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FBI VOL00009

EFTA00799605

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Page 70 of 100 
risor & Associates 
Reportine bed Transcription. Inc. 
Page 44 
1 
BY MR. TEIN: 
2 
Q. 
And IIIIIIrbought a purse, right? 
3 
A. 
Yes. 
4 
Q. 
And you were with her the whole time at 
5 
Marshall's, correct? 
6 
A. 
Yes. 
7 
Q. 
Now tell me about when the federal 
8 
prosecutors told you about getting reimbursed. 
9 
A. 
I have no idea what you're talking about. 
10 
Q. 
Tell me about when the federal prosecutors 
11 
spcke to you about getting money you feel you're entitled 
12 
to from Mr. Epstein. 
13 
A. 
I don't know what you're talking about. 
14 
Q. 
Do you know who 
Villafona is? 
15 
A. 
No, sir. 
16 
Q. 
Did you ever meet with any federal 
17 
prosecutors? 
18 
A. 
I think 
yeah. I think they were 
19 
think they were like FBI. 
20 
Q. 
tm-huh. Did you meet with federal 
21 
prosecutors? 
22 
A. 
They came to my house one time, yes. 
23 
Q. 
When did they come to your house? 
24 
A. 
Very long ago. 
25 
Q. 
Was it this year, 2008? 
70 0116 
Ph. 561.682.0905 - Fax. 561.682.1771 
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ered on FLSDnocket 07/21/2008 
Page 71 of 100 
steponenindltrarscriptiokinc. 
Page 45 
1 
A. 
It was not this year, no. 
2 
Q. 
Was it 2007? 
3 
A. 
I'd have to say at least two years ago or a 
4 
year ago, yeah. So it would be 2007, 2006; but it was a 
5 
while ago. 
6 
Q. 
How many federal prosecutors or FBI agents 
came to your house? 
8 
A. 
I'm trying to remember. I want to say four 
9 
people came. 
10 
Q. 
Did they give you their business cards? 
11 
A. 
If they did, I don't remember, and they 
12 
weren't toward me. Maybe my parents have them. I don't 
13 
know. 
14 
Q. 
Did they give you their cell phone numbers? 
15 
A. 
No. 
16 
Q. 
Did you ever speak to them on their cell 
17 
phones? 
18 
A. 
No, sir. 
19 
Q. 
Did they speak to your parents? 
20 
A. 
That's something you'd have to ask my 
21 
parents. 
22 
Q. 
Do you know whether they spoke to'your 
74 
oarapt'al 
24 
A. 
No, sir. 
25 
Q. 
You have no idea? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
TI elite 
08-80736-CV-MARRA 
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Page 72 of 100 
sor & Associates 
Report's and Transalpine', Inc. 
Page 46 
1 
A. 
No, sir. 
2 
MR. LEOPOLD: Objection. Asked and 
3 
answered. 
4 
BY HR. TEIN: 
5 
O. 
So if I say the name to you 
6 
Villafona, you don't know who that is? 
7 
A. 
No, sir. 
8 
O. 
How many women and how many men came to 
9 
your house? 
10 
A. 
I want to say two ladies and two guys. 
11 
Q. 
Did someone named Jeffrey Sloman come to 
:2 
you: house? 
13 
A. 
I don't know names, sir. 
14 
Q. 
Do you know who Jeffrey Sloman is? 
15 
A. 
No, sir. 
16 
Q. 
Do you know who Jeffrey Herman is? 
17 
A. 
Yes. 
18 
0. 
That's the lawyer who first sued Epstein on 
19 
your behalf, right? 
20 
A. 
Yes. 
21 
Q. 
Has Mr. Herman advanced your family any 
22 
money? 
23 
MR. LEOPOLD: Any conversations that you've 
24 
had with Mr. Herman regarding that issue, you are 
25 
not to disclose. If you've learned in some other 
1 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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nsor & Associates 
Ropaning Ind Transcripnen. Inc. 
3 
2 
3 
4 
BY MR. TEIN: 
fashion, you may answer. 
THE WITNESS: Okay. 
I wouldn't know. 
Page 47 
5 
Q. 
You don't know? 
6 
A. 
No. 
7 
MR. LEOPOLD: Objection. Foundation. 
