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+![](_page_0_Picture_1.jpeg)
+
+sor & Associates Repornng and Transc ripen. Inc
+
+1 2 Q. Because Mr. Epstein never came to your dad's house, correct?
+
+3 A. Correct.
+
+4 5 Q. And no one who worked for Mr. Epstein ever did something to your dad's tires, did they?
+
+6 7 MR. LEOPOLD: Objection. Lack of foundation, predicate.
+
+8 Don't guess.
+
+9 BY MR. TEIN:
+
+10 11 Q. It's not true that Mr. Epstein almost killed your father, is it?
+
+12 13 MR. LEOPOLD: Objection. Asked and answered, lack of foundation, predicate.
+
+14 BY MR. TEIN:
+
+15 0. You can answer.
+
+16 A. No.
+
+17 18 19 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?
+
+20 A. Yes.
+
+21 Q. And that was {sup}`a`lie, wasn't it?
+
+22 A. It's the truth.
+
+23 24 25 Q. You told the police that there was someone in the car next to you and you specifically said you didn't know her name, right?
+
+Page 75
+
+![](_page_1_Picture_1.jpeg)
+
+nsor & Associates Reporting and Transcription, Inc
+
+Page 76
+
+ A. Correct. I do not know her name.
+
+ was dark like a Spanish girl." Those were your words, right? Q. You said, "I don't know her name, but she
+
+
+MR. LEOPOLD: Objection. Asked and answered.
+
+
+Q. Who was in the car that day with you and 
+
+A. Again, I do not know.
+
+Q. It was your good friend wasr't it?
+
+A. No. I don't know {sup}`a`
+
+Q. You lied to the police about who was in the car with you and el , didn't you?
+
+A. Incorrect.
+
+Q. Let me ask you some questions about who you may have spoken to about this case. All right?
+
+A. Go ahead.
+
+Q. Did you speak to your twin sister .
+
+A. Not in detail, but of course she knows; she's family. And yes.
+
+Q. What's her e-mail?
+
+A. I don't think she has an e-mail.
+
+![](_page_2_Picture_1.jpeg)
+
+Page 77
+
+1 Q. What is her phone number?
+
+2 A. gosh. I don't know off the top of my 3 head.
+
+4 Q. And what is her home address?
+
+5 A. She lives with my mom.
+
+6 Q. In Georgia?
+
+7 A. Yes, sir.
+
+8 Q. What about boyfriend IIII? Did you 9 speak to him about Epstein's case?
+
+10 A. That's my mom's boyfriend. My sister 11 doesn't have a boyfriend. My mom's husband's name is 12 so maybe you get them confused.
+
+13 Q. Do you know his phone number?
+
+14 A. No.
+
+15 Q. Where does he live?
+
+16 A. With my mom.
+
+17 Q. In the same house with her?
+
+18 A. Yes. They're married.
+
+19 Q. So not boyfriend; husband?
+
+20 A. Yeah, husband.
+
+21 Q. Have you spoken to about 22 what happened in Mr. Epstein's house?
+
+23 A. Not in detail, but he knows the basics, 24 yes.
+
+25 Q. What is his e-mail?
+
+7 A. I don't know.
+
+8 Q. Where does he live?
+
+9 A. In Palm Beach Lakes somewhere.
+
+![](_page_3_Picture_1.jpeg)
+
+sor & Associates Kellam op and Tranncrip ion, Inc
+
+Page 78
+
+{sup}`1`A. I don't know.
+
+{sup}`2`Q. What is his phone number?
+
+{sup}`3`A. How is that relevant?
+
+{sup}`4`Q. What is his phone number?
+
+{sup}`5`A. 561.719.2652.
+
+{sup}`6`Q. What is his home address?
+
+10 Q. Ever been to his house?
+
+11 A. Yes.
+
+12 Q• You don't know what his address is?
+
+13 14 MR. LEOPOLD: Objection. Asked and answered. She just said she doesn't know.
+
+15 MR. TEIN: Don't coach.
+
+16 17 MR. LEOPOLD: Objection. Asked and answered.
+
+18 BY MR. TEIN:
+
+19 Q. You can answer the question.
+
+20 A. I don't know the exact address.
+
+21 Q. What street is it on?
+
+22 23 street. A. It's an apartment complex; its not {sup}`a`
+
+{sup}`24`Q. What's the name of the apartment complex?
+
+{sup}`25`A. Something Cove.
+
+![](_page_4_Picture_1.jpeg)
+
+ Q. How about to him about your case? Have you spoken
+
+ A. No. We no longer speak.
+
+ Q. What's his phone number? Actually, we already have his phone number and e-mail.
+
+ Q. What apartment number is it?
+
+ A. I couldn't tell you. Page 79
+
+Q. When was the last time you went there?
+
+A. Just visited this past weekend. That's the first and last time I went there.
+
+How about MEW Have you ever spoken to her about your case?
+
+A. I don't know an
+
+Q. 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 {sup}`I` couLd tell you.
+
+Q. All right. Let me see if I can refresh your memory.
+
+A. Okay.
+
+Q. Does it refresh your memory that is the other girl who made allegations about Epstein, but refused to show to the Grand Jury when she had to testify about them under oath?
+
+A. No, sir. I have no knowledge of any other
+
+![](_page_5_Picture_1.jpeg)
+
+nsor & Associates Repnning and Transcriptsco, Inc.
+
+Page 80
+
+girls in this whole situation. We're not allowed to know each other.
+
+Q. I didn't get the last four words.
+
+A. We're not allowed to know each other.
+
+Q. And what about Have you of met her?
+
+
+Q. Let's see if I can refresh your memory on her. She's the other person represented by your lawyer Mr. Herman, who is suing Epstein for fifty million dollars.
+
+A. I have no knowledge of her.
+
+Q. Never met her?
+
+A. Never met her.
+
+Q.
+
+UMW
+
+A. I don't know who that is either.
+
+Q. A person named who knows .
+
+Is that
+
+A. I don't know, sir.
+
+Q. Do you remember making astatement to Detective Pagan that's in the police reports?
+
+
+Q. Have you read the police reports in this case?
+
+
+![](_page_6_Picture_1.jpeg)
+
+nsor & Associates aoportinp anil Transcription. Inc
+
+ Q. They're on the Internet, right?
+
+ A. Yes, I think.
+
+ Q. Were you surprised when the police reports were released on the Internet containing your statements that you had made to the police?
+
+
+ Q. You didn't want to see that happen, right?
+
+
+O. So you're saying you don't know {sup}`a`
+
+Page 81
+
+ MR. LEOPOLD: Objection. Asked and answered.
+
+
+Q. Does it refresh your memory that he was somebody who had gone to jail for drugs and car theft?
+
+
+O. Someone who knows
+
+
+Q. You don't know if he met with Detective Recarey?
+
+
+Q. How about
+
+A. Yes, I remember. I know who that is.
+
+Q. Did you ever speak to about what happened at Mr. Epstein's house?
+
+![](_page_7_Picture_1.jpeg)
+
+nsor & Associates Reponing and Transcript' cch.
+
+Page 82
+
+1 A. He knows what happened four years ago. He 2 doesn't know this is still going on today.
+
+3 Q. What's his address? I'm sorry. I have his 4 address.
+
+5 A. I don't know.
+
+6 Q. How about 1111111111
+
+7 A.
+
+8 Q. You know who that is?
+
+9 A. I know who that is, yes.
+
+10 Q. He's the one you stayed out drinking all 11 night one night last year when your dad reported you 12 missing?
+
+13 A. No, sir.
+
+14 Q. Remember the baseball game you were 15 supposed to go to?
+
+16 A. No, sir.
+
+17 Q. Did you speak to about this 18 case?
+
+19 A. No, sir.
+
+20 Q. How about
+
+21 A. That's my sister's ex-boyfriend.
+
+22 Q. He's the one with the sawed-off shotgun 23 with the obliterated serial number?
+
+24 A. Ask him. I would not know that 25 information.
+
+![](_page_8_Picture_1.jpeg)
+
+nsor & Associates ReptirtIllf, and iiartscal rum. Inc
+
+Page 83
+
+Q. Did you speak to about this case?
+
+
+Q. Have you spoken to alliffira bout this case?
+
+A. No. I don't know who is.
+
+Q. Did your parents speak to IMMilr
+
+A. Ask my parents.
+
+0. Let's see if I can refresh your memory as to who he is. Okay?
+
+A. Uh-huh.
+
+Q. He's the Vanity Fair reporter who made {sup}`a` financial arrangement with your father.
+
+A. I am aware of that. And again, {sup}`I`was not aware like that my dad did it until after it was done. And I don't know the details about that. I just know what you know about that, like that they talked.
+
+Q. Tell me what you know about the financial arrangement that the Vanity Fair reporter, made with your father.
+
+A. I don't know about the details at all.
+
+Q. How much money did MOM give to your father?
+
+A. I don't even know he gave money to my dad.
+
+Q. I'm sorry?
+
+![](_page_9_Picture_1.jpeg)
+
+sor & Associates :tenor:ens and Transcription, lac
+
+Page 84
+
+1 A. I didn't even know he gave money to my dad.
+
+2 Q. What do you know about the deal that Mr 3 has with your father?
+
+4 A. I only know they spoke on the telephone 5 once. I don't know anything else.
+
+6 Q. When was that?
+
+7 A. This was a while ago, a year or two or a 8 year ago. I honestly don't know.
+
+9 Q. Did MEW the Vanity Fair 10 reporter, offer any money to your father?
+
+11 A. I don't know.
+
+12 Q. Did a the Vanity Fair 13 reperter, give you any money?
+
+14 A. No, sir.
+
+15 Q. Did he offer you any money?
+
+16 A. No, sir. Never spoke to him.
+
+17 Q. what reporters have you spoken to?
+
+18 A. Zero.
+
+19 Q. What about your family members? What 20 reporters have they spoken to?
+
+21 A. The whole Palm Beach County, obviously, as 22 you can see in that newspaper.
+
+23 Q. Tell me -- let's go through each one that 24 you remember. Other than the Vanity Fair reporter,
+
+25 what other reporters have any member of your
+
+![](_page_10_Picture_1.jpeg)
+
+sor & Associates Roporunp end Transcription, Inc.
+
+1 family spoken to?
+
+2 3 4 5 A. I don't know. And I know my mom has spoken to zero. My sister spoke to zero. My father and steomother, I wouldn't know. You'd have to ask them. {sup}`I` don't contact them.
+
+6 7 Q. Well, I just want to know -- I don't want you to -- I want to know what's in your mind. All right?
+
+8 9 MR. LEOPOLD: She just told you. She just answered --
+
+10 MR. TEIN: Be quiet.
+
+11 BY MR. TEIN:
+
+12 13 14 15 Q. What I want to know is what you know from your personal knowledge. My question to you is: What knowledge do you have about family members of yours speaking to reporters?
+
+16 17 MR. LEOPOLD: Objection. Asked and answered.
+
+18 19 And if you can't talk professionally, we're going to leave.
+
+20 MR. TEIN: Do what you want to do.
+
+21 22 MR. LEOPOLD: Are you going to continue to talk this way?
+
+23 24 MR. TEIN: I'm not going to answer any question that you ask me, Mr. Leopold.
+
+25 MR. LEOPOLD: Okay. Page 85
+
+![](_page_11_Picture_141.jpeg)
+
+Censor & Associates  
+Reporting and Transcription, Inc.
+
+Page 86
+
+1 MR. TEIN: But you are misrepresenting the  
+2 record and you are grandstanding for your client  
+3 and it's wrong. So be quiet. And you know how to  
+4 make an objection. Make it. Otherwise stop  
+5 talking.
+
+
+7 Q. [REDACTED] --
+
+8 MR. LEOPOLD: Excuse me.
+
+9 MR TEIN: If you want to leave the  
+10 deposition, leave. But you'll be back here.
+
+11 MR. LEOPOLD: Excuse me. If I could just  
+12 make the record, instead of interrupting me,  
+13 please. That's what we do professionally.  
+14 There's a recorder here. I'm certainly not being  
+15 obstructionist. I'm going to make the record.  
+16 But we're going to act with some semblance of  
+17 professionalism, hopefully, by all parties in the  
+18 room. That goes to me, that goes to your  
+19 co-counsel sitting behind you and next to you, the  
+20 court reporter and everyone else in the room.  
+21 Everyone is entitled to that.
+
+22 You've asked a question. She answered the  
+23 question fully and she's not going to be harassed  
+24 because you don't like the answer. If you want to  
+25 follow up --
+
+![](_page_12_Picture_1.jpeg)
+
+te nsor & Associates Repnnt ng and lunsen mina. Inc
+
+Page 87
+
+1 MR. TEIN: Stop engaging me. Make your 2 speech and then we'll ask the questions.
+
+3 MR. LEOPOLD: Well, you won't let me finish 4 making the objection, so it's difficult to do 5 that. But if you want to follow with an 6 appropriate question, feel free to do that. But 7 we're not going to harass the witness.
+
+8 MR. TEIN: I disagree with everything 9 you've said. Let's ask the questions. Okay?
+
+10 MR. LEOPOLD: Ask an appropriate question.
+
+11 MR. TEIN: Are you going to stop talking?
+
+12 MR. LEOPOLD: I'm going to make -- protect 13 my client and make appropriate objections. But 14 there's not a question pending right now.
+
+
+16 Q. IIIIIIIhasillispoken to any reporters?
+
+17 A. No.
