EFTA00230786

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 74 of 100 
nsor & Associates 
Reponing aid Tram ripurm, Inc 
1 
2 
Page 48 
Florida Bar? 
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 
Q. 
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 
Q. 
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 fia 
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. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
74 a 316 
EFTA00231086

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 75 of 100 
nsor & Associates 
°porting nail Transcriptuon, Inc. 
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: 
1.9 
Q. 
You discussed the lawsuit? 
20 
A. 
Yes. 
21 
Q. 
Did 
toll 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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
7$ of 316 
EFTA00231087

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 76 of 100 
nsor & Associates 
Reponinp and Transcription, Inc.
Page 50 
1 
Q. 
Why did the meeting take place at 
2 
Mouse? 
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 
, a woman? 
15 
A. 
I don't know. 
16 
Q. 
Did Ms. 
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 
21 
22 
A. 
Not to my knowledge. 
23 
Q. 
How about an agent named 
24 
A. 
No, sir. 
25 
Q. 
How about an agent named 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
lief 311 
EFTA00231088

Case 9:08-cv-80804-KAM 
Do 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 77 of 100 
4 
n5or & Associates 
Remitting and Trinariptiom, Inc.
Page 51 
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. 
Uh-huh. 
10 
Q. 
-- did anyone ever discuss with you that 
11 
yot 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 I 
24 
wouldn't know. 
25 
Q. 
So your testimony is that you have never 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
77 of 316 
EFTA00231089

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 78 of 100 
sor & Associates 
Roponctip, ad Tnnuripwn,dnc. 
• . 
Page 52 
1 
regftytd a victim notification letter, correct? 
2 
rect. 
3 
Q. 
And your testimony is that you don't know 
4 
if your parents have ever received a victim notification 
5 
letter, correct? 
6 
A. 
Correct. 
7 
Q. 
Have you given any evidence to prosecutors 
8 
or law enforcement in this case? 
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 
O. 
You gave your cell phone to whom? 
22 
A. 
23 
Q. 
Did she keep it? 
24 
A. 
Ask her. 
25 
Q. 
You gave it to her and then you didn't get 
na4b 
.1•••••••• ••••• 
Yd.* 
••••• 
71 e1311 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00231090

Case 9:08-cv-80804-KANA 
Document 1 
7)M 70 
Entered on FLSD Docket 07/21/2008 
Page 79 of 100 
nsor & Associates 
Reporting and Transc option. Inc 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21. 
22 
Page 53 
it back at the end of the meeting? 
A. 
No. They -- yeah. No. They have it. I'm 
guessing. I don't have it. 
Q. 
How much money are you hoping to get out of 
Mr. Epstein? 
MR. LEOPOLD: Objection to the form of the 
question. Attorney/client privilege. 
BY MR. TEIN: 
Q. 
How much money are you hoping to 
yourself, hoping to get out of Epstein? 
MR. LEOPOLD: Same. Same objection, 
attorney/client privilege. 
Don't answer the question. 
BY MR. TEIN: 
you. 
get, you, 
Q. 
I'm not asking about what your lawyer told 
MR. LEOPOLD: I'm instructing her not to 
answer the question, because any of those 
conversations involve her counsel. 
MR. TEIN: Certify that. 
MR. LEOPOLD: Please. 
 
CERTIFIED QUESTION 
23 
BY MR. TEIN: 
24 
Q. 
Now, 
you lied to get out of this 
25 
deposition, didn't you? 
•••••••••• 
Ph. 
Fax. 
. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
I 
EFTA00231091

Case 9:08-cv-80804-KAM 
Document 1 
80 of 318 
Entered on FLSD Docket 07/21/2008 
Page 80 of 100 
sor & Associates 
Ropnnung and Tranticription. Inc 
1 
A. 
No, sir. 
2 
Q. 
Page 54 
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 
19 
of foundation. 
20 
MR. TEIN: Are you instructing her not to 
21 
answer? 
22 
MR. LEOPOLD: I am. 
23 
MR. TEIN: Certify it. 
24 
MR. LEOPOLD: Please. 
25 
object to the form of the question. Lack 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00231092