8 
Attorney/client privilege. 
9 
BY MR. TEIN: 
10 
Q. 
And you say you don't know who Jeff Sloman 
11 
is? 
12 
A. 
No, sir. 
13 
Q. 
Does it refresh your recollection that he's 
34 
the number two prosecutor at the U.S. Attorney's Office? 
15 
A. 
No. 
16 
Q. 
That he's 
Villafona's boss? 
17 
A. 
No. 
18 
Q. 
Does it refresh your memory that he's the 
19 
ex-partner of Jeff Herman, the first lawyer, who sued 
20 
you -- sued Mr. Epstein on your behalf for fifty million 
21 
dollars? 
22 
A. 
No, sir. I don't know who he is. 
23 
O. 
Without telling me any conversations t at--
2 
4 
you've had with your lawyers, how is it that you selected 
25 
Mr. Herman as your lawyer from the 81,000 members of the 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
7) 4311 
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001279 
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nsor & Associates 
licpcinIng and Transctiptinm, Inc. 
Page 48 
1 
Florida Bar? 
2 
A. 
I did not select him. 
3 
Q. 
Who did? 
4 
A. 
My father. 
5 
Q. 
Did you ever meet Mr. Herman? 
6 
A. 
Once. 
7 
O. 
Don't -- don't tell me what you discussed 
8 
with him. Where did you meet him? 
9 
A. 
I was shopping in my -- he showed up at my 
10 
friend's house. 
11 
0. 
Whose house? 
12 
A. 
My friend 
13 
Q. 
Is that 
from the Quarterdeck 
14 
Tavern? 
15 
A. 
Yes. 
16 
Q. 
And did you have a meeting with him at 
17 
house? 
18 
A. 
Yes. I guess you could say that. 
19 
Q. 
And who else was there? 
20 
A. 
My Aunt 
21 
Q. 
And what was that meeting about? 
22 
MR. LEOPOLD: Objection. That calls for 
23 
attorney/client privilege. 
24 
BY MR. TEIN: 
25 
Q. 
What discussions did you have with 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
II of 311 
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sor & Associates 
Reporting and laanscripnnn, 
Page 49 
1 
Mr. Herman in the presence of
2 
A. 
None. 
3 
Q. 
What discussions did you have in the 
4 
presence of her aunt? 
5 
A. 
Of my aunt? 
6 
MR. GOLDBERGER: It's the witness's. aunt. 
7 
BY MR. TEIN: 
8 
Q. 
oh, of your aunt. 
9 
A. 
The only one that we've ever discussed or 
10 
ever had. 
11 
Q. 
And so you were in a conversation with 
12 
Mr. Herman and your aunt? 
13 
A. 
Yes, sir. 
14 
Q. 
And you discussed privileged matters during 
15 
that conversation? 
16 
MR. LEOPOLD: Object to the form. I think 
17 
you might have to educate her on that question. 
18 
BY MR. TEIN: 
19 
Q. 
You discussed the lawsuit? 
20 
A. 
Yes. 
21 
Q. 
Did 
tell you about any 
22 
conversations that she had with Mr. Herman? 
23 
A. 
As far as I'm concerned, she's never spoken 
24 
or she's never had a conversation. She only opened the 
25 
door and then left. She's the one who answered the door. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
75-3is 
08-80736-CV-MARRA 
001281 
EFTA00799710
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nsor & Associates 
Rapartino nail Triaratiptico, 
Page 50 
1 
Q. 
Why did the meeting take place ata 
2 
'l
ouse? 
3 
A. 
I spent the night that night at her house. 
4 
Q. 
And when was this? 
5 
A. 
A while ago. 
6 
Q. 
How long ago? 
7 
A. 
A month and a half ago. I'm guessing. 
8 
Q. 
A month and a half ago? 
9 
A. 
Uh-huh. 
10 
Q. 
So was it before of after Mr. Herman filed 
11 
the fifty-million-dollar lawsuit against Epstein? 
12 
A. 
After. 
13 
Q. 
Did you meet with an FBI agent named 
14 
Nesbitt Kurkendall, a woman? 
15 
A. 
I don't know. 
16 
Q. 
Did Ms. Kurkendall speak to you about 
17 
getting reimbursed from Mr. Epstein? 
18 
A. 
