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efta-efta00801875DOJ Data Set 9Other-0929104.TXT
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efta-efta00801875
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-0929104.TXT
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 2006 CF09454AXX
STATE OF FLORIDA,
-vs-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
Pall,11,91,,11ouse
205 North Dixie Highway
West Palm Beach, Florida 33401
Reported By:
Judith F. Consor, FPR
Notary Public, State of Florida
Consor-Reporting
and Transcription
Phone
1
APPEARANCES:
2
On behalf of the State:
3
ESQ.
ATTORNEY
4
401 North Dixie Highway
ach, Florida 33401
5
6
On behalf of the Defendant:
7
MICHAEL R. TEIN, ESQ.
KATHRYN A. MEYERS, ESQ.
8
LEWIS TEIN, PL
3059 GRAND AVENUE, SUITE 340
Page 1
EFTA00801875
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9
COCONUT GROVE, FL 33133
10
On behalf of the Defendant:
11
JACK A. GOLDBERGER, ESQ.
ATTERBURY, GOLDBERGER & WEISS
12
250 AUSTRALIAN AVENUE SOUTH
SUITE 1400
13
ACH, FLORIDA 33401
14
15
ALSO PRESENT:
KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION,
16
LEGAL-EZE
17
18
19
20
21
22
23
24
25
1
INDEX
2
WITNESS:
3
I III IIMT
ION
4
BY MR. TEIN:
5
6
7
NO EXHIBITS
MARKED
8
9
10
11
12
13
Page 2
4
EFTA00801876
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14
15
16
17
18
19
20
21
22
23
24
25
4
1
Deposition taken before Judith F. Consor,
2 Court Reporter and Notary Public in and for the State of
3 Florida at Large, in the above cause.
4
5
Thereupon,
6
7
having been first duly sworn or affirmed, was examined
8
and testified as follows:
9
THE WITNESS: I do.
10
DIRECT EXAMINATION
11
BY MR. TEIN:
12
O.
Good afternoon. Please tell me your full
13
name.
14
A.
15
0.
And can you please spell it?
16
A.
Page 3
EFTA00801877
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18
O.
Thank you.
19
May I call you
20
A.
Uh-huh.
21
O.
, I'm going to ask you a few
22
questions, several questions today. If at any time you
23
want to take a break, you just let me know. Okay?
24
A.
Okay.
25
O.
If you at any time don't understand one of
1
my questions, will you just please let me know?
2
A.
Yes.
3
O.
And if at any time you're not feeling well
4
or something like that, you'll tell us, right?
5
A.
Yes.
6
O.
Do you feel okay today?
7
A.
Yes.
8
O.
Not taking any alcohol or drugs or anything
9
like that, right?
10
A.
No.
11
O.
So you feel ready to have your deposition
12
taken?
13
A.
Yes.
14
O.
what is your address?
15
A.
I'm currently living at
house and
16
I don't know it off the top of my head.
17
O.
Where is it?
18
A.
19
O.
Who is your aunt?
20
A.
21
O.
Who else is living there?
22
A.
age
EFTA00801878
-0929104.TXT
23
O.
Anyone else living there?
24
A.
No.
25
O.
1
says that you live with
3
and have been living there; is that
4
correct?
5
A.
Yes.
6
O.
How long have you been living with your
7
8
A.
Since
9
O.
That was Thanksgiving of this past year?
10
A.
Yes, sir.
11
O.
Okay. Didn't did your
get an apartment for the two of
13
you?
14
A.
No, sir. He has an apartment, but by
15
himself.
16
O.
Did he get an apartment for the two of you
17
to live in?
18
A.
No, sir.
19
O.
Are you planning to move in with him?
20
A.
Maybe one day in the future.
21
O.
Do you have a plan to move in with him
22
presently?
23
A.
No.
24
O.
Have you been to the apartment that you and
25
have discussed moving in together?
Page 5
EFTA00801879
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7
1
A.
I have been to the apartment.
2
O.
Where is that?
3
A.
4
O.
Have you spent the night over there?
5
A.
No, sir.
6
O.
Do you know the address there?
7
A.
I do not.
8
O.
Isn't
planning on living
9
with you
10
A.
No.
11
O.
, you know that this court case is a
12
criminal prosecution, correct?
13
A.
Correct.
14
O.
And you know that it's a criminal
15
prosecution against a man who has no criminal background.
16
Do you know that?
17
A.
I do now.
18
O.
You agree that court is a very serious
19
matter?
20
A.
Yes.
21
O.
And you're here with your lawyer
22
right?
23
A.
Yes.
24
O.
And you know that
recently
25
8
1
2
: Let me just object.
3
, let me instruct you. Anything that
4
you have learned through conversations between you
Page 6
EFTA00801880
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5
and me are protected. So if you know any of that
6
information outside of those discussions, you may
7
answer. But if the only way you know it is
8
through our discussions, do not answer that
9
question.
10
BY MR. TEIN:
11
O.
, you know that
recently
12
14
: Same objection.
15
If you know the answer to that outside of
16
our discussions, you may answer. If it is the
17
only way that you know the answer is through our
18
discussions, do not answer that question.
19
THE WITNESS: Okay.
20
: Attorney/client privilege.
21
BY MR. TEIN:
22
O.
You can answer the question unless --
23
: Same objection.
24
MR. TEIN: Let me finish.
25
: Excuse me. We're --
1
MR. TEIN: No. Let me finish.
2
: Lewis, we're not going to do
3
that.
4
MR. TEIN: My name is not Lewis.
5
I'm going to finish my question. Okay?
6
: Do not answer until you hear
7
from me.
8
BY MR. TEIN:
Page 7
EFTA00801881
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9
O.
Other than conversations that you have had
10
with
-- I'm not asking about that -- are you
11
aware that
14
: Same objection.
15
Anything that you learn through
16
conversations between you and me, do not answer.
17
Those are protected. If you know through any
18
other realm of knowledge, you may answer.
19
THE WITNESS: No.
20
BY MR. TEIN:
21
O.
You have no idea that
24
25
: Same objection.
Do not answer that question if it's through
10
1
discussions that you and I had. Outside of that,
2
you may answer. So do not answer that question if
3
that is the only basis by which you understand
4
that answer.
5
THE WITNESS: No.
6
BY MR. TEIN:
7
O.
You didn't know that?
8
: Don't answer that question.
9
Against, it's attorney/client privilege. Any
10
information you've learned through conversations
11
between you and I are protected. If you know it
12
through any other realm, you may answer.
13
MR. TEIN: Are you going to say that for
Page 8
EFTA00801882
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14
every question in the deposition,
7
15
: When you ask improper
16
questions like that without the proper --
17
MR. TEIN: You're going to stop your
18
speaking objections right now. Okay?
19
: Without the proper
20
MR. TEIN: You need to stop your speaking
21
objections.
22
Let's continue.
23
: Counsel, you just asked me a
24
question and I'm going to state it on the
25
record --
11
1
MR. TEIN: You need to stop your speaking
2
objections. Check your rules.
3
: Excuse me. For the record,
4
Counsel asked me a question. I'll state the
5
answer on the record. He asked me the question am
6
I going to be answering that way throughout the
7
deposition. So long as there's improper
8
foundation and predicate asked by the attorney, I
9
will protect my client and I make the record where
10
appropriate. If counsel wishes to ask an
11
appropriate worded question with the proper
12
foundation and predicate, I will certainly allow
13
the client to answer the question.
14
MR. GOLDBERGER: Why don't you just state
15
attorney/client privilege and just be done with
16
it.
17
:
I want the record to be
Page 9
EFTA00801883
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18
clear.
19
MR. TEIN: You want to waste time is what
20
you want to do. You were supposed to be here this
21
morning and you totally broke the deal, the
22
agreement that you had with us if your hearing got
23
cancelled.
24
But let's move on and maybe you'll stop
25
obstructing this deposition.
12
1
:
I think the record is very
2
clear where we stand thus far.
3
Is there a recording taken of this
4
deposition?
5
THE COURT REPORTER: Yes.
6
: Just make sure that's
7
preserved.
8
BY MR. TEIN:
9
O.
Go to Exhibit
-- well, before you do
10
that,
, are you aware that
9
12
: Objection.
13
Any conversations that you and I have had
14
regarding that, if that is the only way by which
15
you understand how to answer that question, so not
16
answer. It's attorney/client privilege, as well
17
as any conversations you may have had with the
18
attorney
That is also attorney/client
19
privilege. And I'm assuming --
20
MR. TEIN: You're actually wrong about the
21
attorney/client privilege.
22
: I'm assuming Counsel is not
Page 10
EFTA00801884
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23
asking you to divulge attorney/client
24
MR. TEIN: Of course not.
25
BY MR. TEIN:
13
1
O.
, are you aware that
4
: Same objection.
5
MR. TEIN: We've heard the objection 10
6
times already.
7
: Counsel, excuse me.
8
MR. TEIN: Just say attorney/client
9
privilege. Stop interrupting my questions.
10
: I'm entitled to make an
11
objection for the record, which I'm doing, and
12
I'll make the same objection. And if it calls for
13
attorney/client privilege, any conversations you
14
and I have had, do not answer the question.
15
And I think that it might be appropriate
16
for the record to ask questions via Ms.
17
as opposed to
.
I think that would be more
18
appropriate for this deposition.
19
BY MR. TEIN:
20
O.
Go ahead. Please answer yes or no.
21
A.
Yes.
22
O.
Thank you.
23
In fact, you know that
, don't you?
Page 11
EFTA00801885
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14
1
A.
After it happened.
2
O.
You know that
3 don't you, yes or no?
4
A.
Yes.
5
O.
In fact, let's go to Exhibit
6
MR. GOLDBERGER: Look behind you. You'll
7
see it.
8
BY MR. TEIN:
9
O.
Have you ever seen that picture before?
10
A.
Yes.
11
O.
Is that a picture of
14
A.
Yes.
15
O.
Now you know that this is a very serious
16
matter, don't you?
17
: Asked and answered.
18
Objection.
19
MR. GOLDBERGER: All right. You can
20
object. You're representing a witness here,
21
. You can object on privilege grounds.
22
You cannot make legal objections. You have no
23
standing to do so.
24
: I'm going to make them and
25
then --
15
1
MR. GOLDBERGER: We're --
2
: We're going to leave or we're
3
going to take a break because his demeanor is not
4
appropriate. There's no reason to have this kind
Page 12
EFTA00801886
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5
of demeanor. If you want to have this kind of
6
demeanor with me
7
MR. TEIN: You are obstructing this
8
deposition.
9
MR. GOLDBERGER: Why don't you guys go
10
outside and just talk about --
11
: She -- her job is very
12
difficult and she's not going to be able to take
13
us both talking at he same time.
14
MR. GOLDBERGER: Off the record.
15
: We're not going off the
16
record, Jack. We're not, Jack. Her job is very
17
difficult. I'm going to make the record.
18
I don't think it is appropriate, especially
19
in the small confines of this room, to be very
20
aggressive with this young lady.
21
MR. TEIN: That's not happening. Stop,
22
stop actually --
23
: If you're going to interrupt
24
me, we're going to cancel this deposition
25
MR. TEIN: Stop misrepresenting.
16
1
THE COURT REPORTER:
I need on at a time,
2
no matter who it is.
3
:
I think we're going to take a
4
break. Perhaps you might want to talk to your
5
co-counsel --
6
MR. TEIN: I don't need to talk to him.
7
: But we're going to take a
8
break.
Page 13
EFTA00801887
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9
MR. TEIN: Not taking a break unless the
10
witness needs a break.
11
You're obstructing this deposition, III.
12
: Come on,
13
You all want to continue in this
14
demeanor --
15
MR. TEIN: You're obstructing the
16
deposition. Stop making speeches. We're not
17
discussing this with you. The questions are to
18
your client. Go take your five-minute break.
19
: Fine. We need to make sure
20
the record's clear and clean.
21
And I want to make sure as I've already
22
asked you -- I know that you're one of the best in
23
town -- that this audio -- this needs to be
24
preserved. Okay?
25
MR. TEIN: Go take your five-minute break,
17
1
, now.
2
You were supposed to be here at nine a.m.;
3
it's now after two. Take your break and come
4
back.
5
: Okay. If the demeanor keeps
6
up, we will not be here beyond those five minutes.
7
MR. TEIN: Take your break and come back.
8
: Okay. So I suggest that you
9
relax.
10
MR. TEIN: I suggest that you take your
11
break.
12
MR. GOLDBERGER: Let them take that
13
five-minute break.
Page 14
EFTA00801888
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14
: But I would suggest that you
15
take deep breaths.
16
MR. TEIN: Suggest whatever you want. Go
17
take a break.
18
(Thereupon, a recess was taken.)
19
BY MR. TEIN:
20
O.
you agree that giving testimony
21
today at your deposition is something very serious, don't
22
you?
23
A.
Yes.
24
O.
And you respect the court, don't you?
25
A.
Yes.
18
1
O.
Let me show you Exhibit
. Can you
2
read that out loud, please?
3
A.
Okay. What do you want?
4
O.
Will you read that out loud, please.
5
A.
Oh.
6
O.
Thank you.
7
A.
Lol hah my baddd...lol yah i got some
8
stupid court shit
...bullshit...and damn you
9
still have court shit with him? Like after so long wow
10
im sorry... well yah well we will definitely havta make
11
plans for sure..because i miss u tons times a million and
12
no no no i love you...o p.s. i love ur default pic
13
niggaa. Muah xo.
14
O.
Did you send that message last week to a
15
friend of yours on MySpace?
16
A.
I wouldn't know. There's no dates and I've
17
deleted that MySpace, so --
Page 15
EFTA00801889
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18
O.
We're going to talk about that in a second.
19
A.
Okay.
20
O.
Did you send that message last week
21
A.
Right.
22
O.
Let me finish my question.
23
Did you send that message last week to a
24
friend of yours on MySpace?
25
A.
I wouldn't know the date, but obviously,
19
1
it's to a friend.
2
O.
Did you send that message to a friend of
3
yours on MySpace?
4
A.
Sure, yes.
5
O.
Were you referring to this deposition?
6
A.
Yes.
7
O.
Do you find the term n-i-g-g-e-r offensive?
8
A.
That's not anywhere in there.
9
O.
What word did you use in there?
10
: Where are you referring to,
11
Counsel? There's 20 plus words in there.
12
MR. TEIN: Don't make a speaking objection.
13
THE WITNESS: Are you referring to
14
anything --
15
: No,
. Don't -- don't --
16
let him ask you the question.
17
BY MR. TEIN:
18
O.
What question were you asking,
7
19
: She doesn't ask questions.
20
You ask the questions. What is the question
21
pending?
22
BY MR. TEIN:
Page 16
EFTA00801890
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23
O.
, what is the last word on there in
24
the text of your message before the closing?
