EFTA00230786

Case 9:08-cv-80804-KAM 
D 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 94 of 100 
nsor & Associates 
Ropnruifi and Itamictspan. 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. 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 
MR. LEOPOLD: Just answer the question. 
24 
THE WITNESS: Oh, incorrect. 
25 
BY MR. TEIN: 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
94 x1016 
EFTA00231106

Case 9:08-cv-80804-KAM 
D ument 1 
Entered on FLSD Docket 07/21/2008 
Page 95 of 100 
* 
nsor & Associates 
Reparunp an, Transctipturi, Inc. 
Page 69 
1 
Q. 
Now you can explain your answer. 
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 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
9501311 
EFTA00231107

Case 9:08-cv-80804-KAM 
Doc rnent 1 
Entered on FLSD Docket 07/21/2008 
Page 96 of 100 
nsor & Associates 
Rertnni kg and Transcti pm. Inc 
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 
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. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
911.1311 
EFTA00231108

Case 9:08-cv-80804-KAM 
D 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 97 of 100 
sor & Associates 
koporunp, and Transcription, Jet. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
15 
16 
17 
18 
19 
20 
21 
22 
Page 71 
THE WITNESS: I don't know which MySpace 
you're talking about. 
BY MR. TEIN: 
Q. 
The MySpace page that you're just pointing 
to, where it says you were 18. 
A. 
Yes. 
Q. 
And you were lying about your age, right? 
A. 
Uh-huh. 
Q. 
Why did you finally post your true age on 
your MySpace profile --
A. 
Uh 
4. 
-- four days before you were scheduled to 
testify before the Grand Jury? 
A. 
I honestly don't know which MySpace, 
because I've had like a bazillion MySpaces, and in that 
year, I had two, that one and another one, and that one's 
been deleted. So I don't know which one you're referring 
to. 
Q. 
You remember that you changed your age on 
your MySpace page from 18 to your true age just four days 
before you went and testified in the Grand Jury? 
A. 
No. 
23 
Q. 
You don't remember that. 
24 
A. 
No. 
25 
Q. 
Do you remember Detective 
Did you 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
Sr el 316 
EFTA00231109

Case 9:08-cv-80804-KAM 
D . ent 1 
Entered on FLSD Docket 07/21/2008 
Page 98 of 100 
sor & Associates 
Rerynrtilil and Tranactiptioc. lac. 
Page 72 
1 
ever meet a Detective 
2 
A. 
I don't know the names. 
Q. 
How many different detectives have you met 
4 
with on this case from Palm Beach? 
5 
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 
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 
did 
23 
not drive you, correct? 
24 
MR. LEOPOLD: Objection. /asked and 
25 
answered. 
4..AP 
•••• t• 
• 
• 
• 
• • 
• • 
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• • 
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• 
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Is •••• IMO. 
61 • • •••••••• 
Ph. 
Fax. 
1655 Palm Beach Lakts Blvd., Suite 500 - West Palm Beach, FL 33401 
1 
MOHO 
EFTA00231110

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 99 of 100 
sor & Associates 
Ramming and Transcription. 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 
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 
A. l•-•.•140, 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
Ili el 314 
EFTA00231111

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 100 of 100 
ii 
i liii 
• 
sor & Associates 
Ronarnnp and Transcription .1nc 
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. 
a 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
100 of 31$ 
EFTA00231112

