EFTA00180294

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 48 of 100 
nsor & Associates 
RoponinR wd Tunic6-0m, Inc. 
Page 22 
1 
Q. 
You wrote that to your friend, didn't you? 
2 
MR. LEOPOLD: Objection. Asked and 
3 
answered, for the fourth time. 
4 
MR. TEIN: You are improperly objecting, 
5 
Mr. Leopold. You have no grounds to object. And 
6 
that's not an objection. 
7 
MR. LEOPOLD: It is an objection. 
8 
MR. TEIN: Then terminate the deposition if 
9 
you think it's been asked and answered. 
10 
MR. LEOPOLD: Counsel, I am not precluded 
11 
from just making an objection to the form of the 
12 
question. As the courts well know, and if you 
13 
practice here in West Palm Beach, many of the 
14 
judges require you to set the objection with 
15 
specificity. And I will do that. And if you 
16 
don't want me to, you can make the record. But I 
17 
will do that. 
18 
MR. TEIN: Here's what we'll do, Ted. You 
19 
can 
will allow you to reserve an objection to 
20 
form for every single one of my questions. 
21 
Otherwise, all you're doing is obstructing. 
22 
MR. LEOPOLD: I won't do that. 
23 
MR. TEIN: Of course; because you want to 
24 
obstruct. 
25 
MR. LEOPOLD: All right. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4801316 
EFTA00180454

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page49of100 
nsor & Associates 
Roportin9 and Tranicrip:inn, Inc. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
Page 23 
BY MR. TEIN: 
WS
Q. 
you think that giving testimony 
today, under oath, is bull s-h-i-t, don't you? 
A. 
No. 
O. 
And you wrote that to your friend on 
MySpace last week, didn't you? 
MR. LEOPOLD: Objection. Asked and 
answered. 
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 
Q. 
15 
stcpid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 
1 6 
you. write that? 
17 
A. 
Yes. 
18 
Q. 
Referring to this deposition, didn't you? 
19 
A. 
Referring to the court. I was later 
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 
Q. 
When the police interviewed you one month 
You wrote in this exhibit, "I got some 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
49 c43111 
EFTA00180455

Case 9:08-cv-80804-KAM 
Dq ppient 1 
Entered on FLSD Docket 07/21/2008 Page 50 of 100 
nsor & Associates 
koponitip and 'transcription. Inc. 
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, illp? 
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? 
16 
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 
illillipas 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? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
60 of 314 
EFTA00180456

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 51 of 100 
nsor & Associates 
Ropaning and T:ansctipana, lac 
. Page 25 
1 
2 
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 
never sent you a message over the Internet about 
8 
sexual activity with Epstein, did she? 
9 
A. 
No. 
.10 
Q. 
Did 
ever try to convince you to 
11 
engage in any sexual activity with Epstein? 
12 
A. 
No. 
13 
Q. 
Did 
every try to convince 
14 
you to engage in any sexual activity with Epstein? 
15 
A. 
I don't know who 
is. 
16 
Q. 
Do you have a friend IIIIIII? 
17 
A. 
No. 
18 
Q. 
Okay. Before you went so Epstein's house 
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 
A. 
No. 
A. 
Yes. 
Q. 
Before you got to Epstein's house INS 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
SI o1311 
EFTA00180457

Case 9:08-cv-80804-KAM 
ent 1 
EnteredonFLS,DDocket07/21/2008 
Page 52 of 100 
nsor & Associates 
Repartour and Tunscripien, 
Page 26 
1 
O. 
You're sure that -- let me ask the question 
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 
Q. 
He's coaching you now. So I'm going to ask 
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 
MR. LEOPOLD: Counsel --
21 
MR. TEIN: Stop coaching the witness. 
22 
BY MR. TEIN: 
23 
Q• 
Millet 
me ask you --
24 
MR. LEOPOLD: If you continue to 
25 
MR. TEIN: Stop interrupting my questions. 
Ph. 561.682.0905 - Fax. 561.682.1771 . 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
IS2 a314 
EFTA00180458

