---
title: "FOIA Records: Florida (EFTA02857159)"
source: "FOIA Records: Florida"
sourceUrl: "https://www.justice.gov/epstein/files/Freedom%20of%20Information%20Act%20%28FOIA%29/Florida/EFTA02857159.pdf"
date: "2026-08-12"
category: "FOIA"
eftaNumber: "EFTA02857159"
ocrPages: 1
ocrChars: 319728
ocrElapsed: 0.0
parseTier: "internal"
engine: "marker-pdf 1.5.5 + surya-ocr 0.12.1"
---
I 07/26/17 Page 2609 Public Records Request No.: 17-295
#### **DA - NOTICE TO RENTERS**
36173
s insurance primary: The valid and collectible liability insurance and personal injury protection insurance of any authorized rental or driver is primary for the limits of liability and personal injury coverage required by ss.324.021 (7) and 627.736, Florida Statutes.
to return rental Vehicle: Failure to return rental property or equipment upon expiration of the rental period and failure to pay all s due (including costs for damage to the property or equipment) are prima facie evidence of intent to defraud, punishable in accorvith section 812.155, Florida Statutes.
erms supersede any conflicting terms stated elsewhere.
Agreement is between the undersigned and the company identified above (the "Company"). By signature below, the undersigned acknowledges and represents that they are legally authorized to operate the rental vehicle we's license, and that they have read and agree to the terms, conditions and notices, both printed and written, including the Loss Damage Waiver information, that appear on this Rental Statement and on the separate (the "Agreement"), which is incorporated therein. THE UNDERSIGNED AUTHORIZE THE COMPANY TO PROCESS A CHARGE TO THEIR CREDIT, DEBIT OR CHARGE CARD IN THE AMOUNT SPECIFIED ABOVE RETURN OF THE VEHICLE. ALL CHARGES SUBJECT TO AUDIT. No additional drivers are permitted without the approval.
| Bannin | RENTER X | ADDITIONAL DRIVER |
|--------|----------|-------------------|
| | |
|
295
Public Records Request No
16
:S
## Jeffrey E. Epstein
10 Dr. Berd
1100
to more 11° uz than
calle work at le ou
. 5
trying
## Jeffrey E. Epstein
11 (rerent the cor) - contract up on 2nd of february Dollar Rond D Con Blue Dodge Noon (561) 686- 3300 Jeffrey E. Epstein 07/26/17 Page 2613 Public Records Request No.: 17-295
car extansion Imonth
29 pm butet of roses to Royal Palm Beach High school for
bive the flowers of
8:30 to sb. to give it to her fat the stage ofter performance
DTG OPERATIONS dba DOLLAR RENT A CAR 2401 Turnage Boulevard West Palm Beach, FL 0000033 866-434-2226
West Palm Beach Int'
1 2 4
i.
BANASIAK JANUSZ
358 EL BRILLO WAY
PALM BEACH
FL
33480
1270
FL
04/07/2012
ADD'L DRIVER: None
SLI PPP ESP 561-818-8361
CUSTOMER DECLINES LOW AND IS RESPON-SIBLE FOR LOSS OR DAMAGE PER TERMS OF THE RENTAL AGREEMENT. UMP DECLINED
Rate: WALK Cls: CDAR 920001
VEH.#: 817622-1 L1C.#: W28G15
NISSAN
FUEL LEVEL OUT: FULL MILEAGE OUT:
05
ACCEPT @ 11.95/DAY 322.65 DECLINED DECLINED Est Optional Coverages 322.65
STALL#:
SENTRA
11230
BY YOUR INITIALS YOU ACKNOWLEDGE YOU HAVE ACCEPTED OR DECLINED THE ABOVE OPTIONAL ITEMS: X
| | 12/23/2005 104 | 0 | HH1154 | 84-5 |
|---|----------------------------|--------------|--------|---------|
| | TIME OU
11/26/2005 | | TIME | IN |
| | **RENTAL RAT | ES** | | EST CHG |
| | Hours | 12.00/ | mls | |
| • | | 24.99/ | mls | |
| | Weeks | 124.95/ | mls | 499.80 |
| | Xday | 24.99/ | mls | |
| | Unlimitd mls | | | |
| | VEH LIC FEE
FLA SRCHRG* | .47/Day | | 12.69 |
| | FLA SRCHRG* | 2.03/Day | | 54.81 |
| | Fuel | 5.99/gal | | |
| | STATE TAX
Est Optional | 6.500% | | 36.87 |
| | Est Optional | Coverages | | 322.65 |
| J | **EST | IMATED CHAR | GES** | 926.82 |
| | YOU ARE RESP | | | |
| | VIOLATIONS. | IF YOU FAIL | TO PA | YOUR |
| | TICKET(S), A | NY UNPAID T | ICKET | 5), |
| | PENALTIES, P | LUS A \$25.0 | O FEE | PER |
| | CITATION, WI | LL BE BILLE | D TO Y | DUR |
| | CREDIT CARD. | x | | |
| | ESTIMATED/AC | TUAL CHARGE | S MAY | ARY |
| | | | | |
\* FL Surchg includes \$2 FL St Srchg & .03 Recycle Fee Recv CREDIT CARD AUTHORIZATION/CASH DEPOSITS VI/\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*
CUSTOMER HAS NOT USED THE AIRPORT IN THE LAST 24 HOURS.
WLK SMCKED/187
A per hour rate for late returns is charged right after the start of new Rental Day.
\* 44
.
| 12-20-2005 14:45:56 JJ8375 JJ837 | 5 00 | DTG OPERATIONS | dba DOLLAR RENT A CAR |
|----------------------------------|------|----------------|-----------------------|
| | | DIG OFERALIONS | UDG DULLAR KENT A LAK |
tuls05
Report #0492 Page 0001
| | Screen Print |
|-----------------------------------|---------------------------------------|
| | Dollar RA OPEN HH115484 OPEN |
| 1 NME L/F BANASIAK/JANUSZ | 11 RET DATE/THE 12-23-2005/1040 |
| 2 ADDRESS 358 EL BRILLO WAY | 12 RET LOC/DROP PBI/* |
| 3 C/S/Z PALM BEACH/FL/33480 | 13 VEH/CL/RT/CL 817622/CDAR/WALK/CDAR |
| 4 PH/DOB/GEN 561-818-8361/04-07-1 | 1953/M 14 ODM/FUEL 11230/8 |
| 5 LOCL CNT 5616557626 | 15 EMP/OPEN EMP/DRW SMCKED/SMCKED/187 |
| 6 L1/ST/EX/VER B522420531270/FL/0 | 04-07-2012/* |
| 7 FOP/#/EX V1/4470115340008274/02 | 2-07 A-RATES G-DTS/MISC |
| 8 ATH#/AMT 050298/1066 | B-DB/CUST K-RA CLOSE |
| 9 SR/TY/ID WLK/W/*/* | C-DEPOSIT N-NOTES |
| 10 NOTES * | D-OPTIONS C-OTHER WINDOWS |
| F1=RD ONLY F2=SWIPE F3=ERASE F6=S | |
-- End of report --
07/26/17 Page 2617 Public Records Request No.: 17-295
IMPORTANT MESSAGE IMPORTANT MESSAGE FOR FOR TIME 10: 40 MM 105 TIME 10:00 DATE DATE SMI M OF. CF. PHONE/ PHONE 72-971-1000 MOBILEC MOBILE TELEPHONED PLEASE CALL PLEASE CALL TELEPHONED CAME TO SEE YOU CAME TO SEE YOU WILL CALL AGAIN WILL CALL AGAIN WANTS TO SEE YOU RUSH WANTS TO SEE YOU RUSH RETURNED YOUR CALL SPECIAL ATTENTION RETURNED YOUR CALL SPECIAL ATTENTION 15 MESSAGE. MESSAGE . and she can' come today a SIGNED 8 SIGNED. 1184 1184 RIGNED 12 IMPORTANT MESSAGE FOR 10/2/05 TIME 10:20 FM DATE ono 407 M 100/1 801-3590 MAIXADO OF. PHONE/ MEGSAGE MOBILE X PLEASE CALL TELEPHONED SPECIAL ATTENTION RETURNED YOUR CALL WILL CALL AGAIN CAME TO SEE YOU HSON WANTS TO SEE YOU RUSH WANTS TO SEE YOU CAME TO SEE YOU MITT CVIT YEVIN SPECIAL ATTENTION RETURNED YOUR CALL PLEASE CALL **LELEPHONED** MOBILE MESSAGE. /BNOHd - 20 HO " IN DATE Tible 50/1 2 FOR IMPORTANT MESSAGE 07/26/17 Page 2620 Public Records Request No.: 17-295 B 1184
# GUERLAIN SKIN CARE R
NAME: EMAIL:
TELEPHONE:
DO YOU HAVE ANY CONCERNS WITH THE FOLLOWING?
**D** LINES DEHYDRATION BREAKOUTS □ IRREGULAR TEXTURE □ IRREGULAR COLOR
D PIGMENTATION
1×a week PUB 2-3 week
O
DRY
**DEYE PUFFINESS** DARK CIRCLES
0
HIGHLY SENSITIVE
NIGHT MOISTURIZERS:
MASKS/EXFOLIATORS:
PURIFYING INVIGORATING MASK L
BAUME DE LA FERTE LIP BALM\_\_\_\_
SUCCESSLASER DAY CARE\_
SUCCESSLASER CONCENTRATE
SUBSTANTIFIC FIRMING NECK CREME\_\_\_\_
MOISTURIZING INVIGORATING MASK
SUBSTANTIFIC NIGHT CARE
SUCCESS NIGHT MODEL
SMOOTHING EXFOLIATOR
SPECIAL CARE:
CRÉME CAMPHRÉA
SERENISSIMA
S.O.S. CREAM
S.O.S. SERUM
WHAT WOULD YOU LIKE TO CHANGE ABOUT YOUR SKIN?
#### WHAT IS YOUR SKIN TYPE?
| | | and the second second | |
|--------|-------------|-----------------------|--|
| | | | |
| OILY · | NORMAL/OILY | NORMAL/DRY | |
| | | | |
#### CLEANSERS:
V PURE VEIL CLEANSING MILK
PURE DEW CLEANSING FOAMING GEL PERFECT EYE AND LIP MAKEUP REMOVER.
#### TONERS:
PURIFYING IRIS TONER MOISTURIZING MALLOW TONER SUCCESS SMOOTHING TONER
#### EYE CARE:
SUCCESS EVE TECH EYESERUM HAPPYLOGY EYE CREAM SUBSTANTIFIC EVE AND LIP
#### DAY MOISTURIZERS: V HAPFYLOGY CLA
- SUCCESS MODEL SERUM
- SUPER AQUASÉRUM
- SUBSTANTIFIC DAY CREAM
THANK YOU FOR OFFERING ME THE OPPORTUNITY TO PROVIDE YOU WITH OUR EXCLUSIVE **GUERLAIN FACIAL EXPERIENCE!** 10.1.05 GRACE
PRESCRIBED BY: \_
#### ONE SOUTH COUNTY ROAD • PALM BEACH, FL 33480 • (877) 448-3752
SCI EDULE I
#### THE NEW ALBANY COMPANY ANALYSIS OF THE NACO AND GEORGETOWN CAPITAL ACCOUNTS FROM 1/1/2002 - 12/31/2004 As of 1/20/2005
#### 100 % POSITIVE CASH FLOW APPLIED TO NACO'S INTEREST PAYMENT AND A REDUCTION OF NACO'S CAPITAL ACCOUNT: INTEREST ON GEORGETOWN CAPITAL ACCRUED INTEREST ONLY APPLIED FOR THE YEAR 2004
| 1 | NACO CAPITAL | | Cash Plew from
Operations (1)(3) | Interest
Expense (2) (3) | Capital Additions/
(Reductions)(3) | Capital Account
Balance (4) |
|---|--------------|--------|-------------------------------------|-----------------------------|---------------------------------------|--------------------------------|
| | 2002 | | 10,546,345 | (4,875,000) | (5.671.345) | 75,000,000
69,328,655 |
| | 2003 | | 20,162,655 | (4,506,363) | (15,656,292) | 53,672,363 |
| | 2004 | | 18,414,244 | (3,488,704) | (14,925,540) | 38,746,822 |
| | | Totals | 49,123,244 | (12,870,066) | (36,253,178) | |
| IJ | GEORGETOWN CAPITAL | Cash Flow from
Operations (1)(3) | Interest
Expense (2) (3) | Capital Additions/
(Reductions)(3) | Capital Account
Balance (4) |
|----|--------------------|-------------------------------------|-----------------------------|---------------------------------------|--------------------------------|
| | 2002 | 1.6.1 | (650,000) | 650,000 | 10,000,000 |
| | 2003 | 1. The 1 . | (692,250) | 692,250 | 11,342,250 |
| | 2004 | - | (737,246) | 737,246 | 12,079,496 |
| | Totals | e . | (2,079,496) | 2,079,496 | |
III SUMMARY OF NACO & GEORGETOWN CAPITAL ACCOUNT ACTIVITY
| | Cash Flow from
Operations (1)(3) | Interest
Expease (2) (3) | Capital Additions/
(Reductions)(3) | NACO Capital
Balance (4) | Georgeto vn Capital
Bala: ce (4) | |
|-------|-------------------------------------|-----------------------------|---------------------------------------|-----------------------------|-------------------------------------|--|
| 2402 | 10,546,345 | (5,525,000) | (5,021,345) | 69.328,655 | 10.650,000 | |
| 2003 | 20,162,655 | (5,198,613) | (14,964,042) | 53,672.363 | 11,342,250 | |
| 2004 | 18,414,244 | (4,225,950) | (14,188,294) | 38,746,822 | 12.079,496 | |
| Total | 49,123,244 | (14,949,562) | (34,173,682) | | | |
| | | | | | | |
(1) See page 2 of the Calculation of Estimated Performance Fee for detail of the Managed Cash Flows for years 2002-2004 . Please note New Albany Country Club is not included until 1/1/2005
All Cash Flows are used to pay NACO Interest and any excess is applied as a NACO Capital Account reduction.
(2) The Annual Interest rate is 6.5%. Interest is calculated on the previous Year's Ending Capital Account Balance. Interest Payments and Capital Account Additions (Reductions) are applied at the end of Calendar Year.
(3) Positive Cash flow from Managed Properties is applied in the following order: (i) Interest Expense for NACO if any, and the balance applied to reduce the NACO Capital Account until balance is Zero. If the Cash Flow is insufficient to pay the current interest expense then the unpaid portion of the interest
will be added to the Capital Account Balance. Interest on Goorgetown's Capital sources and is added to the Capital Account. Interest for 2004 is based on 124 days and a 366 day year.
(4) Capital Account Balance as of January 1, 2002 is \$85,000,000. NACO is allocated \$75,000,000 or \$8,24% and Georgetown is allocated \$10,000,000 or 11.76%. Thereafter, the Capital Account Balance is the sum of the Capital as of January 1, 2002 plus Additions and less any Reductions. The Capital Account Balance is an of the end of each Calendar Year.
Prepared by Brent Bradbury 9/30/2005
I - 1
#### New Albany Company Georgetown "Managed Properties" Comparison of Estimated Value and Performance Fee For the Periods 1/1/2002 and 12/31/2004
e
| | Estimate as of
12/31/2004 | As of | Estimated |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------|
| Estimated Performance Fee Payable to Georgatown
Initial Vested Amount (per agreement)
Interest from the Effective date (see Schedule I, Section II Georgetown Capital) | \$ 10,000,000
2,079,496 | \$ 10,000,000 | 2,079,496 |
| 20% of Estimated Incremental Change in Value (Future Amount, see calculation below)
Estimated Performance Fee Payable | 29,526,315
\$ 41,605,811 | and the second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second second s | 29,526,315 |
| Calculation of Estimated "Final" Remaining Yalue
Cash Flow from Managed Properties for the year 2002 -2004(sec Schedule II) | \$ 49,123,244 | | :: 49,123,244 |
| Estimated Value of Managed Properties Remaining (1) | 98,508,332 | | 13,508,332 |
| Estimated "Final" Remaining Value | \$ 147,631,576 | \$ \$5,000,000 | 1: 62,631,576 |
| Calculation of "Besinging Value" Plus "Carry Cost"
Beginning Value
Carry Cost (see Schedulo I-1, Section III Summary of Capital Account Activity) | \$ 85,000,000
14,949,562 | 85,000,000 | 14,949,562 |
| "Beginning Value" Plus "Carry Cost " | \$ . | 85,000,000 | (85,000,000) |
| Calculation of Estimated "Future Amount"
Estimated "Final" Remaining Value
"Beginning Value" Plus "Carry Cost " | \$ 147,631,576 | \$ 85,000,000
(85,000,000) | 62,631,576
85,000,000 |
| Estimated Incremental Change in Value (Puture Amount) | \$ 147,631,576 | s . | 147,631,576 |
| 20% of Estimated Incremental Change in Value (Future Amount) | \$ 29,526,315 | * : ÷ | 29,526,315 |
| (1) Estimated Value of Managed Properties Remaining
Sell-Out Lands Estimated Cash Flow
Discount on Sell-Out Lands | Estimate as of
12/31/2004*
\$ 155,614,000
(59,828,000) | As of
1/1/2001
\$169,907,696
(117,236,310) | Estimated
Change
(14,293,696)
57,408,310 |
| Sell-Out Lands Estimated Value after disconat
Bulk Land (Licking County & Misc)
Development Projects | 95,786,000
19,100,000 | 52,671,386
18,798,988 | 43,114,614
301,012 |
| Duke JV
Market Square (12/31/2004 value reflects mortgage)
Duffy Condo JV
Signature Office (to be transformed to Excluded Properties)
JPI JV (Value/Payment included in Cash Flow from Managed Properties)
New Albany Country Club (Assumed Value is zero as of 12/31/2004) | 2,266,332
3,054,000
750,000
700,000 | 2,144,000
6,785,626
| 122,332
(3,731,626)
750,000
700,000
(600,000)
(4,000,000) |
| Contingency and G&A Adjustment | \$ 121,656,332
(23,148,000) | \$ 85,000,000 | \$ 36,656,332
(23,148,000) |
| Estimated Value of Managed Properties Remaining | \$ 98,508,332 | \$ 85,000,000 | \$ 13,508,332 |
\*Sell-Out Lands includes increases for properties purchased and decreases for properties sold during the 2002-2004 time p midd thereby making comparisons difficult.
Prepared by Brent Bradbury 9/30/2005
THE NEW ALBANY COMPANY
| Jeffrey Epstein | Brent Bradbury |
|---------------------------------------------------------|------------------------------------|
| COMPANY: | 9/30/2005 |
| PAX NUMBER:
212-750-0381 | TOTAL NO. OF PAGES INCLUDING COVER |
| PHONE NUMBER: | SENDER'S REPERENCE NUMBER: |
| Comparison of Values Managed and
Excluded Properties | YOUR REPERENCE NUMHER |
NOTES/COMMENTS:
Jeffrey,
Attached is a schedule comparing the value of the Managed Properties as of 1/1/2002 and the estimated value as of 12/31/2004, including the calculation of the Performance Fee.
Regarding your request for the value of the Excluded Properties as of 1/1/2002, the E&?' appraisal done in 2001 only included "Managed Properties". Approximately 1,000 acres wer: not included in the E & Y appraisal because they were identified before the appraisal as Excluded Properties. In addition, a significant portion of the acres (approximately 100(1) included in the appraisal were transferred to Excluded Properties before the Beginning Valu: was finalized. If you would like me to prepare an estimate the value of the Excluded Properties as of 1/1/2002 please let me know.
Regards,
Dear Mr. Epstein:
I hope you have seen the program and other materials for the 2005 North American regional meeting coming up on November 4-6 in Montreal. We have not heard from you about attending and want to be sure you are aware of the meeting and have had a chance to consider attending. To that end, I attach the program and a reservation form.
Please let us know if you can attend or not. Just reply to this email or send in a completed reservation form.
Thanks,
Michael O'Neil
Page 1 of 1
Fage 1 of 29
GMai
## FW: [Fwd: [Fwd: Re: contract]]
Razek. Ed To: @gmail.com
Jeffrey-
FYI.
Ed
-----Original Message----From: William Mook [mailto:william.mook@mokindustries.com] Sent: Thursday, September 29, 2005 12:49 PM To: Razek, Ed Subject: [Fwd: [Fwd: Re: contract]]
Ed,
We're working with Merrill investment bank and Delta to raise \$50 million by selling at a discount the first \$600 million worth of jet fuel from our production schedule. The \$600 million will have an opportunity to be re-invested for equity in the fuel facility to create an opportunity for additional earnings at the investor's option. Assuming we get a 3:1 multiplier in this second round, the \$50 million could conceievably net the investors \$1.8 billion in less than 3 years. We're looking at 10 shares of \$5 million each - its all spelled out in the enclosed literature.
