EFTA00234224

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 81 of 100 
sor & Associates 
Roporunp and Transcrip:i no. Inc. 
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Page 55 
 
CERTIFIED QUESTION 
BY MR. TEIN: 
Q. 
You asked your co-workers --
MR. LEOPOLD: It's vague and ambiguous. 
BY MR. TEIN: 
Q. 
You asked your co-workers at the 
7 
Quzrterdeck Tavern to lie for you, didn't you? 
8 
A. 
No. I informed my boss about what was 
9 
going on and he told me that he would help in any way 
10 
that he can. 
11 
Q. 
Okay. You got your friend 
to lie 
12 
by switching name tags with you, correct? 
13 
A. 
Incorrect. It was a coincidence that same 
14 
night she was not wearing her name tag; she was wearing 
15 
mine. But I was also not wearing -- I was wearing my 
16 
name tag. Everyone switches name tags. It just so 
17 
happens it was a coincidence that same night the people 
18 
came with the papers. 
19 
MR. TEIN: Will you put up Exhibit 18-001? 
20 
MR. GOLDBERGER: And mark 18-001 for 
I 21 
identification purposes to this deposition. 
22 
MR. LEOPOLD: None of them have been marked 
23 
yet. Can we mark them and put them as attachment 
24 
to the depositions? Because I think you've shown 
25 
three photos now. And this is the only one that 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Pam Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
81 01316 
EFTA00234304

Case 9:08-cv-80804-KAM 
D 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 82 of 100 
nsor & Associates 
ReporunE and Transcripura, Inc. 
Page 56 
1 
has been marked for identification yet. 
2 
BY MR. TEIN: 
3 
Q. 
all 
--
4 
MR. LEOPOLD: Hold on just a second. Just 
5 
so the record is clear --
6 
MR. TEIN: I'm not speaking to you. 
7 
MR. LEOPOLD: Okay. Then don't speak to me 
8 
then. But I'll speak to Mr. Goldberger, perhaps. 
9 
But at least for the record, can we put on 
10 
the record what the previous two photographs were 
11 
marked for identification? 
12 
MR. GOLDBERGER: We will make sure that the 
13 
record is clear at the end of the deposition so 
14 
that there's no ambiguity. 
15 
MR. LEOPOLD: Thank you. 
16 
BY MR. TEIN: 
17 
Q. 
an 
I've put a photograph marked 18-001 
18 
up on the screen. Do you see that? 
19 
A. 
Yup. 
20 
Q. 
Who is that in the photo? 
21 
A. 
the left and me on the right. 
22 
Q. le 
right? 
23 
A. 
Yes. 
24 
Q. 
a 
your friend at the 
25 
Quarterdeck Tavern, right? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6201316 
EFTA00234305

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 83 of 100 
*nsor & Associates 
Reportins end Transcriptirr. Inc. 
Page 57 
1 
A. 
Yes. 
2 
Q. 
your friend, who you say the day 
3 
that the process servers went to serve you with a 
4 
subpoena for this deposition, just happened -- just by 
5 
coincidence, was wearing your name tag? 
6 
A. 
Yes, sir. 
7 
Q. 
And just by coincidence, you were wearing 
8 
her name tag, correct? 
9 
A. 
Yes. 
10 
Q. 
Your testimony under oath is that's just a 
11 
coincidence, right? 
12 
A. 
Total honesty. 
13 
Q. 
It just happens to be the day that you were 
14 
going to be served with a subpoena, correct? 
15 
A. 
That wasn't the first day that --
16 
MR. LEOPOLD: 
just answer the 
17 
question. It calls for a yes or no. 
19 
THE WITNESS: Yes. 
19 
BY MR. TEIN: 
20 
Q. 
You said that wasn't the first day you were 
21 
going to be -- you thought you were being served with a 
22 
subpoena, correct? 
23 
A. 
Correct. 
24 
Q. 
You knew before the day that you switched 
25 
name tags withill'Illithat the process servers were 
6301316 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234306

