EFTA00180294

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 68 of 100 
nsor & Associates 
Roponing and Transcripunn. lac 
Page 42 
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 IIIIII 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 Mend 
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 
i 
21 
saying that they were lying to the police about that? 
22 
A. 
No. But a question or -- questions from 
23 
like she asked me questions, but it wasn't 
24 
joking. She was kind of like in a happy way, like, "Oh, 
25 
what did you do? What did you do?" Like those kind of 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
SI 01310 
EFTA00180474

Case 9:08-cv-80804-KAM 
Do ument 1 
Entered on FLSD Docket 07/21/2008 
Page 69 of 100 
nsor & Associates 
Roponimp and Transcription, inc. 
Page 43 
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 
A. 
No. That's what Lold 
me. 
7 
Q. 
You didn't tell that to 
8 
MR. LEOPOLD: Objection. Asked and 
9 
answered. 
10 
THE WITNESS: No. 
11 
BY MR. TEIN: 
12 
Q. 
After you left Epstein's house you took the 
13 
money and you went shopping with IIIIIIrand the other 
14 
girl in the car, correct? 
15 
A. 
Incorrect. I didn't spend any of the 
16 
money. 
17 
Q. 
You went to Marshall's, didn't you? 
18 
A. 
I went along, yes, but I didn't --
19 
Q. 
You went shopping with them at Marshall's, 
20 
didn't you? 
21 
MR. LEOPOLD: Objection. 
22 
THE WITNESS: I guess you could say that. 
23 
MR. LEOPOLD: Objection. Lack of predicate 
24 
and foundation. Mischaracterization of earlier 
25 
testimony. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
$9 of 318 
EFTA00180475

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 70 of 100 
nsor & Associates 
Itoponing sad Tranicriphon. 
Page 44 
1 
BY MR. TEIN: 
2 
Q. 
And IIIIIIrbought 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 
0. 
Tell me about when the federal prosecutors 
11 
spcke 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 
Q. 
Do you know who Marie Villafona is? 
15 
A. 
No, sir. 
16 
Q. 
Did you ever meet with any federal 
17 
prosecutors? 
18 
A. 
I think -- yeah. I think they were 
I 
19 
think they were like FBI. 
20 
Q. 
Uh-huh. Did you meet with federal 
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? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
70 of 314 
EFTA00180476

Case 9:08-cv-80804-KAM 
ent 1 
EnteredonFLSD.Docket07/21/2008 
Page 71 of 100 
nsor 7 Associates 
Repnnin8 and Traµeripkinn. Jae. 
Page 45 
1 
2 
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 
5 
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? 
A. 
It was not this year, no. 
Q. 
Was it 2007? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
71 of 716 
EFTA00180477

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 72 of 100 
nsor & Associates 
koportnis and Transcliption, Inc. 
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 Marie 
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 
A. 
No, sir. 
16 
Q. 
Do you know who Jeffrey Herman is? 
17 
A. 
Yes. 
18 
Q. 
That's the lawyer who first sued Epstein on 
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 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
72 of 316 
EFTA00180478

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 Page 73 of 100 
nsor & Associates 
RoflartnIS nwd Transcciptinn. Inc. 
Page 47 
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 
Q. 
Does it refresh your recollection that he's 
14 
the number two prosecutor at the U.S. Attorney's Office? 
15 
A. 
No. 
16 
Q. 
That he's Marie Villafona's boss? 
17 
A. 
No. 
18 
Q. 
Does it refresh your memory that he's the 
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 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
73 orate 
EFTA00180479

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 74 of 100 
nsor & Associates 
ReparlillS and 1.71111Gliptill11. Inc. 
Page 48 
1 
Florida Bar? 
2 
A. 
I did not select him. 
3 
Q. 
Who did? 
4 
A. 
My father. 
5 
6 
7 
8 
with him. Where did you meet him? 
9 
10 
friend's house. 
11 
12 
13 
14 
Tavern? 
15 
16 
17 
18 
19 
20 
21 
22 
MR. LEOPOLD: Objection. That calls for 
23 
attorney/client privilege. 
24 
BY MR. TEIN: 
25 
Q. 
What discussions did you have with 
Q. 
Did you ever meet Mr. Herman? 
A. 
Once. 
O. 
Don't -- don't tell me what you discussed 
A. 
I was shopping in my -- he showed up at my 
Q. 
Whose house? 
A. 
My friend 
Q. 
Is that 
from the Quarterdeck 
A. 
Yes. 
Q. 
And did you have a meeting with him at 
house? 
A. 
Yes. I guess you could say that. 
Q. 
And who else was there? 
A. 
My Aunts 
Q. 
And what was that meeting about? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
74 0316 
EFTA00180480

Case 9:08-cv-80804-KAM 
Ltq 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 75 of 100 
nsor & Associates 
Reportinm tend Transctipttno, Inc. 
1 
Mr. Herman in the presence of IIIIIIIIIIII. 
2 
A. 
None. 
3 
Q. 
What discussions did you have in the 
4 
presence of her aunt? 
5 
A. 
Of my aunt? 
Page 49 
6 
MR. GOLDBERGER: It's the witness's aunt. 
7 
BY MR. TEIN: 
8 
Q. 
Oh, 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 NMI 
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. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
76 o1316 
EFTA00180481