+
+18 MR. LEOPOLD: Objection. Asked and 19 answered.
+
+20 BY MR. TEIN:
+
+21 Q. Has been given money by any 22 reperters?
+
+
+24 Q. Has your mom spoken to any reporters?
+
+25 MR. LEOPOLD: Objection. Asked and
+
+![](_page_13_Picture_1.jpeg)
+
+Page 88
+
+1 answered.
+
+2 THE WITNESS: No.
+
+3 BY MR. TEIN:
+
+4 Q. Has your mom's husbandllillspoken to any 5 reporters?
+
+6 A. No.
+
+7 Q. Has your mom's husband IIIIIIreceived any 8 money from reporters?
+
+9 A. No.
+
+10 Q. Are you sure you don't know NW
+
+11 MR. LEOPOLD: Objection. Asked and 12 answered.
+
+13 THE WITNESS: I'm positive.
+
+14 BY MR. TEIN:
+
+15 Q. I'll try again to refresh your memory.
+
+16 A. Okay.
+
+17 Q. Does it refresh your memory that she had 18 been arrested for drugs and was cooperating with 19 Detective Recarey against Epstein to get herself a better 20 deal?
+
+21 A. No. I don't know who she is.
+
+22 Q. Have you spoken to anyone else who's been 23 at Epstein's house?
+
+
+25 0. Without telling me what was said -- I don't
+
+![](_page_14_Picture_1.jpeg)
+
+nsor & Associates Steporunp and lrenscripcion, Inc
+
+1 wart to know about any conversations with any lawyers, 2 okay --
+
+3 A. Uh-huh.
+
+4 0. did you or your parents speak to any 5 other law firms besides Mr. Herman and Mr. Leopold's law 6 firms?
+
+7 A. No.
+
+8 Q. Now without telling me about anything that 9 was said, what -- did one just come to mind?
+
+10 A. No. I was thinking about something else.
+
+11 Q. What were you thinking about?
+
+12 A. Does family court matter?
+
+13 Q. Okay. Without telling me what was said, 14 who prepared you for today's deposition?
+
+15 A. What do you mean prepared?
+
+16 Q. Did you talk about this deposition, about 17 what would happen, with anybody?
+
+18 A. Yes.
+
+19 Q. Don't tell me what was said.
+
+23 A. Okay.
+
+21 Q. I'm not asking that. I don't want to know 22 that.
+
+23 A. Okay.
+
+24 Q. Who prepared you for today's deposition?
+
+25 A. Mr. Leopold.
+
+![](_page_15_Picture_1.jpeg)
+
+nsor & Associates fteparrinp and Transcription. Inc
+
+Page 90
+
+1 Q. Anybody else?
+
+2 A. No.
+
+3 Q. When did you meet with Mr. Leopold to 4 prepare for today's deposition?
+
+5 A. This morning.
+
+6 Q. And how long did that meeting last?
+
+7 A. Until it started.
+
+8 Q. Now you told me that you previously had 9 read the police reports in this case?
+
+
+11 Q. Have you read your statement that you gave 12 to the police?
+
+13 A. Yes, sir.
+
+14 Q. And in what form was that statement?
+
+15 A. What do you mean?
+
+16 Q. Was it in the form of a police report or a 17 transcript?
+
+18 A. What's the difference?
+
+19 Q. A transcript has questions and answers on 2) it. A police report is just typed out narrative.
+
+21 A. II, it's a police report.
+
+22 Q. And when did you read the police report?
+
+23 A. A few days ago. I overread it a few days 24 ago.
+
+25 Q. Had you read it before that?
+
+![](_page_16_Picture_1.jpeg)
+
+
+5 6 this morning to prepare for your deposition, right? Q. You told me that you met with Mr. Leopold
+
+7 A. Yes.
+
+8 Q. When did you set up that meeting with 9 Mr. Leopold to take place this morning?
+
+10 11 ago. A. Gee, like, like five days ago, four days
+
+12 Q. So you're aware that Mr. Leopold told us 13 that he could not start the deposition this morning 14 because he had a court appearance, correct?
+
+15 MR. LEOPOLD: Don't answer that question.
+
+16 Calls for attorney/client communications.
+
+17 BY MR. TEIN:
+
+18 Q. Have you seen the letter that Mr. Leopold 19 wrote to us stating that he -- an e-mail that Mr. Leopold 20 wrote to Mr. Goldberger stating that he could not be here 21 22 this morning because he had a court appearance? Did you see :hat e-mail?
+
+23 MR. LEOPOLD: You can answer that question.
+
+24 THE WITNESS: No.
+
+25
+
+2 Q. Now you told me again, I don't want to 3 know what was said.
+
+4 A. Uh-huh.
+
+![](_page_17_Picture_1.jpeg)
+
+
+2 Q. Have you listened to your tape-recorded 3 statement to the police?
+
+4 A. Yes.
+
+5 Q. Where did you listen to that?
+
+6 A. In, I think, this building. I don't know.
+
+7 It was here.
+
+8 Q. When did you listen to that statement?
+
+9 A. This morning.
+
+10 Q. And who was present when you listened to 11 that statement?
+
+12 A. Mr. Leopold -- and I forget your name.
+
+13 MR. GOLDBERGER: Ms. Belohlavek.
+
+14 THE WITNESS: Ms. Belohlavek.
+
+
+16 Q. And you hadn't listened to your statement 17 before that, correct?
+
+18 A. No, sir.
+
+19 Q. Have you met with lawyers representing 20 anyone else suing Epstein?
+
+21 A. No, sir.
+
+22 Q. How many times have you spoken to officers 23 with the Palm Beach Police Department?
+
+24 A. More than I like can count. It's been 25 ongoing for four years, so quite a few times.
+
+![](_page_18_Picture_1.jpeg)
+
+nsor & Associates
+
+Ropnrtinp mid Transcription, Inc
+
+Page 93
+
+1 Q. When was the last time you spoke with officers of the Palm Beach Police Department?
+
+A. A while ago. I'd say a year ago.
+
+Q. A year ago?
+
+A. Yeah. Maybe a year and a half.
+
+Q. Do you remember Detective Recarey?
+
+
+Q. Do you remember Pagan, Detective
+
+Pagan?
+
+
+11 Q. How many times have you spoken to Detective
+
+Pagan?
+
+A. She was the only one I spoke to about this until for some reason she wasn't on the case anymore.
+
+Q. When was that?
+
+A. The first meeting I ever had was with her and then I think like I met with her like 10 times or 12 times or something like that, and then I didn't get another investigator questioned me after that.
+
+Q. And who was that?
+
+A. I don't remember.
+
+Q. And what type of questions did they ask you?
+
+A. The same.
+
+Q. The same questions all over again?
+
+![](_page_19_Picture_1.jpeg)
+
+nsor & Associates itepornng and Transcii poem. Inc
+
+1 A. I'd have to say like a year and a half ago, 2 a year ago. It was a long time ago.
+
+3 (Discussion held off the record.)
+
+4 MR. TEIN: Tell me the last answer, please.
+
+5 (Thereupon, a portion of the record was read 6 by the reporter.)
+
+7 BY MR. TEIN:
+
+8 Q. And who was present when the FBI spoke to 9 you at your father's house?
+
+10 A. My stepmother was there, but she wasn't 11 around. She made herself like do other things.
+
+12 Q. And how many FBI agents were there?
+
+13 A. I think four.
+
+i4 Q. And you don't remember any of their names?
+
+15 A. No, sir.
+
+16 Q. And were there any lawyers there?
+
+17 A. Not that I know of.
+
+18 Q. And none of them gave you their cell phone 19 numbers?
+
+20 A. No.
+
+21 Q. And the last time you spoke to the FBI was 22 a year and a half ago?
+
+23 A. It was a while ago.
+
+G4 MR. LEOPOLD: Objection. Asked and 25 answered.
+
+![](_page_20_Picture_1.jpeg)
+
+
+Q. And the last time you spoke to the federal prosecutor's office was when?
+
+A. I don't know.
+
+4. Elm Villafona had spoken with Mr. Leopold? Did any of the FBI agents tell you that
+
+
+Q. Did any of the FBI agents tell you that I'll' Villafona had spoken with Mr. Herman?
+
+
+Q. Slonan spoke with Mr. Herman. Did any FBI agents tell you that Jeff
+
+
+Q. Sloran spoke with Mr. Leopold? Did any FBI agents tell you that Jeff
+
+
+Q. Do you know whether any of the federal prosecutors allowed Mr. Herman to review adraft indictment?
+
+A. I wouldn't know.
+
+Q. prosecutors discussed adraft indictment with Mr. Herman? Do you know if any of the federal
+
+A. I wouldn't know.
+
+Q. Have you ever {sup}`e`-mailed with any FBI agent or any federal prosecutor?
+
+![](_page_21_Picture_1.jpeg)
+
+
+2 Q. Have you ever text messaged with any FBI 3 agent or any federal prosecutor?
+
+4 A. No.
+
+5 Q. Has the FBI told you about other testimony?
+
+6 A. No.
+
+7 Q. Has the FBI told you about what other girls 8 have said?
+
+9 A. No.
+
+10 Q. Have federal prosecutors told you what 11 other girls have said?
+
+12 A. No.
+
+13 Q. Do you have any way of getting in touch 14 with the FBI if you wanted to get in touch with them?
+
+15 A. No.
+
+16 Q. How about your parents? Do they know how 17 to get in touch with the FBI?
+
+18 A. I don't know.
+
+19 Q. And by your parents, I'm referring to both 20 sets, okay?
+
+21 A. U. Well, I'm referring to only my dad, 22 because my mom really doesn't care to know any of this 23 stuff.
+
+24 Q. So the answer would be the same for your 25 mom and
+
+![](_page_22_Picture_1.jpeg)
+
+1 A. Yeah.
+
+2 Q. Have you spoken to a lawyer named Burt
+
+3 Ocariz about this case?
+
+4 A. No.
+
+5 Q. Do you know who Burt Ocariz is?
+
+6 Let's see if I can refresh your memory.
+
+7 Does it refresh your memory that he's a good friend of
+
+8 Villafona's boyfriend?
+
+9 A. I don't know who Villafona is.
+
+10 11 Q. Villafona is the lead federal prosecutor that's on the federal part of this case.
+
+12 Okay?
+
+13 A. No.
+
+14 15 Q. So does it refresh your memory that Ocariz is the good friend of Villafona's boyfriend?
+
+16 A. Not at all.
+
+17 18 19 Q. Does it refresh your memory that Villafona tried to get Epstein to pay for Ocariz to represent you in the federal case?
+
+20 A. No.
+
+21 '22 Q. Do you know if Detective Recarey has spoken with your father?
+
+
+24 25 Q. Do you know if Detective Recarey has spoken to your stepmother?
+
+![](_page_23_Picture_1.jpeg)
+
+1 2 First off, this is not a warehouse. This is in a garage.
+
+3 Second of all, I'm not being gang-raped. 4 Everyone has their clothing on.
+
+Page 100
+
+5 6 pictures in that album, I'm drinking -- what's 7 when you're sick you drink it? Thirdly, if you'd look at all the other
+
+8 BY MR. TEIN:
+
+9 Q. You can't ask questions of your counsel.
+
+10 A. All right. I'm drinking like Sprite. I'm 11 not drinking any kind of alcohol, if you would look at my 12 other pictures in that album.
+
+13 14 out of there to present. And it was just a goofy 15 picture. All of these kids like to be goofy. And that's You guys picked the possibly worst pictures 16 what we were doing.
+
+17 O. Who's the man on the left of the picture 28 holding his -- holding a beer bottle as if it were a 19 pen:.s towards your mouth?
+
+20 A.
+
+21 Q. Who's the man behind you, right up towards 22 your backside, with you bent over?
+
+23 A. That one?
+
+24 Q. The right side, kissing with his mouth.
+
+25 A. That's
+
+![](_page_24_Picture_1.jpeg)
+
+1 Q. He's the one grabbing towards the groin 2 area of
+
+3 A. Yes.
+
+4 Q. And there's three other men in the photo.
+
+5 What are their names? The one on the left with the hat?
+
+6 A. That's (phonetic).
+
+7 Q. Smiling?
+
+8 A. Yes.
+
+9 Q. Who's the one kissing --
+
+10 MR. LEOPOLD: Don't interrupt. Let her 11 finish the record. She's testifying.
+
+12 MR. TEIN: I know you don't like this 13 picture, my friend.
+
+14 MR. LEOPOLD: The picture is fine.
+
+15 BY N.R. TEIN:
+
+16 Q. Who's the one with the hat?
+
+17 MR. LEOPOLD: No. Hold on. Stop,
+
+18 You have to let the witness finish her 19 answer. She was in the process of explaining and 20 you cut her off.
+
+21 Please finish what you were saying and then 22 Counsel can ask you whatever he wishes after that.
+
+23 THE WITNESS: Okay. This guy --
+
+24 MR. LEOPOLD: Just make it so the record is 25 clear who you're referring to.
+
+![](_page_25_Picture_1.jpeg)
+
+1
+
+2
+
+3 BY MR. TEIN:
+
+4 Q. He's the one whose head is near the groin
+
+Page 102
+
+THE WITNESS: -- on the far left is OE
+
+a
+
+5 of IIIIIIIIIIIIIIIIright?
+
+6 A. Yes.
+
+7 Q. And in the middle there's a man smiling.
+
+8 who's that?
+
+9 A. That's
+
+10 Q. And who's the one in the red hat, kissing?
