Draft: efta00222254 · The Epstein Index

CASE NO.: 08-CV-80119-MARRA/JOHNSON¶

EXHIBIT A¶

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			Page 3
1		INDEX
2	WITNESS:		PAGE:
3
	DIRECT KRAMINATION		4
4	BY MR. TEIN:
5	g
б
7		NORXHIBITS MARKED
8		= -
ു		. CERTIFIED QUESTIC&S
10	Page	Line
	ટે 3	22
11	55	6-4
	్ స్టే	2
12	111	14
	112	2
13
14
15
16
17
18
19
20
21
22
23
24
25

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	Page 7		Page 8
	Where 18 that? 0		MR. LEOPOLD: Let me just object.
2	Palm Beach Lakes. A.		lot me instruct you. Anything that
ਸ	Have you spent the night over there? ்.		you have learned through conversations between you
	A. No, sir.	2	and me are probected. So if you know any of that
	Do you know the address there? ்		information outside of those discussions, you may
	I do not. R.	5
ારિ 7	planning on living Ism't your sister ்	6	answer. But if the only way you know it is
	with you and	2	through our discussions, do not answer that
8	A. No.	8	question.
ਹੈ।	you know that this court case is a	ு	DY MR. TEIN:
10	். criminal prosecution, correct?	10	you know that Nr. Leopold recently 0.
11	Correct. મરે	11	filed a lawsuit in federal court on your behalf against
12	And you know that it's a criminal	12	Jeffrey Epstein soeking fifty million dollars?
13	0. prosecution against a man who has no criminal background.	13	MR. LEOPOLD: Same objection.
14		14	If you know the answer to that outside of
15	Do you know that?	15	our discussions, you may answer. If it is the
16	I do now. A.	16	only way that you know the answer is through our
17	You sgree that court is a very serious ்	17	discussions, do mot answer that question.
18	matter ?	18	THE WITNESS: Oleay.
19	A. Ton.	19	MR. LEOPOLD: Retorney/client privilege.
20	And you're here with your lawyer ்.	20	BS. Ma. 2219 :
21	Mr. Leopold, right ?	21	rou can answer the quastion unless -- ்.
22	Tea. A.	22	MR. LECOOLD: Same objection.
23	And you know that Mr. Leopold recently 0	23	NR. TEIN: Let me finish.
24	filed a lawsuit in federal court against Jeffrey Epstein,	24	MR. LEOPOLD: Excuse me. We're ==
25	seeking fifty million dollars.	ਡੇਡ	MR. TRIM: No. Let me finish.

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Ternsor & Associates¶

Entered on FLSD Docket 06/30/2008¶

Page 4 of 35¶

Page 10¶

	of OR I which was		1075-21 108 / 16/6/9/9/19/19/9/9 Ropersing and Thenserial to, In
	Page 9		Page 1
	MR. LEOPOLD: Irwis, we're not going to do		you may answer. So do not answer that question if
2	that.	2	that is the only basis by which you understand
3	MR. TEIN: Ny name is not Lewis .	3	that answer.
4	I'm going to finish my question. Okay?	4	THE WITNISS: No.
	MR. LEOPOLD: Do not answer, until you hear	5	BY MR. THIN:
હ	Crom 100.	િ	Tou didn't know that? 0-
7	BY MR. TEIN:		MR. LEOPOLD: Dom't answer that question.
B	Other than conversations that you have had ்	8	Again, it's attorney/client privilege. Any
ਰੋ	with Mr. Leopold -- I'm not asking about that -- are you	9	information you've learned through conversations
10	aware that Mr. Leopold has filed a lawsuit in federal	10	between you and I are protected. If you know it
11	court seeking fifty million dollars from Jeffrey Epstein	11	through any other realm, you nay answer.
12	on your behalf?	12	MR. TEIN: Are you going to say that for
13	MR. ISOPOLD: Same objection.	13	every quostion in the deposition, Mr. Leopold?
24	Anything that you learn through	14	MR. LEOPOLD: When you ask improper
15	conversations between you and ma, do not answer.	15	questions like that without the proper ==
16	Those are protected. If you know through any	16	MR. TRIN: You're poing to stop your
17	other realm of knowledge, you may answer.	17	spaaking objections right now. Okay?
18	THE MITNESS: Bo.	18	MR. LEOPOLD: Without the proper --
19	BY . MR. TEIN:	19	MR. TE28: You need to stop your speaking
20	You have no idea that Mr. Leopold filed a 0.	20	objecticas.
21	fifty million-dollar lawsuit on your behalf against	21	Let's continue.
22	Jeffrey Epstein?	22	KR. LEOPOLD: Counsel, you just asked me a
23	MR. LEOPOLD: Some objection.	23	question and I'm going to state it on the
24	bo not answer that question if it's through	24	record --
25	discussions that you and I had. Outside of that,	25	MR. TEIN: You need to stop your speaking
	The state of the production of the station of the subscription of the same		a manager and modiation come in the comments of a commended to commended to the comments of the comments of the comments of the comments of the comments of the comments of th

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

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19	MR. TEIN: You need to stop your speaking
20	objections .
21	Let's continue.
22	NR. LEOPOLD: Counsel, you just asked me a
23	question and I'm going to state it on the
24	record --
25	MR. TEIN: You need to stop your speaking
	and and and the comments of the comments of the collect Ph. 561.682.0905 · Fax. 561.682.1771 ASEE Bales Deach Laters Blud, E-il- EBO, Vices Oslas Baseb, El 72401.

	Page 11
1	objections. Check your rules.
2	MR. LBOPOLD: Excuse Ins. For the record,
3	Counsel asked me a question. "I'll state the
4	answer on the record. Ho asked me the question an
5	I poing to be answering that way throughout the
0	deposition. So long as there's improper
7	foundation and predicate asked by the attorney. I
8	will protect my client and I make the record where
9	appropriate. If counsel wishes to ask an
10	appropriate worded question with the proper
11	foundation and predicate, I will certainly allow
12	the client to answer the question.
13	MR. GOLDGERGER: Why don't you just state
14	attormey/client privilege and just be done with
15	167
16	MR. IDOPOLD: I wint the record to be
27	claar.
18	MR. TEIN: You want to waste time is what
19	you want to do.
20	You were supposed to be here this marning
21	and you totally broke the deal, the agreement that
22	you had with us if your hearing got cancelled.
23	Bot let's move on and maybe you'll stop
24	obstructing this deposition.
25	MR. LEOPOLO: I think the record is very STATUTE

	Page 12
1	clear where we stand thus far.
60	Is there a recording taken of this
3	deposition?
6	THE COORT REPORTER: Yes.
ಳಿಗಿ	MR. LBOROLD: Just make sure that's
6	preserved.
7	BY . MR. 75IN:
B	Go to Exhibit 20=01 == well, before you do Q-
9	are you aware that a lawyer named Joffrey chat.
10	Herman filed a lawsuit on your behalf, yes or no?
11	NR. LNOPOLD: Objection.
12	Any conversations that you and I have had
13	regarding that, if that is the only way by which
14	you understand how to answer that question, do not
15	answer. It's attorney/client privilege, as well
16	as any conversations you may have had with the
17	attorney from Miami. That is also attorney/client
18	privilege. And I'm assuming --
19	MR. TEIN: You!re actually wrong about the
20	attorney/client privilege.
21	For LEDPOLD: I'm assuming Counsel is swt
22	asking you to divulge attormay/client ==
23	MR. TEIN: Of course not.
24	BY MR. TEIN:
25	are you mware that Jeffrey Herman, Q-

EFTA00222257¶

Consor & Associates¶

Page 13 an attorney, filed a fifty-million-dollar lausuit on your 1 behalf against Jeffrey Epstein, yes or no? 2 MR. LEOPOLD: Same objection. 3 MR. TEIN: We've heard the objection 10 4 5 tines aiready. MR. IMOPOS.D: Counsel, excuse me. రా, 7 MR. TEIN! Just say attorney/client privilage. Stop interrupting my questions. 8 MR. LEOFOGD: I'm entitled to make an g objection for the record, which I'm doing, and 10 1'21 make the same objection. And if it calls for 11 attormay/client privilege, any conversations you 12 and I have had, do not answer the question. 13 And I think that it might be appropriate, 14 for the record, to ask questions via 15 I think that as opposed to 16 would be more appropriate for this deposition. 17 BY MR. TEIN: 10 Go shead. Please answer yes or most 19 ். 20 A. Yes. 21 ୍ର. Thank you. In fact, you know that Mr. Mezman held a 22 press conference after he filed the fifty-million-dollar 23 lawsuit on your behalf, don't you? 24 After it happened. 25 A ()¶

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

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	Contracts pur formation of the contraction inc.
	Page 14
1	You know that he had a press conference, o
2	don't you, yes or no?
3	Tos. A.
4	In fact, let's go to Exhibit 20-D1. ்.
5	MR. GOLDBERGER: Look behind you. You'll
6	noo it.
7	BY MR. TRIN:
a	Have you ever seen that picture before? ्.
್ತಿ	A. Yes.
10	Is that a picture of your father, your ்.
11	stepnother and Mr. Herman at the press conference
12	regarding your lawsuit?
13	A. Tea.
24	Now you know that this is a very serious o
15	matter, don't you?
16	MR. 12000LD: Asked and answered.
17	Objection.
18	MR. GOLDBERGER: All right. You cam
19	object. You're representing a witness here,
20	Mr. Leopold. You can object on privilege grounds.
21	You canmot wake legal objections. You have no
22	standing to do po.
23	NR. IEOPOLD: I'm going to make thom and
24	thefi --
25	ISR. GOLDBERGHR: We're --

Insor & Associates¶

Entered on FLSD Docket 06/30/2008¶

1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401¶

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Page 15		Page 16
MR. 180POLD: We're going to leave or we're		no matter who it is.
going to take a braak, because his demessor is not	2	NR. LEDPOLD: I think we're going to rake a
appropriate. There's no reason to have this kind	3	break. Perhaps you might want to talk to your
of demeanor. If you want to have this kind of	4	co-counsel --
demeanor with ma ==	ಲೆ	MR. TEIN! I dos't need to talk to him.
MR. TEIN: You are obstructing this	રે	MR. LEOPOLD: Suc we're going to Eaxe a
deposition.	7	break.
of syng more a supplies : the don't you quys go	8	MR. TEIN: We're not taking a break unless
autside and just talk about --	ਰੇ	the witness needs a break.
MR. LEOPOLD: She == her 3ob 15 very	10	You're obstructing this deposition, Ted.
difficult and she's not going to be able to take	11	MR. LEOPOLD: Come on,
us both talking at the same time.	12	You all want to continue in this
MR. GOLDGEREER: Off the record.	13	demeanor --
MR. LEOPOLD: Wo're not going off the	14	MR. TEIN: You're obstructing the
record, Jack. We're not, Jack. Mer job is very	15	daposition. Stop making speeches. We're not
difficult. I'm going to make the record.	16	disoussing this with you. The questions are to
I don't think it is appropriate, especially	17	your client. Co take your five-minute break,
in the small confines of this goom, to be very	18	MR. LEOPOLD: Fine. We need to make sure
apgressive with this young lady.	19	the record's clear and clean.
MR. TEIN; That's not happening. Stop,	20	and I want to make sure, as I've already
stop actually --	21	asked you - I know that you're one of the best in
MR. LEOPOLD: If you're going to interrupt	22	town == that this audio -- this meeds to be
me, we're going to cancel this deposition ==	23	preserved. Okay?
MR. TEIN: Stop misrepresenting.	24	MR. TEIN: Go take your five-minute break,
THE COURT REPORTER: I ROOD one at a time,	25	Mr. Leopold, now.

Page 5 of 35¶

Case 9:08-cv-80119-KAM Entered on FLSD Docket 06/30/2008 Document 15-2 Sinsor & Associates¶

Cinsor & Associates¶

Page 17 Tou were supposed to be here at nine a.n.j 1 Take your break and come it's now after two. 2 3 back MR. ISOPOLD: Okay. If the deseanor keep 4 up, we will not be here beyond those five nimutes. 5 MR. TRIN: Take your break and come back, 6 MR. LBOPOLD: Oksy. Bo I suggest that your 7 B relax மு MR. TEIN: I suggest that you take your 10 break 11 MR. GOLDBERGER: Let them take that 12 five-minute break. 13 NR. LEDPOLD: But I would suggest that you 14 take deep breaths. 15 MR. TEIN: Suggest whatever you want. Ga take a hreak. 16 (Thereupon, a recess was taken.) 17 BY MR. THIN: 18 you agree that giving testimony 19 0. today at your deposition is something very serious, don't 20 21 you'l 22 A. You And you respect the gourt, don't you? 23 0. 24 A Yes Lat me show you Exhibit 31-001. Can you 25 ୍ଦ Ph. 561,682.0905 .- Fax. 561,682.1771¶

1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401¶

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e 0. Thank you. Iol hah my baddd. . . lol yah i got some 6 A. stupid court shit on the 20th ... bullehit ... and damn you 7 still have court shit with him? Like after so long wow 9 im sorry ... well yah well we will definitely havta make 9 plans for sure. . because i miss u tons times a million and 10 11 no no no i love you. .. o and p.s. i love ur default pic 12 nigqaa. Muah wo. 13 ୍ତ . Did you send that message last week to a 14 friend of yours on MySpace? I wouldn't know. There's no dates and I've 15 λ delated that MySpace, so --16 17 ੋ we're going to talk about that in a second. 18 A. Okay Did you send that message last week --19 ୍ତ . 20 A. Hight. 21 ୍ତ.. Let me finish my question. 22 Did you nend that message last week to a 23 friend of yours on MySpace? I wouldn't know the date, but obviously, A. 24 it's to a friend. 25 ( )¶

read that out loud, please.¶

A.¶

Okay.¶

What do you want?¶

Will you read that out loud, please.¶

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Ph. 561.682.0905 - Fax. 561.682.1771¶

1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401¶

...........¶

	Face 19
1	Did you send that message to a friend of o
2	yours on HySpace ?
14	Suce, yes. A.
4	Were you referring to this deposition? ்.
5	Yes. A.
િ	Do you find the term n=i-g-g-e-r offennive? 0.
7	That's not anywhere in there. R.
0	What word did you use in there? o
9	MR. LEOFOLD: Where are you referring to,
10	Counsel? There's 20 plus words in there.
11	MR. TEIN: Don't make a speaking objection.
12	THE WITNESS! Are you referring to
13	anything ==
24	Don't == don't No. MR. LEOPOLDI
15	let him ask you the question.
16	BY MR. TEIN:
17	What question were you saking, ்
18	MR. LEOPOLD: She doesn't ask questions.
19	You ask the questions. What is the question
20	pending?
21	BY MI. TEIN:
22	what is the last word on there in ்
23	the text of your message before the closing?
24	Niggad. A.
25	Don't you find that term offemelive? ்

	Page 20
1	No. A.
N	MR. IEOPOID: Can you spell it for the
3	record, please.
1	THE WITHESS! N-1-9-9 -
5	MR. TEIN: No, mo, no. You are not going
6	to be asking questions.
7	NB. LEOPOLO: I'm not asking questions.
(1)	I'm asking for the record the word to be spelled,
9	because we don't have a video here today.
10	MR. THIN: These exhibits are part of the
11	record. You --
12	MR. LEOPOLD: Well, it's not marked as an
13	axhibit.
14	MR. TEIN: Stop interrupting me,
15	Mr. Leopold. I have marked and identified as an
16	exhibit and you will get it.
17	MS. IEOPOLD: There has been no
16	identification of this document in the record.
28	MR. TEIN: Nr. Leopold, stop interrupting
20	this deposition.
21	MR. LEOPOLD: What is the exhibit number
22	marked for identification?
23	MR. TEIN: 31-001.
24	MR. LEOPOLD: Do we have copies? Is it on
25	the record anywhere?

