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FBI VOL00009

EFTA00234324

100 sivua
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Case 9:08-cv-80804-KAM 
Document 1-2 
Entered on FLSD Docket 07/21/2008 
Page 1 of 100 
nsor & Associates 
RepornnE sad Transcripoon. Inc 
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Page 75 
Q. 
Because Mr. Epstein never came to your 
dad's house, correct? 
A. 
Correct. 
Q. 
And no one who worked for Mr. Epstein ever 
did something to your dad's tires, did they? 
MR. LEOPOLD: Objection. Lack of 
foundation, predicate. 
Don't guess. 
BY MR. TEIN: 
Q. 
It's not true that Mr. Epstein almost 
killed your father, is it? 
MR. LEOPOLD: Objection. Asked and 
answered, lack of foundation, predicate. 
BY MR. TEIN: 
Q. 
You can answer. 
A. 
No. 
Q. 
Now you told the police that you didn't 
know who was in the car with you and IIIIIII on the day 
you went to Epstein's house, didn't you? 
A. 
Yes. 
Q. 
And that was a lie, wasn't it? 
A. 
It's the truth. 
Q. 
You told the police that there was someone 
in the car next to you and you specifically said you 
didn't know her name, right? 
1010716 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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Page 2 of 100 
nsor & Associates 
Ropor•.1np and *I ranscnpacm. Inc 
Page 76 
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2 
3 
was dark like a Spanish girl." Those were your words, 
4 
right? 
5 
A. 
Yes. 
6 
MR. LEOPOLD: Objection. Asked and 
7 
answered. 
8 
BY MR. TEIN: 
9 
Q. 
Who was in the car that day with you and 
10 
fl
11 
A. 
Again, I do not know. 
12 
Q. 
It was your good friend 
13 
wasr't it? 
14 
A. 
No. I don't know a
15 
Q. 
You lied to the police about who was in the 
16 
car with you and e, 
didn't you? 
17 
A. 
Incorrect. 
18 
Q. 
Let me ask you some questions about who you 
19 
may have spoken to about this case. All right? 
20 
A. 
Go ahead. 
21 
Q. 
Did you speak to your twin sister 
. 
22 
A. 
Not in detail, but of course she knows; 
23 
she's family. And yes. 
24 
Q. 
What's her e-mail? 
25 
A. 
I don't think she has an e-mail. 
A. 
Correct. I do not know her name. 
Q. 
You said, "I don't know her name, but she 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
I 
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Page 3 of 100 
sor & Associates 
herynning and Transcription, Inc. 
Q. 
Page 77 
1 
2 
A. 
Oh, gosh. I don't know off the top of my 
3 
head. 
4 
Q. 
5 
A. 
6 
Q. 
7 
A. 
8 
Q. 
9 
speak to him about Epstein's case? 
10 
A. 
That's my mom's boyfriend. My sister 
11 
doesn't have a boyfriend. My mom's husband's name is 
12 
so maybe you get them confused. 
13 
Q. 
Do you know his phone number? 
14 
A. 
No. 
15 
Q. 
where does he live? 
16 
A. 
With my mom. 
17 
Q. 
In the same house with her? 
18 
A. 
Yes. They're married. 
19 
Q. 
So not boyfriend; husband? 
20 
A. 
Yeah, husband. 
21 
Q. 
Have you spoken to 
22 
what happened in Mr. Epstein's house? 
23 
A. 
Not in detail, but he knows the basics, 
24 
yes. 
25 
Q. 
What is his e-mail? 
What is her phone number? 
And what is her home address? 
She lives with my mom. 
In Georgia? 
Yes, sir. 
What about '11111iboyfriend..? Did you 
about 
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Case 9:08-cv-80804-KAM 
D 
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Page 4 of 100 
sor & Associates 
Kellam op and Transc ri Ron. Inc 
Page 78 
1 
2 
3 
4 
A. 
I don't know. 
Q. 
A. 
Q. 
What is his phone number? 
How is that relevant? 
What is his phone number? 
