
2Tiffany, your friend, who you say the day
Q.
3that the process servers went to serve you with a
4subpoena for this deposition, just happened just by
5coincidence, was wearing your name tag?
6Yes, sir.
A.
7And just by coincidence, you were wearing
Q.
8her name tag, correct?
9A.
Yes.
10Your testimony under oath is that’s just a
Q.
11coincidence, right?
12A.
Total honesty.
13It just happens to be the day that you were
Q.
14going to be served with a subpoena, correct?
15That wasn’t the first day that
A.
16MR. LEOPOLD:
just answer the
17It calls for a yes or no.
question.
18THE WITNESS:
Yes.
19BY MR. TEIN:
20You said that wasn’t the first day you were
Q.
21going to be you thought you were being served with a
22subpoena, correct?
23Correct.
A.
24You knew before the day that you switched
Q.
25name tags with Tiffany that the process servers were

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sor & Associates Reporting sad Transcription. Inc. Page 58 1 looking for you, didn’t you? 2 A. No. I knew — 3 MR. LEOPOLD: Just answer it. It calls for 4 a yes or no. 5 THE WITNESS: Okay. No. 6 BY MR. TEIN: 7 Q. Now you can explain the answer that your 8 counsel stopped you from explaining.

9 A. Okay. I work at Quarterdeck and people 10 were telling me that people were looking for me. So yes, 11 I was aware that people were searching for me. But I had 12 no idea who they were or what their intentions were. But 13 I thought they were just people I didn’t want to talk to. 14 So I just didn’t want to talk to them. And every time 15 they’d come to work I wasn’t there. And so happens the 16 night that they came in me and my friend switched name 17 tags. No big deal. 18 Q. That’s a lie, isn’t it?

19 MR. LEOPOLD: Objection. Don’t answer that 20 question. That’s harassment and I will not allow 21 it. He could ask the questions and we’ll allow a 22 jury to make that determination, but not counsel. 23 I will not allow her to answer that 24 question. 25 MR. TEIN: Certify it.

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1 MR. LEOPOLD: I’ll certify it. CERTIFIED QUESTION She’s answered that question. She’s explained it five 4 times already. The fact that Counsel doesn’t like the answer, that’s a different query. MR. TEIN: Stop making speaking objections. 7 MR. LEOPOLD: I’m not. I’m not going to put up with it, because it’s in appropriate, Jack, 9 and you know it. I will not allow Counsel to berate a witness, whether it’s in a criminal case 11 or a civil case, whether my client or MR. TEIN: Calm down. MR. LEOPOLD: Excuse me. No, I’m not going to allow it. That is not 15 proper. MR. GOLDBERGER: Okay. 17 MR. LEOPOLD: If he wants to say that she’s lying after asking it five times and her explaining in great detail, he can do that. But I’m not going to allow her to answer, nor be harassed by him. It’s improper. MR. GOLDBERGER: Okay. But your response that Counsel doesn’t like the question — or doesn’t like the answer — just let me finish. MR. LEOPOLD: Absolutely. I wasn’t going

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Page 59

4SiknReporting and transcription, lac 1 2 3 Page 60 to interrupt you. MR. GOLDBERGER: Just requires us to say we like the answer to that question. And it’s not 4 you and I or you and Mr. Tein who are testifying 5 6 7 time of asking the same question and then coming 8 back and pointing a finger at her and saying, 9 “You’re a liar” — 10 MR. TEIN: That didn’t happen. 11 12 going to allow her to answer that question, 13 because she’s answered that same question and has 14 explained it. 15 Now Counsel might be sitting there rubbing 16 17 But if he can’t ask a question appropriately in a 18 19 20 21 22 23 24 that? 25 MR. TEIN: Ted - here. It’s the witness. MR. LEOPOLD: Fine. But after the sixth MR. LEOPOLD: That’s fine. But I’m not his head with a migraine. That’s his problem. professional manner, we will leave. I will not allow her to be berated like that. MR. GOLDBERGER: Actually, we’re very happy with the answer. MR. LEOPOLD: That’s great. MR. GOLDBERGER: Do you want us to get into

sor & Associates

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Page 61 1 MR. LEOPOLD: This is really big stuff that you’re going through. But that’s fine; just ask your question and move on. But do it one time. If you don’t understand it, I’ll let you follow up, but I’m not going to allow you to ask the same question time and again and then call her a liar. 7 Just ask the question, get the answer and move to the next subject matter. MR. TEIN: Ted, I’m sitting right across the table from you. 11 MR. LEOPOLD: Yes, sir. MR. TEIN: Please be quiet. Don’t yell. MR. LEOPOLD: I will not be quiet. MR. TEIN: Stop yelling. MR. LEOPOLD: , when I’m yelling you’ll know it. I will not — 17 MR. TEIN: My name is not MR. LEOPOLD: I thought your first name was , Mr. Tein. MR. TEIN: You watched me for three days at the evidentiary hearing where you sat in the back of the courtroom. You should know who I am. MR. LEOPOLD: Well, that’s the impression you must have made in the courtroom. I will not be quiet.

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1 Page 62 MR. TEIN: That’s obnoxious. Stop being 2 obnoxious. It’s stupid. Let’s go ahead with the 3 questions. 4 MR. LEOPOLD: I will make the record. 5 MR. TEIN: Let’s get on with the questions. 6 MR. LEOPOLD: Do you need a break? 7 (Thereupon, a recess was taken.) 8 BY MR. TEIN: 9 Q. Okay. after you told your manager 10 at the Quarterdeck Tavern everything that was going on 11 and he told you he would help you any way he could, he 12 hid you in the kitchen from the process servers, correct? 13 A. Incorrect. 14 Q. Isn’t it true that lying to avoid service 15 is a meaningless lie to you, ? 16 A. Incorrect. 17 Q. What is your manager’s name? 18 A. I have three. Would you like to know 19 all — 20 Q. Who’s the one who lied for you? 21 A. Justin. 22 Q. And what did Justin do to lie for you? 23 A. Said I wasn’t there. 24 Q. And who did he tell wasn’t there? 25 A. Ask him.

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Page 63 1 Q. Where were you when Justin told this 2 someone that you were not at the Quarterdeck Tavern? A. Eating nachos. 4 Q. At the Quarterdeck Tavern? S A. Yes. 6 Q. What did you do so that Justin would lie to 7 the process servers for you? A. Nothing. 9 Q. You just got him to lie for you, didn’t 10 you? A. No. I had no influence on him saying I wasn’t there. Q. He took that upon himself? Isn’t it true that Mr. Epstein’s process servers had to ask the police to get you out of the restaurant so that they could serve you? MR. LEOPOLD: Objection. Lack of foundation, predicate. BY MR. TEIN: 20 Q. You can answer the question. MR. LEOPOLD: If you know. Don’t guess. THE WITNESS: No. Can you repeat the question? MR. TEIN: Don’t coach. MR. LEOPOLD: Don’t guess.

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Page 65 1 Q. When did you delete your MySpace page? 2 A. A couple days ago. 3 Q. Who told you to take your MySpace page down 4 a couple of days ago? 5 A. Nobody. I’m sick and tired of MySpace. 6 Q. You all of a sudden got sick and tired of 7 MySpace and just a few days before this deposition you 8 decided to delete your MySpace page, correct? 9 A. Correct. 10 Q. Is that your testimony under oath? 11 A. Yes. 12 Q. Did you take your MySpace page down because 13 you thought the government might subpoena it? 14 A. Incorrect. 15 Q. Hadn’t your MySpace page been up for over 16 three months before you took it down? 17 A. Correct. But I also had made tons of 18 MySpaces over the last years. I just get tired of them 19 and delete them because — drama — and make new ones. 20 Q. We’re going to talk about that. 21 So you deleted your MySpace page after you 22 were already under subpoena for this deposition, correct? 23 A. Correct. 24 Q. What about the MySpace page didn’t you want 25 us to see,

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Page 66 1 A. Nothing. 2 Q. Well, we’re going to come back to MySpace 3 in a second. 4 A. You do that. 5 Q. I’m going to ask you some questions 6 about why you lie about your age so often, okay? 7 MR. LEOPOLD: Objection to the form. 8 Argumentative. 9 BY MR. TEIN: 10 Q. You lie about your age all the time, don’t 11 you? 12 MR. LEOPOLD: Objection, argumentative. 13 THE WITNESS: Incorrect. 14 BY MR. TEIN: 15 Q. You lie about your age to get body 16 piercings, don’t you? 17 A. Incorrect. 18 Q. You have body piercings, don’t you? 19 A. Yes. 20 Q. You have four body piercings; isn’t that 21 right? 22 A. Five. 23 Q. Other than the piercings on your ears 24 I’m not talking about that — 25 A. ■, then no; just one.

