EFTA00180294

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page88of100 
nsor & Associates 
Repartiag and Transcription. 
Page 62 
1 
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. 
IIIIIIIIr 
22 
Q. 
And what did 
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. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
11101311 
EFTA00180494

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 89 of 100 
*
nsor & Associates 
Roptviinft and Transcription. inc. 
Page 63 
1 
Q. 
Where were you when 
this 
2 
someone that you were not at the Quarterdeck Tavern? 
3 
A. 
Eating nachos. 
4 
Q. 
At the Quarterdeck Tavern? 
5 
A. 
Yes. 
6 
Q. 
What did you do so that IIIIIIrwould lie to 
7 
the process servers for you? 
8 
A. 
Nothing. 
9 
Q. 
You just got him to lie for you, didn't 
10 
you? 
11 
A. 
No. I had no influence on him saying I 
12 
wasn't there. 
13 
Q. 
He took that upon himself? 
14 
Isn't it true that Mr. Epstein's process 
15 
servers had to ask the police to get you out of the 
16 
restaurant so that they could serve you? 
17 
MR. LEOPOLD: Objection. Lack of 
18 
foundation, predicate. 
19 
BY MR. TEIN: 
20 
Q. 
You can answer the question. 
21 
MR. LEOPOLD: If you know. Don't guess. 
22 
THE WITNESS: No. Can you repeat the 
23 
question? 
24 
MR. TEIN: Don't coach. 
25 
MR. LEOPOLD: Don't guess. 
69 of 316 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180495

Case 9:08-cv-80804-KAM 
Do ment 1 
Entered on FLSD Docket 07/21/2008 
Page 90 of 100 
sor & Associates 
• 
Rooming sad Transcription. Mc 
Page 64 
1 
MR. TEIN: That's a coaching. 
2 
MR. LEOPOLD: No. That's an instruction to 
3 
the client. 
4 
MR. TEIN: No. You don't do that. 
5 
THE WITNESS: Can you repeat the question? 
6 
MR. LEOPOLD: Let me just state for the 
7 
record --
8 
BY MR. TEIN: 
9 
Q. 
Once the police 
isn't it true that 
10 
Mr. Epstein's process servers had to ask the police to 
11 
get you out of the restaurant so that they could serve 
12 
you? 
13 
A. 
Incorrect. My boss called the police. 
14 
Q. 
And once the police showed up, to stop you 
15 
from lying to avoid service, you made up another lie that 
16 
the process servers had harassed you. Isn't that 
17 
correct? 
18 
A. 
Incorrect. 
19 
Q. 
You lie all the time, don't you? 
20 
MR. LEOPOLD: Objection. 
21 
THE WITNESS: Incorrect. 
22 
BY MR. TEIN: 
23 
Q. 
You have a MySpace page, don't you? 
24 
A. 
No longer do I have a MySpace page. I 
25 
deleted it. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
90 of 116 
EFTA00180496

Case 9:08-cv-80804-KAM 
D 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 91 of 100 
nsor & Associates 
Reponms and Tranactipticm, Inc. 
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, 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Sulte 500 - West Palm Beach, FL 33401 
41 of 314 
EFTA00180497

12 01 316 
Case 9:08-cv-80804-KAM 
cument 1 
Entered on FLSD Docket 07/21/2008 
Page 92 of 100 
sor & Associates 
Itapnning.antl Transcripzion. Inc. 
1 
2 
3 
in a second. 
Page 66 
A. 
Nothing. 
O. 
Well, we're going to come back to MySpace 
4 
A. 
You do that. 
5 
Q. 
going to ask you some questions 
6 
abort 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 
13 
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. 
Oh, then no; just one. 
MR. LEOPOLD: Objection, argumentative. 
THE WITNESS: Incorrect. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180498

Case 9:08-cv-80804-KAM 
DQppJpent 1 
Entered on FLSD Docket 07/21/2008 
Page 93 of 100 
Q. 
A. 
nsor & Associates 
Rationing and Tratucliptiok Jae 
1 
2 
3 
Q. 
And where is the one body piercing? 
Belly. 
When did you get that? 
Page 67 
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. 
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, 
Okay. So you had that body piercing when 
15 
correct? 
16 
A. 
Incorrect. 
17 
Q. 
18 
never done that? 
Are you swearing under oath that you've 
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 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Paim Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
97 al 716 
EFTA00180499