5 
A. 
561.719.2652. 
6 
Q. 
What is his home address? 
A. 
I don't know. 
Q. 
Where does he live? 
A. 
In Palm Beach Lakes somewhere. 
10 
Q. 
11 
A. 
12 
Q. 
13 
14 
15 
MR. TEIN: Don't coach. 
16 
17 
18 
19 
20 
21 
22 
23 
street. 
24 
Q. 
What's the name of the apartment complex? 
25 
A. 
Something Cove. 
Ever been to his house? 
Yes. 
You don't know what his address is? 
MR. LEOPOLD: Objection. Asked and 
answered. She just said she doesn't know. 
MR. LEOPOLD: Objection. Asked and 
answered. 
BY MR. TEIN: 
Q. 
You can answer the question. 
A. 
I don't know the exact address. 
Q. 
What street is it on? 
A. 
It's an apartment complex; its not a 
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Page 5 of 100 
nsor & Associates 
Rcparuni.: and Transcrip:i an. Inc. 
Q. 
1 
2 
3 
Q. 
Page 79 
What apartment number is it? 
A. 
I couldn't tell you. 
When was the last time you went there? 
4 
A. 
Just visited this past weekend. That's the 
5 
first and last time I went there. 
6 
Q. 
How about 
ININEr
 
Have you spoken 
7 
to him about your case? 
8 
A. 
No. We no longer speak. 
9 
Q. 
10 
already have his phone number and e-mail. 
11 
How about IIIIIIIIIP 
Have you ever 
12 
spoken to her about your case? 
13 
A. 
I don't know an 
14 
Q. 
Have you ever met 
15 
A. 
No. But just to let you know, I don't 
16 
reaLly know names. If you have pictures of there faces I 
17 
couLd tell you. 
What's his phone number? Actually, we 
18 
Q. 
All right. Let me see if I can refresh 
19 
your memory. 
20 
A. 
Okay. 
21 
Q. 
Does it refresh your memory that 
Mir 
22 
is the other girl who made allegations about Epstein, but 
23 
refused to show to the Grand Jury when she had to testify 
24 
about them under oath? 
25 
A. 
No, sir. I have no knowledge of any other 
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Page 6 of 100 
nsor & Associates 
Repnnung and Transcii po co, Inc. 
Page 80 
1 
girls in this whole situation. We're not allowed to know 
2 
each other. 
3 
Q. 
I didn't get the last four words. 
4 
A. 
We're not allowed to know each other. 
5 
Q. 
And what about 
Have you 
6 
of met her? 
7 
A. 
No, sir. 
8 
Q. 
Let's see if I can refresh your memory on 
9 
her. She's the other person represented by your lawyer 
10 
Mr. Herman, who is suing Epstein for fifty million 
11 
dollars. 
12 
A. 
I have no knowledge of her. 
13 
Q• 
Never met her? 
14 
A. 
Never met her. 
15 
Q. 
16 
A. 
I don't know who that is either. 
17 
Q. 
A person named 
who knows 
. 
18 
Is that OM. 
19 
A. 
I don't know, sir. 
23 
Q. 
Do you remember making a statement to 
21 
Detective Pagan that's in the police reports? 
22 
A. 
No, sir. 
23 
Q. 
Have you read the police reports in this 
24 
case? 
25 
A. 
Yes. 
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Page 7 of 100 
nsor & Associates 
Roponinp. anil TrinsCriptioli. Inc.
Page 81 
1 
Q. 
They're on the Internet, right? 
2 
A. 
Yes, I think. 
3 
Q. 
Were you surprised when the police reports 
4 
were released on the Internet containing your statements 
5 
6 
7 
8 
9 
that you had made to the police? 
A. 
Yes. 
Q. 
You didn't want to see that happen, right? 
A. 
No. 
O. 
So you're saying you don't know a
10 
11 
12 
MR. LEOPOLD: Objection. Asked and 
answered. 
13 
BY MR. TEIN: 
14 
Q. 