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Page 67
1Q.And where is the one body piercing?
2A.Belly.
3Q.When did you get that?
4A.For my birthday, with my stepmother and my
5father.
6Q.And when was that?
7A.When I was 14.
8Q.Okay. So you had that body piercing when
9you met Epstein, correct?
10A.It might have been, or maybe that yeah,
11either my 14th birthday or my 15th.
I honestly don’t
12remember.
13Q.Now you’ve lied about your age to get into
14bars by using driver’s licenses that aren’t yours,
15correct?
16A.Incorrect.
17Q.Are you swearing under oath that you’ve
18never done that?
19A.Yes, I swear under oath.
20Q.And you’ve lied about your age to buy beer,
21correct?
22A.Incorrect.
23Q.You’re swearing under oath that you’ve
24never lied to stores about your age?
25A.I’ve never lied to a store about my age or

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Page 68
1anything.
2Q.You try to look much older than you are,
3don’t you?
4A.Incorrect.
5Q.And you’ve lied about your age on your
6MySpace pages, don’t you?
7A.Incorrect.
8Q.All right.
Let’s look at Exhibit 26-01
9one.
10MS. BELOHLAVEK:
26-001?
11MR. TEIN:
Yes.
12BY MR. TEIN:
13Q.On this page you lied to everyone that you
14were 18, didn’t you?
15A.Correct.
160.Let’s go to Exhibit 33.
17MS. BELOHLAVEK:
That’s 33-001?
18TEIN: Correct.
19BY MR. TEIN:
20Q.On this page you lied to everyone that you
21were 19, didn’t you?
22A.Incorrect.
23Just answer the question.
MR. LEOPOLD:
24THE WITNESS: ■, incorrect.
25BY MR. TEIN:

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Page 69
1Now you can explain your answer.
Q.
2A.
I know that I have seen all of these and I
3know that this one is mine.
4Can you go down?
5MR. LEOPOLD: Just for the record, you’re
6pointing to the photo.
7THE WITNESS: I’m pointing to
8BY MR. TEIN:
9Q.
You’re pointing to the one where it says
10your age is 18?
11A.
Correct.
12That’s yours, right?
Q•
13A.
Correct.
That’s mine from a couple years
14ago that I have not been on, because I don’t use that.
15Please keep going down, please.
And I think that’s it,
16because there’s no one just that one is mine.
17So the one you pointed to where it says
Q.
18your age is 18, that’s yours, correct?
19A.
Correct.
20And when you wrote 18 as your age on your
Q.
21MySpace page, that was a lie, wasn’t it?
22A.
Correct.
23Q.
Did you lie about your MySpace page back
24then because you couldn’t post on MySpace unless you were
2518?

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Page 70 1 A. Correct. There was a rule many years ago 2 that you had to be 18 to have a MySpace. 3 Q. So you lied about your age so you could 4 post on MySpace, right? 5 A. Yes. 6 Q. Let’s go back to the top one on this page, 7 33-01. 8 Are you testifying now under oath that this 9 MySpace page where the headline says, “Twins do have more 10 fun,” and the location is given as Lox, abbreviation for 11 Loxahatchee, and the age is 19, and it says - 12 is it your testimony that you did not post 13 that? 14 A. Correct. 15 Q. Now let’s go back to the one that you were 16 pointing to before on this page, where it says your age 17 is 18 and you lied about your age to post MySpace, okay? 18 A. Uh-huh, yes. 19 Q. All right. Why did you finally put your 20 true age on your MySpace profile four days before you 21 were scheduled to testify before the Grand Jury? 22 A. I don’t know what you’re talking about. 23 MR. LEOPOLD: If you don’t understand, ask 24 him to ask the question again. 25 MR. TEIN: Don’t coach.

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sor & Associates Reporting and Transcription, lac. Page 71 1 THE WITNESS: I don’t know which MySpace 2 you’re talking about. 3 BY MR. TEIN: 4 Q. The MySpace page that you’re just pointing 5 to, where it says you were 18. 6 A. Yes. 7 Q. And you were lying about your age, right? 8 A. Uh-huh. 9 Q. Why did you finally post your true age on 10 your MySpace profile — 11 A. Uh — 12 Q. — four days before you were scheduled to 13 testify before the Grand Jury? 14 A. I honestly don’t know which MySpace, 15 because I’ve had like a bazillion MySpaces, and in that 16 year, I had two, that one and another one, and that one’s 17 been deleted. So I don’t know which one you’re referring 18 to. 19 Q. You remember that you changed your age on 20 your MySpace page from 18 to your true age just four days 21 before you went and testified in the Grand Jury? 22 A. No. 23 Q. You don’t remember that. 24 A. No. 25 R. Do you remember Detective Recarey? Did you

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e Repartees ll ad Trsescripoeo, lac

ever meet a Detective Recarey?
1
2
A.
I don’t know the names.
Q.
How many different detectives have you met
3
with on this case from Palm Beach?
4
5
Probably a good six or seven, maybe.
A.
Did one of the detectives tell you before
Q.
6
7
you testified in the Grand Jury that you should take your
8
MySpace age and put your true age?
A.
No.
9
10
Q.
Didn’t Detective Recarey have to come to
your house to pick you up to get you to testify in front
11
12
of the Grand Jury?
13
A.
Possibly; maybe because I didn’t have a
ride; I was only 14 or 15 at the time.
14
15
Q.
Your mom didn’t drive you?
16
A.
No.
17
Stepmom didn’t drive you?
Q.
18
A.
I think my dad.
my dad; my dad drove
19
me.
20
Your dad drove you?
Q.
21
A.
Yes, sir.
22
So your testimony is Detective
Q.
did
23
not drive you, correct?
24
MR. LEOPOLD:
Objection.
/asked and
25
answered.
Page 7.

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eRe l portiag ad Treascripoos, Inc. Page 73 1 THE WITNESS: No. I’m pretty sure my dad 2 drove me, because he was there with me. 3 BY MR. TEIN: 4 Q. Did any detective tell you to change your 5 age on your MySpace page, to put your true age? 6 A. No, sir. 7 Q. Now you also lied on your MySpace page 8 about your income, didn’t you? 9 A. Yes. 10 Q. And you lied, saying that you made a 11 quarter million dollars a year and higher, correct? 12 A. As a joke, yes. 13 Q. That was a lie, wasn’t it? 14 A. Yes. 15 Q. And you also lied on your MySpace page, 16 saying that you were married, didn’t you? 17 A. Possibly. And that might have been an 18 error on my part. 19 Q. Now you also lie to the police, don’t you? 20 A. No. 21 Q. Well, you lied to the police in your 22 tape-recorded statement that you gave to Detective 23 Pagan three years ago, didn’t you? 24 A. To my knowledge, no, I did not. 25 O. Well, you lied to the police when you

sor & Associates

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Page 74 1 accused Mr. Epstein of attempting to murder your father, 2 didn’t you? 3 A. No. I never heard a statement saying that 4 Mr. Epstein tried to murder my father. 5 Q. You made that statement, didn’t you? 6 MR. LEOPOLD: Do you have a statement to 7 show her? That’s been asked and answered. 8 MR. TEIN: I’m sorry. I didn’t hear the 9 witness’ answer, Mr. Leopold. 10 BY MR. TEIN: 11 Q. you told the police, didn’t you, 12 that Mr. Epstein almost killed your father, didn’t you? 13 A. No. 14 Q. Three years ago, before Mr. Epstein even 15 knew about this investigation, you told the police that 16 Epstein had “already come to my dad’s house and did 17 something to my dad’s tires and my dad almost died. 18 didn’t want my dad to get hurt, because Jeff already 19 almost killed him.” 20 Didn’t you say that? 21 A. Not to my knowledge or recollection. I 22 have never said anything like that. 23 Q. That would have been a complete lie, 24 wouldn’t it have been? 25 A. Yeah.

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Page 75 1 Q. Because Mr. Epstein never came to your dad’s house, correct? A. Correct. 4 Q. And no one who worked for Mr. Epstein ever did something to your dad’s tires, did they? MR. LEOPOLD: Objection. Lack of foundation, predicate. Don’t guess. BY MR. TEIN: 10 4. It’s not true that Mr. Epstein almost 11 killed your father, is it? MR. LEOPOLD: Objection. Asked and answered, lack of foundation, predicate. BY MR. TEIN: Q. You can answer. A. No. Q. Now you told the police that you didn’t know who was in the car with you and Bayley on the day you went to Epstein’s house, didn’t you? A. Yes. Q. And that was a lie, wasn’t it? A. It’s the truth. Q. You told the police that there was someone in the car next to you and you specifically said you didn’t know her name, right?

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8 9 10 Bayley? Page 76 1 A. Correct. I do not know her name. 2 Q. You said, “I don’t know her name, but she 3 was dark like a Spanish girl.” Those were your words, 4 right? 5 A. Yes. 6 MR. LEOPOLD: Objection. Asked and 7 answered. BY MR. TEIN: Q. Who was in the car that day with you and 11 A. Again, I do not know. 12 Q. It was your good friend 13 wasn’t it? 14 A. No. I don’t know a 15 Q. 16 car with you 17 A. 18 Q. 19 20 A. 21 Q-22 A. 23 she’s family. And yes. 24 Q. What’s her e-mail? 25 You lied to the police about who was in the and didn’t you? Incorrect. Let me ask you some questions about who you may have spoken to about this case. All right? Go ahead. Did you speak to your twin sister Not in detail, but of course she knows; A. I don’t think she has an e-mail.