I've never had a discussion with anyone 
19 
about getting reimbursed from Mr. Epstein. 
20 
Q. 
Have you met with an agent named Jason 
21 
Richards? 
22 
A. 
Not to my knowledge. 
23 
Q. 
How about an agent named Tim Slater? 
24 
A. 
No, sir. 
25 
Q. 
How about an agent named Junior Ortiz? 
MAIN 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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nsor & Associates 
Report' ng and Trassati Nino, Inc. 
Page 51 
1 
A. 
No. 
2 
Q. 
And we've learned that many of the girls, 
3 
some of whom are as old as 23, were told by the 
4 
government that they would get money at the end of the 
5 
criminal prosecution. Does that sound familiar to you?' 
6 
A. 
No, sir. 
7 
Q. 
Other than Mr. Leopold here -- I'm not 
8 
asking about Mr. Herman either 
9 
A. 
Oh-huh. 
10 
Q. 
-- did anyone ever discuss with you that 
11 
you could get reimbursement for your damages? 
12 
A. 
No, sir. 
13 
Q. 
Did you or any member --
14 
MR. LEOPOLD: Are you referring to a 
15 
criminal matter or a civil matter? 
16 
BY MR. TEIN: 
17 
Q. 
Did you or any member --
18 
MR. LEOPOLD: Excuse me. Let me object to 
19 
the form of the question. 
20 
BY MR. TEIN: 
21 
Q. 
Did you or any member of your family ever 
22 
get a victim notification letter from anyone? 
23 
A. 
I no longer live at that residence and 
24 
wouldn't know. 
25 
Q. 
So your testimony is that you have never 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
nom 
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sor & Associates 
Itoponiojt Ana 1 ranntiPier., 'kg • 
Page 78 of 100 
8 
or law enforcement in this case? 
letter, correct? 
rgpAwvtd a victim notification letter, correct? 
Q. 
Have you given any evidence to prosecutors 
Q. 
Correct. 
And your testimony is that you don't know 
rect. 
3 
Page 52 
1 
2 
4 
if your parents have ever received a victim notification 
5 
6 
A. 
7 
9 
A. 
What do you mean by evidence? 
10 
Q. 
Well. Anything that you can touch or feel. 
11 
A. 
No. 
12 
MR. LEOPOLD: Objection to the form of the 
13 
question. 
14 
BY MR. TEIN: 
15 
Q. 
So you haven't given anything physical 
16 
A. 
No. 
17 
Q. 
-- any item to any prosecutor, police 
18 . 
officer or law enforcement agent, correct? 
19 
A. 
My cell phone four years ago or three years 
20 
ago, but that's it. 
21 
Q. 
You gave your cell phone to whom? 
22 
A. 
Pagan. 
23 
Q. 
Did she keep it? 
24 
A. 
Ask her. 
25 
Q. 
You gave it to her and then you didn't get 
71 0131. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvrt)84Oa3g@v_Wfam Beach, FL 33401 
001284 
EFTA00799713
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Page 79 of 100 
sor & Associates 
• 
Romomn, 
aid TransctIptiall. Inc.
• - • 
nets* 
Page 53 
1 
it back at the end of the meeting? 
2 
A. 
No. They -- yeah. No. They have it. I'm 
3 
guessing. I don't have it. 
4 
Q. 
How much money are you hoping to get out Of 
5 
Mr. Epstein? 
6 
MR. LEOPOLD: Objection to the form of the 
7 
question. Attorney/client privilege. 
8 
BY MR. TEIN: 
9 
Q. 
How much money arc you hoping to get, you, 
10 
yourself, hoping to get out of Epstein? 
11 
MR. LEOPOLD: Same. Same objection, 
12 
attorney/client privilege. 
13 
Don't answer the question. 
14 
BY MR. TEIN: 
15 
Q. 
I'm not asking about what your lawyer told 
16 
you. 
17 
MR. LEOPOLD: I'm instructing her not to 
18 
answer the question, because any of those 
19 
conversations involve her counsel. 
20 
MR. TEIN: Certify that. 
21 
MR. LEOPOLD: Please. 
22 
 
 CERTIFIED QUESTION 
23 
BY MR. TEIN: 
24 
Q. 
