10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO BW NY ODO oO FB WwW KN ~0929104. TXT COCONUT GROVE, FL 33133 On behalf of the Defendant: JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 WEST PALM BEACH, FLORIDA 33401 561.659.8300 ALSO PRESENT: KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, LEGAL -EZE | NDE X WITNESS: PAGE: DIRECT EXAMINATION 4 BY MR. TEIN: NO EXH!BITS MARKED Page 2 HOUSE_OVERSIGHT_012397
~0929104. TXT 14 15 16 17 18 19 20 21 22 23 24 25 4 7 Deposition taken before Judith F. Consor, 2 Court Reporter and Notary Public in and for the State of 3 Florida at Large, in the above cause. 4 ~ » « 5 Thereupon, 6 a 7 having been first duly sworn or affirmed, was examined 8 and testified as follows: 9 THE WITNESS: 1! do. 10 DIRECT EXAMINATION 11 BY MR. TEIN: 12 Q. Good afternoon. Please tell me your full 13 name. 14 a 15 Q. And can you please spel! it? — 7 Page 3 HOUSE_OVERSIGHT_012398
fo™ 18 19 20 21 22 23 24 25 —_ oOo Ont OD nN Be Ww NY 16 17 18 19 20 21 22 ~0929104 . TXT Q. Thank you. May | call you i? A. Uh-huh. Q. | I'm going to ask you a few questions, several questions today. If at any time you want to take a break, you just fet me know. Okay? A. Okay. Q. if you at any time don't understand one of my questions, will you just please let me know? A. Yes. Q. And if at any time you’re not feeling well or something like that, you'll! tell us, right? A. Yes. Q. Do you feel okay today? A. Yes. Q. Not taking any alcohol or drugs or anything like that, right? A. No. Q. So you feel ready to have your deposition taken? A. Yes. Q. MMMM what is your address? A. ]’m currently living at my aunt's house and | don’t know it off the top of my head. Q A Q. A Q A Where is it? In Jupiter. Who is your aunt? Who else is living there? PS vy uncle. Page 4 HOUSE_OVERSIGHT_012399
ue sy / 23 24 25 — oO Oo CNY Oo oO FF WwW DY ~0929104. TXT Q. Anyone else living there? A. No. Q. The contempt motion that your mother filed 6 against your father regarding your fifty million-dollar lawsuit against Jeffrey Epstein says that you live with your aunt and uncle and have been !iving there; is that correct? A. Yes. Q. How long have you been living with your aunt and uncle? A. Since my father kicked me out. Q. That was Thanksgiving of this past year? A. Yes, sir. Q, Okay. Didn't did your firefighter boy friend Po get an apartment for the two of you? A. No, sir. He has an apartment, but by himself. Q. Did he get an apartment for the two of you to live in? A, No, sir. Q. Are you planning to move in with him? A. Maybe one day in the future. Q. Do you have a plan to move in with him presently? A. No. Q. Have you been to the apartment that you and ae: discussed moving in together? Page 5 HOUSE_OVERSIGHT_012400
—_ oO Oo ON DO oO ek we o Pr WwW NM ~0929104. TXT | have been to the apartment. Where is that? Have you spent the night over there? No, sir. Do you know the address there? | do not. o> oP oP DD . Isn't your sister planning on living with you and ir A. No. Q. | you know that this court case is a criminal prosecution, correct? A. Correct. Q. And you know that it's a criminal prosecution against a man who has no criminal background. Do you know that? A. | do now. Q. You agree that court is a very serious matter? A. Yes. Q. And you're here with your lawyer Mr. Leopold, right? A. Yes. Q. And you know that Mr. Leopold recently Filed a lawsuit in federal court against Jeffrey Epstein, seeking fifty million dollars. MR. LEOPOLD: Let me just object. f let me instruct you. Anything that you have learned through conversations between you Page 6 HOUSE_OVERSIGHT_012401
BY MR. ~0929104.TXT and me are protected. So if you know any of that information outside of those discussions, you may answer. But if the only way you know it is through our discussions, do not answer that question. TEIN: Q. L you know that Mr. Leopold recently filed a lawsuit in federal court on your behalf against Jeffrey Epstein seeking fifty million dollars. BY MR. BY MR. MR. LEOPOLD: Same objection. If you know the answer to that outside of our discussions, you may answer. If it is the only way that you know the answer is through our discussions, do not answer that question. THE WITNESS: Okay. MR. LEOPOLD: Attorney/client privilege. TEIN: Q. You can answer the question unless -- MR. LEOPOLD: Same objection. MR. TEIN: Let me finish. MR. LEOPOLD: Excuse me. We're -- 9 MR. TEIN: No. Let me finish. MR. LEOPOLD: Lewis, we're not going to do that. MR. TEIN: My name is not Lewis. I'm going to finish my question. Okay? MR. LEOPOLD: Do not answer until you hear from me. TEIN: Page 7 HOUSE_OVERSIGHT_012402
—_ 10 11 12 13 14 15 16 7 18 19 20 21 22 23 24 25 — oO Oo OW NY TD oO FP WwW DY ~0929104. TXT Q. Other than conversations that you have had with Mr. Leopold -- |'m not asking about that -- are you aware that Mr. Leopold has filed a lawsuit in federal court. seeking fifty million dollars from Jeffrey Epstein on your behalf? MR. LEOPOLD: Same objection. Anything that you learn through conversations between you and me, do not answer. Those are protected. If you know through any other realm of Knowledge, you may answer. THE WITNESS: No. BY MR. TEIN: Q. You have no idea that Mr. Leopold filed a Fifty million-dollar lawsuit on your behalf against Jeffrey Epstein? MR. LEOPOLD: Same objection. Do not answer that question if it's through 10 discussions that you and | had. Outside of that, 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. Against, it's attorney/client privilege. Any information you've learned through conversations between you and [ are protected. If you know it through any other realm, you may answer. MR. TEIN: Are you going to say that for Page 8 HOUSE_OVERSIGHT_012403
14 15 16 17 18 19 20 21 22 23 24 25 —_ oO Oo MO 4 OD oO PF WwW PD ~0929104. TXT 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 jit on the record -- 1 MR. TEIN: You need to stop your speaking objections. Check your rules. MR. LEOPOLD: Excuse me. For the record, Counsel asked me a question. I'1!l state the answer on the record. He asked me the question am | going to be answering that way throughout the deposition. So long as there's improper foundation and predicate asked by the attorney, | will protect my client and | make the record where appropriate. If counsel wishes to ask an appropriate worded question with the proper foundation and predicate, | 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: | want the record to be Page 9 HOUSE_OVERSIGHT_012404
18 19 20 21 22 23 24 25 7 oO fm SN ODO oO Be WwW NY ~0929104. TXT 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 cancel led. But let's move on and maybe you'll stop obstructing this deposition. 12 MR. LEOPOLD: | think the record is very clear where we stand thus far. Is there a recording taken of this deposition? THE COURT REPORTER: Yes. MR. LEOPOLD: Just make sure that's preserved. BY MR. TEIN: Q. Go to Exhibit 20-01 -- well, before you do that, i, are you aware that a lawyer named Jeffrey Herman Filed a lawsuit on your behalf, yes or no? MR. LEOPOLD: Objection. Any conversations that you and | have had regarding that, if that is the only way by which you understand how to answer that question, so not answer. It's attorney/client privilege, as wel| as any conversations you may have had with the attorney from Miami. That is also attorney/client privilege. And I'm assuming -- MR. TEIN: You're actually wrong about the attorney/client privilege. MR. LEOPOLD: I'm assuming Counsel is not Page 10 HOUSE_OVERSIGHT_012405
~0929104.TXT 23 asking you to divulge attorney/client -- 24 MR. TEIN: Of course not. 25 BY MR. TEIN: 13 3 4 MR. LEOPOLD: Same objection. 5 MR. TEIN: We've heard the objection 10 6 times already. 7 MR. LEOPOLD: Counsel, excuse me. 8 MR. TEIN: Just say attorney/client 9 privilege. Stop interrupting my questions. 10 MR. LEOPOLD: I'm entitled to make an 11 objection for the record, which !'m doing, and 12 I’ || make the same objection. And if it calls for 13 attorney/client privilege, any conversations you 14 and | have had, do not answer the question. 15 And | think that it might be appropriate 16 for the record to ask questions i iii 17 as opposed to J | think that would be more 18 appropriate for this deposition. 19 BY MR. TEIN: 20 Q. Go ahead. Please answer yes or no. 21 22 Q. Thank you. 23 in fact, you know that Mr. Herman held a 24 press conference after he filed the fFifty-million-do} lar 25 lawsuit on your behalf, don't you? Page 11 HOUSE_OVERSIGHT_012406
—_ oO oOo ON OD oO Pe wH ON - WwW DM ~0929104. TXT 14 A. After it happened. Q. don’t you, yes or no? Ae Q. In fact, let's go to Exhibit 20-01. MR. GOLDBERGER: Look behind you. You'l] see it. BY MR. TEIN: Q. Have you ever seen that picture before? A. Yes. Q. Is that a picture of your father, your stepmother and Mr. Herman at the press conference regarding your lawsuit? A. Yes. Q. Now you know that this is a very serious matter, don't you? MR. LEOPOLD: Asked and answered. Objection. MR. GOLDBERGER: All right. You can object. You're representing a witness here, Mr. Leopold. You can object on privilege grounds. You cannot make legal objections. You have no standing to do so. MR. LEOPOLD: I'm going to make them and then -- 15 MR. GOLDBERGER: We're -- 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 Page 12 HOUSE_OVERSIGHT_012407
= on mn oo F&F WwW DN ~0929104.TXT of demeanor. !f 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 he 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. |'m going to make the record. | don't think it is appropriate, especially in the smal! 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. 16 THE COURT REPORTER: | need on at a time, no matter who it is. MR. LEOPOLD: | 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. Page 13 HOUSE_OVERSIGHT_012408
oo, 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ (o> en «°° @? @) 0 ~0929104. TXT MR. TEIN: Not taking a break unless the witness needs a break. You're obstructing this deposition, Ted. MR. LEOPOLD: Come on, You all want to continue in this demeanor -- MR. TEIN: You're obstructing the deposition. Stop making speeches. We're not discussing this with you. The questions are to your client. Go take your five-minute break. MR. LEOPOLD: Fine. We need to make sure the record's clear and clean. And | want to make sure as I've already asked you -- | 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, 7 Mr. Leopold, now. You were supposed to be here at nine a.m.; it's now after two. Take your break and come back. 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 [ suggest that you relax. MR. TEIN: | suggest that you take your break. MR. GOLDBERGER: Let them take that five-minute break. Page 14 HOUSE_OVERSIGHT_012409
