EFTA00230786

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 54 of 100 
nsor & Associates 
Repcontnp. and Tratictirmo, Inc. 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
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20 
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22 
2.3 
24 
25 
Page 28 
MR. TEIN: Stop misrepresenting the record 
and calm down. I'm going to ask my question. 
Stop it. 
BY MR. TEIN: 
Q 
clear. 
MR. LEOPOLD: I think the record is very 
MR. GOLDBERGER: Let me just clarify 
something. When you object to the form of a 
question, you're not instructing the witness not 
to answer the question, are you? 
MR. LEOPOLD: No. And I'm not making that 
objection; only on attorney/client privilege. 
MR. TEIN: Will you stop speaking now so I 
can ask my question? Are you done? 
Okay. I'm going to ask my question. 
BY MR. TEIN: 
Q. 
Listen, IIIIII--
MR. LEOPOLD: Hold on. Stop. 
I've been doing this for 20 plus years and 
have met a lot of attorneys, but I've never had an 
experience like this where I've --
MR. TEIN: Stop your speeches. 
MR. LEOPOLD: If you continue to do this, 
whether it's with me or with my client, I will not 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd.; Suite 500 - West Palm Beach, FL 33401 
5401316 
EFTA00231066

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 55 of 100 
nsor & Associates 
Raped:lop and Tranicrildion, 
Page 29 
1 
2 
3 
Mr. Goldberger knows all this, because I know that 
4 
he wouldn't do this. So I will not put up with 
5 
it. And I think it's highly inappropriate to do 
6 
this with this child sitting here, the way you're 
7 
acting, primarily towards me, and I will not put 
8 
up with it. 
9 
MR. TEIN: Will you please stop your speech 
10 
so I can ask questions? 
11 
MR. LEOPOLD: So long as you act 
12 
professionally, I will do so. But if you continue 
13 
to do it this way, I will leave. 
14 
15 
BY MR. TEIN: 
16 
Q. 
are you sure that before you got to 
17 
Epstein's house no one tried to persuade you to engage in 
18 
sexual activity with Epstein for money? 
19 
MR. LEOPOLD: Asked and answered. 
20 
Objection. 
L1 
MR. TEIN: Did you get her answer? 
22 
THE COURT REPORTER: No, I did not. 
put up with it and I don't need to put up with it 
and it's not appropriate. And I'm sure 
MR. TEIN: Suit yourself. 
23 
THE WITNESS: I'm sure. 
24 
BY MR. TEIN: 
25 
Q. 
Let me ask you a few questions about your 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6501316 
EFTA00231067

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 56 of 100 
sor & Associates 
Reporunp mid Transcripucct Inc 
Page 30 
1 
contact with Jeffrey Epstein. Okay? 
2 
A. 
(Witness nods head up and down.) 
3 
Q. 
Jeff never e-mailed you, did he? 
4 
A. 
No. 
5 
Q. 
Jeff never text messaged you, did he? 
6 
A. 
No. 
7 
Q. 
Jeff never chatted in a chat room with you, 
8 
did he? 
9 
A. 
No. 
10 
Q. 
Before you got to Epstein's house you had 
11 
never spoken to Jeff, had you? 
12 
A. 
No. 
13 
Q. 
And before you got to Epstein's house you 
14 
had never met Jeff? 
15 
A. 
Correct. 
16 
Q. 
Before you got to Epstein's house you had 
17 
never told Jeff that you were under 18, right? 
18 
A. 
No. 
19 
Q. 
Before you got to Epstein's house had you 
20 
ever told Jeffrey that you were under 18? 
21 
A. 
No. I never spoke to the man before that. 
22 
Q. 
And you only went to Jeff Epstein's house 
23 
that one time three years ago, correct? 
24 
A. 
Yes. 
25 
Q. 
You never went there again, correct? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
540311 
EFTA00231068

