24 A. Yeah. I have a halter dress on. 
25 Q. Where is that picture taken? 
108 
1 A. In Steven's house. 
2 Q. Did you post that on the Internet? 
3 A. Yes. 
4 Q. All right. 
5 MR. TEIN: You can take that down. 
6 BY MR. TEIN: 
7 Q. Now your boy friend is Brett 
8 correct? 
9 A. Yeah. 
10 Q. You lie about your age in order to conceal 
11 something about your relationship with Brett 
12 isn't that correct? 
13 A. No. 
Page 92 
HOUSE OVERSIGHT 012487 
-0929104.TXT 
14 Q. Brett's 22 years old, isn't he? 
15 A. Yes. 
16 Q. And Brett is a firefighter with the Palm 
17 Beach Fire Department, right? 
18 A. Yup. 
19 Q. Does the Palm Beach Fire Department know 
20 that your boy friend is dating an underage girl? 
21 A. Actually, Mister, it's legal. 
22 Q. Well --
23 MR. LEOPOLD: Just answer the question, 
24 
25 THE WITNESS: Yes. 
109 
1 BY MR. TEIN: 
2 Q. Did they know two weeks ago that you were 
3 dating an underage girl (sic)? 
4 A. Yes. I met everybody in there. 
5 Q. Did they know your age? 
6 A. Yes. 
7 Q. Did you lie about your age so that the fire 
8 department wouldn't think that Brett is committing a 
9 crime by having a sexual relationship with an underage 
10 girl? 
11 MS. BELOHLAVEK: Objection. Assumes facts 
12 not in evidence. 
13 BY MR. TEIN: 
14 Q. You can answer the question. 
15 A. No. 
16 Q. Does the Palm Beach Police Department know 
17 that Brett is having a sexual relationship with an 
Page 93 
HOUSE OVERSIGHT 012488 
-0929104.TXT 
18 underage girl? 
19 MR. LEOPOLD: Don't guess. Answer if you 
20 know. 
21 THE WITNESS: Can you repeat the question? 
22 BY MR. TEIN: 
23 
24 thowarom m4ormof 
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2 Q. You lie about your twin sister don't 
3 you? 
4 MR. LEOPOLD: Objection. Argumentative. 
5 BY MR. TEIN: 
6 Q. Don't you? 
7 A. No. I have never lied for or to 
8 Q. You lie about the fact that she has a s 
9 drug habit, right? 
10 A. No. I would never accuse my sister of 
11 having a drug habit. 
12 Q. Do you try to conceal the fact that she has 
13 a drug habit? 
14 MR. LEOPOLD: Objection. Argumentative. 
15 BY MR. TEIN: 
16 Q. You can answer the question. 
17 A. No. My sister does not have a drug habit. 
18 Q. You lied when you-went to the crack house 
19 in Georgia, didn't you? 
20 MR. LEOPOLD: Objection. Argumentative. 
21 Lack of foundation, lack of predicate. 
22 THE WITNESS: Never -- what did you say? 
Page 94 
HOUSE OVERSIGHT 012489 
-0929104.TXT 
23 BY MR. TEIN: 
24 Q. You lied when you went to the crack house 
25 in Georgia, didn't you? 
111 
1 MR. LEOPOLD: Objection. Argumentative. 
2 Lack of foundation, lack of predicate. 
3 BY MR. TEIN: 
4 Q. You can answer the question. 
5 A. I have never been to a crack house. 
6 Q. Who don't you lie to? 
7 MR. LEOPOLD: Objection. Argumentative. 
8 Don't answer the question. 
9 MR. TEIN: Certify it. 
10 ..................CERTIFIED QUESTION.................. 
11 BY MR. TEIN: 
12 Q. You don't lie to , do you? 
13 MR. LEOPOLD: Objection. Asked and 
14 answered. 
15 Don't answer the question. 
16 BY MR. TEIN: 
17 Q. No. You can answer that question. 
18 MR. LEOPOLD: No. I just told her not to. 
19 You've asked that question about five --
20 MR. TEIN: No, I haven't. 
21 MR. LEOPOLD: Don't answer the question. 
22 MR. TEIN: I'll certify it. 
23 ..................CERTIFIED QUESTION.................. 
24 MR. LEOPOLD: For the record, you have to 
25 stop interrupting me because she can't take down 
Page 95 
HOUSE OVERSIGHT 012490 
-0929104.TXT 
112 
1 both of us talking at the same time. 
2 BY MR. TEIN: 
3 Q. You tell the truth, don't you? 
4 A. Excuse me? 
5 Q. You tell IIIIIIthe truth, don't you? 
6 A. When it's -- yes, I tell the truth. 
7 Q. Who's s drug dealer? 
8 A. My sister does not have a drug dealer. She 
9 lives in Georgia with my mother. 
10 Q. Okay- MIVRINEWCWOI0010#EWW640§000 
11 you and off at 5:45 a.m. in 2006, after being out 
12 all night, the two of you, using drugs at Palm Beach 
13 Country Estates where your father called the police? 
14 A. VIM= 
15 Q. He's the drug dealer? 
16 A. He is a drug dealer. 
17 Q. Do you remember was arrested by the 
18 Palm Beach Police Department and taken to the Juvenile 
19 Assessment Center that morning? 
20 A. I do remember that. 
21 Q. Now before you massaged Epstein, you were 
22 involuntarily admitted into a juvenile educational 
23 facility; isn't that right? 
24 A. Did you say involuntarily. 
25 Q. Yes. 
113 
1 A. No. I was willing to go. I -- duly said 
2 sure. 
3 Q. And you went there because you were lying 
4 so much, no one could control you; isn't that correct? 
Page 96 
HOUSE OVERSIGHT 012491 
7 
8 
9 
-0929104.TXT 
5 A. Very incorrect. 
6 Q. Now you lie to your parents all the time, 
don't you? 
A. Incorrect. 
MR. LEOPOLD: Objection. Argumentative. 
21 
22 
23 accused you of lying? 
24 A. All the time. 
Sorry? 
Incorrect. 
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10 BY MR. TEIN: 
11 Q. 
12 A. 
13 
16 
17 
18 your father that you were going shopping, didn't you? 
19 A. Yes. 
20 SW Alla 004.M 
:OOP 
Q. And isn't it true that your father has 
25 Q. Didn't your father throw you out of the 
114 
1 house Thanksgiving of this past year because you were 
2 lying so much to him? 
3 A. Yes, he did kick me out No, that's not 
4 the reasons why. 
5 Q. Didn't your father throw your sister 
6 out of the house, too? 
7 A. Yes. 
8 Q. And he threw her out of the house the week 
Page 97 
HOUSE OVERSIGHT 012492 
-0929104.TXT 
9 after Thanksgivings, right? 
10 A. I don't know the date, but sure. 
11 Q. Sounds about right? 
12 A. Sure. 
13 Q. And the reason he threw her out of the 
14 house was because she was lying, too? 
15 MR. LEOPOLD: Objection. Lack of 
16 foundation. Calls for speculation. 
17 BY MR. TEIN: 
18 Q. When your counsel coaches you, you say it's 
19 correct, right? 
20 A. I've never been coached. 
21 MR. LEOPOLD: Objection. 
22 BY MR. TEIN: 
23 Q. Okay. When your counsel that it was there 
24 was lack of foundation, you agree with your counsel, 
25 right? 
115 
1 A. I was like saying, Yeah, let's move on, 
2 because there was no point to asking that question. 
3 Q. Your father threw out of the house 
4 because she was lying, correct? 
5 MR. LEOPOLD: Objection. Lack of 
6 foundation. 
7 Hold on, Let me just make the 
8 objection. 
9 Lack of foundation, predicate, calls for 
10 speculation. 
11 BY MR. TEIN: 
12 Q. Answer. 
13 A. I'm not my sister. I don't know. 
Page 98 
HOUSE OVERSIGHT 012493 
-0929104.TXT 
14 Q. I want to know what you know only. 
15 A. I don't know. 
16 Q. You don't know. That's your answer? 
17 A. Yes. 
18 Q. Now your parents filed the police report 
19 regarding Mr. Epstein, right? 
20 A. Yes. 
21 Q. Now your parents are also lying, aren't 
22 they? 
23 A. Yes. 
24 MR. LEOPOLD: Just so the record is clear, 
25 the father -- because the mother was up north. 
116 
1 MR. TEIN: Don't testify, Counsel. 
2 MR. LEOPOLD: So the record is clear, the 
3 father -- the mother was --
4 MR. TEIN: Counsel, don't coach and 
5 testify, please. That's absolutely improper. 
6 MR. LEOPOLD: You just asked the wrong 
7 question. 
8 MR. TEIN: You can't coach her that way and 
9 you well know it. 
10 MR. LEOPOLD: For the record, it's the 
11 father. He's remarried, I think on his third 
12 marriage. 
13 MR. TEIN: You cannot -- it's absolutely, 
14 totally against the rules and you know it. 
15 MR LEOPOLD: The natural mother lives in 
16 Georgia. 
17 MR TEIN: You need to behave yourself, 
Page 99 
HOUSE OVERSIGHT 012494 
-0929104.TXT 
18 lawyer. 
19 MR LEOPOLD: The natural mother lives in 
20 Georgia. The father is here locally. 
21 MR TEIN: Stop coaching. Stop talking. 
22 You object. You know the rules. You just 
23 lectured me about the rules, Counsel. So why 
24 don't you play by the rules. Or only when they 
25 fit you? Why don't you grandstand a little more 
117 
1 now. Give us a five-minute speech, Mr. Leopold. 
2 MR. LEOPOLD: Are you finished, for the 
3 record. 
4 MR. TEIN: I'm not talking to you. Do what 
5 you want. 
6 MR. LEOPOLD: Don't say anything yet. 
7 BY MR. TEIN: 
8 Q. your parents --
9 MR. LEOPOLD: Hold it. Don't say anything 
10 yet. Let me --
11 BY MR. TEIN: 
12 Q. Your parents, who filed the police report 
13 are also liars. 
14 MR. LEOPOLD: Don't answer the question. 
15 We're not going to answer until I make the record. 
16 I want to put on the record, now that Counsel 
17 appears to be finished with his comments for the 
18 record, that the previous question was 
19 inappropriate, was intentionally misleading. 
20 Now you can ask the question. 
21 BY MR. TEIN: 
22 Q. Your parents, who filed the police report 
Page 100 
HOUSE OVERSIGHT 012495 
-0929104.TXT 
23 in this case, are also proven liars, aren't they? 
24 MR. LEOPOLD: Same objection. 
25 BY MR. TEIN: 
118 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 frae? 
17 
18 
19 •i DS 
20 
21 
22 
23 
24 
25 
Q. Aren't your parents liars? 
MR. LEOPOLD: Calls for speculation. Lack 
of predicate. 
MR. TEIN: Stop coaching. You know what 
that is, Leopold. 
MR. LEOPOLD: Calls for speculation. Lack 
of foundation. 
THE WITNESS: When you say parents, my mom 
is not, but sure, yeah, my dad has been to jail 
for lying. 
BY MR. TEIN: 
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MR. LEOPOLD: You can answer if you know 
the answer to it. I have no idea. 
Page 101 
HOUSE OVERSIGHT 012496 
-0929104.TXT 
119 
1 THE WITNESS: Yeah. 
2 BY MR. TEIN: 
3 Q. And your father filed a lawsuit, the first 
4 lawsuit for fifty million dollars against Mr. Epstein 
5 without consulting you, correct? 
6 A.OttOtE 
7 Q. And your father had a lawyer file the first 
8 lawsuit on your behalf for fifty million dollars against 
9 Mr. Epstein without your knowledge, correct? 
10 A. Correct 
11 Q. And you don't trust your father, do you? 
12 A. Correct. 
13 Q. And you believe he's trying to manipulate 
14 you for his own gain, don't you? 
