EFTA00234324.pdf

Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 1 of 100 nsor & Associates RepornnE sad Transcripoon. Inc Page 75 1 Q. Because Mr. Epstein never came to your 2 dad's house, correct? 3 A. Correct. 4 Q. And no one who worked for Mr. Epstein ever 5 did something to your dad's tires, did they? 6 MR. LEOPOLD: Objection. Lack of 7 foundation, predicate. 8 Don't guess. 9 BY MR. TEIN: 10 Q. It's not true that Mr. Epstein almost 11 killed your father, is it? 12 MR. LEOPOLD: Objection. Asked and 13 answered, lack of foundation, predicate. 14 BY MR. TEIN: 15 Q. You can answer. 16 A. No. 17 Q. Now you told the police that you didn't 18 know who was in the car with you and IIIIIII on the day 19 you went to Epstein's house, didn't you? 20 A. Yes. 21 Q. And that was a lie, wasn't it? 22 A. It's the truth. 23 Q. You told the police that there was someone 24 in the car next to you and you specifically said you 25 didn't know her name, right? Ph. 561.682.0905 - Fax. 561.682.1771 1010716 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 EFTA00234324  Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 2 of 100 nsor & Associates Ropor•.1np and *I ranscnpacm. Inc Page 76 1 A. Correct. I do not know her name. 2 Q. You said, "I don't know her name, but she 3 was dark like a Spanish girl." Those were your words, 4 right? 5 A. Yes. 6 MR. LEOPOLD: Objection. Asked and 7 answered. 8 BY MR. TEIN: 9 Q. Who was in the car that day with you and 10 fl 11 A. Again, I do not know. 12 Q. It was your good friend 13 wasr't it? 14 A. No. I don't know a 15 Q. You lied to the police about who was in the 16 car with you and didn't you? I e, 17 A. Incorrect. 18 Q. Let me ask you some questions about who you 19 may have spoken to about this case. All right? 20 A. Go ahead. 21 Q. Did you speak to your twin sister . 22 A. Not in detail, but of course she knows; 23 she's family. And yes. 24 Q. What's her e-mail? 25 A. I don't think she has an e-mail. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1020/316 EFTA00234325  Case 9:08-cv-80804-KAM rnent 1-2 Entered on FLSD Docket 07/21/2008 Page 3 of 100 sor & Associates herynning and Transcription, Inc. Page 77 1 Q. What is her phone number? 2 A. Oh, gosh. I don't know off the top of my 3 head. 4 Q. And what is her home address? 5 A. She lives with my mom. 6 Q. In Georgia? 7 A. Yes, sir. 8 Q. What about '11111iboyfriend..? Did you 9 speak to him about Epstein's case? 10 A. That's my mom's boyfriend. My sister 11 doesn't have a boyfriend. My mom's husband's name is 12 so maybe you get them confused. 13 Q. Do you know his phone number? 14 A. No. 15 Q. where does he live? 16 A. With my mom. 17 Q. In the same house with her? 18 A. Yes. They're married. 19 Q. So not boyfriend; husband? 20 A. Yeah, husband. 21 Q. Have you spoken to about 22 what happened in Mr. Epstein's house? 23 A. Not in detail, but he knows the basics, 24 yes. 25 Q. What is his e-mail? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 103 W715 EFTA00234326  Case 9:08-cv-80804-KAM D ent 1-2 Entered on FLSD Docket 07/21/2008 Page 4 of 100 sor & Associates Kellam op and Transc riRon. Inc Page 78 1 A. I don't know. 2 Q. What is his phone number? 3 A. How is that relevant? 4 Q. What is his phone number? 5 A. 561.719.2652. 6 Q. What is his home address? 7 A. I don't know. 8 Q. Where does he live? 9 A. In Palm Beach Lakes somewhere. 10 Q. Ever been to his house? 11 A. Yes. 12 Q. You don't know what his address is? 13 MR. LEOPOLD: Objection. Asked and 14 answered. She just said she doesn't know. 15 MR. TEIN: Don't coach. 16 MR. LEOPOLD: Objection. Asked and 17 answered. 18 BY MR. TEIN: 19 Q. You can answer the question. 20 A. I don't know the exact address. 