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Page 77
1Q.
What is her phone number?
2II, gosh.
A.
I don’t know off the top of my
3head.
4Q.
And what is her home address?
5A.
She lives with my mom.
6Q.
In Georgia?
7A.
Yes, sir.
8Q.
What aboutillillillboyfriend Paul?
Did you
9speak to him about Epstein’s case?
10That’s my mom’s boyfriend.
A.
My sister
11doesn’t have a boyfriend.
My mom’s husband’s name is
12Paul, so maybe you get them confused.
13Do you know his phone number?
Q.
14A.
No.
15Q.
Where does he live?
16With my mom.
A.
17In the same house with her?
Q.
18A.
Yes.
They’re married.
19So not boyfriend; husband?
Q.
20A.
Yeah, husband.
21Have you spoken to Brett Albritton about
Q.
22what happened in Mr. Epstein’s house?
23A.
Not in detail, but he knows the basics,
24yes.
25What is his e-mail?
Q.

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Page 78 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 street. 24 Q. What’s the name of the apartment complex? 25 A. Something Cove. A. I don’t know. Q. What is his phone number? A. How is that relevant? Q. What is his phone number? A. Q. What is his home address? A. I don’t know. Q. Where does he live? A. In Palm Beach Lakes somewhere. Q. Ever been to his house? A. Yes. O. You don’t know what his address is? MR. LEOPOLD: Objection. Asked and answered. She just said she doesn’t know. MR. TEIN: Don’t coach. MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. You can answer the question. A. I don’t know the exact address. Q. What street is it on? A. It’s an apartment complex; its not a

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Page 80
1We’re not allowed to know
girls in this whole situation.
2each other.
3Q.
I didn’t get the last four words.
4A.
We’re not allowed to know each other.
5? Have you
And what about
Q.
6of met her?
7A.
No, sir.
8Q.
Let’s see if I can refresh your memory on
9her. She’s the other person represented by your lawyer
10Mr. Herman, who is suing Epstein for fifty million
11dollars.
12I have no knowledge of her.
A.
13Q.
Never met her?
14Never met her.
A.
15Tony
Q.
16A.
I don’t know who that is either.
17Q.
A person named Anthony who knows Hayley?
18Is that Tony 11111111?
19I don’t know, sir.
A.
20Q.
Do you remember making a statement to
21that’s in the police reports?
Detective
22A.
No, sir.
23Q.
Have you read the police reports in this
24case?
25A.
Yes.

Page 81 1 Q. They’re on the Internet, right? 2 A. Yes, I think. 3 Q. Were you surprised when the police reports 4 were released on the Internet containing your statements 5 that you had made to the police? 6 A. Yes. 7 Q. You didn’t want to see that happen, right? 8 A. No. 9 Q. So you’re saying you don’t know a Tony 10 IIIIIIIIIt 11 MR. LEOPOLD: Objection. Asked and 12 answered. 13 BY MR. TEIN: 14 Q. Does it refresh your memory that he was 15 somebody who had gone to jail for drugs and car theft? 16 A. No, sir. 17 Q. Someone who knows Hayley? 18 A. No. 19 Q. You don’t know if he met with Detective 20 Recarey? 21 A. No, sir. 22 Q. How about Zack Bryan? 23 A. Yes, I remember. I know who that is. 24 Q. Did you ever speak to Zack Bryan about what 25 happened at Mr. Epstein’s house?

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Page 82 1 A. He knows what happened four years ago. He 2 doesn’t know this is still going on today. 3 Q. What’s his address? I’m sorry. I have his 4 address. 5 A. I don’t know. 6 Q. How about Nick Kowalski? 7 A. Kowalski? 8 Q. You know who that is? 9 A. I know who that is, yes. 10 Q. He’s the one you stayed out drinking all 11 night one night last year when your dad reported you 12 missing? 13 A. No, sir. 14 Q. Remember the baseball game you were 15 supposed to go to? 16 A. No, sir. 17 Q. Did you speak to Nick Kowalski about this 18 case? 19 A. No, sir. 20 Q. How about 21 A. That’s my sister’s ex-boyfriend. 22 Q. He’s the one with the sawed-off shotgun 23 with the obliterated serial number? 24 A. Ask him. I would not know that 25 information.

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Page 83
1Q.
Did you speak to
about this
2case?
3No, sir.
A.
4Q.
Have you spoken to John Connolly about this
5case?
6A.
I don’t know who John Connolly is.
No.
7Q.
Did your parents speak to John Connolly?
8Ask my parents.
A.
9Let’s see if I can refresh your memory as
Q.
10to who he is. Okay?
11Uh-huh.
A.
12He’s the Vanity Fair reporter who made a
Q.
13financial arrangement with your father.
14A.
I am aware of that.
And again, I was not
15aware like that my dad did it until after it was done.
16And I don’t know the details about that.
I just know
17what you know about that, like that they talked.
18Q.
Tell me what you know about the financial
19arrangement that John Connolly, the Vanity Fair reporter,
20made with your father.
21A.
I don’t know about the details at all.
22Q.
How much money did John Connolly give to
23your father?
24I don’t even know he gave money to my dad.
A.
25Q.
I’m sorry?

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Page 84 1 A. I didn’t even know he gave money to my dad. 2 Q. What do you know about the deal that John 3 Connolly has with your father? 4 A. I only know they spoke on the telephone 5 once. I don’t know anything else. 6 Q. When was that? 7 A. This was a while ago, a year or two or a 8 year ago. I honestly don’t know. 9 Q. Did John Connolly, the Vanity Fair 10 reporter, offer any money to your father? 11 A. I don’t know. 12 Q. Did John Connolly, the Vanity Fair 13 reporter, give you any money? 14 A. No, sir. 15 Q. Did he offer you any money? 16 A. No, sir. Never spoke to him. 17 Q. What reporters have you spoken to? 18 A. Zero. 19 Q. What about your family members? What 20 reporters have they spoken to? 21 A. The whole Palm Beach County, obviously, as 22 you can see in that newspaper. 23 Q. Tell me — let’s go through each one that 24 you remember. Other than the Vanity Fair reporter, John 25 Connolly, what other reporters have any member of your

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07/26/17 Page 2759 Public Records Request No.: 17-295

1 family spoken to? 2 A. I don’t know. And I know my mom has spoken 3 to zero. My sister spoke to zero. My father and 4 stepmother, I wouldn’t know. You’d have to ask them. I don’t contact them. Q. Well, I just want to know — I don’t want you to — I want to know what’s in your mind. All right? 8 MR. LEOPOLD: She just told you. She just answered — 10 MR. TEIN: Be quiet. BY MR. TEIN: Q. What I want to know is what you know from your personal knowledge. My question to you is: What knowledge do you have about family members of yours speaking to reporters? MR. LEOPOLD: Objection. Asked and answered. And if you can’t talk professionally, we’re going to leave. MR. TEIN: Do what you want to do. MR. LEOPOLD: Are you going to continue to talk this way? MR. TEIN: I’m not going to answer any question that you ask me, Mr. Leopold. MR. LEOPOLD: Okay.

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Page 85

Page 86 1 MR. TEIN: But you are misrepresenting the record and you are grandstanding for your client and it’s wrong. So be quiet. And you know how to make an objection. Make it. Otherwise stop talking. BY MR. TEIN: 7 Q. MR. LEOPOLD: Excuse me. MR TEIN: If you want to leave the 10 deposition, leave. But you’ll be back here. MR. LEOPOLD: Excuse me. If I could just make the record, instead of interrupting me, please. That’s what we do professionally. 14 There’s a recorder here. I’m certainly not being obstructionist. I’m going to make the record. But we’re going to act with some semblance of professionalism, hopefully, by all parties in the room. That goes to me, that goes to your co-counsel sitting behind you and next to you, the court reporter and everyone else in the room. Everyone is entitled to that. You’ve asked a question. She answered the question fully and she’s not going to be harassed because you don’t like the answer. If you want to follow up —

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Page 87
1MR. TEIN: Stop engaging me.
Make your
2speech and then we’ll ask the questions.
3MR. LEOPOLD:
Well, you won’t let me finish
4making the objection, so it’s difficult to do
5But if you want to follow with an
that.
6appropriate question, feel free to do that.
But
7we’re not going to harass the witness.
8MR. TEIN:
I disagree with everything
9you’ve said.
Okay?
Let’s ask the questions.
10MR. LEOPOLD:
Ask an appropriate question.
11MR. TEIN:
Are you going to stop talking?
12MR. LEOPOLD: I’m going to make protect
13my client and make appropriate objections. But
14there’s not a question pending right now.
15BY MR. TEIN:
16Q.
spoken to any reporters?
has
17No.
A.
18MR. LEOPOLD:
Asked and
Objection.
19answered.
20BY MR. TEIN:
21Q.
Has
been given money by any
22reporters?
23A.
No.
24Has your mom spoken to any reporters?
Q.
25MR. LEOPOLD: Objection.
Asked and

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Reporting ad Transcription. lac.