25
A.
Niggaa.
20
1
O.
Don't you find that term offensive?
2
A.
No.
3
: Can you spell it for the
4
record, please.
5
THE WITNESS: N-i-g-g --
6
MR. TEIN: No, no, no. You are not going
7
to be asking questions.
8
: I'm not asking questions.
9
I'm asking for the record the word to be spelled
10
because we don't have a video here today.
11
MR. TEIN: These exhibits are part of the
12
record. You --
13
: Well, it's not marked as an
14
exhibit.
15
MR. TEIN: Stop interrupting me,
16
.
I have marked and identified as an
17
exhibit and you will get it.
18
: There has been no
19
identification of this document in the record.
20
MR. TEIN:
, stop interrupting
21
this deposition.
22
: What is the exhibit number
23
marked for identification?
24
MR. TEIN:
25
: Do we have copies? Is it on
Page 17
EFTA00801891
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21
1
the record anywhere?
2
BY MR. TEIN:
3
O.
Let me ask you,
, did you in fact
4
write your friend this message about this deposition?
5
A.
Yes.
6
O.
So you wrote your friend that this
7 deposition is stupid court s-h-i-t, correct?
8
A.
Yes.
9
O.
Because you think this deposition is stupid
10
court s-h-i-t, don't you?
11
A.
No.
12
O.
You wrote that to your friend, didn't you?
13
A.
Yes.
14
O.
You think that court is stupid, don't you?
15
A.
In some cases.
16
O.
And you think that court is bull s-h-i-t,
17
don't you?
18
A.
No.
19
O.
And you think this deposition is bull
20
s-h-i-t, don't you?
21
A.
No.
22
O.
You wrote that to your friend, didn't you?
23
: Objection. Asked and
24
answered.
25
MR. TEIN: That's not an objection.
22
1
BY MR. TEIN:
2
O.
You wrote that to your friend, didn't you?
3
: Objection. Asked and
4
answered, for the fourth time.
Page 18
EFTA00801892
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5
MR. TEIN: You are improperly objecting,
6
. You have no grounds to object. And
7
that's not an objection.
8
: It is an objection.
9
MR. TEIN: Then terminate the deposition if
10
you think it's been asked and answered.
11
: Counsel, I am not precluded
12
from just making an objection to the form of the
13
question. As the courts well know, and if you
14
practice here in West Palm Beach, many of the
15
judges require you to set the objection with
16
specificity. And I will do that. And if you
17
don't want me to, you can make the record. But
18
will do that.
19
MR. TEIN: Here's what we'll do, III. You
20
can -- I will allow you to reserve an objection to
21
form for every single one of my questions.
22
Otherwise, all you're doing is obstructing.
23
:
I won't do that.
24
MR. TEIN: Of course; because you want to
25
obstruct.
23
1
: All right.
2
BY MR. TEIN:
3
O.
, you think that giving testimony
4
today, under oath, is bull s-h-i-t, don't you?
5
A.
No.
6
O.
And you wrote that to your friend on
7
MySpace last week, didn't you?
8
: Objection. Asked and
Page 19
EFTA00801893
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9
answered.
10
THE WITNESS: No, I did not.
11
BY MR. TEIN:
12
O.
You didn't write this exhibit?
13
A.
I wrote that, but I didn't write what you
14
said.
15
O.
You wrote in this exhibit, "I got some
16
stupid court s-h-i-t
Bull s-h-i-t." Didn't
17
you write that?
18
A.
Yes.
19
O.
Referring to this deposition, didn't you?
20
A.
Referring to the court.
I was later
21
informed that it was a deposition.
22
O.
I'm going to ask you some questions now
23
about what happened when you went to Jeff Epstein's house
24
years ago. Okay?
25
A.
Uh-huh.
24
1
O.
2 after you went to Epstein's house, you swore on your
3
4 of any kind?
5
A.
Yes.
6
O.
Didn't you tell that to the police?
7
A.
Yes. And I will continue.
I have never
8
had sex with him.
9
O.
Did what happened upstairs at Jeff
When the police interviewed you
mother's grave that you and Epstein did not engage in sex
10
11
A.
Yes.
12
O.
Now the
Epstein's house take you completely by surprise,
Page 20
EFTA00801894
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14
16
A.
Yes.
17
0.
Were you totally shocked by what happened
18
when you got to Epstein's house?
19
A.
Yes.
20
0.
You didn't expect it at all, did you?
21
A.
No.
22
0.
23
was taking you to Epstein's shoes, right?
24
A.
I was informed it was a massage.
25
Q.
You had absolutely no idea why your friend
1
2
A.
Yes.
3
0.
4
5
6
A.
No.
7
0.
8
9
10
A.
No.
11
0.
Did
12
engage
13
A.
No.
14
0.
Did
15
you to engage
16
A.
17
0.
All you thought that it was going to be was
25
a massage, correct?
Before you got to Epstein's house
never said anything to you on the telephone about sexual
activity with Epstein, did he?
And before you got to Epstein's house
never sent you a message over the Internet about
sexual activity with Epstein, did she?
ever try to convince you to
in any sexual activity with Epstein?
every try to convince
in any sexual activity with Epstein?
I don't know who
Do you have a friend
Page 21
is.
EFTA00801895
-0929104.TXT
18
A.
No.
19
O.
Okay.
20
21
22
A.
No.
23
O.
24
25
Before you went so Epstein's house
did anyone call or e-mail you to induce you to engage in
sexual activity with Epstein?
So you're sure that before you got to
Epstein's house no one tried to persuade you to engage in
sexual activity with
Epstein?
26
1
A.
No.
2
O.
You're sure that -- let me ask the question
3 again.
4
You're sure that before you got to
5
6 sexual activity with Epstein for money. Are you?
7
: Objection. Asked and
8
answered.
9
THE WITNESS: No. And I've already
10
answered that a bazillion times.
11
BY MR. TEIN:
12
O.
He's coaching you now. So I'm going to ask
13
the question
14
: Counsel, I've made an
15
objection for the record.
16
MR. TEIN: Stop speaking.
17
: I'm not going to stop
18
speaking. You can't interrupt me when I'm making
19
the record.
20
MR. TEIN: You're coaching the witness.
21
: Counsel --
22
MR. TEIN: Stop coaching the witness.
Page 22
Epstein's house no one tried to persuade you to engage in
EFTA00801896
-0929104.TXT
23
BY MR. TEIN:
24
O.
, let me ask you --
25
: If you continue to --
27
1
MR. TEIN: Stop interrupting my questions.
2
: If you do it one more time,
3
we're leaving.
4
BY MR. TEIN:
5
O.
6
: I'm going to make the record.
7
You cannot interrupt me when I'm making the
8
record. Out of professional conduct, you cannot
9
do that. I'm entitled to make the record.
I made
10
an objection, asked and answered. You demeanor is
11
inappropriate. You're willing and you are able
12
and you're responsible to ask a question in a
13
professional manner and ask the question and once
14
you get the answer, to either follow up on it or
15
move on, but not continuously browbeat and ask the
16
same question over and over because you don't like
17
the answer.
18
MR. TEIN: Calm down, sir.
19
: Trust me, I'm very calm here.
20
When I'm not calm you'll know it. I'm very calm.
21
So please continue on, but I will not allow
22
you to continue to harass her in the demeanor that
23
you're doing. Ask her a question and move on.
24
MR. TEIN: Are you done?
25
: Thank you.
I am.
Page 23
EFTA00801897
-0929104.TXT
28
1
MR. TEIN: Stop misrepresenting the record
2
and calm down. I'm going to ask my question.
3
Stop it.
4
BY MR. TEIN:
5
O.
6
:
I think the record is very
7
clear.
8
MR. GOLDBERGER: Let me just clarify
9
something. When you object to the form of a
10
question, you're not instructing the witness not
11
to answer the question, are you?
12
: No. And I'm not making that
13
objection; only on attorney/client privilege.
14
MR. TEIN: Will you stop speaking now so I
15
can ask my question? Are you done?
16
Okay. I'm going to ask my question.
17
BY MR. TEIN:
18
O.
Listen,
19
: Hold on. Stop.
20
I've been doing this for 20 plus years and
21
have met a lot of attorneys, but I've never had an
22
experience like this where I've --
23
MR. TEIN: Stop your speeches.
24
: If you continue to do this,
25
whether it's with me or with my client, I will not
29
1
put up with it and I don't need to put up with it
2
and it's not appropriate. And I'm sure Mr.
3
Goldberger knows all this, because I know that he
4
wouldn't do this. So I will not put up with it.
Page 24
EFTA00801898
-0929104.TXT
5
And I think it's highly inappropriate to do this
6
with this child sitting here, the way you're
7
acting, primarily towards me, and I will not put
8
up with it.
9
MR. TEIN: Will you please stop your speech
10
so I can ask questions?
11
: So long as you act
12
professionally, I will do so. But if you continue
13
to do it this way, I will leave.
14
MR. TEIN: Suit yourself.
15
BY MR. TEIN:
16
O.
, are you sure that before you got to
17
Epstein's house no one tried to persuade you to engage in
18
sexual activity with Epstein for money?
19
: Asked and answered.
20
Objection.
21
MR. TEIN: Did you get her answer?
22
THE COURT REPORTER: No, I did not.
23
THE WITNESS: I'm sure.
24
BY MR. TEIN:
25
O.
Let me ask you a few questions about your
1
contact with
Epstein. Okay?
2
A.
3
O.
4
A.
No.
5
O.
6
A.
No.
7
O.
8
did he?
(Witness nods head up and down.)
Jeff never e-mailed you, did he?
Jeff never text messaged you, did he?
30
Jeff never chatted in a chat room with you,
Page 25
EFTA00801899
-0929104.TXT
9
A.
No.
10
O.
11
12
A.
No.
13
O.
14
had never met Jeff?
15
A.
Correct.
16
O.
17
18
A.
No.
19
O.
20
21
A.
22
O.
23
24
A.
Yes.
25
O.
Before you got to Epstein's house you had
never spoken to Jeff, had you?
And before you got to Epstein's house you
Before you got to Epstein's house you had
never told Jeff that you were under 18, right?
Before you got to Epstein's house had you
ever told
that you were under 18?
No, I never spoke to the man before that.
And you only went to Jeff Epstein's house
that one time
years ago, correct?
You never went there again, correct?
1
A.
No.
2
O.
All right. Let me ask you two final areas
3 of questioning about this and we'll move onto something
4
else. Okay?
5
A.
Uh-huh. Yes. I'm sorry.
6
O.
Before you got to Epstein's did anyone
7
associated with Epstein ever call you on the phone and
8 try to persuade, induce, entice or coerce you to engage
9
in any sexual activity?
10
A.
No.
11
O.
Before you got to Epstein's did anybody
12
13
31
associated with Epstein ever contact you on the Internet
and try to persuade, induce, entice or coerce you to
Page 26
EFTA00801900
-0929104.TXT
14
15
16
O.
17
18
age?
19
A.
20
O.
21
the car who
22
A.
23
O.
24
that day?
25
A.
engage in any sexual activity?
A.
No.
, who told you that when you got to
Jeff Epstein's house you should lie to Jeff about your
Was it
or was it the other girl in
you rode over with to Epstein's house?
Who was the other girl in the car with you
I honestly don't know.
32
1
O.
Had you ever seen her before?
2
A.
No, sir.
3
O.
You told the police that when you rode over
4
to Epstein's you had no idea who she was, right?
5
A.
Correct.
6
O.
You told the police that you didn't know
7
her name, but she was
9
9
A.
Yes.
10
O.
Those were your words, right?
11
A.
Yes.
12
O.
Do you now know who she is?
13
A.
No, sir.
14
O.
So it was
who told you to lie about
15
your age to Jeff Epstein?
16
A.
Yes, sir.
17
O.
And
told you that if you weren't 18,
Page 27
EFTA00801901
-0929104.TXT
18
19
A.
That's -- yes, yes.
20
O.
All right. Let's talk for a minute about
21
when you first met Jeff. Okay?
22
A.
Sure.
23
O.
When you first met Jeff he tried to find
Epstein wouldn't let you into his house, right?
24
out how old you were, right?
25
A.
Excuse me?
33
1
O.
When you first met Jeff he tried to find
2 out how old you were, right?
3
A.
Not when we first introduced each other;
4
when we get upstairs, then yes.
5
O.
During the massage Jeff asked you how old
6
you were, correct?
7
A.
Yes, yes.
8
O.
Now hadn't you already told Jeff's
9
assistant, the one who walked you upstairs, that you went
10
to college and had just moved down here
7
11
A.
I never spoke to the lady.
12
O.
Do you want to rethink that answer?
13
: Is that a question?
14
BY MR. TEIN:
15
O.
Do you want to rethink that answer?
16
A.
No.
I didn't really speak with her that
17
much.
18
O.
Do you want to try to refresh your memory
19
on that?
20
: Do you have something to
21
refresh her memory with?
22
MR. TEIN: Do you want to stop making
Page 28
EFTA00801902
-0929104.TXT
23
speaking objections?
24
: No. But to refresh someone's
25
memory you show them a document.
34
1
MR. TEIN: I know how to do this.
2
: Then show her a document.
3
MR. TEIN: Stop speaking.
4
: I'm not going to stop
5
speaking. I'm going to continue to make the
6
record.
7
MR. TEIN: You're obstructing. Please
8
stop.
9
: I'm not obstructing. But if
10
you want to refresh her recollection, you need to
11
show her something.
12
That's not a proper question.
I object to
13
the foundation and the predicate of that question.
14
MR. TEIN: Are you done?
15
:
I am now. Thank you.
16
BY MR. TEIN:
17
O.
Do you want to try to refresh your memory
18
as to whether you had any conversation with the woman who
19
walked you upstairs in Epstein's house in which you told
20
her that you went to college and had just moved down
21
22
: Objection. Object to the
23
form of the question. Lack of foundation and
24
predicate.
25
BY MR. TEIN:
Page 29
EFTA00801903
-0929104.TXT
35
1
O.
You can answer the question.
2
A.
Sure.
3
O.
Is there anything that would refresh your
4
memory that in fact you told Mr. Epstein's assistant, the
5
one who walked you upstairs, that you went to college and
6
you had just moved down here
7
7
A.
I don't remember saying that, but if you --
8
I don't remember saying that myself, so --
9
O.
That would be a lie, right?
10
A.
No.
I really don't remember.
11
O.
So you told Jeff that you were 18 years
12
old, correct?
13
A.
Yes.
14
O.
Do you remember
of
15
the Police Department, Palm Beach Police Department,
16
A.
Yes.
17
O.
Do you remember you spoke to her?
18
A.
Yes.
19
O.
Do you remember that you told Detective
20
that when you lied about your age to Jeff
9
23
A.
24
25
O.
