EFTA00180294

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 28 of 100 
nsor & Associates 
Roponiap anti Transcription. inc 
Page 2 
1 
APPEARANCES: 
2 
On behalf of the State: 
3 
LANNA BELOHLAVEK, ESQ. 
ASSISTANT STATE ATTORNEY 
4 
401 North Dixie Highway 
West Palm Beach, Florida 33401 
5 
561.355.7100 
6 
On behalf of the Defendant: 
MICHAEL R. TEIN, ESQ. 
7 
KATHRYN A. MEYERS, ESQ. 
LEWIS TEIN, PL 
8 
3059 GRAND AVENUE, SUITE 340 
COCONUT GROVE, FL 33133 
9 
On behalf of the Defendant: 
10 
JACK A. GOLDBERGER, ESQ. 
ATTERBURY, GOLDBERGER & WEISS 
11 
250 AUSTRALIAN AVENUE SOUTH 
SUITE 1400 
12 
WEST PALM BEACH, FLORIDA 33401 
561.659.8300 
13 
14 
ALSO PRESENT: 
ON BEHALF OF THE WITNESS: THEODORE J. LEOPOLD, ESQ. 
15 
KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, 
LEGAL-EZE 
• 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
21 a Ni 
EFTA00180434

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 29 of 100 
nsor & Associates 
Report' ny. and lranicei piton, Inc 
1 
2 
3 
INDEX 
WITNESS: 
MN/ 
Page 3 
PAGE: 
DIRECT EXAMINATION 
4 
4 
BY MR. TEIN: 
5 
6 
7 
N0EXHIBITS 
MARKED 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
2.4 
25 
Page 
CERTIFIED QUESTIONS 
Line 
53 
22 
55 
1 
59 
2 
111 
14 
112 
2 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
29 of 310 
EFTA00180435

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 30 of 100 
nsor & Associates 
Re panIn and Tranicti pu en. 
1 
Page 4 
Deposition taken before Judith F. Consor, 
2 
Court Reporter and Notary Public in and for the State of 
3 
Florida at Large, in the above cause. 
4 
5 
Thereupon, 
6 
7 
having been first duly sworn or affirmed, was examined 
$ 
and testified as follows: 
9 
THE WITNESS: I do. 
10 
DIRECT EXAMINATION 
11 
BY MR. TEIN: 
12 
Q. 
Good afternoon. Please tell me your full 
13 
name. 
14 
A. 
15 
Q. 
And can you please spell it. 
16 
A. 
17 
18 
Q. 
Thank you. 
19 
May I call you SW 
20 
A. 
Uh-huh. 
21 
Q. 
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 
700(1,5 
EFTA00180436

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 31 of 100 
nsor & Associates 
Kopartirip end Transcription, Inc 
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 
Q. 
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. 
my uncle. 
23 
Q. 
Anyone else living there? 
24 
A. 
No. 
25 
0. 
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 
31 o1 Ore 
EFTA00180437

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 32 of 100 
nsor & Associates 
Rork-mini! And Tun/cup:ion. 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 
Q. 
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 
Q. 
Have you been to the apartment that you and 
24 
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 
32o1311 
EFTA00180438

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page33of100 
nsor & Associates 
Repining and Transcription, 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 
9 
A. 
No. 
10 
Q• us 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 
0. 
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 
33 el 316 
EFTA00180439

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 34 of 100 
nsor & Associates 
ROFORiAS API! MIMIC ription, Inc. 
Page 8 
1 
2 
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 
Q• 
MI 
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 
Q. 
You can answer the question unless 
22 
MR. LEOPOLD: Same objection. 
23 
24 
25 
MR. LEOPOLD: Let me just object. 
let me instruct you. Anything that 
MR. TEIN: Let me finish. 
MR. LEOPOLD: Excuse me. We're --
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 
34 ol 316 
EFTA00180440

Case 9:08-cv-80804-KAM 
that. 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 35 of 100 
nsor & Associates 
Ropnnine and Transco puon, Inc. 
1 
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 
Page 9 
MR. LEOPOLD: Lewis, we're not going to do 
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? 
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 
I655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
760716 
EFTA00180441

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 36 of 100 
nsor & Associates 
Reportinp and 'franc ciptioa, lac 
1 
2 
3 
4 
5 
6 
7 
8 
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10 
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16 
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Page 10 
you may answer. So do not answer that question if 
that is the only basis by which you understand 
that answer. 
THE WITNESS: No. 
BY MR. TEIN: 
Q. 
You didn't know that? 
MR. LEOPOLD: Don't answer that question. 
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'm going to state it on the 
record --
MR. TEIN: You need to stop your speaking 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
3001314 
EFTA00180442

