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FBI VOL00009

EFTA00234324

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Page 117 
You object. You know the rules. You just 
lectured me about the rules, Counsel. So why 
Case 9:08-cv-80804-KAM 
nt 1-2 
Entered on FL$D Docket 07/21/2008 
Page 41 of 100 
nsor & Associates 
Reparung and lranscri pn on, lnc 
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don't you play by the rules? Or only when they 
4 
fit you? Why don't you grandstand a little more 
5 
now. Give us a five-minute speech, Mr. Leopold. 
6 
MR. LEOPOLD: Are you finished, for the 
record? 
MR. TEIN: I'm not talking to you. Do what 
you want. 
MR. LEOPOLD: Don't say anything yet. 
BY MR. TEIN: 
Q. gar 
your parents --
MR. LEOPOLD: Hold it. Don't say anything 
yet. Let me --
BY MR. TEIN: 
Q. 
Your parents, who filed the police report 
are also liars. 
MR. LEOPOLD: Don't answer the question. 
We're not going to answer until I make the record. 
I want to put on the record, now that Counsel 
appears to be finished with his comments for the 
record, that the previous question was 
inappropriate, was intentionally misleading. 
Now you can ask the question. 
BY MR. TEIN: 
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Case 9:08-cv-80804-KAM 
Q• 
nt 1-2 
Entered on FL$D Docket 07/21/2008 
Page 42 of 100 
sor & Associates 
Roporting mid Transcription, Inc 
Page 118 
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in this case, are also proven liars, aren't they? 
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BY MR. TEIN: 
5 
Q. 
Aren't your parents liars? 
6 
MR. LEOPOLD: Calls for speculation. Lack 
7 
of predicate. 
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MR. TEIN: Stop coaching. You know what 
9 
that is, Leopold. 
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MR. LEOPOLD: Calls for speculation. Lack 
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of foundation. 
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THE WITNESS: When you say parents, my mom 
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is not, but sure, yeah, my dad has been to jail 
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for lying. 
15 
BY MR. TEIN: 
16 
Q. 
Your dad went to federal prison for two 
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yea:s for lying, right? 
18 
A. 
Correct. 
19 
Q. 
Did he tell you it was for a financial 
20 
fraud? 
21 
A. 
Yes. 
22 
Q. 
For stealing money from some financial 
23 
institution? 
24 
A. 
Correct. 
25 
Q. 
And do you think your father is trying to 
Your parents, who filed the police report 
MR. LEOPOLD: Same objection. 
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Case 9:08-cv-80804-KAM 
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Page 43 of 100 
sor & Associates 
Reper•.imp and l'anscripoon, Inc 
Page 119 
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steal your lawsuit money away from you? 
2 
Don't look to your lawyer for the answer. 
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MR. LEOPOLD: You can answer if you know 
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the answer to it. I have no idea. 
5 
THE WITNESS: Yeah. 
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BY MR. TEIN: 
7 
Q. 
And your father filed a lawsuit, the first 
8 
lawsuit for fifty million dollars against Mr. Epstein 
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without consulting you, correct? 
10 
A. 
Correct. 
11 
Q. 
And your father had a lawyer file the first 
12 
lawsuit on your behalf for fifty million dollars against 
13 
Mr. Epstein without your knowledge, correct? 
14 
A. 
Correct. 
15 
Q. 
And you don't trust your father, do you? 
16 
A. 
Correct. 
17 
Q. 
And you believe he's trying to manipulate 
18 
you for his own gain, don't you? 
19 
A. 
Sort of. 
20 
0. 
Well, you know that your mother filed a 
21 
statement, an affidavit, saying that you don't trust your 
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father and that you believe he's trying to manipulate you 
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for lis own gain; isn't that correct? 
24 
A. 
Correct. 
25 
Q. 
You agree with that statement, don't you? 
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Case 9:08-cv-80804-KAM 
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nsor & Associates 
kopornns cod I:inn:mince). Inc 
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A. 
