EFTA00231917

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 85 of 100 
sor & Associates 
Repanimp, and Transaipdan. inc. 
Page 59 
1 
MR. LEOPOLD: I'll certify it. 
2 
 
CERTIFIED QUESTION 
3 
She's answered that question. She's explained it five 
4 
tines already. The fact that Counsel doesn't like the 
5 
answer, that's a different query. 
6 
MR. TEIN: Stop making speaking objections. 
7 
MR. LEOPOLD: I'm not. I'm not going to 
8 
put up with it, because it's in appropriate, Jack, 
9 
and you know it. I will not allow Counsel to 
10 
berate a witness, whether it's in a criminal case 
11 
or a civil case, whether my client or --
12 
MR. TEIN: Calm down. 
13 
MR. LEOPOLD: Excuse me. 
14 
No, I'm not going to allow it. That is not 
15 
proper. 
16 
MR. GOLDBERGER: Okay. 
17 
MR. LEOPOLD: If he wants to say that she's 
18 
lying after asking it five times and her 
19 
explaining in great detail, he can do that. But 
20 
I'm not going to allow her to answer, nor be 
21 
harassed by him. It's improper. 
 22 
MR. GOLDBERGER: Okay. But your response 
. 23 
that Counsel doesn't like the question -- or 
24 
doesn't like the answer -- just let me finish. 
25 
N.R. LEOPOLD: Absolutely. I wasn't going 
pasta 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232217

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 86 of 100 
sor & Associates 
• 
Rept-inns end Tali< ti pncm, Inc 
Page 60 
of 316 
20 
21 
22 
23 
24 
25 
1 
to interrupt you. 
2 
MR. GOLDBERGER: Just requires us to say we 
3 
like the answer to that question. And it's not 
4 
you and I or you and Mr. Tein who are testifying 
5 
here. It's the witness. 
6 
MR. LEOPOLD: Fine. But after the sixth 
7 
time of asking the same question and then coming 
8 
back and pointing a finger at her and saying, 
9 
"You're a liar" --
10 
MR. TEIN: That didn't happen. 
11 
MR. LEOPOLD: That's fine. But I'm not 
12 
going to allow her to answer that question, 
13 
because she's answered that same question and has 
14 
explained it. 
15 
Now Counsel might be sitting there rubbing 
16 
his head with a migraine. That's his problem. 
17 
But if he can't ask a question appropriately in a 
18 
professional manner, we will leave. I will not 
19 
allow her to be berated like that. 
MR. GOLDBERGER: Actually, we're very happy 
with the answer. 
MR. LEOPOLD: That's great. 
MR. GOLDBERGER: Do you want us to get into 
that? 
MR. TEIN: Ted --
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232218

Case 91)8<v-80804-KAM 
ment 1 
EnteredonFLSDDocket07/21/2008 
Page87of100 
nsor & Associates 
Stspornig and Transcaptiem, loc....
$7 of 316 
Page 61 
1 
2 
3 
your question and move on. But do it one time. 
4 
If you don't understand it, I'll let you follow 
MR. LEOPOLD: This is really big stuff that 
you're going through. But that's fine; just ask 
up, but I'm not going to allow you to ask the same 
6 
question time and again and then call her a liar. 
7 
Just ask the question, get the answer and move to 
8 
the next subject matter. 
9 
MR. TEIN: Ted, I'm sitting right across 
10 
the table from you. 
11 
MR. LEOPOLD: Yes, sir. 
12 
MR. TEIN: Please be quiet. Don't yell. 
13 
MR. LEOPOLD: I will not be quiet. 
14 
MR. TEIN: Stop yelling. 
15 
MR. LEOPOLD: Lewis, when I'm yelling 
16 
you'll know it. I will not --
17 
MR. TEIN: My name is not Lewis. 
18 
MR. LEOPOLD: I thought your first name was 
19 
Lewis, Mr. Tein. 
20 
MR. TEIN: You watched me for three days at 
21 
the evidentiary hearing where you sat in the back 
22 
of the courtroom. You should know who I am. 
23 
MR. LEOPOLD: Well, that's the impression 
24 
you must have made in the courtroom. 
25 
I will not be quiet. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232219

