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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00231917

1120 pages
Pages 261–280 / 1120
Page 261 / 1120
Case 9:08-cv-80804-KAM 
D 
Q. 
ent 1 
Entered on FLSD Docket 07/21/2006 
Page 45 of 100 
nsor & Associates 
Reporting ad Trossainakia. 
1 
2 
yours 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. 
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 
MR. LEOPOLD: No, 
Don't -- don't 
15 
let him ask you the question. 
16 
BY MR. TEIN: 
17 
O. 
What question were you asking, 
18 
19 
You ask the questions. What is the question 
20 
pending? 
21 
BY MR. TEIN: 
22 
Q. 
what is the last word on there in 
23 
the text of your message before tne ciosing? 
Int 
MR. LEOPOLD: She doesn't ask questions. 
24 
A. 
Niggaa. 
25 
Q. 
Don't you find that term offensive? 
4 
a 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4001314 
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Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 46 of 100 
sor & Associates 
Reporting and Transcript.= In 
Page 20 
1 
A. 
No. 
2 
MR. LEOPOLD: Can you spell it for the 
3 
record, please. 
4 
THE WITNESS: N-i-g-g --
5 
MR. TEIN: No, no, no. You are not going 
6 
to be asking questions. 
7 
MR. LEOPOLD: I'm not asking questions. 
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 
MR. LEOPOLD: There has been no 
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? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
MI et Ste 
EFTA00232178
Page 263 / 1120
Case 9:08-cv-80804-KAM 
entl 
EnteredonFLSpDocket07/21/2008 
Page 47 of 100 
nsor & Associates 
Reporting nil TenseOption. Inc 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 21 
1 
BY MR. TEIN: 
2 
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. 
Q. 
Because you think this deposition is stupid 
court s-h-i-t, don't you? 
A. 
No. 
Q. 
You wrote that to your friend, didn't you? 
A. 
Yes. 
Q. 
You think that court is stupid, don't you? 
A. 
In some cases. 
Q. 
And you think that court is bull s-h-i-t, 
don't you? 
A. 
No. 
Q. 
And you think this deposition is bull 
s-h-i-t, don't you? 
A. 
No. 
Q. 
You wrote that to your friend, didn't you? 
MR. LEOPOLD: Objection. Asked and 
answered. 
BY MR. TEIN: 
MR. TEIN: That's not an objection. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
470316 
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Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page48of100 
nsor & Associates 
Roponins and Trascripnna, Inc. 
Page 22 
Q. 
You wrote that to your friend, didn't you? 
2 
MR. LEOPOLD: Objection. Asked and 
3 
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. 
MR. TEIN: Then terminate the deposition if 
9 
you think it's been asked and answered. 
10 
MR. LEOPOLD: Counsel, I am not precluded 
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 
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 
MR. LEOPOLD: I won't do that. 
23 
MR. TEIN: Of course; because you want to 
24 
obstruct. 
25 
MR. LEOPOLD: All right. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4804311 
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Case 9:08-cv-80804-KAM 
t 1 
Entered on FLSD Docket 07/21/2008 
Page 49 of 100 
sor & Associates 
Reporting end Tr.uiscrtrion, 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 
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 
you 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 
— 2S--
three-Yearragerr— Gkeig 
24 
A. 
Uh -huh. 
25 
Q. 
When the police interviewed you one month 
Ph. 
- Fax. 
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40 03111 
EFTA00232181
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D u ent 1 
Entered on FLSD Docket 07/21/2008 
Page 50 of 100 
* 
16 
17 
18 
19 
! 20 
21 
22 
23 
sor &Associates 
Reanntap and Transcription,Inc 
Page 24 
1 
after you went to Epstein's house, you swore on your 
2 
mother's grave that you and Epstein did not engage in sex 
3 
of any kind? 
4 
A. 
Yes. 
5 
Q. 
Didn't you tell that to the police? 
6 
A. 
Yes. And I will continue. I have never 
7 
had sex with him. 
8 
Q. 
Did what happened upstairs at Jeff 
9 
Epstein's house take you completely by surprise,
10 
A. 
Yes. 
11 
Q. 
Now the civil complaint that you filed 
12 
against Mr. Epstein for fifty million dollars alleged 
13 
that you were totally shocked by what happened when you 
14 
got there. 
15 
A. 
Yes. 
Q. 
Were you totally shocked by what happened 
when you got to Epstein's house? 
A. 
Yes. 
O. 
You didn't expect it at all, did you? 
A. 
No. 
Q. 
