Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 76 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) three years old when she met Epstein, anything that happened was between two consenting adults. I explained to her that she was not in any trouble however as art of this investigation, I needed to ask certain questions. stated that there were times that Epstein would ask her to perform during the massage. He would instruct her to rub his nipples as he masturbated himself. stated she felt "grossed" about the behavior but as she was gets ng paid, she just continued. also advised she would on occasion perform the massages naked. Epstein would on occasion, utilize the vibrator/massager on her vagina area when she performed the massages. explained that Epstein never exposed himself to her as he mainta ned himself covered under the towel he would be wearing. When Epstein would masturbate he would be covered. I asked if ever received any gifts, or any gratuities from Epstein. advised aside from being paid well, she advised Epstein too care of her tuition from Palm Beach Atlantic College. She received a rental car for a week when her scooter broke down. Additionally she received other gifts from Epstein. Epstein also recommended her to another client who resides at Breakers Row in Palm Beach. The client she was referred to was "Glenn" unknown last name, and his wife, who she provided a massages to. The statement was concluded and placed into evidence upon our return to the Palm Beach Police Department. While at the police station, I researched Florida tag iiiiiii which was also previously seen on the property when there was physical surveillance being done at the property. The vehicle is registered to of Lake Worth, Florida. Researchin Mr. and the ve icle revealed that his daughter, had een driving the vehicle and was cited for unlaw u speed in Lake Clark Shores. The vehicle is a tan, Chevrolet Camaro, 2-door. I researched date of birth, Ilillilill, resides at in Lake Worth. has a space page called In her web page, shows various photos of p otograp e• at a •each. An interview is forthcoming. A review of the video disks which was extracted at the Palm Beach County Sheriff's Office Computer Crime Unit revealed that only one hidden camera was functional at the time. Several images workin at his office were seen. Additional footage of and was seen. There was other footage seen. i e y f the females is unknown at this time, until such time as I meet with dertain females to show the video footage to confirm if in fact, it is them on the video. At this time it appears his des in t e eveniilliurs. Due to poor lighting, a direct that and are seen sitting with Epstein beside confirmation cannot be made at this time. Inv. Continues. EFTA00232117

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Incident Report Page: 77 Program: CMS301L Case No • 1-05-000368 **************************** N A R R A T I V E # 37 NA Reported By: RECAREY, JOSEPH Entered By.: ALTOMARO, NICKIE A. On January 25, 2006, Det Caristo and in Lake Worth and met with year, when she was seventeen ears through her former room mate Epstein at the time. when they modeled. explaine and advised her that s e was in Palm each and requested to see her. IIIII made arrangements to meet with her at Epstein's house. arrived and met Epstein and shopping. a v sed that and ' and went to the Pa m Beach Mall together and went she had received money from Epstein to go to the mall. They ilited Victoria's Secret and purchased undergarments from the store utilizing monies given by Epstein. advised she purchased one item and purchase various items. The money used to purchase the items was the money given by Epstein. (Continued) ************************** 1/30/06 1/30/06 I responded to stated est e, s e met Jeffrey Epstein was allegedly dating ad once cohabitated together called her on her telephone and stated explained how she and Epstein have been datin eacillier continued shopping and having a day together. and he as een paying all of her bills. claimed advised they met in New York and had been dating ever since. They later returned to Epstein's home and encountered Epstein. He had a brief conversation with about her modeling career. He knew of her modeling career from He requested to see her modeling portfolio and explaine at he could help her with modeling jobs. had her book with her to show and showed the book to stein. He commented negatively about er photographs and portfolio. felt uncomfortable with the comments made as she had been wor ing with other professional modeling companies who had offered her work from her photographs. stein requested to see what was purchased at the mall. took out the undergarments which were purchased. She immediate y showed stein different siiiiiurchased. Epstein then requested to view what purchased. was reluctant to show the outfit however since it was Epstein's money that purchased the item she pulled it out of the bag. Epstein asked her to try it on. looked at who told her "yeah, try it on." Feeling compelle to try the undergarment outfit on; she went to another room and put on the bra and panty set. She walked out to the living room where they were sitting, and modeled the suit. She then went back into the other room and chaliiillack into her clothes. returned into the room and told she would be going home. scheduled another day for to return for massages with her. stated within that same week, she returned to meet with and have a massage. had told her that she would be unable. iiiii with her as she wou be going on a bike ride with Epstein. explained she could stay at the house and take advantage of the massage. EFTA00232118

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 78 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) stated she met with an unknown massage therapist and had the table already set up in a guest room. removed her clothing, leaving her anties on, and wrapped herself with a towel for the massage. remembered that the door to the guest room was closed but not loc e . As the therapist was working her back, the door was opened by Epstein and entered into the room. was trying to conceal herself as Epstein was talking to her a out his chiropractic session. Epstein told turn over onto her back. eventually turned over exposing her breasts to Epstein as e applied pressure on her shoulder and her waist. stated Epstein "popped" her back. removed her self from the to le, got dressed and left the house. further stated had attempted to call her on several occasions to invite her back to Epstein's house to which replied "I'm busy." advised she has not had contact with either or Jeffrey Epstein. It should be noted that her mother, was present during the interview. The interview was concluded and we thanked them her for their time. ****************************NARRATIV8 # 38 ************************** NA Reported By: RECAREY, JOSEPH 1/31/06 Entered By.: ALTOMARO, NICKIE A. 1/31/06 On Januar 27 200 Imade telephone contact with , at . 'I'll' is a licensed massage therapist who had frequented the home of Jeffrey Epstein. Ms. has been unable to meet with me in Palm Beach County, and because she lives and works in Port St Lucie, a telephone interview was conducted. I explained to Ms. that there was an on going investigation involving Jeffrey Epstein. stated she knows Epstein and has been em lo ed by him for approximately three years. Epstein has paid to erform Swedish Massages (Deep Tissue) on him and other guests. explained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual friend. Epstein and Maxwell were looking for a massage therapist. stated since that time, she is notified when Epstein is coming to Palm Beach. stated she comes to his house and provides the massage or massages. explained she has also massaged his guests and assistants. continued that she is paid $100.00 and hour for the massage. I asked if anything occurred during the massage that would have made her feel uncomfortable. stated she only provided massages and that was it. she never was approached for anything else. I asked if Epstein ever asked her to rub his chest she stated she would not rub his chest as that is not part of her massage. explained that she was not Epstein's type. The girls she would see at Epstein's house were very thin, beautiful and without tattoos. explained she has several tattoos that are visible. Maxwell and Epstein have commented negatively about her tattoos previously when she has provided massages. EFTA00232119

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 79 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) stated she only provided massages for Epstein and his associates and nothing happened during those massages. stated as she does Swedish style massages, the patient is usuall'ille after the massages. I thanked her for her assistance and the interview was concluded at this time. I received a facsimile from T-Mobile Cellular service on telephone number , which is assigned to David Rodgers, pilot for Mr. Epstein, w o rest es in Lake Worth. Rod ers' telephone number was dialed on several occasions by . A background on Rodgers indicated he has a valid FAA pi of icense First Class for the Southern FAA Region. Rodgers has another historical FAA license for Airline Transport Pilot. Investigation Continues. ****************************NARRATIVE # 39 ************************** NA Reported By: RECAREY, JOSEPH 2/14/06 Entered By.: ALTOMARO, NICKIE A. 2/16/06 On Friday, February 3, 2006, I had made arrangements to meet with at the Palm Beach Police Station. At approximately 1:00pm, and her friend, arrived at the police station. During an interview wit she stated she met Epstein when she turned eighteen years o and was brought to Epstein's house to provide a massa•e. She advised this occurred on May of 2005. She advised had informed her if she wanted to provide a massage for $200.00. a•reed and was brought to Epstein's house to provide a massage. stated she had been to the house on many occasions during the massage sessions. also stated she would remove her clothing to provide the massage on Epstein. advised Epstein would pay her $300.00 to rub his back, legs an c est. During the massages, Epstein would masturbate himself as she rubbed his chest. I asked her if Epstein ever touched her breasts during the massages. replied. "Yes." I asked her if Epstein ever touched or massage er vagina. stated he had on several occasions. I asked her if he ever penetrated her with either his penis or any other objects. stated that during a massage he inserted his fingers in her va Ina as she massaged him. She stated this occurred one time only. stated the massage would be over when Epstein would climax onto a towel. I asked if she had an formal massage training to which she replied that she did not. was then asked if she ever brought anyone to the house to "wor stated she brought two people to the house. She advised she receive money-for-bringing people to the house to "work." stated she brought a girl named " her friend and lobby of the police station. I thanked was still waitin for orher time and her in t e cooperation and escorted her to the lobby. I asked Ms if I could speak with her about this investigation. I EFTA00232120

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 80 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) brought her to the interview room and explained to her that I was conducting an investigation on Jeffrey Epstein and felt she may have information ertainiiilio the investigation. Ms identified and resides in Wellington, Florida. She herself as advised approximately a year aiiiihe was brought to Epstein's house to provide a massage for money. stated she needed to make money and felt it was a quick way to make some money. stated she was brought to the house by and was intro uced to Epstein and his assistant. She was broug t to is main bathroom and provided a massage. I asked her if she provided the massage naked. stated she did. She rubbed Epstein's legs, back and chest. I as a if Epstein touched her during the massage. She advised he did not, however he did masturbate himself as she rubbed his chest. Once he climaxed the massage was over. She was paid her money and left the Epsteinill!ouse. The interview was concluded and was escorted to area. advised it occurred one time and she never returned to the lobby. I located a telephone number for and attempted to contact her on several occasions. I ca ell...II-Ell and spoke with Ms. who advised she would speak with me in Deerfield Beach where she resides. Due to a scheduling conflict, we were unable to meet. I informed her I would contact her to schedule another appointment to speak with her about this investigation. I have attempted to meet with her and make telephone contact with negative results. On February 13, 2006, I met with David Rodgers at in Lake Worth. Rodgers was identified as Epstein s pi o . spoke with Rodgers who advised he has been employed with Epstein since 1991. He flies both planes for Epstein depending where he wants to fly to. Rodgers was asked about passengers in the plane he flies. Rodgers stated unless Epstein flew to his island off of St there would be no way of knowing who the passengers were. I mentioned a recent flight to Ohio, where Rodgers flew to Ohio to pick up Rodgers stated he recalled flying on several occasions and did remember Rodgers stated once he is in the cockpit, he does not know who ”assengers are. When he prepares the passenger manifests he lists Epstein and his assistants he knows by name, and IIIIIIII. Rodgers stated he would list either female or male passengers on the manifests only to keep a count on the passengers. Mrs. Rodgers came into the living room and recommended that her husband consult with an attorney. Mr. Rodgers agreed he would speak with the family attorney to inform him of this questioning. I explained to Mr. Rodgers that he was not the suspect in this investigation and ceased all questions. Based on the fact Rodgers could not advise who passengers were in the plane, I then left the area. I attempted to locate at in Wellington. I left my us ness card for her to return my call. On February 14, 2006, at 12:06 pm, I received a call back from Ms. EFTA00232121

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 81 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) on my voice mail. Ms !III left her telephone number for a return call 561 -=I e heramessage to return call. Investigation Continues.. ****************************NARRATIVE # 40 ************************** NA Reported By: RECAREY, JOSEPH 2/21/06 Entered By.: ALTOMARO, NICKIE A. 2/22/06 On February 15, 2006, I made telephone contact with who provided directions to where I could locate her. Det Caristo and I re responded to III III IIIII III in Lake Park to meet with Upon my arrival, I met with in the parking of erectly be in MAACO Auto Painting. She was a vised I was there to speak with her about an 2222ing investigation that concerned Jeffrey Epstein in Palm Beach. IIIII stated she knows Epstein very well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want to speak with me about anything concerning Jeffrey Epstein. I explained to her that she was seen at the house and I would like to speak with her. She stated she knew there was an investigation and that I had spoken with other eo le and therefore I should know what happened at Epstein's house. ended the conversation and walked back into her boyfrien s usiness, Automotive. Det Caristo and I left the area and returned to t e police station. Investigation continues. ***************** ***** ******NARRATIVE # 41 ************************** NA Reported By: RECAREY, JOSEPH 4/10/06 Entered By.: ALTOMARO, NICKIE A. 4/10/06 A Grand Jury Session was requested during the month of February 2006, in which all the girls that had been interviewed would have been called to testify before the Grand Jury to seek an indictment against Jeffrey Epstein. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appear on myspace.com and speak about alcohol use and some marijuana use. The State Attorney's Office wanted time to review the material. I requested additional subpoenas from the State Attorney's Office in which I requested information from Dollar Rent a Car and Jet Aviation. The information requested from Dollar Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the victims. The other subpoena requested was for Jet Aviation for dates and times when Epstein's planes were in Palm Beach County. I continued to research other names that were acquired either from interviews or intelligence gathered during the investigation. I EFTA00232122

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 82 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) l located in Royal Palm Beach. I responded to . in Royal Beach. During the interview stated she knew I would be speaking with her. stated she was first introduced to Epstein when she turned eighteen years old. stated she was sure of her age as it was her senior year in High School. She advised she was brought there to ma e money an was told she would have to provide a massage to this Palm Beach guy. She remembered she met Epstein and his assistant in the kitchen area. She stated she was taken b one of her riends, She stated she went upstairs with while E stein got ready for the massage. He exited his bathroom na ed and turned around. Epstein asked her if being naked offended her. stated it made her uncomfortable. Epstein then put on a towel and lay on the table. stated she rubbed his back and feet. She stated she had no massage training or experience. stated during the massage, Epstein attempted to touch her buttocks. pulled away as he touched her buttocks. She told him again she was uncomfortable with him touching her. Epstein then cut the massage short and became upset with her. Epstein aid her $200.00 for the massage and told her to leave the house. never returned to the house. She did advise of one time she went with however she waited in the car for as she did not want to go into the house. At the conclusion of visit with Epstein they left the area. stated she had heard from other girls that have gone to the house t at Epstein now required them to do the massage naked and allow him to touch them in their private areas for monies. The interview was concluded as did not have any other information to provide. I then learned from the original victim, III the defense attorney had learned of her identity. I spoke with the father of the victim, who stated there has been a private investigator on his house photographing his family and chasin" visitors who come to the house. Illi He provided a Florida License of . This vehicle is registered to Ivan Robles of West Palm Beach. o es is a private investigator intern who is licensed by the state. I informed the State Attorney's Office of the above information. I received the Grand Jury subpoenas to be delivered to three victims for a Grand Jury session to be held on April 18, through April 20, 2006. Investigation continues. --******** ****** *******Tht***NA KK ATIVE # 42- * W**-****************** 4** NA Reported By: RECAREY, JOSEPH 4/14/06 Entered By.: ALTOMARO, NICKIE A. 4/18/06 The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5, 2006, at approximately 7:30 p.m., I personally served the parents of who had informed me that the private investigators were still irotographing the family. On April EFTA00232123