Case 9:08-cv-80804-KAM 
 
t 1 
Entered on FLSD Docket 07/21/2008 
Page 88of 100 
Domen 
sor & Associates 
Redd inp and ItAtasctijI:lay 
Page 62 
1 
MR. TEIN: That's obnoxious. Stop being 
2 
obnoxious. It's stupid. Let's go ahead with the 
1111e4311 
23 
24 
25 
3 
questions. 
4 
MR. LEOPOLD: I will make the record. 
5 
MR. TEIN: Let's get on with the questions. 
6 
MR. LEOPOLD: Do you need a break? 
7 
(Thereupon, a recess was taken.) 
8 
BY MR. TEIN: 
9 
Q. 
Okay. grAff after you told your manager 
10 
at the Quarterdeck Tavern everything that was going on 
11 
and he told you he would help you any way he could, he 
12 
hid you in the kitchen from the process servers, correct? 
13 
A. 
Incorrect. 
14 
Q. 
Isn't it true that lying to avoid service 
15 
is a meaningless lie to you,
16 
A. 
Incorrect. 
17 
Q. 
What is your manager's name? 
18 
A. 
I have three. Would you like to know 
19 
all --
20 
Q. 
Who's the one who lied for you? 
21 
A. 
IIIIIIII, 
22 
Q. 
And what did 
do to lie for you? 
A. 
Said I wasn't there. 
Q. 
And who did he tell wasn't there? 
A. 
Ask him. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232220

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 89 of 100 
Gtof MG 
nsor & Associates 
Reparnaa and ltaascrinnon. Inc 
1 
2 
3 
4 
5 
6 
7 
8 
9 
Page 63 
Q. 
Where were you when IIIIII,told this 
soreone that you were not at the Quarterdeck Tavern? 
A. 
Eating nachos. 
Q. 
At the Quarterdeck Tavern? 
A. 
Yes. 
Q. 
What did you do so that 
would lie to 
the process servers for you? 
A. 
Nothing. 
Q. 
You just got him to lie for you, didn't 
10 
you? 
11 
A. 
No. i had no influence on him saying I 
12 
wasn't there. 
13 
Q. 
He took that upon himself? 
14 
15 
servers had to ask the police to get you out of the 
16 
restaurant so that they could serve you? 
17 
18 
foundation, predicate. 
19 
BY MR. TEIN: 
20 
Q. 
You can answer the question. 
21 
Isn't it true that Mr. Epstein's process 
MR. LEOPOLD: Objection. Lack of 
MR. LEOPOLD: If you know. Don't guess. 
22 
THE WITNESS: No. Can you repeat the 
I 23 
question? 
24 
MR. TEIN: Don't coach. 
25 
MR. LEOPOLD: Don't guess. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232221

Case 9:08-cv-80804-KAM 
Doc ment 1 
Entered on FLSD Docket 07/21/2008 
Page 90 of 100 
sor & Associates 
ROpOrtillg mJ TOLIIIICripliall, 
Page 64 
1 
MR. TEIN: That's a coaching. 
2 
MR. LEOPOLD: No. That's an instruction to 
3 
the client. 
4 
MR. TEIN: No. You don't do that. 
5 
THE WITNESS: Can you repeat the question? 
6 
MR. LEOPOLD: Let me just state for the 
7 
record --
8 
BY MR. TEIN: 
9 
Q. 
Once the police -- isn't it true that 
10 
Mr. Epstein's process servers had to ask the police to 
11 
get you out of the restaurant so that they could serve 
12 
you? 
13 
A. 
Incorrect. My boss called the police. 
14 
Q. 
And once the police showed up, to stop you 
; 
15 
from lying to avoid service, you made up another lie that 
16 
the process servers had harassed you. Isn't that 
17 
correct? 
18 
A. 
Incorrect. 
19 
Q. 
You lie all the time, don't you? 
20 
MR. LEOPOLD: Objection. 
21 
THE WITNESS: Incorrect. 
22 
BY MR. TEIN: 
23 
Q. 
You have a MySpace page, don't you? 
24 
A. 
No longer do I have a MySpace page. I 
25 
deleted it. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
66 of 316 
EFTA00232222