Let me know if there is any interest by Jeffrey Epstein, or anyone you know. Let me know what you need from me to help make this happen. Where possible -and necessary- we have agreed to pay finders fees that are convertible to share interest.
Once we have the \$50 million we'll move the program past feasability to the point where project financing is possible. The Delta contract is worth nearly \$18 billion. The value of the jet fuel produced by the installation once complete will be around \$60 billion - assuming a 20 year life.
Thanks.
Bill Mook, Mok Industries, LLC and CHW, Inc.
begin 666 ATT907843.eml M6"U-:6UE3TQ%.B!021-:6-R;W-O9G0@17AC:&%N9V4@5C8N M-2XW,C(V+C -"D-O;G1E,G0M8VQA
Fri, Sep 30, 2005 at 10:26 AM
12
**新闻日本日下**。
METRO REFUNDS
PAGE 01/85
## METROPOLITAN REFUNDS 138 EAST PARK AVENUE LONG BEACH, NEW YORK 11561 TEL (516) 889-6664
FAX (516) 889-6665
Property & Tax Consultants -- Utility Auditors -- Reducing Your Operating Costs
### FACSIMILE TRANSMITTAL SHEET
| Jeffrey E. Epstein | Michael Janin | |
|---------------------------------------|---------------------------------|---|
| COMPANY:
11 East 71st Street Trust | DATE:
9-29-05 | • |
| FAX NUMBER:
2123718042 | TELEPHONE NUMBER:
2127509790 | |
| TOTAL NO. OF PAGES INCLUDING COVER: | OUR REFERENCE NUMBER: | |
| Oil Auditing Program | | |
Thought this would be of interest to you. Please review and call us if you are interested.
age 2628
EFTA02857178
(an come either on buturday or Sunday. She requires 4 hours minimum as she will treke day off at work. 150\$ an hair. She needs car to bring her bend take her home.
## Jeffrey E. Epstein
7eb Mail Message
AGENT RS/RS BOOKING REF ZKAZC6
SHOPPERS TRAVEL **196 PRINCETON-HIGHTSTOWN RD** WEST WINDSOR NJ 08550 609 936-0808
DATE: SEP 29 2005
29SEP NEW YORK NY COLUMBUS DELTA AIR LINES 130P 318P DL 6375 THURSDAY LA GUARDIA PORT COLUMBUS Q ECONOMY TERMINAL DL NON SMOKING NON STOP RESERVATION CONFIRMED 1:48 DURATION FLIGHT OPERATED BY RP CHAUTAUQUA AIRLINES )>md AIRCRAFT: EMBRAER RJ135/140/145 UNITED AIRLINES 29SEP COLUMBUS CHARLOTTE NC 710P 828P THURSDAY PORT COLUMBUS DOUGLAS UA 2691 **U ECONOMY** NON STOP RESERVATION CONFIRMED 1:18 DURATION US 1543 FLIGHT OPERATED BY US US AIRWAYS AIRCRAFT: BOEING 737-300 29SEP CHARLOTTE NC FT LAUDERDA FL 930P 1127P UNITED AIRLINES UA 2065 THURSDAY DOUGLAS FLL INTL **U ECONOMY TERMINAL 3** NON STOP RESERVATION CONFIRMED 1:57 DURATION US 0539 FLIGHT OPERATED BY US US AIRWAYS AIRCRAFT: BOEING 757-200/300 RESERVATION NUMBER(S) DL/28G28A UA/X2RRSW you 4:52 pm - I can have this one issued as a backup-
of 1
9/29/2005 10:38 AM Public Records Request No.: 17-295
jcp-i
:r
Jeffrey E. Epstein
Dr. Berd 00 00 5 to more for 11° wiz them work at le ou ßı Jeffrey E. Epstein Page 2633 07/26/17 Public Records Request No.: 17-295 EFTA02857183
#### IDA - NOTICE TO RENTERS
12
r's insurance primary: The valid and collectible liability insurance and personal injury protection insurance of any authorized rental g driver is primary for the limits of liability and personal injury coverage required by ss.324.021 (7) and 627.736, Florida Statute
e to return rental Vehicle: Failure to return rental property or equipment upon expiration of the rental period and failure to pay nts due (including costs for damage to the property or equipment) are prima facie evidence of intent to defraud, punishable in acc with section 812.155, Florida Statutes.
terms supersede any conflicting terms stated elsewhere.
| al Agreement is between the undersigned and the company identi-
driver's license, and that they have read and agree to the terms,
driver's license, and that they have read and agree to the terms,
ket (the "Agreement"), which is incorporated herein. THE UNDER
ket (the "Agreement"). BELOW AND FOR ALL ADDIT | SIGNED AUTHORIZE THE COMPANY | TO PROCEES & CHARGE TO THEIF | R CREDIT, DEBIT OR CUM | ear on this Hental Statement and on the separ. |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------|------------------------------|------------------------|------------------------------------------------|
| ket (the "Agreement"), which is incorporate the second and FOR ALL ADDITH
S RENTAL UPON SIGNATURE BELOW AND FOR ALL ADDITH
y's approval. | ONAL CHARGES DUE UPON RETUR | IN OF THE VEHICLE ALL CHARGE | ES SUBJECT TO AUDIT. N | to additional drivers are permitted without t |
| Tur. Lawouly | RENTER X | | 1 million | ADDITIONAL DRIVE |
Page 2634
(an come either on buturday or Sunday. She requires 4 hours minimum as she will treke day off at work. 150\$ an hair. She needs cor to bring his fond take her home.
## Jeffrey E. Epstein
BRANCH BANKING AND TRUST COMPANY CHARLOTTESVILLE, VIRGINIA JANUSZ BANASIAK 04/95 BEATA BANASIAK 12542 GREAT PARK CIRCLE APT 303 12542 GREAT PARK CIRCLE APT 303 BBBB Pay to the Order of 11111
PAG S Copyright 2003, Purclue Pharma L.P., Stamford, CT 05901-3431 A7368-SP PPXX05 7/03 ICICIEIN --------------------------------------Orkin DRUG STORES Pharmaceutical Security Institute Sellarin F
-1
1
## Palm Beach Police Department Trash Recovery Log
Location: 358 El Bella
| | TRASH (Y,N) | POSITIVE (Y,N) | IDENTIFIER (Y.N) | CONTRABAND TYPE |
|-----------------------------------------|-------------------------------------------|----------------------|----------------------|---------------------------|
| 9.21.05 wed | | 1 | Y | Notes |
| the Lite | | | | Star Net, 19 |
| | | | | |
| | | | MIN CLARKER | |
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| | 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1. 1 | in the second second | | |
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| 1 - C - C - C - C - C - C - C - C - C - | 1. A. A. A. A. A. A. A. A. A. A. A. A. A. | | | |
| | | | | |
| | | | | A CONTRACTOR OF THE OWNER |
| | | | Second Second Second | |
| | 1. 1. 1. A | ** | | |
| | 100 March 100 | | | |
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| | | S. C. S. States | | |
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| | | A | | |
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- Improv Suturday 1500 Bay Road Miuni Flamingos Beach
## Jeffrey E. Epstein
Page 2642
#### DA - NOTICE TO RENTERS
s insurance primary: The valid and collectible liability insurance and personal injury protection insurance of any authorized rental ( driver is primary for the limits of liability and personal injury coverage required by ss.324.021 (7) and 627.736, Florida Statute:
to return rental Vehicle: Failure to return rental property or equipment upon expiration of the rental period and failure to pay a ts due (including costs for damage to the property or equipment) are prima facie evidence of intent to defraud, punishable in acco with section 812.155, Florida Statutes.
terms supersede any conflicting terms stated elsewhere.
Agreement is between the undersigned and the company identified above (the "Company"). By signature below, the undersigned acknowledges and represents that they are legally authorized to operate the rental vehic ver's license, and that they have read and agree to the terms, conditions and notices, both printed and written, including the Loss Damage Waiver information, that appear on this Rental Statement and on the separit (the "Agreement"), which is incorporated berein. THE UNDERSIGNED AUTHORIZE THE COMPANY TO PROCESS A CHARGE TO THEIR CREDIT, DEBIT OR CHARGE CARD IN THE AMOUNT SPECIFIED ABD' RENTAL UPON SIGNATURE BELOW AND FOR ALL ADDITIONAL CHARGES DUE UPON RETURN OF THE VEHICLE, ALL CHARGES SUBJECT TO AUDIT, No additional drivers are permitted without t approval.
| approval. | | and the second second | |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|-----------------------|------------------|
| Part of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the second of the seco | RENTER | X | ADDITIONAL DRIVE |
| Marine marth also and | | B | |
| | | | |
Jeffrey E. Epstein
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## Jeffrey E. Epstein
7.005 incsices a wic so she 743 9 DICL Sin Lity 07/26/17 Page 2652 Public Records Request No.: 17-295
SPRINT SPECTRUM L.P A.M. t SPECIAL ATTENTION WILL CALL AGAIN PLEASE CAL TIME 0 44 b RUSH HANED YOUR CALL TO SEE YOU D SEE YOU 3KC ONED ۵ SIGNED Ь CON 2. - v -Page 2653 07/26/17 Public Records Request No.: 17-295
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EN P MESSAGE 0:0 SPECIAL AITENTION WILL CALL AGAIN oaot PLEASE CALL TIME. RUSH 286 MPORTANT RETURNED YOUR CALL WANTS TO SEE YOU CAME TO SEE YOU 40 **TELEPHONED** MESSAGE PHONE/ DATE 5 Σ IMPORTANT MESSAGE 8:08 AM TIME OF 7000 PHONE/ MOBILE PLEASE CALL TELEPHONED WILL CALL AGAIN AME TO SEE YO WANTS TO SEE YOU RUSH SPECIAL ATTENTION RETURNED YOUR CALL a כ 5 MESSAGE a 118
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## Jeffrey E. Epstein
07/26/17 Page 2656 Public Records Request No.: 17-295
07126/17 Page 2657 Public RecorOS Request No 17-295
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Pape 2W7 Public Records Raquel No:17-295
Jeffrey Fa. Fristpin TELEPHONED CAME ETO SEE YOU WANTS TO SEE YOU RETURNED YOUR CALL k RUSH SPECIAL ATTER RON
ell down by bathroom Fink Room - Shaven temp. control This house Bia's little girl on the food
Jeffrey E. End
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Jeffrey E. Epstein
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006 CF09454AXX
STATE OF FLORIDA,
- 11S-
JEFFREY EPSTEIN,
Defendant.
DEPOSITION OF
Wednesday, February 20, 2008
2:00 p.m. - 4:30 p.m. Palm Beach County Courthouse 205 North Dixie Highway West Palm Beach, Florida 33401
Reported By: Judith F. Consor, FPR Notary Public, State of Florida Consor a, Associates Reporting and Transcription Phone - 561.682.0905
Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07/26/17 Page 2676 Public Records Request No.: 17-295
• Repotting end Transcriptioa, lac. sor & Associates
Page 2 1 APPEARANCES: 2 On behalf of the State: 3 LANNA BELOHLAVEK, ESQ. ASSISTANT STATE ATTORNEY 4 401 North Dixie Highway West Palm Beach, Florida 33401 5 561.355.7100 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 On behalf of the Defendant: 10 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 11 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 12 WEST PALM BEACH, FLORIDA 33401 561.659.8300 13 14 ALSO PRESENT: ON BEHALF OF THE WITNESS: THEODORE J. LEOPOLD, ESQ. 15 KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL-EZE 16 17 18 19 20 21 22 23 24 25
> Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07/26/17 Page 2677 Public Records Request No.: 17-295
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nsor & Associates
Reporttnp and Transcription. Inc | |
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| | | Rule |
| | NDEX
I | |
| 1 | | |
| 2 | WITNESS: | PA(;'. : |
| 3 | DIRECT EXAMINATION | |
| 4 | BY MR. TEIN: | |
| 5 | | |
| 6 | -
-
- | |
| 7 | NOEXHIBITS
MARKED | |
| 8 | | |
| 9 | CERTIFIED QUESTIONS | |
| 10 | Page
Line | |
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22 | |
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1 | |
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14 | |
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## Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07:2617 Page 2678 Rubric Records Request No 17-295
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| 1 | Deposition taken before Judith F. Consor, | | |
| 2 | Court Reporter and Notary Public in and for the State of | | |
| 3 | Florida at Large, in the above cause. | | |
| 4 | | | |
| 5 | Thereupon, | | |
| 6 | | | |
| 7 | having been first duly sworn or affirmed, was examined | | |
| 8 | and testified as follows: | | |
| 9 | THE WITNESS:
I do. | | |
| 10 | DIRECT EXAMINATION | | |
| 11 | BY MR. TEIN: | | |
| 12 | Good afternoon.
Please tell me your full
Q. | | |
| 13 | name. | | |
| 14 | A. | | |
| 15 | Q.
And can you please spell it. | | |
| 16 | A. | | |
| 17 | | | |
| 18 | Thank you.
Q. | | |
| 19 | May I call you | | |
| 20 | A.
Uh-huh. | | |
| 21 | Q.
I'm going to ask you a few | | |
| 22 | questions, several questions today. If at any time you | | |
| 23 | want to take a break, you just let me know.
Okay? | | |
| 24 | A.
Okay. | | |
| 25 | If you at any time don't understand one of
Q. | | |
Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07/26O7 Page 2679 Public Records Request No.: 17-295
| | Page 5 |
|----|---------------------------------------------------|
| 1 | my questions, will you just please let me know? |
| 2 | Yes.
A. |
| 3 | Q.
And if at any time you're not feeling well |
| 4 | or something like that, you'll tell us, right? |
| 5 | A.
Yes. |
| 6 | Q.
Do you feel okay today? |
| 7 | A.
Yes. |
| 8 | Not taking any alcohol or drugs or anything
Q. |
| 9 | like that, right? |
| 10 | A.
No. |
| 11 | So you feel ready to have your deposition
O. |
| 12 | taken? |
| 13 | A.
Yes. |
| 14 | Q.
what is your address? |
| 15 | A.
I'm currently living at my aunt's house and |
| 16 | I don't know it off the top of my head. |
| 17 | Q.
Where is it? |
| 18 | A. |
| 19 | Who is your aunt?
Q. |
| 20 | A. |
| 21 | Q.
Who else is living there? |
| 22 | A.
my uncle. |
| 23 | Q.
Anyone else living there? |
| 24 | A.
No. |
| 25 | Q.
The contempt motion that your mother filed |
07/26117 Page 2680 Public Records Request No.: 17.295
| | 6 C
Page | | |
|----|---------------------------------------------------------|--|--|
| 1 | against your father regarding your fifty million-dollar | | |
| 2 | lawsuit against Jeffrey Epstein says that you live with | | |
| 3 | your aunt and uncle and have been living there; is that | | |
| 4 | correct? | | |
| 5 | A.
Yes. | | |
| 6 | Q.
How long have you been living with your | | |
| 7 | aunt and uncle? | | |
| 8 | A.
Since my father kicked me out. | | |
| 9 | That was Thanksgiving of this past year?
Q. | | |
| 10 | A.
Yes, sir. | | |
| 11 | Okay.
Q.
Didn't your firefighter boyfriend | | |
| 12 | Brett Albritton get an apartment for the two of you? | | |
| 13 | A.
No, sir.
He has an apartment, but by | | |
| 14 | himself. | | |
| 15 | Q.
Did he get an apartment for the two of you | | |
| 16 | to live in? | | |
| 17 | A.
No, sir. | | |
| 18 | Q.
Are you planning to move in with him? | | |
| 19 | A.
Maybe one day in the future. | | |
| 20 | Q.
Do you have a plan to move in with him | | |
| 21 | presently? | | |
| 22 | A.
No. | | |
| 23 | Q.
Have you been to the apartment that you and | | |
| 24 | Brett Albritton have discussed moving in together? | | |
| 25 | A.
I have been to the apartment. | | |
07/26/17 Page 2681 Public Records Request No.: 17-295
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| | | Page 7 | |
| 1 | Q. | Where is that? | |
| 2 | A. | Palm Beach Lakes. | |
| 3 | Q. | Have yoU spent the night over there? | |
| 4 | A. | No, sir. | |
| 5 | Q. | Do you know the address there? | |
| 6 | A. | I do not. | |
| 7 | Q. | Isn't your
planning on living | |
| 8 | with you and Brett? | | |
| 9 | A. | No. | |
| 10 | Q. | you know that this court case is a | |
| 11 | criminal prosecution, correct? | | |
| 12 | A. | Correct. | |
| 13 | Q. | And you know that it's a criminal | |
| 14 | prosecution against a man who has no criminal background. | | |
| 15 | Do you know that? | | |
| 16 | A. | I do now. | |
| 17 | Q. | You agree that court is a very serious | |
| 18 | matter? | | |
| 19 | A. | Yes. | |
| 20 | Q. | And you're here with your lawyer | |
| 21 | Mr. Leopold, | right? | |
| 22 | A. | Yes. | |
| 23 | Q. | And you know that Mr. Leopold recently | |
| 24 | | filed a lawsuit in federal court against Jeffrey Epstein, | |
| 25 | | seeking fifty million dollars. | |
07/26/17 Page 2682 Public Records Request No.: 17-295
| | Page 8 | | |
|----|---------------------------------------------------------|--|--|
| 1 | MR. LEOPOLD:
Let me just object. | | |
| 2 | let me instruct you.
Anything that | | |
| 3 | you have learned through conversations between you | | |
| 4 | So if you know any of that
and me are protected. | | |
| 5 | information outside of those discussions, you may | | |
| 6 | answer.
But if the only way you know it is | | |
| 7 | through our discussions, do not answer that | | |
| 8 | question. | | |
| 9 | BY MR. TEIN: | | |
| 10 | Q.
you know that Mr. Leopold recently | | |
| 11 | filed a lawsuit in federal court on your behalf against | | |
| 12 | Jeffrey Epstein seeking fifty million dollars? | | |
| 13 | MR. LEOPOLD:
Same objection. | | |
| 14 | If you know the answer to that outside of | | |
| 15 | our discussions, you may answer. If it is the | | |
| 16 | only way that you know the answer is through our | | |
| 17 | discussions, do not answer that question. | | |
| 18 | THE WITNESS: Okay. | | |
| 19 | MR. LEOPOLD: Attorney/client privilege. | | |
| 20 | BY MR. TEIN: | | |
| 21 | Q.
You can answer the question unless | | |
| 22 | MR. LEOPOLD:
Same objection. | | |
| 23 | MR. TEIN:
Let me finish. | | |
| 24 | MR. LEOPOLD: Excuse me. We're | | |
| 25 | MR. TEIN:
No.
Let me finish. | | |
07126/17 Page 2683 Public Records Request No.: 17-295
| | sor & Associates
Reportingad Trisicription, lac. |
|----|----------------------------------------------------------|
| | Page 9 |
| 1 | MR. LEOPOLD:
we're not going to do |
| 2 | that. |
| 3 | MR. TEIN:
My name is not |
| 4 | I'm going to finish my question.
Okay? |
| 5 | MR. LEOPOLD:
Do not answer until you hear |
| 6 | from me. |
| 7 | BY MR. TEIN: |
| 8 | Q.
Other than conversations that you have had |
| 9 | with Mr. Leopold I'm not asking about that are you |
| 10 | aware that Mr. Leopold has filed a lawsuit in federal |
| 11 | court seeking fifty million dollars from Jeffrey Epstein |
| 12 | on your behalf? |
| 13 | MR. LEOPOLD: Same objection. |
| 14 | Anything that you learn through |
| 15 | conversations between you and me, do not answer. |
| 16 | Those are protected.
If you know through any |
| 17 | other realm of knowledge, you may answer. |
| 18 | THE WITNESS:
No. |
| 19 | BY MR. TEIN: |
| 20 | Q.
You have no idea that Mr. Leopold filed a |
| 21 | fifty million-dollar lawsuit on your behalf against |
| 22 | Jeffrey Epstein? |
| 23 | MR. LEOPOLD:
Same objection. |
| 24 | Do not answer that question if it's through |
| 25 | discussions that you and I had.
Outside of that, |
07126117 Page 2684 Public Records Request No.: 17-295
Page 10 1 you may answer. So do not answer that question if 2 that is the only basis by which you understand 3 that answer. 4 THE WITNESS: No. 5 BY MR. TEIN: 6 Q. You didn't know that? 7 MR. LEOPOLD: Don't answer that question. 8 Again, it's attorney/client privilege. Any 9 information you've learned through conversations 10 between you and I are protected. If you know it 11 through any other realm, you may answer. 12 MR. TEIN: Are you going to say that for 13 every question in the deposition, Mr. Leopold? 14 MR. LEOPOLD: When you ask improper 15 questions like that without the proper -- 16 MR. TEIN: You're going to stop your 17 speaking objections right now. Okay? 18 MR. LEOPOLD: Without the proper -- 19 MR. TEIN: You need to stop your speaking 20 objections. 21 Let's continue. 22 MR. LEOPOLD: Counsel, you just asked me a 23 question and I'm going to state it on the 24 record -- 25 MR. TEIN: You need to stop your speaking
> Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07/26/17 Page 2685 Public Records Request No.: 17-295
1 objections. Check your rules.
