both to create offices and to appoint officers. In this regard, the concurrence stated that "it was not 
enough simply to repose the power to execute the laws (or to appoint) in the President; it was also 
necessary to provide him with the means to resist legislative encroachment upon that power. The 
means selected were various, including a separate political constituency, to which he alone was 
responsible, and the power to veto encroaching laws, see Art. I, § 7, or even to disregard them when 
they are unconstitutional." Id. at 906 (Scalia, J., concurring). 
HOUSE OVERSIGHT 012393 
6) Lear Siegler, Inc., Energy Products Division v. Lehman, 842 F.2d 1102 (9th Cir. 1988), withdrawn  
in part 893 F.2d 205 (9th Cir. 1990) (en banc): The President refused to comply with provisions of the 
Competition in Contracting Act that he viewed as unconstitutional and thereby allowed for judicial 
resolution of the issue. The Ninth Circuit rejected the President's arguments about the constitutionality 
of the provisions. The court further determined that Lear Siegler was a prevailing party and was 
entitled to attorneys' fees, because the executive branch acted in bad faith in refusing to execute the 
contested provisions. In this regard, the court stated that the President's action was "utterly at odds with 
the texture and plain language of the Constitution," because a statute is part of the law of the land that 
the President is obligated to execute. Id. at 1121, 1124. On rehearing en banc, the court ruled that Lear 
Siegler was not a prevailing party and withdrew the sections of the opinion quoted above. 
HOUSE OVERSIGHT 012394 
TAB 13 
HOUSE OVERSIGHT 012395 
-0929104.TXT 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 2006 CF09454AXX 
STATE OF FLORIDA, 
-vs-
JEFFREY EPSTEIN, 
Defendant. 
DEPOSITION OF 
Wednesday, February 20, 2008 
2:00 p.m. - 4:30 p.m. 
Palm Beach County Courthouse 
205 North Dixie Highway 
West Palm Beach, Florida 33401 
Reported By: 
Judith F. Consor, FPR 
Notary Public, State of Florida 
Consor & Associates Reporting and Transcription 
Phone - 561.682.0905 
1 APPEARANCES: 
2 On behalf of the State: 
3 LANNA BELOHLAVEK, ESQ. 
ASSISTANT STATE ATTORNEY 
4 401 North Dixie Highway 
West Palm Beach, Florida 33401 
5 561.355.7100 
6 On behalf of the Defendant: 
7 MICHAEL R. TEIN, ESQ. 
KATHRYN A. MEYERS, ESQ. 
8 LEWIS TEIN, PL 
3059 GRAND AVENUE, SUITE 340 
Page 1 
2 
HOUSE OVERSIGHT 012396 
-0929104.TXT 
9 	COCONUT GROVE, FL 33133 
10 
On behalf of the Defendant: 
11 	JACK A. GOLDBERGER, ESQ. 
ATTERBURY, GOLDBERGER & WEISS 
12 	250 AUSTRALIAN AVENUE SOUTH 
SUITE 1400 
13 	WEST PALM BEACH, FLORIDA 33401 
561.659.8300 
14 
15 	ALSO PRESENT: 
16 	KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL-EZE 
17 
18 
19 
20 
21 
22 
23 
24 
25 
3 
1 	INDEX 
2 	WITNESS: 	PAGE: 
3 
DIRECT EXAMINATION 	4 
4 	BY MR. TEIN: 
5 
6 	- - - 
7 	NO EXHIBITS MARKED 
8 	- - - 
9 
10 
11 
12 
13 
Page 2 
HOUSE OVERSIGHT 012397 
-0929104.TXT 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
4 
1 
2 
3 
4 
5 Thereupon, 
6 
7 
8 
9 
10 
11 BY MR. TEIN: 
12 
13 name. 
14 A. 
15 
16 A. 
17 
Deposition taken before Judith F. Consor, 
Court Reporter and Notary Public in and for the State of 
Florida at Large, in the above cause. 
having been first duly sworn or affirmed, was examined 
and testified as follows: 
THE WITNESS: I do. 
DIRECT EXAMINATION 
Q. Good afternoon. Please tell me your full 
Q. And can you please spell it? 
Page 3 
HOUSE OVERSIGHT 012398 
-0929104.TXT 
18 Q. Thank you. 
19 May I call you 
20 A. Uh-huh. 
21 Q. , 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 
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 Q. 111111 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. my uncle. 
Page 4 
HOUSE OVERSIGHT 012399 
-0929104.TXT 
23 Q. Anyone else living there? 
24 A. No. 
25 Q. The contempt motion that your mother filed 
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 did your firefighter boy 
12 friend _____________________ get an apartment for the two of 
13 you? 
14 A. No, sir. He has an apartment, but by 
15 himself. 
16 Q. Did he get an apartment for the two of you 
17 to live in? 
18 A. No, sir. 
19 Q. Are you planning to move in with him? 
20 A. Maybe one day in the future 
21 O. Do you have a plan to move in with him 
22 presently? 
23 A. No. 
24 Q. Have you been to the apartment that you and 
25 have discussed moving in together? 
Page 5 
HOUSE OVERSIGHT 012400 
-0929104.TXT 
7 
1 A. I have been to the apartment. 
2 Q. Where is that? 
3 A. 
4 Q. Have you spent the night over there? 
5 A. No, sir. 
6 Q. Do you know the address there? 
7 A. I do not. 
8 Q. Isn't your sister planning on living 
9 with you and 1111. 
10 A. No. 
11 Q. you know that this court case is a 
12 criminal prosecution, correct? 
13 A. Correct. 
14 Q. And you know that it's a criminal 
15 prosecution against a man who has no criminal background. 
16 Do you know that? 
17 A. I do now. 
18 Q. You agree that court is a very serious 
19 matter? 
20 A. Yes. 
21 Q. And you're here with your lawyer 
22 Mr. Leopold, right? 
23 A. Yes. 
24 Q. And you know that Mr. Leopold recently 
25 filed a lawsuit in federal court against Jeffrey Epstein, 
8 
1 seeking fifty million dollars. 
2 MR. LEOPOLD: Let me just object. 
3 let me instruct you. Anything that 
4 you have learned through conversations between you 
Page 6 
HOUSE OVERSIGHT 012401 
-0929104.TXT 
5 and me are protected. So if you know any of that 
6 information outside of those discussions, you may 
7 answer. But if the only way you know it is 
8 through our discussions, do not answer that 
9 question. 
10 BY MR. TEIN: 
11 Q. you know that Mr. Leopold recently 
12 filed a lawsuit in federal court on your behalf against 
13 Jeffrey Epstein seeking fifty million dollars. 
14 MR. LEOPOLD: Same objection. 
15 If you know the answer to that outside of 
16 our discussions, you may answer. If it is the 
17 only way that you know the answer is through our 
18 discussions, do not answer that question. 
19 THE WITNESS: Okay. 
20 MR. LEOPOLD: Attorney/client privilege. 
21 BY MR. TEIN: 
22 Q. You can answer the question unless 
23 MR. LEOPOLD: Same objection. 
24 MR. TEIN: Let me finish. 
25 MR. LEOPOLD: Excuse me. We're 
9 
1 MR. TEIN: No. Let me finish. 
2 MR. LEOPOLD: Lewis, we're not going to do 
3 that. 
4 MR. TEIN: My name is not Lewis. 
5 I'm going to finish my question. Okay? 
6 MR. LEOPOLD: Do not answer until you hear 
7 from me. 
8 BY MR. TEIN: 
Page 7 
HOUSE OVERSIGHT 012402 
-0929104.TXT 
9 Q. Other than conversations that you have had 
10 with Mr. Leopold -- I'm not asking about that -- are you 
11 aware that Mr. Leopold has filed a lawsuit in federal 
12 court seeking fifty million dollars from Jeffrey Epstein 
13 on your behalf? 
14 MR. LEOPOLD: Same objection. 
15 Anything that you learn through 
16 conversations between you and me, do not answer. 
17 Those are protected. If you know through any 
18 other realm of knowledge, you may answer. 
19 THE WITNESS: No. 
20 BY MR. TEIN: 
21 Q. You have no idea that Mr. Leopold filed a 
22 fifty million-dollar lawsuit on your behalf against 
23 Jeffrey Epstein? 
24 MR. LEOPOLD: Same objection. 
25 Do not answer that question if it's through 
10 
1 discussions that you and I had. Outside of that, 
2 you may answer. So do not answer that question if 
3 that is the only basis by which you understand 
4 that answer. 
5 THE WITNESS: No. 
6 BY MR. TEIN: 
7 Q. You didn't know that? 
8 MR. LEOPOLD: Don't answer that question. 
9 Against, it's attorney/client privilege. Any 
10 information you've learned through conversations 
11 between you and I are protected. If you know it 
12 through any other realm, you may answer. 
13 MR. TEIN: Are you going to say that for 
Page 8 
HOUSE OVERSIGHT 012403 
-0929104.TXT 
14 every question in the deposition, Mr. Leopold? 
15 MR. LEOPOLD: When you ask improper 
16 questions like that without the proper --
17 MR. TEIN: You're going to stop your 
18 speaking objections right now. Okay? 
19 MR. LEOPOLD: Without the proper --
20 MR. TEIN: You need to stop your speaking 
21 objections. 
22 Let's continue. 
23 MR. LEOPOLD: Counsel, you just asked me a 
24 question and I'm going to state it on the 
25 record --
11 
1 MR. TEIN: You need to stop your speaking 
2 objections. Check your rules. 
3 MR. LEOPOLD: Excuse me. For the record, 
4 Counsel asked me a question. I'll state the 
5 answer on the record. He asked me the question am 
6 I going to be answering that way throughout the 
7 deposition. So long as there's improper 
8 foundation and predicate asked by the attorney, I 
9 will protect my client and I make the record where 
10 appropriate. If counsel wishes to ask an 
11 appropriate worded question with the proper 
12 foundation and predicate, I will certainly allow 
13 the client to answer the question. 
14 MR. GOLDBERGER: Why don't you just state 
15 attorney/client privilege and just be done with 
16 it. 
17 MR. LEOPOLD: I want the record to be 
Page 9 
HOUSE OVERSIGHT 012404 
-0929104.TXT 
18 clear. 
19 MR. TEIN: You want to waste time is what 
20 you want to do. You were supposed to be here this 
21 morning and you totally broke the deal, the 
22 agreement that you had with us if your hearing got 
23 cancelled. 
24 But let's move on and maybe you'll stop 
25 obstructing this deposition. 
12 
1 MR. LEOPOLD: I think the record is very 
2 clear where we stand thus far. 
3 Is there a recording taken of this 
4 deposition? 
5 THE COURT REPORTER: Yes. 
6 MR. LEOPOLD: Just make sure that's 
7 preserved. 
8 BY MR. TEIN: 
9 Q. Go to Exhibit 20-01 -- well, before you do 
10 that, , are you aware that a lawyer named Jeffrey 
11 Herman filed a lawsuit on your behalf, yes or no? 
12 MR. LEOPOLD: Objection. 
13 Any conversations that you and I have had 
14 regarding that, if that is the only way by which 
15 you understand how to answer that question, so not 
16 answer. It's attorney/client privilege, as well 
17 as any conversations you may have had with the 
18 attorney from Miami. That is also attorney/client 
19 privilege. And I'm assuming --
20 MR. TEIN: You're actually wrong about the 
21 attorney/client privilege. 
22 MR. LEOPOLD: I'm assuming Counsel is not 
Page 10 
HOUSE OVERSIGHT 012405 
-0929104.TXT 
23 asking you to divulge attorney/client --
24 MR. TEIN: Of course not. 
25 BY MR. TEIN: 
13 
1 
2' 
4 tAU4IfEagAblaglaft0SORMODWYAK0000 
4 MR. LEOPOLD: Same objection. 
5 MR. TEIN: We've heard the objection 10 
6 times already. 
7 MR. LEOPOLD: Counsel, excuse me. 
8 MR. TEIN: Just say attorney/client 
9 privilege. Stop interrupting my questions. 
10 MR. LEOPOLD: I'm entitled to make an 
11 objection for the record, which I'm doing, and 
12 I'll make the same objection. And if it calls for 
13 attorney/client privilege, any conversations you 
14 and I have had, do not answer the question. 