Case 9:08-cv-80804-KAM 
Dcyment1 
Entered on FLSD Docket 07/21/2008 
Page 91 of 100 
sor & Associates 
Raporsins and Trauctiptian, 
Page 65 
1 
Q. 
When did you delete your MySpace page? 
2 
A. 
A couple days ago. 
3 
Q. 
Who told you to take your MySpace page down 
4 
a couple of days ago? 
5 
A. 
Nobody. I'm sick and tired of MySpace. 
6 
Q. 
You all of a sudden got sick and tired of 
7 
MySpace and just a few days before this deposition you 
8 
decided to delete your MySpace page, correct? 
9 
A. 
Correct. 
10 
Q. 
Is that your testimony under oath? 
11 
A. 
Yes. 
12 
Q. 
Did you take your MySpace page down because 
13 
you thought the government might subpoena it? 
14 
A. 
Incorrect. 
15 
Q. 
Hadn't your MySpace page been up for over 
16 
three months before you took it down? 
17 
A. 
Correct. But I also had made tons of 
18 
MySpaces over the last years. I just get tired of them 
19 
and delete them because -- drama -- and make new ones. 
20 
Q. 
We're going to talk about that. 
21 
So you deleted your MySpace page after you 
22 
were already under subpoena for this deposition, correct? 
23 
24 
25 
A. 
Correct. 
Q• 
What about the MySpace page didn't you want 
us to see,'"lilt 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
91 of 314 
EFTA00232223

92 o1916 
Case 9:08-cv-80804-KAM 
uncument 1 
Entered on FLSD Docket 07/21/2008 
Page 92 of 100 
sor & Associates 
Reporting-and Transcripnrm. Inc. 
1 
2 
3 
in a second. 
Page 66 
A. 
Nothing. 
Q. 
Well, we're going to come back to MySpace 
4 
A. 
You do that. 
5 
Q. 
I'm 
going to ask you some questions 
6 
abort why you lie about your age so often, okay? 
7 
MR. LEOPOLD: Objection to the form. 
6 
Argumentative. 
9 
BY MR. TEIN: 
10 
Q. 
You lie about your age all the time, don't 
11 
you? 
12 
N.R. LEOPOLD: Objection, argumentative. 
13 
THE WITNESS: Incorrect. 
14 
BY MR. TEIN: 
15 
Q. 
You lie about your age to get body 
16 
piercings, don't you? 
17 
A. 
Incorrect. 
18 
Q. 
You have body piercings, don't you? 
19 
A. 
Yes. 
20 
Q. 
You have four body piercings; isn't that 
21 
right? 
22 
A. 
Five. 
23 
Q. 
Other than the piercings on your ears 
24 
I'm not talking about that --
25 
A. 
Oh, then no; just one. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232224

Case 9:08-cv-80804-KAM 
Dgpyypent 1 
Entered on FLSD Docket 07/21/2008 
Page 93 of 100 
sor & Associates 
Reporting and Tresscriptiecloc 
Page 67 . 
1 
Q. 
And where is the one body piercing? 
A. 
Belly. 
Q. 
When did you get that? 
4 
A. 
For my birthday, with my stepmother and my 
5 
father. 
6 
Q. 
And when was that? 
7 
A. 
When I was 14. 
8 
Q. 
Okay. So you had that body piercing when 
9 
you met Epstein, correct? 
10 
A. 
It might have been, or maybe that -- yeah, 
11 
either my 14th birthday or my 15th. I honestly don't 
12 
remember. 
13 
Q. 
Now you've lied about your age to get into 
14 
bars by using driver's licenses that aren't yours, 
15 
correct? 
16 
A. 
Incorrect. 
17 
Q. 
Are you swearing under oath that you've 
18 
never done that? 
19 
A. 
Yes, I swear under oath. 
20 
Q. 
And you've lied about your age to buy beer, 
21 
correct? 
22 
A. 
Incorrect. 
1 
I 
23 
0. 
You're swearing under oath that you've 
24 
never lied to stores about your age? 
25 
A. 
I've never lied to a store about my age or 
Ph. 
- Fax. 
1655 Pa,m Beach Lakes Blvd., Suite 500 - West Palm Beach, FL. 33401 
9304316 
EFTA00232225

