Case 9:08-cv-80804-KAM

Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 1 of 100 nsor & Associates RepornnE sad Transcripoon. Inc 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 75 Q. Because Mr. Epstein never came to your dad's house, correct? A. Correct. Q. And no one who worked for Mr. Epstein ever did something to your dad's tires, did they? MR. LEOPOLD: Objection. Lack of foundation, predicate. Don't guess. BY MR. TEIN: Q. It's not true that Mr. Epstein almost killed your father, is it? MR. LEOPOLD: Objection. Asked and answered, lack of foundation, predicate. BY MR. TEIN: Q. You can answer. A. No. Q. Now you told the police that you didn't know who was in the car with you and IIIIIII on the day you went to Epstein's house, didn't you? A. Yes. Q. And that was a lie, wasn't it? A. It's the truth. Q. You told the police that there was someone in the car next to you and you specifically said you didn't know her name, right? 1010716 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00234324 Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 2 of 100 nsor & Associates Ropor•.1np and *I ranscnpacm. Inc Page 76 1 2 3 was dark like a Spanish girl." Those were your words, 4 right? 5 A. Yes. 6 MR. LEOPOLD: Objection. Asked and 7 answered. 8 BY MR. TEIN: 9 Q. Who was in the car that day with you and 10 fl 11 A. Again, I do not know. 12 Q. It was your good friend 13 wasr't it? 14 A. No. I don't know a 15 Q. You lied to the police about who was in the 16 car with you and e, didn't you? 17 A. Incorrect. 18 Q. Let me ask you some questions about who you 19 may have spoken to about this case. All right? 20 A. Go ahead. 21 Q. Did you speak to your twin sister . 22 A. Not in detail, but of course she knows; 23 she's family. And yes. 24 Q. What's her e-mail? 25 A. I don't think she has an e-mail. A. Correct. I do not know her name. Q. You said, "I don't know her name, but she Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 I 1020/316 EFTA00234325 Case 9:08-cv-80804-KAM rnent 1-2 Entered on FLSD Docket 07/21/2008 Page 3 of 100 sor & Associates herynning and Transcription, Inc. Q. Page 77 1 2 A. Oh, gosh. I don't know off the top of my 3 head. 4 Q. 5 A. 6 Q. 7 A. 8 Q. 9 speak to him about Epstein's case? 10 A. That's my mom's boyfriend. My sister 11 doesn't have a boyfriend. My mom's husband's name is 12 so maybe you get them confused. 13 Q. Do you know his phone number? 14 A. No. 15 Q. where does he live? 16 A. With my mom. 17 Q. In the same house with her? 18 A. Yes. They're married. 19 Q. So not boyfriend; husband? 20 A. Yeah, husband. 21 Q. Have you spoken to 22 what happened in Mr. Epstein's house? 23 A. Not in detail, but he knows the basics, 24 yes. 25 Q. What is his e-mail? What is her phone number? And what is her home address? She lives with my mom. In Georgia? Yes, sir. What about '11111iboyfriend..? Did you about Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 103 W715 EFTA00234326 7 8 9 Case 9:08-cv-80804-KAM D ent 1-2 Entered on FLSD Docket 07/21/2008 Page 4 of 100 sor & Associates Kellam op and Transc ri Ron. Inc Page 78 1 2 3 4 A. I don't know. Q. A. Q. What is his phone number? How is that relevant? What is his phone number? 5 A. 561.719.2652. 6 Q. What is his home address? A. I don't know. Q. Where does he live? A. In Palm Beach Lakes somewhere. 10 Q. 11 A. 12 Q. 13 14 15 MR. TEIN: Don't coach. 16 17 18 19 20 21 22 23 street. 24 Q. What's the name of the apartment complex? 25 A. Something Cove. Ever been to his house? Yes. You don't know what his address is? MR. LEOPOLD: Objection. Asked and answered. She just said she doesn't know. MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. You can answer the question. A. I don't know the exact address. Q. What street is it on? A. It's an apartment complex; its not a Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 16101316 EFTA00234327 Case 9:08-cv-80804-KAM ent 1-2 Entered on FLS Docket 07/21/2008 Page 5 of 100 nsor & Associates Rcparuni.: and Transcrip:i an. Inc. Q. 1 2 3 Q. Page 79 What apartment number is it? A. I couldn't tell you. When was the last time you went there? 4 A. Just visited this past weekend. That's the 5 first and last time I went there. 6 Q. How about ININEr Have you spoken 7 to him about your case? 8 A. No. We no longer speak. 9 Q. 10 already have his phone number and e-mail. 11 How about IIIIIIIIIP Have you ever 12 spoken to her about your case? 13 A. I don't know an 14 Q. Have you ever met 15 A. No. But just to let you know, I don't 16 reaLly know names. If you have pictures of there faces I 17 couLd tell you. What's his phone number? Actually, we 18 Q. All right. Let me see if I can refresh 19 your memory. 20 A. Okay. 21 Q. Does it refresh your memory that Mir 22 is the other girl who made allegations about Epstein, but 23 refused to show to the Grand Jury when she had to testify 24 about them under oath? 25 A. No, sir. I have no knowledge of any other Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 105 Of 316 EFTA00234328 Case 9:08-cv-80804-KAM ment 1-2 Entered on FLSD Docket 07/21/2008 Page 6 of 100 nsor & Associates Repnnung and Transcii po co, Inc. Page 80 1 girls in this whole situation. We're not allowed to know 2 each other. 3 Q. I didn't get the last four words. 4 A. We're not allowed to know each other. 5 Q. And what about Have you 6 of met her? 7 A. No, sir. 8 Q. Let's see if I can refresh your memory on 9 her. She's the other person represented by your lawyer 10 Mr. Herman, who is suing Epstein for fifty million 11 dollars. 12 A. I have no knowledge of her. 13 Q• Never met her? 14 A. Never met her. 15 Q. 16 A. I don't know who that is either. 17 Q. A person named who knows . 18 Is that OM. 19 A. I don't know, sir. 23 Q. Do you remember making a statement to 21 Detective Pagan that's in the police reports? 22 A. No, sir. 23 Q. Have you read the police reports in this 24 case? 25 A. Yes. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 106 o1316 EFTA00234329 Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 7 of 100 nsor & Associates Roponinp. anil TrinsCriptioli. Inc. Page 81 1 Q. They're on the Internet, right? 2 A. Yes, I think. 3 Q. Were you surprised when the police reports 4 were released on the Internet containing your statements 5 6 7 8 9 that you had made to the police? A. Yes. Q. You didn't want to see that happen, right? A. No. O. So you're saying you don't know a 10 11 12 MR. LEOPOLD: Objection. Asked and answered. 13 BY MR. TEIN: 14 Q. Does it refresh your memory that he was 15 somebody who had gone to jail for drugs and car theft? 16 A. No, sir. 17 O. Someone who knows . 18 A. No. 19 Q. You don't know if he met with Detective 20 Recarey? 21 A. No, sir. 22 Q. How about INS 23 A. Yes, I remember. I know who that is. 24 Q. Did you ever speak to l about what 25 happened at Mr. Epstein's house? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 107ot 316 EFTA00234330 Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 8 of 100 nsor & Associates Rept-bring rind 17anscripticm. Inc Page 82 1 A. He knows what happened four years ago. He 2 doesn't know this is still going on today. 3 Q. What's his address? I'm sorry. I have his 4 address. 5 A. I don't know. 6 Q. How about 7 A. gut 8 Q. You know who that is? 9 A. I know who that is, yes. 10 Q. He's the one you stayed out drinking all 11 night one night last year when your dad reported you 12 missing? 13 A. No, sir. 14 Q. Remember the baseball game you were 15 supposed to go to? 16 A. No, sir. 17 O. Did you speak to about this - 18 case? 19 A. No, sir. 20 Q. How about 21 A. That's my sister's ex-boyfriend. 22 Q. He's the one with the sawed-off shotgun 23 with the obliterated serial number? 24 A. Ask him. I would not know that 25 information. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 108 W715 EFTA00234331 Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 9 of 100 nsor & Associates Repnrunp and lranscnpnon, Inc Page 83 1 Q. Did you speak to about this 2 case? 3 A. No, sir. 4 Q. Have you spoken to allarir bout this 5 case? 6 A. No. I don't know who a is. 7 0. Did your parents speak to Illinir 8 A. Ask my parents. 9 Q. Let's see if I can refresh your memory as 10 to who he is. Okay? 11 A. Uh-huh. 12 Q. He's the Vanity Fair reporter who made a 13 financial arrangement with your father. 14 A. I am aware of that. And again, I was not 15 aware like that my dad did it until after it was done. 16 And I don't know the details about that. I just know 17 what you know about that, like that they talked. 18 Q. Tell me what you know about the financial 19 arrangement that MM. the Vanity Fair reporter, 20 made with your father. 21 A. I don't know about the details at all. 22 Q. How much money did give to MOM 23 your father? 24 A. I don't even know he gave money to my dad. 25 Q. I'm sorry? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 109 01316 EFTA00234332 Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 10 of 100 sor & Associates ;tenoning and Transcription, Inc Page 84 1 A. I didn't even know he gave money to my dad. 2 Q. What do you know about the deal that mir 3 has with your father? 4 A. I only know they spoke on the telephone 5 once. I don't know anything else. 6 Q. When was that? 7 A. This was a while ago, a year or two or a 8 year ago. I honestly don't know. 9 Q. Did MEM the Vanity Fair 10 reporter, offer any money to your father? 11 A. I don't know. 12 Q. Did the Vanity Fair 13 reperter, give you any money? 14 A. No, sir. 15 Q. Did he offer you any money? 16 A. No, sir. Never spoke to him. 17 Q. What reporters have you spoken to? 18 A. Zero. 19 Q. What about your family members? What 20 reporters have they spoken to? 21 A. The whole Palm Beach County, obviously, as 22 you can see in that newspaper. 23 Q. Tell me -- let's go through each one that 24 you remember. Other than the Vanity Fair reporter, 25 IIIMIWwhat other reporters have any member of your Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1100316 EFTA00234333 Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 11 of 100 sor & Associates Repining end Transcription, Inc. Page 85 1 family spoken to? 2 A. I don't know. And I know my mom has spoken 3 to zero. My sister spoke to zero. My father and 4 stepmother, I wouldn't know. You'd have to ask them. I 5 don't contact them. 6 Q. Well, I just want to know -- I don't want 7 you to -- I want to know what's in your mind. All right? 8 MR. LEOPOLD: She just told you. She just 9 answered -- 10 MR. TEIN: Be quiet. 11 BY MR. TEIN: 12 Q. What I want to know is what you know from 13 your personal knowledge. My question to you is: What 14 knowledge do you have about family members of yours 15 speaking to reporters? 16 MR. LEOPOLD: Objection. Asked and 17 answered. 18 And if you can't talk professionally, we're 19 going to leave. 20 MR. TEIN: Do what you want to do. 21 MR. LEOPOLD: Are you going to continue to 22 talk this way? 23 MR. TEIN: I'm not going to answer any 24 question that you ask me, Mr. Leopold. 