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FBI VOL00009
EFTA00231917
1120 sivua
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Case 9:08-cv-80804-KAM D Q. ent 1 Entered on FLSD Docket 07/21/2006 Page 45 of 100 nsor & Associates Reporting ad Trossainakia. 1 2 yours on MySpace? 3 A. Sure, yes. Page 19 Did you send that message to a friend of 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 Q. What word did you use in there? 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 MR. LEOPOLD: No, Don't -- don't 15 let him ask you the question. 16 BY MR. TEIN: 17 O. What question were you asking, 18 19 You ask the questions. What is the question 20 pending? 21 BY MR. TEIN: 22 Q. what is the last word on there in 23 the text of your message before tne ciosing? Int MR. LEOPOLD: She doesn't ask questions. 24 A. Niggaa. 25 Q. Don't you find that term offensive? 4 a Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4001314 EFTA00232177
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Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 46 of 100 sor & Associates Reporting and Transcript.= In Page 20 1 A. No. 2 MR. LEOPOLD: Can you spell it for the 3 record, please. 4 THE WITNESS: N-i-g-g -- 5 MR. TEIN: No, no, no. You are not going 6 to be asking questions. 7 MR. LEOPOLD: I'm not asking questions. 8 I'm asking for the record the word to be spelled, 9 because we don't have a video here today. 10 MR. TEIN: These exhibits are part of the 11 record. You -- 12 MR. LEOPOLD: Well, it's not marked as an 13 exhibit. 14 MR. TEIN: Stop interrupting me, 15 Mr. Leopold. I have marked and identified as an 16 exhibit and you will get it. 17 MR. LEOPOLD: There has been no 18 identification of this document in the record. 19 MR. TEIN: Mr. Leopold, stop interrupting 20 this deposition. 21 MR. LEOPOLD: What is the exhibit number 22 marked for identification? 23 MR. TEIN: 31-001. 24 MR. LEOPOLD: Do we have copies? Is it on 25 the record anywhere? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 MI et Ste EFTA00232178
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Case 9:08-cv-80804-KAM entl EnteredonFLSpDocket07/21/2008 Page 47 of 100 nsor & Associates Reporting nil TenseOption. Inc 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 21 1 BY MR. TEIN: 2 Q. Let me ask you, did you in fact 3 write your friend this message about this deposition? 4 A. Yes. 5 Q. So you wrote your friend that this 6 deposition is stupid court s-h-i-t, correct? 7 A. Yes. Q. Because you think this deposition is stupid court s-h-i-t, don't you? A. No. Q. You wrote that to your friend, didn't you? A. Yes. Q. You think that court is stupid, don't you? A. In some cases. Q. And you think that court is bull s-h-i-t, don't you? A. No. Q. And you think this deposition is bull s-h-i-t, don't you? A. No. Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: MR. TEIN: That's not an objection. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 470316 EFTA00232179
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Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page48of100 nsor & Associates Roponins and Trascripnna, Inc. Page 22 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. 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 17 will do that. 18 MR. TEIN: Here's what we'll do, Ted. You 19 can -- I 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. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4804311 EFTA00232180
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Case 9:08-cv-80804-KAM t 1 Entered on FLSD Docket 07/21/2008 Page 49 of 100 sor & Associates Reporting end Tr.uiscrtrion, loc. Page 23 1 BY MR. TEIN: 2 Q. you think that giving testimony 3 today, under oath, is bull s-h-i-t, don't you? 4 A. No. 5 Q. And you wrote that to your friend on 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 Q. You wrote in this exhibit, "I got some 15 stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 16 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 — 2S-- three-Yearragerr— Gkeig 24 A. Uh -huh. 25 Q. When the police interviewed you one month Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 40 03111 EFTA00232181
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Case 9:08-cv-80804-KAM D u ent 1 Entered on FLSD Docket 07/21/2008 Page 50 of 100 * 16 17 18 19 ! 20 21 22 23 sor &Associates Reanntap 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, 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. Q. Were you totally shocked by what happened when you got to Epstein's house? A. Yes. O. You didn't expect it at all, did you? A. No. Q. You had absolutely no idea why your friend as taking you to Epstein's house, right? 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. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 510 31$ EFTA00232182
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Case 9:08-cv-80804-KAM Anent1 Entered on FLSD Docket 07/21/2008 Page 51 of 100 sor & Associates Reporting and intim/1pda% loc. . Page 25 1 2 3 never said anything to you on the telephone about sexual 4 activity with Epstein, did she? 5 A. No. A. Yes. 0. 6 Q. 7 Before you got to Epstein's house And before you got to Epstein's house 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 4. 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. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 110714 EFTA00232183
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Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 52 of 100 nsor & Associates Rennnens and Tin/airman, lac. Page 26 1 Q. 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. 6 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. let me ask you 24 MR. LEOPOLD: If you continue to -- 25 MR. TEIN: Stop interrupting my questions. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 32 W3141 EFTA00232184