Does it refresh your memory that he was 
15 
somebody who had gone to jail for drugs and car theft? 
16 
A. 
No, sir. 
17 
O. 
Someone who knows 
. 
18 
A. 
No. 
19 
Q. 
You don't know if he met with Detective 
20 
Recarey? 
21 
A. 
No, sir. 
22 
Q. 
How about INS 
23 
A. 
Yes, I remember. I know who that is. 
24 
Q. 
Did you ever speak to l
about what 
25 
happened at Mr. Epstein's house? 
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nsor & Associates 
Rept-bring rind 17anscripticm. Inc 
Page 82 
1 
A. 
He knows what happened four years ago. He 
2 
doesn't know this is still going on today. 
3 
Q. 
What's his address? I'm sorry. I have his 
4 
address. 
5 
A. 
I don't know. 
6 
Q. 
How about 
7 
A. gut 
8 
Q. 
You know who that is? 
9 
A. 
I know who that is, yes. 
10 
Q. 
He's the one you stayed out drinking all 
11 
night one night last year when your dad reported you 
12 
missing? 
13 
A. 
No, sir. 
14 
Q. 
Remember the baseball game you were 
15 
supposed to go to? 
16 
A. 
No, sir. 
17 
O. 
Did you speak to 
about this 
- 
18 
case? 
19 
A. 
No, sir. 
20 
Q. 
How about 
21 
A. 
That's my sister's ex-boyfriend. 
22 
Q. 
He's the one with the sawed-off shotgun 
23 
with the obliterated serial number? 
24 
A. 
Ask him. I would not know that 
25 
information. 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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Page 9 of 100 
nsor & Associates 
Repnrunp and lranscnpnon, Inc 
Page 83 
1 
Q. 
Did you speak to 
about this 
2 
case? 
3 
A. 
No, sir. 
4 
Q. 
Have you spoken to allarir 
bout this 
5 
case? 
6 
A. 
No. I don't know who 
a
 
is. 
7 
0. 
Did your parents speak to Illinir 
8 
A. 
Ask my parents. 
9 
Q. 
Let's see if I can refresh your memory as 
10 
to who he is. Okay? 
11 
A. 
Uh-huh. 
12 
Q. 
He's the Vanity Fair reporter who made a 
13 
financial arrangement with your father. 
14 
A. 
I am aware of that. And again, I was not 
15 
aware like that my dad did it until after it was done. 
16 
And I don't know the details about that. I just know 
17 
what you know about that, like that they talked. 
18 
Q. 
Tell me what you know about the financial 
19 
arrangement that MM. 
the Vanity Fair reporter, 
20 
made with your father. 
21 
A. 
I don't know about the details at all. 
22 
Q. 
How much money did 
give to
MOM 
23 
your father? 
24 
A. 
I don't even know he gave money to my dad. 
25 
Q. 
I'm sorry? 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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sor & Associates 
;tenoning and Transcription, Inc 
Page 84 
1 
A. 
I didn't even know he gave money to my dad. 
2 
Q. 
What do you know about the deal that mir 
3 
has with your father? 
4 
A. 
I only know they spoke on the telephone 
5 
once. I don't know anything else. 
6 
Q. 
When was that? 
7 
A. 
This was a while ago, a year or two 
or a 
8 
year ago. I honestly don't know. 
9 
Q. 
Did MEM 
the Vanity Fair 
10 
reporter, offer any money to your father? 
11 
A. 
I don't know. 
12 
Q. 
Did 
the Vanity Fair 
13 
reperter, give you any money? 
14 
A. 
No, sir. 
15 
Q. 
Did he offer you any money? 
16 
A. 
No, sir. Never spoke to him. 
17 
Q. 
What reporters have you spoken to? 
18 
A. 
Zero. 
19 
Q. 
What about your family members? What 
20 
reporters have they spoken to? 
21 
A. 
The whole Palm Beach County, obviously, as 
22 
you can see in that newspaper. 
23 
Q. 