+
+11 A. That's (phonetic).
+
+12 Q. Let me stop you for a second. Are you
+
+13 done?
+
+14
+
+15
+
+16
+
+A. Yes, I'm done.
+
+Q. Who is
+
+A. My sister's friend. Well, she's a mutual
+
+17 friend, but more my sister's.
+
+18 Q. What is her last name?
+
+19 A.
+
+20 Q. Spell that.
+
+21 A. I don't know how to --
+
+22 Q. Have you spoken to her about this case?
+
+
+24 Q. Who's
+
+25 A. My sister's friend. I don't really speak
+
+![](_page_26_Picture_1.jpeg)
+
+1 to him at all.
+
+2 0. What's his last name?
+
+3 A.
+
+4 Q. WNW
+
+5 A.
+
+6 Q. And have you spoken to =about this
+
+7 case?
+
+8 A. No, sir.
+
+9 Q. Have you spoken to about this case?
+
+10 A. Not in detail, but yes.
+
+11 MS. BELOHLAVEK: Are we referring to
+
+12
+
+13 THE WITNESS: Yes.
+
+14 MR. TEIN: Yes.
+
+15 MS. BELOHLAVEK: Okay.
+
+16 BY MR. TEIN:
+
+17 Q. Have you spoken to =about this case?
+
+{sup}`18`A. win?
+
+19 Q. Do you have a friend named
+
+20 A. I do not have a friend named
+
+21 Q. From freshman year?
+
+22 A. No.
+
+23 Q. How about Or
+
+
+25 Q. Have you spoken to about this case?
+
+![](_page_27_Picture_1.jpeg)
+
+
+2 Q. What's her last name?
+
+3 A. I don't know how to spell it.
+
+4 5 Q. Is she the person whose house you went to on New Year's this year?
+
+6 A. No. I wasn't at her house on New Year's.
+
+7 8 Q. Where were you when you took the picture of "Can you say blazed," that's on your website?
+
+9 10 A. I wouldn't know or -- wait. We were at a birthday party for some girl's 16th birthday.
+
+11 Q. Were you drinking at that party?
+
+12 13 A. No. There was no alcohol or anything there.
+
+14 Q. What does "blaze" mean to you?
+
+15 16 A. It's like -- it just means like messed up. But we weren't, if you look at the picture.
+
+17 Q. Messed up like drunk, right?
+
+18 A. Sure.
+
+19 Q. Who's
+
+20 21 A. A girl I know, like from like two years ago.
+
+22 23 Q• She's the one you were supposed to be staying with when you went drinking with OMR
+
+
+25 Q. What's last name? Page 104
+
+![](_page_28_Picture_1.jpeg)
+
+nsor & Associates Reporting and Transcription, Inc
+
+1
+
+2
+
+3
+
+4
+
+A.
+
+Q. live? Where does she
+
+A. In Palm. I don't know.
+
+Q•
+
+5 A. Uh-huh. I'm guessing.
+
+6 Q. Do you know her phone number?
+
+7 A. No, I do not.
+
+8 Q. Let's look at 25-010.
+
+9 A. See, I'm drinking --
+
+:0 Q. I'm not asking you about what you're
+
+11 drinking.
+
+12 Who are the men in this photo who are 13 pretending to gang up on you and stab you with knives? 14 who are they?
+
+15 A. and
+
+16 Q. Are these firemen?
+
+17 A. Are those? . -- he said the
+
+18 two stabbing with knives. That's why I said that. I 19 don't know. That's and
+
+20 Q. Are these firemen?
+
+21 A. No. They're all on -- except
+
+22 they're all on full rights for football.
+
+23 Q. Go to 025-015.
+
+24 MR. LEOPOLD: 025 dash?
+
+25 MR. TEIN: 015.
+
+![](_page_29_Picture_1.jpeg)
+
+Page 106
+
+THE WITNESS: Gosh, that's so long ago.
+
+
+Q. Who took the photo of you licking the penis?
+
+A. My stepmother.
+
+Q. Whose idea -- that was your stepmother's idea?
+
+A. It was in Buca di Beppo, where she works currently, and that was before she worked there. And we just thought it would be funny.
+
+MR. TEIN: 19-007. Can you enlarge that?
+
+
+Q. Who took this photo of you simulating you having sex with aman?
+
+A. We're not simulating having sex, and it's -- II, and the person who took it was, I'm pretty sure, =out I know him as Mg I don't know his last name.
+
+Q. Go to 19-006, please. Who took this photo of you simulating sex with aman?
+
+A. The same person. And we're not simulating having sex, Mr. --
+
+Q. Tein.
+
+Did you post that on the Internet?
+
+![](_page_30_Picture_1.jpeg)
+
+1 A. Actually, this is an old MySpace I never 2 finished and I never like did anything. I just kind of 3 made it and left it.
+
+4 Q. So the answer is yes, you posted this on 5 MySpace?
+
+6 A. Yup.
+
+7 Q. Go to 25-016. Who took this photo of you 8 simulating sex with a woman?
+
+9 MR. LEOPOLD: Object to the form of the 10 question. Argumentative.
+
+11 THE WITNESS: First off, she's piercing my 12 belly button or repiercing it, and I'm pretty sure 13 it was just like we put up a camera somewhere and 14 put a timer on it. We didn't have anybody take 15 it.
+
+16 BY HR. TEIN:
+
+17 Q. You posted that on your MySpace page?
+
+18 A. Yeah.
+
+19 Q. Go to 25-013. Is that a photo of you?
+
+20 A. Yep.
+
+21 Q. Who's in the photo with you?
+
+22 A.
+
+23 Q.
+
+24 A. Yep.
+
+25 Q. Is this you coming out of the shower?
+
+![](_page_31_Picture_1.jpeg)
+
+nsor & Associates Reponmpandltitructiptim,lm
+
+1 A. Yes.
+
+2 Q. Are you clothed in this picture?
+
+3 A. Yeah. I have a halter dress on.
+
+4 Q. Where is that picture taken?
+
+5 A. In house.
+
+6 Q. Did you post that on the Internet?
+
+7 A. Yes.
+
+8 Q. All right.
+
+9 MR. TEIN: You can take that down.
+
+10 BY MR. TEIN:
+
+11 Q. Now your boyfriend is 12 correct?
+
+13 A. Yeah.
+
+14 Q. You lie about your age in order to conceal 15 something about your relationship with 16 isn't that correct?
+
+17 A. No.
+
+:8 Q. IIIIIIII 22 years old, isn't he?
+
+19 A. Yes.
+
+20 Q. And a firefighter with the Palm 21 Beach Fire Department, right?
+
+22 A. Yup.
+
+23 Q. Does the Palm Beach Fire Department know 24 that your boyfriend is dating an underage girl?
+
+25 A. Actually, mister, it's legal.
+
+![](_page_32_Picture_1.jpeg)
+
+nsor & Associates Reprint np and Transctiptiatinc
+
+1 O. Well --
+
+2 MR. LEOPOLD: Just answer the question,
+
+3 IIIIIIIIII
+
+4 THE WITNESS: Yes.
+
+5 BY MR. TEIN:
+
+6 Q. Did they know two weeks ago that you were 7 dating an underage girl (sic)?
+
+8 A. Yes. I met everybody in there.
+
+9 Q. Did they know your age?
+
+
+11 Q. Did you lie about your age so that the fire 12 department wouldn't think thatillillis committing a 13 crime by having a sexual relationship with an underage 14 girl?
+
+15 MS. BELOHLAVEK: Objection. Assumes facts 16 not in evidence.
+
+17 BY MR. TEIN:
+
+18 Q. You can answer the question.
+
+19 A. No.
+
+20 Q. Does the Palm Beach Police Department know 21 thatles having a sexual relationship with an 22 underage girl?
+
+23 MR. LEOPOLD: Don't guess. Answer if you 2 4 know.
+
+25 THE WITNESS: Can you repeat the question?
+
+![](_page_33_Picture_1.jpeg)
+
+
+2 Q. Does the Palm Beach Police Department know 3 that'll', a member of the Palm Beach Fire Department, 4 is having a sexual relationship with an underage girl?
+
+5 A. I'm guessing no.
+
+6 Q. You lie about your twin sister don't 7 you?
+
+8 MR. LEOPOLD: Objection. Argumentative.
+
+9 BY MR. TEIN:
+
+10 O. Don't you?
+
+11 A. No. I have never lied for or to
+
+12 Q. You lie about the fact that she has a drug 13 ha&t, right?
+
+14 A. No. I would never accuse my sister of 15 having a drug habit.
+
+16 Q. Do you try to conceal the fact that she has 17 a drug habit?
+
+18 MR. LEOPOLD: Objection. Argumentative.
+
+19 BY PR. TEIN:
+
+20 Q. You can answer the question.
+
+21 A. No. My sister does not have a drug habit.
+
+22 Q. You lied when you went to the crack house 23 in Georgia, didn't you?
+
+24 MR. LEOPOLD: Objection. Argumentative.
+
+25 Lack of foundation, lack of predicate.
+
+![](_page_34_Picture_1.jpeg)
+
+1 THE WITNESS: Never -- what did you say?
+
+2 BY MR. TEIN:
+
+3 Q. You lied when you went to the crack house 4 in Georgia, didn't you?
+
+5 MR. LEOPOLD: Objection. Argumentative.
+
+6 Lack of foundation, lack of predicate.
+
+7 BY MR. TEIN:
+
+8 Q. You can answer the question.
+
+9 A. I have never been to a crack house.
+
+10 Q. Who don't you lie to?
+
+11 MR. LEOPOLD: Objection. Argumentative.
+
+12 Don't answer the question.
+
+13 MR. TEIN: Certify it.
+
+14 CERTIFIED QUESTION
+
+
+16 Q. You don't lie to IIIIIIIdo you?
+
+17 MR. LEOPOLD: Objection. Asked and 18 answered.
+
+19 Don't answer the question.
+
+20 BY MR. TEIN:
+
+21 Q. No. You can answer that question.
+
+22 MR. LEOPOLD: No. I just told her not to.
+
+23 You've asked that question about five --
+
+24 MR. TEIN: No, I haven't.
+
+25 MR. LEOPOLD: Don't answer the question.
+
+![](_page_35_Picture_1.jpeg)
+
+Page 112
+
+1 MR. TEIN: I'll certify it.
+
+2 CERTIFIED QUESTION
+
+3 MR. LEOPOLD: For the record, you have to 4 stop interrupting me because she can't take down 5 both of us talking at the same time.
+
+
+7 Q. You tell \_the truth, don't you?
+
+8 A. Excuse me?
+
+9 Q. You tell - the truth, don't you?
+
+10 A. When it's -- yes, I tell...lithe truth.
+
+11 Q. Who's III. drug dealer?
+
+12 A. My sister does not have a drug dealer. She 13 lives in Georgia with my mother.
+
+14 Q. Okay. Who is the drug dealer who dropped 15 you and IIIIIlloff at 5:45 a.m., in 2006, after being out 16 all night, the two of you, using drugs at Palm Beach :7 Country Estates where your father called the police?
+
+18 A.
+
+In 19 Q. He's the drug dealer?
+
+20 A. He is a drug dealer.
+
+21 Q. Do you remember was arrested by the 22 Palm Beach Police Department and taken to the Juvenile 23 Assessment Center that morning?
+
+24 A. I do remember that.
+
+25 Q. Now before you massaged Epstein, you were
+
+![](_page_36_Picture_1.jpeg)
+
+nsor & Associates Reporting and Transcri pzi no, Inc
+
+Page 113
+
+involuntarily admitted into a juvenile educational 2 facility; isn't that right?
+
+3 A. Did you say involuntarily?
+
+{sup}`4`Q. Yes.
+
+5 A. No. I was willing to go. I -- duly said 6 sure.
+
+7 Q. And you went there because you were lying 8 so much, no one could control you; isn't that correct?
+
+9 A. That's very incorrect.
+
+10 Q. Now you lie to your parents all the time, 11 dor't you?
+
+12 A. Incorrect.
+
+13 MR. LEOPOLD: Objection. Argumentative.
+
+1 4 BY MR. TEIN:
+
+15 Q. Sorry?
+
+16 A. Incorrect.
+
+17 Q. The day you went to Epstein's house you 18 lied to your father about where you were going; isn't 19 that correct?
+
+20 A. Correct.
+
+21 Q. You admitted to the police that you told 22 you: father that you were going shopping, didn't you?
+
+23 A. Yes.
+
+24 Q. And that was a lie, wasn't it?
+
+25 A. Yes.
+
+![](_page_37_Picture_1.jpeg)
+
+1 2 Q. And isn't it true that your father has accused you of lying?
+
+3 A. All the time.
+
+4 Q. Didn't your father throw you out of the 5 house Thanksgiving of this past year because you were 6 lying so much to him?
+
+Page 114
+
+7 A. Yes, he did kick me out. No, that's not 8 the reasons why.
+
+9 Q. Didn't your father throw your sister 10 out of the house, too?
+
+11 A. Yes.
+
+12 Q. 13 after Thanksgivings, right? And he threw her out of the house the week
+
+14 A. I don't know the date, but sure.
+
+15 Q. Sounds about right?
+
+16 A. Sure.
+
+17 Q. And the reason he threw her out of the 18 house was because she was lying, too?
+
+19 MR. LEOPOLD: Objection. Lack of 20 foundation. Calls for speculation.
+
+21 BY R. TEIN:
+
+22 Q. When your counsel coaches you, you say it's 23 correct, right?