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 37 of 100 
nsor & Associates 
Reptv:itis and TranictirKinct. Inc 
Page 11 
1 
2 
3 
Counsel asked me a question. I'll state the 
4 
answer on the record. He asked me the question am 
5 
I going to be answering that way throughout the 
6 
deposition. So long as there's improper 
7 
foundation and predicate asked by the attorney, I 
8 
will protect my client and I make the record where 
9 
appropriate. If counsel wishes to ask an 
10 
appropriate worded question with the proper 
11 
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 
MR. LEOPOLD: I want the record to be 
17 
clear. 
18 
MR. TEIN: You want to waste time is what 
19 
you want to do. 
20 
You were supposed to be here this morning 
21 
and you totally broke the deal, the agreement that 
22 
you had with us if your hearing got cancelled. 
23 
24 
obstructing this deposition. 
25 
MR. LEOPOLD: I think the record is very 
objections. Check your rules. 
MR. LEOPOLD: Excuse me. For the record, 
But let's move on and maybe you'll stop 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
31 al 314 
EFTA00180443

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 38 of 100 
nsor & Associates 
Roparung and Transcript, m. Inc 
Page 12 
1 
clear where we stand thus far. 
2 
Is there a recording taken of this 
3 
deposition? 
4 
THE COURT REPORTER: Yes. 
5 
MR. LEOPOLD: Just make sure that's 
6 
preserved. 
7 
BY MR. TEIN: 
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 
18 
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., Sulte 500 - West Palm Beach, FL 33401 
MI of 311 
EFTA00180444

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 39of100 
nsor & Associates 
Reportinp nail Tunic iiption. Inc 
Page 13 
1 
2 
behalf against Jeffrey Epstein, yes or no? 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
attorney/client privilege, any conversations you 
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 
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 
and I have had, do not answer the question. 
And I think that it might be appropriate, 
IIIII, 
for the record, to ask questions via 
WM
as opposed to OM 
I think that 
would be more appropriate for this deposition. 
A. 
After it happened. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
39 el 315 
EFTA00180445

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 40 of 100 
nsor & Associates 
Reparn np end Trans< ri pit on, Inc. 
Page 14 
1 
O. 
You know that he had a press conference, 
2 
don't you, yes or no? 
A. 
Yes. 
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: 
8 
Q. 
Have you ever seen that picture before? 
9 
A. 
Yes. 
10 
Q. 
Is that a picture of your father, your 
11 
stepmother and Mr. Berman at the press conference 
12 
regarding your lawsuit? 
13 
A. 
Yes. 
14 
Q. 
Now you know that this is a very serious 
15 
matter, don't you? 
16 
MR. LEOPOLD: Asked and answered. 
17 
Objection. 
18 
MR. GOLDBERGER: All right. You can 
19 
object. You're representing a witness here, 
20 
Mr. Leopold. You can object on privilege grounds. 
21 
You cannot make legal objections. You have no 
22 
standing to do so. 
23 
MR. LEOPOLD: I'm going to make them and 
24
then -- 
25 
MR. GOLDBERGER: We're --
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180446

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 41 of 100 
nsor & Associates 
Steraning and *Franscripluxn, Inc 
1 
2 
3 
4 
Page 15 
MR. LEOPOLD: We're going to leave or we're 
going to take a break, because his demeanor is not 
appropriate. There's no reason to have this kind 
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 
14 
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 
23 
me, we're going to cancel this deposition 
24 
25 
MR. LEOPOLD: She -- her job is very 
MR. GOLDBERGER: Off the record. 
MR. LEOPOLD: We're not going off the 
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 314 
EFTA00180447

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 42 of 100 
nsor & Associates 
Reporting and Trandcrinnon. Inc 
1 
no matter who it is. 
Page 16 
2 
MR. LEOPOLD: I think we're going to take a 
3 
break. Perhaps you might want to talk to your 
4 
co-counsel --
5 
MR. TEIN: I don't need to talk to him. 
6 
MR. LEOPOLD: But we're going to take a 
7 
break. 
8 
MR. TEIN: We're not taking a break unless 
9 
the witness needs a break. 
10 
You're obstructing this deposition, Ted. 
11 
MR. LEOPOLD: Come on, 
12 
You all want to continue in this 
13 
demeanor --
14 
MR. TEIN: You're obstructing the 
15 
deposition. Stop making speeches. We're not 
16 
discussing this with you. The questions are to 
17 
your client. Go take your five-minute break. 
18 
MR. LEOPOLD: Fine. We need to make sure 
19 
the record's clear and clean. 
20 
And I want to make sure, as I've already 
21 
asked you -- I know that you're one of the best in 
22 
town -- that this audio -- this needs to be 
23 
preserved. Okay? 
24 
MR. TEIN: Go take your five-minute break, 
25 
Mr. Leopold, now. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
42 of 314 
EFTA00180448

