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FBI VOL00009

EFTA00799605

176 pages
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Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 61 of 
176 
Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 30 of 100 
nsor & Associates 
ROMMIIIS /All
111ClitAilii. 
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Deposition 
Court Reporter and Notary 
Florida at Large, in 
Thereupon, 
having been first duly 
and testified as follows: 
THE WITNESS: 
DIRECT 
taken before 
Public in and 
the above cause. 
Page 4 
Judith F. Consor, 
for the State of 
was examined 
sworn or affirmed, 
I do. 
EXAMINATION 
11 
BY MR. TEIN: 
12 
O. 
Good afternoon. Please tell me your full 
13 
nage. 
14 
A. 
15 
0. 
And can you please spell it. 
16 
A. 
7 
18 
Q. 
Thank you. 
19 
May I call you S 
20 
A. 
Uh-huh. 
21 
Q. OM 
I'm going to ask you a few 
22 
questions, several questions today. If at any time you 
23 
want to take a break, you just let me know. Okay? 
24 
A. 
Okay. 
25 
Q. 
If you at any time don't understand one of 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
30 e1316 
08-80736-CV-MARRA 
001236 
EFTA00799665
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nsor & Associates 
Runonias and Truascririm. lac 
Page 5 
1 
my questions, will you just please let me know? 
2 
A. 
Yes. 
3 
Q. 
And if at any time you're not feeling well 
4 
or something like that, you'll tell us, right? 
5 
A. 
Yes. 
6 
Q. 
Do you feel okay today? 
7 
A. 
Yes. 
8 
Q. 
Not taking any alcohol or drugs or anything 
9 
like that, right? 
10 
A. 
No. 
11 
Q. 
So you feel ready to have your deposition 
12 
taken? 
13 
A. 
Yes. 
14 
O. 
what is your address? 
15 
A. 
I'm currently living at my aunt's house and 
16 
I don't know it off the top of my head. 
17 
Q. 
Where is it? 
18 
A. 
In Jupiter. 
19 
Q. 
Who is your aunt? 
20 
A. 
21 
Q. 
Who else is living there? 
22 
A. 
MEM 
my uncle. 
23 
24 
25 
Q. 
A. 
No. 
Q. 
Anyone else living there? 
The contempt motion that your mother filed 
Ph. 561.682.0995 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
it Mils 
08-80736-CV-MARRA 
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Page 32 of 100 
nsor & Associates 
Reporting And TrAnscri pan:Inc. 
Page 6 
1 
against your father regarding your fifty million-dollar 
2 
lawsuit against Jeffrey Epstein says that you live with 
3 
your aunt and uncle and have been living there; is that 
4 
correct? 
5 
A. 
Yes. 
6 
Q. 
How long have you been living with your 
7 
aunt and uncle? 
8 
A. 
Since my father kicked me out. 
9 
Q. 
That was Thanksgiving of this past year? 
10 
A. 
Yes, sir. 
11 
Q. 
Okay. Didn't your firefighter boyfriend 
12 
get an apartment for the two of you? 
13 
A. 
No, sir. He has an apartment, but by 
14 
himself. 
15 
O. 
Did he get an apartment for the two of you 
16 
to live in? 
17 
A. 
No, sir. 
18 
Q. 
Are you planning to move in with him? 
19 
A. 
Maybe one day in the future. 
20 
Q. 
Do you have a plan to move in with him 
21 
presently? 
22 
A. 
No. 
23 
0. 
Have you been to the apartment that you and 
L4 
have discussed moving in together? 
25 
A. 
I have been to the apartment. 
Ph. 561.682.0905 - Fax. 561.682,1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
32 of 314 
08-80736-CV-MARRA 
001238 
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Page 33 of 100 
nsor & Associates 
Ha parting and Tun scri pa i 
. Inc 
Page 7 
1 
Q. 
Where is that? 
2 
A. 
Palm Beach Lakes. 
3 
Q. 
Have you spent the night over there? 
4 
A. 