MR. LEOPOLD: Excuse me. For the record, Counsel asked me a question. I'll state the answer on the record. He asked me the question am I going to be answering that way throughout the deposition. So long as there's improper foundation and predicate asked by the attorney, I will protect my client and I make the record where appropriate. If counsel wishes to ask an 10 appropriate worded question with the proper foundation and predicate, I will certainly allow the client to answer the question. MR. GOLDBERGER: Why don't you just state attorney/client privilege and just be done with it? MR. LEOPOLD: I want the record to be clear. MR. TEIN: You want to waste time is what you want to do. You were supposed to be here this morning and you totally broke the deal, the agreement that you had with us if your hearing got cancelled. But let's move on and maybe you'll stop obstructing this deposition. MR. LEOPOLD: I think the record is very
Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07/26/17 Page 2686 Public Records Request No.: 17-295
| | sor & Associates
/O
nRepots's ad Transcription, lac |
|----|-----------------------------------------------------------|
| | Page 12 |
| 1 | clear where we stand thus far. |
| 2 | Is there a recording taken of this |
| 3 | deposition? |
| 4 | THE COURT REPORTER:
Yes. |
| 5 | MR. LEOPOLD:
Just make sure that's |
| 6 | preserved. |
| 7 | BY MR. TEIN: |
| 8 | Go to Exhibit 20-01 well, before you do
Q. |
| 9 | are you aware that a lawyer named Jeffrey
that |
| 10 | Herman filed a lawsuit on your behalf, yes or no? |
| 11 | MR. LEOPOLD: Objection. |
| 12 | Any conversations that you and I have had |
| 13 | regarding that, if that is the only way by which |
| 14 | you understand how to answer that question, do not |
| 15 | It's attorney/client privilege, as well
answer. |
| 16 | as any conversations you may have had with the |
| 17 | attorney from Miami. That is also attorney/client |
| 18 | privilege.
And I'm assuming |
| 19 | MR. TEIN:
You're actually wrong about the |
| 20 | attorney/client privilege. |
| 21 | I'm assuming Counsel is not
MR. LEOPOLD: |
| 22 | asking you to divulge attorney/client |
| 23 | Of course not.
MR. TEIN: |
| 24 | BY MR. TEIN: |
| 25 | are you aware that Jeffrey Herman,
O. |
07/26/17 Page 2687 Public Records Request No.: 17-295
Page 13 an attorney, filed a fifty-million-dollar lawsuit on your behalf against Jeffrey Epstein, yes or no? MR. LEOPOLD: Same objection. MR. TEIN: We've heard the objection 10 times already. MR. LEOPOLD: Counsel, excuse me. MR. TEIN: Just say attorney/client privilege. Stop interrupting my questions. MR. LEOPOLD: I'm entitled to make an 10 objection for the record, which I'm doing, and I'll make the same objection. And if it calls for attorney/client privilege, any conversations you and I have had, do not answer the question. And I think that it might be appropriate, for the record, to ask questions via "Ms. as opposed to I think that would be more appropriate for this deposition. BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. A. Yes. Q. Thank you. In fact, you know that Mr. Herman held a press conference after he filed the fifty-million-dollar lawsuit on your behalf, don't you? A. After it happened.
Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07126117 Page 2688 Public Records Request No.: 17-295
sor & Associates Reporting and Transcription. lac.
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|----|------------------------------------------------------|--|--|
| 1 | You know that he had a press conference,
O. | | |
| 2 | don't you, yes or no? | | |
| 3 | A.
Yes. | | |
| 4 | Q.
In fact, let's go to Exhibit 20-01. | | |
| 5 | MR. GOLDBERGER: Look behind you.
You'll | | |
| 6 | see it. | | |
| 7 | BY MR. TEIN: | | |
| 8 | Q.
Have you ever seen that picture before? | | |
| 9 | A.
Yes. | | |
| 10 | Q.
Is that a picture of your father, your | | |
| 11 | stepmother and Mr. Herman at the press conference | | |
| 12 | regarding your lawsuit? | | |
| 13 | A.
Yes. | | |
| 14 | Now you know that this is a very serious
Q. | | |
| 15 | matter, don't you? | | |
| 16 | MR. LEOPOLD: Asked and answered. | | |
| 17 | Objection. | | |
| 18 | MR. GOLDBERGER: All right.
You can | | |
| 19 | object.
You're representing a witness here, | | |
| 20 | Mr. Leopold.
You can object on privilege grounds. | | |
| 21 | You cannot make legal objections.
You have no | | |
| 22 | standing to do so. | | |
| 23 | MR. LEOPOLD:
I'm going to make them and | | |
| 24 | then | | |
| 25 | MR. GOLDBERGER:
We're | | |
Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07/26/17 Page 2689 Public Records Request No.: 17-295
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| 1 | MR. LEOPOLD: We're going to leave or we're |
| 2 | going to take a break, because his demeanor is not |
| 3 | appropriate. There's no reason to have this kind |
| 4 | of demeanor.
If you want to have this kind of |
| 5 | demeanor with me |
| 6 | MR. TEIN:
You are obstructing this |
| 7 | deposition. |
| 8 | Why don't you guys go
MR. GOLDBERGER: |
| 9 | outside and just talk about |
| 10 | MR. LEOPOLD: She her job is very |
| 11 | difficult and she's not going to be able to take |
| 12 | us both talking at the same time. |
| 13 | MR. GOLDBERGER: Off the record. |
| 14 | MR. LEOPOLD: We're not going off the |
| 15 | record, Jack.
Her job is very
We're not, Jack. |
| 16 | difficult.
I'm going to make the record. |
| 17 | I don't think it is appropriate, especially |
| 18 | in the small confines of this room, to be very |
| 19 | aggressive with this young lady. |
| 20 | MR. TEIN: That's not happening. Stop, |
| 21 | stop actually |
| 22 | If you're going to interrupt
MR. LEOPOLD: |
| 23 | me, we're going to cancel this deposition |
| 24 | MR. TEIN: Stop misrepresenting. |
| 25 | I need one at a time,
THE COURT REPORTER: |
07/26/17 Page 2690 Public Records Request No.: 17-295
sor & Associates Reporting ad Transcription. lac. Page 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 no matter who it is. MR. LEOPOLD: I think we're going to take a break. Perhaps you might want to talk to your co-counsel -- MR. TEIN: I don't need to talk to him. MR. LEOPOLD: But we're going to take a break. MR. TEIN: We're not taking a break unless the witness needs a break. You're obstructing this deposition, Ted. MR. LEOPOLD: Come on, You all want to continue in this demeanor -- MR. TEIN: You're obstructing the deposition. Stop making speeches. We're not discussing this with you. The questions are to your client. Go take your five-minute break. MR. LEOPOLD: Fine. We need to make sure the record's clear and clean. And I want to make sure, as I've already asked you -- I know that you're one of the best in town -- that this audio -- this needs to be preserved. Okay? MR. TEIN: Go take your five-minute break, Mr. Leopold, now.
> Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07/26/17 Page 2691 Public Records Request No.: 17-295
| | Page 17 |
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| 1 | You were supposed to be here at nine a.m.; |
| 2 | it's now after two. Take your break and come |
| 3 | back. |
| 4 | MR. LEOPOLD:
Okay.
If the demeanor keeps |
| 5 | up, we will not be here beyond those five minutes. |
| 6 | MR. TEIN: Take your break and come back. |
| 7 | MR. LEOPOLD: Okay. So I suggest that you |
| 8 | relax. |
| 9 | MR. TEIN: I suggest that you take your |
| 10 | break. |
| 11 | MR. GOLDBERGER: Let them take that |
| 12 | five-minute break. |
| 13 | MR. LEOPOLD:
But I would suggest that you |
| 14 | take deep breaths. |
| 15 | MR. TEIN:
Go
Suggest whatever you want. |
| 16 | take a break. |
| 17 | (Thereupon, a recess was taken.) |
| 18 | BY MR. TEIN: |
| 19 | you agree that giving testimony
Q. |
| 20 | today at your deposition is something very serious, don't |
| 21 | you? |
| 22 | A.
Yes. |
| 23 | And you respect the court, don't you?
Q. |
| 24 | A.
Yes. |
| 25 | Let me show you Exhibit 31-001. Can you
Q. |
07/26117 Page 2692 Public Records Request No.: 17-295
sor & Associates Reportage ad Treaseripaioe, loc. Page 18 1 read that out loud, please. 2 A. Okay. What do you want? 3 Q. Will you read that out loud, please. 4 A. 5 Q. Thank you. 6 A. Lol hah my baddd...1O1 yah i got some 7 stupid court shit on the 20th...bullshit...and damn you 8 still have court shit with him? Like after so long wow 9 im sorry... well yah well we will definitely havta make 10 plans for sure..because i miss u tons times a million and 11 no no no i love you...o and p.s. i love ur default pic 12 niggaa. Muah xo. 13 Q. Did you send that message last week to a 14 friend of yours on MySpace? 15 A. I wouldn't know. There's no dates and I've 16 deleted that MySpace, so -- 17 Q. We're going to talk about that in a second. 18 A. Okay. 19 Q. Did you send that message last week 20 A. Right. 21 Q. Let me finish my question. 22 Did you send that message last week to a 23 friend of yours on MySpace? 24 A. I wouldn't know the date, but obviously, 25 it's to a friend.
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vawn Page 2693 Public Records Request No.: 17-295
| | Page 19 | | |
|----|---------------------------------------------------|--|--|
| 1 | Did you send that message to a friend of
Q. | | |
| 2 | yours on MySpace? | | |
| 3 | A.
Sure, yes. | | |
| 4 | Q.
Were you referring to this deposition? | | |
| 5 | A.
Yes. | | |
| 6 | Q.
Do you find the term n-i-g-g-e-r offensive? | | |
| 7 | A.
That's not anywhere in there. | | |
| 8 | What word did you use in there?
Q. | | |
| 9 | MR. LEOPOLD:
Where are you referring to, | | |
| 10 | Counsel? There's 20 plus words in there. | | |
| 11 | MR. TEIN:
Don't make a speaking objection. | | |
| 12 | THE WITNESS:
Are you referring to | | |
| 13 | anything | | |
| 14 | Don't don't -
MR. LEOPOLD:
No, | | |
| 15 | let him ask you the question. | | |
| 16 | BY MR. TEIN: | | |
| 17 | What question were you asking,
Q. | | |
| 18 | MR. LEOPOLD: She doesn't ask questions. | | |
| 19 | You ask the questions.
What is the question | | |
| 20 | pending? | | |
| 21 | BY MR. TEIN: | | |
| 22 | what is the last word on there in
Q. | | |
| 23 | the text of your message before the closing? | | |
| 24 | A.
Niggaa. | | |
| 25 | Don't you find that term offensive?
Q. | | |
07/26/17 Page 2694 Public Records Request No.: 17-295
07126/17 Page 2695 Public Records Request No 17-295
Reporting and Transcripcico. Inc
| | | Page 21 |
|----|-------------------------------------------------------|---------------------------------------------|
| 1 | BY MR. TEIN: | |
| 2 | Let me ask you, M.
Q. | did you in fact |
| 3 | write your friend this message about this deposition? | |
| 4 | A.
Yes. | |
| 5 | 0.
So you wrote your friend that this | |
| 6 | deposition is stupid court s-h-i-t, correct? | |
| 7 | Yes.
A. | |
| 8 | Q. | Because you think this deposition is stupid |
| 9 | court s-h-i-t, don't you? | |
| 10 | A.
No. | |
| 11 | Q. | You wrote that to your friend, didn't you? |
| 12 | A.
Yes. | |
| 13 | Q. | You think that court is stupid, don't you? |
| 14 | In some cases.
A. | |
| 15 | Q. | And you think that court is bull s-h-i-t, |
| 16 | don't you? | |
| 17 | A.
No. | |
| 18 | Q. | And you think this deposition is bull |
| 19 | s-h-i-t, don't
you? | |
| 20 | A.
No. | |
| 21 | Q. | You wrote that to your friend, didn't you? |
| 22 | MR. LEOPOLD: | Objection.
Asked and |
| 23 | answered. | |
| 24 | | MR. TEIN: That's not an objection. |
| 25 | BY MR. TEIN: | |
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07'2617 Page 2696 Public Records Request No 17-295
Page 22 1 Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and answered, for the fourth time. MR. TEIN: You are improperly objecting, Mr. Leopold. You have no grounds to object. And that's not an objection. MR. LEOPOLD: It is an objection. MR. TEIN: Then terminate the deposition if you think it's been asked and answered. 10 MR. LEOPOLD: Counsel, I am not precluded from just making an objection to the form of the question. As the courts well know, and if you practice here in West Palm Beach, many of the judges require you to set the objection with specificity. And I will do that. And if you don't want me to, you can make the record. But I will do that. MR. TEIN: Here's what we'll do, Ted. You can -- I will allow you to reserve an objection to form for every single one of my questions. Otherwise, all you're doing is obstructing. MR. LEOPOLD: I won't do that. MR. TEIN: Of course; because you want to obstruct. MR. LEOPOLD: All right.
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07126/17 Page 2697 Public Records Request No.: 17-295
nsor & Associates
\*Reporting and Tian SaiptICO. Inc
| | Page 23 |
|----|------------------------------------------------------------|
| 1 | BY MR. TEIN: |
| 2 | you think that giving testimony
Q. |
| 3 | today, under oath, is bull s-h-i-t, don't you? |
| 4 | No.
A. |
| 5 | And you wrote that to your friend on
Q. |
| 6 | MySpace last week, didn't you? |
| 7 | MR. LEOPOLD:
Objection.
Asked and |
| 8 | answered. |
| 9 | THE WITNESS:
No, I did not. |
| 10 | BY MR. TEIN: |
| 11 | Q.
You didn't write this exhibit? |
| 12 | A.
I wrote that, but I didn't write what you |
| 13 | said. |
| 14 | You wrote in this exhibit, "I got some
Q. |
| 15 | stupid court s-h-i-t on the 20th.
Bull s-h-i-t." Didn't |
| 16 | you write that? |
| 17 | Yes.
A. |
| 18 | Q.
Referring to this deposition, didn't you? |
| 19 | Referring to the court.
I was later
A. |
| 20 | informed that it was a deposition. |
| 21 | Q.
I'm going to ask you some questions now |
| 22 | about what happened when you went to Jeff Epstein's house |
| 23 | three years ago.
Okay? |
| 24 | A.
Uh-huh. |
| 25 | When the police interviewed you one month
Q. |
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07.26,17 Page 2698 Poetic Records Request No 17-295
Page 24 1 after you went to Epstein's house, you swore on your 2 mother's grave that you and Epstein did not engage in sex 3 of any kind? 4 A. Yes. 5 Q. Didn't you tell that to the police? 6 A. Yes. And I will continue. I have never 7 had sex with him. 8 Q. Did what happened upstairs at Jeff 9 Epstein's house take you completely by surprise, 10 A. Yes. 11 Q. Now the civil complaint that you filed 12 against Mr. Epstein for fifty million dollars alleged 13 that you were totally shocked by what happened when you 14 got there. 15 A. Yes. 16 Q. Were you totally shocked by what happened 17 when you got to Epstein's house? 18 A. Yes. 19 Q. You didn't expect it at all, did you? 20 A. No. 21 Q. You had absolutely no idea why your friend 22 Hayley was taking you to Epstein's house, right? 23 A. I was informed it was a massage. 24 Q. All you thought that it was going to be was 25 a massage, correct?
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07/26/17 Page 2699 Public Records Request No.: 17-295
| | Page 25 |
|----|-----------------------------------------------------------|
| | A.
Yes. |
| | Q.
Before you got to Epstein's house Bayley |
| 3 | never said anything to you on the telephone about sexual |
| 4 | activity with Epstein, did she? |
| 5 | A.
No. |
| 6 | Q.
And before you got to Epstein's house |
| 7 | Bayley never sent you a message over the Internet about |
| 8 | sexual activity with Epstein, did she? |
| 9 | A.
No. |
| 10 | Did Zack Bryan ever try to convince you to
Q. |
| 11 | engage in any sexual activity with Epstein? |
| 12 | A.
No. |
| 13 | Q.
every try to convince
Did Anthony |
| 14 | you to engage in any sexual activity with Epstein? |
| 15 | A.
I don't know who Anthony
is. |
| 16 | Q.
Do you have a friend Anthony? |
| 17 | A.
No. |
| 18 | Before you went so Epstein's house
Q.
Okay. |
| 19 | did anyone call or e-mail you to induce you to engage in |
| 20 | sexual activity with Epstein? |
| 21 | A.
No. |
| 22 | Q.
So you're sure that before you got to |
| 23 | Epstein's house no one tried to persuade you to engage in |
| 24 | sexual activity with Jeffrey Epstein? |
| 25 | No.
A. |
07:26,17 Page 2700 Pubic Records Request No 17-295
| | Page 26 |
|----|-----------------------------------------------------------|
| 1 | You're sure that let me ask the question
Q. |
| 2 | again. |
| 3 | You're sure that before you got to |
| 4 | Epstein's house no one tried to persuade you to engage in |
| 5 | sexual activity with Epstein for money.
Are you? |
| 6 | MR. LEOPOLD:
Objection.
Asked and |
| 7 | answered. |
| 8 | THE WITNESS:
No. And I've already |
| 9 | answered that a bazillion times. |
| 10 | BY MR. TEIN: |
| 11 | He's coaching you now. So I'm going to ask
Q. |
| 12 | the question |
| 13 | MR. LEOPOLD: Counsel, I've made an |
| 14 | objection for the record. |
| 15 | MR. TEIN: Stop speaking. |
| 16 | MR. LEOPOLD:
I'm not going to stop |
| 17 | speaking.
You can't interrupt me when I'm making |
| 18 | the record. |
| 19 | MR. TEIN:
You're coaching the witness. |
| 20 | Counsel
MR. LEOPOLD: |
| 21 | MR. TEIN:
Stop coaching the witness. |
| 22 | BY MR. TEIN: |
| 23 | let
Q.
me ask you |
| 24 | If you continue to
MR. LEOPOLD: |
| 25 | MR. TEIN:
Stop interrupting my questions. |
07x26,17 Page 2701 Public Records Request No.: 17-295
Page 27 1 MR. LEOPOLD: If you do it one more time, we're leaving. BY MR. TEIN: Q. MR. LEOPOLD: I'm going to make the record. You cannot interrupt me when I'm making the record. Out of professional conduct, you cannot do that. I'm entitled to make the record. I made an objection, asked and answered. Your demeanor 10 is inappropriate. You're willing and you are able 11 and you're responsible to ask a question in a professional manner, and ask the question and once you get the answer, to either follow up on it or move on, but not continuously browbeat and ask the same question over and over because you don't like the answer. MR. TEIN: Calm down, sir. MR. LEOPOLD: Trust me, I'm very calm here. When I'm not calm, you'll know it. I'm very calm. 20 So please continue on. But I will not allow you to continue to harass her in the demeanor that you're doing. Ask her a question and move on. MR. TEIN: Are you done? MR. LEOPOLD: Thank you. I am.
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07.26,17 Page 2702 PubHc Records Request Na . 17-265
\* nsor & Associates Rcronang and Mtn scription. Inc
| | Page 28 |
|----|----------------------------------------------------|
| 1 | MR. TEIN: Stop misrepresenting the record |
| 2 | and calm down. I'm going to ask my question. |
| 3 | Stop it. |
| 4 | BY MR. TEIN: |
| 5 | Q. |
| 6 | I think the record is very
MR. LEOPOLD: |
| 7 | clear. |
| 8 | MR. GOLDBERGER: Let me just clarify |
| 9 | When you object to the form of a
something. |
| 10 | question, you're not instructing the witness not |
| 11 | to answer the question, are you? |
| 12 | And I'm not making that
MR. LEOPOLD:
No. |
| 13 | objection; only on attorney/client privilege. |
| 14 | MR. TEIN: Will you stop speaking now so I |
| 15 | can ask my question? Are you done? |
| 16 | I'm going to ask my question.
Okay. |
| 17 | BY MR. TEIN: |
| 18 | Q.
Listen, |
| 19 | Hold on. Stop.
