EFTA00234224

Case 9:08-cv-80804-KAM 
ent 1 
Exiterpd on FLS.D Docket 07/21/2008 
Page 61 of 100 
nsor & Associates 
Rcponinp and luau:ippon, Inc 
Page 35 
1 
Q. 
You can answer the question. 
2 
A. 
Sure. 
3 
Q. 
Is there anything that would refresh your 
4 
memory that in fact you told Mr. Epstein's assistant, the 
5 
one who walked you upstairs, that you went to college and 
6 
you had just moved down here from Ohio? 
7 
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 Michelle Pagan 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 
Pagan that when you lied about your age to Jeff you said 
21 
it :tally fast because you didn't want to make it sound 
22 
like you were lying? 
23 
A. 
I don't 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 Pagan 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
61 01 315 
EFTA00234284

Case 9:08-cv-80804-KAM 
S 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 62 of 100 
ReroranR end Transcriptim, Inc.
nsor & Associates 
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 
ay:Jig? 
4 
A. 
No, I don't remember saying those words 
5 
exactly to her. I remember telling her that I told 
6 
Epstein I was 18. 
7 
4. 
Does it sound right to you that you told 
8 
Detective Pagan 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? 
15 
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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6301316 
EFTA00234285

Case 9:08-cv-80804-KAM 
pp¢rnent 1 
Entered on FLSD Docket 07/21/2008 
Page 63 of 100 
nsor & Associates 
Repartunp and Transcripon. Inc 
1 
2 
BY MR. TEIN: 
Q. 
Let me put it again. 
Page 37 
3 
Does it sound right to you that you told 
4 
Detective Pagan 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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6701716 
EFTA00234286

Case 9:08-cv-80804-KAM 
D 
(tient 1 
Entered on FLSD Docket 07/21/2008 
Page 64 of 100 
o
r
nsor & Associates 
Repo:tap and Transc ri rim. Inc 
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Page 38 
A. 
Yes. 
Q. 
Was that the truth? 
A. 
No. 
Q. 
In fact, you went to Royal Palm, right? 
A. 
Yes. 
Q. 
So you lied to Mr. Epstein again, correct? 
A. 
Yes. 
Q. 
Is Wellington the college that you told 
Jeff's assistant that you were attending? 
A. 
I don't remember having that conversation 
with her, so I wouldn't know if that's what I said. 
Q. 
That was a lie, though, wasn't it? 
MR. LEOPOLD: Objection to the form of the 
question, lack of foundation. You're making an 
assumption. She just answered you she can't tell 
you that. 
MR. TEIN: Speaking objection. And you 
well know that, Mr. Leopold. 
MR. LEOPOLD: She can't answer that 
question. The way you phrased that question, 
you're purposely making her not be honest in her 
testimony. She can't answer a question like that. 
She doesn't remember. So then you say, "So you 
were lying." That's improper and you know that. 
That's not a proper question. And any attorney 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
001316 
EFTA00234287

Case 9:08-cv-80804-KAM 
Doc
 ment 1 
Entered on FLSD Docket 07/21/2008 
Page 65 of 100 
l
i 
nsor & Associates 
Repnrinp and Transcap:san. Inc 
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Page 39 
that would do that to a witnesses or to a person 
that's sitting in this chair is not acting 
professionally. You can't ask a question like 
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. 
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: 
28 
Q. 
Ms. 
IIIIIIIIIII 
Mr. Epstein never asked you 
19 
to do anything other than massage him, correct? 
L0 
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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6501315 
EFTA00234288

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FL$D Docket 07/21/2008 
Page 66 of 100 
nsor & Associates 
RepOrri (If and lanscripnnn, lnc 
1 
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BY MR. TEIN: 
predicate. 
THE WITNESS: Correct. 
Page 40 
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 
Q. 
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. 
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. 
Mr. Epstein never tried to put your hand 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Paim Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6601316 
EFTA00234289

Case 9:08-cv-80804-KAM 
D9Pyjnent 1 
Entered on FLSD Docket 07/21/2008 
Page 67 of 100 
nsor & Associates 
Reporting and 'Transcription, Inc 
Q. 
Page 41 
1 
2 
Michelle Pagan that "at no time did he touch me." Didn't 
3 
you say that to the police? 
4 
A. 
Yeah. 
5 
Q. 
6 
truthful. Is that what you're saying now? 
7 
A. 
Correct. 
8 
Q. 
And you're saying if you're not fully 
9 
trt.thful, that's not a lie. Correct? 
10 
A. 
You took that out of context like really 
11 
bad. 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? 
You told the police twice when you spoke to 
And you're saying that that was not fully 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
67°4316 
EFTA00234290

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 68 of 100 
nsor & Associates 
• 
konorons and Transcripon, Inc. 
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 
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 
and 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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234291

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 69 of 100 
sor & Associates 
Reporting and Transcriponn. Inc 
Page 43 
1 
2 
3 
A. 
No. 
things, but it wasn't joking about it at all. 
Q. 
You joked about it, didn't you? 
7 
Q. 
8 
9 
10 
11 
BY AR. TEIN: 
4 
Q. 
You said to "NI 
that if you did this 
5 
every weekend you'd be rich, didn't you? 
6 
A. 
No. That's what 
told me. 
You didn't tell that to 
MR. LEOPOLD: Objection. Asked and 
answered. 
THE WITNESS: No. 
12 
Q. 
After you left Epstein's house you took the 
13 
money and you went shopping with IIIIIIrand 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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
6901316 
EFTA00234292