Now, 
you lied to get out of this 
25 
deposition, didn't you? 
Ph. 561.682.0905 - Fax. 561.682.1771 
. 
1655 Palm Beath Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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001285 
EFTA00799714
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50 el MI 
Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
Page8001100 
*nsor & Associates 
Roprming and Transcription. Inc 
1 
A. 
No, sir. 
Page 54 
2 
Q. 
You didn't want to come to court today and 
3 
tell the story that you had told to the police under 
4 
oath, did you? 
5 
MR. LEOPOLD: Object to the form of the 
6 
question. Lack of foundation, predicate. 
7 
THE WITNESS: No. I have no problem coming 
8 
here and talking to you. 
9 
BY MR. TEIN: 
10 
Q. 
And to avoid getting served with a lawful 
11 
subpoena, you lied about your name, didn't you? 
12 
A. 
No. 
13 
Q. 
And in fact, just lying yourself wasn't 
14 
enough, was it? 
15 
MR. LEOPOLD: Objection to the form of the 
16 
question. 
17 
Don't answer it. It's not a question. 
18 
object. to the form of the question. Lack 
19 
of foundation. 
20 
MR. TEIN: Are you instructing her not to 
21 
answer? 
22 
MR. LEOPOLD: I am. 
L3 
MR. TEIN: Certify it. 
24 
MR. LEOPOLD: Please. 
25 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
08-80736-CV-MARRA 
001286 
EFTA00799715
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*nsor & Associates 
koportins and Transcription, Inc. 
Page 55 
1 
 
CERTIFIED QUESTION 
2 
BY MR. TEIN: 
3 
Q. 
You asked your co-workers 
4 
MR. LEOPOLD: It's vague and ambiguous. 
5 
BY MR. TEIN: 
6 
Q. 
You asked your co-workers at the 
7 
Quarterdeck 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 friendillillippto 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 
1$ 
came with the papers. 
19 
MR. TEIN: Will you put up Exhibit 18-001? 
20 
MR. GOLDBERGER: And mark 18-001 for 
21 
identification purposes to this deposition. 
22 
MR. LEOPOLD: None of them have been marked 
It ot 314 
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 
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. 
ni
1sor & Associates 
Ropo
ng nad Transcngdon Inc 
Page 56 
1 
has been marked for identification yet. 
2 
BY MR. TEIN: 
3 
Q. 
--
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. va 
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. la 
right? 
23 
A. 
Yes. 
24 
Q. 
your friend at the 
25 
Quarterdeck Tavern, right? 
Ph. 561.682.0905 - Fax. 561.682.1771 
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001288 
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11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
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nsor & Associates 
Reporting nil TraliSCriplson.1M. 
1 
A. 
Yes. 
Page 57 
2 
Q. anour 
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 
her name tag, correct? 
9 
A. 
Yes. 
Q. 
Your testimony under oath is that's just a 
coincidence, right? 
A. 
Total honesty. 
Q. 
It just happens to be the day that you were 
going to be served with a subpoena, correct? 
A. 
That wasn't the first day that --
MR. LEOPOLD: 
just answer the 
question. It calls for a yes or no. 
THE WITNESS: Yes. 
BY MR. TEIN: 
Q. 
You said that wasn't the first day you were 
going to be -- you thought you were being served with a 
subpoena, correct? 
Oaf 1S 
23 
A. 
Correct. 
24 
Q. 
You knew before the day that you switched 
25 
name tags with 
that the process servers were 
Ph. 561.682.0905 - Fax. 561.682,1771 
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sor & Associates 
.
1
Roponins and 1'ranscrlN•lne, inc. 
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. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
08-80736-CV-MARRA 
001290 
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nsor & Associates 
Repletion? and Transcdpoon. 
Page 59 
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MR. LEOPOLD: I'll certify it. 
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CERTIFIED QUESTION 
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She's answered that question. She's explained it five 
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tines already. The fact that Counsel doesn't like the 
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answer, that's a different query. 
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MR. TEIN: Stop making speaking objections. 
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MR. LEOPOLD: I'm not. I'm not going to 
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put up with it, because it's in appropriate, Jack, 
and you know it. I will not allow Counsel to 
berate a witness, whether it's in a criminal case 
or a civil case, whether my client or --
MR. TEIN: Calm down. 