MR. LEOPOLD: |
| 20 | I've been doing this for 20 plus years and |
| 21 | have met a lot of attorneys, but I've never had an |
| 22 | experience like this where I've |
| 23 | MR. TEIN: Stop your speeches. |
| 24 | If you continue to do this,
MR. LEOPOLD: |
| 25 | whether it's with me or with my client, I will not |
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07,2617 Page 2703 Pub!a: Records Request No\_ 17-295
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 29 put up with it and I don't need to put up with it and it's not appropriate. And I'm sure Mr. Goldberger knows all this, because I know that he wouldn't do this. So I will not put up with it. And I think it's highly inappropriate to do this with this child sitting here, the way you're acting, primarily towards me, and I will not put up with it. MR. TEIN: Will you please stop your speech so I can ask questions? MR. LEOPOLD: So long as you act professionally, I will do so. But if you continue to do it this way, I will leave. MR. TEIN: Suit yourself. BY MR. TEIN: Q. are you sure that before you got to Epstein's house no one tried to persuade you to engage in sexual activity with Epstein for money? MR. LEOPOLD: Asked and answered. Objection. MR. TEIN: Did you get her answer? THE COURT REPORTER: No, I did not. THE WITNESS: I'm sure. BY MR. TEIN: 0. Let me ask you a few question:: about your.
> Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07)2617 Page 2704 Public Records Request No\_ 17-295
Page 3C 1 contact with Jeffrey Epstein. Okay? 2 A. (Witness nods head up and down.) 3 Q. Jeff never e-mailed you, did he? 4 A. No. 5 Q. Jeff never text messaged you, did he? 6 A. No. 7 Q. Jeff never chatted in a chat room with you, 8 did he? 9 A. No. 10 Q. Before you got to Epstein's house you had 11 never spoken to Jeff, had you? 12 A. No. 13 Q. And before you got to Epstein's house you 14 had never met Jeff? 15 A. Correct. 16 Q. Before you got to Epstein's house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 Q. Before you got to Epstein's house had you 20 ever told Jeffrey that you were under 18? 21 A. No. I never spoke to the man before that. 22 Q. And you only went to Jeff Epstein's house 23 that one time three years ago, correct? 24 A. Yes. 25 O. You never went there again, correct?
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07.26:17 Page 2705 Public Records Request No.: 17-295
Page 31 1 A. No. 2 Q. All right. Let me ask you two final areas 3 of questioning about this and we'll move onto something 4 else. Okay? 5 A. Uh-huh. Yes. I'm sorry. 6 Q. Before you got to Epstein's did anyone 7 associated with Epstein ever call you on the phone and 8 try to persuade, induce, entice or coerce you to engage 9 in any sexual activity? 10 A. No. 11 Q. Before you got to Epstein's did anybody 12 associated with Epstein ever contact you on the Internet 13 and try to persuade, induce, entice or coerce you to 14 engage in any sexual activity? 15 A. No. 16 Q. who told you that when you got to 17 Jeff Epstein's house you should lie to Jeff about your 18 age? 19 A. 20 Q. Was it Hayley or was it the other girl in 21 the car who you rode over with to Epstein's house? 22 A. 23 Q. Who was the other girl in the car with you 24 that day? 25 A. I honestly don't know.
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07/26/17 Page 2706 Public Records Request No 17-295
| | Page 32 |
|----|--------------------------------------------------------|
| 1 | Q.
Had you ever seen her before? |
| 2 | A.
No, sir. |
| 3 | Q.
You told the police that when you rode over |
| 4 | to Epstein's you had no idea who she was, right? |
| 5 | A.
Correct. |
| 6 | Q.
You told the police that you didn't know |
| 7 | her name, but she was like really dark, kind of like a |
| 8 | Spanish girl? |
| 9 | A.
Yes. |
| 10 | Q.
Those were your words, right? |
| 11 | A.
Yes. |
| 12 | Q.
Do you now know who she is? |
| 13 | A.
No, sir. |
| 14 | Q.
So it was
who told you to lie about |
| 15 | your age to Jeff Epstein? |
| 16 | A.
Yes, sir. |
| 17 | Am
old you that if you weren't 18,
Q. |
| 18 | Epstein wouldn't let you into his house, right? |
| 19 | A.
That's yes, yes. |
| 20 | Q.
All right.
Let's talk for a minute about |
| 21 | when you first met Jeff. Okay? |
| 22 | A.
Sure. |
| 23 | Q.
When you first met Jeff he tried to find |
| 24 | out how old you were, right? |
| 25 | A.
Excuse me? |
07 26,17 Page 2707 Public Records Request No.: 17-295
. Itoponing sad Traaraiptios, Inc. sor & Associates
| | Page 33 |
|----|-----------------------------------------------------------|
| 1 | When you first met Jeff he tried to find
Q. |
| 2 | out how old you were, right? |
| 3 | A.
Not when we first introduced each other; |
| 4 | when we get upstairs, then, yes. |
| 5 | During the massage Jeff asked you how old
Q. |
| 6 | you were, correct? |
| 7 | A.
Yes, yes. |
| 8 | Now hadn't you already told Jeff's
Q. |
| 9 | assistant, the one who walked you upstairs, that you went |
| 10 | to college and had just moved down here from Ohio? |
| 11 | A.
I never spoke to the lady. |
| 12 | Q.
Do you want to rethink that answer? |
| 13 | MR. LEOPOLD:
Is that a question? |
| 14 | BY MR. TEIN: |
| 15 | Do you want to rethink that answer?
Q. |
| 16 | A.
I didn't really speak with her that
No. |
| 17 | much. |
| 18 | Do you want to try to refresh your memory
Q. |
| 19 | on that? |
| 20 | Do you have something to
MR. LEOPOLD: |
| 21 | refresh her memory with? |
| 22 | MR. TEIN:
Do you want to stop making |
| 23 | speaking objections? |
| 24 | MR. LEOPOLD:
But to refresh someone's
No. |
| 25 | memory, you show them a document. |
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07/26/17 Page 2708 Public Records Request No.: 17-295
| | Page 34 |
|----|-----------------------------------------------------------|
| 1 | MR. TEIN: I know how to do this. |
| 2 | MR. LEOPOLD: Then show her a document. |
| 3 | MR. TEIN: Stop speaking. |
| 4 | MR. LEOPOLD:
I'm not going to stop |
| 5 | speaking.
I'm going to continue to make the |
| 6 | record. |
| 7 | MR. TEIN: You're obstructing.
tquaae |
| 8 | stop. |
| 9 | But if
MR. LEOPOLD:
I'm not obstructing. |
| 10 | you want to refresh her recollection, you need to |
| 11 | show her something. |
| 12 | I object to
That's not a proper question. |
| 13 | the foundation and the predicate of that question. |
| 14 | MR. TEIN:
Are you done? |
| 15 | MR. LEOPOLD: I am now. Thank you. |
| 16 | BY MR. TEIN: |
| 17 | Q.
Do you want to try to refresh your memory |
| 18 | as to whether you had any conversation with the woman who |
| 19 | walked you upstairs in Epstein's house in which you told |
| 20 | her that you went to college and had just moved down from |
| 21 | Ohio? |
| 22 | MR. LEOPOLD: Objection. Object to the |
| 23 | form of the question.
Lack of foundation and |
| 24 | predicate. |
| 25 | BY MR. TEIN: |
07:2617 Page 2709 Public Records Request No.: 17-295
| | Page 35 |
|----|-----------------------------------------------------------|
| 1 | Q.
You can answer the question. |
| 2 | A.
Sure. |
| 3 | Q.
Is there anything that would refresh your |
| 4 | memory that in fact you told Mr. Epstein's assistant, the |
| 5 | one who walked you upstairs, that you went to college and |
| 6 | you had just moved down here from Ohio? |
| 7 | A.
I don't remember saying that, but if you |
| 8 | I don't remember saying that myself, so |
| 9 | Q.
That would be a lie, right? |
| 10 | A.
No.
I really don't remember. |
| 11 | So you told Jeff that you were 18 years
Q. |
| 12 | old, correct? |
| 13 | A.
Yes. |
| 14 | Q.
Do you remember Detective
Pagan of |
| 15 | the Police Department, Palm Beach Police Department? |
| 16 | A.
Yes. |
| 17 | Q.
Do you remember you spoke to her? |
| 18 | A.
Yes. |
| 19 | Q.
Do you remember that you told Detective |
| 20 | Pagan that when you lied about your age to Jeff you said |
| 21 | it really fast because you didn't want to make it sound |
| 22 | like you were lying? |
| 23 | A.
I don't remember the words exactly, but I |
| 24 | do remember telling her I told him I was 18. |
| 25 | Q.
And do you remember telling Detective Pagan |
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07,2617 Page 2710 Public Records Request No.: 17-295
1
Page 36 1 that when you lied to Epstein about your age that you 2 said it really fast so Epstein wouldn't realize you were 3 lying? 4 A. No, I don't remember saying those words 5 exactly to her. I remember telling her that I told 6 Epstein I was 18. 7 Q. Does it sound right to you that you told 8 Detective Pagan that you said your age really fast to 9 Epstein -- 10 MS. BELOHLAVEK: Objection. Asked and 11 answered. 12 BY MR. TEIN: 13 Q. -- so he wouldn't think that you were 14 lying? 15 MR. LEOPOLD: Objection. Asked and 16 answered, lack of foundation, mischaracterization 17 of her earlier testimony. She's already answered 18 that question. 19 BY MR. TEIN: 20 Q. You can answer it. 21 MR. LEOPOLD: Same objection. It's been 22 asked and answered. 23 You can answer. I've made the objection. 24 THE WITNESS: I forget the question, now. 25
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0726,17 Page 2711 Public Records Request No.: 17-295
| | Page 37 |
|----|------------------------------------------------------|
| 1 | BY MR. TEIN: |
| 2 | Let me put it again.
Q. |
| 3 | Does it sound right to you that you told |
| 4 | Detective Pagan that when you lied about your age to |
| 5 | Jeffrey Epstein, you said it really fast because you |
| 6 | didn't want to make it sound like you were lying? |
| 7 | MR. LEOPOLD:
Objection.
Lack of |
| 8 | foundation, asked and answered. |
| 9 | THE WITNESS:
I could have possibly said |
| 10 | that, yes. |
| 11 | BY MR. TEIN: |
| 12 | Q.
You didn't want Mr. Epstein to know that |
| 13 | you were lying about your age, right? |
| 14 | A.
Correct. |
| 15 | Q.
You didn't want Mr. Epstein to know that |
| 16 | you were not 18 yet, right? |
| 17 | A.
Correct. |
| 18 | You wanted Mr. Epstein to believe that you
Q. |
| 19 | really were 18, right? |
| 20 | A.
Correct. |
| 21 | 0.
Do you remember when Mr. Epstein asked |
| 22 | where you went to school? |
| 23 | A.
Yes. |
| 24 | Q.
And you told Mr. Epstein you went to |
| 25 | Wellington, right? |
0/ 26 17 Page 2712 Public Records Request No.. 17-295
sor & Associates Reportingad Tranicripan. lac Page 38 1 2 3 4 5 6 7 8 A. Yes. Q. Was that the truth? A. No. Q. In fact, you went to right? A. Yes. Q. So you lied to Mr. Epstein again, correct? A. Yes. Q. Is Wellington the college that you told 9 Jeff's assistant that you were attending? 10 A. I don't remember having that conversation 11 with her, so I wouldn't know if that's what I said. 12 Q. That was a lie, though, wasn't it? 13 MR. LEOPOLD: Objection to the form of the 14 question, lack of foundation. You're making an 15 16 17 18 19 20 21 22 23 24 25 assumption. She just answered you she can't tell you that. MR. TEIN: Speaking objection. And you well know that, Mr. Leopold. MR. LEOPOLD: She can't answer that question. The way you phrased that question, you're purposely making her not be honest in her testimony. She can't answer a question like that. She doesn't remember. So then you say, "So you were lying." That's improper and you know that. That's not a proper question. And any attorney
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07126117 Page 2713 Public Records Request No.: 17-295
| | Page 3
, |
|----|-----------------------------------------------------------|
| 1 | that would do that to a witnesses or to a person |
| 2 | that's sitting in this chair is not acting |
| 3 | You can't ask a question like
professionally. |
| 4 | that.
You can do it, but it's not proper.
And |
| 5 | I'm sure you weren't trained that way, certainly |
| 6 | not ethically. |
| 7 | MR. TEIN:
Will you stop? |
| 8 | MR. LEOPOLD: I'm not going to stop, |
| 9 | because the way you're asking that question is |
| 10 | improper and you know it. |
| 11 | MR. TEIN:
You're losing your cool. |
| 12 | BY MR. TEIN: |
| 13 | Q. |
| 14 | MR. LEOPOLD:
Trust me.
I'm very calm. |
| 15 | When I lose my cool, you'll know it. |
| 16 | MR. TEIN:
I do know it. |
| 17 | BY MR. TEIN: |
| 18 | Q.
Mr. Epstein never asked you |
| 19 | to do anything other than massage him, correct? |
| 20 | A.
Incorrect; because he asked me to take off |
| 21 | my bra, so that would be two things he's asked me to do. |
| 22 | Q.
Other than asking you to take your bra off, |
| 23 | Mr. Epstein never asked you to do anything with him other |
| 24 | than massage, correct? |
| 25 | Foundation,
MR. LEOPOLD: Objection. |
07 26 17 Page 2714 Public Records Request No.: 17-295
\*Rerornne and Transcornca. Inc nsor & Associates Page 40 1 predicate. 2 THE WITNESS: Correct. 3 BY MR. TEIN: 4 Q. You told the police, in your words, that 5 you did not whack him off, right? 6 A. Correct. 7 Q. What does that mean? 8 A. Whack, like whacking off? 9 Q. Your term, what does that mean? 10 A. Masturbating. 11 Q. Mr. Epstein never tried at any time to grab 12 your hand, did he? 13 A. No. 14 Q. Mr. Epstein never tried to put your hand 15 anywhere, did he? 16 A. 17 Q. 18 penis, did 19 A. 20 Q. 21 A. 22 4. 23 he touch me." Were you lying to the police then? 24 A. No. Well, I wasn't being fully truthful, 25 but I wasn't lying. No. At no time did you touch Mr. Epstein's you? No. And he did not touch you, correct? Incorrect. Well, you told the police, "At no time did
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07:26:17 Page 2715 Public Records Request No.: 17-295
| | Page 41 |
|----|----------------------------------------------------------|
| 1 | You told the police twice when you spoke to
O. |
| 2 | that "at no time did he touch me." Didn't |
| 3 | you say that to the police? |
| 4 | A.
Yeah. |
| 5 | And you're saying that that was not fully
Q. |
| 6 | truthful.
Is that what you're saying now? |
| 7 | A.
Correct. |
| 8 | Q.
And you're saying if you're not fully |
| 9 | truthful, that's not a lie. Correct? |
| 10 | You took that out of context like really
A. |
| 11 | Touching my legs and
bad.
I didn't mean like that. |
| 12 | he never kept his hands to himself the entire time. |
| 13 | That's what I'm trying to say. |
| 14 | Q.
You told the police, "At no times did he |
| 15 | touch me." You agree with that, correct? |
| 16 | A.
No, I don't agree with that, because he did |
| 17 | touch me. |
| 18 | Did you tell the police that he did not
Q. |
| 19 | touch you, yes or no? |
| 20 | A.
It's a possibility, but I do not remember. |
| 21 | And you did not have any type of sex
Okay.
Q. |
| 22 | with Jeff, correct? |
| 23 | A.
No. |
| 24 | And you did not have any type of oral sex
Q. |
| 25 | with Jeff, correct? |
07.26,17 Page 2716 Pubic Records Request No 17-295
| | Page 42 | |
|----|-------------------------------------------------------------|--|
| 1 | A.
No. | |
| 2 | Q.
No type of intercourse with Jeff, correct? | |
| 3 | A.
Correct. | |
| 4 | Q.
All right.
Let's talk about what happened | |
| 5 | after the massage was over. | |
| 6 | A.
Okay. | |
| 7 | Q.
After the massage, you told Epstein that | |
| 8 | you wanted to bring your twin sister back so she could | |
| 9 | make some money, correct? | |
| 10 | A.
Incorrect. | |
| 11 | Q.
Your twin sister is
right? | |
| 12 | A.
Correct. | |
| 13 | Q.
And you love
very much, don't you? | |
| 14 | A.
Yes. | |
| 15 | Q.
And when you left the house you were joking | |
| 16 | with the other girls, weren't you? | |
| 17 | A.
Incorrect. | |
| 18 | Q.
Well, when Hayley and the other girl in the | |
| 19 | car that day made their statements to the police they | |
| 20 | told the police that you were joking afterwards.
Are you | |
| 21 | saying that they were lying to the police about that? | |
| 22 | A.
But a question or questions from
No. | |
| 23 | Hayley like she asked me questions, but it wasn't | |
| 24 | joking. She was kind of like in a happy way, like, | |
| 25 | what did you do?
What did you do?" Like those kind of | |
07/28/17 Page 2717 Public Records Request No.: 17-295
| | Pdqu 4 3 |
|----|---------------------------------------------------|
| 1 | things, but
it wasn't joking about it at all. |
| 2 | Q.
You joked about it, didn't you? |
| 3 | A.
No. |
| 4 | Q.
You said to
that if you did this |
| 5 | every weekend you'd be rich, didn't you? |
| 6 | That's
A.
No.
told me.
what |
| 7 | You didn't tell that to
Q. |
| 8 | Objection.
Asked and
MR. LEOPOLD: |
| 9 | answered. |
| 10 | THE WITNESS:
No. |
| 11 | BY MR. TEIN: |
| 12 | After you left Epstein's house you took the
Q. |
| 13 | nd the other
money and you went shopping with |
| 14 | girl in the car, correct? |
| 15 | I didn't spend any of the
A.
Incorrect. |
| 16 | money. |
| 17 | Q.
You went to Marshall's, didn't you? |
| 18 | I went along, yes, but I didn't
A. |
| 19 | You went shopping with them at Marshall's,
Q. |
| 20 | didn't you? |
| 21 | MR. LEOPOLD:
Objection. |
| 22 | I guess you could say that.
THE WITNESS: |
| 23 | Objection. Lack of predicate
MR. LEOPOLD: |
| 24 | Mischaracterization of earlier
and foundation. |
| 25 | testimony. |
07'26 17 Page 2718 Pubic Records Request No 17295
| | Page 44 |
|----|-----------------------------------------------------------|
| 1 | BY MR. TEIN: |
| 2 | Q.
And Bayley bought a purse, right? |
| 3 | A.
Yes. |
| 4 | Q.
And you were with her the whole time at |
| 5 | Marshall's, correct? |
| 6 | A.
Yes. |
| 7 | Q.
Now tell me about when the federal |
| 8 | prosecutors told you about getting reimbursed. |
| 9 | A.
I have no idea what you're talking about. |
| 10 | Q.
Tell me about when the federal prosecutors |
| 11 | spoke to you about getting money you feel you're entitled |
| 12 | to from Mr. Epstein. |
| 13 | A.
I don't know what you're talking about. |
| 14 | Do you know who
Q.
is? |
| 15 | A.
No, sir. |
| 16 | Did you ever meet with any federal
Q• |
| 17 | prosecutors? |
| 18 | A.
I think yeah.
I think they were |
| 19 | think they were like FBI. |
| 20 | Uh-huh.
Did you meet with federal
Q. |
| 21 | prosecutors? |
| 22 | A.
They came to my house one time, yes. |
| 23 | Q.
When did they come to your house? |
| 24 | A.
Very long ago. |
| 25 | Q.
Was it this year, 2008? |
07/26117 Page 2719 Public Records Request No.: 17-295
| | | Page 45 |
|----|---------------------|-----------------------------------------------|
| 1 | A. | It was not this year, no. |
| 2 | Q. | Was it 2007? |
| 3 | A. | I'd have to say at least two years ago or a |
| 4 | year ago, yeah. | So it would be 2007, 2006; but it was a |
| S | while ago. | |
| 6 | Q. | How many federal prosecutors or FBI agents |
| 7 | came to your house? | |
| 8 | A. | I'm trying to remember.
I want to say four |
| 9 | people came. | |
| 10 | Q. | Did they give you their business cards? |
| 11 | A. | If they did, I don't remember, and they |
| 12 | weren't toward me. | Maybe my parents have them.
I don't |
| 13 | know. | |
| 14 | Q. | Did they give you their cell phone numbers? |
| 15 | A. | No. |
| 16 | Q. | Did you ever speak to them on their cell |
| 17 | phones? | |
| 18 | A. | No, sir. |
| 19 | Q. | Did they speak to your parents? |
| 20 | A. | That's something you'd have to ask my |
| 21 | parents. | |
| 22 | Q. | Do you know whether they spoke to your |
| 23 | parent's? | |
| 24 | A. | No, sir. |
| 25 | Q. | You have no idea? |
07126117 Page 2720 Public Records Request No.: 17-295
| | Page 46 |
|----|-----------------------------------------------------|
| 1 | A.