Tell me -- let's go through each one that 
24 
you remember. Other than the Vanity Fair reporter, 
25 
IIIMIWwhat 
other reporters have any member of your 
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sor & Associates 
Repining end Transcription, Inc. 
Page 85 
1 
family spoken to? 
2 
A. 
I don't know. And I know my mom has spoken 
3 
to zero. My sister spoke to zero. My father and 
4 
stepmother, I wouldn't know. You'd have to ask them. I 
5 
don't contact them. 
6 
Q. 
Well, I just want to know -- I don't want 
7 
you to -- I want to know what's in your mind. All right? 
8 
MR. LEOPOLD: She just told you. She just 
9 
answered --
10 
MR. TEIN: Be quiet. 
11 
BY MR. TEIN: 
12 
Q. 
What I want to know is what you know from 
13 
your personal knowledge. My question to you is: What 
14 
knowledge do you have about family members of yours 
15 
speaking to reporters? 
16 
MR. LEOPOLD: Objection. Asked and 
17 
answered. 
18 
And if you can't talk professionally, we're 
19 
going to leave. 
20 
MR. TEIN: Do what you want to do. 
21 
MR. LEOPOLD: Are you going to continue to 
22 
talk this way? 
23 
MR. TEIN: I'm not going to answer any 
24 
question that you ask me, Mr. Leopold. 
25 
MR. LEOPOLD: Okay. 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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nsor & Associates 
Reporting and Transc Finnan, Inc 
Page 86 
1 
MR. TEIN: But you are misrepresenting the 
2 
record and you are grandstanding for your client 
3 
and it's wrong. So be quiet. And you know how to 
4 
make an objection. Make it. Otherwise stop 
5 
talking. 
6 
BY MR. TEIN: 
7 
Q. 
init-
8 
MR. LEOPOLD: Excuse me. 
9 
MR TEIN: If you want to leave the 
10 
deposition, leave. But you'll be back here. 
11 
MR. LEOPOLD: Excuse me. If I could just 
12 
make the record, instead of interrupting me, 
13 
please. That's what we do professionally. 
14 
There's a recorder here. I'm certainly not being 
15 
obstructionist. I'm going to make the record. 
16 
But we're going to act with some semblance of 
17 
professionalism, hopefully, by all parties in the 
18 
room. That goes to me, that goes to your 
19 
co-counsel sitting behind you and next to you, the 
20 
court reporter and everyone else in the room. 
21 
Everyone is entitled to that. 
22 
You've asked a question. She answered the 
23 
question fully and she's not going to be harassed 
24 
because you don't like the answer. If you want to 
25 
follow up --
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nsor & Associates 
Repnrti DE anti lranseti piton. Inc 
1 
Page 87 
MR. TEIN: Stop engaging me. Make your 
2 
speech and then we'll ask the questions. 
3 
MR. LEOPOLD: Well, you won't let me finish 
4 
making the objection, so it's difficult to do 
5 
that. But if you want to follow with an 
6 
appropriate question, feel free to do that. But 
7 
we're not going to harass the witness. 
8 
MR. TEIN: I disagree with everything 
9 
you've said. Let's ask the questions. Okay? 
10 
MR. LEOPOLD: Ask an appropriate question. 
11 
MR. TEIN: Are you going to stop talking? 
12 
MR. LEOPOLD: I'm going to make -- protect 
13 
my client and make appropriate objections. 
But 
14 
there's not a question pending right now. 
15 
BY MR. TEIN: 
16 
Q. ahasillispoken 
to any reporters? 
17 
A. 
No. 
18 
MR. LEOPOLD: Objection. Asked and 
19 
answered. 
20 
BY MR. TEIN: 
21 
Q. 
Has 
been given money by any 
22 
reperters? 
23 
A. 
No. 
24 
Q. 
Has your mom spoken to any reporters? 
25 
MR. LEOPOLD: Objection. Asked and 
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lik nsor & Associates 
Reparcinp and itnnscriparz. Inc 
Page 88 
1 
answered. 
2 
THE WITNESS: No. 