Page 6 of 35¶

Page 18¶

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isor & Associates¶

Entered on FLSD Docket 06/30/2008¶

ser & Associates¶

	1
	Di

	Page 21		Page 22
1	BY MP. TEIN:		You wrote that to your friend, didn't you? 0-
2	1063 gra in fact Let me ask you. ਾਂ	2	MR. LEOPOLD: Objection. Asked and
3	write your friend this message about this deposition?	3	answered, for the fourth time.
4	A. 108.	4	MR. TRIN: You are improperly objecting,
ಿ	So you wrote your friend that this o	5	Mr. Leopold. You have no grounds to object. And
હ	deposition is stupid court s-h-i-t, correct?	્રિ	that's mor an objection.
7	Yoa. A.	2	MR. LEOPOLD: It is an objection.
ાને	Because you think this deposition is stupid ்.	8	MR. TEIN: Then terminate the deposition if
ರಿ	court s-h-i-t, don't you?	9	you think it's been asked and answered.
10	No . તે.	10	MR. LEOPOLD: Counsel, I am not precluded
11	You wrote that to your friend, didn't you? 0.	11	from just making an objection to the form of the
12	Yes. ಸ್	12	question. As the courts well know, and if you
13	You think that court is stupid, dom't you? 0.	13	practice here in Wost Palm Reach, many of the
14	In some cases. 2.	14	judges require you to sat the objection with
15	And you think that court is bull s-h-x-t, ்.	15	specificity. And I will do that. And if you
16	don't you?	16	don't want ma to, you can make the record. But I
17	A. NO.	17	will do that.
18	And you think this deposition is ball o	28	MR. TEIN: Here's what we'll do, Ted. You
19	s=h=1-t, don't you? "	19	can -- I will allow you to reserve an objection to
20	2. No .	20	form for every single one of my quastions.
21	You wrote that to your friend, didn't you? 0.	21	Otherwise, all you're doing is obstructing.
22	MR. LEOPOLD: Objection. Asked and	22	HR. LEOPOID: I won't do that.
23	answered.	23	MR. TEIN: Of course; because you want to
24	MR. TEIN: That's not an objection.	24	obstruct.
25	BY 2003. TEIN !	25	MR. LEOPOLD: All right -

1655 Palm Beach Lakes Blvd., Suite 500¶

nsor & Associates Page 23 BY MB. TRIN: 2 you think that giving testimony ਼ 2 gath, is ball s-h-i-t, don't you? today, under 3 No. A. And you wrote that to your friend on 0. week, didm't you? MySpace last thjection. Asked and MR.. LEOPOLO: ed 8 87581 THE MITHISS : No, I did not 0 BY MA. TEIN: 10 11 You dion's write this exhibit? 0-I wrote that, but I didn't write what you 12 A. 13 said. Tou wrote in this exhibit, "I got some 14 0stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 15 16 you urite that? 17 A. You. Referring to this deposition, didn't you? 18 0. a. Referring to the court. I was later 19 20 informed that it was a deposition. 21 0 I'm going to ask you some questions about what happened when you went to Jeff Epatein's house 22 23 three years ago. Okay? 24 A. Uh-huh. When the police interviewed you one month 25 ୍ଦ Ph. 561.682.0905 - Pax. 561.682.0905 - Fax. 561.682.1771. 16SS Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401.¶

	Page 24
	after you went to Epstein's house, you swore on your
1	mother's grave that you and Epstein did not engage in sex
2	of any kind?
3	A. Yes.
4	Didn't you tell that to the police? 0-
5	Yes. And I will continue, I have never A.
6 7	had sex with him.
	Did what happened upstairs at Jeff 0.
E 9	spetein's house take you completely by surprise,
10	Yos. A.
	Now the civil complaint that you filed ்
11 12	against Mr. Epstein for fifty million dollars alleged
13	that you were totally shocked by what happened when you
14	got there.
15	Yes. A.
16	were you totally shocked by what happened o
17	when you got to Epstein's house?
18	Yes. A.
19	You didn't expect it at all, did you? ்
20	50. A.
21	You had absolutely no idea why your friend ்
22	vas taking you to Epatein's house, right?
23	I was informed it was a massage. A.
24	' All you thought that it was going to be was o
25	a massage, correct?

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	Page 27
1	MR. LEOPOLD: If you do it one more time,
2	we're leaving.
3	DT MB. TRIN:
4	0-
5	Ma. LEOPOLD: I'm going to make the recogd.
6	You cannot interrupt me when I'm making the
7	record. Out of professional conduct, you cannot
8	do that. I'm entitled to make the gecord. I ande
9	an objection, asked and answered. Your demeanor
10	is inappeopriate. You're willing and you are able
II	and you're responsible to ask a question in a
12	professional manner, and ask the question and once
13	you get the answer, to either follow up on it or
14	move on, but not continuously browbeat and ask the
15	game question over and over because you don't like
16	the answer.
17	MR. TEIN: Calm down, sir.
18	MR. LEOPOLD: Trust me, I'm very calm here.
19	When I'm not calm, you'll know it. I'm very calm.
20	50 please continue on. But I will not
21	allow you to continue to harass her in the
22	demeanor that you're doing. Ask her a question
23	and nove 001.
24	FR. TEIN: Are you done?
25	MR. LSOPOLD: Thank you.

	Page 28
1	MR. TEIN: Stop misrepresenting the record
2	and calm down. I'm going to ask my question.
3	Stop it.
14	BY MR. TEIN:
5	0.
6	MR. LEOPOLD: I think the record is very
7	clear.
8	MR. GOLDBERGER: Let me just clarify
9	something. When you object to the form of a
10	question, you're not imstructing the witness not
21	to answer the question, are you?
12	MR. LEOPOLD: No. And I'm not making that
13	objection; only on attorney/client privilege.
14	KR. TEIN: Will you stop speaking now so I
15	can ask my question? Are you done?
16	Okay. I'm going to ask my question.
17	BY MR. TRIN:
16	Listed, ்.
19	BR. LEOPOLD: Held on. Stop.
20	I've been doing this for 20 plus years and
21	have net a lot of attorneys, but I've never had an
22	experience like this where 1've --
23	MR. TKIN: Stop your speaches.
24	MR. LEOPOLD: If you continue to do this,
25	whether it's with me or with my client, I will not

Case 9:08-cv-80119-KAM¶

Document 15-2¶

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Consor & Associates¶

	Page 29
1	put up with it and I don't meed to put up with it
2	and it's not sppropriate. And I'm sure
3	Mr. Goldberger knows all this, because I know that
4	he wouldn't do this. So I will mor put up with
5	and I think it's highly inappropriate to do it.
Ch	this with this child sitting here, the way you're
7	acting, primaxily towards me, and I will not put
8	up with it.
9	Na. TRIN: Will you please stop your speech
10	so I can ask questions?
11	MR. LEOFOLD! So long as you act
12	professionally, I will do so. But if you contimue
13	to do it this way, I will leare.
14	MR. TEIN: Suit yourself.
15	By Mk. TEIN:
16	are you sure that before you got to 0
17	Eparein's how mo one tried to persuade you to engage in
18	sexual activity with Epstein for momey?
19	NR. ISOPOLD: Asked and answered.
20	Objection.
21	MR. TEIN: Did you get her answer?
22	THE COURT REPORTER: Wo, I did not.
23	THE MITHESS: I'm 8010.
24	BY MR. TEIN:
25	iet me ask you a few quastions about your 0.

	Page 30
	contact with Jeffrey Epstein. Okay?
2	[Witmess nods head up and down.) A.
3	Jeff never e-mailed you, did he? o
4	No. 2.
5	Jeff never text mensaged you, did loe? 0
6	190 . A.
7	Jeff never chatted in a chat goom with you, o.
8	did he?
9	No. 3.
10	Before you got to Epstein's house you had ்
11	never spoken to Jeff, had you?
12	No. A.
13	And before you got to Epstein's house you 0-
14	had never met Jeff?
15	Correct. A.
16	Before you got to Epstein's house you had o
17	never told Jeff that you were under 18, right?
18	100 . ﺎﺗ
19	Before you got to Epatein's house had you 0-
20	ever told Jeffrey that you were under 18?
21	No. I never spoke to the man before that. A.
22	and you only went to Jeff Epstein's house o
23	that one time three years ago, correct?
24	You. A.
25	You paver went there again, correct ? ்.

Page 9 of 35¶

	Page 31
1	No. A.
2	All right. Let me ask you two final areas 0-
ﻟﻤﺎ	of questioning about this and we'll move onto something
4	Oxay? else.
5	Oh-huh. Yes. I'm sorry. A.
ಕ	Before you got to Epatein's did anyone ்
7	associated with Epstein ever call you on the phone and
B	try to persuade, induce, entice or coarce you to engage
9	in any senual activity?
10	190 . A.
11	Bafore you got to Epstein's did smybody ្ន -
12	associated with Epstein ever contact you on the Internet
13	and try to persuade, induce, ontice or coerce you to
14	engage in any sexual activity?
15	Ho. A.
16	who told you that when you got to 0.
27	Jeff Spatain's house you should lie to Jeff about your
18	age 7
19	B.
20	or was it the other girl in sas it ं
21	the car who you rode over with to Epstein's house?
22	A.
23	Who was the other girl in the car with you 0-
24	that day?
25	I honestly don't know. A.

		Page 32
1	o	Bad you ever seen her before?
2	B. .	No, sir.
3	o	You told the police that when you rode over
4		to Epstein's you had no idea who she was, right?
5	A.	Correct.
6	o	You told the police that you didn't know
7		her name, but she was like really dark, kind of like a
B	Spanish girl?
ച്ച	A.	Yea.
10	்	Those were your words, right?
11	A.	You.
12	்.	Do you now know who she is?
13	A.	No, vir.
14	்	strooms sil of to lie about Bo it was
15	your age to Joff Epstain?
16	A.	Yes, sir.
17	்	told you that if you weren't 18, And
16		Epstein wouldn't let you into his house, right?
19	A.	That's == yes, yes.
20	்	All right. Let's talk for a minute about
21		when you first met Jeff. Okay?
22	A.	Sure.
23	்	When you first met Jeff he tried to find
24		out how old you were, right?
25	A.	Excuse no7

Entered on FLSD Docket 06/30/2008¶

Page 10 of 35¶

	Page 33	Page 34
	When you first met Jeff he tried to find Q.	NR. TEIN: I know how to do this.
	out how old you were, right?	MR. LEOPOLD: Then show her a document.
3	Not when we first introduced each other; A.	NR. TEIN: Stop speaking.
	when we get upstairs, then, yes.	MR. LEOPOLD: I'm not going to stop
ಲಾ	During the massage Jaff asked you how old ்	speaking. I'm going to continue to make the റി
6	you were, correct?	record. હ
	Tes, yes. A.	MR. TEIN: You're obstructing. Please 7
8	Wow hadn't you already told Jeff's 00	atop. ള
9	assistant, the one who walked you upstairs, that you went	NR. LEOPOLD: I'm not obstructing. But if ਹੈ
10	to college and had just noved down here from Dhio?	you want to refresh her recollection, you need to 10
11	I never spoke to the lady. A.	show her something. 11
12	Do you want to rethink that answer? 0.	That's not a proper question. I object to 12
13	MN. LEOPOLD: Is that a quastion?	the foundation and the predicate of that question. 13
14	BY MR. TEIN:	MR. TEIN: Are you done? 14
15	Do you want to rethink that answer ? ்.	MR. 1EOPOLO: I am now. Thenk you. 15
16	No. I didn't really speak with her that 2.	BY MR. TEIN: 16
17	auch.	Do you want to try to refress your memory ்- 17
18	Do you want to try to refresh your memory 0.	as to whether you had any conversation with the woman who 18
19	on that?	walked you upstairs in Epstein's house in which you told 19
20	MR. LEOPOLD: Bo you have something to	her that you went to college and had just moved down from 20
21	refresh her momory with?	Chic7 21
22	MR. THIN: Do you want to stop making	MR. LEOPOLD: Objection. Object to the 22
23	speaking objections?	form of the question. Lack of foundation and 23
24	MR. LEOPOLD: No. But to refresh admoone's	predicate. 24
25	memory, you show then a document	BY MR. TEIN:

0¶

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

	Page 36
1	that when you lied to fpstein sbout your age that you
2	said it really fast so Epatein wouldn't realize you were
3	lying?
4	A. No, I don't remember saying those words
5	exactly to har. I remember tolling her that I told
6	Epstein I was 18.
7	Does it sound right to you that you told a
8	Betective Pagan that you said your age really fast to
9	Enstein --
10	M8. BELCHIAVEK: Objection. Aaked and
11	answered.
12	BY MR. TEIN:
13	-- so he wouldn't think that you were o
14	lying?
15	NR. IBCROLD: Objection. Asked and
16	answered, lack of foundation, mischaracterization,
17	of her earlier testimony. She's already answered
18	that question.
19	BY MR. TEIN:
20	You can answer it. ்
21	MR. LEOPOLD: Same objectian. It's been
22	asked and answered.
23	You can answer. I've made the objection.
24	THE WITNESS: I forget the question, now.
25

Entered on FLSD Docket 06/30/2008¶

Page 11 of 35¶

	Page 37		Page 30
	BY MR. TEIN!		8. Ted.
2	Let me put it again. o	2	Was that the Cruth? 0.
	Does it sound right to you that you told		at So .
	Detective Pagan that when you lied about your age to		In fact, you went to Royal Palm, right? Q.
ന	Jeffray Epstein, you said it really fast because you	5	Yes. A.
ക	didn't want to make it sound like you were lying?	દે	So you lied to Mr. Epstein again, correct? 0
7 -	MR. LEOPOLO: Objection. Lack of	7	B. Yes.
ಆ	foundation, asked and answered:	ાનિ	Is Wellington the college that you told 0-
ੈ	THE WITNESS: I could have possibly said	d	Jaff's assistant that you were attemding?
10	that, yes,	10	I don't remember having that conversation A.
12	BY MB. THIN:	11	with her, no I wouldn't know if that's what I said.
12	You didn't want Nr. Epstein to know that o	12	That was a lie, though, wasn't it? ்.
13	you wore lying about your age, right?	13	MR. LEOPOLD: Objection to the form of the
14	Correct. A.	14	question, lack of foundation. You're making an
15	You didn't want Mr. Epstein to know that 0.	15	assumption. She just answered you she can't tell
16	you were not 18 yet, right?	16	you that.
17	Correct. A.	17	NR. TEIN: Speaking objection. And you
18	You wanted Nr. Epstein to believe that you 0	10	well know that, Mr. Leopold.
19	really were 18, right?	19	MR. LEOPOLD: She can't answer that
20	a. Correct.	20	question. The way you phrased that question,
21	Do you remember whon Mr. Epstein asked 0.	22	you're purposaly making her not be honest in her
22	where you went to school?	22	testimony. She can't answer a question like that.
23	A. tea.	23	She doesn't reneaber. So them you #4y, "So you
24	And you told Mr. Epstein you want to ்.	24	were lying." That's improper and you know that.
25	Wellington, Iight?	25	That's not a proper calestion. And only actorney
	Ph. 561.682.0905 - Fax. 561.682.1 1655 Paim Beach Lakos Blvd., Suite 500 - West Paim Beach, FL 334		Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Sube 500 - West Palm Beach, FL 33401

6¶

	Page 39
1	that would do that to a witnesses or to a person
2	that's sitting in this chair is not acting
3	profossionally. You can't ask a question like
4	that. You can do it, but it's not proper. And
5	I'm sure you weren't trained that way, cartainly
6	not ethically.
7	MR. TEIN: Will you stop?
8	MR. LEOPOLD: I'm not going to stop,
9	because the way you're asking that question is
10	improper and you know it.
12	MR. TSIN: You're losing your cool.
12	BY M. TEIN!
13	Na o
14	MR. LEOPOLD: Trust ma. I'm very calm.
15	When I lose my cool, you'll know it.
16	MR. TEIN: I do know it.
17	BY MB. 78IN:
18	Mr. Epstein never asked you Mo. o
19	to do anything other than massage him, correct?
20	Incorrect; bocause he asked mo to take off A.
21	my bra, so that would be two things he's asked me to do,
22	Other than asking you to take your bra off, o
23	Mr. Epstein nover asked you to do anything with him other
24	than massage, correct?
25	MR. LEOPOLD: Objection. Toundation,

		Page 40
	predicate.
1	THE WITHESS: Correct.
2	BY MR. TEIN:
ﻟﻤﺎ	0.	You told the police, in your words, that
6 5	you did not shack him off, right?
6	Correct : A.
7	Mhat does that mean? ্র
B	Mhack, like whacking off? 2-
9	Your term, what cloes that mean? o
10	Masturbating. N.
11	்	Mr. Epstein never tried at any time to grab-
12	your hand, did he?
13	190 . Ba
14	்.	Nr. Epstein never tried to put your hand
15	anywhere, did he?
16	No. R.	At no time did you towch Mr. Rpatein's
17	o
18	penis, did you?
19	No. A. Mad he did not touch you, correct?
20	். Incorrect.
21	A.	Woll, you told the police, "At no time did
22	் he touch ma." Ware you lying to the police them?
23	ﻟﯿﮯ	Mo. Well, I wasn't being fully truthful,
24 25	but I wasn't lying.

