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FBI VOL00009
EFTA00799605
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 101 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 70 of 100 risor & Associates Reportine bed Transcription. Inc. Page 44 1 BY MR. TEIN: 2 Q. And IIIIIIrbought a purse, right? 3 A. Yes. 4 Q. And you were with her the whole time at 5 Marshall's, correct? 6 A. Yes. 7 Q. Now tell me about when the federal 8 prosecutors told you about getting reimbursed. 9 A. I have no idea what you're talking about. 10 Q. Tell me about when the federal prosecutors 11 spcke to you about getting money you feel you're entitled 12 to from Mr. Epstein. 13 A. I don't know what you're talking about. 14 Q. Do you know who Villafona is? 15 A. No, sir. 16 Q. Did you ever meet with any federal 17 prosecutors? 18 A. I think yeah. I think they were 19 think they were like FBI. 20 Q. tm-huh. Did you meet with federal 21 prosecutors? 22 A. They came to my house one time, yes. 23 Q. When did they come to your house? 24 A. Very long ago. 25 Q. Was it this year, 2008? 70 0116 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001276 EFTA00799705
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 102 of 176 Case 9:08-cv-80804-KAM ent 1 sor EntAssociates ered on FLSDnocket 07/21/2008 Page 71 of 100 steponenindltrarscriptiokinc. Page 45 1 A. It was not this year, no. 2 Q. Was it 2007? 3 A. I'd have to say at least two years ago or a 4 year ago, yeah. So it would be 2007, 2006; but it was a 5 while ago. 6 Q. How many federal prosecutors or FBI agents came to your house? 8 A. I'm trying to remember. I want to say four 9 people came. 10 Q. Did they give you their business cards? 11 A. If they did, I don't remember, and they 12 weren't toward me. Maybe my parents have them. I don't 13 know. 14 Q. Did they give you their cell phone numbers? 15 A. No. 16 Q. Did you ever speak to them on their cell 17 phones? 18 A. No, sir. 19 Q. Did they speak to your parents? 20 A. That's something you'd have to ask my 21 parents. 22 Q. Do you know whether they spoke to'your 74 oarapt'al 24 A. No, sir. 25 Q. You have no idea? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 TI elite 08-80736-CV-MARRA 001277 EFTA00799706
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 103 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 72 of 100 sor & Associates Report's and Transalpine', Inc. Page 46 1 A. No, sir. 2 MR. LEOPOLD: Objection. Asked and 3 answered. 4 BY HR. TEIN: 5 O. So if I say the name to you 6 Villafona, you don't know who that is? 7 A. No, sir. 8 O. How many women and how many men came to 9 your house? 10 A. I want to say two ladies and two guys. 11 Q. Did someone named Jeffrey Sloman come to :2 you: house? 13 A. I don't know names, sir. 14 Q. Do you know who Jeffrey Sloman is? 15 A. No, sir. 16 Q. Do you know who Jeffrey Herman is? 17 A. Yes. 18 0. That's the lawyer who first sued Epstein on 19 your behalf, right? 20 A. Yes. 21 Q. Has Mr. Herman advanced your family any 22 money? 23 MR. LEOPOLD: Any conversations that you've 24 had with Mr. Herman regarding that issue, you are 25 not to disclose. If you've learned in some other 1 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 12 of 3111 08-80736-CV-MARRA 001278 EFTA00799707
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 104 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 73 of 100 nsor & Associates Ropaning Ind Transcripnen. Inc. 3 2 3 4 BY MR. TEIN: fashion, you may answer. THE WITNESS: Okay. I wouldn't know. Page 47 5 Q. You don't know? 6 A. No. 7 MR. LEOPOLD: Objection. Foundation. 8 Attorney/client privilege. 9 BY MR. TEIN: 10 Q. And you say you don't know who Jeff Sloman 11 is? 12 A. No, sir. 13 Q. Does it refresh your recollection that he's 34 the number two prosecutor at the U.S. Attorney's Office? 15 A. No. 16 Q. That he's Villafona's boss? 17 A. No. 18 Q. Does it refresh your memory that he's the 19 ex-partner of Jeff Herman, the first lawyer, who sued 20 you -- sued Mr. Epstein on your behalf for fifty million 21 dollars? 22 A. No, sir. I don't know who he is. 23 O. Without telling me any conversations t at-- 2 4 you've had with your lawyers, how is it that you selected 25 Mr. Herman as your lawyer from the 81,000 members of the Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 7) 4311 08-80736-CV-MARRA 001279 EFTA00799708