And do you remember telling
I don't remember the words exactly, but I
do remember telling her I told him I was 18.
36
1
that when you lied to Epstein about your age that-
4
A.
No, I don't remember saying those words
Page 30
EFTA00801904
-0929104.TXT
5
6
7
8
exactly to her. I remember telling her that I told
Epstein I was 18.
O.
Does it sound right to you that you told
10
MS.
11
answered.
12
BY MR. TEIN:
13
O.
--
Objection. Asked and
15
: Objection. Asked and
16
answered, lack of foundation, mischaracterization
17
of her earlier testimony. She's already answered
18
that question.
19
BY MR. TEIN:
20
O.
You can answer it.
21
: Same objection. It's been
22
asked and answered.
23
You can answer. I've made the objection.
24
THE WITNESS: I forget the question, now.
25
1
BY MR. TEIN:
2
O.
Let me put it again.
3
4
5
Does it sound right to you that you told
that when you lied about your age to
Epstein,
7
8
: Objection. Lack of
foundation, asked and answered.
Page 31
37
EFTA00801905
-0929104.TXT
9
THE WITNESS:
10
that, yes.
11
BY MR. TEIN:
12
O.
13
14
A.
Correct.
15
O.
16
17
A.
Correct.
18
O.
19
really were 18, right?
20
A.
Correct.
21
O.
22
where you went to school?
23
A.
Yes.
24
O.
25
, right?
I could have possibly said
You didn't want Mr. Epstein to know that
you were lying about your age, right?
You didn't want Mr. Epstein to know that
you were not 18 yet, right?
You wanted Mr. Epstein to believe that you
Do you remember when Mr. Epstein asked
And you told Mr. Epstein you went to
1
A.
Yes.
2
O.
Was that the truth?
3
A.
No.
4
O.
In fact, you went to
, right?
5
A.
Yes.
6
O.
7
A.
Yes.
8
O.
Is
the college that you told
9
Jeff's assistant that you were attending?
10
A.
I don't remember having that conversation
11
with her, so I wouldn't know if that's what I said.
12
O.
That was a lie, though, wasn't it?
13
: Objection to the form of the
Page 32
38
So you lied to Mr. Epstein again, correct?
EFTA00801906
-0929104.TXT
14
question, lack of foundation. You're making an
15
assumption. She just answered you she can't tell
16
you that.
17
MR. TEIN: Speaking objection. And you
18
well know that,
19
: She can't answer that
20
question. The way you phrased that question,
21
you're purposely making her not be honest in her
22
testimony. She can't answer a question like that.
23
She doesn't remember. So then you say, "So you
24
were lying." That's improper and you know that.
25
That's not a proper question. And any attorney
39
1
that would do that to a witnesses or to a person
2
that's sitting in this chair is not acting
3
professionally. You can't ask a question like
4
that. You can do it, but it's not proper. And
5
I'm sure you weren't trained that way, certainly
6
not ethically.
7
MR. TEIN: Will you stop?
8
: I'm not going to stop,
9
because the way you're asking that question is
10
improper and you know it.
11
MR. TEIN: You're losing your cool.
12
BY MR. TEIN:
13
O.
Ms.
14
: Trust me. I'm very calm.
15
When I lose my cool, you'll know it.
16
MR. TEIN: I do know it.
17
BY MR. TEIN:
Page 33
EFTA00801907
mmmmmaia29104.TXT
18
Q.
Ms. 11111111, Mr. Epstein never asked you
19
to do anything other than massage him, correct?
20
A.
21
22
Q.
23
Incorrect; because he asked me to take off
my bra, so that would be two things he's asked me to do.
Other than asking you to take your bra off,
Mr. Epstein never asked you to do anything with him other
24
than massage, correct?
25
: Objection. Foundation,
1
2
3
BY MR. TEIN:
4
Q.
5
you did not
6
7
O.
8
A.
9
Q.
10
11
Q.
12
13
14
Q.
15
16
17
Q.
18
19
20
Q.
21
22
40
predicate.
THE WITNESS: Correct.
You told the police, in your words, that
A.
Correct.
, right?
What does that mean?
2
Your term, what does that mean?
A.
Masturbating.
Mr. Epstein never tried at any time to grab
your hand, did he?
A.
No.
Mr. Epstein never tried to put your hand
anywhere, did he?
A.
No.
At no time did you touch Mr. Epstein's
penis, did you?
A.
No.
And he did not touch you, correct?
A.
Incorrect.
O.
Well, you told the police,
Page 34
EFTA00801908
-0929104.TXT
23
Were you lying to the police then?
24
A.
No. Well, I wasn't being fully truthful,
25
but I wasn't lying.
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
41
O.
You told the police twice when you spoke to
that
Didn't
you say that to the police?
A.
Yeah.
O.
And you're saying that that was not fully
truthful. Is that what you're saying now?
A.
Correct.
O.
And you're saying if you're not fully
truthful, that's not a lie. Correct?
bad.
A.
You took that out of context like really
I didn't mean like that. Touching my legs and --
he never kept his hands to himself the entire time.
That's what I'm trying to say.
O.
You told the police,
You agree with that, correct?
A.
No, I don't agree with that, because he did
touch me.
O.
Did you tell the police that he did not
touch you, yes or no?
A.
It's a possibility, but I do not remember.
O.
Okay.
with Jeff, correct?
A.
No.
Q.
And you did not have any type of sex
And you did not have any type of oral sex
with Jeff, correct?
Page 35
EFTA00801909
-0929104.TXT
42
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
A.
No.
0.
No type of intercourse with Jeff, correct?
A.
Correct.
O.
All right. Let's talk about what happened
after the massage was over.
A.
Okay.
O.
After the massage you told Epstein that you
wanted to bring
back so she could make
some money, correct?
A.
Incorrect.
O.
, right?
A.
Correct.
O.
And you love
very much, don't you?
A.
Yes.
O.
And when you left the house you were joking
with the other girls, weren't you?
A.
Incorrect.
O.
Well, when
and the other girl in the
car that day made their statements to the police they
told the police that you were joking afterwards. Are you
saying that they were lying to the police about that?
A.
No. But a question or -- questions from
-- like she asked me questions, but it wasn't
joking. She was kind of like in a happy way, like, "Oh,
what did you do? What did you do?" Like those kind of
43
1
things, but it wasn't joking about it at all.
2
O.
You joked about it, didn't you?
3
A.
No.
4
O.
You said to
that if you did this
age
EFTA00801910
-0929104.TXT
5
every weekend you'd be rich, didn't you?
6
A.
No. That's what
told me.
7
O.
You didn't tell that to
8
: Objection. Asked and
9
answered.
10
THE WITNESS: No.
11
BY MR. TEIN:
12
O.
13
money and you went shopping with
and the other
14
girl in the car, correct?
15
A.
Incorrect.
I didn't spend any of the
16
money.
17
O.
You went to
, didn't you?
18
A.
I went along, yes, but I didn't --
19
O.
You went shopping with them at
20
didn't you?
21
: Objection.
22
THE WITNESS: I guess you could say that.
23
: Objection. Lack of predicate
24
and foundation. Mischaracterization of earlier
25
testimony.
After you left Epstein's house you took the
44
1
BY MR. TEIN:
2
O.
And
bought a purse, right?
3
A.
Yes.
4
O.
And you were with her the whole time at
5
, correct?
6
A.
Yes.
7
O.
Now tell me about when the federal
8
prosecutors told you about getting reimbursed.
Page 37
EFTA00801911
-0929104.TXT
9
A.
I have no idea what you're talking about.
10
O.
Tell me about when the federal prosecutors
11
spoke to you about getting money you feel you're entitled
12
to from Mr. Epstein.
13
A.
I don't know what you're talking about.
14
O.
Do you know who
is?
15
A.
No, sir.
16
O.
Did you ever meet with any federal
17
prosecutors?
18
A.
I think -- yeah.
I think they were --
19
think they were like FBI.
20
O.
Uh-huh. Did you meet with federal
21
prosecutors?
22
A.
They came to my house one time, yes.
23
O.
When did they come to your house?
24
A.
Very long ago.
25
O.
Was it this year, 2008?
45
1
A.
It was not this year, no.
2
O.
Was it
3
A.
I'd have to say at least
or a
4
year ago, yeah. So it would be
; but it was a
5
while ago.
6
O.
How many federal prosecutors or FBI agents
7 came to your house?
8
A.
I'm trying to remember.
I want to say four
9
people came.
10
O.
Did they give you their business cards?
11
A.
If they did, I don't remember, and they
12
weren't toward me. Maybe my parents have them.
I don't
13
know.
Page 38
EFTA00801912
-0929104.TXT
14
O.
Did they give you their cell phone numbers?
15
A.
No.
16
O.
Did you ever speak to them on their cell
17
phones?
18
A.
No, sir.
19
O.
Did they speak to your parents?
20
A.
That's something you'd have to ask my
21
parents.
22
O.
Do you know whether they spoke to your
23
parent's?
24
A.
No, sir.
25
O.
You have no idea?
46
1
A.
No, sir.
2
: Objection. Asked and
3
answered.
4
BY MR. TEIN:
5
O.
So if I say the name to you
6
, you don't know who that is?
7
A.
No, sir.
8
O.
How many women and how many men came to
9
your house?
10
A.
I want to say two ladies and two guys.
11
O.
Did someone named -come
to
12
your house?
13
A.
I don't know names, sir.
14
O.
Do you know who
is?
15
A.
No, sir.
16
O.
Do you know wh
is?
17
A.
Yes.
Page 39
EFTA00801913
-0929104.TXT
18
20
21
O.
A.
O.
That's the lawyer who
•
Yes.
Has Mr.
23
: Any conversations that you've
24
had with Mr.
regarding that issue, you are
25
not to disclose. If you've learned in some other
1
47
fashion, you may answer.
2
THE WITNESS: Okay.
3
I wouldn't know.
4
BY MR. TEIN:
5
O.
You don't know?
6
A.
No.
7
: Objection. Foundation.
8
Attorney/client privilege.
9
BY MR. TEIN:
10
O.
And you say you don't know who
11
is?
12
A.
No, sir.
13
O.
Does it refresh your recollection that he's
14
7
15
A.
No.
16
O.
That he's
7
17
A.
No.
18
O.
Does it refresh your memory that he's the
19
22
A.
No.
I don't know who he is.
Page 40
EFTA00801914
-0929104.TXT
23
O.
Without telling me any conversations that
24
you've had with your lawyers,
25
1
2
A.
3
O.
4
A.
5
O.
Did you ever meet Mr.
7
6
A.
Once.
7
O.
Don't -- don't tell me what you discussed
8
with him. Where did you meet him?
9
A.
I was shopping in my -- he showed up at my
10
friend's house.
11
O.
Whose house?
12
A.
My friend
13
O.
Is that
from
14
15
A.
Yes.
16
O.
And did you have a meeting with him at
17
house?
18
A.
Yes.
I guess you could say that.
19
0.
And who else was there?
20
A.
21
O.
And what was that meeting about?
22
: Objection. That calls for
23
attorney/client privilege.
24
BY MR. TEIN:
25
O.
What discussions did you have with
Page 41
48
EFTA00801915
-0929104.TXT
49
1
Mr.
in the presence of
7
2
A.
None.
3
O.
What discussions did you have in the
4
presence of
5
A.
01
6
MR. GOLDBERGER: It's the
7
BY MR. TEIN:
8
O.
Oh, of
9
A.
The only one that we've ever discussed or
10
ever had.
11
O.
And so you were in a conversation with
12
Mr.
13
A.
Yes, sir.
14
O.
And you discussed privileged matters during
15
that conversation?
16
: Object to the form.
I think
17
you might have to educate her on that question.
18
BY MR. TEIN:
19
O.
20
A.
Yes.
21
O.
Did
tell you about any
22
conversations that she had with Mr.
7
23
A.
As far as I'm concerned, she's never spoken
24
or she's never had a conversation. She only opened the
25
door and then left. She's the one who answered the door.
50
1
O.
Why did the meeting take place at
2
house?
3
A.
I spent the night that night at her house.
4
O.
And when was this?
Page 42
EFTA00801916
-0929104.TXT
5
A.
A while ago.
6
O.
How long ago?
7
A.
I'm guessing.
8
O.
7
9
A.
Uh-huh.
10
O.
12
13
O.
Did you meet what an FBI agent named •
14
, a woman?
15
A.
I don't know.
16
O.
Did Ms.
speak to you about
17
getting reimbursed from Mr. Epstein?
18
A.
I've never had a discussion with anyone
19
about getting reimbursed from Mr. Epstein.
20
O.
Have you met with an agent named
21
22
A.
Not to my knowledge.
23
O.
How about an agent named
7
24
A.
No, sir.
25
O.
How about an agent named
7
1
A.
No.
2
O.
And we've learned that many of the girls,
3 some of whom are as old as 23, were told by the
4
government that they would get money at the end of the
5
criminal prosecution. Does that sound familiar to you?
6
A.
No, sir.
7
O.
Other than
here -- I'm not
8
asking about Mr.
either --
Page 43
51
EFTA00801917
-0929104.TXT
9
A.
Uh-huh.
10
O.
-- did anyone ever discuss with you that
11
you could get reimbursement for your damages?
12
A.
No, sir.
13
O.
Did you or any member --
14
: Are you referring to a
15
criminal matter or a civil matter?
16
BY MR. TEIN:
17
O.
Did you or any member
18
: Excuse me. Let me object to
19
the form of the question.
20
BY MR. TEIN:
21
O.
Did you or any member of your family ever
22
get a victim notification letter from anyone?
23
A.
I no longer live
and I
24
wouldn't know.
25
O.
So your testimony is that you have never
52
1
received a victim notification letter, correct?
2
A.
Correct.
3
O.
And your testimony is that you don't know
4
if your parents have ever received a victim notification
5
letter, correct?
6
A.
Correct.
7
O.
Have you given any evidence to prosecutors
8 or law enforcement in this case?
9
A.
What do you mean by evidence?
10
O.
Well. Anything that you can touch or feel?
11
A.
No.
12
: Objection to the form of the
13
question.
Page 44
EFTA00801918
-0929104.TXT
14
15
16
17
18
BY MR. TEIN:
O.
So you haven't given anything physical
A.
No.
O.
-- any item to any prosecutor, police
officer or law enforcement agent, correct?
19
A.
My cell phone
21
but that's it.
O.
You gave your cell phone to whom?
22
A.
23
O.
Did she keep it?
24
A.
Ask her.
25
O.
You gave it to her and then you didn't get
53
1
it back at the end of the meeting?
2
A.
No. They -- yeah. No. They have it. I'm
3 guessing.
I don't have it.
4
O.
6
: Objection to the form of the
7
question. Attorney/client privilege.
8
BY MR. TEIN:
9
0.