You had absolutely no idea why your friend 
as taking you to Epstein's house, right? 
A. 
I was informed it was a massage. 
24 
Q. 
All you thought that it was going to be was 
25 
a massage, correct? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
510 31$ 
EFTA00232182
Page 267 / 1120
Case 9:08-cv-80804-KAM Anent1 
Entered on FLSD Docket 07/21/2008 Page 51 of 100 
sor & Associates 
Reporting and intim/1pda% loc. 
. Page 25 
1 
2 
3 
never said anything to you on the telephone about sexual 
4 
activity with Epstein, did she? 
5 
A. 
No. 
A. 
Yes. 
0. 
6 
Q. 
7 
Before you got to Epstein's house 
And before you got to Epstein's house 
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 IIIIIII? 
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 
4. 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
110714 
EFTA00232183
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Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 52 of 100 
nsor & Associates 
Rennnens and Tin/airman, lac. 
Page 26 
1 
Q. 
You're sure that -- let me ask the question 
2 
again. 
3 
You're sure that before you got to 
4 
Epstein's house no one tried to persuade you to engage in 
5 
sexual activity with Epstein for money. Are you? 
6 
MR. LEOPOLD: Objection. Asked and 
7 
answered. 
6 
THE WITNESS: No. And I've already 
9 
answered that a bazillion times. 
10 
BY MR. TEIN: 
11 
Q. 
He's coaching you now. So I'm going to ask 
12 
the question --
13 
MR. LEOPOLD: Counsel, I've made an 
14 
objection for the record. 
15 
MR. TEIN: Stop speaking. 
16 
MR. LEOPOLD: I'm not going to stop 
17 
speaking. You can't interrupt me when I'm making 
18 
the record. 
19 
MR. TEIN: You're coaching the witness. 
20 
MR. LEOPOLD: Counsel --
21 
MR. TEIN: Stop coaching the witness. 
22 
BY MR. TEIN: 
23 
Q. 
let me ask you 
24 
MR. LEOPOLD: If you continue to --
25 
MR. TEIN: Stop interrupting my questions. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
32 W3141 
EFTA00232184
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ent 1 
Entered on FLSD Docket 07/21/2008 
Page 53 of 100 
nsor & Associates 
ReportenE mend Tranutirion. Inc 
1 
2 
Page 27 
MR. LEOPOLD: If you do it one more time, 
we're leaving. 
3 
BY MR. TEIN: 
4 
0. 
5 
6 
7 
8 
9 
10 
11 
12 
S 
MR. LEOPOLD: 
I'm going to make the record. 
You cannot interrupt me when I'm making the 
record. Out of professional conduct, you cannot 
do that. I'm entitled to make the record. I made 
an objection, asked and answered. Your demeanor 
is inappropriate. You're willing and you are able 
and you're responsible to ask a question in a 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
53 of 315 
EFTA00232185
Page 270 / 1120
Case 9:08-cv-80804-KAM 
q pent 1 
EnteredonFLSDDocket07/2112008 
Page 54 of 100 
nsor & Associates 
Roparanp aac Transcrtrim, lne 
1 
Page 28 
MR. TEIN: Stop misrepresenting the record 
2 
and calm down. I'm going to ask my question. 
3 
Stop it. 
4 
BY MR. TEIN: 
5 
Q• 
MR. LEOPOLD: I think the record is very 
7 
clear. 
8 
MR. GOLDBERGER: Let me just clarify 
9 
something. When you object to the form of a 
10 
question, you're not instructing the witness not 
11 
to answer the question, are you? 
12 
MR. LEOPOLD: No. And I'm not making that 
13 
objection; only on attorney/client privilege. 
14 
MR. TEIN: Will you stop speaking now so I 
15 
can ask my question? Are you done? 
16 
Okay. I'm going to ask my question. 
17 
18 
19 
20 
21 
22 
23 
24 
25 
BY MR. TEIN: 
Q• 
Listen, IIIIII--
MR. LEOPOLD: Hold on. Stop. 
I've been doing this for 20 plus years and 
have met a lot of attorneys, but I've never had an 
experience like this where I've 
MR. TEIN: Stop your speeches. 
MR. LEOPOLD: If you continue to do this, 
whether it's with me or with my client, I will not 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd.; Suite 500 - West Palm Beach, FL 33401 
S4 of 3101 
EFTA00232186
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Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 55 of 100 
nsor & Associates 
Reporting ad Trans< nfrtion. 
