EFTA00234224

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 21 of 100 
where petitioners alleged that they had "suffered emotional pain, anguish, 
humiliation, insult, indignity, loss of self-esteem, inconvenience, hurt and 
emotional distress" as a result of being forced repeatedly, over time, to "perform 
sexual acts to retain their employment"). Here, even if the Amended Complaint 
can be read to plead that the defendants schemed to solicit other massages from 
other people (see, e.g., Am. Compl. TV 9, 11, 12, 32), those activities are not 
alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. 
F..I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004) 
(holding that "'indirect injuries, that is injuries sustained not as a direct result of 
predicate acts . . . will not allow recovery under Florida RICO."' (quoting 
O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) 
(emphasis added). 
Because the Amended Complaint does not satisfy the direct-injury 
requirement under Florida's RICO law, Jane Doe has failed to allege a cause of 
action against 
for violation of section 772.103, Florida Statutes. 
B. This Notice satisfies the procedural requirements of 28 U.S.C. § 1446. 
1. This notice of removal is timely. 
In accordance with 28 U.S.C. § 1446, this notice of removal is timely. Only 
defendant Epstein has been served with process. Defendants 
21 
Lewis:Teinn. 
and 
3059 Gum} Avtme. Sum 340, Cocomo Gaon, FIOROA 33133 
21 outs 
EFTA00234244

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 22 of 100 
have not yet been served. In a multi-defendant lawsuit, removal is timely when 
effected within 30 days after the last defendant is served. See Hill Dermaceuticals, 
Inc. v. RX Solutions, United Health Group, Inc., No. 6:08-cv-330-Or1-311CRS, 
2008 WL 1744794, at *3 (M.D. Fla. Apr. 11, 2008) (concluding that removal 
petition was timely where it was filed within 30 days after the last defendant was 
served). 
2. Notice has been given, and state-court papers have been filed. 
In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice 
of Removal on July 18, 2008. All papers filed in State Court are attached to this 
Removal Petition. 
3. There is unanimity among the defendants. 
In accordance with 28 U.S.C. § I446(b) the undersigned are authorized to 
represent that all of the defendants join this Petition and consent to removal. 
Conclusion 
Because this is a civil action between citizens of different states, excluding 
any fraudulently joined parties, and the amount in controversy exceeds $75,000, 
exclusive of interests and costs, this Court has original jurisdiction over this action 
pursuant to 28 U.S.C. § 1332(aX1). 
22 
Levyni14.4.,IQ in n. 
3059 Gan* Avmut,Suni 340, CocOolui GEODVI.Ft00.04 33133 
220 316 
EFTA00234245

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07:21/2008 
Page 23 of 100 
WHEREFORE, the Defendants, Jeffrey Epstein, 
and 
, remove this case from Palm Beach Circuit Court to the United States 
District Court for the Southern District of Florida. 
Respectfully submitted, 
LEWIS TEIN, P.L. 
GUY A. LEWIS 
Fla. Bar No. 623740 
[email protected] 
MICHAEL R. TEIN 
Fla. Bar No. 993522 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
By: 
Jack A. Goldberger 
Fla. Bar No. 262013 
[email protected] 
Attorneys for Defendant Jeffrey Epstein 
23 
Lewis Trin 
3059 Guam Avisyt,Sunt 340, Comm, Glow, /toes. 33133 
01916 
EFTA00234246

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07:21:2008 
Page 24 of 100 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that the foregoing document is being served this day, 
July 18, 2008, on counsel of record identified on the service list by U.S. Mail. 
444eCt: 
Michael R. Tein 
24 
Lewis. "rein PI 
309 Gant* Avt mu. Sun: 340. Ca0+u1 Grow, FLOP** 33133 
2101316 
EFTA00234247

