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FBI VOL00009
EFTA00799605
176 sivua
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 61 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 30 of 100 nsor & Associates ROMMIIIS /All 111ClitAilii. 1 2 3 4 5 6 7 8 9 10 Deposition Court Reporter and Notary Florida at Large, in Thereupon, having been first duly and testified as follows: THE WITNESS: DIRECT taken before Public in and the above cause. Page 4 Judith F. Consor, for the State of was examined sworn or affirmed, I do. EXAMINATION 11 BY MR. TEIN: 12 O. Good afternoon. Please tell me your full 13 nage. 14 A. 15 0. And can you please spell it. 16 A. 7 18 Q. Thank you. 19 May I call you S 20 A. Uh-huh. 21 Q. OM I'm 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 30 e1316 08-80736-CV-MARRA 001236 EFTA00799665
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 62 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 31 of 100 nsor & Associates Runonias and Truascririm. lac Page 5 1 my questions, will you just please let me know? 2 A. Yes. 3 Q. And if at any time you're not feeling well 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 O. 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. Who else is living there? 22 A. MEM my uncle. 23 24 25 Q. A. No. Q. Anyone else living there? The contempt motion that your mother filed Ph. 561.682.0995 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 it Mils 08-80736-CV-MARRA 001237 EFTA00799666
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 63 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 32 of 100 nsor & Associates Reporting And TrAnscri pan:Inc. Page 6 1 against your father regarding your fifty million-dollar 2 lawsuit against Jeffrey Epstein says that you live with 3 your aunt and uncle and have been living there; is that 4 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 O. 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 0. Have you been to the apartment that you and L4 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 32 of 314 08-80736-CV-MARRA 001238 EFTA00799667
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 64 of 176 Case 9:08-cv-80804-KAM ent 1 EnteredonFLSODocket07/21/2008 Page 33 of 100 nsor & Associates Ha parting and Tun scri pa i . Inc Page 7 1 Q. Where is that? 2 A. Palm Beach Lakes. 3 Q. Have you spent the night over there? 4 A. No, sir. 5 Q. Do you know the address there? 6 A. I do not. 7 Q. Isn't your sister planning on living 8 with you and IIII? 9 A. No. 10 Q. you know that this court case is a 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 O. And you're here with your Lawyer 21 Mr. Leopold, right? 22 A. Yes. 23 Q. And you know that Mr. Leopold recently 24 filed a lawsuit in federal court against Jeffrey Epstein, 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 3304315 08-80736-CV-MARRA 001239 EFTA00799668
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 65 of 176 Case 9:08-cv-80804-KAM 34 O'311 ent 1 Entered on FLSD Docket 07121/2008 Page 34 of 100 nsor & Associates Rannrtinp and l'ransctilxlan, lac. Page 8 1 MR. LEOPOLD: Let me just object. 2 let me instruct you. Anything that 3 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, you may 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 O. 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 MR. LEOPOLD: Same objection. 14 If you know the answer to that outside of 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 O. You can answer the question unless 22 MR. LEOPOLD: Same objection. 23 MR. TEIN: Let me finish. 74 MR. LEOPOLD: Excuse me. We're -- 25 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 08-80736-CV-MARRA 001240 EFTA00799669
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 66 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 35 of 100 nsor & Associates Reponing and Transcriplien, lrg. Page 9 1 MR. LEOPOLD: Lewis, we're not going to do 2 3 MR. TEIN: My name is not Lewis. 4 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 MR. LEOPOLD: Same objection. 14 Anything that you learn through 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 THE WITNESS: No. 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? that. 23 MR. LEOPOLD: Same objection. 24 Do not answer that question if it's through 25 discussions that you and I had. Outside of that, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 3Solattl 08-80736-CV-MARRA 001241 EFTA00799670