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 84 of 100 
nsor & Associates 
RopanmpandTramoripmmJnc 
Page 58 
1 
looking for you, didn't you? 
2 
A. 
No. I knew --
3 
MR. LEOPOLD: Just answer it. It calls for 
4 
a yes or no. 
5 
THE WITNESS: Okay. No. 
6 
BY MR. TEIN: 
7 
Q. 
Now you can explain the answer that your 
8 
counsel stopped you from explaining. 
9 
A. 
Okay. I work at Quarterdeck and people 
10 
were telling me that people were looking for me. So yes, 
11 
I was aware that people were searching for me. But I had 
12 
no :dea who they were or what their intentions were. But 
13 
I thought they were just people I didn't want to talk to. 
14 
So I just didn't want to talk to them. And every time 
15 
they'd come to work I wasn't there. And so happens the 
16 
night that they came in me and my friend switched name 
17 
tags. No big deal. 
18 
Q. 
That's a lie, isn't it? 
19 
MR. LEOPOLD: Objection. Don't answer that 
20 
question. That's harassment and I will not allow 
21 
it. He could ask the questions and we'll allow a 
22 
jury to make that determination, but not counsel. 
23 
I will not allow her to answer that 
24 
question. 
25 
MR. TEIN: Certify it. 
$401316 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234307

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 85 of 100 
nsor & Associates 
Reparunp nod Transcripuon, inc. 
Page 59 
1 
MR. LEOPOLD: I'll certify it. 
2 
 
CERTIFIED QUESTION 
3 
She's answered that question. She's explained it five 
4 
tines already. The fact that Counsel doesn't like the 
5 
answer, that's a different query. 
6 
MR. TEIN: Stop making speaking objections. 
7 
MR. LEOPOLD: I'm not. I'm not going to 
8 
put up with it, because it's in appropriate, Jack, 
9 
and you know it. I will not allow Counsel to 
10 
berate a witness, whether it's in a criminal case 
11 
or a civil case, whether my client or --
12 
MR. TEIN: Calm down. 
13 
MR. LEOPOLD: Excuse me. 
14 
No, I'm not going to allow it. That is not 
15 
proper. 
16 
MR. GOLDBERGER: Okay. 
17 
MR. LEOPOLD: If he wants to say that she's 
18 
lying after asking it five times and her 
19 
explaining in great detail, he can do that. But 
20 
I'm not going to allow her to answer, nor be 
21 
harassed by him. It's improper. 
22 
MR. GOLDBERGER: Okay. But your response 
23 
that counsel doesn't like the guestiOn -- or 
24 
doesn't like the answer -- just let me finish. 
25 
MR. LEOPOLD: Absolutely. I wasn't going 
5501316 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234308

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 86 of 100 
nsor & Associates 
Ropnrcing and Transcript°. Inc 
Page 60 
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to interrupt you. 
MR. GOLDBERGER: Just requires us to say we 
like the answer to that question. And it's not 
you and I or you and Mr. Tein who are testifying 
here. It's the witness. 
MR. LEOPOLD: Fine. But after the sixth 
time of asking the same question and then coming 
back and pointing a finger at her and saying, 
"You're a liar" --
MR. TEIN: That didn't happen. 
MR. LEOPOLD: That's fine. But I'm not 
going to allow her to answer that question, 
because she's answered that same question and has 
explained it. 
Now Counsel might be sitting there rubbing 
his head with a migraine. That's his problem. 
But if he can't ask a question appropriately in a 
professional manner, we will leave. I will not 
allow her to be berated like that. 
MR. GOLDBERGER: Actually, we're very happy 
with the answer. 
MR. LEOPOLD: That's great. 
MR. GOLDBERGER: Do you want us to get into 
that? 
MR. TEIN: Ted --
86 o1316 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234309

Case 9:08-cv-80804-KAM 
cument 1 
Entered on FLSD Docket 07/21/2008 
Page 87 of 100 
670316 
nsor & Associates 
Ronan' np and Transc ripen. Inc 
Page 61 
1 
MR. LEOPOLD: This is really big stuff that 
2 
you're going through. But that's fine; just ask 
3 
your question and move on. But do it one time. 
4 
If you don't understand it, I'll let you follow 
5 
up, but I'm not going to allow you to ask the same 
6 
question time and again and then call her a liar. 
7 
Just ask the question, get the answer and move to 
8 
the next subject matter. 
9 
MR. TEIN: Ted, I'm sitting right across 
10 
the table from you. 
11 
MR. LEOPOLD: Yes, sir. 
12 
MR. TEIN: Please be quiet. Don't yell. 
73 
MR. LEOPOLD: I will not be quiet. 
14 
MR. TEIN: Stop yelling. 
15 
MR. LEOPOLD: Lewis, when I'm yelling 
16 
you'll know it. I will not 
17 
MR. TEIN: My name is not Lewis. 
18 
MR. LEOPOLD: I thought your first name was 
19 
Lewis, Mr. Tein. 
20 
MR. TEIN: You watched me for three days at 
21 
the evidentiary hearing where you sat in the back 
22 
of the courtroom. You should know who I am. 
23 
MR. LEOPOLD: Well, that's the impression 
24 
you must have made in the courtroom. 
25 
I will not be quiet. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234310

