EFTA00801875.pdf

-0929104.TXT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 2006 CF09454AXX STATE OF FLORIDA, -vs- JEFFREY EPSTEIN, Defendant. DEPOSITION OF Pall,11,91,,11ouse 205 North Dixie Highway West Palm Beach, Florida 33401 Reported By: Judith F. Consor, FPR Notary Public, State of Florida Consor-Reporting and Transcription Phone 1 APPEARANCES: 2 On behalf of the State: 3 ESQ. ATTORNEY 4 401 North Dixie Highway ach, Florida 33401 5 6 On behalf of the Defendant: 7 MICHAEL R. TEIN, ESQ. KATHRYN A. MEYERS, ESQ. 8 LEWIS TEIN, PL 3059 GRAND AVENUE, SUITE 340 Page 1 EFTA00801875  -0929104.TXT 9 COCONUT GROVE, FL 33133 10 On behalf of the Defendant: 11 JACK A. GOLDBERGER, ESQ. ATTERBURY, GOLDBERGER & WEISS 12 250 AUSTRALIAN AVENUE SOUTH SUITE 1400 13 ACH, FLORIDA 33401 14 15 ALSO PRESENT: KEITH J. BRETT, DIRECTOR OF MULTIMEDIA DIVISION, 16 LEGAL-EZE 17 18 19 20 21 22 23 24 25 1 INDEX 2 WITNESS: PAGE: 3 I III I IMT ION 4 4 BY MR. TEIN: 5 6 7 NO EXHIBITS MARKED 8 9 10 11 12 13 Page 2 EFTA00801876  -0929104.TXT 14 15 16 17 18 19 20 21 22 23 24 25 4 1 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 7 having been first duly sworn or affirmed, was examined 8 and testified as follows: 9 THE WITNESS: I do. 10 DIRECT EXAMINATION 11 BY MR. TEIN: 12 O. Good afternoon. Please tell me your full 13 name. 14 A. 15 0. And can you please spell it? 16 A. Page 3 EFTA00801877  -0929104.TXT 18 O. Thank you. 19 May I call you 20 A. Uh-huh. 21 O. , I'm going to ask you a few 22 questions, several questions today. If at any time you 23 want to take a break, you just let me know. Okay? 24 A. Okay. 25 O. If you at any time don't understand one of 1 my questions, will you just please let me know? 2 A. Yes. 3 O. And if at any time you're not feeling well 4 or something like that, you'll tell us, right? 5 A. Yes. 6 O. Do you feel okay today? 7 A. Yes. 8 O. Not taking any alcohol or drugs or anything 9 like that, right? 10 A. No. 11 O. So you feel ready to have your deposition 12 taken? 13 A. Yes. 14 O. what is your address? 15 A. I'm currently living at house and 16 I don't know it off the top of my head. 17 O. Where is it? 18 A. 19 O. Who is your aunt? 20 A. 21 O. Who else is living there? 22 A. age EFTA00801878  -0929104.TXT 23 O. Anyone else living there? 24 A. No. 25 O. 1 says that you live with 3 and have been living there; is that 4 correct? 5 A. Yes. 6 O. How long have you been living with your 7 8 A. Since 9 O. That was Thanksgiving of this past year? 10 A. Yes, sir. 11 O. Okay. Didn't did your get an apartment for the two of 13 you? 14 A. No, sir. He has an apartment, but by 15 himself. 16 O. Did he get an apartment for the two of you 17 to live in? 18 A. No, sir. 19 O. Are you planning to move in with him? 20 A. Maybe one day in the future. 21 O. Do you have a plan to move in with him 22 presently? 23 A. No. 24 O. Have you been to the apartment that you and 25 have discussed moving in together? Page 5 EFTA00801879  -0929104.TXT 7 1 A. I have been to the apartment. 2 O. Where is that? 3 A. 4 O. Have you spent the night over there? 5 A. No, sir. 6 O. Do you know the address there? 7 A. I do not. 8 O. Isn't planning on living 9 with you 10 A. No. 11 O. , you know that this court case is a 12 criminal prosecution, correct? 13 A. Correct. 14 O. And you know that it's a criminal 15 prosecution against a man who has no criminal background. 16 Do you know that? 17 A. I do now. 18 O. You agree that court is a very serious 19 matter? 20 A. Yes. 21 O. And you're here with your lawyer 22 right? 23 A. Yes. 24 O. And you know that recently 25 8 1 2 : Let me just object. 3 , let me instruct you. Anything that 4 you have learned through conversations between you Page 6 EFTA00801880  -0929104.TXT 5 and me are protected. So if you know any of that 6 information outside of those discussions, you may 7 answer. But if the only way you know it is 8 through our discussions, do not answer that 9 question. 