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 67 of 176 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Case 9:08-cv-80804-KAM entl Entered on FLSD Docket 07/21/2008 Page 36 of 100 nsor & Associates Reporting and Truscir'mina, Inc. Page 10 1 2 3 that answer. 4 5 BY MR. DEIN: 6 Q. You didn't know that? 7 MR. LEOPOLD: Don't answer that question. 8 Again, it's attorney/client privilege. Any information you've learned through conversations between you and I are protected. If you know it through any other realm, you may answer. MR. TEIN: Are you going to say that for every question in the deposition, Mr. Leopold? MR. LEOPOLD: When you ask improper questions like that without the proper -- MR. TEIN: You're going to stop your speaking objections right now. Okay? MR, LEOPOLD: Without the proper -- MR. TEIN: You need to stop your speaking objections. Let's continue. MR. LEOPOLD: Counsel, you just asked me a question and I'd going to state it on the record -- 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 THE WITNESS: No. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beath Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001242 EFTA00799671
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 68 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 37 of 100 nsor & Associates Reponing anti 'Frame-rip:ion. Int. 1 2 3 4 5 6 7 8 9 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 10 appropriate worded question with the proper it foundation and predicate, I will certainly allow 12 the client to answer the question. 13 MR. GOLDBERGER: Why don't you just state 14 attorney/client privilege and just be done with 15 it? 16 17 clear. 18 19 20 21 22 MR. LEOPOLD: I want the record to be 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. 23 But let's move on and maybe you'll stop 24 obstructing this deposition. 25 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 *I 31$ 08-80736-CV-MARRA 001243 EFTA00799672
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 69 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 38 of 100 nsor & Associates Repantn2 and TtiminiptIon, 1 2 3 4 clear where we stand thus far. Is there a recording taken of this deposition? THE COURT REPORTER: Yes. Page 12 5 MR. LEOPOLD: Just make sure that's 6 preserved. 7 ay.ma. 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 38 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 34 of 314 08-80736-CV-MARRA 001244 EFTA00799673
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 0 6/02/201 7 Page 70 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 39 of 100 nsor & Associates Repartlap and Taaansi mina, Inc 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 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 Page 13 an attorney, filed a fifty-million-dollar lawsuit on your behalf against Jeffrey Epstein, yes or no? MR. LEOPOLD: Same objection. HR. TEIN: We've heard the objection 10 times already. MR. LEOPOLD: Counsel, excuse me. MR. TEIN: Just say attorney/client privilege. Stop interrupting my questions. MR. LEOPOLD: I'm entitled to make an objection for the record, which I'm doing, and I'll make the same objection. And if it calls for attorney/client privilege, any conversations you and I have had, do not answer the question. And I think that it might be appropriate, IIIIII for the record, to ask questions via elliallas opposed to figi I think that would be more appropriate for this deposition. After it happened. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Hagan 08-80736-CV-MARRA 001245 EFTA00799674
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 71 of 176 Case 9:08-cv-80804-KAM 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 nt 1 Entered on FLSD Docket 07/21/2008 Page 40 of 100 nsor & Associates Reparsins end TrAGIC tiptinn. 1. 2 don't you, yes or no? A. Yes. Page 14 Q. You know that he had a press conference, 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: Q. Have you ever seen that picture before? A. Yes. Q. Is that a picture of your father, your stepmother and Mr. Herman at the press conference regarding your lawsuit? A. Yes. Q. Now you know that this is a very serious matter, don't you? MR. LEOPOLD: Asked and answered. Objection. MR. GOLDBERGER: All right. You can object. You're representing a witness here, Mr. Leopold. You can object on privilege grounds. You cannot make legal objections. You have no standing to do so. MR. LEOPOLD: I'm going to make them and then -- MR. GOLDBERGER: We're -- Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 40 44310 08-80736-CV-MARRA 001246 EFTA00799675