Case 9:08-cv-80804-KAM 
q 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 53 of 100 
nsor & Associates 
Reporting and Transcription, lnc 
1 
2 
3 
BY MR. TEIN: 
4 
O. 
S 
Page 27 
MR. LEOPOLD: If you do it one more time, 
we're leaving. 
S 
MR. LEOPOLD: I'm going to make the record. 
6 
You cannot interrupt me when I'm making the 
7 
record. Out of professional conduct, you cannot 
8 
do that. I'm entitled to make the record. I made 
9 
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 
12 
professional manner, and ask the question and once 
13 
you get the answer, to either follow up on it or 
14 
move on, but not continuously browbeat and ask the 
15 
same question over and over because you don't like 
16 
the answer. 
17 
MR. TEIN: Calm down, sir. 
18 
MR. LEOPOLD: Trust me, I'm very calm here. 
19 
When I'm not calm, you'll know it. I'm very calm. 
20 
So please continue on. But I will not 
21 
allow you to continue to harass her in the 
22 
demeanor that you're doing. Ask her a question 
23 
and move on. 
24 
MR. TEIN: Are you done? 
25 
MR. LEOPOLD: Thank you. 1 am. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
63 o1311 
EFTA00180459

Case9:08-cv-80804-KAM 
q 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 54 of 100 
nsor & Associates 
flepaninp. and Transcriplim. 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 
MR. LEOPOLD: I think the record is very 
7 
clear. 
8 
MR. GOLDBERGER: Let me just clarify 
9 
something. When you object to the form of a 
10 
question, you're not instructing the witness not 
11 
to answer the question, are you? 
12 
MR. LEOPOLD: No. And I'm not making that 
13 
objection; only on attorney/client privilege. 
14 
MR. TEIN: Will you stop speaking now so I 
15 
can ask my question? Are you done? 
16 
Okay. I'm going to ask my question. 
17 
BY MR. TEIN: 
18 
Q. 
Listen, Mr
-
19 
MR. LEOPOLD: Hold on. Stop. 
20 
I've been doing this for 20 plus years and 
21 
have met a lot of attorneys, but I've never had an 
22 
experience like this where I've --
23 
MR. TEIN: Stop your speeches. 
24 
MR. LEOPOLD: If you continue to do this, 
25 
whether it's with me or with my client, I will not 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
64°133 
EFTA00180460

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 55 of 100 
nsor & Associates 
Reporting and Tianicriptioo. Inc 
Page 29 
1 
2 
3 
Mr. Goldberger knows all this, because I know that 
4 
he wouldn't do this. So I will not put up with 
5 
it. And I think it's highly inappropriate to do 
6 
this with this child sitting here, the way you're 
7 
acting, primarily towards me, and I will not put 
8 
up with it. 
9 
MR. TEIN: Will you please stop your speech 
10 
so I can ask questions? 
11 
12 
professionally, I will do so. But if you continue 
13 
to do it this way, I will leave. 
14 
15 
BY MR. TEIN: 
16 
Q. 
are you sure that before you got to 
17 
Epstein's house no one tried to persuade you to engage in 
18 
sexual activity with Epstein for money? 
19 
MR. LEOPOLD: Asked and answered. 
20 
Objection. 
21 
MR. TEIN: Did you get her answer? 
22 
23 
24 
BY MR. TEIN: 
25 
Q. 
Let me ask you a few questions about your 
put up with it and I don't need to put up with it 
and it's not appropriate. And I'm sure 
MR. LEOPOLD: So long as you act 
MR. TEIN: Suit yourself. 
THE COURT REPORTER: No, I did not. 
THE WITNESS: I'm sure. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
5,5 el 311 
EFTA00180461