15 A. Sort of. 
16 Q. Well, you know that your mother filed a 
17 statement, an affidavit, saying that you don't trust your 
18 father and that you believe he's trying to manipulate you 
19 for his own gain; isn't that correct? 
20 A. Correct. 
21 Q. You agree with that statement, don't you? 
22 A. Uh-huh. Yes. 
23 Q. Do you trust your stepmother? 
24 A. My stepmother, no. 
25 Q. You think she's also trying to steal your 
120 
1 Epstein lawsuit money away from you, don't you? 
2 A. I would like to clarify something. You 
3 keep saying my Epstein lawsuit money. I don't have any 
4 money, and it's just a lawsuit at the moment. So I just 
Page 102 
HOUSE OVERSIGHT 012497 
-0929104.TXT 
5 don't trust her. 
6 Q. Okay. You think that your stepmother is 
7 trying to take advantage of this lawsuit to try to get 
8 money from Mr. Epstein that belongs to you, right? 
9 A. Yes. 
10 Q. Did your stepmother tell you why she was 
11 arrested? 
12 A. No. 
13 Q. 
Did your stepmother tell you that she's 
14 ever been arrested? 
15 A. No. 
16 Q. Did she tell you she was arrested for 
17 fraud? 
18 A. Never. 
19 Q. Did she tell you that she was fired from 
20 
21 A. No. 
22 Q. Did she tell you that whe was fired from 
23 for stealing? 
24 A. No. 
25 MR. TEIN: Let's take a break. 
1 
2 BY MR. TEIN: 
3 
121 
(Thereupon, a recess was taken.) 
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Page 103 
HOUSE OVERSIGHT 012498 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
-0929104.TXT 
9 A. Two. 
10 Q. How old were they? 
A. Zack being one year older than me, 
and then the other person was two years older than me. 
Q. What was his name? 
A. Ryan 
Q. How old were you when you first had sexual 
intercourse? 
4P 44* 
Q. How many -- before you met Epstein, how 
many different men had you had any type of sexual 
activity with? 
21 la AtOtabg$03-0 
22 Q. Are you saying you never kissed a man other 
23 than those two? 
24 MR. LEOPOLD: Objection to the form of the 
25 question. 
1 THE WITNESS: Yes, I had kissed people 
2 before. 
3 BY MR. TEIN: 
4 Q. Before you met Epstein, had you ever had 
5 oral sex? 
6 A. No. 
7 Q. Ever in your life, have you exchanged sex 
8 for something of value? 
9 A. No. 
10 MR. TEIN: We're done. 
11 THE WITNESS: Oh, okay. 
12 MR. LEOPOLD: We'll read. 
13 MS. BELOHLAVEK: I don't have any 
Page 104 
122 
HOUSE OVERSIGHT 012499 
-0929104.TXT 
14 questions. Thank you. 
15 MR. LEOPOLD: Before we go off the record, 
16 it's my understanding -- Mr. Goldberger can 
17 correct the record, but we have stipulated that 
18 color copies of the documents that were identified 
19 for identification certainly will be attached to 
20 the deposition and counsel will be taking the 
21 photographs across street so that they can be 
22 laser color copied so that we have a copy, and I'm 
23 assuming he'll get a copy to the court reporter, 
24 too, to attach, actually a certified copy to the 
25 deposition. 
123 
1 MR. GOLDBERGER: Done. 
2 MR. LEOPOLD: That's if you agree to that. 
3 If not, then I want to pull each one out and put 
4 exhibit labels on them, which we should do before 
5 we leave. 
6 MR. GOLDBERGER: We're not going to do 
7 either. I'll have copies sent to the court 
8 reporter and she can attach them to the 
9 deposition. 
10 MR. LEOPOLD: So you're not going to agree 
11 to what we talked about during the break then. 
12 MR. GOLDBERGER: I'm not quite sure what 
13 your asking me to do. Let me finish. 
14 MR. LEOPOLD: Okay. Sure. That's fine. 
15 MR. GOLDBERGER: Okay. If you want me to 
16 go over to Ms. Belohlavek's office and make copies 
17 and then I'll give those to the court reporter, 
Page 105 
HOUSE OVERSIGHT 012500 
-0929104.TXT 
18 fine. All I'm saying is that I would avoid that 
19 process. I would send copies to the court 
20 reporter. But if it will make you happier 
21 MR. LEOPOLD: I'm not? 
22 MR. GOLDBERGER: Let me finish. 
23 MR. LEOPOLD: I'm not interrupting now. 
24 MR. GOLDBERGER: But if it will make you 
25 happier if I go over to Ms. Belohlavek's office 
124 
1 and make a copy of those photos that were part of 
2 this deposition and then I'll give them to the 
3 court reporter, I'll be happy to do it. 
4 MR. LEOPOLD: I trust you implicitly, 
5 however you with to do it. However, the 
6 documents, before they leave this room, need to 
7 have an exhibit sticky on them with the 
8 appropriate --
9 MR. GOLDBERGER: Want to go get some? We 
10 don't have any. 
11 MR. LEOPOLD: I will do that. Excuse me. 
12 Let me finish the record, please. You can't do 
13 that to the court reporter. She's going to stroke 
14 out. You can't do that. You have to let me --
15 MR. TEIN: Finish your sentence, Ted. You 
16 are the most long-winded lawyer I've ever seen in 
17 my life. Finish your sentence. 
18 MR. LEOPOLD: Jack, tell him not to raise 
19 his voice, please. 
20 MR. TEIN: Finish your sentence. Is there 
21 going to be a period at the end of the sentence or 
22 is it just going to be comma after comma after 
Page 106 
HOUSE OVERSIGHT 012501 
-0929104.TXT 
23 comma? 
24 Go ahead, lawyer. 
25 MR. LEOPOLD: All right. The exhibits, I 
125 
1 can't prevent you from taking them, but I will 
2 object and I will be bringing it to the court for 
3 sanctions. You cannot take the exhibits out of 
4 the room without them being marked. I want them 
5 marked, because you cannot identify in the record 
6 what was used. And with all due respect to 
7 Mr. Goldberger, I do not -- the way this 
8 deposition is going, I do not want to rely on 
9 Counsel from Miami to mark the appropriate 
10 exhibits. I will not do that. I cannot prevent 
11 you from taking them. But if you do, I will be 
12 bringing the matter to the court with appropriate 
13 sanctions, because that is improper. That is 
14 improper. When you use something in a deposition, 
15 they are to be marked. And you have refused to do 
16 that throughout for what ever reason. 
17 MR TEIN: You're wrong. Finish your 
18 sentence because you're talking about something 
19 you have no idea. 
20 Every single one is marked, Ted. Every 
21 single one is already marked. But you want to 
22 argue about everything. Ever single one is 
23 already marked. Isn't that silly, Ted? 
24 MR. GOLDBERGER: Thirty years of doing this 
25 and I have never had an argument over this. 
Page 107 
HOUSE OVERSIGHT 012502 
-0929104.TXT 
126 
1 MR. TEIN: You've made -- Ted, you are 
2 obstructionist, you are a liar. You have lied and 
3 misrepresented things, for the record. You are 
4 grandstanding. 
5 MR. LEOPOLD: You need to back up. 
6 MR. TEIN: No, no. I'm going to finish. 
7 MR. LEOPOLD: You can finish, but don't 
8 hover over me. 
9 MR. TEIN: No one is hovering over you. 
10 Stop trying to make a lying record. 
11 Let me say something else. 
12 Don't you dare threaten me with sanctions, 
13 after you lied in a letter to my co-counsel about 
14 the fact -- be quiet. Be quiet and let me finish. 
15 You lied in a letter to my co-counsel, 
16 Mr. Leopold, in which you said -- it was a 
17 complete and utter lie -- that you were 
18 unavailable this morning because you had a 
19 hearing. That was a lie. I have never seen each 
20 lawyer deign to do something like that. 
21 So you will get the ex -- be quiet Let me 
22 finish. You behave. 
23 MR. LEOPOLD: Don't point your finger at 
24 me. 
25 MR. TEIN: Listen. Be quiet and I won't 
127 
1 have a need to point it at you. 
2 MR. LEOPOLD: Don't point your finger at 
3 MR. TEIN: Mr. Leopold --
4 MR. LEOPOLD: Don't point your finger at 
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HOUSE OVERSIGHT 012503 
-0929104.TXT 
5 me. 
6 MR. TEIN: Mr. Leopold, let me finish. 
7 MR. LEOPOLD: Don't raise your voice 
8 either. 
9 MR. TEIN: Mr. Leopold 
10 MR. LEOPOLD: Jack, do you want to take 
11 care of this? 
12 MR. TEIN: Let me finish my sentence. The 
13 exhibits are marked. We are walking out of here. 
14 You are someone who misrepresents the 
15 record. It is absolutely atrocious what you do. 
16 That is not how a lawyer should behave. This 
17 deposition is over. You will get your exhibits, 
18 Mr. Leopold. 
19 MR. GOLDBERGER: I understand what you're 
20 saying, Michael, and I understand Ted's position. 
21 Just so there's -- we're going to have lots 
22 offer issues in this case. We're going to have 
23 lots of reasons to disagree. 
24 I'm going to take it over now and I'm going 
25 to make copies and I'm going to give them to 
128 
1 Ms. Consor. If you want to go find some exhibit 
2 labels and put some exhibit labels on it, be my 
3 guest. But that's what I'm offering to do. 
4 THE WITNESS: Let me say two things, 
5 because I am happy to always disagree and with 
6 you, I have no problem; we could always do it 
7 professionally. 
8 I want to say two things so the record is 
Page 109 
HOUSE OVERSIGHT 012504 
-0929104.TXT 
9 very clear. Since for whatever reason I have not 
10 been able to look at exhibits because they have 
11 been refused to have been shown to me --
12 MR. TEIN: That's a lie. 
13 MR. LEOPOLD: Jack, if you represent that 
14 the documents have the appropriate exhibit numbers 
15 or some identifying markings, 25, 30.000, whatever 
16 they may be, then you can take them, make copies, 
17 send me a copy, make sure the court reporter gets 
18 a copy and then send me a bill for my copy, that's 
19 fine. I didn't know that they are marked that way 
20 because I haven't been able to look at them. 
21 MR. GOLDBERGER: They are barcoded and the 
22 number that we've made reference to in the 
23 deposition coincides with the barcoding. 
24 MR. LEOPOLD: That's fine. Eight by eleven 
25 color laser copies are fine. 
129 
1 MS. BELOHLAVEK: The State Attorneys Office 
2 is not going to charge anybody for color copies I 
3 print out. 
4 MR. LEOPOLD: That's fine He's going to 
5 take them back to his office . 
6 Secondly -- and I will be more than happy 
7 to do it, because it sounds like you all know more 
8 about it than I, but I'm happy to get affidavits 
9 from Mr. Pincus, Judge Stern, everybody else about 
10 what happened with this hearing today, because I 
11 
12 
13 
know very little about it. But my representations 
are what they are. 
MR. GOLDBERGER: They stay --
Page 110 
HOUSE OVERSIGHT 012505 
-0929104.TXT 
14 MR. LEOPOLD: Let me just finish for the 
15 record. 
16 Representations or comments about what 
17 happened, representation about this hearing this 
18 morning, I know very little about it. I --
19 MR. GOLDBERGER: I'll take your word on 
20 that. 
21 MR. LEOPOLD: No, no, no. I just put it on 
22 the record. I will get an affidavit -- I'm 
23 assuming it sounds like you need it -- from Mr. 
24 Pincus. I have no clue about what happened and 
25 why it was canceled. All I was told when I was 
130 
1 out of town yesterday was that the hearing this 
2 morning was cancelled. 
