EFTA00180294

Case 9:08-cv-80804-KAM 
that. 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 35 of 100 
nsor & Associates 
Roponus and Transcripum, Inc. 
1 
2 
3 
4 
Page 9 
MR. LEOPOLD: Lewis, we're not going to do 
MR. TEIN: My name is not Lewis. 
I'm going to finish my question. Okay? 
5 
MR. LEOPOLD: Do not answer until you hear 
6 
from me. 
7 
BY MR. TEIN: 
8 
Q. 
Other than conversations that you have had 
9 
with Mr. Leopold -- I'm not asking about that -- are you 
10 
aware that Mr. Leopold has filed a lawsuit in federal 
11 
court seeking fifty million dollars from Jeffrey Epstein 
12 
on your behalf? 
13 
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 
19 
BY MR. TEIN: 
20 
Q. 
You have no idea that Mr. Leopold filed a 
21 
fifty million-dollar lawsuit on your behalf against 
22 
Jeffrey Epstein? 
23 
MR. LEOPOLD: Same objection. 
24 
25 
discussions that you and I had. Outside of that, 
THE WITNESS: No. 
Do not answer that question if it's through 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
35 of 316 
EFTA00180374

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 37 of 100 
nsor & Associates 
Re portins soul Transcri pant Inc. 
1 
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 11 
objections. Check your rules. 
MR. LEOPOLD: Excuse me. For the record, 
Counsel asked me a question. I'll state the 
answer on the record. He asked me the question am 
I going to be answering that way throughout the 
deposition. So long as there's improper 
foundation and predicate asked by the attorney, I 
will protect my client and I make the record where 
appropriate. If counsel wishes to ask an 
appropriate worded question with the proper 
foundation and predicate, I will certainly allow 
the client to answer the question. 
MR. GOLDBERGER: Why don't you just state 
attorney/client privilege and just be done with 
it? 
MR. LEOPOLD: I want the record to be 
clear. 
MR. TEIN: You want to waste time is what 
you want to do. 
You were supposed to be here this morning 
and you totally broke the deal, the agreement that 
you had with us if your hearing got cancelled. 
But let's move on and maybe you'll stop 
obstructing this deposition. 
MR. LEOPOLD: I think the record is very 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
37 ol3111 
EFTA00180375

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 39 of 100 
nsor & Associates 
Ramming! and Transcripann. Inc 
Page 13 
1 
2 
behalf against Jeffrey Epstein, yes or no? 
3 
4 
5 
6 
7 
6 
9 
10 
11 
12 
13 
and I have had, do not answer the question. 
14 
And I think that it might be appropriate, 
15 
for the record, to ask questions via III" 
16 
opposed to NWI 
think that 
17 
would be more appropriate for this deposition. 
18 
BY MR. TEIN: 
19 
Q. 
Go ahead. Please answer yes or no. 
20 
A. 
Yes. 
21 
Q. 
Thank you. 
22 
23 
press conference after he filed the fifty-million-dollar 
24 
lawsuit on your behalf, don't you? 
25 
A. 
After it happened. 
an attorney, filed a fifty-million-dollar lawsuit on your 
MR. LEOPOLD: Same objection. 
MR. 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 
In fact, you know that Mr. Herman held a 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
76 o1316 
EFTA00180376

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 41 of 100 
nsor & Associates 
Re periling end Transcription, inc. 
Page 15 
1 
2 
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 
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 
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 
G3 
me, we're going to cancel this deposition 
24 
25 
MR. LEOPOLD: We're going to leave or we're 
going to take a break, because his demeanor is not 
MR. LEOPOLD: She -- her job is very 
I don't think it is appropriate, especially 
MR. LEOPOLD: If you're going to interrupt 
MR. TEIN: Stop misrepresenting. 
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 of 310 
EFTA00180377

Case 9:08-cv-80804-KAM 
nt 1 
EnteredonFLSpDocket07/21/2008 
Page 43 of 100 
nsor & Associates 
Kupanias and Transcriptirm, 
Page 17 
1 
You were supposed to be here at nine a.m.; 
2 
it's now after two. Take your break and come 
3 
back. 
4 
MR. LEOPOLD: Okay. If the demeanor keeps 
5 
up, we will not be here beyond those five minutes. 
6 
MR. TEIN: Take your break and come back. 
7 
MR, LEOPOLD: Okay. So I suggest that you 
8 
relax. 
9 
MR. TEIN: I suggest that you take your 
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 
BY MR. TEIN: 
19 
R. 111. 
you agree that giving testimony 
20 
today at your deposition is something very serious, don't 
21 
you? 
22 
A. 
Yes. 
23 
Q. 
And you respect the court, don'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 
4301316 
EFTA00180378