10 BY MR. TEIN: 11 O. , you know that recently 12 14 : Same objection. 15 If you know the answer to that outside of 16 our discussions, you may answer. If it is the 17 only way that you know the answer is through our 18 discussions, do not answer that question. 19 THE WITNESS: Okay. 20 : Attorney/client privilege. 21 BY MR. TEIN: 22 O. You can answer the question unless -- 23 : Same objection. 24 MR. TEIN: Let me finish. 25 : Excuse me. We're -- 1 MR. TEIN: No. Let me finish. 2 : Lewis, we're not going to do 3 that. 4 MR. TEIN: My name is not Lewis. 5 I'm going to finish my question. Okay? 6 : Do not answer until you hear 7 from me. 8 BY MR. TEIN: Page 7 EFTA00801881  -0929104.TXT 9 O. Other than conversations that you have had 10 with -- I'm not asking about that -- are you 11 aware that 14 : Same objection. 15 Anything that you learn through 16 conversations between you and me, do not answer. 17 Those are protected. If you know through any 18 other realm of knowledge, you may answer. 19 THE WITNESS: No. 20 BY MR. TEIN: 21 O. You have no idea that 24 : Same objection. 25 Do not answer that question if it's through 10 1 discussions that you and I had. Outside of that, 2 you may answer. So do not answer that question if 3 that is the only basis by which you understand 4 that answer. 5 THE WITNESS: No. 6 BY MR. TEIN: 7 O. You didn't know that? 8 : Don't answer that question. 9 Against, it's attorney/client privilege. Any 10 information you've learned through conversations 11 between you and I are protected. If you know it 12 through any other realm, you may answer. 13 MR. TEIN: Are you going to say that for Page 8 EFTA00801882  -0929104.TXT 14 every question in the deposition, 7 15 : When you ask improper 16 questions like that without the proper -- 17 MR. TEIN: You're going to stop your 18 speaking objections right now. Okay? 19 : Without the proper 20 MR. TEIN: You need to stop your speaking 21 objections. 22 Let's continue. 23 : Counsel, you just asked me a 24 question and I'm going to state it on the 25 record -- 11 1 MR. TEIN: You need to stop your speaking 2 objections. Check your rules. 3 : Excuse me. For the record, 4 Counsel asked me a question. I'll state the 5 answer on the record. He asked me the question am 6 I going to be answering that way throughout the 7 deposition. So long as there's improper 8 foundation and predicate asked by the attorney, I 9 will protect my client and I make the record where 10 appropriate. If counsel wishes to ask an 11 appropriate worded question with the proper 12 foundation and predicate, I will certainly allow 13 the client to answer the question. 14 MR. GOLDBERGER: Why don't you just state 15 attorney/client privilege and just be done with 16 it. 17 : I want the record to be Page 9 EFTA00801883  -0929104.TXT 18 clear. 19 MR. TEIN: You want to waste time is what 20 you want to do. You were supposed to be here this 21 morning and you totally broke the deal, the 22 agreement that you had with us if your hearing got 23 cancelled. 24 But let's move on and maybe you'll stop 25 obstructing this deposition. 12 1 : I think the record is very 2 clear where we stand thus far. 3 Is there a recording taken of this 4 deposition? 5 THE COURT REPORTER: Yes. 6 : Just make sure that's 7 preserved. 8 BY MR. TEIN: 9 O. Go to Exhibit -- well, before you do 10 that, , are you aware that 9 12 : Objection. 13 Any conversations that you and I have had 14 regarding that, if that is the only way by which 15 you understand how to answer that question, so not 16 answer. It's attorney/client privilege, as well 17 as any conversations you may have had with the 18 attorney That is also attorney/client 19 privilege. And I'm assuming -- 20 MR. TEIN: You're actually wrong about the 21 attorney/client privilege. 