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FBI VOL00009

EFTA00234324

100 sivua
Sivut 21–40 / 100
Sivu 21 / 100
Case 9:08-cv-80804-KAM 
ensOt 1-2
r oz p55Ocla 
()Entered on_FLSDDocket 07/21/2008 
Page 21 of 100 
c es 
Reporting and lranscrip:nri. Inc 
1 
BY MR. TEIN: 
2 
Q. 
Page 96 
And the last time you spoke to the federal 
3 
prosecutor's office was when? 
4 
A. 
I don't know. 
5 
Q. 
Did any of the FBI agents tell you that 
6 
Marie Villafona had spoken with Mr. Leopold? 
7 
A. 
No. 
8 
Q. 
Did any of the FBI agents tell you that 
9 
Marie Villafona had spoken with Mr. Herman? 
10 
A. 
No. 
11 
Q. 
Did any FBI agents tell you that Jeff 
12 
Slonan spoke with Mr. Herman. 
13 
A. 
No. 
14 
Q. 
Did any FBI agents tell you that Jeff 
15 
Slonan spoke with Mr. Leopold? 
16 
A. 
No. 
17 
Q. 
Do you know whether any of the federal 
18 
prosecutors allowed Mr. Herman to review a draft 
19 
indictment? 
20 
A. 
I wouldn't know. 
21 
Q. 
Do you know if any of the federal 
22 
prosecutors discussed a draft indictment with Mr. Herman? 
23 
A. 
I wouldn't know. 
24 
Q. 
Have you ever e-mailed with any FBI agent 
25 
or any federal prosecutor? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
1210316 
EFTA00234344
Sivu 22 / 100
Case 9:08-cv-80804-KAM 
nt 1-2 
AEntered on Flan Docket 07/21/2008 
Page 22 of 100 
-sor & Associates 
hoponenp And Transaipart, Inc. 
Page 97 
1 
2 
3 
agent or any federal prosecutor? 
4 
A. 
No. 
5 
Q. 
Has the FBI told you about other testimony? 
6 
A. 
No. 
7 
Q. 
Has the FBI told you about what other girls 
8 
have said? 
9 
A. 
No. 
10 
Q. 
11 
other girls have said? 
12 
A. 
No. 
13 
Q. 
Do you have any way of getting in touch 
14 
with the FBI if you wanted to get in touch with them? 
15 
A. 
No. 
16 
Q. 
17 
to get in touch with the FBI? 
18 
A. 
I don't know. 
19 
Q. 
And by your parents, I'm referring to both 
20 
sets, okay? 
21 
A. 
Oh. Well, I'm referring to only my dad, 
22 
because my mom really doesn't care to know any of this 
23 
stuff. 
24 
Q. 
So the answer would be the same for your 
25 
mom and 
A. 
No. 
Q. 
Have you ever text messaged with any FBI 
Have federal prosecutors told you what 
How about your parents? Do they know how 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
U2 0 316 
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Case 9:08-cv-80804-KAM 
nt 1-2 
Entered on FLSD Docket 07/21/2008 
Page 23 of 100 
sor & Associates 
Rept-irons! sad Transcri pti Dn. Inc 
A. 
1 
2 
3 
Ocariz about this case? 
4 
A. 
No. 
Page 98 
Q. 
Yeah. 
Have you spoken to a lawyer named Burt 
5 
Q. 
Do you know who Burt Ocariz is? 
6 
7 
Does it refresh your memory that he's a good friend of 
8 
Marie Villafona's boyfriend? 
9 
A. 
I don't know who Marie Villafona is. 
10 
Q. 
Marie Villafona is the lead federal 
11 
prosecutor that's on the federal part of this case. 
12 
Okay? 
13 
A. 
No. 
14 
Q. 
So does it refresh your memory that Ocariz 
15 
is the good friend of Marie Villafona's boyfriend? 
16 
A. 
Not at all. 
17 
Q. 