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 81 of 100 
sor & Associates 
SnRoporunE end Traasciipcion, 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 friend 
to 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 
18 
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 
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. 
Fax. 
1655 Paim Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
II of 316 
EFTA00231093

Case 9:08-cv-80804-KAM I D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 82 of 100 
sor 8,z Associates 
Rowans and Tranunpoce. lat. 
Page 56 
1 
has been marked for identification yet. 
2 
BY MR. TEIN: 
3 
Q. 
all 
--
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 
3 
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. ea 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. a 
right? 
23 
A. 
Yes. 
24 
Q. 
a/ 
your friend at the 
25 
Quarterdeck Tavern, right? 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
Ili WM 
EFTA00231094

53 04 316 
Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 83 of 100 
4 nsor & Associates 
Repertins and Transcorm. bc 
1 
A. 
Yes. 
Page 57 
2 
Q. 
your 
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 
8 
her name tag, correct? 
9 
A. 
Yes. 
10 
Q. 
Your testimony under oath is that's just a 
11 
coincidence, right? 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
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 
22 
subpoena, correct? 
23 
A. 
Correct. 
24 
Q. 
You knew before the day that you switched 
25 
name tags with 
that the process servers were 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00231095

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 84 of 100 
sor & Associates 
Rapornna and Transtriptial. 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 :dee who they were or what their intentions were. But 
13 
1 thought they were just people I didn't want to talk to. 
14 
So 1 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. 
84 04 31$ 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00231096

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 85 of 100 
sor & Associates 
RminniumWTrammorwm3m 
Page 59 
1 
MR. LEOPOLD: I'll certify it. 
2 
 
CERTIFIED QUESTION 
3 
She's answered that question. She's explained it five 
4 
tines already. The fact that Counsel doesn't like the 
5 
answer, that's a different query. 
6 
MR. TEIN: Stop making speaking objections. 
7 
MR. LEOPOLD: I'm not. I'm not going to 
8 
put up with it, because it's in appropriate, Jack, 
9 
and you know it. I will not allow Counsel to 
10 
berate a witness, whether it's in a criminal case 
11 
or a civil case, whether my client or --
12 
MR. TEIN: Calm down. 
13 
MR. LEOPOLD: Excuse me. 
14 
No, I'm not going to allow it. That is not 
15 
proper. 
16 
MR. GOLDBERGER: Okay. 
17 
MR. LEOPOLD: If he wants to say that she's 
18 
lying after asking it five times and her 
19 
explaining in great detail, he can do that. But 
20 
I'm not going to allow her to answer, nor be 
21 
harassed by him. It's improper. 
 22 
MR. GOLDBERGER: Okay. But your response 
23 
that Counsel doesn't like the question -- or 
24 
doesn't like the answer -- just let me finish. 
25 
MR. LEOPOLD: Absolutely. I wasn't going 
115t4311 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00231097

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 86 of 100 
nsor & Associates 
Roportins and 'Franc ripen, ine 
Page 60 
8 al 314 
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. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00231098

$7 of 316 
Case9:08-cv-80804-KAM 
4 
iument1 
Entered on FLSD Docket 07/21/2008 
Page87of100
bsor & Associates 
Repot:ins and Mimic ripm. Inc. 
Page 61 
1 
MR. LEOPOLD: This is really big stuff that 
2 
you're going through. But that's fine; just ask 
3 
your question and move on. But do it one time. 
4 
If you don't understand it, I'll let you follow 
5 
up, but I'm not going to allow you to ask the same 
6 
question time and again and then call her a liar. 
7 
Just ask the question, get the answer and move to 
8 
the next subject matter. 
9 
MR. TEIN: Ted, I'm sitting right across 
10 
the table from you. 
11 
MR. LEOPOLD: Yes, sir. 
12 
MR. TEIN: Please be quiet. Don't yell. 
13 
MR. LEOPOLD: I will not be quiet. 
14 
MR. TEIN: Stop yelling. 
15 
MR. LEOPOLD: Lewis, when I'm yelling 
16 
you'll know it. I will not --
17 
MR. TEIN: My name is not Lewis. 
18 
MR. LEOPOLD: I thought your first name was 
19 
Lewis, Mr. Tein. 
20 
MR. TEIN: You watched me for three days at 
21 
the evidentiary hearing where you sat in the back 
22 
23 
MR. LEOPOLD: Well, that's the impressio 
24 
you must have made in the courtroom. 
25 
1 will not be quiet. 
of the courtroom. You should know who I am. 
Ph. 
- Fax. 
1655 Palm Beach Lakes B'vd., Su.te 500 - West Palm Beach, FL 33401 
EFTA00231099