22 : I'm assuming Counsel is not Page 10 EFTA00801884  -0929104.TXT 23 asking you to divulge attorney/client 24 MR. TEIN: Of course not. 25 BY MR. TEIN: 13 1 O. , are you aware that 4 : Same objection. 5 MR. TEIN: We've heard the objection 10 6 times already. 7 : Counsel, excuse me. 8 MR. TEIN: Just say attorney/client 9 privilege. Stop interrupting my questions. 10 : I'm entitled to make an 11 objection for the record, which I'm doing, and 12 I'll make the same objection. And if it calls for 13 attorney/client privilege, any conversations you 14 and I have had, do not answer the question. 15 And I think that it might be appropriate 16 for the record to ask questions via Ms. 17 as opposed to . I think that would be more 18 appropriate for this deposition. 19 BY MR. TEIN: 20 O. Go ahead. Please answer yes or no. 21 A. Yes. 22 O. Thank you. 23 In fact, you know that , don't you? Page 11 EFTA00801885  -0929104.TXT 14 1 A. After it happened. 2 O. You know that 3 don't you, yes or no? 4 A. Yes. 5 O. In fact, let's go to Exhibit 6 MR. GOLDBERGER: Look behind you. You'll 7 see it. 8 BY MR. TEIN: 9 O. Have you ever seen that picture before? 10 A. Yes. 11 O. Is that a picture of 14 A. Yes. 15 O. Now you know that this is a very serious 16 matter, don't you? 17 : Asked and answered. 18 Objection. 19 MR. GOLDBERGER: All right. You can 20 object. You're representing a witness here, 21 . You can object on privilege grounds. 22 You cannot make legal objections. You have no 23 standing to do so. 24 : I'm going to make them and 25 then -- 15 1 MR. GOLDBERGER: We're -- 2 : We're going to leave or we're 3 going to take a break because his demeanor is not 4 appropriate. There's no reason to have this kind Page 12 EFTA00801886  -0929104.TXT 5 of demeanor. If you want to have this kind of 6 demeanor with me 7 MR. TEIN: You are obstructing this 8 deposition. 9 MR. GOLDBERGER: Why don't you guys go 10 outside and just talk about -- 11 : She -- her job is very 12 difficult and she's not going to be able to take 13 us both talking at he same time. 14 MR. GOLDBERGER: Off the record. 15 : We're not going off the 16 record, Jack. We're not, Jack. Her job is very 17 difficult. I'm going to make the record. 18 I don't think it is appropriate, especially 19 in the small confines of this room, to be very 20 aggressive with this young lady. 21 MR. TEIN: That's not happening. Stop, 22 stop actually -- 23 : If you're going to interrupt 24 me, we're going to cancel this deposition 25 MR. TEIN: Stop misrepresenting. 16 1 THE COURT REPORTER: I need on at a time, 2 no matter who it is. 3 : I think we're going to take a 4 break. Perhaps you might want to talk to your 5 co-counsel -- 6 MR. TEIN: I don't need to talk to him. 7 : But we're going to take a 8 break. Page 13 EFTA00801887  -0929104.TXT 9 MR. TEIN: Not taking a break unless the 10 witness needs a break. 11 You're obstructing this deposition, III. 12 : Come on, 13 You all want to continue in this 14 demeanor -- 15 MR. TEIN: You're obstructing the 16 deposition. Stop making speeches. We're not 17 discussing this with you. The questions are to 18 your client. Go take your five-minute break. 19 : Fine. We need to make sure 20 the record's clear and clean. 21 And I want to make sure as I've already 22 asked you -- I know that you're one of the best in 23 town -- that this audio -- this needs to be 24 preserved. Okay? 25 MR. TEIN: Go take your five-minute break, 17 1 , now. 2 You were supposed to be here at nine a.m.; 3 it's now after two. Take your break and come 4 back. 5 : Okay. If the demeanor keeps 6 up, we will not be here beyond those five minutes. 