No, sir. |
| 2 | MR. LEOPOLD:
Objection.
Asked and |
| 3 | answered. |
| 4 | BY MR. TEIN: |
| 5 | Q.
So if I say the name to you |
| 6 | Villafona, you don't know who that is? |
| 7 | A.
No, sir. |
| 8 | Q.
How many women and how many men came to |
| 9 | your house? |
| 10 | A.
I want to say two ladies and two guys. |
| 11 | Q.
Did someone named Jeffrey Sloman come to |
| 12 | your house? |
| 13 | A.
I don't know names, sir. |
| 14 | Q.
Do you know who Jeffrey Sloman is? |
| 15 | No, sir.
A. |
| 16 | Do you know who Jeffrey Herman is?
Q. |
| 17 | A.
Yes. |
| 18 | That's the lawyer who first sued Epstein on
Q. |
| 19 | your behalf, right? |
| 20 | A.
Yes. |
| 21 | Q.
Has Mr. Herman advanced your family any |
| 22 | money? |
| 23 | MR. LEOPOLD:
Any conversations that you've |
| 24 | had with Mr. Herman regarding that issue, you are |
| 25 | not to disclose.
If you've learned in some other |
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liOnRepaints and Tratescripout Inc. sor & Associates
| | Page 47 |
|----|-----------------------------------------------------------|
| 1 | fashion, you may answer. |
| 2 | THE WITNESS:
Okay. |
| 3 | I wouldn't know. |
| 4 | BY MR. TEIN: |
| 5 | Q.
You don't know? |
| 6 | A.
No. |
| 7 | MR. LEOPOLD:
Objection.
Foundation. |
| 8 | Attorney/client privilege. |
| 9 | BY MR. TEIN: |
| 10 | Q.
And you say you don't know who Jeff Sloman |
| 11 | is? |
| 12 | A.
No, sir. |
| 13 | Does it refresh your recollection that he's
Q. |
| 14 | the number two prosecutor at the U.S. Attorney's Office? |
| 15 | A.
No. |
| 16 | That he's
boss?
Q. |
| 17 | A.
No. |
| 18 | Does it refresh your memory that he's the
Q. |
| 19 | ex-partner of Jeff Herman, the first lawyer who sued |
| 20 | you sued Mr. Epstein on your behalf for fifty million |
| 21 | dollars? |
| 22 | A.
No, sir.
I don't know who he is. |
| 23 | Q.
Without telling me any conversations that |
| 24 | you've had with your lawyers, how is it that you selected |
| 25 | Mr. Herman as your lawyer from the 81,000 members of the |
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Reponas ad Tnescriptieo, lac.
| | | Page |
|----|-----------------|-----------------------------------------|
| 1 | Florida Bar? | |
| 2 | A. | I did not select him. |
| 3 | Q. | Who did? |
| 4 | A. | My father. |
| 5 | Q. | Did you ever meet Mr. Herman? |
| 6 | A. | Once. |
| 7 | Q. | Don't don't tell me what you discussed |
| 8 | with him. | Where did you meet him? |
| 9 | A. | I was shopping in my he showed up at my |
| 10 | friend's house. | |
| 11 | Q. | Whose house? |
| 12 | A. | My friend |
| 13 | Q. | Is that
from the Quarterdeck |
| 14 | Tavern? | |
| 15 | A. | Yes. |
| 16 | Q. | And did you have a meeting with him at |
| 17 | | ouse? |
| 18 | A. | Yes.
I guess you could say that. |
| 19 | Q. | And who else was there? |
| 20 | A. | My Aunt |
| 21 | Q. | And what was that meeting about? |
| 22 | | MR. LEOPOLD: Objection. That calls for |
| 23 | | attorney/client privilege. |
| 24 | BY MR. TEIN: | |
| 25 | Q. | What discussions did you have with |
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## . 1eponia2 ad Traascriptioes Inc. sor & Associates
Page 49 1 Mr. Herman in the presence of Tiffany Rich? 2 A. None. 3 Q. What discussions did you have in the 4 presence of her aunt? 5 A. Of my aunt? 6 MR. GOLDBERGER: It's the witness's aunt. 7 BY MR. TEIN: 8 Q. II, of your aunt. 9 A. The only one that we've ever discussed or 10 ever had. 11 Q. And so you were in a conversation with 12 Mr. Herman and your aunt? 13 A. Yes, sir. 14 Q. And you discussed privileged matters during 15 that conversation? 16 MR. LEOPOLD: Object to the form. I think 17 you might have to educate her on that question. 18 BY MR. TEIN: 19 Q. You discussed the lawsuit? 20 A. Yes. 21 Q. Did Tiffany Rich tell you about any 22 conversations that she had with Mr. Herman? 23 A. As far as I'm concerned, she's never spoken 24 or she's never had a conversation. She only opened the 25 door and then left. She's the one who answered the door.
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| | Page 50 |
|-----|---------------------------------------------------|
| 1 | why did the meeting take place at Tiffany
Q. |
| 2 | Rich's house? |
| 3 | I spent the night that night at her house.
A. |
| 4 | Q.
And when was this? |
| 5 | A while ago.
A. |
| 6 | Q.
How long ago? |
| 7 | A.
A month and a half ago.
I'm guessing. |
| 8 | Q.
A month and a half ago? |
| 9 | A.
Uh-huh. |
| 10 | So was it before of after Mr. Herman file°
Q. |
| 11 | the fifty-million-dollar lawsuit against Epstein? |
| 12 | A.
After. |
| 13 | Q.
Did you meet with an FBI agent named |
| 14 | Nesbitt Kurkendall, a woman? |
| 15 | I don't know.
A. |
| 16 | speak to you about
Q.
Did |
| 17 | getting reimbursed from Mr. Epstein? |
| 18 | I've never had a discussion with anyone
A. |
| 19 | about getting reimbursed from Mr. Epstein. |
| 20 | Have you met with an agent named Jason
Q. |
| 21 | Richards? |
| 22 | Not to my knowledge.
A. |
| 2 3 | How about an agent named Tim Slater?
O. |
| 24 | No, sir.
A. |
| 25 | How about an agent named Junior Ortiz?
O. |
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sor & Associates Reporting and Transcription, Inc.
| | Page 51 |
|----|-----------------------------------------------------------|
| 1 | A.
No. |
| 2 | And we've learned that many of the girls,
Q. |
| 3 | some of whom are as old as 23, were told by the |
| 4 | government that they would get money at the end of the |
| 5 | Does that sound familiar to you?
criminal prosecution. |
| 6 | A.
No, sir. |
| 7 | Other than Mr. Leopold here I'm not
Q. |
| 8 | asking about Mr. Herman either |
| 9 | A.
Uh-huh. |
| 10 | did anyone ever discuss with you that
Q. |
| 11 | you could get reimbursement for your damages? |
| 12 | No, sir.
A. |
| 13 | Did you or any member
Q. |
| 14 | MR. LEOPOLD: Are you referring to a |
| 15 | criminal matter or a civil matter? |
| 16 | BY MR. TEIN: |
| 17 | Did you or any member
Q. |
| 18 | Let me object to
MR. LEOPOLD:
Excuse me. |
| 19 | the form of the question. |
| 20 | BY MR. TEIN: |
| 21 | Did you or any member of your family ever
Q. |
| 22 | get a victim notification letter from anyone? |
| 23 | I no longer live at that residence and I
A. |
| 24 | wouldn't know. |
| 25 | Q.
So your testimony is that you have never |
| | |
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| | Page 52 |
|----|----------------------------------------------------------|
| 1 | received a victim notification letter, correct? |
| 2 | A.
Correct. |
| 3 | Q.
And your testimony is that you don't know |
| 4 | if your parents have ever received a victim notification |
| 5 | letter, correct? |
| 6 | A.
Correct. |
| 7 | Q.
Have you given any evidence to prosecutors |
| 8 | or law enforcement in this case? |
| 9 | What do you mean by evidence?
A. |
| 10 | Anything that you can touch or feel.
Q.
Well. |
| 11 | A.
No. |
| 12 | Objection to the form of the
MR. LEOPOLD: |
| 13 | question. |
| 14 | BY MR. TEIN: |
| 15 | Q.
So you haven't given anything physical - |
| 16 | A.
No. |
| 17 | Q.
any item to any prosecutor, police |
| 18 | officer or law enforcement agent, correct? |
| 19 | My cell phone four years ago or three years
A. |
| 20 | ago, but that's it. |
| 21 | Q.
You gave your cell phone to whom? |
| 22 | A. |
| 23 | Q.
Did she keep it? |
| 24 | A.
Ask her. |
| 25 | Q.
You gave it to her and then you didn't get |
07.26,17 Page 2727 Public Records Request No.: 17-295
Page 53 1 it back at the end of the meeting? 2 A. No. They -- yeah. No. They have it. I'm 3 guessing. I don't have it. 4 Q. How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7 question. Attorney/client privilege. 8 BY MR. TEIN: 9 Q. How much money are you hoping to get, you, 10 yourself, hoping to get out of Epstein? 11 MR. LEOPOLD: Same. Same objection, 12 attorney/client privilege. 13 Don't answer the question. 14 BY MR. TEIN: 15 Q. I'm not asking about what your lawyer told 16 you. 17 MR. LEOPOLD: I'm instructing her not to 18 answer the question, because any of those 19 conversations involve her counsel. 20 MR. TEIN: Certify that. 21 MR. LEOPOLD: Please. 22 CERTIFIED QUESTION 23 BY MR. TEIN: 24 Q. Now, you lied to get out of this 25 deposition, didn't you? Ph. 561.682.0905 - Fax. 561.682.1771
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07/26117 Page 2728 Public Records Request No.: 17-295
Page 54 1 A. No, sir. 2 Q. You didn't want to come to court today and 3 tell the story that you had told to the police under 4 oath, did you? 5 MR. LEOPOLD: Object to the form of the 6 question. Lack of foundation, predicate. 7 THE WITNESS: No. I have no problem coming 8 here and talking to you. 9 BY MR. TEIN: 10 Q. And to avoid getting served with a lawful 11 subpoena, you lied about your name, didn't you? 12 A. No. 13 Q. And in fact, just lying yourself wasn't 14 enough, was it? 15 MR. LEOPOLD: Objection to the form of the 16 question. 17 Don't answer it. It's not a question. 18 Object to the form of the question. Lack 19 of foundation. 20 MR. TEIN: Are you instructing her not to 21 answer? 22 MR. LEOPOLD: I am. 23 MR. TEIN: Certify it. 24 MR. LEOPOLD: Please. 25
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\* nReporting and Trunseription. Inc sor & Associates
| | Page 55 |
|----|---------------------------------------------------------|
| 1 | CERTIFIED QUESTION |
| 2 | BY MR. TEIN: |
| 3 | You asked your co-workers
Q. |
| 4 | MR. LEOPOLD:
It's vague and ambiguous. |
| 5 | BY MR. TEIN: |
| 6 | You asked your co-workers at the
Q. |
| 7 | Quarterdeck Tavern to lie for you, didn't you? |
| 8 | A.
I informed my boss about what was
No. |
| 9 | going on and he told me that he would help in any way |
| 10 | that he can. |
| 11 | Q.
Okay.
You got your
lie |
| 12 | by switching name tags with you, correct? |
| 13 | A.
Incorrect. It was a coincidence that same |
| 14 | night she was not wearing her name tag; she was wearing |
| 15 | But I was also not wearing I was wearing my
mine. |
| 16 | It just so
name tag.
Everyone switches name tags. |
| 17 | happens it was a coincidence that same night the people |
| 18 | came with the papers. |
| 19 | Will you put up Exhibit 18-001?
MR. TEIN: |
| 20 | MR. GOLDBERGER:
And mark 18-001 for |
| 21 | identification purposes to this deposition. |
| 22 | None of them have been marked
MR. LEOPOLD: |
| 23 | Can we mark them and put them as attachment
yet. |
| 24 | to the depositions? Because I think you've shown |
| 25 | three photos now. And this is the only one that |
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| | Page 56 |
|----|-----------------------------------------------------|
| 1 | has been marked for identification yet. |
| 2 | BY MR. TEIN: |
| 3 | Q. |
| 4 | MR. LEOPOLD: Hold on just a second.
Just |
| 5 | so the record is clear |
| 6 | MR. TEIN:
I'm not speaking to you. |
| 7 | MR. LEOPOLD: Okay.
Then don't speak to me |
| 8 | then.
But I'll speak to Mr. Goldberger, perhaps. |
| 9 | But at least for the record, can we put on |
| 10 | the record what the previous two photographs were |
| 11 | marked for identification? |
| 12 | MR. GOLDBERGER:
We will make sure that the |
| 13 | record is clear at the end of the deposition so |
| 14 | that there's no ambiguity. |
| 15 | MR. LEOPOLD:
Thank you. |
| 16 | BY MR. TEIN: |
| 17 | I've put a photograph marked 18-001
Q. |
| 18 | up on the screen.
Do you see that? |
| 19 | A.
Yup. |
| 20 | Who is that in the photo?
Q. |
| 21 | Tiffany on the left and me on the right.
A. |
| 22 | Q.
Tiffany Rich, right? |
| 23 | A.
Yes. |
| 24 | Tiffany Rich, your friend at the
Q. |
| 25 | Quarterdeck Tavern, right? |
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| | Page 57 |
|----|------------------------------------------------------|
| | A.
Yes. |
| 2 | Tiffany, your friend, who you say the day
Q. |
| 3 | that the process servers went to serve you with a |
| 4 | subpoena for this deposition, just happened just by |
| 5 | coincidence, was wearing your name tag? |
| 6 | Yes, sir.
A. |
| 7 | And just by coincidence, you were wearing
Q. |
| 8 | her name tag, correct? |
| 9 | A.
Yes. |
| 10 | Your testimony under oath is that's just a
Q. |
| 11 | coincidence, right? |
| 12 | A.
Total honesty. |
| 13 | It just happens to be the day that you were
Q. |
| 14 | going to be served with a subpoena, correct? |
| 15 | That wasn't the first day that
A. |
| 16 | MR. LEOPOLD:
just answer the |
| 17 | It calls for a yes or no.
question. |
| 18 | THE WITNESS:
Yes. |
| 19 | BY MR. TEIN: |
| 20 | You said that wasn't the first day you were
Q. |
| 21 | going to be you thought you were being served with a |
| 22 | subpoena, correct? |
| 23 | Correct.
A. |
| 24 | You knew before the day that you switched
Q. |
| 25 | name tags with Tiffany that the process servers were |
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sor & Associates Reporting sad Transcription. Inc. Page 58 1 looking for you, didn't you? 2 A. No. I knew -- 3 MR. LEOPOLD: Just answer it. It calls for 4 a yes or no. 5 THE WITNESS: Okay. No. 6 BY MR. TEIN: 7 Q. Now you can explain the answer that your 8 counsel stopped you from explaining.
9 A. Okay. I work at Quarterdeck and people 10 were telling me that people were looking for me. So yes, 11 I was aware that people were searching for me. But I had 12 no idea who they were or what their intentions were. But 13 I thought they were just people I didn't want to talk to. 14 So I just didn't want to talk to them. And every time 15 they'd come to work I wasn't there. And so happens the 16 night that they came in me and my friend switched name 17 tags. No big deal. 18 Q. That's a lie, isn't it?
19 MR. LEOPOLD: Objection. Don't answer that 20 question. That's harassment and I will not allow 21 it. He could ask the questions and we'll allow a 22 jury to make that determination, but not counsel. 23 I will not allow her to answer that 24 question. 25 MR. TEIN: Certify it.
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1 MR. LEOPOLD: I'll certify it. CERTIFIED QUESTION She's answered that question. She's explained it five 4 times already. The fact that Counsel doesn't like the answer, that's a different query. MR. TEIN: Stop making speaking objections. 7 MR. LEOPOLD: I'm not. I'm not going to put up with it, because it's in appropriate, Jack, 9 and you know it. I will not allow Counsel to berate a witness, whether it's in a criminal case 11 or a civil case, whether my client or MR. TEIN: Calm down. MR. LEOPOLD: Excuse me. No, I'm not going to allow it. That is not 15 proper. MR. GOLDBERGER: Okay. 17 MR. LEOPOLD: If he wants to say that she's lying after asking it five times and her explaining in great detail, he can do that. But I'm not going to allow her to answer, nor be harassed by him. It's improper. MR. GOLDBERGER: Okay. But your response that Counsel doesn't like the question -- or doesn't like the answer -- just let me finish. MR. LEOPOLD: Absolutely. I wasn't going
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Page 59
4SiknReporting and transcription, lac 1 2 3 Page 60 to interrupt you. MR. GOLDBERGER: Just requires us to say we like the answer to that question. And it's not 4 you and I or you and Mr. Tein who are testifying 5 6 7 time of asking the same question and then coming 8 back and pointing a finger at her and saying, 9 "You're a liar" -- 10 MR. TEIN: That didn't happen. 11 12 going to allow her to answer that question, 13 because she's answered that same question and has 14 explained it. 15 Now Counsel might be sitting there rubbing 16 17 But if he can't ask a question appropriately in a 18 19 20 21 22 23 24 that? 25 MR. TEIN: Ted - here. It's the witness. MR. LEOPOLD: Fine. But after the sixth MR. LEOPOLD: That's fine. But I'm not his head with a migraine. That's his problem. professional manner, we will leave. I will not allow her to be berated like that. MR. GOLDBERGER: Actually, we're very happy with the answer. MR. LEOPOLD: That's great. MR. GOLDBERGER: Do you want us to get into
sor & Associates
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Page 61 1 MR. LEOPOLD: This is really big stuff that you're going through. But that's fine; just ask your question and move on. But do it one time. If you don't understand it, I'll let you follow up, but I'm not going to allow you to ask the same question time and again and then call her a liar. 7 Just ask the question, get the answer and move to the next subject matter. MR. TEIN: Ted, I'm sitting right across the table from you. 11 MR. LEOPOLD: Yes, sir. MR. TEIN: Please be quiet. Don't yell. MR. LEOPOLD: I will not be quiet. MR. TEIN: Stop yelling. MR. LEOPOLD: , when I'm yelling you'll know it. I will not -- 17 MR. TEIN: My name is not MR. LEOPOLD: I thought your first name was , Mr. Tein. MR. TEIN: You watched me for three days at the evidentiary hearing where you sat in the back of the courtroom. You should know who I am. MR. LEOPOLD: Well, that's the impression you must have made in the courtroom. I will not be quiet.
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1 Page 62 MR. TEIN: That's obnoxious. Stop being 2 obnoxious. It's stupid. Let's go ahead with the 3 questions. 4 MR. LEOPOLD: I will make the record. 5 MR. TEIN: Let's get on with the questions. 6 MR. LEOPOLD: Do you need a break? 7 (Thereupon, a recess was taken.) 8 BY MR. TEIN: 9 Q. Okay. after you told your manager 10 at the Quarterdeck Tavern everything that was going on 11 and he told you he would help you any way he could, he 12 hid you in the kitchen from the process servers, correct? 13 A. Incorrect. 14 Q. Isn't it true that lying to avoid service 15 is a meaningless lie to you, ? 16 A. Incorrect. 17 Q. What is your manager's name? 18 A. I have three. Would you like to know 19 all -- 20 Q. Who's the one who lied for you? 21 A. Justin. 22 Q. And what did Justin do to lie for you? 23 A. Said I wasn't there. 24 Q. And who did he tell wasn't there? 25 A. Ask him.
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Page 63 1 Q. Where were you when Justin told this 2 someone that you were not at the Quarterdeck Tavern? A. Eating nachos. 4 Q. At the Quarterdeck Tavern? S A. Yes. 6 Q. What did you do so that Justin would lie to 7 the process servers for you? A. Nothing. 9 Q. You just got him to lie for you, didn't 10 you? A. No. I had no influence on him saying I wasn't there. Q. He took that upon himself? Isn't it true that Mr. Epstein's process servers had to ask the police to get you out of the restaurant so that they could serve you? MR. LEOPOLD: Objection. Lack of foundation, predicate. BY MR. TEIN: 20 Q. You can answer the question. MR. LEOPOLD: If you know. Don't guess. THE WITNESS: No. Can you repeat the question? MR. TEIN: Don't coach. MR. LEOPOLD: Don't guess.