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 105 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page74of100 nsor & Associates licpcinIng and Transctiptinm, Inc. Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 Q. Did you ever meet Mr. Herman? 6 A. Once. 7 O. Don't -- don't tell me what you discussed 8 with him. Where did you meet him? 9 A. I was shopping in my -- he showed up at my 10 friend's house. 11 0. Whose house? 12 A. My friend 13 Q. Is that from the Quarterdeck 14 Tavern? 15 A. Yes. 16 Q. And did you have a meeting with him at 17 house? 18 A. Yes. I guess you could say that. 19 Q. And who else was there? 20 A. My Aunt 21 Q. And what was that meeting about? 22 MR. LEOPOLD: Objection. That calls for 23 attorney/client privilege. 24 BY MR. TEIN: 25 Q. What discussions did you have with Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 II of 311 08-80736-CV-MARRA 001280 EFTA00799709
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 106 of 176 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 75 of 100 sor & Associates Reporting and laanscripnnn, Page 49 1 Mr. Herman in the presence of 2 A. None. 3 Q. What discussions did you have in the 4 presence of her aunt? 5 A. Of my aunt? 6 MR. GOLDBERGER: It's the witness's. aunt. 7 BY MR. TEIN: 8 Q. oh, of your aunt. 9 A. The only one that we've ever discussed or 10 ever had. 11 Q. And so you were in a conversation with 12 Mr. Herman and your aunt? 13 A. Yes, sir. 14 Q. And you discussed privileged matters during 15 that conversation? 16 MR. LEOPOLD: Object to the form. I think 17 you might have to educate her on that question. 18 BY MR. TEIN: 19 Q. You discussed the lawsuit? 20 A. Yes. 21 Q. Did tell you about any 22 conversations that she had with Mr. Herman? 23 A. As far as I'm concerned, she's never spoken 24 or she's never had a conversation. She only opened the 25 door and then left. She's the one who answered the door. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 75-3is 08-80736-CV-MARRA 001281 EFTA00799710
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 107 of 176 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 76 of 100 nsor & Associates Rapartino nail Triaratiptico, Page 50 1 Q. Why did the meeting take place ata 2 'l ouse? 3 A. I spent the night that night at her house. 4 Q. And when was this? 5 A. A while ago. 6 Q. How long ago? 7 A. A month and a half ago. I'm guessing. 8 Q. A month and a half ago? 9 A. Uh-huh. 10 Q. So was it before of after Mr. Herman filed 11 the fifty-million-dollar lawsuit against Epstein? 12 A. After. 13 Q. Did you meet with an FBI agent named 14 Nesbitt Kurkendall, a woman? 15 A. I don't know. 16 Q. Did Ms. Kurkendall speak to you about 17 getting reimbursed from Mr. Epstein? 18 A. I've never had a discussion with anyone 19 about getting reimbursed from Mr. Epstein. 20 Q. Have you met with an agent named Jason 21 Richards? 22 A. Not to my knowledge. 23 Q. How about an agent named Tim Slater? 24 A. No, sir. 25 Q. How about an agent named Junior Ortiz? MAIN Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001282 EFTA00799711
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 108 of 176 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 77 of 100 nsor & Associates Report' ng and Trassati Nino, Inc. Page 51 1 A. No. 2 Q. And we've learned that many of the girls, 3 some of whom are as old as 23, were told by the 4 government that they would get money at the end of the 5 criminal prosecution. Does that sound familiar to you?' 6 A. No, sir. 7 Q. Other than Mr. Leopold here -- I'm not 8 asking about Mr. Herman either 9 A. Oh-huh. 10 Q. -- did anyone ever discuss with you that 11 you could get reimbursement for your damages? 12 A. No, sir. 13 Q. Did you or any member -- 14 MR. LEOPOLD: Are you referring to a 15 criminal matter or a civil matter? 16 BY MR. TEIN: 17 Q. Did you or any member -- 18 MR. LEOPOLD: Excuse me. Let me object to 19 the form of the question. 20 BY MR. TEIN: 21 Q. Did you or any member of your family ever 22 get a victim notification letter from anyone? 23 A. I no longer live at that residence and 24 wouldn't know. 25 Q. So your testimony is that you have never Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 nom 08-80736-CV-MARRA 001283 EFTA00799712