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 0721/2008 
Page 25 of 100 
Service List 
Theodore J. Leopold, Esq. 
Ricci-Leopold, P.A. 
oe 
Douglas M. McIntosh, Esq. 
Jason A. McGrath, Esq. 
McIntosh, Sawran, Peltz & Cartaya P.A. 
Counsel for Defendant Haley Robson 
Bruce E. Reinhart, Esq. 
Bruce E. Reinhart, P.A. 
n an •ra 
e en 
Robert D. Critton, Esq. 
Michael J. Pike, Esq. 
Burman, Critton, Luther & 
Coleman LL'
o- ounse or cirey Epstein 
25 
Lewis Teinrv. 
3059 Gum) Avow,. Sum 140. Cot owl GNOYE, 'LOMA 331)1 
Not 416 
EFTA00234248

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 26 of 100 
EXHIBIT A 
26 of 316 
EFTA00234249

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 27 of 100 
nsor & Associates 
Ker.onanp and Transcripnca. Inc 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 2006 CF09454AXX 
STATE OF FLORIDA, 
- vs-
JEFFREY EPSTEIN, 
Defendant. 
DEPOSITION OF 
Wednesday, February 20, 2008 
2:00 p.m. - 4:30 p.m. 
Palm Beach County Courthouse 
205 North Dixie Highway 
West Palm Beach, Florida 33401 
Reported By: 
Judith F. Consor, FPR 
Notary Public, State of Florida 
Consor & Associates Reporting and Transcription 
Phone - 561.682.0905 
Copy 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
2701316 
EFTA00234250

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 28 of 100 
nsor & Associates 
Repnniny end 1 nnsc ri pa on Inc 
Page 2 
1 
APPEARANCES: 
2 
3 
4 
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On behalf of the State: 
LANNA BELOHLAVEK, ESQ. 
ASSISTANT STATE ATTORNEY 
6 
On behalf of the Defendant: 
MICHAEL R. TEIN, ESQ. 
7 
KATHRYN A. MEYERS, ESQ. 
,EWIS TEIN, PL 
8 
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On behalf of the Defendant: 
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JACK A. GOLDBERGER, ESQ. 
ATTERBURY, GOLDBERGER & WEISS 
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12 
13 
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ALSO PRESENT: 
ON BEHALF OF THE WITNESS: THEODORE J. LEOPOLD, ESQ. 
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KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, 
LEGAL-EZE 
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:8 
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Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
2801315 
EFTA00234251

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 29 of 100 
nsor & Associates 
Itcpanitnc had lranuripturri Inc 
1 
2 
3 
INDEX 
WITNESS: 
Page 3 
PAGE: 
DIRECT EXAMINATION 
4 
4 
BY MR. TEIN: 
5 
6 
7 
NOEXHIBITS 
MARKED 
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9 
 
CERTIFIED QUESTIONS 
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Page 
Line 
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22 
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55 
1 
59 
2 
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111 
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112 
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Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
nonn 
EFTA00234252

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 30 of 100 
nsor & Associates 
Rcpnrini; and Transtrirum. lu 
1 
2 
3 
Page 4 
Deposition taken before Judith F. Consor, 
Court Reporter and Notary Public in and for the State of 
FlDrida at Large, in the above cause. 
4 
- - - 
5 
Thereupon, 
6 
7 
having been first duly sworn or affirmed, was examined 
a 
and testified as follows: 
9 
THE WITNESS: I do. 
10 
DIRECT EXAMINATION 
11 
BY MR. TEIN: 
12 
Q. 
Good afternoon. Please tell me your full 
13 
name. 
14 
A. 
15 
Q. 
And can you please spell it. 
16 
A. 
17 
18 
Q. 
Thank you. 
19 
May I call you S 
20 
A. 
Uh-huh. 
21 
Q. 
going to ask you a few 
22 
questions, several questions today. If at any time you 
23 
want to take a break, you just let me know. Okay? 
24 
A. 
Okay. 
25 
Q. 
If you at any time don't understand one of 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
3001316 
EFTA00234253