15 And I think that it might be appropriate 
16 for the record to ask questions via 
17 as opposed to I think that would be more 
18 appropriate for this deposition. 
19 BY MR TEIN: 
20 Q. Go ahead. Please answer yes or no. 
21 la TOD 
22 Q. Thank you. 
23 In fact, you know that Mr. Herman held a 
24 press conference after he filed the fifty-million-dollar 
25 lawsuit on your behalf, don't you? 
Q. 400iiii.P.0:41.5-0MOVA.Offriqw.liAtm4Rg 
biVAttotoOgeft toutigfiftS00 tITWOOTIOJtilki5WW-9.00t: 
Page 11 
HOUSE OVERSIGHT 012406 
-0929104.TXT 
14 
1 A. After it happened. 
2 Q. You know that he had press conference 
3 don't you, yes or no? 
4 A. ISI 
5 Q. In fact, let's go to Exhibit 20-01. 
6 MR. GOLDBERGER: Look behind you. You'll 
7 see it. 
8 BY MR. TEIN: 
9 Q. Have you ever seen that picture before? 
10 A. Yes. 
11 Q. Is that a picture of your father, your 
12 stepmother and Mr. Herman at the press conference 
13 regarding your lawsuit? 
14 A. Yes. 
15 Q. Now you know that this is a very serious 
16 matter, don't you? 
17 MR. LEOPOLD: Asked and answered. 
18 Objection. 
19 MR. GOLDBERGER: All right. You can 
20 object. You're representing a witness here, 
21 Mr. Leopold. You can object on privilege grounds. 
22 You cannot make legal objections. You have no 
23 standing to do so. 
24 MR. LEOPOLD: I'm going to make them and 
25 then --
15 
1 MR. GOLDBERGER: We're --
2 MR. LEOPOLD: We're going to leave or we're 
3 going to take a break because his demeanor is not 
4 appropriate. There's no reason to have this kind 
Page 12 
HOUSE OVERSIGHT 012407 
-0929104.TXT 
5 of demeanor. If you want to have this kind of 
6 demeanor with me 
7 MR. TEIN: You are obstructing this 
8 deposition. 
9 MR. GOLDBERGER: Why don't you guys go 
10 outside and just talk about --
11 MR. LEOPOLD: She -- her job is very 
12 difficult and she's not going to be able to take 
13 us both talking at he same time. 
14 MR. GOLDBERGER: Off the record. 
15 MR. LEOPOLD: We're not going off the 
16 record, Jack. We're not, Jack. Her job is very 
17 difficult. I'm going to make the record. 
18 I don't think it is appropriate, especially 
19 in the small confines of this room, to be very 
20 aggressive with this young lady. 
21 MR. TEIN: That's not happening. Stop, 
22 stop actually --
23 MR. LEOPOLD: If you're going to interrupt 
24 me, we're going to cancel this deposition --
25 MR. TEIN: Stop misrepresenting. 
16 
1 THE COURT REPORTER: I need on at a time, 
2 no matter who it is. 
3 MR. LEOPOLD: I think we're going to take a 
4 break. Perhaps you might want to talk to your 
5 co-counsel --
6 MR. TEIN: I don't need to talk to him. 
7 MR. LEOPOLD: But we're going to take a 
8 break. 
Page 13 
HOUSE OVERSIGHT 012408 
-0929104.TXT 
9 MR. TEIN: Not taking a break unless the 
10 witness needs a break. 
11 You're obstructing this deposition, Ted. 
12 MR. LEOPOLD: Come on, 
13 You all want to continue in this 
14 demeanor --
15 MR. TEIN: You're obstructing the 
16 deposition. Stop making speeches. We're not 
17 discussing this with you. The questions are to 
18 your client. Go take your five-minute break. 
19 MR. LEOPOLD: Fine. We need to make sure 
20 the record's clear and clean. 
21 And I want to make sure as I've already 
22 asked you -- I know that you're one of the best in 
23 town -- that this audio -- this needs to be 
24 preserved. Okay? 
25 MR. TEIN: Go take your five-minute break, 
17 
1 Mr. Leopold, now. 
2 You were supposed to be here at nine a.m.; 
3 it's now after two. Take your break and come 
4 back. 
5 MR. LEOPOLD: Okay. If the demeanor keeps 
6 up, we will not be here beyond those five minutes. 
7 
8 
9 relax. 
10 
11 break. 
MR. TEIN: Take your break and come back. 
MR. LEOPOLD: Okay. So I suggest that you 
MR. TEIN: I suggest that you take your 
12 MR. GOLDBERGER: Let them take that 
13 five-minute break. 
Page 14 
HOUSE OVERSIGHT 012409 
-0929104.TXT 
14 MR. LEOPOLD: But I would suggest that you 
15 take deep breaths. 
16 MR. TEIN: Suggest whatever you want. Go 
17 take a break. 
18 (Thereupon, a recess was taken.) 
19 BY MR. TEIN: 
20 Q. you agree that giving testimony 
21 today at your deposition is something very serious, don't 
22 you? 
23 A. Yes. 
24 Q. 
25 A. 
ANT 5i.000%.5 
WO_ 40m 
1 Q. Let me show you Exhibit 31-001. Can you 
2 read that out loud, please? 
3 A. Okay. What do you want? 
4 Q. Will you read that out loud, please. 
5 A. Oh. 
6 Q. Thank you. 
7 A. 
M*1 
hati MOW 
3g.:4 
On WOOt 
00310.04. 
Like after so long wow 
18 
10 im sorry... well yah well we will definitely havta make 
11 plans for sure. .because i miss u tons times a million and 
12 no no no i love you...o p.s. i love ur default pic 
13 niggaa. Muah xo. 
14 Q. Did you send that message last week to a 
15 friend of yours on MySpace? 
16 A. I wouldn't know. There's no dates and I've 
17 deleted that MySpace, so --
Page 15 
HOUSE OVERSIGHT 012410 
-0929104.TXT 
18 Q. Were going to talk about that in a second. 
19 A. Okay. 
20 Q. Did you send that message last week 
21 A. Right. 
22 Q. Let me finish my question. 
23 Did you send that message last week to a 
24 friend of yours on MySpace? 
25 A. I wouldn't know the date, but obviously, 
19 
1 it's to a friend. 
2 Q. q NOW A 400$0g m110 
3 loPMPOAMYWOOZ 
4 
7 
8 
9 
10 
11 
12 
13 THE WITNESS: Are you referring to 
14 anything --
15 MR. LEOPOLD: No, Don't -- don't --
16 let him ask you the question. 
17 BY MR. TEIN: 
18 Q. What question were you asking.. 
19 MR. LEOPOLD: She doesn't ask questions. 
20 You ask the questions. What is the question 
woimyov: 
vIroforriog,to thisA0poItton7; 
YO: 
Q. Do you find the term n-i-g-g-e-r offensive? 
A. That's not anywhere in there. 
Q. What word did you use in there? 
MR. LEOPOLD: Where are you referring to, 
Counsel? There's 20 plus words in there. 
MR. TEIN: Don't make a speaking objection. 
21 pending? 
22 BY MR. TEIN: 
Page 16 
HOUSE OVERSIGHT 012411 
-0929104.TXT 
23 Q. what is the last word on there in 
24 the text of your message before the closing? 
25 A. Niggaa. 
20 
1 Q. Don't you find that term offensive? 
2 A. No. 
3 MR. LEOPOLD: Can you spell it for the 
4 record, please. 
5 THE WITNESS: N-i-g-g --
6 MR. TEIN: No, no, no. You are not going 
7 to be asking questions. 
8 MR. LEOPOLD: I'm not asking questions. 
9 I'm asking for the record the word to be spelled 
10 because we don't have a video here today. 
11 MR. TEIN: These exhibits are part of the 
12 record. You --
13 MR. LEOPOLD: Well, it's not marked as an 
14 exhibit. 
15 MR. TEIN: Stop interrupting me, 
16 Mr. Leopold. I have marked and identified as an 
17 exhibit and you will get it. 
18 MR. LEOPOLD: There has been no 
19 identification of this document in the record. 
20 MR. TEIN: Mr. Leopold, stop interrupting 
21 this deposition 
22 MR. LEOPOLD: What is the exhibit number 
23 marked for identification? 
24 MR. TEIN: 31-001. 
25 MR. LEOPOLD: Do we have copies? Is it on 
Page 17 
HOUSE OVERSIGHT 012412 
-0929104.TXT 
21 
1 the record anywhere? 
2 BY MR. TEIN: 
3 Q. Let me ask you, did you in fact 
4 write your friend this message about this deposition? 
5 
6 
7 40 
8 A. Yes. 
9 Q. Because you think this deposition is stupid 
10 court s-h-i-t, don't you? 
11 A. No. 
12 Q. You wrote that to your friend, didn't you? 
13 A. Yes. 
14 Q. You think that court is stupid, don't you? 
15 A. In some cases. 
16 Q. And you think that court is bull s-h-i-t, 
17 don't you? 
18 A. No. 
19 Q. And you think this deposition is bull 
20 s-h-i-t, don't you? 
21 A. No. 
22 Q. You wrote that to your friend, didn't you? 
23 MR. LEOPOLD: Objection. Asked and 
24 answered. 
25 MR. TEIN: That's not an objection. 
A. 
Q. 
positio 
Yes. 
'00gWrOtO 15100 
stupid400 
deamutttio 
22 
1 BY MR. TEIN: 
2 Q. You wrote that to your friend, didn't you? 
3 MR. LEOPOLD: Objection. Asked and 
4 answered, for the fourth time. 
Page 18 
HOUSE OVERSIGHT 012413 
-0929104.TXT 
5 MR. TEIN: You are improperly objecting, 
6 Mr. Leopold. You have no grounds to object. And 
7 that's not an objection. 
8 MR. LEOPOLD: It is an objection. 
9 MR. TEIN: Then terminate the deposition if 
10 you think it's been asked and answered. 
11 MR. LEOPOLD: Counsel, I am not precluded 
12 from just making an objection to the form of the 
13 question. As the courts well know, and if you 
14 practice here in West Palm Beach, many of the 
15 judges require you to set the objection with 
16 specificity. And I will do that. And if you 
17 don't want me to, you can make the record. But I 
18 will do that. 
19 MR. TEIN: Here's what we'll do, Ted. You 
20 can -- I will allow you to reserve an objection to 
21 form for every single one of my questions. 
22 Otherwise, all you're doing is obstructing. 
23 MR. LEOPOLD: I won't do that. 
24 MR. TEIN: Of course; because you want to 
25 obstruct. 
23 
1 MR. LEOPOLD: All right. 
2 BY MR. TEIN: 
3 Q. Saige, you think that giving testimony 
4 today, under oath, is bull s-h-i-t, don't you? 
5 A. No. 
6 Q. And you wrote that to your friend on 
7 MySpace last week, didn't you? 
8 MR. LEOPOLD: Objection. Asked and 
Page 19 
HOUSE OVERSIGHT 012414 
-0929104.TXT 
9 answered. 
10 THE WITNESS: No, 1 did not. 
11 BY MR. TEIN: 
12 Q. You didn't write this exhibit? 
13 A. I wrote that, but I didn't write what you 
14 said. 
15 Q. You wrote in this exhibit, "I got some 
16 stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 
17 you write that? 
18 A. Yes. 
19 Q. Referring to this deposition, didn't you? 
20 A. Referring to the court. I was later 
21 informed that it was a deposition. 
22 Q. I'm going to ask you some questions now 
23 about what happened when you went to Jeff Epstein's house 
24 three years ago. Okay? 
25 A. Uh-huh. 
Q VOMMO4OF 
24 
00giyou oneMOM 
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5 
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4a NOR, AbOBEW*TfN00.0002 4N000010M0ft 
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Ii A. Yes 
12 Q. Now the civil complaint that you filed 
13 against Mr. Epstein for fifty million dollars alleged 
Page 20 
WOW MOMMEht 
eff 
HOUSE OVERSIGHT 012415 
-0929104.TXT 
14 that you were totally shocked by what happened when you 
15 got there. 
16 A. Yes. 
17 Q. Were you totally shocked by what happened 
18 when you got to Epstein's house? 