3 MR. GOLDBERGER: I'll take your word for 
4 it. 
5 MR. LEOPOLD: If you want an affidavit, 
6 I'll get it for you. 
7 MR. GOLDBERGER: It's a personal issue for 
8 me because I had to disrupt a vacation and if it 
9 was done just because it wasn't convenient for 
10 you, then I'm offended by that. But if you're 
11 telling me that it was planned and it didn't 
12 happen, I'll take your word for it. 
13 MR. LEOPOLD: I am more than happy to get 
14 you an affidavit, because I don't know the reason 
15 why it was canceled other than the fact that I'm 
16 assuming since my deposition was taken for four 
17 hours on Monday for preparation for the hearing 
Page 111 
HOUSE OVERSIGHT 012506 
-0929104.TXT 
18 today, for whatever reason it was canceled, I am 
19 told it is being re-noticed. Why it was canceled 
20 I have no idea, but if your co-counsel wishes an 
21 affidavit to that effect from Mr. Pincus, I'm more 
22 than happy to get it. But I don't know the reason 
23 why it was canceled. 
24 MR. TEIN: I don't need it. But what I do 
25 take issue with is regardless of why it was 
131 
1 canceled, you owed us the courtesy of saying, you 
2 know what? We can start earlier this morning. 
3 MR. LEOPOLD: I owe you nothing 
4 MR. TEIN: I don't care. Don't interrupt 
5 me. 
6 Because Jack canceled his vacation plans 
7 because of you. 
8 MR. GOLDBERGER: That's all right, that's 
9 all right. 
10 MR. TEIN: And you're selfish. And this 
11 deposition is over. Good-by Mr. Leopold. 
12 MR. GOLDBERGER: You can go off the record. 
13 - - - 
14 
15 
16 
17 
18 
19 
20 
21 
22 
Page 112 
HOUSE OVERSIGHT 012507 
-0929104.TXT 
23 
24 
25 
132 
1 CERTIFICATE 
2 - - - 
3 
4 The State of Florida, 
5 County of Palm Beach. 
6 
7 I hereby certify that I have read the 
8 foregoing deposition by me given, and that the statements 
9 contained herein are true and correct to the best of my 
10 knowledge and belief, with the exception of any 
11 corrections or notations made on the errata sheet, if one 
12 was executed. 
13 
14 
15 Dated this _______day of___________________, 2008. 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Page 113 
HOUSE OVERSIGHT 012508 
-0929104.TXT 
133 
1 DATE: [!MONTH2] DATE2, 2008 
2 TO: 
X 
3 X 
X, Florida X 
4 
IN RE: CASENAME 
5 CASE NO.: 2006 CF09454AXX 
6 Please take notice that on Wednesday, the 
DATE1 of [!MONTH1], 2008, you gave your deposition in the 
7 above-referred matter. At that time, you did not waive 
signature. It is now necessary that you sign your 
8 deposition. 
A Please call our office at the below-listed 
9 number to schedule an appointment between the hours of 
9:00 a.m. and 4:30 p.m., Monday through Friday. 
10 AAs a professional courtesy, I am enclosing 
a condensed copy of your deposition transcript. 
11 A As previously agreed to, the transcript 
will be furnished to you through your counsel. Please 
12 read the following instructions: 
At Page A of the transcript, you will find 
13 an errata sheet. As you read your deposition, any 
changes or corrections that you wish to make should be 
14 noted on the errata sheet, citing page and line number of 
said change. DO NOT write on the transcript itself. 
15 Once you have read the transcript and noted any changes, 
be sure to sign and date the errata sheet and return 
16 these pages. You need not return the entire transcript. 
If you do not read and sign the deposition 
17 within a reasonable time, the original, which has already 
been forwarded to the ordering attorney, may be filed 
18 with the Clerk of the Court. If you wish to waive your 
signature, sign your name in the blank at the bottom of 
19 this letter and return it to us. 
Very truly yours, 
20 
21 Judith F. Consor, FPR 
Consor & Associates Reporting and Transcription 
22 1655 Palm Beach Lakes Boulevard, Suite 500 
West Palm Beach, Florida 33401 
23 
I do hereby waive my signature: 
24 
25 SAIGE GONZALEZ 
134 
1 cc via transcript: JACK A. GOLDBERGER, Esquire 
LANNA BELOHLAVEK, Esquire 
2 MICHAEL R. TEIN, Esquire 
file copy 
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Page 114 
HOUSE OVERSIGHT 012509 
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135 
1 	ERRATA 	SHEET 
2 	IN RE: CASENAME 
DEPOSITION OF: 	TAKEN: [IMONTH1] 
3 	DATE1, 2008 
DO NOT WRITE ON TRANSCRIPT 	- ENTER CHANGES HERE 
4 	PAGE # LINE # CHANGE 	REASON 
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21 Please forward the original signed errata sheet to this 
office so that copies may be distributed to all parties. 
22 
Under penalty of perjury, I declare that I have read my 
23 [!TYPE] and that it is true and correct subject to any 
changes in form or substance entered here. 
24 
DATE:___________ SIGNATURE OF DEPONENT:_______________________________ 
25 
136 
1 THE STATE OF FLORIDA, 
2 COUNTY OF PALM BEACH. 
3 
4 
5 I, the undersigned authority, certify that 
6 personally appeared before me on the DATE1 
7 of [IMONTH1], 2008 and was duly sworn. 
8 
9 WITNESS my hand and official seal this DATE2 
10 day of [IMONTH2], 2008. 
11 
12 
13 
Page 116 
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-0929104.TXT 
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Judith F. Consor, FPR 
Notary Public - State of Florida 
137 
1 CERTIFICATE 
2 
The State Of Florida, 
3 County Of Palm Beach. 
4 
5 I, Judith F. Consor, Court Reporter and Notary 
Public in and for the State of Florida at large, do 
6 hereby certify that I was authorized to and 
stenographically report the [!TYPE] of 
7 that a review of the transcript was not requested; and 
that the foregoing pages, numbered from 1 to A, 
8 inclusive, are a true and correct transcription of my 
stenographic notes of said [!TYPE]. 
9 
1 further certify that said [JTYPE] was 
10 taken at the time and place hereinabove set forth and 
that the taking of said [ITYPE] was commenced and 
11 completed as hereinabove set out. 
12 I further certify that I am not an attorney or 
counsel of any of the parties, nor am I a relative or 
13 employee of any attorney or counsel of party connected 
with the action, nor am I financially interested in the 
14 action. 
15 The foregoing certification of this transcript 
does not apply to any reproduction of the same by any 
16 means unless under the direct control and/or direction of 
the certifying reporter. 
17 
DATED this DATE2 day of [!MONTH2], 2008. 
Page 117 
HOUSE OVERSIGHT 012512 
-0929104.TXT 
18 
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Judith F. Consor, Court Reporter 
Florida Professional Reporter 
Page 118 
HOUSE OVERSIGHT 012513 
TAB 14 
HOUSE OVERSIGHT 012514 
sor &Associates 
Favor** gnfl Triamaipeoa, 
Page 1 
THE STATE OF FLORIDA, 
COUNTY OF PALM BEACH. 
IN RE: 
JEFFREY EPSTEIN. 
SWORN STATEMENT OF 
Friday, March 21, 2008 
4:00 p.m. - 4:20 p.m. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, Florida 33401 
Reported By: 
Judith F. Consor, FPR 
Notary Public, State of Florida 
Consor & Associates Reporting and Transcription 
West Palm Beach Office 
Phone - 561.682.0905 
HOUSE OVERSIGHT 012515 
sor & Associates 
Page 2 
1 APPEARANCES: 
2 
On behalf of the Defendant: 
3 JACK A. GOLDBERGER, ESQ. 
ATTERBURY, GOLDBERGER & WEISS 
4 250 AUSTRALIAN AVENUE SOUTH 
SUITE 1400 
5 WEST PALM BEACH, FLORIDA 33401 
561.659.8300 
6 
ALSO PRESENT 
7 LILLY ANN SANCHEZ, ESQ. 
FOWLER WHITE, ATTORNEYS AT LAW 
8 
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^ 
HOUSE OVERSIGHT 012516 
Statement taken before Judith F. Consor, 
Court Reporter and Notary Public in and for the State of 
Florida at Large, in the above cause. 
5 Thereupon, 
having been first duly sworn or affirmed, was examined 
and stated as follows: 
THE WITNESS: I do. 
10 BY MR. GOLDBERGER: 
11 Q. Would you state your name for the record, 
12 please. 
13 A. 
14 Q. Okay. 111111111 where do you live now? 
15 A. Address? 
16 Q. Sure. 
17 A. 
18 
19 Q. Do you live there alone or do you live with 
20 somebody there? 
21 A. My father. 
22 Q. Very good. And are you working now or not 
23 working? Sometimes you work and sometimes you don't? 
24 A. When I want to. 
25 Q. Okay. And how old are you today? 
HOUSE OVERSIGHT 012517 
sor 87, Associates 
RoporringandTrawipifico,  
Page 
1 
2 
3 
4 
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6 
A. Twenty-one. 
Q. Very good. 
What we're going to do today is we're going 
to take what's know as a sworn statement from you. And 
my court reporter just put you under oath. So all I want 
you to do is tell the absolute truth today. 
7 A. Right. 
8 Q. I don't want you to color what you're 
9 saying in any way. Really, the only thing that will be 
10 of any use to anyone is if you just tell the absolute 
11 truth. 
12 A. Right. 
13 Q. So those are the instructions, okay? 
14 A. Okay. 
15 Q. All right. And sometimes -- I've been 
16 doing this for a lot of years and sometimes I talk like a 
17 lawyer too much, and if you don't understand what I'm --
18 A. That's your job. 
19 Q. I guess. But if you don't understand what 
20 I'm saying at some point, just say, "Jack, say it in 
21 English," and I'll make it better for you. Okay? 
22 A. Okay. 
23 Q. So tell me how you first met Jeffrey 
24 Epstein. 
25 A. introduced me to him. 
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HOUSE OVERSIGHT 012518 
5or & A55ociates 
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HOUSE OVERSIGHT 012519 
sor ez. Associates 
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Page 6 
1 Q. Okay. So as far as you understood it and 
2 as far as what told you, you would be going over to 
3 Mr. Epstein's house and just giving him a normal 
4 therapeutic massage? 
5 A. Right. 
6 Q Okay. And I assume told you you would 
7 be paid for it? 
8 A. Yes. 
9 Q Did she tell you how much you would be 
10 paid? 
11 A. Yes. Two hundred. 
12 Q Okay. When was the first time that you 
13 went to Jeffrey Epstein's house? Was it after you spoke 
14 to Alex? 
15 
16 
17 Mr. Epstein's house, that was in response to 
18 talking to you in person. In other words, she said --
19 you saw her somewhere, be it at the store that you worked 
20 at or around the neighborhood, she said to you in person, 
21 "Do you want to go over to Jeffrey Epstein's house?" 
22 Right? 
23 
24 4 110n6000 
A. 
Q. 
A. 
Yes. 
Okay. And the first time that you went to 
Oh-huh. 
HOUSE OVERSIGHT 012520 
sor & Associates 
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And I take it you said okay and you went 
Q. All right. Now at the time that you went 
over there, you were not yet 18, but you were almost 18? 
A. Yes. 
Q. You were within a couple of months of being 
18 years old? 
A. Yes, I do believe so. 
Q. Okay. And what did tell you about if 
asked, how old you should tell anyone you were when you 
went over to his house? 
Was that a bad question? 
A. Repeat that. 
Q. Sure. Okay. 
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HOUSE OVERSIGHT 012521 
sor & Associates 
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HOUSE OVERSIGHT 012522 
Page 
A. It was probably Jeffrey. I don't remember 
very clearly. 
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A. Yes. 