21 Q. What street is it on? 22 A. It's an apartment complex; its not a 23 street. 24 Q. What's the name of the apartment complex? 25 A. Something Cove. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 16101316 EFTA00234327  Case 9:08-cv-80804-KAM ent 1-2 Entered on FLS Docket 07/21/2008 Page 5 of 100 nsor & Associates Rcparuni.: and Transcrip:i an. Inc. Page 79 1 Q. What apartment number is it? 2 A. I couldn't tell you. 3 Q. When was the last time you went there? 4 A. Just visited this past weekend. That's the 5 first and last time I went there. 6 Q. How about Have you spoken ININEr 7 to him about your case? 8 A. No. We no longer speak. 9 Q. What's his phone number? Actually, we 10 already have his phone number and e-mail. 11 How about IIIIIIIIIP Have you ever 12 spoken to her about your case? 13 A. I don't know an 14 Q. Have you ever met 15 A. No. But just to let you know, I don't 16 reaLly know names. If you have pictures of there faces I 17 couLd tell you. 18 Q. All right. Let me see if I can refresh 19 your memory. 20 A. Okay. 21 Q. Does it refresh your memory that Mir is the other girl who made allegati ons about Epstein, but 22 23 refused to show to the Grand Jury when she had to testify 24 about them under oath? 25 A. No, sir. I have no knowledge of any other Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 105 Of 316 EFTA00234328  Case 9:08-cv-80804-KAM ment 1-2 Entered on FLSD Docket 07/21/2008 Page 6 of 100 nsor &Transcii Assoc po co, Inc. iates Repnnung and Page 80 1 girls in this whole situation. We're not allowed to know 2 each other. 3 Q. I didn't get the last four words. 4 A. We're not allowed to know each other. 5 Q. And what about Have you 6 of met her? 7 A. No, sir. 8 Q. Let's see if I can refresh your memory on 9 her. She's the other person represented by your lawyer 10 Mr. Herman, who is suing Epstein for fifty million 11 dollars. 12 A. I have no knowledge of her. 13 Q• Never met her? 14 A. Never met her. 15 Q. 16 A. I don't know who that is either. 17 Q. A person named who knows . 18 Is that OM. 19 A. I don't know, sir. 23 Q. Do you remember making a statement to 21 Detective Pagan that's in the police reports? 22 A. No, sir. 23 Q. Have you read the police reports in this 24 case? 25 A. Yes. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 106 o1316 EFTA00234329  Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 7 of 100 nsoranil& Associates Roponinp. TrinsCriptioli. Inc. Page 81 1 Q. They're on the Internet, right? 2 A. Yes, I think. 3 Q. Were you surprised when the police reports 4 were released on the Internet containing your statements 5 that you had made to the police? 6 A. Yes. 7 Q. You didn't want to see that happen, right? 8 A. No. 9 O. So you're saying you don't know a 10 11 MR. LEOPOLD: Objection. Asked and 12 answered. 13 BY MR. TEIN: 14 Q. Does it refresh your memory that he was 15 somebody who had gone to jail for drugs and car theft? 16 A. No, sir. 17 O. Someone who knows . 18 A. No. 19 Q. You don't know if he met with Detective 20 Recarey? 21 A. No, sir. 22 Q. How about INS 23 A. Yes, I remember. I know who that is. Q. Did you ever speak to l about what 24 25 happened at Mr. Epstein's house? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 107ot 316 EFTA00234330  Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 8 of 100 nsor & Associates Rept-bring rind 17anscripticm. Inc Page 82 1 A. He knows what happened four years ago. He 2 doesn't know this is still going on today. 3 Q. What's his address? I'm sorry. I have his 4 address. 5 A. I don't know. 6 Q. How about 7 A. gut 8 Q. You know who that is? 9 A. I know who that is, yes. 10 Q. He's the one you stayed out drinking all 11 night one night last year when your dad reported you 12 missing? 