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 88 of 100 
sor & Associates 
Rs:parting and Transcription. 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 taken.) 
8 
BY MR. TEIN: 
9 
Q. 
Okay. 
after you told your manager 
10 
at the Quarterdeck Tavern everything that was going on 
11 
and he told you he would help you any way he could, he 
12 
hid you in the kitchen from the process servers, correct? 
13 
A. 
Incorrect. 
14 
Q. 
Isn't it true that lying to avoid service 
15 
is a meaningless lie to 
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. 
IIIIIIIIr 
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. 
Illet311 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00231100

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 89 of 100 
S
nsor & Associates 
Ronornns and ltanxripsion. Inc 
Page 63 
1 
Q. 
Where were you when IIIIIIrtold this 
2 
soreone that you were not at the Quarterdeck Tavern? 
3 
A. 
Eating nachos. 
4 
Q. 
At the Quarterdeck Tavern? 
5 
A. 
Yes. 
6 
Q. 
What did you do so that -would 
lie to 
7 
the process servers for you? 
B 
A. 
Nothing. 
9 
Q. 
You just got him to lie for you, didn't 
10 
you? 
11 
A. 
No. I had no influence on him saying I 
12 
wasn't there. 
13 
Q. 
He took that upon himself? 
14 
Isn't it true that Mr. Epstein's process 
15 
servers had to ask the police to get you out of the 
16 
restaurant so that they could serve you? 
17 
MR. LEOPOLD: Objection. Lack of 
18 
foundation, predicate. 
19 
BY MR. TEIN: 
20 
Q. 
You can answer the question. 
21 
MR. LEOPOLD: If you know. Don't guess. 
22 
THE WITNESS: No. Can you repeat the 
23 
question? 
24 
MR. TEIN: Don't coach. 
25 
MR. LEOPOLD: Don't guess. 
se\ 
I90316 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00231101

Case 9:08-cv-80804-KAM 
Doc ment 1 
Entered on FLSD Docket 07/21/2008 
Page 90 of 100 
sor & Associates 
fteponing And Tranicription, ]roc 
Page 64 
1 
MR. TEIN: That's a coaching. 
2 
MR. LEOPOLD: No. That's an instruction to 
3 
the client. 
4 
MR. TEIN: No. You don't do that. 
5 
THE WITNESS: Can you repeat the question? 
6 
MR. LEOPOLD: Let me just state for the 
7 
record --
8 
BY MR. TEIN: 
9 
Q. 
Once the police -- isn't it true that 
10 
Mr. Epstein's process servers had to ask the police to 
11 
get you out of the restaurant so that they could serve 
12 
you? 
13 
A. 
Incorrect. My boss called the police. 
14 
Q. 
And once the police showed up, to stop you 
15 
from lying to avoid service, you made up another lie that 
16 
the process servers had harassed you. Isn't that 
17 
correct? 
18 
A. 
Incorrect. 
19 
Q. 
You lie all the time, don't you? 
20 
MR. LEOPOLD: Objection. 
21 
THE WITNESS: Incorrect. 
22 
BY MR. TEIN: 
23 
Q. 
You have a MySpace page, don't you? 
24 
A. 
No longer do I have a MySpace page. 
25 
deleted it. 
Ph. 
Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
DO of 314 
EFTA00231102

