EFTA00234224

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 41 of 100 
nsor & Associates 
Re partinp and 1rznrcripa on. Inc 
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Page 15 
MR. LEOPOLD: We're going to leave or we're 
going to take a break, because his demeanor is not 
appropriate. There's no reason to have this kind 
4 
of demeanor. If you want to have this kind of 
5 
demeanor with me --
6 
MR. TEIN: You are obstructing this 
7 
deposition. 
8 
MR. GOLDBERGER: Why don't you guys go 
9 
outside and just talk about --
10 
MR. LEOPOLD: She -- her job is very 
11 
difficult and she's not going to be able to take 
12 
us both talking at the same time. 
13 
MR. GOLDBERGER: Off the record. 
14 
MR. LEOPOLD: We're not going off the 
15 
record, Jack. We're not, Jack. Her job is very 
16 
difficult. I'm going td make the record. 
17 
I don't think it is appropriate, especially 
18 
in the small confines of this room, to be very 
19 
aggressive with this young lady. 
20 
MR. TEIN: That's not happening. Stop, 
21 
stop actually --
22 
MR. LEOPOLD: If you're going to interrupt 
23 
me, we're going to cancel this deposition --
24 
MR. TEIN: Stop misrepresenting. 
25 
THE COURT REPORTER: I need one at a time, 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
41 01316 
EFTA00234264

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 42 of 100 
nsor & Associates 
eteraranp and 'luau ripuno. lac 
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Page 16 
no matter who it is. 
MR. LEOPOLD: I think we're going to take a 
break. Perhaps you might want to talk to your 
co-counsel --
MR. TEIN: I don't need to talk to him. 
MR. LEOPOLD: But we're going to take a 
7 
break. 
8 
MR. TEIN: We're not taking a break unless 
9 
the witness needs a break. 
10 
You're obstructing this deposition, Ted. 
11 
MR. LEOPOLD: Come on, ow 
12 
You all want to continue in this 
13 
demeanor --
14 
MR. TEIN: You're obstructing the 
15 
deposition. Stop making speeches. We're not 
16 
discussing this with you. The questions are to 
17 
your client. Go take your five-minute break. 
18 
MR. LEOPOLD: Fine. We need to make sure 
19 
the record's clear and clean. 
20 
And I want to make sure, as I've already 
21 
asked you -- I know that you're one of the best in 
22 
town -- that this audio -- this needs to be 
23 
preserved. Okay? 
24 
MR. TEIN: Go take your five-minute break, 
25 
Mr. Leopold, now. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4301316 
EFTA00234265

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 43 of 100 
nsor & Associates 
Repo:tins and Traosctiparn .Inc. 
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Page 17 
You were supposed to be here at nine a.m.; 
it's now after two. Take your break and come 
back. 
MR. LEOPOLD: Okay. If the demeanor keeps 
5 
up, we will not be here beyond those five minutes. 
6 
7 
8 
relax. 
9 
10 
break. 
11 
MR. GOLDBERGER: Let them take that 
12 
five-minute break. 
13 
MR. LEOPOLD: But I would suggest that you 
14 
take deep breaths. 
15 
MR. TEIN: Suggest whatever you want. Go 
16 
take a break. 
17 
(Thereupon, a recess was taken.) 
18 
BY MR. TEIN: 
19 
Q. 
you agree that giving testimony 
20 
today at your deposition is something very serious, don't 
21 
you? 
22 
A. 
Yes. 
23 
Q. 
And you respect the court, don't you? 
24 
A. 
Yes. 
25 
Q. 
Let me show you Exhibit 31-001. Can you 
MR. TEIN: Take your break and come back. 
MR. LEOPOLD: Okay. So I suggest that you 
MR. TEIN: I suggest that you take your 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
43 01316 
EFTA00234266