Uh-huh. Yes. 
Q• 
Do you trust your stepmother? 
A. 
My stepmother, no. 
Q• 
Page 120 
You think she's also trying to steal your 
Epstein lawsuit money away from you, don't you? 
A. 
I would like to clarify something. You 
7 
keep saying my Epstein lawsuit money. I don't have any 
8 
money, and it's just a lawsuit at the moment. So I just 
9 
don't trust her. 
10 
Q. 
Okay. You think that your stepmother is 
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trying to take advantage of this lawsuit to try to get 
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money from Mr. Epstein that belongs to you, right? 
13 
A. 
Yes. 
14 
Q. 
Did your stepmother tell you why she was 
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arrested? 
16 . 
A. 
No. 
17 
Q. 
Did your stepmother tell you that she's 
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ever been arrested? 
19 
A. 
No. 
20 
Q. 
Did she tell you she was arrested for 
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fraud? 
22 
A. 
Never. 
23 
Q. 
Did she tell you that she was fired from 
24 
Hawthorne Aviation? 
25 
A. 
No. 
ylOWOMAID 
V 
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Case 9:08-cv-80804-KAM 
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Page 45 of 100 
sor & Associates 
Hcpnr•.inp and Tanscriptico, Inc 
Q. 
Page 121 
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Hawthorne Aviation for stealing? 
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A. 
No. 
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MR. TEIN: Let's take a break. 
5 
(Thereupon, a recess was taken.) 
6 
BY MR. TEIN: 
7 
Q. before 
you met Jeffrey Epstein, had 
8 
you ever had sexual intercourse? 
9 
A. 
Yes, yeah. 
10 
Q. 
How many times? 
11 
A. 
Just a few. Twice. 
12 
Q. 
With how many different men? 
13 
A. 
Two. 
14 
Q. 
How old were they? 
15 
A. 
being one year older than me, 
16 
and then the other person was two years older than me. 
17 
Q. 
What was his name? 
"18 
A. 
19 
Q. 
How old were you when you first had sexual 
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intercourse? 
21 
A. 
14. 
22 
Q. 
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many different men had you had any type of sexual 
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act:.vity with? 
Did she tell you that she was fired from 
How many -- before you met Epstein, how 
25 
A. 
Just those two. 
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Case 9:08-cv-80804-KAM 
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Page 46 of 100 
nsor & Associates 
Raprusina and Transcription, Inc. 
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Page 122 
Q. 
Are you saying you never kissed a man other 
than those two? 
MR. LEOPOLD: Objection to the form of the 
question. 
THE WITNESS: Yes, I had kissed people 
before. 
BY MR. TEIN: 
Q. 
Before you met Epstein, had you ever had 
orel sex? 
A. 
No. 
Q. 
Ever in your life, have you exchanged sex 
for something of value? 
A. 
No. 
MR. TEIN: We're done. 
THE WITNESS: Oh, okay. 
MR. LEOPOLD: We'll read. 
MS. BELOHLAVEK: I don't have any 
questions. Thank you. 
MR. LEOPOLD: Before we go off the record, 
it's my understanding -- Mr. Goldberger can 
correct the record -- but we have stipulated that 
color copies of the documents that were identified 
for identification certainly will be attached to 
the deposition and counsel will be taking the 
photographs across street so that they can be 
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Case 9:08-cv-80804-KAM 
nsor & nAssociates 
tered on FLSD Docket 07/21/2008 
Page 47 of 100 
Roportinp and lranscriptico, lac.
Page 123 
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laser color copied so that we have a copy, and I'm 
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assuming he'll get a copy to the court reporter, 
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too, to attach, actually a certified copy to the 
4 
deposition. 
5 
MR. GOLDBERGER: Done. 
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MR. LEOPOLD: That's if you agree to that. 
7 
If not, then I want to pull each one out and put 
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exhibit labels on them, which we should do before 
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we leave. 