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 57 of 100 
nsor & Associates 
Reporting and Transcrtpt.nn, loc. 
Page 31 
1 
A. 
No. 
2 
Q. 
All right. Let me ask you two final areas 
3 
of questioning about this and we'll move onto something 
4 
else. Okay? 
5 
A. 
Uh-huh. Yes. I'm sorry. 
6 
Q. 
Before you got to Epstein's did anyone 
7 
associated with Epstein ever call you on the phone and 
8 
try to persuade, induce, entice or coerce you to engage 
9 
in any sexual activity? 
10 
A. 
No. 
11 
Q. 
Before you got to Epstein's did anybody 
12 
associated with Epstein ever contact you on the Internet 
13 
and try to persuade, induce, entice or coerce you to 
14 
engage in any sexual activity? 
15 
A. 
No. 
16 
O. 
IIIII who told you that when you got to 
17 
Jeff Epstein's house you should lie to Jeff about your 
18 
age? 
19 
A. 
20 
Q. 
Was it 
or was it the other girl in 
21 
the car who you rode over with to Epstein's house? 
22 
A. 
23 
Q. 
Who was the other girl in the car with you 
24 
that day? 
25 
A. 
I honestly don't know. 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
570316 
EFTA00231069

Case 9:08-cv-80804-KAM 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 58 of 100 
nsor & Associates 
Rona/in, and Traniciiption. Inc 
Page 32 
1 
Q. 
Had you ever seen her before? 
2 
A. 
No, sir. 
3 
Q. 
You told the police that when you rode over 
4 
to Epstein's you had no idea who she was, right? 
5 
A. 
Correct. 
6 
O. 
You told the police that you didn't know 
7 
her name, but she was like really dark, kind of like a 
8 
Spanish girl? 
9 
A. 
Yes. 
10 
Q. 
Those were your words, right? 
11 
A. 
Yes. 
12 
Q. 
Do you now know who she is? 
13 
A. 
No, sir. 
14 
Q. 
So it was 
who told you to lie about 
15 
your age to Jeff Epstein? 
16 
A. 
Yes, sir. 
17 
Q. 
And "Ill' told you that if you weren't 18, 
18 
Epstein wouldn't let you into his house, right? 
19 
A. 
That's -- yes, yes. 
20 
Q. 
All right. Let's talk for a minute about 
21 
when you first met Jeff. Okay? 
22 
A. 
Sure. 
23 
Q. 
When you first met Jeff he tried to find 
24 
out how old you were, right? 
25 
A. 
Excuse me? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
58.4316 
EFTA00231070

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 59 of 100 
nsor & Associates 
Ropnrtinp aiul Trartscripnon. lnc. 
1 
2 
out how old you were, right? 
Page 33 
Q. 
When you first met Jeff he tried to find 
3 
A. 
Not when we first introduced each other; 
4 
when we get upstairs, then, yes. 
5 
Q. 
During the massage Jeff asked you how old 
6 
you were, correct? 
7 
A. 
Yes, yes. 
8 
Q. 
Now hadn't you already told Jeff's 
9 
ass:.stant, the one who walked you upstairs, that you went 
10 
to college and had just moved down here from Ohio? 
11 
A. 
I never spoke to the lady. 
12 
Q. 
Do you want to rethink that answer? 
13 
MR. LEOPOLD: Is that a question? 
14 
BY MR. TEIN: 
15 
Q. 
Do you want to rethink that answer? 
16 
A. 
No. I didn't really speak with her that 
17 
much. 
18 
Q. 
Do you want to try to refresh your memory 
19 
on that? 
20 
MR. LEOPOLD: Do you have something to 
23. 
refresh her memory with? 
22 
MR. TEIN: Do you want to stop making 
23 
speaking objections? 
24 
MR. LEOPOLD: No. But to refresh someone's 
25 
memory, you show them a document. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
59013111 
EFTA00231071