7 MR. TEIN: Take your break and come back. 8 : Okay. So I suggest that you 9 relax. 10 MR. TEIN: I suggest that you take your 11 break. 12 MR. GOLDBERGER: Let them take that 13 five-minute break. Page 14 EFTA00801888  -0929104.TXT 14 : But I would suggest that you 15 take deep breaths. 16 MR. TEIN: Suggest whatever you want. Go 17 take a break. 18 (Thereupon, a recess was taken.) 19 BY MR. TEIN: 20 O. you agree that giving testimony 21 today at your deposition is something very serious, don't 22 you? 23 A. Yes. 24 O. And you respect the court, don't you? 25 A. Yes. 18 1 O. Let me show you Exhibit . Can you 2 read that out loud, please? 3 A. Okay. What do you want? 4 O. Will you read that out loud, please. 5 A. Oh. 6 O. Thank you. 7 A. Lol hah my baddd...lol yah i got some 8 stupid court shit ...bullshit...and damn you 9 still have court shit with him? Like after so long wow 10 im sorry... well yah well we will definitely havta make 11 plans for sure..because i miss u tons times a million and 12 no no no i love you...o p.s. i love ur default pic 13 niggaa. Muah xo. 14 O. Did you send that message last week to a 15 friend of yours on MySpace? 16 A. I wouldn't know. There's no dates and I've 17 deleted that MySpace, so -- Page 15 EFTA00801889  -0929104.TXT 18 O. We're going to talk about that in a second. 19 A. Okay. 20 O. Did you send that message last week 21 A. Right. 22 O. Let me finish my question. 23 Did you send that message last week to a 24 friend of yours on MySpace? 25 A. I wouldn't know the date, but obviously, 19 1 it's to a friend. 2 O. Did you send that message to a friend of 3 yours on MySpace? 4 A. Sure, yes. 5 O. Were you referring to this deposition? 6 A. Yes. 7 O. Do you find the term n-i-g-g-e-r offensive? 8 A. That's not anywhere in there. 9 O. What word did you use in there? 10 : Where are you referring to, 11 Counsel? There's 20 plus words in there. 12 MR. TEIN: Don't make a speaking objection. 13 THE WITNESS: Are you referring to 14 anything -- 15 : No, . Don't -- don't -- 16 let him ask you the question. 17 BY MR. TEIN: 18 O. What question were you asking, 7 19 : She doesn't ask questions. 20 You ask the questions. What is the question 21 pending? 22 BY MR. TEIN: Page 16 EFTA00801890  -0929104.TXT 23 O. , what is the last word on there in 24 the text of your message before the closing? 25 A. Niggaa. 20 1 O. Don't you find that term offensive? 2 A. No. 3 : Can you spell it for the 4 record, please. 5 THE WITNESS: N-i-g-g -- 6 MR. TEIN: No, no, no. You are not going 7 to be asking questions. 8 : I'm not asking questions. 9 I'm asking for the record the word to be spelled 10 because we don't have a video here today. 11 MR. TEIN: These exhibits are part of the 12 record. You -- 13 : Well, it's not marked as an 14 exhibit. 15 MR. TEIN: Stop interrupting me, 16 . I have marked and identified as an 17 exhibit and you will get it. 18 : There has been no 19 identification of this document in the record. 20 MR. TEIN: , stop interrupting 21 this deposition. 22 : What is the exhibit number 23 marked for identification? 24 MR. TEIN: 25 : Do we have copies? Is it on Page 17 EFTA00801891  -0929104.TXT 21 1 the record anywhere? 2 BY MR. TEIN: 3 O. Let me ask you, , did you in fact 4 write your friend this message about this deposition? 5 A. Yes. 6 O. So you wrote your friend that this 7 deposition is stupid court s-h-i-t, correct? 8 A. Yes. 9 O. Because you think this deposition is stupid 10 court s-h-i-t, don't you? 11 A. No. 12 O. You wrote that to your friend, didn't you? 13 A. Yes. 14 O. You think that court is stupid, don't you? 15 A. In some cases. 16 O. And you think that court is bull s-h-i-t, 17 don't you? 18 A. No. 19 O. And you think this deposition is bull 20 s-h-i-t, don't you? 21 A. No. 22 O. You wrote that to your friend, didn't you? 23 : Objection. Asked and 24 answered. 