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 76 of 100 
nsor & Associates 
Repo:Tins and Transcripook 
Page 50 
1 
Q. 
Why did the meeting take place at 
2 
IIIIIIIhouse? 
3 
A. 
I spent the night that night at her house. 
4 
Q. 
And when was this? 
5 
A. 
A while ago. 
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 
Q. 
So was it before of after Mr. Herman filed 
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 
A. 
I don't know. 
16 
Q. 
Did Ms. Kurkendall speak to you about 
17 
getting reimbursed from Mr. Epstein? 
18 
A. 
I've never had a discussion with anyone 
19 
about getting reimbursed from Mr. Epstein. 
20 
Q. 
Have you met with an agent named Jason 
21 
Richards? 
22 
A. 
Not to my knowledge. 
23 
Q. 
How about an agent named Tim Slater? 
24 
A. 
No, sir. 
25 
O. 
How about an agent named Junior Ortiz? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
71 of 316 
EFTA00180482

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 77 of 100 
nsor & Associates 
Ronannit and Transcription. Inc. 
1 
2 
3 
4 
A. 
No. 
Q. 
Page 5] 
And we've learned that many of the girls, 
some of whom are as old as 23, were told by the 
government that they would get money at the end of the 
5 
criminal prosecution. Does that sound familiar to you?' 
6 
A. 
No, sir. 
7 
Q. 
Other than Mr. Leopold here -- I'm not 
8 
asking about Mr. Herman either 
9 
A. 
Uh-huh. 
10 
Q. 
-- did anyone ever discuss with you that 
11 
yot could get reimbursement for your damages? 
12 
A. 
No, sir. 
13 
Q. 
Did you or any member --
14 
MR. LEOPOLD: Are you referring to a 
15 
criminal matter or a civil matter? 
16 
BY MR. TEIN: 
17 
Q. 
Did you or any member --
18 
MR. LEOPOLD: Excuse me. Let me object to 
19 
the form of the question. 
20 
BY MR. TEIN: 
21 
Q. 
Did you or any member of your family ever 
22 
get a victim notification letter from anyone? 
23 
A. 
I no longer live at that residence and I 
24 
wouldn't know. 
25 
Q. 
So your testimony is that you have never 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
77 ofS10 
EFTA00180483

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 78 of 100 
sor & Associates 
RopningmtdiummtirimAnc 
Page 52 
1 
rimapived a victim notification letter, correct? 
2 
rect. 
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 
A. 
What do you mean by evidence? 
10 
Q. 
Well. Anything that you can touch or feel. 
11 
A. 
No. 
12 
MR. LEOPOLD: Objection to the form of the 
13 
question. 
14 
BY MR. TEIN: 
15 
O. 
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 
A. 
My cell phone four years ago or three years 
20 
ago, but that's it. 
21 
Q. 
You gave your cell phone to whom? 
22 
A. 
Michelle Pagan. 
23 
Q. 
Did she keep it? 
24 
A. 
Ask her. 
25 
Q. 
You gave it to her and then you didn't get 
••••••••••••••••••••••• owe... 
Wei 0••••••••...••• W....MS 
WIN IMP •••••••• 
7$ e1310 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180484

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 79 of 100 
nsor & Associates 
Repot-tong and Transcriptim,1m. 
• 
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? 
79 ol 315 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180485

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 80 of 100 
nsor & Associates 
Roporting and TramscrIptton, Inc 
Oa of 31$ 
1 
2 
Page 54 
A. 
No, sir. 
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. 
70 
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 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180486

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 81 of 100 
sor & Associates 
ROIICII1IIIR and .4•1110tiriP31. Inc. 
Page 55 
1 
 
CERTIFIED QUESTION 
2 
BY MR. TEIN: 
3 
Q. 
You asked your co-workers --
4 
MR. LEOPOLD: It's vague and ambiguous. 
5 
BY MR. TEIN: 
6 
Q. 
You asked your co-workers at the 
7 
Quz.rterdeck Tavern to lie for you, didn't you? 
8 
A. 
No. I informed my boss about what was 
9 
going on and he told me that he would help in any way 
10 
that he can. 
11 
Q. 
Okay. You got your friendillillyto lie 
12 
by switching name tags with you, correct? 
13 
A. 
Incorrect. It was a coincidence that same 
14 
night she was not wearing her name tag; she was wearing 
15 
mine. But I was also not wearing -- I was wearing my 
16 
name tag. Everyone switches name tags. It just so 
17 
happens it was a coincidence that same night the people 
18 
came with the papers. 
19 
MR. TEIN: Will you put up Exhibit 18-001? 
20 
MR. GOLDBERGER: And mark 18-001 for 
21 
identification purposes to this deposition. 
22 
MR. LEOPOLD: None of them have been marked 
23 
yet. Can we mark them and put them as attachment 
24 
to the depositions? Because I think you've shown 
25 
three photos now. And this is the only one that 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
It e1316 
EFTA00180487