13 A. No, sir. 14 Q. Remember the baseball game you were 15 supposed to go to? 16 A. No, sir. 17 O. Did you speak to about this - 18 case? 19 A. No, sir. 20 Q. How about 21 A. That's my sister's ex-boyfriend. 22 Q. He's the one with the sawed-off shotgun 23 with the obliterated serial number? 24 A. Ask him. I would not know that 25 information. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 108 W715 EFTA00234331  Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 9 of 100 nsor & Associates Repnrunp and lranscnpnon, Inc Page 83 about this 1 Q. Did you speak to 2 case? 3 A. No, sir. Q. Have you spoken to allarir bout this 4 5 case? A. No. I don't know who is. 6 a 7 0. Did your parents speak to Illinir 8 A. Ask my parents. 9 Q. Let's see if I can refresh your memory as 10 to who he is. Okay? 11 A. Uh-huh. 12 Q. He's the Vanity Fair reporter who made a 13 financial arrangement with your father. 14 A. I am aware of that. And again, I was not 15 aware like that my dad did it until after it was done. 16 And I don't know the details about that. I just know 17 what you know about that, like that they talked. 18 Q. Tell me what you know about the financial 19 arrangement that MM. the Vanity Fair reporter, 20 made with your father. 21 A. I don't know about the details at all. 22 Q. How much money did give to MOM 23 your father? 24 A. I don't even know he gave money to my dad. 25 Q. I'm sorry? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 109 01316 EFTA00234332  Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 10 of 100 sor & Associates ;tenoning and Transcription, Inc Page 84 1 A. I didn't even know he gave money to my dad. 2 Q. What do you know about the deal that mir 3 has with your father? 4 A. I only know they spoke on the telephone 5 once. I don't know anything else. 6 Q. When was that? 7 A. This was a while ago, a year or two or a 8 year ago. I honestly don't know. 9 Q. Did MEM the Vanity Fair 10 reporter, offer any money to your father? 11 A. I don't know. 12 Q. Did the Vanity Fair 13 reperter, give you any money? 14 A. No, sir. 15 Q. Did he offer you any money? 16 A. No, sir. Never spoke to him. 17 Q. What reporters have you spoken to? 18 A. Zero. 19 Q. What about your family members? What 20 reporters have they spoken to? 21 A. The whole Palm Beach County, obviously, as 22 you can see in that newspaper. 23 Q. Tell me -- let's go through each one that 24 you remember. Other than the Vanity Fair reporter, 25 IIIMIWwhat other reporters have any member of your Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 1100316 EFTA00234333  Case 9:08-cv-80804-KAM ent 1-2 Entered on FLSD Docket 07/21/2008 Page 11 of 100 sor & Associates Repining end Transcription, Inc. Page 85 1 family spoken to? 2 A. I don't know. And I know my mom has spoken 3 to zero. My sister spoke to zero. My father and stepmother, I wouldn't know. You'd have to ask them. I 4 5 don't contact them. 6 Q. Well, I just want to know -- I don't want 7 you to -- I want to know what's in your mind. All right? 8 MR. LEOPOLD: She just told you. She just 9 answered -- 10 MR. TEIN: Be quiet. 11 BY MR. TEIN: 12 Q. What I want to know is what you know from your personal knowledge. My question to you is: What 13 14 knowledge do you have about family members of yours 15 speaking to reporters? 16 MR. LEOPOLD: Objection. Asked and 17 answered. 18 And if you can't talk professionally, we're 19 going to leave. 20 MR. TEIN: Do what you want to do. 21 MR. LEOPOLD: Are you going to continue to 22 talk this way? 23 MR. TEIN: I'm not going to answer any 24 question that you ask me, Mr. Leopold. 