No, sir. 
5 
Q. 
Do you know the address there? 
6 
A. 
I do not. 
7 
Q. 
Isn't your sister 
planning on living 
8 
with you and IIII? 
9 
A. 
No. 
10 
Q. 
you know that this court case is a 
11 
criminal prosecution, correct? 
12 
A. 
Correct. 
13 
Q. 
And you know that it's a criminal 
14 
prosecution against a man who has no criminal background. 
15 
Do you know that? 
16 
A. 
I do now. 
17 
Q. 
You agree that court is a very serious 
18 
matter? 
19 
A. 
Yes. 
20 
O. 
And you're here with your Lawyer 
21 
Mr. Leopold, right? 
22 
A. 
Yes. 
23 
Q. 
And you know that Mr. Leopold recently 
24 
filed a lawsuit in federal court against Jeffrey Epstein, 
25 
seeking fifty million dollars. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
3304315 
08-80736-CV-MARRA 
001239 
EFTA00799668
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Case 9:08-cv-80804-KAM 
34 O'311 
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Entered on FLSD Docket 07121/2008 
Page 34 of 100 
nsor & Associates 
Rannrtinp and l'ransctilxlan, lac. 
Page 8 
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MR. LEOPOLD: Let me just object. 
2 
let me instruct you. Anything that 
3 
you have learned through conversations between you 
4 
and me are protected. So if you know any of that 
5 
information outside of those discussions, you may 
6 
answer. But if the only way you know it is 
7 
through our discussions, do not answer that 
8 
question. 
9 
BY MR. TEIN: 
10 
O. 
you know that Mr. Leopold recently 
11 
filed a lawsuit in federal court on your behalf against 
12 
Jeffrey Epstein seeking fifty million dollars? 
13 
MR. LEOPOLD: Same objection. 
14 
If you know the answer to that outside of 
15 
our discussions, you may answer. If it is the 
16 
only way that you know the answer is through our 
17 
discussions, do not answer that question. 
18 
THE WITNESS: Okay. 
19 
MR. LEOPOLD: Attorney/client privilege. 
20 
BY MR. TEIN: 
21 
O. 
You can answer the question unless 
22 
MR. LEOPOLD: Same objection. 
23 
MR. TEIN: Let me finish. 
74 
MR. LEOPOLD: Excuse me. We're --
25 
MR. TEIN: No. Let me finish. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
08-80736-CV-MARRA 
001240 
EFTA00799669
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Page 35 of 100 
nsor & Associates 
Reponing and Transcriplien, lrg. 
Page 9 
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MR. LEOPOLD: Lewis, we're not going to do 
2 
3 
MR. TEIN: My name is not Lewis. 
4 
I'm going to finish my question. Okay? 
5 
MR. LEOPOLD: Do not answer until you hear 
6 
from me. 
7 
BY MR. TEIN: 
8 
Q. 
Other than conversations that you have had 
9 
with Mr. Leopold -- I'm not asking about that -- are you 
10 
aware that Mr. Leopold has filed a lawsuit in federal 
11 
court seeking fifty million dollars from Jeffrey Epstein 
12 
on your behalf? 
13 
MR. LEOPOLD: Same objection. 
14 
Anything that you learn through 
15 
conversations between you and me, do not answer. 
16 
Those are protected. If you know through any 
17 
other realm of knowledge, you may answer. 
18 
THE WITNESS: No. 
19 
BY MR. TEIN: 
20 
Q. 
You have no idea that Mr. Leopold filed a 
21 
fifty million-dollar lawsuit on your behalf against 
22 
Jeffrey Epstein? 
that. 
23 
MR. LEOPOLD: Same objection. 
24 
Do not answer that question if it's through 
25 
discussions that you and I had. Outside of that, 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
3Solattl 
08-80736-CV-MARRA 
001241 
EFTA00799670
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Entered on FLSD Docket 07/21/2008 
Page 36 of 100 
nsor & Associates 
Reporting and Truscir'mina, Inc. 