Case 9:08-cv-80804-KAM 
nt 1 
EnteredonFLSpDocket07/21/2008 
Page 43 of 100 
nsor & Associates 
RoponsuR and Trioscrip:inn, inc. 
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 
BY MR. TEIN: 
19 
Q. 
II,Allir 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 
MR. TEIN: Take your break and come back. 
MR. LEOPOLD: Okay. So I suggest that you 
MR. TEIN: I suggest that you take your 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
♦3 or 315 
EFTA00180449

Case 9:08-cv-80804-KAM 
nt 1 
EnteredonFLSDDocket07/21/2008 
Page 44 of 100 
sor & Associates 
RI:penis! and Tranactipann. Inc 
Page 18 
1 
read that out loud, please. 
2 
3 
Q. 
Will you read that out loud, please. 
4 
A. 
Oh. 
5 
Q. 
Thank you. 
6 
A. 
Lol hah my baddd...lol yah i got some 
7 
stupid court shit on the 20th...bullshit...and damn you 
8 
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 
Q. 
Let me finish my question. 
22 
23 
friend of yours on MySpace? 
24 
A. 
I wouldn't know the date, but obviously, 
25 
it's to a friend. 
A. 
Okay. What do you want? 
Did you send that message last week to a 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
44 of 316 
EFTA00180450

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 45 of 100 
nsor & Associates 
Reputing .and Innscripinn, Inc. 
2 
3 
4 
5 
6 
7 
Page 19 
Q. 
Did you send that message to a friend of 
yoJrs on MySpace? 
A. 
Sure, yes. 
Q. 
Were you referring to this deposition? 
A. 
Yes. 
Q. 
Do you find the term n-i-g-g-e-r offensive? 
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 
MR. LEOPOLD: She doesn't ask questions. 
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 the closing? 
24 
A. 
Niggaa. 
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 
ol 39 
EFTA00180451

Case 9:08-cv-80804-KAM 
Dp
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 46 of 100 
sor & Associates 
Rename! end Transcription, Inc 
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Page 20 
A. 
No. 
MR. LEOPOLD: Can you spell it for the 
record, please. 
THE WITNESS: N-i-g-g --
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MR. TEIN: No, no, no. You are not going 
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to be asking questions. 
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MR. LEOPOLD: I'm not asking questions. 
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I'm asking for the record the word to be spelled, 
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because we don't have a video here today. 
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MR. TEIN: These exhibits are part of the 
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record. You --
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MR. LEOPOLD: Well, it's not marked as an 
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exhibit. 
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MR. TEIN: Stop interrupting me, 
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Mr. Leopold. I have marked and identified as an 
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exhibit and you will get it. 
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MR. LEOPOLD: There has been no 
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identification of this document in the record. 
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MR. TEIN: Mr. Leopold, stop interrupting 
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this deposition. 
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MR. LEOPOLD: What is the exhibit number 
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marked for identification? 
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MR. TEIN: 31-001. 
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MR. LEOPOLD: Do we have copies? Is it on 
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the record anywhere? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180452

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 47 of 100 
nsor & Associates 
Kelton/ nR and Inaactiption. 
Page 21 
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BY MR. TEIN: 
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Q. 
Let me ask you, _did 
you in fact 
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write your friend this message about this deposition? 
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A. 
Yes. 
5 
Q. 
So you wrote your friend that this 
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deposition is stupid court s-h-i-t, correct? 
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A. 
Yes. 
8 
Q. 
Because you think this deposition is stupid 
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court s-h-i-t, don't you? 
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A. 
No. 
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Q. 
You wrote that to your friend, didn't you? 
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A. 
Yes. 
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Q. 
You think that court is stupid, don't you? 
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A. 
In some cases. 
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Q. 
And you think that court is bull s-h-i-t, 
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don't you? 
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A. 
No. 
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O. 
And you think this deposition is bull 
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s-h-i-t, don't you? 
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A. 
No. 
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Q. 
You wrote that to your friend, didn't you? 
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MR. LEOPOLD: Objection. Asked and 
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answered. 
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MR. TEIN: That's not an objection. 
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BY MR. TEIN: 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
47 o1314 
EFTA00180453