25 MR. LEOPOLD: Okay. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 ill oI316 EFTA00234334 Case 9:08-cv-80804-KAM Do rpent 1-2 Entered on FLSD Docket 07/21/2008 Page 12 of 100 nsor & Associates Reporting and Transc Finnan, Inc Page 86 1 MR. TEIN: But you are misrepresenting the 2 record and you are grandstanding for your client 3 and it's wrong. So be quiet. And you know how to 4 make an objection. Make it. Otherwise stop 5 talking. 6 BY MR. TEIN: 7 Q. init- 8 MR. LEOPOLD: Excuse me. 9 MR TEIN: If you want to leave the 10 deposition, leave. But you'll be back here. 11 MR. LEOPOLD: Excuse me. If I could just 12 make the record, instead of interrupting me, 13 please. That's what we do professionally. 14 There's a recorder here. I'm certainly not being 15 obstructionist. I'm going to make the record. 16 But we're going to act with some semblance of 17 professionalism, hopefully, by all parties in the 18 room. That goes to me, that goes to your 19 co-counsel sitting behind you and next to you, the 20 court reporter and everyone else in the room. 21 Everyone is entitled to that. 22 You've asked a question. She answered the 23 question fully and she's not going to be harassed 24 because you don't like the answer. If you want to 25 follow up -- Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11201316 EFTA00234335 Case 9:08-cv-80804-KAM D ment 1-2 Entered on FLSD Docket 07/21/2008 Page 13 of 100 nsor & Associates Repnrti DE anti lranseti piton. Inc 1 Page 87 MR. TEIN: Stop engaging me. Make your 2 speech and then we'll ask the questions. 3 MR. LEOPOLD: Well, you won't let me finish 4 making the objection, so it's difficult to do 5 that. But if you want to follow with an 6 appropriate question, feel free to do that. But 7 we're not going to harass the witness. 8 MR. TEIN: I disagree with everything 9 you've said. Let's ask the questions. Okay? 10 MR. LEOPOLD: Ask an appropriate question. 11 MR. TEIN: Are you going to stop talking? 12 MR. LEOPOLD: I'm going to make -- protect 13 my client and make appropriate objections. But 14 there's not a question pending right now. 15 BY MR. TEIN: 16 Q. ahasillispoken to any reporters? 17 A. No. 18 MR. LEOPOLD: Objection. Asked and 19 answered. 20 BY MR. TEIN: 21 Q. Has been given money by any 22 reperters? 23 A. No. 24 Q. Has your mom spoken to any reporters? 25 MR. LEOPOLD: Objection. Asked and Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 334O1 11301316 EFTA00234336 Case 9:08-cv-80804-KAM Do ' ,ent 1-2 Entered on FLSD Docket 07121'2008 Page 14 of 100 lik nsor & Associates Reparcinp and itnnscriparz. Inc Page 88 1 answered. 2 THE WITNESS: No. 3 BY MR. TEIN: 4 Q. Has your mom's husbandlillispoken to any 5 reporters? 6 A. No. 7 Q. Has your mom's husband IIIIIreceived any 8 money from reporters? 9 A. No. 10 Q. Are you sure you don't know 11 MR. LEOPOLD: Objection. Asked and 12 answered. 13 THE WITNESS: I'm positive. 14 BY MR. TEIN: 15 Q. I'll try again to refresh your memory. 16 A. Okay. 17 Q. Does it refresh your memory that she had 18 been arrested for drugs and was cooperating with 19 Detective Recarey against Epstein to get herself a better 20 deal? 21 A. No. I don't know who she is. 22 Q. Have you spoken to anyone else who's been 23 at Epstein's house? 24 A. No. 25 Q. Without telling me what was said -- I don't Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 114 el 316 EFTA00234337 Case 9:08-cv-80804-KAM po ent 1-2 Entered on FLSD Docket 07/21/2008 Page 15 of 100 4 nsor & Associates Steponsnp mid 1r/inscription, lac. Page 89 1 wart to know about any conversations with any lawyers, 2 okay -- 3 A. Uh-huh. 4 Q. did you or your parents speak to any 5 other law firms besides Mr. Herman and Mr. Leopold's law 6 firms? 7 A. No. 8 Q. Now without telling me about anything that 9 was said, what -- did one just come to mind? 10 A. No. I was thinking about something else. 11 Q. What were you thinking about? 12 A. Does family court matter? 13 Q. Okay. Without telling me what was said, 14 who prepared you for today's deposition? 15 A. What do you mean prepared? 16 Q. Did you talk about this deposition, about 17 what would happen, with anybody? 18 A. Yes. 19 Q. Don't tell me what was said. 2D A. Okay. 21 Q. I'm not asking that. I don't want to know 22 that. 23 A. Okay. 24 Q. Who prepared you for today's deposition? 25 A. Mr. Leopold. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11501316 EFTA00234338 Case 9:08-cv-80804-KAM Dppyment 1-2 Entered on FLSD Docket 07/21/2008 Page 16 of 100 nsor & Associates Itencannp and Transcriptinn. Inc Page 90 1 Q. Anybody else? 2 A. No. 3 Q. When did you meet with Mr. Leopold to 4 prepare for today's deposition? 5 A. This morning. 6 Q. And how long did that meeting last? 7 A. Until it started. 8 Q. Now you told me that you previously had 9 read the police reports in this case? 10 A. Yes. 11 Q. Have you read your statement that you gave 12 to the police? 13 A. Yes, sir. 14 Q. And in what form was that statement? 15 A. What do you mean? 16 Q. Was it in the form of a police report or a 17 transcript? 18 A. What's the difference? 19 Q. A transcript has questions and answers on 2) it. A police report is just typed out narrative. 21 A. Oh, it's a police report. 22 Q. And when did you read the police report? 23 A. A few days ago. I overread it a few days 24 ago. 25 Q. Had you read it before that? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 116 of 316 EFTA00234339 Case 9:08-cv-80804-KAM nt 1-2 ,Entered on FLSD Docket 07/21/2008 Page 17 of 100 nsor P.ssociates Ropornns and Transcription, Inc. Page 91 1 A. No. 2 Q. Now you told me -- again, I don't want to 3 know what was said. 4 A. Oh-huh. 5 Q. You told me that you met with Mr. Leopold 6 this morning to prepare for your deposition, right? 7 A. Yes. 8 Q. When did you set up that meeting with 9 Mr. Leopold to take place this morning? 10 A. Gee, like, like five days ago, four days 11 ago. 12 Q. So you're aware that Mr. Leopold told us 13 that he could not start the deposition this morning 14 because he had a court appearance, correct? 15 MR. LEOPOLD: Don't answer that question. 16 Calls for attorney/client communications. 17 BY MR. TEIN: 18 Q. Have you seen the letter that Mr. Leopold 19 wrote to us stating that he -- an e-mail that Mr. Leopold 20 wrote to Mr. Goldberger stating that he could not be here this morning because he had a court appearance? Did you 22 see :hat e-mail? 23 MR. LEOPOLD: You can answer that question. 24 THE WITNESS: No. 25 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11701316 EFTA00234340 Case 9:08-cv-80804-KAM Dgagppflnt1-2 Entered on FLSD Docket 07/21/2008 Page 18 of 100 sor & Associates Reportinp hod Transcriptorn. Inc 1 2 3 9 10 11 that statement? Page 92 BY MR. TEIN: Q. Have you listened to your tape-recorded statement to the police? 4 A. Yes. 5 Q. Where did you listen to that? 6 A. In, I think, this building. I don't know. 7 It was here. 8 Q. When did you listen to that statement? A. This morning. Q. And who was present when you listened to 12 A. Mr. Leopold -- and I forget your name. 13 MR. GOLDBERGER: Ms. Belohlavek. 14 THE WITNESS: Ms. Belohlavek. 15 BY MR. TEIN: 16 Q. And you hadn't listened to your statement 17 before that, correct? 18 A. No, sir. 19 Q. Have you met with lawyers representing 20 anyone else suing Epstein? 21 A. No, sir. 22 Q. How many times have you spoken to officers 23 with the Palm Beach Police Department? 24 A. More than I like can count. It's been 25 ongoing for four years, so quite a few times. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11641316 EFTA00234341 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 19 of 100 nsor & Associates Roportenp and Transcription, Inc Page 93 1 Q. When was the last time you spoke with 2 officers of the Palm Beach Police Department? 3 A. A while ago. I'd say a year ago. 4 Q. A year ago? 5 A. Yeah. Maybe a year and a half. 6 Q. Do you remember Detective Recarey? 7 A. No. 8 Q. Do you remember Michelle Pagan, Detective 9 Pagan? 10 A. Yes. 11 Q. How many times have you spoken to Detective 12 Pagan? 13 A. She was the only one I spoke to about this 14 until for some reason she wasn't on the case anymore. 15 Q. When was that? 16 A. The first meeting I ever had was with her 17 and then I think like I met with her like 10 times or 12 :8 times or something like that, and then I didn't get 19 another investigator questioned me after that. 20 Q. And who was that? 21 A. I don't remember. 22 Q. And what type of questions did they ask 23 you? 24 A. The same. 25 Q. The same questions all over again? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Paim Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 119 of 616 EFTA00234342 Case 9:08-cv-80804-KAM D ent 1-2 Entered on FLSD Docket 07/21/2008 Page 20 of 100 nsor & Associates iternruns and lranacii poem. Inc Page 95 1 A. I'd have to say like a year and a half ago, 2 a year ago. It was a long time ago. 3 (Discussion held off the record.) 4 MR. TEIN: Tell me the last answer, please. 5 (Thereupon, a portion of the record was read 6 by the reporter.) 7 BY MR. TEIN: 8 Q. And who was present when the FBI spoke to 9 you at your father's house? 10 A. My stepmother was there, but she wasn't 11 around. She made herself like do other things. 12 Q. And how many FBI agents were there? 13 A. I think four. i4 Q. And you don't remember any of their names? 15 A. No, sir. 16 Q. And were there any lawyers there? 17 A. Not that I know of. 18 Q. And none of them gave you their cell phone 19 numbers? 20 A. No. 21 Q. And the last time you spoke to the FBI was 22 a year and a half ago? 23 A. It was a while ago. G4 MR. LEOPOLD: Objection. Asked and 25 answered. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 120 of 316 EFTA00234343 Case 9:08-cv-80804-KAM ensOt 1-2 r oz p55Ocla ()Entered on_FLSDDocket 07/21/2008 Page 21 of 100 c es Reporting and lranscrip:nri. Inc 1 BY MR. TEIN: 2 Q. Page 96 And the last time you spoke to the federal 3 prosecutor's office was when? 4 A. I don't know. 5 Q. Did any of the FBI agents tell you that 6 Marie Villafona had spoken with Mr. Leopold? 7 A. No. 8 Q. Did any of the FBI agents tell you that 9 Marie Villafona had spoken with Mr. Herman? 10 A. No. 11 Q. Did any FBI agents tell you that Jeff 12 Slonan spoke with Mr. Herman. 13 A. No. 14 Q. Did any FBI agents tell you that Jeff 15 Slonan spoke with Mr. Leopold? 16 A. No. 17 Q. Do you know whether any of the federal 18 prosecutors allowed Mr. Herman to review a draft 19 indictment? 20 A. I wouldn't know. 21 Q. Do you know if any of the federal 22 prosecutors discussed a draft indictment with Mr. Herman? 23 A. I wouldn't know. 24 Q. Have you ever e-mailed with any FBI agent 25 or any federal prosecutor? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1210316 EFTA00234344 Case 9:08-cv-80804-KAM nt 1-2 AEntered on Flan Docket 07/21/2008 Page 22 of 100 -sor & Associates hoponenp And Transaipart, Inc. Page 97 1 2 3 agent or any federal prosecutor? 