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MR. GOLDBERGER: We're not going to do 
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either. I'll have copies sent to the court 
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reporter and she can attach them to the 
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deposition. 
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MR. LEOPOLD: So you're not going to agree 
15 
to what we talked about during the break then. 
16 
MR. GOLDBERGER: I'm not quite sure what 
17 
your asking me to do. Let me finish. 
18 
MR. LEOPOLD: Okay. Sure. That's fine. 
19 
MR. GOLDBERGER: Okay. If you want me to 
20 
go over to Ms. Belohlavek's office and make copies 
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and then I'll give those to the court reporter, 
22 
fine. All I'm saying is that I would avoid that 
23 
process. I would send copies to the court 
24 
reporter. But if it will make you happier --
25 
MR. LEOPOLD: I'm not? 
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Case 9:08-cv-80804-KAM 
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Page 48 of 100 
sor 
tissociares 
Roponing and Transcription, Inc 
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Page 124 
MR. GOLDBERGER: Let me finish. 
MR. LEOPOLD: I'm not interrupting now. 
MR. GOLDBERGER: But if it will make you 
4 
happier if I go over to Ms. Belohlavek's office 
5 
and make a copy of those photos that were part of 
6 
this deposition and then I'll give them to the 
7 
court reporter, I'll be happy to do it. 
8 
MR. LEOPOLD: I trust you implicitly, 
9 
however you with to do it. However, the 
10 
documents, before they leave this room, need to 
11 
have an exhibit sticky on them with the 
12 
appropriate --
13 
MR. GOLDBERGER: Want to go get some? We 
74 
don't have any. 
15 
MR. LEOPOLD: I will do that. Excuse me. 
16 
Let me finish the record, please. You can't do 
17 
that to the court reporter. She's going to stroke 
18 
out. You can't do that. You have to let me --
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MR. TEIN: Finish your sentence, Ted. You 
20 
are the most long-winded lawyer I've ever seen in 
21 
my life. Finish your sentence. 
22 
MR. LEOPOLD: Jack, tell him not to raise 
L3 
his voice, please. 
24 
MR. TEIN: Finish your sentence. Is there 
25 
going to be a period at the end of the sentence or 
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EFTA00234371
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Case 9:08-cv-80804-KAM 
ent 1-2 nEntcred on FLSQ Docket 07/21/2008 
Page 49 of 100 
sor disk Associates 
Rep.-mins and Transcriponm, Inc 
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Page 125 
is it just going to be comma after comma after 
comma? 
Go ahead, lawyer. 
MR. LEOPOLD: All right. The exhibits, I 
5 
can't prevent you from taking them, but I will 
6 
object and I will be bringing it to the court for 
7 
sanctions. You cannot take the exhibits out of 
8 
the room without them being marked. I want them 
9 
marked, because you cannot identify in the record 
10 
what was used. And with all due respect to 
11 
Mr. Goldberger, I do not -- the way this 
12 
deposition is going, I do not want to rely on 
13 
Counsel from Miami to mark the appropriate 
14 
exhibits. I will not do that. I cannot prevent 
15 
you from taking them. But if you do, I will be 
16 
bringing the matter to the court with appropriate 
17 
sanctions, because that is improper. That is 
18 
improper. When you use something in a deposition, 
19 
they are to be marked. And you have refused to do 
20 
that throughout for what ever reason. 
21 
MR. TEIN: You're wrong. Finish your 
22 
sentence because you're talking about something 
23 
you have no idea. 
24 
Every single one is marked, Ted. Every 
25 
single one is already marked. But you want to 
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n5or 6). Associates 
Ronartinp and lrinscriFlon.inc 
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Page 126 
argue about everything. Ever single one is 
already marked. Isn't that silly, Ted? 
MR. GOLDBERGER: Thirty years of doing this 
and I have never had an argument over this. 