Case 9:08-cv-80804-KAM 
p. 
Q. 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 45 of 100 
nsor & Associates 
RolortinpamITranscrimitm,Im. 
1 
2 
yoirs on MySpace? 
3 
A. 
Sure, yes. 
Page 19 
Did you send that message to a friend of 
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. 
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 
MR. LEOPOLD: No, ow 
Don't -- don't 
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. 
'hat 
is the last word on there in 
23 
the text of your message before the closing? 
24 
A. 
Niggaa. 
25 
Q. 
Don't you find that term offensive? 
What word did you use in there? 
• 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4$ of aie 
EFTA00180379

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 47 of 100 
nsor & Associates 
Roportins and Traescriptinn. Inc 
1 
BY MR. TEIN: 
2 
Page 21 
Q. 
Let me ask you, _did 
you in fact 
3 
write your friend this message about this deposition? 
4 
A. 
Yes. 
5 
Q. 
So you wrote your friend 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 
O. 
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. 
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: 
And you think this deposition is bull 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
47 41314 
EFTA00180380

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 49 of 100 
nsor & Associates 
Roponing End Transoriptinn, Inc. 
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 
6 
MySpace last week, didn't you? 
7 
MR. LEOPOLD: Objection. Asked and 
8 
answered. 
9 
THE WITNESS: No, I did not. 
10 
BY MR. TEIN: 
11 
Q. 
You didn't write this exhibit? 
12 
A. 
I wrote that, but I didn't write what you 
13 
said. 
14 
Q. 
You wrote in this exhibit, "I got some 
15 
stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 
16 
yot write that? 
17 
A. 
Yes. 
18 
Q. 
Referring to this deposition, didn't you? 
19 
A. 
Referring to the court. I was• later 
20 
informed that it was a deposition. 
21 
Q. 
I'm going to ask you some questions now 
22 
about what happened when you went to Jeff Epstein's house 
23 
three years ago. Okay? 
24 
A. 
Oh-huh. 
25 
Q. 
When the police interviewed you one month 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
49 of 316 
EFTA00180381

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 51 of 100 
nsor & Associates 
Ropnnins soul Tunictipcian, Inc. 
1 
2 
A. 
Yes. 
Q. 
Before you got to Epstein's house 
Page 25 
3 
never said anything to you on the telephone about sexual 
4 
activity with Epstein, did she? 
5 
A. 
No. 
6 
Q. 
And before you got to Epstein's house 
7 
never sent you a message over the Internet about 
8 
sexual activity with Epstein, did she? 
9 
A. 
No. 
- 10 
Q. 
Did 
ever try to convince you to 
11 
engage in any sexual activity with Epstein? 
12 
A. 
No. 
13 
Q. 
Did 
every try to convince 
14 
you to engage in any sexual activity with Epstein? 
15 
A. 
I don't know who 
is. 
16 
Q. 
Do you have a friend 
17 
A. 
No. 
18 
Q. 
Okay. Before you went so Epstein's house 
19 
did anyone call or e-mail you to induce you to engage in 
20 
sexual activity with Epstein? 
21 
A. 
No. 
22 
Q. 
So you're sure that before you got to 
23 
Epstein's house no one tried to persuade you to engage in 
24 
sexual activity with Jeffrey Epstein? 
25 
A. 
No. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
61 of 318 
EFTA00180382