6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Case 9:08-cv-80804-KAM 
q 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 56 of 100 
nsor & Associates 
Ropaniag mid Transcopuce.. Inc. 
Page 30 
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? 
A. 
No. 
Q. 
Jeff never chatted in a chat room with you, 
did he? 
A. 
No. 
Q. 
Before you got to Epstein's house you had 
never spoken to Jeff, had you? 
A. 
No. 
Q. 
And before you got to Epstein's house you 
had never met Jeff? 
A. 
Correct. 
Q. 
Before you got to Epstein's house you had 
never told Jeff that you were under 18, right? 
A. 
No. 
Q. 
Before you got to Epstein's house had you 
ever told Jeffrey that you were under 18? 
A. 
No. I never spoke to the man before that. 
Q. 
And you only went to Jeff Epstein's house 
that one time three years ago, correct? 
A. 
Yes. 
Q. 
You never went there again, correct? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
Hof 314 
EFTA00180462

Case 9:08-cv-80804-KAM Dffnent 1 
Entered on FLSD Docket 07/21/2008 
Page 57 of 100 
nsor & Associates 
Rep-mina and Tnia.scririon, Inc. 
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. 
11. 
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 
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. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
57 of 315 
EFTA00180463

Case 9:08-cv-80804-KAM 
D 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 58 of 100 
nsor & Associates 
floportinE anal Transcri inion. inc. 
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 
5 
A. 
Correct. 
6 
Q. 
You told the police that you didn't 
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 Illilwho told you to lie about 
15 
your age to Jeff Epstein? 
16 
A. 
Yes, sir. 
17 
Q. 
And 
told you that if you weren't 18, 
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 
to Epstein's you had no idea 
24 
out how old you were, right? 
25 
A. 
Excuse me? 
who she was, right? 
know 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
5401311 
EFTA00180464

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 59 of 100 
nsor & Associates 
Roponinp aid Transciiptim. inc. 
Page 33 
1 
Q. 
When you first met Jeff he tried to find 
2 
out how old you were, right? 
3 
A. 
Not when we first introduced each other; 
4 
when we get upstairs, then, yes. 
5 
Q. 
During the massage Jeff asked you how old 
6 
you were, correct? 
7 
A. 
Yes, yes. 
8 
Q. 
Now hadn't you already told Jeff's 
9 
ass:.stant, 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. 
22 
Q. 
Do you want to rethink that answer? 
13 
MR. LEOPOLD: Is that a question? 
14 
BY MR. TEIN: 
15 
Q. 
Do you want to rethink that answer? 
16 
A. 
No. I didn't really speak with her that 
17 
much. 
18 
Q. 
Do you want to try to refresh your memory 
29 
on that? 
20 
MR. LEOPOLD: Do you have something to 
21 
refresh her memory with? 
22 
MR. TEIN: Do you want to stop making 
23 
speaking objections? 
24 
MR. LEOPOLD: No. But to refresh someone's 
25 
memory, you show them a document. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6901310 
EFTA00180465

Case 9:08-cv-80804-KAM 
D • 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 60 of 100 
li
nsor & Associates 
Reporting IS lransoliption, lac. 
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. Please 
8 
stop. 
9 
MR. LEOPOLD: I'm not obstructing. But if 
10 
you want to refresh her recollection, you need to 
11 
show her something. 
12 
That's not a proper question. I object to 
13 
the foundation and the predicate of that question. 
14 
MR. TEIN: Are you done? 
15 
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: 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
60{4316 
EFTA00180466

Case 9:08-cv-80804-KAM 
Q• 
A. 
ent 1 
terpdonFLS,DIQocket07/21/2008 Page 61 of 100 
nsor 
Associates 
etnionins and Transoipti on, Inc 
1 
2 
3 
4 
Q• 
Page 35 
You can answer the question. 
Sure. 
Is there anything that would refresh your 
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 
Q. 
So you told Jeff that you were 18 years 
12 
old, correct? 
13 
A. 
Yes. 
14 
Q. 
Do you remember Detective Michelle 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 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
61 a 016 
EFTA00180467

Case 9:08-cv-80804-KAM 
4ggiypent 1 
Entered on FLSD Docket 07/21/2008 
Page 62 of 100 
nsor & Associates 
Ram-ging and Transceiniaa, 
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 
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 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
12 of 11111 
EFTA00180468