4 A. No. 5 Q. Has the FBI told you about other testimony? 6 A. No. 7 Q. Has the FBI told you about what other girls 8 have said? 9 A. No. 10 Q. 11 other girls have said? 12 A. No. 13 Q. Do you have any way of getting in touch 14 with the FBI if you wanted to get in touch with them? 15 A. No. 16 Q. 17 to get in touch with the FBI? 18 A. I don't know. 19 Q. And by your parents, I'm referring to both 20 sets, okay? 21 A. Oh. Well, I'm referring to only my dad, 22 because my mom really doesn't care to know any of this 23 stuff. 24 Q. So the answer would be the same for your 25 mom and A. No. Q. Have you ever text messaged with any FBI Have federal prosecutors told you what How about your parents? Do they know how Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 U2 0 316 EFTA00234345 Case 9:08-cv-80804-KAM nt 1-2 Entered on FLSD Docket 07/21/2008 Page 23 of 100 sor & Associates Rept-irons! sad Transcri pti Dn. Inc A. 1 2 3 Ocariz about this case? 4 A. No. Page 98 Q. Yeah. Have you spoken to a lawyer named Burt 5 Q. Do you know who Burt Ocariz is? 6 7 Does it refresh your memory that he's a good friend of 8 Marie Villafona's boyfriend? 9 A. I don't know who Marie Villafona is. 10 Q. Marie Villafona is the lead federal 11 prosecutor that's on the federal part of this case. 12 Okay? 13 A. No. 14 Q. So does it refresh your memory that Ocariz 15 is the good friend of Marie Villafona's boyfriend? 16 A. Not at all. 17 Q. Does it refresh your memory that Villafona 18 tried to get Epstein to pay for Ocariz to represent you 19 in the federal case? 20 A. No. 21 Q. Do you know if Detective Recarey has spoken 22 with your father? 23 A. No. 24 Q. Do you know if Detective Recarey has spoken 25 to your stepmother? Let's see if I can refresh your memory. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 123 of 316 EFTA00234346 Case 9:08-cv-80804-KAM D nt1-2 Entered on FLSD Docket 07/21/2008 Page 24 of 100 sor & Associates Roponiq and Transcripn cm. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Page 100 First off, this is not a warehouse. This is in garage. Second of all, I'm not being gang-raped. Everyone has their clothing on. Thirdly, if you'd look at all the other pictures in that album, I'm drinking -- what's when you're sick you drink it? BY MR. TEIN: Q. You can't ask questions of your counsel. A. All right. I'm drinking like Sprite. I'm not drinking any kind of alcohol, if you would look at my other pictures in that album. You guys picked the possibly worst pictures out of there to present. And it was just a goofy picture. All of these kids like to be goofy. And that's what we were doing. 17 O. Who's the man on the left of the picture 18 holding his -- holding a beer bottle as if it were a 19 pen:.s towards your mouth? 20 A. 21 Q. Who's the man behind you, right up towards 22 your backside, with you bent over? 23 A. That one? 24 Q. The right side, kissing with his mouth. 25 A. That's Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 120 of 316 EFTA00234347 Case 9:08-cv-80804-KAM D ent 1-2 Entered on FLSD Docket 07/21/2008 Page 25 of 100 nsor & Associates actor:nip encl 'Iranscnpunn. Inc Page 101 1 Q. He's the one grabbing towards the groin 2 area of 3 A. Yes. 4 O. And there's three other men in the photo. 5 What are their names? The one on the left with the hat? 6 A. That's (phonetic). 7 Q. Smiling? 8 A. Yes. 9 Q. Who's the one kissing -- 10 MR. LEOPOLD: Don't interrupt. Let her 11 finish the record. She's testifying. 12 MR. TEIN: I know you don't like this 13 picture, my friend. 14 MR. LEOPOLD: The picture is fine. 5 BY N.R. TEIN: 16 Q. Who's the one with the hat? 17 MR. LEOPOLD: No. Hold on. Stop, 18 You have to let the witness finish her 19 answer. She was in the process of explaining and 20 you cut her off. 21 Please finish what you were saying and then 22 Counsel can ask you whatever he wishes after that. 23 THE WITNESS: Okay. This guy -- 24 MR. LEOPOLD: Just make it so the record is 25 clear who you're referring to. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 175 0 316 EFTA00234348 Case 9:08-cv-80804-KAM nt 1-2 Entered on FLSD Docket 07/21/2008 Page 26 of 100 nsor & Associates Kollar:ins and lranscriptinn, Inc. Page 102 1 THE WITNESS: -- on the far left is 2 3 BY MR. TEIN: 4 Q. He's the one whose head is near the groin 5 of IIIIIIIIIIIIIIIIright? 6 A. Yes. 7 Q. And in the middle there's a man smiling. 8 who's that? 9 A. That's 10 Q. And who's the one in the red hat, kissing? 11 A. That's (phonetic). 12 Q. Let me stop you for a second. Are you 13 done? 14 A. Yes, I'm done. 15 Q. Who ilium, 16 A. My sister's friend. Well, she's a mutual 17 friend, but more my sister's. 18 Q. What is her last name? 19 A. 20 Q. Spell that. 21 A. I don't know how to -- 22 Q. Have you spoken to her about this case? 23 A. No. 24 Q. Who's IIIIIII 25 A. My sister's friend. I don't really speak a Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 12601316 EFTA00234349 Case 9:08-cv-80804-KAM DQpyynent 1-2 Entered on FLSD Docket 07/21/2008 Page 27 of 100 nsor & Associates Reportrup and Transeriptiam, inc. Page 103 1 to him at all. 2 3 4 5 6 7 case? (2• A. Q. A. What's his last name? Q. And have you spoken to Illiabout this 8 A. No, sir. 9 Q. Have you spoken to about this case? 10 A. Not in detail, but yes. 11 MS. BELOHLAVEK: Are we referring to 12 13 THE WITNESS: Yes. 14 MR. TEIN: Yes. 15 MS. BELOHLAVEK: Okay. 16 BY MR. TEIN: 17 Q. Have you spoken to =about this case? 18 A. wit 19 0. Do you have a friend named 20 A. I do not have a friend named 21 Q. From freshman year? 22 A. No. 23 Q. How about FM 24 A. No. 25 Q. Have you spoken to about this case? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 127 W 316 EFTA00234350 Case 9:08-cv-80804-KAM Dq jg ent1-2 Entered on FLSD Docket 07/21/2008 Page 28 of 100 nsor & Associates Roparnnp and 1 ranscrepnon. Inc Page 104 1 A. No. 2 Q. What's her last name? 3 A. IIIIIIIIIr I don't know how to spell it. 4 Q. Is she the person whose house you went to 5 on New Year's this year? 6 A. No. I wasn't at her house on New Year's. 7 Q. Where were you when you took the picture of 8 "Can you say blazed," that's on your website? 9 A. I wouldn't know or -- wait. We were at a 10 birthday party for some girl's 16th birthday. 11 Q. Were you drinking at that party? 12 A. No. There was no alcohol or anything 13 there. 14 Q. What does "blaze" mean to you? 15 A. It's like -- it just means like messed up. 16 But we weren't, if you look at the picture. 17 Q. Messed up like drunk, right? 18 A. Sure. 19 Q. Who's 20 A. A girl I know, like from like two years 21 ago. 22 Q. She's the one you were supposed to be NEW 23 staying with when you went drinking with 24 A. No. 25 Q. What's I last name? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 125 ot 315 EFTA00234351 Case 9:08-cv-80804-KAM Do ent 1-2 Entered on FLSD Docket 07/21/2008 Page 29 of 100 sor & Associates Reporting and Transcription, Inc 1 2 3 4 A. Q. A. Q. Page 105 live? In Royal Palm. Where does she I don't know. 5 A. Uh-huh. I'm guessing. 6 Q. Do you know her phone number? 7 A. No, I do not. 8 Q. Let's look at 25-010. 9 A. See, I'm drinking -- :0 Q. I'm not asking you about what you're 11 drinking. 12 Who are the men in this photo who are 13 pretending to gang up on you and stab you with knives? 14 who are they? 15 A. and 16 Q. Are these firemen? 17 A. Are those? . -- he said the 18 two stabbing with knives. That's why I said that. I 19 don't know. That's and 20 Q. Are these firemen? 21 A. No. They're all on -- except UMW 22 they're all on full rights for football. 23 Q. Go to 025-015. 24 MR. LEOPOLD: 025 dash? 25 MR. TEIN: 015. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 129 ot 315 EFTA00234352 Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 30 of 100 sor & Associates Ron/wimp and ranscrucion. inc. Page 106 1 THE WITNESS: Gosh, that's so long ago. 2 BY MR. TEIN: 3 Q. Who took the photo of you licking the 4 penis? 5 A. My stepmother. 6 Q. Whose idea -- that was your stepmother's 7 idea? 8 A. It was in Buca di Beppo, where she works 9 currently, and that was before she worked there. And we 10 just thought it would be funny. 11 MR. TEIN: 19-007. Can you enlarge that? 12 BY MR. TEIN: 13 Q. Who took this photo of you simulating you 14 having sex with a man? 15 A. We're not simulating having sex, and 16 it's -- oh, and the person who took it was, I'm pretty 17 sure, =out I know him as= I don't know his 18 last name. 19 Q. Go to 19-006, please. 20 Who took this photo of you simulating sex 21 with a man? 22 A. The same person. And we're not simulating 23 having sex, Mr. -- 24 Q. Tein. 25 Did you post that on the Internet? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 17001 716 EFTA00234353 Case 9:08-cv-80804-KAM Doc ent 1-2 Entered on FLSD Docket 07/21/2008 Page 31 of 100 nsor & Associates Raparti top and Transcript& Inc. 1 Page 107 A. Actually, this is an old MySpace I never 2 finished and I never like did anything. I just kind of 3 made it and left it. 4 Q. So the answer is yes, you posted this on 5 MySpace? 6 A. Yup. 7 Q. Go to 25-016. Who took this photo of you 8 simulating sex with a woman? 9 MR. LEOPOLD: Object to the form of the 10 question. Argumentative. 11 THE WITNESS: First off, she's piercing my 12 belly button or repiercing it, and I'm pretty sure 13 it was just like we put up a camera somewhere and 14 put a timer on it. We didn't have anybody take 15 it. 16 BY MR. TEIN: 17 Q. You posted that on your MySpace page? 18 A. Yeah. 19 Q. Go to 25-013. Is that a photo of you? 20 A. Yep. 21 Q. Who's in the photo with you? 22 A• 23 Q. 24 A. Yep. 25 Q. Is this you coming out of the shower? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 131 01315 EFTA00234354 Case 9:08-cv-80804-KAM Do yrjent 1-2 Entered on FLSD Docket 07/21/2008 Page 32 of 100 nsor & Associates Reporting and "'mac ti plum, Mc Page 108 1 A. Yes. 2 Q. Are you clothed in this picture? 3 A. Yeah. I have a halter dress on. 4 Q. Where is that picture taken? 5 A. In house. 6 Q. Did you post that on the Internet? 7 A. Yes. 8 Q. All right. 9 MR. TEIN: You can take that down. 10 BY MR. TEIN: 11 Q. Now your boyfriend is 12 correct? 13 A. Yeah. 14 Q. You lie about your age in order to conceal 15 something about your relationship with 16 isn't that correct? 17 A. No. :8 Q. IIIIIIII 22 years old, isn't he? 19 A. Yes. 20 Q. And a firefighter with the Palm 21 Beach Fire Department, right? 22 A. Yup. 23 Q. Does the Palm Beach Fire Department know 24 that your boyfriend is dating an underage girl? 25 A. Actually, mister, it's legal. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 132 o1316 EFTA00234355 Case 9:08-cv-80804-KAM D ent 1-2 Entered on FLSD Docket 07/21/2008 Page 33 of 100 ill nsor & Associates Reprint np and Transcliptiam,lnc Page 109 1 O. Well -- 2 MR. LEOPOLD: Just answer the question, 3 IIIIIIIIII 4 THE WITNESS: Yes. 5 BY MR. TEIN: 6 Q. Did they know two weeks ago that you were 7 dating an underage girl (sic)? 