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07126117 Page 2739 Public Records Request No.: 17-295
Page 65 1 Q. When did you delete your MySpace page? 2 A. A couple days ago. 3 Q. Who told you to take your MySpace page down 4 a couple of days ago? 5 A. Nobody. I'm sick and tired of MySpace. 6 Q. You all of a sudden got sick and tired of 7 MySpace and just a few days before this deposition you 8 decided to delete your MySpace page, correct? 9 A. Correct. 10 Q. Is that your testimony under oath? 11 A. Yes. 12 Q. Did you take your MySpace page down because 13 you thought the government might subpoena it? 14 A. Incorrect. 15 Q. Hadn't your MySpace page been up for over 16 three months before you took it down? 17 A. Correct. But I also had made tons of 18 MySpaces over the last years. I just get tired of them 19 and delete them because -- drama -- and make new ones. 20 Q. We're going to talk about that. 21 So you deleted your MySpace page after you 22 were already under subpoena for this deposition, correct? 23 A. Correct. 24 Q. What about the MySpace page didn't you want 25 us to see,
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Page 66 1 A. Nothing. 2 Q. Well, we're going to come back to MySpace 3 in a second. 4 A. You do that. 5 Q. I'm going to ask you some questions 6 about why you lie about your age so often, okay? 7 MR. LEOPOLD: Objection to the form. 8 Argumentative. 9 BY MR. TEIN: 10 Q. You lie about your age all the time, don't 11 you? 12 MR. LEOPOLD: Objection, argumentative. 13 THE WITNESS: Incorrect. 14 BY MR. TEIN: 15 Q. You lie about your age to get body 16 piercings, don't you? 17 A. Incorrect. 18 Q. You have body piercings, don't you? 19 A. Yes. 20 Q. You have four body piercings; isn't that 21 right? 22 A. Five. 23 Q. Other than the piercings on your ears 24 I'm not talking about that -- 25 A. ■, **then no; just one.**
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| | | Page 67 |
|----|------------------|---------------------------------------------------------|
| 1 | Q. | And where is the one body piercing? |
| 2 | A. | Belly. |
| 3 | Q. | When did you get that? |
| 4 | A. | For my birthday, with my stepmother and my |
| 5 | father. | |
| 6 | Q. | And when was that? |
| 7 | A. | When I was 14. |
| 8 | Q. | Okay. So you had that body piercing when |
| 9 | | you met Epstein, correct? |
| 10 | A. | It might have been, or maybe that yeah, |
| 11 | | either my 14th birthday or my 15th.
I honestly don't |
| 12 | remember. | |
| 13 | Q. | Now you've lied about your age to get into |
| 14 | | bars by using driver's licenses that aren't yours, |
| 15 | correct? | |
| 16 | A. | Incorrect. |
| 17 | Q. | Are you swearing under oath that you've |
| 18 | never done that? | |
| 19 | A. | Yes, I swear under oath. |
| 20 | Q. | And you've lied about your age to buy beer, |
| 21 | correct? | |
| 22 | A. | Incorrect. |
| 23 | Q. | You're swearing under oath that you've |
| 24 | | never lied to stores about your age? |
| 25 | A. | I've never lied to a store about my age or |
07/26117 Page 2742 Public Records Request No.: 17-295
| | | Page 68 |
|----|----------------------|--------------------------------------------|
| 1 | anything. | |
| 2 | Q. | You try to look much older than you are, |
| 3 | don't you? | |
| 4 | A. | Incorrect. |
| 5 | Q. | And you've lied about your age on your |
| 6 | | MySpace pages, don't you? |
| 7 | A. | Incorrect. |
| 8 | Q. | All right.
Let's look at Exhibit 26-01 |
| 9 | one. | |
| 10 | | MS. BELOHLAVEK:
26-001? |
| 11 | | MR. TEIN:
Yes. |
| 12 | BY MR. TEIN: | |
| 13 | Q. | On this page you lied to everyone that you |
| 14 | were 18, didn't you? | |
| 15 | A. | Correct. |
| 16 | 0. | Let's go to Exhibit 33. |
| 17 | | MS. BELOHLAVEK:
That's 33-001? |
| 18 | | TEIN: Correct. |
| 19 | BY MR. TEIN: | |
| 20 | Q. | On this page you lied to everyone that you |
| 21 | were 19, didn't you? | |
| 22 | A. | Incorrect. |
| 23 | | Just answer the question.
MR. LEOPOLD: |
| 24 | | THE WITNESS: ■, incorrect. |
| 25 | BY MR. TEIN: | |
07126117 Page 2743 Public Records Request No.: 17.295
| | Page 69 |
|----|-----------------------------------------------------------|
| 1 | Now you can explain your answer.
Q. |
| 2 | A.
I know that I have seen all of these and I |
| 3 | know that this one is mine. |
| 4 | Can you go down? |
| 5 | MR. LEOPOLD: Just for the record, you're |
| 6 | pointing to the photo. |
| 7 | THE WITNESS: I'm pointing to |
| 8 | BY MR. TEIN: |
| 9 | Q.
You're pointing to the one where it says |
| 10 | your age is 18? |
| 11 | A.
Correct. |
| 12 | That's yours, right?
Q• |
| 13 | A.
Correct.
That's mine from a couple years |
| 14 | ago that I have not been on, because I don't use that. |
| 15 | Please keep going down, please.
And I think that's it, |
| 16 | because there's no one just that one is mine. |
| 17 | So the one you pointed to where it says
Q. |
| 18 | your age is 18, that's yours, correct? |
| 19 | A.
Correct. |
| 20 | And when you wrote 18 as your age on your
Q. |
| 21 | MySpace page, that was a lie, wasn't it? |
| 22 | A.
Correct. |
| 23 | Q.
Did you lie about your MySpace page back |
| 24 | then because you couldn't post on MySpace unless you were |
| 25 | 18? |
07/26117 Page 2744 Public Records Request No.: 17.295
Page 70 1 A. Correct. There was a rule many years ago 2 that you had to be 18 to have a MySpace. 3 Q. So you lied about your age so you could 4 post on MySpace, right? 5 A. Yes. 6 Q. Let's go back to the top one on this page, 7 33-01. 8 Are you testifying now under oath that this 9 MySpace page where the headline says, "Twins do have more 10 fun," and the location is given as Lox, abbreviation for 11 Loxahatchee, and the age is 19, and it says - 12 is it your testimony that you did not post 13 that? 14 A. Correct. 15 Q. Now let's go back to the one that you were 16 pointing to before on this page, where it says your age 17 is 18 and you lied about your age to post MySpace, okay? 18 A. Uh-huh, yes. 19 Q. All right. Why did you finally put your 20 true age on your MySpace profile four days before you 21 were scheduled to testify before the Grand Jury? 22 A. I don't know what you're talking about. 23 MR. LEOPOLD: If you don't understand, ask 24 him to ask the question again. 25 MR. TEIN: Don't coach.
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sor & Associates Reporting and Transcription, lac. Page 71 1 THE WITNESS: I don't know which MySpace 2 you're talking about. 3 BY MR. TEIN: 4 Q. The MySpace page that you're just pointing 5 to, where it says you were 18. 6 A. Yes. 7 Q. And you were lying about your age, right? 8 A. Uh-huh. 9 Q. Why did you finally post your true age on 10 your MySpace profile -- 11 A. Uh -- 12 Q. -- four days before you were scheduled to 13 testify before the Grand Jury? 14 A. I honestly don't know which MySpace, 15 because I've had like a bazillion MySpaces, and in that 16 year, I had two, that one and another one, and that one's 17 been deleted. So I don't know which one you're referring 18 to. 19 Q. You remember that you changed your age on 20 your MySpace page from 18 to your true age just four days 21 before you went and testified in the Grand Jury? 22 A. No. 23 Q. You don't remember that. 24 A. No. 25 R. Do you remember Detective Recarey? Did you
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e Repartees ll ad Trsescripoeo, lac
| ever meet a Detective Recarey?
1
2
A.
I don't know the names.
Q.
How many different detectives have you met
3
with on this case from Palm Beach?
4
5
Probably a good six or seven, maybe.
A.
Did one of the detectives tell you before
Q.
6
7
you testified in the Grand Jury that you should take your
8
MySpace age and put your true age?
A.
No.
9
10
Q.
Didn't Detective Recarey have to come to
your house to pick you up to get you to testify in front
11
12
of the Grand Jury?
13
A.
Possibly; maybe because I didn't have a
ride; I was only 14 or 15 at the time.
14
15
Q.
Your mom didn't drive you?
16
A.
No.
17
Stepmom didn't drive you?
Q.
18
A.
I think my dad.
my dad; my dad drove
19
me.
20
Your dad drove you?
Q.
21
A.
Yes, sir.
22
So your testimony is Detective
Q.
did
23
not drive you, correct?
24
MR. LEOPOLD:
Objection.
/asked and
25
answered. | Page 7. |
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eRe l portiag ad Treascripoos, Inc. Page 73 1 THE WITNESS: No. I'm pretty sure my dad 2 drove me, because he was there with me. 3 BY MR. TEIN: 4 Q. Did any detective tell you to change your 5 age on your MySpace page, to put your true age? 6 A. No, sir. 7 Q. Now you also lied on your MySpace page 8 about your income, didn't you? 9 A. Yes. 10 Q. And you lied, saying that you made a 11 quarter million dollars a year and higher, correct? 12 A. As a joke, yes. 13 Q. That was a lie, wasn't it? 14 A. Yes. 15 Q. And you also lied on your MySpace page, 16 saying that you were married, didn't you? 17 A. Possibly. And that might have been an 18 error on my part. 19 Q. Now you also lie to the police, don't you? 20 A. No. 21 Q. Well, you lied to the police in your 22 tape-recorded statement that you gave to Detective 23 Pagan three years ago, didn't you? 24 A. To my knowledge, no, I did not. 25 O. Well, you lied to the police when you
sor & Associates
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Page 74 1 accused Mr. Epstein of attempting to murder your father, 2 didn't you? 3 A. No. I never heard a statement saying that 4 Mr. Epstein tried to murder my father. 5 Q. You made that statement, didn't you? 6 MR. LEOPOLD: Do you have a statement to 7 show her? That's been asked and answered. 8 MR. TEIN: I'm sorry. I didn't hear the 9 witness' answer, Mr. Leopold. 10 BY MR. TEIN: 11 Q. you told the police, didn't you, 12 that Mr. Epstein almost killed your father, didn't you? 13 A. No. 14 Q. Three years ago, before Mr. Epstein even 15 knew about this investigation, you told the police that 16 Epstein had "already come to my dad's house and did 17 something to my dad's tires and my dad almost died. 18 didn't want my dad to get hurt, because Jeff already 19 almost killed him." 20 Didn't you say that? 21 A. Not to my knowledge or recollection. I 22 have never said anything like that. 23 Q. That would have been a complete lie, 24 wouldn't it have been? 25 A. Yeah.
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Page 75 1 Q. Because Mr. Epstein never came to your dad's house, correct? A. Correct. 4 Q. And no one who worked for Mr. Epstein ever did something to your dad's tires, did they? MR. LEOPOLD: Objection. Lack of foundation, predicate. Don't guess. BY MR. TEIN: 10 4. It's not true that Mr. Epstein almost 11 killed your father, is it? MR. LEOPOLD: Objection. Asked and answered, lack of foundation, predicate. BY MR. TEIN: Q. You can answer. A. No. Q. Now you told the police that you didn't know who was in the car with you and Bayley on the day you went to Epstein's house, didn't you? A. Yes. Q. And that was a lie, wasn't it? A. It's the truth. Q. You told the police that there was someone in the car next to you and you specifically said you didn't know her name, right?
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07126O7 Page 2750 Public Records Request No.: 17-295
8 9 10 Bayley? Page 76 1 A. Correct. I do not know her name. 2 Q. You said, "I don't know her name, but she 3 was dark like a Spanish girl." Those were your words, 4 right? 5 A. Yes. 6 MR. LEOPOLD: Objection. Asked and 7 answered. BY MR. TEIN: Q. Who was in the car that day with you and 11 A. Again, I do not know. 12 Q. It was your good friend 13 wasn't it? 14 A. No. I don't know a 15 Q. 16 car with you 17 A. 18 Q. 19 20 A. 21 Q-22 A. 23 she's family. And yes. 24 Q. What's her e-mail? 25 You lied to the police about who was in the and didn't you? Incorrect. Let me ask you some questions about who you may have spoken to about this case. All right? Go ahead. Did you speak to your twin sister Not in detail, but of course she knows; A. I don't think she has an e-mail.
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| | Page 77 |
|----|---------------------------------------------------------|
| 1 | Q.
What is her phone number? |
| 2 | II, gosh.
A.
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 aboutillillillboyfriend Paul?
Did you |
| 9 | speak to him about Epstein's case? |
| 10 | That's my mom's boyfriend.
A.
My sister |
| 11 | doesn't have a boyfriend.
My mom's husband's name is |
| 12 | Paul, so maybe you get them confused. |
| 13 | Do you know his phone number?
Q. |
| 14 | A.
No. |
| 15 | Q.
Where does he live? |
| 16 | With my mom.
A. |
| 17 | In the same house with her?
Q. |
| 18 | A.
Yes.
They're married. |
| 19 | So not boyfriend; husband?
Q. |
| 20 | A.
Yeah, husband. |
| 21 | Have you spoken to Brett Albritton about
Q. |
| 22 | what happened in Mr. Epstein's house? |
| 23 | A.
Not in detail, but he knows the basics, |
| 24 | yes. |
| 25 | What is his e-mail?
Q. |
07126117 Page 2752 Public Records Request No.: 17-295
Page 78 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 street. 24 Q. What's the name of the apartment complex? 25 A. Something Cove. A. I don't know. Q. What is his phone number? A. How is that relevant? Q. What is his phone number? A. Q. What is his home address? A. I don't know. Q. Where does he live? A. In Palm Beach Lakes somewhere. Q. Ever been to his house? A. Yes. O. You don't know what his address is? MR. LEOPOLD: Objection. Asked and answered. She just said she doesn't know. MR. TEIN: Don't coach. MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. You can answer the question. A. I don't know the exact address. Q. What street is it on? A. It's an apartment complex; its not a
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| | Page 80 |
|----|-------------------------------------------------------------|
| 1 | We're not allowed to know
girls in this whole situation. |
| 2 | each other. |
| 3 | Q.
I didn't get the last four words. |
| 4 | A.
We're not allowed to know each other. |
| 5 | ? Have you
And what about
Q. |
| 6 | of met her? |
| 7 | A.
No, sir. |
| 8 | Q.
Let's see if I can refresh your memory on |
| 9 | her. She's the other person represented by your lawyer |
| 10 | Mr. Herman, who is suing Epstein for fifty million |
| 11 | dollars. |
| 12 | I have no knowledge of her.
A. |
| 13 | Q.
Never met her? |
| 14 | Never met her.
A. |
| 15 | Tony
Q. |
| 16 | A.
I don't know who that is either. |
| 17 | Q.
A person named Anthony who knows Hayley? |
| 18 | Is that Tony 11111111? |
| 19 | I don't know, sir.
A. |
| 20 | Q.
Do you remember making a statement to |
| 21 | that's in the police reports?
Detective |
| 22 | A.
No, sir. |
| 23 | Q.
Have you read the police reports in this |
| 24 | case? |
| 25 | A.
Yes. |
Page 81 1 Q. They're on the Internet, right? 2 A. Yes, I think. 3 Q. Were you surprised when the police reports 4 were released on the Internet containing your statements 5 that you had made to the police? 6 A. Yes. 7 Q. You didn't want to see that happen, right? 8 A. No. 9 Q. So you're saying you don't know a Tony 10 IIIIIIIIIt 11 MR. LEOPOLD: Objection. Asked and 12 answered. 13 BY MR. TEIN: 14 Q. Does it refresh your memory that he was 15 somebody who had gone to jail for drugs and car theft? 16 A. No, sir. 17 Q. Someone who knows Hayley? 18 A. No. 19 Q. You don't know if he met with Detective 20 Recarey? 21 A. No, sir. 22 Q. How about Zack Bryan? 23 A. Yes, I remember. I know who that is. 24 Q. Did you ever speak to Zack Bryan about what 25 happened at Mr. Epstein's house?
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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 Nick Kowalski? 7 A. Kowalski? 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 Nick Kowalski 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.
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| | Page 83 |
|----|-----------------------------------------------------------|
| 1 | Q.
Did you speak to
about this |
| 2 | case? |
| 3 | No, sir.
A. |
| 4 | Q.
Have you spoken to John Connolly about this |
| 5 | case? |
| 6 | A.
I don't know who John Connolly is.
No. |
| 7 | Q.
Did your parents speak to John Connolly? |
| 8 | Ask my parents.
A. |
| 9 | Let's see if I can refresh your memory as
Q. |
| 10 | to who he is. Okay? |
| 11 | Uh-huh.
A. |
| 12 | He's the Vanity Fair reporter who made a
Q. |
| 13 | financial arrangement with your father. |
| 14 | A.
I am aware of that.
And again, I was not |
| 15 | aware like that my dad did it until after it was done. |
| 16 | And I don't know the details about that.
I just know |
| 17 | what you know about that, like that they talked. |
| 18 | Q.
Tell me what you know about the financial |
| 19 | arrangement that John Connolly, the Vanity Fair reporter, |
| 20 | made with your father. |
| 21 | A.
I don't know about the details at all. |
| 22 | Q.
How much money did John Connolly give to |
| 23 | your father? |
| 24 | I don't even know he gave money to my dad.
A. |
| 25 | Q.
I'm sorry? |
07/26/17 Page 2758 Public Records Request No.: 17-295
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 John 3 Connolly 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 John Connolly, the Vanity Fair 10 reporter, offer any money to your father? 11 A. I don't know. 12 Q. Did John Connolly, the Vanity Fair 13 reporter, 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, John 25 Connolly, what other reporters have any member of your
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07/26/17 Page 2759 Public Records Request No.: 17-295
1 family spoken to? 2 A. I don't know. And I know my mom has spoken 3 to zero. My sister spoke to zero. My father and 4 stepmother, I wouldn't know. You'd have to ask them. I don't contact them. Q. Well, I just want to know -- I don't want you to -- I want to know what's in your mind. All right? 8 MR. LEOPOLD: She just told you. She just answered -- 10 MR. TEIN: Be quiet. BY MR. TEIN: Q. What I want to know is what you know from your personal knowledge. My question to you is: What knowledge do you have about family members of yours speaking to reporters? MR. LEOPOLD: Objection. Asked and answered. And if you can't talk professionally, we're going to leave. MR. TEIN: Do what you want to do. MR. LEOPOLD: Are you going to continue to talk this way? MR. TEIN: I'm not going to answer any question that you ask me, Mr. Leopold. MR. LEOPOLD: Okay.
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07126117 Page 2760 Public Records Request No.: 17-295
Page 85
Page 86 1 MR. TEIN: But you are misrepresenting the record and you are grandstanding for your client and it's wrong. So be quiet. And you know how to make an objection. Make it. Otherwise stop talking. BY MR. TEIN: 7 Q. MR. LEOPOLD: Excuse me. MR TEIN: If you want to leave the 10 deposition, leave. But you'll be back here. MR. LEOPOLD: Excuse me. If I could just make the record, instead of interrupting me, please. That's what we do professionally. 14 There's a recorder here. I'm certainly not being obstructionist. I'm going to make the record. But we're going to act with some semblance of professionalism, hopefully, by all parties in the room. That goes to me, that goes to your co-counsel sitting behind you and next to you, the court reporter and everyone else in the room. Everyone is entitled to that. You've asked a question. She answered the question fully and she's not going to be harassed because you don't like the answer. If you want to follow up --
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07/26/17 Page 2761 Public Records Request No.: 17-295
| | 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 | But if you want to follow with an
that. |
| 6 | appropriate question, feel free to do that.
But |
| 7 | we're not going to harass the witness. |
| 8 | MR. TEIN:
I disagree with everything |
| 9 | you've said.
Okay?
Let's ask the questions. |
| 10 | MR. LEOPOLD:
Ask an appropriate question. |
| 11 | MR. TEIN:
Are you going to stop talking? |
| 12 | MR. LEOPOLD: I'm going to make protect |
| 13 | my client and make appropriate objections. But |
| 14 | there's not a question pending right now. |
| 15 | BY MR. TEIN: |
| 16 | Q.
spoken to any reporters?
has |
| 17 | No.
A. |
| 18 | MR. LEOPOLD:
Asked and
Objection. |
| 19 | answered. |
| 20 | BY MR. TEIN: |
| 21 | Q.
Has
been given money by any |
| 22 | reporters? |
| 23 | A.
No. |
| 24 | Has your mom spoken to any reporters?
Q. |
| 25 | MR. LEOPOLD: Objection.
