Draft: efta00234324

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	Page 75
1	Because Mr. Epstein never came to your Q.
2	dad's house, correct?
3	Correct. A.
4	And no one who worked for Mr. Epstein ever Q.
5	did something to your dad's tires, did they?
6	Objection. Lack of MR. LEOPOLD:
7	foundation, predicate.
8	Don't guess.
9	BY MR. TEIN:
10	It's not true that Mr. Epstein almost Q.
11	killed your father, is it?
12	Objection. Asked and MR. LEOPOLD:
13	answered, lack of foundation, predicate.
14	BY MR. TEIN:
15	You can answer.
16	A. No.
17	Now you told the police that you didn't Q.
18	know who was in the car with you and IIIIIII on the day
19	you went to Epstein's house, didn't you?
20	Yes. A.
21	And that was a lie, wasn't it? Q.
22	It's the truth. A.
23	You told the police that there was someone Q.
24	in the car next to you and you specifically said you
25	didn't know her name, right?

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Reporting and Transcription. Inc¶

	Page 76
1	I do not know her name. Correct. A.
2	You said, "I don't know her name, but she Q.
3	was dark like a Spanish girl." Those were your words,
4	right?
5	Yes. A.
6	Asked and Objection. MR. LEOPOLD:
7	answered.
8	BY MR. TEIN:
9	Who was in the car that day with you and Q.
10
11	Again, I do not know. A.
12	It was your good friend Q.
13	wasr't it?
14	I don't know a A. No.
15	You lied to the police about who was in the Q.
16	didn't you? car with you and I el ,
17	Incorrect. A.
18	Let me ask you some questions about who you Q.
19	All right? may have spoken to about this case.
20	Go ahead. A.
21	Did you speak to your twin sister Q.
L2	Not in detail, but of course she knows; A.
23	she's family. And yes.
24	What's her e-mail? Q.
25	I don't think she has an e-mail. A.

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

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

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	Roar:mi.: and Transcripn car Inc.
	Page 79
1	What apartment number is it? Q.
2	I couldn't tell you. A.
3	When was the last time you went there? Q•
4	Just visited this past weekend. That's the A.
5	first and last time I went there.
6	Have you spoken Q. How about
7	to him about your case?
8	We no longer speak. No. A.
9	Actually, we What's his phone number? Q.
	already have his phone number and e-mail.
	Have you ever How about MEW
	spoken to her about your case?
13	I don't know an A.
14	Have you ever met Q.
15	But just to let you know, I don't No. A.
16	If you have pictures of there faces I reaLly know names.
17	couLd tell you.
18	Let me see if I can refresh All right. Q.
19	your memory.
20	Okay. A.
21	Does it refresh your memory that Q.
22	is the other girl who made allegations about Epstein, but
23	refused to show to the Grand Jury when she had to testify
24	about them under oath?
25	I have no knowledge of any other No, sir. A.

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

' 12¶

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Page 81¶

		& Associates nsor Roporuns anti Trtnscripuca.lnc
1	0.	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?

Q. You didn't want to see that happen, right? A. No.¶

Q. So you're saying you don't know a¶

MR. LEOPOLD: Objection. Asked and¶

answered.¶

A. Yes.¶

BY MR. TEIN:¶

Q. Does it refresh your memory that he was somebody who had gone to jail for drugs and car theft? A. No, sir.¶

Q. Someone who knowsillill, A. No. Q. You don't know if he met with Detective¶

Recarey?¶

A. No, sir. Q. How about Me A. Yes, I remember. I know who that is.¶

Q. Did you ever speak tol about what happened at Mr. Epstein's house?¶

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

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

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	Page 84
1	I didn't even know he gave money to my dad. A.
2	eir What do you know about the deal that Q.
3	IIIIIIIIIIhas with your father?
4	I only know they spoke on the telephone A.
5	I don't know anything else. once.
6	Q. When was that?
7	This was a while ago, a year or two A. or a
8	I honestly don't know. year ago.
9	Did 11.111/ the Vanity Fair Q.
10	reporter, offer any money to your father?
11	I don't know. A.
12	Did al the Vanity Fair Q.
13	reperter, give you any money?
14	No, sir. A.
15	Did he offer you any money? Q.
16	Never spoke to him. A. No, sir.
17	What reporters have you spoken to? Q.
18	A. Zero.
19	Q. What about your family members? What
20	reporters have they spoken to?
21	The whole Palm Beach County, obviously, as A.
22	you can see in that newspaper.
23	Tell me -- let's go through each one that Q.
24	Other than the Vanity Fair reporter, you remember. IIIIIIF
25	1.111what other reporters have any member of your

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Page 85 family spoken to? A. I don't know. And I know my mom has spoken to zero. My sister spoke to zero. My father and steomother, 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? MR. LEOPOLD: She just told you. She just answered -- 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 86
1	But you are misrepresenting the MR. TEIN:
2	record and you are grandstanding for your client
3	And you know how to So be quiet. and it's wrong.
4	Otherwise stop make an objection. Make it.
5	talking.
6	BY MR. TEIN:
7	Q.
8	Excuse me. MR. LEOPOLD:
9	If you want to leave the MR TEIN:
10	But you'll be back here. deposition, leave.
11	If I could just MR. LEOPOLD: Excuse me.
12	make the record, instead of interrupting me,
13	That's what we do professionally. please.
14	I'm certainly not being There's a recorder here.
15	I'm going to make the record. obstructionist.
16	But we're going to act with some semblance of
17	professionalism, hopefully, by all parties in the
18	room. That goes to me, that goes to your
19	co-counsel sitting behind you and next to you, the
20	court reporter and everyone else in the room.
21	Everyone is entitled to that.
22	You've asked a question. She answered the
23	question fully and she's not going to be harassed
24	because you don't like the answer. If you want to
25	follow up --

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

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	Page 88
1	answered.
2	THE WITNESS: No.
3	BY MR. TEIN:
4	spoken to any Has your mom's husband Q.
5	reporters?
6	A. No.
7	Has your mom's husband Illireceived any 0.
8	money from reporters?
9	No. A.
10	Are you sure you don't know Q.
11	Asked and MR. LEOPOLD: Objection.
12	answered.
13	THE WITNESS: I'm positive.
14	BY MR. TEIN:
15	I'll try again to refresh your memory. Q.
16	Okay. A.
17	Does it refresh your memory that she had Q.
18	been arrested for drugs and was cooperating with
19	Detective Recarey against Epstein to get herself a better
20	deal?
21	I don't know who she is. No. A.
22	Have you spoken to anyone else who's been Q.
23	at Epstein's house?
24	No. A.
25	Q. Without telling me what was said -- I don't

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	Page 89
1	wart to know about any conversations with any lawyers,
2	okay --
3	A. Uh-huh.
4	did you or your parents speak to any Q.
5	other law firms besides Mr. Herman and Mr. Leopold's law
6	firms?
7	A. No.
8	Now without telling me about anything that Q.
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	Does family court matter? A.
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	Did you talk about this deposition, about Q.
17	what would happen, with anybody?
18	A. Yes.
19	Q. Don't tell me what was said.
2D	A. Okay.
2]	Q. I'm not asking that. I don't want to know
22	that.
23	A. Okay.
24	Who prepared you for today's deposition? Q.
25	Mr. Leopold. A.

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		Page 90
1	Q.	Anybody else?
2	A.	No.
3	Q.	When did you meet with Mr. Leopold to
4		prepare for today's deposition?
5	A.	This morning.
6	Q.	And how long did that meeting last?
7	A.	Until it started.
8	Q.	Now you told me that you previously had
9		read the police reports in this case?
10	A.	Yes.
11	Q.	Have you read your statement that you gave
12	to the police?
13	A.	Yes, sir.
14	Q.	And in what form was that statement?
15	A.	What do you mean?
16	4.	Was it in the form of a police report or a
17	transcript?
18	A.	What's the difference?
19	Q.	A transcript has questions and answers on
23	it.	A police report is just typed out narrative.
21	A.	Oh, it's a police report.
22	Q.	And when did you read the police report?
23	A.	A few days ago. I overread it a few days
24	ago.
25	Q.	Had you read it before that?

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	Page 91
1	A. No.
2	Now you told me -- again, I don't want to Q.
3	know what was said.
4	Oh-huh. A.
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	Gee, like, like five days ago, four days A.
11	ago.
12	So you're aware that Mr. Leopold told us Q.
13	that he could not start the deposition this morning
14	because he had a court appearance, correct?
15	Don't answer that question. MR. LEOPOLD:
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 :hat 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	When did you listen to that statement? Q.
9	This morning. A.
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
1	When was the last time you spoke with Q.
2	officers of the Palm Beach Police Department?
3	A while ago. I'd say a year ago. A.
4	A year ago? Q.
5	Maybe a year and a half. Yeah. A.
6	Do you remember Detective Q.
7	No. A.
8	Do you remember Detective Q.
9	Pagan?
10	Yes. A.
11	How many times have you spoken to Detective Q•
12
13	She was the only one I spoke to about this A.
14	until for some reason she wasn't on the case anymore.
15	When was that? Q.
16	The first meeting I ever had was with her A.
17	and then I think like I met with her like 10 times or 12
18	times or something like that, and then I didn't get
19	another investigator questioned me after that.
20	And who was that? Q.
21	I don't remember. A.
22	And what type of questions did they ask Q.
23	you?
24	The same. A.
25	The same questions all over again? Q.