Does it refresh your memory that Villafona 
18 
tried to get Epstein to pay for Ocariz to represent you 
19 
in the federal case? 
20 
A. 
No. 
21 
Q. 
Do you know if Detective Recarey has spoken 
22 
with your father? 
23 
A. 
No. 
24 
Q. 
Do you know if Detective Recarey has spoken 
25 
to your stepmother? 
Let's see if I can refresh your memory. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
123 of 316 
EFTA00234346
Sivu 24 / 100
Case 9:08-cv-80804-KAM 
D 
nt1-2 
Entered on FLSD Docket 07/21/2008 
Page 24 of 100 
sor & Associates 
Roponiq and Transcripn cm. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
Page 100 
First off, this is not a warehouse. This 
is in 
garage.
Second of all, I'm not being gang-raped. 
Everyone has their clothing on. 
Thirdly, if you'd look at all the other 
pictures in that album, I'm drinking -- what's 
when you're sick you drink it? 
BY MR. TEIN: 
Q. 
You can't ask questions of your counsel. 
A. 
All right. I'm drinking like Sprite. I'm 
not drinking any kind of alcohol, if you would look at my 
other pictures in that album. 
You guys picked the possibly worst pictures 
out of there to present. And it was just a goofy 
picture. All of these kids like to be goofy. And that's 
what we were doing. 
17 
O. 
Who's the man on the left of the picture 
18 
holding his -- holding a beer bottle as if it were a 
19 
pen:.s towards your mouth? 
20 
A. 
21 
Q. 
Who's the man behind you, right up towards 
22 
your backside, with you bent over? 
23 
A. 
That one? 
24 
Q. 
The right side, kissing with his mouth. 
25 
A. 
That's 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
120 of 316 
EFTA00234347
Sivu 25 / 100
Case 9:08-cv-80804-KAM 
D 
ent 1-2 
Entered on FLSD Docket 07/21/2008 
Page 25 of 100 
nsor & Associates 
actor:nip encl 'Iranscnpunn. Inc 
Page 101 
1 
Q. 
He's the one grabbing towards the groin 
2 
area of 
3 
A. 
Yes. 
4 
O. 
And there's three other men in the photo. 
5 
What are their names? The one on the left with the hat? 
6 
A. 
That's 
(phonetic). 
7 
Q. 
Smiling? 
8 
A. 
Yes. 
9 
Q. 
Who's the one kissing --
10 
MR. LEOPOLD: Don't interrupt. Let her 
11 
finish the record. She's testifying. 
12 
MR. TEIN: I know you don't like this 
13 
picture, my friend. 
14 
MR. LEOPOLD: The picture is fine. 
5 
BY N.R. TEIN: 
16 
Q. 
Who's the one with the hat? 
17 
MR. LEOPOLD: No. Hold on. Stop, 
18 
You have to let the witness finish her 
19 
answer. She was in the process of explaining and 
20 
you cut her off. 
21 
Please finish what you were saying and then 
22 
Counsel can ask you whatever he wishes after that. 
23 
THE WITNESS: Okay. This guy --
24 
MR. LEOPOLD: Just make it so the record is 
25 
clear who you're referring to. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
175 0 316 
EFTA00234348
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Case 9:08-cv-80804-KAM 
nt 1-2 
Entered on FLSD Docket 07/21/2008 
Page 26 of 100 
nsor & Associates 
Kollar:ins and lranscriptinn, Inc. 
Page 102 
1 
THE WITNESS: -- on the far left is 
2 
3 
BY MR. TEIN: 
4 
Q. 
He's the one whose head is near the groin 
5 
of IIIIIIIIIIIIIIIIright?
6 
A. 
Yes. 
7 
Q. 
And in the middle there's a man smiling. 
8 
who's that? 
9 
A. 
That's 
10 
Q. 
And who's the one in the red hat, kissing? 
11 
A. 
That's 
(phonetic). 
12 
Q. 
Let me stop you for a second. Are you 
13 
done? 
14 
A. 
Yes, I'm done. 
15 
Q. 
