EFTA00230786

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 14 of 100 
Here, Jane Doe cannot assert a cause of action for "violation of Chapter 800, 
Florida Statutes" (Am. Compl. ¶ 18) because there is no private right of action 
under that Chapter. See generally Am. Home Assurance Co. v. Plaza Materials 
Corp., 908 So. 2d 360, 374 (Fla. 2005) (observing that "not every statutory 
violation carries a civil remedy" (citing Villazon v. Prudential Health Care Plan, 
Inc. 843 So. 2d 842, 852 (Fla. 2003))). See also, e.g., Miami Herald Publ'g Co. v. 
Ferre, 636 F. Stipp. 970 (S.D. Fla. 1985) (King, C.J.) (holding that violation of 
Florida's criminal extortion statute does not give rise to a civil cause of action for 
damages); Mantooth v. Richards, 557 So. 2d 646, 646 (Ha. 4th DCA 1990) (per 
curiam) (affirming dismissal of plaintiffs claim for parental kidnapping where 
"the mentioned statutes concern only criminal violations and do not afford a civil 
remedy") (citation omitted) (emphasis added); Wright v. Yurko, 446 So. 2d 1162, 
1 165 (Ha. 5th DCA 1984) (holding that "[a]n act which does not constitute a basis 
for a cause of action against one person cannot be made the basis for a civil action 
for conspiracy"). 
In this case, Jane Doe's claim under Count H (civil conspiracy) fails because 
it derives exclusively from Count I (violation of Chapter 800, Florida Statutes). Cf 
grant of summary judgment against claim for independent conspiracy, noting that 
"lwihen the concerted acts of the defendants do not create a greater harm than if the acts 
v‘ ere committed by one person alone. then there can be no recovery"). 
14 
Lewis "rein it 
3059 GuNoAvmvt,Suirt 340.,Cccaivr Grow. FLORIDA 33133 
14 of 31$ 
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Document 1 
Entered on FLSD Docket 07/21/2008 
Page 15 of 100 
Buchanan v. Miami Herald Publ'g Co., 230 E. 2d 9, 12 (Fla. 1969) (holding that 
where Count I of the complaint had failed to state a cause of action for malicious 
prosecution, there could be no civil-conspiracy claim in Count II "based on the 
allegations of Count I"). Because the statute she expressly pleads as the basis for 
Count I, Chapter 800, Florida Statutes, provides no civil remedy, Jane Doe cannot 
prevail on Count I. Therefore, she cannot prevail on her claim for conspiracy 
(Count II) to violate Chapter 800, Florida Statutes (Count I). 
(II) The laintiff cannot prevail against nondivcrsc defendant 
on her claim for Intentional Infliction 
of Emotional Distress (IIED). 
Even if the plaintiff, for the sake of argument, can assert an IIED claim 
against Jeffrey Epstein, the plaintiff still does not have a cause of action for IIED 
against 
First, the plaintiff cannot recover damages in connection 
with her own illegal conduct; and second, the plaintiffs purported IIED claim fails 
as a matter of law. 
15 
Le.Vp:rein n. 
3059Gams Avtrout, Sun 340, COCON.J1 Gaol. 1100 D.33133 
IS of 316 
EFTA00231027

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 16 of 100 
1. 
The plaintiff seeks damages in connection with her 
own illegal conduct. 
The plaintiff concedes that she went to Jeffrey Epstein's house "to give 
Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff 
also concedes, in the guise of an allegation, that 
"brought Jane Doe 
to Epstein's mansion in Palm Beach" to help the plaintiff execute her own plan. 
(Am. Compl. ¶ 13.) Yet, the plaintiff's plan was illegal: under Florida law, it is a 
cringe "to practice massage" without a license. § 480.047, Ha. Stat. (1997). To say 
it another way, the plaintiff admits that she went to Mr. Epstein's house to commit 
a crime. 
Based on these allegations, it is clear that the plaintiff seeks damages in 
connection with her own illegal conduct; this is enough to support a finding of 
fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 
n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application 
of an affirmative defense can support a finding of fraudulent joinder). This 
conclusion is supported by well-established principles. 
Under Florida law, a plaintiff cannot recover damages flowing from her own 
illegal conduct. See Hall v. Hall, 93 Fla. 709, 112 So. 622, 628 (1927) (referring to 
"the universal rule of our law that one in a court of justice cannot complain . . . of 
another's wrong whereof he was a partaker") (internal quotation marks and citation 
16 
Lewis Tein,,. 
3059 Gunn Iwthui.Stalit 340. Como' i Gioia, I LOAMA 33133 
16 o1316 
EFTA00231028

