EFTA00231917

Case 9:08-cv-80804-KAM 
D c ment 1 
Entered on FLSD Docket 07/21/2008 
Page 65 of 100 
sor & Associates 
Resin/is aid Transcription. 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. 
--
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. = 
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 
650111I 
EFTA00232197

Case 9:08-cv-80804-KAM 
ent 1 
EnteredonFLSDpocket07/21/2008 
Page 66 of 100 
nsor & Associates 
Ropanint and Tranwription, Inc. 
Page 40 
1 
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 
O. 
What does that mean? 
8 
A. 
Whack, like whacking off? 
9 
Q. 
Your term, what does that mean? 
10 
A. 
Masturbating. 
11 
Q. 
Mr. Epstein never tried at any time to grab 
12 
you: hand, did he? 
13 
A. 
No. 
14 
O. 
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. 
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. 
predicate. 
Well, you told the police, "At no time did 
Ph. 
- Fax. 
1655 Pa 'm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
611013111 
EFTA00232198

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 67 of 100 
nsor & Associates 
Reporting and Transcription. lac. 
Page 41 
1 
Q. 
You told the police twice when you spoke to 
2 
Pagan 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 
A. 
Correct. 
8 
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 
0131$ 
EFTA00232199

Case 9:08-cv-80804-KAM 
DQcient 1 
Entered on FLSD Docket 07/21/2008 
Page 68 of 100 
nsor & Associates 
Reponins and TillISCripli OD, 10C. 
3 
2 
3 
4 
Page 42 
A. 
No. 
Q. 
No type of intercourse with Jeff, correct? 
A. 
Correct. 
Q. 
All right. Let's talk about what happened 
5 
after the massage was over. 
6 
A. 
Okay. 
7 
Q. 
8 
you wanted to bring your 
sister back so she could 
9 
make some money, correct? 
10 
A. 
Incorrect. 
11 
Q. 
Your 
sister is III 
right? 
12 
A. 
Correct. 
13 
Q. 
And you love 
very much, don't you? 
14 
A. 
Yes. 
15 
Q. 
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 
After the massage, you told Epstein that 
And when you left the house you were joking 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
18.31316 
EFTA00232200

Case 9:08-cv-80804-KAM 
Doqument1 
Entered on FLSD Docket 07/21/2008 
Page 69 of 100 
sor & Associates 
1 
2 
3 
4 
5 
6 
7 
8 
9 
Reporting and Transcription. 3nc 
Page 43 
things, but it wasn't joking about it at all. 
Q. 
You joked about it, didn't you? 
A. 
No. 
Q. 
You said to 
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 glip 
MR. LEOPOLD: Objection. Asked and 
answered. 
10 
THE WITNESS: No. 
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 
A. 
Incorrect. I didn't spend any of the 
16 
money. 
17 
Q. 
You went to Marshall's, didn't you? 
18 
A. 
I went along, yes, but I didn't --
19 
Q. 
You went shopping with them at Marshall's, 
20 
didn't you? 
21 
MR. LEOPOLD: Objection. 
22 
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 
09 of 010 
EFTA00232201

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 70 of 100
nsor & Associates 
RI:Tarano and Transc dance, 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. 
23 
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 
Thrall@ 
EFTA00232202

Case 9:08-cv-80804-KAM 
ent 1 
QlteredonFLSDpocket07/21/2008 
Page 71 of 100 
sor &Associates 
Roponisq mod Trassaiption. 
1 
2 
3 
Page 45 
A. 
It was not this year, no. 
Q. 
Was it 2007? 
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 
; 
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 
Q. 
Did they speak to your parents? 
20 
A. 
That's something you'd have to ask my 
21 
parents. 
22 
0. 
Do you know whether they spoke to'your 
23 
par 
' 
24 
A. 
No, sir. 
25 
Q. 
You have no idea? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
71 Nits 
EFTA00232203