Q. Okay. Now the first time that you went to 
10 Jeffrey's house did you give him a massage that day? 
11 A. Oh-huh. 
12 MS. SANCHEZ: Answer yes or no so the 
13 record is clear. 
14 THE WITNESS: Yes. Okay. 
15 (Discussion held off the record.) 
16 BY MR. GOLDBERGER: 
17 Q. Okay. So you go to Jeffrey's house and you 
18 meet him and you're going to do a massage that day, 
19 right? 
20 A. Yes. 
21 Q ow were°16d ..... you were 
22 _,.A04#4#k*$0.#00X 
23 
24 Q Yu OVO: tv-ored to do anything that you. 
25 
HOUSE OVERSIGHT 012523 
6 massage? 
Q. No one offered you any drugs to do a 
Q. No one offered you any alcohol to do a 
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HOUSE OVERSIGHT 012524 
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9 when you went there, as far as keeping your clothes on or 
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16 R. It was no problem. He wouldn't be upset. 
17 Q. All right. So told you there would be 
18 no pressure on you whatsoever? 
19 A. Right. 
20 
21 
'PDX 
A. Yes. 
22 Q • 
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24 
25 
Q • 
And if you didn't want to do something, you 
All right. And in your experiences with 
HOUSE OVERSIGHT 012525 
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Page 12 
Mr. Epstein, by the way, was there ever a time when that 
didn't play out, when he tried to force you to do 
something that you didn't want to do? 
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Q. All right. 
Now the first time that you wont there do 
you remember whether you gave Jeffrey a massage with your 
clothes on or your clothes off? 
A. At the beginning, it was with all my 
clothes on. 
Q. Uh-huh. 
A. But the most that -- I mean I was still in 
my bra and panties. 
Q. Okay. The whole time? 
A. Yes. 
Q. Right. 
A. I'm pretty sure, yes. 
Q. Did you see during that massage -- did he 
try and touch you in any way during that massage? 
A. No. 
Q. 
Did he use any kind of device on you in any 
way during that massage? 
HOUSE OVERSIGHT 012526 
sor & Associates 
Tmaxoripfito, 
Page 13 
1 A. No. 
2 Q. Do you know he was wearing a rowel 
3 through that massage? 
4 A. Yes. 
5 Q. Do you know whether he touched himself in 
6 any way, his penis or anything like that, during the 
7 massage? 
8 A. Yeah, like towards the end. 
9 Q. Okay. Do you know whether he masturbated? 
10 A. Oh, my gosh. 
11 Q. If you don't know, you don't know. 
12 A. I mean probably, but I don't know. I can't 
13 remember exactly. It was so long ago. 
19 Q. Okay. There was nothing that you were 
15 uncomfortable with in this massage? 
16 A. No. Yeah. And like I said, he also, you 
17 know, reassured if I wasn't comfortable with anything, 
18 then just tell him and --
19 Q. He would stop? 
20 A. -- that would be the end of it. 
21 Q. Okay. Now after that first time you met at 
22 Jeffrey's house, you left. And did there come other 
23 times that you went to Jeffrey's house? 
24 A. Yes. 
25 Q. And how would that occur? How would that 
HOUSE OVERSIGHT 012527 
1 happen? 
2 
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call or would there be others? 
A. Most of the time. 
24 
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HOUSE OVERSIGHT 012528 
sor & Associates 
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Never, ever suggested, right? 
A. No. 
Q. Okay. The only thing that ever occurred on 
any of these phone calls was, "Are you willing to come 
over," or, "Would you like to come over and give a 
massage?" 
A. 
Q. 
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Right. 
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Q. Okay. The phone call from or any 
other assistant would always -- it would be sporadic, 
right? They always said, "Jeffrey's going to be in town. 
Do you want to come over this afternoon at four o'clock?" 
A. Yeah, yeah. It wasn't --
Q. There was nothing regular about it? 
A. No. 
Q. Okay. Other than who else would have 
called you to ask whether you wanted to come over and 
HOUSE OVERSIGHT 012529 
cr & Amoriates 
Ropartin mxt Trmu 
give a massage? 
2 
Page 16 
A. If it wasn't then I believe 11111111 
3 maybe one other person I don't know the name of. Just --
4 I mean it was mostly And I spoke to a time 
5 or two. 
6 Q. 
7 Jeffrey's house after getting a phone call, you would go 
8 and you'd go to give him a massage, right? 
9 A. Yes. 
10 Q. 
11 massage that occurred? 
12 A. It happened a few times. 
13 Q. Okay. And the few times that it happened, 
14 though, it was very sporadic and it was nothing that was 
15 planned? 
16 A. No way. 
17 Q. It just occurred? 
18 A. Right. 
19 Q. So it wasn't like there was a phone call, 
20 you know, "Today we want you to come over and do more 
2/ than just a massage with Jeffrey"? 
22 A. Right. 
23 Q. When anything more occurred you'd be over 
24 there and it would be totally voluntary on your part? 
25 A. Yes; definitely consensual. 
XaSIOSING.....4.41,40214.0.1,....aixuar,a1444 
Okay. Now when you would go over to 
And occasionally would there be more than a 
HOUSE OVERSIGHT 012530 
Yes. 
A. 
It was probably mostly -- maybe not, not 
particularly oral, but, 
ViiibbOth4OMAUMPtatiObit 
Q. Okay. So let's put it into perspective. 
You certainly never had intercourse with him, right? 
A. No. 
Q. And did you actually ever really have oral 
sex with him? 
A. Maybe once or twice. I barely even 
remember that. 
1 Q. 
2 than just 
sor & Associates 
Rwitveto* Trammip.ft, E. 
Page 17 1 
Okay. Now when we're talking about more 
a massage, what sort of conduct are we talking 
3 about that might have occurred? 
4 
5 
6 
7 
a 
9 
10 
11 
12 
13 
14 Q. Okay. 
15 A. I mean it was all just mostly --
16 Q. I'm sorry. Mostly what? 
17 A. Mostly like hand oriented. 
18 Q. Okay. So on occasion you would touch his 
19 penis with your hand? 
20 A. It's happened a few times. 
21 Q. Okay. And anytime that occurred it would 
22 be totally voluntary on your part? 
23 A. 
24 Q  
25 A.He wQuld nvr make me co anythi 
' . . 
HOUSE OVERSIGHT 012531 
sor 8,t Associates 
'Wolin =4 TrimoTiptiori, hi. 
Page 18 
1 Q. And it would just be totally random and it 
2 would occur during the moment? 
3 A. Uh-huh. 
4 Q. Okay. There was nothing that was planned 
5 in advance concerning that? 
6 A. No. 
7 Q. And it didn't become every time you went 
8 over there that would happen, right? 
9 A. Yeah. No. 
10 Q. No, no. I mean just you would go over and 
11 give a massage one day and the phone call would be the 
12 same, "Do you want to come over and give a massage," and 
13 maybe --
14 A. Yes. 
15 Q. -- maybe another time you would get a phone 
16 call, "Do you want to come over and give a massage," and 
17 just because of the day it was or whatever was going on, 
18 it may have gone a little further where they may have 
19 been some touching, correct? 
20 A. Right. 
21 Q. And then the next time you could go over 
22 there and it could have been a regular massage again, 
23 right? 
24 A. Uh-huh. 
25 Q. Okay. So the point that I guess I'm trying 
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1 
HOUSE OVERSIGHT 012532 
sot- St Associates 
orgirat T1$4, tem 
1 
2 
3 and give a massage," and you just assumed it would be to 
4 go have sex? That was not the case? 
5 A. No. 
6 Q. Never, never, never, right? 
7 A. Yes. 
8 Q. All right. There were times when you would 
9 be away and not be in Palm Beach and -- I mean you very 
10 much thought that Jeffrey was your friend? You treated 
11 him as a friend? 
12 A. Yes, definitely. I felt that he was my 
13 friend. 
14 Q. And there were times when maybe you were 
15 out of town and for whatever reason, you found yourself 
16 in a situation where you needed some money, correct? 
17 A. Yes. 
18 Q. Okay. And you felt that the relationship 
19 was such that you could call Jeffrey and it never had 
20 anything to do with a massage or anything. You would 
21 say, "Listen, I could use a couple of dollars. I have a 
22 problem." 
23 A. Yes. 
24 Q. And would he ever hesitate to help you out? 
Page 19 
to make was that there were never phone calls that would 
come to you and they would say, "Do you want to come over 
25 A. No. 
HOUSE OVERSIGHT 012533 
sor & Associates 
R*peraganitTrotwriptitv,Inp. 
Page 20 
1 
2 listen -- he would talk to you about life and about --
3 A. Yes. 
4 Q. -- about what you wanted to do with your 
5 life? 
6 A. Yes. 
7 Q. And he said, "If you ever find yourself in 
8 trouble, you have a friend in me and you can give me a 
9 call"? 
10 A. Yes. 
11 Q. Okay. If you had to guess -- and 
12 recognizing that there can be no accuracy here -- if you 
13 had to guess, how many times do you think you went over 
14 to Jeffrey's house? 
15 A. I would say at least five, less than ten. 
16 Q. Okay. I think that's kind of a fair range. 
17 And during those five to ten times that you 
18 went there, was there ever anything uncomfortable, in 
19 your mind, that occurred over at Jeffrey's house? 
20 A. No. 
21 Q. Okay. I know we've touched on this, but 
22 just Lilly, the detail person, makes sure that we get 
23 everything. After you met Jeffrey the first time did you 
24 ever talk to him on the telephone about arranging a 
25 massage or anything like that? 
Q. 
And in fact, did he not tell you that, 
HOUSE OVERSIGHT 012534 
sor & Associates 
TriLcd$, 
Page 21 
1 A. No. 
2 Q. Okay. And you never e-mailed him or 
3 anything like that? 
4 A. No, no. 
5 Q. Never text-messaged him? 
6 A. No. 
7 Q. Okay. Now at times when you would go over 
8 zo give a massage, Jeffrey, while he was getting the 
9 massage, would be preoccupied doing a lot of things, 
10 right? 
11 A. Yes, very often. 
12 Q. He was a busy guy? 
13 A. Yes. 
14 Q. He would be on the telephone talking Lo 
15 folks while you were giving a massage? 
16 A. Yes. Sometimes it would be just a massage 
17 and he'd be pretty much doing business the whole time. 
18 Q. Right. Certainly it wasn't sex or anything 
19 like that? 
20 A. No. 
21 Q. He would be doing business and you'd be 
22 massaging him? 
23 A. Yes. 
24 Q. Okay. Give me one second. 
25 (Discussion held off the record.) 
A 
1 
HOUSE OVERSIGHT 012535 
sor &Associates 
pu.tfial5 gad Tomeliptiq'xi, 
1 BY MR. GOLDBERGER: 
2 Q. 
Page 22 3 
Every time you went back to Jeffrey's house 
3 you went back there because you wanted to, right? 
4 
5 
A. Uh-huh, yes. 
Q. No one -- certainly Mr. Epstein never tried 
6 to persuade you or induce you or entice you or coerce you 
7 to engage in any kind of sex? 
8 
9 
A. No. 
Q. And no one representing Jeffrey Epstein 
10 ever tried to persuade or induce you to engage in sex? 
11 
12 
A. No. 
AU right 
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18 Q. Okay. 
19 
20 that. 
21 
'-otYgg0114APIC - 
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A. Like there was no ifs, ands or buts about 
Q. There was a time when there was a concert 
22 or a show down in Fort Lauderdale and Jeffrey got you 
23 tickets to go to that show because it was your birthday, 
24 right? 
25 A. Correct. 
HOUSE OVERSIGHT 012536 
sor & Associates 
Rffipsirlin ATP4 TIVitiM46-9A, 11114. 