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 109 of 176 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 sor & Associates Itoponiojt Ana 1 ranntiPier., 'kg • Page 78 of 100 8 or law enforcement in this case? letter, correct? rgpAwvtd a victim notification letter, correct? Q. Have you given any evidence to prosecutors Q. Correct. And your testimony is that you don't know rect. 3 Page 52 1 2 4 if your parents have ever received a victim notification 5 6 A. 7 9 A. What do you mean by evidence? 10 Q. Well. Anything that you can touch or feel. 11 A. No. 12 MR. LEOPOLD: Objection to the form of the 13 question. 14 BY MR. TEIN: 15 Q. So you haven't given anything physical 16 A. No. 17 Q. -- any item to any prosecutor, police 18 . officer or law enforcement agent, correct? 19 A. My cell phone four years ago or three years 20 ago, but that's it. 21 Q. You gave your cell phone to whom? 22 A. Pagan. 23 Q. Did she keep it? 24 A. Ask her. 25 Q. You gave it to her and then you didn't get 71 0131. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvrt)84Oa3g@v_Wfam Beach, FL 33401 001284 EFTA00799713
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 110 of 176 Case 9:08-ov-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 79 of 100 sor & Associates • Romomn, aid TransctIptiall. Inc. • - • nets* Page 53 1 it back at the end of the meeting? 2 A. No. They -- yeah. No. They have it. I'm 3 guessing. I don't have it. 4 Q. How much money are you hoping to get out Of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7 question. Attorney/client privilege. 8 BY MR. TEIN: 9 Q. How much money arc you hoping to get, you, 10 yourself, hoping to get out of Epstein? 11 MR. LEOPOLD: Same. Same objection, 12 attorney/client privilege. 13 Don't answer the question. 14 BY MR. TEIN: 15 Q. I'm not asking about what your lawyer told 16 you. 17 MR. LEOPOLD: I'm instructing her not to 18 answer the question, because any of those 19 conversations involve her counsel. 20 MR. TEIN: Certify that. 21 MR. LEOPOLD: Please. 22 CERTIFIED QUESTION 23 BY MR. TEIN: 24 Q. Now, you lied to get out of this 25 deposition, didn't you? Ph. 561.682.0905 - Fax. 561.682.1771 . 1655 Palm Beath Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001285 EFTA00799714
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 111 of 176 50 el MI Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page8001100 *nsor & Associates Roprming and Transcription. Inc 1 A. No, sir. Page 54 2 Q. You didn't want to come to court today and 3 tell the story that you had told to the police under 4 oath, did you? 5 MR. LEOPOLD: Object to the form of the 6 question. Lack of foundation, predicate. 7 THE WITNESS: No. I have no problem coming 8 here and talking to you. 9 BY MR. TEIN: 10 Q. And to avoid getting served with a lawful 11 subpoena, you lied about your name, didn't you? 12 A. No. 13 Q. And in fact, just lying yourself wasn't 14 enough, was it? 15 MR. LEOPOLD: Objection to the form of the 16 question. 17 Don't answer it. It's not a question. 18 object. to the form of the question. Lack 19 of foundation. 20 MR. TEIN: Are you instructing her not to 21 answer? 22 MR. LEOPOLD: I am. L3 MR. TEIN: Certify it. 24 MR. LEOPOLD: Please. 25 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001286 EFTA00799715
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 112 of 176 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 81 of 100 *nsor & Associates koportins and Transcription, Inc. Page 55 1 CERTIFIED QUESTION 2 BY MR. TEIN: 3 Q. You asked your co-workers 4 MR. LEOPOLD: It's vague and ambiguous. 5 BY MR. TEIN: 6 Q. You asked your co-workers at the 7 Quarterdeck Tavern to lie for you, didn't you? 8 A. No. I informed my boss about what was 9 going on and he told me that he would help in any way 10 that he can. 11 Q. Okay. You got your friendillillippto lie 12 by switching name tags with you, correct? 13 A. Incorrect. It was a coincidence that same 14 night she was not wearing her name tag; she was wearing 15 mine. But I was also not wearing -- I was wearing my 16 name tag. Everyone switches name tags. It just so 17 happens it was a coincidence that same night the people 1$ came with the papers. 19 MR. TEIN: Will you put up Exhibit 18-001? 20 MR. GOLDBERGER: And mark 18-001 for 21 identification purposes to this deposition. 22 MR. LEOPOLD: None of them have been marked It ot 314 23 yet. Can we mark them and put them as attachment 24 to the depositions? Because I think you've shown 25 three photos now. And this is the only one that Ph, 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001287 EFTA00799716