3 
BY MR. TEIN: 
4 
Q. 
Has your mom's husbandlillispoken to any 
5 
reporters? 
6 
A. 
No. 
7 
Q. 
Has your mom's husband IIIIIreceived any 
8 
money from reporters? 
9 
A. 
No. 
10 
Q. 
Are you sure you don't know 
11 
MR. LEOPOLD: Objection. Asked and 
12 
answered. 
13 
THE WITNESS: I'm positive. 
14 
BY MR. TEIN: 
15 
Q. 
I'll try again to refresh your memory. 
16 
A. 
Okay. 
17 
Q. 
Does it refresh your memory that she had 
18 
been arrested for drugs and was cooperating with 
19 
Detective Recarey against Epstein to get herself a better 
20 
deal? 
21 
A. 
No. I don't know who she is. 
22 
Q. 
Have you spoken to anyone else who's been 
23 
at Epstein's house? 
24 
A. 
No. 
25 
Q. 
Without telling me what was said -- I don't 
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4 
nsor & Associates 
Steponsnp mid 1r/inscription, lac.
Page 89 
1 
wart to know about any conversations with any lawyers, 
2 
okay --
3 
A. 
Uh-huh. 
4 
Q. 
did you or your parents speak to any 
5 
other law firms besides Mr. Herman and Mr. Leopold's law 
6 
firms? 
7 
A. 
No. 
8 
Q. 
Now without telling me about anything that 
9 
was said, what -- did one just come to mind? 
10 
A. 
No. I was thinking about something else. 
11 
Q. 
What were you thinking about? 
12 
A. 
Does family court matter? 
13 
Q. 
Okay. Without telling me what was said, 
14 
who prepared you for today's deposition? 
15 
A. 
What do you mean prepared? 
16 
Q. 
Did you talk about this deposition, about 
17 
what would happen, with anybody? 
18 
A. 
Yes. 
19 
Q. 
Don't tell me what was said. 
2D 
A. 
Okay. 
21 
Q. 
I'm not asking that. I don't want to know 
22 
that. 
23 
A. 
Okay. 
24 
Q. 
Who prepared you for today's deposition? 
25 
A. 
Mr. Leopold. 
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nsor & Associates 
Itencannp and Transcriptinn. Inc 
Page 90 
1 
Q. 
Anybody else? 
2 
A. 
No. 
3 
Q. 
When did you meet with Mr. Leopold to 
4 
prepare for today's deposition? 
5 
A. 
This morning. 
6 
Q. 
And how long did that meeting last? 
7 
A. 
Until it started. 
8 
Q. 
Now you told me that you previously had 
9 
read the police reports in this case? 
10 
A. 
Yes. 
11 
Q. 
Have you read your statement that you gave 
12 
to the police? 
13 
A. 
Yes, sir. 
14 
Q. 
And in what form was that statement? 
15 
A. 
What do you mean? 
16 
Q. 
Was it in the form of a police report or a 
17 
transcript? 
18 
A. 
What's the difference? 
19 
Q. 
A transcript has questions and answers on 
2) 
it. A police report is just typed out narrative. 
21 
A. 
Oh, it's a police report. 
22 
Q. 
And when did you read the police report? 
23 
A. 
A few days ago. I overread it a few days 
24 
ago. 
25 
Q. 
Had you read it before that? 
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nsor 
P.ssociates 
Ropornns and Transcription, Inc. 
Page 91 
1 
A. 
No. 
2 
Q. 
Now you told me -- again, I don't want to 
3 
know what was said. 
4 
A. 
Oh-huh. 
5 
Q. 
You told me that you met with Mr. Leopold 
6 
this morning to prepare for your deposition, right? 
7 
A. 
Yes. 
8 
Q. 
When did you set up that meeting with 
9 
Mr. Leopold to take place this morning? 
10 
A. 
Gee, like, like five days ago, four days 
11 
ago. 
12 
Q. 
So you're aware that Mr. Leopold told us 
13 
that he could not start the deposition this morning 
14 
because he had a court appearance, correct? 