Case 9:08-cv-80804-KAM 
D 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 94 of 100 
nsor & Associates 
Ropncting And Transcription. Inc. 
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 
Q. 
Let's go to Exhibit 33. 
17 
MS. BELONLAVEK: That's 33-001? 
18 
TEIN: Correct. 
19 
BY MR. TEIN: 
20 
O. 
On this page you lied to everyone that you 
21 
were 19, didn't you? 
22 
A. 
Incorrect. 
23 
MR. LEOPOLD: Just answer the question. 
24 
THE WITNESS: Oh, incorrect. 
25 
BY MR. TEIN: 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180500

Case 9:08-cv-80804-KAM 
D ument 1 
Entered on FLSD Docket 07/21/2008 
Page 95 of 100 
nsor & Associates 
Itcporthip and Transcription, Inc, 
Page 69 
1 
2 
3 
4 
5 
6 
7 
Q. 
Now you can explain your answer. 
A. 
I know that I have seen all of these and I 
know that this one is mine. 
Can you go down? 
MR. LEOPOLD: Just for the record, you're 
pointing to the photo. 
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 
Q. 
That's yours, right? 
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 
Q. 
So the one you pointed to where it says 
18 
your age is 18, that's yours, correct? 
19 
A. 
Correct. 
20 
Q. 
And when you wrote 18 as your age on your 
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? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
• 
of 310 
EFTA00180501

Case 9:08-cv-80804-KAM 
Doc ment 1 
Entered on FLSD Docket 07/21/2008 
Page96of100 
nsor & Associates 
Horn-mina and Tranactiptinn, Inc. 
r 
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 
IIIIIIIIIIppis 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 
tree 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. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
OS el 316 
EFTA00180502

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 97 of 100 
ik
nsor & Associates 
Reporting and Transulpeirxn, Inc. 
Page 71 
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. 
Oh --
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 
Q. 
Do you remember Detective Recarey? Did you 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
97 of 316 
EFTA00180503

Case 9:08-cv-80804-KAM 
D u ent 1 
Entered on FLSD Docket 07/21/2008 
Page 98 of 100 
on5or 
& Associates 
Reponinn and Transtri on en. Inc. 
1 
ever meet a Detective Recatey? 
2 
4 
5 
A. 
I don't know the names. 
Q• 
Page 72 
How many different detectives have you met 
with on this case from Palm Beach? 
A. 
Probably a good six or seven, maybe. 
6 
Q. 
Did one of the detectives tell you before 
7 
you testified in the Grand Jury that you should take your 
8 
MySpace age and put your true age? 
9 
A. 
No. 
10 
Q. 
Didn't Detective Recarey have to come to 
11 
your house to pick you up to get you to testify in front 
12 
of the Grand Jury? 
13 
A. 
Possibly; maybe because I didn't have a 
14 
ride; I was only 14 or 15 at the time. 
15 
Q. 
Your mom didn't drive you? 
16 
A. 
No. 
17 
Q. 
Stepmom didn't drive you? 
18 
A. 
I think my dad. Oh, my dad; my dad drove 
19 
me. 
20 
Q. 
Your dad drove you? 
21 
A. 
Yes, sir. 
22 
Q. 
So your testimony is Detective Recarey did 
23 
not drive you, correct? 
24 
MR. LEOPOLD: Objection. /asked and 
25 
answered. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
9101311 
EFTA00180504

Case 9:08-cv-80804-KAM 
D 
;pent 1 
Entered on FLSD Docket 07/21/2008 
Page 99 of 100 
nsor & Associates 
Reporting and Ttaniddplien. 
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 
Michelle Pagan three years ago, didn't you? 
24 
A. 
To my knowledge, no, I did not. 
25 
Q. 
Well, you lied to the police when you 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
»04 315 
EFTA00180505

Case 9:08-cv-80804-KAM 
D 
1 
Entered on FLSD Docket 07/21/2008 
Page 100of100 
Iiii
lentlsor & Associates 
homey dp And Transcription. Inc. 
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. gip 
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. I 
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. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
100 et 316 
EFTA00180506