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 82 of 100 
4 
sor & Associates 
Ropnning and Transcription. Inc. 
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 
Q. 
Ilia I've put a photograph marked 18-001 
18 
up on the screen. Do you see that? 
19 
A. 
Yup. 
20 
Q. 
Who is that in the photo? 
21 
A. 
lill'IlLon the left and me on the right. 
22 
Q. llat 
right? 
23 
A. 
Yes. 
24 
Q. 
a 
your friend at the 
25 
Quarterdeck Tavern, right? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
III al 314 
EFTA00180488

8301310 
Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 83 of 100 
4nsor & Associates 
Repononm nni Transcriptinet, Inc. 
Page 57 
1 
A. 
Yes. 
2 
Q. IIIIIIIIIryour friend, who you say the day 
3 
that the process servers went to serve you with a 
4 
subpoena for this deposition, just happened -- just by 
5 
coincidence, was wearing your name tag? 
6 
7 
8 
9 
10 
11 
12 
13 
14 
going to be served with a subpoena, correct? 
15 
16 
17 
18 
19 
BY MR. TEIN: 
20 
Q. 
21 
going to be -- you thought you were being served with a 
22 
subpoena, correct? 
23 
24 
Q. 
25 
name tags with 
that the process servers were 
A. 
Yes, sir. 
Q. 
And just by coincidence, you were wearing 
her name tag, correct? 
A. 
Yes. 
Q. 
Your testimony under oath is that's just a 
coincidence, right? 
A. 
Total honesty. 
O. 
It just happens to be the day that you were 
A. 
That wasn't the first day that --
MR. LEOPOLD: 
just answer the 
question. It calls for a yes or no. 
THE WITNESS: Yes. 
You said that wasn't the first day you were 
A. 
Correct. 
You knew before the day that you switched 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180489

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 84 of 100 
nsor & Associates 
Reporunp and Iransocirniac, 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 :dee 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. 
Ph. 561.682.0905 - Fax. 561.682.1771 
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&I of 31$ 
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Case 9:08-cv-80804-KAM 
Document 1 
5501015 
Entered on FLSD Docket 07/21/2008 
Page 85 of 100 
nsor & Associates 
RI:TOMAS and TraniCrirRion, 
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Page 59 
MR. LEOPOLD: I'll certify it. 
 
CERTIFIED QUESTION 
She's answered that question. She's explained it five 
tines already. The fact that Counsel doesn't like the 
answer, that's a different query. 
MR. TEIN: Stop making speaking objections. 
MR. LEOPOLD: I'm not. I'm not going to 
put up with it, because it's in appropriate, Jack, 
and you know it. I will not allow Counsel to 
berate a witness, whether it's in a criminal case 
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 
proper. 
MR. GOLDBERGER: Okay. 
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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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180491

Case 9:08-cv-80804-KAM 
Document 1 
34 01311 
Entered on FLSD Docket 07/21/2008 
Page 86 of 100 
nsor & Associates 
Reporting and TranceIption, inc 
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Page 60 
to interrupt you. 
MR. GOLDBERGER: Just requires us to say we 
like the answer to that question. And it's not 
you and I or you and Mr. Tein who are testifying 
here. It's the witness. 
MR. LEOPOLD: Fine. But after the sixth 
time of asking the same question and then coming 
back and pointing a finger at her and saying, 
"You're a liar" --
MR. TEIN: That didn't happen. 
MR. LEOPOLD: That's fine. But I'm not 
going to allow her to answer that question, 
because she's answered that same question and has 
explained it. 
Now Counsel might be sitting there rubbing 
his head with a migraine. That's his problem. 
But if he can't ask a question appropriately in a 
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 
that? 
MR. TEIN: Ted --
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EFTA00180492

IT or 3i6 
Case 9:08-cv-80804-KAM 
ument 1 
Entered on FLSD Docket 07/21/2008 
Page 87 of 100 
nsor & Associates 
Repartins and Transolipum. 
Page 61 
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MR. LEOPOLD: This is really big stuff that 
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you're going through. But that's fine; just ask 
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your question and move on. But do it one time. 
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If you don't understand it, I'll let you follow 
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up, but I'm not going to allow you to ask the same 
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question time and again and then call her a liar. 
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Just ask the question, get the answer and move to 
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the next subject matter. 
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MR. TEIN: Ted, I'm sitting right across 
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the table from you. 
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MR. LEOPOLD: Yes, sir. 
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MR. TEIN: Please be quiet. Don't yell. 
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MR. LEOPOLD: I will not be quiet. 
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MR. TEIN: Stop yelling. 
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MR. LEOPOLD: Lewis, when I'm yelling 
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you'll know it. I will not --
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MR. TEIN: my name is not Lewis. 
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MR. LEOPOLD: I thought your first name was 
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Lewis, Mr. Tein. 
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MR. TEIN: You watched me for three days at 
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the evidentiary hearing where you sat in the back 
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of the courtroom. You should know who I am. 
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MR. LEOPOLD: Well, that's the impression 
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you must have made in the courtroom. 
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I will not be quiet. 
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EFTA00180493