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 83 Time: 8:47:53 Incident Report Program: CMS301L Case No 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I served II at her residence in Royal Palm Beach. The subpoena was given to her mother, III. I learned through one of the victims III that she was personally contacted through a source that has maintained contact with Epstein. The source assured • she would receive monetary compensation for her assistance in not cooperating with law enforcement. II also stated she was told, "Those who help him will be compensated and those who hurt him will be dealt with." I told III that tampering with a witness/victim is an arrestable offense and very serious. I asked her who approached her during this encounter. II originally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends. On April 11, 2006, Det Dawson and I traveled to Tallahassee, Florida and met with the victim, III identified W/F, as the personlilo approached her in Ro a Pa m Beach while s e was ome during Spring Break in March 2006. also stated she did not want to pursue the intimidation charges on II was concerned that the defense attorney was given a copy of the report as certain things she had told me in confidence were repeated to her by subpoena for the Grand Jury which was scheduled to commence April 18, Prior to our departure, the victim was given a copy of her 2006. upon our return from Tallahassee, I notified the State Attorney's Office of what was told to me. I also notified them that the subpoenas were delivered to the witnesses and they would be calling for arrangements for the date and time needed for the Grand Jury. I spoke with ASA Weiss and informed her of the possible intimidation by the defense. On April 13, and April 14, 2006 I attempted contact on several occasions with ASA Weiss and ASA Belohlavic to ascertain when the victims needed to report for Grand Jury testimony. Messages were left on their voicemail. On April 17, 2006, during the hours of 9:00 am and 11:30 am, I again left messages for ASA Weiss and ASA Belohlavic for either of them to return my call as I had not heard from the State Attorney's Office as to the time and date of the Grand Jury. At approximately 12:30 pm, I went to the State Attorney's Office and located ASA Weiss and ASA Belohlavic in their offices. I entered ASA Belohlavic's office who informed me that she was going to return my call. She explained that an offer was made to the defense, Atty Guy Fronstin and Atty Alan Dershowitz. The offer is 1 count of Agg Assault with intefft—to commit a felony, five years probation, with adjudication withheld. Epstein would have to submit to psychiatric/sexual evaluation and no unsupervised visits with minors. When asked about the all the other victims, ASA Belohlavic stated that was the only offer made as to one victim, ASA Belohlavic cell phone rang and went to voice mail. She chilled her voice mail and played the message on speaker. The caller identified himself as EFTA00232124

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 84 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) Atty Guy Fronstin and acknowledged the deal made between them. Fronstin stated in the message, he spoke with his client, Jeffrey Epstein, and agreed to the deal. Fronstin asked to call off the grand jury as they would accept this deal. Belohlavic stated a probable cause would be needed to book Epstein in the county jail and would let me know as to when it would be needed. I explained my disapproval of the deal and not being consulted prior to the deal being offered. However I expressed that was only my opinion and the final approval would come from the Chief of Police. She explained to have Chief Reiter call Barry Krisher about the deal. I left the area and returned to the police station where I briefed the Chief about the deal offered. I checked my voice mail messages and discovered a message from III stepmother for the victim She was calling because the State Attorney's Office still ha not returned any of her calls as to when they are needed for this case. I then called ASA Belohlavic's office and left messages for her to call the victims on this case and explained to them what the State Attorney's Office had done. On April 17, 2006, at approximately 4:30 pm, State Attorney Investigator Tim Valentine called to officially notify me of the cancellation of the Grand Jury. He requested I contact the victims that had been served to appear, to notify them of the cancellation. I advised Valentine that as this Grand Jury session was called based on the State Attorney's Office decision to have the victims heard by the Grand Jury that I felt it was the States Attorney's Office responsibility to contact the victims and advise them of the reason they were no longer needed. ****************************NARRATIVE # 43 ************************** NA Reported By: RECAREY, JOSEPH 5/04/06 Entered By.: ALTOMARO, NICKIE A. 5/04/06 As I had not received any contact from anyone at the State Attorney's Office, on May 1, 2006, I prepared three arrest warrant requests and submitted them to the State Attorney's Office. The packages were delivered to the Crimes against Children Unit in care of ASA Lana Belohlavek. Jeffrey Epstein's arrest warrant was requested for 4 counts of Unlawful Sexual activity with certain minors and one count of Lewd and Lascivious Molestation. , Epstein's assistant's, arrest warrant request was for 4 counts of Principal in the 1st degree Unlawful Sexual activity with certain minors and one count of Principal in the 1st degree Lewd and.Lascivioua Molestation arrest warrant request was for Lewd and Lascivious Acts on a victim under 16 years of age. The receipt of delivery was signed and brought back to the records division at the police department. On May 3, 2006, at approximately 2:54 pm, I received a telephone call from ASA Daliah Weiss on my cellular telephone. ASA Weiss advised she EFTA00232125

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Time: 8:47:53 Page: 85 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired from representation. ASA Lana Belohlavek has been assigned the case. ASA Weiss stated she can no longer speak about the Epstein case with me. i thanked her for her telephone call. ASA Weiss further stated that ASA Belohlavek would be calling me. ****************************NARRATIVE # 44 ***** ********************* NA Reported By: RECAREY, JOSEPH 5/15/06 Entered By.: ALTOMARO, NICKIE A. 5/15/06 On May 10, 2006, information was received that Epstein's associate, Leslie Wexner, The Limited Inc, CEO's, plane had arrived in West Palm Beach, PBIA. The plane, a Gulfstream 4 bearing a N900LS registration, was on the tarmac at Galaxy Aviation. As Epstein had recently acquired the services of a new attorney, and the fact that Epstein's house is currently under remodeling, it was believed that Epstein may be in Palm Beach. I conducted physical surveillance at the residence, 358 El Brillo Way. I observed a large construction crew conducting remodeling at the house. The contractor, David Norr, was observed driving a Ford Eiiiiiir, white in color. The vehicle has a Florida registration of . Norr left Epstein's house and traveled north on County Road. Det Caristo and I conducted surveillance on Norr. Norr traveled to several construction sites and checked on certain jobs. Surveillance was discontinued on Norr and Det Caristo and I traveled to Galaxy Aviation. I observed the white plane with a blue stripe along the body and tail of the plane; the tail number was visible on the bottom of the tail, closer to the body of the plane. We maintained visual surveillance on the plane until 4:57 p.m., when a caravan of Cadillac Escalades drove onto the tarmac. We observed several people exit the vehicles and discovered that they were part of the executive team for Limited Inc. The executives were in Palm Beach County for an executive meeting for the day. They arrived in Palm Beach County on May 9, 2006 at 9:30 pm and were scheduled to leave on the 10th at 5:00 pm. On May 12, 2006, I met with ASA Lana Belohlavek at the State Attorney's Office. She explained that her boss, Barry Krischer, was requesting this case be taken to the Grand Jury again. I e lained to her I had re ested arrest warrants for Jeffrey Epstein, and I asked that she either issue the warrants or direct ile, as so much time has elapsed since the original request to the Grand Jurys___I__explained that the Palm Beach-.Police Department-had- concluded the case in December of 2005 and has been waiting for the case to go forward. Belohlavek stated the original offer was again offered to the new defense attorney. She was waiting for their answer by Friday May 19, 2006. She stated she would advise me of the answer. **************************** NA NARRATIVE # 45 ************************** Reported By: RECAREY, JOSEPH 6/05/06 EFTA00232126

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 86 Time: 8:47:53 incident Report Program: CMS301L Case No • 1-05-000368 Entered By.: ALTOMARO, NICKIE A. (Continued) 6/06/06 On May 222_2006, I received several phone calls throughout the day from Mr. II who stated he had been followed aggressively by a private investigator. Mr. stated that as he drove to and from work and running errands throughout the county, the same vehicle was behind him runnim other vehicles off the road in an attempt not to lose sight of Mr. III vehicle. I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. I also explained to him that there was a meeting scheduled with ASA Lana Belohlavek and Attorney Jack Goldberger at Mr. Krischer's office scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA Lana Belohlavek to inform her of the private investigators following Mr. G however; she was on her vacation during the week of May 22 through May 30 2006. On May 23, 2006, I received other phone calls from Mr. and Mrs. I who advised they were able to acquire the private investigators license plate information. The subject following them was again driving very aggressively and caused Mrs. to run off the road. Mrs. stated the vehicle is a green Chevy Monte Carlo bearing Florida tag The vehicle is registered to Zachary Bechard of Jupiter Florida. Bechard is employed with Candor Investigations from Jupiter, Florida. Bechard is a licensed Private Investigator in the State of Florida. Since the discovery of the threat made against one of the victims in this case III i re ested subpoenas for all calls made to and received from during the month of March 2006 for her cell phone and ome phone. I had confirmed with Florida State University the exact dates of Spring Break for 2006. The Spring Break was from March 4, 2006 through March 12, 2006. I received a subpoena from Sprint/Nextel with all calls made during the month of March 2006. I reviewed the 989 calls made and received during the month of March 2006. I observed on March 7, 2006, made and received thirty five calls during that day. Date Time Seconds 7-Mar-06 11:03 AM 492 7-Mar-06 11:16 AM 6 7-Mar-06 11:22 AM 887.2 7-Mar-06 11:37 AM 48 7-Mar-06 11:39 AM 28.2 7-Mar-06 12:02 PM 727.2 In/Out Outbound Inbound Inbound Outbound Inbound Inbound To/From The table reflects the date of the calls, time of day (EST), duration EFTA00232127

Date: 7/25/06 PALM BEACH POLICE DEPARTMENT Page: 87 Time: 8:47:53 Incident Report Program: CMS301L Case No • 1-05-000368 (Continued) of call in seconds, inbound or outbound calls and calls made to or from phone. On March 7, 2006, at 11:03 am, made a call to the victim II which lasted 492 seconds (8 minutes an 2 seconds). The victim then returned the call at 11:16 am which lasted 6 seconds. The victim then made contact with at 11:22 am for 877.2 seconds (14 minutes and 6 seconds). These sequences of calls were consistent with what the victim had described to me on the date of the intimidation. Immediately after speaking with the victim, makes a call to , Epstein's assistant, which lasts for forty-eight secon s. A call is then immediately received, a telephone number registered to a Corporation affiliated with Jeffrey Epstein located at 457 Madison Ave in New York. An extensive computer check revealed 457 Madison Ave is a business address in which Epstein has his corporations assigned to. Epstein had corporation attorney, Darren Indyke, register the businesses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corporate number which lasts 12 minutes and 1 second. It should be noted that there is no further contact with either the victim during the month of March or A ril of 2006. I also noted that there was no further contact with or Jeffrey Epstein during the remainder of the month of March or April 2006. On June 1, 2006, ASA Lana Belohlavek telephoned me to inform me of the meeting that occurred with Atty. Jack Goldberger and her reference this case. She advised she would make her determination on whether to file on this case or not by Monday June 5, 2006. Inv Continues. ****************************NARRATIVE # 46 ************************** NA Reported By: RECAREY, JOSEPH 7/12/06 Entered By.: ALTOMARO, NICKIE A. 7/12/06 On June 29, 2006, I had spoken to ASA Lana Belohlavic who informed me that the case would be sent to the Grand Jury for charges. She informed me that the grand jury would convene on July 19, 2006 to hear the Epstein case. Belohlavic stated State Attorney Barry Krisher made the determination to go the Grand Jury to hear the case. On July 12, 2006, I spoke with Mrs.. mother of the victim, III who inquired about the status of the case. I explained to her that__I_was _ told we would be going to the Grand Jury during the week of July 19, 2006. She stated she had not been contacted as of yet by the State Attorney's Office for any information. I provided her with the telephone numbers to the State Attorney's Office. Investigation continues... * * * * * * * * * * * * * * * * END OF REPORT * * * * * * * * * * * * * * * * * EFTA00232128

EFTA00232129

07/27/2006 THU 16:22 FAX 07/25/2006 15:44 5618354700 rain.; immining A TRUE BILL IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL. CIRCUIT OF THE STATE OF FLORIDA For Palm Beach County, at the Spring Term thereof, in the yoar of our Lord Two Thousand and Six, to-wit The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31, 2005, did solicit. Induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to Florida Statute 796.07(1) on three or more occasions between August 01, 2004 arid October 31. 2005. contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL){LEVEL 1) against the form of the statute, to the evil example of aft others. and against the peace and dignity of the State of Fbrtda. I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law. Assistant State Attorney of the Fifteenth Judicial Circuit of the State of Florida, prosecuting for the said - State EFTA00232130

07/27/2006 THU 18:23 FAX 07/26/2066 15:44 5510354700 PBPD 1MAINiNU • GRAND JURY FOREPERSON DATE Jeffrey E Epstein, Race: White, Sex: Male, DOB: Issue Warrant EFTA00232131

EFTA00232132

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN and Defendants. :me °D4° July 18, 2008 STEVEN M. LARIM0111 CLERK U4. DIST. CT. 5. 0. Of FLA. • MIAMI NOTICE OF REMOVAL In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(aX1), the defendants, Jeffrey Epstein, and hereby remove this action ) from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical lawsuit in this Court. Sec Jane Doe HI v. Epstein, Case No. 08 cv 80069 KAM (SD. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Ha. 15th Cir. Ct. filed Mar. 6, 2008). Lewis Teinn. 3059 Quo Avuin.San 345 Cattssa Gitovt, Fume. 33133 1 51310 EFTA00232133

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 2 of 100 Jan. 24, 2008) (the "First Federal Action"). The First Federal Action named Jeffrey Epstein as the sole tortfeasor, made the identical operative allegations as the instant Amended Complaint, and demanded damages of $50 million. (The amount of the demand against Epstein is evidently the product of recent reports in the press that Epstein is wealthy.) The First Federal Action was quickly followed by a series of substantially identical "Jane Doe" lawsuits, all filed by the same attorney in a three-month span. Compare Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed Jan. 24, 2008), with Jane Doe #2 v. Epstein, No. 08-CV-80119-KAM (S.D. Fla. filed Feb. 6, 2008) (asserting identical causes of action based on the same operative allegations), Jane Doe #3 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed Mar. 5, 2008) (same), Jane Doe #4 v. Epstein, No. 08-CV-80380-KAM (S.D. Fla. filed Apr. 14, 2008) (same), and Jane Doe #5 v. Epstein, No. 08-80381-CV-KAM (S.D. Fla. filed Apr. 14. 2008) (same). On February 20, amid these filings, Jane Doe #1 was deposed in State of Florida v. Jeffrey Epstein, 502006CF009454AXXXMB (Fla. 15th Cir. Ct., filed Jul. 19, 2006), a parallel state-court criminal action. During that deposition, she made numerous admissions that completely undermined the allegations against Epstein that she had pled in her complaint. A copy of her deposition, with names 2 Lewis Fein N. 3059 GLOM AVINUI. %WTI 340. COCONVI halm 33133 2 of 316 EFTA00232134