Case 9:08-cv-80804-KAM 
Do 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 60 of 100 
4 
nsor & Associates 
Rowans and lraitscripacm. Inc 
Page 34 
1 
MR. TEIN: I know how to do this. 
2 
MR. LEOPOLD: Then show her a document. 
3 
MR. TEIN: Stop speaking. 
4 
MR. LEOPOLD: I'm not going to stop 
5 
speaking. I'm going to continue to make the 
6 
record. 
7 
MR. TEIN: You're obstructing. Please 
8 
stop. 
9 
MR. LEOPOLD: I'm not obstructing. But if 
10 
you want to refresh her recollection, you need to 
11 
show her something. 
12 
That's not a proper question. I object to 
13 
the foundation and the predicate of that question. 
14 
MR. TEIN: Are you done? 
15 
MR. LEOPOLD: I am now. Thank you. 
16 
BY MR. TEIN: 
17 
Q. 
Do you want to try to refresh your memory 
18 
as to whether you had any conversation with the woman who 
19 
walked you upstairs in Epstein's house in which you told 
20 
her that you went to college and had just moved down from 
21 
Ohio? 
22 
MR. LEOPOLD: Objection. Object to the 
23 
form of the question. Lack of foundation and 
24 
predicate. 
25 
BY MR. TEIN: 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4001316 
EFTA00231072

Case 9:08-cv-80804-KAM 
ent 1 
teredonFLS,DDocket07/21/2008 
Page 61 of 100 
nsor 
Associates 
Roportiap anti Transcript'''. Inc 
1 
2 
3 
4 
5 
6 
7 
Page 35 
Q. 
You can answer the question. 
A. 
Sure. 
Q. 
Is there anything that would refresh your 
memory that in fact you told Mr. Epstein's assistant, the 
one who walked you upstairs, that you went to college and 
you had just moved down here from Ohio? 
A. 
I don't remember saying that, but if you --
8 
I don't remember saying that myself, so --
9 
Q. 
That would be a lie, right? 
10 
A. 
No. I really don't remember. 
11 
Q. 
So you told Jeff that you were 18 years 
12 
old, correct? 
13 
A. 
Yes. 
14 
Q. 
Do you remember Detective 
of 
15 
the Police Department, Palm Beach Police Department? 
16 
A. 
Yes. 
17 
Q. 
Do you remember you spoke to her? 
18 
A. 
Yes. 
19 
Q. 
Do you remember that you told Detective 
20 
that when you lied about your age to Jeff you said 
21 
it really fast because you didn't want to make it sound 
22 
like you were lying? 
 23
---Ar-I-denit remember-the-words exactly, but-I--
24 
do remember telling her I told him I was 18. 
25 
Q. 
And do you remember telling Detective 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
61 a 316 
EFTA00231073

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 62 of 100 
nsor & Associates 
Repot:ins and Transcription, Inc 
Page 36 
1 
that when you lied to Epstein about your age that you 
2 
said it really fast so Epstein wouldn't realize you were 
3 
4 
A. 
No, I don't remember saying those words 
5 
exactly to her. 1 remember telling her that I told 
6 
Epstein I was 18. 
7 
0. 
Does it sound right to you that you told 
8 
Detective 
that you said your age really fast to 
9 
Epstein --
10 
MS. BELOHLAVEK: Objection. Asked and 
11 
answered. 
12 
BY .MR. TEIN: 
13 
Q. 
-- so he wouldn't think that you were 
14 
lying? 
MR. LEOPOLD: Objection. Asked and 
16 
answered, lack of foundation, mischaracterization 
17 
of her earlier testimony. She's already answered 
18 
that question. 
19 
BY MR. TEIN: 
20 
Q. 
You can answer it. 
21 
MR. LEOPOLD: Same objection. It's been 
22 
asked and answered. 
23 
You can answer. I'ye made the objection. 
24 
THE WITNESS: I forget the question, now. 
25 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
62 o1316 
EFTA00231074