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 17 of 100 
omitted) (emphasis added); Turner v. Anderson, 704 So. 2d 748, (Ha. 4th DCA 
1998) ("[N]o public policy should allow appellant to recover damages as a result of 
engaging in criminal conduct such as occurred in this case."). Cf Ewe!! v. Daggs, 
108 U.S. 143, 149 (1883) (stating that "'[n]o court will lend its aid to a [plaintiff' 
who founds [a] cause of action upon an immoral or an illegal ace") (quoting 
Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that 
this policy is "not for the sake of the defendant, but because [the courts] will not 
lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) 
(emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) 
(Harris, J., concurring) (remarking in the context of an action brought against an 
alleged prostitution house that "the court should continue its tradition of not 
interceding in civil conflicts involving transactions that are either illegal or are 
against public policy"). 
Based on the foregoing, the plaintiff cannot blame someone else ( 
) for the consequences of her own criminal conduct. Cf. Feld & Sons, Inc. 
v. Pechner, Dorfman, Wolffe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super. 
Ct. 1983) (holding that law-firm clients could not recover damages flowing from 
their own criminal acts, even though clients' lawyers had suggested the unlawful 
conduct to begin with). See also Turner v. Anderson, 704 So. 2d 748, 751 (Fla. 4th 
17 
Lewis 'rein re • 
3059 GoApAytmit,$urt 340, GXOPan Gam. ROMA 33133 
11 of 316 
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Case 9:08-cv-80804-KAM 
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Page 18 of 100 
DCA 1998) (approving reasoning in Feld & Sons, holding that "no public policy 
should allow [a plaintiff] to recover damages as a result of engaging in criminal 
conduct" where the plaintiff had provided false testimony at an arbitration 
proceeding). 
2. 
The plaintiff's IIED claim fails as a matter of law. 
To state a cause of action for TIED, a complaint must allege four elements: 
II) deliberate or reckless infliction of mental suffering; (2) outrageous conduct; (3) 
the conduct caused the emotional distress; and (4) the distress was severe. Metro. 
Life Ins. Co. v. McCarson, 467 So. 2d 277, 278 (Fla. 1985). Whether conduct is 
outrageous enough to support a claim of intentional infliction of emotional distress 
is a question of law, not a question of fact. Liberty Mut. Ins. Co. v. Steadman, 968 
So. 2d 592, 595 (Fla. 2d DCA 2007) (citations omitted). 
In this case, without reaching the question of "outrage," the plaintiff has 
failed to show that 
conduct - - allegedly arranging an illegal 
sexual massage that the plaintiff herself agreed to perform - - itself caused the 
plaintiff to suffer any emotional distress. Even if the alleged agreement was 
fraudulently induced, the plaintiff's IIED claim flows from Epstein's alleged 
conduct, not the joint conduct of 
and Doe in planning the massage. 
18 
LewfrA,Tvinn. 
3059 GaAs° Rvav E. Sun 340, (memo Glow. f 10110A 33133 
1110316 
EFTA00231030

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 19 of 100 
(iii) The plaintiff cannot prevail on her claim for civil remedies 
for criminal practices or racketeering ("civil RICO") pled in 
Count IV. 
A cause of action under section 772.104, Florida Statutes ("Civil Remedies 
for Criminal Practices") requires a showing of direct injury. Even assuming for 
the sake of argument that Jane Doe can establish that the defendants engaged in a 
"pattern of criminal activity," she cannot establish that she was directly injured by 
those activities. 
Section 772.104 allows someone to bring a civil RICO claim only if "he or 
she has been injured by reason of any RICO violation. § 772.104, Fla. Stat. 
(2007). Here, the allegations in Count IV, even if they are true, do not add up to a 
civil RICO claim because there is no proximate cause between the purported 
"pattern of criminal activity" and Jane Doe's alleged injuries. 
In a doomed attempt to satisfy the extremely high burden of pleading civil 
RICO under Florida law, the Amended Complaint lists a series of violations rooted 
in Florida's prostitution statutes. (Am. Compl. 1 31.) According to the Amended 
Complaint, the defendants participated in a criminal enterprise . . . or conspir[acyj" 
(Am. Compl. 1 30) over an unspecified length of time "to repeatedly find and 
bring [Jeffrey Epstein) underage girls . . . in order for Epstein to solicit, coerce, 
entice, compel, or force such girls in acts of prostitution and/or lewdness" (Am. 
19 
LeNtigt,Ttin n 
3059GusoAviltut,Stml 340,Cocosur Gmm, Folio. 33133 
19 of 3111 
EFTA00231031

