EFTA00230786

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page34of100 
nsor & Associates 
Repartinf end Transcripiina, inc. 
1 
MR. LEOPOLD: Let me just object. 
2 
3 
Page 8 
IIIIIIIIplet me instruct you. Anything that 
you have learned through conversations between you 
4 
and me are protected. II 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. 
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 
MR. TEIN: Let me finish. 
24 
MR. LEOPOLD: Excuse me. We're --
25 
MR. TEIN: No. Let me finish. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
34 ol 116 
EFTA00231046

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 35 of 100 
sor & Associates 
Roponin and Transcri rum. Inc. 
Page 9 
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MR. LEOPOLD: Lewis, we're not going to do 
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 
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 
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: 
2 0 
Q. 
21 
fifty million-dollar lawsuit on your behalf against 
22 
Jeffrey Epstein? 
that. 
you 
You have no idea that Mr. Leopold filed a 
23 
MR. LEOPOLD: Same objection. 
2,1 
Do not answer that question if it's through 
25 
discussions that you and I had. Outside of that, 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
66 o1316 
EFTA00231047

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 36 of 100 
nsor & Associates 
Reporting ad Tranxtip:inei. lac 
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Page 10 
you may answer. II 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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
Motile 
EFTA00231048

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 37 of 100 
nsor & Associates 
ReponmsrowllanwfiNum.bc 
1 
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Page 11 
objections. Check your rules. 
MR. LEOPOLD: Excuse me. For the record, 
3 
Counsel asked me a question. I'll state the 
4 
answer on the record. Be asked me the question am 
5 
I going to be answering that way throughout the 
6 
deposition. II 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 
But let's move on and maybe you'll stop 
24 
obstructing this deposition. 
25 
MR. LEOPOLD: I think the record is very 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
IT of 316 
EFTA00231049

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 38 of 100 
nsor & Associates 
Ripening and Transaiption. loc. 
1 
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clear where we stand thus far. 
Is there a recording taken of this 
deposition? 
THE COURT REPORTER: Yes. 
Page 12 
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 
thate 
are you aware that a lawyer named Jeffrey 
10 
Herman filed a lawsuit on your behalf, yes or no? 
11 
MR. LEOPOLD: Objection. 
12 
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 
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, 
Any conversations that you and I have had 
MR. LEOPOLD: I'm assuming Counsel is not 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
31 of 3i6 
EFTA00231050

Case 9:08-cv-80804-KAM 
ent 1 
EnteredonFLSIDDocket07/21/2008 
Page 39 of 100 
nsor & Associates 
Rein-min? and lransc option. Inc 
Page 13 
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an attorney, filed a fifty-million-dollar lawsuit on your 
2 
behalf against Jeffrey Epstein, yes or no? 
3 
MR. LEOPOLD: Same objection. 
4 
MR. TEIN: We've heard the objection 10 
5 
times already. 
6 
MR. LEOPOLD: Counsel, excuse me. 
7 
MR. TEIN: Just say attorney/client 
8 
privilege. Stop interrupting my questions. 
9 
MR. LEOPOLD: I'm entitled to make an 
10 
objection for the record, which I'm doing, and 
11 
I'll make the same objection. And if it calls for 
12 
attorney/client privilege, any conversations you 
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 
16 
as opposed to 11.1, 
I 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 
O. 
Thank you. 
22 
In fact, you know that Mr. Berman held a 
23 
press conference after he filed the fifty-million-dollar 
24 
lawsuit on your behalf, don't you? 
25 
A. 
After it happened. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
39 of 316 
EFTA00231051

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 40 of 100 
nsor & Associates 
Roportenp and Tanscriptinn, 
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stepmother and Mr. Herman 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 
20 
21 
You cannot make legal objections. You have no 
Page 14 
Q. 
You know that he had a press conference, 
don't you, yes or no? 
A. 
Yes. 
Q. 
In fact, let's go to Exhibit 20-01. 
MR. GOLDBERGER: Look behind you. You'll 
see it. 
BY MR. TEIN: 
Q. 
Have you ever seen that picture before? 
A. 
Yes. 
22 
23 
24 
25 
Q. 
Is that a picture of your father, your 
object. You're representing a witness here, 
Mr. Leopold. You can object on privilege grounds. 
standing to do so. 
MR. LEOPOLD: I'm going to make them and 
then --
MR. GOLDBERGER: We're --
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
40 or 314 
EFTA00231052