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 3 of 100 redacted, is attached hereto (Exhibit A). Two days later, counsel for Jane Doe #1 filed a notice of voluntary dismissal without prejudice in the First Federal Action. See Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9. Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1 refilled her complaint in Florida Circuit Court as the instant case, adding two nominal defendants: Mr. Epstein's personal secretary, and one of Jane Doe #1's contemporaries. These defendants have nothing to do with the plaintiff's case against Mr. Epstein, except that the presence of as a defendant in this new case, because she is a citizen of Florida (Am. Comp). ¶ 4), would ostensibly prevent complete diversity? As discussed below, however, was named in the relied lawsuit only to destroy diversity jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 2 Defendant is a citizen of New York (Am. Compl. 1 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section 3509(k) of Title 18, United States Code, provides as follows: If, at any time that a cause of action for recovery of compensation for damage or injury to the person of a child exists, a criminal action is pending which arises out of the same occurrence and in which the child is the victim, the civil action shall be stayed until the end of all phases of the criminal arlion and any mention of the civil action during the criminal proceeding is prohibited. As used in this subsection, a criminal action is pending until its final adjudication in the trial court. 3 LeysFtin 3G59Guw mum,. Sun 340.Oxotito Gran, hone 33M 3 sots EFTA00232135

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 4 of 100 besides having nothing to do with the substantive allegations of the plaintiff's $50,000,000 case, is a community-college student with no assets whatever. Even if this case purports to identify a new (and strategically nondiverse) tortfeasor, the reified lawsuit is still directed against only one defendant—Jeffrey Epstein. Then and now, the operative allegations are the same: Jane Doe alleges that Jeffrey Epstein assaulted her "in violation of Chapter 800 of the Florida Statutes.i4 (Am. Compl. ¶ 18.) To sharpen her lawsuit, the plaintiff says she is seeking damages in connection with a "conspiracy" (Am. Compl. ¶ 22), a "plan" (Am. Compl. ¶ 32), a "scheme" (Am. Compl. ¶ 32), and an "enterprise" (Am. Compl. 1 32). These theories of liability, however, cannot be supported by the allegations in the Amended Complaint. Even if everything in the Amended Complaint were true, recovery against under any formulation, is impossible under Florida law. Focusing on the real parties to this controversy, the instant case could have (once again) been brought here in federal court—just like the four other "Jane 18 U.S.C. § 3509(k) (emphasis added). 4 Chapter 800, Florida Statutes, is entitled, "Lewdness; Indecent Exposure." 4 Lewis Temp 3059 GismAnonn, Wort 340,Cocordtt:GOOMFLOODA 33133 ♦x1311 EFTA00232136

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 5 of 100 Doe" lawsuits presently pending against Epstein, filed by this plaintiffs former lawyer. This case is properly removed to federal court, first, because there is complete diversity among the real parties-in-interest, second, because the amount in controversy exceeds $75,000, and third, because this Notice complies with the requirements of 28 U.S.C. § 1446. Discussion A. This case is properly removable because it falls within the original jurisdiction of the United States District Court for the Southern District of Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case today. Even though it was reconfigured to look like a state-court lawsuit, this action falls squarely within the bounds of the diversity-jurisdiction statute. See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original jurisdiction over cases where the amount in controversy [is more than $75,000] . . . and [when the controversy] is between citizens of different states"). 5 Lewis 'rein ri 3059GuADAvimist,Sunt 340,Caccour Gtove.ftota 13113 5 d 316 EFTA00232137

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 6 of 100 1. The amount in controversy in this action exceeds $75,000. This case is a duplicate of the First Federal Lawsuit. In that case, Jane Doe pled "damages in excess of $50 million." See Doe v. Epstein, No. 08-80069-ICAM (S.D. Fla. filed Jan. 24, 2008) (Compl. ¶ 6). That allegation is now deleted and the Amended Complaint substitutes a generic prayer for relief.5 It is clear, however, that Jane Doe still seeks more than $75,000 in damages. This case, precisely like the First Federal Action, seeks damages in connection with an alleged assault. (Ant. Compl. ¶¶ 16-19.) The Amended Complaint alleges that Jane Doe "has suffered and will continue to suffer severe and permanent traumatic injuries, including mental, psychological, and emotional damages." (Am. Compl. ¶ 19.) These are the identical injuries Jane Doe asserted in the First Federal Action, and are no less serious simply because pled under a state-court caption. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp. 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that the $75,000 threshold had been satisfied, and "clearly [surpassed]," based on "the nature of the injuries alleged" in the complaint). 5 The Complaint seeks damages for "[more than] ... $15,000? (Am. Compl. ¶ 6.) This boilerplate is routinely used in Florida pleading practice to trigger application of section 26.012, Florida Statutes, the statute that establishes the jurisdictional amount required for filing in Florida's Circuit Court (as opposed to County Court). 6 Lewis 3059 Gump Art Nut . Sum 341, Comm Giovt. NOM* 33133 Go1316 EFTA00232138

Case 9:08-cv-80804-KANI Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "[w]hen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent from the complaint that the amount in controversy exceeds the jurisdictional requirement." Williams v. Best Buy Co., Inc., 269 F.3d 1316, 1319 (11th Cir. 2001). This case meets that standard, and satisfies the first prong of diversity jurisdiction. 2. There is complete diversity among the real parties to this controversy. Diversity jurisdiction requires complete diversity. Carden v. Arkoma Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the diversity statute to require 'complete diversity' of citizenship." (citing Strawbridge v. Curtiss, 7 U.S. (3 Cranch) 267, 267-68 (1806))). See also MacGinnitie v. Hobbs Group, LLC, 420 F.3d 1234, 1239 (11th Cir. 2005) (stating that "[c]omplete diversity requires that no defendant in a diversity action be a citizen of the same state as any plaintiff"). As demonstrated below, this case satisfies the statutory requirement of complete diversity. (a) PlaintiffJane Doe is a citizen of Florida. (Am. Compl. 1 1.) 6 6 Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended ________compiaint.,Se.041184V--Y04-P-084-JuIr4,4008--(-reperting that "On his .vvy into cool t gut his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by 1)oc, who has since moved to another state."); Jane Doe Depo. at 77, 112 (indicating that 7 Lewitt Teinn. 3059 Gun Mt PM, lulu 340, cmowr GROW. (IOWA 33133 Tog 314 EFTA00232139

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 8 of 100 (b) Defendant Jeffrey Epstein is a citizen of the U.S. Virgin Islands' (c) Defendant is a citizen of New York. (Am. Comp!. ¶ 5.) 3. Defendant was fraudulently joined to defeat diversity. "A non-diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her. sister lives with her mother in Georgia); Affidavit of LaVogue at y I (stating, "I am the mother and natural guardian for Jane Doe #1" with jurat executed in Georgia before a Georgia notary), DE 4-2, Jane Doe No. l v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."). DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80069-Civ-Marra (1/29/08); Petition for Removal of Disability of Non-Age, at ¶¶ I, 2, 7 (filed "on behalf of S.D.G.," alleging that "The mother is Da[w]n Lavogue and her address is .... Ga.," and stating that "S.D.G. is also the unnamed party in a lawsuit filed by her father on her behalf in the 11.5. District Court for the Southern District of Florida, Case No. 08-80069, which was filed without the consent of the mother"), In re v. Case No. 50 2008 DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has since allowed it. Compare Lowery v. Ala. Power Co., 483 F.3d 1184, 1215-16, 1221 (11th Cir. 2007) (holding that jurisdictional discovery to determine citizenship upon removal is inappropriate), with Calecto v. BASF Constr. Chemicals, LLC, slip op., Case No. 07-60077-CIV-ZLOCH, 2008 WL 1840717, *I (S.D. Fla. Apr. 22, 2008) (ordering that parties "shall engage in jurisdictional discovery for the Court to determine the citizenship of BASF and whether it has subject-matter jurisdiction over this action"). 7 The Amended Complaint erroneously states that Jeffrey Epstein is a citizen of New York. 8 Lewin Teinn. 3010 Maw Ainsen,Sunt 340,Oxormart Coca, Flamm 31113 811319 EFTA00232140

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 9 of 100 Oct. 15, 2007) (Moreno, J.) (citing Riley v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 292 F.3d 1334, 1337 (11th Cir. 2002)); accord, e.g., Tedder v. F.M.C. Corp., 590 F.2d 115, 117 (5th Cir. 1979) (denying motion to remand where two resident defendants were joined for the fraudulent purpose of defeating federal jurisdiction). In this case, the plaintiff relies on her original allegations to support three causes of action against civil conspiracy (Am. Compl. ¶¶ 20-23); Intentional Infliction of Emotional Distress (Am. Comp!. ¶¶ 23-28); and civil RICO (Am. Compl. ¶¶ 29-34). These allegations, however, do not support these claims, or any other theory of liability that would allow recovery against Cl Parks v. The New York Times Co., 308 F.2d 474, 477 (5th Cir. 1962) (observing that "determination of fraudulent joinder is to be based on whether there was a real intention on colorable grounds to procure a joint judgment") (emphasis added).8 (a)Nonresident defendants have a right of removal. The removal statute was enacted specifically "to protect defendants." Legg v. Wyeth, 428 F.3d 1317, 1325 (11th Cir. 2005). Cf., e.g., Piquet v. Amoco Prod. Co., 513 F. Supp. 938, 941 (M.D. La. 1.981) (explaining that courts developed the fraudulent-joinder doctrine to protect "the right [of removal] granted to 8 In Bonner v. City of Prichard. 661 F.2d 1206, 1207 (11th Cir. 1981) (en banc), the -----Laieventh-Cifeklit-Goen-of-Appeals-adepted-as-binding-preeedent-all dvcisiuns of tllc former Fifth Circuit rendered prior to October 1, 1981. 9 LeSyjsjFein n. 3059 Gwe Sun 340. [Menu, GOOrt.ItOitrni. 33133 101319 EFTA00232141

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 10 of 100 [defendants] by . . . Congress"). In this case, by reconstituting her original federal lawsuit and refiling it in state Court, the plaintiff has clearly sought to avoid the strictures of the mandatory stay of this case that federal law requires under 18 U.S.C. § 3509(k).9 In federal court, pursuant to 18 U.S.C. § 3509(k), this action must be automatically stayed pending final disposition of an ongoing parallel criminal action against Mr. Epstein. See 18 U.S.C. § 3509(k) (providing that a parallel civil By filing in state court, the plaintiff's attorney has also evidently sought to avoid the clear command of our local rules forbidding public comment about the merits of a pending lawsuit. Compare S.D. Fla. Local Rule 77.2(7) ("A lawyer or law firm associated with a civil action shall not during its investigation or litigation make or participate in making an extrajudicial statement, other than a quotation from or reference to public records, which a reasonable person would expect to be disseminated by means of public communication if there is a reasonable likelihood that such dissemination will interfere with a fair trial and which relates to (a) Evidence regarding the occurrence or transaction involved. (b) The character . . . of a party .. . . (d) The lawyer's opinion as to the merits of the claims . . . ."), with Ricci—Leopold Home Page, http:// www.riccilaw.com (click on "Breaking News," then access the hyperlink entitled, 03/13/08 - Consumer Justice Attorney Ted Leopold Files Case to aid Jane Doe in seeking justice against sexual predator Jeffrey Epstein and his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida criminal statutes) and quoting the plaintiff's attorney "Ted Leopold, managing partner" as characterizing Epstein as "an extremely powerful and wealthy man," with "vast resources," who acted "in the vilest way" at his "lavish mansion" with "lurid fantasies" and inflicting "untold damage," and opining that he should "be held accountable;" also quoting the plaintiff's attorney as opining that "[t)his case is both about justice and making sure that a wealthy and powerful man knows that he is not above the law;" also quoting the plaintiff's attorney's view of the evidence that plaintiff "continues to endure emotional trauma daily") (Web site last visited July 17, 2008). 10 30S9Gtsuo MAIM, Sun, 340, Comm, Giovt,FlOadm 33133 le et 313 EFTA00232142

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 11 of 100 action arising from an alleged sexual assault of a minor "shall be stayed until the end of all phases of [any] criminal action") (emphasis added). In this case, there is a parallel federal criminal grand jury action pending in the Southern District of Florida, In re Grand Jury, No. (WPB) (S.D. Fla.), which arises out of the same allegations pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. Cf. Doe v. Francis, No. 5:03 CV 260 Mat/WCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds that "the language of 18 U.S.C. § 3509(k) is clear that a stay is required in a case . . . where a parallel criminal action is pending which arises from the same occurrence involving minor victims") (emphasis added). Even outside the context of a mandatory federal statute, "the Supreme Court [has] admonished [that] `the Federal courts should not sanction devices intended to prevent a removal to a Federal court where one has that right, and should be equally vigilant to protect the right to proceed in the Federal court." Legg, 428 F.3d at 1325 (citing Wecker v. Nat'! Enameling & Stamping Co., 204 U.S. 176, 186 (1907)). See also id. (observing that "Congress `did not extend [to defendants a right of removal] with one hand, and with the other give plaintiffs a bag of tricks 11 Lewis Tein PI 1059 GOADAvow Sun r 340. COCON-7 04:74. hum.. 13133 1101311 EFTA00232143

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 12 of 100 to overcome it"' (quoting McKinney v. Bd. of Trustees of Maryland Cray. Colt, 955 F.2d 924, 928 (4th Cir. 1992))). To protect a nonresident defendant's right of removal, a federal court will "determine the matter of jurisdiction" by examining "the true situation both as to parties and causes of action." Bernblum v, Travelers' Inc. Co., 9 F. Supp. 34, 35 (W.D. Mo. 1934) (emphasis added). See also id. (observing that "[Ole federal courts will . . . strike out the fiction injected into a case by a party to prevent removal"). In accordance with these principles, a plaintiff cannot destroy diversity jurisdiction simply by conjuring up a nondiverse defendant; there must be at least some "possibility that the state law might impose liability on [the nondiverse] defendant under the circumstances alleged in the complaint." Florence v. Crescent Res., LLC, 484 F.3d 1293, 1299 (11th Cir. 2007) (citations omitted). See also, Holloway v. Morrow, No. 07-0839-WS-M, 2008 WL 401305, at *5 (S.D. Ala. Feb. 11, 2008) (emphasizing that "'Mlle potential for legal liability. must be reasonable, not merely theoretical" (quoting Legg v. Wyeth, 428 F.3d 1317, 1325 n.5 (11th Cir. 2005))) (emphasis added). In this case, the plaintiffs have tried to whip Jane Doe's original, one- defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 12 n 3059 MIAS° Amkut.$44ti 340. CoccoanGtovi,404443433133 12 dile EFTA00232144

