EPSTEIN
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was said, what -- did one just come to mind?
2J
A.
No.
I 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 today's 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.
I don't want to know
that.
A.
Q.
A.
Okay.
Who prepared you for today's deposition?
Mr. Leopold.
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
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Page 90
Q.
Anybody else?
A.
No.
Q.
When did you meet with Mr. Leopold to
prepare for today's deposition?
A.
This morning.
Q.
And how long did that meeting last?
A.
Until it started.
Q.
Now you told me that you previously had
read the police reports in this case?
A.
Yes.
Q.
Have you read your statement that you gave
to the police?
A.
Yes, sir.
Q.
A.
Q.
And in what form was that statement?
What do you mean?
Was it in the form of a police report or a
transcript?
A.
What's the difference?
Q.
A transcript has questions and answers on
it.
A police report is just typed out narrative.
A.
Oh, it's a police report.
Q.
And when did you read the police report?
A.
A few days ago.
I overread it a few days
ago.
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
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Page 91
A.
No.
Q.
Now you told me -- again, I don't want to
know what was said.
A.
Q.
Uh-huh.
You told me that you met with Mr. Leopold
this morning to prepare for your deposition, right?
A.
Q.
Yes.
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 he had a court appearan_ce?
Did you
see ~hat e-mail?
MR. LEOPOLD:
You can answer that question.
THE WITNESS:
No.
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
118 of 316
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Page 92
BY MR. TEIN:
Q.
Have you listened to your tape-recorded
statement to the police?
A.
Q.
A.
Yes.
Where did you listen to that?
In, I think, this building.
I don't know.
It was here.
Q.
A.
Q.
When did you listen to that statement?
This morning.
And who was present when you listened to
that statement?
BY MR.
before
anyone
A.
Mr. Leopold -- and I forget your name.
TEIN:
Q.
that,
A.
Q.
else
A.
Q.
MR. GOLDBERGER:
Ms. Belohlavek.
THE WITNESS:
Ms. Belohlavek.
And you hadn't listened to your
correct?
No, sir.
statement
Have you met with lawyers representing
suing Epstein?
No, sir.
How many times have you spoken to officers
with the Palm Beach Police Department?
A.
More than I like can count.
It's been
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
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Q.
Page 93
When was the last time you spoke with
officers of the Palm Beach Police Department?
Pagan?
Pagan?
A.
Q.
A.
Q.
A.
Q.
A.
Q.
A.
A while ago.
I'd say a year ago.
A year ago?
Yeah.
Maybe a year and a half.
Do you remember Detective Recarey?
No.
Do you remember Michelle Pagan, Detective
Yes.
How many times have you spoken to Detective
She was the only one I spoke to about this
until for some reason she wasn't on the case anymore.
Q.
A.
When was that?
The first meeting I ever had was with her
and then I think like I met with her like 10 times or 12
times or something like that, and then I didn't get --
another investigator questioned me after that.
you?
Q.
A.
Q.
A.
Q.
And who was that?
I don't remember.
And what type of questions did they ask
The same.
The same questions all over again?
Ph. 561.682.0905 - Fax. 561.682.1771
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401
120 of 316
Case 9:08-cv-80804-KAM Document 1-1 Entered on FLSD Docket 07/21/2008 Page 20 of 100