Case 9:08-cv-80804-KAM 
D. 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 41 of 100 
nsor & Associates 
Rc ponies and Transcription, Inc 
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 
I don't think it is appropriate, especially 
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 
MR. LEOPOLD: If you're going to interrupt 
Page 15 
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 
3 
me, we're going to cancel this deposition 
24 
MR. TEIN: Stop misrepresenting. 
25 
THE COURT REPORTER: I need one at a time, 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
41 of 314 
EFTA00231053

Case 9:08-cv-80804-KAM 
D
jent 1 
Entered on FLSD Docket 07/21/2008 
Page 42 of 100 
nsor & Associates 
Reporting and 'I ranscririon. Inc 
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Page 16 
no matter who it is 
MR. LEOPOLD: I think we're going to take a 
break. Perhaps you might want to talk to your 
co-counsel --
MR. TEIN: I don't need to talk to him. 
MR. LEOPOLD: But we're going to take a 
break. 
MR. 'FEIN: 
We're not taking a break unless 
the witness needs a break. 
You're obstructing this deposition, Ted. 
MR. LEOPOLD: Come on, 
You all want to continue in this 
demeanor --
MR. TEIN: You're obstructing the 
deposition. Stop making speeches. We're not 
discussing this with you. The questions are to 
your client. Go take your five-minute break. 
MR. LEOPOLD: Fine. We need to make sure 
the record's clear and clean. 
And I want. to make sure, as I've already 
asked you -- I know that you're one of the best in 
town -- that this audio -- this needs to be 
preserved. Okay? 
MR. TEIN: Go take your five-minute break, 
Mr. Leopold, now. 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
42 at 616 
EFTA00231054

Case 9:O8-cv-8O8O4-KAM 
nt 1 
Entered on FLSP Docket 07/21/2008 
Page 43 of 100 
nsor & Associates 
ReportivE aad Trauctipdm, lac. 
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. 
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? 
MR. TEIN: Take your break and come back. 
MR. LEOPOLD: Okay. So I suggest that you 
MR. TEIN: I suggest that you take your 
rialf
you agree that giving testimony 
24 
A. 
Yes. 
25 
0. 
Let me show you Exhibit 31-001. Can you 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
430316 
EFTA00231055

Case 9:08-cv-80804-KAM 
nt 1 
Eotterod on FLSD Docket 07/21/2008 
Page 44 of 100 
sor 
H,55OClate5 
Ropartrnp and 1 ranacri pnon. Inc. 
Page 18 
1 
read that out loud, please. 
2 
A. 
Okay. What do you want? 
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 
O. 
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 
Let me finish my question. 
22 
Did you send that message last week to a 
23 
friend of yours on MySpace? 
24 
A. 
I wouldn't know the date, but obviously, 
25 
it's to a friend. 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
44031f 
EFTA00231056

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 45 of 100 
sor & Associates 
Reponinp and Transcripaw, 
1 
2 
3 
4 
5 
6 
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Page 19 
Q. 
Did you send that message to a friend of 
yo.frs 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. 
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 
Q. 
What question were you asking, Ill? 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4501316 
EFTA00231057