Asked and |
| | |
07126/17 Page 2762 Public Records Request No.: 17-295
Reporting ad Transcription. lac.
| | | Page 88 |
|----|-----------------------|-----------------------------------------------------------|
| 1 | | answered. |
| 2 | | THE WITNESS:
No. |
| 3 | BY MR. TEIN: | |
| 4 | Q. | Has your mom's husband Paul spoken to any |
| 5 | reporters? | |
| 6 | A. | No. |
| 7 | Q. | Has your mom's husband Paul received any |
| 8 | money from reporters? | |
| 9 | A. | No. |
| 10 | Q. | Are you sure you don't know |
| 11 | | MR. LEOPOLD:
Objection.
Asked and |
| 12 | | answered. |
| 13 | | THE WITNESS:
I'm positive. |
| 14 | BY MR. TEIN: | |
| 15 | Q. | I'll try again to refresh your memory. |
| 16 | A. | Okay. |
| 17 | 0. | 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. | I don't know who she is.
No. |
| 22 | Q. | Have you spoken to anyone else who's been |
| 23 | at Epstein's house? | |
| 24 | A. | No. |
| 25 | Q. | Without telling me what was said I don't |
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Page 89 1 want to know about any conversations with any lawyers, 2 okay -- 3 A. Uh-huh. 4 Q. -- did you or your parents speak to any 5 other law firms besides Mr. Herman and Mr. Leopold's law 6 firms? 7 A. No. 8 Q. Now without telling me about anything that 9 was said, what -- did one just come to mind? 10 A. No. I was thinking about something else. 11 Q. What were you thinking about? 12 A. Does family court matter? 13 Q. Okay. Without telling me what was said, 14 who prepared you for today's deposition? 15 A. What do you mean prepared? 16 Q. Did you talk about this deposition, about 17 what would happen, with anybody? 18 A. Yes. 19 Q. Don't tell me what was said. 20 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.
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Page 90 1 Q. Anybody else? 2 A. No. Q. When did you meet with Mr. Leopold to prepare for today's deposition? A. This morning. 6 Q. And how long did that meeting last? A. Until it started. Q. Now you told me that you previously had read the police reports in this case? A. Yes. Q. Have you read your statement that you gave to the police? A. Yes, sir. 14 Q. And in what form was that statement? A. What do you mean? Q. Was it in the form of a police report or a transcript? A. What's the difference? Q. A transcript has questions and answers on it. A police report is just typed out narrative. A. II, it's a police report. Q. And when did you read the police report? A. A few days ago. I overread it a few days ago. 25 Q. Had you read it before that?
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07/26/17 Page 2765 Public Records Request No.: 17-295
Page 91 1 A. No. 2 Q. Now you told me -- again, I don't want to 3 know what was said. 4 A. Uh-huh. 5 Q. You told me that you met with Mr. Leopold 6 this morning to prepare for your deposition, right? 7 A. Yes. 8 Q. When did you set up that meeting with 9 Mr. Leopold to take place this morning? 10 A. Gee, like, like five days ago, four days 11 ago. 12 Q. So you're aware that Mr. Leopold told us 13 that he could not start the deposition this morning 14 because he had a court appearance, correct? 15 MR. LEOPOLD: Don't answer that question. 16 Calls for attorney/client communications. 17 BY MR. TEIN: 18 Q. Have you seen the letter that Mr. Leopold 19 wrote to us stating that he -- an e-mail that Mr. Leopold 20 wrote to Mr. Goldberger stating that he could not be here 21 this morning because he had a court appearance? Did you 22 see that e-mail? 23 MR. LEOPOLD: You can answer that question. 24 THE WITNESS: No. 25
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07/26117 Page 2766 Public Records Request No.: 17-295
Page 92 1 BY MR. TEIN: 2 Q. Have you listened to your tape-recorded 3 statement to the police? 4 A. Yes. 5 Q. Where did you listen to that? 6 A. In, I think, this building. I don't know. 7 It was here. 8 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. 15 BY MR. TEIN: 16 Q. And you hadn't listened to your statement 17 before that, correct? 18 A. No, sir. 19 Q. Have you met with lawyers representing 20 anyone else suing Epstein? 21 A. No, sir. 22 Q. How many times have you spoken to officers 23 with the Palm Beach Police Department? 24 A. More than I like can count. It's been 25 ongoing for four years, so quite a few times.
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07/2607 Page 2767 Public Records Request No.: 17-295
| | Page 93 |
|----|----------------------------------------------------------|
| 1 | When was the last time you spoke with
Q. |
| 2 | officers of the Palm Beach Police Department? |
| 3 | A.
A while ago.
I'd say a year ago. |
| 4 | Q.
A year ago? |
| 5 | Maybe a year and a half.
A.
Yeah. |
| 6 | Do you remember Detective Recarey?
Q. |
| 7 | A.
No. |
| 8 | Do you remember
Pagan, Detective
Q. |
| 9 | Pagan? |
| 10 | A.
Yes. |
| 11 | Q.
How many times have you spoken to Detective |
| 12 | Pagan? |
| 13 | She was the only one I spoke to about this
A. |
| 14 | until for some reason she wasn't on the case anymore. |
| 15 | When was that?
Q. |
| 16 | The first meeting I ever had was with her
A. |
| 17 | and then I think like I met with her like 10 times or 12 |
| 18 | times or something like that, and then I didn't get |
| 19 | another investigator questioned me after that. |
| 20 | And who was that?
Q. |
| 21 | I don't remember.
A. |
| 22 | And what type of questions did they ask
Q. |
| 23 | you? |
| 24 | The same.
A. |
| 25 | The same questions all over again?
Q. |
07/26/17 Page 2768 Public Records Request No.: 17-295
| | | Page 94 |
|----|--------------------------|-----------------------------------------------------------|
| 1 | A. | Basically. |
| 2 | Q. | How many taped statements have you given to |
| 3 | the police? | |
| 4 | A. | One that I know of. |
| 5 | Q. | Just the one with Detective Pagan? |
| 6 | A. | Yes, sir. |
| 7 | Q. | How about to the FBI?
Did you give any |
| 8 | statements to them? | |
| 9 | A. | Well, actually, I don't really
No. |
| 10 | | remember if that was taped or not, to be honest with you. |
| 11 | | I had one meeting with them at my house and don't know if |
| 12 | it was taped. | |
| 13 | Q. | You were interviewed at Tiffany Rich's |
| 14 | house? | |
| 15 | A. | That was by the lawyer.
No. |
| 16 | Q. | II,
by the lawyer? |
| 17 | A. | Uh-huh. |
| 18 | Q. | Where did the conversation that you had |
| 19 | with the FBI take place? | |
| 20 | A. | At my father's residence. |
| 21 | Q. | Which is where? |
| 22 | A. | On Downers in Loxahatchee. |
| 23 | Q. | On where? |
| 24 | A. | Downers Road in Loxahatchee. |
| 25 | Q. | And when did that take place? |
07/26/17 Page 2769 Public Records Request No.: 17-295
Page 95 1 A. I'd have to say like a year and a half ago, 2 a year ago. It was a long time ago. 3 (Discussion held off the record.) 4 MR. TEIN: Tell me the last answer, please. 5 (Thereupon, a portion of the record was read 6 by the reporter.) 7 BY MR. TEIN: 8 Q. And who was present when the FBI spoke to 9 you at your father's house? 10 A. My stepmother was there, but she wasn't 11 around. She made herself like do other things. 12 Q. And how many FBI agents were there? 13 A. I think four. 14 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. 24 MR. LEOPOLD: Objection. Asked and 25 answered.
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07/26/17 Page 2770 Public Records Request No.: 17-295
I
| | sor & Associates
Reporting sad Traascripeon. Inc. |
|----|-----------------------------------------------------------|
| | Page 96 |
| 1 | BY MR. TEIN: |
| 2 | Q.
And the last time you spoke to the federal |
| 3 | prosecutor's office was when? |
| 4 | A.
I don't know. |
| 5 | Q.
Did any of the FBI agents tell you that |
| 6 | had spoken with Mr. Leopold? |
| 7 | |
| 8 | d any of the FBI agents tell you that |
| 9 | had spoken with Mr. Herman? |
| 10 | A.
No. |
| 11 | Q.
Did any FBI agents tell you that Jeff |
| 12 | Sloman spoke with Mr. Herman. |
| 13 | A.
No. |
| 14 | Q.
Did any FBI agents tell you that Jeff |
| 15 | Sloman spoke with Mr. Leopold? |
| 16 | A.
No. |
| 17 | Do you know whether any of the federal
Q. |
| 18 | prosecutors allowed Mr. Herman to review a draft |
| 19 | indictment? |
| 20 | A.
I wouldn't know. |
| 21 | Do you know if any of the federal
Q. |
| 22 | prosecutors discussed a draft indictment with Mr. Herman? |
| 23 | A.
I wouldn't know. |
| 24 | Have you ever e-mailed with any FBI agent
Q. |
| 25 | or any federal prosecutor? |
07126O7 Page 2771 Public Records Request No.: 17-295
| | Page 97 |
|----|--------------------------------------------------------|
| 1 | A.
No. |
| 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 | Do you have any way of getting in touch
Q. |
| 14 | with the FBI if you wanted to get in touch with them? |
| 15 | A.
No. |
| 16 | Q.
How about your parents?
Do they know how |
| 17 | to get in touch with the FBI? |
| 18 | A.
I don't know. |
| 19 | And by your parents, I'm referring to both
Q. |
| 20 | sets, okay? |
| 21 | II. Well, I'm referring to only my dad,
A. |
| 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 Paul? |
07/26117 Page 2772 Public Records Request No.: 17-295
| | Page 98 |
|----|---------------------------------------------------------|
| 1 | A.
Yeah. |
| 2 | Have you spoken to a lawyer named Burt
Q. |
| 3 | Ocariz about this case? |
| 4 | A.
No. |
| 5 | 0.
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
s. |
| 10 | s the lead federal
Q. |
| 11 | prosecutor
that's on the federal part of this case. |
| 12 | Okay? |
| 13 | A.
No. |
| 14 | So does it refresh your memory that Ocariz
Q. |
| 15 | is the good
friend of a
oyfriend? |
| 16 | A.
Not at all. |
| 17 | Does it refresh your memory that Villafona
Q. |
| 18 | tried to get Epstein to pay for Ocariz to represent you |
| 19 | in the federal case? |
| 20 | No.
A. |
| 21 | Do you know if Detective
spoken
Q. |
| 22 | with your father? |
| 23 | A.
No. |
| 24 | Do you know if Detective Recarey has spoken
Q. |
| 25 | to your stepmother? |
07/26/17 Page 2773 Public Records Request No.: 17-295
Page 99 1. 2 3 A. No. Q. How about with - -? A. Yes, I would know; and no, she did not. Q. Let's put up -- let me ask you some questions about the photo that you had posted on your MySpace page before you erased it last week. Okay? A. Okay. MR. TEIN: Do you mind if we close the door a second, please. MR. LEOPOLD: Exhibit number, please. 11 MR. TEIN: Put up 25-005. Hold on a second. MR. LEOPOLD: Don't say anything. she was talking to her counsel. MR. TEIN: Put up 25-006. MR. LEOPOLD: Is that 005 right there? MR. TEIN: Yes. BY MR. TEIN: 19 Q. Who took this photo of you in a warehouse, simulating being gang-raped by a bunch of -- 21 MR. LEOPOLD: Objection. Mischaracterizes the photograph, and lack of foundation and predicate. Fully explain if you need to. THE WITNESS: I will.
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07,26/17 Page 2774 Public Records Request No.: 17-295
| | Page 100 |
|----|------------------------------------------------------------|
| 1 | First off, this is not a warehouse.
This |
| 2 | is in Steven Lavelle's garage. |
| 3 | Second of all, I'm not being gang-raped. |
| 4 | Everyone has their clothing on. |
| 5 | Thirdly, if you'd look at all the other |
| 6 | pictures in that album, I'm drinking what's |
| 7 | when you're sick you drink it? |
| 8 | BY MR. TEIN: |
| 9 | You can't ask questions of your counsel.
Q. |
| 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 | You guys picked the possibly worst pictures |
| 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 |
| 16 | what we were doing. |
| 17 | Who's the man on the left of the picture
Q. |
| 18 | holding his holding a beer bottle as if it were a |
| 19 | penis towards your mouth? |
| 20 | Steven Lavelle.
A. |
| 21 | Who's the man behind you, right up towards
Q. |
| 22 | your backside, with you bent over? |
| 23 | A.
That one? |
| 24 | The right side, kissing with his mouth.
Q. |
| 25 | A.
That's Nick Antico. |
07126117 Page 2775 Public Records Request No.: 17-295
StinReporting and Truscription, Inc sor & Associates
Page 101 1 Q. He's the one grabbing towards the groin area of Steven Lavelle? 3 A. Yes. Q. And there's three other men in the photo. What are their names? The one on the left with the hat? A. That's Robbie Shergan (phonetic). Q. Smiling? A. Yes. Q. Who's the one kissing -- 10 MR. LEOPOLD: Don't interrupt. Let her finish the record. She's testifying. MR. TEIN: I know you don't like this picture, my friend. MR. LEOPOLD: The picture is fine. BY MR. TEIN: Q. Who's the one with the hat? MR. LEOPOLD: No. Hold on. Stop, You have to let the witness finish her answer. She was in the process of explaining and you cut her off. Please finish what you were saying and then Counsel can ask you whatever he wishes after that. THE WITNESS: Okay. This guy -- 24 MR. LEOPOLD: Just make it so the record is clear who you're referring to.
> Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07/26/17 Page 2776 Public Records Request No.: 17-295
| | | sor & Associates
Lipman end Treescripties. be. |
|----|--------------|---------------------------------------------------|
| | | Page 102 |
| 1 | | on the far left is John
THE WITNESS: |
| 2 | | |
| 3 | BY MR. TEIN: | |
| 4 | Q. | He's the one whose head is near the groin |
| 5 | | of Steven Lavelle, right? |
| 6 | A. | Yes. |
| 7 | Q. | And in the middle there's a man smiling. |
| 8 | Who's that? | |
| 9 | A. | That's Robbie Shergan. |
| 10 | Q. | And who's the one in the red hat, kissing? |
| 11 | A. | That's Brandon Salnal (phonetic). |
| 12 | Q. | Let me stop you for a second.
Are you |
| 13 | done? | |
| 14 | A. | Yes, I'm done. |
| 15 | Q. | Who is Courtney? |
| 16 | A. | My sister's friend.
Well, she's a mutual |
| 17 | | friend, but more my sister's. |
| 18 | Q. | What is her last name? |
| 19 | A. | Sailor. |
| 20 | Q. | Spell that. |
| 21 | A. | I don't know how to |
| 22 | Q. | Have you spoken to her about this case? |
| 23 | A. | No. |
| 24 | Q. | Who's Vince? |
| 25 | A. | My sister's friend.
I don't really speak |
07126/17 Page 2777 Public Records Request No.: 17-295
• Reporting and Transcriptine, Inc.
| | | Page 103 |
|----|----------------|--------------------------------------------|
| 1 | to him at all. | |
| 2 | Q. | What's his last name? |
| 3 | A. | Roman, |
| 4 | Q. | R-o-m-a-n? |
| 5 | A. | R-o-m-a-n. |
| 6 | Q. | And have you spoken to Vince about this |
| 7 | case? | |
| 8 | A. | No, sir. |
| 9 | Q. | Have you spoken to
bout 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 Justin about this case? |
| 18 | A. | Justin? |
| 19 | Q. | Do you have a friend named Justin? |
| 20 | A. | I do not have a friend named Justin. |
| 21 | Q. | From freshman year? |
| 22 | A. | No. |
| 23 | Q. | How about |
| 24 | A. | No. |
| 25 | Q. | Have you spokes
bout this case? |
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07126/17 Page 2778 Public Records Request No.: 17-295
| | Page 104 |
|----|---------------------------------------------------------|
| 1 | A.
No. |
| 2 | Q.
What's her last name? |
| 3 | A.
Duchesne.
I don't know how to spell it. |
| 4 | Q.
Is she the person whose house you went to |
| 5 | on New Year's this year? |
| 6 | A.
No.
I wasn't at her house on New Year's. |
| 7 | Q.
Where were you when you took the picture of |
| 8 | "Can you say blazed," that's on your website? |
| 9 | A.
I wouldn't know or wait.
We were at a |
| 10 | birthday party for some girl's 16th birthday. |
| 11 | Q.
Were you drinking at that party? |
| 12 | A.
No.
There was no alcohol or anything |
| 13 | there. |
| 14 | Q.
What does "blaze" mean to you? |
| 15 | A.
It's like it just means like messed up. |
| 16 | But we weren't, if you look at the picture. |
| 17 | Q.
Messed up like drunk, right? |
| 18 | A.
Sure. |
| 19 | Q.
Who's |
| 20 | A.
A girl I know, like from like two years |
| 21 | ago. |
| 22 | Q.
She's the one you were supposed to be |
| 23 | staying with when you went drinking with Nick Kowalski? |
| 24 | A.
No. |
| 25 | Q.
What'
last name? |
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07/26/17 Page 2779 Public Records Request No.: 17-295
| | Page 105 |
|----|--------------------------------------------------------|
| 1 | A. |
| 2 | Q.
Where does she live? |
| 3 | A.
I don't know.
In
Palm. |
| 4 | 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 |
| 10 | I'm not asking you about what you're
Q. |
| 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.
Nick Antico and Brandon Salnal. |
| 16 | Are these firemen?
Q. |
| 17 | A.
Steven Lavelle he said th(
Are those? |
| 18 | two stabbing with knives.
That's why I said that. |
| 19 | don't know.
That's Steven Lavelle and John |
| 20 | Are these firemen?
Q. |
| 21 | A.
No.
They're all on except Steven, |
| 22 | they're all on full rights for football. |
| 23 | Go to 025-015.
Q. |
| 24 | MR. LEOPOLD:
025 dash? |
| 25 | MR. TEIN:
015. |
07/2W] Page 2780 Public Records Request No.: 17-295
Page 106 1 THE WITNESS: Gosh, that's so long ago. 2 BY MR. TEIN: 3 Q. Who took the photo of you licking the 4 penis? 5 A. My stepmother. 6 Q. Whose idea -- that was your stepmother's 7 idea? 8 A. It was in Buca di Beppo, where she works 9 currently, and that was before she worked there. And we 10 just thought it would be funny. 11 MR. TEIN: 19-007. Can you enlarge that? 12 BY MR. TEIN: 13 Q. Who took this photo of you simulating you 14 having sex with a man? 15 A. We're not simulating having sex, and 16 it's -- II, and the person who took it was, I'm pretty 17 sure, Chris, but I know him as Swiss. I don't know his 18 last name. 19 Q. Go to 19-006, please. 20 Who took this photo of you simulating sex 21 with a man? 22 A. The same person. And we're not simulating 23 having sex, Mr. -- 24 Q. Tein. 25 Did you post that on the Internet?
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| | Page 107 I |
|----|-----------------------------------------------------------|
| 1 | A.
Actually, this is an old MySpace I never |
| 2 | I just kind of
finished and I never like did anything. |
| 3 | made it and left it. |
| 4 | Q.
So the answer is yes, you posted this on |
| 5 | MySpace? |
| 6 | A.
Yup. |
| 7 | Who took this photo of you
Q.
Go to 25-016. |
| 8 | simulating sex with a woman? |
| 9 | MR. LEOPOLD: Object to the form of the |
| 10 | question.
Argumentative. |
| 11 | First off, she's piercing my
THE WITNESS: |
| 12 | belly button or repiercing it, and I'm pretty sure |
| 13 | it was just like we put up a camera somewhere and |
| 14 | put a timer on it. We didn't have anybody take |
| 15 | it. |
| 16 | BY MR. TEIN: |
| 17 | Q.
You posted that on your MySpace page? |
| 18 | A.
Yeah. |
| 19 | Go to 25-013.
Is that a photo of you?
Q. |
| 20 | A.
Yep. |
| 21 | Q.
Who's in the photo with you? |
| 22 | A.
Steven. |
| 23 | Q.
Steven Lavelle? |
| 24 | A.
Yep. |
| 25 | Q.
Is this you coming out of the shower? |
07/26/17 Page 2782 Public Records Request No.: 17-295
sor & Associates Reporting and Transcriptico, In.
1 2 A. Q. Page 108 Yes. 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 Steven's 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 Brett Albritton, 12 correct? 13 A. Yeah. 14 O. You lie about your age in order to conceal 15 something about your relationship with Brett Albritton; 16 isn't that correct? 17 A. No. 18 Q. Brett's 22 years old, isn't he? 19 A. Yes. 20 Q. And Brett is 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.