~0929104. TXT 14 MR. LEOPOLD: But | would suggest that you 15 take deep breaths. 16 MR. TEIN: Suggest whatever you want. Go 17 take a break. 18 (Thereupon, a recess was taken.) 19 BY MR. TEIN: 20 Q. | you agree that giving testimony 21 today at your deposition is something very serious, don't 22 you? 23 A. Yes. 24 25 18 1 Q. Let me show you Exhibit 31-001. Can you 2 read that out loud, please? 3 A. Okay. What do you want? 4 Q Will you read that out loud, please. 5 A. Oh. 6 Q Thank you. 7 A & @: Like after so long wow 10 im sorry... well yah well we wil! definitely havta make 11 plans for sure..because i miss u tons times a million and 12 no no no i love you...0 p.s. ji love ur default pic 13° niggaa. Muah xo. 14 Q. Did you send that message last week to a 15 friend of yours on MySpace? 16 A. 1 wouldn't know. There's no dates and I've 17 deleted that MySpace, so -- Page 15 HOUSE_OVERSIGHT_012410
o™ 18 19 20 21 22 23 24 25 ~0929104. TXT We're going to talk about that in a second. Okay. Did you send that message last week -- Right. o> o> OS Let me Finish my question. Did you send that message last week to a friend of yours on MySpace? A. ! wouldn't know the date, but obviously, 19 it's to a friend. Do you find the term n-i-g-g-e-r offensive? That's not anywhere in there. What word did you use in there? MR. LEOPOLD: Where are you referring to, Counsel? There's 20 plus words in there. MR. TEIN: Don't make a speaking objection. THE WITNESS: Are you referring to anything -- MR. LEOPOLD: no, i Don't -- don't -- fet him ask you the question. BY MR. TEIN: Q. What question were you asking MR. LEOPOLD: She doesn't ask questions. You ask the questions. What is the question pending? BY MR. TEIN: Page 16 HOUSE_OVERSIGHT_012411
23 24 25 — oOo Oo ON ODO oO PF WwW NY ~0929104 . TXT Q. F | what is the last word on there in the text of your message before the closing? A. Niggaa. 20 Q. Don't you find that term offensive? No. MR. LEOPOLD: Can you spel! it for the record, please. THE WITNESS: N-i-g-g -- MR. TEIN: No, no, no. You are not going to be asking questions. MR. LEOPOLD: I|'m not asking questions. I'm asking for the record the word to be spelled because we don't have a video here today. MR. TEIN: These exhibits are part of the record. You -- MR. LEOPOLD: Well, it's not marked as an exhibit. MR. TEIN: Stop interrupting me, Mr. Leopold. | have marked and identified as an exhibit and you will get it. MR. LEOPOLD: There has been no identification of this document in the record. MR. TEIN: Mr. Leopold, stop interrupting this deposition. MR. LEOPOLD: What is the exhibit number marked for identification? MR. TEIN: 31-001. MR. LEOPOLD: Do we have copies? Is it on Page 17 HOUSE_OVERSIGHT_012412
coo wb oO O OA 4 Oo eF WwW NH — & WwW NY ~0929104. TXT 21 the record anywhere? BY MR. TEIN: Q. Let me ask you, | | did you in fact write your friend this message about this deposition? A. Yes. A. Yes. Q. Because you think this deposition is stupid court s-h-j-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 bul! 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. MR. TEIN: That's not an objection. 22 BY MR. TEIN: Q. You wrote that to your friend, didn't you? MR. LEOPOLD: Objection. Asked and answered, for the fourth time. Page 18 HOUSE_OVERSIGHT_012413
? — non 4 MD oO FP W LD ~0929104. TXT MR. TEIN: You are improperly objecting, Mr. Leopold. You have no grounds to object. And that's not an objection. MR. LEOPOLD: It is an objection. MR. TEIN: Then terminate the deposition if you think it's been asked and answered. MR. LEOPOLD: Counsel, | am not precluded from just making an objection to the form of the question. As the courts wel! know, and if you practice here in West Palm Beach, many of the judges require you to set the objection with specificity. And 1 will do that. And if you don't want me to, you can make the record. But | will do that. MR. TEIN: Here's what we'll! do, Ted. You can -- | will allow you to reserve an objection to form for every single one of my questions. Otherwise, all you're doing is obstructing. MR. LEOPOLD: | won't do that. MR. TEIN: Of course; because you want to obstruct. 23 MR. LEOPOLD: ATt right. BY MR. TEIN: Q. Saige, you think that giving testimony today, under oath, is bull s-h-i-t, don't you? A. No. Q. And you wrote that to your friend on MySpace last week, didn’t you? MR. LEOPOLD: Objection. Asked and Page 19 HOUSE_OVERSIGHT_012414
a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 13 ~0929104. TXT answered. THE WITNESS: No, | did not. BY MR. TEIN: Q. You didn't write this exhibit? A. ! wrote that, but | didn't write what you said. Q. You wrote in this exhibit, “1! got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't you write that? A. Yes. Q. Referring to this deposition, didn't you? A. Referring to the court. | was later informed that it was a deposition. Q. ['m going to ask you some questions now about what happened when you went to Jeff Epstein'’s house three years ago. Okay? A. Uh-huh. 24 Q. Now the civil complaint that you filed against Mr. Epstein for fifty million dollars alleged Page 20 HOUSE_OVERSIGHT_012415
14 15 16 7 18 19 20 21 11 12 13 14 15 16 17 ~0929104. TXT that you were totally shocked by what happened when you got there. A. Yes. Q. Were you totally shocked by what happened when you got to Epstein's house? A, Yes. Q. You didn't expect it at all, did you? No. Q. Did Zack JMJever try to convince you to engage in any sexual activity with Epstein? A. No. Q. Did Anthony P| every try to convince you to engage in any sexual activity with Epstein? A. | don't know who Anthony I is. Q. Do you have a friend Anthony? Page 21 HOUSE_OVERSIGHT_012416
18 ~0929104. TXT 26 Q. You're sure that -- let me ask the question again. MR. LEOPOLD: Objection. Asked and answered. And |'ve already answered that a bazillion times. BY MR. TEIN: Q. He's coaching you now. So I'm going to ask the question -- MR. LEOPOLD: Counsel, I've made an objection for the record. MR. TEIN: Stop speaking. MR. LEOPOLD: I'm not going to stop speaking. You can't interrupt me when I'm making the record. MR. TEIN: You're coaching the witness. MR. LEOPOLD: Counsel -- MR. TEIN: Stop coaching the witness. Page 22 HOUSE_OVERSIGHT_012417
23 24 25 —_ oO Oo ON DO oO Be wD NY ~0929104. TXT BY MR. TEIN: Q. | | let me ask you -- MR. LEOPOLD: If you continue to -- 27 MR. TEIN: Stop interrupting my questions. MR. LEOPOLD: Jf you do it one more time, we're leaving. BY MR. TEIN: 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. 1|’m entitled to make the record. | made an objection, asked and answered. You 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 you get the answer, to either follow up on it or move on, but not continuously browbeat and ask the same question over and over because you don't like the answer. MR. TEIN: Calm down, sir. MR. LEOPOLD: Trust me, I'm very calm here. When I'm not calm you'll know it. I'm very calm. So please continue on, but | will not allow you to continue to harass her in the demeanor that you're doing. Ask her a question and move on. MR. TEIN: Are you done? MR. LEOPOLD: Thank you. 1 am. Page 23 HOUSE_OVERSIGHT_012418
a oO O BN OO oO FF WwW DN - WwW DY ~0929104. TXT 28 MR. TEIN: Stop misrepresenting the record and calm down. I'm going to ask my question. Stop it. BY MR. TEIN: MR. LEOPOLD: | think the record is very clear. MR. GOLDBERGER: Let me just clarify something. When you object to the form of a question, you're not instructing the witness not to answer the question, are you? MR. LEOPOLD: No. And |'m not making that objection; only on attorney/client privilege. MR. TEIN: Will you stop speaking now so | can ask my question? Are you done? Okay. I'm going to ask my question. BY MR. TEIN: Q, Listen, I -- 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, | will not 29 put up with it and | don't need to put up with it and it's not appropriate. And I'm sure Mr. Goldberger knows al! this, because | know that he wouldn't do this. So ft will not put up with it. Page 24 HOUSE_OVERSIGHT_012419
~0929104. TXT 5 And | think it's highly inappropriate to do this 6 with this child sitting here, the way you're 7 acting, primarily towards me, and | wil] not put 8 up with it. 9 MR. TEIN: Will you please stop your speech 10 so | can ask questions? 11 MR. LEQPOLD: So long as you act 12 professionally, | will do so. But if you continue 13 to do it this way, | will leave. 14 MR. TEIN: Suit yourself. 15 BY MR. TEIN: 16 Ls 19 MR. LEOPOLD: Asked and answered. 20 Objection. 21 MR. TEIN: Did you get her answer? 22 THE COURT REPORTER: No, | did not. 23 24 BY MR. TEIN: Page 25 HOUSE_OVERSIGHT_012420
potty ~0929104 . TXT 31 A. No. Q. All right. Let me ask you two fina! areas of questioning about this and we'!! move onto something else. Okay? A. Uh-huh. Yes. I'm sorry. HOUSE_OVERSIGHT_012421
oN 20 21 22 23 24 25 a oO DSN DOD HO FP WwW DN ~0929104 . TXT Q. Was 7 or was it the other girl in the car who you rode over with toa Epstein's house? . Q. Who was the other girl in the car with you that day? A. | honestly don't know. 32 Q. Had you ever seen her before? A. No, sir. Q. You told the police that when you rode over to Epstein's you had no idea who she was, right? A. Correct. Q. You told the police that you didn't know her name, but she was like really dark, kind of like a Spanish girl? A. Yes. Q Those were your words, right? A Yes. Q. Do you now know who she is? A No, sir. Q So it was who told you to lie about your age to Jeff Epstein? A. Yes, Sir. Page 27 HOUSE_OVERSIGHT_012422
18 19 20 21 22 23 24 25 _— oO OWN OD om KH w when you out how you were assistan to colle BY MR. T much. on that? Q. All right. Let's talk for a minute about First met Jeff. Okay? A. Sure. Q. When you first met Jeff he tried to find old you were, right? A. Excuse me? 33 Q. During the massage Jeff asked you how old , correct? A. Yes, yes. Q. Now hadn't you already told Jeff's t, the one who walked you upstairs, that you went ge and had just moved down here from Ohio? A. ! never spoke to the lady. Q. Do you want to rethink that answer? MR. LEOPOLD: is that a question? EIN: Q. Do you want to rethink that answer? A. No. I didn't really speak with her that Q. Do you want to try to refresh your memory MR. LEOPOLD: Do you have something to refresh her memory with? MR. TEIN: Do you want to stop making Page 28 HOUSE_OVERSIGHT_012423
oo 23 24 25 — oO Oo OA NN Oo BP WwW YH speaking MR. ~0929104. TXT objections? LEOPOLD: No. But to refresh someone's memory you show them a document. 34 MR. TEIN: | know how to do this. MR. LEOPOLD: Then show her a document. MR. TEIN: Stop speaking. MR. LEOPOLD: I'm not going to stop speaking. I'm going to continue to make the record. MR. TEIN: You're obstructing. Please stop. MR. LEOPOLD: I'm not obstructing. But if you want to refresh her recollection, you need to show her something. That's not a proper question. | object to the foundation and the predicate of that question. MR. MR. BY MR. TEIN: Q. Do TEIN: Are you done? LEOPOLD: | am now. Thank you. you want. to try to refresh your memory as to whether you had any conversation with the woman who walked you upstairs in Epstein's house in which you told her that you went to college and had just moved down from Ohio? MR. LEOPOLD: Objection. Object to the form of the question. Lack of foundation and predicate. BY MR. TEIN: Page 29 HOUSE_OVERSIGHT_012424