11
: Same. Same objection,
12
attorney/client privilege.
13
Don't answer the question.
14
BY MR. TEIN:
15
O.
I'm not asking about what your lawyer told
16
you.
17
: I'm instructing her not to
Page 45
EFTA00801919
-0929104.TXT
18
answer the question, because any of those
19
conversations involve her counsel.
20
MR. TEIN: Certify that.
21
: Please.
22
CERTIFIED QUESTION
23
BY MR. TEIN:
24
Q.
Now,
, you lied to get out of this
25
deposition, didn't you?
54
1
A.
No, sir.
2
Q.
You didn't want to come to court today and
3 tell the story that you had told to the police under
4
oath, did you?
5
: Object to the form of the
6
question. Lack of foundation, predicate.
7
THE WITNESS: No.
I have no problem coming
8
here and talking to you.
9
BY MR. TEIN:
10
Q.
And to avoid getting served with a lawful
11
subpoena, you lied about your name, didn't you?
12
A.
No.
13
Q.
And in fact, just lying yourself wasn't
14
enough, was it?
15
: Objects to the form of the
16
question.
17
Don't answer it. It's not a question.
18
Object to the form of the question. Lack
19
of foundation.
20
MR. TEIN: Are you instructing her not to
21
answer?
22
:
I am.
Page 46
EFTA00801920
23
24
25
-0929104.TXT
MR. TEIN: Certify it.
: Please.
55
1
CERTIFIED QUESTION
2
BY MR. TEIN:
3
Q.
You asked your co-workers --
4
: It's vague and ambiguous.
5
BY MR. TEIN:
6
Q.
You asked
to lie for you, didn't you?
8
A.
No.
I informed my boss about what was
9
going on and he told me that he would help in any way
10
that he can.
11
Q.
Okay. You got your friend
to lie
12
by switching name tags with you, correct?
13
A.
Incorrect. It was a coincidence that same
14
night she was not wearing her name tag; she was wearing
15
mine. But I was also not wearing -- I was wearing my
16
name tag. Everyone switches name tags. It just so
17
happens it was a coincidence that same night the people
18
came with the papers.
19
MR. TEIN: Will you put up Exhibit 18-001?
20
MR. GOLDBERGER: And mark 18-001 for
21
identification purposes to this deposition.
22
: None of them have been marked
23
yet. Can we mark them and put them as attachment
24
to the depositions? Because I think you've shown
25
three photos now. And this is the only one that
Page 47
EFTA00801921
-0929104.TXT
56
1
has been marked for identification yet.
2
BY MR. TEIN:
3
O.
4
: Hold on just a second. Just
5
so the record is clear --
6
MR. TEIN: I'm not speaking to you.
7
: Okay. Then don't speak to me
8
then. But I'll speak to Mr. Goldberger, perhaps.
9
But at least for the record, can we put on
10
the record what the previous two photographs were
11
marked for identification?
12
MR. GOLDBERGER: We will make sure that the
13
record is clear at the end of the deposition so
14
that there's no ambiguity.
15
: Thank you.
16
BY MR. TEIN:
17
O.
, I've put a photograph marked 18-001
18
up on the screen. Do you see that?
19
A.
Yup.
20
O.
Who is that in the photo?
21
A.
on the left and me on the right.
22
O.
right?
23
A.
Yes.
24
O.
, your friend at the
25
, right?
57
1
A.
Yes.
2
O.
, your friend, who you say the day
3 that the process servers went to serve you with a
4
subpoena for this deposition, just happened -- just by
Page 48
EFTA00801922
-0929104.TXT
5
coincidence, was wearing your name tag?
6
A.
Yes, sir.
7
O.
And just by coincidence, you were wearing
8
her name tag, correct?
9
A.
Yes.
10
O.
Your testimony under oath is that's just a
11
coincidence, right?
12
A.
Total honesty.
13
O.
It just happens to be the day that you were
14
going to be served with a subpoena, correct?
15
A.
That wasn't the first day that --
16
_•
just answer the
17
question. It calls for a yes or no.
18
THE WITNESS: Yes.
19
BY MR. TEIN:
20
O.
21
going to be -- you thought you were being served with a
22
subpoena, correct?
23
A.
Correct.
24
O.
You knew before the day that you switched
25
You said that wasn't the first day you were
name tags with
that the process servers were
58
1
looking for you, didn't you?
2
A.
No.
I knew --
3
: Just answer it. It calls for
4
a yes or no.
5
THE WITNESS: Okay. No.
6
BY MR. TEIN:
7
O.
Now you can explain the answer that your
8
counsel stopped you from explaining.
Page 49
EFTA00801923
-0929104
9
A.
Okay. I work at
and people
10
were telling me that people were looking for me. So yes,
11
I was aware that people were searching for me, but I had
12
no idea who they were or what their intentions were, but
13
I thought they were just people I didn't want to talk to.
14
So I just didn't want to talk to them. And every time
15
they'd come to work I wasn't there. And so happens the
16
night that they came in me and my friend switched name
17
tags. No big deal.
18
Q.
That's a lie, isn't it,
19
: Objection. Don't answer that
20
question. That's harassment and I will not allow
21
it. He could ask the questions and we'll allow a
22
jury to make that determination, but not counsel.
23
I will not allow her to answer that
24
question.
25
MR. TEIN: Certify it.
59
1
: I'll certify it.
2
CERTIFIED QUESTION
3
She's answered that question. She's explained it five
4
times already. The fact that Counsel doesn't like the
5
answer, that's a different query.
6
MR. TEIN: Stop making speaking objections.
7
: I'm not. I'm not going to
8
put up with it, because it's in appropriate, Jack,
9
and you know it.
I will not allow Counsel to
10
berate a witness, whether it's in a criminal case
11
or a civil case, whether my client or --
12
MR. TEIN: Calm down.
13
: Excuse me.
Page 50
EFTA00801924
-0929104.TXT
14
No, I'm not going to allow it. That is not
15
proper.
16
MR. GOLDBERGER: Okay.
17
: If he wants to say that she's
18
lying after asking it five times and her
19
explaining in great detail, he can do that. But
20
I'm not going to allow her to answer, nor be
21
harassed by him. It's improper.
22
MR. GOLDBERGER: Okay. But your response
23
that Counsel doesn't like the question -- or
24
doesn't like the answer -- just let me finish.
25
: Absolutely.
I wasn't going
60
1
to interrupt you.
2
MR. GOLDBERGER: Just requires us to say we
3
like the answer to that question. And it's not
4
you and 1 or you and Mr. Tein who are testifying
5
here. It's the witness.
6
: Fine. But after the sixth
7
time of asking the same question and then coming
8
back and pointing a finger at her and saying,
9
you're a liar --
10
MR. TEIN: That didn't happen.
11
: That's fine. But I'm not
12
going to allow her to answer that question because
13
she's answered that same question and has
14
explained it.
15
Now Counsel might be sitting there rubbing
16
his head with a migraine. That's his problem.
17
But if he can't ask a question appropriately in a
Page 51
EFTA00801925
-0929104.TXT
18
professional manner, we will leave.
I will not
19
allow her to be berated like that.
20
MR. GOLDBERGER: Actually, we're very happy
21
with the answer.
22
: That's great.
23
MR. GOLDBERGER: Do you want us to get into
24
that?
25
MR. TEIN: III
61
1
: This is really big stuff that
2
you're going through, but that's fine; just ask
3
your question and move on. But do it one time.
4
If you don't understand it, I'll let you follow
5
up, but I'm not going to allow you to ask the same
6
question the time and again and then call her a
7
liar. Just ask the question, get the answer and
8
move to the next subject matter.
9
MR. TEIN: III, I'm sitting right across
10
the table from you.
11
: Yes, sir.
12
MR. TEIN: Please be quiet. Don't yell.
13
:
I will not be quiet.
14
MR. TEIN: Stop yelling.
15
: Lewis, when I'm yelling
16
you'll know it.
I will not
17
MR. TEIN: My name is not Lewis.
18
:
I thought your first name was
19
Lewis, Mr. Tein.
20
MR. TEIN: You watched me for three days at
21
the evidentiary hearing where you sat in the back
22
of the courtroom. You should know who I am.
Page 52
EFTA00801926
-0929104.TXT
23
: Well, that's the impression
24
you must have made in the courtroom.
25
I will not be quiet.
62
1
MR. TEIN: That's obnoxious. Stop being
2
obnoxious. It's stupid. Let's go ahead with the
3
questions.
4
:
I will make the record.
5
MR. TEIN: Let's get on with the questions.
6
: Do you need a break?
7
(Thereupon, a recess was taken.)
8
BY MR. TEIN:
9
O.
Okay.
, after you told your manager
10
at
everything that was going on
11
and he told you he would help you any way he could, he
12
hid you in the kitchen from the process servers, correct?
13
A.
Incorrect.
14
O.
Isn't it true that lying to avoid service
15
is a meaningless lie to you,
16
A.
Incorrect.
17
O.
What is your manager's name?
18
A.
1 have_.
Would you like to know
19
all
20
O.
Who's the one who lied for you?
21
A.
22
O.
And what did
do to lie for you?
23
A.
Said I wasn't there.
24
O.
And who did he tell wasn't there?
25
A.
Ask him.
Page 53
EFTA00801927
-0929104.TXT
63
1
O.
Where were you when
told this
2 someone that you were not at
7
3
A.
4
O.
At
7
5
A.
Yes.
6
O.
What did you do so that
would lie to
7 the process servers for you?
8
A.
Nothing.
9
O.
You just got him to lie for you, didn't
10
you?
11
A.
No. I had no influence on him saying
12
wasn't there.
13
O.
He took that upon himself?
14
Isn't it true that Mr. Epstein's process
15
servers had to ask the police to get you out of the
16
so that they could serve you?
17
: Objection. Lack of
18
foundation, predicate.
19
BY MR. TEIN:
20
O.
You can answer the question.
21
: If you know. Don't guess.
22
THE WITNESS: No. Can you repeat the
23
question?
24
MR. TEIN: Don't coach.
25
: Don't guess.
64
1
2
3
4
MR. TEIN: That's a coaching.
: No. That's an instruction to
the client.
MR. TEIN: No. You don't do that.
Page 54
EFTA00801928
-0929104.TXT
5
THE WITNESS: Can you repeat the question?
6
: Let me just state for the
7
record --
8
BY MR. TEIN:
9
O.
Once the police -- isn't it true that
10
Mr. Epstein's process serves had to ask the police to get
11
you out of the
so that they could serve you?
12
A.
Incorrect. My boss called the police.
13
O.
And once the police showed up, to stop you
14
from lying to avoid service, you made up another lie that
15
the process servers had harassed you. Isn't that
16
correct?
17
A.
Incorrect.
18
O.
You lie all the time, don't you?
19
: Objection.
20
THE WITNESS: Incorrect.
21
BY MR. TEIN:
22
O.
You have a MySpace page, don't you?
23
A.
No longer do I have a MySpace page.
24
deleted it.
25
O.
When did you delete your MySpace page?
65
1
A.
2
0.
Who told you to take your MySpace page down
3
4
A.
Nobody. I'm sick and tired of MySpace.
5
O.
You all of a sudden got sick and tired of
6
MySpace and just
before this deposition you
7 decided to delete your MySpace page, correct?
8
A.
Correct.
Page 55
EFTA00801929
-0929104.TXT
9
O.
Is that your testimony under oath?
10
A.
Yes.
11
O.
Did you take your MySpace page down because
12
you thought the government might subpoena it?
13
A.
Incorrect.
14
O.
Hadn't your MySpace page been up for over
15
months before you took it down?
16
A.
Correct. But I also had made tons of
17
MySpaces over the last years.
I just get tired of them
18
and delete them because drama and make new ones.
19
O.
We're going to talk about that.
20
So you deleted your MySpace page after you
21
were already under subpoena for this deposition, correct?
22
A.
Correct.
23
O.
What about the MySpace page didn't you want
24
us to see,
25
A.
Nothing.
66
1
O.
Well, we're going to come back to MySpace
2
in a second.
3
A.
You do that.
4
O.
I'm going to ask you some questions
5
about why you lie about your age so often, okay?
6
: Objection to the form.
7
Argumentative.
8
BY MR. TEIN:
9
O.
You lie about your age all the time, don't
10
you?
11
: Objection, argumentative.
12
THE WITNESS: Incorrect.
13
BY MR. TEIN:
Page 56
EFTA00801930
-0929104.TXT
14
O.
You lie about your age to get body
15
piercings, don't you?
16
A.
Incorrect.
17
O.
You have body piercings, don't you?
18
A.
Yes.
19
O.
You have
body piercings; isn't that
20
right?
21
A.
22
O.
Other than the pierceings on your ears
23
I'm not talking about that --
24
A.
Oh, then no;
25
O.
67
1
2
3
A.
O.
When did you get that?
A.
5
O.
And when was that?
6
A.
When I was III
7
O.
Okay. So you had that body piercing when
8
you met Epstein, correct?
9
A.
It might have been, or maybe that
yeah,
10
either my
I honestly don't
11
remember.
12
O.
Now you've lied about your age to get into
13
bars by using driver's licenses that aren't yours,
14
correct?
15
A.
Incorrect.
16
O.
Are you swearing under oath that you've
17
never done that?
Page 57
EFTA00801931
-0929104.TXT
18
A.
Yes, I swear under oath.
19
O.
And you've lied about your age to buy beer,
20
correct?
21
A.
Incorrect.
22
O.
You're swearing under oath that you've
23
never lied to stores about your age?
24
A.
I've never lied to a store about my age or
25
anything.
68
1
O.
You try to look much older than you are,
2 don't you?
3
A.
Incorrect.
4
O.
And you've lied about your age on your
5
MySpace pages, don't you?
6
A.
Incorrect.
7
O.
All right. Let's look at Exhibit 26-01
8 one.
9
MS.
: 26-001?
10
MR. TEIN: Yes.
11
BY MR. TEIN:
12
O.
13
were 18, didn't you?
14
A.
Correct.
15
O.
Let's go to Exhibit 33.
16
MS.
: That's 33-001?
17
TEIN: Correct.
18
BY MR. TEIN:
19
O.
On this page you lied to everyone that you
20
were 19, didn't you?
21
A.
Incorrect.
22
: Just answer the question.
Page 58
On this page you lied to everyone that you
EFTA00801932
-0929104.TXT
23
THE WITNESS: Oh, incorrect.
24
BY MR. TEIN:
25
O.
Now you can explain your answer.
69
1
A.
I know that I have seen all of these and
2
know that this one is mine.
3
Can you go down?
4
: Just for the record, you're
5
pointing to the photo.
6
THE WITNESS: I'm pointing to --
7
BY MR. TEIN:
8
O.
You're pointing to the one where it says
9
you're age is 18?
10
A.
Correct.
11
O.