25 MR. LEOPOLD: Okay. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 ill oI316 EFTA00234334  Case 9:08-cv-80804-KAM Do rpent 1-2 Entered on FLSD Docket 07/21/2008 Page 12 of 100 nsor & Associates Reporting and Transc Finnan, Inc Page 86 1 MR. TEIN: But you are misrepresenting the 2 record and you are grandstanding for your client 3 and it's wrong. So be quiet. And you know how to 4 make an objection. Make it. Otherwise stop 5 talking. 6 BY MR. TEIN: 7 Q. init- 8 MR. LEOPOLD: Excuse me. 9 MR TEIN: If you want to leave the 10 deposition, leave. But you'll be back here. 11 MR. LEOPOLD: Excuse me. If I could just 12 make the record, instead of interrupting me, 13 please. That's what we do professionally. 14 There's a recorder here. I'm certainly not being 15 obstructionist. I'm going to make the record. 16 But we're going to act with some semblance of 17 professionalism, hopefully, by all parties in the 18 room. That goes to me, that goes to your 19 co-counsel sitting behind you and next to you, the 20 court reporter and everyone else in the room. 21 Everyone is entitled to that. 22 You've asked a question. She answered the 23 question fully and she's not going to be harassed 24 because you don't like the answer. If you want to 25 follow up -- Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11201316 EFTA00234335  Case 9:08-cv-80804-KAM D ment 1-2 Entered on FLSD Docket 07/21/2008 Page 13 of 100 nsor & Associates Repnrti DE anti lranseti piton. Inc Page 87 1 MR. TEIN: Stop engaging me. Make your 2 speech and then we'll ask the questions. 3 MR. LEOPOLD: Well, you won't let me finish 4 making the objection, so it's difficult to do 5 that. But if you want to follow with an 6 appropriate question, feel free to do that. But 7 we're not going to harass the witness. 8 MR. TEIN: I disagree with everything 9 you've said. Let's ask the questions. Okay? 10 MR. LEOPOLD: Ask an appropriate question. 11 MR. TEIN: Are you going to stop talking? 12 MR. LEOPOLD: I'm going to make -- protect 13 my client and make appropriate objections. But 14 there's not a question pending right now. 15 BY MR. TEIN: 16 Q. ahasillispoken to any reporters? 17 A. No. 18 MR. LEOPOLD: Objection. Asked and 19 answered. 20 BY MR. TEIN: 21 Q. Has been given money by any 22 reperters? 23 A. No. 24 Q. Has your mom spoken to any reporters? 25 MR. LEOPOLD: Objection. Asked and Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 334O1 11301316 EFTA00234336  Case 9:08-cv-80804-KAM Do ' ,ent 1-2 Entered on FLSD Docket 07121'2008 Page 14 of 100 nsor & Associates Reparcinp and itnnscriparz. Inc lik Page 88 1 answered. 2 THE WITNESS: No. 3 BY MR. TEIN: 4 Q. Has your mom's husbandlillispoken to any 5 reporters? 6 A. No. 7 Q. Has your mom's husband IIIIIreceived any 8 money from reporters? 9 A. No. 10 Q. Are you sure you don't know 11 MR. LEOPOLD: Objection. Asked and 12 answered. 13 THE WITNESS: I'm positive. 14 BY MR. TEIN: 15 Q. I'll try again to refresh your memory. 16 A. Okay. 17 Q. Does it refresh your memory that she had 18 been arrested for drugs and was cooperating with 19 Detective Recarey against Epstein to get herself a better 20 deal? 21 A. No. I don't know who she is. 22 Q. Have you spoken to anyone else who's been 23 at Epstein's house? 24 A. No. 25 Q. Without telling me what was said -- I don't Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 114 el 316 EFTA00234337  Case 9:08-cv-80804-KAM 4po ent 1-2 Entered on FLSD Docket 07/21/2008 Page 15 of 100 nsor & Associates Steponsnp mid 1r/inscription, lac. Page 89 1 wart to know about any conversations with any lawyers, 2 okay -- 3 A. Uh-huh. 4 Q. did you or your parents speak to any 5 other law firms besides Mr. Herman and Mr. Leopold's law 6 firms? 