—_ oO O@ 8B “4 OO oO FB WwW DH 14 15 16 17 18 19 25 2 3 4 Q. A. Q. ~0929104. TXT 35 You can answer the question. Sure. Is there anything that would refresh your memory that in fact you told Mr. Epstein's assistant, the one who walked you upstairs, that you went to college and you had just moved down here from Ohio? A. 1 don't remember saying that, but if you -- | don't remember saying that myself, so -- Q. A. Q. That would be a lie, right? No. | really don't remember. Do you remember Detective Michelle Pagan of the Police Department, Palm Beach Police Department? A. Q A. Q Q. Yes. Do you remember you spoke to her? Yes. Do you remember that you told Detective And do you remember telling Detective Pagan 36 that when you lied to Epstein about your age that you said it really fast so Epstein wouldn't realize you were lying? No, | don't remember saying those words Page 30 HOUSE_OVERSIGHT_012425
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oO ON KB wo ~0929104. TXT exactly to her. Q. Does it sound right to you that you told Detective Pagan that you said your age really fast to Epstein -- MS. BELOHLAVEK: Objection. Asked and answered. BY MR. TEIN: Q. ~- so he wouldn't think that you were lying? MR. LEOPOLD: Objection. Asked and answered, lack of Foundation, mischaracterization of her earlier testimony. She's already answered that question. BY MR. TEIN: Q. You can answer it. MR. LEOPOLD: Same objection. It's been asked and answered. You can answer. I've made the objection. THE WITNESS: | forget the question, now. 37 BY MR. TEIN: Q. Let me put it again. MR. LEOPOLD: Objection. Lack of foundation, asked and answered. Page 31 HOUSE_OVERSIGHT_012426
~0929104. TXT 11 BY MR. TEIN: 38 71 A. Yes, 2 Be | 4 In fact, you went of right? 5 Yes. 6 8 Q. Is Wellington the college that you told 9 Jeff's assistant that you were attending? 10 A. | don’t remember having that conversation 11 with her, so | wouldn't know if that's what | said. 12 Q. That was a fie, though, wasn't it? 13 MR. LEOPOLD: Objection to the form of the Page 32 HOUSE_OVERSIGHT_012427
~0929104 . TXT 14 question, lack of Foundation. You're making an 15 assumption. She just answered you she can't tell 16 you that. 17 MR. TEIN: Speaking objection. And you 18 well know that, Mr. Leopold. 19 MR. LEOPOLD: She can't answer that 20 question. The way you phrased that question, 21 you're purposely making her not be honest in her 22 testimony. She can't answer a question like that. 23 She doesn't remember. So then you say, "So you 24 were lying.” That's improper and you know that. 25 That's not a proper question. And any attorney 39 ~ 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 . 14 MR. LEOPOLD: Trust me. I'm very calm. 15 When 1 lose my cool, you'll know it. 16 MR. TEIN: 1 do know it. 17 BY MR. TEIN: Page 33 HOUSE_OVERSIGHT_012428
25 21 22 MR. LEOPOLD: Objection. Foundation, 40 predicate. BY MR. TEIN: Q. THE WITNESS: Correct. Incorrect. Well, you told the police, “At no time did Page 34 HOUSE_OVERSIGHT_012429
~0929104. TXT 23 he touch me." Were you lying to the police then? 24 A. No. Well, | wasn't being fully truthful, 25 but | wasn't lying. 41 1 Q. You told the police twice when you spoke to 2 Michelle Pagan that “at no time did he touch me." Didn't 3 you say that to the police? 4 A. Yeah. 5 Q. And you're saying that that was not fully 6 truthful. Is that what you're saying now? 7 A. Correct. 8 Q. And you're saying if you're not fully 9 truthful, that's not a lie. Correct? 10 14 Q. You told the police, "At no times did he 15 touch me." You agree with that, correct? 16 A. No, | 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 | do not remember. 21 OK Page 35 HOUSE_OVERSIGHT_012430
~0929104. TXT 42 3 4 Q. All right. Let's talk about what happened 5 after the massage was over. 6 A. Okay. 7 Q. After the massage you told Epstein that you 8 wanted to bring your twin sister back so she could make 9 some money, correct? 10 A. Incorrect. 11 Q. Your twin sister isi right? 12 A. Correct. 13 Q. And you love | very much, don’t you? 14 A. Yes. 15 Q. And when you left the house you were joking 16 with the other girls, weren't you? 17 A. Incorrect. 18 Q. Well, when and the other girl in the 19 car that day made their statements to the police they 20 told the police that you were joking afterwards. Are you 21 saying that they were lying to the police about that? 22 A. No. But a question or -- questions from 23 a -- 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 43 —_ things, but it wasn't joking about it at all. 2 Q. You joked about it, didn't you? 3 A. No. 4 Q. You said to ME that if you did this Page 36 HOUSE_OVERSIGHT_012431
~0929104. TXT every weekend you'd be rich, didn't you? A. No. That's what i told me. Q. You didn’t tell that to MR. LEOPOLD: Objection. Asked and answered. THE WITNESS: No. BY MR. TEIN: 15 16 17 18 21 22 23 24 25 on ~~ Dn wo SF WwW DY A. Incorrect. 1 didn't spend any of the money. You went to Marshall's, didn't you? A. | went along, yes, but | didn't -- MR. LEOPOLD: Objection. THE WITNESS: | guess you could say that. MR. LEOPOLD: Objection. Lack of predicate and foundation. Mischaracterization of earlier testimony. 44 BY MR. TEIN: Q. and bought a purse, right? A. Yes. Q. And you were with her the whole time at Marshall's, correct? A. Yes. Q. Now tell me about when the federal prosecutors told you about getting reimbursed. Page 37 HOUSE_OVERSIGHT_012432
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 =— oO ODN Oo FPF WwW YN ~0929104. TXT A. | have no idea what you're talking about. Q. Tell me about when the federal prosecutors spoke to you about getting money you feel you're entitled to from Mr. Epstein. A. | don't know what you're talking about. Q. Do you know who Marie Villafona is? A. No, sir. Q. Did you ever meet with any federal prosecutors? A. | think -- yeah. | think they were -- | think they were like FBI. Q. Uh-huh. Did you meet with federal prosecutors? A. They came to my house one time, yes. Q When did they come to your house? A. Very long ago. Q Was it this year, 2008? 45 It was not this year, no. Was it 2007? I'd have to say at least two years ago or a year ago, yeah. So it would be 2007, 2006; but it was a while ago. Q. How many federal prosecutors or FB! agents came to your house? A. i'm trying to remember. 1 want to say four people came. Q. Did they give you their business cards? A. If they did, | don't remember, and they weren't toward me. Maybe my parents have them. | don't know. Page 38 HOUSE_OVERSIGHT_012433
14 15 16 17 18 19 20 21 22 23 24 25 J 0 Oo OD NN ODO oO BP W PDH ~0929104. TXT Did they give you their cell phone numbers? No. Did you ever speak to them on their cel | phones? A. No, sir. Did they speak to your parents? A. That's something you'd have to ask my parents. Q. Do you know whether they spoke to your parent's? A. No, sir. Q. You have no idea? 46 A. No, sir. MR. LEOPOLD: Objection. Asked and answered, BY MR. TEIN: Q. So if | say the name to you Marie Villafona, you don't know who that is? A. No, sir. Q. How many women and how many men came to your house? A. 1 want to say two ladies and two guys. Q. Did someone named Jeffrey Sloman come to your house? A. | don't Know names, sir. Q Do you Know who Jeffrey Sloman is? A. No, sir. Q Do you Know who Jeffrey Herman is? A Yes. Page 39 HOUSE_OVERSIGHT_012434
18 19 20 21 22 23 24 25 —_ So Oo ONY OO oO Be WwW LD ~0929104. TXT Q. That's the lawyer who first sued Epstein on your behalf, right? A. Yes. Q. Has Mr. Herman advanced your family any money? MR. LEOPOLD: Any conversations that you've had with Mr. Herman regarding that issue, you are not to disctose. If you've learned in some other 47 fashion, you may answer. THE WITNESS: Okay. | wouldn't Know. BY MR. TEIN: Q, You don't know? Bo No. MR. LEOPOLD: Objection. Foundation. Attorney/client privilege. BY MR. TEIN: Q. And you say you don't know who Jeff Sloman is? A. No, sir. Q. Does it refresh your recollection that he's the number two prosecutor at the U.S. Attorney's Office? A. No. Q. That he’s Marie Villafona's boss? A. No. Q. Does it refresh your memory that he's the ex-partner of Jeff Herman, the first lawyer who sued you -- sued Mr. Epstein on your behalf for fifty million dol lars? A. No. | don't know who he is. Page 40 HOUSE_OVERSIGHT_012435
23 24 25 —y oo ON ODO oN BRB Ww ND ~0929104. TXT Q. Without telling me any conversations that you've had with your lawyers, how is it that you selected Mr. Herman as your lawyer from the 81,000 members of the 48 Florida Bar? A. | did not select him. Q Who did? A My father. Q. Did you ever meet Mr. Herman? A Once. Q Don't -- don’t tel! me what you discussed with him. Where did you meet him? A. | was shopping in my -- he showed up at my friend's house. Whose house? my triend i is that iii + on Yes. And did you have a meeting with him at ‘s house? Yes. | guess you could say that. And who else was there? My Aunt And what was that meeting about? oD. = P MR. LEOPOLD: Objection. That calls for attorney/client privilege. BY MR. TEIN: Q. What discussions did you have with Page 41 HOUSE_OVERSIGHT_012436
= o Oo On DOD oO FPF WN 1 ~0929104. TXT 49 Mr. Herman in the presence of i: A. None. Q. What discussions did you have in the presence of her aunt? A. Of my aunt? MR. GOLDBERGER: It's the witness's aunt. BY MR. TEIN: Q. On, of your aunt. A. The only one that we've ever discussed or ever had. Q. And so you were in a conversation with Mr. Herman and your aunt? A. Yes, sir. Q. And you discussed privileged matters during that conversation? MR. LEOPOLD: Object to the form. | think you might have to educate her on that question. BY MR. TEIN: Q. You discussed the lawsuit? A. Yes. Q. Did TT te you about any conversations that she had with Mr. Herman? A. As far as |’m concerned, she's never spoken or she's never had a conversation. She only opened the door and then left. She's the one who answered the door. 50 Q. Why did the meeting take place at a 2 fF house? 3 4 A. | spent the night that night at her house. Q. And when was this? Page 42 HOUSE_OVERSIGHT_012437
non ~ Oo on fF WwW DN ~0929104. TXT A while ago. How long ago? A month and a half ago. !'m guessing. A month and a half ago? Uh-huh. = f - 2 - Q. Did you meet what an FBI agent named Nesbit Kirkendall, a woman? A. | don't know. Q. Did Ms. Kirkendall speak to you about getting reimbursed from Mr. Epstein? A. I’ve never had a discussion with anyone about getting reimbursed from Mr. Epstein. Q, Have you met with an agent named Jason Richards? A. Not to my knowledge. Q How about an agent named Tim Slater? A. No, sir. Q How about an agent named Junior Ortiz? 51 A. No. Q. And we've learned that many of the girls, some of whom are as old as 23, were told by the government that they would get money at the end of the criminal prosecution. Does that sound familiar to you? A. No, sir. Q. Other than Mr. Leopold here -- I'm not asking about Mr. Herman either -- Page 43 HOUSE_OVERSIGHT_012438