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 113 of 176 Case 9:08-cv-80804-KAM p ent 1 Entered on FLSD Docket 07/21/2008 Page 82 of 100 . ni 1sor & Associates Ropo ng nad Transcngdon Inc Page 56 1 has been marked for identification yet. 2 BY MR. TEIN: 3 Q. -- 4 MR. LEOPOLD: Hold on just a second. Just 5 so the record is clear -- 6 MR. TEIN: I'm not speaking to you. 7 MR. LEOPOLD: Okay. Then don't speak to me 8 then. But I'll speak to Mr. Goldberger, perhaps. 9 But at least for the record, can we put on 10 the record what the previous two photographs were 11 marked for identification? 12 MR. GOLDBERGER: We will make sure that the 13 record is clear at the end of the deposition so 14 that there's no ambiguity. 15 MR. LEOPOLD: Thank you. 16 BY MR. TEIN: 17 Q. va I've put a photograph marked 18-001 18 up on the screen. Do you see that? 19 A. Yup. 20 Q. Who is that in the photo? 21 A. the left and me on the right. 22 Q. la right? 23 A. Yes. 24 Q. your friend at the 25 Quarterdeck Tavern, right? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001288 EFTA00799717
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 114 of 176 10 11 12 13 14 15 16 17 18 19 20 21 22 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 83 of 100 nsor & Associates Reporting nil TraliSCriplson.1M. 1 A. Yes. Page 57 2 Q. anour friend, who you say the day 3 that the process servers went to serve you with a 4 subpoena for this deposition, just happened -- just. by 5 coincidence, was wearing your name tag? 6 A. Yes, sir. 7 Q. And just by coincidence, you were wearing her name tag, correct? 9 A. Yes. Q. Your testimony under oath is that's just a coincidence, right? A. Total honesty. Q. It just happens to be the day that you were going to be served with a subpoena, correct? A. That wasn't the first day that -- MR. LEOPOLD: just answer the question. It calls for a yes or no. THE WITNESS: Yes. BY MR. TEIN: Q. You said that wasn't the first day you were going to be -- you thought you were being served with a subpoena, correct? Oaf 1S 23 A. Correct. 24 Q. You knew before the day that you switched 25 name tags with that the process servers were Ph. 561.682.0905 - Fax. 561.682,1771 1655 Palm Beach Lakes Blvd,, Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001289 EFTA00799718
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 115 of 176 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 84 of 100 sor & Associates . 1 Roponins and 1'ranscrlN•lne, inc. Page 58 1 looking for you, didn't you? 2 A. No. I knew -- 3 MR. LEOPOLD: Just answer it. It calls for 4 a yes or no. 5 THE WITNESS: Okay. No. 6 BY MR. TEIN: 7 Q. Now you can explain the answer that your 8 counsel stopped you from explaining. 9 A. Okay. I work at Quarterdeck and people 10 were telling me that people were looking for me. So yes, 11 I was aware that people were searching for me. But I had 12 no :.dea who they were or what their intentions were. But 13 I thought they were just people I didn't want to talk to. 14 So I just didn't want to talk to them. And every time 15 they'd come to work I wasn't there. And so happens the 16 night that they came in me and my friend switched name 17 tags. No big deal. 18 Q. That's a lie, isn't it? 19 MR. LEOPOLD: Objection. Don't answer that 20 question. That's harassment and I will not allow 21 it. He could ask the questions and we'll allow a 22 jury to make that determination, but not counsel. 23 I will not allow her to answer that' 24 question. 25 MR. TEIN: Certify it. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001290 EFTA00799719
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 116 of 176 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 85 of 100 nsor & Associates Repletion? and Transcdpoon. 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 9 10 11 12 13 14 15 16 17 18 19 20 21 22 put up with it, because it's in appropriate, Jack, and you know it. I will not allow Counsel to berate a witness, whether it's in a criminal case or a civil case, whether my client or -- MR. TEIN: Calm down. MR. LEOPOLD: Excuse me. No, I'm not going to allow it. That is not proper. MR. GOLDBERGER: Okay. MR. LEOPOLD: If he wants to say that she's lying after asking it five times and her explaining in great detail, he can do that. But I'm not going to allow her to answer, nor be harassed by him. It's improper. 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 MR. LEOPOLD: Absolutely. I wasn't going Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Sulte 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001291 EFTA00799720