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 20 of 100 
Compl. ¶ 32). The alleged "pattern of criminal activity" comprises violations of 
Chapter 796, Florida Statutes—the chapter that proscribes various crimes of 
prostitution.13
These allegations do not tie directly into Jane Doe's alleged psychic injuries. 
In contrast to a cognizable RICO claim, this action concerns only an isolated 
occurrence. More important, the alleged injuries in this case are pled to have 
resulted from an alleged sexual assault, an assault "in violation of Chapter 800 of 
the Florida Statutes" (Am. Compl. ¶ 18)—not anything having to do with the 
facilitation of prostitution, or more succinctly, the violation of Florida's 
prostitution law. 
Civil RICO claims are extraordinarily difficult to plead successfully. There 
are examples in the case law of RICO claims stemming from a prostitution 
enterprise, but they are vastly different from what plaintiff pleads here. They 
involve, for example, prostitutes who sued a house of prostitution (as an 
"enterprise") for inflicting systematic and repetitive abuse on them, over time. See 
Bala: v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example 
of a civil RICO claim against the operators of an alleged "house of prostitution," 
13 
The Amended Complaint alleges a "pattern of criminal activity" comprising the 
following criminal violations: §§ 796.03, 796.07(2)0), 796.07(2)(h), 796.045, and 
796.04, Fla. Stat. (Am. Comp1.1 31.) 
20 
LewAct:Csirt n. 
IDS9GUND nn SUL SUITE 340, COCONUT WOK RONDA 33133 
maw 
EFTA00231032

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 21 of 100 
where petitioners alleged that they had "suffered emotional pain, anguish, 
humiliation, insult, indignity, loss of self-esteem, inconvenience, hurt and 
emotional distress" as a result of being forced repeatedly, over time, to "perform 
sexual acts to retain their employment"). Here, even if the Amended Complaint 
can be read to plead that the defendants schemed to solicit other massages from 
other people (see, e.g., Am. Compl. ¶¶ 9, 11, 12, 32), those activities are not 
alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. 
E.I. Dupont De Nemours & Co., Inc., 881 E. 2d 565, 570 (Fla. 3d DCA 2004) 
(holding that "'indirect injuries, that is injuries sustained not as a direct result of 
predicate acts . . . will not allow recovery under Florida RICO."' (quoting 
O'Malley v. St. Thomas Univ., Inc., 599 M. 2d 999, 1000 (Fla. 3d DCA 1992))) 
(emphasis added). 
Because the Amended Complaint does not satisfy the direct-injury 
requirement under Florida's RICO law, Jane Doe has failed to allege a cause of 
action against 
for violation of section 772.103, Florida Statutes. 
B. This Notice satisfies the procedural requirements of 28 U.S.C. § 1446. 
1. This notice of removal is timely. 
In accordance with 28 U.S.C. § 1446, this notice of removal is timely. Only 
defendant Epstein has been served with process. Defendants 
and 
21 
Lewis Teinn 
3059 G.no AVIMA.SVIII 140, Comma Gwn, kola 33133 
21 M311 
EFTA00231033

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 22 of 100 
have not yet been served. In a multi-defendant lawsuit, removal is timely when 
effected within 30 days after the last defendant is served. See Hill Dermaceuticals, 
Inc. v. RX Solutions, United Health Group, Inc., No. 6:08-cv-330-Or1-31KRS, 
2008 WL 1744794, at *3 (M.D. Ha. Apr. 11, 2008) (concluding that removal 
petition was timely where it was filed within 30 days after the last defendant was 
served). 
2. Notice has been given, and state-court papers have been filed. 
In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice 
of Removal on July 18, 2008. All papers filed in State Court are attached to this 
Removal Petition. 
3. There is unanimity among the defendants. 
In accordance with 28 U.S.C. § 1446(b) the undersigned are authorized to 
represent that all of the defendants join this Petition and consent to removal. 
Conclusion 
Because this is a civil action between citizens of different states, excluding 
any fraudulently joined parties, and the amount in controversy exceeds $75,000, 
exclusive of interests and costs, this Court has original jurisdiction over this action 
pursuant to 28 U.S.C. § 1332(aX1). 
22 
Lewis Tein 
3059 GRANO Amos, Sum 340. COCONUT 69059, itos.04 33133 
22 o1318 
EFTA00231034

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 23 of 100 
WHEREFORE, the Defendants, Jeffrey Epstein, 
, and 
, remove this case from Palm Beach Circuit Court to the United States 
District Court for the Southern District of Florida. 
Respectfully submitted, 
LEWIS TEIN, P.L. 
3059 Grand Avenue, Suite 340 
Coconut Grove, Florida 33133 
Tel: 
Fax: 
• 
By: 1;4 • fdt-
GUY A. LEWIS 
Fla. Bar No. 623740 
lewis@lewistein.com 
MICHAEL R. TEIN 
Fla. Bar No. 993522 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, Florida 33401 
Tel. 
Fax. 
By: 
Jack A. Goldberger 
Fla. Bar No. 262013 
Attorneys for Defendant Jeffrey Epstein 
23 
Leal:Finn 
3059 G9550 Avow. ant 340, [atom! Gam. hors 33233 
23 01310 
EFTA00231035