Who ilium, 
16 
A. 
My sister's friend. Well, she's a mutual 
17 
friend, but more my sister's. 
18 
Q. 
What is her last name? 
19 
A. 
20 
Q. 
Spell that. 
21 
A. 
I don't know how to --
22 
Q. 
Have you spoken to her about this case? 
23 
A. 
No. 
24 
Q. 
Who's IIIIIII 
25 
A. 
My sister's friend. I don't really speak 
a 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
12601316 
EFTA00234349
Sivu 27 / 100
Case 9:08-cv-80804-KAM 
DQpyynent 1-2 
Entered on FLSD Docket 07/21/2008 
Page 27 of 100 
nsor & Associates 
Reportrup and Transeriptiam, inc. 
Page 103 
1 
to him at all. 
2 
3 
4 
5 
6 
7 
case? 
(2• 
A. 
Q. 
A. 
What's his last name? 
Q. 
And have you spoken to Illiabout this 
8 
A. 
No, sir. 
9 
Q. 
Have you spoken to 
about this case? 
10 
A. 
Not in detail, but yes. 
11 
MS. BELOHLAVEK: Are we referring to 
12 
13 
THE WITNESS: Yes. 
14 
MR. TEIN: Yes. 
15 
MS. BELOHLAVEK: Okay. 
16 
BY MR. TEIN: 
17 
Q. 
Have you spoken to =about 
this case? 
18 
A. wit 
19 
0. 
Do you have a friend named 
20 
A. 
I do not have a friend named 
21 
Q. 
From freshman year? 
22 
A. 
No. 
23 
Q. 
How about FM
24 
A. 
No. 
25 
Q. 
Have you spoken to 
about this case? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
127 W 316 
EFTA00234350
Sivu 28 / 100
Case 9:08-cv-80804-KAM 
Dq jg ent1-2 
Entered on FLSD Docket 07/21/2008 
Page 28 of 100 
nsor & Associates 
Roparnnp and 1 ranscrepnon. Inc 
Page 104 
1 
A. 
No. 
2 
Q. 
What's her last name? 
3 
A. IIIIIIIIIr 
I don't know how to spell it. 
4 
Q. 
Is she the person whose house you went to 
5 
on New Year's this year? 
6 
A. 
No. I wasn't at her house on New Year's. 
7 
Q. 
Where were you when you took the picture of 
8 
"Can you say blazed," that's on your website? 
9 
A. 
I wouldn't know or -- wait. We were at a 
10 
birthday party for some girl's 16th birthday. 
11 
Q. 
Were you drinking at that party? 
12 
A. 
No. There was no alcohol or anything 
13 
there. 
14 
Q. 
What does "blaze" mean to you? 
15 
A. 
It's like -- it just means like messed up. 
16 
But we weren't, if you look at the picture. 
17 
Q. 
Messed up like drunk, right? 
18 
A. 
Sure. 
19 
Q. 
Who's 
20 
A. 
A girl I know, like from like two years 
21 
ago. 
22 
Q. 
She's the one you were supposed to be 
NEW
23 
staying with when you went drinking with 
24 
A. 
No. 
25 
Q. 
What's I 
last name? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
125 ot 315 
EFTA00234351
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Case 9:08-cv-80804-KAM 
Do 
ent 1-2 
Entered on FLSD Docket 07/21/2008 
Page 29 of 100 
sor & Associates 
Reporting and Transcription, Inc 
1 
2 
3 
4 
A. 
Q. 
A. 
Q. 
Page 105 
live? 
In Royal Palm. 
Where does she 
I don't know. 
5 
A. 
Uh-huh. I'm guessing. 
6 
Q. 
Do you know her phone number? 
7 
A. 
No, I do not. 
8 
Q. 
Let's look at 25-010. 
9 
A. 
See, I'm drinking --
:0 
Q. 
I'm not asking you about what you're 
11 
drinking. 
12 
Who are the men in this photo who are 
13 
pretending to gang up on you and stab you with knives? 