Page 88
1answered.
2THE WITNESS:
No.
3BY MR. TEIN:
4Q.Has your mom’s husband Paul spoken to any
5reporters?
6A.No.
7Q.Has your mom’s husband Paul received any
8money from reporters?
9A.No.
10Q.Are you sure you don’t know
11MR. LEOPOLD:
Objection.
Asked and
12answered.
13THE WITNESS:
I’m positive.
14BY MR. TEIN:
15Q.I’ll try again to refresh your memory.
16A.Okay.
170.Does it refresh your memory that she had
18been arrested for drugs and was cooperating with
19Detective Recarey against Epstein to get herself a better
20deal?
21A.I don’t know who she is.
No.
22Q.Have you spoken to anyone else who’s been
23at Epstein’s house?
24A.No.
25Q.Without telling me what was said I don’t

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Page 89 1 want to know about any conversations with any lawyers, 2 okay — 3 A. Uh-huh. 4 Q. — did you or your parents speak to any 5 other law firms besides Mr. Herman and Mr. Leopold’s law 6 firms? 7 A. No. 8 Q. Now without telling me about anything that 9 was said, what — did one just come to mind? 10 A. No. I was thinking about something else. 11 Q. What were you thinking about? 12 A. Does family court matter? 13 Q. Okay. Without telling me what was said, 14 who prepared you for today’s deposition? 15 A. What do you mean prepared? 16 Q. Did you talk about this deposition, about 17 what would happen, with anybody? 18 A. Yes. 19 Q. Don’t tell me what was said. 20 A. Okay. 21 Q. I’m not asking that. I don’t want to know 22 that. 23 A. Okay. 24 Q. Who prepared you for today’s deposition? 25 A. Mr. Leopold.

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Page 90 1 Q. Anybody else? 2 A. No. Q. When did you meet with Mr. Leopold to prepare for today’s deposition? A. This morning. 6 Q. And how long did that meeting last? A. Until it started. Q. Now you told me that you previously had read the police reports in this case? A. Yes. Q. Have you read your statement that you gave to the police? A. Yes, sir. 14 Q. And in what form was that statement? A. What do you mean? Q. Was it in the form of a police report or a transcript? A. What’s the difference? Q. A transcript has questions and answers on it. A police report is just typed out narrative. A. II, it’s a police report. Q. And when did you read the police report? A. A few days ago. I overread it a few days ago. 25 Q. Had you read it before that?

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Page 91 1 A. No. 2 Q. Now you told me — again, I don’t want to 3 know what was said. 4 A. Uh-huh. 5 Q. You told me that you met with Mr. Leopold 6 this morning to prepare for your deposition, right? 7 A. Yes. 8 Q. When did you set up that meeting with 9 Mr. Leopold to take place this morning? 10 A. Gee, like, like five days ago, four days 11 ago. 12 Q. So you’re aware that Mr. Leopold told us 13 that he could not start the deposition this morning 14 because he had a court appearance, correct? 15 MR. LEOPOLD: Don’t answer that question. 16 Calls for attorney/client communications. 17 BY MR. TEIN: 18 Q. Have you seen the letter that Mr. Leopold 19 wrote to us stating that he — an e-mail that Mr. Leopold 20 wrote to Mr. Goldberger stating that he could not be here 21 this morning because he had a court appearance? Did you 22 see that e-mail? 23 MR. LEOPOLD: You can answer that question. 24 THE WITNESS: No. 25

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Page 92 1 BY MR. TEIN: 2 Q. Have you listened to your tape-recorded 3 statement to the police? 4 A. Yes. 5 Q. Where did you listen to that? 6 A. In, I think, this building. I don’t know. 7 It was here. 8 Q. When did you listen to that statement? 9 A. This morning. 10 Q. And who was present when you listened to 11 that statement? 12 A. Mr. Leopold — and I forget your name. 13 MR. GOLDBERGER: Ms. Belohlavek. 14 THE WITNESS: Ms. Belohlavek. 15 BY MR. TEIN: 16 Q. And you hadn’t listened to your statement 17 before that, correct? 18 A. No, sir. 19 Q. Have you met with lawyers representing 20 anyone else suing Epstein? 21 A. No, sir. 22 Q. How many times have you spoken to officers 23 with the Palm Beach Police Department? 24 A. More than I like can count. It’s been 25 ongoing for four years, so quite a few times.

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Page 93
1When was the last time you spoke with
Q.
2officers of the Palm Beach Police Department?
3A.
A while ago.
I’d say a year ago.
4Q.
A year ago?
5Maybe a year and a half.
A.
Yeah.
6Do you remember Detective Recarey?
Q.
7A.
No.
8Do you remember
Pagan, Detective
Q.
9Pagan?
10A.
Yes.
11Q.
How many times have you spoken to Detective
12Pagan?
13She was the only one I spoke to about this
A.
14until for some reason she wasn’t on the case anymore.
15When was that?
Q.
16The first meeting I ever had was with her
A.
17and then I think like I met with her like 10 times or 12
18times or something like that, and then I didn’t get
19another investigator questioned me after that.
20And who was that?
Q.
21I don’t remember.
A.
22And what type of questions did they ask
Q.
23you?
24The same.
A.
25The same questions all over again?
Q.

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Page 94
1A.Basically.
2Q.How many taped statements have you given to
3the police?
4A.One that I know of.
5Q.Just the one with Detective Pagan?
6A.Yes, sir.
7Q.How about to the FBI?
Did you give any
8statements to them?
9A.Well, actually, I don’t really
No.
10remember if that was taped or not, to be honest with you.
11I had one meeting with them at my house and don’t know if
12it was taped.
13Q.You were interviewed at Tiffany Rich’s
14house?
15A.That was by the lawyer.
No.
16Q.II,
by the lawyer?
17A.Uh-huh.
18Q.Where did the conversation that you had
19with the FBI take place?
20A.At my father’s residence.
21Q.Which is where?
22A.On Downers in Loxahatchee.
23Q.On where?
24A.Downers Road in Loxahatchee.
25Q.And when did that take place?

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Page 95 1 A. I’d have to say like a year and a half ago, 2 a year ago. It was a long time ago. 3 (Discussion held off the record.) 4 MR. TEIN: Tell me the last answer, please. 5 (Thereupon, a portion of the record was read 6 by the reporter.) 7 BY MR. TEIN: 8 Q. And who was present when the FBI spoke to 9 you at your father’s house? 10 A. My stepmother was there, but she wasn’t 11 around. She made herself like do other things. 12 Q. And how many FBI agents were there? 13 A. I think four. 14 Q. And you don’t remember any of their names? 15 A. No, sir. 16 Q. And were there any lawyers there? 17 A. Not that I know of. 18 Q. And none of them gave you their cell phone 19 numbers? 20 A. No. 21 Q. And the last time you spoke to the FBI was 22 a year and a half ago? 23 A. It was a while ago. 24 MR. LEOPOLD: Objection. Asked and 25 answered.

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I

sor & Associates
Reporting sad Traascripeon. Inc.
Page 96
1BY MR. TEIN:
2Q.
And the last time you spoke to the federal
3prosecutor’s office was when?
4A.
I don’t know.
5Q.
Did any of the FBI agents tell you that
6had spoken with Mr. Leopold?
7
8d any of the FBI agents tell you that
9had spoken with Mr. Herman?
10A.
No.
11Q.
Did any FBI agents tell you that Jeff
12Sloman spoke with Mr. Herman.
13A.
No.
14Q.
Did any FBI agents tell you that Jeff
15Sloman spoke with Mr. Leopold?
16A.
No.
17Do you know whether any of the federal
Q.
18prosecutors allowed Mr. Herman to review a draft
19indictment?
20A.
I wouldn’t know.
21Do you know if any of the federal
Q.
22prosecutors discussed a draft indictment with Mr. Herman?
23A.
I wouldn’t know.
24Have you ever e-mailed with any FBI agent
Q.
25or any federal prosecutor?

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Page 97
1A.
No.
2Q.
Have you ever text messaged with any FBI
3agent or any federal prosecutor?
4A.
No.
5Q.
Has the FBI told you about other testimony?
6A.
No.
7Q.
Has the FBI told you about what other girls
8have said?
9A.
No.
10Q.
Have federal prosecutors told you what
11other girls have said?
12A.
No.
13Do you have any way of getting in touch
Q.
14with the FBI if you wanted to get in touch with them?
15A.
No.
16Q.
How about your parents?
Do they know how
17to get in touch with the FBI?
18A.
I don’t know.
19And by your parents, I’m referring to both
Q.
20sets, okay?
21II. Well, I’m referring to only my dad,
A.
22because my mom really doesn’t care to know any of this
23stuff.
24Q.
So the answer would be the same for your
25mom and Paul?