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 24 of 100 
Michael R. Tein 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that the foregoing document is being served this day, 
July 18, 2008, on counsel of record identified on the service list by U.S. Mail. 
24 
Lewis. Min II. 
„•••••••• ••••A 
30S9GowoAwuw,Swlt 340,Cocomo Wow, kola 33333 
24 01315 
EFTA00231036

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 25 of 100 
Service List 
Theodore J. Leopold, Esq. 
Ricci-Leopold, P.A. 
2925 PGA Blvd., Suite 200 
Palm Beach Gardens, FL 33410 
Fax: 
Counsel for Plaintiff Jane Doe 
Douglas M. McIntosh, Esq. 
Jason A. McGrath, Esq. 
McIntosh, Sawran, Peltz & Cartaya, P.A. 
Centurion Tower 
1601 Forum Place, Suite 1110 
West Palm Beach Florida 33401 
Fax. 
Counsel for Defendant 
Bruce E. Reinhart, Esq. 
Bruce E. Reinhart, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach Florida 33401 
Fax. 
Counsel for Defendant 
Robert D. Critton, Esq. 
Michael J. Pike, Esq. 
Burman, Critton, Luttier & 
Coleman, LLP 
515 N. Flagler Drive, Suite 400 
West Palm Beach Florida 33401 
Fax. 
Co-Counsel for Jeffrey Epstein 
25 
LeVykt:11:, 
in 
VI 
3059 Gam Avi NJ,. 54411 340, COCONu I 61.0vT, :LOMA 33133 
25 of 316 
EFTA00231037

Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
Page 26 of 100 
EXHIBIT A 
24 ol 318 
EFTA00231038

Case 9:08-cv-80804-KAM 
4ti 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 27 of 100 
nsor & Associates 
Reparaap and Transcriptice, 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 2006 CF09454AXX 
STATE OF FLORIDA, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
DEPOSITION OF 
Wednesday, February 20, 2008 
2:00 p.m. - 4:30 p.m. 
Palm Beach County Courthouse 
205 North Dixie Highway 
West Palm Beach, Florida 33401 
Reported By: 
Judith F. Consor, FPR 
C 
PY 
Notary Public, State of Florida 
Consor ry Asociates Reporting and Transcription 
Phone - 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
270316 
EFTA00231039

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 28 of 100 
nsor & Associates 
Repo,.ling mid Traascii pnon. 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 
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 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
2$ al MI 
EFTA00231040

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 29 of 100 
nsor & Associates 
Repnrnnp and Transcri pan Inc 
1 
2 
WITNESS: 
INDEX 
Page 3 
PAGE: 
3 
DIRECT EXAMINATION 
4 
4 
BY MR. TEIN: 
5 
6 
7 
NOEXHIBITS 
MARKED 
8 
- 
- 
-
9 
 
CERTIFIED QUESTIONS 
10 
Page 
Line 
53 
22 
11 
55 
1 
59 
2 
12 
111 
14 
112 
2 
13 
14 
15 
16 
17 
18 
19 
20 
21
22 
23
24 
25 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
atoms 
EFTA00231041

Case 9:08-cv-80804-KAM 
1
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 30 of 100 
nsor & Associates 
Roponing and Transcription. lac.
Page 4 
1 
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 
8 
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 a 
20 
A. 
Uh-huh. 
21 
Q. 
going to ask you a few 
22 
questions, several questions today. If at any time you 
23 
wan: 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. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
30.1311 
EFTA00231042

Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
Page 31 of 100 
nsor & Associates 
ReportinE and Traoscripion. 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 
O. 
II 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 
Q. 
The contempt motion that your mother filed 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
31 of 316 
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nsor & Associates 
Reparnag and Transcii Nit°. 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 
11 
12 
A. 
Q. 
Yes, sir. 
Okay. Didn't your firefighter boyfriend 
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 
0. 
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 
have discussed moving in together? 
25 
A. 
I have been to the apartment. 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
32 al MS 
EFTA00231044

Case 9:08-cv-80804-KAM 
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nsor & Associates 
Her:multp mid lranscripom Inc 
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 
Page 7 
Q. 
Isn't your sister 
planning on living 
8 
with you and it 
9 
A. 
No. 
10 
Q. 
you know that this court case is a 
11 
criminal prosecution, correct? 
12 
A. 
Correct. 
13 
Q. 
And you know that it's a criminal 
14 
prosecution against a man who has no criminal background. 
15 
Do you know that? 
16 
A. 
I do now. 
17 
Q. 
You agree that court is a very serious 
18 
matter? 
19 
A. 
Yes. 
20 
Q. 
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. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
1101316 
EFTA00231045