14 
who are they? 
15 
A. 
and 
16 
Q. 
Are these firemen? 
17 
A. 
Are those? . 
-- he said the 
18 
two stabbing with knives. That's why I said that. I 
19 
don't know. That's 
and 
20 
Q. 
Are these firemen? 
21 
A. 
No. They're all on -- except UMW 
22 
they're all on full rights for football. 
23 
Q. 
Go to 025-015. 
24 
MR. LEOPOLD: 025 dash? 
25 
MR. TEIN: 015. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
129 ot 315 
EFTA00234352
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Case 9:08-cv-80804-KAM 
ent 1-2 
Entered on FLSD Docket 07/21/2008 
Page 30 of 100 
sor & Associates 
Ron/wimp and ranscrucion. inc. 
Page 106 
1 
THE WITNESS: Gosh, that's so long ago. 
2 
BY MR. TEIN: 
3 
Q. 
Who took the photo of you licking the 
4 
penis? 
5 
A. 
My stepmother. 
6 
Q. 
Whose idea -- that was your stepmother's 
7 
idea? 
8 
A. 
It was in Buca di Beppo, where she works 
9 
currently, and that was before she worked there. And we 
10 
just thought it would be funny. 
11 
MR. TEIN: 19-007. Can you enlarge that? 
12 
BY MR. TEIN: 
13 
Q. 
Who took this photo of you simulating you 
14 
having sex with a man? 
15 
A. 
We're not simulating having sex, and 
16 
it's -- oh, and the person who took it was, I'm pretty 
17 
sure, =out 
I know him as= 
I don't know his 
18 
last name. 
19 
Q. 
Go to 19-006, please. 
20 
Who took this photo of you simulating sex 
21 
with a man? 
22 
A. 
The same person. And we're not simulating 
23 
having sex, Mr. --
24 
Q. 
Tein. 
25 
Did you post that on the Internet? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
17001 716 
EFTA00234353
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Case 9:08-cv-80804-KAM 
Doc 
ent 1-2 
Entered on FLSD Docket 07/21/2008 
Page 31 of 100 
nsor & Associates 
Raparti top and Transcript& Inc. 
1 
Page 107 
A. 
Actually, this is an old MySpace I never 
2 
finished and I never like did anything. I just kind of 
3 
made it and left it. 
4 
Q. 
So the answer is yes, you posted this on 
5 
MySpace? 
6 
A. 
Yup. 
7 
Q. 
Go to 25-016. Who took this photo of you 
8 
simulating sex with a woman? 
9 
MR. LEOPOLD: Object to the form of the 
10 
question. Argumentative. 
11 
THE WITNESS: First off, she's piercing my 
12 
belly button or repiercing it, and I'm pretty sure 
13 
it was just like we put up a camera somewhere and 
14 
put a timer on it. We didn't have anybody take 
15 
it. 
16 
BY MR. TEIN: 
17 
Q. 
You posted that on your MySpace page? 
18 
A. 
Yeah. 
19 
Q. 
Go to 25-013. Is that a photo of you? 
20 
A. 
Yep. 
21 
Q. 
Who's in the photo with you? 
22 
A• 
23 
Q. 
24 
A. 
Yep. 
25 
Q. 
Is this you coming out of the shower? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
131 01315 
EFTA00234354
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Case 9:08-cv-80804-KAM 
Do
yrjent 1-2 
Entered on FLSD Docket 07/21/2008 
Page 32 of 100 
nsor & Associates 
Reporting and "'mac ti plum, Mc 
Page 108 
1 
A. 
Yes. 
2 
Q. 
Are you clothed in this picture? 
3 
A. 
Yeah. I have a halter dress on. 
4 
Q. 
Where is that picture taken? 
5 
A. 
In 
house. 
6 
Q. 
Did you post that on the Internet? 
7 
A. 
Yes. 
8 
Q. 
All right. 
9 
MR. TEIN: You can take that down. 
10 
BY MR. TEIN: 
11 
Q. 