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Page 98
1A.
Yeah.
2Have you spoken to a lawyer named Burt
Q.
3Ocariz about this case?
4A.
No.
50.
Do you know who Burt Ocariz is?
6Let’s see if I can refresh your memory.
7Does it refresh your memory that he’s a good friend of
8Villafona’s boyfriend?
9A.
I don’t know who
s.
10s the lead federal
Q.
11prosecutor
that’s on the federal part of this case.
12Okay?
13A.
No.
14So does it refresh your memory that Ocariz
Q.
15is the good
friend of a
oyfriend?
16A.
Not at all.
17Does it refresh your memory that Villafona
Q.
18tried to get Epstein to pay for Ocariz to represent you
19in the federal case?
20No.
A.
21Do you know if Detective
spoken
Q.
22with your father?
23A.
No.
24Do you know if Detective Recarey has spoken
Q.
25to your stepmother?

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Page 99 1. 2 3 A. No. Q. How about with - -? A. Yes, I would know; and no, she did not. Q. Let’s put up — let me ask you some questions about the photo that you had posted on your MySpace page before you erased it last week. Okay? A. Okay. MR. TEIN: Do you mind if we close the door a second, please. MR. LEOPOLD: Exhibit number, please. 11 MR. TEIN: Put up 25-005. Hold on a second. MR. LEOPOLD: Don’t say anything. she was talking to her counsel. MR. TEIN: Put up 25-006. MR. LEOPOLD: Is that 005 right there? MR. TEIN: Yes. BY MR. TEIN: 19 Q. Who took this photo of you in a warehouse, simulating being gang-raped by a bunch of — 21 MR. LEOPOLD: Objection. Mischaracterizes the photograph, and lack of foundation and predicate. Fully explain if you need to. THE WITNESS: I will.

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07,26/17 Page 2774 Public Records Request No.: 17-295

Page 100
1First off, this is not a warehouse.
This
2is in Steven Lavelle’s garage.
3Second of all, I’m not being gang-raped.
4Everyone has their clothing on.
5Thirdly, if you’d look at all the other
6pictures in that album, I’m drinking what’s
7when you’re sick you drink it?
8BY MR. TEIN:
9You can’t ask questions of your counsel.
Q.
10A.
All right.
I’m drinking like Sprite.
I’m
11not drinking any kind of alcohol, if you would look at my
12other pictures in that album.
13You guys picked the possibly worst pictures
14out of there to present.
And it was just a goofy
15picture. All of these kids like to be goofy.
And that’s
16what we were doing.
17Who’s the man on the left of the picture
Q.
18holding his holding a beer bottle as if it were a
19penis towards your mouth?
20Steven Lavelle.
A.
21Who’s the man behind you, right up towards
Q.
22your backside, with you bent over?
23A.
That one?
24The right side, kissing with his mouth.
Q.
25A.
That’s Nick Antico.

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StinReporting and Truscription, Inc sor & Associates

Page 101 1 Q. He’s the one grabbing towards the groin area of Steven Lavelle? 3 A. Yes. Q. And there’s three other men in the photo. What are their names? The one on the left with the hat? A. That’s Robbie Shergan (phonetic). Q. Smiling? A. Yes. Q. Who’s the one kissing — 10 MR. LEOPOLD: Don’t interrupt. Let her finish the record. She’s testifying. MR. TEIN: I know you don’t like this picture, my friend. MR. LEOPOLD: The picture is fine. BY MR. TEIN: Q. Who’s the one with the hat? MR. LEOPOLD: No. Hold on. Stop, You have to let the witness finish her answer. She was in the process of explaining and you cut her off. Please finish what you were saying and then Counsel can ask you whatever he wishes after that. THE WITNESS: Okay. This guy — 24 MR. LEOPOLD: Just make it so the record is clear who you’re referring to.

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07/26/17 Page 2776 Public Records Request No.: 17-295

sor & Associates
Lipman end Treescripties. be.
Page 102
1on the far left is John
THE WITNESS:
2
3BY MR. TEIN:
4Q.He’s the one whose head is near the groin
5of Steven Lavelle, right?
6A.Yes.
7Q.And in the middle there’s a man smiling.
8Who’s that?
9A.That’s Robbie Shergan.
10Q.And who’s the one in the red hat, kissing?
11A.That’s Brandon Salnal (phonetic).
12Q.Let me stop you for a second.
Are you
13done?
14A.Yes, I’m done.
15Q.Who is Courtney?
16A.My sister’s friend.
Well, she’s a mutual
17friend, but more my sister’s.
18Q.What is her last name?
19A.Sailor.
20Q.Spell that.
21A.I don’t know how to
22Q.Have you spoken to her about this case?
23A.No.
24Q.Who’s Vince?
25A.My sister’s friend.
I don’t really speak

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• Reporting and Transcriptine, Inc.

Page 103
1to him at all.
2Q.What’s his last name?
3A.Roman,
4Q.R-o-m-a-n?
5A.R-o-m-a-n.
6Q.And have you spoken to Vince about this
7case?
8A.No, sir.
9Q.Have you spoken to
bout this case?
10A.Not in detail, but yes.
11MS. BELOHLAVEK:
Are we referring to
12
13THE WITNESS:
Yes.
14MR. TEIN:
Yes.
15MS. BELOHLAVEK:
Okay.
16BY MR. TEIN:
17Q.Have you spoken to Justin about this case?
18A.Justin?
19Q.Do you have a friend named Justin?
20A.I do not have a friend named Justin.
21Q.From freshman year?
22A.No.
23Q.How about
24A.No.
25Q.Have you spokes
bout this case?

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07126/17 Page 2778 Public Records Request No.: 17-295

Page 104
1A.
No.
2Q.
What’s her last name?
3A.
Duchesne.
I don’t know how to spell it.
4Q.
Is she the person whose house you went to
5on New Year’s this year?
6A.
No.
I wasn’t at her house on New Year’s.
7Q.
Where were you when you took the picture of
8”Can you say blazed,” that’s on your website?
9A.
I wouldn’t know or wait.
We were at a
10birthday party for some girl’s 16th birthday.
11Q.
Were you drinking at that party?
12A.
No.
There was no alcohol or anything
13there.
14Q.
What does “blaze” mean to you?
15A.
It’s like it just means like messed up.
16But we weren’t, if you look at the picture.
17Q.
Messed up like drunk, right?
18A.
Sure.
19Q.
Who’s
20A.
A girl I know, like from like two years
21ago.
22Q.
She’s the one you were supposed to be
23staying with when you went drinking with Nick Kowalski?
24A.
No.
25Q.
What’
last name?

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Page 105
1A.
2Q.
Where does she live?
3A.
I don’t know.
In
Palm.
4Q.
5A.
Uh-huh.
I’m guessing.
6Q.
Do you know her phone number?
7A.
No, I do not.
8Q.
Let’s look at 25-010.
9A.
See, I’m drinking
10I’m not asking you about what you’re
Q.
11drinking.
12Who are the men in this photo who are
13pretending to gang up on you and stab you with knives?
14Who are they?
15A.
Nick Antico and Brandon Salnal.
16Are these firemen?
Q.
17A.
Steven Lavelle he said th(
Are those?
18two stabbing with knives.
That’s why I said that.
19don’t know.
That’s Steven Lavelle and John
20Are these firemen?
Q.
21A.
No.
They’re all on except Steven,
22they’re all on full rights for football.
23Go to 025-015.
Q.
24MR. LEOPOLD:
025 dash?
25MR. TEIN:
015.

07/2W] Page 2780 Public Records Request No.: 17-295

Page 106 1 THE WITNESS: Gosh, that’s so long ago. 2 BY MR. TEIN: 3 Q. Who took the photo of you licking the 4 penis? 5 A. My stepmother. 6 Q. Whose idea — that was your stepmother’s 7 idea? 8 A. It was in Buca di Beppo, where she works 9 currently, and that was before she worked there. And we 10 just thought it would be funny. 11 MR. TEIN: 19-007. Can you enlarge that? 12 BY MR. TEIN: 13 Q. Who took this photo of you simulating you 14 having sex with a man? 15 A. We’re not simulating having sex, and 16 it’s — II, and the person who took it was, I’m pretty 17 sure, Chris, but I know him as Swiss. I don’t know his 18 last name. 19 Q. Go to 19-006, please. 20 Who took this photo of you simulating sex 21 with a man? 22 A. The same person. And we’re not simulating 23 having sex, Mr. — 24 Q. Tein. 25 Did you post that on the Internet?