Case 9:08-cv-80804-KAM 
QpJ,n3 ent 1 
Entered on FLSD Docket 07/21/2008 
Page 53 of 100 
nsor & Associates 
Rept-tromp and Transcript' no. lnc 
1 
2 
3 
BY MR. TEIN: 
4 
Q. 
5 
Page 27 
MR. LEOPOLD: If you do it one more time, 
we're leaving. 
WI! 
MR. LEOPOLD: I'm going to make the record. 
6 
You cannot interrupt me when I'm making the 
7 
record. Out of professional conduct, you cannot 
8 
do that. I'm entitled to make the record. I made 
9 
an objection, asked and answered. Your demeanor 
10 
is inappropriate. You're willing and you are able 
11 
and you're responsible to ask a question in a 
12 
professional manner, and ask the question and once 
13 
you get the answer, to either follow up on it or 
14 
move on, but not continuously browbeat and ask the 
15 
same question over and over because you don't like 
16 
the answer. 
17 
MR. TEIN: Calm down, sir. 
18 
MR. LEOPOLD: Trust me, I'm very calm here. 
19 
When I'm not calm, you'll know it. I'm very calm. 
20 
So please continue on. But I will not 
21 
allow you to continue to harass her in the 
22 
demeanor that you're doing. Ask her a question 
23 
and move on. 
24 
MR. TEIN: Are you done? 
25 
MR. LEOPOLD: Thank you. i am. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
53 04 316 
EFTA00180383

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 55 of 100 
nsor & Associates 
Roaming and Transcription. Inc. 
Page 29 
1 
2 
3 
Mr. Goldberger knows all this, because I know that 
4 
5 
it. And I think it's highly inappropriate to do 
6 
this with this child sitting here, the way you're 
7 
acting, primarily towards me, and I will not put 
8 
up with it. 
9 
MR. TEIN: Will you please stop your speech 
10 
so I can ask questions? 
11 
MR. LEOPOLD: So long as you act 
12 
professionally, I will do so. But if you continue 
13 
to do it this way, I will leave. 
14 
15 
BY MR. TEIN: 
16 
Q. 
are you sure that before you got to 
17 
Epstein's house no one tried to persuade you to engage in 
18 
sexual activity with Epstein for money? 
19 
MR. LEOPOLD: Asked and answered. 
20 
Objection. 
21 
MR. TEIN: Did you get her answer? 
22 
THE COURT REPORTER: No, I did not. 
23 
THE WITNESS: I'm sure. 
24 
BY N.R. TEIN: 
25 
Q. 
Let me ask you a few questions about your 
put up with it and I don't need to put up with it 
and it's not appropriate. And I'm sure 
he wouldn't do this. So I will not put up with 
MR. TEIN: Suit yourself. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180384

Case 9:08-cv-80804-KAM 
Dot ment 1 
Entered on FLSD Docket 07/21/2008 
Page 57 of 100 
nsor & Associates 
Reporting and Transtii rum. Inc. 
1 
A. 
No. 
Page 31 
2 
Q. 
All right. Let me ask you two final areas 
3 
of questioning about this and we'll move onto something 
4 
else. Okay? 
5 
A. 
Uh-huh. Yes. I'm sorry. 
6 
Q. 
Before you got to Epstein's did anyone 
7 
associated with Epstein ever call you on the phone and 
8 
try to persuade, induce, entice or coerce you to engage 
9 
in any sexual activity? 
10 
A. 
No. 
11 
Q. 
Before you got to Epstein's did anybody 
12 
associated with Epstein ever contact you on the Internet 
13 
and try to persuade, induce, entice or coerce you to 
14 
engage in any sexual activity? 
15 
A. 
No. 
16 
Q. 
IIIII 
who told you that when you got to 
17 
Jeff Epstein's house you should lie to Jeff about your 
18 
age? 
19 
A. 
IIIIIIIIVAlli 
20 
Q. 
Was it 
or was it the other girl in 
21 
the car who you rode over with to Epstein's house? 
22 
A. 
23 
Q. 
Who was the other girl in the car with you 
24 
that day? 
25 
A. 
I honestly don't know. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
57 01 715 
EFTA00180385