Case 9:08-cv-80804-KAM 
4Agrnent 1 
Entered on FLSD Docket 07/21/2008 
Page 63 of 100 
sor & Associates 
Rep:smut 
lranscririon, Inc 
Page 37 
1 
BY MR. TEIN: 
2 
Q. 
Let me put it again. 
3 
Does it sound right to you that you told 
4 
Detective 
that when you lied about your age to 
5 
Jeffrey Epstein, you said it really fast because you 
6 
didn't want to make it sound like you were lying? 
7 
MR. LEOPOLD: Objection. Lack of 
8 
foundation, asked and answered. 
9 
THE WITNESS: I could have possibly said 
10 
that, yes. 
11 
BY MR. TEIN: 
12 
Q. 
You didn't want Mr. Epstein to know that 
13 
you were lying about your age, right? 
14 
A. 
Correct. 
15 
Q. 
You didn't want Mr. Epstein to know that 
16 
you were not 18 yet, right? 
17 
A. 
Correct. 
18 
Q. 
You wanted Mr. Epstein to believe that you 
19 
really were 18, right? 
20 
A. 
Correct. 
21 
Q. 
Do you remember when Mr. Epstein asked 
22 
where you went to school? 
23 
A. 
Yes. 
24 
Q. 
And you told Mr. Epstein you went to 
25 
Wellington, right? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
I33 0I111 
EFTA00231075

Case 9:08-cv-80804-KAM 4 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 64 of 100 
ior
nsor & Associates 
kg:Toning add Tansciirinn, Inc 
Page 38 
1 
A. 
Yes. 
2 
Q. 
Was that the truth? 
3 
A. 
No. 
4 
Q. 
In fact, you went to Royal Palm, right? 
5 
A. 
Yes. 
6 
Q. 
So you lied to Mr. Epstein again, correct? 
7 
A. 
Yes. 
8 
Q. 
Is Wellington the college that you told 
9 
Jeff's assistant that you were attending? 
10 
A. 
I don't remember having that conversation 
11 
with her, so I wouldn't know if that's what I said. 
12 
Q. 
That was a lie, though, wasn't it? 
13 
MR. LEOPOLD: Objection to the form of the 
14 
question, lack of foundation. You're making an 
15 
assumption. She just answered you she can't tell 
16 
you that. 
17 
MR. TEIN: Speaking objection. And you 
18 
well know that, Mr. Leopold. 
19 
MR. LEOPOLD: She can't answer that 
20 
question. The way you phrased that question, 
21 
you're purposely making her not be honest in her 
22 
testimony. She can't answer a question like that. 
23 
She doesn't remember. So then you say, "So you 
24 
were lying." That's improper and you know that. 
25 
That's not a proper question. And any attorney 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
14.1311 
EFTA00231076

Case 9:08-cv-80804-KAM 
D c went 1 
Entered on FLSD Docket 07/21/2008 
Page 65 of 100 
sor & Associates 
Reporting and Triune:in:ion. Inc 
Page 39 
1 
that would do that to a witnesses or to a person 
2 
that's sitting in this chair is not acting 
3 
professionally. You can't ask a question like 
4 
that. You can do it, but it's not proper. And 
5 
I'm sure you weren't trained that way, certainly 
6 
not ethically. 
7 
MR. TEIN: Will you stop? 
8 
MR. LEOPOLD: I'm not going to stop, 
9 
because the way you're asking that question is 
10 
improper and you know it. 
11 
MR. TEIN: You're losing your cool. 
12 
BY MR. TEIN: 
13 
Q. 
ms. NM 
--
14 
MR. LEOPOLD: Trust me. I'm very calm. 
15 
When I lose my cool, you'll know it. 
16 
MR. TEIN: I do know it. 
17 
BY MR. TEIN: 
18 
Q. 
Ms. IIIIIIIII 
Mr. Epstein never asked you 
19 
to do anything other than massage him, correct? 
20 
A. 
incorrect; because he asked me to take off 
21 
my bra, so that would be two things he's asked me to do. 
22 
Q. 
Other than asking you to take your bra off, 
23 
Mr. Epstein never asked you to do anything with him other 
24 
than massage, correct? 
25 
MR. LEOPOLD: Objection. Foundation, 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
66 or 616 
EFTA00231077