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Page 109 1 Q. Well -- 2 MR. LEOPOLD: Just answer the question, 3 Saige. 4 THE WITNESS: Yes. 5 BY MR. TEIN: 6 Q. Did they know two weeks ago that you were 7 dating an underage girl (sic)? 8 A. Yes. I met everybody in there. 9 Q. Did they know your age? 10 A. Yes. 11 Q. Did you lie about your age so that the fire 12 department wouldn't think that Brett is 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 that Brett is having a sexual relationship with an 22 underage girl? 23 MR. LEOPOLD: Don't guess. Answer if you 24 know. 25 THE WITNESS: Can you repeat the question? Ph. 561.682.0905 - Fax. 561.682.1771
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Reporting and Transcription. Inc.
Page 110 1 BY MR. TEIN: Q. Does the Palm Beach Police Department know that Brett, a member of the Palm Beach Fire Department, 4 is having a sexual relationship with an underage girl? A. I'm guessing no. 6 Q. You lie about your twin sister don't you? MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: 10 Q. Don't you? A. No. I have never lied for or to Q. You lie about the fact that she has a drug habit, right? A. No. I would never accuse my sister of having a drug habit. 16 Q. Do you try to conceal the fact that she has a drug habit? MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: Q. You can answer the question. A. No. My sister does not have a drug habit. Q. You lied when you went to the crack house in Georgia, didn't you? MR. LEOPOLD: Objection. Argumentative. Lack of foundation, lack of predicate.
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Page 111 1 THE WITNESS: Never -- what did you say? BY MR. TEIN: Q. You lied when you went to the crack house in Georgia, didn't you? MR. LEOPOLD: Objection. Argumentative. Lack of foundation, lack of predicate. BY MR. TEIN: Q. You can answer the question. A. I have never been to a crack house. 10 Q. Who don't you lie to? MR. LEOPOLD: Objection. Argumentative. Don't answer the question. MR. TEIN: Certify it. CERTIFIED QUESTION BY MR. TEIN: Q. You don't lie to no you? MR. LEOPOLD: Objection. Asked and answered. Don't answer the question. BY MR. TEIN: Q. No. You can answer that question. MR. LEOPOLD: No. I just told her not to. You've asked that question about five -- 24 MR. TEIN: No, I haven't. MR. LEOPOLD: Don't answer the question.
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Page 112 1 2 CERTIFIED QUESTION 3 4 stop interrupting me because she can't take down 5 both of us talking at the same time. BY MR. TEIN: Q. You tell the truth, don't you? A. Excuse me? Q. You tell the truth, don't you? A. When it's yes, I tell the truth. Q. Who's drug dealer? A. My sister does not have a drug dealer. She 6 7 8 9 10 11 12 13 lives in Georgia with my mother. 14 Q. Okay. Who is the drug dealer who dropped 15 16 all night, the two of you, using drugs at Palm Beach 17 Country Estates where your father called the police? 18 A. Mike Duval. 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 MR. TEIN: I'll certify it. MR. LEOPOLD: For the record, you have to you and off at 5:45 a.m., in 2006, after being out
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07126117 Page 2787 Public Records Request No.: 17-295
Page 113 1 involuntarily admitted into a juvenile educational 2 facility; isn't that right? 3 A. Did you say involuntarily? 4 Q. Yes. 5 A. No. I was willing to go. I -- duly said 6 sure. 7 Q. And you went there because you were lying 8 so much, no one could control you; isn't that correct? 9 A. That's very incorrect. 10 Q. Now you lie to your parents all the time, 11 don't you? 12 A. Incorrect. 13 MR. LEOPOLD: Objection. Argumentative. 14 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 your 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.
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07/26/17 Page 2789 Public Records Request No.: 17-295
Page 115 1 BY MR. TEIN: 2 Q. Okay. When your counsel that it was there 3 was lack of foundation, you agree with your counsel, 4 right? 5 A. I was like saying, "Yeah, let's move on," 6 because there was no point to asking that question. 7 Q. Your father threw out of the house 8 because she was lying, correct? 9 MR. LEOPOLD: Objection. Lack of 10 foundation. 11 Hold on, . Let me just make the 12 objection. 13 Lack of foundation, predicate, calls for 14 speculation. 15 BY MR. TEIN: 16 Q. Answer. 17 A. I'm not my sister. I don't know. 18 Q. I want to know what you know only. 19 A. I don't know. 20 Q. You don't know. That's your answer? 21 A. Yes. 22 Q. Now your parents filed the police report 23 regarding Mr. Epstein, right? 24 A. Yes. 25 Q. Now your parents are also lying, aren't
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sor & Associates Reporties ad Trasscripooe. inc.
| | | Page 116 |
|----|-------|-------------------------------------------------|
| 1 | they? | |
| 2 | | A.
Yes. |
| 3 | | Just so the record is clear,
MR. LEOPOLD: |
| 4 | | the father because the mother was up north. |
| 5 | | MR. TEIN:
Don't testify, Counsel. |
| 6 | | MR. LEOPOLD: So the record is clear, just |
| 7 | | The mother was
the father. |
| 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 | | You need to behave yourself,
MR. TEIN: |
| 22 | | lawyer. |
| 23 | | MR. LEOPOLD:
The natural mother lives in |
| 24 | | The father is here locally.
Georgia. |
| 25 | | MR. TEIN:
Stop coaching. Stop talking. |
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07/26/17 Page 2791 Public Records Request No.: 17-295
Page 117 1 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 now. Give us a five-minute speech, Mr. Leopold. MR. LEOPOLD: Are you finished, for the 7 record? MR. TEIN: I'm not talking to you. Do what you want. 10 MR. LEOPOLD: Don't say anything yet. BY MR. TEIN: 12 Q. your parents -- 13 MR. LEOPOLD: Hold it. Don't say anything yet. Let me -- 15 BY MR. TEIN: 16 0. Your parents, who filed the police report are also liars. MR. LEOPOLD: Don't answer the question. We're not going to answer until I make the record. I want to put on the record, now that Counsel appears to be finished with his comments for the record, that the previous question was inappropriate, was intentionally misleading. Now you can ask the question. BY MR. TEIN:
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07126117 Page 2792 Public Records Request No.: 17-295
Page 118 1 Q. Your parents, who filed the police report 2 in this case, are also proven liars, aren't they? 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. 15 BY MR. TEIN: 16 Q. Your dad went to federal prison for two 17 years for lying, right? 18 A. Correct. 19 Q. Did he tell you it was for a financial 20 fraud? 21 A. Yes. 22 Q. For stealing money from some financial 23 institution? 24 A. Correct. 25 Q. And do you think your father is trying to
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Page 119 1 steal your lawsuit money away from you? 2 Don't look to your lawyer for the answer. MR. LEOPOLD: You can answer if you know the answer to it. I have no idea. THE WITNESS: Yeah. BY MR. TEIN: 7 Q. And your father filed a lawsuit, the first lawsuit for fifty million dollars against Mr. Epstein without consulting you, correct? 10 A. Correct. 11 Q. And your father had a lawyer file the first lawsuit on your behalf for fifty million dollars against Mr. Epstein without your knowledge, correct? A. Correct. Q. And you don't trust your father, do you? A. Correct. 17 Q. And you believe he's trying to manipulate you for his own gain, don't you? 19 A. Sort of. Q. Well, you know that your mother filed a statement, an affidavit, saying that you don't trust your father and that you believe he's trying to manipulate you for his own gain; isn't that correct? A. Correct. 25 0. You agree with that statement, don't you?
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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 24 Hawthorne Aviation? 25 A. No.
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Page 121 1 Q. Did she tell you that she was, fired from 2 Hawthorne Aviation for stealing? 3 A. No. 4 MR. TEIN: Let's take a break. (Thereupon, a recess was taken.) BY MR. TEIN: 7 Q. before you met Jeffrey Epstein, had you ever had sexual intercourse? A. Yes, yeah. 10 Q. How many times? A. Just a few. Twice. 12 Q. With how many different men? 13 A. Two. Q. How old were they? A. Zack Bryan, being one year older than me, and then the other person was two years older than me. Q. What was his name? A. Ryan Ortell. Q. How old were you when you first had sexual intercourse? 21 A. 14. Q. How many -- before you met Epstein, how many different men had you had any type of sexual activity with? A. Just those two.
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| | Page 122 |
|----|--------------------------------------------------------------|
| 1 | Are you saying you never kissed a man other
Q. |
| 2 | than those two? |
| 3 | Objection to the form of the
MR.
LEOPOLD: |
| 4 | question. |
| 5 | I had kissed people
Yes,
THE WITNESS: |
| 6 | before. |
| 7 | BY MR. TEIN: |
| 8 | Before you met Epstein,
had you ever had
Q. |
| 9 | oral
sex? |
| 10 | A.
No. |
| 11 | Ever in your life,
have you exchanged sex
Q. |
| 12 | for something of value? |
| 13 | No.
A. |
| 14 | We're done.
MR. TEIN: |
| 15 | II, okay.
THE WITNESS: |
| 16 | We'll read.
LEOPOLD:
MR. |
| 17 | I don't
have any
MS. BELOHLAVEK: |
| 18 | questions.
Thank you. |
| 19 | Before we go off
the record,
MR.
LEOPOLD: |
| 20 | it's
my understanding Mr. Goldberger can |
| 21 | correct
the record but we have stipulated
that |
| 22 | color copies of the documents that
were identified |
| 23 | for identification
certainly
will
be attached
to |
| 24 | the deposition
and counsel will
be taking the |
| 25 | photographs across street
so that
they can be |
07/26117 Page 2797 Public Records Request No.: 17-295
| 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 | I'll have copies sent to the court
either. |
| 12 | reporter and she can attach them to the |
| 13 | deposition. |
| 14 | MR. LEOPOLD: So you're not going to agree |
| 15 | to what we talked about during the break then. |
| 16 | MR. GOLDBERGER:
I'm not quite sure what |
| 17 | Let me finish.
your asking me to do. |
| 18 | That's fine.
MR. LEOPOLD: Okay. Sure. |
| 19 | If you want me to
MR. GOLDBERGER: Okay. |
| 20 | go over to Ms. Belohlavek's office and make copies |
| 21 | and then I'll give those to the court reporter, |
| 22 | fine.
All I'm saying is that I would avoid that |
| 23 | process.
I would send copies to the court |
| 24 | But if it will make you happier
reporter. |
| 25 | MR. LEOPOLD: I'm not? |
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07/26/17 Page 2798 Public Records Request No.: 17-295
| 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 | I will do that.
MR. LEOPOLD:
Excuse me. |
| 16 | You can't do
Let me finish the record, please. |
| 17 | She's going to stroke
that to the court reporter. |
| 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 |
| 23 | his voice, please. |
| 24 | MR. TEIN:
Finish your sentence.
Is there |
| 25 | going to be a period at the end of the sentence or |
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07126/17 Page 2799 Public Records Request No.: 17-295
1 is it just going to be comma after comma after 2 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. 21 MR. TEIN: You're wrong. Finish your 22 sentence because you're talking about something 23 you have no idea. 24 Every single one is marked, Ted. Every
25 single one is already marked. But you want to
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Reporting and lransctipta Id<
| | Page 126 |
|----|------------------------------------------------------|
| 1 | Ever single one is
argue about everything. |
| 2 | 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. |
| 5 | MR. TEIN:
You've made Ted, you are |
| 6 | obstructionist, you are a liar.
You have lied and |
| 7 | misrepresented things, for the record.
You are |
| 8 | grandstanding. |
| 9 | MR. LEOPOLD:
You need to back up. |
| 10 | No, no. I'm going to finish.
MR. TEIN: |
| 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 | Don't you dare threaten me with sanctions, |
| 17 | after you lied in a letter to my co-counsel about |
| 18 | the fact be quiet. Be quiet and let me finish. |
| 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 |
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Page 127 1 finish. You behave. 2 MR. LEOPOLD: Don't point your finger at me. MR. TEIN: Listen. Be quiet and I won't have a need to point it at you. MR. LEOPOLD: Don't point your finger at MR. TEIN: Mr. Leopold -- 8 MR. LEOPOLD: Don't point your finger at me. MR. TEIN: Mr. Leopold, let me finish. MR. LEOPOLD: Don't raise your voice either. MR. TEIN: Mr. Leopold -- 14 MR. LEOPOLD: Jack, do you want to take care of this? MR. TEIN: Let me finish my sentence. The exhibits are marked. We are walking out of here. You are someone who misrepresents the record. It is absolutely atrocious what you do. That is not how a lawyer should behave. This deposition is over. You will get your exhibits, Mr. Leopold. MR. GOLDBERGER: I understand what you're saying, Michael, and I understand Ted's position. Just so there's -- we're going to have lots
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| | Page 128 |
|----|----------------------------------------------------|
| 1 | of issues in this case. We're going to have lots |
| 2 | of reasons to disagree. |
| 3 | I'm going to take it over now and I'm going |
| 4 | to make copies and I'm going to give them to |
| 5 | Ms. Consor. If you want to go find some exhibit |
| 6 | labels and put some exhibit labels on it, be my |
| 7 | guest.
But that's what I'm offering to do. |
| 8 | THE WITNESS:
Let me say two things, |
| 9 | because I am happy to always disagree, and with |
| 10 | you, I have no problem; we could always do it |
| 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. |
| 18 | MR. LEOPOLD: Jack, if you represent |
| 19 | that the documents have the appropriate exhibit |
| 20 | numbers or some identifying markings, 25, 30.000, |
| 21 | whatever they may be, then you can take them, make |
| 22 | copies, send me a copy, make sure the court |
| 23 | reporter gets a copy and then send me a bill for |
| 24 | my copies, that's fine.
I didn't know that they |
| 25 | are marked that way because I haven't been able to |
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nsor & Associates Refer:intl. and Transcript:a. Inc
1 2 3 4 Page 129 look at them. MR. GOLDBERGER: They are barcoded, and the number that we've made reference to in the deposition coincides with the barcoding. 5 MR. LEOPOLD: That's fine. Eight by eleven 6 color laser copies are fine. 7 MS. BELOHLAVEK: The State Attorneys Office 8 is not going to charge anybody for color copies I 9 print out. 10 MR. LEOPOLD: That's fine. He's going to 11 take them back to his office. 12 Secondly -- and I will be more than happy 13 to do it, because it sounds like you all know more 14 about it than I -- but I'm happy to get affidavits 15 from Mr. Pincus, Judge Stern, everybody else about 16 what happened with this hearing today, because I 17 know very little about it. But my representations 18 are what they are. 19 MR. GOLDBERGER: They stay -- 20 MR. LEOPOLD: Let me just finish for the 21 record. 22 My representations or comments about what 23 happened, representation about this hearing this 24 morning, I know very little about it. I -- 25 MR. GOLDBERGER: I'll take your word on
> Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
07i26,17 Page 2804 Public Records Request No.: 17-295
\* Reportiag and Transcriptiaa, lac sor & Associates Page 130 1 that. 2 MR. LEOPOLD: No, no, no. I just put it on 3 the record. I will get an affidavit -- I'm 4 assuming it sounds like you need it -- from Mr. 5 Pincus. I have no clue about what happened and 6 why it was canceled. All I was told when I was 7 out of town yesterday was that the hearing this 8 morning was cancelled. 9 MR. GOLDBERGER: I'll take your word for 10 it. 11 MR. LEOPOLD: If you want an affidavit, 12 I'll get it for you. 13 MR. GOLDBERGER: It's a personal issue for 14 me because I had to disrupt a vacation and if it 15 was done just because it wasn't convenient for 16 you, then I'm offended by that. But if you're 17 telling me that it was planned and it didn't 18 happen, I'll take your word for it. 19 MR. LEOPOLD: I am more than happy to get 20 you an affidavit, because I don't know the reason 21 why it was canceled other than the fact that I'm 22 assuming since my deposition was taken for four 23 hours on Monday for preparation for the hearing 24 today, for whatever reason it was canceled, I am 25 told it is being re-noticed. Why it was canceled,
> Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
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| | Page 131 |
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| 1 | I have no idea, but if your co-counsel-
wishes an |
| 2 | affidavit to that effect from Mr. Pincus, I'm more |
| 3 | than happy to get it. But I don't know the reason |
| 4 | why it was canceled. |
| 5 | MR. TEIN:
But what I do
I don't need it. |
| 6 | take issue with is regardless of why it was |
| 7 | canceled, you owed us the courtesy of saying, You |
| 8 | know what? We can start earlier this morning. |
| 9 | MR. LEOPOLD: I owe you nothing. |
| 10 | MR. TEIN:
I don't care.
Don't interrupt |
| 11 | me. |
| 12 | Because Jack canceled his vacation plans |
| 13 | because of you. |
| 14 | MR. GOLDBERGER: That's all right, that's |
| 15 | all right. |
| 16 | MR. TEIN:
And you're selfish. And this |
| 17 | deposition is over. Good-by Mr. Leopold. |
| 18 | MR. GOLDBERGER:
You can go off the record. |
| 19 | |
| 20 | |
| 21 | |
| 22 | |
| 23 | |
| 24 | |
| 25 | |
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| | sor & Associates
Reporting sad Traniatiptica, lac. |
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| | Page 132 |
| 1 | CERTIFICATE |
| 2 | |
| 3 | |
| 4 | The State of Florida, |
| 5 | County of Palm Beach. |
| 6 | |
| 7 | I hereby certify that I have read the |
| 8 | foregoing deposition by me given, and that the statements |
| 9 | contained herein are true and correct to the best of my |
| 10 | knowledge and belief, with the exception of any |
| 11 | corrections or notations made on the errata sheet, if one |
| 12 | was executed. |
| 13 | |
| 14 | |
| 15 | day of
Dated this
, 2008. |
| 16 | |
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sor & Associates Reporting ad Trunciiption. lac.
Page 133 1 DATE: February 25, 2008 2 TO: c/o Lana Belohlavek 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 within a reasonable time, the original, which has already 12 been forwarded to the ordering attorney, may be filed with the Clerk of the Court. If you wish to waive your 13 signature, sign your name in the blank at the bottom of this letter and return it to us. 14 Very truly yours, 15 Judith F. Consor, FPR 16 Consor & Associates Reporting and Transcription 1655 Palm Beach Lakes Boulevard, Suite 500 West Palm Beach, Florida 33401 I do hereby waive my signature: 17 18 19 20 cc via transcript: JACK A. GOLDBERGER, ESQ. 21 LANNA BELOHLAVEK, ESQ. MICHAEL R. TEIN, ESQ. 22 THEODORE J. LEOPOLD, ESQ. file copy 23 24 25
Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
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sor & Associates Reporting rod Transcription, lac. Page 134 ERRATA SHEET 2 IN RE: STATE-V-JEFFREY EPSTEIN DEPOSITION OF: TAKEN: February 20th, 2008 DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE PAGE if LINE I CHANGE REASON 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:
## Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, ft 33401
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| | sor & Associates
Reporting sad Transcripoon. Inc. |
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| | Page 135 |
| 1 | THE STATE OF FLORIDA, ) |
| 2 | COUNTY OF PALM BEACH. ) |
| 3 | |
| 4 | |
| 5 | I, the undersigned authority, certify that |
| 6 | personally appeared before me on the 20th |
| 7 | of February, 2008 and was duly sworn. |
| 8 | |
| 9 | WITNESS my hand and official seal this 25 day |
| 10 | of February, 2008. |
| 11 | |
| 12 | |
| 13 | |
| 14 | |
| | Judith F. Consor, FPR |
| 15 | Notary Public - State of Florida |
| 16 | |
| 17 | |
| 18 | |
| 19 | |
| 20 | |
| 21 | |
| 22 | |
| 23 | |
| 24 | |
| 25 | |
| | Page 136 |
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| 1 | CERTIFICATE |
| 2 | |
| | The State Of Florida, ) |
| 3 | County Of Palm Beach. ) |
| 4 | |
| 5 | I, Judith F. Consor, Court Reporter and Notary |
| | Public in and for the State of Florida at large, do |
| 6 | hereby certify that I was authorized to and did |
| | stenographically report the deposition of |
| 7 | that a review of the transcript was requested; and that |
| | the foregoing pages, numbered from 1 to 131, inclusive, |
| 8 | are a true and correct transcription of my stenographic |
| | notes of said deposition. |
| 9 | |
| | I further certify that said deposition was |
| 10 | taken at the time and place hereinabove set forth and |
| | that the taking of said deposition was commenced and |
| 11 | completed as hereinabove set out. |
| 12 | I further certify that I am not an attorney or |
| | counsel of any of the parties, nor am I a relative or |
| 13 | employee of any attorney or counsel of party connected |
| | with the action, nor am I financially interested in the |
| 14 | action. |
| 15 | The foregoing certification of this transcript |
| | does not apply to any reproduction of the same by any |
| 16 | means unless under the direct control and/or direction of
the certifying reporter. |
| 17 | |
| | DATED this 25 day of February, |
| 18 | |
| 19 | |
| | |
| 20 | Judith F. Consor, Court Repo |
| | Florida Professional Reporter |
| 21 | |
| 22 | |
| 23 | |
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| 25 | |
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