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Page 107 I
1A.
Actually, this is an old MySpace I never
2I just kind of
finished and I never like did anything.
3made it and left it.
4Q.
So the answer is yes, you posted this on
5MySpace?
6A.
Yup.
7Who took this photo of you
Q.
Go to 25-016.
8simulating sex with a woman?
9MR. LEOPOLD: Object to the form of the
10question.
Argumentative.
11First off, she’s piercing my
THE WITNESS:
12belly button or repiercing it, and I’m pretty sure
13it was just like we put up a camera somewhere and
14put a timer on it. We didn’t have anybody take
15it.
16BY MR. TEIN:
17Q.
You posted that on your MySpace page?
18A.
Yeah.
19Go to 25-013.
Is that a photo of you?
Q.
20A.
Yep.
21Q.
Who’s in the photo with you?
22A.
Steven.
23Q.
Steven Lavelle?
24A.
Yep.
25Q.
Is this you coming out of the shower?

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sor & Associates Reporting and Transcriptico, In.

1 2 A. Q. Page 108 Yes. Are you clothed in this picture? 3 A. Yeah. I have a halter dress on. 4 Q. Where is that picture taken? 5 A. In Steven’s house. 6 Q. Did you post that on the Internet? 7 A. Yes. 8 Q. All right. 9 MR. TEIN: You can take that down. 10 BY MR. TEIN: 11 Q. Now your boyfriend is Brett Albritton, 12 correct? 13 A. Yeah. 14 O. You lie about your age in order to conceal 15 something about your relationship with Brett Albritton; 16 isn’t that correct? 17 A. No. 18 Q. Brett’s 22 years old, isn’t he? 19 A. Yes. 20 Q. And Brett is a firefighter with the Palm 21 Beach Fire Department, right? 22 A. Yup. 23 Q. Does the Palm Beach Fire Department know 24 that your boyfriend is dating an underage girl? 25 A. Actually, mister, it’s legal.

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Page 109 1 Q. Well — 2 MR. LEOPOLD: Just answer the question, 3 Saige. 4 THE WITNESS: Yes. 5 BY MR. TEIN: 6 Q. Did they know two weeks ago that you were 7 dating an underage girl (sic)? 8 A. Yes. I met everybody in there. 9 Q. Did they know your age? 10 A. Yes. 11 Q. Did you lie about your age so that the fire 12 department wouldn’t think that Brett is committing a 13 crime by having a sexual relationship with an underage 14 girl? 15 MS. BELOHLAVEK: Objection. Assumes facts 16 not in evidence. 17 BY MR. TEIN: 18 Q. You can answer the question. 19 A. No. 20 Q. Does the Palm Beach Police Department know 21 that Brett is having a sexual relationship with an 22 underage girl? 23 MR. LEOPOLD: Don’t guess. Answer if you 24 know. 25 THE WITNESS: Can you repeat the question? Ph. 561.682.0905 - Fax. 561.682.1771

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Reporting and Transcription. Inc.

Page 110 1 BY MR. TEIN: Q. Does the Palm Beach Police Department know that Brett, a member of the Palm Beach Fire Department, 4 is having a sexual relationship with an underage girl? A. I’m guessing no. 6 Q. You lie about your twin sister don’t you? MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: 10 Q. Don’t you? A. No. I have never lied for or to Q. You lie about the fact that she has a drug habit, right? A. No. I would never accuse my sister of having a drug habit. 16 Q. Do you try to conceal the fact that she has a drug habit? MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: Q. You can answer the question. A. No. My sister does not have a drug habit. Q. You lied when you went to the crack house in Georgia, didn’t you? MR. LEOPOLD: Objection. Argumentative. Lack of foundation, lack of predicate.

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Page 111 1 THE WITNESS: Never — what did you say? BY MR. TEIN: Q. You lied when you went to the crack house in Georgia, didn’t you? MR. LEOPOLD: Objection. Argumentative. Lack of foundation, lack of predicate. BY MR. TEIN: Q. You can answer the question. A. I have never been to a crack house. 10 Q. Who don’t you lie to? MR. LEOPOLD: Objection. Argumentative. Don’t answer the question. MR. TEIN: Certify it. CERTIFIED QUESTION BY MR. TEIN: Q. You don’t lie to no you? MR. LEOPOLD: Objection. Asked and answered. Don’t answer the question. BY MR. TEIN: Q. No. You can answer that question. MR. LEOPOLD: No. I just told her not to. You’ve asked that question about five — 24 MR. TEIN: No, I haven’t. MR. LEOPOLD: Don’t answer the question.

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Page 112 1 2 CERTIFIED QUESTION 3 4 stop interrupting me because she can’t take down 5 both of us talking at the same time. BY MR. TEIN: Q. You tell the truth, don’t you? A. Excuse me? Q. You tell the truth, don’t you? A. When it’s yes, I tell the truth. Q. Who’s drug dealer? A. My sister does not have a drug dealer. She 6 7 8 9 10 11 12 13 lives in Georgia with my mother. 14 Q. Okay. Who is the drug dealer who dropped 15 16 all night, the two of you, using drugs at Palm Beach 17 Country Estates where your father called the police? 18 A. Mike Duval. 19 Q. He’s the drug dealer? 20 A. He is a drug dealer. 21 Q. Do you remember was arrested by the 22 Palm Beach Police Department and taken to the Juvenile 23 Assessment Center that morning? 24 A. I do remember that. 25 Q. Now before you massaged Epstein, you were MR. TEIN: I’ll certify it. MR. LEOPOLD: For the record, you have to you and off at 5:45 a.m., in 2006, after being out

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Page 113 1 involuntarily admitted into a juvenile educational 2 facility; isn’t that right? 3 A. Did you say involuntarily? 4 Q. Yes. 5 A. No. I was willing to go. I — duly said 6 sure. 7 Q. And you went there because you were lying 8 so much, no one could control you; isn’t that correct? 9 A. That’s very incorrect. 10 Q. Now you lie to your parents all the time, 11 don’t you? 12 A. Incorrect. 13 MR. LEOPOLD: Objection. Argumentative. 14 BY MR. TEIN: 15 Q. Sorry? 16 A. Incorrect. 17 Q. The day you went to Epstein’s house you 18 lied to your father about where you were going; isn’t 19 that correct? 20 A. Correct. 21 Q. You admitted to the police that you told 22 your father that you were going shopping, didn’t you? 23 A. Yes. 24 Q. And that was a lie, wasn’t it? 25 A. Yes.

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07/26/17 Page 2789 Public Records Request No.: 17-295

Page 115 1 BY MR. TEIN: 2 Q. Okay. When your counsel that it was there 3 was lack of foundation, you agree with your counsel, 4 right? 5 A. I was like saying, “Yeah, let’s move on,” 6 because there was no point to asking that question. 7 Q. Your father threw out of the house 8 because she was lying, correct? 9 MR. LEOPOLD: Objection. Lack of 10 foundation. 11 Hold on, . Let me just make the 12 objection. 13 Lack of foundation, predicate, calls for 14 speculation. 15 BY MR. TEIN: 16 Q. Answer. 17 A. I’m not my sister. I don’t know. 18 Q. I want to know what you know only. 19 A. I don’t know. 20 Q. You don’t know. That’s your answer? 21 A. Yes. 22 Q. Now your parents filed the police report 23 regarding Mr. Epstein, right? 24 A. Yes. 25 Q. Now your parents are also lying, aren’t

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sor & Associates Reporties ad Trasscripooe. inc.

Page 116
1they?
2A.
Yes.
3Just so the record is clear,
MR. LEOPOLD:
4the father because the mother was up north.
5MR. TEIN:
Don’t testify, Counsel.
6MR. LEOPOLD: So the record is clear, just
7The mother was
the father.
8MR. TEIN: Counsel, don’t coach and
9testify, please.
That’s absolutely improper.
10MR. LEOPOLD:
You just asked the wrong
11question.
12MR. TEIN:
You can’t coach her that way and
13you well know it.
14MR. LEOPOLD:
For the record, it’s the
15father.
He’s remarried, I think on his third
16marriage.
17MR. TEIN:
You cannot it’s absolutely,
18totally against the rules and you know it.
19MR. LEOPOLD:
The natural mother lives in
20Georgia.
21You need to behave yourself,
MR. TEIN:
22lawyer.
23MR. LEOPOLD:
The natural mother lives in
24The father is here locally.
Georgia.
25MR. TEIN:
Stop coaching. Stop talking.