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	Page 95
1	I'd have to say like a year and a half ago, A.
2	It was a long time ago. a year ago.
3	(Discussion held off the record.)
4	Tell me the last answer, please. MR. TEIN:
5	(Thereupon, a portion of the record was read
6	by the reporter.)
7	BY MR. TEIN:
8	And who was present when the FBI spoke to Q.
9	you at your father's house?
10	My stepmother was there, but she wasn't A.
11	around. She made herself like do other things.
12	And how many FBI agents were there? Q.
13	I think four. A.
i4	And you don't remember any of their names? Q.
15	No, sir. A.
16	And were there any lawyers there? Q.
17	Not that I know of. A.
18	And none of them gave you their cell phone O.
19	numbers?
20	No. A.
21	And the last time you spoke to the FBI was Q.
22	a year and a half ago?
23	It was a while ago. A.
G4	MR. LEOPOLD: Objection. Asked and
25	answered.

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

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

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

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nsor & Associates error:inc end iranscrtpann. Inc¶

	Page 101
1	Q. He's the one grabbing towards the groin
2	area of
3	A. Yes.
4	Q. And there's three other men in the photo.
5	What are their names? The one on the left with the hat?
6	(phonetic). A. That's
7	Q. Smiling?
8	A. Yes.
9	Q. Who's the one kissing --
10	MR. LEOPOLD: Don't interrupt. Let her
11	finish the record. She's testifying.
12	MR. TEIN: I know you don't like this
13	picture, my friend.
14	MR. LEOPOLD: The picture is fine.
5	BY N.R. TEIN:
16	Q. Who's the one with the hat?
17	MR. LEOPOLD: Stop, No. Hold on.
18	You have to let the witness finish her
19	answer. She was in the process of explaining and
20	you cut her off.
21	Please finish what you were saying and then
22	Counsel can ask you whatever he wishes after that.
23	THE WITNESS: Okay. This guy --
24	MR. LEOPOLD: Just make it so the record is
25	clear who you're referring to.

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nsor & Associates Kollar:ins and lranscripurn, Inc. 1 2 3 BY MR. TEIN: 4 O. Page 102 THE WITNESS: -- on the far left is a He's the one whose head is near the groin 5 of IIIIIIIIIIIIIIIIright? 6 7 Q. And in the middle there's a man smiling. 8 Who's that? 9 A. That's 10 Q. And who's the one in the red hat, kissing? 11 A. That's (phonetic). 12 Q. Let me stop you for a second. Are you 13 done? 14 15 16 A. Yes. A. Yes, I'm done. Q. Who is A. My sister's friend. Well, she's a mutual 17 friend, but more my sister's. 18 Q. What is her last name? 19 A• 20 Q. Spell that. 21 A. I don't know how to -- 22 Q. Have you spoken to her about this case? 23 A. No. 24 Q. Who's 25 A. My sister's friend. I don't really speak¶

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¶

¶

Ph. 561.682.0905 - Fax. 561.682.1771¶

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

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126 e1616¶

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sor & Associates Reporting and Transcription, Inc¶

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

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RoportmE and "I ranscrigraem, bc.¶

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

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nsor & Associates Raparti top and Tninscripnon. Inc.¶

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

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nsor & Associates Re/wining nail lransetiptum, Inc¶

			Page 108
1	A.	Yes.
2	Q.	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 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
12	correct?
13	A.	Yeah.
14	Q.	You lie about your age in order to conceal
15		something about your relationship with
16	isn't that correct?
17	A.	No.
:8	Q.	22 years old, isn't he? IIIIIIII
19	A.	Yes.
20	Q.	a firefighter with the Palm And
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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nsor & Associates Reprint np had Transuiptiam,¶

		Page 109
1	O.	Well --
2		MR. LEOPOLD: Just answer the question,
3	IIIIIIIIII
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.	I met everybody in there. Yes.
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 thatIll'Illis 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:
	Q.	You can answer the question.
19	A.	No.
20	Q.	Does the Palm Beach Police Department know
21	thatles	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?

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nsor & Associates ileponing and Transcripsion. Inc. Page 110 1 BY MR. TEIN: 2 Q. Does the Palm Beach Police Department know 3 that'll. a member of the Palm Beach Fire Department, 4 is having a sexual relationship with an underage girl? 5 A. I'm guessing no. 6 Q. You lie about your twin sister don't 7 you? 8 MR. LEOPOLD: Objection. Argumentative. 9 BY MR. TEIN: 10 Q. Don't you? 11 A. No. I have never lied for or to a 12 Q. You lie about the fact that she has a drug 13 hab:.t, right? 14 A. No. I would never accuse my sister of 15 having a drug habit. 16 Q. Do you try to conceal the fact that she has 17 a drug habit? 18 MR. LEOPOLD: Objection. Argumentative. 19 BY PR. TEIN: 20 Q. You can answer the question. 21 A. No. My sister does not have a drug habit. 22 Q. You lied when you went to the crack house 23 in Georgia, didn't you? 24 MR. LEOPOLD: Objection. Argumentative. 25 Lack of foundation, lack of predicate.¶

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Ropnning and lranaripnce, Inc¶

	Page 111
1	THE WITNESS: Never -- what did you say?
2	BY MR. TEIN:
3	You lied when you went to the crack house Q.
4	in Georgia, didn't you?
5	Argumentative. MR. LEOPOLD: Objection.
6	Lack of foundation, lack of predicate.
7	BY MR. TEIN:
8	You can answer the question. Q.
9	I have never been to a crack house. A.
10	Who don't you lie to? Q.
11	MR. LEOPOLD: Objection. Argumentative.
12	Don't answer the question.
13	MR. TEIN: Certify it.
14	CERTIFIED QUESTION
15	BY MR. TEIN:
16	You don't lie to IIIIIIIdo you? Q.
17	MR. LEOPOLD: Objection. Asked and
18	answered.
9	Don't answer the question.
20	BY MR. TEIN:
21	Q. You can answer that question. No.
22	MR. LEOPOLD: No. I just told her not to.
23	You've asked that question about five --
24	MR. TEIN: No, I haven't.
25	MR. LEOPOLD: Don't answer the question.

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nsor & Associates Reporthig end Transcri pap. leg¶

	Page 112
1	MR. TEIN: I'll certify it.
2	CERTIFIED QUESTION
3	For the record, you have to MR. LEOPOLD:
4	stop interrupting me because she can't take down
5	both of us talking at the same time.
6	BY MR. TEIN:
7	You tell _the truth, don't you? Q.
8	Excuse me? A.
9	the truth, don't you? Q. You tell
10	A. When it's -- yes, I tellillill'the truth.
11	drug dealer? Q. Who's
12	A. My sister does not have a drug dealer. She
13	lives in Georgia with my mother.
14	Who is the drug dealer who dropped Q. Okay.
15	you and IIIIIIIoff at 5:45 a.m., in 2006, after being out
16	all night, the two of you, using drugs at Palm Beach
:7	Country Estates where your father called the police?
18	A•
19	He's the drug dealer? Q.
20	He is a drug dealer. A.
21	Do you remember Q. 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

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Reporting and 'Franscripzi en, Inc¶

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

nsor Associates Ropnrnns and Tntnscripoon, Inc¶

	Page 114
1	And isn't it true that your father has Q.
2	accused you of lying?
3	All the time. A.
4	Didn't your father throw you out of the Q.
5	house Thanksgiving of this past year because you were
6	lying so much to him?
7	Yes, he did kick me out. No, that's not A.
8	the reasons why.
9	Didn't your father throw your sister Q.
10	out of the house, too?
11	A. Yes.
12	And he threw her out of the house the week Q.
13	after Thanksgivings, right?
14	I don't know the date, but sure. A.
15	Q. Sounds about right?
16	Sure. A.
17	And the reason he threw her out of the Q.
18	house was because she was lying, too?
19	MR. LEOPOLD: Objection. Lack of
20	Calls for speculation. foundation.
21	R. TEIN: BY
22	When your counsel coaches you, you say it's Q.
23	correct, right?
24	I've never been coached. A.
25	MR. LEOPOLD: Objection.

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sor Associates Reprimand Trnsoripmm. the.¶

		Page 115
1	BY MR. TEIN:
2	Q.	When your counsel that it was there Okay.
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 threwillirout of the house
8		because she was lying, correct?
9		Lack of MR. LEOPOLD: Objection.
10		foundation.
11		Hold on, WI 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.
:9	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

sor & Associates Ropnrunfi and Transcription, Inc.¶

		Page 116
1	they?
2		A. Yes.
3		Just so the record is clear, MR. LEOPOLD:
4		the father -- because the mother was up north.
5		Don't testify, Counsel. MR. TEIN:
6		MR. LEOPOLD: So the record is clear, just
7		The mother was -- the father.
8		Counsel, don't coach and MR. TEIN:
9		That's absolutely improper. testify, please.
10		You just asked the wrong MR. LEOPOLD:
11		question.
12		You can't coach her that way and TEIN: MR.
13		you well know it.
14		MR. LEOPOLD: For the record, it's the
15		He's remarried, I think on his third father.
16		marriage.
17		You cannot -- it's absolutely, MR. TEIN:
18		totally against the rules and you know it.
19		The natural mother lives in MR. LEOPOLD:
20		Georgia.
		You need to behave yourself, MR. TEIN:
L2		lawyer.
23		The natural mother lives in LEOPOLD: MR.
24		The father is here locally. Georgia.
25		TEIN: Stop coaching. Stop talking. MR.

nsor & Associates Roporung and lranscti put& lnc¶

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

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Roporting and Trenscription, Inc¶

	Page 118
1	Q. Your parents, who filed the police report
2	in this case, are also proven liars, aren't they?
3	Same objection. MR. LEOPOLD:
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	yea:s for lying, right?
18	Correct. A.
19	Did he tell you it was for a financial Q.
20	fraud?
21	Yes. A.
22	Q. For stealing money from some financial
23	institution?
24	Correct. A.
25	And do you think your father is trying to Q.