8 A. Yes. I met everybody in there. 9 Q. Did they know your age? 10 A. Yes. 11 Q. Did you lie about your age so that the fire 12 department wouldn't think thatillillis committing a 13 crime by having a sexual relationship with an underage 14 girl? 15 MS. BELOHLAVEK: Objection. Assumes facts 16 not in evidence. 17 BY MR. TEIN: Q. You can answer the question. 19 A. No. 20 Q. Does the Palm Beach Police Department know 21 that is having a sexual relationship with an 22 underage girl? 23 MR. LEOPOLD: Don't guess. Answer if you 24 know. 25 THE WITNESS: Can you repeat the question? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 133 ot 315 EFTA00234356 Case 9:08-cv-80804-KAM Qgcent1-2 Entered on FLSD Docket 07/21/2008 Page 34 of 100 nsor & Associates Reporting and lanstripnon. Inc. Page 110 1 BY MR. TEIN: 2 Q. Does the Palm Beach Police Department know 3 that'll. a member of the Palm Beach Fire Department, 4 is having a sexual relationship with an underage girl? 5 A. I'm guessing no. 6 Q. You lie about your twin sister don't 7 you? 8 MR. LEOPOLD: Objection. Argumentative. 9 BY MR. TEIN: 10 0. Don't you? 11 A. No. I have never lied for or to 12 Q. You lie about the fact that she has a drug 13 hab:.t, right? 14 A. No. I would never accuse my sister of 15 having a drug habit. 16 Q. Do you try to conceal the fact that she has 17 a drug habit? 18 MR. LEOPOLD: Objection. Argumentative. 19 BY PR. TEIN: 20 Q. You can answer the question. 21 A. No. My sister does not have a drug habit. 22 Q. You lied when you went to the crack house 23 in Georgia, didn't you? 24 MR. LEOPOLD: Objection. Argumentative. 25 Lack of foundation, lack of predicate. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 17144715 EFTA00234357 Case 9:08-cv-80804-KAM D nt 1-2 Entered on FLSD Docket 07/21/2008 Page 35 of 100 n5or & Assocates Ramming and lranstripnon, Inc 1 2 3 4 5 Page 111 THE WITNESS: Never -- what did you say? BY MR. TEIN: Q. You lied when you went to the crack house in Georgia, didn't you? MR. LEOPOLD: Objection. Argumentative. 6 Lack of foundation, lack of predicate. 7 BY MR. TEIN: 8 Q. You can answer the question. 9 A. I have never been to a crack house. 10 Q. Who don't you lie to? 11 MR. LEOPOLD: Objection. Argumentative. 12 Don't answer the question. 13 MR. TEIN: Certify it. 14 CERTIFIED QUESTION 15 BY MR. TEIN: 16 Q. You don't lie to IIIIIIIdo you? 17 MR. LEOPOLD: Objection. Asked and 18 answered. :9 Don't answer the question. 20 BY MR. TEIN: 21 Q. No. You can answer that question. 22 MR. LEOPOLD: No. I just told her not to. 23 You've asked that question about five -- 24 MR. TEIN: No, I haven't. 25 MR. LEOPOLD: Don't answer the question. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 WS 0 316 EFTA00234358 Case 9:08-cv-80804-KAM Do • nt 1-2 Entered on FLSD Docket 07/21/2008 Page 36 of 100 nsor & Associates Reaaratc end Transcri pap. Inc Page 112 1 MR. TEIN: I'll certify it. 2 CERTIFIED QUESTION 3 MR. LEOPOLD: For the record, you have to 4 stop interrupting me because she can't take down 5 both of us talking at the same time. 6 BY MR. TEIN: 7 Q. You tell _the truth, don't you? 8 A. Excuse me? 9 Q. You tell - the truth, don't you? 10 A. When it's -- yes, I tellellftthe truth. 11 Q. Who's drug dealer? 12 A. My sister does not have a drug dealer. She 13 lives in Georgia with my mother. 14 Q. Okay. Who is the drug dealer who dropped 15 you and IIIIIIIoff at 5:45 a.m., in 2006, after being out 16 all night, the two of you, using drugs at Palm Beach 17 Country Estates where your father called the police? 18 A. 19 Q. He's the drug dealer? 20 A. He is a drug dealer. 21 Q. Do you remember was arrested by the 22 Palm Beach Police Department and taken to the Juvenile 23 Assessment Center that morning? 24 A. I do remember that. 25 Q. Now before you massaged Epstein, you were Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 136 o1316 EFTA00234359 Case 9:08-cv-80804-KAM nt 1-2 nte/ed on FL$D Docket 07/21/2008 Page 37 of 100 nsor & Associates Reporting and Transcri rizi no, Inc Page 113 1 involuntarily admitted into a juvenile educational 2 facility; isn't that right? 3 A. Did you say involuntarily? 4 Q. Yes. 5 A. No. I was willing to go. I -- duly said 6 sure. 7 Q. And you went there because you were lying 8 so much, no one could control you; isn't that correct? 9 A. That's very incorrect. 10 Q. Now you lie to your parents all the time, 11 dor't you? 12 A. Incorrect. 13 MR. LEOPOLD: Objection. Argumentative. 1 4 BY MR. TEIN: 15 Q. Sorry? 16 A. Incorrect. 17 Q. The day you went to Epstein's house you 18 lied to your father about where you were going; isn't 19 that correct? 20 A. Correct. 21 Q. You admitted to the police that you told 22 you: father that you were going shopping, didn't you? 23 A. Yes. 24 Q. And that was a lie, wasn't it? 25 A. Yes. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 137 8715 EFTA00234360 Case 9:08-cv-80804-KAM t 1-2 ntved on FL,SID Docket 07/21/2008 Page 38 of 100 nsor Associates Ropnm ns and Transcripoco, 1 2 3 4 Page 114 Q. And isn't it true that your father has accused you of lying? A. All the time. Q. Didn't your father throw you out of the 5 house Thanksgiving of this past year because you were 6 lying so much to him? 7 A. Yes, he did kick me out. No, that's not 8 the reasons why. 9 Q. Didn't your father throw your sister 10 out of the house, too? 11 12 Q. 13 after Thanksgivings, right? 14 15 Q. Sounds about right? 16 A. Sure. 17 Q. And the reason he threw her out of the 18 house was because she was lying, too? 19 MR. LEOPOLD: Objection. Lack of 20 foundation. Calls for speculation. 21 BY R. TEIN: 22 Q. When your counsel coaches you, you say it's 23 correct, right? 24 25 MR. LEOPOLD: Objection. A. Yes. And he threw her out of the house the week A. I don't know the date, but sure. A. I've never been coached. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 13601316 EFTA00234361 Case 9:08-cv-80804-KAM nt 1-2 ntgred on FL,SD Docket 07/21/2008 Page 39 of 100 sor ) Associates Report, np, and "transcription. Inc. 1 BY MR. TEIN: 2 Q. Page 115 Okay. When your counsel that it was there 3 was lack of foundation, you agree with your counsel, 4 richt? 5 A. I was like saying, "Yeah, let's move on," 6 because there was no point to asking that question. 7 Q. Your father threw'," out of the house 8 because she was lying, correct? 9 MR. LEOPOLD: Objection. Lack of 10 foundation. 11 Hold on... Let me just make the 12 objection. 13 Lack of foundation, predicate, calls for 14 speculation. 15 BY MR. TEIN: 16 Q. Answer. 17 A. I'm not my sister. I don't know. 8 Q. I want to know what you know only. 19 A. I don't know. 20 Q. You don't know. That's your answer? 21 A. Yes. 22 Q. Now your parents filed the police report 23 regarding Mr. Epstein, right? 24 A. Yes. 25 Q. Now your parents are also lying, aren't Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 13901616 EFTA00234362 Case 9:08-cv-80804-KAM nt 1-2 ;ritexed on FLSD,Docket 07/21/2008 Page 40 of 100 sor P,ssociates Ropnrunfi and l'unscription. lac. 1 2 3 4 they? Page 116 A. Yes. MR. LEOPOLD: Just so the record is clear, the father -- because the mother was up north. 5 MR. TEIN: Don't testify, Counsel. 6 MR. LEOPOLD: So the record is clear, just 7 the father. The mother was -- 8 MR. TEIN: Counsel, don't coach and 9 testify, please. That's absolutely improper. 10 MR. LEOPOLD: You just asked the wrong 11 question. 12 MR. TEIN: You can't coach her that way and 13 you well know it. 14 MR. LEOPOLD: For the record, it's the 15 father. He's remarried, I think on his third 16 marriage. 17 MR. TEIN: You cannot -- it's absolutely, 18 totally against the rules and you know it. 19 MR. LEOPOLD: The natural mother lives in 20 Georgia. 21 MR. TEIN: You need to behave yourself, L2 lawyer. 23 MR. LEOPOLD: The natural mother lives in 24 Georgia. The father is here locally. 25 MR. TEIN: Stop coaching. Stop talking. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 14001316 EFTA00234363 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 117 You object. You know the rules. You just lectured me about the rules, Counsel. So why Case 9:08-cv-80804-KAM nt 1-2 Entered on FL$D Docket 07/21/2008 Page 41 of 100 nsor & Associates Reparung and lranscri pn on, lnc 1 2 3 don't you play by the rules? Or only when they 4 fit you? Why don't you grandstand a little more 5 now. Give us a five-minute speech, Mr. Leopold. 6 MR. LEOPOLD: Are you finished, for the record? MR. TEIN: I'm not talking to you. Do what you want. MR. LEOPOLD: Don't say anything yet. BY MR. TEIN: Q. gar your parents -- MR. LEOPOLD: Hold it. Don't say anything yet. Let me -- BY MR. TEIN: Q. Your parents, who filed the police report are also liars. MR. LEOPOLD: Don't answer the question. We're not going to answer until I make the record. I want to put on the record, now that Counsel appears to be finished with his comments for the record, that the previous question was inappropriate, was intentionally misleading. Now you can ask the question. BY MR. TEIN: Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 141 of 316 EFTA00234364 Case 9:08-cv-80804-KAM Q• nt 1-2 Entered on FL$D Docket 07/21/2008 Page 42 of 100 sor & Associates Roporting mid Transcription, Inc Page 118 1 2 in this case, are also proven liars, aren't they? 3 4 BY MR. TEIN: 5 Q. Aren't your parents liars? 6 MR. LEOPOLD: Calls for speculation. Lack 7 of predicate. 8 MR. TEIN: Stop coaching. You know what 9 that is, Leopold. 10 MR. LEOPOLD: Calls for speculation. Lack 11 of foundation. 12 THE WITNESS: When you say parents, my mom 13 is not, but sure, yeah, my dad has been to jail 14 for lying. 15 BY MR. TEIN: 16 Q. Your dad went to federal prison for two 17 yea:s for lying, right? 18 A. Correct. 19 Q. Did he tell you it was for a financial 20 fraud? 21 A. Yes. 22 Q. For stealing money from some financial 23 institution? 24 A. Correct. 25 Q. And do you think your father is trying to Your parents, who filed the police report MR. LEOPOLD: Same objection. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 142 of 316 EFTA00234365 Case 9:08-cv-80804-KAM nt 1-2 Entered on FLSD Docket 07/21/2008 Page 43 of 100 sor & Associates Reper•.imp and l'anscripoon, Inc Page 119 1 steal your lawsuit money away from you? 2 Don't look to your lawyer for the answer. 3 MR. LEOPOLD: You can answer if you know 4 the answer to it. I have no idea. 5 THE WITNESS: Yeah. 6 BY MR. TEIN: 7 Q. And your father filed a lawsuit, the first 8 lawsuit for fifty million dollars against Mr. Epstein 9 without consulting you, correct? 10 A. Correct. 11 Q. And your father had a lawyer file the first 12 lawsuit on your behalf for fifty million dollars against 13 Mr. Epstein without your knowledge, correct? 14 A. Correct. 15 Q. And you don't trust your father, do you? 16 A. Correct. 