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 59 of 100 
nsor & Associates 
Roportinp. and Tranicripoon, Inc. 
1 
2 
3 
4 
Page 33 
Q. 
When you first met Jeff he tried to find 
out how old you were, right? 
A. 
Not when we first introduced each other; 
when we get upstairs, then, yes. 
5 
Q. 
6 
you were, correct? 
7 
8 
Q. 
9 
ass:.stant, the one who walked you upstairs, that you went 
10 
to college and had just moved down here from Ohio? 
11 
12 
13 
14 
BY MR. TEIN: 
15 
R. 
Do you want to rethink that answer? 
16 
A. 
No. I didn't really speak with her that 
17 
much. 
18 
Q. 
19 
on that? 
20 
21 
22 
23 
24 
25 
During the massage Jeff asked you how old 
A. 
Yes, yes. 
Now hadn't you already told Jeff's 
A. 
I never spoke to the lady. 
Do you want to rethink that answer? 
MR. LEOPOLD: Is that a question? 
Do you want to try to refresh your memory 
MR. LEOPOLD: Do you have something to 
refresh her memory with? 
MR. TEIN: Do you want to stop making 
speaking objections? 
MR. LEOPOLD: No. But to refresh someone's 
memory, you show them a document. 
Ph. 561.682.0905 - Fax. 561.682,1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
61a1316 
EFTA00180386

Case 9:08-cv-80804-KAM 
Q. 
A. 
entl 
tereclonFLSDOocket07/21/2008 
Page 61 of 100 
nsor 
Associates 
Reporting and Transoriptinn, Inr 
1 
2 
3 
4 
Q• 
Page 35 
You can answer the question. 
Sure. 
Is there anything that would refresh your 
memory that in fact you told Mr. Epstein's assistant, the 
5 
one who walked you upstairs, that you went to college and 
6 
you had just moved down here from Ohio? 
7 
A. 
I don't remember saying that, but if you --
8 
I don't remember saying that myself, so --
9 
Q. 
That would be a lie, right? 
10 
A. 
No. I really don't remember. 
11 
Q. 
So you told Jeff that you were 18 years 
12 
old, correct? 
13 
A. 
Yes. 
14 
Q. 
Do you remember Detective Michelle Pagan of 
15 
the Police Department, Palm Beach Police Department? 
16 
A. 
Yes. 
17 
Q. 
Do you remember you spoke to her? 
18 
A. 
Yes. 
19 
Q. 
Do you remember that you told Detective 
20 
Pagan that when you lied about your age to Jeff you said 
21 
it really fast because you didn't want to make it sound 
22 
like you were lying? 
23 
A. 
I don't remember the words exactly, but I 
24 
do remember telling her I told him I was 18. 
25 
Q. 
And do you remember telling Detective Pagan 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
61 of 016 
EFTA00180387

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 63 of 100 
nsor & Associates 
Reportuip. boil Transorivion. 
1 
BY MR. TEIN: 
2 
3 
Q. 
Page 37 
Let me put it again. 
Does it sound right to you that you told 
4 
Detective Pagan that when you lied about your age to 
5 
Jeffrey Epstein, you said it really fast because you 
6 
didn't want to make it sound like you were lying? 
7 
MR. LEOPOLD: Objection. Lack of 
8 
foundation, asked and answered. 
9 
THE WITNESS: I could have possibly said 
10 
that, yes. 
11 
BY MR. TEIN: 
12 
Q. 
You didn't want Mr. Epstein to know that 
13 
you were lying about your age, right? 
14 
A. 
Correct. 
15 
Q. 
You didn't want Mr. Epstein to know that 
16 
you were not 18 yet, right? 
17 
A. 
Correct. 
18 
Q. 
You wanted Mr. Epstein to believe that you 
19 
really were 18, right? 
20 
A. 
Correct. 
21 
Q. 
Do you remember when Mr. Epstein asked 
22 
where you went to school? 
23 
A. 
Yes. 
24 
Q. 
And you told Mr. Epstein you went to 
25 
Wellington, right? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
63of 616 
EFTA00180388

Case 9:08-cv-80804-KAM 
D c ment 1 
Entered on FLSD Docket 07/21/2008 
Page 65 of 100 
o
n
sor & Associates 
Reporting hagl "[FantodO0T. Inc.
2 
3 
4 
Page 39 
that would do that to a witnesses or to a person 
that's sitting in this chair is not acting 
professionally. You can't ask a question like 
that. You can do it, but it's not proper. And 
5 
I'm sure you weren't trained that way, certainly 
6 
not ethically. 
7 
MR. TEIN: Will you stop? 
6 
MR. LEOPOLD: I'm not going to stop, 
9 
because the way you're asking that question is 
10 
improper and you know it. 
11 
MR. TEIN: You're losing your cool. 
12 
BY MR. TEIN: 
13 
Q. 
Ms. .= 
14 
MR. LEOPOLD: Trust me. I'm very calm. 
15 
When I lose my cool, you'll know it. 
16 
MR. TEIN: I do know it. 
17 
BY MR. TEIN: 
18 
Q. 
Ms. IIIIIII/ Mr. Epstein never asked you 
19 
to do anything other than massage him, correct? 
20 
A. 
Incorrect; because he asked me to take off 
21 
my bra, so that would be two things he's asked me to do. 
22 
Q. 
Other than asking you to take your bra off, 
23 
Mr. Epstein never asked you to do anything with him other 
24 
than massage, correct? 
25 
MR. LEOPOLD: Objection. Foundation, 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
fl5 o1311 
EFTA00180389