HOUSE OVERSIGHT 012537 
sor As5ociate5 
Rcipartiag sad nansuripdom, Tn. 
1 
2 Q. 
3 questions, have you? 
4 A. Yes. 
A. Yes. 
Okay. And you've understood all my 
Page 24 
5 MR. GOLDBERGER: Okay. I thank you very 
6 much for coming in today and it really made it 
7 much easier for us to do it this way. So thanks a 
8 lot. 
9 
10 concluded at 4:20 p.m.) 
11 
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(Thereupon, the sworn statement was 
HOUSE OVERSIGHT 012538 
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-sor & Associates 
oportima 4114 Trasuiptivq, 
Page 25 
THE STATE OF FLORIDA, ) 
COUNTY OF PALM BEACH. ) 
I, the undersigned authority, certify that 
personally appeared before me on the 21 of 
March, 2008 and was duly sworn. 
WITNESS my hand and official seal this 22nd day 
of March, 2008. 
Zia'AP4re 41  
Judith F. Consor, FPR 
Notary Public - State of Florida 
4 
1 
HOUSE OVERSIGHT 012539 
sot- & Associates 
RcrmingaTWMwmuiptiolOm 
1 
2 
CERTIFICATE 
Page 26 
The State Of Florida, ) 
3 County Of Palm Beach. ) 
4 
5 I, Judith F. Consor, Court Reporter and Notary 
Public in and for the State of Florida at large, do 
6 hereby certify that I was authorized to and did 
stenographically report the sworn statement of 
V that a review of the transcript was requested; and 
that the foregoing pages, numbered from 1 to 24, 
8 inclusive, are a true and correct transcription of my 
stenographic notes of said sworn statement. 
9 
I further certify that said sworn statement 
10 was taken at the time and place hereinabove set forth and 
that the taking of said sworn statement was commenced and 
11 completed as hereinabove set out. 
12 I further certify that I am not an attorney or 
counsel of any of the parties, nor am I a relative or 
13 employee of any attorney or counsel of party connected 
with the action, nor am I financially interested in the 
14 action. 
15 The foregoing certification of this transcript 
does not apply to any reproduction of the same by any 
16 means unless under the direct control and/or direction of 
the certifying reporter. 
17 
18 
19 
20 
21 
22 
23 
24 
25 
DATED this 22nd day of March, 2007. 
Judith F. Consor, Court Reporte 
Florida Professional Reporter 
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Ph. 561.682.0905 - Fax. 561.682.1771 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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Thainziptima, 
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sor & Associates 
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1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
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TAB 15 
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nsor A5sociate5 
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THE STATE OF FLORIDA. 
COUNTY OF PALM BEACH. 
IN RE: 
JEFFREY EPSTEIN, 
Page 1 
CONTINUED SWORN STATEMENT OF 
March 26, 2008 
6:05 p.m. to 6:22 p.m. 
South 86th Terrace 
West Palm Beach, Florida 
Reported By: 
Maria C. Powers, 
Notary Public State of Florida 
J. Consor & Associates 
West Palm Beach Office 
Phone 561.682.0905 
Reporting & Transcription 
ORIGINAL 
Ph. 561.682.0905 - Fax. 561.682.1771 
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nsor & Associate5 
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1 APPEARANCES : 
2 
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4 On Behalf of the Defendant: 
JACK A. GOLDBERGER, ESQ. 
5 ATTERBURY, GOLDBERGER & WEISS 
6 250 South Australian Avenue 
Suite 1400 
West Palm Beach, Florida 33401 
Page 2 
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1655 Palm Beach Lakes BlVd., Suite 500 West-Palm Beath, FL 33401 
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Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Pahl Beach Lakes Blvd., Suite 500 - West Palm Beach,-FL-33401' • 
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9 BY MR. GOLDBERGER: 
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18 A Yes. 
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Sworn Statement taken before Maria Powers, 
Court Reporter and Notary Public in and for the State 
of Florida at Large, in the above cause. 
Thereupon, 
having been first duly sworn, was examined and 
testified as follows: 
DIRECT EXAMINATION 
as you remember, my name is Jack 
Goldberger. I think we met last Friday, actually. 
You voluntarily came in and gave a sworn 
statement to me concerning your knowledge and your 
friendship with Jeffrey Epstein. 
I would like to very, very, briefly continue 
that statement today, and just focus on one area that 
we forgot to question you about last Friday. 
All I want you to tell me is the absolute 
truth here this evening. There's no right answer, 
other than the truth, okay? 
A Right. 
I haven't promised you or asked you to do 
anything, one way or the other, have I? 
A No. 
Ph. 561.682.0905 - Fax. 561.682.1771 
— 1655 Pah Be'ath-Lakes BlVd.-;-Suite 500 - West Palm Beach, FL-33401 " • 
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1 Q So, we covered a lot of ground last time. 
2 One area that I didn't ask you about is 
3 contact that you've had with either the FBI or the U.S. 
4 Attorney's Office, within the last two or three years. 
5 Can you guess or estimate how many times 
6 someone from the FBI or the U.S. Attorney's Office or 
7 some other law enforcement agency, has attempted to 
8 contact you in the last couple of years? 
9 A I'd have to say -- well, maybe five or six 
10 meetings with, and more than that with phone contact. 
11 
Let's try to break it down by meetings and 
12 phone contacts. I think that would be the best way to 
13 do it. 
14 Of the actual meetings that you've had with 
15 someone from law enforcement or from the U.S. 
16 Attorney's Office, who do you remember being present at 
17 those meetings? 
18 A Nesbith was at all of them. 
19 Q When we're talking about "Nesbith" we're 
20 talking about an FBI agent by the name of "Nesbith 
21 Kurkendall"? 
22 A Yes. 
23 Q And Nesbith was present at all those 
24 meetings? 
25 A Yes. 
Ph. 561.682.0905 - Fax. 561.682.1771 
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2 A The first one was a guy, I'm not sure of his 
3 name. And then there's another one that had -- another 
4 lady with the victim's rights. 
5 Q She was victim's right representative? 
6 A Yes. 
7 Q We talked about a lawyer by the name "Marie 
8 Villafona;" do you know whether she was present during 
9 any of those meetings? 
10 A I'm not sure of the name. 
11 Q The first time that you met with Nesbith, 
12 where did that take place? 
13 A Here, in my backyard. 
14 0 In your backyard, at your home in Western 
15 Palm Beach County, right? 
16 A Yes. 
17 Q Did she announce to you that she was coming, 
18 or did she just show up? 
19 A She showed up. 
20 Q Unannounced? 
21 A Yes. 
22 Q During that time, I assume that you told her 
23 about your relationship with Jeffrey Epstein and any 
24 contact you've had with him, correct? 
Q Okay, go ahead. 
25 A Correct. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palen Beath-Lakes.B1\id., Suite 500 =West Palrn' Begth;R:33401 ' • -• 
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1 Q Did she tell you anything about whether you 
2 were a victim in this case, or anything like that, at 
3 that meeting? 
4 A Yes, she said I was a victim/witness in this, 
5 and that there's victim rights that I'm entitled to, 
6 which include counseling and whatnot. 
7 Q Did you tell her, at that time, that you 
8 didn't feel that you were a victim at all, and that 
9 anything that you've done with Jeffrey Epstein was 
10 totally voluntary? 
11 A Yeah, I did tell her that everything was, you 
12 know, consensual with everything, and I don't agree 
13 with anything that's going on. 
14 Q Did she try and pressure you into being a 
15 victim in this thing, when you were not a victim? 
16 A I wouldn't say that she pressured me, but she 
17 tried to be as convincing as possible. 
18 Q Maybe the use of the word "pressure" is too 
19 strong. But she was trying to change your opinion of 
20 what the relationship was with Jeffrey? 
21 A Yes, she was trying to make me feel bad about 
22 it, in a way, about what was going on. 
23 Q And you didn't feel bad about it, you felt 
24 everything was okay, but she was trying to make you 
25 feel bad, like something wrong had occurred? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm- Beath Lakes BlVd.','Suite 500 - West Palm Beath', FL 33401" " 
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1 A Yeah. 
2 Q How long did that meeting go on for? 
3 A Probably about -- at least an hour. 
4 Q When was the next time that you had contact 
5 with Nesbith or someone else from law enforcement? 
6 A I'm not sure, probably a month or later. I 
7 mean, she probably called me and let me know that she 
8 was going to -- you know, she wanted to meet sometime 
9 soon, to deliver the victim's rights papers to me. 
10 Q So there was a time, after you first met, 
11 where, despite the fact that you said, I don't consider 
12 myself a victim in this, she called you and said, I 
13 want to bring you some paperwork that talks about your 
14 victim's rights? 
15 A Yes. 
16 Q What was your response to her when she told 
17 you that? 
18 A I told her I would meet with her, 'cause she 
19 wanted me to meet with the other woman involved. And 
20 they gave them to me. 
21 I took them, but I never really told them I 
22 needed counseling or anything like that. 
23 Q Where did that meeting take place? 
24 A I believe it was Panera Bread in 
25 Wellington. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm'Beach.Lakes Blvd., Suite 500 West"Palm Beach, FL 33401 " 
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She actually came and sought you out at a 
2 restaurant? 
3 A Well, I told her to meet me there. 
4 Q Were you working there or were you just --
5 A No, I was just there. 
6 Q So she called you and said, I really, really 
7 want to see you. And you said, if you want to see me, 
8 meet me at Panera Bread? 
9 A Yes. 
10 Q Did you feel if you didn't meet her, she 
11 wasn't going to go away, that you had to deal with 
12 her? 
13 A Well, I mean, it wasn't particularly that. I 
14 knew that she was going to contact me because of this 
15 case. Because, whether I want to be involved or not, I 
16 have to be. 
17 Q Okay. That's two meetings that I know of. I 
18 think you indicated that, if you had to guess, there 
19 were maybe a total of five meetings. 
20 Are there other meetings that we haven't 
21 talked about that occurred? 
22 A Yeah, but they were very vague They weren't 
23 anything of importance. And, I mean, it was just 
24 her -- or of importance to me, anyway. 
25 Q Would she call you and say, listen, I really, 
Ph. 561.682.0905 - Fax. 561.682.1771 
' .1655 Palm Beach Lakes-Blvd., Suite 500 - West"Pairn Beath; FL 33401 
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1 really, want to talk to you about being a victim or --
2 
A It wasn't always directly about being a 
3 victim. And, every-time we talked, she would always 
4 touch upon the fact that if I need any help or 
5 so-on-and-so-forth, because I am a victim in this 
6 case. 
7 Q I assume, based on what you're telling me, 
8 you continued to tell her, I'm not a victim? 
9 A I just let her say what she said. I never 
10 got counseling. But she knows from the beginning, and, 
11 I continued to reassure her, that I don't feel that 
12 way. 
13 Q So, the first time you met with her, when you 
14 spent about an hour with her and you went through all 
15 your contact with Jeffrey, that's what occurred at that 
16 meeting, and she talked to you about being a victim at 
17 that meeting? 
18 A Yes. 
19 Q And then there was this second meeting, where 
20 she brought a victim's rights person with her, and that 
21 took place at Panera Bread, right? 
22 
A Yes. 
23 Q And you had the same response, listen, you 
24 think I'm a victim. You could give me the information, 
25 but I don't need that information, right? 
Ph. 561.682.0905 - Fax. 561.682.1771 
' 1655 Pah Beach Lakes BlVd., Suite`500 -Vest Palm Beath, FL 33401—
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A Right, pretty much. 
And then there were some other contacts. 
Would she call you and want to talk to you 
4 about the specific facts about the case? I mean, why 
5 would she contact --
6 A Yeah, I mean, just to re-question me about 
7 certain things, because she wasn't sure that the 
8 answers were --
9 
Were those in-person meetings? 