Entered on FLSD Docket 06/30/2008¶

Page 12 of 35¶

Page 41	Page 42
You sold the police twice when you spoke to 0- Michelle Pagan that "at no time did he touch me." Didn't	NO . A. No type of intercourse with Jeff, correct? 0-
you say that to the police ? Yean. A. and you're saying that that was not fully 0	Correct . R. 3 All right. Let's talk about what happened 0. 4 after the massage was over.
5 trathful. Is that what you're saying now? Correce. Ba 7 And you're saying if you're not fully 0. 8	5 Oksy - A. ಲಿ after the massage, you told Epstein that 0- 7 you wanted to bring your twin sister back so she could 18
truchful, that's not a lie. Correct? ಿ You took that our of contaxt like really A. 10 bad. I didn't mean like that. Touching my legs and -- 11 he nover kept his hands to himsels the entire time.	make some money, correct? 6 Incorrect. Ba- 10 right? Tour twin sister is 0. 11
12 That's what I'm trying to say. 13 You told the police, "at no times did he 0- 14 touch mo." You agree with that, correct? 15	Correct. 24 12 very much, don't you? and you love 0. 13 YOS. A. 14 And when you laft the house you were joking 0.
No, I don't agree with that, because he did R. 16 Couch IM. 17 Did you tell the police that he did not 0 18	15 with the other girls, weren't you? 16 Incorrect. A. 17 and the other girl in the Well, when 0 18
touch you, yes or no? 19 It's a possibility, hut I do not remember. ત્વે 20 Okay. And you did not have any type of sex 0.	car that day made their statements to the police they 19 told the police that you were joking afterwards. Are you 20 saying that they were lying to the police about that?
21 with Jeff, correct? 22 80 a A. 23 And you did not have any type of oral sex	21 No. But a gaestion or -- questions from A. 22 like she asked no questions, but it wasn't 23 joking. She was kind of like in a happy way, like, "Dh,
0. 24 with Jeff, correct? 25 Ph. 561.682.0905 - Pax. 561.682.1771	24 what did you do? What did you do?" Like those kind of Carlos Concession Compression Comparis Comparis Comparis Comparis Comparis Comparis Comparis Comparis Comparis Comparis Comparis Comparis Comparis Comparis Comparis Comments 25 Ph. 561.682.0905 - Fax. 561.682.1771
1655 Paim Beach Lakes Blvd:, Sulte-500 - West Palm Beach, FL 33	1655 Palm Beach Lakes Bivd., Suite 500 -- West Pairn Beach, FL. 33401

	Page 43
2	things, but is wasn't joking about it at all.
2	You joked about it, didn't you? 0-
3	190 . 3.4 that if you did this
4	You said to 0
5	every weekend you'd be rich, didn't you? . 016 0103
	That's what No. A.
7	Tou didn't tell that to ் Asked and
	MB. ISOPOLD: Objection.
9	answered.
10	THE SITEESS: 190 .
11	BY MR. TEIN: Mftar you left Epatein's house you took the
12	் and the other
13	mopay and you went shopping with
14	girl in the car, correct? Incorrect. I didn't spend any of the
15	A.
16	noney . You wont to Marshall's, didn't you?
17	Q. I went along, yos, but I didn't -- 24
18	You went shopping with them at Marshall's, Q-
19	didn't you?
20	objection. MR. LEOBOLD:
21	I quess you could say that. THE NITHESS :
22 23	MR. ISOPOLD: Objection. Iack of predicate
24	and foundation. Mischaracterization of earlier
25	bestimony.

	Page 44
	BY MR. TEIN:
2	bought a parse, right? And 0-
3	Yes. A.
4	And you were with her the whole time at ்.
5	Marahall's, correct?
6	Yes. A.
7	Now tell me about when the federal ்
8	prosecutors told you about getting reimbursed.
9	I have no idea what you're talking about. A.
10	Tell ne about when the faderal prosecutors ்.
11	spoke to you about getting money you feel you're entitled
12	to from Mr. Epstein.
13	I don't know what you're talking about. A.
14	po you know who Marie Villafons is? 0-
15	Ko, sir. 1.
16	Did you ever meet with any federal o
17	prosecutors?
18	I think -- yeah. I think they were -- 24
19	think they were like FBI.
20	Uh-huh. Did you meet with federal o
21	prosecutors?
22	They cans to my house one time, yes, A. When did they come to your house?
23	்
24	Wery long ago. Ra Was it this year, 20087

Case 9:08-cv-80119-KAM¶

Document 15-2 - Entered on FLSD Docket 06/30/2008¶

Page 13 of 35¶

	Fage 45	Page 46
	It was not this year, no. &	Mo, siz. 3.4
2	Was it 2007? 0.	Asked and MB. LEOPOLD: Objection.
	I'd have to say at lesst two years ago or a a -	answered. 3
	year ago, yeah. So it would be 2007, 2006; but it was a	BY MB. TEIN: 4
	while ago.	so if I say the mans to you Marle 0. 19
6	How many federal prosecutors or FBI agents 0-	Villafona, you don't know who that is? 6
7	came to your house?	No, 51.1. A. 7
8	I'm trying to resember. I want to say four A.	Bow nany women and how many men came to 0 P
ਰੇ	people came.	your house? ಿ
10	Did they give you their business cards? o.	I want to say two ladies and two guys. A. 10
11	If they did, I don't remember, and they R.	Did someone named Jeffrey Sloman come to 0 11
12	weren't toward ne. Maybe my parents have them. I don't	your house? 12
13	"MOUTH pid they give you their cell phone numbers?	I don't know names, sir. A. 13 Do you know who Jeffrey Sloman is?
14	்.	0- 14
15	-04 A. Did you ever speak to them on their call	No, sir. A. 15 Do you know who. Jeffrey Herman 187
16	0	0 JE
17	chones 7 300, 852.	Yes. A. 17 That's the lawyer who first sued Epstein on
10	A. Did they speak to your parents?	0. 18
19	0- That's something you'd have to ask my a.	your behalf, right? 19 140. at
20		20 Has Nr. Hernan advanced your family any 0.
21	parents. Do you know whether they spoke to your 0	21 money?
22	parent's?	22 MR. LEOPOLD: Any conversations that you've
23 24	No, 815. 2.	23 had with Mr. Herman regarding that issue, you are
25	You have no idea? 0-	24 not to disclose. If you've learned in some other 25
	Ph. 561,682,0905 · Fax. 561,682.	Ph. 561.682.0905 - Fax. 561.682.
	1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401	1655 Paim Beach Lakes Blvd., Sulte 500 - West Palm Beach, EL

0¶

	Page 47
	fashion, you may answer.
1	THE WITNESS: Okay.
2	I wouldn't know.
3	BY MR. TEIN!
14	You don't know? 0 -
5	No. A.
6 2	NR. LEOPOLO: Objection. Foundation.
0	Attorney/client privilege.
9	BY MR., TEIN:
10	And you say you don't know who Jeff 51oman ்.
11	287
12	No, Bir. h.
13	Does it refresh your recollection that has o
ી ન	the number two prosecutor at the U.S. Attorney's Office?
15	190 a A.
16	That he's Marie Villafona's boss? 0-
17	190 . 2.
18	Does it refresh your memory that ho's the ்
19	ex-partner of Jeff Marman, the first lawyer who sued
20	you -- pued Mr. Epstein on your behalf for fifty million
21	dollars? No, six. I don't know who he is.
22	A. without telling me any conversations that
23	். you've had with your lawyers, how is it that you sekected
24	Mr. Herman as your lawyer from the 81,000 members of the
25	Ph. 561.682.0905 - Fax, 561.682.1771

		Page 48
	Florida Bar?
1 2	A.	I did not select him.
3	् -	Who did?
4	24	By father.
5	்.	Did you ever meet Mr. Herman?
6	8.	රියාරණ -
7	0	Don't -- don't tell me what you discussed
8		with him. Where did you meet him?
9	A.	I was shopping in my -- ha showed up at my
10	friend's house.
11	0-	Whose house?
12	A.	My friend from the Quarterdeck
13	0-	Is that
14	Tavora?
15	A.	Yev. and did you have a meeting with him at
16	0-	house?
17		Yes. I goass you could say that.
18	A. 0-	And who else was there?
19	R.	By Aunt
20	0.	And what was that meeting about?
21		MR. LEOPOLD: Objection. That calls for
22 23		attorney/client privilage.
24	BY MR. TEIN:
25	o	What discussions did you have with

Entered on FLSD Docket 06/30/2008¶

Page 14 of 35¶

	Fage 49	Page 50 Why did the meeting take place at
	Mr. Herman in the prosence of	0
	None . A.	Crase ?
3	What discussions did you have in the 0.	I spent the night that night at her house. A. 3
	presence of her aunt?	And when was this? 0.
ട്	of my aunt? A.	A while ago. 2.4 5
6	MR. GOLDBERGER: It's the witness's aunt.	How long ago? 0.
7	BY MR. TEIN:	& month and a half ago. I'm quessing. A.
B	ob, of your aunt. ்.	A month and a half ago? 0 9
	The caly one that we've ever dispussed or 2.	Uh=huh . R. 9
10	ever had.	So was it before of after Mr. Herman filed Q. 10
11	And so you were in a conversation with 0	the fifty-million-dollar lawsuit against Epstein? 11
12	Mr. Herman and your aunt?	After. A. 12
13	Yes, $ir. A.	Did you meet with an IBI agent named 0. 13
14	And you discussed privileged matters during ្នុ	Beabitt Kurkendall, a woman? 14
15	that conversation?	I don't know. A. 15
16	MR. LEOPOLD: Object to the form. I think	pid Ms. Burkendall speak to you about 0 16
17	you might have to educate her on that question,	getting reimbursed from Mr. Epatein? 17
18	BY M8. TELN:	I've never had a discussion with anyone 2. 18
19	You discussed the lawsuit? 0-	about getting reimbarsed from Mr. Epstein. 19
20	You. A.	Have you met with an agent named Jason 0 20
21	tell you about any ्र व ்	Bichards? 21
22	conversations that sho had with Mr. Hernan?	Not to my knowledge. A. 22
23	As fax as I'm concerned, she's never spoken A.	Bow about an agent named Tim Slater? 0 23
24	or she's never had a conversation. She only opened the	No, sir. R. 24
	door and then left. She's the one who answered the cloor.	How about an agent named Junior Ortix? Q- 25
25	Ph. 561.682,0905 - Fax. 561.682.1	Ph. 561.682.0905 - Fax. 561.682.1771

	Page 51
	No. A.
2	And we've learned that many of the girls, 0.
3	some of whom are as old as 23, were told by the
0	government that they would get money at the end of the
5	criminal prosecution. Does that sound familiar to you?
6	No, sir. A.
7	Other than Mr. Lecpold here == I'm not o
E	asking about Mr. Borman either ==
9	0ks=hidh . A.
10	-- did snyone ever discuss with you that ்
12	you could get reimbursement for your damages?
12	be, sir. A.
13	Did you or any member -- ्.
14	MR. LEOPOLD: Are you referring to a
15	criminal matter or a civil matter?
16	BY MR. TEIN:
17	Did you or any member -- o
18	MR. LEOPOLD: Excuse me. Let me object to
19	the form of the question.
20	BY MB. TEIN:
21	Did you or any member of your family ever 0.
22	get a victim notification letter from anyone?
23	I no longer live at that residence and I A.
24	wouldn't know.
25	So your testimony is that you have never o

		Page 52
1		remained a victim notification letter, correct?
2		røgt.
3	0-	And your testinony is that you don't know
4		if your parents have ever received a victim notification
5	letter, correct?
હ	a.	Correct.
7	்	Have you given any evidence to prosecutors
0		or law enforcement in this case?
9	8.	What do you mean by evidence?
10	o.	Well. Anything that you can touch or feel.
11	A.	blo.
12		MB. LEOPOLD: Objection to the form of the
13		quostion.
14	BY MR. TEIN:
15	்.	Bo you haven't given anything physical =
16	A.	80.
17	்	-- any item to any prosecutor, police
18		officer or law enforcement agent, correct?
19	A.	Wy call phone four years ago or three years
20	ago, but that's it.
21	்.	You gave your cell phone to whom?
22	A.	Michelle Pagan.
23	்.	Did she keep it?
24	A.	Ask her.
25	0-	You gave it to her and then you didn't get