Case 9:08-cv-80804-KAM 
nt 1 
Enteredon FLSD Docket 07/21/2008 
Page 44 of 100 
nsor & Associates 
Ropartinp and 'Transcription. Inc 
Page 18 
1 
read that out loud, please. 
2 
A. 
Okay. What do you want? 
3 
Q. 
Will you read that out loud, please. 
4 
A. 
Oh. 
5 
Q. 
Thank you. 
6 
A. 
Lol hah my baddd...1O1 yah i got some 
7 
stupid court shit on the 20th...bullshit...and damn you 
8 
still have court shit with him? Like after so long wow 
9 
im sorry... well yah well we will definitely havta make 
10 
plans for sure..because i miss u tons times a million and 
11 
no no no i love you...o and p.s. i love ur default pic 
12 
niggaa. Muah xo. 
13 
Q. 
Did you send that message last week to a 
14 
friend of yours on MySpace? 
15 
A. 
I wouldn't know. There's no dates and I've 
16 
deleted that MySpace, so --
17 
Q. 
We're going to talk about that in a second. 
18 
A. 
Okay. 
19 
Q. 
Did you send that message last week -- 
20 
A. 
Right. 
21 
0. 
Let me finish my question. 
22 
Did you send that message last week to a 
23 
friend of yours on MySpace? 
24 
A. 
I wouldn't know the date, but obviously, 
25 
it's to a friend. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
44 01316 
EFTA00234267

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 45 of 100 
nsor & Associates 
Reportint and 1 ransc ripantn, lac. 
Page 19 
1 
Q. 
Did you send that message to a friend of 
2 
yours on MySpace? 
3 
A. 
Sure, yes. 
4 
Q. 
Were you referring to this deposition? 
5 
A. 
Yes. 
6 
Q. 
Do you find the term n-i-g-g-e-r offensive? 
7 
A. 
That's not anywhere in there. 
8 
Q. 
What word did you use in there? 
9 
MR. LEOPOLD: Where are you referring to, 
10 
Counsel? There's 20 plus words in there. 
11 
MR. TEIN: Don't make a speaking objection. 
12 
THE WITNESS: Are you referring to 
13 
anything --
14 
MR. LEOPOLD: No, 
Don't -- don't 
15 
let him ask you the question. 
16 
BY MR. TEIN: 
17 
Q. 
what question were you asking, 
? 
18 
MR. LEOPOLD: She doesn't ask questions. 
19 
You ask the questions. What is the question 
20 
pending? 
21 
BY MR. TEIN: 
22 
Q. 
what is the last word on there in 
23 
the text of your message before the closing? 
24 
A. 
Niggaa. 
25 
Q. 
Don't you find that term offensive? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4501316 
EFTA00234268

Case 9:08-cv-80804-KAM 
D 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 46 of 100 
nsor & Associates 
Reponing end Transcrirlea, Inc 
Page 20 
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Mr. Leopold. I have marked and identified as an 
16 
exhibit and you will get it. 
17 
MR. LEOPOLD: There has been no 
18 
identification of this document in the record. 
19 
MR. TEIN: Mr. Leopold, stop interrupting 
20 
this deposition. 
21 
MR. LEOPOLD: What is the exhibit number 
22 
marked for identification? 
23 
MR. TEIN: 31-001. 
24 
MR. LEOPOLD: Do we have copies? Is it on 
25 
the record anywhere? 
A. 
No. 
MR. LEOPOLD: Can you spell it for the 
record, please. 
THE WITNESS: N-i-g-g --
MR. TEIN: No, no, no. You are not going 
to be asking questions. 
MR. LEOPOLD: I'm not asking questions. 
I'm asking for the record the word to be spelled, 
because we don't have a video here today. 
MR. TEIN: These exhibits are part of the 
record. You --
MR. LEOPOLD: Well, it's not marked as an 
exhibit. 
MR. TEIN: Stop interrupting me, 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4601416 
EFTA00234269

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 47 of 100 
nsor & Associates 
Rcpartinfi and Transtripticri Uc 
1 
BY MR. TEIN: 
2 
Page 21 
Q. 
Let me ask you, 
did you in fact 
3 
write your friend this message about this deposition? 
4 
A. 
Yes. 
5 
Q. 
So you wrote your friend that this 
6 
deposition is stupid court s-h-i-t, correct? 
7 
A. 
Yes. 
8 
Q. 
Because you think this deposition is stupid 
9 
court s-h-i-t, don't you? 
10 
A. 
No. 
11 
Q. 
You wrote that to your friend, didn't you? 
12 
A. 
Yes. 
13 
Q. 
You think that court is stupid, don't you? 
14 
A. 
In some cases. 
15 
Q. 
And you think that court is bull s-h-i-t, 
16 
don't you? 
17 
A. 
No. 
18 
Q. 
And you think this deposition is bull 
19 
s-h-i-t, don't you? 
20 
A. 
No. 
21 
Q. 
You wrote that to your friend, didn't you? 
22 
MR. LEOPOLD: Objection. Asked and 
23 
answered. 
24 
MR. TEIN: That's not an objection. 
25 
BY MR. TEIN: 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
47 01316 
EFTA00234270