Now your boyfriend is 
12 
correct? 
13 
A. 
Yeah. 
14 
Q. 
You lie about your age in order to conceal 
15 
something about your relationship with 
16 
isn't that correct? 
17 
A. 
No. 
:8 
Q. 
IIIIIIII 
22 years old, isn't he? 
19 
A. 
Yes. 
20 
Q. 
And 
a firefighter with the Palm 
21 
Beach Fire Department, right? 
22 
A. 
Yup. 
23 
Q. 
Does the Palm Beach Fire Department know 
24 
that your boyfriend is dating an underage girl? 
25 
A. 
Actually, mister, it's legal. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
132 o1316 
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Case 9:08-cv-80804-KAM 
D 
ent 1-2 
Entered on FLSD Docket 07/21/2008 
Page 33 of 100 
ill  
nsor & Associates 
Reprint np and Transcliptiam,lnc 
Page 109 
1 
O. 
Well --
2 
MR. LEOPOLD: Just answer the question, 
3 
IIIIIIIIII 
4 
THE WITNESS: Yes. 
5 
BY MR. TEIN: 
6 
Q. 
Did they know two weeks ago that you were 
7 
dating an underage girl (sic)? 
8 
A. 
Yes. I met everybody in there. 
9 
Q. 
Did they know your age? 
10 
A. 
Yes. 
11 
Q. 
Did you lie about your age so that the fire 
12 
department wouldn't think thatillillis committing a 
13 
crime by having a sexual relationship with an underage 
14 
girl? 
15 
MS. BELOHLAVEK: Objection. Assumes facts 
16 
not in evidence. 
17 
BY MR. TEIN: 
Q. 
You can answer the question. 
19 
A. 
No. 
20 
Q. 
Does the Palm Beach Police Department know 
21 
that 
is having a sexual relationship with an 
22 
underage girl? 
23 
MR. LEOPOLD: Don't guess. Answer if you 
24 
know. 
25 
THE WITNESS: Can you repeat the question? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
133 ot 315 
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Case 9:08-cv-80804-KAM 
Qgcent1-2 
Entered on FLSD Docket 07/21/2008 
Page 34 of 100 
nsor & Associates 
Reporting and lanstripnon. Inc. 
Page 110 
1 
BY MR. TEIN: 
2 
Q. 
Does the Palm Beach Police Department know 
3 
that'll. a member of the Palm Beach Fire Department, 
4 
is having a sexual relationship with an underage girl? 
5 
A. 
I'm guessing no. 
6 
Q. 
You lie about your twin sister 
don't 
7 
you? 
8 
MR. LEOPOLD: Objection. Argumentative. 
9 
BY MR. TEIN: 
10 
0. 
Don't you? 
11 
A. 
No. I have never lied for or to 
12 
Q. 
You lie about the fact that she has a drug 
13 
hab:.t, right? 
14 
A. 
No. I would never accuse my sister of 
15 
having a drug habit. 
16 
Q. 
Do you try to conceal the fact that she has 
17 
a drug habit? 
18 
MR. LEOPOLD: Objection. Argumentative. 
19 
BY PR. TEIN: 
20 
Q. 
You can answer the question. 
21 
A. 
No. My sister does not have a drug habit. 
22 
Q. 
You lied when you went to the crack house 
23 
in Georgia, didn't you? 
24 
MR. LEOPOLD: Objection. Argumentative. 
25 
Lack of foundation, lack of predicate. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
17144715 
EFTA00234357
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Case 9:08-cv-80804-KAM 
D 
nt 1-2 
Entered on FLSD Docket 07/21/2008 
Page 35 of 100 
n5or & Assocates 
Ramming and lranstripnon, Inc 
1 
2 
3 
4 
5 
Page 111 
THE WITNESS: Never -- what did you say? 
BY MR. TEIN: 
Q. 
You lied when you went to the crack house 
in Georgia, didn't you? 
MR. LEOPOLD: Objection. Argumentative. 
6 
Lack of foundation, lack of predicate. 