+
+24 A. I've never been coached.
+
+25 MR. LEOPOLD: Objection.
+
+![](_page_38_Picture_1.jpeg)
+
+Page 115
+
+
+2 Q. Okay. When your counsel that it was there 3 was lack of foundation, you agree with your counsel, 4 richt?
+
+5 A. I was like saying, "Yeah, let's move on," 6 because there was no point to asking that question.
+
+7 Q. Your father threwillIpout of the house 8 because she was lying, correct?
+
+9 MR. LEOPOLD: Objection. Lack of 10 foundation.
+
+11 Hold on,IIIII, Let me just make the 12 objection.
+
+13 Lack of foundation, predicate, calls for 14 speculation.
+
+
+16 Q. Answer.
+
+17 A. I'm not my sister. I don't know.
+
+:8 O. I want to know what you know only.
+
+L9 A. I don't know.
+
+20 Q. You don't know. That's your answer?
+
+21 A. Yes.
+
+22 Q. Now your parents filed the police report 23 regarding Mr. Epstein, right?
+
+L4 A. Yes.
+
+25 Q. Now your parents are also lying, aren't
+
+![](_page_39_Picture_1.jpeg)
+
+1 they?
+
+2 A. Yes.
+
+3 MR. LEOPOLD: Just so the record is clear, 4 the father -- because the mother was up north.
+
+5 MR. TEIN: Don't testify, Counsel.
+
+6 MR. LEOPOLD: So the record is clear, just 7 the father. The mother was --
+
+8 MR. TEIN: Counsel, don't coach and 9 testify, please. That's absolutely improper.
+
+10 MR. LEOPOLD: You just asked the wrong 11 question.
+
+12 MR. TEIN: You can't coach her that way and 13 you well know it.
+
+14 MR. LEOPOLD: For the record, it's the 15 father. He's remarried, I think on his third 16 marriage.
+
+17 MR. TEIN: You cannot -- it's absolutely, 18 totally against the rules and you know it.
+
+19 MR. LEOPOLD: The natural mother lives in 20 Georgia.
+
+21 MR. TEIN: You need to behave yourself, 22 lawyer.
+
+23 MR. LEOPOLD: The natural mother lives in 24 Georgia. The father is here locally.
+
+25 MR. TEIN: Stop coaching. Stop talking.
+
+7 6 MR. LEOPOLD: Are you finished, for the record?
+
+8 9 MR. TEIN: I'm not talking to you. Do what you want.
+
+10 MR. LEOPOLD: Don't say anything yet.
+
+11 BY MR. TEIN:
+
+12 Q. Mr your parents --
+
+13 14 MR. LEOPOLD: Hold it. Don't say anything yet. Let me --
+
+
+16 17 Q. Your parents, who filed the police report are also liars.
+
+18 19 20 21 22 23 MR. LEOPOLD: Don't answer the question. We're not going to answer until I make the record. I want to put on the record, now that Counsel appears to be finished with his comments for the record, that the previous question was inappropriate, was intentionally misleading.
+
+24 Now you can ask the question.
+
+25 BY MR. TEIN:
+
+![](_page_40_Picture_1.jpeg)
+
+1 2 3 4 You object. You know the rules. You just lectured me about the rules, Counsel. So why don't you play by the rules? Or only when they fit you? Why don't you grandstand a little more 5 now. Give us a five-minute speech, Mr. Leopold.
+
+Page 127
+
+![](_page_41_Picture_1.jpeg)
+
+1 2 in this case, are also proven liars, aren't they? Q. Your parents, who filed the police report
+
+3 MR. LEOPOLD: Same objection.
+
+4 BY MR. TEIN:
+
+5 Q. Aren't your parents liars?
+
+6 MR. LEOPOLD: Calls for speculation. Lack 7 of predicate.
+
+8 MR. TEIN: Stop coaching. You know what 9 that is, Leopold.
+
+10 MR. LEOPOLD: Calls for speculation. Lack 11 of foundation.
+
+12 THE WITNESS: When you say parents, my mom 13 is not, but sure, yeah, my dad has been to jail 14 for lying.
+
+
+16 Q. Your dad went to federal prison for two 17 yea:s for lying, right?
+
+18 A. Correct.
+
+19 Q. 20 fraud? Did he tell you it was for a financial
+
+21 A. Yes.
+
+22 Q. For stealing money from some financial 23 institution?
+
+24 A. Correct.
+
+25 Q. And do you think your father is trying to
+
+![](_page_42_Picture_1.jpeg)
+
+sor 8z Associates Repot:imp and l'anscriptiom, Inc
+
+1 steal your lawsuit money away from you?
+
+2 Don't look to your lawyer for the answer.
+
+Page 119
+
+3 MR. LEOPOLD: You can answer if you know 4 the answer to it. I have no idea.
+
+5 THE WITNESS: Yeah.
+
+
+7 Q. And your father filed a lawsuit, the first 8 lawsuit for fifty million dollars against Mr. Epstein 9 without consulting you, correct?
+
+10 A. Correct.
+
+11 Q. And your father had a lawyer file the first 12 lawsuit on your behalf for fifty million dollars against 13 Mr. Epstein without your knowledge, correct?
+
+14 A. Correct.
+
+15 Q. And you don't trust your father, do you?
+
+16 A. Correct.
+
+17 Q. And you believe he's trying to manipulate 18 you for his own gain, don't you?
+
+19 A. Sort of.
+
+20 0. Well, you know that your mother filed a 21 statement, an affidavit, saying that you don't trust your 22 father and that you believe he's trying to manipulate you 23 for lis own gain; isn't that correct?
+
+24 A. Correct.
+
+25 Q. You agree with that statement, don't you?
+
+![](_page_43_Picture_1.jpeg)
+
+Page 120
+
+1 A. Uh-huh. Yes.
+
+2 Q. Do you trust your stepmother?
+
+3 A. My stepmother, no.
+
+4 Q. You think she's also trying to steal your 5 Epstein lawsuit money away from you, don't you?
+
+6 A. I would like to clarify something. You 7 keep saying my Epstein lawsuit money. I don't have any 8 money, and it's just a lawsuit at the moment. So I just 9 don't trust her.
+
+10 Q. Okay. You think that your stepmother is 11 trying to take advantage of this lawsuit to try to get 12 money from Mr. Epstein that belongs to you, right?
+
+13 A. Yes.
+
+14 Q. Did your stepmother tell you why she was 15 arrested?
+
+16 A. No.
+
+17 Q. Did your stepmother tell you that she's 18 ever been arrested?
+
+19 A. No.
+
+20 Q. Did she tell you she was arrested for 21 fraud?
+
+22 A. Never.
+
+23 Q. Did she tell you that she was fired from ,2.4 Hawthorne Aviation?
+
+25 A. No.
+
+![](_page_44_Picture_1.jpeg)
+
+Q. Hawthorne Aviation for stealing? Did she tell you that she was fired from
+
+sor & Associates Renaming and Transcriptial, Inc
+
+Page 121
+
+
+MR. TEIN: Let's take a break. (Thereupon, arecess was taken.)
+
+
+Q. before you met Jeffrey Epstein, had you ever had sexual intercourse?
+
+A. Yes, yeah.
+
+Q. How many times?
+
+A. Just a few. Twice.
+
+Q. With how many different men?
+
+A. Two.
+
+0. How old were they?
+
+A. being one year older than me, and then the other person was two years older than me.
+
+Q. What was his name?
+
+"18 A. =Ma
+
+Q. How old were you when you first had sexual intercourse?
+
+A. 14.
+
+Q. many different men had you had any type of sexual act:.vity with? How many -- before you met Epstein, how
+
+A. Just those two.
+
+![](_page_45_Picture_1.jpeg)
+
+Q. Are you saying you never kissed a man other than those two?
+
+MR. LEOPOLD: Objection to the form of the question.
+
+THE WITNESS: Yes, I had kissed people before.
+
+
+Q. Before you met Epstein, had you ever had oral. sex?
+
+10 A. No.
+
+11 Q. Ever in your life, have you exchanged sex for something of value?
+
+
+MR. TEIN: We're done.
+
+THE WITNESS: II, okay.
+
+MR. LEOPOLD: We'll read.
+
+MS. BELOHLAVEK: I don't have any questions. Thank you.
+
+MR. LEOPOLD: Before we go off the record, 20 it's my understanding -- Mr. Goldberger can correct the record -- but we have stipulated that 22 color copies of the documents that were identified for identification certainly will be attached to the deposition and counsel will be taking the photographs across street so that they can be
+
+![](_page_46_Picture_1.jpeg)
+
+Page 123
+
+1 laser color copied so that we have a copy, and I'm 2 assuming he'll get a copy to the court reporter, 3 too, to attach, actually a certified copy to the 4 deposition.
+
+5 MR. GOLDBERGER: Done.
+
+6 MR. LEOPOLD: That's if you agree to that. 7 If not, then I want to pull each one out and put 8 exhibit labels on them, which we should do before 9 we leave.
+
+10 MR. GOLDBERGER: We're not going to do 11 either. I'll have copies sent to the court 12 reporter and she can attach them to the 13 deposition.
+
+14 MR. LEOPOLD: So you're not going to agree 15 to what we talked about during the break then.
+
+16 17 MR. GOLDBERGER: I'm not quite sure what your asking me to do. Let me finish.
+
+18 MR. LEOPOLD: Okay. Sure. That's fine.
+
+19 20 MR. GOLDBERGER: Okay. If you want me to go over to Ms. Belohlavek's office and make copies 21 and then I'll give those to the court reporter, 22 fine. All I'm saying is that I would avoid that 23 process. I would send copies to the court 24 reporter. But if it will make you happier --
+
+25 MR. LEOPOLD: I'm not?
+
+![](_page_47_Picture_1.jpeg)
+
+1 MR. GOLDBERGER: Let me finish.
+
+2 MR. LEOPOLD: I'm not interrupting now.
+
+3 MR. GOLDBERGER: But if it will make you 4 happier if I go over to Ms. Belohlavek's office 5 and make a copy of those photos that were part of 6 this deposition and then I'll give them to the 7 court reporter, I'll be happy to do it.
+
+8 MR. LEOPOLD: I trust you implicitly, 9 however you with to do it. However, the 10 documents, before they leave this room, need to 11 have an exhibit sticky on them with the 12 appropriate --
+
+13 MR. GOLDBERGER: Want to go get some? We 14 don't have any.
+
+15 MR. LEOPOLD: I will do that. Excuse me. 16 Let me finish the record, please. You can't do 17 that to the court reporter. She's going to stroke 18 out. You can't do that. You have to let me --
+
+19 MR. TEIN: Finish your sentence, Ted. You 20 are the most long-winded lawyer I've ever seen in 21 my life. Finish your sentence.
+
+22 MR. LEOPOLD: Jack, tell him not to raise L3 his voice, please.
+
+24 MR. TEIN: Finish your sentence. Is there 25 going to be a period at the end of the sentence or
+
+![](_page_48_Picture_1.jpeg)
+
+1 2 is it just going to be comma after comma after comma?
+
+3 Go ahead, lawyer.
+
+4 MR. LEOPOLD: All right. The exhibits, I 5 can't prevent you from taking them, but I will 6 object and I will be bringing it to the court for 7 sanctions. You cannot take the exhibits out of 8 the room without them being marked. I want them 9 marked, because you cannot identify in the record 10 what was used. And with all due respect to 11 Mr. Goldberger, I do not -- the way this 12 deposition is going, I do not want to rely on 13 Counsel from Miami to mark the appropriate 14 exhibits. I will not do that. I cannot prevent 15 you from taking them. But if you do, I will be 16 bringing the matter to the court with appropriate 17 sanctions, because that is improper. That is 18 improper. When you use something in a deposition, 19 they are to be marked. And you have refused to do 20 that throughout for what ever reason.
+
+Page 125
+
+21 MR. TEIN: You're wrong. Finish your 22 sentence because you're talking about something 23 you have no idea.
+
+24 Every single one is marked, Ted. Every 25 single one is already marked. But you want to
+
+![](_page_49_Picture_1.jpeg)
+
+1 2 argue about everything. Ever single one is already marked. Isn't that silly, Ted?
+
+3 MR. GOLDBERGER: Thirty years of doing this 4 and I have never had an argument over this.
+
+Page 126
+
+5 6 obstructionist, you are a liar. You have lied and 7 misrepresented things, for the record. You are 8 grandstanding. MR. TEIN: You've made -- Ted, you are
+
+9 MR. LEOPOLD: You need to back up.
+
+10 MR. TEIN: No, no. I'm going to finish.
+
+11 MR. LEOPOLD: You can finish, but don't 12 hover over me.
+
+13 MR. TEIN: No one is hovering over you. 14 Stop trying to make a lying record.
+
+15 Let me say something else.
+
+16 17 after you lied in a letter to my co-counsel about 18 the fact -- be quiet. Be quiet and let me finish. Don't you dare threaten me with sanctions,
+
+19 You lied in a letter to my co-counsel,
+
+20 Mr. Leopold, in which you said -- it was a 21 complete and utter lie -- that you were
+
+22 unavailable this morning because you had a
+
+23 hearing. That was a lie. I have never seen a 24 lawyer deign to do something like that.
+
+25 So you will get the ex -- be quiet. Let me
+
+
+![](_page_50_Picture_1.jpeg)
+
+sor & Associates Reparnna and Transcriphnn. Inc
+
+1 finish. You behave.