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 31 of 100 
nsor R Associates 
RepontnE and Tnnscripuca. lnc 
Page 5 
1 
my questions, will you just please let me know? 
2 
3 
Q. 
4 
or something like that, you'll tell us, right? 
5 
A. 
Yes. 
6 
Q. 
Do you feel okay today? 
7 
A. 
Yes. 
8 
Q. 
Not taking any alcohol or drugs or anything 
9 
like that, right? 
10 
A. 
No. 
11 
Q. 
So you feel ready to have your deposition 
12 
taken? 
13 
A. 
Yes. 
14 
Q. 
what is your address? 
15 
A. 
I'm currently living at my aunt's house and 
16 
I don't know it off the top of my head. 
17 
Q. 
Where is it? 
18 
A. 
In Jupiter. 
19 
Q. 
Who is your aunt? 
20 
A. 
21 
Q. 
22 
A. IIIIIIIIIIIIr 
my uncle. 
23 
Q. 
Anyone else living there? 
24 
A. 
No. 
25 
Q. 
The contempt motion that your mother filed 
A. 
Yes. 
And if at any time you're not feeling well 
Who else is living there? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
31,0316 
EFTA00234254

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 32 of 100 
nsor & Associates 
Report' np and Tranulirynco. Inc 
1 
2 
3 
4 
Page 6 
against your father regarding your fifty million-dollar 
lawsuit against Jeffrey Epstein says that you live with 
your aunt and uncle and have been living there; is that 
correct? 
5 
A. 
Yes. 
6 
Q. 
How long have you been living with your 
7 
aunt and uncle? 
8 
A. 
Since my father kicked me out. 
9 
Q. 
That was Thanksgiving of this past year? 
10 
A. 
Yes, sir. 
11 
Q. 
Okay. Didn't your firefighter boyfriend 
12 
get an apartment for the two of you? 
13 
A. 
No, sir. He has an apartment, but by 
14 
himself. 
15 
Q. 
Did he get an apartment for the two of you 
16 
to live in? 
17 
A. 
No, sir. 
18 
Q. 
Are you planning to move in with him? 
19 
A. 
Maybe one day in the future. 
20 
Q. 
Do you have a plan to move in with him 
21 
presently? 
22 
A. 
No. 
23 
Q. 
Have you been to the apartment that you and 
24 
have discussed moving in together? 
25 
A. 
I have been to the apartment. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
31.0316 
EFTA00234255

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 33 of 100 
nsor & Associates 
Reponimp and Transcriptim 
1 
2 
3 
4 
5 
6 
Q. 
Where is that? 
A. 
Palm Beach Lakes. 
Q. 
Have you spent the night over there? 
A. 
No, sir. 
O. 
Do you know the address there? 
A. 
I do not. 
Page 7 
7 
Q. 
Isn't your sister 
planning on living 
8 
with you and ill, 
9 
A. 
No. 
10 
Q. 
11 
criminal prosecution, correct? 
12 
A. 
Correct. 
13 
Q. 
And you know that it's a criminal 
14 
prosecution against a man who has no criminal background. 
15 
Do you know that? 
16 
A. 
I do now. 
17 
Q. 
You agree that court is a very serious 
18 
matter? 
19 
A. 
Yes. 
20 
Q. 
And you're here with your lawyer 
21 
Mr. Leopold, right? 
22 
A. 
Yes. 
23 
Q. 
And you know that Mr. Leopold recently 
filed a lawsuit in federal court against Jeffrey Epstein, 
Illillif
you know that this court case is a 
25 
seeking fifty million dollars. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
3301316 
EFTA00234256

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 34 of 100 
nsor & Associates 
Reporting and 1r/usefinnan. lac 
1 
2 
3 
Page 8 
MR. LEOPOLD: Let me just object. 
IIIIIIIIp
let me instruct you. Anything that 
you have learned through conversations between you 
4 
and me are protected. So if you know any of that 
5 
information outside of those discussions, 
6 
answer. But if the only way you know it is 
7 
through our discussions, do not answer that 
8 
question. 
9 
BY MR. TEIN: 
10 
Q. 
UM 
you know that Mr. Leopold recently 
11 
filed a lawsuit in federal court on your behalf against 
12 
Jeffrey Epstein seeking fifty million dollars? 
13 
14 
15 
our discussions, you may answer. If it is the 
16 
only way that you know the answer is through our 
17 
discussions, do not answer that question. 
18 
THE WITNESS: Okay. 
19 
MR. LEOPOLD: Attorney/client privilege. 
20 
BY MR. TEIN: 
21 
Q. 
22 
23 
24 
25 
MR. LEOPOLD: Same objection. 
you may 
If you know the answer to that outside of 
You can answer the question unless --
MR. LEOPOLD: Same objection. 
MR. TEIN: Let me finish. 
MR. LEOPOLD: Excuse me. We're --
MR. TEIN: No. Let me finish. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
3401316 
EFTA00234257