Case 9:08-cv-80804-KAM 
D 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page94 01100 
l
i k41 sor & Associates 
Roraniap anti Transcriptive, Inc. 
1 
anything. 
2 
Q. 
You try to look much older than you are, 
3 
don't you? 
4 
A. 
Incorrect. 
5 
Q. 
And you've lied about your age on your 
6 
MySpace pages, don't you? 
7 
A. 
Incorrect. 
8 
Q. 
All right. Let's look at Exhibit 26-01 
9 
one. 
10 
MS. BELOHLAVEK: 26-001? 
11 
MR. TEIN: Yes. 
12 
BY MR. TEIN: 
13 
Q. 
On this page you lied to everyone that you 
14 
were 18, didn't you? 
15 
A. 
Correct. 
16 
Q. 
Let's go to Exhibit 33. 
17 
MS. BELOHLAVEK: That's 33-001? 
18 
TEIN: Correct. 
19 
BY MR. TEIN: 
20 
Q. 
On this page you lied to everyone that you 
21 
were 19, didn't you? 
22 
A. 
Incorrect. 
23 
MR. LEOPOLD: Just answer the question. 
24 
THE WITNESS: Oh, incorrect. 
25 
BY MR. TEIN: 
Ph. 
- Fax. 
1655 Palm Beach Lakes B!vd., Suite 500 - West Palm Beach, FL 33401 
140311 
EFTA00232226

Case 9:08-cv-80804-KAM 
D ument 1 
Entered on FLSD Docket 07/21/2008 
Page 95 of 100 
sor & Associates 
Repnninp bat! Transcription, Mr 
Page 69 
1 
Q. 
Now you can explain your answer. 
2 
A. 
I know that I have seen all of these and I 
3 
know that this one is mine. 
4 
Can you go down? 
5 
MR. LEOPOLD: Just for the record, you're 
6 
pointing to the photo. 
7 
THE WITNESS: I'm pointing to --
8 
BY MR. TEIN: 
9 
Q. 
You're pointing to the one where it says 
10 
your age is 18? 
11 
A. 
Correct. 
12 
Q. 
That's yours, right? 
13 
A. 
Correct. That's mine from a couple years 
14 
ago that I have not been on, because I don't use that. 
15 
Please keep going down, please. And I think that's it, 
16 
because there's no one -- just that one is mine. 
17 
Q. 
So the one you pointed to where it says 
18 
your age is 18, that's yours, correct? 
19 
A. 
Correct. 
20 
Q. 
And when you wrote 18 as your age on your 
21 
MySpace page, that was a lie, wasn't it? 
22 
A. 
Correct. 
I 
1 
23 
Q. 
Did you lie about your MySpace page back 
24 
then because you couldn't post on MySpace unless you were 
25 
18? 
Ph. 
- Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
1601016 
EFTA00232227

Case 9:08-cv-80804-KAM 
Docyrnent 1 
Entered on FLSD Docket 07/21/2008 
Page 96 of 100 
nsor & Associates 
Roportinp and Trauctipoon, )nc. 
2 
3 
4 
post on MySpace, right? 
5 
A. 
Yes. 
Page 70 
A. 
Correct. There was a rule many years ago 
that you had to be 18 to have a MySpace. 
Q. 
So you lied about your age so you could 
6 
7 
33-01. 
8 
Q. 
Let's go back to the top one on this page, 
Are you testifying now under oath that this 
9 
'MySpace page where the headline says, 'Sills do have more 
10 
fun," and the location is given as Lox, abbreviation for 
11 
Loxahatchee, and the age is 19, and it saysjillill, 
12 
is it your testimony that you did not post 
13 
that? 
14 
A. 
Correct. 
15 
Q. 
Now let's go back to the one that you were 
16 
pointing to before on this page, where it says your age 
17 
is 18 and you lied about your age to post MySpace, okay? 
18 
A. 
Uh-huh, yes. 
19 
Q. 
All right. Why did you finally put your 
20 
true age on your MySpace profile four days before you 
21 
were scheduled to testify before the Grand Jury? 
22 
A. 
I don't know what you're talking about. 
23 
MR. LEOPOLD: If you don't understand, ask 
24 
him to ask the question again. 
25 
MR. TEIN: Don't coach. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Sulte 500 - West Palm Beach, FL 33401 
No/316 
EFTA00232228

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 97 of 100 
sor & Associates 
itoponios nil Transcription, Mc. 
Page 71 
THE WITNESS: I don't know which MySpace 
2 
you're talking about. 
3 
BY MR. TEIN: 
4 
Q. 
The MySpace page that you're just pointing 
5 
to, where it says you were 18. 
6 
A. 
Yes. 
7 
Q. 
And you were lying about your age, right? 
8 
A. 
Qh-huh. 
9 
Q. 
Why did you finally post your true age on 
10 
your MySpace profile --
11 
A. 
Uh --
12 
Q. 
-- four days before you were scheduled to 
13 
testify before the Grand Jury? 
14 
A. 
I honestly don't know which MySpace, 
15 
because I've had like a bazillion MySpaces, and in that 
16 
year, I had two, that one and another one, and that one's 
17 
been deleted. So I don't know which one you're referring 
18 
to. 
19 
Q. 
You remember that you changed your age on 
20 
your MySpace page from 18 to your true age just four days 
21 
before you went and testified in the Grand Jury? 
22 
A. 
No. 
23 
Q. 
You don't remember that. 
24 
A. 
No. 
25 
0. 
Do you remember Detective Recarey? Did you 
Sale M.I
.,.••• MOVE. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
NOM, 
EFTA00232229