Case 9:08-cv-80804-KAM 
Qpgkynent 1 
Entered on FLSD Docket 07/21/2008 
Page 63 of 100 
nsor & Associates 
Etc porn 6E food irSIUGlip:111O. 
Page 37 
1 
BY MR. TEIN: 
2 
0. 
Let me put it again. 
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 
O. 
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 
Q. 
You wanted Mr. Epstein to believe that you 
19 
really were 18, right? 
20 
A. 
Correct. 
21 
O. 
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? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
63 of 316 
EFTA00180469

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 64 of 100 
41
nsor & Associates 
Repanang and Transcdpdan, lac 
Page 38 
1 
A. 
Yes. 
2 
Q. 
Was that the truth? 
3 
A. 
No. 
4 
Q. 
In fact, you went to Royal Palm, right? 
5 
A. 
Yes. 
6 
Q. 
So you lied to Mr. Epstein again, correct? 
7 
A. 
Yes. 
8 
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 
assumption. She just answered you she can't tell 
16 
you that. 
17 
MR. TEIN: Speaking objection. And you 
18 
well know that, Mr. Leopold. 
19 
MR. LEOPOLD: She can't answer that 
20 
question. The way you phrased that question, 
21 
you're purposely making her not be honest in her 
22 
testimony. She can't answer a question like that. 
23 
She doesn't remember. So then you say, "So you 
24 
were lying." That's improper and you know that. 
25 
That's not a proper question. And any attorney 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
64 col 316 
EFTA00180470

Case 9:08-cv-80804-KAM 
D 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 65 of 100 
sor & Associates 
Repartin8 *ad '4.nm:rip:Huh inc.
Page 39 
1 
that would do that to a witnesses or to a person 
2 
that's sitting in this chair is not acting 
3 
professionally. You can't ask a question like 
4 
that. You can do it, but it's not proper. And 
5 
I'm sure you weren't trained that way, certainly 
6 
not ethically. 
7 
MR. TEIN: Will you stop? 
8 
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. 
Ms. 
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. 
Ms. 
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 
MR. LEOPOLD: Objection. Foundation, 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
OS of 311I 
EFTA00180471

Case 9:08-cv-80804-KAM 
ent 1 
EifiteredonFL$Dflocket07/21/2008 
Page 66 of 100 
nsor & Associates 
Ropnni An and Transcriptnet, Inc. 
Page 40 
1 
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 
you: hand, did he? 
13 
A. 
No. 
14 
Q. 
Mr. Epstein never tried to put your hand 
15 
anywhere, did he? 
16 
A. 
No. 
17 
Q. 
At no time did you touch Mr. Epstein's 
18 
penis, did you? 
A. 
No. 
20 
Q. 
And he did not touch you, correct? 
21 
A. 
Incorrect. 
22 
Q. 
Well, you told the police, "At no time did 
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. 
predicate. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
664:4316 
EFTA00180472

Case 9:08-cv-80804-KAM 
Qppyylient 1 
Entered on FLSD Docket 07/21/2008 
Page 67 of 100 
nsor & Associates 
Reporting end llamaIntim. Inc. 
Q. 
1.
Page 41 
1 
2 
Michelle Pagan that "at no time did he touch me." Didn't 
3 
you say that to the police? 
4 
A. 
Yeah. 
5 
Q. 
And you're saying that that was not fully 
6 
truthful. Is that what you're saying now? 
You told the police twice when you spoke to 
7 
A. 
Correct. 
8 
Q. 
And you're saying if you're not fully 
9 
trtthful, that's not a lie. Correct? 
10 
A. 
You took that out of context like really 
11 
bac. I didn't mean like that. Touching my legs and 
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 
Q. 
Did you tell the police that he did not 
19 
touch you, yes or no? 
20 
A. 
It's a possibility, but I do not remember. 
21 
Q. 
Okay. And you did not have any type of sex 
22 
with Jeff, correct? 
23 
A. 
No. 
24 
Q. 
And you did not have any type of oral sex 
25 
with Jeff, correct? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
ST o1616 
EFTA00180473