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 13 of 100 complaint contains four claims for relief, the first and second claims state only one cause of action") (emphasis added). Using her original allegations and adding nothing, Jane Doe has tried to add claims against for civil conspiracy (Am. Compl. ¶¶ 20-23), Intentional Infliction of Emotional Distress (Am. Compl. ¶¶ 24-28), and civil RICO (Compl. ¶¶ 29-34) in order to append a nondiverse defendant to her Complaint. These claims, however, are untenable under Jane Doe's own allegations, and therefore cannot be used to destroy diversity jurisdiction. (b) There is no possibility that the plaintiff can establish a cause of action against under Florida law. (i) The conspiracy claim against must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 (Ha. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. CI Churruca v. Miami Jai-Alai, Inc., 353 So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily ... no independent tort for conspiracy," there is a narrow exception to this rule when "the plaintiff can show some peculiar power of coercion possessed by the conspirators by virtue of their combination") (emphasis added). See generally Liappas v. Augoustis, 47 So. 2d 582, 583 (Fla. 1950) (observing that "'instances of conspiracy which is in itself an independent tort are rare and should be added to with caution" (quoting Fleming v. Dane, 22 N.E.2d _609,41-1-,-(Mass,1939-M-(emphaffis-added). Plainlyithis-ctbe involvcb die geucral rule, not the narrow exception, because only one person could have caused Jane Doe's injuries. CI Martin v. Marlin, 529 So. 2d 1174, 1179 (Fla. 3d DCA 1988) (upholding 13 Lewis 30$9GweAvoug, Sun( 340.03conta Griot CiaiuoA 33133 11.1311 EFTA00232145

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 14 of 100 Here, Jane Doe cannot assert a cause of action for "violation of Chapter 800, Florida Statutes" (Am. Compl. ¶ 18) because there is no private right of action under that Chapter. See generally Am. Home Assurance Co. v. Plaza Materials Corp., 908 So. 2d 360, 374 (Fla. 2005) (observing that "not every statutory violation carries a civil remedy" (citing Villazon v. Prudential Health Care Plan, Inc. 843 So. 2d 842, 852 (Fla. 2003))). See also, e.g., Miami Herald Publ'g Co. v. Ferre, 636 F. Stipp. 970 (S.D. Fla. 1985) (King, C.J.) (holding that violation of Florida's criminal extortion statute does not give rise to a civil cause of action for damages); Mantooth v. Richards, 557 So. 2d 646, 646 (Ha. 4th DCA 1990) (per curiam) (affirming dismissal of plaintiffs claim for parental kidnapping where "the mentioned statutes concern only criminal violations and do not afford a civil remedy") (citation omitted) (emphasis added); Wright v. Yurko, 446 So. 2d 1162, 1 165 (Ha. 5th DCA 1984) (holding that "[a]n act which does not constitute a basis for a cause of action against one person cannot be made the basis for a civil action for conspiracy"). In this case, Jane Doe's claim under Count H (civil conspiracy) fails because it derives exclusively from Count I (violation of Chapter 800, Florida Statutes). Cf grant of summary judgment against claim for independent conspiracy, noting that "lwihen the concerted acts of the defendants do not create a greater harm than if the acts v‘ ere committed by one person alone. then there can be no recovery"). 14 Lewis "rein it 3059 GuNoAvmvt,Suirt 340.,Cccaivr Grow. FLORIDA 33133 14 of 31$ EFTA00232146

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 15 01 100 Buchanan v. Miami Herald Publg Co., 230 So. 2d 9, 12 (Fla. 1969) (holding that where Count I of the complaint had failed to state a cause of action for malicious prosecution, there could be no civil-conspiracy claim in Count II "based on the allegations of Count I"). Because the statute she expressly pleads as the basis for Count 1, Chapter 800, Florida Statutes, provides no civil remedy, Jane Doe cannot prevail on Count I. Therefore, she cannot prevail on her claim for conspiracy (Count II) to violate Chapter 800, Florida Statutes (Count I). (ii) The plaintiff cannot prevail against nondiverse defendant on her claim for Intentional Infliction of Emotional Distress (IIED). Even if the plaintiff, for the sake of argument, can assert an IIED claim against Jeffrey Epstein, the plaintiff still does not have a cause of action for IIED against First, the plaintiff cannot recover damages in connection with her own illegal conduct; and second, the plaintiff's purported IIED claim fails as a matter of law. 15 I e.s r8 Tein ri. 3059 Gum/A.44K Sum 340.CocordurGtovtitomm 13133 IS al 314 EFTA00232147

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "brought Jane Doe to Epstein's mansion in Palm Beach" to help the plaintiff execute her own plan. (Am. Compl. ¶ 13.) Yet, the plaintiff's plan was illegal: under Florida law, it is a crime "to practice massage" without a license. § 480.047, Fla. Stat. (1997). To say it another way, the plaintiff admits that she went to Mr. Epstein's house to commit a crime. Based on these allegations, it is clear that the plaintiff seeks damages in connection with her own illegal conduct, this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 ( I I th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support a finding of fraudulent joinder). This conclusion is supported by well-established principles. Under Florida law, a plaintiff cannot recover damages flowing from her own illegal conduct. See v. 93 Fla. 709, 112 So. 622, 628 (1927) (referring to "the universal rule of our law that one in a court of justice cannot complain . . . of another's wrong whereof he was a partaker") (internal quotation marks and citation 16 Lets Tein n. 3059 Goma Aviout. Soot 340, Craw' Gion, Co w13133 II of ills EFTA00232148

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 17 of 100 omitted) (emphasis added); Turner v. Anderson, 704 So. 2d 748, (Fla. 4th DCA 1998) ("[N]o public policy should allow appellant to recover damages as a result of engaging in criminal conduct such as occurred in this case."). Cf. Ewe!! v. Daggs, 108 U.S. 143, 149 (1883) (stating that "Injo court will lend its aid to a [plaintiff] who founds [a) cause of action upon an immoral or an illegal act'") (quoting Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that this policy is "not for the sake of the defendant, but because [the courts] will not lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) (emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) (Harris, J., concurring) (remarking in the context of an action brought against an alleged prostitution house that "the court should continue its tradition of not interceding in civil conflicts involving transactions that are either illegal or are against public policy"). Based on the foregoing, the plaintiff cannot blame someone else (= for the consequences of her own criminal conduct. CI Feld & Sons, Inc. v. Pechner, Dorfman, Wolfe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super. Ct. 1983) (holding that law-firm clients could not recover damages flowing from their own criminal acts, even though clients' lawyers had suggested the unlawful conduct to begin with). See also Turner v. Anderson, 704 So. 2d 748, 751 (Fla. 4th 17 LevSTsin n 3059 Gime Mom, Sun HO, Cocann Coon, ftwoo. 33133 IT of 310 EFTA00232149

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 18 of 100 DCA 1998) (approving reasoning in Feld (Cr Sons, holding that "no public policy should allow [a plaintiff] to recover damages as a result of engaging in criminal conduct" where the plaintiff had provided false testimony at an arbitration proceeding). 2. The plaintiffs LIED claim fails as a matter of law. To state a cause of action for LIED, a complaint must allege four elements: I I ) deliberate or reckless infliction of mental suffering; (2) outrageous conduct; (3) the conduct caused the emotional distress; and (4) the distress was severe. Metro. Life Ins. Co. v. McCarson, 467 So. 2d 277, 278 (Fla. 1985). Whether conduct is outrageous enough to support a claim of intentional infliction of emotional distress is a question of law, not a question of fact. Liberty Mut. Ins. Co. v. Steadman, 968 So. 2d 592, 595 (Fla. 2d DCA 2007) (citations omitted). In this case, without reaching the question of "outrage," the plaintiff has failed to show that conduct - - allegedly arranging an illegal sexual massage that the plaintiff herself agreed to perform - - itself caused the plaintiff to suffer any emotional distress. Even if the alleged agreement was fraudulently induced, the plaintiff's TIED claim flows from Epstein's alleged conduct, not the joint conduct of and Doe in planning the massage. 18 Lewis 'rein a 3059 Gine° Avinia, Sint 340, (=Mr Glen, 1IOMM 33133 11 o1318 EFTA00232150

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 19 of 100 (iii) The plaintiff cannot prevail on her claim for civil remedies for criminal practices or racketeering ("civil RICO") pled in Count IV. A cause of action under section 772.104, Florida Statutes ("Civil Remedies for Criminal Practices") requires a showing of direct injury. Even assuming for the sake of argument that Jane Doe can establish that the defendants engaged in a "pattern of criminal activity," she cannot establish that she was directly injured by those activities. Section 772.104 allows someone to bring a civil RICO claim only if "he or she has been injured by reason of any RICO violation. § 772.104, Fla. Stat. (2007). Here, the allegations in Count IV, even if they are true, do not add up to a civil RICO claim because there is no proximate cause between the purported "pattern of criminal activity" and Jane Doe's alleged injuries. In a doomed attempt to satisfy the extremely high burden of pleading civil RICO under Florida law, the Amended Complaint lists a series of violations rooted in Florida's prostitution statutes. (Am. Compl. ¶ 31.) According to the Amended Complaint, the defendants participated in a criminal enterprise . . . or conspir[acy]" (Am. Compl. ¶ 30) over an unspecified length of time "to repeatedly find and bring [Jeffrey Epstein] underage girls . . . in order for Epstein to solicit, coerce, entice, compel, or force such girls in acts of prostitution and/or lewdness" (Am. 19 Lewis yein n. 3059 GKAPC Anhui, yull I 340, CocoNuT Gw/vt.FtWODA 33133 1901116 EFTA00232151

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 20 of 100 Comp!. ¶ 32). The alleged "pattern of criminal activity" comprises violations of Chapter 796, Florida Statutes—the chapter that proscribes various crimes of prostitution:3 These allegations do not tie directly into Jane Doe's alleged psychic injuries. In contrast to a cognizable RICO claim, this action concerns only an isolated occurrence. More important, the alleged injuries in this case are pled to have resulted from an alleged sexual assault, an assault "in violation of Chapter 800 of the Florida Statutes" (Am. Compl. 1 18)—not anything having to do with the facilitation of prostitution, or more succinctly, the violation of Florida's prostitution law. Civil RICO claims are extraordinarily difficult to plead successfully. There are examples in the case law of RICO claims stemming from a prostitution enterprise, but they are vastly different from what plaintiff pleads here. They involve, for example, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Balas v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution," 13 The Amended Complaint alleges a "pattern of criminal activity" comprising the following criminal violations: §§ 796.03, 796.07(2Xf), 796.07(2Xh), 796.045, and 796.04, Fla. Stat. (Am. Comp!. ¶ 31.) 20 Lewis 'rein it 1059 G Pao A‘INW, Sun13n0,CucnwrGAM, itIMOA 33133 30 at Mil EFTA00232152

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 21 of 100 where petitioners alleged that they had "suffered emotional pain, anguish, humiliation, insult, indignity, loss of self-esteem, inconvenience, hurt and emotional distress" as a result of being forced repeatedly, over time, to "perform sexual acts to retain their employment"). Here, even if the Amended Complaint can be read to plead that the defendants schemed to solicit other massages from other people (see, e.g., Am. Compl. 111 9, 11, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas YBambu, S.A. v. F..I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . wit! not allow recovery under Florida RICO."' (quoting O'Malley v. St. Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-injury requirement under Florida's RICO law, Jane Doe has failed to allege a cause of action against for violation of section 772.103, Florida Statutes. B. This Notice satisfies the procedural requirements of 28 U.S.C. § 1446. 1. This notice of removal is timely. In accordance with 28 U.S.C. § 1446, this notice of removal is timely. Only defendant Epstein has been served with process. Defendants and 21 LeAxika !!!!!! 1059G...two Avom.Sum 140,Cof own Gnow,hotsm 33131 21 of 311 EFTA00232153

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 22 of 100 have not yet been served. In a multi-defendant lawsuit, removal is timely when effected within 30 days after the last defendant is served. See Hill Dermaceuticals, Inc. v. RX Solutions, United Health Group, Inc., No. 6:08-cv-330-Or1-31KRS, 2008 WL 1744794, at *3 (M.D. Ha. Apr. 11, 2008) (concluding that removal petition was timely where it was filed within 30 days after the last defendant was served). 2. Notice has been given, and state-court papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are authorized to represent that all of the defendants join this Petition and consent to removal. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently joined parties, and the amount in controversy exceeds $75,000, exclusive of interests and costs, this Court has original jurisdiction over this action pursuant to 28 U.S.C. § 1332(a)(1). 22 L.evyjp: in rs. 3029 Goma Avow.. Soot 340, (Mow, Wore, Rosa 33133 22 of 316 EFTA00232154

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 23 of 100 WHEREFORE, the Defendants, Jeffrey Epstein, and remove this case from Palm Beach Circuit Court to the United States District Court for the Southern District of Florida. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove. Florida 33133 Tel: Fax: By: GUY A. LEWIS Fla. Bar No. MICHAEL R. TEIN Fla. Bar No. ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach. Florida 33401 Tel. Fax. By: Jack A. Goldbet.• Fla. Bar No Attorneys for Defendant Jeffrey Epstein 23 Leayip ysiri 3039 Gw.o Avow', Sum 340. Cocosul Geod. FICIOSOA 33133 23 o1316 EFTA00232155

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 24 of 100 CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing document is being served this day, July 18, 2008, on counsel of record identified on the service list by U.S. Mail. re: Michael R. Tein 24 Lewis rein.. 3059GuaoAvinue, 5u0e 340,Coccom GAOVI.FLORW 33113 x40311 EFTA00232156

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 25 of 100 Service List Theodore J. Leopold, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: Counsel for Plaintiffiane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya, P.A. Centurion Tower 1601 Forum Place, Suite 1110 West Palm Beach Florida 33401 Fax. III Counsel for Defendant Bruce E. P . Bruce E. , P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 Fax. Counsel for Defendant Robert D. Critton, Esq. Michael J. Pike, Esq. Burman, Critton, Luttier & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach, Florida 33401 Fax. Co-Counsel for Jeffrey Epstein 25 Lewis Fein ,. )059 Gana An Nut. SuOT 340, CoOmul fitOvt. ?Iota 13)33 2$ of 3t1 EFTA00232157

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 26 of 100 EXHIBIT A 2001316 EFTA00232158

r Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 27 of 100 nsor & Associates Rcpniap slid Tummy:in% Inc. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006 CF09454AXX STATE OF FLORIDA, JEFFREY EPSTEIN, Defendant. DEPOSITION OF Wednesday, February 20, 2008 2:00 p.m. - 4:30 p.m. Palm Beach County Courthouse 205 North Dixie Highway West Palm Beach, Florida 33401 Reported By: Judith F. Consor, FPR copy Notary Public, State of Florida Consor & ASsociates Reporting and Transcription Phone - Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 atom EFTA00232159

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 28 of 100 nsor & Associates Repanitv and Transcripline. lnc Page 2 1 APPEARANCES: 2 On behalf of the State: 3 LANNA BELOHLAVEK, ESQ. ASSISTANT STATE ATTORNEY 4 401 North Dixie Highway West Palm Beach, Florida 33401 5 561.355.7100 6 On behalf of the Defendant: MICHAEL R. TEIN, ESQ. 7 KATHRYN A. MEYERS, ESQ. LEWIS TEIN, PL 8 3059 GRAND AVENUE, SUITE 340 COCONUT GROVE, FL 33133 9 On behalf of the Defendant: 10 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 11 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 12 WEST PALM BEACH, FLORIDA 33401 13 14 ALSO PRESENT: ON BEHALF OF THE WITNESS: THEODORE J. LEOPOLD, ESQ. 15 KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL-EZE 16 17 :8 19 20 21 22 23 24 25 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 280 3% EFTA00232160