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1 2 steal your Page 119 lawsuit money away from you? Don't look to your lawyer for the answer. 3 MR. LEOPOLD: You can answer if you know 4 the answer to it. I have no idea. 5 THE WITNESS: Yeah. 6 BY MR. TEIN: 7 Q. And your father filed a lawsuit, the first 8 lawsuit for fifty million dollars against Mr. Epstein 9 without consulting you, correct? 10 A. Correct. 11 Q. And your father had a lawyer file the first 12 lawsuit on your behalf for fifty million dollars against 13 Mr. Epstein without your knowledge, correct? 14 A. Correct. 15 Q. And you don't trust your father, do you? 16 A. Correct. 17 Q. And you believe he's trying to manipulate 18 you for his own gain, don't you? 19 A. Sort of. 20 0. Well, you know that your mother filed a 21 statement, an affidavit, saying that you don't trust your 22 father and that you believe he's trying to manipulate you 23 for lis own gain; isn't that correct? 24 A. Correct. 25 Q. You agree with that statement, don't you?¶

Reparapp and l'ranscrirynon, Inc¶

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Reporting and Transcription, Inc.¶

	Page 120
1	A. Uh-huh. Yes.
2	Q. Do you trust your stepmother?
3	My stepmother, no. A.
4	You think she's also trying to steal your Q.
5	Epstein lawsuit money away from you, don't you?
6	I would like to clarify something. You A.
7	keep saying my Epstein lawsuit money. I don't have any
8	So I just money, and it's just a lawsuit at the moment.
9	don't trust her.
10	Okay. You think that your stepmother is Q.
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	Did your stepmother tell you why she was 0.
15	arrested?
16	A. No.
17	Did your stepmother tell you that she's Q.
18	ever been arrested?
19	No. A.
20	Q. Did she tell you she was arrested for
21	fraud?
22	Never. A.
23	Did she tell you that she was fired from Q.
24	Hawthorne Aviation?
25	No. A.

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Hanning and Trasaiptico, Inc¶

	Page 121
1	Did she tell you that she was fired from Q.
2	Hawthorne Aviation for stealing?
3	No. A.
4	Let's take a break. MR. TEIN:
5	(Thereupon, a recess was taken.)
6	BY MR. TEIN:
7	you met Jeffrey Epstein, had before Q.
8	you ever had sexual intercourse?
9	Yes, yeah. A.
10	How many times? Q.
11	Twice. Just a few. A.
12	With how many different men? Q.
13	Two. A.
14	How old were they? Q.
15	being one year older than me, A.
16	and then the other person was two years older than me.
17	What was his name? Q.
:8	MEM A.
19	How old were you when you first had sexual Q.
20	intercourse?
21	14. A.
22	How many -- before you met Epstein, how Q.
23	many different men had you had any type of sexual
24	act:.vity with?
25	Just those two. A.

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Ropaninn and Transcription, Inc.¶

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

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	Page 123
1	laser color copied so that we have a copy, and I'm
2	assuming he'll get a copy to the court reporter,
3	too, to attach, actually a certified copy to the
4	deposition.
5	Done. MR. GOLDBERGER:
6	MR. LEOPOLD: That's if you agree to that.
7	If not, then I want to pull each one out and put
8	exhibit labels on them, which we should do before
9	we leave.
10	We're not going to do MR. GOLDBERGER:
11	I'll have copies sent to the court either.
12	reporter and she can attach them to the
13	deposition.
14	So you're not going to agree MR. LEOPOLD:
15	to what we talked about during the break then.
16	MR. GOLDBERGER: I'm not quite sure what
17	Let me finish. your asking me to do.
18	MR. LEOPOLD: Okay. Sure. That's fine.
19	If you want me to MR. GOLDBERGER: Okay.
20	go over to Ms. Belohlavek's office and make copies
21	and then I'll give those to the court reporter,
22	fine. All I'm saying is that I would avoid that
23	I would send copies to the court process.
24	But if it will make you happier -- reporter.
25	I'm not? MR. LEOPOLD:

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1-2¶

	Page 124
1	Let me finish. MR. GOLDBERGER:
2	I'm not interrupting now. MR. LEOPOLD:
3	But if it will make you MR. GOLDBERGER:
4	happier if I go over to Ms. Belohlavek's office
5	and make a copy of those photos that were part of
6	this deposition and then I'll give them to the
7	court reporter, I'll be happy to do it.
8	I trust you implicitly, LEOPOLD: MR.
9	however you with to do it. However, the
10	documents, before they leave this room, need to
11	have an exhibit sticky on them with the
12	appropriate --
13	Want to go get some? We MR. GOLDBERGER:
14	don't have any.
15	MR. LEOPOLD: I will do that. Excuse me.
16	You can't do Let me finish the record, please.
17	that to the court reporter. She's going to stroke
18	You can't do that. You have to let me -- out.
19	MR. TEIN: Finish your sentence, Ted. You
20	are the most long-winded lawyer I've ever seen in
21	Finish your sentence. my life.
22	MR. LEOPOLD: Jack, tell him not to raise
23	his voice, please.
24	Finish your sentence. Is there MR. TEIN:
25	going to be a period at the end of the sentence or

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or it Kenny:Inc end Transcriponm, Inc¶

1 2 3 4 Page 125 is it just going to be comma after comma after comma? Go ahead, lawyer. 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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	Page 126
1	Ever single one is argue about everything.
2	Isn't that silly, Ted? already marked.
3	Thirty years of doing this MR. GOLDBERGER:
4	and I have never had an argument over this.
5	You've made -- Ted, you are MR. TEIN:
6	You have lied and obstructionist, you are a liar.
7	misrepresented things, for the record. You are
8	grandstanding.
9	You need to back up. MR. LEOPOLD:
10	I'm going to finish. MR. TEIN: No, no.
11	You can finish, but don't MR. LEOPOLD:
12	hover over me.
13	MR. TEIN: No one is hovering over you.
14	Stop trying to make a lying record.
15	Let me say something else.
16	Don't you dare threaten me with sanctions,
17	after you lied in a letter to my co-counsel about
18	Be quiet and let me finish. the fact -- be quiet.
19	You lied in a letter to my co-counsel,
20	Mr. Leopold, in which you said -- it was a
21	complete and utter lie -- that you were
22	unavailable this morning because you had a
23	That was a lie. I have never seen a hearing.
24	lawyer deign to do something like that.
25	So you will get the ex -- be quiet. Let me

sor 1 Associates Repornnn and Transcriptonn. Inc¶

	Page 12-;
	1 You behave. finish.
2	Don't point your finger at MR. LEOPOLD:
3	me.
4	MR. TEIN: Be quiet and I won't Listen.
5	have a need to point it at you.
6	Don't point your finger at MR. LEOPOLD:
7	Mr. Leopold -- MR. TEIN:
8	Don't point your finger at MR. LEOPOLD:
9	me.
10	Mr. Leopold, let me finish. MR. TEIN:
11	Don't raise your voice MR. LEOPOLD:
12	either.
13	Mr. Leopold -- MR. TEIN:
14	Jack, do you want to take MR. LEOPOLD:
15	care of this?
16	MR. TEIN: Let me finish my sentence. The
17	exhibits are marked. We are walking out of here.
18	You are someone who misrepresents the
19	It is absolutely atrocious what you do. record.
20	This That is not how a lawyer should behave.
21	You will get your exhibits, deposition is over.
22	Mr. Leopold.
23	MR. GOLDBERGER: I understand what you're
24	saying, Michael, and I understand Ted's position.
25	Just so there's -- we're going to have lots

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

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	Page 129
1	look at them.
2	MR. GOLDBERGER: They are barcoded, and the
3	number that we've made reference to in the
4	deposition coincides with the barcoding.
5	Eight by eleven MR. LEOPOLD: That's fine.
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: He's going to That's fine.
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	They stay -- MR. GOLDBERGER:
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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	Page 130
1	that.
2	I just put it on MR. LEOPOLD: No, no, no.
3	I will get an affidavit -- I'm the record.
4	assuming it sounds like you need it -- from Mr.
5	I have no clue about what happened and Pincus.
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	I'll take your word for MR. GOLDBERGER:
10	it.
11	MR. LEOPOLD: If you want an affidavit,
12	I'll get it for you.
13	It's a personal issue for MR. GOLDBERGER:
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	Why it was canceled, told it is being re-noticed.