17 Q. And you believe he's trying to manipulate 18 you for his own gain, don't you? 19 A. Sort of. 20 0. Well, you know that your mother filed a 21 statement, an affidavit, saying that you don't trust your 22 father and that you believe he's trying to manipulate you 23 for lis own gain; isn't that correct? 24 A. Correct. 25 Q. You agree with that statement, don't you? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 10 0 316 EFTA00234366 Case 9:08-cv-80804-KAM D nt 1-2 Entered on FLSD Docket 07121x2008 Page 44 of 100 nsor & Associates kopornns cod I:inn:mince). Inc 1 2 3 4 5 6 A. Uh-huh. Yes. Q• Do you trust your stepmother? A. My stepmother, no. Q• Page 120 You think she's also trying to steal your Epstein lawsuit money away from you, don't you? A. I would like to clarify something. You 7 keep saying my Epstein lawsuit money. I don't have any 8 money, and it's just a lawsuit at the moment. So I just 9 don't trust her. 10 Q. Okay. You think that your stepmother is 11 trying to take advantage of this lawsuit to try to get 12 money from Mr. Epstein that belongs to you, right? 13 A. Yes. 14 Q. Did your stepmother tell you why she was 15 arrested? 16 . A. No. 17 Q. Did your stepmother tell you that she's 18 ever been arrested? 19 A. No. 20 Q. Did she tell you she was arrested for 21 fraud? 22 A. Never. 23 Q. Did she tell you that she was fired from 24 Hawthorne Aviation? 25 A. No. ylOWOMAID V Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 14404016 EFTA00234367 Case 9:08-cv-80804-KAM nt 1-2 Entered on FLSD Docket 07/21/2008 Page 45 of 100 sor & Associates Hcpnr•.inp and Tanscriptico, Inc Q. Page 121 1 2 Hawthorne Aviation for stealing? 3 A. No. 4 MR. TEIN: Let's take a break. 5 (Thereupon, a recess was taken.) 6 BY MR. TEIN: 7 Q. before you met Jeffrey Epstein, had 8 you ever had sexual intercourse? 9 A. Yes, yeah. 10 Q. How many times? 11 A. Just a few. Twice. 12 Q. With how many different men? 13 A. Two. 14 Q. How old were they? 15 A. being one year older than me, 16 and then the other person was two years older than me. 17 Q. What was his name? "18 A. 19 Q. How old were you when you first had sexual 20 intercourse? 21 A. 14. 22 Q. 23 many different men had you had any type of sexual 24 act:.vity with? Did she tell you that she was fired from How many -- before you met Epstein, how 25 A. Just those two. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 145 of 316 EFTA00234368 Case 9:08-cv-80804-KAM D 1-2 Entered on FLSD Docket 07/21/2008 Page 46 of 100 nsor & Associates Raprusina and Transcription, Inc. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 122 Q. Are you saying you never kissed a man other than those two? MR. LEOPOLD: Objection to the form of the question. THE WITNESS: Yes, I had kissed people before. BY MR. TEIN: Q. Before you met Epstein, had you ever had orel sex? A. No. Q. Ever in your life, have you exchanged sex for something of value? A. No. MR. TEIN: We're done. THE WITNESS: Oh, okay. MR. LEOPOLD: We'll read. MS. BELOHLAVEK: I don't have any questions. Thank you. MR. LEOPOLD: Before we go off the record, it's my understanding -- Mr. Goldberger can correct the record -- but we have stipulated that color copies of the documents that were identified for identification certainly will be attached to the deposition and counsel will be taking the photographs across street so that they can be Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 146 W016 EFTA00234369 Case 9:08-cv-80804-KAM nsor & nAssociates tered on FLSD Docket 07/21/2008 Page 47 of 100 Roportinp and lranscriptico, lac. Page 123 1 laser color copied so that we have a copy, and I'm 2 assuming he'll get a copy to the court reporter, 3 too, to attach, actually a certified copy to the 4 deposition. 5 MR. GOLDBERGER: Done. 6 MR. LEOPOLD: That's if you agree to that. 7 If not, then I want to pull each one out and put 8 exhibit labels on them, which we should do before 9 we leave. 10 MR. GOLDBERGER: We're not going to do 11 either. I'll have copies sent to the court 12 reporter and she can attach them to the 13 deposition. 14 MR. LEOPOLD: So you're not going to agree 15 to what we talked about during the break then. 16 MR. GOLDBERGER: I'm not quite sure what 17 your asking me to do. Let me finish. 18 MR. LEOPOLD: Okay. Sure. That's fine. 19 MR. GOLDBERGER: Okay. If you want me to 20 go over to Ms. Belohlavek's office and make copies 21 and then I'll give those to the court reporter, 22 fine. All I'm saying is that I would avoid that 23 process. I would send copies to the court 24 reporter. But if it will make you happier -- 25 MR. LEOPOLD: I'm not? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1001316 EFTA00234370 Case 9:08-cv-80804-KAM nt 1-2 gntwed on FLSD, Docket 07/21/2008 Page 48 of 100 sor tissociares Roponing and Transcription, Inc 1 2 3 Page 124 MR. GOLDBERGER: Let me finish. MR. LEOPOLD: I'm not interrupting now. MR. GOLDBERGER: But if it will make you 4 happier if I go over to Ms. Belohlavek's office 5 and make a copy of those photos that were part of 6 this deposition and then I'll give them to the 7 court reporter, I'll be happy to do it. 8 MR. LEOPOLD: I trust you implicitly, 9 however you with to do it. However, the 10 documents, before they leave this room, need to 11 have an exhibit sticky on them with the 12 appropriate -- 13 MR. GOLDBERGER: Want to go get some? We 74 don't have any. 15 MR. LEOPOLD: I will do that. Excuse me. 16 Let me finish the record, please. You can't do 17 that to the court reporter. She's going to stroke 18 out. You can't do that. You have to let me -- 19 MR. TEIN: Finish your sentence, Ted. You 20 are the most long-winded lawyer I've ever seen in 21 my life. Finish your sentence. 22 MR. LEOPOLD: Jack, tell him not to raise L3 his voice, please. 24 MR. TEIN: Finish your sentence. Is there 25 going to be a period at the end of the sentence or Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1/601 316 EFTA00234371 Case 9:08-cv-80804-KAM ent 1-2 nEntcred on FLSQ Docket 07/21/2008 Page 49 of 100 sor disk Associates Rep.-mins and Transcriponm, Inc 1 2 3 4 Page 125 is it just going to be comma after comma after comma? Go ahead, lawyer. MR. LEOPOLD: All right. The exhibits, I 5 can't prevent you from taking them, but I will 6 object and I will be bringing it to the court for 7 sanctions. You cannot take the exhibits out of 8 the room without them being marked. I want them 9 marked, because you cannot identify in the record 10 what was used. And with all due respect to 11 Mr. Goldberger, I do not -- the way this 12 deposition is going, I do not want to rely on 13 Counsel from Miami to mark the appropriate 14 exhibits. I will not do that. I cannot prevent 15 you from taking them. But if you do, I will be 16 bringing the matter to the court with appropriate 17 sanctions, because that is improper. That is 18 improper. When you use something in a deposition, 19 they are to be marked. And you have refused to do 20 that throughout for what ever reason. 21 MR. TEIN: You're wrong. Finish your 22 sentence because you're talking about something 23 you have no idea. 24 Every single one is marked, Ted. Every 25 single one is already marked. But you want to Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 149 o1316 EFTA00234372 Case 9:08-cv-80804-KAM t1-2 elEntered on FLSQ Ckx*et07/21/2008 Page 50 of 100 n5or 6). Associates Ronartinp and lrinscriFlon.inc 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 126 argue about everything. Ever single one is already marked. Isn't that silly, Ted? MR. GOLDBERGER: Thirty years of doing this and I have never had an argument over this. MR. TEIN: You've made -- Ted, you are obstructionist, you are a liar. You have lied and misrepresented things, for the record. You are grandstanding. MR. LEOPOLD: You need to back up. MR. TEIN: No, no. I'm going to finish. MR. LEOPOLD: You can finish, but don't hover over me. MR. TEIN: No one is hovering over you. Stop trying to make a lying record. Let me say something else. Don't you dare threaten me with sanctions, after you lied in a letter to my co-counsel about the fact -- be quiet. Be quiet and let me finish. You lied in a letter to my co-counsel, Mr. Leopold, in which you said -- it was a complete and utter lie -- that you were unavailable this morning because you had a hearing. That was a lie. I have never seen a lawyer deign to do something like that. So you will get the ex -- be quiet. Let me Ph. 561.682.0905 - Fax. 561.682.1771 1655 Pali) Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1500? 310 EFTA00234373 Case 9:08-cv-80804-KAM ent 1-2 ntered on FLSO Docket 07/21/2008 Page 51 of 100 sor 1 Associates Reparnna and Transcriphnn. Inc 1 2 3 me. 4 Page 12-; finish. You behave. MR. LEOPOLD: Don't point your finger at MR. TEIN: Listen. Be quiet and I won't 5 have a need to point it at you. 6 7 8 9 me. 10 MR. TEIN: Mr. Leopold, let me finish. 11 MR. LEOPOLD: Don't raise your voice 12 either. 13 MR. TEIN: Mr. Leopold -- 14 MR. LEOPOLD: Jack, do you want to take 15 care of this? 16 MR. TEIN: Let me finish my sentence. The 17 exhibits are marked. We are walking out of here. 18 19 record. It is absolutely atrocious what you do. 20 That is not how a lawyer should behave. This 21 deposition is over. You will get your exhibits, 22 Mr. Leopold. 23 MR. GOLDBERGER: I understand what you're 24 saying, Michael, and I understand Ted's position. 25 MR. LEOPOLD: Don't point your finger at MR. TEIN: Mr. Leopold -- MR. LEOPOLD: Don't point your finger at You are someone who misrepresents the Just so there's -- we're going to have lots Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 151t0316 EFTA00234374 t o Case 9:08-cv-80804-KAM nt 1-2 Entered on FLSt1Docket07/21/2008 Page 52 of 100 nsor A55OClatC5 Rcpnninc and ltanstrimarel. Inc. Page 128 1 of issues in this case. We're going to have lots 2 of reasons to disagree. 3 I'm going to take it over now and I'm going 4 to make copies and I'm going to give them to 5 Ms. Consor. If you want to go find some exhibit 6 labels and put some exhibit labels on it, be my 7 guest. But that's what I'm offering to do. 8 THE WITNESS: Let me say two things, 9 because I am happy to always disagree, and with 10 you, I have no problem; we could always do it 13. professionally. I have not problem. 12 I want to say two things so the record is 13 very clear. 14 Since for whatever reason I have not been 15 able to look at exhibits, because they have been 16 refused to have been shown to me -- 17 MR. TEIN: That's a lie. 18 MR. LEOPOLD: -- Jack, if you represent 19 that the documents have the appropriate exhibit 23 numbers or some identifying markings, 25, 30.000, 21 whatever they may be, then you can take them, make 22 copies, send me a copy, make sure the court 23 reporter gets a copy and then send me a bill for 24 my copies, that's fine. I didn't know that they 25 are marked that way because I haven't been able to Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 152 0715 EFTA00234375 * Case 9:08-cv-80804-KAM 1-2 fl. r-k 07/21/2008 Page 53 of 100 nnt so r et n‘ dgnoFaafeg‘et Renaming and lranscripan. lac Page 129 1 look at them. 2 MR. GOLDBERGER: They are barcoded, and the 3 number that we've made reference to in the 4 deposition coincides with the barcoding. 