Alessi Depo

Case Document 291-17 Entered on FLSD Docket 01/21/2015 Page 1 of 8 EXHIBIT 18 Case 9:08-cv-80736-KAM Document 291-17 Entered on FLSD Docket 01/21/2015 Page 2 of 8 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No.08-CV-80119-CIV-MARRA/JOHNSON Page 3 1 2 JANE DOE NO. 2, 3 Plaintiff, 4 -vsJEFFREY EPSTEIN, Defendant. _____________________________________________________ Related cases: 08-80232, 08-80380, 98-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 ______________________________________________________ VIDEOTAPED DEPOSITION OF JUAN ALESSI VOLUME I Tuesday, September 8, 2009 10:12 a.m. - 3:45 p.m. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33401 Reported By: Sandra W. Townsend, FPR Notary Public, State of Florida PROSE COURT REPORTING AGENCY West Palm Beach Office 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On behalf of the Defendant: ROBERT J. CRITTON, ESQUIRE BURMAN, CRITTON & LUTTIER 515 North Flagler Drive, Suite 400 West Palm Beach, Florida 33401 Phone: 561.842.2820 rcrit@bclclaw.com mpike@bclclaw.com Page 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 APPEARANCES: On behalf of the Plaintiffs: RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 Phone: 561.582.7600 reelrhw@hotmail.com STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 Phone: 305.931.2200 ssm@sexabuseattorney.com ahorowitz@sexabuseattorney.com WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 Phone: 954.522.3456 bedwards@rra-law.com KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 Phone: 305.358.2800 rjosefsberg@podhurst.com kezell@podhurst.com ADAM J. LANGINO, ESQUIRE LEOPOLD KUVIN 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 Phone: 561.515.1400 skuvin@leopoldkuvin.com 22 23 24 25 Page 4 - - EXHIBITS - - - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NUMBER DESCRIPTION PAGE Exhibit number 1 Exhibit number 2 Exhibit number 3 Exhibit number 4 Exhibit number 5 Photographs 45 Transcript 130 Incident Report 137 Incorporation Papers 149 Incorporation Papers 150 1 (Pages 1 to 4) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) (561) 832-7506 76ef564a-4a1c-4dee-87ac-479898cc7004 Case 9:08-cv-80736-KAM Document 291-17 Entered on FLSD Docket 01/21/2015 Page 3 of 8 Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROCEEDINGS --Deposition taken before Sandra W. Townsend, Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. - - VIDEOGRAPHER: Today is September 8, 2009. The time is 12 minutes after 10:00 in the morning. This is the videotaped deposition of Juan Alessi in the matter of Jane Doe number two versus Jeffrey Epstein. This deposition is being held at 2139 Palm Beach Lakes Boulevard in West Palm Beach, Florida. My name is Stan Sanders. I'm the videographer representing Visual Evidence, Incorporated. Would the attorneys please announce their appearances for the record. MR. WILLITS: Richard Willits, representing Carolyn Andriano. MR. BERGER: William J. Berger, representing E.W., L.M. and Jane Doe number two. MR. MERMELSTEIN: Stuart Mermelstein of Mermelstein and Horowitz, representing Jane Does numbers two through eight. MR. LANGINO: Adam Langino, on behalf of B.B. Page 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Boynton Beach, Florida, 33472. Q. All right, sir. Did you ever work for Jeffrey Epstein? A. Yes, I did. Q. In what capacity? A. Everything. I started with Jeffrey Epstein around 19 -- please bear with the dates because I trying -Q. Sure. A. -- to remember. 1969 as a part-time maintenance guy. And then I become a full-time employee, I think it was January 1, 2 -- '91, '92, so '92. Sorry. Q. You said you started in 1969? That would be -A. No. No. No. No. No. Q. Okay. A. '99. Q. 1999? A. Yeah. Q. All right. And how did you happen to get that job? Was it through an employment agency -A. No. Q. -- or an ad in the paper? A. I had a company at that time used to take care Page 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. EZELL: Katherine Ezell from Podhurst Orseck, on behalf of Jane Does 101 and 102. MR. CRITTON: Bob Critton, on behalf of Jeffrey Epstein. THEREUPON, JUAN ALESSI, having been first duly sworn or affirmed, was examined and testified as follows: THE WITNESS: I do. DIRECT EXAMINATION BY MR. WILLITS: Q. Good morning, sir. A. Good morning. Q. I introduced myself through the videographer. My name is Richard Willits. A. Okay. Q. I represent a young lady by the name of Carolyn Andriano. A. Okay. Q. Is that name familiar to you at all? A. Whose name? Q. Carolyn Andriano. Do you recognize that name? A. No. Q. What is your residence address, sir? A. My address is 6791 Fairway Lakes Drive, Page 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of a lot of residents in Palm Beach. And I got to know Jeffrey through Lesley Wexner. And I used to work in about 20 different, 20, 25 different homes in Palm Beach as a maintenance guy. Q. Okay. A. And