-111%19d SUi--NoN n'd9S 
Q1 N10111 S,Nalcdg 
EFTA00231113

JUN-26-2009 FRI 02:28 P11 
FAX NO. 5618358691 
P. 01 
Date: 6/26/09 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
ATTORNEY AT LAW 
SUITE 1400 
250 AUSTRALIAN AVENUE SOUTH 
WEST PALM BEACH, FLORIDA 33401-5086 
TELEPHONE 
FAX 
FAX COVER SHEET 
To: 
R. Alexander Acosta, Esq. USAO 
Barbara Burns, Esq. ASAO 
Bradley J. Edwards, Fsq. 
William J. Berger, Esq. 
Robert D. Critton, Esq. 
Spencer T. Kuvin, Esq. 
Subject: State of Florida v. Epstein 
Pages: 3 , including this cover sheet. 
See attached letter. 
ORIGINAL WILL BE SENT: 
YES 
X 
NO 
IF THERE ARE ANY PROBLEMS WITH 
THE TRANSMISSION, PLEASE CONTACT 
AS SOON AS POSSIBLE.
The information contained In this facsimile message is attorney privileged and confidential information intended 
only for the use of the individual or entity named above. If the reader of this message is not the intended 
recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly 
prohibited. If you have received this communication in error, please immediately notify us by telephone. Thank 
you. 
EFTA00231114

FAX NO. 661E95?691 
JOSEPH R.ATTERBURY 
JACK &GOLDBERGER 
JASON S.WEISS 
Boani Conine Cflotooltial A, torney 
flembor of Now Jeray R Fleyala Bars 
June 26, 2009 
TELECOPIED THIS DATE 
The Honorable Jeffrey Colbath 
Palm Beach County Courthouse 
205 N. Dixie Highway 
Room 11F 
West Palm Beach, FL 33401 
Re; 
State of Florida v. Jeffrey Epstein 
Dear Judge Colbath: 
On behalf of Mr. Epstein, we strongly object to the proposed order submitted by 
Deanna Shullman on behalf of the Palm Beach Post. The court has already entered an 
order dated June 25, 2009 on: 
a) 
Non-party, M.'s Motion to Vacate Order Sealing Records and Unseal 
Records 
b) 
Palm Beach Post's Motions to Intervene and petition for Access 
c) 
Motions to Intervene and for an order to Unseal Records 
d) 
Jeffrey Epstein's Motion to Make Court Records Confidential. 
The only matter before the court today was Defendant Epstein's Motion for a 
Stay which the court denied. Contrary to the assertions in the proposed order submitted 
to you by the Palm Beach Post, the court made a specific finding-that the Defendant 
-Epstein-has met his burden of Irreparable harm. Additionally, all of the other matters 
contained in the proposed order were addressed in the court's Order of June 25, 2009. 
It is the position of Defendant Epstein that the order on today's Motion to Stay 
should simply state that the Defendant's Motion to Stay is denied. In this way, the 
court's order of June 25, 2009 on the merits of the issue and the order of the court 
One Clearlake Centre, Suite 1400 
250 Australian Avenue South 
WaSt Palm Reach. FL. 33401 
P 
f 
www.agwpa.com 
EFTA00231115

P. 03 
JUN-26-2009 FRI 02:28 Ptt 
The Honorable Jeffrey Colbath 
June 26, 2009 
Page 2 
FAX NO. 5618358691 
denying the stay motion can properly be reviewed by the Fourth District Court of 
Appeal. 
Very truly yqurs, 
ACK A. GOLDBERGER 
JAG:cg 
cc: 
U.S. Attorney's Office (via facsimile) 
State Attorney's Office(via facsimile) 
Deanna K. Shullman, Esquire (via facsimile) 
Bradley J. Edwards, Esquire (via facsimile) 
Spencer t. Kuvin, Esquire (via facsimile) 
EFTA00231116

day of June, 2009. 
IN THE CIRCUIT COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN AND FOR PALM BEACH 
COUNTY, FLORIDA 
CRIMINAL DIVISION "W" 
CASE NO. 502008CF009381AXXMB 
502006CF009454AXXMB 
STATE OF FLORIDA, 
vs. 
JEFFREY EPSTEIN, 
Defendant 
ORDER DENYING MOTION TO STAY DISCLOSURE AGREEMENT 
THIS MATTER came before the Court at a hearing on June 26, 2009, on Jeffrey 
Epstein's Motion to Stay the Disclosure of the Non-Prosecution Agreement and the Addendum 
thereto. The Court notes the parties were present and represented by counsel. Based upon 
argument, it is 
ORDERED AND ADJUDGED that 
1. 
The Motion to Stay is denied. 
2. 
The Clerk of Court shall make the documents available for disclosure at 
noon on Thursday, July 2, 2009. It is the intent of the Court to give the 
Defendant, Mr. Epstein, and his attorney an opportunity to have this 
Court's orders reviewed by the 4th DCA. If the Clerk gets no direction from 
the Appellate Court, she shall disclose the documents on the date referred 
to above. 
DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this 
::a3TJCDA74 D OArED 
JUN 2 6 2009 
JEFFREY J. a/BAWL COLBATH 
Circuit Court Judge 
EFTA00231117