Entered on FLSD Docket 06/30/2008¶

Page 15 of 35¶

	Page 53		Page 54
	it back at the end of the meeting?		A. No, Bir.
2	No. They == yeah. So. They have it. I'm R.	2	You didn't want to come to court today and 0.
ਤੇ	guessing. I don't have it.	3	tell the story that you had told to the police under
4	How much money are you hoping to get out of ்	ਪ੍	osts, did you?
ಲ್	Mr. Epstein?	ಲಿ	MR. LEOPOLD: Object to the form of the
	MR. LEOPOLD: Objection to the form of the	6	question. Lack of foundation, predicate.
7	question. Attorney/client privilege.	7	THE WITNESS: No. I have no problem occaing
B	BY ICR. TEIN:	ાં જ	here and talking to you.
19	Now much money are you hoping to get, you, ்	ੀ	BY MS. TEIN:
10	yourself, hoping to get out of Epsteim?	10	And to avoid getting served with a lawful 0-
11	MR. LEOPOID: Same, Same objection,	11	subpoena, you lied about your name, didn't you?
12	attorney/client privilege.	12	A. NO
13	Don't answer the question.	13	And in fact, just lying yourself wasn't ୍ରିୟ
14	BY MR. TEIN:	14	enough, was it?
15	I'm not asking about what your lawyer told ்	15	MR. LEOPOLD: Objection to the form of the
16	you.	16	question.
17	MR. LEOPOLD: I'm instructing her not to	17	Don't answer it. It's mot a quostion.
18	answer the question, because any of those	18	object to the form of the question. Lack
19	conversations involve her counsel.	19	of foundation.
20	MR. TEIN: Certify that.	20	MR. TEIN: Are you imstructing her not to
21	MR. LEOPOLD: Please.	21	answer?
22	.	22	MB. LEOPOLD: I am.
23	ST MI. TEIN:	23	MR. TRIN: Certify it .
24	single to get out of this . Q. ිමරික	24	MI. LEOPOLD: Plusse.
25	deposition, didm't you'	25

	Page 55
1	· CERTIFIED DUESTION :
2	BY MR. TEIN:
14	You asked your co-workers -- ்
0	MR. LEOPOLD: It's vague and ambiquous.
5	BY MR. TEIN:
2	You asked your co-workers at the ்.
7	Quarterdeck Tavern to lie for you, didn't you?
00	No. I informed my boss about what was A.
0	going on and he told me that he would help in any way
10	that he can.
12	Okay. You got your friend to lie 0-
12	by switching mane tags with you, correct?
13	Incorrect. It was a coincidence that same ni
14	night she was not wearing her name tag; who was wearing
15	mine. But I was also not wearing -- I was wearing my
16	name tag. Everyone switches name tags. It just so
17	happens it was a coincidence that same night the people
18	came with the papers.
19	MR. TEIN: Will you pat up Exhibit 18-001?
20	MR. QUIDBERGER: And mark 18-001 for
21	identification purposes to this deposition.
22	MR. LEOPOLD: None of them have been marked
23	Can we mark them and put them as attechment yot.
24	to the depositions? Because I think you've shown
25	three photos now. And this is the only one that

1	Page 56 has been marked for identification yet.
2	DY MR. TEIN:
3	்
0	MR. IBOROLD: Hold on just a second. Just
5	so the record is clear --
6	NR. TEIN: I'm not speaking to you.
7	MR. LEOPOLD: Okay, Then clon't speak to me
0	But I'll speak to Mr. Goldberger, perhaps. then.
40	But at least for the record, can we put on
10	the record what the previous two photographs were
11	marked for identification?
12	MR. GOLOGERGER: Ne will make sure that the
13	record is clear at the end of the deposition ao
14	that there's no ambiquity.
15	MR. IZO@OLD: Thank you.
16	BY MR. TEIN!
17	I've put a photograph marked 18-001 o
18	up on the screen. Do you see that?
19	Yup . A.
20	Who is that in the photo? Q -
21	on the left and me on the right. A.
22	right? 0-
23	A. You.
24	your friend at the o
25	Charterdeck Tavern, right?

11¶

0¶

Entered on FLSD Docket 06/30/2008¶

Page 16 of 35¶

	Page 57		Page 58
	A. Yes.		looking for you, diem't you?
	your friend, who you say the day ்.		No. I knew -- A.
3	that the process servers went to serve you with a		MR. LEOPOLD: Just answer it. It calls for-
4	subpoena for this deposition, just happensed -- just by	4	a yes or no.
ಲ್	coincidence, was waaring your name tag?	5	THE WITNESS: Okay. Wo.
ല്	Ba Yen, 51x.	દ	BY MR. TEIN:
	And just by coincidence, you were waaring 0.	7	Now you can explain the answer that your ்
B	her name tag, corrent?	B	counsel stopped you from explaining.
ਰੁ	2. 108.	ਹੈ	Okay. I work at Quarterdeck and people A.
10	Your testimony under cath is that's just a 0	10	were telling me that people were looking for me. 30 yes,
11	coincidence, right?	11	I was aware that people were searching for me. But I had
12	A Total honesty.	12	mo idea who they were or what their intentions were. But
13	It just happens to be the day that you were ்.	13	I thought they were just people I didn't want to talk to.
14	going to be served with a subpoens, correct?	14	So I just didn't want to talk to them. And every time
15	Bau That wasn't the first day that ==	15	they'd come to work I wasn't there. And 80 happens the
16	ust answer the MB., LEOPOLD:	16	night that they came in me and my friend switched name
17	quostion. It calls for a yes or no.	17	tags. No hig deal.
18	THE WITNESS: Yes.	18	That's a lie, isn't it? ்
19	BY MR. TEIN:	19	MR. LEOPOLD: Objection. Don't anawer that
20	You said that wasn't the first day you were ்	20	question. That's harasmant and I will not allow
21	going to be -- you thempht you were being served with a	21	He could ask the questions and we'll allow a it.
22	subpoena, correct?	22	jury to make that determination, but not counsel.
23	A. Correct.	23	I will not allow her to answer that
24	You knew before the day that you switched 0.	24	question.
25	hat the process servers were name Lags With	25	MR. TEIN: Certify it.

	Page 59
	MR. LEOPOLO: I'll certify it.
2	· · · · CERTIFIED QUESTION . ·	2
3	She's answered that question. She's explained it five	3
4	times already. The fact that Counsel doesn't like the
5	answer, that's a different quary.	12
6	MR. TEIN: Stop making speaking objections.	6
7	MR. LEOPOLD: I'm not. I'm not going to	7
8	put up with it, because it's in appropriate, Jack,	ਲ
9	and you know it. I will not allow Counsel to	40
10	berate a witness, whether it's in a criminal case	10
11	or a civil case, whether my client or ==	11
12	MR. TEIN: Calm down.	12
13	MB. LBOPOLO: Excuse Int.	13
14	No, I'm not going to allow it. That is mot	14
15	proper.	15
16	MR. GOLDERGER: Okay.	16
17	MR. LEOFOLD: If he wants to say that she's	17
18	lying after asking it five times and her	18
19	explaining in great detail, he can do that. But	19
20	I'm not going to allow her to answer, nor be	20
22	harassed by him. It's improper.	21
22	HR. COLOBERGIR: Okay. But your response	22
23	that Counsel doesn't like the question == or	23
24	doesn't like the answer - just let me finish.	24
25	MR. LEOPOLD: Absolutely. I wasn't going	25

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

Entered on FLSD Docket 06/30/2008¶

Page 17 of 35¶

	Page 61		Page 62
	MR. LEOPOLD: This is really big stuff that		MR. TEIN: That's obmoxious. Stop being
	you're going through. But that's fine; just ask	2	obnoxious. It's stupid. Iet's go abead with the
	your question and move on. But do it one time.	44	questions.
	If you don't understand it, I'll let you follow		MR. LEOPOLD: I will make the record.
	up, but I'm not going to allow you to ask the sume	5	MR. TEIN: let's get on with the questions.
	question time and again and then call her a liar.	ર્ભ	MR. LEOPOLO: Do you need a break?
	Just ask the question, get the answer and move to	7	(Thereupon, a recess was Eaken.)
	the maxt subject matter.	B	BY MR. TEIN:
ੀ।	NR. TEIN: Ted, I'm sitting right across	ਰੋ	after you told your manager ். Okay.
10	the table from you.	10	at the Quarterdeck Tavern everything that was going on
11	MR. LEOPOLD: Yes, sir.	11	and he told you he would help you any way he could, he
12	MR. TEIN: Please be quiet. Dom't yell.	12	hid you in the kitchen from the process servers, correct?
13	MR. IBOPOLO! I will not be quilet.	13	Incorrect. A.
14	MR. TEIN: Stop yelling.	14	Isn't it true that lying to avoid service ்.
15	MB. LEOPOLD: Lewin, when I'm yolling	15	is a meaningless lie to you,
16	you'll know it. I will not ==	16	A. Incorrect.
17	MR. TEIN: My name is not Lewis.	17	What is your manager's name? 0.
18	Ma. LETTOGD: I thought your first name was	18	A. I have three. Would you like to know
19	Lewis, Mr. Toin.	19	all --
20	MR. TEIN: You watched no for three days at	20	The s the one who lied for you? 0.
21	the evidentiary hearing where you sat in the back	21	A.
22	of the courtroom. You should know who I am.	22	do to lie for you? And what did 0.
23	Well, that's the impression MR. LEOPOLD!	23	Said I wasn't there. A.
24	you must have made in the courtroom.	24	And who did he tell wasn't there? 0.
25	I will not be quiet.	25	Ask him. A.

-... -¶

:¶

।¶

..¶

			Page 63
	1	o.	told this Where were you when
	2		nomeone that you were not at the Quarterdeck Tavern?
	ਤੇ	A.	Bating nachos.
	14	்.	At the Quarterdeck Tavern?
	5	A.	100 .
	C	Q-	What did you do so that 01 011 PIB.OW
	7		the process servars for you?
	0	A.	Nothing.
	9	்	You just got him to lie for you, didn't
10	you?
11		A.	Mo. I had mo influence on him saying I
12		Masm'e there.
13		்.	Ite took that upon himself?
14			Isn't it true that Mr. Epstein's process
15			servers had to ask the police to get you out of the
16			reatsurant so that they could serve you?
17			NR. LEOPOLD: Objection. Lack of
18			foundation, predicate.
19		BY MR. TEIN:
20		0 .	You can answer the question.
21			NR. LEOPOLD: If you know. Don't quess.
22			THE WITNESS: No. Can you repeat the
23		question?
24			MR. TEIN: Don't coach.
25			MR. LEOPOLD: Don't quess.

:¶

	Page 64
2	MR. TEIN: That's a coaching.
2	MR. LEOPOLO: No. That's an instruction to
ﻟﻨﺎ	the client.
4	MR. TEIN: No. You don't do that.
5	THE WITNESS: Can you repeat the question?
6	MR. IEOPORD: Let me just state for the
7	record --
8	BY MR. 721N:
9	Once the police -- isn't it true that ்
10	Mr. Epstein's process servers had to ask the police to.
11	get you out of the restaurant so that they could serve
12	you?
13	Incorrect. My boss called the police. A.
14	And once the police showed up, to stop you o
15	from lying to avoid service, you made up another lie that
16	the process servers had harassed you. Isn't that
17	correct?
18	24. Incorrect.
19	You lie all the time, clon't you? ்.
20	MR. LEOPOLD: Objection.
21	THE WITNESS: Incorrect.
22	BY MR. TEIN:
23	You have a MySpace page, don't you? o
24	No longer do I have a MySpace page. I A.
25	deleted it.

:¶

Entered on FLSD Docket 06/30/2008¶

Page 18 of 35¶

		Page 65			Page 66
	0	When did you delete your NySpace page?		A.	Nothing.
2	A.	A couple days ago.	2	0	Well, we're going to come back to MySpace
3	0-	Who told you to take your MySpace page down	3	in & second.
ర్తా		a couple of days ago?	4	A.	You do that.
ಲ್	A.	Mobody. I'm sick and tired of MySpace.	ഗ്രീ	् -	scoles to ask you some questions
6	0	You all of a success got sick and tired of	રુ		about why you lie about your age so often, okay?
7		MySpace and just a few days before this deposition you	7		NR. LEOPOID: Objection to the form.
B		decided to delete your MySpace page, correct?	8		Argumentative.
9	A.	Correct.	9	BY MR. TEIN!
10	்	Is that your testimony under oath?	10	0	You lie about your spe all the time, don't
11	A.	Tos.	11	you?
12	0-	Did you take your HySpace page down because	12		MR. LEOPOLD: Objection, argumentative.
13		you thought the government might subpoena it?	13		THE WITHESS: Incorrect.
14	માં	Incorrect.	14	BY MR. TEIN:
15	்.	Hadn't your MySpace page bean up for over	15	0-	You lie about your age to get body
16		three months before you took it down?	16	piercings, don't you?
17	A.	Corpect. But I also had made toms of	17	Ba	Incorrect.
18		Ny@paces over the last years. I just get tired of them	18	0	You have body piercings, don't you?
19		and delete them because -- drama -- and make new ones.	19	મું	Yes.
20	்	We re going to talk about that.	20	0-	You have four body piercings; isn't that
21		So you deleted your RySpace page after you	21	right?
22		were already under subpoems for this deposition, correct?	22	A.	Five.
23	B.	Correct.	23	்	Other than the piercings on your ears --
24	0-	What about the MySpace page didn't you want	24		I'm not talking about that ==
25	us to bee,		25	A.	Oh, then no; just one.

.¶

1	POSTER FOR T. THEW SEARCH PARTS CONSULTION CONSULTION THE CONTRACT CONTRACT
	Ph. 561.682.0905 - Fax. 561.682.1771 1655 Paim Beach Lakes Blvd., Suite 500 - Wiest Palm Bea

	16 2008 08 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000 000

		Page 67
1	்.	And where is the one body piercing?
2	A.	B&lly.
3	்.	When did you get that 7
4	A.	For my birthday, with my stepmother and my
Ca	father.
6	்.	And when was that?
7	A.	When I was 14.
B	்.	Ocay. So you had that body piercing when
9		you met Epstein, correct?
10	ﺗ	It might have been, or maybe that == yeah,
11		wither my 14th birthday or my 15th. I honestly dom't
12	renember.
13	o	Now you've lied about your age to get into
14		hars by using driver's licenses that aren't yours,
15	GDETACT 7
16	R.	Incorrect.
17	0.	Are you swearing under cath that you've
18	never done that?
19	h.	Tes, I suear under oath.
20	o	And you've lied about your age to buy beer,
21	correct?
22	A.	Incorrect.
23	்.	You're swearing under oath that you're
24		never lied to stores about your age?
25	A.	I we never lied to a store about my age or

		Page 68
1	anything.
2	்	You try to look much older than you are,
3	don't you?
4	B.	Incorrect.
5	0-	And you've lied about your age on your
6		MySpace pages, don't you?
7	2.	Incorrect.
B	0.	All right. Let's look at Exhibit 26-01
9	· 0410
10		MS. BELOHLAVEK: 26-001?
11		MB. TEIN: Yes.
12	BY MB. TEIN !
13	o	On this page you lied to everyone that you
14	ware 18, didn't you?
15	A.	Correct.
16	o	Let's go to Exhibit 33.
17		MS. BELOHLAVEK: That's 33-002?
18		TEIN! Correct.
19	BY MR. TEIN:
20	o	On this page you lied to everyone that you
21	were 19, didn't you?
22	A.	Incorrect.
23		MR. LEOPOLD: Just answer the question.
24		THE NITNESS: Oh, incorrect.
25	BY MR. IEIN :