+
+2 3 me. MR. LEOPOLD: Don't point your finger at
+
+4 MR. TEIN: Listen. Be quiet and I won't 5 have a need to point it at you.
+
+Page 12";
+
+6 MR. LEOPOLD: Don't point your finger at
+
+7 MR. TEIN: Mr. Leopold --
+
+8 9 me. MR. LEOPOLD: Don't point your finger at
+
+10 MR. TEIN: Mr. Leopold, let me finish.
+
+11 MR. LEOPOLD: Don't raise your voice 12 either.
+
+13 MR. TEIN: Mr. Leopold --
+
+14 MR. LEOPOLD: Jack, do you want to take 15 care of this?
+
+16 MR. TEIN: Let me finish my sentence. The 17 exhibits are marked. We are walking out of here.
+
+18 19 record. It is absolutely atrocious what you do. 20 That is not how a lawyer should behave. This 21 deposition is over. You will get your exhibits, 22 Mr. Leopold. You are someone who misrepresents the
+
+23 MR. GOLDBERGER: I understand what you're 24 saying, Michael, and I understand Ted's position.
+
+25 Just so there's -- we're going to have lots
+
+![](_page_51_Picture_1.jpeg)
+
+1 of issues in this case. We're going to have lots 2 of reasons to disagree.
+
+I'm going to take it over now and I'm going to make copies and I'm going to give them to Ms. Consor. If you want to go find some exhibit labels and put some exhibit labels on it, be my 7 guest. But that's what I'm offering to do.
+
+8 THE WITNESS: Let me say two things, 9 because I am happy to always disagree, and with 10 you, I have no problem; we could always do it 11 professionally. I have not problem.
+
+12 I want to say two things so the record is 13 very clear.
+
+14 Since for whatever reason I have not been 15 able to look at exhibits, because they have been 16 refused to have been shown to me --
+
+17 MR. TEIN: That's a lie.
+
+MR. LEOPOLD: -- Jack, if you represent 19 that the documents have the appropriate exhibit numbers or some identifying markings, 25, 30.000, 21 whatever they may be, then you can take them, make 22 copies, send me a copy, make sure the court reporter gets a copy and then send me a bill for my copies, that's fine. I didn't know that they are marked that way because I haven't been able to
+
+![](_page_52_Picture_1.jpeg)
+
+1 look at them.
+
+2 3 4 MR. GOLDBERGER: They are barcoded, and the number that we've made reference to in the deposition coincides with the barcoding.
+
+5 6 MR. LEOPOLD: That's fine. Eight by eleven color laser copies are fine.
+
+7 8 9 MS. BELOHLAVEK: The State Attorneys Office is not going to charge anybody for color copies I print out.
+
+10 11 MR. LEOPOLD: That's fine. He's going to take them back to his office.
+
+12 13 14 15 16 17 18 Secondly -- and I will be more than happy to do it, because it sounds like you all know more about it than I -- but I'm happy to get affidavits from Mr. Pincus, Judge Stern, everybody else about what happened with this hearing today, because I know very little about it. But my representations are what they are.
+
+19 MR. GOLDBERGER: They stay --
+
+20 21 MR. LEOPOLD: Let me just finish for the record.
+
+22 23 24 My representations or comments about what happened, representation about this hearing this morning, I know very little about it. I
+
+25 MR. GOLDBERGER: I'll take your word on
+
+![](_page_53_Picture_1.jpeg)
+
+1 that.
+
+2 3 4 5 6 7 8 MR. LEOPOLD: No, no, no. I just put it on the record. I will get an affidavit -- I'm assuming it sounds like you need it -- from Mr. Pincus. I have no clue about what happened and why it was canceled. All I was told when I was out of town yesterday was that the hearing this morning was cancelled.
+
+9 10 MR. GOLDBERGER: I'll take your word for it.
+
+11 12 MR. LEOPOLD: If you want an affidavit, I'll get it for you.
+
+13 14 15 16 17 18 MR. GOLDBERGER: It's a personal issue for me because I had to disrupt a vacation and if it was done just because it wasn't convenient for you, then I'm offended by that. But if you're telling me that it was planned and it didn't happen, I'll take your word for it.
+
+19 20 21 22 23 24 25 MR. LEOPOLD: I am more than happy to get you an affidavit, because I don't know the reason why it was canceled other than the fact that I'm assuming since my deposition was taken for four hours on Monday for preparation for the hearing today, for whatever reason it was canceled, I am told it is being re-noticed. Why it was canceled,
+
+![](_page_54_Picture_1.jpeg)
+
+1 2 3 4 I have no idea, but if your co-counsel wishes an affidavit to that effect from Mr. Pincus, I'm more than happy to get it. But I don't know the reason why it was canceled.
+
+5 6 7 8 MR. TEIN: I don't need it. But what I do take issue with is regardless of why it was canceled, you owed us the courtesy of saying, You know what? We can start earlier this morning.
+
+9 MR. LEOPOLD: I owe you nothing.
+
+10 11 MR. TEIN: I don't care. Don't interrupt me.
+
+12 13 Because Jack canceled his vacation plans because of you.
+
+14 15 MR. GOLDBERGER: That's all right, that's all right.
+
+16 17 MR. TEIN: And you're selfish. And this deposition is over. Good-by Mr. Leopold.
+
+18 MR. GOLDBERGER: You can go off the record.
+
+19
+
+20
+
+21
+
+22
+
+23
+
+24
+
+25
+
+- - -
+
+![](_page_55_Picture_1.jpeg)
+
+#### CERTIFICATE
+
+The State of Florida, County of Palm Beach.
+
+I hereby certify that I have read the foregoing deposition by me given, and that the statements contained herein are true and correct to the best of my knowledge and belief, with the exception of any corrections or notations made on the errata sheet, if one was executed.
+
+Dated this day of , 2008.
+
+![](_page_56_Picture_1.jpeg)
+
+1 2 DATE: February 25, 2008 TO: c/o L 3 Office of the State Attorney 401 N. Dixie Highway 4 West Palm Beach, Florida 33401 5 IN RE: STATE OF FLORIDA -V- JEFFREY EPSTEIN CASE NO.: 2006 CF09454AXX
+
+6 Please take notice that on Wednesday, the 7 20th of February, 2008, you gave your deposition in the above-referred matter. At that time, you did not waive 8 signature. It is now necessary that you sign your deposition.
+
+9 Please call our office at the below-listed number to schedule an appointment between the hours of 10 9:00 a.m. and 4:30 p.m., Monday through Friday.
+
+11 If you do not read and sign the deposition wittin a reasonable time, the original, which has already 12 beer forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your 13 signature, sign your name in the blank at the bottom of this letter and return it to us.
+
+14 Very truly yours,
+
+15 Judith F. Consor, FPR 16 Consor & Associates Reporting and Transcription 1655 Palm Beach Lakes Boulevard, Suite 500 17 West Palm Beach, Florida 33401
+
+18 I do hereby waive my signature:
+
+19
+
+20 cc via transcript: JACK A. GOLDBERGER, ESQ. 21 LANNA BELOHLAVEK, ESQ. MICHAEL R. TEIN, ESQ. 22 THEODORE J. LEOPOLD, ESQ. file copy
+
+23 24 25
+
+![](_page_57_Picture_1.jpeg)
+
+1 ERRATA SHEET 2 IN RE: STATE-V-JEFFREY EPSTEIN DEPOSITION OF: TAKEN: February 20th, 3 2008
+
+DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 4 PAGE # LINE # CHANGE REASON
+
+22 Please forward the original signed errata sheet to this office so that copies may be distributed to all parties.
+
+> Under penalty of perjury, I declare that I have read my deposition and that it is true and correct subject to any changes in form or substance entered here.
+
+DATE: SIGNATURE OF DEPONENT:
+
+![](_page_58_Picture_1.jpeg)
+
+THU STATE OF FLORIDA, ) COUNTY OF PALM BEACH. )
+
+I, the undersigned authority, certify that 6 IIIIIIIIII personally appeared before me on the 20th 7 of February, 2008 and was duly sworn.
+
+WITNESS my hand and official seal this 25 day 10 of February, 2008.
+
+enforC\_
+
+Judith F. Consor, FPR
+
+Notary Public - State of Florida
+
+![](_page_59_Picture_190.jpeg)
+
+C E R T I F I C A T E
+
+The State Of Florida, )  
+County Of Palm Beach. )
+
+I, Judith F. Consor, Court Reporter and Notary Public in and for the State of Florida at large, do hereby certify that I was authorized to and did stenographically report the deposition of [REDACTED] that a review of the transcript was requested; and that the foregoing pages, numbered from 1 to 131, inclusive, are a true and correct transcription of my stenographic notes of said deposition.
+
+I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out.
+
+I further certify that I am not an attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action.
+
+The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter.
+
+DATED this 25 day of February, 2008
+
+Judith F. Consor, Court Reporter  
+Florida Professional Reporter
+
+![](_page_59_Picture_202.jpeg)
+
+# STATE COURT PLEADINGS
+
+
+CASE NO. **50 2008 CA 00 65 96 XXXX MB**
+
+JANE DOE, by and through  
+JANE DOE'S MOTHER as parent and natural  
+guardian,
+
+Plaintiffs,
+
+v.  
+*(Signature)*
+
+JEFFREY EPSTEIN, [REDACTED],  
+and SARAH KELLEN,
+
+
+2008 HAR - 6 PH 4: 37  
+SHAF JANE BOCK, CLERK  
+PALM BEACH COUNTY  
+CIRCUIT CIVIL  
+**AB**  
+**LED**
+
+**COMPLAINT**
+
+Plaintiffs, JANE DOE, by and through JANE DOE'S MOTHER as parent and natural  
+guardian of JANE DOE, bring this Complaint against Defendants JEFFREY EPSTEIN, [REDACTED]  
+[REDACTED], and [REDACTED], and state as follows:
+
+**Parties, Jurisdiction and Venue**
+
+1. 1. Jane Doe is a citizen and resident of the State of Florida. She is a minor under the age of 18 years.
+2. 2. Jane Doe's Mother brings this action as parent and natural guardian of Jane Doe.
+3. 3. This Complaint is brought under fictitious names to protect the identity of the Minor Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a minor.
+4. 4. Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+5. 5. Defendant [REDACTED] is a citizen and resident of Palm Beach County, Florida.
+6. 6. Defendant [REDACTED] is a citizen and resident of the State of New York.
+
+7. This is an action for damages in excess of Fifteen Thousand Dollars (\$15,000) exclusive of interest and costs.
+
+R. Venue is proper in this Court under section 47.011, Florida Statutes, because the causes of action brought herein accrued in Palm Beach County, Florida and one or more Defendants resides in Palm Beach County, Florida.
+
+#### Factual Allegations
+
+9. At all relevant times, Defendant Jeffrey Epstein was an adult male. F;pstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is a mum of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. and Palm Beach, Florida. The allegations herein concern Epstcin's conduct while at his Lavish estate in Palm Beach.
+
+10. Jpon information and belief, Epstein has a sexual preference and obsession for minor girls. He engaged in a plan, scheme, and/or enterprise in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls or coerced them to engage in prostitution, and then gave them money. In or about 2005, .lone Doe, then 14 years old, fell into Epstein's trap and became one of his victims.
+
+II. Upon information and belief, Jeffrey Epstein carried out this scheme/enterprise and assaulted girls in Florida, New York and on his private island, known as Little Si. James, in St.
+
+12. An integral player in Epstein's Florida scheme was an assistant of Epstein's from New York, New York and Haley In a Palm Beach Community College student from Loxahatchee. Florida. They recruited girls ostensibly to give a wealthy man a massage for monetary compensalion in his Palm Beach mansion. Under Epstein's plan/enterprise,.— was contacted shortly bcfpro or soon after Epstein was at his Palm Beach residence Epstein, or someone on their behalf directed NM to bring one or more underage girls to the residence.
+
+MEM upon information and belief, generally sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who would be enticed by the money being offered - generally \$200 to 5300 per "massage" session — and who were perceived ns less likely to complain to authorities or have credibility if allegations of improper conduct were made. This was an important element of Epstein's plan/enterprise
+
+{sup}`a`Epstein's plan. scheme, and/or enterprise reflected a particular pattern and method. Upon arrival at Epstein's mansion, Mr would introduce each victim to Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. MIMIwouldchen bring the girl tip a flight of stairs ton bedroom that contained a massage table in addition to other furnishings. There were photographs of nude women lining the stairway hall and in the bedroom would then leave the girl alone in this room, whereupon Epstein would enter wearing only atowel. He would then remove his towel, lay down naked on the massage table, and direct the girl to remove her clothes. He then would perform one or more lewd, lascivious and sexual acts, including masturbation, touching the girl's vagina with a vibrator, or digitally penetrating the girl's vagina.