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 29 of 100 sor & Associates Rep/irons and Traucripuna, 1 2 3 INDEX WITNESS: Page 3 PAGE: DIRECT EXAMINATION 4 4 BY MR. TEIN: 5 6 7 NOEXHIBITS MARKED - 23 24 25 Page - CERTIFIED QUESTIONS Line 53 22 55 1 59 2 111 14 112 2 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232161

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 30 of 100 nsor & Associates Ropm.ans and iraftscdpro. 1.714 16 7 18 O. Thank you. 19 May I call you 4111W 20 A. Uh-huh. 21 Q. going to ask you a few 22 questions, several questions today. If at any time you 23 wan: to take a break, you just let me know. Okay? 24 A. Okay. 25 O. If you at any time don't understand one of Page 4 1 Deposition taken before Judith F. Consor, 2 Court Reporter and Notary Public in and for the State of 3 Flsrida at Large, in the above cause. 4 5 Thereupon, 6 7 having been first duly sworn or affirmed, was examined 8 and testified as follows: 9 THE WITNESS: I do. 10 DIRECT EXAMINATION 11 BY MR. TEIN: 12 O. Good afternoon. Please tell me your full 13 naue. 14 A. 15 0. And can you please spell it. A. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 30 of 3l EFTA00232162

Case 9:08-cv-80804-KAM ent 1 EnteredonFLSDDocket07/21/2008 Page 31 of 100 nsor & Associates Ruportias and Tractscriptice. lac Page 5 1 my questions, will you just please let me know? 2 A. Yes. 3 Q. And if at any time you're not feeling well 4 or something like that, you'll tell us, right? 5 A. Yes. 6 Q. Do you feel okay today? 7 A. Yes. 8 Q. Not taking any alcohol or drugs or anything 9 like that, right? 10 A. No. 11 0. So you feel ready to have your deposition 12 taken? 13 A. Yes. 14 Q. what is your address? 15 A. I'm currently living at my aunt's house and 16 I don't know it off the top of my head. 17 Q. Where is it? 18 A. In Jupiter. 19 Q. Who is your aunt? 20 A. 21 Q. Who else is living there? 22 A. a my uncle. 23 24 25 Q. A. Q. Anyone else living there? No. The contempt motion that your mother filed Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 I 31 4:4316 EFTA00232163

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 32 of 100 nsor & Associates Rep/min; and Transcription. inc. Page 6 1 against your father regarding your fifty million-dollar 2 lawsuit against Jeffrey Epstein says that you live with 3 your aunt and uncle and have been living there; is that 4 correct? 5 A. Yes. 6 Q. How long have you been living with your 7 aunt and uncle? 8 A. Since my father kicked me out. 9 Q. That was Thanksgiving of this past year? 10 A. Yes, sir. 11 Q. Okay. Didn't your firefighter boyfriend 12 get an apartment for the two of you? 13 A. No, sir. He has an apartment, but by 14 himself. 15 Q. Did he get an apartment for the two of you 6 to live in? 17 A. No, sir. 18 Q. Are you planning to move in with him? 19 A. Maybe one day in the future. 20 Q. Do you have a plan to move in with him 21 presently? 22 A. No. 23 Q. Have you been to the apartment that you and 24 have discussed moving in together? 25 A. I have been to the apartment. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 32 el 316 EFTA00232164

Case 9:08-cv-80804-KAM ent 1 EnteredonFLSODocket07/21/2008 Page 33 of 100 nsor & Associates tiertaniqf and transcriptim Inc 1 2 3 Q. Q. Where is that? A. Palm Beach Lakes. Have you spent the night over there? Page 7 4 A. No, sir. 5 Q. Do you know the address there? 6 A. I do not. 7 Q. Isn't your sister planning on living 8 with you and at 9 A. No. 10 Q. llIR you know that this court case is a 11 criminal prosecution, correct? 12 A. Correct. 13 Q. And you know that it's a criminal 14 prosecution against a man who has no criminal background. 15 Do you know that? 16 A. I do now. 17 Q. You agree that court is a very serious 18 matter? 19 A. Yes. 20 Q. And you're here with your lawyer 21 Mr. Leopold, right? 22 A. Yes. 23 Q. And you know that Mr. Leopold recently 24 filed a lawsuit in federal court against Jeffrey Epstein, 25 seeking fifty million dollars. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 13.1316 EFTA00232165

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 34 of 100 nsor & Associates aornrtiap and Tratsctipoto. lac. Page 8 1 MR. LEOPOLD: Let me just object. 2 let me instruct you. Anything that 3 you have learned through conversations between you 4 and me are protected. So if you know any of that 5 information outside of those discussions, you may 6 answer. But if the only way you know it is 7 through our discussions, do not answer that 8 question. 9 BY MR. TEIN: 10 Q. IIIII1 you know that Mr. Leopold recently 11 filed a lawsuit in federal court on your behalf against 12 Jeffrey Epstein seeking fifty million dollars? 13 MR. LEOPOLD: Same objection. 14 If you know the answer to that outside of 15 our discussions, you may answer. If it is the 16 only way that you know the answer is through our 17 discussions, do not answer that question. 18 THE WITNESS: Okay. 19 MR. LEOPOLD: Attorney/client privilege. 20 BY MR. TEIN: 21 Q. You can answer the question unless -- 22 MR. LEOPOLD: Same objection. 23 MR. TEIN: Let me finish. 24 MR. LEOPOLD: Excuse me. We're -- 25 MR. TEIN: No. Let me finish. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 34 of Mt EFTA00232166

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 35 of 100 sor & Associates Homing sold Tramscripam, Inc. 1 2 3 4 that. Page 9 MR. LEOPOLD: Lewis, we're not going to do MR. TEIN: My name is not Lewis. I'm going to finish my question. Okay? 5 MR. LEOPOLD: Do not answer until you hear 6 from me. 7 BY MR. TEIN: 8 Q. Other than conversations that you have had 9 with Mr. Leopold -- I'm not asking about that -- are you 10 aware that Mr. Leopold has filed a lawsuit in federal 11 court seeking fifty million dollars from Jeffrey Epstein 12 on your behalf? 13 MR. LEOPOLD: Same objection. 14 Anything that you learn through 15 conversations between you and me, do not answer. 16 Those are protected. If you know through any 17 other realm of knowledge, you may answer. 18 19 BY MR. TEIN: 20 Q. You have no idea that Mr. Leopold filed a 21 fifty million-dollar lawsuit on your behalf against THE WITNESS: No. 22 Jeffrey Epstein? 23 24 MR. LEOPOLD: Same objection. Do not answer that question if it's through 25 discussions that you and I had. Outside of that, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 35013t6 EFTA00232167

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 36 of 100 nsor & Associates Reporting ad Tranxtip:inei. lac 1 2 3 4 5 6 7 8 9 10 13. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 10 you may answer. So do not answer that question if that is the only basis by which you understand that answer. THE WITNESS: No. BY MR. TEIN: Q. You didn't know that? MR. LEOPOLD: Don't answer that question. Again, it's attorney/client privilege. Any Information you've learned through conversations between you and I are protected. If you know it through any other realm, you may answer. MR. TEIN: Are you going to say that for every question in the deposition, Mr. Leopold? MR. LEOPOLD: When you ask improper questions like that without the proper -- MR. TEIN: You're going to stop your speaking objections right now. Okay? MR. LEOPOLD: Without the proper -- MR. TEIN: You need to stop your speaking objections. Let's continue. MR. LEOPOLD: Counsel, you just asked me a question and I'm going to state it on the record -- MR. TEIN: You need to stop your speaking Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Motile EFTA00232168

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 37 of 100 nsor & Associates Re porung and Transciip<m). lnc 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 17 18 19 20 21 22 Page 11 objections. Check your rules. MR. LEOPOLD: Excuse me. For the record, Counsel asked me a question. I'll state the answer on the record. He asked me the question am I going to be answering that way throughout the deposition. So long as there's improper foundation and predicate asked by the attorney, I will protect my client and I make the record where appropriate. If counsel wishes to ask an appropriate worded question with the proper foundation and predicate, I will certainly allow the client to answer the question. MR. GOLDBERGER: Why don't you just state attorney/client privilege and just be done with it? MR. LEOPOLD: I want the record to be clear. MR. TEIN: You want to waste time is what you want to do. You were supposed to be here this morning and you totally broke the deal, the agreement that you had with us if your hearing got cancelled. 23 But let's move on and maybe you'll stop 24 obstructing this deposition. 25 MR. LEOPOLD: I think the record is very Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 37 of 310 EFTA00232169

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 38 of 100 nsor & Associates Reporting end Transcription. lac. Page 12 1 clear where we stand thus far. 2 Is there a recording taken of this 3 deposition? 4 THE COURT REPORTER: Yes. 5 MR. LEOPOLD: Just make sure that's 6 preserved. 7 BY.MR. TEIN: 8 Q. Go to Exhibit 20-01 -- well, before you do 9 that, are you aware that a lawyer named Jeffrey 10 Herman filed a lawsuit on your behalf, yes or no? 11 MR. LEOPOLD: Objection. 12 Any conversations that you and I have had 13 regarding that, if that is the only way by which 14 you understand how to answer that question, do not 15 answer. It's attorney/client privilege, as well 16 as any conversations you may have had with the 17 attorney from Miami. That is also attorney/client 18 privilege. And I'm assuming -- 19 MR. TEIN: You're actually wrong about the 20 attorney/client privilege. 21 MR. LEOPOLD: I'm assuming Counsel is not 22 asking you to divulge attorney/client -- 23 MR. TEIN: Of course not. 24 BY MR. TEIN: 25 Q. a are you aware that Jeffrey Herman, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 31 d711 EFTA00232170

Case 9:08-cv-80804-KAKI ent 1 Entered on FLSD Docket 07/21/2008 Page 39 of 100 nsor & Associates Reporting and Traescriptico, Inc. Page 13 an attorney, filed a fifty-million-dollar lawsuit on your 2 behalf against Jeffrey Epstein, yes or no? 3 MR. LEOPOLD: Same objection. 4 MR. TEIN: We've heard the objection 10 5 times already. 6 MR. LEOPOLD: Counsel, excuse me. 7 MR. TEIN: Just say attorney/client 8 privilege. Stop interrupting my questions. 9 MR. LEOPOLD: I'm entitled to make an 10 objection for the record, which I'm doing, and 11 I'll make the same objection. And if it calls for 12 attorney/client privilege, any conversations you 13 and I have had, do not answer the question. 14 And I think that it might be appropriate, 15 for the record, to ask questions via 16 4IIIIIIIIIias opposed to gm, I think that 17 would be more appropriate for this deposition. 18 BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. 20 A. Yes. 21 Q. Thank you. 22 In fact, you know that Mr. Herman held a 23 press conference after he filed the fifty-million-dollar 24 lawsuit on your behalf, don't you? 25 After it happened. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 39 of 3I6 EFTA00232171

Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 40 of 100 nsor & Associates Roportenp and Tanscriptinn, 2 4 5 6 7 8 9 10 11 stepmother and Mr. Herman at the press conference 12 regarding your lawsuit? 13 A. Yes. 14 Q. Now you know that this is a very serious 15 matter, don't you? 16 MR. LEOPOLD: Asked and answered. 17 objection. 18 MR. GOLDBERGER: All right. You can 19 20 21 You cannot make legal objections. You have no Page 14 Q. You know that he had a press conference, don't you, yes or no? A. Yes. Q. In fact, let's go to Exhibit 20-01. MR. GOLDBERGER: Look behind you. You'll see it. BY MR. TEIN: Q. Have you ever seen that picture before? A. Yes. 22 23 24 25 Q. Is that a picture of your father, your object. You're representing a witness here, Mr. Leopold. You can object on privilege grounds. standing to do so. MR. LEOPOLD: I'm going to make them and then -- MR. GOLDBERGER: We're -- Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 40 or 314 EFTA00232172

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 41 of 100 nsor & Associates Re ponies arid Transentman, Inc I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2_4 25 Page 15 MR. LEOPOLD: We're going to leave or we're going to take a break, because his demeanor is not appropriate. There's no reason to have this kind of demeanor. If you want to have this kind of demeanor with me -- MR. TEIN: You are obstructing this deposition. MR. GOLDBERGER: Why don't you guys go outside and just talk about MR. LEOPOLD: She -- her job is very difficult and she's not going to be able to take us both talking at the same time. MR. GOLDBERGER: Off the record. MR. LEOPOLD: We're not going off the record, Jack. We're not, Jack. Her job is very difficult. I'm going td make the record. I don't think it is appropriate, especially in the small confines of this room, to be very aggressive with this young lady. MR. TEIN: That's not happening. Stop, stop actually -- MR. LEOPOLD: If you're going to interrupt me, we're going to cancel this deposition MR. TEIN: Stop misrepresenting. THE COURT REPORTER: I need one at a time, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 41 of 311 EFTA00232173

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 42 of 100 nsor & Associates Roparziap and Transcription. lac. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 16 no matter who it is. MR. LEOPOLD: I think we're going to take a break. Perhaps you might want to talk to your co-counsel -- MR. TEIN: I don't need to talk to him. MR. LEOPOLD: But we're going to take a break. MR. TEIN: We're not taking a break unless the witness needs a break. You're obstructing this deposition, Ted. MR. LEOPOLD: Come on, NW You all want to continue in this demeanor -- MR. TEIN: You're obstructing the deposition. Stop making speeches. We're not discussing this with you. The questions are to your client. Go take your five-minute break. MR. LEOPOLD: Fine. We need to make sure the record's clear and clean. And I want to make sure, as I've already asked you -- I know that you're one of the best in town -- that this audio -- this needs to be preserved. Okay? MR. TEIN: Go take your five-minute break, Mr. Leopold, now. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 42 Wile EFTA00232174

Case 9 08-cv-80804-KAM nt 1 EnteredonFLSpDocket07121/2008 Page 43 of 100 nsor & Associates Ropartin mod TrassaIptIra, lac. 1 Page 17 You were supposed to be here at nine a.m.; 2 it's now after two. Take your break and come 3 back. 4 5 6 7 MR. LEOPOLD: Okay. If the demeanor keeps up, we will not be here beyond those five minutes. MR. TEIN: Take your break and come back. MR. LEOPOLD: Okay. So I suggest that you 8 relax. 9 10 break. 11 MR. GOLDBERGER: Let them take that 12 five-minute break. 13 MR. LEOPOLD: But I would suggest that you 14 take deep breaths. 15 MR. TEIN: Suggest whatever you want. Go 16 take a break. 17 (Thereupon, a recess was taken.) 18 BY MR. TEIN: 19 Q. you agree that giving testimony 20 today at your deposition is something very serious, don't MR. TEIN: I suggest that you take your 21 you? 22 A. Yes. 23 Q. 24 And you respect the court, don't you? A. Yes. 25 Q. Let me show you Exhibit 31-O01. Can you Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 43,1311 EFTA00232175