Entered on FLSD Docket 06/30/2008¶

Page 19 of 35¶

	Page 69			Page 70
	Mos you can explain your answer. 0.			Correct. There was a rule many years ago A.
2	I know that I have seen all of these and I A.			that you had to be 18 to have a MySpace.
ತಿ	know that this one is mine.		3	So you lied about your age so you could 0-
	Can your go down?			post on MySpace, right?
	MR. IEOROLD: Just for the record, you're			A. Yes.
	pointing to the photo.		6	் Let's go back to the top one on this page,
	THE WITHESS: I'm pointing to --		2	33-01.
H	DY MR. TEIN:		8	Arm you testifying now under oath that this
ਰ	You're pointing to the one where it says ்.		9	MySpace page where the headline says. "Twins do have more
10	your age is 167		10	fun, " and the location is given as Lox, abbreviation for
11	Correct. A.		11	Lowahatchee, and the age is 19, and it says,
12	That's yours, right? ்.		12	is it your testimony that you did not post
13	Correct. That's nime from a couple years A.		13	that?
14	ago that I have not been on, because I don't use that.	14	A. Correct.
15	Please keep going down, please. And I think that's it,		15	Now let's go back to the one that you ware 0-
16	because there's no one == just that one is mine.	16	pointing to before on this page, where it says your age
17	So the one you pointed to where it says 0-		17	is 18 and you lied about your age to post MySpace, okay?
18	your age is 18, that's yours, correct?		18	A. Ch-hub, yea.
19	ારે Correct.		19	All right. Why did you finally put your 0-
20	And when you wrote 18 as your age on your 0-		20	true age on your HySpace profile four days before you
21	MySpace page, that was a lie, wasn't it?		21	were scheduled to testify before the Grand Jury?
22	Correct. h.		22	I don't know what you're talking about. A.
23	Did you lie about your Myspace page back 0-		23	MB. LEOPOLD: If you don't understand, ask
24	then because you couldn't post on My8pace unless you ware		24	him to ask the question again.
25	167		25	MR. TEIN! Don't coach.
	105 Paim Beach Lakes Blvd., Suite 500 = West Palm			Ph. 561.682.0905 · Fax. 561.682.177 Palm Beach Lakes Blvd.; Suite 500 - West-Palm Beach; FL-33401-

	Page 71
1	THE WITNESS: I don't know which MySpace
2	you're talking about.
3	BY MR. TEIN:
4	The NySpace page that you're just pointing ்
5	to, where it nays you were 18.
6	A. Yes.
7	And you were lying about your age, right? ்
8	00-20021. A.
9	Why did you finally post your true age on ்
10	your MySpace profile --
11	R. Uh ==
12	-- four days before you were scheduled to o
13	testify before the Grand Jury?
14	I honestly don't know which MySpace, A.
15	because I've had like a bazillion MySpaces, and in that
16	year, I had two, that one and another one, and that one's
17	been deleted. So I don't know which one you're referring
16	to.
19	You remember that you changed your age on ்
20	your Nyspace page from 18 to your true age just four days
21	before you went and testified in the Grand Jury?
22	A. 200 .
23	You don't remember that. ்
24	190. A.
25	Do you remamber Detective Recarey? Did you ்

	Page 72
1	aver meet a Detective Recarey?
N	I don't know the names. A.
ﻟﻨﺎ	How many different detectives has you met ්
4	with on this case from Palm Beach?
5	Probably a good six or neven, maybe. A.
0	Did one of the detectives tell you before ្ត -
7	you testified in the Crand Jury that you should take your
B	MySpace age and put your true age?
9	n. No.
10	Didn't Detective Recarey have to come to ்
11	your house to pick you up to get you to testify in front
12	of the Grand Jury?
13	Possibly; maybe because I didn't have a A.
14	ride: I was coly 14 or 15 at the time.
15	Your mom didn't drive you? ்.
16	A. 190 .
17	Stepson didn't drive you? ்.
18	I think wy dad. Oh, my dad; my dad drowe A.
19	10.
20	Your dad drove you? 0.
21	A. Yes, 812.
22	50 your testimony is Detective Recarey did a.
23	not drive you, correct?
24	HR. LEOPOLD: Objection. /asked and
25	answered.

Entered on FLSD Docket 06/30/2008¶

Page 20 of 35¶

		Page 73 TER WITNESS: No. I'm pretty sure my dad		Page 74 accused Mr. Epstein of attempting to murder your father,
		drove ne, boosuse he was there with me.	1
	BY MR. TEIN:		2	dida't you? Mo. I never beard a statement saying that
	்.	Did any detective tell you to change your	ਤੇ	A. Mr. Epstein tried to murder my father.
ಲಿ		age on your MySpace page, to put your true age?	ની	You made that statement, didn't you?
િ	A.	No, sir.	ਦੇ	் MR. LEOPOLD: Do you have a statement to
7	್ನ	Now you also lied on your MySpace page	ાર 7	show her? That's been asked and answered.
ല		about your income, didn't you?		MR. TEIN: I'm soxry. I didn't hear the
9	A.	Yes .	8 9	sitness' answer, Mr. Leopold.
10	ਾ	And you lied, saying that you made a	10	BY MR. TEIN:
11		quarter million dollars a year and higher, correct?	11	you told the police, didn't you, ் -
12	A.	As a joke, yes.	12	that Mr. Epstein almost killed your father, didn't you?
13	0-	That was a lie, wasn't it?	13	A. No.
14	B.	145.	14	Three years ago, before Mr. Epstein oven ்.
35	்	And you also lied on your WySpace page,	15	knew about this investigation, you told the police that
16		saying that you were married, didn't you?	16	Epatein had "already come to my dad's house and did
17	Bro	Possibly. And that might have been an	17	something to my dad's tires and my dad almost died. I
18	error on my part.		18	didn't want my dad to get hurt, because Jeff already
19	்	Mow you also lie to the police, don't you?	19	almost killed him."
20	Ba	190 .	20	Didn't you say that?
21	0-	Wall, you lied to the police in your	21	Not to my knowledge or recollection. I A.
22		tape-recorded statement that you gave to Detective	22	have never said anything like that.
23		Michelle Pagan thron years ago, didn't you?	23	That would have been a complete lie, 0.
24	A.	To ay knowledge, no, I did not.	24	wouldn't it have been?
25	্র	Well, you lied to the police when you	25	Teals. A.

	Page 75		Page 76
	Because Mr. Epstein never came to your Q-		Correct. I do not know her name. A.
	dad's house, correct?	24	You said, "I don't know her name, but she Q.
	A. Correct.	3	was dark like a Spanish girl." Those were your words,
	0. And no one who worked for Nr. Epatein ever	ক্	right?
5	did something to your dad's tires, did they?	5	. 60% A.
6	MR. LEOPOLD: Objection. Lack of	6	HR. LEOPOLD: Objection. Asked and
7	foundation, predicate.	7	anowered.
B	Don't guesn.	க்	BY MR. TEIN:
9	BY MB, TEIN:	ి	Who was in the car that day with you and ਂ
10	It's not true that Mr. Epstein almost ்	10
11	killed your father, is it?	11	kgain, I do not know. A.
12	MR. LEOPOLD: Objection. Asked and	12	It was your good friend ்.
13	answered, lack of foundation, predicate.	13	wasn't. it?
14	BY MR. TEIN:	14	80. I don't know a A.
15	் You can answer.	15	You lied to the police about who was in the ्रं
16	A. Ba .	16	didn't you? car with you and
17	Now you told the police that you didn't a	17	Incorrect. A.
18	know who was in the car with you and on the day	18	Let me ask you some questions about who you ्
19	you went to Epstein's house, didn't you?	19	may have spoken to about this case. All right?
20	A. Yes.	20	Ga ahead. R.
21	And that was a lie, wasn't it? ்.	21	Did you speak to your twin sister ् -
22	It's the truth. A.	22	Not in detail, but of course she knows; . A.
23	You told the police that there was someome ்	23	she's family. And yes.
24	in the car next to you and you specifically said you	24	What's her e-mail? 0.
నే వ	didn't know her mame, right?	25	I don't think she has an e-muil. A.

EFTA00222273¶

	Page 77 · What is her phone number?		Page 78 I don't know.
	0. Oh, gosh. I don't know off the top of my		A. What is his phone number? ்.
2	2.		How is that relevant? A.
3	12484 . And what is her home address? 0.	7 4	What is his phone number? ்
4	She lives with my mom. A.	e	561.719.2652. A.
ಲಿ	In Georgia? ପି -	6	What is his home address? 0-
	A. Yen, sir.	1	I don't know. A.
તિ	Did you boyEriend What about ୍ରା	ಆ	Where does he live? ்
ਿੰ	speak to him about Epstein's case?	9	In Palm Beach Lakes somewhere. A
10	That's my mom's boyfriend. My sister Bi	10	Ever been to his house? ୍ଦି -
11	doesn't have a boyfriend. My mom's husband's name is	11	A. 105.
12	so maybe you get them confused.	12	You dom't know what his address is? ୍ସ -
13	Do you know his phone number? o	13	MR. LEOPOLD: Objection. Asked and
14	A. No.	14	answered. She just said she doesn't know.
15	Where does he live? Q-	15	MR. TEIN: Don't coach.
16	With my mom. ત્વે	16	MR. LEOPOMO: Objection. Asked and
17	In the same house with her? ਼-	17	answered.
18	Yes. They're married. A.	18	BY MR. TEIN:
19	So mot boyfriend; husband? 0-	। ਰੇ	You can answer the question. ்
20	Yeah, husband. A.	20	I don't know the exact address. A.
21	about Have you spoken to o-	21	What street is it on? ்.
22	what happened in Nr. Epstein's house?	22	It's an apartment complex; its not a 24.
23	Not in detail, but he knows the basics, A.	23	street.
24	yes.	24	What's the name of the apartment complex? ்
25	What is his c-nail? 0-
	Ph. 561.682.0905 - Fax. 561.682.1771 1655 Paim' Beach Lakes Blvd., Suite 500 - West Palm Boach, FL-33401	25	Something Cove. 24 - Ph. 561.682.0905 = Fax. 561.682.1771 1655 Paim Beach Lakes Blvd .; Sulte 500 .- West Palm Beachy FL 33401 .-


	Page 79 what apartment number is it?		Page 80
	i couldn't tell you. A.		girls in this whole situation. We're not allowed to know
2	when was the last time you went there? 0-	2	each other. I didn't get the last four words.
3	Just visited this past weekend. That's the at	ਤੋ	0-
4 5	first and last time I wont there.	ની ട്	We're not allowed to know each other. A. Have you And what about ា -
ஆ	Have you spoken How about ்		of mat her?
7	to hin about your case?	6 7	No. $1r. A.
ଞ୍ଚି	No. We no longer speak. 24 .		Let's see if I can refresh your memory on ்
ರಿಗ	what's his phone number? Actually, we 0.	ಿ	her. She's the other person represented by your lawyer
10	already have his phone number and e-mail.	10	Mr. Berman, who is suing Epstein for fifty million
11	Bave you ever Mow about	31	dollars.
12	spoken to her about your case?	12	I have no knowledge of her. A.
13	I don't know an A.	13	Never met her? ்-
14	Have you ever met ்.	14	Never met her. A.
15	Bo. But just to let you know, I don't A.	15	ੂੰ -
16	really know names. If you have pictures of there facos I	16	I don't know who that is either. A.
17	could tell you.	17	who knows A person named Q-
18	All right. let me see if I can refresh ்-	28	Is that
19	your nemory.	ਹੈ ਕੇ	I don't know, sir. A.
20	Okay . A.	20	Do you remember making a statement to Q-
21	Does it refresh your memory that ்.	21	Detective Pagan that's in the police reports?
22	is the other girl who made allegations about Epstein, but	22	No, size. A.
23	refused to show to the Grand Jury when she had to testify	23	Have you read the police reports in this o
24	about them under oath?	24	case?

・・¶

i " . ---------i i ----ur --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------1¶

![](_page_21_Figure_0.jpeg)¶

How much money did¶

Ph. 561.682.0905 - Fax. 561.682.1771¶

1655 Paim Beach Lakes Blvd .; Suite 500 - West Palm Beach, FL 33401 -- --¶

I'm sorry?¶

I don't even know he gave money to my dad.¶

A¶

0¶

your father?¶

22¶

23¶

24¶

25¶

dive to¶

EFTA00222275¶

Tell me -- let's go through each one that¶

Other than the Vanity Fair reporter,¶

what other reporters have any member of your¶

Ph. 561.682.0905 - Fax. 561.682.1771¶

1655 Paim: Beach Lakes Blvd., Suite 500 - West: Palm Beachy FL - 33401 --¶

you can see in that newspaper.¶

0¶

you remember.¶

22¶

23¶

24¶

25¶

O¶

17¶

18¶

19¶

20¶

21¶

22¶

23¶

24¶

25¶

a. No.¶

A. No.¶

୍କ ପ୍ର¶

BY MR. TEIN:¶

reporters?¶

answered.¶

No 9¶

MR. LEOPOLD: Objection.¶

Asked and¶

been given money by any¶

Mas your mom spoken to any reporters?¶

MR. LEOPOLD: Ubjection. Asked and¶

Ph. 561.682.0905 - Fax. 561.682.1771¶

-1655-Paim Beach-Lakes Blvd.,- Suite 500 -- West Palm-Beach,-FL-33401-¶

Entered on FLSD Docket 06/30/2008¶

	Page 85			Page 86
1	family spoken to?			MR. TEIN: But you are micropresenting the
2	I don't know. And I know my mom has spoken A.			record and you are grandstanding for your client
3	to zero. My sister spoke to zero. My father and	3		and it's wrong. So be quiet. And you know how to
ਾ	stepmother, I wouldn't know. You'd have to ask them. I			make an objection. Make it. Otherwise stop
ટિ	don't contact them.	5		talking.
ાર	Well, I just want to know -- I don't want ்.	િ	By ME' LEIN:
7	you to -- I want to know what's in your mind. All right?	7		்
દર	MR. LEOPOLD: She just told you. She just	B		MR. LEOPOLD: Excuse me.
ದ	-- Delopment	9		MR TEIN: If you want to leave the
10	MR. TEIN: Be quiet.	10		deposition, leave. But you'll be back here.
11	BY MR. ZRIN:	11		MR. LEOPOLD: Excuss ne. If I could just
12	what I want to know is what you know from ்	15		make the record, instead of interrupting me,
13	your personal knowledge. My question to you is: What	13		please. That's what we do professionally.
14	knowledge do you have about family members of yours	14		There's a recorder here. I'm certainly not being
15	speaking to reporters?	15		obstructionist. I'm going to make the record.
16	MR. LEOPOLD: Objection. Asked and	16		But we're going to act with some semblance of
17	answered.	17		professionalism, hopefully, by all parties in the
18	And if you can't talk professionally, we're	18		room. That goes to me, that goes to your
। ਰੇ	going to leave.	19		co-counsel sitting behind you and mexe to you, the
20	MR. TEIN: Do what you want to do.	20		court reporter and everyone else in the room.
27	MR. LEOPOLD: Are you going to continue to	21		Everyone is entitled to that.
22	talk this way?	22		You've asked a question. She answered the
23	MR. TEIN: I'm not going to answer any	23		question fully and she's not going to be harassed
24	question that you ask me, Mr. Leopold,	24		because you don't like the answer. If you want to
25	MR. LEOPOLO: Okay.	25		follow up ==
	Ph. 561.682.0905 · Fax. 561.682.1771 1655 Palm' Beach Lakes Blvd., Suite 500 - Wost Paim Beachy FL-3340 J			Ph. 561.682.0905 = Fax. 561.682.1771 Paim Beach Lakes Blvd., Suite-500 - West Palm Beach, FL 33401.