+
+14. Consistent wit 1 the foregoing plan, scheme, and/or enterprise, MI recruited Jane Doc to give Epstein a massage for monetary compensation • brought Jane Doe to Epstein's mansion in Palm Beach. Jane was introduced to N who led her up the flight of stairs to the room with the massage table set tip the message table and laid out message oils and told Jane Doe that Epstein would be in shortly and than left the room. Jane Doe was alone in the room when Epstein arrived. Epstein told her to remove her clothes and left the room. When Epstein returned he was wearing only atowel. He removed his towel, and laid down on his stomach on the message table. Epstein again told Jane Doe remove her clothes. In shock, fear and trepidation, Jane Doe complied, removing her clothes except for her panties and bra. Shortly
+
+after starting to rub Epstein's back, Epstein told Jane Doe to sit on his hack. June Doe, out of fear and trepidation, complied. After a period of time Epstein got up from the table and went behind the door. For several minutes Jane Doc heard loud noises and moans and believes that Epstein was masturbating'. Thereafter Epstein, naked, returned to the message table and laid face up on the table. Epstein than told Jane Doe to continue with the message and told her to sit on top of him. Out of fear and trepidation she complied. As Jane Doc rubbed Epstein's chest Epstein began tc use a vibrator on Jane Doe's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane's vagina At this same time Epstein was masturbating. Upon reaching orgasm Epstein licit up from the message table and told Jane Doe to write down her name and phone number and than left the room.
+
+15. Jane Doe was then able to get dressed, leave the room and go back down the stairs and into the kitchen. Epstein, and were waiting for Jane Doe. Epstein paid Jane Doe 5300. was paid \$200 by Epstein for bringing Jane to him..\_ brought Jane Doe home.
+
+16. As a result of this encounter with Epstein, the I4-year old Jane Doe experienced confusion, shame, humiliation, embarrassment and the assault sent her life into adownward spiral.
+
+#### COUNT I Sexual Assault against Defendant Epstein
+
+17. Plaintiff Jane Dot by and through her Mother, as parent and natural guardian, repeats and realleges paragraphs I through 16 above.
+
+:8. Defendant Epstein toniously assaulted Jane Doc sexually in or about 2005.
+
+19. This sexual assault was in violation of Chapter 800 of the Florida Statutes, which recognizes as a crime the lewd and lascivious acts committed by Epstein upon Jane Doe.
+
+20. As a direct Lnd proximate result of Epstein's assault on Jane Doc, she has suffered and will continue to softer severe and permanent traumatic injuries, including mental, psychological and emotional damages.
+
+WHEREFORE, Plaintiff Jane Doc, by and through her Mother, as parent and natural guardian, demands judgment against Defendant Jeffrey Epstein for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim fur punitive damages pursuant to Florida Law.
+
+#### COUNT II Civil Conspiracy against Defendants Epstein, and
+
+21. Plaintiff Jane Doc by and through her Mother, as parent and natural guardian, repeats and realleges paragraphs I through 16 above.
+
+22. Defendants Epstein, and conspired to subject Jane Doe to the sexual assault of Defendant Epstein.
+
+23. Each of the Defendants commined an overt act in pursuance of this conspiracy Defendant Ftobscin used false pretenses to lure Jane Doe to the home of Defendant Epstein so that Epstein could sexually assault Jane Doc; Defendant delivered Jane Doe to Defendant Epstein's bedroom so that Epstein could sexually assault Jane Doe, and Defendant Epstein actually committed sexual assault against Jnne Doe.
+
+24. As a direct and proximate result of Defendants' civil conspiracy, Jane Doe has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological and emotional damages
+
+WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein, and {sup}`a` for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend tins Complaint to add aclaim for punitive iamages pursuant to Florida Law.
+
+#### COUNT III Intentional Infliction of Emotional Distress against Defendant Epstein
+
+25. Plaintiffs Jane Doe by and through her Mother, as parent and natural guardian, repeat and realtege paragraphs through 16 above
+
+26. Epstein's conduct was intentional or reckless.
+
+27. Epstein's conduct was outrageous, going beyond all bounds of decency.
+
+28. Epstein's conduct caused severe emotional distress not only to lane Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional trauma and damage to Jane Doe and her mother.
+
+29. As a dire& and proximate result of Epstein's intentional or reckless conduct, Jane Doe will continue to suffer severe mental anguish and pain.
+
+wIlEREFORE, :rine Doe, by and through her Mother, and Jane Doe's Mother, individually, demand judgment against Defendant Jeffrey Epstein for compensatory damages, costs, attorney's fees, and such other and further relief as this Court deems just and proper. Further, Plaintiff reserves the right to amend this Complaint to add a claim for punitive damages pursuant to Florida Law. '
+
+#### COUNT IV Civil Remedy for Violation of Florida Statute Section 772.103 against Defendants Epstein, and
+
+30. Plaintiffs Jane Doe by and through her Mother, us parent and natural guardian, repeal and reallege paragraphs I through 16 above.
+
+31. Defendants participated in an enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statute section 772.103(3)-(4).
+
+32. Defendants engaged in this pattern of criminal activity by engaging in of least two of the following incidents of criminal activity with the same or similar intents, results, accomplices, victims, and methods of commission within a 5 year period:
+
+- a. Procuring for prostitution, or causing to be prostituted, any person who is under the age of III years in violation of Florida Statute section 796.03;
+- b. Soliciting, inducing, enticing, or procuring another to commit prostitution, lewdness, or assignation in violation of Florida Statute section 796.07(2)(0, or aiding, abetting or participating in such acts in violation of Florida Statute section 796.07(2)(h);
+- c. Knowingly recruiting, enticing, harboring, transporting, providing, or obtaining by any means a person, knowing that force, fraud, or coercion will be used to cause that person to engage in prostitution in violation of Florida Statute section 796.045; or
+- d. Forcing, compelling, nr coercing another to become o prostitute in violation of Florida Statute section 796.04.
+
+33. Under Defendants' plan, scheme and enterprise, Defendant Epstein paid Defendant to repeated y find and bring him underage girls, who were delivered to Epstein by
+
+Defendants and a in order for Epstein to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and/or lewdness.
+
+34. Plaintiff.lant Doe was the victim of Defendants' plan, scheme and enterprise. Defendant took Jane Doe to Epstein's home under the pretense that Jane Doc would be paid to give Epstein a massage. Defendant delivered Jane Doe to a room with a message table and told Mat Epstein would be in shortly. Jane Doe was alone in the room when Epstein arrived. Epstein told her to remove her clothes and left the room. When Epstein returned he was wearing only orowel. He removed his towel, and laid down on his stomach on the message table. Epstein again told Jane Doe remove her clothes. In shock, fear and trepidation, Jane One complied, removing her cloaca except for her panties and bra. Shortly after stoning to rub Epstein's back, Epstein told Jane Doe to sit on his hack. Jane Doe, out of fear and trepidation, complied. After {sup}`a` period of time Epstein got up from the table and went behind the door. For several minutes Jane Doc heard loud noises and moans and believes that Epstein was masturbating. Thereafter Epstein, naked, returned to the message table and laid face tip on the table. Epstein than told Jane Dec to continue with the message and told her to sit on top of him. Out of fear and trepidation she complied. As Jane rubbed Epstein's chest Epstein began to use a vibrator on Jane Doc's vagina. Thereafter Epstein began to digitally stimulate and attempt to penetrate Jane Doe's vagina. Ai tits same time, with his other hand, Epstein was masturbating. Upon reaching orgasm Epstein gm up from the message table and told Jane Doe to write down her name and phone number and :han left the room
+
+35. Jane Doe was then able to get dressed, leave the room and go back down the stairs and into the kitchen. Epstein, mind were waiting for Jane Doe. Epstein paid Jane Doc
+
+\$300. was paid \$200 by Epstein for bringing Jane to him. brought Jane Doe home.
+
+WHEREFORE, Plaintiff Jane Doe, by and through her Mother, as parent and natural guardian, demands judgment against Defendants Jeffrey Epstein, Haley and Ja for compensatory damages, treble damages under Florida Statute section 772.104, costs and attorney's fees under Florida Statute section 772 104, and such other and further relief as this Court deems just 'and proper. Further, Plaintiff reserves the right to amend this Complaint to add {sup}`a`claim for punitive damages pursuant to Florida Law.
+
+#### JURY TRIAL DEMAND
+
+Plaintiffs demand a jury trial in this action.
+
+Dated: March 6 2008Respectfully submitted,
+
+RICCI—LE 2925 PGA Palm Bea Phone: 56 Fax: 5
+
+LEOPOLD 705608
+
+Ill of 316
+
+
+
+#### Civil Cover Sheet
+
+#### Form 1.997 Civil Cover Sheet
+
+The civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law. This form is requ:red for the use of the Clerk of the Court for the purpose of reporting judicial workload data pursuant TO Florida Statute 25.075. 50 2008 CA 1) U 65 9 6 XXXXMB
+
+#### I. CASE STYLE
+
+#### CIRCUIT COURT
+
+JANE DOE, by and through JANE DOC'S MOTHER As parent and natural guardian,
+
+#### v.
+
+asiaN and
+
+#### 2. TYPE' OF CASE:
+
+Tortsil
+
+Other Civil:
+
+Professional Malpractice Products Liability Auto Negligence V Other Negligence
+
+-I nt -< n(
+
+Contracts Condominium Real Property/Mortgage Foreclosure Eminent Domain Other
+
+### <sup>3</sup>IS JURY TRIAL DEMANDED IN COMPLAINT?
+
+YES NO
+
+DATED THIS 6 day of March, 2008.
+
+2925 PGA Blvd.  
+Palm Beach Gardens, FL 32440  
+Phone: (561) 684-6500  
+Fax: (561) 697-2383
+
+
+IN THE CIRCUIT COURT Olt THE • ISTII JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA
+
+CASE NO: 50 2998 CA 006596 XXXX MB AB
+
+JANE DOE, by and through JANE DOE'S MOTHER, as parent and natural guardian,
+
+• 1 n r •. . . • • rJ
+
+
+vs
+
+JEFFREY EPSTEIN. and
+
+
+#### SUMMONS
+
+# PERSONAL SERVICE ON A NATURAI. PERSON
+
+TO DEFENDANT;
+
+JEFFREY EPSTEIN 457 Madison Avenue 4th Floor New York, New York
+
+#### IMPORTANT
+
+Alawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court. A phone call Nill not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. If you dc not file yotr response on time, you may lose the case, and your wages, money, and properly may thereafter be taken without further warning from the Court. There arc other legal requirements. You may want to cull an attorney right away. If you do not know an attorney, you may call an attorney referral service or {sup}`a`legal aid office (listed in the phone book).
+
+If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/ Plaintiffs Attorney" named below.
+
+"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within areasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 52500, West Palm Bench, FL 33401, telephone (561)355.2431, {sup}`I`-800-955-R771 (TDD), or 1-800- 955-8770(V), via Florida Relay Service".
+
+THEODORE. LEOPOLD, ESQUIRE RICO-LEOPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 (561) 684-6500
+
+
+TO EACH SHERIFF OF THE STATE, You arc commanded yt serve is Sum ons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). erec
+
+DATED ON
+
+![](_page_75_Picture_12.jpeg)
+
+### MPORTANT
+
+
+
+SANDRACU CIRCUIT COURT
+
+listed ha sido demandado legalmente. Tiene 20 Dias, contados a pair del recibo du este notification, pant contester la demanda adjunta, pr escrito, y presentarla ante este tribunal. Una Hamada telefonica no to protegera. Si usted desea que el tribunal considere su defense, debt presentar su respuestn por escrito, incluyendo el numbero del caso y los nombres de las panes interesadas. Si usted no contesta la demanda a tiempo, pudiese perder el ens° y podria set despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del U•ibunal. Existen otros requisitos legates. Si lo desea, puede usted consulter aun abogudo inrnediatemente. Si DO conoce a un abogado, pucdc Hamar a una de las of tins de asistencia legal que apace= en la guia telefonica.
+
+Si desea responder ala demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera asked enviar por correo {sup}`o`entregar una copia dc su respuesta a la persona denominada airejo corro "Plaintiff/Plaintiffs Attorney" (Demandants o Abogado del Dernandante).
+
+"De acucrdo con el Acto b Decreto de los Americansos con Irnpedimentos, Inhabilitados, personas en neccsidad del servicio special pare participar en estc procedimiento deberith, dentro de un iiernpo razonable, antes de cualquier procedimiento, ponerse en contact° con la officina Administraiativa du la Cone, 205 North Dixie Highway, oficina 5.2500, West Palm Beach, FL 33401, Telefnno (561) 355.2431, 1.800-955-8771 (TOD) 4 1-800-955-8770 (V), Via Flonda Relay Service".
+
+#### IMPORTANT
+
+Des Ki:suites judiciures ant ete entreprises contre vous Vous avez 20 jotes consecutifs o partir de la date de ('assignation de cane citation pour deposer tine reponse ecrite a In plainte ci-joinke mores de ce tribunal. Un simple coup de telephone est insuflisunt pour vous proteger. Vous eies oblige de deposer votre reponse eCrite, avec mention du numero de dossier cidessus et du nom des panics nominees ici, si vous souhaitez clue le tribunal entende votre cause. Si vous ne dcposez pas votre reponse ecrite dans le rclai requis, vous risquez de perdre la cause ainsi que votre salaire, votre urgent, et vos biens peuvent etre saisis par la suite, sans aueun preavis ulterieur du tnbunal. II y a d'autres obligations juridiques et vous pouvez requerir les services immediats d'un avocat. Si vous ne connaissez pas d'avocal, vous pourriez telephoner a un service de reference d'avocats ou a un bureau d'assistance juridique (figurant aPannuture de telephones).
+
+Si vous choisissez de deposer vous-mane tine reponse ecrite, it vous faudra cgalement, en meme temps que cette fonnalite, faire parvenir ou expedier tine copio de voile reponse ecrite nu "Plaintiff/Plaintiffs Attorney" (Plaignant ou a son avocat) nomme ci-dessous.