5 MR. LEOPOLD: That's fine. Eight by eleven 6 color laser copies are fine. 7 MS. BELOHLAVEK: The State Attorneys Office 8 is not going to charge anybody for color copies I 9 print out. 10 MR. LEOPOLD: That's fine. He's going to 11 take them back to his office. 12 Secondly -- and I will be more than happy 13 to do it, because it sounds like you all know more 14 about it than I -- but I'm happy to get affidavits 15 from Mr. Pincus, Judge Stern, everybody else about 16 what happened with this hearing today, because 17 know very little about it. But my representations 18 are what they are. 19 MR. GOLDBERGER: They stay -- 20 MR. LEOPOLD: Let me just finish for the 21 record. 22 My representations or comments about what 23 happened, representation about this hearing this 24 morning, I know very little about it. I 25 MR. GOLDBERGER: I'll take your word on Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 153W3M EFTA00234376 Case 9:08-cv-80804-KAM nt 1-2 -Entered on FLSO Docket 07/21/2008 Page 54 of 100 sor & Associates korinntris and TIIIII3Cfi prin. lnc that. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 130 MR. LEOPOLD: No, no, no. I just put it on the record. I will get an affidavit -- I'm assuming it sounds like you need it -- from Mr. Pincus. I have no clue about what happened and why it was canceled. All I was told when I was out of town yesterday was that the hearing this morning was cancelled. MR. GOLDBERGER: I'll take your word for it. MR. LEOPOLD: If you want an affidavit, I'll get it for you. MR. GOLDBERGER: It's a personal issue for me because I had to disrupt a vacation and if it was done just because it wasn't convenient for you, then I'm offended by that. But if you're telling me that it was planned and it didn't happen, I'll take your word for it. MR. LEOPOLD: I am more than happy to get you an affidavit, because I don't know the reason why it was canceled other than the fact that I'm assuming since my deposition was taken for four hours on Monday for preparation for the hearing today, for whatever reason it was canceled, I am told it is being re-noticed. Why it was canceled, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 154 14 315 EFTA00234377 Case 9:08-cv-80804-KAM nt 1-2 r•Entkred on FLSQ Docket 07/21/2008 Page 55 of 100 sor Associates Rept-mint and Transt I i New. Inc. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 131 I have no idea, but if your co-counsel wishes an affidavit to that effect from Mr. Pincus, I'm more than happy to get it. But I don't know the reason why it was canceled. MR. TEIN: I don't need it. But what I do take issue with is regardless of why it was canceled, you owed us the courtesy of saying, You know what? We can start earlier this morning. MR. LEOPOLD: I owe you nothing. MR. TEIN: I don't care. Don't interrupt me. Because Jack canceled his vacation plans because of you. MR. GOLDBERGER: That's all right, that's all right. MR. TEIN: And you're selfish. And this deposition is over. Good-by Mr. Leopold. MR. GOLDBERGER: You can go off the record. - - - Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 155 Of 316 EFTA00234378 Case 9:08-cv-80804-KAM 2 r ritAglged.plaocket 07/21/2008 Page 56 of 100 5O1 N. on Reporuns and 1r/uncoil:inn, 'Inc 1 2 3 4 The State of Florida, CERTIFICATE 5 County of Palm Beach. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 23 21 22 23 24 25 Page 132 I hereby certify that I have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed. Dated this day of , 2008. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 156 (4 316 EFTA00234379 I llO r Case 9:08-cv-80804-KAM ' ' 1-2 -P , nnr 07/21/2008 Page 57 of 100 nnt5Or eanA t rgscsaactnesket RI:toning and Transcripano, inc Page 133 1 2 DATE: February 25, 2008 TO: c/o L 3 Office of the State Attorney 401 N. Dixie Highway 4 west Palm Beach, Florida 33401 5 IN RE: STATE OF FLORIDA -V- JEFFREY EPSTEIN CASE NO.: 2006 CF09454AXX 6 Please take notice that on Wednesday, the 7 20th of February, 2008, you gave your deposition in the above-referred matter. At that time, you did not waive 8 signature. It is now necessary that you sign your deposition. 9 Please call our office at the below-listed number to schedule an appointment between the hours of 10 9:00 a.m. and 4:30 p.m., Monday through Friday. 11 If you do not read and sign the deposition wittin a reasonable time, the original, which has already 12 beer forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your 13 signature, sign your name in the blank at the bottom of this letter and return it to us. 14 Very truly yours, 15 Judith F. Consor, FPR 16 Consor & Associates Reporting and Transcription 1655 Palm Beach Lakes Boulevard, Suite 500 17 West Palm Beach, Florida 33401 18 I do hereby waive my signature: 19 20 cc via transcript: JACK A. GOLDBERGER, ESQ. 21 LANNA BELOHLAVEK, ESQ. MICHAEL R. TEIN, ESQ. 22 THEODORE J. LEOPOLD, ESQ. file copy 23 24 25 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 157 of 316 EFTA00234380 Case 9:08-cv-80804-KAM y6r gnnsoomisket 07/21/2008 Page 58 of 100 Reporting ad Transcription, Inc Page 134 1 ERRATA SHEET 2 IN RE: STATE-V-JEFFREY EPSTEIN DEPOSITION OF: TAKEN: February 20th, 3 2008 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 4 PAGE # LINE # CHANGE REASON 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 22 Please forward the original signed errata sheet to this office so that copies may be distributed to all parties. 22 23 24 25 Under penalty of perjury, I declare that I have read my deposition and that it is true and correct subject to any changes in form or substance entered here. DATE: SIGNATURE OF DEPONENT: Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 158 of 315 EFTA00234381 Case 9:08-cv-80804-KAM -6r gzotAeg6bFaSSif8gcet 07/21/2008 Page 59 of 100 Ropnrunp and Trinscrireco. inc Page 135 1 THE STATE OF FLORIDA, ) 2 COUNTY OF PALM BEACH. ) 3 4 5 I, the undersigned authority, certify that 6 personally appeared before me on the 20th 7 of February, 2008 and was duly sworn. 8 9 WITNESS my hand and official seal this 25 day 10 of February, 2008. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Judith F. Consor, FPR Notary Public - State of Florida Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 159403I6 EFTA00234382 Case 9:08-cv-80804-KAM ivi5ONgEOthifieget 07/21/2008 Page 60 of 100 herinnunE and 'I ranscri pnon. Inc 1 2 CERTIFICATE Page 136 The State Of Florida, ) 3 County Of Palm Beach. ) 4 5 I, Judith F. Consor, Court Reporter and Notary Public in and for the State of Florida at large, do 6 hereby certify that I was authorized to and did stenographically report the deposition of 7 that a review of the transcript was regueste ; anc at the foregoing pages, numbered from 1 to 131, inclusive, 8 are a true and correct transcription of my stenographic notes of said deposition. 9 I further certify that said deposition was 10 taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and 11 completed as hereinabove set out. 12 I further certify that I am not an attorney or counsel of any of the parties, nor am I a relative or 13 employee of any attorney or counsel of party connected with the action, nor am I financially interested in the 14 action. 15 The foregoing certification of this transcript does not apply to any reproduction of the same by any 16 means unless under the direct control and/or direction of the certifying reporter. 17 18 9 0 21 22 23 24 25 DATED this 25 day of February, 20 • Judith F. Consor, Court Repo (.41-30211 t Florida Professional Reporter Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 150 0 315 EFTA00234383 Case 9:08-cs-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 61 of 100 STATE COURT PLEADINGS EFTA00234384 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 62 of 100 .f3rr ut nen Page. 15151 Date 5129/200812.09:; A IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA JANE DOE, by and through JANE DOE'S MOTHER as parent and natural guardian, • Plaintiffs, V . JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants, 962118 a 0 065 9 6,0000e COMPLAINT ' Plaintiffs, JANE DOE, by and through JANE DOES MOTHER as parent and natural guardian of JANE DOE, bring this Complaint against Defendants JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, and state as follows: Parties, Jurisdiction and Vonuc I. Jane Doe is a citizen and resident of the Stale of Florida. She is a minor under the age of I 8 years. 2. Jane Doe'S Mother brings this action as parent and natural guardian of Jane Doe. 3. This Complaint is brought under fictitious names to protect the identity of the Minor Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 4. DefendanfJeffrey Epstein is a citizen and resident of the State of New York. 5. Defendant Haley Robson is a citizen and resident of Palm Beach County, Florida. 6. Defendant Sarah Kellen is a citizen and resident of the Suite of New York. 162 of 316 This fax was received by GFI FAXmaker fax server For more information, visit: http://wmar gfi.com EFTA00234385 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 63 of 100 From 11 ,can Page 16/51 Date 5129/2006 12:09: M 7. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000) exclusive of interest and costs 8. Venue is proper in this Court under section 47.011, Florida Statutes, because the causes of action brought herein accrued in Palm Beach County, Florida and one or more Defendants resides in Palm Beach County, Florida. Factual Allegations 9. At all relevant times, Defendant Jeffrey Epstein was an adult male. F;pstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, Florida. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach. 10. Jpon information and belief, Epstein has a sexual preference and obsession For minor girls. He engaged in a plan, scheme, and/or enterprise in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls or coerced them to engage in prostitution, and then gave them money. In or about 2005, Jane Doc, then 14 years old, fell into Epstein's trap and became one of his victims. I I. Upon in formmion and belief, Jeffrey Epstein carried out this scheme/enterprise and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas. 12. An integral player in Epstein's Florida scheme was Sarah Kellen, an assistant of Epstein's front New York, New York and Haley Robson, a Palm Beach Community college student from Loxahatchee. Florida. They recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan/enterprise. Ms. Robson was contacted shortly befare or soon after Epstein was at his Palm Beach residence Epstein, Kellen or someone on their behalf directed Ms. Robson to bring one or more underage girls to the residence. Page 2 of 9 153 et 315 This fax was received by GFI FAXmakei fax solver. For more information, visit http.