19 A. Yes. 
20 Q. You didn't expect it at all, did you? 
21 
22 
A. 
No. 
)1.0.0;1144.441).$0.Mrat/g00:3400AWiSfOgg.ftt010-
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11 
12 engage in any sexual activity with Epstein? 
13 A. No. 
14 Q. Did Anthony every try to convince 
15 you to engage in any sexual activity with Epstein? 
16 A. I don't know who Anthony is. 
17 Q. Do you have a friend Anthony? 
Page 21 
A. 
house 
0151INOWaVaitiN#XVO.Iii 
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And b440410POPAROPOIPWWW 
never sent yo a message100MONTOtOtk, 
... activity 0 Epstein, did 
Q. Did Zack ever try to convince you to 
HOUSE OVERSIGHT 012416 
-0929104.TXT 
18 A. No. 
19 140 :ONOYiN 
Babreimulglivent%scREDstemRsMitycme 
20• to Thd.HOMiiiY008g0g0 
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24 UnOfillMihaW0A0000TOOdgt0g1405$04 
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1 
2 
3 again. 
4 
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7 
14 
15 objection for the record. 
16 MR. TEIN: Stop speaking. 
17 MR. LEOPOLD: I'm not going to stop 
18 
19 the record. 
20 MR. TEIN: You're coaching the witness. 
21 MR. LEOPOLD: Counsel --
22 MR. TEIN: Stop coaching the witness. 
Page 22 
NO:. 
gg *OIL 
Q. 
dowAi 
U. tooigàge In 
26 
You're sure that -- let me ask the question 
Yd a. tibt 00f6MVOW-4Mtd; 
yw 
0-trt0d4tO_MIU 
a 
de you to engago 
MR. LEOPOLD: Objection. Asked and 
8 answered. 
9 THE WITNESS o And I've already 
10 answered that a bazillion times. 
11 BY MR. TEIN: 
12 Q. He's coaching you now. So I'm going to ask 
13 the question --
MR. LEOPOLD: Counsel, I've made an 
speaking. You can't interrupt me when I'm making 
HOUSE OVERSIGHT 012417 
-0929104.TXT 
23 BY MR. TEIN: 
24 Q. let me ask you --
25 MR. LEOPOLD: If you continue to --
27 
1 MR. TEIN: Stop interrupting my questions. 
2 MR. LEOPOLD: If you do it one more time, 
3 we're leaving. 
4 BY MR. TEIN: 
5 Q. 
6 MR. LEOPOLD: I'm going to make the record. 
7 You cannot interrupt me when I'm making the 
8 record. Out of professional conduct, you cannot 
9 do that. I'm entitled to make the record. I made 
10 an objection, asked and answered. You demeanor is 
11 inappropriate. You're willing and you are able 
12 and you're responsible to ask a question in a 
13 professional manner and ask the question and once 
14 you get the answer, to either follow up on it or 
15 move on, but not continuously browbeat and ask the 
16 same question over and over because you don't like 
17 the answer. 
18 MR. TEIN: Calm down, sir. 
19 MR. LEOPOLD: Trust me, I'm very calm here. 
20 When I'm not calm you'll know it. I'm very calm. 
21 So please continue on, but I will not allow 
22 you to continue to harass her in the demeanor that 
23 you're doing. Ask her a question and move on. 
24 MR. TEIN: Are you done? 
25 MR. LEOPOLD: Thank you. I am. 
Page 23 
HOUSE OVERSIGHT 012418 
-0929104.TXT 
28 
1 MR. TEIN: Stop misrepresenting the record 
2 and calm down. I'm going to ask my question. 
3 Stop it. 
4 BY MR. TEIN: 
5 Q. 
6 MR. LEOPOLD: I think the record is very 
7 clear. 
8 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 MR. TEIN: Will you stop speaking now so I 
15 can ask my question? Are you done? 
16 Okay. I'm going to ask my question. 
17 BY MR. TEIN: 
18 Q. Listen, 
19 MR. LEOPOLD: Hold on. Stop. 
20 I've been doing this for 20 plus years and 
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 MR. LEOPOLD: If you continue to do this, 
25 whether its with me or with my client, I will not 
29 
1 put up with it and I don't need to put up with it 
2 and it's not appropriate. And I'm sure Mr. 
3 Goldberger knows all this, because I know that he 
4 wouldn't do this. So I will not put up with it. 
Page 24 
HOUSE OVERSIGHT 012419 
21 
22 
23 
24 
25 
1 
3 
1:$ 
5 
6 
-0929104.TXT 
And I think it's highly inappropriate to do this 
with this child sitting here, the way you're 
7 acting, primarily towards me, and I will not put 
8 up with it. 
9 MR. TEIN: Will you please stop your speech 
10 so I can ask questions? 
11 MR. LEOPOLD: So long as you act 
12 professionally, I will do so. But if you continue 
13 to do it this way, I will leave. 
14 MR. TEIN: Suit yourself. 
15 BY MR. TEIN: 
16 
la 
are you sure that brore you go:t. 
ie tried to..."TttUalCSO.40.3Migtr.1 
$0001g6M9440Witft 'gtb4W bitHM40/7 
19 MR. LEOPOLD: Asked and answered. 
20 Objection. 
MR. TEIN: Did you get her answer? 
THE COURT REPORTER: No, I did not. 
THEATINEW 
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BY MR. TEIN: 
OtH0080 
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30 
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Q Jeff never e-rnai led you, dd he? 
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Page 25 
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HOUSE OVERSIGHT 012420 
-0929104.TXT 
1 
2 
A. 
Q. 
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ad you 
And  you only went 
that one time three years ag, correct? 
A. 
Yu never went there again, 
A. No. 
taiiiaariiitpAtOtdaZba1$0 
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Q. All right. Let me ask you two final areas 
3 of questioning about this and we'll move onto something 
4 else. Okay? 
5 A. Uh-huh. Yes. I'm sorry. 
6 moggrommok -WOMOOW 
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erce you to engage 
WOWinduce, entice or c 
Page 26 
31 
HOUSE OVERSIGHT 012421 
-0929104.TXT 
14 engage in any sexual activity? 
!;IS 
Q. 
5WW.OTWYOdttOt 
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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 Q. Who was the other girl in the car with you 
24 that day? 
25 A. I honestly don't know. 
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 Agt A0410400Ahlk Page 27 
27 
HOUSE OVERSIGHT 012422 
-0929104.TXT 
18 hoL 
19 
20 
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 
300MERMY0040$0 
Q. All right. Let's talk for a minute about 
A. Excuse me? 
33 
1 ' 000#000; hONtd#0400400) 
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3 Not. whrW fi rsti................rtrodUd P4OWMOr 
4 WOht AMter$40X4MY: 
5 Q. During the massage Jeff asked you how old 
6 you were, correct? 
7 A. Yes, yes. 
8 Q. Now hadn't you already told Jeff's 
9 assistant, 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. Do you want to rethink that answer? 
16 A. No. I didn't really speak with her that 
17 much. 
18 Q. Do you want to try to refresh your memory 
19 on that? 
20 MR. LEOPOLD: Do you have something to 
21 refresh her memory with? 
22 MR. TEIN: Do you want to stop making 
Page 28 
HOUSE OVERSIGHT 012423 
-0929104.TXT 
23 speaking objections? 
24 MR. LEOPOLD: No. But to refresh someone's 
25 memory you show them a document. 
34 
1 
2 
3 
4 
5 
6 
7 
MR. TEIN: I know how to do this. 
MR. LEOPOLD: Then show her a document. 
MR. TEIN: Stop speaking. 
MR. LEOPOLD: I'm not going to stop 
speaking. I'm going to continue to make the 
record. 
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: 
Page 29 
HOUSE OVERSIGHT 012424 
-0929104.TXT 
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 W WNW Ri Jeff that you weragInf 
10-,L gOttOM 
13 YO*0 
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 igogp_....................................................... Wppj$4tdatiOUWWW-  :thJf1HVoUrdi 
....... MOtbaWOMitti.0040$0400 
22 
JAM 
00§WR 
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25 Q. And do you remember telling Detective Pagan 
.i$ound, 
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 lying? 
4 A. No, I don't remember saying those words 
Page 30 
HOUSE OVERSIGHT 012425 
-0929104.TXT 
5 exactly to her. 3-gtoioobotawmgatgaiampao 
44XPTIVAMMOWTOZ 
7 Q. 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've made the objection. 
24 THE WITNESS: I forget the question, now. 
25 
37 
1 BY MR. TEIN: 
2 
3 
4 
7 
8 
Q. Let me put it again. 
P9g*iiPg$01400:gr*OggPgYOm 4;.!ggo.lo 
;!pgpootif:MgRggpmingvmhowa. I,:ttWoh•otrPsoutuogmixo 
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4146AtAbbtg iff6M4V 
8-0 
MR. LEOPOLD: Objection. 
foundation, asked and answered. 
Page 31 
HOUSE OVERSIGHT 012426 
9 
44 
11 BY MR. TEIN: 
12 
-0929104.TXT 
3#,RIMEMPAt 
f0.00X1J 
:ro.:,,,:lylog*i.04t1Yourogg:15401tz 
-#Z 00t0.0t 
15 Q YOM0140MOOVI.,Mr Epstein to know that 
T uwot.i8.zitTgbtZ: 
::POtPOOtM: 
100104mOdMit&tt*tOitotd:A$4:140Mth4t 
Hy were is, right? 
24 	Wh e 	Ak , 	Correct. Do you remember when Mr. :g4tfl omooto school? Aritd1iMr Epstein Y0 ONWOWXR right? 
38 
1 	A. 	Yes. 
2 	q. 	Was that thGxpowz, W 
4 	Q. 	In fact, you went to 	right? 
5 	A. 	Yes. 
6 	Tm 	wsc- Tiedgzogyi 01.#1540PrOOPZ. 
006 
8 	Q. 	Is Wellington the college that you told 
9 	Jeff's assistant that you were attending? 
10 	A. 	I don't remember having that conversation 
11 	with her, so I wouldn't know if that's what I said. 
12 	Q. 	That was a lie, though, wasn't it? 
13 	MR. LEOPOLD: Objection to the form of the 
Page 32 
HOUSE OVERSIGHT 012427 
-0929104.TXT 
14 15 16 17 	question, lack of foundation. You're making an assumption. She just answered you she can't tell you that. MR. TEIN: Speaking objection. And you 
18 	well know that, Mr. Leopold. 
19 	MR. LEOPOLD: She can't answer that 
20 	question. The way you phrased that question 
21 	you're purposely making her not be honest in her 
22 	testimony. She can't answer a question like that. 
23 	She doesn't remember So then you say, "So you 
24 	were lying." That's improper and you know that. 
25 	That's not a proper question. And any attorney 
39 
1 	that would do that to a witnesses or to a person 
2 	that's sitting in this chair is not acting 
3 	professionally. You can't ask a question like 
4 	that. You can do it, but it's not proper. And 
5 	I'm sure you weren't trained that way, certainly 
6 	not ethically. 
7 	MR. TEIN: Will you stop? 
9 	MR. LEOPOLD: I'm not going to stop, because the way you're asking that question is 
10 	improper and you know it. 
11 	MR. TEIN: You're losing your cool. 
12 	BY MR. 	TEIN: 
13 	Q. 
14 	MR. LEOPOLD: Trust me. I'm very calm. 
15 	When I 	lose my cool, you'll know it. 
16 	MR. TEIN: I do know it. 
17 	BY MR. 	TEIN: 
Page 33 
HOUSE OVERSIGHT 012428 
104. TXT 
18 •:Q,.11it Mr'r:::'.1::Eri:$K%Olii.009:0.n!..0-$.-gOtlz-S0,0:-
Ta ,K.Mii:.....M6:01110M0100t:!kititiaiiiit05$4402.1.1110igi00.C100-gitZ 
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4Y6 
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25 
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MR. LEOPOLD: Objection. Foundation, 
40 
predicate. 
THE WITNESS: Correct. 
You toldthe p01 lce :A*Otatg#00Matbbt 
him 46....2.4V-
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IA00$MOOMMOOtai: 
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At no time di 
did you? 
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114 'AMEXWOW 
I ncorrect. 
Well, you told the police, "At no time did 
Page 34 
HOUSE OVERSIGHT 012429 
-0929104.TXT 
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. 