MR. TEIN: You've made -- Ted, you are 
obstructionist, you are a liar. You have lied and 
misrepresented things, for the record. You are 
grandstanding. 
MR. LEOPOLD: You need to back up. 
MR. TEIN: No, no. I'm going to finish. 
MR. LEOPOLD: You can finish, but don't 
hover over me. 
MR. TEIN: No one is hovering over you. 
Stop trying to make a lying record. 
Let me say something else. 
Don't you dare threaten me with sanctions, 
after you lied in a letter to my co-counsel about 
the fact -- be quiet. Be quiet and let me finish. 
You lied in a letter to my co-counsel, 
Mr. Leopold, in which you said -- it was a 
complete and utter lie -- that you were 
unavailable this morning because you had a 
hearing. That was a lie. I have never seen a 
lawyer deign to do something like that. 
So you will get the ex -- be quiet. Let me 
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1655 Pali) Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
1500? 310 
EFTA00234373
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ntered on FLSO Docket 07/21/2008 
Page 51 of 100 
sor 1 Associates 
Reparnna and Transcriphnn. Inc 
1 
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me. 
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Page 12-; 
finish. You behave. 
MR. LEOPOLD: Don't point your finger at 
MR. TEIN: Listen. Be quiet and I won't 
5 
have a need to point it at you. 
6 
7 
8 
9 
me. 
10 
MR. TEIN: Mr. Leopold, let me finish. 
11 
MR. LEOPOLD: Don't raise your voice 
12 
either. 
13 
MR. TEIN: Mr. Leopold --
14 
MR. LEOPOLD: Jack, do you want to take 
15 
care of this? 
16 
MR. TEIN: Let me finish my sentence. The 
17 
exhibits are marked. We are walking out of here. 
18 
19 
record. It is absolutely atrocious what you do. 
20 
That is not how a lawyer should behave. This 
21 
deposition is over. You will get your exhibits, 
22 
Mr. Leopold. 
23 
MR. GOLDBERGER: I understand what you're 
24 
saying, Michael, and I understand Ted's position. 
25 
MR. LEOPOLD: Don't point your finger at 
MR. TEIN: Mr. Leopold --
MR. LEOPOLD: Don't point your finger at 
You are someone who misrepresents the 
Just so there's -- we're going to have lots 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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EFTA00234374
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t
o
Case 9:08-cv-80804-KAM 
nt 1-2 
Entered on FLSt1Docket07/21/2008 
Page 52 of 100 
nsor 
A55OClatC5 
Rcpnninc and ltanstrimarel. Inc. 
Page 128 
1 
of issues in this case. We're going to have lots 
2 
of reasons to disagree. 
3 
I'm going to take it over now and I'm going 
4 
to make copies and I'm going to give them to 
5 
Ms. Consor. If you want to go find some exhibit 
6 
labels and put some exhibit labels on it, be my 
7 
guest. But that's what I'm offering to do. 
8 
THE WITNESS: Let me say two things, 
9 
because I am happy to always disagree, and with 
10 
you, I have no problem; we could always do it 
13. 
professionally. I have not problem. 
12 
I want to say two things so the record is 
13 
very clear. 
14 
Since for whatever reason I have not been 
15 
able to look at exhibits, because they have been 
16 
refused to have been shown to me --
17 
MR. TEIN: That's a lie. 
18 
MR. LEOPOLD: -- Jack, if you represent 
19 
that the documents have the appropriate exhibit 
23 
numbers or some identifying markings, 25, 30.000, 
21 
whatever they may be, then you can take them, make 
22 
copies, send me a copy, make sure the court 
23 
reporter gets a copy and then send me a bill for 
24 
my copies, that's fine. I didn't know that they 
25 
are marked that way because I haven't been able to 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
152 0715 
EFTA00234375
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1-2 
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r-k 
07/21/2008 
Page 53 of 100 
nnt so r et n‘ dgnoFaafeg‘et 
Renaming and lranscripan. lac 
Page 129 
1 
look at them. 