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oO Oo OA OD TO SF W DN ~0929104. TXT A. Uh-huh. Q. -- did anyone ever discuss with you that you could get reimbursement for your damages? A. No, sir. Q. Did you or any member -- MR. LEOPOLD: Are you referring to a criminal matter or a civil matter? BY MR. TEIN: Q. Did you or any member -- MR. LEOPOLD: Excuse me. Let me object to the form of the question. BY MR. TEIN: Q. Did you or any member of your family ever get a victim notification letter from anyone? A. | no longer live at that residence and | wouldn't know. Q. So your testimony is that you have never 52 received a victim notification letter, correct? A. Correct. Q. And your testimony is that you don't know if your parents have ever received a victim notification letter, correct? A. Correct. Q. Have you given any evidence to prosecutors or law enforcement in this case? A. What do you mean by evidence? Q. Well. Anything that you can touch or feel? A. No. MR. LEOPOLD: Objection to the form of the question. Page 44 HOUSE_OVERSIGHT_012439
14 15 16 17 18 19 20 21 22 23 24 25 —_t oo Oo ON OD oO Be Bw PY ~0929104. TXT BY MR. TEIN: Q. So you haven't given anything physical -- A. No. Q. -- any item to any prosecutor, police officer or law enforcement agent, correct? A. My cell phone four years ago or three years ago, but that's it. Q. You gave your cell phone to whom? A. Michelle Pagan. “ Q. Did she keep it? Avs Ask her. Q. You gave it to her and then you didn't get 53 it back at the end of the meeting? A. No. They -- yeah. No. They have it. I'm guessing. [| don't have it. Q. How much money are you hoping to get out of Mr. Epstein? MR. LEOPOLD: Objection to the form of the question. Attorney/client privilege. BY MR. TEIN: Q. How much money are you hoping to get, you, yourself, hoping to get out of Epstein? MR. LEOPOLD: Same. Same objection, attorney/client privilege. Don't answer the question. BY MR. TEIN: Q. I'm not asking about what your lawyer told you. MR. LEOPOLD: [t'm instructing her not to Page 45 HOUSE_OVERSIGHT_012440
18 19 20 21 22 23 24 25 —_ oro Oo Oa NN OD oO Fe WwW NY ~0929104. TXT answer the question, because any of those conversations involve her counsel. MR. TEIN: Certify that. MR. LEOPOLD: Please. BY MR. TEIN: Q. Now, Saige, you lied to get out of this deposition, didn't you? 54 A. No, sir. Q. You didn't want to come to court today and tell the story that you had told to the police under oath, did you? MR. LEOPOLD: Object to the form of the question. Lack of foundation, predicate. THE WITNESS: No. | have no problem coming here and talking to you. BY MR. TEIN: Q. And to avoid getting served with a lawful subpoena, you lied about your name, didn't you? A. No. Q. And in fact, just lying yourself wasn't enough, was it? MR. LEOPOLD: Objects to the form of the question. Don't answer it. It's not a question. Object to the form of the question. Lack of foundation. MR. TEIN: Are you instructing her not to answer? MR. LEOPOLD: | am. Page 46 HOUSE_OVERSIGHT_012441
yay 23 24 25 —_ oO Oo an Om ao FF WwW LD ~0929104. TXT MR. TEIN: Certify it. MR. LEOPOLD: Please. 55 BY MR. TEIN: Q. You asked your co-workers -- MR. LEOPOLD: [t's vague and ambiguous. BY MR. TEIN: Q. You asked your co-workers at the ae lie for you, didn't you? A. No. | informed my boss about what was going on and he told me that he would help in any way that he can. Q. Okay. You got your friend J to lic by switching name tags with you, correct? A. Incorrect. It was a coincidence that same night she was not wearing her name tag; she was wearing mine. But | was also not wearing -- | was wearing my name tag. Everyone switches name tags. It just so happens it was a coincidence that same night the people came with the papers. MR. TEIN: Will you put up Exhibit 18-001? MR. GOLDBERGER: And mark 18-001 for identification purposes to this deposition. MR. LEOPOLD: None of them have been marked yet. Can we mark them and put them as attachment to the depositions? Because | think you've shown three photos now. And this is the only one that Page 47 HOUSE_OVERSIGHT_012442
- Ww NWN BY MR. T BY MR. T up on th ~0929104.TXT 56 has been marked for identification yet. EIN: 0. i MR. LEOPOLD: Hold on just a second. Just so the record is clear -- MR. TEIN: I'm not speaking to you. MR. LEQPOLD: Okay. Then don't speak to me then. But |'!! speak to Mr. Goldberger, perhaps. But at least for the record, can we put on the record what the previous two photographs were marked for identification? MR. GOLDBERGER: We wil! make sure that the record is clear at the end of the deposition so that there's no ambiguity. MR. LEOPOLD: Thank you. EIN: Q. | |'ve put a photograph marked 18-001 e screen. Do you see that? A. Yup. Q Who is that in the photo? A on the left and me on the right. Q. right? A Yes. Q FY your friend at the that the subpoena 57 A. Yes. Q. Pe your friend, who you say the day process servers went to serve you with a for this deposition, just happened -- just by Page 48 HOUSE_OVERSIGHT_012443
os oO ~~ OM oO FF W DY ~0929104 . TXT coincidence, was wearing your name tag? A. Yes, sir. Q. And just by coincidence, you were wearing her name tag, correct? A. Yes. Q. Your testimony under oath is that's just a coincidence, right? | A. Total honesty. Q. lt 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: Lo just answer the question. It calls for a yes or no. THE WITNESS: Yes. BY MR. TEIN: Q. 58 looking for you, didn't you? A. No. 1 knew -- MR. LEOPOLD: Just answer it. it calls for a yes or no. THE WITNESS: Okay. No. BY MR. TEIN: Q. Now you can explain the answer that your counsel! stopped you from explaining. Page 49 HOUSE_OVERSIGHT_012444
10 11 12 13 14 15 16 7 18 19 20 21 22 23 24 25 ay oO Oo OD NN OD oO PF WwW KN ~0929104. TXT A. Okay. ! work at MJ and people were telling me that people were looking for me. So yes, | was aware that people were searching for me, but | had no idea who they were or what their intentions were, but | thought they were just people | didn't want to talk to. So | just didn't want to talk to them. And every time they'd come to work | wasn’t there. And so happens the night that they came in me and my friend switched name tags. No big deal. Q. That's a tie, isn’t it? MR. LEOPOLD: Objection. Don't answer that question. That's harassment and | wil! not allow it. He could ask the questions and we'll allow a jury to make that determination, but not counsel. | will not allow her to answer that question. MR. TEIN: Certify it. 59 MR. LEOPOLD: I'Il certify it. She's answered that question. She's explained it five times already. The fact that Counsel doesn't jike the answer, that's a different query. MR. TEIN: Stop making speaking objections. MR. LEOPOLD: I'm not. I'm not going to put up with it, because it's in appropriate, Jack, and you know it. | will not allow Counsel to berate a witness, whether it's in a criminal case or a civil case, whether my client or -- MR. TEIN: Calm down. MR. LEOPOLD: Excuse me. Page 50 HOUSE_OVERSIGHT_012445
co™ 14 15 16 17 18 19 20 21 22 23 24 25 — oOo BOs Oo oO FP WwW DN ~0929104. TXT No, I’m not going to allow it. That is not proper. MR. GOLDBERGER: Okay. MR. LEOPOLD: If he wants to say that she's lying after asking it Five times and her explaining in great detail, he can do that. But |'m not going to allow her to answer, nor be harassed by him. It's improper. MR. GOLDBERGER: Okay. But your response that Counsel doesn't like the question -- or doesn't like the answer -- just let me finish. MR. LEOPOLD: Absolutely. 1! wasn't going 60 to interrupt you. MR. GOLDBERGER: Just requires us to say we like the answer to that question. And it’s not you and | or you and Mr. Tein who are testifying here. It's the witness. MR. LEOPOLD: Fine. But after the sixth time of asking the same question and then coming back and pointing a finger at her and saying, you're a liar -- MR. TEIN: That didn't happen. MR. LEOPOLD: That's fine. But I'm not going to allow her to answer that question because she's answered that same question and has explained it. Now Counsel might be sitting there rubbing his head with a migraine. That's his problem. But if he can't ask a question appropriately in a Page 51 HOUSE_OVERSIGHT_012446
18 19 20 21 22 23 24 25 —_ oOo ON OD oH eR Ww NY ; ~0929104. TXT professional manner, we will leave. [| will not allow her to be berated like that. MR. GOLDBERGER: Actually, we're very happy with the answer. MR. LEOPOLD: That's great. MR. GOLDBERGER: Do you want us to get into that? MR. TEIN: Ted -- 61 MR. LEOPOLD: This is really big stuff that you're going through, but that's fine; just ask your question and move on. But do it one time. If you don't understand it, I'll let you fotlow up, but |'m not going to allow you to ask the same question the time and again and then call her a liar. Just ask the question, get the answer and move to the next subject matter. MR. TEIN: Ted, I'm sitting right across the table from you. MR. LEOPOLD: Yes, sir. MR. TEIN: Please be quiet. Don't yell. MR. LEOPOLD: { will not be quiet. MR. TEIN: Stop yelling. MR. LEOPOLD: Lewis, when I'm yelling you'll know it. | will not -- MR. TEIN: My name is not Lewis. MR. LEOPOLD: | thought your first name was Lewis, Mr. Tein. MR. TEIN: You watched me for three days at the evidentiary hearing where you sat in the back of the courtroom. You should know who | am. Page 52 HOUSE_OVERSIGHT_012447
23 24 25 — oO Oo 8B NN DO oO PP & NG ~0929104. TXT MR. LEOPOLD: Well, that's the impression you must have made in the courtroom. | will not be quiet. 62 MR. TEIN: That's obnoxious. Stop being obnoxious. It's stupid. Let's go ahead with the questions. MR. LEOPOLD: { will make the record. MR. TEIN: Let's get on with the questions. MR. LEOPOLD: Do you need a break? (Thereupon, a recess was taken.) BY MR. TEIN: Q. Okay. P| after you told your manager at the [EE everything that was going on and he told you he would help you any way he could, he hid you in the kitchen from the process servers, correct? A. Incorrect. Q. isn't it true that lying to avoid service is a meaningless lie to you A. Incorrect. Q. What is your manager's name? A. 1 have three. Would you like to know all -- Q. Who's the one who Jied for you? A. Justin. Q. And what did Justin do to lie for you? A. Said | wasn't there. Q. And who did he tell wasn't there? A. Ask him. Page 53 HOUSE_OVERSIGHT_012448
dt oo A NN OD oO BR WwW NN - WwW NW ~0929104. TXT 63 Q. Where were you when Justin told this someone that you were not at the ee: A. Eating nachos. A. Yes. Q. What did you do so that Justin would lie to the process servers for you? A. Nothing. Q. You just got him to lie for you, didn't you? A. No. | had no influence on him saying | wasn't there. Q. He took that upon himself? Isn't it true that Mr. Epstein's process servers had to ask the police to get you out of the restaurant so that they could serve you? MR. LEOPOLD: Objection. Lack of foundation, predicate. BY MR. TEIN: Q. You can answer the question. MR. LEOPOLD: If you Know. Don't guess. THE WITNESS: No. Can you repeat the question? MR. TEIN: Don't coach. MR. LEQPOLD: Don’t guess. 64 MR. TEIN: That's a coaching. MR. LEOPOLD: No. That's an instruction to the client. MR. TEIN: No. You don't do that. Page 54 HOUSE_OVERSIGHT_012449