I have basically my own company and I do repairs for them. I did home sit in for them. Q. And what was -- did you work for Jeffrey Epstein? What was your position when you started? A. When I started, he hire me to -- he just bought the house. Q. I'm sorry? A. He just had bought the house -Q. Okay. A. -- where he live on El Brillo. And he hire me through Mr. Wexner's references to do repair works. And basically what I did the most was taking walls apart, windows and stuff that he didn't want to have it, -Q. I see. A. -- fix it. Q. And when you started working for Mr. Epstein, were you still working for other people in Palm Beach? A. Yes, I did. Q. Okay. And about how long a period of time did you do this type of work for Mr. Epstein, the 2 (Pages 5 to 8) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) (561) 832-7506 76ef564a-4a1c-4dee-87ac-479898cc7004 Case 9:08-cv-80736-KAM Document 291-17 Entered on FLSD Docket 01/21/2015 Page 4 of 8 Page 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 maintenance and taking out walls? A. It was couple months. It was couple months before. Q. And what was the name of your company? A. Alessi Maintenance. Q. And how were you paid? A. By him? Q. Yes. A. Usually by check or cash sometimes. Q. Do you know what company actually paid your company? A. It was Jeffrey Epstein and Company. Q. So you said you had that position for a couple of months. What happened next? A. Then Mr. Epstein asked me to, if I wanted to be his employee, because I was going from one house to another house to another house, one hour here. I was just running around Palm Beach all day. So he asked me if I would just work for him, exclusively for him. Q. Okay. A. And we agreed with the terms and I become a full-time employee as a maintenance guy. And I was taking care of everything, as far as maintenance. Page 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 about seven months before -- after I become a full-time employee. Q. Okay. And how did Ms. Maxwell come into the picture? A. It was his girlfriend, his main girlfriend. Q. Okay. Had you known her before she became -A. No. Q. -- your -A. Never know her before. Q. I'm sorry. I didn't get a chance to finish my question. Would you have referred to her as your supervisor or your superior or what would you have called Mrs. Maxwell? A. I used to call her Ghislaine. Q. Okay. And how was it explained to you that you were now to deal with Ms. Maxwell, as opposed to Jeffrey Epstein? A. She would tell me, I am going to take care of the house. Q. Okay. That was explained to you by Ms. Maxwell? A. Uh-huh. Q. Is that a yes? A. Yes. Page 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Then my job changed little by little to house man, estate manager, and then to a majordomo. Q. Okay. When you first agreed to terms with Mr. Epstein and you first started working for him full time, what were those terms, do you remember? A. The terms is basically was how much -- he asked me how much I was making in all the properties. And I says, well, I make this -- this amount of money. And he says, fine. Q. And how much was that, did he pay you? A. Around $45,000. I think I started with 45. Q. Okay. And when you started to work for him as a full-time employee, did you have anybody that you reported to or did you deal directly with Mr. Epstein? A. At the beginning with Mr. Epstein, directly to him. Q. Did that change? A. Later on, yes. Q. And how did that change? A. When Ms. Maxwell, Ghislaine Maxwell came to the picture. Q. Okay. About when was it that she came into the picture? A. Exactly date, I cannot remember. But it was Page 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And when Ms. Maxwell started assuming responsibility for the house, did your duties change at that time? A. Not much. Q. Okay. A. Not much. Q. And at that time when Ms. Maxwell started taking responsibility for the house, what were your duties? A. Basically I was still doing the maintenance work. Q. Okay. A. Was doing -- they were trying to remodel the home and they would told me, okay, tear down this wall. We want to see how it's going to look. Or put this windows and tear down -- we had a fishing tank. We took it out -- I took it out. A kitchen on the second floor. I took it out. So it was basically dismantling the house. Q. Okay. And about how long a period of time did that project last? A. I would says, six to seven months. Q. Okay. And after the remodeling slacked off or stopped, did your duties then change? A. Yeah. Increasingly they change. 