Page 10 
1 
2 
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that answer. 
4 
5 
BY MR. DEIN: 
6 
Q. 
You didn't know that? 
7 
MR. LEOPOLD: Don't answer that question. 
8 
Again, it's attorney/client privilege. Any 
information you've learned through conversations 
between you and I are protected. If you know it 
through any other realm, you may answer. 
MR. TEIN: Are you going to say that for 
every question in the deposition, Mr. Leopold? 
MR. LEOPOLD: When you ask improper 
questions like that without the proper --
MR. TEIN: You're going to stop your 
speaking objections right now. Okay? 
MR, LEOPOLD: Without the proper --
MR. TEIN: You need to stop your speaking 
objections. 
Let's continue. 
MR. LEOPOLD: Counsel, you just asked me a 
question and I'd going to state it on the 
record --
MR. TEIN: You need to stop your speaking 
you may answer. So do not answer that question if 
that is the only basis by which you understand 
THE WITNESS: No. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beath Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
08-80736-CV-MARRA 
001242 
EFTA00799671
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Page 37 of 100 
nsor & Associates 
Reponing anti 'Frame-rip:ion. Int. 
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Page 11 
objections. Check your rules. 
MR. LEOPOLD: Excuse me. For the record, 
Counsel asked me a question. I'll state the 
answer on the record. He asked me the question am 
I going to be answering that way throughout the 
deposition. So long as there's improper 
foundation and predicate asked by the attorney, I 
will protect my client and I make the record where 
appropriate. If counsel wishes to ask an 
10 
appropriate worded question with the proper 
it 
foundation and predicate, I will certainly allow 
12 
the client to answer the question. 
13 
MR. GOLDBERGER: Why don't you just state 
14 
attorney/client privilege and just be done with 
15 
it? 
16 
17 
clear. 
18 
19 
20 
21 
22 
MR. LEOPOLD: I want the record to be 
MR. TEIN: You want to waste time is what 
you want to do. 
You were supposed to be here this morning 
and you totally broke the deal, the agreement that 
you had with us if your hearing got cancelled. 
23 
But let's move on and maybe you'll stop 
24 
obstructing this deposition. 
25 
MR. LEOPOLD: I think the record is very 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
37 *I 31$ 
08-80736-CV-MARRA 
001243 
EFTA00799672
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Page 38 of 100 
nsor & Associates 
Repantn2 and TtiminiptIon, 
1 
2 
3 
4 
clear where we stand thus far. 
Is there a recording taken of this 
deposition? 
THE COURT REPORTER: Yes. 
Page 12 
5 
MR. LEOPOLD: Just make sure that's 
6 
preserved. 
7 
ay.ma. 
8 
Q. 
Go to Exhibit 20-01 -- well, before you do 
9 
that." 
are you aware that a lawyer named Jeffrey 
10 
Herman filed a lawsuit on your behalf, yes or no? 
11 
MR. LEOPOLD: Objection. 
12 
Any conversations that you and I have had 
13 
regarding that, if that is the only way by which 
14 
you understand how to answer that question, do not 
15 
answer. It's attorney/client privilege, as well 
16 
as any conversations you may have had with the 
17 
attorney from Miami. That is also attorney/client 
38 
privilege. And I'm assuming --
19 
MR. TEIN: You're actually wrong about the 
20 
attorney/client privilege. 
21 
MR. LEOPOLD: I'm assuming Counsel is not 
22 
asking you to divulge attorney/client --
23 
MR. TEIN: Of course not. 
24 
BY MR. TEIN: 
25 
Q. 
a 
are you aware that Jeffrey Herman, 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
34 of 314 
08-80736-CV-MARRA 
001244 
EFTA00799673
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176 
Case 9:08-cv-80804-KAM 
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Page 39 of 100 
nsor & Associates 
Repartlap and Taaansi mina, Inc 
1 
2 
3 
4 
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6 
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8 
9 
10 
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14 
15 
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18 
BY MR. TEIN: 
19 
Q. 