41 
1 Q. You told the police twice when you spoke to 
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. 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 
14 
15 
16 
17 
18 
todu 
47@ga 
A. YOU t001( that 01..rt of context I 4C4Wrea 1 
didn-tt an lIke that. Touching my legSsand --
kePtlilhands to himself tile entire time. 
TWV 
to 
Q. You told the police, "At no times did he 
touch me." You agree with that, correct? 
A. No, I don't agree with that, because he did 
touch me. 
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 ,(W A60400HOUIROWNVOROYA9W0f3WO 
VIVT 4OrCIR4611I0Ota 
23 
24 
POz. 
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TWO TAW 
Page 35 
Y tYPe of ora sax 
HOUSE OVERSIGHT 012430 
4 
Q. 
-0929104.TXT 
42 
1 
440394100§f-
POROME: 
All right. 
afEattdOtTi 
Let's talk about what happened 
5 after the massage was over. 
6 
7 
A. Okay. 
Q. After the massage you told Epstein that you 
8 wanted to bring your twin sister back so she could make 
9 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 
1 things, but it wasn't joking about it at all. 
2 Q. You joked about it, didn't you? 
3 A. No. 
4 Q. You said to that if you did this 
Page 36 
43 
HOUSE OVERSIGHT 012431 
-0929104.TXT 
5 every weekend you'd be rich, didn't you? 
6 A. No. That's what told me. 
7 Q. You didn't tell that to =? 
8 MR. LEOPOLD: Objection. Asked and 
9 answered. 
10 THE WITNESS: No. 
11 BY MR. TEIN: 
12 W AMMMYOWTOMEO - '''' :,1000$040w With0-
gi *MVO OIMINA04.... 
14 4W-EtwthONOVezorpootiz 
15 A. Incorrect. I didn't spend any of the 
16 money. 
17 
18 
19 
21 
22 
23 
24 
Q. You went to Marshall's, didn't you? 
A. I went along, yes, but I didn't --
T003000AAMOROWANMANOWOMMOMM 
4. 
MR. LEOPOLD: Objection. 
THE WITNESS: I guess you could say that. 
MR. LEOPOLD: Objection. Lack of predicate 
and foundation. Mischaracterization of earlier 
25 testimony. 
1 BY MR. TEIN: 
2 Q. And 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. 
Page 37 
44 
HOUSE OVERSIGHT 012432 
-0929104.TXT 
9 A. I have no idea what you're talking about. 
10 Q. Tell me about when the federal prosecutors 
11 spoke 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 Marie Villafona 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? 
45 
1 A. It was not this year, no. 
2 Q. Was it 2007? 
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. 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. 
Page 38 
HOUSE OVERSIGHT 012433 
-0929104.TXT 
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? 
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 Marie 
6 Villafona, you don't know who that is? 
7 A. No, sir. 
8 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 Jeffrey Sloman come to 
12 your house? 
13 A. I don't know names, sir. 
14 Q. Do you know who Jeffrey Sloman is? 
15 A. No, sir. 
16 Q. Do you know who Jeffrey Herman is? 
17 A. Yes. 
Page 39 
HOUSE OVERSIGHT 012434 
-0929104.TXT 
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 
47 
1 fashion, you may answer. 
2 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 who Jeff Sloman 
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 Marie Villafona'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. I don't know who he is. 
Page 40 
HOUSE OVERSIGHT 012435 
-0929104.TXT 
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 
48 
1 
2 
3 
4 
5 
6 
7 
Florida Bar? 
A. I did not select him. 
Q. Who did? 
A. My father. 
Q. Did you ever meet Mr. Herman? 
A. Once. 
Q. Don't -- don't tell me what you discussed 
8 with him. Where did you meet him? 
9 
10 friend's house. 
11 Q. Whose house? 
12 A. My friend 
13 Q. Is that from 
14 
15 
16 
17 
18 
19 
A. I was shopping in my -- he showed up at my 
A. Yes. 
Q. And did you have a meeting with him at 
's house? 
A. Yes. I guess you could say that. 
Q. 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 
Page 41 
HOUSE OVERSIGHT 012436 
-0929104.TXT 
49 
1 Mr. Herman in the presence of 
2 A. None. 
3 Q. What discussions did you have in the 
4 presence of her aunt? 
5 A. Of my aunt? 
6 MR. GOLDBERGER: It's the witness's aunt. 
7 BY MR. TEIN: 
8 Q. Oh, of your aunt. 
9 A. The only one that we've ever discussed or 
10 ever had. 
11 Q. And so you were in a conversation with 
12 Mr. Herman and your aunt? 
13 A. Yes, sir. 
14 Q. And you discussed privileged matters during 
15 that conversation? 
16 MR. LEOPOLD: Object to the form. I think 
17 you might have to educate her on that question. 
18 BY MR. TEIN: 
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. 
50 
1 Q. Why did the meeting take place at 
2 house? 
3 A. I spent the night that night at her house. 
4 Q. And when was this? 
Page 42 
HOUSE OVERSIGHT 012437 
5 A. 
6 Q. 
7 A. 
8 Q. 
9 A. 
10 
11 
12 
13 
14 
15 
16 
-0929104.TXT 
A while ago. 
How long ago? 
A month and a half ago. I'm 
A month and a half ago? 
Uh-huh. 
:WWWJMOWOMOVAMOVAIna 
guessing. 
ottotattriA0.0.. 
4W ABM 
Q. Did you meet what an FBI agent named Nesbit 
Kirkendall, a woman? 
A. I don't know. 
Q. Did Ms. Kirkendall speak to you about 
17 getting reimbursed from Mr. Epstein? 
18 
19 
20 
21 
22 A. Not to my knowledge. 
A. I've never had a discussion with anyone 
about getting reimbursed from Mr. Epstein. 
Q. Have you met with an agent named Jason 
Richards? 
23 Q. 
24 A. 
25 Q. 
How about an agent named Tim Slater? 
No, sir. 
How about an agent named Junior Ortiz? 
51 
1 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 --
Page 43 
HOUSE OVERSIGHT 012438 
-0929104.TXT 
9 A. Uh-huh. 
10 Q. -- did anyone ever discuss with you that 
11 you could get reimbursement for your damages? 
12 A. No, sir. 
13 Q. Did you or any member 
14 MR. LEOPOLD: Are you referring to a 
15 criminal matter or a civil matter? 
16 BY MR. TEIN: 
17 Q. Did you or any member --
18 MR. LEOPOLD: Excuse me. Let me object to 
19 the form of the question. 
20 BY MR. TEIN: 
21 Q. Did you or any member of your family ever 
22 get a victim notification letter from anyone? 
23 A. I no longer live at that residence and I 
24 wouldn't know. 
25 Q. So your testimony is that you have never 
52 
1 received a victim notification letter, correct? 
2 A. Correct. 
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. 
Page 44 
HOUSE OVERSIGHT 012439 
-0929104.TXT 
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 
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 
Page 45 
HOUSE OVERSIGHT 012440 
-0929104.TXT 
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, Saige, you lied to get out of this 
25 deposition, didn't you? 
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: Objects 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. 
Page 46 
HOUSE OVERSIGHT 012441 
23 
24 
25 
-0929104.TXT 
MR. TEIN: Certify it. 
MR. LEOPOLD: Please. 
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 to lie for you, didn't you? 
8 A. No. I informed my boss about what was 
9 going on and he told me that he would help in any way 
10 that he can. 
11 Q. Okay. You got your friend to lie 
12 by switching name tags with you, correct? 
13 A. Incorrect. It was a coincidence that same 
14 night she was not wearing her name tag; she was wearing 
15 mine. But I was also not wearing -- I was wearing my 
16 name tag. Everyone switches name tags. It just so 
17 happens it was a coincidence that same night the people 
18 came with the papers. 
19 MR. TEIN: Will you put up Exhibit 18-001? 
20 MR. GOLDBERGER: And mark 18-001 for 
21 identification purposes to this deposition. 
22 MR. LEOPOLD: None of them have been marked 
23 yet. Can we mark them and put them as attachment 
24 to the depositions? Because I think you've shown 
25 three photos now. And this is the only one that 
Page 47 
HOUSE OVERSIGHT 012442 
-0929104.TXT 
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. I've put a photograph marked 18-001 
18 up on the screen. Do you see that? 
19 A. Yup. 
20 Q. Who is that in the photo? 
21 A. on the left and me on the right. 
22 Q. right? 
23 A. Yes. 
24 Q. your friend at the 
25 right? 
57 
1 A. Yes. 
2 Q. your friend, who you say the day 
3 that the process servers went to serve you with a 
4 subpoena for this deposition, just happened --just by 
Page 48 
HOUSE OVERSIGHT 012443 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
-0929104.TXT 
coincidence, was wearing your name tag? 
A. Yes, sir. 
Q. And just by coincidence, you were wearing 
her name tag, correct? 
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. 
BY MR. TEIN: 
Q. NOW$010gtb AMOOPritM 
going to 
000C90040,03 
Gtflg 
na 
0150000WPOffrOW 
A. c.dittotua 
Q. 1650UKOWDOMM 
00103 
_AtON00 
h that the process serve 
58 
1 looking for you, didn't you? 
2 A. No. I knew --
3 MR. LEOPOLD: Just answer it. It calls for 
4 a yes or no. 
5 THE WITNESS: Okay. No. 
6 BY MR. TEIN: 
7 Q. Now you can explain the answer that your 
8 counsel stopped you from explaining. 
Page 49 
HOUSE OVERSIGHT 012444 
-0929104.TXT 
9 A. Okay. I work at 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 idea who they were or what their intentions were, but 
13 I 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. 
59 
1 MR. LEOPOLD: I'll certify it. 
2 ..................CERTIFIED QUESTION.................. 
3 She's answered that question. She's explained it five 
4 times already. The fact that Counsel doesn't like the 
5 answer, that's a different query. 
6 MR. TEIN: Stop making speaking objections. 
7 MR. LEOPOLD: I'm not. I'm not going to 
8 put up with it, because it's in appropriate, Jack, 
9 and you know it. I will not allow Counsel to 
10 berate a witness, whether it's in a criminal case 
11 or a civil case, whether my client or 
12 MR. TEIN: Calm down. 
13 MR. LEOPOLD: Excuse me. 
Page 50 
HOUSE OVERSIGHT 012445 
-0929104.TXT 
14 No, I'm not going to allow it. That is not 
15 proper. 
16 MR. GOLDBERGER: Okay. 
17 MR. LEOPOLD: If he wants to say that she's 
18 lying after asking it five times and her 
19 explaining in great detail, he can do that. But 
20 I'm not going to allow her to answer, nor be 
21 harassed by him. It's improper. 
22 MR. GOLDBERGER: Okay. But your response 
23 that Counsel doesn't like the question -- or 
24 doesn't like the answer -- just let me finish. 
25 MR. LEOPOLD: Absolutely. I wasn't going 
60 
1 to interrupt you. 
2 MR. GOLDBERGER: Just requires us to say we 
3 like the answer to that question. And it's not 
4 you and t or you and Mr. Tein who are testifying 
5 here. It's the witness. 
6 MR. LEOPOLD: Fine. But after the sixth 
7 time of asking the same question and then coming 
8 back and pointing a finger at her and saying, 
9 you're a liar --
10 MR. TEIN: That didn't happen. 
11 MR. LEOPOLD: That's fine. But I'm not 
12 going to allow her to answer that question because 
13 she's answered that same question and has 
14 explained it. 
15 Now Counsel might be sitting there rubbing 
16 his head with a migraine. That's his problem. 
17 But if he can't ask a question appropriately in a 
Page 51 
HOUSE OVERSIGHT 012446 
-0929104.TXT 
18 professional manner, we will leave. I will not 
19 allow her to be berated like that. 
20 MR. GOLDBERGER: Actually, we're very happy 
21 with the answer. 
22 MR. LEOPOLD: That's great. 
23 MR. GOLDBERGER: Do you want us to get into 
24 that? 
25 MR. TEIN: Ted --
61 
1 MR. LEOPOLD: This is really big stuff that 
2 you're going through, but that's fine; just ask 
3 your question and move on. But do it one time. 