7 
BY MR. TEIN: 
8 
Q. 
You can answer the question. 
9 
A. 
I have never been to a crack house. 
10 
Q. 
Who don't you lie to? 
11 
MR. LEOPOLD: Objection. Argumentative. 
12 
Don't answer the question. 
13 
MR. TEIN: Certify it. 
14 
CERTIFIED QUESTION 
15 
BY MR. TEIN: 
16 
Q. 
You don't lie to IIIIIIIdo you? 
17 
MR. LEOPOLD: Objection. Asked and 
18 
answered. 
:9 
Don't answer the question. 
20 
BY MR. TEIN: 
21 
Q. 
No. You can answer that question. 
22 
MR. LEOPOLD: No. I just told her not to. 
23 
You've asked that question about five --
24 
MR. TEIN: No, I haven't. 
25 
MR. LEOPOLD: Don't answer the question. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
WS 0 316 
EFTA00234358
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Case 9:08-cv-80804-KAM 
Do • 
nt 1-2 
Entered on FLSD Docket 07/21/2008 
Page 36 of 100 
nsor & Associates 
Reaaratc end Transcri pap. Inc 
Page 112 
1 
MR. TEIN: I'll certify it. 
2 
 
CERTIFIED QUESTION 
3 
MR. LEOPOLD: For the record, you have to 
4 
stop interrupting me because she can't take down 
5 
both of us talking at the same time. 
6 
BY MR. TEIN: 
7 
Q. 
You tell _the 
truth, don't you? 
8 
A. 
Excuse me? 
9 
Q. 
You tell - the truth, don't you? 
10 
A. 
When it's -- yes, I tellellftthe truth. 
11 
Q. 
Who's 
drug dealer? 
12 
A. 
My sister does not have a drug dealer. She 
13 
lives in Georgia with my mother. 
14 
Q. 
Okay. Who is the drug dealer who dropped 
15 
you and IIIIIIIoff at 5:45 a.m., in 2006, after being out 
16 
all night, the two of you, using drugs at Palm Beach 
17 
Country Estates where your father called the police? 
18 
A. 
19 
Q. 
He's the drug dealer? 
20 
A. 
He is a drug dealer. 
21 
Q. 
Do you remember 
was arrested by the 
22 
Palm Beach Police Department and taken to the Juvenile 
23 
Assessment Center that morning? 
24 
A. 
I do remember that. 
25 
Q. 
Now before you massaged Epstein, you were 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
136 o1316 
EFTA00234359
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Case 9:08-cv-80804-KAM 
nt 1-2 
nte/ed on FL$D Docket 07/21/2008 
Page 37 of 100 
nsor & Associates 
Reporting and Transcri rizi no, Inc 
Page 113 
1 
involuntarily admitted into a juvenile educational 
2 
facility; isn't that right? 
3 
A. 
Did you say involuntarily? 
4 
Q. 
Yes. 
5 
A. 
No. I was willing to go. I -- duly said 
6 
sure. 
7 
Q. 
And you went there because you were lying 
8 
so much, no one could control you; isn't that correct? 
9 
A. 
That's very incorrect. 
10 
Q. 
Now you lie to your parents all the time, 
11 
dor't you? 
12 
A. 
Incorrect. 
13 
MR. LEOPOLD: Objection. Argumentative. 
1 4 
BY MR. TEIN: 
15 
Q. 
Sorry? 
16 
A. 
Incorrect. 
17 
Q. 
The day you went to Epstein's house you 
18 
lied to your father about where you were going; isn't 
19 
that correct? 
20 
A. 
Correct. 
21 
Q. 
You admitted to the police that you told 
22 
you: father that you were going shopping, didn't you? 
23 
A. 
Yes. 
24 
Q. 
And that was a lie, wasn't it? 
25 
A. 
Yes. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
137 8715 
EFTA00234360
Sivu 38 / 100
Case 9:08-cv-80804-KAM 
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Page 38 of 100 
nsor 
Associates 
Ropnm ns and Transcripoco, 
1 
2 
3 
4 
Page 114 
Q. 