	Fage 83			Page 88
	MB. TEIN: Stop andaging me. MIKE 'your			anawered.
	speech and then we'll ask the questions.	2		THE WITNESS! Wo.
	MR. LEOPOLD: Well, you wom't let me finish			BY MR. TEIN:
de	making the objection, so it's difficult to do	ব		spoken to any Mas your mom's husband ்
5	that. Bot if you want to follow with an	റി	reporters?
ବି	appropriate question, feel free to do that. But	6		Ro. A.
7	we're not going to harass the witness.	7		Has your mom's busband received any ் -
B	MR. TSIN: I disagree with everything	မြိ		money from reporters?
റ്റി	you've said. Let's ask the questions. Okay?	9		A. No.
10	MR. LEOPOLD: Mak an appropriate question.	10		Are you sure you dom't know ்
11	MR. TEIN: Are you going to stop talking?	11		MR. LEOPOLD: Objection. Asked and
12	MR. LEOPOLD: I'm going to make == protect	12		answered.
13	my client and make appropriate objections. But	13		THE WITNESS: I'm positive.
14	there's not a question pending right now.	14		BY MR. TEIN:
15	BY MR. TEIN:	15		I'll try again to refresh your mamory. ់-
16	spoken to any reporters? ் has	16		okay. A.

Does it refresh your memory that she had ் been arrested for drugs and was cooperating with¶

17¶

10¶

19¶

20¶

25¶

0¶

Detective Recarey against Epstein to get herself a better doal7¶

21
22	்		Bave you spoken to anyone else who's been
	23 at Epstein's house?
	ﺗﮯ 24 - - - - - -	No.

-1655 Palm Beach Lakes Blvd., Suite-500 - West Palm Beach, FL-33401 ---¶

Page 23 of 35¶

I dom't¶

Entered on FLSD Docket 06/30/2008 Page 24 of 35¶

Sinsor & Associates¶

		Page 89				Page 90
		· · want to know about any conversations with any lawyers,			0-	Anybody else? · · ·
2	okay --		2		A.	No.
3	A.	Uh-huh.	3		்.	When did you meet with Mr. Leopold to
ય	0-	== did you or your parents speak to any	4			prepare for today's deposition?
ട്		other law firms besides Mr. Herwan and Mr. Leopold's law	5		A.	This morning.
6	tims?		ર્દ		Q.	And how long did that meeting last?
7	A.	No.	7		A.	Until it started.
0	்.	Bow without telling me about anything that	જિ		0-	Now you told me that you previously had
ਭੇ		was said, what == did one just come to mind?	ੀ			read the police reports in this case?
10	A.	No. I was thinking about something else.	10		A.	Yes.
11	Q.	What were you thinking about?	11		0.	Have you read your statement that you gave
12	A.	Does family court matter?	12	to the police?
13	o	Okay. Without telling me what was said,	13		A.	Yes, sir.
14		who prepared you for today's deposition?	14		0.	And in what form was that statement?
15	A.	what do you mean prepared?	15		A.	What do you mean?
16	Q-	Did you talk about this deposition, about	16		0-	Bas it in the form of a police report or a
17		what would happen, with anybody?	17	transoript?
18	A.	145.	18		A.	What's the difference?
। ਰੋ	்	Don't tell me what was said.	19		0-	A transcript has questions and answers on
20	A.	Okay.	20			it. A police report is just typed out narrative.
21	்.	I'm not asking that. I don't want to know	21		A.	On, it's a police report.
22	that.		22		Q-	And when did you read the police report?
23	A.	Okay.	23		A.	A few days ago. I overread it a few days
24	்.	Who prepared you for today's deposition?	24	ago .
25	Pr. .	Mr. Lecpold.	25		Q-	Had you read it before that?
		STATIONAL PLACE TO FERE THE COLLEGE ACCOUNT CART FOR CONSULT CONSULTERS ON THE				Carrents which and which and with the stress of the submit of the stars for the states and the mail of the mail of the mail of the mail of the mail of the mail of the mail of

Ph. 561.682.0905 - Fax. 561.682.1771¶

-1655-Paim-Beach Lakes-Blvcl., Suite-500-West Palm-Beach,-FL-33401-¶

Ph. 561.682.0905 - Fax. 561.682.1771 -1655 Palm Beach Lakes Blvd .; Sulte-500 -- West-Paim Beach -FL-33401 --¶

	Page 91
1	A. No.		BY MR. TEIN :		Page 92
2	Now you told me == again, I don't want to ்.	N	0-	Bave you listened to your tape-recorded
ತಿ	icnow what was said.	3	statement to the police?
	A. Uh-huh .		A.	You.
5	You told me that you met with Mr. Deopold 0.	5	0-	Where did you listen to that?
6	this morning to prepare for your deposition, right?	6	A -	In, I think, this building. I don't know.
7	A. You.	7	It was here.
00	When did you set up that meeting with 0-	ള	் -	When did you listen to that statement?
ರಿ	Nr. Leopold to take place this morning?	0	A.	This morning.
10	Gee, like, like five days ago, four days A.	10	்.	And who was present when you listened to
11	ago .	11	that statement?
12	So you're aware that Mr. Leopold told us ்	12	A.	Mr. Leopold == and I forget your name.
13	that he could not start the deposition this morning	13		MR. GOLDBERGER: Ms. Belohlavex.
24	because he had a court appearance, correct?	14		TKE WITNESS: Ms. Belohlavek.
15	MR. LEOPOLD: Don't answer that question.	15	BY MR. TEIN:
16	Calls for attorney/client communications.	16	0.	And you hadh't listened to your statement
17	BY MB. TEIN:	17	before that, correct ?
18	Have you seen the letter that Mr. Leopold ்.	18	A.	No, siz.
19	wrote to us stating that he -- an e-mail that Mr. Leopold	19	0.	Have you met with lawyers representing
20	wrote to Mr. Goldberger stating that he could not be here	20		anyona else suing Epstein?
21	this morning because he had a court appearance. Did you	21	A.	No, sir.
22	see that e-mail?	22	0-	How many times have you spoken to officers
23	MR. LEOPOLO: You can answer that question.	23		with the Palm Beach Police Department?
24	INS WITH28S: No.	24	A.	More than I like can count. It's been
25		25		ongoing for four years, so quite a few times.

EFTA00222277¶

	Page 93		Page 94
	When was the last time you spoke with 0.	1	Basically. A.
	officers of the Palm Beach Police Department?	2	How many taped statements have you given to 0-
3	A while ago. I'd say a year ago. A.	ਤੇ	the police?
	A year ago? ்	4	One that I know of, A.
	Yeah. Maybe a year and a half. A.	ಲಿ	Just the one with Detective Pagan? ்
	Do you remember Detective Recarey? ்.	હ	A. YUS, BIE.
7	A. No.	7	How about to the PBI? Did you give any ்.
8	Do you remember Michelle Pagan, Detective ்	ଞ୍ଚି	statements to them?
	Pagan?	ಿಗ	No. Well, actually, I don't really A.
ਉ	Pr. Tes.	10	remember if that was tapad or not, to be honest with you.
10	How many times have you spoken to Detective		I had one meeting with them at my house and don't know if
11	்	11
12	Pagan?	12	it was taped. You were interviewed at
13	She was the only one I spoke to about this A.	13	்
14	until for some reason she wasn't on the case anymore.	14	house?
15	When was that? ்	15	No. That was by the lawyer. A.
16	The first meeting I aver had was with her Pre	16	Oh, by the lawyer? 0-
17	and then I think like I met with her like 10 times or 12	17	A. Ch-buln.
18	times or something like that, and then I didn't get --	10	Where did the conversation that you had ்
1 a	another investigator questioned me after that.	Ia	with the FBI take place?
20	And who was that? ్ర	20	A. At my father's residence.
21	I don't remember. A.	21	Which is where? ্র.
22	And what type of questions did they ask ்.	22	in Loxahatchee. A. (0.03
23	you?	23	ાં On where?
24	7he same. A.	24	in Loxahatchee. R.
25	The same questions all over again? 0-	રેક	And when did that take place? 0
	655 Palm Beach Lakes Blvd., Suite 500 - West Parti Beach, FL 33401		Ph. 561.682.0905 = Fax. 561.682.1771 Palm Beach Lakes Blvd., Suite 500" West Palm Beach, FL 33401


	Page 95 I'd have to say like a year and a half ago, A.	1	BY MR. TEIN:

2	a year ago. It was a long time ago.	2	்
ਤੋ	(Discussion held off the record. )	3	prosecutor's office was when?
ক	MR. 7EIN: Tell me the last answer, please.	డ్	I don't know. A.
ટે	(Thereupon, a portion of the record was read	ದ	Did any of the FBI agents tell you that ்.
ર્ણ	by the reporter. )	હ	Narle Villafona had spoken with Mr. Leopold?
7	BY MB. ZEIN:	7	A. No.
த	And who was present when the FBI spoke to ்.	க்	Did any of the FBI agents tell you that ்
તે	you at your father's house?	ಿ	Mario Villafona had spoken with Mr. Herman?
10	My atepoother was there, but she waan't Pa	10	Ba. No .
	around. She made herself like do other things,	11	Did any and agents tell you that Jeff ்
11 15	And how many FBI agents were there? ்	12	Sloman spoke with Mr. Werman.
13	A. I think four.	13	ત્વે రికిం -
14	And you don't remember any of their names? ்.	14	Did any 2732 agents tell you that Jeff ்
15	No, sir. A.	15	Sloman spoke with Mr. Leopold?
16	And were there any lawyers there? Q.	16	A. 100 -
17	Not that I know of. A.	17	Do you know whether any of the federal ்.
18	And none of them gave you their cell phone ்.	18	prosecutors allowed Mr. Herman to review a ciraft
	rningers 7		indictment ?
19		19	I wouldn't know.
20	A. No.	20	A. Do you know if any of the federal
21	And the last time you spoke to the FII was 0.	21	Page 96 And the last time you spoke to the federal ்.
22	a year and a half ago?	22	prosecutors discussed a draft indictment with Mr. Herman?.
23	A. It was a while ago.	23	I wouldn't know. A.
24 25	MR. LEOPOLD: Objection. Asked and answered.	24 25	Have you ever e-mailed with any PBI agent ். or any federal prosecutor?

EFTA00222278¶

C CO¶

UNIVULIUS D.¶

	Page 97		Page 98 A. Yealı.
	A. blog.		Have you spoken to a lawyer named Burt
2	Have you ever text messaged with any FBI ்	2	்.
ਤ	agent or any federal prosecutor?	3	Ocariz about this case?
	240 . A.	C	80. A.
	Has the FBI told you about other testimony? Q.	ತ	Do you know who Burt Overiz 187 ্র -
6	A. MO .	6	Let's see if I can refresh your memory.
7	Has the FBI told you about what other girls ்.	7	Does it refresh your memory that he's a good friend of
કિ	bave said?	B	Marie Villafona's boyfriend?
ਰੋ	No. A.	ੇ	I don't know who Marie Villafona is. A.
10	Have federal prosecutors told you what ்	10	Narie Villafona is the lead federal ்
11	other girls have said?	11	prosecutor that's on the federal part of this case.
13	A. NO .	12	Okay?
13	Do you have any way of getting in touch ்	13	A. 140 .
14	with the FBI if you wanted to get in touch with them?	14	So does it refresh your memory that Ocariz 0-
15	A. 040 .	15	is the good friend of Marie Willafona's boyfriend?
16	Now about your paremts? Do they know how won 0.	16	Wot at all. A.
17	to get in touch with the FBI?	17	poes it refresh your memory that Villafona 0-
18	I don't know. ત્વે	18	tried to get Epstein to pay for Coariz to represent you
19	And by your parents, I'm referring to both 0.	19	in the federal case?
20	sets, okay?	20	A. ్టింగ్రామం నుండి 10 కి.మీ. దూర
21	Oh. Well, I'm referring to only my dad, A.	21	Do you know if Detective Recarey has spoken ்.
22	because my mom really doesn't care to know any of this	22	with your father?
23	stuit.	23	A. ్లో
24	So the answer would be the same for your ்.	24	Do you know if Detective Recarey has spoken 0-
25	nom and	25	to your stepmother?

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


	Page 99 Po. No.		First off, this is not a warehouse. This
	How BDOut WI! 0-		15 11
			garage.
ਤੇ	Yes, I would know; and no, she did not. ત્વ	3	Second of all, I'm not being gang-raped.
4	Let's put up == let me ask you some ्.	ర్	Everyone has their clothing on.
നി	questions about the photo that you had posted on your	ನ	Thirdly, if you'd look at all the other
્ઠ	MySpace page before you erased it last week. Okay?	6	pictures in that album, I'm drinking -- what's
7	A. Okay .	7	when you're sick you drink it?
8	MR. TEIN: Do you mind if we close the door	ு	BY MR. TEIN:
તે	a second, please.	ി	You can't ask questions of your counsel. ்
10	MR. LEOPOLD: Exhibit number, please.	10	All right. I'm drinking like Sprite. I'm A.
11	MR. TEIN: Put up 25-005.	11	not drinking any kind of alcohol, if you would look at my
12	Bold on a second.	12	other pictures in that album.
13	MR. LEOPOLD: Dom't say anything. She was	13	You guys picked the possibly worst pictures
14	talking to her counsel.	14	out of there to present. And it was just a goofy
15	MB. TZIN: Put up 25-00%.	15	picture. All of these kids like to be goofy. And that's
16	MR. LEOPOLD: Is that 005 right there?	16	what we were doing.
17	MR. TEIN: Yes .	17	Who's the man on the left of the picture ்-
18	BA MR, IBIN;	18	holding his -- holding a beer bottle as if it ware a
19	Who took this photo of you in a warehouse, ்.	19	panis towards your mouth?
20	simulating being gang-raped by a bunch of --	20	A.
21	MR. LEOPOLD: Objection. Mischaracterizes	21	Who's the man behind you, right up towards ்
22	the photograph, and lack of foundation and	22	your backside, with you bent over?
23	predicate.	23	A. That one?
24	Fully explain if you meed to.	24	Page 100 The right side, kissing with his mouth. ்

![](_page_26_Figure_0.jpeg)¶

EFTA00222280¶

	Document 15-2		Page 28 of 35 Entered on FLSD Docket 06/30/2008
	Page 105		Page 106
1	A.		THE WITNESS: Gosh, that's so long ago.
2	Where does she live? ् -	N	BY MR. TEIN!
3	I don't know. In Royal Palm. A.	3	Who took the photo of you licking the 0.
C	0-	4	penis?
	A. Uh-huh. I'm guessing.	5	My stepmother. 3.
	Do you know her phone number? ்.	ર્ણ	Whose iea -- that was your stepswchers's ் -
	No, I do not. P. .	7	1 ජීවිය 7
N	Let's look at 25-010. ்	8	It was in Baca di Beppo, where she works A.
9	See, I'm drinking -- A.	9	currently, and that was before she worked there. And we
10	I'm not asking you about what you re 0.	10	just thought it would be funny.
11	drinking.	11	MR. TEIN: 19-007. Can you enlarge that 7
12	Who are the men in this photo who are	12	BY MR. TEIN:
13	pretending to gang up on you and stab you with knives?	13	Who took this photo of you simulating you 0
14	Who are they?	14	having sex with a man?
15	A. and	15	We're not sixulating having nex, and A.
16	Are these firemen? 0-	16	it's == ch, and the person who took it was, I'm pretty
17	- he said the Are those? N.	17	I don't know his se I know him as sure,
18	two stabbing with knives. That's why I said that.	18	last name.
19	dom't know. That's	19	Go to 19-006, please. ् -
20	Are these firemen? ்.	20	Who took this photo of you simulating sex
21	No. They're all om -- except A.	21	with a man?
22	they're all on full rights for football.	22	The name person. And we're not simulating A.
23	Go to 025-015. ்	23	having sex, Mr. --
24	MR. LEOPOLD: 025 dash?	24	Tein. ប៉
25	MR. TEIN: 015	25	Did you post that on the Internet?
	Ph. 561.682.0905 - Fax. 561.682.1771 1655. Palm.Beach.Lakes Blvd., Suite 500 - West Paim Beach, Fi. 33402		Ph. 561.682.0905 - Fax. 561.682.1771 -1655. Palm Beach Lakes. Blvd., Suite 500 - West Palm Beach, FL 3340