Page Two 
Case No. 502008CF009381A)0(MB/502006CF009454AXXMB 
Order Denying Motion to Stay Disclosure Agreement 
Copies furnished: 
R. Alexander Acosta, U.S. Attorneys Office - Southern District 
500 South Australian Avenue, 
West Palm Beach, FL 33401 
Barbara Burns, Esq., State Attorney's Office 
401 North Dixie Highway 
West Palm Beach, FL 33401 
William J. Berger, Esq. 
Bradley J. Edwards, Esq. 
Rothstein Rosenfeldt Adler 
401 East Las Olas Boulevard., Suite 1650 
Ft. Lauderdale, FL 33394 
Robert D. Critton, Esq. 
Burman, Critton, Luther & Coleman 
515 North Flagler Drive, 
West Palm Beach, FL 33401 
Jack A. Goldberger, Esq. 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401 
Spencer T. Kuvin, Esq. 
Leopold-Kuvin, P.A. 
2925 PGA Boulevard, Suite 200 
Palm Beach Gardens, FL 33410 
Deanna K. Shullman, Esq. 
P. O. Box 2602 
Tampa, FL 33602 
EFTA00231118

Judge Jeffrey J. Colbath 
205 North Dixie Highway 
VVestRalm Beach, FL 33401 
WESTPALMBEACWRAWDA330H 
MSS
.
$ 00.44L: 
R. A LEAA tett A coSTA CSCI 
U.S. Attorney's Office Southern District 
500 S. Australian Avenue 
West Palm Beach, FL 33401 
33401+623S 
EFTA00231119

0-4 fikr-elt: P Cji
tv 
EFTA00231120

IN THE CIRCUIT COURT OF THE 
Ir 
IEENTH JUDICIAL CIRCUIT IN
AND FOR PALM BEACH COUNTY, 
FLORIDA 
CASE NO. 2008CF009381A 
DIVISION W 
STATE OF FLORIDA 
v. 
JEFFREY EPSTEIN, 
Defendant. 
EPSTEIN'S MOTION TO STAY DISCLOSURE OF THE NON-
PROSECUTION AGREEMENT AND ADDENDUM PENDING REVIEW 
Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned 
counsel and pursuant to Rule 9.310, Florida Rules of Appellate Procedure, moves to stay 
disclosure of the Non-Prosecution Agreement and Addendum (collectively, the "NPA") 
pending review, and states: 
1. 
In the event the Court grants Nonparty M.'s Motion to Vacate Order 
Sealing Records and Unseal Records, grants Palm Beach Post's Motion to Intervene and 
Petition for Access and/or denies EPSTEIN's Motion to Make Court Records 
Confidential, EPSTEIN moves to stay the disclosure of the NPA pending review by the 
Fourth District Court of Appeals. 
2. 
Rule 9.310(a), Florida Rules of Appellate Procedure, provides in pertinent 
part, "...a party seeking to stay a final or non-final order pending review shall file a 
motion in the lower tribunal, which shall have continuing jurisdiction, in its discretion , to 
grant, modify or deny such relief." 
EFTA00231121