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 67 of 100 
nsor & Associates 
Hopefuls mil Intnioriptinn, Inc. 
Page 41 
1 
Q. 
You told the police twice when you spoke to 
2 
Michelle Pagan that "at no time did he touch me." Didn't 
3 
you say that to the police? 
4 
A. 
Yeah. 
5 
Q. 
And you're saying that that was not fully 
6 
truthful. Is that what you're saying now? 
7 
A. 
Correct. 
8 
Q. 
And you're saying if you're not fully 
9 
truthful, that's not a lie. Correct? 
10 
A. 
You took that out of context like really 
11 
bad. I didn't mean like that. Touching my legs and 
12 
he never kept his hands to himself the entire time. 
13 
That's what I'm trying to say. 
14 
Q. 
You told the police, "At no times did he 
15 
touch me." You agree with that, correct? 
16 
A. 
No, I don't agree with that, because he did 
17 
touch me. 
18 
Q. 
Did you tell the police that he did not 
19 
tout') you, yes or no? 
20 
A. 
It's a possibility, but I do not remember. 
21 
Q. 
Okay. And you did not have any type of sex 
22 
with Jeff, correct? 
23 
A. 
No. 
24 
Q. 
And you did not have any type of oral sex 
25 
with Jeff, correct? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
07 of 310 
EFTA00180390

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 69 of 100 
nsor & Associates 
Rep/mina ant Transc iiptunn, inc. 
Page 43 
1 
things, but it wasn't joking about it at all. 
2 
Q. 
You joked about it, didn't you? 
3 
A. 
No. 
4 
Q. 
You said to 
that if you did this 
5 
every weekend you'd be rich, didn't you? 
6 
A. 
No. That's what Lold 
me. 
7 
Q. 
You didn't tell that to lip 
8 
MR. LEOPOLD: Objection. Asked and 
9 
answered. 
10 
THE WITNESS: No. 
11 
BY MR. TEIN: 
12 
Q. 
After you left Epstein's house you took the 
13 
money and you went shopping with IIIIIIrand the other 
14 
girl in the car, correct? 
15 
A. 
Incorrect. I didn't spend any of the 
16 
money. 
1 
Q. 
You went to Marshall's, didn't you? 
18 
A. 
I went along, yes, but I didn't --
19 
Q. 
You went shopping with them at Marshall's, 
20 
didn't you? 
21 
MR. LEOPOLD: Objection. 
22 
THE WITNESS: I guess you could say that. 
23 
MR. LEOPOLD: Objection. Lack of predicate 
24 
and foundation. Mischaracterization of earlier 
25 
testimony. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
119.1311 
EFTA00180391

Case 9:08-cv-80804-KAM 
ent 1 
EnteredonFLSODocket07/21/2008 
Page 71 of 100 
nsor & Associates 
Repaning and Topic iipti rm, Inc. 
1 
2 
3 
Page 45 
A. 
It was not this year, no. 
Q. 
Was it 2007? 
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 
7 
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 
23 
parent's? 
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 
71 of 310 
EFTA00180392

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 73 of 100 
nsor & Associates 
Roponin and Traniciiption. Inc. 
1 
2 
3 
fashion, you may answer. 
THE WITNESS: Okay. 
I wouldn't know. 
Page 47 
4 
BY MR. TEIN: 
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 
11 
is? 
12 
A. 
No, sir. 
13 
Q. 
Does it refresh your recollection that he's 
14 
15 
A. 
No. 
1 6 
O. 
That he'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 
Q. 
Without telling me any conversations that 
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 
T3 of 316 
EFTA00180393