Case 9:08-cv-80804-KAM nt 1 ter E wdonFLSIDDlocket07/21/2008 Page 44 of 100 pi sor Associates Repartinp ad 1 rancti pucm, Page 18 1 read that out loud, please. 2 A. Okay. What do you want? 3 Q. Will you read that out loud, please. 4 A. Oh. 5 Q. Thank you. 6 A. Lol hah my baddd...1O1 yah i got some 7 stupid court shit on the 20th...bullshit...and damn you 8 still have court shit with him? Like after so long wow 9 im sorry... well yah well we will definitely havta make 10 plans for sure..because i miss u tons times a million and 11 no no no i love you...o and p.s. i love ur default pic 12 niggaa. Muah xo. 13 Q. Did you send that message last week to a 14 friend of yours on MySpace? 15 A. I wouldn't know. There's no dates and I've 16 deleted that MySpace, so -- 17 Q. We're going to talk about that in a second. 18 A. Okay. 19 Q. Did you send that message last week -- 20 A. Right. 21 Q. Let me finish my question. 22 Did you send that message last week to a 23 friend of yours on MySpace? 24 A. I wouldn't know the date, but obviously, 25 it's to a friend. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 44 of 314 EFTA00232176

Case 9:08-cv-80804-KAM D Q. ent 1 Entered on FLSD Docket 07/21/2006 Page 45 of 100 nsor & Associates Reporting ad Trossainakia. 1 2 yours on MySpace? 3 A. Sure, yes. Page 19 Did you send that message to a friend of 4 Q. Were you referring to this deposition? 5 A. Yes. 6 Q. Do you find the term n-i-g-g-e-r offensive? 7 A. That's not anywhere in there. 8 Q. What word did you use in there? 9 MR. LEOPOLD: Where are you referring to, 10 Counsel? There's 20 plus words in there. 11 MR. TEIN: Don't make a speaking objection. 12 THE WITNESS: Are you referring to 13 anything -- 14 MR. LEOPOLD: No, Don't -- don't 15 let him ask you the question. 16 BY MR. TEIN: 17 O. What question were you asking, 18 19 You ask the questions. What is the question 20 pending? 21 BY MR. TEIN: 22 Q. what is the last word on there in 23 the text of your message before tne ciosing? Int MR. LEOPOLD: She doesn't ask questions. 24 A. Niggaa. 25 Q. Don't you find that term offensive? 4 a Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4001314 EFTA00232177

Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page 46 of 100 sor & Associates Reporting and Transcript.= In Page 20 1 A. No. 2 MR. LEOPOLD: Can you spell it for the 3 record, please. 4 THE WITNESS: N-i-g-g -- 5 MR. TEIN: No, no, no. You are not going 6 to be asking questions. 7 MR. LEOPOLD: I'm not asking questions. 8 I'm asking for the record the word to be spelled, 9 because we don't have a video here today. 10 MR. TEIN: These exhibits are part of the 11 record. You -- 12 MR. LEOPOLD: Well, it's not marked as an 13 exhibit. 14 MR. TEIN: Stop interrupting me, 15 Mr. Leopold. I have marked and identified as an 16 exhibit and you will get it. 17 MR. LEOPOLD: There has been no 18 identification of this document in the record. 19 MR. TEIN: Mr. Leopold, stop interrupting 20 this deposition. 21 MR. LEOPOLD: What is the exhibit number 22 marked for identification? 23 MR. TEIN: 31-001. 24 MR. LEOPOLD: Do we have copies? Is it on 25 the record anywhere? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 MI et Ste EFTA00232178

Case 9:08-cv-80804-KAM entl EnteredonFLSpDocket07/21/2008 Page 47 of 100 nsor & Associates Reporting nil TenseOption. Inc 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 21 1 BY MR. TEIN: 2 Q. Let me ask you, did you in fact 3 write your friend this message about this deposition? 4 A. Yes. 5 Q. So you wrote your friend that this 6 deposition is stupid court s-h-i-t, correct? 7 A. Yes. Q. Because you think this deposition is stupid court s-h-i-t, don't you? A. No. Q. You wrote that to your friend, didn't you? A. Yes. Q. You think that court is stupid, don't you? A. In some cases. Q. And you think that court is bull s-h-i-t, don't you? A. No. Q. And you think this deposition is bull s-h-i-t, don't you? A. No. Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: MR. TEIN: That's not an objection. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 470316 EFTA00232179

Case 9:08-cv-80804-KAM nt 1 Entered on FLSD Docket 07/21/2008 Page48of100 nsor & Associates Roponins and Trascripnna, Inc. Page 22 Q. You wrote that to your friend, didn't you? 2 MR. LEOPOLD: Objection. Asked and 3 answered, for the fourth time. 4 MR. TEIN: You are improperly objecting, 5 Mr. Leopold. You have no grounds to object. And 6 that's not an objection. 7 MR. LEOPOLD: It is an objection. MR. TEIN: Then terminate the deposition if 9 you think it's been asked and answered. 10 MR. LEOPOLD: Counsel, I am not precluded 11 from just making an objection to the form of the 12 question. As the courts well know, and if you 13 practice here in West Palm Beach, many of the 14 judges require you to set the objection with 15 specificity. And I will do that. And if you 16 don't want me to, you can make the record. But 17 will do that. 18 MR. TEIN: Here's what we'll do, Ted. You 19 can -- I will allow you to reserve an objection to 20 form for every single one of my questions. 21 Otherwise, all you're doing is obstructing. 22 MR. LEOPOLD: I won't do that. 23 MR. TEIN: Of course; because you want to 24 obstruct. 25 MR. LEOPOLD: All right. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 4804311 EFTA00232180

Case 9:08-cv-80804-KAM t 1 Entered on FLSD Docket 07/21/2008 Page 49 of 100 sor & Associates Reporting end Tr.uiscrtrion, loc. Page 23 1 BY MR. TEIN: 2 Q. you think that giving testimony 3 today, under oath, is bull s-h-i-t, don't you? 4 A. No. 5 Q. And you wrote that to your friend on 6 Myspace last week, didn't you? 7 MR. LEOPOLD: Objection. Asked and 8 answered. 9 THE WITNESS: No, I did not. 10 BY MR. TEIN: 11 Q. You didn't write this exhibit? 12 A. I wrote that, but I didn't write what you 13 said. 14 Q. You wrote in this exhibit, "I got some 15 stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't 16 you write that? 17 A. Yes. 18 Q. Referring to this deposition, didn't you? 19 A. Referring to the court. I was• later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house — 2S-- three-Yearragerr— Gkeig 24 A. Uh -huh. 25 Q. When the police interviewed you one month Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 40 03111 EFTA00232181

Case 9:08-cv-80804-KAM D u ent 1 Entered on FLSD Docket 07/21/2008 Page 50 of 100 * 16 17 18 19 ! 20 21 22 23 sor &Associates Reanntap and Transcription,Inc Page 24 1 after you went to Epstein's house, you swore on your 2 mother's grave that you and Epstein did not engage in sex 3 of any kind? 4 A. Yes. 5 Q. Didn't you tell that to the police? 6 A. Yes. And I will continue. I have never 7 had sex with him. 8 Q. Did what happened upstairs at Jeff 9 Epstein's house take you completely by surprise, 10 A. Yes. 11 Q. Now the civil complaint that you filed 12 against Mr. Epstein for fifty million dollars alleged 13 that you were totally shocked by what happened when you 14 got there. 15 A. Yes. Q. Were you totally shocked by what happened when you got to Epstein's house? A. Yes. O. You didn't expect it at all, did you? A. No. Q. You had absolutely no idea why your friend as taking you to Epstein's house, right? A. I was informed it was a massage. 24 Q. All you thought that it was going to be was 25 a massage, correct? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 510 31$ EFTA00232182

Case 9:08-cv-80804-KAM Anent1 Entered on FLSD Docket 07/21/2008 Page 51 of 100 sor & Associates Reporting and intim/1pda% loc. . Page 25 1 2 3 never said anything to you on the telephone about sexual 4 activity with Epstein, did she? 5 A. No. A. Yes. 0. 6 Q. 7 Before you got to Epstein's house And before you got to Epstein's house never sent you a message over the Internet about 8 sexual activity with Epstein, did she? 9 A. No. 10 Q. Did ever try to convince you to 11 engage in any sexual activity with Epstein? 12 A. No. 13 Q. Did every try to convince 14 you to engage in any sexual activity with Epstein? 15. A. I don't know who is. 16 Q. Do you have a friend IIIIIII? 17 A. No. 18 Q. Okay. Before you went so Epstein's house 19 did anyone call or e-mail you to induce you to engage in 20 sexual activity with Epstein? 21 A. No. 22 4. So you're sure that before you got to 23 Epstein's house no one tried to persuade you to engage in 24 sexual activity with Jeffrey Epstein? 25 A. No. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 110714 EFTA00232183

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 52 of 100 nsor & Associates Rennnens and Tin/airman, lac. Page 26 1 Q. You're sure that -- let me ask the question 2 again. 3 You're sure that before you got to 4 Epstein's house no one tried to persuade you to engage in 5 sexual activity with Epstein for money. Are you? 6 MR. LEOPOLD: Objection. Asked and 7 answered. 6 THE WITNESS: No. And I've already 9 answered that a bazillion times. 10 BY MR. TEIN: 11 Q. He's coaching you now. So I'm going to ask 12 the question -- 13 MR. LEOPOLD: Counsel, I've made an 14 objection for the record. 15 MR. TEIN: Stop speaking. 16 MR. LEOPOLD: I'm not going to stop 17 speaking. You can't interrupt me when I'm making 18 the record. 19 MR. TEIN: You're coaching the witness. 20 MR. LEOPOLD: Counsel -- 21 MR. TEIN: Stop coaching the witness. 22 BY MR. TEIN: 23 Q. let me ask you 24 MR. LEOPOLD: If you continue to -- 25 MR. TEIN: Stop interrupting my questions. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 32 W3141 EFTA00232184

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 53 of 100 nsor & Associates ReportenE mend Tranutirion. Inc 1 2 Page 27 MR. LEOPOLD: If you do it one more time, we're leaving. 3 BY MR. TEIN: 4 0. 5 6 7 8 9 10 11 12 S MR. LEOPOLD: I'm going to make the record. You cannot interrupt me when I'm making the record. Out of professional conduct, you cannot do that. I'm entitled to make the record. I made an objection, asked and answered. Your demeanor is inappropriate. You're willing and you are able and you're responsible to ask a question in a professional manner, and ask the question and once 13 you get the answer, to either follow up on it or 14 move on, but not continuously browbeat and ask the 15 same question over and over because you don't like 16 the answer. 17 MR. TEIN: Calm down, sir. 18 MR. LEOPOLD: Trust me, I'm very calm here. 19 When I'm not calm, you'll know it. I'm very calm. 20 So please continue on. But I will not 21 allow you to continue to harass her in the 22 demeanor that you're doing. Ask her a question 23 and move on. 24 MR. TEIN: Are you done? 25 MR. LEOPOLD: Thank you. I am. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 53 of 315 EFTA00232185

Case 9:08-cv-80804-KAM q pent 1 EnteredonFLSDDocket07/2112008 Page 54 of 100 nsor & Associates Roparanp aac Transcrtrim, lne 1 Page 28 MR. TEIN: Stop misrepresenting the record 2 and calm down. I'm going to ask my question. 3 Stop it. 4 BY MR. TEIN: 5 Q• MR. LEOPOLD: I think the record is very 7 clear. 8 MR. GOLDBERGER: Let me just clarify 9 something. When you object to the form of a 10 question, you're not instructing the witness not 11 to answer the question, are you? 12 MR. LEOPOLD: No. And I'm not making that 13 objection; only on attorney/client privilege. 14 MR. TEIN: Will you stop speaking now so I 15 can ask my question? Are you done? 16 Okay. I'm going to ask my question. 17 18 19 20 21 22 23 24 25 BY MR. TEIN: Q• Listen, IIIIII-- MR. LEOPOLD: Hold on. Stop. I've been doing this for 20 plus years and have met a lot of attorneys, but I've never had an experience like this where I've MR. TEIN: Stop your speeches. MR. LEOPOLD: If you continue to do this, whether it's with me or with my client, I will not Ph. - Fax. 1655 Palm Beach Lakes Blvd.; Suite 500 - West Palm Beach, FL 33401 S4 of 3101 EFTA00232186

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 55 of 100 nsor & Associates Reporting ad Trans< nfrtion. Page 29 1 2 3 Mr. Goldberger knows all this, because I know that 4 he wouldn't do this. So I will not put up with 5 it. And I think it's highly inappropriate to do 6 this with this child sitting here, the way you're 7 acting, primarily towards me, and I will not put 8 up with it. 9 MR. TEIN: Will you please stop your speech 10 so I can ask questions? 11 12 professionally, I will do so. But if you continue 13 to do it this way, I will leave. 14 15 BY MR. TEIN: 16 Q. are you sure that before you got to 17 Epstein's house no one tried to persuade you to engage in 18 sexual activity with Epstein for money? 19 MR. LEOPOLD: Asked and answered. 20 Objection. 21 MR. TEIN: Did you get her answer? 22 THE COURT REPORTER: No, I did not. put up with it and I don't need to put up with it and it's not appropriate. And I'm sure MR. LEOPOLD: So long as you act MR. VEIN: Suit yourself. 23 THE WITNESS: I'm sure. 24 BY YR. TEIN: 25 0. Let me ask you a few questions about your Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 55 of SIO EFTA00232187

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 56 of 100 nsor & Associates Roponini ranscrip:u co. Inc. Page 30 1 contact with Jeffrey Epstein. Okay? 2 A. (Witness nods head up and down.) 3 Q. Jeff never e-mailed you, did he? 4 A. No. 5 Q. Jeff never text messaged you, did he? 6 A. No. 7 Q. Jeff never chatted in a chat room with you, 8 did he? 9 A. No. 10 Q. Before you got to Epstein's house you had 11 never spoken to Jeff, had you? 12 A. No. 13 Q. And before you got to Epstein's house you 14 had never met Jeff? 15 A. Correct. 16 Q. Before you got to Epstein's house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 Q. Before you got to Epstein's house had you 20 ever told Jeffrey that you were under 18? 21 A. No. I never spoke to the man before that. 22 Q. And you only went to Jeff Epstein's house 23 that one time three years ago, correct? 24 A. Yes. 25 Q. You never went there again, correct? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Seat Sit EFTA00232188