+
+En accordance avec Is Lot des "Americans With Disabilities". Les personnes en besoin d'unc accommodation speciale pour paniciper aces procedures dolma, dans tut temps raisonable, avant à'enrreptendre aucune stare démarche, contactor l'office administrative de la Court snot all 5.2500, 205 North Dixie Highway, West Palm Beach, Fl.. 33401 le telephone (561)355- {sup}`2431`ou 1-800.955-8771 ('WD) ou 1-800-955-8770 (V) Via Florida Relay Service.
+
+#### IMPORTANT
+
+D4pré ako ki fe! avek Americans With Disabilities Act, tout mown ki ginyin you hézwen éspésiyal pou akomodasiyon pou yo patisipé nan pwogram sor{sup}`e`dwt, nan yen rézonab avan ninpot aranjman kapab fet, yo dwt kontakte Administrative Office of the Court, Id nan niméro {sup}`205` Nonh Dixie Highway, Chain nimtro 5.2500 West Palm Beach, Florida 33401 telefon nan se (561)355-2431 oubyen 1.800-955-8771 (T.D.D. oubycn 1-800-955-8770 (V) an pasan pa Florida Relay Service.
+
+
+CASE NO: 50 2008 CA 006596 XXXX  
+MB AB
+
+JANE DOE, by and through JANE DOE'S  
+MOTHER, as parent and natural guardian,
+
+
+
+JEFFREY EPSTEIN, [REDACTED] and  
+[REDACTED]
+
+
+JUN 11 2018 7:02 PM 12:42  
+MAILED BY FRED BELL  
+
+
+
+
+[REDACTED]  
+12247772{sup}`NO` COURT NORTH  
+[REDACTED] PALM BEACH, FL
+
+
+A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book).
+
+If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney" named below.
+
+"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 5.2500, West Palm Beach, FL 33401, telephone (561)355-2431, 1-800-955-8771 (TDD), or 1-800-955-8770 (V), via Florida Relay Service".
+
+THEODORE J. LEOPOLD, ESQUIRE  
+RICCI-LEOPOLD, F.A.  
+2925 PGA Boulevard  
+(561) 684-6500
+
+
+TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and a copy of the complaint/petition in this lawsuit on the above named defendant(s).
+
+MAR 18 2008
+
+DATED ON \_\_\_\_\_, 2008.
+
+![](_page_79_Picture_429.jpeg)
+
+SHATRON BOCK  
+CLERK OF THE CIRCUIT COURT  
+By: [Signature]  
+SANDRA CUEVA
+
+Usted ha sido demandado legalmente. Tiene 20 Dias, contados a partir del recibo de esta notificacion, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. Una llamada telefonica no lo protegera. Si usted desea que el tribunal considere su defensa, debe presentar su respuesta por escrito, incluyendo el numbero del caso y los nombres de las partes interesadas. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen otros requisitos legales. Si lo desea, puede usted consultar a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de asistencia legal que aparecen en la guia telefonica.
+
+Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera usted enviar por correo o entregar una copia de su respuesta a la
+
+persona denominada abajo como "Plaintiff/Plaintiffs Attorney" (Demandonte o Abogado del Dernandante).
+
+"De acuerdo con cl Ado 0 (hereto de los Americansos con Impedimentos, Inhabilitados, personas en necesidad del SCNICIO special pars participar en este procedimiento debenin, dentro de wi tiempo nrionable, antes de cualquier procedimiento, ponerse en contact° con la oflicina Administratativa de la Corte, 205 North Dixie Highway, °Bohm 5.2500, West Palm Beach, FL 33401, Telefono (561) 355-2431, I-R00-955-8771 (TDD) 61-800-955-8770 (V), Via Florida kelay Service".
+
+#### IMPORTANT
+
+Des poursuites judiciares ont ete entreprises contre vous. Vous avez 20 jours consecutifs a partir de la date de fassignation dc cene citation pour deposer um reponse ecrite a la plainte ci•jointe aupres dc ce tribunal. Un simple coup de telephone est insuffisant pour vous proteger. Vous etes oblige de deposer votre reponse ecrite, avec mention du numero de dossier cidessus et du nom des parties nominees lei, si vous souhaitez que le tribunal entencle votre cause. Si vous ne deposez pas votre reponse ecrite dans le rclai remits, vous risquez de perdre la cause ainsi que votre salaire, yore argent, et vos biens peuvent eue saisis par la suite, sans aucun preavis ulterieur du tribunal. II y a d'auues obligations juridiques et vous pouvez requerir Its services immeditts d'un avocat. Si vous nc connaissez pas d'avocat, vous pourriez telephoner aun service de reference d'avocars ou a un bureau d'assistance juridique (figurant al'annuaire de telephones).
+
+Si vous choisissez de deposer vous-meme une reponse ecrite, it vous faudra egalement, en meme temps que cette formalite, faire parvcnir ou expedier une copie de votre reponse ecrite au Manua/Plaintiff's Attorney" (Plaignant ou a son avocet) nomme ci-dessous.
+
+En accordance avec In Loi des "Americans With Disabilities". Les personnes en bcsoin d'une accommodation speciale pour paniciper aces procedures doivent, darts un temps raisonable, avant d'entreprendre aucune outre demarche, contacter l'office administrative dc Is Court situe au 5.2500, 205 North Dixie Highway, West Palm Reach, FL 33401 le telephone (561)355- {sup}`2431`ou 1-800-955-8771 (TDD) ou 1-800-955-8770 N) Via Florida Relay Service.
+
+#### IMPORTANT
+
+Dime ako ki fet avek Americans Wilh Disabilities Act, tout moun ki ginyin yun bezwen fspesiyal por. akomodasiyon pou yo patisipe nan pwograrn sa-a dwd, nan yun rezonab avan ninpot aranjman kapab fet, yo dwi kontalcte Administrative Office of the Court, ki nan Minim {sup}`205` North Dixie Highway, Chain nimero 5.2500 West Palm Beach, Florida 33401 telelbn nun s0 (561)355-2431 oubyen 1.800-955-8771 (T.D.D. oubyen 1.800-955-8770 (V) an pasan pa Florida Relay Service.
+
+
+CASE NO: 50 2008 CA 006596 XXXX  
+MB AB
+
+![](_page_82_Picture_27.jpeg)
+
+JANE DOE, by and through JANE DOE'S  
+MOTHER, as parent and natural guardian,
+
+
+
+JEFFREY EPSTEIN, [redacted] and  
+[redacted],
+
+
+
+
+
+[redacted],  
+301 East 66{sup}`th` Street  
+Apt. 10N  
+New York, New York
+
+
+A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book).
+
+If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney" named below.
+
+"In accordance with the Americans with Disabilities Ad, persons in need of a special accommodation to participate in this proceeding shall, within areasonable time prior to any proceeding, contact lt.e Administrative Office of the Court, 205 North Dixie Highway, Room 5.2500, West Palm Beach, FL 33401, telephone (561)355-2431, 1400.955-8771 (MD), or 1.800- 955.8770 (v), via Florida Relay Service".
+
+THEODORE). LEOPOLD, ESQUIRE RICCI—LEOPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL {sup}`33410` (561) 684-6500
+
+
+TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and a copy of the complaint/petition in this lawsuit on the above named defend: o s).
+
+DATED ON HARI 8 Zpos.
+
+![](_page_83_Picture_12.jpeg)
+
+ARON BOCK {sup}`g`ER.K OF THE CIRCUIT COURT SANDRA CUEVA By. {sup}`O`{sup}`a`Deputy Clerk
+
+#### IMPORTANTI
+
+listed ha side demandado legalmente. Tienc 20 Dias, contados a pan ir del recibo de este notification, pars contester la demands udjunta, par escrito, y presenter's ante este tribunal. Una Hamada telethn,ca no In protegera. Si usted desea que el tribunal considere su defense, debe presenter su respuesta por escrito, incluyendo el numbero del caso y los Hombres de las panes interesadas. Si usted no contesta In demands a tiempo, pudiese perder el case y podria ser despojado de sus.ingresos y propiedades, o privado de sus dereclios, sin previa Huts° del tribunal. Existen altos requisito legales. Si lo desea, puede usted consulter a un abogudo inmediatamente. Si no conoce a tin abogado, puede llamas a Una de las oficinas de asisiencia legal que aparecen en hi gui atelefonica.
+
+Si desea responder ala demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera usted enviar por correo {sup}`o`entregar una copia de su respuesta a la persona denominada abajo como "Plaintiff/Plaintiffs Attorney" (Demandante o Abogado del Demandante).
+
+"De acuerdo con el Acto 6 Decreto dc los Americansos con Impedimentos, Inhabilitados, persones en necesidad del servicio special pare participar en este procedimiento deberán, dentro de un tiempo razonable, antes de cualquier procedimiento, ponerse en contacto con la officina Administnitariva de la Corte, 205 North Dixit Highway, oficina 5.2500, West Palm Beach, FL 33401, Téléfono (561) 355.2431, 1.800-955.8771 (TDD) 6 1-800-955-8770 (V), Via Florida Relay Service".
+
+#### IMPORTANT
+
+Des poursuites judiciares ont ere entreprises tontre vous. Vous avez 20 jours consecutifs a partir de la date de Passignation de cene citation pour deposer une reponse unte a la piel= ct-jointe atiples de ce tribunal. Un simple coup de telephone est insuffisant pour vous proteger. Vous etes oblige dc deposer vutre reponse ecrite, avec mention du numero de dossier cidessus el du nom des parties nommees ici, si vous souhaitez que le tribunal entende votre cause. Si vous ne deposet pes yoyo reponse ecrite dans le reta) raquis, vous nsquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre SaiSiS par la suite, sans aucun preavis ultericur du tribunal. II y a d'armes obligations juridiques et vous pouvez requerir les services immediais dun avotan. Si vous ne connaissez pas d'evocar, vous pourriez telephoner aun service de reference d'avocats ou a un bureau d'assistance juridique (figurant al'annuaire de telephones).
+
+Si vous choisissez de deposer vous-meme une reponse ecrite, il vous faudra egalement, en mente temps que cene forrnaltte, faire porvenir ou expedier une copie de votre reponse ecrite au "Pla miff/Plaintiff's Attorney" (Plaignant ou a son avocat) nomme ci-dessous.
+
+En accordance avec la Loi des "Americans With Disabilities". Les personnes en besoin d'une accommodation speciale pour participer aces proeedures doivenl, dans un temps raisonable, ovan: d'en.reprendre encune nutre démarche, contacter Foffice administrative de in Court situé ou 5.2500, 205 North Dixie Highway, West Palm Beach, FL 33401 le telephOne (561)355- {sup}`2431`ou I-800-955-8771 (TDD) ou 1.800-955-8770 (V) Via Florida Relay Service.
+
+#### IMPORTANT
+
+Depré eko ki fet svek Americans With Disabilities Act, tour moun ki ginyin yun bézwen éspésiyal pou akomodasiyon pou yo petisipd mur pwograrn sa-a dwé, nan yun rézonab avan ninpat tranjman kapab let, yo dwé kontakté Administrative Office of the Court, ki aun niméro {sup}`205` North Dixie Highway, Charn niméro 5.2500 West Palm Beach, Florida 33401 téléfon nan sé (561)355-2431 oubyen 1-800-955-8771 oubyen 1-800-955-8770 (V) an pasan pa Florida Relay Service.
+
+RETURN OF SERVICE
+
+
+
+
+Case Number: 502008CA006596XXXXMBAB
+
+JANE DOE BY AND THROUGH JANE DOE'S MOTHER, AS PARENT  
+AND NATURAL GUARDIAN
+
+
+
+JEFFREY EPSTEIN. [REDACTED] AND [REDACTED]
+
+
+RICCI~LEOPOLD, P.A.  
+2925 Pga Blvd. Suite 200  
+
+Received by C.W. SERVICES on the 19th day of March, 2008 at 9:20 am to be served on HALEY ROBSON. 12247  
+72nd COURT NORTH, [REDACTED] PALM BEACH, FL
+
+I, Alan J. Cutler, do hereby affirm that on the 21st day of March, 2008 at 8:34 pm. I:
+
+SERVED BY RESIDENTIAL SUBSTITUTION by leaving a true copy of this Summons and Complaint with the date and time of service endorsed thereon by me. This address is the above named subject's usual place of abode. The court document was served to a person residing at this numerical who was verified to be 15 years of age or older and was identified as TOMMY [REDACTED] /FATHER and informing this subject of the contents thereof.
+
+I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process Server in good standing in the judicial circuit in which the process was served.
+
+
+(661) 630-4866
+
+Our Job Serial Number: 2008034295
+
+IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM REACH COUNTY FLORIDA
+
+CASE NO: 50 2008 CA 006596 XXXX MB AB
+
+JANE DOE, by and through JANE DOE'S MOTHER, as parent and natural guardian,
+
+
+
+"9.
+
+JEFFREY EPSTEIN, and SARAH
+
+
+
+
+TO DEFENDANT;
+
+mops 12247 72 COURT NORTI I PALM BEACH, FL
+
+#### IMPOgI NT
+
+
+rd
+
+Alawsuit has been filed against you. You have 20 calendar days atter this summons is sewed on you to file a written response to the attached taamplaint/petition with the Clerk of this Court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the Court to hear your side of the case. If you do not file yogi response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There arc other legal requirements. You mt.y want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or {sup}`a`legal aid office (listed in the phone book)
+
+If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/ Plaintiffs Attorney' named below.