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 48 of 100 
nsor & Associates 
Reparan3 rind Transcrip:m. Inc. 
Page 22 
Q. 
You wrote that to your friend, didn't you? 
1. 
4 
5 
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8 
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specificity. And I will do that. And if you 
16 
don't want me to, you can make the record. But I 
17 
will do that. 
18 
MR. TEIN: Here's what we'll do, Ted. You 
19 
can -- I will allow you to reserve an objection to 
20 
form for every single one of my questions. 
21 
Otherwise, all you're doing is obstructing. 
22 
MR. LEOPOLD: I won't do that. 
23 
MR. TEIN: Of course; because you want to 
24 
obstruct. 
25 
MR. LEOPOLD: All right. 
MR. LEOPOLD: Objection. Asked and 
answered, for the fourth time. 
MR. TEIN: You are improperly objecting, 
Mr. Leopold. You have no grounds to object. And 
that's not an objection. 
MR. LEOPOLD: It is an objection. 
MR. TEIN: Then terminate the deposition if 
you think it's been asked and answered. 
MR. LEOPOLD: Counsel, I am not precluded 
from just making an objection to the form of the 
question. As the courts well know, and if you 
practice here in West Palm Beach, many of the 
judges require you to set the objection with 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
44301316 
EFTA00234271

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 49 of 100 
nsor & Associates 
Relinnin: mud Trinscrip:inm, Inc 
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Page 23 
BY MR. TEIN: 
MN
Q. 
you think that giving testimony 
today, under oath, is bull s-h-i-t, don't you? 
A. 
No. 
Q. 
And you wrote that to your friend on 
MySpace last week, didn't you? 
MR. LEOPOLD: Objection. Asked and 
answered. 
THE WITNESS: No, I did not. 
10 
BY MR. TEIN: 
11 
Q. 
You didn't write this exhibit? 
12 
A. 
I wrote that, but I didn't write what you 
13 
said. 
14 
Q. 
15 
stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 
16 
you write that? 
17 
18 
Q. 
Referring to this deposition, didn't you? 
19 
A. 
Referring to the court. I was later 
20 
informed that it was a deposition. 
21 
Q. 
I'm going to ask you some questions now 
22 
about what happened when you went to Jeff Epstein's house 
You wrote in this exhibit, "I got some 
A. 
Yes. 
23 
three years ago. Okay? 
24 
25 
A. 
Uh -huh. 
Q. 
When the police interviewed you one month 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
49(0316 
EFTA00234272

Case 9:08-cv-80804-KAM 
p . 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 50 of 100 
nsor & Associates 
RoponniF and 'Transcription lnc 
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Page 24 
after you went to Epstein's house, you swore on your 
mother's grave that you and Epstein did not engage in sex 
of any kind? 
A. 
Yes. 
Q. 
Didn't you tell that to the police? 
A. 
Yes. And I will continue. I have never 
had sex with him. 
Q. 
Did what happened upstairs at Jeff 
Epstein's house take you completely by surprise,. 
A. 
Yes. 
Q. 
Now the civil complaint that you filed 
against Mr. Epstein for fifty million dollars alleged 
that, you were totally shocked by what happened when you 
got there. 
A. 
Yes. 
Q. 
Were you totally shocked by what happened 
when you got to Epstein's house? 
A. 
Yes. 
Q. 
You didn't expect it at all, did you? 
A. 
No. 
Q. 
You had absolutely no idea why your friend 
IIIII/I.as taking you to Epstein's house, right? 
A. 
I was informed it was a massage. 
Q. 
All you thought that it was going to be was 
a message, correct? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
5001316 
EFTA00234273