Case 9:08-cv-80804-KAM p ent1 Entered on FLSD Docket 07/21/2008 Page 57 of 100 nsor & Associates Reporting sod Tratteriptra, 1 2 3 of questioning about this and we'll move onto something 4 else. Okay? 5 A. Uh-huh. Yes. I'm sorry. 6 Q. Before you got to Epstein's did anyone 7 associated with Epstein ever call you on the phone and A. No. Page 31 Q. All right. Let me ask you two final areas 8 try to persuade, induce, entice or coerce you to engage 9 in any sexual activity? 10 A. No. 11 Q. Before you got to Epstein's did anybody 12 associated with Epstein ever contact you on the Internet 13 and try to persuade, induce, entice or coerce you to 14 engage in any sexual activity? 15 A. No. 16 Q. MN who told you that when you got to 17 Jeff Epstein's house you should lie to Jeff about your 18 age? 19 A. 20 Q. Was it or was it the other girl in 21 the car who you rode over with to Epstein's house? 22 A. 3 O. Who was the other girl in the car with you 24 that day? 25 A. I honestly don't know. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 sr a SUP EFTA00232189

Case 9:08-cv-80804-KAM merit 1 Entered on FLSD Docket 07/21/2008 Page 58 of 100 n5Or & Associates Reporting ad Traatiptien. lac. Page 32 1 Q. Had you ever seen her before? 2 A. No, sir. 3 Q. You told the police that when you rode over 4 to Epstein's you had no idea who she was, right? 5 A. Correct. 6 Q. You told the police that you didn't know 7 her name, but she was like really dark, kind of like a 8 Spanish girl? 9 A. Yes. 10 Q. Those were your words, right? 11 A. Yes. 12 Q. Do you now know who she is? 13 A. No, sir. 14 0. So it was Illillwho told you to lie about 15 your age to Jeff Epstein? 16 A. Yes, sir. 17 Q. And IIII told you that if you weren't 18, 18 Epstein wouldn't let you into his house, right? 19 A. That's -- yes, yes. 20 Q. All right. Let's talk for a minute about 21 when you first met Jeff. Okay? 22 A. Sure. 23 Q. When you first met Jeff he tried to find 24 out how old you were, right? 25 A. Excuse me? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 51cAlIll EFTA00232190

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 59 of 100 nsor & Associates Reportinp /ad Tunic apron, lnc. Page 33 1 Q. When you first met Jeff he tried to find 2 out how old you were, right? 3 A. Not when we first introduced each other; 4 when we get upstairs, then, yes. 5 Q. During the massage Jeff asked you how old 6 you were, correct? 7 A. Yes, yes. 8 Q. Now hadn't you already told Jeff's 9 ass:stant, the one who walked you upstairs, that you went 10 to college and had just moved down here from Ohio? 11 A. I never spoke to the lady. 12 Q. Do you want to rethink that answer? 13 MR. LEOPOLD: Is that a question? 14 BY MR. TEIN: 15 Q. Do you want to rethink that answer? 16 A. No. I didn't really speak with her that 17 much. 18 Q. Do you want to try to refresh your memory 19 on that? 20 MR. LEOPOLD: Do you have something to 21 refresh her memory with? 22 MR. TEIN: Do you want to stop making 23 speaking objections? 24 MR. LEOPOLD: No. But to refresh someone's 25 memory, you show them a document. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 St of 316 EFTA00232191

Case 9:08-cv-80804-KAM 4# 0 ent 1 Entered on FLSD Docket 07/21/2008 Page 60 of 100 nsor & Associates Reparunp Dad Transcriputo. Page 34 1 MR. TEIN: I know how to do this. 2 MR. LEOPOLD: Then show her a document. 3 MR. TEIN: Stop speaking. 4 MR. LEOPOLD: I'm not going to stop 5 speaking. I'm going to continue to make the 6 record. 7 MR. TEIN: You're obstructing. Please 8 stop. 9 MR. LEOPOLD: I'm not obstructing. But if 10 you want to refresh her recollection, you need to 11 show her something. 12 That's not a proper question. I object to 13 the foundation and the predicate of that question. 14 MR. TEIN: Are you done? 15 MR. LEOPOLD: I am now. Thank you. 16 BY MR. TEIN: 17 Q. Do you want to try to refresh your memory 18 as to whether you had any conversation with the woman who 19 walked you upstairs in Epstein's house in which you told 20 her that you went to college and had just moved down from 21 Ohio? 22 MR. LEOPOLD: Objection. Object to the 23 form of the question. Lack of foundation and 24 predicate. 25 BY MR. TEIN: Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 GO a/ 31f EFTA00232192

Case 9:08-cv-80804-KAM ent 1 teradonFLSCOocket07/21/2008 Page 61 of 100 nsor Associates Roaming and Trassansuice, lac Page 35 2 3 4 memory that in fact you told Mr. Epstein's assistant, the 5 one who walked you upstairs, that you went to college and 6 you had just moved down here from Ohio? 7 A. I don't remember saying that, but if you -- Q. You can answer the question. A. Sure. Q. Is there anything that would refresh your B I don't remember saying that myself, so -- 9 Q. That would be a lie, right? 10 A. No. I really don't remember. 11 Q. So you told Jeff that you were 18 years 12 old, correct? 13 A. Yes. 14 Q. Do you remember Detective Pagan of 15 the Police Department, Palm Beach Police Department? 16 A. Yes. 17 Q. Do you remember you spoke to her? 18 A. Yes. 19 Q. Do you remember that you told Detective 20 Pagan that when you lied about your.age to Jeff you said 21 it really fast because you didn't want to make it sound 22 like you were lying? 23 A. I don't remember the words exa 24 do remember telling her I told him I was 18. 25 Q. And do you remember telling Detective Pagan Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 61 at 316 EFTA00232193

Case 9:08-cv-80804-KAM ent 1 EnteredonFLSODocket07121/2008 Page 62 of 100 nsor & Associates • Reporting end Transcription, inc. Page 36 1 that when you lied to Epstein about your age that you 2 said it really fast so Epstein wouldn't realize you were 3 lyLng? 4 A. No, I don't remember saying those words 5 exactly to her. I remember telling her that I told 6 Epstein I was 18. 7 O. Does it sound right to you that you told 8 Detective Pagan that you said your age really fast to 9 Epstein -- MS. BELOHLAVEK: Objection. Asked and 11 answered. 12 BY MR. TEIN: 13 Q. -- so he wouldn't think that you were 14 lying? 15 MR. LEOPOLD: Objection. Asked and 16 answered, lack of foundation, mischaracterization 17 of her earlier testimony. She's already answered 18 that question. 19 BY MR. TEIN: 20 Q. You can answer it. 21 MR. LEOPOLD: Same objection. It's been 22 asked and answered. 23 You can answer. I've made the objection. 24 THE WITNESS: I forget the question, now. 25 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 62 x1616 EFTA00232194

Case 9:08-cv-80804-KAM Qagkynent 1 Entered on FLSD Docket 07/21/2008 Page 63 of 100 sor & Associates Repornic and lranacripuon. kit Page 37 1 BY MR. TEIN: 2 Q. Let me put it again. 3 Does it sound right to you that you told 4 Detective Pagan that when you lied about your age to 5 Jeffrey Epstein, you said it really fast because you 6 didn't want to make it sound like you were lying? 7 MR. LEOPOLD: Objection. Lack of 8 foundation, asked and answered. 9 THE WJTNESS: I could have possibly said 10 that, yes. 11 BY MR. TEIN: 12 Q. You didn't want Mr. Epstein to know that 13 you were lying about your age, right? 14 A. Correct. 15 Q. You didn't want Mr. Epstein to know that 16 you were not 18 yet, right? 17 A. Correct. 18 Q. You wanted Mr. Epstein to believe that you 19 really were 18, right? 20 A. Correct. 21 Q. Do you remember when Mr. Epstein asked 22 where you went to school? 23 A. Yes. 24 Q. And you told Mr. Epstein you went to 25 wellington, right? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 63 el 316 EFTA00232195

Case9:08-cv-80804-KAM D u ent 1 Entered on FLSD Docket 07/21/2008 Page 64 of 100 nsor & Associates itencatinA and Transcnrian, Inc 1 2 A. Q. Page 38 Yes. Was that the truth? 3 A. No. 4 Q. In fact, you went to , right? 5 A. Yes. 6 Q. So you lied to Mr. Epstein again, correct? 7 A. Yes. 8 Q. Is Wellington the college that you told 9 Jeff's assistant that you were attending? 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I don't remember having that conversation with her, so I wouldn't know if that's what I said. Q. That was a lie, though, wasn't it? MR. LEOPOLD: Objection to the form of the question, lack of foundation. You're making an assumption. She just answered you she can't tell you that. MR. TEIN: Speaking objection. And you well know that, Mr. Leopold. MR. LEOPOLD: She can't answer that question. The way you phrased that question, you're purposely making her not be honest in her testimony. She can't answer a question like that. She doesn't remember. So then you say, "So you were lying." That's improper and you know that. That's not a proper question. And any attorney Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 84 or 310 EFTA00232196

Case 9:08-cv-80804-KAM D c ment 1 Entered on FLSD Docket 07/21/2008 Page 65 of 100 sor & Associates Resin/is aid Transcription. Inc Page 39 1 that would do that to a witnesses or to a person 2 that's sitting in this chair is not acting 3 professionally. You can't ask a question like 4 that. You can do it, but it's not proper. And 5 I'm sure you weren't trained that way, certainly 6 not ethically. 7 MR. TEIN: Will you stop? 8 MR. LEOPOLD: I'm not going to stop, 9 because the way you're asking that question is 10 improper and you know it. 11 MR. TEIN: You're losing your cool. 12 BY MR. TEIN: 13 Q. -- 14 MR. LEOPOLD: Trust me. I'm very calm. 15 When I lose my cool, you'll know it. 16 MR. TEIN: I do know it. 17 BY MR. TEIN: 18 Q. Ms. = Mr. Epstein never asked you 19 to do anything other than massage him, correct? 20 A. Incorrect; because he asked me to take off 21 my bra, so that would be two things he's asked me to do. 22 Q. Other than asking you to take your bra off, 23 Mr. Epstein never asked you to do anything with him other 24 than massage, correct? 25 MR. LEOPOLD: Objection. Foundation, Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 650111I EFTA00232197

Case 9:08-cv-80804-KAM ent 1 EnteredonFLSDpocket07/21/2008 Page 66 of 100 nsor & Associates Ropanint and Tranwription, Inc. Page 40 1 2 THE WITNESS: Correct. 3 BY MR. TEIN: 4 Q. You told the police, in your words, that 5 you did not whack him off, right? 6 A. Correct. 7 O. What does that mean? 8 A. Whack, like whacking off? 9 Q. Your term, what does that mean? 10 A. Masturbating. 11 Q. Mr. Epstein never tried at any time to grab 12 you: hand, did he? 13 A. No. 14 O. Mr. Epstein never tried to put your hand 15 anywhere, did he? 16 A. No. 17 Q. At no time did you touch Mr. Epstein's 18 penis, did you? 19 A. No. 20 Q. And he did not touch you, correct? 21 A. Incorrect. 22 Q. 23 he touch me." Were you lying to the police then? 24 A. No. Well, I wasn't being fully truthful, 25 but I wasn't lying. predicate. Well, you told the police, "At no time did Ph. - Fax. 1655 Pa 'm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 611013111 EFTA00232198

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 67 of 100 nsor & Associates Reporting and Transcription. lac. Page 41 1 Q. You told the police twice when you spoke to 2 Pagan that "at no time did he touch me." Didn't 3 you say that to the police? 4 A. Yeah. 5 Q. And you're saying that that was not fully 6 truthful. Is that what you're saying now? 7 A. Correct. 8 Q. And you're saying if you're not fully 9 truthful, that's not a lie. Correct? 10 A. You took that out of context like really 11 bac. I didn't mean like that. Touching my legs and 12 he never kept his hands to himself the entire time. 13 That's what I'm trying to say. 14 Q. You told the police, "At no times did he 15 touch me." You agree with that, correct? 16 A. No, I don't agree with that, because he did 17 touch me. 18 Q. Did you tell the police that he did not 19 touch you, yes or no? 20 A. It's a possibility, but I do not remember. 21 Q. Okay. And you did not have any type of sex 22 with Jeff, correct? 23 A. No. 24 Q. And you did not have any type of oral sex 25 with Jeff, correct? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 0131$ EFTA00232199

Case 9:08-cv-80804-KAM DQcient 1 Entered on FLSD Docket 07/21/2008 Page 68 of 100 nsor & Associates Reponins and TillISCripli OD, 10C. 3 2 3 4 Page 42 A. No. Q. No type of intercourse with Jeff, correct? A. Correct. Q. All right. Let's talk about what happened 5 after the massage was over. 6 A. Okay. 7 Q. 8 you wanted to bring your sister back so she could 9 make some money, correct? 10 A. Incorrect. 11 Q. Your sister is III right? 12 A. Correct. 13 Q. And you love very much, don't you? 14 A. Yes. 15 Q. 16 with the other girls, weren't you? 17 A. Incorrect. 18 Q. Well, when Mend the other girl in the 19 car that day made their statements to the police they 20 told the police that you were joking afterwards. Are you 21 saying that they were lying to the police about that? 22 A. No. But a question or -- questions from 23 like she asked me questions, but it wasn't 24 joking. She was kind of like in a happy way, like, "Oh, 25 what did you do? What did you do?" Like those kind of After the massage, you told Epstein that And when you left the house you were joking Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 18.31316 EFTA00232200

Case 9:08-cv-80804-KAM Doqument1 Entered on FLSD Docket 07/21/2008 Page 69 of 100 sor & Associates 1 2 3 4 5 6 7 8 9 Reporting and Transcription. 3nc Page 43 things, but it wasn't joking about it at all. Q. You joked about it, didn't you? A. No. Q. You said to that if you did this every weekend you'd be rich, didn't you? A. No. That's what told me. Q. You didn't tell that to glip MR. LEOPOLD: Objection. Asked and answered. 10 THE WITNESS: No. 11 BY MR. TEIN: 12 Q. After you left Epstein's house you took the 13 money and you went shopping with and the other 14 girl in the car, correct? 15 A. Incorrect. I didn't spend any of the 16 money. 17 Q. You went to Marshall's, didn't you? 18 A. I went along, yes, but I didn't -- 19 Q. You went shopping with them at Marshall's, 20 didn't you? 21 MR. LEOPOLD: Objection. 22 THE WITNESS: I guess you could say that. 23 MR. LEOPOLD: Objection. Lack of predicate 24 and foundation. Mischaracterization of earlier 25 testimony. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 09 of 010 EFTA00232201

Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 70 of 100 nsor & Associates RI:Tarano and Transc dance, Inc. Page 44 1 BY MR. TEIN: 2 Q. And IIIIIIrbought a purse, right? 3 A. Yes. 4 Q. And you were with her the whole time at 5 Marshall's, correct? 6 A. Yes. 7 Q. Now tell me about when the federal 8 prosecutors told you about getting reimbursed. 9 A. I have no idea what you're talking about. 10 Q. Tell me about when the federal prosecutors 11 spcke to you about getting money you feel you're entitled 12 to from Mr. Epstein. 13 A. I don't know what you're talking about. 14 Q. Do you know who is? 15 A. No, sir. 16 Q. Did you ever meet with any federal 17 prosecutors? 18 A. I think -- yeah. I think they were -- I 19 think they were like FBI. 20 Q. Uh-huh. Did you meet with federal 21 prosecutors? 22 A. They came to my house one time, yes. 23 Q. When did they come to your house? 24 A. Very long ago. 25 Q. Was it this year, 2008? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 Thrall@ EFTA00232202