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 72 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 41 of 100 nsor & Associates Reporting and Transcription, Inc Page 15 1 MR. LEOPOLD: We're going to leave or we're 2 going to take a break, because his demeanor is not 3 appropriate. There's no reason to have this kind 4 of demeanor. If you want to have this kind of 5 demeanor with me -- 6 MR. TEIN: You are obstructing this 7 deposition. 8 MR. GOLDBERGER: Why don't you guys go 9 outside and just talk about -- 10 MR. LEOPOLD: She -- her job is very 11 difficult and she's not going to be able to take 12 us both talking at the same time. 13 MR. GOLDBERGER: Off the record. 14 MR. LEOPOLD: We're not going off the 15 record, Jack. We're not, Jack. Her job is very 16 difficult. I'm going td make the record. 17 I don't think it is appropriate, especially 18 in the small confines of this room, to be very 19 aggressive with this young lady. 20 MR. TEIN: That's not happening. Stop, 21 stop actually -- 22 MR. LEOPOLD: If you're going to interrupt 23 me, we're going to cancel this deposition -- 24 MR. TEIN: Stop misrepresenting. 25 THE COURT REPORTER: I need one at a time, Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 41 44 316 08-80736-CV-MARRA 001247 EFTA00799676
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 73 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 42 of 100 nsor & Associates ;tenoning sad Tranictirion. Inc 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 16 no matter who it is. MR. LEOPOLD: I think we're going to take a break. Perhaps you might want to talk to your co-counsel -- MR. TEIN: I don't need to talk to him. MR. LEOPOLD: But we're going to take a break. MR. TEIN: We're not taking a break unless the witness needs a break. You're obstructing this deposition, Ted. MR. LEOPOLD: Come on, You all want to continue in this demeanor -- MR. TEIN: You're obstructing the deposition. Stop making speeches. We're not discussing this with you. The questions are to your client. Go take your five-minute break. MR. LEOPOLD: Fine. We need to make sure the record's clear and clean. And I want. to make sure, as I've already asked you -- I know that you're one of the best in town -- that this audio -- this needs to be preserved. Okay? MR. TEIN: Go take your five-minute break, Mr. Leopold, now. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 AS el 316 08-80736-CV-MARRA 001248 EFTA00799677
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 74 of 176 Case 9:08-cv-80804-KAM nt 1 EnteredonFLSDDocket07/21/2008 Page43of100 nsor & Associates Ropansn mid Transciirim. 1 2 3 back. 4 Page 17 You were supposed to be here at nine a.m.; it's now after two. Take your break and come MR. LEOPOLD: Okay. If the demeanor keeps 5 up, we will not be here beyond those five minutes. 6 7 8 relax. 9 10 break. 11 MR. GOLDBERGER: Let them take that 12 five-minute break. 13 MR. LEOPOLD: But I would suggest that you 14 take deep breaths. 15 MR. TEIN: Suggest whatever you want. Go 16 take a break. 17 (Thereupon, a recess was taken.) 18 ➢Y MR. TEIN: 19 Q. you agree that giving testimony 20 today at your deposition is something very serious, don't 21 you? MR. TEIN: Take your break and come back. MR. LEOPOLD: Okay. So I suggest that you MR. TEIN: i suggest that you take your 22 A. Yes. 23 Q. And you respect the coilif7—Uan't you. 24 A. Yes. 25 Q. Let me show you Exhibit 31-001. Can you Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4101311 08-80736-CV-MARRA 001249 EFTA00799678
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 75 of 176 Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 44 of 100 nsor & Associates keportimp end TransClipnnn. Page 18 1 read that out loud, please. 2 A. Okay. What do you want? 3 Q. Will you read that out loud, please. 4 A. Oh. 5 Q. Thank you. 6 A. Lol hah my baddd...1O1 yah i got some 7 stupid court shit on the 20th...bullshit...and damn you still have court shit with him? Like after so long wow 9 im sorry... well yah well we will definitely havta make 10 plans for sure..because i miss u tons times a million and 11 no no no i love you...o and p.s. i love ur default pic 12 niggaa. Muah xo. 13 Q. Did you send that message last week to a 14 friend of yours on MySpace? 15 A. I wouldn't know. There's no dates and I've 16 deleted that MySpace, so -- 17 Q. We're going to talk about that in a second. 18 A. Okay. 19 Q. Did you send that message last week -- 20 A. Right. 21 O. Let me finish my question. 22 Did you send that message last week to a 23 friend of yours on MySpace? 24 A. I wouldn't know the date, but obviously, 25 it's to a friend. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 44 of 314 08-80736-CV-MARRA 001250 EFTA00799679