4 If you don't understand it, I'll let you follow 
5 up, but I'm not going to allow you to ask the same 
6 question the time and again and then call her a 
7 liar. Just ask the question, get the answer and 
8 move to the next subject matter. 
9 MR. TEIN: Ted, I'm sitting right across 
10 the table from you. 
11 MR. LEOPOLD: Yes, sir. 
12 MR. TEIN: Please be quiet. Don't yell. 
13 MR. LEOPOLD: I will not be quiet. 
14 MR. TEIN: Stop yelling. 
15 MR. LEOPOLD: Lewis, when I'm yelling 
16 you'll know it. I will not --
17 MR. TEIN: My name is not Lewis. 
18 MR. LEOPOLD: I thought your first name was 
19 Lewis, Mr. Tein. 
20 MR. TEIN: You watched me for three days at 
21 the evidentiary hearing where you sat in the back 
22 of the courtroom. You should know who I am. 
Page 52 
HOUSE OVERSIGHT 012447 
-0929104.TXT 
23 MR. LEOPOLD: Well, that's the impression 
24 you must have made in the courtroom. 
25 I will not be quiet. 
62 
1 MR. TEIN: That's obnoxious. Stop being 
2 obnoxious. It's stupid. Let's go ahead with the 
3 questions. 
4 MR. LEOPOLD: I will make the record. 
5 MR. TEIN: Let's get on with the questions. 
6 MR. LEOPOLD: Do you need a break? 
7 (Thereupon, a recess was taken.) 
8 BY MR. TEIN: 
9 Q. Okay. after you told your manager 
10 at the everything that was going on 
11 and he told you he would help you any way he could, he 
12 hid you in the kitchen from the process servers, correct? 
13 A. Incorrect. 
14 Q. Isn't it true that lying to avoid service 
15 is a meaningless lie to you, 
16 A. Incorrect. 
17 Q. What is your manager's name? 
18 A. I have three. Would you like to know 
19 all 
20 Q. Who's the one who lied for you? 
21 A. Justin. 
22 Q. And what did Justin do to lie for you? 
23 A. Said I wasn't there. 
24 Q. And who did he tell wasn't there? 
25 A. Ask him. 
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HOUSE OVERSIGHT 012448 
-0929104.TXT 
63 
1 Q. Where were you when Justin told this 
2 someone that you were not at the 
3 A. Eating nachos. 
4 Q. At the 
5 A. Yes. 
6 Q. What did you do so that Justin would lie to 
7 the process servers for you? 
8 A. Nothing. 
9 Q. You just got him to lie for you, didn't 
10 you? 
11 A. No. I had no influence on him saying I 
12 wasn't there. 
13 Q. He took that upon himself? 
14 Isn't it true that Mr. Epstein's process 
15 servers had to ask the police to get you out of the 
16 restaurant so that they could serve you? 
17 MR. LEOPOLD: Objection. Lack of 
18 foundation, predicate. 
19 BY MR. TEIN: 
20 Q. You can answer the question. 
21 MR. LEOPOLD: If you know. Don't guess. 
22 THE WITNESS: No. Can you repeat the 
23 question? 
24 MR. TEIN: Don't coach. 
25 MR. LEOPOLD: Don't guess. 
64 
1 MR. TEIN: That's a coaching. 
2 MR. LEOPOLD: No. That's an instruction to 
3 the client. 
4 MR. TEIN: No. You don't do that. 
Page 54 
HOUSE OVERSIGHT 012449 
-0929104.TXT 
5 THE WITNESS: Can you repeat the question? 
6 MR. LEOPOLD: Let me just state for the 
7 record --
8 BY MR. TEIN: 
9 Q. Once the police -- isn't it true that 
10 Mr. Epstein's process serves had to ask the police to get 
11 you out of the restaurant so that they could serve you? 
12 A. Incorrect. My boss called the police. 
13 Q. And once the police showed up, to stop you 
14 from lying to avoid service, you made up another lie that 
15 the process servers had harassed you. Isn't that 
16 correct? 
17 A. Incorrect. 
18 Q. You lie all the time, don't you? 
19 MR. LEOPOLD: Objection. 
20 THE WITNESS: Incorrect. 
21 BY MR. TEIN: 
22 Q. You have a MySpace page, don't you? 
23 A. No longer do I have a MySpace page. I 
24 deleted it. 
25 Q. When did you delete your MySpace page? 
65 
1 A. A couple days ago. 
2 Q. Who told you to take your MySpace page down 
3 a couple of days ago? 
4 A. Nobody. I'm sick and tired of MySpace. 
5 Q. You all of a sudden got sick and tired of 
6 MySpace and just a few days before this deposition you 
7 decided to delete your MySpace page, correct? 
8 A. Correct. 
Page 55 
HOUSE OVERSIGHT 012450 
-0929104.TXT 
9 Q. Is that your testimony under oath? 
10 A. Yes. 
11 Q. Did you take your MySpace page down because 
12 you thought the government might subpoena it? 
13 A. Incorrect. 
14 Q. Hadn't your MySpace page been up for over 
15 three months before you took it down? 
16 A. Correct. But I also had made tons of 
17 MySpaces over the last years. I just get tired of them 
18 and delete them because drama and make new ones. 
19 Q. We're going to talk about that. 
20 So you deleted your MySpace page after you 
21 were already under subpoena for this deposition, correct? 
22 A. Correct. 
23 Q. What about the MySpace page didn't you want 
24 us to see,M 
25 A. Nothing. 
66 
1 Q. Well, we're going to come back to MySpace 
2 in a second. 
3 A. You do that. 
4 Q. I'm going to ask you some questions 
5 about why you lie about your age so often, okay? 
6 MR. LEOPOLD: Objection to the form. 
7 Argumentative. 
8 BY MR. TEIN: 
9 Q. You lie about your age all the time, don't 
10 you? 
11 MR. LEOPOLD: Objection, argumentative. 
12 THE WITNESS: Incorrect. 
13 BY MR. TEIN: 
Page 56 
HOUSE OVERSIGHT 012451 
-0929104.TXT 
14 Q. You lie about your age to get body 
15 piercings, don't you? 
16 A. Incorrect. 
17 Q. You have body piercings, don't you? 
18 A. Yes. 
19 Q. You have four body piercings; isn't that 
20 right? 
21 A. Five. 
22 Q. Other than the pierceings on your ears --
23 I'm not talking about that --
24 A. Oh, then no; just one. 
25 Q. And where is the one body piercing? 
67 
1 A. Belly. 
2 Q. When did you get that? 
3 A. For my birthday, with my stepmother and my 
4 father. 
5 Q. And when was that? 
6 A. When I was 14. 
7 Q. Okay. So you had that body piercing when 
8 you met Epstein, correct? 
9 A. It might have been, or maybe that -- yeah, 
10 either my 14th birthday or my 15th. I honestly don't 
11 remember. 
12 Q. Now you've lied about your age to get into 
13 bars by using driver's licenses that aren't yours, 
14 correct? 
15 A. Incorrect. 
16 Q. Are you swearing under oath that you've 
17 never done that? 
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HOUSE OVERSIGHT 012452 
-0929104.TXT 
18 A. Yes, I swear under oath. 
19 Q. And you've lied about your age to buy beer, 
20 correct? 
21 A. Incorrect. 
22 Q. You're swearing under oath that you've 
23 never lied to stores about your age? 
24 A. I've never lied to a store about my age or 
25 anything. 
68 
1 Q. 
2 don't you? 
3 
4 
5 
6 
7 Q. 
8 one. 
9 
10 
11 BY MR. TEIN: 
12 
13 
14 
15 
16 
17 
18 BY MR. TEIN: 
19 Q. 
20 
21 
22 
You try to look much older than you are, 
A. Incorrect. 
Q. And you've lied about your age on your 
MySpace pages, don't you? 
A. Incorrect. 
All right. Let's look at Exhibit 26-01 
MS. BELOHLAVEK: 26-001? 
MR. TEIN: Yes. 
n t You? 
0 I i ed- to everyone I, 4t400 
Q. Let's go to Exhibit 33. 
MS. BELOHLAVEK: That's 33-001? 
TEIN: Correct. 
On this page you lied to everyone that you 
were 19, didn't you? 
A. Incorrect. 
MR. LEOPOLD: Just answer the question. 
Page 58 
HOUSE OVERSIGHT 012453 
-0929104.TXT 
23 THE WITNESS: Oh, incorrect. 
24 BY MR. TEIN: 
25 Q. Now you can explain your answer. 
69 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 18? 
25 
A. I know that I have seen all of these and I 
know that this one is mine. 
Can you go down? 
MR. LEOPOLD: Just for the record, you're 
pointing to the photo. 
THE WITNESS: I'm pointing to --
BY MR. TEIN: 
1§0mgootholgig VOW 
gOalt ORTORM 
)W: ggEPRP 
Q. That's yours, right? 
A. Correct. That's mine from a couple years 
ago that I have not been on base I don't use that. 
Please keep going down, please. And I think that's it, 
because there's no one --just that one is mine. 
Q. 4.0C 
6COOMUTL-
Ot.00401V 
A. 
V.OttOldt. 
yours, correct? 
NOW. AY§i 
Q. And when you wrote 18 as your age on your 
MySpace page, that was a lie, wouldn't it? 
A. Correct. 
Q. Did you lie about your MySpace page back 
then because you couldn't post on MySpace unless you were 
A. Correct. There was a rule many years ago 
Page 59 
HOUSE OVERSIGHT 012454 
-0929104.TXT 
70 
1 that you had to be 18 to have a MySpace. 
2 Q. So you lied about your age so you could 
3 post on MySpace, right? 
4 A. Yes. 
5 Q. Let's go back to the top one on this page, 
6 33-01. 
7 
8 
Ilotim gth4g0t0t100 
AI tôtifJ flow mid 
-01:01W-0 
XY500g0g0A010110A 
4.40AUW$AYW' 
' " Ain'. • 
IbM0Y00:40iEhhOICK 
OMR: 
13 
14 
Lox abbreviation for 
it says 
POEMODY 'post 
':CbttOaCi 
Q. Now let's go back to the one that you were 
15 pointing to before on this page, where it says your age 
16 is 18 and you lied about your age to post MySpace, okay? 
17 A. Uh-huh, yes. 
18 
19 
20 
Q. All right. Why did you finally put your 
true age on your MySpace profile four days before you 
morems0400010M ,:-.AtIfYg15.0ZOW 
21 A. jAbn khOWOOWS0 taTROWoboorz, 
22 MR. LEOPOLD: If you don't understand, ask 
23 him to ask the question again. 
24 MR. TEIN: Don't coach. 
25 THE WITNESS: I don't know which MySpace 
71 
1 you're talking about. 
2 BY MR. TEIN: 
3 Q. The MySpace page that you're just pointing 
4 to, where it says you were 18. 
Page 60 
HOUSE OVERSIGHT 012455 
-0929104.TXT 
5 A. Yes. 
6 Q. AmtmtgAor 
7 
8 Q. 
9 
10 
11 
12 
13 
14 
15 
16 
17 to. 
18 
19 
20 
21 
22 
23 
24 
25 ever 
bouTY0arovunglItZ 
Why did you finally post your true age on 
your MySpace profile --
A. Uh --
Q. -- four days before you were scheduled to 
testify before the Grand Jury? 
A. I honestly don't know which MySpace, 
because I've had like a bazillion MySpaces and in that 
year, I had two, that one and another one and that one's 
been deleted. So I don't know which one you're referring 
NdfiNtbffidffibdtgthWyMailft—dw WW§d&dit 
Your MySpace Page 
"'• oorAtuoi 
1500. 
0040001 NVITAW 1W 040nloty?: 
A. No. 
Q. You don't remember that. 
A. No. 
Q. Do you remember Detective Recarey? Did you 
meet a Detective Recarey? 
72 
1 A. I don't know the names. 
2 Q. How many different detectives have you met 
3 with on this case from Palm Beach? 
4 A. Probably a good six or seven, maybe. 
5 Q. Did one of the detectives tell you before 
6 you testified in the Grand Jury that you should take your 
7 MySpace age and put your true age? 
8 A. No. 
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9 Q. Didn't Detective Recarey have to come to 
10 your house to pick you up to get you to testify in front 
11 of the Grand Jury? 