— on Oo TO B&B WwW DN ~0929104.TXT THE WITNESS: Can you repeat the question? MR. LEOPOLD: Let me just state for the record -- BY MR. TEIN: Q. Once the police -- isn't it true that Mr. Epstein's process serves had to ask the police to get you out of the restaurant so that they could serve you? A. Incorrect. My boss called the police. Q. And once the police showed up, to stop you from lying to avoid service, you made up another lie that the process servers had harassed you. t[sn't that correct? A. Incorrect. You lie all the time, don't you? MR. LEOPOLD: Objection. THE WITNESS: Incorrect. BY MR. TEIN: Q. You have a MySpace page, don't you? A. No longer do | have a MySpace page. | deleted it. . Q. When did you delete your MySpace page? 65 A. A couple days ago. Q. Who told you to take your MySpace page down a couple of days ago? A, Nobody. I'm sick and tired of MySpace. Q. You all of a sudden got sick and tired of MySpace and just a few days before this deposition you decided to delete your MySpace page, correct? A. Correct. Page 55 HOUSE_OVERSIGHT_012450
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 —_ oo Oo ON OF OH FPF WwW DN ~0929104. TXT Q. Is that your testimony under oath? A. Yes. Q. Did you take your MySpace page down because you thought the government might subpoena it? A. Incorrect. Q. Hadn't your MySpace page been up for over three months before you took it down? A. Correct. But | also had made tons of MySpaces over the last years. | just get tired of them and delete them because drama and make new ones. Q. We're going to talk about that. So you deleted your MySpace page after you were already under subpoena for this deposition, correct? A. Correct. Q. What about the MySpace page didn't you want us to see, pg A. Nothing. 66 Q. Well, we're going to come back to MySpace in a second. A. You do that. Q. | | I'm going to ask you some questions about why you lie about your age so often, okay? MR. LEOPOLD: Objection to the form. Argumentative. BY MR. TEIN: Q. You lie about your age all the time, don't you? MR. LEOPOLD: Objection, argumentative. THE WITNESS: Incorrect. BY MR. TEIN: Page 56 HOUSE_OVERSIGHT_012451
: a 14 15 16 17 18 19 20 21 22 23 24 25 _ Co Oo BS OO ee WwW LD ~0929104. TXT Q. You lie about your age to get body piercings, don't you? A. Incorrect. Q You have body piercings, don't you? A. Yes. Q You have four body piercings; isn't that right? A. Five. Q. Other than the pierceings on your ears -- I'm not talking about that -- A. Oh, then no; just one. Q. And where is the one body piercing? 67 Belly. When did you get that? For my birthday, with my stepmother and my father. Q. And when was that? A. When | was 14. Q. Okay. So you had that body piercing when you met Epstein, correct? A. It might have been, or maybe that -- yeah, either my 14th birthday or my 15th. | honestly don't remember . Q. Now you've lied about your age to get into bars by using driver's licenses that aren't yours, correct? A. Incorrect. Q. Are you swearing under oath that you've never done that? Page 57 HOUSE_OVERSIGHT_012452
18 19 20 21 22 23 24 25 —_ oO 8 OD SD HO BF WwW DN ~0929104. TXT A. Yes, | swear under oath. Q. And you've lied about your age to buy beer, correct? A. Incorrect. Q. You're swearing under oath that you've never lied to stores about your age? A. I've never lied to a store about my age or anything. 68 Q. You try to look much older than you are, don't you? A. Incorrect. Q. And you've lied about your age on your MySpace pages, don't you? A. Incorrect. Q. All right. Let's look at Exhibit 26-01 one. MS. BELOHLAVEK: 26-0017? MR. TEIN: Yes. BY MR. TEIN: Q. Let's go to Exhibit 33. MS. BELOHLAVEK: That's 33-001? TEIN: Correct. BY MR. TEIN: Q. On this page you lied to everyone that you were 19, didn't you? A. Incorrect. MR. LEOPOLD: Just answer the question. Page 58 HOUSE_OVERSIGHT_012453
23 24 25 — oO oO BAN Oo on FF WwW LD ~0929104. TXT THE WITNESS: Oh, incorrect. BY MR. TEIN: Q. Now you can explain your answer. 69 A. | Know that | have seen all of these and | Know that this one is mine. Can you go down? MR. LEOPOLD: Just for the record, you're pointing to the photo. THE WITNESS: I'm pointing to -- BY MR. TEIN: Q. That's yours, right? A. Correct. That's mine from a couple years ago that | have not been on base | don't use that. Please keep going down, please. And | think that's it, because there's no one -- just that one is mine. Q. And when you wrote 18 as your age on your MySpace page, that was a lie, wouldn't it? A. Correct. Q. Did you lie about your MySpace page back then because you couldn't post on MySpace unless you were 18? A. Correct. There was a rule many years ago Page 59 HOUSE_OVERSIGHT_012454
— 14 15 16 17 18 19 20 21 22 23 24 25 —_ &- WwW DY ~0929104 . TXT 70 that you had to be 18 to have a MySpace. Q. So you lied about your age so you could post on MySpace, right? A. Yes. Q. Let's go back to the top one on this page, 33-01. Q. Now let's go back to the one that you were pointing to before on this page, where it says your age is 18 and you lied about your age to post MySpace, okay? A. Uh-huh, yes. Q. Atl right. Why did you finally put your true age on your MySpace profile four days before you MR. LEOPOLD: If you don't understand, ask him to ask the question again. MR. TEIN: Don't coach. THE WITNESS: | don’t know which MySpace 71 you're talking about. BY MR. TEIN: Q. The MySpace page that you're just pointing to, where it says you were 18. Page 60 HOUSE_OVERSIGHT_012455
Oo ~~ Dm oO FP WwW DN ~0929104. TXT A. Yes. Q. Why did you finally post your true age on your MySpace profile -- A. Uh -- Q. -- four days before you were scheduled to testify before the Grand Jury? A. | honestly don't know which MySpace, because I've had like a bazillion MySpaces and in that year, | had two, that one and another one and that one's been deleted. So | don't know which one you're referring to. A. No. Q. You don't remember that. A. No. Q. Do you remember Detective Recarey? Did you ever meet a Detective Recarey? 72 As, | don't know the names. Q. How many different detectives have you met with on this case from Palm Beach? A. Probably a good six or seven, maybe. Q. Did one of the detectives tell you before you testified in the Grand Jury that you should take your MySpace age and put your true age? A. No. Page 61 HOUSE_OVERSIGHT_012456
10 17 12 13 14 15 16 17 18 19 20 21 22 23 24 25 om oO On OD TO BP W PD 12 13 ~0929104. TXT Q. Didn't Detective Recarey have to come to your house to pick you up to get you to testify in front of the Grand Jury? A. Possibly, maybe because | didn't have a ride. | was only 14 or 15 at the time. Q. Your mom didn't drive you? A. No. Q. Stepmom didn't drive you? A. | think my dad. Oh, my dad / my dad drove me. Q. Your dad drove you? A. Yes, sir. Q. So your testimony is Detective Recarey did not drive you, correct? MR. LEOPOLD: Objection /asked and answered. THE WITNESS: No. I'm pretty sure my dad 73 drove me because he was there with me. BY MR. TEIN: Q. Did any detective tell you to change your age on your MySpace page to put your true age? A. No, sir. Q. Now you also lied on your MySpace page about your income, didn't you? As Yes. Q. That was a lie, wasn't it? Yes. Page 62 HOUSE_OVERSIGHT_012457
a 14 15 16 17 18 19 20 21 22 23 24 25 “ oOo ON ODO oO PF WwW NH ~0929104. TXT Q. Now you also tie to the police, don't you? A. No. Q. Well, you lied to the police in your tape-recorded statement that you gave to Detective Michelle Pagan three years ago, didn't you? A. To my knowledge, no, | did not. Q. Well, you lied to the police when you accused Mr. Epstein of attempting to murder your father, 74 didn't you? A. No. 1 never heard a statement saying that Mr. Epstein tried to murder my father. Q, You made that statement, didn't you? MR. LEOPOLD: Do you have a statement to show her? That's been asked and answered. MR. TEIN: I'm sorry. | didn't hear the witness’ answer, Mr. Leopold. BY MR. TEIN: Q. | | you told the police, didn't you, that Mr. Epstein almost killed your father, didn't you? A. No. | Q. Three years ago, before Mr. Epstein even Knew about this investigation, you told the police that Epstein had “already come to my dad's house and did something to my dad's tires and my dad almost died. | didn't want my dad to get hurt, because Jeff already Page 63 HOUSE_OVERSIGHT_012458
18 19 20 21 22 23 24 25 —_ oO Oo Oa 4 OD oO fF WO NWN ~0929104.TXT almost killed him." Didn't you say that? A. Not to my knowledge or recollection. | have never said anything !ike that. A. Yeah. Q. Because Mr. Epstein never came to your 75 dad's house, correct? A. Correct. Q. And no one who worked for Mr. Epstein ever did something to your dad's tires. Did they? MR. LEOPOLD: Objection. Lack of foundation, predicate. Don't guess. BY MR. TEIN: Q. It's not true that Mr. Epstein almost killed your father, is it? MR. LEOPOLD: Objection. Asked and answered, lack of foundation, predicate. BY MR. TEIN: Q. You can answer. A. No. Q. Now you told the police that you didn't know who was in the car with you and Hayley on the day you went to Epstein's house, didn't you? Yes. And that was a lie, wasn't it? It's the truth. o> 2 > You told the police that there was someone Page 64 HOUSE_OVERSIGHT_012459
23 24 25 —_- oOo Os DOD oO FR WwW DN ~0929104. TXT in the car next to you and you specifically said you didn't know her name, right? A. Correct. | do not know her name. 76 Q. You said, “I don’t know her name, but she was dark like a Spanish girl." Those were your words, right? A. Yes. MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. Who was in the car that day with you and a A. Again, |t do not know. Q. It was your good friend i . wasn't it? A. No. 1 don't know a x. Q. You [ied to the police about who was in the car with you and | | didn't you? A. Incorrect. Q. Let. me ask you some questions about who you may have spoken to about this case. All right? A. Go ahead. Q. Did you speak to your I sister A. Not in detail, but of course she knows; she's family and yes. Q. What's her e-mail? A. | don't think she has an e-mail. Q. What is her phone number? Page 65 HOUSE_OVERSIGHT_012460
aa kt - WwW DY ~0929104. TXT 77 A. Oh, gosh. | don't know off the top of my head. Q. And what is her home address? ie She lives with my mom. Q. In Georgta? A. Yes, Sir. Q. What about is boy friend Paul? Did you speak to him about Epstein's case? A. That's my mom's boy friend. My sister doesn't have a boy friend. My mom's husband's name is Paul, so maybe you get them confused. Q. Do you know his phone number? A. No. Q. Where does he live? A. With my mom. Q. In the same house with her? A. Yes. They're married. Q. So not boy friend; husband? A. Yeah, husband. Q. Have you spoken to prect [i about what happened in Mr. Epstein's house? A. Not in detail, but he knows the basics, yes. What is his e-mail? | don’t know. 78 Q. What is his phone number? A. How is that relevant? Q. What is his phone number? A. Page 66 HOUSE_OVERSIGHT_012461