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

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

	Page 133
1	DATE: February 25, 2008
2	TO: c/o L
3	Office of the State Attorney
	401 N. Dixie Highway
4	west Palm Beach, Florida 33401
5	STATE OF FLORIDA -V- JEFFREY EPSTEIN IN RE:
	CASE NO.: 2006 CF09454AXX
6
	Please take notice that on Wednesday, the
7	20th of February, 2008, you gave your deposition in the
	At that time, you did not waive above-referred matter.
8	It is now necessary that you sign your signature.
	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
	wittin a reasonable time, the original, which has already
12	beer 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
17	I do hereby waive my signature:
18 19
20
	JACK A. GOLDBERGER, ESQ. cc via transcript:
21	LANNA BELOHLAVEK, ESQ.
	MICHAEL R. TEIN, ESQ.
22	THEODORE J. LEOPOLD, ESQ.
	file copy
23
24
25

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cEnAscl %ket 07/21/2008 Page 58 of 100 mi¶

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	Page 134
1	ERRATA SHEET
2	STATE-V-JEFFREY EPSTEIN IN RE:
	TAKEN: February 20th, DEPOSITION OF:
3	2008
	DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
4	CHANGE REASON LINE # PAGE #
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21	Please forward the original signed errata sheet to this
	office so that copies may be distributed to all parties.
22
	Under penalty of perjury, I declare that I have read my
23	deposition and that it is true and correct subject to any
	changes in form or substance entered here.
24
	SIGNATURE OF DEPONENT: DATE:
25

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	Page 135
1	THE STATE OF FLORIDA, )
2	COUNTY OF PALM BEACH. )
3
4
5	I, the undersigned authority, certify that
6	personally appeared before me on the 20th
7	of February, 2008 and was duly sworn.
8
9	WITNESS my hand and official seal this 25 day
10	of February, 2008.
11
12
13
14	4!
	Judith F. Consor, FPR
15	Notary Public - State of Florida
16
17
8
19
20
21
22
23
24
25

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

STATE COURT PLEADINGS¶

EFTA00234384¶

IN THE CIRCUIT COURT OF THE ISTI-1 JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA¶

cntb3CA 00659400m¶

,IANE DOE, by and through .IANE DOE'S MOTHER as parent and natural guardian,¶

v • JEFFREY EPSTEI Plaintiffs, Defendants. r\3\ COMPLAINT •¶

Plaintiffs, JANE DOE, by and through JANE DOE'S MOTHER as parent and natural¶

guardian of JANE DOE, bring this Complaint against Defendants JEFFREY EPSTEIN.¶

and and state as follows:¶

Parties, Jurisdiction and Venue¶

I. Jane Doe is a citizen and resident of the State of Florida. She is a minor under the age of¶

I8 years.¶

2. Jane Doe'S Mother brings this action as parent and natural guardian of Jane Doe.

3. This Complaint is brought under fictitious names to protect the identity of the Minor

Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a¶

minor.¶

• 4. DefcridanCJelTrey Epstein is a citizen and resident of the State of New York.
• 5. Detention.... is a citizen and resident of Palm Beach County, Florida.
• 6. Defend:in is a citizen end resident of the State of New York

This fax was received by GFI FAXmaker fax server For mole information, visit: http://www gli.com¶

7. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000) exclusive of interest and costs.

g. Venue is proper in this Court under section 47.011, Florida Statutes, because the causes of action brought herein accrued in Palm Beach County, Florida and one or more Defendants resides in Palm Beach County, Florida.¶

Factual Allegations¶

9. At all relevant times, Defendant Jeffrey Epstein was an adult male. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is a miin of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, Florida. The allegations herein concern Epstein's conduct while at his twish estate in Palm Beach.

10. Jpon information and belief, Epstein has a sexual preference and obsession for minor girls. He engaged in a plan, scheme, and/or enterprise in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls or coerced them to engage in prostitution, and then gave them money. In or about 2005, lane Doe, then 14 years old, fell into Epstein's trap and became one of his victims.

I I. Upon information and belief, Jeffrey Epstein carried out Ibis scheme/enterprise and assaulted girls in Florida, New York and on his private island, known as Little Si. James, in St. Thomas.¶

12. An integral player in Epstein's Florida scheme wasaill, an assistant of Epstcin's from New York, Nevi York unc Palm Beach Community College student from Loxahatchee. Florida. They recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan/enterprise, Ms. 'as contacted shortly before or soon after Epstein was at his Palm Beach residence Epstein, a r someone on their behalf directed It bring one or more underage girls to the residence.

Page 2 of 9¶

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Ms. upon information and belief, generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who would be enticed by the money being offered - generally $200 to $300 per "massage" session — and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made This was an important element of Epstein's plan/enterprise¶

13. Epstein's plan. scheme, and/or enterprise reflected a particular pattern and method. Upon arrival at Epstein's mansion, Mr 'ould introduce each victim I a IlpSle in's assistant, who gathered the girl's personal information, including her name and telephone number. Ms /Quid:then bring the girl up a flight of stairs ton bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom. Ms. =would then leave the girl alone in this room, whereupon Epstein would enter wearing only a towel. He would then remove his towel, lay down naked on the massage table, and direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and sexual acts, including masturbation, touching the girl's vagina with a vibrator, or digitally penetrating the girl's vagina.

14. Consistent wit 1 the foregoing plan, scheme, and/or enterprise, M: cruited Jane Doc to give Epstein a massage for monetary compensation. Ms.IMIa rought Jane Doe to Epstein's mansion in Palm Beach. Jane was introduced to vho led her up the flight of stairs to the room with the massage table Ms-set up the message table and laid out message oils and told Jane Doe that Epstein would be in shortly and than left the room. Jane Doe was alone in the room when Epstein arrived. Epstein told her to remove her clothes and left the room. When Epstein returned he was wearing only a towel. He removed his towel, and laid down on his stomach on the message table. Epstein again told Jane Doe remove her clothes. In shock, fear and trepidation, Jane Doe complied, removing her clothes except for her panties and bra. Shortly

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after starting to rub Epstein's back, Epstein told Jane Doe to sit on his hack. Jane Doe, out of fear and trepidation, complied. After a period of time Epstein got up from the table and went behind the door. For several minutes Jane Doc heard loud noises and moans and believes that Epstein was masturbating'. Thereafter Epstein, naked, returned to the message table and laid face up on the table. Epstein than told Jane Doe to continue with the message and told her to sit on top of him. Out of fear and trepidation she complied. As Jane Doc rubbed Epstein's chest Epstein began tc use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane's vagina At this same lime Epstein was masturbating. Upon reaching orgasm Epstein Aot tip from the message table and told Jane Doe to write down her name and phone number and than left the room.¶

15. Jane Doe was then able to get dressed, leave the room and go back down the stairs and into the kitchen. Epstein,' Here wailing for Jane Doe. Epstein paid Jane Doe 5300. Ms was paid $200 by Epstein for bringing Jane to him. Ms Robson brought Jane Doe home.

16. As a result of this encounter with Epstein, the I4-year old Jane Doe experienced confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral.

COUNTI Sexual Assault against Defendant Epstein¶

17. Plaintiff Jane Doe by and through her Mother, as parent and natural guardian, repeats and reallegcs paragraphs I through 16 above.

18. Defendant Epstein toniously assaulted Jane Doc sexually in or about 2005.

19. This sexual assault was in violation of Chapter 800 of the Florida Statutes, recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane Doe. which

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EFTA00234388¶

20. As a direct Lnd proximate result of Epstein's assault on Jane Doc, she has suffered and will continue to sutler severe and permanent traumatic injuries, including mental, psychological and emotional damages.

WHEREFORE, Plaintiff Jane Doc, by and through her Mother, as patent and natural guardian, demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim fur punitive damages pursuant to Florida Law.¶

COUNTII Civil Conspiracy against Defendants Epstein,,¶

21. Plaintiff Jane Doe by and through her Mother, as parent and natural guardian, repeats and realleges paragraphs 1 through 16 above.

22. Defendants Epstein, conspired to subject Jane Doe to the sexual assault of Defendant Epstein.

23. Each of the Defendants commined an overt act in pursuance of this conspiracy Defendant used false pretenses to lure Jane Doe to the home of Defendant Epstein so that Epstein could sexually assault Jane Doc; Defendan=elivered Jane Doe to Defendant Epstein's bedroom so that Epstein could sexually assault Jane Doe, and Defendant Epstein actually committed sexual assault against Jnne Doe.

24. As a direct and proximate result of Defendants' civil conspiracy, Jane Doe has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages

Page 5 of 9¶

WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein,¶

for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend tins Complaint to add it claim for punitive iamages pursuant to Florida Law.¶

COUNT HI Intentional Infliction of Emotional Distress against Defendant Epstein¶

25. Plaintiffs Jane Doe by and through her Mother, as parent and natural guardian, repeat and realtege paragraphs ihrough 16 above

26. Epstein's conduct was intentional or reckless.

27. Epstein's conduct was outrageous, going beyond all bounds of decency.

28. Epstein's conduct caused severe emotional distress not only to lane Doe Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe and her mother.