Page 29 
1 
2 
3 
Mr. Goldberger knows all this, because I know that 
4 
he wouldn't do this. So I will not put up with 
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 
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. 
put up with it and I don't need to put up with it 
and it's not appropriate. And I'm sure 
MR. LEOPOLD: So long as you act 
MR. VEIN: Suit yourself. 
23 
THE WITNESS: I'm sure. 
24 
BY YR. TEIN: 
25 
0. 
Let me ask you a few questions about your 
Ph. 
- Fax. 
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55 of SIO 
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ent 1 
Entered on FLSD Docket 07/21/2008 
Page 56 of 100 
nsor & Associates 
Roponini 
ranscrip:u co. Inc. 
Page 30 
1 
contact with Jeffrey Epstein. Okay? 
2 
A. 
(Witness nods head up and down.) 
3 
Q. 
Jeff never e-mailed you, did he? 
4 
A. 
No. 
5 
Q. 
Jeff never text messaged you, did he? 
6 
A. 
No. 
7 
Q. 
Jeff never chatted in a chat room with you, 
8 
did he? 
9 
A. 
No. 
10 
Q. 
Before you got to Epstein's house you had 
11 
never spoken to Jeff, had you? 
12 
A. 
No. 
13 
Q. 
And before you got to Epstein's house you 
14 
had never met Jeff? 
15 
A. 
Correct. 
16 
Q. 
Before you got to Epstein's house you had 
17 
never told Jeff that you were under 18, right? 
18 
A. 
No. 
19 
Q. 
Before you got to Epstein's house had you 
20 
ever told Jeffrey that you were under 18? 
21 
A. 
No. I never spoke to the man before that. 
22 
Q. 
And you only went to Jeff Epstein's house 
23 
that one time three years ago, correct? 
24 
A. 
Yes. 
25 
Q. 
You never went there again, correct? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
Seat Sit 
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p 
ent1 
Entered on FLSD Docket 07/21/2008 
Page 57 of 100 
nsor & Associates 
Reporting sod Tratteriptra, 
1 
2 
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 
A. 
No. 
Page 31 
Q. 
All right. Let me ask you two final areas 
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. 
MN 
who told you that when you got to 
17 
Jeff Epstein's house you should lie to Jeff about your 
18 
age? 
19 
A. 
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. 
3 
O. 
Who was the other girl in the car with you 
24 
that day? 
25 
A. 
I honestly don't know. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
sr a SUP 
EFTA00232189
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merit 1 
Entered on FLSD Docket 07/21/2008 
Page 58 of 100 
n5Or & Associates 
Reporting ad Traatiptien. lac. 
Page 32 
1 
Q. 
Had you ever seen her before? 
2 
A. 
No, sir. 
3 
Q. 
You told the police that when you rode over 
4 
to Epstein's you had no idea who she was, right? 
5 
A. 
Correct. 
6 
Q. 
You told the police that you didn't know 
7 
her name, but she was like really dark, kind of like a 
8 
Spanish girl? 
9 
A. 
Yes. 
10 
Q. 
Those were your words, right? 
11 
A. 
Yes. 
12 
Q. 
Do you now know who she is? 
13 
A. 
No, sir. 
14 
0. 
So it was Illillwho told you to lie about 
15 
your age to Jeff Epstein? 
16 
A. 
Yes, sir. 
17 
Q. 
And IIII told you that if you weren't 18, 
18 
Epstein wouldn't let you into his house, right? 
19 
A. 
That's -- yes, yes. 
20 
Q. 
All right. Let's talk for a minute about 
21 
when you first met Jeff. Okay? 
22 
A. 
Sure. 
23 
Q. 
When you first met Jeff he tried to find 
24 
out how old you were, right? 
25 
A. 
Excuse me? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
51cAlIll 
EFTA00232190
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ent 1 
Entered on FLSD Docket 07/21/2008 
Page 59 of 100 
nsor & Associates 
Reportinp /ad Tunic apron, lnc. 
Page 33 
1 
Q. 
When you first met Jeff he tried to find 
2 
out how old you were, right? 
3 
A. 
Not when we first introduced each other; 
4 
when we get upstairs, then, yes. 
5 
Q. 
During the massage Jeff asked you how old 
6 
you were, correct? 
7 
A. 
Yes, yes. 
8 
Q. 
Now hadn't you already told Jeff's 
9 
ass:stant, the one who walked you upstairs, that you went 
10 
to college and had just moved down here from Ohio? 
11 
A. 
I never spoke to the lady. 
12 
Q. 
Do you want to rethink that answer? 
13 
MR. LEOPOLD: Is that a question? 