12 A. Possibly, maybe because I didn't have a 
13 ride. I was only 14 or 15 at the time. 
14 Q. Your mom didn't drive you? 
15 A. No. 
16 Q. Stepmom didn't drive you? 
17 A. I think my dad. Oh, my dad / my dad drove 
18 me. 
19 Q. Your dad drove you? 
20 A. Yes, sir. 
21 Q. So your testimony is Detective Recarey did 
22 not drive you, correct? 
23 MR. LEOPOLD: Objection /asked and 
24 answered. 
25 THE WITNESS: No. I'm pretty sure my dad 
73 
1 drove me because he was there with me. 
2 BY MR. TE1N: 
3 Q. Did any detective tell you to change your 
4 age on your MySpace page to put your true age? 
5 
6 
7 
8 
9 
12 
13 
A. No, sir. 
Q. Now you also lied on your MySpace page 
about your income, didn't you? 
A. Yes. 
And..yoti lied, sayir that104410000 
APOtt0t0034 -m0104M 
Q. 
A. Yes. 
That was a lie, wasn't it? 
Page 62 
HOUSE OVERSIGHT 012457 
-0929104.TXT 
14 
15 
16 
youa:lo Hod on your MSpace page 
impopv ..Vitor&MOVVIAd dfdtgt4b0Z 
17 Ottta: 
18 
19 
20 
21 tape-recorded statement that you gave to Detective 
22 Michelle Pagan three years ago, didn't you? 
23 A. To my knowledge, no, I did not. 
24 Q. Well, you lied to the police when you 
25 accused Mr. Epstein of attempting to murder your father, 
And thatmight hve1eenag 
Q. 
A. 
Q. 
Now you also lie to the police, don't you? 
No. 
Well, you lied to the police in your 
74 
1 didn't you? 
2 A. No. I never heard a statement saying that 
3 Mr. Epstein tried to murder my father. 
4 Q. You made that statement, didn't you? 
5 MR. LEOPOLD: Do you have a statement to 
6 show her? That's been asked and answered. 
7 MR. TEIN: I'm sorry. I didn't hear the 
8 witness' answer, Mr. Leopold. 
9 BY MR. TEIN: 
10 Q. you told the police, didn't you, 
11 that Mr. Epstein almost killed your father, didn't you? 
12 A. No. 
13 Q. Three years ago, before Mr. Epstein even 
14 knew about this investigation, you told the police that 
15 Epstein had "already come to my dad's house and did 
16 something to my dad's tires and my dad almost died. 1 
17 didn't want my dad to get hurt, because Jeff already 
Page 63 
HOUSE OVERSIGHT 012458 
-0929104.TXT 
18 almost killed him." 
19 Didn't you say that? 
20 A. Not to my knowledge or recollection. I 
21 have never said anything like that. 
22 4tg 144WWWWWWDOOONCOMMOW . 
23 Joo t vo.moie 
24 A. Yeah. 
25 Q. Because Mr. Epstein never came to your 
75 
1 dad's house, correct? 
2 A. Correct. 
3 Q. And no one who worked for Mr. Epstein ever 
4 did something to your dad's tires. Did they? 
5 MR. LEOPOLD: Objection. Lack of 
6 foundation, predicate. 
7 Don't guess. 
8 BY MR. TEIN: 
9 Q. Its not true that Mr. Epstein almost 
10 killed your father, is it? 
11 MR. LEOPOLD: Objection. Asked and 
12 answered, lack of foundation, predicate. 
13 BY MR. TEIN: 
14 Q. You can answer. 
15 A. No. 
16 Q. Now you told the police that you didn't 
17 know who was in the car with you and Hayley on the day 
18 you went to Epstein's house, didn't you? 
19 A. Yes. 
20 Q. And that was a lie, wasn't it? 
21 A. It's the truth. 
22 Q. You told the police that there was someone 
Page 64 
HOUSE OVERSIGHT 012459 
-0929104.TXT 
23 in the car next to you and you specifically said you 
24 didn't know her name, right? 
25 A. Correct. I do not know her name. 
76 
Q. You said, "I don't know her name, but she 
2 was dark like a Spanish girl." Those were your words, 
3 right? 
4 A. Yes. 
5 MR. LEOPOLD: Objection. Asked and 
6 answered. 
7 BY MR. TEIN: 
8 Q. Who was in the car that day with you and 
9 
10 A. Again, I do not know. 
11 Q. It was your good friend 
12 wasn't it? 
13 A. No. I don't know a 
14 Q. You lied to the police about who was in the 
15 car with you and , didn't you? 
16 A. Incorrect. 
17 Q. Let me ask you some questions about who you 
18 may have spoken to about this case. All right? 
19 A. Go ahead. 
20 Q. Did you speak to your sister.= 
21 A. Not in detail, but of course she knows; 
22 she's family and yes. 
23 Q. What's her e-mail? 
24 A. I don't think she has an e-mail. 
25 Q. What is her phone number? 
Page 65 
HOUSE OVERSIGHT 012460 
-0929104.TXT 
77 
1 A. Oh, gosh. I don't know off the top of my 
2 head. 
3 Q. And what is her home address? 
4 A. She lives with my mom. 
5 Q. In Georgia? 
6 A. Yes, sir. 
7 Q. What about 's boy friend Paul? Did 
8 you speak to him about Epstein's case? 
9 A. That's my mom's boy friend. My sister 
10 doesn't have a boy friend. My mom's husband's name is 
11 Paul, so maybe you get them confused. 
12 Q. Do you know his phone number? 
13 A. No. 
14 Q. Where does he live? 
15 A. With my mom. 
16 Q. In the same house with her? 
17 A. Yes. They're married. 
18 Q. So not boy friend; husband? 
19 A. Yeah, husband. 
20 Q. Have you spoken to Brett about 
21 what happened in Mr. Epstein's house? 
22 A. Not in detail, but he knows the basics, 
23 yes. 
24 Q. What is his e-mail? 
25 A. I don't know. 
78 
1 
2 
3 
4 
Q. What is his phone number? 
A. How is that relevant? 
Q. What is his phone number? 
A. 
Page 66 
HOUSE OVERSIGHT 012461 
-0929104.TXT 
5 Q. What is his home address? 
6 A. I don't know. 
7 Q. Where does he live? 
8 A. In somewhere. 
9 Q. Ever been to his house? 
10 A. Yes. 
11 Q. You don't know what his address is? 
12 MR. LEOPOLD: Objection. Asked and 
13 answered. She just said she doesn't know. 
14 MR. TEIN: Don't coach. 
15 MR. LEOPOLD: Objection. Asked and 
16 answered. 
17 BY MR. TEIN: 
18 Q. You can answer the question. 
19 A. I don't know the exact address. 
20 Q. What street is it on? 
21 A. It's an apartment complex; its not a 
22 street. 
23 Q. What's the name of the apartment complex? 
24 A. 
25 Q. What apartment number is it? 
79 
1 A. I couldn't tell you. 
2 Q. When was the last time you went there? 
3 A. Just visited this past weekend. That's the 
4 first and last time I went there. 
5 Q. How about Steven M? Have you spoken 
6 to him about your case? 
7 A. No. We no longer speak. 
8 Q. What's his phone number? Actually, we 
Page 67 
HOUSE OVERSIGHT 012462 
-0929104.TXT 
9 10 11 	already have his phone number room and e-mail. 	you ever 
How about Have 
spoken to her about your case? 
12 	A. I don't know an 
13 	Q. Have you ever met 
14 	A. No. But just to I et you know, I don' t 
15 	really know names. If you have pictures, of there faces 
16 	I could tell you. 
17 18 	Q. All right. Let me see if I can refresh your memory. 
19 	A. Okay. 
20 	Q. Does it refresh your memory that 
21 	is the other girl who made allegations about Epstein, but 
22 23 	refused to show to the Grand Jury when she had to testify about them under oath? 
24 	A. No, sir. I have no knowledge of any other 
25 	girls in this whole situation. We're not allowed to know 
1 	80 each other. 
2 	Q. I91I4figtA0Wutoa20 four..............................words, 
3 	A. mommbM4413bWOMt061010WOOW moom 
4 5 	Q. And what about ? Have you of met her? 
6 	A. No, sir. 
7 	Q. Let's see if I can refresh your memory on 
8 	her. She's the other person represented by your lawyer 
9 10 	Mr. Herman, who is suing Epstein for fifty million dollars. 
11 	A. I have no knowledge of her. 
12 	Q. Never met her? 
13 	A. Never met her. 
Page 68 
HOUSE OVERSIGHT 012463 
were [eased on the Internet containing You 
. . . .. .. .. . . .. 
-0929104.TXT 
14 Q. MI11111111111 
15 A. I don't know who that is either. 
16 Q. A person named Anthony who knows 
17 Is that Tony 
18 A. I don't know, sir. 
19 Q. Do you remember making a statement to 
20 Detective Pagan that's in the police reports? 
21 A. No. 
22 Q. Have you read the police reports in this 
23 case? 
24 A. Yes. 
25 Q. They're on the Internet, right? 
81 
1 A. Yes, I think. 
2 Q moroyarsomelo Rohouthomaii0ogre015.t0i 
3 
4 MbAt ACAORM 
5 ...... Y.d  
6 Q. You didn't want to see that happen, right? 
7 A. No. 
8 Q. So you're saying you don't know a Tony 
9 IIIIIIIIIk 
10 MR. LEOPOLD: Objection. Asked and 
11 answered. 
12 BY MR. TEIN: 
13 Q. Does it refresh your memory that he was 
14 somebody who had gone to jail for drugs and car theft? 
15 A. No, sir 
16 Q. Someone who knowsIIIIIII 
17 A. No. 
Page 69 
r statements 
HOUSE OVERSIGHT 012464 
-0929104.TXT 
18 Q. You don't know if he met with Detective 
19 Recarey? 
20 A. No, sir. 
21 Q. How about Zack=? 
22 A. Yes, I remember. I know who that is. 
23 Q. Did you ever speak to Zack about what 
24 happened at Mr. Epstein's house? 
25 A. He knows what happened four years ago. He 
82 
1 doesn't know this is still going on today. 
2 Q. What's his address? I'm sorry. I have his 
3 address. 
4 A. I don't know. 
5 Q. How about Nick 
6 A. 
7 Q. You know who that is? 
8 A. I know who that is, yes. 
9 Q. He's the one you stayed out drinking all 
10 night one night last year when your dad reported you 
11 missing? 
12 A. No, sir. 
13 Q. Remember the baseball game you were 
14 supposed to go to? 
15 A. No, sir. 
16 Q. Did you speak to Nick about this 
17 case? 
18 A. No, sir. 
19 Q. How about Patrick 
20 A. That's my sister's ex-boy friend. 
21 Q. He's the one with the sawed-off shotgun 
22 with the obliterated serial number? 
Page 70 
HOUSE OVERSIGHT 012465 
-0929104.TXT 
23 A. Ask him. I would not know that 
24 information. 
25 Q. Did you speak to Patrick about this 
83 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
case? 
A. No, sir. 
Q. Have you spoken to John about this 
case? 
A. No. I don't know who John is. 
Q. Did your parents speak to John? 
A. Ask my parents. 
Q. Let's see if I can refresh your memory as 
to who he is. Okay? 
A. Uh-huh. 
MOAWm;  \iarity Fr reporter OWItigd60: 
txParmi0jagetWOOMOM. ..... OtENOW 
iiir.10)0§Orki;i0FiVIIMAR *.g!tiOt 
ails a 0 
ke that they 
what ou know 
MilOWKWWW110 
100 
000ttfliki 
OPPAllgOMOO.Vt[44: 
iii Conr 
porter 
father 
don't know out thedi 
Q. 
your father? 
A. I don't even know he gave money to my dad. 
Q. I'm sorry? 
A. I didn't even know he gave money to my dad. 
ail 
How much money did John Connolly give to 
Page 71 
HOUSE OVERSIGHT 012466 
-0929104.TXT 
84 
1 Q. What do you know about the deal that John 
2 Connolly has with your father? 
3 A. I only know they spoke on the telephone 
4 once. I don't know anything else. 
5 Q. When was that? 
6 A. This was a while ago, a year or two or a 
7 year ago. I honestly don't know. 