That's yours, right?
12
A.
Correct. That's mine from a couple years
13
ago that I have not been on base I don't use that.
14
Please keep going down, please. And I think that's it,
15
because there's no one -- just that one is mine.
16
O.
So the one you pointed to where it says
17
your age is 18, that's yours, correct?
18
A.
Correct.
19
O.
And when you wrote 18 as your age on your
20
MySpace page, that was a lie, wouldn't it?
21
A.
Correct.
22
O.
Did you lie about your MySpace page back
23
then because you couldn't post on MySpace unless you were
24
18?
25
A.
Correct. There was a rule many years ago
Page 59
EFTA00801933
-0929104.TXT
70
1
that you had to be 18 to have a MySpace.
2
O.
So you lied about your age so you could
3
post on MySpace, right?
4
A.
Yes.
5
O.
Let's go back to the top one on this page,
6
33-01.
7
8
Are you testifying now under oath that this
MySpace page where the headline says, '
," and the location is given as
, and the age is., and it says
11
12
that?
13
A.
Correct.
, is it your testimony that you did not post
14
O.
Now let's go back to the one that you were
15
pointing to before on this page, where it says your age
16
is .and you lied about your age to post MySpace, okay?
17
A.
Uh-huh, yes.
18
O.
All right. Why did you finally put your
19
true age on your MySpace profile
before you
20
were scheduled to testify before the Grand Jury?
21
A.
I don't know what you're talking about.
22
: If you don't understand, ask
23
him to ask the question again.
24
MR. TEIN: Don't coach.
25
THE WITNESS: I don't know which MySpace
71
1
you're talking about.
2
BY MR. TEIN:
3
O.
The MySpace page that you're just pointing
4
to, where it says you were III
Page 60
EFTA00801934
-0929104.TXT
5
A.
Yes.
6
O.
And you were lying about your age, right?
7
A.
Uh-huh.
8
O.
Why did you finally post your true age on
9
your MySpace profile --
10
A.
Uh --
11
O.
before you were scheduled to
12
testify before the Grand Jury?
13
A.
I honestly don't know which MySpace,
14
because I've had like a bazillion MySpaces and in that
15
year, I had
. So I don't know which one you're referring
17
to_
18
O.
You remember that you changed your age on
19
20
before you went and testified in the Grand Jury?
21
A.
No.
22
O.
You don't remember that.
23
A.
No.
24
O.
Do you remember Detective
? Did you
25
ever meet a Detective
your MySpace page from
just
1
2
A.
I don't know the names.
O.
How many different detectives have you met
72
3 with on this case from Palm Beach?
4
A.
Probably a good six or seven, maybe.
5
O.
Did one of the detectives tell you before
6
you testified in the Grand Jury that you should take your
7
MySpace age and put your true age?
8
A.
No.
Page 61
EFTA00801935
-0929104,141=mm
9
O.
Didn't Detective 1111111 have to come to
10
your house to pick you up to get you to testify in front
11
of the Grand Jury?
12
A.
Possibly, maybe because I didn't have a
13
ride.
I was only
at the time.
14
O.
didn't drive you?
15
A.
No.
16
O.
didn't drive you?
17
A.
I think
. Oh,
drove
18
me.
19
O. -drove
you?
20
A.
Yes, sir.
21
O.
So your testimony is Detective
did
22
not drive you, correct?
23
: Objection /asked and
24
answered.
25
THE WITNESS: No. I'm pretty sure
73
1
drove me because he was there with me.
2
BY MR. TEIN:
3
O.
Did any detective tell you to change your
4
age on your MySpace page to put your true age?
5
A.
No, sir.
6
O.
Now you also lied on your MySpace page
7
about your income, didn't you?
8
A.
Yes.
9
O.
And you lied, saying that you made a
10
, correct?
11
A.
As a joke, yes.
12
O.
That was a lie, wasn't it?
13
A.
Yes.
Page 62
EFTA00801936
-0929104.TXT
14
15
16
17
18
19
20
21
22
23
24
25
Q.
And you also lied on your MySpace page,
saying that you were married, didn't you?
A.
Possibly.
error on my part.
And that might have been an
O.
Now you also lie to the police, don't you?
A.
No.
O.
Well, you lied to the police in your
tape-recorded statement that you gave to Detective
, didn't you?
A.
To my knowledge, no, I did not.
O.
Well, you lied to the police when you
accused Mr. Epstein of attempting to murder your father,
74
1
didn't you?
2
A.
No.
I never heard a statement saying that
3
Mr. Epstein tried to murder my father.
4
O.
You made that statement, didn't you?
5
: Do you have a statement to
6
show her? That's been asked and answered.
7
MR. TEIN: I'm sorry.
I didn't hear the
8
witness' answer,
9
BY MR. TEIN:
10
O.
, you told the police, didn't you,
11
that Mr. Epstein almost killed your father, didn't you?
12
A.
No.
13
O.
before Mr. Epstein even
14
knew about this investigation, you told the police that
15
Epstein had "already come to my dad's house and did
16
something to my dad's
and my dad almost died.
I
17
didn't want my dad to get hurt, because Jeff already
Page 63
EFTA00801937
-0929104.TXT
18
almost killed him."
19
Didn't you say that?
20
A.
Not to my knowledge or recollection.
1
21
have never said anything like that.
22
O.
That would have been a complete lie,
23
wouldn't it have been?
24
A.
Yeah.
25
O.
Because Mr. Epstein never came to your
75
1
dad's house, correct?
2
A.
Correct.
3
O.
And no one who worked for Mr. Epstein ever
4
did something to your dad's
Did they?
5
: Objection. Lack of
6
foundation, predicate.
7
Don't guess.
8
BY MR. TEIN:
9
O.
It's not true that Mr. Epstein almost
10
killed your father, is it?
11
: Objection. Asked and
12
answered, lack of foundation, predicate.
13
BY MR. TEIN:
14
O.
You can answer.
15
A.
No.
16
O.
Now you told the police that you didn't
17
know who was in the car with you and
on the day
18
you went to Epstein's house, didn't you?
19
A.
Yes.
20
O.
And that was a lie, wasn't it?
21
A.
It's the truth.
22
O.
You told the police that there was someone
Page 64
EFTA00801938
-0929104.TXT
23
in the car next to you and you specifically said you
24
didn't know her name, right?
25
A.
Correct. I do not know her name.
76
1
O.
You said, "I don't know her name, but she
2
was dark like a Spanish girl." Those were your words,
3
right?
4
A.
Yes.
5
: Objection. Asked and
6
answered.
7
BY MR. TEIN:
8
O.
Who was in the car that day with you and
9
10
A.
Again, I do not know.
11
O.
It was your good friend
12
wasn't it?
13
A.
No.
I don't know a
14
O.
You lied to the police about who was in the
15
car with you and
didn't you?
16
A.
Incorrect.
17
O.
Let me ask you some questions about who you
18
may have spoken to about this case. All right?
19
A.
Go ahead.
20
O.
Did you speak to
21
A.
Not in detail, but of course she knows;
22
she's family and yes.
23
O.
What's her e-mail?
24
A.
I don't think she has an e-mail_
25
O.
What is her phone number?
Page 65
EFTA00801939
-0929104.TXT
77
1
A.
Oh, gosh. I don't know off the top of my
2
head.
3
O.
And what is her home address?
4
A.
She lives
-
5
O.
In
6
A.
Yes, sir.
7
O.
What about
7 Did
8
you speak to him about Epstein's case?
9
A.
That's my
. My sister
10
doesn't have
, so maybe you get them confused.
12
O.
Do you know his phone number?
13
A.
No.
14
O.
Where does he live?
15
A.
16
O.
In the same house with her?
17
A.
Yes. They're married.
18
O.
So not boy friend; husband?
19
A.
Yeah, husband.
20
O.
Have you spoken to
about
21
what happened in Mr. Epstein's house?
22
A.
Not in detail, but he knows the basics,
23
yes.
24
O.
What is his e-mail/
25
A.
I don't know.
78
1
O.
What is his phone number?
2
A.
How is that relevant?
3
O.
What is his phone number?
4
A.
Page
66
EFTA00801940
-0929104.TXT
5
O.
What is his home address?
6
A.
I don't know.
7
O.
Where does he live?
8
A.
In
somewhere.
9
O.
Ever been to his house?
10
A.
Yes.
11
O.
You don't know what his address is?
12
: Objection. Asked and
13
answered. She just said she doesn't know.
14
MR. TEIN: Don't coach.
15
: Objection. Asked and
16
answered.
17
BY MR. TEIN:
18
O.
You can answer the question.
19
A.
I don't know the exact address.
20
O.
What street is it on?
21
A.
It's an apartment complex; its not a
22
street.
23
O.
What's the name of the apartment complex?
24
A.
25
O.
What apartment number is it?
79
1
A.
I couldn't tell you.
2
O.
When was the last time you went there?
3
A.
Just visited
That's the
4
I went there.
5
O.
How about
7 Have you spoken
6
to him about your case?
7
A.
No. We no longer speak.
8
O.
What's his phone number? Actually, we
Page 67
EFTA00801941
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
-0929104.TXT
already have his phone number room and e-mail.
How about
7 Have you ever
spoken to her about your case?
A.
I don't know an
O.
Have you ever met
A.
No. But just to let you know, I don't
really know names. If you have pictures, of there faces
I could tell you.
O.
All right. Let me see if I can refresh
your memory.
A.
Okay.
O.
Does it refresh your memory that
is the other girl who made allegations about Epstein, but
A.
No, sir. I have no knowledge of any other
girls in this whole situation. We're not allowed to know
80
1
each other.
2
O.
I didn't get the last four words.
3
A.
We're not allowed to know each other.
4
O.
And what about
? Have you
5
of met her?
6
A.
No, sir.
7
O.
Let's see if I can refresh your memory on
8
her. She's the other person
11
A.
I have no knowledge of her.
12
O.
Never met her?
13
A.
Never met her.
Page 68
EFTA00801942
14
15
16
17
18
19
20
21
22
23
24
25
Is that
case?
-0929104.TXT
A.
I don't know who that is either.
O.
A person named
who knows
7
A.
I don't know, sir.
O.
Do you remember making a statement to
that's in the police reports?
A.
No.
O.
Have you read the police reports in this
A.
Yes.
0.
1
A.
2
O.
81
5
A.
Yes.
6
O.
You didn't want to see that happen, right?
7
A.
No.
8
O.
So you're saying you don't know a
9
10
: Objection. Asked and
11
answered.
12
BY MR. TEIN:
13
O.
Does it refresh your memory that he was
14
somebody who had gone to jail for
7
15
A.
No, sir.
16
O.
Someone who knows
7
17
A.
No.
Page 69
EFTA00801943
-0929104.TXT
18
O.
You don't know if he met with Detective
19
20
A.
No, sir.
21
O.
How about
22
A.
Yes, I remember.
I know who that is.
23
O.
Did you ever speak to
about what
24
happened at Mr. Epstein's house?
25
A.
He knows what happened
He
82
1
doesn't know this is still going on today.
2
O.
What's his address? I'm sorry.
I have his
3 address.
4
A.
I don't know.
5
O.
How about
7
6
A.
7
O.
You know who that is?
8
A.
I know who that is, yes.
9
O.
He's the one you
12
A.
No, sir.
13
O.
Remember the
you were
14
supposed to go to?
15
A.
No, sir.
16
O.
Did you speak to
about this
17
case?
18
A.
No, sir.
19
O.
How about
?
20
A.
That's my
21
Q.
age
EFTA00801944
-0929104.TXT
23
24
25
A.
information.
O.
Ask him. I would not know that
Did you speak to
about this
83
1
case?
2
A.
No, sir.
3
O.
Have you spoken to
about this
4
case?
5
A.
No.
I don't know who
is.
6
O.
Did your parents speak to
?
7
A.
Ask my parents.
8
O.
Let's see if I can refresh your memory as
9 to who he is. Okay?
10
A.
Uh-huh.
11
O.
He's the
13
A.
I am aware of that. And again, I was not
14
aware like tha
17
O.
Tell me what you know about
20
A.
I don't know about the details at all.
21
O.
How much money did
23
A.
I don't even know
24
O.
I'm sorry?
25
A.
I didn't even know
Page 71
EFTA00801945
-0929104.TXT
84
1
0.
What do you know about the
3
A.
I only know
I don't know anything else.
5
0.
When was that?
6
A.
This was a while ago,
.
I honestly don't know.
8
0.
Did
9
10
A.
I don't know.
11
0.
Did
13
A.
No, sir.
14
0.
Did he offer you any money?
15
A.
No, sir. Never spoke to him.
16
0.
What reporters have you spoken to?
17
A.
Zero.
18
0.
What about your family members? What
19
reporters have they spoken to?
20
A.
22
0.
Tell me -- let's go through each one that
23
you remember.
what other reporters have any member of your
25
family spoken to?
1
85
A.
I don't know. And I know
4
don't contact them.
You'd have to ask them.
I
Page 72
EFTA00801946
-0929104.TXT
5
O.
Well, I just want to know -- I don't want
6
you to -- I want to know what's in your mind? All right?
7
: She just told you. She just
8
answered --
9
MR. TEIN: Be quiet.
10
BY MR. TEIN:
11
O.
What I want to know is what you know from
12
your personal knowledge. My opinion question to you is:
13
What knowledge do you have about family members of yours
14
speaking to reporters?
15
: Objection. Asked and
16
answered.
17
And if you can't talk professionally, we're
18
going to leave.
19
MR. TEIN: Do what you want to do.
20
: Are you going to continue to
21
talk this way?
22
MR. TEIN: I'm not going to answer any
23
question that you ask me,
24
: Okay.
25
MR. TEIN: But you are misrepresenting the
86
1
record and you are grandstanding for your client
2
and it's wrong. So be quiet. And you know how to
3
make an objection. Make it. Otherwise stop
4
talking.
5
BY MR. TEIN:
6
O.
7
: Excuse me.
8
MR TEIN: If you want to leave the
Page 73
EFTA00801947
-0929104.TXT
9
deposition, leave. But you'll be back here.
10
: Excuse me. If I could just
11
make the record, instead of interrupting me,
12
please, that's what we do professionally. There's
13
a recorder here. I'm certainly not being
14
obstructionist. I'm going to make the record.
15
But we're going to act with some semblance of
16
professionalism, hopefully, by all parties in the
17
room. That goes to me, that goes to your
18
co-counsel sitting behind you and next to you, the
19
court reporter and everyone else in the room.
20
Everyone goes entitled to that.
21
You've asked a question. She answered the
22
question fully and she's not going to be harassed
23
because you don't like the answer. If you want to
24
follow up --
25
MR. TEIN: Stop engaging me. Make your
87
1
speech and then we'll ask the questions.