Case 9:08-cv-80804-KAM 
Dgcujnent 1 
Entered on FLSD Docket 07/21/2008 
Page 98 of 100 
sor & Associates 
• 
Reporting and Transcription. Inc 
Page 72 
ever meet a Detective Recafey? 
2 
A. 
I don't know the names. 
3 
Q. 
How many different detectives have you met 
4 
with on this case from Palm Beach? 
5 
A. 
Probably a good six or seven, maybe. 
6 
Q. 
Did one of the detectives tell you before 
7 
you testified in the Grand Jury that you should take your 
8 
MySpace age and put your true age? 
9 
A. 
No. 
10 
Q. 
Didn't Detective Recarey have to come to 
11 
your house to pick you up to get you to testify in front 
12 
of the Grand Jury? 
13 
A. 
Possibly; maybe because I didn't have a 
14 
rice; I was only 14 or 15 at the time. 
15 
Q. 
Your mom didn't drive you? 
16 
A. 
No. 
17 
Q. 
Stepmom didn't drive you? 
18 
A. 
I think my dad. Oh, my dad; my dad drove 
19 
me. 
20 
Q. 
Your dad drove you? 
21 
A. 
Yes, sir. 
22 
Q. 
So your testimony is Detective Recarey did 
23 
not drive you, correct? 
24 
MR. LEOPOLD: Objection. /asked and 
25 
answered. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
III a100 
EFTA00232230

Case 9:08-cv-80804-KAM 
Dq 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 99 of 100 
sor & Associates 
Reponota and Transcription, Inc. 
Page 73 
THE WITNESS: No. I'm pretty sure my dad 
2 
drove me, because he was there with me. 
3 
BY MR. TEIN: 
Q. 
Did any detective tell you to change your 
5 
age on your MySpace page, to put your true age? 
6 
A. 
No, sir. 
7 
Q. 
Now you also lied on your MySpace page 
8 
about your income, didn't you? 
9 
A. 
Yes. 
10 
Q. 
And you lied, saying that you made a 
11 
quarter million dollars a year and higher, correct? 
12 
A. 
As a joke, yes. 
13 
Q. 
That was a lie, wasn't it? 
14 
A. 
Yes. 
15 
Q. 
And you also lied on your MySpace page, 
16 
saying that you were married, didn't you? 
17 
A. 
Possibly. And that might have been an 
18 
error on my part. 
19 
Q. 
Now you also lie to the police, don't you? 
20 
A. 
No. 
21 
Q. 
Well, you lied to the police in your 
22 
tape-recorded statement that you gave to Detective 
23 
Pagan three years ago, didn't you? 
24 
A. 
To my knowledge, no, I did not. 
25 
Q. 
Well, you lied to the police when you 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
19 64 314 
EFTA00232231

Case 9:08-cv-80804-KAM 
 
ent1 
Entered on FLSD Docket 07/21/2008 
Page 100 of 100 
Dionsor 
& Associates
Ropartinp and "franscription, inc 
Page 74 
1 
accused Mr. Epstein of attempting to murder your father, 
2 
didn't you? 
3 
A. 
No. I never heard a statement saying that 
4 
Mr. Epstein tried to murder my father. 
5 
O. 
You made that statement, didn't you? 
6 
MR. LEOPOLD: Do you have a statement to 
7 
show her? That's been asked and answered. 
8 
MR. TEIN: I'm sorry. I didn't hear the 
9 
witness' answer, Mr. Leopold. 
10 
BY MR. TEIN: 
ll 
Q. 
you told the police, didn't you, 
12 
that Mr. Epstein almost killed your father, didn't you? 
13 
A. 
No. 
14 
Q. 
Three years ago, before Mr. Epstein even 
15 
knew about this investigation, you told the police that 
16 
Epstein had "already come to my dad's house and did 
17 
something to my dad's tires and my dad almost died. 
didn't want my dad to get hurt, because Jeff already 
19 
almost killed him." 
20 
Didn't you say that? 
21 
A. 
Not to my knowledge or recollection. I 
22 
have never said anything like that. 
23 
Q. 
That would have been a complete lie, 
24 
wouldn't it have been? 
25 
A. 
Yeah. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
100 et 316 
EFTA00232232