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Page 117 1 You object. You know the rules. You just lectured me about the rules, Counsel. So why don’t you play by the rules? Or only when they fit you? Why don’t you grandstand a little more now. Give us a five-minute speech, Mr. Leopold. MR. LEOPOLD: Are you finished, for the 7 record? MR. TEIN: I’m not talking to you. Do what you want. 10 MR. LEOPOLD: Don’t say anything yet. BY MR. TEIN: 12 Q. your parents — 13 MR. LEOPOLD: Hold it. Don’t say anything yet. Let me — 15 BY MR. TEIN: 16 0. Your parents, who filed the police report are also liars. MR. LEOPOLD: Don’t answer the question. We’re not going to answer until I make the record. I want to put on the record, now that Counsel appears to be finished with his comments for the record, that the previous question was inappropriate, was intentionally misleading. Now you can ask the question. BY MR. TEIN:

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Page 118 1 Q. Your parents, who filed the police report 2 in this case, are also proven liars, aren’t they? 3 MR. LEOPOLD: Same objection. 4 BY MR. TEIN: 5 Q. Aren’t your parents liars? 6 MR. LEOPOLD: Calls for speculation. Lack 7 of predicate. 8 MR. TEIN: Stop coaching. You know what 9 that is, Leopold. 10 MR. LEOPOLD: Calls for speculation. Lack 11 of foundation. 12 THE WITNESS: When you say parents, my mom 13 is not, but sure, yeah, my dad has been to jail 14 for lying. 15 BY MR. TEIN: 16 Q. Your dad went to federal prison for two 17 years for lying, right? 18 A. Correct. 19 Q. Did he tell you it was for a financial 20 fraud? 21 A. Yes. 22 Q. For stealing money from some financial 23 institution? 24 A. Correct. 25 Q. And do you think your father is trying to

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Page 119 1 steal your lawsuit money away from you? 2 Don’t look to your lawyer for the answer. MR. LEOPOLD: You can answer if you know the answer to it. I have no idea. THE WITNESS: Yeah. BY MR. TEIN: 7 Q. And your father filed a lawsuit, the first lawsuit for fifty million dollars against Mr. Epstein without consulting you, correct? 10 A. Correct. 11 Q. And your father had a lawyer file the first lawsuit on your behalf for fifty million dollars against Mr. Epstein without your knowledge, correct? A. Correct. Q. And you don’t trust your father, do you? A. Correct. 17 Q. And you believe he’s trying to manipulate you for his own gain, don’t you? 19 A. Sort of. Q. Well, you know that your mother filed a statement, an affidavit, saying that you don’t trust your father and that you believe he’s trying to manipulate you for his own gain; isn’t that correct? A. Correct. 25 0. You agree with that statement, don’t you?

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Page 120 1 A. Uh-huh. Yes. 2 Q. Do you trust your stepmother? 3 A. My stepmother, no. 4 Q. You think she’s also trying to steal your 5 Epstein lawsuit money away from you, don’t you? 6 A. I would like to clarify something. You 7 keep saying my Epstein lawsuit money. I don’t have any 8 money, and it’s just a lawsuit at the moment. So I just 9 don’t trust her. 10 Q. Okay. You think that your stepmother is 11 trying to take advantage of this lawsuit to try to get 12 money from Mr. Epstein that belongs to you, right? 13 A. Yes. 14 Q. Did your stepmother tell you why she was 15 arrested? 16 A. No. 17 Q. Did your stepmother tell you that she’s 18 ever been arrested? 19 A. No. 20 Q. Did she tell you she was arrested for 21 fraud? 22 A. Never. 23 Q. Did she tell you that she was fired from 24 Hawthorne Aviation? 25 A. No.

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Page 121 1 Q. Did she tell you that she was, fired from 2 Hawthorne Aviation for stealing? 3 A. No. 4 MR. TEIN: Let’s take a break. (Thereupon, a recess was taken.) BY MR. TEIN: 7 Q. before you met Jeffrey Epstein, had you ever had sexual intercourse? A. Yes, yeah. 10 Q. How many times? A. Just a few. Twice. 12 Q. With how many different men? 13 A. Two. Q. How old were they? A. Zack Bryan, being one year older than me, and then the other person was two years older than me. Q. What was his name? A. Ryan Ortell. Q. How old were you when you first had sexual intercourse? 21 A. 14. Q. How many — before you met Epstein, how many different men had you had any type of sexual activity with? A. Just those two.

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Page 122
1Are you saying you never kissed a man other
Q.
2than those two?
3Objection to the form of the
MR.
LEOPOLD:
4question.
5I had kissed people
Yes,
THE WITNESS:
6before.
7BY MR. TEIN:
8Before you met Epstein,
had you ever had
Q.
9oral
sex?
10A.
No.
11Ever in your life,
have you exchanged sex
Q.
12for something of value?
13No.
A.
14We’re done.
MR. TEIN:
15II, okay.
THE WITNESS:
16We’ll read.
LEOPOLD:
MR.
17I don’t
have any
MS. BELOHLAVEK:
18questions.
Thank you.
19Before we go off
the record,
MR.
LEOPOLD:
20it’s
my understanding Mr. Goldberger can
21correct
the record but we have stipulated
that
22color copies of the documents that
were identified
23for identification
certainly
will
be attached
to
24the deposition
and counsel will
be taking the
25photographs across street
so that
they can be

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1laser color copied so that we have a.copy, and I’m
2assuming he’ll get a copy to the court reporter,
3too, to attach, actually a certified copy to the
4deposition.
5MR. GOLDBERGER:
Done.
6MR. LEOPOLD: That’s if you agree to that.
7If not, then I want to pull each one out and put
8exhibit labels on them, which we should do before
9we leave.
10MR. GOLDBERGER:
We’re not going to do
11I’ll have copies sent to the court
either.
12reporter and she can attach them to the
13deposition.
14MR. LEOPOLD: So you’re not going to agree
15to what we talked about during the break then.
16MR. GOLDBERGER:
I’m not quite sure what
17Let me finish.
your asking me to do.
18That’s fine.
MR. LEOPOLD: Okay. Sure.
19If you want me to
MR. GOLDBERGER: Okay.
20go over to Ms. Belohlavek’s office and make copies
21and then I’ll give those to the court reporter,
22fine.
All I’m saying is that I would avoid that
23process.
I would send copies to the court
24But if it will make you happier
reporter.
25MR. LEOPOLD: I’m not?

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1MR. GOLDBERGER: Let me finish.
2MR. LEOPOLD:
I’m not interrupting now.
3MR. GOLDBERGER: But if it will make you
4happier if I go over to Ms. Belohlavek’s office
5and make a copy of those photos that were part of
6this deposition and then I’ll give them to the
7court reporter, I’ll be happy to do it.
8MR. LEOPOLD:
I trust you implicitly,
9however you with to do it. However, the
10documents, before they leave this room, need to
11have an exhibit sticky on them with the
12appropriate
13MR. GOLDBERGER: Want to go get some? We
14don’t have any.
15I will do that.
MR. LEOPOLD:
Excuse me.
16You can’t do
Let me finish the record, please.
17She’s going to stroke
that to the court reporter.
18out.
You can’t do that.
You have to let me
19MR. TEIN:
Finish your sentence, Ted. You
20are the most long-winded lawyer I’ve ever seen in
21my life.
Finish your sentence.
22MR. LEOPOLD: Jack, tell him not to raise
23his voice, please.
24MR. TEIN:
Finish your sentence.
Is there
25going to be a period at the end of the sentence or

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1 is it just going to be comma after comma after 2 comma?

3 Go ahead, lawyer.

4 MR. LEOPOLD: All right. The exhibits, I 5 can’t prevent you from taking them, but I will 6 object and I will be bringing it to the court for 7 sanctions. You cannot take the exhibits out of 8 the room without them being marked. I want them 9 marked, because you cannot identify in the record 10 what was used. And with all due respect to 11 Mr. Goldberger, I do not — the way this 12 deposition is going, I do not want to rely on 13 Counsel from Miami to mark the appropriate 14 exhibits. I will not do that. I cannot prevent 15 you from taking them. But if you do, I will be 16 bringing the matter to the court with appropriate 17 sanctions, because that is improper. That is 18 improper. When you use something in a deposition, 19 they are to be marked. And you have refused to do 20 that throughout for what ever reason. 21 MR. TEIN: You’re wrong. Finish your 22 sentence because you’re talking about something 23 you have no idea. 24 Every single one is marked, Ted. Every

25 single one is already marked. But you want to

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Reporting and lransctipta Id<

Page 126
1Ever single one is
argue about everything.
2already marked.
Isn’t that silly, Ted?
3MR. GOLDBERGER: Thirty years of doing this
4and I have never had an argument over this.
5MR. TEIN:
You’ve made Ted, you are
6obstructionist, you are a liar.
You have lied and
7misrepresented things, for the record.
You are
8grandstanding.
9MR. LEOPOLD:
You need to back up.
10No, no. I’m going to finish.
MR. TEIN:
11MR. LEOPOLD:
You can finish, but don’t
12hover over me.
13MR. TEIN:
No one is hovering over you.
14Stop trying to make a lying record.
15Let me say something else.
16Don’t you dare threaten me with sanctions,
17after you lied in a letter to my co-counsel about
18the fact be quiet. Be quiet and let me finish.
19You lied in a letter to my co-counsel,
20Mr. Leopold, in which you said it was a
21complete and utter lie that you were
22unavailable this morning because you had a
23hearing. That was a lie.
I have never seen a
24lawyer deign to do something like that.
25So you will get the ex be quiet.
Let