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 117 of 176 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 86 of 100 nsor & Associates 'towns anti 7/ascription, Jac Page 60 1401 316 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to interrupt you. MR. GOLDBERGER: Just requires us to say we like the answer to that question. And it's not you and I or you and Mr. Tein who are testifying here. It's the witness. MR. LEOPOLD: Fine. But after the sixth time of asking the same question and then coming back and pointing a finger at her and saying, "You're a liar" -- MR. TEIN: That didn't happen. MR. LEOPOLD: That's fine. But I'm not going to allow her to answer that question, because she's answered that same question and has explained it. Now Counsel might be sitting there rubbing his head with a migraine. That's his problem. But if he can't ask a question appropriately in a professional manner, we will leave. I will not 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. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001292 EFTA00799721
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 118 of 176 Case9:08-cv-80804-KAM cumentl Entered on FLSDIDocket07/21/2008 Page 87 of 100 nsor & Associates Reporting 4nd Tranteriptino. Inc.. . II? el 311 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 8 19 20 21 22 Page 62 MR. LEOPOLD: This is really big stuff that you're going through. But that's fine; just ask your question and move on. But do it one time. If you don't understand it, I'll let you follow up, but I'm not going to allow you to ask the same question time and again and then call her a liar. Just ask the question, get the answer and move to the next subject matter. MR. TEIN: Ted, I'm sitting right across the table from you. MR. LEOPOLD: Yes, sir. MR. TEIN: Please be quiet. Don't yell. MR. LEOPOLD: I will not be quiet. MR. TEIN: Stop yelling. MR. LEOPOLD: Lewis, when I'm yelling you'll know it. I will not -- MR. TEIN: My name is not Lewis. MR. LEOPOLD: I thought your first name was Lewis, Mr. Tein. MR. TEIN: You watched me for three days at the evidentiary hearing where you sat in the back of the courtroom. You should know who I am. 23 MR. LEOPOLD: Well, that's the impressibm 24 you must have made in the courtroom. 25 I will not be quiet. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001293 EFTA00799722
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 119 of 176 Case 9:08-cv-80804-KAM Do ument 1 Entered on FLSD Docket 07/21/2008 Page 88 of 100 sor & Associates FterinninA end Tunectipana, Inc Page 62 1 MR. TEIN: That's obnoxious. Stop being 2 obnoxious. It's stupid. Let's go ahead with the 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 takeh.) 8 BY MR. TEIN: 9 Q. Okay. 'WAIF after you told your manager 10 11 at the Quarterdeck Tavern everything that was going on 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. 22 Q. And what did do to lie for you? 23 A. Said I wasn't there. 24 Q. And who did he tell wasn't there? 25 A. Ask him. of3111 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001294 EFTA00799723
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 120 of 176 Case 9:08-cv-80804-KAM Document 1 EnteredonFLSDDocket07121/2008 Page 89 of 100 $nsor & Associates Ropnaing and Trascripcion. inc. 2 3 4 5 6 7 8 9 10 you? 11 12 13 14 15 16 17 18 19 20 21 22 Page 63 Q. Where were you when IIIIII,told this someone 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 IIIIIIPwould lie to the process servers for you? A. Nothing. Q. You just got him to lie for you, didn't A. No. I had no influence on him saying I wasn't there. Q. He took that upon himself? Isn't it true that Mr. Epstein's process servers had to ask the police to get you out of the restaurant so that they could serve you? MR. LEOPOLD: Objection. Lack of foundation, predicate. BY MR. TEIN: Q. You can answer the question. MR. LEOPOLD: If you know. Don't guess. TEE WITNESS: No. Can you repeat the 00 of 315 23 question? 24 MR. TEIN: Don't coach. 25 MR. LEOPOLD: Don't guess. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 08-80736-CV-MARRA 001295 EFTA00799724