2 
MR. GOLDBERGER: They are barcoded, and the 
3 
number that we've made reference to in the 
4 
deposition coincides with the barcoding. 
5 
MR. LEOPOLD: That's fine. Eight by eleven 
6 
color laser copies are fine. 
7 
MS. BELOHLAVEK: The State Attorneys Office 
8 
is not going to charge anybody for color copies I 
9 
print out. 
10 
MR. LEOPOLD: That's fine. He's going to 
11 
take them back to his office. 
12 
Secondly -- and I will be more than happy 
13 
to do it, because it sounds like you all know more 
14 
about it than I -- but I'm happy to get affidavits 
15 
from Mr. Pincus, Judge Stern, everybody else about 
16 
what happened with this hearing today, because 
17 
know very little about it. But my representations 
18 
are what they are. 
19 
MR. GOLDBERGER: They stay --
20 
MR. LEOPOLD: Let me just finish for the 
21 
record. 
22 
My representations or comments about what 
23 
happened, representation about this hearing this 
24 
morning, I know very little about it. I 
25 
MR. GOLDBERGER: I'll take your word on 
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Case 9:08-cv-80804-KAM 
nt 1-2 -Entered on FLSO Docket 07/21/2008 
Page 54 of 100 
sor & Associates 
korinntris and TIIIII3Cfi prin. lnc 
that. 
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Page 130 
MR. LEOPOLD: No, no, no. I just put it on 
the record. I will get an affidavit -- I'm 
assuming it sounds like you need it -- from Mr. 
Pincus. I have no clue about what happened and 
why it was canceled. All I was told when I was 
out of town yesterday was that the hearing this 
morning was cancelled. 
MR. GOLDBERGER: I'll take your word for 
it. 
MR. LEOPOLD: If you want an affidavit, 
I'll get it for you. 
MR. GOLDBERGER: It's a personal issue for 
me because I had to disrupt a vacation and if it 
was done just because it wasn't convenient for 
you, then I'm offended by that. But if you're 
telling me that it was planned and it didn't 
happen, I'll take your word for it. 
MR. LEOPOLD: I am more than happy to get 
you an affidavit, because I don't know the reason 
why it was canceled other than the fact that I'm 
assuming since my deposition was taken for four 
hours on Monday for preparation for the hearing 
today, for whatever reason it was canceled, I am 
told it is being re-noticed. Why it was canceled, 
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154 14 315 
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Page 55 of 100 
sor 
Associates 
Rept-mint and Transt I i New. Inc. 
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Page 131 
I have no idea, but if your co-counsel wishes an 
affidavit to that effect from Mr. Pincus, I'm more 
than happy to get it. But I don't know the reason 
why it was canceled. 
MR. TEIN: I don't need it. But what I do 
take issue with is regardless of why it was 
canceled, you owed us the courtesy of saying, You 
know what? We can start earlier this morning. 
MR. LEOPOLD: I owe you nothing. 
MR. TEIN: I don't care. Don't interrupt 
me. 
Because Jack canceled his vacation plans 
because of you. 
MR. GOLDBERGER: That's all right, that's 
all right. 
MR. TEIN: And you're selfish. And this 
deposition is over. Good-by Mr. Leopold. 
MR. GOLDBERGER: You can go off the record. 
- - - 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
155 Of 316 
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Page 56 of 100 
5O1 N. 
on 
Reporuns and 1r/uncoil:inn, 'Inc 
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The State of Florida, 
CERTIFICATE 
5 
County of Palm Beach. 
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Page 132 
I hereby certify that I have read the 
foregoing deposition by me given, and that the statements 
contained herein are true and correct to the best of my 
knowledge and belief, with the exception of any 
corrections or notations made on the errata sheet, if one 
was executed. 