+
+"In accordance with the Americans with Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 5, 2500, West Palm Beach, FL 33401, telephone (561)355-2431, 1-800-955-8771 (TDD), or 1-800-955-8770 (V), via Florida Relay Service".
+
+THEODORE J. LEOPOLD, ESQUIRE  
+2925 PGA Boulevard  
+(561) 684-6500
+
+
+TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and a copy of the complaint/petition in this lawsuit on the above named defendant(s).
+
+MAR 18 2008
+
+DATED ON \_\_\_\_\_, 2008.
+
+![](_page_88_Picture_419.jpeg)
+
+SHERON BOCK  
+CLERK OF THE CIRCUIT COURT
+
+
+SANDRA CUEVA
+
+Used ha sido demandado legalmente. Tiene 20 Dias, contados a partir del recibo de esta notificacion, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. Una llamada telefonica no lo protegera. Si usted desea que el tribunal considere su defensa, debe presentar su respuesta por escrito, incluyendo el numbero del caso y los nombres de las partes interesadas. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen otros requisitos legales. Si lo desea, puede usted consultar a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de asistencia legal que aparecen en la guia telefonica.
+
+Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera usted enviar por correo o entregar una copia de su respuesta a la
+
+persona denominada abajo como "Plaintiff/Plaintiff's Attorney" (Demandante o Abogado del Demandante).
+
+"De acuerdo con el Acto ó Decreto de los Americansos con Impedimentos, Inhabilitados, personas en necesidad del servicio special para participar en este procedimiento deberán, dentro de un t.empo razonable, antes de cualquier procedimiento, ponerse en contacto con la officina Administrativa de la Corte, 205 North Dixie Highway, oficina 5.2500, West Palm Beach, FL 33401, Téléfono (561) 355-2431, 1-800-955-8771 (TDD) ó 1-800-955-8770 (V), Via Florida Relay Service".
+
+
+Des poursuites judiciares ont ete entreprises contre vous. Vous avez 20 jours consecutifs a partir de la date de l'assignation de cette citation pour deposer une reponse ecrite a la plainte ci-jointe aupres de ce tribunal. Un simple coup de telephone est insuffisant pour vous proteger. Vous etes oblige de deposer votre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des parties nommees ici, si vous souhaitez que le tribunal entende votre cause. Si vous ne deposez pas votre reponse ecrite dans le relai requis, vous risquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre saisis par la suite, sans aucun preavis ulterieur du tribunal. Il y a d'autres obligations juridiques et vous pouvez requerir les services immediats d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez telephoner a un service de reference d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaire de telephones).
+
+Si vous choisissez de deposer vous-meme une reponse ecrite, il vous faudra egalement, en méme temps que cette formalite, faire parvenir ou expedier une copie de votre reponse ecrite au "Plaintiff/Plaintiff's Attorney" (Plaignant ou a son avocat) nomme ci-dessous.
+
+En accordance avec la Loi des "Americans With Disabilities". Les personnes en besoin d'une accommodation speciale pour participer a ces procedures doivent, dans un temps raisonable, avant d'entreprendre aucune autre démarche, contacter l'office administrative de la Court situé au 5.2500, 205 North Dixie Highway, West Palm Beach, FL 33401 le telephone (561)355-2431 ou 1-800-955-8771 (TDD) ou 1-800-955-8770 (V) Via Florida Relay Service.
+
+
+Dapré ako ki fet avek Americans With Disabilities Act, tout moun ki ginyin yun bézwen éspésiyal pou akomodasiyon pou yo patisipé nan pwogram sa-a dwé, nan yun rézonab avan ninpot aranjman kapab fet, yo dwé kontakté Administrative Office of the Court, ki nan niméro 205 North Dixie Highway, Cham niméro 5.2500 West Palm Beach, Florida 33401 téléfon nan sé (561)355-2431 oqbyen 1-800-955-8771 (T.D.D. oqbyen 1-800-955-8770 (V) an pasan pa Florida Relay Service.
+
+IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN  
+AND FOR PALM BEACH COUNTY FLORIDA
+
+JANE DOE, by and through JANE  
+DOE'S MOTHER, as parent and natural  
+guardian
+
+CASE NO. 50 2008 CA006596  
+XXXX MB
+
+*AB*
+
+FILED  
+08 APR 10 PM 4:12  
+CLERK  
+CIRCUIT COUNTY, FL
+
+FILED
+
+
+
+JEFFREY EPSTEIN. [REDACTED]  
+[REDACTED] and [REDACTED]
+
+
+MOTION TO QUASH SERVICE OF PROCESS
+
+COMES NOW [REDACTED] by and through her undersigned attorneys,  
+and files this Motion to Quash Service of Process, and as grounds therefore would  
+state as follows:
+
+1. Florida Statute §48.031(1) allows service of original process  
+by delivering a copy of it to the person to be served or by leaving copies at his or her  
+usual place of abode with any person residing there who is fifteen years or older and  
+informing that person of their contents.
+
+2. An agent for counsel for the Plaintiff purports to have served  
+[REDACTED] with a copy of the Complaint via residential substitution on March  
+21, 2008 at 8:34 p.m. (A true and correct copy of the Return of Service is attached)
+
+
+hereto as Exhibit A.) As the Court can see, the agent for the Plaintiff who served the Summons and Complaint purports to have served the same on Tommy [REDACTED], who is identified as [REDACTED] father. Said service was purportedly made at 12247 72nd Court North, [REDACTED] Palm Beach, Florida, located in Palm Beach County.
+
+3. On March 21, 2008, [REDACTED] usual place of abode was not 12247 72nd Court North, [REDACTED] Palm Beach, Florida, in Palm Beach County. Rather, [REDACTED] usual place of abode on March 21, 2008, was an entirely different location. [REDACTED] did not authorize anyone, including Tommy [REDACTED], to accept service of process on her behalf. Therefore, this service was not proper and was ineffective.
+
+4. It is well recognized in Florida that a person's usual place of abode is defined as the place where the person is actually living at the time of service. *See Shurman v. Atlantic Mortgage and Investment Corp.*, 795 So. 2d 952 (Fla. 2001). In the Shurman opinion, the Supreme Court of Florida also confirmed that "statutes governing service of process are to be strictly construed and enforced." *Id. at 954.*
+
+5. There are different schools of thought as to the most appropriate way to challenge service of process. There is also some confusion with regard to whether filing a motion other than a Motion to Quash Service of Process waives one's right
+
+
+to move to quash service of process. Therefore, files this Motion to Quash Service of Process in lieu of any other type of motion or responsive pleading pursuant to the Fourth District Court of Appeal's opinion in &mbar, v. Smcsmim which holds that the "preferable manner of presenting adefense of insufficiency of service of process ...is by aMotion to Quash such allegedly insufficient service of process rather than ny a Motion to Dismiss the Complaint." &tabor' v. Sussman {sup}`439` So. 2d 1046, 1047 (Fla. e DCA 1983).
+
+6. reserves the right to supplement this motion with evidence to support it.
+
+WHEREFORE, respectfully moves this Honorable Court for the entry of an Order granting Motion to Quash the Service of Process.
+
+# ccial MATE OF SERVICE
+
+WE HEREBY CERTIFY that a true and comet copy of the foregoing was furnished via regular mail to Theodore J. Leopold, Esq., Ricci-Leopold, P.A., {sup}`2925` PGA Boulevard, Suite 200, P.O. Box 2946, Palm Beach Gardens, FL 33410, this 10th day of April, 2008.
+
+
+McINTOSH, SAWRAN, PELTZ  
+& CARTAYA, P.A.  
+Centurion Tower  
+1601 Forum Place, Suite 1110  
+West Palm Beach, Florida 33401  
+Telephone: (561) 682-3202  
+Facsimile: (561) 682-3206
+
+
+DOUGLAS M. McINTOSH  
+Florida Bar No. 325597  
+**JASON A. McGRATH**  
+Florida Bar No. 97349
+
+RETURN OF SERVICE
+
+
+
+
+Case Number: 502008CA00656XXXXMBAB
+
+JANE DOE BY AND THROUGH JANE DOE'S MOTHER, AS PARENT  
+AND NATURAL GUARDIAN
+
+vt.
+
+JEFFREY EPSTEIN, [REDACTED] AND [REDACTED]
+
+RICCI-LEOPOLD, P.A  
+2025 Pgo Blvd. Suite 200  
+
+CIRCUIT CIVIL
+
+Received by C.W. SERVICES on the 19th day of March, 2008 at 9:20 am to be served on HALEY ROBSON, 12247  
+72nd COURT NORTH, [REDACTED] PALM BEACH, FL.
+
+I, Alan J. Cutler, do hereby affirm that on the 21st day of March, 2008 at 8:34 pm, I:
+
+SERVED BY RESIDENTIAL SUBSTITUTION by leaving a true copy of this Summons and Complaint with the date and time of service endorsed thereon by [REDACTED]. This address is the above named subject's usual place of abode. The court document was served to a person residing at this numerical who was verified to be 15 years of age or older and was identified as TOMMY ROBSON/FATHER and informing this subject of the contents thereof.
+
+I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process Server in good standing in the judicial circuit in which the process was served.
+
+*Alan J. Cutler*
+
+
+(861) 630-4866
+
+Our Job Serial Number: 2008034295
+
+Copyright © 1983-2006 Database Devices, Inc. - Process Server's Trademark V5.8
+
+![](_page_95_Picture_426.jpeg)
+
+**RETURN OF SERVICE**
+
+
+
+
+Case Number: 502008CA006596XXXXMBAB
+
+**JANE DOE BY AND THROUGH JANE DOE'S MOTHER, AS PARENT  
+AND NATURAL GUARDIAN**
+
+
+
+**JEFFREY EPSTEIN, [REDACTED] AND [REDACTED]**
+
+
+2925 Pga Blvd Suite 200  
+
+PALM BEACH CIVIL  
+CIRCUIT COURT
+
+2008 MAY 20 AM 10:05
+
+Received by C W SERVICES on the 14th day of May, 2008 at 3:59 pm to be served on **JEFFREY EPSTEIN, 368 EL BRILLO WAY, PALM BEACH FL. 33480**
+
+I, Alan J. Cutler, do hereby affirm that on the 16th day of May, 2008 at 9:15 am, I:
+
+**SERVED BY RESIDENTIAL SUBSTITUTION** by leaving a true copy of this Summons and Complaint with the date and time of service endorsed thereon by me. This address is the above named subject's usual place of abode. The court document was served to a person residing at this numerical who was verified to be 15 years of age or older and was identified as **JANJSZ BANASIAK (LIVE IN HOUSE MANAGER)** and informing this subject of the contents thereof.
+
+**Military Status:** Based upon inquiry of party served, defendant is not in the military service of the United States.
+
+I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process Server in good standing in the judicial circuit in which the process was served.
+
+
+(561) 630-4866
+
+Our Job Serial Number: 2008035775
+
+Hot u. wr Page 45/51 Date 5129/2335 "2 {sup}`091`{sup}`M`
+
+
+JANE DOE, by and through JANE DOE'S MOTHER, us parent and natural guardian,
+
+
+
+JEFFREY EPSTEIN, and
+
+Defendunts.
+
+
+#### SUMMONS
+
+3 c/2 96 7
+
+IN THE CIRCUIT COURT OF THE 15Th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORI DA
+
+CASK NO: 50 2008 CA 006596 XXXX MB AR
+
+#### PERSONAL SERVICE ON A NATURAL PERSON
+
+JEFFREY EPSTEIN 457 Madison Avenue 46Floor New York, New York /Oa 7.2.-
+
+#### IMPORTANT
+
+{sup}`A`lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the Clerk of this Court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must he filed if you want the Court to hear your side of the case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or {sup}`a`legal aid office (listed in the phone book).
+
+If you choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/ Plaintiffs Attorney" named below.
+
+tt .
+
+"In accordance with the Americans with Disabilities Act, persons in need of n special accommodation to participate in this proceeding shall, within a reasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 North Dixie Highway, Room 5.2500. West Palm Beach, FL 33401, telephone (561)355-2431, 1.800-955.8771 (TDD), or I.800- 955.8770 (V), via 1{sup}`7` orida Relay Service".
+
+THEODORE J. LEOPOLD. ESQUIRE RICCI-LE.OPOLD, P.A. 2925 PGA Boulevard Suite 200 Palm Bench Gardens, FL 33410 (561)684-6500
+
+
+TO EACH SHERIFF OF THE STATE! You are commanded it {sup}`t`serve d is \$umrdons and fl copy of the complaint/petition in this lawsuit on the above named defenclautt(s). III
+
+DATED ON
+
+![](_page_99_Picture_7.jpeg)
+
+#### IMPORTANTE
+
+By: Deputy Clerk
+
+listed ha sido demundudo lep,almente. Tiene 20 Dias, contados a partir del recibo de esta notificacion, papa contester la dementia adjunta, per escrito, y presentarla ante este tribunal. Una llainada telefort.co no lo protegera. Si usted desea que el tribunal considere su defense, debe presenter su respuesta por escrito incluyendo el numbcro del caso y los nonlbres dc las panes interesudas. Si timed no contests la demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propieducles, o privado de sus derechos, sin previo aviso del tribunal. Existen otros requisi.os legates Si lo desea, puede usted consultar a un abogado inntechatamente. Si no conoce a un abogado, puede Ilamar a una de las oficinas de asistencia legal que aparecen en la guia telefonica.
\ No newline at end of file