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 76 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 45 of 100 sor & Associates ReponinvimlYmnsairion,Inc. Page 19 Q. Did you send that message to a friend of 2 yours on MySpace? 3 A. Sure, yes. 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 15 let him ask you the question. 16 BY MR. TEIN: 17 Q. What question were you asking, ? 18 MR. LEOPOLD: She doesn't ask questions. 19 You ask the questions. What is the question 20 pending? 21 BY MR. TEIN: 22 Q. Z3 —The text of your message before tne closing? MR. LEOPOLD: No, Don't -- don't 24 A. Niggaa. leawhat is the last word on there in 25 Q. Don't you find that term offensive? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4$ of 316 08-80736-CV-MARRA 001251 EFTA00799680
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 77 of 176 Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 46 of 100 nsor & Associates Repo/lien end Transcription, inn 2 3 4 5 Page 20 A. No. MR. LEOPOLD: Can you spell it for the record, please. THE WITNESS: N-i-g-g -- MR. TEIN: No, no, no. You are not going 6 to be asking questions. 7 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 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? MR. LEOPOLD: I'm not asking questions. MR. LEOPOLD: There has been no Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 46 el 314 08-80736-CV-MARRA 001252 EFTA00799681
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 78 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 47 of 100 nsor & Associates ;tenoning and Transcription. lAC Page 21 1 BY MR. TEIN: 2 Q. Let me ask you, Sdid you in fact 3 write your friend this message about this deposition? 4 A. Yes. 5 Q. So you wrote your triend that this 6 deposition is stupid court s-h-i-t, correct? 7 A. Yes. 8 Q. Because you think this deposition is stupid 9 court s-h-i-t, don't you? 10 A. No. 11 Q. You wrote that to your friend, didn't you? 12 A. Yes. 13 Q. You think that court is stupid, don't you? 14 A. In some cases. 15 Q. And you think that court is bull s-h-i-t, 16 don't you? 17 A. No. 18 Q. And you think this deposition is bull 19 s-h-i-t, don't you? 20 A. No. 21 Q. You wrote that to your friend, didn't you? 22 MR. LEOPOLD: Objection. Asked and 23 answered. 24 MR. TEIN: That's not an objection. 25 BY MR. TEIN: Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 eel 316 08-80736-CV-MARRA 001253 EFTA00799682
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 79 of 176 Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 48 of 100 sor & Associates Reporting sod Transcdplion, Mt. 1. 2 Page 22 Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and 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. 8 MR. TEIN: Then terminate the deposition if 9 you think it's been asked and answered. 10 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 I 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 23 MR. TEIN: Of course; because you want to 24 obstruct. 25 MR. LEOPOLD: All right. MR. LEOPOLD: Counsel, I am not precluded MR. LEOPOLD: I won't do that. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001254 EFTA00799683
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 80 of 176 Case 9:08-cv-80804-KAM 9 10 11 12 nt 1 Entered on FLSD Docket 07/21/2008 Page 49 of 100 nsor & Associates Reporting sod Transcription, 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 G MySpace last week, didn't you? 7 HR. LEOPOLD: Objection. Asked and 8 answered. THE WITNESS: No, I did not. BY MR. TEIN: Q. You didn't write this exhibit? A. I wrote that, but I didn't write what you 13 said. 14 15 16 you write that? 17 A. Yes. 18 Q. 19 A. 20 informed that it was a deposition. 21 22 about what happened when you went to Jeff Epstein's house Q. You wrote in this exhibit, "I got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't Referring to this deposition, didn't you? Referring to the court. I was later O. I'm going to ask you some questions now Yee y Okay' 24 A. Oh-huh. 25 Q. When the police interviewed you one month • .0 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 MOM 08-80736-CV-MARRA 001255 EFTA00799684