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 35 of 100 
sor & Associates 
Rcpmmn and Ininscri p:i nn, Inc 
1 
2 
3 
4 
that. 
Page 9 
MR. LEOPOLD: Lewis, we're not going to do 
MR. TEIN: My name is not Lewis. 
I'm going to finish my question. Okay? 
5 
MR. LEOPOLD: Do not answer until you hear 
6 
from me. 
7 
BY MR. TEIN: 
8 
Q. 
Other than conversations that you have had 
9 
with Mr. Leopold -- I'm not asking about that -- are you 
10 
aware that Mr. Leopold has filed a lawsuit in federal 
11 
court seeking fifty million dollars from Jeffrey Epstein 
12 
on your behalf? 
13 
14 
15 
conversations between you and me, do not answer. 
16 
Those are protected. If you know through any 
17 
other realm of knowledge, you may answer. 
18 
19 
BY MR. TEIN: 
20 
Q. 
You have no idea that Mr. Leopold filed a 
21 
fifty million-dollar lawsuit on your behalf against 
22 
Jeffrey Epstein? 
23 
MR. LEOPOLD: Same objection. 
4 
25 
discussions that you and I had. Outside of that, 
MR. LEOPOLD: Same objection. 
Anything that you learn through 
THE WITNESS: No. 
Do not answer that question if it's through 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
3501316 
EFTA00234258

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 36 of 100 
nsor & Associates 
Repornnp and Transc ripon. Inc 
Page 10 
1 
2 
3 
that answer. 
4 
THE WITNESS: No. 
5 
BY MR. TEIN: 
6 
Q. 
You didn't know that? 
7 
MR. LEOPOLD: Don't answer that question. 
8 
Again, it's attorney/client privilege. Any 
9 
information you've learned through conversations 
10 
between you and I are protected. If you know it 
11 
through any other realm, you may answer. 
12 
13 
every question in the deposition, Mr. Leopold? 
14 
MR. LEOPOLD: When you ask improper 
15 
questions like that without the proper --
16 
MR. TEIN: You're going to stop your 
17 
speaking objections right now. Okay? 
18 
19 
MR. TEIN: You need to stop your speaking 
20 
objections. 
21 
Let's continue. 
22 
MR. LEOPOLD: Counsel, you just asked me a 
23 
question and I'm going to state it on the 
24 
record --
25 
MR. TEIN: You need to stop your speaking 
you may answer. So do not answer that question if 
that is the only basis by which you understand 
MR. TEIN: Are you going to say that for 
MR. LEOPOLD: Without the proper --
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
36 01316 
EFTA00234259

Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
Page 37 of 100 
nsor & Associates 
Re portmE tnd TralllefipO11O. Inc 
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Page 11 
objections. Check your rules. 
MR. LEOPOLD: Excuse me. For the record, 
Counsel asked me a question. I'll state the 
answer on the record. He asked me the question am 
I going to be answering that way throughout the 
deposition. So long as there's improper 
foundation and predicate asked by the attorney, I 
will protect my client and I make the record where 
appropriate. If counsel wishes to ask an 
appropriate worded question with the proper 
foundation and predicate, I will certainly allow 
the client to answer the question. 
MR. GOLDBERGER: Why don't you just state 
attorney/client privilege and just be done with 
it? 
MR. LEOPOLD: I want the record to be 
clear. 
MR. TEIN: You want to waste time is what 
you want to do. 
You were supposed to be here this morning 
and you totally broke the deal, the agreement that 
you had with us if your hearing got cancelled. 
But let's move on and maybe you'll stop 
obstructing this deposition. 
MR. LEOPOLD: I think the record is very 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
37 of 316 
EFTA00234260

Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
Page 38 of 100 
nsor & Associates 
Roan:cif and Transcripunn, Inc 
Page 12 
1 
clear where we stand thus far. 
2 
Is there a recording taken of this 
3 
deposition? 
4 
THE COURT REPORTER: Yes. 
5 
MR. LEOPOLD: Just make sure that's 
6 
preserved. 
7 
BY MR. TEIN: 
8 
Q. 
Go to Exhibit 20-01 -- well, before you do 
9 
that,_ 
are you aware that a lawyer named Jeffrey 
10 
Herman filed a lawsuit on your behalf, yes or no? 
11 
MR. LEOPOLD: Objection. 
12 
Any conversations that you and I have had 
13 
regarding that, if that is the only way by which 
14 
you understand how to answer that question, do not 
15 
answer. It's attorney/client privilege, as well 
16 
as any conversations you may have had with the 
17 
attorney from Miami. That is also attorney/client 
18 
privilege. And I'm assuming --
19 
MR. TEIN: You're actually wrong about the 
20 
attorney/client privilege. 
21 
MR. LEOPOLD: I'm assuming Counsel is not 
22 
asking you to divulge attorney/client 
23 
MR. TEIN: Of course not. 
24 
BY MR. TEIN: 
25 
Q. 
a 
are you aware that Jeffrey Herman, 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
3801316 
EFTA00234261

Case 9:08-cv-80804-KAM 
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Page 39 of 100 
nsor & Associates 
Reportinr, and Transcrirann. Inc 
1 
2 
3 
Page 13 
an attorney, filed a fifty-million-dollar lawsuit on your 
behalf against Jeffrey Epstein, yes or no? 
MR. LEOPOLD: Same objection. 
4 
MR. TEIN: We've heard the objection 10 
5 
times already. 
6 
MR. LEOPOLD: Counsel, excuse me. 
7 
MR. TEIN: Just say attorney/client 
8 
privilege. Stop interrupting my questions. 
9 
MR. LEOPOLD: I'm entitled to make an 
10 
objection for the record, which I'm doing, and 
11 
I'll make the same objection. And if it calls for 
12 
attorney/client privilege, any conversations you 
13 
and I have had, do not answer the question. 
14 
And I think that it might be appropriate, 
15 
for the record, to ask questions via 
76 
as opposed to 
I think that 
17 
would be more appropriate for this deposition. 
18 
BY MR. TEIN: 
19 
Q. 
Go ahead. Please answer yes or no. 
20 
A. 
Yes. 
21 
Q. 
Thank you. 
22 
In fact, you know that Mr. Herman held a 
23 
press conference after he filed the fifty-million-dollar 
24 
lawsuit on your behalf, don't you? 
25 
A. 
After it happened. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
3901316 
EFTA00234262

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 40 of 100 
nsor & Associates 
Reporang and Transcription. Inc. 
Page 14 
7 
Q. 
You know that he had a press conference, 
2 
don't you, yes or no? 
A. 
Yes. 
4 
Q. 
In fact, let's go to Exhibit 20-01. 
5 
MR. GOLDBERGER: Look behind you. You'll 
6 
see it. 
7 
BY MR. TEIN: 
8 
Q. 
Have you ever seen that picture before? 
9 
A. 
Yes. 
10 
0. 
Is that a picture of your father, your 
11 
stepmother and Mr. Herman at the press conference 
12 
regarding your lawsuit? 
13 
A. 
Yes. 
14 
Q. 
Now you know that this is a very serious 
15 
matter, don't you? 
16 
MR. LEOPOLD: Asked and answered. 
17 
Objection. 
18 
MR. GOLDBERGER: All right. You can 
19 
object. You're representing a witness here, 
20 
Mr. Leopold. You can object on privilege grounds. 
21 
You cannot make legal objections. You have no 
22 
standing to do so. 
23 
MR. LEOPOLD: I'm going to make them and 
24 
then --
25 
MR. GOLDBERGER: We're --
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4001316 
EFTA00234263