~~ porn ~0929104. TXT 5 Q. What is his home address? 6 A. | don't know. 7 Q. Where does he live? 8 A. in EE somewhere. 9 Q. Ever been to his house? 10 A. Yes. 11 Q. You don't know what his address is? 12 MR. LEOPOLD: Objection. Asked and 13 answered. She just said she doesn't know. 14 MR. TEIN: Don't coach. 15 MR. LEOPOLD: Objection. Asked and 16 answered. 17 BY MR. TEIN: 18 Q. You can answer the question. 19 A | don't Know the exact address. 20 Q. What street is it on? 21 A It'S an apartment complex; its not a 22 street. 23 Q. What's the name of the apartment complex? 25 Q. What apartment number is it? 79 1 A. 1} couldn't tell you. 2 Q. When was the last time you went there? 3 A. Just visited this past weekend. That's the 4 first and fast time | went there. 5 Q. How about steven IP Have you spoken 6 to him about your case? 7 A. No. We no longer speak. 8 Q. What's his phone number? Actually, we Page 67 HOUSE_OVERSIGHT_012462
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 — oO OD NN TD oO FP WwW NY ~0929104.TXT already have his phone number room and e-mail. How about ee: Have you ever spoken to her about your case? A. ! don't know an FY Q. Have you ever met ae: A. No. But just to let you know, | don't really know names. If you have pictures, of there faces |} could tell you. Q. All right. Let me see if | can refresh your memory. A. Okay. Q. Does it refresh your memory that Is the other gir! who made allegations about Epstein, but refused to show to the Grand Jury when she had to testify about them under oath? A. No, sir. 1 have no knowledge of any other girls in this whole situation. We're not allowed to know 80 each other. Q. And what about a: Have you of met her? A. No, sir. Q. Let's see if | can refresh your memory on her. She's the other person represented by your lawyer Mr. Herman, who is suing Epstein for fifty million dollars. A. | have no knowledge of her. Never met her? Never met her. Page 68 HOUSE_OVERSIGHT_012463
— 14 15 16 17 18 19 21 22 23 24 25 —_ oo oO ON OO Fe WwW | Q. A. Q. ~0929104. TXT vony | don't know who that is either. A person named Anthony who knows SP Is that Tony i? A. | don't know, sir. Q. Do you remember making a statement to ' Detective Pagan that’s in the police reports? A. No. Q. Have you read the police reports in this case? A. Yes. Q. They're on the Internet, right? 81 A. Yes, | think. Q. You didn't want to see that happen, right? No. So you're saying you don't know a Tony MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. Does it refresh your memory that he was somebody who had gone to jail for drugs and car theft? A. No, sir. Q. Someone who knows a? No. Page 69 HOUSE_OVERSIGHT_012464
18 19 20 21 22 23 24 25 —_ oO @ @ Ns DMD oH & WwW DN ~0929104. TXT Q. You don't know if he met with Detective Recarey? A No, sir. Q How about Zack A. Yes, | remember. | know who that is. Q Did you ever speak to Zack J about what happened at Mr. Epstein’s house? A. He Knows what happened four years ago. He 82 doesn't know this is still going on today. Q. What's his address? I'm sorry. 1 have his address. A. | don't Know. Q. How about Nick a: Q. You know who that is? A. | know who that is, yes. Q. He's the one you stayed out drinking al! night one night last year when your dad reported you missing? A. No, sir. Q. Remember the baseball! game you were supposed to go to? A. No, sir. Q. Did you speak to Nick MM about this case? No, sir. How about Patrick | lg That's my sister's ex-boy friend. PF Go He's the one with the sawed-off shotgun with the obliterated serial number? Page 70 HOUSE_OVERSIGHT_012465
23 24 25 —_ oo Oo OWN ODO OH BR WwW DY 22 23 24 25 A. information. Q. case? A. Q. case? A. Q. A. Q. to who he is. A. Q. your father? A. Q. A. ~0929104. TXT Ask him. | would not know that Did you speak to Patrick PE abou this 83 No, sir. Have you spoken to John P| about this No. | don't know who John is. Did your parents speak to John Ask my parents. Let's see if | can refresh your memory as Okay? Uh-huh. How much money did John Connolly give to | don't even know he gave money to my dad. I'm sorry? | didn't even Know he gave money to my dad. Page 71 HOUSE_OVERSIGHT_012466
—_ oo @ ONY DO oO FPF WD > WwW DN ~0929104 . TXT 84 Q. What do you know about the dea! that John Connolly has with your father? A. | only know they spoke on the telephone once. | don't know anything else. Q. When was that? A. This was a while ago, a year or two or a year ago. 1 honestly don't know. Q. Did John Connolly the Vanity Fair reporter offer any money to your father? A. i don't know. Q. Did John Connolly, the Vanity Fair reporter, give you any money? A. No, sir. Q Did he offer you any money? A No, sir. Never spoke to him. Q. What reporters have you spoken to? A Zero. Q. What about your fem Iy members? What reporters have they spoken to? A. The whole Palm Beach County, obviously, as you can see in that newspaper. Q. Tell me -- let's go through each one that you remember. OQther than the Vanity Fair reporter, John Connolly, what other reporters have any member of your family spoken to? 85 A. i don't know. And | know my mom has spoken to zero. My sister spoke to zero. My father and stepmother, | wouldn't know. You'd have to ask them. | don't contact them. Page 72 HOUSE_OVERSIGHT_012467
a ao nt fm oO fF WwW DN ~0929104. TXT Q. Well, | just want to know -- | don't want you to -- | want to know what's in your mind? AIl right? MR. LEOPOLD: She just told you. She just answered -- MR. TEIN: Be quiet. BY MR. TEIN: Q. What | want to know is what you know from your personal knowledge. My opinion question to you is: What knowledge do you have about family members of yours speaking to reporters? MR. LEOPOLD: Objection. Asked and answered. And if you can't talk professionally, we're going to leave. MR. TEIN: Do what you want to do. MR. LEOPOLD: Are you going to continue to talk this way? MR. TEIN: I'm not going to answer any question that you ask me, Mr. Leopold. MR. LEOPOLD: Okay. MR. TEIN: But you are misrepresenting the 86 record and you are grandstanding for your client and it's wrong. So be quiet. And you know how to make an objection. Make it. Otherwise stop talking. BY MR. TEIN: Q. Saige -- MR. LEOPOLD: €&xcuse me. MR TEIN: If you want to leave the Page 73 HOUSE_OVERSIGHT_012468
c™ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oy oOo ON OF ON Rh WwW DN ~0929104. TXT deposition, leave. But you'l| be back here. MR. LEOPOLD: Excuse me. if | could just make the record, instead of interrupting me, please, that's what we do professionally. There's a recorder here. I|'m certainly not being obstructionist. I|'m going to make the record. But we're going to act with some semblance of professionalism, hopefully, by all parties in the room. That goes to me, that goes to your co-counsel sitting behind you and next to you, the court reporter and everyone else in the room. Everyone goes entitled to that. You've asked a question. She answered the question fully and she's not going to be harassed because you don't like the answer. If you want to follow up -- MR. TEIN: Stop engaging me. Make your 87 speech and then we'!l! ask the questions. MR. LEOPOLD: Well, you won't let me finish making the objection, so it's difficult to do that. But if you want to follow with an appropriate question, feel free to do that. But we're not going to harass the witness. MR. TEIN: 1 disagree with everything you've said. Let's ask the questions. Okay? MR. LEOPOLD: Ask an appropriate question. MR. TEIN: Are you going to stop talking? MR. LEOPOLD: I'm going to make -- protect my client and make appropriate objection, but there's not a question pending right now. Page 74 HOUSE_OVERSIGHT_012469
aoo™ 14 15 16 17 18 19 20 21 22 23 24 25 son oO Oo ON TD oO FP WwW DY ~0929104. TXT BY MR. TEIN: Q, a has spoken to any reporters? A. No, MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. Has MB ocon given money by any reporters? A. No. Q. Has your mom spoken to any reporters? MR. LEOPOLD: Objection. Asked and answered. 88 THE WITNESS: No. BY MR. TEIN: Q. Has your mom's husband Paul spoken to any reporters? A, No. Q. Has your mom's husband Paul received any money from reporters? A. No. Q. Are you sure you don't know a: MR. LEOPOLD: Objection. Asked and answered. THE WITNESS: I'm positive. BY MR. TEIN: Q. I’ ll try again to refresh your memory. A. Okay. Q. Does it refresh your memory that she had been arrested for drugs and was cooperating with Page 75 HOUSE_OVERSIGHT_012470
18 19 20 21 22 23 24 25 ad oO Oo Os DMD oO BR WwW DY ~0929104. TXT Detective Recarey against Epstein to get herself a better deal? A. No. | don't know who she is. Q. Have you spoken to anyone else who's been at Epstein's house? A. No. Q. Without telling me what was said -- ! don't want to Know about any conversations with any lawyers, 89 okay -- A. Uh-huh. Q. -- did you or your parents speak to any other law firms besides Mr. Herman and Mr. Leopold's law Firms? No. Q. Now without telling me about anything that was said, what -- did one just come to mind? A, No. | was thinking about something else. Q. What were you thinking about? A. Does family court matter? Q. Okay. Without telling me what was said, who prepared you for todays deposition? A. What do you mean prepared? Q. Did you talk about this deposition, about what would happen, with anybody? A, Yes. Q Don't tell me what was said? A. Okay. Q I'm not asking that. | don't want to know that. A. Okay. Page 76 HOUSE_OVERSIGHT_012471
23 24 25 — oo 8B 4 TO NO RF WwW PD A. Q. ~0929104 . TXT Who prepared you for today's deposition? Mr. Leopold. Anybody else? 90 No. When did you meet with Mr. Leopold to prepare for today's deposition? A. Q A. Q This morning. And how long did that meeting last? Until it started. Now you told me that you previously had read the police reports in this case? A. Q. Yes. Have you read your statement that you gave to the police? A. Q. A. Q. transcript? A. Q. it. A police A. Q. A. ago. Yes, sir. And in what form was that statement? What do you mean? Was it in the form of a police report or a What's the difference? A transcript has questions and answers on report is just typed out narrative. Oh, it's a police report. And when did you read the police report? A few days ago. | overread it a few days Had you read it before that? No. Page 77 HOUSE_OVERSIGHT_012472