29. As a dire& and proximate result of Epstein's intentional or reckless conduct, Jane Doe will continue to suffer severe mental anguish and pain.

WHEREFORE, :nric Doe, by and through her Mother, and Jane Doe's Mother, individually, demand judgment against Defendant Jeffrey Epstein for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law. '¶

Page 6 of 9¶

COUNT IV Civil Remedy for Violation of Florida Statute Section 772.103 against Defendants Epstein¶

30. Plaintiffs Jane Doe by and through her Mother, as parent and natural guardian, repeat and :college paragraphs I through 16 above.

31. Defendants participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statute section 772.103(3)-(4).

32. Defendants engaged in this pattern of criminal activity by engaging in at least two of the following incidents of criminal activity with the same or similar intents, results, accomplices, victims, and methods of commission within a 5 year period:

• a. Procuring for prostitution, or causing to be prostituted, any person who is under the age of III years in violation of Florida Statute section 796.03;
• b. Soliciting, inducing, enticing, or procuring another to commit prostitution, lewdaess, or assignation in violation of Florida Statute section 796.07(2)(0, or aiding, abetting or participating in such acts in violation of Florida Statute section 796.07(2)(h);
• e. Knowingly recruiting, enticing, harboring, transporting, providing, or obtaining by' any means a person, knowing that force, fraud, or coercion will be used to cause that person to engage in prostitution in violation of Florida Statute section 796.C45; or
• d. Forcing, compelling, or coercing another to become o prostitute in violation of Florida Statute section 796.04.

33. Under Defendants' plan, scheme and enterprise, Defendant Epstein paid Defendant to repeated y find and bring him underage girls, who were delivered to Epstein by

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Defendant, in order for Epstein to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and/or lewdness.¶

34. PlaintiffJane Doe was the victim of Defendants' plan, scheme and enterprise. Defendant _took Jane Doc to Epstein's home under the pretense that .lane Doc would be paid to give Epstein a massage. Defendant delivered Jane Doe to a room with a message table and told twat Epstein would be in shortly. Jane Doe was alone in the room when Epstein arrived. Epstein told her to remove her clothes and left the room. When Epstein returned he was wearing only o towel. He removed his towel, and laid down on his stomach on the message table. Epstein again told Jane Doe remove her clothes. In shock, fear and trepidation, Jane One complied, removing her clothes except for her panties and bra. Shortly after stoning to rub Epstein's back, Epstein told Jane Doe to sit on his back. Jane Doe, out of fear and trepidation, complied. After a period or time Epstein got up from the table and went behind the door. for several minutes Jane Doc heard loud noises and moans and believes that Epstein was masturbating. Thereafter Epstein, naked, returned to the message table and laid face up on the table. Epstein than told Jane Doe to continue with the message and told her to sit on top of him. Out of fear and trepidation she complied As Jane rubbed Epstein's chest Epstein began to use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane Doe's vagina. Ai tits same time, with his other hand, Epstein was masturbating. Upon reaching orgasm Epstein got up from the message table and cold Jane Doe to write down her name and phone number and :huh left the room

35. Jane Doe was then able to get dressed, leave the room and go back down the stairs and into the kitchen. Epstein,' -I were waiting for Jane Doe. Epstein paid Jane Doc

Page 8 of 9¶

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$300. Ms. vas paid $200 by Epstein for bringing Jane to him. Ms.Mirought Jane¶

WHEREFORE, Plaintiff Jane Doe, by arid through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein,¶

for compensatory damages, treble damages under Florida Statute section T72.I 04, costs and attorney's fees under Florida Statute section 172. 104, and such other and further relief as this Court deems just und proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law,¶

JURY TRIAL DEMAND¶

Plaintiffs demand a jury trial in this action.¶

Doe home.¶

Dated: March 6 2008 Respectfully submitted, RICCI—LE 2925 PGA Palm Bea Phone: 56 Fax: 5 8 LEOPOLD 705608¶

Page 9 of 9¶

¶

DATED THIS day of March, 2008.¶

RICCI-LEOPOLD, P.A 2925 PGA Blvd. Suite 200 Palm Beau Phone: (5 Fax: ( 0 J POLD 'lorida Bar No. 05 08¶

170 of 316¶

IN THE CIRCUIT COURT OF THE • Ism JUDICIAL. CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA¶

CASE NO: 50 2008 CA 006596 XXXX MB AB¶

JANE DOE, by and through JANE DOE'S MOTHER, as parent and natural guardian,¶

Plaintiff,¶

vs.¶

Mit		and
	Defendants.

¶

SUMMONS¶

PERSONAL SERVICE ON A NATURAL PERSON¶

TO DEPENDANT:¶

JEFFREY EPS•fEIN 457 Madison Avenue 4th Floor New York, New York¶

IMPORTANT¶

A lawsuit has been tiled against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further wanting from the Court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book).¶

If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/ Plaintiffs Attorney" named below.¶

Thus lax was received by GFt FAXmaker fax server. For more information, visit. httpilvivnie.ge.com¶

Case 9:08-ov-80804-Ki,J1A uiCto,9nurnerd¶

nIram¶

"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable lime prior to any proceeding, contact the Administrative Office 5 North Dixie Highway, Room 5 2500, West Palm Bench, FL 33401, telephone ( via Florida Relay Service".¶

THEODORE J. LEOPDLD, ESQUIRE RICCI-LEOPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410¶

THE STATE OF FLORIDA¶

TO EACH SHERIFF OF THE STATE' You arc commanded yt serve t is Stun ons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). e in e DATED ON By: Deputy Clerk SANDRA CU CIRCUIT COURT¶

I MPORTANT¶

Listed ha sido demanded° legalmcnte. Tiene 20 Dias, contados a pertir del recibo du este notification, par' contester la demanda adjunta, pr escrito, y presentarla ante este tribunal. Una Ilamada telefonica no lo protegera. Si used desea que el tribunal considere su defense, debt presenter su respuesta por escrito, incluyendo el numbero del cast) y los nombres de las panes interesadas. Si usted no contesta la demanda a tiempo, pudiese perdcr cl etiso y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen otros requisitos legates. Si lo desea, puede usted consulter a un abogudo inrnediatemente. Si no conoce a un ahogado, pucdc llama a una de las oficinas de asistencia legal que aparecen en la gull telefonica.¶

Page 2 of 3¶

This tax was received by GFI FAXmaker fax server. For more information, visit http.//www gfi. corn¶

Flonda Relay Service".¶

Si desea responder a la demands por su cuenta, al misino tiempo en que presenta su respuesta ante el tribunal, debera usted envier por correo o entregar rna copia de su respuesta a la persona denominada abajo como "Plaintiff/PlaintifFs Attorney" (Demandante o Abogado del Demandante).¶

"De acuerdo con el Acto 6 Decreto de los Americansos con Impedimentos, Inhabilitados, personas en necesidad det servicio special para participer en estc procedtmiento debernn, dentro dc un limp° razonable, antes de cualquier procedimiento, ponerse en contact° con la officina Administratativa -' ^^c wn n pik/ }liehway. cificina 5.2500, West Palm Beach, FL 33401, Teleran° is¶

IMPORTANT¶

Des poursuites judiciurcs ant ete entreprises contre vous Vous avez 20 jours consecutifs a partir de la dale de ('assignation dc tetre citation pour deposer une reponse ecrite a la plainte citiointe cupres de es tribunal. Un simple coup de telephone est insuffisant pour vous proteger. Vous des oblige de deposer votre reponse ecrite, avec mention du numera de dossier cidessus et du nom des panics nominees ici, si vous souhaitez que le tribunal entende votre cause. Si vous ne dcposez pas votre reponse ecrite dans le relit' requis, vous risquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre saisis par la suite, sans aucun preavis ulicricur du tribunal. II y a d'autres obligations juridiques et vous pouvez requerir les services immediate d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez telephoner a tin service de reference d'avocats ou a un bureau d'assistance juridique (figuran a Pannuture de telephones).¶

Si vous choisis.sex de deposer vous-meme une reponse ecrite, il vous faudni cgalement, en meme temps que cette formalize, faire parvenir ou expedier une topic de votre reponse ecrite au "Plaintift/Plaintin's Attorney" (Plaignant ou a son avocet) nomrne ci-dessous.¶

En accordance avec la Loi des "Americans With Disabilities". Les personnos en besoin d'une accoinmcdation speciale pour participer a tes procedures doivent, dans un temps raisonable, avant ::l'enrruprendre aucune autre demarche, contacter !Inflict administrative de la Court BU 5.2500 205 North Dixie Highway, West Palm Beach, FL 33401 le telephone ia Florida Relay Service.¶

IMPORTANT¶

D4pre eko ki fet rink Americans With Disabilities Act, tout moan ki ginyin yun bezwen espesiyal you akomodasiyon pen yo patisipt nan pwogram sura dwt, nan jean rtzonab svan ninpot aranjman kapab fet, yo dwt kontakta Administrative Office of the Court, Id nan nimero 205 North Dixie Highway, Chain nimtro 5.2500 West Pal 401 telefon nan st oubyen an pasan pa Florida¶

Relay Service.¶

Page 3 of 3¶

This fax was received by GFI FAXmaker fax server For more information, visit http.//www.gfEcorn¶

178 of 316¶

EFTA00234401¶

Case 9:08-cv_80804-Kipm, D0,9,9,meq91-39,51 E raffike,,,,, -r cl-nOB-611Dooket 07/21/2008 Page 79 of 100¶

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA¶

CASE NO: 50 2008 CA 006596 XXXX MB AB¶

JANE DOE, by and through JANE DOE'S MOTHER, as parent and natural guardian,¶

Plaintiff,¶

vs.
EPSTEIN, FREY		and
	Defendants.