8 Q. Did John Connolly the Vanity Fair reporter 
9 offer any money to your father? 
10 A. I don't know. 
11 Q. Did John Connolly, the Vanity Fair 
12 reporter, give you any money? 
13 A. No, sir. 
14 Q. Did he offer you any money? 
15 A. No, sir. Never spoke to him. 
16 Q. What reporters have you spoken to? 
17 A. Zero. 
18 Q. What about your family members? What 
19 reporters have they spoken to? 
20 A. The whole Palm Beach County, obviously, as 
21 you can see in that newspaper. 
22 Q. Tell me -- let's go through each one that 
23 you remember. Other than the Vanity Fair reporter, John 
24 Connolly, what other reporters have any member of your 
25 family spoken to? 
85 
1 A. I don't know. And I know my mom has spoken 
2 to zero. My sister spoke to zero. My father and 
3 stepmother, I wouldn't know. You'd have to ask them. 
4 don't contact them. 
Page 72 
HOUSE OVERSIGHT 012467 
-0929104.TXT 
5 Q. Well, I just want to know -- I don't want 
6 you to -- I want to know what's in your mind? All right? 
7 MR. LEOPOLD: She just told you. She just 
8 answered --
9 MR. TEIN: Be quiet. 
10 BY MR. TEIN: 
11 Q. What I want to know is what you know from 
12 your personal knowledge. My opinion question to you is: 
13 What knowledge do you have about family members of yours 
14 speaking to reporters? 
15 MR. LEOPOLD: Objection. Asked and 
16 answered. 
17 And if you can't talk professionally, we're 
18 going to leave. 
19 MR. TEIN: Do what you want to do. 
20 MR. LEOPOLD: Are you going to continue to 
21 talk this way? 
22 MR. TEIN: I'm not going to answer any 
23 question that you ask me, Mr. Leopold. 
24 MR. LEOPOLD: Okay. 
25 MR. TEIN: But you are misrepresenting the 
86 
1 record and you are grandstanding for your client 
2 and it's wrong. So be quiet. And you know how to 
3 make an objection. Make it. Otherwise stop 
4 talking. 
5 BY MR. TEIN: 
6 Q. Saige --
7 MR. LEOPOLD: Excuse me. 
8 MR TEIN: If you want to leave the 
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-0929104.TXT 
9 deposition, leave. But you'll be back here. 
10 MR. LEOPOLD: Excuse me. If I could just 
11 make the record, instead of interrupting me, 
12 please, that's what we do professionally. There's 
13 a recorder here. I'm certainly not being 
14 obstructionist. I'm going to make the record. 
15 But were going to act with some semblance of 
16 professionalism, hopefully, by all parties in the 
17 room. That goes to me, that goes to your 
18 co-counsel sitting behind you and next to you, the 
19 court reporter and everyone else in the room. 
20 Everyone goes entitled to that. 
21 You've asked a question. She answered the 
22 question fully and she's not going to be harassed 
23 because you don't like the answer. If you want to 
24 follow up --
25 MR. TEIN: Stop engaging me. Make your 
87 
1 speech and then we'll ask the questions. 
2 MR. LEOPOLD: Well, you won't let me finish 
3 making the objection, so it's difficult to do 
4 that. But if you want to follow with an 
5 appropriate question, feel free to do that. But 
6 we're not going to harass the witness. 
7 MR. TEIN: I disagree with everything 
8 you've said. Let's ask the questions. Okay? 
9 MR. LEOPOLD: Ask an appropriate question 
10 MR. TEIN: Are you going to stop talking? 
11 MR. LEOPOLD: I'm going to make -- protect 
12 my client and make appropriate objection, but 
13 there's not a question pending right now. 
Page 74 
HOUSE OVERSIGHT 012469 
-0929104.TXT 
14 BY MR. TEIN: 
15 Q. has spoken to any reporters? 
16 A. No. 
17 MR. LEOPOLD: Objection. Asked and 
18 answered. 
19 BY MR. TEIN: 
20 Q. Has been given money by any 
21 reporters? 
22 A. No. 
23 Q. Has your mom spoken to any reporters? 
24 MR. LEOPOLD: Objection. Asked and 
25 answered. 
88 
1 THE WITNESS: No. 
2 BY MR. TEIN: 
3 Q. Has your mom's husband Paul spoken to any 
4 reporters? 
5 A. No. 
6 Q. Has your mom's husband Paul received any 
7 money from reporters? 
8 A. No. 
9 Q. Are you sure you don't know 
10 MR. LEOPOLD: Objection. Asked and 
11 answered. 
12 THE WITNESS: I'm positive. 
13 BY MR. TEIN: 
14 Q. I'll try again to refresh your memory. 
15 A. Okay. 
16 Q. Does it refresh your memory that she had 
17 been arrested for drugs and was cooperating with 
Page 75 
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-0929104.TXT 
18 Detective Recarey against Epstein to get herself a better 
19 deal? 
20 A. No. I don't know who she is. 
21 Q. Have you spoken to anyone else who's been 
22 at Epstein's house? 
23 A. No. 
24 Q. Without telling me what was said -- I don't 
25 want to know about any conversations with any lawyers, 
89 
1 okay --
2 A. Uh-huh. 
3 Q. -- did you or your parents speak to any 
4 other law firms besides Mr. Herman and Mr. Leopold's law 
5 firms? 
6 A. No. 
7 Q. Now without telling me about anything that 
8 was said, what -- did one just come to mind? 
9 A. No. I was thinking about something else. 
10 Q. What were you thinking about? 
11 A. Does family court matter? 
12 Q. Okay. Without telling me what was said, 
13 who prepared you for todays deposition? 
14 A. What do you mean prepared? 
15 Q. Did you talk about this deposition, about 
16 what would happen, with anybody? 
17 A. Yes. 
18 Q. Don't tell me what was said? 
19 A. Okay. 
20 Q. I'm not asking that. I don't want to know 
21 that. 
22 A. Okay. 
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-0929104.TXT 
23 24 25 1 2 	Q. A. Q. A. Q. 	Who prepared you for today's deposition? Mr. Leopold. Anybody else? 90 No. When did you meet with Mr. Leopold to 
3 	prepare for today's deposition? 
4 	A. 	This morning. 
5 	Q. 	And how long did that meeting last? 
6 	A. 	Until it started. 
7 	Q. 	Now you told me that you previously had 
8 	read the police reports in this case? 
9 	A. 	Yes. 
10 	Q. 	Have you read your statement that you gave 
11 	to the police? 
12 	A. 	Yes, sir. 
13 	Q. 	And in what form was that statement? 
14 	A. 	What do you mean? 
15 	Q. 	Was it in the form of a police report or a 
16 	transcript? 
17 	A. 	What's the difference? 
18 	Q. 	A transcript has questions and answers on 
19 	it. A police report is just typed out narrative. 
20 	A. 	Oh, its a police report. 
21 	Q. 	And when did you read the police report? 
22 	A. 	A few days ago. I overread it a few days 
23 	ago. 
24 	Q. 	Had you read it before that? 
25 	A. 	No. 
Page 77 
HOUSE OVERSIGHT 012472 
-0929104.TXT 
91 
1 Q. Now you told me -- again, I don't want to 
2 know what was said. 
3 A. Uh-huh. 
4 Q. You told me that you met with Mr. Leopold 
5 this morning to prepare for your deposition, right? 
6 A. Yes. 
7 Q. When did you set up that meeting with 
8 Mr. Leopold to take place this morning? 
9 A. Gee, like, like five days ago, four days 
10 ago. 
11 Q. So you're aware that Mr. Leopold told us 
12 that he could not start the deposition this morning 
13 because he had a court appearance, correct? 
14 MR. LEOPOLD: Don't answer that question. 
15 Calls for attorney/client communications. 
16 BY MR. TEIN: 
17 Q. Have you seen the letter that Mr. Leopold 
18 wrote to us stating that he -- an e-mail that Mr. Leopold 
19 wrote to Mr. Goldberger stating that he could not be here 
20 this morning because healed a court appearance? Did you 
21 see that e-mail? 
22 MR. LEOPOLD: You can answer that question. 
23 THE WITNESS: No. 
24 BY MR. TEIN: 
25 Q. Have you listened to your tape-recorded 
92 
1 statement to the police? 
2 A. Yes. 
3 Q. Where did you listen to that? 
4 A. In, I think, this building. I don't know. 
Page 78 
HOUSE OVERSIGHT 012473 
-0929104.TXT 
5 It was here. 
6 Q. When did you listen to that statement? 
7 A. This morning. 
8 Q. And who was present when you listened to 
9 that statement? 
10 A. Mr. Leopold -- and I forget your name. 
11 MR. GOLDBERGER: Ms. Belohlavek. 
12 THE WITNESS: Ms. Belohlavek. 
13 BY MR. TEIN: 
14 Q. And you hadn't listened to your statement 
15 before that, correct? 
16 A. No, sir. 
17 Q. Have you met with lawyers representing 
18 anyone else suing Epstein? 
19 
20 
21 
22 
23 tW*404_ft_fddt4dAMVWALTAit —taTtidtH 
A. No, sir. 
Q. How -many times have you tOgOttIOOPO 
'he Palm Beach 
partment? 
More 
KH„,,,ztafhtM 
A. 
24 Q. When was the last time you spoke with 
25 officers of the Palm Beach Police Department? 
1 A. A while ago. I'd say a year ago. 
2 Q. A year ago? 
3 A. Yeah. Maybe a year and a half. 
4 Q. Do you remember Detective Recarey? 
5 A. No. 
6 Q. Do you remember Michelle Pagan, Detective 
7 Pagan? 
8 A. Yes. 
Page 79 
93 
HOUSE OVERSIGHT 012474 
Appgmorammolgprommomono :9PORaft -'TtlatZ 
-0929104.TXT 
9 Q. How many times have you spoken to Detective 
10 Pagan? 
11 A. She was the only one I spoke to about this 
12 until for some reason she wasn't on the case anymore. 
13 
Q. When was that? 
14 A. The first meeting I ever had was with her 
15 and then I think like I met with her mgolp opow 0.2tz 
16 MMO% d$OMOttar CO4t0OW 000, XOWTEV 
17 
18 Q. And who was that? 
19 A. I don't remember. 
20 Q. And what type of questions did they ask 
21 you? 
22 A. The same. 
23 Q. The same questions all over again? 
24 A. Basically. 
25 Q. How many taped statements have you given to 
94 
1 the police? 
2 A. One that I know of. 
3 Q. Just the one with Detective Pagan? 
4 A. Yes, sir. 
5 Q. How about to the FBI? Did you give any 
6 statements to them? 
7 A. No. Well, actually. I don't really 
8 remember if that was taped or not to be honest with you. 
9 I had one meeting with them at my house and don't know if 
10 it was taped. 
11 Q. You were interviewed at 
12 house? 
13 A. No. That was by the lawyer. 
Page 80 
HOUSE OVERSIGHT 012475 
-0929104.TXT 
14 Q. Oh, boy the lawyer? 
15 A. Uh-huh. 
16 Q. Where did the conversation that you had 
17 with the FBI take place? 
18 A. At my father's residence. 
19 Q. Which is where? 
20 A. On Downers in Loxahatchee. 
21 Q. On where? 
22 A. Downers Road in Loxahatchee. 
23 Q. And when did that take place? 
24 A. I'd have to say like a year and a half ago, 
25 a year ago. It was a long time ago. 
95 
1 (Discussion held off the record.) 
2 MR. TEIN: Tell me the last answer, please. 
3 (Thereupon, a portion of the record was read 
4 by the reporter.) 
5 BY MR. TEIN: 
6 Q. And who was present when the FBI spoke to 
7 you at your father's house? 
8 A. My stepmother was there, but she wasn't 
9 around. She made herself like do other things. 
10 Q. And how many FBI agents were there? 
11 A. I think four. 
12 Q. And you don't remember any of their names? 
13 A. No, sir. 
14 Q. And were there any lawyers there? 
15 A. Not that I know of. 
16 Q. And none of them gave you their cell phone 
17 numbers? 
Page 81 
HOUSE OVERSIGHT 012476 
-0929104.TXT 
18 
19 
20 
21 
22 
23 
24 
25 
A. No. 
0. Anomigmou 
90.40 
ONOW1408A 
go? 