Case 9:08-cv-80804-KAM 
ent 1 
gpteredonFL$DDocket07/21/2008 
Page 66 of 100 
nsor & Associates 
Repotting ad Tunic/intim, Inc. 
Page 40 
1 
predicate. 
2 
THE WITNESS: Correct. 
3 
BY MR. TEIN: 
4 
Q. 
You told the police, in your words, that 
5 
you did not whack him off, right? 
6 
A. 
Correct. 
7 
Q. 
What does that mean? 
8 
A. 
Whack, like whacking off? 
9 
O. 
Your term, what does that mean? 
10 
A. 
Masturbating. 
11. 
Q. 
Mr. Epstein never tried at any time to grab 
12 
your hand, did he? 
13 
A. 
No. 
14 
Q. 
Mr. Epstein never tried to put your hand 
15 
anywhere, did he? 
16 
A. 
No. 
17 
Q. 
At no time did you touch Mr. Epstein's 
18 
penis, did you? 
19 
A. 
No. 
20 
Q. 
And he did not touch you, correct? 
21 
A. 
Incorrect. 
22 
Q. 
Well, you told the police, "At no time did 
23 
he touch me." Were you lying to the police then? 
24 
A. 
No. Well, I wasn't being fully truthful, 
25 
but I wasn't lying. 
Ph. 
Fax. 
1655 Pam Beach Lakes Blvd., Suite 500 - West Palm Beath FL 33401 
Illet316 
EFTA00231078

Case 9:08-cv-80804-KAM 
Qgyfnent 1 
Entered on FLSD Docket 07/21/2008 
Page 67 of 100 
nsor & Associates 
Repomig and Tranicription, Inc. 
1 
Page 41 
Q. 
You told the police twice when you spoke to 
2 
that "at no time did he touch me." Didn't 
3 
you say that to the police? 
4 
A. 
Yeah. 
5 
Q. 
And you're saying that that was not fully 
6 
truthful. Is that what you're saying now? 
7 
8 
A. 
Correct. 
Q. 
And you're saying if you're not fully 
9 
truthful, that's not a lie. Correct? 
10 
A. 
You took that out of context like really 
11 
bac. I didn't mean like that. Touching my legs and 
12 
he never kept his hands to himself the entire time. 
13 
That's what I'm trying to say. 
14 
Q. 
You told the police, "At no times did he 
15 
touch me." You agree with that, correct? 
16 
A. 
No, I don't agree with that, because he did 
17 
touch me. 
18 
Q. 
Did you tell the police that he did not 
19 
touch you, yes or no? 
20 
A. 
It's a possibility, but I do not remember. 
21 
Q. 
Okay. And you did not have any type of sex 
22 
with Jeff, correct? 
23 
A. 
No. 
24 
Q. 
And you did not have any type of oral sex 
25 
with Jeff, correct? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
67 ol 311 
EFTA00231079

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 68 of 100 
sor & Associates 
Ronan Ins and Trariscripunn.loc 
Page 42 
A. 
No. 
2 
Q. 
No type of intercourse with Jeff, correct? 
3 
A. 
Correct. 
4 
Q. 
All right. Let's talk about what happened 
5 
after the massage was over. 
6 
A. 
Okay. 
7 
Q. 
After the massage, you told Epstein that 
8 
you wanted to bring your twin sister back so she could 
9 
make some money, correct? 
10 
A. 
Incorrect. 
11 
Q. 
Your twin sister is IIIIII right? 
12 
A. 
Correct. 
13 
Q. 
And you love -very 
much, don't you? 
14 
A. 
Yes. 
15 
Q. 
And when you left the house you were joking 
16 
with the other girls, weren't you? 
17 
A. 
Incorrect. 
18 
Q. 
Well, when Mend 
the other girl in the 
19 
car that day made their statements to the police they 
20 
told the police that you were joking afterwards. Are you 
21 
saying that they were lying to the police about that? 
22 
A. 
No. But a question or -- questions from 
23 
like she asked me questions, but it wasn't 
24 
joking. She was kind of like in a happy way, like, "Oh, 
25 
what did you do? What did you do?" Like those kind of 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
OS of 311 
EFTA00231080