10 A I mean, a lot of them were on the phone. I 
11 mean, it wasn't very often that we would meet. 
12 Q Was there any other time that you did meet? 
13 We talked about two times that you actually 
14 did meet, once here at your home and once at Panera 
15 Bread. 
16 Were there any other actual meetings, or did 
17 the others occur on the phone? 
18 A There were other meetings, but they were, 
19 like I said, not really important. 
20 Q Do you remember where they were that they 
21 took place? 
22 A They came to my job, I think, two times. 
23 Q When you say "they" --
24 A Well, it Nesbith the first time, and, the 
25 second time, it was the David Copperfield investigators 
Ph. 561.682.0905 - Fax. 561.682.1771 
••••• • '1655•Pali-n--Bekh• Lakes BlVd.";Suite'500 -"West*Palm-Beach:FL3340•1"--'----
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1 with Nesbith. 
2 Q Right. 
3 So, the third time that you met with Nesbith, 
4 she came to your job, and she wanted to talk to you 
5 about more facts of the case? 
6 A Ah-huh. 
7 Q And, during that meeting, she also talked to 
8 you about your rights as a victim again? 
9 A Yeah, she always reassured me of my rights as 
10 a victim. 
11 Q Then there would have been a fourth time 
12 we're talking about now, where there were investigators 
13 from Washington coming down, concerning David 
14 Copperfield, and Nesbith introduced them to you, 
15 correct? 
16 A Right. 
17 Q I take it what you're telling me is that 
18 Nesbith seized the opportunity to talk to you again 
19 about being a victim, right? 
20 A She always kind of comes out as asking if I'm 
21 okay, and if everything okay. And if I ever need any 
22 kind of help or anything, with -- you know, I could 
23 always have help. 
24 Q Did you continue to say, listen, I'm fine, 
25 there's no issues here? 
3 
Ph. 561.682.0905 - Fax. 561.682.1771 
Palhi.Bektitake't•BIVtl":,'SOite-500",, We8t-Palhi Beath, FL '33401 " 
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A I just -- I mean, I was never pushy on it. I 
2 just, like I said, she always knows. 
3 I may not tell her every time, but she always 
4 knows how I feel about this case. 
5 Q Meaning? 
6 A I don't need any-thing. 
7 Q Meaning that you made it really clear to her 
8 that you didn't need any help? 
9 A Yeah, from the beginning, I was very, very 
10 reassuring about how I felt about it. And I wasn't 
11 very happy. 
12 Q All right. I understand. 
13 Now, we're about four contacts with 
14 Nesbith your house, Panera Bread, work, the David 
15 Copperfield investigators. 
16 A Yes. 
17 Q Were there any other meetings that we have 
18 not spoken about? 
19 A There may have been like one or two. But 
20 they're -- I don't even remember. I mean, those are 
21 the ones, like, that remember the most. 
22 Q That you really remember, okay. 
23 Now, were there other telephone calls that 
24 occurred, where, kind of the same kind of conversation 
25 would occur? You know, there's help for you and you'd 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach•LakOs Blvd:, Suita"500 West Palm'Reath, FL3340r' 
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1 say, I'm really not a victim here? 
2 A Like I said, I was, like, okay. You know, 
3 she would always continuously tell me. I mean, but 
4 every time, it was the same thing. 
5 I mean I was never -- I mean, I was never 
6 mean to any of them. I never gave anybody attitude 
7 about anything. But, I mean, she knows that. She 
8 knows how I feel. 
9 Q I think what I hear you saying is that she 
10 knows how you feel, and you made it clear to her from 
11 the start, that you were not a victim? 
12 
13 because 
14 
15 me 
16 
17 
18 Q Do you think that's what she was trying to 
19 do, is try to convince you to change your attitude as 
20 to how you felt? 
21 A In a way, yes. 
22 Q Is there anything else that we need to 
23 discuss that we haven't talked about? 
24 A No, I think that's mostly it. 
25 Q I appreciate your courtesies once again for 
A Yeah, I mean, she pretty much, does it - 
that's what she has to do. She has to continue 
to tell me. And, you know, in a way, try to convince 
that I am a victim. 
I just let her say what's she's going to say, 
and, then, you know, okay, goodbye. 
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1 seeing me one more time, and doing this voluntarily. 
2 And, thanks so much for making yourself 
3 available today. 
4 A No problem. 
5 Q That will do it -- actually, one more time. 
6 Brittany, let me say one more time: 
7 Everything you've told me here today is the 
8 absolute truth, right? 
9 A Yes. 
10 Q I haven't tried to convince you to say one 
11 thing, one way or the other, have I? 
12 A No. 
13 Q All right. That's it. Thank you very much. 
14 (Thereupon, the sworn statement was 
15 concluded at 6:22 p.m.) 
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1 THE STATE OF FLORIDA 
2 COUNTY OF PALM BEACH 
3 
4 
5 
6 I, the undersigned authority, certify that 
7 
personally appeared before me on March 
8 26, 2008 and was duly sworn. 
9 
10 
11 WITNESS my hand and office seal this 26TH day 
12 of MARCH, 2008. 
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(.01A;L 6, if?4,40) 
Maria C. Powers, Court Reporter 
Notary Public - State of Florida 
My Commission No. DD149010 
My Commission Expires: 9/10/10 
Ph. 561.682.0905 - Fax. 561.682.1771 
-1655'Palim Beach Lakes''Blvd:"aiite500'-'We'st Palm Rack FL 33:401"-- • 
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, 
1 1 
nor & Associate5 
Page 17 
1 CERTIFICATE 
2 
3 The State of Florida 
County Of Palm Beach 
4 
5 
6 I, MARIA C. POWERS, a Shorthand Reporter, State 
of Florida at Large, do hereby certify that 
7 was by me first duly sworn to testify 
the whole truth; that I was authorized to and did 
8 report said deposition in stenotype; and that the 
foregoing pages, numbered from 1 to 17 inclusive, are a 
9 true and correct transcription of my shorthand notes of 
said deposition. 
10 
I further certify that said deposition 
11 was taken at the time and place hereinabove set forth 
and that the taking of said proceeding was commenced 
12 and completed as hereinabove set out. 
13 I further certify that I am not an 
attorney or counsel of any of the parties, nor am I a 
14 relative or employee of any attorney or counsel of 
party connected with the action, nor am I financially 
15 interested in the action. 
16 The foregoing certification of this 
transcript does not apply to any reproduction of the 
17 same by any means, unless under the direct control 
and/or direction of the certifying reporter. 
18 
IN WITNESS WHEREOF, I have hereunto set 
19 my hand this 26TH day of MARCH, 2008. 
20 
21 
22 
Maria C. Powers, Notary Public 
23 In and for the State of Florida 
My Commission No. DD149010 
24 My Commission Expires: 9/10 
25 
Ph. 561.682.0905 - Fax. 561.682.1771 
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''' • '" 1655'Palhl Beach 'LakeS 500'1'West 'PaIhrBeaCh,:FIL 33401 
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TAB 16 
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11/16/2006 16:31 FAX 5618021787 
USAO IPPB FL ra 002 
U.S. Department of Justice 
United States- Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
West Palm Beach, FL 33401 
(561) 820-8711 
Facsimile: (561) 820-8777 
November 16, 2006 
VIA FACSIMILE  
Lilly Ann Sanchez, Esq. 
Fowler White Burnett 
1395 Brickell Ave Fl 14 
Miami Florida 33131-3300 
Re: Jeffrey Epstein 
Dear Ms. Sanchez: 
Thank you for your letter and voicernail. I will plan to direct all correspondence to you 
unless you provide other instructions. In turn, please direct all future communications with the 
Office to my attention. 
As I mentioned in my voicemail, Mr. Lewis stated that Mr. Epstein is willing to provide 
documents and information that we deem necessary to the investigation. I would appreciate if you 
would forward the documents and information listed below to my attention or, if you prefer, to 
Special Agent E. Nesbitt Kuyrkendall, Federal Bureau of Investigation, 500 South Flagler Drive, 
Suite 500, West Palm Beach, PL 33404. If you require a grand jury subpoena for any of the items, 
please let me know_ 
1. Documentation related to the ownership of the property located at 358 Ell3rillo Way, 
Palm Beach, Florida, including the purchase agreement and any mortgages, liens, or 
other encumbrances. 
2. Documentation related to the ownership of Gulfstream Aircraft N909JE, Model 
01159B, and Boeing Aircraft N908JE, Model 727-31, including purchase 
information, lease agreements, liens or other encumbrances, and payments for 
maintenance and storage. 
3. All documents and information provided to the Palm Beach County State Attorney's 
Office in connection with its investigation of Mr. Epstein. 
4. Bank information, account numbers, bank statements and billing statements for any 
bank accounts and/or credit cards used by Mr. Epstein (or any of his employees) to 
pay for Mr. Epstein's personal expenses, from January 1, 20(04 to the present. 
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PAGE 2 OF 3 
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5. Information and billing statements for any "land lines," cellular telephones, 
Blackberry units, e-mail addresses, webpages, or the like for Mr. Epstein and all of 
his personal assistants (including but not limited to and 
from January 1, 2004 to the present. 
6. The computers, hard drives, CPUs, and any other computer media (ineluding CD-
ROMs, DVDs, floppy disks, flash drives, etc.) removed from 358 El Brillo Way, 
Palm Beach, Florida prior to the execution of the search warrant at that premises in 
October 2005. 
7. All calendars, diaries, and address books kept by Mr. Epstein and all of his personal 
assistants from January 1, 2004 to the present, including electronic calendars and 
address books, whether stored on computer, PDA, or cellular telephone. 
8. For persons in his employ at any time from January 1, 2004 to the present, 
employment and/or separation agreements between Mr. Epstein (or his company) 
and his personal assistants, airplane pilots, personal chefs, and for anyone who 
worked at 358 El 13riLlo Way, Palm Beach, Florida. 
9. The names and contact information of all persons who performed "massage services" 
for Mr. Epstein at 358 El Brillo Way, Palm Beach, Florida or at his residences in 
New Albany, Ohio, Little St. James, U.S.V.I., and New York, NY; and 
documentation of payments made to or gifts given to any such persons. 
10. Wage and earnings statements and other tax documents for all individuals referenced 
in items (8) and (9), supra. 
11. Mr. Epstein's tax returns for 2004 and 2005. 
12. From January 1, 2004, to the present, flight manifests and passenger lists for travel 
via Gulfstream Aircraft N909.1E, Model G1159B and Boeing Aircraft N908JE, 
Model 727-31 (to the extent not already provided). 
13. Documentation regarding any other interstate or international travel undertaken by 
Mr. Epstein from January 1, 2004, to the present, including but not limited to 
airplane tickets, ear rental records, and hotel receipts. 
After I have a chnce to review the documents, I will contact you to set up a time to 
interview Mr. Epstein. 
00270 
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LILLY ANN SANCH R7, ESQ. 
Nova/mm.16, 2006 
PAGE 3 OF 3 
e 004 
Thank you for your assistance with this matter, and I look forward to working with you and 
Mr. Lefcourt. 
By: 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
A. Marie Villafaiia 
Assistant United States Attorney 
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H)-44g (KCV. 6-2-90 
FBI WEST PALM BEACH RA P.01 
FBI FACSIMILE 
COVER SHEET 
PRECEDENCE 
El Immediate 
ID Priority 
El Routine 
To: William Riley 
CLASSIFICATION 
0 Top Secret Time Transmitted: _________________________ 
El Secret Sender's Initials: jrr  
0 Confidential Number of Pages:  5  
I:1 Sensitive (including cover sheet) 
iili Unclassified 
Name of Office 
Facsimile Number: 954-905-4922 
Attn: 
Name 
From: FBI 
Room Telephone 
Name of Office 
Subject  Service of Federal Grand Jury Subpoenas 
Date: 06/20/2007 
Special Handling Instructions: _______________________________________________________________________________________________________________ 
Originator's NalIle: SA Jason Richards  Telephone: 561-833-7517 
Originator's Facsimile Number: 5 61 - 8 33 - 7 979 
Approved: _____________________________________________ 
Brief Description of Corarnunipation Faxed:  Two subpoenas: 1) William Riley arid. 2)  
Custodian of Records, Riley Kiraly  
WARNING 
Information attached to the cover sheet is U.S. Government Property. If you arc not the intended recipient of this 
information, disclosure, reproduction, distribution, or use of this information is prohibited (I S.USC, § 641). Please notify the 
originator or the local FBI Office immediately to arrange for proper disposition. 