¶

r¶

SUMMON;¶

PERSONAL SERVICE ON A NATURAL PERSON¶

TO DEFENDANT:¶

¶

IMPORTANT¶

A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court, A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. II you do not file your response on lime, you may lose the case, and your wages, money, end property may thereafter be taken without further warning from the Cowl. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an anontey referral service or a legal aid office (listed in the phone book).¶

If you choose to file a %linen response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the 'Plaintiff/ Plaintiffs Attorney" named below.¶

"In accordance with the America= with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office he Court 205 North Dixie Highway, Room ' West Palrit B:tech, FL 33401, telephon r MIME¶

THEODORE J. LEOPOLD, ESQUIRE RJCCI-LEOPOLD, P.A. 292$ PGA Boulevard Suite 200 ns, FL 33410¶

via Florida Relay Service".¶

THE STATE OF FLORIDA¶

TO EACH SHERWT OF THE. STATE: You are commanded to serve this Summons and a copy of the complaint/petition in this lawsuit onilieabove named defendant(s).¶

¶

Usfled ha sido demandado legalmente. Tiene 20 Dias, contados a partir del recibo de esta notificacion, ,pant contester la demanda adjunta, por escrito, y presentarla ante este tribunal. Una Hamada telefonica no lo protegera. Si usted desea que el tribunal considere su defense, debe presenter su respuesin pur escrito, incluyendo et number° del caso y los nombres de las panes interesadas. Si usted no contests la demanda a tiempo, pudiese perder el caso y podria set clespojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen outs requisitos legales. Si lo desca, puede usted consulter a un abogado inmediatamente. Si no conoce a un abogado, puede hamar a une de las (Akins de asistencia lewd que aparecen en la pia telefonica¶

Si desca responder a la demands por su cuenta, al mismo tiempo en que presents su respuesta ante el tribunal, debera usted envier por correo o entregar uno copia de su respuesta a la¶

Page 2 of 3¶

his tax was received by GFI FAXmaker fax server. For more information, visit http://www.nli corn Case 9:08-cv-80804-KAp' LDOconen1,34,115.1 EntairPCitdakaitEispOdiet 07/21/2008 Page 81 of 100¶

persona denominbdo abajo como "Plaintiff/Plaintiffs Attorney" (Demandante o Abogado del Dernandante).¶

"Dc acuerdo con el Ado 0 Death) de los Americansos con Impedimentos, Inhabilitados, personas en necesidad del servicio special para participar en este procedimiento deberim, dentro de tin tiempo =unable, antes de cualquier procedimiento, ponerse en contacto con la Beach, FL 33401, Telefono Cone 205 North Dixie Highway, oft W t Palm Via oflicina Administrataiiva Florida ketay Service".¶

IMPO_RIANT¶

Des poursuites judiciares ont etc entreprises contre vous. Vous avez 20 jours consecutifs a partir de la date de /'assignation dc cone citation pour deposer one reponse ecrite a la plainte ci-jointe aupres dc ce tribunal. Un simple coup de telephone est insuffisani pour vous proteger. Vous etes oblige de deposer votre reponse ecrite, avec mention du numero de dossier cidessus et du nom des parties nommees lei, si vous souhaitez out Ic tribunal entencle votre cause. Si vous nc deposez pas votre reponse come dans le rclai requis, vous risquez de perdre la cause ainsi que votre salaire,, vo.re argent, et vos bens peuvent cue saisis par la suite, sans aucun preavis ulterieur du tribunal. II y a d'autres obligations juridiques et vous pouvez requcrir les services immediats d'un avocat. Si vous nc connaissez pas d'avocat, vous pourriez telephoner a un service de reference d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaire de telephones).¶

Si vOiS choisissez de deposer vous-meme une reponse ecrite, it vents faudra egalement, en meme temps que cette formalite, faire parvcnir ou cxpedier une copie de votre reponse ecrite au ?Plaintiff/Plaintiffs Attorney" (Plaignant ou a son avocet) nornme ci-dessous.¶

Eri ac:ordance avec la Loi des "Americans With Disabilities". Les personnes en besoin d'une accommodation speciale pour participer a ces procedures doivent, dans un temps raisonable, avant d'entreprendre aucune autre dernarche, contacter ('office administrative Court SitUe au Dixie Highway, West Palm Beach, FL 33401 le tclephon a Florida Relay Service.¶

IMPORTANT¶

Dante ako ki fet avek Americans With Disabilities Act, tout moun ki ginyin yun bozwen espesiyal pot. akomodasiyon poll yo patisipd nan pwograrn sa-a dwd, nan yun rezonab nan ninpot aranjman kapab fet, yo dwd kontakte Administrative Office of the Court, ki nan Minim 205 ham ninth.° 5.2500 West Palm Bmich, Florida 334 1 telefon nun se pa Florida¶

Relay Service.¶

Page 3 of 3¶

Case 9:08-cv-80804-K%lrn Dc,QQmetiltot- ?2151 Entlikrsegkii2051-16O3Docket 07/21/2008 Page 83 of 100¶

JANE DOE, by and through JANE DOE'S MOTHER, as parent and natural guardian,¶

Plaintiff,¶

vs.
JEFFREY EPSTEIN,	and
De fen clan es.

SUMMONS¶

PERSONAL SERVICE ON A NATURAL PERSON¶

TO DEFENDANT:¶

¶

IMPORTANT¶

A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file u written response to dic attached complaint/petition with the Clerk of this Court. A phone call will not protect you. Your written response, including the case number given above and the names cd the parties, must be filed if you want the Court to hear your side of the case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. •there arc other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book).¶

If you choose to file a wrinen response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/ Plaintiffs Attorney" named below,¶

83 of 316¶

"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact tie Administrative Offic oral Dixie Highway, Room 00 West Palm Beach, FL 33401, tetepho via Florida Relay Service".¶

THEODORE). LEOPOLD, ESQUIRE RICCI—LEOPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 (561)684-6500¶

THE STATE OF FLORIDA¶

TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and a copy of the complaint/petition in this lawsuit on the above named defend: s).¶

	8248 NAR 1
DATED ON
	gERX	ARON BOCK OF 'f HE CIRCUIT COURT
	ta A	SANDRA CUEVA
	7A. 'By r
	0 a 1 u	Deputy Clerk

Ustcd ha side demanded° legalmente. Tienc 20 Dias, tornados a pan ir del recibo de este notification, pars contcstar la demands udjunta, per escrito, y prostate's ante este tribunal. Una Hamada telefon,ca no In protegera. Si usted desea que el tribunal considere su defense, debe presenter su respuesta por escrito, incluyendo el numbero del caso y los Hombres de las panes interesades. Si usted no contesta 1n demands a tiempo, pudiese perder el case y podrix ser despojado de sus.ingresos y propiedades, o privado de sus derechos, sin previe aviso del tribunal. Existen ouos requisites legates. Si lo desert, puede usted consultar a un abogado inmediatamente. Si no conoce a tin abogado, puede llamas a ima de las oficinas de asisiencia legal que aparecen en hi gui a telefonica.¶

IMPORTANTE¶

Page 2 of 3¶

This lax was received by GFI FAXmaker fax server. Fa more information, visit hltfyfiwow gli.com¶

Si deka responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera ustcd caviar por correo o entregar tura copia de su respuesta a la persona denominada (Maio como "Plaintiff/Plaintiffs Attorney' (Demandante o Abogado del Demandante).¶

"De acuerdo con el Acto 6 Decreto dc los Americansos con Impedimentos, Inhabilitados, persona en necesidad del servicio special pare parlicipar en este procedimiento deberan, dentro de un tiernpo nizonabie, antes de cualquier procedimiento, ponerse en contact° con In officina Administrntativ rth Dixie Hi hway, oficina 5.2500, West Palm Beach, a. 33401. Telefon Via Florida Relay Service".¶

IMPORTANT¶

Des poursuiles judiciares ont etc entreprises contre vous. Vous avez 20 jours consccutifs a partly de la date de ('assignation de cette citation pour deposer une reponse ethic a la plaint° ct-jointe aupres de ce tribunal. Un simple coup de telephone est insuffisant pour vous proteger. Vous etes oblige de deposer votre reponse ecrite, avec mention du numero de dossier cidessus el du nom des parties nominees ici, si vous souhaitez que le tribunal entende votre cause. Si vous ne deposez pas votrc reponse ecrite dans Ic relit) remits, vous nsquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre saisis par la suite, sans auctm preavis ultericur du tribunal. II y a d'aturcs obligations juridiques et vous pouve? requerir les services immedims d'un avocet. Si vous ne connaissez pas d'avocat, vous potirriez telephoner a tin service de reference d'avocats ou a un bureau d'assistance juridique (figurant a I'annuaire de telephones).¶