Case 9:08-cv-80804-KAM ent 1 QlteredonFLSDpocket07/21/2008 Page 71 of 100 sor &Associates Roponisq mod Trassaiption. 1 2 3 Page 45 A. It was not this year, no. Q. Was it 2007? A. I'd have to say at least two years ago or a 4 year ago, yeah. So it would be 2007, 2006; but it was a ; while ago. 6 Q. How many federal prosecutors or FBI agents 7 came to your house? 8 A. I'm trying to remember. I want to say four 9 people came. 10 Q. Did they give you their business cards? 11 A. If they did, I don't remember, and they 12 weren't toward me. Maybe my parents have them. I don't 13 know. 14 Q. Did they give you their cell phone numbers? 15 A. No. 16 Q. Did you ever speak to them on their cell 17 phones? 18 A. No, sir. 19 Q. Did they speak to your parents? 20 A. That's something you'd have to ask my 21 parents. 22 0. Do you know whether they spoke to'your 23 par ' 24 A. No, sir. 25 Q. You have no idea? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 71 Nits EFTA00232203

Case 9:08-cv-80804-KAM Qg g lent 1 Entered on FLSD Docket 07/21/2008 Page 72 of 100 nsor & Associates Agnomen and Trmuctirtian, Page 46 1 A. No, sir. 2 MR. LEOPOLD: Objection. Asked and 3 answered. 4 BY MR. TEIN: 5 Q. So if I say the name to you 6 you don't know who that is? 7 A. No, sir. B Q. How many women and how many men came to 9 your house? 10 A. I want to say two ladies and two guys. 11 Q. Did someone named come to 12 your house? 13 A. I don't know names, sir. 14 Q. Do you know who is? 15 A. No, sir. 16 Q. Do you know who Jeffrey Herman is? 17 A. Yes. 18 Q. That's the lawyer who first sued Epstein on 19 your behalf, right? 20 A. Yes. 21 Q. Has Mr. Herman advanced your family any 22 money? 23 MR. LEOPOLD: Any conversations that you've 24 had with Mr. Herman regarding that issue, you are 25 not to disclose. If you've learned in some other 1 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 72 of 316 EFTA00232204

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 73 of 100 nsor & A5soclates Reporting and lrinscriptioa Inc 2 3 4 BY MR. TEIN: fashion, you may answer. THE WITNESS: Okay. I wouldn't know. Page 47 5 Q. You don't know? 6 A. No. 7 MR. LEOPOLD: Objection. Foundation. 8 Attorney/client privilege. 9 BY MR. TEIN: 10 Q. And you say you don't know who 11 is? 12 A. No, sir. 13 Q• Does it refresh your recollection that he's 14 the number two prosecutor at the U.S. Attorney's Office? 15 A. No. 16 Q. That he's boss? 17 A. No. 18 Q. Does it refresh your memory that he's the 19 ex-partner of Jeff Herman, the first lawyer who sued 20 you -- sued Mr. Epstein on your behalf for fifty million 21 dollars? 22 A. No, sir. I don't know who he is. 23 Q. Without telling me any conversations that 24 you've had with your lawyers, how is it that you selected 25 Mr. Herman as your lawyer from the 81,000 members of the Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 71 et 311 EFTA00232205

Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 sor & Associates [tenoning and Inniscrivinn. Inc. Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 Q. Did you ever meet Mr. Herman? 6 A. Once. 7 Q. Don't -- don't tell me what you discussed 8 with him. Where did you meet him? 9 A. I was shopping in my -- he showed up at my 10 friend's house. 11 Q. Whose house? 12 A. My friend 13 Q. Is that from the Quarterdeck 14 Tavern? 15 A. Yes. 16 Q. And did you have a meeting with him at 17 house? 18 A. Yes. I guess you could say that. 19 0. And who else was there? 20 A. My Aunt 21 Q. And what was that meeting about? 22 MR. LEOPOLD: Objection. That calls for 23 attorney/client privilege. 24 BY MR. TEIN: 25 Q. What discussions did you have with Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 ?act 316 EFTA00232206

Case 9:08-cv-80804-KAM CZo ent 1 Entered on FLSD Docket 07/21/2008 Page 75 of 100 sor & Associates Reporting one Thinscripann, Inc. Page 49 1 Mr. Herman in the presence of ailla 2 A. None. 3 Q. What discussions did you have in the 4 presence of her aunt? 5 A. Of my aunt? 6 MR. GOLDBERGER: It's the witness's aunt. 7 BY MR. TEIN: 8 Q. Oh, of your aunt. 9 A. The only one that we've ever discussed or 10 ever had. 11 Q. And so you were in a conversation with 12 Mr. Herman and your aunt? 13 A. Yes, sir. 14 Q. And you discussed privileged matters during 15 that conversation? 16 MR. LEOPOLD: Object to the form. i think 17 you might have to educate her on that question. 18 BY MR. TEIN: 19 Q. You discussed the lawsuit? 20 A. Yes. 21 Q. Did tell you about any 22 conversations that she had with Mr. Herman? 23 A As far as I'm concerned, she's never spoken 24 or she's never had a conversation. She only opened the 25 door and then left. She's the one who answered the door. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 7$ ei EFTA00232207

Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 76 of 100 100 nsor & Associates Rcporiinp aid Transcription, Jac. Page 50 1 Q. Why did the meeting take place at 2 amuse? 3 A. I spent the night that night at her house. 4 O. And when was this? 5 A. A while ago. 6 Q. How long ago? 7 A. A month and a half ago. I'm guessing. 8 Q. A month and a half ago? 9 A. Uh-huh. 10 Q. So was it before of after Mr. Herman filed 11 the fifty-million-dollar lawsuit against Epstein? 12 A. After. 13 Q. Did you meet with an FBI agent named 14 , a woman? 15 A. I don't know. 16 Q. Did Ms. speak to you about 17 getting reimbursed from Mr. Epstein? 18 A. I've never had a discussion with anyone 19 about getting reimbursed from Mr. Epstein. 20 O. Have you met with an agent named 21 22 A. Not to my knowledge. 23 Q. How about an agent named 24 A. No, sir. 25 O. How about an agent named Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 7101311 EFTA00232208

Case 9:08-cv-80804-KAM Do ent 1 Entered on FLSD Docket 07/21/2008 Page 77 of 100 4 nsor & Associates Repartmg and Transeriimian, lac. Page 51 A. No. 2 Q. And we've learned that many of the girls, 3 some of whom are as old as 23, were told by the 4 government that they would get money at the end of the 5 criminal prosecution. Does that sound familiar to you?' 6 A. No, sir. 7 Q. Other than Mr. Leopold here -- I'm not 8 asking about Mr. Herman either -- 9 A. Uh-huh. 10 Q. -- did anyone ever discuss with you that 11 yot could get reimbursement for your damages? 12 A. No, sir. 13 Q. Did you or any member -- 14 MR. LEOPOLD: Are you referring to a 15 criminal matter or a civil matter? 16 BY MR. TEIN: 17 Q. Did you or any member -- 18 MR. LEOPOLD: Excuse me. Let me object to ;9 the form of the question. 20 BY MR. TEIN: 21 Q. Did you or any member of your family ever 22 get a victim notification letter from anyone? 23 A. I no longer live at that residence and I 24 wouldn't know. 25 Q. So your testimony is that you have never Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 77 of 310 EFTA00232209

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 78 of 100 sor & Associates Kopm10)24,411flmmtthmelm. Page 52 4 if your parents have ever received a victim notification 7 6 A. 5 letter, correct? Q. Have you given any evidence to prosecutors Correct. 1 igneui.vcd a victim notification letter, correct? 2 rect. 3 Q. And your testimony is that you don't know 8 or law enforcement in this case? 9 A. What do you mean by evidence? 10 Q. Well. Anything that you can touch or feel. 11 A. No. 12 MR. LEOPOLD: Objection to the form of the 13 question. 14 BY MR. TEIN: 15 Q. So you haven't given anything physical -- 16 A. No. 17 Q. -- any item to any prosecutor, police 18 officer or law enforcement agent, correct? 19 A. My cell phone four years ago or three years 20 ago, but that's it. 21 O. You gave your cell phone to whom? 22 A. Pagan. 23 Q. Did she keep it? 24 A. Ask her. 25 O. You gave it to her and then you didn't get meomponiesSeillYienalipinahmell, ta•ff Imre". nod wary 71.1314 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232210

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 79 of 100 sor & Assoctates Ropanisig and Tnascriptimi, lac. • Page 53 it back at the end of the meeting? 9 A. No. They -- yeah. No. They have it. I'm 3 guessing. I don't have it. 4 Q. How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7 question. Attorney/client privilege. 8 BY MR. TEIN: 9 Q. How much money are you hoping to get, you, 10 yourself, hoping to get out of Epstein? 11 MR. LEOPOLD: Same. Same objection, 12 attorney/client privilege. 13 Don't answer the question. 14 BY MR. TEIN: 15 Q. I'm not asking about what your lawyer told 16 you. 17 MR. LEOPOLD: I'm instructing her not to 18 answer the question, because any of those 19 conversations involve her counsel. 20 MR. TEIN: Certify that. 21 MR. LEOPOLD: Please. 22 CERTIFIED QUESTION 23 BY MR. TEIN: 24 Q. Now, you lied to get out of this 25 deposition, didn't you? 79W070 Ph. - Fax. . 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232211

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 80 of 100 sor & Associates Roporunc and Transcription. Inc Page 54 1 A. No, sir. 2 Q. You didn't want to come to court today and 3 tell the story that you had told to the police under 4 oath, did you? 5 MR. LEOPOLD: Object to the form of the 6 question. Lack of foundation, predicate. 7 THE WITNESS: No. I have no problem coming 8 here and talking to you. 9 BY MR. TEIN: 10 Q. And to avoid getting served with a lawful 11 subpoena, you lied about your name, didn't you? 12 A. No. 13 Q. And in fact, just lying yourself wasn't 14 enough, was it? 15 MR. LEOPOLD: Objection to the form of the 16 question. 17 Don't answer it. It's not a question. 18 Object to the form of the question. Lack 19 of foundation. 20 MR. TEIN: Are you instructing her not to 21 answer? 22 MR. LEOPOLD: I am. 23 MR. TEIN: Certify it. 24 MR. LEOPOLD: Please. 25 50 of 314 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232212

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 81 of 100 nsor & Associates Roportang and lralosospoco. Inc . Page 55 1 CERTIFIED QUESTION 2 BY MR. TEIN: 3 Q. You asked your co-workers -- 4 MR. LEOPOLD: It's vague and ambiguous. 5 BY MR. TEIN: 6 Q. You asked your co-workers at the 7 Quarterdeck Tavern to lie for you, didn't you? 8 A. No. I informed my boss about what was 9 going on and he told me that he would help in any way 10 that he can. 11 Q. Okay. You got your friendIIIIIIIIPto lie 12 by switching name tags with you, correct? 13 A. Incorrect. It was a coincidence that same 14 night she was not wearing her name tag; she was wearing 15 mine. But I was also not wearing -- I was wearing my 16 name tag. Everyone switches name tags. It just so 17 happens it was a coincidence that same night the people 18 came with the papers. 19 MR. TEIN: Will you put up Exhibit 18-001? 20 MR. GOLDBERGER: And mark 18-001 for 21 identification purposes to this deposition. 22 MR. LEOPOLD: None of them have been marked 23 yet. Can we mark them and put them as attachment 24 to the depositions? Because I think you've shown 25 three photos now. And this is the only one that Ph. - Fax. 1655 Paim Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 It el 31$ EFTA00232213

Case 9:08-cv-80804-KAM ent 1 Entered on FLED Docket 07/21/2008 Page 82 of 100 D nsor & Associates Ropaning cad Tuascrquice,. Inc. Page 56 1 has been marked for identification yet. 2 BY MR. TEIN: 3 Q. -- 4 MR. LEOPOLD: Hold on just a second. Just 5 so the record is clear -- 6 MR. TEIN: I'm not speaking to you. 7 MR. LEOPOLD: Okay. Then don't speak to me 8 then. But I'll speak to Mr. Goldberger, perhaps. 9 But at least for the record, can we put on 10 the record what the previous two photographs were 11 marked for identification? 12 MR. GOLDBERGER: We will make sure that the 13 record is clear at the end of the deposition so 14 that there's no ambiguity. 15 MR. LEOPOLD: Thank you. 16 BY MR. TEIN: 17 Q. us t've put a photograph marked 18-001 18 up on the screen. Do you see that? 19 A. Yup. 20 Q. Who is that in the photo? 21 A. 14IIIIILon the left and me on the right. 22 Q. right? 23 A. Yes. 24 Q. IOW your friend at the 25 Quarterdeck Tavern, right? Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 eta 316 EFTA00232214

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 83 of 100 nsor 81 Associates Reporting tad Transertptim, Inc. 1 A. Yes. 2 Page 57 Q. IIIIIIIIIryour friend, who you say the day 3 that the process servers went to serve you with a 4 5 coincidence, was wearing your name tag? 6 A. Yes, sir. 7 Q. And just by coincidence, you were wearing 8 her name tag, correct? 9 10 11 12 13 14 15 16 17 18 19 BY MR. TEIN: 20 Q. You said that wasn't the first day you were 21 going to be -- you thought you were being served with a 22 subpoena, correct? subpoena for this deposition, just happened -- just by A. Yes. Q. Your testimony under oath is that's just a coincidence, right? A. Total honesty. Q. It just happens to be the day that you were going to be served with a subpoena, correct? A. That wasn't the first day that -- MR. LEOPOLD: just answer the question. It calls for a yes or no. THE WITNESS: Yes. 4 COM 23 A. Correct. 24 Q. You knew before the day that you switched 25 name tags with that the process servers were Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232215

Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 84 of 100 sor & Associates R planing and Transcription. lac. Page 58 1 looting for you, didn't you? 54 et 3i6 2 A. No. I knew -- 3 MR. LEOPOLD: Just answer it. It calls for 4 a yes or no. 5 THE WITNESS: Okay. No. 6 BY MR. TEIN: 7 Q. Now you can explain the answer that your 8 counsel stopped you from explaining. 9 A. Okay. I work at Quarterdeck and people 10 were telling me that people were looking for me. So yes, 11 I was aware that people were searching for me. But I had 12 no :dee who they were or what their intentions were. But 13 1 thought they were just people I didn't want to talk to. 14 So I just didn't want to talk to them. And every time 15 they'd come to work I wasn't there. And so happens the 16 night that they came in me and my friend switched name 17 tags. No big deal. 18 Q. That's a lie, isn't it? 19 MR. LEOPOLD: Objection. Don't answer that 20 question. That's harassment and I will not allow 21 it. He could ask the questions and we'll allow a 22 jury to make that determination, but not counsel. 23 I will not allow her to answer that' 24 question. 25 MR. TEIN: Certify it. Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00232216