Case 9:08-cv-80804-KAM 
Dp ment 1 
Entered on FLSD Docket 07/21/2008 
Page 70 of 100 
nsor & Associates 
Reportinp Ind ansc ru pawn, Inc 
Page 44 
1 
BY MR. TEIN: 
2 
Q. 
And IIIIII/bought 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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
7001316 
EFTA00234293

Case 9:08-cv-80804-KAM 
ent 1 
ntered on FLSD Docket 07/21/2008 
Page 71 of 100 
sor l Associates 
Renaming and Transcription, lne. 
Page 45 
1 
2 
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. 
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 
Q. 
Do you know whether they spoke to your 
23 
parent's? 
24 
A. 
No, sir. 
25 
Q. 
You have no idea? 
A. 
It was not this year, no. 
Q. 
Was it 2007? 
How many federal prosecutors or FBI agents 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
71 01316 
EFTA00234294

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 72 of 100 
nsor & Associates 
Reponinp and Transcripace. 
1 
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3 
4 
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6 
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8 
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10 
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12 
A. 
answered. 
BY MR. TEIN: 
Q. 
Villafona, 
A. 
Q. 
your house? 
A. 
Q. 
you:: house? 
No, sir. 
MR. LEOPOLD: Objection. Asked 
So if I say the name to you Marie 
you don't know who that is? 
No, sir. 
How many women and how many men 
I want to say two ladies and two 
Page 46 
and 
came to 
guys. 
come to 
Did someone name
13 
A. 
I don't know names, sir. 
14 
Q. 
Do you know who ,n
 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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
nol316 
EFTA00234295

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 73 of 100 
sor & Associates 
Rcpt-irons and Transcription. Inc. 
1 
2 
Page 47 
fashion, you may answer. 
THE WITNESS: Okay. 
3 
I wouldn't know. 
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 whc 
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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
not
EFTA00234296

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Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 74 of 100 
nsor & Associates 
Reportiny and lranscrirrix, 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? 
A. 
I was shopping in my -- he showed up at my 
friend's house. 
Q. 
Whose house? 
A. 
My friend 
Q. 
Is that 
from the Quarterdeck 
Tavern? 
A. 
Yes. 
Q. 
And did you have a meeting with him at 
house? 
A. 
Yes. I guess you could say that. 
Q. 
And who else was there? 
A. 
My Aunt 
Q. 
And what was that meeting about? 
MR. LEOPOLD: Objection. That calls for 
attorney/client privilege. 
BY MR. TEIN: 
Q. 
What discussions did you have with 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
7401315 
EFTA00234297

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 75 of 100 
nsor & Associates 
Rept-wimp and 'Inlaid ripm, lac.
Page 49 
1 
Mr. Herman in the presence of MEM? 
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? 
73 
A. 
As far as I'm concerned, she's never spoken 
24 
or she's never had a conversation. She only opened the 
25 
door and then left. She's the one who answered the door. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
noun 
EFTA00234298

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 76 of 100 
nsor & Associates 
Reportunp and Transcription, ln< 
Page 50 
1 
Q. 
Why did the meeting take place at 1IIIIIIIIII 
2 
IIIIIIIpouse? 
3 
A. 
I spent the night that night at her house. 
4 
Q. 
And when was this? 
5 
A. 
A while ago. 
6 
Q. 
How long ago? 
7 
A. 
A month and a half ago. I'm guessing. 
8 
Q. 
A month and a half ago? 
9 
A. 
Uh-huh. 
10 
Q. 
So was it before of after Mr. Herman filed 
11 
the fifty-million-dollar lawsuit against Epstein? 
12 
A. 
After. 
13 
Q. 
Did you meet with an FBI agent named 
14 
Nesbitt Kurkendall, a woman? 
15 
A. 
I don't know. 
16 
Q• 
Did Ms. Kurkendall speak to you about 
17 
getting reimbursed from Mr. Epstein? 
18 
A. 
I've never had a discussion with anyone 
19 
about getting reimbursed from Mr. Epstein. 
20 
Q. 
Have you met with an agent named 
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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
7601 16 
EFTA00234299

Case 9:08-cv-80804-KAM 
Do 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 77 of 100 
nsor & Associates 
Rerew:ins and 'transcription, Inc 
Page 5] 
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 
yol.. 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 
O. 
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. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
n(0316 
EFTA00234300

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07)21:2008 
Page 78 of 100 
sor & Associate
t Roponiig and intrtseriptice, Asc. 
Page 52 
1 
rAgmlopcd 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 
Q. 
You gave your cell phone to whom? 
22 
A. 
Michelle Pagan. 
23 
Q. 
Did she keep it? 
24 
A. 
Ask her. 
25 
Q. 
You gave it to her and then you didn't get 
78ol316 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234301

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 79 of 100 
nsor & Associates 
Reporting and Transcription. Inc 
Page 53 
1 
it back at the end of the meeting? 
2 
A. 
No. They -- yeah. No. They have it. I'm 
3 
guessing. I don't have it. 
4 
Q. 
How much money are you hoping to get out of 
5 
Mr. Epstein? 
6 
MR. LEOPOLD: Objection to the form of the 
7 
question. Attorney/client privilege. 
8 
BY MR. TEIN: 
9 
Q. 
How much money 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, gip you lied to get out of this 
25 
deposition, didn't you? 
. . 
_ 
not 315 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234302

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 80 of 100 
 
 10 Rep r:ins and Tansc ripuon, Inc 
sor & Associates 
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.:4416 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00234303