3. 
A stay pending review is warranted under the circumstances because of 
the irreparable harm that would be caused by disclosure of the NPA including, but not 
limited to, substantial injury to a party by disclosing matters protected by common law 
and privacy rights, substantial injury to a compelling government interest, substantial 
injury to innocent third parties and a serious imminent threat to the fair, impartial and 
orderly administration of justice as set forth in the hearing record date June 25, 2009. 
4. 
In Mariner Health Care of Nashville, Inc. v. Baker 739.. 24 608, 609 
(Fla. 1st DCA 1999), defendant Mariner filed a petition for writ of certiorari after the trial 
court compelled it to produce certain incident reports. Mariner also moved for a stay 
pending review pursuant to Fla. R. App. Pro. 9.310. The trial court advised the parties 
that Mariner would be required to submit the incident reports to the court under seal as a 
prerequisite to a stay. Mariner refused to produce the documents under seal and the trial 
court denied the motion for stay and imposed daily fines until the documents were 
produced. Id. The First District Court of Appeals affirmed the trial court's order and 
noted 
Mariner has failed to explain how the production of the 
reports under seal would result in any prejudice. To the 
contrary, the records will be protected from disclosure 
during the entire course of the certiorari proceeding before 
this court. No harm can be done if this court ultimately 
determines that the reports are protected by the work 
product privilege. 
Id. at 610. 
5. 
In the instant case the NPA is already filed under seal. Should the Court 
grant Nonparty M.'s Motion to Vacate Order Sealing Records and Unseal Records, 
grant Palm Beach Post's Motion to Intervene and Petition for Access and/or deny 
2 
EFTA00231122

EPSTEIN's Motion to Make Court Records Confidential, EPSTEIN requests the Court 
exercise its discretion under Fla R. App. Pro. 9.310(a) and enter a stay pending review 
by the 4th DCA. 
6. 
No hann will be done if the NPA remains under seal pending appellate 
review. To the contrary, EPSTEIN will suffer irreparable harm if a stay is not entered 
and the NPA is disclosed to the public. 
WHEREFORE, Defendant, JEFFREY EPSTEIN, respectfully requests that if the 
Court grants Nonparty M.'s Motion to Vacate Order Sealing Records and Unseal 
Records, grants Palm Beach Post's Motion to Intervene and Petition for Access and/or 
denies EPSTEIN's Motion to Make Court Records Confidential, the Court enter a stay 
pending review and grant any additional relief the Court deems just and proper. 
Certificate of Service 
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been 
furnished by Hand Delivery to 
., United States Attorney's 
Office — Southern District, 500 S. Australian Avenue, 
West Palm Beach, FL 
33401, JUDITH STEVENSON AREO, ESQ., State Attorney's Office — West Palm 
Beach, 401 North Dixie Highway, West Palm Beach, FL 33401, WILLIAM J. BERGER, 
ESQ., and BRADLEY J. EDWARDS, Rothstein Rosenfeldt Adler, 401 East Las Olas 
Boulevard, Suite 1650, Fort Lauderdale, FL 33394, JACK A. GOLDBERGER, ESQ., 
Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South Suite 1400„ weet 
Palm Beach, FL 33401, SPENCER T. KUVIN, ESQ., Leopold-Kuvin, P.A., 2925 PGA 
Blvd., Suite 200, Palm Beach Gardens, FL 33410, and DEANNA K. SHULLMAN, 
3 
EFTA00231123

400 North 
Drive, Suite 1100, P.O. Box 2602 (33601) Tampa, FL 33602, this 25th 
day of June.  2009. 
BURMAN, CRITTON, LUTTIER & 
COLEMAN, LLP 
515 N. Flagler Drive, 
West Palm Beach, FL 
401 
By: 
Robert D. Cri n, Jr. 
Florida Bar 
24162 
Michael J. Pike 
Florida Bar #617296 
Counsel for Defendant J6ffrey Epstein) 
and 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beac FL 33401-5012 
Fax: 
Counsellor Defendant Jeffrey Epstein 
4 
EFTA00231124

BURMAN, CRITTON, LUTTIER 
& COLEMAN LLP 
L•A•W'Y•B•R•S 
515 N. FLAMER DRIVE 
WEST PALM BEACH, FLORIDA 33401 
I 
U.S. Attorney's Office Southern District 
500 S. Australian Avenue 
West Palm Beach, FL 33401 
c023 
$ 00.44° 
r PC1A /iP C.:1;0F 
EFTA00231125