25 MR. TEIN: That's not an objection. 22 1 BY MR. TEIN: 2 O. You wrote that to your friend, didn't you? 3 : Objection. Asked and 4 answered, for the fourth time. Page 18 EFTA00801892  -0929104.TXT 5 MR. TEIN: You are improperly objecting, 6 . You have no grounds to object. And 7 that's not an objection. 8 : It is an objection. 9 MR. TEIN: Then terminate the deposition if 10 you think it's been asked and answered. 11 : Counsel, I am not precluded 12 from just making an objection to the form of the 13 question. As the courts well know, and if you 14 practice here in West Palm Beach, many of the 15 judges require you to set the objection with 16 specificity. And I will do that. And if you 17 don't want me to, you can make the record. But 18 will do that. 19 MR. TEIN: Here's what we'll do, III. You 20 can -- I will allow you to reserve an objection to 21 form for every single one of my questions. 22 Otherwise, all you're doing is obstructing. 23 : I won't do that. 24 MR. TEIN: Of course; because you want to 25 obstruct. 23 1 : All right. 2 BY MR. TEIN: 3 O. , you think that giving testimony 4 today, under oath, is bull s-h-i-t, don't you? 5 A. No. 6 O. And you wrote that to your friend on 7 MySpace last week, didn't you? 8 : Objection. Asked and Page 19 EFTA00801893  -0929104.TXT 9 answered. 10 THE WITNESS: No, I did not. 11 BY MR. TEIN: 12 O. You didn't write this exhibit? 13 A. I wrote that, but I didn't write what you 14 said. 15 O. You wrote in this exhibit, "I got some 16 stupid court s-h-i-t Bull s-h-i-t." Didn't 17 you write that? 18 A. Yes. 19 O. Referring to this deposition, didn't you? 20 A. Referring to the court. I was later 21 informed that it was a deposition. 22 O. I'm going to ask you some questions now 23 about what happened when you went to Jeff Epstein's house 24 years ago. Okay? 25 A. Uh-huh. 24 1 O. When the police interviewed you 2 after you went to Epstein's house, you swore on your 3 mother's grave that you and Epstein did not engage in sex 4 of any kind? 5 A. Yes. 6 O. Didn't you tell that to the police? 7 A. Yes. And I will continue. I have never 8 had sex with him. 9 O. Did what happened upstairs at Jeff 10 Epstein's house take you completely by surprise, 11 A. Yes. 12 O. Now the Page 20 EFTA00801894  -0929104_TXT 14 16 A. Yes. 17 0. Were you totally shocked by what happened 18 when you got to Epstein's house? 19 A. Yes. 20 0. You didn't expect it at all, did you? 21 A. No. 22 0. You had absolutely no idea why your friend 23 was taking you to Epstein's shoes, right? 24 A. I was informed it was a massage. 25 Q. All you thought that it was going to be was 25 1 a massage, correct? 2 A. Yes. 3 0. Before you got to Epstein's house 4 never said anything to you on the telephone about sexual 5 activity with Epstein, did he? 6 A. No. 7 0. And before you got to Epstein's house 8 never sent you a message over the Internet about 9 sexual activity with Epstein, did she? 10 A. No. 11 0. Did ever try to convince you to 12 engage in any sexual activity with Epstein? 13 A. No. 14 0. Did every try to convince 15 you to engage in any sexual activity with Epstein? 16 A. I don't know who is. 17 0. Do you have a friend Page 21 EFTA00801895  -0929104.TXT 18 A. No. 19 O. Okay. Before you went so Epstein's house 20 did anyone call or e-mail you to induce you to engage in 21 sexual activity with Epstein? 22 A. No. 23 O. So you're sure that before you got to 24 Epstein's house no one tried to persuade you to engage in 25 sexual activity with Epstein? 26 1 A. No. 2 O. You're sure that -- let me ask the question 3 again. 4 You're sure that before you got to 5 Epstein's house no one tried to persuade you to engage in 6 sexual activity with Epstein for money. Are you? 7 : Objection. Asked and 8 answered. 