//www gip corn EFTA00234386 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 64 of 100 From ui wn Page 17/51 Date 5/29/2008 12 09 ", A Ms. Robson, upon information and belief, generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who would be enticed by the money being offered - generally $200 to $300 per "massage" session — and who were perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made This was an important elementof Epstein's plan/enterprise 13. Epstein's plan. scheme, and/or enterprise reflected a particular pattern and method. Upon arrival at Epstein's mansion. Mr. Robson would introduce each victim to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would:then bring the girl up a flight of stairs ton bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom. Ms. Kellen would then leave the girl alone in this room, whereupon Epstein would enter wearing only a towel. He would then remove his towel, lay down naked on the massage table, and direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and sexual acts, including masturbation, touching the girl's vagina with a vibrator, or digitally penetrating the girl's vagina. 14. Consistent will the foregoing plan, scheme, and/or enterprise, Ms. Robson recruited Jane Doc to give Epstein a massage for monetary compensation. Ms. Robson brought Jane Doe to Epstein's mansion in Palm Beach. Jane was introduced to Sarah Kellen, who led her up the flight of stairs to the room with the massage table Ms. Kellen set up the message table and laid out message oils and told Jane Doe that Epstein would be in shortly and than left the room. Jane Doe was alone in the room when Epstein arrived. Epstein told her to remove her clothes and left the room. When Epstein returned he was wearing only a towel. He removed his towel, and laid down on his stomach on the message table. Epstein again told Jane Doe remove her clothes. In shock, fear and trepidation, Jane Doe complied, removing her clothes except for her panties and bra. Shortly Page 3 of 9 169 of 316 This fax was reetwed by GFI FAXmaker fax server. For more information, visit http./Mww gfi.com EFTA00234387 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket O7/21/2OO8 Page 65 of 100 From u wn Page 18151 Date 5/29/2008 12.09.: vl after starting to rub Epstein's back, Epstein told Jane Doe to sit on his back. Jane Doe, out of fear and trepidation, complied. After a period of time Epstein got up from the table and went behind the door. For several minutes Jane Doe heard loud noises and moans and believes that Epstein was masturbating'. Thereafter Epstein, naked, returned to the message table and laid face up on the table. Epstein than told Jane Doe to continue with the message and told her to sit on top of him. Out of fear and trepidation she complied. As Jane Doc rubbed Epstein's chest Epstein began tc use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane's vagina At this same lime Epstein was masturbating. Upon reaching orgasm Epstein Aot lip from the message table and told Jane Doe to write down her name and phone number and than left the room. 15. Jane Doe was then able to get dressed, leave the room and go back down the stairs and into the kitchen. Epstein, Robson and Kellen were waiting for Jane Doe. Epstein paid Jane Doe £300. Ms. Robson was paid $200 by Epstein for bringing Jane to him. Ms Robson brought Jane Doe home. 16. As a result of this encounter with Epstein. the I4-year old Jane Doe experienced confusion, shame, humiliation, embarrassment and the assault sent her life into a downward spiral. COUNT I Sexual Assault against Defendant Epstein 17. Plaintiff Jane Doe by and through her Mother, as parent and natural guardian, repeats and realleges paragraphs I through 16 above. :8. Defendant Epstein toniously assaulted Jane Doc sexually in or about 2005. 19. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane Doe. Page 4 of 9 This fax was received by GFI FAXmaker fax server. For more information. visit hap://www. glicorn 1650,316 EFTA00234388 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 66 of 100 From t win Page: 19/51 Date 5/29/2008 12 09 'M 20. As a direct Lnd proximate result of Epstein's assault on Jane Doc, she has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages. WHEREFORE, Plaintiff Jane Doc, by and through her Mother, as parent and natural guardian, demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim fur punitive damages pursuant to Florida Law. COUNT II Civil Conspiracy against Defendants Epstein, Robson and Kellen 21. Plaintiff Jane Doe by and through her Mother, as parent and natural guardian, repeats and realleges paragraphs I through 16 above. 22. Defendants Epstein, Robson and Kellen conspired to subject Jane Doe to the sexual assault of Defendant Epstein. 23. Each of the Defendants commined an overt act in pursuance of this conspiracy Defendant Ftobscin used false pretenses to lure Jane Doe to the home of Defendant Epstein so that Epstein could sexually assault Jane Doc; Defendant Kellen delivered Jane Doe to Defendant Epstein's bedroom so that Epstein could sexually assault Jane Doe, and Defendant Epstein actually committed sexual assault against Jane Doe. 24. As a direct and proximate result of Defendants' civil conspiracy, Jane Doe has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages Page 5 of 9 166 ot 315 This lax was received by GFI FAXmaker fax server For more information. 'Sit http://www gfi.com EFTA00234389 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 67 of 100 From V! AT Page 20/51 Date 5/29/200ti 12 09 A WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein, Haley Robson, and Sarah Kellen for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend tins Complaint to add it claim for punitive damages pursuant to Florida Law. COUNT HI Intentional infliction of Emotional Distress against Defendant Epstein 25. Plaintiffs Jane Doe by and through her Mother, as parent rind natural guardian, repeat and reallege paragraphs through 16 above 26. Epstein's conduct was intentional or reckless. 27. Epstein's conduct was outrageous, going beyond all bounds of decency. 28. Epstein's conduct caused severe emotional distress not only to lane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe and her mother. 29. As a direot and proximate result of Epstein's intentional or reckless conduct, Jane Doe will continue to suffer severe mental anguish and pain. WI-IEREFORE, :rine Doe, by and through her Mother, and Jane Doe's Mother, individually, demand judgment against Defendant Jeffrey Epstein for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law. ' Page 6 of 9 1670/316 This tax was received by CFI FAXmaker fax server. For more information, visit http.//www gfi corn EFTA00234390 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 68 of 100 rorn o, .wn Page 21/51 Date 5/29/2008 12 09. vt COUNT IV Civil Remedy for Violation of Florida Statute Section 772.103 against Defendants Epstein, Robson nod Kellen 30. Plaintiffs Jane Doe by and through her Mother, us parent and natural guardian, repeat and reallege paragraphs I through 16 above. 31. Defendants participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statute section 772.103(3)-(4). 32. Defendants engaged in this pattern of criminal activity by engaging in of least two of the following incidents of criminal activity with the same or similar intents, results, accomplices, victims, and methods of commission within a S year period: a. Procuring for prostitution, or causing to be prostituted, any person who is under the age of IS years in violation of Florida Statute section 796.03; b. Soliciting, inducing, enticing, or procuring another to commit prostitution, lewdness, or assignation in violation of Florida Statute section 796.07(2)(1), or aiding, abetting or participating in such acts in violation of Florida Statute section 796.07(2)(h); e. Knowingly recruiting, enticing, harboring, transporting, providing, or obtaining by' tiny means a person, knowing that force, fraud, or coercion will be used to cause that person to engage in prostitution in violation of Florida Statute section 796.04.5; or d. Forcing, compelling, or coercing another to become o prostitute in violation of Florida Statute section 796.04. 33. Under Defendants' plan, scheme and enterprise, Defendant Epstein paid Defendant Robson to repeated y find and bring him underage girls, who were delivered to Epstein by Page 7 of 9 16661316 This tax was received by GFI FAXmaker tax server For more information. visit, hap //v..ww gfi.com EFTA00234391 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 69 of 100 From u ran Page 22151 Date' 5/29/2008 12:09 M Defendants Robson and Kellen, in order for Epstein to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and/or lewdness. 34. PlaintiffJant Doe was the victim of Defendants' plan, scheme and enterprise. Defendant Robson took Jane Doc to Epstein's home under the pretense that Jane Doc would be paid to give Epstein a massage. Defendant Kellett delivered Jane Doe to a room with a message table and told WI Epstein would be in shortly. Jane Doe was alone in the room when Epstein arrived. Epstein told her to remove her clothes and left the room. When Epstein returned he was wearing only o towel. He removed his towel, and laid down on his stomach on the message table. Epstein again told Jane Doc remove her clothes. In shock, fear and trepidation, Jane One complied, removing her clottes except for her panties and bra. Shortly after stoning to rub Epstein's back, Epstein told Jane Doe to sit on his hack. Jane Doe, out of fear and trepidation, complied. After a period of time Epstein got up from the table and went behind the door. Inc several minutes Jane Doc heard loud noises and moans and believes that Epstein was masturbating. Thereafter Epstein, naked, returned to the message table and laid face tip on the table. Epstein than told Jane Doe to continue with the message and told her to sit on top of him. Out of fear and trepidation she complied As Jane rubbed Epstein's chest Epstein began to use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane Doe's vagina. Ai tits same time, with his other hand, Epstein was masturbating. Upon reaching orgasm Epstein gm up from the message table and told Jane Doe to write down her name and phone number and :han left the room 35. Jane Doe was then able to get dressed, leave the room and go back down the stairs and into the kitchen. Epstein, Robson and Kellen were waiting for Jane Doe. Epstein paid Jane Doc Page 8 of 9 16901316 This fax was received by GFI FAXmakor fax server For more information, visa hap/Nyww gfi corn EFTA00234392 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 70 of 100 From II ,wn Page 23/51 Date 5/29/2008 12 09 : $300. Ms. Robson was paid $200 by Epstein for bringing Jane to him. Ms. Robson brought Jane Doe home. WHEREFORE, Plaintiff Jane Doe, by arid through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein, Haley Robson, and Sarah Kellen for compensatory damages, treble damages under Florida Statute section 772.104, costs arid attorney's fees under Florida Statute section 772.104, and such other and further relief as this Court deems just 'and proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law. JURY TRIAL DEMAND Plaintiffs demand a jury trial in this action. Dated: March 6 2008 Respectfully submitted, RICCI—LE 2925 PGA Palm Bea Phone: 56 Fax: 5 Page 9 of 9 LEOPOLD 705608 170 ot 315 This fax was received by GFI FAXmakei fax server. For more information, visit http //www gli.com EFTA00234393 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07:21'2008 Page 71 of 100 171 of 316 EFTA00234394 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 72 of 100 From awn Page 2451 Date 5/29/2008 1209. [tQl Civil Cover Sheet Form 1.997 Civil Cover Sheet The civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by low. This form is requ:red for the use of the Clerk of the Court for the purpose of reporting judicial workload data pursuant 1C1 Florida Statute 25.075. 