Go ahead. Please answer yes or no. 
20 
A. 
Yes. 
21 
Q. 
Thank you. 
22 
In fact, you know that Mr. Herman held a 
23 
press conference after he filed the fifty-million-dollar 
24 
lawsuit on your behalf, don't you? 
25 
Page 13 
an attorney, filed a fifty-million-dollar lawsuit on your 
behalf against Jeffrey Epstein, yes or no? 
MR. LEOPOLD: Same objection. 
HR. TEIN: We've heard the objection 10 
times already. 
MR. LEOPOLD: Counsel, excuse me. 
MR. TEIN: Just say attorney/client 
privilege. Stop interrupting my questions. 
MR. LEOPOLD: I'm entitled to make an 
objection for the record, which I'm doing, and 
I'll make the same objection. And if it calls for 
attorney/client privilege, any conversations you 
and I have had, do not answer the question. 
And I think that it might be appropriate, 
IIIIII 
for the record, to ask questions via 
elliallas opposed to figi 
I think that 
would be more appropriate for this deposition. 
After it happened. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
Hagan 
08-80736-CV-MARRA 
001245 
EFTA00799674
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Case 9:08-cv-80804-KAM 
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nt 1 
Entered on FLSD Docket 07/21/2008 
Page 40 of 100 
nsor & Associates 
Reparsins end TrAGIC tiptinn. 
1. 
2 
don't you, yes or no? 
A. 
Yes. 
Page 14 
Q. 
You know that he had a press conference, 
4 
Q. 
In fact, let's go to Exhibit 20-01. 
5 
MR. GOLDBERGER: Look behind you. You'll 
6 
see it. 
7 
BY MR. TEIN: 
Q. 
Have you ever seen that picture before? 
A. 
Yes. 
Q. 
Is that a picture of your father, your 
stepmother and Mr. Herman at the press conference 
regarding your lawsuit? 
A. 
Yes. 
Q. 
Now you know that this is a very serious 
matter, don't you? 
MR. LEOPOLD: Asked and answered. 
Objection. 
MR. GOLDBERGER: All right. You can 
object. You're representing a witness here, 
Mr. Leopold. You can object on privilege grounds. 
You cannot make legal objections. You have no 
standing to do so. 
MR. LEOPOLD: I'm going to make them and 
then --
MR. GOLDBERGER: We're --
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
40 44310 
08-80736-CV-MARRA 
001246 
EFTA00799675
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Page 41 of 100 
nsor & Associates 
Reporting and Transcription, Inc 
Page 15 
1 
MR. LEOPOLD: We're going to leave or we're 
2 
going to take a break, because his demeanor is not 
3 
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 44 316 
08-80736-CV-MARRA 
001247 
EFTA00799676
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Page 42 of 100 
nsor & Associates 
;tenoning sad Tranictirion. Inc 
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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 
break. 
MR. TEIN: We're not taking a break unless 
the witness needs a break. 
You're obstructing this deposition, Ted. 
MR. LEOPOLD: Come on, 
You all want to continue in this 
demeanor --
MR. TEIN: You're obstructing the 
deposition. Stop making speeches. We're not 
discussing this with you. The questions are to 
your client. Go take your five-minute break. 
MR. LEOPOLD: Fine. We need to make sure 
the record's clear and clean. 
And I want. to make sure, as I've already 
asked you -- I know that you're one of the best in 
town -- that this audio -- this needs to be 
preserved. Okay? 
MR. TEIN: Go take your five-minute break, 
Mr. Leopold, now. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
AS el 316 
08-80736-CV-MARRA 
001248 
EFTA00799677
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Page43of100 
nsor & Associates 
Ropansn mid Transciirim. 
1 
2 
3 
back. 
4 
Page 17 
You were supposed to be here at nine a.m.; 
it's now after two. Take your break and come 
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 
➢Y MR. TEIN: 
19 
Q. 
you agree that giving testimony 
20 
today at your deposition is something very serious, don't 
21 
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 
22 
A. 