Dated this  
day of 
, 2008. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
156 (4 316 
EFTA00234379
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I llO
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' ' 
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-P 
, 
nnr 
07/21/2008 
Page 57 of 100 
nnt5Or eanA
t rgscsaactnesket 
RI:toning and Transcripano, inc 
Page 133 
1 
2 
DATE: February 25, 2008 
TO: 
c/o L 
3 
Office of the State Attorney 
401 N. Dixie Highway 
4 
west Palm Beach, Florida 33401 
5 
IN RE: 
STATE OF FLORIDA -V- JEFFREY EPSTEIN 
CASE NO.: 2006 CF09454AXX 
6 
Please take notice that on Wednesday, the 
7 
20th of February, 2008, you gave your deposition in the 
above-referred matter. At that time, you did not waive 
8 
signature. It is now necessary that you sign your 
deposition. 
9 
Please call our office at the below-listed 
number to schedule an appointment between the hours of 
10 
9:00 a.m. and 4:30 p.m., Monday through Friday. 
11 
If you do not read and sign the deposition 
wittin a reasonable time, the original, which has already 
12 
beer forwarded to the ordering attorney, may be filed 
with the Clerk of the Court. If you wish to waive your 
13 
signature, sign your name in the blank at the bottom of 
this letter and return it to us. 
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Very truly yours, 
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Judith F. Consor, FPR 
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Consor & Associates Reporting and Transcription 
1655 Palm Beach Lakes Boulevard, Suite 500 
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West Palm Beach, Florida 33401 
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I do hereby waive my signature: 
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cc via transcript: 
JACK A. GOLDBERGER, ESQ. 
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LANNA BELOHLAVEK, ESQ. 
MICHAEL R. TEIN, ESQ. 
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THEODORE J. LEOPOLD, ESQ. 
file copy 
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Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
157 of 316 
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Reporting ad Transcription, Inc 
Page 134 
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ERRATA 
SHEET 
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IN RE: STATE-V-JEFFREY EPSTEIN 
DEPOSITION OF: 
TAKEN: February 20th, 
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2008 
DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE 
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Please forward the original signed errata sheet to this 
office so that copies may be distributed to all parties. 
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Under penalty of perjury, I declare that I have read my 
deposition and that it is true and correct subject to any 
changes in form or substance entered here. 
DATE: 
SIGNATURE OF DEPONENT: 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
158 of 315 
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Ropnrunp and Trinscrireco. inc 
Page 135 
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THE STATE OF FLORIDA, ) 
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COUNTY OF PALM BEACH. ) 
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I, the undersigned authority, certify that 
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personally appeared before me on the 20th 
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of February, 2008 and was duly sworn. 
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WITNESS my hand and official seal this 25 day 
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of February, 2008. 
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Judith F. Consor, FPR 
Notary Public - State of Florida 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
159403I6 
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herinnunE and 'I ranscri pnon. Inc 
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CERTIFICATE 
Page 136 
The State Of Florida, ) 
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County Of Palm Beach. ) 
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I, Judith F. Consor, Court Reporter and Notary 
Public in and for the State of Florida at large, do 
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hereby certify that I was authorized to and did 
stenographically report the deposition of 
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that a review of the transcript was regueste ; anc 
at 
the foregoing pages, numbered from 1 to 131, inclusive, 
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are a true and correct transcription of my stenographic 
notes of said deposition. 
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I further certify that said deposition was 
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taken at the time and place hereinabove set forth and 
that the taking of said deposition was commenced and 
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completed as hereinabove set out. 
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I further certify that I am not an attorney or 
counsel of any of the parties, nor am I a relative or 
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employee of any attorney or counsel of party connected 
with the action, nor am I financially interested in the 
14 
action. 
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The foregoing certification of this transcript 
does not apply to any reproduction of the same by any 
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means unless under the direct control and/or direction of 
the certifying reporter. 
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DATED this 25 day of February, 20 
• 
Judith F. Consor, Court Repo 
(.41-30211 
t 
Florida Professional Reporter 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
150 0 315 
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