	Page 107		Page 108
1	Actually, this is am old Myspace I never		Yes A.
2	finished and I naver like did anything. I just kind of		Are you clothed in this picture? ் -

4¶

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isn't that correct?¶

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BY MR. TEIN:¶

DOCT@CE ?¶

In¶

Yes.¶

Yeah.¶

100 .¶

Yes.¶

And Boach Fire Department, right?¶

Yup.¶

that your boyfriend is dating an underage girl?¶

Ph. 561.682.0905 - Fax. 561.682.1771¶

Lakes Blvd., Suite Beach Lakes Blvd., Suite 500 .; West Paim Beach, FL 33401¶

Actually, mister, it's legal.¶

something about your relationship with¶

All right.¶

Where is that picture takem? house.¶

Did you post that on the Internet?¶

MR. TEIN: You can take that down.¶

You lie about your age in order to conceal¶

22 years old, isn't he?¶

Does the Palm Beach Fire Department know¶

is a firefighter with the Palm¶

Now your boyfriend in¶

4¶

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rap.¶

Yop.¶

BY MR. TEIN:¶

rup.¶

question. Argumentative.¶

simulating mex with a woman?¶

MySpace ?¶

So the answer is yes, you posted this on¶

Go to 25-016. Who took this photo of you¶

MR. LEOPOLD: Object to the form of the¶

belly button or repiercing it, and I'm pretty sure¶

it was joint up a camers summers somers sone and¶

put a timer on it. We didn't have anybody take¶

You posted that on your MySpace page?¶

Go to 25-013. Is that a photo of you?¶

Is this you coming out of the shower?¶

.¶

Who's in the photo with you?¶

Ph. 561.682.0905 - Fax. 561.682.1771¶

1655.Palm Beach Lakes Blvd., Suite 500 · West Paim Beach, FL 33401¶

.....¶

THE WITNESS: First off, she's piercing my¶

EFTA00222281

			Page 109					Page 110
		Well ==			BY ME. ZEIN:
			MR. LEOPOLD: Just answer the quastion,	2		்	Does the Palm Beach Police Department know
				3	that		a member of the Palm Beach Fire Department,
		THE WITHESS: Yes.					is having a sexual relationship with an underage girl?
	BY MR. TEIN:			5		A.	I'm goessing no.
િ	0		Did they know two weeks ago that you were	6		ਾ	You lie ahout your twin sister	don't
7		dating an underage gixl (aic) ?		7	you?
નિ	A.	Yes. I met everybody in there.		નિર			MM. LEOPOLD: Objection. Argumentative.
ਰੂ	0	Did they know your age?		9	BY MR. TEIN:
10	A.	Yes.		10		்.	Don't you?
11	0-		Did you lie about your age so that the fire	11		A.	No. I have never lied for or to
12		department wouldn't think that	is committing a	12		0	You lie about the fact that she has a drug
13		crime by having a sexual relationship with an underage		13	habit, right?
14	girl?			14		A.	No. I would never accuse my sister of
15			MS. BRIONIAVEK: Objection. Assumes facts	15	having a drug habit.
16		not in evidence.		16		0-	Do you try to conceal the fact that she has
17	BY MR. TEIN:			17	a drug habit?
38	Q.	You can answer the question.		18			MR. LEOPOLD: Chiection. Argumentative,
19	A.	100 .		19	BY MR. TEIN:
20	਼		Does the Palm Beach Police Department know	20		Q-	You can answer the question.
21	thut	s having a sexual relationship with an		21		A.	No. My sister does not have a drug habit.
22	underage girl?			22		0-	You lied when you went to the crack house
23			NR. LEOPOLO: Don't guess. Answer if you	23	in Georgia, didn't you?
24		KILOW .		24			MR. LEOPOLD: Objection. Argumentative.

1¶

	Page 111		Page 112
	THE NITNESS: Nover -- what did you say?		MR. TRIN: I'll certify it,
2	BY MR. TEIN:	2	CERTIFIED QUESTION
17	You lied when you went to the crack house 0.	3	NR. LEOPOLD: For the record, you have to
ની	in Georgia, didn't you?	C	stop interrupting me because she can't take down
	MR. LEOPOLD: Objection. Argumentative.	5	both of us telking at the same time.
6	Lack of foundation, lack of predicate.	6	DY MR. TEIN:
7	BY MR. TEIN:	7	the truth, don't you? ci Tou cell
00	You can answer the question. ்	8	A. Excuse me ?
ਰ	I have never been to a crack house. 3. -	ਰ	the truth, don't you? You tell 0.
10	Who don't you lie to? 0-	10	When it's -- yes, I tell the truch. 24 .
11	MR. LEOPOLO: Objection, Argumentative.	11	drug dealer? Hho 5 ்
12	Don't answer the question.	12	My sister does not have a drug dealer. She A.
13	MR. TEIN: Certify it.	13	lives in Georgia with my mother.
14	· · · CERTIFIED QUESTION · · · · ·	14	Okay. Who is the drug dealer who dropped 0
15	BY MR. TEIN:	15	off at 5:45 a.m., in 2006, after being out you and
16	do you? You don't lie to ്-	16	all night, the two of you, using drogs at Palm Beach
17	MR. LEOPOLO: Objection. Asked and	17	Country Estates where your father called the police?
18	answered.	18	A.
19	Don't answer the question.	19	Be's the drug desler? Q-
20	BY MR. TEIN:	20	He is a drug dealer. A.
21	No. You can answer that question. ்	21	was arrested by the Do you remember 0-
22	MR. LEOPOLD: Ko. I just told her mot to.	22	Faln Beach Police Department and taken to the Juvenile
23	You've asked that question about five ==	23	Assessment Center that morning?
24	MR. TEIN: No, I haven'e.	24	I do remember that. A.
25	MR. LEOPOLD: Don't answer the question.	રેક	Now before you massaged Epstein, you were 0-

EFTA00222282¶

…¶

・・ -: : -: . . ----¶

15¶

16¶

17¶

18¶

19¶

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21¶

22¶

23¶

24¶

25¶

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BY MR. TEIN:¶

0-¶

ﺔ.¶

A.¶

்.¶

a.¶

Q-¶

A.¶

0-¶

Answar.¶

Yos.¶

regarding Mr. Epstein, right?¶

Yas.¶

I don't know.¶

I'm not my sister. I don't kmow,¶

I want to know what you know only.¶

You don't know. That's your answer?¶

Now your parents filed the police report¶

Now your parents are also lying, arem't¶

Entered on FLSD Docket 06/30/2008 Page 30 of 35¶

nsor & Associates¶

Raparties and Teaxuristing, Inc.	1041 12 / 1670 0 000 sarting and inder parts.
Page 113	Page 114
involuntarily admitted into a juvenile educational 1	And isn't it troe that your father has ்
facility; isn't that right? 2	accused you of lying? 2
Did you say involumtarily? A. ੇ	All the time. A.
Yes. ்	ತ Didn't your father throw you out of the 0
No. I was willing to go. I -- duly said A. 5	ન્ડ house Thanksgiving of this past year because you were
sure . 6	5 lying as much to him?
And you wont there because you were lying ் 7	હ Yes, he did kick me out. No, that's not
so much, no one could control you! isn't that correct? 8	A. 7
That's very incorrect. A. ತಿ	the reasons why. 00 Didn't your father throw your sister
Now you lie to your parents all the time.	្រ. 9
10 ି	out of the house, too? 10
don't you? 11	Yes. A- 11
Incorrect. A. 12	And he threw her out of the house the week 0- 12
MR. LEDPOLD: Objection. Argumentative. 13	after Thanksgivings, right? 13
BY MR. TEIN! 14	I don't know the date, but sure. A. 14
Sorry? 15 ்	Sounds about right? ் 15
Incorrect. 16 A.	Sure. A. 16
The day you went to Epstein's house you 17 0-	And the reason he threw her out of the 0- 17
lied to your father about where you were going; is t ਹੈ ਲੋ	house was because she was lying, too? 18
that correct? 3 9	MR. LEOPOLD: Objection. Lack of 19
Correct. A. 20	Foundation. Calls for speculation. 20
You admitted to the police that you told 21 ்	BY MR. TEIN: 21
your father that you were going shopping, didn't you? 22	When your counsel cosches you, you say it's ੋਂ 22
Yes. 23 Pa-	correct, right? 23
And that was a lie, wasn't it? ். 24	I've never been coached. ai 24
25 A. 203.	MR. LEOPOLD: Objection. 25
Ph. 561.682.0905 = Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401	Ph. 561.682.0905 - Fax. 561.682.1771 1655-Palm Boach Lakes Blvd., Suite 500 - West Paim Beach, FL 33401
Page 115	Page 216
BY MR. IEIN: I	they? 1
Okay. When your counsel that it was there ் 2	24. XGB = 2
was lack of foundation, you agree with your counsel, ਡ	MR. LEOPOLD: Just so the record is clear, ਤੇ
	the father -- because the mother was up north.
right? I was like saying, "Yeah, let's move on," A.	MR. TEIN: Don't testify, Counsel.
5 because there was no point to asking that question.	5 MR. LEOPOLO: 80 the record is clear, just
റ്റ out of the house	6 the father. The mother was ==
Your father threw ். 7	7
because she was lying, correct? 8	HR. TEIN: Counsel, don't coach and ાં જિ
MR. LEOPOLD: Objection. Lack of ತಿ	testify, please. That's absolutely improper. ੀ।
foundation. 10	MR. LEOPOLD: You just asked the wrong 10
Let me just make the Hold ca, 11	question. 11
abjection. 12	MR. TEIN: You can't coach her that way and 12
Lack of foundation, predicate, calls for 13	you wall know it. 13
speculation. 14	MR. LEOPOLD: For the record, it's the 14

15¶

16¶

17¶

18¶

19¶

20¶

21¶

22¶

23¶

24¶

25¶

(1) Ph. 561.682.0905 - Fax. 561.682.1771 -1655 Paim Beach Lake's Blvd., Suite 500 -- West Paim Beach, FL 33401¶

Ph. 561.682.0905 - Fax. 561.682.1771¶

Georgia. The father is here locally.¶

father. He's remarried, I think on his third¶

totally against the rules and you know it.¶

MR. TEIN: You cannot -- it's absolutely,¶

MR. LEOPOLD: 7the natural mother lives in¶

MR. TEIN: You need to behave yourself,¶

MR. LEOPOLD: The natural mother lives in¶

MR. TEIN: Stop coaching. Stop talking.¶

marriage.¶

Georgia.¶

lawyer.¶

1¶

^{------------------------------------------------------------------------------------------------------------------------------------------------------------------------------}¶

Case 9:08-cv-80119-KAM Document 15-2 Entered on FLSD Docket 06/30/2008 Page 31 of 35¶

Sinsor & Associates¶

ூ¶

్రా¶

Consor & Associates¶

Page 117		Page 118
You object. You know the rules. You just		Your parents, who filed the police report 0.
lectured me about the rules, Counsel. So why	2	in this case, are also proven liars, aren't they?
don't you play by the rules? Or only when they	3	MR. LEOPOLD: Same objection.
fit you? Why don't you grandstand a little more	4	BY MR. TEIN !
now. Give us a five-minute speech, Mr. Leopold.	5	Aren't your parents liars? ்
MR. LEOPOLD: Rre you finished, for the	6	MR. LEOPOLO: Calls for speculation. Lack
record?	7	of predicate.
MR. TRIN: I'm not talking to you. Do what	8	MR. TEIN: Stop coaching. You know what
. They don't	್ತಿ	that is, Imopold.
MR. LEOPOLD: Don't say anything yet.	10	MR. LEOPOLD: Calls for speculation. Lack
BY MR. TEIN:	11	of foundation.
your parents -- ்	12	THE WITNESS: When you say parents, my mom
MR. LEOPOLD: Nold it. Don't say anything	13	is not, but sure, yeah, my dad has been to jail
· yot, Lot na --	14	for lying.
BY ME. TEIN:	15	BY FR. JEIN:
Your parents, who filed the police report ்	16	Your dad went to federal prison for two ்
are also liars.	17	years for lying, right?
MR. LEOPOLD: Don't answer the question.	18	A. Correct.
We're not going to answer until I make the record.	19	Did he tell you it was for a financial ்
I want to put on the record, mow that Counsel	20	fraud?
appears to be finished with his comments for the	21	Yes . Pr.
record, that the previous quostion was	22	For stealing money from some financial ં
inappropriate, was intentionally misleading.	23	institution?
Now you can ask the question.	24	Pr. Correct.
BY MB, TEIN:	25	And do you think your father is trying to o

	Page 119		Page 120
	steal your lawsuit money away from you?		Uh-huh. Yea. ic
2	Don't look to your lawyer for the answer.	2	Do you trust your stepmother? 0
ਤਾ।	MR. LEOPOLD: You can answer if you know	3	My stepmother, no. A.
4	the answer to it. I have no ides.	4	You think she's also trying to steal your 0.
5	THE WITNESS: Yeah.	ટે	Epstain lawsuit money away from you, don't you?
റ്റ്	BY MR. TEIN:	હ	I would like to clarify something. You A.
7	And your father filed a lawsuit, the first 0.	7	keep saying my Epstein lawnuit money. I don't have any
00	lawsuit for fifty million dollars against Mr. Epstein	8	money, and it's just a lawsuit at the moment. So I just
છે	without consulting you, correct?	ੈ	dom't trust hex.
10	Correct. A.	10	Okay. You think that your stepmother is ்
11	And your father had a lawyer file the first ்	11	trying to take advantage of this lawsuit to try to get
12	lawsuit on your behalf for fifty million dollars against	12	money from Mr. Epstein that belongs to you, right?
13	Kr. Epstein without your knowledge, correct?	13	A. Yos.
14	Correct. A.	14	Did your stepmother tell you why she was 0.
15	And you don't trust your father, do you? ்	15	arrested?
16	Corrace . A.	16	A. No.
17	And you believe he's trying to manipulate 0-	17	Did your stepmother tell you that she's ਼
18	you for his own gain, don't you?	18	ever been arrested?
19	Sort of. 2. -	19	at 190 .
20	Well, you know that your mother filed a ்	20	Did she tell you she was arrested for 0-
21	statement, an affidavit, saying that you don't trust your	21	Exaud ?
22	father and that you believe he's trying to manipulate you	22	8. Nover .
23	for his own gain; ism't that correct?	23	Did she tell you that she was fired from 0 -
24	Correct. A.	24	Hawthorne Aviation?
25	You agree with that statement, don't you? ਼ -	25	A. No.

... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ..¶

...¶

	Page 121
	Did she tell you that she was fired from		Page 122
	்.		Are you saying you never kissed a num other 0-
	Hawthorne Aviation for stealing?		than those two?
2	200 - A.		MR. LEOPOLD: Objection to the form of the
	MR. TRIN: Let's take a break.		question.
	(Thereupon, a recess was taken )		THE WITNESS: Yes, I had kissed people
6	BY MR. TEIN:		before.
7	fore you met Jeffrey Epstein, had ପ୍ର -	7	BY MB. TEIN:
છે	you ever had sexual intercourse?	ਜ਼ਿ	Before you met Epstein, had you ever had ்.
ਰੋ।	Yes, yeall. મે મ	ਰੋ	DEAT BOKY
10	How many kimes? 0.	10	140 . A.
11	Just a few. Twice. A.	11	Ever in your life, have you exchanged sex ்
12	With how many different men? ਾਂ	12	for something of value?
13	TWO. A.	13	A. No.
14	How old were they? 0-	14	MR. TEIN: We're done.
15	being one year older than me, A.	15	THE WITNESS: Ch, okny.
16	and then the other person was two years older than me.	16	MB. LEOPOLD: We'll read.
17	What was his name? 0	17	MS. BELOHLAVEK: I don't have any
18	A.	18	questions. Thank you.
19	How old were you when you first had sexual 0.	19	MR. LEOPOLD: Before we go off the record,
20	intercourse?	20	it's my understanding == Mr. Goldberger can
21	14. A.	21	correct the record -- but we have stipulated that
22	How many -- before you met Epstein, how 0.	22	color copies of the documents that were identified
23	many different mon had you had any type of sexual	23	for identification certainly will be attached to
24	activity with?	24	the deposition and counsel will be taking the
25	Just those two. A.		photographs across street so that they can be
	Ph. 561.682.0905 - Fax. 561.682.1771 1655 Paim Beach Lakes Blvd., Suite 500 ~ West Palm. Beach, FL 33401		Ph. 561.682.0905 - Fax. 561.682.1771 1655 Paim Beach Lakes Blvd., Suite 500 - West Palm Beach, FL . 33401


	Page 123
	laser color copied so that we have a copy, and I'm		MR. GOLDERRGER: Let me finish.
	assuming he'll get a copy to the court reporter,		MR. LEOPOLO: I'm not interrupting now.
3	too, to attach, actually a certified copy to the	3	MR. GOLDERGER: But if it will make you
శ్	deposition.	ત્વ	happier if I go over to Ms. Belohlavek's office
5	MR. GOLDBERGER: Done.	5
ర్	MR. LEOPOLD: That's if you agree to that.		this deposition and then I'll give them to the
7	if not, then I want to pull each one out and put	6	court reporter, I'll be happy to do it.
	exhibit labels on them, which we should do before	7	MR. IMOPOLD: I trast you implicitly,
ಿ	we leave.	8	however you with to do it. Nowever, the
ಿ	MR. GOLDBERGER: We're not going to do	9
10		10	documents, before they leave this room, need to
11	either. I'll have copies sent to the court	11	have an exhibit sticky on them with the
12	reporter and she can attach them to the	12	Page 124 and make a copy of those photos that were part of appropriato --
13	deposition.	13	MR. GOLDBERGER: Want to go get some? Wo
14	NR. LEOPOLD: So you're mot going to agree	14	don't have any .
15 16	to what we talked about during the break then. NR. GOLDBERGES: "I'm not quite sure what	15	MR. LEOFOLD: I will do that. Excuse me. let me finish the record, please. You can't do

17¶

10¶

19¶

20¶

21¶

22¶

23¶

24¶

25¶

O¶

that to the court reporter. She's going to stroke out. You can't do that. You have to let ma --MR. TEIN: Finish your sentence, Ted. You are the most long-winded lawyer I've ever seen in my life. Finish your sentence.¶

MR. LEOPOLD: Jack, tell him not to raise his voice, please.¶

MR. TEIN: Finish your sentence. Is there going to be a period at the and of the sentence or¶

ﺍﻟﻤﺘﻮﻗﻒ ﺍﻟ 1 e l'est province¶

Ph. 561.682.0905 · Fax. 561.682.1771¶

Ph. 361.665.Paim.Beach.Lakes Blvd., Suite 500 - West Palm Beach, FL 33401¶

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

MR. LEOPOLO: I'm not?¶

彩票¶

.¶

process. I would send copies to the court¶

reporter. But if it will make you happier --¶

MR. LEOPOLD: Okay. Sure. That's fine.¶

go over to Ms. Belohlavek's office and make copies¶

and then I'll give those to the court reporter,¶

fine. All I'm saying is that I would avoid that¶

MR. GOLDBERGER: Okay. If you want me to¶

17¶

18¶

19¶

20¶

21¶

22¶

23¶

24¶

25¶

.¶

ි¶

0¶

ூ¶

3¶

Entered on FLSD Docket 06/30/2008¶

Page 33 of 35¶

	SUSOI & ASSOCIates

Sinsor & Associates¶

	Page 125		Page 126
1	is it just going to be comma after comma after		argue about everything. Ever single one is
2	coma.7	2	already marked. Isn't that silly, Ted?
3	Go ahead, lawyer.	ತಿ	MR. GOLDERGER: Thirty years of doing this
দ্য	MR. LEOPOLD: All right. The exhibits, I		and I have never had an argument over this.
មក	can't prevent you from taking them, but I will	5	MR. TEIN: You've made -- Ted, you are
હ	object and I will be bringing it to the court for	ને	obstructionist, you are a liar. You have lied and
7	sanctions. You cannot take the exhibits out of	7	miarepresented things, for the record. You are
હિ	the room without them being marked. I want them	ള	grandstanding.
ு	marked, because you cannot identify in the record	ಿ	NR. IMCPOLD: You need to back up.
10	what was used. And with all due respect to	10	MR. TEIN: No, no. I'm going to finish.
11	Mr. Goldberger, I do not -- the way this	11	You can finish, but don't MR. LECPOLDI
12	deposition is going, I do mot want to rely on	12	hover over me.
13	Counsel from Miami to mark the appropriate	13	MR. TEIN: No one is hovering over you.
14	exhibits. I will not do that. I cannot prevent	14	Stop trying to make a lying record.
15	you from taking them. But if you do, I will be	15	Let me say something else.
16	bringing the matter to the court with appropriate	16	Don't you dare threaten me with samobions,
17	sanctions, because that is improper. That is	17	after you lied in a letter to my co-counsel about
18	improper. When you use something in a deposition,	18	the fact -- be quiet. Be quiet and let me finish.
19	they are to be marked. And you have refused to do	19	You lied in a letter to my co-counsel,
20	that throughout for what over reason.	20	Mr. Leopold, in which you said == it was a
21	MR. TEIN: You're wrong. Finish your	21	complete and utter lie -- that you were
22	sentence because you're talking about something	22	unavailable this morning because you had a
23	you have no idea.	23	hearing. That was a lie. I have never seen a
24	Every single one is marked, 7ed. Every	24	lawyer deign to do something like that.
25	single one is already marked. But you want to The Contraction of the propries and the only of the stations on the management of the many of the same of	25	So you will get the ex == be quiet. Lat mo The state the state of the same of the state and and comments of comments
	bh, 561,682,0905 - Fay, 561,682,1771		Dr. D61 683 0005 . Fay. 561,682,1771

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

Ph. 561.682.0905 - Fax. 561.682.0905 - Fax. 561.682.1777 1655.Palm Beach Lakes Blyd., Suite 500 - West Palm Beach, Fl. 33401¶

	Page 127		Page 128
	finish. You behave.		of issues in this case. We're going to have lots
2	NR. LEONOLD: Don't point your finger at	2	of reasons to disagree.
3	me .	ತ	I'm going to take it over now and I'm going
	MR. TEIN: Listen. Be quiet and I wom't	4	to make copies and I'm going to give them to
ಕ	have a need to point it at you.	5	Ms. Consox. If you want to go find some exhibit
6	MN. LEOPOLD: Don't point your finger at --	్	labels and put some exhibit labels on it, be my
7	MR. TEIN: Mr. Leopold --	P	quest. But that's what I'm offering to clo.
8	MR. LEOPOLD: Don't point your finger at	8	THE NITNESS: Let mo say two things,
്യാം	110 .	9	because I am happy to always disagree, and with
10	MR. TEIN: Mr. Leopold, let me finish.	10	you, I have no problem; we could always do it
12	MR. LEDPOLD: Bon't raise your voice	11	professionally. I have not problem.
12	aither.	12	I want to say two things so the record is
13	MR. TEIN: Mr. Leopald ==	13	very clear.
14	MR. LEOPOLD: Jack, do you want bo take	14	Since for whatever reason I have not been
15	care of this?	15	able to look at exhibits, because they have been
16	MR. TEIN: Let me finish my sentence. The	16	refused to have been shown to me --
17	exhibits are marked. We are walking out of here.	17	KR. TEIN: That's a lie.
18	You are scheone who misrepresents the	18	MR. LEGPOLD: -- Jack, if you represent
19	record. It is absolutely atrocious what you do.	19	that the documents have the appropriate exhibit
20	That is not how a lawyer should behave. This	20	numbers or some identifying markings, 25, 30.000,
21	deposition is over. You will get your exhibits,	21	whatever they may be, then you can take than, make
22	Mr. Lecpold.	22	copies, send me a copy, make sure the court
23	MR. GOLDBERGER: I understand what you're	23	reporter gets a copy and then send me a bill for
24	saying, Michael, and I understand Ted's position.	24	ny copies, that's fine. I didn't know that they
25	Just so there's -- we're going to have lots	25	are marked that way because I haven't been able to

Caco 0.08-01-80110-KAM + 46 0 Da¶

8000/00/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/08/0 Cista CLODDA¶

Page 34 of 35¶

	Page 229		Page 130
	look at them.		LAST
2	MR. GOLDSERCER: They are barcoded, and the		MR. LEOPO&D: No, no, no. I just put it on
3	mumber that we've made reference to in the		the record. I will get an affidavit -- I'm
	deposition coincides with the barcoding.		assuming it sounds like you need it -- from Mr.
5	MR. LEOPOLD: That's fine. Sight by eleven		Pincus. I have no clue about what happened and
	color laser copies are fine.		why it was canceled. All I was told when I was
6	MS. BELOHLAVEK: The State Attorneys Office	હ	out of town yesterday was that the hearing this
1	is mot going to charge anybody for color copies I	7	morning was cancelled.
તિ	print out.	ಕಿ	MR. GOLDBERGER: I'll take your word for
ਭ	MR. LEOPOLD: That's fine. Ho's going to	9
10	take them back to his office.	10	ie. MR. LEOPOLD: If you want an affidavit,
11	Secondly -- and I will be more than happy	11
13	to do it, because it sounds like you all know more	12	I'll get it for you. MR. GOLDSERGER: It's a personal issue for
13	about it than I -- but I'm happy to get affidavits	13	me because I had to disrupt a vacation and if it
14	from Mr. Pincus, Judge Stern, everybody else about	24
15		15	was done just because it wasn't convenient for
16	what happened with this hearing today, because I	16	you, then I'm offended by that. But if you're
17	know very little about it. But my representations	17	telling me that it was planned and it didn't
18	are what they are.	18	happen, I'll take your word for it.
19	MR. GOLOBERGIR: They stay --	19	MR. LEOPOLD: I am more than happy to get
20	MR. LEOPOLD: Lot me just finish for the	20	you an affidavit, because I don't know the reason
21	record.	21	why it was canceled other than the fact that I'm
22	My representations or comments about what	22	assuming since my deposition was taken for four
23	happened, representation about this hearing this	23	hours on Monday for preparation for the hearing
24	morning, I know wery little about it. I --	24	today, for whatever reason it was canceled, I am
	MR. GOLDBERGER: I'll take your word on		told it is being re-moticed. Why it was canceled,
	Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401		MIDDING THE STORA PHONO CONSULTION CONSULTION THE PROPERTY Ph. 561.682.0905 - Fax. 561.682.1771 55 Palm. Beach Lakes Blvd., Suite 500 . West Paim Beach, FL 33401


	Page 131		Page 132
	I have no idea, but if your co-counsel wishes an		CERTIFICATE
	affidawit to that effect from Mr. Pincus, I'm more
	than happy to get it. But I don't know the reason	3
	why it was canceled.	4	The State of Florida,
	NR. TEIN: I don't need it. But what I do	ന്	County of Palm Beach.
	take issue with is regardless of why it was	6
	canceled, you ownd us the courtesy of saying, You	7	I hereby certify that I have read the
	know what? We can start earlier this morning.	ાં છ	foregoing deposition by me given, and that the statuments
	NR. LEOPOLD: I owe you nothing.	ਰੋ	contained herein are true and correct to the best of my
	MR. This I don't care. Don't interrupt	10	knowlodge and belief, with the exception of any
	ne ,	11	corrections or notations made on the errata sheet, if one
	Because Jack canceled his yacation plans	12	passioning ann.
	because of you.	13
	NR. GOLDBERGER: That's all right, that's	14
	all right.	15	, 2008. pated this ___ day of
	NR. TEIN: And you're selfish. And this	16
	deposition is over. Good-by Mr. Leopold.	17
	MR. GOLDBERGER: You can go off the record,	18
25 1 4 ಲಿ રે 7 8 ਰੇ 10 11 12 13 14 15 16 17 18 19		19
		20
20 21		21
22		22
23		23

Ph. 561.682.0905 - Fox. 561.682.0905 - Fex. 561.682.1.771 1655 Palm.Beach 1.akes Blvd., Sulte 500 - West Palm Beach, FL 33401¶

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

EFTA00222287¶

	Page 133		Page 134
	DATE: February 25, 200B		ERRATA SHEET
	70:		IN RE: STATE-V-JEFFREY EPSTEIN
ತಿಗ	C/o into Beather ver Office of the State Attorney		TAKEN: February 20th, DEPOSITION DF:
	401 M. Dixie. Righway West Palm Beach, Florida 33401	3	200B DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
	STATE OF FLORIDA -V- JEFFREY EPSTEIN IN RE:		REASON CHANGS LINE # PAGE .
	CASE NO.: 2006 CF09454AXX
6	Please take notice that on Wednesday, the
7	20th of Pebruary, 2008, you gave your deposition in the above-referred matter. At that time, you did not waive
8	sigmature. It is now necessary that you sign your
ਰੇ	deposition. Please call our office at the below-listed
	number to schedule an appointment between the hours of 9:00 a.m. and 4:30 p.m., Monday through Friday,	10
10 11	If you do not read and sign the deposition	11
	within a rensonable time, the original, which has already been forwarded to the ordering attorney, may be filed	12
12	with the Clerk of the Court. If you wish to wnive your	13 14
13	signature, sign your name in the blank at the bottom of this letter and paturn it to us.	15
14	Very truly yours,	16
15	Judith F. Consor, FP9	17
16	Consor & Associates Reporting and Transcription 1655 Palm Beach Lakes Boulevard, Suite 500	18
17	West Palm Beach, Florida 33401	19 20
18	I do hereby waive my signature:	21	Please forward the original signed errata shoet to this
19			office so that copies may be distributed to all parties.
20	JACK A. GOLDSERGER, ESQ. oc via transcript:	22	Under penalty of perjury, I declare that I have read my
21	LANNA BELOHLAVEK, ESQ. MICHAEL R. TEIN, ESO.	23	deposition and that it is true and correct subject to any
22	THEODORE J. LEOPOLD, ESO.		changes in form or substance untered here.
	file copy	24
23 24			SIGNATURE OF DEPORTUNI:
25		25


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

EFTA00222288¶

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