Yes. 
23 
Q. 
And you respect the coilif7—Uan't you. 
24 
A. 
Yes. 
25 
Q. 
Let me show you Exhibit 31-001. Can you 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
4101311 
08-80736-CV-MARRA 
001249 
EFTA00799678
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Page 44 of 100 
nsor & Associates 
keportimp end TransClipnnn. 
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 
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 
O. 
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 of 314 
08-80736-CV-MARRA 
001250 
EFTA00799679
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sor & Associates 
ReponinvimlYmnsairion,Inc. 
Page 19 
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 
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. 
 Z3 
—The text of your message before tne closing? 
MR. LEOPOLD: No, 
Don't -- don't 
24 
A. 
Niggaa. 
leawhat 
is the last word on there in 
25 
Q. 
Don't you find that term offensive? 
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nsor & Associates 
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2 
3 
4 
5 
Page 20 
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 
6 
to be asking questions. 
7 
8 
I'm asking for the record the word to be spelled, 
9 
because we don't have a video here today. 
10 
MR. TEIN: These exhibits are part of the 
11 
record. You --
12 
MR. LEOPOLD: Well, it's not marked as an 
13 
exhibit. 
14 
MR. TEIN: Stop interrupting me, 
15 
Mr. Leopold. I have marked and identified as an 
16 
exhibit and you will get it. 
17 
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? 
MR. LEOPOLD: I'm not asking questions. 
MR. LEOPOLD: There has been no 
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nsor & Associates 
;tenoning and Transcription. lAC 
Page 21 
1 
BY MR. TEIN: 
2 
Q. 
Let me ask you, Sdid 
you in fact 
3 
write your friend this message about this deposition? 
4 
A. 
Yes. 
5 
Q. 
So you wrote your triend 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: 
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sor & Associates 
Reporting sod Transcdplion, Mt. 
1. 
2 
Page 22 
Q. 
You wrote that to your friend, didn't you? 
MR. LEOPOLD: Objection. Asked and 
answered, for the fourth time. 
4 
MR. TEIN: You are improperly objecting, 
5 
Mr. Leopold. You have no grounds to object. And 
6 
that's not an objection. 
7 
MR. LEOPOLD: It is an objection. 
8 
MR. TEIN: Then terminate the deposition if 
9 
you think it's been asked and answered. 
10 
11 
from just making an objection to the form of the 
12 
question. As the courts well know, and if you 
13 
practice here in West Palm Beach, many of the 
14 
judges require you to set the objection with 
15 
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 
23 
MR. TEIN: Of course; because you want to 
24 
obstruct. 
25 
MR. LEOPOLD: All right. 
MR. LEOPOLD: Counsel, I am not precluded 
MR. LEOPOLD: I won't do that. 
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nsor & Associates 
Reporting sod Transcription, loc. 
Page 23 
1 
BY MR. TEIN: 
2 
Q. 
you think that giving testimony 
3 
today, under oath, is bull s-h-i-t, don't you? 
4 
A. 
No. 
5 
Q. 
And you wrote that to your friend on 
G 
MySpace last week, didn't you? 
7 
HR. LEOPOLD: Objection. Asked and 
8 
answered. 
THE WITNESS: No, I did not. 
BY MR. TEIN: 
Q. 
You didn't write this exhibit? 
A. 
I wrote that, but I didn't write what you 
13 
said. 
14 
15 
16 
you write that? 
17 
A. 
Yes. 
18 
Q. 
19 
A. 
20 
informed that it was a deposition. 
21 
22 
about what happened when you went to Jeff Epstein's house 
Q. 
You wrote in this exhibit, "I got some 
stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 
Referring to this deposition, didn't you? 
Referring to the court. I was later 
O. 
I'm going to ask you some questions now 
Yee y 
Okay' 
24 
A. 
Oh-huh. 
25 
Q. 
When the police interviewed you one month 
• .0 
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