3 (Pages 9 to 12) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) (561) 832-7506 76ef564a-4a1c-4dee-87ac-479898cc7004 Case 9:08-cv-80736-KAM Document 291-17 Entered on FLSD Docket 01/21/2015 Page 5 of 8 Page 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. EZELL: I'm going to ask -- I don't know whether you've still been serially designating Exhibits or whether we're doing them separately for deposition. MR. CRITTON: I think we cannot trust that people will do them serially. I'd do them with each one. MS. EZELL: Then would you mark this, please, as Exhibit 1 to this deposition. And I'm just going to state on the record that I will keep that original. We will not attach it to the deposition. (Exhibit number 1 was marked for identification purposes and retained by Counsel for the Plaintiffs.) THE WITNESS: Yes, that's -BY MS. EZELL: Q. Can you identify that -- the young woman in those pictures? A. Yes. Q. Who is it? A. That's V. -- V. Now that you says R., that is V.R. definite, a hundred percent. MR. CRITTON: Let me just note my objection, as I did in A. Rod's deposition or Mr. Rodriguez's Page 47 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE WITNESS: Could have been. But, you know, I am not -- I don't think I am a very good judge of ages. If you ask me how old you are, I really couldn't tell you. MR. CRITTON: Kathy thinks she's 25. MS. EZELL: In my dreams. THE WITNESS: Now, again, I must tell you, I was never told to check any i.d.s on any of the people who work at the house. BY MS. EZELL: Q. I understand that. And, so, I think I'm just trying to establish that you didn't consider it part of your job description to worry about or consider the ages -A. No. Q. -- of the young women that came there? A. Absolutely not. Absolutely not. Q. And, so, you never really focused on that or particularly thought about it if they seemed young? MR. CRITTON: Form. THE WITNESS: I don't -- I didn't see that many young girls, you know, young, underage girls at the house. I never saw except the two girls that I mentioned that I think it was underage was N. for sure because she was still in high school. Page 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 deposition, that I know you're going to confiscate Exhibit number 1. I think it's inappropriate. I think I should be allowed to have a copy of Exhibits that are being used in deposition. But I'll file a motion with the Court so we don't get into a pulling match over your Exhibits. MR. BERGER: I would ask that the court reporter initial that. MS. EZELL: Sure. Oh, you did? MR. WILLITS: She marked it. MR. BERGER: Did she put her initials or did she just put a number or a letter? MR. CRITTON: She's nodding that she did everything that she usually does, which means, initials, date and number. MR. MERMELSTEIN: You can talk. MR. WILLITS: But when you talk, use your initials. BY MS. EZELL: Q. How old did you think V.R. was at the time she began coming to Mr. Epstein's home? A. She could have been 17, 18, 19. Q. Could she have also been 15? MR. CRITTON: Form. Page 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And she -- she had dinner with her mother, a couple times with her mother. And she become an actress. She's an actress and she has done movies. And he help her in her career. That's the only girl that I knew she was young because she was going to high school and I pick her up from high school sometimes. But she was not a massage therapist. She will go for dinner. And they will go for the movies and she sang sometimes because she was a singer. So she sung at the house. Beautiful girl. Very talented. That's the only girl that I know that it was -- I would says, underage. BY MS. EZELL: Q. Okay. Did -- who told you that V.R. was a massage therapist? A. Nobody. Q. Did you assume that she was a massage therapist because you were told she was coming to give a massage? A. No. I assumed she was a massage therapy because I was -- I drove Ms. Maxwell to Mar-a-lago, Donald Trump's residence. And I wait in the car while Ms. Maxwell got a -- I think it was a facial or massage. I don't know. But that day I remember this girl, V., 12 (Pages 45 to 48) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) (561) 832-7506 76ef564a-4a1c-4dee-87ac-479898cc7004 Case 9:08-cv-80736-KAM Document 291-17 Entered on FLSD Docket 01/21/2015 Page 6 of 8 Page 69 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. CRITTON: Form. THE WITNESS: No, not that I can remember. BY MS. EZELL: Q. Do you know if he and Mr. Epstein were involved in any businesses together? A. Mr. Epstein, I never knew what businesses he was involved. He will -- I was completely shut off of all of the business, except for the office, transfer of communications or faxes. But I have no idea of the relationship with other business partners. Q. Did you ever have to deal with his -- the office in New York with someone named Lesley in New York? A. The secretary? Q. Yes. A. Yeah. I would call -- I would call Lesley almost every day or other secretaries, they live in New York. Basically it came a point when Mr. Epstein will call New York and New York call me to do things for Mr. Epstein. But he was on the phone or busy or something and he would call the office and the