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 46 of 100 
nsor & Associates 
Reportins. and Transcription, /nt 
Page 20 
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A. 
No. 
MR. LEOPOLD: Can you spell it for the 
record, please. 
THE WITNESS: N-i-g-g --
MR. TEIN: No, no, no. You are not going 
to be asking questions. 
MR. LEOPOLD: I'm not asking questions. 
I'm asking for the record the word to be spelled, 
because we don't have a video here today. 
MR. TEIN: These exhibits are part of the 
record. You --
MR. LEOPOLD: Well, it's not marked as an 
exhibit. 
MR. TEIN: Stop interrupting me, 
Mr. Leopold. I have marked and identified as an 
exhibit and you will get it. 
MR. LEOPOLD: There has been no 
identification of this document in the record. 
MR. TEIN: Mr. Leopold, stop interrupting 
this deposition. 
MR. LEOPOLD: What is the exhibit number 
marked for identification? 
MR. TEIN: 31-001. 
MR. LEOPOLD: Do we have copies? Is it on 
the record anywhere? 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
44.1311 
EFTA00231058

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 47 of 100 
nsor & Associates 
Reporting and Transcription, Inc. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
Q. 
And you think this deposition is bull 
19 
s-h-i-t, don't you? 
20 
21 
22 
Page 21 
BY MR. TEIN: 
Q. 
Let me ask you, 
did you in fact 
write your friend this message about this deposition? 
A. 
Yes. 
Q. 
So you wrote your friend that this 
deposition is stupid court s-h-i-t, correct? 
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. 
A. 
No. 
Q. 
You wrote that to your friend, didn't you? 
MR. LEOPOLD: Objection. Asked and 
23 
answered. 
24 
25 
BY MR. TEIN: 
MR. TEIN: That's not an objection. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
47 e131$ 
EFTA00231059

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page48of100 
sor & Associates 
Ropontng end Transcririon, 
1. 
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.3
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Page 22 
Q. 
You wrote that to your friend, didn't you? 
MR. LEOPOLD: Objection. Asked and 
answered, for the fourth time. 
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. 
8 
MR. TEIN: Then terminate the deposition if 
9 
you think it's been asked and answered. 
10 
N.R. 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 I 
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 
23 
MR. TEIN: Of course; because you want to 
24 
obstruct. 
25 
MR. LEOPOLD: All right. 
MR. LEOPOLD: I won't do that. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
Hot316 
EFTA00231060

Case 9:08-cv-80804-KAM 
P
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 49 of 100 
nsor & Associates 
Roporung end ITansoription. /he 
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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 
answered. 
THE WITNESS: No, I did not. 
BY MR. TEIN: 
Q. 
You didn't write this exhibit? 
A. 
I wrote that, but I didn't write what you 
13 
said. 
14 
4. 
15 
16 
you write that? 
17 
18 
19 
20 
21 
22 
about what happened when you went to Jeff Epstein's house 
You wrote in this exhibit, "I got some 
stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 
A. 
Yes. 
Q. 
Referring to this deposition, didn't you? 
A. 
Referring to the court. I was later 
informed that it was a deposition. 
Q. 
I'm going to ask you some questions now 
 —2-3-  
three years 09e.—Okey-? 
24 
25 
A. 
Oh-huh. 
Q. 
When the police interviewed you one month 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4S of 316 
EFTA00231061

Case 9:08-cv-80804-KAM 
 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 50 of 100 
D
sor & Associates 
tenoning and Transcription. 
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. 
16 
Q. 
Were you totally shocked by what happened 
17 
when you got to Epstein's house? 
18 
A. 
Yes. 
19 
Q. 
You didn't expect it at all, did you? 
20 
A. 
No. 
21 
Q. 
You had absolutely no idea why your friend 
22 
ias 
taking you to Epstein's house, right? 
23 
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 
SO of 318 
EFTA00231062

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 51 of 100 
nsor & Associates 
Repnninp and T:anictipcion, lnc. 
1 
A. 
Yes. 
. Page 25 
Q. 
Before you got to Epstein's house 
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 
lillillinever 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 IIIII? 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
el 
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1 
O. 
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. 
8 
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 
0. 
UM 
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 
112of 314 
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RepartenE and Trannyipuon. Inc 
1 
2 
3 
BY MR. TEIN: 
Page 27 
MR. LEOPOLD: If you do it one more time, 
we're leaving. 
4 
O. 
MP 
5 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
53 o1316 
EFTA00231065