9 THE WITNESS: No. And I've already 10 answered that a bazillion times. 11 BY MR. TEIN: 12 O. He's coaching you now. So I'm going to ask 13 the question 14 : Counsel, I've made an 15 objection for the record. 16 MR. TEIN: Stop speaking. 17 : I'm not going to stop 18 speaking. You can't interrupt me when I'm making 19 the record. 20 MR. TEIN: You're coaching the witness. 21 : Counsel -- 22 MR. TEIN: Stop coaching the witness. Page 22 EFTA00801896  -0929104.TXT 23 BY MR. TEIN: 24 O. , let me ask you -- 25 : If you continue to -- 27 1 MR. TEIN: Stop interrupting my questions. 2 : If you do it one more time, 3 we're leaving. 4 BY MR. TEIN: 5 O. 6 : I'm going to make the record. 7 You cannot interrupt me when I'm making the 8 record. Out of professional conduct, you cannot 9 do that. I'm entitled to make the record. I made 10 an objection, asked and answered. You demeanor is 11 inappropriate. You're willing and you are able 12 and you're responsible to ask a question in a 13 professional manner and ask the question and once 14 you get the answer, to either follow up on it or 15 move on, but not continuously browbeat and ask the 16 same question over and over because you don't like 17 the answer. 18 MR. TEIN: Calm down, sir. 19 : Trust me, I'm very calm here. 20 When I'm not calm you'll know it. I'm very calm. 21 So please continue on, but I will not allow 22 you to continue to harass her in the demeanor that 23 you're doing. Ask her a question and move on. 24 MR. TEIN: Are you done? 25 : Thank you. I am. Page 23 EFTA00801897  -0929104.TXT 28 1 MR. TEIN: Stop misrepresenting the record 2 and calm down. I'm going to ask my question. 3 Stop it. 4 BY MR. TEIN: 5 O. 6 : I think the record is very 7 clear. 8 MR. GOLDBERGER: Let me just clarify 9 something. When you object to the form of a 10 question, you're not instructing the witness not 11 to answer the question, are you? 12 : No. And I'm not making that 13 objection; only on attorney/client privilege. 14 MR. TEIN: Will you stop speaking now so I 15 can ask my question? Are you done? 16 Okay. I'm going to ask my question. 17 BY MR. TEIN: 18 O. Listen, 19 : Hold on. Stop. 20 I've been doing this for 20 plus years and 21 have met a lot of attorneys, but I've never had an 22 experience like this where I've -- 23 MR. TEIN: Stop your speeches. 24 : If you continue to do this, 25 whether it's with me or with my client, I will not 29 1 put up with it and I don't need to put up with it 2 and it's not appropriate. And I'm sure Mr. 3 Goldberger knows all this, because I know that he 4 wouldn't do this. So I will not put up with it. Page 24 EFTA00801898  -0929104.TXT 5 And I think it's highly inappropriate to do this 6 with this child sitting here, the way you're 7 acting, primarily towards me, and I will not put 8 up with it. 9 MR. TEIN: Will you please stop your speech 10 so I can ask questions? 11 : So long as you act 12 professionally, I will do so. But if you continue 13 to do it this way, I will leave. 14 MR. TEIN: Suit yourself. 15 BY MR. TEIN: 16 O. , are you sure that before you got to 17 Epstein's house no one tried to persuade you to engage in 18 sexual activity with Epstein for money? 19 : Asked and answered. 20 Objection. 21 MR. TEIN: Did you get her answer? 22 THE COURT REPORTER: No, I did not. 23 THE WITNESS: I'm sure. 24 BY MR. TEIN: 25 O. Let me ask you a few questions about your 30 1 contact with Epstein. Okay? 2 A. (Witness nods head up and down.) 3 O. Jeff never e-mailed you, did he? 4 A. No. 5 O. Jeff never text messaged you, did he? 6 A. No. 7 O. Jeff never chatted in a chat room with you, 8 did he? Page 25 EFTA00801899  -0929104.TXT 9 A. No. 10 O. Before you got to Epstein's house you had 11 never spoken to Jeff, had you? 12 A. No. 13 O. And before you got to Epstein's house you 14 had never met Jeff? 15 A. Correct. 