2
: Well, you won't let me finish
3
making the objection, so it's difficult to do
4
that. But if you want to follow with an
5
appropriate question, feel free to do that. But
6
we're not going to harass the witness.
7
MR. TEIN: I disagree with everything
8
you've said. Let's ask the questions. Okay?
9
: Ask an appropriate question.
10
MR. TEIN: Are you going to stop talking?
11
: I'm going to make -- protect
12
my client and make appropriate objection, but
13
there's not a question pending right now.
Page 74
EFTA00801948
-0929104.TXT
14
BY MR. TEIN:
15
O.
, has
spoken to any reporters?
16
A.
No.
17
: Objection. Asked and
18
answered.
19
BY MR. TEIN:
20
O.
Has
been given money by any
21
reporters?
22
A.
No.
23
O.
Has
spoken to any reporters?
24
: Objection. Asked and
25
answered.
88
1
THE WITNESS: No.
2
BY MR. TEIN:
3
O.
Has
spoken to any
4
reporters?
5
A.
No.
6
O.
Has
received any
7
money from reporters?
8
A.
No.
9
O.
Are you sure you don't know
10
: Objection. Asked and
11
answered.
12
THE WITNESS: I'm positive.
13
BY MR. TEIN:
14
O.
I'll try again to refresh your memory.
15
A.
Okay.
16
0.
Does it refresh your memory thai
Page 75
EFTA00801949
18
19
20
A.
No.
I don't know who she is.
21
O.
Have you spoken to anyone else who's been
22
at Epstein's house?
23
A.
No.
24
O.
Without telling me what was said -- I don't
25
want to know about any conversations with any lawyers,
89
1
okay --
2
A.
Uh-huh.
3
O.
-- did you or your parents speak to any
4
other law firms besides
law
5
firms?
6
A.
No.
7
O.
Now without telling me about anything that
8
was said, what -- did one just come to mind?
9
A.
No.
I was thinking about something else.
10
O.
What were you thinking about?
11
A.
Does family court matter?
12
O.
Okay. Without telling me what was said,
13
who prepared you for todays deposition?
14
A.
What do you mean prepared?
15
O.
Did you talk about this deposition, about
16
what would happen, with anybody?
17
A.
Yes.
18
O.
Don't tell me what was said?
19
A.
Okay.
20
O.
I'm not asking that.
I don't want to know
21
that.
22
A.
Okay.
Page 76
EFTA00801950
-0929104.TXT
23
24
25
1
2
O.
A.
O.
A.
O.
Who prepared you for today's deposition?
Anybody else?
No.
When did you meet with
to
3
prepare for today's deposition?
4
A.
This morning.
5
O.
And how long did that meeting last?
6
A.
Until it started.
7
O.
Now you told me that you previously had
8
read the police reports in this case?
9
A.
Yes.
10
O.
Have you read your statement that you gave
11
to the police?
12
A.
Yes, sir.
13
O.
And in what form was that statement?
14
A.
What do you mean?
15
O.
Was it in the form of a police report or a
16
transcript?
17
A.
What's the difference?
18
O.
A transcript has questions and answers on
19
it. A police report is just typed out narrative.
20
A.
Oh, it's a police report.
21
O.
And when did you read the police report?
22
A.
A few days ago. I overread it a few days
23
ago.
24
O.
Had you read it before that?
25
A.
No.
Page 77
90
EFTA00801951
-0929104.TXT
91
1
O.
Now you told me -- again, I don't want to
2
know what was said.
3
A.
Uh-huh.
4
O.
You told me that you met with
5
this morning to prepare for your deposition, right?
6
A.
Yes.
7
O.
When did you set up that meeting with
8
to take place this morning?
9
A.
Gee, like, lik
10
ago.
11
O.
So you're aware that
told us
12
that he could not start the deposition this morning
13
, correct?
14
: Don't answer that question.
15
Calls for attorney/client communications.
16
BY MR. TEIN:
17
O.
Have you seen the letter that
18
wrote to us stating that he -- an e-mail that
19
wrote to Mr. Goldberger stating that he could not be here
20
this morning because
?
Did you
21
see that e-mail?
22
: You can answer that question.
23
THE WITNESS: No.
24
BY MR. TEIN:
25
O.
Have you listened to your tape-recorded
92
1
statement to the police?
2
A.
Yes.
3
O.
Where did you listen to that?
4
A.
In, I think, this building.
I don't know.
Page 78
EFTA00801952
-0929104.TXT
5
It was here.
6
O.
When did you listen to that statement?
7
A.
This morning.
8
O.
And who was present when you listened to
9 that statement?
10
A.
-- and I forget your name.
11
MR. GOLDBERGER: Ms.
12
THE WITNESS: Ms.
13
BY MR. TEIN:
14
O.
And you hadn't listened to your statement
15
before that, correct?
16
A.
No, sir.
17
O.
19
A.
No, sir.
20
Q.
How many times have you spoken to officers
21
with the Palm Beach Police Department?
22
A.
More than I like can count. It's been
23
ongoing for,
so quite a few times.
24
O.
When was the last time you spoke with
25
officers of the Palm Beach Police Department?
1
A.
2
0.
3
A.
A while ago. I'd say
Yeah. Maybe a
4
O.
Do you
5
A.
No.
6
O.
Do you remember
7
8
A.
Yes.
remember Detective
Page 79
, Detective
93
EFTA00801953
-0929104.TXT
9
O.
How many times have you spoken to Detective
10
11
A.
She was the only one I spoke to about this
12
until for some reason she wasn't on the case anymore.
13
O.
When was that?
14
A.
The first meeting I ever had was with her
15
and then I think like I met with her
or something like that, and then I didn't get --
17
18
O.
And who was that?
19
A.
I don't remember.
20
O.
And what type of questions did they ask
21
you?
22
A.
The same.
23
O.
The same questions all over again?
24
A.
Basically.
25
O.
How many taped statements have you given to
another investigator questioned me after that.
1
the police?
2
A.
One that I know of.
3
O.
Just the one with
4
A.
Yes, sir.
5
O.
How about to the FBI? Did you give any
6
statements to them?
7
A.
No. Well, actually.
I don't really
8
9
10
11
12
house?
13
remember if that was taped or not to be honest with you.
I had one meeting
it was taped.
O.
You were interviewed at
94
with them at my house and don't know if
A.
No. That was by the lawyer.
Page 80
EFTA00801954
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14
O.
Oh, boy the lawyer?
15
A.
Uh-huh.
16
O.
Where did the conversation that you had
17
with the FBI take place?
18
A.
At my
19
O.
Which is where?
20
A.
On
21
O.
On where?
22
A.
23
O.
And when did that take place?
24
A.
I'd have to say like a
ago,
25
ago. It was a long time ago.
95
1
(Discussion held off the record.)
2
MR. TEIN: Tell me the last answer, please.
3
(Thereupon, a portion of the record was read
4
by the reporter.)
5
BY MR. TEIN:
6
O.
And who was present when the FBI spoke to
7
you at
8
A.
Mynas
there, but she wasn't
9
around. She made herself like do other things.
10
O.
And how many FBI agents were there?
11
A.
I think four.
12
O.
And you don't remember any of their names?
13
A.
No, sir.
14
O.
And were there any lawyers there?
15
A.
Not that I know of.
16
O.
And none of them gave you their cell phone
17
numbers?
Page 81
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18
A.
No.
19
O.
20
al
ago?
21
A.
It was a while ago.
22
: Objection. Asked and
23
answered.
24
BY MR. TEIN:
25
O.
And the last time you spoke to the federal
And the last time you spoke to the FBI was
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
96
prosecutor's office was when?
A.
I don't know.
O.
Did any of the FBI agents tell you that
had spoken with
A.
No.
O.
Did any of the FBI agents tell you that
had spoken with Mr.
A.
No.
O.
Did any FBI agents tell you that
spoke with Mr.
A.
No.
O.
Did any FBI agents tell you that
spoke with
A.
No.
O.
Do you know whether any of the federal
prosecutors allowed Mr.
to review a draft
indictment?
A.
I wouldn't know.
O.
Do you know if any of the federal
prosecutors discussed a draft indictment with Mr.
7
A.
I wouldn't know.
O.
Have you ever e-mailed with any FBI agent
Page 82
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23
or any federal prosecutor?
24
A.
No.
25
O.
Have you ever text messaged with any FBI
97
1
agent or any federal prosecutor?
2
A.
No.
3
O.
Has the FBI told you about other testimony?
4
A.
No.
5
O.
Has the FBI told you about what other girls
6
have said?
7
A.
No.
8
O.
Have federal prosecutors told you what
9 other girls have said?
10
A.
No.
11
O.
Do you have any way of getting in touch
12
with the FBI if you wanted to get in touch with them?
13
A.
No.
14
O.
How about your parents? Do they know how
15
to get in touch with the FBI?
16
A.
I don't know.
17
O.
And by your parents, I'm referring to.....
, okay?
19
A.
Oh. Well, I'm referring to only
20
because
22
O.
So the answer would be the same for your
23
24
A.
Yeah.
25
O.
Have you spoken to a lawyer name0.....
Page 83
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98
1
about this case?
2
A.
No.
3
O.
Do you know who-is?
4
Let's see if I can refresh your memory.
5
Does it refresh your memory that he's
6
7
A.
I don't know wholIIIIIIIIIIIIII is.
8
O.
is the lead federal
9
prosecutor that's on the federal part of this case.
10
Okay?
11
A.
No.
12
O.
So does it refresh your memory that
9
14
A.
Not at all.
15
O.
Does it refresh your memory that
16
tried to get
17
in the federal case?
18
A.
No.
19
O.
Do you know if Detective
has spoken
20
with your?
21
A.
No.
22
O.
Do you know if Detective
has spoken
23
to your
24
A.
No.
25
O.
How about with
99
1
A.
Yes, I would know, and no, she did not.
2
O.
Let's put up -- let me ask you some
3 questions about the photo that you had posted on your
4
MySpace page before you erased
Okay?
Page 84
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5
6
7
8
9
10
11
12
13
14
15
16
BY MR. TEIN:
17
O.
18
19
20
21
22
23
24
25
This is in
A.
Okay.
MR. TEIN: Do you mind if we close the door
a second, please.
: Exhibit number, please.
MR. TEIN: Put up 25-005.
Hold on a second.
: Don't say anything. She was
talking to her counsel.
MR. TEIN: Put up 25-006.
: Is that 005 right there?
MR. TEIN: Yes.
Who took this photo of you in a
by a bunch of --
: Objection. Mischaracterizes
the photograph, and lack of foundation and
predicate.
Fully explain if you need to.
THE WITNESS: I will.
First of all. This is not a
garage.
100
1
Second of all, I'm not being
2
Everyone has their clothing on.
3
Thirdly, if you look at all the other
4
pictures in this album, I'm drinking -- what's
5
when you're sick you drink it,
6
BY MR. TEIN:
7
O.
You can't ask questions of your counsel.
8
A.
All right. I'm drinking like Sprite. I'm
Page 85
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9
note drinking any kind of alcohol, if you would look at
10
my other pictures in that album. You guys picked the
11
possibly worst pictures out of there to present. And it
12
was just a goofy picture. All of these kids like to be
13
goofy. And that's what we were doing.
14
0.
Who's the man on the left of the picture
15
holding his -- holding a beer bottle as if it were a
16
penis towards your mouth?
17
A.
18
0.
Who's the man behind you, right up towards
19
your backs side, with you bent over?
20
A.
That one?
21
0.
The right side, kissing with his mouth.
22
A.
That's
23
0.
He's the one grabbing towards the groin
24
area of
25
A.
Yes.
101
1
0.
And there's three other men in the photo.
2
What are their names? The one on the left with the hat?
3
A.
That's
(phonetic).
4
0.
Smiling?
5
A.
Yes.
6
0.
Who's the one kissing
7
: Don't interrupt. Let her
8
finish the record. She's testifying.
9
MR. TEIN: I know you don't like this
10
picture, my friend.
11
: The picture is fine.
12
BY MR. TEIN:
13
0.
Who's the one with the hat?
Page 86
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14
15
16
17
18
: No. Hold on. Stop,
You have to let the witness finish her
answer. She was in the process of explaining and
you cut her off.
Please finish what you were saying and then
19
Counsel can ask you whatever he wishes after that.
20
THE WITNESS: Okay. This guy --
21
: Just make it so the record is
22
clear who you're referring to.
23
THE WITNESS: -- on the far left is
25
BY MR. TEIN:
1
O.
102
He's the one whose head is near the groin
2 of
, right?
3
A.
Yes.
4
O.
And in the middle there's a man smiling.
5
Who's that?
6
A.
That's
7
O.
Who's the one in the red hat, kissing?
8
A.
(phonetic).
9
O.
Let me stop you for a second. Are you
10
done?
11
A.
Yes, I'm done.
12
O.
Who is
13
A.
My
15
O.
What is her last name?
16
A.
17
O.
Spell that.
Page 87
EFTA00801961
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18
19
A.
O.
I don't know how to --
Have you spoken to her about this case?
20
A.
No.
21
O.
Who'sillill?
22
A.
My
.
I don't really speak
23
to him at all.
24
O.
What's his last name?
25
A.
1
O.
103
2
A.
3
O.
And have you spoken to
about this
4
case?
5
A.
No, sir.
6
O.
Have you spoken to
about this case?
7
A.
Not in detail, but yes.
8
MS.
: Are we referring to
9
10
THE WITNESS: Yes.
11
MR. TEIN: Yes.
12
MS.
: Okay.
13
BY MR. TEIN:
14
O.
Have you spoken to
about this case?
15
A.
16
O.
Do you have a friend named
7
17
A.
I do not have a friend named
18
O.
From freshman year?
19
A.
No.
20
O.
How about
21
A.
No.
22
O.
Have you spoken to
about this case?
Page 88
EFTA00801962
-0929104.TXT
23
A.
No.
24
O.
What's her last name?
25
A.
.
I don't know how to spell it,
1
O.
104
Is she the person whose house you went to
2 on New Year's this year?
3
A.
No.
I wasn't at her house on New Year's.
4
O.
Where were you when you took the picture of
5
? That on your website?
6
A.
I wouldn't know or -- wait. We were at a
7
birthday party for some girl's 16th birthday.
8
O.
Were you drinking at that party?
9
A.
No. There was no alcohol or anything
10
there.
11
O.
What does
mean to you?
12
A.
It's like -- it just means like messed up.
13
But we weren't, if you look at the picture.
14
O.
Messed up like drunk, right?
15
A.
Sure.
16
O.
Who's
17
A.
A girl I know like from like two years ago.
18
O.
She's the one you were supposed to be
19
staying with when you went drinking with
20
A.
No.
21
O.
What's
last name?
22
A.
23
O.
Where does she live?
24
A.
I don't know. In
25
O.