Case 9:08-cv-80804-KAM 
Dcyment1 
Entered on FLSD Docket 07/21/2008 
Page 91 of 100 
sor & Associates 
Raporsins and Trauctiptian, 
Page 65 
1 
Q. 
When did you delete your MySpace page? 
2 
A. 
A couple days ago. 
3 
Q. 
Who told you to take your MySpace page down 
4 
a couple of days ago? 
5 
A. 
Nobody. I'm sick and tired of MySpace. 
6 
Q. 
You all of a sudden got sick and tired of 
7 
MySpace and just a few days before this deposition you 
8 
decided to delete your MySpace page, correct? 
9 
A. 
Correct. 
10 
Q. 
Is that your testimony under oath? 
11 
A. 
Yes. 
12 
Q. 
Did you take your MySpace page down because 
13 
you thought the government might subpoena it? 
14 
A. 
Incorrect. 
15 
Q. 
Hadn't your MySpace page been up for over 
16 
three months before you took it down? 
17 
A. 
Correct. But I also had made tons of 
18 
MySpaces over the last years. I just get tired of them 
19 
and delete them because -- drama -- and make new ones. 
20 
Q. 
We're going to talk about that. 
21 
So you deleted your MySpace page after you 
22 
were already under subpoena for this deposition, correct? 
23 
24 
25 
A. 
Correct. 
Q. 
What about the MySpace page didn't you want 
us to see, lilt 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
91 of 314 
EFTA00231103

1x0716 
Case 9:08-cv-80804-KAM 
ument 1 
Entered on FLSD Docket 07/21/2008 
Page 92 of 100 
sor & Associates 
Rapanistand Tramscripmen. lac. 
Page 66 
1 
A. 
Nothing. 
2 
Q. 
Well, we're going to come back to MySpace 
3 
in a second. 
4 
A. 
You do that. 
5 
0. 
going to ask you some questions 
6 
abo-it why you lie about your age so often, okay? 
7 
MR. LEOPOLD: Objection to the form. 
8 
Argumentative. 
9 
BY MR. TEIN: 
10 
Q. 
You lie about your age all the time, don't 
11 
you? 
12 
MR. LEOPOLD: Objection, argumentative. 
13 
THE WITNESS: Incorrect. 
14 
BY MR. TEIN: 
15 
Q. 
You lie about your age to get body 
16 
piercings, don't you? 
17 
A. 
Incorrect. 
18 
Q. 
You have body piercings, don't you? 
19 
A. 
Yes. 
20 
Q. 
You have four body piercings; isn't that 
21 
right? 
22 
A. 
Five. 
23 
Q. 
Other than the piercings on your ears 
24 
I'm not talking about that --
25 
A. 
Oh, then no; just one. 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00231104

Case 9:08-cv-80804-KAM 
DQc 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 93 of 100 
sor & Associates 
Reportin and Tremscriptiaman. 
Page 67 
1 
Q. 
And where is the one body piercing? 
2 
A. 
Belly. 
3 
Q. 
When did you get that? 
4 
A. 
For my birthday, with my stepmother and my 
5 
father. 
6 
Q. 
And when was that? 
7 
A. 
When I was 14. 
8 
Q. 
Okay. So you had that body piercing when 
9 
you met Epstein, correct? 
10 
A. 
It might have been, or maybe that 
yeah, 
11 
either my 14th birthday or my 15th. I honestly don't 
12 
remember. 
13 
Q. 
Now you've lied about your age to get into 
14 
bars by using driver's licenses that aren't yours, 
15 
correct? 
16 
A. 
Incorrect. 
17 
Q. 
Are you swearing under oath that you've 
18 
never done that? 
19 
A. 
Yes, I swear under oath. 
20 
O. 
And you've lied about your age to buy beer, 
21 
correct? 
22 
A. 
Incorrect. 
23 
Q. 
You're swearing under oath that you've 
24 
never lied to stores about your age? 
25 
A. 
I've never lied to a store about my age or 
Ph. 
Fax. 
1655 Pam Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
93.13111 
EFTA00231105