A. It was a while ago. 
MR. LEOPOLD: Objection. Asked and 
answered. 
BY MR. TEIN: 
Q. And the last time you spoke to the federal 
96 
1 prosecutor's office was when? 
2 A. I don't know. 
3 Q. Did any of the FBI agents tell you that 
4 Marie Villafona had spoken with Mr. Leopold? 
5 A. No. 
6 Q. Did any of the FBI agents tell you that 
7 Marie Villafona had spoken with Mr. Herman? 
8 A. No. 
9 Q. Did any FBI agents tell you that Jeff 
10 Sloman spoke with Mr. Herman. 
11 A. No. 
12 Q. Did any FBI agents tell you that Jeff 
13 Sloman spoke with Mr. Leopold? 
14 A. No. 
15 Q. Do you know whether any of the federal 
16 prosecutors allowed Mr. Herman to review a draft 
17 indictment? 
18 A. I wouldn't know. 
19 Q. Do you know if any of the federal 
20 prosecutors discussed a draft indictment with Mr. Herman? 
21 A. I wouldn't know. 
22 Q. Have you ever e-mailed with any FBI agent 
Page 82 
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-0929104.TXT 
23 or any federal prosecutor? 
24 A. No. 
25 Q. Have you ever text messaged with any FBI 
97 
1 agent or any federal prosecutor? 
2 A. No 
3 Q. Has the FBI told you about other testimony? 
4 A. No. 
5 Q. Has the FBI told you about what other girls 
6 have said? 
7 A. No. 
8 Q. Have federal prosecutors told you what 
9 other girls have said? 
10 A. No. 
11 Q. Do you have any way of getting in touch 
12 with the FBI if you wanted to get in touch with them? 
13 A. No. 
14 Q. How about your parents? Do they know how 
15 to get in touch with the FBI? 
16 A. I don't know. 
17 Q. And by your parents, I'm referring to both 
18 sets, okay? 
19 A. Oh. Well, I'm referring to only my dad, 
20 because my mom really doesn't care to know any of this 
21 stuff. 
22 Q. So the answer would be the same for your 
23 mom and Paul? 
24 A. Yeah. - 
25 Q. Have you spoken to a lawyer named Burt 
Page 83 
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-0929104.TXT 
98 
1 Ocariz about this case? 
2 A. No. 
3 Q. Do you know who Burt Ocariz is? 
4 Let's see if I can refresh your memory. 
5 Does it refresh your memory that he's a good friend of 
6 Marie Villafona's boyfriend? 
7 A. I don't know who Mari Villafona is. 
8 Q. Marie Villafona is the lead federal 
9 prosecutor that's on the federal part of this case. 
10 Okay? 
11 A. No. 
12 Q. So does it refresh your memory that Ocariz 
13 is the good friend of Marie Villafona's boy friend? 
14 A. Not at all. 
15 Q. Does it refresh your memory that Villafona 
16 tried to get Epstein to pay for Ocariz to represent you 
17 in the federal case? 
18 A. No. 
19 Q. Do you know if Detective Recarey has spoken 
20 with your father? 
21 A. No. 
22 Q. Do you know if Detective Recarey has spoken 
23 to your stepmother? 
24 A. No. 
25 Q. How about with amber? 
99 
1 A. Yes, I would know, and no, she did not. 
2 Q. Let's put up -- let me ask you some 
3 questions about the photo that you had posted on your 
4 MySpace page before you erased it last week. Okay? 
Page 84 
HOUSE OVERSIGHT 012479 
-0929104.TXT 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 BY MR. TEIN: 
17 
18 
19 
20 
21 
22 
23 
24 
25 
1 
2 
3 
A. Okay. 
MR. TEIN: Do you mind if we close the door 
a second, please. 
MR. LEOPOLD: Exhibit number, please. 
MR. TEIN: Put up 25-005. 
Hold on a second. 
MR. LEOPOLD: Don't say anything. She was 
talking to her counsel. 
MR. TEIN: Put up 25-006. 
MR. LEOPOLD: Is that 005 right there? 
MR. TEIN: Yes. 
toOkl 
photo 
ou h a warehouse 
y.,!:;;;ogtoitfa. 
MR. LEOPOLD: Objection. Mischaracterizes 
the photograph, and lack of foundation and 
predicate. 
Fully explain if you need to. 
THE WITNESS: I will. 
First of all. Oft 2004A1W0P000$0.Z 
t6V6W IglgOP4W: 
Second of all, I'm not being gang-raped. 
Everyone has their clothing on. 
Thirdly, if you look at all the other 
100 
4 pictures in this album, I'm drinking -- what's 
5 when you're sick you drink it? 
6 BY MR. TEIN: 
7 Q. You can't ask questions of your counsel. 
8 A. All right. I'm drinking like Sprite. I'm 
Page 85 
HOUSE OVERSIGHT 012480 
-0929104.TXT 
9 note drinking any kind of alcohol, if you would look at 
10 my other pictures in that album. You guys picked the 
11 possibly worst pictures out of there to present. And it 
12 was just a goofy picture. All of these kids like to be 
13 goofy. And that's what we were doing. 
14 Q. Who's the man on the left of the picture 
15 holding his -- holding a beer bottle as if it were a 
16 penis towards your mouth? 
17 A. Steven 
18 Q. Who's the man behind you, right up towards 
19 your backs side, with you bent over? 
20 A. That one? 
21 Q. The right side, kissing with his mouth. 
22 A. That's Nick 
23 Q. He's the one grabbing towards the groin 
24 area of Steven 
25 A. Yes. 
101 
1 Q. And there's three other men in the photo. 
2 What are their names? The one on the left with the hat? 
3 A. That's Robbie (phonetic). 
4 Q. Smiling? 
5 A. Yes. 
6 Q. Who's the one kissing --
7 MR. LEOPOLD: Don't interrupt. Let her 
8 finish the record. She's testifying. 
9 MR. TEIN: I know you don't like this 
10 picture, my friend. 
11 MR. LEOPOLD: The picture is fine. 
12 BY MR. TEIN: 
13 Q. Who's the one with the hat? 
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14 MR. LEOPOLD: No. Hold on. Stop, 
15 You have to let the witness finish her 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 BY MR. TEIN: 
1 Q. He's the one whose head is near the groin 
2 of Steven , right? 
3 A. Yes. 
4 Q. And in the middle there's a man smiling. 
5 Who's that? 
6 A. That's Robbie 
7 Q. Who's the one in the red hat, kissing? 
8 A. Most Brandon (phonetic). 
9 Q. Let me stop you for a second. Are you 
10 done? 
11 A. Yes, I'm done. 
12 Q. Who is 
13 A. My sister's friend. Well, she's a mutual 
14 friend, but more my sister's. 
15 Q. What is her last name? 
16 A. 
17 Q. Spell that. 
Page 87 
answer. She was in the process of explaining and 
you cut her off. 
Please finish what you were saying and then 
Counsel can ask you whatever he wishes after that. 
THE WITNESS: Okay. This guy --
MR. LEOPOLD: Just make it so the record is 
clear who you're referring to. 
THE WITNESS: -- on the far left is John 
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18 A. I don't know how to --
19 Q. Have you spoken to her about this case? 
20 A. No. 
21 Q. Who's Vince? 
22 A. My sister's friend. I don't really speak 
23 to him at all. 
24 Q. What's his last name? 
25 A. 
103 
1 Q. 
2 A. 
3 
4 case? 
5 
6 
Q. And have you spoken to Vince about this 
A. No, sir. 
Q. Have you spoken to about this case? 
7 A. Not in detail, but yes. 
8 MS. BELOHLAVEK: Are we referring to 
9 
10 THE WITNESS: Yes. 
11 MR. TEIN: Yes. 
12 MS. BELOHLAVEK: Okay. 
13 BY MR. TEIN: 
14 Q. Have you spoken to Justin about this case? 
15 A. Justin? 
16 Q. Do you have a friend named Justin? 
17 A. I do not have a friend named Justin. 
18 Q. From freshman year? 
19 A. No. 
20 Q. How about In 
21 A. No. 
22 Q. Have you spoken to 1111 about this case? 
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23 24 25 	A. Q. A. 	No. What's her last name? . I don't know how to spell it? 
104 
1 	Q. 	Is she the person whose house you went to 
2 	on New Year's this year? 
3 	A. 	No. I wasn't at her house on New Year's. 
4 	Q. 	Where were you when you took the picture of 
5 	Can you say blazed? That on your website? 
6 	A. 	I wouldn't know or -- wait. We were at a 
7 	birthday party for some girl's 16th birthday. 
8 	Q. 	Were you drinking at that party? 
9 	A. 	No. There was no alcohol or anything 
10 	there. 
11 	Q. 	What does "blaze" mean to you? 
12 	A. 	It's like -- it just means like messed up. 
13 	But we weren't, if you look at the picture. 
14 	Q. 	Messed up like drunk, right? 
15 	A. 	Sure. 
16 	Q. 	Who's 
17 	A. 	A girl I know like from like two years ago. 
18 	Q. 	She's the one you were supposed to be 
19 	staying with when you went drinking with Nick 
20 	A. 	No. 
21 	Q. 	What's 's last name? 
22 	A. 
23 	Q. 	Where does she live? 
24 	A. 	I don't know. In Royal Palm. 
25 	Q. 
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105 
1 A. Uh-huh. I'm guessing. 
2 Q. Do you know her phone number? 
3 A. No, I do not. 
4 Q. Let's look at 25-010. 
5 A. See, tin drinking --
6 Q. I'm not asking you about what you're 
7 drinking. 
8 Who are the men in this photo who are 
9 pretending to gang up on you and stab you with knives? 
10 Who are they? 
11 A. Nick and Brandon (phonetic). 
12 Q. Are they firemen? 
13 A. Are those? Steven -- he said the 
14 two stabbing with knives. That's why I said that. 1 
15 don't know. That's Steven and John 
16 Q. Are these firemen? 
17 A. No. They're all on -- except Steven, 
18 they're all on full rights for football. 
19 Q. Go to 025-015? 
20 MR. LEOPOLD: 025- dash? 
21 MR. TEIN: 015. 
22 THE WITNESS: Gosh, that's so long ago. 
23 BY MR. TEIN: 
24 Q. Who took the photo have you licking the 
25 penis? 
106 
1 A. My stepmother. 
2 Q. Whose idea -- that was your stepmother's 
3 idea? 
4 A. It was in Buca di Beppo, where she works 
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5 currently and that was before she worked there, and we 
6 just thought it would be funny. 
7 MR. TEIN: 19-007. Can you enlarge that? 
8 BY MR. TEIN: 
9 Q. Who took this photo of you simulating you 
10 having sex with a man? 
11 A. We're not simulating having sex, and 
12 it's -- oh, and the person who took it was, I'm pretty 
13 sure, Chris, but I know him as don't know his 
14 last name. 
15 Q. Go to 19-006, please. 
16 Who took this photo of you simulating sex 
17 with a man? 
18 A. The same person. And we're not simulating 
19 having sex, Mr. --
20 Q. Tein. 
21 Did you post that on the Internet? 
22 A. Actually, this is an old MySpace I never 
23 finished and I never like did anything. I just kind of 
24 made it and left it. 
25 Q. So the answer is yes, you posted this on 
107 
1 MySpace? 
2 A. Yup. 
3 Q. Go to 25-016. Who took this photo of you 
4 simulating sex with a woman? 
5 MR. LEOPOLD: Object to the form of the 
6 question. Argumentative. 
7 THE WITNESS: First off, she's piercing my 
8 belly button or repiercing it, and I'm pretty sure 
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9 it was just like we put up a camera somewhere and 
10 put a timer on it. We didn't have anybody take 
11 it. 
12 BY MR. TEIN: 
13 Q. You posted that on your MySpace page? 
14 A. Yeah. 
15 Q. Go to 25-013. Is that a photo of you? 
16 A. Yep. 
17 Q. Who's in the photo with you? 
18 A. Steven. 
19 Q. Steven =? 
20 A. Yep. 
21 Q. Is this you coming out of the shower? 
22 A. Yes. 
23 Q. Are you clothed in this picture?