16 O. Before you got to Epstein's house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 O. Before you got to Epstein's house had you 20 ever told that you were under 18? 21 A. No, I never spoke to the man before that. 22 O. And you only went to Jeff Epstein's house 23 that one time years ago, correct? 24 A. Yes. 25 O. You never went there again, correct? 31 1 A. No. 2 O. All right. Let me ask you two final areas 3 of questioning about this and we'll move onto something 4 else. Okay? 5 A. Uh-huh. Yes. I'm sorry. 6 O. Before you got to Epstein's did anyone 7 associated with Epstein ever call you on the phone and 8 try to persuade, induce, entice or coerce you to engage 9 in any sexual activity? 10 A. No. 11 O. Before you got to Epstein's did anybody 12 associated with Epstein ever contact you on the Internet 13 and try to persuade, induce, entice or coerce you to Page 26 EFTA00801900  -0929104.TXT 14 engage in any sexual activity? 15 A. No. 16 O. , who told you that when you got to 17 Jeff Epstein's house you should lie to Jeff about your 18 age? 19 A. 20 O. Was it or was it the other girl in 21 the car who you rode over with to Epstein's house? 22 A. 23 O. Who was the other girl in the car with you 24 that day? 25 A. I honestly don't know. 32 1 O. Had you ever seen her before? 2 A. No, sir. 3 O. You told the police that when you rode over 4 to Epstein's you had no idea who she was, right? 5 A. Correct. 6 O. You told the police that you didn't know 7 her name, but she was 9 9 A. Yes. 10 O. Those were your words, right? 11 A. Yes. 12 O. Do you now know who she is? 13 A. No, sir. 14 O. So it was who told you to lie about 15 your age to Jeff Epstein? 16 A. Yes, sir. 17 O. And told you that if you weren't 18, Page 27 EFTA00801901  -0929104.TXT 18 Epstein wouldn't let you into his house, right? 19 A. That's -- yes, yes. 20 O. All right. Let's talk for a minute about 21 when you first met Jeff. Okay? 22 A. Sure. 23 O. When you first met Jeff he tried to find 24 out how old you were, right? 25 A. Excuse me? 33 1 O. When you first met Jeff he tried to find 2 out how old you were, right? 3 A. Not when we first introduced each other; 4 when we get upstairs, then yes. 5 O. During the massage Jeff asked you how old 6 you were, correct? 7 A. Yes, yes. 8 O. Now hadn't you already told Jeff's 9 assistant, the one who walked you upstairs, that you went 10 to college and had just moved down here 7 11 A. I never spoke to the lady. 12 O. Do you want to rethink that answer? 13 : Is that a question? 14 BY MR. TEIN: 15 O. Do you want to rethink that answer? 16 A. No. I didn't really speak with her that 17 much. 18 O. Do you want to try to refresh your memory 19 on that? 20 : Do you have something to 21 refresh her memory with? 22 MR. TEIN: Do you want to stop making Page 28 EFTA00801902  -0929104.TXT 23 speaking objections? 24 : No. But to refresh someone's 25 memory you show them a document. 34 1 MR. TEIN: I know how to do this. 2 : Then show her a document. 3 MR. TEIN: Stop speaking. 4 : I'm not going to stop 5 speaking. I'm going to continue to make the 6 record. 7 MR. TEIN: You're obstructing. Please 8 stop. 9 : I'm not obstructing. But if 10 you want to refresh her recollection, you need to 11 show her something. 12 That's not a proper question. I object to 13 the foundation and the predicate of that question. 14 MR. TEIN: Are you done? 15 : I am now. Thank you. 16 BY MR. TEIN: 17 O. Do you want to try to refresh your memory 18 as to whether you had any conversation with the woman who 19 walked you upstairs in Epstein's house in which you told 20 her that you went to college and had just moved down 21 22 : Objection. Object to the 23 form of the question. Lack of foundation and 24 predicate. 