9
Page 89
EFTA00801963
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105
1
A.
Uh-huh. I'm guessing.
2
O.
Do you know her phone number?
3
A.
No, I do not.
4
O.
Let's look at 25-010.
5
A.
See, I'm drinking --
6
O.
I'm not asking you about what you're
7 drinking.
8
Who are the men in this photo who are
9
7
10
Who are they?
11
A.
and
(phonetic).
12
O.
Are they
13
A.
Are those?
-- he said the
14
That's why I said that.
I
15
don't know. That's
and
16
O.
Are these
17
A.
No. They're all on -- except
18
they're all on
19
O.
Go to 025-015?
20
: 025- dash?
21
MR. TEIN: 015.
22
THE WITNESS: Gosh, that's so long ago.
23
BY MR. TEIN:
24
O.
Who took the photo have you licking the
25
penis?
1
A.
106
My
2
O.
Whose idea -- that was your
3
idea?
4
A.
It was in
, where she works
ag
EFTA00801964
-0929104.TXT
5
currently and that was before she worked there, and we
6 just thought it would be funny.
7
MR. TEIN: 19-007. Can you enlarge that?
8
BY MR. TEIN:
9
O.
Who took this photo of you simulating you
10
having sex with a man?
11
A.
We're not simulating having sex, and
12
it's -- oh, and the person who took it was, I'm pretty
13
sure,
but I know him as
I don't know his
14
last name.
15
O.
Go to 19-006, please.
16
Who took this photo of you simulating sex
17
with a man?
18
A.
The same person. And we're not simulating
19
having sex, Mr. --
20
O.
Tein.
21
Did you post that on the Internet?
22
A.
Actually, this is an old MySpace I never
23
finished and I never like did anything.
I just kind of
24
made it and left it.
25
O.
So the answer is yes, you posted this on
107
1
MySpace?
2
A.
Yup.
3
O.
Go to 25-016. Who took this photo of you
4
simulating sex with a woman?
5
: Object to the form of the
6
question. Argumentative.
7
THE WITNESS: First off, she's
, and I'm pretty sure
Page 91
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9
it was just like we put up a camera somewhere and
10
put a timer on it. We didn't have anybody take
11
it.
12
BY MR. TEIN:
13
O.
You posted that on your MySpace page?
14
A.
Yeah.
15
O.
Go to 25-013. Is that a photo of you?
16
A.
Yep.
17
O.
Who's in the photo with you?
18
A.
19
O.
20
A.
Yep.
21
O.
Is this you coming out of the shower?
22
A.
Yes.
23
O.
Are you clothed in this picture?
24
A.
Yeah. I have a halter dress on.
25
O.
Where is that picture taken?
108
1
A.
In
house.
2
O.
Did you post that on the Internet?
3
A.
Yes.
4
O.
All right.
5
MR. TEIN: You can take that down.
6
BY MR. TEIN:
7
O.
Now your boy friend is
8 correct?
9
A.
Yeah.
10
O.
You lie about your age in order to conceal
11
something about your relationship with
12
isn't that correct?
13
A.
No.
Page 92
EFTA00801966
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14
O.
years old, isn't he?
15
A.
Yes.
16
O.
is a•
right?
18
A.
Yup.
19
O.
Does th
is dating an underage girl?
21
A.
Actually, Mister, it's legal.
22
O.
Well --
23
: Just answer the question,
24
25
THE WITNESS: Yes.
109
1
BY MR. TEIN:
2
O.
Did they know two weeks ago that you were
3 dating an underage girl (sic)?
4
A.
Yes. I met everybody in there.
5
O.
Did they know your age?
6
A.
Yes.
7
O.
Did you lie about your age so that-
wouldn't think that
is committing a
9 crime by having a sexual relationship with an underage
10
girl?
11
MS.
: Objection. Assumes facts
12
not in evidence.
13
BY MR. TEIN:
14
O.
You can answer the question.
15
A.
No.
16
O.
Does the Palm Beach Police Department know
17
that
is having a sexual relationship with an
Page 93
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18
underage girl?
19
: Don't guess. Answer if you
20
know.
21
THE WITNESS: Can you repeat the question?
22
BY MR. TEIN:
23
O.
24
that
25
Does the Palm Beach Police Department know
is having a sexual relationship with an underage girl?
110
1
A.
I'm guessing no.
2
O.
You lie about
, don't
3
you?
4
: Objection. Argumentative.
5
BY MR. TEIN:
6
O.
Don't you?
7
A.
No.
I have never lied for or to
8
O.
You lie about the fact that she has a s
9
drug habit, right?
10
A.
No.
I would never accuse
12
O.
Do you try to conceal the fact that she has
13
a drug habit?
14
: Objection. Argumentative.
15
BY MR. TEIN:
16
O.
You can answer the question_
17
A.
No.
18
O.
You lied when you went to
didn't you?
20
: Objection. Argumentative.
21
Lack of foundation, lack of predicate.
22
THE WITNESS: Never -- what did you say?
Page 94
EFTA00801968
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23
BY MR. TEIN:
24
Q.
You lied when you went
didn't you?
111
1
: Objection. Argumentative.
2
Lack of foundation, lack of predicate.
3
BY MR. TEIN:
4
Q.
You can answer the question.
5
A.
I have never been to
-
6
Q.
Who don't you lie to?
7
: Objection. Argumentative.
8
Don't answer the question.
9
MR. TEIN: Certify it.
10
CERTIFIED QUESTION
11
BY MR. TEIN:
12
Q.
You don't lie to
, do you?
13
: Objection. Asked and
14
answered.
15
Don't answer the question.
16
BY MR. TEIN:
17
Q.
No. You can answer that question.
18
: No.
I just told her not to.
19
You've asked that question about five --
20
MR. TEIN: No, I haven't.
21
: Don't answer the question.
22
MR. TEIN: I'll certify it.
23
CERTIFIED QUESTION
24
: For the record, you have to
25
stop interrupting me because she can't take down
Page 95
EFTA00801969
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112
1
both of us talking at the same time.
2
BY MR. TEIN:
3
O.
You tell
the truth, don't you?
4
A.
Excuse me?
You tell
the truth, don't you?
When it's
yes, I tell
the truth.
5
6
7
8
O.
A.
O.
A.
10
O.
Okay.
14
15
16
17
A.
0.
A.
0.
20
A.
I do remember that.
21
O.
Now before you massaged Epstein,
24
A.
1
A.
3
O.
4
so much, no
And you went there because you were lying
one could control you; isn't that correct?
Page 96
113
EFTA00801970
-0929104.TXT
5
A.
Very incorrect.
6
O.
Now you lie to your parents all the time,
7 don't you?
8
A.
Incorrect.
9
: Objection. Argumentative.
10
BY MR. TEIN:
11
O.
Sorry?
12
A.
Incorrect.
13
O.
The day you went to Epstein's house you
14
lied to your father about where you were going; isn't
15
that correct?
16
A.
Correct.
17
O.
You admitted to the police that you told
18
your father that you were going shopping, didn't you?
19
A.
Yes.
20
O.
And that was a lie, wasn't it?
21
A.
Yes.
22
O.
And isn't it true that your father has
23
accused you of lying?
24
A.
All the time.
25
O.
114
3
A.
Page 97
EFTA00801971
9104.TXT
15
: Objection. Lack of
16
foundation. Calls for speculation.
17
BY MR. TEIN:
18
O.
When your counsel coaches you, you say it's
19
correct, right?
20
A.
I've never been coached.
21
: Objection.
22
BY MR. TEIN:
23
O.
Okay. When your counsel that it was there
24
was lack of foundation, you agree with your counsel,
25
right?
115
1
A.
I was like saying, Yeah, let's move on,
2
because there was no point to asking that question_
3
O.
Your fathe
4
because she was lying, correct?
5
: Objection. Lack of
6
foundation.
7
Hold on,
. Let me just make the
8
objection.
9
Lack of foundation, predicate, calls for
10
speculation.
11
BY MR. TEIN:
12
O.
Answer.
13
A.
I'm not
I don't know.
Page 98
EFTA00801972
-0929104.TXT
14
15
16
17
18
O.
I want to know what you know only.
A.
I don't know.
O.
You don't know. That's your answer?
A.
Yes.
O.
Now
filed the police report
19
regarding Mr. Epstein, right?
20
A.
Yes.
21
O.
Now
are also lying, aren't
22
they?
23
A.
Yes.
24
: Just so the record is clear,
25
1
MR. TEIN:
116
Don't testify, Counsel.
2
: So the record is clear, the
3
4
MR. TEIN: Counsel, don't coach and
5
testify, please. That's absolutely improper.
6
: You just asked the wrong
7
question.
8
MR. TEIN: You can't coach her that way and
9
you well know it.
10
: For the record, it's the
11
13
MR. TEIN: You cannot -- it's absolutely,
14
totally against the rules and you know it.
15
17
MR. TEIN: You need to behave yourself,
Page 99
EFTA00801973
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18
lawyer.
19
The
21
MR. TEIN: Stop coaching. Stop talking.
22
You object. You know the rules. You just
23
lectured me about the rules, Counsel. So why
24
don't you play by the rules. Or only when they
25
fit you? Why don't you grandstand a little more
117
1
now. Give us a five-minute speech,
2
: Are you finished, for the
3
record.
4
MR. TEIN: I'm not talking to you. Do what
5
you want.
6
: Don't say anything yet.
7
BY MR. TEIN:
8
O.
9
: Hold it. Don't say anything
10
yet. Let me --
11
BY MR. TEIN:
12
O.
, who filed the police report
13
are also liars.
14
: Don't answer the question.
15
We're not going to answer until I make the record.
16
I want to put on the record, now that Counsel
17
appears to be finished with his comments for the
18
record, that the previous question was
19
inappropriate, was intentionally misleading.
20
Now you can ask the question.
21
BY MR. TEIN:
22
O.
who filed the police report
age 100
EFTA00801974
-0929104.TXT
23
24
25
in this case, are also proven liars, aren't they?
: Same objection.
BY MR. TEIN:
1
O.
Aren't
118
liars?
2
: Calls for speculation. Lack
3
of predicate.
4
MR. TEIN: Stop coaching. You know what
5
that is, Leopold.
6
: Calls for speculation. Lack
7
of foundation.
8
THE WITNESS: When you say
11
BY MR. TEIN:
12
23
Don't look to your lawyer for the answer.
24
: You can answer if you know
25
the answer to it.
I have no idea.
Page 101
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119
1
THE WITNESS: Yeah.
2
BY MR. TEIN:
11
12
13
O.
And you don't trust
, do you?
A.
Correct.
O.
And you believe he's trying to manipulate
14
you for his own gain, don't you?
15
A.
Sort of.
16
O.
Well, you know that
20
21
22
23
24
25
A.
Correct.
O.
You agree with that statement, don't you?
A.
Uh-huh. Yes.
O.
Do you trust your
A.
0.
120
2
A.
I would like to clarify something_ III
So I just
age
EFTA00801976
-0929104.TXT
5
don't trust her.
6
O.
Okay. You think that
9
A.
Yes.
25
MR. TEIN: Let's take a break.
1
2
BY MR. TEIN:
3
O.
4
121
(Thereupon, a recess was taken.)
, before you met Jeffrey Epstein have
you ever had sexual intercourse?
Page 103
EFTA00801977
-0929104_TXT
24
: Objection to the form of the
25
question.
1
3
BY MR. TEIN:
4
Q.
Before you met Epstein, had you ever had
5
oral sex?
6
A.
No.
7
Q.
Ever in your life, have you exchanged sex
8
for something of value?
9
A.
No.
10
MR. TEIN: We're done.
11
12
13
THE WITNESS: Oh, okay.
: We'll read.
MS.
:
I don't have any
age 104
122
EFTA00801978
-0929104.TXT
14
questions. Thank you.
15
: Before we go off the record,
16
it's my understanding -- Mr. Goldberger can
17
correct the record, but we have stipulated that
18
color copies of the documents that were identified
19
for identification certainly will be attached to
20
the deposition and counsel will be taking the
21
photographs across street so that they can be
22
laser color copied so that we have a copy, and I'm
23
assuming he'll get a copy to the court reporter,
24
too, to attach, actually a certified copy to the
25
deposition.
123
1
MR. GOLDBERGER: Done.
2
: That's if you agree to that.
3
If not, then I want to pull each one out and put
4
exhibit labels on them, which we should do before
5
we leave.
6
MR. GOLDBERGER: We're not going to do
7
either. I'll have copies sent to the court
8
reporter and she can attach them to the
9
deposition.
10
: So you're not going to agree
11
to what we talked about during the break then.
12
MR. GOLDBERGER: I'm not quite sure what
13
your asking me to do. Let me finish.
14
: Okay. Sure. That's fine.
15
MR. GOLDBERGER: Okay. If you want me to
16
go over to Ms.
office and make copies
17
and then I'll give those to the court reporter,
Page 105
EFTA00801979
-0929104.TXT
18
fine. All I'm saying is that I would avoid that
19
process.
I would send copies to the court
20
reporter. But if it will make you happier
21
: I'm not?
22
MR. GOLDBERGER: Let me finish.
23
: I'm not interrupting now.
24
MR. GOLDBERGER: But if it will make you
25
happier if I go over to Ms.
office
124
1
and make a copy of those photos that were part of
2
this deposition and then I'll give them to the
3
court reporter, I'll be happy to do it.
4
:
I trust you implicitly,
5
however you with to do it. However, the
6
documents, before they leave this room, need to
7
have an exhibit sticky on them with the
8
appropriate --
9
MR. GOLDBERGER: Want to go get some? We
10
don't have any.
11
:
I will do that. Excuse me.
12
Let me finish the record, please. You can't do
13
that to the court reporter. She's going to stroke
14
out. You can't do that. You have to let me --
15
MR. TEIN: Finish your sentence, III. You
16
are the most long-winded lawyer I've ever seen in
17
my life. Finish your sentence.
18
: Jack, tell him not to raise
19
his voice, please.
20
MR. TEIN: Finish your sentence. Is there
21
going to be a period at the end of the sentence or
22
is it just going to be comma after comma after
Page 106
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-0929104.TXT
23
24
25
comma?
Go ahead, lawyer.
: All right. The exhibits, I
125
1
can't prevent you from taking them, but I will
2
object and I will be bringing it to the court for
3
sanctions. You cannot take the exhibits out of
4
the room without them being marked.
I want them
5
marked, because you cannot identify in the record
6
what was used. And with all due respect to
7
Mr. Goldberger, I do not -- the way this
8
deposition is going, I do not want to rely on
9
Counsel from Miami to mark the appropriate
10
exhibits. I will not do that.
I cannot prevent
11
you from taking them. But if you do, I will be
12
bringing the matter to the court with appropriate
13
sanctions, because that is improper. That is
14
improper. When you use something in a deposition,
15
they are to be marked. And you have refused to do
16
that throughout for what ever reason.