Si vous choisissez de deposer vous-memc une reponse ecrite, it vous fetidly egalement, en menu temps que cute formalite, faire parvenir ou expedier une copie de votre reponse ecrite au "Pla miff/Plaintiffs Attorney" (Plaigmtnt ou a son avocat) nomme ci-dessous.¶

En accordance avec In Loi des "Americans With Disabilities". Les personncs en besoin dune accommodation speciale pour participer a ces procedures doivenl, dans un temps raisonable, avant d'emreprendre immune °titre dernarche, cementer Porting administrative de is Court Dixie Highway, West Palm Beach, FL 33401 Ic telephone_ ride Relay Service.¶

IMPORTANT¶

Dapre ako Id let avek Americans With Disabilities Act, tout moun Id pinyin yun bezwen espesiyal pou akornodasiyon pou yo patisipe nan pwogram sa-a dwd, nan yun rezonab avan ninpot aranjman kopab fel, yo dwe kontakte Administrative Office of the Court, ki nun nimdro 205 Dixie Highway, Chain nimero 5.2500 West Palm Beach, Florida 3340! telefon nan se pasan pa Florida¶

Relay Service. '¶

Page 3 of¶

RETURN OF SERVICE¶

		Circuit Court
State of Florida Case Number 50200804005598XXXXMBAti	County of Polm Bosch
JANE DOE BY AND THROUGH JANE DOES MOTHER. AS PARENT Ple.ntiff. AND NATURAL GUARDIAN
vs. Dander* JEFFREY EPSTEIN
For Ted LO0D0ld, Esquire RICCI—LEOPOLD. R.A 2925 Pps Blvd Suite 200 Palm Beach Jordon's. FL 33410
	RVICES on the 19th day of March, 2008 et 9 20 am to be served
I, Alan J Culler, do hereby affirm that on the 21st day of March, 2008 el 8;34 pm. I:

SERVED BY RESIDENTIAL SUBSTITUTION by leaving a true copy of this Summons and Complaint with the dale and time of service endorsed thereon by me This address is the above named subject's usual place of abode The court document was lve0 toe arson residing at this numerical who was verified to be 15 years of age or older and was identified a rd informing this subject of the contents thereof¶

I certify that I am over the age of 18. have no interest in the above action, and am a Certified Process Server in good Blending in the judicial circuit in which the process was served¶

C.W. SERVICES 4908 Gras:deaf Oriva Pala, Bosch Gardena, Fl. 33418 (681) 830.4866¶

Our Job Serial Number 2008034295¶

CaProani 0 Ite?.2COMNriem... dram at -P/4p o Um,.¶

Case 9:08-cv-80804-KAM Dopyment 1-4w, ErVetrktfitiokartiDookiet 07/21/2008 Page 88 f 100 loth¶

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA¶

CASE NO: 50 2008 CA 006596 XXXX MR AB¶

•¶

r'3¶

JANE DOE, by and through JANE DOE'S MOTHER, as pureni and natural guardian,¶

Pianitiff,¶

vs.
JEFFREY EPSTEIN,
Defendants.
	•
,SUMMONS

PERSONAL SERVICE ON A NATURAL PERSON¶

TO DEFENDANT;¶

¶

I M PQaTA NT¶

A lawsuit has been filed against you. You have 20 calendar days atter this summons is served on you to file a written response to the attached wmplaint/petition with the Clerk of this Court A phone eall will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side or the case. If you do not file yotr response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There arc other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an anompy referral service or a legal aid office (listed in the phone book)¶

If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your wriucn response to the "Plaintiff/ Plaintiff's Attorney" named below.¶

"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable lime prior to any nroceeding, contact the Administrative Office - 'tie Hi hway. Room iiiiiit Palm Beach, FL 33401, telephon¶

, via Florida Relay Service".¶

THEODORE J. LEO FOLD, ESQUIRE RICC1—LEOPOLD, F.A. 2925 PGA Boulevard Suite 200 Min Beach Gardens, FL 33410 (56 I) 684-6500¶

THE STATE OF FLORIDA¶

TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and n copy of the complaint/petition in this lawsuit owbc abo8ve nomad defendant(s).¶

¶

Wed tae lido demandado legalmente. Tiene 20 Dias, contac.los a partir del recibo de este. nolificacion, pare contcstar la demands adjunta, por escrito, y presemarla ante este tribunal. Una Ilamada telefonica no lo protegera. Si usted desea que el tribunal considere su defense, debe presenter su rem-Mesta por escrito, incluyendo el number° del caso y los nombres de las mutes interesades. Si usted no contests la demanda a tiempo, pudic= perdcr el caso y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen otros requisitos legates. Si lo desea, puede usted consulter a on abogado inmodiauunente. Si no conoce a un ahogado, puede 'lamer a una de las Widnes de asistencia legal que apareccn en la guia telefonicu.¶

Si clesea responder a la demanda por su cuenta, al mismo tiempo en que presents so respuesta ante el tribunal, debera usted envier par enrreo a entregar una engirt de su respuesta a la¶

Page 2 of3¶

persona denominada ebtijo como "Plaintifl7Plaintiffs Anomey" (Demandante o Abogado del Demandante).¶

kirsch, FL 33401, Teléfono "13e ucuerdo con el Acto 6 Decreto de los Americanos con Impedimentos, Inhabilitados, personas en necesidad del servicio special para participar en este procedimiento deberán, dentro dc un Lempo razonable, antes de cualquier procedimiento, ponerse en contacto con, la officina Administratativa . .chwa oficina 5.2500, West Palm la¶

Florida Reluy Service".¶

LMP.QRTANT¶

Des poursuites judiciures unt etc entreprises eontre vous. Vous aven 20 jours COnSteUtifS a Futir de la date de l'assignation dc cene citation pour deponer une repense ecrite n la plainte ei-jointe nupres de cc tribunal. Un simple coup de telephone est in.suffisanl puur vous proteger. Vous eles oblige de deposer vone reponse corito, avec mention du numero de dossier cidessus et du nom des parties nommees ici, si vous souhaitez que le tribunal enlende votre cause. Si vous ne depon pas votre reponse eerite dans le relai raquis, vous risquez de perdre la cause ainsi que votre salaire, volt?. angen', et vos biens peuvent erre saisis par In suite, sans aneurt preavis ulterieur du tribunal. fl y a d'out/es obligations juridiques et vous pouvez requerir les services immediais d'un avocat. Si vous ne connaissez pos (rayuela, vous pourriez telephoner a un service de reference d'avocals ou a un bureau d'assistance juridique (figurant a rannuaire de telephones).¶

Si vous choisissez de deposer vous-meine une ruponsc =he, il vous faudrn egalement, en méme temps que cene formalite, faite porvenir ou expedier une copie de votre reponse ecrite au Wlaintitl7Plaintiffs Anomer (Plaignant nu a son evoco') nomme ei-dessous.¶

En neoordene avec la Loi des "Americans With L)isubilities". Les personnes en besoin bune aecommodution speciale pour participen a ces procedures doivent, dilas tm temps raisonable, anar dentreprendre aucune nutre démarche, cometer l'office administrative d.. la feurt -ifia 111 4.2tOp, 205 North Disk 1 fi hway, West Palm Beachba 1 , FLd 33401ay sl erv ce erelephol¶

JMPORTANT¶

Dapré alce ki fet avek Americans With Disabilities Act, tout moun lo ginyin yun bdzwen éspésiyal pou akomodasiyon pou yo patisipé non pwogram sa-a dwé, non yun rézonab :oran ninval aranjman kapab fet, yo dad kontaktri Administrative Office of the Court, ki non :limero 205 nirnåro 5.2500 West Palm Beach, Florida 33401 ttlefon ran sé pa Florido¶

Reluy Service.¶

Page 3 o f 3¶

11'1 THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA¶

JANE through and by DOE, JANE natural and as parent MOTHER, DOE'S guardian	NO . 50 CASE MB XXXX	2008	CA006596 •
Plaintiff,			k. of CD	710 •19	-71
VS.			--	0	F rn
EPSTEIN 'Y			ri n k cot	u -	O
			n r- z sh"m• r
Defendants.			n r

MOTION TO QUASI{ SERVICE OF PROCESS¶

COMES NOMMEN by and through her undersigned attorneys, and files this Motion to Quash Service of Process, and as grounds therefore would state as follows:¶

1. Florida Statute §48.031(1) allows service of original process by delivering a copy of it to the person to be served or by leaving copies at his or her usual place of abode with any person residing there who is fifteen years or older and informing that person of their contents.