And isn't it true that your father has 
accused you of lying? 
A. 
All the time. 
Q. 
Didn't your father throw you out of the 
5 
house Thanksgiving of this past year because you were 
6 
lying so much to him? 
7 
A. 
Yes, he did kick me out. No, that's not 
8 
the reasons why. 
9 
Q. 
Didn't your father throw your sister 
10 
out of the house, too? 
11 
12 
Q. 
13 
after Thanksgivings, right? 
14 
15 
Q. 
Sounds about right? 
16 
A. 
Sure. 
17 
Q. 
And the reason he threw her out of the 
18 
house was because she was lying, too? 
19 
MR. LEOPOLD: Objection. Lack of 
20 
foundation. Calls for speculation. 
21 
BY R. TEIN: 
22 
Q. 
When your counsel coaches you, you say it's 
23 
correct, right? 
24 
25 
MR. LEOPOLD: Objection. 
A. 
Yes. 
And he threw her out of the house the week 
A. 
I don't know the date, but sure. 
A. 
I've never been coached. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
13601316 
EFTA00234361
Sivu 39 / 100
Case 9:08-cv-80804-KAM 
nt 1-2 
ntgred on FL,SD Docket 07/21/2008 
Page 39 of 100 
sor ) Associates 
Report, np, and "transcription. Inc. 
1 
BY MR. TEIN: 
2 
Q. 
Page 115 
Okay. When your counsel that it was there 
3 
was lack of foundation, you agree with your counsel, 
4 
richt? 
5 
A. 
I was like saying, "Yeah, let's move on," 
6 
because there was no point to asking that question. 
7 
Q. 
Your father threw'," out of the house 
8 
because she was lying, correct? 
9 
MR. LEOPOLD: Objection. Lack of 
10 
foundation. 
11 
Hold on... 
Let me just make the 
12 
objection. 
13 
Lack of foundation, predicate, calls for 
14 
speculation. 
15 
BY MR. TEIN: 
16 
Q. 
Answer. 
17 
A. 
I'm not my sister. I don't know. 
8 
Q. 
I want to know what you know only. 
19 
A. 
I don't know. 
20 
Q. 
You don't know. That's your answer? 
21 
A. 
Yes. 
22 
Q. 
Now your parents filed the police report 
23 
regarding Mr. Epstein, right? 
24 
A. 
Yes. 
25 
Q. 
Now your parents are also lying, aren't 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
13901616 
EFTA00234362
Sivu 40 / 100
Case 9:08-cv-80804-KAM 
nt 1-2 
;ritexed on FLSD,Docket 07/21/2008 
Page 40 of 100 
sor P,ssociates 
Ropnrunfi and l'unscription. lac. 
1 
2 
3 
4 
they? 
Page 116 
A. 
Yes. 
MR. LEOPOLD: Just so the record is clear, 
the father -- because the mother was up north. 
5 
MR. TEIN: Don't testify, Counsel. 
6 
MR. LEOPOLD: So the record is clear, just 
7 
the father. The mother was --
8 
MR. TEIN: Counsel, don't coach and 
9 
testify, please. That's absolutely improper. 
10 
MR. LEOPOLD: You just asked the wrong 
11 
question. 
12 
MR. TEIN: You can't coach her that way and 
13 
you well know it. 
14 
MR. LEOPOLD: For the record, it's the 
15 
father. He's remarried, I think on his third 
16 
marriage. 
17 
MR. TEIN: You cannot -- it's absolutely, 
18 
totally against the rules and you know it. 
19 
MR. LEOPOLD: The natural mother lives in 
20 
Georgia. 
21 
MR. TEIN: You need to behave yourself, 
L2 
lawyer. 
23 
MR. LEOPOLD: The natural mother lives in 
24 
Georgia. The father is here locally. 
25 
MR. TEIN: Stop coaching. Stop talking. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
14001316 
EFTA00234363
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