Case 9:08-cv-80804-KAM 
Docummnt 1 
Entered on FLSD Docket 07/21/2008 
Page 69 of 100 
nsor & Associates 
Roporting And Tranactiptim, ≥nr.
Page 43 
1 
2 
3 
4 
5 
6 
7 
8 
things, but it wasn't joking about it at all. 
Q. 
You joked about it, didn't you? 
A. 
No. 
Q. 
You said to IIIIIII that if you did this 
every weekend you'd be rich, didn't you? 
A. 
No. That's what 
told me. 
Q. 
You didn't tell that to 
MR. LEOPOLD: Objection. Asked and 
9 
answered. 
10 
11 
BY MR. TEIN: 
12 
Q. 
After you left Epstein's house you took the 
13 
money and you went shopping with 
and the other 
14 
girl in the car, correct? 
15 
16 
money. 
17 
Q. 
16 
19 
Q. 
20 
didn't you? 
21 
MR. LEOPOLD: Objection. 
22 
THE WITNESS: No. 
A. 
Incorrect. I didn't spend any of the 
You went to Marshall's, didn't you? 
A. 
I went along, yes, but I didn't --
You went shopping with them at Marshall's, 
THE WITNESS: I guess you could say that. 
23 
MR. LEOPOLD: Objection. Lack of predicate 
24 
and foundation. Mischaracterization of earlier 
25 
testimony. 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
66 of 516 
EFTA00231081

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 70 of 100 
nsor & Associates 
Reporting, And Tranacriptton, 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 
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 
I 
19 
think they were like FBI. 
20 
Q. 
Uh-huh. Did you meet with federal 
21 
prosecutors? 
22 
A. 
They came to my house one time, yes. 
?3 
Q. 
When did they come to your house? 
24 
A. 
Very long ago. 
25 
Q. 
Was it this year, 2008? 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
70 of 315 
EFTA00231082

Case 9:08-cv-80804-KAM 
ent 1 
iltered on FLSD Docket 07/21/2008 
Page 71 of 100 
sor & Associates 
Repaning one Transcriptive, Inc. 
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 
7 
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 
0. 
Did they speak to your parents? 
20 
A. 
That's something you'd have to ask my 
21 
parents. 
22 
O. 
Do you know whether they spoke to your 
parent' 
24 
A. 
No, sir. 
25 
Q. 
You have no idea? 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
11 01 31! 
EFTA00231083

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 72 of 100 
sor & Associates 
Ktriormis an4 Transcriponn, inc. 
Page 46 
1 
A. 
No, sir. 
2 
MR. LEOPOLD: Objection. Asked and 
3 
answered. 
4 
BY MR. TEIN: 
5 
Q. 
So if I say the name to you 
6 
, you don't know who that is? 
7 
A. 
No, sir. 
8 
Q. 
How many women and how many men came to 
9 
your house? 
10 
A. 
: want to say two ladies and two guys. 
11 
Q. 
Did someone named 
come to 
12 
your house? 
13 
A. 
I don't know names, sir. 
14 
Q. 
Do you know who 
is? 
15 
A. 
No, sir. 
16 
Q. 
Do you know who Jeffrey Herman is? 
17 
A. 
Yes. 
18 
Q. 
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 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
72 of 316 
EFTA00231084

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 73 of 100 
sor & Associates 
Repartrns and Tann 
)nc. 
a 
2 
3 
fashion, you may answer. 
THE WITNESS: Okay. 
I wouldn't know. 
Page 47 
4 
BY MR. TEIN: 
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 
11 
is? 
12 
A. 
No, sir. 
13 
Q. 
Does it refresh your recollection that he's 
14 
the number two prosecutor at the U.S. Attorney's Office? 
15 
A. 
No. 
16 
Q. 
That he'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 
Q. 
Without telling me any conversations that 
24 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
73 M310 
EFTA00231085