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Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 53 of 100 nsor & Associates ReportenE mend Tranutirion. Inc 1 2 Page 27 MR. LEOPOLD: If you do it one more time, we're leaving. 3 BY MR. TEIN: 4 0. 5 6 7 8 9 10 11 12 S 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 is inappropriate. You're willing and you are able and you're responsible to ask a question in a 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. I am. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 53 of 315 EFTA00232185
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Case 9:08-cv-80804-KAM q pent 1 EnteredonFLSDDocket07/2112008 Page 54 of 100 nsor & Associates Roparanp aac Transcrtrim, lne 1 Page 28 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• 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 18 19 20 21 22 23 24 25 BY MR. TEIN: Q• Listen, IIIIII-- MR. LEOPOLD: Hold on. Stop. I've been doing this for 20 plus years and have met a lot of attorneys, but I've never had an experience like this where I've MR. TEIN: Stop your speeches. MR. LEOPOLD: If you continue to do this, whether it's with me or with my client, I will not Ph. - Fax. 1655 Palm Beach Lakes Blvd.; Suite 500 - West Palm Beach, FL 33401 S4 of 3101 EFTA00232186
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Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 55 of 100 nsor & Associates Reporting ad Trans< nfrtion. 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 THE COURT REPORTER: No, I did not. 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. VEIN: Suit yourself. 23 THE WITNESS: I'm sure. 24 BY YR. TEIN: 25 0. Let me ask you a few questions about your Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 55 of SIO EFTA00232187
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Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 56 of 100 nsor & Associates Roponini ranscrip:u co. 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? 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 Q. You never went there again, correct? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Seat Sit EFTA00232188
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Case 9:08-cv-80804-KAM p ent1 Entered on FLSD Docket 07/21/2008 Page 57 of 100 nsor & Associates Reporting sod Tratteriptra, 1 2 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 A. No. Page 31 Q. All right. Let me ask you two final areas 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. MN 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. 3 O. Who was the other girl in the car with you 24 that day? 25 A. I honestly don't know. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 sr a SUP EFTA00232189
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Case 9:08-cv-80804-KAM merit 1 Entered on FLSD Docket 07/21/2008 Page 58 of 100 n5Or & Associates Reporting ad Traatiptien. lac. 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 0. So it was Illillwho told you to lie about 15 your age to Jeff Epstein? 16 A. Yes, sir. 17 Q. And IIII 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 24 out how old you were, right? 25 A. Excuse me? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 51cAlIll EFTA00232190
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Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 59 of 100 nsor & Associates Reportinp /ad Tunic apron, lnc. 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. 12 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 19 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. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 St of 316 EFTA00232191
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Case 9:08-cv-80804-KAM 4# 0 ent 1 Entered on FLSD Docket 07/21/2008 Page 60 of 100 nsor & Associates Reparunp Dad Transcriputo. 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. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 GO a/ 31f EFTA00232192
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Case 9:08-cv-80804-KAM ent 1 teradonFLSCOocket07/21/2008 Page 61 of 100 nsor Associates Roaming and Trassansuice, lac Page 35 2 3 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 -- Q. You can answer the question. A. Sure. Q. Is there anything that would refresh your B 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 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 exa 24 do remember telling her I told him I was 18. 25 Q. And do you remember telling Detective Pagan Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 61 at 316 EFTA00232193
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Case 9:08-cv-80804-KAM ent 1 EnteredonFLSODocket07121/2008 Page 62 of 100 nsor & Associates • Reporting end Transcription, inc. 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 lyLng? 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 O. Does it sound right to you that you told 8 Detective Pagan that you said your age really fast to 9 Epstein -- 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. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 62 x1616 EFTA00232194
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Case 9:08-cv-80804-KAM Qagkynent 1 Entered on FLSD Docket 07/21/2008 Page 63 of 100 sor & Associates Repornic and lranacripuon. kit Page 37 1 BY MR. TEIN: 2 Q. 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 WJTNESS: 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 Q. You wanted Mr. Epstein to believe that you 19 really were 18, right? 20 A. Correct. 21 Q. 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. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 63 el 316 EFTA00232195
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Case9:08-cv-80804-KAM D u ent 1 Entered on FLSD Docket 07/21/2008 Page 64 of 100 nsor & Associates itencatinA and Transcnrian, Inc 1 2 A. Q. Page 38 Yes. Was that the truth? 3 A. No. 4 Q. In fact, you went to , 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 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't remember having that conversation with her, so I wouldn't know if that's what I said. Q. That was a lie, though, wasn't it? MR. LEOPOLD: Objection to the form of the question, lack of foundation. You're making an 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 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 84 or 310 EFTA00232196