17
MR. TEIN: You're wrong. Finish your
18
sentence because you're talking about something
19
you have no idea.
20
Every single one is marked, III. Every
21
single one is already marked. But you want to
22
argue about everything. Ever single one is
23
already marked. Isn't that silly, III,
24
MR. GOLDBERGER: Thirty years of doing this
25
and I have never had an argument over this.
Page 107
EFTA00801981
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126
1
MR. TEIN: You've made -- III, you are
2
obstructionist, you are a liar. You have lied and
3
misrepresented things, for the record. You are
4
grandstanding.
5
: You need to back up.
6
MR. TEIN: No, no. I'm going to finish.
7
: You can finish, but don't
8
hover over me.
9
MR. TEIN: No one is hovering over you.
10
Stop trying to make a lying record.
11
Let me say something else.
12
Don't you dare threaten me with sanctions,
13
after you lied in a letter to my co-counsel about
14
the fact -- be quiet. Be quiet and let me finish.
15
You lied in a letter to my co-counsel,
16
, in which you said -- it was a
17
complete and utter lie -- that you were
18
unavailable this morning because you had a
19
hearing. That was a lie.
I have never seen each
20
lawyer deign to do something like that.
21
So you will get the ex -- be quiet. Let me
22
finish. You behave.
23
: Don't point your finger at
24
me.
25
MR. TEIN: Listen. Be quiet and I won't
127
1
2
3
4
have a need to point it at you.
: Don't point your finger at --
MR. TEIN:
Don't point your finger at
Page 108
EFTA00801982
-0929104.TXT
5
me.
6
MR. TEIN:
, let me finish.
7
: Don't raise your voice
8
either.
9
MR. TEIN:
10
: Jack, do you want to take
11
care of this?
12
MR. TEIN: Let me finish my sentence. The
13
exhibits are marked. We are walking out of here.
14
You are someone who misrepresents the
15
record. It is absolutely atrocious what you do.
16
That is not how a lawyer should behave. This
17
deposition is over. You will get your exhibits,
18
19
MR. GOLDBERGER: I understand what you're
20
saying, Michael, and I understand
position.
21
Just so there's -- we're going to have lots
22
offer issues in this case. We're going to have
23
lots of reasons to disagree.
24
I'm going to take it over now and I'm going
25
to make copies and I'm going to give them to
128
1
Ms. Consor. If you want to go find some exhibit
2
labels and put some exhibit labels on it, be my
3
guest. But that's what I'm offering to do.
4
THE WITNESS: Let me say two things,
5
because I am happy to always disagree and with
6
you, I have no problem; we could always do it
7
professionally.
8
I want to say two things so the record is
Page 109
EFTA00801983
-0929104.TXT
9
very clear. Since for whatever reason I have not
10
been able to look at exhibits because they have
11
been refused to have been shown to me --
12
MR. TEIN: That's a lie.
13
: Jack, if you represent that
14
the documents have the appropriate exhibit numbers
15
or some identifying markings, 25, 30.000, whatever
16
they may be, then you can take them, make copies,
17
send me a copy, make sure the court reporter gets
18
a copy and then send me a bill for my copy, that's
19
fine. I didn't know that they are marked that way
20
because I haven't been able to look at them.
21
MR. GOLDBERGER: They are barcoded and the
22
number that we've made reference to in the
23
deposition coincides with the barcoding.
24
: That's fine. Eight by eleven
25
color laser copies are fine.
129
1
MS.
: The State Attorneys Office
2
is not going to charge anybody for color copies 1
3
print out.
4
: That's fine. He's going to
5
take them back to his office .
6
Secondly -- and I will be more than happy
7
to do it, because it sounds like you all know more
8
about it than I, but I'm happy to get affidavits
9
from
, everybody else about
10
what happened with this hearing today, because 1
11
know very little about it. But my representations
12
are what they are.
13
MR. GOLDBERGER: They stay --
Page 110
EFTA00801984
-0929104.TXT
14
: Let me just finish for the
15
record.
16
Representations or comments about what
17
happened, representation about this hearing this
18
morning, I know very little about it.
I --
19
MR. GOLDBERGER: I'll take your word on
20
that.
21
: No, no, no.
I just put it on
22
the record.
I will get an affidavit -- I'm
23
assuming it sounds like you need it -- from Mr.
24
.
I have no clue about what happened and
25
why it was canceled. All I was told when I was
130
1
out of town yesterday was that the hearing this
2
morning was cancelled.
3
MR. GOLDBERGER: I'll take your word for
4
it.
5
: If you want an affidavit,
6
I'll get it for you.
7
MR. GOLDBERGER: It's a personal issue for
8
me because I had to disrupt a vacation and if it
9
was done just because it wasn't convenient for
10
you, then I'm offended by that. But if you're
11
telling me that it was planned and it didn't
12
happen, I'll take your word for it.
13
:
I am more than happy to get
14
you an affidavit, because I don't know the reason
15
why it was canceled other than the fact that I'm
16
assuming since my deposition was taken for four
17
hours on Monday for preparation for the hearing
Page 111
EFTA00801985
-0929104.TXT
18
today, for whatever reason it was canceled, I am
19
told it is being re-noticed. Why it was canceled
20
I have no idea, but if your co-counsel wishes an
21
affidavit to that effect from
, I'm more
22
than happy to get it. But I don't know the reason
23
why it was canceled.
24
MR. TEIN: I don't need it. But what I do
25
take issue with is regardless of why it was
131
1
canceled, you owed us the courtesy of saying, you
2
know what? We can start earlier this morning.
3
:
I owe you nothing.
4
MR. TEIN: I don't care. Don't interrupt
5
me.
6
Because Jack canceled his vacation plans
7
because of you.
8
MR. GOLDBERGER: That's all right, that's
9
all right.
10
MR. TEIN: And you're selfish. And this
11
deposition is over. Good-by
12
MR. GOLDBERGER: You can go off the record.
13
14
15
16
17
18
19
20
21
22
Page 112
EFTA00801986
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23
24
25
132
1
CERTI
F ICATE
2
3
4
The State of Florida,
)
5
County of Palm Beach.
)
6
7
I hereby certify that I have read the
8 foregoing deposition by me given, and that the statements
9 contained herein are true and correct to the best of my
10
knowledge and belief, with the exception of any
11
corrections or notations made on the errata sheet, if one
12
was executed.
13
14
15
Dated this
day of
, 2008.
16
17
18
19
20
21
22
23
24
25
Page 113
EFTA00801987
-0929104.TXT
133
1
2 TO:
X
3 X
X, Florida X
4
IN RE:
CASENAME
5
CASE NO.: 2006 CF09454AXX
6
Please take notice that on Wednesday, the
DATE1 of [MONTN1], 2008, you gave your deposition in the
7
above-referred matter. At that time, you did not waive
signature. It is now necessary that you sign your
8
deposition.
A
Please call our office at the below-listed
9
number to schedule an appointment between the hours of
9:00 a.m. and 4:30 p.m., Monday through Friday.
10
AAs a professional courtesy, I am enclosing
a condensed copy of your deposition transcript.
11
A
As previously agreed to, the transcript
will be furnished to you through your counsel. Please
12
read the following instructions:
At Page A of the transcript, you will find
13
an errata sheet. As you read your deposition, any
changes or corrections that you wish to make should be
14
noted on the errata sheet, citing page and line number of
said change. DO NOT write on the transcript itself.
15
Once you have read the transcript and noted any changes,
be sure to sign and date the errata sheet and return
16
these pages. You need not return the entire transcript.
If you do not read and sign the deposition
17
within a reasonable time, the original, which has already
been forwarded to the ordering attorney, may be filed
18
with the Clerk of the Court. If you wish to waive your
signature, sign your name in the blank at the bottom of
19
this letter and return it to us.
Very truly yours,
20
21
Judith F. Consor, FPR
-
- tion
22
23
I do hereby waive my signature:
24
25
134
1
cc via transcript:
2
3
4
file copy
ER, Esquire
, Esquire
01.00
Esquire
Page 114
EFTA00801988
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5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
135
1
2
3
4
5
6
7
8
ERRATA
SHEET
IN RE: LOSE OF:
DEPOSITION OF:
DATE1, 2008
DO NOT WRITE ON TRANSCRIPT
PAGE #
LINE #
CHANGE
TAKEN: [IMONTH1]
- ENTER CHANGES HERE
REASON
Page 115
EFTA00801989
-0929104.TXT
9
10
11
12
13
14
15
16
17
18
19
20
21
Please forward the original signed errata sheet to this
office so that copies may be distributed to all parties.
22
Under penalty of perjury, I declare that I have read my
23 [!TYPE] and that it is true and correct subject to any
changes in form or substance entered here.
24
SIGNATURE OF DEPONENT:
25
136
1
THE STATE OF FLORIDA,
)
2
COUNTY OF PALM BEACH.
)
3
4
5
1, the undersigned authority, certify that
6
personally appeared before me on the DATE1
7 of [!MONTH1], 2008 and was duly sworn.
8
9
WITNESS my hand and official seal this DATE2
10
day of [!MONTH2], 2008.
11
12
13
Page 116
EFTA00801990
-0929104.TXT
14
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18
19
20
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22
23
24
25
Judith r7—Consor, rPR
Notary Public - State of Florida
137
1
CERTI
F ICATE
2
The State Of Florida,
3 County Of Palm Beach.
4
5
I, Judith F. Consor, Court Reporter and Notary
Public in and for the State of Florida at large, do
6
hereby certify that I was authorized to,
stenographically report the [!TYPE] of
7 that a review of the transcript was not reques
an
that the foregoing pages, numbered from 1 to A ,
8
inclusive, are a true and correct transcription of my
stenographic notes of said [!TYPE].
9
further certify that said [!TYPE ] was
10
taken at the time and place hereinabove set forth and
that the taking of said [!TYPE] was commenced and
11
completed as hereinabove set out.
12
1 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
DATED this DATE2 day of [!MONTH2], 2008.
Page 117
EFTA00801991
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18
19
20
21
22
23
24
25
Judith P7—Consor, Court Reporter
Florida Professional Reporter
Page 118
EFTA00801992
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Case 9:08-cv-80804-KAM
Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Flietit0A ()MO D.C. ELECT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN, [REDACTED - Survivor], and SARAH KELLEN, Defendants. NOTICE OF REMOVAL July 18, 2008 STEVEN M. LARIMORF CLERK D.S. DIST. CT. S.O. OF FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, Jeffrey Epstein, hereby remove this action' from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical lawsuit in this Court. See Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Ct. filed Mar. 6, 2008). Lewis "Fein 1059 044.444vEleuf Skim 340, E0coRuT Go
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Case 9:08-cv-80804-KAM
Case 9:08-cv-80804-KAM Document 14 Entered on FLSD Docket 08/22/2008 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a JANE DOE #1, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. EPSTEIN'S RESPONSE TO MOTION TO PRESERVE EVIDENCE [DE 121 Defendant Jeffrey Epstein hereby responds to the plaintiff Jane Doe's motion to preserve evidence, as follows: I. The Certificate of Compliance annexed to the plaintiffs motion states that plaintiff's "counsel conferred with counsel for [Mr. Epstein] . . . and [Epstein's] counsel advised that [Epstein] opposelS] this motion." DE 12 at 2 (emphasis added). That certification is inaccurate. 2. On August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the Lewis Tein law firm to elicit Epstein's position on this motion. Ms. Meyers responded that she would confer with Mr. Tein and call them back. Less than thirty minutes later, however, plain
4p
DOJ Data Set 9OtherUnknown
Case 9:08-cv-80804-KAM
Case 9:08-cv-80804-KAM Document 1-3 Entered on FLSD Docket 07/21/2008 Page 1 of 116 From ne Page 47/51 Date. 5/29/2008 12 09 L' • Si esta responder u la demanda per su cueille, al mismo tiempo en que prise= su respucsta ante il tribunal, debeni ustett envier por comme o entregar une copia de su rapueste a la persona denominada abaju corne "PlaintifUPlaintiffs Attorney" (Demandante o Abogado del Demandante). "De acuerdo con el Acto 6 Decreto de los Ameriennsos con Impedirnentos, inhabilitados, persona.; en necesidad del servicio special para panicipar en este procedimiento deberin, dcntm de un 'derme rezonable, antes de cualquier proœdimicnto, ponerse en contacto con is officine Administratutiva dc la Cone, 205 North Dixie Highway, oficina 52500, West Palm Beach, FL 33401, Téléfono (561) 355-2431, 1-800-955-8771 (I'DD) 6 1-800-955-8770 (V), Via Floride Relay Service". pv1FOR'FANT Des poursuites judiciaires ont etc entreprises contre vous. Vous avez 20 jours ormsecu
116p
DOJ Data Set 9OtherUnknown
ROY BLACK
ROY BLACK HOWARD M. SREBNICK SaYIT A. KORNSPAN LARRY A. STUMPY? MARIA NEYRA JACKIE PERCZEK MARK A.J.lAPIRO JARED BLACK SREBNICK KORNSPAN STUMPF P.A. May 18, 2010 VIA EMAIL AND U.S. MAIL Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 RE: Jeffrey Epstein Dear Counsel: JESSICA FONSECA-NADER KATHLEEN P. PHILLIPS AARON ANTHON MARCOS BEATON, JR. JENIPER J. SOULUCIAS NOAH FOX JOSHUA SHORE E-Mail: RBlack(lfioyBlack.com Jeff Sloman, Esq. United States Attorney 99 N.E. 4th Street Miami, FL 33132 Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 We received notice this morning that Podhurst Orseck, P.A. has filed a civil complaint seeking over $2,000,000 in addition to the $526,000 they have already been paid by Jeffrey Epstein for their work as attorney representatives. As we communicated to you during our February 3, 2010
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DOJ Data Set 9OtherUnknown
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 y
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DOJ Data Set 9OtherUnknown
CM/ECF - Live natabase - flsd
CM/ECF - Live natabase - flsd Page 1 of 6 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80804-KAM Doe v. Epstein et al Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson ' Case in other court: 15th Judicial Circuit, 50 2008 CA 006596 Cause: 28:1331 Federal Question CLOSED, L1RJ Date Filed: 07/18/2008 • Date Terminated: 10/03/2008 Jury Demand: Plaintiff Nature of Suit: 890 Other Statutory Actions Jurisdiction: Federal Question Plaintiff Jane Doe represented by Spencer Todd Kuvin Ricci Leopold 2925 PGA Boulevard Suite 200 Palm Beach Gardens , FL 33410 Defendant Jeffrey Epstein Fax: 515-2610 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Theodore Jon Leopold Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens , FL 33410 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Guy Alan Lewis Lewis Tein 3059 Grand Avenue Suite 340 Coconut Gr
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