office will send me an e-mail or call me or -- it was a constant report with the office in New York. Q. And did you in turn sometimes call New York to get a message to Mr. Epstein? Page 71 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Diane's secretary, she stay there for a week with her kids and we took care of her. Who else? Mr. Trump. That's a celebrity. Mr. Robert Kennedy, Junior. Mr. Frederick Fekkai. Q. Who is that? A. Fekkai, Frederick Fekkai, the famous hairstylist. Who else? I don't think I can remember anymore. Q. David Copperfield, the magician? A. No, I never saw him. Q. You never saw him. Now, would these -- the people that you named were all people that you saw visiting in the home? A. Yes. Also was a Noble Prize winners, the -- I can't remember his name. It was an old gentleman. He was a Noble Prize, chemistry, I think, or mathematics. There was a couple -- a couple of those, very -- also, we had at one time at the house, it was a reunion of very Noble Prize winners. But I don't know. They're not famous, I guess. I can't remember their names. Very important people. Q. Was that a dinner or a reception? A. I think it was a lunch. Q. A lunch. President Clinton, did you ever -- Page 70 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes. Q. Did you ever overhear Mr. Epstein talking to any people that you would consider celebrities? A. Yes. I knew some -- many celebrities. Q. Who -- what celebrities did you understand that he spoke with? A. He spoke to it? Q. Yes. A. I don't know who he spoke to because I never listen to his conversations. But I saw guests at the house that were celebrities. Q. Who did you see at house? A. Many. It was senators. It was Senator Mitchell, George Mitchell. It was Prince Andrew. It was Princess Sarah. Q. Princess? A. Sarah, the wife of Andrew. Q. Sarah Ferguson? A. Ferguson. And it was a couple Misses, Misses Yugoslavia, Miss Germany that I don't even know the names. But they were a lot of queens and other famous people that I can't remember. It was a very famous lawyers that I'm sure you know, Alan Dershowitz, who spend at the house a couple times. And he slept there. He -- Princess Page 72 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I met President Clinton on Mr. Epstein's plane in the last, I think it was the last month or just before I left -- I left, I met President Clinton in Miami at his plane. We drove him to Miami. Q. And do you know, was that a trip -- were they going on a trip to Africa? A. I hear about it, but it was not when I was there. Q. So that was not the time that you drove -A. No, I was already out. Q. And Kevin Spacey, did you ever meet him? A. No. I hear about it on the news, but I never met him. Q. Were Prince Andrew and Princess Sarah friends of Ms. Maxwell? A. Both of them. Q. Both Ms. Maxwell and Mr. Epstein? A. Yeah. Q. Did -- did they ever have massages when they were there? A. Prince Andrew did. I think Sarah was there only once and for a short time. I don't think she slept in there. I cannot remember. I think she was visiting Wellington and she came to the house and we met her. But Prince Andrew, yes, Prince Andrew spent weeks with 18 (Pages 69 to 72) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) (561) 832-7506 76ef564a-4a1c-4dee-87ac-479898cc7004 Case 9:08-cv-80736-KAM Document 291-17 Entered on FLSD Docket 01/21/2015 Page 7 of 8 Page 73 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 75 us. 1 2 Q. Where would he sleep? 3 A. In the main room, the main guest bedroom. 4 That was the blue room. 5 Q. And, so, when he would come and stay, during 6 that time would he frequently have massages? 7 MR. CRITTON: Form. 8 THE WITNESS: I would says, daily massages. 9 They have a daily massage. 10 BY MS. EZELL: 11 Q. Was it sometimes more than one a day? 12 A. I can't remember if he had more than one, but 13 I think it was just a massage for him. We set up the 14 tables and -Q. Do you have any recollection of V.R. coming to 15 16 the house when Prince Andrew was there? 17 A. It could have been, but I'm not sure. 18 Q. Not sure. When Mr. Dershowitz was 19 visiting, -20 A. Uh-huh. 21 Q. -- how often did he come? 22 A. He came pretty -- pretty often. I would says, 23 at least four or five times a year. 24 Q. And how long would he stay typically? 