HOUSE OVERSIGHT 012571 
JUN-20-2007 11:18 
FBI WEST PALM BEACH RR P.02 
United States District Court 
SOUIHERN DISTRICT OF FLORIDA 
TO: Custodian of Records 
Riley Kiraly 
Comnoercial Center of Miatni 
6155 NW 167th Street E-26 
Miami, FL 33015 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
Fog 07-103(WPB)No. OLY-64 
SUBPOENA FOR: 
PERSON 12d DOCUMENTS OR OBJECVI 
YOU ARE HEREBY COMMANDED to appear and testifyhefore the Grand Jury ofthe United States District 
Court at the place, date and time specified below. 
PLACE: 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TIME: 
July 10, 2007 
l00 pm* 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): 
TEE DOCUMENTS AND OBJECTS LISTED ON ATTACHMENT 
*Please coordinate your compliance with this subpoena and confirm the date, time, and location of your 
appearance 'with WA Nesbitt Kuyrkendall, Federal Bureau of Investigation-, Telephone: (561) S22-5946. 
ThiS subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting 
on behalf of the court. 
This subpoena is issued upon application 
of the U'led States of America 
•11":aet Applicable, cram "none: 
Name, Address and Phone Number of Assistant U.S, Attorney 
Alan Marie C. Villafst3,a, Assistant IJ_S..Attorney 
500 So. Australian Avenue, Suite 400 
West Palm Beach, FL 33401-6235 
Tel: (561) 820-8711 x3047. 
Pax: (561) 802-1787 
Tdla used in Enn of AIM 10 
FORM ORD-227 
JAN.86 
HOUSE OVERSIGHT 012572 
JUN-20-2007 11:19 
FBI WEST PALM BERCH RA P.03 
ATTACHMENT A  
SUBPOENA TO PAUL A. LAVERY 
1. All computer equipment and electronic storage media removed from the 
residence located at 358 El Brill° Way, Palm Beach, Florida, including but not 
limited to central processing units ("CPUs"), laptop computers, keyboards, 
printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, 
DVDs, floppy diskettes, digital cameras, and memory cards. 
2. MI comptiter equipment and electronic storage media that currently belongs 
to, or has ever belonged to, Jeffrey Epstein, including but not limited to central 
processing units ("CPUs"), laptop computers, keyboards, printers, modems, 
routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy 
diskettes, digital cameras, and memory cards. 
3. All documents and information related to the nature of the relationship 
between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, 
including, but not limited to, retainer agreements; employment agreements; 
billing statements (whether submitted directly to Mr. Epstein or to a third party 
for reimbursement); records of the dates when services were performed and 
the hours worked; telephone logs or records of dates of communications with 
Mr. Epstein (or with a third party on Mr. Epstein's behalf); appointment 
calendars/datebooks and the like (whether in hard copy or electronic form) for 
any period when work was performed on behalf of Mr. Epstein or when any 
communication was had with Mr. Epstein (or with a third party on Mr. 
Epstein's behalf); and records of fee arrangements and payments received for 
work performed on Mr, Epstein's behalf, 
HOUSE OVERSIGHT 012573 
JUN-20-2007 11:19 
FBI WEST PALM BEACH RA 
P.  
United States District Court 
SOUTHERN DISTRICT OF FLORIDA 
' TO: William Riley 
Riley Kiraly 
ComMercial Center of Miami 
6135 NW 167th Street E-26 
Miami, FL 33015 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
FOJ 07-103(WPB)/No. OLY.-63 
SUBPOENA FOR: 
PERSON Fl DOCUMENTS OR OBSECiTS1 
X 
YOU ARE PIEREBY COMMANDED to appear and testify before the Qrand July ofthe United States District 
Court at the place, date and time specified below. 
P LACL.: 
United States District Courthouse 
701 Clematis Street 
West Palm Beach, Florida 33401 
ROOM: 
Grand Jury Room 
DATE AND TIME: • 
July 10, 2007 
1:00 pm* 
YOU ARE ALSO COMMANDED to bring with you the following docinnent(s) or object(s): 
I tit. DOCUMENTS AND OBJECTS LISTED ON ATTACHNIENT A. 
*Please coordinate your compliance with this subpoena and confirm the date time and location of your 
appearance with S/A Nesbitt Kuyritendall, Federal Bureau of Investigation, Telephone: (61) 822-5946. 
This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting 
on behalf of the court. 
This subpoena is issued upon application 
of the United States of America 
+Irmo( applicabk, owe "none." 
Name. Address and Phone Number of Assistant U.S. Attorney 
Ann Marie C. Villafalla, Assistant U.S. Attorney 
500 Se. Australian Avenue, Suite 400 
West Palm Beach, EL 33401_6235 
Tel: (561) 8204711 x3047 
Fax: (561) 302-1787 
ToreI IgAl;)1111 
FORM QR.I>2.27 
JA1416 
HOUSE OVERSIGHT 012574 
JUN-20-2007 1119 
FBI WEST PALM BEACH RA P.05 
ATTACHMENT A 
SUBPOENA TO PAUL A. LAVERY 
1. All computer equipment and electronic storage media removed from the 
residence located at 358 El Brillo Way, Palm Beach, Florida, including but not 
limited to central processing units ("CPUs"), laptop computers, keyboards, 
printers, modems, routers, hard drives, flash drives, thumb drives, CD-Roms, 
DVDs, floppy diskettes, digital cameras, and memory cards. 
2. All computer equipment and electronic storage media that currently belongs 
to, or has ever belonged to, Jeffrey Epstein, including but not limited to central 
processing units ("CPUs"), laptop computers, keyboards, printers, modems, 
routers, hard drives, flash drives, thumb drives, CD-Roms, DVDs, floppy 
diskettes, digital cameras, and memory cards. 
3. All documents and information related to the nature of the relationship 
between Mr. William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, 
including, but not limited to, retainer agreements; employment agreements; 
billing statements (whether submitted directly to Mr. Epstein or to a third party 
for reimbursement); records of the dates when services were performed and 
the hours worked; telephone logs or records of dates of communications with 
Mr. Epstein (or with a third party on Mr. Epstein's behalf); appointment 
calendars/datebooks and the like (whether in hard copy or electronic form) for 
any period when work was performed on behalf of Mr. Epstein or when any 
communication was had with Mr. Epstein (or with a third party on Mr. 
Epstein's behalf); and records of fee arrangements and payments received for 
work performed on Mr. Epstein's behalf 
TOTAL P.05 
HOUSE OVERSIGHT 012575 
TAB 18 
HOUSE OVERSIGHT 012576 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
DELIVERY BY ELECTRONIC MAIL 
Jay P. Lefkowitz, Esq. 
Kirkland & Ellis LLP 
Citigroup Center 
153 East 53rd Street 
New York, New York 10022-4675 
Re: Jeffrey Epstein 
Dear Jay: 
500 S. Australian Ave, Ste 400 
West Palm Beach, FL 33401 
(561) 820-8711 
Facsimile: (561) 820-8777 
December 13, 2007 
I am writing not to respond to your asserted "policy concerns" regarding Mr. Epstein's Non-
Prosecution Agreement, which will be addressed by the United States Attorney, but the time has 
come for me to respond to the ever-increasing attacks on my role in the investigation and 
negotiations. 
It is an understatement to say that I am surprised by your allegations regarding my role 
because I thought that we had worked very well together in resolving this dispute. I also am 
surprised because I feel that I bent over backwards to keep in mind the effect that the agreement 
would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the 
agreement. For example, I brought to your attention that one potential plea could result in no gain 
time for your client; I corrected one of your calculations of the Sentencing Guidelines that would 
have resulted in Mr. Epstein spending far more time in prison than you projected; I contacted the 
Bureau of Prisons to see whether Mr. Epstein would be eligible for the prison camp that you desired; 
and I told you my suspicions about the source of the press "leak" and suggested ways to avoid the 
press. Importantly, I continued to work with you in a professional manner even after I learned that 
you had been proceeding in bad faith for several weeks — thinking that I had incorrectly concluded 
that solicitation of minors to engage in prostitution was a registrable offense and that you would 
"fool" our Office into letting Mr. Epstein plead to a non-registrable offense. Even now, when it is 
clear that neither you nor your client ever intended to abide by the terms of the agreement that he 
signed, I have never alleged misconduct on your part. 
The first allegation that you raise is that I "assiduously" hid from you the fact that Bert 
Ocariz is a friend of my boyfriend and that I have a "longstanding relationship" with Mr. Ocariz. 
HOUSE OVERSIGHT 012577 
JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 2 OF 5 
I informed you that I selected Mr. Ocariz because he was a friend and classmate of two people 
whom I respected, and that I had never met or spoken with Mr. Ocariz prior to contacting him about 
this case. All of those facts are true. I still have never met Mr. Ocariz, and, at the time that he and 
I spoke about this case, he did not know about my relationship with his friend. You suggest that I 
should have explicitly informed you that one of the referrals came from my "boyfriend" rather than 
simply a "friend," which is the term I used, but it is not my nature to discuss my personal 
relationships with opposing counsel. Your attacks on me and on the victims establish why I wanted 
to find someone whom I could trust with safeguarding the victims' best interests in the face of 
intense pressure from an unlimited number of highly skilled and well paid attorneys. Mr. Ocariz 
was that person. 
One of your letters suggests a business relationship between Mr. Ocariz and my boyfriend. 
This is patently untrue and neither my boyfriend nor I would have received any financial benefit 
from Mr. Ocariz's appointment. Furthermore, after Mr. Ocariz learned more about Mr. Epstein's 
actions (as described below), he expressed a willingness to handle the case pro bono, with no 
financial benefit even to himself. Furthermore, you were given several other options to choose from, 
including the Podhurst firm, which was later selected by Judge Davis. You rejected those other 
options. 
You also allege that I improperly disclosed information about the case to Mr. Ocariz. I 
provided Mr. Ocariz with a bare bones summary of the agreement's terms related to his appointment 
to help him decide whether the case was something he and his firm would be willing to undertake. 
I did not provide Mr. Ocariz with facts related to the investigation because they were confidential 
and instead recommended that he "Google" Mr. Epstein's name for background information. When 
Mr. Ocariz asked for additional information to assist his firm in addressing conflicts issues, I 
forwarded those questions to you, and you raised objections for the first time. I did not share any 
further information about Mr. Epstein or the case. Since Mr. Ocariz had been told that you 
concurred in his selection, out of professional courtesy, I informed Mr. Ocariz of the Office's 
decision to use a Special Master to make the selection and told him that the Office had made contact 
with Judge Davis. We have had no further contact since then and I have never had contact with 
Judge Davis. I understand from you that Mr. Ocariz contacted Judge Davis. You criticize his 
decision to do so, yet you feel that you and your co-counsel were entitled to contact Judge Davis to 
try to "lobby" him to select someone to your liking, despite the fact that the Non-Prosecution 
Agreement vested the Office with the exclusive right to select the attorney representative. 