50 2008 CA U U 65 9 6 XXXX MB I. CASE STYLE CIRCUIT COURT JANE DOE, by and through JANE DOE'S MOTHER As parent and natural guardian, V. JEFFREY EPSTEIN, HALEY ROBSON end SARAH KELLEN, 2. TYPE' OF CASE: Torts:l Other Civil: Professional Malpractice Products Liability Auto Negligence V Other Negligence -Ir.. C.> 2( Contracts Condominium Real Property/Mortgage Foreclosure Eminent Domain Other 3 IS JURY TRIAL DEMANDED IN COMPLAINT? YES NO FT; 172 of 316 This fax was received by GFI FAXmaker fax server. For more information, visit httpavivw gfi.com EFTA00234395 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 73 of 100 From u. iwn Page 25/51 Date 5/29/200812:09:. M DATED THIS day of March, 2008. PICCI-LEOPOLD, P.A 2925 PGA Blvd. Suite 200 Palm Beac Phone: (5 Fax: ( 0 OR!: J POLD 'lorida Bar No. 05 08 173 of 315 This fax was received by GPI FAXmaker fax server. For more information, visit http.//www.gfi.com EFTA00234396 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07121'2008 Page 74 of 100 174 o1316 EFTA00234397 Case 9:08-cv-80804-KAM Document Eresse0acpapoc,,;(et 07/21/2008 Page 75 of 100 From u, wn IN THE CIRCUIT COURT OF THE • ISTII JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO: 50 2998 CA 006596 XXXX MB AB JANE DOE, by and through JANE DOE'S MOTHER, as parent and natural guardian, Plaintiff, VS. JEFFREY EPSTEIN, HALEY ROBSON and SARAH KELLEN, Defendants. SUMMONS PERSONAL SERVICE ON A NATURAL PERSON •1.O DEFENDANT; JEFFREY EPSTEIN 457 Madison Avenue 4th Floor New York, New York IMPORTANT • . • •••••-•.' A lawsuit has been filed against you. You have 20 calendar clays after this summons is served on you to file n written response to the attached complaint/petition with the Clerk of this Court. A phone call %ill not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. If you dc not file yotr response on time, you may lose the case, and your wages, money, and properly may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to cull an attorney right away. If you do not know an attorney, you muy call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/ Plaintiffs Attorney" named below. 17501716 This fax was received by GPI FAXmakei fax server. For more information, visit. http:JW/ww.gli corn EFTA00234398 Case 9:08-cv-80804-KAM Document 1-2 Erii9re9Thglgipocicet 07/21/2008 Page 76 of 100 from w wn Page 27/51 a e "In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 5 2500, West Palm Bench, FL 33401, telephone (561)355.2431, 1-800-955-R771 (IDD), or 1-800- 955-8770(V), via Florida Relay Service". THEODORE J. LEOPOLD, ESQUIRE RICO-LEOPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 (561) 684-6500 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE! You arc commanded yt serve is Sum ons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). DATED ON I MPORTANT By: Deputy Clerk SANDRA CU CIRCUIT COURT Usied ha side demanded° legalmente. Tiene 20 Dias, contados a pair del recibo du este notification, pan' contester la demanda adjunta, pr escrito, y presentarla ante esie tribunal. Una Ilamada telefonica no lo protegera. Si usted desea que el tribunal considere su defense, debt presentar su respuesui por escrito, incluyendo el numbero del caso y los nombres de las panes interesadas. Si usted no contesta la demanda a tiempo, pudiese perder cl ens° y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo oviso del u•ibunal. Existen otros requisitos legates. Si to desea, puede usted consulter a un abused° inmediatamente. Si DO conoce a un abogado, pucdc Ilamar a uno de las oficinas de asistencin legal que apace= en la gull telefonica. Page 2 of 3 175 of 315 This tax was received by GFI FAXmaket fax serve( For more information, visit http.//www gli corn EFTA00234399 Case 9:08-ov-80804-KA/ From. i Lb DoÇurer4 n g1-?8/51 En6wg2920Figg,Do4et 07/21/2008 Page 77 of 100 Si ,desen responder a la demand!' por su cutout, al mismo ticmpo en que presents su respuesta ante el tribunal, debera usted envier por correo o entregar una copia dc su respuesta a la persona denominada airejo tomo "Plaintiff/Plaintiffs Attorney" (Demandants o Abogado del Demandanie). "De acuerdo con el Acto b Decreto de los Americansos con Impedimentos, Inhabilitados, personas en necesidad del servicio special pare participar en estc procedimiento deberfui, dentio dc un 'lemon razonable, antes de cualquier procedinnento, ponerse en comacto con Is officina Administratativa du la Cone, 205 North Dixie Highway, oficina 5.2500, West Palm Beach, FL 33401, Téléfrino (561) 355-2431, 1.800-955-8771 (TOD) 4 1-800-955-8770 (V), Via Flonda Relay Service". IMPORTANT Des noursuites judiciures ona ets entreprises contre vous. Vous eve?, 20 jotes consecutifs o partir de la date de ('assignation de cane citation pour deposer tine reponse sents a In plaint< citioinie eupres de ce tribunal. Un simple coup de telephone est insuflisunt pour vous protegcr. Vous ems oblige de deposer votre reponse ecrite, avec mention du numero de dossier ci- dessus et du nom 'des panics nominees ici, si vous souhaitcz clue le tribunal entendc votis cause. Si vous ne dcposez pas votre reponse ecrite Bans Ic rclai requis, vous risquez de perdre la cause ainsi que volts salaire, votre argent, et vos biens peuvent etre saisis par In suite, sans aucun preavis ulicricur du tribunal. II y a d'autres obligations juridiques et vous pouvez requerir les services immediats d'un avoc.at. Si vous ne connaissez pas d'avocat, vous pourriez telephoner a un service de reference d'avocats ou a on bureau d'assistance juridique (figurant a I'annuaire de telephones). Si vous choisissez de deposer vous-mane tine reponse ecrite, it vous faudru cgalement, en meme temps clue cette fonnalite, faire parvenir ou expedier one copio de votre reponse ecrite au "Plainciff/Plainti ffs Attorney" (Plaignant ou a son avocet) nonune ci-dessous. En accordance avec la Loi des "Americans With Disabilities". Les personnes en besoin crone accommodation speciale pour paniciper a ces procedures dowerit, dens tin temps raisonable, avant à'enrreprendre &Kura :Wire démarche, contacter l'office administrative tic la Court Otte su 5.2500, 205 North Dixie Highway, West Palm Beach, FL 33401 le telephone (561)355- 2431 ou I -800-955-877 I (Tco) ou 1-800-955-8770 (V) Via Florida Relay Service. IMPORTANT D4pré aka ki let avek Americans With Disabilities Act, tout moan ki ginyin you bézwen éspésiyal pou akomodasiyon pou yo patisipé nan pwogram sera dwt, nan ylin rézonab avan ninpot aranjman kapab fet, yo dwe kontakte Administrative Office of the Court, Id nan niméro 205 Nonh Dixie Highway, Chain niméro 5.2500 West Palm Beach, Florida 33401 telefon nan se (561)355-2431 oubyen 1.800-955-8771 (T.D.D. oubycn 1-800-955-8770 (V) an pasan pa Florida Relay Service. Page 3 of 3 177 of 316 This fax was received by GFI FAXmaker fax server For more information, visit http.//www.gfi.corn EFTA00234400 Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 78 of 100 178 of 316 EFTA00234401 Case 9:08-cv-80804-Kttlm ,DozymecItag1e-3,/.51 Ergreekeffj4aDooket 07/21/2008 Page 79 of 100 IN TFIE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO: 50 2008 CA 006596 XXXX MB AB JANE DOE, by and through JANE DOE'S MOTHER, as parent and natural guardian, Plaintiff, vs. JEFFREY EPSTEIN, HALEY ROBSON and SARAH KELLEN, Defendants. SUMMON; PERSONAL SERVICE ON A NATURAL PERSON TO DEFENDANT: HALEY ROBSON 12247 72N0 COURT NORTH ROYAL PALM BEACH, FL IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court, A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. II you do not file your response on time, you may lose the ease, and your wages, money, and property may thereafter be taken without further warning from the Cowl. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an anompy referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the Chun you must also mail or take a copy of your wrinen response to the "Plaintiff/ Plaintiffs Attorney" named below. 170 of 316 This fax was received by GFI FAXmaker fax server For more information, visit he') &Amy gli.corn EFTA00234402 Case 9:08-cv-80804-KM1r, ,D096Ifneritaii2soist EntOigkilltaai2D0CITtet 07/21/2008 Page 80 100 "In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 5.2500, West PAM Bach, FL 33401, telephone (561)355.2431, 1-800.9554771 (TDD), or 1-800- 955-8770 (V), via Florida Relay Service". THEODORE J. LEOPOLD, ESQUIRE RJCCI-LEOPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 (561)684-6500 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and a copy of the complaint/petition in this lawsuit onik above named defendant(s). MR 1 8 au DATED ON , 2008. ° is I M PORTANTE LIg.led ha sido demandado legalmente. Tiene 20 Dias, contados a pertir del recibo de esta notificacion, ,pam contester le demanda adjunta, por escrito, y presentarla ante este tribunal. Una Hamada telefonica no lo protegera. Si usted desea que el tribunal considere su defense, debe presenter su respuesm par escrito, incluyendo et numbero del caso y los nombres de las panes interesadas. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria set clespojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen cams requisitos legates. Si lo desea, puede usted consultor a un abogado inmediatarnente. Si no conoce a un abogado, puede 'lamer a uno de las oficinas de asistencia legal que aparecen en la pia telefonica Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera usted envier por correo o entregar uno copia de su respuesta a la Page 2 or 3 -his tax was received by GP FAXmalter fax server. For more information, visit httpitwww.gfi corn 18601316 EFTA00234403 Case 9:08-ov-80804-KAK Lawnegiaji.g.115.1 EnWleoiskirDkaQi9DoOket 07/21/2008 Page 81 of 100 persona denomineda a