14 
BY MR. TEIN: 
15 
Q. 
Do you want to rethink that answer? 
16 
A. 
No. I didn't really speak with her that 
17 
much. 
18 
Q. 
Do you want to try to refresh your memory 
19 
on that? 
20 
MR. LEOPOLD: Do you have something to 
21 
refresh her memory with? 
22 
MR. TEIN: Do you want to stop making 
23 
speaking objections? 
24 
MR. LEOPOLD: No. But to refresh someone's 
25 
memory, you show them a document. 
Ph. 
- Fax. 
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St of 316 
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0 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 60 of 100 
nsor & Associates 
Reparunp Dad Transcriputo. 
Page 34 
1 
MR. TEIN: I know how to do this. 
2 
MR. LEOPOLD: Then show her a document. 
3 
MR. TEIN: Stop speaking. 
4 
MR. LEOPOLD: I'm not going to stop 
5 
speaking. I'm going to continue to make the 
6 
record. 
7 
MR. TEIN: You're obstructing. Please 
8 
stop. 
9 
MR. LEOPOLD: I'm not obstructing. But if 
10 
you want to refresh her recollection, you need to 
11 
show her something. 
12 
That's not a proper question. I object to 
13 
the foundation and the predicate of that question. 
14 
MR. TEIN: Are you done? 
15 
MR. LEOPOLD: I am now. Thank you. 
16 
BY MR. TEIN: 
17 
Q. 
Do you want to try to refresh your memory 
18 
as to whether you had any conversation with the woman who 
19 
walked you upstairs in Epstein's house in which you told 
20 
her that you went to college and had just moved down from 
21 
Ohio? 
22 
MR. LEOPOLD: Objection. Object to the 
23 
form of the question. Lack of foundation and 
24 
predicate. 
25 
BY MR. TEIN: 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
GO a/ 31f 
EFTA00232192
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ent 1 
teradonFLSCOocket07/21/2008 
Page 61 of 100 
nsor 
Associates 
Roaming and Trassansuice, lac 
Page 35 
2 
3 
4 
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 --
Q. 
You can answer the question. 
A. 
Sure. 
Q. 
Is there anything that would refresh your 
B 
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 
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 exa 
24 
do remember telling her I told him I was 18. 
25 
Q. 
And do you remember telling Detective Pagan 
Ph. 
- Fax. 
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1 
that when you lied to Epstein about your age that you 
2 
said it really fast so Epstein wouldn't realize you were 
3 
lyLng? 
4 
A. 
No, I don't remember saying those words 
5 
exactly to her. I remember telling her that I told 
6 
Epstein I was 18. 
7 
O. 
Does it sound right to you that you told 
8 
Detective Pagan that you said your age really fast to 
9 
Epstein --
MS. BELOHLAVEK: Objection. Asked and 
11 
answered. 
12 
BY MR. TEIN: 
13 
Q. 
-- so he wouldn't think that you were 
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lying? 
15 
MR. LEOPOLD: Objection. Asked and 
16 
answered, lack of foundation, mischaracterization 
17 
of her earlier testimony. She's already answered 
18 
that question. 
19 
BY MR. TEIN: 
20 
Q. 
You can answer it. 
21 
MR. LEOPOLD: Same objection. It's been 
22 
asked and answered. 
23 
You can answer. I've made the objection. 
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THE WITNESS: I forget the question, now. 
25 
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BY MR. TEIN: 
2 
Q. 
Let me put it again. 
3 
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 WJTNESS: 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? 
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2 
A. 
Q. 
Page 38 
Yes. 
Was that the truth? 
3 
A. 
No. 
4 
Q. 
In fact, you went to 
, right? 
5 
A. 
Yes. 
6 
Q. 
So you lied to Mr. Epstein again, correct? 
7 
A. 
Yes. 
8 
Q. 
Is Wellington the college that you told 
9 
Jeff's assistant that you were attending? 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A. 
I don't remember having that conversation 
with her, so I wouldn't know if that's what I said. 
Q. 
That was a lie, though, wasn't it? 
MR. LEOPOLD: Objection to the form of the 
question, lack of foundation. You're making an 
assumption. She just answered you she can't tell 
you that. 
MR. TEIN: Speaking objection. And you 
well know that, Mr. Leopold. 
MR. LEOPOLD: She can't answer that 
question. The way you phrased that question, 
you're purposely making her not be honest in her 
testimony. She can't answer a question like that. 
She doesn't remember. So then you say, "So you 
were lying." That's improper and you know that. 
That's not a proper question. And any attorney 
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