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 51 of 100 
nsor & Associates 
Repontng and 'I.:Ansi:rip/1n, Inc 
. Page 25 
1 
2 
3 
never said anything to you on the telephone about sexual 
4 
activity with Epstein, did she? 
5 
A. 
No. 
6 
Q• 
7 
never sent you a message over the Internet about 
A. 
Yes. 
Q. 
Before you got to Epstein's house r—
And before you got to Epstein's house 
8 
sexual activity with Epstein, did she? 
9 
A. 
No. 
10 
Q. 
Did 
ever try to convince you to 
11 
engage in any sexual activity with Epstein? 
12 
A. 
No. 
13 
Q. 
Did 
every try to convince 
14 
you to engage in any sexual activity with Epstein? 
15 
A. 
I don't know who 
is. 
16 
Q. 
Do you have a friend IIIIIII? 
17 
A. 
No. 
18 
Q. 
Okay. Before you went so Epstein's house 
19 
did anyone call or e-mail you to induce you to engage in 
20 
sexual activity with Epstein? 
21 
A. 
No. 
22 
0• 
So you're sure that before you got to 
23 
Epstein's house no one tried to persuade you to engage in 
24 
sexual activity with Jeffrey Epstein? 
25 
A. 
No. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
51 Q4 516 
EFTA00234274

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 52 of 100 
nsor & Associates 
kepnitint. and Transcriputo Inc 
Page 26 
1 
Q. 
You're sure that -- let me ask the question 
2 
again. 
3 
You're sure that before you got to 
4 
Epstein's house no one tried to persuade you to engage in 
5 
sexual activity with Epstein for money. Are you? 
6 
MR. LEOPOLD: Objection. Asked and 
7 
answered. 
8 
THE WITNESS: No. And I've already 
9 
answered that a bazillion times. 
10 
BY MR. TEIN: 
11 
Q. 
He's coaching you now. So I'm going to ask 
12 
the question 
13 
MR. LEOPOLD: Counsel, I've made an 
14 
objection for the record. 
15 
MR. TEIN: Stop speaking. 
16 
MR. LEOPOLD: I'm not going to stop 
17 
speaking. You can't interrupt me when I'm making 
18 
the record. 
19 
MR. TEIN: You're coaching the witness. 
20 
MR. LEOPOLD: Counsel --
21 
MR. TEIN: Stop coaching the witness. 
22 
BY MR. TEIN: 
23 
Q. 
MI 
let me ask you --
24 
MR. LEOPOLD: If you continue to --
25 
MR. TEIN: Stop interrupting my questions. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
52 01316 
EFTA00234275

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 53 of 100 
nsor & Associates 
Rept-tramp and lranscripam, Inc 
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Page 27 
MR. LEOPOLD: If you do it one more time, 
we're leaving. 
BY MR. TEIN: 
O 
MR. LEOPOLD: I'm going to make the record. 
You cannot interrupt me when I'm making the 
record. Out of professional conduct, you cannot 
do that. I'm entitled to make the record. I made 
an objection, asked and answered. Your demeanor 
is inappropriate. You're willing and you are able 
and you're responsible to ask a question in a 
professional manner, and ask the question and once 
you get the answer, to either follow up on it or 
move on, but not continuously browbeat and ask the 
same question over and over because you don't like 
the answer. 
MR. TEIN: calm down, sir. 
MR. LEOPOLD: Trust me, I'm very calm here. 
When I'm not calm, you'll know it. I'm very calm. 
So please continue on. But I will not 
allow you to continue to harass her in the 
demeanor that you're doing. Ask her a question 
and move on. 
MR. TEIN: Are you done? 
MR. LEOPOLD: Thank you. I am. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
5301315 
EFTA00234276