25 BY MR. TEIN: Page 29 EFTA00801903  -0929104.TXT 35 1 O. You can answer the question. 2 A. Sure. 3 O. Is there anything that would refresh your 4 memory that in fact you told Mr. Epstein's assistant, the 5 one who walked you upstairs, that you went to college and 6 you had just moved down here 7 7 A. I don't remember saying that, but if you -- 8 I don't remember saying that myself, so -- 9 O. That would be a lie, right? 10 A. No. I really don't remember. 11 O. So you told Jeff that you were 18 years 12 old, correct? 13 A. Yes. 14 O. Do you remember of 15 the Police Department, Palm Beach Police Department, 16 A. Yes. 17 O. Do you remember you spoke to her? 18 A. Yes. 19 O. Do you remember that you told Detective 20 that when you lied about your age to Jeff 9 23 A. I don't remember the words exactly, but I 24 do remember telling her I told him I was 18. 25 O. And do you remember telling 36 1 that when you lied to Epstein about your age that- 4 A. No, I don't remember saying those words Page 30 EFTA00801904  -0929104.TXT 5 exactly to her. I remember telling her that I told 6 Epstein I was 18. 7 O. Does it sound right to you that you told 8 10 MS. Objection. Asked and 11 answered. 12 BY MR. TEIN: 13 O. -- 15 : Objection. Asked and 16 answered, lack of foundation, mischaracterization 17 of her earlier testimony. She's already answered 18 that question. 19 BY MR. TEIN: 20 O. You can answer it. 21 : Same objection. It's been 22 asked and answered. 23 You can answer. I've made the objection. 24 THE WITNESS: I forget the question, now. 25 37 1 BY MR. TEIN: 2 O. Let me put it again. 3 Does it sound right to you that you told 4 that when you lied about your age to 5 Epstein, 7 : Objection. Lack of 8 foundation, asked and answered. Page 31 EFTA00801905  -0929104.TXT 9 THE WITNESS: I could have possibly said 10 that, yes. 11 BY MR. TEIN: 12 O. You didn't want Mr. Epstein to know that 13 you were lying about your age, right? 14 A. Correct. 15 O. You didn't want Mr. Epstein to know that 16 you were not 18 yet, right? 17 A. Correct. 18 O. You wanted Mr. Epstein to believe that you 19 really were 18, right? 20 A. Correct. 21 O. Do you remember when Mr. Epstein asked 22 where you went to school? 23 A. Yes. 24 O. And you told Mr. Epstein you went to 25 , right? 38 1 A. Yes. 2 O. Was that the truth? 3 A. No. 4 O. In fact, you went to , right? 5 A. Yes. 6 O. So you lied to Mr. Epstein again, correct? 7 A. Yes. 8 O. Is the college that you told 9 Jeff's assistant that you were attending? 10 A. I don't remember having that conversation 11 with her, so I wouldn't know if that's what I said. 12 O. That was a lie, though, wasn't it? 13 : Objection to the form of the Page 32 EFTA00801906  -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, 19 : She can't answer that 20 question. The way you phrased that question, 21 you're purposely making her not be honest in her 22 testimony. She can't answer a question like that. 23 She doesn't remember. So then you say, "So you 24 were lying." That's improper and you know that. 25 That's not a proper question. And any attorney 39 1 that would do that to a witnesses or to a person 2 that's sitting in this chair is not acting 3 professionally. You can't ask a question like 4 that. You can do it, but it's not proper. And 5 I'm sure you weren't trained that way, certainly 6 not ethically. 7 MR. TEIN: Will you stop? 8 : 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 O. Ms. 14 : Trust me. I'm very calm. 15 When I lose my cool, you'll know it. 16 MR. TEIN: I do know it. 17 BY MR. TEIN: Page 33 EFTA00801907  mmmmmaia29104.TXT 18 Q. Ms. 11111111, Mr. Epstein never asked you 19 to do anything other than massage him, correct? 20 A. Incorrect; because he asked me to take off 21 my bra, s