15 
MR. LEOPOLD: Don't answer that question. 
16 
Calls for attorney/client communications. 
17 
BY MR. TEIN: 
18 
Q. 
Have you seen the letter that Mr. Leopold 
19 
wrote to us stating that he -- an e-mail that Mr. Leopold 
20 
wrote to Mr. Goldberger stating that he could not be here 
this morning because he had a court appearance? Did you 
22 
see :hat e-mail? 
23 
MR. LEOPOLD: You can answer that question. 
24 
THE WITNESS: No. 
25 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
11701316 
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2 
3 
9 
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that statement? 
Page 92 
BY MR. TEIN: 
Q. 
Have you listened to your tape-recorded 
statement to the police? 
4 
A. 
Yes. 
5 
Q. 
Where did you listen to that? 
6 
A. 
In, I think, this building. I don't know. 
7 
It was here. 
8 
Q. 
When did you listen to that statement? 
A. 
This morning. 
Q. 
And who was present when you listened to 
12 
A. 
Mr. Leopold -- and I forget your name. 
13 
MR. GOLDBERGER: Ms. Belohlavek. 
14 
THE WITNESS: Ms. Belohlavek. 
15 
BY MR. TEIN: 
16 
Q. 
And you hadn't listened to your statement 
17 
before that, correct? 
18 
A. 
No, sir. 
19 
Q. 
Have you met with lawyers representing 
20 
anyone else suing Epstein? 
21 
A. 
No, sir. 
22 
Q. 
How many times have you spoken to officers 
23 
with the Palm Beach Police Department? 
24 
A. 
More than I like can count. It's been 
25 
ongoing for four years, so quite a few times. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
11641316 
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Page 93 
1 
Q. 
When was the last time you spoke with 
2 
officers of the Palm Beach Police Department? 
3 
A. 
A while ago. I'd say a year ago. 
4 
Q. 
A year ago? 
5 
A. 
Yeah. Maybe a year and a half. 
6 
Q. 
Do you remember Detective Recarey? 
7 
A. 
No. 
8 
Q. 
Do you remember Michelle Pagan, Detective 
9 
Pagan? 
10 
A. 
Yes. 
11 
Q. 
How many times have you spoken to Detective 
12 
Pagan? 
13 
A. 
She was the only one I spoke to about this 
14 
until for some reason she wasn't on the case anymore. 
15 
Q. 
When was that? 
16 
A. 
The first meeting I ever had was with her 
17 
and then I think like I met with her like 10 times or 12 
:8 
times or something like that, and then I didn't get 
19 
another investigator questioned me after that. 
20 
Q. 
And who was that? 
21 
A. 
I don't remember. 
22 
Q. 
And what type of questions did they ask 
23 
you? 
24 
A. 
The same. 
25 
Q. 
The same questions all over again? 
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Page 95 
1 
A. 
I'd have to say like a year and a half ago, 
2 
a year ago. It was a long time ago. 
3 
(Discussion held off the record.) 
4 
MR. TEIN: Tell me the last answer, please. 
5 
(Thereupon, a portion of the record was read 
6 
by the reporter.) 
7 
BY MR. TEIN: 
8 
Q. 
And who was present when the FBI spoke to 
9 
you at your father's house? 
10 
A. 
My stepmother was there, but she wasn't 
11 
around. She made herself like do other things. 
12 
Q. 
And how many FBI agents were there? 
13 
A. 
I think four. 
i4 
Q. 
And you don't remember any of their names? 
15 
A. 
No, sir. 
16 
Q. 
And were there any lawyers there? 
17 
A. 
Not that I know of. 
18 
Q. 
And none of them gave you their cell phone 
19 
numbers? 
20 
A. 
No. 
21 
Q. 
And the last time you spoke to the FBI was 
22 
a year and a half ago? 
23 
A. 
It was a while ago. 
G4 
MR. LEOPOLD: Objection. Asked and 
25 
answered. 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
120 of 316 
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