Case 9:08-cv-80804-KAM 
Qg g lent 1 
Entered on FLSD Docket 07/21/2008 
Page 72 of 100 
nsor & Associates 
Agnomen and Trmuctirtian, 
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. 
B 
Q. 
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 
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 
1 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
72 of 316 
EFTA00232204

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 73 of 100 
nsor & A5soclates 
Reporting and lrinscriptioa Inc 
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 
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 
71 et 311 
EFTA00232205

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 74 of 100 
sor & Associates 
[tenoning and Inniscrivinn. 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 
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 
0. 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
?act 316 
EFTA00232206

Case 9:08-cv-80804-KAM 
CZo 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 75 of 100 
sor & Associates 
Reporting one Thinscripann, Inc. 
Page 49 
1 
Mr. Herman in the presence of ailla 
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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
7$ ei 
EFTA00232207

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 76 of 100 
100
 nsor & Associates 
Rcporiinp aid Transcription, Jac. 
Page 50 
1 
Q. 
Why did the meeting take place at 
2 
amuse? 
3 
A. 
I spent the night that night at her house. 
4 
O. 
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 
O. 
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 
O. 
How about an agent named 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
7101311 
EFTA00232208

Case 9:08-cv-80804-KAM 
Do 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 77 of 100 
4 
nsor & Associates 
Repartmg and Transeriimian, lac. 
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 
;9 
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 310 
EFTA00232209

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 78 of 100 
sor & Associates 
Kopm10)24,411flmmtthmelm. 
Page 52 
4 
if your parents have ever received a victim notification 
7 
6 
A. 
5 
letter, correct? 
Q.
Have you given any evidence to prosecutors 
Correct. 
1 
igneui.vcd a victim notification letter, correct? 
2 
rect. 
3 
Q. 
And your testimony is that you don't know 
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. 
Pagan. 
23 
Q. 
Did she keep it? 
24 
A. 
Ask her. 
25 
O. 
You gave it to her and then you didn't get 
meomponiesSeillYienalipinahmell, 
ta•ff Imre". 
nod 
wary 
71.1314 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232210

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 79 of 100 
sor & Assoctates 
Ropanisig and Tnascriptimi, lac. 
• 
Page 53 
it back at the end of the meeting? 
9 
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 are 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? 
79W070 
Ph. 
- Fax. 
. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232211

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 80 of 100 
sor & Associates 
Roporunc and Transcription. Inc 
Page 54 
1 
A. 
No, sir. 
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. 
23 
MR. TEIN: Certify it. 
24 
MR. LEOPOLD: Please. 
25 
50 of 314 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232212

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 81 of 100 
nsor & Associates 
Roportang and lralosospoco. 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 friendIIIIIIIIPto 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 
It el 31$ 
EFTA00232213

Case 9:08-cv-80804-KAM 
 
ent 1 
Entered on FLED Docket 07/21/2008 
Page 82 of 100 
D nsor 
& Associates 
Ropaning cad Tuascrquice,. 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. us t'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. 
14IIIIILon the left and me on the right. 
22 
Q. 
right? 
23 
A. 
Yes. 
24 
Q. 
IOW 
your friend at the 
25 
Quarterdeck Tavern, right? 
Ph. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
eta 316 
EFTA00232214

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 83 of 100 
nsor 81 Associates 
Reporting tad Transertptim, Inc. 
1 
A. 
Yes. 
2 
Page 57 
Q. 
IIIIIIIIIryour friend, who you say the day 
3 
that the process servers went to serve you with a 
4 
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 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
BY MR. TEIN: 
20 
Q. 
You said that wasn't the first day you were 
21 
going to be -- you thought you were being served with a 
22 
subpoena, correct? 
subpoena for this deposition, just happened -- just by 
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. 
4 
COM 
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 
EFTA00232215

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 84 of 100 
sor & Associates 
R planing and Transcription. lac. 
Page 58 
1 
looting for you, didn't you? 
54 et 3i6 
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 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. 
- Fax. 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00232216