7 A. No. 8 Q. Now without telling me about anything that 9 was said, what -- did one just come to mind? 10 A. No. I was thinking about something else. 11 Q. What were you thinking about? 12 A. Does family court matter? 13 Q. Okay. Without telling me what was said, 14 who prepared you for today's deposition? 15 A. What do you mean prepared? 16 Q. Did you talk about this deposition, about 17 what would happen, with anybody? 18 A. Yes. 19 Q. Don't tell me what was said. 2D A. Okay. 21 Q. I'm not asking that. I don't want to know 22 that. 23 A. Okay. 24 Q. Who prepared you for today's deposition? 25 A. Mr. Leopold. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11501316 EFTA00234338  Case 9:08-cv-80804-KAM Dppyment 1-2 Entered on FLSD Docket 07/21/2008 Page 16 of 100 nsor & Associates Itencannp and Transcriptinn. Inc Page 90 1 Q. Anybody else? 2 A. No. 3 Q. When did you meet with Mr. Leopold to 4 prepare for today's deposition? 5 A. This morning. 6 Q. And how long did that meeting last? 7 A. Until it started. 8 Q. Now you told me that you previously had 9 read the police reports in this case? 10 A. Yes. 11 Q. Have you read your statement that you gave 12 to the police? 13 A. Yes, sir. 14 Q. And in what form was that statement? 15 A. What do you mean? 16 Q. Was it in the form of a police report or a 17 transcript? 18 A. What's the difference? 19 Q. A transcript has questions and answers on 2) it. A police report is just typed out narrative. 21 A. Oh, it's a police report. 22 Q. And when did you read the police report? 23 A. A few days ago. I overread it a few days 24 ago. 25 Q. Had you read it before that? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 116 of 316 EFTA00234339  Case 9:08-cv-80804-KAM nt 1-2 ,Entered on FLSD Docket 07/21/2008 Page 17 of 100 nsor P.ssociates Ropornns and Transcription, Inc. Page 91 1 A. No. 2 Q. Now you told me -- again, I don't want to 3 know what was said. 4 A. Oh-huh. 5 Q. You told me that you met with Mr. Leopold 6 this morning to prepare for your deposition, right? 7 A. Yes. 8 Q. When did you set up that meeting with 9 Mr. Leopold to take place this morning? 10 A. Gee, like, like five days ago, four days 11 ago. 12 Q. So you're aware that Mr. Leopold told us 13 that he could not start the deposition this morning 14 because he had a court appearance, correct? 15 MR. LEOPOLD: Don't answer that question. 16 Calls for attorney/client communications. 17 BY MR. TEIN: 18 Q. Have you seen the letter that Mr. Leopold 19 wrote to us stating that he -- an e-mail that Mr. Leopold 20 wrote to Mr. Goldberger stating that he could not be here this morning because he had a court appearance? Did you 22 see :hat e-mail? 23 MR. LEOPOLD: You can answer that question. 24 THE WITNESS: No. 25 Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11701316 EFTA00234340  Case 9:08-cv-80804-KAM Dgagppflnt1-2 Entered on FLSD Docket 07/21/2008 Page 18 of 100 sor & Associates Reportinp hod Transcriptorn. Inc Page 92 1 BY MR. TEIN: 2 Q. Have you listened to your tape-recorded 3 statement to the police? 4 A. Yes. 5 Q. Where did you listen to that? 6 A. In, I think, this building. I don't know. 7 It was here. 8 Q. When did you listen to that statement? 9 A. This morning. 10 Q. And who was present when you listened to 11 that statement? 12 A. Mr. Leopold -- and I forget your name. 13 MR. GOLDBERGER: Ms. Belohlavek. 14 THE WITNESS: Ms. Belohlavek. 15 BY MR. TEIN: 16 Q. And you hadn't listened to your statement 17 before that, correct? 18 A. No, sir. 19 Q. Have you met with lawyers representing 20 anyone else suing Epstein? 21 A. No, sir. 22 Q. How many times have you spoken to officers 23 with the Palm Beach Police Department? 