EPSTUN es morN TO 
SEAL NoN -PROS *air 
EFTA00232233

JUN-26-2009 FRI 02:28 P11 
FAX NO. 5618358691 
P. 01 
Date: 6/26/09 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
ATTORNEY. LAW 
SUITE 400 
250 AUSTRALIAN AVENUE SOUTH 
WEST PALM BEACH FLO 
01-5066 
TELEPHONE 
FAX-
FAX COVER SHEET 
To: 
R. Alexander Acosta, Esq. USAO 
Barbara Burns, Esq. ASAO 
Bradley J. Edwards, Esq. 
William J. Berger, Esq. 
Robert D. Critton. Esq. 
Spencer T. Kuvin, Esq. 
Subject: State of Florida v. Epstein 
Pages: 3 , including this cover sheet. 
See attached letter. 
ORIGINAL WILL BE SENT:  
YES 
X 
NO 
IF THERE ARE ANY PROBLEMS WITH 
SSION, PLEASE CONTACT 
AS SOON AS POSSIBLE. 
The information contained In this facsimile message Is attorney privileged and confidential information Intended 
only for the use of the individual or entity named above. If the reader of this message is not the intended 
recipient, you are hereby notified that any dissemination, distribution or copy of this communication is strictly 
prohibited. If you have received this communication in error, please immediately notify us by telephone. Thank 
you. 
EFTA00232234

JUN-26-2009 FRI 02:28 PM 
TELECOPIED THIS DATE 
The Honorable Jeffrey Colbath 
Palm Beach County Courthouse 
205 N. Dixie Highway 
Room 11F 
West Palm Beach, FL 33401 
FAX NO. 5618358691 
June 26, 2009 
Re; 
State of Florida v. Jeffrey Epstein 
Dear Judge Colbath: 
P. 
JOSEPH R.ATTERBURY 
' JACK A.GOLDBERGER 
JASON! S. WEISS 
Ulan' 
CCrtalIWI CrintoorPOI 
tome., 
! MendKr of Now Jersoy A hot Hors 
On behalf of Mr. Epstein, we strongly object to the proposed order submitted by 
Deanna Shullman on behalf of the Palm Beach Post. The court has already entered an 
order dated June 25, 2009 on: 
a) 
Non-party,E's Motion to Vacate Order Sealing Records and Unseal 
Records 
b) 
Palm Beach Post's Motions to Intervene and petition for Access 
c) 
Motions to Intervene and for an order to Unseal Records 
d) 
Jeffrey Epstein's Motion to Make Court Records Confidential. 
The only matter before the court today was Defendant Epstein's Motion for a 
Stay which the court denied. Contrary to the assertions in the proposed order submitted 
to you by the Palm Beach Post, the court made a_specific finding-that the-Defendant 
-
-Epstein-has met-his burden of Irreparable harm. Additionally, all of the other matters 
contained in the proposed order were addressed in the court's Order of June 25, 2009. 
It is the position of Defendant Epstein that the order on today's Motion to Stay 
should simply state that the Defendant's Motion to Stay is denied. In this way, the 
court's order of June 25, 2009 on the merits of the issue and the order of the court 
One ClearlAke Contre,Suito 1400 
230 Australian Avenue South Wftsr NMI Reach. FL. 3340i 
www.agwpa.com 
EFTA00232235

P. 03 
JUN-26-2009 FRI 02:28 PM 
The Honorable Jeffrey Colbath 
June 26, 2009 
Page 2 
FAX NO. 5618368691 
denying the stay motion can properly be reviewed by the Fourth District Court of 
Appeal. 
Very truly yqurs, 
ACK A. GOLDBERGER 
JAG:cg 
cc: 
U.S. Attorney's Office (via facsimile) 
State Attorneys Office(via facsimile) 
Deanna K. Shullman, Esquire (via facsimile) 
Bradley J. Edwards, Esquire (via facsimile) 
Spencer t. Kuvin, Esquire (via facsimile) 
EFTA00232236