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07:21/2008 
Page 88 of 100 
nsor & Associates 
ReponinS and Transcri rico, Mc. 
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, 41111,0 
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. 
IIIIIIIIF 
22 
Q. 
And what did IIIIII 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. 
8801316 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234311

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 89 of 100 
Snsor & Associates 
Roper:mg and lranscririon Inc 
Page 63 
1 
Q. 
Where were you when IIIIIIIrtold 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 Illirwould 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 
was:n'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 
1 6 
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. 
8901316 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234312

Case 9:08-cv-80804-KAM 
Doc ment 1 
Entered on FLSD Docket 07/21/2008 
Page 90 of 100 
nsor & Associates 
Reporting end Transcription, Inc 
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 
O. 
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 01316 
EFTA00234313

Case 9:08-cv-80804-KAM 
Docyment 1 
Entered on FLSD Docket 07/21/2008 
Page 91 of 100 
nsor & Associates 
Renew:flap and Transcripm, 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, llilir 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
91 01316 
EFTA00234314

Case 9:08-cv-80804-KAM 
cument 1 
Entered on FLSD Docket 07/21/2008 
Page 92 of 100 
9204 316 
nsor & Associates 
iloportiop .121141 Twist ri p:i ism.lac 
Page 66 
1 
A. 
Nothing. 
2 
Q. 
well, we're going to come back to MySpace 
3 
in a second. 
4 
A. 
You do that. 
5 
0. 
I'm going to ask you some questions 
6 
about 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 
MR. LEOPOLD: Objection, argumentative. 
13 
THE WITNESS: Incorrect. 
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. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234315

Case 9:08-cv-80804-KAM 
D c 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 93 of 100 
nsor & Associates 
• Roportmg and Transcript's:0)3.1c 
Page 67 
1 
Q. 
And where is the one body piercing? 
2 
A. 
Belly. 
3 
Q. 
When did you get that? 
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. 
Okay. So you had that body piercing when 
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, 
15 
correct? 
16 
A. 
Incorrect. 
17 
Q. 
Are you swearing under oath that you've 
18 
never done that? 
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 Pa :m Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
9001316 
EFTA00234316

Case 9:08-cv-80804-KAM 
Dq ment 1 
Entered on FLSD Docket 07/21/2008 
Page 94 of 100 
li
i nsor & Associates 
Roamns and liascripm. 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 
My$pace 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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
N01315 
EFTA00234317

Case 9:08-cv-80804-KAM 
Do ument 1 
Entered on FLSD Docket 07/21/2008 
Page 95 of 100 
nsor & Associates 
Reporting and Transcrirnina, 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. 
G0 
Q. 
And when you wrote 18 as your age on your 
21 
MySpace page, that was a lie, wasn't it? 
L2 
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 
95 of 316 
EFTA00234318

Case 9:08-cv-80804-KAM 
Dog ment 1 
Entered on FLSD Docket 07/21/2008 
Page 96 of 100 
nsor & Associates 
keptirtins and Transcription, Inc 
Page 70 
1 
2 
that you had to be 18 to have a MySpace. 
3 
Q. 
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 
is 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. 
A. 
Correct. There was a rule many years ago 
So you lied about your age so you could 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
9601316 
EFTA00234319

Case 9:08-cv-80804-KAM 
Do ment 1 
Entered on FLSD Docket 07/21/2008 
Page 97 of 100 
4; 4, 
nsor & Associates 
kopornng and TranscTipzion, Inc 
Page 71 
1 
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. 
ph-huh. 
9 
Q. 
Why did you finally post your true age on 
10 
your MySpace profile --
11 
A. 
Uh --
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 
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ever meet a Detective Recatey? 
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 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 
O. 
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. 
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Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
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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 
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Case 9:08-cv-80804-KAM 
DQcylfrlent 1 
Entered on FLSD Docket 07/21/2008 
Page 100 of 100 
sor & Associates 
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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. OW 
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. 
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