• 2. An agent for counsel for the Plaintiff purports to have served 'th a copy o ['the Complaint via residential substitution on March 21, 2008 at 8:34 o.M. (A true and correct copy of the Return of Service is attached

91C1070511.9AWRAP. P61.1 a CAIITAY•, P.A. • 011116/110 AT LAW • 166I MUM ?LACE • 30111 Or • Mat IPALM PEACH. Pl..11.111 lii.9711UNI. OM/ •••••1161 1098114AX is•1) 940.•611¶

19201316 This fax was received by GPI FAXmaker fax server. For more information, visit. http.//www.gftcorn¶

CASE NO. 50 2008 CA006506 X)OCX MB¶

the served who Plaintiff the for agent van see, the Court the As A.) as Exhibit hereto
who the same served have to purports Complaint Summons and
made at was purportedly service Said father. alas identified is
County. Beach Palm in located
was not abode of place s usual 2008 21, March On 3.
Rather, County. PalmBeach in
different was an entirely 2008, on March 21, abode of place uival
to anyone, including authorize not did location.
i proper and was not service this Therefore, behalf. process on her of service accept

was ineffective.¶

4. It is well recognized in Florida that a person's usual place of abode is defined as the place where the person is actually living at the time of service. See Sharman it Atlantic Mortgage and Investment Corp. 795 So. 2d 952 (Fla. 2001). In the Sturman opi lion, the Supreme Court of Florida also confirmed that "statutes governing service of process are to be strictly construed and enforced." Id. at 954.

5. There arc different schools of thought as to the most appropriate way to challenge service of process. There is also some confusion with regard to whether filing a motion other than a Motion to Quash Service of Process waives one's right

MCINMAN, NAWKAN. PKI.TY., & CANTATA. P.A. • AT,LIIINRYS AT I.AW • INN POPP& VIACC • UNTIL II lo • MCA PALM III:ACII. It MU rACAimitx OM) 681.33" I &LAMM, pm" ibilit.h10¶

193 wart This fax was received by GFI FAXmaker fax server. For more information, visit http:/lwww.gfi.com¶

to move to quash service of process. Thereforel= files this Motion to Quash Service of Process in lieu of any other type of motion or responsive pleading pursuant to the Fourth District Court of Appeal's opinion in aaraban v. &cv.sagn which holds that the "preferable manner of presenting a defense of insufficiency of service of process ...is by a Motion to Quash such allegedly insufficient service of process rather than oy a Motion to Dismiss the Complaint." fiataban v. Sussman 439 So. 2d 1046, 1047 (Fla. 4thDCA 1983).¶

6. alereserves the right to supplement this motion wi th evidence

to support it.¶

WHERETO a respectfully moves this Honorable Court for the entry of an Order granting Motion to Quash the Service of Process.¶

CERTIFICATE OF SERVICE¶

WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via regular mail to Theodore J. Leopold, Esq., Ricci-Leopold, P.A., 2925 PGA Boulevard, Suite 200, P.O. Box 2946, Palm Beach Gardens, FL 33410, this 10th day of April, 2008.¶

MC I /414/9/1. SAWRA1e, PELTZ, 49 CARTA V A, 1..A. • Ai TORNNYI AT LAW • 11•1 YUIIIN ri.Act .surri. I iir • wtler 40444 'MACH, FL Si 114.4.014064•Stileaw1/•• rat nwiLC 1.611 4. 341• 4¶

3¶

19401316 This fax was received by GFI FAXmaker fax server. For more information, visit. http./Minvw.gfi.com¶

Case 9:08-cv-80804-KAFfi Doaimepui2,51 Eqweesimcgela Docket 07/21/2008 Page 95 of 100¶

CASE NO. 50 2008 CA006596 XXXX MB¶

McINTOSH, SAWRAN, FELTZ & CARTAYA, P.A. Centurion Tower 1601 Forum Place, Stine 1110 West Palm Beach, Florida 33401 Telephone: Facsimile: f By: DOUGLAS M. Mc1NTOSH Florida Bar No. 325597 JASON A. McGRATH Florida Bar No. 97349¶

MC !NUMMI. SAwmAre, polka, CAM I AVA. r.A• • ATTOMMEYS•Ii AW • [al TIMM PIA, C • Wilt 1113 • Ma/ was WeACII. VI. Taal¶

TOACPWbiti nil I MI/ *AM IM.SIMILE fMl 60.1)116¶

4¶

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Case 9:08-cv-80804-KtFrNA Document 1-9 Ssi EacisrAfflop t.pp•Dqgket 07/21/2008 Page 96 of 100 RETURN OF SERVICE State of Florida Coco Number 502008CA006696X)0(XMBAU County of Palm Bosch Circuit Court Pialntift JANE DOE DY AND THROU3H JANE DOES MOTHER, AS PARENT AND NATURAL GUARDIAN vc Defendant JEFFREY EPSTEIN, For Trid Leopold. Esnire RICCI-LEOPOI.O. P.A 2925 Pao Uwe Stilts 200 n: rf¶

ERVICES on the 19th day of March. 2000 m 9 20 am to be served¶

Pnlm Botch Gardena. FL 33410¶

I. Awn J. Culler. do hereby alarm that on the 2int day of March, 2008 at 8:34 pm, h¶

SERVED BY RESIDENTIAL SUBSTITUTION by leaving a true copy of this Summons and Complaint with the date °Warne of service endorsed thereon by me This oaths* is the above named Gairoere U6U01 *CO of abode. The WWI document was served toe person residing at this numerical who was verified to be 15 yours of ago or older ant we: identified as TOMMY ROBSONIFATHER and Informing this aubjoct of the contents thereof¶

I codify Thal I am over the ago of 18. have no inb red in the above action, and tin a Certified Process Server In good standing in the judicial (scull in which the process wee served.¶

-.1 • •¶

Alan J. Cutler Court Offices /¶

C.W. SERVICES 4908 Grimeloaf Drive Palm Beach Gardens, FL 33418 (681) 6304868¶

Our Job Sahel Number 2006034296¶

Cy•kri • 1601.300$ Camila ilara•o.6• hems* erne Teets V6.•¶

¶

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r.¶

F tom w wn Page 44151 Date¶

RETURN OF SERVICE¶

State of Florida¶

County of Palm Beach Circuit Court¶

Cuso Number 502008CA008596XXXXMBAB¶

Plaintiff JANE DOE BY AND THROUGH JANE DOE'S MOTHER, AS PARENT AND NATURAL GUARDIAN¶

vs Defendant. JEFFREY EPSTEIN,¶

For Ted Leopold. Esquire RICCI-LEOPOLD, P.A 2925 Pga Bivd Suite 200 Palm Beach Gardens, FL 33410¶

¶

Received by C W SERVICES on the 14th day of May, 2008 at 359 pm to be served on JEFFREY EPSTEIN. 368 El. BRILLO WAY. PALM BEACH FL. 33480¶

I, Allan J Cutler. do hereby affirm that on the 18th cloy of May, 2008 el 9:15 am, I:¶

SERVED BY RESIDENTIAL SUBSTITUTION by leaving a true copy of this Summons and Complaint with the date arc lime of service endorsed thereon by me This address is the above named subject's usual place of abode The court document was sewed to o person residing at this numerical who was verified to be 15 years of age or older and was identified as JANJSZ BANASIAK (LIVE IN HOUSE MANAGER) and informing this subject of the contents thereof¶

MIlltary Status: Based upon inquiry of party served, defendant is not in the military service of the United States.¶

I certify that I am over the sge of 18, have no interest in the above action, and am a Certified Process Server in good standing in the judicial circuit in which the process was served¶

Alan J. Cutler Court Officer #843¶

C.W. SERVICES 4908 Greenleaf Drive Palm Beach Gardens, FL 33418 (661) 630-4866¶

Our Job Serial Number 2008035775¶

Capriird 0 14112.194 Dalame Int • Wr•o•••• terve" Amin v5 SI¶

Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 99 of 100 rot L. wn Page 45/51 Date. 5/29200812:09.: M • c1,2_ 7¶

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLOM DA

¶

CASK NO: SD 2008 CA 006596 XXXX MB Ali¶

JANE DOE, by and through JANE DOE'S MOTHER, us parent and natural guardian,¶

Plaintiff,¶

vs.
EPSTEIN, JEFFREY	nd
	Defendants.

SUMMONS¶

PERSONAL SERVICE ON A NATURAL l'ERSON¶

TO DEFENDANT:¶

JEFFREY EPSTEIN 457 Madison Avenue 4sFloor New York, New York /Oa Z•2•-•¶

IMPORTANT¶

A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must he filed if you want the Court to hear your side of the case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book).¶

if you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/ Plaintiffs Attorney" named below.¶

¶

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In accordance with the Americans with Disabilities Act, persons in need of n special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room Palm Beach, FL 33401, telephon¶

via Ronda Relay Service".¶

THEODORE J. LEOPOLD, ESQUIRE RICCI-LEOPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Bench Gardens, FL 33410 (561) 684-6500¶

THE STATE OF FLORIDA¶

TO EACH SHERIFF OF THE STATE: You are commanded it serve d is Sumtdons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). III¶

¶

IMPORTANTE¶

Usted ha sido demundudo lep,almente. Tiene 20 Dias, contados a partir del recibo de este notificacion, pre contester la dementia adjunta, per escrito, y presentarla ante este tribunal. Una Hamada telefortza no lo protegers. Si usted desea que el tribunal cunsidere su defense, debe presenter su respuesta par escrito incluyendo el numbero del caso y los nonlbres dc las panes interesudas. Si listed no contests la denuinda a tiempo, pudiese perder el caso y podrie ser despojado de sus ingresos y propiedudes, o privado de sus derechos, sin previo aviso del tribunal. Existen otros requisi.os legates Si lo desea, puede usted consulter a un abogado inntediatamente. Si no conoce a un abogado, puede Hamar a una de las oficinas de asistencia legal que aparecen en la guia telefonica.¶

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