25 A. Two, three days. MR. LANGINO: Go ahead. Sure. BY MS. EZELL: Q. You said that you set up the massage tables. And would you also set up the oils and the towels? A. Yes, ma'am. Q. And I think I read one time you said they used 40 or 50 towels a day? MR. CRITTON: Form. THE WITNESS: That's correct. There was a tremendous amount of work in the house, especially laundry towels, because they were -- we have towels, piles of towels. And they use in the pool. There was a lot of people in the pool and there were a towel that went in the floor, we have to go and pick it up, wash it. So it was -- it was a lot of towels, yes. BY MS. EZELL: Q. And did you ever have occasion to go upstairs and clean up after the massages? A. Yeah, uh-huh. Q. Did you ever find any vibrators in that area? A. Yes. I told him, yes. MS. EZELL: And did you ask that? I'm sorry. MR. CRITTON: Yes. MS. EZELL: I don't know how I missed that. Page 74 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Did he have massages sometimes when he was there? A. Yes. A massage was like a treat for everybody. If they want it, we call the massage and they have a massage. Q. Now, Mr. Trump had a home in Palm Beach, correct? A. Uh-huh. Q. So he didn't come and stay there, did he? A. No, never. Q. He would come for a meal? A. He would come, have dinner. He never sat at the table. He eat with me in the kitchen. Q. Did he ever have massages while he was there? A. No. Because he's got his own spa. Q. Sure. MS. EZELL: I don't have any other questions right now. I'd just like to reserve if something comes up to ask. But, otherwise, you may go ahead. MR. LANGINO: It is noon, so I don't know what everybody else's schedule is. I don't know how you're feeling. THE WITNESS: I am fine. MS. EZELL: I do have another question. May I ask it? Page 76 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. EZELL: Q. Since I did miss it, if you don't mind, let me just ask you again. Would you describe for me what kinds of vibrators you found? A. I'm not familiar -- not too familiar with the names, but they were big dildos, what they call the big rubber things like that (indicating). And I used to go and put my gloves on and pick them up, put them in the sink, rinse it off and put it in Ms. Maxwell -Ms. Maxwell had in her closet, she had, like, a laundry basket, one of those laundry basket that you put laundry in. She have full of those toys. And that was -- and that was me being professional, leaving the room ready for bed when he would come back to the room again. Q. Okay. A. That happened a few times, few times. Q. Were there other sex toys that you found in the area -A. No. Q. -- sometimes? You mentioned she kept them in a basket in her closet? A. She kept them in her basket. She had some videos there and she have a costume there. I know that she bought it, that she brought it with her. 19 (Pages 73 to 76) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) (561) 832-7506 76ef564a-4a1c-4dee-87ac-479898cc7004 Case 9:08-cv-80736-KAM Document 291-17 Entered on FLSD Docket 01/21/2015 Page 8 of 8 Page 77 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. What kind of costume? A. I don't know. It was a black, shiny costume. I never saw it on her. Q. Was it leather? A. No. I think it was like a vinyl. But we were very fussy about touching any of that stuff. We just... MS. EZELL: No other questions. Thank you, sir. THE WITNESS: You're welcome. MR. LANGINO: I shouldn't have more than a half hour's worth of questions, if everybody is okay to power through. MR. BERGER: I probably have a half hour to an hour. MR. LANGINO: Okay. MR. BERGER: Unless you cover what I cover. MR. MERMELSTEIN: I could say the same thing, so probably less than that. MR. LANGINO: So I guess my question is -MR. BERGER: I think we ought to take a break. MR. LANGINO: That was my question. MR. BERGER: We're going to take a break. Do you have any problem with that? THE WITNESS: No. Whatever you guys want to do. Page 79 1 2 3 4 5 6 7 8 9 10 11 12 13 14 CERTIFICATE OF OATH STATE OF FLORIDA COUNTY OF PALM BEACH I, the undersigned authority, certify that JUAN ALESSI personally appeared before me and was duly sworn on the 8th day of September, 2009. Dated this 19th day of September, 2009. ____________________________________ 15 16 17 18 19 20 21 22 23 24 25 Sandra W. Townsend, Court Reporter Notary Public - State of Florida My Commission Expires: 6/26/12 My Commission No.: DD 793913 Page 78 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Lunch recess.) (Continued to Volume II.) Page 80 1 2 3 4 5 6 7 8 CERTIFICATE STATE OF FLORIDA COUNTY OF PALM BEACH I, Sandra W. Townsend, Court Reporter and Notary Public in and for the State of Florida at Large, do hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth; that I was authorized to and did report said deposition in stenotype; and that the foregoing pages numbered 1 to 78, inclusive, are a true and correct transcription of my shorthand notes of said deposition. 9 10 11 12 13 14 15 16 I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. I further certify that I am not attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. 17 18 Dated this 19th day of September, 2009. 19 20 _____________________________________ 21 Sandra W. Townsend, Court Reporter 22 23 24 25 20 (Pages 77 to 80) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401-377-676-2895) Electronically signed by Sandra Townsend (401-377-676-2895) (561) 832-7506 76ef564a-4a1c-4dee-87ac-479898cc7004