MR. LEOPOLD: Excuse me. 
No, I'm not going to allow it. That is not 
proper. 
MR. GOLDBERGER: Okay. 
MR. LEOPOLD: If he wants to say that she's 
lying after asking it five times and her 
explaining in great detail, he can do that. But 
I'm not going to allow her to answer, nor be 
harassed by him. It's improper. 
MR. GOLDBERGER: Okay. But your response 
23 
that Counsel doesn't like the question -- or 
24 
doesn't like the answer -- just let me finish. 
25 
MR. LEOPOLD: Absolutely. I wasn't going 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Sulte 500 - West Palm Beach, FL 33401 
08-80736-CV-MARRA 
001291 
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nsor & Associates 
'towns anti 7/ascription, Jac 
Page 60 
1401 316 
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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 --
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nsor & Associates 
Reporting 4nd Tranteriptino. Inc.. . 
II? el 311 
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Page 62 
MR. LEOPOLD: This is really big stuff that 
you're going through. But that's fine; just ask 
your question and move on. But do it one time. 
If you don't understand it, I'll let you follow 
up, but I'm not going to allow you to ask the same 
question time and again and then call her a liar. 
Just ask the question, get the answer and move to 
the next subject matter. 
MR. TEIN: Ted, I'm sitting right across 
the table from you. 
MR. LEOPOLD: Yes, sir. 
MR. TEIN: Please be quiet. Don't yell. 
MR. LEOPOLD: I will not be quiet. 
MR. TEIN: Stop yelling. 
MR. LEOPOLD: Lewis, when I'm yelling 
you'll know it. I will not --
MR. TEIN: My name is not Lewis. 
MR. LEOPOLD: I thought your first name was 
Lewis, Mr. Tein. 
MR. TEIN: You watched me for three days at 
the evidentiary hearing where you sat in the back 
of the courtroom. You should know who I am. 
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MR. LEOPOLD: Well, that's the impressibm 
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you must have made in the courtroom. 
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I will not be quiet. 
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sor & Associates 
FterinninA end Tunectipana, Inc 
Page 62 
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MR. TEIN: That's obnoxious. Stop being 
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obnoxious. It's stupid. Let's go ahead with the 
3 
questions. 
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MR. LEOPOLD: I will make the record. 
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MR. TEIN: Let's get on with the questions. 
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MR. LEOPOLD: Do you need a break? 
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(Thereupon, a recess was takeh.) 
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BY MR. TEIN: 
9 
Q. 
Okay. 'WAIF 
after you told your manager 
10 
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at the Quarterdeck Tavern everything that was going on 
and he told you he would help you any way he could, he 
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hid you in the kitchen from the process servers, correct? 
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A. 
Incorrect. 
14 
Q. 
Isn't it true that lying to avoid service 
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is a meaningless lie to you,
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A. 
Incorrect. 
17 
Q. 
What is your manager's name? 
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A. 
I have three. Would you like to know 
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all --
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Q. 
Who's the one who lied for you? 
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A. 
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Q. 
And what did 
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. 
of3111 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
08-80736-CV-MARRA 
001294 
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$nsor & Associates 
Ropnaing and Trascripcion. inc. 
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you? 
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Page 63 
Q. 
Where were you when IIIIII,told this 
someone that you were not at the Quarterdeck Tavern? 
A. 
Eating nachos. 
Q. 
At the Quarterdeck Tavern? 
A. 
Yes. 
Q. 
What did you do so that IIIIIIPwould lie to 
the process servers for you? 
A. 
Nothing. 
Q. 
You just got him to lie for you, didn't 
A. 
No. I had no influence on him saying I 
wasn't there. 
Q. 
He took that upon himself? 
Isn't it true that Mr. Epstein's process 
servers had to ask the police to get you out of the 
restaurant so that they could serve you? 
MR. LEOPOLD: Objection. Lack of 
foundation, predicate. 
BY MR. TEIN: 
Q. 
You can answer the question. 
MR. LEOPOLD: If you know. Don't guess. 
TEE WITNESS: No. Can you repeat the 
00 of 315 
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question? 
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MR. TEIN: Don't coach. 
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MR. LEOPOLD: Don't guess. 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
08-80736-CV-MARRA 
001295 
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