— oo Oo OD NY OD oH BF WwW —_ > W DY ~0929104. TXT 91 Q. Now you told me -- again, | don't want to know what was said. A. Uh-huh. Q. You told me that you met with Mr. Leopold this morning to prepare for your deposition, right? A. Yes. Q. When did you set up that meeting with Mr. Leopold to take place this morning? A. Gee, like, like five days ago, four days ago. Q. So you're aware that Mr. Leopold told us that he could not start the deposition this morning because he had a court appearance, correct? MR. LEOPOLD: Don't answer that question. Calls for attorney/client communications. BY MR. TEIN: Q. Have you seen the letter that Mr. Leopold wrote to us stating that he -- an e-mail that Mr. Leopold wrote to Mr. Goldberger stating that he could not be here this morning because healed a court appearance? Did you see that e-mail? MR. LEOPOLD: You can answer that question. THE WITNESS: No. BY MR. TEIN: Q. Have you listened to your tape-recorded 92 statement to the police? A. Yes. Q. Where did you listen to that? A. In, | think, this building. 1 don't know. Page 78 HOUSE_OVERSIGHT_012473
ao 4s DO oO FF WwW ND ~0929104. TXT It was here. Q. When did you listen to that statement? A. This morning. Q. And who was present when you |istened to that statement? A. Mr. Leopold -- and | forget your name. MR. GOLDBERGER: Ms. Belohlavek. THE WITNESS: Ms. Belohlavek. BY MR. TEIN: Q. And you hadn't listened to your statement before that, correct? A. No, str. Q. Have you met with lawyers representing anyone else suing Epstein? A. No, sir. Q. When was the last time you spoke with officers of the Palm Beach Police Department? 93 A. A while ago. I'd say a year ago. Q. A year ago? A. Yeah. Maybe a year and a half. Q. Do you remember Detective Recarey? A. No. Q. Do you remember Michelle Pagan, Detective Pagan? A. Yes. Page 79 HOUSE_OVERSIGHT_012474
(~~ 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oO Oo Os OD OH BF WwW DY ee or | wo NO = ~0929104. TXT Q. How many times have you spoken to Detective Pagan? A. She was the only one | spoke to about this until for some reason she wasn't on the case anymore. Q. When was that? A. The first meeting | ever had was with her and then | think like |! met with her And who was that? | don't remember. Q. And what type of questions did they ask you? A. The same, Q. The same questions all over again? A. Basically. Q. How many taped statements have you given to 94 the police? A. One that | know of. Q. Just the one with Detective Pagan? A. Yes, sir. Q. How about to the FBI? Did you give any statements to them? A. No. Well, actually. 1 don't really remember if that was taped or not to be honest with you. | had one meeting with them at my house and don't know if it was taped. Q. You were interviewed at Po house? A. No. That was by the lawyer. Page 80 HOUSE_OVERSIGHT_012475
14 15 16 7 18 19 20 21 22 23 24 25 —_ oo On ODO om PB we PY 17 ~0929104.TXT Q. Oh, boy the lawyer? A. Uh-huh. Q. Where did the conversation that you had with the FBI take place? At my father's residence. Which is where? On Downers in Loxahatchee. On where? Downers Road in Loxahatchee. - Fr FP And when did that take place? A. ['d have to say like a year and a half ago, a year ago. It was a long time ago. 95 (Discussion held off the record.) MR. TEIN: Tell me the last answer, please. (Thereupon, a portion of the record was read by the reporter.) BY MR. TEIN: Q. And who was present when the FBI spoke to you at your father's house? A. My stepmother was there, but she wasn't around. She made herself like do other things. Q. And how many FB! agents were there? A. ! think four. Q. And you don't remember any of their names? A. No, sir. Q, And were there any lawyers there? A. Not that I know of. Q. And none of them gave you their cel! phone numbers? Page 81 HOUSE_OVERSIGHT_012476
om 18 19 20 24 22 23 24 25 —_ oo Oo OND OH Rh WwW NY ~0929104. TXT A. lt was a while ago. MR. LEOPOLD: Objection. Asked and answered. BY MR. TEIN: Q. And the last time you spoke to the federal 96 prosecutor's office was when? A. | don't know. Q. Did any of the FBI agents tell you that Marie Villafona had spoken with Mr. Leopold? A. No. Q. Did any of the FBI agents tell you that Marie Villafona had spoken with Mr. Herman? A. No. Q. Did any FBI agents tell you that Jeff Sloman spoke with Mr. Herman. A. No. Q. Did any FBI agents tell you that Jeff Sloman spoke with Mr. Leopold? A. No. Q. Do you know whether any of the federal prosecutors allowed Mr. Herman to review a draft indictment? A. i wouldn't know. Q. Da you know if any of the federal prosecutors discussed a draft indictment with Mr. Herman? A. f wouldn't know. Q. Have you ever e-mailed with any FBI agent Page 82 HOUSE_OVERSIGHT_012477
23 24 25 7 oO OD SN OO FF WwW DH ~0929104 . TXT or any federal prosecutor? A. No. Q. Have you ever text messaged with any FBI 97 agent or any federal prosecutor? A. No. Q. Has the FBI told you about other testimony? A. No. Q. Has the FBI told you about what other girls have said? A, No. Q. Have federal prosecutors told you what other girls have said? A. No. Q. Do you have any way of getting in touch with the FBI tf you wanted to get in touch with them? A. No. Q. How about your parents? Do they know how to get in touch with the FBI? A. } don't know. Q. And by your parents, I'm referring to both sets, okay? A. Oh. Well, I'm referring to only my dad, because my mom really doesn’t care to know any of this stuff. Q. So the answer would be the same for your mom and Paul? A. Yeah. —~ Q. Have you spoken to a lawyer named Burt Page 83 HOUSE_OVERSIGHT_012478
— oc Oo OWN DO Be Ww NY b&b W DY ~0929104. TXT 98 Ocariz about this case? A. No. Q. Do you know who Burt Ocariz is? Let's see if | can refresh your memory. Does it refresh your memory that he's a good friend of Marie Villafona's boyfriend? A. | don't know who Mari Villafona is. Q. Marie Villafona is the lead federal prosecutor that's on the federal part of this case. Okay? A. No. Q. So does it refresh your memory that Ocariz is the good friend of Marie Villafona's boy friend? A, Not at all. Q. Does it refresh your memory that Villafona tried to get Epstein to pay for Ocariz to represent you in the federal case? A. No. Q. Do you know if Detective Recarey has spoken with your father? A. No. Q. Do you know if Detective Recarey has spoken to your stepmother? A. No. Q. How about with amber? 99 A. Yes, | would know, and no, she did not. Q. Let's put up -- let me ask you some questions about the photo that you had posted on your MySpace page before you erased it last week. Okay? Page 84 HOUSE_OVERSIGHT_012479
—_ on OD ao FB W DY ~0929104. TXT A. Okay. MR. TEIN: Do you mind if we close the door a second, please. MR. LEOPOLD: Exhibit number, please. MR. TEIN: Put up 25-005. Hold on a second. MR. LEOPOLD: Don’t say anything. She was talking to her counsel. MR. TEIN: Put up 25-006. MR. LEOPOLD: Is that 005 right there? MR. TEIN: Yes. BY MR. TEIN: MR. LEOPOLD: Objection. Mischaracterizes the photograph, and lack of foundation and predicate. Fully explain if you need to. THE WITNESS: | will. First of all. 100 Second of all, I’m not being gang-raped. Everyone has their clothing on. Thirdly, if you look at all the other pictures in this album, |'m drinking -- what's when you're sick you drink it? BY MR. TEIN: Q. You can't ask questions of your counsel. A. All right. -'m drinking Tike Sprite. t'm Page 85 HOUSE_OVERSIGHT_012480
om 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oO Oo oO 4 TO OH FPF WwW DY —_— tk —_ 12 13 ; ~0929104.TXT note drinking any kind of alcohol, if you would lIaok at my other pictures in that album. You guys picked the possibly worst pictures out of there to present. And it was just a goofy picture. All of these kids like to be goofy. And that's what we were doing. Q. Who's the man on the left of the picture holding his -- holding a beer bottle as if it were a penis towards your mouth? A. Steven a. Q. Who's the man behind you, right up towards your backs side, with you bent over? A. That one? Q. The right side, kissing with his mouth. A. That's Nick SD Q. He's the one grabbing towards the groin area of Steven | A. Yes. 101 Q. And there's three other men in the photo. What are their names? The one on the left with the hat? A. That's Robbie P| (phonetic) . Q. Smiling? A. Yes. Q. Who's the one kissing -- MR. LEOPOLD: Don't interrupt. Let her finish the record. She's testifying. MR. TEIN: § Know you don't like this picture, my friend. MR. LEOPOLD: The picture is fine. BY MR. TEIN: Q. Who's the one with the hat? Page 86 HOUSE_OVERSIGHT_012481
fo ™ 14 15 16 7 18 19 20 21 22 23 24 25 wood oO on OO Fe WwW LH ~0929104.TXT MR. LEOPOLD: No. Hold on. Stop, iia You have to let the witness finish her answer. She was in the process of explaining and you cut her off. Please finish what you were saying and then Counsel can ask you whatever he wishes after that. THE WITNESS: Okay. This guy -- MR. LEOPOLD: Just make it so the record is clear who you're referring to. THE WITNESS: -- on the far left is John BY MR. TEIN: 102 Q. He's the one whose head is near the groin of Steven a, right? A. Yes. Q. And in the middle there's a man smiling. Who's that? A. That's Robbie nn Q. Who's the one in the red hat, kissing? A. Most Brandon | (phonetic). Q. Let me stop you for a second. Are you done? A. Yes, I'm done. Q. who is iP A. My sister's friend. Well, she’s a mutual friend, but more my sister's. Q. What is her last name? . Q. Spell that. Page 87 HOUSE_OVERSIGHT_012482
a, ‘. 18 19 20 21 22 23 24 25 —_ oo 0 Oo NY ODO oO eB Ww > Oo > o> ~0929104. TXT | don't know how to -- Have you spoken to her about this case? No. Who's Vince? My sister's friend. | don't really speak to him at all. case? What's his last name? 103 And have you spoken to Vince about this No, sir. Have you spoken to a about this case? Not in detail, but yes. MS. BELOHLAVEK: Are we referring to BY MR. TEIN: ca) SP > P+ o> DO > THE WITNESS: Yes. MR. TEIN: Yes. MS. BELOHLAVEK: Okay. Have you spoken to Justin about this case? Justin? Do you have a friend named Justin? | do not have a friend named Justin. From freshman year? No. How about |g No. Have you spoken to || about this case? Page 88 HOUSE_OVERSIGHT_012483
f—™ ~0929104. TXT 23 A. No. 24 Q. What's her last name? 25 A. a. | don't Know how to spell it? 104 1 Q. is she the person whose house you went to 2 on New Year's this year? 3 A. No. | wasn't at her house on New Year's. 4 Q. Where were you when you took the picture of 5 Can you say blazed? That on your website? 6 A. | wouldn't know or -- wait. We were at a 7 birthday party for some girl's 16th birthday. 8 Q. Were you drinking at that party? 9 No. There was no alcohol or anything 10 ~=there. 11 Q. What does "blaze" mean to you? 12 A. It's Like -- it just means like messed up. 13 But we weren't, if you look at the picture. 14 Q. Messed up like drunk, right? 15 A. Sure. 16 Q. Who's a: 17 A. A girl | know like from like two years ago. 18 Q She's the one you were supposed to be 19 staying with when you went drinking with Nick iP 20 A. No. 21 Q. what's Ss fast name? 22 J i. 23 Q. Where does she live? 24 A. | don't know. In Royal Palm. Page 89 HOUSE_OVERSIGHT_012484