24 A. More than I like can count. It's been 25 ongoing for four years, so quite a few times. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 11641316 EFTA00234341  Case 9:08-cv-80804-KAM Document 1-2 Entered on FLSD Docket 07/21/2008 Page 19 of 100 nsor & Associates Roportenp and Transcription, Inc Page 93 1 Q. When was the last time you spoke with 2 officers of the Palm Beach Police Department? 3 A. A while ago. I'd say a year ago. 4 Q. A year ago? 5 A. Yeah. Maybe a year and a half. 6 Q. Do you remember Detective Recarey? 7 A. No. 8 Q. Do you remember Michelle Pagan, Detective 9 Pagan? 10 A. Yes. 11 Q. How many times have you spoken to Detective 12 Pagan? 13 A. She was the only one I spoke to about this 14 until for some reason she wasn't on the case anymore. 15 Q. When was that? 16 A. The first meeting I ever had was with her 17 and then I think like I met with her like 10 times or 12 :8 times or something like that, and then I didn't get 19 another investigator questioned me after that. 20 Q. And who was that? 21 A. I don't remember. 22 Q. And what type of questions did they ask 23 you? 24 A. The same. 25 Q. The same questions all over again? Ph. 561.682.0905 - Fax. 561.682.1771 1655 Paim Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 119 of 616 EFTA00234342  Case 9:08-cv-80804-KAM D ent 1-2 Entered on FLSD Docket 07/21/2008 Page 20 of 100 nsor & Associates iternruns and lranacii poem. Inc Page 95 1 A. I'd have to say like a year and a half ago, 2 a year ago. It was a long time ago. 3 (Discussion held off the record.) 4 MR. TEIN: Tell me the last answer, please. 5 (Thereupon, a portion of the record was read 6 by the reporter.) 7 BY MR. TEIN: 8 Q. And who was present when the FBI spoke to 9 you at your father's house? 10 A. My stepmother was there, but she wasn't 11 around. She made herself like do other things. 12 Q. And how many FBI agents were there? 13 A. I think four. i4 Q. And you don't remember any of their names? 15 A. No, sir. 16 Q. And were there any lawyers there? 17 A. Not that I know of. 18 Q. And none of them gave you their cell phone 19 numbers? 20 A. No. 21 Q. And the last time you spoke to the FBI was 22 a year and a half ago? 23 A. It was a while ago. G4 MR. LEOPOLD: Objection. Asked and 25 answered. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 120 of 316 EFTA00234343  Case 9:08-cv-80804-KAM ensOt 1-2 () Entered on_FLSDDocket 07/21/2008 Page 21 of 100 r oz p55Oclaces Reporting and lranscrip:nri. Inc Page 96 1 BY MR. TEIN: ral 2 Q. And the last time you spoke to the fede 3 prosecutor's office was when? 4 A. I don't know. that 5 Q. Did any of the FBI agents tell you Leopold? 6 Marie Villafona had spoken with Mr. A. No. 7 8 Q. Did any of the FBI agents tell you that an? 9 Marie Villafona had spoken with Mr. Herm 10 A. No. 11 Q. Did any FBI agents tell you that Jeff 12 Slonan spoke with Mr. Herman. 13 A. No. 14 Q. Did any FBI agents tell you that Jeff 15 Slonan spoke with Mr. Leopold? 16 A. No. 17 Q. Do you know whether any of the federal ew a draft 18 prosecutors allowed Mr. Herman to revi 19 indictment? 20 A. I wouldn't know. 21 Q. Do you know if any of the federal ctment with Mr. Herman? 22 prosecutors discussed a draft indi 23 A. I wouldn't know. 24 Q. Have you ever e-mailed with any FBI agent 25 or any federal prosecutor? Ph. 561.682.0905 - Fax. 561.682.1771 33401 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 1210316 EFTA00234344  Case 9:08-cv-80804-KAM nt 1-2 AEntered on Flan Docket 07/21/2008 Page 22 of 100 -sor & Associates hoponenp And Transaipart, Inc. Page 97 1 A. No. 2 Q. Have you ever text messaged with any FBI 3 agent or any federal prosecutor? 4 A. No. 5