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 54 of 100 
nsor & Associates 
Report ng mid Transcriptonn, Inc 
1 
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3 
Stop it. 
4 
BY MR. TEIN: 
5 
Q. 
6 
7 
clear. 
8 
Page 28 
MR. TEIN: Stop misrepresenting the record 
and calm down. I'm going to ask my question. 
MR. LEOPOLD: I think the record is very 
MR. GOLDBERGER: Let me just clarify 
9 
something. When you object to the form of a 
10 
question, you're not instructing the witness not 
11 
to answer the question, are you? 
12 
MR. LEOPOLD: No. And I'm not making that 
13 
objection; only on attorney/client privilege. 
14 
15 
can ask my question? Are you done? 
16 
17 
BY MR. TEIN: 
18 
Q. 
Listen, al 
19 
MR. LEOPOLD: Hold on. Stop. 
20 
21 
have met a lot of attorneys, but I've never had an 
22 
experience like this where I've --
23 
MR. TEIN: Stop your speeches. 
24 
25 
whether it's with me or with my client, I will not 
MR. TEIN: Will you stop speaking now so I 
Okay. I'm going to ask my question. 
I've been doing this for 20 plus years and 
MR. LEOPOLD: If you continue to do this, 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
5.01316 
EFTA00234277

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put up with it and I don't need to put up with it 
Case 9:08-cv-80804-KAM 
Rggjrjrwent 1 
Entered on FLSD Docket 07/21/2008 
Page 55 of 100 
nsor & Associates 
Reportiap end Transcripon. Inc. 
Page 29 
1 
2 
and it's not appropriate. And I'm sure 
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 
up with it. 
MR. TEIN: Will you please stop your speech 
so I can ask questions? 
MR. LEOPOLD: So long as you act 
professionally, I will do so. But if you continue 
to do it this way, I will leave. 
MR. TEIN: Suit yourself. 
BY MR. TEIN: 
Q. 
fl
are you sure that before you got to 
Epstein's house no one tried to persuade you to engage in 
sexual activity with Epstein for money? 
MR. LEOPOLD: Asked and answered. 
Objection. 
MR. TEIN: Did you get her answer? 
THE COURT REPORTER: No, I did not. 
THE WITNESS: I'm sure. 
BY R. TEIN: 
Q. 
Let me ask you a few questions about your 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
5501 316 
EFTA00234278

Case 9:08-cv-80804-KAM 
RgcUment 1 
Entered on FLSD Docket 07/21/2008 
Page 56 of 100 
nsor & Associates 
iicpornap And ranscro pow. 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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
5601316 
EFTA00234279

Case 9:08-cv-80804-KAM 
D 
ment 1 
Entered on FLSD Docket 07/21/2008 
Page 57 of 100 
nsor & Associates 
Reporting and Transcription. Inc 
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Page 31 
A. 
No. 
Q. 
All right. Let me ask you two final areas 
of questioning about this and we'll move onto something 
else. Okay? 
A. 
Uh-huh. Yes. I'm sorry. 
Q. 
Before you got to Epstein's did anyone 
associated with Epstein ever call you on the phone and 
try to persuade, induce, entice or coerce you to engage 
in any sexual activity? 
A. 
No. 
Q. 
Before you got to Epstein's did anybody 
associated with Epstein ever contact you on the Internet 
and try to persuade, induce, entice or coerce you to 
engage in any sexual activity? 
15 
A. 
No. 
16 
Q. 
who told you that when you got to 
_7 
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 
O. 
Who was the other girl in the car with you 
24 
that day? 
25 
A. 
I honestly don't know. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
W01316 
EFTA00234280

Case 9:08-cv-80804-KAM s 
D pment 1 
Entered on FLSD Docket 07/21/2008 
Page 58 of 100 
io
Repornnp and Transcri moon. Inc 
nsor & Associates 
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 
Q. 
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 gill' 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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
5801316 
EFTA00234281

Case 9:08-cv-80804-KAM 
Q. 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 59 of 100 
nsor & Associates 
ReportenF and Transcli pm. Inc 
1 
2 
out how old you were, right? 
Page 33 
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. 
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. 
16 
A. 
No. I didn't really speak with her that 
17 
much. 
18 
Q. 
19 
on that? 
L0 
MR. LEOPOLD: Do you have something to 
21 
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. 
During the massage Jeff asked you how old 
Do you want to rethink that answer? 
Do you want to try to refresh your memory 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6901316 
EFTA00234282

Case 9:08-cv-80804-KAM 
D • 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 60 of 100 
* 
nsor & Associates 
Repnrans and Iranscripam, 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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6001316 
EFTA00234283