Another reason for my surprise about your allegations regarding misconduct related to the 
Section 2255 litigation is your earlier desire to have me perform the role of "facilitator" to convince 
the victims that the lawyer representative was selected by the Office to represent their interests alone 
and that the out-of-court settlement of their claims was in their best interests. You now state that 
doing the same things that you had asked me to do earlier is improper meddling in civil litigation. 
Much of your letter reiterates the challenges to Detective Recarey's investigation that have 
HOUSE OVERSIGHT 012578 
JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 3 OF 5 
already been submitted to the Office on several occasions and you suggest that I have kept that 
information from those who reviewed the proposed indictment package. Contrary to your 
suggestion, those submissions were attached to and incorporated in the proposed indictment 
package, so your suggestion that I tried to hide something from the reviewers is false. I also take 
issue with the duplicity of stating that we must accept as true those parts of the Recarey reports and 
witness statements that you like and we must accept as false those parts that you do not like. You 
and your co-counsel also impressed upon me from the beginning the need to undertake an 
independent investigation. It seems inappropriate now to complain because our independent 
investigation uncovered facts that are unfavorable to your client. 
You complain that I "forced" your client and the State Attorney's Office to proceed on 
charges that they do not believe in, yet you do not want our Office to inform the State Attorney's 
Office of facts that support the additional charge nor do you want any of the victims of that charge 
to contact Ms. Belohlavek or the Court. Ms. Belohlavek's opinion may change if she knows the full 
scope of your client's actions. You and I spent several weeks trying to identify and put together a 
plea to federal charges that your client was willing to accept. Yet your letter now accuses me of 
"manufacturing" charges of obstruction of justice, making obscene phone calls, and violating child 
privacy laws. When Mr. Lourie told you that those charges would "embarrass the Office," he meant 
that the Office was unwilling to bend the facts to satisfy Mr. Epstein's desired prison sentence — a 
statement with which I agree. 
I hope that you understand how your accusations that I imposed "ultimatums" and "forced" 
you and your client to agree to unconscionable contract terms cannot square with the true facts of 
this case. As explained in letters from Messrs. Acosta and Sloman, the indictment was postponed 
for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to 
the Office to convince the Office not to prosecute. Those presentations were unsuccessful. As you 
mention in your letter, I —a simple line AUSA — handled the primary negotiations for the Office, and 
conducted those negotiations with you, Ms. Sanchez, Mr. Lewis, and a host of other highly skilled 
and experienced practitioners. As you put it, your group has a "combined 250 years experience" to 
my fourteen. The agreement itself was signed by Mr. Epstein, Ms. Sanchez, and Mr. Lefcaut, 
whose experience speaks for itself. You and I spent hours negotiating the terms, including when to 
use "a" versus "the" and other minutiae. When you and I could not reach agreement, you repeatedly 
went over my head, involving Messrs. Lourie, Menchel, Sloman, and Acosta in the negotiations at 
various times. In any and all plea negotiations the defendant understands that his options are to 
plead or to continue with the investigation and proceed to trial. Those were the same options that 
were proposed to Mr. Epstein, and they are not "persecution or intimidation tactics." Mr. Epstein 
chose to sign the agreement with the advice of a multitude of extremely noteworthy counsel. 
You also make much of the fact that the names of the victims were not released to Mr. 
Epstein prior to signing the Agreement. You never asked for such a term. During an earlier 
meeting, where Mr. Black was present, he raised the concern that you now voice. Mr. Black and 
I did not have a chance to discuss the issue, but I had already conceived of a way to resolve that 
HOUSE OVERSIGHT 012579 
JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 4 OF 5 
issue if it were raised during negotiations. As I stated, it was not, leading me to believe that it was 
not a matter of concern to the defense. Since the signing of the Non-Prosecution Agreement, the 
agents and I have vetted the list of victims more than once. In one instance, we decided to remove 
a name because, although the minor victim was touched inappropriately by Mr. Epstein, we decided 
that the link to a payment was insufficient to call it "prostitution." I have always remained open to 
a challenge to the list, so your suggestion that Mr. Epstein was forced to write a blank check is 
simply unfounded. 
Your last set of allegations relates to the investigation of the matter. For instance, you claim 
that some of the victims were informed of their right to collect damages prior to a thorough 
investigation of their allegations against Mr. Epstein. This also is false. None of the victims was 
informed of the right to sue under Section 2255 prior to the investigation of the claims. Three 
victims were notified shortly after the signing of the Non-Prosecution Agreement of the general 
terms of that Agreement. You raised objections to any victim notification, and no further 
notifications were done. Throughout this process you have seen that I have prepared this case as 
though it would proceed to trial. Notifying the witnesses of the possibility of damages claims prior 
to concluding the matter by plea or trial would only undermine my case. If my reassurances are 
insufficient, the fact that not a single victim has threatened to sue Mr. Epstein should assure you of 
the integrity of the investigation.' 
'There are numerous other unfounded allegations in your letter about document demands, 
the money laundering investigation, contacting potential witnesses, speaking with the press, and the 
like. For the most part, these allegations have been raised and disproven earlier and need not be 
readdressed. However, with respect to the subpoena served upon the private investigator, contrary 
to your assertion, and as your co-counsel has already been told, I did consult with the Justice 
Department prior to issuing the subpoena and I was told that because I was not subpoenaing an 
attorney's office or an office physically located within an attorney's office, and because the business 
did private investigation work for individuals (rather than working exclusively for Mr. Black), I 
could issue a grand jury subpoena in the normal course, which is what I did. I also did not 
"threaten" the State Attorney's Office with a grand jury subpoena, as the correspondence with their 
grand jury coordinator makes perfectly clear. 
With regard to your allegation of my filing the Palm Beach Police Department's probable 
cause affidavit "with the court knowing that the public could access it," I do not know to what you 
are referring. All documents related to the grand jury investigation have been filed under seal, and 
the Palm Beach Police Department's probable cause affidavit has never been filed with the Court. 
If, in fact, you are referring to the Ex Parte Declaration of Joseph Recarey that was filed in response 
to the motion to quash the grand jury subpoena, it was filed both under seal and ex parte, so no one 
should have access to it except the Court and myself. Those documents are still in the Court file 
only because you have violated one of the terms of the Agreement by failing to "withdraw 
[Epstein's] pending motion to intervene and to quash certain grand jury subpoenas." 
HOUSE OVERSIGHT 012580 
JAY P. LEFKOWITZ, ESQ. 
DECEMBER 13, 2007 
PAGE 5 OF 5 
With respect to Ms. Miller, I contacted her attorney - who was paid for by Mr. Epstein and 
was directed by counsel for Mr. Epstein to demand immunity - and asked only whether he still 
represented Ms. Miller and if he wanted me to send the victim notification letter to him. He asked 
what the letter would say and I told him that the letter would be forthcoming in about a week and 
that I could not provide him with the terms. With respect to Ms. Miller's status as a victim, you 
again want us to accept as true only facts that are beneficial to your client and to reject as false 
anything detrimental to him. Ms. Miller made a number of statements that are contradicted by 
documentary evidence and a review of her recorded statement shows her lack of credibility with 
respect to a number of statements. Based upon all of the evidence collected, Ms. Miller is classified 
as a victim as defined by statute. Of course, that does not mean that Ms. Miller considers herself 
a victim or that she would seek damages from Mr. Epstein. I believe that a number of the identified 
victims will not seek damages, but that does not negate their legal status as victims. 
I hope that you now understand that your accusations against myself and the agents are 
unfounded. In the future, I recommend that you address your accusations to me so that I can correct 
any misunderstandings before you make false allegations to others in the Department. I hope that 
we can move forward with a professional resolution of this matter, whether that be by your client's 
adherence to the contract that he signed, or by virtue of a trial. 
Sincerely, 
R. Alexander Acosta 
United States Attorney 
By: s/A. Marie Villafana 
A. Marie Villafaria 
Assistant United States Attorney 
cc: R. Alexander Acosta, U.S. Attorney 
Jeffrey Sloman, First Assistant U.S. Attorney 
You also accuse me of " broaden [ing] the scope of the investigation without any foundation 
for doing so by adding charges of money laundering and violations of a money transmitting business 
to the investigation." Again, I consulted with the Justice Department's Money Laundering Section 
about my analysis before expanding that scope. The duty attorney agreed with my analysis. 
HOUSE OVERSIGHT 012581 
TAB 19 
HOUSE OVERSIGHT 012582 
vaA0110 (Rev. 04/07) Subpoena In Tcstify Before Grand Jury 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
TO: 
SUBPOENA TO TESTIFY 
BEFORE GRAND JURY 
FGJ 07-10-3(WPB)-Tues. No. OLY-85/1 
SUBPOENA FOR: 
ft PERSON lEr DOCUMENT(S) OR OBJECT(S) 
YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District 
Court at the place, date, and time specified below. 
-pLiNicg 
United States District Court 
701 Clematis Street 
West Palm Beach, Florida 33401 
.COLRTR 00 M • " 
Grand Jury Room 
tiATEAND TIME 
7/1/2008 10:30 am 
YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):. 
ALL DOCUMENTS AND INFORMATION REFERENCED IN THE ATTACHMENT TO THIS SUBPOENA. 
0 Please see additional Information on ret,-,t 
This subpoena shall remain in elf 
behalf of the court. 
(By) Deputy clod( 
This subpoena is issued on application 
of the- CA a' 
• Irnol applicable. enla "none". 
p.rikbythe couk or by an-officet acting on. 
NAME; ADDRESS' AND PHONE NUMBER or ASSISTANT US. ATTORNEY 
Ann Marie C. Villafarla, Assistant U.S. Attorney 
500 South Australian Avenue, Suite 400 
West Palm Beach, Florida 33401-6235 
Tel: (561) 820-8711, ext 3047 
HOUSE OVERSIGHT 012583 
ATTACHMENT TO GRAND JURY SUBPOENA OLY-85/1  
ADDRESSED TO  
PLEASE BRING THE FOLLOWING DOCUMENTS, ITEMS, AND INFORMATION WITH YOU 
TO YOUR GRAND JURY APPEARANCE: 
1. Any and all notes, letters, cards, gifts, payments, photographs, or other items that you 
have received from Jeffrey Epstein,__________________ 
Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein. 
2. Any and all photographs, whether printed or digital, of Jeffrey Epstein, 
Lesley Groff, Ghislaine Maxwell, and/or any 
other employee or associate of Jeffrey Epstein. 
3. Any and all c-mails, instant messages, chats, text messages, voicemails or telephone 
messages that you have sent to and/or received from Jeffrey Epstein, 
Lesley Groff, Ghislaine Maxwell, and/or any other 
employee or associate of Jeffrey Epstein. 
4. A list of all telephone numbers (cellular and "land line"), e-mail addresses, screen 
names, addresses, and any other contact information that you have for the following persons during 
the period of January 1, 2003 to the present: 
a. yourself; 
b. Jeffrey Epstein; 
C. 
d. 
e. 
f. 
g. Lesley Groff; 
h. Ghislaine Maxwell; 
i. any person(s) who introduced you to Jeffrey Epstein and/or Ghislaine 
Maxwell; 
j. any person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine 
Maxwell; 
k. any person(s) who communicated with you to arrange appointments to meet 
with Jeffrey Epstein and/or Ghislaine Maxwell. 
5. Any billing statements for telephone service (cellular and "land line") for any 
telephone you used during the period of January 1, 2003 to the present. 
HOUSE OVERSIGHT 012584 
TAB 20 
HOUSE OVERSIGHT 012585 
CONFIDENTIAL PLEA NEGOTIATIONS 
TERMS OF EPSTEIN NON-PROSECUTION AGREEMENT 
• Epstein pleads guilty (not nob o contendere) to an Information filed by the 
Palm Beach County State Attorney's Office charging him with: 
(a) lewd and lascivious battery on a child, in violation of Fl. Stat. 800.04(4);