— oO Oo 8 4S DO oO FF WwW DN —_ - WwW NY oO FoF Oo drinking. pretending to Who are they? A. Q. A. ~0929104. TXT 105 Uh-huh. {'m guessing. Do you know her phone number? No, | do not. Let's look at 25-010. See, I'm drinking -- I'm not asking you about what you're Who are the men in this photo who are gang up on you and stab you with knives? Nick | and Brandon BE (phonet ic). Are they firemen? Are those? Steven a -- he said the two stabbing with knives. That's why | said that. | don't know. That's Steven | and John a. Q. A. Are these firemen? No. They're all on -- except Steven, they're all on full rights for football. Q. BY MR. TEIN: Q. penis? A. idea? A. Go to 025-015? MR. LEOPOLD: 025- dash? MR. TEIN: 015. THE WITNESS: Gosh, that's so long ago. Who took the photo have you ticking the 106 My stepmother. Whose idea -- that was your stepmother's lt was in Buca di Beppo, where she works Page 90 HOUSE_OVERSIGHT_012485
on DO oO FR WwW DN ~0929104. TXT currently and that was before she worked there, and we just thought it would be funny. MR. TEIN: 19-007. Can you enlarge that? BY MR. TEIN: Q. Who took this photo of you simulating you having sex with a man? A. We're not simulating having sex, and it's -- oh, and the person who took it was, I'm pretty sure, Chris, but | know him as | don't Know his last name. Q. Go to 19-006, please. Who took this photo of you simulating sex with a man? A. The same person. And we're not simulating having sex, Mr. -- Q. Tein. Did you post that on the Internet? A. Actually, this is an old MySpace | never Finished and | never [ike did anything. 1 just kind of made it and left it. Q. So the answer is yes, you posted this on 107 MySpace? A. Yup. Q. Go to 25-016. Who took this photo of you simulating sex with a woman? MR. LEOPOLD: Object to the form of the question. Argumentative. THE WITNESS: First off, she's piercing my belly button or repiercing it, and I'm pretty sure Page 91 HOUSE_OVERSIGHT_012486
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ccorh oO OWN DMD OH PB WwW DN ~0929104. TXT it was just like we put up a camera somewhere and put a timer on it. We didn't have anybody take it. BY MR. TEIN: D ep FD > BY MR. TEIN: Q. correct? A. Q. You posted that on your MySpace page? Yeah. Go to 25-013. Is that a photo of you? Yep. Who's in the photo with you? Steven. Steven a: Yep. is this you coming out of the shower? Yes. Are you clothed in this picture? Yeah. 1 have a halter dress on. Where is that picture taken? 108 In Steven's house. Did you post that on the Internet? Yes. All right. MR. TEIN: You can take that down. Now your boy friend is Brett Yeah. You lie about your age in order to conceal something about your relationship with Brett a. isn't that correct? A. No. Page 92 HOUSE_OVERSIGHT_012487
14 15 16 7 18 19 20 21 22 23 24 25 ver oO oOo OWN OOo eR Oh UN ~0929104.TXT Q. Brett's 22 years old, isn’t he? A, Yes. Q. And Brett is a firefighter with the Palm Beach Fire Department, right? A. Yup. Q. Does the Palm Beach Fire Department know that your boy friend is dating an underage girl? A, Actually, Mister, it's legal. Q. Well -- MR. LEOPOLD: Just answer the question, a THE WITNESS: Yes. 109 BY MR. TEIN: Q. Did they know two weeks ago that you were dating an underage gir! (sic)? A. Yes. | met everybody in there. Q. Did they know your age? A. Yes. Q. Did you lie about your age so that the fire department wouldn't think that Brett is committing a crime by having a sexual relationship with an underage girl? MS. BELOHLAVEK: Objection. Assumes facts not in evidence. BY MR. TEIN: Q. You can answer the question. A. No. Q. Does the Palm Beach Police Department know that Brett is having a sexual relationship with an Page 93 HOUSE_OVERSIGHT_012488
18 19 20 21 22 23 24 25 —_— oO Oo OA SYS OD oO B@ Ww DY ~0929104. TXT underage girl? MR. LEOPOLD: Don't guess. Answer if you know. THE WITNESS: Can you repeat the question? BY MR. TEIN: Q. You lie about your twin sister don't you? MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: Q. Don't you? A. No. | have never lied for or to | | Q. You lie about the fact that she has as drug habit, right? A. No. | would never accuse my sister of having a drug habit. Q. Do you try to conceal the fact that she has a drug habit? MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: Q. You can answer the question. A. No. My sister does not have a drug habit. Q. You [ied when you went to the crack house in Georgia, didn't you? MR. LEOPOLD: Objection. Argumentative. Lack of foundation, lack of predicate. THE WITNESS: Never -- what did you say? Page 94 HOUSE_OVERSIGHT_012489
oo 23 24 25 oO Oo OW SN OD oO F WwW DY = mM mM NM NY NY ND S| BB BSB ew |S | ws Go a 4 ao fF WwW NY -F= FC 0 8 4 DBD A BF WwW DY =F ~0929104. TXT BY MR. TEIN: Q. You |ied when you went to the crack house in Georgia, didn’t you? 111 MR. LEOPOLD: Objection. Argumentative. Lack of foundation, lack of predicate. BY MR. TEIN: Q. You can answer the question. A. | have never been to a crack house. Q. Who don't you lie to? MR. LEOPOLD: Objection. Argumentative. Don't answer the question. MR. TEIN: Certify it, Le eee eee eee CERTIFIED QUESTION.................. BY MR. TEIN: Q. You don't lie to | do you? MR. LEOPOLD: Objection. Asked and answered. Don't answer the question. BY MR. TEIN: Q. No. You can answer that question. MR. LEOPOLD: No. I| just told her not to. You've asked that question about five -- MR. TEIN: No, | haven't. MR. LEOPOLD: Don't answer the question. MR. TEIN: I'll certify it. MR. LEOPOLD: For the record, you have to stop interrupting me because she can't take down Page 95 HOUSE_OVERSIGHT_012490
pes, 2 3 4 ~0929104. TXT both of us talking at the same time. BY MR. TEIN: Q. You tell | i truth, don't you? Excuse me? You tell | truth, don't you? When it's -- yes, | tel! HE tne truth. who's [BBs drug dealer? ep SP, My sister does not have a drug dealer. She lives in Georgia with my mother. Q. Okay . you and a or at 5:45 a.m. in 2006, after being out all night, the two of you, using drugs at Palm Beach Country Estates where your father called the police? A. | Q. He's the drug dealer? A. He is a drug dealer. Q. Do you remember Jl was arrested by the Palm Beach Police Department and taken to the Juvenile Assessment Center that morning? A. 1 do remember that. Q. Now before you massaged Epstein, you were involuntarily admitted into a juvenile educational facility; isn't that right? A. Did you say involuntarily. Q. Yes. 113 A. No. | was willing to go. | -- duly said sure. Q. And you went there because you were lying so much, no one could control you; isn’t that correct? Page 96 HOUSE_OVERSIGHT_012491
7 18 19 20 21 22 23 24 25 oO ~~ DMD oO fF W DN ~0929104. TXT A. Very incorrect. Q. Now you lie to your parents all the time, don't you? A. Incorrect. MR. LEOPOLD: Objection. Argumentative. BY MR. TEIN: Q. Sorry? A. Incorrect. Q. You admitted to the police that you told your father that you were going shopping, didn't you? A. Yes. Q. And isn't it true that your father has accused you of lying? A. Atl the time. Q. Didn't your father throw you out of the house Thanksgiving of this past year because you were lying so much to him? A, Yes, he did kick me out. No, that’s not the reasons why. Q. Didn't your father throw your sister out of the house, too? A. Yes. Q. And he threw her out of the house the week Page 97 HOUSE_OVERSIGHT_012492
— _ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 oO Oo BAN OD oO SF WwW NB ey wo No ~0929104 . TXT after Thanksgivings, right? A. | don't know the date, but sure. Q. Sounds about right? A. Sure. Q. And the reason he threw her out of the house was because she was lying, too? MR. LEOPOLD: Objection. Lack of foundation. Calls for speculation. BY MR. TEIN: Q. When your counsel coaches you, you say it's correct, right? A. I've never been coached. MR. LEOPOLD: Objection. BY MR. TEIN: Q. Okay. When your counsel! that it was there was lack of foundation, you agree with your counsel, right? As | was like saying, Yeah, let's move on, because there was no point to asking that question. Q. Your father threw I out of the house because she was lying, correct? MR. LEOPOLD: Objection. Lack of foundation. Hold on, i Let me just make the objection. Lack of foundation, predicate, calls for speculation. BY MR. TEIN: Q. Answer . A. t'm not my sister. | don't know. Page 98 HOUSE_OVERSIGHT_012493
14 15 16 17 18 19 20 21 22 23 24 25 —_ oO OO OB Ss OD oT FB WwW DN ~0929104. TXT Q | want to know what you know only. A | don't know. Q. You don’t Know. That's your answer? A Yes. Q Now your parents filed the police report regarding Mr. Epstein, right? they? A. Yes. Q. Now your parents are also lying, aren't A. Yes. MR. LEOPOLD: Just so the record is clear, the father -- because the mother was up north. MR. TEIN: Don't testify, Counsel. MR. LEOPOLD: So the record is clear, the father -- the mother was -- MR. TEIN: Counsel, don't coach and testify, please. That's absolutely improper. MR. LEOPOLD: You just asked the wrong question. MR. TEIN: You can't coach her that way and you wel! know it. MR. LEOPOLD: For the record, it's the father. He's remarried, | think on his third marriage. MR. TEIN: You cannot -- it's absolutely, totally against the rules and you know it. MR. LEOPOLD: The natural mother fives in Georgia. MR. TEIN: You need to behave yourself, Page 99 HOUSE_OVERSIGHT_012494
18 19 20 21 22 23 24 25 —_ oO @ A 4 DP oO fF WwW DN ~0929104. TXT lawyer. MR. LEOPOLD: The natural mother lives in Georgia. The father is here locally. MR. TEIN: Stop coaching. Stop talking. You object. You know the rules. You just lectured me about the rules, Counsel. So why don't you play by the rules. Or only when they Fit you? Why don't you grandstand a little more 17 now. Give us a five-minute speech, Mr. Leopold. MR. LEOPOLD: Are you finished, for the record. MR. TEIN: I'm not talking to you. Do what you want. MR. LEOPOLD: Don't say anything yet. BY MR. TEIN: Q. a your parents -- MR. LEOPOLD: Hold it. Don't say anything yet. Let me -- BY MR. TEIN: Q. Your parents, who filed the police report are also liars. MR. LEOPOLD: Don't answer the question. We're not going to answer until! | make the record. | want to put on the record, now that Counse| appears to be finished with his comments for the record, that the previous question was inappropriate, was intentiona!!ly misleading. Now you can ask the question. BY MR. TEIN: Q. Your parents, who filed the police report Page 100 HOUSE_OVERSIGHT_012495
i ™ 23 24 25 — oO 0 Oa NOD HN Be WwW ON ~0929104. TXT in this case, are also proven liars, aren't they? MR. LEOPOLD: Same objection. BY MR. TEIN: 118 Q. Aren't your parents liars? MR. LEOPOLD: Calls for speculation. Lack of predicate. MR. TEIN: Stop coaching. You know what that is, Leopold. MR. LEOPOLD: Calls for speculation. Lack of foundation. THE WITNESS: When you say parents, my mom is not, but sure, yeah, my dad has been to jail for iying. BY MR. TEIN: Don't jook to your lawyer for the answer. MR. LEOPOLD: You can answer if you know the answer to it. 1 have no idea. Page 101 HOUSE_OVERSIGHT_012496
































