EFTA00231917

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 Plaintiffiane 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. III 
Counsel for Defendant 
Bruce E. 
P . 
Bruce E. 
, 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 
Lewis Fein ,. 
)059 Gana An Nut. SuOT 340, CoOmul fitOvt. ?Iota 13)33 
2$ of 3t1 
EFTA00232157

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 26 of 100 
EXHIBIT A 
2001316 
EFTA00232158

r 
Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
Page 27 of 100 
nsor & Associates 
Rcpniap slid Tummy:in% Inc. 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 2006 CF09454AXX 
STATE OF FLORIDA, 
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 
copy 
Notary Public, State of Florida 
Consor & ASsociates Reporting and Transcription 
Phone - 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
atom 
EFTA00232159

Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
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nsor & Associates 
Repanitv and Transcripline. lnc 
Page 2 
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APPEARANCES: 
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On behalf of the State: 
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LANNA BELOHLAVEK, ESQ. 
ASSISTANT STATE ATTORNEY 
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401 North Dixie Highway 
West Palm Beach, Florida 33401 
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561.355.7100 
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On behalf of the Defendant: 
MICHAEL R. TEIN, ESQ. 
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KATHRYN A. MEYERS, ESQ. 
LEWIS TEIN, PL 
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3059 GRAND AVENUE, SUITE 340 
COCONUT GROVE, FL 33133 
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On behalf of the Defendant: 
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JACK A. GOLDBERGER, ESQ. 
ATTERBURY, GOLDBERGER & WEISS 
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250 AUSTRALIAN AVENUE SOUTH 
SUITE 1400 
12 
WEST PALM BEACH, FLORIDA 33401 
13 
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ALSO PRESENT: 
ON BEHALF OF THE WITNESS: THEODORE J. LEOPOLD, ESQ. 
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KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, 
LEGAL-EZE 
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:8 
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Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
280 3% 
EFTA00232160

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Case 9:08-cv-80804-KAM 
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sor & Associates 
Rep/irons and Traucripuna, 
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INDEX 
WITNESS: 
Page 3 
PAGE: 
DIRECT EXAMINATION 
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BY MR. TEIN: 
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NOEXHIBITS 
MARKED 
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Page 
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CERTIFIED QUESTIONS 
Line 
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Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232161

Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
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nsor & Associates 
Ropm.ans and iraftscdpro. 1.714 
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7 
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O. 
Thank you. 
19 
May I call you 4111W 
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 
O. 
If you at any time don't understand one of 
Page 4 
1 
Deposition taken before Judith F. Consor, 
2 
Court Reporter and Notary Public in and for the State of 
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Flsrida at Large, in the above cause. 
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Thereupon, 
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7 
having been first duly sworn or affirmed, was examined 
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and testified as follows: 
9 
THE WITNESS: I do. 
10 
DIRECT EXAMINATION 
11 
BY MR. TEIN: 
12 
O. 
Good afternoon. Please tell me your full 
13 
naue. 
14 
A. 
15 
0. 
And can you please spell it. 
A. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
30 of 3l
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nsor & Associates 
Ruportias and Tractscriptice. lac 
Page 5 
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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 
0. 
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. 
a 
my uncle. 
23 
24 
25 
Q. 
A. 
Q. 
Anyone else living there? 
No. 
The contempt motion that your mother filed 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
I 
31 4:4316 
EFTA00232163

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nsor & Associates 
Rep/min; and Transcription. inc. 
Page 6 
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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 
6 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
32 el 316 
EFTA00232164

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nsor & Associates 
tiertaniqf and transcriptim Inc 
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3 
Q. 
Q. 
Where is that? 
A. 
Palm Beach Lakes. 
Have you spent the night over there? 
Page 7 
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 
at 
9 
A. 
No. 
10 
Q. llIR 
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 
13.1316 
EFTA00232165

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Entered on FLSD Docket 07/21/2008 
Page 34 of 100 
nsor & Associates 
aornrtiap and Tratsctipoto. lac. 
Page 8 
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MR. LEOPOLD: Let me just object. 
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let me instruct you. Anything that 
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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. 
IIIII1 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 of Mt 
EFTA00232166

Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
Page 35 of 100 
sor & Associates 
Homing sold Tramscripam, Inc. 
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that. 
Page 9 
MR. LEOPOLD: Lewis, we're not going to do 
MR. TEIN: My name is not Lewis. 
I'm going to finish my question. Okay? 
5 
MR. LEOPOLD: Do not answer until you hear 
6 
from me. 
7 
BY MR. TEIN: 
8 
Q. 
Other than conversations that you have had 
9 
with Mr. Leopold -- I'm not asking about that -- are you 
10 
aware that Mr. Leopold has filed a lawsuit in federal 
11 
court seeking fifty million dollars from Jeffrey Epstein 
12 
on your behalf? 
13 
MR. LEOPOLD: Same objection. 
14 
Anything that you learn through 
15 
conversations between you and me, do not answer. 
16 
Those are protected. If you know through any 
17 
other realm of knowledge, you may answer. 
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BY MR. TEIN: 
20 
Q. 
You have no idea that Mr. Leopold filed a 
21 
fifty million-dollar lawsuit on your behalf against 
THE WITNESS: No. 
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Jeffrey Epstein? 
23 
24 
MR. LEOPOLD: Same objection. 
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 
35013t6 
EFTA00232167

Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
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nsor & Associates 
Reporting ad Tranxtip:inei. lac 
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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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
Motile 
EFTA00232168

Case 9:08-cv-80804-KAM 
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Entered on FLSD Docket 07/21/2008 
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nsor & Associates 
Re porung and Transciip<m). lnc 
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objections. Check your rules. 
MR. LEOPOLD: Excuse me. For the record, 
Counsel asked me a question. I'll state the 
answer on the record. He asked me the question am 
I going to be answering that way throughout the 
deposition. So long as there's improper 
foundation and predicate asked by the attorney, I 
will protect my client and I make the record where 
appropriate. If counsel wishes to ask an 
appropriate worded question with the proper 
foundation and predicate, I will certainly allow 
the client to answer the question. 
MR. GOLDBERGER: Why don't you just state 
attorney/client privilege and just be done with 
it? 
MR. LEOPOLD: I want the record to be 
clear. 
MR. TEIN: You want to waste time is what 
you want to do. 
You were supposed to be here this morning 
and you totally broke the deal, the agreement that 
you had with us if your hearing got cancelled. 
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 
37 of 310 
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nsor & Associates 
Reporting end Transcription. lac. 
Page 12 
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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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
31 d711 
EFTA00232170

Case 9:08-cv-80804-KAKI 
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Entered on FLSD Docket 07/21/2008 
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nsor & Associates 
Reporting and Traescriptico, Inc. 
Page 13 
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 
4IIIIIIIIIias 
opposed to gm, 
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 
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 
After it happened. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
39 of 3I6 
EFTA00232171

Case 9:08-cv-80804-KAM 
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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 
EFTA00232172

Case 9:08-cv-80804-KAM 
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Page 41 of 100 
nsor & Associates 
Re ponies arid Transentman, Inc 
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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 
demeanor with me --
MR. TEIN: You are obstructing this 
deposition. 
MR. GOLDBERGER: Why don't you guys go 
outside and just talk about 
MR. LEOPOLD: She -- her job is very 
difficult and she's not going to be able to take 
us both talking at the same time. 
MR. GOLDBERGER: Off the record. 
MR. LEOPOLD: We're not going off the 
record, Jack. We're not, Jack. Her job is very 
difficult. I'm going td make the record. 
I don't think it is appropriate, especially 
in the small confines of this room, to be very 
aggressive with this young lady. 
MR. TEIN: That's not happening. Stop, 
stop actually --
MR. LEOPOLD: If you're going to interrupt 
me, we're going to cancel this deposition 
MR. TEIN: Stop misrepresenting. 
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 311 
EFTA00232173

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Roparziap and Transcription. lac. 
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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. TEIN: We're not taking a break unless 
the witness needs a break. 
You're obstructing this deposition, Ted. 
MR. LEOPOLD: Come on, NW 
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 Wile 
EFTA00232174

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Page 17 
You were supposed to be here at nine a.m.; 
2 
it's now after two. Take your break and come 
3 
back. 
4 
5 
6 
7 
MR. LEOPOLD: Okay. If the demeanor keeps 
up, we will not be here beyond those five minutes. 
MR. TEIN: Take your break and come back. 
MR. LEOPOLD: Okay. So I suggest that you 
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. 
you agree that giving testimony 
20 
today at your deposition is something very serious, don't 
MR. TEIN: I suggest that you take your 
21 
you? 
22 
A. 
Yes. 
23 
Q. 
24 
And you respect the court, don't you? 
A. 
Yes. 
25 
Q. 
Let me show you Exhibit 31-O01. Can you 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
43,1311 
EFTA00232175

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pi
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Repartinp ad 1 rancti pucm, 
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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...1O1 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 
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. 
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