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Page 127 1 finish. You behave. 2 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 — 8 MR. LEOPOLD: Don’t point your finger at me. MR. TEIN: Mr. Leopold, let me finish. MR. LEOPOLD: Don’t raise your voice either. MR. TEIN: Mr. Leopold — 14 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

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Page 128
1of issues in this case. We’re going to have lots
2of reasons to disagree.
3I’m going to take it over now and I’m going
4to make copies and I’m going to give them to
5Ms. Consor. If you want to go find some exhibit
6labels and put some exhibit labels on it, be my
7guest.
But that’s what I’m offering to do.
8THE WITNESS:
Let me say two things,
9because I am happy to always disagree, and with
10you, I have no problem; we could always do it
11professionally.
I have not problem.
12I want to say two things so the record is
13very clear.
14Since for whatever reason I have not been
15able to look at exhibits, because they have been
16refused to have been shown to me
17MR. TEIN: That’s a lie.
18MR. LEOPOLD: Jack, if you represent
19that the documents have the appropriate exhibit
20numbers or some identifying markings, 25, 30.000,
21whatever they may be, then you can take them, make
22copies, send me a copy, make sure the court
23reporter gets a copy and then send me a bill for
24my copies, that’s fine.
I didn’t know that they
25are marked that way because I haven’t been able to

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nsor & Associates Refer:intl. and Transcript:a. Inc

1 2 3 4 Page 129 look at them. MR. GOLDBERGER: They are barcoded, and the number that we’ve made reference to in the deposition coincides with the barcoding. 5 MR. LEOPOLD: That’s fine. Eight by eleven 6 color laser copies are fine. 7 MS. BELOHLAVEK: The State Attorneys Office 8 is not going to charge anybody for color copies I 9 print out. 10 MR. LEOPOLD: That’s fine. He’s going to 11 take them back to his office. 12 Secondly — and I will be more than happy 13 to do it, because it sounds like you all know more 14 about it than I — but I’m happy to get affidavits 15 from Mr. Pincus, Judge Stern, everybody else about 16 what happened with this hearing today, because I 17 know very little about it. But my representations 18 are what they are. 19 MR. GOLDBERGER: They stay — 20 MR. LEOPOLD: Let me just finish for the 21 record. 22 My representations or comments about what 23 happened, representation about this hearing this 24 morning, I know very little about it. I — 25 MR. GOLDBERGER: I’ll take your word on

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* Reportiag and Transcriptiaa, lac sor & Associates Page 130 1 that. 2 MR. LEOPOLD: No, no, no. I just put it on 3 the record. I will get an affidavit — I’m 4 assuming it sounds like you need it — from Mr. 5 Pincus. I have no clue about what happened and 6 why it was canceled. All I was told when I was 7 out of town yesterday was that the hearing this 8 morning was cancelled. 9 MR. GOLDBERGER: I’ll take your word for 10 it. 11 MR. LEOPOLD: If you want an affidavit, 12 I’ll get it for you. 13 MR. GOLDBERGER: It’s a personal issue for 14 me because I had to disrupt a vacation and if it 15 was done just because it wasn’t convenient for 16 you, then I’m offended by that. But if you’re 17 telling me that it was planned and it didn’t 18 happen, I’ll take your word for it. 19 MR. LEOPOLD: I am more than happy to get 20 you an affidavit, because I don’t know the reason 21 why it was canceled other than the fact that I’m 22 assuming since my deposition was taken for four 23 hours on Monday for preparation for the hearing 24 today, for whatever reason it was canceled, I am 25 told it is being re-noticed. Why it was canceled,

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Page 131
1I have no idea, but if your co-counsel-
wishes an
2affidavit to that effect from Mr. Pincus, I’m more
3than happy to get it. But I don’t know the reason
4why it was canceled.
5MR. TEIN:
But what I do
I don’t need it.
6take issue with is regardless of why it was
7canceled, you owed us the courtesy of saying, You
8know what? We can start earlier this morning.
9MR. LEOPOLD: I owe you nothing.
10MR. TEIN:
I don’t care.
Don’t interrupt
11me.
12Because Jack canceled his vacation plans
13because of you.
14MR. GOLDBERGER: That’s all right, that’s
15all right.
16MR. TEIN:
And you’re selfish. And this
17deposition is over. Good-by Mr. Leopold.
18MR. GOLDBERGER:
You can go off the record.
19
20
21
22
23
24
25

07126/17 Page 2806 Public Records Request No.: 17-295

sor & Associates
Reporting sad Traniatiptica, lac.
Page 132
1CERTIFICATE
2
3
4The State of Florida,
5County of Palm Beach.
6
7I hereby certify that I have read the
8foregoing deposition by me given, and that the statements
9contained herein are true and correct to the best of my
10knowledge and belief, with the exception of any
11corrections or notations made on the errata sheet, if one
12was executed.
13
14
15day of
Dated this
, 2008.
16
17
18
19
20
21
22
23
24
25

sor & Associates Reporting ad Trunciiption. lac.

Page 133 1 DATE: February 25, 2008 2 TO: c/o Lana Belohlavek 3 Office of the State Attorney 401 N. Dixie Highway 4 West Palm Beach, Florida 33401 5 IN RE: STATE OF FLORIDA -V- JEFFREY EPSTEIN CASE NO.: 2006 CF09454AXX 6 Please take notice that on Wednesday, the 7 20th of February, 2008, you gave your deposition in the above-referred matter. At that time, you did not waive 8 signature. It is now necessary that you sign your deposition. 9 Please call our office at the below-listed number to schedule an appointment between the hours of 10 9:00 a.m. and 4:30 p.m., Monday through Friday. 11 If you do not read and sign the deposition within a reasonable time, the original, which has already 12 been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your 13 signature, sign your name in the blank at the bottom of this letter and return it to us. 14 Very truly yours, 15 Judith F. Consor, FPR 16 Consor & Associates Reporting and Transcription 1655 Palm Beach Lakes Boulevard, Suite 500 West Palm Beach, Florida 33401 I do hereby waive my signature: 17 18 19 20 cc via transcript: JACK A. GOLDBERGER, ESQ. 21 LANNA BELOHLAVEK, ESQ. MICHAEL R. TEIN, ESQ. 22 THEODORE J. LEOPOLD, ESQ. file copy 23 24 25

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sor & Associates Reporting rod Transcription, lac. Page 134 ERRATA SHEET 2 IN RE: STATE-V-JEFFREY EPSTEIN DEPOSITION OF: TAKEN: February 20th, 2008 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE if LINE I CHANGE REASON Please forward the original signed errata sheet to this office so that copies may be distributed to all parties. Under penalty of perjury, I declare that I have read my deposition and that it is true and correct subject to any changes in form or substance entered here. DATE: SIGNATURE OF DEPONENT:

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sor & Associates
Reporting sad Transcripoon. Inc.
Page 135
1THE STATE OF FLORIDA, )
2COUNTY OF PALM BEACH. )
3
4
5I, the undersigned authority, certify that
6personally appeared before me on the 20th
7of February, 2008 and was duly sworn.
8
9WITNESS my hand and official seal this 25 day
10of February, 2008.
11
12
13
14
Judith F. Consor, FPR
15Notary Public - State of Florida
16
17
18
19
20
21
22
23
24
25
Page 136
1CERTIFICATE
2
The State Of Florida, )
3County Of Palm Beach. )
4
5I, Judith F. Consor, Court Reporter and Notary
Public in and for the State of Florida at large, do
6hereby certify that I was authorized to and did
stenographically report the deposition of
7that a review of the transcript was requested; and that
the foregoing pages, numbered from 1 to 131, inclusive,
8are a true and correct transcription of my stenographic
notes of said deposition.
9
I further certify that said deposition was
10taken at the time and place hereinabove set forth and
that the taking of said deposition was commenced and
11completed as hereinabove set out.
12I further certify that I am not an attorney or
counsel of any of the parties, nor am I a relative or
13employee of any attorney or counsel of party connected
with the action, nor am I financially interested in the
14action.
15The foregoing certification of this transcript
does not apply to any reproduction of the same by any
16means unless under the direct control and/or direction of
the certifying reporter.
17
DATED this 25 day of February,
18
19
20Judith F. Consor, Court Repo
Florida Professional Reporter
21
22
23
24
25

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Record, 2005-12-23

Other records

FOIA Records: Florida · Dec. 23, 2005

I 07/26/17 Page 2609 Public Records Request No.: 17-295 DA - NOTICE TO RENTERS 36173 s insurance primary: The valid and collectible liability insurance and personal injury protection insurance of any authorized rental or driver is primary for the limits of liability and personal injury coverage required by ss.324.021 (7) and 627.736, Florida Statutes. to return rental Vehicle: Failure to return rental property or equipment upon expiration of the rental period and failure to pay all s due (including costs for damage to the property or equipment) are prima facie evidence of intent to defraud, pu…